FILED: NEW YORK COUNTY CLERK 07/07/ :53 PM INDEX NO /2013 NYSCEF DOC. NO. 64 RECEIVED NYSCEF: 07/07/2015

Similar documents
FILED: NEW YORK COUNTY CLERK 06/07/ :32 PM INDEX NO /2017 NYSCEF DOC. NO. 164 RECEIVED NYSCEF: 06/07/2018

FILED: NEW YORK COUNTY CLERK 09/05/ :37 PM INDEX NO /2014 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 09/05/2014

FILED: NEW YORK COUNTY CLERK 08/08/ :26 PM INDEX NO /2015 NYSCEF DOC. NO. 117 RECEIVED NYSCEF: 08/08/2016

DEFENDANTS' VERIFIED ANSWER

FILED: NEW YORK COUNTY CLERK 08/25/ :15 AM INDEX NO /2016 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 08/25/2017

FILED: KINGS COUNTY CLERK 09/22/ :49 PM INDEX NO /2016 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 09/22/2016. Exhibit D {N

FILED: WESTCHESTER COUNTY CLERK 03/22/ :11 PM INDEX NO /2016 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 03/22/2016

FILED: ONEIDA COUNTY CLERK 01/23/ :02 PM

IN THE CIRCUIT COURT OF MONTGOMERY COUNTY, ALABAMA

FILED: KINGS COUNTY CLERK 08/21/ :37 PM INDEX NO /2016

Case 3:08-cv VRW Document 11 Filed 05/22/2008 Page 1 of 9

FILED: NEW YORK COUNTY CLERK 06/19/ :05 PM INDEX NO /2015 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 06/19/2015

FILED: NEW YORK COUNTY CLERK 12/17/ :47 PM INDEX NO /2015 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 12/17/2015

FILED: NEW YORK COUNTY CLERK 11/13/ :06 PM INDEX NO /2015 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 11/13/2015

FILED: NEW YORK COUNTY CLERK 08/26/ :49 PM INDEX NO /2015 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 08/26/2015

FILED: NEW YORK COUNTY CLERK 01/23/ /09/ :34 PM INDEX NO /2013 NYSCEF DOC. NO RECEIVED NYSCEF: 01/23/2014

Case5:09-cv JW Document106 Filed04/22/10 Page1 of 9

FILED: NEW YORK COUNTY CLERK 09/30/ :41 PM INDEX NO /2016 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/30/2016

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

FILED: NEW YORK COUNTY CLERK 09/29/ :13 PM INDEX NO /2016 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 09/29/2016

FILED: RICHMOND COUNTY CLERK 03/30/ :14 PM INDEX NO /2016 NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 03/30/2018

FILED: NEW YORK COUNTY CLERK 06/09/ :30 PM INDEX NO /2016 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 06/09/2017

FILED: KINGS COUNTY CLERK 12/12/ :27 PM INDEX NO /2014 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 12/12/2014

FILED: KINGS COUNTY CLERK 08/10/ :35 PM INDEX NO /2015 NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 08/10/2018 EXHIBIT 4

FILED: NEW YORK COUNTY CLERK 07/06/ :18 PM INDEX NO /2006 NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 07/06/2016. Exhibit 21

FILED: NEW YORK COUNTY CLERK 11/09/ :16 PM INDEX NO /2016 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 11/09/2016

FILED: NEW YORK COUNTY CLERK 07/19/2012 INDEX NO /2011 NYSCEF DOC. NO. 135 RECEIVED NYSCEF: 07/19/2012

FILED: NEW YORK COUNTY CLERK 11/18/ :03 PM INDEX NO /2016 NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 11/18/2016

FILED: NEW YORK COUNTY CLERK 12/08/ :36 PM INDEX NO /2012 NYSCEF DOC. NO. 223 RECEIVED NYSCEF: 12/08/2014

PLAINTIFF'S REPLY TO DEFENDANTS GORDON RAMSAY'S AND G.R. US LICENSING'S AMENDED COUNTERCLAIMS

Defendant, Prevost Car (US) Inc., Individually and as. Successor to Nova Bus, by its attorneys, MAIMONE & ASSOCIATES,

