SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK

x CITIZENS DEFENDING LIBRARIES, : EDMUND MORRIS, ANNALYN SWAN, : STANLEY N. KATZ, THOMAS BENDER, : Index No.: 652427/2013 DAVID NASAW, JOAN W. SCOTT, : CYNTHIA M. PYLE, CHRISTABEL GOUGH, and BLANCHE WEISEN COOK, Plaintiffs, - against DR. ANTHONY W. MARX, NEIL L. RUDENSTINE, BOARD OF TRUSTEES : OF 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. -andSTATE OF NEW YORK, NEW YORK STATE OFFICE OF PARKS, RECREATION & HISTORIC PRESERVATION (NEW YORK STATE HISTORIC PRESERVATION OFFICE), Nominal Defendants. : x AFFIDAVIT OF ARCHITECT CHARLES DAVOCK WARREN

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 I have written for Architectural Record, Progressive

architecture and town planning.

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

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 -4-

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

rn to before me this ay of July, 20

Notary Public
MICHAEL S. HILLER Notary Public, State of New York No. 02H16068274 Qualified in Kings County Commission Expires April 20, 2014