EXHIBIT C

FILED: NEW YORK COUNTY CLERK 04/15/2015 03:59 PM INDEX NO. 652721/2014

NYSCEF DOC. NO. 134 RECEIVED NYSCEF: 04/15/2015

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

X Index No: 652721/2014

Hon. Judge Saliann Scarpulla

SUBPOENA DUCES TECUM

FCRC MODULAR, LLC,

Plaintiff,

-against-

SKANSKA MODULAR LLC and RICHARD A. KENNEDY,

Defendants.

SKANSKA MODULAR LLC and RICHARD A. KENNEDY,

Third-Party Plaintiffs

-against —

FOREST CITY RATNER COMPANIES, LLC, FOREST CITY ENTERPRISES, INC., JOHN DOES 1-10 AND JANE DOE,

Third-Party Defendants X

THE PEOPLE OF THE STATE OF NEW YORK:

To: Berlin Rosen Ltd. 15 Maiden Lane New York, NY 10038

WE COMMAND YOU, that all other business and excuses being laid aside, to

produce, at the offices of Peckar & Abramson, PC, at 41 Madison Ave., 20th Floor, New

York, NY 10010, on the 19th day of November, 2014 at 9:30 o'clock a.m. the records set

forth in the Schedule of Documents attached hereto.

FAILURE TO COMPLY WITH THIS SUBPOENA is punishable as a contempt of

Court and shall make you liable to the person on whose behalf this subpoena was issued for a

LAW OFFICES

Peckar & Abramson A Professional Corporation

penalty not to exceed fifty dollars, plus costs of up to fifty dollars and all damages sustained

by reason of your failure to comply.

PLEASE TAKE FURTHER NOTICE, that production of these records is required

because Berlin Rosen, by Jeremy Soffin, issued a Press Release which is attached to this

Subpoena as Exhibit A, in which it stated:

"The Complaint also states a claim for tortious interference with contract against Kennedy because he knowingly, wrongfully, intentionally, maliciously, in bad faith and without reasonable justification or excuse induced Skanska Modular to breach the LLC Agreement."

Richard A. Kennedy is a party in a pending action and it is relevant to determine the entities

and individuals which and/or whom authorized the issuance of this Press Release.

Dated: October 22, 2014 New York, New York

Respectfully submitted,

Bruce D.D. Meller

PECKAR & ABRAMSON, P.C. 41 Madison Avenue, 20th Floor New York, NY 10010 Telephone: (212) 382-0909

Co-Counsel for Skanska Modular LLC And Counsel for Richard A. Kennedy

K&L GATES LLP 599 Lexington Avenue New York, NY 10022-6030 Telephone: (212) 536-3900 Fax: (212) 536-3901

LAW OFFICES

Peckar & Abramson

Co-Counsel for Skanska Modular LLC

A Professional Corporation

DEFINITIONS

These definitions apply throughout these document requests and internally within the

text of these definitions:

1. "Press Release" as used herein shall mean the document attached as Exhibit A

to this Subpoena.

2. "FCRC Modular" as used herein shall mean FCRC Modular, LLC.

3. "Forest City" shall mean Forest City Ratner Companies, LLC and/or Forest

City Ratner Enterprises, Inc. and any of their members, officers, former officers, directors,

former directors, agents, former agents, employees, former employees, partners, former

partners, assignees, successors, parent organizations, affiliates, or subsidiaries, or any of its

divisions, branches, or departments and all other persons or entities acting on its behalf.

3. "Berlin Rosen" shall mean Berlin Rosen Ltd.

4. The term "documents" used herein shall mean all writings of any kind,

including the originals, all copies, and all non-identical copies, whether different from the

original by reason of any notation made on such copies, or otherwise, and includes, without

limitation, all drafts, alterations, modifications, changes and amendments or any document

and any graphic or aural records of representations of any kind (including without limitation,

photographs, charts, graphs, microfilm, video tape, recordings, motion pictures) and

electronic, mechanical or electric records or representations of any kind (including, without

limitation, tapes, cassettes, discs, recordings, E-mail discs and printouts, voice mail

recordings). LAW OFFICES

Peckar & Abramson A Professional Corporation

SCHEDULE A

DOCUMENTS TO BE PRODUCED PURSUANT TO SUBPOENA DUCES TECUM

All documents concerning the Press Release, including all documents identifying (1)

its preparation and contents; (ii) any person or entity which or whom authorized Berlin Rosen

to issue the Press Release; (iii) to whom the Press Release was issued; and (iv) all inquiries

made to Berlin Rosen or Jeremy Soffin regarding the Press Release and any response(s) made

to such inquiries including any person or entity which authorized such response(s).

