Notes

against Jessica Guetta in which Ronen asserts that his wife breeched her fiduciary duties relative to their jointly owned LLC, among other things, misappropriating 2 million dollars from the company by diverting it to her personal accpunt and by intentionally sabotaging existing contracts relative to real estate construction and development deals of which the llc was a party. Also, assert a cause of action for breach of contract based upon the same facts. Also assert a cause of action for an accounting. Also, assert a cause of action for the imposition of a constructive trust upon the funds wrongly diverted by the wife. Also assert a cause of action for unjust enrichment. Use the following legal authority to help formulate the complaint:
Under New York law, the husband could potentially bring several claims against his wife given the scenario described [1]. First, he may have a claim for breach of fiduciary duty. This might be applicable if, for example, the wife owned a significant portion of the company's common stock and was in a position of power within the company, similar to a case where a wife was the CEO of a corporation, and the husband was able to successfully bring a claim of breach of fiduciary duty against her.

Second, the husband could potentially bring a claim for breach of contract. This would be applicable if the husband could prove that his wife's withdrawal of funds from the corporation constituted a breach of their contractual agreement, akin to the situation in Freedom Holding, Inc. v. Haart, where similar allegations were found to be sufficient to plead elements of breach of contract under New York law.

Third, the husband might have the option to request dissolution of the company or appointment of a temporary receiver. This could be relevant if the wife is found to have violated the company's LLC Agreements without the husband's knowledge or consent, similar to the case of N.F. v. J.D., where the court ruled in favor of the wife on this issue [2].

However, it is essential to note that the husband would need to provide evidence to support his claims. In Y.B. v. G.B., the court noted that allegations of intentional sabotage of the LLC and financial misappropriation must be supported by concrete evidence.

Furthermore, the husband's actions could also be scrutinized. This was the case in N.F. v. J.D., where the court found that the husband had violated the company's automatic orders, thereby opening himself up to potential counterclaims or defenses by the wife.

In terms of the funds diverted to the wife's personal accounts, New York law has also allowed for the imposition of a constructive trust over funds or assets in certain cases. In Ptachewich v. Ptachewich, a constructive trust was imposed in favor of the wife when the husband had unjustly retained the use of the parties' joint funds to the exclusion of the wife.

Lastly, while the search results did not provide a direct equivalent to the wife's alleged sabotage of company projects, the courts' emphasis on the need for evidence to support such claims indicates that the husband would need to provide substantial evidence to prove this.

The LLC is Guetta building company LLC. It is a domestic New York state limited liability company. It was formed on April 7, 2016. It was formed in Nassau County. It's principal place of business is 115 sycamore Drive, Roslyn, New York 11576. Both plaintiff and defendant reside at that address. Please name the LLC as an additional party defendant, but do not allege any of the causes of action against that defendant. Certainly, it should be referenced in the parties section of the pleading.