Plaintiff INK 954, LLC, by its attorneys Law Office of Stacie Bryce Feldman as and for its Verified Complaint alleges as follows:

The Plaintiff, INK 954, LLC (“Plaintiff”) is a limited liability corporation authorized to do business in the State of New York.

Upon information and belief, and pursuant to the guaranty to the Lease, Defendant, STEVEN MANN (alternatively “Defendant” or Guarantor), is an individual and resident of New York State, Bronx County.

Defendant is the guarantor to a certain residential lease agreement dated August 16, 2016 (“Lease”) made between Plaintiff as landlord, and Justin David Mann (hereinafter “Tenant Mann”), Joshua Christensen, and Matthew Carter, as tenants (“Tenants”) for Apartment 2R (the “Apartment”) in the building.

WHEREFORE, Plaintiff demands judgment against Defendant on the First Cause of Action a money judgment in the amount of $44,250.00 for rent, additional rent and/or use and occupancy owed through and including November 2023, and such other sums that come due from December 1, 2023, for rent, additional rent and/or use and occupancy or otherwise under the terms of the Lease for so long as Tenant Mann, or any other tenant or occupant, remains in possession of the Apartment; on the Second Cause of Action a money judgment in the amount to be determined by the Court but not less than $15,000.00 for reasonable attorney’s fees; together with interest on all amounts due, plus the costs and disbursements of the action; and such other further relief at this Court may deem just, proper and equitable.