SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX EMMANUEL YUSUF, ISSAKA MOHAMMED, ABDULAI SALLAH, EDGAR AQUINO, AUGUSTINA Index No. 251206/15 FRIMPOMA, SARA AGYEDUMWAH, PAULINO JIMINEZ, ZAINAB FAROUK, HENRIETTA GYIMAH, ANSWER CHARLES ACHEAMPONG, MARCELO CHARLES, WILBERFORCE YEBOAH, LINDA JOHNS, AHMED GADO, JOSEPHINE ALLSOP, LESLIE SANDERS, CHARLEY ANETOR and MARJORIE KING, Plaintiffs, - against SHREE GANESH BRONX, LLC, DHIREN MEHTA, as principal, and LALITA SINGH, as managing agent. Defendants. Defendants Shree Ganesh Bronx, LLC, Dhiren Mehta, as principal, and Lalita Singh, as managing agent (?Defendants?), by their attorneys, Belkin Burden Wenig Goldman, LLP, as and for their answer to plaintiffs? complaint dated August 10, 2015 (the ?Complaint?), allege as follows: 1. Deny the allegations contained in paragraph 1 of the Complaint, except admit that plaintiffs? apartments are subject to the Rent Stabilization Law 2. Deny the allegations contained in paragraph 2 of the Complaint. 3. Deny the allegations contained in paragraph 3 of the Complaint. 4. Deny the allegations contained in paragraph 4 of the Complaint, except admit that Emmanuel Yusuf is the tenant of apartment 3F. 5. Deny the allegations contained in paragraph 5 of the Complaint, except admit that lsaka Mohamed is the tenant of apartment 2K. 6. Deny the allegations contained in paragraph 6 of the Complaint, except admit that Sallah Abdulai is the tenant of apartment SE. 7. Deny the allegations contained in paragraph 7 of the Complaint, except admit that Edgar Aquino is the tenant of apartment 3T. 8. Deny the allegations contained in paragraph 8 of the Complaint, except admit that Agustina Frimpona is the tenant of apartment 3E. 9. Deny the allegations contained in paragraph 9 of the Complaint, except admit that Sara Agyedumwah is the tenant of apartment 2L. 10. Deny the allegations contained in paragraph 10 of the Complaint, except admit that Paulino Jimenez is the tenant of apartment 4C. 11. Deny the allegations contained in paragraph 11 of the Complaint, except admit that Emmanuel Yusuf is the tenant of apartment 3F. 12. Deny the allegations contained in paragraph 12 of the Complaint, except admit that Zainab Farouk is the tenant of apartment 2J. 13. Deny the allegations contained in paragraph 13 of the Complaint, except admit that Charles Acheampong is the tenant of apartment BB. 14. Deny the allegations contained in paragraph 14 of the Complaint, except admit that Charles Marcelo is the tenant of apartment 4L. 15. Deny the allegations contained in paragraph 15 of the Complaint, except admit that Wilbefore Yeboah is the tenant of apartment BD. 16. Deny the allegations contained in paragraph 16 of the Complaint, except admit that Linda Johns is the tenant of apartment 6D. 17. Deny the allegations contained in paragraph 17 of the Complaint, except admit that Josephine Allsop is the tenant of apartment 6K. -2- 18. Deny the allegations contained in paragraph 18 of the Complaint, except admit that Ahmed Gado is the tenant of apartment 6L. 19. Deny the allegations contained in paragraph 19 of the Complaint, except admit that Leslie Sanders is the tenant of apartment 5H. 20. Deny the allegations contained in paragraph 20 of the Complaint, except admit that Marjorie King is the tenant of apartment 1E. 21. Admit the allegations contained in paragraph 21 of the Complaint. 22. Deny the allegations contained in paragraph 22 of the Complaint. 23. Deny the allegations contained in paragraph 23 of the Complaint. 24. Deny the allegations contained in paragraph 24 of the Complaint, except admit that the Court has subject matter jurisdiction as provided for in the New York State Constitution and Civil Practice Law and Rules. 25. Deny the allegations contained in paragraph 25 of the Complaint, except admit that venue is proper. 26. Deny the allegations contained in paragraph 26 of the Complaint and refer the Court to the referenced statutory provisions for the terms thereof. 27. Deny the allegations contained in paragraph 27 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 28. Deny the allegations contained in paragraph 28 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 29. Deny the allegations contained in paragraph 29 of the Complaint and refer the Court to the referenced statutory provisions for the terms thereof. 30. Deny the allegations contained in paragraph 30 of the Complaint and refer the Court to the referenced statutory provisions for the terms thereof. -3- 31. Deny the allegations contained in paragraph 31 of the Complaint and refer the Court to the referenced statutory and regulatory provisions for the terms thereof. 32. Deny the allegations contained in paragraph 32 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 33. Deny the allegations contained in paragraph 33 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 34. Deny the allegations contained in paragraph 34 of the Complaint and refer the Court to the referenced statutory and regulatory provisions for the terms thereof. 