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
O GALLO VITUCCI KLAR
LLP
John U. H. Blumenstock
Westchester Office
jblumenstock@gvlaw.com
646.695.1777
January 30, 2019
Supreme Court of the State of New York
Hon. Lawrence H. Ecker, J.S.C.
111 Martin Luther King Boulevard
White Plains, New York 10601
Attn: Hon. Lawrence H. Ecker, J.S.C.
Re: CDC Development Properties, Inc. v. American Independent Paper Mills Supply
Index No.: 51573/2015
Proposed Order following Oral Argument of January 16, 2019
Dear Justice Ecker:
With respect your honor, a stipulation should not require this amount of the
Court's valuable time. Defendant, having seemingly agreed to terms, keeps shifting the
goal posts and insisting on new language. Enough is enough.
Having gotten the Court to change the terms of the stipulation twice (once to
lessen CDC's time to post a bond from 15 days to 10, and once to require CDC to give
A.I.P. a copy of the bond before it is purchased,) defense counsel now wants to change
the agreement again.
We will agree to sign the stipulation we filed today. We will not agree to any
further changes. In the event that this is not agreeable to defendant, there is no agreement
and we ask the Court to decide the motion brought by Order to Show Cause and the
defendant's cross motion on their merits.
Thank you for your courtesy, your patience and your consideration.
Very truly yours,
GALLO VITUCCI KLAR LLP
John U. H. Blumenstock
JUHB/mf
Cc: Mark E. Constantine, Esq. (via e-filing)
Manhattan 90 BroadStreet, • New
12th Floor, New York, NY 10004 Jersey1 University
Plaza, Suite
306, Hackensack,NJ 07601
Westchester One BridgeStreet,Suite NY 10533
140, Irvington, •Long Island
100 Crossways Park West,Suite305, Woodbury,NY 11797
MAILING ADDRESS: 90 BROAD STREET, 12TH FLOOR, NEW YORK, NY 10004
Document Filed Date
January 30, 2019
Case Filing Date
February 05, 2015
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O GALLO VITUCCI KLAR LLP John U. H. Blumenstock Westchester Office jblumenstock@gvlaw.com 646.695.1777 January 30, 2019 Supreme Court of the State of New York Hon. Lawrence H. Ecker, J.S.C. 111 Martin Luther King Boulevard White Plains, New York 10601 Attn: Hon. Lawrence H. Ecker, J.S.C. Re: CDC Development Properties, Inc. v. American Independent Paper Mills Supply Index No.: 51573/2015 Proposed Order following Oral Argument of January 16, 2019 Dear Justice Ecker: With respect your honor, a stipulation should not require this amount of the Court's valuable time. Defendant, having seemingly agreed to terms, keeps shifting the goal posts and insisting on new language. Enough is enough. Having gotten the Court to change the terms of the stipulation twice (once to lessen CDC's time to post a bond from 15 days to 10, and once to require CDC to give A.I.P. a copy of the bond before it is purchased,) defense counsel now wants to change the agreement again. We will agree to sign the stipulation we filed today. We will not agree to any further changes. In the event that this is not agreeable to defendant, there is no agreement and we ask the Court to decide the motion brought by Order to Show Cause and the defendant's cross motion on their merits. Thank you for your courtesy, your patience and your consideration. Very truly yours, GALLO VITUCCI KLAR LLP John U. H. Blumenstock JUHB/mf Cc: Mark E. Constantine, Esq. (via e-filing) Manhattan 90 BroadStreet, • New 12th Floor, New York, NY 10004 Jersey1 University Plaza, Suite 306, Hackensack,NJ 07601 Westchester One BridgeStreet,Suite NY 10533 140, Irvington, •Long Island 100 Crossways Park West,Suite305, Woodbury,NY 11797 MAILING ADDRESS: 90 BROAD STREET, 12TH FLOOR, NEW YORK, NY 10004