throbber
FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 650981/2022
`
`RECEIVED NYSCEF: 03/02/2022
`
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`
`LIMANAKI, INC.,
`
`
`
`
`
`
`
`
`Plaintiff,
`
`-against-
`
`Index No. _____________
`
`
`
` SUMMONS
`
`Plaintiff designates New York County as
`the place of trial.
`Basis of venue is Plaintiff’s place of
`business.
`
`
`
`EL-KAM REALTY CO., EL-KAM 1501-1509,
`LLC and EL-KAM LEXINGTON AVE, LLC.
`
`
`
`
`
`Defendant(s).
`
`
`
`
`
`TO THE ABOVE-NAMED DEFENDANTS:
`
`
`
`You are hereby summoned to answer the complaint in this action and to serve a copy of your
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`answer, or, if the complaint is not served with this summons, to serve a notice of appearance, on
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`plaintiffs’ attorney within twenty (20) days after the service of this summons exclusive of the day of
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`service (or within thirty (30) days after the service is complete if this summons is not personally
`
`delivered to you within the State of New York); and in case of your failure to appear or answer,
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`judgement will be taken against you by default for the relief demanded in the complaint.
`
`
`Dated: New York, New York
`
`March 1, 2022
`
`
`
`
`
`
`By:
`
`
`
`
`
`
`
`
` /s/ Louis V. Fasulo
`Louis V. Fasulo, Esq.
`FASULO BRAVERMAN & DIMAGGIO, LLP
`225 Broadway, Suite 715
`New York, New York 10007
`(212)566-6213
`lfasulo@fbdmlaw.com
`
`
`
`Page 1 of 2
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`1 of 15
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 650981/2022
`
`RECEIVED NYSCEF: 03/02/2022
`
`
`
`EL-KAM 1501-1509, LLC
`3 West 57th Street
`New York, New York 10019
`c/o Hakim Organization
`
`TO: EL-KAM REALTY CO.
`
`3 West 57th Street
`
`New York, New York 10019
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`EL-KAM LEXINGTON AVE, LLC
`3 West 57th Street
`New York, New York 10019
`c/o Hakim Organization
`
`
`
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`Page 2 of 2
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`2 of 15
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 650981/2022
`
`RECEIVED NYSCEF: 03/02/2022
`
`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`
`LIMANAKI, INC.,
`
`
`
`
`
`
`
`
`Plaintiff,
`
`-against-
`
`Index No. _____________
`
`
`
` VERIFIED COMPLAINT
`
`
`
`
`
`
`
`
`EL-KAM REALTY CO., EL-KAM 1501-1509,
`LLC and EL-KAM LEXINGTON AVE, LLC.
`
`
`
`
`
`Defendant(s).
`
`
`
`
`
`Plaintiff, LIMANAKI, INC., by and through its attorneys, FASULO BRAVERMAN &
`
`DIMAGGIO, LLP, complaining of defendants, EL-KAM REALTY CO., EL-KAM 1501-1509,
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`LLC and EL-KAM LEXINGTON AVE, LLC, alleges as follows:
`
`NATURE OF THE ACTION
`
`1.
`
`Defendants own and operate a mixed-use building located in Yorkville neighborhood of
`
`Manhattan. Plaintiff began leasing the bottom floor commercial unit from Defendants in
`
`approximately March 2021 to operate a restaurant business.
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`2.
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`Since taking the lease, Plaintiff has expended over $130,000 to build out the space to operate
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`the restaurant on the understanding that gas utility was operational at the time of entering into the
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`lease. Plaintiff later learned, however, that gas utility service had been suspended by Consolidated
`
`Edison, Inc. (“Con Ed”) in approximately July 2020 (which such information was withheld from
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`Plaintiff at the time of entering into the lease). When Plaintiff attempted to restore gas service to the
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`premises in approximately July 2021, Plaintiff learned that a major gas utility upgrade was necessary
`
`to restore service.
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`3.
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`Defendants, who were immediately put on notice of the issue, have entirely failed to act and
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`have failed perform the necessary utility upgrades.
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`
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 650981/2022
`
`RECEIVED NYSCEF: 03/02/2022
`
`
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`4.
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`Plaintiff brings this action for a mandatory permanent injunction requiring Defendants to
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`perform all work necessary to restore gas service to the premises, together with an award of damages
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`in favor of Plaintiffs for Defendants negligence, breach of contract, fraud in the inducement and an
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`abatement of rent, inter alia.
