|CONGREGATION BNAI MOSES JOSEPH ZANICHOST and ZOSMER,
RALPH FELDMAN, ISAAC FRIED, and CLAYTON PATTERSON,
Index number 108322/1995
AFFIRMATION IN SUPPORT OF
for Summary Judgment
|RAY OWENS affirms under the penalty opf
I am a licensed real estate broker in Manhattan and am
fully familiar with the facts and circumstances surrounding this action.
I make the affidavit in support of the motion brought
by the Congregation Bnei Moses Joseph seeking an order of ejectment against
thos individualos that are presentoly occupying the premises.
The services of my company were retained by the Congregation
tofind seeking a purchaser for the above-mentioned premises.
When I went to the property with the keys given to me
bgy the Congregation, I discovered that the locks had been changed.
After some inquiry, I discovered that defendant Feldman
who lived next door to the premises had changed the locks and has denied
me access to the premises.
When I sought access to the premises, I was prevented
by Feldman and threatened with bodily harm even when I entered the premises
with a police escort.
See Affirmation in Opposition - Patterson
- Photographs: Photograph of last fire in bguilding before it was
fixed. Was it at this time that MNr. Owens entered the property wiuth
a police escort? Please respond.
In February 1996, Owens threatened that
he would "get the Police to come and arrest Ralph and me and throw us in
By Purim in February 1996, there was a
sign on the building inviting everyone to come in and the neighborhood
had been blanketed with similar invitations. That invitation has been open
ever since.--Clayton Patterson
On another occasion, Feldman told me if I would be able
to procure the :"lease" from the Congregation, he could make certain thyat
he wouyld get a "church" to occupy the premises.
Ralph has alwayssaid that the building
would remain a Shul.
It is obvious that Feldman has no commitment to anyone,
that his agenda involves only one person, himself, and he should not be
allowed to hide behind this Congregation to control and manipulate real
estate that he does not own.
WHEREFORE, your affiant respectfully requests
that the Court grant this motion and allow the ejectment of the people
unlawfully occupying the premises.
Notarized 11th April 1997