defendants waived any defense (New York) · Go Syfert
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defendants waived any defense in New York

7 New York opinions name it 2 courts 2002–2026 3 in the last five years

The cases below were cited by New York courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (3)

CaseFollowedCited
32nd Avenue, LLC v. Angelo Holding Corp.green
nyappdiv · 2011 · cited in 2 New York opinions naming this issue, 2013–2013
2 sentences

2013Moreover, the defendants waived any defense based on Gabel Equipment’s alleged lack of standing because they failed to interpose that defense in their answer or in a timely pre-answer motion to dismiss the complaint (see CPLR 3211 [e]; U.S. Bank N.A. v Denaro, 98 AD3d 964 , 964-965 [2012]; 32nd Ave., LLC v Angelo Holding Corp., 88 AD3d 986, 987 [2011]).

2013Moreover, the defendants waived any defense based on Gabel Equipment’s alleged lack of standing because they failed to interpose that defense in their answer or in a timely pre-answer motion to dismiss the complaint (see CPLR 3211 [e]; U.S. Bank N.A. v Denaro, 98 AD3d 964 , 964-965 [2012]; 32nd Ave., LLC v Angelo Holding Corp., 88 AD3d 986, 987 [2011]).

22
Leon v. Martinezgreen
ny · 1994 · cited in 2 New York opinions naming this issue, 2013–2013
2 sentences

2013Further, contrary to the defendants’ contention, accepting the facts as alleged in the complaint as true and according the corporate plaintiff the benefit of every possible favorable inference (see CPLR 3211 [a] [7]; Leon v Martinez, 84 NY2d 83, 87-88 [1994]), Gabel Equipment stated a cause of action alleging waste of corporate assets pursuant to Business Corporation Law § 720 (see Rapoport v Schneider, 29 NY2d at 400 ).

2013Further, contrary to the defendants’ contention, accepting the facts as alleged in the complaint as true and according the corporate plaintiff the benefit of every possible favorable inference (see CPLR 3211 [a] [7]; Leon v Martinez, 84 NY2d 83, 87-88 [1994]), Gabel Equipment stated a cause of action alleging waste of corporate assets pursuant to Business Corporation Law § 720 (see Rapoport v Schneider, 29 NY2d at 400 ).

22
Bank of America, National Ass'n v. Brannongreen
nyappdiv · 2017 · cited in 2 New York opinions naming this issue, 2019–2025
2 sentences

2025NO. 68 RECEIVED NYSCEF: 06/30/2025 Mtge. , LLC v Vorderme ier, 165 AD3d 822 , 822-823 [2018]; Bank of Am. , NA. v Brannon, 156 AD3d 1, 7 [2017]; 1199 Haus.

2019The defendants waived any defense based on the plaintiff's alleged failure to comply with a condition precedent of the consolidated mortgage since they did not raise this defense with specificity in their answer or in any motion to amend their answer ( see CPLR 3015[a]; Nationstar Mtge., LLC v Vordermeier , 165 AD3d 822 , 822-823; Bank of Am., N.A. v Brannon , 156 AD3d 1, 7 ; 1199 Hous.

12

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
U.S. Bank National Ass'n v. Denaro green
nyappdiv · 2012
2 sentences

2013Moreover, the defendants waived any defense based on Gabel Equipment’s alleged lack of standing because they failed to interpose that defense in their answer or in a timely pre-answer motion to dismiss the complaint (see CPLR 3211 [e]; U.S. Bank N.A. v Denaro, 98 AD3d 964 , 964-965 [2012]; 32nd Ave., LLC v Angelo Holding Corp., 88 AD3d 986, 987 [2011]).

2013Moreover, the defendants waived any defense based on Gabel Equipment’s alleged lack of standing because they failed to interpose that defense in their answer or in a timely pre-answer motion to dismiss the complaint (see CPLR 3211 [e]; U.S. Bank N.A. v Denaro, 98 AD3d 964 , 964-965 [2012]; 32nd Ave., LLC v Angelo Holding Corp., 88 AD3d 986, 987 [2011]).

22013–2013
Rapoport v. Schneider green
ny · 1972
2 sentences

2013Further, contrary to the defendants’ contention, accepting the facts as alleged in the complaint as true and according the corporate plaintiff the benefit of every possible favorable inference (see CPLR 3211 [a] [7]; Leon v Martinez, 84 NY2d 83, 87-88 [1994]), Gabel Equipment stated a cause of action alleging waste of corporate assets pursuant to Business Corporation Law § 720 (see Rapoport v Schneider, 29 NY2d at 400 ).

2013Further, contrary to the defendants’ contention, accepting the facts as alleged in the complaint as true and according the corporate plaintiff the benefit of every possible favorable inference (see CPLR 3211 [a] [7]; Leon v Martinez, 84 NY2d 83, 87-88 [1994]), Gabel Equipment stated a cause of action alleging waste of corporate assets pursuant to Business Corporation Law § 720 (see Rapoport v Schneider, 29 NY2d at 400 ).

22013–2013
Deutsche Bank Natl. Trust Co. v. Wentworth neutral
nyappdiv · 2022
1 sentence

2026Trust Co. v Wentworth , 211 AD3d 684, 687 ).

12026–2026
Soufer v. Baroukhian neutral
nyappdiv · 2020
1 sentence

2025In any event, the defendants failed to establish, prima facie, that the action was untimely ( see CPLR 213[2]; 214[2]; Soufer v Baroukhian , 182 AD3d 624, 626 ) or otherwise establish their prima facie entitlement to judgment as a matter of law ( see CPLR 3212).

12025–2025
Jakobleff v. Cerrato, Sweeney & Cohn green
nyappdiv · 1983
1 sentence

2002Ins. v Wade’s Canadian Inn & Cocktail Lounge, 225 AD2d 863, 864 ; Jakobleff v Cerrato, Sweeney & Cohn, 97 AD2d 834, 835 ; Erljur Assoc. v Weissman, 134 AD2d at 322 ).

12002–2002
Erljur Associates v. Weissman neutral
nyappdiv · 1987
1 sentence

2002Ins. v Wade’s Canadian Inn & Cocktail Lounge, 225 AD2d 863, 864 ; Jakobleff v Cerrato, Sweeney & Cohn, 97 AD2d 834, 835 ; Erljur Assoc. v Weissman, 134 AD2d at 322 ).

12002–2002
New York TRW Title Insurance v. Wade's Canadian Inn & Cocktail Lounge, Inc. green
nyappdiv · 1996
1 sentence

2002Ins. v Wade’s Canadian Inn & Cocktail Lounge, 225 AD2d 863, 864 ; Jakobleff v Cerrato, Sweeney & Cohn, 97 AD2d 834, 835 ; Erljur Assoc. v Weissman, 134 AD2d at 322 ).

12002–2002

Where else courts name it

NY 7 (2002–2026) GA 2 (1999–2024) MO 2 (1955–2023) CT 2 (1986–2009)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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