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  • Onedol Rock Holdings Lp v. The Village Of Scarsdale, The Village Of Scarsdale Committee For Historic Preservation, The Village Of Scarsdale Board Of TrusteesSpecial Proceedings - CPLR Article 78 document preview
  • Onedol Rock Holdings Lp v. The Village Of Scarsdale, The Village Of Scarsdale Committee For Historic Preservation, The Village Of Scarsdale Board Of TrusteesSpecial Proceedings - CPLR Article 78 document preview
  • Onedol Rock Holdings Lp v. The Village Of Scarsdale, The Village Of Scarsdale Committee For Historic Preservation, The Village Of Scarsdale Board Of TrusteesSpecial Proceedings - CPLR Article 78 document preview
  • Onedol Rock Holdings Lp v. The Village Of Scarsdale, The Village Of Scarsdale Committee For Historic Preservation, The Village Of Scarsdale Board Of TrusteesSpecial Proceedings - CPLR Article 78 document preview
  • Onedol Rock Holdings Lp v. The Village Of Scarsdale, The Village Of Scarsdale Committee For Historic Preservation, The Village Of Scarsdale Board Of TrusteesSpecial Proceedings - CPLR Article 78 document preview
  • Onedol Rock Holdings Lp v. The Village Of Scarsdale, The Village Of Scarsdale Committee For Historic Preservation, The Village Of Scarsdale Board Of TrusteesSpecial Proceedings - CPLR Article 78 document preview
  • Onedol Rock Holdings Lp v. The Village Of Scarsdale, The Village Of Scarsdale Committee For Historic Preservation, The Village Of Scarsdale Board Of TrusteesSpecial Proceedings - CPLR Article 78 document preview
  • Onedol Rock Holdings Lp v. The Village Of Scarsdale, The Village Of Scarsdale Committee For Historic Preservation, The Village Of Scarsdale Board Of TrusteesSpecial Proceedings - CPLR Article 78 document preview
						
                                

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FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 06/11/2021 Exhibit 2e(ii) FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 06/11/2021 September 28, 2020 06151-0003 Lawrence 0. Graham, Esq. Cuddy& Feder LLP 445 Hamilton 14th Floor Avenue, White Plains, New York 10601 RE: 11 Dolma Road (Request for Certificateof Appropriateness) Response to Ann Gregory Cefola Dear Mr. Graham: sety The purpose of thisletter is torespond to information included in a document writtenby Ann Gregory "errors" representations" Cefola that identifiesa group of and "systematic in our originalletter,dated May 15, 2020, thatprovided you with our opinion on whether the buildingsat 11 Dolma Road meet the Village of Scarsdale's Criteria to determine historicalimportance. The present letter also refers to c t., supplemental information on the same subject pravided to you in our letter dated August 20, 2020 chn "ERRORS" 1.0 RE. IN OUR ORIGINAL LETTER 1.1 Re. Eugene Gregory's profession Ms. Cefola mistook my meaning in this discussion of her great-grandfather in the phrase pioneer." "grapefruit-growing This was intended to convey that Mr. Gregory was a pioneer in establishing grapefruit growing in California,not that he was a grower himself. I reviewed the sources she cites in addition to others and understood at the time of my initial report that Eugene Gregory was not a grapefruit-grower himself. Regarding histime as mayor of Sacramento, Mr. Gregory's New York Times obituary states that he served as mayor of Sacramento between 1887 and 1891, not 1887 to 1888 ("Eugene Gregory," J. New York Times 27 March 1916). Numerous period articlesinhistoric California newspapers (forexample, the Sacramei1to Bee, the San Francisco Call,and the San Francisco Examiner) document his tenure as mayor as spanning more than one year. In addition,an 1895 articlediscussing accusations against Gregory offraud and embezziement termed him "one of the most widely-known men in theState by reason ofthe various prominent public positions he occupied" Patent," has ("Gone after a San Francisco Examiner 22 July 1895, p,2). 1.2 Re. Julius Gregory's Education Itiscorrect that there was no architecture course per se at the University of Californiaat the time Gregory studied there, but it is also accurate to state that he studied mechanical architecture" engineering. Itisnot the case, however, that there was no "instructionin inthe United States in the 1880s and 1890s. The quote Ms. Cefola includes suggests thiswas the case when she applies Frank Lloyd Wright's experience ofthe lack of such a curriculum atthe University of Wisconsin at Madison to the education ofJulius Gregory. With few exceptions, American architecturaleducation up untilWorld War II was largelybased on the methods of instructionof the Ecole des Beaux-Arts