RE: Apartment 2O, 225 Parkside Avenue, Brooklyn, NY 11226 โ Tenancy of 44+ Years
Dear Nieuw Amsterdam Property Management,
I am writing as Power of Attorney for my mother, Walterine Noel, the lease holder of Apartment 2O at 225 Parkside Avenue, Brooklyn, NY 11226, and as a tenant of the apartment. My mother and I have resided in this apartment together for over 44 years. All future communications regarding this tenancy must be directed to me, Michael Alfred, at
[email protected]. This notice is being copied to Dara Yaskil and Courtney Horwitz at Strada Ventures LLC in their capacities as management liaisons, to Stephanie Knight at Summit as liaison for the building owners, and to the additional parties identified in the CC block below.
This letter constitutes written notice under the New York City Housing Maintenance Code, the New York State Multiple Dwelling Law ยง 78, the Fair Housing Act (42 U.S.C. ยง 3604), the Americans with Disabilities Act, and the NYC Rent Stabilization Law (Admin. Code ยง 26-511 et seq.).
I. CONTACT HISTORY & FAILURE TO RESPOND
March 30โ31, 2026 โ Substandard Contractor Work. Contractor Orgist (646-529-3652) entered the unit and performed painting and plastering work that does not meet habitability or workmanship standards โ flat paint applied directly over existing surfaces without scraping, proper surface preparation, or crack repair; cracks remain visible beneath the paint, and no prep work was completed. That contractor has not returned. His crew's materials โ ladders, paint buckets, roller equipment, and paper floor coverings โ have remained inside the unit since late March 2026 and have not been removed, constituting active trip hazards for my mother, age 85, who ambulates with a walker, and for me as a wheelchair user.
On or about April 13, 2026 โ First Contact with New Management. Contacted your office to report outstanding repair conditions and request completion of previously committed work. Your office had no record of any work orders for this unit, despite HPD inspection findings dating to December 2025.
April 20, 2026 โ Second Contact / Work Orders Issued. Spoke directly with Leo at your office regarding the same outstanding repairs and was given no remediation timeline. On this date, Leo also confirmed in writing that rent checks should be made payable to FLGSP225PARKSIDEAVELLC.
April 20, 2026 โ Written Commitment Re: Elevator. Received written communication from your office stating that elevator service would be restored by April 21, 2026.
April 22, 2026 โ Elevator Failure / DOB Complaint Filed. Elevator service was not restored as promised. At 9:35 AM, filed DOB Service Request SR# 311-27229207 (Type: Elevator โ Not Working, 225 Parkside Avenue, Brooklyn, NY 11226).
April 23, 2026 โ Emergency / NYPD Intervention. When I arrived at the building, the elevator remained inoperative. I was forced to call 911. At approximately 1:00 PM, NYPD officers physically lifted me into the building. The elevator was not restored until later that day, only after I filed an additional HPD complaint. As a wheelchair user, the inoperative elevator rendered me completely unable to access the apartment that my mother and I have shared for over 44 years, from Thursday, April 17 through April 23, 2026 โ six consecutive days. My mother, age 85, was left without caregiver assistance for this entire period. My personal caregiver was likewise unable to access the premises to attend to my needs.
April 24, 2026 โ Repair Appointment Scheduled. Contacted your office and was given an appointment; informed workers would arrive Monday, April 27, 2026 to begin repairs.
April 27, 2026 โ No-Show / Assessment by Manhattan Innovators. Canceled all personal appointments to be present. No workers arrived. When I called your office at approximately 11:30 AM, I was told no appointment had been scheduled for me; I stated a representative was required to visit the unit that day or I would immediately file additional HPD and 311 complaints. At 12:19 PM, Vinny Mrkulic of Manhattan Innovators (914-309-3175, 310 West 49th Street, New York, NY) arrived and conducted an assessment โ without a uniform, contractor identification, or visible company credentials. Formally requesting a copy of Manhattan Innovators' contractor license.
Per Mr. Mrkulic's assessment, the scope of required work includes: full apartment remediation; floor replacement throughout the apartment (front bedroom, main hallway, kitchen, and bathroom tile); replacement of bathroom sink cabinet and medicine cabinet; replacement of all broken windows and broken glass panes, including the window with a bullet hole; repair of the fire escape window to ensure full, functional operation; proper repair of all sagging and leaking ceilings; all radiator pipe areas to be rectified; and widening of the bathroom door for ADA compliance.
