FILED: NEW YORK COUNTY CLERK 03/04/2021 11:32 AM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 651486/2021
`
`RECEIVED NYSCEF: 03/05/2021
`
`SUMMONS
`
`Index No.
`
`STATE OF NEW YORK
`SUPREME COURT
`
` COUNTY OF NEW YORK
`
`EVEREST NATIONAL INSURANCE COMPANY,
`
`Plaintiff,
`
`-vs-
`
`NEW YORK CONSTRUCTION & RENOVATION, INC.,
`DAJ REALTY, LLC, 37 CROSBY REALTY, LLC,
`ENGINEERING GROUP ASSOCIATES, P.C., GENNADY
`SARATOVSKY P.E., INTEGRITY CONSULTING
`SERVICE, INC., ALEKSANDER LEVIN P.E., BRENT M.
`PORTER ARCHITECTS AND ASSOCIATES, BRENT M.
`PORTER ARCHITECT, PLLC, BRENT PORTER R.A.,
`ASPEN AMERICAN INSURANCE CO. a/s/o DAJ
`REALTY, 35 1/2 CROSBY STREET REALTY CORP.,
`WALTER SEDOVIC ARCHITECT, P.C., YORAM
`FINKELSTEIN, FLAGSTAFF1, LLC, ICON REALTY
`MANAGEMENT, LLC, and T&T REALTY
`MANAGEMENT, LLC,
`
`Defendants.
`
`TO: New York Construction & Renovation, Inc.
`992 Coney Island Avenue
`Brooklyn, New York 11230
`
`DAJ Realty, LLC
`150 East 58th Street
`New York, New York 10155
`
`37 Crosby Realty LLC
`419 Lafayette Street, 5th Floor
`New York, New York 10003
`
`Engineering Group Associates, P.C.
`45 East 20th Street, 6th Floor
`New York, New York 10003
`
`Gennady Saratovsky, P.E.
`45 East 20th Street, 6th Floor
`New York, New York 10003
`
`21741327.2
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`NYSCEF DOC. NO. 1
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`INDEX NO. 651486/2021
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`RECEIVED NYSCEF: 03/05/2021
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`SUMMONS
`
`Index No.
`
`STATE OF NEW YORK
`SUPREME COURT
`
` COUNTY OF NEW YORK
`
`EVEREST NATIONAL INSURANCE COMPANY,
`
`Plaintiff,
`
`-vs-
`
`NEW YORK CONSTRUCTION & RENOVATION, INC.,
`DAJ REALTY, LLC, 37 CROSBY REALTY, LLC,
`ENGINEERING GROUP ASSOCIATES, P.C., GENNADY
`SARATOVSKY P.E., INTEGRITY CONSULTING
`SERVICE, INC., ALEKSANDER LEVIN P.E., BRENT M.
`PORTER ARCHITECTS AND ASSOCIATES, BRENT M.
`PORTER ARCHITECT, PLLC, BRENT PORTER R.A.,
`ASPEN AMERICAN INSURANCE CO. a/s/o DAJ
`REALTY, 35 1/2 CROSBY STREET REALTY CORP.,
`WALTER SEDOVIC ARCHITECT, P.C., YORAM
`FINKELSTEIN, FLAGSTAFF1, LLC, ICON REALTY
`MANAGEMENT, LLC, and T&T REALTY
`MANAGEMENT, LLC,
`
`Defendants.
`
`TO: New York Construction & Renovation, Inc.
`992 Coney Island Avenue
`Brooklyn, New York 11230
`
`DAJ Realty, LLC
`150 East 58th Street
`New York, New York 10155
`
`37 Crosby Realty LLC
`419 Lafayette Street, 5th Floor
`New York, New York 10003
`
`Engineering Group Associates, P.C.
`45 East 20th Street, 6th Floor
`New York, New York 10003
`
`Gennady Saratovsky, P.E.
`45 East 20th Street, 6th Floor
`New York, New York 10003
`
`21741327.2
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`INDEX NO. 651486/2021
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`RECEIVED NYSCEF: 03/05/2021
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`Integrity Consulting Service, Inc.
`443 Arbuckle Avenue
`Cedarhurst, New York 11516
`
`Aleksander Levin, P.E.
`443 Arbuckle Avenue
`Cedarhurst, New York 11516
`
`Brent M. Porter Architects and Associates
`166 St. James Place
`Brooklyn, New York 11238
`
`Brent M. Porter Architect, PLLC
`166 St. James Place
`Brooklyn, New York 11238
`
`Brent Porter, R.A.
