Court Docs

FILED: NEW YORK COUNTY CLERK 02/06/2020 11:06 AM INDEX NO.
150328/2018
NYSCEF DOC. NO. 83 RECEIVED NYSCEF: 02/06/2020
SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
-------------------------------- ----------------------------X
ALICE BAHAR,
AMENDED VERIFIED
Plaintiff, COMPLAINT
-against- Index No. 150328/2018
ABRAHAM SANIEOFF; THE SANI GROUP a/1da

25 GROVE STREET LLC; CHARLET SANIEOFF;
ELIZA SABETFARD; LEOR SABETFARD; and Corrected
MATTHEW SABETFARD,
Defendants.
--------------------------------------------- --------x
Plaintiff ALICE BAHAR, individually through her attorneys, DELINCE LAW PLLC,
complaining of Defendants, ABRAHAM SANIEOFF; THE SANI GROUP a/lda 25 GROVE
STREET LLC; CHARLET SANIEOFF; ELIZA SABETFARD; LEOR SABETFARD; and
MAtTHEW SABETFARD, alleges as follows:
INTRODUCTION
1. This Action arises out of the intentional, premeditated, and systematic campaign of
harassment to which Plaintiff was subjected by Defendants, ABRAHAM SANIEOFF, THE SANI
GROUP a/lda GROVE STREET LLC, CHARLET SANIEOFF, ELIZA SABETFARD, LEOR
SABETFARD, and MATTHEW SABETFARD. Plaintiff performed real estate brokerage services
on behalf of Defendants Abraham Sanieoff and 25 Grove Street LLC. In the first few months of
Plaintiff's employment, in 2016, Plaintiff was heavily pressured, and eventually coerced, into
beginning a sexual relationship with Defendant Abraham Sanieoff, whom Plaintiff imew to be
married. Plaintiff and Defendant Abraham Sanieoff carried on an intimate relationship until in or
around February 2017, when Defendant Abraham Sanieoff's wife, Defendant Charlet Sanieoff,
discovered her husband's affair. Immediately thereafter, Defendant Abraham Sanieoff terminated
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FILED: NEW YORK COUNTY CLERK 02/06/2020 11:06 AM INDEX NO. 150328/2018
Plaintiff's employment, and Defendant Charlet Sanieoff, as well as her mother, Defendant Eliza
Sabetfard, and her two brothers, Leor and Matthew Sabetfard, engaged in a course of conduct
designed to harass, intimidate, and humiliate Plaintiff, and traumatized Plaintiff, causing her severe
emotional distress.
P_ARTIES AND VENUE
2. Plaintiff, ALICE BAHAR (hereinafter referred to as "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
Sanieoff"
referred to as "Defendant Abraham or "Defendant A. 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.
7. Upon information and belief, Defendant CHARLET SANIEOFF (hereinafter
Sanieoff"
referred to as "Defendant Charlet or "Defendant C. Sanieoff"), the wife of Defendant
Abraham 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, Defendant Charlet Sanieoff's mother, Defendant
Sabetfard"
ELIZA SABETFARD (hereinafter referred to as "Defendant Eliza or "Defendant 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, Defendant Charlet Sanieoff's brother, LEOR
Sabetfard"
SABETFARD (hereinafter referred to as "Defendant Leor or "Defendant L.
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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, Defendant Charlet Sanieoff's brother MATTHEW
Sabetfard"
SABETFARD (hereinafter referred to as "Defendant Matthew or "Defendant 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 THE SANI GROUP a/k/a 25 GROVE
STREET LLC (hereinafter referred to as "Defendant 25 Grove Street"), presently, and at all times
relevant hereto, is a corporation doing business in the State of New York, which, among other
things, owns property located at 25 Grove Street, New York, New York 10014, and has an office
located 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.
BACKGROUND
13. Plaintiff received her New York real estate license since 2012, and had been
working as a licensed agent with Bond New York Properties, LLC ("Bond") since 2013.
14. Plaintiff held both open listings and maintained exclusive listings with several
landlords in the West Village, New York.
15. Defendant Abraham Sanieoff is the owner and Managing Member of Defendant 25
Grove Street LLC, which owns the building located at 25 Grove Street, New York, New York.
16. On or about May 18, 2016, Plaintiff met Defendant Abraham Sanieoff. Plaintiff
was introduced to Defendant A. Sanieoff by Svetozar Zukovic (hereinafter referred to as "Zuko"),
the superintendent of a building located near 25 Grove Street, whom she had known for many
years prior to the events giving rise to this Action.
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17. A voluminous series of text messages and other written communications between
the Parties reveals that Defendant A. Sanieoff began pressuring Plaintiff into a sexual relationship,
and that, in or around late-July 2016, Plaintiff relented to the pressure.
18. When Defendant Charlet Sanieoff discovered her husband's infidelity, on or about
February 17, 2017, Defendant C. Sanieoff, with the assistance of Eliza Sabetfard, Leor Sabetfard,
and Matthew Sabetfard, inflicted upon Plaintiff severe mental pain and anguish through a
deliberate and malicious campaign of harassment and intimidation. And Defendant Abraham
Sanieoff terminated Plaintiff's employment.
FACTS
19. On or about May 18, 2016, Plaintiff was introduced to Defendant Abraham
Sanieoff by Zuko, the superintendent of 110 Bedford Street, owned by Defendant A. Sanieoff,
whom Plaintiff had known for many years.
20. Plaintiff met Defendant A. Sanieoff, at or around 1:30 PM EST, in front of
Defendant A. Sanieoff's building, 25 Grove Street. Defendant A. Sanieoff took Plaintiff inside to
view the rental apartment, spoke about the price of the unit, and signed an exclusive rental
5.1
agreement giving only to Plaintiff the listing to secure rental for apartment no.
21. Plaintiff had rented, within two days, apartment no. 5, and thereafter Defendant
Abraham Sanieoff signed a second Exclusive Rental Agreement giving Plaintiff the listing to
apartment no. 12.
22. Defendant A. Sanieoff went on to give Plaintiff approximately four additional
exclusive rental agreements, for an approximate total of nine exclusive apartment rental listings.
1
Although the exclusive rental agreements to which Plaintiff refers above, and throughout this Amended Complaint,
were between Defendant Abraham Sanieoff and BOND New York Properties, LLC, the agreements were signed in
the presence of Plaintiff, as the agent on behalf of BOND New York Properties, LLC.
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Plaintiff and Defendant A. Sanieoff continued to work together until on or about February 17,
2017.
23. In or around July 2016, after Plaintiff had finished showing an apartment in 25
2.2
Grove Street, Defendant Abraham Sanieoff told Plaintiff to meet him in apartment no. Plaintiff
complied with the instruction from her boss, and entered apartment no. 2 to find Defendant A.
Sanieoff relaxing with a bottle of Johnny Walker Blue.
24. Defendant A. Sanieoff poured, and Plaintiff drank, about 2-3 glasses of whiskey
before Defendant A. Sanieoff induced Plaintiff into having sex with him.
25. Although Plaintiff did not wish to enter into or continue a sexual relationship with
her boss, Defendant A. Sanieoff relentlessly pursued Plaintiff, bending Plaintiff's will to his own,
until she broke down, stopped protesting, and participated in the relationship.
26. On or about February 17, 2017, Defendant Abraham Sanieoff terminated Plaintiff's
present and future services, stating on Plaintiff's voicemail, at or around 1:37 PM EST:
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 and that's it. You're fired from Grove. We can't work together
on anything anymore.
27. In the same voicemail, approximately twenty-five seconds into the
recording, Defendant Charlet Sanieoff warns Plaintiff:
If you breath passed my husband, look towards my husband, text my

