In People v. Gottlieb (36 N.Y.2d 629 [1975]), the Court of Appeals held that an application for a certificate of occupancy was not a written instrument within the meaning of Penal Law 175.35. At the time, Article 175 did not define "written instrument." The court held that although the nature of the statute prohibiting the filing of a false instrument potentially encompassed a great many documents, the term had to be given a narrow construction so as not to exceed the scope of legislative mandate (id. at 631-631.) The court specifically rejected the argument that the broad definition of "written instrument," then present in Article 170, should also apply to Article 175 (id. at 632), and held that had the legislature intended to define the term in such an expansive way, it would have expressly done so in Article 175 (id. at 633).