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150328/2018
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 04/01/2019

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
---------------------------------------------------------------------- X
ALICE BAHAR, :
: Index No. 150328/2018
Plaintiff, :
:
-against- : AMENDED VERIFIED
: COMPLAINT
ABRAHAM SANIEOFF; SANI GROUP a/k/a 25 :
GROVE STREET LLC; CHARLET SANIEOFF; ELIZA :
SABETFARD; LEOR SABETFARD; and MATTHEW
:
SABETFARD,
Defendants. :
:
---------------------------------------------------------------------- X

Plaintiff, ALICE BAHAR, individually through her attorneys, NEIL L. POSTRYGACZ,

ATTORNEY AT LAW, P.C., complaining of Defendants, ABRAHAM SANIEOFF, SANI

GROUP a/k/a 25 GROVE STREET LLC, CHARLET SANIEOFF, ELIZA SABETFARD, LEOR

SABETFARD, and MATTHEW SABETFARD, alleges as follows:

INTRODUCTION

1. While all humans are fallible, this action arises out of the intentional, premeditated,

and well planned predatory scheme of Defendant, ABRAHAM SANIEOFF, personally and on

behalf of SANI GROUP a/k/a 25 GROVE STREET LLC—whose negligence permitted the

actions complained of to happen—to use his power, wealth, influence, and connections to focus

on and orchestrate his plan to lure Plaintiff, a single 37-year-old hard-working real estate agent to

ostensibly be an onsite agent at 25 Grove Street, New York, New York (“25 Grove”), while his

undisclosed, real, and ulterior motive was to engage in a personal, hopefully “romantic” and

eventual intimate relationship with her, as detailed hereafter.

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2. Worse, immediately after the exposure of Sanieoff’s infidelity, improper and

inappropriate sexual behavior and exploitation, he personally terminated Plaintiff’s employment,

and Sanieoff’s family, including his wife, wife’s mother, and wife’s brothers, and as admitted,

New York City police and a “Black, six-foot-four” person that weighs “319 pounds” engaged in a

systematic, well planned, illegal, and vindictive conspiracy to threaten and intimidate Plaintiff.

3. Threats were made of disfiguring Ms. Bahar, breaking her legs, and causing severe

bodily harm while going to extraordinary levels to damage her reputation, destroy her career, and

essentially destroy her life with the intent and purpose of causing her irreparable physical and

emotional injury and economic loss, and as she was warned by Defendant ELIZA SABETFARD

(“ELIZA”), Sanieoff’s mother-in-law, in a voicemail dated February 17, 2017: “You don’t know

how powerful I am.”

4. These actions constitute causes of action for intentional infliction of emotional

distress, negligent infliction of emotional distress, illegal and prima facie tort, sexual Deleted: , stalking, harassment and aggravated harassment,
cyberstalking
discrimination of an employee under New York Human Rights Law, sexual harassment of an

independent contractor under New York Human Rights Law, employment discrimination and

retaliation, and sexual discrimination of employee under New York City Administrative Code.

PARTIES AND VENUE

5. Plaintiff, ALICE BAHAR (hereinafter referred to as “Bahar” or “Plaintiff”), is a

resident of New York, who presently, and at all times relevant hereto, resides in the City of New

York, County and State of New York.

6. Upon information and belief, Defendant ABRAHAM SANIEOFF (hereinafter

referred to “Abraham” or “Sanieoff”), presently and at all times relevant hereto, is a resident of

the Village of Great Neck, County of Nassau and State of New York.

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7. Upon information and belief, Defendant CHARLET SANIEOFF (hereinafter

referred to “C. Sanieoff”), presently and at all times relevant hereto, is a resident of the Village of

Great Neck, County of Nassau and State of New York.

8. Upon information and belief, C. Sanieoff’s mother ELIZA SABETFARD

(hereinafter referred to as “E. Sabetfard”), presently and at all times relevant hereto, is a resident

of the Village of Great Neck, County of Nassau and State of New York.

9. Upon information and belief, C. Sanieoff’s brother LEOR SABETFARD

(hereinafter referred to as “L. Sabetfard”), presently and at all times relevant hereto, and is a

resident of the City of New York, County and State of New York.

10. Upon information and belief, C. Sanieoff’s brother MATTHEW SABETFARD

(hereinafter referred to as “M. Sabetfard”), presently and at all times relevant hereto, is a resident

of the Village of Great Neck, County of Nassau and State of New York.

11. Upon information and belief, Defendant SANI GROUP a/k/a 25 GROVE STREET

LLC (hereinafter referred to as “Sani Group”), presently and at all times relevant hereto, is a

corporation doing business in the State of New York, which, among other things, owned property

located at 25 Grove Street, New York, New York, and has an office at 38 West 31st Street, Suite

3, New York, New York 10001.

12. Venue is proper in New York County, as all events recited herein occurred in New

York County, where Plaintiff resides and works.

OVERVIEW

13. Plaintiff has had her New York real estate license since 2012. She has been working

as a licensed agent with Bond New York Properties, LLC (“Bond”) since 2013.

14. Bahar worked on both open listings and maintained exclusive listings with several

landlords in the West Village, New York. It is very rare to obtain exclusives, and is considered a

big deal when such an agreement is given.

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15. Plaintiff met Sanieoff on May 18, 2016.

16. Sanieoff is the owner and Managing Member of 25 Grove Street LLC, which owns

the building located at 25 Grove Street, New York, New York (“25 Grove”).

FACTS

17. Sanieoff had been looking for an agent to list Apartment #5 at 25 Grove. Zuko,

Sanieoff’s super at 25 Grove, set up a meeting between Sanieoff and Plaintiff on May 18, 2016

about the possibility of signing her as his broker.

18. At their meeting, Sanieoff showed Plaintiff Apartment #5, and after talking for

about five minutes, he hired her and signed the first exclusive agreement with Bond for Plaintiff

to be the exclusive broker on Apartment #5 for the period between May 18, 2016 and June 18,

2016. As a result, she began working for him and 25 Grove. Deleted: as an independent contractor, with Sanieoff, the
principal, and Managing Member of, the Sani Group and/or
25 Grove Street LLC, as her boss.
19. On May 19, 2016, Bahar and a photographer went to 25 Grove to take pictures of

Apartment #5, and she listed the apartment online that same day.

20. A client contacted Bahar to see Apartment #5, and she showed the apartment on

May 20, 2016. Bahar hosted additional open houses from May 21 to 23, 2016.

21. In addition to hosting open houses, Bahar received numerous emails and

communicated with clients constantly in order to secure a lease for the apartment.

22. After just 2 days, on May 21, 2016, Bahar received an application for Apartment

#5.

23. Sanieoff required Bahar to meet him in person to go over any applications for his

apartments and any other paperwork.

24. Plaintiff met Sanieoff at the Starbucks on 7th Avenue and Grove Street on May 23,

2016 to go over the application for Apartment #5, though she never had to meet with a landlord in

person to go over an applications before, and believed this requirement to be unusual.

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25. Sanieoff also required Plaintiff to meet with him in person to go over the lease, later

that same day on May 23rd.

26. Sanieoff approved the application on or about May 23, 2016, and the tenants signed

Apartment #5’s lease on or about May 31 at or about 7 p.m. in Bahar’s office.

27. During the period of this first exclusive, Sanieoff texted Plaintiff many times and

praised her for her hard work.

28. Sanieoff was satisfied with Bahar’s work and told her on May 24, 2016 that he

cannot wait to work with her on the next apartment—which happened to be Apartment #6. Bahar

showed this unit on May 25th, and tendered the tenant’s application and leased the unit on May

26th, in a turnaround so quick that it was not listed online.

29. Bahar worked hard for each apartment she received an exclusive agreement for,

including, but not limited to, Apartment #s 12, 7, 4, 19, and 5 (re-listing) at 25 Grove, as well as

her other exclusives in other buildings.

30. In addition to the aforementioned Apartments, Bahar also rented Apartment #’s 8,

2, and 11 at 25 Grove.

31. While Bahar may have first started working for 25 Grove and Abraham as an

independent contractor, it soon became clear that Abraham and 25 Grove employed Bahar. Formatted: Font: (Default) Times New Roman

32. Slowly, Sanieoff started getting close to Plaintiff, wanting to spend more time with

her. Due to the fact that Sanieoff required that Bahar meet him in person every time she had an

application for an apartment, he often asked her to meet in one of the empty apartments in 25

Grove.

33. When she asked if she could email him the application to lease an apartment from

a potential renter, as is usually done, his response was “This is not how I work,” requiring her to

meet him in person each time. This prevented Bahar from spending time to develop business

contacts with other landlords to secure more exclusives, and lease the exclusives she already had

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at other buildings, so she could earn more money by way of other landlords, as she was constantly

meeting with Sanieoff under his in-person policy.

34. Bahar began receiving checks directly from 25 Grove Street and executed by

Abraham, in 2016 and 2017.

35. From the outset, Sanieoff engaged in a pattern of sexual banter, flirtation, innuendo,

comments, jokes, requests, and other forms of inappropriate behavior, creating a polluted and

hostile work atmosphere.

36. Sanieoff came by 25 Grove when he knew Bahar would be working, often waiting

around for her to finish with showing an apartment to spend time with her.

37. Sanieoff incessantly offered to take Bahar out for coffee, and questioned every time

when she declined.

38. When Plaintiff was showing exclusives in other buildings, Sanieoff would

sometimes escort her there, and wait while she met with clients. She found this behavior odd.

39. Plaintiff was aware of the fact that Sanieoff had the authority to either stop giving

her future exclusive agreements or even fire her if she did not comply with his invitations. As

Sanieoff was in the process of renovating many units at 25 Grove and more were becoming

available every month to lease out, he also constantly talked about purchasing another building,

and asked Bahar for her opinion on the new building and the apartments in 25 Grove, Plaintiff

knew and understood that there was a lot of employment potential with Sanieoff.

40. Eventually, Plaintiff gave in to Sanieoff’s invitation when he offered to buy her a

smoothie, having run out of excuses to decline. Sanieoff continued to walk with Plaintiff to her

office upon purchasing the smoothie, though he had no reason to go in the direction of her office.

41. Sanieoff took the smoothie acceptance as the gateway to invite Plaintiff to lunch

and other meetups that went beyond the scope of a typical lease application discussion.

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42. Sanieoff started calling and texting Plaintiff late at night because he was aware that

she was single and alone, working hard to pay her bills, and was potentially vulnerable to being

taken advantage of.

