This Pro-forma Complaint by Adoption (Check-off) and the Master Complaint which it 

adopts is being filed pursuant to the Order Regulating Proceedings, Judge Alvin K. Hellerstein, 

June 4, 2007, as relates to 21 MC 102 (AKH). Guidelines and other directives relative to 

additional filings, amendments, corrections and other matters as relate to the individual 

Complaint by Adoption (Check-Off Complaint) to be filed by the individual plaintiffs, in 

accordance with said Order, will be addressed by the Court in a future CMO. 

 I. 

 INTRODUCTION 

 

A Plaintiff-Specific Complaint by Adoption (Check-off Complaint), in the within format, 

is to be filed by each Plaintiff, and to be utilized and read in conjunction with the Master 

Complaint on file with the Court. Where applicable to the instant Plaintiff(s), specific paragraphs 

are to be marked with an “X,” and specific case information is to be set forth, inserting said 

information in the blank space, if provided. If Plaintiff wishes to assert additional allegations, 

plaintiffs should follow the procedure as outlined in the CMO # 4 governing the filing of the 

Master Complaint and Check-off Complaints. 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

 

IN RE LOWER MANHATTAN DISASTER SITE 

LITIGATION 

21 MC 102 (AKH) 

(INSERT PLAINTIFF NAME HERE) 

 Plaintiffs, 

DOCKET NO. 

_______________ 

COMPLAINT BY 

ADOPTION (CHECKOFF COMPLAINT) 

RELATED TO THE 

MASTER COMPLAINT 

 - against - 

PLAINTIFF(S) DEMAND 

A TRIAL BY JURY 

(SEE SECTION IV., PARTIES, WITHIN) 

 Defendants. 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 1 of 46
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Plaintiffs, as captioned above, by his/her/their attorneys, complaining of Defendant(s), 

respectfully allege: 

 1. All headings, paragraphs, allegations and Causes of Action in the entire Master Complaint 

are applicable to and are adopted by the instant Plaintiff(s) as if fully set forth herein, in addition 

to those paragraphs specific to the individual Plaintiff(s), as alleged within the individual Checkoff Complaint. 

 2. Plaintiffs adopt those allegations as set forth in the Master Complaint Section I, 

Introduction. 

II. 

JURISDICTION 

 3. Plaintiffs adopt those allegations as set forth in the Master Complaint Section II, 

Jurisdiction. 

 4. The Court’s jurisdiction over the subject matter of this action is: Founded upon Federal 

Question Jurisdiction, specifically 

 4A.-1. Air Transport Safety & System Stabilization Act of 2001, (or) 

 4A.-2. Federal Officers Jurisdiction, (or) 

 4A.-3. This Court has supplemental jurisdiction pursuant to 28 USC 

 §1367(a) based upon the New York Labor Law §200 and 

 §241(6), and common law negligence. 

 Other if an individual plaintiff is alleging a basis of jurisdiction not 

 stated above, plaintiffs should follow the procedure as outlined in the 

 CMO # 4 governing the filing of the Master Complaint and Check- off 

Complaints. 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 2 of 46
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 5. The Court’s jurisdiction of the subject matter of this action is: Contested, but the Court has 

already determined that it has removal jurisdiction over this action, pursuant to 28 U.S.C. §

1441. 

III. 

VENUE 

 6. Plaintiffs adopt those allegations as set forth in the Master Complaint Section III, Venue. 

IV.

 PARTIES 

 7. Plaintiffs adopt those allegations as set forth in the Master Complaint Section IV, Parties. 

 8. THE INJURED PLAINTIFF’S NAME IS (referencing the individual specifically injured 

and/or if deceased, hereinafter referred to as “Decedent Plaintiff”): ___ 

and the last four digits of his /her social security number are__________ or the last four 

digits of his/her federal identification number are ____________. 

 9. THE INJURED PLAINTIFF’S ADDRESS IS: ________________________________

 10. THE REPRESENTATIVE PLAINTIFF’S NAME IS (if “Injured Plaintiff” is deceased): 

________________________(hereinafter referred to as the “Representative Plaintiff”) 

 11. THE REPRESENTATIVE PLAINTIFF’S ADDRESS IS (if “Injured Plaintiff” is 

deceased): _______________________________________________________________ 

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 12. THE REPRESENTATIVE PLAINTIFF (if “Injured Plaintiff” is deceased) was appointed 

as Administrator of the Goods, Chattels and Credits which were of the “Injured Plaintiff” 

on ___________________________________, 

by the Surrogate Court, County of ___________, State of New York. 

 13. THE REPRESENTATIVE PLAINTIFF (if “Injured Plaintiff” is deceased) was appointed 

as Executor of the Estate of the “Injured Plaintiff” on 

___________________________________, by the Surrogate Court, County of 

______________, State of New York. 

 14. THE DERIVATIVE PLAINTIFF’S NAME: (hereinafter referred to as the “Derivative 

Plaintiff” and if deceased, hereinafter referred to as “Decedent Derivative Plaintiff”) 

_____________________ 

 15. THE DERIVATIVE PLAINTIFF’S ADDRESS: 

___________________________________ 

 16. THE REPRESENTATIVE DERIVATIVE PLAINTIFF’S NAME: (if “Derivative 

Plaintiff” is deceased) ______________________________________ 

 17. THE REPRESENTATIVE PLAINTIFF’S DERIVATIVE ADDRESS (if “Derivative 

Plaintiff” is deceased): _______________________ 

 18. THE REPRESENTATIVE DERIVATIVE PLAINTIFF was appointed as Administrator 

of the Goods, Chattels and Credits which were of the “Derivative Plaintiff” on 

__________________________, 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 4 of 46
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 by the Surrogate Court, County of ___________, State of New York. 

 19. THE REPRESENTATIVE DERIVATIVE PLAINTIFF was appointed as Executor of the 

Estate of the “Derivative Plaintiff” on ___________________________________, by the 

Surrogate Court, County of ______________, State of New York. 

 20. Injured Plaintiff, as aforementioned, is an individual and a resident of the State of New 

York residing at the aforementioned address. 

 21. Injured Plaintiff, as aforementioned, is an individual and a resident of (if other 

than New York) __________________, and resides at the aforementioned address. 

 22. Representative Plaintiff, as aforementioned, is a resident of the State of New York, 

residing at the aforementioned address. 

 23. Representative Plaintiff, as aforementioned, is an individual and a resident of (if other 

than New York)___________________, and resides at the aforementioned address. 

 24. Representative Plaintiff, as aforementioned, brings this claim in his/her representative 

capacity, as aforementioned on behalf of the Estate of the Decedent Plaintiff. 

 25. Derivative Plaintiff, as aforementioned, is a resident of the State of New York, residing 

at the aforementioned address. 

 26. Derivative Plaintiff, as aforementioned, is an individual and a resident of (if other than 

New York)___________________, and resides at the aforementioned address. 

 27. Representative Derivative Plaintiff, as aforementioned, is a resident of the State of New 

York, residing at the aforementioned address. 

 28. Representative Derivative Plaintiff, as aforementioned, is an individual and a resident of 

(if other than New York)___________________, and resides at the aforementioned 

address. 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 5 of 46
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 29. Representative Derivative Plaintiff, as aforementioned, brings this claim in his/her 

representative capacity, as aforementioned, on behalf of the Estate of the Derivative 

Plaintiff. 

30. The Derivative Plaintiff and or the Representative Derivative Plaintiff in his or her 

representative capacity on behalf of the estate of the Decedent Derivative Plaintiff was 

the: 

 a. SPOUSE at all relevant times herein, was lawfully married to Plaintiff, 

and brings this derivative action for her/his loss due to the injuries 

sustained by her husband/his wife, Injured Plaintiff. 

 Instructions: To the extent that plaintiff has specificity as to the information to be 

placed within the columns of the chart below, such should be provided. Additionally, 

to the extent that plaintiff has specificity as to differing areas or floors within a 

particular building or location, a separate line entry should be made for each area or 

floor within a building within which they worked. If plaintiff is unable at this time to 

enunciate a response to a particular column heading, the applicable column should 

be marked with an “X.” (See Sample Chart below) 

 Each sub-paragraph shall be deemed to allege: “The Injured Plaintiff at times 

relevant to the claims herein, worked at (address/location), on or at (the floor or 

area) for the following (dates of employment), while in the employ of (name of 

employer), maintaining the position of (job title), performing the activities of (job 

activity) and worked at said location for approximately (hours), working in the 

following shift (shift worked). i.e., “The Injured Plaintiff at times relevant to the 

claims herein, worked at 500 Broadway, on the 2nd floor, for the following dates, 

10/1/01-6/1/02, while in the employ of ABC Corp, maintaining the position of cleaner 

and performing activities including debris removal and worked on and/or at said 

floor or area for approximately 20 hours, working the 8-am-5PM shift.” 