FILED: KINGS COUNTY CLERK 02/24/ /31/ :26 08:31 PM AM INDEX NO /2016 NYSCEF DOC. NO. 637 RECEIVED NYSCEF: 02/24/2017

FILED: NEW YORK COUNTY CLERK 11/13/ :06 PM INDEX NO /2015 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 11/13/2015

FILED: NEW YORK COUNTY CLERK 03/19/ :45 PM INDEX NO /2016 NYSCEF DOC. NO. 168 RECEIVED NYSCEF: 03/19/2018

FILED: QUEENS COUNTY CLERK 11/28/ :53 PM INDEX NO /2016 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 11/28/2016

Case 3:15-cv RGJ-KLH Document 38 Filed 11/25/16 Page 1 of 9 PageID #: 257 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA

FILED: NEW YORK COUNTY CLERK 02/09/ :55 PM INDEX NO /2017 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 02/09/2018

FILED: NASSAU COUNTY CLERK 08/14/2013 INDEX NO /2013 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 08/14/2013

FILED: NEW YORK COUNTY CLERK 08/11/ :17 PM INDEX NO /2016 NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 08/11/2017

FILED: NEW YORK COUNTY CLERK 01/31/ :46 PM INDEX NO /2016 NYSCEF DOC. NO. 112 RECEIVED NYSCEF: 01/31/2017

R. BRIAN DIXON, Bar No LITTLER MENDELSON, P.C.

Case 1:12-cv DJC Document 36 Filed 09/10/13 Page 1 of 16 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

FILED: NEW YORK COUNTY CLERK 04/08/2013 INDEX NO /2010 NYSCEF DOC. NO. 76 RECEIVED NYSCEF: 04/08/2013

FILED: NEW YORK COUNTY CLERK 08/15/ :02 PM INDEX NO /2013 NYSCEF DOC. NO. 302 RECEIVED NYSCEF: 08/15/2017

FILED: NEW YORK COUNTY CLERK 04/11/2013 INDEX NO /2012 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 04/11/2013

FILED: KINGS COUNTY CLERK 09/11/ :43 PM INDEX NO /2017 NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 09/11/2017

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

)(

FILED: NEW YORK COUNTY CLERK 11/17/ :50 PM INDEX NO /2013 NYSCEF DOC. NO. 72 RECEIVED NYSCEF: 11/17/2014

FILED: KINGS COUNTY CLERK 10/13/ :25 AM INDEX NO /2016 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/13/2016

SUPERIOR COURT OF WASHINGTON FOR KING COUNTY. Defendant FedEx Ground Package System, Inc. (hereinafter FedEx Ground ), by and

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Civil Case No.: 18-cv (WMW/SER)

FILED: NEW YORK COUNTY CLERK 02/19/ :38 AM INDEX NO /2016 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 02/19/2016

Kanter v. California Administrative Office of the Courts Doc. 10 Case 3:07-cv MJJ Document 10 Filed 07/02/2007 Page 1 of 13

NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 11/10/2010. Plaintiffs,

FILED: NEW YORK COUNTY CLERK 03/15/ :24 AM INDEX NO /2016 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 03/15/2016

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

FILED: NEW YORK COUNTY CLERK 12/02/ :13 AM INDEX NO /2016 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 12/02/2016

FILED: NEW YORK COUNTY CLERK 12/18/ :36 PM INDEX NO /2017 NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 12/18/2017

FILED: NEW YORK COUNTY CLERK 08/11/ :47 PM INDEX NO /2016 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 08/11/2016

FILED: NEW YORK COUNTY CLERK 02/08/ :44 PM INDEX NO /2016 NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 02/08/2018

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA GAINESVILLE DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 2:12-cv APG-PAL Document 168 Filed 04/16/14 Page 1 of 12

FILED: NEW YORK COUNTY CLERK 10/03/ :34 AM INDEX NO /2014 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 10/03/2014

FILED: NEW YORK COUNTY CLERK 02/13/ :43 PM INDEX NO /2016 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 02/13/2018

FILED: RICHMOND COUNTY CLERK 06/03/ :22 PM INDEX NO /2015 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/03/2015

