Opposition Brief — Hausch v. Grievance Committee Committee Committee for the Ninth Judicial Judicial District (No. 08-748)

OFFICE OF THE CLERK

Supreme Court of The United States

VIVIAN L. HAUSCH,

Petitioner,

- against -

GRIEVANCE COMMITTEE FOR

THE NINTH JUDICIAL DISTRICT,

Respondent.

Petition for a Writ of Certiorari to the

New York State Court of Appeals

BRIEF IN OPPOSITION

GARY L. CASELLA

Chief Counsel

FORREST STRAUSS

Of Counsel

GRIEVANCE COMMITTEE

9™ JUDICIAL DISTRICT

399 Knollwood Road - Suite 200

White Plains, New York 10603

(914) 949-4540

Appeal Press - (914) 761-3600 (212) 267-6602 (516) 872-1110 (13864

TABLE OF CONTENTS

Page

Table of Contents ....6....:420508580 i

Table of Authorities. ............<55.52 il

Preliminary Statement .................. 1

Acqua, .... ss iescca sean 8

POINT I:

Appellant Has Not Presented A

Question Appropriate For This

Courts) RWG ose aen eee 8

POINT II:

Appellant Is Time Barred From

Seeking Certiorari On the Basis

of Her Second Reason ............. 14

Conclusion

TABLE OF AUTHORITIES

Cases:

Erdman v. Stevens,

458 F2d 1205 (2d Cir., 1972) Cert.

denied ,409 U.S. 889, 93 S. Ct. 126

oo in yc ae cel a cee ea 12

Heatherman v. USDC For The Central District,

503 F2d 1032 (9" Circuit, 1974) ....... 9

Javits v. Stevens,

382 F. Supp. 131, 141 (S.D.N.Y. 1978) 12

Maggio v. Hynes,

423 F.Supp 144 (EDNY, 1976)....... 9

Matter of Capoccia,

59 N.Y.2d 549, 552-553 (1983) ...... 13

Matter of Dondi,

Oa m.v.oe gol C1964) ............. 13

Matter of Gould,

DU 5. 'n: toca See Se 13

Matter of Hausch,

36 A.D.3d 141; 825 N.Y.S.2d 109;

2006 N.Y. App. Div. LEXIS 13859

a er eee ee |

Matter of Hausch,

8 NY3d 801, 828 NYS2d 292

.

Matter of Hausci..

NYSlpOp 84168(U) (2d Dep’t, 2007) .. 6

Matter of Hausch,

2008 NYSlipOp 64537(U)

of) re re ee 7

Matter of Hausch,

10 N.Y.3d 713; 891 N.E.2d 308;

861 N.Y.S.2d 273; 2008 N.Y. LEXIS

BPE CRE gi cee ewccss 7

Matter of Hausch,

11 N.Y.3d 760; 894 N.E.2d 1194;

864 N.Y.S.2d 804; 2008 N.Y.

Re EE gk os ws So os eo wees 8

Matter of Rouss,

221N. Y. 81, 84,116 N. E. 782,783 . 13

Matter of Walker,

113 AD2d 254, 356 (1° Dep’t 1985) .. 11

Matter of Wysell,

10 AD2d 199 (1** Dep’t, 1960)....... 13

Mildner v. Gulotta,

405 F.Supp 182, 188 (EDNY 1975),

affirmed 425 US 901 (USNY 1976)... 11

St. Regis Paper Company v. U.S.,

368 U.S. 208, 219, 82 S.Ct. 289 (1961) .. 9

Theard v. U.S., 354 U.S. 278 (1957) ....... 13

Statutes:

ee ar he on no a eG de eek 9,10,11

NY CLS JUDICIARY LAW §90(2) ........ 11

Other Authorities:

oR eh BY ee 11

Mh ts EE passim

re @ pik 2 Gare aranr ll

Sm POE BEORE-AOO) 25 ee eee 11

PRELIMINARY STATEMENT

By order of the Appellate Division, Second

Department, dated and entered on October 15, 2004,

the Grievance Committee for the Ninth Judicial

District was authorized to institute and prosecute a

disciplinary proceeding against VIVIAN HAUSCH, an

attorney and counselor-at-law, on the basis of a July

19, 2004 petition containing eight charges of

professional misconduct. The Court’s order further

referred the issues raised by the petition and any

answer thereto to the Hon. Lawrence J. Tonetti, as

Special Referee, “to hear and report.”

