Preview
FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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WASHINGTON AVENUE OWNER LLC, Index No.:
921 WASHINGTON AVENUE LLC,
941 WASHINGTON AVENUE LLC, SUMMONS
Plaintiffs,
Plaintiffs Designate Kings County as
-against- the place for trial.
SENTINEL REAL ESTATE CORPORATION, The basis for venue is
NEWCASTLE REALTY SERVICES, LLC, CPLR §503(a) and §507.
WASHINGTON 921 LIMITED PARTNERSHIP,
WASHINGTON 941 LIMITED PARTNESHIP,
Defendants.
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TO THE ABOVE NAMED DEFENDANTS
YOU ARE HEREBY SUMMONED to answer the Complaint in this action in the Supreme Court
of the State of New York, County of Kings, at the Office of the Clerk of the said Court at 360
Adams Street, Brooklyn, NY 11201, and to serve a copy of your Answer on the Plaintiffs’ attorney
within the time provided by law as noted below and to interpose an Answer within twenty (20)
days after service of this Summons, exclusive of the day of service (or within thirty (30) days after
the service is complete if this Summons is not personally delivered to you within the State of New
York); and in case of your failure to appear or answer, judgment will be taken against you by
default for the relief demanded in the Complaint.
Dated: Bronx, New York JASON D. BOROFF & ASSOCIATES, P.L.L.C.
June 24, 2024 Attorneys for Plaintiffs
_______________________________________
By: David S. Lee
349 East 149th Street, Suite 703
Bronx, NY 10451
(718) 475-7888
dlee@borofflaw.com
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Defendants’ Addresses:
Sentinel Real Estate Corporation Sentinel Real Estate Corporation
c/o Corporation Service Company 1251 Avenue of the Americas, 35th Floor
80 State Street New York, NY 10020
Albany, NY 12207
Newcastle Realty Services, LLC
c/o Smallbiz Agents
1710 First Ave, #121
New York, NY 10128
Washington 921 Limited Partnership
c/o Sentinel Real Estate Corporation
1251 Avenue of the Americas, 36th Floor
New York, NY 10020
Washington 941 Limited Partnership
c/o Sentinel Real Estate Corporation
1251 Avenue of the Americas, 36th Floor
New York, NY 10020
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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WASHINGTON AVENUE OWNER LLC,
921 WASHINGTON AVENUE LLC,
941 WASHINGTON AVENUE LLC,
Index No.:
Plaintiffs,
VERIFIED COMPLAINT
-against-
SENTINEL REAL ESTATE CORPORATION,
NEWCASTLE REALTY SERVICES, LLC,
WASHINGTON 921 LIMITED PARTNERSHIP,
WASHINGTON 941 LIMITED PARTNESHIP,
Defendants.
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WASHINGTON AVENUE OWNER LLC, 921 WASHINGTON AVENUE LLC, and 941
WASHINGTON AVENUE LLC (collectively referred to as “Plaintiffs”) by and through their
attorneys, Jason D. Boroff & Associates, P.L.L.C., as and for its Complaint against Defendants
SENTINEL REAL ESTATE CORPORATION (“Sentinel”), NEWCASTLE REALTY
SERVICES, LLC (“Newcastle”), WASHINGTON 921 LIMITED PARTNERSHIP and
WASHINGTON 941 LIMITED PARTNERSHIP (collectively referred to as “Washington”),
alleges as follows:
THE PARTIES
1. Washington Avenue Owner LLC is a New York limited liability company and its
principal place of business is 276 Fifth Avenue, Suite 900, New York, NY 10001.
2. 921 Washington Avenue LLC is a New York limited liability company and its
principal place of business is 276 Fifth Avenue, Suite 900, New York, NY 10001.
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3. 941 Washington Avenue LLC is a New York limited liability company and its
principal place of business is 276 Fifth Avenue, Suite 900, New York, NY 10001.
4. Sentinel is a corporation organized and existing under the laws of the State of New
York. Sentinel’s principal place of business is 1251 Avenue of the Americas, 35th Floor, New York,
New York 10020.
5. Newcastle Realty Services, LLC (“Newcastle”) is a New York limited liability
company which was voluntarily dissolved on or about July 12, 2022. Its address is c/o Smallbiz
Agents, 1710 First Ave #121, New York, NY 10128.
6. Washington 921 Limited Partnership is an inactive limited partnership, organized
under the laws of the State of Delaware with a registered address of 251 Little Falls Drive,
Wilmington, DE 19808. The service of process address that is on file with the New York State
Secretary of State is 1251 Avenue of the Americas, 36th Floor, New York, NY 10020.
7. Washington 941 Limited Partnership is an inactive limited partnership, organized
under the laws of the State of Delaware with a registered address of 251 Little Falls Drive,
Wilmington, DE 19808. The service of process address that is on file with the New York State
Secretary of State is 1251 Avenue of the Americas, 36th Floor, New York, NY 10020.
JURISDICTION AND VENUE
8. The Court has jurisdiction over this action pursuant to CPLR §503(a) and §507 as
the real properties at issue are located in Kings County, which is where the events giving rise to
the claims occurred.
THE PLAINTIFFS AND CHAIN OF TITLE
9. Washington Avenue Owner LLC is the owner of the real properties commonly
known as 921 Washington Avenue, Brooklyn, NY 11225 (the “921 Building”), and 941
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Washington Avenue, Brooklyn, NY 11225 (the “941 Building”). Plaintiff took title to the 921
Building and the 941 Building by a Bargain and Sale Deed dated December 14, 2023, which was
duly recorded with the Office of the City Register of the City of New York on February 5, 2024,
under CRFN 2024000031333 for the 921 Building, and CRFN 2024000031334 for the 941
Building.
10. Prior to the aforementioned transfer of title, on February 28, 2018, 921 Washington
Avenue LLC and 941 Washington Avenue LLC purchased the 921 Building and the 941 Building
from Sentinel and its affiliates. 921 Washington Avenue LLC was the owning entity of the 921
Building; and 941 Washington Avenue LLC was the owning entity of the 941 Building.
11. Gregory Jones and Graham Jones are members and officers of both 921 Washington
Avenue LLC and 941 Washington Avenue LLC. Gregory Jones and Graham Jones are also
members and officers of Washington Avenue Owners LLC.
12. In late 2023, 921 Washington Avenue LLC and 941 Washington Avenue LLC
sought to refinance and restructure the respective loans for the 921 Building and the 941 Buildings.
The lending bank however, required one owning entity for both buildings. Accordingly, 921
Washington Avenue LLC and 941 Washington Avenue LLC deeded the 921 Building and the 941
Building to Washington Avenue Owner LLC as the single owning entity. The members, officers,
and principal place of business of all three entities remain the same.
13. Gregory Jones’ signature – as the authorized signatory – appears on the following
recorded documents:
i. The mortgage given by 921 Washington Avenue LLC on February 28, 2018 when it
purchased the 921 Building;
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ii. The mortgage given by 941 Washington Avenue LLC on February 28, 2018 when it
purchased the 941 Building;
iii. The deeds, dated December 14, 2023, transferring ownership from 921 Washington
Avenue LLC and 941 Washington Avenue LLC to Washington Avenue Owner LLC;
iv. The GAP Multifamily Mortgage, as well as the Consolidation, Extension and
Modification Agreement given by Washington Avenue Owner LLC to the lending bank
when Plaintiff took title to the 921 Building and the 941 Building; and
v. The Assignment and Assumption Agreement wherein Gregory Jones is the authorized
signatory for Washington Avenue Owner LLC, as well as 921 Washington Avenue LLC
and 941 Washington Avenue LLC.
14. Plaintiffs have been aggrieved and injured by Defendants’ fraudulent scheme –
succinctly, all three Plaintiffs are victims of Defendant’s vast and unlawful enterprise to
fraudulently deregulate apartments in order to increase the rent roll and valuation of buildings.
