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MISTAKEN COMMENCEMENT DATE IN A LEASE IS A SUFFICIENT GROUND FOR RESCISSION (SECOND DEPT).

The Second Department determined a mistaken start-date in the lease was a sufficient ground for rescission:

Rescission “rests upon the equitable principle that a person shall not be allowed to enrich himself [or herself] unjustly at the expense of another” … , and is invoked “where the parties can be substantially restored to their status quo ante positions” … . The remedy of rescission may be granted where, as here, a mistake existed at the time the contract was entered into if “the mistake is so material that . . . it goes to the foundation of the agreement”… .

Here, the landlord’s principal admitted at trial that a mistake was made regarding the commencement date of the parties’ lease. Contrary to the landlord’s contention, however, the mistake as to the commencement date related to a material term of the lease … , and substantially defeated the purpose of the lease. K.A.M.M. Group, LLC v 161 Lafayette Realty, Inc., 2017 NY Slip Op 06260, Second Dept 8-23-17

 

LANDLORD-TENANT (LEASE, MISTAKEN COMMENCEMENT DATE IN A LEASE IS A SUFFICIENT GROUND FOR RESCISSION (SECOND DEPT))/LEASE (MISTAKEN COMMENCEMENT DATE IN A LEASE IS A SUFFICIENT GROUND FOR RESCISSION (SECOND DEPT))/RESCISSION (LEASE, MISTAKEN COMMENCEMENT DATE IN A LEASE IS A SUFFICIENT GROUND FOR RESCISSION (SECOND DEPT))

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DEFENDANT COLLEGE DEMONSTRATED IT DID NOT CREATE OR HAVE NOTICE OF THE CONDITION WHICH INJURED PLAINTIFF, A PORTION OF A LIGHT FIXTURE IN PLAINTIFF’S ON-CAMPUS ROOM FELL ON HER (SECOND DEPT).

The Second Department determined defendant’s motion for summary judgment was properly granted. Plaintiff, a student living in defendant’s on-campus housing, was injured when a globe from an overhead light fell on her. The defendant college demonstrated it did not created the dangerous condition and did not have actual or constructive notice of the condition:

The plaintiff was a student at the defendant, Long Island University, and resided at its on-campus housing facility in Brooklyn. During the evening of November 5, 2010, a glass globe fell from a ceiling lighting fixture in the plaintiff’s room onto her head. The plaintiff subsequently commenced this action against the defendant to recover damages for personal injuries. Following discovery, the defendant moved for summary judgment dismissing the complaint. The Supreme Court granted the defendant’s motion, and the plaintiff appeals.

The defendant established its prima facie entitlement to judgment as a matter of law by demonstrating that it did not create the condition that allegedly caused the plaintiff’s injuries or have actual or constructive notice of it … . Williamson v Long Is. Univ., 2017 NY Slip Op 06100, Second Dept 8-9-17

 

NEGLIGENCE (DEFENDANT COLLEGE DEMONSTRATED IT DID NOT CREATE OR HAVE NOTICE OF THE CONDITION WHICH INJURED PLAINTIFF, A PORTION OF A LIGHT FIXTURE IN PLAINTIFF’S ON-CAMPUS ROOM FELL ON HER (SECOND DEPT))/LANDLORD-TENANT (NEGLIGENCE, DEFENDANT COLLEGE DEMONSTRATED IT DID NOT CREATE OR HAVE NOTICE OF THE CONDITION WHICH INJURED PLAINTIFF, A PORTION OF A LIGHT FIXTURE IN PLAINTIFF’S ON-CAMPUS ROOM FELL ON HER (SECOND DEPT))

BROKER WHICH NEGOTIATED A 2001 LEASE NOT ENTITLED TO COMMISSION ON THE 2011 LEASE BETWEEN THE SAME PARTIES, 2011 LEASE WAS DEEMED A NEW LEASE, NOT A RENEWAL OF THE 2001 LEASE 4TH DEPT.

