Preview
FILED: KINGS COUNTY CLERK 12/03/2020 03:52 PM INDEX NO. 519697/2018
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 12/03/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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JAHARY CANTO,
VERIFIED BILL OF
PARTICULARS
Plaintiff,
-against- Index No.: 519697/2018
CINE MAGIC EAST RIVER STUDIOS, LLC and JAVA
LANDING, LLC AND THE CITY OF NEW YORK,
Defendants.
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Plaintiff, by his attorneys, GOLDSTEIN & HANDWERKER, LLP, responding to the
demand of Defendant, CINE MAGIC EAST RIVER STUDIOS, for a Verified Bill of
Particulars, alleges, upon information and belief:
135*
1. Plaintiff, JAHARY CANTO resides at 510 West Street, Apartment #6, New
York, New York 10031. He was born on 5/6/xx, and bears social security number: xxx-xx-3720.
2. The occurrence complained of, took place on 10/10/l 7 at or about 5:40 A.M.
3. The occurrence complained of, took place on roadway and/or sidewalk existed in
front of at/or near 33 Ken Cine Magic East River Studios, located at 33 Kent Avenue, in the
County of Kings, City and State of New York.
4. (a) Defendant, itsagents, servants, and/or employees were negligent, careless, and
reckless, in the ownership, operation, control and maintenance of said sidewalk and/or roadway,
in causing, permitting and allowing the said sidewalk and/or roadway to become and remain in a
defective, dangerous condition constituting a, trap,nuisance and hazard and in failing to repair,
backfill or pave said condition; in causing, permitting and allowing the said sidewalk and/or
roadway to become and remain in a broken, loose, defective, dangerous, obstructed, cracked,
uneven, raised, depressed, missing and/or deteriorated condition; in negligently and improperly
repairing said sidewalk and/or roadway in a negligent, careless and improper manner; in failing
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and neglecting to employ the proper and required materials and techniques for the said sidewalk
and/or roadway; in failing and neglecting to follow the statutes, ordinances, standards, rules and
regulations conforming to the standard; in causing, creating and allowing a dangerous, hazardous
and trap-like condition to exist; in causing, creating and allowing a nuisance to exist; in failing
and neglecting to warn or apprise the public and all lawful users thereof, particularly the Plaintiff
herein, of the dangerous and defective conditions then and there existing in and upon the said
sidewalk and/or roadway; in failing and neglecting to barricade or section off the defective area
and condition; in causing, permitting and allowing the said sidewalk and/or roadway to be,
become and remain in an unfinished condition which was not leveled or uniform and posed a
serious danger to all lawful users thereof; in failing and neglecting to prevent the dangerous,
defective, and unsafe condition of the aforesaid sidewalk and/or roadway; in failing and
neglecting to post signs or signals, or in any way wam the public, and in particular the injured
plaintiff herein, of the dangerous and defective condition of the said sidewalk and/or roadway; in
failing and neglecting to reroute lawful users of said premises to a safe area. Defendant violated
the applicable rules, laws, regulations, and statutes in such cases made and provided and of
which the Court will take judicial notice at the trial hereof.
(b) i-iv.Breach of warranty: Not applicable.
5.-6. Defendant had both actual and constructive notice of the condition herein. Actual
notice is claimed in that the Defendant(s), itsofficers, agents, servants and/or employees caused,
created and contributed to said condition in that itactively owned, managed created, maintained
and controlled the aforesaid roadway and/or sidewalk existed in front of at/or near 33 Ken Cine
Magic East River Studios, located at 33 Kent Avenue, in the County of Kings, City and State of
New York. Defendant(s) is directed to the law in question wherein a party who causes, creates or
maintains a condition is deemed to have actual notice thereof.
Constructive notice is claimed in that the condition existed for a substantial period of time, prior
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to the accident herein, such that the condition should have been seen and noticed upon
reasonable inspection and then the defective condition should have been remedied and repaired.
