Case Type

Holdover-Other

Housing Type

Not Stated

Court

Civil Court of the City of New York

County

New York County (Manhattan)

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

LT-002071-25/NY

Petitioner

Yun Hoe Wong

Respondent

May Lan Wong

Judge

Ofshtein, Eleanora

Decision/Order Date

2026-07-16

Posture

Post-Answer Motion by Landlord

Disposition

Case Dismissed/discontinued

Winner

Tenant Substantially Won

Synopsis

In this holdover proceeding, tenant moved (motion sequence 3) to dismiss for failure to comply with the service requirements of RPAPL §735 under Saltzman v. Chernoff. The notice of petition and petition were dated December 31, 2025. The affidavit of service showed service was not made until January 30, 2026—ten days after the first court appearance on January 20, 2026. The court held that service made after the first court appearance violates RPAPL §735, which requires service to be made sufficiently in advance of the return date, and dismissed the petition without prejudice.

Keywords

Failure to Comply with Filing Requirements; RPAPL § 735; Saltzman

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