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NYC Law Department memo on WTC document preservation, 2002

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Memo from NYC Law Department instructing staff to preserve World Trade Center documents as evidence for potential legal actions.

NYC-WTC_000140212–000140231

Folder label: “EPA Cate Jenkins

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NYC 9/11 Public Portal Document

Jenkins v. U.S. Environmental Protection Agency, 88-SWD-2 (ALJ July 10, 1998) Page 34 of 34

11 While the timeliness of the complaint was raised initially as issue, neither party raised it at the hearing, and the respondent devoted only a short paragraph in its brief to the issue. Tlierefore, it is unclear whether timeliness continues to be an issue. Further, a discussion of the timeliness of the complaints is very complicated, since six separate complaints were filed and issues such as the continuing violations theory would have to be addressed. Regardless, because it is recommended that the complaints be dismissed on the merits, there is no reason to discuss the timeliness question, and it will not be addressed in this decision.

i?Dellinger testified that during the summer of 1988 medical waste began to wash up on the shores of New Jersey and New York. As a result of this crisis, Dellinger was made responsible for supervising all activity regarding a newly created medical waste project.

Hwhile complainant's brief states the lower rating was "satisfactory," the record reflects that the lower rating was "fully successful" (CX 224-B).

file://A:\Dismissed.html 12/21/01

NYC-WTC_000140231

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NYC-WTC_000140231Source: NYC Law Department, mirrored locally

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