The Fourth Department determined defendant landlord’s motion for summary judgment in the action by a real estate broker seeking a commission based upon a lease should have been granted. The broker had negotiated the original lease in 2001 and was paid a commission. The question was whether the second lease in 2011 was a renewal of the original lease or a new lease, for which no commission was due. The Fourth Department held the 2011 lease was a new lease:

… [W]e agree with defendants that they met their burden on their motion by establishing that the 2011 lease was a new lease, rather than a renewal of the 2001 lease. In support of their motion, defendants submitted evidence establishing that, under the 2011 lease, HealthNow was leasing only part of the subject building, rather than the whole building as called for under the 2001 lease. In addition, the 2011 lease called for First Columbia [landlord] to make structural changes to the building to accommodate HealthNow’s [tenant’s] changing needs, and to install a backup generator at a cost in excess of $300,000. Furthermore, the rent was higher in the 2011 lease, it was not calculated in accordance with the terms for a renewal as provided in the 2001 lease, and the 2011 lease was for a term of seven years, whereas the 2001 lease called for a renewal term of five years. Finally, defendants established that the 2011 lease was not the result of any brokerage services performed by plaintiff. Baumann Realtors, Inc. v First Columbia Century-30, LLC, 2017 NY Slip Op 05546, 4th Dept 7-7-17

LANDLORD-TENANT (BROKER’S COMMISSIONS, BROKER WHICH NEGOTIATED A 2001 LEASE NOT ENTITLED TO COMMISSION ON THE 2011 LEASE BETWEEN THE SAME PARTIES, 2011 LEASE WAS DEEMED A NEW LEASE, NOT A RENEWAL OF THE 2001 LEASE 4TH DEPT)/LEASES (BROKER’S COMMISSIONS, BROKER WHICH NEGOTIATED A 2001 LEASE NOT ENTITLED TO COMMISSION ON THE 2011 LEASE BETWEEN THE SAME PARTIES, 2011 LEASE WAS DEEMED A NEW LEASE, NOT A RENEWAL OF THE 2001 LEASE 4TH DEPT)/BROKERS (REAL ESTATE, COMMISSIONS, LEASES, BROKER WHICH NEGOTIATED A 2001 LEASE NOT ENTITLED TO COMMISSION ON THE 2011 LEASE BETWEEN THE SAME PARTIES, 2011 LEASE WAS DEEMED A NEW LEASE, NOT A RENEWAL OF THE 2001 LEASE 4TH DEPT)/COMMISSIONS (REAL ESTATE BROKERS, LEASES, , BROKER WHICH NEGOTIATED A 2001 LEASE NOT ENTITLED TO COMMISSION ON THE 2011 LEASE BETWEEN THE SAME PARTIES, 2011 LEASE WAS DEEMED A NEW LEASE, NOT A RENEWAL OF THE 2001 LEASE 4TH DEPT)

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INSURER’S DISCLAIMER OF COVERAGE IN THIS SLIP AND FALL CASE IS NOT SUFFICIENT PROOF THE TENANT FAILED TO PROCURE THE INSURANCE REQUIRED BY THE LEASE, SUMMARY JUDGMENT ON THE BREACH OF CONTRACT CAUSE OF ACTION SHOULD NOT HAVE BEEN GRANTED.

The Fourth Department, reversing Supreme Court, determined summary judgment on the breach of contract cause of action should not have been granted. The property owner (the church) in this parking lot slip and fall case alleged that the lessee (Stepping Stones) failed to procure the insurance required by the lease. That allegation was based on the insurer’s disclaimer of coverage. The Fourth Department noted that the disclaimer could be erroneous and was therefore not proof of a breach of the lease:

In denying Stepping Stones’s motion in part and sua sponte granting summary judgment to the Church defendants on the breach of contract claims, the court reasoned that the Church defendants were entitled to judgment on the ground that, “[i]f the insurance carrier provided by Stepping Stones fails to cover the broad coverage demanded by the Lease, then Stepping Stones has breached the Lease agreement.”

On appeal, Stepping Stones addresses only the court’s determination with respect to the breach of contract claims. We agree with Stepping Stones that the court erred in granting summary judgment to the Church defendants on those claims, and we therefore modify the order accordingly. The mere fact that the insurance carrier disclaimed coverage for the accident does not establish as a matter of law that Stepping Stones failed to obtain the necessary coverage. It is possible that the insurance carrier’s disclaimer was improper, and that possibility may be explored by way of a declaratory judgment action … . Strong v St. Thomas Church of Irondequoit, 2017 NY Slip Op 05333, 4th Dept 6-30-17

 

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NUISANCE LAW COULD LEAD TO EVICTION FOR REPORTING CRIMES TO THE POLICE, THE REACH OF THE LAW VIOLATED TENANTS’ FIRST AMENDMENT RIGHTS AND WAS THEREFORE UNENFORCEABLE AGAINST THE LANDLORD.

