SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK HATIXBE BAJRUSHI, INDIVIDUALLY, AND AS THE NATURAL PARENT OF INFANT GANI BAJRUSHI, Index No. 95/128881 Plaintiffs, VERIFIED -against- ANSWER AND AFFIRMATIVE 211w 3 THE TRUMP ORGANIZATION, INC., ,3 MATTHEW CALAMARI, JAMES GRAU, 9 1996} DOMINIC PEZZA AND MICHAEL NICOLE, ?Wigwam OFFICE WYORK Defendants. m: Defendants the Trump Corporation, Inc., doing business as The Trump Organization (incorrectly sued herein as The Trump Organization, Inc.), Matthew Calamari, James Grau, Domenic Pezzo (incorrectly sued herein as Dominic Pezza), and Michael Nicoll (incorrectly sued herein as Michael Nicole) (together, the "defendants") for their veri?ed answer to the veri?ed complaint of plaintiffs HatixBe Bajrushi ("HatixBe") and Gani Bajrushi respond as follows: 1. Deny knowledge and information suf?cient to form a belief as to the truth of each and every allegation set forth in paragraph one of plaintiffs? complaint. 2. Deny knowledge an! tn'ormation suf?cient to form a belief as to the truth of each and every allegation set forth in paragraph two of plaintiffs? complaint. 3. Admit that the Trump Corporation, Inc. is a corporation organized under state law. with a principal place of business at 725 Fifth Avenue, New York, New York and, except as so admitted, deny each and every allegation set forth in paragraph three of plaintiffs? complaint. 4. Admit the allegations in paragraph four of plaintiffs? complaint. 5. Admit that James Grau resides at 200 East 69th Street, New York, NY and that he is the brother-in-law of Donald Trump and, except as so admitted, deny each and every allegation set forth in paragraph ?ve of plaintiffs? complaint. 6. Admit the allegations in paragraph six of plaintiffs? complaint. 7. Admit the allegations in paragraph seven of plaintiffs? complaint. 8. Admit that from April 1991 through September 22, 1995, Daut Bajrushi ("Daut") was employed as superintendent at the Trump Palace and, except as so admitted, deny knowledge and information suf?cient to form a belief as to the truth of each and every allegation set forth in paragraph eight of plaintiffs? complaint. 9. Admit that the Trump Palace permitted Daut, in his capacity as superintendent, to use a basement of?ce and, except as so admitted, deny each and every allegation set forth in paragraph nine of plaintiffs? complaint. 10. Deny knowledge and information suf?cient to form a belief as to the truth of each and every allegation set forth in paragraph ten of plaintiffs? complaint. 11. Deny each and every allegation set forth in paragraph eleven of plaintiffs? complaint. 12. Deny each and every allegation set forth in paragraph twelve of plaintiffs? complaint. 13. Deny knowledge and information suf?cient to form a belief as to the truth of each and every allegation set forth in paragraph thirteen of plaintiffs? complaint. 14. Deny each and every allegation set forth in paragraph fourteen of plaintiffs? complaint. IN ?on Wm in? of ?Qx M~m?Nawathmem l\ 30? 1L a m?M?m? that of plaintiti?s' complaint. 25. Admit that HatixBe made a telephone call in which she spoke 3 foreign Wage and. except as so admitted, deny each and every allegation set forth in mragraph twenty-?ve of plaintiffs? complaint. 26. Admit that New York City Police Of?cers were present at the Trump Palace on September 22, 1995 and, except as so admitted, deny knowledge and information suf?cient to form a belief as to the truth of each and every allegation set forth in paragraph twenty-six of plaintiffs? complaint. 27. Admit that the police were present at the Trump Palace on September 22, 1995 and, except as so admitted, deny each and every allegation set forth in paragraph twenty-seven of plainti??s? complaint. 