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First Set of Interrogatories to Defendant, 2012

Machine-extracted title · confidence 95%

Plaintiffs' First Set of Interrogatories directed to the City of New York in Supreme Court litigation.

NYC-WTC_000159150–000159159

Folder label: “Hurricane Irene - Lit Support

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NYC 9/11 Public Portal Document

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND

IRENE YANNI, SAMY ABDELMALEK, DAVID ALVO, FERN ARCIERI, MICHAEL BOULIS, ALFIA Index No. 150217/2012 COGLITORE, EILEEN COHEN, FRANK ESPOSITO, SAMER GIRGIS, CHENGXIN GONG, NABIEL GURGES, MICHELLE HAGGIAG, SUSAN JUAN, JOHN KIEVER, DAVID LEE, LESLIE LEGISTER, PLAINTIFFS* FIRST SET OF LOUIS CAMPIONE, DORIT LEVI, LYNNE LIBERT, INTERROGATORIES TO LAURA MALLEN, WILLIAM MCGINNIS, DEFENDANT (Nos. 1-15) ANTHONY MILLER and RACHEL SHREM,

Plaintiffs,

V,

CITY OF NEW YORK,

Defendant.

Pursuant to CPLR 3130, Plaintiffs direct the following interrogatories to Defendant City

of New York.

INSTRUCTIONS

1. Answer the interrogatories in writing directed to Plaintiffs’ counsel, Garbarini

FitzGerald p.c., at their offices at 420 Lexington Avenue, Suite 2743, New York, New York

10128.

2. You are required to respond to these Interrogatories within 30 days of service.

3. For the sake of efficiently completing discovery in this matter, and to avoid

unnecessary and unproductive disputes, if you find an interrogatory to be vague, overbroad, or

unduly burdensome, contact Plaintiffs’ counsel for clarification before formally responding to

this set of interrogatories.

NYC-WTC_000159150

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