Parks holds houseboat owners to unwritten laws, and have them unlawfully bear a greater regulatory burden than others similarly situated at the BOAT BASIN; Houseboats and Terry were forced to meet the “black letter” of Defendants’ policies, practices and regulations where others owners were not required to meet these same standards. The houseboats at the BOAT BASIN were forced to comply with policies and practices that were not required by others.
78. Defendants’, including PARKS’ management, were aware, or should have been aware, of the MARINE DIVISION’S policies and practices at the BOAT BASIN that discriminated and singled out those who had a “houseboat” and year round contracts, and actively promoted and rewarded managers who would effectuate these illegal discriminatory anti-houseboat strategy. The scheme worked in such a way that the MARINE DIVISION management at the BOAT BASIN rewarded those dockmasters who engaged and executed these illegal management strategies.
79. The MARINE DIVISION proceeded with these strategies with a lack of Defendants, including PARKS’, supervision, active noncompliance with proper management techniques, controls and Standard Operating Procedures. This lack of proper control and supervision by Defendants, including PARKS’ management, was intended as a reward for what all parties knew to be improper behavior, pursuing improper and illegal objectives of harassing and removing and eliminating houseboats from the BOAT BASIN.
Parks to selectively enforced insurance requirements against the houseboat community and those occupants who had a year round contracts; Defendants historically have condoned the policy of the MARINE DIVISION and/or was negligent in its supervision of MARINE DIVISION for the BOAT BASIN.
80. The management created a situation whereby with each houseboat that was removed, the Dockmaster could rent the empty slip to a transient boat customer and increase revenues at the BOAT BASIN; and the revenue may or may not have been turned over to REVENUE. The PARKS’ knew that the revenues from the empty slips rentals to transient boat customers were not accounted for and knew that it was a violation of New York City revenue policy and knew also that the BOAT BASIN’S Dockmaster could pocket the revenue and may or may not report it to REVENUE. This EXTRA illegal revenue was the PARKS’ reward to the MARINE DIVISION Dockmaster for engaging in a known illegal policy of harassing houseboats. Moreover, the lack of compliance with the New York City’s financial accounting rules created a defacto incentive for the Chief Dockmaster because empty slips generate money, which may or may not have been reported to REVENUE. The lack of compliance with New York City RULES emboldened the Dockmaster to engage in activities that harassed the houseboat community .
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