`166 St. James Place
`Brooklyn, New York 11238
`
`Aspen American Insurance Company
`175 Capital Boulevard, Suite 300
`Rocky Hill, Connecticut 06067
`
`35 1/2 Crosby Street Realty Corp.
`666 Broadway
`New York, New York 10012
`
`Walter Sedovic Architect, P.C.
`1 Bridge Street, Suite 1
`Irvington, New York 10533
`
`Yoram Finkelstein
`2112 Broadway, Room 204
`New York, New York 10023
`
`Flagstaff1 LLC
`425 N. Broadway, #502
`Jericho, New York 11753
`
`Icon Realty Management LLC
`419 Lafayette Street, 5th Fl.
`New York, New York 10003
`
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`INDEX NO. 651486/2021
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`RECEIVED NYSCEF: 03/05/2021
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`T&T Realty Management LLC
`419 Lafayette St., 5th Fl.
`New York, New York 10003
`
`YOU ARE HEREBY SUMMONED and required to serve upon attorneys for Everest
`
`National Insurance Company an Answer to the Complaint in this action within TWENTY (20)
`
`days after the service of this summons, exclusive of the day of service, or within THIRTY (30)
`
`days after service is complete if service is made by any method other than personal delivery to you
`
`within the State of New York.
`
`If you do not serve an answer to the attached Complaint within the applicable time
`
`limitation stated above, a judgment may be rendered against you, by default, for the relief
`
`demanded in the Complaint.
`
`DATED:
`
`March 4, 2021
`
`BARCLAY DAMON LLP
`
`By:
`
`s/ Sanjeev Devabhakthuni
`Anthony J. Piazza
`Sanjeev Devabhakthuni
`
`
`
`Attorneys for Plaintiff
`Everest National Insurance Company
`Office and Post Office Address
`2000 Five Star Bank Plaza
`100 Chestnut Street
`Rochester, New York 14604
`Telephone: (585) 295-4420
`
`21741327.2
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`INDEX NO. 651486/2021
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`RECEIVED NYSCEF: 03/05/2021
`
`STATE OF NEW YORK
`SUPREME COURT
`
` COUNTY OF NEW YORK
`
`EVEREST NATIONAL INSURANCE COMPANY,
`
`Plaintiff,
`
`-vs-
`
`NEW YORK CONSTRUCTION & RENOVATION, INC.,
`DAJ REALTY, LLC, 37 CROSBY REALTY, LLC,
`ENGINEERING GROUP ASSOCIATES, P.C., GENNADY
`SARATOVSKY P.E., INTEGRITY CONSULTING
`SERVICE, INC., ALEKSANDER LEVIN P.E., BRENT M.
`PORTER ARCHITECTS AND ASSOCIATES, BRENT M.
`PORTER ARCHITECT, PLLC, BRENT PORTER R.A.,
`ASPEN AMERICAN INSURANCE CO. a/s/o DAJ
`REALTY, 35 1/2 CROSBY STREET REALTY CORP.,
`WALTER SEDOVIC ARCHITECT, P.C., YORAM
`FINKELSTEIN, FLAGSTAFF1, LLC, ICON REALTY
`MANAGEMENT, LLC, and T&T REALTY
`MANAGEMENT, LLC,
`
`Defendants.
`
`COMPLAINT
`
`Index No.
`
`Plaintiff, Everest National Insurance Company (“Everest”), by its attorneys, Barclay
`
`Damon, LLP, for its Complaint against Defendants hereby alleges as follows:
`
`INTRODUCTION AND PARTIES
`
`1.
`
`This is an insurance coverage action in which Everest seeks a declaration that it is
`
`not obligated to defend, indemnify, or otherwise provide coverage to New York Construction &
`
`Renovation, Inc. (“NYC&R”) in connection with property damage allegedly sustained to a
`
`property owned by Defendant DAJ Realty, LLC (“DAJ Realty”), as described in further detail
`
`herein.
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`INDEX NO. 651486/2021
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`RECEIVED NYSCEF: 03/05/2021
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`2.
`
`At all times hereinafter mentioned, Everest was and is an insurance company
`
`authorized to transact business in the State of New York and licensed to issue insurance policies
`
`in the State of New York.
`
`3.
`
`At all times hereinafter mentioned, NYC&R was and still is a domestic business
`
`corporation duly organized and existing by virtue of the laws of the State of New York, with its
`
`principal place of business at 992 Coney Island Avenue, Brooklyn, New York 11230.
