Greenberg v. Veteran Rule 3(G) Statement
Public Court Documents
January 22, 1990
Cite this item
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Brief Collection, LDF Court Filings. Greenberg v. Veteran Rule 3(G) Statement, 1990. 17aa605e-b49a-ee11-be36-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/de018fb3-4142-4a60-aa50-2e23cfb8d5ec/greenberg-v-veteran-rule-3-g-statement. Accessed November 23, 2025.
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
— ---------------------------------------- -— ------------------ -------------------- — X
In the Hatter of the Application of
MYLES GREENBERG and FRANCES M.
MULLIGAN,
Petitioners,
-against-
ANTHONY F. VETERAN, et al.,
Respondents.
89 Civ. 0591 (GLG)
RULE 3(G)
STATEMENT
X
Pursuant to Civil Rule 3(g) of the rules of this
Court, respondents contend that the following are material
facts as to which there is no genuine issue to be tried.
1. On September 14, 1988, a petition to incorpo
rate the proposed Village of Mayfair Rnollwood was presented
to the Supervisor of the Town of Greenburgh, respondent
Anthony F . Veteran (the "Town Supervisor").
2. The incorporation petition included a descrip
tion of the boundary of the proposed village. Annexed
Exhibit 1 is a copy of that description.
3. On November 1, 1988, a public hearing was held
with respect to the Mayfair Knollwood petition, at which the
Town Supervisor presided. At the end of the session, the
Town Supervisor adjourned the hearing to November 21, 1988 to
permit the submission of additional written materials.
I Exhibit 1 Exhibit 2
2
4. After conclusion of the public hearing session
and prior to November 21, 1988, Larry J. Nardecchia, Jr.
submitted to the Town Supervisor a written statement in
opposition to the petition to form the Village of Mayfair
Knollwood. A copy of Mr. Nardecchia*s statement is annexed
as Exhibit 2.
5. Mr. Nardecchia is a resident of the Town of
Greenburgh. He also is a professional engineer, licensed to
practice in the State of New York. He has been the Town
Engineer of the Town of Greenburgh for approximately five
years, and he has held various positions in local government
for approximately 27 years. His regular work has included
the review of property descriptions to determine their
sufficiency.
6. Mr. Nardecchia reviewed the Mayfair Knollwood
boundary description (Exhibit 1). His findings, opinions,
and conclusions with respect to that review are set forth in
his statement (Exhibit 2).
7. On December 6, 1988, the Town Supervisor’s
decision with respect to the Mayfair Knollwood incorporation
petition was filed. The Town Supervisor rejected the peti
tion, in part, on the ground that the boundary description
submitted with the petition did not describe the proposed
village with "common certainty," as required by Village Law
- 2-
3
§ 2-202(1)(c)(1). The Town Supervisor based this ground for
his decision on Mr. Nardecchia's statement (Exhibit 2).
Dated: Elmsford, New York
January 22, 1990
PAUL AGRESTA, ESQ
Town Attorney (
Town of Greenburgh
P.O. Box 205
Elmsford, New York 10523
(914) 993-1546
Attorney for Respondents
Anthony F. Veteran and
Susan Tolchin
CUDDY & FEDER
90 Maple Avenue
White Plains, New York 10601
Attorneys for Respondents
Karen Developments, Inc., and
Robert Martin Company
RUTH E. ROTH, ESQ.
90 Maple Avenue
White Plains, New York 10601
(914) 761-1300
Respondent Pro Se
By:
(914)
Ruth E. Roth
- 3-
4
PAUL, WEISS, RIFKIND, WHARTON & GARRISON
1285 Avenue of the Americas
New York, New York 10019
(212) 373-3000
Attorneys for Respondents
Anita Jordan, April Jordan, Latoya
Jordan, Anna Ramos, Lizette Ramos,
Vanessa Ramos, Gabriel Ramos, Thomas
Myers, Lisa Myers, Thomas Myers, Jr.,
Linda Myers, Shawn Myers, and National
Coalition for the Homeless
Local counsel for Respondents
Yvonne Jones, Odell A. Jones, Melvin
Dixon, Geri Bacon, Mary Williams, James
Hodges, and National Association for the
Advancement of Colored People, Inc.
White Plains/Greenburgh Branch
JOYCE KNOX, ESQ.
NAACP, Inc.
4805 Mount Hope Drive
Baltimore, Maryland 21215-3297
(301) 486-9191
Attorney for Respondents
Yvonne Jones, Odell A. Jones, Melvin
Dixon, Geri Bacon, Mary Williams, James
Hodges, and National Association for the
Advancement of Colored People, Inc.
White Plains/Greenburgh Branch
By:
-and-
- 4 -
5
Of Counsel:
Robert M. Hayes, Esq.
O ’Melveny & Myers
Citicorp Center
153 East 53rd Street, Room 5314
New York, New York 10022
(212) 326-2000
Julius L. Chambers, Esq.
John Charles Boger, Esq.
Sherrilyn Ifill, Esq.
99 Hudson Street
New York, New York 10013
(212) 219-1900
Andrew M. Cuomo, Esq.
12 East 33rd Street, 6th Floor
New York, New York 10016
(212) 779-3350
-5-
EXHIBIT A
Description of the territory proposed to be incorporated as the
Village of Mayfair Knollwood with a description sufficient to
identify and describing the location and extent of such territory
with common certainty and which description includes a metes and
bounds description of same forming the entire boundaries of the
territory proposed to be incorporated as the Village of Mayfair
Knollwood.
_ . ... *he intersection of the easterly side of Knollwood Road
and^the loutherly border of the town of Mount Pleasant located at or
about the center of said Grasslands Road.
Punning thence South 67“ 40' East a distance of 49.25 feet
said southerly border of the Town of Mount
J U X . S ! being ^ s o the northerly border of the Town of
Greenburgh.
Running thence South 6 8“ 27' 40" East a distance of 344.15
feet along the said southerly border of the Town o, Moun.
Pleasant,"being also the northerly border of the Town of
Greenburgh.
Running thence South 67“ 23' 20" East a distance of 165.00
feet aiong the said southerly border of the Town of Mount
Pleasai??9biVn5 elec the northerly border of the Town of
Greenburgh.
.49
of MountRunning thence South 6 8" 55’ 30" East a distance of 2
feet along the said southerly border o* the Town o- K
fleisin?? being also the northerly border of the Town or
Greenburgh.
Running thence South 71" 53' 40” East a distance of 98 00
feet along the said southerly border of the Town o. Mou.;.
Pleasant,?being also the northerly border the Town o*
Greenburgh.
„ . „ con.v, 7 4 ® 32' 00" East a distance of 373 .£2
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border o. the To .. -
Greenburgh.
c , e 701 2 0 " East a distance of 7£.57
fee?^longethe said southerly border of the Town of Mount
Pleasant^being also the northerly border of the Town of
Greenburgh.
,. « « 7 7 ' 30" East a distance of 232 . 29
fee”'alone6the s^id southerly border of the Town of Mount
Pleasant?"being also the northerly border of the Town of
Greenburgh.
Running thence South 60e 25' 10" East a distance of 484.02
feet airng the said southerly border of the Town of Mount
Pleasant, being also the northerly,border pf the Town of
Greenburgh. _ _ J ' . : - -17 - ’ -
Running thence South €1° 45* 20"'East a'distance of 313.97
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 57* 39' 50" East a distance of 375.77
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 60° 14' 50" East a distance of 320.11
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 63° 35' 50" East a distance of 139.45
feet alone the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 63° 58' 50" East a distance of 286.63
feet along the said southerly border of the Town c.. Mou..u
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 64® 20' 00" East a distance of 79.65
feet along the said southerly border of the Town o~ Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 6 6° 38' 20" East a distance of 74.66
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 70° 34' 40" East a distance of 210.68
feet along the said southerly border of the Town of Mount
Pleasant,"being also the northerly border of the Town of
Greenburgh.
Running thence South 71° 19' 50" East a distance of 45.98
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border cf the Town of
Greenburgh.
- 2 -
Running thence South 73e 56' 40" East a distance of 196.32
feet along the said southerly border of the Towr of Mount
Pleasant, being also the northerly border cf the Town of
Greenburgh ■ ---,----~
Running thence South 79° 43' 50" East a distance of 66.06
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 78° 52' 10" East a distance of 56.67
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 74° 04' 10" East a distance of 39.04
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 68° 27' 00" East a distance of 36.86
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 68° 37' 40" East a distance of 261.65
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 60° 23' 40" East a distance of 61.09
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 57° 13' 04" East a distance of 38.60
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh to a point at or about the center of Stevens
Lane
Running thence South 47° 49' 47" East a distance of 40.99
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
-3-
Running thence South 48® 40' 36" East a distance of 16.25
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh _ ' __ . _V _ _ ■__ ̂ .
