89-07 34th Avenue HP (1)
Transcript of 89-07 34th Avenue HP (1)
CIVIL COURT OF THE STATE OF NEW YORKCOUNTY OF QUEENS, PART C
LUIS ANGULO, ROSA ARIAS, JESUS BENAVIDES, Index No. HP
FREDDY FABIAN BERMEJO, LISA BRADSHAW,DOLORES CALLE, MANUEL CARDENAS,FABIOLA CARPINTEYRO, LUIS CARRASCO,ANGELES CARREON, CARMEN CASTRO, JUANA
CONTRERAS, FAUSTINA COYOTL, NEMECIO VERIFIED PETITION
COYOTL, RUFINO DIAZ, SONIA DILONE, WILSON
ENCARNACION, ANGELINA ESPINO, CECILIA FA
RCIERT, ADELA FLORES, IRIS FLORES, Subject Premises:
MIRIAM FUENTES, WILSON GOMEZ, CARMEN 89-07 34th Avenue
GONZALEZ, OLIVIA GONZAGA, MAGNOLIA Queens, New York 11372
GUZMAN, LAURA HIDALGO, ALBA INASTRILLA,
ALEJANDRO CRUZ LOPEZ, MARTHA
MALDONADO, JUDITH MARTINEZ, NESTOR
MEJIA, MARIA MELENDEZ, SERGIO MELO, JR.,
MARIA MENDEZ, PETER MONCADA, CARMEN
MONSALVE, ZORAIDA MORA, VALENTIN
OLIVARES, CATHERINE PALAGUACHI,MARGARITA PAZ, NINFA PERALTA, KAREN
PEREZ, FABIAN JUAREZ POBLANO, IRINEO
RAMIREZ, ANDRES RESTREPO, JUAN REYES,
PATRICIA RIVAS, BASIILIA RODRIGUEZ, JOSE
RODRIGUEZ, NEYILIA RODRIGUEZ, ROSA
RODRIGUEZ, ELVER RUIZ, GIOVANNI SANCHEZ,ANDREW SOKOLOF, MODESTO SOSA, FAUSTINO
TEPOZ, JOVITA TORRES, COLUMBA VALLE,SALVADOR VALLE, ANA VASQUEZ, NORMA
VASQUEZ, AND TERESA VELIZ
Petitioners
-against-
KEDEX PROPERTIES LLC, KEVIN BOLANOS,JORGE BOLANOS, ROSA BOLANOS
Respondent-Owners, and
DEPARTMENT OF HOUSING PRESERVATION
AND DEVELOPMENT
Co-Respondent, and
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NEW YORK CITY DEPARTMENT OF BUILDINGS
Co-Respondent.
Petitioners, by their attorneys The Legal Aid Society, respectfully allege the following:
1. Petitioners bring this procccdiñg to correct the serious and ongoing
conditions that have resulted in the iccua- of vacate orders by both the New York City
Departmcñt of Buildings and the New York City Department of Housing Preservation
and Development. The vacate orders, issued following a fire in April 2021, have resulted
in over 100 fandlies being forced out of their homes for nearly five months.
2. The building, located at 89-07 and 89-11 34th Avenue, Queens New York
and known as 89-073481
Avenue, Queens, New York 11372 (hcrciñafter "the subject
premises"), is a multiple dwelling as defmed by Section 27-2004(a) of the Housing
Main±==nce Code and contains 133 units. The subject premises is rent regulated, and,
upon information and belief, the subject apartmcñts are rent stabilized or rent controlled.
PARTIES
3. The Petitioners herein are tenants and lawful occupants of the subject
premises. Prior to the issuance of the vacate orders that are currently in place and that
prevent Petitioners from physically occupying the subject premises, Pendenes resided in
and were and are entitled to lawful occupancy of their respective apartments in the
subject premises. The Petitioners, many of whom are long-term residents of the subject
premises, are entitled to enforce the Housing Maiñtcñance Code. The names and
respective apartment ñümbers of the Petitioners are listed in Exhibit A.
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4. Petitioners are members of 89th Street Tenant Unidos Association which
is the long-time tenant association of the residents living at the subject premises.
