A BRONX REPUBLICAN TALE: PROMISES MADE, PROMISES KEPT

 

Bronx Republican Success By the Numbers:

Highest Vote Total for a Presidential candidate in the Bronx since 1988

Chairman Rendino: Republican Progress in Deep Blue Hispanic Bronx Communities is the Roadmap to Future Success for the New York City GOP

 In just four years, the Republican Party has made dramatic in-roads in the Bronx. After taking over as Chairman of the Bronx Republican Party in 2016, former 9/11 firefighter Mike Rendino has led the organization to major successes including an 18% voter registration increase and the highest vote total for a GOP presidential candidate since 1988, due in large part to major gains in majority-Latino communities, like the deep-blue South Bronx.

Bronx Republican Chairman Mike Rendino said, “Four years ago I reluctantly accepted the role of Chairman after my predecessor stepped down for health reasons. When I started this journey I promised not only to improve the Bronx Republican Party, but to grow it. I am proud to say that we have kept that promise.

“We grew our party with outreach into nontraditional Republican populations in the Bronx and holding meetings in deep blue Democrat areas. We remained loyal to our base, our Republican principles and our traditional strongholds, while at the same time working to expand our coalition of like-minded New Yorkers by focusing on small business and public safety -- issues that resonate, in particular, with hispanics, who now make up 58% of the population of the Bronx. Our progress in deep blue hispanic Bronx communities is the roadmap to future success for the New York City Republican Party." 

BY THE NUMBERS:

In just 4 years we increased Republican voter enrollment by 18% from 37,190 to 43,992

Four years ago we fielded candidates in just 6 of 16 State Assembly and Senate campaigns. This year we fielded candidates in 14 of the 16 Bronx seats with every candidate more than doubling votes totals from 4 years ago, including tripling the past vote total in one district. 

We also recruited the Bronx's very own John Cummings and put together the team that raised over 11 million dollars in what turned out to be one of the most expensive house races in the country. The Bronx is Ground Zero for the war on Socialism, and John's wildly successful fundraising operation and vigorous campaign against AOC helped our entire slate of candidates, including President Trump.

This election cycle, we achieved the highest vote total for a Republican Presidential candidate in the Bronx since 1988. Incredible, considering the Bronx had a very different demographic 32 years ago. The Bronx is now 58% Hispanic and the Republican Party has made huge in roads in the community, while the Democrats continue to ignore the needs of this constituency.

Because of the work we've done over the past 4 years, President Trump outperformed Bronx Republican voter registration, which is less than 6% and received over 15%. The President did better in the Bronx than even in his home county in Manhattan, where he received 12%.

Chairman Rendino concluded, “As Bronx Democrats laid down their arms at ground zero in the war against socialism, Bronx Republicans engaged and fought back with blue collar conservatism. We fought, and we won over working class voters of all ethnicities throughout the Bronx. As the New York City Board of Elections certifies the 2020 election results, I am proud to report that the promise I made 4 years ago has been kept.”

Bronx Republican Party 

3029 Middletown Rd, Bronx, NY 10461

EDITOR'S NOTE:

Donald Trump in 2020 won fifteen election district in three different assembly districts, compared to winning twelve election districts in just two assembly districts in 2016.

80th A.D. ED's 3 and 19.

81st A.D. ED 31.

82nd A.D. ED's 1,2,3,42,42,43,44,45,46,47,48,and 49.

KRVC - Visit Santa on Johnson Avenue on December 13th!

 

Visit Santa on Johnson Avenue! Between West 235th &236th Streets .  Join us to celebrate Riverdale again on Sunday, December 13th!  ______ **Please note that due to weather the program may need to be  modified. Those decisions will be made each week to ensure the  safety and success of our staff, participants and community  members.** Email Tracykrvc@gmail.com for more information www.krvcdc.org

NYS Office of Mental Health Issues Request For Proposals to Continue Work of Project Teach

 

Program Helps Expand Access to Behavioral Health Services for Children, Adolescents, and Families

 The NYS Office of Mental Health (OMH) has issued a Request for Proposals to continue and enhance the work of Project TEACH (Training and Education for the Advancement of Children’s Health).  Project TEACH creates collaborations between primary care providers, such as pediatricians, and behavioral health care providers. This allows primary care providers to better address their patients’ mild to moderate mental health concerns and provide mental health services to children, adolescents, and their families.