Case 1:17-cv PBS Document 24 Filed 05/26/17 Page 1 of 11 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS ) ) ) ) ) ) ) ) ) ) ) )

FILED: ORANGE COUNTY CLERK 03/30/ :05 PM

FILED: NEW YORK COUNTY CLERK 10/28/ :04 PM INDEX NO /2016 NYSCEF DOC. NO. 55 RECEIVED NYSCEF: 10/28/2016

Case LSS Doc 5 Filed 09/20/17 Page 1 of 10 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

FILED: KINGS COUNTY CLERK 05/31/ :16 PM INDEX NO /2015 NYSCEF DOC. NO. 78 RECEIVED NYSCEF: 05/31/2016

FILED: NEW YORK COUNTY CLERK 03/10/ :54 PM INDEX NO /2016 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/10/2016

Case3:13-cv SI Document11 Filed03/26/13 Page1 of 17

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SACRAMENTO

Case 4:17-cv PJH Document 61 Filed 02/28/18 Page 1 of 33

Case 1:14-cv JCC-IDD Document 7 Filed 10/14/14 Page 1 of 9 PageID# 39

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION. Plaintiff, Defendant.

FILED: NEW YORK COUNTY CLERK 01/05/ :54 PM INDEX NO /2017 NYSCEF DOC. NO. 148 RECEIVED NYSCEF: 01/05/2018

FILED: NEW YORK COUNTY CLERK 02/05/ :47 PM INDEX NO /2016 NYSCEF DOC. NO. 54 RECEIVED NYSCEF: 02/05/2018

Case 2:12-cv MSD-TEM Document 4 Filed 12/26/12 Page 1 of 11 PageID# 25

Case 1:16-cv LGS Document 21 Filed 04/11/16 Page 1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

2. Green Tree is without knowledge of the allegations contained in Paragraph 2 of

Plaintiff, Yonkers Contracting Company, Inc. ("Yonkers"), and Zurich American Insurance Company

FILED: NEW YORK COUNTY CLERK 10/31/ :29 PM INDEX NO /2016 NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 10/31/2016

FILED: NEW YORK COUNTY CLERK 04/28/ :02 PM INDEX NO /2017 NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 04/28/2017

FILED: NEW YORK COUNTY CLERK 08/03/ :13 AM INDEX NO /2016 NYSCEF DOC. NO. 78 RECEIVED NYSCEF: 08/03/2017

FILED: QUEENS COUNTY CLERK 03/06/ :01 PM INDEX NO /2017 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 03/06/2018

Case 1:14-cv CMA-KMT Document 1081 Filed 05/16/18 USDC Colorado Page 1 of 30 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case Doc 19 Filed 06/01/16 Entered 06/01/16 14:19:45 Desc Main Document Page 1 of 13 UNITED STATES BANKRUPTCY COURT DISTRICT OF MASSACHUSETTS

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION. Case No. 3:18-CV FDW-DSC

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) )

FILED: NEW YORK COUNTY CLERK 06/14/ :52 AM INDEX NO /2016 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/14/2016

FILED: NEW YORK COUNTY CLERK 05/21/2013 INDEX NO /2012 NYSCEF DOC. NO. 94 RECEIVED NYSCEF: 05/21/2013

Case 1:17-cv LAP Document 88 Filed 07/20/18 Page 1 of 17

FILED: NEW YORK COUNTY CLERK 08/26/ :23 PM INDEX NO /2015 NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 08/26/2015

FILED: SUFFOLK COUNTY CLERK 10/13/ :12 PM INDEX NO /2017 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 10/13/2017

Case 2:17-cv EEF-MBN Document 66 Filed 11/07/17 Page 1 of 10 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

Case 8:13-cv JSM-AEP Document 17 Filed 01/14/14 Page 1 of 12 PageID 64 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

Case: 1:12-cv Document #: 21 Filed: 03/05/12 Page 1 of 11 PageID #:30 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS

FILED: NEW YORK COUNTY CLERK 06/07/ :33 PM INDEX NO /2016 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 06/07/2016

Transcription:

FILED: NEW YORK COUNTY CLERK 07/07/2015 03:53 PM INDEX NO. 158552/2013 NYSCEF DOC. NO. 64 RECEIVED NYSCEF: 07/07/2015 SUPREME COURT: STATE OF NEW YORK NEW YORK COUNTY THE BOARD OF MANAGERS OF 11-15 EAST 70TH ST. CONDOMINIUM, Plaintiff, Index No. 158552/2013 -against- 11 EAST 70TH CORP., BERRY-HILL GALLERIES, INC., HSBC BANK USA, NATIONAL ASSOCIATION, PAULSON & CO., INC., ROBERT BURNS, THE NEW YORK STATE DEPARTMENT OF LABOR, 624 ART HOLDINGS, LLC, THE NEW YORK CITY DEPARTMENT OF FINANCE, THE NEW YORK CITY ENVIRONMENTAL CONTROL BOARD, AND THE NEW YORK CITY PARKING VIOLATIONS BUREAU. Defendants. ANSWER Defendant 624 Art Holdings, LLC (the Defendant ), as and for its answer to the amended complaint ( AC ) filed by plaintiff The Board of Managers of 11-15 East 70th St. Condominium (the Plaintiff ), by and through its undersigned counsel, Sam P. Israel, P.C., states as follows: ANSWER TO ALLEGATIONS 1. In response to Paragraph 1 of the AC, the Defendant denies knowledge or information sufficient to form a belief as to the truthfulness of the assertions set forth therein regarding the ownership of the alleged apartment building or its recordation, and further states that no response is required as to the documents referenced in Paragraph 1, which speak for themselves. 2. In response to Paragraph 2 of the AC, the Defendant denies knowledge or information sufficient to form a belief as to the truthfulness of the assertions set forth 1

therein regarding the Plaintiff s alleged actions and intentions, including, those concerning the filings of liens alleged in Paragraph 2, and otherwise denies all other allegations contained in that paragraph. 3. In response to Paragraphs 3-9, 11-14, 20, 26-28, 30, 34-35, 37, 39, 45, 51, 55 56, 58, 60, 66, 69, 73, 75 76 of the AC, the Defendant denies knowledge or information sufficient to form a belief as to the truthfulness of the assertions set forth in those paragraphs. 4. In response to Paragraph 10 of the AC, the Defendant admits that 624 Art Holdings LLC is a New York limited liability company, and that it holds a judgment against Berry-Hill Galleries, Inc., as well as the company s principal, James Hill; denies all other allegations contained in Paragraph 10, and further states that it holds a valid and enforceable judgment lien on all real and personal property owned by James Hill and Berry-Hill Galleries, Inc. 5. In response to Paragraph 21 of the AC, the Defendant admits that it is a judgment creditor of Berry-Hill Galleries, Inc. and that it has an interest in the alleged property; the Defendant denies knowledge or information sufficient to form a belief as to the truthfulness of the remaining allegations contained in Paragraph 21. 6. In response to Paragraphs 17, 18, 22, 38, 40, 59, and 61 of the AC, the Defendant denies knowledge or information sufficient to form a belief as to the truthfulness of the assertions set forth therein, and further states that no response is required as to the documents referenced in those paragraphs, which speak for themselves. 7. In response to Paragraph 23-25, 32, 33, 41, 46, 53 54, 62, 67, and 77 of the AC, the Defendant denies knowledge or information sufficient to form a belief as to the truthfulness of the assertions set forth therein regarding the various provisions of the alleged Condominium s By-Laws and Rules and Regulations, and further states that no response is required as to any of the documents referenced in those paragraphs, which speak for themselves. 2

