Case 1:15-cv LTS-KHP Document 485 Filed 07/09/18 Page 1 of 5 15-CV-5236 (LTS) (KHP)
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1 Case 1:15-cv LTS-KHP Document 485 Filed 07/09/18 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x JANELL WINFIELD, TRACEY STEWART, SHAUNA NOEL, and EMMANUELLA SENAT, Plaintiffs, -against- 15-CV-5236 (LTS) (KHP) CITY OF NEW YORK, Defendant x DECLARATION OF CRAIG GURIAN IN SUPPORT OF PLAINTIFFS MOTION TO COMPEL THE DEPOSITION OF MAYOR BILL DE BLASIO CRAIG GURIAN, an attorney admitted to practice before this Court, pursuant to 28 U.S.C. 1746, declares that the following is true and correct: 1. I am co-counsel for plaintiffs and submit this declaration in support of plaintiffs motion to compel the deposition of Mayor Bill de Blasio. 2. Such yellow highlighting as appears in any of the exhibits annexed hereto was added by plaintiffs in connection with this motion for the convenience of the Court. 3. Excerpts of the transcript of the Nov. 3, 2017 Alicia Glen deposition are annexed hereto as Exhibit A Jul. 17, 2017 Politico New York article entitled De Blasio says Council opposition not an obstacle to affordable housing goals is annexed hereto as Exhibit An excerpt of the transcript of the Sept. 14, 2017 Court Conference (ECF 183) is annexed hereto as Exhibit 3. 1
2 Case 1:15-cv LTS-KHP Document 485 Filed 07/09/18 Page 2 of 5 6. An excerpt of the Office of the Mayor transcript of remarks of the Mayor on Aug. 21, 2015, Mayor de Blasio, Queens Officials and the Arker Companies Break Ground on 154 New Affordable Homes for Low-Income Seniors, is annexed hereto as Exhibit Excerpts of the transcript of the Aug. 2, 2017 deposition of Vicki Been ( Been I ) are annexed hereto as Exhibit An excerpt of the Office of the Mayor transcript of remarks by the Mayor and other city officials on July 13, 2015, Mayor de Blasio Announces a Record-Breaking 20,325 Affordable Apartments and Homes Financed in Last Fiscal Year, Enough for 50,000 New Yorkers, is annexed hereto as Exhibit An excerpt of the Preliminary Guide to NYC s AFH Submission, specifically, Table 3, at 8 (permitted to be used by plaintiffs pursuant to ECF 259, at 23) is annexed hereto as Exhibit An excerpt of the Office of the Mayor transcript of Mayor de Blasio Appears on NBC s Ask the Mayor from Apr. 18, 2016 is annexed hereto as Exhibit A copy of defendant s Fifth Responses and Objections to Plaintiffs First Set of Interrogatories, June 11, 2018, is annexed hereto as Exhibit An excerpt of the Office of the Mayor transcript of Mayor de Blasio Appears Live on Inside City Hall from Jan. 17, 2018 is annexed hereto as Exhibit Excerpts of the transcript of the Apr. 10, 2018 deposition of Vicki Been ( Been II ) are annexed hereto as Exhibit A copy of an Aug chain including s between the Mayor and Ms. Been, Bates , is annexed hereto as Exhibit 12. 2
3 Case 1:15-cv LTS-KHP Document 485 Filed 07/09/18 Page 3 of A copy of overlapping July chains involving the Mayor, Bates , are annexed hereto as Exhibit An excerpt of the transcript of the June 1, 2018 Shaun Donovan deposition is annexed hereto as Exhibit An excerpt of the Office of the Mayor transcript of a Mar. 14, 2016 town hall meeting, Mayor de Blasio Hosts Town Hall Meeting with Brooklyn Residents to Discuss Affordable Housing, is annexed hereto as Exhibit Excerpts of the transcript of the Mar. 16, 2018 deposition of Matthew Murphy is are annexed hereto as Exhibit An excerpt of the transcript of the May 18, 2018 Elyzabeth Gaumer deposition is annexed hereto as Exhibit Excerpts of the transcript of the Apr. 19, 2018 Purnima Kapur deposition are annexed hereto as Exhibit An excerpt of the transcript of the May 10, 2018 deposition of Maria Torres- Springer are annexed hereto as Exhibit An excerpt of the June 22, 2017 New York Times article, No Deal, Just Blame, on Mayoral Control of New York City Schools, is annexed hereto as Exhibit An excerpt of the Office of the Mayor transcript of remarks delivered by the Mayor on May 11, 2016, Mayor de Blasio Delivers Remarks at NYSAFAH Housing for all Conference, is annexed hereto as Exhibit An excerpt of the Office of the Mayor transcript of Mayor de Blasio Appears Live on WNYC from June 9, 2017 is annexed hereto as Exhibit 22. 3
