JOHN ROLAND, under penalty of perjury, declares and says:

1. I was a television anchor for Fox Five News in New York for 35 years. I submit this Declaration in support of plaintiff Jennifer Klein, and that she remain as Managing Member of Wine and Roses.

2. I have known Jennifer and Todd Klein for many years and have frequented Wine and Roses regularly since the day it opened.

3. Wine and Roses was and is the concept of Jennifer and Todd Klein.

4. Wine and Roses is a successful establishment because of Jennifer and Todd Klein’s hard work and dedication.

5. The unfounded accusations of the investors could not be further from the truth, since I believe that Jennifer Klein is the soul of Wine and Roses.

_________________________________________________________________

From: john roland  Date: July 22, 2010 1:35:24 PM EDT

Subject: Jennifer Klein

____________________________________________________________________

KAITY TONG, under penalty of perjury, declares and says:

_________________________________________________________________

On Jul 22, 2010, at 5:17 PM, Barbara Adler wrote:

Dear Jennifer and Todd,

I am so very sorry for all your recent troubles.  I really enjoyed working with both of you over the past four years, and as you know, I nominated Wine and Roses for an award with Manhattan Media, which it won, for being an outstanding establishment on Columbus Avenue.   

I thought that the renovation of your wine bar was spectacular, and that the attention you have shown to detail, such as the rose on each table, etc. has been fresh, lovely and unique.

Whenever I went by, I saw you or Todd at Wine and Roses, and have always felt that you were great managers of the place.    I am hopeful that things will work out well for you both.

Best regards,

Barbara

Barbara Adler, Executive Director

Columbus Avenue BID

_________________________________________________________________________________

July 22, 2010

To Whom It may Concern,

It is has been my pleasure getting to know the management at Wine and Roses located on Columbus Ave between 74th and 75th street. I have lived on the Upper West Side for ten years. I attended college locally in the neighborhood at Fordham University and I have seen plenty of Restaurants come and go throughout the years.

When Wine & Roses opened, my husband and I were so delighted, finally a great wine bar had opened up with a friendly and well run staff. We started coming to Wine and Roses weekly. We soon met Todd and Jen and Wine & Roses became hands down our favorite local hangout.

I just recently resigned as Managing Partner & Head of Global Marketing and Promotions for Three Company Stores from All American Taverns. I organized and executed all Quarterly Sales Plans, Marketing Strategies, Flyer Creation and headlined all weekly manager meetings at each restaurant. In addition I directed the corporations overall marketing and strategic planning programs, corporate contact communications, and network database. I was in charge of overseeing all recruitment, hiring and development of the bars staff and supervising all business development including intensive one–on-one work shops to teach and guide positions pertaining to: Event Planning, Electronic Marketing, Business Development Coordination, and handling both external and internal Communication Systems (websites, Advertising, Sales, Banners, Table Tents, flyers, etc). That being said, it speaks volumes that we often held lunch and early evening business meetings at your establishment. I, have personally sent countless friends, clients, and co-workers to Wine and Roses because I knew they would not be disappointed. and they never were. Jen and Todd always went above and beyond to accommodate our needs – on one occasion they went as far as to give us their home number once to make sure we could contact them directly if we needed to make a reservation or book a party. They made sure every time that our guests were treated right.

Every time I walk by Wine and Roses the restaurant is always packed. This is true sign that the management is doing an amazing job. As busy as it gets, you are never treated like a number and you are always welcomed and the staff works hard to make sure you are taken care of quickly. The management really does a nice job across the board.

In June of 2009, my husband and I got engaged in Central Park. After we had our whole family meet us at Wine and Roses to celebrate. Todd and Jen have made Wine a Roses a home to it’s neighborhood families and locals. They have managed to get to know almost all of their patrons by fist name. This is an amazing feat for any bar and restaurant owner. Their personal touches have made Wine and Roses - a place you want to come too. They have made Wine and Roses what it is today.

Lastly, I am on the board of a foundation called The Timothy C. McWilliams, Jr. Foundation: which raises money for victims suffering from Traumatic Brain Injury. Wine and Roses has been our home base for many group committee meetings. We often have board members from out of town attend as well and they are always delighted and impressed with Wine and Roses. Every year people search for A Wine and Roses - Wine Tasting Raffle Item to bid on at our annual fundraiser. It is one of favorite items, most sought after and asked about year after year. Each year over 700 New Yorkers attend our charity event - so this should help illustrate the influence Jen and Todd have had on us personally and on our organization.

