They are, however, available for claims of negligent misrepresentations where "the defendant's conduct evinces a high degree of moral turpitude and demonstrates such wanton dishonesty as to imply a criminal indifference to civil obligations." Kemp v. Henry, 2017 WL 1901433, at *2 (E.D.N.Y. May 6, 2017) (quoting Hutchins v. Utica Mut. Ins. Co., 107 A.D.2d 871, 484 N.Y.S.2d 686, 688 (3d Dep't 1985)). Because portions of Plaintiff's negligent misrepresentation claim have not been dismissed, the Court declines to strike the request for punitive damages at this time.

In light of Plaintiff's pro se status, the Court will interpret the facts in all of Plaintiff's filings to raise "the strongest arguments they suggest." Kemp v. Henry, No. 17-CV-1020, 2017 WL 1901433, at *1 n.1 (E.D.N.Y. May 6, 2017) (citing Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474-76 (2d Cir. 2006); see also id. (considering the facts alleged in both the original complaint and the amended complaint in light of the plaintiff's pro se status after noting "the amended complaint completely replaces the original complaint"). In the Notice of Claim, Plaintiff asserts substantially identical allegations to the SAC and seeks identical relief. (Id. at 7-13.)