Board of Mgrs. of Tribeca Townhomes v. 16 Warren St. PH, LLC

2025 NY Slip Op 34413(U)
CourtNew York Supreme Court, New York County
DecidedNovember 14, 2025
DocketIndex No. 850018/2025
StatusUnpublished

This text of 2025 NY Slip Op 34413(U) (Board of Mgrs. of Tribeca Townhomes v. 16 Warren St. PH, LLC) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Board of Mgrs. of Tribeca Townhomes v. 16 Warren St. PH, LLC, 2025 NY Slip Op 34413(U) (N.Y. Super. Ct. 2025).

Opinion

Board of Mgrs. of Tribeca Townhomes v 16 Warren St. PH, LLC 2025 NY Slip Op 34413(U) November 14, 2025 Supreme Court, New York County Docket Number: Index No. 850018/2025 Judge: Francis A. Kahn III 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. [FILED: NEW YORK COUNTY CLERK 11/18/2025 01:00 PM] INDEX NO. 85 00l 8 / 2 0 25 NYSCEF DOC. NO. 130 .~CEIVED NYSCEF: 11/17/2025 SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. FRANCIS A. KAHN, Ill PART 32 Justice ------------------------------------------------------------------------X INDEX NO. 850018/2025 BOARD OF MANAGERS OF TRIBECA TOWNHOMES AT MOTION DATE 16 WARREN STREET CONDOMINIUM ON BEHALF OF THE UNIT OWNERS OF TRIBECA TOWNHOMES AT 16 WARREN STREET, MOTION SEQ. NO. 001 Plaintiff, - V -

16 WARREN STREET PH, LLC,JPMORGAN CHASE DECISION + ORDER ON BANK, N.A., JOHN DOE AND MARY DOE, MOTION

Defendant. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 001) 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 105,106,107,108,109,110,111,112,113,114,115,116,117,118,119,120,121,122,123 were read on this motion to/for JUDGMENT - SUMMARY

Upon the foregoing documents, the motion is determined as follows:

Plaintiff commenced this action to foreclose on a purported lien for unpaid common charges encumbering a premises located at 16 Warren Street, Unit PH, New York, New York. Defendant 16 Warren Street PH, LLC, the unit owner, answered and pled eight affirmative defenses as well a counterclaim. Plaintiff replied to the counterclaim. Now, Plaintiff moves for summary judgment against the appearing parties, a default judgment against the non-appearing parties, striking the appearing parties' answer and affirmative defenses and appointing a referee to compute. Defendant opposes the motion.

With respect to the cause of action for foreclosure of the lien for common charges, Real Property Law §339-aa provides that such a claim "may be foreclosed by suit authorized by and brought in the name of the board of managers, acting on behalf of the unit owners, in like manner as a mortgage of real property" (see Board of Mgrs. of the Parkchester N. Condominium v. Alaska Seaboard Partners Ltd. Partnership, 37 AD3d 3 32 [1 st Dept 2007]). In this case, Plaintiff must submit proof of its "authority to collect common charges from the owners of units and, in the event of nonpayment, to add late fees, interest, attorneys' fees and other costs of collection to the assessment" (Board of Mgrs. of W Amherst Off Park Condominium v RMFSG, LLC, 153 AD3d 1611 [4 th Dept 2017]). In addition, Plaintiff must demonstrate the reliability of or how the amounts were calculated (see Board of Mgrs. of Natl. Plaza Condominium Iv. Astoria Plaza, LLC, 40 AD3d 564 [2d Dept 2007]). As in all foreclosure actions, a plaintiff moving for summary judgment, must establish a prima facie case exists to foreclose with proof in evidentiary form (see CPLR §3212[b]; U.S. Bank, NA., v James, 180 AD3d 594 [1 st Dept 2020]; Tri-State Loan Acquisitions Ill, LLC v Litkowski, 172 AD3d 780 [1 st Dept 2019]; Bank ofNYv Knowles, 151 AD3d 596 [Pt Dept 2017]). Here, Plaintiff demonstrated with the affidavit of Chelseay Boulos ("Boulos"), the President of Plaintiff, its authority to collect common charges and that its method of calculation was reliable. As such, Plaintiff demonstrated, primafacie, its entitlement to summary judgment on its foreclosure cause of action.

