Case Type

Non-payment

Housing Type

Other

Court

Civil Court of the City of New York

County

Bronx County (Bronx)

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

LT-301374-25/BX

Petitioner

DAMIR REALTY CORP

Respondent

JIMMY HERNANDEZ; JANE DOE; JOHN DOE

Judge

Danescu, Madalina

Decision/Order Date

2026-04-06

Posture

Post-answer Motion by Tenant

Disposition

Case Dismissed/discontinued

Winner

Tenant Substantially Won

Synopsis

Court granted respondent's cross-motion to dismiss for failure to comply with RPAPL § 735(2), which requires proof of service to be filed within three days of service, and denied petitioner's motion to deem the affidavits timely filed under CPLR § 2001. Applying the First Department's strict compliance standard from Riverside Syndicate v Saltzman, the court held that because service was by conspicuous place delivery rather than personal delivery, service was not complete until proof was filed, rendering the defect jurisdictional and not curable by CPLR § 2001.

Keywords

RPAPL § 735(2); Proof Of Service Not Filed; Strict Compliance Standard; First Department; Conspicuous Place Service; Jurisdictional Defect; CPLR § 2001; Saltzman; Siedlecki v Doscher; Department Split

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