`
`4.
`
`At all times hereinafter mentioned, DAJ Realty was and still is a domestic limited
`
`liability company duly organized and existing by virtue of the laws of the State of New York, with
`
`its principal place of business at 150 East 58th Street, New York, New York 10155.
`
`5.
`
`At all times hereinafter mentioned, 37 Crosby Realty LLC was and still is a
`
`domestic limited liability company duly organized and existing by virtue of the laws of the State
`
`of New York, with its principal place of business at 419 Lafayette Street, 5th Floor, New York,
`
`New York 10003.
`
`6.
`
`At all times hereinafter mentioned, Engineering Group Associates, P.C. was and
`
`still is a domestic professional corporation duly organized and existing by virtue of the laws of the
`
`State of New York, with its principal place of business at 45 East 20th Street, 6th Floor, New York,
`
`New York 10003.
`
`7.
`
`At all times hereinafter mentioned, Gennady Saratovsky, P.E. was and still is a
`
`resident of the County of New York, State of New York.
`
`8.
`
`At all times hereinafter mentioned, Integrity Consulting Service, Inc. was and still
`
`is a domestic business corporation duly organized and existing by virtue of the laws of the State
`
`of New York, with its principal place of business at 443 Arbuckle Avenue, Cedarhurst, New York
`
`11516.
`
`21741327.2
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`2
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`RECEIVED NYSCEF: 03/05/2021
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`9.
`
`At all times hereinafter mentioned, Aleksander Levin, P.E. was and still is a resident
`
`of the County of Nassau, State of New York.
`
`10.
`
`At all times hereinafter mentioned, Brent M. Porter Architects and Associates was
`
`and still is a domestic business corporation duly organized and existing by virtue of the laws of
`
`the State of New York, with its principal place of business at 166 St. James Place, Brooklyn, New
`
`York 11238.
`
`11.
`
`At all times hereinafter mentioned, Brent M. Porter Architect, PLLC was and still
`
`is a professional limited liability corporation duly organized and existing by virtue of the laws of
`
`the State of New York, with its principal place of business at 166 St. James Place, Brooklyn, New
`
`York 11238.
`
`12.
`
`At all times hereinafter mentioned, Brent Porter, RA was and still is a resident of
`
`the County of Kings, State of New York.
`
`13.
`
`At all times hereinafter mentioned, Aspen American Insurance Co. was and still is
`
`a domestic business corporation duly organized and existing by virtue of the laws of the State of
`
`Texas, with its principal place of business at 175 Capital Boulevard, Suite 300, Rocky Hill,
`
`Connecticut 06067.
`
`14.
`
`At all times hereinafter mentioned, 35 1/2 Crosby Street Realty Corp. was and still
`
`is a domestic business corporation duly organized and existing by virtue of the laws of the State
`
`of New York, with its principal place of business at 666 Broadway, New York, New York 10012.
`
`15.
`
`At all times hereinafter mentioned, Walter Sedovic Architect, P.C. was and still is
`
`a domestic professional corporation duly organized and existing by virtue of the laws of the State
`
`of New York, with its principal place of business at 1 Bridge Street, Suite 1, Irvington, New York
`
`10533.
`
`21741327.2
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`3
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`6 of 14
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`INDEX NO. 651486/2021
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`RECEIVED NYSCEF: 03/05/2021
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`16.
`
`At all times hereinafter mentioned, Yoram Finkelstein was and still is a resident of
`
`the County of New York, State of New York.
`
`17.
`
`At all times hereinafter mentioned, Flagstaff1 LLC was and still is a domestic
`
`limited liability company duly organized and existing by virtue of the laws of the State of New
`
`York, with its principal place of business at 425 N. Broadway, #502, Jericho, New York 11753.
`
`18.
`
`DAJ Realty, LLC, 37 Crosby Realty LLC, Engineering Group Associates, P.C.,
`
`Gennady Saratovsky, P.E., Integrity Consulting Service, Inc., Aleksander Levin, P.E., Brent M.
`
`Porter Architects and Associates, Brent M. Porter Architect, PLLC, Brent Porter, R.A., Aspen
`
`American Insurance Company, 35 1/2 Crosby Street Realty Corp., Walter Sedovic Architect, P.C.,
`
`Yoram Finkelstein, and Flagstaff1 LLC are named in this declaratory judgment action since they
`
`are parties to the underlying lawsuits.
