CIVIL COURT OF THE CITY OF NEW YORK COUNTY OF NEW YORK: HOUSING PART JEFF CALTABIANO, BRIAN CLARK, STEVEN LEE, SHAHED MIAH, CHERRY MUI, SUK HAY MUI, and DAVID NG, Tenants - Petitioners, -against- SASSAN MAHFAR, SINA MAHFAR, 102 NORFOLK LLC, SMA EQUITIES INC., DAVID MOUSSAZADEH, JEANETTE COLAIANNI, and OMER ZWICKEL, Landlord Respondents, THE DEPARTMENT OF HOUSING PRESERVATION AND DEVELOPMENT OF THE CITY OF NEW YORK, THE DEPARTMENT OF BUILDINGS OF THE CITY OF NEW YORK, and THE DEPARTMENT OF HEALTH AND MENTAL HYGENE OF THE CITY OF NEW YORK Respondents. Index No.: HP 902/2015 STIPULATION 0F SETTLEMENT Premises: 102 Norfolk Street New York, NY 10002 WHEREAS, pursuant to the New York City Housing Maintenance Code, petitioning tenants Jeff Caltabiano, Brian Clark, Steven Lee, Shahed Miah, Cherry Mui, Suk Hay Mui, and David Ng (?Petitioners?) residing at 102 Norfolk Street, New York, New York (the ?Building?), brought this proceeding seeking an order to correct, Civil penalties, and other appropriate relief; WHEREAS, Respondent 102 Norfolk LLC (?Respondent-Owner?) is the owner of the Building; WHEREAS, respondents Sassan Mahfar, Sina Mahfar, and David Moussazadeh are Partner/Members and Of?cers of Respondent-Owner; WHEREAS, SMA Equities Inc. is the Managing Agent for the Building; WHEREAS, respondent Jeanette Colaianni is the registered Managing Agent of the Building; WHEREAS, respondent Omer Zwickel is listed as the Head Of?cer of WHEREAS, respondent Department of Housing Preservation and Development of the City of New York is the City Department which is charged with enforcement of, 131g a_lia, the Housing Maintenance Code; WHEREAS, respondent The Department of Buildings of the City of New York is the City Department charged with enforcement of, 1% Q, the Buildings Code; WHEREAS, respondent The Department of Health and Mental Hygiene of the City of New York is the City Department charged with enforcement of, intg? a_li_a, the Health Code; WHEREAS, Respondent-Owner, SMA, and individual respondents Sassan Mahfar, Sina Mahfar, Jeanette Colaianni, David Moussazadeh and Omer Zwickel shall collectively be referred to as the ?Respondents?; WHEREAS, there are 34 open violations of record of the Housing Maintenance Code and 3 open Environmental Control Board violations recorded against the Building; WHEREAS, pursuant to the Housing Maintenance Code, Petitioners sought an order to correct outstanding violations as well as civil penalties for harassment; WHEREAS, the parties desire to obviate the need for further litigation and it is expressly understood that, with respect to the petition filed by Petitioners, this is a compromise settlement -2- entered into solely for the purposes of avoiding the expenses and inconvenience of further litigation; IT IS HEREBY AGREED BY AND BETWEEN THE PARTIES each represented by counsel that THE PROCEEDINGS ARE SETTLED AS FOLLOWS: 1. Respondents consent to the jurisdiction of the Court in this proceeding. 2. This Court shall retain jurisdiction of this proceeding. 3. This Stipulation is a product of the negotiations between the parties and shall not be construed more strongly against any party hereto. 4. This Stipulation shall be binding on all parties, successors and assigns, of?cers, agents, representatives, af?liates, ?duciaries, insurers, administrators, directors, and owners for a period not to exceed 24 months (the ?Sunset Date?) unless, on or before the Sunset Date, Petitioners restore this proceeding to the calendar for purposes of compelling compliance with the terms hereof and the Court issues a ?nal decision and/or order determining that Respondents were in material breach of this Stipulation (the ?Breach Order?). In the event a Breach Order is issued, then the Sunset Date shall be deemed extended for an additional 12 months. In the event that a Breach Order is reversed on appeal, then any extension of the Sunset Date that was triggered by the existence of that Breach Order will be null and void, nunc pro tune. Upon the occurrence of the Sunset Date, the Respondents? obligations hereunder shall be null and void, except as to those items which speci?cally state that they shall survive the expiration of this Stipulation, without prejudice to Respondents? continuing obligation to comply with law. 5. As used throughout this Stipulation, the terms set forth below shall mean as follows: ?Effective Date? means the date this Stipulation is executed by the parties hereto. ?Emergency? means a condition dangerous to life, safety, or health of tenants at the Building or individuals in the surrounding area including but not limited to any condition that is, or would be, categorized as a Class?C Violation under the Housing Maintenance Code requiring repairs within twenty-four (24) hours or a Class-1 Environmental Control Board Violation. ?Respond? means the acknowledgement and assessment of Repair Requests. SAFE CONSTRUCTION PRACTICES 6. Respondents shall comply with the Housing Maintenance Code, Buildings Code, Health Code and all applicable regulations as promulgated by HPD, DOB, and DOHMH with respect to any construction performed at the Building. 