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FILED: NEW
KINGS
YORK
COUNTY
COUNTY
CLERK
CLERK
09/09/2022
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526205/2022
NYSCEF DOC. NO. 2
1 RECEIVED NYSCEF: 03/26/2024
09/09/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
___________________________________________________________________Ç
DIANA PEREZ, Index No.
SUMMONS .
Plaintiff,
-against- Plaintiff designates Kings
County as the place of trial
MP 1525 BEDFORD LLC, FBE BEDFORD LLC,
FBE LIMITED LLC, ADAM AMERICA LLC Basis of Venue is CPLR §503(a)
and OPUS OPERATIONS LLC, Location of Occurrence
Defendants. Plaintiff resides at:
131-20
14th
Ave
------------------------------------------------------------------X College Point, NY 11356
TO THE ABOVE NAMED DEFENDANTS:
You are hereby summoned and required to serve upon Plaintiff's attorneys an answer to the
Verified Complaint in this action within twenty (20) days after the service of this Summons,
exclusive of the day of service, or within thirty (30) days after se e is complete if this Summons
is not personally delivered to you within the State of New Yo . In ca of your 'lure to answer,
judgment will be taken against you by default for the relie emande n the erifle Complaint.
Dated: Garden City, New York
September 6, 2022
ANTHONY EMANUEL, ESQ.
BORNSTEIN & EMANUEL, P.C.
Attorneys for Plaintiff
200 Garden City Plaza, Suite 201
Garden City, New York 11530
(516) 227-3777
Defendants'
addresses:
MP 1525 BEDFORD LLC - c/o of State of the State of New New York.
Secretary York, Albany,
FBE BEDFORD LLC - c/o of State of the State of New New York.
Secretary York, Albany,
FBE LIMITED LLC - c/o of State of the State of New New York.
Secretary York, Albany,
ADAM AMERICA LLC - c/o
Secretary of State of the State of New York, Albany, New York.
OPUS OPERATIONS LLC - c/o of State of the State of New New York.
Secretary York, Albany,
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NYSCEF DOC. NO. 2
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
_________________________________________________________________Ç
DIANA PEREZ, Index No.
Plaintiff,
-against- VERIFIED
COMPLAINT
MP 1525 BEDFORD LLC, FBE BEDFORD LLC,
FBE LIMITED LLC, ADAM AMERICA LLC
and OPUS OPERATIONS LLC,
Defendants.
____________.______________________________________________________Ç
PLAINTIFF, by her attorneys, BORNSTEIN & EMANUEL, P.C., complaining of the
defendants herein, upon information and belief and at all times hereinafter mentioned, alleges as
follows:
AS AND FOR A FIRST CAUSE OF ACTION
14th
1. Plaintiff, DIANA PEREZ, resided and resides at 131-20 Avenue, College Point,
County of Queens, City and State of New York.
2. Defendant, MP 1525 BEDFORD LLC, (hereinafter referred to as "MP 1525"), was
and still is a domestic corporation duly organized and existing under and by virtue of the laws of
the State of New York.
3. MP 1525 is a duly organized corporation doing business in the State of New York.
4. MP 1525's principal place of business is located within the State of New York.
5. MP 1525 has filed a Certificate of Incorporation within the State of New York.
6. MP 1525 is a duly organized foreign corporation transacting business in the State
of New York.
7. MP 1525 solicits business within the State of New York.
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8. MP 1525 derives substantial revenue from goods used or consumed or services
rendered in the State of New York.
9. MP 1525 expected or should reasonably have expected his acts and business
activities to have consequences within the State of New York.
10. MP 1525 derives substantial revenue from interstate or international commerce.
11. MP 1525 is a duly organized partnership existing and doing business under and by
virtue of the laws of the State of New York.
12. MP 1525 is a duly organized proprietorship existing and doing business under and
by virtue of the laws of the State of New York.
13. Defendant, FBE BEDFORD LLC, (hereinafter referred to as "FBE BEDFORD"),
was and still is a domestic corporation duly organized and existing under and by virtue of the laws
of the State of New York.
