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FILED: NEW YORK COUNTY CLERK 07/20/2018 01:44 PM INDEX NO. 154772/2017
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 07/20/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK Index No. 154772/2017
-----------------------------------------------------------------------X
MICHAEL CESTARO, CHRIS BECKER, KATHERINE Hon. Gerald Lebovits
ESPOSITO, EMERSON WOLFE, JORDAN KLING,
AMANDA PEACOCK, REMY AGEMY, KRISTOPHER
TAIT, JOSHUA McTEE, TALEAH MONA-LUSKY,
ELAINE PURCELL, JOEL POULTER, and NATHAN PLAINTIFFS’ DEMAND FOR
SHUPENKO, AUTHORIZATIONS FROM
THE DEPARTMENT OF
HOUSING AND
Plaintiffs,
COMMUNITY RENEWAL
-against- (DHCR)
CARMINE TIERRA, LLC,
Defendant.
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S IR or MADAM:
PLEASE TAKE NOTICE, that pursuant to CPLR §3101(e), the defendant or the
defendant’s attorneys are required to serve upon plaintiffs’ counsel within twenty (20) days after
receipt of this notice the following written authorizations in substantially the form annexed
together with proof of ownership of the building known as and located at 59-61 Carmine Street,
New York, NY (the “building”), sufficient to allow the plaintiffs to obtain the following
documents from the New York State Department of Housing and Community Renewal
(“DHCR”):
Building-wide Rent Roll, 1983-date
Initial Building-wide Services Registration
Individual Apartment(s) Rent History from 1983-2018 for Apt. #s.: 2D, 2F, 3A, 3B, 3C, 4E, 5C,
5D, 5F, 6B, 6E, and 6F
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FILED: NEW YORK COUNTY CLERK 07/20/2018 01:44 PM INDEX NO. 154772/2017
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 07/20/2018
All Apartment Rent Registrations from 2003-20108 for Apt. #s: 2D, 2F, 3A, 3B, 3C, 4E, 5C, 5D,
5F, 6B, 6E, and 6F, including all initial registrations, RR-1 notices, and exist registrations; and
All DHCR docket numbers for any cases with respect to the building and authorization to obtain
the complete DHCR docket for each docket number.
Dated: July 19, 2018
New York, NY
/S/___________________
John T. Maher, Esq.
Attorney for Plaintiffs
105 E. 122nd St.
New York, NY 10035
646-675-8909
Email: johntmaher@yahoo.com
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FILED: NEW YORK COUNTY CLERK 07/20/2018 01:44 PM INDEX NO. 154772/2017
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 07/20/2018
Consent Authorization for Release of Information from the New York Department of
Housing Community and Renewal (DHCR)
To:
DHCR Records Access Officer
Gertz Plaza
92-31 Union Hall Street
Jamaica, New York 11433
Re: Cestaro v. Carmine Tierra, LLC, New York Supreme Court, Index No. 54772/2017
I, a duly authorized representative of the OWNER of the building located at 59-61 Carmine
Street, New York, NY (the “building”) hereby authorize and direct NYS DHCR to release and to
and verify information as requested in the attached Authorization to LAW OFFICE OF JOHN T.
MAHER and John T. Maher, Esq. and/or Diana Jarvis, Esq.,
All information listed in the DHCR REC-1 form under Section 7, including:
Building-wide Rent Roll, 1983-date
Initial Building-wide Services Registration
Individual Apartment(s) Rent History from 1983-2018 for Apt. #s.: 2D, 2F, 3A, 3B, 3C, 4E, 5C,
5D, 5F, 6B, 6E, and 6F
Initial Apartment Rent Registrations from 2003-20108 for Apt. #s: 2D, 2F, 3A, 3B, 3C, 4E, 5C,
5D, 5F, 6B, 6E, and 6F
All DHCR docket numbers for each case with respect to the building and authorization to obtain
the complete DHCR docket for each docket number.
I further authorize the DHCR Records Access Officer to communicate freely with
representatives of LAW OFFICE OF JOHN T. MAHER and John T. Maher, Esq. and/or Diana
Jarvis, Esq. regarding the fulfillment of this request.
I agree that a photocopy of this authorization may be used for the purposes stated above. The
original of this authorization will stay in my file and will remain in effect for 36 months from the
date signed or until the conclusion of the above referenced lawsuit.
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FILED: NEW YORK COUNTY CLERK 07/20/2018 01:44 PM INDEX NO. 154772/2017
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 07/20/2018
I attach proof of ownership in the form of a copy of deed or tax bill:
___________________________________________________________________________
and I understand that Rent Roll information can only be provided to the building owner;
authorized representative of owner or authorized representative of all tenants in the subject
building or anyone operating with the express consent of the foregoing.