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 31. The Injured Plaintiff worked at the address/location, on the following floors or areas, 

for following dates of employment, for the employer, in the job title of, performing 

the job activity of and for the number of hours, and for the shift worked, as specified 

on the following page. 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 7 of 46
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Sample Chart 

Total Hours Worked: 40

 ADDRESS/ 

LOCATION 

FLOOR(S)/ AREAS 

DATES OF EMPLOYMENT 

NAME OF EMPLOYER 

JOB TITLE 

JOB ACTIVITY HOURS 

WORKED 

SW

 31a *500 

Broadway 

 2 10/1/01-6/1/02 ABC CORP. CLEANER DEMOLITION/DEBRIS 

REMOVAL 

20 8

 31b 1600 

Broadway 

2 11/1/01-11/15/01 ABC CORP. CLEANER X 10 X 

 31c 1600 

Broadway 

basement 12/15/01-12/16/01 XYZ Corp. CLEANER X 10 X 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 8 of 46
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 ADDRESS/ 

LOCATION 

FLOOR(S)/ AREAS 

DATES OF EMPLOYMENT

NAME OF EMPLOYER 

JOB TITLE 

JOB ACTIVITY 

HOURS WORKED

 31a.  31b.  31c.  31d.  31e.  31f.  31g.  31h.  31i.  31j. 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 9 of 46
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 ADDRESS/ 

LOCATION 

FLOOR(S)/ AREAS 

DATES OF EMPLOYMENT

NAME OF EMPLOYER 

JOB TITLE 

JOB ACTIVITY 

HOURS WORKED

 31k.  31l.  31m.  31n.  31o.  31p.  31q.  31r.  31s. 

Other (Check here, if need for additional space and attach Rider and continue with same format as above) 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 10 of 46
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31t. The plaintiff worked at all buildings or locations for the total number of hours as 

indicated: ___________. 

 32. The Injured Plaintiff was exposed to and breathed noxious fumes on all dates, at the 

site(s) indicated above, unless otherwise specified. 

 33. The Injured Plaintiff was exposed to and inhaled or ingested toxic substances and 

particulates on all dates at the site(s) indicated above, unless otherwise specified 

 34. The Injured Plaintiff was exposed to and absorbed or touched toxic or caustic substances 

on all dates at the site(s) indicated above, unless otherwise specified 

 35. The Plaintiff, and/or if also applicable to derivative plaintiff, check here , or his/or 

representative, has not made a claim to the Victim Compensation Fund. Therefore, 

pursuant to §405(c)(3)(B)(i) of the Air Transportation Safety and System Stabilization 

Act, 49 U.S.C. 40101, the issue of waiver is inapplicable. 

 36. The Plaintiff and/or if also applicable to derivative plaintiff, check here , or his/or 

representative, has made a claim to the Victim Compensation Fund, which claim was not 

deemed “substantially complete.” The plaintiff therefore has not waived the “right to file 

a civil action (or be party to an action) in any Federal or State court for damages 

sustained as a result of the terrorist aircraft crashes of September 11,2001, except for civil 

actions to recover collateral source obligations.” 49 U.S.C. 40101 at § 405 (c)(3)(B). 

 37. The Plaintiff and/or if also applicable to derivative plaintiff, check here , or his/or 

representative, has made a claim to the Victim Compensation Fund, which claim was 

deemed “substantially complete” by the Fund. The plaintiff has therefore waived the 

“right to file a civil action (or be party to an action) in any Federal or State court for 

damages sustained as a result of the terrorist aircraft crashes of September 11, 2001, 

except for civil actions to recover collateral source obligations.” 49U.S.C. 40101 at 

Section 405 (c) (3) (B) 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 11 of 46
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 38. The Plaintiff and/or if also applicable to derivative plaintiff, check here , or his/or 

representative, has made a claim to the Victim Compensation Fund that was granted by 

the Fund. The plaintiff has therefore waived the “right to file a civil action (or be party to 

an action) in any Federal or State Court for damages sustained as a result of the terrorist 

aircraft crashes of September 11, 2002 except for civil actions to recover collateral source 

obligations.” 49 U.S. C. 40101 at Sec. 405 (c)(3) (B) 

 39. The Plaintiff and/or if also applicable to derivative plaintiff, check here , or his/or 

representative, has made a claim to the Victims Compensation Fund that was deemed 

ineligible prior to a determination of being substantially complete. 

 40. The Plaintiff and/or if also applicable to derivative plaintiff, check here , or his/or 

representative, has made a claim to the Victims Compensation Fund that was deemed 

ineligible subsequent to a determination of being substantially complete. 

 41. The allegations in the body of the Master Complaint, are asserted as against each 

defendant as checked off below. If plaintiff asserts additional allegations, buildings, 

locations and/or defendants plaintiffs should follow the procedure as outlined in the CMO 

# 4 governing the filing of the Master Complaint and Check-off Complaints. 

 42. The specific Defendants alleged relationship to the property, as indicated below or as 

otherwise the evidence may disclose, or their role with relationship to the work thereat, 

gives rise to liability under the causes of actions alleged, as referenced in the Master 

Complaint. 

 Instruction: The Defendant(s) names in the Master Complaint are re-stated below. The 

Defendant’s are listed by reference to the building and/or location at which this specific 

plaintiff alleges to have worked. Each sub- paragraph shall be deemed to allege: “With 

reference to (address), the defendant (entity) was a and/or the (relationship) of and/or at 

the subject property and/or in such relationship as the evidence may disclose,” (i.e. With 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 12 of 46
 12 12

reference to 4 Albany Street, defendant Bankers Trust Company, was the owner of the 

subject property and/or in such relationship as the evidence may disclose). 

 43. With reference to (address as checked below), the defendant (entity as checked below) 

was a and/or the (relationship as indicated below) of and/or at the subject property and/or 

in such relationship as the evidence may disclose. 

 

 (43-1) 4 ALBANY STREET 

 A. BANKERS TRUST COMPANY (OWNER) 

B. BANKERS TRUST NEW YORK CORPORATION (OWNER) 

 C. BANKERS TRUST CORP.(OWNER ) 

 D. DEUTSCHE BANK TRUST COMPANY AMERICAS (OWNER) 

 E. DEUTSCHE BANK TRUST CORPORATION (OWNER) 

 F. JONES LANG LASALLE AMERICAS, INC. (OWNER) 

 G. JONES LANG LASALLE SERVICES, INC. (OWNER) 

 H. AMBIENT GROUP, INC. (CONTRACTOR)

 I. RJ LEE GROUP, INC. (OWNER) 

 J. TISHMAN INTERIORS CORPORATION(CONTRACTOR) 

 

 (43-2) 99 BARCLAY STREET 

A. THE BANK OF NEW YORK COMPANY, INC. (OWNER) 

B. ONE WALL STREET HOLDINGS, LLC. (OWNER) 

 (43-3)101 BARCLAY STREET (BANK OF NEW YORK) 

A. THE BANK OF NEW YORK COMPANY, INC. (OWNER) 

B. ONE WALL STREET HOLDINGS, LLC. (OWNER) 

 

 (43-4)125 BARCLAY STREET 

A. ELAINE ESPEUT, AS TRUSTEE UNDER A DECLARATION OF 

TRUST (OWNER) 

B. FRANK MORELLI, AS TRUSTEE UNDER A DECLARATION OF 

TRUST (OWNER) 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 13 of 46
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C. 37 BENEFITS FUND TRUST (OWNER) 

 (43-5) 20 BROAD STREET 

 A. 20 BROAD ST. CO. (OWNER) 

 B. VORNADO OFFICE MANAGEMENT, LLC (AGENT) 

 (43-6) 30 BROAD STREET (CONTINENTAL BANK BUILDING) 

A. 30 BROAD STREET ASSOCIATES, LLC (OWNER) 

B. MURRAY HILL PROPERTIES (AGENT)

 (43-7) 40 BROAD STREET 

A. 40 BROAD, LLC (OWNER)

B. CB RICHARD ELLIS (AGENT)

 (43-8) 60 BROAD STREET 

A. WELLS 60 BROAD STREET, LLC (OWNER)

B. COGSWELL REALTY GROUP & WELLS REAL ESTATE FUNDS 

 (AGENT)