28. Deny each and every allegation set forth in paragraph twenty- eight of plaintiffs? complaint. WM 29. Defendants repeat and reallege each and every response set forth in paragraphs 1?28 of this answer as if fully set forth herein. 30. Deny each and every allegation set forth in paragraph thirty of plaintiffs? complaint. vny ?Ch and 6" 585665: set forth in paragraph twn- - four of plaintit?t?s? complaint. 25. Admit that HatixBe made a telephone call in which she spoke a ?are-ign language and, except as so admitted, deny each and every allegation set forth in paragraph twenty-?ve of plaintiffs? complaint. 26. Admit that New York City Police Of?cers were present at the Trump Palace on September 22, 1995 and, except as so admitted, deny knowledge and information suf?cient to form a belief as to the truth of each and every allegation set forth in paragraph twenty-six of plaintiffs? complaint. 27. Admit that the police were present at the Trump Palace on September 22, 1995 and, except as so admitted, deny each and every allegation set forth in paragraph twenty-seven of plaintiffs? complaint. 28. Deny each and every allegation set forth in paragraph twenty- eight of plaintiffs? complaint. AEFATI 29. Defendants repeat and reallege each and every response set forth in paragraphs 1-28 of this answer as if fully set forth herein. 30. Deny each and every allegation set forth in paragraph thirty of plaintiffs? complaint. 31. Deny each and every allegation set forth in paragraph thirty-one of plaintiffs? complaint. 32. Deny each and every allegation set forth in paragraph thirty-two of plaintiffs? complaint. 33. Deny each and every allegation set forth in paragraph thirty- three of plaintiffs? complaint. 34. Deny each and every allegation set forth in paragraph thirty-four of plaintiffs? complaint. 35. For purposes of this lawsuit, admit that Mr. Calamari, Mr. Pezzo, and Mr. Nicoll were acting within the course of their employment with the Trump Corporation, Inc., but speci?cally deny that they performed any acts alleged in the complaint, that they responsible for any wrongdoing, and that they or the Trump Corporation, Inc., have any liability and, except as so admitted, deny each and every allegation set forth in paragraph thirty-?ve of plaintiffs? complaint. 36. Deny each and every allegation set forth in paragraph thirty-six of plaintiffs? complaint. 37. Deny each and every allegation set forth in paragraph thirty- seven of plaintiffs? complaint. Exhibit A 1* Exhibit A 38. Deny each and every allegation set forth in paragraph thirty- eight of plaintiffs? complaint. TE SEQQND CAUSE QF AQTIQE 39. Defendants repeat and reallege each and every response set forth in paragraphs 1-38 of this answer as if fully set forth herein. 40. Deny each and every allegation set forth in paragraph forty of plaintiffs? complaint. 41. Deny each and every allegation set forth in paragraph forty-one of plaintiffs? complaint. 42. Deny each and every allegation set forth in paragraph forty-two of plaintiffs? complaint. 43. Deny each and every allegation set forth in paragraph forty- three of plaintiffs? complaint. 44. Deny each and every allegation set forth in paragraph forty-four of plaintiffs? complaint. THIRD A TI 45. Defendants repeat and reallege each and every response set forth in paragraphs 1-44 of this answer as if fully set forth herein. - 3ng?hk?w. . .. 'x Deny eac an every a ega ion se 0 1n paragraph forty 81 of plaintiffs complaint. 47. Deny each and every allegation set forth in paragraph forty- seven of plaintiffs? complaint. 48. Deny each and every allegation set forth in paragraph forty-eight of plaintiffs complaint. 49. Deny each and every allegation set forth in paragraph forty-nine of plaintiffs complaint. 