FILED: NEW YORK COUNTY CLERK 05/09/2016 11:52 AM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 450545/2016
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`RECEIVED NYSCEF: 05/09/2016
`
`
`VERIFIED
`PETITION
`
`Index No.______________________
`IAS Part ______________________
`Assigned to Justice ______________
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`
`
`THE PEOPLE OF THE STATE OF NEW YORK,
`by ERIC T. SCHNEIDERMAN, Attorney General
`of the State of New York,
`
`Petitioner,
`
`
`
`
`
`
`
`
`-against-
`
`
`STEVEN CROMAN, ANTHONY FALCONITE,
`CROMAN REAL ESTATE INC., 9300 REALTY
`MANAGEMENT INC., 9300 REALTY INC.,
`FALCONITE LLC, 3-5 WEST 103RD LLC, 7 EAST
`75 LLC, 9 WEST 103RD LLC, 15 WEST 103RD
`LLC, 17 WEST 103RD LLC, 40 AVENUE B LLC,
`44 AVE B LLC, 44 EAST 1ST LLC, 60 AVENUE B
`LLC, 68 CLINTON STREET LLC, 72 WEST 108TH
`ASSOCIATES LLC, 99-105 THIRD AVENUE
`REALTY LLC, 102 EAST 7TH ST LLC, 115 AVE
`A LLC, 115 MULBERRY LLC, 118 EAST 7 LLC,
`120-120½ FIRST LLC, 124 RIDGE LLC, 127
`EAST 7TH STREET LLC, 134 ORCHARD LLC,
`138 EAST 16TH STREET LLC, 145 E 26 LLC, 159-
`161 STANTON LLC, 171 EAST 102ND LLC, 179-
`181 ESSEX LLC, 182 STANTON LLC, 193-195
`STANTON LLC, 199 EAST 3RD ST LLC, 200
`STANTON LLC, 206 EAST 83RD LLC, 208-214 E
`25TH ST LLC, 209 E 25 LLC, 212-214 EAST 105
`LLC, 213 E 26 LLC, 215 AVENUE B REALTY
`LLC, 218 A LLC, 219 EAST 28 LLC, 227 E. 82
`LLC, 228-230 E 32ND LLC, 232 ELIZABETH LLC,
`232 W 14TH LLC, 234-236 W 14TH LLC, 257
`BLEECKER LLC, 277 E. 10TH LLC, 290 W12 LLC,
`309 WEST 97 LLC, 314 E 106 LLC, 321 EAST
`10TH LLC, 321 W. 16TH LLC, 325 E 5TH LLC, 326 E
`35TH LLC, 326-338 E 100TH LLC, 334 E 6TH LLC,
`343 EAST 8TH LLC, 343-345 E. 5TH ST LLC, 345
`WEST 53RD LLC, 351-357 WEST 45 LLC, 358 W
`51 LLC, 380-382 E. 10TH LLC, 411 E. 12TH ST
`LLC, 420 E. 9TH LLC, 420 W 51 LLC, 422 E. 9TH
`LLC, 424 E. 9TH LLC, 434 WEST 52 LLC, 436
`WEST 52 LLC, 459 W 50 ST LLC, 529 E. 6TH ST.
`LLC, 560-566 HUDSON LLC, 635 E 6 LLC, 697
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`TENTH LLC, 722-724 TENTH AVENUE
`HOLDING LLC, 1373 FIRST AVENUE
`ASSOCIATES LLC, 1590 LEXINGTON LLC,
`M&E 234 LLC, M&E 336-348 E. 18TH ST. LLC,
`M&E 410 EAST 13TH ST. LLC, M&E 416 E 13TH
`STREET LLC, M&E 432 E. 13TH LLC, M&E
`CHRISTOPHER LLC, M&E MOTT LLC, MAJOR
`LEROY CORP., MAJOR MOTT ST. CORP.,
`PRINCE HOLDINGS 2012 LLC, SECOND
`AVENUE & 50TH STREET REALTY LLC,
`
`Respondents.
