January 24, 2024

The limitations period for breach of fiduciary duty and conversion.

The six-year statute of limitations under CPLR 213(8) applies to causes of action to recover damages for breach of fiduciary duty and conversion, since allegations of fraud are essential to, and not merely incidental to, the cause of action.

Gam v. Dvir, NY Slip Op 00181 (2d Dep't January 17, 2024)

Here is the decision.