The Committee’s July 19, 2004 petition contained

eight (8) charges, six of which were predicated upon

appellant Hausch’s alleged misconduct in response to

zoning code enforcement efforts regarding the use and

occupancy of 99 Main Street, Tuckahoe, New York —a

storefront office owned by appellant Hausch’s client

P&N Tiffany Properties, Inc. and litigation that

resulted therefrom. The remaining charges arose

from appellant Hausch’s failure to comply with

requests, made by the respondent Committee during

the course of it’s investigation of those matters, that

she provide specific information regarding her client

and its corporate structure, as well as a request that

she come to the respondent Committee’s office and give

testimony under oath regarding the foregoing matters.

Appellant Hausch submitted an answer, dated

November 30, 2005, wherein she denied the charges of

professional misconduct alleged therein and proffered

various legal and factual explanations in defense of her

alleged misconduct.

Once issue was joined, and preliminary issues

were addressed, the Special Referee conducted

hearings in the disciplinary matter, after which both

parties were permitted to submit post-hearing

memoranda. In its “Proposed Findings,” the

respondent Committee conceded that it could not prove

Charges Four, Five, Six, and Seven of the petition as

drafted, and that said charges should therefore be

withdrawn and/or dismissed. The Special Referee

thereafter adopted the proposed report of the

respondent Committee, and submitted his findings in

a November 14, 2005 report to the Appellate Division,

Second Department. Therein he concluded that

Charges One, Two, Three, and Eight of the petition

should be sustained.

The parties thereafter each moved to confirm

and/or disaffirm as their respective interests dictated.

By order of the Appellate Division, Second

Department, dated and entered on November 21, 2006,

that Court found that Charges One, Two, Three and

Eight of the petition had been correctly sustained, and

that appellant Hausch had engaged in professional

misconduct, including:

(a) conduct prejudicial to the administration of

justice and/or which adversely reflected upon

her fitness as a lawyer on the basis of her

failure to cooperate with the lawful directives of

the Village of Tuckahoe, and

(b) additional conduct prejudicial to the

administration of justice and/or which adversely

reflected upon her fitness as a lawyer on the

basis of her failure to cooperate with the lawful

demands of the respondent Committee and its

efforts to investigate her conduct with respect to

iw)

the Village of Tuckahoe, and

(c) disregarding and/or counseling her client to

disregard one or more rulings made by a

tribunal in the course of a proceeding, and

(d) conduct involving dishonesty, fraud, deceit, or

misrepresentation on the basis of material

misrepresentations she made to the respondent

Committee and/or other local and_ state

government authorities regarding the location

of her law office.

Based upon these findings, the Appellate Division,

Second Department ordered that appellant Hausch be

suspended from the practice of law for a period of six

(6) months, effective December 21, 2006. Matter of

Hausch, 36 A.D.3d 141; 825 N.Y.S.2d 109; 2006 N.Y.

App. Div. LEXIS 138859 (2d Dep't, 2006)(see

Appellant’s Appendix E).

On December 14, 2006, the New York State Court

of Appeals declined to sign an Order to Show Cause

presented by the appellant Hausch as part of her

application for a stay of the November 21, 2006

Opinion and Order of the Appellate Division, Second

Department. Appellant Hausch thereafter filed an

application seeking leave to appeal to the New York

State Court of Appeals on the same date. This

application to the New York State Court of Appeals for

permissive leave to appeal was denied in an Order

dated January 9, 2007. Matter of Hausch, 8 NY3d 801,

828 NYS2d 292 (NY, 1/9/07).

On June 22, 2007, appellant Hausch moved before

the Appellate Division, Second Department for

reinstatement to the practice of law at the conclusion

of her six-month suspension. The respondent

Committee immediately filed an “Affirmation in

Response,’ citing the fact that, among other things: (a)

appellant’s reinstatement application was not in the

form required by 22 NYCRR §691.11, (b) she had failed

to provide copies of her state and federal income tax

returns for the period of her suspension, and (c) failed

to provide proof that she hz 1 completed sufficient

continuing legal education credits required under 22

NYCRR §691.11. However, it took no position upon

whether or not appellant’s petition for reinstatement

should be granted.

