Stahl Assoc. LLC v. Cataldo

2026 NY Slip Op 30085(U)
CourtCivil Court Of The City Of New York, New York County
DecidedJanuary 23, 2026
DocketIndex No. L&T 317188/24
StatusUnpublished
AuthorClinton J. Guthrie

This text of 2026 NY Slip Op 30085(U) (Stahl Assoc. LLC v. Cataldo) is published on Counsel Stack Legal Research, covering Civil Court Of The City Of New York, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stahl Assoc. LLC v. Cataldo, 2026 NY Slip Op 30085(U) (N.Y. Super. Ct. 2026).

Opinion

Stahl Assoc. LLC v Cataldo 2026 NY Slip Op 30085(U) January 23, 2026 Civil Court of the City of New York, New York County Docket Number: Index No. L&T 317188/24 Judge: Clinton J. Guthrie 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 FILED: NEW YORK CIVIL COURT - L&T 01/23/2026 05:21 PMNO. LT-317188-24/NY [HO] NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 01/23/2026

CIVIL COURT OF THE CITY OF NEW YORK COUNTY OF NEW YORK: HOUSING PART D ---------------------------------------------------------------X STAHL ASSOCIATES LLC, Index No. L&T 317188/24

Petitioner,

-against- DECISION/ORDER

LISA CATALDO, JOHN DOE, JANE DOE,

Respondents. ----------------------------------------------------------------X Present:

Hon. CLINTON J. GUTHRIE Judge, Housing Court

Recitation, as required by CPLR § 2219(a), of the papers considered in the review of petitioner’s motion for discovery pursuant to CPLR §§ 408 and 3107 and respondent’s cross-motion for discovery pursuant to CPLR §§ 408 and 3107:

Papers Numbered

Notice of Motion & All Documents Annexed………………....... 1 (NYSCEF #9-12) Notice of Cross-Motion & All Documents Annexed......……....... 2 (NYSCEF #15-25) Affirmation in Reply and in Opposition……...………………….. 3 (NYSCEF #27) Reply Affirmation (Cross-Motion) & Exhibit Annexed…………. 4 (NYSCEF #29)

Upon the foregoing cited papers, the decision and order on petitioner’s motion and respondent’s

cross-motion, consolidated for determination herein, is as follows.

PROCEDURAL HISTORY

This summary holdover proceeding based upon a combined notice of termination and

notice of nonrenewal alleging nonprimary residence was filed in September 2024. Respondent

appeared through counsel and interposed an answer in October 2024. Subsequently, both parties

filed motions for discovery. After briefing, this court heard argument on the motions on July 17,

2025.

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DISCUSSION/CONCLUSION

I. Petitioner’s Motion for Discovery

In this special proceeding governed by Article 4 of the CPLR, discovery may only be

granted by leave of court upon showing of an ample need for disclosure (see CPLR § 408;

Georgetown Unsold Shares, LLC v Ledet, 130 AD3d 99, 106 [2d Dept 2015]; Mautner-Glick

Corp. v Higgins, 64 Misc 3d 16, 18 [App Term, 1st Dept 2019]; New York University v Farkas,

121 Misc 2d 643, 647 [Civ Ct, NY County 1983, Saxe, J]).

Typically, the assessment of ample need is grounded in the six factors enumerated by

Judge David B. Saxe in Farkas: (1) whether the party seeking discovery has asserted facts to

establish a cause of action; (2) whether there is a need to determine information directly related

to the cause of action; (3) whether the requested disclosure is carefully tailored and is likely to

clarify the disputed facts; (4) whether prejudice will result from the granting of an application for

disclosure; (5) whether the prejudice can be diminished or alleviated by an order fashioned by

the court for this purpose; and (6) whether the court, in its supervisory role, can structure

discovery so that pro se tenants, in particular, will be protected and not adversely affected by

discovery requests (see Farkas, 121 Misc 2d at 647). More recently, some lower courts have

also considered whether discovery “will speed a case towards a fair resolution, whether by

stipulation or trial.” (Temo Realty LLC v Herrera, 82 Misc 3d 299, 301 [Civ Ct, Kings County

2023] [citing 50th St. HDFC v Abdur-Rahim, 72 Misc 3d 1210[A], 2021 NY Slip Op 50693[U]

[Civ Ct, Kings County 2021] and 717 Sterling Corp. v Cook, 78 Misc 3d 1224[A], 2023 NY Slip

Op 50345[U] [Civ Ct, Kings County 2023]]; see also 109th Affordable Hous. LLC v Beck, 2025

NY Slip Op 32735[U], *2 [Civ Ct, NY County 2025]).

