the Union violated New York Human Rights law by failing to contest the board-certification requirement. Although the complaint does not explain the basis for such liability, in light of the fact that the Union is not an “employer” under New York Human Rights law, liability must be based on Executive Law § 296(6), which forbids “aiding and abetting” of discrimination. See N.Y. Exec. Law § 296(6) (McKinney’s 1993) (making unlawful the aiding or abetting of “the acts forbidden under this article”). Because, as explained above, plaintiffs’ claims against the non-Union Defendants are without merit, there are no acts “forbidden under [that] article,” which could have been aided or abetted by the Union. See, e.g., Sowemimo v. D.A.O.R. Security, Inc., 43 F.Supp.2d 477, 490-91 (S.D.N.Y.1999) (<HOLDING>); Rivera v. Prudential Ins. Co., No. 95 CV 0829
holding that coconspirator liability for a  924c offense may be established under pinkerton liability holding no liability existed under the circumstances holding that title vii and nyhrl claims are arbitrable recognizing disagreement among district courts in the second circuit as to whether the standard for vicarious liability is the same under title vii and the nyhrl but interpreting second circuit law including quinn to indicate that nyhrl claims should be analyzed under the framework of title vii holding that liability under  2966 cannot attach without first finding employer liability for discrimination under nyhrl