Upon information and belief, the Clerk of the

Appellate Division, Second Department thereafter

rejected appellant Hausch’s June 22, 2007 papers on

the basis of her failure to follow the required format

specified in 22 NYCRR §691.11. The respondent

Committee’s “Affirmation in Response” was also

returned by the Court at or about the same time.

However, appellant Hausch, having been served with

a copy of the respondent Committee's “Affirmation in

Response,” thereafter served and filed a

“Supplemental Affidavit,” in what appeared to be an

effort to comply with the format dictated by 22 NYCRR

§691.11.

Once again, the respondent Committee prepared

a response, which it denominated as a “Supplemental

Affirmation in Reply,” wherein it again highlighted the

various ostensible deficiencies in appellant Hausch’s

latest submission’, but continued to take no position

Including the filure to provide tax returns, proof of completion of

required Continuing Legal Education courses, or any other

explanation regarding a judgment for unpaid taxes entered

against her client P&N Tiffany Properties by the NYS Tax

Commission. Appellant's role in corporate structure of P&N

Tiffany Properties was one of the issues appellant Hausch

steadfastly refused to provide any information about during the

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upon appellant Hausch’s application for reinstatement

itself. Upon information and belief, appellant Hausch’s

“Supplemental Affidavit” was again deemed unsuitable

for filing and also returned to her by the Clerk of the

Appellate Division. However, the respondent

Committee’s “Supplemental Affirmation in Reply” was

not returned and was, instead, upon information and

belief, retained in the Appellate Division, Second

Department’s docket file for future reference.

Appellant Hausch thereafter filed yet another

motion for reinstatement, dated July 13, 2007, with

the Appellate Division, Second Department. Appellant

Hausch’s July, 2007 application was supported by an

attached affidavit that (a) asserted compliance with

the CLE requirements by virtue of her having

completed a CLE course on July 11, 2007, but (b) was

otherwise essentially the same “Supplemental

Affidavit” previously rejected by the Appellate

Division, Second Department.

On July 16, 2007, the respondent Committee

advised the Clerk of the Appellate Division, Second

Department that the concerns cited in its previously

submitted and retained “Supplemental Affirmation in

Reply” were equally applicable to both of appellant

Hausch’s two most recent submissions and that,

therefore, no new papers would be submitted in

response to the July 13, 2007 motion at that time.

On or about September 29, 2007, appellant

Hausch served and filed a “Second Supplemental

Affidavit” with the Appellate Division, Second

Department, wherein she again petitioned that court

for reinstatement on essentially the same petition, but

now sought a waiver of the requirement that she

course of the underlying disciplinary proceeding.

+)

submit copies of her tax returns with that application.

The respondent Committee prepared and submitted an

“Affirmation in Reply,” dated October 9, 2007, wherein

it reiterated the same concerns expressed earlier and

submitted that appellant Hausch should be held to the

same standard of compliance with 22 NYCRR §691.11

as every other attorney reinstatement applicant.

However, once again, the respondent Committee took

no position upon appellant Hausch’s application for

reinstatement, relying instead upon the Court’s

discretion to determine it in the interests of justice.

On November 21, 2007, the Appellate Division,

Second Department issued a “Decision and Order on

Motion for Reinstatement” wherein it formally denied

appellant Hausch’s application for a waiver of the

requirement that she submit her tax returns and held

her application for reinstatement in abeyance for a

period of 30 days pending her submission of same.

Matter of Hausch, NYSlipOp 84168(V) (2d Dep’t, 2007?

(see Appellant’s Appendix D).

On December 18, 2007, appellant, Hausch filed yet

a “Third Supplemental Affidavit,” with the Appellate

Division, Second Department, wherein she asserted

that proof of filing was all that the rule required and

claimed’ that she had documented her proof of same

with respect to her federal tax returns. Once again,

the respondent Committee submitted yet another

“Affirmation in Reply,” dated December 26, 2007,

wherein it again highlighted its ongoing concerns,

including the similarity between appellant Hausch’s

conduct in this matter and the conduct that led to her

* In fact, all respondent did was provide proof that she had

requested proof of filing of her returns. No proof of actual filing at

was provided to the court.

suspension from practice, but otherwise took no

position upon respondent’s application.