50. Deny each and every allegation set forth in paragraph ?fty of plaintiffs? complaint. 51. Deny each and every allegation set forth in paragraph ?fty-one of plaintiffs complaint. 52. Deny each and every allegation set forth in paragraph ?fty-two of plaintiffs? complaint. ANS HERINQ THE FQUKLH CAUSE QF AQTIQE 53. Defendants repeat and reallege each and every response set forth in paragraphs 1-52 of this answer as if fully set forth herein. 54. Deny each and every allegation set forth in paragraph ?fty-four of plaintiffs? complaint. 53. Deny eacn and every a11egauu11 5U. 1U1u1 111 1 of plaintiffs? complaint. 56. Deny each and every allegation set forth in paragraph ?fty-six of plaintiffs? complaint. 57. Deny each and every allegation set forth in paragraph ?fty-seven of plaintiffs? complaint. 58. Deny each and every allegation set forth in paragraph ?fty-eight of plaintiffs? complaint. DEFE AFFIRMATIVE DEFE maxim 59. As the plaintiffs well knew at all relevant times, the Trump Corporation, Inc. acted as the authorized agent of the Trump Palace with regard to various matters including security. 60. As noted earlier, and as the plaintiffs also well knew, Messrs. Calamari, Pezzo, and Nicoll were at all relevant times employees of the Trump Corporation, Inc., and were acting on behalf of the Trump Palace. 61. Daut Bajrushi, alias Bob Bajrushi, who is alleged to be the husband of plaintiff HatixBe, alias Tina Bajrushi, and the father of plaintiff Gani, was employed as the superintendent at the Trump Palace, located at 200 East 69th Exhibit A Street in New York City, beginning in April 1991 and continuing through September 22, 1995. 62. As part of his employment, Daut was provided with the use of the superintendent?s of?ce located in the basement of the Trump Palace, and he and his family (plaintiffs) were provided with an apartment in the luxury building. 63. As an employee of the Trump Palace, Daut was at all times bound to exercise the utmost loyalty, honesty, and good faith in the performance of his duties. Thus, he is required to account to his employer for secret pro?ts and to forfeit his right to compensation for services rendered by him where, as occurred in the matter at bar, he proves disloyal, dishonest, and to have acted in bad faith. 64. As an employee he warranted and represented each time that he received compensation from his employer that he had committed no act of disloyalty, dishonesty, or bad faith, the disclosure of which would cause his termination. 65. Daut, aided and abetted by, and acting in concert and as a co- schemer with HatixBe, wrongfully engaged in acts of disloyalty, dishonesty, and bad faith, perpetrating a number of schemes to defraud the Trump Palace, resulting in the violation of the duties Daut owed to the Trump Palace. 10 Exhibit A 66. HatixBe, by reason of her having aided and abetted, acted in concert with, and been the co?schemer of Daut in his acts of disloyalty, dishonesty, and bad faith, and by her wrongful actions designed to prevent the discovery thereof through her attempts to remove, destroy, and otherwise tamper with evidence of Daut?s on?going misconduct, is a joint tortfeasor with him. II . . I 67. Upon information and belief, Daut, without the knowledge or consent of the Trump Palace, during the course of his employment, beginning on or about April 1991 and continuing until on or about September 1995, operated a contracting company called GDB Construction, which he utilized to carry out certain of his fraudulent activities. In his capacity as the superintendent of the Trump Palace, Daut came to learn of many tenants who sought to have work done in their private apartments. Daut not only secretly converted these opportunities to his own bene?t by referring these tenants to his own contracting company, but he also used other Trump Palace employees to perform such work for the tenants during the hours in which they were supposed to be working for the bene?t of the Trump Palace, and for which they were paid by the Trump Palace. 