SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK

x CITIZENS DEFENDING LIBRARIES, : EDMUND MORRIS, ANNALYN SWAN, : STANLEY N. KATZ, THOMAS BENDER, : Index No.: 652427/2013 DAVID NASAW, JOAN W. SCOTT, : CYNTHIA M. PYLE, CHRISTABEL GOUGH, and BLANCHE WEISEN COOK, Plaintiffs, - against - DR. ANTHONY W. MARX, NEIL L. : RUDEN S TINE, BOARD OF TRUSTEES : OF THE NEW YORK PUBLIC LIBRARY, : NEW YORK PUBLIC LIBRARY, ASTOR, : LENOX AND TILDEN FOUNDATIONS, MICHAEL R. BLOOMBERG, VERONICA WHITE, NEW YORK CITY : PARKS DEPARTMENT, CITY OF NEW : YORK, ROBERT SILMAN ASSOCIATES,: P.C., and JOSEPH TORTORELLA, Defendants. -andSTATE OF NEW YORK, NEW YORK STAT E OFFICE OF PARKS, RECREATION & HISTORIC PRESERVATION (NEW YORK STATE HISTORIC PRESERVATION OFFICE), Nominal Defendants. : AFFIDAVIT OF CHRISTABEL GOUGH

STATE OF NEW YORK )

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COUNTY OF NEW YORK ) CHRISTABEL GOUGH, having been duly sworn, deposes and says: 1. I am a plaintiff in this action. I submit this Affidavit in Support of the Order to

Show Cause for, among other things, an order immediately restraining the planned demolition and removal of the stacks ("Stacks") located at the eminent and historic library fronting Fifth Avenue at 42nd Street ("Central Library"). As discussed below and in the accompanying papers, demolition and removal of the Stacks are part of an overarching scheme by which the historic core of the Central Library -- seven stories of structural steel and iron shelving that were, for more than a century, filled with millions of books and other resource materials are to be gutted out and replaced with an atrium, sarcastically described by the architectural critic of The New York Times as having "all the elegance and distinction of a suburban mall," thus irreparably destroying one of New York's most precious architectural masterpieces. Personal Background 2. I am a historic preservationist and long-time user of the New York Public Library

("NYPL"). More than 50 years ago, I discovered that New York had a research library at 42nd Street (the Central Library) open to alland that whatever question I had would probably be a topic in the card catalog there. The cards had been thumbed through by so many hands that they were worn round at the edges, in the same way that the stone steps of a cathedral can be worn down by millions of feet. There, in the library, I could find books I never knew existed as well as other items unavailable elsewhere, all of which could be retrieved almost at once and read in circumstances of splendor. The Central Library was a palace for books, and the books were a guiding link to the past.

3.

Like most users of the Central Library, I am not among the renowned literary

figures who depend on it for their work. But I do depend on it as an invaluable resource for research and documentation; for learning. I have used the Central Library throughout my life, and my life has been enriched and is the better for it. The Central Library is one of the crucial civic amenities that make it worthwhile for someone like me to live here in New York. 4. My activities as an historic preservation advocate, in part, are grounded in my own

history. As a small child during World War II, I was terrified by stories and newsreels reporting air raids and the destruction of cities. Warring factions from both sides deliberately bombed architectural monuments as well as military targets like railroads, because the military understood the devastating psychological effect that the loss of national heritage can have on a people. Axis powers rained firebombs on St. Paul's Cathedral, and the people risked their lives to extinguish resultant fires with buckets of sand; the cathedral at Coventry was lost, and the allies retaliated by obliterating the monuments of the city of Dresden. Perhaps many reacted with fear as I did, because after the War, there was a huge increase in landmarks preservation legislation throughout the world. So it is sad to see, in time of peace, the damage we are doing to ourselves, to our' ur own National Historic Landmark at 42nd Street. Preserving the Central Library 5. Protection cannot come from our local landmarks law, which designates only

building interiors when they are customarily accessible to the public. Members of the NYPL executive staff have incorrectly stated that the Central Library Plan, which is the overarching scheme pursuant to which the Stacks and their books are slated to be removed, was approved by the Landmarks Preservation Commission. In fact, no approval was ever granted by the LPC because it has no jurisdiction over the interior demolition of the Stacks that the NYPL has 3

proposed. 6. The library is important from the standpoint of historic preservation, not only for its

beauty and its iconic place at a crossroads of the city, but because it is a fine example of the work of those American builders and architects at the turn of the 20th Century who adapted the Beaux Arts/City Beautiful tradition and made it their own through new efficiencies and new interior configurations to meet contemporary needs. They made good use of the classical orders and classically derived decoration without in any way sacrificing functionality, rational circulation through space, or even expression of function on the building's shell. The Central Library's west facade has been cited by critics as an early example of modernism, since the unusual long slit windows both light and express the presence of the book Stacks. Like Grand Central Station, or the original Penn Station, the library is a fusion of new performance standards and old tradition, an efficiently functioning machine as well as a delight to the eye. Gutting the interior obliterates its real place in architectural history. 7. The conception and execution of the public research library, and the Central

Library building dedicated to it, grew out of the Astor, Lenox and Tilden bequests and the official formation of the New York Public Library as a single, consolidated corporation in 1895. It was given form by the chief librarian, John Shaw Billingswho designated the location of .the reading room together with the design and placement of the book Stacks beneath it, lit by sliver windows and equipped with pneumatic tubes to summon the books and mechanical lifts to retrieve themcreated one of the most efficient and practical book delivery systems in the world. The young architects, Carrere and Hastings, were chosen through a competition because they best accommodated Billings' concept in their final design. Under the CLP, all this history will be erased. 4

8.

A parallel initiative, commenced somewhat later, was the expansion and

consolidation of the branch lending libraries in conjunction with Andrew Carnegie's enormous 1901 gift, which has been described as the equivalent of $2.7 billion today. Under the terms of the consolidation, a small lending library was incorporated into the research library building, located in the north courtyard light shaft; it is now known as the Bartos Forum. It is a strange interpretation of history to claim (as NYPL publicity does) that this small facility was so important that it must be made larger and brought back at the expense of the functionality of the research library for which the building was conceived and built. 9. In fact, in the 1970s, a different board of trustees determined that the research

library building could not adequately accommodate the needs of a growing midtown circulating branch. Consequently, they took the initiative of creating the present Mid Manhattan Library on 40th Street, with the benefits of appropriate space and very convenient street level access for patrons in a hurry, not to mention excellent accommodation for Americans with Disabilities. The Mid Manhattan has suffered from deferred maintenance, for which the trustees are responsible, but even without expansion it is larger than the space that would be made for it by the demolition proposed under the Central Library Plan. The budgetary potential of treating a public asset like the Mid Manhattan Library as a real estate investment ripe for sale is perhaps outweighed by the enormous (and not yet finally estimated) cost of the structural re-enforcement required to support the Central Library, if the original structural support provided by the Stacks were to be removed in the planned demolition. 10. As with the 2005 private sale of Asher Durand's Hudson River school masterwork,

"Kindred Spirits," from the Library's collection, the executive staff and trustees fail to understand that their actions cause irreparable loss to the people of this city. The shrinkage of our libraries, .,5

the short-sighted sale of our public assets, and the ill-judged demolition of the Stacks that have served inquisitive minds for more than a century, will lay waste to an integral part of the distinct cultural landscape that makes New York our home.

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CHRISTABE GOU Sworn to before me this day of July, 2013.

LAUREN A. RUDICK Notary Public, State of New York No. 02RU6245314 Qualified in New York County Commission Expires July 18, 20 ' 3