It has been my pleasure working with Jen and Todd and getting to know them and Wine and Roses over the years. Please feel Free to contact me anytime.

Sincerely yours,

Katie-Jane McWilliams

From: Siobhan Mccarthy 

Manager of Peters Bar for 22 years

Siobhan,
Manager
Peter's Bar

From: kim sawyer  (W&R Bartender)

Date: July 22, 2010 4:34:26 PM EDT

To: Todd Klein

Todd & Jen.

Jen, the presence you bring to the bar each night and the energy and love you have for the   people who work along side   you is astounding. You are the most caring and understanding managers I have had the pleasure of working with and believe your hard work is contagious, creating a strong team environment where we all want to work hard to achieve a common goal: creating the ultimate wine experience for our customers.

Todd,   your care and thought that goes into the operational process of running a bar is impressive. Aesthetically, you have created one of the most sociable and soothing atmospheres in the city. The small details are what matter in a highly competitive industry and your experience/talent and foresight are what put Wine and Roses on the Wine Lover's map of places one MUST visit in the city.

The bar you have both built from scratch has become a mecca for Manhattan socialites and Out-of-towners alike. We have a core group of locals who traditionally come in on a daily/weekly basis to catch up with Todd and Jenn and the staff, but there is all an   increasing population of   Downtowners, East siders, Brooklyners, etc   who are visiting Wine and Roses and this all stems from word of mouth and how fantastic the bar is, the owners (   YOU ) are and how knowledgeable the staff is about wine.

I couldn't imagine the Upper West Side without the Wine and Roses you both created.  I Love you both!  I can't thank you enough for inviting me into your Wine and Roese family over 1 1/2 years ago... The friendships I have made through working here will last a life time and we will all continue to carry this on from this day forward!  

Love,

Kimberly Sawyer

Ernst & Young LLP

_________________________________________________________________

Date: July 22, 2010 4:03:53 PM EDT

To Whom this May concern:

First let me tell you what pleasure it has been for me working the few short months I've been at Wine & Roses. Todd & Jennifer Klein run a first-class, respectable winebar with one of the most genuine, down to earth, hardworking staff with whom I've ever worked. All of the staff get along perfectly well, we enjoy each others' company and have respect for each other in and out work...which is rare to find in a group of women in the service industry! Most of this is due to Todd & Jen's approach to management and choosing quality, intelligent staff, and trusting us with their 4 years of hard work & dedication that is Wine & Roses. They treat us like family, and it is a familial vibe that permeates throughout our place of employment. Todd & Jen are friendly, accommodating, and have great hearts. They have put their blood, sweat, & tears into making Wine and Roses the success it is today. It seems ludicrous to me that they would do anything malicious or deceitful with their ownership of Wine & Roses. They take pride in the bar and encourage all of us on staff do to do the same. This is evidenced in the amount of regulars who come back nightly, the continued loyalty of the kitchen and bar staff, and the fact that many of us employees enjoy coming to Wine & Roses on our days off!    I feel so grateful to be a part of this family and hope to contribute to the continued success of Wine & Roses.

Sincerely,

*Cassandra Liveris*

_________________________________________________________________

From:    Courtney  (W&R Bartender)
Subject:    Re: Wine and Roses
Date:    July 21, 2010 12:55:50 PM EDT

To whom it may concern,

I have worked for Todd and Jennifer Klein for almost two years at Wine and Roses. In the bar industry, it is usually unheard of to stay any longer than one year.    But, to leave Wine and Roses-- when run by Todd and Jennifer--would be like to leave a home.  

Throughout the years that I have worked at this establishment, the Kleins created an atmosphere of familial warmth. As this court process unfolds, the fact is that Todd and Jennifer are the soul of Wine and Roses, while the staff provides the heartbeat for the establishment.    Without all of us, it is just a place with tables and chairs. In the best interest of the business, I hope that one can see how Todd and Jen, as well as the prior staff, are synonymous with the success of this establishment.  

Thank you,

Courtney

From: Jenna Gruttadauria   (W&R Bartender)
Date: July 21, 2010 12:19:48 PM EDT 
To: Todd Klein   Subject: Wine and Roses

____________________________________________________

July 21, 2010

To Whom It May Concern:

My Employment at Wine and Roses Bar and Cafe was from December, 2009 until Monday, July 19th 2010. During this time, I never witnessed Todd Klein or Jennifer Klein handle any of the cash flow.