The logic being that free market units yield higher rents as they are no longer relegated to rent
regulation which in turn increases the value of a building.
15. These fraudulent deregulations occurred in numerous apartments within the 921
Building and the 941 Building. Defendants then marketed and sold the 921 Building for Thirty-
Three Million Two Hundred Thousand and 00/100’s ($33,200,000.00) Dollars, and the 941
Building for Twenty Million Fifty Thousand and 00/100’s ($20,050,000.00) Dollars to Plaintiffs.
It must be noted that Sentinel and Washington 921 Limited Partnership purchased the 921 Building
for Fifteen Million One Hundred Thousand and 00/100’s ($15,100,000.00) Dollars in December
2007; and Sentinel and Washington 941 Limited Partnership purchased the 941 Building for Seven
million Eight Hundred Thousand and 00/100’s ($7,800,000.00) Dollars, also in December 2007.
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16. As a result of Defendants’ fraudulent deregulations, the sales price of the 921
Building and the 941 Building more than doubled from the time Sentinel purchased them.
17. The fraudulent deregulation caught the New York State Attorney General’s
(“OAG”) attention which resulted in an investigation into Defendants’ unlawful enterprise; which
in turn resulted in Defendants’ settlement with the OAG; and in turn resulted in Plaintiffs having
to comply with the OAG’s investigation and re-regulate numerous apartments in the 921 Building
and the 941 Building. Said re-regulation of numerous apartments deflated the value of the 921
Building, as well as the 941 Building.
18. As a result of Defendants’ fraudulent deregulations, Plaintiff commences this action
for fraud and fraudulent inducement, which is supported by the OAG’s findings and Sentinel’s
settlement with the OAG that is detailed in Assurance of Discontinuance 21-053.
THE FRAUDULENT SCHEME TO DEREGULATE
AND THE ASSURANCE OF DISCONTINUANCE 21-053
19. The fraudulent scheme to deregulate was perpetrated by Sentinel and its affiliates
as follows: Sentinel fraudulently deregulated units by inflating renovation costs in the 921 Building
and the 941 Building to remove apartments from New York’s rent regulation laws, and to treat
them as free market units thereby increasing the rent rolls and respective valuation of the 921
Building and the 941 Building.
20. The fraudulent scheme was carried out by Defendants in the following manner:
When Sentinel acquired a building, Margaret Streicker Porres and her employees, Michael
Zauberman and David Drumheller 1 (employees and agents of Newcastle), met with Sentinel to
discuss how they would spend only what was necessary to take paired or packaged units out of
1
The New York State Attorney General commenced an action against David Drumheller alleging unlawful and
fraudulent deregulation under index number 450792/2019
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rent stabilization. This means that they would group units together so that renovation costs could
be shared between and among units. Upon information and belief, Margaret Streicker Porres was
responsible for “packaging” the units and assigning the work to contractors which was a critical
aspect of the fraud that Defendants perpetrated against Plaintiffs.
21. To reiterate, Sentinel’s fraudulent manner of unlawfully enhancing property values
triggered an investigation by the OAG. Said fraudulent manner of enhancing property values are,
inter alia, illegally removing units from rent-regulation, thereby purportedly increasing the market
value of the building, and then selling those buildings to innocent purchasers such as Plaintiffs.
22. OAG found that property manager, Newcastle, as agent of owners, “violated the
law and rent regulations, by among other things, soliciting kickbacks from contractors and
assigning false costs to contract labor associates with Gotham IAI’s” (AOD 21-053 at p. 4)
(Gotham is the name of funds that held the subject properties). The OAG not only required
Sentinel and its affiliates to audit their units across their New York portfolio and re-stabilize
apartments which were represented as deregulated, but also required a settlement payment of Four
Million and 00/100’s ($4,000,000.00) Dollars to a tenant protection fund. However, Plaintiffs
remains damaged as a result of Sentinel’s fraudulent scheme as the settlement payment did not
recompence Plaintiffs.
23. On or about July 7, 2022, the OAG entered into Assurance of Discontinuance 21-
053 (“AOD 21-053”) with Sentinel and its affiliates. AOD 21-053 is signed by Connell J. Watters 2,
who is listed on Sentinel’s webpage as a “Senior Vice President” and paragraph sixty-three of AOD
21-053 states:
63. The Respondents represent and warrant, through the signatures below,
that the terms and conditions of this Assurance are duly approved.
Respondents further represent and warrant that Connell J. Watters, as
2
https://www.sentinelcorp.com/management-team.aspx
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the signatory to this Assurance, is a duly authorized officer acting at
the direction of the Boards of Directors of Respondents.
24. In relevant part, the OAG made the below findings:
7. In addition to routine property management functions and rent regulatory
compliance functions, Newcastle and Highcastle advised on and carried out
capital expenditures in each building in the Funds and owned by certain of
the Respondents.
8. In this vein, one of Newcastle's and Highcastle's responsibilities was
planning and overseeing Individual Apartment Improvements ("IAI’s") to
rent regulated apartments.
9. In exchange for its services, Newcastle and Highcastle received a
monthly property management fee equivalent to five percent of the relevant
building's monthly income. In addition, Respondents paid Newcastle and
Highcastle a bonus of $5,000 for certain apartments that underwent an IAI
pursuant to various agreements entered into from time to time.
10. As detailed below, the OAG has determined that Newcastle and
Highcastle violated the law and rent regulations by, among other things,
soliciting kickbacks from contractors and assigning false costs to contract
labor associated with Gotham IAI’s. The OAG has also determined that
Respondents' oversight was insufficient to detect or prevent Newcastle and
Highcastle's misconduct.
***
C. False Costs Attributed to IAI’S
22. From in and around 2008 to in and around 2016, Newcastle and
Highcastle violated rent regulation by assigning false costs to
contractor labor-and, in certain instances, window installation-
associated with Gotham I IAI’s. Newcastle and Highcastle used those
costs as a basis for raising rents, including rents that exceeded the
applicable deregulation thresholds.
23. These false costs fell into the following three categories: (i) costs that
were "fixed," or pre-determined, by Newcastle and Highcastle; (ii) costs
that were falsely inflated or deflated because they were not wholly
attributable to the apartment being renovated; and (iii) costs that were
inflated because they included false change orders and/or included
kickbacks to Newcastle and Highcastle employees and agents.
i. Predetermined Labor Costs
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24. For certain renovations, Newcastle and Highcastle predetermined the
prices they were willing to pay for labor towards a renovation project
without any competitive bidding and without considering the actual cost of
the labor.
25. Newcastle and Highcastle repeatedly and persistently set the price of
labor to the amount necessary to deregulate a unit. While "hard" costs, such
as materials and supplies, were not impacted, the cost of labor varied
dramatically from apartment to apartment and renovation to
renovation, even when the actual work performed by the contractor
and time spent laboring in the unit was roughly equivalent.
26. Newcastle and Highcastle repeatedly set the price of labor before
even determining a scope of work or inviting a contractor to take a job.
Once invited, Newcastle and Highcastle told the contractor the price it
would pay for the job--regardless of the price the contractor would have bid
for the job and often without the contractor even seeing the apartment.
These costs did not necessarily change based on the renovation needs for a
given apartment.
27. The labor price fixed for a job often had nothing to do with the size
of the apartment. Thus, in 2012 Newcastle set the price of renovation of
two similar one-bedroom apartments in the same building and on the
same line at $52,500 and $38,000. There was no material difference in
the contractor's scope of work; rather, the apartments had different
legal regulated rents, and the former required more than $14,000 extra
by way of IAI to push the rent to the deregulation threshold.