`
`
`
`
`
`
`The People of the State of New York, by their attorney, Eric T. Schneiderman,
`
`Attorney General of the State of New York, as and for his Petition, respectfully allege:
`
`INTRODUCTION
`
`1.
`
`Over the past decade, Steven Croman has amassed a portfolio of more
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`than 140 apartment buildings throughout Manhattan that are managed by entities he owns
`
`and operates. He grows his portfolio by using a business model predicated on fraudulent
`
`and illegal practices that exploit rent-regulated tenants, and on flouting laws designed to
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`protect the safety and well-being of New York residents. With each new building he
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`acquires, Croman and his business associates harass, coerce, and deceive rent-regulated
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`tenants to drive them out of their long-term homes, so that they can then convert the
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`apartments into highly profitable market-rate units. Croman has implemented this model
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`so successfully that he has deregulated the majority of the rent-stabilized tenants in many
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`of his buildings within just a few years of purchase—a rate much higher than the average
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`New York City landlord.
`
`2.
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`To carry out his scheme, Croman pressures property managers to obtain
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`“buyouts”— payments to tenants who agree to vacate their apartments, often amounting
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`to no more than a few thousand dollars or a few months of free rent—and awards to the
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`managers of bonuses of up to $10,000 for each buyout. When tenants refuse to take a
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`buyout, Croman and his associates resort to an array of illegal methods:
`
`(a) Croman deploys his agents and employees to intimidate, stalk, and
`threaten rent-regulated tenants. Upon purchasing a building, Croman
`dispatches private investigator and former NYPD officer Anthony
`Falconite to conduct “building sweeps” targeting each and every rent-
`regulated tenant in the building. Falconite regularly uses false pretenses to
`get into tenants’ apartments, posing as a repairperson, deliveryman, or
`building manager. Once inside, he accuses the tenants, some of whom
`have lived in their apartments for decades, of illegally occupying the units,
`and threatens them with eviction. Falconite has even stalked tenants—
`visiting them multiple times at their homes, confronting them at work, and
`tracking down friends and family members out-of-state—all for the
`purpose of coercing them into surrendering their apartments.
`
`lawsuits against rent-regulated tenants.
`(b) Croman files frivolous
`Croman intensifies the pressure on besieged tenants by filing baseless
`lawsuits against them (sometimes multiple times against the same tenant),
`requesting repeated adjournments to delay the court process, and then, in
`numerous cases, dropping the suit, only to commence another one shortly
`thereafter. Croman often manufactures a false basis for such lawsuits by
`refusing to deposit tenants’ checks and then suing them for non-payment.
`Even after tenants prevail in these frivolous lawsuits, Croman continues to
`harass them by refusing to deposit their rent checks, charging them
`unlawfully for legal fees, and threatening them with eviction.
`
`into
`turns buildings with rent-regulated apartments
`(c) Croman
`hazardous construction zones. To create as many market-rate units as
`possible in the shortest amount of time, Croman cuts corners during
`renovations, engages in dangerous construction practices, and regularly
`fails to create legally required tenant-protection plans. The slipshod
`construction exacerbates the already substandard conditions of rent-
`regulated apartments, which Croman has deliberately allowed to fall into
`disrepair as part of his tenant harassment tactics. Tenants who reside in the
`buildings during construction must contend with constant and pervasive
`lead-contaminated dust, ceilings collapsing in their children’s bedrooms,
`sewage backflowing through their pipes, and rain pouring through holes in
`the roof. Croman conceals his illegal practices from safety inspectors by
`intentionally failing to secure work permits, flouting stop-work orders, and
`falsely certifying to authorities that his buildings are unoccupied.
