On February 09, 2023 a
LETTER / CORRESPONDENCE TO JUDGE
was filed
involving a dispute between
Curtis Gobrecht,
Lovers Leap Farm, Llc,
and
Heinz Grossjohann,
for Real Property - Other (Declaratory Judgment)
in the District Court of Columbia County.
Preview
INDEX NO. E012023019692
NYSCEF DOC. NO. 23
WILLIAM J. BETTER, P.C. RECEIVED NYSCEF: 01/29/2024
Joseph D. Clyne, Esq.
William J. Better, Esq. 1 Albany Avenue, P.O. Box 406 josephdclyne@williamjbetterpc.com
williamjbetter@williamjbetterpc.com Kinderhook, New York 12106
Veronica S. Concra, Esq.
TELEPHONE: (518) 758-1511 veronicasconcra@williamjbetterpc.com
FACSIMILE: (518) 671-3832
January 29, 2024
Hon. Daniel C. Lynch, J.S.C.
Albany County Courthouse, Room 102
16 Eagle Street
Albany, NY 12207
Re: Lovers Leap, et al. v. Heinz Grossjohann
Index No.: E012023019692
Dear Judge Lynch:
This office represents plaintiffs Lovers Leap Farm, LLC and Curtis Gobrecht in the above-
referenced matter, in which a status update has been requested by the Court.
In this action, the plaintiffs assert a possessory right in certain real property located in the Town
of Kinderhook, New York, and seek the imposition of a constructive trust to enforce a promise
with respect to that property.
The defendant in this matter resides in Berlin, Germany, and while he is aware of this action, and
has at points sought to negotiate a resolution through counsel, he will not accept service. As
such, because Germany is a signatory to the Hague Convention on the Service Abroad of Judicial
and Extrajudicial Documents, service documents had to be translated and sent overseas for
review by the German central office, which is now responsible for delivering the documents to
the defendant.
As yet, the German central office has not successfully served the relevant documents upon the
defendant, but we are optimistic that service will be accomplished in the coming weeks.
The plaintiff has twice moved the Court for an extensions to the window for service, and we will
keep the Court informed if another request appears necessary.
Should you have any questions, please do not hesitate to contact my office at the number
provided above.
Sincerely,
Joseph D. Clyne, Esq.
1 of 1
Document Filed Date
January 29, 2024
Case Filing Date
February 09, 2023
Category
Real Property - Other (Declaratory Judgment)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
INDEX NO. E012023019692 NYSCEF DOC. NO. 23 WILLIAM J. BETTER, P.C. RECEIVED NYSCEF: 01/29/2024 Joseph D. Clyne, Esq. William J. Better, Esq. 1 Albany Avenue, P.O. Box 406 josephdclyne@williamjbetterpc.com williamjbetter@williamjbetterpc.com Kinderhook, New York 12106 Veronica S. Concra, Esq. TELEPHONE: (518) 758-1511 veronicasconcra@williamjbetterpc.com FACSIMILE: (518) 671-3832 January 29, 2024 Hon. Daniel C. Lynch, J.S.C. Albany County Courthouse, Room 102 16 Eagle Street Albany, NY 12207 Re: Lovers Leap, et al. v. Heinz Grossjohann Index No.: E012023019692 Dear Judge Lynch: This office represents plaintiffs Lovers Leap Farm, LLC and Curtis Gobrecht in the above- referenced matter, in which a status update has been requested by the Court. In this action, the plaintiffs assert a possessory right in certain real property located in the Town of Kinderhook, New York, and seek the imposition of a constructive trust to enforce a promise with respect to that property. The defendant in this matter resides in Berlin, Germany, and while he is aware of this action, and has at points sought to negotiate a resolution through counsel, he will not accept service. As such, because Germany is a signatory to the Hague Convention on the Service Abroad of Judicial and Extrajudicial Documents, service documents had to be translated and sent overseas for review by the German central office, which is now responsible for delivering the documents to the defendant. As yet, the German central office has not successfully served the relevant documents upon the defendant, but we are optimistic that service will be accomplished in the coming weeks. The plaintiff has twice moved the Court for an extensions to the window for service, and we will keep the Court informed if another request appears necessary. Should you have any questions, please do not hesitate to contact my office at the number provided above. Sincerely, Joseph D. Clyne, Esq. 1 of 1