Monthly Archives: September 2014

Yellowstone Proceedings

I periodically review and update the appellate case law relating to so-called Yellowstone proceedings – where the tenant under a commercial lease brings an action in Supreme Court to toll the time to remedy a default asserted by a landlord in a notice to cure and to enjoin the filing of a summary proceeding for eviction in Civil Court. In recent months, the First Department has issued five decisions relating to Yellowstone proceedings. Continue reading