 (43-9) 75 BROAD STREET 

A 75 BROAD LLC (OWNER) 

B. JEMB REALTY CORP. (AGENT) 

 (43-10) 85 BROAD STREET 

A ASSAY PARTNERS (AGENT)

 (43-11)104 BROAD STREET (NEW YORK TELEPHONE COMPANY 

BUILDING) 

A. CITY OF NEW YORK (OWNER)

 (43-12) 1 BROADWAY 

A. KENYON & KENYON (OWNER) 

B. LOGANY LLC (OWNER) 

C. ONE BROADWAY, LLC (OWNER) 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 14 of 46
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 (43-13) 2 BROADWAY 

A. 2 BROADWAY, LLC (OWNER)

B. COLLIERS ABR, INC. (AGENT)

 (43-14) 25 BROADWAY 

A. 25 BROADWAY OFFICE PROPERTIES, LLC (OWNER)

B. ACTA REALTY CORP. (AGENT) 

 (43-15) 30 BROADWAY 

A. CONSTITUTION REALTY LLC (OWNER) 

 (43-16) 45 BROADWAY 

A. B.C.R.E. (AGENT)

 (43-17) 61 BROADWAY 

A. CROWN BROADWAY, LLC (OWNER) 

B. CROWN PROPERTIES, INC (OWNER) 

C. CROWN 61 ASSOCIATES, LP (OWNER) 

D. CROWN 61 CORP (OWNER) 

 (43-18) 71 BROADWAY 

A. ERP OPERATING UNLIMITED PARTNERSHIP (OWNER)

B. EQUITY RESIDENTIAL (AGENT) 

 (43-19) 90 EAST BROADWAY 

A. SUN LAU REALTY CORP. (OWNER) 

 (43-20) 111/113 BROADWAY 

A TRINITY CENTRE LLC (OWNER) 

B. CAPITAL PROPERTIES, INC. (OWNER) 

 (43-21) 115/119 BROADWAY 

A. TRINITY CENTRE LLC (OWNER) 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 15 of 46
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 (43-22) 120 BROADWAY (THE EQUITABLE BUILDING) 

A. BOARD OF MANAGERS OF THE 120 BROADWAY 

 CONDOMINIUM (CONDO #871) (OWNER) 

B. 120 BROADWAY, LLC (OWNER) 

C. 120 BROADWAY CONDOMINIUM (CONDO #871) (OWNER) 

D. 120 BROADWAY PROPERTIES, LLC (OWNER) 

E. 715 REALTY CO. (OWNER) 

F. SILVERSTEIN PROPERTIES, INC. (OWNER) 

G. 120 BROADWAY HOLDING, LLC (OWNER) 

H. CITIBANK, NA (OWNER) 

 (43-23) 140 BROADWAY 

A. MSDW 140 BROADWAY PROPERTY L.L.C. (OWNER) 

 (43-24) 150 BROADWAY 

A. 150 BROADWAY N.Y. ASSOCS. L.P. (OWNER) 

B. 150 BROADWAY CORP. (OWNER) 

C. BAILEY N.Y. ASSOCIATES (OWNER) 

D. AT&T WIRELESS SERVICES, INC. (OWNER) 

E. BROWN HARRIS STEVENS COMMERCIAL SERVICES, LLC 

(AGENT) 

 (43-25) 160 BROADWAY 

 A. DAROR ASSOCIATES, LLC (OWNER) 

 B. BRAUN MANAGEMENT, INC. (AGENT) 

 (43-26) 170 BROADWAY 

A. AMG REALTY PARTNERS, LP (OWNER) 

B. JONES LANG LASALLE AMERICAS, INC. (OWNER) 

C. JONES LANG LASALLE SERVICES, INC. (OWNER)

D. AMBIENT GROUP, INC. (CONTRACTOR)

 (43-27) 214 BROADWAY 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 16 of 46
 16 16

A. 122 BROADWAY, LLC (OWNER) 

 (43-28) 222 BROADWAY 

A. 222 BROADWAY, LLC (OWNER) 

B. SWISS BANK CORPORATION (OWNER) 

C. CUSHMAN & WAKEFIELD, INC. (OWNER)

D. CHASE MANHATTAN BANKING CORPORATION (OWNER) 

 (43-29) 225 BROADWAY 

A. 225 BROADWAY COMPANY LP (OWNER)

B. BRAUN MANAGEMENT, INC. (OWNER)

 (43-30) 230 BROADWAY 

A. 233 BROADWAY OWNERS, LLC (OWNER)

 (43-31) 233 BROADWAY 

 A. 233 BROADWAY OWNERS, LLC (OWNER) 

 (43-32) 250 BROADWAY 

A. 1221 AVENUE HOLDINGS, LLC (OWNER)

 (43-33) 125 CEDAR STREET 

A. 120 LIBERTY ST., LLC (OWNER) 

 

 (43-34) 130 CEDAR STREET 

A. AJ GOLDSTEIN & CO. (OWNER) 

 B. CAROL GAYNOR, AS TRUSTEE OF THE CAROL 

 GAYNOR TRUST (OWNER) 

 C. MATTHEW A. GELBIN, AS TRUSTEE OF THE GELBIN 

 FAMILY (OWNER) 

 D. NATALIE S. LEBOW, AS TRUSTEE OF THE JERRY P. 

 LEBOW FAMILY TRUST (OWNER) 

 E. NATALIE S. LEBOW, AS TRUSTEE OF THE JEREMIAH 

 PHILIP LEBOW REVOCABLE TRUST (OWNER) 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 17 of 46
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 F. CAROL GAYNOR TRUST (OWNER) 

 G. PAMELA BETH KLEIN, AS TRUSTEE OF THE PAMELA 

 AND ROWAN KLEIN TRUST (OWNER) 

 H. ROWAN K. KLEIN, AS TRUSTEE OF THE PAMELA AND 

 ROWAN KLEIN TRUST (OWNER) 

 I. FRED GOLDSTEIN (OWNER) 

 J. MARGARET G. WATERS (OWNER) 

 K. MARGUERITE K. LEWIS, AS TRUSTEE UNDER THE LAST 

 WILL AND TESTAMENT OF LOUIS W. GOLDSTEIN (OWNER)

 L. HERMAN L. BLUM, AS TRUSTEE UNDER THE LAST WILL 

 AND TESTAMENT OF LOUIS W. GOLDSTEIN (OWNER)

M. SYLVIA R. GOLDSTEIN (OWNER) 

N. RUTH G. LEBOW (OWNER) 

 O. HAROLD G. GOLDSTEIN, AS TRUSTEE UNDER 

 DECLARATION OF TRUST (OWNER)

 P. IDELL GOLDSTEIN, AS TRUSTEE UNDER DECLARATION 

 OF TRUST (OWNER)

 Q. HARLAND GAYNOR, AS TRUSTEE UNDER DECLARATION 

 OF TRUST (OWNER)

 R. SHIRLEY G. SHOCKLEY, AS TRUSTEE UNDER 

 DECLARATION OF TRUST (OWNER)

 S. BETTY JEAN GRANQUIST (OWNER)

 T. CAROL MERRIL GAYNOR (OWNER)

 U. ALAN L. MERRIL (OWNER)

 (43-35) 90 CHAMBERS STREET 

 90 CHAMBERS REALTY, LLC (OWNER)

 (43-36) 105 CHAMBERS STREET 

 DATRAN MEDIA (OWNER) 

 (43-37) 145 CHAMBERS STREET 

A. 145 CHAMBERS A CO. (OWNER) 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 18 of 46
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 (43-38) 199 CHAMBERS STREET (BOROUGH OF MANHATTAN 

COMMUNITY COLLEGE (CUNY)) 

A. BOROUGH OF MANHATTAN COMMUNITY COLLEGE 

 (43-39) 345 CHAMBERS STREET (STUYVESANT HIGH SCHOOL) 

 A. TRIBECA LANDING L.L.C. (OWNER) 

B. BOARD OF EDUCATION OF THE CITY OF NEW YORK 

(OWNER) 

C. NEW YORK CITY SCHOOL CONSTRUCTION AUTHORITY 

(OWNER) 

D. THE CITY OF NEW YORK (OWNER) 

E. BATTERY PARK CITY AUTHORITY (OWNER) 

 F. DEPARTMENT OF BUSINESS SERVICES (AGENT)

 (43-40) 400 CHAMBERS STREET 

A. THE RELATED COMPANIES, LP (OWNER) 

B RELATED MANAGEMENT CO., LP (OWNER) 

