STATE OF NEW YORK
                            OFFICE OF RENT ADMINISTRATION
                                     GERTZ PLAZA
                               92-31 UNION HALL STREET
                                  JAMAICA, NY 11433

          APPEAL OF                                    DOCKET NO.:
                                                       HD130053RO et al. (See
                                                       (attached Exhibits A, 
                                                       B and C.)
               Glen Oaks Village Owners, Inc.;
               Glen Oaks Village Corp.;
               Various Individual Owners
               As Holders of Unsold Shares
                                                       RENT ADMINISTRATOR'S
                                                       DOCKET NO.:
                                                       FL130071B et seq. 
                                                       through FL130192B


          The above-named petitioner-owners filed timely petitions for 
          administrative review of various orders issued by the Rent 
          Administrator concerning the housing accommodations known 
          collectively as Glen Oaks Village located in Queens, New York, 
          wherein the Rent Administrator determined the tenants' complaint of 
          various decreased complex wide services.

          The Commissioner has reviewed all the evidence in the record and 
          has carefully considered that portion of the record relevant to the 
          issues raised by the petitions.

          On March 26, 1991, the Rent Administrator determined the complaints 
          of various tenants residing in the housing complex known as Glen 
          Oaks, located in Queens, New York.  That determination under 
          EA110008RK found that playground and storage space facilities were, 
          in fact, base date services which, pursuant to the Rent 
          Stabilization Code, the owner was to provide to tenants.  This 
          determination was affirmed by the Commissioner upon administrative 
          review in an order dated June 12, 1992, and by the Supreme Court 
          upon judicial review in a determination dated July 22, 1993.  GOV 
          Corp. v Division of Housing, Index No. 29415/92, NYLJ Pg.24 Col.6 
          July 28, 1993 (Friedmann, J.).   Said determination is set forth 
          herein, below.
          The instant proceeding was commenced below by approximately 100 
          tenants of Glen Oaks similarly situated, seeking comparable relief, 


          i.e. restoration of services and a rent reduction for owner's 
          failure to provide base date playgrounds, and elimination of 
          storage space facilities.

          The facts as they pertain to the issues of reduction of services 
          are not in dispute to the extent that the owner removed 37 
          children's playgrounds, and that storage space facilities provided 
          by the owner prior to and subsequent to the May 31, 1968 base date, 
          are no longer provided.
          The parties named as owners in the proceedings under review herein 
          were Glen Oaks Village Corp. (hereinafter GOV) and Glen Oaks 
          Village Owners, Inc. (hereinafter GOVO), care of Grenadier Realty 

          GOVO is the cooperative corporation which owns the approximately 
          three thousand (3000) unit complex known as Glen Oaks Village.  
          Grenadier Realty Corp. was the managing agent for the entire 

          GOV is one of the owners and holder of the shares of stock 
          allocated to various apartments.  They were the owners of the 
          apartments in the proceedings under EA110008RK.  GOVO indicated in 
          their papers below that GOV is a nominee or a subsidiary of the 
          America Savings Bank, which held a security interest in various 
          stock and leases held by the sponsor of the cooperative concern, 
          and that American Savings Bank was taken over by the Federal 
          Deposit Insurance Corporation (hereinafter FDIC).

          The Rent Administrator's Notice and Transmittal of Tenant's 
          Complaint, the copy of the complaint and answer forms were mailed 
          on January 22, 1992 to GOVO at their correct address.

          GOVO filed an answer asserting the following:

               In each of these proceedings GOVO is incorrectly 
               indicated as "owner".  GOVO is a cooperative corporation 
               organized under the laws of the State of New York.  The 
               shares for each of the subject apartments are owned by 
               someone or an entity other than GOVO.  GOVO is not the 
               landlord in any of these proceedings.

               The purpose of this letter is only to advise you of these 
               jurisdictional defects.  Please take notice that GOVO, 
               for purpose other than advising you of jurisdictional 
               defects, does not appear in these proceedings and is not 
               a party thereto.  Further, GOVO is not empowered to act 
               for or in place of any of the owners and landlords of the 
               apartments which are the subjects of the annexed copies 
               of Notice and Transmittal of Tenant's Complaint.

          GOV also filed an answer, asserting the following:


               It should be noted that the Order referred to in the 
               tenant's complaint is currently under appeal by the 
               owner.  The appeal has been assigned Docket No.: FH- 
               130039-RO.  The filing of the appeal renders the cited 
               order "non-final."

