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712807/2016
NYSCEF DOC. NO. 133 RECEIVED NYSCEF: 05/16/2019

Supreme
Court of the State of New York

of Queens
County

KCM Realty Company, LP.,

NOTICE

New Ram LLC Index


Realty,

712807/2016

PLEASE TAKE NOTICE that (insert your


New Ram Realty, LLC
name)

hereby appeals to the Appellate Division of the Supreme Court of the State of Ne

Judicial Department, from a (insert judgment, order, decree, etc.) order/judgement

Supreme Queens
Court,

May 3, 2019

Dated: Scarsdale New York


,

May 16 , 2019

Yours, etc.,

(Print Name)

(Address)
xc-
t
ARa
(Telephone Number)

To: (Insert below the name and 1address


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of the clerk ofthe trial
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9upreme Gourt of tig 9tate of New Worlt

Appellate Binistan: hthicial Bepartment


Informational Statement (Pursuant to 22 NYCRR 1250.3 - Civil
[a])

For Court of Original Instance

KCM Realty Company, LP.,

Date Notice of Appeal Filed


- against -

New Ram Realty, LLC For Appellate Division

Civil Action CPLR article 78 Proceeding M Appeal O Transferred Proceeding


O CliLR article 75 Arbitration O Special Proceeding Other O Original Proceedings O CPLR Article 78
O CPLR Article 78 O Executive Law § 298
Habeas Corpus Proceeding
O Eminent Domain CPLR 5704 Review
Labor Law 220 or 220-b
Public Officers Law § 36
Real Property Tax Law § 1278

O Administrative Review O Business Relationships E Commercial O Contracts

M Declaratory Judgment O Domestic Relations O Election Law O Estate Matters

O Family Court O Mortgage Foreclosure O Miscellaneous O Prisoner Discipline & Parole

O Real Property O Statutory O Taxation O Torts


otifér than foreclosure)

Informational Statement - Civil

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Paper Appealed From (Check one only): If an appeal has been taken from more than one order or
judgment by the filing of this notice of appeal, please
indicate the below information for each such order or
judgment appealed from on a separate sheet of paper.
O Ameñded Decree O Determination O Order O Resettled Order
O Amended Judgement O Finding O Order & Judgment O Ruling
O Amended Order O Interlocutory Decree O Partial Decree O Other (specify):
E Decision O Interlocutory Judgment O Resettled Decree
O Decree O Judgment O Resettled Judgment

Court: Supreme Court County: Queens


Dated: 05/03/2019 Entered: May 10, 2019
Judge (name in full): Leonard Livote Index No.: 712807/2016

Stage: O Interlocutory M Final O Post-Final Trial: O Yes E No If Yes: O Jury O Non-Jury


Prior Uñperfected Appeal and Related Case Information

Are any appeals arising in the same action or proceeding currently pending in the court? O Yes R No
If Yes, please set forth the Appellate Division Case Nüraber assigned to each such appeal.

Where apprepriate, indicate whether there is any related action or proceeding now in any court of this or any other

jurisdiction, and if so, the status of the case:

Commêñced by: O Order to Show Cause O Notice of Petition O Writ of Habeas Corpus Date Filed:
Statute autherizing commcacement of proceeding in the Appellate Division:

Court: Choose Court County: Choose Countv


Judge (name in full): Order of Transfer Date:

Court: Choose Court County: Choose Countv


Judge (name in full): Dated:

Description: If an appeal, briefly describe the paper appealed from. If the appeal is from an order, specify the relief
requested and whether the motion was granted or denied. If an original proceeding commenced in this court or transferred
pursuant to CPLR 7804(g), briefly describe the object of proceeding. If an application under CPLR 5704, briefly describe the
nature of the ex parte order to be reviewed.
Defendantappealsfrom eachand every part of the order/decisionof Leonard Livote, dated May 3, 2019, which grantedPlaintiff summaryjudgmenton causesof action1 and 3.
' The Plaintiff seeked,inter
alia, a declaratroyjudgment from the court that the Defendantis violating the use provisionsof the lease betweenthe parties by rentingblocksof roomsto
DHS or other agenicesthat work for DHS. This is an appealfrom a decisionrenderedby judge LeonardUvotefrom whereby the court ordered,adjudgedand decreedthat the
defendant'srentingof roomsat the property located at 59-40-55thRoad, Maspeth,NewYork to DHS or another agency of NewYork City to househomelesspersonsconstitutesa
materialdeparturefrom the use provisions(Artice5 and Section 35.8) of the lease and a breachof use provisions. Defendantwouldfurther appeal the order anddecreeallowingthe
Plaintiffto exerciseits remediesunderthe lease and for a decisionthat their is liability undertheir cause of actionfor costs/attorneyfees.