Additionally, advised Mr. Mrkulic that within 60 to 90 days I will be transitioning to a power wheelchair. Formally reiterating here: a ramp at the lobby entrance will be required, or management must provide personnel to assist me up the four steps at the building entrance each time I enter and exit.
Formally requesting, in writing, a complete project timeline identifying which licensed workers will perform which portions of the scope of work and by what dates. All work will be video recorded for documentation of quality and completeness. A final walkthrough will be conducted against the NYC DCA Home Improvement Inspection Checklist.
II. NOTICE OF HPD VIOLATIONS ON RECORD โ APT 2O โ ALL OPEN AND UNCORRECTED
HPD inspections conducted December 19โ20, 2025 resulted in 31 violations formally issued against Apartment 2O. As of the date of this letter, all 31 remain open and uncertified as corrected. The elevator violation is the sole item that has been addressed. All other violations remain outstanding and unresolved. Effective immediately, HPD and 311 complaints will be filed on a bi-weekly basis for each unresolved violation until every item is certified as corrected.
CLASS C โ IMMEDIATELY HAZARDOUS (legally required correction within 24 hours; all four deadlines passed, none corrected):
ยท #18529324 (Order #510, issued 12/24/2025) โ Inoperable lower window sash (shut closed) at fire escape window, 5th room from east. Due 12/30/2025. 119+ DAYS PAST DUE.
ยท #18518251 (Order #568, issued 12/23/2025) โ Active roach infestation, entire apartment. Due 01/18/2026. 99+ DAYS PAST DUE.
ยท #18518250 (Order #569, issued 12/23/2025) โ Active mice infestation, entire apartment. Due 01/18/2026. 99+ DAYS PAST DUE.
ยท #18518248 (Order #501, issued 12/23/2025) โ Broken/defective glass pane at lower sash, 5th room from north. Due 12/29/2025. 120+ DAYS PAST DUE.
CLASS B โ HAZARDOUS (legally required correction within 30 days; all deadlines passed, none corrected):
ยท #18529330 โ Water leak at ceiling, 1st room from east. Due 01/28/2026.
ยท #18529329 โ Broken/defective plastered surfaces and paint, ceiling and north wall, 1st room from east. Due 01/28/2026.
ยท #18529328 โ Broken/defective counterbalance at lower sash, window, 1st room from east. Due 01/28/2026.
ยท #18529327 โ Water leak at ceiling, 2nd room from east. Due 01/28/2026.
ยท #18529326 โ Broken/defective plastered surfaces and paint, ceiling, 2nd room from east. Due 01/28/2026.
ยท #18529323 โ Broken/defective plastered surfaces and paint, ceiling and east wall, 6th room from east. Due 01/28/2026.
ยท #18529322 โ Broken/defective plastered surfaces and paint, ceiling and east wall, bathroom. Due 01/27/2026.
ยท #18529321 โ Water leak at ceiling, bathroom. Due 01/27/2026.
ยท #18529320 โ Leaky/defective faucets at wash basin, bathroom. Due 01/27/2026.
ยท #18529319 โ Broken/defective plastered surfaces and paint, ceiling, private hallway. Due 01/27/2026.
ยท #18529318 โ Broken/defective plastered surfaces and paint, south and north walls, foyer. Due 01/27/2026.
ยท #18518253 โ Smoke detecting device absent/non-operational, entire apartment. Due 01/27/2026.
ยท #18518252 โ Carbon monoxide detecting device defective, entire apartment. Due 01/27/2026.
ยท #18518245 โ Water leak at ceiling, 1st room from north at east. Due 01/27/2026.
ยท #18518244 โ Broken/defective plastered surfaces and paint, ceiling, south and east walls, 1st room from north at east. Due 01/27/2026.
ยท #18518241 โ Water leak at ceiling, 1st private hallway from north. Due 01/27/2026.
ยท #18518240 โ Broken/defective plastered surfaces and paint, ceiling, 1st private hallway from north. Due 01/27/2026.
