The second cause of action alleges that defendants breached the indenture that created the so-called Emergency Egress Easement. It is undisputed that an extension to defendants' building blocks the emergency exit door of plaintiff's building. However, there is an issue of fact as to whether this extension "interferes" with the easement as contemplated by the indenture. The first counterclaim is primarily mandatory in nature as it requires plaintiff to accept a substitute...
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