COUNTY OF NEW YORK ORDER TO SHOW. New York, held in and for the SUPREME COURT OF THE STATE OF NEW YORK. NOEL RICHARDS and YOLANDA MIERES, CAUSE

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1 At IAS Part of the Supreme Court of the State of New York, held in and for the County of New York, at the Courthouse located at 60 Centre Street, New York on the _ day of, P R E S E N T : Hon. J.S.C. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK NOEL RICHARDS and YOLANDA MIERES, X Index No.: /2015 Plaintiff ' ORDER TO SHOW CAUSE -against- ALEXANDER'S INC, VORNADO REALTY TRUST, 731 COMMERICIAL HOLDIND, LLC and 731 RESIDENTIAL, LLC,, Defendants. X Upon the reading and filing of the Affirmation of David P. Feehan Esq., dated June 12, 2018, together with the exhibits annexed, and upon all prior pleadings and proceedings heretofore had herein, and upon the motion of Hannum Feretic Prendergast & Merlino, LLC, attorneys for the Defendants, ALEXANDER'S INC, VORNADO REALTY TRUST, 731 COMMERICIAL HOLDING, LLC, and 731 RESIDENTIAL LLC: LET the plaintiffs or their attorneys, show cause before this Court, in New York State Supreme Court, New York County at the Courthouse located at 60 Centre Street, New York, New York, Part on the day of June, 2018 at 9:30 A.M., or as soon therealter therearer as counsel can be

2 heard, why an Order should not be issued herein, for an Order: (1) staying the trial of this action which is presently scheduled for June 13, 2018, in IAS Trial Ready Part 40, until defendants, ALEXANDER'S INC, VORNADO REALTY TRUST, 731 COMMERICIAL HOLDING, LLC, and 731 RESIDENTIAL LLC, prior timely summary judgment motion that was marked fully submitted on April 5, 2018 has been decided, as well as the defendants have had a full and fair opportunity to conduct and complete discovery in furtherance of their due process rights based on punitive damages claims recently asserted in the Amended Complaint; or (2) pursuant to New York Rules of Court vacating the Note of Issue and striking the action from the calendar on the ground that the action is not ready for trial; (3) compelling the plaintiffs to provide discovery and evidence in support of punitive damages claims contained in the Amended Complaint; or (4) precluding the plaintiffs from asserting claims for punitive damages based on a lack of any evidence offered by plaintiffs to date with respect to conduct warranting such claims; (5) plaintiff to provide trial authorizations for all providers; and (6) for such other and further relief as this Court may deem just, proper and equitable. IT IS FURTHER ORDERED that pending the hearing and determination of this application, the trial in this action is stayed in its entirety; IT IS FURTHER ORDERED that service of a copy of this Order, together with the documents upon which it is based, be served by overnight mail, on or before the day of, 2018, be considered adequate and proper service for all purposes herein; and IT IS FURTHER ORDERED, that any opposition and/or response papers to this application be served upon Hannum Feretic Prendergast & Merlino, LLC, 55 Broadway, Suite 202, New York, New York providing that such papers are received by counsel not less than seven (7) days prior to the return date of this application.

3 IT IS FURTHER ORDERED, that counsel is permitted to serve reply papers for this application providing that such papers are received by plaintiff's counsel not less than two (2) days prior to the return date of this application. The above-entitled action is for personal injuries. No prior application has been made for the relief sought herein. E N T E R E D: J.S.C.

4 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK NOEL RICHARDS and YOLANDA MIERES, X Index No.: /2015 Plaintiff ' AFFIRMATION SUPPORT IN -against- ALEXANDER'S INC, VORNADO REALTY TRUST, 731 COMMERICIAL HOLDIND, LLC and 731 RESIDENTIAL, LLC,, Defendants. X David P. Feehan, Esq., an attorney duly admitted to practice law before the Courts of the State of New York, hereby affirms the following to be true under the penalties of perjury: 1. I am a member of the law firm of Hannum, Feretic, Prendergast & Merlino, LLC, attorneys for defendants, ALEXANDER'S INC, VORNADO REALTY TRUST, 731 COMMERICIAL HOLDING, LLC, and 731 RESIDENTIAL LLC, in the above-referenced matter, and as such, I am fully familiar with the facts and circumstances as set forth herein. 2. I submit this affirmation in support of the instant Order to Show Cause, which seeks an Order: (1) staying the trial of this action which is presently scheduled for June 13, 2018, in IAS Trial Ready Part 40, until defendants, ALEXANDER'S INC, VORNADO REALTY TRUST, 731 COMMERICIAL HOLDING, LLC, and 731 RESIDENTIAL LLC, until the defendants prior timely summary judgment motion which was interposed on February 28, 2018 and marked fully submitted on April 5, 2018 has been decided, as well as the defendants have had a full and fair opportunity to conduct and complete discovery in furtherance of their due process rights based on punitive damages claims recently asserted in the Amended Complaint; or (2) pursuant to New York Rules of Court $ vacating the Note of Issue and striking the action

