The following excerpt is from Cofacredit v. Windsor Plumbing Supply, 187 F.3d 229 (2nd Cir. 1997):
To prove a conspiracy, a plaintiff must show a corrupt agreement, an overt act in furtherance of that agreement, and membership in the conspiracy by each defendant. See Kashi v. Gratsos, 790 F.2d 1050, 1055 (2d Cir. 1986). As is true in criminal conspiracies, agreements in civil conspiracies will not easily be shown by direct evidence, but may be inferred from circumstantial evidence. In this case, there is ample evidence to support the conclusion that there was a conspiracy.
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