The Third Department, in a full-fledged opinion by Justice Garry, determined a village nuisance law was facially unconstitutional and could not be enforced against the owner of several properties which rented out single rooms. Apparently, criminal activity, including domestic abuse, at these properties was a concern for the village. The local village nuisance law assigned points for certain conditions or incidents at the properties. Points were assessed even when police were called to the properties by crime victims. Once a certain number of points are accumulated, the village can take certain enumerated actions against the property owner, including ordering the eviction of tenants. The reach of the nuisance statute therefore encroached on the tenant’s first amendment right to report crimes to the police (to petition the government for redress of grievances):

The Nuisance Law’s provisions pertaining to remedies demonstrate that the loss of a tenant’s home may result directly from the designation of a property as a public nuisance. As previously noted, the Nuisance Law expressly permits owners to include the eviction of tenants in the required plans to abate public nuisances — again, with no exception for tenants who may have caused points to be assessed against a property by summoning police because they were victimized by criminal activity, or who otherwise exercised their constitutionally-protected right to request police assistance. Further, as the relief permitted by article II of the Nuisance Law includes the property’s temporary closure, all tenants and occupants of a property where illegal activity occurs — not just those who actually commit a violation — are at risk of losing their homes upon a declaration that the property is a public nuisance. The plain language of the law therefore tends to discourage tenants from seeking help from police. As the amici curiae assert, this discouragement may have a particularly severe impact upon victims of domestic violence … . If a tenant who has an order of protection against an individual because of prior domestic violence calls police for assistance in enforcing the order, points may be assessed against the property. Further, if a tenant summons police because he or she has been the victim of a crime of domestic violence involving assault or one of the other offenses worth 12 points, the Nuisance Law automatically deems the property to be a public nuisance, placing the tenant at risk of losing his or her home solely because of this victimization. Board of Trustees of The Vil. of Groton v Pirro, 2017 NY Slip Op 04938, 3rd Dept 6-5-17

MUNICIPAL LAW (NUISANCE LAW, LANDLORD-TENANT, CONSTITUTIONAL LAW, NUISANCE LAW COULD LEAD TO EVICTION FOR REPORTING CRIMES TO THE POLICE, THE REACH OF THE LAW VIOLATED TENANTS’ FIRST AMENDMENT RIGHTS AND WAS THEREFORE UNENFORCEABLE AGAINST THE LANDLORD)/CONSTITUTIONAL LAW (MUNICIPAL LAW, LANDLORD-TENANT, NUISANCE LAW COULD LEAD TO EVICTION FOR REPORTING CRIMES TO THE POLICE, THE REACH OF THE LAW VIOLATED TENANTS’ FIRST AMENDMENT RIGHTS AND WAS THEREFORE UNENFORCEABLE AGAINST THE LANDLORD)/LANDLORD-TENANT (MUNICIPAL LAW, CONSTITUTIONAL LAW, NUISANCE LAW COULD LEAD TO EVICTION FOR REPORTING CRIMES TO THE POLICE, THE REACH OF THE LAW VIOLATED TENANTS’ FIRST AMENDMENT RIGHTS AND WAS THEREFORE UNENFORCEABLE AGAINST THE LANDLORD)/NUISANCE LAW (MUNICIPAL LAW, CONSTITUTIONAL LAW,  NUISANCE LAW COULD LEAD TO EVICTION FOR REPORTING CRIMES TO THE POLICE, THE REACH OF THE LAW VIOLATED TENANTS’ FIRST AMENDMENT RIGHTS AND WAS THEREFORE UNENFORCEABLE AGAINST THE LANDLORD)

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ALTHOUGH THE BUILDING OWNER WAS AN ADDITIONAL INSURED ON THE LESSEE’S POLICY, THE INSURER HAD NO DUTY TO DEFEND AN ACTION STEMMING FROM A SLIP AND FALL IN THE BUILDING PARKING LOT, THE LEASE DID NOT CALL FOR MAINTENANCE OF THE PARKING LOT BY THE LESSEE.

