Affidavit of Matthew Kadushin

    SUPREME COURT OF THE STATE OF NEW YORK 
COUNTY OF QUEENS 

THE COUNCIL OF THE CITY OF NEW YORK, et al. 

Plaintiffs, INDEX NO. 004897-96 

- against - 

RUDOLPH W. GIULIANI, THE MAYOR OF THE 
CITY OF NEW YORK, et al, 

Defendants. 

CAMPAIGN TO SAVE OUR PUBLIC HOSPITALS AFFIDAVIT OF 
QUEENS COALITION, an unincorporated MATTHEW KADUSHIN 
association, et al., 

Plaintiffs, INDEX NO. 10763/96 

- against - 

RUDOLPH W. GIULIANI, THE MAYOR OF THE 
CITY OF NEW YORK, et al., 

Defendants. 

STATE OF NEW YORK 

COUNTY OF NEW YORK 

MATTHEW KADUSHIN, being duly sworn, deposes and says: 

I am not a party to this action and am over 18 years of 

2 On the 19th day of November, 1996, I served the Campaign 

Plaintiffs’ Supplemental Memorandum of Law in Support of 

Plaintiffs’ Motion for Summary Judgment and the Supplemental 

Affirmation of Rachel D. Godsil with Exhibit in the above- 

referenced proceeding upon: 

Paul A. Crotty 
Corporation Counsel of the 

City of New York 
100 Church Street 

New York, NY 10007  



  

by personal service to the appointed representatives of the above- 

named agencies, at the above-referenced addresses. 

3. On the 20th day of November, 1996, I served the Campaign 

Plaintiffs’ Supplemental Memorandum of Law in Support of 

Plaintiffs’ Motion for Summary Judgment and the Supplemental 

Affirmation of Rachel D. Godsil with Exhibit in the above- 

referenced proceeding upon: 

Tenzer Greenblatt LLP 
The Chrysler Building 
405 Lexington Avenue 
New York, New York 10174 

and 

Richard Weinberg, Esq. 
General Counsel 
The Council of the City of New York 
75 Park Place, 5th Floor 
New York, New York 10007 

by placing a copy in the United States mail. 

NL 
MATTHEW KADUSHIN 
  

Sworn to before me this 
20th day of November, 1996 

¢  res— 
Notary Public 
  

EVELYN ANDERSON 

Notary Public, State of New York 

No. O1ANS0SoLe. i 

ualified in New York County 

EL Expires November 20, 1997 

 



   



SUPREME COURT OF THE STATE OF NEW YORK 
COUNTY OF QUEENS 

THE COUNCIL OF THE ClTY OF NEW YORK, et al. 

Plaintiffs, INDEX NO. 004897-96 

- against - 

RUDOLPH W. GIULIANI, THE MAYOR OF THE 

CITY OF NEW YORK, et al, SUPPLEMENTAL AFFIRMATION 

OF RACHEL D. GODSIL WITH 

Defendants. EXHIBIT 
  

CAMPAIGN TO SAVE OUR PUBLIC HOSPITALS 

QUEENS COALITION, an unincorporated 
association, et al., 

Plaintiffs, INDEX NO. 10763/96 

- against - 

RUDOLPH W. GIULIANI, THE MAYOR OF THE 
CITY OF NEW YORK, et al., 

Defendants. 

STATE OF NEW YORK 

COUNTY OF NEW YORK Be 

Rachel D. Godsil, Esq. hereby affirms that the following is true 

under the penalty of perjury: 

1: I am an attorney duly authorized to practice in the State of 

New York. TI am Assistant Counsel to the NAACP Legal Defense and 

Educational Fund, Inc. I make this affirmation in support of 

plaintiffs’ motion for summary judgment and in opposition to 

defendants’ motion for summary judgment. The facts set forth below are 

within my personal knowledge or are based upon information obtained 

from books and records of New York City, the New York City Health and 

Hospitals Corporation ("HHC"), and the New York City Economic 

l  



id 4 t i 
. [ - . 

. v 

  

Development Corporation ("EDC"), or other public documents. 

2. Attached herein is a copy of the appearance notice for the 

September 13, 1995 Board of Estimate Hearing concerning the sublease of 

the R&S Building located at the Bellevue Hospital Complex to Enzo 

Biochem Inc. Sixteen people testified in opposition to the sublease, 

including several representatives from the Community Board representing 

the area. It is inconceivable that these sixteen people attended the 

hearing and testified in opposition to the sublease solely as a result 

of their concern about the business terms. The interests of the 

Community Board undoubtedly stemmed from concern over land use. 

