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CIVIL COVER SHEET

JS
44CISDNY

APR O 1 2011

The JS-44 civil co sheet and theInformation co


lned h ein nel he\,,,. aor aup n ll
of
pleadlng1 or other papara as required bylaw, e
u
ded by local rul81 ot co
- he
Judiclel Conterenc, of the United Stal..in September 1874.11required tor use of ha Clark or Court for Iha purpoae ot
lnilieling the clvM docket sheet .

REV. 512010

PLAINTIFFS

DEFENDANTS

Surrey Equities, LLC and Surrey Property Management, LLC,


.
.
. .
suing on behalf of themselves and their Manager and
Capital One,National Assoc1at1on
ATTORNEYS (FIRM NAME. ADDRESS, AND TELEPHONE NUMBER

Paul, Hastings, Janofsky and Walker, LLP, 75 East 55th


Street, New York,NY 10022, (212) 318 - 6000

ATIORNEYS (IF KNOWN)

Carla R. Walworth and Cynthia A. Curtin

CAUSE OF ACTION (CITE THE

U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE)
(DO NOT CITE JURISDICTION,\L ST,\TUTES UNLESS DIVERSITY)

28 U.S.<;;. 1332, removal of action from State Court to this Court.


Has this or a similar case been previously flied In SONY at any lime? No?
If yes, was this case VolD lnvol.

Dismissed. No D Yes

(PLACE AN [x] IN ONE BOX


ONLY)

0 Yes? 0

Judge Previously Assigned

& Case No.

If yes, give date

NATURE OF SUIT
ACTIONS UNDER STATUTES

TORTI

FORFEITURE/PENALTY
[ 1610 AGRICUlTURE
OTHER FOOO &
[ ) 362 PERSONALINJURY
DRUG
MED MALPRACTICE
[ J 625 DRUG RB.ATED
[ J 365 PERSONALINJURY
SEIZURE OF
PRODUCT LWIIUTY
PROPERTY
21 USC881
[ J 388 ASBESTOS PERSONAL
LIQUOR L,\WS
INJURY PROOUCT
1J
630 LIABILITY
[ J 640
[ J 1!5D RR& TRUCK
PERSOLPROPERTY
( J 660 AIRLINE REGS
OCCUPATlONAL
[ )370 OTHER FRAUD
IJ 690 SAFETY/HEALTH
OTI'iER
[ J 371 TRUTHINLENDING
PERSONALINJtJRY

PeRSOHAI. INJIJRY
CONTRACT
[ 1110 INSURANCE
[ 1120 MARINE
( J 130 Mlll:R ACT
( 1140 NEGOTlABLE
INSTRUMEN
T
I 1150 RECOVERY OF
OVERPAYMENT &
ENFORCEMEPfT Of
JUDGMENT
( J 11 MEDICARE ACT
[ J 152 RECOVERY OF
DEFAULTED
STUOE"1' LOANS
(EXCL VETERANS)
( J 153 RECOVERY OF
OVERPAYMENT OF
VETERAN'S BENEFITS
[ J 160 STOCKHOLDERS
SUITS
M190 OTHER COPfTRACT
( 11&5 CONTAACT PRODUCT
LIABILITY
I1196
FRANCHISE

JIEAL PROPERTY

[ )310 AIRPLANE
AIRPI.ANE
PRODUCT
LIABILITY
( J 320 ASSAULT ,LIBB.&
SlANDER
{ ) 330 FEDERAL
EMPLOYERS'

[ J 315

LIABILITY

[ ]340 MARINE
{ J 345 MARINE PRODUCT
LIABILITY
( J 350 MOTOR VEHICLE
[ J 355 MOTOR VEHICLE
PROOUCT LIABILITY

I J 360

I)620

[ I380 OTHER PERSONAL


[ I38S

EJECTMENT

LAND [ ) 245 TORT


PRODUCT
LIABILITY
J 290 AU OTHER
REAL PROPERTY

APPEAL

28 use 1ss

{ ] 423 WITHDRAWAL

2e use 1s1
PROPERTY RIGKTS

[ I830

PATENT

[ I!MO TRADEMARK
SOCIAL SECURITY

PROPERTY DAMAGE
PROOlJCTLIABILITY

( I861

HIA (13&5fl)

