New development activity is back in New York, and the roar of construction has awakened a dreaded industry bogeyman: the holdout. From the Diamond District to Billionaires’ Row, neighbors and tenants have dug in their heels and hobbled major projects. Perhaps the starkest example is playing out at Miki Naftali’s Upper West Side condominium conversion at 215 West 84th Street. In February, the developer sued Ahmet Ozsu, the sole remaining tenant in the 16-story apartment

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