SUPREME COURT STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------x

350 BLEECKER STREET APARTMENT                     : Index #: 113271/02
CORPORATION 

               Plaintiff,                         : NOTICE OF DEPOSITION
                                             
                     v.                           :

KENNETH B. NEWMAN, individually and as 
managing/general partner of BLEECKER CHARLES      :
COMPANY and KENNETH B. NEWMAN 
REALTY CORP.,                                     :

               Defendants.
--------------------------------------------------x
KENNETH B. NEWMAN,                                :

           Defendant and Third-Party Plaintiff,   :

                     v.                           : Index No. 91057/02

MARK LILIEN AND JAMES D. KAFADAR                  :

           Third-Party Defendants.                :

--------------------------------------------------x

                    PLEASE TAKE NOTICE that, pursuant to Rule 3107 of the Civil Practice Law and Rules, defendants will take the deposition upon oral examination of plaintiff 350 Bleecker Street Apartment Corp., by its of officers, directors, employees and agents with knowledge of the subject matter of this action, including but not limited to:

beginning on October 29, 2002 at 10:00 a.m. at the offices of Proskauer Rose LLP, 1585 Broadway, New York, NY 10036. The deposition will be taken before a notary public or other officer authorized by law to administer oaths and will continue from day to day until completed. You are invited to attend and cross-examine.

                    PLEASE TAKE FURTHER NOTICE that each witness to be deposed is required to produce at his, her or its deposition all documents and other tangible things (as those terms are defined in Rule 3120 of the Civil Practice Law and Rules), including but not limited to computer lists, tapes and all other storage media, that embody any document or contain any document, entry or data that is relevant to any claim, defense or any counterclaim in this action.

Dated:   New York, NY
             October 9, 2002

TO:

MITCHELL R. SCHRAGE & ASSOCIATES, PLLC
Attorneys for Plaintiff
126 East 56th Street
New York, NY 10022
(212) 758-9000

MARK LILIEN
350 Bleecker St.
Apartments 3D-3E-3F
New York, NY 10014

JAMES D. KAFADAR
350 Bleecker St.
Apartments 6C-6D-6E
New York, NY 10014

SUPREME COURT STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------x

350 BLEECKER STREET APARTMENT                     : Index #: 113271/02
CORPORATION 

               Plaintiff,                         : NOTICE OF DEPOSITION
                                             
                     v.                           :

KENNETH B. NEWMAN, individually and as 
managing/general partner of BLEECKER CHARLES      :
COMPANY and KENNETH B. NEWMAN 
REALTY CORP.,                                     :

               Defendants.
--------------------------------------------------x
KENNETH B. NEWMAN,                                :

           Defendant and Third-Party Plaintiff,   :

                     v.                           : Index No. 591057/02

MARK LILIEN AND JAMES D. KAFADAR                  :

           Third-Party Defendants.                :

--------------------------------------------------x

                    PLEASE TAKE NOTICE that, pursuant to Rule 3107 of the Civil Practice Law and Rules, defendants will take the deposition upon oral examination of Friedman, Krauss & Zlotolow, whose address is 888 Seventh Avenue, New York, New York 10106-0299, as a third-party witness, by its of ficers, directors, employees and agents with knowledge of the subject matter of this action, including but not limited to:

beginning on November 4, 2002 at 10:00 a.m. at the offices of Proskauer Rose LLP, 1585 Broadway, New York, NY 10036. The deposition will be taken before a notary public or other officer authorized by law to administer oaths and will continue from day to day until completed. You are invited to attend and cross-examine.

                    PLEASE TAKE FURTHER NOTICE that each witness to be deposed is required to produce at his, her or its deposition all documents and other tangible things (as those terms are defined in Rule 3120 of the Civil Practice Law and Rules), including but not limited to computer lists, tapes and all other storage media, that embody any document or contain any document, entry or data that is relevant to any claim, defense and/or counterclaim in this action, as set forth more particularly in Schedule A annexed hereto.