4 Case 1:15-cv LTS-KHP Document 485 Filed 07/09/18 Page 4 of An excerpt of the Office of the Mayor transcript of Mayor de Blasio Appears Live on Inside City Hall from June 12, 2017 is annexed hereto as Exhibit An excerpt of the Office of the Mayor transcript of Mayor de Blasio Appears Live on the Brian Lehrer Show from May 11, 2018 is annexed hereto as Exhibit An excerpt of a May 11, 2017 New York Times article, De Blasio, Expanding an Education Program, Dismisses Past Approaches, is annexed hereto as Exhibit An excerpt of the Office of the Mayor transcript of Aug. 10, 2016 remarks by the Mayor, A Year Ahead of Schedule, Mayor de Blasio Announces Opening of New Upper West Side School, is annexed hereto as Exhibit Excerpts of an op-ed written by the Mayor that appeared in the New York Daily News on Mar. 9, 2016, Why our housing plan must pass: Mayor de Blasio urges the City Council and advocates to get behind his zoning reforms, is annexed hereto as Exhibit Excerpts of an Apr. 23, 2018 Politico New York article, 50 years after Fair Housing Act, New York City still struggles with residential segregation, is annexed hereto as Exhibit A copy of a letter to the editor from Council Member Ritchie Torres to Crain s New York that appeared on Jan. 22, 2018, Mayor s fair-housing pledge doesn t inspire confidence, is annexed hereto as Exhibit An excerpt of a May 23, 2018 New York Daily News article, City Council may create office to fix racial segregation in schools, is annexed hereto as Exhibit Excerpts of the transcript of the Nov. 29, 2017 deposition of Steven Banks are annexed hereto as Exhibit 31. 4
5 Case 1:15-cv LTS-KHP Document 485 Filed 07/09/18 Page 5 of Excerpts of the Office of the Mayor transcript of the Mayor s Feb. 28, 2017 speech on the City s homelessness plan ( Homeless Policy Speech ) is annexed hereto as Exhibit An excerpt of the transcript of the Jul. 27, 2017 deposition of Carl Weisbrod is annexed hereto as Exhibit 33. I declare under penalty of perjury that the foregoing statements are true and correct to the best of my knowledge and belief. Executed on July 9, Craig Gurian Craig Gurian 5
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27 Case 1:15-cv LTS-KHP Document Filed 07/09/18 Page 1 of 2 OverviewNewsMayor's BioOfficials Transcript: Mayor de Blasio, Queens Officials and the Arker Companies Break Ground on 154 New Affordable Homes for Low-Income Seniors August 21, 2015 Mayor Bill de Blasio: Well, Dan, thank you. And thank you to everyone at the Arker Companies. You guys have been fantastic in this project and so many others. You re long-time partners with the city of New York in the creation of affordable housing in all five boroughs. So, I thank you. You know, we depend on companies in the real estate community to get the job done and there are so many that are devoted truly devoted, personally and humanly devoted to the work of affordable housing. And the Arker Companies are one of the great examples of that. Two years from this very day, right here, the lives of more than 150 senior citizens will change and change for the better. That will be when they move into the Beach Channel Senior Residences. It s going to be a wonderful development. And for over 150 people, it means security, it means affordability. It means a good, safe place to live. And they deserve that. Our seniors deserve that, considering all they ve done for us. What they ll be leaving behind, in many cases, is a lot of worries, a lot of challenges, the struggle to make ends meet, which too many seniors in this city face every single day. I ve heard from seniors all over New York City they want to stay in the city they love. They just want to be able to afford it. Beach Channel Senior Residences are going to give that opportunity to 150 of our fellow New Yorkers. Now, any groundbreaking where we re creating affordable housing is a good groundbreaking. This is a special one because this will be the first apartments created under one of our new initiatives the Senior Affordable Rental Apartments Program, with the helpful acronym SARA. [Laughter] I love a program that says exactly what it is Senior Affordable Rental Apartments. There s no mystery in that, and we are thrilled that we are going to be doing this on a very big scale. This is the first ever program created by the city of New York for low-income seniors in which we will build affordable housing for them. This is created with a city investment of $350 million dollars. And I want to thank our colleagues in the City Council, who we depend on as we make these decisions about where to invest. The support and agreement of the City Council is crucial. I want to thank them for their belief in this program. You know I ll say this as someone who used to work for HUD long ago the assumption in terms of senior affordable housing, for decades, was that the federal government saw that as a primary responsibility. That has now diminished to almost nothing. Now, it s up to the city of New York to