- 

Dated: New York, New York 

November 19, 1996 yy 2 

  

RACHEL D. GODSIL, ESQ. 

 



  

  

  
  

1 

el : Se... 1985 

Disposition of the Matters on_.the Calendar of the Special 

Meeting of the Board of Estimate of The City of New York, held in 

Room 16, City Hall, Borough of Manhattan, on Thursday, September 13, 

1985. 

A. The Board met pursuant to the Call of the Chair. (R-2309) 

“Present: - 

William Howell, Mayor's Representative on the Board of Estimate 

Thomas O'Keefe, Acting Comptroller 

Cindy Freidmutter, Acting President of the Council 

Thomas Cusick, Acting President, Borough of Manhattan 

Marilyn Gelber, Acting President, Borough of Brooklyn 

Robert Castellanete, Acting President, Borough of The Bronx 

James Golia, Acting President, Borough of Queens 

Aldo Benedetto, Acting President, Borough of Staten Island 

Theodore H. Meekins, Secretary 

(Roll Call At 12:12 P.M.) 

William Howell, Mayor's Representative, voted on Cal. Nos. A, 1 and 2» 

Thomas O'Keefe, Acting Conpiratier, voted on Cal. Nos. A, 1 and 2. 

Cindy Freidmutter, Acting President of the Council, voted on Cal. Nos. 

A, 1 and 2. Y 

Thomas Cusick, Acting President, Borough of Manhattan, voted on Cal. 

Nos. A, 1 and 2. 

Marilyn Gelber, Acting President, Borough of Brooklyn, voted on Cal. 

Nos. A, 1 and 2. 

Robert Castellanette, Acting President, Borough of The Bronx, voted 

on Cal. Nos. A, 1 and 2. 

James Golia, Acting President, Borough of Queens, voted on Cal. Nos. 

A, 1 and 2. 

Aldo Benedetto, Acting President, Borough of Staten Island, voted on 

2i5Cal. Nos. A, 1 and 2. : 

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#0 APPEARANCES: 
In Opposition: 

Hon. Steven Sanders, Self 

Hon. Carol Greitzer, Representing C.D. 3, Manhattan 

Henry W. Weiss, Representing Community Board #6, 

Manhattan 

Julia Rivera, Representing President of Comhunity Board 

#6 

Anne Emmerson, Representing Community Board #6, Manhattan 

Mary O'Connor, Representing Beelevue Task Force 

Paul Van Souder, Self 
Dr. Robert Boorstein, Self 

Louis Supgrsky, Representing Community Board #6, 

Manhattan 

Howard Harrington, Representing Community Board #6, 

Manhattan 
2ita fearson, Self . 

Parimal Das, Representing Community Board # 6, Manhattan 

Sylvia Grossman, Representing Community Board #6, 

Manhattan 

N. Zuger, Representing Community Board #6, Manhattan 

Brenda Levin, Representing Community Board #6, Manhattan 

Scott Mollen, Self 

 



  

seo @er 13,.1985 

APPEARANCES: 

In Favor=s 
Barry Wein, Self 

Mark A., Self 
Lawrence Kieves, Representing Office Business Development 

Development 

Terrance Moan, Representing Deputy Commissioner of 

Real Property ; 

Jean B. Cropper, Representing Deputy Commissioner of HHC 

Gail Benjamin, Representing Special Assistant HHC 

Statements were made by the Mayor's Representative, Acting 

President of the Council and Acting President, Borough of 

Manhattan. 

On the Motioh of the Mayor's Representative 

" Hearing Clesed. 
Resolution adopted 7 to 4, Actin Comptroller and Acting. 

President of the Council voting in negative. 

Statements were made on Roll Call by The Mayor's Representative, 

Acting President of the Council and Acting President, Borough 

of Manhattan. . 

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MATTERS NOT ON THE CALENDAR CONSIDERED BY UNANIMOUS CONSENT: 
  

2 Offered by the President of the Council: R-2310 

COMMUNICATION dated September 13, 1985, from tne President of 
the Council, designating Cindy Freidmutter, to represent and vote for 

the Council of the President at the September 13, 1985, special session 

of the Board. = 

Ordered Filed. 

THE BOARD THEREUPON ADJOURNED 

AT 2:53 A.M, 

TO MEET AGAIN ON 

THURSDAY, OCTOBER 24, 1985 

AT 10:30 A.M. 

