SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ULSTER ‘ConnectOne Bank, as successor-in-interest to Greater | Hudson Bank, Index No.: [- 530 | Plaintiff, vs. COMPLAINT TechCity 42 & 43 LLC, TechCity 52 LLC, TechCity 33, 51 & 64 LLC, CERES Technologies Inc., Anaerobic Athletics LLC, Brooklyn Brew Shop, Innate Movement Parkour, LLC, JSP Plumbing and Heating Inc., C&A | Custom Builders, Inc., Consolidated Harvest Company, LLC dba Hudson Valley Harvest, Visual Color Systems, | inc., Synergy Merchant Services, LLC, AG Properties of FIL Kingston LLC, oe on JOHN DOE No. 1" through "JOHN DOE No. 10" | “D 15 2019 inclusive, the names of the last 10 defendants being | fictitious, the true names of said defendants being ula costupack, unknown to Plaintiff, it being intended to designate fee owners, tenants or ogcupants of the mortgaged premises J slor persons or partis having or claiming an interest in or a lien upon the mortgaged premises described in the | complaint herein, | Lo Defendants. _ Plaintiff ConnectOne Bank, as successor-in-interest to Greater Hudson Bank (“ConnectOne” or “Plaintiff”) alleges by and through its attorneys, Bronster, LLP, by way of its ‘Complaint against the defendants as follows: NATURE OF THE ACTION 1 This is an action to foreclose on a mortgage encumbering real property located at Section: 48.7, Block: 1, Lot: 29.210, Section: 48.7, Block: 1, Lot: 29.290, and Section: 48.7, Block: 1, Lot: 29.230 on the Tax Map of the Town of Ulster, County of Ulster, State of New York, more commonly known as 1600-1678 Enterprise Drive, Kingston, New York (“Building (uistossi:1)43"), 90-98 Boices Lane, Kingston, New York (“Building 42”) and 1700-1798 Enterprise Drive, Kingston New York (“Building 52) (collectively the “Mortgage Properties”). This action also seeks to foreclosure a mortgage encumbering real property located at Section: 48.7, Block: 1, Lot: 29.180, Section: 48.7, Block: 1, Lot: 29.190, and Section: 48.7, Block: 1, Lot: 29.220 on the Tax Map of the Town of Ulster, County of Ulster, State of New York, more commonly known as 70-78 Boices Lane, Kingston, New York (“Building 51”), 80-88 Boices Lane, Kingston, New York (“Building 33”), and 1680-1698 Enterprise Drive (wk/a 1650 Enterprise Drive), Kingston New York (“Building 64”) (collectively the “Collateral Properties”). This action also seeks to foreclose a mortgage encumbering Building 64. The parcels are more particularly described and identified by the legal metes and bounds description of the land included and improvements thereon described in Schedule A annexed hereto and made a part hereof (the “Mortgaged Properties”). This action also seeks to foreclose on a mortgage encumbering the Mortgage Properties that is junior to the three mortgages described previously. PARTIES TO THE ACTION 2. Plaintiff ConnectOne Bank, as successor-in-interest to Greater Hudson Bank, is a New Jersey commercial bank which maintains its principal place of business at 301 Sylvan Ave, Englewood Cliffs, NJ 07632 3. Plaintiff is the owner of the Amended Note, Mortgage, AG Mortgage, Collateral Mortgage, Credit Line Note and Credit Line Mortgage (defined below). 4. Defendant TechCity 42 & 43 LLC is a New York domestic limited liability company, having an address of 300 Enterprise Drive, Kingston, New York 12401, and is the owner of Building 42 and Building 43 and an original obligor on the loan. 5. Defendant TechCity 52 LLC is a New York domestic limited liability company,having an address of 300 Enterprise Drive, Kingston, New York 12401, and is the owner of Building 52 and an original obligor on the loan. 6. Defendant TechCity 33, 51 & 64 LLC is a New York domestic limited liability company, having an address of 300 Enterprise Drive, Kingston, New York 12401, and is the ‘owner of the Collateral Mortgage Properties. 7. Defendant AG Properties of Kingston, LLC is a New York domestic limited liability company, having an address of 300 Enterprise Drive, Kingston, New York 12401 and is the former owner of Building 64, 8. CERES Technologies Inc. is named as a defendant due to a written lease of space in Building 42 and Building 64. 9. Anaerobic Athletics LLC is named as a defendant due to a written lease of space in Building 33. 10. Brooklyn Brew Shop is named as a defendant due to a written lease of space in Building 33. 11, Innate Movement Parkour, LLC is named as a defendant due to a written lease of space in Building 33. 12, JSP Plumbing and Heating Inc. is named as a defendant due to a written lease of space in Building 33. 13, C&A Custom Builders, Inc. is named as a defendant due to a written lease of space in Building 51. 14. Consolidated Harvest Company, LLC dba Hudson Valley Harvest is named as a defendant due to a written lease of space in Building 51 and Building 64. 15. Visual Color Systems, Inc. is named as a defendant due to a written lease of space