[ I883

DIWC/OIWW

OTHER PERSONAL
INJURY

l I710
1 1720

[ J730

F"1RLABOR
STANDARDS ACT

LABOR/MGt..lT
RELATIONS
LABOR/MGMT
REPORTING &
DISCLOSURE ACT

[ I862 BL.ACK LUNG (923)

(405(g)>
[ 1864 SSID TITLE XVI
RSI(AOS(gl)

( J 865

FEDERAL TAX SUITS


( 1740 RAILWAY LABOR ACT {
ACTIONS UNDER STATUTES
CIVIL RIGHTS

[ 1790
PRISONER PETITIONS

[ I 1 VOTING

[ 'J

OTHER LABOR
LITIGATION
EMPL RETINC
SECURITY ACT

791 [ ]510 MOTIONS TO


VACATE SENTENCE IllMIGRATION
20 USC 2255
[ J 462 NATURALIZATION
IJ 530 HABEAS CORPUS
[ J4 WELFARE
[ ]535 DEATH PENALTY
APPLICATION
[ ]540 MANDAMUS & OTHER ( 1463 HABEAS CORPUS
[ I445 ,\MERICANS WITH
CIVIL
RIGHTS
ALIENDETAINEE
l
J
550
OISAl! LITIES
[ J 555 PRISON CONDITION !I"65 OTHE:R
EMi>LOYMENT
[ IUS AMERICANS WITH
ll,IMIGRATION
DlSABll.lTIES -OTHER
ACTIONS
[ J 440 OTHER CIVIL
RIGHTS

CJ CHECK IF THIS IS A CLASS ACT

OTHER STATUTeS

I)400

ST,\TE
REAPPORTIONMENT

( J 410 ANTITRUST
( J 430 BANKS & BANKING
( J 450 COMMERCE
IJ 480 DEPORTATION

I J 470

[ J 820 COPYRIGHTS

PROPERTY DAMAGE LABOR

[ J 210 Li\ND CONDEMNATION [ ) 2 EMPLOYMENT


[ J 2%0 FORECLOSURE
[ J 443 HOUSING/
ACCOMMODATIONS
[ J 230 RENT LEASE &
[ J 240 TORTS TO

BANKRUPTCY

[ J 422

J 870

RACKETEERINFLU
ENCED & CORRUPT
ORGANIZATION ACT

(RICO)

[ J 480 CONSUMER CREDIT

[ J 490

CABLE/$,\TELUTE TV
( 1810 SELECTIVE SERVICE
{ 1850 SECURmES/
COMMODmESI

EXCHAHGE
l I875 CUSTOMER
CHALLENGE
12 USC 3410
[ J 890 OTHER STATIJTORY
ACTIONS
[ J 891 ,\GR!CUlTURAL ACTS
[ J 892 ECONOMIC
STABILIZATION ACT

TAXES (U.S. Plllintillor [ J 893 ENVIRONMENTAL

ant)
[ 1871 IRS-THIRD P,\RTY
26 USC 7609

MATIERS

[ J 894 ENERGY

A.U.OCATION /'CT
[ ) 895 FREEDOM OF
NFORMATK>N ACT
IJ 900 PEAL Of FEE
DETERt.l!Ni\TION
UNDER EQUAL ACCESS
TO.JUSTICE
[ J 950 CONSTITUTIONAUTY
OF STATE STATUTES

DO YOU CLAIM THIS CASE IS REL.ATEDTO A CIV IL CASE NOW PENDING IN


S.D.N.Y.? IF SO, STATE:

ION
F.R.C.P.23
Check
if UNDER
demanded
In complaint:

DEMAND $.

OTHER __

JUDGE

Judge Deborah Batts

DOCKET NUMBER 11 CIV 1798

Check YES oo/y if demanded in complaint

JURY DEMAND: 0 YES O

NO

NOTE: Please submit at the lime of filing an explanation of why cases are deemed related.

..
(PLACE AN

x IN ONE BOX ONLY)

D1
Original
Proceeding

[Zj 2a.

