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Re: Re: Manhattan Club Lawsuit (by Steven H.):

In November, 2021, Jean-Marc Zimmerman and Steven Hoffberg filed an amended complaint in Acklin et al. v. Eichner et al., Civil Action No. 1:20-CV-07042 pending in the U.S. Federal District Court for the Southern District of New York on behalf of many plaintiffs, alleging as a basis for federal jurisdiction violations of the federal civil RICO statute. Defendants promptly filed a motion to dismiss, which was responded to over one year ago in January, 2022. The court clerk recently affirmed that the motion remains pending, but unresolved.

We have also communicated with Louis Solomon, Chief of Enforcement, NYS Office of The Attorney General, Real Estate Finance Bureau (212) 416-8109, who did not provide us with significant information about the “ongoing” TMC investigation. There is apparently a monitor appointed per the AOD, but Mr. Solomon did not disclose his name. Mr. Solomon was, however, interested in receiving further evidence of fraud or impropriety at TMC.

We intend to attend and participate in this year’s annual meeting, and encourage all members to attend, and raise your concerns publicly with the Board.

Jean-Marc Zimmerman Zimmerman Law Group Telephone: (908) 768-6408 Email: jmz@zimllp.com

Steven M. Hoffberg Hoffberg & Associates Telephone: (914) 949-2300 Email: steve@hoffberglaw.com