SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND THE TOWN OF RAMAPO Plaintiff/Petitioner, -against- Index No. MOSDOS SANZ KLAUSENBERG 031147/2016 Defendant/RespondentE NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING PLEASE TAKE NOTICE that the matter captioned above has been commenced as an electronically filed case in the New York State Courts Electronic Filing System as required by CPLR 2111 and Uniform Rule 202.5-bb (mandatory electronic filing). This notice is being served as required by that rule. 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They can serve and file documents in paper form and must be served with documents in paper form. However, an unrepresented litigant may participate in e-filing. Page 1 of 2 . EFM-1 For information on how to participate in e-filing, unrepresented litigants should contact the appropriate clerk in the court where the action was filed or visit MW gov/efileunrepresented. Unrepresented litigants also are encouraged to visit or contact the Help Center in the court where the action was filed. An unrepresented litigant who consents to e-filing may cease participation at any time. However, the other parties may continue to e-file their court documents in the case. For additional information about electronic filing and to create a NYSCEF account, visit the NYSCEF website at or contact the NYSCEF Resource Center (phone: 646- 386-3033; e-mail: Dated: 04/05/2016 Signature Michael Specht Name Michael Klein, Town Attorney of the Town of Ramapo Firm Name 237 Route 59 Address Suffern, NY 10901 City, State, and Zip 845?357-5100 Phone gittelmanj@ramapo.Org E?Mail To: Mosdos Sanz Klausenberq 8 Eckerson Lane Monsey, New York 10952 9/3/1 5 Index Page 2 of 2 EFM-1 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND THE TOWN OF RAMAPO, SUMMONS Plaintiff, 7 ?against- Index No. 031147/2016 MOSDOS SANZ KLAUSENBERG, Defendant. To the above named Defendant: You are hereby summoned to answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance, on the Plaintiffs Attorney within 20 days after the service of this summons, exclusive of the day of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear- _or answer, judgment will be taken against you by default for the relief demanded in the complaint. Michael L. Klein, Esq. By? Michael B. Specht, Esq. Attorney for Plaintiff 237 Route 59 Suffem, New York 10901 Dated: Suffern, New York March 31, 2016 To: MOSDOS SANZ KLAUSENBERG 8 Eckerson Lane Monsey, New York 10952 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND - THE TOWN OF RAMAPO, VERIFIED Plaintiff, COMPLAINT -against? Index No. 031147/2016 MOSDOS SANZ KLAUSENBERG, Defendant. . Plaintiff, by its attorney, Michael L. Klein, Esq., complaining of the defendants, alleges as follows: 1. Plaintiff is a municipal corporatiOn organized and existing under the laws of the State of New York, situated in Rockland County, New York whose principal of?ces are located at 237 Route 59, Suffern, New York. 2. Upon information and belief, that at all times hereinafter mentioned, defendant MOSDOS SANZ KLAUSENBERG was and still is the owner of certain lands and premises located in the Town of Ramapo at 8 Eckerson Lane, Monsey, New York and designated on the Town of Ramapo tax map as Section /Block/Lot 3. Upon information and belief, defendant operates the premises located at 8 Eckerson Lane as a school. 4. Pursuant to Section 376-76 of the Zoning Law of the Town of Ramapo, the Director of Building, Planning and Zoning of the Town of Ramapo is authorized to issue a permit for the temporary use of modular units that have applications pending for site development plan approval to the Planning Board for the approval of construction of a school. 5. Pursuant to Section 376?76 of the Zoning Law, permits for temporary modular units are good for a period of twelve months, and one additional extension of one year can be granted for good cause shown. 6. On or about July 23, 2013, the Director of Building, Planning and Zoning issued a temporary certi?cate of occupancy to the defendant" for the use of an existing house on the property as a school. This certi?cate of occupancy expired on July 23, 2014 and was issued a one year extension, which expired on July 23, 2015. 7. On October 29, 2014, the Director of Building, Planning and Zoning issued a certi?cate of occupancy for the use of temporary modular units as classroom space. This certi?cate of occupancy expired on October 29, 2015. No extension was granted, as the extension for the use of the existing house had expired previously. 8. Upon information and belief, the temporary modular unites at the premises continues to be used by defendant as a school without the issuance of a certi?cate of occupancy or site development plan approval, and after the expiration of the temporary use permit. 9. The above described conditions are in violation of the Code of the Town of Ramapo. 11. The unlawful use of the premises violates the following sections of the Zoning Law of the Town of Ramapo: a) Use of the premises as a school without appropriate certi?cate of occupancy authorizing said use (Zoning Code. of the Town of Ramapo Section b) Use of the premises as a school without an approved site development plan (Zoning Code of the Town of Ramapo Section 376?90; 7 c) Use of temporary modular units after expiration of a permit (Zoning Code of the Town of Ramapo Section 376-67). 12. If the defendant is not enjoined from the use and operation of the premises except in conformity with any certi?cate of occupancy, the same will continue in an unlawful manner and will continue to be violative of the laws of the Town of Ramapo. WHEREFORE, for all the foregoing reasons, plaintiff demands judgment permanently enjoining and directing the defendants to cease all use and occupancy of the premises except in conformity with any certi?cates of occupancy, and that the plaintiff have such other and further and different relief as justice may require together with the costs and disbursements of this action. Dated: Suffem, New York April 4, 201 6 Yours, etc. MICHAEL L. KLEIN, ESQ. By, Michael B. Specht, Esq. Deputy Town Attorney Attorney for Plaintiff 237 Route 59 Suffern, New York 10901 (845) 357?5100 A TT ORNE VERIFICA I 0N STATE OF NEW YORK COUNTY OF ROCKLAND That Michael Specht is an attorney duly admitted to practice law in the Courts of the State of New York; that deponent is a Deputy Town Attorney for the Town of Ramapo, one of the parties in the within action: and deponent has read the foregoing Verified Complaint knows the contents thereof, and that the same is true, upon information and belief, and deponent believes them to be true. This written veri?cation is made by deponent and not the Town of Ramapo because the Town of Ramapo is a municipal corporation. The grounds of deponent?s belief as to all matters are as follows: Books and Records in the Town Hall The undersigned af?rms the foregoing as true under the penalties of perjury. Dated: Suffern, New York April 5, 2016 Michael Specht