Case Type

Holdover-Non-primary Residence

Housing Type

Co-op

Court

Civil Court of the City of New York

County

Kings County (Brooklyn)

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

308199/25

Slip Opinion Number

2025 NY Slip Op 33480(U)

Petitioner

Vital Brookdale LLC

Respondent

Sequan Moore, ET AL.

Judge

Weisberg, Michael L.

Decision/Order Date

2025-09-10

Posture

Pre-answer Motion by Landlord

Disposition

Case Dismissed/discontinued

Winner

Tenant Substantially Won

Synopsis

In this holdover proceeding, the court denied the landlord's application for a default judgment and dismissed the petition. The landlord alleged the tenant failed to comply with income recertification procedures. The court found the petition improperly verified by an attorney lacking personal knowledge. Crucially, the court held that the lease provision, which allowed termination upon ten days' notice for non-compliance, constituted a condition, not a conditional limitation. Consequently, a summary holdover proceeding could not be maintained as a conditional limitation, providing for automatic lease expiration upon notice, was absent.

Keywords

Failure to Recertify Holdover Dismissed; Petition Improperly Verified by Attorney; Conditional Limitation Clause

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