Motion-Secondary: Board Of Managers Of Towers On The Park Condominium v. Josefina Cruz, City Of New York Parking Violations Bureau, City Of New York Environmental Control Board, John Doe 1 Through John Doe 5

On August 09, 2017 a Motion-Secondary was filed involving a dispute between Board Of Managers Of Towers On The Park Condominium, and City Of New York Environmental Control Board, City Of New York Parking Violations Bureau, John Doe 1 Through John Doe 5, Josefina Cruz, for Real Property - Other (Condo Lien Foreclosure) in the District Court of New York County.

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FILED: NEW YORK COUNTY CLERK 05/17/2018 03:40 PM INDEX NO. 157132/2017
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 05/17/2018

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

BOARD OF MANAGERS OF TOWERS ON THE PARK
CONDOMINIUM, Index No. 157132/17

Plaintiff,
-against-

JOSEFINA CRUZ, CTTY OF NEW YORK PARKING DEFENDANT'S
VIOLATIONS BUREAU, CITY OF NEW YORK AFFIDAVIT IN

ENVIRONMENTAL CONTROL BOARD and "John OPPOSITION
Doe" Doe"
lthrough "John 5,
Defendants.

JOSEFINA
~ CRUZ, being duly sworn deposes and says:

l. I am the Defendant Pro Se in the above proceeding.

2. Pursuant to CPLR §3212, I submit that the following are the material facts in this case:

FACTS

3. The named Plaintiff in this case is BOARD OF MANAGERS OF TOWERS ON THE PARK

"Plaintiff'
CONDOMINIUM (hereinafter "Plaintiff"). The Plaintiff initiated the instant litigation when it

filed its Summons and Verified Complaint on or about August 7, 2017 and a Notice of Pendency

on or about August 8, 2017. ATTACHMENT "A".

4. Plaintiffs Complaint, under color of law, presumes to be an action to foreclose on a

condominium common charge lien recorded against the unit Defendant owns in Towers in the

Park Condominium located in New York and designated as Tax Lot 1009 in Block 1846 in the

Borough of Manhattan.

"B"
5. The instant Motion for Summary Judgment seeks an Order (ATTACHMENT ¶3):

Granting Plaintiff summary judgment and dismissing with prejudice the affirmative defenses and

counterclaims contained in Defendant's Amended Answer as without merit as a matter of law;

Appointing a Referee to compute the common charges, assessments, electric charges, storage

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fees, late fees, accrued interest and legal fees due and owing to the Plaintiff through the date of

sale of Unit 1J, 301 Cathedral Parkway, New York, New York 10026;

For such costs, legal fees, disbursements, and all other relief this Court deems just and proper.

6. To establish its prima facie case in the instant Motion, the Plaintiff relies on the Affirmation in

Support made by itsattorney, which relies on the affidavits of Nadine Kellogg and David

Fonseca. The affidavits do not say (i)that the statements are true or (ii) contain the language

"under the penalties of perjury", pursuant to CPLR §2106.

7. While courts have ruled that the absence of a proper certificate of - a defect in form -
conformity

is not always fatal and can be given nunc pro tune effect once properly acknowledged (JP

Morgan Chase Bank, N.A. v. S.I. Wood Furniture, 34 Misc 3d 1214(A), 946 NYS2d 67 [Sup. Ct,

Kings County, 2012]); Hall v ELRAC, 79 AD3d 427, 913 NYS2d 37 [NY A.D. 1st Dept., 2010];

Betz v. Daniel Conti, Inc., 69 AD3d 545, 892 NYS2d 477 [NY AD2d Dept., 2010}; Matapos

Ltd. v Compania Andina De Comercio Ltd., 68 AD3d 672 , 891 NYS2d 394 [NY A.D. 1st

Dept., 2009]; Moccia v Carrier Car Rental, Inc. 40 AD3d 504, 837 NYS2d 67 [NY A.D. Ist

Dept., 2007]; Smith v Allstate ins. Co., 38 AD3d 522, 832 NYS2d 587 [NY A.D. 2nd Dept.,

2007]; Falah v Stop & Shop Cos. Inc., 41 AD3d 638, 838 NYS2d 639 [NY AD2d Dept., 2007)];

Sparaco v Sparaco, 309 AD2d 1029, 765 NYS2d 6683 [NY AD3d Dept., 2003]; Nandy v Albany

Med. Ctr. Hosp., 155 AD2d 83, 548 NYS2d 98 [NY AD3d Dept., 1989]; see also Siegel,

Practice Commentaries, McKinney's Cons Laws of NY, Book 7B, C2309:3 at 348), Defendant's

concern in this regard goes beyond the technical requirement of CPLR 2309(c) and are based on

the prejudice she has suffered in a prior case (ATTACHMENT "C") that Plaintiff procured by

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fraud, misrepresentation and other misconduct Defendant respectfully requests that the

affidavits be stricken and deemed substantively palpably improper and inadmissible.