7. Defendant violated all applicable sections of the New York State Vehicle and Traffic
Law and the New York City Traffic Rules and Regulations concerning the safe and proper
operation of a motor vehicle upon the public ways and streets of the State ofNew York including
but not limited to Vehicle and Traffic Law Sections 375, 1101, 1102, 1105, 1110, 1111, 1113,
1115, 1120, 1121, 1122, l 123,l 124,l 125,l 126,1127, 1128, 1130, 1140, 1142, 1143, l144, 1145,
1146, 1160, l 161, 1162, 1163, 1164, l166, 1170, 1171, 1172, 1173, 1174, 1175, 1176, 1180,
1180-a, 1181, 1182, 1192, 1192-a, 1200, 1201, 1202, 1203, 1203-b, 1210, 1211, 1212, 1213,
1214, 1215, 1216, 1217, 1218, 1219, 1220, 1221, 1222, 1223, 1225, 1225-a, 1226, 1227, 1228,
1229, 1229-b, 1229-c, 1250, 1251, 1252, and 1252 of the Vehicle and Traffic Law of the State of
New York and Sections 4- 4-09 and 4-12 of the Traffic
4-03, 04, 4-05, 4-06, 4-07, 4-08,
Regulations of the City of New York, along with all other applicable Statutes, Ordinances, Rules
and Regulations that the Court will take Judicial Notice of at the time of trial.
8. Prior accident: Not applicable.
9. Subsequent repair or other remedial action: To be provided, if applicable.
10. As a result of the occurrence, the Plaintiff, JAHARY CANTO, sustained the
following personal injuries, allof which are alleged to be of a permanent nature:
Left Ankle/Foot:
- Avulsion closed fractures;
-
Sprain;
- Joint effusion;
-
Edema;
- Sprain and strain;
- and altered gait.
Limping
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All of the aforementioned injuries, resulting disabilities, aggravations, exacerbations
and involvements are associated with further soft tissue injuries to the areas traumatically
affected, including: fracture, tearing, derangement and damage to the associated muscle groups,
ligaments, tendons, cartilage, blood, tissue, epithelial tissue, all concomitant to the specific
injuries and related to the specific portions of the body mentioned hereinabove with resultant
scars, haemorrhage, pain, ecchymosis, deformity and disability; stiffness, tenderness, weakness,
partial restriction and limitation of motion, pain on motion and loss of use of the abovementioned
parts; atrophy, anxiety and mental anguish; all of which have substantially prevented the Plaintiff
from enjoying the normal fruits of social activities.
The Plaintiff reserves his rights to prove any and all further consequences and any and
all further medical expenses up to and at the time of trial.
All of the injuries and conditions caused and/ or contributed to the Plaintiff living a
lesser quality of life, including loss of enjoyment of life than the Plaintiff would otherwise have
experienced, but for the injuries and conditions alleged herein.
The Plaintiff suffered, still suffer, and upon information and belief will continue to
suffer pain, discomfort and limited movement of the injured portions of his body, including the
adjacent and surrounding muscles, tendons, nerves, joints, fascia, vessels and soft tissues pain,
discomfort and limited movement of the injured portions of his body, including the adjacent and
surrounding muscles, tendons, nerves, joints, fascia, vessels and soft tissues.
In the event plaintiff had a prior injury or had naturally occurring degenerative changes
to the affected body parts, such prior injuries and/ or naturally occurring degenerative changes
were pain free and asymptomatic at the time of the accident and were reinjured, aggravated and/
or exacerbated by this accident.
Upon information and belief, all of the above injuries are permanent and continuing in
nature, except for objective signs of contusions and abrasions.
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11. (a)-(b) 5104(a): Not applicable.
12. Plaintiff JAHARY CANTO was confined to New York Presbyterian Hospital, 622
1680'
West Street, New York, New York 10032 from 11/6/17 to 11/7/17.
13. The plaintiff was treated by the following health care provider:
- 1680¹
New York Presbyterian Hospital, 622 West Street, New York, New York
10032.
14. Plaintiff was employed as a Parking Assistant by Entertainment Partners, 5
Pennsylvania Plaza, New York, New York 10001.
Plaintiff was incapacitated from employment since the date of the accident intermittently
thereafter following the accident.
15. (a) See response #12.
(b)Plaintiff, JAHARY CANTO, was confined to bed for approximately 28 days
following the accident.
(c) Plaintiff, JAHARY CANTO, was confined to house for approximately 28 days
following the accident.