Running thence South 45° 31 ' 31* East a distance of 18.51
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 43® 30' 22" East a distance of 17.36
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 38® 31' 27" East a distance of 23.76
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 30° 13' 50" East a distance of 64.75
feet along the said southerly border of the Town of Mount
Pleasant,"being also the northerly border of the Town of
Greenburgh
Running thence South 28° 00' 40" East a distance of 24.6E
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 25® 46’ 40" East a distance of 5.02
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 28° 52’ 50" East a distance of 10.€C
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh
Running thence South 19° 26’ 40" East a distance cf 24.53
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh
Running thence South 15® 06' 50" East a distance of 24.35
feet along the said southerly border of the Town cf Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh
-4-
Running thence South 14® 27 ' 50" East a distance of 3 6 . 0 3
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh .. __ _
Running thence South 14® 19' 20" East a distance of 6 9 . 0 0
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 14® 19 ' 20" East a distance of 59.90
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 12° 35' 58" East a distance of 79.66
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 13® 58' 00" East a distance of 150.00
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 27® 31' 40" East a distance of 119.09
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 47° 32' 20" East a distance of 82.49
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 14® 42' 50" East a distance of 83.19
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 5° 17' 20" East a distance of 21.26
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh
Running thence South 2° 18' 28" East a distance of 121.6£
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh
_5_
Running thence South 5° 07' 15" East a distance of 73.85
feet along the said southerly border of the Town of idount
Pleasant, being also the northerly border of the Town of
Greenburgh ..... . ^ ^ . >
Running thence South 35® 29* 55" East a distance of 23.50
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 7° 49' 10" East a distance of 106.94
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 23® 31' 20" East a distance of 35.05
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 42® 08' 10" East a distance of 72.11
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 41° 48' 10" East a distance of 50.62
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 17® 13' 00" West a distance of 121.25
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh to a point at or about the center line of
Hillside Avenue (also known as Route 100)
Running thence South 28® 35' 40" West a distance of
feet at or about the center line of Hillside Avenue
known as Route 100)
131.18
(also
Running thence South 23® 20' 40" West a distance of 388.19
feet at or about the center line of Hillside Avenue (also
known as Route 100)
Running thence South 21® 37' 00" West a distance of 54.35
feet at or about the center line of Hillside Avenue (also
known as Route 100)
- 6-
Running thence South 27® 30' 20" West a distance of
approximately 510.00 feet at or about t^e center line of
Hillside Avenue (also known as Route 100)
Running thence South 35® 02'- 00" West 's distance of 311.18
feet at or about the center line of Hillside Avenue (also
known as Route 100)
Running thence South 37? 44' 00" West a distance of 113.0
feet at or about the center line of Hillside Avenue (also
known as Route 100)
Running thence South 43° 19' 00" West a distance of 117.50
feet at or about the center line of Hillside Avenue (also
known as Route 100)
Running thence South 41° 22’ 00" West a distance of 85.25
feet at or about the center line of Hillside Avenue (also
known as Route 100)
Running thence South 51° 11' 00" West a distance of 321.03
feet at or about the center line of Hillside Avenue (also
known as Route 100)
Running thence South
feet at or about the
known as Route 100)
50° 38' 35" West a distance of 203.45
center line of Hillside Avenue (also
Running thence South 51® 39' 50"
feet at or about the center line
known as Route 100)
Running thence South 54° 58' 20"
feet at or about the center line
known as Route 100)
West a distance of 137.44
of Hillside Avenue (also
West a distance of 65.41
of Hillside Avenue (also
Running thence South 60° 16' 55" West a distance of 173.23
feet at or about the center line of Hillside Avenue (also
known as Route 100)
Running thence South 59° 51' 30" West a distance of 60.4
feet at or about the center line of Hillside Avenue (also
known as Route 100)
Running thence South 66® 56' 50" West a distance of 585.14
feet at or about the center line of Hillside Avenue (also
known as Route 100)
-7-
\D
Running thence South
feet at or about the
known as Route 100)
62® 42’
center
50"
line
West a distance of
of Hillside Avenue
328.15
(also
Running thence South
feet at or about the
known as Route 100)
80® 42'.
center'
20"
line
West a distance of
of Hillside Avenue
270.06
(also
Running thence South
feet at or about the
known as Route 100)
52° 25’
center
10"
line
West a distance of
of Hillside Avenue
337.83
(also
Running thence South
feet at or about the
known as Route 100)
49® 23'
center
10"
line
West a distance of
of Hillside Avenue
158.38
.(also
Running thence South
feet at or about the
known as Route 100)
43® 10'
center
00"
line
West a distance of
of Hillside Avenue
121.53
(also
Running thence South
feet at or about the
known as Route 100)
36° 40'
center
30"
line
West a distance of
of Hillside Avenue
102.92
(also
Running thence South
feet at or about the
known as Route 100)
25® 06'
center
3 0"
line
West a distance of
of Hillside Avenue
93.38
(also
Running thence North
feet at or about the
known as Route 100)
86® 33'
center
40"
line
West a distance of
of Hillside Avenue
12.48
(also
Running thence South
feet at or about the
known as Route 100)
17® 53'
center
00"
line
West a distance of
of Hillside Avenue
215.86
(also
Running thence South
feet at or about the
known as Route 100)
15® 34'
center
30"
line
West a distance of
of Hillside Avenue
223.77
(alsc
Running thence South
feet at or about the
known as Route 100}
16® 54'
center
10"
line
West a distance of
of Hillside Avenue
201.52
(alsc
Running thence South
feet to a point
88® 10' 20" West a distance of 170 . 4 C
Running thence South 89 0 00' 20" West a distance cf 171.00
feet to a point
-8-
Running thence South 89s 35' 20 H
feet to a point
Running thence North 80s 37’ 40*
feet to a point .
Running thence South 876 41' 20"
feet to a point
Running thence South 88® 26' 10"
feet to a point
Running thence South 81° 34' 10"
feet to a point
Running thence South 86° 11' 00"
feet to a point
Running thence South 84° 57' 30"
feet to a point
Running thence South 84° 04' 50"
feet to a point
Running thence North 86* 04' 20"
feet to a point
Running thence South 8° 18' oo" :
feet to a point
Running thence South 9* 04' oo" :
feet to a point
Running thence South 17* 49’ 00"
feet to a point
Running thence South 18° 06' 00"
feet to a point
Running thence South 16° 48' 00"
feet to a point
Running thence North 89* 44' 00"
feet to a point
Running thence North 88* 00' 00"
feet to a point
West a distance of 49.00
West a distance of 28.10
West a distance of 418.87
West a distance of 269.58
West a distance of 120.40
West a distance of 48.11
West a distance of 58.42
West a distance of 33.13
West a distance of 111.52
East a distance of 254.62
East a distance of 104.97
East a distance of 110.2.
East a distance of 56.7c
East a distance of 191.1
East a distance of 19.32
East a distance of 192.:
-9-
Running thence North 89° oo
o o 3 East a distance of 94.52feet to a point
Running thence North 88 6 43/ 00" East a distance of 216.34feet to a point
-
_♦
Running thence North 87° 28* 0 0 " East a distance of 95.18feet to a point
Running thence North 86® 0 6 ' 00" East a distance of 100.31feet to a point
Running thence South 89 6 2 0 ' 0 0 " East a distance of 135.72feet to a point
Running thence North 88° 3 0 ' 00" East a distance of 188.13feet to a point at or■ about the center .line of Hills ide
Avenue (also known as Route 100)
Running thence South 15° 11' 00" West a distance of 742.31
feet at or about the center line of Hillside Avenue (also
known as Route 100)
Running thence South OO VO o 32’ 00" West a distance of 118.72feet to a point
Running thence North 87° 21' 00" West a distance of 57.22feet to a point
Running thence South 88° 30' 00" West a distance of 200.02feet to a point
Running thence South 87° 25' 00" West a distance of 126.00feet to a point
Running thence South 88° 40’ 00" West a distance of 157.02feet to a point
Running thence North 85° 45' 00" West a distance of 15.13feet to a point
Running thence South 87° 1 6 ' 00" West a distance of 46.01feet to a point
Running thence North 88° 09 ' 00" West a distance of 34.09feet to a point
Running thence South 86° 01 ' 00" West £ distance of 10 92 0 4feet to a point
-10-
Running thence North 5® 59' 20" West a distance of 435.99
feet to a point . - - ---
Running thence South 88® 07' 50" West a distance of 806.08
feet to a point
Running thence South 11® 54' 00s East a distance of 458.87
feet to a point at or about the center line of Old Tarrytown
Road
Running thence South 87° 55' 00" West a distance of 22.03feet to a point
Running thence North 72® 43' 00" West a distance of 14.60
feet at or about the center line of Old Tarrytown Road
Running thence South 89® 14' 00" West a distance of 254.50
feet at or about the center line of Old Tarrytown Road
Running thence North 88® 45' 00" West a distance of 40.50
feet at or about the center line of Old Tarrytown Road
Running thence South 59° 34' 00" West a distance of 21.00
feet at or about the center line of Old Tarrytown Road
Running thence South 81° 26' 00" West a distance of 56.53
feeu at or about the center line of Old Tarrytown Road
Running thence South 87° 22' 00" West a distance of 284.92
feet at or about the center line of Old Tarrytown Road
Running thence South 74® 11' 00" West a distance of 59.78
feet at or about the center line of Old Tarrytown Road
Running thence North 88® 22' 00" West a distance of 89.15
feet at or about the center line of Old Tarrytown Road
Running thence southerly a distance of approximately 25 fe?