(A copy of AOD 21-053 is annexed herein as Exhibit A.)
25. Before the Housing Stability and Tenant Protection Act of 2019 (“HSTPA”)
changed the law to eliminate IAI’s on or about June 14, 2019, "high rent vacancy decontrol"
occurred when, upon vacancy of the prior tenant of a rent-stabilized apartment, the monthly legal
regulated rent for the apartment reached a threshold value set by the RSL (hereinafter "deregulation
threshold"). RSL § 26-504.2.
26. During the period in which the respondents in the OAG action acquired and sold
buildings, the deregulation threshold ranged from $2,000 (June 19, 1997 to June 23, 2011); to
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$2,500.00 (June 24, 2011 to June 14, 2015); $2,700.00 (June 15, 2015 to December 31, 2017; and
$2,733.75 (January 1, 2018 to December 31, 2018).
27. The IAI’s played a direct role in Sentinel and its affiliate’s investment strategy.
From in or around 2008 to in or around 2016, Sentinel’s strategy for its portfolio included investing
in apartment renovations in order to use IAI’s as a mechanism to increase the legal regulated rents
of stabilized units and then remove them from rent regulation pursuant to high rent decontrol. At
the time, Newcastle was awarded incentive "deregulation" bonuses by Sentinel if they invested
sufficient funds into a unit to remove it from rent regulation.
28. The OAG found violations of rent regulations through 2016. Sentinel and its
affiliates neither admitted nor denied that finding in the AOD 21-053, but the fact that the OAG
made such findings; and the fact that Sentinel settled rather than face and defend an action by the
OAG must be taken into account. Indeed, Four Million and 00/100’s ($4,000,000.00) Dollars is
a lofty price to pay if innocent; and upon information and belief, Sentinel paid Four Million
and 00/100’s Dollars ($4,000,000.00) to the “Affordable Housing Fund” with the New York
City Department of Housing Preservation and Development (HPD).
29. On August 23, 2022, pursuant to the findings by the OAG which is set forth in AOD
21-053, the OAG issued a press release 3 with the headline: “Attorney General James Secures $4
Million from Landlords After Uncovering an Illegal Kickback Scheme to Deregulate Rent-
Stabilized Apartments.”
30. The Four Million and 00/100’s Dollar ($4,000,000.00) settlement amount pales
in comparison to the damage Plaintiffs suffered as a result of Defendants’ fraudulent scheme
to deregulate. Hence Sentinel has not been held accountable to the degree that it profited
3
https://ag.ny.gov/press-release/2022/attorney-general-james-secures-4-million-landlords-after-uncovering-illegal
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from the fraud it committed, but rather, Sentinel continues to reap the benefits of fraud as it
pocketed money from an exaggerated sales price of the 921 Building and the 941 Building.
Consider that in less than eleven (11) years, from when Sentinel and its affiliates bought the
921 Building and the 941 Building in December 2007, the valuation more than doubled (as a
result of their fraud) in February 2018 when Plaintiffs bought the Buildings.
31. It is also submitted that Plaintiffs would not have purchased the 921 Building and/or
the 941 Building if the number of deregulated apartments were less than what Sentinel and its
affiliates represented. Indeed, Brian Ritter, Sentinel’s Managing Director signed the deed of sale
for the 921 Building and the 941 Building, and also provided Plaintiffs with affidavits attesting to
the legal rents that we now know were fraudulently increased. (A copy of Brian Ritter’s Affidavits
for the 921 Building are annexed herein as Exhibit B, and a copy of Mr. Ritter’s Affidavits for the
941 Building are annexed herein as Exhibit C.)
32. Just as the Sentinel affiliated entities that were named in AOD 21-053 have been
dissolved, Washington 921 Limited Partnership and Washington 941 Limited Partnership are also
dissolved. It is submitted that Sentinel dissolved those entities without making provisions for
known potential claims by purchasers in the face of the widespread fraud it, and its affiliates
committed, to avoid liability to unsuspecting purchasers such as Plaintiffs. Under these
circumstances, the certification of cancellation of the dissolved entities should be nullified and the
entities revived because Sentinel did not set aside reserves. In addition, Sentinel exercised
dominance and control over the entities named in AOD 21-053, just as Sentinel exercised dominion
and control over Washington 921 Limited Partnership, Washington 941 Limited Partnership, and
Newcastle.
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33. As a matter of law, as well as public policy and equity, Sentinel and its affiliates
must not be allowed to benefit from its unlawful enterprises.
THE RELATIONSHIP AND CONNECTION BETWEEN THE DEFENDANTS
HEREIN AND ALL TWENTY-NINE (29) ENTITIES NAMED IN AOD 21-053
34. John H. Streicker was the Chairman and Founder of Sentinel.
35. Michael F. Streicker, the son of John Streicker, is the President of Sentinel.
36. Margaret Streicker Porres, the daughter of John Streicker, founded Newcastle in
2004.
37. The 921 Building and 941 Building were both managed by Newcastle from in or
about 2008 to in or about 2016.
38. Defendant Washington 921 Limited Partnership LP was incorporated in the State
of Delaware with a registered address of 251 Little Falls Drive, Wilmington, DE 19808; and its
phone number is (302) 636-5401. When it took title to the 921 Building on December 12, 2007,
the UCC Financing Statement 4 that was filed sets forth Washington 921 Limited Partnership’s
mailing address as: “c/o Sentinel Real Estate Corp., 1251 Avenue of the Americas.” 5
39. Moreover, the deed of sale 6 from Washington 921 Limited partnership to 921
Washington Avenue LLC was signed by Brian Ritter, who is Sentinel’s Managing Director 7 and
responsible for portfolio management of several of Sentinel's commingled funds and separate
accounts, as well as asset management for Sentinel's New York City portfolio.
4
The UCC Financing Statement was recorded with the City of New York, Office of the Register on October 14, 2010,
under CRFN 2010000343986.
5
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2010101300491003
6
The deed was recorded with the City of New York, Office of the Register on March 22, 2018, under CRFN
2018000097140.
7
https://www.sentinelcorp.com/brian-ritter.aspx
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40. Defendant Washington 941 Limited Partnership LP was incorporated in the State
of Delaware with a registered address of 251 Little Falls Drive, Wilmington, DE 19808; and its
phone number is (302) 636-5401. The deed of sale from Washington 941 Limited Partnership to
921 Washington Avenue LLC was signed by Brian Ritter, who is Sentinel’s Managing Director. 8
41. With respect to the twenty-nine (29) entities the OAG named in AOD 21-053, their
connection to Sentinel is irrefutable and evidences a modus operandi pattern of fraud:
i. Gotham City Residential Manager I, LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel:
1251 Avenue of the Americas, 35th Floor, New York, NY 10020.
ii. Gotham City Residential Manager II, LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel:
1251 Avenue of the Americas, 35th Floor, New York, NY 10020.
iii. Gotham City Residential Advisors II, LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel:
1251 Avenue of the Americas, 35th Floor, New York, NY 10020.
iv. Gotham Segregated Account GP I, LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel:
1251 Avenue of the Americas, 35th Floor, New York, NY 10020.
v. Gotham Segregated Account Manager I, LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel:
1251 Avenue of the Americas, 35th Floor, New York, NY 10020.
vi. Hygrocybe 1115 Union GP V, LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
8
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2018030601439002
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- See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel:
1251 Avenue of the Americas, 35th Floor, New York, NY 10020.
vii. Hygrocybe Manager V, LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel:
1251 Avenue of the Americas, 35th Floor, New York, NY 10020.
viii. Tarzetta Catinus LP
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel:
1251 Avenue of the Americas, 35th Floor, New York, NY 10020.
ix. 5008 Broadway LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- GAP Mortgage dated July 21, 2015, is signed by Brian Kraut 9, Senior Vice President of Sentinel.
