Francesca Carelli v. East 88th Street Associates, Llc

This is an action for damages arising out of Defendant’s negligence and intentional

violation of the contracts and laws governing New York City housing, including, but not limited

to, New York Real Property Law § 235-B, the New York City Administrative Code, and the

common laws of contracts, habitability, and negligence.

This Court has jurisdiction over this proceeding and the parties pursuant to New

York Civil Practice Law and Rules (“CPLR) §§ 301 and 302 because Defendant has transacted

business in the State of New York, including operating an apartment building in the State of New

York. Further, the causes of action set forth herein arise out of, and relate to, certain events,

omissions, and transactions that occurred within the State of New York.

Causes of Action

1. Breach of Contract

2. Breach of Implied Warranty of Habitability

3. Breach of Implied Harassment by Disruption of Essential Services and Repeated Failure to Correct Hazardous Violations