5. Respondet KEDEX PROPERTIES LLC is the Corporation Owner listed
on the subjectpremises'
Online Building Registration Sr---y Report at 44 Chestnut
Street, Garden City, New York 11530 and is an owner as defined by the Housing
Maintenance Code.
6. Respondet KEVIN BOLANOS is the Managing Agent listed on the
subjectpremises'
Online Buildi-g Registration Summary Report at 89-07 34th Avenue,
Apartment 1-L, Jackson Heights, New York 11372 and is an owner as defined by the
Housing Maintenance Code.
7. Respondet JORGE BOLANOS is the Head Officer listed on the subject
premiscs'Online Building Registration Summary Report at 44 Chestnut Street, Garden
City, New York 11530 and is an owner as defined by the Housing Maintmance Code.
8. Respondent ROSA BOLANOS is the Officer listed on the subject
premises'Online B=il-lieg Registration Summay Report at 44 Chestnut Street, Garden
City, New York 11530 and is an owner as defined by the HousingMai=+--==--3 Code.
9. Co-Respondent DEPARTMENT OF HOUSING PRESERVATION AND
DEVELOPMENT (hcrciñafter HPD) is a city agency charged with enforcing the various
laws pertai-i-g to the maintenance of residential housing, is a statutory respondent
pursuant to NYC Admin. Code 27-2115, and has issued a vacate order for the subject
premises
10. Co-Respondent NEW YORK CITY DEPARTMENT OF BUILDINGS
(herciñaficr DOB) is a city agcñcy charged with enforcing the various laws pertaining to
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the mai÷nance of residential housing and has issued a vacate order for the subject
premises
REGULATORY SCHEME
11. Under NYC Ad-Mst-ative Code § 27-2115(h)(1) and (i), any tenant or
group of teñañts may request issuance of housing standa-d violations against an owner
and may apply iñdividually or jointly, to the housing part for an order directing the
owner, as well as the Department charged with enforcing the Housing Maiñtcñance Code,
to appear before the court. Under NY City Civil Court Act § 110(d) any other city
departmcñt may be joined to an action in order to effectuate proper housing standards and
promote the public interest. A tenant or group of tenants may also com-mee an HP
proceeding to obtain civil pealdes against an owner. See NYC Adm. Code § 27-2115.
12. This Court has broad powers under the NY City Civil Court Act § 110(c)
to "recommend or employ any remedy, program, procedure or sancEen authorized by law
for the enforcanet of housing standards, if it believes they will be more effective to
accomplish compliance or to protect and promote the publicinterest"
as well as under
NYC Adm. Code § 27-2121 to issue an order to correct any violation of the Housing
Mainicnance Code and "to take such other steps as the court may deem ñccessary to
assure contimñg compliance with the requirements of thiscode."
STATEMENT OF FACTS
13. On April 6, 2021, a seven-alarm fire tore through the subject premises,
causing widespread and extensive damage and displaciñg over a hundred families, many
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of whom are long-term residcñts of the building. Nearly five months have passed, and
Petitioners remain üñabic to return to the subject premises to live in their homes.
14. On April 6, 2021, DOB issued a full vacate order. See Exhibit B. On April
14, 2021, HPD issued vacate orders for every apartment in the subject premises due to a
variety of conditions includiñg fire damage to individual apartments, damage to the roof
of the building and shut-offs of electricity and gas. See_Exhibit C, Vacate Order issued by
HPD and Exhibit D, HPD Violations Report dated August 27, 2021. The full vacate
order issued by DOB was modified to a partial vacate order on or about July 19, 2021.
Said order was modified to the extent necessary to allow tenants to enter the premises to
obtain personal belongings from apartments A through I on the first, second, third, fourth,
and fifth floors. See Exhibit B.
15. According to DOB records, the agency also issued a partial stop work
order on or about July 30, 2021. The stop work order appears to have been issued for
unsafe use of a crane.
16. As of the filing of this Petition, the reddents of the building have not been
able to return to live in their apartments and many residents have not had any access to
their apartments since the fire. Currently, there are on or about 139 open violations at the
subject premises iñcluding 129 class"C"
violations, 6 class"B"
violations, 3 class"A"
violations and one class"I"
violation. The I violation requires the building to get a new
certineate of occupancy before the building can be occupied. See_Exhibit D, HPD
Violations Report dated August 27, 2021.
