OPINION & ORDER Plaintiff filed this motion for dispositive sanctions pursuant to Federal Rule of Civil Procedure 37(b) on February 27, 2019. The motion is GRANTED in part and DENIED in part. BACKGROUND Plaintiff filed her complaint on December 6, 2017, asserting claims for reformation of contract, breach of contract, rescission of contract, conversion and punitive damages. The Court granted partial summary judgment on the reformation, rescission, and breach of contract claims on January 15, 2019, and entered judgment in favor of Plaintiff for $500,023 plus interest. This motion followed immediately after the Court’s partial summary judgment decision. It seeks case dispositive sanctions on the remaining conversion count and an award of punitive damages.1 The basis for the sanctions motion is Defendant’s consistent failure to comply with the Court’s orders and her discovery obligations. Throughout this litigation, Defendant has been ordered and refused to respond to Plaintiff’s discovery requests. The Court has ordered Defendant to comply with her discovery obligations at least three times. The parties served initial discovery requests in May 2018. One month later, on June 15, 2018, the parties submitted a joint status letter informing the Court that Defendant had not responded to Plaintiff’s discovery requests. ECF No. 23. Accordingly, the Court ordered Defendant to respond by July 9, 2018. ECF No. 24. On July 12, 2018, the parties submitted a second status letter, again informing the Court that Defendant had not responded to discovery requests. ECF No. 25. A week later, following a telephone conference with the parties, the Court again ordered Defendant to respond to Plaintiff’s discovery requests by July 27, 2018. ECF No. 27. By August of 2018, the parties seemed prepared to settle and the matter was stayed through September 14, 2018, to facilitate negotiation. Settlement negotiations proved unfruitful though, and on November 5, 2018, the parties submitted another joint status letter informing the Court for a third time that Defendant had still not responded to discovery requests. ECF No. 42. The Court again ordered that Defendant respond to discovery requests by January 11, 2019. In the alternative, the Court invited Plaintiff to file a motion seeking appropriate relief. ECF No. 43. In their January 15, 2019 joint status letter, the parties informed the Court for a fourth time of Defendant’s failure to respond to discovery requests and of her failure to attend her own deposition. ECF No. 44. Following a telephone conference on January 25, 2019, the Court ordered Plaintiff to file a motion for relief. See ECF No. 47. A month later, on February 27, 2019, Plaintiff filed this motion for case dispositive sanctions pursuant to Federal Rule of Civil Procedure 37(b)(2). LEGAL STANDARD A district court has “wide discretion in sanctioning a party for discovery abuses.” Reilly v. Natwest Markets Grp. Inc., 181 F.3d 253, 267 (2d Cir. 1999). Rule 37(b)(2) provides a non-exhaustive list of sanctions for failure to obey a court order compelling discovery, including, inter alia, directing that “matters embraced in the order or other designated facts be taken as established” and “rendering a default judgment against the disobedient party.” In addition, Rule 37(b)(2)(C) requires a court to order a party who has disobeyed discovery orders to pay reasonable expenses, including attorney’s fees, caused by the noncompliance “unless the failure was substantially justified or other circumstances make an award of expenses unjust.” Factors relevant to the court’s determination of appropriate sanctions are: “(1) the willfulness of the noncompliant party or the reasons for noncompliance; (2) the efficacy of lesser sanctions; (3) the duration of the period of noncompliance; and (4) whether the noncompliant party had been warned of the consequences of his noncompliance.” Nieves v. City of New York, 208 F.R.D. 531, 535 (S.D.N.Y. 2002) (citing Bambu Sales, Inc. v. Ozak Trading Inc., 58 F.3d 849, 852-54 (2d Cir. 1995)). When failure to comply with a court order is “due to willfulness, or bad faith, or is otherwise culpable,” severe sanctions like default judgment and taking adverse facts as established are justified. See Daval Steel Prod., a Div. of Francosteel Corp. v. M/V Fakredine, 951 F.2d 1357, 1367 (2d Cir. 1991). DISCUSSION