10 shared non-person entities · 1 shared topics · 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”
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OCR text
OCR status: ok · source: pdftotext
NYC 9/11 Public Portal Document
Fourteenth Amendments to the Constitution of the United States that they form part of the
same case or controversy under Article III of the Constitution of the United States.
34. Venue in this Court is proper pursuant to 28 U.S.C. Section 1391(b), since a substantial
portion of the events or omissions giving rise to DePietro's causes of action occurred
within this judicial district, (b) the subject property is located in this judicial district, and
(c) all Defendants do business in the City and State of New York.
35. On March 4, 2008, DePietro served upon the City a Notice of Claim which was served
upon the City within ninety (90) days after the causes of action herein alleged accrued.
36. At least thirty (30) days have elapsed since the Notice of Claim upon which this action is
predicated was presented to the City for adjustment, and the City has neglected and/or
refused to make adjustment or payment therefor.
37. The City has not demanded an examination of DePietro's claim, as provided under New
York General Municipal Law Section 50-h.
38. This case has been commenced against the City within the period of one (1) year and
ninety (90) days after the cause of action herein alleged accrued.
39. This case has been commenced within the period of three (3) years after the causes of
action herein alleged accrued, and is within the statute of limitations for civil rights
actions under 42 U.S.C. Section 1983.
BRIEF SUMMARY
40. This action is brought for alleged civil rights and constitutional due process and equal
protection violations, damages caused by the wrongful demolition of Plaintiffs buildings
from December 6, 2007 to December 10, 2007, and certain other related intentional and
7
NYC-WTC 000159372
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NYC-WTC_000159372Source: NYC Law Department, mirrored locally
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