 C. THE RELATED REATLY GROUP, INC (OWNER) 

 D. RELATED BPC ASSOCIATES, INC. (OWNER) 

 

 (43-41) 55 CHURCH STREET (MILLENIUM HILTON HOTEL) 

 CDL NEW YORK LLC MILLENIUM BROADWAY (OWNER)

 (43-42) 90 CHURCH STREET (POST OFFICE) 

 A. 90 CHURCH STREET LIMITED PARTNERSHIP (OWNER) 

 B. BOSTON PROPERTIES, INC. (OWNER) 

 C. STUCTURE TONE (UK), INC. (CONTRACTOR)

 D. STRUCTURE TONE GLOBAL SERVICES, INC. 

 (CONTRACTOR) 

 E. BELFOR USA GROUP, INC. (CONTRACTOR)

F. AMBIENT GROUP, INC. (CONTRACTOR)

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 19 of 46
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 (43-43) 99 CHURCH STREET 

A. MOODY’S HOLDINGS, INC. (OWNER) 

B. GRUBB & ELLIS MANAGEMENT SERVICES (AGENT)

 (43-44) 100 CHURCH STREET 

A. THE CITY OF NEW YORK (OWNER) 

B. 100 CHURCH LLC (OWNER) 

C. ZAR REALTY MANAGEMENT CORP. (AGENT)

D. MERRILL LYNCH & CO, INC. (OWNER) 

E. AMBIENT GROUP, INC. (CONTRACTOR)

F. INDOOR ENVIRONMENTAL TECHNOLOGY, INC. 

 (CONTRACTOR/AGENT) 

G. GPS ENVIRONMENTAL CONSULTANTS, INC. 

 (CONTRACTOR/AGENT

H. CUNNINGHAM DUCT CLEANING CO., INC. (CONTRACTOR)

I. TRC ENGINEERS, INC. (CONTRACTOR/AGENT

J. INDOOR AIR PROFESSIONALS, INC. (CONTRACTOR/AGENT

K. LAW ENGINEERING P.C. (CONTRACTOR/AGENT

L. ROYAL AND SUNALLIANCE INSURANCE GROUP, PLC 

 (OWNER) 

 (43-45) 110 CHURCH STREET 

A. 110 CHURCH LLC (OWNER)

B. 53 PARK PLACE LLC (OWNER)

C. ZAR REALTY MANAGEMENT CORP. (AGENT)

D. LIONSHEAD DEVELOPMENT LLC (OWNER/AGENT) 

E. LIONSHEAD 110 DEVELOPMENT LLC (OWNER/AGENT)

 (43-46) 120 CHURCH STREET (BANK OF NEW YORK) 

A. 110 CHURCH LLC (OWNER) 

B. 53 PARK PLACE LLC (OWNER)

C. ZAR REALTY MANAGEMENT CORP. (AGENT) 

D. LIONSHEAD DEVELOPMENT LLC (OWNER/AGENT)

E. LIONSHEAD 110 DEVELOPMENT LLC (OWNER/AGENT) 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 20 of 46
 20 20

 (43-47) 22 CORTLANDT STREET (CENTURY 21) 

A. MAYORE ESTATES LLC (OWNER) 

B. 80 LAFAYETTE ASSOCIATES, LLC (OWNER)

C. MAYORE ESTATES LLC AND 80 LAFAYETTE ASSOCIATION LLC 

AS TENANTS IN COMMON (OWNER)

D. BLUE MILLENNIUM REALTY LLC (OWNER) 

E. CENTURY 21, INC. (OWNER)

F. B.R. FRIES & ASSOCIATES, INC. (AGENT)

G. STONER AND COMPANY, INC. (AGENT)

H. HILLMAN ENVIRONMENTAL GROUP, LLC. 

(AGENT/CONTRACTOR) 

I GRUBB & ELLIS MANAGEMENT SERVICES (AGENT) 

 (43-48) 26 CORTLANDT STREET (CENTURY 21) 

A. BLUE MILLENNIUM REALTY LLC (OWNER)

B. CENTURY 21 DEPARTMENT STORES LLC (OWNER)

C. GRUBB & ELLIS MANAGEMENT SERVICES (AGENT) 

 (43-49) 7 DEY STREET (GILLESPI BUILDING) 

A. SAKELE BROTHERS LLC (OWNER)

 (43-50) 1 FEDERAL PLAZA 

 US GOVERNMENT (OWNER) 

 (43-51) 26 FEDERAL PLAZA (JACOB K. JAVITS FEDERAL BUILDING) 

A. TRIO ASBESTOS REMOVAL (CONTRACTOR) 

 (43-52) 163 FRONT STREET 

A. AMERICAN INTERNATIONAL REALTY CORP. (OWNER)

B. AMERICAN INTERNATIONAL GROUP (OWNER)

 (43-53) 77 FULTON STREET 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 21 of 46
 21 21

A. SOUTHBRIDGE TOWER, INC. (OWNER)

 (43-54) GATE HOUSE 

A. THE CITY OF NEW YORK (OWNER) 

 (43-55) 100 GOLD STREET 

A. CITY WIDE ADMINISTRATIVE SERVICES (OWNER)

 (43-56) 240 GREENE STREET 

A. NEW YORK UNIVERSITY (OWNER)

B. DORMITORY AUTHORITY OF THE STATE OF NEW YORK 

 (OWNER)

 (43-57) 70 GREENWICH STREET (PARKING GARAGE) 

 A. EDISON PARKING MANAGEMENT, L.P. (OWNER/AGENT)

 B. ALLRIGHT PARKING MANAGEMENT, INC. 

 (OWNER/AGENT)

 C. CENTRAL PARKING SYSTEM OF NEW YORK, INC. 

 (OWNER/AGENT)

 (43-58) 88 GREENWICH STREET 

A. BLACK DIAMONDS LLC (OWNER)

B. 88 GREENWICH LLC (OWNER)

 (43-59) 108 GREENWICH STREET 

A. JOSEPH MARTUSCELLO (OWNER) 

 (43-60) 114 GREENWICH STREET 

A. SENEX GREENWICH REALTY ASSOCIATES, LLC (OWNER)

 (43-61) 120 GREENWICH PLACE 

A. SENEX GREENWICH REALTY ASSOCIATES (OWNER)

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 22 of 46
 22 22

 (43-62) 234 GREENWICH STREET 

A. THE BANK OF NEW YORK (OWNER)

 (43-63) 390 GREENWICH STREET 

A. STATE STREET BK & TRTETC (OWNER) 

B. CITIGROUP CORPORATE REALTY SERVICES (AGENT) 

 (43-64) 7 HANOVER SQUARE 

A. MB REAL ESTATE (AGENT) 

B. SEVEN HANOVER ASSOCIATES (OWNER) 

 (43-65) 40 HARRISON STREET (INDEPENDENCE PLAZA) 

A. AM & G WATERPROOFING LLC (CONTRACTOR) 

 (43-66) 60 HUDSON STREET 

 60 HUDSON OWNER, LLC (OWNER) 

 (43-67) 315 HUDSON STREET 

 315 HUDSON LLC (OWNER)

 (43-68) 2 JOHN STREET 

A. GOTHAM ESTATE, LLC (OWNER)

B. GOTHAM ESTATE, LLC (AGENT) 

 (43-69) 45 JOHN STREET 

A. BANK OF NEW YORK (OWNER)

 (43-70) 99 JOHN STREET 

A. ROCKROSE DEVELOPMENT CORP. (OWNER)

 (43-71) 100 JOHN STREET 

A. MAZAL GROUP (OWNER) 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 23 of 46
 23 23

B. NEWMARK KNIGHT FRANK (AGENT)

 (43-72) ONE LIBERTY PLAZA 

A. NEW LIBERTY PLAZA LP (OWNER)

B. WORLD FINANCIAL PROPERTIES, L.P. (OWNER)

C. WFP ONE LIBERTY PLAZA CO., L.P. (OWNER)

D. ONE LIBERTY PLAZA (OWNER)

E. BROOKFIELD FINANCIAL PROPERTIES, INC. (OWNER)

F. WFP ONE LIBERTY PLAZA, CO. GP, CORP. (OWNER)

G. THE ONE LIBERTY PLAZA CONDOMINIUM 

(CONDO #1178) (OWNER)

