Contrary to defendants' argument, the IAS court was not obliged to defer to the Special Referee, since her report and recommendations did not depend on the credibility of witnesses; rather, it was based on counsel's billing records. The court correctly characterized this case as involving "far from difficult," "run-of-the-mill issues," requiring four court appearances, two of which involved adjournments, a "simple motion" and a settlement for the full amount of rent arrears...
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