16. Plaintiff sustained special damages as follows:
Physicians'
(a) services: $25,000.00;
Physicians'
(b)Medical supplies: See Hospital and services;
(c)Loss of earnings: To be provided, If applicable
Name(s) and address(es) of employer: See response #14;
(d)Future loss of earnings: To be provided, if applicable;
(e)Hospital expenses: $7,500.00;
Nurses'
(f) services: See Hospital and Physician services;
(g)Any other special damage: To be provided, if applicable.
17. Loss of services: Not applicable.
18. Plaintiff, JAHARY CANTO's medical expenses were partially and/or fully paid by
Empire BlueCross BlueShield, P.O. Box 1407, Church Street Station, New York, New York
5 of 8
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10008-1407 ID: JLJ714070738.
19. - 26. Medicare benefits: Not applicable.
27. Any additional insurance: To be provided, if applicable.
28. Plaintiff is not known by any other names.
Dated: New York, New York
December 3, 2020
Y urs, etc.
GOLDSTEIN
GOLDSTEIN & HANDWERKER, LLP
Attomeys for Plaintiff
JAHARY CANTO
280 Madison Avenue, Suite 1202
New York, New York 10016
(212) 679-1330
TO:
EUSTACE, MARQUEZ, EPSTEIN, PREZIOSO & YAPCHANYK
Attorneys for Defendant
CINE MAGIC EAST RIVER STUDIOS, LLC
28d'
55 Water Street, Floor
New York, New York 10041
(212) 612-4200
JAMES E. JOHNSON
Corporation Counsel
Attorney for Defendant
THE CITY OF NEW YORK
100 Church Street
New York, New York 10007
(718) 724-5200
LAW OFFICES OF GREGORY B. COBURN
Attomey for Defendant
JAVA LANDING, LLC
15d'
160 Water Street, Floor
New York, New York 10038
(212) 422-7533
File No.: 249427
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ATTORNEY'S VERIFICATION
STEVEN GOLDSTEIN, ESQ. an attorney duly admitted to practice before the Courts of
the State of New York, affirms the following to be true under the penalties of perjury:
I am an attorney at GOLDSTEIN & HANDWERKER, LLP, attorneys of record for
Plaintiff, JAHARY CANTO, in the action within. I have read the annexed BILL OF
PARTICULARS and know the contents thereof, and the same are true to my knowledge, except
those matters therein which are stated to be alleged upon information and belief, and as to those
matters I believe them to be true. My belief, as to those matters therein not stated upon
knowledge, is based upon facts, records, and other pertinent information contained in my files.
This verification is made by me because Plaintiff is not presently in the County wherein I
maintain my offices.
Dated: New York, New York
December 3, 2020
S OLDSTEIN, ESQ.
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Index No.: 519697/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
JAHARY CANTO,
Plaintiff,
-against-
CINE MAGIC EAST RIVER STUDIOS, LLC and JAVA
LANDING, LLC AND THE CITY OF NEW YORK,
Defendants.
