Case Type

Holdover-Lease Expiration

Housing Type

Rent Stabilized

Court

SUPREME COURT, APPELLATE TERM, SECOND DEPARTMENT

County

Queens County (Queens)

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

2024-577 Q C

Slip Opinion Number

2025 NY Slip Op 50849(U)

Petitioner

14-16 30th Road, LLC

Respondent

Walid Hassan, "John Doe", "Jane Doe"

Judge

Mundy, Marina Cora; Ottley, Lisa S; Quiñones, Joanne D

Decision/Order Date

2025-05-23

Posture

Pre-answer Motion by Tenant

Disposition

Other

Winner

Landlord Substantially Won

Synopsis

The Appellate Term affirmed the Civil Court's denial of the tenant's pre-answer motion to dismiss a holdover petition. The tenant argued that substituted service on "John and Jane Doe" was untimely. The court held that a personal jurisdiction defense cannot be raised on behalf of another party. Furthermore, the court reiterated that jurisdiction attaches upon delivery and mailing of papers, not solely upon the filing of the affidavit of service. Therefore, untimely filing of the affidavit of service, absent alleged prejudice, is not a jurisdictional defect and can be disregarded under CPLR 2001.

Keywords

Personal Jurisdiction; 735(2)(b); Prejudice

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