43. Toward the end of June 2016, Plaintiff and Sanieoff met at Starbucks to discuss

lease application documents, upcoming apartment showings, and renovations at 25 Grove. At this

point, Plaintiff had been working for Sanieoff for a little longer than one (1) month. At this work-

related meeting, and out of nowhere, Sanieoff gave Plaintiff an extremely inappropriate gift from

an adult entertainment store, the nature of which is not appropriate to state herein.

44. In July 2016, while showing a unit at 25 Grove, Defendant Sanieoff surprised Bahar

and began to make inappropriate jokes while opening his pants. He also began to touch Bahar’s

vagina without her consent, from the outside, while telling her to touch his penis. Bahar refused

and Abraham left, leaving Plaintiff feeling shocked and trapped.

45. Soon after, while showing another unit at 25 Grove, Abraham called to see if Bahar

was still there. She told him she was in the unit with the prospective tenant. He asked

her to meet him in Unit 2 when she was done with the showing.

46. Once in Unit 2, Abraham took out a bottle of Johnny Walker Blue that he said he just Formatted: Indent: Left: 0.25", Hanging: 0.25"

bought on his walk over. He asked Bahar if she wanted to have a drink. She said yes

and Abraham kept pouring her drinks, until things became fuzzy. He started touching

her vagina and this time they did have sex. Formatted: Font: (Default) -webkit-standard, Font color:
Black

47. Upon information and belief, Sanieoff refused to rent out Unit 2 because he used it Deleted: In July 2016,
Deleted: Sanieoff offered Plaintiff Johnny Walker Blue
as his “man cave.” whiskey inside Apartment #2, the apartment that
Deleted: and
48. Essentially, while giving Plaintiff the exclusive agreements, he expected sexual Deleted: ,
Deleted: for the purpose of getting her tipsy so he could
favors in return. On a few occasions, he stopped by open houses she was holding on Sunday, and induce her into having sex with him.

started touching and caressing Plaintiff and asked her to touch…… but Plaintiff refused. This

happened in Apartment #4 before they had any personal contact.

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49. Sanieoff was sending text messages nonstop every single day from 7 a.m. to 10

p.m., and even in the middle of the night, in spite of the fact that Plaintiff was pleading with him

to leave her alone and saying that the only thing she wanted was to do her job and make a living.

50. In response, Plaintiff kept telling Sanieoff to go be with his family.

51. Further, among the subjects discussed with Plaintiff were Sanieoff’s home, family,

relatives, tenants, and strategies concerning the same, activities in other states, including, but not

limited to, Boston, and other matters, the nature of which is best not revealed and/or disclosed in

a public filing. This went above and beyond the scope necessary for an employer-employee

relationship.

52. Sanieoff gave Plaintiff small jewelry gifts for the December 2016 holidays, though

Plaintiff refused to accept them and told him to return them. He reasoned that they were in

appreciation for all the work she did at 25 Grove.

53. Sanieoff bought a second building, 601 Hudson Street, New York, New York (“601

Hudson”), on or about April 20, 2017. Before the purchase was finalized in months prior, he took

Plaintiff in or around December 2016 to the building to view it and asked for her opinion on floor

plans. He told her that the commercial space in the building would be his office and that he wanted

her to get a broker’s license and work exclusively with him there, instead of working at her real

estate agency. He also informed the prior owner that he had a broker (Plaintiff) to lease the units,

and would not need the prior owner’s broker—who had a listing up at the time. Formatted: Font: (Default) Times New Roman

54. Sanieoff had requested Plaintiff to find comparable units to the ones at 601 Hudson

as research for how to price them and renovate them. One such comparison in or about January

2017 that she gave him was for a four-bedroom unit for about $9,000 at 400 Bleecker Street, New

York, New York.

55. On or about Valentine’s Day, February 14, 2017, Sanieoff gave Plaintiff a bracelet.

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56. On or about February 15, 2017, Sanieoff asked Plaintiff to find comparisons in the

West Village for similar commercial units to the one at 601 Hudson, so he could renovate and

price it accordingly. Plaintiff printed comparisons for him.

57. Unfortunately, Bahar never realized the benefits from this employment Formatted: Font: (Default) Arial, Font color: Black
Formatted: Font: (Default) Arial, Font color: Black
because she was fired by Abraham and 25 Grove on February 17, 2017, just over two Formatted: Font: (Default) Arial, Font color: Black

months before Abraham did in fact purchase 610 Hudson Street (on or about April 20,

2017). All worked performed by Bahar for 601 Hudson was done through her personally. Formatted: Font: (Default) Times New Roman

58. Before and through this date, Plaintiff had been a hard worker and achieved every

goal and assignment she had to complete for Sanieoff as his exclusive broker. No one else had

worked for Sanieoff and Sani Group to lease units during the time that Plaintiff worked with

Sanieoff.

59. Plaintiff went above and beyond her real estate duties as the exclusive broker on 25

Grove units to ensure Sanieoff was satisfied with her work; in addition to the typical broker duties,

which include listing apartments, communicating with potential clients, showing apartments,

collecting and reviewing applications, preparing and orchestrating lease signing, and turning over

the keys, she additionally visited 601 Hudson with Sanieoff, toured each unit individually, and

found comparisons for units, among other things—all of which went beyond her scope as an agent.

60. Meanwhile, Defendant C. Sanieoff had hired a private investigator to follow

Sanieoff, her husband. She discovered Sanieoff’s activities in February 2017, and told Sanieoff of

her findings.

61. On February 17, 2017, at or about 1:37 p.m. EST, Sanieoff left Plaintiff a voicemail,

terminating her employment. The first twenty-four seconds of the voicemail played the following:

Hi Alice. This is Abe. Um. I can’t work with you anymore. I can’t
see you anymore. Can’t talk with you anymore. My wife knows
everything, and she has a private investigator that was following us.
Um. That’s it. You’re fired from Grove. We can’t work together
on anything anymore.

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(emphasis added).

62. As a direct result of Sanieoff’s inability to have a personal relationship with

Plaintiff due to his wife’s findings, he terminated Plaintiff’s employment, including the work she

was doing on behalf of 610 Hudson Street, that very same day because she could no longer be used

as an object of his sexual desires, despite her impeccable work performance at 25 Grove and 601 Deleted: help with

Hudson.

63. Plaintiff was denied employment, career opportunities, exclusivity rights to future

apartments, including 601 Hudson, and other benefits that other similarly situated brokers would

be afforded by landlords based on their performance, due to Sanieoff’s sexual discrimination and

harassment of Plaintiff.

64. Not only did Plaintiff lose her job without merit, but C. Sanieoff began threatening

Plaintiff with both voicemails and text messages, beginning with the second half of Sanieoff’s

February 17, 2017, 1:37 p.m. recording.

65. C. Sanieoff was in earshot of the voicemail recording when Sanieoff terminated

Plaintiff’s employment, and approximately twenty-five seconds into the recording, she threatened

Plaintiff.

66. Immediately after hearing this voicemail, on February 17, 2017, Plaintiff took down

the active re-listing for Apartment #5 at 25 Grove, for which she had been instructed to relist on

January 26, 2017 by Sanieoff.

67. The phone calls and text messages from C. Sanieoff and her mother, Defendant E.

Sabetfard, to Plaintiff were frequent and incessant. C. Sanieoff and E. Sabetfard were so nefarious

in their recordings that Plaintiff was afraid to leave her apartment. Phone calls with serious threats

started on February 17, 2017, and text messages of the same nature began on February 18, 2017.

68. E. Sabetfard, C. Sanieoff’s mother, left Plaintiff at least ten (10) voicemails over

the course of a two-and-a-half-week period.

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69. In these messages, E. Sabetfard boasted of her power and threatened Bahar’s well-

being.

70. On February 18, 2017, Plaintiff received a text message from C. Sanieoff, wherein

she states her numerous affiliations with NYPD officers who owe her a favor. She also warns of

so many people watching Bahar 24 hours a day.

71. These voicemails and text messages were full of vile threats and insults and were

intended to terrorize, intimidate and harass Plaintiff.

72. Plaintiff was unable to sleep, eat, work, or do anything normal anymore, upon

receiving threat after threat after threat. Plaintiff’s life was changed immediately and drastically.

73. Plaintiff took every word C. Sanieoff and E. Sabetfard said very seriously and she

is still afraid; she has nightmares and cannot sleep at night because of her threats.

74. In addition to the threatening voice and text messages, C. Sanieoff and E. Sabetfard

interfered with Plaintiff’s job by harassing her supervisors and pretending to be clients; L.

Sabetfard and M. Sabetfard followed Plaintiff; C. Sanieoff hired a private investigator to watch

and record Plaintiff; C. Sanieoff also hired a threatening African-American of husky build to

intimidate and harm Plaintiff, as was threatened in the February 20, 2017, 9:06 a.m. voicemail;

and Sanieoff admitted to Plaintiff’s real estate agency that he had a business and personal

relationship with her, in order to endanger her job. All of these actions were done while Plaintiff

had an effective order of protection against C. Sanieoff, who spearheaded this campaign against

Plaintiff.

75. Plaintiff filed a police report on February 18, 2017 and C. Sanieoff was arrested in

March 2017. Plaintiff obtained her first order of protection against C. Sanieoff in April 2017, in

effect until July 12, 2017.

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76. C. Sanieoff stated in one of her voicemails that Plaintiff “will never have another

listing” as most of the landlords live in Great Neck and they all know each other. Defendants’ plan

was to spread rumors about Plaintiff, so she would lose the opportunity to make a living.

77. C. Sanieoff and E. Sabetfard were calling Plaintiff’s managers approximately

twenty (20) times a day in February and March 2017, bothering them and complaining in order to

get Plaintiff fired.

78. On or about March 1, 2017, Plaintiff’s manager called Plaintiff and asked her to

come to the office the next day at 8:30 a.m. so they could talk.

79. Plaintiff’s manager decided to give Plaintiff another chance if the phone calls

stopped. Defendants embarrassed Plaintiff so she could not show her face at work.

80. Moreover, E. Sabetfard was sending Plaintiff emails pretending to be a client who

wanted to see an apartment; she was emailing Plaintiff from fake email accounts and texting and

calling Plaintiff from fake numbers, as will be revealed in the course of discovery.

81. Defendants were trying to do everything possible for Plaintiff not to work so she

would not be able to pay her bills and be forced to leave New York and return to her home country

of Israel, as E. Sabetfard alluded to in one of her many voicemails.

