A memo dated January 22, 2003, regarding the preservation of evidence related to the World Trade Center incident.
NYC-WTC_000153954–000153958Folder label: “WORLD TRADE CENTER - PRESERVATION OF EVIDENCE”
OCR status: ok · source: pdftotext
NYC 9/11 Public Portal Document
. 7 V DEP-RECEIVEO UFFiCE GF (HE COMMiSSiOKER
ZOO) JAN lb P 2^ 23 The City of New York
MICHAEL A. CARDOZO Law Department Corporation Counsel 100 CHURCH STREET NEW YORK, N.Y. 10007-2601
January 15, 2003
Hon. Christopher O. Ward Commissioner of the Department of Environmental Protection 59-17 Junction Boulevard Corona, NY 11368
Re: World Trade Center Litigation Document Retrieval Process DearCbmimssioM^Ward: !
As . I reported at the-Agency'head meetingFwith the Mayor in December, a substantial number of wrongful death, personal injury and property damage claims have been filed, against the City as the result of the terrorist attack on the World Trade Center on September 11, 2001. I have created a unit, within the Law Department’s Tort Division, to defend the City’s interests with respect to those claims. Although we do not yet know the final parameters of the universe of claims against the City, it is vital to the Unit’s work that we not only prepare to defend against the claims we know about, but also anticipate claims that may be raised in the future.
Accordingly, the Unit is in the process of implementing a Citywide document retrieval program to obtain and review every document in the possession of any and all City agencies that may conceivably be related to the World trade Center disaster and subsequent recovery effort. This will be necessary not only for production of documents during the discovery phase of the various lawsuits we will defend, but to permit us to prepare for and anticipate any claims, whether or not they have been filed at this time. Our search for documents will encompass the broadest possible definition of relevance to the critical events. In order to ensure compliance with the City’s long-term discovery obligations in this critical litigation, it will be necessary for the Law Department to take custody' of the original files. Duplicate files will be provided for your agency. ' ' " ’
Inasmuch as your agency was significantly involved in the crucial actions of the City in response to the attack on the World Trade Center, I ask you to begin as quickly as possible to aid my staff in the document retrieval effort. To that end, I request that you designate a member of your Senior Staff to serve as principal liaison with Law Department personnel.
www.nyc.gov
NYC-WTC^ddo 153955
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NYC-WTC_000152095
Letter from Corporation Counsel informing the DEP Commissioner of wrongful death and injury claims filed against the City.
4 shared non-person entities · Same agency, volume and box · similarity 0.953
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000152648
Internal routing form for a Department of Environmental Protection document requiring action or review.
5 shared non-person entities · 1 shared topics · Same agency, volume and box · similarity 0.952
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000153409
Draft correspondence explaining the need to remove WTC debris containing potential asbestos from lower Manhattan buildings.
2 shared non-person entities · Same agency, volume and box · similarity 0.951
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000153971
City Law Department letter directs DEP to preserve electronic and written evidence regarding the September 11 attacks for legal discovery.
3 shared non-person entities · Same agency, volume and box · similarity 0.949
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000151413
Memorandum providing a timeline of DEP's initial response and coordinated street cleanup efforts at the World Trade Center site.
4 shared non-person entities · 1 shared topics · similarity 0.954
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000151492
Internal DEP memorandum routing form with checkboxes for document handling actions, outcome tracking, and coordination across city agencies.
3 shared non-person entities · similarity 0.952
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000161974
Internal DEP communication from September 21, 2001 with forwarded attachment regarding early post-9/11 agency coordination.
2 shared non-person entities · 1 shared topics · similarity 0.951
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000151742
Letter responding to correspondence regarding the EPA World Trade Center Cleanup Program, noting that extensions through December 28, 2002, were sufficient for registration.
3 shared non-person entities · 1 shared topics · similarity 0.950
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000164563
Memo forwarding the interview schedule for selecting a vendor to design and implement a Lower Manhattan information dissemination campaign.
2 shared non-person entities · 1 shared topics · similarity 0.949
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000137113
Archival folder label for September 11 news clippings from the Office of the Mayor, identified as Folder 0124.
3 shared non-person entities · similarity 0.948
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000151483
Internal DEP memorandum routing form with checkboxes for document handling actions, outcome tracking, and coordination across city agencies.
3 shared non-person entities · similarity 0.948
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000151438
Letter or document involving a U.S. Congressional committee related to environmental and public works matters, received by DEP in March 2002.
3 shared non-person entities · 1 shared topics · similarity 0.947
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NYC-WTC_000153903
Administrative cover page for the World Trade Center Preservation of Evidence collection within DEP Box 26.
Filed in the same folder
NYC-WTC_000153904
Page containing illegible text and a file identification number associated with the World Trade Center Preservation of Evidence collection.
Filed in the same folder
NYC-WTC_000153905
Document page containing a file identification number associated with World Trade Center evidence preservation protocols.
Filed in the same folder
Attorney-client communication containing a draft directive for preserving records regarding ongoing World Trade Center litigation.
Filed in the same folder
Memorandum from DEP counsel regarding the Law Department's collection of documents for 9/11 litigation and their subsequent return.
Filed in the same folder