`
`(d) Croman uses fraud and subterfuge to elude the government
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`authorities who attempt to hold him accountable for his unlawful
`conduct. Croman’s disregard for his legal obligations as a landlord is near
`absolute. He routinely files false documents with government agencies
`responsible for enforcing building and construction codes and simply
`ignores administrative and judicial orders that demand compliance with
`minimum legal standards.
`
`3.
`
`The Attorney General’s investigation into Croman’s business operations
`
`
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`has confirmed that Respondents engaged in—and continue to perpetuate—an illegal and
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`fraudulent scheme that has victimized hundreds of tenants, pushed out long-time
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`residents from their homes, and accelerated the loss of affordable housing in New York
`
`City. Respondents’ many violations of city and state law include the following:
`
`(a) Unlawful tenant harassment, 9 N.Y.C.R.R. § 2525.5, N.Y.C. Admin. Code
`§§ 27-2004(a)(48), 27-2005(d);
`
`(b) Deceptive business practices, N.Y. General Business Law § 349, by using
`false pretenses and deception to gain access to tenants’ apartments, filing
`baseless lawsuits against tenants, and serving tenants with false and
`deceptive rent demands and eviction threats;
`
`(c) Illegal construction practices, N.Y.C. Construction Codes, N.Y.C. Admin.
`Code § 28-105.1 et seq., by routinely working without permits, violating
`stop-work orders, preventing government authorities from inspecting work
`sites, and making false statements to the Department of Buildings;
`
`(d) Violations of city lead-safety laws, N.Y.C. Admin. Code § 27-2056.1 et
`seq.; 28 R.C.N.Y. §§ 11-06(g)(1)(ix)(D), (g)(2)(vii)-(3)(viii)) et seq., by
`failing to protect tenants from lead-paint hazards, violating Department of
`Health orders to abate lead paint, misleading tenants about lead hazards in
`their buildings, and failing to provide tenants with required lead notices;
`
`(e) Violations of the Real Estate Broker Law, N.Y. Real Property Law § 441,
`by conducting tenant buyouts without real-estate brokers’ licenses;
`
`(f) Violations of the Private Investigator Law, N.Y. General Business Law §
`79(1), by demonstrating untrustworthiness and accepting compensation
`that is tied to the outcome of the investigation;
`
`(g) Fraud, N.Y. Exec. Law § 63(12), by filing false instruments with the
`Department of Buildings, filing baseless lawsuits against tenants, serving
`tenants with false rent and eviction notices, and using false pretenses to
`gain access to tenants’ apartments; and
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`(h) Violations of security deposit laws, 9 N.Y.C.R.R. § 2525.4, N.Y. Gen.
`Obligations § 7-103, by failing to place tenants’ security deposits in trust
`accounts, commingling tenants’ security deposits with the companies’
`general funds, and unlawfully refusing to return security deposits to
`tenants.
`
`PARTIES
`
`4.
`
`Petitioner is the People of the State of New York, by its attorney, Eric T.
`
`Schneiderman, the Attorney General of the State of New York.
`
`5.
`
`Respondent Steven Croman (or “Croman”) is an individual residing in
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`New York City.
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`6.
`
`Croman is the president, founder, and sole owner of Respondent Croman
`
`Real Estate Inc. and the Chief Executive Officer of Respondents 9300 Realty Inc. and
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`9300 Realty Management Inc.
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`7.
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`Croman also exercises control over each special-purpose entity described
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`in paragraphs 11-101 below (collectively, the “Landlord LLCs”).
`
`8.
`
`Respondent Croman Real Estate Inc. is a domestic corporation with its
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`principal office and place of business at 632 Broadway in New York City, from which it
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`has transacted business at all times mentioned herein.
`
`(a) Croman Real Estate is a real-estate brokerage licensed under New York
`
`law.
`
`(b) Steven Croman is a licensed associate broker affiliated with Croman Real
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`Estate.
`
`9.
