Request to File as a Related Case with Greenberg and Harris v. City of New York, Index No. 100760/2007, Assigned to Judge Joan Madden
______X
In the Matter of the Application of
Emergency Coalition Organization
To Save Washington Square Park; Jessie McNab;
Ray Brizzi; Susan Furman; Daniel Weinberg; Nina
Reznick; Jerry Sitner;; and Robert Levine,
Petitioners,AMENDED NOTICE
OF
For a Judgment pursuant to CPLR Article 78PETITION
-against-INDEX NO: ______
The City of New York; Michael Bloomberg, in07 102194
his capacity as Mayor of the City of New York;
the New York City Department of Parks and
Recreation; Adrian Benepe, in his capacity as
Commissioner of the Department of Parks and
Recreation; and William Castro, in his capacity
as Manhattan Borough Commissioner of the
Department of Parks and Recreation,
Respondents.
______X
SIRS/MESDAMES:
PLEASE TAKE NOTICE, that upon the annexed Amended Verified Petition duly verified the 21stday of February 2007, and upon all the prior pleadings and proceedings heretofore had herein, anapplication for relief pursuant to Article 78 ofthe C.P.L.R. will be made at the Motion Submission , Part 130, at the Supreme Court located at 60 Centre Street, New York, New York,onthe 20 day ofMARCH 2007, at 9:30 AM ofthat day or as soon thereafter as counsel can be heard for a judgment vacating, annulling and setting aside theNegative Declaration of environmental impact and Environmental Assessment Statement by theNew York City Department of Parks and Recreation regarding the redesign of WashingtonSquare Park, and to require the NewYork City Department ofParks and Recreation to complywith the requirements ofthe State Environmental Quality Review Act ("SEQRA") and the City Environmental Quality Review ("CEQR"), and for such other and further relief as to the Courtmay deem just and proper.
PLEASE TAKE FURTHER NOTICE that pursuant to CPLR § 403(b), answering papersare due at least seven days before return date of this motion.
Dated: New York, New York
February 21, 2007
JOEL R KUPFERMAN
NEW YORK ENVIRONMENTAL LAW & JUSTICE PROJECT
Attorneys for Petitioners
351 Broadway #400
New York, New York10013-3902
(212) 334-5551
TO: Michael A. Cardozo, Corporation Counsel
100 Church Street
New York, New York10007
Attorneys for Respondents
The City of New York and
Michael Bloomberg, in his official capacity as Mayor of the City of New York,
Adrian Benepe, in his capacity as Commissioner of the New York City
Department of Parks and Recreation and
The New York City Department of Parks and Recreation
The Arsenal, Central Park
830 Fifth Avenue
New York, New York10021
William Castro inhis capacity as Manhattan Borough
Commissioner of the Department of Parks and Recreation
The Arsenal, Central Park
830 Fifth Avenue
New York, New York10021