35. Deny the allegations contained in paragraph 35 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 36. Deny the allegations contained in paragraph 36 of the Complaint, except admit that the building receives 421-a tax benefits. 37. Deny the allegations contained in paragraph 37 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 38. Deny the allegations contained in paragraph 38 of the Complaint, and refer the Court to any applicable leases for the terms thereof. 39. Deny the allegations contained in paragraph 39 of the Complaint, except admit that Shree Ganesh Bronx, LLC owns the building. 40. Deny the allegations contained in paragraph 40 of the Complaint. 41. Deny the allegations contained in paragraph 41 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 42. Deny the allegations contained in paragraph 42 of the Complaint. -4- 43. Deny the allegations contained in paragraph 43 of the Complaint. 44. Deny the allegations contained in paragraph 44 of the Complaint. 45. Deny knowledge or information concerning the truth of the allegations contained in paragraph 45 of the Complaint and refer the Court to the referenced statutory and regulatory provisions for the terms thereof. 46. Deny the allegations contained in paragraph 46 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 47. Deny the allegations contained in paragraph 47 of the Complaint. 48. Deny the allegations contained in paragraph 48 of the Complaint, except admit that Emmanuel Yusuf is the tenant of apartment 3F. 49. Deny the allegations contained in paragraph 49 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 50. Deny the allegations contained in paragraph 50 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 51. Deny the allegations contained in paragraph 51 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 52. Deny the allegations contained in paragraph 52 of the Complaint, and refer the Court to the applicable lease documents for the terms thereof. 53. Deny the allegations contained in paragraph 53 of the Complaint. 54. Deny the allegations contained in paragraph 54 of the Complaint. 55. Deny the allegations contained in paragraph 55 of the Complaint. 56. Deny the allegations contained in paragraph 56 of the Complaint, and refer the Court to any notices for the contents thereof. 57. Deny the allegations contained in paragraph 57 of the Complaint, except admit that Isaka Mohamed is the tenant of apartment 2K. 58. Deny the allegations contained in paragraph 58 of the Complaint. 59. Deny the allegations contained in paragraph 59 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 60. Deny the allegations contained in paragraph 60 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 61. Deny the allegations contained in paragraph 61 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 62. Deny the allegations contained in paragraph 62 of the Complaint. 63. Deny the allegations contained in paragraph 63 of the Complaint. 64. Deny the allegations contained in paragraph 64 of the Complaint, and refer the Court to any notices for the contents thereof. 65. Deny the allegations contained in paragraph 65 of the Complaint, except admit that Sallah Abdulai is the tenant of apartment 5E. 66. Deny the allegations contained in paragraph 66 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 67. Deny the allegations contained in paragraph 67 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 68. Deny the allegations contained in paragraph 68 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. -6- 69. Deny the allegations contained in paragraph 69 of the Complaint. 70. Deny the allegations contained in paragraph 70 of the Complaint. 71. Deny the allegations contained in paragraph 71 of the Complaint. 72. Deny the allegations contained in paragraph 72 of the Complaint, and refer the Court to any notices for the contents thereof. 73. Deny the allegations contained in paragraph 73 of the Complaint, except admit that Edgar Aquino is the tenant of apartment 3T. 74. Deny the allegations contained in paragraph 74 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 75. Deny the allegations contained in paragraph 75 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 76. Deny the allegations contained in paragraph 76 of the Complaint. 77. Deny the allegations contained in paragraph 77 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 78. Deny the allegations contained in paragraph 78 of the Complaint, except admit that a non?payment proceeding was commenced against Edgar Aquino. 79. Deny the allegations contained in paragraph 79 of the Complaint, except admit that Augustine Frimpona is the tenant of apartment 3E. 80. Deny the allegations contained in paragraph 80 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 81. Deny the allegations contained in paragraph 81 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 82. Deny the allegations contained in paragraph 82 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. -7- 83. Deny the allegations contained in paragraph 83 of the Complaint, and refer the Court to the applicable lease documents for the terms thereof. 