From Casetext: Smarter Legal Research

Automatic Findings, Inc. v. Allied Outdoor Advertising, Inc.

Appellate Division of the Supreme Court of New York, First Department
Apr 25, 1995
214 A.D.2d 482 (N.Y. App. Div. 1995)

Opinion

April 25, 1995

Appeal from the Supreme Court, New York County (Martin B. Stecher, J., Karla Moskowitz, J.).


Justice Stecher properly determined that article 55 of the lease, which shielded defendant/landlord from liability for losses, including lost profits, by requiring plaintiff/tenant to procure insurance, did not violate General Obligations Law § 5-321 (see, Hogeland v Sibley, Lindsay Curr Co., 42 N.Y.2d 153, 161). Contrary to plaintiff's contention, there was no evidence of overreaching or unconscionability (see, Board of Educ. v Valden Assocs., 46 N.Y.2d 653, 657). As the issue of liability for lost profits under the lease was fully litigated in the action based on the fire loss, the doctrine of collateral estoppel precludes claims for lost profits in the action based on the flood loss (see, D'Arata v New York Cent. Mut. Fire Ins. Co., 76 N.Y.2d 659, 664).

The court also properly denied motions to amend the complaints due to prejudice to defendant for unreasonable delays (see, Adams Drug Co. v Knobel, 129 A.D.2d 401, 404). Retention of new counsel herein was an inadequate excuse for the delay (see, Wise v Greenwald, 194 A.D.2d 850, 851). Further, the proposed amendments in the flood action did not relate back to the original complaint and were thus barred by the Statute of Limitations (see, Alpert v Shea Gould Climenko Casey, 160 A.D.2d 67, 72-73).

We have considered plaintiffs' remaining arguments and find them to be without merit.

Concur — Sullivan, J.P., Rosenberger, Wallach, Kupferman and Tom, JJ.


Summaries of

Automatic Findings, Inc. v. Allied Outdoor Advertising, Inc.

Appellate Division of the Supreme Court of New York, First Department
Apr 25, 1995
214 A.D.2d 482 (N.Y. App. Div. 1995)
Case details for

Automatic Findings, Inc. v. Allied Outdoor Advertising, Inc.

Case Details

Full title:AUTOMATIC FINDINGS, INC., et al., Appellants, et al., Plaintiff, v. ALLIED…

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

Date published: Apr 25, 1995

Citations

214 A.D.2d 482 (N.Y. App. Div. 1995)
625 N.Y.S.2d 220

Citing Cases

Duane Reade v. 405 Lexington

Such claims are "wholly distinct and separate from property damage" claims ( Periphery Loungewear v. Kantron…