UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO.: 9:20-cv-81205-RAR 

SECURITIES AND EXCHANGE COMMISSION, 

Plaintiff, 

v. 

COMPLETE BUSINESS SOLUTIONS GROUP, 

INC. d/b/a/ PAR FUNDING, et al., 

Defendants. 

___________________________________________/ 

DECLARATION OF JAMES LAFORTE 

Pursuant to 28 U.S.C. § 1746, the undersigned states as follows: 

1. My name is James LaForte. I am over twenty-one (21) years of age and have 

personal knowledge of the matters set forth herein. 

2. I am the sole owner of Bushwick Beer Garden, LLC, which I acquired from Vincent 

Minsquero around January 2021. I use Bushwick Beer Garden, LLC to run my restaurant business, 

including Rebel Café & Garden in Brooklyn, NY. 

3. I am also an account representative, and in that capacity, I do business with and 

through BG Sky Trade, LLC. BG Sky Trade is engaged in a broad range of business activities, 

including selling leads to MCA lenders, serving as an ISO, and doing other commission based 

work in various industries. 

4. Joseph LaForte is my brother and Lisa McElhone is my sister-in-law. After my 

brother was arrested and this lawsuit began in July of 2020, I did what I could to help Joe make 

bail and get good legal counsel. From the beginning of this lawsuit through today, I have helped 

Joe and Lisa with their legal fees and other expenses as much as I can. 

5. Vincent Bardong and Vincent Minsquero are both good friends of mine who I have 

done business with over the years. At my request, they both agreed to put their houses up as 

security for Joe’s bail. My cousin Peter Padovano and others also agreed to put their houses up 

for Joe’s bail after I asked them to. 

6. I obtained a $3 Million loan from Financial Mutual in order to help pay Joe and 

Lisa’s attorneys and cover other costs for them. (A copy of the loan agreement is attached as 

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Exhibit A). Frank Scarpati owns Financial Mutual and is a very good friend of mine, and he agreed 

to loan me the money. 

7. The loan from Financial Mutual was not paid out to me in a lump sum. Instead, it 

was made available to me like a line of credit I could draw from. I asked Frank Scarpati to make 

payments to attorneys and to other professionals for Joe and Lisa’s defense and to count those 

payments as advances against the amount Financial Mutual agreed to lend to me. I asked Financial 

Mutual to make $492,654 in payments to Alejandro Soto, $431,500 to the Berkowitz accounting 

firm, $95,000 to Kopelowitz Ostrow P.A., $762,500 to Alan Futerfas, $225,000 to James Froccaro 

and $350,000 to Michael Bachner. 

8. I also made some payments to attorneys and professionals through my company, 

Bushwick Beer Garden. Also, I arranged for BG Sky Trade to make payments to attorneys and 

professionals. The payments from BG Sky Trade were made in partial satisfaction of the 

commissions owed to me by BG Sky Trade for the deals I generated. 

9. I did all of this because I love my brother and sister-in-law and wanted to help them. 

At the time I arranged for the loan agreement with Financial Mutual I thought the Receivership 

would be over quickly and that CBSG would go back to being a very profitable business. 

10. Neither Joe nor Lisa were involved in my efforts to borrow and raise money to pay 

for their defense. I did this on my own. 

11. I have reviewed the Receiver’s contempt motion, and I believe that the Receiver 

has misunderstood or mischaracterized a number of transactions I was involved in. 

12. First, the Receiver states that $500,000 was diverted from B&T Supplies and 

Lifeguard Office Supplies to BG Sky Trade. The payments the Receiver refers to appear to have 

been payments Tzvi Odzer or his companies made to partially cover the $1.5 Million owed to me 

as a commission for brokering a large shipment of PPE he purchased through his companies. This 

transaction had nothing to do with the MCA agreements he and his companies had with CBSG, 

CFS or any other Receivership entity. Tzvi also agreed to make some payments at my request 

directly to my brother’s attorneys. These payments were likewise treated as partial payments of 

the commission he owed me on the PPE deal. 

13. Second, the Receiver states that $1,085,000 was diverted from Bene Market to BG 

Sky Trade. However, I know that BG Sky Trade provided leads to Bene Market and earned 

commissions for those leads. I believe the payments the Receiver refers to were payments for BG 

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Sky Trade’s earned commissions on leads, and had nothing to do with Bene Market’s MCA 

agreements with any Receivership entity. 

14. Third, the Receiver states that Bushwick BG paid Dayne Property Management 

Group Inc. $1,392,400. Dayne is owned by my friend and business associate, Joe Talamini, and 

does property management, renovation and construction work. I have used Dayne for a number of 

projects, including for the renovations of Rebel Café & Garden and Court Street Tavern in 

Brooklyn, NY. I reviewed invoices I paid for work Dayne performed for me and my companies 

between January 2021 and May 2022, and these total $1,392,412. (The Invoices are attached as 

Exhibit B). These payments did not have anything to do with CBSG, CFS or any MCA 

Agreements, they were for quality work Dayne did renovating Rebel Café & Garden, Court Street 

Tavern and other venues I am developing. I’ve included before and after pictures of Rebel Café & 

Garden as Court Street Tavern as an example of the renovation work Dayne performed for me. 

(See photos attached as Exhibit C) 

15. Fourth, the Receiver states that in May of 2022 Dayne paid about $94,000 for 

property taxes on Lisa’s home in Jupiter, Florida. I asked Joe Talamini to make this payment for 

me because I did not have the cash on hand to pay it myself at that time. Joe Talamini and I do a 

lot of business together, and he agreed to pay the taxes as a favor to me. I later paid him back, as 

promised. 

16. I have not done anything to divert merchant collections from CBSG or CFS or 

otherwise violate the Receivership Orders. 

17. Neither Joe nor Lisa ever asked me or directed me to divert merchant collections or 

violate the Receivership Orders, and I did not conspire with either of them to do so. 

18. To the best of my knowledge and belief, there is absolutely no truth to the 

Receiver’s allegations that Joe, Lisa or I were involved in a diversion scheme. 

19. I declare under penalty of perjury that the foregoing is true and correct. 

Executed on: _____________ 

_________________ 

James LaForte

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EXHIBIT A

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EXHIBIT B

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Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 24

Invoice Date 01/23/2021

Due Date 02/20/2021

Item Description Unit Price Quantity Amount

Service Floor Refinishing Cost

Non-discounted retail pricing for: 2 component, waterborne

urethane/acrylic polymer finish. Gloss or satin finish.

Non-yellowing. Quantity includes typical waste overage,

material for repair and local deliver

1571.00 1.00 1,571.00

Service Hardwood Floor Refinishing Labor, Basic

Basic labor to refinish hardwood floor with favorable site

conditions. Prep up to 1 hr per 100 SF - remove debris, spot

fill and patch level up to 2 defects per 100 SF. Remove

finish layer by 2 pass machine sanding. Apply 2 coats

polyurethane finish. Includes planning, equipment and

material acquisition, area preparation and protection, setup

and cleanup.

10547.00 1.00 10,547.00

Service Hardwood Floor Refinishing Job Supplies

Cost of related materials and supplies typically required to

refinish hardwood floor including: manufacturer

recommended underlayment, fasteners, adhesives and

surface sealants

1289.00 1.00 1,289.00

Service Artificial Lawn Cost

Non-discounted retail pricing for: 60 oz face weight.

Blended green / tan color. 1 3/4" pile height. 15' wide to 100'

long. 10 yr warranty. Quantity includes typical waste

overage, material for repair and local delivery.

13258.00 1.00 13,258.00

Service Artificial Lawn Installation Labor, Basic

Basic labor to install artificial lawn with favorable site

conditions. Excavate area to set finished height and

contour. Apply base gravel and compacted sand base. Fit,

seam and secure artificial lawn. Includes planning,

equipment and material acquisition, area preparation and

protection, setup and cleanup.

