Petitioner landlord brought a holdover summary eviction proceeding to recover possession of the subject premises, based on the termination of respondent’s tenancy for her use of the premises to facilitate trade in illegal drugs.

Bronx Housing Court Judge Krzysztof Lach had to determine whether respondent was, and continues to be, a person incapable of adequately defending her interest in this proceeding such that she was in need of a guardian ad litem prior to the entry of the default judgment, as she is suffering from drug addiction and its negative effects.