H. THE BOARD OF MANAGERS OF THE ONE LIBERTY PLAZA C 

 ONDOMINIUM (CONDO #1178) (OWNER)

I. BFP ONE LIBERTY PLAZA CO., LLC (OWNER)

J. NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. 

(OWNER) 

K. NEW YORK CITY INDUSTRIAL DEVELOPMENT AGENCY 

(OWNER) 

L. NEW YORK CITY ECONOMIC DEVELOPMENT 

 CORPORATION (OWNER)

M. NEW YORK CITY INDUSTRIAL DEVELOPMENT 

 CORPORATION (OWNER)

N. BLACKMON-MOORING-STEAMATIC CATASTOPHE, 

 INC. d/b/a BMS CAT (AGENT/CONTRACTOR) 

O. HILLMAN ENVIRONMENTAL GROUP, LLC. 

(AGENT/CONTRACTOR) 

P. GENERAL RE SERVICES CORP. (OWNER/AGENT) 

 (43-73) 10 LIBERTY STREET 

 LIBERTY STREET REALTY (OWNER) 

 (43-74) 30 LIBERTY STREET 

A. CHASE MANHATTAN BANK (OWNER)

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 24 of 46
 24 24

 (43-75) 33 LIBERTY STREET 

 VERIZON NEW YORK, INC. (OWNER) 

 (43-76) 114 LIBERTY STREET 

 WARWICK & CO. (OWNER) 

 (43-77) 130 LIBERTY STREET (DEUTSCHE BANK BUILDING) 

A. DEUTSCHE BANK TRUST CORPORATION (OWNER)

B. DEUTSCHE BANK TRUST COMPANY (OWNER)

C. BANKERS TRUST CORPORATION (OWNER)

D. DEUTSCHE BANK TRUST COMPANY AMERICAS (OWNER)

E. THE BANK OF NEW YORK TRUST COMPANY NA (OWNER)

F. BT PRIVATE CLIENTS CORP. (OWNER)

G. TISHMAN INTERIORS CORPORATION (CONTRACTOR) 

H. TULLY CONTSRUCTION CO., INC. (CONTRACTOR)

I. TULLY INDUSTRIES (CONTRACTOR) 

 (43-78) 377 LIBERTY STREET 

 A LIBERTY HOUSE CONDOMINIUM (OWNER) 

 (43-79) 41 MADISON AVENUE 

A. 41 MADISON LP/RUDIN MGMT CO. (OWNER/AGENT) 

 (43-80) 59 MAIDEN LANE 

A. 59 MAIDEN LANE ASSOCIATES, LLC (OWNER)

 (43-81) 80 MAIDEN LANE 

A. BATTERY PARK CITY AUTHORITY (OWNER)

 (43-82) 90 MAIDEN LANE 

A. MAIDEN 80/90 LLC (OWNER)

B. AM PROPERTY HOLDING CORP (OWNER)

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 25 of 46
 25 25

 (43-83) 95 MAIDEN LANE 

A. CHICAGO 4, L.L.C. (OWNER)

B. 2 GOLD L.L.C., SUCCESSOR BY MERGER TO CHICAGO 4, L.L.C. 

(OWNER) 

 (43-83-1) 125 MAIDEN LANE 

A. 125 MAIDEN LANE EQUITIES, LLC (OWNER)

 (43-84) MARRIOTT FINANCIAL CENTER HOTEL 

A. HMC CAPITOL RESOURCES CORP. (AGENT)

B. HMC FINANCIAL CENTER, INC. (OWNER)

C. MARRIOTT HOTEL SERVICES, INC. (AGENT)

D. MK WEST STREET COMPANY (AGENT)

E. MK WEST STREET COMPANY, L.P. (AGENT)

 (43-85) 101 MURRAY STREET 

 A. ST. JOHN’S UNIVERSITY (OWNER)

 (43-86) 110 MURRAY STREET 

A. THE BANK OF NEW YORK COMPANY, INC. (OWNER)

B. ONE WALL STREET HOLDINGS, LLC. (OWNER)

 (43-87) 26 NASSAU STREET (1 CHASE MANHATTAN BANK 

A. J.P. MORGAN CHASE CORPORATION (OWNER) 

 (43-88) 81 NASSAU STREET 

A. SYMS CORP. (OWNER)

 (43-89) 4 NEW YORK PLAZA 

A. MANUFACTURERS HANOVER TRUST COMPANY 

 (OWNER) 

 (43-90) 102 NORTH END AVENUE 

A. HARRAH’S OPERATING COMPANY, INC. (OWNER/AGENT) 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 26 of 46
 26 26

B. HILTON HOTELS CORPORATION (OWNER)

 (43-91) PACE UNIVERSITY 

 PACE UNIVERSITY (OWNER)

 (43-92) 75 PARK PLACE 

A. RESNICK 75 PARK PLACE, LLC (OWNER) 

B. JACK RESNICK & SONS, INC. (AGENT)

 (43-93) 299 PEARL STREET 

 SOUTHBRIDGE TOWERS, INC. (OWNER)

 (43-94) 375 PEARL STREET 

A. VERIZON COMMUNICATIONS, INC. (OWNER) 

B. RICHARD WINNER (AGENT) 

C. VERIZON NEW YORK, INC. (OWNER)

 (43-95) PICASSO PIZZERIA RESTAURANT 

 CITY OF NEW YORK (OWNER)

 (43-96) 30 PINE STREET 

A. JP MORGAN CHASE (OWNER) 

B. JP MORGAN CHASE (AGENT) 

 (43-97) 70 PINE STREET 

A. AMERICAN INTERNATIONAL REALTY CORP. (OWNER)

B. AMERICAN INTERNATIONAL GROUP, INC. (OWNER)

C. AIG REALTY, INC. (OWNER)

 (43-98) 80 PINE STREET 

A. 80 PINE, LLC (OWNER)

B. RUDIN MANAGEMENT CO., INC. (AGENT)

 

 (43-99) P.S. 234 INDEPENDENCE SCHOOL 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 27 of 46
 27 27

 SABINE ZERARKA (OWNER)

 (43-100) 30 ROCKEFELLER PLAZA 

A. TISHMAN SPEYER PROPERTIES (OWNER)

B. V CUCINIELLO (OWNER) 

 (43-101) 1-9 RECTOR STREET 

A. 50 TRINITY, LLC (OWNER)

B. BROADWAY WEST STREET ASSOCIATES LIMITED 

 PARTNERSHIP (OWNER)

C. HIGHLAND DEVELOPMENT LLC (OWNER)

D. STEEPLECHASE ACQUISITIONS LLC (OWNER)

E. BLACK DIAMONDS LLC (OWNER)

F. 88 GREENWICH LLC (OWNER)

 (43-102) 19 RECTOR STREET 

 A. BLACK DIAMONDS LLC (OWNER)

B. 88 GREENWICH LLC (OWNER)

 (43-103) 40 RECTOR STREET 

A. NEW YORK TELEPHONE COMPANY (AGENT) 

 (43-104) 225 RECTOR PLACE 

 A. LIBERTY VIEW ASSOCIATES, L.P. (OWNER)

 B. AMG REALTY PARTNERS, LP (OWNER)

 C. RELATED MANAGEMENT CO., LP (AGENT) 

 D. THE RELATED REALTY GROUP, INC. (OWNER)

 E. THE RELATED COMPANIES, LP (OWNER)

 F. RELATED BPC ASSOCIATES, INC. (OWNER)

 

 (43-105) 280 RECTOR PLACE (THE SOUNDING) 

A. BROWN HARRIS STEVENS (AGENT) 

 B. THE RELATED COMPANIES, LP (OWNER)

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 28 of 46
 28 28

 (43-106) 300 RECTOR PLACE (BATTERY POINTE) 

A. BATTERY POINTE CONDOMINIUMS (OWNER)

B. RY MANAGEMENT (AGENT) 

 (43-107) 377 RECTOR PLACE (LIBERTY HOUSE 

A. MILFORD MANAGEMENT CORP. (AGENT)

B. MILSTEIN PROPERTIES CORP. (OWNER) 

C. LIBERTY HOUSE CONDOMINIUM (OWNER) 

 (43-108) 380 RECTOR PLACE (LIBERTY TERRACE) 

A. MILFORD MANAGEMENT CORP. (OWNER) 

B. LIBERTY TERRACE CONDOMINIUM (OWNER)

 (43-109) 2 SOUTH END AVENUE (COVE CLUB) 

A. COOPER SQUAER REALTY, INC. (OWNER)

 (43-110) 250 SOUTH END AVENUE (HUDSON VIEW EAST) 

