Cohen v. Rosenberg

2026 NY Slip Op 30798(U)
CourtNew York Supreme Court, New York County
DecidedMarch 6, 2026
DocketIndex No. 159685/2024
StatusUnpublished
AuthorMatthew V. Grieco

This text of 2026 NY Slip Op 30798(U) (Cohen v. Rosenberg) 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
Cohen v. Rosenberg, 2026 NY Slip Op 30798(U) (N.Y. Super. Ct. 2026).

Opinion

Cohen v Rosenberg 2026 NY Slip Op 30798(U) March 6, 2026 Supreme Court, New York County Docket Number: Index No. 159685/2024 Judge: Matthew V. Grieco 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.

file:///LRB-ALB-FS1/Vol1/ecourts/Process/covers/NYSUP.1596852024.NEW_YORK.001.LBLX000_TO.html[03/13/2026 3:45:57 PM] !FILED: NEW YORK COUNTY CLERK 03/10/2026 09: 40 AM! INDEX NO. 159685/2024 NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 03/09/2026

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. MATTHEW V. GRIECO PART 30M Justice ---------------------------------------------------------------------------------X INDEX NO. 159685/2024 DAN COHEN, MOTION DATE 12/31/2025 Plaintiff, MOTION SEQ. NO. 001 - V -

COREY ROSENBERG, GG1 LLC DECISION + ORDER ON MOTION Defendant. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 001) 13, 14, 15, 16, 17, 18, 19, 20 were read on this motion to/for JUDGMENT - DEFAULT

Upon the foregoing documents, and for the reasons stated infra, plaintiffs

motion for a default judgment is denied.

Plaintiff, Dan Cohen, commenced this action on October 17, 2024, alleging that

defendant Corey Rosenberg, another tenant in the building where he lived, assaulted

him on August 11, 2024 by punching him numerous times in the face and body, and that

defendant GG1 LLC, the owner and operator of the building, negligently failed to protect

him (NYSCEF Doc. No. 1 [Summons and Complaint]).

On December 18, 2024, defendant Rosenberg filed an answer with counterclaims

for trespass, private nuisance, and intentional infliction of emotional distress (NYSCEF

Doc No. 6). Plaintiff replied to the counterclaims (NYSCEF Doc. No. 7).

To date, defendant GG1 LLC has neither answered nor appeared.

On December 31, 2025, plaintiff moved for a default judgment pursuant to CPLR

3215 against defendant GG1 LLC (NYSCEF Doc. Nos. 13-14).

159685/2024 COHEN, DAN vs. ROSENBERG, COREY ET AL Page 1 of 4 Motion No. 001

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A plaintiff seeking default judgment against a non-appearing defendant must

move within one year of the default (see CPLR 3215[c]), and file proof of: (1) service of

the summons and complaint, or summons with notice; (2) the facts constituting the

claim; and (3) the default (see CPLR 3215[f]; Bigio v Gooding, 213 AD3d 480, 481 [1st

Dept 2023]).

To establish the "facts constituting the claim," the movant need only demonstrate

"enough facts to enable a court to determine that a viable cause of action exists"

(Woodson v Mendon Leasing Corp., 100 NY2d 62, 71 [2003]), which can be effected by

affidavit of a party or by verified complaint, if one has been properly served (see id. at

70; CPLR 3215[f]). The "standard of proof is not stringent, amounting only to some

firsthand confirmation of the facts" (Joosten v Gale, 129 AD2d 531,535 [1 st Dept 1987]).

Here, plaintiff has established service on GG1 LLC, by submitting an affidavit of

service through the Secretary of State under Business Corporation Law§ 306(b)

(NYSCEF Doc. No. 3, 18), and an affidavit of the additional service by mail required by

CPLR 3215(g)(4) (NYSCEF Doc. No. 12, 19) (see Sterk-Kirch v Uptown

Communications & Elec., Inc., 124 AD3d 413 [1 st Dept 2015]).

As to the facts constituting the claim, plaintiff proffers: the complaint, verified by

plaintiff personally (NYSCEF Doc. No. 1, 16), his affirmation on the motion (NYSCEF

Doc. No. 20), a copy of his lease (NYSCEF Doc. No. 17), and an affirmation of counsel

NYSCEF Doc. No. 15). The verified complaint states, in pertinent part:

For a period commencing on or about ,June 1, 2024, and continuing to present, the other tenant [defendant Rosenberg] has engaged in a pattern of harassment against the Plaintiff. The other tenant has verbally abused and assaulted the plaintiff. The other tenant has played loud music throughout the night creating an unbearable living situation for the Plaintiff and the owner [defendant GG 1 LLC] has been notified of this situation on many occasions and has refused to act. The other tenant had

159685/2024 COHEN, DAN vs. ROSENBERG, COREY ET AL Page 2 of 4 Motion No. 001

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and has dangerous, violent propensities, and the owner was aware of these violent and dangerous propensities. Finally, because of the owner's failure to act, the other tenant assaulted the plaintiff on August 11, 2024.