8696.00 1.00 8,696.00

Service rtificial Lawn Debris Disposal

Costs to load and haul away old materials, installation

waste and associated debris

767.00 1.00 767.00

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NOTES: Rebel Cafe

Subtotal 36,128.00

Total 36,128.00

Amount Paid 36,128.00

Balance Due $0.00

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Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 22

Invoice Date 04/01/2021

Due Date 05/07/2021

Item Description Unit Price Quantity Amount

Service Marble Tile Flooring Cost

Non-discounted retail pricing for: 12"x24" polished marble

tile. Factory sealant applied. 3/8" thick. Better grade Turkish

marble with uniform veining. Quantity includes typical waste

overage, material for repair and local delivery.

8057.00 1.00 8,057.00

Service Marble Tile Floor Installation Labor, Basic

Basic labor to install marble tile floor with favorable site

conditions. Plan layout, seams. Install and level mortar bed.

Set floor in thinset adhesive and grout seams. Includes

planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

27140.00 1.00 27,140.00

Service Marble Tile Floor Installation Job Supplies

Cost of related materials and supplies typically required to

install marble tile floor including: manufacturer

recommended underlayment, fasteners, adhesives and

surface sealants.

1425.00 1.00 1,425.00

Service Remove Tile

Detach tile and mortar from backing surface. Break into haul

able pieces. Remove from home and dispose of legally.

9009.00 1.00 9,009.00

Service Marble Tile Flooring Debris Disposal

Costs to load and haul away old materials, installation

waste and associated debris

1200.00 1.00 1,200.00

Service Wallpaper Cost

Non-discounted retail pricing for: Vinyl coated wallpaper.

Prepasted and paper backed. Washable and paintable.

Quantity includes typical waste overage, material for repair

and local delivery.

2936.00 1.00 2,936.00

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Service Wallpaper Installation Labor, Basic

Basic labor to install wallpaper with favorable site

conditions. Lightly clean surface. Apply, activate adhesive

and apply to walls. Pattern match and press seams. Trim at

edges. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

8627.00 1.00 8,627.00

Service Remove Wallpaper

Score wallpaper surface. Apply wallpaper paste/remover

solvent. Scrape paper from surface.

10987.00 1.00 10,987.00

Service Home Painting Cost

Non-discounted retail pricing for: Interior wall and trim paint.

Latex based, paint and primer in one. Flat, satin, eggshell

finish options. Quantity includes typical waste overage,

material for repair and local delivery.

2589.00 1.00 2,589.00

Service Home Interior Painting Labor, Basic

Basic labor to paint home with favorable site conditions.

Prep up to 3 hr per 100 SF - clean, scrape, sand and patch

up to 4 defects per 100 SF. Caulk gaps and spot prime. Roll

/ brush 2 coats of paint over lightly textured ceiling/walls.

Paint up to 2 doors and door trim per room. Includes

planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

7611.00 0.00 0.00

NOTES: Basement Location Rebel Garden

Subtotal 71,970.00

Total 71,970.00

Amount Paid 71,970.00

Balance Due $0.00

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Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Group B&G

449 Court St

Brooklyn NY 11231

I N V O I C E

Invoice # 78

Invoice Date 04/03/2021

Due Date 05/08/2021

Item Description Unit Price Quantity Amount

Service Artificial Lawn Cost

Non-discounted retail pricing for: 60 oz face weight.

Blended green / tan color. 1 3/4" pile height. 15' wide to 100'

long. 10 yr warranty. Quantity includes typical waste

overage, material for repair and local delivery.

7160.00 1.00 7,160.00

Service Artificial Lawn Installation Labor, Basic

Basic labor to install artificial lawn with favorable site

conditions. Excavate area to set finished height and

contour. Apply base gravel and compacted sand base. Fit,

seam and secure artificial lawn. Includes planning,

equipment and material acquisition, area preparation and

protection, setup and cleanup.

4716.00 1.00 4,716.00

Service Concrete Pad Cost

Non-discounted retail pricing for: 4+ inch thick, fibermesh

reinforced 3500 PSI concrete. Broom finish. Quantity

includes typical waste overage, material for repair and local

delivery.

2663.00 1.00 2,663.00

Service Concrete Pad Installation Labor, Basic

Basic labor to install concrete pad with favorable site

conditions. Layout pad height and slope. Lightly grade and

remove loose soil. Set forms and reinforcing. Pour and

finish concrete. Excavation, gravel base layer, compaction

or hardscape demolition not included. 500 sq ft maximum.

Includes planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

5107.00 1.00 5,107.00

Service Debris clean Up 2500.00 1.00 2,500.00

Service Sliding Door Cost

Non-discounted retail pricing for: Wood sliding patio door

with fusion welded frame. Double pane, low E glass with

Argon insulation layer

3170.00 1.00 3,170.00

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Service Sliding Door Installation Labor, Basic

Basic labor to install sliding door with favorable site

conditions. Set unit in rough opening. Shim to achieve level

and plumb placement. Set jamb edges flush to finished wall

surfaces. Secure unit to rough opening framing. Includes

planning, equipment and material acquisition, area

preparation and protection, setup and cleanup

3500.00 1.00 3,500.00

NOTES: Outside yard Court St Tavern

Subtotal 28,816.00

Total 28,816.00

Amount Paid 28,816.00

Balance Due $0.00

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Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 127

Invoice Date 09/01/2021

Due Date 10/01/2021

Item Description Unit Price Quantity Amount

Service Membrane Roofing System Cost

Non-discounted retail pricing for: Structurally reinforced

membrane. For fully adhered or mechanically attached. 30

yr warranty. UV resistance and 100 mph wind rating.

Quantity includes typical waste overage, material for repair

and local delivery.

3919.00 1.00 3,919.00

Service Membrane Roofing Installation Labor, Basic

Basic labor to install membrane roofing system with

favorable site conditions. Clear roof surface of debris.

Set/remove protruding nails. Cut and layout material, apply

recommended adhesive and roll. Seal edges and all roof

penetrations. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup

8547.00 1.00 8,547.00

Service Membrane Roofing Installation Job Supplies

Cost of related materials and supplies typically required to

install membrane roofing system including: fasteners,

underlayment, drip edges, sealant and basic flashing.

1258.00 1.00 1,258.00

Service Membrane Roofing Installation Equipment Allowance

Job related costs of specialty equipment used for job quality

and efficiency, including: Roof jacks, pneumatic roofing

nailer, shingle cutting tools. Daily rental. Consumables

extra.

365.00 5.00 1,825.00

Service Shelving Installation Labor, Basic

Basic labor to install shelving with favorable site conditions.

Secure mounting brackets to wall framing. Fit, level and

secure shelves up to 2m/7ft in length. Includes planning,

equipment and material acquisition, area preparation and

protection, setup and cleanup

22538.00 1.00 22,538.00

Service Wood Countertop Cost

Non-discounted retail pricing for: Solid hardwood block

countertop. 1.25" thick with full exterior rails. Penetrating oil

finish. NSF approved for food preparation. Quantity includes

typical waste overage, material for repair and local delivery.

7198.00 1.00 7,198.00

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Service Wood Countertop Installation Labor, Basic

Basic labor to install wood countertop with favorable site

conditions. Template, layout and fabricate wood countertop

with basic edge. Add 1 sink and faucet cutout. Install and

secure countertop. Includes planning, equipment and

material acquisition, area preparation and protection, setup

and cleanup.

2745.00 1.00 2,745.00

Service Wood Countertop Installation Job Supplies

Cost of related materials and supplies typically required to

install wood countertop including: fabrication consumables,

fasteners, sealants and caulking.