Irdormational Statement - Civil

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Is,sugs: Specify the issues proposed to be raised on the appeal, proceeding, or application for CPLR 5704 review, the grounds
for reversal, or modification to be advanced and the specific relief sought on appeal.

Was the decision/order of Judge Leonard Livote dated May 3, 2019 properly made.
Court errored in holding that Defendant did not meet its burden.
Court errored in holding that Plaintiff met its burden and shited the burden to Defendant.
Court errored in hc|ding that Defendant's use of the premises is in violation of the use restrictions of the lease.
Court errored in holding that Town of Brookhaven vs. Marian Chus supports the claims of the Plaintiff.
Owners'
Cour,t errored in holding that Chelsea Bus & Prop Ass'n LLC does not control the issues in this case.
Court errored in distinguishing Chelsea behueen the meaning and intent of the use provision in the lease and the meaning
and intent of the Zoning Resolution interpreted by BSA.
Court errored in granting Plaintiff's third cause of action based upon all the other court's errors.
Court errored in finding that Defendant's renting of the roomsto DHS or another agency to house homless persons
constitutes a materia departure from the use provisions of the lease and a breach of the lease.
Court eiTcred in finding that Plaintiff may exercise its remedied under the lease.

Party Information

InstÊüctions: Fill in the name of each party to the action or proceeding, one name per line. If this form is to be filed for an

appeal, indicate the status of the party in the court of original instance and his, her, or its status in this court, if any. If this
form is to be filed for a proceeding ccinmenced in this court, fill in only the party's name and his, her, or its status in this
court.

No. Party Name Original Status Appellate Division Status


1 KCM Realty Company, LP Plaintiff Respondent
2 New Ram Realty, LLC Defendant Appellant
3
4
5
6
7
8
9
10
11
~
12
13
14
15
16
17
18
19
20

Informational Statement - Civil

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Instructions: Fill in the names of the attorneys or firms for the respective parties. If this form is to be filed with the
, notice of petition or order to show cause by which a special proceeding is to be conn..cu ed in the Appellate Division,
only the name of the attorney for the petiticaer need be provided. In the event that a litigant represents herself or
Se"
himself, the box marked "Pro must be checked and the apprópriate information for that litigant must be supplied
in the spaces provided.

Attorney/Firm Name: Mitchell Geller, Esq. Holland & Knight, LLP


Address: 31 West 52nd Street
City: New York State: N.Y. Zip: 10019 Telephone No: (212) 513-3200
E-mail Address: Mitchell.Geller@hklaw.com

Attorney Type: M Retained O Assigned O Goverarñent O Pro Se O Pro Hac Vice

Party or Parties Represented (set forth party ñümber(s) from table above): No. 1 KCM Realty LP

Attorney/Firm Name: Clifford H. Greene, Esq.


Address: 700 Post Rd., Suite 309
City: Scarsdale State: N.Y. Zip: 10583 Telephone No: (914) 738 5992
E-mail Address: cliff@chgandassociates.com

Attorney Type: M Retained O Assigned O Government O Pro Se O Pro Hac Vice

Party or Parties Represented (set forth party number(s) from table above): No. 2 New Ram Realty, LLC

Attorney/Firm Name:
Address:
City: State: Zip: Telephone No:
E-mail Address:

Attorney Type: O Retained O Assigned O Güverññient O Pro Se O Pro Hac Vice

Party or Parties Represented (set forth party number(s) from table above):

Attorney/Firm Name:
Address:
.City: State: Zip: Telephone No:
E-mail Address:

Attorney Type: O Retained O Assigned O Güverñmêñt O Pro Se O Pro Hac Vice

Party or Parties Represented (set forth party number(s) from table above):

Attorney/Firm Name:
Address:
City: State: Zip: Telephone No:
E-máil Address:

Attorney Type: O Retained O Assigned O Government O Pro Se O Pro Hac Vice

Party or Parties Represented (set forth party number(s) from table above):