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`PARTIES, JURISDICTION, AND VENUE
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`5.
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`Plaintiff Limanaki, Inc. is a New York corporation formed and existing under the laws of the
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`State of New York, with its principal place of business located in New York County.
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`6.
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`Upon information and belief, Defendant El-Kam Realty Co. is a New York partnership
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`formed and existing under the laws of the State of New York with its principal place of business
`
`located in New York County.
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`7.
`
`Upon information and belief, Defendant El-Kam 1501-1509, LLC is a limited liability
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`company formed and existing under the laws of the State of New York with its principal place of
`
`business located in New York County.
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`8.
`
`Upon information and belief, Defendant El-Kam Lexington Ave, LLC is a limited liability
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`company formed and existing under the laws of the State of New York with its principal place of
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`business located in New York County.
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`9.
`
`Upon information and belief, Defendants own a mixed-use building located at 1748 First
`
`Avenue, New York, New York (the “Building”).
`
`FACTS
`
`10.
`
`On or about March 1, 2021, Plaintiff and Defendants entered into a 10-year commercial lease
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`agreement for the bottom floor commercial unit of the Building and a portion of the basement area to
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`operate a restaurant business (the “Premises”).
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`11.
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`Prior to entering into the lease, Defendants, or their representatives, agents or assigns,
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`
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
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`INDEX NO. 650981/2022
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`RECEIVED NYSCEF: 03/02/2022
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`
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`represented to Plaintiff that gas utility service to the Premises was in good working order.
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`12.
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`At the time this statement was made, the agent knew that the gas service had been turned off
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`and that the gas pipes were insufficient to supply gas to the premise.
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`13.
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`At the time the statement was made, the agent intended that the Plaintiff rely on this statement
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`so as to induce them to enter the lease.
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`14.
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`The Plaintiff, justifiably relied on this inducement to enter the lease.
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`15.
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`Rely on this and other representations, Plaintiff entered into the lease agreement and began
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`making substantial and costly repairs and upgrades to the Premises in order to operate its restaurant
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`business.
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`16.
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`From approximately March 2021 to date, Plaintiff has expended no less than $130,000 in
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`making repairs and upgrades to the Premises, including significant upgrades to the kitchen area.
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`17.
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`Plaintiff obtained all necessary approvals of Defendants before performing any work as
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`required by the lease agreement, and obtained all necessary New York City and State permits and
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`approvals to preform said work.
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`18.
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`In approximately July 2021, Plaintiff contacted Con Ed to restore gas service to the upgraded
`
`kitchen.
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`19.
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`Con Ed advised Plaintiff that the gas utility service has been disconnected for over one year,
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`and thus there was no gas service at the Premises.
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`20.
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`Con Ed further advised Plaintiff that Con Ed had to inspect the Premises prior to restoring any
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`gas service.
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`21.
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`Plaintiff thereafter, at its sole cost and expense, engaged a plumber and engineer to perform
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`inspections and render engineering drawings necessary to apply for and obtain Department of
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`Building (“DOB”) permits to perform the necessary repairs.
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 650981/2022
`
`RECEIVED NYSCEF: 03/02/2022
`
`
`
`22.
`
`In approximately September 2021, Con Ed performed a re-inspection of the Premises and
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`noted that the certain gas pipelines in the Building were below code and were required to be upgraded
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`to restore gas service to the Premises.
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`23.
`
`Plaintiff immediately notified Defendants of the issue and Defendants performed their own
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`inspection of the gas utility line.
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`24.
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`Thus, since at least October 2021, Defendants were on notice that gas utility lines in the
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`Building were below code and were required to be upgraded to meet DOB standards.
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`25.
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`Defendants thereafter retained their own professionals to perform their own inspection of the
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`Building.
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`26.
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`Despite being on notice of these gross deficiencies in the Building’s utility service,
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`Defendants have entirely failed to act and have failed to perform any work to upgrade the Building’s
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`gas utility line to comply with DOB code.
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`27.
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`Since approximately July 2021, Plaintiff has been wholly unable to operate its restaurant
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`business at the Premises due to Defendants’ breach of the lease agreement and gross negligence in its
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`maintenance of the Building.
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`28.
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`Defendants’ breach of lease and gross negligence in this regard has rendered the lease
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`agreement and Premises useless to Plaintiff.
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`29.
`
`Plaintiff simply cannot operate a restaurant business until gas service is restored to the
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`Premises, and gas service will not be restored until Defendants make all necessary repairs and
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`upgrades to the Building as required by the New York City Department of Buildings and Con Ed.
