Skip to content

White Tab 106 – G21 Scope: Court-Ordered vs. Executed – Evidence Resource (Facts Only)

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) Scope and Unit Context (Facts Only)

Unit: G21 (97 Green Street side, same building footprint as 226 Franklin).

Purpose of this tab: Collate source-tied facts comparing the court-ordered remediation scope (Stipulation Exhibit 1) to (i) reported on-site instructions during the July 2021 work window and (ii) ALC's Post-Remediation Verification (PRV) submission on July 28, 2021. Also logs later post-PRV re-wet documentation (July 2023) and related collection needs.

White note: No legal conclusions are drawn here. This page is a reference index for counsel and experts.

B) Primary Source Document – Court-Filed Stipulation of Settlement

DOCUMENT EMBEDDED BELOW (Notion Archive)

Embed Location: The original 12-page PDF of the HP 6086/2020 Stipulation of Settlement should be embedded here in Notion.

File: Stipulation_of_Settlement_Original__Uneditable.pdfPages: 12 total (pp. 1-6 = Stipulation terms; p. 7 = Exhibit 1 cover; pp. 8-12 = Scope of Work + Floor Plan)

To embed in Notion: Click the area below, type /embed or /pdf, and upload or link the PDF file.

[EMBED: HP 6086/2020 STIPULATION OF SETTLEMENT - 12 PAGES]

Stipulation of Settlement_Original_ Uneditable.pdf

B.1) Stipulation Header Facts (pp. 1-6)

Court: Civil Court of the City of New York, County of Kings: Housing Part B

Index Number: HP 6086/2020

Caption: Christian Gray (Tenant-Petitioner) v. American Package Company, Inc. (Owner-Respondent) and The Department of Housing Preservation and Development (Respondent)

Document Type: Stipulation of Settlement (SO-ORDERED)

Judge Initials: J.H.C.

Petitioner's Counsel: Goodfarb and Sandercock, LLP (Margaret Sandercock, Esq.) – 110 E 59th Street, 22nd Floor, New York, NY 10022

Respondent's Counsel: Belkin Burden Goldman, LLP (David M. Skaller, Esq.) – 270 Madison Avenue, New York, NY 10016

Key Stipulation Terms (verbatim excerpts):

  • Para. 1: "Respondent has retained a licensed and insured mold remediation named Serve Pro (emergency contact is Lisa Mulcahy whose email address is lmulcahy@servprohoboken.com and cell phone #551-226-1997) company ('Mold Remediation Company') to perform the scope of work annexed hereto as Exhibit 1 ('Remediation Work') in apartment G21 ('Apartment') in the building located and known as 97 Green Street, Brooklyn, New York 11222 ('Building')."
  • Para. 1 (continued): "The Remediation Work shall commence on July 20, 2021 with regard to the preparation work with the remediation work to commence on July 21, 2021 ('Renovation Work Commencement Date')."
  • Para. 3: "Respondent's mold inspection company, ALC Environmental ('ALC') and Petitioner's mold inspection company, Olmstead Environmental Services ('Olmstead') shall be permitted to be present during the Remediation Work."
  • Para. 4: "Upon completion of the Remediation Work ('Completion Date'), ALC shall inspect and test the Apartment to ensure that the Remediation Work has been completed and prepare a written report ('ALC Post Remediation Report')."

Signatures: David M. Skaller (Respondent's counsel); Margaret Sandercock (Petitioner's counsel); Christian Gray (Petitioner)

B.2) Exhibit 1 – Scope of Work (pp. 8-11) – VERBATIM TRANSCRIPTION

Title: Mold Abatement Scope of Work – 97 Green St. Apartment #G21 Brooklyn, NY

Reference: "See attached diagram in this document." (Floor plan on p. 12)

SCOPE OF WORK

Mold abatement at 97 Green St. Apartment #G21 Brooklyn, NY – See attached diagram in this document.