17. Upon information and belief, although individual apartments suffered
varying levels of damage, Petitioners have been given limited information about the
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scope and timcframe of work necessary to repair the common areas, to restore utilities,
and to fix their individual apartments, such that the subject premises will be safe to
occupy.
18. Upon information and belief, Respondent-Owners have denied Petitioners
access to portions of the buildi-g, meaning that many Petitioners have been unable to
access their apartmcñts to retrieve their belonghgs For those Petitioners that have been
able to enter their apartmcñts, access has been unreasonable and severely limited, and
Petitioners have been unable to retrieve their belongi-gs or have received insufficient
notice and assistånce to arrange to move and store their property.
19. Furthermore, upon information and belief, Respondent-Owners have
informed individual Petitioners that they will not be able to retrieve their beloughgs
before construction work commences. Should Respondent-Owners and Respondents
HPD and DOB prcycñt Petitioners from accessing their apartments and retrieving their
belongings, Petitioners, who already been displaced from their homes during a global
pandanic and public health crisis and endured damage to their personal property, may
suffer a complete loss of their belongings.
20. Upon information and belief, HPD has failed to request penalties based
uponrespondents'
failure to correct the listed violations within the time specified by the
Administrative Code of the City of New York.
21. Respondents have failed to make the necessary repairs that would allow
DOB to provide a new certificate of occupancy or allow DOB and HPD to remove their
respective vacate orders so Petitionas may safely return to their homes.
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22. The conditions at the subject premises constitute an emergency, a danger
to the health and safety of the tenants, and constitute violations of the Ad=4=4strative
Code of the City of New York, the Multiple Dwelling Law, and other applicable laws and
regulations.
23. No prior request for this relief has been made.
24. WHEREFORE, Petitioners respectfully request that this Court issue an order:
a. Directing Respondat-Owners to inspect and repair all violadens of the Housing
Maiñtcñañcc Code, the Buildi-g Code, the Multiple Dwelling Law, and any and
all other laws, regulations, and statutes perta ning to housing standards;
b. Directing Respondent-Owners to correct all conditions described in the full and
partial vacate orders issued by the Department of Housing Preservation and
Development and the Department of Buildhgs and correct all violations issued by
the Department of Housing Preservation and Development and Department of
Buildings such that a new certificate of occupancy can be issued, and Petitioners
can safely return to the subject premises;
c. Enje½g Respondat-Owners from commencing construction in the subject
premises until such time that Petitioners have been able to retrieve their personal
belongings;
d. Ordering Respondent-Owners to restorePendenæ;'
apartmcñts to their size and
configuration directly prior to the fire that resulted in the issuañce of vacate orders
by the Department of Housing Preservation and Developmcñt and Department of
Buildings in April 2021;
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e. Allowing Petitioners reasonable and regular access to the subject premises to
obtain their belongir.gs and inspect and confirm the ongoing repair work;
f. Directing Respondent-Owners to provide Petitioners with the Respondent-
Owners' plans and timetable for the correction of all conditions and to provide
ongoing updates to Petitioners until such conditions are corrected;
g. Directing Respondent-Owners and Respondents Department of Housing
Preservations and Developmat and the Department of Buildings to provide the
court and Petitioners with any submissions, certifications, permit applications or
other decamcsts that Respondent-Owners has filed with Co-Resper.dcats to
camm-ce repair work or to remove the violadens and the current vacate orders
issued in the subject premises by the Department of Housing Preservation and
Development and the Department of Buildings and to continue to provide such
documcñts to Petitioners upon filing of said documents;
h. Imposing upon Respeñdcñt-Owners the civil penalties provided by
Ad- -½ative Code § 27-2115(a) based on Respondent-Owners' failure to
correct violations ceñuined in notices of violations issued by the Department of
Housing Preservation and Devclepment and entering a judgement against the
Respondent-Owners for the amount of civil-pealdes imposed by the Court;
i. Finding that the conditions described in the petition constitute violadens, and
directing the respondent-owners to correct the violations within the time provided
by NYC Ad=4=4±ative Code § 27-2115(c) or be subject to civil penalties
pursuant to § 27-2115(a);
j. Awarding costs, disbursements, and reasonableattorneys'
fees to Petitioners;
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k. Granting any other and further relief as the court deems just and proper.