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`AS AND FOR A FIRST CAUSE OF ACTION
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`(Breach of Contract - Injunction)
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`30.
`
`Plaintiff, repeats and reiterates each and every allegation of the complaint, in paragraphs
`
`
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 650981/2022
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`RECEIVED NYSCEF: 03/02/2022
`
`
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`number “1 through 29” with the same force and effect as if herein set forth at length.
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`31.
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`Plaintiff and Defendants entered into a valid written lease agreement dated March 1, 2022.
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`32.
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`Plaintiff has paid the required security deposit as per the lease.
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`33.
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`Plaintiff has withheld rent from September 2021 up to and including to present.
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`34.
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`Plaintiff has withheld held because of the Defendant’s failure to correct the gas pipes so as to
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`allow gas service to the restaurant. Plaintiff has otherwise substantially complied with all terms of the
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`lease agreement.
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`35.
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`Plaintiff seeks an abatement for such time from September 2021 up to and including until the
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`gas pipes can be upgraded to allow the service of gas.
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`36.
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`Defendants have breached the lease agreement by failing to properly maintain utility service
`
`to the Building.
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`37.
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`By Defendants breach, Plaintiff has suffered damages because it has not been able to open
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`and operate its business since at least July 2021.
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`38.
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`Plaintiff will continue to stuffer damages each and every day they are unable to open and
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`operate its business.
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`39.
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`By way of the foregoing, Plaintiff is entitled to a permanent mandatory injunction requiring
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`Defendants to perform all work necessary to the Building to restore gas service to the Premises, in
`
`compliance with all local, state or federal rules, laws, codes and or standards.
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`AS AND FOR A SECOND CAUSE OF ACTION
`
`(Breach of Contract - Damages)
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`40.
`
`Plaintiff, repeats and reiterates each and every allegation of the complaint, in paragraphs
`
`number “1 through 39” with the same force and effect as if herein set forth at length.
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`41.
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`Plaintiff and Defendants entered into a valid written lease agreement dated March 1, 2022.
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 650981/2022
`
`RECEIVED NYSCEF: 03/02/2022
`
`
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`42.
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`Plaintiff has paid the required security deposit as per the lease.
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`43.
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`Plaintiff has withheld rent from September 2021 up to and including to present.
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`44.
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`Plaintiff has withheld held because of the Defendant’s failure to correct the gas pipes so as to
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`allow gas service to the restaurant.
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`45.
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`Plaintiff seeks an abatement for such time from September 2021 up to and including until the
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`gas pipes can be upgraded to allow the service of gas.
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`46.
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`Defendants have breached the lease agreement by failing to properly maintain utility service
`
`to the Building.
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`47.
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`By Defendants breach, Plaintiff has suffered damages because it has not been able to open
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`and operate its business since at least July 2021.
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`48.
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`Plaintiff will continue to stuffer damages each and every day they are unable to open and
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`operate its business.
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`49.
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`By way of the foregoing, Plaintiff is entitled to an award of damages in an amount to
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`determined at trial but no less than $50,000.
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`AS AND FOR A THIRD CAUSE OF ACTION
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`(Negligence - Injunction)
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`50.
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`Plaintiff, repeats and reiterates each and every allegation of the complaint, in paragraphs
`
`number “1 through 49” with the same force and effect as if herein set forth at length.
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`51.
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`As owner of the Building, Defendants owed a duty of care to properly upkeep and maintain
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`the Building consistent with all local, state and federal laws, rules, codes, regulations and standards.
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`52.
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`Defendants breached its duty of care by failing to properly maintain the Building’s utility
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`service, in violation of certain local, state and federal laws, rules, codes, standards and regulations.
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`53.
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`Because of Defendants’ negligence, Plaintiff have suffered significant damages in that they
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`Page 6 of 13
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`8 of 15
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 650981/2022
`
`RECEIVED NYSCEF: 03/02/2022
`
`
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`have been unable to open and operate their business since at least July 2021, among other things.
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`54.
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`Plaintiff will continue to stuffer damages each and every day they are unable to open and
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`operate its business.
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`55.
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`By way of the foregoing, Plaintiff is entitled to a permanent mandatory injunction requiring
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`Defendants to perform all work necessary to the Building to restore gas service to the Premises, in
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`compliance with all local, state or federal rules, laws, codes and or standards.
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`AS AND FOR A FORTH CAUSE OF ACTION
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`(Negligence - Damages)
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`56.
