page  of  pages
Report on Elizabeth P Dominguez’ criminal
Extrinsic Fraud upon the Court
July 8 2018 1723 GMT

Started June 20 2018

Elizabeth P Dominguez
[
aka Elizabeth H Gutierrez]
c/o Nestor D Dominguez
KMN Capital Management LLC
17 Bergen Street PH
Brooklyn NY 11201

Chart of Elizabeth P Dominguez paragraphs containing perjury

Dominguez ¶ 4  Dominguez ¶ 5  Dominguez ¶ 6  Dominguez ¶ 7  Dominguez ¶ 8  Dominguez ¶ 9  Dominguez ¶ 10  Dominguez ¶ 11


Chart of Exhibits

Exhibit “_”:  Elizabeth P Dominguez June 23 1993 Affidavit in Opposition

Exhibit “_”:  May 24 1989 letter Koenig to Gottsegen

Exhibit “_”:  Beckert and deSesa application to sublease.

Exhibit “_”:  Koenig family cooperative apartment insurance contract

Exhibit “_”:  Koenig family umbrella contract

Exhibit:  Abraham Joselow PE’s January 15 1988 letter in its entirety



Let’s breakdown Elizabeth P Dominguez’ June 23 1994 affidavit [annexed in its entirety at Exhibit “_”], statement by statement, as she wrote it - taken from her original verified ur-document as on file today with the New York County Clerk and scanned on June 29 2018:

Elizabeth P Dominguez outrageous statement above is Libel by Extrinsic Fact.  Her hardship, which is self-inflicted, must be established by testimony.  The Koenig family never forced anybody to endure anything; and such forcing must be established by testimony.  There was no refusal to meet financial obligations by the Koenig family to their coop:  instead, there was a carefully reasoned, explained. but never excused withholding of rent and assessments because the Koenig family simply could not pay them.  And Robert J Koenig’s Federal Bankruptcy was the actual outcome of Elizabeth P Dominguez’ studied criminal extrinsic fraud upon the court.

Elizabeth P Dominguez’ hardship was settled on her by Robert J Phillips certainly contumacious and likely criminal refusal to install this $75 Series 100 Stainless Steel Flexonic Hose in January 12 1987 - before the Koenig family had even moved in [1]  :

 

on the steam riser runout in the

in Southwest corner of # 17C:

Elizabeth P Dominguez and her entire Board of Directors:

55 Liberty Owners Corp  [2], Kenneth E Madsen [3] , John R Williams  [4],Andrew A Prieto [5],  Joseph Pell Lombardi (as Board Member)  [6],  Don Lebowitz Esq  [7],  Elizabeth P Dominguez  [8]

and her lawyers

Michael Seth Feuer Esq (disbarred for Federal wire fraud)   [9], Robert J Zastrow Esq [10],  Henry Lee Saurborn Esq [11],  Phyllis H Weisberg Esq  [12],  Fred L Seeman Esq  [13],  Daniel Ward White Esq  [14], Carol A Pisano Esq  [15], Alan M Goldberg Esq  [16] , Aaron "Ron" Goldstein Esq [17],  Jonathan Jay Fink Esq [18],  James Gaither Samson Esq [19]

and her managing agents:

Robert J Phillips  [20], Paul R Gottsegen  [21],  Daniel P Kessler  [22]  and Richard "Jack" A Oelberger [23] , Walsh [RIP],  Stephen A Rossi [24],  Joseph Cusenza  [25],  Donald E Wilson  [26],  Steven Olin-Dabrowski [27]

all knew, with absolute precision and certainty, that the Koenig family is fully insured.

Nowhere in Elizabeth P Dominguez’ affidavit is there any mention of the fact that the Koenig family has only asked the court for a directed verdict/declaratory judgement to parse responsibility for the costs.  The simple question of the allocation of the responsibility to repair is based on indisputable extrinsic facts requiring no trial; all that is required from The Honorable Carol E Huff is a reading of the proprietary lease followed quickly by Judge Huff’s order.

A quick reading of the Koenig family’s Proprietary Lease:

sets the stage for Carol E Huff’s only possible directed verdict/declaratory judgement: which is that at all times the Koenig family is 100% responsible to perform and pay for the entire restoration.

Elizabeth P Dominguez and all her lawyers (supra.) and all her managing agents (supra.) know absolutely that the Koenig family is 100% responsible to pay all the costs (down to the last farthing) for the restoration of # 17C.

Elizabeth P Dominguez perjures herself in these two sentences.

The damages to the Koenig family home that were generated by a documented series of steam riser runout explosions over the years 1987 - 1999 can only be quantified by competent experts.

I speak here only of the total damages - prior to any  2nd/3rd party allocation which necessarily follows where damaged property is owned by more than one party.

This allocation, the parsing of financial responsibility, must be also be done by competent experts:  and these experts are called licensed insurance adjusters.