84. Deny the allegations contained in paragraph 84 of the Complaint, and refer the Court to the applicable lease documents for the terms thereof. 85. Deny the allegations contained in paragraph 85 of the Complaint. 86. Deny the allegations contained in paragraph 86 of the Complaint. 87. Deny the allegations contained in paragraph 87 of the Complaint, and refer the Court to any notices for the contents thereof. 88. Deny the allegations contained in paragraph 88 of the Complaint, except admit that a non?payment proceeding was commenced against Augustine Frimpoma. 89. Deny the allegations contained in paragraph 89 of the Complaint, except admit that Sara Agyedumwah is the tenant of apartment 2L. 90. Deny the allegations contained in paragraph 90 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 91. Deny the allegations contained in paragraph 91 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 92. Deny the allegations contained in paragraph 92 of the Complaint and refer the Court to the governmental records for the contents thereof. 93. Deny the allegations contained in paragraph 93 of the Complaint and refer the Court to the governmental records for the contents thereof. 94. Deny the allegations contained in paragraph 94 of the Complaint, and refer the Court to the applicable lease documents for the terms thereof. 95. Deny the allegations contained in paragraph 95 of the Complaint, and refer the Court to any notices for the contents thereof. 96. Deny the allegations contained in paragraph 96 of the Complaint, and refer the Court to any notices for the contents thereof. 97. Deny the allegations contained in paragraph 97 of the Complaint, except admit that a non-payment proceeding was commenced against Sara Agyedumwah. 98. Deny the allegations contained in paragraph 98 of the Complaint, except admit that Paulino Jimenez is the tenant of apartment 4C. 99. Deny the allegations contained in paragraph 99 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 100. Deny the allegations contained in paragraph 100 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 101. Deny the allegations contained in paragraph 101 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 102. Deny the allegations contained in paragraph 102 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 103. Deny the allegations contained in paragraph 103 of the Complaint. 104. Deny the allegations contained in paragraph 104 of the Complaint. 105. Deny the allegations contained in paragraph 105 of the Complaint, and refer the Court to the applicable lease documents for the terms thereof. 106. Deny the allegations contained in paragraph 106 of the Complaint, and refer the Court to any notices for the contents thereof. 107. Deny the allegations contained in paragraph 107 of the Complaint, and refer the Court to any notices for the contents thereof. 108. Deny the allegations contained in paragraph 108 of the Complaint, except admit that Zainab Farouk Jimenez is the tenant of apartment 2J. 109. Deny the allegations contained in paragraph 109 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 110. Deny the allegations contained in paragraph 110 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 111. Deny the allegations contained in paragraph 111 of the Complaint. 112. Deny the allegations contained in paragraph 112 of the Complaint and refer the Court to the governmental records for the contents thereof. 113. Deny the allegations contained in paragraph 113 of the Complaint, and refer the Court to the applicable lease documents for the terms thereof. 114. Deny the allegations contained in paragraph 114 of the Complaint, and refer the Court to any notices for the contents thereof. 115. Deny the allegations contained in paragraph 115 of the Complaint, and refer the Court to any notices for the contents thereof. 116. Deny the allegations contained in paragraph 116 of the Complaint, except admit that a non-payment proceeding was commenced against Zainab Farcuk. 117. Deny the allegations contained in paragraph 117 of the Complaint, except admit that Henrietta Gyimah is the tenant of apartment 4D. 118. Deny the allegations contained in paragraph 118 of the Complaint and refer the Court to the applicable lease documents for the terms thereof and to the governmental records for the contents thereof. -10- 119. Deny the allegations contained in paragraph 119 of the Complaint, and refer the Court to the applicable lease documents for the terms thereof. 120. Deny the allegations contained in paragraph 120 of the Complaint, and refer the Court to the applicable lease documents for the terms thereof. 121. Deny the allegations contained in paragraph 121 of the Complaint, and refer the Court to the applicable lease documents for the terms thereof. 