Case Type

Holdover-Lease Expiration

Housing Type

Market Rate

Court

Civil Court of the City of New York

County

Queens County (Queens)

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

LT-303798-26/QU

Slip Opinion Number

2026 NY Slip Op 32165(U)

Petitioner

Milton Lai, Trustee Under Lai Family Irrevocable Trust, Dated July 30, 2021; Woon Kwan Lai

Respondent

Grace Tiphung Wong, John Doe, Jane Doe

Judge

Guthrie, Clinton J.

Decision/Order Date

2026-08-19

Posture

Pre-Answer Motion by Landlord

Disposition

Case Dismissed/discontinued

Winner

Tenant Substantially Won

Synopsis

Tenant moved to dismiss a holdover proceeding predicated on a 90-day notice of termination, arguing improper service and that landlord's Good Cause Eviction Law notice failed to adequately plead the small landlord exemption from GCEL. The court granted dismissal, holding that the GCEL notice did not provide sufficient specificity to satisfy the statutory notice requirements for the small landlord exemption.

Keywords

Personal Jurisdiction; GCEL; Small Landlord Disclosure; RPL § 214(1); Landlord Not Required To Disclose Their Principal Residence In Small Landlord Disclosure; Verification Of Petition; CPLR § 2106; CPLR § 3022; Notice Of Improperly Verified Pleading Must Be Given With Due Diligence; Authorization To Sign Termination Notice; Siegel v Kentucky Fried Chicken Narrow Holding

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