FILED: NEW YORK COUNTY CLERK 01/16/ :37 PM

Transcription

1 EXHIBIT A

2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK MAYRA MAHMOOD, et al., - against- Plaintiffs, Index No /2017 (NYSCEF Case) PLAINTIFFS' FIRST NOTICE OF DISCOVERY AND INSPECTION MASON MANAGEMENT SERVICES CORP., d/b/a STELLAR MANAGEMENT, et al. Defendants. SIR/MADAM: PLEASE TAKE NOTICE that, pursuant to, among other things, Article 31 of the CPLR, plaintiffs MAYRA MAHMOOD, ANTHONY CIMINO, RALPH PORR, C.E. MONDEN, MARK TADROS, MARGO ROSS, KIMBERLEY GARRETT, P.G. LYNE, J.M. LUMPKIN, LARRY BENNETT, WENDY BENNETT, LUNA ALARCON, ALEXIS BARBER- DAVIS, ALEX DRYDEN, STEPHANIE FUTCH, FILOMENA REYES, JASON GALLAGHER, MELISSA ABLER, RAMA NDIAYE, ERIC ROCHMAN, SHELLEY ORMES, ERIC FRANKLIN, FRANKSHELL MACHUA, GIOVANNI ANDOLLO, NICOLE AUGSTEIN, CALI HERSH, LEN GUTMAN, KAREN SCHROEDER, DAN DAVENPORT, RUYI JIAO, EMILY HOCHBERG, MICHELLE COURSEY, MATTHEW KARL GALE, WILLIAM PRESTON GRUBBS, YURIY VASKEVICH, BENJAMIN BROWN, KRISTINA CAPPUCCILLI, SYED RAZA RIZVI, EOGHAN MCNULTY, ROISIN MCNULTY, CATHERINE HATTEN, DENISE AQUINO, ALESSANDRA SIMEONE, lillian CHASE, CASSONDRA PULS, ROBIN MINITER, NEHA SAVANT, SAMUEL GOODSPEED, JON WILLIAMS, ROBERT CARR, GIOVANNI CASSINELLI, OUSMAN LAAST ANDREW MARTIN, NARI BOWIE, FADIA ABDEL QADER, JOSE VALDEZ, AMANDA

3 WATERMEYER, RACHAEL WILLOUGHBY JORDAN SHIPLEY, YANA ANJUDINOVA, AND IGOR BORODYANSKY (together, "Plaintiffs") hereby request and demand that Defendant MASON MANAGEMENT SERVICES CORP. d/b/a STELLAR MANAGEMENT and Defendant LAURENCE GLUCK (collectively "Defendants") produce, for inspection and copying, the documents and things listed below, at the offices of Plaintiffs' attorneys, Newman Ferrara LLP, 1250 Broadway, 27th Floor, New York, New York on December 18, 2017 at 10:00 a.m. DEFINITIONS AND INSTRUCTIONS 1. The following terms, whether plural or singular, shall have the meanings set forth below wherever used in this request for production and responses hereto: a. "Plaintiffs" shall mean, each and every time used herein Mayra Mahmood, Anthony Cimino, Ralph Porr, C.E. Monden, Mark Tadros, Margo Ross, Kimberley Garrett, P.O. Lyne, J.M. Lumpkin, Larry Bennett, Wendy Bennett, Luna Alarcon, Alexis Barber Davis, Alex Dryden, Stephanie Futch, Filomena Reyes, Jason Gallagher, Melissa Abler, Rama Ndiaye, Eric Rochman, Shelley Ohmes, Eric Franklin, Frankshell Machua, Giovanni Andollo, Nicole Augstein, Cali Hersh, Len Gutman, Karen Schroeder, Dan Davenport, Ruyi Jiao, Emily Hochberg, Michelle Coursey, Matthew Karl Gale, William Preston Grubbs, Yuriy Vaskevich, Benjamin Brown, Kristina Cappuccilli, Syed Raza Rizvi, Eoghan McNulty, Roisin McNulty, Catherine Hatten, Denise Aquino, Alessandra Simeone, Jillian Chase, Cassandra Puis, Robin Miniter, Neha Savant, Samuel Goodspeed, Jon Williams, Robert Carr, Giovanni Cassinelli, Ousman Laast Andrew Martin, Nari Bowie, Fadia Abdel Qader, Jose Valdez, Amanda Watermeyer, Rachael Willoughby Jordan Shipley, Yana Anjudinova, and Igor Borodyansky, collectively. 2

