SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

CITIZENS DEFENDING LIBRARIES, :

EDMUND MORRIS, ANNALYN SWAN, :

STANLEY N. KATZ, THOMAS BEND ER, :

DAVID NASAW , JOAN W . SCOTT,

CYNTHIA M. PYLE, CHR ISTABEL

GOUGH, and BLANCHE W EISEN

COOK,

Plaintiffs,

Index No.: 652427/2013

- against -

FFIDAVIT OF

CHRISTABEL GOUGH

DR. ANTHONY W. MARX, NEIL L.

RUDEN S TINE, BOARD OF TRUSTEES :

OF THE NEW Y ORK PUBLIC LIBRARY, :

NEW YO RK PUBLIC LIBRARY, ASTOR, :

LENOX AND TILDEN FOUNDA TIONS,

MICHAEL R. BLOOMBERG,

VERONICA WHITE, NEW YORK CITY :

PARKS DEPARTMENT, CITY OF NEW :

YORK, ROBERT SILMAN ASSOCIATES,:

P.C., and JOSEPH TORTOREL LA,

Defendants.

-and-

STATE OF NEW YORK, NEW YORK

STAT E OFFICE OF PARKS,

RECREATION & HISTORIC

PRESERVATION (NEW YO RK

STATE HISTORIC PRESERVATION

OFFICE),

Nominal Defendants. :

 

STATE OF NEW YORK )

.SS:

COUNTY OF NEW YORK )

CHRISTABEL GOUGH ,

having been duly sworn, deposes and says:

1.

I am a plaintiff in this action. I submit this Affidavit in Support of the Order to

Show Cause for, among other things, an order imm ediately restraining the planned demolition and

removal of the stacks ("S tacks") located at the eminent and historic library fronting Fifth Avenue at

42nd Street ("Central Library"). As discussed below a nd in the accompanying papers, dem olition

and removal of the Stacks are part of an overarching scheme by which the historic core of the

Central Library -- seven stories of structural steel and iron shelving that were, for more than a

century, filled with millions of books and other resource materials – are to be gutted out and

replaced w ith an atrium, sarcastically described by the arch itectural critic of

T h e N e w Y o rk T i m e s

as having "all the elegance and distinction of a suburban m all," thus irreparably destroying one of

New York's most precious architectural masterpieces.

Personal Background

2.

I am a historic preservationist and long-time user of the New York Public Library

("NYPL"). More than 50 years ago, I discovered that New York had a research library at 42nd

Street (the Central Library) open to all—and that whatever question I had would probably be a

topic in the card catalog there. The cards had been thumbed through by so many hands that they

were worn round at the edges, in the same way that the stone steps of a cathedral can be w orn down

by millions of feet. There, in the library, I could find book s I never kne w ex isted as we ll as other

items unavailable elsewhere, all of which could be retrieved almost at once and read in

circumstances of splendor. The Central Library was a palace for books, and the books were a

guiding link to the past.

 

3. Like most users of the Central Library, I am not among the renowned literary

figures who depend on it for their work. But I do depend on it as an invaluable resource for

research and documentation; for learning. I have used the Central Library throughout my life,

and my life has been enriched and is the better for it. The Central Library is one of the crucial

civic amenities that mak e it worthw hile for someon e like me to live here in New Y ork.

4.

My a ctivities as an historic preservation advocate, in part, are grounded in m y own

history. As a small child during World War II, I was terrified by stories and newsreels reporting

air raids and the destruction of cities. Warring factions from both sides deliberately bombed

architectural monum ents as we ll as military targets like railroads, because the military understood

the devastating psychological effect that the loss of national heritage can have on a people. Axis

powers rained firebombs on St. Paul's Cathedral, and the people risked their lives to extinguish

resultant fires with buckets of sand; the cathedral at C oventry was lost, and the allies retaliated by

obliterating the monuments of the city of Dresden. Perhaps many reacted with fear as I did,

because a fter the War, there wa s a huge increase in landmarks prese rvation legislation throughout

the world. So it is sad to see, in time of peace, the damage we are doing to ourselves, to our'r own

National Historic Landmark at 42nd Street.