122. Deny the allegations contained in paragraph 122 of the Complaint. 123. Deny the allegations contained in paragraph 123 of the Complaint, and refer the Court to any notices for the contents thereof. 124. Deny the allegations contained in paragraph 124 of the Complaint, and refer the Court to any notices for the contents thereof. 125. Deny the allegations contained in paragraph 125 of the Complaint, except admit that Charles Acheampong is the tenant of apartment BB. 126. Deny the allegations contained in paragraph 126 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 127. Deny the allegations contained in paragraph 127 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 128. Deny the allegations contained in paragraph 128 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 129. Deny the allegations contained in paragraph 129 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 130. Deny the allegations contained in paragraph 130 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. -11- 131. Deny the allegations contained in paragraph 131 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 132. Deny the allegations contained in paragraph 132 of the Complaint. 133. Deny the allegations contained in paragraph 133 of the Complaint, and refer the Court to any notices for the contents thereof. 134. Deny the allegations contained in paragraph 134 of the Complaint, and refer the Court to any notices for the contents thereof. 135. Deny the allegations contained in paragraph 135 of the Complaint, except admit that Charles Marcelo is the tenant of apartment 4L. 136. Deny the allegations contained in paragraph 136 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 137. Deny the allegations contained in paragraph 137 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 138. Deny the allegations contained in paragraph 138 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 139. Deny the allegations contained in paragraph 139 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 140. Deny the allegations contained in paragraph 140 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 141. Deny the allegations contained in paragraph 141 of the Complaint. 142. Deny the allegations contained in paragraph 142 of the Complaint, and refer the Court to any notices for the contents thereof. -12- 143. Deny the allegations contained in paragraph 143 of the Complaint, and refer the Court to any notices for the contents thereof. 144. Deny the allegations contained in paragraph 144 of the Complaint, except admit that Wilberforce Yeboah is the tenant of apartment ED. 145. Deny the allegations contained in paragraph 145 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 146. Deny the allegations contained in paragraph 146 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 147. Deny the allegations contained in paragraph 147 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 148. Deny the allegations contained in paragraph 148 of the Complaint and refer the Court to the referenced governmental records for the contents thereof. 149. Deny the allegations contained in paragraph 149 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 150. Deny the allegations contained in paragraph 150 of the Complaint. 151. Deny the allegations contained in paragraph 1510f the Complaint, and refer the Court to any notices for the contents thereof. 152. Deny the allegations contained in paragraph 152 of the Complaint, and refer the Court to any notices for the contents thereof. 153. Deny the allegations contained in paragraph 153 of the Complaint, except admit that a non-payment proceeding was commenced against Wilberforce Yeboah. -13- 154. Deny the allegations contained in paragraph 154 of the Complaint, except admit that Linda Johns is the tenant of apartment SD. 155. Deny the allegations contained in paragraph 155 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof, to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 156. Deny the allegations contained in paragraph 156 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 157. Deny the allegations contained in paragraph 157 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 158. Deny the allegations contained in paragraph 158 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 159. Deny the allegations contained in paragraph 159 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 160. Deny the allegations contained in paragraph 160 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 161. Deny the allegations contained in paragraph 161 of the Complaint. 162. Deny the allegations contained in paragraph 162 of the Complaint, and refer the Court to any notices for the contents thereof. -14- 163. Deny the allegations contained in paragraph 163 of the Complaint, and refer the Court to any notices for the contents thereof. 