The Appellate Division, Second Department upheld the Supreme Court’s denial of the Plaintiff’s cross-motion for summary judgment to recover damages for conversion of funds. The Appellate Court affirmed the Trial Court’s holding that Plaintiff did not proffer sufficient prima facie evidence proving legal ownership of the allegedly converted funds. Sammy v. First Am. Title Ins. Co., 205 A.D.3d 949, 168 N.Y.S.3d 519 (2022).