On January 2, 2008, the Clerk of the Appellate

Division, Second Department advised appellant

Hausch in writing that, inter alia, compliance with

that Court’s November 21, 2007 order and 22 NYCRR

§691.11 would require the production of copies of her

tax returns and not mere proof of filing (see

Appellant’s Appendix F). On January 9, 2008,

appellant Hausch submitted a “Fourth Supplemental

Affidavit,” wherein she advised the court that

“regrettably, I cannot submit my income tax returns to

the court in order to be reinstated as a lawyer.” Ina

“Decision and Order on Motion for Reinstatement,”

dated February 22, 2008, appellant Hausch’s

application for reinstatement was finally denied by the

Appellate Division, Second Department. Matter of

Hausch,2008 NYSlipOp 64537(U)(2d Dep’t, 2008)(see

Appellant’s Appendix C).

On April 10, 2008, appellant Hausch filed a

“Motion for Leave to Appeal” with the New York State

Court of Appeals, seeking permissive leave to appeal

from the February 22, 2008 Order of the Appellate

Division, Second Department. The respondent

Committee opposed this application in an “Answer in

Opposition to Motion for Permissive Leave to Appeal,”

dated April 18, 2008. The New York State Court of

Appeals in an Order dated and entered June 10, 2008

thereafter denied appellant Hausch’s application for

permissive leave to appeal. Matter of Hausch, 10

N.Y.3d 713; 891 N.E.2d 308; 861 N.Y.S.2d 273; 2008

N.Y. LEXIS 1507;2008 NYSlipOp 74142 (NY,

2008)(see Appellant’s Appendix A).

On July 10, 2008, appellant Hausch moved for re-

~]

argument of the June 10, 2008 decision by the New

York Court of Appeals and the respondent Committee

thereafter filed opposition papers, dated July 18, 2008.

Appellant Hausch’s motion for reargument was

thereafter denied in an Order, issued by the New York

State Court of Appeals, dated and entered September

9, 2008. Matter of Hausch, 11 N.Y.3d 760; 894 N.E.2d

1194; 864 N.Y.S.2d 804; 2008 N.Y. LEXIS 2658; 2008

NYSlipOp 74142 (NY, 2008)(see Appellant’s Appendix

B).

ARGUMENT

POINT I

Appellant Has Not Presented A Question

Appropriate For This Court’s Review

While couched in constitutional allegory,

appellant Hausch seeks nothing more than appellate

review of the Appellate Division, Second Department’s

refusal to reinstate her to the practice of law on her

own stubbornly dictated terms when she has failed to

meet her burden of proving her character and fitness

under the expressly stated requirements of 22 NYCRiv

§691.11.

In the first of the two “Reasons for Granting the

Writ” proffered by appellant Hausch. she endeavors to

persuade this honorable Court that her right to

privacy under the United States Constitution has been

unjustly infringed 22 NYCRR §691.11 where it

requires copies of her tax returns in her application for

reinstatement to the practice of law. However, 26 USC

§6103 did not create and does not embody the

sweeping, constitutionally guaranteed, absolute, right

to privacy of all income tax returns and taxpayer

information that appellant would have this honorable

Court believe.

In fact, the confidentiality and non-disclosure

obligations in that section apply to only the Internal

Revenue Service (“IRS”) and not the individual

taxpayer or other private parties. Moreover, the

provisions of 26 USC §6103 itself contain numerous

exceptions to the statutory confidentiality embodied

therein, each of which permits the Internal Revenue

Service to reveal that information to various federal

and state agencies under a variety of conditions and

circumstances. What 26 USC §6103 does not contain,

however, is any provision that would bar an individual

taxpayer from voluntarily providing such information

when requested to do so.

Consistent with this view, it has been

repeatedly held that tax returns in the hands of the

taxpayer are not privileged and therefore discoverable.

In St. Regis Paper Company v. U.S., 368 U.S. 208, 219,

82 S.Ct. 289 (1961), this honorable Court held that tax

returns in the taxpayer’s possession were discoverable

in litigation. In Heathermanv. USDC For The Central

District, 503 F2d 1032 (9 Circuit, 1974), the 9”

Circuit Court of Appeals again held that 26 USC §6103

applies only to the release of tax information by the

government while concluding that tax returns in the

taxpayer’s possession are not privileged and not

subject to its restrictions. Similarly, in Maggio v.

