Rich v. East 10th Street Associates LLC

Tom, J.P. (dissenting).

These actions, consolidated for disposition, seek recovery of rent overcharges in the amount paid under a lease subject to the Rent Stabilization Law of 1969. While the actions are governed by the four-year statute of limitations of CPLR 213-a, the issue to be decided is whether the statutory proscription against “examination of the rental history of the housing accommodation prior to the four-year period immediately preceding the commencement of the action” encompasses a rent reduction order that was issued prior to the limitations period.

Resolution of these matters…