82. Moreover, C. Sanieoff sent her brothers L. Sabetfard and M. Sabetfard to follow

Plaintiff everywhere by foot or by car, especially in her neighborhood, monitor her activities, and

intimidate her so Plaintiff could not leave her apartment or go to work. Plaintiff saw them circling

around her all the time.

83. Every time that Plaintiff left her apartment, she could see C. Sanieoff’s brothers

circling around Plaintiff.

84. L. Sabetfard and M. Sabetfard knew Plaintiff’s route in the morning, as she would

leave her apartment and walk by Starbucks on W 10th Street and Hudson Street to go to her office.

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85. On March 3, 2017 at or about 9:30 a.m., L. Sabetfard started following Plaintiff,

who was right next to Starbucks. This Starbucks is across the street from the New York City Police

Department – 6th Precinct station at 233 W 10th Street, New York, New York. Plaintiff got scared

when she saw L. Sabetfard right behind her and decided to cross the street and stand in front of the

police station until he walked away.

86. L. Sabetfard walked to the corned and then looked back to see if Plaintiff was still

there, but she was hiding behind a car, so he did not see her.

87. That same morning, when Plaintiff finally went to the office at or about 10:30 a.m.,

she called the police to tell them that C. Sanieoff’s brothers were following her.

88. The police station has cameras and were able to record Plaintiff hiding from L.

Sabetfard, and they could see him walking behind her.

89. Further, C. Sanieoff was sending private investigators to follow and watch Plaintiff

all the time when Plaintiff left her apartment.

90. C. Sanieoff had said that she had numerous NYPD officers, whom all owed her

favors, and private investigators working for her, in her communications to Plaintiff.

91. C. Sanieoff and E. Sabetfard sent Jerry Breen (“Breen”), a private investigator, to

approach Plaintiff on June 4 and July 11, 2017, in spite of Plaintiff having an order of protection.

92. Jerry Breen was sent to make conversation with Plaintiff, pretending to be friendly

and get to know Plaintiff so C. Sanieoff could obtain personal information about Plaintiff.

93. Breen wanted to know if Plaintiff lived in her apartment without her parents, where

she liked to go out, and whether she worked from home or went to the office.

94. Breen offered Plaintiff to have a drink, all while recording everything that she said.

95. Plaintiff received texts about a week later from E. Sabetfard pretending to be “John”

with information that she only gave to Breen. Because of this, Plaintiff knew that she was being

recorded during her conversation with Breen.

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96. Later, Breen started telling Plaintiff repeatedly “I want to kiss you, I don’t want to

fuck you… You like to have fun, right?... What kind of fun, drugs? … I’m looking at your breast!”

He was repeating that on purpose to get Plaintiff’s reaction and make her feel like that was all that

she was good for, as he was directed to do by Defendants.

97. Breen was trying to put words in Plaintiff’s mouth. He was on a mission to make

her look bad, cheap, dirty, and a whore so Defendants could spread rumors about her and destroy

Plaintiff’s reputation, so nobody would deal with Plaintiff in her personal or professional life.

98. On July 12, 2017, upon the expiration of her first protective order, and the day after

Breen approached Plaintiff for the second time, Plaintiff obtained another temporary order of

protection, valid until January 11, 2018.

99. In addition, on or about September 1, 2017 at or about 11:45 a.m., Plaintiff observed

a stranger—African-American with a husky build—sitting in front of her building, monitoring

who was coming in and out, just as C. Sanieoff had threatened in her February 20, 2017, 9:06 a.m.

voicemail. Plaintiff has lived in the same apartment for ten (10) years and nobody had ever done

that before, except for Defendants. Plaintiff has a picture of this stranger sitting in front of her

building from this date and time.

100. On or about September 14, 2017, Plaintiff’s real estate agency, Bond, received a

letter from Sanieoff’s counsel admitting that Sanieoff was in a professional and personal

relationship with Plaintiff, and that upon his termination of both personal and business

relationships, she engaged in retaliatory tactics to embarrass him in front of his family. This letter

was written and sent in an effort to turn the tables against Plaintiff about who was harassing whom,

put her in trouble at her job, and make her lose her job so she would not have the opportunity to

make a living.

101. As the voicemail from February 17, 2017, 1:37 p.m. shows, Sanieoff terminated his

business and personal relationship simultaneously in the same twenty-four-second period, and

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instantly, his wife C. Sanieoff chimed in and threatened Plaintiff. The harassment began here by

Defendants.

102. During the course that these harassing events were taking place, Plaintiff filed

police reports after C. Sanieoff was arrested and Plaintiff contacted the District Attorney many

times due to Defendants’ violation of the order of protection. However, upon information and

belief, nobody cared or wanted to help Plaintiff because of Defendants’ power, wealth, and

influence, all of which is being investigated as, upon information and belief, improper influence

was exerted.

103. The whole Defendant family worked extremely hard to destroy Plaintiff’s life and

her reputation.

104. All of Defendants’ actions changed Plaintiff’s life completely. First, Sanieoff took

advantage of Plaintiff, and then, the rest of the family attacked Plaintiff like an animal.

105. Plaintiff is still having a very hard time as she cannot go back to her normal life and

is undergoing treatment, which is expected to last at least one (1) year or more.

106. Plaintiff always watches her back when she walks around because she is afraid.

107. Plaintiff goes to a therapist to try to heal, but it will take a long time.

AS AND FOR A FIRST CAUSE OF ACTION

(Intentional Infliction of Emotional Distress)

108. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

101 above, as fully set forth herein.

109. As detailed herein, Defendants jointly and severally have engaged in (i) extreme

and outrageous conduct; with the (ii) intent to cause, or disregard of a substantial probability of

causing, severe emotional distress; (iii) and there is a causal connection between the conduct and

injury; and there has been (iv) severe emotional distress.

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110. Defendants have intentionally and recklessly engaged in the extreme and

outrageous conduct described above for the sole purpose of causing severe emotional distress and

harm.

111. By engaging and continuing to engage in the actions and conduct described above,

Defendants’ have caused significant harm, including extreme emotional distress and anxiety to

Plaintiff.

112. As a result of said emotional distress that has been caused by Defendants, Plaintiff,

for the first time, has been forced to undergo psychiatric treatment and has been prescribed a litany

of anti-depressant and anti-anxiety medications simply so that she can function in her day-to-day

life.

113. Nevertheless, even with the medical treatment and medications, Plaintiff has been

unable to resume her normal life free from extreme emotional distress and anxiety, which she

enjoyed prior to the Defendants’ intentionally engaging in a malicious campaign of extreme and

outrageous harassment, lies, and intimidation against her, as described above.

114. At all times described herein, Defendants were aware of the harm and severe

emotional distress that their actions were causing Plaintiff and yet, they continued to engage in the

conduct described above without any justification based in law or any bounds of decency, simply

because they have the wealth and power to do so without any perceived repercussions—even

violating orders or protection with impunity, which is being investigated.

115. Plaintiff also continues to suffer from extreme emotional distress and anxiety as a

direct result of Defendants’ intentional conduct, as described above.

116. Furthermore, Plaintiff continues to fear for her safety, which only serves to add to

and heighten the emotional distress and anxiety from which she is suffering, as a direct result of

being constantly watched and stalked by Defendants and their private security detail.

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117. By reason of the foregoing, Defendants are liable to Plaintiff for compensatory and

punitive damages for the harm she has suffered and continues to suffer as a direct result of

Defendants’ intentional and ongoing actions described above, the remedy of which shall be

determined as trial, but in no event, should be less than ten million dollars ($10,000,000).

AS AND FOR A SECOND CAUSE OF ACTION

(Negligent Infliction of Emotional Distress)

118. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

111 above, as fully set forth herein.

119. As described above, Defendants’ conduct jointly and severally and actions directed

towards Plaintiff created an unreasonable risk of causing Plaintiff emotional distress.

120. At all relevant times, Defendants were aware of the emotional distress they were

causing Plaintiff and the fact that she was suffering from severe depression and anxiety as a result.

Nevertheless, Defendants, hired private security to follow and harass the Plaintiff, all of which has

been described above. They also engaged in the extreme and outrageous conduct described above,

including the threatening text and voice messages..

121. Plaintiff feared and continues to fear for her safety as a result of being followed and

harassed by Defendants and Defendants’ private security, which only serves to cause her additional

emotional distress.

122. Based on all of the above described circumstances, Defendants’ conduct of

harassment and having the Plaintiff followed by Senioff’s private security created an unreasonable

risk of causing her severe emotional distress and anxiety.

123. As has been described above, Defendants were aware of Plaintiff’s emotional state

as a result of all of their actions and conduct so that it was clearly foreseeable that having Plaintiff

followed and/or harassed by Defendants and a private security would cause her greater emotional

distress.

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124. Defendants’ conduct, as described above, has caused Plaintiff to fear for her safety

and wellbeing, which has caused and continues to cause Plaintiff severe emotional distress.

125. By reason of the foregoing, Defendants are liable to Plaintiff for compensatory and

punitive damages for the harm she has suffered and continues to suffer as a direct result of

Defendants’ actions described above, the remedy of which shall be determined at trial, but in no

event should be less than ten million dollars ($10,000,000).

AS AND FOR A THIRD CAUSE OF ACTION

(Prima Facie Tort)

126. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

119 above, as fully set forth herein.

127. Defendants jointly and severally engaged in those acts detailed above, and as will

be revealed in the course of discovery for the purpose of intentionally inflicting harm, to

Defendants without excuse or justification by and through a series of acts, that, in this case were

not even lawful even if they believed their acts to be lawful.

128. By reason of the foregoing, Defendants are liable to Plaintiff for compensatory,

special, and punitive damages.

AS AND FOR A FOURTH CAUSE OF ACTION

(Battery) Formatted: Font: (Default) Times New Roman

129. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through Formatted: Font: (Default) Times New Roman

128 above, as fully set forth herein. Formatted: Font: (Default) Times New Roman

130. As described above, Defendant Abraham touched Bahar’s vagina, without her

consent.

131. Defendant Abraham intended to make the contact, as he was touching himself at

the same time. This conduct is the very definition of offensive and caused Bahar to suffer.

