89-07 34th Avenue HP (1)

CIVIL COURT OF THE STATE OF NEW YORKCOUNTY OF QUEENS, PART C

LUIS ANGULO, ROSA ARIAS, JESUS BENAVIDES, Index No. HP

FREDDY FABIAN BERMEJO, LISA BRADSHAW,DOLORES CALLE, MANUEL CARDENAS,FABIOLA CARPINTEYRO, LUIS CARRASCO,ANGELES CARREON, CARMEN CASTRO, JUANA

CONTRERAS, FAUSTINA COYOTL, NEMECIO VERIFIED PETITION

COYOTL, RUFINO DIAZ, SONIA DILONE, WILSON

ENCARNACION, ANGELINA ESPINO, CECILIA FA

RCIERT, ADELA FLORES, IRIS FLORES, Subject Premises:

MIRIAM FUENTES, WILSON GOMEZ, CARMEN 89-07 34th Avenue

GONZALEZ, OLIVIA GONZAGA, MAGNOLIA Queens, New York 11372

GUZMAN, LAURA HIDALGO, ALBA INASTRILLA,

ALEJANDRO CRUZ LOPEZ, MARTHA

MALDONADO, JUDITH MARTINEZ, NESTOR

MEJIA, MARIA MELENDEZ, SERGIO MELO, JR.,

MARIA MENDEZ, PETER MONCADA, CARMEN

MONSALVE, ZORAIDA MORA, VALENTIN

OLIVARES, CATHERINE PALAGUACHI,MARGARITA PAZ, NINFA PERALTA, KAREN

PEREZ, FABIAN JUAREZ POBLANO, IRINEO

RAMIREZ, ANDRES RESTREPO, JUAN REYES,

PATRICIA RIVAS, BASIILIA RODRIGUEZ, JOSE

RODRIGUEZ, NEYILIA RODRIGUEZ, ROSA

RODRIGUEZ, ELVER RUIZ, GIOVANNI SANCHEZ,ANDREW SOKOLOF, MODESTO SOSA, FAUSTINO

TEPOZ, JOVITA TORRES, COLUMBA VALLE,SALVADOR VALLE, ANA VASQUEZ, NORMA

VASQUEZ, AND TERESA VELIZ

Petitioners

-against-

KEDEX PROPERTIES LLC, KEVIN BOLANOS,JORGE BOLANOS, ROSA BOLANOS

Respondent-Owners, and

DEPARTMENT OF HOUSING PRESERVATION

AND DEVELOPMENT

Co-Respondent, and

FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PM INDEX NO. LT-306054-21/QU

NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021

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NEW YORK CITY DEPARTMENT OF BUILDINGS

Co-Respondent.

Petitioners, by their attorneys The Legal Aid Society, respectfully allege the following:

1. Petitioners bring this procccdiñg to correct the serious and ongoing

conditions that have resulted in the iccua- of vacate orders by both the New York City

Departmcñt of Buildings and the New York City Department of Housing Preservation

and Development. The vacate orders, issued following a fire in April 2021, have resulted

in over 100 fandlies being forced out of their homes for nearly five months.

2. The building, located at 89-07 and 89-11 34th Avenue, Queens New York

and known as 89-073481

Avenue, Queens, New York 11372 (hcrciñafter "the subject

premises"), is a multiple dwelling as defmed by Section 27-2004(a) of the Housing

Main±==nce Code and contains 133 units. The subject premises is rent regulated, and,

upon information and belief, the subject apartmcñts are rent stabilized or rent controlled.

PARTIES

3. The Petitioners herein are tenants and lawful occupants of the subject

premises. Prior to the issuance of the vacate orders that are currently in place and that

prevent Petitioners from physically occupying the subject premises, Pendenes resided in

and were and are entitled to lawful occupancy of their respective apartments in the

subject premises. The Petitioners, many of whom are long-term residents of the subject

premises, are entitled to enforce the Housing Maiñtcñance Code. The names and

respective apartment ñümbers of the Petitioners are listed in Exhibit A.



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4. Petitioners are members of 89th Street Tenant Unidos Association which

is the long-time tenant association of the residents living at the subject premises.

5. Respondet KEDEX PROPERTIES LLC is the Corporation Owner listed

on the subjectpremises'

Online Building Registration Sr---y Report at 44 Chestnut

Street, Garden City, New York 11530 and is an owner as defined by the Housing

Maintenance Code.