1301.00 1.00 1,301.00

Service Quartz Countertop Cost

Non-discounted retail pricing for: Mid grade, 20mm thick

solid surface countertop. Non-porous, stain and scratch

resistant. 15 yr warranty. Price assumes 80+% slab

utilization. Quantity includes typical waste overage, material

for repair and local delivery.

15547.00 1.00 15,547.00

Service Quartz Countertop Installation Labor, Basic

Basic labor to install quartz countertop with favorable site

conditions. Template, layout and fabricate synthetic stone

countertop with basic edge. Add 1 sink and faucet cutout.

Install and secure countertop. Includes planning, equipment

and material acquisition, area preparation and protection,

setup and cleanup.

4813.00 1.00 4,813.00

Service Split Ac Unit Cost

Non-discounted retail pricing for: 2 Ton 16 SEER mini-split

heat pump system. 9,000 BTU indoor air handler with

remote control. Requires 240V 25A. 10 yr limited warranty.

2291.00 1.00 2,291.00

Service Split System Air Conditioner Installation Labor, Basic

Basic labor to install split system air conditioner with

favorable site conditions. Install new 240V 20A circuit.

Mount and secure condenser to new pad. Fabricate pass

through. Connect air handlers and mount unit. Connect,

insulate and enclose lines between condenser air handler.

Connect control panel and power source. Charge

condenser with up to 12 lbs of R410a refrigerant. Verify

proper operation. Includes planning, equipment and

material acquisition, area preparation and protection, setup

and cleanup.

3812.00 1.00 3,812.00

Service Pendant Light Cost

Non-discounted retail pricing for: 3-light with multipendant

base fixture. Clear glass pendant shade. Chrome | brass |

stainless steel finish options. Direct wire. 120V.

1875.00 5.00 9,375.00

Service Pendant Lighting Installation Labor, Basic

Basic labor to install pendant lighting with favorable site

conditions. Turn off power to circuit. Layout location and cut

mounting hole. Add or modify wiring from existing switch or

parallel fixture. Place fixture and trim piece. Power and test.

Includes planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

2571.00 5.00 12,855.00

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Service Add AFCI Circuit Protection

Shutoff power to circuit. Remove existing circuit breaker.

Add new 15A or 20A Arc Fault Circuit Interrupt breaker.

Repower and verify proper operation. For existing systems

with compatible AFCI breaker option only.

1299.00 5.00 6,495.00

Service Debris Removal 1080.00 1.00 1,080.00

NOTES: Rebel Cafe & Garden

Pizza Area

Subtotal 105,599.00

Total 105,599.00

Amount Paid 105,599.00

Balance Due $0.00

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Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 0000099

Invoice Date 11/30/2021

Due Date 12/30/2021

Item Description Unit Price Quantity Amount

Service Drywall Cost

Non-discounted retail pricing for: Paper faced 1/2" thick

gypsum board. 4' x 8' sheets. Quantity includes typical

waste overage, material for repair and local delivery.

1810.00 1.00 1,810.00

Service Drywall Installation Labor, Basic

Basic labor to install drywall with favorable site conditions.

Layout, fabricate and fit drywall sheets. With up to 1 cutout

per 100 SF. Secure to framing per manufacturer

specifications. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

4356.00 1.00 4,356.00

Service Remove Drywall

Break drywall into sections and remove from framing.

Remove drywall fasteners from framing. Dispose of material

in responsible manner. Material cost includes dump fee.

1500.00 1.00 1,500.00

Service Wall Painting Cost

Non-discounted retail pricing for: Interior wall and ceiling

paint. Latex based, paint and primer in one. Flat, satin,

eggshell finish options. Quantity includes typical waste

overage, material for repair and local delivery.

2359.00 1.00 2,359.00

Service Wall Painting And Finishing Labor, Basic

Basic labor to paint wall with favorable site conditions. Prep

up to 1 hr per 200 SF - scrape, sand and patch up to 4

defects per 100 SF. Roll 2 coats of paint and cut in at trim

molding. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

5968.00 1.00 5,968.00

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Service Interior Wall Framing Labor, Basic

Basic labor to frame interior wall with favorable site

conditions. Layout, fabricate and install conventional wood

framed wall using 2"x4" studs spaced 16" on center.

Includes double top plate, blocking and 1 corner per 100 SF

of wall. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

5601.00 1.00 5,601.00

Service Interior Wall Framing Job Supplies

Cost of related materials and supplies typically required to

frame interior wall including: fasteners, connectors and

dimensional lumber for openings.

3576.00 1.00 3,576.00

Service Sliding Door Cost

Non-discounted retail pricing for: Barn Door

2377.00 1.00 2,377.00

Service Sliding Door Installation Labor, Basic

Basic labor to install sliding door with favorable site

conditions. Set unit in rough opening. Shim to achieve level

and plumb placement. Set jamb edges flush to finished wall

surfaces. Secure unit to rough opening framing. Includes

planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

1855.00 1.00 1,855.00

Service Pendant Light Cost

Non-discounted retail pricing for: 3-light with multipendant

base fixture. Clear glass pendant shade. Chrome | brass |

stainless steel finish options. Direct wire. 120V.

4687.00 1.00 4,687.00

Service Pendant Lighting Installation Labor, Basic

Basic labor to install pendant lighting with favorable site

conditions. Turn off power to circuit. Layout location and cut

mounting hole. Add or modify wiring from existing switch or

parallel fixture. Place fixture and trim piece. Power and test.

Includes planning, equipment and material acquisition, area

preparation and protection, setup and cleanup

6346.00 1.00 6,346.00

Service Add AFCI Circuit Protection

Shutoff power to circuit. Remove existing circuit breaker.

Add new 15A or 20A Arc Fault Circuit Interrupt breaker.

Repower and verify proper operation. For existing systems

with compatible AFCI breaker option only.

3222.00 2.00 6,444.00

Service Electrical Outlet Cost

Non-discounted retail pricing for: Duplex, 120V 20A weather

resistant outlet in weatherproof electrical box and trim plate.

NM conduit and wiring extra.

555.00 1.00 555.00

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Service Electrical Receptacle Installation Labor, Basic

Basic labor to install electrical receptacle with favorable site

conditions. Turn off power to circuit. Layout location and cut

mounting hole. Mount remodeling style electrical box. Add

or modify NM-B wiring from existing circuit and fixture.

Connect receptacle and secure NM-B wiring to framing.

Place receptacle and trim piece. Repower circuit and verify

proper polarity and operation. Includes planning, equipment

and material acquisition, area preparation and protection,

setup and cleanup.

5088.00 1.00 5,088.00

NOTES: Ainsworth 26th St

Basement

Subtotal 52,522.00

Total 52,522.00

Amount Paid 52,522.00

Balance Due $0.00

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Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Group B&G

449 Court St

Brooklyn NY 11231

I N V O I C E

Invoice # 113

Invoice Date 12/20/2021

Due Date 01/20/2022

Item Description Unit Price Quantity Amount

Service Drywall Cost

Non-discounted retail pricing for: Paper faced 1/2" thick

gypsum board. 4' x 8' sheets. Quantity includes typical

waste overage, material for repair and local delivery.

1723.00 1.00 1,723.00

Service Drywall Installation Labor, Basic

Basic labor to install drywall with favorable site conditions.

Layout, fabricate and fit drywall sheets. With up to 1 cutout

per 100 SF. Secure to framing per manufacturer

specifications. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

6382.00 1.00 6,382.00

Service Remove Drywall

Break drywall into sections and remove from framing.

Remove drywall fasteners from framing. Dispose of material

in responsible manner. Material cost includes dump fee.