husband, open your pussy up one more time to my husband, I will
physically come there and take care of it myself ... You're a
homewrecker, a slut, a whore, and your is going to come one day.
original).3
(Voicemail 26) (grammatical errors in
2 Abraham
Upon information and belief, apartment no. 2 was an empty unit in 25 Grove Street, used by Defendant
pad."
Sanieoff as a "bachelor
3
Although others did not, we employ the actual words, albeit with distaste, for the purpose of reflecting precisely
the facts of the case. The use of such vile language serves, in particular, to describe accurately the severity of the
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28. Also on February 17, 2017, at or around 3:32 PM EST, Defendant Eliza Sabetfard
threatened:
... I am going to drag you down and I am going to step at your throat
... If I hear or if I see that you are continuing to [inaudible] him ...
I am going to do something that you will be regret it for the rest of
your life, and I am very serious. I am going to do something that
even your face is not going to be the way that it should be. I am
going to do something that you are going to regret it in the
community, in your office, in the Facebook, in the whole world ...
No matter what is takes me, I am going to stop this. I am serious, I
am doing something that you can never ever have a face in the pretty
looks that you have [inaudible]. You're going to hide yourself for
the rest of your life because your face is not going to look the way
that anybody can't see ...
(Voicemail 27) (grammatical errors in original).
29. And then, again on February 17, at or around 6:01 PM EST, Plaintiff received from
Defendant Eliza Sabetfard another voicemail stating:
You don't have to call me back. I left you a message, I am going to
leave you a message every day ... I am going to destroy your life
that you can never even imagine. I am going to ruin your life, in your
office, in the community, in every possible way that you can
imagine. You do not know how powerful I am. I am going to do
something that you never experienced it before... I am going to
follow you without you knowing it every single minute of your life.
I am going to make you something that you wish you never been
born...
30. On or about February 18, 2017, at or around 7:46 AM EST, Defendant Charlet
Sanieoff sent to Plaintiff, with the intent to terrorize and permanently traumatize Plaintiff, an
words'
behavior to which Plaintiff was subjected significant power to offend,
and not to trivialize the insult, and
belittle.
See Turley v. ISG Lackawanna, Inc., 774 F. 3d 140, 148 n. 5 (2d Cir. 2014) (quoting Matusick v. Erie Cnty.
Water Auth., 757 F.3d 31, 38 n. 3 (2d Cir. 2014)) (internal and external quotation marks omitted).
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ominous text message. For example, Plaintiff was alarmed and gravely intimidated when she read
from Defendant C. Sanieoff:
I have so many people watching you 24 hours a day, you have no
idea. I have 4 affiliations with NYPD that all owe me favors. Trust
me I will take care of you...All my private investigators are tracking
when you're awake asleep earing and losing your mind. Good. I
hope you suffer each day a little bit more.
31. In the same text message to Plaintiff, Defendant C. Sanieoff makes specific and
unequivocal threats of harm to Plaintiff's professional reputation and to cause Plaintiff public
humiliation:
I will send out a mall email to all of your colleagues at the brokerage.
Your boss your employees your colleagues showing them exactly

