Motion-Secondary: Derek Florimon v. 251 Kane Street, Llc, Owen Realty, Marcia Owen, Josephine Owen, Elizabeth Forman, City Of New York, New York City Department Of Transportation, New York City Department Of Parks And Recreation

On July 16, 2019 a Motion-Secondary was filed involving a dispute between Derek Florimon, and 251 Kane Street, Llc, City Of New York, Elizabeth Forman, Josephine Owen, Marcia Owen, New York City Department Of Parks And Recreation, New York City Department Of Transportation, Owen Realty, for Torts - Other (Premises) in the District Court of Kings County.

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FILED: KINGS COUNTY CLERK 01/16/2020 10:49 AM INDEX NO. 515540/2019
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 01/16/2020

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------- x

DEREK FLORIMON, Index No. 515540/2019

Plaintiff,
RESPONSE TO DEMAND FOR
-against- VERIFIED BILL OF
PARTICULARS AS TO
251 KANE STREET LLC, OWEN REALTY, MARCIA AFFIRMATIVE DEFENSES
OWEN, JOSEPHINE OWEN, ELIZABETH FORMAN,
CITY OF NEW YORK, NEW YORK CITY
DEPARTMENT OF TRANSPORTATION and NEW
YORK CITY DEPARTMENT OF PARKS AND
RECREATION,

Defendants.
_________________________________ ----------------------------X

PLEASE TAKE NOTICE Defendants 251 KANE STREET LLC, OWEN REALTY,

MARCIA OWEN, and JOSEPHINE OWEN (hereinafter collectively referred to as

"Defendants"), by and throughiheir attorneys, O'Toole Scrivo, LLC, as and for their response to

Demand for Verified Bill of Particulars as to Affirmative Defenses hereby alleges as follows:

1. It will be claimed that the damages sustained by Plaintiff were caused by his

negligence in failing to exercise reasonable care and caution for his own safety in view of the

alleged circumstances and conditions in existence at the time and place of the occurrence; in

failing to exercise due care and caution for his own safety in view of the conditions allegedly

then and there in existence; in consciously disregarding the conditions allegedly then and there

existing and the danger allegedly posed thereby and/or in assuming the risk thereof; in ignoring

alleged conditions that were of such an open, obvious and apparent nature that a reasonably

prudent person would have and should have perceived them, and would have and should have

taken appropriate action to avoid and guard against the happening of the accident; in failing to

use an alternative path or means of proceeding as to avoid the said alleged danger; in failing to

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act as a reasonable and prudent person under the circumstances then and there prevailing; in

creating or causing the alleged dangerous condition; and such other acts and further acts of

negligence, culpability, lack of care and omissions which Defendants currently lack knowledge,

which they should learn through discovery proceedings herein.

2. Defendants object to this demand on the grounds that it seeks information of an

evidentiary nature and goes beyond the scope of that which is permissible for a bill of particulars

under CPLR § 3043. See Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822

(2d Dep't 1982) (holding that "[i]t is not the function of a bill of particulars to provide

evidentiary material").

3. Defendants object to this demand on the grounds that itseeks information that

would -be in Plaintiff's possession and Defendants demand the same. Defendants currently lack

knowledge if the alleged negligent acts were committed and/or omitted by Plaintiff solely or

jointly with other persons. Defendants reserve the right to supplement this response during the

course of litigation should they learn such information.

4. Defendants object to this demand on the grounds that it seeks information of an

evidentiary nature and goes beyond the scope of that which is permissible for a bill of particulars

under CPLR § 3043. See Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822

(2d Dep't 1982) (holding that "[i]t is not the function of a bill of particulars to provide

evidentiary material"). Subject to and without waiving said objections, see response to Number

5. Defendants object to this demand on the grounds that it seeks information of an

evidentiary nature and goes beyond the scope of that which is permissible for a bill of particulars

under CPLR § 3043. See Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822

(2d Dep't 1982) (holding that "[i]t is not the function of a bill of particulars to provide

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evidentiary material"). Subject to and without waiving said objections, see response to Number

6. Defendants object to this demand on the grounds that it seeks information relating

to an interpretation of law and/or application of law to certain facts. Defendants further object to

this demand on the grounds that it seeks information of an evidentiary nature and goes beyond

the scope of that which is permissible for a bill of particulars under CPLR § 3043. See

Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822 (2d Dep't 1982) (holding

that "[i]t is not the function of a bill of particulars to provide evidentiary material"). Subject to

and without waiving said objections, Defendants currently lack knowledge of the collateral

reimbursement source that will require Plaintiff's damages to be reduced. Defendants reserve

the right to supplement this response. during the course of litigation should they learn such

information. .

