deregulation, is erroneous and based on contradictory evidence; and that the owner used
preferential rents to create the idea that the apartment was subject to rent regulation while
simultaneously claiming that the apartment was not subject to rent regulation, which made the
tenants uncertain as to the rent regulated status of the apartment.
The tenants further contend that, since the current owner purchased the subject building,
such owner has deregulated nearly 70% of the building's rent stabilized apartments; that, although
the owner alleged it is in possession records that shows that the subject apartment was deregulated,
it has failed to produce such records or to provide them to the tenants; that the owner. contradicted
the 2007 deregulation of the apartment by stating that the subject apartment became a free market
apartment in 2014/2015 based on vacancy leases; that the subject apartment was therefore not
exempt from rent stabilization in 2007; that the owner has a history of illegally deregulating rent
stabilized apartments (citing Jeffrety Winsauer· v. Neera Raj, Index 5 I 8755/2022, PAR Docket
IS2 l 0067RK, and I 02 Albemarle Assoc. LLC. v. Mehandru, Index 093429/2013, New York Law
Journal No.1202651137762 (Kings Civ. Ct. 2014)); that the default method for determining the
base date rent should be applied when the owner is found to have engaged in a fraudulent scheme
to deregulate the subject apartment thereby depriving the complaining tenants of their rights under
the Rent Stabilization Law and Code (RSL and RSC); that the RA's Order failed to comply with
Section 307(1) of the State Administrative Procedure Act (SAPA) because the RA failed to provide
any reasoning for his Order; and that the tenants cannot properly file an appeal without knowing
the