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Document / 10 pages

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

INTERROGATORY No. 4

Describe in detail all steps taken by the New York Department of Environmental

Protection to evaluate the risk of flooding in the Bullshead Community prior to Hurricane Irene.

INTERROGATORY No. 5

Describe in detail all steps taken by the New York City Department of Parks &

Recreation to evaluate the risk of flooding in Willowbrook Park prior to Hurricane Irene.

INTERROGATORY No. 6

Describe in detail the methodology used for assessing the Bullshead Community as “low

to no risk” of flooding as described in the Complaint.

INTERROGATORY No. 7

Describe in detail how complaints to the Office of Councilman Oddo are processed,

addressed, and stored.

ImiSRROGATORYNo^

Identify in detail all steps taken by the CITY OF NEW YORK to ensure the Victory

Boulevard Pumping Station was functioning prior to Hurricane Irene.

INTERROGATORY No. 9

Identify the dates and times the Department of Environmental Protection inspected the

sewers, storm drains, and catch basins on Saybrook Street, Goller Place, Croft Place, and Eton

Place from June 27,2011 through and including August 27,2011.

INTERROGATORY No. 10

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

formulating any flood mitigation plan for the Bullshead Community from June 27,2011 through

and including August 27, 2011.

6

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NYC-WTC_000137113

Archival folder label for September 11 news clippings from the Office of the Mayor, identified as Folder 0124.

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