7. Defendants object to this demand on the grounds that it seeks information of an

evidentiary nature and goes beyond the scope of that which is permissible for a bill of particulars

under CPLR § 3043. See Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822

(2d Dep't 1982) (holding that "[i]t is not the function of a bill of particulars to provide

evidentiary material"). Subject to and without waiving said objections, see response to Number

8. Defendants object to this demand on the grounds that it seeks information relating

to an interpretation of law and/or application of law to certain facts. Defendants further object to

this demand on the grounds that it seeks information of an evidentiary nature and goes beyond

the scope of that which is permissible for a bill of particulars under CPLR § 3043. See

Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822 (2d Dep't 1982) (holding

that "[i]t is not the function of a bill of particulars to provide evidentiary material").

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9. Defendants object to this demand on the grounds that it seeks information of an

evidentiary nature and goes beyond the scope of that which is permissible for a bill of particulars

under CPLR § 3043. See Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822

(2d Dep't 1982) (holding that "[i]t is not the function of a bill of particulars to provide

evidentiary material"). Subject to and without waving said objections, the alleged defect is

located entirely on the sidewalk abutting 249 Kane Street, and thus the Defendants had no legal

right to exercise any control over such area.

10. See response to Numbers 1 and 9. Subject to and without waiving said

objections, Defendants currently lack knowledge regarding which third-persons proximately

caused the injuries allegedly sustained by Plaintiff. Defendants reserve the right to supplement

this response during the course of litigation should they learn such information.

11. Defendants object to this demand on the grounds that it seeks information of an

evidentiary nature and goes beyond the scope of that which is permissible for a bill of particulars

under CPLR § 3043. See Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822

(2d Dep't 1982) (holding that "[i]t is not the function of a bill of particulars to provide

evidentiary material"). Defendants further object to this demand on the grounds that it seeks

information that would be in Plaintiff's possession and Defendants demand the same. Subject to

and without waiving said objections, Defendants currently lack knowledge regarding Plaintiff's

failure to mitigate his damages. Defendants reserve the right to supplement this response during

the course of litigation should they learn such information.

12. Defendants object to this demand on the grounds that itseeks information of an

evidentiary nature and goes beyond the scope of that which is permissible for a bill of particulars

under CPLR § 3043. See Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822

(2d Dep't 1982) (holding that "[i]t is not the function of a bill of particulars to provide

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evidentiary material"). Subject to and without waving said objections, see response to Numbers 1

and 9.

13. Defendants object to this demand on the grounds that it seeks information of an

evidentiary nature and goes beyond the scope of that which is permissible for a bill of particulars

under CPLR § 3043. See Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822

(2d Dep't 1982) (holding that "[i]t is not the function of a bill of particulars to provide

evidentiary material"). Subject to and without waving said objections, see response to Numbers 1

and 9. Defendants further object to this demand on the grounds that it seeks information that

would be in Plaintiff's possession and Defendants demand the same. Subject to and without

waiving said objections, Defendants currently lack knowledge that the injuries allegedly

sustained by Plaintiff were the result of superseding and/or intervening causes over which the

Defendants had neither control nor the right of control. Defendants reserve the right to

supplement this response during the course of litigation should they learn such information.

14. Defendants object to this demand on the grounds that it seeks information of an

evidentiary nature and goes beyond the scope of that which is permissible for a bill of particulars

under CPLR § 3043. See Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822

(2d Dep't 1982) (holding that "[i]t is not the function of a bill of particulars to provide

evidentiary material"). Subject to and without waving said objections, see response to Number 1.

