Preview
FILED: NEW YORK COUNTY CLERK 12/24/2020
09/30/2022 08:36
02:46 AM
PM INDEX NO. 161241/2020
NYSCEF DOC. NO. 1
56 RECEIVED NYSCEF: 12/24/2020
09/30/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------------------------------x Date Filed:
SEAN YOUNG and KIMBERLY YOUNG, Index #:
Plaintiffs, Plaintiff designates
-against- NEW YORK COUNTY
15™
JAMESTOWN 450 WEST STREET L.P., Basis of venue
JAMESTOWN PROPERTIES CORP.,
155
AGB STREET L.L.C, MILK STUDIOS, DEFENDANT'S RESIDENCE
and "ABC
CORPORATION" a
LLC,
fictitious corporation representing SUhDS3NS
unidentified individuals, businesses
Plaintiff resides at:
and/or corporations who owned, 236-14 Bentley Road
controlled, maintained or was
Rosedale, NY 11422
otherwise responsible for the subject
premises,
Defendants.
-------------------------------------x
TO THE ABOVE NAMED DEFENDANT(S):
YOU ARE HEREBY SUMMONED to answer the Complaint in
this action and to serve a copy of your Answer, or, if the
Complaint is not served with this Summons, to serve a Notice of
Appearance, on the Plaintiff's Attorney(s) within 20 days after
the service of this summons, exclusive of the day of service
(or within 30 days after the service is complete if this
summons is not personally delivered to you within the State of
New York); and in case of your failure to appear or answer,
judgment will be taken against you by default for the relief
demanded in the Complaint.
Dated, New York, New York WEITZ & ERG, P.C.
December 23, 2020
By:
Gary Kyein, Esq.
Attorneys for Plaintiffs,
Post Office Address:
700 Broadway
New York, NY 10003
(212) 558-5500
DEFENDANTS:
SEE ATTACHED RIDER
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RIDER
15"
JAMESTOWN 450 WEST STREET L.P.
21St
10 East Street
New York, NY 10010
and/or
Overton 12"
One Park, Floor
3625 Cumberland Blvd.
Atlanta, GA 30339
JAMESTOWN PROPERTIES CORP.
Leon 7*
675 Ponce De Ave. NE, Floor
Atlanta, GA 30308
15"
AGB STREET L.L.C
Park
26*
245 Ave., Floor
New York, NY 10011
and/or
SERVICE VIA NEW YORK SECRETARY OF STATE
AND UPON CORPORATION SERVICE COMPANY
28 Liberty Street
New York, NY 10005
MILK STUDIOS, LLC
215 Coles Street
Jersey City, NJ 07310
and/or
15*
450 W. Street
New York, NY 10011
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------X
SEAN YOUNG and KIMBERLY YOUNG, VERIFIED
COMPLAINT
Index No:
Date Filed:
Plaintiffs,
-against-
15™
JAMESTOWN 450 WEST STREET L.P.,
JAMESTOWN PROPERTIES CORP.,
AGB 15® STREET L.L.C, MILK STUDIOS, LLC
and "ABC
CORPORATION" a fictitious corporation representing
unidentified individuals, businesses and/or corporations who
owned, controlled, maintained or was otherwise responsible
for the subject premises,
Defendants.
--------------------------------------X
Plaintiffs, by their attorneys, WEITZ & LUXENBERG,
P.C., upon information and belief, and at all times
mentioned hereinafter allege:
PARTIES
1. Plaintiffs, SEAN YOUNG and KIMBERLY YOUNG, resided
and still reside at 236-14 Bentley Road, in the County of
Queens, City and State of New York.
15"
2. Defendant, JAMESTOWN 450 WEST STREET L.P., is
a foreign limited partnership duly organized and existing
under and by virtue of the laws of the State of New York.
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15"
3. Defendant, JAMESTOWN 450 WEST STREET L.P., is
a foreign limited partnership doing business in the State of
New York with a place of business being located at 10 East
218
Street, in the County, City and State of New York
and/or 12®
at One Overton Park, Floor, 3625 Cumberland
Boulevard, in the County of Fulton, City of Atlanta and
State of Georgia.
4, Defendant, JAMESTOWN PROPERTIES CORP., is a
foreign business corporation duly organized and existing
under and by virtue of the laws of the State of New York.
