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White Tab 101 — COVID Storage Relocation Emails — Tier-1 PDF

GUARDRAIL: WHITE — FACT REPOSITORY ONLY

Facts & source pinpoints only. No strategy, no argument, no legal opinions. All quotations are "as reported" unless exact text appears in a cited source.

A. Provenance & Bates

  • Tier-1 Source (PDF): Email_Harassment__re_storage_relocation_during_covid-19_lockdown.pdf — 4 pages, dated May 13–14, 2020. Bates: G21-HOUS-005–008.
  • Binder index entry: WT-101 listed under Tier-1 Evidence with the same Bates and page count.
  • PDF validation memo: Confirms 4 pages (content pages = 3; metadata page present in file).

Scope: Email correspondence between American Package Co. (sender address: ampaco@gmail.com) and Christian Gray during NYC COVID-19 restrictions regarding clearing three storage rooms.

B. Parties & Addresses (as shown in thread)

  • Sender/Signers shown: Violet Lautan (American Package Co.); Martin C. Kofman (American Package Company Inc.).
  • Recipient: Christian Gray (christiangray3@yahoo.com).
  • Company contact block (as printed in email footers): "American Package Company Inc., 226 Franklin Street, Brooklyn, NY 11222, TEL (718) 389-4444."

C. Exhibit Index (for Grey C001 Pattern Linkage)

This section indexes exhibits derived from WT-101 for use in Grey C001 — COVID-19 Endangerment Evidence — Pattern Linkage. WT-101 remains the canonical source; Grey C001 embeds specific pages for counsel convenience.

Exh A — Demand Language Page (WT-101 pin)

Source page: WT-101 PDF page showing the line:

"PLEASE EMPTY the 3 storage spaces … by Monday. We need the space and if you do not empty them, we will."

  • Bates: G21-HOUS-00X (to be inserted after pinpoint task completion)
  • Pin task: C001-PIN-A — Insert exact Bates page and timestamp
  • Status: Pending WT-003 task completion
  • Used in: GREY-C001 (Exh A)

Exh B — Tenant 6-ft Distancing Objection Page (WT-101 pin)

Source page: WT-101 PDF page showing the line:

"How can you have people move things when we are supposed to be staying 6 feet away from each other?"

  • Bates: G21-HOUS-00Y (to be inserted after pinpoint task completion)
  • Pin task: C001-PIN-B — Insert exact Bates page and timestamp
  • Status: Pending WT-003 task completion
  • Used in: GREY-C001 (Exh B)

Exh C — Executive Order Anchors (context authorities)

These exhibits provide contemporaneous State directives that frame the incident. They are not part of the WT-101 PDF but are cited alongside it in Grey C001 for pattern analysis.

C-1 — EO 202.8: 100% In-Person Workforce Reduction

Source: Executive Order 202.8 (March 20, 2020), modifying EO 202.6

Text to capture (screenshot):

"The provisions of Executive Order 202.6 are hereby modified to read … Effective on March 22 at 8 p.m.: … Each employer shall reduce the in-person workforce at any work locations by 100%."

Official PDFs:

Pin task: C001-PIN-C1 — Insert PDF page number and paragraph citation Effective window: March 22, 2020 at 8 p.m. (extended by subsequent orders) Used in: GREY-C001 (Exh C-1)

C-2 — EO 202.8: Eviction-Enforcement Pause

Source: Executive Order 202.8 (March 20, 2020)

Text to capture (screenshot):

"There shall be no enforcement of either an eviction of any tenant residential or commercial, or a foreclosure of any residential or commercial property for a period of ninety days."

Official PDFs:

Pin task: C001-PIN-C2 — Insert PDF page number for the eviction-enforcement sentence Used in: GREY-C001 (Exh C-2)

C-3 (optional) — ESD Guidance on EO 202.6

Source: Empire State Development — "Guidance on Executive Order 202.6"

Context: Shows "Residential and commercial moving services" listed as essential, with social-distancing protocols required.

State guidance link: https://esd.ny.gov/guidance-executive-order-2026

Pin task: C001-PIN-C3 — Insert URL and capture date Used in: GREY-C001 (Exh C-3, optional context)

Discovery Routing — WT-003 Tasks

All exhibit pinpoint tasks and native file collection are managed through:

WT-003 ▸ Entry — WT-101 Discovery Packet — COVID Storage Email Documentation Collection (v1.1)

Open tasks:

  • C001-PIN-A: Exact Bates page for demand language
  • C001-PIN-B: Exact Bates page for 6-ft objection
  • C001-PIN-C1: EO 202.8 PDF page + paragraph cite (100% workforce)
  • C001-PIN-C2: EO 202.8 PDF page cite (eviction pause)
  • C001-PIN-C3: ESD URL + capture date (optional context)
  • WT-101-COL-NATIVE: Native .eml file collection
  • WT-101-COL-META: Email header metadata extraction
  • WT-101-COL-REF: Referenced "expert reports"/"approved plans" identification
  • WT-101-COL-VOICE: Voicemail referenced in May 13, 2020 message

D. Thread Chronology (verbatim excerpts)

May 13, 2020 (1:03 PM) — American Package Co. to Christian Gray:

"I left a message on your voicemail to please call me back on my cell. Thank you."

May 14, 2020 (3:32 PM) — American Package Co. to Christian Gray:

"PLEASE EMPTY the 3 storage spaces in the factory by monday. We need the space and if you do not empty them, we will."

May 14, 2020 (3:37 PM) — American Package Co. to Christian Gray (follow-up):

"Please empty all the storage spaces by Monday 5/18/2020" (signature block lists 226 Franklin St., Brooklyn, NY 11222).

May 14, 2020 — Christian Gray reply to American Package:

"Where would your people move my things? How can you have people move things when we are supposed to be staying 6 feet away from each other? …"

May 14, 2020 (4:07:58 PM) — American Package (signed Martin C. Kofman):

"We need at least two of the storage rooms … There are no more explanations of the expert reports … When we can the remediation team is going to follow this report and remove the mold. The space will then be retested … we need to move forward according to the approved plans."

Christian Gray initial message in thread (header block):

"Marty told me that I can use the spaces until the renovations were complete … It is unreasonable to ask me to move my stuff out of storage … How do you recommend that I move three storage rooms of stuff out by myself during a pandemic when people are sheltering in place?"

E. Cross-References (White 07)

  • Binder control: WT-101 cataloged as Tier-1 Evidence; dates/Bates align.
  • Grey C001 — COVID-19 Endangerment Evidence — Pattern Linkage: Embeds WT-101 pages as Exh A/B; cites contemporaneous EO 202.8 as Exh C-1/C-2.
  • WT-003 ▸ WT-101 Discovery Packet: Manages native file collection and pinpoint tasks.
  • WT-105 (Alternative Housing Offer — Unit F1) context page cites WT-101 as May 13–14, 2020 storage emails (Bates listed).

F. Attachments

END — White Tab 101 — COVID Storage Relocation Emails v1.3