in Paris.The historyof thisinstruction begins before the Civil War. The firstAmericans to study architecture at the Ecole were, 67B Mountain Blvd Ext famously, Henry Hobson Richardson and Richard Morris Hunt; ofthese, Hunt was the first to PO Box 4039 graduate from the Ecole. Hunt (equally famously) established hisown studio in New York City Warren. NJ 07059 in the 10th both street Studio building he designed in 1857, teaching and employing young t. 732.560.9700 architects. Hunt's atelierbecame an incubator for Beaux-Arts methods of education and practice.Among the members of Hunt's atelierwas William Robert Ware, who established the first collegiate program inarchitectural education in the United States, at MIT, beginning in 1868) Other schools followed suit:in 1874, Thomas Webb Richards became the firstprofessor 11 Dolma Rd - 0133 FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 06/11/2021 Lawrence O. Graham, Esq. 11 Dolma Road (Request for Certificateof Appropriateness) Response to Ann Gregory Cefola September 28, 2020 Page 2 of and architecture at the of Pennsylvania.ii In the Columbia drawing University 1880s, established a department of architecture, wooing Ware away from MIT with the offer of a substantial raise. At the University of California, the important Bay-area architect Bernard Maybeck taught architectural design from 1894 to 1903. Despite the basis ofthe earliestprograms in theEcole's methods. a significantnumber of young American architects continued to pursue study atthe Ecole itselfor in Beaux-Arts schools in other French cities.Harvey Wiley Corbett, also a student atthe University of California, in "atelier" whose Gregory reported he studied, was one ofthese Americans who studied at the Ecole E Gregory's architectural inthe methods of the Ecole was not as complete Thus, training as if hehad studied at the Ecole itself. 1.3 Re, the Professional Relationship between Julius Gregory and Buchman & Kahn As we stated in our initial report, our research surveyed published sources available indigital format and inhard copy of trade and professional architectural journals, scholarly articles, National Register acminations, and newspaper articles.We found no published basis for an association between Buchman & Kahn and Gregory and no period basis for a business "reported" relationship. Therefore, we used the term to indicate thatthere was no published period record of a business association. Conventionally, associated architectson a project are identifiedas such inpublication. Inregard tothe buildings Ms. Cefola cites in House & Garden published in 1921 as indicating an associated architect relationship between Gregory with Buchman & Kahn for the projects illustratedthere,the magazine identifies Buchrnan & Kahn as the designers of one of houses and Gregory as the designer of the other two) The accompany:ñg textgives no indication of a professional association or collaboration. Thematic articlesthat linkdesigñérs and juxtapose theirwork in the manner represented by this issue were common inthe architecturalpress and do not constitute documentation ofassociation between firms or practices to produce a design or completed buildingor buildings. The Avery index to architectural periodicals (now a ProQuest database) which we consulted as part of our research inaddition to key word searches indigitized period sources, gave no indication ofprojects on which Gregory and Buchman & Kahn were assüciated. Review of the records of theBuchman & Kahn drawings in thecmlimtinn ofthe Avery Library availableonline identified three projects forwhich there are drawings in theBuchman & Kahn collectionin which Gregory isalso named as a creator.The catalog record for the project noted by Ms. Cefola does not identifyGregory as an associated architecton the project.Itsimply identifies him as a creator, and the relationship between Gregory and Buchman & Kahn isnot identified. In addition, a period articlein a professional architectural trade journal identifiesGregory as the architectfor the Church ofAllNations project to which Ms. Cefola refers.vTwo commercial only projects - the 1922-23 Gilbur Corporation atthe northeast corner of7th Avenue and building 370 Street inNew York and the design for 1920-21 City the Steiger-Vedder Company Building in Hartford -- note as the associated architectin the of drawings available Gregory catalog through theAvery library'swebsite. Thus. the record of thisassociation with Buchman & Kahn isminimal, and does not extend to records published inthe period, on which our analysis was based 1.4 Re. Styles As in theprevious item, the analysis ofstyles for which Gregory was known was