CORRESPONDENCE AND DOCUMENTS BSA 2006-2008
(latest documents first)
Opposition Exhibits
Opp. Ex. QQ Filed July 29, 2008
Opp. Ex. OO Filed July 29, 2008
Opp. Ex. NN Filed July 29, 2008
Opp. Ex. MM Filed July 29, 2008 - Freeman Docs
Opp. Ex. LL Filed July 29, 2008
Opp. Ex. KK April 15, 2008
GG - Drawings Classroom Space and Access - March 25, 2007
HH - Re Beit Rabban IRS Form 990 and Rent - March 25, 2007
JJ - Re Classrooms, Toddler Program - March 25, 2007
A to FF Opposition Exhibit Binder I (Large File: 11 MB) - January 28, 2008
July 29, 2008 Filings
Sugarman Post Hearing Brief
Landmark West - Kate Wood - Synthesis of Prior Filings
Landmark West Cover Letter
Marty Levine - MVS - Opposition Feasibiity Expert
Jay Greer - Opposition Statement Re Classrooms and Lower Floor Variances
July 8, 2008 Congregation Filings With BSA
Friedman & Gotbaum Cover Letter.
July 8, 2008 Statement in Support (55 Pages).
Changes in July 8, 2008 Statement as Compared to May 13, 2008
Statement.
Freeman & Frazier Further Feasability Study and Responses (12 pages).
Revision to Drawing P-3 Showing Refrigerated Garbage Storage Room.
June 24, 2008 Hearing
Transcript - Official Transcription
Transcript- Opponent Transcription.
Transcript- Opponent Transcription - 4 up.
Alan D. Sugarman Sur-Reply Letter in Opposition.
Martin Levine sur-reply letter re feasibility studies.
June 17, 2008 Congregation Filings - Congregation Admits False Statement to BSA and that No Case Law Supports its Position
June 17, 2008 CSI Reply Filing to BSA Complete (61 pages),
Friedman & Gotbaum Statement for Applicant
Freeman Frazier - Yet Another Letter Re Feasibility.
AKRF - Yet another attempt re Environmental Study
June 10, 2008. Opposition Files New Statements
Sugarman Supplemental Opposition Brief - 41 pages.
Mulford Economic Analysis in Opposition.
Levine Valuation Analysis in Opposition.
Landmark West Statement In Opposition
Landmark West Summary of Flaws in Congregation's Submissions.
Jay Greer Re Classroom Needs
Susan Nial Re Neutral Zoning
Katherine Davis Re Acqusition Costs
June 19, 2008 Letter from Katherine Davis As to the Congregations
Misrepresentaton that up to 500 persons attend Sabbath services.
May 13, 2008 Documents Filed by CSI with BSA
Cover Letter dated May 13, 2008 from Friedman & Gotbaum to BSA.
May 13, 2008 CSI Revised Statement in Support - 65 pages.
Environmental Assessment date May 12, 2008 from ARKF (includes shadow studies).
Revised Feasibility Analysis of Freeman Frazier dated May 13, 2008.
Proposed New Building With Courtyard Plans of various dates - 17 pages of plans.
Revised Zoning Analysis Form.
As-of-Right-Zoning Envelope Section - Parsonage dated May 12, 2008.
April 15, 2008 - Hearing and Documents Filed at Hearing by Opposition
Transcript - April 15, 2008 Hearing
Exhibit KK -Freeman Frazier Submissions Compiled and Filed by ProtectWest70 - Sugarman
Marty Levine Letter
Jay Greer Letter with Charts and Tables - Opp. Ex. LL
Jim Mulford Letter
Jim Mulford Presentation
KL Davis Presentation
Craig Morrison Statement
Kate Wood Statement
Susan Nial Second Letter Brief
Ron Prince - 18 West 70- Statement
April 2, 2008 Documents filed By Congregation With BSA
March 25, 2007 documents filed by Opposition
Statement by Alan D. Sugarman
Opposition Exhibits
GG - Drawings Classroom Space and Access
HH - Re Beit Rabban IRS Form 990 and Rent
JJ - Re Classrooms, Toddler Program
Statement of Martin B. Levine Metropolitan Valuation Services (re Economic Feasibility)
Statement of Landmark West - Kate Wood
Attachment to LW Statements - Soft Sites CPW
Statement of Mark Lebow
Letter Brief of Susan Nial, Esq.
Statement of Craig Morrison
Grubb & Ellis Appraisal re 18 West
Letter of David Rosenberg re DOB and Jurisdiction
Statement of Jay Greer re Classrooms Programmatic Need
Statement of Jay Greer re Funding of Religious Organizations
March 11, 2008 Documents were filed by the Congregation
Cover Letter dated March 11, 2008 from Friedman Gotbaum.
