G & Y MAINTENANCE CORP. v. GLSC 48 SPECIAL, LLC

8325N. 162458/14.

169 A.D.3d 414 (2019)

91 N.Y.S.3d 691

2019 NY Slip Op 00839

G & Y Maintenance Corp., Appellant, v. GLSC 48 Special, LLC, Respondent, et al., Defendant.

Appellate Division of the Supreme Court of New York, First Department.

Decided February 5, 2019.


The court properly determined that plaintiff had failed to substantially comply with Lien Law § 9. Although each of the defects in plaintiff's September 2014 lien, standing alone, could have been amended (see Lien Law § 12-a), here, where there are no fewer than four defects, it cannot be said that plaintiff substantially complied with the Lien Law (see Matter of Diamond Architecturals v EFCO Corp.,

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