6. Respondet KEVIN BOLANOS is the Managing Agent listed on the

subjectpremises'

Online Buildi-g Registration Summary Report at 89-07 34th Avenue,

Apartment 1-L, Jackson Heights, New York 11372 and is an owner as defined by the

Housing Maintenance Code.

7. Respondet JORGE BOLANOS is the Head Officer listed on the subject

premiscs'Online Building Registration Summary Report at 44 Chestnut Street, Garden

City, New York 11530 and is an owner as defined by the Housing Maintmance Code.

8. Respondent ROSA BOLANOS is the Officer listed on the subject

premises'Online B=il-lieg Registration Summay Report at 44 Chestnut Street, Garden

City, New York 11530 and is an owner as defined by the HousingMai=+--==--3 Code.

9. Co-Respondent DEPARTMENT OF HOUSING PRESERVATION AND

DEVELOPMENT (hcrciñafter HPD) is a city agency charged with enforcing the various

laws pertai-i-g to the maintenance of residential housing, is a statutory respondent

pursuant to NYC Admin. Code 27-2115, and has issued a vacate order for the subject

premises

10. Co-Respondent NEW YORK CITY DEPARTMENT OF BUILDINGS

(herciñaficr DOB) is a city agcñcy charged with enforcing the various laws pertaining to



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the mai÷nance of residential housing and has issued a vacate order for the subject

premises

REGULATORY SCHEME

11. Under NYC Ad-Mst-ative Code § 27-2115(h)(1) and (i), any tenant or

group of teñañts may request issuance of housing standa-d violations against an owner

and may apply iñdividually or jointly, to the housing part for an order directing the

owner, as well as the Department charged with enforcing the Housing Maiñtcñance Code,

to appear before the court. Under NY City Civil Court Act § 110(d) any other city

departmcñt may be joined to an action in order to effectuate proper housing standards and

promote the public interest. A tenant or group of tenants may also com-mee an HP

proceeding to obtain civil pealdes against an owner. See NYC Adm. Code § 27-2115.

12. This Court has broad powers under the NY City Civil Court Act § 110(c)

to "recommend or employ any remedy, program, procedure or sancEen authorized by law

for the enforcanet of housing standards, if it believes they will be more effective to

accomplish compliance or to protect and promote the publicinterest"

as well as under

NYC Adm. Code § 27-2121 to issue an order to correct any violation of the Housing

Mainicnance Code and "to take such other steps as the court may deem ñccessary to

assure contimñg compliance with the requirements of thiscode."

STATEMENT OF FACTS

13. On April 6, 2021, a seven-alarm fire tore through the subject premises,

causing widespread and extensive damage and displaciñg over a hundred families, many



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of whom are long-term residcñts of the building. Nearly five months have passed, and

Petitioners remain üñabic to return to the subject premises to live in their homes.

14. On April 6, 2021, DOB issued a full vacate order. See Exhibit B. On April

14, 2021, HPD issued vacate orders for every apartment in the subject premises due to a

variety of conditions includiñg fire damage to individual apartments, damage to the roof

of the building and shut-offs of electricity and gas. See_Exhibit C, Vacate Order issued by

HPD and Exhibit D, HPD Violations Report dated August 27, 2021. The full vacate

order issued by DOB was modified to a partial vacate order on or about July 19, 2021.

Said order was modified to the extent necessary to allow tenants to enter the premises to

obtain personal belongings from apartments A through I on the first, second, third, fourth,

and fifth floors. See Exhibit B.

15. According to DOB records, the agency also issued a partial stop work

order on or about July 30, 2021. The stop work order appears to have been issued for

unsafe use of a crane.

16. As of the filing of this Petition, the reddents of the building have not been

able to return to live in their apartments and many residents have not had any access to

their apartments since the fire. Currently, there are on or about 139 open violations at the

subject premises iñcluding 129 class"C"

violations, 6 class"B"

violations, 3 class"A"

violations and one class"I"

violation. The I violation requires the building to get a new

certineate of occupancy before the building can be occupied. See_Exhibit D, HPD

Violations Report dated August 27, 2021.

