05-11-2004
MAY-11-2004 rUE 02:46 PM
FAX NO,
P. 01103
OBRALD A. VBROJUS.
nNNmIM. STENGER
ALBERT P. ROBEIn'S
LOUIS 1. VIOLOTIl
JOAN P. GAI$.l!T1**
moMAS II DAVIS
EMANUEL 11. SARIS
VERGlLIS, STENGER., RoBERTS, PERGAMENI' & VIGLorrI, LLP
AlTORNEYS AND COUNSELORS AT LAW
1136 ROUTE 9
WAPPlNGERS fALLS, NEW YOlK 12j90
(845) 298-2000
fAX (845) 298.2142
e-mail: VSRPeSe81WcIJ.-
OF COUNSEL:
IRA A. PBRGAMBNT
LEGAL ASSISTANT:
AMY It- OBc.uLO
.ADM1'I11lD 1'0 nAC'11CIl
IN NY ... I'LA.
.'ADMl'I11lP TO I'IVICTICll
IN NY . CONN.
POUGHKEBPSIB 0PfIICB
216 MAIN MALL
POUGKUBP$IIS, NY J2$lt
(MS) 452-1046
PINE PLAINS OPPIct
2lI!IO CHtlRCH ST.
P.O. BOX 21
PINE PLAINS. NY 12S67
(518) 391-"57
KAREN P. MACNISH
KEVIN T. McDERMOTT
SlBVBN ~ J'A'M'BIt.SON
JAY B. RSNFRO
ADDlIU8 JlIIIV TO: ( ) POUGHICIIIPSIIl
()~
( ) PJNE PLA.lNS
May 11, 2004
Hon. Joseph Ruggiero, Supervisor
Town of Wappinger
20 Middlebush Road
Wappinger Fans, New York 12590
Via facsimile: 297-4558
Hon. Graham Foster, Highway Superintendent
Town of Wappinger
20 Old Route 9
Wappingers Falls, New York 12590
Via facsimile: 298-0524
Tatiana Lukianoff, Zoning Administrator
Town of Wappinger
20 Middlebush Road
Wappinger Falls, New York 12590
Via facsimile: 298-1478
Re: Absolute Property Management, Inc. et a1. v. Town of Wappinger
File No, 12951.0703
Dear Joe. Graham and Tatiana:
Enclosed herewith please find a copy ofa fax letter dated May 7,2004 received in our
office apparently on May 8, 2004. Please advise as soon as possible if any of these
docwnents are available. There is a hearing scheduled tomorrow morning. Manny Saris,
regrettably, is home sick today and I am just trying to cover for him in preparation for
tomorrow's hearing.
y yours,
IS, STENGER, ROBERTS, PERGAMENT & VIGLOTTI. LLP
MAY-11-2004 TUE 02:46 PM
FAX NO.
Salem Law Office
(108) 441-4$10
Fax: (708) 448-45 I S
sleml2'~II.com
P.O. Box 276. 7400 elIDe,,,w If(JIIJ
1',,1.$ Hcl,hlJ, Jlllnoll 604!JJ
73 FlliJjield DrM, St~ 101
p"ttemlJt, /+If 1 :ZS6J
MillY 7, 2004
Emanuel F. Saris, Esq.
Ver~iUs, Stenger, Roberts Peraament & Viglotti, u.P
1136 Route 9
Wappinaer$ FaUs, NY 12590
Phone: (845) 298-2000
Fax: (845) 298-2842
Re:
O'~ara. ~al-a' Town ~fW:mDinR.m.
~aseNo' ~ IV. 9814 YourFilcNo.: 12951,0701
Dear Mr. S&Tis:
The following is a list of documents that were not copied for us from the town
hall. Also is a list of the documents that arc held with the bighway superintendent's
office. As per the Judgc's order, on Friday at 11 a.m. my agents wilt come to the town
hall to review the documents. They also want to review the documents held in highway
superintendent's office. Due to the time constraints my ascnts will do the WOf~ in
making the copies needed on that same day.
The following docwnents were marked on Ihe day we Vi5jt~ the Town and \.Vere not
provide to us:
5. Preliminary layout for Map #3107 that was submitted to the Plannina Baud for
Wildwood Manor.
The following files and documents are either at the hi;hway superintendent's office or
were never made available to us at the Town Hall:
1. We need copies of the site plan dated April 22. 1965 for Wildwood Manot, Inc.
and Wildwood Manor Carden Apartments and we need to vieW the complete file
and any IIDd all documents relatina to the initial application, through and inclusive
to the final approval for same.
2. We need copies of all documents IUld files for the approval of the: conversion of
Wildwood Garden Apartments to Wildwood Condos approved in the year 1987.
P. 02/03
MAY-11-2004 TUE 02:46 PM
FAX NO,
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3. The complete file and all docwnents that the Town's i'iighway superintendent and
or Town Eniinecr maintains with regards to map 3107 and the road that was built
itlOwn on map 3107 as Parcel A known as Wildwood Drive from New
Hackinsack Road inclusive to Windmer R.oad.
4. We need copies of the Town Plan and Master Plan in effect as of Janwu'Y 23.
1963 (the cW:e of Planning Board gave conditional approval ofMap#31 07.)
5. As per Zonini Law and practice the Plannin& Board is empowered to approve
subdivisions only whe~ the Municipal Legislature has enacted an Ordinance
vestin~ such powers in the planning Board we need copies of this Ordinance
granting such powers.
6. Copies ofbigbway specifications and reaulations that weTe in effect as of
December 1, 1962.
7. We need copies of the complete file relating to the Bond that was filed for map
3107.
8. Ar. per the January 23. 1963 Plannins Board Resolution various provisions were
waived except as required by the Town's Highway Engineer, we need to revie:w
all docwnentaUon and files that show what was required by the town's Highway
Enaineer.
If you have any questions please do not hesitate to call. Thank you.
v cry truly yours,
~~~~, .~
~-:f~c....!~ ? /~
Maurice J. Salem, Esq.
2
p, 03/03