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Petitioner seeks discovery in relation to its claim that respondent does not primarily

reside in the subject premises. There is a general presumption in favor of discovery upon

nonprimary residence claims in summary proceedings (see Hughes v Lenox Hill Hosp., 226

AD2d 4, 18 [1st Dept 1996], lv denied 90 NY2d 829 [1997]; Cox v JD Realty Associates, 217

AD2d 179, 183-184 [1st Dept 1995]). Respondent opposes those discovery demands that she

claims are outside the relevant time-period (the two years prior to the expiration of her last

lease), overly broad, or already produced to petitioner.

Upon due consideration, petitioner’s motion for discovery is granted, subject to the

following limitations. Respondent shall produce items responsive to petitioner’s document

demands except those numbered 3, which the court finds to be overly broad, and 31, since

petitioner is presumed to possess communications between respondent and itself. Respondent

shall be required to produce documents for the period from August 1, 2022 through July 31,

2024. While there is appellate support for evaluating the entire history of the tenancy in

nonprimary residence cases (see 615 Co. v Mikeska, 75 NY2d 987, 988 [1990]), petitioner does

not offer a sufficient basis in its motion for requiring discovery for the period prior to the most

recent lease term. The responsive documents and/or appropriate Jackson affidavit shall be

produced to petitioner’s attorneys no later than February 27, 2026. Respondent shall not be

required to re-produce any relevant documents already produced to petitioner or petitioner’s

attorneys after the date of petitioner’s notice of termination/nonrenewal. Petitioner shall be

permitted to schedule a deposition of respondent thereafter, but in no event later than April 10,

2026, unless by agreement of the parties.

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II. Respondent’s Cross-Motion for Discovery

Respondent’s cross-motion seeks discovery in relation to her defense that any absence

was excusable due to the condition of the subject premises and to petitioner’s allegation of illegal

subletting. Petitioner opposes the cross-motion in its entirety.

Where an absence from an apartment is “attributable to a credible, excusable reason,” it

will constitute a defense to a nonprimary residence proceeding (Emel Realty Corp. v Carey, 188

Misc 2d 280, 282 [App Term, 1st Dept 2001]; see also Second 82nd Corp. v Veiders, 51 Misc 3d

142[A], 2016 NY Slip Op 50652[U], *1 [App Term, 1st Dept 2016] [citing Rent Stabilization

Code (RSC) [9 NYCRR] §§ 2520.6(u) and 2523.5(b)(2)]). Respondent details in her affidavit in

support of the cross-motion a series of water leaks in the subject apartment and resulting damage

and mold that made the apartment temporarily uninhabitable. Respondent also annexes emails

with petitioner about the conditions, a report of a licensed mold assessor, Department of Housing

Preservation and Development (HPD) complaints and violations, and a draft relocation

agreement purportedly prepared by petitioner’s attorneys.

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Related

Hughes v. Lenox Hill Hospital
226 A.D.2d 4 (Appellate Division of the Supreme Court of New York, 1996)
Matter of Georgetown Unsold Shares, LLC v. Ledet
130 A.D.3d 99 (Appellate Division of the Supreme Court of New York, 2015)
615 Co. v. Mikeska
556 N.E.2d 1069 (New York Court of Appeals, 1990)
Cox v. J.D. Realty Associates
217 A.D.2d 179 (Appellate Division of the Supreme Court of New York, 1995)
New York University v. Farkas
121 Misc. 2d 643 (Civil Court of the City of New York, 1983)
Emel Realty Corp. v. Carey
188 Misc. 2d 280 (Appellate Terms of the Supreme Court of New York, 2001)

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Bluebook (online)
2026 NY Slip Op 30085(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/stahl-assoc-llc-v-cataldo-nycivctny-2026.