Case Type

Holdover

Housing Type

Market Rate

Court

Civil Court of the City of New York

County

Bronx County (Bronx)

L&T / Index / Case / Docket / Clerk's Number

LT-320917-25/BX

Petitioner

Ramreign Inc

Respondent

Sharon S. Carbon, Garnette G. Carbon, Shirley Carbon, John Doe, Jane Doe

Judge

Baum, Howard

Decision/Order Date

2026-05-26

Posture

Pre-Answer Motion by Landlord

Disposition

Case Dismissed/discontinued

Winner

Tenant Substantially Won

Synopsis

In this no-grounds/nonrenewal of tenancy holdover, the court granted respondent's motion to dismiss for failure to state a cause of action because, although the landlord claimed the 'small landlord' exemption to GCEL, the GCEL notice attached to the predicate notice of termination failed to identify the properties owned by the landlord as required by RPL § 231-c. The court dismissed the petition without prejudice, relying on 3515 Eastchester Rd., LLC v Soto [Civ Ct, Bronx Co. 2025] and observing that the factual allegations in the GCEL notice, which is incorporated into the notice of termination, cannot be amended.

Keywords

GCEL; Small Landlord Exemption; Failure to Identify Properties Owned by Landlord

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