In Cut-Outs, Inc. v. Man Yun Real Estate Corp., 286 A.D.2d 258 (1st Dept. 2001), a landlord restricted use of a freight elevator to its tenants during a period of reconstruction of the entire building. The tenants argued that such limitation constituted a partial actual eviction of their premises. In finding for the landlord, the court stated that, although the landlord's renovations caused the tenants substantial inconvenience, involved certain encroachments on the leased premises, and caused delays in bringing shipments in and out of the premises, the tenants were never denied access to their premises. The tenants only evidenced that access was slower, less convenient, less pleasant, and more difficult. The court held that such interference with ingress and egress does not amount to partial actual eviction.