the slut that you are. With context showing you fucking my husband
and sucking his dick.
32. The message ends by Defendant C. Sanieoff, for her own personal amusement and
enjoyment, gleefully taunting Plaintiff:
But you see, THIS. IS. JUST. THE. BEGINNING! ... The phone
calls and email messages will be going out immediately after 3 days
if I don't see [items of jewelry gifted to Plaintiff by Defendant
Abraham Sanieoff].
Good Morning, Buttercup! Let the games begin!
33. Later on, at or around 9:30 AM EST, Defendant Eliza Sabetfard stated to Plaintiff,
day."
"just a reminder, I am on you 24/7... We are on you 24 hours a (Voicemail 30).
34. Upon receiving Defendant E. Sabetfard's February 18 voicemail, at or around 12
PM EST, Plaintiff went to the 6th Precinct, located at 233 West 10th Street, New York, NY 10014,
to report the behavior of Defendants Charlet Sanieoff and Eliza Sabetfard, behavior which Police
Officer Kreuman classified as the crime of aggravated harassment. Plaintiff was told by the police
time."
that she had to wait because "these things take
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35. On or about February 19, 2017, at or around 10:02 AM EST, Defendant Eliza
Sabetfard threatened Plaintiff:
...This is a wakeup call again for you. Stay away from him if you
know what is good for you. We said it ten times, we'll say it every
single day. You've been watched all the time....You will get this
call again and again.
(Voicemail 31).
36. Again on February 19, at or around 10:58 AM EST, Defendant E. Sabetfard,
ostensibly forgetting to include in her earlier barbaric diatribe threats related to Plaintiff's return
of small jewelry items gifted to her by Defendant Abraham Sanieoff, left Plaintiff another
voicemail:
One more thing, you home breaker prostitute. All the gifts that you
have received, you packed it, put it in a box, leave it at the front desk
or the secretary, with the name of the person as a pickup Sam, and I
will pick it up in 48 hours. If you do not do that, it means that you
been paid by being a prostitute, a whore, with a old, fat, ugly whore
that any person can fuck and you be paid for that...
37. At or around 2:59 PM EST, Defendant Charlet Sanieoff sent to Plaintiff, for the
purpose of violating her sense of a text which in part: and hide- it'll
security, message, read, "Try
everywhere."
Never work. I have eyes on you
38. On or about February 20, 2017, at or around 9:06 AM EST, Plaintiff received from
Defendant Charlet Sanieoff a voicemail, which, through threats of physical violence, placed
Plaintiff in fear of imminent bodily harm:
Trust me when I tell you, you have 24 hours. One day, one day left
to give me back every single gift ... write it down you dumb bitch
[P.O. BOX ADDRESS] ... If it's not in my hand in one day, one
day, I will give him the order to break both of your motherfucking
legs. He's Black, 6 foot 4, and weighs 319 pounds. He'll just make
it look...like an accident; he'll just make it look...like you fell down
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a flight of stairs. You can run, you can hide. My team is watching
you; my team is watching your every move. I'm in charge, let's get
that straight. Yesterday [February 19, 2017] they were 100 feet away
from you, you fucking whore ... Trust me when I tell you my
investigators and undercover NYPD Officers will be following your
every move. You'll never be able to show your face in town to

another client or colleague ... But I got good news for you, you're
'R'
not cut out for brokerage, but Whores Us is looking for you...
(Voicemail 34).
39. At or around 9:10 AM EST, Defendant Charlet Sanieoff threatened to kill Plaintiff
in a text message: "Your worst days are ahead of you... Mail all the gifts- you've had enough
warnings...24 before you start to cry and for your life - "
[hours] beg
40. At or around 11:16 AM EST, Defendant Eliza Sabetfard followed her daughter's
9:06 AM voicemail with her own villainous message:
...It's a wakeup call for you, honey ... The group of family are
together like a thick rope and protecting him against your slutty, fat,
ugly, old cunt ... Every breath you take, every move that you make,
ten people are watching it...
41. Finally, at or around 8:48 PM EST, Plaintiff received from a client named Eliza a
message through RentHop, asking to be shown available apartment in a number of buildings, one
of which was 25 Grove Street. Plaintiff ignored the messages, but continued to receive them until
at least February 21, 2017, at or around 2:15 PM EST.
42. It is Plaintiff's belief, both now and at the time of occurrence, that Defendants were
trying to learn Plaintiff's whereabouts at any time during the day, presumably for the stated
purpose of allowing Defendants to follow Plaintiff.
43. On or about February 21, 2017, Plaintiff received from Defendants three more
voicemails. In the first voicemail, at or around 12:30 PM EST, Defendant Charlet Sanieoff begins
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by screaming at Plaintiff to mail back to Defendants the gifted items of jewelry, and ends by
making specific threats to destroy Plaintiff's professional reputation and opportunity to procure
business opportunities:
...Don't take it for granted that I haven't blackmailed you yet with
photos and documents and videos from my investigator on an email
blast to your entire BOND real estate office, Alice. Your boss will
know you're a whore, your colleagues; you will never have another
listing again, no one wants a prostitute. You see, he chose me, he
didn't choose you. DON'T TEMPT ME...
(Voicemail 40).
44. Approximately fifteen seconds later, at or around 12:31 PM EST, Defendant
Charlet Sanieoff called back Plaintiff simply to torment her:
You're saving his gifts because you think you're in love with him
still. DO NOT TEMPT ME. I physically will come there, outside of
[Plaintiff's home address]. You think you can move? You could run
anywhere, we're watching you; when you're eating, we are 50, 50
feet away from you...
(Voicemail 41) (emphasis in original).
45. Finally, at or around 8:46 PM EST, Defendant Eliza Sabetfard terrorized Plaintiff
with an R. Kelly song:
You whore ... If we do not receive it [the jewelry items] by

