Case Type

Holdover-Licensee

Housing Type

Project Based Section 8

Court

Supreme Court, Appellate Term, Second Department

County

Queens County (Queens)

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

2024-807 Q C

Slip Opinion Number

2025 NY Slip Op 51973(U)

Petitioner

New York City Housing Authority-Latimer Gardens Houses

Respondent

Amanda Strobert, John Doe, Jane Doe

Judge

Buggs, Chereé A., Ottley, Lisa S., Quiñones, Joanne D.

Decision/Order Date

2025-12-05

Posture

Pre-answer Motion by Tenant

Disposition

Motion Granted for Landlord

Winner

Landlord Substantially Won

Synopsis

In this licensee holdover proceeding, the Appellate Term reversed the Civil Court's order which granted the tenant's motion for summary judgment dismissing the petition. The Appellate Term found that the 10-day notice to quit was legally sufficient under RPAPL 713(7), even though it did not specify how the former tenant of record vacated the apartment, as there is no requirement for such detail. The court also rejected the tenant's argument that the former tenant was a necessary party, noting that the tenant offered no affirmative proof the former tenant still possessed the apartment. The Appellate Term denied the tenant's motion for summary judgment.

Keywords

Licensee Holdover; Reasonable Notice Under Attendant Circumstances; RPAPL 713(7)

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