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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 is first 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-wpd STATE 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