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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Greenburger v. Leary, 119 Misc. 2d 358 (1983)

Citation
Greenburger v. Leary, 119 Misc. 2d 358 (1983)
Parent Document
Greenburger v. Leary, 119 Misc. 2d 358 (1983)
Jurisdiction
New York (state)
Effective Date
1983-05-23

Full Text

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The more recent appellate cases are consistent only in holding that the delay must be examined in each instance to determine whether it is being used to manipulate the tenant so as to create an eviction. (See, e.g., 177 East 90th St. v Devine, NYLJ, March 30, 1982, p 6, col 1 [App Term, 1st Dept]; Schwartz v Abt, NYLJ, May 4, 1978, p 5, col 4 [App Term, 1st Dept]; Thunderbird Realty Co. v Ahn, NYLJ, Nov. 19,1981, p 11, col l [App Term, 1st Dept]; City of New York v Betancourt, supra.) It appears, therefore, that whatever the analytical basis for Gramford (supra) and its progeny may be — whether public policy, laches, waiver, or bad faith application — if there is good cause for delay there is no basis for precluding a landlord’s resort to a summary proceeding under the RPAPL.