1569.00 1.00 1,569.00

Service Drywall Debris Disposal

Costs to load and haul away old materials, installation

waste and associated debris.

1250.00 1.00 1,250.00

Service Acoustic Ceiling Removal Labor, Basic

Basic labor to remove acoustic ceiling with favorable site

conditions. For asbestos-free texture only. Apply softening

agent / water. Scrape texture from surface. Dispose of

scrapings. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup

2385.00 1.00 2,385.00

Service Interior Door Cost

Non-discounted retail pricing for: 30" x 80" hollow core 6

panel slab interior door. Primed for paint. Quantity includes

typical waste overage, material for repair and local delivery

338.00 4.00 1,352.00

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Service Interior Door Installation Labor, Basic

Basic labor to install interior door with favorable site

conditions. Measure, trim and plane door to fit existing door

jamb. Mark and mortise hinge locations. Install hinges.

Fabricate holes, mortises for door handle set and jamb

strike plate. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

1554.00 3.00 4,662.00

Service Molding Cost

Non-discounted retail pricing for: 1/2" x 2 1/4" Primed MDF

casing. Paint ready. Quantity includes typical waste

overage, material for repair and local delivery.

6659.00 1.00 6,659.00

Service Trim Molding Installation Labor, Basic

Basic labor to install trim molding with favorable site

conditions. Measure, cut (1 miter and 1 coped end per

section) molding and finish nail. Patch and smooth nail

holes and if painting caulk edge gaps. Includes planning,

equipment and material acquisition, area preparation and

protection, setup and cleanup.

23432.00 1.00 23,432.00

Service Trim Molding Installation Job Supplies

Cost of related materials and supplies typically required to

install trim molding including: fasteners, connectors, surface

preparation and finishing materials

2427.00 1.00 2,427.00

Service Remove Molding

Score perimeter of trim, where trim is bonded to adjacent

surface(s). Pry trim away from surface without damaging

adjacent surfaces, finishes or hardware. Remove trim

millwork from premises.

13029.00 1.00 13,029.00

Service Molding Debris Disposal

Costs to load and haul away old materials, installation

waste and associated debris.

1359.00 1.00 1,359.00

NOTES: Court St Tavern

Subtotal 66,229.00

Total 66,229.00

Amount Paid 66,229.00

Balance Due $0.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 22 of

63
Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Group B&G

449 Court St

Brooklyn NY 11231

I N V O I C E

Invoice # 87

Invoice Date 12/22/2021

Due Date 01/25/2022

Item Description Unit Price Quantity Amount

Service Ceramic Floor Tile Cost

Non-discounted retail pricing for: Residential grade glazed

ceramic tile 12" x 12". Moderate to heavy traffic. Quantity

includes typical waste overage, material for repair and local

delivery.

9858.00 1.00 9,858.00

Service Ceramic Floor Tile Installation Labor, Basic

Basic labor to install ceramic floor tile with favorable site

conditions. Measure, fabricate and secure backer board.

Layout tile pattern. Fabricate and install with thinset mortar.

Grout and clean surface. Includes planning, equipment and

material acquisition, area preparation and protection, setup

and cleanup

67220.00 1.00 67,220.00

Service Ceramic Floor Tile Installation Job Supplies

Cost of related materials and supplies typically required to

install ceramic floor tile including: fabrication and polishing

disposables, manufacturer recommended underlayment,

fasteners, adhesives and surface sealants.

4284.00 1.00 4,284.00

Service Remove Flooring

Detach from mounting surface(s). Break into haul able

pieces. Remove from home and dispose of legally.

Asbestos handling is extra.

7844.00 1.00 7,844.00

Service Ceramic Floor Tile Debris Disposal

Costs to load and haul away old materials, installation

waste and associated debris.

1153.00 1.00 1,153.00

NOTES: Court St Tavern

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 23 of

63
Subtotal 90,359.00

Total 90,359.00

Amount Paid 90,359.00

Balance Due $0.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 24 of

63
Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 115

Invoice Date 12/27/2021

Due Date 01/31/2022

Item Description Unit Price Quantity Amount

Service Subfloor Repair Labor, Basic

Basic labor to repair subfloor with favorable site conditions.

Cut and remove damaged subfloor. Fabricate and install

2"x6" joist reinforcements and subfloor surface. 10 square

feet minimum. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

92697.00 1.00 92,697.00

Service Subfloor Repair Job Supplies

Cost of related materials and supplies typically required to

repair subfloor including: fasteners, connectors and

dimensional lumber for openings.

31516.00 1.00 31,516.00

Service Subfloor Repair Equipment Allowance

Job related costs of specialty equipment used for job quality

and efficiency, including: Pneumatic framing nailer, 12"

miter saw and 3 1/4" electric planer. Daily rental.

Consumables extra.

550.00 1.00 550.00

Service Debris Removal 1250.00 1.00 1,250.00

NOTES: Ainsworth

26th St

Basement

Subtotal 126,013.00

Total 126,013.00

Amount Paid 126,013.00

Balance Due $0.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 25 of

63
Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 88

Invoice Date 01/10/2022

Due Date 02/10/2022

Item Description Unit Price Quantity Amount

Service Icemaker Cost

Non-discounted retail pricing for: Freezer mounted ice

making unit with connections and fitting.

1300.00 1.00 1,300.00

Service ce Maker Installation Labor, Basic

Basic labor to install ice maker with favorable site

conditions. Shut off water supply to existing branch. Add

shutoff tee connector. Route water supply tubing from

shutoff tee to back of appliance. Mount and secure unit.

Connect water supply and verify leak free operation. Verify

operation cycle. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

750.00 1.00 750.00

Service Water Heater Cost

Non-discounted retail pricing for: 40 gallon gas water

heater. Tank type with 40,000 BTU rating. 9 yr warranty.

1500.00 1.00 1,500.00

Service Hot Water Heater Replacement Labor, Basic

Basic labor to replace hot water heater with favorable site

conditions. Replace tank type gas water heater. Level and

secure new unit. Connect to existing gas, water and vent

lines and leak test. Connection kit included. Includes

planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

1750.00 1.00 1,750.00

Service ink Drain Cost

Non-discounted retail pricing for: 4 1/2" diameter fixed post

drain with strainer. Stainless steel finish and safety rolled

edge.

75.00 5.00 375.00

Service Kitchen Sink Drain Replacement Labor, Basic

Basic labor to replace kitchen sink drain with favorable site

conditions. Disconnect and remove existing drain assembly.

Fabricate and fit drain assembly to p trap and existing

rough-in drain connection. Drain and leak test. Includes

planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

1354.00 1.00 1,354.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 26 of

63
Service Toilet Cost

Non-discounted retail pricing for: 2 piece, elongated toilet.

Low volume, gravity flush. Floor mount. With soft close seat

350.00 3.00 1,050.00

Service Toilet Replacement Labor, Basic

Basic labor to replace toilet with favorable site conditions.

Drain, remove and dispose of existing toilet. Fit new unit

with new wax ring and new water supply connector.

Includes planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

1400.00 1.00 1,400.00

Service Plumbing Leak Repair Labor, Basic

Basic labor to repair plumbing leak with favorable site

conditions. Locate leak. Replace leaking pipe, fitting or

connection. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

250.00 10.00 2,500.00

Service Dishwasher Cost

Non-discounted retail pricing for: Under cabinet mounted

dishwasher. 3 cycles. Front mounted controls. Requires

120V electrical and cold water connection at unit. 1 yr

warranty.