5. Defendant, JAMESTOWN PROPERTIES CORP., is a
foreign business corporation doing business in the State of
New York with a place of business being located at 675 Ponce
7"
De Leon Ave. NE, Floor, in the County of Fulton, City of
Atlanta and State of Georgia.
15"
6. Defendant, AGB STREET L.L.C, is a foreign
limited liability company duly organized and existing under
and by virtue of the laws of the State of Delaware.
15*
7. Defendant, AGB STREET L.L.C, is a foreign
limited liability company doing business in the State of New
York with a place of business being located at 245 Park
26*
Ave., Floor, in the County, City and State of New York.
2
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8. Defendant, MILK STUDIOS, LLC, is a foreign limited
liability company duly organized and existing under and by
virtue of the laws of the State of New York.
9. Defendant, MILK STUDIOS, LLC, is a foreign limited
liability company doing business in the State of New York
with a place of business being located at 215 Coles Street,
in the County of Hudson, City of Jersey City and State of
15*
New Jersey and/or 450 W. Street, in the County, City
and State of New York.
CORPORATION,"
10. Defendants, "ABC are fictitious
names designated as such to represent any and all
unidentified individuals, businesses and/or corporations who
either owned, controlled, maintained or was in any other way
responsible for maintaining the subject premises free of
hazards to the public, and especially to Plaintiff, SEAN
YOUNG. Although the full identities of Defendants, "ABC
CORPORATION," are it is expected that
presently unknown,
during discovery the identities of these Defendants will be
revealed and the appropriate names (and any further specific
deeds) of these Defendants will be substituted into this
matter.
FIRST CAUSE OF ACTION
6*
11. On or about the day of August, 2018,
3
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15"
defendant, JAMESTOWN 450 WEST STREET L.P., was an owner
15*
of the property located at 450 West Street, in the
County, City and State of New York.
On or 6*
12. about the day of August, 2018,
15"
defendant, JAMESTOWN 450 WEST STREET L.P., leased the
aforesaid property.
6*
13. On or about the day of August, 2018,
15"
defendant, JAMESTOWN 450 WEST STREET L.P., was the
lessor of the aforesaid property.
63
14. On or about the day of August, 2018,
15"
defendant, JAMESTOWN 450 WEST STREET L.P., was the
lessee of the aforesaid property.
6*
15. On or about the day of August, 2018,
15"
defendant, JAMESTOWN 450 WEST STREET L.P., leased a
portion of the aforesaid property.
6*
16. On or about the day of August, 2018,
15"
defendant, JAMESTOWN 450 WEST STREET L.P., by his
agents, servants and/or employees, managed, maintained,
operated, controlled, supervised, inspected and/or repaired
the aforesaid property.
63
17. On or about the day of August, 2018,
15"
def endant, JAMESTOWN 450 WEST STREET L.P., by its
agents, servants and/or employees, created a defective,
4
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dangerous and/or hazardous condition at the aforesaid
property.
On 6*
18. or about the day of August, 2018,
15"
defendant, JAMESTOWN 450 WEST STREET L.P., by its
agents, servants and/or employees, permitted a defective,
dangerous and/or hazardous condition to remain uncorrected
and/or unchanged at the aforesaid property.
6*
19. On or about the day of August, 2018,
defendant, JAMESTOWN PROPERTIES CORP., was an owner of the
15*
property located at 450 West Street, in the
County, City and State of New York.
6*
20. On or about the day of August, 2018,
defendant, JAMESTOWN PROPERTIES CORP., leased the aforesaid
property.
65
21. On or about the day of August, 2018,
defendant, JAMESTOWN PROPERTIES CORP., was the lessor of the
aforesaid property.
6*
22. On or about the day of August, 2018,
defendant, JAMESTOWN PROPERTIES CORP., was the lessee of the
aforesaid property.
6*
23. On or about the day of August, 2018,
defendant, JAMESTOWN PROPERTIES CORP., leased a portion of
the aforesaid property.
5
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24. On or
6*
about the day of August, 2018,
defendant, JAMESTOWN PROPERTIES CORP., by his agents,
servants and/or employees, managed, maintained, operated,
controlled, supervised, inspected and/or repaired the
aforesaid property.
