We, the following residential dwellers, who are New York City voters, and owners of retail establishments in the neighborhood of Consolidated Edison of New York, Inc.'s Power Station located on 76th - 75th Streets, between the East River and York Avenue, New York, New York 10021 (hereinafter, the "75th/76th Streets Con Ed Station"), hereby seek redress from said utility for its reckless endangerment of our life and property in Con Ed's grossly negligent operation of its aforesaid facility, as evidenced in its repeatedly willful failure to prevent: dangerous explosions, resulting in heavy, metallic, hazardously heated manhole covers being hurled in the air and striking pedestrians, vehicles and surrounding buildings, causing serious bodily harm and injuries thereto; fires, with excessive, hazardous smoke that enters commercial businesses and private residences, causing serious injuries to health, as well as damage to property; constant interruptions of electrical power, resulting in brownouts and blackouts for commercial and residential neighborhood establishments which have suffered compensable damages.