`
`INSURANCE POLICY ISSUED BY EVEREST
`
`19.
`
`Everest issued two insurance policies to NYC&R as the named insured, both with
`
`an effective policy period of February 6, 2012 to February 6, 2013: a Commercial General
`
`Liability Policy bearing policy number 6900002188-001, and a Commercial Excess Liability
`
`Policy, bearing policy number 75F0000430-121 (collectively, the “Everest Policy”).
`
`20.
`
`The Everest Policy provides coverage for, among other things, “property damage”
`
`caused by an “occurrence” that takes place in the “coverage territory” and during the policy period,
`
`subject to the Policy provisions, terms, and conditions.
`
`21.
`
`The Everest Policy sets forth several conditions with which NYC&R is required to
`
`comply as a condition precedent to coverage.
`
`22.
`
`Namely, the Everest Policy states that, in the event of an occurrence, offense, claim,
`
`or suit, NYC&R must: (1) “[i]mmediately send [Everest] copies of any demands, notices,
`
`21741327.2
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`INDEX NO. 651486/2021
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`RECEIVED NYSCEF: 03/05/2021
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`summonses or legal papers received in connection with the claim or ‘suit;’” (2) “[a]uthorize
`
`[Everest] to obtain records and other information;” (3) “[c]ooperate with [Everest] in the
`
`investigation or settlement of the claim or defense against the ‘suit;’” and (4) “[a]ssist [Everest],
`
`upon [its] request, in the enforcement of any right against any person or organization which may
`
`be liable to the insured because of injury or damage to which this insurance may also apply.”
`
`UNDERLYING LAWSUITS
`
`23.
`
`On May 24, 2017, Defendant DAJ Realty commenced a lawsuit, entitled DAJ
`
`Realty, LLC v. 37 Crosby Realty LLC, et al. and bearing Index Number 154824/2017, by filing a
`
`Summons and Complaint in the New York County Clerk’s Office (the “DAJ Realty Lawsuit”).
`
`24.
`
`In its Complaint, DAJ Realty claims that it owns property located at 35 Crosby
`
`Street in the City of New York, and that this property shares a wall with neighboring property 37
`
`Crosby Street.
`
`25.
`
`DAJ Realty alleges that the owner of 37 Crosby Street, Defendant 37 Crosby Realty
`
`LLC (“37 Crosby Realty”), performed renovation work on its property from approximately
`
`February 2012 through June 2014 (the “Project”).
`
`26.
`
`The Complaint states that 37 Crosby Realty hired NYC&R as general contractor on
`
`the Project in approximately August 2012.
`
`27.
`
`The DAJ Realty Lawsuit alleges, among other things, the defendants named therein,
`
`including NYC&R, caused property damage to the DAJ Realty property located at 35 Crosby
`
`Street.
`
`28.
`
`On November 1, 2017, Defendant Aspen American Insurance Co. (“Aspen
`
`American”), a first party property insurer of DAJ Realty, filed a related subrogation action in New
`
`York County Supreme Court, entitled Aspen American Insurance Co. a/s/o DAJ Realty v. 35 1/2
`
`21741327.2
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`RECEIVED NYSCEF: 03/05/2021
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`Crosby Street Realty Corp., et al. and bearing Index Number 151442/2017 (the “Aspen American
`
`Lawsuit”).
`
`29.
`
`Aspen American named NYC&R (incorrectly sued as “New York Construction and
`
`Restoration, Inc.”) as a defendant in its subrogation action.
`
`30.
`
`As stated in its Complaint, Aspen American seeks subrogation from the defendants
`
`named therein, “in the event of any future payments made” to its insured DAJ Realty, arising out
`
`of the Project-related damages allegedly sustained by DAJ Realty.
`
`31.
`
`By a Decision and Order of the Court (Hon. Barbara Jaffe, J.S.C.), filed on
`
`December 18, 2018, the Aspen American lawsuit was dismissed as duplicative of the DAJ Realty
`
`lawsuit.
`
`RELEVANT FACTUAL HISTORY
`
`32.
`
`Since the commencement of the underlying lawsuits, Everest has repeatedly and
`
`consistently communicated with NYC&R regarding its obligation to provide cooperation with the
`
`investigation of the aforementioned Project and defense of the underlying lawsuits and claims.
`
`Despite these efforts, NYC&R has failed to provide this needed information and cooperation.
`
`Some of the following factual information is being made upon information and belief, and is based
`
`upon documents received by Everest and/or information transmitted to Everest.