to the northeasterly corner of lands now or formerly of
Mount Vernon Trap Rock Corporation being at the intersect;.:
of the westerly boundary of Manhattan Park as shown on R.C.
Map #1015 on a course South 3® 56' 20" West a distance of
248.20 feet
Running thence South 3® 25' 20" West a distance of
approximately 316.4 feet to a point
Running thence South 86® 20' 05" West a distance of 723 ."9
feet to a point
-11-
Running thence North 55' 30' 30" Nest a distance of 348.34
feet to a point at or about the center line of Knollwood
Road
Running thence North 28' 41' 30" East a distance of 142.82
feet at or about the center line of Knollwood Road (also
known as Route 100A)
„ . 4' 23" West a distance of 93.84 feet
a“ bout the center line of Knollwood Road (also known as
Route 100A)
Running thence North 39° 25' 10" East a distance of 233.07
feet at or about the center line of Knollwood Road (also
known as Route 100A)
Running thence North 28° 23' 30" East a distance of 7.9 feet
at Sr about the center line of Knollwood Road (also known aE
Route 100A)
Running thence North 35° 20’ 10" East a distance of
approximately 198.44 feet at or about the center line of
Knollwood Road (also known as Route 100A)
Running thence North 35' 18’ 00" East a distance of 142.17
feet at or about the center line of Knollwood Road
(also known as Route 100A)
Running thence westerly across Knollwood Road to a point
where the Village of Elmsford border proceeds in a
northwesterly direction from the westerly side of Knollwooc
Road
Running thence North 10° 25’ 50" West a distance cf^
approximately 4115 feet to a point sald 1^ ncec
to be immediately adjacent to the present border of the
Village of Elmsford
Running thence North 80' 15’ 30" West a distance of 100.02
feet said line being intended to be immediately ad3acent t.
the present border of the Village of Elmsford
c ® i t 5 0" East a distance of 512.26
fee?1along8the easterly border of the Sprain Brook Parkway
to the southerly side of Payne Street
Running thence North 62" 12' 49" Nest a distance of 252.59
feet to a point
Running thence easterly along the southerly side of Payne
Street a distance of approximately 100 feet to the
intersection formed by the southerly side of Payne Street
and the westerly, 6ide of Montgomery__Avenue
-Running thence northerly across Payne Street a distance of
approximately 50 feet to the intersection formed by the
northerly side of Payne Street and the westerly side of
Montgomery Avenue
Running thence along the westerly side of Montgomery Avenue
a distance of 285 feet to a point on the westerly side of
Montgomery Avenue
Running thence easterly and at right angles to the westerly
side of Montgomery Avenue a distance of 150 feet to a point
distant 100 feet from the westerly side of Lawrence Avenue
Running thence northerly and parallel with the westerly sic
of Lawrence Avenue (distant 100 feet westerly from the
westerly side of Lawrence Avenue) a distance of 400 feet
Running thence westerly across the Sprain Erook Parkway to
point on the easterly side of Executive Boulevard distant
393.20 feet on a course South 34° 37' 00" West from Monumer.
No. 16 as shown on Map No. 15544 filed in the Westchester
County Clerk's Office Division of Land Records on August 2C
1967
Running thence North 55® 23 ' o o a West a distance of 3C0.0C
feet to a point
Running thence North 4 3® 0 7 ’ 00" West a distance of 365.90
feet to a point
Running thence South 8 3® 0 2 ' 00" West a distance of 2 3 5 . EC
feet to a point
Running thence South 77® 27' 00" West a distance of 3 8 . 2 C
feet to a point
Running thence South 83® 39' 00" West a distance of 704.9:
feet to a point
Running thence North 10® 49' 00" West a distance of 473.5
feet to a point
Running thence South 64® 05' 30" West a distance of 4 1 ."3 6
feet to a point
-13-
Running
feet to
thence South
a point
42® 23 * 20" West a distance of 53.08
Running
feet to
thence South
a point
12® 58'«20" West a distance of 72.54
Running
feet to
thence South
a point
81® 57' 40" West a distance of 36.23
Running
feet to
thence South
a point
69® 09' 30" West a distance of 54.13
Running
feet to
thence South
a point
40® 26' 30" West a distance of 75.29
Running
feet to
thence South
a point
71® 11' 40" West a distance of 100.90
Running
feet to
thence South
a point
57® 15' 20" West a distance of 100.39
Running
feet to
thence South
a point
79° 22' 10" West a distance - tw■ 46.87
Running
feet to
thence South
a point
55° 41' 30" West a distance of 7 7 . 8 E
Running
feet to
thence South
a point
55® 57 * 50" West a distance cf 91.22
Running
feet to
thence South
a point
42® 00' 00" West a distance of 100.60
Running
feet to
thence South
a point
59® 08' 50" West a distance of 48.26
Running
feet to
thence South
a point
79° 19 ’ 00" West a distance of 18.60
Running
feet to
thence South
a point
89® 03’ 10" West a distance of 26.25
Running thence northwesterly a distance of 55 feet mere c
less to the westerly side of Saw Mill River Road (Route 9
at a point formed by the westerly side of Saw Mill River
Road (Route 9A) and the southerly side of Fairview Park
Drive where same intersect at the southerly end of a curve
to the south having a radius of 30 feet
/
-14-
>
M
Running thence along the westerly side of Saw Mill River
Road (Route 9A) a distance of 149.83 feet to a point
Running thence along the westerly side of Saw"Mill River
Road (Route 9A) South 17® 50* 16* East a distance of 36.86
feet to a point
Running thence along the westerly side of Saw Mill River
Road (Route 9A) South 18® 37' 50* East a distance of 832.06
feet to a point
Running thence along the westerly side of Saw Mill River
Road (Route 9A) South 13® 28s 30* East a distance of 272.4
feet to a point
Running thence along a curve to the right with a radius of
731.0 feet, a central angle of 4® 21’ 09" a distance of
55.53 feet to a point
Running thence South 81® 00* 20" West a distance of 768.04
feet to a point
Running thence South 5° 29* 10" West a distance of 630.84
feet to a point
Running thence North 56® 311 40" West a distance of 576.11
feet to a point on the easterly line of lands of the New
York and Northern Railroad Company now, or formerly, New
York Central Railroad Companv (Putnum Division) (hereinafte
"N.Y.C.RR.P.D.")
Running thence along the easterly line of said
N.Y.C.RR.P.D. North 5® 50' 50" East a distance of 124.67
feet to a point
Running thence along the easterly line of said N.Y.C.RR.P.E
on a curve to the left tangent to the previous course and
having a radius of 1194.06 feet a distance of 697.31 feet t
a point
Running thence northerly along the easterly line of saic
N.Y.C.RR.P.D. on a curve to the left having a radius of
1177.56 feet, a central angle of 25® 01' 00" a distance of
514.15 feet to a point
Running thence North 52® 46' 20" West a distance of 722. CC
feet to a point
-15-
Running thence northerly on a curve to the right having a
radius of 1399.39 feet, a central angle of 10° 39' 25" a
distance of 260.28 feet to a point
Running thence North 73° 09' 00" East a distance of 16.44
feet to a point
Running thence North 73° 39' 00" East a distance of 1.82
feet to a point
Running thence northerly on a curve to the right having a
radius of 1382.89 feet, a central angle of 17° 39' 58" a
distance of 426.39 feet'
Running thence North 24° 46' 20" West a distance of 250.00
feet to a point
Running thence northerly on a curve to the left having a
radius of 1004.41 feet, a central angle of 22c 33' 15" a
distance of 395.38 feet to a point
Running
feet to
thence North
a point
47° 19 ' 35" West a distance of 270.70
Running
feet to
thence North
a point
57° 46' 20" West a distance of 504.2
Running thence continuing along the northerly and easterly-
lines of "N.Y.C.RR.P.D." as it winds along the southerly
line of lands now or formerly of the County of Westchester
to a point located at the southeasterly corner of lands
shown on a certain map entitled "Westchester Lighting Co.
