SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORK xCITIZENS DEFENDING LIBRARIES, :EDMUND MORRIS, ANNALYN SWAN, :STANLEY N. KATZ, THOMAS BENDER, :DAVID NASAW, JOAN W. SCOTT, :CYNTHIA M. PYLE, CHRISTABELGOUGH, and BLANCHE WEISENCOOK,

Plaintiffs,

- against -

Index No.: 652427/2013

DR. ANTHONY W. MARX, NEIL L. AFFIDAVIT OF ARCHITECTRUDENSTINE, BOARD OF TRUSTEES : CHARLES DAVOCK WARRENOF THE NEW YORK PUBLIC LIBRARY, :NEW YORK PUBLIC LIBRARY, ASTOR, :LENOX AND TILDEN FOUNDATIONS, :MICHAEL R. BLOOMBERG,VERONICA WHITE, NEW YORK CITY :PARKS DEPARTMENT, CITY OF NEW :YORK, ROBERT SILMAN ASSOCIATES,:P.C., and JOSEPH TORTORELLA,

Defendants.

-and-

STATE OF NEW YORK, NEW YORKSTATE OFFICE OF PARKS,RECREATION & HISTORICPRESERVATION (NEW YORKSTATE HISTORIC PRESERVATIONOFFICE),

Nominal Defendants. :x

STATE OF NEW YORK

SS.:

COUNTY OF NEW YORK

CHARLES DAVOCK WARREN, being duly sworn, deposes and says:

1. I am an architect and author, having extensive personal experience and

professional expertise with regard to the New York Public Library. Among other things, I

coauthored the two-volume monograph - Carrere & Hastings, Architects (Acanthus Press), the

architectural firm that designed and built the main branch of the New York Public Library,

located in Manhattan between 40 th and 42nd Streets along Fifth Avenue and adjacent to Bryant

Park (the "Central Building"). I am fully familiar with the facts set forth in this affidavit, which I

make in support of the request for an Order preventing removal of the seven stories of iron and

structural steel book stacks (the "Stacks") from the Central Building.

Professional Background

2. Since 1987, I have led the Manhattan-based practice Charles Warren Architect

p.c. The firm has worked extensively in the New York metropolitan area and completed houses,

commercial buildings, gardens, and other projects from New England to Florida. Careful

attention to historic, geographic, and ecological contexts has led to successful projects in historic

districts, environmentally sensitive coastal areas, and within planned towns. This work has been

featured in books and magazines in the United States and Europe.

3. I began my professional career with Robert A.M. Stern Architects in 1979, where

I worked for six years as a lead designer on projects including private residences, urban planning

proposals, and institutional buildings. During this period, I also worked briefly for Peter Gluck

& Associates. In 1990-91, after starting my practice, I served as Town Architect of Seaside,

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Florida, an early example of New Urbanism designed by town planners Duany Plater-Zyberk &

Co.

4. University level teaching has always been a part of my career. During my

graduate studies, I was a teaching assistant in the Columbia College architectural design studio.

In 1987, I was awarded the Muschenheim Fellowship at the University of Michigan College of

Architecture and Urban Planning. As a visiting assistant professor there, I taught design studios

and seminars on architectural theory. I have also taught design studios and seminars

at Catholic University in Washington and The Institute of Classical Architecture & Art in New

York. I have served on numerous peer review and student juries for professional organizations

and universities.

5. In addition to my architectural practice, I have published books and essays on

architecture and town planning. I have written for Architectural Record, Progressive

Architecture, Inland Architecture, and The Classicist. I am the author of introductory essays for

new editions of The Architecture of Charles A. Platt (Acanthus Press) and John Nolen's 1927

classic New Towns for Old (LALH & University of Massachusetts Press). As noted above,

coauthored the two volume monograph - Carrere & Hastings, Architects (Acanthus Press). I

have been awarded grants supporting these projects by the Nolen Research Fund at Cornell

University and the Graham Foundation.

6. I studied fine arts at California Institute of the Arts, and graduated with a Bachelor

of Science in fine arts from Skidmore College in 1976. In 1980, I received a Master of

Architecture from Columbia University, where I was awarded a Kinne travel fellowship and the

Lowenfish prize for design. I am a member of the American Institute of Architects, The

Congress for the New Urbanism, The Institute of Classical Architecture & Art, and The

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Architectural League of New York. I served for ten years as Treasurer and Trustee of the Library

of American Landscape Architecture.

New York Public Library

7. The Central Building of the New York Public Library was constructed by the City

of New York to store and deliver the library's books and research material to New Yorkers, or

indeed to any visitor. John Shaw Billings, the library's first director, studied and visited libraries

in Paris, London and elsewhere as he worked determinedly to insure that the library he built

would equal or surpass them. He worked with architects Carrere & Hastings and the best

engineers of the era to fashion a perfect machine for the storage, retrieval and reading of books.

This magnificent, durable building can still house over three million books and deliver any one

of them to a reader within minutes.

8. Such efficiency is possible because of a unique spatial arrangement and an

ingenious use of iron and steel. The books are stored in a dense seven-story steel book stack

directly below the main reading room. Once located, books are taken to a central dumb-waiter

and lifted to readers awaiting them above. The logistical simplicity of this system is matched by

its structural elegance; 1,300 Carnegie steel columns support the seven floors of books, as they

also support the reading room floor. Structure, spatial arrangement, and function are thereby

fused in a building seemingly alive to its purpose.

9. Now the Stacks have been emptied of books and it usually takes forty-eight hours

rather than fifteen minutes to retrieve them from storage facilities as far away as Princeton, NJ.

This has slowed and hindered my own research and that of colleagues, but worse things await us.

The library's leaders propose to demolish the iron and steel construction, so the books can never

be returned. In so doing they will substitute a new structural system to support the floor of the

celebrated reading room, leaving the magnificent marble walls of the library an inefficient, empty

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rn to before me thisay of July, 20

Notary PublicMICHAEL S. HILLER

Notary Public, State of New YorkNo. 02H16068274

Qualified in Kings CountyCommission Expires April 20, 2014

shell. They plan to do this while the reading room is occupied by the thousands of visitors who

use it every day. Surely this project will further slow book delivery while distracting and

interrupting readers with the noise and vibration that accompany such a complex construction

process. Removing supports from an occupied floor poses a worrisome, albeit modest, safety

risk.

10. Storing and retrieving books are central to the mission of the New York Public

Library; its building was designed exactly for that purpose. Removing the books and lengthening

the time it takes to obtain them is an irresponsible erosion of that mission. The error is

compounded when the structure meant to store the books and support the room most crucial to

their use is ripped out. The custom made cast iron and Carnegie steel utilized in the structure of

the Stacks are irreplaceable. Thus, removal of the Stacks will result in an irreparable alteration to

one of New York's most historic buildings. It is a destructive plan that jeopardizes the

functioning of the library in the short term and diminishes it in perpetuity. To allow any part of

this demolition to proceed without a specific plan for what is to replace this efficient, significant

engineering achievement is to allow irresponsible vandalism of public property.

11. For all of the foregoing reasons, I implore the Court to enjoin removal of the

Stacks, and any further removal of the books they contain.

CHARLES DAVOCK WARREN

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