Case Type

Non-payment

Housing Type

Rent Stabilized

Court

Civil Court of the City of New York

County

New York County (Manhattan)

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

LT-311330-25/NY

Petitioner

52 HENRY STREET REALTY LLC

Respondent

DIAN QIANG JIANG; JOHN DOE; JANE DOE

Judge

Chinea, Daniele

Decision/Order Date

2026-03-26

Posture

Post-answer Motion by Tenant

Disposition

Motion Granted for Tenant

Winner

Tenant Substantially Won

Synopsis

In this nonpayment proceeding against a rent-stabilized tenant, the court granted the tenant's motion to amend the answer and for summary judgment, dismissing the landlord's petition without prejudice. The landlord's petition was dismissed because the predicate rent demand was fatally defective. The defect stemmed from the rent demand and its attached ledger including late fees alongside rent arrears, which is impermissible in a summary nonpayment proceeding under RPAPL § 702(1). The court held that a predicate notice containing such impermissible charges renders the demand fatally defective and cannot be cured by amendment.

Keywords

Defective Rent Demand; Nonpayment Petition Dismissed Because Rent Demand and Rent Ledger Included Legal Fees for Which Non-Coop Tenants Cannot be Evicted Pursuant to RPAPL § 702

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