28 Case 1:15-cv LTS-KHP Document Filed 07/09/18 Page 2 of 2 have never stopped working together since. I truly appreciate his leadership Councilman Donovan Richards. [ ] Mayor: Okay. So, here goes your choreography. We re going to take questions on the topic of this announcement on our affordable housing plan. We re then going to do the groundbreaking. We re then going to come back and talk about other topics and take questions on other topics. So, first, questions on affordable housing and this project. Yes? Question: What percentage of the units are going to be certified for [inaudible] Mayor: Well, I m going to start, and Vicki you can add. This is consistent with our entire approach to affordable housing in this city where there is a set of units 50 percent of those community preference, meaning the community board district, and 50 percent are part of a city-wide lottery. We believe that s a very fair approach because folks who have built up communities deserve a special opportunity to get affordable housing that s created. But we also think it s important that there be a substantial portion available to anyone and everyone. So, the model strikes that balance. You want to add, or Unknown: [inaudible] Mayor: Yes? Question: [inaudible] Mayor: Oh, I think it s a top priority of New Yorkers again, you know, I think for Donovan, and Jumaane, and I, we do not need the services of a professional public opinion research firm. We get it everyday and we always have. And I was a council member and public advocate for 12 years before I was mayor or as Bob Dylan once said, you don t need a weatherman to know which way the wind blows. So, it s quite clear it s a number one issue on the minds of New Yorkers I ve talked to over the last decade-plus. And with the price of housing today, I think even more so. I think this issue deserves a lot more attention because it s so crucial to people s lives. It s the ultimate bread and butter issue. It s the number one expense. It s the thing that people struggle with the most, especially a very substantial number of New Yorkers who are having trouble making ends meet. So, we re going to be talking about it a lot. I said in the state of the city address this year, the number one focus is affordable housing. I think we proved that we meant it with the 20,000-plus number, again the fiscal year. Again, tremendous credit to Vicki and her team for that. But there s a lot more where that came from. We re going to be focused a lot on it, and I think people want to hear more about it. Question: [inaudible] Mayor: [inaudible] this idea of we believe in all of our affordable housing efforts, the same in our Built It Back efforts anything that we sponsor, the work we do in public housing, we want to maximize jobs for community residents in every possible way, every appropriate way. So, that s something we try and bake into everything we do. Commissioner Vicki Been, Department of Housing Preservation and Development: So, this construction project will bring a great may construction jobs to this neighborhood. The Arkers have been an amazing company in terms of hiring local and really making efforts to bringing local residents onto their programs. We are doing a lot around City Hall and city agencies to provide workforce assistance to help them find local residents, to help them find qualified residents across
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UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WISCONSIN
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WISCONSIN RUTHELLE FRANK, et al., on behalf of themselves and all others similarly situated, Plaintiffs, Civil Action No. 2:11-cv-01128 (LA) v.
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