City Law Department letter directs DEP to preserve electronic and written evidence regarding the September 11 attacks for legal discovery.
NYC-WTC_000153971–000153973Folder label: “WORLD TRADE CENTER - PRESERVATION OF EVIDENCE”
OCR status: ok · source: pdftotext
NYC 9/11 Public Portal Document
THE City of WewYork MICHAEL A. CARDOZO Law Department Corporalion Counsel iOO CHURCH STREET NEW YORK, N.Y. 10007-2601
June 25, 2003
Hon. Christopher O. Ward Commissioner of the Department of Environmental Protection 59-17 Junction Boulevard Corona, NY 11368
Dear Commissioner/Ward: U' C As previously reported, the City of New York is defending more than two thousand claims arising from the September 11, 2001 terrorist attacks on the World Trade Center. The amount currently claimed is more than $12 billion, with the possibility of future claims in even greater amounts.
To meet our discovery obligations in this litigation, my staff and I have instructed City agencies to preserve documents concerning the attacks on the World Trade Center and their aftermath, including documents in electronic form. We have recently learned, however, that some agencies may not be taking all necessary steps to preserve electronic evidence. Please be advised that the City may be subject to the most extreme legal penalties if the strongest possible steps are not taken to preserve ail electronic evidence that may bear in any way on the World Trade Center litigation. It is vital that we make every effort to insure that the City meets its legal obligations and does not become subject to sanctions. Accordingly, senior members of the WTC Litigation Unit will contact your agency to meet with your Chief Information Officer to discuss the steps that must be taken to preserve and copy electronic data. It is essential that your agency cooperate fully with them.
All agency personnel should be directed to preserve all electronic evidence (as well as hardcopy documents) that may concern the World Trade Center litigation. Please transmit, in substantially the form attached, a directive to all your employees that electronic data and other documents that may concern the terrorist attacks and their aftermath must be preserved.
To enable us to document the measures taken by the City to meet its discovery obligations, please supply to the WTC Unit a copy of the directive you transmit to your
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NYC-WTC_000153971
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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.
3 shared non-person entities · Same agency, volume and box · similarity 0.956
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000153954
A memo dated January 22, 2003, regarding the preservation of evidence related to the World Trade Center incident.
3 shared non-person entities · Same agency, volume and box · similarity 0.949
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000152687
Directive from DEP Bureau instructing staff to forward World Trade Center-related FOIL requests to designated personnel for processing and coordination with NYC Law Department.
3 shared non-person entities · 1 shared topics · Same agency, volume and box · similarity 0.946
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000152680
Directive from DEP Bureau instructing staff to forward World Trade Center-related FOIL requests to designated personnel for processing and coordination with NYC Law Department.
3 shared non-person entities · 1 shared topics · Same agency, volume and box · similarity 0.945
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000152648
Internal routing form for a Department of Environmental Protection document requiring action or review.
3 shared non-person entities · Same agency, volume and box · similarity 0.937
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000153928
Memorandum distributing a questionnaire from the Law Department to DEP senior staff regarding World Trade Center evidence and litigation defense.
1 shared non-person entities · 1 shared topics · Same agency, volume and box · similarity 0.936
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000153922
Administrative log tracking a meeting and action item regarding World Trade Center evidence preservation.
3 shared non-person entities · Same agency, volume and box · similarity 0.935
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000152082
DEP memo alerting staff that NIST is investigating the World Trade Center collapse and may request documents or interviews.
2 shared non-person entities · 1 shared topics · Same agency, volume and box · similarity 0.935
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.
2 shared non-person entities · similarity 0.939
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000164649
DEP memorandum alerting staff that NIST is investigating the World Trade Center collapse and coordinating responses through the Law Department.
1 shared non-person entities · 1 shared topics · similarity 0.936
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000162121
Internal memo requesting editorial review and Commissioner signature for a declaration document before hand delivery.
1 shared non-person entities · 1 shared topics · similarity 0.935
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000164621
DEP memorandum forwarding Law Department questionnaire regarding WTC activities and requesting staff responses for interview scheduling and document location identification.
1 shared non-person entities · 1 shared topics · similarity 0.934
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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.
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NYC-WTC_000153905
Document page containing a file identification number associated with World Trade Center evidence preservation protocols.
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Attorney-client communication containing a draft directive for preserving records regarding ongoing World Trade Center litigation.
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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