Dated:   New York, NY
             October 9, 2002

TO:

MITCHELL R. SCHRAGE & ASSOCIATES, PLLC
Attorneys for Plaintiff
126 East 56th Street
New York, NY 10022
(212) 758-9000

MARK LILIEN
350 Bleecker St.
Apartments 3D-3E-3F
New York, NY 10014

JAMES D. KAFADAR
350 Bleecker St.
Apartments 6C-6D-6E
New York, NY 10014

Schedule A

     1.       Each and every calendar, diary, time sheet, computer entry or other notation or data describing, identifying or referencing the date, time and/or place of any contact that you had with Mark Lilien ("Lilien"), James Kafadar ("Kafadar") or any other shareholder, officer, director or representative of plaintiff 350 Bleecker Street Apartment Corp. ("the Coop") prior to June 1, 1999.

     2.       Each and every document or other data entry evidencing, embodying or indicating the date upon which you first informed Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op that there was legislation of any kind that enabled the Co-op or any of its shareholders to seek to disaffirm or terminate its lease with defendant Bleecker Charles Company ("the Sponsor") ("the Master Lease") covering the garage ("the Garage") located at 350 Bleecker Street in the City, County and State of New York ("the Building"), including but not limited to the Condominium and Cooperative Conversion Protection and Abuse Relief Act, 15 U.S.C. §§3601 et seq. ("the Act").

     3.       Each and every document or entry embodying, evidencing or indicating when you first prepared or reviewed any draft of the notice dated June 1, 1999 from Lilien to shareholders of the Co-op calling for a shareholders' meeting to vote upon a resolution to terminate, pursuant to the Act, the Master Lease insofar as it covered the Garage or any other portion of the leased premises.

     4.       Each and every document or entry embodying, evidencing or indicating when you first received any information regarding the number of units in Sponsor's conversion plan covering the Building and/or the identity of the person from whom you received such information.

     5.       Each and every document or entry embodying, evidencing or indicating when you first prepared any form of retainer agreement pursuant to which you proposed that the Co-op retain the firm of Friedman, Krauss & Zlotolow or any partner or attorney associated or affiliated with that firm.

     6.       Each and every document or entry embodying or evidencing any advice, whether oral or written, that you gave to Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op regarding the manner in which units would be counted under the Act for purposes of determining when the so-called "window period" thereunder opened and/or for voting for terminating any contract or lease, including the Master Lease, under the Act.

     7.       Each and every document or entry embodying or evidencing any advice, whether oral or written, that you gave to Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op regarding the termination of the Master Lease, insofar as it covers the Garage or otherwise, pursuant to the Act.

     8.       Each and every document or entry embodying any bill or invoice that you rendered for any services performed or advice rendered prior to June 1, 1999 to Lilien, Kafadar or any other shareholder, of ficer, director or representative of the Co-op.

     9.       Each and every document or entry embodying or referring to any payment received from Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op for any services performed or advice rendered prior to June 1, 1999, whether or not pursuant to any bill or invoice described in item 8 above.

SUPREME COURT STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------x

350 BLEECKER STREET APARTMENT                     : Index #: 113271/02
CORPORATION 

               Plaintiff,                         : NOTICE OF DEPOSITION
                                             
                     v.                           :

KENNETH B. NEWMAN, individually and as 
managing/general partner of BLEECKER CHARLES      :
COMPANY and KENNETH B. NEWMAN 
REALTY CORP.,                                     :

               Defendants.
--------------------------------------------------x
KENNETH B. NEWMAN,                                :

           Defendant and Third-Party Plaintiff,   :

                     v.                           : Index No. 591057/02

MARK LILIEN AND JAMES D. KAFADAR                  :

           Third-Party Defendants.                :

--------------------------------------------------x

                    PLEASE TAKE NOTICE that, pursuant to Rule 3107 of the Civil Practice Law and Rules, defendants will take the deposition upon oral examination of Robert Fass, whose address is c/o Friedman, Krauss & Zlotolow, 888 Seventh Avenue, New York, New York 10106-0299, as a third-party witness, beginning on November 4, 2002 at 10:00 a.m. at the offices of Proskauer Rose LLP, 1585 Broadway, New York, NY 10036. The deposition will be taken before a notary public or other officer authorized by law to administer oaths and will continue from day to day until completed. You are invited to attend and cross-examine.