ORIGIN

Romoved from

03 Rsmanded from O

Stole Court

Appellate Court

Reinstated or

Ropenad

Transferred from

Multidistnct

Litigation

(Specify District)

2b.Romovad from
Stoll> Court
ANO at reast
one perty is pro
H.

BASIS OF JURISDICTION

(PlACE AN x IN ONE BOX ONLY)

0 1 U.S. PLAINTIFF O 2 U.S. DEFENDANT O 3 FEDERAL QUESTION

Appeal to Di trict
Judgo from
Magi1tr1te Judga
Judgmant

IF DIVERSITY, INDICATE
CITIZENSHIP BELOW.

04

(28 USC 1322, 1441)

DIVERSITY
(U.S. NOT A PARTY)

CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)


(Place an [X] in one box for Plaintiff and one box for
Defendant)
PTF
CITl l;N OF THIS STATE

1
1

PTF

PTF

DEF

2'

DEF
[]

CITIZEN OF ANOTHER STATE [ 12 )(J 2


4

( J3 !I3

CITIZEN OR SUBJECT OF A
FOREIGN COUNTRY
INCORPORATED

2! PRINCIPAL PLACE

(]5

FOREIGN NATION

[ ls

[ J

J/11::

OF BUSINESS IN THIS STATE

..J!!.:

INCORPORATED ond PRINCIPAL PLACE


OF BUSINESS IN ANOTHER STATE

l I6

PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)

Surrey Equities, LLC and Surrey Property Management, LLC, 40 Fulton Street, 6th Floor, New York, NY 10038; New York
County

DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)

Capital One, National Association, 1680 Capital One Drive, Mclean, VA 22102-3491; Fairfax County
DEFENDANT(S) ADDRESS UNKNOWN
REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, IHAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN THE
RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:

Check one:

THIS ACTION SHOULD BE ASSIGNED TO:

WHITE PLAINS

(DO NOT check either box if this a PRISONER PETITION.)

[Z] MANHATTAN

ADMITTED TO PRACTICE IN THIDISTRICT

DATE

Magistrate Judge is to be designated by the Clerk of the Court.


RECEIPT #

[ I NO

A1ist1999

kl

Yr. J

YES (DATE ADMITTED Mo.

Magistrate Judge ---------------------------is so Designated.


Attorney Bar Code
#CW-5401
Ruby J . Krajick, Clerk of Court by

Deputy Clerk, DATED ----------

UN1TED STATES DISTRICT COURT (NEW YORK SOUTHERN)

.
Carla R. Walworth (CW5401) Cynthia A. Curtin
PAUL, HASTINGS, JANOFSKY & WALKER LL
75 East 55th Street

.
.

N
e

w York, New York


Telephone: 212-318-6000
Facsimile: 212-319-4090
carlawalworth@paulhastings.com
cynthiacurtin@paulhastings.com

UNITED STATES DISTRICT COURT


SOUTHERN DISTRICT OF NEW YORK

SURREY EQUITIES, LLC and


SURREY PROPERTY MANAGEMENT, LLC,
Suing on behalf of themselves and their Manager and Guarantors,
Plaintiffs

NOTICE OF REMOVAL

-againstCAPITAL ONE, N .A. as Successor to


NORTHFORK BANK,
Defendant

To:

Clerk of the Court


United States District Court
Southern District of New York
PLEASE TAKE NOTICE that Defendant Capital One, National Association ("Capital

One" or "Defendant"), through their undersigned counsel, hereby removes this civil action
from the Supreme Court of the State of New York, County of the Bronx, where it is now
pending, to the United States District Court for the Southern District of New York pursuant to
28 U.S.C.
1332 and state as follows:
1.

On or about March 1, 2011, Plaintiffs Surrey Equities, LLC and Surrey

Property Management, LLC ("Plaintiffs") filed a Complaint in the Supreme Court of the State of
New York, County of the Bronx, captioned Surrey Equities LLC and Surrey Property

Management, LLC, Suing on behalf of themselves and their Manager and Guarantors v.
Capital One, N A., as Successor to Northfork Bank. A true and correct copy of the Complaint
and is attached hereto as Exhibit A.

2.

