Rios v. Addams

2025 NY Slip Op 30099(U)
CourtNew York Supreme Court, New York County
DecidedJanuary 13, 2025
DocketIndex No. 153589/2022
StatusUnpublished

This text of 2025 NY Slip Op 30099(U) (Rios v. Addams) 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
Rios v. Addams, 2025 NY Slip Op 30099(U) (N.Y. Super. Ct. 2025).

Opinion

Rios v Addams 2025 NY Slip Op 30099(U) January 13, 2025 Supreme Court, New York County Docket Number: Index No. 153589/2022 Judge: Arlene P. Bluth 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. 153589/2022 NYSCEF DOC. NO. 100 RECEIVED NYSCEF: 01/13/2025

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. ARLENE P. BLUTH PART 14 Justice ---------------------------------------------------------------------------------X INDEX NO. 153589/2022 MAGDA ROSA RIOS, MOTION DATE 01/09/2025 Plaintiff, MOTION SEQ. NO. 002 -v- ROBERT DAVID ADDAMS, ADDAMS PROPERTIES LLC DECISION + ORDER ON MOTION Defendants. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 002) 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 77, 78, 95, 96, 97, 98, 99 were read on this motion to/for STRIKE PLEADINGS .

Plaintiff’s motion to strike defendants’ answer is decided as described below.

Background

The instant property dispute arises out of a previous romantic relationship between

plaintiff and defendant Addams. They met in 1988 and had two children (one in 1989 and one in

1992). The two never married but decided, in 1993, to purchase an apartment. This is where the

parties’ stories divert. Plaintiff argues that during the loan application process, the parties agreed

to leave plaintiff off the loan and the deed because of defendant Addams’ better credit rating.

Addams claims that there was little negotiation about the price of the apartment because

it was a sponsor unit at a condo and that he paid the entire deposit of $12,500 from his own

funds. He insists that because of plaintiff’s poor credit history, the lender would not issue

financing with plaintiff on the title or the mortgage; he disputes plaintiff’s assertion that a better

rate was offered if plaintiff was left out of the transaction. He points the Court to the amended

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purchase agreement (a document uploaded by plaintiff) in which she was removed from the

purchase agreement entirely (NYSCEF Doc. No. 4).

Plaintiff and Addams soon broke up after he purchased the apartment and Addams

moved out. Both parties agree that plaintiff continued to live in the apartment while their

children were minors and that no lease agreement was ever entered into. Plaintiff alleges that

she proceeded as if she co-owned the unit, maintained the apartment, and paid all condo charges

as well as all mortgage payments. Defendant Addams claimed that he thought it was best for

plaintiff to pay the combined maintenance and mortgage payments rather than forcing plaintiff to

find a new place and pay rent there. It also allowed their children to stay in the same apartment.

He insists that he paid the property taxes, however.

In 2016, Addams transferred title to the property to co-defendant Addams Properties

LLC. He claims he did this after the mortgage was paid off and that he then told plaintiff to

make the maintenance payments to the corporate entity but she refused. Addams contends that

he then commenced a non-payment proceeding in Housing Court. However, the judge

ultimately found that there was no landlord-tenant relationship and rejected Addams’ petition.

Addams insists that plaintiff has not made any payments for the use and occupancy of the

apartment since March 2016 (except for two payments made while the non-payment case was

active).

In this motion, plaintiff seeks to strike defendants’ answer or, in the alternative, to issue

preclusion orders barring defendants from offering testimony or evidence at trial. She contends

that defendants have repeatedly frustrated plaintiff’s efforts to pursue discovery. Plaintiff argues

that defendants served responses to initial discovery demands that did not address several

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categories of documents. And she points out that defendants failed to serve any response to

plaintiff’s second document demands served in May 2024.

In opposition, defendants argue that plaintiffs did not comply with 22 NYCRR 202.7, a

rule requiring a party to seek a good faith resolution to a dispute prior to making a motion. They

insist that they have provided discovery in response to plaintiff’s document demands. Defendants

argue that the second document demand is duplicative and that the extreme relief sought by

plaintiff is not appropriate. Defendants also argue that plaintiff is not entitled to the additional

discovery sought in the second document demand because they are overbroad and seek financial

records for over 32 years.

In reply, plaintiff emphasizes that defendants refused to comply with discovery demands

for two years and have engaged in a willful pattern of noncompliance. She insists that the only

appropriate relief is to strike defendants’ answer or to preclude them from offering testimony or

evidence.

The Court observes that defendants failed to timely oppose this motion and so it was

initially granted without opposition. Defendants then moved to vacate and the Court granted that

application; the Court now considers this fully briefed motion on the merits.

Discussion

As an initial matter, the Court observes that striking a pleading is a drastic remedy that is

not appropriate under these circumstances. “[T]he drastic remedy of striking a pleading or even

precluding evidence pursuant to CPLR 3126 should not be imposed unless the failure to comply

with discovery demands or orders is clearly willful and contumacious” (Palmieri v Piano Exch.,

Inc., 124 AD3d 611, 612, 1 NYS3d 315 [2d Dept 2015]).

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To be sure, defendants have not exactly timely responded to discovery demands.

However, the parties entered into stipulations regarding the first set of discovery demands that

delayed defendants’ time to respond (see e.g., NYSCEF Doc. Nos. 49, 53). And defendants

eventually served responses to those demands. The Court cannot strike a pleading or impose the

drastic remedy of preclusion where the parties agreed to a new deadline for responses, even

where prior deadlines may have passed. The Court declines to go back in time and impose such a

severe sanction under these circumstances.

To the extent that plaintiff complains about the quality and substance of defendants’

responses to the first set of demands, that is also not a basis to strike defendants’ answer. The

fact is that plaintiff uploaded a letter after receiving these responses asking for time to review

them (NYSCEF Doc. No. 54) and the next discovery stipulation between the parties did not

mention anything about these responses (NYSCEF Doc. No. 57). That is, plaintiff did not insist

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Related

Palmieri v. Piano Exchange, Inc.
124 A.D.3d 611 (Appellate Division of the Supreme Court of New York, 2015)
Thompson v. St. Charles Condominiums
258 A.D.2d 448 (Appellate Division of the Supreme Court of New York, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
2025 NY Slip Op 30099(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/rios-v-addams-nysupctnewyork-2025.