Document fragment with identification number

NYC 9/11 Public Portal Document

New York, State of New York, zip code 11414, due to the negligence of the respondents herein.

3. The time when, the place where, and the manner In which the claim arose:

The incident initially occurred on April 30,2014, in the neighborhood known as Howard Beach, County of Queens, City of New York, zip code 11414, after significant rainfall that day, when, following said heavy rain during the day, at or around between 6:00 and 10:00 p.m. (in some cases as early as 4:00 p.m., but in most cases approximately 7:00 p.m.), water started to rise inside the homes of claimants, continuing throughout the night, and did not start to recede until at or around between 12:00 and 6:00 a.m. in the morning of May 1 (in most cases, approximately between 2:00 and 4:00 a.m.). Depending on the area of the specific room and/or the specific home, water levels rose to levels between a few inches to six feet.

Said flood was caused by a defect and/or failure in the drainage and/or sewer system and/or sanitary and storm combined sewer system located at and/or throughout said neighborhood, or, the drainage and or sewer system and/or facility that is responsible for maintaining water, sewage, and drainage in the subject neighborhood. Respondents engaged in an act that caused the incident, or the respondents failed to engage in an act, and such failure caused the incident. Respondents failed to properly man a facility; respondents failed to properly clean and/or maintain the subject sewers and/or drainage system in the neighborhood; respondents failed to properly control relevant valves, and/or gates, and/or dams, and/or other properties or materials pertaining to a sewage and/or drainage system; and were otherwise negligent.

Because of the negligence of respondents, claimants were caused to endure large amounts of water within their homes and/or garages, ranging from several inches to several feet, destroying and damaging massive amounts of property, and causing massive amounts of damage to the homes themselves, requiring repair, demolition, replacement, cleaning and mold removal, among other things. Further, the property values of respondents’ homes are believed to have decreased dramatically due to this flood resulting from the negligence of the respondents.

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NYC-WTC_000159551