SLOTNICK v. RBL AGENCY LTD.


271 A.D.2d 365 (2000)

706 N.Y.S.2d 431

NANCY L. SLOTNICK, Appellant, v. RBL AGENCY LTD., Respondent.

Appellate Division of the Supreme Court of the State of New York, First Department.

Decided April 27, 2000.


Plaintiff sued RBL for unpaid commissions and alleged two causes of action against her former employer, one for a breach of contract and the other for both attorney's fees and liquidated damages pursuant to Labor Law § 198 (1-a). The latter "cause of action" actually provides only a damage remedy for substantive violations of article 6 of the Labor Law and depends upon pleading and proof of such substantive violation (Gottlieb v Laub & Co.,

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