17. Upon information and belief, although individual apartments suffered

varying levels of damage, Petitioners have been given limited information about the



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scope and timcframe of work necessary to repair the common areas, to restore utilities,

and to fix their individual apartments, such that the subject premises will be safe to

occupy.

18. Upon information and belief, Respondent-Owners have denied Petitioners

access to portions of the buildi-g, meaning that many Petitioners have been unable to

access their apartmcñts to retrieve their belonghgs For those Petitioners that have been

able to enter their apartmcñts, access has been unreasonable and severely limited, and

Petitioners have been unable to retrieve their belongi-gs or have received insufficient

notice and assistånce to arrange to move and store their property.

19. Furthermore, upon information and belief, Respondent-Owners have

informed individual Petitioners that they will not be able to retrieve their beloughgs

before construction work commences. Should Respondent-Owners and Respondents

HPD and DOB prcycñt Petitioners from accessing their apartments and retrieving their

belongings, Petitioners, who already been displaced from their homes during a global

pandanic and public health crisis and endured damage to their personal property, may

suffer a complete loss of their belongings.

20. Upon information and belief, HPD has failed to request penalties based

uponrespondents'

failure to correct the listed violations within the time specified by the

Administrative Code of the City of New York.

21. Respondents have failed to make the necessary repairs that would allow

DOB to provide a new certificate of occupancy or allow DOB and HPD to remove their

respective vacate orders so Petitionas may safely return to their homes.



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22. The conditions at the subject premises constitute an emergency, a danger

to the health and safety of the tenants, and constitute violations of the Ad=4=4strative

Code of the City of New York, the Multiple Dwelling Law, and other applicable laws and

regulations.

23. No prior request for this relief has been made.

24. WHEREFORE, Petitioners respectfully request that this Court issue an order:

a. Directing Respondat-Owners to inspect and repair all violadens of the Housing

Maiñtcñañcc Code, the Buildi-g Code, the Multiple Dwelling Law, and any and

all other laws, regulations, and statutes perta ning to housing standards;

b. Directing Respondent-Owners to correct all conditions described in the full and

partial vacate orders issued by the Department of Housing Preservation and

Development and the Department of Buildhgs and correct all violations issued by

the Department of Housing Preservation and Development and Department of

Buildings such that a new certificate of occupancy can be issued, and Petitioners

can safely return to the subject premises;

c. Enje½g Respondat-Owners from commencing construction in the subject

premises until such time that Petitioners have been able to retrieve their personal

belongings;

d. Ordering Respondent-Owners to restorePendenæ;'

apartmcñts to their size and

configuration directly prior to the fire that resulted in the issuañce of vacate orders

by the Department of Housing Preservation and Developmcñt and Department of

Buildings in April 2021;



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e. Allowing Petitioners reasonable and regular access to the subject premises to

obtain their belongir.gs and inspect and confirm the ongoing repair work;

f. Directing Respondent-Owners to provide Petitioners with the Respondent-

Owners' plans and timetable for the correction of all conditions and to provide

ongoing updates to Petitioners until such conditions are corrected;

g. Directing Respondent-Owners and Respondents Department of Housing

Preservations and Developmat and the Department of Buildings to provide the

court and Petitioners with any submissions, certifications, permit applications or

other decamcsts that Respondent-Owners has filed with Co-Resper.dcats to

camm-ce repair work or to remove the violadens and the current vacate orders

issued in the subject premises by the Department of Housing Preservation and

Development and the Department of Buildings and to continue to provide such

documcñts to Petitioners upon filing of said documents;

h. Imposing upon Respeñdcñt-Owners the civil penalties provided by

Ad- -½ative Code § 27-2115(a) based on Respondent-Owners' failure to

correct violations ceñuined in notices of violations issued by the Department of

Housing Preservation and Devclepment and entering a judgement against the

Respondent-Owners for the amount of civil-pealdes imposed by the Court;

i. Finding that the conditions described in the petition constitute violadens, and

directing the respondent-owners to correct the violations within the time provided

by NYC Ad=4=4±ative Code § 27-2115(c) or be subject to civil penalties

pursuant to § 27-2115(a);

j. Awarding costs, disbursements, and reasonableattorneys'

fees to Petitioners;



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k. Granting any other and further relief as the court deems just and proper.

Dated: September 3, 2021

Brooklyn, New York

Respectfully Submitted,

Amee Master, Esq.