The tenant had been making threats against the Plaintiff for months. As well as engaging in all night parties and loud noise which the owner had and [sic] constructive knowledge about [NYSCEF Doc. No. 1, 16 ,i 7, 20].

There is no question that "[l]andlords have a common-law duty to take minimal

precautions to protect tenants from foreseeable harm, including a third party's

foreseeable criminal conduct" (Burgos v Aqueduct Realty Corp., 92 NY2d 544, 548

[1998] [internal quotes and cites omitted]). However, "[a] landlord has no duty to

prevent one tenant from attacking another tenant unless it has the authority, ability, and

opportunity to control the actions of the assailant" (Britt v New York City Rous. Auth.,

3 AD3d 514,514 [2d Dept 2004], lv denied 2 NY3d 705 [2004]; see Simms v St.

Nicholas Ave. Hotel Co., 187 AD2d 373 [1st Dept 1992], lv denied 81 NY2d 704 [1993]).

The power to evict does not furnish a landlord "with a reasonable opportunity or

effective means to prevent or remedy [a tenant's] unacceptable conduct [where] the

incident giving rise to the injuries sustained, and indeed, the pattern of harassment

alleged by the plaintiff, arose from a purely personal dispute between the two

individuals" (Blatt v New York City Rous. Auth., 123 AD2d 591, 593 [2d Dept 1986]

[internal quotes omitted], lv denied 69 NY2d 603 [1987]).

Plaintiff has not sufficiently proven the facts constituting the claim as to the

foreseeability of the assault or GG1 LLC's reasonable opportunity to control Rosenberg's

actions (see Henry v Storage Post, 181 AD3d 543 [1 st Dept 2020] [summary judgment

granted to landlord where, even accepting purported hearsay statement of an employee

oflandlord that he had "had problems with the tenant, who harassed other tenants, and

had called the police twice about him, and that some tenants and staff were fearful of 159685/2024 COHEN, DAN vs. ROSENBERG, COREY ET AL Page 3 of 4 Motion No. 001

3 of 4 [* 3] !FILED: NEW YORK COUNTY CLERK 03/10/2026 09: 40 AM! INDEX NO. 159685/2024 f' NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 03/09/2026

him," there was "no evidence that the tenant had ever attempted to assault anyone or

engaged in violent behavior"]; Cortez v Delmar Realty Co., Inc., 57 AD3d 313 [1 st Dept

2008] [summary judgment granted to landlord where tenant "was assaulted by an

illegal subtenant of the building who was suspected of dealing drugs and ultimately

evicted for nonpayment of rent"], lv denied 12 NY3d 774 [2009]; Simms, 187 AD2d at

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Related

Burgos v. Aqueduct Realty Corp.
706 N.E.2d 1163 (New York Court of Appeals, 1998)
Woodson v. Mendon Leasing Corp.
790 N.E.2d 1156 (New York Court of Appeals, 2003)
Sterk-Kirch v. Uptown Communications & Electric, Inc.
124 A.D.3d 413 (Appellate Division of the Supreme Court of New York, 2015)
Henry v. Storage Post
2020 NY Slip Op 2112 (Appellate Division of the Supreme Court of New York, 2020)
Virella v. 245 N. St. Hous. Dev. Fund Corp.
2020 NY Slip Op 06605 (Appellate Division of the Supreme Court of New York, 2020)
Britt v. New York City Housing Authority
3 A.D.3d 514 (Appellate Division of the Supreme Court of New York, 2004)
Cortez v. Delmar Realty Co.
57 A.D.3d 313 (Appellate Division of the Supreme Court of New York, 2008)
Blatt v. New York City Housing Authority
123 A.D.2d 591 (Appellate Division of the Supreme Court of New York, 1986)
Joosten v. Gale
129 A.D.2d 531 (Appellate Division of the Supreme Court of New York, 1987)
Gill v. New York City Housing Authority
130 A.D.2d 256 (Appellate Division of the Supreme Court of New York, 1987)
Firpi v. New York City Housing Authority
175 A.D.2d 858 (Appellate Division of the Supreme Court of New York, 1991)

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Bluebook (online)
2026 NY Slip Op 30798(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/cohen-v-rosenberg-nysupctnewyork-2026.