On or about March 8, 2011, Plaintiffs filed an Amended Complaint in the

same court. The Amended Complaint also was captioned Surrey Equities LLC and Surrey

Property Management, LLC, Suing on behalf of themselves and their Manager and Guarantors
v. Capital One, N A., as Successor to Northfork Bank. A true and correct copy of the
Amended Complaint and is attached hereto as Exhibit B.
3.

Both the Complaint and the Amended Complaint were assigned to the County Clerk's Index

No. 301848/2011.
4.

Plaintiffs served a copy of the Complaint on Defendant's agent on March 2, 2011. Plaintiffs
served a copy of the Amended Complaint on Defendant's agent on March 16, 2011.

GROUNDS FOR REMOVAL


5.

This action is removable under 28 U.S.C. 1332 because (i) complete diversity of
citizenship exists between the parties and (ii) the amount in controversy exceeds
$75,000 exclusive of interest and costs.

6.

On information and belief, plaintiff Surrey Equities, LLC is a New York limited liability
company with its principal place of business at 40 Fulton Street, Floor 6, New York, NY
10038. On information and belief, Surrey Equities, LLC is a citizen of New York and New
Jersey.

-2-

7.

On information and belief, plaintiff Surrey Property Management, LLC is a New York limited
liability company with its principal place of business at 40 Fulton Street, Floor 6, New York,
NY 10038. On information and belief, defendant Surrey Property Management, LLC is a
citizen of New York and New Jersey.
Defendant Capital One, National Association is a national bank with its principal
place of business located.at 1680 Capital One Drive, McLean, Virginia 22102.
Capital One is a successor by merger to North Fork Bank ("North Fork"), which
merged with and into Capital One, N.A., on or about August 1, 2007.
8.

In their Complaint, Plaintiffs seek damages "believed to be in excess of

1.7 million dollars." See Complaint at 4-5. In their Amended Complaint, Plaintiffs seek
damages "believed to be in excess of 15 million dollars." See Amended Complaint at 5-6. The
damages sought by Plaintiffs are well in excess of the $75,000 minimum required to confer
jurisdiction on this .Court.
9.

Removal to this Court is proper under 28 U.S.C. 1446(a), as the Southern District of
New York is the district within which the lawsuit was pending prior to removal.

TIMELINESS AND NOTICE


10.

This Notice of Removal is timely under 28 U.S.C. Section 1446(b) because it is being
filed within thirty days of receipt by Defendant of a service copy of the Complaint setting
forth the claims for relief upon which this action is based.

11.

Pursuant to 28 U.S.C. 1446(b), Defendant will promptly give written notice of this filing of
this Notice of Removal to Plaintiff, and will file a copy of this Notice with the clerk of the
Supreme Court of the State of New York, County of the Bronx.

-3-

WHEREFORE, pursuant to 28 U.S.C. 1332 and 1446, Defendant hereby


remove this action from the Supreme Court of the State of New York, County of the Bronx, to
the United States District Court for the Southern District of New York.

Respectfully submitted,

Dated: New York, New York


April 1,2011

Carla R.Walworth (CW-5401)


Cynthia A. Curtin

PAUL, HASTINGS, JANOFSKY &


WALKER LLP
75 East 55th Street
New York, New York
Telephone:212-3 18-6000
Facsimile: 212-319-4090
carlawalworth@paulhastings.com
cynthiacurtin@paulhastings.com
ATTORNEYS FOR PLAINTIFF CAPITAL
ONE, N.A.

-4-

Wrobel & Schatz LLP


Attorneys for Plaintiffs
1040 Avenue of the Americas, 11rh Floor
New York, NY 10018
(212) 421-8100

SUPREME COURT STATE OF NEW YORK


COUNTY OF THE BRONX
---------- -------------------------------------------------x
SURREY EQUITIES, LLC and
SURREY PROPERTY MANAGEMENT, LLC,
Suing on behalf of themselves and their
Manager and Guarantors,
Plaintiffs,

Index No.1o I LIS /2011

SUMMONS
Swnmons and Complaint
Filed on March l_, 2011

-againstCAPITAL ONE, N.A. as Successor to


NORTHFORK BANK,
Defendant.

