Case Type

Non-payment

Housing Type

Rent Stabilized

Court

Civil Court of the City of New York

County

New York County (Manhattan)

L&T / Index / Case / Docket / Clerk's Number

LT-319095-24/NY

Petitioner

109TH AFFORDABLE HOUSING LLC

Respondent

ANA NOELIA ALMANZAR

Judge

Meyers, Adam, R

Decision/Order Date

2025-10-16

Posture

Post-answer Motion by Tenant

Disposition

Motion Granted for Tenant

Winner

Tenant Substantially Won

Synopsis

In a nonpayment proceeding, the tenant moved for leave to amend their answer to interpose an overcharge counterclaim and for discovery. The court granted the tenant's motion to amend, finding sufficient indicia of a potentially meritorious overcharge claim due to long gaps in rent registrations and a significant rent increase, noting that under *W. Pierre Assoc. LLC v Harvey*, fraud is not required to look beyond the base date for post-HSTPA tenancies. The court also granted the tenant's motion for limited discovery, finding ample need based on the rent history irregularities and reminded the landlord of the utility of a *Jackson* affidavit if certain documents were unavailable.

Keywords

Rent Overcharge; Discovery; Gaps In Registration History; Large Rent Increase; Jackson Affidavit

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