In so ruling, the Second Circuit noted that the complaint lacked any specifics as to dates, times, amount of alleged violations, and references to referral agreements and business referrals. The Court also pointed out that while not necessary to sustain a section 8(a) claim, there were no allegations that Defendant Title Companies charged any of the Plaintiffs a rate inflated by the alleged kickbacks.
Ralph T. Wutscher
McGinnis Tessitore Wutscher LLP
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