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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. 33 RECEIVED NYSCEF: 06/11/2021 Exhibit 2f(i) FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/11/2021 Septernber 14, 2020 06151-0003 Lawrence O. Graham, Esq. Cuddy& Feder LLP 445 Hamilton 14th Floor Avenue, White Plains, New York 10601 RE: 11 Dolma Road (Request forCertificateof Appropriateness) ""'*" Response to Ann Cefola Gregory Nm Diimy Dear Mr. Graham: The purpose of thisletteristo respond toinformation included in adocument written by Ann Gregory "errors" representations" Cefola that identifiesa group of and "systematic inour original dated letter, May 15, 2020, that provided you with our opinion on whether thebuildings at 11 Dolma Road meet the Village of Scarsdale's Criteriato determine historicalimportance. The present letteralso refers to supplemental information on the same subject provided to you in ourletterdated August 20, 2020 Sc:cnco& Tedmology "ERRORS" 1.0 RE. IN Ol)R Q RIGINAL 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 toconvey thatMr. Gregory was a pioneer in establishing grapefruit growing in Califomia, not that he was a grower himself.I reviewed the sources she cites in addition to others and understood at the time of my initialreport that Eugene Gregory was not a grapefruit-grower himself. Regarding histirne 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 articlesin historicCalifomia newspapers (forexample, the Sacramento Bee, the San Francisco Ca//, and the San Francisco Examiner) document histenure as mayor asspanning more than one year.In addition,an 1895 articlediscussing accusations against Gregory of fraudand theembezzlement termed him "one of the most widely-known men in theState by reason ofthe various prominent public positions occupied" Patent," he has ("Gone after a San Francisco Examiner 22 July 1895, p. 2). 1.2 Re. Julius Gregory's Education Itiscorrect that there was no architecturecourse per se atthe University of California atthe time Gregory studied there,but it alsoaccurate to statethat he studied mechanical engineering. architecture" Itis notthe case, however, thatthere was no "instructionin in the United States inthe 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 at the University of Wisconsin at Madison to theeducation of Julius Gregory. With few exceptions,.Arnerican architecturaleducation up untilWorld War II waslargely based on the rnethods of instruction ofthe Ecole des Beaux-Arts in Paris.The history of this instruction begins before the CivilWar, The firstAmericans to study architecture at the Ecole were, 670 Mountain B1vdExt famously, Henry Hobson Richardson and Richard Morris Hunt; of these, Hunt was the firstto PO Box 4039 graduate from the Ecole. Hunt established his own studioin New York (equally famously) City Warren, NJ 07059 in the 10th Street Studio both building he designed in 1857, teaching and employing young I. 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 firstcollegiate program in architectural education in the United States, at MlT, beginning in 1888 80ther inllnwortnuit·in187a Thnman Wohn Richarrin hat-mmo the 11rct nrnfocenr anhnnIn FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/11/2021 Lawrence O. Graharn, Esq. 11 Dolma Road (Request for Certificateof Appropriateness) Response toAnn Gregory Cefola September 14, 2020 Page 2 of and architecture at the of Pennsylvania.H In the Columbia drawing University 1880s, established a department of architecture, wooing Ware away from MIT with the offerof a substantial raise. At the University of California, the important Bay-area architect Bernard Maybeck taught architecturaidesign from 1894 to1903. Despite the basis of theearliestprograms in theEcole's methods, a significant number of young American architects continued to pursue study at the Ecole itself or in Beaux-Arts schools in other French cities.Harvey Wiley Corbett, also a student at the University of Califomia, in "atelier" whose Gregory reported he studied, was one ofthese Americans who studied atthe m Gregory's architectural in themethods of theEcole was not as complete Ecole Thus, training as if hehad studied at the Ecole itself. 1,3 Re. the ProfesMoña! 