County of Westchester," said map filed in the Office of th
Clerk of Westchester County, Division of Land Records, or.
1-5-1943 as Map No. 5673; being approximately a distance c
197 feet
Running thence still along said northerly and easterly lin
of said "N.Y.C.RR.P.D.," North 75° 32' 55" West 783.94 fee
to a point
Running thence in a northwesterly direction, along a curve
to the right having a radius of 621.78 feet, an interior
angle of 62° 24' 40", a distance of 677.29 feet to a point
Running thence still along said "N.Y.C.RR.P.D.," North 13c
08' 15" West 933.97 feet to a point
-16-
Running thence still along said railroad, on a curve to the
right in a generally northeasterly direction, said curve
having an interior angle ©f 69® 57* 15", a radius of 754.32
feet and a distance of 920.97 feet to a point
Running thence still along said railroad North 56® 49' East
351.24 feet to a point
Running thence still along said railraod, in a generally
northerly direction, on a curve to the left, having a radius
of 811.78 feet, an interior angle of 21® 35* 46", a distance
of 305.98 feet to a point
Running thence still along said railroad, North 35® 13’ 14"
East 752.69 feet to a point on the southwesterly line of Ole
Saw Mill River Road, as the same is shown on the aforesaid
filed Map No. 5673
Running thence continuing on a prolongation of said line to
a point in said Old Saw Mill River Road at the division lim
between the Town of Greenbrugh on the South and the Town of
Mount Pleasant on the North
Running thence along said division line on a line generally
parallel with the following 2 courses and distances
South 48® 26' 56" East 377.83 feet to a point
South 48° 56' 36" East 30.22 feet to a point, said point
being a prolongation of the division line between lands N/F
of James Butler and/or Emipire City Racing Association, and
lands N/F Westchester Lighting Co. as shown on the aforesa;
Map No. 5673
Thence continuing along said division line between the Towr
of Mount Pleasant on th North and the Town of Greenburgh cr
the South on a line gnerally parallel to the following 6
courses and distances
On a curve to the left, in a generally Easterly direction,
having a radius of 1946.86 feet, a central angle of 1® 48’
38", a distance of 61.52 feet to a point
Thence continuing along said division in the same manner,
South 34® 45’ 00" West 45.54 feet to a point
South 55® 15' 00" East 102.00 feet to a point
North 34® 45' 00" East 41.97 feet to a point
-17-
Thence continuing in an easterly direction, along a curve tc
the left, having a radius of 1946.86 feet, a central angle
of 2® 23* 15", a distance of 81.125 feet to a point
Thence continuing along said Town division line, in the sane
manner, the following 14 courses and
South 57® 37' 16" East 373.84 feet
South 57® 53' 10" East 43.33 feet
South 63® 20' 30" East 64.27 feet
South 68® 16' 40" East 63.98 feet
South 71® 57' 20" East 48.14 feet
South 75® 31’ 00" East 167.65 feet
South 75® 03' 30" East 417.19 feet
South 71® 58' 00" East 46.04 feet
South 70® 36' 00" East 53.02 feet
South 67® 40' 50" East 36.36 feet
South 66° 14' 50" East 71.78 feet
South 63° 42' 50" East 155.58 feet
South 63® 47' 50" East 376.04 feet
Running thence along a curve to the right in a generally
southeasterly direction, having a radius of 954.67 feet, a
central angle of 53° 14' 00", a distance of 830.73 feet me
or less, to a point on the aforesaid Town division line, a
the intersection of Old Saw Mill River Road and Grasslands
Road (a/k/a Lower Cross Road)
Running thence from said point, continuing along the
division line between said Towns, in a generally easterly
direction, all as shown on filed Map No. 1879, sheet 67, t
a point being the prolongation of the Westerly line of la:,
shown on said map as "Property To Be Acquired By The City
New York"
-18-
Running thence from said point, continuing along said
division line between the Town of Mount Pleasant on the
North, and the Town of Greenburgh on the South, in a
generally Easterly direction, all as shown_on.filed Map
No. 1863, sheet 52, to a point and the Easterly boundary of
lands shown on Map No. 1879, sheet 67, as “Property To Be
Acquired By The City of New York", said easterly line more
particularly shown on filed Map No, 1863
Continuing along said division line, in a generally
southeasterly direction, and generally parallel to the
northerly taking lines shown on filed Maps Nos. 19736,
19319, 12821 and 19920, 19993, 19317 and 19484,
respectively, to a point where said division line intersect
the easterly side of Knowllwood Road, at the point or place
Of BEGINNING.
-IS-
TO : ANTHONY F. VETERAN, SUPERVISOR
FROM : LARRY J. NARDECCHIA, JR., P.E.
RE : STATEMENT IN OPPOSITION TO PETITION TO FORM
VILLAGE OF MAYFAIR-KNOLLWOOD
I am a resident of the Town of Greenburgh, a
registered voter, and a person qualified to vote for town
offices in the Town of Greenburgh.
I am the duly appointed Town Engineer of the Town
of Greenburgh. I have been employed by the Town in this
capacity for ne past four ue ars. Prt'r tc that I Served =!
the Ccrrj, ..ssioner of Public Works for the Town of New Castle
for three years; as the Building Inspector, Village Engineer
and Highway Superintendent for the Village of Dobbs Ferry
for three years; and as an Assistant Engineer for the City
of New Rochelle for 17 years. I have a Bachelors Degree in
Civil Engineering from Manhattan College, a Masters in
Public Administration from Pace University and am a Licensed
Professional Engineer licensed by the State of New York,
License No. 56570.
I hate a total of 2V years experience working for
local governments which includes a:; part of the regular
course of my duties the review of property descriptions tc
determine their sufficiency.
i' 12.1
I have carefully examined the property description
in the petition (Exhibit A). Based on my analysis I submit
the following objections and urge you to reject the petition
as invalid because the property description does not
describe an area with "common certainty".
At one time, land was recorded with descriptions
of natural or artificial features of the terrain such as
streams and stone walls. As years passed and land was
developed, many of these features ceased to exist. Needless
to say, numerous disputes resulted. It became more common
to describe lengths and directions of boundaries by compass
and measurements. When bearings and lengths are given to
describe a tract of land, the description is by "metes and
bounds". This system dc tes bac< c . color, .-i a 3 dais and is
u. >c 1 r most of the .-as tern part cf the United States. The
describer locates a corner of the property and follows the
directions and the distances of the property lines until the
perimeter is described back to the starting point.
A metes and bounds description uses mathematic
precision to locate each and every point or. a perimeter cf a
many sided figure (polygon). Through this system every
point may be computed to give an accurate finite distance
north from the Equator (Latitude! and an accurate finite
distance east from the Prime Meridian (Longitude) of a giver,
point from a previous point in the description.
The compass reading or direction of the property
line is giver, in one cf the four quadrants (N.E., S.E.,
125
N . W ., or S.W.). The angles are never more than 90° and they
are taken from either the north meridian or the south
meridian, whichever gives the lesser angle. Therefore by
giving a bearing which can be translated to an angle for
trigonometric calculation and a finite distance [not an
approximate (±) distance] we give a unique location of the
described property point. If the metes and bounds
description was complete it would return to the point of
beginning and create a unique one-of-a-kind polygon.
This system could tie into any other system, using
the same datum. Surveyors in the Town of Greenburgh base
their surveys on the United States Coast and Geodetic System.
(USC&GS) which has markers throughout Westchester County,
:t? , riles, i ■,i s, . d villager. It apperrs f hat this
description has started its descriptive process m the same
datum system currently in use in the Town of Greenburgh.
All metes and bounds descriptions are supposed to
begin at a known point on the filed map. This description
does not begin by referring to a known point on a filed map.
Therefore, the whole description cannot be tied in, with
certainty, to the entire land records system of Westchester
County.