Upon information and belief, Elizabeth P Dominguez and her lawyers (supra.), her managing agents (supra.), and her multi-peril insurance carrier  (Greater Mutual Multi-Peril Coop Policy # 1131M75921-S [28])  performed a secret 2nd/3rd party adjustment of the extensive damage at #17C.

Upon information and belief, Ms Dominguez’ E&O Carrier, the Chubb Insurance Company, also performed a secret 2nd/3rd adjustment.

Those two 2nd/3rd adjustments performed by 55 Liberty’s own insurers showed (upon information and belief) that Greater New York Mutual Insurance Company and the Chubb Company conclude that the Koenig family is 100% responsible.  Upon information and belief, the Greater New York Mutual Insurance Company and the Chubb Company’s adjuster reports also discuss the effects of an inevitable subrogated claim by USAA against a number of parties.

In fact, the only fact that seems to interest my carrier, United Services Automobile Association [USAA]  [29], was whether I have waived a right of subrogation against the coop and its board: which I have not.

So what about  United Services Automobile Association  [USAA] ?

United Services Automobile Association’s  2nd adjuster Grace L Ward [30] also did complete a secret and undated 1st party adjustment :

Upon information and belief, Grace L Ward’s secret undated USAA adjuster’s report was supplied to:

I also know exactly who in did fact read Grace L Ward’s secret undated adjuster’s report.

Grace L Ward’s secret undated adjuster’s report was given to The Honorable Diane Alexis Lebedeff  [34] who mistakenly gave it to me when she returned exhibits at the end of a trial.  Upon information and belief, Robert M Spadaro gave USAA’s Grace L Ward’s secret undated adjusters report to The Honorable Diane Alexis Lebedeff in one of his several ex parte meetings with Lebedeff that he conducted right in front of me and the court reporters [yes - fucking unbelievable].

The only person who has never been objectively supplied with Grace L Ward’s secret undated USAA adjustment report was me.


So as we can see - Elizabeth P Dominguez lied as to the measure of the damages.  Even USAA’s opening gambit was $13,810.


Now we move on to ¶ 4:

This statement (highlighted- above) is extrinsic fraud and grounds for thus immediate judgement in plaintiff Koenig’s favor.

The judgement that Koenig seeks is a parsing by allocation of all costs to restore # 17C from landlord’s negligent steampipe explosion 100% to the Koenig family:  as ¶ 2, ¶ 4, and ¶ 17 of the proprietary lease read along with 55 Liberty’s proprietary in-house and secret corporate records show that the Koenig family owns all the fixtures and installations.


Now we move on to ¶ 5 of Elizabeth P Dominguez’s serial extrinsic fraud upon the court.

 

Elizabeth P Dominguez’ percipient observation and personal conclusion that an apartment with serially exploding asbestos-covered steam riser run-outs can be safely lived in may be good enough for her.

Elizabeth P Dominguez’ own family’s history of serious childhood disease tips us off that perhaps she should pay more attention to her own children’s environment.  Elizabeth P Dominguez’ opens the door to my own percipient observation in that regard [her family].



Now we move on to an instance of flat-out perjury, also in Elizabeth P Dominguez’ ¶ 5.

A detailed understanding of the 55 Liberty events starting in the winter 1988/1989 heating season thru November 1989 is best had by reading this:

http://compartmentalizedfraud.com/fraud_55_liberty_early/douglas_elliman_paul_r_gottsegen/index.html 

Elizabeth P Dominguez knows from the corporate records of 55 Liberty Owners Corp, as supplied to her by Douglas Elliman - Gibbons & Ives et seq. , that Douglas Elliman - Gibbons & Ives arranged for its contract carpenter, Mark Brannon, to remove the finished floor and subfloor - starting on his July 28 1989 visit.

Elizabeth P Dominguez knows exactly who cut two holes, first in the finished floor and then the sub-floor on that day:  Mark Bannon - 55 Liberty’s Carpenter.

USAA’s unlicensed adjuster, Richard J Froese, took this August 3 1989 photo when he came to insect the under-floor water damage that had been exposed when Douglas Elliman - Gibbons & Ives contract carpenter Mark Brannon came on July 28 1989:

I wonder what Elizabeth P Dominguez thinks is in the black plastic bag?

And the July 28 1989 floor cuts which exposed ponding water spawned these letters to Elizabeth P Dominguez’ managing agent:

May 24 1989 letter Koenig to Gottsegen



Mr Gottsegen never got back to me.


Now ¶ 6:

Elizabeth P Dominguez seeks to turn a direct approach by two renters into my perjury and bad-faith.

Koenig directed Michael Beckert, a seasoned lawyer, and Stephanie deSesa [RIP], a seasoned business person, to Elizabeth P Dominguez’  managing agent Joseph B Cusenza  [35],  to apply as tenants to occupy # 17C for the account of 55 Liberty Owners Corp.  Beckert and deSesa were childless and planned to remain so.  I fully explained the asbestos danger to Beckert and deSesa.