132. By reason of the foregoing, Defendant Abraham is liable to Plaintiff for

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compensatory, special, and punitive damages. Formatted: Font: (Default) Times New Roman
Formatted: Font: (Default) Times New Roman
AS AND FOR A FIFTH CAUSE OF ACTION Formatted: Normal, No bullets or numbering
Deleted: AS AND FOR A FOURTH CAUSE OF
(Aiding and Abetting Battery) ACTION¶
(Stalking)¶
Plaintiff repeats and realleges the allegations contained in
Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through 132 above, Paragraphs 1 through 122 above, as fully set forth herein. ¶
Defendants jointly and severally, intentionally, and for no
as fully set forth herein. legitimate purpose, engaged in a course of conduct directed
at Plaintiff and knew or reasonably should have known that
such conduct was likely to cause reasonable fear of material
130. As described above, Defendant Abraham touched Bahar’s vagina, without her harm to the physical health, safety, or property of Plaintiff
and cause material harm to the mental or emotional health of
Plaintiff, as such conduct consisted of telephoning or
consent. initiating communication or contact with Plaintiff, and
Defendants were aware or should have been aware that they
131. Defendant Abraham intended to make the contact, as he was touching himself at should have ceased such actions.¶
Further, Defendants engaged in those actions complained of
herein to cause Plaintiff to reasonably fear that her
the same time. This conduct is the very definition of offensive and caused Bahar to suffer. employment or career would be threatened, where such
conduct consisted of appearing, telephoning, or initiating
communication or contact at Plaintiff’s place of employment
132. Defendant 25 Grove Street did nothing to stop the battery by Abraham despite or business. ¶
By reason of the foregoing, Defendants are liable to Plaintiff
having knowledge of harassment campaign against Bahar. They own the property located at 25 for compensatory, special, and punitive damages. ¶
AS AND FOR A FIFTH CAUSE OF ACTION¶
(Harassment and Aggravated Harassment)¶
Grove Street, were party to the exclusive rental agreements, and Abraham was managing member Plaintiff repeats and realleges the allegations contained in
Paragraphs 1 through 126 above, as fully set forth herein. ¶
Defendants jointly and severally, intentionally, and for no
of 25 Grove Street during all relevant time periods herein. legitimate purpose engaged in a course of conduct which
annoyed, threatened, intimidated, alarmed, and put Plaintiff
132. By reason of the foregoing, Defendant 25 Grove Street is liable to Plaintiff for in fear of her safety.¶
By reason of the foregoing, Defendants are liable to Plaintiff
for compensatory, special, and punitive damages. ¶
compensatory, special, and punitive damages. AS AND FOR A SIXTH CAUSE OF ACTION¶
(Cyberstalking)¶
Plaintiff repeats and realleges the allegations contained in
AS AND FOR A FIFTH CAUSE OF ACTION Paragraphs 1 through 129 above, as fully set forth herein. ¶
Defendants jointly and severally, intentionally, and for no
(Sexual Discrimination Against Employee Under New York Human Rights Law) legitimate purpose engaged in a course of conduct, as
detailed above, which annoyed, threatened, intimidated,
alarmed, and put Plaintiff in fear of her safety through the
133. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through 132 use of emails, text messages, and through use of the Internet. ¶
By reason of the foregoing, Defendants are liable to Plaintiff
for compensatory, special, and punitive damages. ¶
above, as fully set forth herein.
Deleted: SEVENTH
134.Pursuant to Section 296(I) of the Executive Law, it is an unlawful discriminatory Formatted: Font: (Default) Times New Roman
Formatted: Normal, No bullets or numbering
practice for an employer, because of the sex of an individual, to discriminate against any such Deleted: ¶
Formatted: Font: (Default) Times New Roman
individual in compensation or in terms, conditions, or privileges of employment. Formatted: Font: (Default) Times New Roman
Formatted: Font: (Default) Times New Roman
135. Defendants Sanieoff and Sani Group a/k/a 25 Grove have engaged in an unlawful
Formatted: Normal, No bullets or numbering

discriminatory practice under Section 296(I) of the State Human Rights Law by failing to promote Deleted: ¶
Formatted: Font: (Default) Times New Roman
Plaintiff, and significantly reducing her assignments and responsibilities on the basis of her sex. Formatted: Font: (Default) Times New Roman
Formatted: Normal, Indent: First line: 0.5", No bullets or
numbering
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136. As a result of the foregoing unlawful discriminatory practices, Plaintiff has suffered

and will continue to suffer damages in an amount to be determined, but in no event should be less Formatted: Font: (Default) Times New Roman
Formatted: Normal, No bullets or numbering
than ten million dollars ($10,000,000).

AS AND FOR AN SIXTH CAUSE OF ACTION Deleted: EIGHTH

(Sexual Harassment of Independent Contractor under New York Human Rights Law)

137. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through 136 Formatted: Font: (Default) Times New Roman

above, as fully set forth herein. Formatted: Font: (Default) Times New Roman
Formatted: Normal, No bullets or numbering
138. Pursuant to Section 296-d of the Executive Law, it is an unlawful discriminatory Deleted: .¶
Formatted: Font: (Default) Times New Roman
practice for an employer to permit sexual harassment of non-employees in its workplace. An Formatted: Normal, Indent: First line: 0.5", No bullets or
numbering
employer may be held liable to a non-employee who is a contractor, subcontractor, vendor, Formatted: Font: (Default) Times New Roman

consultant or other person providing services pursuant to a contract in the workplace or who is an

employee of such contractor, subcontractor, vendor, consultant or other person providing services

pursuant to a contract in the workplace, with respect to sexual harassment, when the employer, its

agents or supervisors knew or should have known that such non-employee was subjected to sexual

harassment in the employer’s workplace, and the employer failed to take immediate and

appropriate corrective action.

139. Defendants Sanieoff and Sani Group a/k/a 25 Grove have engaged in an unlawful Formatted: Font: (Default) Times New Roman

discriminatory practice under Section 296-d of the State Human Rights Law because Sanieoff, as Formatted: Font: (Default) Times New Roman
Formatted: Normal, No bullets or numbering
Plaintiff’s direct supervisor and the principal of Sani Group/owner of 25 Grove Street LLC,

sexually harassed Plaintiff during her employment as an independent contractor at 25 Grove, and

failed to take immediate and appropriate corrective action.

140. As a result of the foregoing unlawful discriminatory practices, Plaintiff has suffered and Formatted: Font: (Default) Times New Roman

will continue to suffer damages in an amount to be determined, but in no event should be less than Formatted: Font: (Default) Times New Roman
Formatted: Normal, No bullets or numbering
ten million dollars ($10,000,000).

AS AND FOR A SEVENTH CAUSE OF ACTION Deleted: NINTH

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(Employment Discrimination and Retaliation)

1. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

140 above, as fully set forth herein.

2. Pursuant to Section 296(7) of the Executive Law, it is unlawful discriminatory

practice for any person engaged in any activity to which this section applies, to retaliate or

discriminate against any person because she has opposed any practices forbidden under this Article

or because she has filed a complaint, testified, or assisted in any proceeding under this Article.

3. Defendant Sanieoff and Sani Group a/k/a 25 Grove have engaged in unlawful

discriminatory practice under Section 296(7) of the Human Rights Law by creating a hostile and

intimidating atmosphere and engaging in a pattern of harassment and intimidation subsequent to

the time that Plaintiff brought this matter to its attention.

4. As a result of the foregoing unlawful discriminatory practices, Plaintiff has suffered

and will continue to suffer damages in an amount to be determined, but in no event should be less

than ten million dollars ($10,000,000).

AS AND FOR A EIGHTH CAUSE OF ACTION Deleted: TENTH

(Sexual Discrimination Against Employee under New York City Administrative Code)

5. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

144 above, as fully set forth herein.

6. Pursuant to Chapters 1 through 7 of Title 8 of the Administrative Code of the City

of New York, Section 8-101 et seq., it is an unlawful discriminatory practice for any person,

because of the sex of any individual, to discriminate against any such individual in compensation

or in terms, conditions, or privileges of employment, or to retaliate or discriminate against any

person because she has opposed any practice forbidden under this Article or because she has filed

a complaint, testified, or assisted in any proceeding under this Article.

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7. As a result of the aforementioned violations of the Administrative Code, Plaintiff

seeks, in addition to other damages, punitive damages in the amount to be determined, but in no

event should be less than ten million dollars ($10 million), in accordance with Chapter 5, ¶ 8-502

of the Administrative Code.

AS AND FOR A NINTH CAUSE OF ACTION Deleted: N ELEVENTH

(Intentional Interference with Contractual Relationship)

8. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

147 above, as fully set forth herein.

9. As discussed above, C. Sanieoff and E. Sabetfard were calling Plaintiff’s

managers approximately twenty (20) times a day in February and March 2017, bothering them

and complaining in order to get Plaintiff fired.

10. Sanieoff had his counsel send a letter to Bond admitting that Sanieoff was in a

professional and personal relationship with Plaintiff, and that upon his termination of both

personal and business relationships, she engaged in retaliatory tactics to embarrass him in front

of his family.

11. This letter was written and sent in an effort to turn the tables against Plaintiff

about who was harassing whom, put her in trouble at her job, and make her lose her job so she

would not have the opportunity to make a living.

12. Defendants knew of Bahar’s contract with Bond and intentionally interfered with

same, causing Plaintiff to suffer damages.

13. By reason of the foregoing, Defendants are liable to Plaintiff for compensatory,

special, and punitive damages.

AS AND FOR A TENTH CAUSE OF ACTION Deleted: TWELFTH

(Tortious Interference with Prospective Economic Advantage)

14. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

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153 above, as fully set forth herein.

15. As discussed above, C. Sanieoff and E. Sabetfard were calling Plaintiff’s

managers approximately twenty (20) times a day in February and March 2017, bothering them and

complaining in order to get Plaintiff fired.

16. Sanieoff had his counsel send a letter to Bond admitting that Sanieoff was in a

professional and personal relationship with Plaintiff, and that upon his termination of both personal

and business relationships, she engaged in retaliatory tactics to embarrass him in front of his

family.

17. This letter was written and sent in an effort to turn the tables against Plaintiff

about who was harassing whom, put her in trouble at her job, and make her lose her job so she

would not have the opportunity to make a living.

18. Defendants knew of Bahar’s relationship with Bond and intentionally,

Maliciously, and unlawfully interfered with Bahar’s business relationship with Bond, causing

Plaintiff to suffer damages.

19. By reason of the foregoing, Defendants are liable to Plaintiff for compensatory,

special, and punitive damages.