Hynes, 423 F.Supp 144 (EDNY, 1976), the United

States District Court for the Eastern District of New

York held that even tax returns in the possession of

the taxpayer's accountant are not privileged or barred

from discovery by 26 USC §6103 while finding no merit

CO

to the taxpayer’s claim that discovery of the returns

violated the taxpayer’s rights to privacy and/or

freedom from unreasonable search and seizure under

the United States Constitution.

Clearly, the requirement that an attorney

seeking reinstatement submit copies of his/her tax

returns does not invade any constitutionally protected

right to privacy. In the instant matter, 22 NYCRR

§691.11 requires only that attorneys (i.e. the

taxpayers) seeking reinstatement provide copies of

their tax returns for the period during which they were

suspended or disbarred. Since the confidentiality

imposed by 26 USC §6103 applies only to the IRS, and

22 NYCRR §691.11 seeks only tax returns and

information directly from the taxpayer, there is

neither a constitutional nor statutory prohibition to

this rule.

Moreover, the requirement that attorney

reinstatement applicants provide tax returns at some

point in the reinstatement process is hardly unique.

Upon information and belief, outside of New York, at

least thirteen (13) other states* require reinstatement

applicants to submit tax returns for use in assessing

the character and fitness of disciplined attorneys

seeking reinstatement to the bar. Within New York,

the Appellate Division, First Department, requires

that tax returns must be provided by attorneys seeking

reinstatement after a period of suspension greater

than six (6) months while the Second, Third, and

Fourth Appellate Departments each require the

% Arizona, California, Indiana, Louisiana, Massachusetts,

Maryland, Pennsylvania, Oregon, Oklahoma, Rhode Island, Utah,

Virginia, and Wisconsin

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production of tax returns as part of any application for

reinstatement, regardless of the length of the

applicant’s suspension. See 22 NYCRR §603.14 [1*

Dep’t]; 22 NYCRR §691.11 [2d Dep’t]; 22 NYCRR

§806.12 [3d Dep’t]; and 22 NYCRR §1022.28(3) [4"

Dep’t]; 22 NYCRR §603.14 [1% Dep’t], 22 NYCRR

§691.11 [2d Dep’t]; 22 NYCRR §806.12 [3d Dep't]; and

22 NYCRR §1022.28(3) [4" Dep't].

This de minimus difference does not, however,

rise to the level of unequal treatment suggested by

appellant. Instead, it merely reflects the fact that, in

New York, the four Appellate Divisions of the New

York State Supreme Court have exclusive jurisdiction

over attorney disciplinary matters within their

respective departments. See NY CLS Jud §90(2); see

also Mildner v. Gulotta, 405 F.Supp 182, 188 (EDNY

1975), affirmed 425 US 901 (USNY 1976). Since

reasons of policy regarded as significant by one

Appellate Department in their effect on the conduct of

attorneys may not prevail in another Department,

because of differing conditions in those jurisdictions, it

has been held that the rules governing the conduct of

attorneys licensed to practice law before those courts

may vary. Nothing in the Constitution or statutes

guarantees that different jurisdictions must adhere to

identical procedures. Matter of Walker, 113 AD2d 254,

356 (1% Dep’t 1985).

Nor is such a requirement unreasonable where

an attorney’s character and fitness to practice law is at

issue. A special relationship exists between the

attorney and the court that grants him or her a license

to practice law before it. “No other body is as well

qualified or as interested in determining whether an

attorney is qualified to practice law.” See Javits uv.

1]

Stevens, 382 F. Supp. 131, 141 (S.D.N.Y. 1978). Thus,

state courts have traditionally been allowed wide

discretion in the establishment and application of

standards of professional conduct and moral character

to be observed by their court officers. Erdman_ov.

Stevens, 458 F2d 1205 (2d Cir., 1972) Cert. denied 409

U.S. 889, 93S. Ct. 126 (1972). What appellant Hausch

fails to grasp is that it is the Appellate Division, and

not she, who determines what is required to establish

an attorney’s character and fitness to engage in the

practice of law.

Where the character and fitness of an attorney

to practice law is at issue, tax returns and the

information they contain provide the Courts with

substantial information about the applicant’s conduct

during the period of suspension, including but not

limited to: (a) how the applicant has earned a living,

(b) the completeness and timeliness of the applicant’s

compliance with any income reporting and tax

payment obligations, and (c) whether or not the

applicant has held oneself out as an attorney to the

government or other third parties, during the period of

suspension or disbarment. Such information also

affords corroboration and confirmation of other claims

made by the disciplined attorney applicant as part of

their reinstatement application, a _ particularly

valuable tool where the applicant, like appellant

Hausch, has been previously found guilty of conduct

prejudicial to the administration of justice and/or

conduct involving dishonesty, fraud, deceit, or

misrepresentation.