14 FBE BEDFORD is a duly organized corporation doing business in the State of New
York.
15. FBE BEDFORD's principal place of business is located within the State of New
York.
16. FBE BEDFORD has filed a Certificate of Incorporation within the State of New
York.
17. FBE BEDFORD is a duly organized foreign corporation transacting business in the
State of New York.
18. FBE BEDFORD solicits business within the State of New York.
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19. FBE BEDFORD derives substantial revenue from goods used or consumed or
services rendered in the State of New York.
20, FBE BEDFORD expected or should reasonably have expected his acts and business
activities to have consequences within the State of New York.
21.. FBE BEDFORD derives substantial revenue from interstate or international
commerce.
22. FBE BEDFORD is a duly organized partnership existing and doing business under
and by virtue of the laws of the State of New York.
23, FBE BEDFORD is a duly organized proprietorship existing and doing business
under and by virtue of the laws of the State of New York.
24. Defendant, FBE LIMITED LLC, (hereinafter referred to as "FBE LIMITED"), was
and still is a domestic corporation duly organized and existing under and by virtue of the laws of
the State of New York.
25; FBE LIMITED is a duly organized corporation doing business in the State of New
York.
26. FBE LIMITED's principal place of business is located within the State of New
York.
27. FBE LIMITED has filed a Certificate of Incorporation within the State of New
York.
28. FBE LIMITED is a duly organized foreign corporation transacting business in the
State of New York.
29, FBE LIMITED solicits business within the State of New York.
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30. FBE LIMITED derives substantial revenue from goods used or consumed or
services rendered in the State of New York.
31. FBE LIMITED expected or should reasonably have expected his acts and business
activities to have consequences within the State of New York.
32. FBE LIMITED derives substantial revenue from interstate or international
commerce.
33, FBE LIMITED is a duly organized partnership existing and doing business under
and by virtue of the laws of the State of New York.
34. FBE LIMITED is a duly organized proprietorship existing and doing business under
and by virtue of the laws of the State of New York.
35. Defendant, ADAM AMERICA LLC (hereinafter referred to as "ADAM
AMERICA"), was and still is a domestic corporation duly organized and existing under and by
virtue of the laws of the State of New York.
36. ADAM AMERICA is a duly organized corporation doing business in the State of
New York.
37. ADAM AMERICA's principal place of business is located within New York
County, State of New York.
38. ADAM AMERICA has filed a Certificate of Incorporation in the New York County
Clerk's Office, County of New York, State of New York.
39. ADAM AMERICA is a duly organized foreign corporation transacting business in
the State of New York.
40. ADAM AMERICA solicits business within the State of New York.
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41. ADAM AMERICA derives substantial revenue from goods used or consumed or
services rendered in the State of New York.
42 ADAM AMERICA expected or should reasonably have expected his acts and
business activities to have consequences within the State of New York.
43. ADAM AMERICA derives substantial revenue from interstate or international
commerce.
44. ADAM AMERICA is a duly organized partnership existing and doing business
under and by virtue of the laws of the State of New York.
45. ADAM AMERICA is a duly organized proprietorship existing and doing business
under and by virtue of the laws of the State of New York.
46. Defendant, OPUS OPERATIONS LLC (hereinafter referred to as "OPUS"), was
and still is a domestic corporation duly organized and existing under and by virtue of the laws of
the State of New York.
47. OPUS is a duly organized corporation doing business in the State of New York.
OPUS'
48. principal place of business is located within Kings County, City and State
of New York.
49. OPUS has filed a Certificate of Incorporation in the Kings County Clerk's Office,
County of Kings, City and State of New York.
50. OPUS is a duly organized foreign corporation transacting business in the State of
New York.
51. OPUS solicits business within the State of New York.
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52. OPUS derives substantial revenue from goods used or consumed or services
rendered in the State of New York.
53. OPUS expected or should reasonably have expected his acts and business activities
to have consequences within the State of New York.