WHEREFORE, Plaintiff demands judgment against Defendants jointly and severally as

follows:

A) On the First Cause of Action, compensatory and punitive damages against

Defendants in an amount to be determined at trial, but in no event less than

$10,000,000;

B) On the Second Cause of Action, compensatory and punitive damages against

Defendants in an amount to be determined at trial, but in no event less than

$10,000,000;

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C) On the Third Cause of Action, compensatory damages against Defendants in an

amount to be determined at trial;

D) On the Fourth Cause of Action, compensatory and punitive damages against

Defendants in an amount to be determined at trial;

E) On the Fifth Cause of Action, compensatory damages against Defendants in an

amount to be determined at trial;

F) On the Sixth Cause of Action, compensatory damages against Defendants in an

amount to be determined at trial;

G) On the Seventh Cause of Action, compensatory damages and damages for mental

anguish, pain, and suffering against Defendants in an amount to be determined at

trial, but in no event less than $10 million;

H) On the Eighth Cause of Action, compensatory damages and damages for mental

anguish, pain, and suffering against Defendants in an amount to be determined at

trial, but in no event less than $10 million;

I) On the Ninth Cause of Action, compensatory damages and damages for mental

anguish, pain, and suffering against Defendants in an amount to be determined at

trial, but in no event less than $10 million;

J) On the Tenth Cause of Action, in addition to other damages, punitive damages in

the amount of $10 million;

K) On the Eleventh Cause of Action, in addition to other damages, punitive damages

in the amount of $10 million;

L) On the Twelfth Cause of Action, in addition to other damages, punitive damages in

the amount of $10 million;

M) All claims, costs, fees and expenses, including reasonable attorneys’ fees incurred

by Plaintiff in this action;

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N) Punitive damages on all causes of action;

O) For such other and further relief as the Court may deem just and proper;

P) Expedited Discovery including electronic discovery of all Defendants’ cell phones,

computers, phone records, board of director meetings for the Sani Group, insurance

policies, prior incident reports, phone records, payments to private detectives and

New York City police officers, and the six-foot-four person referenced in the

previously cited voicemail, and the personal and corporate tax returns of all

Defendants for two years, subject to a confidentiality and protective order.

DEMAND FOR JURY TRIAL

Plaintiff hereby demands a trial by jury on all issues and claims so triable.

Dated: New York, New York

January 29, 2019

Respectfully Submitted,

NEIL L. POSTRYGACZ
ATTORNEY AT LAW, P.C

By: Neil L. Postrygacz

175 Varick Street
New York, New York 10014
p 212-392-4945

Attorneys for Plaintiff

TO: Joseph L. Buckley

SILLS CUMMIS & GROSS, P.C.
101 Park Avenue, 28th Floor
New York, NY 10178
Attorneys for Defendants

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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
---------------------------------------------------------------------- X
ALICE BAHAR, :
: Index No. 150328/2018
Plaintiff, :
:
-against- : AMENDED VERIFIED
: COMPLAINT
ABRAHAM SANIEOFF; SANI GROUP a/k/a 25 :
GROVE STREET LLC; CHARLET SANIEOFF; ELIZA :
SABETFARD; LEOR SABETFARD; and MATTHEW
:
SABETFARD,
Defendants. :
:
---------------------------------------------------------------------- X

Plaintiff, ALICE BAHAR, individually through her attorneys, NEIL L. POSTRYGACZ,

ATTORNEY AT LAW, P.C., complaining of Defendants, ABRAHAM SANIEOFF, SANI

GROUP a/k/a 25 GROVE STREET LLC, CHARLET SANIEOFF, ELIZA SABETFARD, LEOR

SABETFARD, and MATTHEW SABETFARD, alleges as follows:

INTRODUCTION

1. While all humans are fallible, this action arises out of the intentional, premeditated,

and well planned predatory scheme of Defendant, ABRAHAM SANIEOFF, personally and on

behalf of SANI GROUP a/k/a 25 GROVE STREET LLC—whose negligence permitted the

actions complained of to happen—to use his power, wealth, influence, and connections to focus

on and orchestrate his plan to lure Plaintiff, a single 37-year-old hard-working real estate agent to

ostensibly be an onsite agent at 25 Grove Street, New York, New York (“25 Grove”), while his

undisclosed, real, and ulterior motive was to engage in a personal, hopefully “romantic” and

eventual intimate relationship with her, as detailed hereafter.

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2. Worse, immediately after the exposure of Sanieoff’s infidelity, improper and

inappropriate sexual behavior and exploitation, he personally terminated Plaintiff’s employment,

and Sanieoff’s family, including his wife, wife’s mother, and wife’s brothers, and as admitted,

New York City police and a “Black, six-foot-four” person that weighs “319 pounds” engaged in a

systematic, well planned, illegal, and vindictive conspiracy to threaten and intimidate Plaintiff.

3. Threats were made of disfiguring Ms. Bahar, breaking her legs, and causing severe

bodily harm while going to extraordinary levels to damage her reputation, destroy her career, and

essentially destroy her life with the intent and purpose of causing her irreparable physical and

emotional injury and economic loss, and as she was warned by Defendant ELIZA SABETFARD

(“ELIZA”), Sanieoff’s mother-in-law, in a voicemail dated February 17, 2017: “You don’t know

how powerful I am.”

4. These actions constitute causes of action for intentional infliction of emotional

distress, negligent infliction of emotional distress, illegal and prima facie tort, sexual

discrimination of an employee under New York Human Rights Law, sexual harassment of an

independent contractor under New York Human Rights Law, employment discrimination and

retaliation, and sexual discrimination of employee under New York City Administrative Code.

PARTIES AND VENUE

5. Plaintiff, ALICE BAHAR (hereinafter referred to as “Bahar” or “Plaintiff”), is a

resident of New York, who presently, and at all times relevant hereto, resides in the City of New

York, County and State of New York.

6. Upon information and belief, Defendant ABRAHAM SANIEOFF (hereinafter

referred to “Abraham” or “Sanieoff”), presently and at all times relevant hereto, is a resident of

the Village of Great Neck, County of Nassau and State of New York.

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7. Upon information and belief, Defendant CHARLET SANIEOFF (hereinafter

referred to “C. Sanieoff”), presently and at all times relevant hereto, is a resident of the Village of

Great Neck, County of Nassau and State of New York.

8. Upon information and belief, C. Sanieoff’s mother ELIZA SABETFARD

(hereinafter referred to as “E. Sabetfard”), presently and at all times relevant hereto, is a resident

of the Village of Great Neck, County of Nassau and State of New York.

9. Upon information and belief, C. Sanieoff’s brother LEOR SABETFARD

(hereinafter referred to as “L. Sabetfard”), presently and at all times relevant hereto, and is a

resident of the City of New York, County and State of New York.

10. Upon information and belief, C. Sanieoff’s brother MATTHEW SABETFARD

(hereinafter referred to as “M. Sabetfard”), presently and at all times relevant hereto, is a resident

of the Village of Great Neck, County of Nassau and State of New York.

11. Upon information and belief, Defendant SANI GROUP a/k/a 25 GROVE STREET

LLC (hereinafter referred to as “Sani Group”), presently and at all times relevant hereto, is a

corporation doing business in the State of New York, which, among other things, owned property

located at 25 Grove Street, New York, New York, and has an office at 38 West 31st Street, Suite

3, New York, New York 10001.

12. Venue is proper in New York County, as all events recited herein occurred in New

York County, where Plaintiff resides and works.

OVERVIEW

13. Plaintiff has had her New York real estate license since 2012. She has been working

as a licensed agent with Bond New York Properties, LLC (“Bond”) since 2013.

14. Bahar worked on both open listings and maintained exclusive listings with several

landlords in the West Village, New York. It is very rare to obtain exclusives, and is considered a

big deal when such an agreement is given.

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15. Plaintiff met Sanieoff on May 18, 2016.

16. Sanieoff is the owner and Managing Member of 25 Grove Street LLC, which owns

the building located at 25 Grove Street, New York, New York (“25 Grove”).

FACTS

17. Sanieoff had been looking for an agent to list Apartment #5 at 25 Grove. Zuko,

Sanieoff’s super at 25 Grove, set up a meeting between Sanieoff and Plaintiff on May 18, 2016

about the possibility of signing her as his broker.

18. At their meeting, Sanieoff showed Plaintiff Apartment #5, and after talking for

about five minutes, he hired her and signed the first exclusive agreement with Bond for Plaintiff

to be the exclusive broker on Apartment #5 for the period between May 18, 2016 and June 18,

2016. As a result, she began working for him and 25 Grove.

19. On May 19, 2016, Bahar and a photographer went to 25 Grove to take pictures of

Apartment #5, and she listed the apartment online that same day.

20. A client contacted Bahar to see Apartment #5, and she showed the apartment on

May 20, 2016. Bahar hosted additional open houses from May 21 to 23, 2016.

21. In addition to hosting open houses, Bahar received numerous emails and

communicated with clients constantly in order to secure a lease for the apartment.

22. After just 2 days, on May 21, 2016, Bahar received an application for Apartment

#5.

23. Sanieoff required Bahar to meet him in person to go over any applications for his

apartments and any other paperwork.

24. Plaintiff met Sanieoff at the Starbucks on 7th Avenue and Grove Street on May 23,

2016 to go over the application for Apartment #5, though she never had to meet with a landlord in

person to go over an applications before, and believed this requirement to be unusual.

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25. Sanieoff also required Plaintiff to meet with him in person to go over the lease, later

that same day on May 23rd.

26. Sanieoff approved the application on or about May 23, 2016, and the tenants signed

Apartment #5’s lease on or about May 31 at or about 7 p.m. in Bahar’s office.

27. During the period of this first exclusive, Sanieoff texted Plaintiff many times and

praised her for her hard work.

28. Sanieoff was satisfied with Bahar’s work and told her on May 24, 2016 that he

cannot wait to work with her on the next apartment—which happened to be Apartment #6. Bahar

showed this unit on May 25th, and tendered the tenant’s application and leased the unit on May

26th, in a turnaround so quick that it was not listed online.

29. Bahar worked hard for each apartment she received an exclusive agreement for,

including, but not limited to, Apartment #s 12, 7, 4, 19, and 5 (re-listing) at 25 Grove, as well as

her other exclusives in other buildings.

30. In addition to the aforementioned Apartments, Bahar also rented Apartment #’s 8,

2, and 11 at 25 Grove.

31. While Bahar may have first started working for 25 Grove and Abraham as an

independent contractor, it soon became clear that Abraham and 25 Grove employed Bahar.

32. Slowly, Sanieoff started getting close to Plaintiff, wanting to spend more time with

her. Due to the fact that Sanieoff required that Bahar meet him in person every time she had an

application for an apartment, he often asked her to meet in one of the empty apartments in 25

Grove.