850018/2025 BOARD OF MANAGERS OF TRIBECA TOWNHOMES AT 16 WARREN STREET Page 1 of 4 CONDOMINIUM ON BEHALF OF THE UNIT OWNERS OF TRIBECA TOWNHOMES AT 16 WARREN STREET vs. 16 WARREN STREET PH, LLC ET AL Motion No. 001

1 of 4 [* 1] [FILED: NEW YORK COUNTY CLERK 11/18/2025 01:00 P~ INDEX NO. 850018/2025 NYSCEF DOC. NO. 130 RECEIVED NYSCEF: 11/17/2025

As to the affirmative defenses, as pled, all are entirely conclusory and unsupported by any facts in the answer. As such, these affirmative defenses are nothing more than unsubstantiated legal conclusions which are insufficiently pled as a matter of law (see Board of Mgrs. of Ruppert Yorkville Towers Condominium v Hayden, 169 AD3d 569 [Pt Dept 2019]; see also Bosco Credit V Trust Series 2012-1 v. Johnson, 177 AD3d 561 [Pt Dept 2020]; 170 W Vil. Assoc. v. G & E Realty, Inc., 56 AD3d 372 [1st Dept 2008]; see also Becher v Feller, 64 AD3d 672 [2d Dept 2009]; Cohen Fashion Opt., Inc. v V & M Opt., Inc., 51 AD3d 619 [2d Dept 2008]). Further, to the extent that specific legal arguments were not proffered in support of any affirmative defense, those defenses were abandoned (see US. Bank NA. v Gonzalez, 172 AD3d 1273, 1275 [2d Dept 2019]; Flagstar Bank v Bellafiore, 94 AD3d 1044 [2d Dept 2012]; Wells Fargo Bank Minnesota, NA v Perez, 41 AD3d 590 [2d Dept 2007]).

In opposition, Defendant's suggestion the lien at issue is invalid as it fails to sufficiently specify "the date when due" pursuant to RPL §339-aa is without merit. That section does not require that charges forming the aggregate lien be itemized and dated accordingly. Without such a specific provision the viability of the lien is not "affect[ed] or impair[ ed]" (RPL §339-aa). This is in accord with the express directive that the Condominium Act be "liberally construed to effect the purposes thereof' (RPL §339-ii). Claimed defects in the unit, the common areas and disagreement with actions taken by a condominium board do not justify withholding payment of common charges (see Board of Mgrs. of Villas on the Lake Condominium v. Policicchio, 228 AD3d 610,612 [2d Dept 2024]; Mailman v Abbady, 216 AD2d 115 [1 st Dept 1995]).

Any argument concerning the amount due, including attorney's fees, is not a defense to summary judgment as it can be addressed during the reference (see 1855 E. Tremont Corp. v Collado Holdings LLC, 102 AD3d 567 [ pt Dept 2013 ]). Defendants' assertion the motion must be denied because no discovery has been conducted is unavailing as they have offered nothing to demonstrate Plaintiff is in exclusive possession of facts which would establish a viable defense to foreclosure of the lien (see Island Fed. Credit Union v. I&D Hacking Corp., 194 AD3d 482 [1 st Dept 2021 ]). Moreover, as "the affirmative defenses are precluded, no discovery could lead to facts that would warrant denial of plaintiffs summary judgment motion" (Bernstein v Dubrovsky, 169 AD3d 410 [1 st Dept 2019]).

The branch of Plaintiffs motion for a default judgment against the non-appearing parties is granted (see CPLR §3215; SRMOF II 2012-1 Trust v Tella, 139 AD3d 599,600 [1 st Dept 2016]). i The branch of Plaintiffs motion to amend the caption is granted (see generally CPLR §3025; JP Morgan Chase Bank, NA. v Laszio, 169 AD3d 885,887 [2d Dept 2019]). .I Defendant's counterclaim is severed as that cause of action is wholly dissimilar and separable from the lien foreclosure action (see Valley Sav. Bank v Rose, 228 AD2d 666 [2d Dept 1997]).

Accordingly, it is

ORDERED that Plaintiffs motion for a summary judgment against the appearing Defendants on the first, second, third and fourth causes of action is granted; and it is further

0 RD ERED that the branch of the motion for a default judgment against the non-appearing parties is granted; and it is further

ORDERED that Defendant's counterclaim is severed; and it is further

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Related

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139 A.D.3d 599 (Appellate Division of the Supreme Court of New York, 2016)
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Flagstar Bank v. Bellafiore
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Bluebook (online)
2025 NY Slip Op 34413(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/board-of-mgrs-of-tribeca-townhomes-v-16-warren-st-ph-llc-nysupctnewyork-2025.