FOR

IMMEDIATE RELEASE


When newlyweds Matthew and Katherine Smith saw the historic home for sale on
Jermain Avenue in Sag Harbor in 2013, they immediately felt a nostalgic connection
to the property a stones throw away from where they first met in 2007. Fast
forward to 2014, with a new baby in their arms, the Smiths were excited for the
architectural plans that reflected their dream for the new home. According to a
Complaint filed this week in Suffolk County Supreme Court, that excitement would
be short-lived.

As set forth in the Complaint, the Smiths hired Michael Nobiletti, of Nobiletti
Builders in Water Mill, New York, to renovate the historic, yet dated home that they
purchase.

The Complaint alleges that Nobiletti commenced construction work in 2015, after
the renovation plans were unanimously approved by Sag Harbors Zoning Board of
Appeals and its Architectural Review Board. According to the Complaint, Nobiletti
initially quoted the Smiths a price of $652,000 for the renovation and promised
them that all work would be completed within six months. But, the Complaint
alleges, today, $2.5 million dollars and 18 months later, the home remains
unfinished. Moreover, according to the Complaint, it is riddled with incomplete
work that the Smiths must pay another builder to complete, multiple unfinished
rooms and bathrooms and with no certificate of occupancy.

Worse yet, according to the Complaint, Nobiletti conspired with subcontractors he
employed to fraudulently inflate invoices, demand kickbacks, and otherwise defraud
the Smiths of money. The Complaint alleges that over a period of three years,
Nobiletti misrepresented costs, accepted kickbacks, and manipulated invoices all the
while failing to provide basic oversight and coordination. Without proper
supervision and basic site security, thousands of dollars of material disappeared and
critical workers frequently failed to show up to complete necessary tasks. As set
forth in the Complaint, over the course of 2015, the Smiths dream home turned into
a nightmare as they watched the original budget and timeline grow exponentially as
progress slowed to an unbearable pace.

The Complaint alleges that in early January of 2016, now expecting their second
child, it became clear that while the Smiths were working in New York City, Nobiletti
and some of his subcontractors capitalized on their vulnerabilities to charge
outlandish costs for subpar construction. According to the Complaint, in April of
2016, three weeks prior to the Smiths anticipated move in date, Nobiletti jetted off
to a "$35,000 trip of a lifetime to the South Pacific during which time the Smiths
building permit expired. The Complaint provides that on April 6, the Village
building inspector called Nobiletti to inform him that the building permit was about
to expire but could be extended for free with a simple letter. According to the
Complaint, instead of writing the letter, Nobiletti allowed the building permit to

expire and it will now cost five thousand dollars to renew before a certificate of
occupancy can be issued. The Complaint alleges that when the gaffe was brought to
Nobilettis attention, he refused to pay to extend the permit, thus further delaying
the certificate of occupancy.

As set forth in the Complaint, following the birth of their son, in early May of 2016
and the expiration of their lease extension in Manhattan, the Smiths were forced to
move into the yet-uncompleted Sag Harbor home. Instead of enjoying a peaceful
summer in their new home with their young children, the Smiths have been
subjected to a daily construction site with myriad of workers trying to finish what
Nobiletti could not. The Complaint asserts that as the details of the alleged fraud
began to emerge, they were forced to hire new contractors to complete the project.