This d.-ficiency is further compounded by the fact-
that the centc. -line of Grasslands Read or. which the
description begins has been altered by the New York State
Department of Transportation which means that at this
location the center-line might not be on the Town boundary
9 -3- 126
line. It cannot be supposed which center-line of Grasslands
Road is referred to, the new one or the old one, from the
description given.
In general, the description then runs rather
consistently as a metes and bounds description for the first
eleven pages.
At page 11, line 26, the property description then
deviates from being a metes and bounds description because
terms like "thence southerly" without a bearing and
"approximately 25 feet" without a finite distance appear.
At this point, the unique location in relation to latitude
and longitude of the next point cannot continue with
accuracy. For instance, at page 11, line 26, no bearing or
c..;- -/.re ii . ver. cc that at this point the description •_r
the parcel car.r.ot be continued with certainty. There is no
way to determine in what direction the boundary line is
intended to proceed, or for what distance. The polygon
being described has lost its mathematical uniqueness and nc
longer continues as a valid metes and bounds description.
If this were the only point of deficiency a forced closure
could compute the bearing and distance giving a unique
description. However, this inconsistency occurs 13 more
tines ir the following 7 pages thus creating 1̂ separa+e
piece? of a description which are not linked together.
On page 12, line 24, no distance or bearing is
given, creating a second point of discontinuity.
it t - 4 - 127
On page 13, line 2, no bearing is given and the
distance is only approximate. Therefore, it's impossible to
determined in which direction the line goes and its length
thus creating a third point of discontinuity.
On page 13, line 6, no bearing is given and the
distance is only approximate. In likewise manner, this
creates a fourth point of total discontinuity.
On page 13, line 10, no bearing is given and we do
not know in which direction the property line proceeds
creating a fifth point of discontinuity.
On page 13, line 13, no bearing is give since one
cannot go off at a right angle from a preceding line whose
bearing line was not given. At this point, we have
,.j-p... h-l the- trier anc have a sixth point _f
discontinuity.
On page 13, line 16, we have no bearing anc the
description only says that it is parallel to another
bearing. This is indeterminate and cannot be used for the
continuity of a description. This creates a seventh point
of discontinuity.
On page 13, line 20, no bearing nor distance are
given, creating an eighth point of total discontinuity.
On pa‘ge 14, lire 31, no bearing a_d only an
apr.cximate distance is given, creating a ninth poi.it of
discontinuity.
On page 15, line 12, the curve is defined with a
central angle, but by computing, . i's cbvious that the curve
f - 5- 128
chord
is net tangent to the preceding property line nor the
following property line. Therefore, two radials or a
and bearing would have to be used for this description.
Neither of these is supplied and there would be an infinite
number of curves proposed without further definition. This
creates a tenth point of discontinuity.
On page 16, line 20, the description given is an
extension of a straight line and has no bearing at all, with
only an aproximate distance. This obviously creates an
eleventh point of discontinuity.
On page 17, line 15, the prolongation as it is
stated has no bearing nor has a distance been given,
creating a twelfth point of discontinuity.
Or. pace 1 “, line ln, "general 2; parallel" meets r :
desrr.ptive criteria whatsoever since you must gc from, a
specific point to another specific point. This neither
starts nor ends at either. Parallel is a descriptive term,
defining an infinite number of points all the same distance
from: a given line. The description makes that term one of
generality, creating a thirteenth point of discontinuity.
On page 17, line 29, the same generality is used
and meets no descriptive criteria for an unique polygon,
cr“2 f ir.g a fourteenth pc: nt of discontinuity. The actual
area of this fijure cannot be computed until there is ar.
accurate (closed) figure to work from.
In a separate instance the text quotes "the
following 34 courses and distances" and proceeds tc only
- 6-
129
sup ply 13, on pa g e 18. C e r t a i n l y the m i s s i n g link could
represent acres in area not to mention conflict with all the
physical field locations of roads, rails, walls and rivers.
This creates at least a fifteenth point of discontinuity.
The last two pages of the description turn into a
litany of towns, owners, and filed maps which cannot equate
into a mathematical translation necessary to constitute a
metes and bounds description. Though it might be possible
to extrapolate a metes and bounds description from these
filed maps, depending on their content, the preparer for
some reason chose to lump these sides together merely by
telling us where to look. However none of these maps were
filed with the Town of Greenburgh nor did I have copies
cm-- r.g my 2uOC map s in -ur 'hies.
In general the description has 15 voids alcig its
course and a last series of unknown number of sides which
was not even described rendering it unusable for a metes ar.d
bounds description, or any kind of description with "common
certainty". As a description it bounces from one system to
another and finally to mere references as to where the
information can be found without any specifics. This last
case makes this totally defective for any type of
description.
Eased on my 27 years of experience u is my
opinion that the property description does not in fact
130
describe an area of land with common certainty due to the
omissions and inaccuracies as defined herein.
Respectfully submitted,
Ardsley, New York 10502
(Town of Greenburgh)
- 8-
13J
132
EXHIBIT A
D e s c r i p t i o n of the t e r r i t o r y proposed to be incorporated as t h e
Village of Mayfair Knollwood with a description sufficient
identify and describing the location a n d e x t e n t c. sucm territc
with common certainty and which description includes a me
hour.:
terr:
oe;
:ry pr
.ption
Dpcsed to
of same fonr.. no the entire boundaries c. the
income rated as the tillage
Kncllwooc
13?
^ 'O
i J {^Beginning at the intersection of the easterly side of Knclxwcoa Rea
a -ana the southerly border of the town of M&unt Pleasant locatec at c
, - ©A*' about the center of said Grasslands Road.CU
0
Running thence South 676 40' East a distance of 49.25 feet
along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 68° 27' 40" East a distance of 344.15
feet along the said southerly border of the Town or Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 67° 23' 20" East a distance of 165.CO
feet along the said southerly border of the Town or Mount
PXea.cant, being also the northerly border of the Town or
Gree- '• urgh
Running thence Soatn 68° 55' 30" East a distance c: - •.t9
feet along the said southerly border of the Town cr Mount
Pleasant, being also the northerly border of the Town cr
Greenburgh.
Running thence South 71° 53’ 40" East a distance of 98.00
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 74° 32' 00" East a distance of 373. S2
feet along the said southerly border of the Town of Mount.
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 61e 38' 20" East a distance of 78.57
feet along the said southerly border of the "cv" of Mount
Pleasant, being aiso the n o r t h e r l y border of the Town cr
Greenburgh.
Running thence South 56° 32' 30" East a distance of 232.29
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
. 134
- 1-
Running thence South 60° 25' 10" East a distance of 484.02
feet alrng the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 61° 45' 20" East a distance of 313.5“
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 57° 39' 50" East a distance of 375.77
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 60° 14' 50" East a distance of 320.11
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh.
Running thence South 63° 35' 50" East a distance of 139.^5
.eet along the said southerly ' order of the Town vf Mount
Pleasant, being also the northerly border cf the Town cf
Greenburgh.
Running thence South 63° 58' 50" East a distance cf 286.62
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border cf the Town cf
Greenburgh.
Running thence South 64° 20' 00" East a distance cf 79.65
feet along the said southerly border of the Town cf Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh.
Running thence South 66° 38' 20" East a distance of 74.66
feet along the said southerly border of the Town cf Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh.
Runnina _;.«r.ce South 70® 34' 40" East a d_star.cc cf — . C. i ?
feet along the said southerly border of the Town cf Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh.
Running thence South 71° 19' 50" East a distance of 45. 9v
feet along the said southerly border of the Town cf Mount
Pleasant, being also the northerly border cf the Town cf
Greenburgh.
