ZAFRA v. PILKES


245 A.D.2d 218 (1997)

666 N.Y.S.2d 633

Christopher H. Zafra, Appellant, v. Simon Pilkes, Respondent

Appellate Division of the Supreme Court of the State of New York, First Department.

December 30, 1997


Appellate Term upheld the determination of the Civil Court that neither the four-year Statute of Limitations for rent overcharge complaints (Rent Stabilization Law of 1969 [Administrative Code of City of NY] § 26-516 [a] [2]; Rent Stabilization Code [9 NYCRR] § 2526.1 [a] [2]) nor the record-keeping provisions relieving a landlord from having to produce records dating back more than four years prior to the most recent...

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