The Second Department determined the insurer of a lessee had no duty to defend an action by plaintiff who slipped and fell in the parking lot of the building. The lease included no obligation to maintain the parking lot. Although the building owner was an additional insured on the lessee’s policy, the injury was not the result of a bargained-for risk:

An insurer’s duty to defend is “exceedingly broad”… . An additional insured is entitled to the same coverage as if it were a named insured … . “If any of the claims against an insured arguably arise from covered events, the insurer is required to defend the entire action” … . The phrase “arising out of” requires “only that there be some causal relationship between the injury and the risk for which coverage is provided” … . “[A]n insurer does not wish to be liable for losses arising from risks associated with a premises for which the insurer has not evaluated the risk and received a premium” … . Moreover, “[u]nambiguous provisions of an insurance contract must be given their plain and ordinary meaning” … . The interpretation of policy language is a question of law for the courts … .

Here, [the insurer] established its prima facie entitlement to judgment as a matter of law. The additional insured endorsement unambiguously provided that [the building owner] was an additional insured for liability “arising out of” the “ownership, maintenance or use” of the “premises leased” to [lessee]. [The lessee] leased only a portion of the building from [the owner], not the parking lot where the accident occurred, and it had no duty to maintain the parking lot. As such, there was no causal relationship between the injury and the risk for which coverage was provided, and [plaintiff’s] injury was not a bargained-for risk … . Atlantic Ave. Sixteen AD, Inc. v Valley Forge Ins. Co., 2017 NY Slip Op 04243, 2nd Dept 5-31-17

INSURANCE LAW (ALTHOUGH THE BUILDING OWNER WAS AN ADDITIONAL INSURED ON THE LESSEE’S POLICY, THE INSURER HAD NO DUTY TO DEFEND AN ACTION STEMMING FROM A SLIP AND FALL IN THE BUILDING PARKING LOT, THE LEASE DID NOT CALL FOR MAINTENANCE OF THE PARKING LOT BY THE LESSEE)/LANDLORD-TENANT (INSURANCE LAW, ALTHOUGH THE BUILDING OWNER WAS AN ADDITIONAL INSURED ON THE LESSEE’S POLICY, THE INSURER HAD NO DUTY TO DEFEND AN ACTION STEMMING FROM A SLIP AND FALL IN THE BUILDING PARKING LOT, THE LEASE DID NOT CALL FOR MAINTENANCE OF THE PARKING LOT BY THE LESSEE)/SLIP AND FALL (INSURANCE LAW, ALTHOUGH THE BUILDING OWNER WAS AN ADDITIONAL INSURED ON THE LESSEE’S POLICY, THE INSURER HAD NO DUTY TO DEFEND AN ACTION STEMMING FROM A SLIP AND FALL IN THE BUILDING PARKING LOT, THE LEASE DID NOT CALL FOR MAINTENANCE OF THE PARKING LOT BY THE LESSEE)

COMPLEX ISSUES ARISE IN RETROACTIVELY DETERMINING THE APPROPRIATE RENTAL AMOUNT FOR A RENT STABILIZED APARTMENT OCCUPIED BY THE SAME TENANTS SINCE 2000.

The First Department, in a full-fledged opinion by Justice Gische, dealt with complex issues relating to the appropriate rental amount for a rent stabilized apartment occupied by the same tenants since 2000:

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There are interlocking complex issues framed by this appeal involving plaintiffs’ claims that the apartment they have continuously rented for the last 16 years (apartment 5M), was improperly removed from rent stabilization. The overarching issue is whether the apartment should be restored to rent stabilization because defendant 72A Realty Associates L.P. (the Owner) deregulated the apartment pursuant to the luxury decontrol laws while it was simultaneously receiving tax incentives under the City’s J-51 program … . There can be little dispute that following Roberts v Tishman Speyer Props., L.P., (13 NY3d 270 [2009]) and its progeny applying Roberts retroactively … the subject apartment must be returned to rent stabilization as of 2000, when the Owner first treated the apartment as exempt. The thornier issues implicated by returning the apartment to rent stabilization concern the setting of the stabilized rent, the base date for, and the statute of limitations applicable to, the setting of such rent, and the possible imposition of treble damages and attorney fees. We agree with Supreme Court that plaintiffs are entitled to a declaration that the apartment was and still is subject to rent stabilization and that they are the rent-stabilized tenants thereof. We also agree with Supreme Court that the issues of the legal rent, as well as the issues of possible overcharge, treble damages and attorneys fees cannot be resolved on a motion for summary judgment. We disagree with Supreme Court only insofar as it held that the increases made to the rent-stabilized rent in 2000, based upon individual apartment improvements (IAIs) before the plaintiffs took occupancy, are subject to challenge on this record. Taylor v 72A Realty Assoc., L.P., 2017 NY Slip Op 04218, 1st Dept 5-25-17