7. Respondents shall comply with the New York City Lead Law and all applicable regulations as promulgated by HPD and the New York City Department of Health and Mental Hygiene including pre-?ling with DOHMH, if applicable, as well as with all applicable federal and state law, when performing work that will disturb lead?based paint or paint presumed to contain lead in any part of the Building as required by law. Regardless of legal requirements, Respondents agree to implement the lead-safe work practices (as described at 40 C.F.R. 745.80, et seq.) and lead-safe work practices (issued pursuant to Local Law 1 of 2004) for any work that will disturb lead-based paint or paint presumed to contain lead in any part of Building including, but not limited to: Employing an EPA?certi?ed ?rm with at least three (3) years? experience in performing comparable work that employs EPA-certi?ed personnel who have received lead training; Posting notices in the Building lobby to advise residents of lead safe renovation no less than twenty-four (24) hours prior to commencing work; (0) Performing clearance dust tests after all work is completed, and sending results of all tests to Petitioners? attorneys upon receipt; Sealing off work areas according to the Lead~Safe Certified Guide To Renovate Right (the ?Lead Guide?) published by the United States Environmental Protection Agency (6) Using HEPA air scrubbers in all work areas as required by law; Keeping all waste bagged and wet during work and disposing of all waste as required by law; Wet mopping and HEPA vacuuming the work area and any surrounding area at the end of each work shift as required by law; Complying with any other cleaning and protective measures described in the lead?safe work practice standards (at 40 C.F.R. 745.85) or in the lead?safe work practices described in the regulations issued by the HPD pursuant to Local Law 1 of 2004. 8. Respondents shall provide Petitioners and their counsel with an updated and comprehensive lead and/or asbestos plan, as applicable, by email and/or mail and by posting a copy in the lobby at least fourteen (14) calendar days prior to commencing any planned or future work that might disturb lead paint or asbestos in occupied units and/or common areas of the -5- Building. Respondents shall also provide Petitioners and their counsel with an updated and comprehensive lead and/or asbestos plan as applicable, by email and/or mail and by posting a copy in the lobby at least fourteen (14) calendar days prior to commencing any planned or future work that might disturb lead paint or asbestos in vacant apartment at the Building. 9. Respondents shall provide Petitioners? counsel with a. copy of the existing Tenant Protection Plan on ?le with DOB for the Building upon execution of this Stipulation, to the extent one exists, and shall provide any further Tenant Protection Plans to Petitioners? counsel within 1 week of Respondents? receipt of stamped, approved plans from DOB. 10. Respondents shall conduct all construction, demolition, repair and alteration work pursuant to the applicable Tenant Protection Plans, safe work practices, including the Lead Guide, when applicable, and the law. Respondents shall obtain all required permits, use licensed workers, and perform all work in a workmanlike manner. Workers must clean the work area at the end of each day, and may only leave equipment, materials and/or isolation areas intact to the extent that they do not block ingress or egress or pose any hazard to tenants. ll. Upon execution of this Stipulation, Respondents shall provide Petitioners a projected construction schedule for the Building for the month following the Effective Date, and continuing thereafter on a basis, subject to revision, specifying the general scope of work to be performed in substantially the same form as Exhibit annexed hereto and the dates when construction work will cause noise or other disruptions, as reasonably anticipated. In the event of signi?cant changes or additions to the scope of work or the schedule, Respondents shall provide Petitioners and their counsel with an updated schedule with 2 business days? notice, or as soon as othelwise practicable, by email to counsel and posting notice of the foregoing in the lobby of the Building. In no event. shall construction or demolition work begin prior to 9 am or -6- end later than 6 pm. Workers may arrive at the Building to set up beginning at 8 am. Construction and demolition work shall only occur Monday through Friday or pursuant to After?