tomorrow, somebody will visit your office...to pick it up... Stay
your fucking big cunt away from him. Every move that you make,
every breath that you take, somebody is watching you. Stay away
from him, you slut.
46. On or about February 22, 2017, at or around 1:31 PM EST, Defendant Eliza
Sabetfard left Plaintiff another voicemail similarly degrading episode of verbal assault. This
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voicemail contains such vulgar and heinous language, for no purpose other than to insult and
herein.4
denigrate Plaintiff, that it has not been reproduced
47. On or about February 22 or 23, 2017, Defendant Eliza Sabetfard repeatedly called
Plaintiff's boss at BOND New York Properties, Ida Hamdan, speaking erratically and in a
threatening manner about Plaintiff. The following day, as a result of Defendant E. Sabetfard's
approximately twenty phone calls harassing Plaintiff's employer, Plaintiff was called into a
meeting with Ms. Hamdan and Brokerage Services Manager Douglas Wagner. Plaintiff was not
terminated from BOND at this time because Plaintiff had had a good relationship with BOND,
since she stated in 2013.
48. On or about February 28, 2017, at or around 5:09 PM EST,
Don't you think for a second you've been forgotten. You think
because you got a restraining order, everything is going to be
forgotten? Not a way in hell... Every move that you make, every
call that you make, its been watching... I take care of you and eat it
for breakfast.
49. Minutes after Plaintiff received this voicemail, at or around 5:18 PM EST, she text
messaged Detective Ryan Glas, with whom she had spoken when she returned to the 6th Precinct
2017,5
to follow up on the first police report that she had filed on February 18, asking whether
4
While all of the voicemails contain language that is the same or similarly vile, the particular voicemail to which we
refer in ¶ 46, voicemail 43, contains only vile language, with no informative or ... , this voicemail no less than the
others illustrates a wanton and deliberate indifference to Plaintiff's well-being and contributed all the same to
Plaintiff's psychological deterioration.
5
The initial conversation between Plaintiff and Detective Glas concluded with Detective
Glas telling Plaintiff that he
would contact Defendant Charlet Sanieoff, and then would call back Plaintiff.
Shortly after this meeting, but on or
before February 28, Detective Defendant Glas called C. Sanieoff, who was out of the country, vacationing, with
Defendant A. Sanieoff, to tell her that Plaintiff formally had filed against her a police report and informally had made
Defendants'
to police several additional complaints about unrelenting harassment and that all contact with Plaintiff
had to cease pursuant to the temporary order of protection that was being issued against her. It is Plaintiff's belief that
Defendant C. Sanieoff told her mother, Defendant E. Sabetfard, that Plaintiff had reported them to the police and had
obtained against them a temporary order of protection.
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anything was being done, since Defendant E. Sabetfard had acknowledged the existence and her
disregard of the impending temporary order of protection. In response, Detective Glas told Plaintiff
that he had assigned her case to his co-worker, Detective Colasuonno.
50. On or about March 3, 2017, at or around 9:30 AM EST pursuant to the numerous
warnings from Defendants Charlet Sanieoff and Eliza Sabetfard, in their February 18 text message
(see ¶ 30), February 18 voicemail (see ¶ 33), February 19 voicemail (see ¶ 35), February 19 text
message (see ¶ 37), February 20 voicemail (see ¶ 38), second February 20 voicemail (see ¶ 40),
February 21 voicemail (see ¶ 44), other February 21 voicemail (see ¶ 45), and February 28
voicemail (see ¶ 48), Plaintiff was at the Starbucks on W. 10th Street and Hudson Street, where
she regularly visits, when she noticed Defendant C. Sanieoff's brother, Defendant Leor Sabetfard,
following closely behind her, on foot. Terrified, Plaintiff ran across the street, into the parking lot
of the New York City Police Department, located at 233 W. 10th Street, and stood in front of the
precinct until Defendant Leor Sabetfard walked passed her. Once Defendant L. Sabetfard reached
the corner of the street, Plaintiff, who had ducked behind a car in the NYPD parking lot, could see
that he turned around and looked back to see whether Plaintiff still was there. When Plaintiff finally
made it to her office, at or around 10:30 AM EST, she called the police to report that Defendant
Leor Sabetfard was following her in public.
51. On or about March 6, 2017, at or around 6:34 PM EST, Plaintiff received from
Defendant Eliza Sabetfard a voicemail, which largely taunts and insults Plaintiff in much the same
way as the February 22 voicemail (see ¶ 46), Defendant E. Sabetfard warns:
...You've been watched every second. Try to get your slutty boots
running around. Somebody was watching you 24 hours, all the

