Case No. 102 LIQUIDATED DAMAGES/UNCONSCIONABILITY Spring Valley Garden Associates v.Earle County Court, Rockland County 112 Misc.2d 786, 447 N.Y.S.2d 629 (1982) FACTS: Plaintiff Spring Valley Garden Associates (Spring Valley) is the owner of property that is leased to tenants for residential purposes. Defendant Felm was a tenant in an apartment owned by Spring Valley in Earle (Earle) In November 198 1, Earle paid her rent with a check that bounced. By the time Spring Valley deposited the check and learned that it would not clear, more than ten days from the rent due date had passed. A provision in the
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