Letter/Report from Feasibility Consultant Freeman Frazier.
Letter/Report from Planner Consultant AKRF.
Program Usage Chart
Modified Proposed Drawings - Re 18 West Windows
Zoning Maps
Lebow-Friedman Letters with Drawing Shown at BSA hearing.
February and March 2008 - Various Letters
Letter February 21, 2008 Mark Lebow to Shelly Friedman
Letter March 4, 2008 Shelly Friedman to Mark Lebow
Letter March 7, 2008 Alan Sugarman to CB7
February 22, 2008 [not obtained by opposition until April 21, 2008 FOIL Response.]
Letter from Feasability Consultant Freeman Frazier with Sliver Building Floor Area Schedules.
February 12, 2008 Second BSA Hearing
Transcript Second BSA Hearing February 12, 2008
February 12, 2008 . Opposition Filings at second BSA Hearing
Transcript - posted Feb. 25, 2008
Statement by Alan D. Sugarman
Report by Craig Morrison Opposition Architect
Report by Marty Levine Opposition Valuation Expert
Statement by Jay Greer
Statement by Bruce Simon
Statement by Kate Wood Landmark West
Statement by Assemblyman Thomas Duane
Statement by Architect Melvin White re 91 CPW
Floorplan of 91 CPW
Statement of Otis Pearsall
Statement of Elliot Sclar Re Contextual Zoning
18 West Window Analysis (to be provided)
February 4, 2008 - documents filed by the Congregation
February 4, 2008 Letter from Friedman & Gotbaum, attorneys for the Congregation, to the Board of Standards and Appeals, with Platt and Freeman attachments.
February 4, 2008 Friedman & Gotbaum - letter only.
February 4. 2008 Platt Letter
January 30, 2008 Freeman Letter
January 28, 2008 - Community Opponent Responses Filed With BSA
December 28, 2007 - Submission from Congregation Shearith Israel.
December 28, 2007 Cover Letter from Friedman & Gotbaum to BSA.
December 28, 2007 Response Letter from Friedman & Gotbaum to BSA (20 pages plus exhibits).
Exhibit A - Deeds.
Exhibit B - 1984 City Planning Commission Reports re Mid-Block Zoning.
Exhibit C - Fourth Revised Feasibility Analysis by Freeman Frazier.
Exhibit D - Programmatic Diagrams PR E-6-10 and PR P-6-11.
Exhibit E - Map re building in R10A/R8B.
AKRT Summary Explaining Why Shadow Study Not Submitted.
Revised Versions of Prior Drawings P-3,P-7,P-9, P-10.
LPC Transcripts (to be posted later).
December 4, 2007 - Community Board 7 Hearing
November 27, 2008 - First BSA Hearing
Transcript - November 27, 2008 BSA First Hearing- 81 pages.
Slides Presented by Alan D. Sugarman
Statement of Landmark West
Ron Prince
Jay Greer
October 27, 2007 - BSA Second Revised Application
October 12, 2007. BSA Second Set of Objections
October 12, 2007 - BSA Second Set of Objections
September 27, 2007 Oppositioin Submission
September 27, 2007 Lebow Letter to BSA enclosing Simon Letter.September 26, 2007 Simon Bertrang Memorandum as to Zoning Issues
September 19, 2007 Preliminary Opposition By Sugarman
September 19, 2007 Protect West 70th Street Preliminary Opposition Statement to BSA
September 19, 2007 Cover Letter for Preliminary Opposition from Alan D. Sugarman and ProtectWest70.org to BSA.
September 10, 2007 BSA Filing By Congregation
CSI Cover Letter
September 9, 2007 Rev. Statement In Support (35 pages).
Redline of Revised App. 9/20
Rev. Financial Report
Rev. Environmental Assessment
Rev. BSA Zoning Analysis
LPC COA (re-filing)
Updated DOB Objections
Land Use Zoning Policy Statement
Central Park Shadow Study
Drawings Existing
Drawings Proposed Scheme
Drawings-A-As-Of-Right
Drawings-B-As-Of-Right
Drawings-C-Res-As-Of-Right
SAVE TIME: DOWNLOAD All DOCS IN ONLY TWO FILES
All Drawings Sept. 2007 - 5MB
All Documents Sept. 2007 - 2MB
June 28, 2007 Memorandum from Planner Simon Betrang discussing BSA objections and Shearith Israel BSA Application.
June 28, 2007 Letter from Mark Lebow to Community Board 7 requesting postponement of meeting scheduled for July 18, 2007.
