On March 23, 1994, defendant circulated a memorandum to all horsemen and trainers who stabled horses at Saratoga Raceway (hereinafter Raceway), a harness racing track located in the City of Saratoga Springs, Saratoga County, advising them they would have to remove their horses and property from the Raceway by 4:00 P.M., on April 1, 1994 if they had not submitted a stall application on March 10, 1994. Thereafter, on March 31, 1994, defendant...
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