- Assignment of Leases dated July 21, 2015, is signed by Brian Kraut.
- The July 21, 2015 UCC-1 shows a mailing address of: “c/o Newcastle Realty, 270 Madison
Avenue 19th Floor.”
- Deed of sale dated April 27, 2023, is signed by Brian Ritter, Managing Director of Sentinel.
x. 658 West 188th Street LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- GAP Mortgage dated July 21, 2015, is signed by Brian Kraut, Senior Vice President of Sentinel.
- Assignment of Leases dated July 21, 2015, is signed by Brian Kraut.
- The UCC Financing Statement dated February 15, 2019 contains a mailing address of: “c/o
Sentinel Real Estate Corporation, 1251 Avenue of the Americas.”
- Deed of sale dated August 30, 2023, is signed by Brian Ritter, Managing Director of Sentinel.
xi. 80 Clarkson LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- GAP Mortgage dated October 30, 2015, is signed by Brian Kraut, Senior Vice President of
Sentinel.
- Assignment of Rents dated October 30, 2015, is signed by Brian Kraut.
- Deed of sale dated January 23, 2024, is signed by Brian Ritter, Managing Director of Sentinel.
xii. 92 Pinehurst Avenue LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- Mortgage dated February 15, 2019, is signed by Brian Kraut, Senior Vice President of Sentinel.
9
https://www.sentinelcorp.com/management-team.aspx
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- Assignment of Rents dated February 15, 2019, is signed by Brian Kraut.
- The UCC Financing Statement dated February 15, 2019 contains a mailing address of: “c/o
Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.”
- Deed of sale dated August 30, 2023, is signed by Brian Ritter, Managing Director of Sentinel.
xiii. 3100 Brighton 2nd Street LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- Assumption of Mortgage dated August 30, 2016, is signed by Brian Ritter, Managing Director of
Sentinel.
- Assignment of Leases dated August 30, 2016, is signed by Brian Ritter.
- Mortgage Modification Agreement dated February 26, 2020, are signed by Brian Kraut, Senior
Vice President of Sentinel.
- As per the HPD registration, William Freydberg is the head officer of 1803 Beverly Road LLC.
Mr. Freydberg’s address is the same as Sentinel’s (1251 Ave Of The Americas, 35 FL, New York,
NY 10020), and he is listed on Sentinel’s website as a Senior Vice President of Sentinel 10.
xiv. Brightwater 219 LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- Assumption of Mortgage dated August 30, 2016, is signed by Brian Ritter, Managing Director of
Sentinel.
- Assignment of Leases dated August 30, 2016, is signed by Brian Ritter.
- Mortgage Modification dated March 31, 2020, is signed by Brian Kraut, Senior Vice President
of Sentinel.
- As per the HPD registration, Leland Roth is the head officer of Brightwater 219 LLC. Mr. Roth’s
address is the same for Sentinel (1251 Ave Of The Americas, 35 FL, New York, NY 10020), and
he is listed on Sentinel’s website as the Chief Financial Officer 11.
xv. Brightwater 231 LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- Assumption of Mortgage dated August 30, 2016, is signed by Brian Ritter, Managing Director of
Sentinel.
- Assignment of Leases dated August 30, 2016, is signed by Brian Ritter.
- Mortgage Modification dated February 26, 2020, is signed by Brian Kraut, Senior Vice President
of Sentinel.
- As per the HPD registration, Leland Roth is the head officer of Brightwater 231 LLC. Mr. Roth’s
address is the same for Sentinel (1251 Ave Of The Americas, 35 FL, New York, NY 10020), and
he is listed on Sentinel’s website as the Chief Financial Officer.
xvi. 66 St. Nicholas Place LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
10
https://www.sentinelcorp.com/management-team.aspx
11
https://www.sentinelcorp.com/leland-j-roth.aspx
16 of 30
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- Mortgage dated December 19, 2018, is signed by Brian Kraut, Senior Vice President of Sentinel.
- The UCC Financing Statement dated February 15, 2019 contains a mailing address of: “c/o
Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.”
- As per HPD, Brian Ritter, Managing Director of Sentinel, is the head officer of 66 St. Nicholas
Place LLC. Mr. Ritter’s address is the same as Sentinel’s: 1251 6th Avenue, New York, NY 10020).
xvii. 75 St. Nicholas Place LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- The UCC Financing Statement dated December 19, 2018, contains a mailing address of: “c/o
Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.”
- As per HPD, Brian Ritter, the Managing Director of Sentinel, is the head officer of 75 St. Nicholas
Place LLC. Mr. Ritter’s address is the same as Sentinel’s: 1251 6th Avenue New York, NY 10020).
xviii. 76 St. Nicholas Place LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- Mortgage dated December 19, 2018, is signed by Brian Kraut, Senior Vice President of Sentinel.
- The UCC Financing Statement dated December 19, 2018, contains a mailing address of: “c/o
Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.”
- As per HPD, Brian Ritter, the Managing Director of Sentinel, is the head officer of 76 St. Nicholas
Place LLC. Mr. Ritter’s address is the same as Sentinel’s: 1251 6th Avenue New York, NY 10020.
xix. 853 St. Nicholas Avenue LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- The UCC Financing Statement dated December 19, 2018, contains a mailing address of: “c/o
Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.”
- Mortgage dated December 19, 2018, is signed by Brian Kraut, Senior Vice President of Sentinel.
- As per HPD, Brian Ritter, the Managing Director of Sentinel, is the head officer of 853 St.
Nicholas Place LLC. Mr. Ritter’s address is the same as Sentinel’s: 1251 6th Avenue, New York,
NY 10020).
xx. 79 Brighton 11th Street LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- As per the HPD registration, Leland Roth is the head officer of 79 Brighton 11th Street LLC. Mr.
Roth’s address is the same as Sentinel’s (1251 Ave Of The Americas, 35 FL, New York, NY
10020), and he is listed on Sentinel’s website as the Chief Financial Officer.
xxi. 125 Brighton 11th Street LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- Mortgage dated January 15, 2014, is signed by Brian Kraut, Senior Vice President of Sentinel.
17 of 30
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- As per the HPD registration, Leland Roth is the head officer of 125 Brighton 11th Street LLC.
Mr. Ritter’s address is the same as Sentinel’s (1251 Ave Of The Americas, 35 FL, New York, NY
10020), and he is listed on Sentinel’s website as the Chief Financial Officer.
xxii. 1511-1521 Brightwater Avenue LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- Mortgage dated January 15, 2014, is signed by Brian Kraut, Senior Vice President of Sentinel.
- Consolidation and Extension Agreement dated January 15, 2014, is signed by Brian Kraut.
- The UCC Financing Statement dated December 19, 2018, contains a mailing address of: “c/o
Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.”
- As per the HPD registration, Brian Kraut is the head officer of 1511-1521 Brightwater Avenue
LLC. Mr. Kraut’s address is the same as Sentinel’s (1251 Ave Of The Americas, 35 FL, New York,
NY 10020), and he is listed on Sentinel’s website as the Chief Financial Officer.
xxiii. 120 East 19th Street GSA I LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- Mortgage dated December 19, 2018, is signed by Brian Kraut, Senior Vice President of Sentinel.
- Consolidation, Extension, and Modification Agreement dated December 19, 2018, is signed by
Brian Kraut.
- The UCC Financing Statement dated December 19, 2018, contains a mailing address of: “c/o
Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.”
- As per the HPD registration, Brian Kraut is the head officer of 120 East 19th Street GSA I LLC.
Mr. Kraut’s address is the same as Sentinel’s (1251 Ave Of The Americas, 35 FL, New York, NY
10020).
xxiv. 146 East 19th Street LLC
- Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE
19808; and the phone number is (302) 636-5401.