A. BATTERY PARK CITY AUTHORITY (OWNER)

B. HUDSON VIEW TOWERS ASSOCIATES (OWNER)

C. HUDSON VIEW EAST CONDOMINIUM (OWNER)

D. BOARD OF MANAGERS OF THE HUDSON VIEW EAST 

CONDOMINIUM (OWNER)

E. R Y MANAGEMENT CO., INC. (AGENT) 

F. ZECKENDORF REALTY, LP, (AGENT/OWNER) 

G. ZECKENDORF REALTY, LLC, (AGENT/OWNER) 

 (43-111) 315 SOUTH END AVENUE 

A. THE CITY OF NEW YORK (OWNER) 

 (43-112) 345 SOUTH END AVENUE (100 GATEWAY PLAZA) 

A. EMPIRE STATE PROPERTIES, INC. (OWNER)

B. LEFRAK ORGANIZATION INC. (OWNER)

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 29 of 46
 29 29

 (43-113) 355 SOUTH END AVENUE (200 GATEWAY PLAZA) 

A. EMPIRE STATE PROPERTIES, INC. (OWNER)

 B. LEFRAK ORGANIZATION INC. (OWNER)

 (43-114) 375 SOUTH END AVENUE (600 GATEWAY PLAZA) 

A. EMPIRE STATE PROPERTIES, INC. (OWNER)

B. LEFRAK ORGANIZATION INC. (OWNER)

 (43-115) 385 SOUTH END AVENUE (500 GATEWAY PLAZA) 

A. EMPIRE STATE PROPERTIES, INC. (OWNER)

B. LEFRAK ORGANIZATION INC. (OWNER)

 (43-116) 395 SOUTH END AVENUE (400 GATEWAY PLAZA) 

A. THE CITY OF NEW YORK (OWNER)

B. BATTERY PARK CITY AUTHORITY (OWNER)

C. HUDSON TOWERS HOUSING CO., INC. (OWNER)

D. EMPIRE STATE PROPERTIES, INC. (OWNER)

 E. LEFRAK ORGANIZATION, INC. (OWNER)

 (43-117) 22 THAMES STREET 

A. 123 WASHINGTON, LLC (C/O THE MOINIAN GROUP) 

 (43-118) 88 THOMAS STREET 

 50 HUDSON LLC (OWNER)

 (43-119) TRINITY CHURCH 

 RECTOR OF TRINITY CHURCH (OWNER) 

 (43-120) 100 TRINITY PLACE (HIGH SCHOOL OF ECONOMICS AND 

FINANCE) 

A. THAMES REALTY CO. (OWNER)

B. NEW YORK UNIVERSITY (OWNER)

 (43-121) 78-86 TRINITY PLACE (AMERICAN STOCK EXCHANGE) 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 30 of 46
 30 30

A. AMERICAN STOCK EXCHANGE LLC (OWNER)

B. AMERICAN STOCK EXCHANGE CLEARING LLC (OWNER)

C. AMERICAN STOCK EXCHANGE REALTY ASSOCIATIES 

 LLC (OWNER)

D. NATIONAL ASSOCIATION OF SECURITIES DEALERS 

(OWNER)

 E. THE NASDAQ STOCK MARKET, INC (OWNER)

F. AMEX SEAT OWNERS ASSOCIATION, INC. (OWNER)

G. AMEX SPECIALISTS ASSOCIATION, INC. (OWNER)

H. AMEX COMMODITIES LLC (OWNER)

I. AMEX INTERNATIONAL INC. (OWNER)

J. AMEX INTERNATIONAL LLC (OWNER)

K. NEW YORK CITY INDUSTRIAL DEVELOPMENT AGENCY 

(OWNER)

L. NEW YORK CITY ECONOMIC DEVELOPMENT 

 CORPORATION (OWNER)

M. NEW YORK CITY INDUSTRIAL DEVELOPMENT 

 CORPORATION (OWNER)

 (43-122) 90 TRINITY PLACE 

A. NEW YORK UNIVERSITY (OWNER)

 (43-123) TRINITY BUILDING 

A. CAPITAL PROPERTIES, INC. (AGENT) 

B. TRINITY CENTRE, LLC (OWNER)

 (43-124) 75 VARICK STREET AND 76 VARICK STREET 

A. NYC INDUSTRIAL DEVELOPMENT AGENCY (OWNER)

B. TRINITY REAL ESTATE (AGENT)

 (43-125) 30 VESEY STREET 

A. SILVERSTEIN PROPERTIES (OWNER)

 (43-126) 1 WALL STREET 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 31 of 46
 31 31

A. THE BANK OF NEW YORK COMPANY, INC. (OWNER)

B. ONE WALL STREET HOLDINGS LLC (OWNER) 

C. 4101 AUSTIN BLVD CORPORATION (OWNER) 

 (43-127) 11 WALL STREET (NEW YORK STOCK EXCHANGE, INC.) 

A. NYSE, INC. (OWNER)

B. NYSE, INC. (AGENT) 

 (43-128) 37 WALL STREET 

A. W ASSOCIATES LLC (OWNER)

 (43-129) 40 WALL STREET 

A. 32-42 BROADWAY OWNER, LLC (OWNER)

B. CAMMEBY’S MANAGEMENT CO., LLC (AGENT)

 (43-130) 45 WALL STREET 

A. 45 WALL STREET LLC (OWNER)

 

 (43-131) 60 WALL STREET AND 67 WALL STREET 

A. DEUTSCHE BANK DBAB WALL STREET LLC (OWNER)

B. JONES LANG LASALLE (AGENT)

 (43-132) 63 WALL STREET 

A. 63 WALL, INC. (OWNER)

B. 63 WALL STREET INC. (OWNER)

C. BROWN BROTHERS HARRIMAN & CO., INC. (AGENT) 

 (43-133) 100 WALL STREET 

A. 100 WALL STREET COMPANY LLC (OWNER)

B. RECKSON CONSTRUCTION GROUP NEW YORK, INC. 

 (AGENT/CONTRACTOR) 

 (43-134) 111 WALL STREET 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 32 of 46
 32 32

A. CITIBANK, N.A. (OWNER)

B. STATE STREET BANK AND TRUST COMPANY, AS OWNER 

 TRUSTEE OF ZSF/OFFICE NY TRUST (OWNER)

C. 111 WALL STREET LLC (OWNER)

D. 230 CENTRAL CO., LLC (OWNER)

E. CUSHMAN & WAKEFIELD, INC. (AGENT) 

F. CUSHMAN & WAKEFIELD 111 WALL, INC (AGENT) 

G. CITIGROUP, INC. (OWNER)

 (43-135) 46 WARREN STREET 

A. DAVID HELFER (OWNER)

 (43-136) 73 WARRAN STREET 

A 73 WARREN STREET LLP (OWNER)

 (43-137) 201 WARREN STREET (P.S. 89) 

 A. TRIBECA NORTH END, LLC (OWNER) 

B. THE CITY OF NEW YORK (OWNER)

C. THE NEW YORK CITY DEPARTMENT OF EDUCATION 

(OWNER)

D. THE NEW YORK CITY SCHOOL CONSTRUCTION 

 AUTHORITY (OWNER)

 (43-138) 130 WASHINGTON STREET 

 HMC FINANCIAL CENTER, INC. (OWNER) 

 (43-139) 55 WATER STREET 

A. 55 WATER STREET CONDOMINIUM (OWNER)

B. NEW WATER STREET CORP. (OWNER)

 (43-140) 160 WATER STREET 

A. 160 WATER STREET ASSOCIATES (OWNER)

B. G.L.O. MANAGEMENT, INC. (AGENT) 

C. 160 WATER ST. INC. (OWNER)

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 33 of 46
 33 33

 

 (43-141) 199 WATER STREET 

 A. RESNICK WATER ST. DEVELOPMENT CO. (OWNER)

B. JACK RESNICK & SONS INC. (AGENT)

 (43-142) 200 WATER STREET 

A. NEW YORK UNIVERSITY (OWNER)

B. NEW YORK UNIVERSITY REAL ESTATE CORPORATION 

(OWNER)

C. 127 JOHN STREET REALTY LLC (OWNER)

 D. ROCKROSE DEVELOPMENT CORP. (OWNER)

 (43-143) 3 WEST 57TH STREET (THE WHITEHALL BUILDING) 

A. EL-KAM REALTY CO. (OWNER)

 (43-144) 50 WEST STREET 

A CAPMARK FINANCE, INC. (OWNER)

