Freedom to Defraud?!

The early dismissal is dependent on the court's upholding of some pretty egregious fraud allegations, based on the alleged written disclosure of those very frauds, and the presence of a merger clause. Does this ruling mean that New York law permits a contract defendant to avoid fraud claims merely by disclaiming in writing the very fraud that defendant has committed?

Both the Driver's Ed Plaintiff and the Etiquette Plaintiffs have filed appeals to the Second Circuit Court of Appeals.