164. Deny the allegations contained in paragraph 164 of the Complaint, except admit that Ahmed Gado is the tenant of apartment 6L. 165. Deny the allegations contained in paragraph 165 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 166. Deny the allegations contained in paragraph 166 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 167. Deny the allegations contained in paragraph 167 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 168. Deny the allegations contained in paragraph 168 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 169. Deny the allegations contained in paragraph 169 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 170. Deny the allegations contained in paragraph 170 of the Complaint. 171. Deny the allegations contained in paragraph 171 of the Complaint. 172. Deny the allegations contained in paragraph 172 of the Complaint, and refer the Court to any notices for the contents thereof. 173. Deny the allegations contained in paragraph 173 of the Complaint, and refer the Court to any notices for the contents thereof. -15.. 174. Deny the allegations contained in paragraph 174 of the Complaint, except admit that a non-payment proceeding was commenced against Ahmed Gado. 175. Deny the allegations contained in paragraph 175 of the Complaint, except admit that Josephine Allsop is the tenant of apartment 6K. 176. Deny the allegations contained in paragraph 176 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 177. Deny the allegations contained in paragraph 177 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 178. Deny the allegations contained in paragraph 178 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 179. Deny the allegations contained in paragraph 179 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 180. Deny the allegations contained in paragraph 180 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 181. Deny the allegations contained in paragraph 181 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 182. Deny the allegations contained in paragraph 182 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 183. Deny the allegations contained in paragraph 183 of the Complaint. 184. Deny the allegations contained in paragraph 184 of the Complaint, and refer the Court to any notices for the contents thereof. 185. Deny the allegations contained in paragraph 185 of the Complaint, and refer the Court to any notices for the contents thereof. -15- 186. Deny the allegations contained in paragraph 186 of the Complaint, except admit that a non?payment proceeding was commenced against Josephine Allsop. 187. Deny the allegations contained in paragraph 187 of the Complaint, except admit that Leslie Sanders is the tenant of apartment SH. 188. Deny the allegations contained in paragraph 188 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 189. Deny the allegations contained in paragraph 189 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 190. Deny the allegations contained in paragraph 190 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 191. Deny the allegations contained in paragraph 191 of the Complaint and refer the Court to the referenced governmental records for the contents thereof. 192. Deny the allegations contained in paragraph 192 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 193. Deny the allegations contained in paragraph 193 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 194. Deny the allegations contained in paragraph 194 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 195. Deny the allegations contained in paragraph 195 of the Complaint. 196. Deny the allegations contained in paragraph 196 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. -17_ 197. Deny the allegations contained in paragraph 197 of the Complaint, and refer the Court to any notices for the contents thereof. 198. Deny the allegations contained in paragraph 198 of the Complaint, except admit that Charlie Anetor is the tenant of apartment SG. 199. Deny the allegations contained in paragraph 199 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. 200. Deny the allegations contained in paragraph 200 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 201. Deny the allegations contained in paragraph 201 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 202. Deny the allegations contained in paragraph 202 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 203. Deny the allegations contained in paragraph 203 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 204. Deny the allegations contained in paragraph 204 of the Complaint, and refer the Court to any notices for the contents thereof. 205. Deny the allegations contained in paragraph 205 of the Complaint, and refer the Court to any notices for the contents thereof 206. Deny the allegations contained in paragraph 206 of the Complaint, except admit that Marjorie King is the tenant of apartment 1E. 207. Deny the allegations contained in paragraph 207 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 208. Deny the allegations contained in paragraph 208 of the Complaint and refer the Court to the referenced regulatory provisions for the terms thereof. -13- 209. Deny the allegations contained in paragraph 209 of the Complaint and refer the Court to the applicable lease documents for the terms thereof, and to the referenced governmental records for the contents thereof. 