54. OPUS derives substantial revenue from interstate or international commerce.
55. OPUS is a duly organized partnership existing and doing business under and by
virtue of the laws of the State of New York.
56. OPUS is a duly organized proprietorship existing and doing business under and by
virtue of the laws of the State of New York.
57. MP 1525 was and still is the owner of the premises known as 1535 Bedford
Avenue, Brooklyn, County of Kings, City and State of New York.
58, MP 1525 was and still is the lessor of the premises known as 1535 Bedford
Avenue, Brooklyn, County of Kings, City and State of New York.
59. MP 1525 was and still is the lessee of the premises known as 1535 Bedford
Avenue, Brooklyn, County of Kings, City and State of New York.
60. MP 1525 was and still is the managing agent of the premises known as 1535
Bedford Avenue, Brooklyn, County of Kings, City and State of New York.
61. MP 1525 maintained the aforesaid premises.
62. MP 1525 operated the aforesaid premises.
63. MP 1525 controlled the aforesaid premises.
64. MP 1525 inspected the aforesaid premises.
65. MP 1525 repaired the aforesaid premises.
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66. MP 1525 supervised the aforesaid premises.
67; MP 1525 made a special use of and received a special benefit from the aforesaid
premises.
68. MP 1525, owned, leased, operated, maintained, managed, controlled, supervised,
repaired, inspected and made special use of the building and premises known as 1535 Bedford
Avenue, Brooklyn, County of Kings, City and State of New York, in a condition which invited
physical injury thereon.
69. MP 1525, owned, leased, operated, maintained, managed, controlled, supervised,
repaired, inspected and made special use of the building and premises known as 1535 Bedford
Avenue, Brooklyn, County of Kings, City and State of New York, in a condition which was
dangerous to all persons lawfully traversing thereat.
70. FBE BEDFORD was and still is the owner of the premises known as 1535
Bedford Avenue, Brooklyn, County of Kings, City and State of New York.
71; FBE BEDFORD was and still is the lessor of the premises known as 1535 Bedford
Avenue, Brooklyn, County of Kings, City and State of New York.
72. FBE BEDFORD was and still is the lessee of the premises known as 1535
Bedford Avenue, Brooklyn, County of Kings, City and State of New York.
73. FBE BEDFORD was and still is the managing agent of the premises known as 1535
Bedford Avenue, Brooklyn, County of Kings, City and State of New York.
74. FBE BEDFORD maintained the aforesaid premises.
75. FBE BEDFORD operated the aforesaid premises.
76, FBE BEDFORD controlled the aforesaid premises.
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77. FBE BEDFORD inspected the aforesaid premises.
78. FBE BEDFORD repaired the aforesaid premises.
79. FBE BEDFORD supervised the aforesaid premises.
80, FBE BEDFORD made a special use of and received a special benefit from the
aforesaid premises.
81. FBE BEDFORD, owned, leased, operated, maintained, managed, controlled,
supervised, repaired, inspected and made special use of the building and premises known as 1535
Bedford Avenue, Brooklyn, County of Kings, City and State of New York, in a condition which
invited physical injury thereon.
82. FBE BEDFORD, owned, leased, operated, maintained, managed, controlled,
supervised, repaired, inspected and made special use of the building and premises known as 1535
Bedford Avenue, Brooklyn, County of Kings, City and State of New York, in a condition which
was dangerous to all persons lawfully traversing thereat.
83. FBE LIMITED was and still is the owner of the premises known as 1535 Bedford
Avenue, Brooklyn, County of Kings, City and State of New York.
84. FBE LIMITED was and still is the lessor of the premises known as 1535 Bedford
Avenue, Brooklyn, County of Kings, City and State of New York.
85. FBE LIMITED was and still is the lessee of the premises known as 1535 Bedford
Avenue, Brooklyn, County of Kings, City and State of New York.
86. FBE LIMITED was and still is the managing agent of the premises known as 1535
Bedford venue, Brooklyn, County of Kings, City and State of New York.