 (43-145) 90 WEST STREET (WEST STREET BUILDING) 

A. FGP 90 WEST STREET, INC. (OWNER)

B. KIBEL COMPANIES (OWNER)

 (43-146) 140 WEST STREET (VERIZON BUILDING) 

A. VERIZON NEW YORK, INC. (OWNER)

B. VERIZON PROPERTIES, INC. (OWNER)

C. VERIZON COMMUNICATIONS, INC. (OWNER)

D. HILLMAN ENVIRONMENTAL GROUP, LLC. 

(OWNER’S AGENT/CONTRACTOR) 

 (43-147) 30 WEST BROADWAY 

A. THE CITY UNIVERSITY OF NEW YORK (OWNER)

B. THE CITY OF NEW YORK (OWNER) 

 (43-148) 100 WILLIAM STREET 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 34 of 46
 34 34

 A. WU/LIGHTHOUSE (OWNER)

 B. LIGHTHOUSE REAL ESTATE, LLC (AGENT)

 (43-149) 123 WILLIAM STREET 

 A. WILLIAM & JOHN REALTY, LLC (OWNER)

 B. AM PROPERTY HOLDING (AGENT) 

 (43-150) 40 WORTH 

A. LITTLE 40 WORTH ASSOCIATES, LLC (AGENT)

 B. NEWMAN AND AMP COMPANY REAL ESTATE (AGENT) 

 (43-151) 125 WORTH 

 A. CITY WIDE ADMINISTRATIVE SERVICES (OWNER) 

 (43-152) 200 LIBERTY STREET (ONE WORLD FINANCIAL CENTER) 

A. BATTERY PARK CITY AUTHORITY (OWNER)

B. BROOKFIELD PROPERTIES CORPORATION (OWNER)

C. BROOKFIELD FINANCIAL PROPERTIES, LP (OWNER)

D. BROOKFIELD FINANCIAL PROPERTIES, INC. (OWNER)

E. BROOKFIELD PROPERTIES HOLDINGS INC. (OWNER)

F. BROOKFIELD PARTNERS, LP (OWNER)

G. WFP TOWER A CO. (OWNER)

H. WFP TOWER A CO. L.P. (OWNER)

I WFP TOWER A. CO. G.P. CORP. (OWNER)

J. TUCKER ANTHONY, INC. (AGENT)

K. BLACKMON-MOORING-STEAMATIC CATASTOPHE, 

 INC. d/b/a BMS CAT (CONTRACTOR/AGENT) 

 (43-153) 225 LIBERTY STREET (TWO WORLD FINANCIAL CENTER) 

A. BATTERY PARK CITY AUTHORITY (OWNER) 

B. BROOKFIELD PROPERTIES CORPORATION (OWNER)

C. BROOKFIELD PARTNERS, L.P. (OWNER)

D. BROOKFIELD PROPERTIES HOLDINGS INC. (OWNER)

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 35 of 46
 35 35

E. BROOKFIELD FINANCIAL PROPERTIES, L.P. (OWNER)

F. BROOKFIELD FINANCIAL PROPERTIES, INC. (OWNER)

G. MERRILL LYNCH & CO, INC. (OWNER)

H. WESTON SOLUTIONS, INC. (AGENT/CONTRACTOR) 

 I. GPS ENVIRONMENTAL CONSULTANTS, INC. 

(AGENT/CONTRACTOR)

J. INDOOR ENVIRONMENTAL TECHNOLOGY, INC. 

(AGENT/CONTRACTOR)

K. BLACKMON-MOORING-STEAMATIC CATASTOPHE, 

 INC. d/b/a BMS CAT (AGENT/CONTRACTOR)

 L. STRUCTURE TONE, (UK) INC. (CONTRACTOR) 

 M. STRUCTURE TONE GLOBAL SERVICES, INC 

(CONTRACTOR)

N. ENVIROTECH CLEAN AIR, INC. (CONTRACTOR)

O. ALAN KASMAN DBA KASCO (CONTRACTOR)

 P. KASCO RESTORATION SERVICES CO. (CONTRACTOR)

Q. NOMURA HOLDING AMERICA, INC. (OWNER) 

R. NOMURA SECURITIES INTERNATIONAL, INC. (OWNER)

S. WFP TOWER B HOLDING CO., LP (OWNER)

T. WFP TOWER B CO., G.P. CORP. (OWNER)

U. WFP TOWER B CO. L.P. (OWNER)

V. TOSCORP. INC. (OWNER)

W. HILLMAN ENVIRONMENTAL GROUP, LLC. 

(AGENT/CONTRACTOR) 

X. ANN TAYLOR STORES CORPORATION (OWNER)

 (43-154) 200 VESEY STREET (THREE WORLD FINANCIAL CENTER) 

A. BFP TOWER C CO. LLC. (OWNER)

B. BFP TOWER C MM LLC. (OWNER)

C. WFP RETAIL CO. L.P. (OWNER)

D. WFP RETAIL CO. G.P. CORP. (OWNER)

E. AMERICAN EXPRESS COMPANY (OWNER)

F. AMERICAN EXPRESS BANK , LTD (OWNER)

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 36 of 46
 36 36

G. AMERICAN EXPRESS TRAVEL RELATED SERVICES 

COMPANY, INC. (OWNER)

H. LEHMAN BROTHERS, INC. (OWNER)

I. LEHMAN COMMERCIAL PAPER, INC. (OWNER)

J. LEHMAN BROTHERS HOLDINGS INC. (OWNER)

K. TRAMMELL CROW COMPANY (AGENT) 

L. BFP TOWER C CO. LLC (OWNER)

M. MCCLIER CORPORATION (AGENT)

N. TRAMMELL CROW CORPORATE SERVICES, INC. (AGENT)

O. BLACKMON-MOORING-STEAMATIC CATASTOPHE, 

 INC. d/b/a BMS CAT (AGENT/CONTRACTOR) 

 (43-155) 250 VESEY STREET (FOUR WORLD FINANCIAL CENTER) 

A. BATTERY PARK CITY AUTHORITY (OWNER)

B. BROOKFIELD PROPERTIES CORPORATION (OWNER)

C. BROOKFIELD FINANCIAL PROPERTIES, LP. (OWNER)

D. BROOKFIELD FINANCIAL PROPERTIES, INC. (OWNER)

E. BROOKFIELD PROPERTIES HOLDINGS, INC. (OWNER)

F. BROOKFIELD PARTNERS, LP (OWNER)

G. WFP TOWER D CO. L.P. (OWNER)

I. H.WFP TOWER D CO., G.P. CORP (OWNER). 

J. WFP TOWER D HOLDING I G.P. CORP. (OWNER)

K. WFP TOWER D HOLDING CO. I L.P. (OWNER)

L. WFP TOWER D HOLDING CO. II L.P. (OWNER)

M. MERRILL LYNCH & CO, INC. (OWNER)

 N. WESTON SOLUTIONS, INC. (CONTRACTOR/AGENT) 

 O. GPS ENVIRONMENTAL CONSULTANTS, INC. 

(CONTRACTOR/AGENT)

 P. INDOOR ENVIRONMENTAL TECHNOLOGY, INC. 

 (CONTRACTOR/AGENT)

 Q. BLACKMON-MOORING-STEAMATIC CATASTOPHE, 

 NC. d/b/a BMS CAT (CONTRACTOR/AGENT)

 R. STRUCTURE TONE, (UK) INC. (CONTRACTOR/AGENT)

 S. STRUCTURE TONE GLOBAL SERVICES, INC 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 37 of 46
 37 37

 (CONTRACTOR/AGENT)

 T. ENVIROTECH CLEAN AIR, INC. (CONTRACTOR/AGENT)

 U. ALAN KASMAN DBA KASCO (CONTRACTOR/AGENT)

 V. KASCO RESTORATION SERVICES CO. 

 (CONTRACTOR/AGENT)

 (43-156) ZEN RESTAURANT 

 CITY OF NEW YORK (OWNER) 

 OTHER: if an individual plaintiff is alleging injury sustained at a building/location other than 

as above, and/or if an individual plaintiff is alleging an injury sustained at a building/location 

above, but is alleging a claim against a particular defendant not listed for said building, plaintiff 

should check this box, and plaintiffs should follow the procedure as outlined in the CMO # 4

governing the filing of the Master Complaint and Check-off Complaints. 

 V – VIII. 