Wine and Roses was an enjoyable place to work and was run very successfully by Todd and Jennifer Klein. As the head bartender, I contributed to the success of the business and I strongly believe after meeting with the new management team that they will not be able to keep it running smoothly.

Sincerely,

Hi Todd,

I just wanted to say what a joy it has been to work at Wine and Roses under your and Jen's ownership.    Coming from many corporate restaurants, it has been a breathe of fresh air.    Everyone is truly a family.    I have never worked with all girls and liked every one of them.    The atmosphere that you and Jenn have created is so peaceful, easy, and classy.    I love that me and the girls are trusted to be in charge, take care of the guests and get to know them.  

Thank you that you even trust others with the tips, cash register, and closing moneys.  You never touched the moneys and just trusted us to safely calculate it and place it all in the safe.  Thank you for believing in us and entrusting your baby in our arms.

All my love,

Date: July 20, 2010 5:02:10 PM EDT

"Todd @ Wine & Roses"

Subject: Wine & Roses Letter of Support

I am writing this letter in support of Wine and Roses Bar and Cafes under the management of Jennifer and Todd Klein. I started my employment at the bar at the end if May 2010. For the past two months I could not have had a more pleasant, professional, and safe working environment. Mr. and Mrs. Klein show nothing but respect for their employees and business' well-being.

I have both opened and closed the bar as a bartender over the past two months. Every cent is meticulously counted, recorded, and sent to Mr. Klein on a nightly basis. I have no reason to believe that Mr. or Mrs. Klein have ever acted irresponsibly with the bar's revenue or the tips to the employees. At the end of the night, the two closing bartenders count the money in the register and make sure that the bank matches the total cash sales plus the starting bank of the day. The bank is then sealed in an envelope with the amount enclosed written and circled on the outside. The closing envelopes are then placed in the safe through the drop box in the top. The closing system is very effective and I feel safe doing it because we lock the outside door, take the money to the office to count it, and there are security cameras recording all of these actions 24/7.

I have worked in many establishments over the years, and honestly, this bar has been one of my favorite and most pleasant work experience thus far. If you have any questions about my statements, please let me know.

Thank you for your time.

Sincerely,

Lauren Rayner

_________________________________________________________________

Hi Jen,

I really enjoyed my experience at Wine and Roses as a server and bartender.    When I first started, I was impressed by the prestigious, diversified wine list and I foresaw an opportunity to learn a lot about wine culture. The style of the program was different from what I had seen prior in New York City. To have single-vineyard wines as by-the-glass options gave the customers, especially wine-savvy people a real unique opportunity to explore the wine world without having to necessarily depend on others to share or commit to a bottle.  It therefore gave us employees the opportunity to be mini-ambassadors for each winery.  To really emphasis what they were drinking, and to express the meaning that stood behind each and every bottle.

As the face of Wine & Roses, you brought such a warmth to the atmosphere.    You treated each and every customer as you number one guest and you were always extremely accommodating.    Your generosity was clearly appreciated by all and your attention to detail really helped to create a romantic, attractive atmosphere for the go-to date spot that Wine & Roses is night after night.

I'll always remember the experience!

All my best,

Christine

___________________________________________________________

To Whom It May Concern:

This letter is being written with the intention of showing my support for Ms. Jennifer Klein with whom I've had a friendship for the past 30 years.

Throughout the years, I have admired Jennifer's honesty, discipline and unerring sense of fairness with her staff and vendors. Previous to opening Wine and Roses, Jennifer developed and ran a company manufacturing high-end food items.

She opened many doors in New York and the Hamptons due to her business ethics and the fact that she honored all commitments.  Naturally, I have been a patron of Wine and Roses since its inception.

Everyone in the neighborhood seems to know Jennifer as she personally greets all who enter her establishment and makes them feel at home. I have seen how fairly Mrs. Klein treats her staff and should you ask anyone who works for her, they would tell you they are a family.

Jennifer's moral character is beyond reproach. I know this as a friend and someone who is in great admiration of  her unusual combination of attributes--strength of character, humility, fairness and respect for all those that are lucky enough to cross her path.

As I am traveling at the moment, please email me should you wish any more information.

