fabricated eviction notice on petitioner's door can only be construed as an act to create chaos and
confusion, done to cause an illegal eviction. Had this illegal notice been taken further, this
petitioner could have been unlawfully removed during a time of critical public health
emergency.
Respondent takes no responsibility and claims no awareness. Respondent does not deny or
dispute the video and text messages sent to petitioner and Mr. Pang.
Petitioner's evidence shows a series of messages demanding that petitioner pay or move out.
Petitioner also shows that video messages were sent to her husband with suggestions that [*4]there were criminal activities going on at the premises. The videos,
recorded and sent by respondent's agent, suggest an objective and goal to compel petitioner to
move out. Alleging robbery and insinuation that petitioner is engaged in prostitution can only be
interpreted as behavior intended to cause humiliation and interference with one's enjoyment of
the premises. The Administrative Code includes threatening, intimidating or using obscene
language; g. other repeated acts or omissions of such significance as to substantially interfere
with or disturb the comfort, repose, peace or quiet of any person lawfully entitled to occupancy of
such dwelling unit and that cause or are intended to cause such person to vacate such dwelling
unit or to surrender or waive any rights in relation to such occupancy.
Section 27-2005 of the NYC Admin Code states that "[t]he owner of a dwelling
shall not harass any tenants or persons lawfully entitled to occupancy of such dwelling."
Harassment is defined as "any act or omission by or on behalf of an owner that causes or is