4 b. "Stellar Management" shall mean, each and every time used herein, defendant MASON MANAGEMENT SERVICES CORP. d/b/a STELLAR MANAGEMENT its agents, employees, representatives, partners, affiliates, attorneys, accountants, predecessors, successors, subsidiaries, and all other persons or entities acting on its behalf or under its control. c. "Defendants" shall mean, each and every time used herein, Stellar Management and Laurence Gluck, collectively. d. "1795 Riverside Drive" shall mean, each and every time used herein, the entire building located at 1795 Riverside Drive, New York, New York. e. "1 Post Avenue" shall mean, each and every time used herein, the entire building located at 1 Post Avenue, New York, New York. f. "3 Post Avenue" shall mean, each and every time used herein, the entire building located at 3 Post Avenue, New York, New York. g. "5 Post Avenue" shall mean, each and every time used herein, the entire building located at 5 Post Avenue, New York, New York. h. "120 Vermilyea Avenue" shall mean, each and every time used herein, the entire building located at 120 Vermilyea, New York, New York. 1. "118 Post Avenue" shall mean, each and every time used herein, the entire building located at 118 Post Avenue, New York, New York. J. "155 Ridge Street" shall mean, each and every time used herein, the entire building located at 155 Ridge Street, New York, New York. k. "501 W. 11 oth Street" shall mean, each and every time used herein, the entire building located at 501 West lloth Street, New York, New York. 3

5 1. "301 E. 4ih Street" shall mean, each and every time used herein, the entire building located at 301 East 4ih Street, New York, New York. m. "20 Seaman Avenue" shall mean, each and every time used herein, the entire building located at 20 Seaman Avenue, New York, New York. n. "341 1Oth Street" shall mean, each and every time used herein, the entire building located at 341 loth Street, Brooklyn, New York. o. "236 E. 13th Street" shall mean, each and every time used herein, the entire building located at 236 East 13th Street, New York, New York. p. "561 W. 141 st Street" shall mean, each and every time used herein, the entire building located at 561 West 141 st Street, New York, New York. q. "600 W. 136th Street" shall mean, each and every time used herein, the entire building located at 600 West 136th Street, New York. r. "600 W. 144th Street" shall mean, each and every time used herein, the entire building located at 600 West 144th Street, New York. s. "620 W. 152nd Street" shall mean, each and every time used herein, the entire building located at 620 West 152nd Street, New York, New York. t. "700 W. 178th Street" shall mean, each and every time used herein, the entire building located at 700 West 178th Street, New York, New York. u. "701 W. 17ih Street" shall mean, each and every time used herein, the entire building located at 700 West 177th Street, New York, New York. v. "700 W. 180th Street" shall mean, each and every time used herein, the entire building located at 700 West 180th Street, New York, New York. 4

6 w. "87 Hamilton Place" shall mean, each and every time used herein, the entire building located at 87 Hamilton Place, New York, New York. x. "Buildings" shall mean, each and every time used herein, 1795 Riverside Drive, 1 Post Avenue. 3 Post Avenue, 5 Post Avenue, 120 Vermilyea Avenue, 155 Ridge Street, 501 W. lloth Street, 301 E. 47th Street, 341 loth Street, 236 E. 13th Street, 561 W. 141st Street, 600 W. 136th Street, 600 W. 144th Street, 620 W. 152nd Street, 700 W. I 78th Street, 701 W. I 77th Street, 700 W. I 80th Street, and 87 Hamilton Place collectively. y. "Apartment" shall mean, each and every time used herein, a unit within the Buildings designated for residential living purposes. z. "Apartments" shall mean, each and every time used herein, all units within the Buildings designated for residential living purposes. aa. "DHCR" shall mean, each and every time used herein, the New York State Division of Housing and Community Renewal. bb. "IAI" shall mean, each and every time used herein, a substantial increase or decrease in dwelling space or a change in the services, furniture, furnishings or equipment provided in the housing accommodations, or improvements installed in the housing accommodation, used to justify a rent increase under (a)(l) of the Rent Stabilization Code.. cc. "J-51 Program" refers to the J-51 tax benefits program, New York Administrative Code, (formerly, J ). dd. "Notices of Deregulation" shall mean, each and every time used herein, the written notice required by RSC (u). 5