`
`Respondent 9300 Realty Inc. is a domestic corporation with its principal
`
`office and place of business in New York City, from which it has transacted business at
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`all times mentioned herein.
`
`(a) 9300 Realty Inc. advertises on its website that its “brokerage team” can
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`help renters find apartments in “buildings [that] have undergone extensive
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`renovations.”
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`(b) 9300 Realty Inc. is not a licensed real-estate brokerage.
`
`10.
`
`Respondent 9300 Realty Management Inc. is a domestic corporation with
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`its principal office and place of business in New York City, from which it has transacted
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`business at all times mentioned herein. 9300 Realty Management Inc. is a wholly owned
`
`subsidiary of 9300 Realty Inc. 9300 Realty Management Inc. is the employer of the
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`property managers for Steven Croman’s apartment buildings.
`
`11.
`
`Respondent Anthony Falconite (or “Falconite”) is an individual residing in
`
`New York City.
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`(a) Falconite holds a private investigator license issued by the New York
`
`Department of State Division of Licensing Services.
`
`(b) Falconite is a licensed real estate salesperson affiliated with Croman Real
`
`Estate.
`
`12.
`
`Respondent Falconite LLC is a domestic limited liability company with its
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`principal office and place of business in New York City, from which it has transacted
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`business at all times mentioned herein.
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`(a) Falconite is the president and founder of Respondent Falconite LLC.
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`(b) Anthony Falconite is Falconite LLC’s only employee.
`
`13.
`
`Respondent 3-5 West 103rd LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 3-5 West 103rd LLC has transacted business from its principal office and was the
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`owner of the real property located at 3 and 5 West 103rd Street, New York, New York.
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`14.
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`Respondent 7 East 75 LLC is a domestic limited liability company with its
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`principal office and place of business in New York City. At all times mentioned herein, 7
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`East 75 LLC has transacted business from its principal office and was the owner of the
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`real property located at 7 East 75th Street, New York, New York.
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`15.
`
`Respondent 9 West 103rd LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
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`herein, 9 West 103rd LLC has transacted business from its principal office and was the
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`owner of the real property located at 9 West 103rd Street, New York, New York.
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`16.
`
`Respondent 15 West 103rd LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 15 West 103rd LLC has transacted business from its principal office and was the
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`owner of the real property located at 15 West 103rd Street, New York, New York.
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`17.
`
`Respondent 17 West 103rd LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
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`herein, 17 West 103rd LLC has transacted business from its principal office and was the
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`owner of the real property located at 17 West 103rd Street, New York, New York.
`
`18.
`
`Respondent 40 Avenue B LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 40 Avenue B LLC has transacted business from its principal office and was the
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`owner of the real property located at 40 Avenue B, New York, New York.
`
`19.
`
`Respondent 44 Ave B LLC is a domestic limited liability company with its
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`principal office and place of business in New York City. At all times mentioned herein,
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`44 Ave B LLC has transacted business from its principal office and was the owner of the
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`real property located at 44 Avenue B, New York, New York.
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`20.
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`Respondent 44 East 1st LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
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`herein, 44 East 1st LLC has transacted business from its principal office and was the
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`owner of the real property located at 44 East 1st Street, New York, New York.
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`Respondent 102 East 7th St LLC is a domestic limited liability company with its principal
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`office and place of business in New York City. At all times mentioned herein, 102 East
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`7th St LLC has transacted business from its principal office and was the owner of the real
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`property located at 102 East 7th Street, New York, New York.
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`21.
`
`Respondent 60 Avenue B LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
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`herein, 60 Avenue B LLC has transacted business from its principal office and was the
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`owner of the real property located at 60 Avenue B, New York, New York.
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`22.
`
`Respondent 68 Clinton Street LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
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`herein, 68 Clinton Street LLC has transacted business from its principal office and was
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`the owner of the real property located at 68 Clinton Street, New York, New York.
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`23.
