First Set of Interrogatories to Defendant, 2012

NYC 9/11 Public Portal Document

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

by the responding party into a reasonably usable form.

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

constituting.

1) 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.

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

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

INTERROGATORY No. 1

State the name, title, agency and general duties of each and every individual responsible

for risk assessment and flood plaiming for the Bullshead Community.

INTERROGATORY No. 2

State the name, title, agency and general duties of each and every individual responsible

for oversight, functioning or maintenance of the Victory Boulevard Pumping Station prior to

Hurricane Irene.

INTERROGATORY No. 3

State the name, title, agency and general duties of each and every individual responsible

for the Drainage System in the Bullshead Community prior to Hurricane Irene.

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NYC-WTC_000159154