LANDLORD-TENANT (COMPLEX ISSUES ARISE IN RETROACTIVELY DETERMINING THE APPROPRIATE RENTAL AMOUNT FOR A RENT STABILIZED APARTMENT OCCUPIED BY THE SAME TENANTS SINCE 2000)/RENT STABILIZATION (NYC) (COMPLEX ISSUES ARISE IN RETROACTIVELY DETERMINING THE APPROPRIATE RENTAL AMOUNT FOR A RENT STABILIZED APARTMENT OCCUPIED BY THE SAME TENANTS SINCE 2000)

TAKING IN AIRBNB CUSTOMERS IN A RENT-STABILIZED APARTMENT VIOLATED THE RENT STABILIZATION CODE (NYC), LESSOR ENTITLED TO TERMINATE THE ELDERLY 40-YEAR TENANT’S LEASE.

The First Department, reversing Supreme Court, over a two-justice dissent, determined plaintiff was entitled to terminate defendant’s lease of a rent-stabilized cooperative apartment for “subletting” to Airbnb customers. Defendant, an elderly 40-year tenant, took in Airbnb customers on 338 days over an 18-month period, realizing $12,000 more than 10% “profit” allowed for “subletting” under the Rent Stabilization Code:

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Defendant’s listing on the Airbnb website also provided (1) links for making reservations, (2) “check-in” and “check-out” times, (3) the financial penalty for untimely cancellation, and (4) reviews from numerous past guests.

Turning her rent-stabilized apartment into a single-unit tourist hotel in this fashion enabled defendant to earn substantial profits, far in excess of the legally permissible 10% premium. After Airbnb (to which the subtenants paid the rent) deducted its fees, the subletting generated total income of $33,592.00 for defendant. The stabilized rent she paid for the same 338 days (based on the aforementioned per-diem figure of $57.80) was only $19,536.40. Thus, defendant realized a 72% profit from her subletting — about seven times the 10% premium permitted for otherwise lawful sublets of furnished rent-stabilized apartments. Had defendant limited herself to the 10% premium permitted by the RSC, her aggregate revenue would have been $21,490.04 — about $12,000 less than her actual revenue of $33,592.00. Taking into account the lawful 10% premium (and ignoring the fact that the apartment was shared), defendant overcharged her 93 subtenants, in aggregate, by approximately 56% … . Goldstein v Lipetz, 2017 NY Slip Op 04070, 1st Dept  5-23-17

 

LANDLORD-TENANT (TAKING IN AIRBNB CUSTOMERS IN A RENT-STABILIZED APARTMENT VIOLATED THE RENT STABILIZATION CODE (NYC), LESSOR ENTITLED TO TERMINATE THE ELDERLY 40-YEAR TENANT’S LEASE)/RENT STABILIZATION CODE (NYC) (TAKING IN AIRBNB CUSTOMERS IN A RENT-STABILIZED APARTMENT VIOLATED THE RENT STABILIZATION CODE (NYC), LESSOR ENTITLED TO TERMINATE THE ELDERLY 40-YEAR TENANT’S LEASE)/AIRBNB  (TAKING IN AIRBNB CUSTOMERS IN A RENT-STABILIZED APARTMENT VIOLATED THE RENT STABILIZATION CODE (NYC), LESSOR ENTITLED TO TERMINATE THE ELDERLY 40-YEAR TENANT’S LEASE)

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TENANT ASSAULTED BY INTRUDER, QUESTIONS OF FACT ABOUT FORESEEABILITY, ADEQUACY OF SAFETY PRECAUTIONS, AND PROXIMATE CAUSE REQUIRED REVERSAL OF GRANT OF SUMMARY JUDGMENT TO DEFENDANTS.