                    PLEASE TAKE FURTHER NOTICE that each witness to be deposed is required to produce at his, her or its deposition all documents and other tangible things (as those terms are defined in Rule 3120 of the Civil Practice Law and Rules), including but not limited to computer lists, tapes and all other storage media, that embody any document or contain any document, entry or data that is relevant to any claim, defense and/or counterclaim in this action, as more particularly set forth in Schedule A annexed hereto.

Dated:   New York, NY
             October 9, 2002

TO:

MITCHELL R. SCHRAGE & ASSOCIATES, PLLC
Attorneys for Plaintiff
126 East 56th Street
New York, NY 10022
(212) 758-9000

MARK LILIEN
350 Bleecker St.
Apartments 3D-3E-3F
New York, NY 10014

JAMES D. KAFADAR
350 Bleecker St.
Apartments 6C-6D-6E
New York, NY 10014

Schedule A

     1.       Each and every calendar, diary, time sheet, computer entry or other notation or data describing, identifying or referencing the date, time and/or place of any contact that you had with Mark Lilien ("Lilien"), James Kafadar ("Kafadar") or any other shareholder, officer, director or representative of plaintiff 350 Bleecker Street Apartment Corp. ("the Coop") prior to June 1, 1999.

     2.       Each and every document or other data entry evidencing, embodying or indicating the date upon which you first informed Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op that there was legislation of any kind that enabled the Co-op or any of its shareholders to seek to disaffirm or terminate its lease with defendant Bleecker Charles Company ("the Sponsor") ("the Master Lease") covering the garage ("the Garage") located at 350 Bleecker Street in the City, County and State of New York ("the Building"), including but not limited to the Condominium and Cooperative Conversion Protection and Abuse Relief Act, 15 U.S.C. §§3601 et seq. ("the Act").

     3.       Each and every document or entry embodying, evidencing or indicating when you first prepared or reviewed any draft of the notice dated June 1, 1999 from Lilien to shareholders of the Co-op calling for a shareholders' meeting to vote upon a resolution to terminate, pursuant to the Act, the Master Lease insofar as it covered the Garage or any other portion of the leased premises.

     4.       Each and every document or entry embodying, evidencing or indicating when you first received any information regarding the number of units in Sponsor's conversion plan covering the Building and/or the identity of the person from whom you received such information.

     5.        Each and every document or entry embodying, evidencing or indicating when you first prepared any form of retainer agreement pursuant to which you proposed that the Co-op retain the firm of Friedman, Krauss & Zlotolow or any partner or attorney associated or affiliated with that firm.

     6.       Each and every document or entry embodying or evidencing any advice, whether oral or written, that you gave to Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op regarding the manner in which units would be counted under the Act for purposes of determining when the so-called "window period" thereunder opened and/or for voting for terminating any contract or lease, including the Master Lease, under the Act.

     7.       Each and every document or entry embodying or evidencing any advice, whether oral or written, that you gave to Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op regarding the termination of the Master Lease, insofar as it covers the Garage or otherwise, pursuant to the Act.

     8.       Each and every document or entry embodying any bill or invoice that you rendered for any services performed or advice rendered prior to June 1, 1999 to Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op.

     9.       Each and every document or entry embodying or referring to any payment received from Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op for any services performed or advice rendered prior to June 1, 1999, whether or not pursuant to any bill or invoice described in item 8 above.

SUPREME COURT STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------x

350 BLEECKER STREET APARTMENT                     : Index #: 113271/02
CORPORATION 

               Plaintiff,                         : NOTICE OF DEPOSITION
                                             
                     v.                           :

KENNETH B. NEWMAN, individually and as 
managing/general partner of BLEECKER CHARLES      :
COMPANY and KENNETH B. NEWMAN 
REALTY CORP.,                                     :

               Defendants.
--------------------------------------------------x
KENNETH B. NEWMAN,                                :

           Defendant and Third-Party Plaintiff,   :

                     v.                           : Index No. 591057/02

MARK LILIEN AND JAMES D. KAFADAR                  :