Attorney/Firm Name:
Address:
City: State: Zip: Telephone No:
E-mail Address:

Attorney Type: O Retained O Assigned O Goverñrñêñt O Pro Se O Pro Hac Vice

Party or Parties Represented (set forth party number(s) from table above):

Informational Statement - Civil

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SUPREME COURT OF THE STATE OF NEW YORK


COUNTY OF QUEENS

KCM REALTY COMPANY, L.P., Index No. 712807/2016

Plaintiff, Justice Leonard Livote


IAS Part 33
v. COMMERCIAL DIVISION PART
A
NEW RAM REALTY, LLC,
NOTICE OF ENTRY
Defendant.

PLEASE TAKE NOTICE that the within is a true copy of an Order and Judgment, dated

May 3, 2019, of the Supreme Court, Queens County, that was entered in the above-entitled action

and filed in the Office of the Clerk of the Supreme Court, Queens County, on May 10, 2019.

Dated: May 10, 2019


New York, New York HOLLAND & KNIGHT LLP

Mitchell J. Ge r

31 West 52nd Street


New York, New York 10019

(212) 513-3200

Attorneys for Plaintiff


KCM Realty Company, L.P.

TO: VIA NYSCEF

CLIFFORD GREENE & ASSOCIATES


700 White Plains Post Road, Suite 309

Scarsdale, New York 10583

(914) 738-5992
Attn: Clifford H. Greene, Esq.
Attorneys for Defendant New Ram Realty, LLC

#67669949_vl

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Short Form Order and Judgment

NEW YORK SUPREME COURT - QUEENS COUNTY

Present: HONORABLE LEONARD LIVOTE COMMERCIAL DIVISION

Acting Supreme Court Justice PART A

KCM Realty Company, LP, x Index

Plaintiff, Number 712807 2016

- against - Motion
Date Januarv 15, 2019
New Ram Realty, LLC,
Defendan t, Motion Seq. No. 5

The following papers EF numbered below read on this motion by plaintiff KCM Realty
Company for summary judgment on its first and third causes of action.
Papers
Numbei-ed

Notice of Motion - Affidavits - Exhibits ............................................. 107- 112


Affidavits - Exhibits .......................................................... 119-124
Answering
Reply Affidavit s ................................................................................... 126-127
Memoranda of Law............................................................................ 113, 118, 128

Upon the foregoing papers it is ordered that the motion which is for summary
judgment on the first and third causes of action is granted and judgment is granted

accordingly, as more fully set forth below.

I. The Facts

55*
Plaintiff KCM Realty Company (KCM.) owns property located at 59-40

Road, Maspeth, New York which it rented by lease dated March 5, 2004 to defendant
New Ram Realty, LLC (New Ram). Articlé 5 of the lease provides that "Tenant shall use

the Premises for (i) the erection [and] operation of a hotel which shall not exceed five (5)
stories in height, (ii) retail stores, and (iii) for the parking of vehicles related to the
*** use."
business of the hotel and such stores and for no other Section 35.8 of the Lease

states: "Tenant shall not use the Premises for any use other than to accommodate

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hotel."
transient hotel guests and for retail stores located on the ground floor of the
"
Section 12. l (b) of the lease provides that Tenant and its successors and assigns shall not

directly or indirectly seek to circumvent the requirements of this Article [Article 12]
Owner."
which require Tenant and is successors and assigns to obtain the consent of
Section 14.7 of the lease provides in relevant part: "Tenant shall also pay to Owner all
costs and expenses, including reasonable attorney's fees, paid or incurred by Owner in
***."
enforcing any of the covenants and provisions of this lease

In late August, 2016, New Ram contacted KCM about the former's plan to
sublease the hotel to a third party who would convert the building into a shelter for
homeless adults pursuant to an agreement with the New York City Department of
Homeless Services (DHS). New Ram requested KCM's consent to a Room Rental
Agreement that it proposed to enter into with Promesa Housing Fund Development

Corporation, whereby New Ram would rent I 10 of the I15 rooms in the hotel to
Promesa for the use of homeless persons at an annual rental of $2,400,000 for five years.

