On August 20, 2015, Justice Kornreich of the New York County Commercial Division issued a decision in Dionne-Tontchev v. Worldwide Wealth Management Corp., 2015 NY Slip Op. 31587(U), rejecting a referee’s recommended award of punitive damages on the plaintiff’s breach of contract, quasi-contract and tort claims, because “[n]o testimony was elicited as to why punitive damages are appropriate in this case. Nor did [the] J.H.0. . . . explain why $250,000 is an appropriate punitive damages award.” The trial court gave the plaintiff a choice: he could ask the court to remand the matter to the J.H.O. “for further proceedings to establish a sufficient record upon which a punitive damages award may be based” or he could “forgo his punitive damages claim and seek entry of judgment in the amount of” the compensatory damages awarded.