VERIFIED BILL OF PARTICULARS
GOLDSTEIN &HANDWERKER, LLP
Attorneys for Plaintiff
280 Madison Avenue, Suite 1202
New York, New York 10016
(212) 679-1330
TO: EUSTACE, MARQUEZ, EPSTEIN, PREZIOSO & YAPCHANYK
Attorneys for Defendant
CINE MAGIC EAST RIVER STUDIOS, LLC
28th
55 Water Street, FlOOr
New York, New York 10041
(212) 612-4200
ZACHARY W. CARTER
Corporation Counsel
Attomey for Defendant
THE CITY OF NEW YORK
100 Church Street
New York, New York 10007
(718) 724-5200
LAW OFFICES OF GREGORY B. COBURN
Attorney for Defendant
JAVA LANDING, LLC
15th
160 Water Street, FlOOr
New York, New York 10038
(212) 422-7533
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Preview
FILED: KINGS COUNTY CLERK 12/03/2020 03:52 PM INDEX NO. 519697/2018 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 12/03/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------X JAHARY CANTO, VERIFIED BILL OF PARTICULARS Plaintiff, -against- Index No.: 519697/2018 CINE MAGIC EAST RIVER STUDIOS, LLC and JAVA LANDING, LLC AND THE CITY OF NEW YORK, Defendants. -------------------------------------------------------------------X Plaintiff, by his attorneys, GOLDSTEIN & HANDWERKER, LLP, responding to the demand of Defendant, CINE MAGIC EAST RIVER STUDIOS, for a Verified Bill of Particulars, alleges, upon information and belief: 135* 1. Plaintiff, JAHARY CANTO resides at 510 West Street, Apartment #6, New York, New York 10031. He was born on 5/6/xx, and bears social security number: xxx-xx-3720. 2. The occurrence complained of, took place on 10/10/l 7 at or about 5:40 A.M. 3. The occurrence complained of, took place on roadway and/or sidewalk existed in front of at/or near 33 Ken Cine Magic East River Studios, located at 33 Kent Avenue, in the County of Kings, City and State of New York. 4. (a) Defendant, itsagents, servants, and/or employees were negligent, careless, and reckless, in the ownership, operation, control and maintenance of said sidewalk and/or roadway, in causing, permitting and allowing the said sidewalk and/or roadway to become and remain in a defective, dangerous condition constituting a, trap,nuisance and hazard and in failing to repair, backfill or pave said condition; in causing, permitting and allowing the said sidewalk and/or roadway to become and remain in a broken, loose, defective, dangerous, obstructed, cracked, uneven, raised, depressed, missing and/or deteriorated condition; in negligently and improperly repairing said sidewalk and/or roadway in a negligent, careless and improper manner; in failing 1 of 8 FILED: KINGS COUNTY CLERK 12/03/2020 03:52 PM INDEX NO. 519697/2018 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 12/03/2020 and neglecting to employ the proper and required materials and techniques for the said sidewalk and/or roadway; in failing and neglecting to follow the statutes, ordinances, standards, rules and regulations conforming to the standard; in causing, creating and allowing a dangerous, hazardous and trap-like condition to exist; in causing, creating and allowing a nuisance to exist; in failing and neglecting to warn or apprise the public and all lawful users thereof, particularly the Plaintiff herein, of the dangerous and defective conditions then and there existing in and upon the said sidewalk and/or roadway; in failing and neglecting to barricade or section off the defective area and condition; in causing, permitting and allowing the said sidewalk and/or roadway to be, become and remain in an unfinished condition which was not leveled or uniform and posed a serious danger to all lawful users thereof; in failing and neglecting to prevent the dangerous, defective, and unsafe condition of the aforesaid sidewalk and/or roadway; in failing and neglecting to post signs or signals, or in any way wam the public, and in particular the injured plaintiff herein, of the dangerous and defective condition of the said sidewalk and/or roadway; in failing and neglecting to reroute lawful users of said premises to a safe area. Defendant violated the applicable rules, laws, regulations, and statutes in such cases made and provided and of which the Court will take judicial notice at the trial hereof. (b) i-iv.Breach of warranty: Not applicable. 5.