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107-48 Queens Blvd. Holding Corp. v. ABC Brokerage Inc.

Citations: 238 A.D.2d 557; 656 N.Y.S.2d 691

Court: Appellate Division of the Supreme Court of the State of New York; April 28, 1997; New York; State Appellate Court

Narrative Opinion Summary

Maredin Rest. Corp. appeals a September 20, 1996 order from the Supreme Court, Queens County, which denied its motion to transfer a summary nonpayment proceeding (107-48 Queens Blvd. Holding Corp. v Maredin Rest. Corp., Index No. 65405/96) from Civil Court to the Supreme Court and to consolidate it with related actions concerning lease breach damages. The order is affirmed with costs. The lease prohibits the appellant from filing counterclaims in the summary proceeding, a restriction that cannot be bypassed through consolidation with Supreme Court actions, as supported by precedents (Titleserv, Inc. v Zenobio; Hanlon, White Assocs. v Schultz). Other arguments from the parties were deemed without merit. Rosenblatt, J.P., Miller, Thompson, and Friedmann, JJ. concur.

Legal Issues Addressed

Consolidation of Actions in Summary Proceedings

Application: The court affirmed that consolidation of the summary nonpayment proceeding with related actions in Supreme Court is not permissible when the lease expressly prohibits counterclaims.

Reasoning: The lease prohibits the appellant from filing counterclaims in the summary proceeding, a restriction that cannot be bypassed through consolidation with Supreme Court actions, as supported by precedents (Titleserv, Inc. v Zenobio; Hanlon, White Assocs. v Schultz).

Evaluation of Additional Arguments in Judicial Decisions

Application: The court evaluated other arguments presented by the parties and determined that they were without merit.

Reasoning: Other arguments from the parties were deemed without merit.

Prohibition of Counterclaims in Summary Proceedings

Application: The lease in question prevents the appellant from filing counterclaims in the summary nonpayment proceeding, and this restriction holds even when the appellant seeks consolidation with related actions in Supreme Court.

Reasoning: The lease prohibits the appellant from filing counterclaims in the summary proceeding, a restriction that cannot be bypassed through consolidation with Supreme Court actions, as supported by precedents (Titleserv, Inc. v Zenobio; Hanlon, White Assocs. v Schultz).