6*
25. On or about the day of August, 2018,
defendant, JAMESTOWN PROPERTIES CORP., by its agents,
servants and/or employees, created a defective, dangerous
and/or hazardous condition at the aforesaid property.
18*
26. On or about the day of February, 2011,
defendant, JAMESTOWN PROPERTIES CORP., by its agents,
servants and/or employees, permitted a defective, dangerous
and/or hazardous condition to remain uncorrected and/or
unchanged at the aforesaid property.
29. At all times herein mentioned, it was the duty of,
defendant, JAMESTOWN PROPERTIES CORP., to keep the aforesaid
property in a reasonably safe and proper condition for use
by the public, including plaintiff, SEAN YOUNG.
6*
30. On or about the day of August, 2018,
15*
defendant, AGB STREET L.L.C, was an owner of the
15*
property located at 450 West Street, in the
County, City and State of New York.
6*
32. On or about the day of August, 2018,
6
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15®
defendant, AGB STREET L.L.C, leased the aforesaid
property.
6"
33. On or about the day of August, 2018,
155
defendant, AGB STREET L.L.C, was the lessor of the
aforesaid property.
6"
34. On or about the day of August, 2018,
15*
defendant, AGB STREET L.L.C, was the lessee of the
aforesaid property.
62
35. On or about the day of August, 2018,
15"
defendant, AGB STREET L.L.C, leased a portion of the
aforesaid property.
36. On or about the
62 of
day August, 2018,
155
defendant, AGB STREET L.L.C, by its agents, servants
and/or employees, managed, maintained, operated, controlled,
supervised, inspected and/or repaired the aforesaid
property.
65
37. On or about the day of August, 2018,
15"
defendant, AGB STREET L.L.C, by its agents, servants
and/or employees, created a defective, dangerous and/or
hazardous condition at or about the aforesaid property.
6"
38. On or about the day of August, 2018,
15"
defendant, AGB STREET L.L.C, by its agents, servants
and/or employees, permitted a defective, dangerous and/or
7
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hazardous condition to remain uncorrected and/or unchanged
at the aforesaid property.
6*
39. On or about the day of August, 2018,
AGB 15*
defendant, STREET L.L.C, by its agents, servants
and/or employees, permitted a defective, dangerous and/or
hazardous condition to be, become and/or remain unabated for
an unreasonable length of time on, at or about the aforesaid
property.
40. At all times herein mentioned, it was the duty of,
15*
defendant, AGB STREET L.L.C, to keep the aforesaid
property in a reasonably safe and proper condition for use
by the public, including plaintiff, SEAN YOUNG.
65
41. On or about the day of August, 2018,
defendant, MILK STUDIOS, LLC, was an owner of the property
15*
located at 450 West Street, in the County, City and
State of New York.
65
42. On or about the day of August, 2018,
defendant, MILK STUDIOS, LLC, leased the aforesaid
property.
65
43. On or about the day of August, 2018,
defendant, MILK STUDIOS, LLC, was the lessor of the
aforesaid property.
6*
44. On or about the day of August, 2018,
8
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defendant, MILK STUDIOS, LLC, was the lessee of the
aforesaid property.
or 6*
45. On about the day of August, 2018,
defendant, MILK STUDIOS, LLC, leased a portion of the
aforesaid property.
65
46. On or about the day of August, 2018,
defendant, MILK STUDIOS, LLC, by its agents, servants
and/or employees, managed, maintained, operated, controlled,
supervised, inspected and/or repaired the aforesaid
property.
6"
47. On or about the day of August, 2018,
defendant, MILK STUDIOS, LLC, by its agents, servants
and/or employees, created a defective, dangerous and/or
hazardous condition at or about the aforesaid property.
6"
48. On or about the day of August, 2018,
defendant, MILK STUDIOS, LLC, by its agents, servants
and/or employees, permitted a defective, dangerous and/or
hazardous condition to remain uncorrected and/or unchanged
at the aforesaid property.
or 65
49. On about the day of August, 2018,
defendant, MILK STUDIOS, LLC, by its agents, servants
and/or employees, permitted a defective, dangerous and/or
hazardous condition to be, become and/or remain unabated for
9
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an unreasonable length of time on, at or about the aforesaid
property.