Preserving the Central Library

5. Protection cannot come from our local landmarks law, which designates only

building interiors when they are customarily accessible to the public. Members of the NYPL

executive staff have incorrectly stated that the Central Library Plan, which is the overarching

scheme pursuant to which the Stacks and their books are slated to be removed, was approved by

the Landmarks Preservation Commission. In fact, no approval was ever granted by the LPC

because it has no jurisdiction over the interior demolition of the Stacks that the NYPL has

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proposed.

6.

The library is important from the standpoint of historic preservation, not only for its

beauty and its iconic place at a crossroads of the city, but because it is a fine examp le of the w ork

of those Am erican builders and architects at the turn of the 20th Century wh o adapted the Beaux

Arts/City Beautiful tradition and made it their own through new efficiencies and new interior

configurations to meet contemporary needs. They made good use of the classical orders and

classically derived decoration without in any way sacrificing functionality, rational circulation

through space, or even expression of function on the building's shell. The Central Library's west

facade has been cited by critics as an early example of modernism, since the unusual long slit

windows both light and express the presence of the book Stacks. Like Grand Central Station, or

the original Penn Station, the library is a fusion of new perform ance standards and old tradition, an

efficiently functioning machine as well as a delight to the eye. Gutting the interior obliterates its

real place in architectural history.

7.

The conception and execution of the public research library, and the Central

Library building dedicated to it , grew out of the A stor, Lenox and Tilden bequests and the official

formation of the New York Public Library as a single, consolidated corporation in 1895. It was

given form by the chief librarian, John Shaw Billings—who designated the location of .the reading

room together with the design and placem ent of the book Stacks b eneath it, lit by sliver windows

and equipped with pneumatic tubes to summon the books and mechanical lifts to retrieve

them—created one of the most efficient and practical book delivery systems in the world. The

young architects, Carrere and Hastings, were chosen through a competition because they best

accommodated Billings' concept in their final design. Under the CLP, all this history will be

erased.

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8.

A parallel initiative, commenced somewhat later, was the expansion and

consolidation of the branch lending libraries in conjunction with Andrew Carnegie's enormous

1901 gift, which has been described as the equivalent of $2.7 billion today. Under the terms of

the consolidation, a small lending library was incorporated into the research library building,

located in the north courtyard light shaft; it is now known as the Bartos Forum. It is a strange

interpretation of history to claim (as N YP L pu blicity does) that this sma ll facility was so important

that it must be made larger and brought back at the expense of the functionality of the research

library for which the building was conce ived and built.

9. In fact, in the 1970s, a different board of trustees determined that the research

library building could not adequately accommodate the needs of a growing midtown circulating

branch. Consequently, they took the initiative of creating the present Mid Manhattan Library on

40th Street, with the benefits of appropriate space and very convenient street level access for

patrons in a hurry, not to m ention excellent accomm odation for Am ericans with Disabilities. The

Mid M anhattan has suffered from deferred m aintenance, for which the trustees are responsible, but

even without expansion it is larger than the space that would be made for it by the demolition

proposed under the Central Library Plan. The budgetary potential of treating a public asset like

the Mid M anhattan Library as a real estate investment ripe for sale is perhaps outweighed by the

enormous (and not yet finally estimated) cost of the structural re-enforcement required to support

the Central Library, if the original structural support provided by the Stacks w ere to be rem oved in

the planned demolition.

10.

As w ith the 2005 private sale of Asher Durand's Hudson River school masterwork,

"Kindred Sp irits," from the Library's collection, the executive staff and trustees fail to understand

that their actions cause irreparable loss to the people of this city. The shrinkage of our libraries,

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the short-sighted sale of our public assets, and the ill-judged demolition of the Stacks that have

served inquisitive minds for m ore than a cen tury, will lay wa ste to an integral part of the distinct

cultural landscape that makes N ew York our hom e.

41/ C‘4.1

CHRISTABE GOU

Sworn to before me this

ay of July, 2013.

LAUREN A. RUDICK

Notary Public, State of New York

No. 02RU6245314

Qualified in New Y ork County

Comm ission Expires July 18, 20 ' 3

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