210. Deny the allegations contained in paragraph 210 of the Complaint and refer the Court to the referenced governmental records for the contents thereof. 211. Deny the allegations contained in paragraph 211 of the Complaint and refer the Court to the referenced governmental records for the contents thereof. 212. Deny the allegations contained in paragraph 212 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 213. Deny the allegations contained in paragraph 213 of the Complaint. 214. Deny the allegations contained in paragraph 214 of the Complaint, and refer the Court to any notices for the contents thereof. 215. Deny the allegations contained in paragraph 215 of the Complaint, and refer the Court to any notices for the contents thereof. AS TO THE FIRST CAUSE OF ACTION 216. Answering paragraph 216 of the Complaint, defendants repeat and reallege their responses to paragraphs 1 through 215 of the Complaint as if fully set forth herein. 217. Deny the allegations contained in paragraph 217 of the Complaint and refer the Court to the referenced statutory and regulatory provisions for the terms thereof. 218. Deny the allegations contained in paragraph 218 of the Complaint and refer the Court to the referenced statutory and regulatory provisions for the terms thereof. -19- 219. Deny the allegations contained in paragraph 219 of the Complaint and refer the Court to the applicable lease documents for the terms thereof. 220. Deny the allegations contained in paragraph 220 of the Complaint, except admit that plaintiffs? apartments are and remain subject to the RSL. AS TO THE SECOND CAUSE OF ACTION 221. Answering paragraph 221 of the Complaint, defendants repeat and reallege their responses to paragraphs 1 through 220 of the Complaint as if fully set forth herein. 222. Deny the allegations contained in paragraph 222 of the Complaint. 223. Deny the allegations contained in paragraph 223 of the Complaint and refer all questions of law to the court. 224. Deny the allegations contained in paragraph 224 of the Complaint. 225. Deny the allegations contained in paragraph 225 of the Complaint. 226. Deny the allegations contained in paragraph 226 of the Complaint. AS TO THE THIRD CAUSE OF ACTION 227. Answering paragraph 227 of the Complaint, defendants repeat and reallege their responses to paragraphs 1 through 226 of the Complaint as if fully set forth herein. 228. Deny the allegations contained in paragraph 228 of the Complaint. 229. Deny the allegations contained in paragraph 229 of the Complaint. FIRST AFFIRMATIVE DEFENSE 230. Plaintiffs waived any claims they may have had to seek damages or other relief for their claims. SECOND AFFIRMATIVE DEFENSE 231. Defendants did not overcharge plaintiffs. -20- AFFIRMATIVE DEFENSE 232. Any award of damages or other relief would cause plaintiffs to receive a windfall. FOURTH AFFIRMATIVE DEFENSE 233. Some or all of plaintiffs' claims are barred by the applicable statutes of limitation. FIFTH AFFIRMATIVE DEFENSE 234. Plaintiffs failed to exhaust their administrative remedies prior to commencing the instant action. SIXTH AFFIRMATIVE DEFENSE 235. To the extent that any of plaintiffs? claims have previously been determined or adjudicated by an administrative agency or court, they are barred by the doctrine of res judicata. SEVENTH AFFIRMATIVE QEFENSE 236. To the extent that any of plaintiffs? claims have previously been determined or adjudicated by an administrative agency or court, they are barred by the doctrine of collateral estoppel. EIGHTH AFFIRMATIVE DEFENSE 237. Plaintiffs are not entitled to recover attorneys? fees under their leases or applicable law. 238. Some or all of plaintiffs? claims are barred to the extent that they have not been occupying their apartments as their primary residence. -21- TENTH AFFIRMATIVE DEFENSE 239. The Complaint fails to state a cause of action upon which relief may be granted. ELEVENTH AFFIRMATIVE DEFENSE 240. Plaintiffs are not entitled to declaratory relief because there is no genuine dispute regarding the current rights of the parties, and plaintiffs? are not entitled to an advisory opinion regarding future rights, WHEREFORE, defendants respectfully demands judgment as follows: an order dismissing the Complaint; thatjudgment be entered in Defendants? favor; and for such other and further relief as this Court may deem just and proper. Dated: New York, New York September 1, 2015 BURDEN WENIG GOLDMAN, LLP Attorneys for Defendants 270 Madison Avenue New York, New Yo 016 (212) 867-446 By: Steven Kirkpatrick TO: LEGAL SERVICES NYC Attorneys for Plaintiffs 349 East 149?? Street, 10th Floor Bronx, New York 10451 718-928-371 1 THE LEGAL SOCIETY Attorneys for Plaintiffs 260 East 1615t Street, 8?h Floor Bronx, New York 10451 646?340?1 937 -22- 1699.0001/1658817