-6. Defendant had both actual and constructive notice of the condition herein. Actual notice is claimed in that the Defendant(s), itsofficers, agents, servants and/or employees caused, created and contributed to said condition in that itactively owned, managed created, maintained and controlled the aforesaid roadway and/or sidewalk existed in front of at/or near 33 Ken Cine Magic East River Studios, located at 33 Kent Avenue, in the County of Kings, City and State of New York. Defendant(s) is directed to the law in question wherein a party who causes, creates or maintains a condition is deemed to have actual notice thereof. Constructive notice is claimed in that the condition existed for a substantial period of time, prior 2 of 8 FILED: KINGS COUNTY CLERK 12/03/2020 03:52 PM INDEX NO. 519697/2018 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 12/03/2020 to the accident herein, such that the condition should have been seen and noticed upon reasonable inspection and then the defective condition should have been remedied and repaired. 7. Defendant violated all applicable sections of the New York State Vehicle and Traffic Law and the New York City Traffic Rules and Regulations concerning the safe and proper operation of a motor vehicle upon the public ways and streets of the State ofNew York including but not limited to Vehicle and Traffic Law Sections 375, 1101, 1102, 1105, 1110, 1111, 1113, 1115, 1120, 1121, 1122, l 123,l 124,l 125,l 126,1127, 1128, 1130, 1140, 1142, 1143, l144, 1145, 1146, 1160, l 161, 1162, 1163, 1164, l166, 1170, 1171, 1172, 1173, 1174, 1175, 1176, 1180, 1180-a, 1181, 1182, 1192, 1192-a, 1200, 1201, 1202, 1203, 1203-b, 1210, 1211, 1212, 1213, 1214, 1215, 1216, 1217, 1218, 1219, 1220, 1221, 1222, 1223, 1225, 1225-a, 1226, 1227, 1228, 1229, 1229-b, 1229-c, 1250, 1251, 1252, and 1252 of the Vehicle and Traffic Law of the State of New York and Sections 4- 4-09 and 4-12 of the Traffic 4-03, 04, 4-05, 4-06, 4-07, 4-08, Regulations of the City of New York, along with all other applicable Statutes, Ordinances, Rules and Regulations that the Court will take Judicial Notice of at the time of trial. 8. Prior accident: Not applicable. 9. Subsequent repair or other remedial action: To be provided, if applicable. 10. As a result of the occurrence, the Plaintiff, JAHARY CANTO, sustained the following personal injuries, allof which are alleged to be of a permanent nature: Left Ankle/Foot: - Avulsion closed fractures; - Sprain; - Joint effusion; - Edema; - Sprain and strain; - and altered gait. Limping 3 of 8 FILED: KINGS COUNTY CLERK 12/03/2020 03:52 PM INDEX NO. 519697/2018 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 12/03/2020 All of the aforementioned injuries, resulting disabilities, aggravations, exacerbations and involvements are associated with further soft tissue injuries to the areas traumatically affected, including: fracture, tearing, derangement and damage to the associated muscle groups, ligaments, tendons, cartilage, blood, tissue, epithelial tissue, all concomitant to the specific injuries and related to the specific portions of the body mentioned hereinabove with resultant scars, haemorrhage, pain, ecchymosis, deformity and disability; stiffness, tenderness, weakness, partial restriction and limitation of motion, pain on motion and loss of use of the abovementioned parts; atrophy, anxiety and mental anguish; all of which have substantially prevented the Plaintiff from enjoying the normal fruits of social activities. The Plaintiff reserves his rights to prove any and all further consequences and any and all further medical expenses up to and at the time of trial. All of the injuries and conditions caused and/ or contributed to the Plaintiff living a lesser quality of life, including loss of enjoyment of life than the Plaintiff would otherwise have experienced, but for the injuries and conditions alleged herein. The Plaintiff suffered, still suffer, and upon information and belief will continue to suffer pain, discomfort and limited movement of the injured portions of his body, including the adjacent and surrounding muscles, tendons, nerves, joints, fascia, vessels and soft tissues pain, discomfort and limited movement of the injured portions of his body, including the adjacent and surrounding muscles, tendons, nerves, joints, fascia, vessels and soft tissues. In the event plaintiff had a prior injury or had naturally occurring degenerative changes to the affected body parts, such prior injuries and/ or naturally occurring degenerative changes were pain free and asymptomatic at the time of the accident and were reinjured, aggravated and/ or exacerbated by this accident. Upon information and belief, all of the above injuries are permanent and continuing in nature, except for objective signs of contusions and abrasions. 