               Accordingly, as the tenant is basing its claim upon a 
               "non-final" order, the appeal of that order must be 
               resolved before this complaint can be determined.  
               Therefore, we assume that no action will be taken in this 
               matter until the owner's PAR is resolved.

               As an aside, it should also be noted that the complaining 
               tenant has not annexed any documentation which would 
               confirm their claim that any of them specifically had the 
               cited items as a service.  At most, the tenant is 
               attempting to capitalize upon a finding for other, 
               unnamed units at the premises.

          Another answer, filed on behalf of an individual owner of unsold 
          shares at the subject apartment under FL130125B, argued that this 
          tenant had not suffered a decrease in services, that this tenant 
          had not established having been entitled to or deprived of storage 
          space, that this owner could not have failed to maintain storage 
          space since the decision to redo the playgrounds and seal the 
          storage space was by the Board of Directors of the co-op 
          corporation which is not controlled by the individual owner of 
          unsold shares, and that if the co-op corporation does not restore 
          the services this owner will be made to suffer a permanent rent 

          Thereafter, on August 21, 1992, and September 1, 1992, the DHCR 
          conducted inspections of the subject premises.  The DHCR inspector 
          reported that, per the superintendent, no storage space was 
          provided.  The inspector also reported that there were five (5) 
          playgrounds in the complex.

          The Rent Administrator issued orders directing the owner to restore 
          services and further, ordered a reduction of the stabilization 
          rents.  In addition to the inspection results, the Rent 
          Administrator's orders noted that the June 27, 1991 order under 
          EA110008RK, affirmed on administrative appeal, on June 12, 1992 
          found that the storage space was a base date service the owner is 
          required to provide, and that the replacement of 37 playgrounds 
          with five (5) is not an equivalent service.
          In the consolidated petition for administrative review under 
          HD130053RO, GOVO points to the then pending Article 78 proceeding 
          commenced by GOV seeking to annul the Administrator's order under 
          EA110008RK affirmed by the Commissioner's June 12, 1992 under 
          FH130039RO, finding that storage space was a base date service that 
          had been eliminated and that five new large playgrounds did not 


          provide equivalent services to the 37 playgrounds that had been 

          In the Article 78 proceeding, GOV had moved to join GOVO as a 
          necessary party because the services in question (playgrounds and 
          storage space) are common area services within the control of the 
          co-op corporation.

          In response to said notice GOVO made a cross motion for an order 
          remitting the entire proceeding back to the DHCR so that GOVO could 
          be given an opportunity to present its case in those proceedings.

          Anticipating a remand by the Court, GOVO reasons that since all the 
          orders under review were based upon the June 12, 1992 order, and as 
          those proceedings should be remanded pending a new determination 
          therein, the orders under review herein should be vacated.

          A list of the orders issued in March and April 1993, which are the 
          subject of GOVO's petition for administrative review under 
          HD110053RO, is provided in the attached Exhibit A, and is fully 
          made a part of this order.

          Thereafter, GOVO filed separate petitions for administrative review 
          with respect to orders issued later under FL130084B, FL130105B, and 
          FL130186B, assigned HF130096RO, HG130062RO and HH130039RO, setting 
          forth similar reasons.

          GOV filed separate individual petitions for administrative review 
          requesting that the Rent Administrator's orders be revoked or be 
          held in abeyance pending the outcome of GOV's judicial appeal of 
          the order under EA110008RK, as affirmed in the June 12, 1992 order 
          under FH130039RO.  GOV argued that as long as the Article 78 
          petition was pending, or if the matter was remanded for further 
          processing, the subject orders under appeal "herein must be deemed 
          to be based upon a `non-final' determination that's subject to 

          A list setting forth the Rent Administrator's orders and GOV's 
          corresponding petitions for administrative review is set forth in 
          the attached Exhibit B, which is fully made a part of this order.

          In a petition for administrative review under HD130193RO, the 
          individual owner of unsold shares reiterates this owner's arguments 
          set forth under FL130125B that there had been no reduction of 
          playground services, or that this tenant had not established  
          having been entitled to or deprived of storage space, or that this 
          owner could not have failed to maintain services, since the 
          decision to redo the playground and seal the storage area was by 
          the Board of Directors of the co-op corporation, which is not 
          controlled by an individual owner of unsold shares.  The owner 
          speculates that if the co-op corporation does not restore services 
          the owner will be made to suffer a permanent rent freeze; and would 


          constitute a taking of property without compensation.  For the 
          first time on appeal, the owner also points to a General Release 
          signed by the tenant allegedly precluding the tenant therein from 
          any relief based upon the Rent Administrator's order.