50. At all times herein mentioned, it was the duty of,
defendant, MILK STUDIOS, LLC, to keep the aforesaid
property in a reasonably safe and proper condition for use
by the public, including plaintiff, SEAN YOUNG.
65
51. On or about the day of August, 2018,
defendant, "ABC CORPORATION", leased the aforesaid
property.
62
52. On or about the day of August, 2018,
defendant, "ABC CORPORATION", was the lessor of the
aforesaid property.
65
53. On or about the day of August, 2018,
defendant, "ABC CORPORATION", was the lessee of the
aforesaid property.
65
54. On or about the day of August, 2018,
defendant, "ABC CORPORATION", leased a portion of the
aforesaid property.
65
55. On or about day of August, 2018, defendant,
"ABC CORPORATION", by its agents, servants and/or employees,
created a defective, dangerous and/or hazardous condition
on, at or about the aforesaid property.
65
56. On or about day of August, 2018, defendant,
10
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"ABC CORPORATION", by its agents, servants and/or employees,
permitted a defective, dangerous and/or hazardous condition
to remain uncorrected and/or unchanged at the aforesaid
property.
or 6*
57. On about day of August, 2018, defendant,
"ABC CORPORATION", by its agents, servants and employees,
permitted a defective, dangerous and/or hazardous condition
to be, become and/or remain unabated for an unreasonable
length of time on, at or about the aforesaid
Preview
FILED: NEW YORK COUNTY CLERK 12/24/2020 09/30/2022 08:36 02:46 AM PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 1 56 RECEIVED NYSCEF: 12/24/2020 09/30/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -------------------------------------x Date Filed: SEAN YOUNG and KIMBERLY YOUNG, Index #: Plaintiffs, Plaintiff designates -against- NEW YORK COUNTY 15™ JAMESTOWN 450 WEST STREET L.P., Basis of venue JAMESTOWN PROPERTIES CORP., 155 AGB STREET L.L.C, MILK STUDIOS, DEFENDANT'S RESIDENCE and "ABC CORPORATION" a LLC, fictitious corporation representing SUhDS3NS unidentified individuals, businesses Plaintiff resides at: and/or corporations who owned, 236-14 Bentley Road controlled, maintained or was Rosedale, NY 11422 otherwise responsible for the subject premises, Defendants. -------------------------------------x TO THE ABOVE NAMED DEFENDANT(S): YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a copy of your Answer, or, if the Complaint is not served with this Summons, to serve a Notice of Appearance, on the Plaintiff's Attorney(s) within 20 days after the service of this summons, exclusive of the day of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the Complaint. Dated, New York, New York WEITZ & ERG, P.C. December 23, 2020 By: Gary Kyein, Esq. Attorneys for Plaintiffs, Post Office Address: 700 Broadway New York, NY 10003 (212) 558-5500 DEFENDANTS: SEE ATTACHED RIDER 1 of 17 FILED: NEW YORK COUNTY CLERK 12/24/2020 09/30/2022 08:36 02:46 AM PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 1 56 RECEIVED NYSCEF: 12/24/2020 09/30/2022 RIDER 15" JAMESTOWN 450 WEST STREET L.P. 21St 10 East Street New York, NY 10010 and/or Overton 12" One Park, Floor 3625 Cumberland Blvd. Atlanta, GA 30339 JAMESTOWN PROPERTIES CORP. Leon 7* 675 Ponce De Ave. NE, Floor Atlanta, GA 30308 15" AGB STREET L.L.C Park 26* 245 Ave., Floor New York, NY 10011 and/or SERVICE VIA NEW YORK SECRETARY OF STATE AND UPON CORPORATION SERVICE COMPANY 28 Liberty Street New York, NY 10005 MILK STUDIOS, LLC 215 Coles Street Jersey City, NJ 07310 and/or 15* 450 W. Street New York, NY 10011 2 of 17 FILED: NEW YORK COUNTY CLERK 12/24/2020 09/30/2022 08:36 02:46 AM PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 1 56 RECEIVED NYSCEF: 12/24/2020 09/30/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------X SEAN YOUNG and KIMBERLY YOUNG, VERIFIED COMPLAINT Index No: Date Filed: Plaintiffs, -against- 15™ JAMESTOWN 450 WEST STREET L.P., JAMESTOWN PROPERTIES CORP., AGB 15® STREET L.L.C, MILK STUDIOS, LLC and "ABC CORPORATION" a fictitious corporation representing unidentified individuals, businesses and/or corporations who owned, controlled, maintained or was