33. When she asked if she could email him the application to lease an apartment from

a potential renter, as is usually done, his response was “This is not how I work,” requiring her to

meet him in person each time. This prevented Bahar from spending time to develop business

contacts with other landlords to secure more exclusives, and lease the exclusives she already had

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at other buildings, so she could earn more money by way of other landlords, as she was constantly

meeting with Sanieoff under his in-person policy.

34. Bahar began receiving checks directly from 25 Grove Street and executed by

Abraham, in 2016 and 2017.

35. From the outset, Sanieoff engaged in a pattern of sexual banter, flirtation, innuendo,

comments, jokes, requests, and other forms of inappropriate behavior, creating a polluted and

hostile work atmosphere.

36. Sanieoff came by 25 Grove when he knew Bahar would be working, often waiting

around for her to finish with showing an apartment to spend time with her.

37. Sanieoff incessantly offered to take Bahar out for coffee, and questioned every time

when she declined.

38. When Plaintiff was showing exclusives in other buildings, Sanieoff would

sometimes escort her there, and wait while she met with clients. She found this behavior odd.

39. Plaintiff was aware of the fact that Sanieoff had the authority to either stop giving

her future exclusive agreements or even fire her if she did not comply with his invitations. As

Sanieoff was in the process of renovating many units at 25 Grove and more were becoming

available every month to lease out, he also constantly talked about purchasing another building,

and asked Bahar for her opinion on the new building and the apartments in 25 Grove, Plaintiff

knew and understood that there was a lot of employment potential with Sanieoff.

40. Eventually, Plaintiff gave in to Sanieoff’s invitation when he offered to buy her a

smoothie, having run out of excuses to decline. Sanieoff continued to walk with Plaintiff to her

office upon purchasing the smoothie, though he had no reason to go in the direction of her office.

41. Sanieoff took the smoothie acceptance as the gateway to invite Plaintiff to lunch

and other meetups that went beyond the scope of a typical lease application discussion.

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42. Sanieoff started calling and texting Plaintiff late at night because he was aware that

she was single and alone, working hard to pay her bills, and was potentially vulnerable to being

taken advantage of.

43. Toward the end of June 2016, Plaintiff and Sanieoff met at Starbucks to discuss

lease application documents, upcoming apartment showings, and renovations at 25 Grove. At this

point, Plaintiff had been working for Sanieoff for a little longer than one (1) month. At this work-

related meeting, and out of nowhere, Sanieoff gave Plaintiff an extremely inappropriate gift from

an adult entertainment store, the nature of which is not appropriate to state herein.

44. In July 2016, while showing a unit at 25 Grove, Defendant Sanieoff surprised Bahar

and began to make inappropriate jokes while opening his pants. He also began to touch Bahar’s

vagina without her consent, from the outside, while telling her to touch his penis. Bahar refused

and Abraham left, leaving Plaintiff feeling shocked and trapped.

45. Soon after, while showing another unit at 25 Grove, Abraham called to see if Bahar

was still there. She told him she was in the unit with the prospective tenant. He asked

her to meet him in Unit 2 when she was done with the showing.

46. Once in Unit 2, Abraham took out a bottle of Johnny Walker Blue that he said he just

bought on his walk over. He asked Bahar if she wanted to have a drink. She said yes

and Abraham kept pouring her drinks, until things became fuzzy. He started touching

her vagina and this time they did have sex.

47. Upon information and belief, Sanieoff refused to rent out Unit 2 because he used it

as his “man cave.”

48. Essentially, while giving Plaintiff the exclusive agreements, he expected sexual

favors in return. On a few occasions, he stopped by open houses she was holding on Sunday, and

started touching and caressing Plaintiff and asked her to touch…… but Plaintiff refused. This

happened in Apartment #4 before they had any personal contact.

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49. Sanieoff was sending text messages nonstop every single day from 7 a.m. to 10

p.m., and even in the middle of the night, in spite of the fact that Plaintiff was pleading with him

to leave her alone and saying that the only thing she wanted was to do her job and make a living.

50. In response, Plaintiff kept telling Sanieoff to go be with his family.

51. Further, among the subjects discussed with Plaintiff were Sanieoff’s home, family,

relatives, tenants, and strategies concerning the same, activities in other states, including, but not

limited to, Boston, and other matters, the nature of which is best not revealed and/or disclosed in

a public filing. This went above and beyond the scope necessary for an employer-employee

relationship.

52. Sanieoff gave Plaintiff small jewelry gifts for the December 2016 holidays, though

Plaintiff refused to accept them and told him to return them. He reasoned that they were in

appreciation for all the work she did at 25 Grove.

53. Sanieoff bought a second building, 601 Hudson Street, New York, New York (“601

Hudson”), on or about April 20, 2017. Before the purchase was finalized in months prior, he took

Plaintiff in or around December 2016 to the building to view it and asked for her opinion on floor

plans. He told her that the commercial space in the building would be his office and that he wanted

her to get a broker’s license and work exclusively with him there, instead of working at her real

estate agency. He also informed the prior owner that he had a broker (Plaintiff) to lease the units,

and would not need the prior owner’s broker—who had a listing up at the time.

54. Sanieoff had requested Plaintiff to find comparable units to the ones at 601 Hudson

as research for how to price them and renovate them. One such comparison in or about January

2017 that she gave him was for a four-bedroom unit for about $9,000 at 400 Bleecker Street, New

York, New York.

55. On or about Valentine’s Day, February 14, 2017, Sanieoff gave Plaintiff a bracelet.

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56. On or about February 15, 2017, Sanieoff asked Plaintiff to find comparisons in the

West Village for similar commercial units to the one at 601 Hudson, so he could renovate and

price it accordingly. Plaintiff printed comparisons for him.

57. Unfortunately, Bahar never realized the benefits from this employment

because she was fired by Abraham and 25 Grove on February 17, 2017, just over two

months before Abraham did in fact purchase 610 Hudson Street (on or about April 20,

2017). All worked performed by Bahar for 601 Hudson was done through her personally.

58. Before and through this date, Plaintiff had been a hard worker and achieved every

goal and assignment she had to complete for Sanieoff as his exclusive broker. No one else had

worked for Sanieoff and Sani Group to lease units during the time that Plaintiff worked with

Sanieoff.

59. Plaintiff went above and beyond her real estate duties as the exclusive broker on 25

Grove units to ensure Sanieoff was satisfied with her work; in addition to the typical broker duties,

which include listing apartments, communicating with potential clients, showing apartments,

collecting and reviewing applications, preparing and orchestrating lease signing, and turning over

the keys, she additionally visited 601 Hudson with Sanieoff, toured each unit individually, and

found comparisons for units, among other things—all of which went beyond her scope as an agent.

60. Meanwhile, Defendant C. Sanieoff had hired a private investigator to follow

Sanieoff, her husband. She discovered Sanieoff’s activities in February 2017, and told Sanieoff of

her findings.

61. On February 17, 2017, at or about 1:37 p.m. EST, Sanieoff left Plaintiff a voicemail,

terminating her employment. The first twenty-four seconds of the voicemail played the following:

Hi Alice. This is Abe. Um. I can’t work with you anymore. I can’t
see you anymore. Can’t talk with you anymore. My wife knows
everything, and she has a private investigator that was following us.
Um. That’s it. You’re fired from Grove. We can’t work together
on anything anymore.

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(emphasis added).

62. As a direct result of Sanieoff’s inability to have a personal relationship with

Plaintiff due to his wife’s findings, he terminated Plaintiff’s employment, including the work she

was doing on behalf of 610 Hudson Street, that very same day because she could no longer be used

as an object of his sexual desires, despite her impeccable work performance at 25 Grove and 601

Hudson.

63. Plaintiff was denied employment, career opportunities, exclusivity rights to future

apartments, including 601 Hudson, and other benefits that other similarly situated brokers would

be afforded by landlords based on their performance, due to Sanieoff’s sexual discrimination and

harassment of Plaintiff.

64. Not only did Plaintiff lose her job without merit, but C. Sanieoff began threatening

Plaintiff with both voicemails and text messages, beginning with the second half of Sanieoff’s

February 17, 2017, 1:37 p.m. recording.

65. C. Sanieoff was in earshot of the voicemail recording when Sanieoff terminated

Plaintiff’s employment, and approximately twenty-five seconds into the recording, she threatened

Plaintiff.

66. Immediately after hearing this voicemail, on February 17, 2017, Plaintiff took down

the active re-listing for Apartment #5 at 25 Grove, for which she had been instructed to relist on

January 26, 2017 by Sanieoff.

67. The phone calls and text messages from C. Sanieoff and her mother, Defendant E.

Sabetfard, to Plaintiff were frequent and incessant. C. Sanieoff and E. Sabetfard were so nefarious

in their recordings that Plaintiff was afraid to leave her apartment. Phone calls with serious threats

started on February 17, 2017, and text messages of the same nature began on February 18, 2017.

68. E. Sabetfard, C. Sanieoff’s mother, left Plaintiff at least ten (10) voicemails over

the course of a two-and-a-half-week period.

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69. In these messages, E. Sabetfard boasted of her power and threatened Bahar’s well-

being.

70. On February 18, 2017, Plaintiff received a text message from C. Sanieoff, wherein

she states her numerous affiliations with NYPD officers who owe her a favor. She also warns of

so many people watching Bahar 24 hours a day.

71. These voicemails and text messages were full of vile threats and insults and were

intended to terrorize, intimidate and harass Plaintiff.

72. Plaintiff was unable to sleep, eat, work, or do anything normal anymore, upon

receiving threat after threat after threat. Plaintiff’s life was changed immediately and drastically.

73. Plaintiff took every word C. Sanieoff and E. Sabetfard said very seriously and she

is still afraid; she has nightmares and cannot sleep at night because of her threats.

74. In addition to the threatening voice and text messages, C. Sanieoff and E. Sabetfard

interfered with Plaintiff’s job by harassing her supervisors and pretending to be clients; L.

Sabetfard and M. Sabetfard followed Plaintiff; C. Sanieoff hired a private investigator to watch

and record Plaintiff; C. Sanieoff also hired a threatening African-American of husky build to

intimidate and harm Plaintiff, as was threatened in the February 20, 2017, 9:06 a.m. voicemail;

and Sanieoff admitted to Plaintiff’s real estate agency that he had a business and personal

relationship with her, in order to endanger her job. All of these actions were done while Plaintiff

had an effective order of protection against C. Sanieoff, who spearheaded this campaign against

Plaintiff.

75. Plaintiff filed a police report on February 18, 2017 and C. Sanieoff was arrested in

March 2017. Plaintiff obtained her first order of protection against C. Sanieoff in April 2017, in

effect until July 12, 2017.

