CIVIL COURT OF THE CITY OF NEW YORK COUNTY OF NEW YORK: HOUSING PARTB i000 05 > RAFABL GARCIA; LUZ GONZALE: YSABEL LARA; DORIS CASTILLO-DIAZ; RUFINO TEJADA; SUANA SANTANA; CARMEN SOSA; ROSA LENDEBORY; VIRGINIA PERALTA; CONRADO RODRIGUEZ; INDEXNO. \(Q |e /\ 7 Petitioners, cagainst. > * ORDER TO SHOW CAUSE, DORAN REALTY CORPORATION; FELIX GOMEZ; AARON BAUE] Respondents, DEPARTMENT OF HOUSING PRESERVATION PREMISES: AND DEVELOPMENT; =. °° 61-71 VERMILYEA AVENUE DEPARTMENT OF BUILDINGS; NEW YORK, NEW YORK 10034 Co-Respondents. Vip i Wai ain, a pi wk pont es al et, pod el sete ae ping teh (ORDERED tat Respondents crc to appear befr this court and show esta “vit Tem af the Housing Faso the Civil out ofthe iy of New Yok, Part, locate courthouse of 11 Conse Suet New York, Now York onthe IT day ot Fe Spenry, 2017, at G3? "etek of tat dy or 8 son there the panes may be her, hy an order should not be entered: 1. Directing Respondents to correct any and all violations of law existing at the subject premises plus any and all conditions constituting violations, including but not Limited to the MDL, HMC, and various other New York City laws, Codes, Regulations, and Rules, and further directing them to maintain the premises in conformance with the law;2 Directing Respondents to update Pestonrs, HD, en this Cour on a weekly bass a to the progress ofthe reasonable plan to coet sid canditons in the Buildings 3. Enjoining Respondents from pemniting sid violations to exist and from pesmiting any {ature conditions to exist which endanger the lif, health and sfety ofthe Petitioners; 4. Imposing civil penalties in an amount tobe determined by the Cour, but no less than the amount required by the NYC Admin. Code § 27-211 5. Awarding actual damages to Petitioners in an amount tobe determined by the Court; 6. Awarding reasonable attomeys’ fees fo Manhattan Legal Services in an amount to be determined by the Court 7, Awarding costs and disbursements of this action for Petitioner; and 8. Awarding such other and further relief as this Court deems just and proper. IT IS FURTHER ORDERED that service of a copy of Order, toser with the paper pon which twas granted upon each Respondent by peronl service andlor Sue certified mail wth tum recep requested speed by NYC Admin, Code § 21150), on ot before the 27 “tay of Vaaensna/ 2017, be deemed good and suiient servic, and these papers, together wih prof of service thereof, may be etumed ono before the eum date ofthis poceding ina (72507 New Yor, New YorkCIVIL COURT OF THE CITY OF NEW YORK COUNTY OF NEW YORK: HOUSING PART B RAFAEL GARCIA; LUZ GONZALEZ; ‘YSABEL LARA; DORIS CASTILLO-DIAZ; RUFINO TEJADA; JUANA SANTANA; CARMEN SOSA; ROSA LENDEBORY; VIRGINIA PERALTA; CONRADO RODRIGUEZ; Petitioners, against VERIFIED PETITION DORAN REALTY CORPORATION; FELIX GOMEZ; ‘AARON BAUER; Respondents, DEPARTMENT OF HOUSING PRESERVATION AND DEVELOPMENT OF THE CITY OF NEW YORK; DEPARTMENT OF BUILDINGS; Co-Respondents Petitioners, for their verified petition against Respondents, respectfully allege 1. Petitioners are tenants of two Class A multiple dwelling buildings located at Gt Vermilyea ‘Avenue, New York, New York 10034 (hereinafter “Building 61°) and 71 Vermilyea ‘Avenue, New York, New York 10034 (hereinafter “Building 71"). 2. Petitioners have instituted this proceeding pursuant to the New York City Administrative Code (‘N.Y.C. Admin. Code”) §§§ 27-2115(h), 27-2115() and 27-2121; New York City Civil Court Act (*CCA”) §§§ 110(@)(4), 110(2)(7), and 209(6)(2}; and New York State Real Property Actions and Proceedings Law (“RPAPL”) § 211 5. Petitioners seek the correction of any and all violations and other conditions that are ‘dangerous to life, health and safety existing in their building, including but not limited to, violations of the New York State Multiple Dwelling Law (*MDL"), the Housing Maintenance Code (“HMC”), the Building Code, the Fite Code, and various other New York City Codes,it 