8. During a March 13, 2018 board meeting, the Board of Managers of Towers on the Park

Condominium made changes to its thereb>' President Pryor and Vice
officers, thereby removing

President Simmons and electing in their stead Kellogg and Kolins as President and Vice

President, respectively, for the remainder of this election cycle.

month.2
9. Therefore, Kellogg has been President of the Condominium Board for only a month. Although

she affirms that she is familiar with the books and records of the Condominium, she lacks direct

personal knowledge of the facts at issue. ATTACHMENT "D". Her lack of direct personal

knowledge makes the attorney's affirmation, as the Court of Appeals has firmly and consistently

ruled, insufficient for an award of summary judgment. Park Health Ctr. v. Green Bus Lines, /nc.,

App. Term., 2d & I IthJus. Dists., 2002 NY Slip Op. 40029[U]); Zuckerman v. City of New

York, 49 NY2d 557 [1980] ; Amaze Med. Supply, Inc. v. Allstate ins. Co., 3 Misc 3d 133(A),

[App Term, 2nd 4 1 l thJud. Dists, 2004]; Wisnieski v. Kraft, 242 AD2d 290, 6691 NYS2d 46

1997].
[NY A.D., 2d Dept., 1997]; Lupinsky v. Windham Constr. Corp., 293 AD2d 3 I7, 739 NYS2d

171 [NY A.D., 1st Dept., 2002]). Fonseca's affidavit (ATTACHMENT "E") fares even worse

since over the last five years he has been an on again, off again lawyer/debt collector who was

impermissibly retained to target Defendant. He certainly lacks direct personal knowledge of the

facts at issue and should have never authored the affidavit for some unfathomable reason.

(a)In one appeal, PlaintifPsex parte maneuvers caused Defendant lo default.whether or not her missing Oral Argument
could have changed the November I8,2015 affirmationofihe lower court's decision.(b) A motion for substantialadditional
tegalfees (in theamount of$21,390.09 plus interest)dated March 10, 2016, almost four months afterthe rightto recover
attorney'sfees had been waived. The motion thatviolated Civil Rule 82 and 58.1 was nevertheless granted (J.Sokotoff) on
August 24, 2016 and entered August 31, 2016.
2
After both thePresident and the Vice President of thecurrent cycle were deposed on March 13, 2018.

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10. To prove Defendant's point, Affiant Kellogg misstates that Defendant claims to have made

payment of judgments. ATTACHMENT "D", ¶¶ 14 and 15. This brings us to obvious

contradictions between Kellog's affidavit and the attorney's affirmation. In paragraph 7, affiant

Kellogg asserts that Defendant "failed to pay common charges and other fees billed by the

Condominium from November 2013 through June 2014". ld. ¶7. Paragraph 13 of the attorney's

affirmation (ATTACHMENT "F") states: "Cruz failed to pay common charges and other fees

over a lengthy period of time commencing November, 2013. Seven months is not a lengthy

period of time, especially ifother long-time delinquent home owners that are or were simply

monitored are factored in.The fact is that since Defendant resumed paying current maintenance

fees. However, the Condominium's Managing Agent processes her monthly payments

electronically but does not credit her home owner's account. Therefore, Defendant has been

forced to fileComplaint No. 1396178 in the Office of the NYS Attorney General. The case is

under investigation. ATTACHMENT "G".

"F"
11. The attorney's affirmation contains other errors. ATTACHMENT ¶¶ 17, 18. There are

inaccuracies in the recitation of the procedural history of the action bearing Index No. 7798

"H"
(ATTACHMENT ¶¶ 20-27) and also contradictions in ¶¶ 14 and 20. He also failsto disclose

that the insurer's attorney of record for action bearing Index No. 158208/2014 recommended the

condominium to settle with Defendant, after the insurance company declined the claim. On

information and belief, the Board did not settle because of (i)unfiltered personal animus of its

members against Defendant and (ii)spoliation of evidence, meaning that the Board possesses no

records. Finally, itis unclear what Plaintiff's attorney considers "a prior action pending seeking

relief'
the identical (¶20) as Plaintiff's instant foreclosure complaint.

