MOZES v. SHANAMAN

"The four-year Statute of Limitations applicable to both administrative and judicial rent overcharge claims, by its terms, commences to run with the `first overcharge alleged'" ( Matter of Brinckerhoff v. New York State Div. of Hous. Community Renewal, 275 AD2d 622, 622 [citations omitted], lv denied 96 NY2d 712). Since the first overcharges alleged by plaintiff tenants occurred no later than 1996, these actions commenced in 2003 are time-barred (CPLR 213-a).