LETTER / CORRESPONDENCE TO JUDGE (Motion #004) - RE: Improper Submission - Cdc Development Properties, Inc. v. American Independent Paper Mills Supply Co., Inc., Hudson Harbor Homes, Inc.

Download Document Print Document

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.

                        
						    Preview
                        
                        
                          GALLO VITUCCI

   

90 Broad Street * 3rd Floor ¢ New York, NY 10004
Tel: 212 683.7100 Fax: 212 683.5555
www.gvlaw.com

May 22, 2017

VIA E-FILE

Hon. David F. Everett, A.J.S.C.
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
Adversary's 2nd Request to Adjourn Summary Judgment Motion returnable May 5, 2017

Dear Justice Everett:

We represent the plaintiff CDC Development Properties, Inc. With great respect, we
submit that the defendant's papers filed May 19th in further opposition to plaintiff's Motion for
Summary Judgment, should be disregarded and rejected in entirety.

The papers submitted by defendant are in direct violation of your Court Order dated May
15, 2017. Defendant has submitted Sur-Reply papers dealing nearly exclusively with plaintiff's
original motion …