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The usual method for recovering property left in a residence that the present tenant or landlord refuses to release is through small claims court. The owner of the personal property must file a claim in court and win a judgment. The court would issue an order for the recovery of the property or money damages, not a lien.

In most cases in is illegal for someone to hold personal property unless the holder has a court order allowing the action or a judgment for debt owed.

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Q: Can a lien be placed on a house to allow personal property to be recovered from the residence in New York?
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