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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

150 West End Owners Corp. v. Chestnut Holdings of N.Y. Inc., 49 Misc. 3d 1147 (2015)

Citation
150 West End Owners Corp. v. Chestnut Holdings of N.Y. Inc., 49 Misc. 3d 1147 (2015)
Parent Document
150 West End Owners Corp. v. Chestnut Holdings of N.Y. Inc., 49 Misc. 3d 1147 (2015)
Jurisdiction
New York (state)
Effective Date
2015-09-25

Full Text

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A counterclaim is “related” to a nonpayment proceeding when it must be asserted to avoid the risk of preclusion under principles of collateral estoppel, i.e., “where the issues in the plaintiff[’s] claims are potentially identical and decisive of issues raised in the counterclaims.” (Textile, 81 NY2d at 59; N.A.S. Holdings, 12 AD3d at 752.) As a corollary, if the Civil Court lacks jurisdiction to hear a particular counterclaim because it cannot be litigated in the first instance, that counterclaim is unrelated because it could not be barred by collateral estoppel in a later proceeding. (Halberstam v Kramer, 39 Misc 3d 126[A], 2013 NY Slip Op 50408[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2013]; 374 E. Parkway.)