KCM responded by a letter dated August 25, 2016 which stated that the
conversion of the hotel into a shelter for homeless adults violated the use restrictions of
the lease and that KCM would not consent to the conversion. However, a few weeks later
DHS booked some rooms at the subject property directly though the Holiday Inn's
reservation system.

provider,"
DHS, a "nonprofit is at the premises to provide services to
homeless adults. These services include the provision of three meals a day, security
provided by three to six guards, and social services provided by about nineteen people
used by Acacia Network, Inc., an affiliate of Promesa. DHS or Acacia rented

approximately 53 rooms with 106 beds to house homeless individuals for the period May,
20 17 to November, 2018. Acacia requested the removal of the beds in four rooms which
it uses for administrative offices. The rooms rented by DHS or Acacia amount to almost
one half of the hotel's 115 rooms. From October 2016 through March 2018, a total of
254 homeless people resided at the hotel, and on average each individual resided there for
195 nights. 100 of the homeless individuals resided at the hotel from 216 days to 537
days. 43 of the homeless individuals resided at the hotel for 365 days or more from

October, 2016 through March, 2018. Pursuant to an amendment dated December 14, 2017
to the agreement between DHS and Acacia, the latter agreed to provide 53 rooms at the
hotel to house homeless persons for the period October 10, 2016 to June, 2020.

II. Brief Procedural History

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Plaintiff KCM began the instant action by the filing of a summons and a
complaint on October 26, 20 l 6. By an amended complaint dated November 28, 2016, the
plaintiff asserted three causes of action against the defendant. The first is for a judgment
declaring:"that New Ram's renting of 30 rooms at the Premises to DHS or another agency
of New York City to house homeless persons constitutes a material departure from the
use provisions (Article 5 and Section 35.8) of the Lease and a breach of such use
***."
provisions The second cause of action is for a judgment "enjoining New Ram from
provisions***."
violating the Lease's use The third cause of action is for a judgment

"awarding KCM costs, expenses, and reasonable attorney's fees incurred in enforcing the
***."
use provisions of the Lease

III. Discussion

"[T]he proponent of a summary judgment motion must make a prima facie

showing of entitlement to judgment as a matter of law, tendering sufficient evidence to


***."
demonstrate the absence of any material issues of fact ( Alvarez v. Prospect

Hospital, 68 NY2d 320, 324 [1986].) Plaintiff KCM successfully carried this burden.

Turning to the first cause of action, Article 5 of the lease provides in


relevant part that "Tenant shall use the Premises for (i) the erection [and] operation of a
***"
hotel and Section 35.8 of the Lease states in relevant part: "Tenant shall not use the
***."
Premises for any use other than to accommodate transient hotel guests The lease
guests"
between the parties does not define "transient hotel in any special way, and thus
meaning."
the phrase in the contract must be given its "plain and ordinary (See, Blake v.
[2"d "
Solomon, 169 AD3d 791 Dept, 2019]). The phrase was intended to be interpreted
meaning"
in its accepted and dictionary ( See, Engel v. Calgon Corp., 114 AD2d 108,
3'd
1 I0, [ Dept 1986]), aff'd, 69 NY2d 753 [1987]; Amato v. New York City Dep't of Parks
15t
& Recreation, 1 10 AD3d 439, 440[ Dept 2013] ["based on the ordinary dictionary

meaning of the word"].) "The words and phrases used in an agreement must be given
their plain meaning so as to define the rights of the parties ***and in this regard, it is

common practice for the courts of this State to refer to the dictionary to determine the
"
plain and meaning of words to a contract (Mazzola v. Cty. ofSuffolk, 143
ordinary
2"d
AD2d 734, 735[ Dept 1988]; Mann v. 125 E. 50th St. Corp., 124 Misc2d 115,
l 17[Civ. Ct. 1984]), aff d, on the opinion below, 126 Misc 2d 1016, [App. Term 1985]
[court resorted to dictionary to determine whether an occupant of a hotel for a long

period could be considered a "transient"]).

"transient"
Black's Law (10th ed. 2014) defines as "[a] person or
Dictionary
fleeting."
whose presence is temporary or It defines temporary as: "[1]asting for a
thing
transitory."
time only; or continuing for a limited (usu. short) time; The Merriam
existing

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"transient"
Webster on line Dictionary defines the adjective as: "passing through or by a
sojourn." "transient" "
place with only a brief stay or and the noun as a guest or boarder
briefly."
who stays only The homeless individuals placed into the subject property for
months on end by defendant New Ram do not meet these definitions.

