Sally Mae Ginsburg is a single mother living in a rent-stabilized apartment on the Upper West Side in Manhattan, New York. Sally Mae has been living in this 2 bedroom, 1 12 bathroom apartment for 25 years. Sally Mae's apartment is rent-stabilized. Sally Mae is 53 years old.

Last month, Sally Mae complained to her landlord on 3 separate occasions that the stove in her kitchen was no longer working. Sally Mae also complained to her landlord that her upstairs neighbor makes loud noises in the afternoon when she walks around in her apartment. Sally Mae informed her landlord that this loud noise disturbs Sally Mae's afternoon naps.

Sally Mae's landlord, Johnny Good Jacobs, had previously agreed to purchase and replace Sally Mae's stove at no cost to her. Landlord Jacobs had also agreed to speak with the upstairs tenant and ask if she could put down the carpet to prevent the loud noise caused by her walking around.

Before Landlord Jacobs could perform these two things requested by Sally Maw, on June 11, 2019, the State of New York approved the Housing Stability and Tenant Protections Act of 2019. The next day after the passage of this law, Landlord Jacobs informed Sally Mae, in writing, that he would no longer purchase and/or replace Sally Mae's stove. Landlord Jacobs also informed Sally Mae that he would not help with the "quiet use and enjoyment" of her apartment as it pertains to the upstairs tenant making noises in the afternoon. Landlord Jacobs, also indicated that he would increase Sally Mae's rent by 7% the following month.

Sally Mae was very upset when she received Landlord Jacob's letter. Sally Mae quickly retained your services to sue Landlord Jacobs for the following:

(a)Purchase and replacement of her stove;

(b)Against the quiet use and enjoyment of her apartment; and

(c)Monthly rental increase of 7%.

Your response is to specifically go through each and every cause of action stated above and indicate what Sally Mae will prevail/win on against Landlord Jacobs. You are the Lawyer representing Sally Mae only.