STATE OF NEW YORK
SUPREME COURT ULSTER COUNTY
In the Matter of the Application of
CATSKILL HERITAGE ALLIANCE, INC.
cd NOTICE OF PETITION
Petitioner,
for a Judgment Pursuant to
CPLR Article 78 INDEX NO. 16-385
~against-
DATE OF FILING:
CROSSROADS VENTURES, LLC, and TOWN OF
SHANDAKEN PLANNING BOARD, February 12, 2016
Respondents.
PLEASE TAKE NOTICE that, upon the annexed verified petition,
an application will be made by the Petitioner at the Ulster
County Courthouse, 285 Wall Street, Kingston, New York, at 10:30
a.m. on the 28th day of March, 2016, or at such other time and
place as the assigned justice shall determine, for a judgment
pursuant to CPLR Article 78 annulling the January 13, 2016
approval by respondent Town of Shandaken Planning Board of the
special use permit and site plan review application by respondent
Crossroads Ventures, LLC; declaring said approval to be null and
void; determining that respondent Town of Shandaken Planning
Board may not approve the special use permit and site plan review
application by Crossroads Ventures, LLC unless a use variance isfirst obtained for the construction of certain structures,
including multifamily dwellings, a conference center, clubhouses,
a community center, and an activity center, in the applicable
zoning districts; awarding the Petitioner the costs and
disbursements of this proceeding; and granting such other and
further relief as may be deemed just and proper by the Court.
PLEASE TAKE FURTHER NOTICE that pursuant to CPLR § 7804(c),
any answering papers must be served at least five (5) days before
the return date.
Dated: February 11, 2016
CAFFRY & FLOWER
Attorneys for Petitioners
Claudia K. Braymer, of Counsel
100 Bay Street
Glens Falls, New York 12801
518-792-1582
S:\Client.Piles\catshill Heritage Alliance. Tow.3462\Notice..of Petition-wpdSTATE OF NEW YORK
SUPREME COURT ULSTER COUNTY
ee
In the Matter of the Application of
CATSKILL HERITAGE ALLIANCE, INC. PETITION
Petitioner,
for a Judgment Pursuant to INDEX NO. 16-385
CPLR Article 78
-against- DATE OF FILING:
CROSSROADS VENTURES, LLC, and February 12, 2016
TOWN OF SHANDAKEN PLANNING BOARD,
Respondents.
eS
Petitioner, Catskill Heritage Alliance, Inc., for its verified
petition herein, alleges as follows:
SUMMARY OF PROCEEDING
1. This proceeding is brought pursuant to Article 78 of the
Civil Practice Law and Rules (“CPLR”) to annul, vacate, and set
aside the January 13, 2016 approval by respondent Town of
Shandaken Planning Board (hereinafter “Planning Board”) of the
special use permit and site plan review application by respondent
Crossroads Ventures, LLC (hereinafter “Applicant” or
Crossroads”) .
2. This proceeding is also brought to request that the
Court determine that the Planning Board may not approve the
Applicant’s special use permit and site plan review application