- Mortgage dated December 19, 2018, is signed by Brian Kraut, Senior Vice President of Sentinel.
- Consolidation, Extension, and Modification Agreement dated December 19,
Preview
FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------X WASHINGTON AVENUE OWNER LLC, Index No.: 921 WASHINGTON AVENUE LLC, 941 WASHINGTON AVENUE LLC, SUMMONS Plaintiffs, Plaintiffs Designate Kings County as -against- the place for trial. SENTINEL REAL ESTATE CORPORATION, The basis for venue is NEWCASTLE REALTY SERVICES, LLC, CPLR §503(a) and §507. WASHINGTON 921 LIMITED PARTNERSHIP, WASHINGTON 941 LIMITED PARTNESHIP, Defendants. --------------------------------------------------------------------X TO THE ABOVE NAMED DEFENDANTS YOU ARE HEREBY SUMMONED to answer the Complaint in this action in the Supreme Court of the State of New York, County of Kings, at the Office of the Clerk of the said Court at 360 Adams Street, Brooklyn, NY 11201, and to serve a copy of your Answer on the Plaintiffs’ attorney within the time provided by law as noted below and to interpose an Answer within twenty (20) days after service of this Summons, exclusive of the day of service (or within thirty (30) days after the service is complete if this Summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the Complaint. Dated: Bronx, New York JASON D. BOROFF & ASSOCIATES, P.L.L.C. June 24, 2024 Attorneys for Plaintiffs _______________________________________ By: David S. Lee 349 East 149th Street, Suite 703 Bronx, NY 10451 (718) 475-7888 dlee@borofflaw.com 1 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 Defendants’ Addresses: Sentinel Real Estate Corporation Sentinel Real Estate Corporation c/o Corporation Service Company 1251 Avenue of the Americas, 35th Floor 80 State Street New York, NY 10020 Albany, NY 12207 Newcastle Realty Services, LLC c/o Smallbiz Agents 1710 First Ave, #121 New York, NY 10128 Washington 921 Limited Partnership c/o Sentinel Real Estate Corporation 1251 Avenue of the Americas, 36th Floor New York, NY 10020 Washington 941 Limited Partnership c/o Sentinel Real Estate Corporation 1251 Avenue of the Americas, 36th Floor New York, NY 10020 2 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -----------------------------------------------------------------------X WASHINGTON AVENUE OWNER LLC, 921 WASHINGTON AVENUE LLC, 941 WASHINGTON AVENUE LLC, Index No.: Plaintiffs, VERIFIED COMPLAINT -against- SENTINEL REAL ESTATE CORPORATION, NEWCASTLE REALTY SERVICES, LLC, WASHINGTON 921 LIMITED PARTNERSHIP, WASHINGTON 941 LIMITED PARTNESHIP, Defendants. -----------------------------------------------------------------------X WASHINGTON AVENUE OWNER LLC, 921 WASHINGTON AVENUE LLC, and 941 WASHINGTON AVENUE LLC (collectively referred to as “Plaintiffs”) by and through their attorneys, Jason D. Boroff & Associates, P.L.L.C., as and for its Complaint against Defendants SENTINEL REAL ESTATE CORPORATION (“Sentinel”), NEWCASTLE REALTY SERVICES, LLC (“Newcastle”), WASHINGTON 921 LIMITED PARTNERSHIP and WASHINGTON 941 LIMITED PARTNERSHIP (collectively referred to as “Washington”), alleges as follows: THE PARTIES 1. Washington Avenue Owner LLC is a New York limited liability company and its principal place of business is 276 Fifth Avenue, Suite 900, New York, NY 10001. 2. 921 Washington Avenue LLC is a New York limited liability company and its principal place of business is 276 Fifth Avenue, Suite 900, New York, NY 10001. 3 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 3. 941 Washington Avenue LLC is a New York limited liability company and its principal place of business is 276 Fifth Avenue, Suite 900, New York, NY 10001. 4. Sentinel is a corporation organized and existing under the laws of the State of New York. Sentinel’s principal place of business is 1251 Avenue of the Americas, 35th Floor, New York, New York 10020. 5. Newcastle Realty Services, LLC (“Newcastle”) is a New York limited liability company which was voluntarily dissolved on or about July 12, 2022. Its address is c/o Smallbiz Agents, 1710 First Ave #121, New York, NY 10128. 6. Washington 921 Limited Partnership is an inactive limited partnership, organized under the laws of the State of Delaware with a registered address of 251 Little Falls Drive, Wilmington, DE 19808. The service of process address that is on file with the New York State Secretary of State is 1251 Avenue of the Americas, 36th Floor, New York, NY 10020. 7. Washington 941 Limited Partnership is an inactive limited partnership, organized under the laws of the State of Delaware with a registered address of 251 Little Falls Drive, Wilmington, DE 19808. The service of process address that is on file with the New York State Secretary of State is 1251 Avenue of the Americas, 36th Floor, New York, NY 10020. JURISDICTION AND VENUE 8. The Court has jurisdiction over this action pursuant to CPLR §503(a) and §507 as the real properties at issue are located in Kings County, which is where the events giving rise to the claims occurred. THE PLAINTIFFS AND CHAIN OF TITLE 9. Washington Avenue Owner LLC is the owner of the real properties commonly known as 921 Washington Avenue, Brooklyn, NY 11225 (the “921 Building”), and 941 4 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 Washington Avenue, Brooklyn, NY 11225 (the “941 Building”). Plaintiff took title to the 921 Building and the 941 Building by a Bargain and Sale Deed dated December 14, 2023, which was duly recorded with the Office of the City Register of the City of New York on February 5, 2024, under CRFN 2024000031333 for the 921 Building, and CRFN 2024000031334 for the 941 Building. 10. Prior to the aforementioned transfer of title, on February 28, 2018, 921 Washington Avenue LLC and 941 Washington Avenue LLC purchased the 921 Building and the 941 Building from Sentinel and its affiliates. 921 Washington Avenue LLC was the owning entity of the 921 Building; and 941 Washington Avenue LLC was the owning entity of the 941 Building. 11. Gregory Jones and Graham Jones are members and officers of both 921 Washington Avenue LLC and 941 Washington Avenue LLC. Gregory Jones and Graham Jones are also members and officers of Washington Avenue Owners LLC. 12. In late 2023, 921 Washington Avenue LLC and 941 Washington Avenue LLC sought to refinance and restructure the respective loans for the 921 Building and the 941 Buildings. The lending bank however, required one owning entity for both buildings. Accordingly, 921 Washington Avenue LLC and 941 Washington Avenue LLC deeded the 921 Building and the 941 Building to Washington Avenue Owner LLC as the single owning entity. The members, officers, and principal place of business of all three entities remain the same. 13. Gregory Jones’ signature – as the authorized signatory – appears on the following recorded documents: i. The mortgage given by 921 Washington Avenue LLC on February 28, 2018 when it purchased the 921 Building; 5 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 ii. The mortgage given by 941 Washington Avenue LLC on February 28, 2018 when it purchased the 941 Building; iii. The deeds, dated December 14, 2023, transferring ownership from 921 Washington Avenue LLC and 941 Washington Avenue LLC to Washington Avenue Owner LLC; iv. The GAP Multifamily Mortgage, as well as the Consolidation, Extension and Modification Agreement given by Washington Avenue Owner LLC to the lending bank when Plaintiff took title to the 921 Building and the 941 Building; and v. The Assignment and Assumption Agreement wherein Gregory Jones is the authorized signatory for Washington Avenue Owner LLC, as well as 921 Washington Avenue LLC and 941 Washington Avenue LLC. 14. Plaintiffs have been aggrieved and injured by Defendants’ fraudulent scheme – succinctly, all three Plaintiffs are victims of Defendant’s vast and unlawful enterprise to fraudulently deregulate apartments in order to increase the rent roll and valuation of buildings. The logic being that free market units yield higher rents as they are no longer relegated to rent regulation which in turn increases the value of a building. 15. These fraudulent deregulations occurred in numerous apartments within the 921 Building and the 941 Building. Defendants then marketed and sold the 921 Building for Thirty- Three Million Two Hundred Thousand and 00/100’s ($33,200,000.00) Dollars, and the 941 Building for Twenty Million Fifty Thousand and 00/100’s ($20,050,000.00) Dollars to Plaintiffs. It must be noted that Sentinel and Washington 921 Limited Partnership purchased the 921 Building for Fifteen Million One Hundred Thousand and 00/100’s ($15,100,000.00) Dollars in December 2007; and Sentinel and Washington 941 Limited Partnership purchased the 941 Building for Seven million Eight Hundred Thousand and 00/100’s ($7,800,000.00) Dollars, also in December 2007. 