87. FBE LIMITED maintained the aforesaid premises.
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88. FBE LIMITED operated the aforesaid premises.
89. FBE LIMITED controlled the aforesaid premises.
90. FBE LIMITED inspected the aforesaid premises.
91. FBE LIMITED repaired the aforesaid premises.
92 FBE LIMITED supervised the aforesaid premises.
93. FBE LIMITED made a special use of and received a special benefit from the
aforesaid premises.
94: FBE LIMITED, owned, leased, operated, maintained, managed, controlled,
supervised, repaired, inspected and made special use of the building and premises known as 1535
Bedford Avenue, Brooklyn, County of Kings, City and State of New York, in a condition which
invited physical injury thereon.
95: FBE LIMITED, owned, leased, operated, maintained, managed, controlled,
supervised, repaired, inspected and made special use of the building and premises known as 1535
Bedford Avenue, Brooklyn, County of Kings, City and State of New York, in a condition which
was dangerous to all persons lawfully traversing thereat.
96. ADAM AMERICA was and still is the owner of the premises known as 1535
Bedford Avenue, Brooklyn, County of Kings, City and State of New York.
97. ADAM AMERICA was and still is the lessor of the premises known as 1535
Bedford Avenue, Brooklyn, County of Kings, City and State of New York.
98. ADAM AMERICA was and still is the lessee of the premises known as 1535
Bedford Avenue, Brooklyn, County of Kings, City and State
Preview
FILED: NEW KINGS YORK COUNTY COUNTY CLERK CLERK 09/09/2022 03/26/2024 09:35 12:33 AM PM INDEX NO. 152748/2024 526205/2022 NYSCEF DOC. NO. 2 1 RECEIVED NYSCEF: 03/26/2024 09/09/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ___________________________________________________________________Ç DIANA PEREZ, Index No. SUMMONS . Plaintiff, -against- Plaintiff designates Kings County as the place of trial MP 1525 BEDFORD LLC, FBE BEDFORD LLC, FBE LIMITED LLC, ADAM AMERICA LLC Basis of Venue is CPLR §503(a) and OPUS OPERATIONS LLC, Location of Occurrence Defendants. Plaintiff resides at: 131-20 14th Ave ------------------------------------------------------------------X College Point, NY 11356 TO THE ABOVE NAMED DEFENDANTS: You are hereby summoned and required to serve upon Plaintiff's attorneys an answer to the Verified Complaint in this action within twenty (20) days after the service of this Summons, exclusive of the day of service, or within thirty (30) days after se e is complete if this Summons is not personally delivered to you within the State of New Yo . In ca of your 'lure to answer, judgment will be taken against you by default for the relie emande n the erifle Complaint. Dated: Garden City, New York September 6, 2022 ANTHONY EMANUEL, ESQ. BORNSTEIN & EMANUEL, P.C. Attorneys for Plaintiff 200 Garden City Plaza, Suite 201 Garden City, New York 11530 (516) 227-3777 Defendants' addresses: MP 1525 BEDFORD LLC - c/o of State of the State of New New York. Secretary York, Albany, FBE BEDFORD LLC - c/o of State of the State of New New York. Secretary York, Albany, FBE LIMITED LLC - c/o of State of the State of New New York. Secretary York, Albany, ADAM AMERICA LLC - c/o Secretary of State of the State of New York, Albany, New York. OPUS OPERATIONS LLC - c/o of State of the State of New New York. Secretary York, Albany, 1 of 22 FILED: NEW KINGS YORK COUNTY COUNTY CLERK CLERK 09/09/2022 03/26/2024 09:35 12:33 AM PM INDEX NO. 152748/2024 526205/2022 NYSCEF DOC. NO. 2 1 RECEIVED NYSCEF: 03/26/2024 09/09/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS _________________________________________________________________Ç DIANA PEREZ, Index No. Plaintiff, -against- VERIFIED COMPLAINT MP 1525 BEDFORD LLC, FBE BEDFORD LLC, FBE LIMITED LLC, ADAM AMERICA LLC and OPUS OPERATIONS LLC, Defendants. ____________.