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CIVIL COURT OF THE CITY OF NEW YORK

COUNTY OF KINGS Index No. L&T:

MICHAEL KRICHEVSKY
Petitioner/Landlord,

- against-
NOTICE OF PETITION
NATALIA KARDYUKOVA
NONPAYMENT
Respondent(s)/Tenant(s)
All rooms, Apt.
r
5D,
'
120 Oceana Dr. West □□□□□□□
Brooklyn, New York 11235 t> • ajj
Petitioner s Address:
- and - 4221 Atlantic Ave.

JOHN DOE Brooklyn, NY 11224


Respondent(s)/Undertenant(s)

Your landlord is suing you for nonpayment of rent.

1. Your landlord has started an eviction nonpayment case against you for rent the landlord claims you owe.
The landlord's reasons are given in the attached Petition.

2. Your landlord is asking this Court for:


• a money judgment for $21,000, plus interest from July 1, 2018, and
• permission to evict you from your home if you do not pay the money judgment.

3. You have a right to a trial. But first you must Answer the Petition by going to the landlord-tenant Clerk's
Office at: 141 Livingston Street, Brooklyn, NY 11201. You must do this within 5 days after the date these
papers were given to you or a person who lives or works in your home, or were posted at your home at:
Address or description of the premises

All rooms. Apt. 5D, 120 Oceanja Dr. West, Kings, New York

Warning! If you don't Answer the Petition within 5 days, a judgment may be entered against you. If that
happens, the landlord will have the right to evict you.

4. Your Answer should say the legal reasons that you don't owe all or part of the rent. The legal reasons are
called defenses. You can also say any claims you have against the landlord. You will have to prove your
defenses and claims in court. To Answer the Petition you must either:
• Go to the landlord-tenant Clerk's Office and tell the Clerk your Answer, or
• Give the landlord-tenant Clerk your Answer in writing (Form No. Civ-LT-91a).
Information to help you Answer the Petition is attached (Form No. Civ-LT-92).
Important! If you don't tell the Clerk about a defense in your Answer you might not be able to talk about it
later in this case or any other case.

5. When you Answer the Petition, you will get a date to come back to Court 3 to 8 days later.
6. If your name is not on this Notice but you live in the home listed above, you have a right to come to Court
and Answer the Petition.

7. Available Resources:
• Language Help: If you don't speak English well you have a right to a free court interpreter. Tell the
Court Clerk you need an interpreter, or call 646 386-5670. To read a translation of this Notice in another
language visit: httD://nvcourl.s.uov/housinunvc. For information on evictions:
646 386-5750: Informations concemant les expulsions •
• HH^OpMaUHH O BblCeJieHHH •
CiL^jk« • Enfomasyon Konsenan Degepisman • Informacion sobre desalojos
• ADA Help: If you need special accommodations to use the court because of a disability, tell a Court
Clerk or ADA contact person listed at:
http://ww'^\'.nvcourts.uo\7COURTS/nvc/hoiisinu/services.shtml#ada or call 646 386-5300 or 711 (TTY).
• Financial Help: If you owe the rent and don't have the money, contact HRA's Infoline at 718 557-1399
for more information about getting help to pay the rent.
• Legal Help: The court does not give you a lawyer. If you do not have money to hire a lawyer, contact
the Legal Aid Society 212 577-3300 or Legal Services 212 431-7200 or visit LawHelpNY at
http://www.lawhelpnv.or^. If you have money to hire a lawyer, you can contact the New York City Bar
Legal Referral Service at 212 626-7373.
• Help at the Courthouse: There is a Help Center in the courthouse where you can speak to a Court
Attorney or a Volunteer Lawyer.
• Online Help: Visit the Housing Court's website at: hrtp://wvv\v.nvcoiirts.gov7nvchousinu (also available
in Spanish and Chinese) or visit LawHelpNY at www.lawhelpny.org.

Postponements and Rent Deposits. In court, you can ask^to postpone your case. But, if your case is not finished
30 days after the first court date, or you ask to postpone the case twice, the court can order you to deposit
money in court or make a rent payment to the landlord. If you don't do this, the landlord may get a judgment
against you without a trial. If you fajl to make future payments ordered by the court, your case may go to trial
right away. RPAPL Sec. 745.

After Judgment. If the court orders a judgment against you after a trial, the court may give you up to 5 days to
pay the judgment and not be evicted. Once the warrant of eviction is issued, the landlord can still evict you even
if you pay the rent. After the warrant is issued, you will get a Notice of Eviction from a Marshal giving you at
least 72 hours to move. If you don't move you will be evicted. RPAPL Sec. 749(2).

