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WTC Building 7 transformer oil spill litigation discussion 2003

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Confidential litigation discussion regarding transformer oil spill cleanup at WTC Building 7 in May 2003.

NYC-WTC_000165888–000165889
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NYC 9/11 Public Portal Document

Varoli, David From: Adams, Robert Sent: May 02, 2003 9:06 AM To: Varoli, David Subject: RE; WTC - Litigation - 7 WTC - Follow-up

Sensitivity: Confidential

David: I do have some records concerning CON-ED and transformer oil spillage - State DEC made CON-ED do a fair amount of clean-up of oil that spilled around #7 -1 may even have a copy of the work plans. As to Ammo near building 7,1 do not believe they ever found any in that area. It was largely confined to the vicinity of building 6.

Bob

■Original Message- From: Varoli, David Sent: May 01, 2003 9:06 AM To: Papageorge, Anne; Rueda, Louie; Mendes, Luis; Eschenasy, Dan; Adams, Robert; Hooker, Don Cc: Jay Cohen (E-mail); Jesse Levine (E-mail) Subject: wre - Utigation - 7 WTC - Follow-up Sensitivity: Confidential

CONFIDENTIAL AND PRML.KGED

PREPARED FOR LITIGATION PURPOSES ONLY

Anne, Louie, Luis and Dan, thank you again for taking the time yesterday to meet with the Law Department and the City's outside counsel. They expressed to me again their appreciation of your time and efforts.

As you know, they are in the early stages of preparing the City's defenses to the two claims filed against the City on behalf of Silverstein (IRI insurance company) and Con Ed (Aegis insurance company) alleging that the City is somehow at fault for Building No. 7. As our team of lawyers get more involved in these matters, they may be calling on each of you again to provide additional support, I am here to assist you if and when they call.

During yesterday's meetings (the first meeting was with Anne, Louie, and Luis; and the second meeting was with Dan) they had asked for a number of documents. Please have your assistants make copies of these documents and forward them to my attention. If possible, I would like to get them all copies by the end of next week.

The following was requested:

1) Any notes that you may have on the construction of the new building (I believe Luis stated that he may some notes based on the meetings he attended. Please, also check with the Special Projects staff who may have went to these meetings);

2) Any documents sent to DDC by Swanke or OEM concerning the old OEM (I believe Luis stated that they had sent some of these documents to him or to DDC);

3) Any documents that reference or mention tanks in the old or new buildings;

4) Any information or analysis that DDC provided to OMB or FEMA on the costs of the new building;

5) All planning documents or preliminary schematics of the new building or its space;

6) Any field notes or documents about the debris removal project of Bldg. #7 only - DDC's staff personnel field logs, notes or diary entries;

7) Any pictures of Bldg. #7 from 9/11/01 until the present (I believe Dan said he had some);

8) Any documents that the engineers generated concerning Bldg. # 7 (Dan); 1

NYC-WTC_000165888

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NYC-WTC_000165888Source: NYC Law Department, mirrored locally

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