          Various individual owners of unsold shares filed individual 
          petitions for administrative review.  They also argued the fact 
          that an Article 78 proceeding was pending in Supreme Court seeking 
          to vacate the June 12, 1992 Commissioner's order as erroneous.  
          They also asserted that as they and/or GOVO had not been parties to 
          the proceedings resulting in the June 12, 1992 order or been given 
          an opportunity to be heard and to present a case below, they had 
          been denied due process, and requested that GOVO be given further 
          opportunity to present its case.

          A list of the administrative appeals filed by these individual 
          owners of unsold shares is provided in the attached Exhibit C, and 
          is fully made a part of this order.

          On July 22, 1993, the Court issued a determination in the Article 
          78 proceeding which: a) denied GOV's motion to join GOVO as a party 
          to the Article 78 proceeding; b) denied GOVO's cross-motion to 
          remit back to the DHCR the proceedings relating to the June 12, 
          1992 order and; c) dismissed the Article 78 petition.  The Court 
          set forth the following:

               The [GOV] motion by petitioner to join GOVO as a 
               necessary party is denied.  In making a determination as 
               to whether a missing party is necessary, the court must 
               consider whether those who are already parties will be 
               given complete relief without joinder and whether the 
               missing party will be inequitably affected by the 
               judgment.  (CPLR 1001 [a]; see, Joanne S. v Carey, 115 
               AD2d 4, 7.)  Here, petitioner seeks a judgment vacating 
               respondent's determination that it is not entitled to a 
               restoration of rents.  The determination rejecting 
               petitioner's PAR was based upon respondent's finding that 
               petitioner had failed to adequately restore certain 
               required services to its tenants, including playgrounds 
               and storage space.  Petitioner claims that since GOVO is 
               ultimately responsible for these services, it is a 
               necessary party.  The argument is without merit.  First, 
               the existing parties will be given final relief by a 
               judgment herein.  It is apparent that petitioner seeks to 
               make GOVO a party so that it will be collaterally 
               estopped in a future action to impose liability upon GOVO 
               for the decrease in required services.  The purpose of 
               this Article 78 proceeding is not to determine the 
               responsibilities of petitioner and GOVO with respect to 
               the common areas, but rather, to determine whether 
               respondent's challenged order is proper.  Second, GOVO, 
               which opposes any joinder, will not be inequitably 


               affected by any judgment if not joined.  Responsibility 
               for the common areas and any potential liability as 
               between GOVO and petitioner in the event of a rent 
               reduction is a separate matter presumably governed by the 
               agreements between them.  In addition, petitioner's claim 
               that GOVO may be liable to provide the aforementioned 
               services to all rent stabilized tenants in the complex as 
               a result of respondent's determination is unfounded.  
               Since GOVO was not a party to any of the proceedings, it 
               is not bound thereby.

               The cross motion by GOVO to remit this matter to 
               respondent is denied.  GOVO contends that it should be 
               given an opportunity to present its case at the 
               administrative level since it may be adversely affected 
               by respondent's determination.  9 NYCRR 2527.3 of the 
               Rent Stabilization Code requires respondent to give 
               notice to anyone adversely affected by any application or 
               answer before it.  However, the application to restore 
               rent and the answer thereto, did not, on their face, 
               adversely affect GOVO.  Furthermore, respondent's 
               determination to proceed solely against petitioner, the 
               owner of the units which was responsible to provide the 
               required services to the rent stabilized tenants and 
               which received rents therefrom, was completely within 
               their discretion.