5 from the calendar on the ground that the action is not ready for trial; (3) compelling the plaintiffs to provide discovery and evidence in support of punitive damages claims contained in the Amended Complaint; or (4) precluding the plaintiffs from asserting claims for punitive damages based on a lack of any evidence offered by plaintiffs to date with respect to conduct warranting such claims; (5) requiring plaintiff to provide a complete set of authorizations for trial subpoenas; and (6) for such other and further relief as this Court may deem just, proper and equitable. PROCEDURAL HISTORY 3. The action arises from plaintiff NOEL RICHARDS' alleged accident on February 5, 2014, on the public sidewalk adjoining premises at 731 Lexington Avenue, New York, New York. Plaintiff NOEL RICHARDS seeks compensation for bodily injuries. He claims to have been struck by snow and/or ice falling from above. His wife, YOLANDA MIERES, asserts a derivative claim for loss of her injured husband's services. 4. On March 12, 2015, the action was commenced by the filing of a Summons and Verified Complaint, a copy of which is annexed hereto as Exhibit "A". 5. On April 16, 2015, defendants 731 COMMERCIAL HOLDING, LLC, 731 RESIDENTIAL, LLC., ALEXANDER'S INC., and VORNADO REALTY TRUST joined issue by serving a Verified Answer to the Complaint, a copy of which is annexed hereto as Exhibit "B". 6. On April 28, 2015, defendants 731 COMMERCIAL HOLDING, LLC, 731 RESIDENTIAL, LLC., ALEXANDER'S INC., VORNADO REALTY TRUST, ROSE ASSOCIATES, INC., and ONE BEACON COURT SUPERINTENDENT CORP. joined issue by serving an Amended Verified Answer to the Complaint, a copy of which is annexed hereto as Exhibit "C".

6 7. On July 31, 2015, plaintiffs served a Verified Bill of Particulars, a copy of which is annexed hereto as Exhibit "D". 8. On August 18, 2016, plaintiffs filed the Note of Issue and Certificate of Trial Readiness, a copy of which is annexed hereto as Exhibit "E". In Note of Issue, they certify that all pleadings were served, all discovery proceeding known to be necessary were completed, that there has been a reasonable opportunity to complete the foregoing proceedings, and that the case was "ready for trial." 9. On August 25, 2016, plaintiff executed voluntary Stipulation of Discontinuance against defendants ROSE ASSOCIATES, INC., and ONE BEACON, a copy of which is annexed hereto as Exhibit "F". 10. Nearly two and a half years after this action was originally commenced and over one year after plaintiffs filed the Note of Issue, on August 28, 2017, plaintiffs interposed a motion seeking to amend the Complaint to assert punitive damages, a copy of Notice of Motion and Affinnation in Support without attachments is annexed hereto as Exhibit "G". 11. On September 7, 2017, defendants opposed motion and, in the alternative, cross-moved seeking an enlargement of time to move for summary judgment to dismiss plaintiffs punitive damages claim, a copy of joint papers in opposition to motion to amend and in support of their cross-motion without exhibits is annexed hereto as Exhibit "H". 12. On September 13, 2017, plaintiffs served papers in reply to the original motion and in opposition papers to the cross-motion to extend their time to move for summary judgment, a copy of which is annexed hereto as Exhibit "I".

