First, a member or shareholder seeking an accounting must establish that a pre-suit demand for such an accounting was made and refused (New York Studios, Inc. v Steiner Digital Studios, 151 AD3d 454, 455 [1st Dept 2017] [“In the absence of an allegation that plaintiffs demanded an accounting, the claim for an accounting fails to state a cause of action”]; Mawere v Landau, 130 AD3d 986, 990 [2d Dept 2015]… [read post]