Upon the reading and filing of the following papers in this matter: (1) Order to Show Cause by the petitioner, signed February 3, 2016 (Garguilo, J.), and supporting papers, including Memorandum of Law; (2) Affirmation in Opposition by the respondents, dated March 4, 2016, and supporting papers; (3) Reply Affirmation by the petitioner, dated March 11, 2016, and supporting papers; and now

UPON DUE DELIBERATION AND CONSIDERATION BY THE COURT of the foregoing papers, the motion is decided as follows: it is

ORDERED that the application by Order to Show Cause of the petitioner, which seeks, inter alia, an order declaring that the petitioner is entitled to redeem the subject premises pursuant to Chapter 29 of the Suffolk County Adminstrative Code (Hardship Redemption Law) is hereby denied in all respects; and it is further

ORDERED that all restraints, stays of proceeding and injunctions set forth in the February 3, 2016 Order to Show Cause are hereby vacated; and it is further

ORDERED that counsel for the respondents shall promptly serve a copy of this Order upon counsel for the petitioner via First Class Mail, and shall promptly thereafter file a copy of the affidavit of such service with the Suffolk County Clerk.

In this action, the petitioner, a Limited Liability Company, alleges that the respondents wrongfully denied its application to redeem the subject property, 430 Fire Island Avenue, Babylon, New York, which was acquired by the County of Suffolk due to petitioner's nonpayment of real property taxes. Petitioner essentially alleges that although it is a Limited Liability Company, and although it failed to submit an application for redemption within 6 month period permitted as a matter of right pursuant to Local Law 16-1976 and Section 46 of the Suffolk County Tax Act, it should nevertheless be permitted to redeem the property within the 24-month period after the property's transfer, pursuant to Suffolk County Code Chapter 29 and County Law §215. In opposition, the respondents argue that because the petitioner is a Limited Liability Company, it is precluded from redemption because the 24-month redemption period does not apply to business entities. Petitioner contends that the respondents' denial of its application on those grounds was arbitrary and capricious because the Code does not expressly exclude Limited Liability Companies from such extended redemption period.

It is axiomatic that it is the role of the Legislature, not the courts, to make law and courts may not legislate under the guise of interpreting statutes (see Davis v Davis, 71 AD3d 13, 889 [*2]NYS2d 611 [2d Dept 2009] Bright Homes v Wright, 8 NY2d 157, 203 NYS2d 67 [1960]). It this regard, the court must read and give effect to a statute as it is written by the Legislature, not as the court may think it should or would have been written if the Legislature had envisioned all the problems and complications which may arise in the course of its administration (see Parochial Bus Systems, Inc. v Board of Education, 60 NY2d 539, 470 NYS2d 564 [1983]; Allen v Minskoff, 38 NY2d 506, 381 NYS2d 454 [1976]; Lawrence Constr. Corp. v State of New York, 293 NY 634, 59 NE2d 630 [1944]; Incorporated Village of Old Field v Hickey, 225 AD2d 666, 639 NYS2d 480 [2d Dept 1996]).

When construing a statute, effect and meaning should be given to the entire statute with every part and word forming an integrated text (see Corsello v Verizon New York, Inc., 77 AD3d 344, 908 NYS2d 57 [2d Dept 2010]). If the natural significance of the words employed involve no absurdity or contradiction, there is no room for construction and courts have no right to add to or take away from that meaning (id; see also Matter of Golub Corp. v New York State Tax Appeals Tribunal, 116 AD3d 1261, 984 NYS2d 454 [2d Dept 2014]; Matter of Pro Home Builders, Inc. v Greenfield, 67 AD3d 803, 888 NYS2d 182 [2d Dept 2009]). It is fundamental that a court, in interpreting a statute, should attempt to effectuate the intent of the Legislature (see Matter of County of Cheung v Shah, __ NY3d __, __ AD3d __, 2016 NY Slip Op 07043, [2016]; Majewski v Broadalbin-Perth Cen. Sch. Dist., 91 NY2d 577, 673 NYS2d 966 [1998]).

Here, the petitioner has failed to establish that the respondents applied the Code to petitioner in an arbitrary and capricious manner. Petitioner has not shown any instances in which the Code was applied differently to any other Limited Liability Company. Although the Code does not expressly exclude Limited Liability Companies from redemption within the 24-month redemption period, the Court finds that the relevant Code provisions and the legislative intent establish, as clarified by Resolution 1488-2014, (amended on July 17, 2014), that the 24-month redemption period applies to non-business entities. Since the petitioner has failed to meet its burden of proof, the petition is denied in all respects.

This constitutes the Order and Judgment of the Court.

Dated: January 4, 2017