ยท #18518238 โ Broken/defective plastered surfaces and paint, ceiling, 4th room from north. Due 01/27/2026.
ยท #18518237 โ Broken/defective plastered surfaces and paint, east and west walls, 2nd private hallway from north. Due 01/27/2026.
ยท #18518247 โ Broken/defective counterbalance at lower sash, 5th room from north. Due 01/27/2026.
ยท #18518243 โ Leaky/defective faucets at wash basin, bathroom. Due 01/27/2026.
ยท #18518236 โ Broken/defective plastered surfaces and paint, ceiling, bathroom. Due 01/27/2026.
CLASS A โ NON-HAZARDOUS:
ยท #18529325 โ Paint heat riser per dept. regulation, 2nd room from east. Due 03/29/2026.
ยท #18518246 โ Repair broken/defective wood floor by riser pipe, 1st room from north at east. Due 03/28/2026.
ยท #18518242 โ Paint riser pipe per dept. regulation, bathroom. Due 03/28/2026.
ยท #18518239 โ Paint riser pipe per dept. regulation, 4th room from north. Due 03/28/2026.
ยท #18518249 โ Repair broken/defective wood floor by riser pipe, 5th room from north. Due 03/28/2026.
All 31 violations carry a status of NOV SENT or NOI SENT with no certification of correction on record.
III. OPEN HPD COMPLAINTS ON RECORD โ APT 2O
Open complaints filed April 22, 2026 (SR# 311-27229354, Complaint #14686528, unless noted): bulging wall, entrance; broken/defective basin/sink, bathroom; broken/missing bathroom door; broken/missing kitchen floor tile; and broken/missing window frame lock, entire apartment (SR# 311-27229237, Complaint #14686483).
City-confirmed conditions from December 19, 2025 (inspected by HPD, violations issued, complaints now administratively closed โ none remediated): collapsing ceiling, private hallway (SR# 311-25644378); broken/defective basin/sink, bathroom (SR# 311-25644195); collapsing ceiling, bathroom (SR# 311-25644167).
IMMEDIATE HAZARD โ Construction Materials on Premises: ladders, paint buckets, roller equipment, and paper floor coverings have remained inside the unit since late March 2026, constituting active trip hazards under NYC HMC ยง 27-2005, posing direct and ongoing risk to an 85-year-old resident using a walker and to a wheelchair user. Removal is required within 48 hours of receipt of this notice, unless work is being scheduled immediately and a written timeline is provided.
IV. ADDITIONAL OUTSTANDING WORK โ NOT YET ON VIOLATION RECORD
Committed by prior management and remaining incomplete, documented in prior written/verbal communications and to be raised in any HP proceeding: bathroom sink, sink cabinet, and medicine cabinet/mirror (promised for replacement, never completed); ADA-compliant grab bars required in bathtub/shower area (NYC Building Code ยง 1109 / 29 C.F.R. ยง 1630); ADA-compliant adjustable shower arm required; all windows require full replacement per December 2025 HPD inspection findings; wall surfaces painted over without scraping or proper surface preparation (apartment must be restored to its prior finish standard โ semi-gloss/gloss paint throughout โ with proper surface preparation completed before any repainting); and retiling of the bathroom required.
IV-A. DOCUMENTED REPAIR HISTORY โ BATHTUB, SINK & BATHROOM (OCTOBERโNOVEMBER 2025)
The bathroom conditions referenced above โ the defective bathtub, leaking sink, and deteriorated cabinetry โ were previously reported and acknowledged by building staff in October 2025. Timeline based on contemporaneous written communications with the building superintendent, retained on file: October 25, 2025 โ request submitted for urgent bathtub replacement due to inability to safely bathe. October 26โ29, 2025 โ multiple follow-ups required; repeated assurances a plumber would contact us; no timely outreach occurred. October 28โ29, 2025 โ management explicitly notified the apartment contains an 85-year-old resident and a disabled occupant, and that the condition constituted a hygiene and health concern requiring urgent resolution. October 29, 2025 โ after escalation and formal notice of potential state-level action, a service appointment was finally scheduled. October 30, 2025 โ bathtub work commenced; however, significant debris beneath the tub was left in place, workers were unable to communicate effectively due to a language barrier, and additional defects were identified including a rotted and leaking bathroom sink and deteriorated cabinet requiring full replacement. Post-installation โ work was left incomplete, with tile work deferred and temporary materials installed. November 4, 2025 โ follow-up request made for completion of bathroom work and replacement of sink and cabinet. November 5, 2025 โ management acknowledged the delay and deferred completion to the following week; no confirmation of completion was ever provided.