7 ee. "MCI" shall mean, each and every time used herein, a major capital improvement submitted to, and/or approved by DHCR, pursuant to of the Rent Stabilization Code. ff. "Document" shall mean, each and every time used herein, any written, typed, recorded or graphic matter, however produced or reproduced, of any kind or description, including originals, non-identical copies and drafts, but is not limited to papers, books, letters, correspondence, telegrams, studies, surveys, contracts, advertisements, schedules, licenses, agreements, notes, memoranda, inter-office communications, s, text messages or other electronic communications, charts, books of account, computer print-outs, computer disks, cdroms, computer tapes, back-up tapes, statements, transcripts, bills of sale, legal pleadings, vouchers, bank checks, bank records, business records, invoices, drafts, drawings, photographs, motion pictures, audio tape recordings, videotapes, promissory notes, desk calendars, appointment books, diaries, and all communicative materials of any kind. gg. "And" as well as "or" shall be construed either m the disjunctive or conjunctive as necessary to bring within the scope hereof any information (as defined herein) which might otherwise be construed to be outside the scope of this discovery request. hh. "Any" shall be understood to include and encompass "all" and vice versa. u. "Communication" shall mean, each and every time used herein, any contact, oral, written or electronic, formal or informal, where information of any nature was transmitted, transferred or exchanged. JJ. "Related to," "relating to," and "relate to" shall include pertaining to, referring to, relevant to, supporting, contradicting, mentioning, evidencing, discussing, 6

8 concerning, evidencing, constituting or otherwise involving, whether directly or indirectly, the subject matter of the specified request. kk. "Concerning" shall include relating to and all of the definitions of "relating to" as set forth in subparagraph "x" above. ll. "Including" shall mean including, but not limited to. 2. The use of the singular form of any word includes the plural and vice versa so as to make the demand most inclusive. 3. This request is of a continuing nature. Therefore, in the event that you acquire possession, custody, or control of any additional documents responsive to the demands herein, after the service of your initial responses hereto, you shall promptly furnish such additional responses to Plaintiffs' undersigned attorneys. 4. If any document demanded was, but no longer is, in your possession, custody or control, state the subject matter of the document; its disposition; the date or dates upon which such disposition was made; and, additionally, produce all documents relating to or concerning the disposition of such document. 5. If any request, or portion thereof, is objected to, (a) state with specificity all grounds for such objection, and (b) respond to the request to the extent no objection exists or applies. 6. If any documents called for by this request are withheld under a claim of privilege, furnish a list setting forth the following for each document for which privilege is claimed: a. the nature of the privilege asserted; b. the type of document; 7

9 c. the general subject matter of the document; d. the date of the document; e. the author of the document; f. the addressee(s) ofthe document; g. the relationship of the author of the document to the addressee(s); h. all other persons who have seen the document or been informed of its contents; and 1. such other information as is sufficient to identify the document for a subpoena duces tecum. 7. Unless a different period is specifically set forth in a demand herein, the period of time covered by this demand shall be deemed to be January 1, 2005 through and including the date of this demand/notice (the "Relevant Period"). DOCUMENT REQUEST PLEASE TAKE FURTHER NOTICE that Defendants are required to produce the below-listed documents in their possession, custody and/or control, unless provided otherwise. 1. Any and all documents and/or communications concerning applications for real estate tax abatements, exemptions, benefits and/or credits in connection with 1795 Riverside Drive, including, without limitation, pursuant to the J-51 Program. 2. Any and all documents and/or communications concerning the receipt of any real estate tax abatements, exemptions, benefits and/or credits in connection with 1795 Riverside including, without limitation, pursuant to the J-51 Program. 3. Any and all documents and communications concerning any IAis performed in Apartment 1A at 1795 Riverside Drive between 2011 and the present (including, without 8

10 limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 4. Any and all Notices of Deregulation provided for any tenant at Apartment la at 1795 Riverside Drive between 2011 and the present. 5. Any and all Apartment Registrations for Apartment 1A at 1795 Riverside Drive between 2011 and the present. 6. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 1A at 1795 Riverside Drive between 2011 and the present. 7. Any and all documents and communications concerning any IAis performed in Apartment 2A at 1795 Riverside Drive between 2011 and the present (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 8. Any and all Notices of Deregulation provided for any tenant at Apartment 2A at 1795 Riverside Drive between 2011 and the present. 9. Any and all Apartment Registrations for Apartment 2A at 1795 Riverside Drive between 2011 and the present. 10. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 2A at 1795 Riverside Drive between 2011 and the present. 11. Any and all documents and communications concerning any IAis performed in Apartment 2G at 1795 Riverside Drive between 2010 and the present (including, without 9

11 limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 12. Any and all Notices of Deregulation provided for any tenant at Apartment 2G at 1795 Riverside Drive between 2010 and the present. 13. Any and all Apartment Registrations for Apartment 2G at 1795 Riverside Drive between 2010 and the present. 14. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 2G at 1795 Riverside Drive between 2010 and the present. 15. Any and all Apartment Registrations for Apartment 2K at 1795 Riverside Drive between 2015 and the present. 16. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 2K at 1795 Riverside Drive between 2015 and the present. 17. Any and all documents and communications concerning any la Is performed in Apartment 3E at 1795 Riverside Drive between 2011 and the present (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 18. Any and all Notices of Deregulation provided for any tenant at Apartment 3E at 1795 Riverside Drive between 2011 and the present. 19. Any and all Apartment Registrations for Apartment 3E at 1795 Riverside Drive between 2011 and the present. 10

