Case Type

Non-payment

Housing Type

Commercial Property

Court

Civil Court of the City of New York

County

Queens County (Queens)

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

LT-308685-25/QU

Slip Opinion Number

2025 NY Slip Op 51384(U)

Petitioner

Lemena Holdings LLC

Respondent

Wo Kee Noodle Inc., & XYZ CORP.

Judge

Kagan, Mark

Decision/Order Date

2025-09-02

Posture

Other

Disposition

Motion Granted for Landlord

Winner

Landlord Substantially Won

Synopsis

The court denied the tenant's motion to dismiss the nonpayment petition, which was based on a claim of res judicata from a prior dismissed case. The court found that the previous dismissal was due to a **defective rent demand**, a procedural prerequisite, and not a decision on the merits of the underlying claim for rent. Therefore, the doctrine of **res judicata** did not apply to bar the landlord from commencing a new proceeding after correcting the deficiency in the predicate notice. The court reasoned that a dismissal based on a failure to comply with a preliminary act does not preclude a subsequent action once the act is properly performed.

Keywords

Previous dismissal for defective rent demand does not have res judicata effect on new nonpayment based on corrected rent demand; commercial nonpayment

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