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The Second Department Holds That Lender Cannot Use CPLR 3215(c) to Avoid Dismissal of Foreclosure Action Despite Death of Borrower

Today’s article relates to a decision in a mortgage foreclosure action that combines numerous concepts about which we have previously written....more

RPAPL 1501(4) and the Mortgagee in Possession Doctrine

Today’s article addresses a property owner’s right to cancel a recorded mortgage pursuant to RPAPL 1501(4)[1] and whether a mortgagee is “is entitled to recover sums expended to preserve and maintain an allegedly abandoned...more

The Appellate Division, Second Department, Holds that Banking Law 6-l is a Personal Defense that Can Only be asserted by the...

By: Jonathan H. Freiberger As readers of this BLOG know, we frequently write about issues relating to mortgage foreclosure. We have also written numerous articles relating to the recently enacted FAPA... ...more

Death of a Litigant

Because litigation can be a long and drawn-out process, it is not uncommon for litigants to die during the pendency of a lawsuit. In today’s BLOG article, we address the problems that may arise when a litigant dies. This BLOG...more

Caveat Emptor and Reasonable Reliance on Fraudulent Misrepresentations When Purchasing Real Property

Today’s BLOG article relates to fraudulent concealment, caveat emptor and justifiable reliance when purchasing real property. As readers of this BLOG know, a “cause of action to recover damages for fraudulent...more

Individual Membership Interests In An LLC Does Not Equate to Individual Ownership Interest In Real Property Owned By The LLC For...

Partition is “the act or proceeding by which co-owners of property cause it to be divided into as many shares as there are owners, according to their interests therein, or if that cannot be equitably done, to be sold for the...more

Questions of Fact Exist as to Plaintiff’s Standing to Commence Action Where Form of Company Changed From Corporation to LLC

This BLOG has frequently addressed issues related to a party’s standing, in many different contexts, to commence litigation. In prior BLOG articles we have explained that in order to prosecute a lawsuit, the plaintiff must...more

The Second Department Reminds Litigants To Follow Requisite Procedures Before Seeking Discovery Sanctions

Discovery (or disclosure) in litigation, which is governed in New York State practice by Article 31 of the CPLR, is the mechanism by which litigants obtain facts and information from other parties and non-parties to support...more

Problems Related to “Short” Return Dates on Notices of Motion for Summary Judgment in Lieu of Complaint Pursuant to CPLR 3213

CPLR 3213, which is a procedural device permitting a plaintiff, under certain circumstances, to obtain summary relief at the very beginning of a lawsuit, provides, in pertinent part: When an action is based upon an...more

Courts Will Not Assist An Effort To Enforce An Illegal Contract

By Jonathan H. Freiberger  The Courts of New York will not aid in the enforcement of a contract when the subject matter is illegal. Cases standing for this seemingly unremarkable proposition are varied. For example, in...more

Renewal Judgments Under CPLR 5014 in the Face of Defective Service of Process

By Jonathan H. Freiberger Today’s article relates to renewal judgments under CPLR 5014 in the face of potentially defective service of process. This BLOG has previously addressed CPLR 5014...more

Personal Jurisdiction and the Vacatur of Defaults

By Jonathan H. Freiberger There are two “components and constitutional predicates of personal jurisdiction.”  Keane v. Kamin, 94 N.Y.2d 263, 265 (1999). “One component involves service of process, which implicates due process...more

New York City Sparkies Beware – Be Licensed or be Square

This BLOG has previously addressed issues related to proper licensure for contractors and the problems that arise for them if they perform work without a license. We have previously noted that home improvement contractors are...more

Second Department Holds That Material Term of Contract For Sale of Real Property (i.e., the Property Description) Was Too...

This BLOG has written numerous times on issues related to contract formation. See, e.g., [here], [here], [here], [here] and [here]. Briefly stated, “[t]o create a binding contract, there must be a manifestation of mutual...more

The First Department Dismisses COVID-19 Based Frustration of Purpose and Impossibility Related Defenses In Rent Arrears Action

Among the problems resulting from COVID-19, is the pandemic’s effect on business. Numerous businesses were forced to close due to lock downs and supply chain issues. The economic slowdowns and business closures caused by...more

It’s Settled!!  The Second Department Holds that Length Does Matter

Most often a lawsuit begins with the filing of a summons and complaint or summons with notice. CPLR 304. Once the lawsuit is commenced, the plaintiff is required to serve the defendant(s) with process – the event by which...more

Vacating a Recorded Satisfaction of Mortgage

Generally, folks borrow money to purchase real property.  Such loans are typically secured by a mortgage on the property being purchased.  The mortgage, when filed with the clerk of the county in which the property is...more

Extreme Vacations and Limitations of Liability

By Jonathan H. Freiberger This Blog has recently written on the issue of contractual limitations of liability.  [Here] Proving that timing is everything, Jonathan H. Freiberger, one of Freiberger Haber LLP’s founding members,...more

To Settle an Order or Not to Settle an Order, That is the Question

On July 12, 2023, the Appellate Division, Second Department, in U.S. Bank Trust, N.A. v. Rahman, addressed an issue that has been confusing lawyers for quite some time involving 22 N.Y.C.R.R. §202.48 – “Submission of orders,...more

Can You Limit Liability for Your Own Negligence in a Contract

Folks sign contracts of all types that purport to contain limitations of liability; but are they enforceable.  In many cases, the answer is “yes”.  “In the absence of a contravening public policy, exculpatory provisions...more

Proper Evidentiary Support for Compliance with RPAPL 1304 Remains an Issue for Foreclosing Lenders

Because there have been a number of appellate decisions interpreting RPAPL 1304, this Blog has written frequently on that topic. By way of background, and as previously noted in the Blog, RPAPL 1304 requires that at least...more

Sometimes One Bite at the Apple is All You Get

Today’s Blog involves motions to renew and reargue and successive motions for summary judgment. When a motion is denied, a movant has several options.  One can accept the loss and move on.  An appeal can also be pursued. ...more

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