Sincerely,

Laurie Roper

On Jul 27, 2010, at 10:02 AM, Leslie Cruden wrote:

Jenifer,

Don’t give up the fight; even if that fight is a new place!    When we met, something in my core just truly liked you!    You have a cheerleader in me.    Please keep me in the loop…you will succeed…it’s just who you are.

Warm Regards,

Leslie Crunden

Member Relationship Manager

New York State Restaurant Association

_______________________________________________________________

Jennifer --

I don't know what to say...."I'm sorry"....just doesn't say it all well enough.

I know you two have to be devastated.    I'm in shock.    I really didn't expect the worst outcome would be the final one.    Is there any hope for negotiations, so that you and Todd come out with something, anything??

You two are fortunate to have so, so many friends in your corner...you've wisely cultivated meaningful friendships over the years there.    The "phoenix" always rises from the ashes.

The important thing is that you two are together....you're strong, with vast expertise and creativity...and, you've got each other.

-- Karalenne --

P.S.    I'll take you up on your offer for dinner in the park, under the stars and   moon.    I've never had squirrel before, but I'm sure it can be very tasty once it's marinated for a few hours in wine...     

___________________________________________________________

On Jul 27, 2010, at 12:25 AM, Sharon wrote:

Hi guys,

Don't know details, but know it didn't go as we had hoped today. Chins up, life goes on and those assholes will get what they have coming. Tomorrow is another day. As Dylan Thomas said do not go gentle into that dark night. Rage, rage against the dying of the light. You will be fine, just another chapter. Thinking of you always.

Much love

Shazxxx

_______________________________________________________________

_______________________________________________________________

Hi Jennifer:

Sorry to hear about the situation at the Wine Bar.    Its very sad that you and Todd have to go through this as you certainly do not deserve it.

You have always supported me as a sales rep and did right by me and my company.    We have never experienced a payment issue and I have been working with you since you opened; I think we have good relationship.

My sincere wishes for a successful conclusion and I look forward to seeing you at the bar soon.

Best,

Jennifer Spiering

_______________________________________________________________

...I wish you two the best of luck fighting this monsters and i'll be back in the city in 3 weeks to fight along with you in this WAR that i know we'll win...may the force be with you (star wars)

Take care and please say hello to all your loyal employees for me.

Your friend and fighter :)

XxxOoo  Victor Reyes  Peru

_________________________________________________________________

On Jul 24, 2010, at 12:35 PM, Nancy Dineen wrote:

As a friend and patron of Wine & Roses, I must speak of the travesty of the "other partners" trying to throw Jennifer and Todd out of the restaurant. I was there and lived near the restaurant from the beginning and witnessed the hard work and dedication that Jennifer put into the opening of Wine & Roses.    It seemed she was the ONLY one doing all the work. She worked day and night for many many months to get the restaurant perfect and ready to be opened.    I walked by there every day and it was only Jennifer there with the workers!! Even before it opened, she stood there and befriended people walking by which insured them to be future customers.

After the opening, it was clear that a big reason the restaurant became to popular was Jennifer, herself.    She is not only beautiful, but gracious, warm and personable. She makes every single person who enters feel special! She makes every woman feel beautiful!!

Jennifer is WINE & ROSES!!

It is beyond my comprehension why these other partners would want to remove what is obviously the most precious asset of Wine & Roses. They have to be the dumbest people on the planet. I, for one, and most of my friends will not be going there should Jennifer and Todd be thrown out!!

Once again, Jennifer is Wine & Roses!   If it wasn't for her their would be no Wine & Roses!

N. Dineen

______________________________________________

TO WHOM IT MAY CONCERN:

Jennifer and Todd have been best of friends with us for the last 10 years. We have

frequented their bar and have had only the best of service and the best of

times there. They have put their heart and souls to make their business the

greatest wine bar ever and they have truly succeeded.

Sincerely,

Mr. & Mrs. Ian G. Rae,
Ian G. Rae, Former Executive Vice President, News, Fox Television Stations, Inc

_________________________________________________________________

On Jul 23, 2010, at 11:22 AM, Contreras, Elmer wrote:

Dear Jennifer,

I want to write a note to express my surprise regarding the last events that have taken place at Wine & Roses.

Frederick Wildman and I, are hoping for the best and we value the great business relationship that we have accomplished since the opening of your bar in August 2006.