`
`Respondent 72 West 108th Associates LLC is a domestic limited liability
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`company with its principal office and place of business in New York City. At all times
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`mentioned herein, 72 West 108th Associates LLC has transacted business from its
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`principal office and was the owner of the real property located at 72 West 108th Street,
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`New York, New York.
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`24.
`
`Respondent 99-105 Third Avenue Realty LLC is a domestic limited
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`liability company with its principal office and place of business in New York City. At all
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`times mentioned herein, 99-105 Third Avenue Realty LLC has transacted business from
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`its principal office and was the owner of the real property located at 99 3rd Avenue, New
`
`York, New York.
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`25.
`
`Respondent 115 Ave A LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
`
`herein, 115 Ave A LLC has transacted business from its principal office and was the
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`owner of the real property located at 115 Avenue A, New York, New York.
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`26.
`
`Respondent 115 Mulberry LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
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`herein, 115 Mulberry LLC has transacted business from its principal office and was the
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`owner of the real property located at 115 Mulberry Street, New York, New York.
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`27.
`
`Respondent 118 East 7 LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
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`herein, 118 East 7 LLC has transacted business from its principal office and was the
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`owner of the real property located at 118 East 7th Street, New York, New York.
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`28.
`
`Respondent 120-120½ First LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
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`herein, 120-120½ First LLC has transacted business from its principal office and was the
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`owner of the real property located at 120 and 120½ First Avenue, New York, New York.
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`29.
`
`Respondent 124 Ridge LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
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`herein, 124 Ridge LLC has transacted business from its principal office and was the
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`owner of the real property located at 124 Ridge Street, New York, New York.
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`30.
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`Respondent 127 East 7th Street LLC is a domestic limited liability
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`company with its principal office and place of business in New York City. At all times
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`mentioned herein, 127 East 7th Street LLC has transacted business from its principal
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`office and was the owner of the real property located at 127 East 7th Street, New York,
`
`New York.
`
`31.
`
`Respondent 134 Orchard LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
`
`herein, 134 Orchard LLC has transacted business from its principal office and was the
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`owner of the real property located at 134 Orchard Street, New York, New York.
`
`32.
`
`Respondent 138 East 16th Street LLC is a domestic limited liability
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`company with its principal office and place of business in New York City. At all times
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`mentioned herein, 138 East 16th Street LLC has transacted business from its principal
`
`office and was the owner of the real property located at 138 East 16th Street, New York,
`
`New York.
`
`33.
`
`Respondent 145 E 26 LLC is a domestic limited liability company with its
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`principal office and place of business in New York City. At all times mentioned herein,
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`145 E 26 LLC has transacted business from its principal office and was the owner of the
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`real property located at 145 East 26th Street, New York, New York.
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`34.
`
`Respondent 159-161 Stanton LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 159-161 Stanton LLC has transacted business from its principal office and was
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`the owner of the real property located at 159 and 161 Stanton Street, New York, New
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`York.
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`35.
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`Respondent 171 East 102nd LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 171 East 102nd LLC has transacted business from its principal office and was the
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`owner of the real property located at 171 East 102nd Street, New York, New York.
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`36.
`
`Respondent 179-181 Essex LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
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`herein, 179-181 Essex LLC has transacted business from its principal office and was the
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`owner of the real property located at 179 Essex Street, New York, New York.
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`37.
`
`Respondent 182 Stanton LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
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`herein, 182 Stanton LLC has transacted business from its principal office and was the
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`owner of the real property located at 182 and 184 Stanton Street, New York, New York.
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`38.
`
`Respondent 193-195 Stanton LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
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`herein, 193-195 Stanton LLC has transacted business from its principal office and was
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`the owner of the real property located at 193 and 195 Stanton Street, New York, New
`
`York.
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`39.
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`Respondent 199 East 3rd St LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
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`herein, 199 East 3rd St LLC has transacted business from its principal office and was the
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`owner of the real property located at 199 and 201 East 3rd Street, New York, New York.
