Markh v. Chen

2025 NY Slip Op 31513(U)
CourtNew York Supreme Court, New York County
DecidedApril 28, 2025
DocketIndex No. 451333/2025
StatusUnpublished

This text of 2025 NY Slip Op 31513(U) (Markh v. Chen) 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
Markh v. Chen, 2025 NY Slip Op 31513(U) (N.Y. Super. Ct. 2025).

Opinion

Markh v Chen 2025 NY Slip Op 31513(U) April 28, 2025 Supreme Court, New York County Docket Number: Index No. 451333/2025 Judge: Jeffrey H. Pearlman 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. 451333/2025 NYSCEF DOC. NO. 44 RECEIVED NYSCEF: 04/28/2025

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. JEFFREY H. PEARLMAN PART 44 Justice --------X INDEX NO. 451333/2025 LENNY MARKH, MARIYA MARKH, AIYUN LI, MICHAEL D BENJAMIN, STUART HEIER, SUSAN A. LIEBMAN MOTION DATE 4/25/25

Petitioners, MOTION SEQ. NO. 001

-v- JANICE CHEN, BOARD OF ELECTIONS IN THE CITY OF DECISION + ORDER ON NEW YORK, MOTION

Respondents. ----------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 001) 13, 14, 15, 16, 17, 18, 19,20,21,22,23, 32, 34, 36, 37, 39,40,41 were read on this motion to/for ELECTION LAW- INVALIDATE PETITION

Upon the foregoing papers, and after oral argument and hearing held before the Court on

the record, respondent-candidate Janice Chen (Respondent), candidate for Civil Court Judge,

Kings County, moves for an order dismissing the petition to invalidate her designating petition

pursuant to CPLR 321 l(a)(1)(5) and (7) for failure to properly serve her with specifications of

objections as required by Election Law§ 6-154 (3)(b). On April 14, 2025, petitioners-objectors

Lenny Marl

referred to as the Petitioner-Objectors) and petitioner-aggrieved-candidate Susan A. Liebman

(Petitioner-Aggrieved Candidate), commenced the within invalidating proceeding against

respondent-candidate and the Board of Elections (the Board) pursuant to Election Law§§ 16-100,

16-102 and 6-116.

The matter was initially brought in brought in New York State Supreme Court, Kings

County, with the order to show cause signed by the Hon. Robin K. Shears, J.S.C. On April 16,

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2025, the instant matter was transferred from Kings County, Civil Term, to New York County,

Civil Term by the administrative order of the Deputy Chief Administrative Judge Adam Silvera,

along with two other matters, one involving many of the same Petitioner-Objectors (Index No.

451334/2025) seeking to invalidate the designating petition of another candidate for Civil Court

Judge, Janis P. Purvis, and the other involving Ms. Purvis' anticipatory validation petition (Index

No. 451339/2025). A court notice was uploaded to NYSCEF directing the parties and their counsel

to report to New York County Supreme Court Special Election Part 44 on Monday, April 21, 2025.

On that day, the Respondent filed the instant motion to dismiss, and both parties were heard

on the record regarding the parties' respective positions, with the Court providing the parties

additional time to brief the issues raised therein. On April 22, 2025, the Court issued an order that

referred the matter for Special Referees to hear and report on the line-by-line review of the subject

volumes of Respondent's designating petitions. What is more, the Court issued another order that

directed the Board to transfer the identified petition volumes from their Kings County offices to

their facilities located at 200 Varick Street, New York, N.Y. The line-by-line review of the

volumes began on Wednesday April 23, 2025 and continued through Friday April 25, 2025, with

Special Referee Rebecca Wohl and Special Referee BB Liu reviewing challenged signatures by

volume.

I. Respondent's Motion

As stated in her memorandum of law, Respondent herein moves for:

an Order and Judgment, pursuant to CPLR § 3211 (a)(l), (5) and (7); NY Election Law§ 6-154(2), (3)(b) and Rule(s), HI, Hl(b), H3, H6 and H15 of the "Designating Petition & Opportunity to Ballot Petition Guidelines for Primary Elections," issued by the Respondent-Board of Elections in the City of New York on February 11, 2025, denying the relief requested by Petitioner's Order to Show Cause in its entirety; (ii) an Order and Judgment

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dismissing the Verified Petition in its entirety; (iii) an Order and Judgment granting the counterclaim in Respondent-Candidate's Proposed Verified Answer, declaring her Designating Petition valid in all respects; (iv) an Order and Judgment directing that Respondent Board of Elections place the name of Respondent-Candidate on the ballot for the Public office of Judge of the Civil Court of the City of New York, Kings County.

Respondent contends, among other things, that the instant petition should be dismissed,

because the Petition is defective. Specifically, the Respondent argues that the Petitioner-Objectors

and Petitioner-Aggrieved Candidate have failed to satisfy a condition precedent to initiating the

instant action, namely failing to fulfil the requirements of Election Law § 6-154 that requires

objectors to serve specifications of objection (typically referred to as "specifications" or "specs")

on candidates. Respondent posits that such service is a mandatory requirement to confer standing

to a petitioner and for any objections to be considered by the Court. Instead of being served with

the specification of objections filed by Petitioners with the Board of Elections, the Respondent

notes that she was mistakenly served with specifications of objections for Ms. Purvis, the other

challenged candidate for the position of Civil Court Judge in the related matter. 1 As part of an

affidavit by Respondent, she alleges that on April 14, 2025, she was in fact served with a package,

and when she opened the package she "discovered were the Specifications of Objection ('specs')

to the Petition of Janice Purvis, a candidate for the Civil Court of the City of New York, Assigned

Vacancy #12" (NYSCEF doc. no. 14 at, 6).

Respondent contends that Petitioner-Objectors and Petitioner-Aggrieved Candidate

(collectively Petitioners) failed to effectuate and complete service of their specifications of

objections to Respondent-Candidate and that this failure deprives this Court of its authority to

proceed with the petition, as such failure is a jurisdictional defect. In support of this position,

1 This matter, Lenny Markh et al v. Janice P Purvis et al, Index No. 451334/2025, was discontinued by the parties pursuant to stipulation dated April 25, 2025. 451334/2025 Page 3 of 15

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Respondent cites to recent legislative amendments to Election Law § 6-154, which now require

objectors to serve Specifications of Objections on candidates as a mandatory requirement for any

objections to be considered. Election Law § 6-154(b) provides, in pertinent part, that:

(b) No specifications of objections to any petition, certificate of nomination or ballot access document will be considered unless the objector filing the specifications personally delivers or mails by overnight mail a duplicate copy of the specification to each candidate for public office named on the petition.

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Bluebook (online)
2025 NY Slip Op 31513(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/markh-v-chen-nysupctnewyork-2025.