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SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK ------------------------------------ x In the Matter of the Application

of Index No. ___________________ NEW YORK CITY COUNCIL BARUCH HOUSES TENANTS ASSOCIATION, ROBERTO NAPOLEON, DOUGLASS HOUSES TENANTSASSOCIATION, and JANE WISDOM, AFFIRMATION OF LISA E. CLEARY IN SUPPORT OF ORDER Petitioners, TO SHOW CAUSE For an Order Pursuant to Article 78 of the Civil Practice Law and Rules, and for other relief, -againstNEW YORK CITY HOUSING AUTHORITY; JOHN B. RHEA, as Chairman of the Board of the New York City Housing Authority, Respondents. -----------------------------------x

LISA E. CLEARY, an attorney duly admitted to practice in the Courts of this State, hereby subscribes and affirms under penalty of perjury, pursuant to CPLR 2106, as follows: 1. I am an attorney duly admitted to practice in the courts of the State of New

York and am a member of Patterson Belknap Webb & Tyler LLP, counsel to plaintiffs New York City Council, Baruch Houses Tenants Association, Roberto Napoleon, Douglass Houses Tenants Association, and Jane Wisdom. I make this affirmation in support of plaintiffs application for an Order to Show Cause seeking the relief requested in the petition filed herein.



As set forth in the accompanying Verified Petition, this proceeding is

being commenced to challenge a Request for Expressions of Interest (RFEI) that was issued by the respondents on August 16, 2013, and to which responses are due on November 18, 2013. Respondents have stated that upon receipt of responses to the RFEI, they may enter into agreements with developers to commence the developments that are being challenged. Petitioners contend that these developments are contrary to the law. 3. This proceeding is being commenced by Order to Show Cause in order to

obtain an expedited review of this matter. In particular, petitioners seek a resolution of their claims by November 18, 2013, or as soon thereafter as feasible. 4. or any other court. Dated: October 10, 2013 New York, New York No prior application for the relief requested herein has been made in this

___________________________________ LISA E. CLEARY