7 13. On October 17, 2017, this Court issued an Order deciding plaintiff's motion to amend and cross-motion to enlarge their time to move for summary judgment, a copy of which is annexed hereto as Exhibit "J". In the Order, this Court granted application to amend the Complaint and also granted cross-motion to extend their time to move for summary judgment for 135 days after the date of the Order. Therefore, pursuant to the Order, defendants had until March 1, 2018 to file a summary judgment motion seeking to dismiss plaintiff's punitive damages claim. 14. In compliance with this Court's Order, on February 28, 2018, the defendants timely moved for summary judgment seeking to dismiss plaintiff's punitive damages claim, a copy of the summary judgment motion without exhibit is annexed hereto as Exhibit "K". 15. On March 29, 2018, plaintiff opposed the summary judgment motion, a copy of which without exhibits is annexed hereto as Exhibit "L". 16. On April 3, 2018, the defendants served reply papers, a copy of which is annexed hereto as Exhibit "M". 17. On April 5, 2018, this Court marked summary judgment motion fully submitted. This motion is still pending before the Court and has not yet been decided. A copy of the E-Court's print-out indicating that this motion was submitted on April 5, 2018 and that it is still undecided is annexed hereto as Exhibit "N". 18. This matter is scheduled to begin jury selection on June 13, However, this matter cannot be tried until both the prior summary judgment motion and this instant Order to Show Cause are decided. The defendants will be substantially and unfairly prejudiced should this matter proceed to trial without a decision on its prior summary judgment motion. The entire purpose of prior motion to enlarge their time to move for summary judgment, that

8 plaintiff vigorously opposed, and this court granted was to file a summary judgment motion to dismiss plaintiff's punitive damages and to receive a decision on said motion. 19. In accordance with this Court's rules, because this application includes a request for a Temporary Restraining Order seeking to stay the trial of this matter pending the determination this instant Order to Show Cause, this our office provided written notification of the presentation of this Order to Show Cause on June 12, 2018, a copy of which is attached hereto as Exhibit "O". LEGAL ARGUMENT I. THIS ACTION MUST BE STAYED UNTIL THIS COURT DECIDES THE DEFENDANTS' PREVIOUSLY SUBMITTED SUMMARY JUDGMENT MOTION 20. In the original Complaint, plaintiffs asserted two causes of action against the defendants. (Complaint, Ex. A). The first cause of action sounded in negligence and asserted that the have a duty to maintain their building, located at 731 Lexington Avenue, New York, NY 10022, in a reasonably safe condition. It should be noted that the second cause of action in the original Complaint is a derivative claims for loss of services, society, companionship and consortium and is not at issue here. In the first cause of action, the plaintiffs alleged that building contains an exterior, downward sloping, metal ledge underneath the glass windows on each floor, that, the plaintiffs claim, were known to accumulate snow and ice when temperatures drop below freezing and that during the day as temperatures rise the snow and ice melts and falls off the ledges. Plaintiff claims in the original Complaint that defendants have been aware of this (i.e., had notice), since the building opened in 2005 and that complaints were filed against the building because of falling snow and ice.

9 21. The first cause of action in the original Complaint is strictly a negligence claim, with plaintiff alleging that defendants had a duty to keep the building reasonably safe and alleging that defendants had notice of a dangerous condition and failed to remedy said condition. Nowhere in that Complaint are any claims of punitive damages, recklessness, or gross negligence asserted. As such, the case was defended on the basis that plaintiffs were only asserting claims of negligence and that the issue of whether defendants had notice of the allegedly dangerous condition was the primary issue in the case. 22. In the Amended Complaint, plaintiffs also only assert two causes of action with the second being the derivative claims discussed earlier. (Amended Complaint, Ex. G). However, for the first time, plaintiffs added boilerplate allegations to the first cause of action alleging that plaintiff's accident was caused by defendants, "in otherwise being willfully reckless and wantonly negligent a the subject time and place." It should be noted that "willfully reckless" is an oxymoron, as "reckless," by definition (according to Merriam-Webster) indicates lack of thinking about consequences, whereas willfulness requires thought and intent. 23. Plaintiff also claims for the first time that despite alleged knowledge of the condition that caused plaintiff's accident, "defendants recklessly, willfully and wantonly failed to provide warning and/or safety to the public from the falling snow and ice hazard." Plaintiffs then claim that, as a result of this alleged conduct, "punitive damages are necessary to deter defendants from continuing their willful, wanton and reckless behavior. 24. CPLR 2201 provides that except where otherwise prescribed by law, the Court in which an action is pending may grant a stay of proceedings "in a proper case", upon such terms as may be just. As noted above, when plaintiffs sought to Amend the Complaint, the defendants opposed the application and immediately cross-moved seeking to enlarge their time to move for