- Hours Variance(s) issued by DOB, which shall be utilized only to perform work which Respondents reasonably anticipate does not involve demolition or signi?cant hammering, sawing or drilling, and will not cause excessive noise or disturbance. Respondents and their vendors/agents may photographs/videotape apartment conditions as needed to perform alterations, repairs and/or construction. 12. Respondents shall either give Petitioners forty?eight (48) hours advance written notice prior to the commencement of any scheduled or reasonably anticipated disruption of essential services, including but not limited to heat, hot water, and/or electricity or (ii) post notice if unscheduled work that disrupts essential services is undertaken due to Emergency. Respondents shall use their best efforts to minimize disruptions of essential services. Disruptions to essential services necessitated by Emergency repairs do not require advance notice, but Respondents will notify Petitioners of Emergency disruptions as soon as practicable but in no event later than the commencement of the next business day, and will inform Petitioners of the disruption?s anticipated duration when possible. 13. Respondents shall provide Petitioners? counsel with a copy of all general construction permits issued to Respondents for the Building within two (2) business days of Respondents? receipt of such permits. 14. Respondents agree that, upon two (2) business day? notice to Respondent Omer Zwickel or another agent designated by Respondents, Petitioners? counsel may walk through construction areas in the Building not otherwise accessible to Petitioners, accompanied by Respondents and/or their agents. Such shall only be conducted for the purpose of -7- investigating speci?c concerns regarding construction practices, safety, or disruptions to Petitioners where construction is taking place in said areas. Petitioners shall advise Respondents of said concerns in writing two (2) business days prior to a It is understood and agreed that access to construction areas for Petitioners? counsel is contingent upon counsel following all safety precautions and instructions of Respondents and their agents regarding safety. . Petitioners? counsel may take photos in construction areas for the sole purpose of informing Petitioners about the status of construction. In addition to the foregoing, the parties agree that all construction work and photographs of same shall be con?dential and may not be disclosed to any third party except either party hereto may disclose the status of construction and/or photographs of same to the extent required by law, court order or by governmental regulation or in any litigation or arbitration between the parties even if such disclosure as stated herein results in the construction work and/or photographs becoming public information. In the event any photos leak and/or become public, this provision shall become null and void, all photos previously taken will be returned or permanently deleted, and Petitioners will cooperate with any actions by Respondents to quash the distribution of such photos. REPAIRS AND ACCESS 15. Respondents shall resolve all HPD violations, subject to access provided by Petitioners within the following time frames: Class Violations within ?fteen (15) calendar days of the Effective Date for currently-open Class Violations; within twenty-four (24) hours of receiving noti?cation of a new Class Violation unless such violation is for window guards. RE?x75679\0003\6i6019vl Class Violations within ?fteen (15) calendar days of the Effective Date for currently open Class violations; within thirty (30) calendar days of receiving noti?cation of any new Class violations. (0) Class A Violations within forty-?ve (45) calendar days of the Effective Date for currently open Class A violations; within ninety (90) calendar days of receiving noti?cation of any new Class A Violations. 