time...You are not even a human, you are an animal. Listen, animal,
there is no name for somebody like you...
Because Plaintiff had not received from Detective Glas a phone call in the week following their first discussion,
Plaintiff texted Detective Glas inquiring about the status of her case.
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(Voicemail 53).
52. Out of fear for her life, Plaintiff left the country on April 11, 2017, and did not
return for three weeks.
53. On or about May 1, 2017, at or around 8:50 AM EST, Plaintiff was on W. 10th
Street and Bleeker Street when she saw a Sabet Group van circling the block.
54. On May 10, 2017, Plaintiff was issued the first Temporary Order of Protection
against Defendants.
55. On or about May 18, 2017, Plaintiff received through StreetEasy a message from
hojatb@gmail.com,6
the email address asking to see an apartment in 70 Grove Street. Again,
Plaintiff believed then, as she does now, that Defendants were trying to determine her location
from where they could follow her.
56. Pursuant to Defendant Abraham Sanieoff's February 17 voicemail (see ¶ 26);
Defendant Charlet Sanieoff's February 18 text message (see ¶ 30), February 19 text message (see
¶ 37), February 20 voicemail (see ¶ 38), February 21 voicemail (see ¶ 44); and Defendant Eliza
Sabetfard's February 20 voicemail (see ¶ 40) and February 21 voicemail (see ¶ 45), on or about
June 4, 2017, at or around 11 AM EST, Plaintiff again was at the Starbucks on W. 10th and Hudson
Street when she was approached by a man whom she now knows to be retired NYPD Detective
Jerry Breen. Breen was sitting on the bench outside of Starbucks when he started talking to Plaintiff
about where she like to go at night and asking her specifically about the bar Employees Only,
which was right across the street from the Starbucks and which Plaintiff always had thought to be
a gay bar; asking her whether she likes to have fun and likes to party; telling her more than one
6
The email address from which Plaintiff was messaged has been traced to Hojatollah Behrooz, a Senior
Transportation and ITS Manager for Tehran Chamber of Commerce, Industries, Mines and Agriculture.
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you" breast."
time, "I don't want to fuck you but I want to kiss and "I'm looking at your Plaintiff
believes now, as she did then, that Jerry Breen was trying to extract from her personal information
about her life in order more effectively to harass and traumatize Plaintiff.
57. Following her first encounter with Jerry Breen, on or about June 10, 2017, at or
"John,"
around 5:44 PM EST, Plaintiff received from whom she now knows to be Defendant Eliza
downtown"
Sabetfard, a text message talking to her about the bar "Unemployment and whether
sleeps.7
she goes out with a lot of guys and whether she remembers everyone with whom she
58. On or about June 11, 2017, Plaintiff returned to the 6th Precinct to file a second
police report, again for conduct which the intake officer, Police Officer Henry, classified as the
Defendants'
crime of aggravated harassment. Plaintiff told Officer Henry about unyielding verbal
threats and harassment, the times when she saw Defendants Leor and/or Matthew Sabetfard
following her movement, and when and what she spoke to Jerry Breen.
59. On or about June 16, 2017, at or around 1:45 PM EST, on the corner of Bleeker
Street and Christopher Street, Plaintiff again observed one of the brothers of Defendant Charlet
Sabetfard,8
Sanieoff, either Leor or Matthew just standing on the corner, watching her.
60. On or about July 11, 2017, at or around 6 PM EST, Plaintiff saw Jerry Breen sitting
on the stairs of a townhouse on Hudson Street between Christopher Street and Barrow Street. As
hello?"
Plaintiff passed by him, Breen asked Plaintiff, "you're not going to say
61. On July 12, 2017, 151aintiff was issued the second Order of Protection against
Defendants.
7
The phone number from which Plaintiff received these text messages on June 10, 2017, was (305) 290-2831,
which we have traced to a non-fixed VOIP number, such as Facetime Audio or Skype. Non-fixed VOIP phone
numbers are not fixed to an account holder's physical address, and commonly are used for spam and fraudulent
activity.
8
Discovery will reveal which Defendant was following Plaintiff on June 16, 2017.
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62. Plaintiff continued to receive at all times anonymous messages from temporary
phone numbers asking about apartment showings. Plaintiff was so terrorized and so fearful that
she could not do her job, which required her to be alone in an apartment with the potential renter.
She became suspicious of and had to inspect closely every she message received both through
residential real estate websites, like RentHop and StreetEasy, and from unknowable phone
numbers claiming to be Plaintiff s old friends.
63. On or about July 27, 2017, at or around 1:58 PM EST, Plaintiff saw Defendants
Leor and Matthew Sabetfard circling around on foot W. 10th Street and Hudson Street.
64. On or about August 27, 2017, Defendants still had not ceased their incessant
harassment, and Plaintiff returned to the 6th Precinct to file against Defendants a third police
report.
65. On or about September 1, 2017, at or around 11:45 AM EST, Plaintiff saw sitting
on the front stairs of her apartment building the large, African American man whom Defendants
had threatened would cause Plaintiff physical and violent injury, in Defendant Charlet Sanieoff s
February 20 voicemail (see ¶ 38) and February 21 voicemail (see ¶ 44), and in Defendant Eliza
Sabetfard's February 22 voicemail (see ¶ 51).
66. On or about September 14, 2017, Defendants attorney at the time, Steve Landy,
sent to Nathan Grass, Managing Director at BOND New York, a letter, sometimes
mischaracterizing, other times misleading and many times flat-out lying about, the facts of the
dispute between Plaintiff and Defendants. Plaintiff effectively was forced to resign from BOND
Defendants'
as a result of letter, sent in violation of the Order of Protection, which disallowed