`
`33. More particularly, Everest and its representatives have sent numerous letters and
`
`emails, and made many phone calls and in-person visits, requesting that NYC&R provide certain
`
`documents and information in order to assist Everest with its investigation and defense of the
`
`underlying lawsuits.
`
`34.
`
`Specifically, Everest has repeatedly requested the following documents and
`
`information, among other things:
`
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`RECEIVED NYSCEF: 03/05/2021
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` Copies of all NYC&R’s contracts and subcontracts for work performed in
`connection with the Project;
` A narrative general description of the work performed by NYC&R at the Project;
` All work records for work performed at the Project;
` A description of the building at 37 Crosby Street;
`
`Identification of NYC&R’s general liability insurance carriers between February 6,
`2013 and the present.
`
`35.
`
`For a period of more than two years, NYC&R has failed to cooperate, by not
`
`providing the requested information and documents, despite Everest’s follow-up requests.
`
`36.
`
`In addition, Everest retained the law firm of Braff, Harris, Sukoneck & Maloof
`
`(“Braff Harris”) to defend NYC&R in the underlying lawsuits.
`
`37.
`
`Attorneys at Braff Harris also have attempted to obtain NYC&R’s cooperation,
`
`including the aforementioned documents and information, on numerous occasions without
`
`success.
`
`38.
`
`On December 14, 2020, Everest sent a letter to NYC&R stating that Everest is
`
`denying coverage to NYC&R with respect to the underlying lawsuits based upon NYC&R’s failure
`
`to cooperate with Everest and Braff Harris in the investigation and defense of the lawsuits.
`
`AS AND FOR A FIRST CAUSE OF ACTION
`AGAINST DEFENDANT NEW YORK CONSTRUCTION & RENOVATION, INC.
`(BREACH OF CONTRACT)
`
`39.
`
`Plaintiff Everest repeats and realleges each and every allegation contained in
`
`paragraphs “1” through “48” as if fully set forth herein.
`
`40.
`
`NYC&R has failed to cooperate with Everest in connection with Everest’s defense
`
`of NYC&R in the DAJ Realty Lawsuit and Aspen American Lawsuit.
`
`41.
`
`NYC&R has failed to forward to Everest all litigation-related documents it has
`
`received in connection with the DAJ Realty Lawsuit and Aspen American Lawsuit.
`
`21741327.2
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`42.
`
`NYC&R has failed to provide Everest with all relevant documentation and
`
`information necessary to investigate and defend against the DAJ Realty Lawsuit and Aspen
`
`American Lawsuit.
`
`43.
`
`Pursuant to the conditions outlined in the Everest Policy, NYC&R is required to
`
`cooperate with Everest in its defense of a claim or suit, forward all litigation-related documents,
`
`and provide all relevant documentation and information.
`
`44.
`
`NYC&R has failed to satisfy these Policy conditions, and that failure constitutes a
`
`breach of the terms of the Everest Policy.
`
`45.
`
`Everest has fulfilled all of its obligations to NYC&R under the Everest Policy.
`
`46.
`
`Accordingly, Everest is not obligated to defend or indemnify NYC&R in the DAJ
`
`Realty Lawsuit, or with respect to any claims asserted therein.
`
`47.
`
`Everest is likewise not obligated to defend or indemnify NYC&R in the Aspen
`
`American Lawsuit, or with respect to any claims asserted therein.
`
`48.
`
`Everest has no adequate remedy at law.
`
`49.
`
`Everest is entitled to a declaration that it is not obligated to defend or indemnify
`
`NYC&R in connection with either the DAJ Realty Lawsuit or the Aspen American Lawsuit.
`
`AS AND FOR A SECOND CAUSE OF ACTION
`AGAINST DEFENDANT NEW YORK CONSTRUCTION & RENOVATION, INC.
`(FOR DECLARATORY JUDGMENT)
`
`50.
`
`Plaintiff Everest repeats and realleges each and every allegation contained in
`
`paragraphs “1” through “59” as if fully set forth herein.
`
`51.
`
`Pursuant to the conditions outlined in the Everest Policy, NYC&R is required to
`
`cooperate with Everest in its defense of a claim or suit, forward all litigation-related documents,
`
`and provide all relevant documentation and information.
`
`21741327.2
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`INDEX NO. 651486/2021
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`RECEIVED NYSCEF: 03/05/2021
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`52.
