CIVIL COURT OF THE CITY OF NEW YORK COUNTY OF KINGS FIELDBRIDGE ASSOCIATES, LLC. Index No.: 074080/2013 Petitioner-Landlord, AFFIDAVIT IN SUPPORT -against- ROBIN TAYLOR BY HER MENTAL HYGIENE LAW ARTICLE 81 GUARDIAN THE JEWISH ASSOCIATION SERVING THE AGING Premises: Apartment 12N 1700 Bedford Avenue Brooklyn, New York 11225 Respondent-Tenant. STATE OF NEW YORK COUNTY OF NEW YORK 33.: PAUL ORTIZ, being duly sworn does hereby depose and says as follows: I. INTRODUCTION 1. I am the Program Director for the Jewish Association Serving the Aging and as such I am fully familiar with the facts and circumstances I set forth in this Af?davit In Support. I respectfully submit this Af?davit In Support of our application seeking an Order from this Court staying the execution of the within warrant of eviction until September 30, 2015 so that we can source a safe temporary home to which we may relocate our ward the Respondent?Tenant Robin Taylor. 2. I respectfully submit that based upon an assessment of the facts and circumstances upon which our application is based this Court will grant the same in its entirety. II. RELEVANT FACTUAL BACKGROUND 3. JASA was appointed the guardian of the Person and Property of Ms. Taylor pursuant to a certain Order and Judgment Appointing Special Guardian issued by the Honorable Leon Ruchelsman in the context of the Mental Hygiene Law Article 81 proceeding encaptioned In Re: Robin Taylor [Kings County, Supreme Court index no.: 100071/2015]. We quali?ed as Ms. Taylor?s guardian on or about May 12, 2015. copy of the Order/Judgment is annexed hereto as Exhibit 4. The within proceeding is a summary ?chronic litigancy? holdover proceeding pertaining to the apartment in which Ms. Taylor is residing, Apartment 12N at 1700 Bedford Avenue, Brooklyn, New York. I am advised that Ms. Taylor has been residing in this apartment for many years. 5. Upon my information and belief, which is based upon a review of the ?le documents that had been made available to my organization and discussions with some of the interested parties, a judgment and a warrant have already been entered and issued respectively in the context of this proceeding. 6. We have determined that Ms. Taylor must be relocated from her present apartment as it is not ?nancially feasible to source grant funds to pay the arrears. 7. Ms. Taylor, our ward, is approximately 60 years of age. She is frail resulting from a number of medical impairments that she suffers from. She is reliant upon a walker to ambulate. In addition she suffers from sleep apnea and uses a CPAP [continuous positive airway pressure] device in order to sleep. Accordingly Ms. Taylor is not able to safely reside, even temporarily, in a shelter. 8. We are in the process of trying to locate another apartment for Ms. Taylor both in Brooklyn and in other counties. Ms. Taylor?s present income is suf?cient to enable her to afford a private apartment. However we have been faced with certain road blocks when we contact renting agencies. Ms. Taylor?s credit history is not good. As a result a number of the rental agencies and private landlords we have contacted will not entertain an application for us on behalf of Ms. Taylor. In addition some of the apartments have not been suitable for someone who is reliant upon a walker. 9. In June when we last conferenced this case with the landlord?s attorney we agreed to pay an additional month?s rent and to relocate Ms. Taylor by July 31, 2015. As per our agreement we have paid the rent. 10. However for the reasons that I have stated we have been unable as of yet to source a safe and suitable apartment to Ms. Taylor; that is both affordable and accessible to someone who is reliant on a walker. 11. We have been advised by the marshal that Ms. Taylor is scheduled to be evicted on Wednesday August 12, 2015. 12. Accordingly we need to relocate Ms. Taylor temporarily until we can source a suitable permanent new apartment to which we may relocate Ms. Taylor. 13. We therefore need an extension upon the stay of Ms. Taylor?s eviction to, through and including September 30, 2015. We believe we will be able to source a temporary housing accommodation for Ms. Taylor by then where she can safely reside until we ?nd a suitable permanent new home for Ms. Taylor. 14. Based upon?the fact that Ms. Taylor cannot safely be reiocated to a sleiter we respectfully request that this Court grant this motion and extend the stay upon the execution of the warrant to September 30, 2015. We can pay an additional month?s rent for the extension that we are requesting. 15. Unless the stay relief we are requesting is granted Ms. Taylor will be rendered homeless and will have no housing option that does not present a threat to her health and safety. 16. Should a suitable housing accommodation become available before then we will relocate Ms. Taylor in advance of that date. CONCLUSION 17. Based upon all the foregoing we respectfully request that this Court issue an Order granting this motion in its entirety and providing for such other and further relief which as to this Court may seem just, proper and equitable. 18. No prior request for this relief has been made. PAUL Director Sworn to before me this 1 Wgust 2015 Normal/P761511) HRIS K. MITHANI Notary Public, State of New York . Wm. 1173i? a . MONT 06, 2017 MORRIS K. Notary Public, State of Now York 6 No. Qualified In New York County commission Expires October 06,201? I