Ultimately, appellant Hausch grossly misleads

this honorable court where she suggests that attorneys

are forced to choose between giving up their

12

constitutional rights and giving up their rights to

make a living. What appellant Hausch fails to grasp

is that the ability to practice law in the State of New

York is not a right, but rather a privilege, burdened

with conditions, surrounded with a public interest, and

vested with a private responsibility. Theard v. U.S.,

354 U.S. 278 (1957), citing Matter of Rouss, 221 N. Y.

81, 84, 116 N. E. 782, 783; See also: Matter of Dondi,

63 N.Y.2d 331 (1984); Matter of Capoccia, 59 N.Y.2d

549, 552-553 (1983); Matter of Wysell, 10 AD2d 199 (1"

Dep't, 1960).

If appellant Hausch wishes to regain the

privilege of practicing law in New York State, she

must first satisfy the Court by clear and convincing

evidence that she has both complied with the

provisions of the order suspending her and that she

now possesses the requisite character and general

fitness to resume the practice law. 22 NYCRR

§691.11(c)(1). The public must be protected “tn its

reliance upon the integrity and responsibility of the

legal profession.” Matter of Wysell, supra, citing Matter

of Gould, 4 AD2d 174,175.

Yet, appellant Hausch has utterly, completely,

and totally failed to meet that burden, even after

multiple opportunities were afforded to her by the

reviewing court and her obligations were repeatedly

and clearly explained to her. The denial of her

reinstatement application is the direct result of her

own deliberate, knowing, willful and contumacious

refusal to undertake the necessary acts, provide the

required information, and follow the procedures

required to persuade the Court of her fitness to

practice law. She should not now be heard to complain

about the denial of that relief when such was directly

13

engineered by her own stubbornly foolish actions.

There is no basis upon which appellant Hausch’s

instant petition can or should be granted and her

petition must therefore be denied.

POINT Il

APPELLANT IS TIME BARRED FROM

SEEKING CERTIORARI ON THE

BASIS OF HER SECOND REASON

In the second of appellant’s “Reasons for Granting

the Writ,” she endeavors to reprise and relitigate the

very same issues she failed to prevail on in the

underlying disciplinary hearing in this matter.

Virtually all of these issues (with the exception of

the grossly scandalous and totally baseless accusations

she makes against the petitioner’s staff counsel) were

previously the subject of appellant’s December, 2006

application for permissive leave to appeal to the New

York State of Court of Appeals. The New York State

Court of Appeals in its order of January 9, 2007 denied

that application. Matter of Hausch, 8 NY3d 801, 828

NYS2d 292 (NY, 1/9/07).

Accordingly, appellant was already time barred

from petitioning for further appellate review of that

determination at the time she began the reinstatement

process. Moreover, while those issues were not raised,

at any time, during the course of appellant’s failed

attempt at reinstatement, she nevertheless included

them in her March, 2008 application to the New York

Court of Appeals for leave to appeal from the order

denying her petition for reinstatement. In its response

to that application, the respondent Committee argued

14

that the January 9, 2007 order was res judicata

therein and that appellant was therefore estopped by

virtue thereof from again litigating those same

arguments and issues in her latest application for

permissive leave to appeal.

By trying to renew an already time-barred

claim, appellant seeks to deceive this honorable Court

into granting certiorari on the basis of issues and

claims that she would not otherwise be legally able to

argue.

Accordingly, respondent-appellant’s application

on these grounds should be denied in its entirety.

CONCLUSION

Appellant Hausch has failed to articulate any

grounds that would justify her petition for a Writ of

Certiorari to this honorable Court herein. Accordingly,

it is respectfully submitted that appellant Hausch’s

application should be dismissed in its entirety.

Dated: January 12, 2009

White Plains, New York

Respectfully submitted by,

ORREST STRAUSS

Of Counsel

GRIEVANCE COMMITTEE

FOR THE 9" DISTRICT

399 Knollwood Road

White Plains, N.Y. 10603

(914) 949-4540 x209

15