contact with Plaintiff or Plaintiff s affiliates through any third parties. Plaintiff s coworkers
distanced themselves from her, no one spoke to Plaintiff or wanted anything to do with her, and
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Plaintiff could feel from her superiors a shift in their behavior and attitude towards her, where the
avoidance of and lack of communication with Plaintiff interfered with her ability to do her job.
Plaintiff no longer was welcome by BOND in the office. Furthermore, a letter to Plaintiff's
employer, in furtherance of the harassment and intimidation giving rise to and prohibited by the
Order of Protection, arguably is a violation of the Order of Protection.
67. On or about October 6, 2017, Plaintiff text messaged Katie Coulson, the prosecutor
Defendants'
assigned to Charlet Sanieoff's criminal case, in order to report violations of the Order
of Protection. Plaintiff did not receive a response from Ms. Coulson. On or about October 16,
2017, Plaintiff texted Ms. Coulson again, for the same purpose, but never received a response from
Ms. Coulson.
68. On or about January 12, 2018, Plaintiff received from a woman named "Sarah
Levy"
a Facebook message stating: "Thinking maybe you should remove your Facebook acet after
reading the article about you in the post. #LOWLIFE". Plaintiff previously had been called a
lowlife in one or more voicemails left by Defendant Eliza Sabetfard, and recognized as coming
from Defendant E. Sabetfard this message from Sarah Levy. Additional events constituting
aggravated harassment were committed in 2018, which will be revealed through discovery.
69. On or about April 12, 2019, at or around 5:30 PM EST, Plaintiff sat down at a table
in the same Starbucks, on W. 10th and Hudson, when a man who also sitting at the table started
asking where Plaintiff was from and telling her he knew a person named Ana Bahar. The man
asked Plaintiff whether she was in real estate and whether she had a card because he would be
looking in the near future for an apartment. The man also stated that his business partner had stolen
money from him in London and talked about American legal system, saying the Plaintiff that the
lawyers are much slowed in Europe, not like in the U.S. and how different courts and lawsuits are
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in America. Plaintiff grew uneasy, similarly to how she felt talking to Jerry Breen, and immediately
shut down. Plaintiff left and never got his name.
Denihan"
70. On or about June 4, 2019, at or around 3 PM EST, a man named "Tony
sat down next to Plaintiff at Sweet Corner Bakeshop, located on Hudson Street between Perry
Street and Charles Street, and immediately began telling her that he wants to sell his apartment
and give to Plaintiff the exclusive listing. This man did not ask Plaintiff where she worked or what
she did for a living, yet knew anyway this personal information about Plaintiff's life, specifically,
Plaintiff's goal of obtaining exclusive rental agreements. When Plaintiff asked Mr. Denihan what
it."9
he did for a living, Denihan replied: "I work for the government and can't talk about
71. Also on or about June 4, Plaintiff received through CitiHabitats, the real estate
Defendants'
company at which she worked after conduct caused her to be fired from BOND, from
"Shirley,"
a woman named with the email address as@aol.com, a message stating: "Whose
husband are you after now".
72. On or about July 8, 2019, Plaintiff received from an unknown number belonging to
"Lisa,"
a client named a text message telling Plaintiff that she works for a Jewish developer in
Brooklyn and is looking to move. Plaintiff became suspicious and stopped responding to
communications from this number.
"Lisa"
73. On or about August 14, 2019, texted messaged Plaintiff again, saying, "Hi.
brooklyn?"
You do Plaintiff did not respond.
74. On or about October 13, 2019, at or around 2:48 PM EST, Plaintiff received from
Goodman,"
unidentifiable phone number, by a woman named "Dorothy a text message asking to
be shown available apartments. Plaintiff found the message to be out of the ordinary in the way it
9
Tony Denihan also told Plaintiff that he lived at 1420 York Avenue New York, NY 10012, and that his phone
number is (646) 533-8868.
17 | P a g e
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was written and instinctually attributed to the sender a nefarious intent. If Plaintiff's suspicions
were warranted, which will be revealed through discovery, then this was another violation by
Defendants of the Order of Protection. If Plaintiff's suspicions were not warranted, which also
would be revealed through discovery, then, as a consequence of the fear instilled in Plaintiff by
Defendants, Defendants cost Plaintiff a potential business opportunity.
75. Beginning February 17, 2017 Plaintiff has lived in constant fear. She has not been
able to eat, sleep, work, sit still, relax, or interact with people. Defendants have made to Plaintiff
specific and unequivocal threats of death (see, e.g., ¶ 39) and severe bodily injury (see, e.g., ¶¶ 28,
38). Defendants placed Plaintiff under constant surveillance, exactly as they said they would (see,
e.g., ¶¶ 30, 33, 35, 37-38, 40, 44, 48, 51) and carried out threats to harm Plaintiff's professional
reputation and potential business opportunities (see, e.g., ¶¶ 29, 31-32, 43). At one point, Plaintiff
was too afraid to leave her apartment; she lost ten pounds in ten days.
76. Defendants thought of exactly the right words and the best ways to terrorize and
permanently traumatize and tear apart Plaintiff.
Defendants'
77. As a result of conduct, in or around December 2017, Plaintiff sought
medical treatment. Plaintiff was found to exhibit symptoms insomnia, fearfulness, isolative
behavior, lack of trust, and poor appetite, all of which are ongoing, and was diagnosed with Major
Depressive Disorder, Generalized Anxiety Disorder, and Adjustment Disorder. Plaintiff was
prescribed anti-depressant and anti-anxiety medication, with directions to take each every day, and
instructed to continue individual psychotherapy.
AS AND FOR A FIRST CAUSE OF ACTION