1300.00 2.00 2,600.00

Service Dishwasher Installation Labor, Basic

Basic labor to install dishwasher with favorable site

conditions. Connect to existing electrical, existing water

supply and existing drain line. Level and secure unit. Verify

operation cycle. Check and fix leaks. Includes planning,

equipment and material acquisition, area preparation and

protection, setup and cleanup

1650.00 1.00 1,650.00

NOTES: Winston's

NYC

Subtotal 16,229.00

Total 16,229.00

Amount Paid 16,229.00

Balance Due $0.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 27 of

63
Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 0000062

Invoice Date 01/20/2022

Due Date 09/20/2022

Item Description Unit Price Quantity Amount

Service Ceramic Floor Tile Cost

Non-discounted retail pricing for: Residential grade glazed

ceramic tile 12" x 12". Moderate to heavy traffic. Quantity

includes typical waste overage, material for repair and local

delivery.

12980.00 1.00 12,980.00

Service Ceramic Floor Tile Installation Labor, Basic

Basic labor to install ceramic floor tile with favorable site

conditions. Measure, fabricate and secure backer board.

Layout tile pattern. Fabricate and install with thinset mortar.

Grout and clean surface. Includes planning, equipment and

material acquisition, area preparation and protection, setup

and cleanup.

99549.00 1.00 99,549.00

Service Ceramic Floor Tile Installation Job Supplies

Cost of related materials and supplies typically required to

install ceramic floor tile including: fabrication and polishing

disposables, manufacturer recommended underlayment,

fasteners, adhesives and surface sealants.

4873.00 1.00 4,873.00

Service Remove Flooring

Detach from mounting surface(s). Break into haul able

pieces. Remove from home and dispose of legally.

Asbestos handling is extra.

40424.00 1.00 40,424.00

Service Remove Flooring

Detach from mounting surface(s). Break into haul able

pieces. Remove from home and dispose of legally.

Asbestos handling is extra.

1250.00 1.00 1,250.00

NOTES: Ainsworth 26th St

NYC

Basement

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 28 of

63
Subtotal 159,076.00

Total 159,076.00

Amount Paid 159,076.00

Balance Due $0.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 29 of

63
Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 0000041

Invoice Date 02/22/2022

Due Date 03/08/2022

Item Description Unit Price Quantity Amount

Service Membrane Roofing Installation Labor, Basic

Basic labor to install membrane roofing system with

favorable site conditions. Clear roof surface of debris.

Set/remove protruding nails. Cut and layout material, apply

recommended adhesive and roll. Seal edges and all roof

penetrations. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup. *** Front Garden ***

55000.00 1.00 55,000.00

Service Membrane Roofing Installation Labor, Basic

Basic labor to install membrane roofing system with

favorable site conditions. Clear roof surface of debris.

Set/remove protruding nails. Cut and layout material, apply

recommended adhesive and roll. Seal edges and all roof

penetrations. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup. *** Rear Garden ***

25000.00 1.00 25,000.00

Service Ceramic Floor Tile Installation Labor, Basic

Basic labor to install ceramic floor tile with favorable site

conditions. Measure, fabricate and secure backer board.

Layout tile pattern. Fabricate and install with thinset mortar.

Grout and clean surface. Includes planning, equipment and

material acquisition, area preparation and protection, setup

and cleanup. *** Downstairs basement ***

32000.00 1.00 32,000.00

Service Wallpaper Hanging Labor, Basic

Basic labor to hang wallpaper with favorable site conditions.

Lightly clean surface. Apply, activate adhesive and apply to

walls. Pattern match and press seams. Trim at edges.

Includes planning, equipment and material acquisition, area

preparation and protection, setup and cleanup. * Upstairs

and Downstairs *

15000.00 1.00 15,000.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 30 of

63
Service Granite Countertop Installation Labor, Basic

Basic labor to install granite countertops with favorable site

conditions. Template, layout and fabricate granite

countertop with basic edge. Add 1 sink and faucet cutout.

Install and secure countertop. Includes planning, equipment

and material acquisition, area preparation and protection,

setup and cleanup. * Upstairs bar & downstairs bar *

16000.00 1.00 16,000.00

Service Air Handler Installation Labor, Basic

Basic labor to install air handler with favorable site

conditions. Add new air handling unit to existing, compatible

split system. Secure mounting plate. Fabricate pass

through. Connect air handler lines and mount air handler.

Connect, insulate and enclose lines between condenser air

handler - up to 20 ft. Charge condenser with up to 12 lbs of

R410a refrigerant. Power unit. Verify proper cycling and

temperature control. Includes planning, equipment and

material acquisition, area preparation and protection, setup

and cleanup.

15000.00 1.00 15,000.00

Service Ceiling Light Installation Labor, Basic

Basic labor to install ceiling light fixture with favorable site

conditions. Shut off power to circuit. Layout location and cut

mounting hole. Add or modify NM-B wiring from existing

switch or parallel fixture. Connect outlet and secure NM-B

wiring to framing. Place fixture and trim piece. Power circuit

and verify proper operation. Includes planning, equipment

and material acquisition, area preparation and protection,

setup and cleanup.

1000.00 10.00 10,000.00

NOTES: Rebel Cafe & Garden

Subtotal 168,000.00

Total 168,000.00

Amount Paid 168,000.00

Balance Due $0.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 31 of

63
Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Group B&G

449 Court St

Brooklyn NY 11231

I N V O I C E

Invoice # 0000040

Invoice Date 02/28/2022

Due Date 03/08/2022

Item Description Unit Price Quantity Amount

Service Hardwood Floor Refinishing Labor, Basic

Basic labor to refinish hardwood floor with favorable site

conditions. Prep up to 1 hr per 100 SF - remove debris, spot

fill and patch level up to 2 defects per 100 SF. Remove

finish layer by 2 pass machine sanding. Apply 2 coats

polyurethane finish. Includes planning, equipment and

material acquisition, area preparation and protection, setup

and cleanup

3500.00 1.00 3,500.00

Service Wood Floor Staining Labor, Basic

Basic labor to stain wood flooring with favorable site

conditions. Remove debris from new wood floor. Apply 2

coats stain. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

2500.00 1.00 2,500.00

Service Tile Floor Installation Labor, Basic

Basic labor to install tile floor with favorable site conditions.

Measure, fabricate and secure backer board. Layout tile

pattern. Fabricate and install with thinset mortar. Grout and

clean surface. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

35000.00 1.00 35,000.00

Service Interior Painting Labor, Basic

Basic labor to paint with favorable site conditions. Prep up

to 3 hr per 100 SF - clean, scrape, sand and patch up to 4

defects per 100 SF. Caulk gaps and spot prime. Roll / brush

2 coats of paint over lightly textured ceiling/walls. Paint up

to 2 doors and door trim per room. Includes planning,

equipment and material acquisition, area preparation and

protection, setup and cleanup.

11000.00 1.00 11,000.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 32 of

63
Service Drain Line Installation Labor, Basic

Basic labor to install drain line with favorable site conditions.

Install connection fitting from wall/floor, primary drain

connection fitting and up to 10m/30ft to primary drain line.

Secure and leak test. Route in wall/underfloor only.

Demolition, structural modifications and surface restoration

are NOT included. Wall/floor surface restoration if needed is

extra. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup

10000.00 1.00 10,000.00

Service Plumbing Relocation Labor, Basic

Basic labor to move plumbing with favorable site conditions.

Install coupling and up to 10m/30ft water line. Connect,

route, secure and leak test rerouted line. Wall/floor surface

restoration if needed is extra. Includes planning, equipment

and material acquisition, area preparation and protection,

setup and cleanup.

8000.00 1.00 8,000.00

NOTES: Court Street Tavern

Subtotal 70,000.00

Total 70,000.00

Amount Paid 70,000.00

Balance Due $0.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 33 of

63
Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 101

Invoice Date 03/01/2022

Due Date 04/01/2022

Item Description Unit Price Quantity Amount

Service Electrical Outlet Cost

Non-discounted retail pricing for: Duplex, 120V 20A weather

resistant outlet in weatherproof electrical box and trim plate.