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12. The Fonseca Affidavit states that his law firm commenced an action against Defendant on or

about March 17, 2014 seeking a money judgment for and including allegedly unpaid real estate

"E"
taxes (ATTACHMENT gtt 2 and 3), which Defendant disputes because NYC DOF bills

RETaxes directly to unit owners. Defendant's mortgagor has paid her RETaxes for fifteen years

out of an escrow account.

13. Plaintiffs Complaint, under color of law, presumes to be an action to foreclose on a

condominium common charge lien recorded against the unit Defendant owns in Towers in the

"B" "E"
Park Condominium. ATTACHMENTS at ¶9 and ¶l4. Plaintiff's attorney deliberately

conceals itbut in reality the defective lien that Plaintiff alleges to own and hold was filed by

Fonseca's firm (ATTACHMENT "I") and on information and belief is not a valid negotiable

instrument because Fonseca arranged for the then Managing Agent employee Mary Frances

Shaughnessy to materially and fraudulently pose as Special Secretary to the Condominium Board

to deficiently acknowledge the Notice of Lien before co-worker Ningchuk Cheng and make false

sworn statements to NYC Department of Finance and the NYC Registrar in the process of filing

Lien No. CRFN 2014000036016, which was not timely sent to Defendant3. .

14. Not surprisingly, affiant Fonseca does not discuss the deficiently acknowledged affidavits

authored by the then Property Manager Christine Ang that he used in court pleadings to procure

an award of summary judgment, either. Notably, the Court of Appeals has firmly and

consistently determined that an affidavit or affirmation from a party's attorney who lacks

personal knowledge of the facts is of no probative value and is insufficient to support an award

of summary judgment. Park Health Ctr. v. Green Bus Lines, Inc., App. Term., 2d & 11th Jus.

deficien1acknowledgment - -,
-, bearing Index No. -.
by Managing Company
This same
employees
employee
Christine
used the
Ang,
same fraudulent litleto file
, of
claims
lawsuit
of
entitled
unequal or
excessive assessment before tax authoritiesin2014, thistime along with co-worker David Goodman (DEF1 126).
ATTACHMENT "G".

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Dists., 2002 NY Slip Op. 40029[U]); Zuckerman v. City of New York, 49 NY2d 557 [1980];

Amaze Med. Supply, Inc. v. Allstate ins. Co., 3 Misc 3d 133(A), [App Term, 2nd & 11th Jud.

Dists, 2004]; Wisnieski v. Kraft, 242 AD2d 290, 6691 NYS2d 46 [NY A.D., 2d Dept., 1997];

Lupinsky v. Windham Constr. Corp., 293 AD2d 317, 739 NYS2d 171 [NY A.D., 1st Dept.,

2002]). Nevertheless, Fonseca procured a summary judgment without evidence.

15. Under these circumstances, plaintiff does not have the legal rights required as a matter of law to

bring an action to foreclose on the condominium common charge lien or on Defendant's unit (or,

attorneys'
for that matter, demand the fees awarded to the Condominiurn in two money

judgments which, though procured by fraud, were also affirmed by the Appellate Term. ld. at ¶¶

10-12. In its latest pleadings Plaintiff could not - and does not - assert that itcomplied with RPL

339-j and Article IX, §§ 1 or 2 of the Condominium By-Laws to the Declaration, which require

Plaintiff to send Defendant, at the inception of this case, the fraudulent Notice of Default

described above as well as an intention to File Notice of Lien, which are the appropriate legal

proceedings.

16. Attorneys are supposed to report even when committed their but Fonseca - who
fraud, by client,

is an Officer of the Court - filed two different fraudulent versions of his Detail Transaction File

List with two different dates. ATTACHMENT "J". The 2015 version covered dates 1/3/2014 TO

2/19/2015 while the 2016 version starts on 12/30/2014. A fact-finder that compares Fonseca's

2015 and 2016 ledgers will find sufficient incriminating evidence. Northrop v. Thorsen, 46

A.D.3d 780, 782, 848 N.Y.S.2d 304, 308 [2d Dep't 2007]). Plaintiff nevertheless prevailed in

lower court and was affirmed on appeal. Now he takes itupon himself to support his former

client's cause against a Defendant he himself seriously aggrieved.