Clearly prospective tenants Beckert and deSesa saw an opportunity to establish occupancy and buy-out the Koenig family apartment for cheap.  And the pro-temp arrangement with Managing Agent Cusenza was that 55 Liberty Owners Corp could keep the entire rental making a substantial profit.

55 Liberty Owners Corp could then repair the damage, make a profit, and then we could go our separate ways.

55 Liberty Owners Corp Managing Agent, Joseph Cusenza, fraudulently encouraged Beckert and deSesa to apply to be subtenants by sending them an application and then stole, for his account, their $150 deposit:


Vincent Cusenza


¶ 7:  Elizabeth P Dominguez then indulges herself in categorical extrinsic fraud.


¶ 8: Elizabeth P Dominguez then again indulges herself in categorical extrinsic fraud by asserting that Robert J Koenig’s constructive eviction letter:

was a litigation tactic.

Her paragraph # makes no sense.

Even though Elizabeth P Dominguez never once engaged with me: it is quite clear that Elizabeth P Dominguez understood that the Koenig family was not going to move back in until (1) the required flexible steam fitting was installed and (2) the asbestos abated.

Elizabeth P Dominguez also knew that repairs to the building’s common steam pipe system was way beyond the ambit of a tenant’s repair capabilities.

And asbestos abatement is a project that may be undertaken by neither tenant nor landlord.  Only a licensed asbestos contractor can abate the asbestos in # 17C.

If the likelihood of future steam pipe explosions and the release of asbestos, both easily cured, do not run with the warranty of habitability: then what does?


Elizabeth P Dominguez’ ¶ 9

In her secret ex parte prove-up hearing before The Honorable Carol E Huff, Elizabeth P Dominguez conveniently forgot that she is at all times fully informed that at 55 Liberty Street there is a repeated cracking of steam riser runouts.  And then Ms Dominguez commits criminal perjury

Elizabeth P Dominguez must live in a parallel universe where there are no leaks.  The presence of constantly breaking steam pipes is testified to by Elizabeth P Dominguez’ own expert contract professional engineer, Abraham Joselow PE  [36], who on January 15 1988 wrote as follows :

Professional Engineer Joselow’s January 15 1988 letter is annexed in its entirety. as Exhibit “_”.

As for my failure to allege steam riser runout explosions at 55 Liberty Street after the January 1987 and the November 1989 explosions - I was not there.

But I know here were ongoing explosions and secret repairs.  It may be that 55 Liberty superintendent Robert J Phillips was hiding these events from Elizabeth P Dominguez.

But on the very first time that I visited # 17C, which was on January 21 1995 in advance of the February 2 1995 mediation session before Judge Milton Mollen [RIP], I discovered that 55 Liberty superintendent Robert J Phillips was actively engaged in yet another repair to another exploded steam riser runout in the Northwest corner of the living room.


¶ 10


Elizabeth P Dominguez’ ¶ 11 :  It pays to remember -  the Koenig family was absolutely 100 % responsible to restore and to bear 100% of the costs to restore # 17C from the steampipe explosions that were going on all around them.   So if the Koenig family was responsible to pay for the repairs, what Koenig perjury, exactly, did Elizabeth P Dominguez find?

Elizabeth P Dominguez’ fanciful ideas of Koenig perjury, submitted ex parte in some sort of prove-up hearing before Judge Huff, show her obsessive concern with where I was living after I lodged this December 5 1989 notice of constructive eviction:

Now here is the truly exquisite question.  As Elizabeth P Dominguez and all her fellow Board Members and Lawyers and Management Executives all knew that the Koenig family was 100% insured for the exact eventuality that had occured.  Here is a summary of the Koenig family limits of liability:

And the terms of the insurance contract are annexed as Exhibit “_” and the Koenig umbrella policy annexed as Exhibit “_”.

Elizabeth P Dominguez and all her fellow Board Members and Lawyers and Management Executives all knew the Koenig family capacity to supply their insurer with a proof of loss resided in the proprietary stock transfer records and construction application records of  55 Liberty Owners Corp.

These stock transfer records and the records of construction applications for # 17C were deliberately withheld from the Koenig family.

And this was the story that the hidden records held.

In 1980, Stephen Edward Globus, an original promoter of 55 Liberty Tower,  took back shares in # 17C in lieu of a sponsor’s cash profit becoming a sponsor ur-shareholder.  If Globus had installed the fixtures that the Koenig family was living in, there was an argument that the cooperative corporation would have owned the damaged fixtures.

But apStephen Edward Globus installed nothing.

In 1984, Stephen Edward Globus sold # 17C to Randy Zeiger and Zeiger onsold to Lombardi.

And then Lombardi performed this comprehensive rehab to #17C under this March 1985 sales contract to Burt Sanoff:

 

This contract establishes that a prior tenant installed the interior of # 17C.

And then Sanoff “jumped out window” falling 17 stories to his death in the alley along the West Wall of 55 Liberty Street.

I believe that 55 Liberty’s superintendent, Robert J Phillips [RIP], may have had something to do with Burt Sanoff’s death.  Building handyman Mr Pelikan certainly thought so.