______________________________________________________Ç PLAINTIFF, by her attorneys, BORNSTEIN & EMANUEL, P.C., complaining of the defendants herein, upon information and belief and at all times hereinafter mentioned, alleges as follows: AS AND FOR A FIRST CAUSE OF ACTION 14th 1. Plaintiff, DIANA PEREZ, resided and resides at 131-20 Avenue, College Point, County of Queens, City and State of New York. 2. Defendant, MP 1525 BEDFORD LLC, (hereinafter referred to as "MP 1525"), was and still is a domestic corporation duly organized and existing under and by virtue of the laws of the State of New York. 3. MP 1525 is a duly organized corporation doing business in the State of New York. 4. MP 1525's principal place of business is located within the State of New York. 5. MP 1525 has filed a Certificate of Incorporation within the State of New York. 6. MP 1525 is a duly organized foreign corporation transacting business in the State of New York. 7. MP 1525 solicits business within the State of New York. 2 of 22 FILED: NEW KINGS YORK COUNTY COUNTY CLERK CLERK 09/09/2022 03/26/2024 09:35 12:33 AM PM INDEX NO. 152748/2024 526205/2022 NYSCEF DOC. NO. 2 1 RECEIVED NYSCEF: 03/26/2024 09/09/2022 8. MP 1525 derives substantial revenue from goods used or consumed or services rendered in the State of New York. 9. MP 1525 expected or should reasonably have expected his acts and business activities to have consequences within the State of New York. 10. MP 1525 derives substantial revenue from interstate or international commerce. 11. MP 1525 is a duly organized partnership existing and doing business under and by virtue of the laws of the State of New York. 12. MP 1525 is a duly organized proprietorship existing and doing business under and by virtue of the laws of the State of New York. 13. Defendant, FBE BEDFORD LLC, (hereinafter referred to as "FBE BEDFORD"), was and still is a domestic corporation duly organized and existing under and by virtue of the laws of the State of New York. 14 FBE BEDFORD is a duly organized corporation doing business in the State of New York. 15. FBE BEDFORD's principal place of business is located within the State of New York. 16. FBE BEDFORD has filed a Certificate of Incorporation within the State of New York. 17. FBE BEDFORD is a duly organized foreign corporation transacting business in the State of New York. 18. FBE BEDFORD solicits business within the State of New York. 2 3 of 22 FILED: NEW KINGS YORK COUNTY COUNTY CLERK CLERK 09/09/2022 03/26/2024 09:35 12:33 AM PM INDEX NO. 152748/2024 526205/2022 NYSCEF DOC. NO. 2 1 RECEIVED NYSCEF: 03/26/2024 09/09/2022 19. FBE BEDFORD derives substantial revenue from goods used or consumed or services rendered in the State of New York. 20, FBE BEDFORD expected or should reasonably have expected his acts and business activities to have consequences within the State of New York. 21.. FBE BEDFORD derives substantial revenue from interstate or international commerce. 22. FBE BEDFORD is a duly organized partnership existing and doing business under and by virtue of the laws of the State of New York. 23, FBE BEDFORD is a duly organized proprietorship existing and doing business under and by virtue of the laws of the State of New York. 24. Defendant, FBE LIMITED LLC, (hereinafter referred to as "FBE LIMITED"), was and still is a domestic corporation duly organized and existing under and by virtue of the laws of the State of New York. 25; FBE LIMITED is a duly organized corporation doing business in the State of New York. 26. FBE LIMITED's principal place of business is located within the State of New York. 27. FBE LIMITED has filed a Certificate of Incorporation within the State of New York. 28. FBE LIMITED is a duly organized foreign corporation transacting business in the State of New York. 29, FBE LIMITED solicits business within the State of New York. 3 4 of 22 FILED: NEW KINGS YORK COUNTY COUNTY CLERK CLERK 09/09/2022 03/26/2024 09:35 12:33 AM PM INDEX NO. 152748/2024 526205/2022 NYSCEF DOC. NO. 2 1 RECEIVED NYSCEF: 03/26/2024 09/09/2022 30. FBE LIMITED derives substantial revenue from goods used or consumed or services rendered in the State of New York. 31. FBE LIMITED expected or should reasonably have expected his acts and business activities to have consequences within the State of New York. 32. FBE LIMITED derives substantial revenue from interstate or international commerce. 