Case Type

Holdover-Lease Expiration

Housing Type

Other

Court

Civil Court of the City of New York

County

New York County (Manhattan)

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

L&T 301348/25

Slip Opinion Number

2025 NY Slip Op 52081(U)

Petitioner

Acquisition America VII, LLC

Respondent

Eli Mizrahi-Aks, Matthew Shtaynberg, Sahar Paz, John Doe, Jane Doe

Judge

Guthrie, Clinton J.

Decision/Order Date

2025-12-12

Posture

Pre-answer Motion by Tenant

Disposition

Motion Granted for Tenant

Winner

Tenant Substantially Won

Synopsis

In this holdover proceeding premised on a 90-day termination notice for alleged nonpayment of rent, a tenant moved to dismiss, asserting he vacated the premises before the proceeding commenced. The court granted the tenant's motion, emphasizing that a summary holdover proceeding under RPAPL Article 7 is purely possessory and requires the tenant to be in physical possession at the time of commencement. As it was undisputed the tenant had permanently vacated, the court found the landlord lacked a cause of action for possession against him, dismissing the petition as to that tenant while reserving the landlord's monetary claims for a separate plenary action.

Keywords

GCEL; Nonpayment of Rent as Good Cause for Eviction; RPL § 216(1)(a)(i); Petition Fails to State Cause of Action Under RPAPL § 711(1) and Court Lacks Jurisdiction Over Tenant Who Permanently Vacated Before Proceeding Commenced

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