Extrinsic Fraud

Libel by Extrinsic Fact

Dominguez proceeded as a gratuitous Percipient Witness

narrative:

That Elizabeth P Dominguez committed extrinsic fraud upon The Honorable Carol E Huff’s court, and by extension on The Honorable Martin Schoenfeld’s court and The Honorable Diane Alexis Lebedeff’s court is sufficient cause alone to render the entire proceedings and the final orders a nullity.

Even more important than what Elizabeth P Dominguez said in her fraudulent statements is what she didn’t say.

Let’s review what Dominguez knew.

Criminal Elizabeth P Dominguez had complete scienter of all the pertinent facts of the matter.

The one single principal overriding and over-arching fact was that the Koenig family had an absolute duty to perform all repairs from any damage whatsoever to #17C.

Elizabeth P Dominguez knew that.

And Elizabeth P Dominguez knew that the Koenig’s didn’t know that.

And Elizabeth P Dominguez’ attorneys:

Robert J Zastrow Esq [37],  Henry Lee Saurborn Esq [38],  Phyllis H Weisberg Esq  [39],  Fred L Seeman Esq  [40],  Daniel Ward White Esq  [41], Carol A Pisano Esq  [42], Alan M Goldberg Esq  [43] , Aaron "Ron" Goldstein Esq [44],  Jonathan Jay Fink Esq [45],  James Gaither Samson Esq [46]

knew that Koenig family had an absolute duty to perform all repairs from any damage whatsoever to #17C.

And Elizabeth P Dominguez’ attorneys knew that the Koenig’s didn’t know that.

And the entire managing agent apparatchik and the entire Board of Directors at 55 Liberty:

55 Liberty Owners Corp  [47], Kenneth E Madsen [48] , John R Williams  [49]Andrew A Prieto [50],  Joseph Pell Lombardi (as Board Member)  [51], Elizabeth P Dominguez  [52]

knew that Koenig family had an absolute duty to perform all repairs from any damage whatsoever to #17C.

And Elizabeth P Dominguez’ Board of Directors  and her Managing Agent knew that the Koenig’s didn’t know that.

And here is where it gets really really good.

Elizabeth P Dominguez’ Board of Directors  and her Managing Agent knew that the Koenig’s had in place the canonically correct insurance contract via United Services Automobile Association [USAA]  [53] which completely indemnified the Koenig’s as to the entire $25,000 cost to repair the damage from the exploded steam pipe.

And Elizabeth P Dominguez’ Board of Directors  and her Managing Agent knew that the Koenig’s had in place the canonically correct insurance contract via United Services Automobile Association [USAA]  [54] which supplied 40 months of loss-of-use:  if indeed that was how long it would take to repair the damage.

Elizabeth P Dominguez and her lawyers and her managing agent all knew that the source (we are talking about water, after all) was a serially fracturing steam riser runout that exploded every two years right on schedule.

Elizabeth P Dominguez and her lawyers and her managing agent all knew that the three exploding steam pipes behind the walls  of # 17C could be fixed with this $45 part ( 3 x $45 = $135):

Elizabeth P Dominguez and her lawyers and her managing agent, with criminal intent, withhold the $135 fix as installing this repair would admit to the origins of the explosion.

And Elizabeth P Dominguez and her lawyers and her managing agent all knew that the steam pipes behind the walls of 55 Liberty Street are covered with asbestos.

And Elizabeth P Dominguez and her lawyers and her managing agent all knew that each time the walls were invaded to repair the steam pipes that asbestos would be released.

And Elizabeth P Dominguez and her lawyers and her managing agent all knew that the asbestos covering # 17c’s  three steampipe risers could be conclusively remediated for about $100 each (3 x $100 = $300).

And Elizabeth P Dominguez and her lawyers and her managing agent all knew that while the Koenig family was eager to restore and reoccupy # 17C:  that there was going to be no restoration and re occupancy until the asbestos was abated ($300) and the stainless flexible fittings installed (135).

I explained to Elizabeth P Dominguez and her lawyers and her managing agent that the Koenig family would be happy to pay for the asbestos remediation and the permanent flexible fitting fix.


So this leaves the reader (principally the horrible nasty disgusting Jüdischer Ordnungsdienst The Honorable Martin Schoenfeld) wondering this.

If the Koenig’s were ready, willing,and financially capable (via insurance) of restoring and reoccupying (and removing the asbestos and installing the flexible fitting):

WHY WAS ELIZABETH P DOMINGUEZ’ AFFIDAVIT TOTALLY SILENT ON THE MATTER OF AN ACCELERATED REPAIR AND RE OCCUPANCY.  POST HASTE.

Here’s why.

 

 

 


Exhibit “_”:  Elizabeth P Dominguez June 23 1993 Affidavit in Opposition


Exhibit “_”:  May 24 1989 letter Koenig to Gottsegen


Exhibit “_”:  Beckert and deSesa application to sublease.


