Case Type

Holdover-Illegal Sublet

Housing Type

Rent Stabilized

Court

Civil Court of the City of New York

County

New York County (Manhattan)

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

LT-069208-16/NY

Petitioner

BLDG MANAGEMENT CO., INC.

Respondent

PUBLIC ADMINISTRATOR OF CITY OF NEW YORK FOR THE ESTATE OF GERALD FISHER, MICHAEL RICHARDS

Judge

Ferdinand, Tracy E.

Decision/Order Date

2025-07-28

Posture

Post-answer Motion by Landlord

Disposition

Other

Winner

Tenant Substantially Won

Synopsis

The court denied the landlord's motion to strike the tenant's answer for failure to comply with a pre-HSTPA order to pay use and occupancy. While the court acknowledged that it had the authority to strike the answer under the pre-HSTPA version of RPAPL § 745, it found that the tenant's default was not "willful and contumacious." The court noted that the tenant had made good-faith efforts to pay, including applying for ERAP, which the landlord rejected. As a result, the court instead ordered an immediate trial on the illegal sublet/succession claim, consistent with the remedy provided in the current version of RPAPL § 745.

Keywords

Motion to strike answer for failure to comply with pre-HSTPA order to pay use and occupancy denied because the defaults were not willful and contumacious; HSTPA amendment to RPAPL § 745 now precludes final judgment and instead requires immediate trial

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