12 20. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 3E at 1795 Riverside Drive between 2011 and the present. 21. Any and all Notices of Deregulation provided for any tenant at Apartment 3E at 1795 Riverside Drive between 2011 and the present. 22. Any and all Apartment Registrations for Apartment 5B at 1795 Riverside Drive between 2015 and the present. 23. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 5B at 1795 Riverside Drive between 2011 and the present. 24. Any and all documents and communications concerning any IAis performed in Apartment 5H at 1795 Riverside Drive between 2013 and the present (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 25. Any and all Notices of Deregulation provided for any tenant at Apartment 5H at 1795 Riverside Drive between 2013 and the present. 26. Any and all Apartment Registrations for Apartment 5H at 1795 Riverside Drive between 2013 and the present. 27. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 5H at 1795 Riverside Drive between 2013 and the present. 28. Any and all documents and communications concerning any IAis performed in Apartment 5L at 1795 Riverside Drive between 2007 and the present (including, without 11

13 limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change orders, payment receipts and/or any documents submitted to_dhcr). 29. Any and all Apartment Registrations for Apartment 5L at 1795 Riverside Drive between 2007 and the present. 30. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 5L at 1795 Riverside Drive between 2007 and the present. 31. Any and all Apartment Registrations for Apartment 6A at 1795 Riverside Drive between 2013 and the present. 32. Any and all documents and communications concerning any IAis performed in Apartment 34 at 1 Post Avenue between 2015 and the present (including, without limitation, 33. Any and all Apartment Registrations for Apartment 34 at 1 Post Avenue between 2014 and the present. 34. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 34 at 1 Post A venue between 2014 and the present. 35. Any and all documents and communications concerning the receipt of any Social Citizen Rent Increase Exemption (SCRIE) tax benefit received in connection with Apartment 41 at 3 Post A venue. 36. Any and all Apartment Registrations for Apartment 41 at 3 Post A venue between 2014 and the present. 12

14 37. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 41 at 3 Post A venue between 2014 and the present. 38. Any and all documents and communications concerning any IAis performed in Apartment 44 at 3 Post A venue between 2013 and the present (including, without limitation, 39. Any and all Apartment Registrations for Apartment 44 at 3 Post Avenue between 2013 and the present. 40. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 44 at 3 Post A venue between 2013 and the present. 41. Any and all documents and communications concerning any IAis performed in Apartment 44 at 3 Post Avenue between 2013 and the present (including, without limitation, 42. Any and all Notices of Deregulation provided for any tenant at Apartment 44 at 3 Post A venue between 2013 and the present. 43. Any and all documents and/or communications concerning applications for real estate tax abatements, exemptions, benefits and/or credits in connection with 5 Post A venue, including, without limitation, pursuant to the J-51 Program. 13

15 44. Any and all documents and/or communications concerning the receipt of any real estate tax abatements, exemptions, benefits and/or credits in connection with 5 Post A venue including, without limitation, pursuant to the J-51 Program. 45. Any and all Apartment Registrations for Apartment 1 at 5 Post Avenue between 2009 and the present. 46. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 1 at 5 Post A venue between 2009 and the present. 47. Any and all documents and/or communications concerning applications for real estate tax abatements, exemptions, benefits and/or credits in connection with 120 Vermilyea Avenue, including, without limitation, pursuant to the J-51 Program. 48. Any and all documents and/or communications concerning the receipt of any real estate tax abatements, exemptions, benefits and/or credits in connection with 120 Vermilyea Avenue including, without limitation, pursuant to the J-51 Program. 49. Any and all Apartment Registrations for Apartment A31 at 120 Vermilyea A venue between 2007 and the present. 50. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment A31 at 120 Vermilyea A venue between 2007 and the present. 51. Any and all documents and communications concerning any IAis performed in Apartment A31 at 120 Vermilyea A venue between 2007 and the present (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 14

