I've now read the Complaint, which does appear to spell out the elements of conversion, and even makes allegations typical of a case seeking punitive damages, although none are part of the prayer for relief. Strangely, the heading of Count One is "Breach of Contract--Lader Consignment Agreements", but no such agreements are described; instead and again, a claim for conversion is alleged. Headings are not themselves allegations, so I would argue the conversion claim is already asserted, which of course is unaffected by any statute of frauds contract defense (although the drafting appears sloppy and amendment may be needed).
Interestingly, the Complaint alleges that Goodwin texted Lader on January 10, 2017, acknowledging that the jersey had passed the authentication process with flying colors. If this text can be verified as coming from Goodwin, he's got some 'splainin to do.
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If we are to have another contest in the near future of our national existence, I predict that the dividing line will not be Mason and Dixon's but between patriotism and intelligence on the one side, and superstition, ambition and ignorance on the other. - Ulysses S. Grant, military commander, 18th US President.
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