Demand for Discovery and Inspection, 2012

NYC 9/11 Public Portal Document

j) Concerning shall mean relating to, referring to, describing, evidencing or

constituting.

k) And/Or shall mean The connectives “and” and “or” shall be construed either

disjunctively or conjunctively as necessary to bring within the scope of the

discovery requests all responses that might otherwise be construed to be outside

of its scope.

1) All/Each shall mean the terms “all” and “each” shall be construed as all and each.

m) The use of the singular form of any word includes the plural and vice versa.

REQUESTS

Department ofEnvironmental Protection

18. To the Department ofEnvironmental Protection: All Communications with the

Office of Emergency Management, Department of Parks & Recreation, FEMA, Office of the

Mayor, Department of Sanitation, Office of Councilman James Oddo, and Office of Borough

President James P. Molinaro, Concerning floodmg in titre Bullshead Community.

19. To the Department ofEnvironmental Protection: All Documents/ESI Concerning

emergency repairs to the Victory Boulevard Pumping Station from January 1,1999 through

September 15,2003.

20. To the Department ofEnvironmental Protection: All Documents/ESI Concerning

repairs to the Victory Boulevard Pumping Station from August 27,2007 through the date of

these Requests.

21. To the Department ofEnvironmental Protection: All reports, assessments or

analyses Concerning the performance, function or maintenance of the Victory Boulevard

Pumping station.

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