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MEMORANDUM OPINION & ORDER   Plaintiff Ladders, Inc. (“Ladders”) commenced this action on October 27, 2020, by filing the Complaint. (Compl. [ECF No. 1].) The Complaint alleges that Ladders is a Delaware corporation with offices in New York (Compl. 1); Defendant Vindicia, Inc. (“Vindicia”) is a Delaware corporation with offices in California (Compl. 2); Defendant Paul Larsen (“Larsen”) resides in New York (Compl. 3); and Defendant PLC, LLC, d/b/a Paul Larsen Consulting (“PLC”), is a New York limited liability company with offices in New York (Compl. 4). Ladders alleges that, in 2017, it hired Vindicia for integration and credit card processing services based on PLC’s recommendation and self-proclaimed consulting expertise in the area. (Compl.

6, 24, 26-27.) Ladders further alleges that Vindicia’s services were grossly deficient and resulted in millions of dollars in losses to Ladders. (Compl. 6.) The Complaint alleges six causes of action: (I)replevin; (II) conversion; (III) breach of contract; (IV) gross negligence; (V) unjust enrichment; and (VI) negligent misrepresentation. (Compl.

 
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