Landlord Entitled to Extended Document Production

Landlord sued to evict rent-stabilized tenant's son after tenant died in January 2015. The son claimed succession rights, and landlord asked for pretrial documentation production. The court ruled for landlord in part but limited the period of time for which landlord could request records. Landlord appealed and won. The appeals court ruled that landlord could seek documents going back five years before tenant died. This covered not only the two-year period before tenant died, but the period prior to the son's incarceration, since this was of critical importance in assessing whether the son had a valid succession defense.

86 West Corp. v. Singh: 57 Misc.3d 152(A), 2017 NY Slip Op 51585(U) (App. T. 1 Dept.; 11/27/17; Lowe III, PJ, Schoenfeld, Shulman, JJ)