DEP tickler log entry, Sept-Oct 2004

NYC 9/11 Public Portal Document

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begin the evidence collection process there by late September, parallel with the conduct of the process at the Department of Health and Mental Hygiene.

In conducting the Project, we intend to build upon our long and excellent working relationship with DEP. Our attorneys have worked closely with Deputy Commissioner Robert Avaltroni, Assistant Deputy Commissioner Michael Gilsenan, Asbestos Control Unit Director Krish Radhakrishnan and other DEP officials on City Council hearings, the EPA WTC Technical Expert Panel and other matters.

The Project functions on a streamlined, systematic basis. We use specific “Task Forces” of WTC attorneys and paralegals to identify, interview and collect WTC-related documents and electronic information from City agency officials and employees who participated in the WTC response or who now have possession of such materials.

We will start by distributing evidence questionnaires for DEP personnel to fill out (either in writing or through e-mail) so that we may initially identify those whom we need to interview. Our “DEP Task Force” intends to begin this process with your Deputy Commissioners and other senior staff. Based upon the information these officials provide, we will provide questionnaires to other officials and staff and meet with those who have WTC materials. We will collect and copy all WTC materials in your staffs possession.

Assistant Corporation Counsel Brian Lieberman, who has worked on numerous matters with Deputy Commissioner Avaltroni and other DEP officials, will lead our “DEP Task Force.” Brian, along with a select team of our Unit attorneys and paralegals, is committed to conducting the entire process in a sixty-day period. We are prepared to devote the resources necessary to meet this timetable.

Please feel free to have a member of your staff contact me with any comments or questions you may have. In addition, please advise me as to when in latter September you would be able to meet with us at your offices so we can explain the process and seek the support of your agency in completing this substantial project as efficiently and expeditiously as possible.

Thank you in advance for your cooperation on this important matter.

Sincerely yours,

Jesse I. Levine

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