New York City

For example, on July 12, 2023, LEWIS-MARTIN pressured the Deputy Mayor to leave a meeting with Mayor Adams – regarding hate crimes in New York City – to attend a meeting with LANDAU and HPD about the Red Hook Project. At approximately 11:32 AM, LEWIS- MARTIN texted the Deputy Mayor stating, “I know the mayor is major priority, but if you could skip out for second. They had been bugging the stuffings out of me.” Two minutes later, at approximately 11:34 AM, LEWIS-MARTIN sent a Signal message to MARTIN II and LANDAU stating, “Good morning: [the Deputy Mayor] is in a meeting with the mayor about hate crimes. She had [the Deputy Mayor’s Chief of Staff], her number one (1) join the call. I promise you that your project is priority. I need more.” At approximately 11:42 AM, LANDAU sent a Signal message to LEWIS-MARTIN and MARTIN II informing them that HPD “was giving push back and saying [the Red Hook Project] won’t close in December [2023].” At approximately 1:38 PM, MARTIN II replied, “Fuck him we make it close,” and at approximately 4:09 PM, LEWIS-MARTIN responded, “Ok. I agree with Glennie.” Within the same minute, LEWIS-MARTIN sent a text message to the Deputy Mayor stating, “Please give me a call when you have a chance.”

LEWIS-MARTIN exerted similar pressure on the HPD Commissioner. For example, on July 28, 2023, from approximately 9:53 AM to approximately 12:13 PM, LEWIS-MARTIN sent multiple text messages to the HPD Commissioner directing him, in sum and substance, to “text me what is missing from the project that we discussed. I need to have a conversation with them,” and stating that she was awaiting the HPD Commissioner’s response. Later that afternoon, LEWIS-MARTIN called LANDAU using Signal. The next day, on July 29, 2023, LEWIS-MARTIN sent two follow-up text messages to the HPD Commissioner stating, “I have dates when all of the above was originally sent. More like months but [sic] weeks. We need to get it done,” and then adding, “December,” referring to LANDAU’s desired closing date for the Red Hook Project.

In or about February 2024, HPD completed its background review of the project’s ownership structure and site acquisition allowing it into HPD’s “pipeline,” a list of projects slated to close. At any given time, hundreds of projects are in the pipeline, but only a few are able to close each calendar year. As a result, many projects wait multiple years before closing. But LANDAU would not wait his turn and LEWIS-MARTIN continued to push.

LEWIS-MARTIN went so far as to engage directly with LANDAU’s representatives on the Red Hook Project by attending private meetings and phone calls without HPD or other City Hall officials present. For example, on April 10, 2024, at approximately 10:36 AM, LEWIS-MARTIN had a three-way conversation with LANDAU and his private consultant on the Red Hook Project. She stated, “We’re gonna, we gotta get that place [HPD] under control, so when we fucking tell them something, we expect them to make that shit move… I’m gonna speak to the Mayor, and then that’s it, so we’re just gonna push for December [2024] and we’re gonna keep it going.” The next day, on April 11, 2024, LEWIS-MARTIN confirmed a meeting with LANDAU and an attorney representing the Red Hook Project. HPD was not a party to these calls or meetings.

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