based on the publication of his projects in professional architecturaljournals because these publications represented the reception of Gregory's work on the part of his peers. I focused on these "master" sources because the assessment of an architect as a rests on whether his or her greatness is generally recognized, and therefore the publication ofan architect'swork isa key indicatorof thisrecognition. Because architects in theperiod did not approach styledetails from historicalsources in anarchaeological manner in thesense ofcopying whole historic buildings, "Normandy" my use of the term covers a range ofstyle detailstaken from (largely vernacular) buildings whose dates spanned from the medieval period intothe seventeenth century in PA06f51\0003kReportshErwirtCRMiMisc Letter Repor0.Drafts111 Dalma Road supplernental letter docx 11 Dolma Rd -0134 FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 06/11/2021 Lawrence O. Graham, Esq.. 11 Dolma Road (Request for Certificateof Appropriateness) Response to Ann Gregory Cefola September 28, 2020 Page 3 neithern France and Eñgland. The detailsand materials of these buildings were taken from a variety of source buildings in a varietyof locations withinthis geographic and temporal range. Revival" Revival" Thus, the distinctionbetween "Medieval and "Tudor isan artificial one that does not accurately reflectthe facts of architectural decorative practice in the period. More information on this isincluded in my supplemental report. 1.5 Re. the Role of the Small Cottage in Gregory's work This point was addressed inmy presentation tothe CHP and supplemental report.As forthe previous item, while itis the case that Gregory designed larger houses, the projects that appeared in professionalpublications, including inhisown articleon the "Charm and Character Cottage," of the English overwhelmingly concentrated on the small house, or cottage. 1.6 Re. the Publication of the 11 Dolma Road House As noted inour original and supplemental reports, there are two instances in which the house Home" appears in print.The firstis the "S200,000 Scarsdale piece that appeared in several New York newspapers. As we noted inthe supplemental report, "itisnotable that the piece begins with the cost of the project - $200,000 - and that the isdescribed as 'one of property size.' the last sites available in this section of Westchester for an estate of this Thus, the 'importance' sought- ofthe buildingto the uuniangorary readership isitshigh pricetag and location." after Rather than qualitativediscussion ofthe importance of the design, quantitative measures (including the note that the house has seven bathrooms) are what stand out in this piece. The second publicationof thehouse was itsappearance in Collet's prGrñGtiarialbooklet. Neither of these publications constitutes a recGgnition of design importance for the Main Residence at 11 Dolma Road. 1.7 Re. Small Residences Please see item1.5 above. 1.8 Re. Lack of CriticalAttention to Gregory This is addressed in our original assessment - there have been no monographs on the fully architect'swork, nor has he appeared in scholarly orpopular publicaticis on architecture of the period in any substantial way. Gregory's role in the Fieldston districtis addressed in my supplemental letter. MISREPRESENTATION" 2.0 RE. "SYSTEMATIC IN OUR ORIGINAL LETTER 2.1 Re. ("Wall" the Discussion of the Willis Vernon Cole PrGject and "bathroom") Ms. Cefola mistook the purpose of including this information. The sole purpose of these references was to document the earliestprojects by Gregory thatappear in publication,rather than to cast aspersions. This research was, in fact, extensive. It took the Avery index to architectural periodicals,the long-term gold standard of architecturalcommission research, as a mere starting point.The Avery index identifiedprojects by Gregory beginning only in 1920. The popular design-oriented and professional architectural journals which were reviewed included, but were not limitedto the following: • American Architect • Architectural Forum • Architecture • Architecture and Building • Architectural Record 11 Dolma Rd -0135 P10615 tW0034ReparisW-EnvMCRI.Mbsc Lelter ReportlDraftsT11 Doima Road suppiementai letterdoes FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 06/11/2021 Lawrence 0. Graham, Esq. 11 Dolma Road (Request for Certificateof Appropriateness) Response to Ann Gregory Cefola September 28, 2020 Page 4 • Architectural Review • Country Life • House & Garden Relatively small projects are fairlytypicalof architects starting out,and that was the point of including a reference to this one. The McLaury Tile Company advertisement (figure 1), appeared in 1916 in Architecture and Building, and is the earliest reference to Gregory in professional practice inpublication. Because the advertisement notes that the work was forthe poet Willis Vernon Cole, the clientforthe garden wall project(figure 2), I inferredthat these were partof the same early project and that the project didnot constitute the entire residence. My report went on to refer tothe fact that Gregory's practice expanded thereafter to include design ofentire residences ki ICST).C'TUNE ANDBUHA I G ONL.rFuW BATilROOys ty yr.wy..itica .8.l-AMMENT IRTr.51 w0I'It'I'll -E'S1.'E 11r313ER T1LE WORK EXECUTED BY D. H. Mc Laury Tile Co., Inc. 103 Park Avenue, New York ‰memmer rvessr c•waracra mosaeda..dham-se Ameww.:rke ApartnaentHouses Residences hathStreetandP.irkAvenue, N.Y. .dMrs.GeaR.Turgilmil. RC)f'Icme Hayshore, Uns)Suresaml]'ark Avenue. N. Y. L. L Pahner & Ilorabgirl..\rchaects AdamsRaidence. J l·. R ( arpeilterArchitect Co.m Gremwich. Palmt-r& flornluanel. Architect.s Mi.aceHaneou* JolmWhclem. Mt.Vers.on. N. Y. & \ atet.Architects Hocker Long 1.4diI CollegeHospital W.V,].awrence. Br.munk.N.Y. Wills\' 1.nle.Shurt·-\cres.. TrAircout's Bmidmg_ American M.3mar nenk. Y Park.gmlSmiramlAtes...Br lyrl Fram-iwri & jm.bu.. Archnects. WhitePlainsCourtIInuse Ford.Butler& Oliver.Anhitects W. hrr'.-. ,\reldicctllr l)r rmlticham. BeniSursu-' py, Y.-15hSUcrtN.Y Abraham & Starr,Brnoklyn Jeremiah PortChester. Milhank. N.Y. I Alteration3) Sotre,PostC]wster. Richard N.Y. Google Figure 1: D. H. McClaury Tile Company advertisement, Architecture and Building 48, no. 12: advertisements p. 10. 11 Dolma Rd -0136 Letter P.061SnODO3tReportstN-EnvihCRMiMtsc ReportkDransiII Dolma Roadsupplementa1leiter does FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 06/11/2021 Lawrence O. Graham, Esq. 11 Dolma Road (Request for Certificateof Appropriateness) Response to Ann Gregory Cefola Septernber 28, 2020 Page 5 N.Y.," Figure 2: "Garden Wall, Estate Willis Vernon Cole, 'Shore Acres Mamaroneck, Architecture 38, no. 6 (December 1, 1918): 214. 11 Dolma Rd - 0137 ;v4-- .:"EnvirkCRMiMasc P70615ns3G3.; Letter ReportiDraftsl11 Dobrun Road supplememal letter doca FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 06/11/2021 Lawrence O. Graham, Esq. 11 Dolma Road (Request for Certificate of Approprial.enw) Response to Ann Gregory Cefola September 28, 2020 Page 6 2.2 Re. Lovrien Price Ms. Cefola provides family stories not available tothe public and not reflected in thepublished record. Because Lovrien Price was clearlya talented and successful artist,I chose to honor her with the assumption that she was a well-connected professional. 2.3 Re. AIA Fellowship The cünferring offellowship marked a key recognition ofan architect by his (rarelyher) peers. Thus, electionto feliGwship, which required the review of an app!ication and is portfolio, a key indicator ofwhêther an architectcould legiti-±ly be called a master. The importance of our discussion of fellowship (and its lack thereof) was forits indexical role in the recognition of "master." greatness, as is required forthe assessment ofstatus of "Designer" 2.4 Re. the Use of the Term "designer" Ms. Cefola mistock my meaning here as well The term as itwas used covers a range of prafsssioris,inuiuciing,most notably, architects and landscape architects.It isnot a pejorative term, and was not used that way inour report.Itwas used in the instance cited "architect" because was used in another part of the same sentence, and the reason for including it wasto avoid repetition. Very Truly Yours, PAULUS, SOKOLOWSKI AND SARTOR, LLC. Emily T. Cooperman, M.S., Ph.D. Senior Architectural Historian 11 Dolma Rd -0138 PW615two031ReportnW-EnvriCRhNAisc Lener ReporttDramst11 Dalma Road suppememal lener docr FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 06/11/2021 Notes Columbia," On Ware's educational career, see J.A. Chewining, "Wil[iam Robert Ware at MIT and Journal of Architectural Education 33, no. 2 (November, 1979); 25-29. " See https://archives.upenn.edu/exhibits/penn,people/biographylthomas-webb-richards iii Gregory'sAIA filewas cited inour originalreport. Corbett's record thathe studied at the Ecole is included in his AIA which can be accessed at http;//content.aia.orq/sites/default/files/2018- file, 09/CorbettHarvevWilev.odf (accessed 14 September 2020). iv The York," full citation forarticleis "A Group of Three Houses Near New House & Garden 39, no 2 'V 1921): 39-41. (February, York," Hubert Van Vechten. "Church Building in New American Builder 41, no. 5 (August 1, 1926): 115 ff. 678 Mountain BIvd Ext PO Box 4039 Warren. NJ 07059 1.732.560.9700 11 Dolma Rd - 0139