otherwise responsible for the subject premises, Defendants. --------------------------------------X Plaintiffs, by their attorneys, WEITZ & LUXENBERG, P.C., upon information and belief, and at all times mentioned hereinafter allege: PARTIES 1. Plaintiffs, SEAN YOUNG and KIMBERLY YOUNG, resided and still reside at 236-14 Bentley Road, in the County of Queens, City and State of New York. 15" 2. Defendant, JAMESTOWN 450 WEST STREET L.P., is a foreign limited partnership duly organized and existing under and by virtue of the laws of the State of New York. 3 of 17 FILED: NEW YORK COUNTY CLERK 12/24/2020 09/30/2022 08:36 02:46 AM PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 1 56 RECEIVED NYSCEF: 12/24/2020 09/30/2022 15" 3. Defendant, JAMESTOWN 450 WEST STREET L.P., is a foreign limited partnership doing business in the State of New York with a place of business being located at 10 East 218 Street, in the County, City and State of New York and/or 12® at One Overton Park, Floor, 3625 Cumberland Boulevard, in the County of Fulton, City of Atlanta and State of Georgia. 4, Defendant, JAMESTOWN PROPERTIES CORP., is a foreign business corporation duly organized and existing under and by virtue of the laws of the State of New York. 5. Defendant, JAMESTOWN PROPERTIES CORP., is a foreign business corporation doing business in the State of New York with a place of business being located at 675 Ponce 7" De Leon Ave. NE, Floor, in the County of Fulton, City of Atlanta and State of Georgia. 15" 6. Defendant, AGB STREET L.L.C, is a foreign limited liability company duly organized and existing under and by virtue of the laws of the State of Delaware. 15* 7. Defendant, AGB STREET L.L.C, is a foreign limited liability company doing business in the State of New York with a place of business being located at 245 Park 26* Ave., Floor, in the County, City and State of New York. 2 4 of 17 FILED: NEW YORK COUNTY CLERK 12/24/2020 09/30/2022 08:36 02:46 AM PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 1 56 RECEIVED NYSCEF: 12/24/2020 09/30/2022 8. Defendant, MILK STUDIOS, LLC, is a foreign limited liability company duly organized and existing under and by virtue of the laws of the State of New York. 9. Defendant, MILK STUDIOS, LLC, is a foreign limited liability company doing business in the State of New York with a place of business being located at 215 Coles Street, in the County of Hudson, City of Jersey City and State of 15* New Jersey and/or 450 W. Street, in the County, City and State of New York. CORPORATION," 10. Defendants, "ABC are fictitious names designated as such to represent any and all unidentified individuals, businesses and/or corporations who either owned, controlled, maintained or was in any other way responsible for maintaining the subject premises free of hazards to the public, and especially to Plaintiff, SEAN YOUNG. Although the full identities of Defendants, "ABC CORPORATION," are it is expected that presently unknown, during discovery the identities of these Defendants will be revealed and the appropriate names (and any further specific deeds) of these Defendants will be substituted into this matter. FIRST CAUSE OF ACTION 6* 11. On or about the day of August, 2018, 3 5 of 17 FILED: NEW YORK COUNTY CLERK 12/24/2020 09/30/2022 08:36 02:46 AM PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 1 56 RECEIVED NYSCEF: 12/24/2020 09/30/2022 15" defendant, JAMESTOWN 450 WEST STREET L.P., was an owner 15* of the property located at 450 West Street, in the County, City and State of New York. On or 6* 12. about the day of August, 2018, 15" defendant, JAMESTOWN 450 WEST STREET L.P., leased the aforesaid property. 6* 13. On or about the day of August, 2018, 15" defendant, JAMESTOWN 450 WEST STREET L.P., was the lessor of the aforesaid property. 63 14. On or about the day of August, 2018, 15" defendant, JAMESTOWN 450 WEST STREET L.P., was the lessee of the aforesaid property. 6* 15. On or about the day of August, 2018, 15" defendant, JAMESTOWN 450 WEST STREET L.P., leased a portion of the aforesaid property. 