16. Respondents shall notify Petitioners when HPD or DOB schedule an inspection to clear violations at the Building, and will give at least seventy-two (72) hours? notice to Petitioners to the extent the agencies provide such notice to Respondents and where access is required to Petitioners? apartments. 17. Respondents shall resolve all DOB and/or ECB violations, subject to access provided by Petitioners, within the following time frames: Class-1 Violations within thirty (30) calendar days of the Effective Date for currently open Class-1 Violations; within twenty?four (24) hours of receiving noti?cation of a new Class-l Violation. Class-2 Violations within thirty (30) calendar days of the Effective Date for currently Open Class-2 Violations; within forty (40) calendar days of receiving notification of any new Class-2 or Class-3 Violations. . sponden shall per rm all othfuilding wi and indynal tenant repairs cure all of violati 3 listed the violati report i this procee ing within sixty (60) . . tho/ml 8 ys of the fective 19. For tenant repairs to cure the violations listed in the violation report in this calendar proceeding, Petitioners shall provide access on the dates and times agreed upon at least seven (7) -9- days in advance. Each party shall provide the other forty-eight (48) hours? notice in the event the party needs to reschedule pre-arranged access dates. To the extent a request for repair is made in writing, at or other written notice if Petitioners do not have access to said website, Respondents shall acknowledge a Petitioner?s request for non~Emergency repairs within twenty-four (24) hours, and shall contact Petitioners by Petitioners? preferred method of contact (if provided by Petitioner) to assess repair needs and to schedule repairs within two (2) business days. If such repairs are unclassi?ed by HPD or DOB, and do not constitute an Emergency as de?ned in 11 5(b) herein, Respondents shall complete such repairs within fourteen (14) days of receiving the initial request, subject to access provided by Petitioners. If Petitioners request repairs for an Emergency as de?ned herein, Respondents shall complete such repairs within twenty-four (24) hours or as soon as otherwise practicable. 20. Petitioners agree to work in good faith and cooperate with Respondents with respect to any and all repairs contemplated by this Stipulation. Further, Petitioners agree not to impede or otherwise obstruct any and all construction and/or repairs performed by Respondents in the Building. In furtherance of that, Petitioners shall not call 311 for non-Emergency repair requests unless Petitioners ?rst provided notice of said repair request to Respondents; provided Respondents with a reasonable opportunity to respond as set forth herein; and Respondents failed to respond or timely commence said repair. Nothing herein shall prevent Petitioners from contacting 311 to report a violation or repair need that they believe in good faith to be an Emergency. 21. If Respondents seek access to Petitioners? apartments for future improvements or repairs that do not constitute an Emergency as de?ned herein, Respondents shall provide seven (7) days? notice of need for access in writing, delivered by a veri?able method which may be e- -10- RE\75679\0003\616019vi mail, overnight delivery, or ?rst class and certi?ed mail. ln-hand delivery may be used in addition to a veri?able delivery method listed above. Petitioners shall respond within two (2) days to requests for access, and reserve the discretion to permit access for nonuEmergency repairs on less than seven (7) days? notice. Respondents retain all rights to bring proceedings for breach of obligations of tenancy based on refusal to grant access. 22. If the need for Emergency repairs either to cure Class violations or prevent imminent damage to the Subject Building requires Respondents or their agents to enter Petitioners? apartments without prior notice or consent, Respondents shall notify Petitioners of the entry, the reason it was necessary, the names of the persons who entered, and the scope of work completed within two (2) hours of such entry if done during business hours, otherwise, as soon as practicable. 23. Respondents represent that all repair work performed shall be done in a workmanlike manner and that any defects in the quality of such work shall be repaired by Respondents at Respondents? sole cost and expense. 