1691 Fulton Ave. Assoc., L.P. v. Washington

2024 NY Slip Op 30411(U)
CourtCivil Court Of The City Of New York, Bronx County
DecidedFebruary 7, 2024
StatusUnpublished

This text of 2024 NY Slip Op 30411(U) (1691 Fulton Ave. Assoc., L.P. v. Washington) is published on Counsel Stack Legal Research, covering Civil Court Of The City Of New York, Bronx County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
1691 Fulton Ave. Assoc., L.P. v. Washington, 2024 NY Slip Op 30411(U) (N.Y. Super. Ct. 2024).

Opinion

1691 Fulton Ave. Assoc., L.P. v Washington 2024 NY Slip Op 30411(U) February 7, 2024 Civil Court of the City of New York, Bronx County Docket Number: Index No. 313351/21 Judge: Travis J. Arrindell Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. LT-313351-21/BX [HO] FILED: BRONX CIVIL COURT - L&T 02/08/2024 07:44 AM NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 02/08/2024

NEW YORK CITY CIVIL COURT COUNTY OF BRONX: HOUSING PART B ----------------------------------------------------------------X 1691 FULTON AVENUE ASSOCIATES, L.P.,

Petitioner - Landlord, DECISION AND ORDER v. L&T 313351/21 SHANELLE WASHINGTON, “JOHN DOE,” and “JANE DOE,”

Respondents (Occupants).

----------------------------------------------------------------X Present: HON. TRAVIS J. ARRINDELL Judge, Housing Court

Recitation, as required by CPLR §2219(A), of the papers considered in the review of Respondent’s motion to amend and Petitioner’s cross-motion to deem their service affidavit filed timely nunc pro tunc and use and occupancy: Papers Respondent’s Motion (Numbered 14-20 on NYSCEF).......…….................……..……...... 1 Petitioner’s Cross motion and Opposition (Numbered 21-26 on NYSCEF)……............... 2 Respondent’s Reply (Numbered 19 on NYSCEF)....……............................…….............. 3 ____________________________________________________________ TRAVIS J. ARRINDELL, J.:

After review of the papers, Respondent’s motion seeking to amend their answer is granted, and Petitioner’s cross-motion seeking the affidavit of service timely filed, nunc pro tunc, and use and occupancy is denied.

Respondent’s Motion to Amend

Pursuant to CPLR § 3025(b) “A party may amend [their] pleading …at any time by leave of court. Leave shall be freely given upon such terms as may be just…” The granting or denying of a motion to amend is a matter of judicial discretion.1 “Mere lateness is not a barrier to the amendment. It must be lateness coupled with significant prejudice to the other side.”2 Prejudice has been defined as a special right lost in the interim, a change of position, or significant trouble or expense that could have been avoided had the original pleading contained the proposed

1 Murray v. New York, 43 N.Y.2d 400. 2 Siegal, Practice Commentaries, McKinney’s Cons. Laws of New York, Book 7B, CPLR 3025:5 at 356.

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amendment.3 Courts should also “examine the sufficiency of the merits of the proposed amendment when considering such motions. [If] the proposed amendments are totally devoid of merit and are legally insufficient, leave to amend should be denied.”4 Furthermore, “it has been repeatedly held that defenses waived under CPLR § 3211 (e) can nevertheless be interposed, with court leave, in an amended answer, provided the amendment does not cause the plaintiff ‘prejudice or surprise resulting directly from the delay.’”5 Petitioner fails to allege any facts in their opposition demonstrating any prejudice if the Court were to grant Respondent’s amendment. Petitioner’s opposition is devoid of any allegations demonstrating a special right lost, a change of position, or significant trouble or expense that could have been avoided. Furthermore, but for Respondent’s jurisdictional defense, Petitioner is prepared to allow the amendment.6 Petitioner argues that Respondent’s jurisdictional defense lacks merit therefore their motion to amend must be denied. However, the opposite is true; Respondent’s jurisdictional defense has merit. Pursuant to RPAPL § 733 (1) “…the notice of petition and petition shall be served at least ten and not more than seventeen days before the time at which the petition is noticed to be heard.” Furthermore, pursuant to RPAPL § 735 (2), service of the notice of petition and petition by conspicuous service is complete only upon filing proof of service. It is undisputed by the parties that the Notice of Petition and Petition was noticed to be heard on December 7, 2021. Additionally, it is undisputed that the Notice of Petition and Petition was served upon Respondent by conspicuous service on November 24, 2021. Finally, it also undisputed Petitioner completed service of the Notice of Petition and Petition by filing their service affidavit on November 29, 2021, eight days prior to the December 7, 2021 return date.7 Since Petitioner short served the Notice of Petition and Petition pursuant to RPAPL § 733, Respondent’s jurisdictional defense has merit and the Court in its discretion grants Respondent’s motion to amend.