Exhibit “_”:  Koenig family cooperative apartment insurance contract


And



Exhibit “_”:  Koenig family umbrella contract

Exhibit:  Abraham Joselow PE’s January 15 1988 letter in its entirety.



 


<iframe src="https://docs.google.com/document/d/e/2PACX-1vTj-EbK9HN1Vxg0WJhQL-40zjIkpBdVwnGA1eraDQfYC6J2APvZZlWcbSZthkvHLaQmyKOn6UCShdVo/pub?embedded=true"></iframe>

https://docs.google.com/document/d/1V7sGD-JB_GqC4qnQonJoQeo3yd_P7Y3LrXm3Rz9BQTo/edit

http://compartmentalizedfraud.com/fraud_55_liberty_intermediate/55_liberty_board_president_elizabeth_p_dominguez/index.html 

http://compartmentalizedfraud.com/fraud_usaa_intermediate/usaa_lawyer_joseph_b_kuroly/usaa_lawyer_joseph_kuroly_load_original_w_ip_address.php 


Time in GMT


Exhibit “_”:  visit to 17 Bergen Street Brooklyn on Sunday July 1 2018 1657 EDT.


Appendix  “_”:  July 3 2018 email to Chubb’s Aaron Goldstein



<iframe src="https://docs.google.com/document/d/e/2PACX-1vTj-EbK9HN1Vxg0WJhQL-40zjIkpBdVwnGA1eraDQfYC6J2APvZZlWcbSZthkvHLaQmyKOn6UCShdVo/pub?embedded=true"></iframe>

https://docs.google.com/document/d/1V7sGD-JB_GqC4qnQonJoQeo3yd_P7Y3LrXm3Rz9BQTo/edit


http://compartmentalizedfraud.com/fraud_55_liberty_intermediate/55_liberty_board_president_elizabeth_p_dominguez 


Please consult:

http://compartmentalizedfraud.com/fraud_55_liberty_intermediate/55_liberty_board_pr

esident_elizabeth_p_dominguez/55_liberty_board_president_elizabeth_p_dominguez_load_w_ip_address.php 

 


[1] We asked our Real Estate Broker, Louisa Kennedy,about the large hole in our wall which greeted us when we took possession in January 1987.

[2] 55 Liberty Owners Corp; NYS DOS ID # 548928

[3] Kenneth E Madsen Esq
President
55 Liberty Street Owners Corp.
55 Liberty Street
|New York NY 10005

Kenneth E Madsen
59 Maiden Lane
New York NY

Kathryn E Madsen
1 Broad Street
New York NY 10005
+1.732.671.2635

NY Attorney Registration Number:  1359223

[4] John R Williams
President of the Board
55 Liberty Owners Corp
55 Liberty Street 16D
New York NY 10005

[5] Andrew A Prieto
Treasurer
55 Liberty Street Owners Corporation
55 Liberty Street
New York NY 10005

Andrew A Prieto
33 Driftwood Dr
Port Washington NY 11050-1716

Andrew A Prieto
Chief Executive Officer
Nation Printing Corporation
55 Liberty Street APT 9A
New York NY 10005

Nation Printing Corporation
32-00 Skillman Avenue
Long Island City NY 11101
+1.718.433.0800
fax: +1.718.433.3625
apnation@aol.com

[6] Joseph Pell Lombardi B. Arch. M.Sc.
Architecture (B. Arch.) and Historic Preservation (M.Sc.)
Joseph Pell Lombardi & Associates
412 Broadway 4th floor
New York NY 10013
+1.212.349.0700
Fax:+1.212.732.4083
josephpelllombardi@gmail.com
office@josephpelllombardi.com

[7] Don Lebowitz Esq
NYS Registration Number: 1126929
280 Riverside Dr Apt 9A
New York NY 10025
+1.917.282.1023

[8] Elizabeth P Dominguez
President
55 Liberty Owners Corp.
c/o J C Klein Inc
3 Hanover Square - Suite 15G
New York NY 10004

Elizabeth P Dominguez
c/o Nestor D Dominguez
Managing Member
KMN Capital Management LLC
17 Bergen Street PH
Brooklyn NY 11201

[9] Michael Seth Feuer Esq
NYS Registration Number: 2311082
(Disbarred for Federal Fraud)
Associate
Rosenbloom & Hofflich
15 Maiden Lane Suite 600
New York NY 10038
+1.212.227.6262

Michael Seth Feuer
27 Cambridge Drive
Jackson NJ 08527-2608k
+1.908.755.4344 (VOIP)
+1.732.656.7797 (landline)

Michael Seth Feuer
11 Old Church Road
Warren NJ 07059-5808

℅ Jerald Rosenbloom Esq
Rosenbloom & Hofflich
15 Maiden Lane Suite 600
|New York NY 10038
+1.212.227.6262
jrosenbloom@rhllplaw.com

[10] Robert J Zastrow Esq
74 Washington Square
Salem MA 01970-4034
+1.781.771.6130
z18611865@gmail.com