6 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 16. As a result of Defendants’ fraudulent deregulations, the sales price of the 921 Building and the 941 Building more than doubled from the time Sentinel purchased them. 17. The fraudulent deregulation caught the New York State Attorney General’s (“OAG”) attention which resulted in an investigation into Defendants’ unlawful enterprise; which in turn resulted in Defendants’ settlement with the OAG; and in turn resulted in Plaintiffs having to comply with the OAG’s investigation and re-regulate numerous apartments in the 921 Building and the 941 Building. Said re-regulation of numerous apartments deflated the value of the 921 Building, as well as the 941 Building. 18. As a result of Defendants’ fraudulent deregulations, Plaintiff commences this action for fraud and fraudulent inducement, which is supported by the OAG’s findings and Sentinel’s settlement with the OAG that is detailed in Assurance of Discontinuance 21-053. THE FRAUDULENT SCHEME TO DEREGULATE AND THE ASSURANCE OF DISCONTINUANCE 21-053 19. The fraudulent scheme to deregulate was perpetrated by Sentinel and its affiliates as follows: Sentinel fraudulently deregulated units by inflating renovation costs in the 921 Building and the 941 Building to remove apartments from New York’s rent regulation laws, and to treat them as free market units thereby increasing the rent rolls and respective valuation of the 921 Building and the 941 Building. 20. The fraudulent scheme was carried out by Defendants in the following manner: When Sentinel acquired a building, Margaret Streicker Porres and her employees, Michael Zauberman and David Drumheller 1 (employees and agents of Newcastle), met with Sentinel to discuss how they would spend only what was necessary to take paired or packaged units out of 1 The New York State Attorney General commenced an action against David Drumheller alleging unlawful and fraudulent deregulation under index number 450792/2019 7 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 rent stabilization. This means that they would group units together so that renovation costs could be shared between and among units. Upon information and belief, Margaret Streicker Porres was responsible for “packaging” the units and assigning the work to contractors which was a critical aspect of the fraud that Defendants perpetrated against Plaintiffs. 21. To reiterate, Sentinel’s fraudulent manner of unlawfully enhancing property values triggered an investigation by the OAG. Said fraudulent manner of enhancing property values are, inter alia, illegally removing units from rent-regulation, thereby purportedly increasing the market value of the building, and then selling those buildings to innocent purchasers such as Plaintiffs. 22. OAG found that property manager, Newcastle, as agent of owners, “violated the law and rent regulations, by among other things, soliciting kickbacks from contractors and assigning false costs to contract labor associates with Gotham IAI’s” (AOD 21-053 at p. 4) (Gotham is the name of funds that held the subject properties). The OAG not only required Sentinel and its affiliates to audit their units across their New York portfolio and re-stabilize apartments which were represented as deregulated, but also required a settlement payment of Four Million and 00/100’s ($4,000,000.00) Dollars to a tenant protection fund. However, Plaintiffs remains damaged as a result of Sentinel’s fraudulent scheme as the settlement payment did not recompence Plaintiffs. 23. On or about July 7, 2022, the OAG entered into Assurance of Discontinuance 21- 053 (“AOD 21-053”) with Sentinel and its affiliates. AOD 21-053 is signed by Connell J. Watters 2, who is listed on Sentinel’s webpage as a “Senior Vice President” and paragraph sixty-three of AOD 21-053 states: 63. The Respondents represent and warrant, through the signatures below, that the terms and conditions of this Assurance are duly approved. Respondents further represent and warrant that Connell J. Watters, as 2 https://www.sentinelcorp.com/management-team.aspx 8 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 the signatory to this Assurance, is a duly authorized officer acting at the direction of the Boards of Directors of Respondents. 24. In relevant part, the OAG made the below findings: 7. In addition to routine property management functions and rent regulatory compliance functions, Newcastle and Highcastle advised on and carried out capital expenditures in each building in the Funds and owned by certain of the Respondents. 8. In this vein, one of Newcastle's and Highcastle's responsibilities was planning and overseeing Individual Apartment Improvements ("IAI’s") to rent regulated apartments. 9. In exchange for its services, Newcastle and Highcastle received a monthly property management fee equivalent to five percent of the relevant building's monthly income. In addition, Respondents paid Newcastle and Highcastle a bonus of $5,000 for certain apartments that underwent an IAI pursuant to various agreements entered into from time to time. 10. As detailed below, the OAG has determined that Newcastle and Highcastle violated the law and rent regulations by, among other things, soliciting kickbacks from contractors and assigning false costs to contract labor associated with Gotham IAI’s. The OAG has also determined that Respondents' oversight was insufficient to detect or prevent Newcastle and Highcastle's misconduct. *** C. False Costs Attributed to IAI’S 22. From in and around 2008 to in and around 2016, Newcastle and Highcastle violated rent regulation by assigning false costs to contractor labor-and, in certain instances, window installation- associated with Gotham I IAI’s. Newcastle and Highcastle used those costs as a basis for raising rents, including rents that exceeded the applicable deregulation thresholds. 23. These false costs fell into the following three categories: (i) costs that were "fixed," or pre-determined, by Newcastle and Highcastle; (ii) costs that were falsely inflated or deflated because they were not wholly attributable to the apartment being renovated; and (iii) costs that were inflated because they included false change orders and/or included kickbacks to Newcastle and Highcastle employees and agents. i. Predetermined Labor Costs 9 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 24. For certain renovations, Newcastle and Highcastle predetermined the prices they were willing to pay for labor towards a renovation project without any competitive bidding and without considering the actual cost of the labor. 25. Newcastle and Highcastle repeatedly and persistently set the price of labor to the amount necessary to deregulate a unit. While "hard" costs, such as materials and supplies, were not impacted, the cost of labor varied dramatically from apartment to apartment and renovation to renovation, even when the actual work performed by the contractor and time spent laboring in the unit was roughly equivalent. 26. Newcastle and Highcastle repeatedly set the price of labor before even determining a scope of work or inviting a contractor to take a job. Once invited, Newcastle and Highcastle told the contractor the price it would pay for the job--regardless of the price the contractor would have bid for the job and often without the contractor even seeing the apartment. These costs did not necessarily change based on the renovation needs for a given apartment. 27. The labor price fixed for a job often had nothing to do with the size of the apartment. Thus, in 2012 Newcastle set the price of renovation of two similar one-bedroom apartments in the same building and on the same line at $52,500 and $38,000. There was no material difference in the contractor's scope of work; rather, the apartments had different legal regulated rents, and the former required more than $14,000 extra by way of IAI to push the rent to the deregulation threshold. (A copy of AOD 21-053 is annexed herein as Exhibit A.) 25. Before the Housing Stability and Tenant Protection Act of 2019 (“HSTPA”) changed the law to eliminate IAI’s on or about June 14, 2019, "high rent vacancy decontrol" occurred when, upon vacancy of the prior tenant of a rent-stabilized apartment, the monthly legal regulated rent for the apartment reached a threshold value set by the RSL (hereinafter "deregulation threshold"). RSL § 26-504.2. 