10 summary judgment. (Defendant's Cross Motion Papers, Ex. H). Additionally, this Court granted the defendants request and allowed the defendants until March 1, 2018 to interpose such a motion. (Order, Ex. K). In compliance with this Court's Order, on February 28, 2018, the defendants timely moved for summary judgment seeking to dismiss punitive damages claim. (Summary Judgment Motion, Ex. L). This motion has been fully briefed and was marked submitted on April 5, (E-Court's Printout, Ex N). 25. The entire purpose of prior applicable to enlarge their time to move for summary judgment that this court granted over plaintiff's opposition was to file a summary judgment motion to dismiss plaintiff's punitive damages claim and to receive a decision on said motion. Allowing this matter to proceed to trial without having a decision rendered on the defendant's motion would render defendant's prior motion to enlarge their time to interpose a summary judgment motion entirely moot. There is no purpose of interposing a summary judgment motion if it will not be decided prior to trial. The defendants will be substantially and unfairly prejudiced should this matter proceed to trial without a decision on their prior summary judgment motion. 26. It is well settled that a court has broad discretion to grant a stay in order to avoid the risk of inconsistent adjudications, application of proof and potential waste ofjudicial resources. Access Capital, Inc. v. DeCicco, 302 A.D.2d 48, 51, 752 N.Y.S.2d 658, 661 (l" Dept. 2002); Zonghetti v. Jeromack, 150 A.D.2d 561, 562, 541 N.Y.S.2d 235, 237 (2nd 52 Dept. 1989). This instant litigation is a perfect example of why the legislator enacted CPLR 2201 and vested the Courts with "broad discretion to grant stays". Access Capital, Inc. 302 A.D.2d at First, allowing this matter to proceed to trial while the summary motion judgment is pending presents the risk of inconsistent decisions, i.e. this Court risks having

11 issuing a decision regarding plaintiffs punitive damages one way, only to have a jury to decide.~ci id*' another. Access Capital, 302 A.D.2d at 51 ("in considering whether to impose a discretionary stay... a court should weigh the risk of inconsistent adjudications."). Second, forcing this matter to trial prior to a decision is a complete waste ofjudicial resources. Access Capital, Inc. v. DeCicco, 302 A.D.2d 48, 51, 752 N.Y.S.2d 658, 661 (l" Dept. 2002)("[A] stay will avoid duplication of effort and waste of judicial resources"). If defendants are granted summary judgment on their granted, there is no need to waste the Court's and the jury's time with a full trial. Id. 28. To the extent plaintiffs argue that they will be prejudiced by any further delay in this litigation, this Court is reminded that plaintiffs waited nearly two and a half years after this action was originally commenced and over one year after they filed the Note of Issue to interpose a motion to seeking to amend his Complaint to assert punitive damages. (Plaintiff's Motion to Amend, Ex. G). The defendants should not be denied their right a decision on their timely interposed summary judgment motion because ofplaintiff's own dilatory conduct. 29. A stay is warranted in order to prevent unnecessary prejudice to one party when there is little to no prejudice to the party opposing the stay. Access Capital, Inc. v. DeCicco, 302 A.D.2d 48, 51, 752 N.Y.S.2d 658, 661 (l" Dept. 2002)(find a stay appropriate because plaintiffs did "not demonstrated how they would be prejudiced by a stay"). In other words, a stay is warranted where the resulting prejudice to the plaintiff is not as severe as prejudice the defendants will suffer without a stay. Britt v. Int'l Bus Servs., Inc., 255 A.D.2d 143, 144, 679 N.Y.S.2d 616 (l" Dept. 1998). 30. Accordingly, this Court should issue a stay until the prior summary judgment has been decided.