This documented history establishes that management had actual notice of defective bathroom conditions for over six months, including plumbing failures and structural deterioration, and failed to fully remediate those conditions. The currently open HPD violations relating to the bathroom are directly connected to these previously reported and acknowledged conditions. Video documentation of bathroom conditions following the October 2025 work is retained and will be submitted as evidence in any HP proceeding.
V. FORMAL REASONABLE ACCOMMODATION REQUEST โ FAIR HOUSING ACT & ADA
A person with a qualifying mobility disability currently using a manual wheelchair, in the process of transitioning to a power wheelchair โ a letter from the treating physician confirming this transition will be provided. The building entrance at 225 Parkside Avenue presents four steps with no accessible route. This request is made exclusively under the Fair Housing Act, the applicable federal law governing accessibility modifications in residential apartment buildings โ ADA Title II and Title III do not generally apply to the lobbies and common areas of private residential buildings; the Fair Housing Act provides the correct and enforceable legal framework here. Pursuant to the Fair Housing Act (42 U.S.C. ยง 3604(f)(3)(B)) and the NYC Human Rights Law (Admin. Code ยง 8-107(5)(a)), formally requesting: installation of an ADA-compliant accessible ramp or equivalent accessible route at the primary building entrance, sufficient to provide unassisted independent access for a Class II power wheelchair.
HUD guidance requires landlords to engage in a timely, good-faith interactive process upon receipt of a reasonable modification request. While a landlord may deny a modification request on grounds of undue financial burden, that denial must be made in writing, in good faith, and with supporting documentation of the claimed burden โ a blanket denial without good-faith engagement is itself a Fair Housing Act violation. Prepared to engage in the interactive process and, if necessary, to pursue this matter with HUD FHEO, NYSDHR, and NYCCHR if good-faith engagement does not occur. The elevator's repeated failures additionally constitute an independent ongoing Fair Housing Act violation under 42 U.S.C. ยง 3604(f)(2); DOB Service Request SR# 311-27229207, filed April 22, 2026, is on record. If no written response is received within ten (10) business days, complaints will be filed with HUD FHEO, NYSDHR, and NYCCHR.
VI. RENT โ NOTICE OF TENDER READINESS & RENT STABILIZATION
Nieuw Amsterdam Property Management assumed management of this building on April 7, 2026. As of the date of this letter, no verified rent payment address, no functioning online portal access, and no written payment instructions have been formally provided to this unit โ the only payment guidance received was Leo's verbal confirmation on April 20, 2026 that checks should be made payable to FLGSP225PARKSIDEAVELLC. Under New York law, a landlord's failure to provide a proper means of rent tender may affect the legal standing of any nonpayment proceeding. On April 27, 2026, following completion of the apartment assessment, certified bank checks for April and May 2026 rent were obtained, made payable to FLGSP225PARKSIDEAVELLC โ held in reserve, with copies retained; rent will be tendered upon completion of the required repairs.
Under New York Real Property Law ยง 235-b (Warranty of Habitability), this apartment has been and continues to be in a condition that is not safe, habitable, or fit for the use intended. Accordingly, a rent abatement claim will be pursued โ a court-ordered reduction or refund of rent proportional to the period during which the apartment was uninhabitable โ covering all months during which the violations cited in this letter were open and uncertified, to be asserted in any Housing Court proceeding. Rent owed will not simply be withheld; rather, any court proceeding will be used to establish the abatement amount owed to this tenancy retroactively.
This building is registered as historically rent regulated with HCR, and this tenancy is subject to the full protections of the NYC Rent Stabilization Law (Admin. Code ยง 26-511 et seq.). Rent stabilization does not, by itself, prevent a nonpayment proceeding if rent is not tendered โ for this reason, rent owed is being handled through the abatement route described above, not through unilateral withholding, which is the legally proper mechanism for a rent-stabilized tenancy. Any retaliatory action, harassment, failure to renew the lease, or attempt to destabilize this tenancy in response to this notice will be reported to DHCR and the NYC Office of Tenant Protection as a violation of the Rent Stabilization Law and NYC Admin. Code ยง 26-511 et seq.