April 2, 2007 BSA Application by Congregation Shearith Israel
CSI Application to BSA - (120 pages - 4MB) with "Bates" numbers 000001 to 000120
Proposed Building Drawings P-1 to P-17
As of Right Building Drawings AOR-1 to AOR-15
Current Building Drawings EX-1 to EX-14
Radius Drawing ( 1 drawing, .5 mb)
The documents in the 120 page submission may be downloaded individually here:
CSI Application Cover Letter
1 DOB BZ Application Form
2 DOB Objection Sheet
3 April 2, 2007 CSI Statement in Support (30 pages).
4 Zoning Analysis
5 Zoning Maps
8 Existing Certificate of Occupancy
9 Affected Property Owners List
10 Environmental Assessment Application
10-1 Revised Attachment to Environmental Assessment (4-20-07)
10-2 Exhibit to 10-1 Shadow Studies for Park (4-20-07)
11 CSI Economic Analysis Report
12 Photographs
13 Deeds
14 Affidavit of Ownership
15 Tax Exempt Organization Certificate
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Versions of Congregation Statements in Support:
July 8, 2008 Statement in Support - 55 Pages.
May 13, 2008 CSI Revised Statement in Support - 65 pages.
December 28, 2007 Response Letter - not full Statement in Support - from Friedman & Gotbaum to BSA - 20 pages plus exhibits.
October 27, 2008 Statement in Support - 34 pages.
April 2, 2007 CSI Statement in Support - 30 pages.
Other Documents And Correspondence
May 7, 2008 FOIL Response from BSA concerning rules for Feasibility Studies
April 22, 2008 FOIL Request
April 21,2008 FOIL Response
April 14, 2008 Sugarman FOIL request to BSA
April 11, 2008 Sugarman FOIL Request to BSA
March 25, 2008 Lebow Letter to BSA
March 25, 2008 David Rosenberg Letter to BSA re DOB
March 11, 2008 Lebow to Friedman re Drawings
March 4, 2008 Letter Friedman to Lebow
February 21, 2008 Letter Lebow to Friedman
February 14, 2008 BSA Letter to Lebow Re 18 West Information
November 19, 2007 CB7 Land Use Committee Minutes and Resolution.
Letter Sugarman to BSA re Stix Letter to Gottfried and recusal.
Letter to Dick Gottfried re recusal from Margaret Stix, November 7, 2008.
October 31, 2007 Letter Lebow to BSA
October 31, 2007 Letter Friedman to Rosenberg
2007-10-30 Letter Rosenberg to BSA re DOB
October 29, 2007 Sugarman to bSA objecting to meeting
October 29, 2007 BSA Notice to CSI
September 27, 2007 Lebow Letter to BSA and CB7
September 26, 2007 Betrang Memo
September 19, 2007 Sugarman Preliminary Opposition to BSA
August 28, 2007 Lebow Letter to BSA
April 2, 2007 CIS Application to BSA with interpolated BSA and Community Objections - 44 pages.
June 18, 2007 letter from Sugarman to Sheldon Fine of Community Board 7 concerning the need to adjourn the Land Use Committee Hearing Scheduled for June 20, 2007 as a result of the BSA objection letter.
June 15, 2007 Letter of Objection from BSA to Congregation.
June 12, 2007 Letter from Alan Sugarman to Jack Freeman, Economic Consultant for Congregation With Formal Questions Concerning Report
June 12, 2007 Letter From Alan Sugarman to Sheldon Fine, Chair of Community Board 7, concerning upcoming meeting and incomplete package from the Congregation.
June 8, 2007 Letter from Sugarman to Public Advocate criticizing BSA Commissioners re improper ex parte meeting, as well as failing to respond in good faith to FOIL requests.
June 1 , 2007. FOIL response from BSA to Sugarman providing copies of documents to Sugarman, but failing to provide May 29, 2007 May 29, 2007 Letter from BSA to Public Advocate responding to Inquiry to BSA. This is an attempt to justify the improper ex parte meeting of November 8, 2006 between CSI and BSA Commissioners.
May 24, 2007 Letter BSA to Sugarman renewing FOIL request. FOIL request are in general not continuing requests and need to be renewed. This letter also focuses on the abusive use of attorney client privilege.
May 10, 2007 BSA Letter to Sugarman Refusing to Provide Documents and Denying Appeal.
May 1, 2007 Letter from Sugarman to BSA re further deficiencies in Congregation Application for Variance
April 26, 2007 Letter Sugarman to BSA re Abuse of FOIL
April 26, 2007 Letter from Sugarman to BSA re stale DOB Objections and deficiencies in BSA Application.
April 23, 2007 Letter Friedman & Gotbaum to BSA with supplemental information including shadow studies and recent LPC COA.
April 23, 2007 Letter Sugarman to BSA re lack of shadow studies and information re 18 West 70th Street.
April 19, 2007 Letter from BSA re recusal stating that will be considered at first hearing.