68. Thus, Daut not only misused his power as superintendent to convert business opportunities for himself, but he also essentially co-opted other 11 Exhibit A (W: .. Trump Palace employees to serve as a cost?free workforce for GDB. Such secretive conduct was a direct and willful breach of the duties of loyalty, honesty, and good faith which Daut owed to his employer, the Trump Palace. 69. Upon information and belief, the work done by GDB for the bene?t of Daut, and in violation of his ?duciary duties of loyalty, honesty, and good faith, included, but was not limited to, the following: a. On March 17, 1995, GDB contracted with Barron Property Management to perform services in apartment 16A, 200 East 69th Street. b. On July 24, 1995, GDB contracted with Doris Lee to perform services in apartment 6D, 200 East 69th Street. 0. On August 3, 1995, GDB contracted with REDAC to perform services in apartment 8K, 200 East 69th Street. d. These and similar wrongful, unauthorized acts at the expense of the Trump Palace were performed on at least eighty (80) occasions by GDB and Daut for Trump Palace residents. Additional examples of such wrongful acts are scheduled in Exhibit A hereto and incorporated herein by reference. 70. In addition to violating his ?duciary duties, Daut?s conduct was also in violation of the published Building Rules and Regulations: No private work of any kind is to be done for a Resident either during your work hours or after hours on your own time. This 12 rule has Wong. You are to perform the duties for which you were hired only. (Emphasis in original). False Time ?inching And Embezzlement of Paych?gs 71. Upon information and belief, beginning in or about April 1991 and continuing until on or about September 1995, Daut perpetrated a scheme in which the time cards of Trump Palace employees were punched at times when the employees were not at work. On many such occasions, the workers? pay checks for the time would then be cashed by Daut either directly or through a relative?s account. 72. Daut?s actions, which constitute embezzlement from the Trump Palace, were in violation of his ?duciary duties, as well as a breach of the published Building Rules and Regulations: No employee may punch a time card for another employee under any circumstances. Any employee in violation of this rule is subject to immediate dismissal. 73. Upon information and belief, beginning on or about April 1991 and continuing until on or about September 1995 Daut illegally installed an electronic device that enabled him to monitor and record telephone calls being placed by employees (but not by residents) inside the Trump Palace. 13 Exhibit A or COHSCHI. Inc parucnpanm, Wd5 In?. a. participant in the conversations. 75. Upon information and belief, on September 22, 1995, HatixBe attempted to remove tapes re?ecting intercepted conversations and recording equipment from the Trump Palace superintendent?s of?ce for the purpose of furthering Daut?s schemes by concealing such evidence of his misconduct. A 76. Upon information and belief, prior to the completion of the Trump Palace, Daut engaged in a scheme to steal a large number of microwave ovens that were to be installed in the newly constructed apartments. ixB?P ii 'nInh hm 77. Upon information and belief, HatixBe was aware of Daut?s misconduct and aided and abetted, and acted in concert and as a co-schemer with him in such misconduct. 