Case Type

Non-payment

Housing Type

Rent Stabilized

Court

Supreme Court, Appellate Term, First Department

County

New York County (Manhattan)

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

570014/26

Slip Opinion Number

2026 NY Slip Op 50592(U)

Petitioner

Lex & Third 116th Street Corp.

Respondent

Rosa Vargas, Moises Mendoza, "John Doe," and "Jane Doe"

Judge

Brigantti, Tisch, Alpert

Decision/Order Date

2026-04-28

Posture

Pre-answer Motion by Tenant

Disposition

Motion Granted for Tenant

Winner

Tenant Substantially Won

Synopsis

An appellate court reversed a lower court's order denying the tenant's motion for discovery in a nonpayment proceeding. The tenant sought discovery to determine if the premises constituted a horizontal multiple dwelling, which would subject it to rent stabilization. The appellate court found the lower court improvidently exercised its discretion, holding that the tenant demonstrated "ample need" for disclosure as the landlord possessed particular knowledge of the properties' ownership, management, and operation, and the tenant showed indicia of commonality between the buildings. The matter was remanded to the Civil Court to limit the scope of the overbroad discovery demands.

Keywords

Discovery Motion Improperly Denied; Horizontal Multiple Dwelling; Ample Need Demonstrated

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