it by cooperation or request, or who lend aid or encouragement to the wrongdoer . are equally liable with him.” Putt- man, 149 F.3d at 122 (quoting Bichler v. Eli Lilly & Co. 55 N.Y.2d 571, 580, 450 N.Y.S.2d 776, 486 N.E.2d 182 (1982)). To be liable under either conspiracy or aiding and abetting, however