               Petitioner's petition to vacate respondent's order is 
               denied and the proceeding is hereby dismissed.  An agency 
               determination may not be disturbed upon review by a court 
               unless that determination is arbitrary, capricious and 
               constitutes an abuse of discretion, or is not supported 
               by substantial evidence.  (CPLR 7803; see, Matter of Pell 
               v Board of Educ., 34 NY2d 222.) Upon review of 
               respondent's determination, this court finds that it is 
               not arbitrary and capricious and is supported by 
               substantial evidence in the record.  The determination 
               was entirely discretionary and this court may not 
               substitute its judgment for that of respondent.  (See, 
               Matter of Consol. Edison Co. of New York v New York State 
               Div. of Human Rights, 77 NY2d 411, 417.)  Finally, even 
               if respondent's inspection of the premises while the 
               action was proceeding was improper, it is without legal 
               effect.  Clearly, with respect to the playgrounds issue, 
               respondent based its determination, inter alia, upon its 
               view that the five larger playgrounds were inadequate 
               when compared to the prior thirty-seven smaller ones.  
               The determination would have been the same without the 

          There is no record that either GOV or GOVO pursued appellate review 
          of the Court's determination and the time to do so has expired.


          In light of the Court's decision, GOVO amended its administrative 
          appeals filed prior to the Court's determination, to request that 
          the proceedings below be reopened and/or that the rent reduction be 
          stayed and the matter be remanded to the Rent Administrator.  GOVO 
          contends that this will provide it a full and fair opportunity to 
          present its case in these proceedings, a right GOVO alleges it has 
          been unlawfully and unjustly denied to date.

          In addition, GOVO's application, to amend its PARs, also indicates 
          that GOVO negotiated a purchase and took title on September 21, 
          1993 of 134 cooperative apartments previously controlled by 
          Resolution Trust Company (RTC), and was negotiating a purchase of 
          apartments controlled by the FDIC.  Also noted was that GOVO had 
          filed applications on September 21, 1993 seeking to substitute new 
          services, for the services deemed reduced under the June 12, 1992 

          After careful consideration the Commissioner is of the opinion that 
          the owners' petitions should be denied.

          Tenants residing in rent stabilized apartments located in premises 
          converted to cooperative or condominium ownership are entitled to 
          the same rights and protection as are afforded to all other rent 
          stabilized tenants, as required by the Rent Stabilization Law and 

          The basis for imposing responsibility upon co-op property lessees, 
          co-op sponsors or holders of unsold shares, co-op corporations or 
          associations and their managing agents lies in General Business Law 
          (hereinafter GBL) Sections 352-eee and eeee, subdivision 3, read in 
          conjunction with the definitions of an "owner"  as contained in 
          Section 2520.6(r) of the Rent Stabilization Code (hereinafter 

          Subdivision 3 of both GBL Sections 352-eee and 352-eeee, provides 

               All dwelling units occupied by non-purchasing tenants 
               shall be managed by the same managing agent who manages 
               all other dwelling units in the building or group of 
               buildings or development.  Such managing agent shall 
               provide to non-purchasing tenants all services and 
               facilities required by law on a non-discriminatory basis.  
               The offeror shall guarantee the obligation of the 
               managing agent to provide all such services and 
               facilities until such time as the offeror surrenders 
               control to the board of directors or board of managers, 
               at which time the cooperative corporation or the 


               condominium association shall assume responsibility for 
               the provision of all services and facilities required by 
               law on a non-discriminatory basis.

          Section 2520.6(r) of the Rent Stabilization Code defines the 
          "owner" to include:

          .    Fee owners (includes co-op corporations)
          .    Proprietary lessees
          .    Condo unit owners
          .    Co-op or condo sponsors (i.e., holders of unsold shares or 
          .    Any person or entity entitled to receive rent
          .    An agent of any of the foregoing (includes managing agents and 
               their co-op corporation and condo association guarantors for 
               services pursuant to GBL Section 352-eeee[3])

          From the definition of owner in the rent regulations as well as 
          from GBL Sections 352-eee and 352-eeee, quoted above, all owners, 
          including managing agents, have overlapping virtually concurrent 
          responsibility to provide base date required services.

          GBL Sections 352-eee(3) and 352-eeee(3), quoted above, under 
          "Ownership Entities," require compliance, by the single managing 
          agent, with laws on maintenance of services, including building- 
          wide services and certain services within individual apartments.  
          If such agent does not provide the required services, 
          responsibility lies with the sponsor, co-op corporation/condo 
          association, as well as the proprietary lessee/condo unit owner.

