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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. 11

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

Protection to prepare for flooding in the Bullshead Community prior to Hurricane Irene.

INTERROGATORY No. 12

Identify any and all complaints of flooding in the Bullshead Community received by the

CITY OF NEW YORK, including but not limited to, Office of the Mayor, Office of Borough

President Peter Molinari, Office of Councilman James Oddo, Department of Information

Technology, Department of Sanitation, Department of parks & Recreation and Department of

Environmental Protection.

INTERROGATORY No. 13

Identify any and all complaints of blocked: sewers, catch basins, receiving drains or

manholes in the Bullshead Community received by the CITY OF NEW YORK, including but

not limited to the. Office of the Mayor, Office of Borough President Peter Molinari, Office of

Councilman Janies Oddo, Department of Sanitation, Department of Information Technology,

Department of Parks & Recreation and Department of Environmental Protection.

INTERROGATORY No. 14

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

Protection to alleviate flooding in the Bullshead Community from August 27,2012 through

August 29,2012.

INTERROGATORY No. IS

Describe in detail all steps taken by the New York City Office of Emergency

Management to alleviate flooding in the Bullshead Community from August 27,2012 through

August 29,2012.

7

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

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