78. Upon information and belief, HatixBe knowingly shared in the wrongfully obtained proceeds of Daut?s schemes, and, as is detailed below, furthered the schemes by preventing the discovery of evidence thereof through her acts of attempting to remove, destroy, and otherwise tamper with such evidence. 14 without the knowledge or consent of the participants, even though he was not a participant in the conversations. 75. Upon information and belief, on September 22, 1995, HatixBe attempted to remove tapes re?ecting intercepted conversations and recording equipment from the Trump Palace superintendent?s of?ce for the purpose of furthering Daut?s schemes by concealing such evidence of his misconduct. Augmm The?; Qf Microwave Qvens 76. Upon information and belief, prior to the completion of the Trump Palace, Daut engaged in a scheme to steal a large number of microwave ovens that were to be installed in the newly constructed apartments. i In Th 77. Upon information and belief, HatixBe was aware of Daut?s misconduct and aided and abetted, and acted in concert and as a co-schemer with him in such misconduct. 78. Upon information and belief, HatixBe knowingly shared in the wrongfully obtained proceeds of Daut?s schemes, and, as is detailed below, furthered the schemes by preventing the discovery of evidence thereof through her acts of attempting to remove, destroy, and otherwise tamper with such evidence. 14 . ?xi. .. ..: 79. On September 22, 1995, defendants became, aware of the fact that plaintiffs were in the superintendent?s of?ce of the Trump Palace attempting to remove, destroy, and otherwise tamper with documents and other materials incriminating Daut in his schemes. 80. In an effort to prevent plaintiffs from removing, destroying, or otherwise tampering with the evidence of Daut and HatixBe?s willful misconduct, defendants Calamari and Nicoll went to the Trump Palace superintendent?s of?ce where they encountered plaintiffs. 81. Defendants Calamari and icoll repeatedly told plaintiffs that they were free to leave and that they could take any personal property that they wished, but that they could not remove any Trump Palace property and could not remove, destroy, and otherwise tamper with documents and other materials incriminating Daut in his schemes. FI AFFI TI DEFE 82. The alleged incident and injuries and/or damages allegedly sustained by plaintiffs as set forth in plaintiffs? complaint were wholly or in part caused by plaintiffs? culpable conduct, in that plaintiffs were present at the Trump Palace on the date of the alleged incident for the purpose of furthering Daut?s 15 though their acts of prev schemes attempting to remove, destroy, and otherwise tamper with evidence of the on-going misconduct perpetrated by Daut. AFFIRMATIVE DEFEN 83. If plaintiffs sustained injuries and/or damages as alleged in the complaint, such damages were the result of plaintiffs? assumption of the risk in that their presence at the Trump Palace on the date of the alleged incident was for the purpose of furthering Daut?s schemes by preventing the discovery of evidence thereof, through their acts of attempting to remove, destroy, and otherwise tamper with evidence of the on-going misconduct perpetrated by Daut. THIRD AFFIRMATIVE DEFENSE 84. If plaintiffs have received remuneration and/or compensation for some or all of their claimed economic loss, or will with reasonable certainty receive remuneration and/or compensation for the alleged loss in the future, defendants are entitled to have any award granted to plaintiffs reduced by the amount of remuneration and/or compensation pursuant to CPLR 4545 TH AFFIRMATIVE DEFEN 85. The provisions of CPLR 1601 et. seq. are applicable to this lawsuit. 