First Set of Interrogatories to Defendant, 2012

NYC 9/11 Public Portal Document

4. Each Interrogatory is directed to the City of New York, unless a specific

individual or agency is identified in the request

5. In answering these Interrogatories, You are requested to furnish not only such

information as is available to You but also such information as is known to any of Your agents,

representatives, employees, servants, consultants, contractors, subcontractors, investigators.

attorneys, and any other person or entity acting or purporting to act on behalf of You.

6. In any matter responsive to any of the Interrogatories You shall set forth

completely the grounds for the asserted privilege, along with copies of the Privacy Act

provisions or other written materials upon which such assertion is made. You shall Identify as to

each privileged communication or document:

a. its date;

b. its author(s);

c. the business title or position of its author(s);

d. its recipients);

e. the business title or position of its recipient(s);

f. its number of pages;

g. its stated subject matter;

h. the legal basis upon which You claim privilege;

i. the specific portion of the Interrogatory or document to which the communication

or document is responsive.

7. In each of Your answers to these Interrogatories, You are requested to provide not

only such information as is in Your possession, but also information as is reasonably available.

In the event You are able to provide only part of the information called for by any particular

2

NYC-WTC_000159151