15. Defendants object to this demand on the grounds that it seeks information relating

to an interpretation of law and/or application of law to certain facts. Defendants further object to

this demand on the grounds that it seeks information of an evidentiary nature and goes beyond

the scope of that which is permissible for a bill of particulars under CPLR § 3043. See

Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822 (2d Dep't 1982) (holding

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that "[i]t is not the function of a bill of particulars to provide evidentiary material"). Subject to

and without waving said objections, see response to Numbers 1 and 9.

16. Defendants object to this demand on the grounds that itseeks information relating

to an interpretation of law and/or application of law to certain facts.

17. Defendants object to this demand on the grounds that it seeks information of an

evidentiary nature and goes beyond the scope of that which is permissible for a bill of particulars

under CPLR § 3043. See Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822

(2d Dep't 1982) (holding that "[i]t is not the function of a bill of particulars to provide

evidentiary material"). Defendants further object to this demand on the grounds that it seeks

information that would be in Plaintiff's possession and Defendants demand the same. Subject to

and without waving said objections, see response to Numbers 1 and 9.

18. Defendants object to this demand on the grounds that it seeks information of an

evidentiary nature and:goes beyond the scope of that which is permissible for a bill of particulars

under CPLR § 3043. See Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822

(2d Dep't 1982) (holding that "[i]t is not the function of a bill of particulars to provide

evidentiary material"). Defendants further object to this demand on the grounds that it seeks

information that would be in Plaintiff's possession and Defendants demand the same. Subject to

and without waving said objections, see response to Numbers 1 and 9.

19. Defendants object to this demand on the grounds that it seeks information of an

evidentiary nature and goes beyond the scope of that which is permissible for a bill of particulars

under CPLR § 3043. See Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822

(2d Dep't 1982) (holding that "[i]t is not the function of a bill of particulars to provide

evidentiary material"). Defendants further object to this demand on the grounds that it seeks

information relating to an interpretation of law and/or application of law to certain facts.

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Defendant also objects to this demand on the grounds that it seeks information that would be in

Plaintiff's possession and Defendants demand the same.

20. Defendants object to this demand on the grounds that it seeks information relating

to an interpretation of law and/or application of law to certain facts.

21. Defendants object to this demand on the grounds that itseeks information relating

to an interpretation of law and/or application of law to certain facts. Defendants further object to

this demand on the grounds that it seeks information of an evidentiary nature and goes beyond

the scope of that which is permissible for a bill of particulars under CPLR § 3043. See

Frequency Electronics, Inc. v. We're Associates Co., 90 A.D.2d 822 (2d Dep't 1982) (holding

that "[i]t is not the function of a bill of particulars to provide evidentiary material"). Subject to

and without waiving said objections, see response to Numbers 1 and 9.

22. Objection on the grounds this demands seeks information that would be in

Plaintiff's possession and Defendants demand the same.

23. Objection on the grounds this demand seeks information that would be in

Plaintiff's possession and Defendants demand the same. In addition, Defendants object to this

demand on the grounds that it seeks information relating to an interpretation of law and/or

application of law to certain facts.

24. Defendants reserve the right supplement their responses in accordance with CPLR

§ 3043.

PLEASE TAKE FURTHER NOTICE that Defendant hereby reserves her right to

supplement this Response up to and including the time of trial.

Dated: Cedar Grove, New Jersey
January 16, 2020

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Yours, etc.,

O'TOOLE SCRIVO, LLC

/s/MichaelC.Feinberg,Esq.

Michael C. Feinberg, Esq.
Attorneys for Defendants 251 Kane Street, LLC, Owen

Realty,MarciaOwen,andJosephine Owen
14 Village Park Road
Cedar Grove, New Jersey 07009

(973) 239-5700
mfeinberg@oslaw.com

- - AND - -

Empire State Building
350 Fifth Avenue

59th Floor

New York, New York 10118

(888) 663-1117

File No.: 1140-417
office*
*Please reply to New Jersey

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ATTORNEY VERIFICATION

Michael C. Feinberg, an attorney duly admitted to practice law before the Courts of the

State of New York, hereby affirms the following:

That I am an associate with the law firm of O'Toole Scrivo, LLC, attorneys for

Defendants 251 Kane Street, LLC, Owen Realty, Marcia Owen, and Josephine Owen in the

within action.