12 II. THIS COURT SHOULD STAY THIS ACTION UNTIL DEFENDANTS HAVE HAD A FULL AND FAIR OPPORTUMTY TO CONDUCT AND COMPLETE DISCOVERY IN FURTHERANCE OF THEIR DUE PROCESS PLAINTIFFS' RIGHTS, OR IN THE ALTERNATIVE, VACATE NOTE OF ISSUE AND/OR PRECLUDE PLAINTIFFS FROM OFFERING EVIDENCE REGARDING THEIR CLAIM FOR PUNITIVE DAMAGES 31. As noted above, new claims seek punitive damages. These new claims exceed the standard negligence claims asserted by the plaintiffs in the original complaint and require additional discovery to be properly defended against. 32. The request for punitive damages triggers significant Constitutional limitations under the Due Process Clause of the Fourteenth Amendment. State Farm Mut. Auto. Ins. Co. v ~Cam bell 338 U.S. 408 (2003); Coo er Indus. Inc. v Leatherman Tool Grou Inc., 332 U.S. 424 (2001); BMW of N. Am. Inc. v Gore 517 U.S. 559 ( 1996) 33. More specifically, the Due Process Clause of the Fourteenth Amendment imposes both procedural and substantive constraints on awards of punitive damages. State Farm, 538 U.S. 408 ("it is well established that there are procedural and substantive constitutional limitations on 8 d "3'8 d. 33 Udd8: The Court's "concerns are heightened when the decisionmaker is presented...with evidence that has little bearing as to the amount of punitive damages that should be awarded." State Farm Mut. Auto. Ins. Co. v. Cam bell 538 U.S. 408, 418, 123 S. Ct. 1513, 1520, 155 L. Ed. 2d 585 (2003). Here, no discovery has been conducted with respect to amended claims and, thus, it is imperative that the defendants are afforded the ability to properly develop a defense if punitive damages claims are allowed to stand in this matter, necessitating a stay of the trial or vacatur of the Note of Issue, in order to permit defendants to conduct the discovery necessary to properly inform a potential jury.

13 35. Due process requires that a defendant be provided with an opportunity to conduct discovery and establish a defense with respect to a punitive damages claim because such a claim involves different elements and standards of proof and potentially subjects defendants to a far greater and different dimension of liability than would otherwise be the case. Matter of New York City Asbestos Litigation, 130 A.D.3d 489, 13 N.Y.S.3d 398 (l" Dept. 2015); see Heller v Louis Provenzano, Inc., 303 A.D.2d 20, 756 N.Y.S.2d 26 (1" Dept. 2003). 36. Additionally, as "instructions can go just so far in promoting systemic consistency when awards are not tied to specifically proven items of damage," it is even more important that defendants be afforded the opportunity to fully develop the defense against punitive claims in this matter. Exxon Shipping Co. v. Baker, 554 U.S. 471, 504 (2008). Thus, a stay of the trial is warranted to permit defendants to conduct appropriate discovery and retain the necessary experts to appropriately address the punitive claims, so as to afford defendants the due process required in opposing the claims. 37. The Appellate Division, First Department, has held that: punitive damages are not available for ordinary negligence...in order to recover punitive damages, a plaintiff must show, by 'clear, unequivocal and convincing conduct' evidence'...'egregious and willful that is 'morally culpable, or is actuated by evil and reprehensible motives'. Munoz v. Puretz, 301 A.D.2d 382, 384, 753 N.Y.S.2d 463, 466 (1" Dept. 2003)(internal citations omitted). 38. "An act, to be wanton in the law, should be without care. Where there exists slight care, or some care, it may not be held to be wanton." Phalen v. Rae Misc. 424, 428, 168 N.Y.S. 139, 141 (Sup. Ct., Rensselaer Cnty. 1917), aff d, 184 A.D. 922, 170 N.Y.S (3"1 Dept. 1918). Here, there has been no showing by plaintiffs that conduct was without any care. Rather, the evidence indicates that defendants would rope off areas of the street, station

14 security guards outside to keep people from moving by the building and call the NYPD and MTA to close down a subway entrance at the building if conditions warranted. (Deposition Transcript of Alessio Amico at pp , 54, which is annexed hereto as Exhibit "P"; Deposition Transcript O' of Sean O'Sullivan at p. 44, which is annexed hereto as Exhibit "Q". This shows at least a level of care that precludes a finding of wanton conduct by the defendants. 39. "The nature of the conduct which justifies an award of punitive damages has been variously described, but, essentially, it is conduct having a high degree of moral culpability...which manifests a 'conscious disregard of the rights of others or conduct so reckless as to amount to such disregard.'" Home Ins. Co. v. Am. Home Prod. Corp.,. 75 N.Y.2d 196, 203, 551 N.Y.S.2d 481, 485 (1990)(internal citations omitted). Plaintiffs have offered no evidence to demonstrate this level of conduct by defendants. As such, the claims for punitive damages should be precluded or the Note of Issue should be vacated and the plaintiffs should be compelled to produce evidence demonstrating said conduct by the defendants. If plaintiff is permitted to assert these claims, the trial should be stayed so that defendants can properly address the claims as due process affords. 40. In light of the claims asserted in Amended Complaint requesting punitive damages, the trial of this matter should be stayed to afford defendants the opportunity to conduct meaningful discovery to defend against these claims or the Note of Issue should be vacated to allow additional discovery regarding claims of willful, wanton and recldess conduct by defendants.