Petitioner’s Cross-motion to Deem the Affidavit of Service Timely Filed.

In the alternative, though Petitioner admits that they short served the Notice of Petition and Petition pursuant to RPAPL § 733, they argue that Respondent suffered no prejudice by their late filing and that the Court should overlook the filing defect.8 However, Petitioner’s argument lacks merit. In Riverside Syndicate, Inc. v. Saltzman, 49 A.D.3d 402, 402, the Appellate Division First Department (Appellate Division) dismissed a summary proceeding because the landlord failed to complete service within the statutory time frame as required by RPAPL § 733. The Court in Saltzman, 49 A.D.3d 402, noted “a summary proceeding is a special proceeding ‘governed entirely by statute . . . and it is well established that there must be strict compliance

3 Heller v. Louis Provenzano, Inc., 303 A.D.2d 20. 4 Id., at 25. 5 See Armstrong v. Peat, Marwick, Mitchell & Co., 150 A.D.2d 189, 190 (citing Fahey v County of Ontario, 44 NY2d 934, 935). 6 See Petitioner’s Affirmation in Support of Cross Motion and in Opposition to Respondent’s Motion to Amend (NYSCEF Doc. # 22), at ¶ 15. 7 See NYSCEF Doc. # 7. 8 See Petitioner’s Affirmation in Support of Cross Motion and in Opposition to Respondent’s Motion to Amend (NYSCEF Doc. # 22), at ¶ 11 (citing CPLR § 2001).

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with the statutory requirements to give the court jurisdiction.’”9 It is important to note, that the Appellate Division in Saltzman, 49 A.D.3d 402, overruled the lower court’s, Appellate Term First Department, decision in this matter finding “In the absence of any discernible prejudice to tenants, landlord's one-day delay in filing proof of service of the petitions did not require dismissal of these otherwise properly commenced holdover proceedings.”10 The Appellate Division in its holding to “strict compliance” rejected the prejudice analysis followed by the lower court and other cases relied on by Petitioner such as Jamal Estates v. Crockwell, 113 Misc. 2d 548 (Appellate Term 1st Dept.,1982) (holding a landlord may seek nunc pro tunc relief from a late filing absence prejudice). Because Saltzman, 49 A.D.3d 402, requires strict compliance and rejects an analysis on prejudice, Petitioner’s cross-motion seeking their service affidavit timely filed, nunc pro tunc, is denied.

Petitioner’s Cross-motion for Use and Occupancy

Petitioner’s cross-motion for use and occupancy is denied. RPAPL § 745(2) states:

2.

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Related

Murray v. City of New York
372 N.E.2d 560 (New York Court of Appeals, 1977)
People ex rel. Hamilton v. Dalsheim
505 N.E.2d 951 (New York Court of Appeals, 1987)
Riverside Syndicate, Inc. v. Saltzman
49 A.D.3d 402 (Appellate Division of the Supreme Court of New York, 2008)
Berkeley Associates Co. v. Di Nolfi
122 A.D.2d 703 (Appellate Division of the Supreme Court of New York, 1986)
Armstrong v. Peat, Marwick, Mitchell & Co.
150 A.D.2d 189 (Appellate Division of the Supreme Court of New York, 1989)
MSG Pomp Corp. v. Doe
185 A.D.2d 798 (Appellate Division of the Supreme Court of New York, 1992)
Heller v. Louis Provenzano, Inc.
303 A.D.2d 20 (Appellate Division of the Supreme Court of New York, 2003)
Jamal Estates v. Crockwell
113 Misc. 2d 548 (Appellate Terms of the Supreme Court of New York, 1982)

Cite This Page — Counsel Stack

Bluebook (online)
2024 NY Slip Op 30411(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/1691-fulton-ave-assoc-lp-v-washington-nycivctbronx-2024.