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`40.
`
`Respondent 200 Stanton LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
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`herein, 200 Stanton LLC has transacted business from its principal office and was the
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`owner of the real property located at 200 Stanton Street, New York, New York and 139,
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`141, and 143 Ridge Street, New York, New York.
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`41.
`
`Respondent 206 East 83rd LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
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`herein, 206 East 83rd LLC has transacted business from its principal office and was the
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`owner of the real property located at 206 East 83rd Street, New York, New York.
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`42.
`
`Respondent 208-214 E 25th St LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
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`herein, 208-214 E 25th St LLC has transacted business from its principal office and was
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`the owner of the real property located at 208, 210, 212, and 214 E 25th Street, New York,
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`New York.
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`43.
`
`Respondent 209 E 25 LLC is a domestic limited liability company with its
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`principal office and place of business in New York City. At all times mentioned herein,
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`209 E 25 LLC has transacted business from its principal office and was the owner of the
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`real property located at 209 East 25th Street, New York, New York.
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`44.
`
`Respondent 212-214 East 105 LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
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`herein, 212-214 East 105 LLC has transacted business from its principal office and was
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`the owner of the real property located at 212 and 214 East 105th Street, New York, New
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`York.
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`45.
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`Respondent 213 E 26 LLC is a domestic limited liability company with its
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`principal office and place of business in New York City. At all times mentioned herein,
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`213 E 26 LLC has transacted business from its principal office and was the owner of the
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`real property located at 213 East 26th Street, New York, New York.
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`46.
`
`Respondent 215 Avenue B Realty LLC is a domestic limited liability
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`company with its principal office and place of business in New York City. At all times
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`mentioned herein, 215 Avenue B Realty LLC has transacted business from its principal
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`office and was the owner of the real property located at 147 Avenue A, New York, New
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`York.
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`47.
`
`Respondent 218 A LLC is a domestic limited liability company with its
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`principal office and place of business in New York City. At all times mentioned herein,
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`218 A LLC has transacted business from its principal office and was the owner of the real
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`property located at 218 Avenue A, New York, New York.
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`48.
`
`Respondent 219 East 28 LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
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`herein, 219 East 28 LLC has transacted business from its principal office and was the
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`owner of the real property located at 219 East 28th Street, New York, New York.
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`49.
`
`Respondent 227 E 82 LLC is a domestic limited liability company with its
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`principal office and place of business in New York City. At all times mentioned herein,
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`227 E 82 LLC has transacted business from its principal office and was the owner of the
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`real property located at 227 East 82nd Street, New York, New York.
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`50.
`
`Respondent 228-230 E 32nd LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
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`herein, 228-230 E 32nd LLC has transacted business from its principal office and was the
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`owner of the real property located at 228 and 230 East 32nd Street, New York, New York.
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`51.
`
`Respondent 232 Elizabeth LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 232 Elizabeth LLC has transacted business from its principal office and was the
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`owner of the real property located at 232 and 234 Elizabeth Street, New York, New York.
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`52.
`
`Respondent 232 W 14th LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
`
`herein, 232 W 14th LLC has transacted business from its principal office and was the
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`owner of the real property located at 232 West 14th Street, New York, New York.
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`53.
`
`Respondent 234-236 W 14th LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 234-236 W 14th LLC has transacted business from its principal office and was the
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`owner of the real property located at 234 and 236 West 14th Street, New York, New
`
`York.
`
`54.
`
`Respondent 257 Bleecker LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 257 Bleecker LLC has transacted business from its principal office and was the
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`owner of the real property located at 257 Bleecker Street, New York, New York.
`
`55.
`
`Respondent 277 E 10th LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
`
`herein, 277 E 10th LLC has transacted business from its principal office and was the
`
`owner of the real property located at 277 East 10th Street, New York, New York.
`
`56.
