NYC 9/11 Public Portal Document
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Levine, Robin
From: Lieberman, Brian [[email protected]]
Sent: Wednesday, October 24, 2007 2:51 PM
To: Levine, Robin
Cc: Schiano, Frank
Subject: FW: OCME - World Trade Center Debris Removal Litigation - Document Retention Directive
Importance: High
PRIVILEGED AND CONFIDENTIAL
ATTORNEY WORK PRODUCT
ATTORNEY CLIENT COMMUNICATION
Robin: It was a pleasure talking to you, and again congratulations on becoming GC. I know we never met during
the course of the WTC Unit's prior work with DEP, but I guess you'll get to know us a bit now.
As we discussed, because the City is still involved in so many new and ongoing WTC-related matters, the Law
Department and our outside counsel for the WTC litigation, Patton Boggs, decided that due diligence and best
practices warrant the use of updated preservation hold notices. We have already disseminated hold
notice/directives at OCME (see below) and have a draft pending with the Mayor's Office (which I will forward
separately), we think that DEP, as one of the other agencies still substantially involved in WTC matters, should
also use an updated preservation hold. Other agencies include OEM, NYPD, DDC, DOB and FDNY.
I agree that it makes no sense to distribute a preservation directive throughout all of DEP. Only a small portion
of the agency's 6000 employees are involved in ongoing projects, such as senior staff and some other personnel
in the Bureau of Environmental Compliance, Legal Affairs and the Commissioner's Office.
Please review and let me know your thoughts as to the form of the preservation hold and recipients. It may
be helpful for me to send you and Frank a list of all the staff we collected from during the evidence collection
project at DEP. I look forward to speaking with you again soon.
Sincerely,
Brian
Brian Lieberman
Senior Counsel
WTC Unit
New York City Law Department
100 Church Street
New York, NY 10007
From: Kamelhar, Leslie [mailto:[email protected]]
Sent: Tuesday, August 14, 2007 2:49 PM
To: ALL_OCME_USERS
Cc: Small, Adlai; Lieberman, Brian; Glasband, Elissa
Subject: OCME - World Trade Center Debris Removal Litigation - Document Retention Directive
Importance: High
OCME - World Trade Center Debris Removal Litigation - Document Retention Directive
As we have communicated in the past, the City of New York remains obligated to preserve documents
that may concern the on-going litigation relating to the response to the aftermath of the collapse of the World
Trade Center (“WTC”) buildings following the attacks of September 11,2001.
10/24/2007
NYC-WTC_000153905
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