the interfer- ence with a person’s right to possession of real property either by an unlawful act or a lawful act performed in an unlawful man- ner.” N.Y. State Nat'l Org. for Women v. Terry, 886 F.2d 1839, 1361 (2d Cir.1989) (citing Ivancic v. Olmstead, 66 N.Y.2d 349, 352, 497 N.Y.S.2d 326, 488 N.E.2d 72 (1985)). To th