16 52. Any and all Notices of Deregulation provided for any tenant at Apartment A31 at 120 Vermilyea Avenue between 2017 and the present. 53. Any and all Apartment Registrations for Apartment A53 at 120 Vermilyea A venue between 2007 and the present. 54. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment A53 at 120 Vermilyea Avenue between 2007 and the present. 55. Any and all documents and communications concerning any IAis performed in Apartment A53 at 120 Vermilyea Avenue between 2007 and the present (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 56. Any and all Notices of Deregulation provided for any tenant at Apartment A53 at 120 Vermilyea Avenue between 2007 and the present. 57. Any and all Apartment Registrations for Apartment B02 at 120 Vermilyea A venue between 2011 and the present. 58. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment B02 at 120 Vermilyea Avenue between 2011 and the present. 59. Any and all documents and communications concerning any IAis performed in Apartment B02 at 120 Vermilyea Avenue between 2007 and the present (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 15

17 60. Any and all Apartment Registrations for Apartment B22 at 120 Vermilyea Avenue between 2013 and the present. 61. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment B22 at 120 Vermilyea A venue between 2013 and the present. 62. Any and all documents and communications concerning any IAis performed in Apartment B22 at 120 Vermilyea Avenue between 2013 and the present (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 63. Any and all Apartment Registrations for Apartment B23 at 120 Vermilyea A venue between 2006 and the present. 64. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment B23 at 120 Vermilyea Avenue between 2006 and the present. 65. Any and all Apartment Registrations for Apartment B42 at 120 Vennilyea A venue between 1997 and the present. 66. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment B42 at 120 Vermilyea Avenue between 1997 and the present. 67. Any and all Apartment Registrations for Apartment E52 at 120 Vermilyea A venue between 2013 and the present. 16

18 68. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment ES2 at 120 Vermilyea Avenue between 2013 and the present. 69. Any and all documents and communications concerning any IAis performed in Apartment ES2 at 120 Vermilyea Avenue between 2013 and the present (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 70. Any and all Apartment Registrations for Apartment F02 at 120 Vermilyea Avenue between 2014 and the present. 71. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment F02 at 120 Vermilyea Avenue between 2014 and the present. 72. Any and all documents and communications concerning any IAis performed in Apartment F02 at 120 Vermilyea Avenue between 2014 and the present (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 73. Any and all Apartment Registrations for Apartment SF at 1SS Ridge Street between 2013 and the present. 74. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment SF at 1SS Ridge Street between 2013 and the present. 7S. Any and all documents and communications concerning any IAis performed in Apartment SF at 1SS Ridge Street between 2013 and the present (including, without limitation, 17

19 76. Any and all Notices of Deregulation provided for any tenant at Apartment SF at 155 Ridge Street between 2013 and the present. 77. Any and all documents and/or communications concerning applications for real estate tax abatements, exemptions, benefits and/or credits in connection with 501 W. 110th Street, including, without limitation, pursuant to the J-51 Program. 78. Any and all documents and/or communications concerning the receipt of any real estate tax abatements, exemptions, benefits and/or credits in connection with 501 W. 110th Street, including, without limitation, pursuant to the J-51 Program. 79. Any and all Apartment Registrations for Apartment 2F at 501 W h Street between 2007 and the present. 80. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 2F at 501 W. 110th Street between 2007 and the present. 81. Any and all documents and communications concerning any IAis performed in Apartment 2F at 501 W. 11 oth Street between 2007 and the present (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 82. Any and all Notices of Deregulation provided for any tenant at Apartment 2F at 501 W. 110th Street between 2013 and the present. 83. Any and all Apartment Registrations for Apartment 7B at 501 W h Street between 2009 and the present. 18

20 84. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 7B -at 501 W. 110th Street between 2009 and the present. 85. Any and all documents and communications supporting the calculation of the legal regulated rent of$4, for Apartment 7B at 501 W. lloth Street, when that Apartment was re-registered with DHCR in Any and all Apartment Registrations for Apartment 7G at 501 W. lloth Street between 2006 and the present. 87. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 7G at 501 W. 11 Oth Street between 2006 and the present. 88. Any and all documents and communications concerning any IAis performed in Apartment 7G at 501 W. 110th Street between 2006 and the present (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 89. Any and all documents and communications supporting the calculation of the legal regulated rent of $4, for Apartment 7G at 501 W. 11 Oth Street, when that Apartment was re-registered with DHCR in Any and all Notices of Deregulation provided for any tenant at Apartment 7G at 501 W. 11 Oth Street between 2006 and the present. 91. Any and all Apartment Registrations for Apartment 9F at 501 W. lloth Street between 2013 and the present. 19

