Brickerhoff v. DHCR

In Brickerhoff v. DHCR, 275 AD2d 622, (1st Dept. 2000) it was held that since the four-year Statute of Limitations contained in the RSL and the CPLR "by its terms commences to run with the first overcharge alleged', (and) since the first overcharge alleged by petitioners occurred on August 1, 1984 and the overcharge proceeding before DHCR was not commenced until April 6, 1989, the proceeding was time-barred".