6* 16. On or about the day of August, 2018, 15" defendant, JAMESTOWN 450 WEST STREET L.P., by his agents, servants and/or employees, managed, maintained, operated, controlled, supervised, inspected and/or repaired the aforesaid property. 63 17. On or about the day of August, 2018, 15" def endant, JAMESTOWN 450 WEST STREET L.P., by its agents, servants and/or employees, created a defective, 4 6 of 17 FILED: NEW YORK COUNTY CLERK 12/24/2020 09/30/2022 08:36 02:46 AM PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 1 56 RECEIVED NYSCEF: 12/24/2020 09/30/2022 dangerous and/or hazardous condition at the aforesaid property. On 6* 18. or about the day of August, 2018, 15" defendant, JAMESTOWN 450 WEST STREET L.P., by its agents, servants and/or employees, permitted a defective, dangerous and/or hazardous condition to remain uncorrected and/or unchanged at the aforesaid property. 6* 19. On or about the day of August, 2018, defendant, JAMESTOWN PROPERTIES CORP., was an owner of the 15* property located at 450 West Street, in the County, City and State of New York. 6* 20. On or about the day of August, 2018, defendant, JAMESTOWN PROPERTIES CORP., leased the aforesaid property. 65 21. On or about the day of August, 2018, defendant, JAMESTOWN PROPERTIES CORP., was the lessor of the aforesaid property. 6* 22. On or about the day of August, 2018, defendant, JAMESTOWN PROPERTIES CORP., was the lessee of the aforesaid property. 6* 23. On or about the day of August, 2018, defendant, JAMESTOWN PROPERTIES CORP., leased a portion of the aforesaid property. 5 7 of 17 FILED: NEW YORK COUNTY CLERK 12/24/2020 09/30/2022 08:36 02:46 AM PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 1 56 RECEIVED NYSCEF: 12/24/2020 09/30/2022 24. On or 6* about the day of August, 2018, defendant, JAMESTOWN PROPERTIES CORP., by his agents, servants and/or employees, managed, maintained, operated, controlled, supervised, inspected and/or repaired the aforesaid property. 6* 25. On or about the day of August, 2018, defendant, JAMESTOWN PROPERTIES CORP., by its agents, servants and/or employees, created a defective, dangerous and/or hazardous condition at the aforesaid property. 18* 26. On or about the day of February, 2011, defendant, JAMESTOWN PROPERTIES CORP., by its agents, servants and/or employees, permitted a defective, dangerous and/or hazardous condition to remain uncorrected and/or unchanged at the aforesaid property. 29. At all times herein mentioned, it was the duty of, defendant, JAMESTOWN PROPERTIES CORP., to keep the aforesaid property in a reasonably safe and proper condition for use by the public, including plaintiff, SEAN YOUNG. 6* 30. On or about the day of August, 2018, 15* defendant, AGB STREET L.L.C, was an owner of the 15* property located at 450 West Street, in the County, City and State of New York. 6* 32. On or about the day of August, 2018, 6 8 of 17 FILED: NEW YORK COUNTY CLERK 12/24/2020 09/30/2022 08:36 02:46 AM PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 1 56 RECEIVED NYSCEF: 12/24/2020 09/30/2022 15® defendant, AGB STREET L.L.C, leased the aforesaid property. 6" 33. On or about the day of August, 2018, 155 defendant, AGB STREET L.L.C, was the lessor of the aforesaid property. 6" 34. On or about the day of August, 2018, 15* defendant, AGB STREET L.L.C, was the lessee of the aforesaid property. 62 35. On or about the day of August, 2018, 15" defendant, AGB STREET L.L.C, leased a portion of the aforesaid property. 36. On or about the 62 of day August, 2018, 155 defendant, AGB STREET L.L.C, by its agents, servants and/or employees, managed, maintained, operated, controlled, supervised, inspected and/or repaired the aforesaid property. 65 37. On or about the day of August, 2018, 15" defendant, AGB STREET L.L.C, by its agents, servants and/or employees, created a defective, dangerous and/or hazardous condition at or about the aforesaid property. 6" 38. On or about the day of August, 2018, 15" defendant, AGB STREET L.L.C, by its agents, servants and/or employees, permitted a defective, dangerous and/or 7 9 of 17 FILED: NEW YORK COUNTY CLERK 12/24/2020 09/30/2022 08:36 02:46 AM PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 1 56 RECEIVED NYSCEF: 12/24/2020 09/30/2022 hazardous condition to remain uncorrected and/or unchanged at the aforesaid property. 