21 92. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 9F at 501 W Street between 2013 and the present. 93. Any and all documents and communications concerning any IAis performed in Apartment 9F at 501 W Street between 2012 and the present (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 94. Any and all Apartment Registrations for Apartment log at 501 W. lloth Street between 2011 and the present. 95. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 1 OG at 501 W. lloth Street between 2011 and the present. 96. Any and all documents and communications concerning any IAis performed in Apartment log at 501 W Street between 2011 and the present (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change 97. Any and all documents and/or communications concerning applications for real estate tax abatements, exemptions, benefits and/or credits in connection with 301 E. 47th Street, including, without limitation, pursuant to the J-51 Program. 98. Any and all documents and/or communications concerning the receipt of any real estate tax abatements, exemptions, benefits and/or credits in connection with 301 E. 4i 11 Street, including, without limitation, pursuant to the J-51 Program. 20

22 99. Any and all Apartment Registrations for Apartment 4E at 301 E. 47th Street between 2002 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 4E at 301 E. 47th Street between 2002 and the present Any and all Apartment Registrations for Apartment 4F at 341 loth Street between 2006 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 4F at 341 1oth Street between 2006 and the present Any and all documents and communications concerning any IAis performed in Apartment 4F at 341 1oth Street between 2006 and the present (including, without limitation, 104. Any and all Notices of Deregulation provided for any tenant at Apartment 4F at 501 W. 11 Oth Street between 2006 and the present Any and all Apartment Registrations for Apartment 7M at 341 loth Street between 2010 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 7M at 341 1oth Street between 2010 and the present Any and all documents and communications concerning any IAis performed in Apartment 7M at 341 loth Street between 2010 and the present (including, without limitation, 21

23 108. Any and all Apartment Registrations for Apartment 9F at 341 1oth Street between 2011 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 9F at 341 1oth Street between 2011 and the present Any and all documents and communications concerning any IAis performed in Apartment 9F at 341 loth Street between 2011 and the present (including, without limitation, 111. Any and all Notices of Deregulation provided for any tenant at Apartment 9F at 341 1oth Street between 2011 and the present Any and all Apartment Registrations for Apartment 11L at 341 loth Street between 2008 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 11 L at 341 1oth Street between 2008 and the present Any and all documents and communications concerning any IAis performed in Apartment 11 L at 341 1Oth Street between 2008 and the present (including, without limitation, 22

24 115. Any and all Notices of Deregulation provided for any tenant at Apartment 9F at 341 1Oth Street between 2008 and the present Any and all Apartment Registrations for Apartment 15B at 341 1Oth Street between 2008 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 15B at 341 1oth Street between 2008 and the present Any and all documents and communications concerning any IAis performed in Apartment 15B at 341 1Oth Street between 2008 and the present (including, without limitation, 119. Any and all Notices of Deregulation provided for any tenant at Apartment 15B at 341 1Oth Street between 2008 and the present Any and all Apartment Registrations for Apartment 18C at 341 loth Street between 2012 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 18C at th Street between 2012 and the present Any and all documents and communications concerning any IAis performed in Apartment 18C at 341 loth Street between 2012 and the present (including, without limitation, 23

25 123. Any and all Notices of Deregulation provided for any tenant at Apartment 18C at 341 loth Street between 2012 and the present Any and all Apartment Registrations for Apartment 23 at 236 E. 13th Street between 2015 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 23 at 236 E. 13th Street between 2015 and the present Any and all documents and communications concerning any IAis performed in Apartment 23 at 236 E. 13th Street between 2015 and the present (including, without limitation, 127. Any and all Notices of Deregulation provided for any tenant at Apartment 23 at 236 E. 13th Street between 2015 and the present Any and all documents and/or communications concerning applications for real estate tax abatements, exemptions, benefits and/or credits in connection with 561 W. 141st Street, including, without limitation, pursuant to the J-51 Program Any and all documents and/or communications concerning the receipt of any real estate tax abatements, exemptions, benefits and/or credits in connection with 561 W. 141 st St. including, without limitation, pursuant to the J-51 Program Any and all Apartment Registrations for Apartment 69 at 561 W. 141st St. between 2014 and the present. 24

26 131. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assigmnents and/or guaranties in connection with Apartment 69 at 561 W. 141 st St. between 2014 and the present Any and all documents and communications concerning any IAis performed in Apartment 69 at 561 W. 141 st St. between 2014 and the present (including, without limitation, 133. Any and all Notices of Deregulation provided for any tenant at Apartment 69 at 561 W. 141 st St. between 2014 and the present Any and all Apartment Registrations for Apartment 6A at 600 W. 136th St. between and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assigmnents and/or guaranties in connection with Apartment 6A at 600 W h St. between 2010 and the present Any and all documents and communications concerning any IAis performed in Apartment 6A at 600 W. 136th St. between 2010 and the present (including, without limitation, 137. Any and all Notices of Deregulation provided for any tenant at Apartment 6A at 600 W h St. between 2010 and the present Any and all Apartment Registrations for Apartment 6D at 600 W. 136th St. between 2015 and the present. 25