Robert J Zastrow Esq
NYS Registration Number: 1081868
Stroock & Stroock & Lavan LLP
180 Maiden Lane
New York, NY 10038-4982
+1.212.806.5400 (main)
fax. +1.212.806.2604

Dale Degenshein Esq
ddegenshein@stroock.com

Robert J Zastrow Esq
GeyerGorey LLP
1220 L Street, NW, Suite 100, #418
Washington DC 20005-4018
+1.202.644.9769
robertzastrow@geyergorey.com

[11] Henry Lee Saurborn Jr Esq
NYS Registration Number: 2109825
Kaiser Saurborn & Mair PC
111 Broadway 18th Floor
New York NY 10006
+1.212.338.9100
fax:  +1.212.338.9088
saurborn@ksmlaw.com

[12] Phyllis H Weisberg Esq
NYS Registration Number: 1358274
Partner
Montgomery McCracken Walker & Rhoads LLP
(formerly Kurzman Karelsen & Frank
437 Madison Avenue, 29th Floo
New York NY 10022
+1.212.867.950
fax:  +1.212.201.1939
pweisberg@mmwr.com

[13] Fred L Seeman Esq
NYS Registration Number: 1912666
|32 Broadway - Suite 1214
New York NY 10004
+1.212.608.5000
fax:    +1.212.385.8161
fred@seemanlaw.com

[14] Daniel Ward White Esq
NYS Registration Number: 1972736
Of Counsel
Chiesa Shahinian & Giantomasi PC
11 Times Square 31st Floor
New York NY 10036-6600
+1.973.530.2095
fax: +1.973.530.2295
dwhite@csglaw.com

[15] Carol A Pisano Esq
NYS Registration Number:  1678333
Counsel to the Firm
McElroy Deutsch Mulvaney & Carpenter LLP
88 Pine Street 24th Floor
New York NY 10005
+1.212.483.9490
fax: +1.212.483.9129
cpisano@mdmc-law.com

[16] Alan M Goldberg Esq
Of Counsel
NYS Registration #: 1661859
Anderson Kill PC
1251 Avenue of the Americas
New York NY 10020
+1.212.278.1082 (o-direct)
agoldberg@andersonkill.com

[17] Aaron "Ron" Goldstein Esq
Managing Director
Legal and Claims Practice Group
Aon Financial Services Group (“FSG”)
199 Water Street
New York NY 10038
+1 212.441.1282
aaron.goldstein@aon.com

[18] Jonathan Jay Fink Esq
NYS Registration Number: 1551266
(registration to practice law in NYS is delinquent)
Samson Fink & Dubow LLP
10 E 40th St # 708
New York NY 10016‎
+1.212.856.5800

[19] James Gaither Samson Esq
NYS Registration Number: 1128701
Samson Fink & Dubow LLP
10 E 40th St # 708
New York NY 10016‎
+1.212.856.5800
fax:  +1.212.856.5818

[20] Robert J Phillips (RIP)
115 Kinnebrook Park
[115 Kinnebrook Mobile Home Park]
Monticello NY 12701

[21] Paul R Gottsegen
Management Executive
Douglas Elliman - Gibbons & Ives

Paul R Gottsegen
Executive Asset and Acquisitions Manager Canada & US
Time Equities
55 Fifth Avenue 15th Floor
New York NY 10003-4398
+1.212.206.6000
fax: +1.212.727.0563
pgottsegen@timeequities.com

[22] Daniel P Kessler [RIP]
Management Executive
Douglas Elliman - Gibbons & Ives
and
Corporate Secretary
55 Liberty Owners Corp

Daniel P Kessler [RIP]
530 East 90th Street - 2J
New York, NY  10128-7859
+1.212.427.9323

[23] Richard "Jack" A Oelberger
Management Executive
Douglas Elliman - Gibbons & Ives

Richard "Jack" A Oelberger
Irene Oelberger
c/o Courtney Oelberger
5845 Doverwood Dr Unit 101
Culver City CA 90230
+1.310.490.6733  (son?) (T-Mobile USA Mobile
+1.310.360.1572 (Pacific Bell Landline)
+1.323.644.2036 (US Telepacific Landline)

[24] Stephen A Rossi
Management Executive
Douglas Elliman - Gibbons & Ives
which morphed in the Milstein Group

Stephen A Rossi
Anne Mary Rossi
29 Seely Lane
31 Seely Lane
POB 133
Sag Harbor NY 11963  [City of North Haven]

Stephen A Rossi
POB 133
Sag Harbor NY 11963

Stephen A Rossi
Anne Mary Rossi
99 Battery Pl Apt 4M
New York NY 10280
+1.212.898.4848 (rings out)(RCN Telecom Services)
anne.rossi@corcoran.com

[25] Joseph Cusenza
J C  Klein Inc
3 Hanover Square
New York NY 10004
+1.212.425.3001

Joseph Cusenza
Chief Executive Officer
J C  Klein Inc
3 Hanover Square
Apartment 15 F
New York, NY 10004