That I have read the foregoing Response to Demand for Verified Bill of Particulars as to

Affirmative Defenses, and know the contents thereof; that the same is true to the best of my own

knowledge, except as to those matters therein stated to be upon information and belief and that as

to those matters I believe itto be true.

That the reason this verification is made by me and not by my clients is that my clients do

not reside in the County where my office is maintained.

That the grounds for my belief as to all matters not stated upon my knowledge are as

follows: records, reports, facts, and documents contained in the file maintained by my office.

Dated: Cedar Grove, New Jersey
January 16, 2020

/s/ Michael C. Feinberg, Esq.
Michael C. Feinberg

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
____--------------__________-------- ------------------------X
DEREK FLORIMON, Index No. 515540/2019

Plaintiff,
RESPONSE TO NOTICE FOR
-against- DISCOVERY AND INSPECTION

251 KANE STREET LLC, OWEN REALTY, MARCIA
OWEN, JOSEPHINE OWEN, ELIZABETH FORMAN,
CITY OF NEW YORK, NEW YORK CITY
DEPARTMENT OF TRANSPORTATION and NEW
YORK CITY DEPARTMENT OF PARKS AND
RECREATION,

Defendants.
---------------------------------- ---------------------------x

PLEASE TAKE NOTICE Defendants 251 KANE STREET LLC, OWEN REALTY,

MARCIA OWEN, and JOSEPHINE OWEN (hereinafter collectively referred to as

"Defendants"), by and through their attorneys, O'Toole Scrivo, LLC, as and for her response to

Plaintiff's Combined Demands hereby state as follows:

GENERAL OBJECTIONS

1. Defendants object to each demand that seeks documents beyond the scope of

CPLR 3101 and/or CPLR 3120. Defendants will respond to a notice seeking designated

documents or things by making said documents or things available for inspection at a mutually

agreeable time at her counsel's office in accordance with CPLR 3101 and/or CPLR 3120.

2. Defendants object to each demand that seeks documents which are protected from

disclosure by the attorney-client privilege, work-product privilege, and any other privilege

recognized by statute, common law, or the CPLR. To the extent any protected information is

produced, such information was produced inadvertently, and Defendants shall not be deemed to

have waived any of her privileges with respect to that or any other information.

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3. Defendants object to each demand that seeks documents which are not relevant to

the subject matter of this action or not reasonably calculated to lead to the discovery of

admissible evidence.

4. Defendants object to each demand that is overbroad, unduly burdensome, vague,

ambiguous, not limited to a specific time period, require subjective knowledge by persons or

parties other than Defendants, call for speculation, or involve issues of law subject to resolution

by the Court.

5. Defendants object to each demand that fails to sufficiently particularize or

describe the documents sought.

6. Defendants object to each demand that requests documents which are not within

itspossession, custody, or control.

7. Defendants object to the Requests to the extent that they are not limited to a

specific time period relevant to the allegations contained in the Complaint that has been filed to

date in the above-captioned action and/or seek they seek information beyond the time period that

could conceivably lead to the discovery of admissible evidence.

8. Defendants object to each demand which seeks information that is to be

determined within the judgment of counsel, inasmuch as the mental impressions, conclusions,

opinions or legal theories of counsel are absolutely protected from disclosure.

9. Defendants object to the definitions and instructions set forth by plaintiff, to the

extent such definitions and instructions would impose upon Defendant burdens and requirements

beyond those imposed or required by the CPLR.

10. Defendants object to each demand to the extent itseeks information compiled or

to be compiled by experts retained in anticipation of litigation, or in preparation for trial, or by

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experts who are not presently expected to be called as witnesses at trial and which are protected

from disclosure by the CPLR.

11. Defendants object to each demand to the extent it seeks disclosure of mental

impressions, conclusions or opinions of Defendant, their attorneys, or their representatives

respecting the value or merit of the claim or defense or respecting this Defendant's strategy or

tactics.