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17. In addition, Plaintiff's Motion for Summary Judgment wrongly sets forth a listof Defendants in

"A" "B" "D"
its Schedule (ATTACHMENT at 2 and ¶¶ 3-6 at 2). In its Complaint, Plaintiff

'A'
alleges that "[t]he defendants set forth in Schedule reside or have a place of business at the

address set forth therein and are made defendants in this action in the capacities therein alleged

and for the purpose of foreclosing and extinguishing any other right, titleor interest said

"A"
defendants may have in the subject Unit". ATTACHMENT )gal 3-6.While Defendant does

not understand why the NYC Parking Violations Bureau and the Environmental Control Board

"1" "5"
appear as Defendants, John Doe through should not. Defendant Cruz is thesole occupier

of Unit 301 #13 at and there are no rental agreements. Defendant will cross-
present, Therefore,

move to have the John Doe's removed from the instant caption.

18. Similarly, Plaintiff alleges that the Declaration and the By-Laws of the Condominium were

amended on August 8, 2011 and on June 19, 2012, which were recorded on March 16, 2017,

bearing City Register File No. 201700102676 and 20 I 7000192677, respectively.

"A" "D"
ATTACHMENT ¶7 and ¶ 7 at 3. The validity of the amendments in question

(ATl'ACHMENT "K"), which were also deficiently acknowledged by Managing Agent

employee Christine - a in interest - has been disputed prior Board member Linda
Ang party by

Reynolds, who filed an Article 78 Petition entitled Reynolds v. Towers on the Park

Condominium that bears Index No. 100624/2017. ATTACHMENT "L".

19. Citing to New York Nat. Bank v. Harris, 182 A.D.2d 680, 680-81, 582 N.Y.S.2d 278, 278-79 (2d

"defendants'
Dep't 1992), Plaintiff's attorney contends that allegations challenge only the

amount due and owing to the plaintiff, as their claims, ifproven, might be offset against the

amount due and owing to the plaintiff". I guess, even if Defendant raises issues of fact that

would warrant the denial of summary judgment for the Plaintiff? Very persuasive, indeed!

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20. In this regard, Defendant welcomes the appointment of a Referee to compute the correct

common charges, assessments, electric charges, late fees, accrued interest and legal fees due and

"B"
owing by Defendant (which should not include RETaxes or storage fees). ATTACHMENT

¶¶ 10-12 and Chester MOL ¶l 8. However, on information and belief Plaintiff has no supporting

documents, basically due to intentional spoliation of evidence. Most claims raised by Defendant

"M"
are contained in her Amended Answer, ATTACHMENT ¶¶ 6-3 I, 37-42 and in the section

Discriminatory Treatment.

21. At this point, Defendant can rest her case and leave in more competent hands the above

computation of budgets and assessments, developing a formula for late fees, attorney's fees, etc.

Through a lawyer retained for that purpose, from Day One, in both December 2013 and April

2014 Defendant offered to pay what she truly owed. ATTACHMENT "N". Defendant is

preparing and will submit an affidavit which will hopefully be used as evidence in this regard.

STANDARD OF REVIEW

22. Summary judgment is proper when, based on an examination of evidence, no genuine issues of

material fact exist and the movant is entitled to judgment as a matter of law. Fed.R.Civ.P. 56.

The movant carries the initial burden and must show the Court that there is "an absence of

case."
evidence to support the nonmoving party's King v. Asset Acceptance, LLC, 452 F Supy

2d 1272 - Dist. Court, ND Georgia 2006

23. "In reviewing a motion for summary judgment, the Court must construe the evidence and all

party." WSB-
inferences drawn from the evidence in the light most favorable to the non-moving

TV v. Lee, 842 F 2d 1266, 1270 (/ lth Cir.1988). The Court must also take all the facts that the

non-movant states as true and must draw allreasonable inferences in favor of the non-moving

party. When the non-movant ispro se, the requirements should be less stringent.

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DEFENDANT'S ANSWER 10 THE CHESTER MEMORANDUM OF LAW

24. Under Point 1, Plaintiff's attorney states that the Condominium has established itsprima facie

right to judgment as a matter of law by submitting evidence of itsauthority to collect such fees

pursuant to relevant sections of the Declaration of Condominium and By-Laws.
-Laws. ATTACHMENT

"O"
(Chester MOL) at 1. Unfortunately, such documentary evidence is often misinterpreted for

self-serving reasons. In a conclusory fashion, he adds that Defendant's affirmative defenses and

in her Amended Answer (ATTACHMENT "M") fail to raise any material issues

ol'
of fact and asks the court to dismiss and grant summary judgment. Defendant disputes this

assertion but agrees with the appointment of a Referee who - with the By-Laws -
complying

attorneys'
compute common charges, assessments, late fees, interest and fees. Defendant is

pleased that the listdoes not include real estate taxes (which the Condominium never paid for

Defendant but Fonseca included in the charges the civil court approved).