J. C. Klein, Inc.
Principal Executive Office
3 Hanover Square
New York, NY 10004

[26] Donald E Wilson
President
Blue Woods Management Group Inc
307 Seventh Avenue  Suite 604
New York NY 10471
+1.212.645.7333
fax:  212-366-4126

Donald E Wilson
42 River Street 2nd Floor
Sleepy Hollow NY 10591
+1.914.524.8600
fax:  +1.914.524.9100

[27] Steven Olin-Dabrowski
Manager
FirstService Residential
622 Third Avenue 14th Floor
New York NY 10017
+1.212.324.977
+1.212.634.890
fax: +1.212.634.3946

[28] Harold Glauberman
Vice President
Greater New York Mutual Insurance Company
[GNY Insurance Companies]
Greater New York Mutual Insurance Company
200 Madison Avenue - 3rd Floor
New York NY 10016
+1.212.683.9700
fax:  +1.212.532.8018
NAIC 22187
55 Liberty Owners Corporation Multi-Peril Policy # 1131M75921-S

[29] United Services Automobile Association; NAIC # 25941; FEIN  74-0959140; TDI Company Number 14-86800; Current TDI Certificate of Authority  [CofA]  # 14585 granted on April 2 2008: an unincorporated insurance syndicate organized as a Texas reciprocal inter-insurance exchange.

Unlawfully commenced inter-insuring by receipt of a syndicate name's deposit against a reciprocal contract on either June 20 or June 22 1922. First one year license (expired February 28 1926) to commence inter-insuring by reciprocal contract granted on or slightly before March 23 1925 (two and nine years after USAA's unlawful 1922 "receipt of a first deposit from a "syndicate name".

[30] Grace L Ward
NYS Adjuster License # 705538
Excel Claims Service Inc
103 Fort Salonga Road - Suite 8
Northport NY 11768
+1.631.261.2006
fax:  +1.631.261.2676 (good 05 oct 13) (good 28 nov 17)
lossnotice@excelclaims.com
gward@excelclaims.com

Excel Claims Service Inc
63 Berg Avenue
Kings Park NY 11754
[nb:  owned by Andrew Ward - residence?]
[nb:  also the public address of Excel Claims Service Inc]

Grace L Ward
324 Meadow Road
Kings Park NY 11754
+1.631.269.4941
[nb:  this address  is “owned” by Ward]

[31] Daniel Ward White Esq
NYS Registration Number: 1972736
Of Counsel
Chiesa Shahinian & Giantomasi PC
11 Times Square 31st Floor
New York NY 10036-6600
+1.973.530.2095
fax: +1.973.530.2295
dwhite@csglaw.com

[32] Harold Glauberman
Vice President
Greater New York Mutual Insurance Company
[GNY Insurance Companies]
Greater New York Mutual Insurance Company
200 Madison Avenue - 3rd Floor
New York NY 10016
+1.212.683.9700
fax:  +1.212.532.8018
NAIC 22187
55 Liberty Owners Corporation Multi-Peril Policy # 1131M75921-S

[33] Robert M Spadaro Esq
NYS Registration # 1298561
80 Grymes Hill Road
Staten Island NY 10301-3821+1.718.720.0524
rmspadaro@rmspadaro.com

[34] The Honorable Diane Alexis Lebedeff
NYS Registration Number: 1292119
2623 Seville Boulevard # 201
Clearwater FL 33764

[35] Joseph B Cusenza
Chief Executive Officer
J C  Klein Inc
Managing agent for 55 Liberty Street
3 Hanover Square
New York NY 10004
+1.212.425.3001

Joseph B Cusenza
36 Eagle Rock Way
Montclair NJ 07042-201
+1.973.403.908
+1.973.509.9088

[36] Abraham Joselow PE PC
45 West 34th Street Suite 110
New York NY 10001
+1.212.736.2584
fax:  +1.212.736.0241

Peter Joselow
Design-Engineer

[37] Robert J Zastrow Esq
74 Washington Square
Salem MA 01970-4034
+1.781.771.6130
z18611865@gmail.com

Robert J Zastrow Esq
NYS Registration Number: 1081868
Stroock & Stroock & Lavan LLP
180 Maiden Lane
New York, NY 10038-4982
+1.212.806.5400 (main)
fax. +1.212.806.2604

Dale Degenshein Esq
ddegenshein@stroock.com

Robert J Zastrow Esq
GeyerGorey LLP
1220 L Street, NW, Suite 100, #418
Washington DC 20005-4018
+1.202.644.9769
robertzastrow@geyergorey.com

[38] Henry Lee Saurborn Jr Esq
NYS Registration Number: 2109825
Kaiser Saurborn & Mair PC
111 Broadway 18th Floor
New York NY 10006
+1.212.338.9100
fax:  +1.212.338.9088
saurborn@ksmlaw.com

[39] Phyllis H Weisberg Esq
NYS Registration Number: 1358274
Partner
Montgomery McCracken Walker & Rhoads LLP
(formerly Kurzman Karelsen & Frank
437 Madison Avenue, 29th Floo
New York NY 10022
+1.212.867.950
fax:  +1.212.201.1939
pweisberg@mmwr.com

