320 Manhattan Ave. LP v. Nebbou

2026 NY Slip Op 30014(U)
CourtCivil Court Of The City Of New York, New York County
DecidedJanuary 21, 2026
DocketIndex No. L&T 308934/22
StatusUnpublished
AuthorClinton J. Guthrie

This text of 2026 NY Slip Op 30014(U) (320 Manhattan Ave. LP v. Nebbou) is published on Counsel Stack Legal Research, covering Civil Court Of The City Of New York, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
320 Manhattan Ave. LP v. Nebbou, 2026 NY Slip Op 30014(U) (N.Y. Super. Ct. 2026).

Opinion

320 Manhattan Ave. LP v Nebbou 2026 NY Slip Op 30014(U) January 21, 2026 Civil Court of the City of New York, New York County Docket Number: Index No. L&T 308934/22 Judge: Clinton J. Guthrie Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. LT-308934-22/NY FILED: NEW YORK CIVIL COURT - L&T 01/21/2026 09:23 AM NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 01/21/2026

CIVIL COURT OF THE CITY OF NEW YORK COUNTY OF NEW YORK: HOUSING PART D ---------------------------------------------------------------X 320 MANHATTAN AVENUE LP, Index No. L&T 308934/22

Petitioner,

-against- DECISION/ORDER

ALLAN NEBBOU, JOHN DOE, JANE DOE,

Respondents. ----------------------------------------------------------------X Present:

Hon. CLINTON J. GUTHRIE Judge, Housing Court

Recitation, as required by CPLR § 2219(a), of the papers considered in the review of respondent’s motion for summary judgment and related relief (seq. 4), and petitioner’s cross- motion for summary judgment (seq. 5):

Papers Numbered

Notice of Motion & All Documents Annexed………………....... 1 (NYSCEF #37-43) Notice of Cross-Motion & All Documents Annexed....………..... 2 (NYSCEF #46) Reply Affirmation & All Documents Annexed………………….. 3 (NYSCEF #51-54) Affirmation in Reply (for Cross-Motion) & All Documents Annexed………………………………………………………….. 4 (NYSCEF #56)

Upon the foregoing cited papers, the decision and order on respondent’s motion and petitioner’s

cross-motion, consolidated for determination herein, is as follows.

PROCEDURAL HISTORY

This summary nonpayment proceeding was filed in June 2022. Respondent filed a pro se

answer in June 2022. Thereafter, counsel for respondent appeared and an amended answer was

filed on consent. Respondent later moved for discovery and petitioner cross-moved to strike

certain defenses and counterclaims. By Decision/Order dated April 3, 2023, Judge Tracy

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Ferdinand granted respondent’s motion for discovery and denied petitioner’s motion except to

the extent of permitting amendment of the petition to date.

Following the completion of discovery, both parties have moved for summary judgment.

After several adjournments for briefing and attempted settlement, this court heard argument on

both motions on July 17, 2025.

DISCUSSION/CONCLUSION

The related issues relevant to both summary judgment motions are the legality of the rent

sought by petitioner and the regulatory status of the subject apartment before respondent’s

tenancy. Both parties agree that the subject apartment is currently subject to rent stabilization.

Respondent argues in his motion that he was charged an inflated rent from the inception of his

tenancy in 2013 and has overpaid rent as a result. In support of its cross-motion, petitioner

argues that the subject apartment was subject to rent control during the tenancy of the prior long-

term tenant, that the first rent-stabilized rent agreed to with respondent was lawful, and that any

registration of the apartment as rent stabilized during the rent-controlled tenancy was erroneous

and immaterial.

Petitioner is correct that rent stabilization coverage cannot be conferred by waiver or

estoppel (Matter of Trainer v State of N.Y. Div. of Hous. & Community Renewal, 162 AD3d 461

[1st Dept 2018]; 546 W. 156th St. HDFC v Smalls, 43 AD3d 7, 11 [1st Dept 2007]). Petitioner’s

proof that the apartment was rent controlled during the period of the prior tenancy consists of

notations on the DHCR (New York State Division of Housing and Community Renewal) rent

registration that the apartment was registered as rent controlled from 1984 to 1996 and an

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affidavit from Juda Stern, petitioner’s managing agent.1 Mr. Stern states in his affidavit that

prior tenant, Thornton Meacham, was “erroneously registered as a ‘Rent Stabilized (‘RS’) tenant

in subsequent years . . . from 1997 through 2009.” (Stern Aff., ¶ 8).