Our support goes to you and your staff; and hope this situation is solved.

Sincerely

Elmer E. Contreras

Metro New York Sales Manager

Frederick Wildman & Sons

   _________________________________________________________________

_________________________________________________________________

On Jul 22, 2010, at 5:46 PM, Richard Sher wrote:

Dear Jennifer,

Since the inception of Wine & Roses you and Todd have worked so hard to make the wine bar a successful establishment on the upper West Side even during the recession. Your presence with Todd on a daily basis has made the wine bar a popular hang out for the rich and famous.

The party I had for my wife was terrific as you took care of all the details and made it a fantastic event.

The success of Wine & Roses is solely due to you both.

Best regards

Rich

Sher Plastics Co.

_________________________________________________________________

I am at a loss today... I have personally known Jennifer & Todd Klein for 35 years and I would like to take the opportunity to stand behind their commitment to Wine & Roses.

In all of the years I have known Jennifer and Todd they have always taken great pride and have demonstrated dedication, devotion and untiring hours to creating their establishment and making it what it is today.   

On Jul 22, 2010, at 4:27 PM:

Oh boyJen, you have so much you're dealing with, Christ! First your mom, and then Todd.    Hope they are both well, but you better take it easy or you will be getting sick too, God forbid.

I hope your customers will boycott the bar while you and Todd aren't there - then the greedy bastards will get the message.

If there is anything you need, or anything we can do for you, you know where to find me.

Be strong; Take care!!

Love Maureen

_______________________________________________________________

On Jul 22, 2010, at 4:18 PM,

To whom it may concern:

Like a number of people we have seen the press about the conflict between the Wine & Rose investors and Jen and Todd. We think we have some special insight into the situation which we would like to share. We live in the neighborhood and were literally there at the launch of W&R. We first met Jennifer at a competitor wine bar when she was scouting locations and developing the concept. She quizzed    us for almost an hour about likes/dislikes etc in a wine bar. She was

a woman on a mission. She may not even remember the event because it was clear that she was doing considerable research and was interviewing a number of people.   

As a result though, we took particular interest in the growth, development and success of the bar. We became "regulars" and were able to see first hand that this was their baby - every aspect. Every detail was labored over. Even the wine racks on the wall.

I am a private investor myself and the main criteria for me in choosing investments is management. The integrity, passion, commitment, dedication and talent of management. Todd and Jen showed us to have all of those in abundance. Inspiration and perspiration, they were 110%. To the regulars, or the one time visitor, it is crystal clear that the success of the establishment is solely because of Jen and Todd.

Speaking as an investor, again, I can't imagine that the bar will remain successful without them being there. They are as much a part of the bar as the wine itself.

In short, we would like to step forward to endorse and support them and be a reference for them. Please feel free to contact us with any questions or further elaboration on this letter.

Nathan and Joy

___________________________________________________________

So sorry to hear what happened...

I was appalled when I found out what was going on at Wine and Roses.    Every time I've been there it is very obvious that Jennifer is an integral part of this business, there would be NO business without her insight and foresight on what it takes to make Wine and Roses successful.   An indispensable addition to her business acumen is her genuine warmth, her face lights up talking with her customers, she is truly interested in their needs both as a business woman and on a personal level.      There are many wine bars to chose from but Jennifer is the reason why her customers choose Wine and Roses.

Maryann  _____________________________________________________________

On Jul 22, 2010, at 3:41 PM, Joni Moehring wrote:

It's Joni here (huge W&R fan and UWS neighbor) just wanted to say I'm sorry for all the unfortunate stuff you had to endure this week, but was so HAPPY to see a sign saying you're back!!  (NOTE: NOT YET.)  Wine and Roses would not be the same without your charisma and never-ending hospitality!!      

Hopefully this nightmare is behind you, and please let me know if there's anything I can do to help....I'm rooting for you!!!    Best wishes!!!    Joni

*and look forward to seeing you soon @ W&R!!!!

_______________________________________________________________  

Dear Jennifer...

All the best and can't wait to see you,

Tony

(Executive Producer, Academy Award Best Picture of the Year:
“The Hurt Locker”)

_______________________________________________________________

On Jul 22, 2010, at 3:16 PM, Kelly Wright wrote:

Dear Jen and Todd,

I am so glad to hear the news that you were able to get Wine & Roses back (note: not yet)   You and Wine & Roses are a shining light in our little UWS neighborhood.    I look forward to toasting to your return!