(Intentional Infliction of Emotional Distress)
78. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through
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77 above, as fully set forth herein.
79. 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) there is a causal connection between the conduct and
injury; and there exists (iv) severe emotional distress.
80. 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.
81. 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.
82. 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.
83. 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
Defendants'
enjoyed prior to the intentionally engaging in a malicious campaign of extreme and
outrageous harassment, lies, and intimidation against her, as described above.
84. 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.
19|Page
19 of 25
85. Plaintiff also continues to suffer from extreme emotional distress and anxiety as a
Defendants'
direct result of intentional conduct, as described above.
86. 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.
87. 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
Defendants'
of 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)
89. As described above, Defendants jointly and severally engaged in a course of conduct,
directed at Plaintiff, and created an unreasonable risk of harm to Plaintiff's mental and emotional
well-being.
90. At all relevant times, Defendants were aware of the emotional distress to which they
were subjecting Plaintiff and the fact that she was suffering from severe depression and anxiety as
a result. Nevertheless, Defendants employed family members and a private investigator to follow
and harass Plaintiff. Defendants also engaged in the extreme and outrageous conduct described
above, including the threatening and intimidating text and voice messages..
91. Plaintiff feared and continues to fear for her safety as a result of being surveilled and
harassed by Defendants, which only serves to cause her additional emotional distress.
20 of 25
Defendants'
92. Based on the circumstances described above, campaign of harassment
and intimidation created an unreasonable risk of causing her severe emotional distress and anxiety
93. As has been described above, Defendants were aware of Plaintiff's emotional state
as a result of their actions and conduct, such that it was clearly foreseeable that having Plaintiff
followed and/or harassed by Defendants would cause her greater emotional distress.
Defendants'
94. 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.
95. 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