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`Plaintiff, repeats and reiterates each and every allegation of the complaint, in paragraphs
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`number “1 through 55” with the same force and effect as if herein set forth at length.
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`57.
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`As owner of the Building, Defendants owed a duty of care to properly upkeep and maintain
`
`the Building consistent with all local, state and federal laws, rules, codes, regulations and standards.
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`58.
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`Defendants breached its duty of care by failing to properly maintain the Building’s utility
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`service, in violation of certain local, state and federal laws, rules, codes, standards and regulations.
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`59.
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`Because of Defendants’ negligence, Plaintiff have suffered significant damages in that they
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`have been unable to open and operate their business since at least July 2021, among other things.
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`60.
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`Plaintiff will continue to stuffer damages each and every day they are unable to open and
`
`operate its business.
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`61.
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`By way of the foregoing, Plaintiff is entitled to an award of damages in an amount to be
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`determined at trial but no less than $50,000.
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`Page 7 of 13
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 650981/2022
`
`RECEIVED NYSCEF: 03/02/2022
`
`
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`AS AND FOR A FIFTH CAUSE OF ACTION
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`(Fraud in the inducement)
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`62.
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`Plaintiff, repeats and reiterates each and every allegation of the complaint, in paragraphs
`
`number “1 through 61” with the same force and effects as if herein set forth at length.
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`63.
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`That an agent of the defendant acted as a broker for the above mentioned property.
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`64.
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`That, Plaintiff and this Agent explicitly discussed whether there was a current gas service
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`within this building.
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`65.
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`That, the Plaintiff explicitly asked whether the gas was sufficient to operate the restaurant.
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`66.
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`That, the agent, knowing the Plaintiff would not enter into the lease without an appropriate
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`gas service, stated that the service was sufficient and available to operate the restaurant.
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`67.
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`That, the plaintiff did in fact rely on this representation.
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`68.
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`That, it was in fact reasonable for the Plaintiff to rely on this representation.
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`69.
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`That, when this representation was made, the purpose of the agent was to induce the Plaintiff
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`into entering the lease agreement.
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`70.
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`That, upon relying on the representation, the Plaintiff entered the lease agreement.
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`71.
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`That, upon taking possession of the premise, the Plaintiff did not immediately initiate gas
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`service.
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`72.
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`That, the Plaintiff instead invested at least 130,000 dollars into improving the leased property
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`and installing all new appliances.
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`73.
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`That, the Plaintiff attempted to initiate gas service through Con Edison in or around July 2021.
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`74.
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`That, Con Edison told the Plaintiff that Gas service had been shut off at least 1 year prior to
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`the Plaintiff taking possession of the property.
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`75.
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`That the Plaintiff, with reasonable diligence, could not have discovered this issue until an
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`Page 8 of 13
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
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`INDEX NO. 650981/2022
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`RECEIVED NYSCEF: 03/02/2022
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`attempt to initiate gas service through Con Edison
`
`
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`76.
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`That, In order to restart this service, Con Edison would have to inspect the premise.
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`77.
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`That, in or around July 2021, the Plaintiff, at their own expense, contacted a plumber and an
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`engineer to inspect the premise.
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`78.
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`That the aforementioned engineer did draft drawings for new pipes.
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`79.
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`That in or around July 2021, the aforementioned drawings were submitted to the building
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`department for licensing.
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`80.
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`That, in or around, September 2021, a Con Edison engineer came to inspect the premise and
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`Gas Pipes.
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`81.
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`That, upon inspection, the aforementioned engineer did in fact inspect the premise.
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`82.
`
`That the engineer was shocked to find a previously unknown water boiler blocking the gas
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`pipes.
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`83.
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`That the engineer found that the gas pipes were not only inadequate to service the restaurant
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`but in fact were inadequate to service the entire building.
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`84.
`
`That the engineer found that the gas pipes for the entire building would have to be upgraded
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`as they fell below the standard required by the city.
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`85.
`
`That the Defendant had to upgrade these pipes in order to conform with the City’s code.
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`86.
`
`That the Defendant was aware that these pipes were not up to code.
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`87.
`
`That the Defendant was aware that they had placed a water boiler on top of the gas pipes.
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`88.
`
`That the Defendant did not inform Con Edison nor did they inform the Plaintiff that there was
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`in fact a water boiler on top of the pipes.
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`89.
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`That the Defendant was aware that gas service had been shut off for at least 1 year prior to the
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`Plaintiff taking possession.