Access to consultation and collaboration with child and adolescent psychiatrists is a strategy that is supported by the American Academy of Pediatrics, the American Academy of Child and Adolescent Psychiatry, and the National Institute for Health Care Management.

In addition, the RFP will expand the Maternal Mental Health Initiative which provides maternal health providers with access to consultation, training and assistance with referral and linkage around maternal mental health issues.  

OMH Commissioner Dr. Ann Sullivan said, “Through Project TEACH we are increasing access to behavioral health services for children and their families, which is especially important now, as we deal with the impact the COVID-19 pandemic is having on so many families across the State.  Project TEACH has also helped pregnant women and new mothers overcome maternal depression, which when identified and treated early, leads to better health outcomes for mothers and children.”

Project TEACH is comprised of three interrelated services for primary care providers: it increases access to psychiatric consultations from child and adolescent mental healthcare specialists, links primary care physicians and their patients with appropriate community-based services and provides training for primary care providers.

The RFP provides for an award of up to $17 million for a five year contract beginning July 1, 2021 to coordinate Project TEACH services which include development of specialty consultation services, development and delivery of training programs that would be available throughout the state, maintenance of the statewide Project TEACH website and marketing and promotion of the program.

Founded in 2010, the mission of Project TEACH is to strengthen and support the ability of primary care providers to deliver care to children and families who experience mild-to-moderate mental health concerns. Project TEACH educates and supports primary care providers to integrate care for mild-to moderate behavioral health concerns into primary care for children and adolescents, ages 0 to 21.

By increasing access to behavioral health care for children, Project TEACH has been especially valuable in areas that have historically been underserved. Access to care for children is essential to achieving good health care outcomes and pediatric primary care providers have an essential role in identifying and treating behavioral health problems in children.

In a National Examination of Child Psychiatric Telephone Consultation Programs' Impact on Children's Mental Health Care Utilization, children from states with statewide child psychiatry telephone access programs were significantly more likely to receive mental health services than children residing in states without such programs.  Project TEACH is helping to mitigate the shortage of child and adolescent psychiatrists and promote more equitable access utilizing the network of primary care providers.

Letters of Intent to Bid on the RFP are due by December 14, and questions from bidders on the RFP are due by December 28. Proposals are due by February 1, 2021 OMH anticipates announcing the award by February 5, 2021.  More information can be found on the OMH website at: https://omh.ny.gov/omhweb/rfp/2020/teach/project-teach-rfp.pdf

STATEMENT FROM MAYOR BILL DE BLASIO ON THE NORTH BROOKLYN PIPELINE PROJECT

 

 Mayor Bill de Blasio today joined with advocates and elected officials to call on National Grid to halt the North Brooklyn Pipeline project.

“Climate change is an existential threat to our city and we must transition quickly to clean energy. Today, I am voicing my opposition to National Grid’s North Brooklyn Pipeline because we cannot justify the environmental impacts on the largely Black and Brown residents of Brooklyn associated with an unnecessary pipeline expansion. Racial and environmental justice go hand-in-hand, and National Grid has failed to clearly demonstrate that this pipeline is needed to keep New Yorkers warm and safe. I am calling on them to withdraw this project immediately," said Mayor Bill de Blasio.

 

“Our climate crisis demands an end to new fossil fuel infrastructure, here in New York City and around the globe,” said Daniel Zarrilli, NYC's Chief Climate Policy Advisor. “Even in this moment as federal climate leadership is poised to re-emerge, it is clear that cities like New York will need to continue raising their climate ambitions. Earlier this year, Mayor de Blasio signed a ground-breaking executive order opposing new fossil fuel infrastructure serving our city and we are following through on that pledge. That’s why we are divesting our pensions from fossil fuels, investing billions into job-creating climate solutions like solar, wind, and hydro, and fighting destructive projects like the Williams pipeline and the North Brooklyn pipeline that are undermining our future.”

 

“With the Mayor’s announcement against National Grid’s fracked gas pipeline, there is now unanimous opposition from local city, state, and federal elected officials and tens of thousands of New Yorkers in the affected areas from Brownsville to Greenpoint. So far National Grid has ignored the will of the people and continued construction, but New York City is united against their plans to lock us in to decades of raising our rates for more fossil fuels, pollution, and climate chaos for their private profit. We look forward to continuing our work with the Mayor’s office as we operationalize the Executive Order to end the expansion of fossil fuel infrastructure, like the LNG facility at the apex of the North Brooklyn Pipeline,” said Kim Fraczek, Director, Sane Energy Project, a co-founding member of No NBK Pipeline Coalition.