  

  

  

  

  

 



  

* | 4 5 » - . : 
ps ; 

SUPREME COURT OF THE STATE OF NEW YORK 
COUNTY OF QUEENS 
tt sr vet mm i i em rma mm SF i me X 

THE COUNCIL OF THE CITY OF NEW YORK, et al. 

Plaintiffs, INDEX NO. 004897-96 

- against - 

RUDOLPH W. GIULIANI, THE MAYOR OF THE 

CITY OF NEW YORK, et al, 

Defendants. 
st Com om nr a pet a Sm mi i mms mt mm tl fe «ma mart oo Oa ae Sa Tes ET X 

CAMPAIGN TO SAVE OUR PUBLIC HOSPITALS - AFFIDAVIT OF 
QUEENS COALITION, an unincorporated MATTHEW KADUSHIN 
association, et al., 

Plaintiffs, INDEX NO. 10763/96 

- against - 

RUDOLPH W. GIULIANI, THE MAYOR OF THE 

CITY OF NEW YORK, ef al., 

Defendants. 
i mm fn oo ari a em ot X 

STATE OF NEW YORK ) 

) SS. : 
COUNTY OF NEW YORK ) 

MATTHEW KADUSHIN, being duly sworn, deposes and says: 

1. I am not a party to this action and am over 18 years of 

age. 

2. On the 19th day of November, 1996, I served the Campaign 

Plaintiffs’ Supplemental Memorandum of Law in Support of 

Plaintiffs’ Motion for Summary Judgment and the Supplemental 

Affirmations of Rachel D. Godsil with Exhibit in the above- 

referenced proceeding upon: 

Paul A. Crotty 
Corporation Counsel of the 

City of New York 
100 Church Street 
New York, NY 10007 

 



by personal service to the appointed representatives of the above- 

named agencies, at the above-referenced addresses. 

3. On the 20th day of November, 1996, I served the Campaign 

Plaintiffs’ Supplemental Memorandum of Law in Support of 

Plaintiffs’ Motion for Summary Judgment and the Supplemental 

Affirmation of Rachel D. Godsil with Exhibit in. the above- 

referenced proceeding upon: 

Tenzer Greenblatt LLP 
The Chrysler Building 
405 Lexington Avenue 
New York, New York 10174 

Richard Weinberg, Esq. 
General Counsel 
The Council of the City of New York 
75 Park Place, 5th Floor 

New York, New York 10007 

by placing a copy in the United States mail. 

lA ee 
MATTHEW KADUSHIN 
  

Sworn to before me this 

20th day of November, 1996 

[ 
  

Notary Public 

EVELYN ANDERSON 

Notary Public, State of New York 
No.01ANS5052182 

ualified in New York County 

hE Expires November 20,1997  



  

SUPREME COURT OF THE STATE OF NEW YORK 
COUNTY OF QUEENS 

THE COUNCIL OF THE CITY OF NEW YORK, et al. 

Plaintiffs, INDEX NO. 004897-96 

- against - 

RUDOLPH W. GIULIANI, THE MAYOR OF THE 
CITY OF NEW YORK, et al, 

Defendants. SUPPLEMENTAL AFFIRMATION OF 
RACHEL D. GODSIL WITH EXHIBIT 
  

CAMPAIGN TO SAVE OUR PUBLIC HOSPITALS - 
QUEENS COALITION, an unincorporated 
association, et al., 

Plaintiffs, INDEX NO. 10763/96 

- against - 

RUDOLPH W. GIULIANI, THE MAYOR OF THE 
CITY OF NEW YORK, et al., 

Defendants. 

KENNETH KIMERLING 
PUERTO RICAN LEGAL DEFENSE & EDUCATION FUND, INC. 
99 Hudson St., 14th Floor 
New York, N.Y. 10013 
212-219-3360 

ELAINE R. JONES 
Director-Counsel 

NORMAN CHACHKIN 
MARIANNE L. ENGELMAN LADO 
RACHEL D. GODSIL 
NAACP LEGAL DEFENSE & EDUCATIONAL FUND, INC. 
99 Hudson St., 16th Floor 
New York, New York 100183 
212-219-1900 

BARBARA OLSHANSKY 
CENTER FOR CONSTITUTIONAL RIGHTS 
666 Broadway, 7th Floor 
New York, N.Y. 10012 
212-664-6464 

ATTORNEYS FOR PLAINTIFFS 

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