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Exhibit B · Filed by the owner in its own lawsuit

The City's Own Security Assessment

Prepared by W. Greg Kierce, Director, Jersey City Office of Emergency Management & Homeland Security, at the direction of the Business Administrator. Report dated April 10, 2025. It examined Portside Towers to test the owner's request to be excused from the 24/7 uniformed-security law, and it named the unsecured Korean War Memorial among the failures.

This is not the residents' account. It is the City's own homeland-security office, after interviewing the two tenant-association presidents and Equity Residential's own managers, and after consulting the New Jersey State Police. It found the property's security inadequate on multiple counts, and it reached a one-word conclusion about the owner's exemption request. “it is clearly evident that Port Side/Equity Residential Management fails to meet compliance … and their request for an exemption should be DENIED.”

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The assessment, page by page

“Unsecured Korean War Memorial Access Path … This requirement is consistently violated because there are no security personnel to implement it.”Kierce assessment, documented security failures (page 3)
Kierce security assessment, page 3
Page 3 of 6
This document is Exhibit B to the property owner's own verified complaint challenging the City's denial of its security-ordinance exemption (Superior Court of New Jersey, Hudson County). It is reproduced here as a public court record; the document controls. The characterizations on this page track the assessment's own words. Nothing here states that any company or person has been found by a court to have broken the law. This is tenant advocacy and First Amendment protected speech by residents and advocates, not attorneys, and is not legal advice. Maintained by the Portside Towers Tenant Association · the full record.