FRIEDMAN KRAUSS & ZLOTOLOW
Robert N. Fass (RF-9146)
888 Seventh Avenue
New York, New York 10106
(212) 247-5990
Attorney for Plaintiff

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

PLEASE TAKE NOTICE that, upon the Stipulation of Undisputed Facts signed by all counsel and dated March 15, 2001, and the exhibits thereto, the Affidavit of Mark Lilian , sworn to on May 18th 2001, and the exhibits thereto, and upon all prior pleadings and proceedings herein in the action to date, Defendant, 350 Bleecker Street Apartment Corporation (the "Cooperative"), will cross move before the Honorable Gerald E. Lynch, at the United States Courthouse, Southern District of New York, 40 Centre Street, Room 1815, New York, New York 10007, for an order, pursuant to Rule 56, Fed. R. Civ. Pro. granting partial summary judgment.

1. declaring that ("the Garage Portion") of the Agreement of Lease dated July 31,

1985 ("the Master Lease") between the Cooperative, as landlord, and Plaintiff, Bleecker Charles Company (the "Sponsor"), as tenant, covering a public parking garage ("the Garage") at the building known as 350 Bleecker Street in the City, County and State of New York ("the Premises"), was validly terminated pursuant to the Condominium and Cooperative Conversion Protection and Abuse Relief Act, 15 U.S.C. §§ et. seq.;

2. granting the Cooperative possession of the Garage; and
3. granting such other or further relief as may be just and proper.

Dated: New York
May 18, 2001

FRIEDMAN KRAUSS & ZLOTOLOW

By: ____________________________

Robert N. Fass (RF-9146)
888 Seventh Avenue
New York, NY 10106
(212) 247-5990
Attorneys for Defendant

TO: Dale A. Schreiber, Esq.
Allison B. Feld, Esq.

Proskauer Rose LLP
1585 Broadway
New York, NY 10036
(212) 969-3000
Attorneys for Plaintiff

Vincent J. Syracuse, Esq.
Tannenbaum Helpern Syracuse & Hirschtritt LLP
900 Third Avenue
New York, NY 10022
(212) 508-6700
Attorneys for Additional Counterclaim Defendant