 

“We have to prioritize lower income communities of color that have been stripped of resources and exploited for profit for too long. We’re calling on our elected officials to fight this pipeline with sustainable love through environmental practices. Restorative justice includes environmental justice for the Black and Brown communities. Going forward, we must foster bold solutions that would prevent projects like the Metropolitan Reliability Infrastructure (North Brooklyn Pipeline) from ever being constructed in this neighborhood.  We need more investments in sustainable development, green spaces, clean energy and processes that reflect social inclusion and equity for our community. Brownsville is not a sacrifice zone," said Gabriel Jamison, a founding member of the Brownsville Residents Green Committee.

 

“Mayor de Blasio’s opposition to the North Brooklyn fracked gas pipeline is welcome news and yet another clear signal that New Yorkers will never allow National Grid to double down on fossil fuels. It’s obvious that we must not build infrastructure that will lock us into decades of ruinous reliance on fossil fuels. We’re proud to stand united with Mayor de Blasio and New Yorkers from all five boroughs in opposition to the North Brooklyn Pipeline and all other new fossil fuel projects,” said Alex Beauchamp, Northeast Region Director at Food & Water Watch, a member of the No NBK Pipeline Coalition.

 

“As a Brownsville resident and Sandy survivor, it’s good to see the City oppose this polluting project. It’s time to go off fracked gas. It makes no sense to build entirely new gas infrastructure, and then let National Grid stick all of us with the bill,” said Rachel Rivera, a member of New York Communities for Change. 

 

“People power stopped the Williams fracked gas pipeline. People power secured an executive order from the mayor of the biggest city in USA banning new fossil fuel infrastructure. Now the mayor is seeing that forward, clearly opposing the unnecessary and risky North Brooklyn pipeline. It's time for National Grid to wake up and realize the future is in renewables, not yet more losing attempts at building new fracked gas infrastructure,” said Dominique Thomas, lead organizer, 350.org.

Governor Cuomo Announces State to Receive Initial Delivery of COVID-19 Vaccine Doses for 170,000 New Yorkers and Updates New Yorkers on State's Progress During COVID-19 Pandemic - DECEMBER 2, 2020

 

State Expects to Receive Vaccines December 15 if All Safety and Efficacy Approvals Are Granted

New York Expects to Receive Additional Vaccine Allocations from Pfizer and Moderna This Month

Positive Testing Rate in All Focus Zone Areas is 5.88 Percent; New York State Positivity Outside All Focus Zone Areas is 4.21 Percent     

Statewide Positivity Rate is 4.63 Percent

69 COVID-19 Deaths in New York State Yesterday

 Governor Andrew M. Cuomo today announced that New York State will receive an initial delivery of enough COVID-19 vaccine doses for 170,000 New Yorkers. If all safety and efficacy approvals are granted by the federal government, the state expects to receive the vaccines—which were created by Pfizer—on December 15. New York State expects additional allocations of vaccines from Pfizer and Moderna later this month.

"As we continue to move through the holiday season, the good news is that there is a light at the end of the tunnel, but unfortunately it is still a ways away and we are now faced with a set of challenges to overcome before we get there. Not only is the number of COVID-19 cases rising virtually everywhere, but they are stemming from a new source, with nearly 70 percent of cases being traced back to households and private gatherings," Governor Cuomo said. "The federal government has also informed us that New York will be getting its first 170,000 doses of the vaccine in the coming weeks, and while that is certainly welcomed news, the federal vaccination plan not only overlooks the black, brown, and poor communities, but its data sharing provisions will dissuade the undocumented community from getting a vaccination. Winning the war against COVID has to be an inclusive process and only by everyone working together will we be successful. While we continue to fight to make the federal plan more inclusive, effective and fair, New Yorkers need to do their part to help limit the spread."

The Governor noted that the positive testing rate in all focus areas under the state's Micro-Cluster strategy is 5.88 percent, and outside the focus zone areas is 4.21 percent. Within the focus areas, 49,027 test results were reported yesterday, yielding 2,882 positives. In the remainder of the state, not counting these focus areas, 144,524 test results were reported, yielding 6,091 positives.