26. During the period in which the respondents in the OAG action acquired and sold buildings, the deregulation threshold ranged from $2,000 (June 19, 1997 to June 23, 2011); to 10 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 $2,500.00 (June 24, 2011 to June 14, 2015); $2,700.00 (June 15, 2015 to December 31, 2017; and $2,733.75 (January 1, 2018 to December 31, 2018). 27. The IAI’s played a direct role in Sentinel and its affiliate’s investment strategy. From in or around 2008 to in or around 2016, Sentinel’s strategy for its portfolio included investing in apartment renovations in order to use IAI’s as a mechanism to increase the legal regulated rents of stabilized units and then remove them from rent regulation pursuant to high rent decontrol. At the time, Newcastle was awarded incentive "deregulation" bonuses by Sentinel if they invested sufficient funds into a unit to remove it from rent regulation. 28. The OAG found violations of rent regulations through 2016. Sentinel and its affiliates neither admitted nor denied that finding in the AOD 21-053, but the fact that the OAG made such findings; and the fact that Sentinel settled rather than face and defend an action by the OAG must be taken into account. Indeed, Four Million and 00/100’s ($4,000,000.00) Dollars is a lofty price to pay if innocent; and upon information and belief, Sentinel paid Four Million and 00/100’s Dollars ($4,000,000.00) to the “Affordable Housing Fund” with the New York City Department of Housing Preservation and Development (HPD). 29. On August 23, 2022, pursuant to the findings by the OAG which is set forth in AOD 21-053, the OAG issued a press release 3 with the headline: “Attorney General James Secures $4 Million from Landlords After Uncovering an Illegal Kickback Scheme to Deregulate Rent- Stabilized Apartments.” 30. The Four Million and 00/100’s Dollar ($4,000,000.00) settlement amount pales in comparison to the damage Plaintiffs suffered as a result of Defendants’ fraudulent scheme to deregulate. Hence Sentinel has not been held accountable to the degree that it profited 3 https://ag.ny.gov/press-release/2022/attorney-general-james-secures-4-million-landlords-after-uncovering-illegal 11 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 from the fraud it committed, but rather, Sentinel continues to reap the benefits of fraud as it pocketed money from an exaggerated sales price of the 921 Building and the 941 Building. Consider that in less than eleven (11) years, from when Sentinel and its affiliates bought the 921 Building and the 941 Building in December 2007, the valuation more than doubled (as a result of their fraud) in February 2018 when Plaintiffs bought the Buildings. 31. It is also submitted that Plaintiffs would not have purchased the 921 Building and/or the 941 Building if the number of deregulated apartments were less than what Sentinel and its affiliates represented. Indeed, Brian Ritter, Sentinel’s Managing Director signed the deed of sale for the 921 Building and the 941 Building, and also provided Plaintiffs with affidavits attesting to the legal rents that we now know were fraudulently increased. (A copy of Brian Ritter’s Affidavits for the 921 Building are annexed herein as Exhibit B, and a copy of Mr. Ritter’s Affidavits for the 941 Building are annexed herein as Exhibit C.) 32. Just as the Sentinel affiliated entities that were named in AOD 21-053 have been dissolved, Washington 921 Limited Partnership and Washington 941 Limited Partnership are also dissolved. It is submitted that Sentinel dissolved those entities without making provisions for known potential claims by purchasers in the face of the widespread fraud it, and its affiliates committed, to avoid liability to unsuspecting purchasers such as Plaintiffs. Under these circumstances, the certification of cancellation of the dissolved entities should be nullified and the entities revived because Sentinel did not set aside reserves. In addition, Sentinel exercised dominance and control over the entities named in AOD 21-053, just as Sentinel exercised dominion and control over Washington 921 Limited Partnership, Washington 941 Limited Partnership, and Newcastle. 12 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 33. As a matter of law, as well as public policy and equity, Sentinel and its affiliates must not be allowed to benefit from its unlawful enterprises. THE RELATIONSHIP AND CONNECTION BETWEEN THE DEFENDANTS HEREIN AND ALL TWENTY-NINE (29) ENTITIES NAMED IN AOD 21-053 34. John H. Streicker was the Chairman and Founder of Sentinel. 35. Michael F. Streicker, the son of John Streicker, is the President of Sentinel. 36. Margaret Streicker Porres, the daughter of John Streicker, founded Newcastle in 2004. 37. The 921 Building and 941 Building were both managed by Newcastle from in or about 2008 to in or about 2016. 38. Defendant Washington 921 Limited Partnership LP was incorporated in the State of Delaware with a registered address of 251 Little Falls Drive, Wilmington, DE 19808; and its phone number is (302) 636-5401. When it took title to the 921 Building on December 12, 2007, the UCC Financing Statement 4 that was filed sets forth Washington 921 Limited Partnership’s mailing address as: “c/o Sentinel Real Estate Corp., 1251 Avenue of the Americas.” 5 39. Moreover, the deed of sale 6 from Washington 921 Limited partnership to 921 Washington Avenue LLC was signed by Brian Ritter, who is Sentinel’s Managing Director 7 and responsible for portfolio management of several of Sentinel's commingled funds and separate accounts, as well as asset management for Sentinel's New York City portfolio. 4 The UCC Financing Statement was recorded with the City of New York, Office of the Register on October 14, 2010, under CRFN 2010000343986. 5 https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2010101300491003 6 The deed was recorded with the City of New York, Office of the Register on March 22, 2018, under CRFN 2018000097140. 7 https://www.sentinelcorp.com/brian-ritter.aspx 13 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 40. Defendant Washington 941 Limited Partnership LP was incorporated in the State of Delaware with a registered address of 251 Little Falls Drive, Wilmington, DE 19808; and its phone number is (302) 636-5401. The deed of sale from Washington 941 Limited Partnership to 921 Washington Avenue LLC was signed by Brian Ritter, who is Sentinel’s Managing Director. 8 41. With respect to the twenty-nine (29) entities the OAG named in AOD 21-053, their connection to Sentinel is irrefutable and evidences a modus operandi pattern of fraud: i. Gotham City Residential Manager I, LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel: 1251 Avenue of the Americas, 35th Floor, New York, NY 10020. ii. Gotham City Residential Manager II, LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel: 1251 Avenue of the Americas, 35th Floor, New York, NY 10020. iii. Gotham City Residential Advisors II, LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel: 1251 Avenue of the Americas, 35th Floor, New York, NY 10020. iv. Gotham Segregated Account GP I, LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel: 1251 Avenue of the Americas, 35th Floor, New York, NY 10020. v. Gotham Segregated Account Manager I, LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel: 1251 Avenue of the Americas, 35th Floor, New York, NY 10020. vi. Hygrocybe 1115 Union GP V, LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. 