Defendant tenant moved for treble damages solely on the basis of the overcharge, without arguing the landlord's willfulness, a requirement, in any event, effectively rebutted in the landlord's opposition. On the occasion of the judgment as well as in the order under review, the IAS Court made no finding of willfulness, a necessary predicate to an award of treble damages under the Rent and Rehabilitation Law (Administrative Code of City of NY § 26-413 [d] [2]). Since...
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