8. Paragraph 19 of the AC does not require a response; to the extent that a response is required, the Defendant admits that a document purporting to be a deed is attached to the AC as Exhibit B, and denies all other allegations contained in this paragraph. 9. The allegations set forth in Paragraphs 15, 16, 31, 36, 42-44, 48, 52, 57, 63 65, 70 and 74 of the AC comprise legal conclusions and are therefore respectfully referred to the Court for its deliberations upon a full and complete record; to the extent a response is required to any purported factual allegations in the aforesaid paragraphs, they are denied. 10. In response to Paragraphs 29, 50, and 71 of the AC, the Defendant repeats, re-alleges, and incorporates by reference, each and every one of its responses to the paragraphs numerically preceding them. 11. In response to Paragraph 72 of the AC, the Defendant denies all allegations contained therein with respect to the Defendant, and denies knowledge or information sufficient to form a belief as to the truthfulness of all other assertions set forth therein. 12. In response to Paragraphs 47 and 68 of the AC, the Defendant denies that any interests, claims or liens of 624 Art Holdings, LLC in connection with the alleged real property units are subordinate to the alleged liens, and denies knowledge or information sufficient to form a belief as to the truthfulness of all other assertions set forth therein; the Defendant further states that Defendant is entitled to the proceeds, in whole or in part, from the sale of the subject property in order to satisfy its judgment lien. 13. In responding to Paragraphs 49, 78 and the Wherefore clause of the AC, the Defendant denies that the Plaintiff is entitled to judgment in its favor or for any relief whatsoever, including the relief requested in Paragraphs 49, 78 and in the "Wherefore" clause of the AC. 14. The Defendant denies each and every allegation set forth in the AC that is not otherwise expressly addressed herein. 3

AFFIRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE The AC fails to state a claim, in whole or in part, upon which relief can be granted. SECOND AFFIRMATIVE DEFENSE The Plaintiff s claims are barred by the doctrines of waiver and estoppel, and/or by other equitable doctrines. THIRD AFFIRMATIVE DEFENSE The Plaintiff s claims are barred by the doctrine of unclean hands. FOURTH AFFIRMATIVE DEFENSE The Plaintiff s claims are barred by the applicable statute of limitations. FIFTH AFFIRMATIVE DEFENSE The Plaintiff s claims are barred, in whole or in part, due to the Plaintiff s failure to mitigate the damages alleged in the AC. SIXTH AFFIRMATIVE DEFENSE The Plaintiff s claims are barred, in whole or in part, because the AC fails to establish that the Plaintiff suffered any actual damages. SEVENTH AFFIRMATIVE DEFENSE One or more of the Plaintiff s claims are barred, in whole or in part, due to of accord and satisfaction of the alleged debt. EIGHTH AFFIRMATIVE DEFENSE One or more of the Plaintiff s claims are barred, in whole or in part, by reason of the Plaintiff s failure to perform in accordance with alleged contract. NINTH AFFIRMATIVE DEFENSE The Plaintiff would be unjustly enriched if its claims are successful. TENTH AFFIRMATIVE DEFENSE The Plaintiff s claims are barred by Plaintiff s lack of standing because Plaintiff was not the legal owner of the Note and/or Mortgage at the time it commenced this foreclosure lawsuit. 4

ELEVENTH AFFIRMATIVE DEFENSE Plaintiff s claims are barred, in whole or in part, inasmuch as Plaintiff s demands for interest are usurious and violate state and federal laws. TWELFTH AFFIRMATIVE DEFENSE Plaintiff failed to deliver the necessary pre-foreclosures notices prior to filing this lawsuit. THIRTEENTH AFFIRMATIVE DEFENSE Plaintiff has failed to name all necessary parties. FOURTEENTH AFFIRMATIVE DEFENSE Plaintiff s claims are barred because its interests, claims or liens, if any, are subordinate to the Defendant s interest, claims and liens in the real property at issue in the AC. FIFTEENTH AFFIRMATIVE DEFENSE The Defendant is entitled to the proceeds, in whole or in part, from the sale of the subject property in order to satisfy its judgment lien. RESERVATION OF RIGHTS The Defendant reserves the right to assert any additional and further defenses as may be revealed in discovery or otherwise. PRAYER FOR RELIEF WHEREFORE, the Defendant respectfully requests that this Court enter a judgment against the Plaintiff, granting the following relief: 1) That the AC be dismissed with prejudice; 2) That the Defendant be awarded attorney's fees, costs and applicable interest; and 3) Whatever other and further relief the Court deems just and proper. 5

Dated: New York, New York July 7, 2015 Eleonora Zlotnikova Attorneys for Defendant 624 Art Holdings, LLC 1 Liberty Plaza-Thirty Fifth Floor New York, New York 10006 T: (646) 787-9880 I F: (646) 787-9886 E: elzlotnikova@spi-pc.com 6