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76. C. Sanieoff stated in one of her voicemails that Plaintiff “will never have another

listing” as most of the landlords live in Great Neck and they all know each other. Defendants’ plan

was to spread rumors about Plaintiff, so she would lose the opportunity to make a living.

77. C. Sanieoff and E. Sabetfard were calling Plaintiff’s managers approximately

twenty (20) times a day in February and March 2017, bothering them and complaining in order to

get Plaintiff fired.

78. On or about March 1, 2017, Plaintiff’s manager called Plaintiff and asked her to

come to the office the next day at 8:30 a.m. so they could talk.

79. Plaintiff’s manager decided to give Plaintiff another chance if the phone calls

stopped. Defendants embarrassed Plaintiff so she could not show her face at work.

80. Moreover, E. Sabetfard was sending Plaintiff emails pretending to be a client who

wanted to see an apartment; she was emailing Plaintiff from fake email accounts and texting and

calling Plaintiff from fake numbers, as will be revealed in the course of discovery.

81. Defendants were trying to do everything possible for Plaintiff not to work so she

would not be able to pay her bills and be forced to leave New York and return to her home country

of Israel, as E. Sabetfard alluded to in one of her many voicemails.

82. Moreover, C. Sanieoff sent her brothers L. Sabetfard and M. Sabetfard to follow

Plaintiff everywhere by foot or by car, especially in her neighborhood, monitor her activities, and

intimidate her so Plaintiff could not leave her apartment or go to work. Plaintiff saw them circling

around her all the time.

83. Every time that Plaintiff left her apartment, she could see C. Sanieoff’s brothers

circling around Plaintiff.

84. L. Sabetfard and M. Sabetfard knew Plaintiff’s route in the morning, as she would

leave her apartment and walk by Starbucks on W 10th Street and Hudson Street to go to her office.

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85. On March 3, 2017 at or about 9:30 a.m., L. Sabetfard started following Plaintiff,

who was right next to Starbucks. This Starbucks is across the street from the New York City Police

Department – 6th Precinct station at 233 W 10th Street, New York, New York. Plaintiff got scared

when she saw L. Sabetfard right behind her and decided to cross the street and stand in front of the

police station until he walked away.

86. L. Sabetfard walked to the corned and then looked back to see if Plaintiff was still

there, but she was hiding behind a car, so he did not see her.

87. That same morning, when Plaintiff finally went to the office at or about 10:30 a.m.,

she called the police to tell them that C. Sanieoff’s brothers were following her.

88. The police station has cameras and were able to record Plaintiff hiding from L.

Sabetfard, and they could see him walking behind her.

89. Further, C. Sanieoff was sending private investigators to follow and watch Plaintiff

all the time when Plaintiff left her apartment.

90. C. Sanieoff had said that she had numerous NYPD officers, whom all owed her

favors, and private investigators working for her, in her communications to Plaintiff.

91. C. Sanieoff and E. Sabetfard sent Jerry Breen (“Breen”), a private investigator, to

approach Plaintiff on June 4 and July 11, 2017, in spite of Plaintiff having an order of protection.

92. Jerry Breen was sent to make conversation with Plaintiff, pretending to be friendly

and get to know Plaintiff so C. Sanieoff could obtain personal information about Plaintiff.

93. Breen wanted to know if Plaintiff lived in her apartment without her parents, where

she liked to go out, and whether she worked from home or went to the office.

94. Breen offered Plaintiff to have a drink, all while recording everything that she said.

95. Plaintiff received texts about a week later from E. Sabetfard pretending to be “John”

with information that she only gave to Breen. Because of this, Plaintiff knew that she was being

recorded during her conversation with Breen.

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96. Later, Breen started telling Plaintiff repeatedly “I want to kiss you, I don’t want to

fuck you… You like to have fun, right?... What kind of fun, drugs? … I’m looking at your breast!”

He was repeating that on purpose to get Plaintiff’s reaction and make her feel like that was all that

she was good for, as he was directed to do by Defendants.

97. Breen was trying to put words in Plaintiff’s mouth. He was on a mission to make

her look bad, cheap, dirty, and a whore so Defendants could spread rumors about her and destroy

Plaintiff’s reputation, so nobody would deal with Plaintiff in her personal or professional life.

98. On July 12, 2017, upon the expiration of her first protective order, and the day after

Breen approached Plaintiff for the second time, Plaintiff obtained another temporary order of

protection, valid until January 11, 2018.

99. In addition, on or about September 1, 2017 at or about 11:45 a.m., Plaintiff observed

a stranger—African-American with a husky build—sitting in front of her building, monitoring

who was coming in and out, just as C. Sanieoff had threatened in her February 20, 2017, 9:06 a.m.

voicemail. Plaintiff has lived in the same apartment for ten (10) years and nobody had ever done

that before, except for Defendants. Plaintiff has a picture of this stranger sitting in front of her

building from this date and time.

100. On or about September 14, 2017, Plaintiff’s real estate agency, Bond, received a

letter from Sanieoff’s counsel admitting that Sanieoff was in a professional and personal

relationship with Plaintiff, and that upon his termination of both personal and business

relationships, she engaged in retaliatory tactics to embarrass him in front of his family. This letter

was written and sent in an effort to turn the tables against Plaintiff about who was harassing whom,

put her in trouble at her job, and make her lose her job so she would not have the opportunity to

make a living.

101. As the voicemail from February 17, 2017, 1:37 p.m. shows, Sanieoff terminated his

business and personal relationship simultaneously in the same twenty-four-second period, and

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instantly, his wife C. Sanieoff chimed in and threatened Plaintiff. The harassment began here by

Defendants.

102. During the course that these harassing events were taking place, Plaintiff filed

police reports after C. Sanieoff was arrested and Plaintiff contacted the District Attorney many

times due to Defendants’ violation of the order of protection. However, upon information and

belief, nobody cared or wanted to help Plaintiff because of Defendants’ power, wealth, and

influence, all of which is being investigated as, upon information and belief, improper influence

was exerted.

103. The whole Defendant family worked extremely hard to destroy Plaintiff’s life and

her reputation.

104. All of Defendants’ actions changed Plaintiff’s life completely. First, Sanieoff took

advantage of Plaintiff, and then, the rest of the family attacked Plaintiff like an animal.

105. Plaintiff is still having a very hard time as she cannot go back to her normal life and

is undergoing treatment, which is expected to last at least one (1) year or more.

106. Plaintiff always watches her back when she walks around because she is afraid.

107. Plaintiff goes to a therapist to try to heal, but it will take a long time.

AS AND FOR A FIRST CAUSE OF ACTION

(Intentional Infliction of Emotional Distress)

108. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

101 above, as fully set forth herein.

109. As detailed herein, Defendants jointly and severally have engaged in (i) extreme

and outrageous conduct; with the (ii) intent to cause, or disregard of a substantial probability of

causing, severe emotional distress; (iii) and there is a causal connection between the conduct and

injury; and there has been (iv) severe emotional distress.

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110. Defendants have intentionally and recklessly engaged in the extreme and

outrageous conduct described above for the sole purpose of causing severe emotional distress and

harm.

111. By engaging and continuing to engage in the actions and conduct described above,

Defendants’ have caused significant harm, including extreme emotional distress and anxiety to

Plaintiff.

112. As a result of said emotional distress that has been caused by Defendants, Plaintiff,

for the first time, has been forced to undergo psychiatric treatment and has been prescribed a litany

of anti-depressant and anti-anxiety medications simply so that she can function in her day-to-day

life.

113. Nevertheless, even with the medical treatment and medications, Plaintiff has been

unable to resume her normal life free from extreme emotional distress and anxiety, which she

enjoyed prior to the Defendants’ intentionally engaging in a malicious campaign of extreme and

outrageous harassment, lies, and intimidation against her, as described above.

114. At all times described herein, Defendants were aware of the harm and severe

emotional distress that their actions were causing Plaintiff and yet, they continued to engage in the

conduct described above without any justification based in law or any bounds of decency, simply

because they have the wealth and power to do so without any perceived repercussions—even

violating orders or protection with impunity, which is being investigated.

115. Plaintiff also continues to suffer from extreme emotional distress and anxiety as a

direct result of Defendants’ intentional conduct, as described above.

116. Furthermore, Plaintiff continues to fear for her safety, which only serves to add to

and heighten the emotional distress and anxiety from which she is suffering, as a direct result of

being constantly watched and stalked by Defendants and their private security detail.

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117. By reason of the foregoing, Defendants are liable to Plaintiff for compensatory and

punitive damages for the harm she has suffered and continues to suffer as a direct result of

Defendants’ intentional and ongoing actions described above, the remedy of which shall be

determined as trial, but in no event, should be less than ten million dollars ($10,000,000).

AS AND FOR A SECOND CAUSE OF ACTION

(Negligent Infliction of Emotional Distress)

118. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

111 above, as fully set forth herein.

119. As described above, Defendants’ conduct jointly and severally and actions directed

towards Plaintiff created an unreasonable risk of causing Plaintiff emotional distress.

120. At all relevant times, Defendants were aware of the emotional distress they were

causing Plaintiff and the fact that she was suffering from severe depression and anxiety as a result.

Nevertheless, Defendants, hired private security to follow and harass the Plaintiff, all of which has

been described above. They also engaged in the extreme and outrageous conduct described above,

including the threatening text and voice messages..

121. Plaintiff feared and continues to fear for her safety as a result of being followed and

harassed by Defendants and Defendants’ private security, which only serves to cause her additional

emotional distress.

122. Based on all of the above described circumstances, Defendants’ conduct of

harassment and having the Plaintiff followed by Senioff’s private security created an unreasonable

risk of causing her severe emotional distress and anxiety.

123. As has been described above, Defendants were aware of Plaintiff’s emotional state

as a result of all of their actions and conduct so that it was clearly foreseeable that having Plaintiff

followed and/or harassed by Defendants and a private security would cause her greater emotional

distress.

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124. Defendants’ conduct, as described above, has caused Plaintiff to fear for her safety

and wellbeing, which has caused and continues to cause Plaintiff severe emotional distress.

125. By reason of the foregoing, Defendants are liable to Plaintiff for compensatory and

punitive damages for the harm she has suffered and continues to suffer as a direct result of

Defendants’ actions described above, the remedy of which shall be determined at trial, but in no

event should be less than ten million dollars ($10,000,000).

AS AND FOR A THIRD CAUSE OF ACTION

(Prima Facie Tort)

126. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

119 above, as fully set forth herein.