24. On scheduled access dates, workers shall arrive within two (2) hours of the start of the scheduled access time. If the workers fail to arrive within two (2) hours, Petitioners may leave for the day and will not be deemed to have denied access. COMPENSATION AND WAIVER OF RENT INCREASES 25. Respondents agree to the following conditions with regards to any application for rent increases on the basis of alleged Major Capital Improvements at the Building: Respondents agree to waive the right to seek MCI increases for installation of new security cameras, new mailboxes, and new intercoms, and for any work speci?ed in this -11- RE\75679\0003\616019vi Respondents shall provide Petitioners with 12 months? of rent abatements (the ??Abatements?) at their current legal regulated rent (or, if Petitioner?s apartment is allegedly not rent regulated, at their current contract rent). The Abatements are intended as reimbursement of past rent paid based on demolition and construction conditions at the Subject Premises that allegedly deprived Petitioners of full use and occupancy of their apartments due to the alleged breach of the Warranty of Habitability (the ?Warranty of Habitability Allegations?). The Abatements constitute full settlement of each and every Petitioner?s Warranty of Habitability Allegations from the beginning of time through the dates this Stipulation is executed. The Abatements are not to be construed as income to Petitioners and Respondents shall not designate them as such to any relevant authorities. The Abatements shall first be applied to any and all arrears and then, thereafter, shall be applied to any future rent payments due after the Effective Date. Respondents shall provide each and every Petitioner a new rent statement within ten (10) calendar days of the next billing period. The Abatements shall be applied only to the portion of rent that is the responsibility of the tenant. Respondents shall not apply any portion of the Abatements to portions of rent that are paid by, overdue from, or otherwise the responsibility of any government agency, including the New York City Housing Authority and New York City Department of Housing Preservation and Development and their respective Section 8 voucher programs. If any Petitioner receives a Senior Citizen Rent Increase Exemption or Disability Rent Increase Exemption Respondents shall not apply the Abatement to any portion of the rent for which Respondents receive property tax bene?ts pursuant to those programs. The dollar amounts of the Rent Credit are set forth in Exhibit B. If any Petitioner -12- who receives an Abatement under this paragraph moves out of the Premises before the Abatement has been fully applied to the portion of the rent that is the responsibility of the tenant, Respondents shall issue a certi?ed check or money order to any such Petitioner in the amount of the remaining, unapplied Abatement within ten calendar days of the date any such Petitioner moves out of the Premises. NO HARASSMENT 26. This Stipulation is not an admission of guilt and/or liability on behalf of any of the Respondents, all of whom deny same. 27. Respondents shall re?'ain from engaging in any Harassment against the Petitioners and other individuals residing in Petitioners? apartments. The Term ?Harassment? includes, but is not limited to, the following meanings: Causing repeated interruptions and discontinuances of heat, hot water, and electrical services; Hiring Michel Pimienta or any other buy-out specialist or ?relocator?; speci?cally excluded from this provision is an attorney; (0) Ignoring requests for repairs; Engaging in illegal construction and construction without permits; and Using threatening, intimidating or obscene language in conversations with the Petitioners. 28. Petitioners acknowledge and agree that they shall not engage in behavior which creates a hostile work environment for Respondents and/or their employees, which behavior shall include threatening, intimidating and/or obscene language with Respondents and/or their -13- respective employees and/or agents or contractors, and/or any third party, accompanying Respondents? representatives. 29. Respondents may make an initial buyout offer to Petitioners in writing, only, and Petitioners shall respond in writing. If a Petitioner declines the offer, Respondents shall not initiate any further conversation about a possible buyout for a period of 180 days. Petitioners may revisit the issue of buyouts by contacting Respondents at any time, in writing. in the event that any Petitioner noti?es Respondents in writing, by mailing written notice to Respondents by regular first class mail and certi?ed mail, that such Petitioner is not interested in discussing a possible buyout with Respondents, Respondents shall not approach that Petitioner to discuss a buyout unless and until such Petitioner rescinds its Buyout Notice. Within three (3) weeks of execution of this Stipulation, Respondents shall provide renewal leases in the names of Petitioners as set forth below. Respondents shall return fully executed leases to Petitioners (with email noti?cation) within 30 days of Respondents receipt of the signed renewal leases. Respondents shall issue rent stabilized renewal leases in the names of the following Petitioners: 0 Apartment 3: Suk Hay Mui (tenant of record) and, subject to Respondent?s review of documentation establishing that she has maintained Apartment 3 as her primary residence for the last two years, Cherry Mui (adult daughter of tenant). 