Connor Mealey, Esq.

of counsel

Janet E. Sabel, Attorney-in-Chief

THE LEGAL AID SOCIETY

Queens Neighborhood Office

120-46 Queens Boulevard

Kew Gardens, New York 11415

(646) 398-2937

Attorneys for Petitioners

FILED: QUEENS CIVIL COURT - L&T 09/10/2021 12:55 PMINDEX NO. LT-306054-21/QUNYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/10/2021

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VERIFICATION

STATE OF NEW YORK ): ss.:

COUNTY OF QUEENS )

I, bq1 R . /J. y fr t/ L 3being duly sworn, depose and say:

1. I am a Petitioner in the within entitled action.

2. The foregoing Petition has been read to me in Spanish.

3. The information stated therein is true to my own knowledge except as to

those matters stated to be alleged upon information and belief, and as to those matters I believe

the information to be true.

Sworn to before me this

c15 day of August 2021

NOTARY PUBLIC

Amee Shah Master

Notary Public- State of New YorkNo. 02MA6266407

Qualified in Kings CountyCommission Expires: 7/30/


10 of 73

VERIFICATION


COUNTY OF QUEENS )

I, ()So o being duly sworn, depose and say:






NAME:


day of August 2021

NOTARY PUBLIC

AmeeShah

MasterNotary Public-State of

NewYorkNo.02MA6266407Qualified in Kings

CountyommissionExpires:

7/30/__


11 of 73

VERIFICATION


COUNTY O QUEENS )

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AME: e U er)Au Ld C

Sworn to before me this eunvid

S - /© day of August 2021

NOTA PU C

NOTARY PUBLIC, STATE OF NEW YORICRegistration No. 01NAS$97695

ousimed in ousens county


12 of 73

VERIFICATION


COUNTY OF QUEENS )

I,7n , /YF/ being duly sworn, depose and say:






AME:


day of August 2021

NOTEY PUBLIC

Amee Shah Master

NotaryPublic- State of New York

No.02MA6266407

Qualmed in Kings County

Commission Expires: 7/30fÎ


13 of 73

VERIFICATION


COUNTY OF QUEENS )

I, \. , uly sworn, depose and say:


2. I have read or have had read to me the foregoing Petition.




LsaBradshawuNAME:


day of August 2021

NOTARY PUBLIC

Amee Shah Master

Notary Public- State of New York

No. 02MA6266407

Qualified in Kings County

Commission Expires: 7/30/...


14 of 73

VERIFICATI


COUNTY OF QUEENS )

I, 60 O les CcEb , being duly sworn, depose and say:






NAME: D O c


day of August 2021

NOTA PU

NOTARY PUBUC, STATE OF NEW YOfutRegistration No.01NA6397595

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VERIFICATION


COUNTY OF QUEENS )

I, ing duly sworn, depose and say:





the information to be true. __

NAME:


day of August 2021

N RY PUBLIC

Amee Shah Master


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16 of 73

VERIFICATION


COUNTY OF QUEENS )

I, y eing duly sworn, depose and say:







day of August 2021

NOTEY PUBLIC

Amee Shah Master


No. 02MA6266407


Commission Expires: 7/301


17 of 73

VERIFICATION


COUNTY OF QUEENS )

I, ÅU Ì S CAfU2AS (O, being duly sworn, depose and say:






NAME: ÅU// G4 W L O


day of August 2021

NOTARY PUBLIC

Amee Shah MasterPublic- State of New yoryNo.

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on Expires: 7/30/B


18 of 73

VERIFICATION


COUNTY OF QUEENS )

I, /}pp/es Carreon , being duly sworn, depose and say:







day of August 2021

NO RY PUBLIC

a Shah Master

NuaryPublic- State of New York

No. 02MA6266407


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VERIFICATION


COUNTY OF QUEENS )

I,by ry; n mpbeing duly sworn, depose and say:






NAME: NWW Cet sTn,


day of August 2021

NOT PU IC

NOTARY PUBLIC, STATE OF NEW YORICRegistration No.01NA6397595

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VERIFICATION


COUNTY OF QUEENS )

I, OROR Ûor MS, being duly sworn, depose and say:






NAME: 1RC1c4 o rh3


day of August 2021

NOTARY PUBLIC

Amee Shah Master


No. 02MA6266407




21 of 73

VERIFICATION


COUNTY OF QUEENS )

