OCR status: ok · source: pdftotext
NYC 9/11 Public Portal Document
99. Deny the allegations set forth in paragraphs “186,” “187,” “188,” “189,”
and “190” of the complaint.
AS AND FOR A FIRST DEFENSE;
100. The complaint fails to state a claim upon which relief can be granted.
AS AND FOR A SECOND DEFENSE:
101. Some or all of plaintiffs claims and causes of actions are baned by the
applicable statute of limitations.
AS AND FOR A THIRD DEFENSE:
102. City defendants have not violated any rights, privileges or immunities
reserved to the plaintiff by the constitutions or laws of the United States or the State of New
York, nor have they violated any act of Congress providing for the protection of civil rights.
103. The demolition of the subject property pursuant to a Department of
Building’s Declaration of Immediate Emergency Police Department’s did not violate the Due
Process or Equal Protection clauses of the United States or New York State Constitution, nor
constitutes an unlawful seizure under the Fourth Amendment.
AS AND FOR A FOURTH DEFENSE;
104. Any injury alleged to have been sustained resulted from the plaintiffs
own culpable or negligent conduct or the culpable or negligent conduct of parties other than the
City defendants.
AS AND FOR A FIFTH DEFENSE;
105. At all times relevant herein, the individually-named City defendants.
(defendants Ignizio, Mustaciuolo, Gluckman, Deluca, Ruvolo, Coyle, Girimonte, McArdle, and
Falcone) acted within the scope of their employment and in a good faith belief that their actions
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1 NYC-WTC_000159412
OCR can misread numbers and units. Confirm readings against the page image before using them.
Ranked by indexed similarity. Reasons describe shared subjects and filing context; check the source records.
NYC-WTC_000159366
Correspondence from attorneys regarding a lawsuit involving a specific property address and the Department of Environmental Protection.
10 shared non-person entities · 1 shared topics · Same agency, volume and box · similarity 0.941
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000159150
Plaintiffs' First Set of Interrogatories directed to the City of New York in Supreme Court litigation.
2 shared non-person entities · Same agency, volume and box · similarity 0.929
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000159559
Document listing multiple amended claims involving various individuals and families associated with the site.
2 shared non-person entities · Same agency, volume and box · similarity 0.926
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000159549
A single-page document containing only a handwritten identifier and an archive reference number.
2 shared non-person entities · 1 shared topics · Same agency, volume and box · similarity 0.925
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000159462
Legal document listing multiple amended claims involving various individuals and families associated with the April 30, 2014 flood.
2 shared non-person entities · Same agency, volume and box · similarity 0.924
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000159349
Legal notice filed in Bronx Court regarding a premises liability case at 141-143 E 149th Street dated January 17, 2012.
Same agency, volume and box · similarity 0.913
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000159197
Notification to NYC DEP legal staff of receipt of a World Trade Center-related subpoena and coordination with outside counsel to prepare a response.
1 shared non-person entities · 1 shared topics · Same agency, volume and box · similarity 0.911
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000137749
Archival folder label for Department of Environmental Protection invoices related to World Trade Center activities from 1999 to 2001.
5 shared non-person entities · similarity 0.922
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000137113
Archival folder label for September 11 news clippings from the Office of the Mayor, identified as Folder 0124.
2 shared non-person entities · similarity 0.913
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000169388
A 30-page license agreement dated March 25, 1998, for the Mayor's Office of Emergency Management to occupy the 23rd floor at 7 World Trade Center.
2 shared non-person entities · similarity 0.913
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000136990
Archival folder label for September 11 news clippings from the Office of the Mayor, identified as Folder 0123.
3 shared non-person entities · similarity 0.912
machine-extracted · confidence unavailable · Check page ↗NYC-WTC_000144568
Draft document outlining enforcement requirements and responsibilities for the World Trade Center debris removal and environmental cleanup.
2 shared non-person entities · 1 shared topics · similarity 0.911
machine-extracted · confidence unavailable · Check page ↗Similar subjects in other documents. Similarity does not establish the same event, measurement or conclusion.
Page similarity is temporarily unavailable or this page has no indexed vector.
Machine-extracted building matches; verify each source. Buildings, never households.
Readers open these alongside this record — through an Ask answer, the same folder, or indexed similarity. Not a claim they are about the same event.
Record of a request filed in 2012 regarding World Trade Center environmental matters.
Filed in the same folder
NYC-WTC_000159308
Civil Court information subpoena dated February 8, 2011, served on DEP regarding a small claims action involving Corner Furniture.
Filed in the same folder
NYC-WTC_000159316
Letter regarding subcontractor services for a water tunnel project dated February 27, 2012.
Filed in the same folder
NYC-WTC_000159347
Letter from the Comptroller's office notifying DEP of a filed settlement in a legal matter dated September 11, 2012.
Filed in the same folder
NYC-WTC_000159349
Legal notice filed in Bronx Court regarding a premises liability case at 141-143 E 149th Street dated January 17, 2012.
Filed in the same folder