16 WHEREFORE, the defendants demand: A. judgment dismissing with prejudice phin??s? complaint against the defendants; B. PIOPCL Dated: New York, New York JAY GOLDBERG, P.C. February 5, 1996 Attorneys for Defendants The Trump Corporation, Inc., Matthew Calamari, Domenic Pam, and Michael Nicol] and MICHAEL G. BERGER Attorney for Defendant James Gran 250ParkAvmue Floor New York, NY 10177 17 [11? negligence and/or contributory neglige was the sole and. or proximate cause of the alleged damages. SLXIHWSE l?here is no personal jurisdiction over defend inwroper sen ice of process. WHEREFORE. the defendants demand: A. judgment dismissing with prejudice plaintiffs? complaint against the defendants; B. defendants? costs and disbursements in this action; and C. such other and further relief as the Court may deem just and proper. Del/2d: New York, New York February 5, 1996 Tabla) rub? Jdib we? 17 Latmu' j? JAY GOLDBERG, P.C. Attorneys for Defendants The Trump Corporation, 1110., Matthew Calamari, Domenic Pezzo, and Michael Nice? and MICHAEL G. BERGER Attorney for Defendant James Grau 250 Park Avenue Fourteenth Floor New York, NY ??77 (212) 983 0000 j? . --. . TIXBE BAJRUSHI. IN AS THE NATURAL PARENT OF INFANT GANI BAJRUSHI. Index No. 95/ 128881 Plaintiffs. VERIFICATION -against- THE TRUMP ORGANIZATION, INC., MATTHEW CALAMARI, JAMES GRAU, DOMINIC PEZZA AND MICHAEL NICOLE 9 Defendants. STATE OF NEW YORK COUNTY OF NEW YORK MICHAEL NICOLL, being duly sworn deposes and says: I am a defendant in the within action. I verify this pleading on behalf of all defendants pursuant to CPLR 3020 insofar as they are united in interest. I have read the foregoing veri?ed answer and af?rmative defenses, and the same is true, except for those matters alleged upon information and belief, and as to those matters, I believe them to be true. - .. . Nukli MICHAEL NICOLL Sworn to before me this 5 day off ruary, 1996. Notary Public Cr. ?an, Exhibit A INV 1466 1467 1468 1470 1472 1473 1474 1475 1476 1477 1478 1479 1480 1481 1482 1483 1484 1485 1486 1487 1488 1489 1490 1491 1492 1493 DATE 2/12/93 2/25/93 2/18/93 2/25/93 3/11/93 3/31/93 4/2/93 4/12/93 6/3/93 6/2/93 6/18/93 6/21/93 6/21/93 7/15/93 7/16/93 7/18/93 7/26/93 8/11/93 8/12/93 8/16/93 10/1/93 9/24/93 11/3/93 11/8/93 11/8/93 11/10/93 COMPANY REDAC INC. REDAC INC. REDAC INC. REDAC INC. REDAC INC. REDAC INC. REDAC INC. THE CORCORAN GROUP THE CORCORAN GROUP REDAC INC. DCH MANAGEMENT INC. OCH MANAGEMENT INC. THE CORCORAN GROUP REDAC INC. BENJAMIN BORDEN ESQ. REDAC INC. REDAC INC. REDAC INC. REDAC INC. REDAC INC. DCH MANAGEMENT INC. REDAC INC. MRS. LEE REDAC INC. REDAC INC. APT. T.H. 5G 17B T.P.12C ADDRESS 205 E. 68TH STREET 200 E. 69TH STREET 205 E. 68TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 333 E. 38TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 205 E. 68TH STREET 205 E. 68TH STREET 205 E. 68TH STREET 205 E. 68TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 205 E. 68TH STREET 205 E. 68TH STREET 205 E. 68TH STREET 205 E. 68TH STREET 205 E. 68TH STREET 200 E. 69TH STREET 205 E. 68TH STREET 200 E. 69TH STREET 200 E. 69TH STREET AMOUNT 200.00 649.50 216.50 CHECK 649.50 1,732.00 1,840.25 487.00 757.75 1,190.75 1,732.00 1,136.52 1,028.37 541.25 1,840.25 1,840.25 129.90 270.62 1,082.50 1,299.00 1,299.00 920.25 1,840.25 1,900.00 1,299.00 757.75 3,100.00 29,740.16 BANK STUB AMT DEPOSIT 3/1/93 649.50 3/16/93 8 218.50 3,16,93 1,732.00 25/29/93 1,840.25 487.00 5/17/93 7/23/93 1,732.00 6/21/93 . 7/21/93 3 1,840.25 8/2/93 5 1,840.25. 7/19/93 129.90 8/12/93 3 270.62 8/12/93 3 1,082.50 9/3/93 3 1,299.00 9/3/93 5 1,299.00 9/3/93 5 944.14 1 1/2/93 3 1,840.25 10/18/93 8 1,299.00 11/29/93 5 757.75 11/29/93 INV 1494 1495 1496 1497 1498 1499 1500 1501 1502 1503 1504 1505 1506 1507 1508 1509 1510 1511 1512 1513 1514 1515 1516 1517 1518 1519 1520 1521 1522 1523 1524 1525 1523 153 1531 DATE 1/ 2/ 94 1/5/94 1/17/94 3? 