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`Page 9 of 13
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`11 of 15
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 650981/2022
`
`RECEIVED NYSCEF: 03/02/2022
`
`
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`90.
`
`That the agent of the Defendant was aware that gas service had been shut off for at least 1
`
`year prior to the Plaintiff taking possession.
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`91.
`
`That both the agent and Defendant failed to inform the Plaintiff of this fact.
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`92.
`
`That the Plaintiff has made numerous attempts to contact the Defendant about correcting the
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`pipes.
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`93.
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`That as to the date of writing, the Defendant has still not corrected the pipes.
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`94.
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`That it is because of this misrepresentation as to the service of gas and the failure to correct
`
`the pipes, that the Plaintiff has been unable to open and operate their restaurant.
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`95.
`
`That, because the Defendant has failed to correct this issue, they are liable for all of the harm
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`caused to the Plaintiff.
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`96.
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`By way of the foregoing, Plaintiff is to be awarded an amount of damages to be determined
`
`at trial which is no less than 50,000 and costs, disbursements and reasonable attorney fees as well as
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`statutory interest from July 2021 to present.
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`
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 650981/2022
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`RECEIVED NYSCEF: 03/02/2022
`
`
`
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`WHEREFORE, Plaintiff hereby demands judgement as follows:
`
`PRAYER FOR RELIEF
`
`(a)
`
`On the first cause of action, Plaintiff is entitled to a permanent mandatory injunction requiring
`
`Defendants to perform all work necessary to the Building to restore gas service to the Premises, in
`
`compliance with all local, state or federal rules, laws, codes and or standards;
`
`(b)
`
`On the second cause of action, Plaintiff is entitled to an award of damages in an amount to
`
`determined at trial but no less than $50,000;
`
`(c)
`
`On the third cause of action, Plaintiff is entitled to a permanent mandatory injunction requiring
`
`Defendants to perform all work necessary to the Building to restore gas service to the Premises, in
`
`compliance with all local, state or federal rules, laws, codes and or standards.
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`(d)
`
`On the forth cause of action, Plaintiff is entitled to an award of damages in an amount to
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`determined at trial but no less than $50,000;
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`(e)
`
`On the fifth cause of action, Plaintiff is entitled to an award of damages to be determined at
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`trial which is no less than 50,000 and costs, disbursements and reasonable attorney fees as well as
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`statutory interest from July 2021 to present.;
`
`(f)
`
`In conjunction with all of the above, Plaintiff is entitled to an abatement of rent from the period
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`of September 2021 up to and including until the Defendants corrects the gas pipes; and
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`(g) Awarding such other and further relief as this Court deems just and proper.
`
`
`Dated: March 1, 2022
`
`New York, New York
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 650981/2022
`
`RECEIVED NYSCEF: 03/02/2022
`
`
`
`
`
`
`
`
`By:
`
`
`
`
`
`
`
`
` /s/ Louis V. Fasulo
`Louis V. Fasulo, Esq.
`FASULO BRAVERMAN & DIMAGGIO, LLP
`225 Broadway, Suite 715
`New York, New York 10007
`(212)566-6213
`lfasulo@fbdmlaw.com
`
`Page 12 of 13
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`FILED: NEW YORK COUNTY CLERK 03/02/2022 04:10 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 650981/2022
`
`RECEIVED NYSCEF: 03/02/2022
`
`VERIFICATION
`
`State
`
`of New York
`
`:
`
`} ss:
`
`County
`
`of Manhattan
`
`:
`
`I, Evangelos
`
`Vamvakoulas
`
`being
`
`duly
`
`sworn,
`
`deposes
`
`and
`
`says
`
`that
`
`I have
`
`read
`
`the above
`
`Complaint
`
`and
`
`know
`
`the
`
`contents
`
`thereof,
`
`that
`
`the
`
`same
`
`is true
`
`to my own
`
`knowledge,
`
`except
`
`as
`
`to those
`
`stated
`
`to be upon
`
`information
`
`and
`
`belief,
`
`and
`
`as to those matters,
`
`I believe
`
`them to be
`
`true.
`
`Evangelos
`
`Vamvakoulas
`
`Sworn
`
`to before
`
`me this
`
`t(
`
`day
`
`of February,
`
`2022.
`
`LIU YAOYU
`Notary Public, State of New York
`Q
`d n
`Coronnumun Expires
`
`n4
`uly 10, 2
`
`15 of 15
`
`

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