LAW OFFICES

Peckar & Abramson -#411033v2-

A Professional Corporation

EXHIBIT A

From: "Miller, Beth" <Beth.Miller@skanska.com>

Date: September 5, 2014 at 5:38:15 PM EDT

To: "Kennedy, Richard" <Richard.Kennedv@skanska.com>, "Didda, Nicole"

<Nicole.Didda@skanska.com>, "Crane, Tom" <Tom.Crane@skanska.com>, "Tina Cassidy

(tina@inkhouse.com)" <tina@inkhouse.com>

Subject: FW: FCRC Modular complaint filed against Skanska Modular and Richard Kennedy

Looks like the waited to the end of the day to surprise us ©

Shall I just send the statement we landed on?

Just reading this now...

Thanks,

Beth

Elizabeth Miller Director, Communications Northeast

Skanska USA Inc. Coinrnunications

use.skanska.com 350Fin Avenig3 32r;d New Ycric. NY 10118, United Staten

Phone -1 917 438 4523 Mobile 917 656 5883 Fax 1-1 866 701 21414

Connect kAliti Us* Bled Facebook i Twitter I Linked in I Instegrarn I YouTuLlc-4.

Think twice before you press "print." This menage. including any attachments hereto, may contain privileged or confidential information and is sent solely for the attention and use of the intended addressee(s) If you are not an intended addressee, you rnay neither use this message nor copy or deliver it to anyone In such case; you should immediately deslicy this message and kindly notify the sender by reply email. Thank you.

From: Post, Nadine [mailto:nadine.postPmhfi.com] Sent: Friday, September 05, 2014 5:21 PM To: Miller, Beth Cc: Korman, Richard Subject: FW: FCRC Modular complaint filed against Skanska Modular and Richard Kennedy Importance: High

Any comment? (My colleague Richard Korman is taking over for now. I am writing a cover story on modular, as you know. If Richard wants to speak to me, I will pass my notes to Richard Korman. ) Nadine M. Post Editor-at-Large

Engineering News-Record Two Penn Plaza 9th Floor, New York NY 10121-2298 T 212.904-4139 nadine.post@mhfi.com (New) Download EMI news @ enr.com/newsapp

FCRC Modular Press Release, September 5, 2014

From: Jeremy Soffin <ieremy@berlinrosen.com> To: Jeremy Soffin <Ieremy@berlinrosen.com>

Subject: FCRC Modular complaint filed against Skanska Modular and Richard Kennedy

Apologies for the timing but this was just filed.

FCRC Modular representatives tried to enter the factory today and were barred by Skanska. Building on

yesterday's letter we are moving forward with efforts to re-open the factory as follows:

Today, FCRC Modular filed suit against Skanska Modular and Richard Kennedy. FCRC Modular and

Skanska Modular are partners in a joint venture called FC+Skanska LLC ("the Company") that leases and

operates the factory where the modules for the B2 BKLYN project are fabricated. The complaint asserts

a breach of contract claim against Skanska Modular for issuing furlough and WARN Act notices to the

factory's employees, resulting in the mass layoff of over 150 workers and the stoppage of work, without

the approval of the Company's board of directors, as required under the Company's LLC

Agreement. The complaint also states a claim for tortious interference with contract against Kennedy

because he knowingly, wrongfully, intentionally, maliciously, in bad faith and without reasonable

justification or excuse induced Skanska Modular to breach the LLC Agreement. FCRC Modular is seeking

damages to be determined by the Court and an injunction to return matters to the status quo as they

were prior to Skanska Modular's issuance of the furlough and WARN Act notices and a stoppage of work

at the factory.

"FCRC Modular continues to pursue every possible measure to re-open the factory and put more than

150 people back to work. Yesterday, we offered to take full responsibility for the factory, which Skanska

rejected after having unilaterally stopped work and furloughed the workers. Today we are asking the

Court for an injunction that would allow us to re-open the factory immediately. We remain committed

to completing B2 as soon as possible despite Skanska's indifference to the wellbeing of these workers

and the project." -- MaryAnne Gilmartin, President and CEO, Forest City Ratner Companies

Also, in case you missed it, this quote was released today:

Brooklyn Borough President Adams, Council Members Cumbo and Lander Issue Joint Statement on

Construction Halted at B2 Tower

"It is unacceptable that a financial dispute has left more than 150 workers unemployed, jeopardizing the

economic stability of their families and further delaying the construction of affordable housing units in

Fort Greene. The completion of the modular apartment tower is vital to the working families who have

waited years for promises to become a reality. Forest City Ratner has proposed reopening the factory

immediately and assuming responsibility to resume operations, to keep this job on track and individuals

employed while the courts hear the broader issue. We urge both parties to work out a fair and amiable

agreement for the betterment of our community."