Case Type

Non-payment

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

LT-314356-25/NY

Petitioner

215-219 E 2nd St Assoc

Respondent

Dennis Kane et al

Judge

Meyers, Adam R.

Decision/Order Date

2026-02-02

Posture

Post-answer Motion by Tenant

Disposition

Motion Granted for Tenant

Winner

Tenant Substantially Won

Synopsis

Handwritten Opinion. In this nonpayment proceeding, the court granted the tenant's summary judgment motion, dismissing the petition for failure to state a cause of action under RPAPL § 711(2). The predicate rent demand was found fatally defective as it failed to properly credit ERAP payments according to their earmarking in the approval letter. This deficiency meant the demand did not fairly apprise the tenant of the periods for which rent was allegedly due, resulting in a substantial win for the tenant.

Keywords

Defective Rent Demand; Failure to Credit/Reflect ERAP Payments to the Months for Which They Were Earmarked

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