The U.S. District Court for the Southern District of New York granted a life insurer's motion to dismiss claims for violations of New York's General Business Law § 349, for breach of the implied covenant of good faith and fair dealing, and for declaratory relief in a lawsuit alleging wrongful cost of insurance rate increase. Our firm represented the life insurer. Fleisher v. Phoenix Life Insurance Co., 858 F. Supp. 2d 290 (S.D.N.Y. 2012).