Today's data is summarized briefly below:

• Patient Hospitalization - 3,924 (+150)
• Patients Newly Admitted - 627
• Hospital Counties - 54
• Number ICU - 742 (+24)
• Number ICU with Intubation - 373 (+25)
• Total Discharges - 86,201 (+393)
• Deaths - 69
• Total Deaths - 26,889

Licensed Attorney And Disbarred Attorney Charged With Securities Fraud For Roles In Fraudulent Opinion Letter Scheme

 Audrey Strauss, the Acting United States Attorney for the Southern District of New York, and Carl W. Hoecker, the Inspector General of the Office of Inspector General of the U.S. Securities and Exchange Commission (“SEC-OIG”), announced today the unsealing of an Indictment in Manhattan federal court charging RICHARD RUBIN and THOMAS CRAFT with securities fraud.  The Indictment alleges that RUBIN, a disbarred attorney, and CRAFT, an attorney licensed in Florida, engaged in a fraudulent scheme in which CRAFT falsely represented that he had undertaken certain legal work in connection with three types of attorney opinion letters, all of which enabled the relevant securities to be sold to the investing public.  In truth and in fact, RUBIN, despite his disbarment, had undertaken all of the legal work attested to in the letters; CRAFT merely served as a “rubber stamp” on the letters in exchange for tens of thousands of dollars in monetary compensation.  RUBIN was taken into custody today in New York, New York, and will be presented today before Magistrate Judge Katharine H. Parker in Manhattan federal court.  CRAFT was taken into custody today in West Palm Beach, Florida, and will be presented today in federal court in Florida.  The case has been assigned to United States District Judge Paul A. Engelmayer.

Acting U.S. Attorney Audrey Strauss said:  “As alleged, rather than act as gatekeepers against fraud, the defendants used their positions as attorneys – albeit one of them disbarred – to actively carry out a fraud, working to generate dozens of attorney opinion letters containing false representations that brought false comfort to the investing public that certain legal work had been performed and certain information had been confirmed as accurate. 

SEC Inspector General Carl W. Hoecker said:  “Today’s criminal indictment demonstrates our commitment to holding bad actors accountable for undermining the integrity of the securities registration system.”

As alleged in the Indictment unsealed today in Manhattan federal court:[1] 

Securities Registration Requirements and SEC Rule 144 

Under the Securities Act of 1933 (the “Securities Act”), anyone seeking to sell a security must first register the offering of that security unless an exemption applies. See 15 U.S.C. § 77e.  This registration requirement protects investors by promoting disclosure of information pertinent to informed investment decisions. 

A company registering the offer of securities must complete a registration statement such as SEC Form S-1 before the securities can be listed on a national exchange and publicly traded.   SEC Form S-1 contains information pertinent to informed investment decisions, including, among other things, information on the company’s business operations, the company’s financial condition, and a description of the company’s management.  In connection with SEC Form S-1, the company is required to file an opinion letter (the “Form S-1 Opinion Letter”) from a licensed attorney regarding the legality of the securities being offered or sold pursuant to the registration statement.  A company’s SEC Form S-1 and the Form S-1 Opinion Letter are available to the public on the SEC’s Electronic Data Gathering, Analysis, and Retrieval System (“EDGAR”).

“Restricted securities” refers to securities acquired in unregistered, private sales from the issuing company or from an affiliate of the issuer, with “affiliate” meaning a person that directly or indirectly controls, or is controlled by, or is under common control with, an issuer.  Affiliates can also include an executive officer or a director or large shareholder who is in a relationship of control with respect to the issuing company.  Restricted securities bear a legend indicating that the securities may not be resold in the marketplace unless they are registered with the SEC or are exempt from such registration requirements.

Securities Act Rule 144 (“Rule 144”), codified at 17 C.F.R. § 230.144, provides a registration exemption for the resale of restricted securities.  Specifically, it permits the public resale of restricted securities if a number of conditions are met, including conditions relating to how long the securities are held, the way in which they are sold, the public information available to investors about the securities, and the amount that can be sold at any one time.  However, even if these conditions are met, the sale of restricted securities to the public is still not permitted until a transfer agent removes the “restricted” legend from the security. 

