Zimmerman v. 1660 Condominium Ass'n

Plaintiff, Irving R. Zimmerman, doing business as Irving Zimmerman Associates, filed suit to foreclose a mechanics’ lien and for unjust enrichment against the defendants, 1660 Condominium Association (the Association), and the board of managers of the 1660 Condominium (the board). The trial court dismissed plaintiff’s suit for failure to name and individually serve each of the owners of the 429 condominium units. On appeal, plaintiff raised the issue whether a party pursuing a mechanics’ lien foreclosure action or an unjust enrichment action involving improvements made to the common elements…