Respondent does not explicitly dispute that the apartment was previously subject to rent

control but argues that pursuant to a Regulatory Agreement between DHCR and petitioner dated

January 30, 1997, the apartment would have become subject to rent stabilization starting in 1997.

Petitioner opposes by asserting that the subject apartment was not one of those that were

“income-based” subject to the Regulatory Agreement.

Generally, an apartment that is rent controlled will retain that status even if the apartment

becomes temporarily exempt or subject to a statute or program that would otherwise confer rent

stabilization status (see Oteri v Temporary State Hous. Rent Commission, 9 AD2d 529, 530 [1st

Dept 1960], affd 8 NY2d 810 [1960]; President Park Inc. v Brabham, 167 Misc 2d 700, 705-706

[Civ Ct, Kings County 1995]). The court can discern nothing in the Regulatory Agreement

annexed to respondent’s motion that would indicate that the apartment would lose rent control

status when it came into effect. Nonetheless, the court finds that there exist material issues of

fact regarding the regulatory status of the subject premises immediately before respondent’s

tenancy that preclude summary judgment in either party’s favor (see P & J Hous. Partners v

Alvarado, 34 Misc 3d 130[A], 2011 NY Slip Op 52310[U] [App Term, 1st Dept 2011]). The

DHCR registration suggests but does not establish that the prior long-term tenant was rent

controlled. Contrariwise, the court does not find that respondent established that the apartment

was rent stabilized during the prior tenancy. If the apartment was rent controlled, the process for

1 The court notes that the copy of the DHCR rent registration was annexed to respondent’s moving papers. 3

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setting the initial rent-stabilized rent would be governed by the Rent Stabilization Code (RSC),

specifically RSC § 2521.1(a)(1) (9 NYCRR § 2521.1(a)(1)) (see Liggett v Lew Realty LLC, 42

NY3d 415, 420 [2024]). While petitioner is correct that under pre-HSTPA (Housing Stability

and Tenant Protection Act) law, a fair market rent appeal (FMRA) to challenge the initial rent of

an apartment formerly subject to rent control needed to be filed within four years of the last rent-

controlled tenant’s vacancy, this limitation does not apply when rent regulatory status is at issue

(see Thurman v Sullivan Props. L.P., 226 AD3d 453, 454 [1st Dept 2024]; Jacin Invs. Corp.,

N.V. v Von Vogt, 87 Misc 3d 130[A], 2025 NY Slip Op 51649[U], *2 [App Term, 1st Dept

2025]).

Moreover, even if respondent had unequivocally proven that the apartment was not

subject to rent control immediately before his tenancy, he has not demonstrated, as a matter of

law, that petitioner engaged in regulatory fraud or a “fraudulent scheme to evade the protection

of the rent stabilization laws” (Burrows v 75-25 153rd St., LLC, 44 NY3d 74, 84 [2025]) that

would allow the court to review the rental history beyond the 4-year base date and determine that

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Related

Oteri v. Temporary State Housing Rent Commission
9 A.D.2d 529 (Appellate Division of the Supreme Court of New York, 1960)
Oteri v. Temporary State Housing Rent Commission
168 N.E.2d 389 (New York Court of Appeals, 1960)
546 West 156th Street HDFC v. Smalls
43 A.D.3d 7 (Appellate Division of the Supreme Court of New York, 2007)
President Park Inc. v. Brabham
167 Misc. 2d 700 (Civil Court of the City of New York, 1995)
Liggett v. Lew Realty LLC
42 N.Y.3d 415 (New York Court of Appeals, 2024)
Burrows v. 75-25 153rd St., LLC
44 N.Y.3d 74 (New York Court of Appeals, 2025)
Jacin Invs. Corp., N.V. v. Von Vogt
2025 NY Slip Op 51649(U) (Appellate Terms of the Supreme Court of New York, 2025)

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