33, FBE LIMITED is a duly organized partnership existing and doing business under and by virtue of the laws of the State of New York. 34. FBE LIMITED is a duly organized proprietorship existing and doing business under and by virtue of the laws of the State of New York. 35. Defendant, ADAM AMERICA LLC (hereinafter referred to as "ADAM AMERICA"), was and still is a domestic corporation duly organized and existing under and by virtue of the laws of the State of New York. 36. ADAM AMERICA is a duly organized corporation doing business in the State of New York. 37. ADAM AMERICA's principal place of business is located within New York County, State of New York. 38. ADAM AMERICA has filed a Certificate of Incorporation in the New York County Clerk's Office, County of New York, State of New York. 39. ADAM AMERICA is a duly organized foreign corporation transacting business in the State of New York. 40. ADAM AMERICA solicits business within the State of New York. 4 5 of 22 FILED: NEW KINGS YORK COUNTY COUNTY CLERK CLERK 09/09/2022 03/26/2024 09:35 12:33 AM PM INDEX NO. 152748/2024 526205/2022 NYSCEF DOC. NO. 2 1 RECEIVED NYSCEF: 03/26/2024 09/09/2022 41. ADAM AMERICA derives substantial revenue from goods used or consumed or services rendered in the State of New York. 42 ADAM AMERICA expected or should reasonably have expected his acts and business activities to have consequences within the State of New York. 43. ADAM AMERICA derives substantial revenue from interstate or international commerce. 44. ADAM AMERICA is a duly organized partnership existing and doing business under and by virtue of the laws of the State of New York. 45. ADAM AMERICA is a duly organized proprietorship existing and doing business under and by virtue of the laws of the State of New York. 46. Defendant, OPUS OPERATIONS LLC (hereinafter referred to as "OPUS"), was and still is a domestic corporation duly organized and existing under and by virtue of the laws of the State of New York. 47. OPUS is a duly organized corporation doing business in the State of New York. OPUS' 48. principal place of business is located within Kings County, City and State of New York. 49. OPUS has filed a Certificate of Incorporation in the Kings County Clerk's Office, County of Kings, City and State of New York. 50. OPUS is a duly organized foreign corporation transacting business in the State of New York. 51. OPUS solicits business within the State of New York. 5 6 of 22 FILED: NEW KINGS YORK COUNTY COUNTY CLERK CLERK 09/09/2022 03/26/2024 09:35 12:33 AM PM INDEX NO. 152748/2024 526205/2022 NYSCEF DOC. NO. 2 1 RECEIVED NYSCEF: 03/26/2024 09/09/2022 52. OPUS derives substantial revenue from goods used or consumed or services rendered in the State of New York. 53. OPUS expected or should reasonably have expected his acts and business activities to have consequences within the State of New York. 54. OPUS derives substantial revenue from interstate or international commerce. 55. OPUS is a duly organized partnership existing and doing business under and by virtue of the laws of the State of New York. 56. OPUS is a duly organized proprietorship existing and doing business under and by virtue of the laws of the State of New York. 57. MP 1525 was and still is the owner of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York. 58, MP 1525 was and still is the lessor of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York. 59. MP 1525 was and still is the lessee of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York. 60. MP 1525 was and still is the managing agent of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York. 61. MP 1525 maintained the aforesaid premises. 62. MP 1525 operated the aforesaid premises. 63. MP 1525 controlled the aforesaid premises. 64. MP 1525 inspected the aforesaid premises. 65. MP 1525 repaired the aforesaid premises. 6 7 of 22 FILED: NEW KINGS YORK COUNTY COUNTY CLERK CLERK 09/09/2022 03/26/2024 09:35 12:33 AM PM INDEX NO. 152748/2024 526205/2022 NYSCEF DOC. NO. 2 1 RECEIVED NYSCEF: 03/26/2024 09/09/2022 66. MP 1525 supervised the aforesaid premises. 