Anyhow, a declare to possess Tennessee title loan conversion “can’t be according to just violation regarding package ” Piven v. Wolf Haldenstein Adler Freeman & Herz L.L.P., No. 08CI. 10578 (RJS), 2010 WL 1257326, at *9 (S.D.N.Y. )(citation omitted). “Rather, to state a claim for conversion, a plaintiff must allege ‘independent facts sufficient to give rise to tort liability.’” Id. (citations omitted). Homes Co Here, the Court finds that the Plaintiff’s conversion claim is simply a restatement of the breach of contract claim based on the Defendant’s assessment of overdraft fees. Thus, there is no basis for a claim that the Defendant violated an independent tort duty owed to the Plaintiff. F. The Unfair Enrichment Allege Under New York law, an unjust enrichment claim is a quasi-contract claim. As such, this claim generally exists only where there is no express agreement between the parties. Come across Valley Liquid Ltd., Inc. v. Evian Waters from France, Inc., 87 F.3d 604, 610 (2d Cir. 1996)(“Under New York law, ‘[t]he existence of a valid and enforceable written contract governing a particular subject matter ordinarily precludes recovery in quasi contract for events arising out of the same subject matter.’”)(citation omitted); D’Amato v. Kristina MurrayKristina Murray extensive work experience that varies from programming to PR, I have come to learn that my passion is in digital transformations, digital business development and digital strategy. The analysis of data to improve an online position for any company is what drives me. – Digital Business Development / Strategy – Social networking strategy. – Digital advertising – E-Comercio