Dated: September 3, 2021
Brooklyn, New York
Respectfully Submitted,
Amee Master, Esq.
Connor Mealey, Esq.
of counsel
Janet E. Sabel, Attorney-in-Chief
THE LEGAL AID SOCIETY
Queens Neighborhood Office
120-46 Queens Boulevard
Kew Gardens, New York 11415
(646) 398-2937
Attorneys for Petitioners
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, bq1 R . /J. y fr t/ L 3being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
c15 day of August 2021
NOTARY PUBLIC
Amee Shah Master
Notary Public- State of New YorkNo. 02MA6266407
Qualified in Kings CountyCommission Expires: 7/30/
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, ()So o being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME:
Sworn to before me this
day of August 2021
NOTARY PUBLIC
AmeeShah
MasterNotary Public-State of
NewYorkNo.02MA6266407Qualified in Kings
CountyommissionExpires:
7/30/__
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY O QUEENS )
it t oDsn c.v 51, being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
AME: e U er)Au Ld C
Sworn to before me this eunvid
S - /© day of August 2021
NOTA PU C
NOTARY PUBLIC, STATE OF NEW YORICRegistration No. 01NAS$97695
ousimed in ousens county
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I,7n , /YF/ being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
AME:
Sworn to before me this
day of August 2021
NOTEY PUBLIC
Amee Shah Master
NotaryPublic- State of New York
No.02MA6266407
Qualmed in Kings County
Commission Expires: 7/30fÎ
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, \. , uly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. I have read or have had read to me the foregoing Petition.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
LsaBradshawuNAME:
Sworn to before me this
day of August 2021
NOTARY PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/...
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VERIFICATI
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, 60 O les CcEb , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: D O c
Sworn to before me this
day of August 2021
NOTA PU
NOTARY PUBUC, STATE OF NEW YOfutRegistration No.01NA6397595
oualifiedinoueeneCommission Expires September 20A8
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, ing duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true. __
NAME:
Sworn to before me this
day of August 2021
N RY PUBLIC
Amee Shah Master
NotaryPublic- State of New York
uu ONo.
02MA6266407
enO
Qualified in Kings County
0 99 N
Cem!ssion Expires: 7/30/-
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, y eing duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
day of August 2021
NOTEY PUBLIC
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/301
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, ÅU Ì S CAfU2AS (O, being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: ÅU// G4 W L O
Sworn to before me this
day of August 2021
NOTARY PUBLIC
Amee Shah MasterPublic- State of New yoryNo.
02MA6266407Qualified in Kings County
on Expires: 7/30/B
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, /}pp/es Carreon , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
day of August 2021
NO RY PUBLIC
a Shah Master
NuaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/2
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I,by ry; n mpbeing duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: NWW Cet sTn,
Sworn to before me this
day of August 2021
NOT PU IC
NOTARY PUBLIC, STATE OF NEW YORICRegistration No.01NA6397595
ountmod in Queene Countycommleolon 9 sons
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, OROR Ûor MS, being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: 1RC1c4 o rh3
Sworn to before me this
day of August 2021
NOTARY PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/21
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, c being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME:
Sworn to before me this
day of August 2021
NOTARY PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/_2
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, )()VLf(¯
(O , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: f ) p g( o
Sworn to before me this
day of August 2021
OTARY PUBLIC
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/.2
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, Êafgp a L , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
day of August 2021
NOt- RY PUBLIC
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Oc=missics Expires: 7/30/-
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VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, b4GCh\ar , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: 6CW c OvW
Sworn to before me this
f f day of August 2021
NOTARY PUBLIC
Amee Shah Master
Notary Public- State of New YorkNo. 02MA6266407
Qualified in Kings CountyCommission Expires: 7/30/1
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
25 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, eing duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
day of August 2021
NOT RY PUBLIC
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
26 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, Ú (ffy being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. I have read or have had read to me the foregoing Petition.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: / LÙ
Sworn to before me this
da pf August 2021
NOTARY PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
27 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, (off (t dr-a('Ã , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: eC/ (6 ()V08
Sworn to before me this
day of August 2021
NOT P LI
NOgUW m SWE OF NEW YORK
in Q
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
28 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, 2 otsv"
eS, being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: c e C d \c-e
Sworn to before me this
day of August 2021
NOTA LIC
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/ 2 H