30. Simultaneous with the execution of this Stipulation, in accordance with Multiple Dwelling Law Petitioners shall provide Respondents with a duplicate copy of the full set of key(s) to each and every unit covered by this Stipulation. In the event that Petitioners change the locks to their unit then they shall provide Respondents with a copy of the new key within forty?eight (48) hours. -14- 31. Respondents shall install one (1) wall-mounted ?re extinguisher on each floor of the Building during any period of signi?cant construction in the Building, until such construction is substantially complete. Extinguishers are to be Class ABC, UL tested, sized 10 lbs. or more, and must be in working order with proper unexpired tags. Respondents will maintain ?re extinguishers for the relevant period with inspections performed by a properly trained and quali?ed employee. 32. Respondents shall bleed heating pipes and drain the boiler of the Building once at the beginning of the heating season each year, or perform such other maintenance as is appropriate based on the speci?c mechanics of the boiler. 33. Respondents shall not remove gas stoves and/or heating pipes from Petitioners? apartments, or convert gas appliances to electric, without written consent from Petitioners, as well as, if applicable, permission from the New York State Division of Housing and Community Renewal . 34. Within ?fteen (15) calendar days of the Effective Date Respondents will arrange for its professionals to verify that the gas and electric meters servicing the common areas of the Building, as applicable, are not connected to any individual apartment meters, or, in the alternative, Respondents will contact Con Ed to request such an inspection. Respondents will reimburse (or arrange for utility companies to reimburse) Petitioners who have been overcharged for past utility services upon receipt of a written report from Con Ed substantiating any overcharges that are not Con Ed?s responsibility. Respondents will, subject to access by Petitioners and availability of third-party vendors, remedy any metering or other issues that have led to improper billing within thirty (30) days such discovery. -15- 35. Respondents shall annually register Petitioners? apartments with DHCR at correct Legal Regulated Rent (for Rent Stabilized tenants) or correct Maximum Base Rents/Maximum Collectible Rents (for Rent Controlled tenants), and shall provide Petitioners with copies of such registration. This provision shall survive expiration of the Sunset Date. 36. This paragraph shall only apply to Petitioners that have submitted forms to Respondent-Owner. Within ?ve (5) calendar days of the Effective Date Respondents shall request that the subject bank provide a statement to Petitioners with a full accounting of their security deposits, including bank information and accrued interest (a ?Statement?). It is understood that the subject bank should send out such Statement annually. In the event that a Petitioner does not receive said Statement then, within 10 days of requesting same from Respondents, Respondents shall request that the subject bank provide said Statement to Petitioner. 37. Petitioners who have not yet submitted a W-9 form to Respondent-Owner shall be eligible to request a Statement pursuant to the foregoing paragraph thirty days after said Petitioners submit a W-9 form to Respondent-Owner. 