LETTER / CORRESPONDENCE TO JUDGE - re: leave for move to dismiss - Cdc Development Properties, Inc. v. American Independent Paper Mills Supply Co., Inc., Hudson Harbor Homes, Inc.

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On February 5, 2015 a commercial case was filed by Cdc Development Properties, Inc., represented by Blumenstock, John U., Kaye, Andrew Charles, and Klar, Howard P., against American Independent Paper Mills Supply Co., Inc., and Hudson Harbor Homes, Inc., represented by Constantine, Mark E, in the jurisdiction of Westchester County. Judge Nicholas Colabella presiding.

                        
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                          GALLO Wanna

 

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December 14, 2016

VIA E-FILE

David Evan Markus, Esq., Court Attorney Referee
Supreme Court of the State of New York
Westchester County

111 Martin Luther King Jr., Boulevard

White Plains, New York 10601

Re: — CDC Development Properties, Inc. v. American Independent Paper Mills Supply Co.
Westchester County, Supreme Court Index No. 51573/2015
Court Order dated November 7, 2016

Dear Mr. Markus:

We represent the plaintiff, CDC Development Properties, Inc., in the matter referenced
above. Pursuant to Court Order (worked out before you on November 7, 2016,) our client’s
deposition was to take place tomorrow, December 15", and the defendant, by Mr. Peter Baselice,
was directed to submit to a deposition on Tuesday, December 20".

Today, defense counsel has written to plaintiff's counsel, unilaterally cancelling both
depositions on two bases. First, counsel states he is cu…