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001 .. GERALD A. VERGILIS* KENNETH M. STENGER ALBERT P. ROBERTS LOUIS 1. VIGLOTTI JOAN F. GARRETT** THOMAS R. DAVIS EMANUEL F. SARIS VERGILIS, STENGER, ROBERTS & PARTNERS, LLP AITORNEYS AND COUNSELORS AT LAW 1136 ROUTE 9 WAPPINGERS FALLS, NEW YORK 12590 (845) 298-2000 FAX (845) 298-2842 LEGAL ASSISTANT: AMY E. DECARLO e-mail: info@vsrp.com POUGHKEEPSIE OFFICE 276 MAIN MALL POUGHKEEPSIE, NY 12601 (845) 452-1046 KAREN P. MacNISH KEVIN T. McDERMOTT JAY B. RENFRO ANGEL 1. FALCON ANTHONY M. DEFAZIO NEWBURGH OFFICE 299 N. PLANK ROAD, SUITE 106 NEWBURGH, NY 12550 (845) 567-3783 .ADMITTED TO PRACTICE IN NY &: PLA. ..ADMITTED TO PRACTICE IN NY &: CONN. ADDRESS REPLY TO: ( ) POUGHKEEPSIIl ( ) WAPPINGIlRS October 5, 2005 RECEIVED OCT 0 6 2005 TOWN CLERK Bv Facsimile (297-1110) and Rel!ular Mail Sedore & Company, CPA's, P.C. P.O. Box 918 62 East Main Street Wappingers Falls, New York 12590 Attention: James L. Sedore, Jr., CPA Re: Town of Wappinger Pending or Threatened Litigation File No. 12951.0060 Dear Mr. Sedore: Pursuant to the letter request dated June 29, 2005, from Joseph Ruggiero, Supervisor of the Town of Wappinger, the following is the status of material Pending or Threatened Litigation, Claims and Assessments against the Town of Wappinger, as known to the best of my knowledge through September 30,2005. Please be advised that the undersigned was originally appointed attorney to the Town of Wappinger, effective January 1, 1990, and has been subsequently reappointed yearly thereafter until present. 0:\ Wappinger\Town Board\PendingLi1igation(.0060)\1 00505 sedore.doc Sedore & Company, CPA's, P.C. October 5, 2005 Page Two PENDING OR THREATENED LITIGATION (Excluding Unasserted Claims and Assessments): I hereby report that as of the date of this letter, there are some material Pending or Threatened Litigation matters in which the Town of Wappinger was named or is expected to be named as a party. With respect to Tort and Tax Certiorari actions, please know that there are claims pending against the Town which are being defended by the Town's insurance carriers. I am unaware of the exact number, nature, status or probability of success with respect to any of these actions. Emanuel F. Saris, Esq., now of this firm, has been retained by the Town to defend Tax Certiorari actions and he will submit a separate opinion regarding same. Various actions are being handled by attorneys assigned by the Town's insurance carrIers. Alpine Improvements, LLC v. Town of Wappinger (Challenging Benefit Assessment): As noted in previous correspondence, in May 2002, the Town was sued by Alpine Improvements, LLC, challenging the Benefit Assessment Formula for the Tri-Municipal Sewer Transmission/Treatment Improvement Area Phase 3A Improvements. In my opinion letter dated July 18, 2003, I provided a detailed analysis of the lawsuit. However, since the commencement of the action, the Petitioner's attorney has not actively pursued the prosecution of this matter and it has remained dormant for almost 3 years. Joseph Boyce v. Town ofWapoinger (Notice of Claim): In my opinion letters of July 18, 2003 and September 30, 2004, I noted a claim commenced by one Joseph Boyce against the Town of Wappinger alleging various acts of orchestrated harassment by employees of the Town, malicious and unwarranted prosecution of him, depriving him from income from rental property, loss of value to the property, emotional and physical damages, etc. The matter is being handled through the Town's insurance carrier and the Town's insurance carrier has appointed a law firm, Miranda and Sokoloff, to defend the Town's interest. The matter is presently pending in Supreme Court, Dutchess County and I am advised by the firm of Miranda and Sokoloff that a Motion for Summary Judgment is pending. In the event the Town fails to win on the Motion for Summary Judgment, a trial date is scheduled for the latter part of October. Based on my understanding of the facts, 0:\ Wappinger\Town Board\PendingLitigation(.0060)\1 00505 sedore. doc Sedore & Company, CPA's, P.C. October 5,2005 Page Five To the best ofthe knowledge of the undersigned, there are no actions that have been commenced against the Town, or threatened to be commenced the Town, nor are there any actions pending which would subject the Town to any monetary payment or financial loss. Very truly yours, VERGILIS, STENGER, ROBERTS, PERGAMENT & VIGLOTTI, LLP 4;;j;f~' · ,..-'J /; 1 / ./ k~. / ~ / '/~", '" ~~"'. ,.,kr. /_~~..~.:;) ~/ ,..'. - ~'~- e::"-" '-' ALBERT P. ROBERTS / .- APRlkc cc: Hon. Joseph Ruggiero, Supervisor Hon. John C. Masterson, Town Clerk 0:\ Wappinger\Town BoardlPendingLitigation(.0060)\100505 sedore. doc