A. Based on competent evidence, Defendant disputes that common charges and

assessments were properly imposed as provided for in the Declaration and By-Laws.

B. Based on the evidence submitted by Plainti ff,Lien CRFN 2014000036016 is invalid.

C. It isuncontroverted that the Condominium has earned money judgments (but said

judgments were procured by fraud).

D. If the Condominium is entitled to summary judgment to foreclose its lien and to

attorneys'
collect all arrears, including fees, why resort to fraud?

25. Under Point II, Defendant understands that itis the judge who will determine whether her

affirmative defenses are or are NOT meritless as a matter of law. Defendant is aware of the

stakes (not just money but perhaps her place of residence), but she claims the ultimate right to

state her truth and present the admissible evidence available to her. In addition, Defendant asserts

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that in no other claim has she raised the issue that the Board has no standing as an affirmative

defense, so it is wrong to say this is repetitive. And she has never claimed she was not served

with process. Defendant has already submitted evidence that the alleged debt has not been

proven by Plaintiff. It appears that these amounts must be submitted to a Referee for review, so

there is no need for argument. The proof is in the pudding. The method of calculation of

common charges established in the Chester Affirmation must conform to the By-Laws

provisions. The issue is not rent overcharges, as the Plaintiff's attorney argues, citing to Nicholas

(l"
A. Gravante, P.C. Empt. Pension Fundy. Gennaro / ombardiCorp., 228 A.D.2d 231 Dep't

1996), but a contract that must be complied with.

26. With regards to sending a Notice of Default, RPL §339-j and Article lX §l are the legal

requirements covering this issue. The interests and fees are not only excessive: There is no

formula for calculating them, as has been often pointed out. In addition, Defendant has made

maintenance payments and has Chase Bank statements to prove that she mailed the checks and

that merchant TOP Check PMTS ARC lD:9000277241 cashes them. What is happening since

September 2017 is that the Managing Agent has processed her payments electronically (on 9/12,

10/11, I1/09, 12/08, 2017 and 1/9, 2/9, 3/9 and 4/10 2018) but has not credited her account.

After notifying Argo Real Estate LLC, Defendant had to file Complaint No. 1396178 in the

Office of the NYS Attorney General. The case is under investigation. ATTACHMENT "G".

27. Under Point ill.Plaintiff's attorney makes many statements in a conclusory fashion, like

counterclaims that are duplicative of Defendant's affirmative defenses, and that there was no

discrimination against Defendant. Itshould be up to the Court to decide if her counterclaims or

affirmative defenses survive.

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28. Finally, Defendant want to address Plaintiff's attorney directly and state as follows with regards

to the section labeled ARGUMENT at p. 3:

It is surprising to find rilanguage so disrespectful of a litigant who is Pro Se in a

Memorandum of Law. Courts should also abhor attorneys who attempt to intimidate

and scare the self-represented in such a vicious manner. It should not be allowed in

Of icers of the Court. You should not be outraged but rather be grateful if my

ignorance makes iteasy for you to prevail and earn ri fortune. I, to the contrary,

respect your right to do your job but understand there is a huge difference between you

and I. You see, in your case this is about prestige and money, but in my case I am a

retired NYC public school teacher, on a fixed income and defending my place of

residence. I believe I deserve an apology.

29. Summine up: The Plaintiffs Motion Should Be Denied. The Supreme Court has held that a

judge's function is not to determine the truth of the matter asserted or weight of the evidence

presented, but to determine whether or not there is a genuine issue for trial.Anderson v. Liberty

Lobby, Inc., 477 U.S. at 249, 106 S.Ct. 2505 (1986). In making this determination, the facts are

to be looked upon in the light most favorable to the nonmoving party. Celotex Corp. v. Catren,

Plaintifi"
477 U.S. 317, 323, 106 S. Ct. 2548(1986). This all means that, to prevail, the Plaintiff's

summary judgment motion must show that (i)there are no genuine issues of material fact, and

(ii)that s/he is entitled to judgment as a matter of law. Fed.R.Bankr.P. 7056(c); Anderson v.