Cheers,

US Country Manager Esporao Wines & Olive Oils, Inc.

I've been a patron of Wine and Roses for the past several years.    The Klein's, both Jennifer and Todd, have always made me and my friends feel welcomed, comfortable and very well taken care of with their superb service.    From the beginning,   I'd see Jennifer look over every detail from their lovely decor to the menu and just getting to know her customers personally.  Both Jennifer and Todd treat their customers and staff wonderfully.

Wine and Roses is the Klein's.  That is just it,   it would not be the same without them.    Nor would I ever want to enter it without the creators and founders of THEIR ESTABLISHMENT.

Sincerly,

Jeanne Leto

_______________________________________________________________

On Jul 22, 2010, at 2:00 PM,

I am so sorry for what is happening to you and the unfairness of the "investors" in trying to remove you.    I have watched you for about 4 years now and how you (and Todd) have put your blood, sweat and tears, and hours upon hours, into that business.    You have made it what it is today, which is spectacular, popular and most importantly, the success that it is.    I wish you luck in your battle to take back what is rightfully yours!

Best Regards,

_______________________________________________________________

On Jul 22, 2010, at 1:13 PM, Lori Schwarz wrote:

Jen honey,

How could they even think of ousting you from your bar???    You're the face of Wine and Roses!!!    Who's face do I look forward to seeing on my way home at night and who do I miss when you're not there???    You, of course!!!    I know everyone in the neighborhood feels that way!!!    I'm so sorry this drama has happened and hope you know you are loved, appreciated and admired!!!    I think someone might be jealous?

All my love,

Lori  

Jennifer

I was appalled when I read that your partners have accused you of mismanagement.

I have been a customer of yours since you opened and I have been very impressed with how smoothly the business has operated.

Having owned a restaurant myself for 6 years in Ct. I know that management makes all the difference between success and failure.

Your wine bar operates as smoothly when you are not on the premise as when you are present which is the secret of success. There is a reason that you are profitable and I give you (and Todd) all the credit.

Without you the business would not be the same.

regards

Lynn LaCava

_______________________________________________________________

On Jul 22, 2010, at 11:43 AM, Elisabeth Anderson wrote:

Dear Jennifer and Todd,

With luck, the Judge will award you enough in damages so you get enough to own the place outright.    That will be the only way you feel at peace about it.

Love,

Lis

_______________________________________________________________

On Jul 22, 2010, at 9:29 AM, Sabio, Gina wrote:

Hi Jen, CONGRATULATIONS!! When I read the story in the Post on Tuesday, I thought you and Todd work so hard building your business.    I wouldn't go back    without you and Todd running the bar.    I'm very happy you're fighting to keep what's yours.    I will stop bt again soon.    Let me know when you're ready for a second bar. With Best Wishes and Warmest Regards,
Gina

_______________________________________________________________

On Jul 22, 2010, at 8:17 AM, Anthony R. Mangano wrote:

Hi Jennifer,

My name is Anthony and I am writing you because I have seen the NY Post articles the last couple of days regarding your restaurant and I just wanted to say congratulations! (note: not yet) It is nice to hear good news about someone who has taken such pride, commitment and worked so hard to build a wonderful successful business. It’s funny because from me following your story in the Post is how I came to know about your restaurant. I am 29 years old and work in Midtown as a Financial Crimes Investigator. Since the article I have been interested in dining at your establishment. I was just wondering what the typical dress code is and whether you need to make reservations. Also, does your restaurant have a Facebook page?

I wish you and Todd all the successfulness for the future and look forward to meeting you and visiting Wine and Roses!!

Best wishes,

Anthony Mangan

_______________________________________________________________

COURTNEY DOWDEL, under penalty of perjury, declares and says:

1. I am an employee of Wine and Roses Bar and Cafe (“Wine and Roses”), a wine bar located at 286 Columbus Avenue, New York, New York. I submit this Declaration in support of plaintiff Jennifer Klein, and that she remain as Managing Member of Wine and Roses.

2. I have worked as an employee of Wine and Roses for almost two years under the employ of the Managing Member, Jennifer Klein, and her husband Todd Klein.

3. Jennifer and Todd Klein are the heart and soul of Wine and Roses and have created an atmosphere of familial warmth between the employees and the management.