- 2 -
135
Running thence South 73° 56' 40" East a distance of 196.32
feet along the said southerly border of the Town or Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 79° 43' 50" East a distance of 66.08
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 78° 52' 10" East a distance of 56.67
feet along the said southerly border of the Town of Mount
Pleasant,"being also the northerly border of the Town of
Greenburgh
Running thence South 74° 04' 10" East a distance of 39.04
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 68° 27’ 00" /ast a distance of 38.86
feet along the said s i ■’“ly border of tr.e Tow., of Mv-r.t
Pleasant, being also the northerly border of the Town or
Greenburgh
Running thence South 68° 37' 40" East a distance of 261.65
feet along the said southerly border of the Town or Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 60° 23' 40" East a distance of 61.09
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 57° 13' 04" East a distance of 38.60
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town or
Greenburgh to a point at or about the center of Stevens
Lane
Running thence South 47e 49' 47" East a distance vf 4C.39
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
-3- 13P
Running thence South 48° 40' 36" East a distance of 16.25
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 45° 31' 31" East a distance of 18.51
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 43° 30' 22" East a distance of 17.36
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 38® 31' 27" East a distance of 23.76
feet along the said southerly border of the Town of Mount
Pleasant,"being also the northerly border of the Town of
Greenburgh
Running t.hence South 3 0c 13' 50" East a distance c f 6 4.79
fe-’t aio.., the said so\ therly border of the Town c
Pleasant, being
Greenburgh
sJ.sc the northerly border of the . r a ■' **
Running thence South 28® 00' 40" East a distance c f 2 4.68
v feet along the said southerly border of the Town of Mount
Pleasant,"being also the northerly border of the Town of
Greenburgh
Running thence South 25s 46' 40" East a distance of 5.02
feet along the said southerly border of the Town of Mount
Pleasant,"being also the northerly border of the Town of
Greenburgh
Running thence South 28® 52' 50" East a distance of 10.60
feet along the said southerly border of the Town of Mount
Pleasant,"being also the northerly border of the Town of
Greenburgh
Penning thence South 19° 26' 40" East a cxstarce of 2.. 6 3
feet along the said southerly border jf the Town of Mount
Pleasant,"being also the northerly border of the Town of
Greenburgh
Runninc thence South 15® 06’ 50" East a distance of 24.35
feet along the .-aid southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
-4-
137
Running thence South 14° 27' 50" East a distance cf 36.C2
feet along the said southerly border cf the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 14s 19' 20" East a distance of 69.00
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 14° 19' 20" East a distance of 59.90
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh
Running thence South 12° 35' 58" East a distance of 79.66
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 13° 58' 00" East a distance cf 150.0
i eet- r - - ~ g the said southerly border of the ~ of "c .* n
? 1 e a s a i. , beir.c also the northerly border cf tV_ T own
Greenburgh
Running thence South 27° 31' 40" East a distance of 115.C
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh
Running thence South 47° 32' 20" East a distance cf 82.49
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh
Running thence South 14® 42' 50" East a distance of 83.19
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh
Running thence South 5° 17' 20" East a distance of 21.26
feet a’ong the said southerly border of the Town cf MC'.r.t
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 2° 18' 28" East a distance of 121.68
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly berd r cf the Town of
Greenburgh
5-
• 138
Running thence South 5® 07' 15" East a distance of 73.85
feet along the said southe-ly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 35° 29' 55" East a distance of 23.50
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Running thence South 7° 49' 10" East a distance of 106.94
feet alonq the said southerly border of the Town of Mount
Pleasant/being also the northerly border of the Town of
Greenburgh
Running thence South 23° 31' 20" East a distance of 35.05
feet along the said southerly border of the Town of Mount
Pleasant, being also the northerly border of the Town of
Greenburgh
Punning thence South 42° 08' 10" East a distance of 72.11
ceet alone the sate, southerly borae. of the •. c. wr. r; .•.tun _
Pleasant, being also the northerly border cf .he r‘c •• c_
Giter.b argh
Running thence South 41° 48' 10" East a distance of 50.62
feet along the said southerly border of the Town cf Mount
Pleasant/being also the northerly border cf the Town of
Greenburgh
Running thence South 17° 13' 00" West a distance cf 121.29
feet along the said southerly border of the Town cf Mount
Pleasant, being also the northerly border of the Town cf
Greenburgh to a point at or about the center line or
Hillside"Avenue (also known as Route 100)
Running thence South 28° 35' 40" West a distance cf 131.18
feet at or about the center line of Hillside Avenue (alsc
known as Route 100)
Running thence South
feet at or about the
known as Route lOQj
23° 20' 40" West a diatar.ee c:
center line of Hillside Avenue
Running thence South
feet at or about the
known as Route 100)
21® 37' 00" West a distance of 54.29
center line of Hillside Avenue (alsc
v «*
- 6- 13P
Running thence South 27® 30' 20" West a distance of
approximately 510.00 feet at or about t'"e center line of
Hillside Avenue (also known as Route 100)
Running thence South
feet at or about the
known as Route 100)
35° 02'
center
00"
line
West a distance of
of Hillside Avenue
311.18
(also
Running thence South
feet at or about the
known as Route 100)
37° 44'
center
00"
line
West a distance of
of Hillside Avenue
113.0
(also
Running thence South
feet at or about the
known as Route 100)
43° 19'
center
00"
line
West a distance of
of Hillside Avenue
117.50
(also
Running thence South
feet at or about the
known as Route 100)
41° 22'
center
00"
line
West a distance of
of Hillside Avenue
85.25
(also
Running thence South
feet at or about the
known as Route 100)
51° 11'
cente ■■
00" West a distance of
r Hillside A nnue
321 .03
(also
Running thence South
feet at or about the
known as Route 100)
50° 38'
center
35"
line
West a distance of
of Hillside Avenue
203.45
(also
Running thence South
feet at or about the
known as Route 100)
51° 39'
center
50"
line
West a distance of
of Hillside Avenue
137.44
(also
Running thence South
feet at or about the
known as Route 100)
54® 58’
center
20"
line
West a distance of
of Hillside Avenue
€5.41
(also
Running thence South
feet at or about the
known as Route 100)
60° 16'
center
55"
line
West a distance of
of Hillside Avenue
173.25
(also
Running thence South
feet at or about the
known as Route 100)
5 9® 51'
center
30"
3 ine
West a distance of
Hillside Avenue
- - c
false
Running thence South
feet at or about the
known as Route 100)
66° 56'
center
50"
line
West a distance of
of Hillside Avenue
585.14
(also
-7-
H P
C
) M
l
Running thence South 62° 42
feet at or about the center
known as Route 100)
Running thence\South
feet at or abouV-t^re-
known as Route 100)
50" West a distance of
line of Hillside Avenue
?
80° 42' 20" West a distance of
-center—tine of Hillside Avenue
326.15
(also
270.06
(also
Running thence South
feet at or about the
known as Route 100)
52° 25' 1C"
center line
West a distance of
of Hillside Avenue
337.83
(also
Running thence South
feet at or about the
known as Route 100)
4 96 23' 10"
center line
West a distance of
of Hillside Avenue
158.38
(also
Running thence South
feet at or about the
known as Route 100)
43° 10' 00"
center line
West a distance of
of Hillside Avenue
121.53
(else
Running thence South
feet at or about the
known as Route 100,
36° 40’ 30"
cent-u line
West a distance r.f
of Hill sice V.'erue
102.92
f a I sc
Running thence South
feet at or about the
known as Route 100)
25s 06' 30"
center line
West a distance of
of Hillside Avenue
9 3.36
(also
Running thence North
feet at or about the
known as Route 100)
86° 33' 40"
center line
West a distance of
of Hillside Avenue
12.48
(also
ft
Running thence South
feet at or about the
known as Route 100)
176 53' 00"
center line
West a distance of
of Hillside Avenue
215.86
(also
Running thence South
feet at or about the
known as Route 100)
15® 34' 30"
center line
West a distance of
of Hillside Avenue
223 .
(aisc
/Tj| cm x>
Running thence South
feet at or about the
known as Route 100)
16° 54’ 10"
renter line
West a distance of
of Hillside ' venue
/ rv! c '
f c*. 1 SC
Running thence South
feet to a point
88° 10’ 20" West a distance of 170.4:
Running thence South
feet tc a point
89® 00' 20" West a distance of 171.00
> l* -8-
u :
Running thence South 89° 35' 20" West a distance of 49.00
feet to a point
Running thence North 80° 37' 40" West a distance of 2 8 . 1C
feet to a point
Running thence South 8 70 41’ 2 0" West a distance of 418.8
feet to a point
Running thence South 88® 26' 10" West a distance of 269 . 5
feet to a point
Running thence South 81° 34' 10" West a distance o f 120.4
feet to a point
Running thence South 86° 11' 00" West a distance of 4 8.11
feet to a point
Running thence South 84® 57' 30" West a distance of 58.42
feet to a point
FuV: ~ 1 n c t.h f t ~ S o u t h S 4 0 0 4' 50” West a distance
r e e ̂ tc d pu x 11 C
Running thence North 86° 04' 20" West a distance o f 111.5
feet to a point
Running thence South 8® 18' 00" East a. distance i 254.62
feet to a point
Running thence South 9® 04' 00" East a. distance <of 104.9'
feet to a point
Running thence South 17® 49' 00" East a distance of 110.2
feet to a point
Running thence South 18® 06' 00" East a distance of 5 6 . 7 £
feet to a point
Running thence South 16° 48' 00" East a distance c f 19 1.:
feet to a point
Running thence North 89® 44' 00" East a distance of 19.32
feet to a point
Running thence North 88® 00' 0U" East a distance of 19 2.:
feet to a point
-9-
( 14?