I, c being duly sworn, depose and say:






NAME:


day of August 2021

NOTARY PUBLIC

Amee Shah Master


No. 02MA6266407


Commission Expires: 7/30/_2


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day of August 2021

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VERIFICATION


COUNTY OF QUEENS )

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day of August 2021

NOt- RY PUBLIC

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COUNTY OF QUEENS )

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NAME: 6CW c OvW


f f day of August 2021

NOTARY PUBLIC

Amee Shah Master


Qualified in Kings CountyCommission Expires: 7/30/1


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VERIFICATION


COUNTY OF QUEENS )

I, eing duly sworn, depose and say:







day of August 2021

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No. 02MA6266407


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COUNTY OF QUEENS )

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NOTARY PUBLIC

Amee Shah Master


No. 02MA6266407




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day of August 2021

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VERIFICATION


COUNTY OF QUEENS )

I, D77 eing duly sworn, depose and say:







/C day of August 2021

NOTARY PUBLIC

Amee Shah Master


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VE_RIFICATION


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day of August 2021

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VERIFICATION


COUNTY OF QUEENS )

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day of August 2021

NÖTARY PUBLIC

Amee Shah Master


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VERIFICATION


COUNTY OF QUEENS )

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NAME: 7


day of August 2021

NOTARY PUBLIC

Amee Shah Master


No. 02MA6266407




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NAME: O


day of August 2021

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Amee Shah Master


No. 02MA6266407

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VERIFICATION


COUNTY OF QUEENS )

I V a 41 being duly sworn, depose and say:






NAME:


day of August 2021

NOTARY PUBLIC

Amee Shah Master


No. 02MA6266407




35 of 73

VERIFICATION


COUNTY OF QUEENS )

I, df , mg duly sworn, depose and say:






NAME:


day of August 2021

NO ARY PUBLIC

Amee Shah Master


No. 02MA6266407


Commission Expires: 7/30d


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COUNTY OF QUEENS )

IAl ba. cEl r t Î l 4 being duly sworn, depose and say:






NAME: a.. c


day of August 2021

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Amee Shah Master


No. 02MA6266407


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COUNTY OF QUEENS )

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ff day of August 2021

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day of August 2021

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day of August 2021

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NOTARY PUBUC. STATE OF NEW YORICNo. 01NA6397506

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VERIFICATION


COUNTY OF QUEENS )

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day of August 2021

NdTAÉY PUBLIC

Awsednah Master

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No. 02MA6266407




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VERIFICATION


COUNTY OF QUEENS )

I, / / a 7 7/fbeing duly sworn, depose and say:







day of August 2021

NWARY PUBLIC

Amee Shah Master


No. 02MA6266407


Commission Expires: 7/30/2 1


44 of 73

VERIFICATION


COUNTY OF QUEENS )






the information to be true. .

NAME:


day of August 2021

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45 of 73

VERIFICATION


COUNTY OF QUEENS )

I, C armm 3 sc\w being duly sworn, depose and say:







day of August 2021

NOTARY PUBLIC

Amee Shah Master


Qualified In Kings CountyCommission Expires: 7/30/f


46 of 73

VERIFICATION


COUNTY OF QUEENS )

I, Z8AA /O4 NOR/ being duly sworn, depose and say:






NAME: 2GQA (/) & 024


day of August 2021

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Amee Shah MasterNotary Public- State of New York

No. 02MA6266407Qualified in Kings County

Commission Expires: 7/30/b


47 of 73

VERIFICATION


COUNTY OF QUEENS )

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NAME: E)rdm W 00 6WAS.


day of August 2021

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No.02MA6266407

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48 of 73

VERIFICATION


COUNTY OF QUEENS )

I, (p‰er tne a eing duly sworn, depose and say:







day of August 2021

NO flfY PUBLIC

Amee Shah Master


No. 02MA6266407


Commission Expires: 7/30/-


49 of 73

VERIFICATION


COUNTY OF QUEENS )

I, y Ct r ClZ_, being duly sworn, depose and say:






NAME: C( r // A. 7-


day of August 2021

NQMY PUBLIC

Amee Shah Master


No. 02MA6266407


Commission Expires: 7/30/_,


50 of 73

VERIFICATION


COUNTY OF QUEENS )