6* 39. On or about the day of August, 2018, AGB 15* defendant, STREET L.L.C, by its agents, servants and/or employees, permitted a defective, dangerous and/or hazardous condition to be, become and/or remain unabated for an unreasonable length of time on, at or about the aforesaid property. 40. At all times herein mentioned, it was the duty of, 15* defendant, AGB STREET L.L.C, to keep the aforesaid property in a reasonably safe and proper condition for use by the public, including plaintiff, SEAN YOUNG. 65 41. On or about the day of August, 2018, defendant, MILK STUDIOS, LLC, was an owner of the property 15* located at 450 West Street, in the County, City and State of New York. 65 42. On or about the day of August, 2018, defendant, MILK STUDIOS, LLC, leased the aforesaid property. 65 43. On or about the day of August, 2018, defendant, MILK STUDIOS, LLC, was the lessor of the aforesaid property. 6* 44. On or about the day of August, 2018, 8 10 of 17 FILED: NEW YORK COUNTY CLERK 12/24/2020 09/30/2022 08:36 02:46 AM PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 1 56 RECEIVED NYSCEF: 12/24/2020 09/30/2022 defendant, MILK STUDIOS, LLC, was the lessee of the aforesaid property. or 6* 45. On about the day of August, 2018, defendant, MILK STUDIOS, LLC, leased a portion of the aforesaid property. 65 46. On or about the day of August, 2018, defendant, MILK STUDIOS, LLC, by its agents, servants and/or employees, managed, maintained, operated, controlled, supervised, inspected and/or repaired the aforesaid property. 6" 47. On or about the day of August, 2018, defendant, MILK STUDIOS, LLC, by its agents, servants and/or employees, created a defective, dangerous and/or hazardous condition at or about the aforesaid property. 6" 48. On or about the day of August, 2018, defendant, MILK STUDIOS, LLC, by its agents, servants and/or employees, permitted a defective, dangerous and/or hazardous condition to remain uncorrected and/or unchanged at the aforesaid property. or 65 49. On about the day of August, 2018, defendant, MILK STUDIOS, LLC, by its agents, servants and/or employees, permitted a defective, dangerous and/or hazardous condition to be, become and/or remain unabated for 9 11 of 17 FILED: NEW YORK COUNTY CLERK 12/24/2020 09/30/2022 08:36 02:46 AM PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 1 56 RECEIVED NYSCEF: 12/24/2020 09/30/2022 an unreasonable length of time on, at or about the aforesaid property. 50. At all times herein mentioned, it was the duty of, defendant, MILK STUDIOS, LLC, to keep the aforesaid property in a reasonably safe and proper condition for use by the public, including plaintiff, SEAN YOUNG. 65 51. On or about the day of August, 2018, defendant, "ABC CORPORATION", leased the aforesaid property. 62 52. On or about the day of August, 2018, defendant, "ABC CORPORATION", was the lessor of the aforesaid property. 65 53. On or about the day of August, 2018, defendant, "ABC CORPORATION", was the lessee of the aforesaid property. 65 54. On or about the day of August, 2018, defendant, "ABC CORPORATION", leased a portion of the aforesaid property. 65 55. On or about day of August, 2018, defendant, "ABC CORPORATION", by its agents, servants and/or employees, created a defective, dangerous and/or hazardous condition on, at or about the aforesaid property. 65 56. On or about day of August, 2018, defendant, 10 12 of 17 FILED: NEW YORK COUNTY CLERK 12/24/2020 09/30/2022 08:36 02:46 AM PM INDEX NO. 161241/2020 NYSCEF DOC. NO. 1 56 RECEIVED NYSCEF: 12/24/2020 09/30/2022 "ABC CORPORATION", by its agents, servants and/or employees, permitted a defective, dangerous and/or hazardous condition to remain uncorrected and/or unchanged at the aforesaid property. or 6* 57. On about day of August, 2018, defendant, "ABC CORPORATION", by its agents, servants and employees, permitted a defective, dangerous and/or hazardous condition to be, become and/or remain unabated for an unreasonable length of time on, at or about the aforesaid