          DHCR may determine that the failure of the single managing agent to 
          provide services, on a nondiscriminatory basis, is a reduction in 
          services which are required by law; in this case, the GBL and the 
          Rent Stabilization Law (hereinafter RSL).  Where the DHCR finds a 
          failure to maintain services, the rent shall be reduced pursuant to 
          the relevant provisions of the Rent Stabilization Law and Code, 
          regardless of which ownership entity or entities caused such 

          While co-op corporations or condominium associations and their 
          individual proprietary lessees or unit owners may have entered into 
          agreements making the corporation/association primarily responsible 
          for building-wide services and proprietary lessees/unit owners 
          primarily responsible for individual apartment services, pursuant 
          to the rent laws and regulations and the single managing agent rule 
          of the GBL, all of these entities share responsibility for ensuring 
          that each and every service is provided.

          Rules of co-op corporations and condo associations cannot diminish 
          the rights of stabilized tenants to continue to receive required 
          base date services or other protection under the rent laws.


          Rent reduction orders may be imposed where a co-op/condo board has 
          eliminated services in whole or in part.  However, upon 
          application, the DHCR may approve a modification or decrease of 
          services; the latter may be linked to a permanent proportionate 
          decrease in rent.

          GOVO is correct to the extent that the Supreme Court ruled that, as 
          GOVO was not a party to any of the proceedings before the DHCR that 
          culminated in the June 12, 1992 order, GOVO was not bound by it, 
          except insofar as the responsibility for the common areas and 
          potential liability as between GOVO and GOV, or any other holder of 
          unsold shares, is presumably governed by agreements between them.

          However, GOVO's further argument, that GOVO was not afforded the 
          opportunity to present a case in the proceedings resulting in the 
          orders under review herein, is without merit.  Copies of the 
          tenants' complaint naming GOV and GOVO as owners, care of the 
          managing agent, Grenadier Realty Co., were served on GOVO.  Rather 
          than taking the opportunity to raise objections and to present its 
          case, GOVO's response, detailed above, set forth that GOVO would 
          not appear in the proceeding and was not a proper party thereto as 
          it was not an "owner," and that the purpose of its letter was only 
          to advise the agency of the alleged jurisdictional defect.

          Thereafter, the complaints were processed in accordance with the 
          Division's procedures, and based upon pertinent evidence, including 
          the findings culminating in the June 12, 1992 determination, and 
          then current facts, including further inspections, the Rent 
          Administrator issued the orders under review herein.

          Accordingly, there is no merit to GOVO's assertion that it was not 
          afforded the opportunity to present its case, and its claims of 
          lack of due process must therefore be rejected.  Furthermore, the 
          scope of review of an administrative appeal is limited to a review 
          of the facts or evidence before the Rent Administrator as raised in 
          the petition.  Insofar as GOVO attempts to raise new facts or 
          evidence that were not before the Rent Administrator, such matters 
          must likewise be rejected.

          GOVO's assertion that it is not an owner is rejected by reason of 
          the provisions of the Code and GBL noted above.  They affirm that 
          control of the cooperative is placed in the hands of the member 
          shareholders of the co-op corporation, and that it acts through the 
          Board of Directors (Board), the entity charged with maintaining the 
          base date services which are the subject of these proceedings.

          The Commissioner previously rejected the arguments that the five 
          (5) new larger playgrounds provide an adequate substitute for the 
          37 smaller playgrounds previously provided on the base date, and 
          that the GOV tenants had not submitted proof or established that 
          the leases provided storage space as a service.  The determination 
          was based upon evidence, including the leases and tenants' 


          testimony that all the leases provided for storage of luggage and 
          baby carriages, and that the storage spaces were utilized for the 
          storage of personal items not limited to carriages and luggage for 
          many years with the knowledge of the prior owner, without 
          objection.  These services had been provided on a complex wide 
          basis on the base date and as such were required to be provided 
          thereafter to all stabilized tenants.

          The Court affirmed the Commissioner's June 12, 1992 determination 
          that storage space was a service provided to all tenants, which had 
          been eliminated, and that the five larger playgrounds were 
          inadequate substituted services when compared to the thirty-seven 
          smaller ones previously provided, and removed by the owner.
          The Commissioner now points to the fact that the circumstances have 
          not changed from those which culminated in the June 12, 1992 order 
          and that the Court dismissed the same arguments presented by the 
          owner in those proceedings.  It is also noted that no evidence was 
          submitted below by any owner that any tenant had failed to avail 
          himself or herself of the right to storage space.