Liberty Lobby Inc., 477 U.S. at 250. In this case, Defendant believes there are triable, genuine

issues of material fact, making summary judgment inappropriate.

30. The record shows that Plaintiff did not send a Notice of Default pursuant to RPL §339-j and

Article IX Section 1 of the By-Laws of the Condominium and has failed to show that ithas any

right to foreclose on Defendant's home.

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31. Competent and admissible evidence submitted by Defendant negate the Plaintiff's four causes of

action.

32. The undisclosed maneuvers prove that the TOP Board breached itsfiduciary duty. However,

without disclosure Defendant did not have enough facts to be sufficiently aware of her real

claims and was unable to seek damages for the Board's derogation and breach of the bylaws and

of the implied covenant of good faith and fair dealing.

CONCLUSION

WHEREFORE, Defendant moves the Court to:

Deny Plaintiffs Motion for Summary Judgment as improper;

Strike Plaintiffs Affidavits

For such other and further relief as is proper.

Respectfully submitted

DATED: New York, N.Y. L..

May 15, 2018 Josefina ruz$o Se
301 C hedral Parkway #1J
New York, NY 10026

(212) 222-0371

TO: Robert Chester, Esq.
AND/OR
Bonnie Reid Berkow, Esq.
WAGNER BERKOW, LLP
23"1
1410 Broadway, Floor
New York, NY 10018
Tel (646) 780-7272

15th
Sworn to before me this

day of May 2018.

OKEY ARIZOR
Notary Public,Stateof New ibrk
No. 01AR6189659
Otary 1C Qualifiedin Bronx County
Commission ExpiresJune x
30, 20.-.

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V

FILED: NEW YORK 1COUNTY CLERK 08 09 /2017 10 : 19 W INDEX NO. 157132/2017

NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/09/2017

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------------------------------------------------------------------x
'
BOARD OF Plaintiff designates
MANAGERS OF K)WERS ON THE PARK
New York County as the
CONDOMINItJM,
place of trial.

Plaintiff,
Basis of Venue: Property
- against - located in New York County

JOSEFINA CITY OF NEW S U M M O N S
CRUZ, YORK PARKING
VIOLATIONS BUREAU, CITY OF NEW YORK
Index No:
ENVIRONMENTAL CONTROL BOARD and the following Date of Filing:
persons or parties being either tenants or occupants of the
liened premises or persons or parties or to
having claiming Plaintiff'sprincipal place of business
have a right, titleor interest in the liened premises herein is
being located at:
sued fictitiously because their representative names are 301 Cathedral Parkway
unknown Doe"
presently V ) ~~ to
)V the
U)L plaintiff, ~.) "John
IVII)
i.e., ) ~WC 1 through New
)>> York, New York 10026
Doe"
"John 5,
Defendants.
â€”â€”
-------------r----------------------------------------------------------x
----"-X
Property Address: 301 Cathedral Parkway, New New York Unit
York, 10026, 1J

To the above named Defendant(s):

You are hereby summoned to answer the Complaint in thisaction and toserve a copy of your

Answer, or, ifthe Complaint is not served with this to serve
Summons, a notice of appearance, on the

Case Info

Judge

JAFFE, BARBARA Track Judge’s New Case

Case No.

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Document Filed Date

May 17, 2018

Case Filing Date

August 09, 2017

County

Parties

BERKOW, BONNIE REID Attorney for the Plaintiff
Board of Managers of Towers on the Park Condominium Plaintiff
BRANDT, IAN JASON Attorney for the Plaintiff
CHESTER, ROBERT AMORY MYERS Attorney for the Plaintiff
City of New York Environmental Control Board Defendant
City of New York Parking Violations Bureau Defendant
John Doe 1 through John Doe 5 Defendant
Josefina Cruz Defendant
KHINDRI, NIKI KUMARI Attorney for the Plaintiff
PANUSH, DON Attorney for the Defendants
MARIO FONSECA Attorney
ROBERT CHESTER Attorneys for Plaintiffs
TERRY LICHTASH Attorneys for Plaintiffs
CAROL DUNNING Attorney

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Motion-Secondary: Board Of Managers Of Towers On The Park Condominium v. Josefina Cruz, City Of New York Parking Violations Bureau, City Of New York Environmental Control Board, John Doe 1 Through John Doe 5

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