Status: “The complaint is well underway. Several plaintiffs were identified and the challenge was filed on their behalf, which of course, is on behalf of all property owners in NYS. The suit focuses on the COVID Hardship Declaration Form, which has been part and parcel to the “eviction moratorium” and other hurdles put in place to recovery of money or real property, and alleges that the instrument results in the following (and other) violations of the NYS and US Constitutions: violation of property owners’ right to due process, that the Legislature has delegated specifically non-delegable powers of the Judiciary and courts, that the control of cases has been vested in a party with a direct interest in the outcomes (Tenants, and that the language lack specificity and shifts the burden of proof to the Property Owner. The order to show cause was submitted the week of 3/12, was signed by the judge, and as a result, the state has until 3/25 to present arguments against a temporary restraining order against this law while the case can be heard in court. Once tendered, the Plaintiffs have until 3/29 to reply to those arguments, and then it will be in the hands of a judge to review. I have attached a copy of the filed complaint herein for your review.

At this stage, we are hopeful that many of our associates across the state, all of whom will ultimately benefit from a victory in this suit, will assist with contributions to the legal costs. The estimated total amount is approximately $50,000.

Would you please help us out by reaching out to anyone who might be able to make a substantial or even a smaller, contribution to the cause?

Even more critical – would CDARPO be willing to contribute a substantial donation?

NYCRA will be participating as well, and we would very much appreciate any assistance CDARPO is able to bring to the table.

Together – NYS property owners can accomplish anything!

Here is the entity through which … the legal challenge …is being funded:


Rockmore, LLC
PO Box 11600
Albany, NY 12211-0600

Summons & Complaint