(Harassment and Aggravated Harassment)
97. Defendants jointly and severally intentionally, and for no legitimate purpose, engaged
in a course of conduct designed to annoy, threaten, intimidate, alarm, and harass, which reasonably
caused Plaintiff to fear for her physical safety.
98. By reason of the foregoing, Defendants are liable to Plaintiff for compensatory,
special, and punitive damages.
AS AND FOR A FOURTH CAUSE OF ACTION

(Intentional Interference with Contractual Relationship)
21 Page
21 of 25
100. As discussed above, Defendants Charlet Sanieoff and Eliza Sabetfard called
incessantly Plaintiff's employers approximately twenty (20) times a day in late-February to early-
March 2017, with the intent to get Plaintiff fired from her job.
101. Defendants had their former counsel send to Plaintiff's employers a letter, blaming
Defendants'
Plaintiff for course of conduct and accusing Plaintiff of engaging in retaliatory tactics
to embarrass Defendants.
102. This letter was written with the intent that it causes Plaintiff to be fired from her
job.
103. Defendants had knowledge of Plaintiff's contract with BOND New York and
intentionally interfered with same, causing Plaintiff to suffer damages.
AS AND FOR A FIFTH CAUSE OF ACTION

(Tortious Interference with Prospective Economic Advantage)
106. As discussed above, Defendants Charlet Sanieoff and Eliza Sabetfard called
Plaintiff's employers approximately twenty (20) times a day in February and March 2017,
complaining and harassing them for the purpose of causing Plaintiff to lose her job.
107. Defendants had their former counsel send to Plaintiff's employers a letter, blaming
Defendants'
Plaintiff for course of conduct and accusing Plaintiff of engaging in retaliatory tactics
to embarrass Defendants.
108. This letter was written with the intent that it causes Plaintiff to be fired from her
job.
22 Page
22 of 25
109. Defendants had knowledge of Plaintiff's relationship with BOND New York and
intentionally, maliciously, and unlawfully interfered with Plaintiff's business relationship with
Bond, causing Plaintiff to suffer 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;
B) On the Second Cause of Action, compensatory and punitive damages against
Defendants in an amount to be determined at trial,
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;
attorneys'
M) All claims, costs, fees and expenses, including reasonable fees incurred
by Plaintiff in this action;
N) Punitive damages on all causes of action;
O) For such other and further relief as the Court may deem just and proper;
23 | P a g e
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Defendants'
P) Expedited Discovery including electronic discovery of all 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.
DE-MAND FOR JURY TRIAL
Plaintiff hereby demands a trial by jury on all issues and claims so triable.
Dated: New York, New York
January 24, 2020
Respectfully Submitted,
DELINCE LAW PLLC

Attorneys for Plaintiff
299 Broadway, Suite 1310
New York, New York 10007
Tel. 212 382 3544
jpd@delincelaw.com
TO: Joseph L. Buckley

SILLS CUMMIS & GROSS, P.C.
101 Park Avenue, 28th Floor
New York, NY 10178
Attorneys for Defendants
24|Page
24 of 25
INDIVIDUAL VERIFICATION
S T A TE O F NE W YORK )
ss:
C OUN TY O F NE W Y ORK )
I am the plaintiff in this action. The foregoing corrected verified amended complaint is true to my
own knowledge, except as to matters herein stated to be alleged on information and belief, and as to
those matters, I believe them to be true.
Alice Bahar
5"¹
Sworn to before me on this day of February 2020
Notar P c agb€(o33533
. .
25 of 25

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FILED: NEW YORK COUNTY CLERK 02/06/2020 11:06 AM INDEX NO.

SUPREME COURT OF THE STATE OF NEW YORK

-against- Index No. 150328/2018

ABRAHAM SANIEOFF; THE SANI GROUP a/1da

complaining of Defendants, ABRAHAM SANIEOFF; THE SANI GROUP a/lda 25 GROVE

STREET LLC; CHARLET SANIEOFF; ELIZA SABETFARD; LEOR SABETFARD; and

MAtTHEW SABETFARD, alleges as follows:

P_ARTIES AND VENUE

2. Plaintiff, ALICE BAHAR (hereinafter referred to as "Plaintiff"), is a resident of

and State of New York.

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

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

Neck, County of Nassau and State of New York.

8. Upon information and belief, Defendant Charlet Sanieoff's mother, Defendant

County of Nassau and State of New York.

9. Upon information and belief, Defendant Charlet Sanieoff's brother, LEOR

County and State of New York.

County of Nassau and State of New York.

New York County, where Plaintiff resides and works.

landlords in the West Village, New York.

was introduced to Defendant A. Sanieoff by Svetozar Zukovic (hereinafter referred to as "Zuko"),

years prior to the events giving rise to this Action.

and that, in or around late-July 2016, Plaintiff relented to the pressure.

Sanieoff terminated Plaintiff's employment.

whom Plaintiff had known for many years.

20. Plaintiff met Defendant A. Sanieoff, at or around 1:30 PM EST, in front of

apartment no. 12.

22. Defendant A. Sanieoff went on to give Plaintiff approximately four additional

Sanieoff relaxing with a bottle of Johnny Walker Blue.

27. In the same voicemail, approximately twenty-five seconds into the

recording, Defendant Charlet Sanieoff warns Plaintiff:

If you breath passed my husband, look towards my husband, text my

physically come there and take care of it myself ... You're a

homewrecker, a slut, a whore, and your is going to come one day.

I am going to do something that you will be regret it for the rest of

your life, and I am very serious. I am going to do something that

going to do something that you are going to regret it in the

community, in your office, in the Facebook, in the whole world ...

No matter what is takes me, I am going to stop this. I am serious, I

(Voicemail 27) (grammatical errors in original).

Defendant Eliza Sabetfard another voicemail stating:

You don't have to call me back. I left you a message, I am going to

office, in the community, in every possible way that you can

imagine. You do not know how powerful I am. I am going to do

something that you never experienced it before... I am going to

(Voicemail 29) (grammatical errors in original).

from Defendant C. Sanieoff:

I have so many people watching you 24 hours a day, you have no

me I will take care of you...All my private investigators are tracking

hope you suffer each day a little bit more.

Your boss your employees your colleagues showing them exactly

enjoyment, gleefully taunting Plaintiff:

if I don't see [items of jewelry gifted to Plaintiff by Defendant

Good Morning, Buttercup! Let the games begin!

34. Upon receiving Defendant E. Sabetfard's February 18 voicemail, at or around 12

Sabetfard threatened Plaintiff:

36. Again on February 19, at or around 10:58 AM EST, Defendant E. Sabetfard,

will pick it up in 48 hours. If you do not do that, it means that you

(Voicemail 32) (grammatical errors in original).

Plaintiff in fear of imminent bodily harm:

every move. You'll never be able to show your face in town to

9:06 AM voicemail with her own villainous message:

(Voicemail 38) (grammatical errors in original).