4. Having Jennifer Klein as Managing Member of Wine and Roses is in the best interest of the business and is synonymous with the success of the establishment.

_______________________________________________________________

KIM SAWYER, under penalty of perjury, declares and says:

I have worked as bartender at Wine and Roses for the last year and a half. I submit this Declaration in support of plaintiff Jennifer Klein, and that she remain as Managing Member of Wine and Roses.

During my time at Wine and Roses, it was clear to me that Jennifer Klein created a strong team environment devoted to the customer experience.

Jennifer and Todd Klein have created a core group of clientele that are regular customers due to the environment the Kleins have created.

Both Todd and Jennifer Klein bring a presence to Wine and Roses that fosters an environment of cohesiveness, hard work and respect.

_______________________________________________________________

LAUREN RAYNER, under penalty of perjury, declares and says:

I am a Bartender of Wine and Roses Bar and Cafes, LLC (“Wine and Roses”), a wine bar and restaurant located at 286 Columbus Avenue, New York, New York. I submit this Declaration in support of plaintiff Jennifer Klein, and that she remain as Managing Member of Wine and Roses.

My employment at Wine and Roses began towards the end of May 2010, under the management of Jennifer and Todd Klein. For the past two months, I could not have had a more pleasant, professional, and safe working environment. Mr. and Mrs. Klein show nothing but respect for their employees and the business’ well-being.

I have both opened and closed the bar as a bartender over the past two months. Every cent is meticulously counted, recorded, and sent to Mr. Klein on a nightly basis. I have no reason to believe that Mr. or Mrs. Klein have ever acted irresponsibly with the bar's revenue or the tips to the employees. At the end of the night, the two closing bartenders count the money in the register and make sure that the bank matches the total cash sales plus the starting bank of the day. The bank is then sealed in an envelope with the amount enclosed written and circled on the outside. The closing envelopes are then placed in the safe through the drop box in the top. The closing system is very effective and I feel safe doing it because we lock the outside door, take the money to the office to count it, and there are security cameras recording all of these actions twenty-four hours a day, seven days a week.

I have worked in many establishments over the years, and honestly, this bar has been one of my favorite and most pleasant work experiences thus far, thanks to the management of Jennifer Klein.

KIM SAWYER, under penalty of perjury, declares and says:

I have worked as bartender at Wine and Roses for the last year and a half. I submit this Declaration in support of plaintiff Jennifer Klein, and that she remain as Managing Member of Wine and Roses.

During my time at Wine and Roses, it was clear to me that Jennifer Klein created a strong team environment devoted to the customer experience.

Jennifer and Todd Klein have created a core group of clientele that are regular customers due to the environment the Kleins have created.

Both Todd and Jennifer Klein bring a presence to Wine and Roses that fosters an environment of cohesiveness, hard work and respect.

JENNA GRUTTADAURIA, under penalty of perjury, declares and says:

I am a Bartender of Wine and Roses Bar and Cafes, LLC (“Wine and Roses”), a wine bar and restaurant located at 286 Columbus Avenue, New York, New York. I submit this Declaration in support of plaintiff Jennifer Klein, and that she remain as Managing Member of Wine and Roses.

I have only been working at Wine and Roses for a couple months, but in this time, I have developed close relationships with my co-workers and with the owners, Jennifer and Todd Klein. Wine and Roses is a very family-oriented environment, bonded together with team work and honesty.  

The bartenders are given 100% responsibility for the flow of service and the ringing of transactions. The bartenders, at the end of the night, count out the drawer and after computing the days starting bank plus the cash tips and subtracting the day’s receipts, the bartenders would arrive at the total of the bank we had just counted.

After this number was reached, the bartenders would place the bank in a sealed envelope and then into the safe with the other paperwork from the evening. Tory, our day time account manager, would then count out everything correctly again in the morning, as a precaution, and do the banking. Jennifer Klein has no contact with the money at all.  

I have never worked for a place as inviting and welcoming as Wine and Roses, as made possible by Jennifer and Todd, who are great managers. They are respectful and have great faith in their staff.

I only hope the rightful owners and the most qualified management, Jennifer and Todd, are granted access to do what they have been doing wonderfully for the past 4 years, and that is flawlessly run their wine bar, a little diamond in the rough of the upper west side bar scene.  

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Lorri and Marvin Scott

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