The First Department, reversing Supreme Court, determined there were questions of fact precluding summary judgment in favor of the defendants in this action stemming from the assault of plaintiff-tenant by an intruder. The intruder entered the building by “piggy-backing” on an entering tenant. There was evidence this particular intruder had entered the building the same way on other occasions when he had harassed and assaulted women:

Given the existence of an issue of fact as to foreseeability, an issue of fact also exists whether defendants discharged their common-law duty to take minimal precautions to protect the tenants from the foreseeable harm… . In particular, in view of the previous incidents, issues of fact exist whether the security measures in place adequately protected female tenants from the risks posed and whether reasonable measures should have included, among others, warnings to tenants about the perpetrator, advising security staff of the perpetrator’s prior arrest in the complex, providing security staff and tenants with the perpetrator’s photograph, real-time monitoring of surveillance videos, or increasing the presence of lobby attendants, who were absent on the day of the assault. In other words, under the unique circumstances of this case, an issue is raised as to whether defendants, who had notice of this repeat intruder, took minimal security steps with respect to preventing his ability to easily access the interior of their buildings and attempt to sexually assault female tenants … .

Finally, an issue of fact exists whether any negligence on defendants’ part was a proximate cause of the assault … . The record shows that the perpetrator was able to gain entry into plaintiff’s building not as a guest but as an intruder; given defendants’ awareness of the practice of “piggy backing” in general and “piggy backing” by this perpetrator specifically, the tenant’s act of permitting the perpetrator to enter the building by “piggy backing” does not, as a matter of law, amount to a superseding intervening act that breaks the chain of causation between any deficient security and the assault on plaintiff … . Gonzalez v Riverbay Corp., 2017 NY Slip Op 04042, 1st Dept 5-18-17

NEGLIGENCE (TENANT ASSAULTED BY INTRUDER, QUESTIONS OF FACT ABOUT FORESEEABILITY, ADEQUACY OF SAFETY PRECAUTIONS, AND PROXIMATE CAUSE REQUIRED REVERSAL OF GRANT OF SUMMARY JUDGMENT TO DEFENDANTS)/ASSAULT (NEGLIGENCE, TENANT ASSAULTED BY INTRUDER, QUESTIONS OF FACT ABOUT FORESEEABILITY, ADEQUACY OF SAFETY PRECAUTIONS, AND PROXIMATE CAUSE REQUIRED REVERSAL OF GRANT OF SUMMARY JUDGMENT TO DEFENDANTS)/LANDLORD-TENANT (ASSAULT, NEGLIGENCE, TENANT ASSAULTED BY INTRUDER, QUESTIONS OF FACT ABOUT FORESEEABILITY, ADEQUACY OF SAFETY PRECAUTIONS, AND PROXIMATE CAUSE REQUIRED REVERSAL OF GRANT OF SUMMARY JUDGMENT TO DEFENDANTS)

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UNDISCLOSED PRINCIPAL CAN SUE ON A LEASE ENTERED INTO BY ITS AGENT.

The Second Department determined the owner of a parking lot (Berkshire) could assert cross claims against the lessee of the parking lot (Livingston), even though the lessee did not know the lease was entered into by an undisclosed agent of the owner. Plaintiff was injured in a slip and fall on the sidewalk adjacent to the parking lot. The owner cross-claimed for indemnification by the lessee:

Berkshire may enforce provisions of Livingston’s lease for the parking lot. An undisclosed principal may sue on a contract made in the name of its agent unless there is a showing of fraud … . Here, Livingston’s submissions confirmed that Berkshire owned the property that Livingston was renting, and that the lease was valid. Livingston does not assert that it would not have entered into the lease had it known then that Berkshire was, in fact, the owner. Although Livingston was not aware that Berkshire had authorized an agent to enter into the lease on its behalf, Livingston cannot escape liability on the contract by claiming ignorance of the undisclosed principal’s existence … . Simmons v Berkshire Equity, LLC, 2017 NY Slip Op 03208, 2nd Dept 4-26-17

CONTRACT LAW (UNDISCLOSED PRINCIPAL CAN SUE ON A LEASE ENTERED INTO BY ITS AGENT)/AGENCY (UNDISCLOSED PRINCIPAL CAN SUE ON A LEASE ENTERED INTO BY ITS AGENT)/LANDLORD-TENANT (UNDISCLOSED PRINCIPAL CAN SUE ON A LEASE ENTERED INTO BY ITS AGENT)/NEGLIGENCE (SLIP AND FALL, UNDISCLOSED PRINCIPAL CAN COUNTERCLAIM AGAINST LESSEE BASED ON A LEASE ENTERED INTO BY ITS AGENT)/AGENCY (UNDISCLOSED PRINCIPAL CAN SUE ON A LEASE ENTERED INTO BY ITS AGENT)

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