City of New York, County of Kings


Dated: .20
Clerk of the Civil Court ofthe City of New York:

Michael Krichevsky
Petitioner
4221 Atlantic Ave.
Brooklyn, NY, 11224
(718)687-2300
CIVIL COURT OF THE CITY OF NEW YORK
COUNTY OF KINGS Index No. L&T:

Michael Krichevsky
Petitioner/Landlord,

-against-
PETITION
Natalia Kardyukova
Respondent(s)/Tenant(s) NONPAYMENT
All rooms. Apt. 5D, 120 Oceana Dr.
□□□□□□a
West
Petitioner's Address:
Brooklyn, New York 11235
4221 Atlantic Ave.
-and- Brooklyn, NY 11224
John Doe
Respondent(s)/Undertenant(s)

THE PETITION OF Michael Krichevsky shows that:

1. Petitioner Michael Krichevsky is the owner/landlord of the premises.

2. Respondent/tenant(s) Natalia Kardyukova is the month-to-month tenant of the premises.


3. She entered into possession by oral rental agreement made on or about April 1, 2018,
between Respondent/tenant(s) and myself, in which respondent(s) promised to pay $ 3,500 rent
each month payable on the 1 st day of the month.
4. However, respondent refused to pay rent upon oral demand starting in April 1, 2018.
5. Respondent did not give any reason to landlord as to why she refused to pay rent and told
that her attorney, Arkady Bukh, would contact me.

6. Respondent refused to move out without giving landlord any reason for such decision.
7. Respondent/undertenant(s) John Doe is/are the unknown, fictitious names, possible
undertenant(s) of Respondent/tenant(s) Natalia Kardyukova.
8. Upon information and belief, Respondent rents out some part of the premises to John
Doe(s), tourist(s) from Russia, without my consent.
9. The premises are described as follows: 1500 sq ft. two-bedroom duplex apartment. Apt.
5D, 120 Oceana Dr. West, Brooklyn, New York 11235, which is located in jurisdiction of this
Court, County of Kings.

Made using the Civil Court of the City of New York's


FREE DIY Forms program.
10. Under the agreement, the rent was due to landlord from Respondent/tenant on April 1,

2018.

11. Prior to agreement, Respondent hired Bukh Law Firm, PC to advise her about

landlord/tenant law.

12. As a direct result ofthis advice, respondent decided not to pay rent and enter into court

litigation using attomeys.

13. Attomeys began delaying the outcome of litigation.

14. "FREE DIY Forms" computer program that I used to prepare this petition advised me

that I could only sue respondent in housing Court for the 6 Month Arrears. Accordingly, without

waiving my right to sue respondent for the difference of$10,500 plus interest in another court, I

sue her for the 6 months stated below in compliance with the program.

15. The following rent was due to landlord from Respondent/tenant(s):

$3500-July 2018

$ 3500 - August 2018

$ 3500 - September 2018

$ 3500 - September 2018

$ 3500 - October 2018

$ 3500 - November 2018

16. Respondent/tenant(s) has not paid, and the total rent owed for 6 month is $ 21,000.
17. The rent was orally demanded from the Respondent/tenants in April and May of 2018.

18. The rent was demanded in writing from the Respondent/tenants through her attomeys

Bukh Law Firm, PC and BALSAMO & ROSENBLATT.

19. Last time, the rent was demanded in writing from the Respondent/tenants and is

evidenced by Exhibit A.

20. Respondent/tenant(s) converted premises into rooming house and antics warehouse
without petitioner's permission.

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21. Respondent/tenant(s) continue in possession of the premises without petitioner's

permission after failing to pay the rent from April 1, 2018.

22. The premises is not rent regulated because it is luxury multi building condominium

complex.

23. The premises is a multiple dwelling and pursuant to the Administrative Article 41 there is
a currently effective registration statement on file with the Office of Code Enforcement in which
I have designated the managing agent named below,a natural person over 21 years of age, to be
in control of and responsible for the maintenance and operation of the building.

Multiple Dwelling Registration Number: 377881

Registered Managing Agent: Matina Monioudis

Address: 40 Oceana Dr. West, Brooklyn, New York, 11235.

Petitioner requests final judgment awarding possession of the premises to the


petitioner/landlord, issuance of a warrant to remove respondent(s) ixom possession,judgment for
rent in arrears against respondent Tenant(s)for $ 21,000, and costs and disbursements.

Dated: November 22, 2018

Michael Krichevsky

VERIFICATION

STATE OF NEW YORK,COUNTY OF KINGS ss: The petitioner, being duly sworn states:
That deponent has read the petition, and the contents of the petition are true to deponent's own
knowledge except as to those matters which are alleged on information and belief, and as to them
deponent believes them to be true.

Michael Krichevsky
:nevsKy-

i(
Sworn to before me on November 23,
ALEKSANDR RUBIN
Notary Public State ofNew York
NO.0IRU6108300
yualificd in Kings County "7^
Notary Fublic Commission Btipiros April 12,20

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EXHIBIT A
RENT DEMAND

November 17, 2018

Re: Residential premises:


All rooms. Apt. 5D, 120 Oceana
Dr. West
Brooklyn, New York 11236

TO:

Natalia Kardyukova, Tenant(s)

All rooms, Apt. 5D, 120 Oceana Dr. West


Brooklyn, New York 11235

and every person in possession of the premises.

Please take notice that you owe rent for the following months:

$3500-July 2018
$ 3500-August2018
$ 3500 - September 2018
$ 3500 - September 2018
$3500-October 2018
$ 3500 - November 2018

The total rent now due is $ 21,000.

If you do not pay the total rent due on or before the expiration of three days from
the date of the service of this notice, or give possession of said premises to the
landlord, the landlord will commence summary proceedings to evict you.

Dated: November 17, 2018


Michael Krichevsky, Landlord
4221 Atlantic Ave.
Brooklyn. NY 11224
(718)687-2300

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