12, 1B. BACKGROUND; PETITIONERS Petitioner ROSA LENDEBORY is the tenant of Apertment 3G in Building 61. Ms. Lendebory has lived in Building 61 for fly (50) yeas, Petitioner VIRGINIA PERALTA is the tenant of Apartment 21 in Building 61. Ms, Peralta has lived in Building 61 for twenty-five (25) yeas, Petitioner CONRADO RODRIGUEZ is the tenant of Apartment 2M in Building 61. Me. Rodriguez hes lived in Building 61 for two (2) yeas. Petitioner JUANA SANTANA is the tenant of Apartment 4G in Building 61. Ms. Santana has lived in Building 61 for thirty-seven (37) years Petitioner RUFINO TETADA is the tenant of Apartment 4H in Building 61. Mr. Tejada has lived in Building 61 for approximately eight (8) years Petitioner LUZ GONZALEZ:s the tenant of Apartment lin Building 61. Ms. Gonzalez ‘has lived in Building 61 for sixteen (16) yeas. Petitioner CARMEN SOSA isthe tenant of Apartment 2D in Building 71. Ms. Sosa has lived in Building 71 for thirty-four (34) years. Petitioner DORIS CASTILLO-DIAZ is the tenant of Apartment 28 in Building 71. Ms CCastillo-Diazhas lived in Building 71 for ten (10) years. Petitioner RAFAEL GARCIA is the tenant of Apartment IC in Building 71. Mr. Garcia has lived in Building 71 for four (4) years. Petitioner YSABEL LARA is the tenant of Apartment 4A in Building 71. Ms. Lara hes lived in the Building 71 fo forty-one (41) yeas. .D: RESPONDENTS Respondent DORAN REALTY CORPORATION is registered as the owner with the16. 17. 18, 19. 20, 21 2, 2B. m, Department of Housing Preservation and Development of the City of New York (bersinafer HPD"). A tre and comet copy of HPD’s Building Registration Summary Reports annexed hereto as EXHIBIT A. Respondent FELIX GOMEZ is registered asthe head officer and managing agent with HPD, See EXHIBIT A, Respondent AARON BAUER as registered as the officer with HPD. See EXHIBIT A Respondent(s)" shall refer DORAN REALTY CORPORATION, FELIX GOMEZ, aud AARON BAUER collectively. n the event that any Respondent removed from this matter the remaining partes shall coninve tobe refered o as “Respondent(s.” Respondents list ther offices at 1624 Webster Avenue, Bronx, New York, 10457. See EXHIBIT A Respondents ore owners of the premises as that term i defied in MDL § (44) and in the MMC, N.¥.C. Admin, Code § 27-2008(aK45). ‘Co-Respondent HPD isthe municipal agency charged with enforcement of, iter alia the Housing Maintenance Code (“HMC”). Accordingly, HPD is a proper party to this ‘proceeding pursuant to New York Civil Court Act § 110(@). (Co-Respondent HPD is located at 100 Gold Street, New York, New York 10038. Co-Respondent Department of Buildings (DOR) is a named Co-Respondent herein pursuant to the provisions of the CCA § 110(4). DOB is located at 280 Broadway, 7 Floor, New York, New York 10007. REGULATORY SCHEME ‘A tenant or group of tenants may petition the Court to order HPD to inspect and issue violations against a landlord-owner for conditions in violation of the Housing2s, 26. 21. 28. 29, 30, 3 Maintenance Code, NYC Admin. Code § 27-2002. A tenant or group of tenants, may bring a Housing Part Action seeking an order ditectng the owner to correc all violations found by the Coun, dat §27-2115(H) Respondents are oblgned to Keep the promises in good repair ané to comect all ‘ioltions of law. Upon Respondents” ile to creche violtons in the time required snder the Housing Maintenance Code the court shall impose civil penalties aginst the owner. t § 27-2115. sued several violations for the Building, and as such, Co-Respondent HPD has Respondent-Owners ate required to correct said violations. Respondents are willfully and recklessly violating the Multiple Dwelling Law, the Housing Maintenance Code, and vatious other New York City Codes. FACTUAL ALLEGATIONS Upon information and belief, Building 61 and Building 71 are five (5) stores each and ave a combined total of sixty-five (6) units. Upon information and belit, the Building 61 and Building 71 are