PLEASE TAKE NOTICE, that upon the annexed affirmation of Joseph M. Charchalis, Esq. dated March 30, 2022, and the exhibits attached thereto and upon all the prior pleadings and proceedings had herein, the defendant(s) will move this Court, at an Support Part Room 217, at the Courthouse located at 851 Grand Concourse, Bronx, New York, on the 2nd day of May, 2022 at 9:30 a.m. or as soon thereafter as counsel can be heard, for an Order consolidating the above- captioned actions for the purpose of a joint trial, and for such other and further relief as this Court may deem just and proper.

§ 2214(b), answering papers are required to be served at least seven (7) days prior to the return date of this motion.

and CRISTOPHER A. BOYKE 1377 Motor Parkway, Suite 400 Islandia, New York 11749 631.755.0101 By: ________________________________

SUBIN ASSOCIATES, LLP Attorneys for Plaintiffs in Action 1

Attorneys For Co-Defendant TIFFANY ADESIYAN in Action 4 875 Merrick Avenue Westbury, NY 11590 516.229.4497

was an owner of certain real property, together with the York referred to improvements thereon, located at 248 Flushing Avenue, Brooklyn,New (hereinafter as the "PREMISES").

directed the construction, demolition, excavation, erection, repairing, altering, painting, cleaning, and/or pointing labor and/or services upon the aforesaid

controlled the construction, demolition, excavation, erection, repairing, altering, painting, cleaning, and/or pointing labor and/or services upon the aforesaid

directed the construction, demolition, excavation, erection, repairing, altering, painting, cleaning, and/or pointing labor and/or services upon the aforesaid

and/or to perform construction, demolition, excavation, erection, repairing, altering, painting, cleaning, and/or poiñtiñg labor and/or services upon the aforesaid

That none of the exemptions set forth in CPLR Article 16 are applicable to this and even if one where applicable, the answering defendant's liability is limited pursuant matter, thereto.

LLC was a foreign Limited Liability Company duly authorized in the State of New York, and deny knowledge or information sufficient to form a belief as to the truth of the remainder of the allegation as designated in paragraph "2" of plaintiffs Verified Complaint, and

deny knowledge & or information sufficient to form a belief as to the truth of each and every allegation contained in the Complaint designated as "3," "5," "7," "9," "10," 1," "12," "14," "1 paragraphs of plaintiffs Verified "15," "16," "17," "18," "19," "21," "22," "23," "24," "25," "26," "28," "29," "30," "31," "32," "33," "34," "35," "36," "37," "38," "39," "40," "41," "42," "43," "44," "45," "46," "47," "48," "49," "50," "51," "52," "53," "54," "55," "56," "57," "58," "59," "60," "61," "62," "63," "64," "65," "66," "67," "76," "77," "78," "80," "81" "82," "68," "69," "70," "71," "72," "73," "74," "75," "79", and and refer all questions of law, fact or conclusions raised therein to the trial court for respectfully determination.

was a foreign Limited Liability Cosupany duly authorized in the State of New York, and deny knowicdge or information sufficient to form a belief as to the truth of the remainder of the allegation as designated in paragraph "4" of paintiff's Verified Complaint, and respectfully refer all questions of law, fact or cen±cicme raised therein to the trial court for determination.

10/12/2017 of the remainder of the allegation as designated in paragraph "6" of plaintiffs Verified Complaint, and respectfully refer all questions of law, fact or conclusions raised therein to the trial court for determination.

STREET OWNER LLC owned the real property located at 248 Flushing Avenue, Brooklyn, New York, and deny knowledge or information sufficient to form a belief as to the truth of the r nder of the allegation as designated in paragraph "13" of plaintiffs Verified Complaiñt, of or conclusions trial and respectfully refer all questions law, fact raised therein to the court for determination.