NM conduit and wiring extra.

45.00 10.00 450.00

Service Electrical Receptacle Installation Labor, Basic

Basic labor to install electrical receptacle with favorable site

conditions. Turn off power to circuit. Layout location and cut

mounting hole. Mount remodeling style electrical box. Add

or modify NM-B wiring from existing circuit and fixture.

Connect receptacle and secure NM-B wiring to framing.

Place receptacle and trim piece. Repower circuit and verify

proper polarity and operation. Includes planning, equipment

and material acquisition, area preparation and protection,

setup and cleanup

2067.00 1.00 2,067.00

Service dd AFCI Circuit Protection

Shutoff power to circuit. Remove existing circuit breaker.

Add new 15A or 20A Arc Fault Circuit Interrupt breaker.

Repower and verify proper operation. For existing systems

with compatible AFCI breaker option only.

1289.00 3.00 3,867.00

Service Pendant Light Cost

Non-discounted retail pricing for: 3-light with multipendant

base fixture. Clear glass pendant shade. Chrome | brass |

stainless steel finish options. Direct wire. 120V.

185.00 15.00 2,775.00

Service Pendant Lighting Installation Labor, Basic

Basic labor to install pendant lighting with favorable site

conditions. Turn off power to circuit. Layout location and cut

mounting hole. Add or modify wiring from existing switch or

parallel fixture. Place fixture and trim piece. Power and test.

Includes planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

3829.00 1.00 3,829.00

Service Bathroom Fan Cost

Non-discounted retail pricing for: Wall or ceiling mounted

ventilation fan. 70 CFM, 6 sones operation. Connect to

existing electrical and vent ducting

225.00 3.00 675.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 34 of

63
Service Bathroom Fan Installation Labor, Basic

Basic labor to install bathroom fan with favorable site

conditions. Shut off power to circuit. Layout location and cut

mounting hole. Add or branch circuit and switch wiring from

existing circuit with sufficient power capacity. Place and

secure fixture to framing. Connect electrical wiring to unit.

Connect vent ducting to unit and route to suitable wall/roof

vent. Power circuit and verify proper operation. Includes

planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

2877.00 1.00 2,877.00

Service Built-In Refrigerator Cost

Non-discounted retail pricing for: 18.6 cubic foot refrigerator.

Stainless steel door. 3 shelves and adjustable storage bins.

1 yr limited warranty.

7019.00 1.00 7,019.00

Service Built-In Refrigerator Replacement Labor, Basic

Basic labor to replace built-in refrigerator with favorable site

conditions. Disconnect and remove existing refrigerator.

Install mounting brackets. Connect and mount new

refrigerator. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

2225.00 1.00 2,225.00

NOTES: Winston's

NYC

Upstairs

Subtotal 25,784.00

Total 25,784.00

Amount Paid 25,784.00

Balance Due $0.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 35 of

63
Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 0000061

Invoice Date 03/15/2022

Due Date 04/15/2022

Item Description Unit Price Quantity Amount

Service Interior Wall Removal Labor, Basic

Basic labor to remove interior wall with favorable site

conditions. Detach from adjacent surfaces. Break into haul

able pieces. Remove from home and dispose of legally.

Includes planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

3107.00 1.00 3,107.00

Service nterior Wall Debris Disposal

Costs to load and haul away old materials, installation

waste and associated debris

2507.00 1.00 2,507.00

Service Plumbing Relocation Labor, Basic

Basic labor to move plumbing with favorable site conditions.

Install coupling and up to 10m/30ft water line. Connect,

route, secure and leak test rerouted line. Wall/floor surface

restoration if needed is extra. Includes planning, equipment

and material acquisition, area preparation and protection,

setup and cleanup.

7480.00 1.00 7,480.00

Service Plumbing Relocation Job Supplies

Cost of related materials and supplies typically required to

move plumbing including: fittings, mounting hardware and

connectors

1417.00 1.00 1,417.00

Service Slate Flooring Cost

Non-discounted retail pricing for: Contoured, textured stone

tile 12" x 12". Natural surface. Quantity includes typical

waste overage, material for repair and local delivery.

5608.00 1.00 5,608.00

Service Slate Tile Flooring Installation Labor, Basic

Basic labor to install slate tile flooring with favorable site

conditions. Apply full mud base. Layout slate tile pattern.

Fabricate and install. Grout and clean surface. Includes

planning, equipment and material acquisition, area

preparation and protection, setup and cleanup

16989.00 1.00 16,989.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 36 of

63
Service Bathroom Floor Tile Cost

Non-discounted retail pricing for: Residential grade glazed

ceramic tile 12" x 12". Moderate to heavy traffic. Quantity

includes typical waste overage, material for repair and local

delivery.

2500.00 1.00 2,500.00

Service Bathroom Floor Tile Installation Labor, Basic

Basic labor to install bathroom floor tile with favorable site

conditions. Measure, fabricate and secure backer board.

Layout tile pattern. Fabricate and install with thinset mortar.

Grout and clean surface. Includes planning, equipment and

material acquisition, area preparation and protection, setup

and cleanup.

2800.00 1.00 2,800.00

NOTES: Winston's

NYC

Subtotal 42,408.00

Total 42,408.00

Amount Paid 42,408.00

Balance Due $0.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 37 of

63
Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Group B&G

449 Court St

Brooklyn NY 11231

I N V O I C E

Invoice # 122

Invoice Date 03/28/2022

Due Date 04/28/2022

Item Description Unit Price Quantity Amount

Service Exterior Trim Painting Cost

Non-discounted retail pricing for: Exterior enamel paint.

Latex based, paint and primer in one. Eggshell and

semi-gloss finish options. For wood, vinyl, masonry, stucco,

brick. Mildew resistant. 15 yr warranty. Quantity includes

typical waste overage, material for repair and local delivery.

2747.00 1.00 2,747.00

Service Exterior Trim Painting Labor, Basic

Basic labor to paint exterior trim with favorable site

conditions. Prep up to 1 hr per 100LF - remove loose paint,

spot prime and caulk edges, gaps. Roll / brush 2 coats of

paint. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

5774.00 1.00 5,774.00

Service Floor Finishing Cost

Non-discounted retail pricing for: Oil based,

semi-transparent stain with integral sealer. Quantity

includes typical waste overage, material for repair and local

delivery.

2538.00 1.00 2,538.00

Service Hardwood Floor Staining And Finishing Labor, Basic

Basic labor to stain hardwood floors with favorable site

conditions. Clean debris and dust from new, ready to finish

wood surface. Apply up to 2 coats stain. Ready for clear

coating. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

4881.00 1.00 4,881.00

Service Water Line Re-Routing Labor, Basic

Basic labor to move water line with favorable site

conditions. Install coupling and up to 10m/30ft water line for

single piping run. Connect, route, secure and leak test

rerouted line. Route in wall/underfloor only. Demolition,

structural modifications and surface restoration are NOT

included. Wall/floor surface restoration if needed is extra.

Includes planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

3765.00 1.00 3,765.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 38 of

63
Service House Repiping Labor, Basic

Basic labor to repipe house water supply lines with

favorable site conditions. For typical 3 bath,1 water heater.

Remove existing piping between utility meter and all

fixtures. Fit, secure and test new piping, fixture shutoff

valves. Pass permit inspections. Apply basic patch to any

damaged wall/surface access points. Remove old piping

and all related job debris. Concrete break out and repair

specified separately. Includes planning, equipment and

material acquisition, area preparation and protection, setup

and cleanup.

8717.00 1.00 8,717.00

Service House Repiping Job Supplies

Cost of related materials and supplies typically required to

repipe house water supply lines including: fittings, mounting

hardware and connectors.