-- --- - ------------.---------------x

defe
ndan

To the above-named
You are hereby summoned to answer the complaint in this action and to serve a copy of
your answer on plaintiffs' attorney within 20 days after service of this summons, exclusive of the
date of service, or within 30 days after completion of service where service is made in any other
manner than by personal service within the state. In case of your failure to appear or answer,
judgment will be taken against you by default for the relief demanded in the complaint.

t:

Pursuant to CPLR 503(a), Plaintiffs designate the County of Bronx as the place of
trial.

New York, New York


Dated: March 1, 2011

WROBEL & SCHATZ LLP


....

Duvid C. Wrobel , Esq:

Attorneys for Plaintiffs


1040 Avenue of the Americas-11th floor
New York, New York 10018
212-421-8100

Wrobel & Schatz LLP


Attorneys for Plaintiffs
I 040 Avenue of the Americas, 11th Floor

New York, NY 10018


(212) 421-8100
SUPREME COURT STATE OF NEW YORK
COUNTY OF THE BRONX

----------------------------------------------- - - - -x
SURREY EQUITIES, LLC and
SURREY PROPERTY MANAGEMENT , LLC,
Suing on behalf of themselves and their

Index No.

/2011

Manager and Guarantors,

Plaintiffs,

COMPLAINT

-againstCAPITAL ONE, N.A. as Successor to

NORTHFORK BANK,
Defendant.

---------------------------------------------------------------x
Plaintiffs Surrey Equities, LLC and Surrey Property Management, LLC, suing
herein on behalf of themselves and their Guarantors, by and through their attorneys,
Wrobel & Schatz LLP, as and for their Complaint against defendant Capital One, N.A. as
Successor to Northfork Bank, N.A., allege as follows:
Introduction

1. Both plaintiff Surrey Equities, LLC and plaintiff Surrey Property Management, LLC,
(hereinafter, collectively, the "Surrey Plaintiffs") are limited liability companies
organized and existing under the laws of the State of New York.
2.

Upon information and belief, defendant Capital One, N.A. as Successor to Northfork
Bank ("Capital One") is a national banking association with branches in the Bronx,

New York.

The Surrey Plaintiffs' Checking Accounts


3.

Both plaintiff Surrey Equities, LLC and plaintiff Surrey Property Management, LLC, at
all times relevant hereto, were owned by Leon Silvera, Edward Silvera, and Tivoli
Partners, LLC, an entity controlled by Jacob Frydman and managed by Leon Silvera,
Edward Silvera, and Jacob Frydman.

4.

Beginning in 2004, the Surrey Plaintiffs established checking accounts numbered


3014007029, 3014010486, and 3014007169 with Capital One and/or its
predecessor-in-interest, Northfork Bank.

5.

According to the explicit terms of the relevant account agreements, no checks could be
drawn on the checking accounts without the signatures of at least two
signatories, one of whom was required to be Jacob Frydman.

Capital One's Violation of the Account Agreements


6.

Notwithstanding the foregoing, and in derogation of Mr. Frydman's rights, Capital


One improperly cleared approximately $1. 7 million in checks drawn on the
accounts of the Surrey Plaintiffs in violation of and in breach of its agreement not to do
so.

Capital One,s Alleged Claims Against Guarantors


7.

Notwithstanding its blatant violation of the relevant account agreements, Capital One has
recently started demanding from guarantors of the Surrey Plaintiffs, including Jacob
Frydman, payment in respect of certain sums allegedly due.

8.

Specifically, Capital One has demanded : $345,689.93 plus interest from Jacob
Frydman in respect of a line of credit issued by Capital One; $330,264.00 plus interest

from Jacob Frydman in respect of a letter of credit issued by Capital One for the benefit
of White Acre Equities, LLC; and $628,674.00 plus interest from Jacob Frydman, Leon
Silvera, and Ed Silvera in respect of a line of credit issued by Capital one in favor of
Surrey Equities, LLC.

First Cause of Action


(Breach of Contract - Surrey)
9.

Plaintiffs repeat and reallege each and every allegation set forth herein in paragraphs 1
through 8 above.

10. Capital One breached its contractual obligations to plaintiffs when it allowed the
clearance of checks that did not contain the signature of Jacob Frydman.
11. As a result of the foregoing, Plaintiffs have been damaged in an amount to be
determined at trial, believed to be in excess of $1.7 milJion.