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 architecturaljournals, scholarly articles, National Register nominations, 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 terin toindicate that there was no published period record of a business associauon. Conventionally, associated architectson a projectare identifiedas such in publication.In regard to thebuildings Ms. Cefola cites inHouse & Garden published in 1921 as indicating an associated architect relationship between Gregory with Buchman & Kahn for the projects illustrated there, the magazine identifiesBuchman & Kahn as the designers of one of houses and Gregory as the designer of the other two The accompanying textgives no indication ofa professional association or collaboration. Thematic articlesthat linkdesigners and juxtapose theirwork inthe manner represented by thisissue Were a cornrñonplace in the architectural press and do not constitute documentation of association between firmsor practices to produce a design or 00 opleted building or buildings, The Avery index to architecturalperiodicals (now a ProQuest database) which we consulted as part of our research inaddition to key word searches indigitizedperiod sources, gave no indication ofprojects on which Gregory and Buchman & Kahn were associated. Review ofthe records ofthe Buchman & Kahn drawings in thecollection of theAvery Libraryavailable online identifiedthreeprojects forwhich there are drawings in the Buchman & Kahn collectionin which Gregory is also named as a creator. The catalog record forthe project noted by Ms. Cefola does not identifyGregory as an associated architect on the project. It simplyidentifieshim as a creator, and the relationship between Gregory and Buchman & Kahn is not identified.In addition, a period articleina professional architecturaltrade journal identifiesGregory as the only architectfor theChurch of AII Nations projectto which Ms. Cefola refers Two commercial ojects - the 1922-23 Gilbur Corporation at the northeast corner of 75 Avenue and p building 37M Streetin New York and the design for the 1920-21 Steiger-Vedder City Company Building in Hartford - note as the associated architect in the of drawings available Gregory catalog through the Avery library'swebsite. Thus, the record of thisassociation with Buchman & Kahn isminimal, and does not extend to records published in theperiod, on whichouranalysiswas based. 1.4 Re. Styles As in the previous item, the analysis ofstyles forwhich 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. Ifocused on these "master" sources because the assessment of an architect as a rests on whether hisor her greatness isgenerally recognized, and therefore the publicationof an architect'swork is akey indicatorof thisrecognition. Because architectsintheperiod did notapproach styledetailsfrom historicalsources in an archaeological manner in thesense of copying whole historicbuildings, term"Normandy" rny use of the covers a range ofstyle detailstaken from (largelyvernacular) hidldinns whnse datem mnannpd frarñ thA fñAdioumi norind inin the couontoonth conhmu M FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/11/2021 Lawrence 0. Graham, Esq. 11 Dolma Road (Request for Certificateof Appropriateness) Response toAnn Gregory Cefola September 14, 2020 Page 3 northern France and England. The detailsand materials ofthese buildings were taken from a variety ofsource buildings ina variety of locationswithin thisgeographic and temporai range. Revival" Revival" Thus, the distinction'0etweep "Medieval and "Tudor is an artificial one that does not accurately reflectthe facts of architecturaldecorative 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 in my presentation to the HPC and supplemental report As forthe previous item, while itis the case the Gregory designed larger houses, the projects that appeared in professional pub!!cetions,including in hisown article on the"Charm and Characte Cottage," of the English overwhelming 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 *$200,000 Scarsdale piece that appeared in several New York newspapers. As we noted in the supplemental report,"Itis notable that the piece begins withthe cost ofthe project - $200,000 - and thatthe isdescribed as *one of property size.' the last sitesavailable in thissection ofWestchester for an estate of this Thus, the 'importance' sought- of the building to the contemporary readership is itshigh price tag and location." after Rather than qualitative discussion of the importance ofthe design, quantitative measures (including the note thatthe house has seven bathrooms) are what stand out in this piece. The second publicationof the house was itsappearance promotional iin Collet's booklet. Neither of these publications constitutes a recügnition of design importance for the IMain Residence at 11 Dolma Road. 1.7 Re. Small Residences Please see item 1.5 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 scholarlyor popular publications on architecture ofthe period in any substantial way. Gregory':s role in the Fieldston districtis addressed in my supplemental letter. TION" 2.0 RE. "SYSTEMATIC MISREP.RESEl TA IN OUR ORLGINAL LETTEjR ("Wall" 2.1 Re. the Discussion of the Willis Vernon Cole Project and "bathroom") Ms. Cefola mistook the purpose of including this information. The sole purpose of these references was to document the earliestprojects by Gregory that appear inpublication, rather than to cast aspersions. This research was, in fact,extensive. ittook the .Avery index to architecturalperiodicals, the long-term gold standard