The Appellate Division affirmed the denial of the petition brought to expunge the May 6, 2019 disciplinary letter from petitioner's personnel file. As the four-month statute of limitations began to run when the letter was placed in petitioner's file, and this proceeding was not commenced until January 13, 2021, the court should not have considered the letter.
Matter of Connors v. City of New York, NY Slip Op 03209 (1st Dep't May 17, 2022)