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World Trade Center subpoena receipt and response, Nov 2013

Machine-extracted title · confidence 85%

Notification to NYC DEP legal staff of receipt of a World Trade Center-related subpoena and coordination with outside counsel to prepare a response.

NYC-WTC_000159197–000159203

Folder label: “MISC

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Scanned page image, NYC-WTC_000159202
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NYC 9/11 Public Portal Document

RIDER TO BE PRODUCED BY NON-PARTY DEPAR' ALPRO’rECTION

For the building located at 70 Greenwich Street, New York, NY (hereinafter referred to as tile Building”), at which your company performed services includiog nbatement and/or cleanup and/or removal of asbestos, particulate matter, chemical waste, or any other toxic waste material (hereinafter referred to as “work”) following the September 11,2001 aitacks on toe World Trade Center, please produce the following;

t Any and all contracts and other writing retaining your company to perform the aforementioned work at the Building; 2. Any and all correspondence regarding your work in tiie Building;

3. Any and all documents evidencing your firm's reter.tioji to perform work in the Building;

4. Any and ail documents evidencing the damage sustained |o the Building as a result ofthe September 11,2001 attacks, including the contamination of the Building;

5. Any and all daily or otherwise work records documenting your penbrmance on the Building;

6. Any and all documents signifying when work was performed on adaily, or otherwise, basis and on which floors of the Building the work was performed;

7. Any and all documents including the name of all individuals employed or otherwise performing work at the Building;

8. Any and all documents evidencing the work perform id nt the Building including testing for toxic or dangerous materials or substances, ncJ tiding the location within the Building and any contracts, applications, and permits ibr the work;

9. Any and all documents evidencing the air quality or other testing done prior to, during, and after the work was performed at tide Building;

10. Any and all documents reflecting communications with the Building owners, agents or representatives regarding the work to be performed;

n. Any and all policies and procedures, including any manuals, regarding the work performed, including any safetyplansand/orproccdures in effect as ofSeptember 11, 2001;

NYC-WTC_000159202

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NYC-WTC_000159202Source: NYC Law Department, mirrored locally

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