Madden v. Creative Services, Inc.
Plaintiffs George Madden and Roseanne Cohen filed a diversity action against Ralph Douglas Howe, Jr., Michael Sean Cole, National Amusements, Inc., Creative Services, Inc., Sklar, and Redstone. The suit arose from a break-in into the plaintiffs' attorney's office by Howe and Cole, employees of Creative Services, which was hired by National Amusements to investigate opposition to a proposed theater complex. Plaintiffs alleged various torts including intentional infliction of emotional distress, conversion, interference with attorney-client privilege, unlawful search and seizure, and negligent infliction of emotional harm. The court granted the defendants' motions to dismiss the complaint, finding that the alleged conduct did not meet the legal thresholds for the claimed torts under New York law and declined to create new causes of action. Consequently, all principal and derivative claims were dismissed.