 CAUSES OF ACTION

 44. Plaintiffs adopt those allegations as set forth in the Master Complaint Section V-VIII, 

Causes of Action. 

 45. Plaintiff(s) seeks damages against the above named defendants based upon the following 

theories of liability, and asserts each element necessary to establish such a claim under the 

applicable substantive law: 

 45 A. Breach of the defendants' duties and obligations 

pursuant to the New York State Labor Law(s) 

including § 200 

 45 B. Breach of the defendants' duties and obligations 

pursuant to the New York State Labor Law 241(6) 

 45 C. Common Law Negligence 

 45 D. Wrongful Death 

 45 E. Loss of Services/Loss of Consortium for Derivative 

Plaintiff 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 38 of 46
 38 38

 45 F. Other: if an individual plaintiff is alleging an additional 

cause of action or additional substantive law or theory of 

law upon which his/or claim is based, other than as 

appears in this section, plaintiff should check this box, 

and plaintiffs should follow the procedure as outlined in 

the CMO # 4 governing the filing of the Master 

Complaint and Check-off Complaints.

 46. As to the following municipal entities or public authorities, or other entity for which 

for which a Notice of Claim is a requirement, a Notice of Claim pursuant to the 

applicable statutes as referenced within the Master Complaint, has been timely served on 

the following dates. 

Name of Municipal Entity or Public Authority Date Notice of Claim 

Served

 46. a 

 46. b. 

 46. c. 

 46. d. 

 46. e. 

 46. f. 

 46. g. 

 46. h. 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 39 of 46
 39 39

 47. As to certain municipal entities or public authorities, if specified as defendants herein, 

with reference to the service of a Notice of Claim, an application has been made to the 

Supreme Court, County of New York (insert name of Court), as to 

___________________(insert name of municipal entity or public authority or other 

entity):

 47A. to deem Plaintiff’s (Plaintiffs’) Notice of Claim timely 

filed, or in the alternative to grant Plaintiff(s) leave to file 

a late Notice of Claim Nunc Pro Tunc, and for 

___________________________ (insert if additional 

relief was requested) and: 

 47B. a determination is pending 

 47C. an Order granting the petition was made 

 on: ___________________ (insert date) 

 47D. an Order denying the petition was made 

on:___________________ (insert date) 

Instructions: If an application has been made to the Court with reference to additional 

municipal entities or public authorities, list them in sub-paragraph format. 

 [i.e., 47-1 ___________________________ (insert name of municipal entity or public 

authority or other entity)

 47-1A. to deem Plaintiff’s (Plaintiffs’) Notice of Claim 

timely filed, or in the alternative to grant Plaintiff(s) leave 

to file a late Notice of Claim Nunc Pro Tunc, and for 

___________________________ (insert if additional relief 

was requested) and: 

 47-1B. a determination is pending 

 47-1C. an Order granting the petition was made 

 47-1D. an Order denying the petition was made 

 on:___________________ (insert date)] 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 40 of 46
 40 40

 48.As a direct and proximate result of defendant’s culpable actions in the clean-up, 

construction, demolition, excavation, and/or repair operations and all work performed 

at the premises, the Injured Plaintiff sustained the following injuries including, but not 

limited to: 

 Abdominal 

48-1 Abdominal Pain _______________ 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

 Cancer 

48-2 Fear of Cancer 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-3 Tumor (of the________) 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-4 Leukemia 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-5 Lung Cancer 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-6 Lymphoma 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

 Circulatory 

48-7 Hypertension 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

 Death 

48-8 Death: 

Date of death: _________________________ 

If autopsy performed, date _____________________________ 

 Digestive 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 41 of 46
 41 41

48-9 Gastric Reflux 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-10 Indigestion 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-11 

Nausea 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

 Pulmonary 

48-12 Asthma 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-13 Chronic Obstructive Lung Disease 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-14 Chronic Restrictive Lung Disease 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-15 Chronic Bronchitis 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-16 Chronic Cough 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-17 Pulmonary Fibrosis 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________

48-18 Pulmonary Nodules 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-19 Sarcoidosis 

Date of onset: ________________________ 

Date physician first connect this injury to WTC work 

48-20 Shortness of Breath 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-21 Sinusitis 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 42 of 46
 42 42

 Skin Disorders, Conditions or Disease 

48-22 Burns 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-23 Dermatitis 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

 Sleep Disorder 

48-24 Insomnia 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: ____________

48-25 Other: _______________________________________________ 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-26 Other: _______________________________________________ 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-27 Other: _______________________________________________ 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-28 Other: _______________________________________________ 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

48-29 Other: _______________________________________________ 

Date of onset: ______________________ 

Date physician first connected this injury to WTC work: _____________ 

 

 If additional injuries are alleged, check here and attach Rider continuing with the same 

format for sub-paragraphs 

 49. As a direct and proximate result of the injuries identified above the Injured Plaintiff has in 

the past suffered and/or will and/or may, subject to further medical evaluation and opinion, in 

the future, suffer the following compensable damages: 

 49 A. Pain and suffering 

 49 B. Death 

 49 C. Loss of the pleasures of life 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 43 of 46
 43 43

 49 D. Loss of earnings and/or impairment of earning capacity 

 49 E. Loss of retirement benefits/diminution of retirement benefits 

 49 F. Expenses for medical care, treatment, and rehabilitation 

 49 G. Mental anguish 

 49 H. Disabilities 

 49 I. Medical monitoring 

 49 J. OTHER ______________ 

 49 K. OTHER ______________ 

 49 L. OTHER ______________ 

 49 M. OTHER ______________ 

 49 N. OTHER ______________ 

 49 O. OTHER ______________ 

 49 P. OTHER ______________ 

 49 Q. OTHER ______________ 

 49 R. OTHER ______________ 

 49 S. OTHER ______________ 

 50. As a direct and proximate result of the injuries described supra, the Derivative 

plaintiff(s), have in the past suffered and/or will in the future suffer a loss of the love, 

society, companionship, services, affection, and support of the plaintiff and such other 

losses, injuries and damages for which compensation is legally appropriate, and or as is 

otherwise alleged. 

IX. 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 44 of 46
 44 44

 PRAYER FOR RELIEF

 51. Plaintiffs adopt those allegations as set forth in the Master Complaint Section IX., 

Prayer for Relief. 

 52. OTHER RELIEF: If plaintiff is asserting relief (other than monetary) other than as 

indicated above, check here and insert Relief sought: ___________________________ 

 If plaintiff is asserting monetary relief in amounts different than as alleged within the 

Master Complaint, Check this box and fill in the WHEREFORE clause below: 

 WHEREFORE, the above-named Plaintiff demands judgment against the above-named 

Defendants in the amount of ___________________ DOLLARS ($____________), on the First 

Cause of Action; and in the amount of ________________ DOLLARS ($_____________) on 

the Second Cause of Action; and in the amount of ____________ DOLLARS ($_________) on 

the Third Cause of Action; and Derivative Plaintiff demands judgment against the above named 

Defendants in the amount of ____________ DOLLARS ($____________) on the Fourth Cause 

of Action; and Representative Plaintiff demands judgment against the above named Defendants 

in the amount of ______________ ($______________) on the Fifth Cause of Action, and as to 

all Demands for Relief, and or as determined by a Jury or this Court, jointly and severally, for 

general damages, special damages, and for his/her attorneys' fees and costs expended herein and 

in a non-specified amount to be determined by a Jury or this Court for punitive and exemplary 

damages, and for prejudgment interest where allowable by law and post judgment interest on the 

judgment at the rate allowed by law; and Plaintiff seeks such other relief as is just and equitable. 

X. 

 JURY TRIAL DEMAND

 53. Plaintiffs adopt those allegations as set forth in the Master Complaint Section X, Jury 

Trial Demand. 

If Riders are annexed check the applicable BOX indicating the paragraphs for which Riders are 

annexed. 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 45 of 46
 45 45

 Paragraph 31 

 Paragraph 44 

 Paragraph 48 

WHEREFORE, plaintiff(s) respectfully pray that the Court enter judgment in his/her/their favor 

and against defendant(s) for damages, costs of suit and such other, further and different relief as 

may be just and appropriate. 

Dated: New York, New York 

_________________, 200___ 

 

 Yours, etc. 

 ___________________________ 

(Insert Firm Name) 

 

By:_________________________ 

Attorneys for Plaintiffs 

Office and PO Address 

Tel: 

Fax: 

Email: 

Case 1:07-cv-05370-AKH Document 2-3 Filed 06/29/2007 Page 46 of 46