On February 05, 2015 a
Letter,Correspondence
was filed
involving a dispute between
Cdc Development Properties, Inc.,
and
American Independent Paper Mills Supply Co., Inc.,
Hudson Harbor Homes, Inc.,
for Commercial
in the District Court of Westchester County.
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August 31, 2017
Via Electronic Filing
Hon. Lawrence Ecker, J.S.C.
Supreme Court of the State of New York
Westchester County
111 Dr. Martin Luther King, Jr. Boulevard
White Plains, New York 10601
Re: CDC Development Properties, Inc. v. American Independent Paper Mills Co.
(“AIP”), et al.
Westchester County, Supreme Court Index No.: 51573-2015
Adversary’s Supplemental Attorney Reply Affirmation__________________
Dear Justice Ecker:
This office represents Plaintiff, CDC Development Properties, Inc. ("CDC") in connection
with the above referenced matter. Please be advised that we vigorously oppose the defendant’s
Supplemental Attorney Reply Affirmation both substantively and procedurally. With great respect,
we submit that the defendant’s papers filed August 30, 2017 should be disregarded and rejected in
their entirety.
The handling attorney for CDC, Mr. John Blumenstock, is travelling overseas until
Tuesday, September 5, 2017, and is unavailable to formally submit opposition papers until that
time. A formal response will be filed by end of day on Tuesday, September 5, 2017 when Mr.
Blumenstock returns.
Thank you for your time, your courtesy, your assistance, and your attention to this matter.
Very truly yours,
GALLO VITUCCI KLAR LLP
HOWARD P. KLAR
HPK/cg
Document Filed Date
August 31, 2017
Case Filing Date
February 05, 2015
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August 31, 2017 Via Electronic Filing Hon. Lawrence Ecker, J.S.C. Supreme Court of the State of New York Westchester County 111 Dr. Martin Luther King, Jr. Boulevard White Plains, New York 10601 Re: CDC Development Properties, Inc. v. American Independent Paper Mills Co. (“AIP”), et al. Westchester County, Supreme Court Index No.: 51573-2015 Adversary’s Supplemental Attorney Reply Affirmation__________________ Dear Justice Ecker: This office represents Plaintiff, CDC Development Properties, Inc. ("CDC") in connection with the above referenced matter. Please be advised that we vigorously oppose the defendant’s Supplemental Attorney Reply Affirmation both substantively and procedurally. With great respect, we submit that the defendant’s papers filed August 30, 2017 should be disregarded and rejected in their entirety. The handling attorney for CDC, Mr. John Blumenstock, is travelling overseas until Tuesday, September 5, 2017, and is unavailable to formally submit opposition papers until that time. A formal response will be filed by end of day on Tuesday, September 5, 2017 when Mr. Blumenstock returns. Thank you for your time, your courtesy, your assistance, and your attention to this matter. Very truly yours, GALLO VITUCCI KLAR LLP HOWARD P. KLAR HPK/cg