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
29 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, D77 eing duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. I have read or have had read to me the foregoing Petition.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
/C day of August 2021
NOTARY PUBLIC
Amee Shah Master
Notary Public- State of New YorkNo. 02MA6266407
Qualified in Kings CountyCommission Expires: 7/30/,,2,1
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
30 of 73
VE_RIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, M f r uar) g q , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: Fr )°a vy U Q.n C3
Sworn to before me this
day of August 2021
NOTARfPUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/-2
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
31 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I,'
/7E2being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: O PER
Sworn to before me this
day of August 2021
NÖTARY PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/_2 1
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
32 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: 7
Sworn to before me this
day of August 2021
NOTARY PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/3
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
33 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, (T ) y ) R , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: O
Sworn to before me this
day of August 2021
NOMY PUBLIk
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Q ualified in Kings County
Commission Expires: 7/30/
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
34 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I V a 41 being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. I have read or have had read to me the foregoing Petition.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME:
Sworn to before me this
day of August 2021
NOTARY PUBLIC
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/29
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
35 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, df , mg duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME:
Sworn to before me this
day of August 2021
NO ARY PUBLIC
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30d
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
36 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
IAl ba. cEl r t Î l 4 being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: a.. c
Sworn to before me this
day of August 2021
TARY PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/_
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
37 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, F â$2 Ya , being d y sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME:
Sworn to before me this
day of August 2021
NOT P B
ggy TA5tY PUBLIC, STATE OF NEW YQlKgtegionation No.01NA8397695
Quellfled in Queens CountyCommiselon Empiree September 9.3033
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
38 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, /d WjMp NAb b d, being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
il(nQ f jgh d ( ..j)c A) /4 jd
NAME: a o
Sworn to before me this
day of August 2021
NOTARY PUBLIC
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/-2 N
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
39 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I,T×-<Ó 47 c Äcy
being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: c
Sworn to before me this
ff day of August 2021
NOTARY PUBLIC
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/f4
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
40 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, A , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: 3Óo V
Sworn to before me this
day of August 2021
NOTA PU L
NO UW PUBLA SRTE OF NEW VONENo.01NAS3975OS
hQueens Countycommleolon Exphus September 9, 2083
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
41 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, (1rf C f ( 11 , duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: a CdSworn to before me this
day of August 2021
NO Y P I
NOTARY PUBUC. STATE OF NEW YORICNo. 01NA6397506
lfled in Queens CountyCommission Expirge September 9. 20 A8
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
42 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, £60 LL OQ ing duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
day of August 2021
NdTAÉY PUBLIC
Awsednah Master
yPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
43 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, / / a 7 7/fbeing duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
day of August 2021
NWARY PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/2 1
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
44 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true. .
NAME:
Sworn to before me this
day of August 2021
NOTAR B C
NOTARY PUBUC. STAM
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
45 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, C armm 3 sc\w being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. I have read or have had read to me the foregoing Petition.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
day of August 2021
NOTARY PUBLIC
Amee Shah Master
Notary Public- State of New YorkNo. 02MA6266407
Qualified In Kings CountyCommission Expires: 7/30/f
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
46 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, Z8AA /O4 NOR/ being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: 2GQA (/) & 024
Sworn to before me this
day of August 2021
NOTA1Ñ-PÚBLIC
Amee Shah MasterNotary Public- State of New York
No. 02MA6266407Qualified in Kings County
Commission Expires: 7/30/b
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
47 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, (l&fe/T/A/ ( 2 (l/4ff)being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: E)rdm W 00 6WAS.