The term “transfer agent” refers to a company that keeps track of individuals and entities that own the stocks and bonds of a given company that has publicly traded securities.  Among other things, transfer agents issue and cancel certificates to reflect changes in ownership, serve as the company’s intermediary for payouts, exchanges, or mailings, and handle lost, destroyed or stolen certificates.  Transfer agents also, when appropriate, remove the “restricted” legend from securities. 

A Rule 144 Seller’s Representation Letter, or “Seller’s Representation Letter,” is a letter to a transfer agent to establish certain facts underlying a legal opinion that the securities at issue can be sold publicly pursuant to Rule 144.  The transfer agent relies on the Seller’s Representation Letter in determining whether to remove the restricted legend from a security.

Over-the-Counter Securities and OTC Markets Group 

Over-the-counter (“OTC”) securities are securities that are traded between two counterparties outside of a formal securities exchange.  OTC Markets Group (“OTC Markets”) is a company headquartered in New York, New York that provides price and liquidity information for OTC securities.

OTC Markets requires issuers seeking to be quoted on certain tiers of OTC Markets to hire a licensed attorney to review company records and submit a letter to OTC Markets (an “OTC Markets Attorney Letter”) regarding whether information publicly disclosed by the issuer is in compliance with the condition in SEC Rule 144 governing the public information available to investors about the issuer.  OTC Markets relies on the OTC Markets Attorney Letter to determine whether an issuer’s security may be quoted on OTC Markets.  OTC Markets Attorney Letters are available to the public on the OTC Markets website. 

The Scheme to Defraud 

From at least in or about 2011 through at least in or about September 2018, RUBIN and CRAFT, the defendants, participated in a fraudulent scheme in which CRAFT falsely represented that he had undertaken certain legal work in connection with Seller’s Representation Letters, OTC Markets Attorney Letters, and S-1 Opinion Letters, all of which enabled the relevant securities to be sold to the investing public.  In addition, in connection with the securities of certain issuers, RUBIN, the defendant, falsely represented that he was an attorney in Seller’s Representation Letters and OTC Markets Attorney Letters, all of which enabled the relevant securities to be sold to the investing public.  The false representations were in letters pertaining to over a dozen companies.

RUBIN, 78, of Brooklyn, New York, and CRAFT, 55, of Tequesta, Florida, are each charged with one count of conspiracy to commit securities fraud, which carries a maximum sentence of five years in prison, one count of securities fraud in violation of 18 U.S.C. §§ 1348 and 2, which carries a maximum sentence of 25 years in prison, and one count of securities fraud in violation of 15 U.S.C. §§ 78j(b) and 78ff, 17 C.F.R. § 240.10b-5, and 18 U.S.C. § 2, which carries a maximum sentence of 20 years in prison.  The maximum potential sentences in this case are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendants will be determined by the judge.       

Ms. Strauss praised the investigative work of the SEC OIG.  Ms. Strauss also thanked the U.S. Postal Inspection Service, Office of the Inspector General, which assisted in the investigation.  Ms. Strauss also thanked the SEC Division of Enforcement, which brought a separate civil enforcement action against the defendants. 

The charges contained in the Indictment are merely accusations, and the defendants are presumed innocent unless and until proven guilty.

 [1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein, constitute only allegations, and every fact described should be treated as an allegation. 

Governor Cuomo Releases New PSA Highlighting the Dangers of COVID-19 Transmission Through 'Living Room Spread'

 

New York's Contact Tracing Data Shows 70 Percent of New COVID-19 Cases Occur From Households and Small Gatherings

See New PSA Here

 Governor Andrew M. Cuomo today announced the release of a new PSA highlighting the dangers of COVID-19 "living room spread." New York's latest contact tracing data shows 70 percent of new COVID-19 cases originate from households and small gatherings. As the number of new cases continues to grow nationwide, the PSA encourages New Yorkers to avoid gatherings to keep themselves and their loved ones safe.

"It's not just mass gatherings causing the spread anymore. The virus is now literally spreading in households," Governor Cuomo said. "When you eliminate other options for socialization, people will shift their behavior and begin joining together in their homes. We are seeing the impacts of that now, with a significant number of cases originating in households and small gatherings. I know you may think, 'I'm in my house with my family and with my friends so this is my safe zone,' but that just is simply not the case anymore. As we move forward into the winter, addressing living room spread will be one of the biggest challenges in the fight against COVID-19, and we can do it, but only if New Yorkers stay smart."