15 41. It is respectfully submitted that permitting the case to proceed to trial at this time will engender prejudice to the defendants. The fact remains that the defendants have not been able to properly defend against these new claims by plaintiff to the extent due process requires. Without staying the trial of this matter, the defendants are deprived of information essential to their defense. 42. As such, it is respectfully requested that the Court, in the interest of justice, stay the trial of this action which is presently scheduled for June 13, 2018, in IAS Trial Ready Part 40 until defendants have had a full and fair opportunity to conduct and complete discovery; or vacate the plaintiff's Note of Issue and strike the action from the calendar on the ground that the action is not ready for trial. 43. Based on the foregoing, an emergency stay of the trial is required due to the impending trial date of June 13, 2018, in IAS Trial Ready Part 40. Without the stay, the defendants will substantially and irrevocably prejudiced. Elie v. City of New York, 92 A.D.3d 716, 717, 938 N.Y.S.2d 595 (2nd Dept. 2012); Allen v Crowell-Collier Pub. Co., 21 N.Y.2d 403, 405, 288 N.Y.S.2d 449 (1968)(holding that considerations of judicial economy and prejudice warrant granting relief). 44. Additionally, the defendants have never been provided with trial authorizations for all providers including and not limited to Social Security Administrations, Dr. Jenny Walker, Luke' unrestricted St. Luke's, among others, in so as to properly defend the case. 45. No prior application has been made by the defendants for the relief requested herein. WHEREFORE, it is respectfully requested that the Court issue an Order: (1) staying the trial of this action which is presently scheduled for June 13, 2018, in IAS Trial Ready Part 40, until defendants, ALEXANDER'S INC, VORNADO REALTY TRUST, 731 COMMERICIAL

16 HOLDING, LLC, and 731 RESIDENTIAL LLC, until the prior timely summary judgment motion that was marked fully submitted on April 5, 2018 has been decided, as well as the defendants have had a full and fair opportunity to conduct and complete discovery in furtherance of their due process rights based on punitive damages claims recently asserted in the Amended Complaint; or (2) pursuant to New York Rules of Court vacating the Note of Issue and striking the action from the calendar on the ground that the action is not ready for trial; (3) compelling the plaintiffs to provide discovery and evidence in support of punitive damages claims contained in the Amended Complaint; or (4) precluding the plaintiffs from asserting claims for punitive damages based on a lack of any evidence offered by plaintiffs to date with respect to conduct warranting such claims; and (5) for such other and further relief as this Court may deem just, proper and equitable. DATED: New York, New York June 12, 2018 Yours, etc., HANNUM FERET PRENDERGAST & MERLINO David P. Feehan Attorneys for Defendants ALEXANDER'S INC, VORNADO REALTY TRUST, 731 COMMERICIAL HOLDING, LLC, and 731 RESIDENTIAL LLC Office and Post Office Address 55 Broadway, Suite 202 New York, New York (212)

17 Index No.: /2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK NOEL RICHARDS and YOLANDA MIERES, Plaintiff, -against- ALEXANDER'S INC, VORNADO REALTY TRUST, 731 COMMERICIAL HOLDIND, LLC and 731 RESIDENTIAL, LLC, Defendants. ORDER TO SHOW CAUSE and AFFIRMATION IN SUPPORT HANNUM FERETIC PRENDERGAST 4 MERLINO, LLC Attorneys for the Defendants ALEXANDER'S INC, VORNADO REALTY TRUST, 731 COMMERICIAL HOLDING, LLC, 731 RESIDENTIAL LLC Office and Post Office Address 55 Broadway, Suite 202 New York, New York (212)