Plaintiff requests that the Court enter judgment on her conversion claim and grant her punitive damages. Specifically, the Plaintiff requests that the “Court determine facts in a manner adverse to Defendant” such that Plaintiff would be entitled to judgment on her conversion claim and an award of punitive damages. Although no fraud count is pled, Plaintiff also requests that the Court find that Defendant’s conduct alleged in the complaint constituted intentional fraud. Plaintiff argues that Defendant’s refusal to respond to discovery requests or appear at her deposition deprived Plaintiff of an opportunity to establish that the Defendant misappropriated Plaintiff’s investment for a purpose other than what Plaintiff intended. Such discovery would have also established the fraudulent nature of Defendant’s conduct. Defendant does not contest that she has failed to provide any discovery. She also does not offer an explanation or excuse for her noncompliance. Nonetheless, Defendant argues that, despite numerous refusals to comply with court orders, she should not be sanctioned or ordered to pay punitive damages. Defendant argues that Plaintiff has failed to state a claim for conversion or to plead a distinct claim of common law fraud. Defendant also argues that Plaintiff’s breach of contract claim was resolved and that further relief arising from Defendant’s failure to comply with discovery orders is therefore unwarranted. I. Default Judgment on Conversion Claim To state a claim for conversion, a plaintiff must establish (1) legal ownership of a specific, identifiable piece of property; and (2) the defendant’s exercise of dominion over or interference with the property in defiance of the plaintiff’s rights. Regions Bank v. Wieder & Mastroianni, P.C., 526 F. Supp. 2d 411, 413 (S.D.N.Y. 2007), aff’d, 268 F. App’x 17 (2d Cir. 2008). If the defendant’s possession was initially lawful, conversion is established only if she refuses to return the property or wrongfully transfers or disposes of it before a transfer is made. Id. Even if a plaintiff can establish the elements, a claim for conversion will be dismissed if it is merely duplicative of a breach of contract claim. See Wechsler v. Hunt Health Sys., Ltd., 330 F. Supp. 2d 383, 431 (S.D.N.Y. 2004) (noting that a conversion claim may be dismissed as duplicative of a contract claim even though the conversion claim “satisf[ies] the technical elements of that tort” (internal quotation marks and citation omitted)); Richbell Info. Servs., Inc. v. Jupiter Partners, 765 N.Y.S.2d 575, 590 (1st Dep’t 2003) (holding that plaintiff’s action for conversion, “while satisfying the technical elements of that tort, was properly dismissed as duplicative of the insufficient contract claims” (citations omitted)). The parties dispute whether a conversion claim lies where the property at issue is money. “Where the property is money, it must be specifically identifiable and be subject to an obligation to be returned or to be otherwise treated in a particular manner.” Republic of Haiti v. Duvalier, 626 N.Y.S.2d 472, 475 (1st Dep’t 1995). Conversely, “if the allegedly converted money is incapable of being described or identified in the same manner as a specific chattel, it is not the proper subject of a conversion action.” Cal Distrib., Inc. v. Cadbury Schweppes Ams. Beverages, Inc., No. 06-CV-0496 (RMB), 2007 WL 54534, at *11 (S.D.N.Y. Jan. 5, 2007) (quoting Interior by Mussa, Ltd. v. Town of Huntington, 664 N.Y.S.2d 970, 972 (2d Dep’t 1997)). See also Horn v. Toback, 989 N.Y.S.2d 779, 782 (2d Dep’t 2014) (holding that defendant was entitled to summary judgment on conversion claim because the claim “seeks merely to recover an allegedly unpaid debt, and does not seek to recover money from a discrete, identifiable fund”); Grgurev v. Licul, 229 F. Supp. 3d 267 (S.D.N.Y. 2017) (denying motion to dismiss where funds were specifically identifiable as federal disaster relief funds). While Plaintiff was denied the opportunity to develop facts to establish that the money she invested was “specifically identifiable,” her pleadings allege nothing that would entitle her, as a matter of law, to judgment on this claim. The Court is unwilling to exercise its discretion to invent facts to support a conversion claim on what is essentially an unpaid debt claim. See Compl. Count IV for Conversion,
