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-307129-25/KI

Slip Opinion Number

2026 NY Slip Op 51502(U)

Petitioner

Dan Lin

Respondent

Luis Alberto Genis-Perez; et al.

Judge

Arrindell, Travis J.

Decision/Order Date

2026-09-15

Posture

Post-Trial Motion by Landlord

Disposition

Motion Granted for Landlord

Winner

Landlord Substantially Won

Synopsis

After trial in this GCEL lease expiration holdover, court takes up two questions: whether small landlord ownership disclosures must appear in the predicate notice, and whether landlord may add them to the petition post-trial. On the first, a plain reading of the statutes places those disclosures in the petition — not the termination notice. On the second, with no showing of prejudice by tenant, court allows the amendment under CPLR § 3025 and reopens the trial record so tenant may contest whether landlord qualifies for the exemption.

Keywords

GCEL; Small Landlord Exemption; Landlord Permitted to Amend Petition to Conform to Proof Post-Trial Under CPLR 3025; Trial Record Reopened to Allow Tenant to Present Rebuttal Case on Whether Landlord Is Entitled to Small Landlord Exemption; Small Landlord Disclosure Does Not Need to Be Attached to Predicate Notice of Termination

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