"work,"
12. Defendants object to the term as used throughout the Requests, as vague,

ambiguous, and subject to several different interpretations.

13. Any Response that states that documents will be produced is to be construed as

relating only to responsive documents in Defendants possession, custody, or control and that are

not otherwise protected by a privilege or other immunity from discovery. Moreover, such

statement shall not be construed as a representation that such documents exist, but should instead

be considered only as an affirmation that documents located through a reasonable search will be

produced.

Objections"
14. These "General are applicable to and incorporated into each of

Defendants'
responses, as if specifically set forth therein. The stating of specific objections to a

Defendants' Objections"
particular Request shall not be construed as a waiver of "General nor

Objection"
does the restatement of a specific reference to a "General in the Response to a

Objection."
particular response Request waive any other "General Unless otherwise specifically

Defendants'
stated, objections to each Request apply to the entire Request, including each and

every subparagraph of each Request. Defendants reserve the right to make specific and further

objections to each Request.

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RESERVATION OF RIGHTS

Defendants expressly reserve their rights to supplement the responses herein, as well as

documents made available for inspection, including identification of documents withheld on the

basis of privilege.

Defendants submit these responses and objections, and will make her documents

available for inspection as described herein, without conceding the relevancy or materiality of

the subject matter of anything contained in the documents, without prejudice to these

Defendants'
rights to object to further discovery, or to object to the admissibility of anything

contained herein, or in such documents or the subject matter thereof at trial. Defendants do not,

by this response, or by the related production, waive any privilege with respect to any document.

No incidental or implied admissions are intended by these responses. The fact that this

Defendants have responded or objected to any demand should not be taken as an admission that

"facts"
itaccepts or admits the existence of any sought by the demand.

RESPONSE

1. Defendants are not in possession of any records of construction, inspection, repair

and/or renovation on the sidewalk adjacent to the premises located at 249-251 Kane Street in

Brooklyn for a period of two years prior to and including the date of Plaintiff's incident on

September 15, 2018.

2. Defendants are not in possession of any records relating to inspections of the

sidewalk adjacent to the premises located at 249-251 Kane Street in Brooklyn for a period of two

years prior to and including the date of Plaintiff's incident on September 15, 2018.

3. Defendants are not in possession of any written policy or memoranda regarding

the cleaning maintaining of the subject premises for three years prior to and including the date of

Plaintiff's incident on September 15, 2018.

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4. Defendants are not in possession of any written policy or memoranda regarding

cleaning procedures and/or guidelines of the subject premises for three years prior to and

including the date of Plaintiff's incident on September 15, 2018.

5. Defendants are not in possession of any records of repair and renovation of the

subject premises for three years prior to and including the date of Plaintiff's incident on

September 15, 2018.

6. Defendants object to this request on the grounds that it improperly assumes facts

that are neither established, stipulated, nor part of the evidentiary record. Defendants further

object to this request on the grounds that it is overly broad and unduly burdensome. Subject to

and without waiving said objections, Defendants are not in possession of any contracts with third

parties responsible for maintenance repairs of the subject premises for three years prior to and

including the date of Plaintiff's incident on September 15, 201&

7. Defendants object to this request on the grounds that itimproperly assumes facts

that are neither established, stipulated, nor part of the evidentiary record. Defendants further

object to this request on the grounds that it is overly broad and unduly burdensome. Subject to

and without waiving said objections, Defendants are not in possession of any permits issued for

three years prior to and including the date of Plaintiff's incident on September 15, 2018.

8. Defendants object to this request on the grounds that it improperly assumes facts

that are neither established, stipulated, nor part of the evidentiary record. Defendants further

object to this request on the grounds that it is overly broad and unduly burdensome. Subject to

and without waiving said objections, Defendants are not in possession of any written complaints

or violations for three years prior to and including the date of Plaintiff's incident on September

15, 2018.

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9. Defendants object to this request on the grounds that it is not reasonably

calculated to lead to the discovery of admissible evidence.