67; MP 1525 made a special use of and received a special benefit from the aforesaid premises. 68. MP 1525, owned, leased, operated, maintained, managed, controlled, supervised, repaired, inspected and made special use of the building and premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York, in a condition which invited physical injury thereon. 69. MP 1525, owned, leased, operated, maintained, managed, controlled, supervised, repaired, inspected and made special use of the building and premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York, in a condition which was dangerous to all persons lawfully traversing thereat. 70. FBE BEDFORD was and still is the owner of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York. 71; FBE BEDFORD was and still is the lessor of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York. 72. FBE BEDFORD was and still is the lessee of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York. 73. FBE BEDFORD was and still is the managing agent of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York. 74. FBE BEDFORD maintained the aforesaid premises. 75. FBE BEDFORD operated the aforesaid premises. 76, FBE BEDFORD controlled the aforesaid premises. 7 8 of 22 FILED: NEW KINGS YORK COUNTY COUNTY CLERK CLERK 09/09/2022 03/26/2024 09:35 12:33 AM PM INDEX NO. 152748/2024 526205/2022 NYSCEF DOC. NO. 2 1 RECEIVED NYSCEF: 03/26/2024 09/09/2022 77. FBE BEDFORD inspected the aforesaid premises. 78. FBE BEDFORD repaired the aforesaid premises. 79. FBE BEDFORD supervised the aforesaid premises. 80, FBE BEDFORD made a special use of and received a special benefit from the aforesaid premises. 81. FBE BEDFORD, owned, leased, operated, maintained, managed, controlled, supervised, repaired, inspected and made special use of the building and premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York, in a condition which invited physical injury thereon. 82. FBE BEDFORD, owned, leased, operated, maintained, managed, controlled, supervised, repaired, inspected and made special use of the building and premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York, in a condition which was dangerous to all persons lawfully traversing thereat. 83. FBE LIMITED was and still is the owner of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York. 84. FBE LIMITED was and still is the lessor of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York. 85. FBE LIMITED was and still is the lessee of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York. 86. FBE LIMITED was and still is the managing agent of the premises known as 1535 Bedford venue, Brooklyn, County of Kings, City and State of New York. 87. FBE LIMITED maintained the aforesaid premises. 8 9 of 22 FILED: NEW KINGS YORK COUNTY COUNTY CLERK CLERK 09/09/2022 03/26/2024 09:35 12:33 AM PM INDEX NO. 152748/2024 526205/2022 NYSCEF DOC. NO. 2 1 RECEIVED NYSCEF: 03/26/2024 09/09/2022 88. FBE LIMITED operated the aforesaid premises. 89. FBE LIMITED controlled the aforesaid premises. 90. FBE LIMITED inspected the aforesaid premises. 91. FBE LIMITED repaired the aforesaid premises. 92 FBE LIMITED supervised the aforesaid premises. 93. FBE LIMITED made a special use of and received a special benefit from the aforesaid premises. 94: FBE LIMITED, owned, leased, operated, maintained, managed, controlled, supervised, repaired, inspected and made special use of the building and premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York, in a condition which invited physical injury thereon. 95: FBE LIMITED, owned, leased, operated, maintained, managed, controlled, supervised, repaired, inspected and made special use of the building and premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York, in a condition which was dangerous to all persons lawfully traversing thereat. 96. ADAM AMERICA was and still is the owner of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York. 97. ADAM AMERICA was and still is the lessor of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State of New York. 98. ADAM AMERICA was and still is the lessee of the premises known as 1535 Bedford Avenue, Brooklyn, County of Kings, City and State