Running thence North 89° 00’ Oo East a distance of 94.52
feet to a point
Running thence North 88° 43' 00" East a distance of 216.34
feet to a point
Running thence North 87° 28' 00" East a distance of 95.16
feet to a point
Running thence North 86° 06' 00" East a distance of 100.31
feet to a point
Running thence South 89s 20' 00" East a distance of 135."2
feet to a point
Running thence North 88° 30' 00" East a distance of 188.13
feet to a point at or■ about the center line of Hillside
Avenue I[also known as, Route 100)
Running thence South 15® 11' 00" West a distance c f 7 4 2.3 1
feet at or about the center line of Hillside Ave:lue (alsc
cwr a?: Route 100)
Running thence South 89® 321 0 0” West a diST.ar.ce c f 11 6 . ~3
feet to a point
Running thence North 87° 21' 00" West a distance of 57.22
feet to a point
Running thence South 88® 30' 00" West a distance c i 2 C 0.0 2
feet to a point
Running thence South 87® 25' 00" West a distance of 126.01
feet to a point
Running thence South 88® 40’ 00" West a distance of 157.02
feet to a point✓— —,
Running thencev North,. ̂8 5 ® 45'1 00" West a distance of 15.13
feet to a point'*-—
P"-'ning thence South 87° 16'1 00" West i . distance c f <36.11
feet to a point
Running thenceforth >8® 09 ' 00" West a distance of 34.C9
feet to a point- ---
Running thence South 86® 01 ' 00" West a distance of 10' .04
feet to a point
-10'
li?
o*4 o o \ c \
Running thence North 5° 59' 20" West a distance of 435.99
feet to a point
Running thence South 88° 07' 50" West a distance of 806.CS
feet to a point
Running thence South 11° 54' 00" East a distance of 458.87
feet to a point at or about the center line of Old Tarryto.
Road
Running thence North 72® 43' 00" West a distance cf 14.60
feet at or about the center line of Old Tarrytown Road
Running thence South 89° 14' 00" West a distance of 254.50
feet at or about the center line of Old Tarrytcwr. Road
Running thence North 88° 45’ 00" West a distance of 40.50
feet at or about the center line of Old Tarrytown Road
Running thence South 87° 55' 00” West a distance cf 22.03
feet to a point
,.*g thence South 59° 34' 00" West a
at or about the center line cf Old Tarry
- O _ G . . _ C
wr
^ ^ \
n
t f
^ V *
L ' ^ X . t ' J
Running thence South 81° 26' 00" West a distance cf 56.83
feet at or about the center line of Old Tarrytcwr. Road
Running thence South 87° 22' 00" West a distance of 284.92
feet at or about the center line of Old Tarrytcwr. Road
Running thence South 74° 11' 00" West a distance of 59.78
feet at or about the center line of Old Tarrytcwr* Road
Running thence North 88® 22' 00" West a distance of 89.15
feet at or about the center line of Old Tarrytown Road
Running thence southerly a distance of (approximately 2
to the northeasterly corner of lands now or formerly o
Mount Vernon Trap Rock Corporation being at the inters
of the wester1 y boundary of Manhattan Park as shown or.
Map #1015 on a course South 3° 56' 20" West a distance
248.20 feet
Running thence South 3° 25’ 20" West a distance of
approximately 316.4 feet to a point
Running thence South 86® 20' 05" West a distance cf 72
feet to a point
- 11-
ir» h# 0)
c
\
Running thence North 62® 12' 49" West a distance of 257.59
feet to a point
Running thence North 55° 30' 30" West a distance of 348.34
feet to a point at or about the center line of Knollwood
Road
t u Running thence North 28® 41' 30" East a distance of 142.82
feet at or about the center line of Knollwood Road (also
known as Route 100A)
Running thence North 3® 4' 23" West a distance of 93. B4 feet
at or about the center line of Knollwood Road (also known as
Route 100A)
Running thence North 39® 25' 10" East a distance cf 233.07
feet at or about the center line of Knollwood Road (also
known as Route 100A)
Running thence North 28® 23' 30" East a distance of 7.9 fee-
at or about the center line of Knollwood Read (also known a:
Route 100A)
Running thence North 35° 20' 10" East a distance cf
approximately 198.44 feet at or about the center line of
Knollwood Road (also known as Route 10GA)
Running thence North 35® 18' 00" East a distance or
feet at or about the center line of Knollwood Road
(also known as Route 100A)
142.1"
\ o T \ .
' ...\ o' 1
Running thence westerTy across Knollwood Read to a pc
where the Village of Elmsford border proceeds in a
northwesterly direction from the westerly side of Kr.
fSBaad-- ------------— --- - ‘ ' " " “
Running thence North 10® 25' 50" West a distance cf
approximately 4115 feet to a point said line being i
to be immediately adjacent to the present border of
Village of Elmsford
it \
nten.ee;
the
Punning thence North 80® 15’ 30" West a distance cf -CC.C*
feet said line being intended to be immediately ac;a cent tc
the present border of the Village of Elmsford
Running thence North 8® 31' 20" East a distance of 512.26
feet along the easterly border of the Sprain Rrook Parkway
to the southerly side of Payne Street
- 12-
f
5
Running thence easterly along the southerly side of Payne
' ’’ ' street a distance of approximately 100 feet to the
•^''intersection formed by the southerly side of Payne Street
. , , and the westerly side of Montgomery Avenue
" Runnina thence northerly across Payne Street a distance ci
"I ,r ■ approximately 50 feet to the intersection formed by the
clr/A- northerly side of Payne Street and the westerly side of
_3 Montgomery Avenue
^0
If'
Running thence along the westerly side of Montgomery Avenu
a distance of 285 feet to a point on the westerly side of
Montgomery Avenue
Running thence easterly and at right angles to the westerl
side of Montgomery Avenue a distance of 150 feet to a pcin
distant 100 feet from the westerly side of Lawrence Avenue
- Running thence northerly and parallel with the westerly si
f Lawrence Avenue (distant 100 feet westerly from the
terly side of Lawrence Avenue) a distance of 400 feet
F v'n: r.g thence -iterly across the Sprair. Erock ?ark,c’ • "
pc m u on the east ..rly side of Executive Ecuxevarc distant
393.20 feet on a course South 34° 37’ 00" West from Mc.vu.me
No. 16 as shown on Map No. 15544 filed in the Westchester
County Clerk’s Office Division of Land Records on August 2
1967
Running
feet to
thence North
a point
55° 23 ’ 00" West a distance of 3C0.CC
Running
feet to
thence North
a point
43s 07 ’ 00" West a distance of 365.9"
Running
feet to
thence South
a point
83° 02’ 00" West a distance of 2 3 5 . SC
Running
feet to
thence South
a point
77° 27' 00" West a distance of 35. 20
Running
feet to
thence South
a point
83 0 39' 00" West a distance of / 0 4.9
Running
feet to
thence North
a point
10° 49' 00" West a distance of 4 7 3 .5
Running
feet to
thence Sou- h
a point
64° 05' 30" West a distance of 4 1 .'3 6
146
-13-
Running
feet to
thence South
a point
42° 23 ' 20" West a distance of 5 3.08
Running
feet to
thence South
a point
12° 58' 20” West a distance of 72.54
Running
feet to
thence South
a point
81° 57 ' 40" West a distance of 3 6.23
Running
feet to
thence South
a point
69° 09 ’ 30" West a distance of 54.13
Running
feet to
thence South
a point
40° 26' 30" West a distance cf 75.29
Running
feet to
thence South
a point
71 e 11' 40" West a distance of 100.90
Running
feet to
thence South
a point
57° 15' 20" West a distance of 100.39
f< nnni nc
i cf *' \ l. 0
thence South
a point
79° 22 ' • Ml~ U West a cist- c c v.- — •* C . 8
Running
feet to
thence South
a point
55° 41 ' 30" W 0 S t a distance 0 z ” 7 . E 8
Running
feet to
thence South
a point
55° 57 ' 50" West a distance cf 91.22
Running
feet to
thence South
a point
42° 00 ' 00" West a distance of 100.60
Running
feet to
thence South
a point
59° 08 ' 50" West a distance of 48.26
Running
feet to
thence South
a point
79° 19 ' 00" West a distance of 18.60
Running
feet to
thence South
a point
89° 03 ' 10" West a distance of ^.25
^ Running thence northwesterly a distance cf 55 feet r.c-re cr
less to the westerly side of Saw Mill River Road (Route 9A
at a point formed by the westerly side of Sav, Mill River
. t w L v j Hoad (Route 9A) and the southerly side of Fairview Park
Drive where same intersect at the southerly end of a curve
'' •* ? to the south having a radius cf 30 feet
-14-
Running thence along the westerly side of Saw Mill River
Road (Route 9A) a distance of 149.83 feet to a point
Running thence along the westerly
Road (Route 9A) South 17® 50' 16"
feet to a point
side of Saw Mill River
East a distance of 36.86
Running thence along the westerly
Road (Route 9A) South 18° 37’ 50"
feet to a point
side of Saw Mill River
East a distance of 832 . Cf
Running thence along the westerly side of Saw Mill River
Road (Route 9A) South 13® 28' 30" East a distance of 272.4
feet to a point
Running thence along a curve to the right with a radiu
731.0 feet, a central angle of 4® 21' 09" a distance o
55.53 feet to a point
Running thence South 81® 00' 20" West a distance of 768.04
feet to a point
Pit*, ing thence South 5° 29' 10" Wes* : u j. - . - ■ >c <. cr "4
feet to a point
Running thence North 56° 31' 40" West a distance of 576..*
feet to a point on the easterly line of lands or one New
York and Northern Railroad Company now, or formerly, New
York Central Railroad Company (Putnuro Division) (hereinaft*
"N.Y.C.RR.P.D.")