38. Respondents agree to translate written notices into Spanish and Chinese. This provision shall survive expiration of the Sunset Date. 39. Within ?ve (5) calendar days of the Effective Date, Respondents shall install and maintain a bulletin board (sized at least 24? by 18?) in a visible area in the ?rst ?oor lobby of the Building for use by tenants regarding subjects and notices pertinent to Tenants? Association business. Petitioners shall not post any items disparaging Respondents, their agents, employees or properties. Any such posting shall be immediately removed. in the event that Petitioners violate this provision four (4) times in any twelve (12) month period then Respondents may -16- 6019v] remove the bulletin board and refuse to install the same. Respondents shall provide Petitioners? counsel with any and all evidence of such postings (including any video footage or photographs of the alleged person(s) who posted said disparaging document) within two (2) business days of Respondent? discovery of such alleged posting. This provision shall survive expiration of the Sunset Date. 40. Respondents shall provide written invoices to Petitioners re?ecting all rent due as well as the most recent payments of rent. This provision shall survive expiration of the Sunset Date. 41. All prospective tenants, lenders, purchasers and mortgagees who enter the Building must be accompanied by a representative or agent of Respondents, which may include a real estate agent or broker. Petitioners shall not approach prospective tenants, lenders, purchasers and mortgagees or otherwise impede or impair the tour of the Building. Notwithstanding the foregoing, in the event that said prospective tenants, lenders, purchasers and mortgagees inquires of Petitioner then Petitioner may answer the question asked. 42. Respondents shall take commercially reasonable steps to ensure that the New York City Noise Code is strictly enforced for the commercial tenants of the Building. Speci?cally, the commercial establishments that play music must not exceed 42 decibels as measured from inside nearby residences and 7 decibels over the ambient sound level. in addition, base sound measurements may not exceed 6 above the ambient sound if the ambient sound is greater than 62 ADDITIONAL GENERAL PROVISIONS -17- 43. If either party fails to fully comply with this Stipulation in any way, including but not limited to engaging in Harassment, failure to meet repair and/or access deadlines, failure to provide Petitioners essential services or failure to acknowledge Petitioners? rent abatement, either party may restore their case to the calendar upon eight (8) days written notice for an order seeking contempt and all appropriate remedies. 44. In the event any individual Respondent is no longer an owner, as de?ned by the Housing Maintenance Code g. no longer employed by Respondent?Owner and/or SMA), then such individual will no longer have any liability hereunder. 45. All Parties shall bear their own attorneys? fees. 46. No modi?cation or waiver of the terms of this Stipulation shall be effected unless it shall be in writing and executed by the parties to be charged with the same formalities of this Stipulation. 47. This Stipulation may be executed by Facsimile and in counterpart. 48. The undersigned counsel represent that they are authorized to sign this Stipulation on behalf of their respective clients. 49. The parties agree to execute any other writings and/or documents reasonably necessary to effectuate the terms of this Stipulation. -18- WHEREFORE, the following signatures are af?xed hereto this day of February, 2016. URBAN JUSTICE CENTER Attorneys for Petitioners Garrett Wright Community Development Project 123 William Street, 16th Floor New York, New York 10038 (646) 459-3012 NEW YORK LAWYERS FOR THE PUBLIC INTEREST Attorneys for Petitioners By: Rachel Ser 151 West 30th Street, 1111] Floor New York, New York 10001 (212) 244-4664 DEPARTMENT OF HOUSING PRESERVATION AND DEVELOPMENT OF THE CITY OF NEW YORK Attorneys for Department of Housing Preservation and Development By: Housing Litigation iVision 100 Gold Street, Sixth Floor New York, New York 10038 (212) 863-8251 - - Wrens ROSENBERG ESTIS, P.C. Attorneysfor Respondents eborah Ri$gel 733 Third Avenue New York, New York 10017 (212) 867-6000 By: Angeli Thomas Ad inistrati Law Division 10 Church St eet, Room 5~140 New York, Ne York 10007 (212) 356.2174 -19- {0 102 Norfolk Street, New York, NY 10002 Construction Schedui 20 2: 27 2:8 (35 {36 02/05/16 page 1 of1 Exhibit - Abatement Schedule - 102 Norfolk Petitioner Apartment Rent amount Total abatement Jeff Caltabiano 9 $1704.23 8" $20,979.60 Brian Clark 13 1 $2122.89 $25,474.68 Steven 15ee 14 $682.96 $8,195.52 Shahed Miah 22 . $1329 $15,948.00 Cherry Mui 3 $491.65 $5,899.80 Suk Hay Mui 3 Same as above David Ng 23 $657.77 $7,893.24 ~96 mermt 042311} :?Lll'agq Loktch 75mm} Elms bffw?? 411 DWOMI 9 - . .41 099m 4M9 5W 0? (m we: $991, 429 40 saw-1. u; (400/ which} ?mv?j LUb?H?D'?mlr (1C4:sz ?w?v??audx?b 1109 61000443 (114%! 10 PM Oohswfe (33 13001120], 2019.