Graubard Mollen Horowits Pomeranz & Shapiro v. 600 Third Avenue Associates

In Graubard Mollen Horowits Pomeranz & Shapiro v. 600 Third Avenue Associates, 240 A.D.2d 161 (1st Dept. 1997), the Appellate Division held that the alleged interference with the tenant's ingress and egress to its premises by the landlord replacing two elevators with three smaller ones resulting in a reduction of elevator service never resulted in a denial of access and therefore did not constitute a partial actual eviction.