Case Type
Holdover-Lease Expiration
Housing Type
Market Rate
Court
Civil Court of the City of New York
County
Kings County (Brooklyn)
L&T / Index / Case / Docket / Clerk's Number
LT-326620-25/KI
Petitioner
Mugen Group LLC
Respondent
Paulino Tufino
Judge
Vincent
Decision/Order Date
2026-05-08
Posture
Pre-Answer Motion by Tenant
Disposition
Case Dismissed/discontinued
Winner
Tenant Substantially Won
Synopsis
RPL §231-c requires that a landlord append the statutory Good Cause Eviction Law notice to any predicate notice served pursuant to RPL §226-c. Here, landlord failed to append the required GCEL notice to the 90-day termination notice. Landlord's inclusion of GCEL-related language within the petition did not cure this defect, as the statute requires the notice to accompany the predicate notice itself. Predicate notices are conditions precedent to the maintenance of a summary proceeding and are not amendable. Proceeding dismissed without prejudice.
Keywords
GCEL; Failure To Attach GCEL Notice To Predicate Notice Warrants Dismissal; RPL § 231-c; Failure To Attach GCEL Notice To Predicate Notice Not Amendable Defect
Recommended Citation
"Mugen Group LLC v. Tufino" (2026). All Decisions. 2325.
https://ir.lawnet.fordham.edu/housing_court_all/2325