3194 324/94 325/94 4/7/94 51/10/94 5?10/94 5?10?94 5/4/94 5110/94 525/94 5.20/94 615/94 7/1/94 7/2/94 55/15/94 7/7/94 8125/94 8/25/94 8730/94 911 4794 91' 1 4/94 9728/94 5313/94 1 0/28/94 1 1/17/94 1 1/14/94 12/2/94 12/29/94 12/29/94 12/27/94 COMPANY REDAC INC. REDAC INC. REDAC INC. REDAC INC. REDAC INC. THE CORCORAN GROUP GLEN SANDS SELINA MO DAVID YANG DAVID YANG REDAC INC. MR. 8 MRS. BRADLEY ETBC HOLDING INC. CHARLES STRANDBURG MALCOLM ANDERSON SELINA MO REDAC INC. REDAC INC. REDAC INC. DORIS LEE REDAC INC. REDAC INC. REDAC INC. REDAC INC. REDAC INC. REDAC INC. MRS. CONSEPCION REDAC INC. IZUMI INTERNATIONAL FURUMOTO REALTY DORIS LEE WILLIAM LEE REDAC INC. REDAC INC. DORIS LEE APTADDRESS 205 E. 68TH STREET 205 E. 68TH STREET 205 E. 68TH STREET 205 E. 68TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 188 E. 70TH STREET 205 E. 68TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 205 E. 68TH STREET 205 E. 68TH STREET 200 E. 69TH STREET 205 E. 68TH STREET 205 E. 68TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 205 E. 68TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 200 E. 69TH STREET 205 E. 68TH STREET 205 E. 68TH STREET 200 E. 69TH STREET AMOUNT 3 1,948.50 9 433.00 1,299.00 8 2,110.08 1,732.00 1,356.37 3 3,680.50 3 1,515.50 5 378.87 8 1,796.12 811.87 3 250.00 3 81.18 270.62 5 140.72 3 216.50 3 1,575.03 270.62 5 2,401.50 3 189.43 974.25 5 1,623.75 3 1,299.00 5 270.62 3 2,814.50 2,500.00 8 1,299.00 4,871.25 591.00 5 2,381.50 5 384.28 3 1,299.00 5 162.37 5 866.00 45,525.93 STUB AMT 5 1.94850 433.00 2,110.08 1,732.00 8 811.87 5 216.50 8 1,575.03 270.62 5 1,732.00 5 974.25 3 1,299.00 270.62 3 2,814.50 5 1,299.00 1,299.00 162.37 CHECK . DEPOSIT ?31/84 217/94 33/28/94 4/18194 5/25/94 6127/94 7/1/94 7/18/94 7/18/94 7/18/94 8/1/94 9/12/94 9/28/94 9/28/94 10/7/94 10/17/94 11/11/94 12/19/94 12/9/94 3/7/95 1/25/95 1/25/95 1/18/95 WV 14 DA 1 1: COMPANY APT. 9 ADDRESS AMOUNT DEP i 0811 1532 1/10/95 MRS. J. CARRINGTON 198 200 E. 69TH STREET 9 2,381.50 3 1533 2/15/95 REDAC INC. 158 200 E. 69TH STREET 9 1,948.50 9 1,948.50 3?30?95 1534 3/17/95 REDAC INC. . 50 200 E. 69TH STREET 9 1,451.37 9 1,451.37 8?3/95 1535 3/17/95 BARRON PROPERTY MGMT. 16A 200 E. 69TH STREET 9 1,948.50 I95 1535 3/27/95 REDAC INC. 118 200 E. 69TH STREET 9 3,139.25 9 3,139.25 4,18] 1537 3/27/95 REDAC INC. 50 205 E. 58TH STREET 9 1,559.52 9 1,559.52 4,18/25 1538 3/25/95 REDAC INC. 58 205 E. 68TH STREET 9 1,407.25 9 1,407.25 5 1539 4/3/95 REDAC INC. 5E 205 E. 68TH STREET 9 1,948.50 9 1,948.50 1540 4/2/95 DORIS LEE 7E 200 E. 69TH STREET 9 1,299.00 4,18% 1541 4/4/95 DORIS LEE 5E 200 E. 69TH STREET 9 1,299.00 4,20,95 1542 4/18/95 DORIS LEE 7D 200 E. 69TH STREET 9 1,407.25 53/4/95 1543 4/20/95 REDAC INC. 150 200 E. 69TH STREET 9 129.90 9 129.90 502,95 1544 4/24/95 REDAC INC. 118 200 E. 59TH STREET 9 152.37 5/22/95 1545 4/25/95 REDAC INC. 5E 205 E. 68TH STREET 9 97.42 9 97.42 5/22/95 1545 4/27/95 REDAC INC. 4H 205 E. 68TH STREET 9 1,948.50 9 1,948.50 5/22/95 1547 5/3/95 DORIS LEE 71: 200 E. 69TH STREET 9 1,299.00 5/15/95 1548 5/9/95 DORIS LEE 8C 200 E. 69TH STREET 9 1,353.12 5/15/95 1549 5/7/95 REDAC INC. 30 205 E. 68TH STREET 9 920.12 9 920.12 5/22/95 1550 7/24/95 DORIS LEE 6D 200 E. 69TH STREET 1,299.00 8/7/95 1551 8/5/95 REDAC INC. SD 200 E. 69TH STREET 216.50 1552 8/3/95 REDAC INC. 8K 200 E. 69TH STREET 162.37 162.37 1553 8/23/95 REDAC INC. 50 205 E. 68TH STREET 9 573.72 1554 9/1/95 REOAO INC. 3A 205 E. 68TH STREET 9 1,807.77 9 1,807.77 1555 9/7/95 REDAC INC. 4E 455 E. 86TH STREET 1,948.50 1555 9/13/95 REDAC INC. 188 235 E. 47TH STREET 9 2,381.50 9 2,381.50 1557 9/14/95 REDAC INC. 280 330 E. 88TH STREET 9 1,732.00 9 1,732.00 1558 9/13/95 REDAC INC. 188 F. 70TH STREET 9 292.27 9 292.27 1559 9/14/95 REDAC INC. 3004 188 E. 64TH STREET 9 152.37 9 152.37 36,296.17