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← Document results/GRM 010290082 - BOX 26/Requests 2012
Document / 34 pages

Legal letter regarding premises liability case, January 2012

Machine-extracted title · confidence 90%

Correspondence from attorneys regarding a lawsuit involving a specific property address and the Department of Environmental Protection.

NYC-WTC_000159366–000159399

Folder label: “Requests 2012”

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Scanned page image, NYC-WTC_000159382
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NYC 9/11 Public Portal Document

98. Kristin observed that Defendants Ignizio, Mustaciuolo, Tobacco, McArdle, several police oticers and several employees of Defendant Russo were unlawfully trespassing on the Property.

99. Kristin attempted to deliver the Order to Show Cause and the Stop-Work Order to a chief of the FDNY, who refused to accept them.

100. Kristin attempted to deliver the Order to Show Cause and the Stop-Work Order to Defendant McArdle, who refused to accept them.

101. Kristin attempted to deliver the Order to Show Cause and the Stop-Work Order to employees of Defendant Russo, who refused to accept them. 102. Kristin attempted to deliver the Order to Show Cause and the Stop-Work Order to Police Officers Jeffrey Walter and Tracy Lavelle, who refused to accept them. 103. Kristin attempted to deliver the Order to Show Cause and the Stop-Work Order to Defendant Ruvolo, who refused to accept them.

104. Kristin attempted to deliver the Order to Show Cause and the Stop-Work Order to several other employees and agents of the City and its agencies, who refused to accept them.

105. Finally, Defendant Ignizio examined the Order to Show Cause and the Stop-Work Order, and disregarded them.

106. In addition, upon information and belief, Defendant McArdle determined that the Order to Show Cause and the Stop-Work Order were not applicable to HPD. 107. The City, the City Agencies and Russo, and all their employees and agents, all disregarded the Order to Show Cause and the Stop-Work Order brought to the Property by Kristin on the morning of December 6, 2007.

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NYC-WTC 000159382

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NYC-WTC_000159382Source: NYC Law Department, mirrored locally

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