subject to rent: egulation. Most if not all, of the units are rent stabilized. “There currendy exist defects and open violation i the building tht are dangerous to the health and safety of the tenants and which constinte violations of the HMC and other laws that regulate housing standards See EXHIBIT A. These violations are in need of immetiat rept To date, there are approximately one-hundred (100) violations recorded with HPD including twenty-three immediatly hazardous “C” violins, See EXHIBIT A. These violations include, but are not limited to, those described in The Schedules annexed32, 33, 35, 36 3, 38 39, 40. 41 hereto as EXHIBIT B and made «pat hereof, and the violations recorded with HPD, annexed hereto as EXHIBIT A. Building 61 and Building 71 are heavily infested with roaches, mice, and rats Petitioners apartmens are similarly infest with roaches, ts, and mice ‘Building 61 and Building 71 lack an operable intercom system, ‘Walls ceilings and floors thoughout Petitioners” apartments contain cracks and holes. Building 61, Building 71, and many of Petionrs' apartments have not been pisted in several years Petitioners’ apartments only have heat and hot water ding the afternoon ~ there i no heat or hot water during the evening hows, even when the temperate outside falls Below 55 degrees outside. Petldoners fave made te Respondents avare of the conditions in thir respective sparen and Huiling 61 and Building 71, Nevetcles, Respondent have repeatedly filed to inspect and repair as requiced by law said contitions in Petitioners” apartments snd in Building 61 and Building 71 Several Petitioners have personally spent money to have repics made othe individual sparen ‘According to Petitioners, when Respondents send someone to corect the conditions in ther apartments, the epaic jobs poor and inadequate Petitioner Doris Castille-iaz hs documented the repairs she hs personally made to her ‘partment and photos of the inadequate repsirs made by Respondents’ agents, See ‘Photographs annexed hereto as EXHIBIT C. Several Petitioners have previously commenced prose HP actions agnnst Respondents42. Respondents have repeatedly been notified of the conditions in the Building, Petitioners ‘have been and remain willing and available to have the conditions in their respective tobe freely and liberally available, upon reasonable notice. 43, Respondents have taken the aforementioned actions that have made Petitioners’ lives intolerable. Upon information and belief, these actions constitute harassment and were and continue to be designed to make Pestones’ lives sufficiently miserable so that, Petitioners would surrender tenancy rights 44, Despite this the conditions inthe Building emsin unabated, Respondents have fled or refused to repair the conditions complsined of in Petitioners’ apartments or the public areas ofthe Building, WHEREFORE, Petitioners demand: A. An order dieting Respondents to coret any and all voltons of law existing at the premises plus any and all conditions constiusing violation, including but not limited to the MDL, FIM, and various other New York City laws, Codes, Regulations, and Rules, and futher directing them to msntin the premise in conformance with hel; B. Issuance of an immediately hazardous Class C violation for harassment ©. An order directing Respondents to update Petitioners, HPD, and this court on a ‘weekly basis ast the progress ofthe reasonable plan to costect sid conditions atthe subject premises; 1D. Imposition of civil penalties in an amount to be determined by the Cour, but noTess than the amount required by the NYC Admin. Code § 27-2115: BE. Reasonable attomey’s fees to Manhattan Legal Services in an amount to be determined by the Cour; and F, Such other and further relieas this Court deems just and proper. Dated: Janvary 24,2017 MANHATTAN LEGAL SERVICES ‘New York, New York By: ha C. Elstob-Wesley, Rita Vega, Law Graduate Attorneys for Petitioners 5030 Broadway, Suite 