          In regard to the argument that an individual owner of unsold shares 
          does not control the Board of the co-op corporation (GOVO) that 
          decided to redo the playgrounds and eliminate the storage space, it 
          is noted that pursuant to the Code and GBL, owners of unsold shares 
          are considered owners since they collect rent and are obligated to 
          secure compliance by the appropriate party, with the directive to 
          restore services.  Moreover, owners of unsold shares were aware, or 
          should have been aware, upon acquiring an interest, that such 
          owners could not directly control the Board, but would be 
          accountable for the action taken by or on behalf of the co-op 

          corporation.  Nor can such claims deprive the tenants of their 
          rights under the Rent Stabilization Law and Code.

          As to GOV, the Division's finding in the underlying proceedings 
          under EA110008RK, affirmed upon administrative and judicial review, 
          is given collateral estoppel effect in the cases under review 
          herein as to GOV's petitions under various docket numbers (per 
          Exhibit B).

          Assertions below and on appeal that other services have been 
          provided which were not previously provided to the tenants prior to 
          the cooperative are not relevant to the issue in these proceedings 
          regarding the storage space and playgrounds previously provided.

          Concerning GOVO's claim in its amended petitions, indicating that 
          GOVO filed two separate applications on September 21, 1992 
          requesting the Rent Administrator's permission to substitute new 
          services for the playground and storage space services deemed to 
          have been reduced, the Commissioner notes that since scope of 
          review is limited to a review of the facts and evidence before the 


          Administrator such claims may not be considered for the first time 
          on appeal.  The Commissioner further notes that Section 2522.4(e) 
          of the Code permits an owner to substitute an equivalent service 
          upon application by the owner, and that no such modification or 
          substitute shall take place prior to the approval of the owner's 
          application.  The fact that the applications were filed subsequent 
          to the Rent Administrator's findings of decreased services fails to 
          raise any issue regarding the correctness of the orders being 

          Concerning the claim of the owner of unsold shares in the 
          proceedings under HD130193RO, appealing the order under FL130125B, 
          that the tenant signed a General Release dated January 21, 1992 
          precluding the tenant from any relief based upon the Rent 
          Administrator's order, the Commissioner notes that Section 2520.13 
          of the Code provides that "An agreement by the tenant to waive the 
          benefit to any provision of the RSL or the Code is void provided 
          however that .... the tenant may withdraw any complaint pending 
          before the DHCR".  Also, there is no record that the tenant did 
          withdraw in the proceeding, or that the Rent Administrator had 
          notice of this agreement.  Insofar as the owner attempts to raise 
          new facts or evidence that were not before the Rent Administrator, 
          the claim is beyond the scope of review.  

          GOV and GOVO as well as several individual owners of unsold shares, 
          requested the Commissioner to vacate the orders below as premature, 
          in light of their anticipation that the June 12, 1992 order under 
          review would be set aside and the proceeding remitted to the agency 
          for further consideration.  In fact, the Court affirmed the 
          Commissioner's determination.  GOVO's request to amend its petition 
          for administrative review has been granted herein.  There is no 
          indication that GOV and the various individual owners of unsold 
          shares sought to amend their administrative appeals (per attached 
          Exhibit B and C).  The requests to vacate the orders below on the 
          ground that there was an Article 78 petition seeking revocation or 
          modification of the June 12, 1992 order, failed to raise any issue 
          regarding the correctness of the order being appealed.  Moreover, 
          they have been rendered moot by the Court's judgment.  The 
          Commissioner finds, insofar as this argument is raised, it is 
          without merit, and therefore, the GOV petitions (per Exhibit B) 
          should be dismissed, and that the petitions of the owners of unsold 
          shares (per Exhibit C) should be denied. 

          The automatic stay of the retroactive rent abatements that resulted 
          by the filing of these petitions are vacated upon issuance of this 
          order and opinion.

          THEREFORE, pursuant to the Rent Stabilization Law and Code and 
          Operational Bulletin 84-1, it is

          ORDERED, that the GOVO petitions, under the docket numbers set 
          forth in Exhibit A and the petitions of the individual owners of 


          unsold shares under docket numbers set forth in Exhibit C, be and 
          the same hereby are, denied.  It is further

          ORDERED, that the GOV petitions under docket numbers set forth in 
          Exhibit B, be and the same hereby are, dismissed for mootness and 
          for failure to state a cause of action.  It is further

          ORDERED, that the Rent Administrator's orders be and the same 
          hereby are affirmed.


                                             JOSEPH A. D'AGOSTA
                                             Deputy Commissioner  

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