I, eing duly sworn, depose and say:






NAME:


day August 2021

NOT&RÝ PUBLIC

Amee Shah Master


No. 02MA6266407

Gue!!fi=J in Kings County

Commissi0u Expires: 7/30/2


51 of 73

VERIFICATION


COUNTY OF QUEENS )

I, G( W77 , being duly sworn, depose and say:






NAME: 7


day of August 2021

NO RY PUBLIC

Amee Shah Master


Qualified in Kings CountyCommission Expires: 7/30/_3


52 of 73

VERIFICATION


COUNTY OF QUEENS )

I,]O(ht Mk 30awt being duly sworn, depose and say:






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day o ust 2021

DARY PUBLIC

Amee Shah Master


No. 02MA6266407




53 of 73

VERIFICATION


COUNTY OF QUEENS )

I, 1Ù 060 K 6 2 being duly sworn, depose and say:






NAME: 1 0 60


day of August 2021

NO Y PUBLIC

Amee Shah Master

otaryPublic- State of New York

No. 02MA6266407




54 of 73

VERIFICATION


COUNTY OF QUEENS )

I, N Ó(f 1', being duly sworn, depose and say:






NAME:


day of August 2021

NOTAl BLIC

Amee Shah Master


No. 02MA6266407


Commission Expires: 7/30/__


55 of 73

VERIFICATION


COUNTY OF QUEENS )

I, bb%3 éyes , being duly sworn, depose and say:






NAME: 30 O


/1 day of August 2021

NO RÝ PUBLIC O


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56 of 73

VERIFICATION


COUNTY OF Q EENS )

I, a being duly sworn, depose and say:






NAME: Î44


day of August 2021

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57 of 73

VERIFICATION


COUNTY OF QUEENS )

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day of August 2021

N ARY PUBLI

Amee Shah Master




58 of 73

VERIFICATION


COUNTY OF QUEENS )







NAME:


day of August 2021

N ARY PUBLIC

Amee Shah Master


No. 02MA6266407




59 of 73

VERIFICATION


COUNTY OF QUEENS )

I, duly sworn, depose and say:







day of August 2021

NdLdfÉY PUBLC

Amee Shah Master


No. 02MA6266407


Commission Expires: 7/30/.2,


60 of 73

KRIFICATION


COUNTY OF QUEENS )








day of August 2021

OTARY PUBLIC

Amee Shah Master


Qualified in Kings CountyCommission Expires: 7/30/f


61 of 73

VERIFICATION


COUNTY OF QUEENS )

I, F b/g ( ÎÊ L , being duly sworn, depose and say:






NAME: t L


day of August 2021

N Y PUBLIC

Amee Shah Master

Notary Pubilo- State of New YorkNo. 02MA6266407

Qualified in Kings CountyCommission Expires: 7/30/P


62 of 73

VERIFICATION


COUNTY OF QUEENS )

I, Sif0V{djM QA|\cH , being duly sworn, depose and say:






NAME: OVANpt S/NCHGZ


/5 day of August 2021

NOTARY PUBLIC

Amee Shah Master


No. 02MA6266407




63 of 73

VERIFICATION


COUNTY OF QUEENS )


1. . I am a Petitioner in the within entitled action.





NAME:


li day of August 2021

NOTARY PUBLIC

Amee Shah Master


No. 02Ma6266407

QuaG n Kings County



64 of 73

VERIFICATION


COUNTY OF QUEENS )

I, being duly sworn, depose and say:






NAME:


day of August 2021

NOTARY PUBLIC

Amee Shah Master


Qualified in Kings CountyCommission Expires: 7/30/_,,Ê


65 of 73

VERIFICATION


COUNTY OF QUEENS )

I, Â being duly sworn, depose and say:






NAME:


day of August 2021

NOh PUBLIC

Amee Shah Master


No. 02MA6266407




66 of 73

VERIFICATION


COUNTY OF QUEENS )

I, O 4 Off6 , being duly sworn, depose and say:






NAME: /)V 6Sworn to before me this

day of August 2021

NOTARY PUBLIC

Amee Shah Master


No. 02MA6266407


Commission Expires: 7/30/__


67 of 73

VERIFICATION


COUNTY OF QUEENS )

I, 4 being duly sworn, depose and say:






NAME: ( p (jMÎ;qV()


day of August 2021

NÓl"XRY PUBLI


No.02MA6266407



68 of 73

VERIFICATION


COUNTY OF QUEENS )







NAME: (


day of August 2021

60fARY PUBLIC

Amee Shah Master


Qualified in Kings CountyCommission Expires: 7/30/-


69 of 73

VERIFICATION


COUNTY OF QUEENS )

I, AG ( b 7 /f-7 , being duly sworn, depose and say:






NAME: ()Q Z


day of August 2021

TARY PUBL

Amee Shah Master


No. 02MA6266407

Oua!ified in Kings County

Cammission Expires: 7/301


70 of 73

VERIFICATION


COUNTY OF QUEENS )

I, /dC/ncx \ h ,egbeing duly sworn, depose and say:






NAME: A )A/An \ in.T o c c


day of August 2021

NOT PU

No.01NA8397895InQueens

comunlesion Explrus


71 of 73

VERIFICATION


COUNTY OF QUEENS )

I,tcr A 5 . ( /L , being duly sworn, depose and say:







ff day of August 2021

NOTA Y PUBLIC

Amee Shah Master


No. 02MA6266407




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Index No. Year 2021

CIVIL COURT OF THE CITY OF NEW YORKCOUNTY OF QUEENS: HOUSING PART C=====================================================================

LUIS ANGULO, ROSA ARIAS, JESUS BENAVIDES, FREDDY FABIAN BERMEJO, LISA BRADSHAW,DOLORES CALLE, MANUEL CARDENAS, FABIOLA CARPINTEYRO, LUIS CARRASCO, ANGELES

CARREON, CARMEN CASTRO, JUANA CONTRERAS, FAUSTINA COYOTL, NEMECIO COYOTL,RUFINO DIAZ, SONIA DILONE, WILSON ENCARNACION, ANGELINA ESPINO, CECILIA FARCIERT,ADELA FLORES, IRIS FLORES, MIRIAM FUENTES, WILSON GOMEZ, CARMEN GONZALEZ, OLIVIA

GONZAGA, MAGNOLIA GUZMAN, LAURA HIDALGO, ALBA INASTRILLA, ALEJANDRO CRUZ LOPEZ,MARTHA MALDONADO, JUDITH MARTINEZ, NESTOR MEJIA, MARIA MELENDEZ, SERGIO MELO, JR.MARIA MENDEZ, PETER MONCADA, CARMEN MONSALVE, ZORAIDA MORA, VALENTIN OLIVARES,CATHERINE PALAGUACHI, MARGARITA PAZ, NINFA PERALTA, KAREN PEREZ, FABIAN JUAREZ

POBLANO, IRINEO RAMIREZ, ANDRES RESTREPO, JUAN REYES, PATRICIA RIVAS, BASIILIA

RODRIGUEZ, JOSE RODRIGUEZ, NEYILIA RODRIGUEZ, ROSA RODRIGUEZ, ELVER RUIZ, GIOVANNI

SANCHEZ, ANDREW SOKOLOF, MODESTO SOSA, FAUSTINO TEPOZ, JOVITA TORRES, COLUMBAVALLE, SALVADOR VALLE, ANA VASQUEZ, NORMA VASQUEZ, AND TERESA VELIZ

Petitioners

-against-

KEDEX PROPERTIES LLC, KEVIN BOLANOS, JORGE BOLANOS, ROSA BOLANOS

Respondent-Owners, and

DEPARTMENT OF HOUSING PRESERVATION AND DEVELOPMENT

Co-Respondent, and

NEW YORK CITY DEPARTMENT OF BUILDINGS

Co-Respondent.

VERIFIED PETITION===================--================================================

AMEE MASTER, ESQ.of Counsel to

JANET. E. SABEL, ESQ.Attorney-in-Chief

THE LEGAL AID SOCIETYCIVIL PRACTICE

120-46 QUEENS BOULEVARD FL 3KEW GARDENS, NY 11415-1204

Tel. (646) 398-2937Fax (718) 263 4234

ATTORNEYS FOR PETITIONERS=====================================================================

Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State,certifies that, upon information and belief and reasonable inquiry, the contenti ontained in the annexed

document are not frivolous.

Dated:........September 3, 2021...................... Signature........... ........ ....................... ..................................

Print Signer's Name:....Amee Master......................................


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