1552.00 1.00 1,552.00

Service Toilet Drain Pipe Installation Labor, Basic

Basic labor to install toilet drain pipe with favorable site

conditions. Install toilet flange at floor level, primary drain

connection fitting and up to 10m/30ft of properly sloped

drain line. Secure and leak test. Route in wall/underfloor

only. Demolition, structural modifications and surface

restoration are NOT included. Includes planning, equipment

and material acquisition, area preparation and protection,

setup and cleanup.

1049.00 3.00 3,147.00

NOTES: Court St Tavern

Subtotal 33,121.00

Total 33,121.00

Amount Paid 33,121.00

Balance Due $0.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 39 of

63
Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 112

Invoice Date 04/01/2022

Due Date 04/30/2022

Item Description Unit Price Quantity Amount

Service Brick Painting Cost

Non-discounted retail pricing for: Exterior paint. Latex

based, paint and primer in one. Flat, eggshell and

semi-gloss finish options. For wood, vinyl, masonry, stucco,

brick. Mildew resistant. 15 yr warranty. Quantity includes

typical waste overage, material for repair and local delivery.

1999.00 1.00 1,999.00

Service Brick Painting Labor, Basic

Basic labor to paint brick with favorable site conditions. Prep

up to 2 hr per 350SF - remove loose paint, spot prime and

caulk edges, gaps. Roll / brush 2 coats of paint. Includes

planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

8744.00 1.00 8,744.00

Service rick Painting Equipment Allowance

Job related costs of specialty equipment used for job quality

and efficiency, including: 115V, 10+ amp electric paint

sprayer, 3000 psi. Daily rental. Consumables extra.

365.00 5.00 1,825.00

Service Brick Painting Job Supplies

Cost of related materials and supplies typically required to

paint brick including: masking tape and paper, surface

repair material, solvents and cleanup supplies

521.00 1.00 521.00

Service Power Wash Surface

Clear surface of solid debris. Apply cleaner with light

scrubbing. Power wash and rinse surface.

1250.00 1.00 1,250.00

Service Fence Power Washing Labor, Basic

Basic labor to power wash fence with favorable site

conditions. Clear surface of dirt and debris. Apply cleaner

with light brushing. Power wash and power rinse 1 side of

fence surface. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

1500.00 1.00 1,500.00

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Service Fence Power Washing Job Supplies

Cost of related materials and supplies typically required to

power wash fence including: basic cleaning solutions, tool

and machine consumables and disposable cleaning

materials.

638.00 1.00 638.00

Service Front Door Refinishing Labor, Basic

Basic labor to refinish front door with favorable site

conditions. Remove existing finish. Repair minor defects.

Apply new finish. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

1806.00 4.00 7,224.00

Service Glass Repair Labor, Basic

Basic labor to replace glass with favorable site conditions.

For single pane. Remove broken glass, putty and existing

glazing points. Install new glass pane and glazing points.

Fill, level and smooth glazing compound. Includes planning,

equipment and material acquisition, area preparation and

protection, setup and cleanup

2408.00 1.00 2,408.00

Service Glass Pane Debris Disposal

Costs to load and haul away old materials, installation

waste and associated debris.

550.00 1.00 550.00

Service Window Repair Labor, Basic

Basic labor to repair window with favorable site conditions.

Replace glass in single lite, dual pane glass unit. Includes

planning, equipment and material acquisition, area

preparation and protection, setup and cleanup

2292.00 1.00 2,292.00

Service Window Repair Job Supplies

Cost of related materials and supplies typically required to

repair window including: fasteners, shims, flashing, drip cap,

perimeter foam insulation and exterior caulking.

717.00 1.00 717.00

Service Window Debris Disposal

Costs to load and haul away old materials, installation

waste and associated debris.

550.00 1.00 550.00

NOTES: Rebel Cafe & Garden

Subtotal 30,218.00

Total 30,218.00

Amount Paid 30,218.00

Balance Due $0.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 41 of

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Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 57

Invoice Date 04/14/2022

Due Date 05/15/2022

Item Description Unit Price Quantity Amount

Service Ceiling Outlet Box Installation Labor, Basic

Basic labor to install ceiling outlet box with favorable site

conditions. Turn off power to circuit. Layout location and cut

mounting hole. Mount remodeling style electrical box. Add

or modify NM-B wiring from existing circuit. Secure NM-B

wiring to framing. Connect receptacle. Power circuit and

verify proper operation. Includes planning, equipment and

material acquisition, area preparation and protection, setup

and cleanup.

6799.00 1.00 6,799.00

Service Ceiling Outlet Box Installation Job Supplies

Cost of related materials and supplies typically required to

install ceiling outlet box including: connectors, fittings,

junction boxes and fasteners.

1554.00 1.00 1,554.00

Service Add AFCI Circuit Protection

Shutoff power to circuit. Remove existing circuit breaker.

Add new 15A or 20A Arc Fault Circuit Interrupt breaker.

Repower and verify proper operation. For existing systems

with compatible AFCI breaker option only

1933.00 3.00 5,799.00

Service Electrical Service Panel Cost

Non-discounted retail pricing for: 100A primary electrical

load center. 20 slot BR type circuit breakers. UL and CSA

rated. 10 yr warranty.

2900.00 1.00 2,900.00

Service Electrical Service Panel Upgrade Labor, Basic

Basic labor to upgrade electrical service panel with

favorable site conditions. Unwire and dispose of existing

panel. Fit and mount new panel. Wire and connect up to 20

circuits and breakers. Includes planning, equipment and

material acquisition, area preparation and protection, setup

and cleanup.

6128.00 1.00 6,128.00

Service Electrical Service Panel Debris Disposal

Costs to load and haul away old materials, installation

waste and associated debris.

1250.00 1.00 1,250.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 42 of

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Service Circuit Breaker Cost

Non-discounted retail pricing for: 125V 20A AFCI/GFCI

circuit breaker. Residential. UL and CSA rated

1189.00 1.00 1,189.00

Service Circuit Breaker Installation Labor, Basic

Basic labor to install circuit breaker with favorable site

conditions. Shut off power to panel. Connect circuit wiring to

panel location for circuit breaker. Install, repower and verify

proper operation of new circuit breaker. For existing panel

with free circuits. Circuit wiring and any other modifications

to service panel not included. Includes planning, equipment

and material acquisition, area preparation and protection,

setup and cleanup

6105.00 1.00 6,105.00

Service Wall Mounted Light Cost

Non-discounted retail pricing for: 36" wide, 4 light bar style

fixture with glass insert. Chrome | brushed nickel | brass

finish options. 120 V.

10087.00 1.00 10,087.00

Service Wall Mounted Lighting Installation Labor, Basic

Basic labor to install wall mounted lighting with favorable

site conditions. Turn off power to circuit. Layout and cut

mounting hole. Add or modify wiring from existing switch or

parallel fixture. Route and connect wiring to fixture. Place

fixture and trim piece. Power and test. Includes planning,

equipment and material acquisition, area preparation and

protection, setup and cleanup.

6081.00 1.00 6,081.00

NOTES: Winston's

NYC

Subtotal 47,892.00

Total 47,892.00

Amount Paid 47,892.00

Balance Due $0.00

Case 9:20-cv-81205-RAR Document 1385-1 Entered on FLSD Docket 08/29/2022 Page 43 of

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Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 111

Invoice Date 04/19/2022

Due Date 05/24/2022

Item Description Unit Price Quantity Amount

Service Granite Countertop Cost

Non-discounted retail pricing for: Mid grade, 30mm thick

solid stone countertop. Slab lengths to 110". Price assumes

80+% slab utilization. Quantity includes typical waste

overage, material for repair and local delivery.