           Third-Party Defendants.                :

--------------------------------------------------x

                    PLEASE TAKE NOTICE that, pursuant to Rule 3107 of the Civil Practice Law and Rules, defendants will take the deposition upon oral examination of Walter D. Goldsmith, whose address is c/o Friedman, Krauss & Zlotolow, 888 Seventh Avenue, New York, New York 10106-0299, as a third-party witness, beginning on November 5, 2002 at 10:00 a.m. at the offices of Proskauer Rose LLP, 1585 Broadway, New York, NY 10036. The deposition will be taken before a notary public or other officer authorized by law to administer oaths and will continue from day to day until completed. You are invited to attend and cross-examine.

                    PLEASE TAKE FURTHER NOTICE that each witness to be deposed is required to produce at his, her or its deposition all documents and other tangible things (as those terms are defined in Rule 3120 of the Civil Practice Law and Rules), including but not limited to computer lists, tapes and all other storage media, that embody any document or contain any document, entry or data that is relevant to any claim, defense and/or counterclaim in this action, as more particularly set forth in Schedule A annexed hereto.

Dated:   New York, NY
             October 9, 2002

TO:

MITCHELL R. SCHRAGE & ASSOCIATES, PLLC
Attorneys for Plaintiff
126 East 56th Street
New York, NY 10022
(212) 758-9000

MARK LILIEN
350 Bleecker St.
Apartments 3D-3E-3F
New York, NY 10014

JAMES D. KAFADAR
350 Bleecker St.
Apartments 6C-6D-6E
New York, NY 10014

Schedule A

     1.       Each and every calendar, diary, time sheet, computer entry or other notation or data describing, identifying or referencing the date, time and/or place of any contact that you had with Mark Lilien ("Lilien"), James Kafadar ("Kafadar") or any other shareholder, officer, director or representative of plaintiff 350 Bleecker Street Apartment Corp. ("the Coop") prior to June 1, 1999.

     2.       Each and every document or other data entry evidencing, embodying or indicating the date upon which you first informed Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op that there was legislation of any kind that enabled the Co-op or any of its shareholders to seek to disaffirm or terminate its lease with defendant Bleecker Charles Company ("the Sponsor") ("the Master Lease") covering the garage ("the Garage") located at 350 Bleecker Street in the City, County and State of New York ("the Building"), including but not limited to the Condominium and Cooperative Conversion Protection and Abuse Relief Act, 15 U.S.C. §§3601 et seq. ("the Act").

     3.       Each and every document or entry embodying, evidencing or indicating when you first prepared or reviewed any draft of the notice dated June 1, 1999 from Lilien to shareholders of the Co-op calling for a shareholders' meeting to vote upon a resolution to terminate, pursuant to the Act, the Master Lease insofar as it covered the Garage or any other portion of the leased premises.

     4.       Each and every document or entry embodying, evidencing or indicating when you first received any information regarding the number of units in Sponsor's conversion plan covering the Building and/or the identity of the person from whom you received such information.

     5.        Each and every document or entry embodying, evidencing or indicating when you first prepared any form of retainer agreement pursuant to which you proposed that the Co-op retain the firm of Friedman, Krauss & Zlotolow or any partner or attorney associated or affiliated with that firm.

     6.       Each and every document or entry embodying or evidencing any advice, whether oral or written, that you gave to Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op regarding the manner in which units would be counted under the Act for purposes of determining when the so-called "window period" thereunder opened and/or for voting for terminating any contract or lease, including the Master Lease, under the Act.

     7.       Each and every document or entry embodying or evidencing any advice, whether oral or written, that you gave to Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op regarding the termination of the Master Lease, insofar as it covers the Garage or otherwise, pursuant to the Act.

     8.       Each and every document or entry embodying any bill or invoice that you rendered for any services performed or advice rendered prior to June 1, 1999 to Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op.

     9.       Each and every document or entry embodying or referring to any payment received from Lilien, Kafadar or any other shareholder, officer, director or representative of the Co-op for any services performed or advice rendered prior to June 1, 1999, whether or not pursuant to any bill or invoice described in item 8 above.