27 139. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 6D at 600 W. 136th St. between 2015 and the present Any and all documents and communications concerning any IAis performed in Apartment 6D at 600 W. 136th St. between 2015 and the present (including, without limitation, 141. Any and all Notices of Deregulation provided for any tenant at Apartment 6D at 600 W. 136th St. between 2015 and the present Any and all documents and/or communications concerning applications for real estate tax abatements, exemptions, benefits and/or credits in connection with 600 W. 144th St., including, without limitation, pursuant to the J-51 Program Any and all documents and/or communications concerning the receipt of any real estate tax abatements, exemptions, benefits and/or credits in connection with 600 W. 144th St. including, without limitation, pursuant to the J-51 Program Any and all documents concerning the decontrol of Apartment 6D at 600 W. 144th St., including, but not limited to, a copy of the Initial Apartment Registration form (DHCR Form RR-1) filed with DHCR, and a copy of the Initial Apartment Registration provided to the first rent stabilized tenant following the decontrol of Apartment 6D at 600 W. 144th St., and the copy of any Fair Market Rent Appeal, if one was filed Any and all Apartment Registrations for Apartment 6D at 600 W. 144th St. between 2015 and the present. 26

28 146. Any and all Apartment Registrations for Apartment 16 at 620 W. 152nd St. between and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 16 at 620 W. 152nd St. between 2010 and the present Any and all documents and communications concerning any IAis performed in Apartment 16 at 620 W. 152nd St. between 2010 and the present (including, without limitation, 149. Any and all Notices of Deregulation provided for any tenant at Apartment 16 at 620 W. 152nd St. between 2010 and the present Any and all Apartment Registrations for Apartment 46 at 700 W. 178th St. between 2014 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 46 at 700 W. 178th St. between 2014 and the present Any and all documents and communications concerning any IAis performed in Apartment 46 at 700 W. 178th St. between 2014 and the present (including, without limitation, 153. Any and all Notices of Deregulation provided for any tenant at Apartment 46 at 700 W. 178th St. between 2014 and the present. 27

29 154. Any and all Apartment Registrations for Apartment 51 at 700 W. 178th St. between 2014 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 51 at 700 W. 178th St. between 2014 and the present Any and all documents and communications concerning any IAis performed in Apartment 51 at 700 W. 178th St. between 2014 and the present (including, without limitation, 157. Any and all Notices of Deregulation provided for any tenant at Apartment 51 at 700 W. 178th St. between 2014 and the present Any and all Apartment Registrations for Apartment 67 at 701 W. 17i 11 St. between 2015 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 67 at 701 W. 177th St. between 2015 and the present Any and all documents and communications concerning any IAis performed in Apartment 67 at 701 W. 17ih St. between 2015 and the present (including, without limitation, 161. Any and all Notices of Deregulation provided for any tenant at Apartment 67 at 701 W. 177th St. between 2015 and the present. 28

30 162. Any and all documents and/or communications concerning applications for real estate tax abatements, exemptions, benefits and/or credits in connection with 700 W. 180th St., including, without limitation, pursuant to the J-51 Program Any and all documents and/or communications concerning the receipt of any real estate tax abatements, exemptions, benefits and/or credits in connection with 700 W. 180th St. including, without limitation, pursuant to the J-51 Program Any and all Apartment Registrations for Apartment 27 at 700 W h St. between 2008 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 27 at 700 W. 180th St. between 2008 and the present Any and all documents and communications concerning any IAis performed in Apartment 27 at 700 W h St. between 2008 and the present (including, without limitation, 167. Any and all documents and communications supporting the temporary exemption contained in the rent history of Apartment 27 at 700 W. 180th St., for the year Any and all Notices of Deregulation provided for any tenant at Apartment 27 at 700 W. 180th St. between 2008 and the present Any and all documents and/or communications concerning applications for real estate tax abatements, exemptions, benefits and/or credits in connection with 87 Hamilton Place, including, without limitation, pursuant to the J-51 Program. 29

31 I70. Any and all documents and/or communications concerning the receipt of any real estate tax abatements, exemptions, benefits and/or credits in connection with 87 Hamilton Place including, without limitation, pursuant to the J-5I Program. I7I. Any and all Apartment Registrations for Apartment IN at 87 Hamilton Place between 2008 and the present. I72. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment IN at 87 Hamilton Place between 2008 and the present. I73. Any and all documents and communications concerning any IAis performed in Apartment IN at 87 Hamilton Place between 2008 and the present (including, without limitation, I74. Any and all Notices of Deregulation provided for any tenant at Apartment IN at 87 Hamilton Place between 2008 and the present. I75. Any and all Apartment Registrations for Apartment 2G at 87 Hamilton Place between 20I4 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 2G at 87 Hamilton Place between 20 I4 and the present. I77. Any and all documents and communications concerning any IAis performed in Apartment 2G at 87 Hamilton Place between 20I4 and the present (including, without limitation, 30