8 https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2018030601439002 14 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 - See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel: 1251 Avenue of the Americas, 35th Floor, New York, NY 10020. vii. Hygrocybe Manager V, LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel: 1251 Avenue of the Americas, 35th Floor, New York, NY 10020. viii. Tarzetta Catinus LP - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - See also Exhibit A, AOD 21-053 at paragraph I(1), it maintains the same address as Sentinel: 1251 Avenue of the Americas, 35th Floor, New York, NY 10020. ix. 5008 Broadway LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - GAP Mortgage dated July 21, 2015, is signed by Brian Kraut 9, Senior Vice President of Sentinel. - Assignment of Leases dated July 21, 2015, is signed by Brian Kraut. - The July 21, 2015 UCC-1 shows a mailing address of: “c/o Newcastle Realty, 270 Madison Avenue 19th Floor.” - Deed of sale dated April 27, 2023, is signed by Brian Ritter, Managing Director of Sentinel. x. 658 West 188th Street LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - GAP Mortgage dated July 21, 2015, is signed by Brian Kraut, Senior Vice President of Sentinel. - Assignment of Leases dated July 21, 2015, is signed by Brian Kraut. - The UCC Financing Statement dated February 15, 2019 contains a mailing address of: “c/o Sentinel Real Estate Corporation, 1251 Avenue of the Americas.” - Deed of sale dated August 30, 2023, is signed by Brian Ritter, Managing Director of Sentinel. xi. 80 Clarkson LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - GAP Mortgage dated October 30, 2015, is signed by Brian Kraut, Senior Vice President of Sentinel. - Assignment of Rents dated October 30, 2015, is signed by Brian Kraut. - Deed of sale dated January 23, 2024, is signed by Brian Ritter, Managing Director of Sentinel. xii. 92 Pinehurst Avenue LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - Mortgage dated February 15, 2019, is signed by Brian Kraut, Senior Vice President of Sentinel. 9 https://www.sentinelcorp.com/management-team.aspx 15 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 - Assignment of Rents dated February 15, 2019, is signed by Brian Kraut. - The UCC Financing Statement dated February 15, 2019 contains a mailing address of: “c/o Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.” - Deed of sale dated August 30, 2023, is signed by Brian Ritter, Managing Director of Sentinel. xiii. 3100 Brighton 2nd Street LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - Assumption of Mortgage dated August 30, 2016, is signed by Brian Ritter, Managing Director of Sentinel. - Assignment of Leases dated August 30, 2016, is signed by Brian Ritter. - Mortgage Modification Agreement dated February 26, 2020, are signed by Brian Kraut, Senior Vice President of Sentinel. - As per the HPD registration, William Freydberg is the head officer of 1803 Beverly Road LLC. Mr. Freydberg’s address is the same as Sentinel’s (1251 Ave Of The Americas, 35 FL, New York, NY 10020), and he is listed on Sentinel’s website as a Senior Vice President of Sentinel 10. xiv. Brightwater 219 LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - Assumption of Mortgage dated August 30, 2016, is signed by Brian Ritter, Managing Director of Sentinel. - Assignment of Leases dated August 30, 2016, is signed by Brian Ritter. - Mortgage Modification dated March 31, 2020, is signed by Brian Kraut, Senior Vice President of Sentinel. - As per the HPD registration, Leland Roth is the head officer of Brightwater 219 LLC. Mr. Roth’s address is the same for Sentinel (1251 Ave Of The Americas, 35 FL, New York, NY 10020), and he is listed on Sentinel’s website as the Chief Financial Officer 11. xv. Brightwater 231 LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - Assumption of Mortgage dated August 30, 2016, is signed by Brian Ritter, Managing Director of Sentinel. - Assignment of Leases dated August 30, 2016, is signed by Brian Ritter. - Mortgage Modification dated February 26, 2020, is signed by Brian Kraut, Senior Vice President of Sentinel. - As per the HPD registration, Leland Roth is the head officer of Brightwater 231 LLC. Mr. Roth’s address is the same for Sentinel (1251 Ave Of The Americas, 35 FL, New York, NY 10020), and he is listed on Sentinel’s website as the Chief Financial Officer. xvi. 66 St. Nicholas Place LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. 10 https://www.sentinelcorp.com/management-team.aspx 11 https://www.sentinelcorp.com/leland-j-roth.aspx 16 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 - Mortgage dated December 19, 2018, is signed by Brian Kraut, Senior Vice President of Sentinel. - The UCC Financing Statement dated February 15, 2019 contains a mailing address of: “c/o Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.” - As per HPD, Brian Ritter, Managing Director of Sentinel, is the head officer of 66 St. Nicholas Place LLC. Mr. Ritter’s address is the same as Sentinel’s: 1251 6th Avenue, New York, NY 10020). xvii. 75 St. Nicholas Place LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - The UCC Financing Statement dated December 19, 2018, contains a mailing address of: “c/o Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.” - As per HPD, Brian Ritter, the Managing Director of Sentinel, is the head officer of 75 St. Nicholas Place LLC. Mr. Ritter’s address is the same as Sentinel’s: 1251 6th Avenue New York, NY 10020). xviii. 76 St. Nicholas Place LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - Mortgage dated December 19, 2018, is signed by Brian Kraut, Senior Vice President of Sentinel. - The UCC Financing Statement dated December 19, 2018, contains a mailing address of: “c/o Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.” - As per HPD, Brian Ritter, the Managing Director of Sentinel, is the head officer of 76 St. Nicholas Place LLC. Mr. Ritter’s address is the same as Sentinel’s: 1251 6th Avenue New York, NY 10020. xix. 853 St. Nicholas Avenue LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - The UCC Financing Statement dated December 19, 2018, contains a mailing address of: “c/o Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.” - Mortgage dated December 19, 2018, is signed by Brian Kraut, Senior Vice President of Sentinel. - As per HPD, Brian Ritter, the Managing Director of Sentinel, is the head officer of 853 St. Nicholas Place LLC. Mr. Ritter’s address is the same as Sentinel’s: 1251 6th Avenue, New York, NY 10020). xx. 79 Brighton 11th Street LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - As per the HPD registration, Leland Roth is the head officer of 79 Brighton 11th Street LLC. Mr. Roth’s address is the same as Sentinel’s (1251 Ave Of The Americas, 35 FL, New York, NY 10020), and he is listed on Sentinel’s website as the Chief Financial Officer. xxi. 125 Brighton 11th Street LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - Mortgage dated January 15, 2014, is signed by Brian Kraut, Senior Vice President of Sentinel. 17 of 30 FILED: KINGS COUNTY CLERK 06/24/2024 04:13 PM INDEX NO. 517288/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/24/2024 - As per the HPD registration, Leland Roth is the head officer of 125 Brighton 11th Street LLC. Mr. Ritter’s address is the same as Sentinel’s (1251 Ave Of The Americas, 35 FL, New York, NY 10020), and he is listed on Sentinel’s website as the Chief Financial Officer. xxii. 1511-1521 Brightwater Avenue LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - Mortgage dated January 15, 2014, is signed by Brian Kraut, Senior Vice President of Sentinel. - Consolidation and Extension Agreement dated January 15, 2014, is signed by Brian Kraut. - The UCC Financing Statement dated December 19, 2018, contains a mailing address of: “c/o Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.” - As per the HPD registration, Brian Kraut is the head officer of 1511-1521 Brightwater Avenue LLC. Mr. Kraut’s address is the same as Sentinel’s (1251 Ave Of The Americas, 35 FL, New York, NY 10020), and he is listed on Sentinel’s website as the Chief Financial Officer. xxiii. 120 East 19th Street GSA I LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - Mortgage dated December 19, 2018, is signed by Brian Kraut, Senior Vice President of Sentinel. - Consolidation, Extension, and Modification Agreement dated December 19, 2018, is signed by Brian Kraut. - The UCC Financing Statement dated December 19, 2018, contains a mailing address of: “c/o Sentinel Real Estate Corporation, 1251 Avenue of the Americas, 35th Floor.” - As per the HPD registration, Brian Kraut is the head officer of 120 East 19th Street GSA I LLC. Mr. Kraut’s address is the same as Sentinel’s (1251 Ave Of The Americas, 35 FL, New York, NY 10020). xxiv. 146 East 19th Street LLC - Incorporated in Delaware with a registered address of: 251 Little Falls Drive, Wilmington, DE 19808; and the phone number is (302) 636-5401. - Mortgage dated December 19, 2018, is signed by Brian Kraut, Senior Vice President of Sentinel. - Consolidation, Extension, and Modification Agreement dated December 19,