4 of 8 FILED: KINGS COUNTY CLERK 12/03/2020 03:52 PM INDEX NO. 519697/2018 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 12/03/2020 11. (a)-(b) 5104(a): Not applicable. 12. Plaintiff JAHARY CANTO was confined to New York Presbyterian Hospital, 622 1680' West Street, New York, New York 10032 from 11/6/17 to 11/7/17. 13. The plaintiff was treated by the following health care provider: - 1680¹ New York Presbyterian Hospital, 622 West Street, New York, New York 10032. 14. Plaintiff was employed as a Parking Assistant by Entertainment Partners, 5 Pennsylvania Plaza, New York, New York 10001. Plaintiff was incapacitated from employment since the date of the accident intermittently thereafter following the accident. 15. (a) See response #12. (b)Plaintiff, JAHARY CANTO, was confined to bed for approximately 28 days following the accident. (c) Plaintiff, JAHARY CANTO, was confined to house for approximately 28 days following the accident. 16. Plaintiff sustained special damages as follows: Physicians' (a) services: $25,000.00; Physicians' (b)Medical supplies: See Hospital and services; (c)Loss of earnings: To be provided, If applicable Name(s) and address(es) of employer: See response #14; (d)Future loss of earnings: To be provided, if applicable; (e)Hospital expenses: $7,500.00; Nurses' (f) services: See Hospital and Physician services; (g)Any other special damage: To be provided, if applicable. 17. Loss of services: Not applicable. 18. Plaintiff, JAHARY CANTO's medical expenses were partially and/or fully paid by Empire BlueCross BlueShield, P.O. Box 1407, Church Street Station, New York, New York 5 of 8 FILED: KINGS COUNTY CLERK 12/03/2020 03:52 PM INDEX NO. 519697/2018 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 12/03/2020 10008-1407 ID: JLJ714070738. 19. - 26. Medicare benefits: Not applicable. 27. Any additional insurance: To be provided, if applicable. 28. Plaintiff is not known by any other names. Dated: New York, New York December 3, 2020 Y urs, etc. GOLDSTEIN GOLDSTEIN & HANDWERKER, LLP Attomeys for Plaintiff JAHARY CANTO 280 Madison Avenue, Suite 1202 New York, New York 10016 (212) 679-1330 TO: EUSTACE, MARQUEZ, EPSTEIN, PREZIOSO & YAPCHANYK Attorneys for Defendant CINE MAGIC EAST RIVER STUDIOS, LLC 28d' 55 Water Street, Floor New York, New York 10041 (212) 612-4200 JAMES E. JOHNSON Corporation Counsel Attorney for Defendant THE CITY OF NEW YORK 100 Church Street New York, New York 10007 (718) 724-5200 LAW OFFICES OF GREGORY B. COBURN Attomey for Defendant JAVA LANDING, LLC 15d' 160 Water Street, Floor New York, New York 10038 (212) 422-7533 File No.: 249427 6 of 8 FILED: KINGS COUNTY CLERK 12/03/2020 03:52 PM INDEX NO. 519697/2018 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 12/03/2020 ATTORNEY'S VERIFICATION STEVEN GOLDSTEIN, ESQ. an attorney duly admitted to practice before the Courts of the State of New York, affirms the following to be true under the penalties of perjury: I am an attorney at GOLDSTEIN & HANDWERKER, LLP, attorneys of record for Plaintiff, JAHARY CANTO, in the action within. I have read the annexed BILL OF PARTICULARS and know the contents thereof, and the same are true to my knowledge, except those matters therein which are stated to be alleged upon information and belief, and as to those matters I believe them to be true. My belief, as to those matters therein not stated upon knowledge, is based upon facts, records, and other pertinent information contained in my files. This verification is made by me because Plaintiff is not presently in the County wherein I maintain my offices. Dated: New York, New York December 3, 2020 S OLDSTEIN, ESQ. 7 of 8 FILED: KINGS COUNTY CLERK 12/03/2020 03:52 PM INDEX NO. 519697/2018 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 12/03/2020 Index No.: 519697/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS JAHARY CANTO, Plaintiff, -against- CINE MAGIC EAST RIVER STUDIOS, LLC and JAVA LANDING, LLC AND THE CITY OF NEW YORK, Defendants. VERIFIED BILL OF PARTICULARS GOLDSTEIN &HANDWERKER, LLP Attorneys for Plaintiff 280 Madison Avenue, Suite 1202 New York, New York 10016 (212) 679-1330 TO: EUSTACE, MARQUEZ, EPSTEIN, PREZIOSO & YAPCHANYK Attorneys for Defendant CINE MAGIC EAST RIVER STUDIOS, LLC 28th 55 Water Street, FlOOr New York, New York 10041 (212) 612-4200 ZACHARY W. CARTER Corporation Counsel Attomey for Defendant THE CITY OF NEW YORK 100 Church Street New York, New York 10007 (718) 724-5200 LAW OFFICES OF GREGORY B. COBURN Attorney for Defendant JAVA LANDING, LLC 15th 160 Water Street, FlOOr New York, New York 10038 (212) 422-7533 8 of 8