Aiding and Abetting Conversion as a Cause of Action in New York

“To state a cause of action for aiding and abetting conversion, the plaintiff must first establish the existence of an underlying conversion by the primary tortfeasor (William Doyle Galleries, Inc. v Stettner, 167 AD3d 501, 505 [1st Dept 2018]). The complaint must set forth sufficient factual allegations to support a strong inference that the defendant had actual knowledge of the underlying conversion or was willfully ignorant of it, and rendered substantial assistance to enable the harm to proceed by, for example, concealment or failure to act (Sayles v Ferone, 137 AD3d 486, 486 [1st Dept 2016]).” Shanghai Nonobank Fin. Info. Serv. Co. v. Jie, 2019 N.Y. Slip Op. 32043 (N.Y. Sup. Ct. 2019).