10 shared non-person entities · 1 shared topics · Same agency, volume and box · similarity 0.941
machine-extracted · confidence unavailable · Check page ↗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_000159366–000159399Folder label: “Requests 2012”
Page image
OCR text
OCR status: ok · source: pdftotext
NYC 9/11 Public Portal Document
98. Kristin observed that Defendants Ignizio, Mustaciuolo, Tobacco, McArdle, several police
officers 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.
17
NYC-WTC_000159382
OCR can misread numbers and units. Confirm readings against the page image before using them.
NYC-WTC_000159382Source: NYC Law Department, mirrored locally
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