10. Defendants object to this request on the grounds that itimproperly assumes facts

that are neither established, stipulated, nor part of the evidentiary record. Subject to and without

waiving said objections, Defendants are not in possession of any surveillance footage of the

subject premises for 24 hours prior to and including the date of Plaintiff's incident on September

15, 2018.

11. Defendants object to this request on the grounds that itimproperly assumes facts

that are neither established, stipulated, nor part of the evidentiary record. Subject to and without

waiving said objections, Defendants currently lack knowledge of any claims or lawsuits arising

out of the subject incident other than the above-captioned matter.

12. Defendants object to this request on the grounds that it improperly assumes facts

that are neither established, stipulated, nor part of the evidentiary record. Defendants further

object to this request on the grounds that itis not limited to a specified location. Defendants also

"similar"
object to this request on the grounds that the term is vague and ambiguous. Subject to

and without waiving said objections, Defendants currently lack knowledge of any similar

accidents at the subject premises for three years prior to and including September 15, 2018.

13. Defendants object to this request on the grounds that itis overly broad and unduly

burdensome. Subject to and without waving said objections, Defendants are not possession of

any written or oral complaints regarding the subject premises for three years prior to and

including the date of Plaintiff's incident on September 15, 2018.

14. Defendants object to this request on the grounds that itis overly broad and unduly

burdensome. Subject to and without waiving said objections, Defendants claim the following

persons caused or contributed to the subject incident:

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a. Plaintiff; 102 Baltic Street, Apartment 2L, Brooklyn, New York 11201;

b. Elizabeth Forman; 249 Kane Street, Brooklyn, New York 11231;

c. The City of New York; 100 Church Street, New York, New York 10007;

d. The New York City Department of Transportation; 100 Church Street, New York,

New York 10007; and

e. The New York City Department of Parks and Recreation; 100 Church Street, New

York, New York 10007; and

f. All other persons Defendants learn during the course of litigation that may have

caused or contributed to the subject incident.

15. Defendants object to this request on the grounds that itis overly broad and unduly

burdensome. Subject to and without waiving said objections, Defendants respond as follows:

Case Info

Judge

KATHERINE LEVINE Track Judge’s New Case

Case No.

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Document Filed Date

January 16, 2020

Case Filing Date

July 16, 2019

County

Parties

(2019-053936) Attorney for the Defendants
251 Kane Street, LLC Defendant
AMATO, RYAN JOHN Attorney for the Plaintiff
BROMFELD, JEFFREY BRIAN Attorney for the Plaintiff
City of New York Defendant
Counsel, Corporation Attorney for the Defendant
Counsel, Corporation Attorney for the Defendants
DANAYEVA, AIGERIM Attorney for the Plaintiff
Derek Florimon Plaintiff
ELEFTERAKIS, NICHOLAS Attorney for the Plaintiff
Elizabeth Forman Defendant
FEINBERG, MICHAEL COLIN Attorney for the Defendant
FEINBERG, MICHAEL COLIN Attorney for the Defendants
GHAZNAVI, FAIZAN UL-HAQ Attorney for the Plaintiff
GIFFORD, ROBERT WINSOR Attorney for the Defendant
Josephine Owen Defendant
Marcia Owen Defendant
MARRON, MICHAEL SCOTT Attorney for the Plaintiff
NEWMAN, MARK T Attorney for the Plaintiff
New York City Department of Parks and Recreation Defendant
New York City Department of Transportation Defendant
Owen Realty Defendant
ROCCO, DANIEL P. Attorney for the Defendant
WATSON, JOEL LEON ANDRE Attorney for the Defendant
YAPCHANYK, CHRISTOPHER M Attorney for the Defendant
CHERYL FEINBERG Attorneys for Defendants
ANDREY STRUTINSKIY Attorneys for Defendants
MICHAEL CORMACK Attorneys for Defendants

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Motion-Secondary: Derek Florimon v. 251 Kane Street, Llc, Owen Realty, Marcia Owen, Josephine Owen, Elizabeth Forman, City Of New York, New York City Department Of Transportation, New York City Department Of Parks And Recreation

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Parties