Appellate Division of the Supreme Court of the State of New York November 4, 1983 (Irondequoit Bay Pure Waters District v. Nalews, Inc.)
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United States · · · 04-11-1983
Order unanimously affirmed, without costs. Memorandum: We note that a demand for punitive damages does not constitute a separate cause of action for pleading purposes. In any event, the complaint in this breach of contract action is insufficient to support a claim for punitive damages.
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