SIGNATURES:
NAME:
OFFICIAL CAPACITY:
NAME OF OWNER:
DATE:
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Preview
FILED: NEW YORK COUNTY CLERK 07/20/2018 01:44 PM INDEX NO. 154772/2017 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 07/20/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Index No. 154772/2017 -----------------------------------------------------------------------X MICHAEL CESTARO, CHRIS BECKER, KATHERINE Hon. Gerald Lebovits ESPOSITO, EMERSON WOLFE, JORDAN KLING, AMANDA PEACOCK, REMY AGEMY, KRISTOPHER TAIT, JOSHUA McTEE, TALEAH MONA-LUSKY, ELAINE PURCELL, JOEL POULTER, and NATHAN PLAINTIFFS’ DEMAND FOR SHUPENKO, AUTHORIZATIONS FROM THE DEPARTMENT OF HOUSING AND Plaintiffs, COMMUNITY RENEWAL -against- (DHCR) CARMINE TIERRA, LLC, Defendant. ----------------------------------------------------------------------X S IR or MADAM: PLEASE TAKE NOTICE, that pursuant to CPLR §3101(e), the defendant or the defendant’s attorneys are required to serve upon plaintiffs’ counsel within twenty (20) days after receipt of this notice the following written authorizations in substantially the form annexed together with proof of ownership of the building known as and located at 59-61 Carmine Street, New York, NY (the “building”), sufficient to allow the plaintiffs to obtain the following documents from the New York State Department of Housing and Community Renewal (“DHCR”): Building-wide Rent Roll, 1983-date Initial Building-wide Services Registration Individual Apartment(s) Rent History from 1983-2018 for Apt. #s.: 2D, 2F, 3A, 3B, 3C, 4E, 5C, 5D, 5F, 6B, 6E, and 6F 1 1 of 4 FILED: NEW YORK COUNTY CLERK 07/20/2018 01:44 PM INDEX NO. 154772/2017 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 07/20/2018 All Apartment Rent Registrations from 2003-20108 for Apt. #s: 2D, 2F, 3A, 3B, 3C, 4E, 5C, 5D, 5F, 6B, 6E, and 6F, including all initial registrations, RR-1 notices, and exist registrations; and All DHCR docket numbers for any cases with respect to the building and authorization to obtain the complete DHCR docket for each docket number. Dated: July 19, 2018 New York, NY /S/___________________ John T. Maher, Esq. Attorney for Plaintiffs 105 E. 122nd St. New York, NY 10035 646-675-8909 Email: johntmaher@yahoo.com 2 2 of 4 FILED: NEW YORK COUNTY CLERK 07/20/2018 01:44 PM INDEX NO. 154772/2017 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 07/20/2018 Consent Authorization for Release of Information from the New York Department of Housing Community and Renewal (DHCR) To: DHCR Records Access Officer Gertz Plaza 92-31 Union Hall Street Jamaica, New York 11433 Re: Cestaro v. Carmine Tierra, LLC, New York Supreme Court, Index No. 54772/2017 I, a duly authorized representative of the OWNER of the building located at 59-61 Carmine Street, New York, NY (the “building”) hereby authorize and direct NYS DHCR to release and to and verify information as requested in the attached Authorization to LAW OFFICE OF JOHN T. MAHER and John T. Maher, Esq. and/or Diana Jarvis, Esq., All information listed in the DHCR REC-1 form under Section 7, including: Building-wide Rent Roll, 1983-date Initial Building-wide Services Registration Individual Apartment(s) Rent History from 1983-2018 for Apt. #s.: 2D, 2F, 3A, 3B, 3C, 4E, 5C, 5D, 5F, 6B, 6E, and 6F Initial Apartment Rent Registrations from 2003-20108 for Apt. #s: 2D, 2F, 3A, 3B, 3C, 4E, 5C, 5D, 5F, 6B, 6E, and 6F All DHCR docket numbers for each case with respect to the building and authorization to obtain the complete DHCR docket for each docket number. I further authorize the DHCR Records Access Officer to communicate freely with representatives of LAW OFFICE OF JOHN T. MAHER and John T. Maher, Esq. and/or Diana Jarvis, Esq. regarding the fulfillment of this request. I agree that a photocopy of this authorization may be used for the purposes stated above. The original of this authorization will stay in my file and will remain in effect for 36 months from the date signed or until the conclusion of the above referenced lawsuit. 3 of 4 FILED: NEW YORK COUNTY CLERK 07/20/2018 01:44 PM INDEX NO. 154772/2017 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 07/20/2018 I attach proof of ownership in the form of a copy of deed or tax bill: ___________________________________________________________________________ and I understand that Rent Roll information can only be provided to the building owner; authorized representative of owner or authorized representative of all tenants in the subject building or anyone operating with the express consent of the foregoing. SIGNATURES: NAME: OFFICIAL CAPACITY: NAME OF OWNER: DATE: 4 of 4