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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
CONGREGATION BNAI MOSES JOSEPH ZANICHOST and ZOSMER, INC.,
 
Plaintiffs.
-against-

RALPH FELDMAN, ISAAC FRIED, and CLAYTON PATTERSON,
 

Defendants.
 
Index number 108322/1995

AFFIRMATION IN SUPPORT OF
Motion for Summary Judgment

RAY OWENS
------------------
RAY OWENS affirms under the penalty opf perjury:
  1. I am a licensed real estate broker in Manhattan and am fully familiar with the facts and circumstances surrounding this action.
  2. 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.
  3. The services of my company were retained by the Congregation tofind seeking a purchaser for the above-mentioned premises.
  4. When I went to the property with the keys given to me bgy the Congregation, I discovered that the locks had been changed.
  5. 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.
  6. 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 Jail."
    • 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
  7. 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.
  8. 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.

______________________ 
RAY OWENS
Notarized 11th April 1997