The closest case on point, Town ofBrookhaven v. Marian Chun


[2"d
Enterprises,1nc., (133 AD2d 754 Dept. 1987], rev'd on other grounds, 71 NY2d 953

[1988]), supports plaintiff KCM's claims. In that case, the Town of Brookhaven brought
an action to permanently enjoin the defendant from operating Lakeview Lodge Motel as a

lodging, boarding and/or rooming house without having first obtained a proper certificate
of occupancy. In enjoining the the owner of the facility from operating the facility
without a proper certificate of occupancy, the Appellate Division, Second Department,,
stated: "Under the amended ordinance, a motel is defined, inter alia, as a place which
travelers"
provides lodging for "transient (see, Code of Town of Brookhaven § 85-l[B] ).

The facts in this case indicate that persons referred to Lakeview Lodge Motel by the
Suffolk County Department of Social Services may reside there for periods of three to six
months or at times longer, register their children in the local schools, and consider
"transient"
Lakeview Lodge Motel as their home. Such persons cannot be considered

travelers ***A certificate of occupancy appropriate to the use of Lakeview Lodge Motel

as housing for such persons is necessary (see, Code of the Town of Brookhaven §
85-14)" 754-755)."
( Town of Brookhaven v. Marian Chun Enterprises, Inc., supra,

The Brookhaven case relied on Mann v. 125 E. 50th St. Corp. (supra) in
'"Transient" "resident"
which the court stated: has been considered the opposite of (see

The Leontios Teryazos, 45 F Supp 618), and with respect to a hotel, is one who has a

home elsewhere and is staying at the hotel for a short period in connection with a trip
home"
away from (Mann at 1 17).

"
A landlord has a legal right to control the uses to which his building may
enforced."
be put by appropriate lease provisions, which to be effective must be
a
(Qwakazi, Ltd., v. 107 W. 86th St. Owners Corp., 123 AD2d 253, 254[ l Dept 1986];
[1"
Beauty Plus Stores, II, Inc. v. 404 6th Ave. Realty Corp., 70 AD3d 604 Dept 2010]).

"Where the use and occupation of the premises are restricted by express provision to the

purpose therein specified, any material departure from the specified use constitutes a
lease"
violation of the express terms of the (74 N.Y. Jur. 2d Landlord and Tenant § 271;
see, Burber v. Jilamb Prime Meat, Inc., 1 15 Misc2d 976 [Civ. Ct. 1982]).

"use"
Where it is clear that a tenant has violated the clause in his lease.
appropriate"
summary judgment declaring the landlord's rights is (see Qwakazi, Ltd., v.

107 W. 86th St. Owners Corp., supra; Dennis & Jimmy's Food Corp. v. Milton Co., 99

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[2"d
AD2d 477 Dept 1984], affd, 62 NY2d 613[1984].) Under all of the facts and
circumstances of this "an analysis of percentage mix ***
case, including to ascertain
"
whether a departure is material or deminimus (see Burber v. Jilamb Prime Meat, Inc.,
supra, 978), plaintiff KCM has demoñstrated its prima facie right to summary judgment
on its first cause of action. The court again notes that from October 20 I6 through March

2018, a total of 254 homeless people resided at the hotel, and on average each individual
resided there for 195 nights.

The burden on this branch of the motion shifted to defendant New Ram,
requiring it to produce proof that there is an issue of fact which must be tried (see Alvarez
v. Prospect Hospital, supra) or of demonstrating the existence of a defense warranting
the denial of summary judgment. (See Plantamura v. Penske Truck Leasing, Inc., 246
[1"
AD2d 347 Dept 1998]). Defendant New Ram failed to carry this burden. First,
contrary to the assertions made in the defendant's memorandum of law, no issue of fact
arises merely because the lease does not expressly prohibit defendant New Ram "from
time"
licensing rooms to Acacia or DHS to house homeless persons for any period of and

merely because the lease does not expressly prohibit the hotel from being used as a
homeless shelter. Although the lease requires some interpretation, the lease

unambiguously restricts the use of the premises to the operation of a hotel, which a
Owners'
homeless shelter is not. Second, the defendant relies on Chelsea Bus. & Prop.
[1"
Ass'n, LLC v. City of New York (107 AD3d 414, Dept 2013]), an Article 78