`
`The Everest Policy does not afford coverage to NYC&R in the event NYC&R fails
`
`to satisfy the conditions of the Policy.
`
`53.
`
`In failing to cooperate with Everest in its defense of a claim or suit, failing to
`
`forward all litigation-related documents, and failing to provide all relevant documentation and
`
`information, NYC&R has failed to satisfy the conditions in the Everest Policy and it is not entitled
`
`to coverage under the Policy.
`
`54.
`
`Accordingly, Everest is not obligated to defend or indemnify NYC&R in the DAJ
`
`Realty Lawsuit, or with respect to any claims asserted therein.
`
`55.
`
`Everest is likewise not obligated to defend or indemnify NYC&R in the Aspen
`
`American Lawsuit, or with respect to any claims asserted therein.
`
`56.
`
`Everest has no adequate remedy at law.
`
`57.
`
`Everest is entitled to a declaration that it is not obligated to defend or indemnify
`
`NYC&R in connection with either the DAJ Realty Lawsuit or the Aspen American Lawsuit.
`
`WHEREFORE, it is respectfully requested that this Court enter judgment in favor of
`
`Plaintiff Everest National Insurance Company as follows:
`
`(a)
`
`(b)
`
`finding that New York Construction & Renovation, Inc. breached
`the terms of the Everest Policy;
`
`declaring that Everest is not obligated to defend, indemnify,
`reimburse, or otherwise compensate New York Construction &
`Renovation, Inc. in connection with either the DAJ Realty Lawsuit
`or the Aspen American Lawsuit; and
`
`(d)
`
`granting such other and further relief as this Court deems just and
`proper.
`
`DATED:
`
`March 4, 2021
`
`BARCLAY DAMON LLP
`
`By:
`
`s/ Sanjeev Devabhakthuni
`Anthony J. Piazza
`Sanjeev Devabhakthuni
`
`
`
`21741327.2
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`
`
`FILED: NEW YORK COUNTY CLERK 03/04/2021 11:32 AM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 651486/2021
`
`RECEIVED NYSCEF: 03/05/2021
`
`Attorneys for Plaintiff
`Everest National Insurance Company
`Office and Post Office Address
`2000 Five Star Bank Plaza
`100 Chestnut Street
`Rochester, New York 14604
`Telephone: (585) 295-4420
`
`TO: New York Construction & Renovation, Inc.
`992 Coney Island Avenue
`Brooklyn, New York 11230
`
`DAJ Realty, LLC
`150 East 58th Street
`New York, New York 10155
`
`37 Crosby Realty LLC
`419 Lafayette Street, 5th Floor
`New York, New York 10003
`
`Engineering Group Associates, P.C.
`45 East 20th Street, 6th Floor
`New York, New York 10003
`
`Gennady Saratovsky, P.E.
`45 East 20th Street, 6th Floor
`New York, New York 10003
`
`Integrity Consulting Service, Inc.
`443 Arbuckle Avenue
`Cedarhurst, New York 11516
`
`Aleksander Levin, P.E.
`443 Arbuckle Avenue
`Cedarhurst, New York 11516
`
`Brent M. Porter Architects and Associates
`166 St. James Place
`Brooklyn, New York 11238
`
`21741327.2
`
`10
`
`13 of 14
`
`
`
`FILED: NEW YORK COUNTY CLERK 03/04/2021 11:32 AM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 651486/2021
`
`RECEIVED NYSCEF: 03/05/2021
`
`Brent M. Porter Architect, PLLC
`166 St. James Place
`Brooklyn, New York 11238
`
`Brent Porter, R.A.
`166 St. James Place
`Brooklyn, New York 11238
`
`Aspen American Insurance Company
`175 Capital Boulevard, Suite 300
`Rocky Hill, Connecticut 06067
`
`35 1/2 Crosby Street Realty Corp.
`666 Broadway
`New York, New York 10012
`
`Walter Sedovic Architect, P.C.
`1 Bridge Street, Suite 1
`Irvington, New York 10533
`
`Yoram Finkelstein
`2112 Broadway, Room 204
`New York, New York 10023
`
`Flagstaff1 LLC
`425 N. Broadway, #502
`Jericho, New York 11753
`
`Icon Realty Management LLC
`419 Lafayette Street, 5th Fl.
`New York, New York 10003
`
`T&T Realty Management LLC
`419 Lafayette St., 5th Fl.
`New York, New York 10003
`
`21741327.2
`
`11
`
`14 of 14
`
`
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