of architecturalcommissionresearch. as a mere startingpoint. The Avery index identifiedprojectsby Gregory beginning only in 1920. The popular design-oriented and professional architectural journals which were reviewed included, but were not limitedto the following: • AmericanArchitect • ArchitecturalForum • Architecture 11 Dolma Rd -0143 • ArchitectureandBuilding FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/11/2021 Lawrence 0. Graharn, Esq. 11 Dolma Road (Request for CertificateofAppropriateness) Response to Ann Gregory Cefola Septernber 14, 2020 Page 4 • Architectural Record • Architectural Review • Country Life • House & Garden Relatively small prõjects are fairlytypicalof architects startingout, and that was the point of including a reference to this one. The McLaury TliteCompany advertisement (figure 1), appeared in 1916 in Architecture and Building, and is the earliest reference to Gregory in professional practice in publication. Because the advertisement notes thatthe work was forthe poet WillisVernon Cole, the client for the garden wall project(figure 2),I inferred that these were part ofthe same early projectand thatthe project did not constitutethe entire residence. My report went on to refer to the factthat Gregory's practice expanded thereañer to include design ofentire residences. 19' .·|NOt)T htTUREANDDU1130NG TILE WORK EXECLrTED BY D. H. Mc Laury Tile Co., Inc. 103 Park Avenue, New York sema erner streniansmmlutunas sadlerthecaetze ùftQnstructhin ApartenentHowees Realdences 06ileStreetan-1 l'.uk AventieN. Y. heSeleme of Mrs.Cr·o. TLTurnlaull, linysliurr, himr L. L 02ndMirectaril l'art Avenu, N. Y. & HurulanwL Ardnio-gs, . li tf. Unrponger, Aediiteel lhhimn Gnu 'Grea.uwwn, Painter& IlorntmstelArchh«ts ohnWheNu, N. Y.. Mt.Veruen, Mhcellaneous hcker & Vntet,Archkecu Wm,Iriggiem. Architect WIII Cok.SIm Am.. Francisco & J.wohips, Arth1tfCth WhiteMainsCoursHrune Ur,Dellermingham. IErn).W. 3torris,ArchileeiKYiW.·I5thSurn-t.N.Y. a surans- Ai,rnham swre.ureoklyn cremr.hmini.·mk, P0,icue,c..N.v. talierailuns) tichardScro.PortCItester. N.Y. .J'thrWI acI. nwimy e ow/mstmr Pa +Gw cog Figure 1: D. H McClaury Tile Company advertisement, Architecture and Buildin 48, no. 12: advertisements p. 10. 11 Dolma Rd -0 44 FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/11/2021 Lawrence O. Graham, Esq. 11 Dolma Road (Request for Certificateof Appropriateness) Response toAnn Gregory Cefola September 14, 2020 Page 5 Acres,' Figure 2: "Garden Wall, Estate Willis Vernon Cole, 'Shore Mamaroneck, N.Y., Architecture 38, no. 6 (December 1, 1918): 214. 11 Dolma Rd -0145 FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/11/2021 Lawrence 0. Graham, Esq. 11 Dolma Road (Request for CertificateofAppropriateness) Response to Ann Gregory Cefola September 14, 2020 Page 6 2.2 Re. Lovrien Price Ms. Cefalo provides family storiesnot available tothe public and notreflected in thepubi1shed record, Because Lovrien Price was clearlya talented and successful artist,1 elected tohonor her with the assumption that she was a well-connected professional 2.3 Re. AIA Fellowship The conferring offellowship marked a key recognition ofan architectby his (rarelyher) peers. Thus, electionto fellowship,which required the review ofan application and is portfolio, a key indicator ofwhether an architectcould legitimatelybe called a master. The importance of our discussion of feliewship (and itslack thereof) was forits iñdexical rolein the recognition of "master." greatness, as isrequired for the assessment ofstatus of "Designer" 2.4 Re. the Use of the Term "designer" Ms. Cefola mistook my meaning here as well,The term as it was used covers a range of professions, including, most notably, architects and landscape architects.It isnot a pejorative term, and was not used that way in our report. Itwas used inthe 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 -0146 FILED: WESTCHESTER COUNTY CLERK 06/11/2021 03:29 PM INDEX NO. 54241/2021 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 06/11/2021 Notes I On Columbia," Ware's educational career, see J. A. Chewining, "William Robert Ware at MIT and Journal of ArchitecturalEducation 33, no. 2 (November, 1979): 25-29, 'i Seehttps://archives.upenn.edu/exhibits/penn-peop|elbiagraphy/thomas-webb-richards ul Gregory's AIA file was cited in our original report.Corbett's record that he studied at the Ecole is included in his AIA file,which can be accessed at htto://content.aiaarn/sites/defaulfiles/2018- la™d" 09/CorbettHarveyWiley.pdf (accessed 14 September 2020). * York," The citation full for articleis"A Group of Three Houses Near New House & Garden 39, no 2 "°" (February, 1921): 39-41. v Hubert York," Van Vechten, "Church Building in New American Builder 41, no. 5 (August 1, 1926): 115 ff. Pt.uneSecor ReMEs1Mc so,oncea Pchrology 67BMountain Blvd Ext Po Box 4039 Warren, NJ 07059 1.732.550.9700 11 Dolma Rd -0147