32 178. Any and all Notices of Deregulation provided for any tenant at Apartment 20 at 87 Hamilton Place between 2014 and the present Any and all Apartment Registrations for Apartment 2S at 87 Hamilton Place between 2014 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 2S at 87 Hamilton Place between 2014 and the present Any and all documents and communications concerning any IAis performed in Apartment 2S at 87 Hamilton Place between 2014 and the present (including, without limitation, 182. Any and all Apartment Registrations for Apartment 6E at 87 Hamilton Place between 2014 and the present Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assignments and/or guaranties in connection with Apartment 6E at 87 Hamilton Place between 2014 and the present Any and all documents and communications concerning any IAis performed in Apartment 6E at 87 Hamilton Place between 2014 and the present (including, without limitation, 185. Any and all Apartment Registrations for Apartment 6K at 87 Hamilton Place between 2008 and the present. 31

33 186. Any and all leases and/or lease riders, modifications, amendments, extensions and/or renewals, subleases, assigrunents and/or guaranties in connection with Apartment 6K at 87 Hamilton Place between 2008 and the present Any and all documents and communications concerning any IAis performed in Apartment 6K at 87 Hamilton Place between 2008 and the present (including, without limitation, 188. Any and all Notices of Deregulation provided for any tenant at Apartment 6K at 87 Hamilton Place between 2008 and the present Any and all documents and/or communications concerning applications for loans and/or financing in connection with the Buildings Any and all documents and/or communications concerning the receipt of any loans and/or financing in connection with the Buildings Any and all documents and/or communications concerning the sale of any of the Buildings A true and complete copy of the DHCR's "Registration Rent Roll Report" for the Buildings A true and complete copy of the DHCR's "Cases by Building Report" for the Buildings Any and all documents and communications concerning any MCI in or about the Buildings (including, without limitation, applications, statements, reports, estimates, bids, contracts, agreements, plans, drawings, change orders, payment receipts and/or documents submitted to DHCR). 32

34 195. Any and all operating agreements for any LLC claiming any ownership interest in any of the Buildings, including any exhibits and amendments thereto Any and all formation agreements for any LLC claiming any ownership interest in any of the Buildings, including any exhibits and amendments thereto Any and all agreements concerning real property management services for any of the Buildings, including any exhibits and amendments thereto All documents upon which Defendants intend to rely upon at trial. PLEASE TAKE FURTHER NOTICE that Plaintiffs reserve the right to serve additional and/or supplemental demands upon Defendants, as may be deemed appropriate and/or necessary during the course of discovery. Dated: New York, New York November 21, 2017 Yours, etc., NEWMAN FERRARA LLP By: ~ ~ Jarred I. Kassenoff, Esq Broadway, 27th Street New York, New York (212) cc: ROSENBERG & ESTIS, P.C. Deborah Riegel, Esq Third Avenue New York, NY (212) Attorneys for Def endants 33

35 NYSCEF DOC. SUPREME NO. 28 COURT OF THE STATE OF NEW YORK RECEIVED NYSCEF: 01/16/2018 CQ(J}!TY OF NEW YORK MA YRA MAHMOOD, et al. Plaintiffs, -against- ( MASON MANAGEMENT SERVICES CORP., d/b/a STELLAR MANAGEMENT, et al. Defendants. PLAINTIFFS' FIRST NOTICE OF DISCOVERY AND INSPECTION NEWMAN FERRARA LLP Attomey(s) for Plaintiffs Office and Post Office Address, Telephone 1250 Broadway, 27th Fl. New York, New York (212) Pursuant to 22 NYCRR a. the undersigned. an al/orney admilled to practice i upon information and belief and reasonable inquiry. the contents of the annexed docun Dated:... l/.~j./:::.~. 9.J Service of a copy of the within is hereby admitted. Dated, Attorney(s) for Sir: Please take notice 0 NOTICE OF ENTRY that the within is a (certified) true copy of a duly entered in the office of the clerk of the within named court on 0 NOTICE OF SETTLEMENT that an order settlement to the HON. of which the within is a true copy will be presented for one of the judges of the within named Court. at on the day of Dated, at M. Yours, etc. NEWMAN FERRARA LLP Signature To Attorney(s) for Attorney(s) for Print Name Office and Post Office Address 1250 Broadwilv?7th m

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