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.
Preview
MARK E. CONSTANTINE, ESQ.
106 NORTH BROADWAY
IRVINGTON, NEW YORK 10533
PHONE (914) 631-0410 FAX (914) 631-0440
April 15, 2019
VIA E-FILE
Supreme Court of the State of New York
Westchester County
111 Martin Luther King Jr, Boulevard
White Plains, New York 10601
Attn..: Hon. Lawrence Ecker, JSC
Re: CDC v. AIP, et al,Index No.: 51573-2015
CDC's Proposed Order E-Filed on 4-12-19
Your Honour:
Greetings. The undersigned is writing to advise that the above referenced Order
filed by CDC will be acceptable to the undersigned as long as the COurt will add the
following underlined identifying language to the second to last decretal paragraph of the
Order as follows: "ORDERED: the Court hereby imposes a Preliminary Injunction,
enjoining plaintiff CDC and its principal and lease guarantor KEVIN
KHOSROWSHAHI from selling, transferring, mortgr.gir.g or otherwise
hypothecating or encumbering the premises at 510 High Cliffe Lane, Tarrytown,
New York 10591 as further described in Control Number AO2899242, liber 12361,
further"
Page 223 in the Westchester County Clerk's Office; and it is
This language was presented to CDC's counsel earlier today via email but I have
received no response. Furthermore, it is respectfully submitted that the language is
merely clerical, ministerial and identifying in nature such that its inclusion imposes no
new or additional burdens on any party. Accordingly, if this minor edit is acceptable to
and can be made by the Court I hereby respectfully request that the Court settle and sign
this Order forthwith on consent so we can finally put this behind us. Thank you for your
continued thoughtful consideration in this regard.
Very truly yours,
Mark E. Constantine, Esq.
cc: John Blumenstock, Esq., Via efile
Document Filed Date
April 15, 2019
Case Filing Date
February 05, 2015
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MARK E. CONSTANTINE, ESQ. 106 NORTH BROADWAY IRVINGTON, NEW YORK 10533 PHONE (914) 631-0410 FAX (914) 631-0440 April 15, 2019 VIA E-FILE Supreme Court of the State of New York Westchester County 111 Martin Luther King Jr, Boulevard White Plains, New York 10601 Attn..: Hon. Lawrence Ecker, JSC Re: CDC v. AIP, et al,Index No.: 51573-2015 CDC's Proposed Order E-Filed on 4-12-19 Your Honour: Greetings. The undersigned is writing to advise that the above referenced Order filed by CDC will be acceptable to the undersigned as long as the COurt will add the following underlined identifying language to the second to last decretal paragraph of the Order as follows: "ORDERED: the Court hereby imposes a Preliminary Injunction, enjoining plaintiff CDC and its principal and lease guarantor KEVIN KHOSROWSHAHI from selling, transferring, mortgr.gir.g or otherwise hypothecating or encumbering the premises at 510 High Cliffe Lane, Tarrytown, New York 10591 as further described in Control Number AO2899242, liber 12361, further" Page 223 in the Westchester County Clerk's Office; and it is This language was presented to CDC's counsel earlier today via email but I have received no response. Furthermore, it is respectfully submitted that the language is merely clerical, ministerial and identifying in nature such that its inclusion imposes no new or additional burdens on any party. Accordingly, if this minor edit is acceptable to and can be made by the Court I hereby respectfully request that the Court settle and sign this Order forthwith on consent so we can finally put this behind us. Thank you for your continued thoughtful consideration in this regard. Very truly yours, Mark E. Constantine, Esq. cc: John Blumenstock, Esq., Via efile