To the extent some courts have held that the City may assert a waived statute-of-limitations defense later in litigation where there is no evidence of surprise or prejudice, those cases were not small claims actions where "delays are antithetical to small-claims litigation's basic purpose," and thus distinguishable. Small Claims Manual, at 144; contra., e.g., Hayes v. City of New York, 2020 NY Slip Op 30672(U), *5-6 (Sup. Ct., New York Co. 2020). As the First Department has noted, "[t]he corporation counsel's office, too, has an obligation to conduct lawsuits in a disciplined and efficient manner," which includes litigation consistent with the policy goals in creating the small claims process.