`
`Respondent 290 W 12 LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
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`herein, 290 W 12 LLC has transacted business from its principal office and was the
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`owner of the real property located at 290, 292, and 294 West 12th Street, New York, New
`
`York.
`
`57.
`
`Respondent 309 West 97 LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 309 West 97 LLC has transacted business from its principal office and was the
`
`owner of the real property located at 309 West 97th Street, New York, New York.
`
`58.
`
`Respondent 314 E 106 LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
`
`herein, 314 E 106 LLC has transacted business from its principal office and was the
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`owner of the real property located at 314 East 106th Street, New York, New York.
`
`59.
`
`Respondent 321 East 10th LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 321 East 10th LLC has transacted business from its principal office and was the
`
`owner of the real property located at 321 East 10th Street, New York, New York.
`
`60.
`
`Respondent 321 W. 16th LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
`
`herein, 321 W. 16th LLC has transacted business from its principal office and was the
`
`owner of the real property located at 321 West 16th Street, New York, New York.
`
`61.
`
`Respondent 325 E 5th LLC is a domestic limited liability company with its
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`principal office and place of business in New York City. At all times mentioned herein,
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`325 E 5th LLC has transacted business from its principal office and was the owner of the
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`real property located at 325 East 5th Street, New York, New York.
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`62.
`
`Respondent 326 E 35th LLC is a domestic limited liability company with
`
`its principal office and place of business in New York City. At all times mentioned
`
`herein, 326 E 35th LLC has transacted business from its principal office and was the
`
`owner of the real property located at 326 East 35th Street, New York, New York.
`
`63.
`
`Respondent 326-338 E 100th LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 326-338 E 100th LLC has transacted business from its principal office and was the
`
`owner of the real property located at 326, 330, 332, 338, and 340 East 100th Street, New
`
`York, New York.
`
`64.
`
`Respondent 334 E 6th LLC is a domestic limited liability company with its
`
`principal office and place of business in New York City. At all times mentioned herein,
`
`334 E 6th LLC has transacted business from its principal office and was the owner of the
`
`real property located at 334 East 6th Street, New York, New York.
`
`65.
`
`Respondent 343 East 8th LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
`
`herein, 343 East 8th LLC has transacted business from its principal office and was the
`
`owner of the real property located at 343 East 8th Street, New York, New York.
`
`66.
`
`Respondent 345 West 53rd LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 345 West 53rd LLC has transacted business from its principal office and was the
`
`owner of the real property located at 345 West 53rd Street, New York, New York.
`
`67.
`
`Respondent 343-345 E. 5th St LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 343-345 E. 5th St LLC has transacted business from its principal office and was
`
`the owner of the real property located at 343 and 345 East 5th Street, New York, New
`
`York.
`
`68.
`
`Respondent 351-357 West 45 LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 351-357 West 45 LLC has transacted business from its principal office and was
`
`the owner of the real property located at 351, 353, 355, and 357 West 45th Street, New
`
`York, New York.
`
`69.
`
`Respondent 358 W 51 LLC is a domestic limited liability company with
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`its principal office and place of business in New York City. At all times mentioned
`
`herein, 358 W 51 LLC has transacted business from its principal office and was the
`
`owner of the real property located at 358 West 51st Street, New York, New York.
`
`70.
`
`Respondent 380-382 E 10th LLC is a domestic limited liability company
`
`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 380-382 E 10th LLC has transacted business from its principal office and was the
`
`owner of the real property located at 380 and 382 East 10th Street, New York, New York.
`
`71.
`
`Respondent 411 E 12th St LLC is a domestic limited liability company
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`with its principal office and place of business in New York City. At all times mentioned
`
`herein, 411 E 12th St LLC has transacted business from its principal office and was the
`
`owner of the real property located at 411 East 12th Street, New York, New York.
`
`72.
`
`Respondent 420 E. 9th LLC is a domestic limited liability company with
`
`its principal office and place o