[40] Fred L Seeman Esq
NYS Registration Number: 1912666
|32 Broadway - Suite 1214
New York NY 10004
+1.212.608.5000
fax:    +1.212.385.8161
fred@seemanlaw.com

[41] Daniel Ward White Esq
NYS Registration Number: 1972736
Of Counsel
Chiesa Shahinian & Giantomasi PC
11 Times Square 31st Floor
New York NY 10036-6600
+1.973.530.2095
fax: +1.973.530.2295
dwhite@csglaw.com

[42] Carol A Pisano Esq
NYS Registration Number:  1678333
Counsel to the Firm
McElroy Deutsch Mulvaney & Carpenter LLP
88 Pine Street 24th Floor
New York NY 10005
+1.212.483.9490
fax: +1.212.483.9129
cpisano@mdmc-law.com

[43] Alan M Goldberg Esq
Of Counsel
NYS Registration #: 1661859
Anderson Kill PC
1251 Avenue of the Americas
New York NY 10020
+1.212.278.1082 (o-direct)
agoldberg@andersonkill.com

[44] Aaron "Ron" Goldstein Esq
Managing Director
Legal and Claims Practice Group
Aon Financial Services Group (“FSG”)
199 Water Street
New York NY 10038
+1 212.441.1282
aaron.goldstein@aon.com

[45] Jonathan Jay Fink Esq
NYS Registration Number: 1551266
(registration to practice law in NYS is delinquent)
Samson Fink & Dubow LLP
10 E 40th St # 708
New York NY 10016‎
+1.212.856.5800

[46] James Gaither Samson Esq
NYS Registration Number: 1128701
Samson Fink & Dubow LLP
10 E 40th St # 708
New York NY 10016‎
+1.212.856.5800
fax:  +1.212.856.5818

[47] 55 Liberty Owners Corp; NYS DOS ID # 548928

[48] Kenneth E Madsen Esq
President
55 Liberty Street Owners Corp.
55 Liberty Street
|New York NY 10005

Kenneth E Madsen
59 Maiden Lane
New York NY

Kathryn E Madsen
1 Broad Street
New York NY 10005
+1.732.671.2635

NY Attorney Registration Number:        1359223

[49] John R Williams
President of the Board
55 Liberty Owners Corp
55 Liberty Street 16D
New York NY 10005

[50] Andrew A Prieto
Treasurer
55 Liberty Street Owners Corporation
55 Liberty Street
New York NY 10005

Andrew A Prieto
33 Driftwood Dr
Port Washington NY 11050-1716

Andrew A Prieto
Chief Executive Officer
Nation Printing Corporation
55 Liberty Street APT 9A
New York NY 10005

Nation Printing Corporation
32-00 Skillman Avenue
Long Island City NY 11101
+1.718.433.0800
fax: +1.718.433.3625
apnation@aol.com

[51] Joseph Pell Lombardi B. Arch. M.Sc.
Architecture (B. Arch.) and Historic Preservation (M.Sc.)
Joseph Pell Lombardi & Associates
412 Broadway 4th floor
New York NY 10013
+1.212.349.0700
Fax:+1.212.732.4083
josephpelllombardi@gmail.com
office@josephpelllombardi.com

[52] Elizabeth P Dominguez
President
55 Liberty Owners Corp.
c/o J C Klein Inc
3 Hanover Square - Suite 15G
New York NY 10004

Elizabeth P Dominguez
c/o Nestor D Dominguez
Managing Member
KMN Capital Management LLC
17 Bergen Street PH
Brooklyn NY 11201

[53] United Services Automobile Association; NAIC # 25941; FEIN  74-0959140; TDI Company Number 14-86800; Current TDI Certificate of Authority  [CofA]  # 14585 granted on April 2 2008: an unincorporated insurance syndicate organized as a Texas reciprocal inter-insurance exchange.

Unlawfully commenced inter-insuring by receipt of a syndicate name's deposit against a reciprocal contract on either June 20 or June 22 1922. First one year license (expired February 28 1926) to commence inter-insuring by reciprocal contract granted on or slightly before March 23 1925 (two and nine years after USAA's unlawful 1922 "receipt of a first deposit from a "syndicate name".

[54] United Services Automobile Association; NAIC # 25941; FEIN  74-0959140; TDI Company Number 14-86800; Current TDI Certificate of Authority  [CofA]  # 14585 granted on April 2 2008: an unincorporated insurance syndicate organized as a Texas reciprocal inter-insurance exchange.

Unlawfully commenced inter-insuring by receipt of a syndicate name's deposit against a reciprocal contract on either June 20 or June 22 1922. First one year license (expired February 28 1926) to commence inter-insuring by reciprocal contract granted on or slightly before March 23 1925 (two and nine years after USAA's unlawful 1922 "receipt of a first deposit from a "syndicate name".