The lease is currently held in my mother's name. Despite prior requests to predecessor management, I have not been formally added to the lease as an authorized tenant; Power of Attorney documentation is enclosed. Formally requesting to be added to the lease as an authorized tenant, and that succession rights and right to remain be formally acknowledged in writing.
VII. DEMANDS, DEADLINES & REMEDIES
Within 24 hours: written remediation plan for all four Class C violations, all 99โ120+ days past their legally mandated correction deadlines.
Within 48 hours: physical removal of all contractor equipment and materials from the unit, unless work is being scheduled immediately, in which case a written scope and timeline must be provided in lieu of removal; a written work plan identifying the full names of all workers entering the premises, which specific portions of the scope of work each will perform, and specific start/completion dates for each portion of the project; and a copy of Manhattan Innovators' contractor license. All work performed will be video and photographically documented for quality and completeness, consistent with tenant rights.
Within 10 business days: (1) remediation schedule with specific completion dates for all 31 violations and all open complaints; (2) written response to the reasonable accommodation/modification request in Section V; (3) written rent payment instructions sufficient to allow immediate tender; (4) written acknowledgment that Power of Attorney is on file, and initiation of lease amendment to add Michael Alfred as an authorized tenant with full succession and residency rights. Also respectfully requesting that Dara Yaskil and Courtney Horwitz at Strada Ventures LLC, understood to be responsible for overseeing the tenant transition and succession process, contact me within 72 hours to confirm their role and next steps in that process.
By May 31, 2026: full remediation of all conditions cited in Sections II, III, and IV, completed to code and to professional finish standards โ all work to be performed as if preparing the unit for a new tenancy, to the same quality standard this apartment has maintained for over 44 years.
VIII. NOTICE OF BI-WEEKLY COMPLAINT FILING
Effective immediately, complaints will be filed with HPD and 311 on a bi-weekly basis for each unresolved violation until all items are certified as corrected. This constitutes advance notice of continuing lawful enforcement action.
IX. AGENCIES WHERE FORMAL COMPLAINTS WILL BE FILED (ONGOING & ESCALATING)
In addition to HPD and 311 complaints already filed and continuing bi-weekly, this matter will be escalated as applicable to: City housing enforcement (HPD Emergency Housing/Code Enforcement; NYC 311; DOB for elevator/structural/safety violations; NYC Housing Court for an HP Proceeding/Action to Compel Repairs); State agencies (DHCR for rent stabilization violations, harassment, and failure to maintain services; NYSDHR for disability discrimination and failure to accommodate); Federal agencies (HUD FHEO for Fair Housing Act violations and disability accommodation failures); City human rights enforcement (NYC Commission on Human Rights); additional oversight (NYC Comptroller; NY State Attorney General for tenant protection/harassment/systemic violations; the Mayor's Office for tenant protection escalation; the local NYC Council Member for district tenant advocacy escalation); and tenant/legal support if needed (Legal Aid Society Housing Unit; Legal Services NYC; Brooklyn tenant legal assistance organizations). All filings will be documented and timestamped as part of a continuing enforcement record until full compliance is achieved.
FAILURE TO COMPLY โ NOTICE OF INTENDED LEGAL ACTIONS
Failure to meet the deadlines above will result in the following actions without further notice: initiation of an HP Proceeding in NYC Housing Court to compel repairs; assertion of rent withholding in escrow pursuant to RPL ยง 235-b; Fair Housing Act complaints filed with HUD FHEO, NYSDHR, and NYCCHR; a complaint filed with DHCR and the NYC Office of Tenant Protection regarding rent stabilization violations; formal AEP enrollment advocacy submitted to HPD Division of Code Enforcement; and referral to legal counsel for compensatory and punitive damages under 42 U.S.C. ยง 3613 and the NYC Human Rights Law.
This letter is being transmitted with delivery confirmation and read receipt enabled and is retained as part of a formal, timestamped documentation record.