Case Type

Non-payment

Housing Type

Co-op

Court

Civil Court of the City of New York

County

New York County (Manhattan)

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

L&T 321107/24

Slip Opinion Number

2025 NY Slip Op 34550(U)

Petitioner

HELLMUTH OWNERS CORP.

Respondent

DAPHNE RECANTI KAPLAN, THOMAS KAPLAN, JOHN DOE, JANE DOE

Judge

Guthrie, Clinton J.

Decision/Order Date

2025-12-05

Posture

Post-answer Motion by Landlord

Disposition

Other

Winner

Landlord Substantially Won

Synopsis

In this nonpayment proceeding for a co-op, the landlord moved to dismiss tenant's counterclaims and affirmative defenses, and the tenant cross-moved for discovery. The court largely granted the landlord's motion, severing many counterclaims (including monetary damages, injunctive, and declaratory relief) without prejudice due to Housing Court's limited subject matter jurisdiction. Several affirmative defenses were also dismissed without prejudice for being insufficiently pleaded or devoid of merit. However, the tenant's constructive eviction counterclaim was allowed to proceed. The tenant's motion for discovery was denied as overly broad.

Keywords

Defenses And Counterclaims Dismissed For Lack of Subject Matter Jurisdiction; Jurisdiction of Housing Court; Injunctive Relief; Affirmative Defenses Dismissed Because Devoid Of Merit; Discovery Demand Overly Broad, Not Narrowly Tailored; Motion For Discovery Denied

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