Case of first impression in the Appellate Division Second Department. The court applied the six year statute of limitations to a claim by a non-record owner, who was not in possession of realty, to vacate a recorded deed that allegedly was forged. This holding is distinguished from cases in the Appellate Division, the First Department, which applies the ten year statute of limitations applicable to quiet title claims.
Download PDF JP Morgan Chase v. Bette Kalpakis