Amended claim list document, undated

NYC 9/11 Public Portal Document

ATTORNEY Nora Constance Marino, Esq. 175 East Shore Road Great Neck, NY 11023 ph.: 516-829-8399 fax: 516-829-4699 [email protected]

2. The nature of the claim:

Claim for personal injuries, property damage, loss of property, cost of cleaning; cost of repairs, lost wages, loss of property values, and a compromised ability to obtain insurance, which may result in future damages, inter alia, arising out of an incident involving the of flooding of claimants' homes, premises, and property, both real and personal, which occurred on April 30,2014, in the neighborhood known as Lindenwood, Howard Beach, County of Queens, City of 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. jin 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

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NYC-WTC_000159564