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← Document results/DEP Box 41/Lyndenwood Flood - Howerd Bch 4-30-14
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List of claimants in amended flood claim

Machine-extracted title · confidence 95%

A legal document listing multiple individuals and families filing claims against the City for damages from the April 30, 2014 flood.

NYC-WTC_000159475–000159547

Folder label: “Lyndenwood Flood - Howerd Bch 4-30-14

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Scanned page image, NYC-WTC_000159482
OCR text

OCR status: ok · source: pdftotext

NYC 9/11 Public Portal Document

causing the existence of mold in claimant’s homes and residences; in exposing claimants to harmful pathogens, bacteria, and other hazardous and unknown substances; in failing to give any warning of the hazardous condition. Said conduct, by permitting and allowing the above-identified dangerous condition to exist, thereby creating a hazardous and dangerous condition, and falling to repair, maintain, and control, shows a complete disregard for the safety and well-being of claimants.

Respondents had at least constructive notice of said condition but permitted same to remain uncorrected. Respondents had actual notice of said condition but permitted same to remain uncorrected. Respondents had prior written notice of said condition. Respondents caused and created the condition. Respondents knew the weather report called for significant rainfall, but failed to take any action at any reasonable time prior to the flood to prevent flooding, failed to man relevant and crucial facilities; failed to implement any type of fail-safe procedure at relevant and crucial facilities, although duly had ample opportunity to do so, thus creating the defective and hazardous condition.

That the negligence of respondents consisted of failing to properly and safely maintain and control the aforementioned area; in neglecting and/or failing to properly maintain, inspect, and/or repair the infrastructure of the aforementioned sewer and/or drainage system in the aforementioned neighborhood, and thereby causing the resulting flood and creating the condition complained of; in failing to properly clear and/or clean sewers in a reasonable, and/or regular, and/or timely manner in the aforementioned neighborhood of debris; in failing to prevent a backup of water during a rainstorm; in failing to property man related facilities, including but not limited to the Spring Creek [Combined Sewer Overflow] Facility; In failing to properly maintain, control, manage, and/or repair that and/or other facilities. Including but not limited to the Spring Creek [Combined Sewer Overflow] Facility; in allowing Improperly and Incorrectly pitched catch basins to remain in a defective, inadequate, and ineffective condition; In allowing and permitting a failure to occur at a related sewer overflow facility, causing sewers to back up into claimants' homes; in failing to properly and timely upgrade and/or maintain the subject sewer system; In falling to properly clean sewer grates and/or allowing garbage and debris to accumulate in same; in negligently relying on computer action rather than human action; in causing and permitting a dangerous condition; In falling to act in

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NYC-WTC_000159482

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NYC-WTC_000159482Source: NYC Law Department, mirrored locally

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