In Valdez v. Northeast Brooklyn Housing Development Corp. (8 Misc 3d 1008[A], 801 N.Y.S.2d 782, 2005 NY Slip Op 50986[U] [Sup Ct, Kings County 2005]), plaintiff-tenant sought a declaratory judgment and a preliminary injunction to prevent defendant-landlord from violating a relocation agreement and plaintiff's possessory rights to her apartment. The Court granted plaintiff a preliminary injunction, and held, at 5-6, "given that plaintiff appears to derive her income primarily from social security benefits and defendant has not demonstrated that it will suffer any undue hardship as a result of the injunctive relief granted by the court, the court finds that an undertaking in the amount of $ 100.00 shall be good and sufficient for purposes of CPLR 6312 (b)."