127. Defendants jointly and severally engaged in those acts detailed above, and as will

be revealed in the course of discovery for the purpose of intentionally inflicting harm, to

Defendants without excuse or justification by and through a series of acts, that, in this case were

not even lawful even if they believed their acts to be lawful.

128. By reason of the foregoing, Defendants are liable to Plaintiff for compensatory,

special, and punitive damages.

AS AND FOR A FOURTH CAUSE OF ACTION

(Battery)

129. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

128 above, as fully set forth herein.

130. As described above, Defendant Abraham touched Bahar’s vagina, without her

consent.

131. Defendant Abraham intended to make the contact, as he was touching himself at

the same time. This conduct is the very definition of offensive and caused Bahar to suffer.

132. By reason of the foregoing, Defendant Abraham is liable to Plaintiff for

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compensatory, special, and punitive damages.

AS AND FOR A FIFTH CAUSE OF ACTION

(Aiding and Abetting Battery)

Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through 132 above,

as fully set forth herein.

130. As described above, Defendant Abraham touched Bahar’s vagina, without her

consent.

131. Defendant Abraham intended to make the contact, as he was touching himself at

the same time. This conduct is the very definition of offensive and caused Bahar to suffer.

132. Defendant 25 Grove Street did nothing to stop the battery by Abraham despite

having knowledge of harassment campaign against Bahar. They own the property located at 25

Grove Street, were party to the exclusive rental agreements, and Abraham was managing member

of 25 Grove Street during all relevant time periods herein.

132. By reason of the foregoing, Defendant 25 Grove Street is liable to Plaintiff for

compensatory, special, and punitive damages.

AS AND FOR A FIFTH CAUSE OF ACTION

(Sexual Discrimination Against Employee Under New York Human Rights Law)

133. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through 132

above, as fully set forth herein.

134.Pursuant to Section 296(I) of the Executive Law, it is an unlawful discriminatory

practice for an employer, because of the sex of an individual, to discriminate against any such

individual in compensation or in terms, conditions, or privileges of employment.

135. Defendants Sanieoff and Sani Group a/k/a 25 Grove have engaged in an unlawful

discriminatory practice under Section 296(I) of the State Human Rights Law by failing to promote

Plaintiff, and significantly reducing her assignments and responsibilities on the basis of her sex.

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136. As a result of the foregoing unlawful discriminatory practices, Plaintiff has suffered

and will continue to suffer damages in an amount to be determined, but in no event should be less

than ten million dollars ($10,000,000).

AS AND FOR AN SIXTH CAUSE OF ACTION

(Sexual Harassment of Independent Contractor under New York Human Rights Law)

137. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through 136

above, as fully set forth herein.

138. Pursuant to Section 296-d of the Executive Law, it is an unlawful discriminatory

practice for an employer to permit sexual harassment of non-employees in its workplace. An

employer may be held liable to a non-employee who is a contractor, subcontractor, vendor,

consultant or other person providing services pursuant to a contract in the workplace or who is an

employee of such contractor, subcontractor, vendor, consultant or other person providing services

pursuant to a contract in the workplace, with respect to sexual harassment, when the employer, its

agents or supervisors knew or should have known that such non-employee was subjected to sexual

harassment in the employer’s workplace, and the employer failed to take immediate and

appropriate corrective action.

139. Defendants Sanieoff and Sani Group a/k/a 25 Grove have engaged in an unlawful

discriminatory practice under Section 296-d of the State Human Rights Law because Sanieoff, as

Plaintiff’s direct supervisor and the principal of Sani Group/owner of 25 Grove Street LLC,

sexually harassed Plaintiff during her employment as an independent contractor at 25 Grove, and

failed to take immediate and appropriate corrective action.

140. As a result of the foregoing unlawful discriminatory practices, Plaintiff has suffered and

will continue to suffer damages in an amount to be determined, but in no event should be less than

ten million dollars ($10,000,000).

AS AND FOR A SEVENTH CAUSE OF ACTION

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(Employment Discrimination and Retaliation)

1. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

140 above, as fully set forth herein.

2. Pursuant to Section 296(7) of the Executive Law, it is unlawful discriminatory

practice for any person engaged in any activity to which this section applies, to retaliate or

discriminate against any person because she has opposed any practices forbidden under this Article

or because she has filed a complaint, testified, or assisted in any proceeding under this Article.

3. Defendant Sanieoff and Sani Group a/k/a 25 Grove have engaged in unlawful

discriminatory practice under Section 296(7) of the Human Rights Law by creating a hostile and

intimidating atmosphere and engaging in a pattern of harassment and intimidation subsequent to

the time that Plaintiff brought this matter to its attention.

4. As a result of the foregoing unlawful discriminatory practices, Plaintiff has suffered

and will continue to suffer damages in an amount to be determined, but in no event should be less

than ten million dollars ($10,000,000).

AS AND FOR A EIGHTH CAUSE OF ACTION

(Sexual Discrimination Against Employee under New York City Administrative Code)

5. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

144 above, as fully set forth herein.

6. Pursuant to Chapters 1 through 7 of Title 8 of the Administrative Code of the City

of New York, Section 8-101 et seq., it is an unlawful discriminatory practice for any person,

because of the sex of any individual, to discriminate against any such individual in compensation

or in terms, conditions, or privileges of employment, or to retaliate or discriminate against any

person because she has opposed any practice forbidden under this Article or because she has filed

a complaint, testified, or assisted in any proceeding under this Article.

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7. As a result of the aforementioned violations of the Administrative Code, Plaintiff

seeks, in addition to other damages, punitive damages in the amount to be determined, but in no

event should be less than ten million dollars ($10 million), in accordance with Chapter 5, ¶ 8-502

of the Administrative Code.

AS AND FOR A NINTH CAUSE OF ACTION

(Intentional Interference with Contractual Relationship)

8. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

147 above, as fully set forth herein.

9. As discussed above, C. Sanieoff and E. Sabetfard were calling Plaintiff’s

managers approximately twenty (20) times a day in February and March 2017, bothering them

and complaining in order to get Plaintiff fired.

10. Sanieoff had his counsel send a letter to Bond admitting that Sanieoff was in a

professional and personal relationship with Plaintiff, and that upon his termination of both

personal and business relationships, she engaged in retaliatory tactics to embarrass him in front

of his family.

11. This letter was written and sent in an effort to turn the tables against Plaintiff

about who was harassing whom, put her in trouble at her job, and make her lose her job so she

would not have the opportunity to make a living.

12. Defendants knew of Bahar’s contract with Bond and intentionally interfered with

same, causing Plaintiff to suffer damages.

13. By reason of the foregoing, Defendants are liable to Plaintiff for compensatory,

special, and punitive damages.

AS AND FOR A TENTH CAUSE OF ACTION

(Tortious Interference with Prospective Economic Advantage)

14. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

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153 above, as fully set forth herein.

15. As discussed above, C. Sanieoff and E. Sabetfard were calling Plaintiff’s

managers approximately twenty (20) times a day in February and March 2017, bothering them and

complaining in order to get Plaintiff fired.

16. Sanieoff had his counsel send a letter to Bond admitting that Sanieoff was in a

professional and personal relationship with Plaintiff, and that upon his termination of both personal

and business relationships, she engaged in retaliatory tactics to embarrass him in front of his

family.

17. This letter was written and sent in an effort to turn the tables against Plaintiff

about who was harassing whom, put her in trouble at her job, and make her lose her job so she

would not have the opportunity to make a living.

18. Defendants knew of Bahar’s relationship with Bond and intentionally,

Maliciously, and unlawfully interfered with Bahar’s business relationship with Bond, causing

Plaintiff to suffer damages.

19. By reason of the foregoing, Defendants are liable to Plaintiff for compensatory,

special, and punitive damages.

WHEREFORE, Plaintiff demands judgment against Defendants jointly and severally as

follows:

A) On the First Cause of Action, compensatory and punitive damages against

Defendants in an amount to be determined at trial, but in no event less than

$10,000,000;

B) On the Second Cause of Action, compensatory and punitive damages against

Defendants in an amount to be determined at trial, but in no event less than

$10,000,000;

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C) On the Third Cause of Action, compensatory damages against Defendants in an

amount to be determined at trial;

D) On the Fourth Cause of Action, compensatory and punitive damages against

Defendants in an amount to be determined at trial;

E) On the Fifth Cause of Action, compensatory damages against Defendants in an

amount to be determined at trial;

F) On the Sixth Cause of Action, compensatory damages against Defendants in an

amount to be determined at trial;

G) On the Seventh Cause of Action, compensatory damages and damages for mental

anguish, pain, and suffering against Defendants in an amount to be determined at

trial, but in no event less than $10 million;

H) On the Eighth Cause of Action, compensatory damages and damages for mental

anguish, pain, and suffering against Defendants in an amount to be determined at

trial, but in no event less than $10 million;

I) On the Ninth Cause of Action, compensatory damages and damages for mental

anguish, pain, and suffering against Defendants in an amount to be determined at

trial, but in no event less than $10 million;

J) On the Tenth Cause of Action, in addition to other damages, punitive damages in

the amount of $10 million;

K) On the Eleventh Cause of Action, in addition to other damages, punitive damages

in the amount of $10 million;

L) On the Twelfth Cause of Action, in addition to other damages, punitive damages in

the amount of $10 million;

M) All claims, costs, fees and expenses, including reasonable attorneys’ fees incurred

by Plaintiff in this action;

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N) Punitive damages on all causes of action;

O) For such other and further relief as the Court may deem just and proper;

P) Expedited Discovery including electronic discovery of all Defendants’ cell phones,

computers, phone records, board of director meetings for the Sani Group, insurance

policies, prior incident reports, phone records, payments to private detectives and

New York City police officers, and the six-foot-four person referenced in the

previously cited voicemail, and the personal and corporate tax returns of all

Defendants for two years, subject to a confidentiality and protective order.

DEMAND FOR JURY TRIAL

Plaintiff hereby demands a trial by jury on all issues and claims so triable.

Dated: New York, New York

April 1, 2019

Respectfully Submitted,

NEIL L. POSTRYGACZ
ATTORNEY AT LAW, P.C
Neil L. Postrygacz
By: Neil L. Postrygacz
175 Varick Street
New York, New York 10014
p 212-392-4945

Attorneys for Plaintiff

TO: Joseph L. Buckley

SILLS CUMMIS & GROSS, P.C.
101 Park Avenue, 28th Floor
New York, NY 10178
Attorneys for Defendants

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