April 17, 2007 Letter from BSA to Sugarman with Additional FOIL responses.
April 17, 2007 DOB Foil Responses (sparse) April 10, 2007 New York Sun Article re LW FOIL case against DOB
April 10, 2007 Letter from DOB to Sugarman re FOIL records
April 10, 2007 Letter Sugarman to BSA requesting recusal of Commissioners
April 10, 2007 Complaint in Action by Landmark West against Department of Buildings Re Freedom of Information Law
April 5, 2007 Letter Sugarman to Friedman & Gotbaum re service of notice on CB7 on Passover
April 3, 2007. Update Certificate of Service Establishing that the BSA Application Was Served by Congregation Shearith Israel on the First Day of Passover.
March 21, 2007 Certificate of Appropriateness from LPC
March 16, 2007 Letter Sugarman to Friedman & Gotbaum re ex parte meetings and colluding with DOB to deny access to documents under the FOIL.
January 22, 2007 Letter from DOB to Sugarman denying access to FOIL Documents Unless Permission Letter Obtained from Congregation.
January 12, 2007 Letter from Friedman & Gotbaum again refusing to provide waiver letter to DOB and continuing to stonewall.
January 9, 2007 Letter from Alan Sugarman to Congregation Shearith Israel concerning CSI's refusal to allow access to DOB documents based on 9/11 security concerns.
January 3, 2007 Letter from CSI's Attorneys Friedman and Gotbaum refusing access to DOB documents.
January 2, 2007 Letter (second) from Alan Sugarman to Friedman and Gotbaum requesting access to DOB documents.
December 20, 2006 Letter (sometimes referred to as December 19 letter) from Alan Sugarman to Friedman and Gotbaum requesting access to DOB documents.
December 19, 2006 FOIL request from Alan D. Sugarman to DOB.
December 19, 2006 Second Letter from Alan D. Sugarman to BSA reiterating Foil Requests.
December 18, 2006 Letter from Alan D. Sugarman to BSA - appeal of BSA FOIL denial.
December 12, 2006 Appeal Letter from David Rosenberg, counsel for Landmark West to DOB with related attachments including Landmark West FOIL requests and responses of DOB on security grounds.
November 27, 2006 Letter from BSA again asserting attorney client privilege as to notes of ex parte meeting.
November 26, 2006 - Tom Wolfe New York Times Article.
November 20, 2006 Alan D. Sugarman Letter to BSA with further detailed clarification.
November 14, 2006 Letter from BSA enclosing DOB FOIL responses
Complete November 14, 2006 BSA FOIL package;
November 11, 2006 Sign-In Sheet Ex-Parte BSA Meeting.
November 8, 2006 E-mail Notice of BSA Ex-Parte Meeting Not Including Commissioners.
November 8, 2006 Letter from Friedman & Gotbaum to BSA enclosing copies of drawings.
October 13, 2006 Letter from Friedman & Gotbaum to BSA requesting meeting and listing Freedman as attendee.
September 1, 2006 FOIL request from Alan D. Sugarman to BSA.
September 1, 2006 Letter from Alan D. Sugarman to BSA re documents in electronic form.
April 11, 2006 LPC Response of April 11, 2006 to April 5, 2006 letter - re procedures and Certificate of Appropriateness not to be issued until final permit.
April 5, 2006 letter of complaint Sugarman to LPC |
Pre-April 2007 Comments:
Community groups remain in the dark, as both the BSA and DBA are stonewalling neighborhood and landmark groups. Both Landmark West and community members have filed Freedom of Information Law requests with DOB and BSA. BSA refuses to turn over notes of the ex parte BSA meeting on the specious ground of attorney client privilege.
DOB has refused to provide access on security concerns having decided to designated certain religious sites as "sensitive" and after 9/11 having decided to release information only if approved by the building owner - and - CSI has refuse to authorize release.. So, for now, material that will be completely public when CSI applies to the BSA and goes through the CB7 process, is now considered to pose security risks.
Tom Wolfe in a New York Times article "The (Naked) City and the Undead" launched a powerful missive criticizing the New York City development process and in particular LPC and its Chairman Robert Tierney. This provoked a flurry of letter to the editor by Tierney and friends defending LPC, Tierney and the process.
But the little game now being played by BSA, DOB, and CSI is illustrative of the City's practice to treat interested members of the public and groups as a nuisance, largely irrelevant to the back door decisions driven by powerful entities like CSI and its influential membership.
The game of withholding documents is standard operating procedure. Then, the Community Boards are pressured to finish meetings in a 60 day period, and the agencies conveniently forward proposals to the Community Board at times so as to conflict with the known pre-scheduled meetings Community Board and subcommittees. |
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