proceeding brought to annul a determination by the Board of Standards and Appeals of


the City of New York (BSA) concerning the approvals issued for the operation of a
homeless shelter. In upholding the administrative determination, the Appellate Division,
First Department stated: "The BSA rationally determined that the definition of "transiest
hotel"
in section 12-10 of the Zoning Resolution is clear and unambiguous and that the
proposed use of the building meets the three criteria of the definition, i.e., it (1) provides

sleeping accommodations used primarily for transient occupancy; (2) has a common
entrance to serve the sleeping accommodations; and (3) provides 24-hour desk service,
laundering."
housekeeping, telephone and linen Defendant New Ram's reliance on
Chelsea is misplaced. At best for the defeñdâüt, Chelsea, decided by the Appellate

Division, First Department, conflicts with Town of Brookhaven, decided by the Appellate

Division, Second Department, and, of course, this court is obligated to follow the
decisions of the latter. Moreover, the Chelsea court followed the usual practice in Article
78 proceedings in deferring to interpretations made by administrative agencies, and the
Appellate Division, First Department made little or no analysis of its own concerning the
hotel" occupancy."
terms "transient and "transient Finally, the case at bar is
distinguishable from Chelsea because the meaning and intent of the use clause in the
lease differs from the meaning and intent of the Zoning Resolution as interpreted by

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BSA. The use clause in the lease was clearly intended to restrict the use of the premises to .
the operation of a hotel as that term is traditionally and understood.
commonly
The interest of a landlord in tightly the use of his private differs from
controlling property
the interest of an administrative agency in expanding the use of property for public
purposes.

Accordingly, plaintiff KCR is entitled to summary judgment on its first -


cause of action.

Turning to the third cause of action, generally, a plaintiff may be awarded


attorney's fees as part of a damages award where such relief is specifically authorized by
statute, rule or contract (Lemming v. Barnwell Nursing Home & Health Facilities, Inc., 15
NY3d 375 [2010] ; Hooper Assoc. v. AGS Computers, 74 NY2d 487 [1989]). In the case
at bar, a judgment awarding KCM costs, expenses, and reasonable attorney's fees
incurred in enforcing the use provisions of the Lease is authorized by Section l 4.7 of the
lease. Accordingly, it is,

Ordered, adjudged and decreed that defendant New Ram Realty, LLC's

renting of rooms at property located at 59-40 55thROad, MaSpeth, New York to DHS or
another agency of New York City to house homeless persons constitutes a material
departure from the use provisions (Article 5 and Section 35.8) of the lease and a breach of
such use provisions; and it is further,

Ordered, adjudged and decreed that plaintiff KCM Realty Company is


entitled to exercise its remedies under the lease; and it is further,

Ordered, that the motion for summary judgment on the third cause of action
is granted on the issue of liability.

This constitutes the Order of the Court.

Dated:
NV 3 a
/S
A. .S.C.

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SUPREME COURT OF THE STATE OF NEW YORK


COUNTY OF QUEENS
-- X
KCM REALTY COMPANY, LP,

Plaintiff, AFFIRMATION OF
-against- SERVICE

NEW RAM REALTY, LLC

Index No.: 712807/2016


Defendant.

AFFIRMATION OF SERVICE BY FIRST CLASS MAIL

STATE OF NEW YORK )


) ss.
COUNTY OF WESTCHESTER )

Clifford H. Greene, an attorney duly admitted to practice law before the courts of
the State of New York, affirms the following statements are true under penalties of perjury:

I am not a party to this action, am over 18 years of age and reside in Westchester,
New York.

On May 16, 20192 I served a copy of Defendants Notice of Appeal, Information


Statement and copy of Notice of Entry of the decision/order dated May 3, 2019 by mailing the
same by first class mail, in a sealed envelope, with postage prepaid thereon, in the post office
or an official depository of the U.S. Postal Service within the State of New York, addressed the
last known address of the addressee as indicated below:

The Honorable Leonard Livote


Attn: Robert Perez, Court Clerk of Part 33, Court Room 122
88-11 Sutphin Blvd.

Queens, N.Y. 11435

Holland & Knight, LLP


Attn: Mitchell Gellar, Esq.
Attorneys at Law
52nd
31 West Street,
New York, New York 10019 ')

ifford H. Greene, Esq.

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