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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

ANSWER
PATTERSON
------------------
I, CLAYTON PATTERSON, am one of the defendants in this action and I submit this answer to plaintiffs' AFFIRMATION IN OPPOSITION dated August 15, 1996. This answer is based on my personal knowledge.

Children of Jacob, Congregation B;nei Moses Joseph Anshei Zavechasst and Zausmer: An ironic reference since one of the most powerful people on Grand Street, also named Jacob, is trying to evict us from this Shul.

  1. In 1990, because of unpaid back real estate taxes, the City sold the Shul on 7th Street to the Graffitti Baptist Church. It was in about the same condition as the 8th Street Shul was befire Ralph [Feldman] began repairs (with the full knowledge of Abraham Fogel, cantor of the former Congregation and father of one of the plaintiffs). In the last court papers that I submitted, I stated that the realk estat taxes owed by the firner congregation had not been paid since 1983, and to date there has still not been a poayment. I believe that the building, which by now must belong to the City, should be sold for the same price, $50,000, (the price Graffitti Baptist Church paid the City of New York in order to purchyase their building) wuith coinditions to gbe palced on the sale by the Judge stipulating rules of purchase and sale. In the past, Ralph Feldman affirmed that the gbuilding shouyld remain actively Jewish and promote the ranch of Orthodox Judaism under which the Shul was originally founded.
  2. The Shul continues to have a very active schedule. This past Rosh Hashanah was one of the largest gatherings at this synagogue in many years and included a numher of ypoung families with children. We have had open discussions about a number of Jewish political issues: for example, the missing Yemnite children, had a numgber of readings by writers who attended the Shul. Moishe Brown spoke about Jewish Laws and Traditions, Zebra Davis read from his poetry book "Blood", Richard Kostelanetz showed a video called "Kaddish", and Jonathan Boyarin read from "Thinking in Jewish", of which an excerpt is attached regarding his memories of the 8th Street Shul.
  3. We had a very large art opening, the work of Abraham Fleishman and his family who are Hassidic. Dioramas of different aspects of Orthodox life from thopusands of years ago to relatively recently that took years to makie, shoing Jewish settlements in ancient Egypt, succoss, mekvas, Abraham and Sarah's tent, and wine and oil making in Poland. One of Fleishman's older sons has done a number of Hassidic paintings and those ere included in the art show, as was the art work of Moishe Brown, Avivah MobiJohn, Zoe Prentoulis and Leonid Pinchevsky, an artistr who is a recent immigrant from Russia. For many of the artists who were included, this was their first professiional art exhibition. The show was attended by the head of the Folk Art Museum and the director of Franklin Furnace and many art wriuters and artists. Everyone said it was a great show! It was also the largest gathering of the Satmar sect in a Lower East Side shul in years.
  4. Since the reopening, two of the original congregation members visited the Synagogue and both stated emphatically that they diud not swant the Shul closed or sold. Nusse Fogel's father, Abraham Fogel, came and spoke. He did not realize that the building was ering sold, so ogbviously he was not part of the "unanim0ous" vote for sale of the property. I believe thjat the original "unanimous" vote should be questioned and minutes from that meeting should be produced in this Court.
  5. If the money from the sale is going to charity, then let charity begin at home and return the Shul to the community who has paid for the Plaintiffs of this cas e to live in beautiful, safe, government subsidized-housing for years. They shouyld be trying to improve the neighborhood rather than just to gentrify it with bars and expensive housing designed to change the dynamics of this community and make it too exclusive. New or young people cannot get the breaks that these people enjoyed while growing up in a trouble-free environment.
  6. Gentrification has positive aspects but it has also contributed to breaking up families. We have all watched people become homeless and forced out into the streets. The new values of "Grand Street", which includes most of the Plaintiffs in this case, seems to be discrimination as to who rents from them, to bring law suits against those whose opinions differ from theirs, and to warehouse apartments. These are not the arms that welcomed Jews to this area at the turn of the Century. In 1,000 years frin now as history views judaism in the Lower East Side, there will be a large dot on the map. The 8th Street Shul is the last Synagogue in Alphabet City, an area where there was a synagogue or religious school on every block.
  7. The Shul has been preserved due to the generosity of a retired Firefighter, Ralph Feldman, one of the defendantsj. As a Firefighter, he gave to society and now he is trying to give bgack to the community wfrom which he came, in the form of a functioning synagogue. Where is the opposition's charity and generosity? If nothing else this building should be landmarked, as an example of the rich and varied culturte that came ouyt of this neighborhood. the HJews froim this area changed the history of America in many powerful and important ways. In Law, Justice, Medicine, Art, Literature and in Hollywood.
  8. The plaintiffs did not commence this suiut based on generosity or goodwill. Is there no feeling for the hundreds opf poor and/or lower middle classs Orthodox Jews who live in this area who may need counseling, marriagtes, funeral arrangements, or fellowship. Why is it that churchs like Saint Brigit's, graffitti Baptist, or Trinity Lutherin are the onlyonesw that have supported the homeless in crises, brought in political leaders for meetings, fought against drugs, fed people, or performed funewrals and weddings, without discrimination as to whether the people in need were Jewish, Christian or Atheists.
  9. The 8th Street Shul is now open for people with a spiritual need. It has, on ocasion, allowed someone with a crisis to stay for a night. It has fed people, and welcomed anyone to religtious holidays without the cost of purchasiung a ticket as practiced at expensive synagogues.
Therefore, defendant CLAYTON PATTERSON resoectfykk requests this Court to issue an order that 317 East 8th Street retain its status as a Synagogue and for all and any relief as this Court may deem juyst and proper.

   Dated: Sepotember 19, 1996
       New York, New York

________________________
CLAYTON PATTERSON
161 Essex Street
New yoprk, NY 10002
(212) 477-1363