MEMORANDUM & ORDER
PAUL A. CROTTY, District Judge.
Plaintiff Eugene DiMatteo is a statutory tenant in a rent-controlled apartment in New York City. His landlord refused to cash a year's worth of rent checks tendered, not by DiMatteo, but rather by a person who lives with DiMatteo, because doing so might establish a right to succeed to DiMatteo's rent-controlled tenancy. The landlord, represented by Defendants, commenced a summary...
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