Running thence along the easterly line of said
N.Y.C.RR.P.D. North 5® 50' 50" East a distance of 124.67
feet to a point
Running thence along the easterly line of said N.Y.C.RR.P.;
on a curve to the left tangent to the previous course and
having a radius of 1194.06 feet a distance of 697.31 feet
a point
Funning thence northerly along one easterly line of sarn
N.Y.C.RR.P.D. on a curve to the left having a radius of
1177.56 feet, a central angle of 25® 01' 00" a distance cr
514.15 feet to a point
/
Running thence North 52® 46' 20" West a distance of 722.CC
feet to a point
-15-
148
th
m
Running thence northerly on a curve to the right having a
radius of 1399.39 feet, a central angle of 10° 39' 23" a
distance of 260.28 feet to a point
Running thence North 73s 09' 00" East a distance of 16.44
feet to a point
Running thence North 73° 39' 00" East a distance of 1.82
feet to a point
Running thence northerly on a curve to the right having a
radius'of 1382.89 feet, a central angle of 17° 39' 58" a
distance of 426.39 feet
Running thence North 24° 46' 20" West a distance of 250.00
feet to a point
Running thence northerly on a curve to the left having a
radius of 1004.41 feet, a central angle of 22c 33' 15" a
distance of 395.38 feet to a point
Running thence North 47° 19' ?r West a distance c: _-0. C
feet to a point
Running thence North 57c 46' 20" West a distance c: ou4.2
feet to a point
Running thence continuing along the northerly and easterly
lines of "N.Y.C.RR.P.D." as it winds along the southerly
line of lands now or formerly of the County of Westchester
to a point located at the southeasterly corner of lands
shown on a certain map entitled "Westchester Lighting Co.
County of Westchester," said map filed in the Office of th
Clerk"of Westchester County, Division of Land Records, on
1-5-1943 as Map No. 5673; being approximately a distance c
197 feet
Running thence still along said northerly and easterly lin
of said "N.Y.C.RR.P.D.," North 75e 32' 55" West 763.94 fee
to a point
Running thence in a northwesterly direction, along a cvr\
to the right having a radius of 621.78 feet, an ir.tencr
angle of 62° 24' 40", a distance of 677.29 feet to a point
Running thence still along said "N.Y.C.RR.P.D.," North lrc
08’ 15" West 933.97 feet to a point ,
>-
J ■
>
c
r
■ y C -
Running thence still along said railroadmen a curve to tr.e
riaht in a generally northeasterly direction, ^said curve
having an interior angle of 69° 57' 15", a .radius o_ 7d ..oi
feet and a distance of 920.97 feet to a point
Running thence still along said railroad North 56s 49' East
351.24 feet to a point
Running thence still along said railraod, in a generally_
northerly direction, on a curve to the left, haying a racit
of 811.78 feet, an interior angle of 2* 3 d 46 , a dis.a..c
of 305.98 feet to a point
Running thence still along said railroad, North 35° 13’ j.4
£a«t 752.69 feet to a point on the southwesterly line o^ 0.
Saw Mill River Road, as the same is shown on the a.oresaic
filed Map No. 5673
C Ru^irna thence continuing on a prolongation of said line tc
' a point in said Old Saw Mill River Road at the^division lu
^ between the Town of Greenbrugh on the South ana the Town c.
Mount Pleasant or. the N ■ h
( Running thence along said division line cn_a line 9-cera._
"h parallel with the following 2 courses ana aistances
South 48° 26' 56" East 377.83 feet to a point
South 48° 56' 36" East 30.22 feet to a point, said^pcir.t
being a prolongation of the division line between lanes w-
of jlmesButler and/or Emipire City Racing Association, an.
!ands N/F Westchester Lighting Co. as shown on tne aforesa
Map No. 5673
Thence continuing along said division line between the Tow
of Mount Pleasant on th North and the Town of Greenburg..
the South on a line gnerally_parallel to the following
jT courses and distances
On c curve to the left, in a generally Easterly direction,
having a radius of 1946.86 feet, a cent, a . a.cl- n f . 4,
38", a distance of 61.52 feet tc a point
Thence continuing along said division in the same manner,
South 34° 45' 00" West 45.54 feet to a point
South 55° 15' 00" East 102.00 feet to a point
North 34° ‘5' 00" East 41.97 feet to a point
-17-
150
Thence continuing in an easterly direction, alone a curve ‘
the left, having a radius of 1946.86 feet, a central angle
of 2® 23' 15", a distance of 81.125 feet to a point
Thence continuing along said Town division line, in the sa:
manner, the following 14 courses and distances
South 57° 37’ 16” Bast 373.84 feet -
South 57° 53’ 10" East 43.33 feet -
South 63° 20 • 30" East 64.27 feet :
South 68° 16’ 40" East 63.98 feet -
South 71® 57’ 20" East 48.14 feet r
South 75® 31’ 00" East 167.65 feet .
South 75° 03 ’ 30" East 417.19 feet
S c uth 71® 5 8 ’ Ol ‘ East 46,04 feet
South 70 0 36’ 00 East 53.02 feet '
South 67° 40’ 50" East 36.36 feet
South 66° 14 ’ 50" East 71.78 feet
South 63° 42 ’ 50" East 155.58 feet >
South 63® 47 ’ 50" East 376.04 feet
Running thence along a curve to the : a cenerallv
southeasterly direction, naviny a wx <
central angle of 53° 14’ 00", a distance of 830.73 feet r,:
or less, to a point on the aforesaid Town division line, ■
the intersection of Old Saw Mill River Road and Grassland
Road (a/k/a Lower Cross Road)
Running thence from said point, continuing along the
division line between said Towns, in a general..^
direction, all as shown on filed map No. 1879, sheet
a point beinc the prolongation of the Westerly line c
shown on said map as -Property To b e Acquired By The
N*w Y o r k ‘ ,
^ s
-18-
1 * 1-f W
O
M
l
<T
>
(T»
Running thence from said point, continuing along said
division line between the Town of Mount Pleasant on the
North, and the Town of Greenburgh on the South, in a
generally Easterly direction, all as shown on filed Ma
No. 1863, sheet 52, to a point and the Easterly bounds
lands shown on Map No. 1879, sheet 67, as "Property To
Acquired By The City of New York", said easterly line
particularly shown on filed Map No. 1863
Continuing along said division line, in a generally
southeasterly direction, and generally parallel to the
northerly taking lines shown on filed Maps Nos. 19736,
19319, 12821 and 19920, 19993, 19317 and 19484,
respectively, to a point where said division line inte
the easterly side of Knowllwood Road, at the point or
of BEGINNING.
-19-
15?
ft,
U
£
ft
89 Civ. 0591 (GLG)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In the Matter of the
Application of
MYLES GREENBERG and
FRANCES M. MULLIGAN,
Petitioners,
-against-
ANTHONY F. VETERAN, et al.,
Respondents.
RULE 3(G) STATEMENT
Paul Agresta, Esq.
Town of Greenburgh
P.O. Box 205
Elmsford, New York 10523
(914) 993-1546
Attorney for Respondents
Anthony F. Veteran and
Susan Tolchin