Sworn to before me this
day of August 2021
Y PUBLI
Amee Shah MasterNotary Public- State of New York
No.02MA6266407
Qualified in Kings CountyCommissionExpires: 7/30/-
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
48 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, (p‰er tne a eing duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
day of August 2021
NO flfY PUBLIC
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/-
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
49 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, y Ct r ClZ_, being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: C( r // A. 7-
Sworn to before me this
day of August 2021
NQMY PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/_,
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
50 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, eing duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME:
Sworn to before me this
day August 2021
NOT&RÝ PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Gue!!fi=J in Kings County
Commissi0u Expires: 7/30/2
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
51 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, G( W77 , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: 7
Sworn to before me this
day of August 2021
NO RY PUBLIC
Amee Shah Master
Notary Public- State of New YorkNo. 02MA6266407
Qualified in Kings CountyCommission Expires: 7/30/_3
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
52 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I,]O(ht Mk 30awt being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: a Octve L
Sworn to before me this
day o ust 2021
DARY PUBLIC
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/2
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
53 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, 1Ù 060 K 6 2 being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: 1 0 60
Sworn to before me this
day of August 2021
NO Y PUBLIC
Amee Shah Master
otaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
54 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, N Ó(f 1', being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. I have read or have had read to me the foregoing Petition.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME:
Sworn to before me this
day of August 2021
NOTAl BLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/__
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
55 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, bb%3 éyes , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: 30 O
Sworn to before me this
/1 day of August 2021
NO RÝ PUBLIC O
Amee Shah MasterNotary Public- State of New York
No. 02MA6266407Qualified inKings County
Comrñissica Expires: 7/30/2
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
56 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF Q EENS )
I, a being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: Î44
Sworn to before me this
day of August 2021
NO PUEL C
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
57 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, /3r Siffra (lc ysfy,d being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
day of August 2021
N ARY PUBLI
Amee Shah Master
Notary Public- State of New YorkNo. 02MA6266407
Qualified in Kings CountyCommission Expires: 7/30/
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
58 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. I have read or have had read to me the foregoing Petition.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME:
Sworn to before me this
day of August 2021
N ARY PUBLIC
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/24
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
59 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
day of August 2021
NdLdfÉY PUBLC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/.2,
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
60 of 73
KRIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
day of August 2021
OTARY PUBLIC
Amee Shah Master
Notary Public- State of New YorkNo. 02MA6266407
Qualified in Kings CountyCommission Expires: 7/30/f
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
61 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, F b/g ( ÎÊ L , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. I have read or have had read to me the foregoing Petition.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: t L
Sworn to before me this
day of August 2021
N Y PUBLIC
Amee Shah Master
Notary Pubilo- State of New YorkNo. 02MA6266407
Qualified in Kings CountyCommission Expires: 7/30/P
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
62 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, Sif0V{djM QA|\cH , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. I have read or have had read to me the foregoing Petition.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: OVANpt S/NCHGZ
Sworn to before me this
/5 day of August 2021
NOTARY PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/2
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
63 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, , being duly sworn, depose and say:
1. . I am a Petitioner in the within entitled action.
2. I have read or have had read to me the foregoing Petition.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME:
Sworn to before me this
li day of August 2021
NOTARY PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02Ma6266407
QuaG n Kings County
Commission Expires: 7/30/
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
64 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME:
Sworn to before me this
day of August 2021
NOTARY PUBLIC
Amee Shah Master
Notary Public- State of New YorkNo. 02MA6266407
Qualified in Kings CountyCommission Expires: 7/30/_,,Ê
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
65 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, Â being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME:
Sworn to before me this
day of August 2021
NOh PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/2
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
66 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, O 4 Off6 , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: /)V 6Sworn to before me this
day of August 2021
NOTARY PUBLIC
Amee Shah Master
Notary Public- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/__
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
67 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, 4 being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: ( p (jMÎ;qV()
Sworn to before me this
day of August 2021
NÓl"XRY PUBLI
Amee Shah MasterNotary Public- State of New York
No.02MA6266407
Qualified in Kings CountyCommission Expires: 7/30/
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
68 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: (
Sworn to before me this
day of August 2021
60fARY PUBLIC
Amee Shah Master
Notary Public- State of New YorkNo. 02MA6266407
Qualified in Kings CountyCommission Expires: 7/30/-
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
69 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, AG ( b 7 /f-7 , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. I have read or have had read to me the foregoing Petition.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: ()Q Z
Sworn to before me this
day of August 2021
TARY PUBL
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Oua!ified in Kings County
Cammission Expires: 7/301
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
70 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I, /dC/ncx \ h ,egbeing duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
NAME: A )A/An \ in.T o c c
Sworn to before me this
day of August 2021
NOT PU
No.01NA8397895InQueens
comunlesion Explrus
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
71 of 73
VERIFICATION
STATE OF NEW YORK ): ss.:
COUNTY OF QUEENS )
I,tcr A 5 . ( /L , being duly sworn, depose and say:
1. I am a Petitioner in the within entitled action.
2. The foregoing Petition has been read to me in Spanish.
3. The information stated therein is true to my own knowledge except as to
those matters stated to be alleged upon information and belief, and as to those matters I believe
the information to be true.
Sworn to before me this
ff day of August 2021
NOTA Y PUBLIC
Amee Shah Master
NotaryPublic- State of New York
No. 02MA6266407
Qualified in Kings County
Commission Expires: 7/30/24
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
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Index No. Year 2021
CIVIL COURT OF THE CITY OF NEW YORKCOUNTY OF QUEENS: HOUSING PART C=====================================================================
LUIS ANGULO, ROSA ARIAS, JESUS BENAVIDES, FREDDY FABIAN BERMEJO, LISA BRADSHAW,DOLORES CALLE, MANUEL CARDENAS, FABIOLA CARPINTEYRO, LUIS CARRASCO, ANGELES
CARREON, CARMEN CASTRO, JUANA CONTRERAS, FAUSTINA COYOTL, NEMECIO COYOTL,RUFINO DIAZ, SONIA DILONE, WILSON ENCARNACION, ANGELINA ESPINO, CECILIA FARCIERT,ADELA FLORES, IRIS FLORES, MIRIAM FUENTES, WILSON GOMEZ, CARMEN GONZALEZ, OLIVIA
GONZAGA, MAGNOLIA GUZMAN, LAURA HIDALGO, ALBA INASTRILLA, ALEJANDRO CRUZ LOPEZ,MARTHA MALDONADO, JUDITH MARTINEZ, NESTOR MEJIA, MARIA MELENDEZ, SERGIO MELO, JR.MARIA MENDEZ, PETER MONCADA, CARMEN MONSALVE, ZORAIDA MORA, VALENTIN OLIVARES,CATHERINE PALAGUACHI, MARGARITA PAZ, NINFA PERALTA, KAREN PEREZ, FABIAN JUAREZ
POBLANO, IRINEO RAMIREZ, ANDRES RESTREPO, JUAN REYES, PATRICIA RIVAS, BASIILIA
RODRIGUEZ, JOSE RODRIGUEZ, NEYILIA RODRIGUEZ, ROSA RODRIGUEZ, ELVER RUIZ, GIOVANNI
SANCHEZ, ANDREW SOKOLOF, MODESTO SOSA, FAUSTINO TEPOZ, JOVITA TORRES, COLUMBAVALLE, SALVADOR VALLE, ANA VASQUEZ, NORMA VASQUEZ, AND TERESA VELIZ
Petitioners
-against-
KEDEX PROPERTIES LLC, KEVIN BOLANOS, JORGE BOLANOS, ROSA BOLANOS
Respondent-Owners, and
DEPARTMENT OF HOUSING PRESERVATION AND DEVELOPMENT
Co-Respondent, and
NEW YORK CITY DEPARTMENT OF BUILDINGS
Co-Respondent.
VERIFIED PETITION===================--================================================
AMEE MASTER, ESQ.of Counsel to
JANET. E. SABEL, ESQ.Attorney-in-Chief
THE LEGAL AID SOCIETYCIVIL PRACTICE
120-46 QUEENS BOULEVARD FL 3KEW GARDENS, NY 11415-1204
Tel. (646) 398-2937Fax (718) 263 4234
ATTORNEYS FOR PETITIONERS=====================================================================
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State,certifies that, upon information and belief and reasonable inquiry, the contenti ontained in the annexed
document are not frivolous.
Dated:........September 3, 2021...................... Signature........... ........ ....................... ..................................
Print Signer's Name:....Amee Master......................................
FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021
73 of 73