Second Cause of Action


(Breach of Contract - Frydman)
12. Plaintiffs repeat and reallege each and every allegation set forth herein in
paragraphs 1 through 8 above.
13. Capital One breached its contractual obligations to Frydman, the manager of Surrey
Plaintiffs, when it allowed the clearance of checks that did not contain the signature of
Jacob Frydman.
14. As a result of the foregoing, Jacob Frydman has been damaged in an amount to be
determined at trial, believed to be in excess of $1.7 million.

Third Cause of Action


(Negligence)
15. Plaintiffs repeat and reallege each and every allegation set forth herein in
paragraphs I through 8 above.

16. Capital One was negligent when it allowed the clearance of checks that did not
contain the signature of Jacob Frydman.
17. As a result of the foregoing, Plaintiffs have been damaged in an amount to be
determined at trial, believed to be in excess of $ J .7 mil1ion.

Forth Cause of Action


(Set-oft)
18. Plaintiffs repeat and reallege each and every allegation set forth herein in paragraphs

1 through 8 above.
19. As a result of the foregoing, the guarantors of the Surrey Plaintiffs, including Jacob
Frydman, are entitled to a Declaration that they may set off, against any sums allegedly
due from them, such amounts as Capital One improperly cleared, in an amount to be
proven at trial, believed to be in excess of $1.7 million.
WHEREFORE, Plaintiffs Surrey Equities, LLC and Surrey Management, LLC,
on behalf of themselves and their Managers and Guarantors, demand judgment against
Capital One, N.A. as follows:
a. On the First Cause of Action, a judgment in an amount to be determined at
trial and believed to be i n excess of $1.7 million, together with interest,
reasonable attorney's fees and costs, and such further relief as the Court
may deem just and proper;
b. On the Second Cause of Action, a judgment in an amount to be
determined at trial and believed to be in excess of $ J .7 million,
together

with interest, reasonable attorney's fees and costs, and such further relief as
the Court may deem just and proper;

c. On the Third Cause of Action, a judgment in an amount to be determined


at trial and believed to be in excess of $1.7 million, together with interest,
reasonable attorney's fees and costs, and such further relief as the Court
may deem just and proper;
d. On the Fourth Cause of Action a Declaratory Judgment asserting that the
guarantors of Surrey Equities, LLC and Surrey Management, LLC,
including Jacob Frydman, may set off, against any sums allegedly due
from them, in an amount to be proven at trial, believed to be in excess of

$1.7 million.
e. The costs and disbursements incurred in this action, together with such
other and further relief as this Court deems just and proper.
Dated: New York, New York
March 1, 2011

WROBEL & SCHATZ LLP


David C. Wrobel, Esq.
Attorneys for Plaintiffs

1040 Avenue of the Americas


II1h Floor
New York, New York 10018-3703
2 \ 2-421-8100

5
Case 1:11-cv-02247-DAB Document 31
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF' NEW YORK

Filed 12/.2 1,,/. 1. 2 Page.. 1.. o.. f-.,.1.,..,.

.
.
4""'
SURREYEQUITIES, LLC und
SURR.BY PROPERTY MANAOEMBNT, LLC. and
IACOB FRYDMAN,

Case No.: 1:11-cv-02247 (DAB)

-against,.

CAPITAL ONE. N.A. as Successor to

NORTHFORK.BANK.
Defendant.

. ST!PULATION OF DISMISSAL
Plaintiffs Surrey Equities, LLC, Surrey Property Management, LLC, and Jacob Frydman, and Defendent

Capital 0.110, N.A.,hereby stipulate that this matter shall be dismissed with prejudice and wi1hout fees or costs to any party.
Dated: New York, New York
September
2012
r.-t"'

cl Wrobel_(DW-524
Mary Katherine Shcmtn.

wa. .

.1040 Avenue of thoAmerioM, l ln,Jlloor

New Yodc,NY 10018 .


(212) 421-8100

Attorneyfor PlaJ.ntJ.ffe

PAUL

&w,......,
:

Carle
al.worth (CW-5401)
Cynthfa C. Cortin

{r-t

75 Bast 5Stb Street

New YOTk., NY 10022 (212) 318-5000


A.ttorney3for DefendlJllt