664-666 ‘New York, NY 10034 (646) 48223145VERIFICATION STATE OF NEW YORK ) ) COUNTY OF NEW YORK ) Petitioners, being duly sworn, depose and say: 1 Me are tenants or legal occupants at 61 Vermilyea Avene or 71 Vermilyen Avene, "New York, New York 10034, and are Petitioners in the above captioned proceeding 2. We have reviewed the within Petition, ‘annexed to the Petition, and we affirm th (our knowleilge. As to those matters state ‘obe tue, Rosa Lendebaty, 6/Vermilyea Apt 3 Swormto Before me this_}1 day of 2017 AAR ‘Conrado Rodriguez, 61 Vermilgea Apt 2M ‘Swom to Before me this_/] day of 2017 Eugron wen asinceN Netra Saat aon terse te HPD online violation report, and schedules atthe facts stated therein are tue to the best of = upon information and belie, we believe them ines ‘Vermilyea, a a Sworn to Before me this [day of (eg Sentana, 61 eas ‘Apt 4G ‘Swom to Before me this 177 day of Browwesey pte eae ‘ary Public’ Oumeines Sonyiota oF ‘sna RRL a Sworn to Before me this [day of Rafiel Garcia, 71 Wéemilyes Apt. IC ‘Swom to Before methis_[] day of a Til se Doris Castillo-Diaz, 71 Vernilyea Apt. 2° —~- Swom to Before methis |] day of onary 2017 Rorovwesey acai LC é KR Ney nate aura ree ‘ fotary Public ‘Connon on ny ‘Yablel Lara, 71 VermliyedApt 4 ‘Sworn to Before me this | f day of % ANSTO Carmen Sosa, 71 Veruilyea Apt. 2 ‘Swom to Before me this | day of Swom to Before me this day of a 2017 Nn ecaane ‘emannncpos Se 2 Notary Publiswoir icdthigie ies SET Tiaeat ties 1 RE OR, TT aN Sm am Sas itt Mata a lon fon nd omen Renewal at eon ER BSE LE Sy fe Alte fom may ugeane coe a Tle ares ats known as: os mpaniratyewgtPDertneboet metingwoz Ho Buran v0 Bang, aapcrmion 8 ontin Sevee(=ERT=S) tae ‘Thesdauc addres: 61 VERNGLVEA AVENUE, Neahoron 10030 hls bulling hae tld records withthe aw Yoo sate Dvsion of Housina ang Communlty Ransual 3¢ {Shee one tima trom 1999 0 tho present Your snd ay contain dns OF mors repulsed Sparen a fae Bek CD Grind Gis Ann BU Omen Det Can param] man Building Rogictration Summary Report essen | tind Apartment ee eee Se fan" focee towns au forser 42/206 EAGER Anno wee NEES ane wy | lemon hota = tear aon totoanie — bORa REET Tae WEST eeomc wr ee sul Cowowron we a Le GEN ie VETO aoa ioe gta ot |ome™™ _se/any Ie ae oe GAR vO ae NERET® arom av 1047 ies iene ‘Open Violations ~ ALL DATES ‘There aye 100 Violations. 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Ba Se Sasreecre ceca” Sen, es Sree neaae eat SR Sp = ae ea ae F Sema Ee eeceereere Bia, ee Se ae Be pra tps rhea peningSCHEDULE A-61 and 71 Vermilyea Avenue ‘Counsel: Aisha Elston-Wesley, Esq, & Rita Vega, Law Graduate ROSA LENDEBORY ~ 61 VERMILYEA APT. 36 ‘THROUGHOUT BUILDING + Broken intercom system + Broken lock on the building entrance door ‘THROUGHOUT APARTMENT Roaches © Mice © Tnedequate heat > Inadequate hot water BATHROOM + Broken bathtub © Water leaks from the sink ‘+ Hole inthe ceiling near the heating pipe BEDROOM ‘© Broken window Broken floor tle KITCHEN + Pipe leak under the sink «Broken faucet VIRGINIA PERALTA ~ 61 VERMILYEA APT. 21, ‘THROUGHOUT BUILDING + Broken lock on the building entrance door © Tnadequate light in lobby and stairs ‘Broken intercom system ‘© Trash in hallways, stairs, lobby, backyard and building entrance ‘+ Lobby and hallways need new paint ‘© Building inspection card isnot visible + Rodents + Tnadequate heat + Inadequate hot water ‘THROUGHOUT APARTMENT© Mice + Apartment needs tobe painted * Inadequate heat ‘+ Inadequate hot water ‘© Cracked ceiling and walls ‘+ Broken front door lock + Dinty windows BATHROOM + Ceiling fas + Moldin ceiling 4+ Broken barb faucet 4 Toilet doesnot sh ropely KITCHEN + Sink and fost ak + Roiten floor + Detective electra outlets LIVING ROOM © Uneven floors Dt mez ‘THROUGHOUT BUILDING ‘Broken lock on the building entrance door ‘+ Broken intercom system + Mice © Roaches ‘THROUGHOUT APARTMENT Inadequate heat Inadequate hot water Roaches Mice Intercom system does