Demand for Discovery and Inspection, 2012

NYC 9/11 Public Portal Document

Specific Definitions as used herein: a) You or Your shall mean the New York City unless a specific department or

agency is identified in the request

b) Bullshead Community shall mean the neighborhood in Staten Island

encompassing and including Saybrook Street, Goller Place, Croft Place, and Eton

Place.

c) Willowbrook Pond shall mean the pond adjacent to the Bullshead Community in

Staten Island, New York.

d) Hurricane Irene shall mean the storm and related events that took place from

August 27 - August 28,2011.

e) Pumping Station shall mean the water pumping station located at 2952 Victory

Boulevard Pump Station.

f) Culvert shall mean the drainage canal which is associated with Willowbrook

Pond.

g) Drainage System shall mean the catch basins, receiving drains, screening

chambers, storm drains, sewers, grate, and gutters in the Bullshead Conununity.

General Definitions as used herein:

h) Communication shall mean the transmittal of information including e-mail (in

the form of facts, ideas, inquiries or otherwise).

i) Documents/ESI shall mean any information stored in any electronic form.

including e-mail, as well as any writings, drawings, graphs, charts, photographs.

sound recordings, images, and other data or data compilations medium form from

which information can be obtained either directly, or if necessary, after translation

by the responding party into a reasonably usable form. 2

NYC-WTC_000159142