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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

13. Any request that seeks information “prior to Hurricane Irene” should be read as a

reasonable time prior to August 27,2011 sufficient to respond.

Definitions a) You or Your shall mean the CITY OF NEW YORK unless a specific department

or agency is identified in the specific request.

b) Complaint shall mean the operative Complaint in this matter.

c) BuUshead Community shall mean the neighborhood in Staten Island

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

Place.

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

Staten Island, New York.

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

August 27 - August 28,2011.

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

Boulevard Pump Station.

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

Pond.

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

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

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

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

j) 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 4

NYC-WTC_000159153

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NYC-WTC_000159153Source: NYC Law Department, mirrored locally

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