not work Need new paint Uneven floors Cracked floor tiles BEDROOM © Walls cracked Broken windows + Defective electrical outlets+ Lights have to be tamed off by unserewing the light bulb BATHROOM © Rusted toilet Ceiling leaks Clogged bathtub Clogged sink Broken floor tiles Door does not close Mold ‘Wall leaks KITCHEN, ‘+ Broken stove ‘© Broken cabinets + Broken floor tiles IUANA SANTANA ~ 61 VERMILYEA APT. 4G THROUGHOUT BUILDING *+ Broken lock on the building entrance door ‘+ Inadequate light in lobby and stairs ‘+ Broken intercom aystom, ‘Trash in hallways, stairs, lobby, backyard and building entrance + Lobby and hallways need new paint + Building inspection card isnot visible = Rodents © Inadequate heat Inadequate hot water ‘THROUGHOUT APARTMENT © Mice * Roaches = Inadequate heat ‘© Inadequate hot water LUZ GONZALEZ ~ 6] VERMILYEA APT. 4, ‘THROUGHOUT BUILDING Broken lock on the building entrance door and back door * Window in lobby does not properly close ‘+ Broken intercom system + Rodents+ Roaches THROUGHOUT APARTMENT © Mice * Roaches ‘Broken intercom system + Inadequate heat Inadequate bot water + Entrance door frame is broken ‘© Apartment needs t be painted KITCHEN + Ceiling leaks Mold Peeling plaster on the walls end ceiling Electrical wiring needs to be re-done Holes: Broken floor tile LIVING Room Broken floor tiles BEDROOM + Broken window + Nobeat BATHROOM Pipes leak Ceiling aks ‘Walls around the bathtub leak Mold Broken window UFINO TEA ‘THROUGHOUT BUILDING ‘+ Broken lock on the building entrance door ‘Inadequate light in lobby and stairs Broken intercom system + Broken mailboxes VERMILYES APT. ‘Trash in hallways, stairs, lobby, backyard and building entrance Lobby and hallways need new paint Roaches Mice* Broken roof door THROUGHOUT APARTMENT © Mice + Roaches ‘Broken intercom system, © Inadequate heat Inadequate hot water ‘+ Entrance door frame is broken * Apartment needs to be painted + Mold KITCHEN Broken refrigerator Broken cabinets LIVINGROOM + Radiator leaks BATHROOM © Pipes leak * Poor water pressure + Broken floor tiles ‘DORIS CASTILLO-DIAZ ~ 71 VERMILYEA APT. 28 THROUGHOUT BUILDING * Broken lock on the building entrance door ‘+ Inadequate light in lobby and stars Trash in hallways, stair, lobby, backysed and building entrance * Building inspection card isnot visible + Rodents © Inadequate heat THROUGHOUT APARTMENT © Uneven floors + Inadequate heat Inadequate hot water Electrical re-wiring light bulbs constantly short out Defective electrical outlets tht cause circuit breaks KITCHEN Pipes leak ‘Defective light switches© Uneven floor ‘Sink rusted because of eaks * Broken cabinets BEDROOM * Uneven floors + Nobeat ‘+ Broken light switches BATHROOM + Pipes leak ‘* Broken bathtub Broken Mloor tiles + Broken wall tiles + Broken door © Toilet leaks + Broken and rusted tilt FAEL GARCIA AAP IC THROUGHOUT BUILDING Broken lock on the building entrance door + Broken intercom system ‘THROUGHOUT APARTMENT. ‘Broken intercom system * Inadequate heat + Tnadequate hot water + Flcctticalre-wiring — light bulbs constantly short out + Mice KITCHEN + Needs tobe painted BATHROOM Pipes leak 7 AIS: leks fom other sparen int his apartment assng the bathtub oll with ‘brown water and dir ISABEL LARA — 71 VERMILYE APT. 44 THROUGHOUT APARTMENT + Inadequate heat© Inadequate hot water Cracked floor tiles ‘Wall inside hallway closets cracked BEDROOM Cracked and falling ceiling ‘+ Broken radiator Cracked floor tiles BATHROOM Pipes leak ‘+ Broken bathtub + Yellow walls because of water damage + Cracked and falling ceiling LIVING ROOM + Uneven floor CARMEN SOSA ~ 71 VERMILYEA APT. 20 ‘THROUGHOUT APARTMENT = Inedequate heat 4+ Inadequate hot water © Roaches * Mice ‘+ Holes in the floor where rodents come in + Broken intercom system # Defective outlets + Defective radiators © Yellowwater damaged walls BATHROOM ‘© Pipes leak © Ceiling leaks + Toilet leaks Showerhead leaks © Mold KITCHEN + Clogged sinklan