While New York continues to maintain one of the lowest infection rates in the United State, avoiding small gatherings and practicing safe behaviors like wearing masks, washing hands and socially distancing, is as important as ever as COVID-19 cases continue to rise nationally.

Earlier this week, the Governor announced the state's plan for combating COVID-19 this winter. Developed in consultation with global public health experts, local governments and other stakeholders, the plan builds off the lessons learned during the past nine months to anticipate and prepare for an expected increase in COVID cases and hospitalizations over the Holiday season.

Specifically, the winter plan consists of five targeted strategies focused on mitigating the spread of the virus and bolstering New York State hospital preparedness including:

• Continue and Strengthen New York's Targeted Micro-Cluster Strategy while Managing Hospital Capacity to Enhance and Equalize Care;
• Increase and Balance Testing Resources and Availability;
• Keep Schools Open Safely;
• Prevent Viral Spread from Small Gatherings; and

Operationalize an Equitable and Safe Vaccination Program

Acting U.S. Attorney Sues Village Of Airmont For Renewed Religious Discrimination Against Orthodox Jewish Residents

 

Lawsuit Follows Recidivist Village’s Adoption of Discriminatory Zoning Code and Land Use Practices that Violate Federal Law and Prior Court Judgment

 Audrey Strauss, the Acting United States Attorney for the Southern District of New York, announced the filing today of a lawsuit in federal district court against the Village of Airmont in Rockland County (“AIRMONT” or the “VILLAGE”) to rectify AIRMONT’S renewed efforts to discriminate against its Orthodox Jewish community.  As alleged in the Complaint, AIRMONT has violated the Religious Land Use and Institutionalized Persons Act (“RLUIPA”) by imposing land use and zoning provisions that, among other things, restrict Orthodox Jewish residents’ ability to worship in private homes and prevent operation of a private religious school.  The lawsuit marks the third time that the United States has sued AIRMONT since its 1991 incorporation for discriminatory treatment of Orthodox Jewish residents under both RLUIPA and the Fair Housing Act.  The first two lawsuits resulted in the entry of court judgments against the VILLAGE – a judgment following a jury trial in 1996 and judgment pursuant to a court-entered consent decree in 2011.     

Acting U.S. Attorney Audrey Strauss said:  “As a jury found over two decades ago, the Village of Airmont was born out of a spirit of animus against a religious minority.  Sadly, rather than working to overcome that shameful legacy, Airmont has flagrantly ignored the terms of a court judgment and implemented land use practices that by design and operation are again meant to infringe unlawfully on the rights of a minority religious community.  Religious discrimination will not be tolerated.  We will remain vigilant to ensure that the right to worship freely and without undue interference is protected for all.”  

According to the Complaint filed in White Plains federal court:

Following the expiration of the last court-entered consent decree against AIRMONT in 2015, and beginning with an administration elected in 2017 on an openly anti-Hasidic platform, the VILLAGE has actively sought to prevent its Orthodox Jewish residents from operating home synagogues and a private school in conformity with their faith.  AIRMONT has pursued its discriminatory agenda by, among other actions:  

• Imposing a nearly two-year land use moratorium in 2017 that was motivated by a desire to prevent the growing Orthodox Jewish community from developing property rather than any legitimate governmental purpose.
   
• Amending the Village Zoning Code in 2018 to strike “residential place of worship” as a recognized land use category, in direct violation of the terms of the final judgment entered by the court in 1996.
   
• Imposing new Zoning Code requirements that place an unlawful and arbitrary limit on the gross floor area of private residences that can be used for worship, ban the use of private home mikvahs, or ritual baths, and restrict the co-congregants whom homeowners are allowed to host.
   
• Implementing a new, arbitrary land use application process controlled by the Village designed to impose unreasonable and unnecessary zoning requirements on Orthodox Jewish residents, drive up their costs, and ensure their applications, including minor alterations to private homes, are never approved despite years of good faith efforts to comply.
   
• Targeting Orthodox Jewish residents with the threat and imposition of unfounded fines for supposed zoning infractions in order to thwart and intimidate land use applicants. 

RLUIPA authorizes the Department of Justice to commence an action against any local government that implements a land use regulation that places a substantial burden on religious exercise, discriminates on the basis of religion, or unreasonably limits religious assemblies, institutions, and structures.  The Complaint seeks declaratory and injunctive relief against AIRMONT.