Defendant moves for dismissal of plaintiff's first and second causes of action pursuant to CPLR 3211 (a) (7) or, alternatively, for summary judgment pursuant to CPLR 3212 (b). Plaintiff cross-moves for summary judgment on her first cause of action and also moves to amend her complaint with respect to the second cause of action increasing the ad damnum clause from $50,000 to $500,000.
The facts underlying this action are as...
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