NYC 9/11 Public Portal Document
MEMORANDUM
TO: JAY COHEN; EED FILE
FROM: COURTNEY E. LINDAHL
DATE: SEPTEMBER 4, 2003
SUBJECT: INITIAL MEETING WITH DEPARTMENT OF ENVIRONMENTAL
PROTECTION, SEPTEMBER 3, 2003
PRIVILEGED AND CONFIDENTIAL
ATTORNEY-CLIENT COMMUNICATION
ATTORNEY WORK PRODUCT
Introduction by Law Department
Jay Cohen gave a brief overview of the nature of the claims that the City is currently
facing with regard to the World Trade Center disaster. He also emphasized the importance of
preserving electronic evidence and the potential repercussions (court sanctions, etc.) if all
possible steps are not taken to preserve evidence. The three goals for the meeting are: 1) Identify
all archives and legacy systems, 2) Identify all current systems, and 3) as of the date of the
Cardozo letter, receive assurances that evidence is being preserved.
E-Mail Systems
Prior to 9/11, DEP used Microsoft MS Mail. They currently use Microsoft
Exchange/Outlook. Since receipt of the Cardozo letter, the e-mail accounts of former DEP
employees have remained open. Some may have been deleted prior to the letter; DEP will check
archives. Each bureau within DEP has its own Exchange administrator and server. DEP stated
they have hard copies of all e-mail, but Jay countered that metadata embedded within the e-mail
is also crucial to the discovery process.
NYC-WTC_000153327
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