47389.00 1.00 47,389.00

Service Granite Countertop Installation Labor, Basic

Basic labor to install granite countertops with favorable site

conditions. Template, layout and fabricate granite

countertop with basic edge. Add 1 sink and faucet cutout.

Install and secure countertop. Includes planning, equipment

and material acquisition, area preparation and protection,

setup and cleanup.

10903.00 1.00 10,903.00

Service Remove Existing Countertop

Protect flooring, cabinetry and appliances in proximity to

countertop sections to be removed. Detach countertop from

adjacent and mounting surfaces. Break into haul able

pieces. Remove from home and dispose of responsibly.

Material cost includes dump fee.

2752.00 1.00 2,752.00

Service Built-In Refrigerator Cost

Non-discounted retail pricing for: 18.6 cubic foot refrigerator.

Stainless steel door. 3 shelves and adjustable storage bins.

1 yr limited warranty.

7120.00 1.00 7,120.00

Service Built-In Refrigerator Installation Labor, Basic

Basic labor to install built-in refrigerator with favorable site

conditions. Measure, place and secure mounting hardware.

Connect appliance to existing utility connections behind

appliance. Place, level and secure appliance to mounting

hardware and verify operation. Includes planning,

equipment and material acquisition, area preparation and

protection, setup and cleanup.

2250.00 1.00 2,250.00

Service Costs to load and haul away old materials, installation

waste and associated debris.

2250.00 1.00 2,250.00

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NOTES: Ainsworth

26th St

Upstairs

Subtotal 72,664.00

Total 72,664.00

Amount Paid 72,664.00

Balance Due $0.00

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Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 76

Invoice Date 05/01/2022

Due Date 05/31/2022

Item Description Unit Price Quantity Amount

Service Subfloor Framing Labor, Basic

Basic labor to frame subfloor with favorable site conditions.

Layout, fabricate and install conventional wood framed

perimeter and pier foundation. Beams 4' spacing and 2"x8"

joists spaced 16" on center. Includes planning, equipment

and material acquisition, area preparation and protection,

setup and cleanup

25271.00 1.00 25,271.00

Service Subfloor Framing Job Supplies

Cost of related materials and supplies typically required to

frame subfloor including: fasteners, connectors and

dimensional lumber for openings.

7529.00 1.00 7,529.00

Service Basement Floor Preparation Labor, Basic

Basic labor to prepare basement flooring with favorable site

conditions. Install and plane level 2"x2" sleepers 16" on

center over vapor barrier. Glue and screw 1" tongue and

groove subfloor to sleepers. Includes planning, equipment

and material acquisition, area preparation and protection,

setup and cleanup.

16565.00 1.00 16,565.00

Service Basement Floor Preparation Job Supplies

Cost of related materials and supplies typically required to

prepare basement flooring including: fasteners, connectors

and dimensional lumber for openings.

3157.00 1.00 3,157.00

Service Debris Removal 1250.00 1.00 1,250.00

NOTES: Winston's

NYC

Basement

Subtotal 53,772.00

Total 53,772.00

Amount Paid 53,772.00

Balance Due $0.00

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Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 0000063

Invoice Date 08/22/2022

Due Date 08/22/2022

Item Description Unit Price Quantity Amount

Service Split Ac Unit Cost

Non-discounted retail pricing for: 2 Ton 16 SEER mini-split

heat pump system. 9,000 BTU indoor air handler with

remote control. Requires 240V 25A. 10 yr limited warranty.

3468.00 4.00 13,872.00

Service plit System Air Conditioner Installation Labor, Basic

Basic labor to install split system air conditioner with

favorable site conditions. Install new 240V 20A circuit.

Mount and secure condenser to new pad. Fabricate pass

through. Connect air handlers and mount unit. Connect,

insulate and enclose lines between condenser air handler.

Connect control panel and power source. Charge

condenser with up to 12 lbs of R410a refrigerant. Verify

proper operation. Includes planning, equipment and

material acquisition, area preparation and protection, setup

and cleanup.

11001.00 1.00 11,001.00

Service Hvac Ductwork Cost

Non-discounted retail pricing for: 8 in dia flexible duct,

fittings and register. Polyester duct shell with R8 insulation.

1 yr limited warranty. Quantity includes typical waste

overage, material for repair and local delivery.

1824.00 1.00 1,824.00

Service Hvac Ductwork Installation Labor, Basic

Basic labor to install ductwork with favorable site conditions.

Install 10" diameter metal ducting, with 1 damper and 1

register per 20 ft. Assemble, secure, support and connect

duct sections. Air seal and tape joints. Boots, registers and

other fittings are not included. Includes planning, equipment

and material acquisition, area preparation and protection,

setup and cleanup.

6779.00 1.00 6,779.00

Service Heat Pump Cost

Non-discounted retail pricing for: 2.5 Ton 14 SEER heat

pump system. For horizontal, up flow, down flow and

vertical installation. Requires 240V 25A electrical

connection required at unit. 10 yr limited warranty.

4692.00 1.00 4,692.00

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Service Heat Pump Installation Labor, Basic

Basic labor to install heat pump with favorable site

conditions. Install dedicated 240V 20A circuit. Mount and

secure condenser to new pad. Install heat exchanger in

existing plenum. Connect, insulate lines between condenser

and heat exchanger. Connect existing thermostat. Charge

condenser with up to 12 lbs of R410a refrigerant. Power

unit. Verify proper cycling and temperature control. Includes

planning, equipment and material acquisition, area

preparation and protection, setup and cleanup.

1989.00 1.00 1,989.00

NOTES: Winston's

NYC

Basement

Subtotal 40,157.00

Total 40,157.00

Amount Paid 40,157.00

Balance Due $0.00

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Dayne Property Management Group

44 Center Pl

Staten Island NY 10306

License # 2036484-DCA

Bushwick Beer Garden

2 Knickerbocker Ave

Brooklyn NY 11237

I N V O I C E

Invoice # 0000064

Invoice Date 08/22/2022

Due Date 08/22/2022

Item Description Unit Price Quantity Amount

Service Membrane Roofing System Cost

Non-discounted retail pricing for: Structurally reinforced

membrane. For fully adhered or mechanically attached. 30

yr warranty. UV resistance and 100 mph wind rating.

Quantity includes typical waste overage, material for repair

and local delivery

13500.00 1.00 13,500.00

Service Membrane Roofing Installation Labor, Basic

Basic labor to install membrane roofing system with

favorable site conditions. Clear roof surface of debris.

Set/remove protruding nails. Cut and layout material, apply

recommended adhesive and roll. Seal edges and all roof

penetrations. Includes planning, equipment and material

acquisition, area preparation and protection, setup and

cleanup.

18547.00 1.00 18,547.00

Service Membrane Roofing Installation Job Supplies

Cost of related materials and supplies typically required to

install membrane roofing system including: fasteners,

underlayment, drip edges, sealant and basic flashing.

1258.00 1.00 1,258.00

Service Membrane Roofing Installation Equipment Allowance

Job related costs of specialty equipment used for job quality

and efficiency, including: Roof jacks, pneumatic roofing

nailer, shingle cutting tools. Daily rental. Consumables

extra.

365.00 10.00 3,650.00

Service Membrane Roofing System Debris Disposal

Costs to load and haul away old materials, installation

waste and associated debris.

3500.00 1.00 3,500.00

Service Install Green plastic grass around the whole building,

outside lounge in the front and rear

8500.00 1.00 8,500.00

Service Install three Outdoor lighting fixtures (signs) 6500.00 1.00 6,500.00

NOTES: Rebel Cafe & Garden

Back outside lounge

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Subtotal 55,455.00

Total 55,455.00

Amount Paid 55,455.00

Balance Due $0.00

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EXHIBIT C

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