  1. Gut demolish rooms 1, 2 and 3 as indicated. This includes walls and flooring to the concrete slab and remove ceilings. Remove ceiling tiles and discard any insulation above the ceiling where present. Clean any visible staining or visible mold growth on the wood deck above the ceiling. Wood framing should be cleaned.
  2. Commented [JG1]: Except as noted in 6, below.
  3. Remove the bathroom raised floor under the tub and how water heater. This will require removal of the hot water heater and tub. Clean and save the tub and HW heater.
  4. Remove the bathroom sheetrock wall shared with the kitchen. Inspect the wall cavity and the back of the cabinets.
  5. Move and save the washer and dryer outside the bathroom. Remove the sheetrock wall behind the washer and dryer.
  6. Commented [JG2]: I would require only 2 feet to expose and examine.
  7. In rooms 1 and 2 remove the sheetrock to the wall cavity and do not damage the neighbors side of the wall.
  8. In room 2 remove the lower 4 feet of the wall shared with the common hallway.
  9. In the hallway between rooms 3 and rooms 1 and 2 remove the ceiling. Clean the loft above the ceiling and remove insulation and clean visible staining or visible mold growth on the wood deck
  10. Cut four 2 by 2 ft. probes along the length of the wall into the living room wall shared with the neighbor into the wall cavity. Inspect for mold growth.
  11. In the living room cut probes into the ceiling to the wood deck and inspect for mold.
  12. At completion of the work service and clean the air handling unit.

GENERAL CONDITIONS

  1. The contractor will be licensed by the New York State Department of Labor as a mold abatement contractor.
  2. All workers will be certified mold abatement workers by the New York State Department of Labor.
  3. The contractor shall inform employees of the potential health risk for Contractor's supervisors and workers during microbial remediation is exposure to or contact with massive concentrations of fungi. Risks include allergic respiratory disease (for example, asthma and hypersensitivity pneumonitis).
  4. Commented [JG3]: Since the entire apartment will be cleaned at the end…one containment (limited) will be needed. No need to protct a surface that will be removed or cleaned.

WORK AREA PROCEDURES

  1. Remove all movable objects from each work area prior to beginning the work. Move and protect the washer and dryer, tub and HW heater.
  2. The contractor shall construct containment barriers around each work area work area and over each door inside the work area. Plastic sheeting should be used to isolate and enclose the demolition areas. 6-mil flame retardant polyethylene sheeting should be secured to existing structures using duct or other suitable specialty tape), spray adhesives, staples or any other combination thereof to ensure the integrity of the barrier for the duration of the work.
  3. The contractor shall be responsible to provide employee fall protection to comply with OSHA construction standards when necessary when working in loft areas. Fall arrest equipment if used must comply with the most current ANSI standard.
  4. Floors, walls, and stationary non-colonized objects in the enclosed containment work area should be covered by polyethylene sheeting according to the professional judgment of the Remediation Contractor and Environmental Consultant.
  5. The HVAC systems serving the work areas shall be shut down and the duct outlets sealed with six mil plastic. The filters should be removed and disposed of.
  6. The contractor shall install and activate negative air filtration (AFDs) systems that provide four air changes per hour in each work area. The devices and work area set up will establish at a minimum, a negative air pressure differential of 0.02 inches of water inside the work area relative to areas outside the containment before remedial operations begin. This air pressure differential shall be maintained until the Environmental Consultant has determined that the work area has passed clearance inspections and testing. The Contractor shall provide sufficient filters for replacement as necessary or as required by applicable regulations.
  7. Use of detergent solution for damp wiping and for cleaning of dust is permitted. Surfaces to be cleaned should be damp wiped but not soaked.
  8. Commented [JG4]: Not a fan of biocide. We are paying the contractor to remove the visible growth, and to remove wet materials. If conditions for growth are eliminated, then biocide is an unneeded chemical exposure.
  9. A HEPA filter vacuum cleaner should be used to collect any dust and debris. All floors and adjacent surfaces should be cleaned with a biocide solution as a final step.
  10. The Contractor shall utilize ground fault circuit interrupters for all electrical equipment including vacuum cleaners, lights, power tools, and negative air machines.
  11. As waste is removed, it must be placed into a disposal container promptly. Contaminated materials shall be disposed of in sealed 6 mil bags. All waste bags will be double bagged. Bags will be taped to form an air-tight seal and labeled appropriately. Two layers of wrapping or double bagging shall be used.
  12. Commented [JG5]: No need to seal up the waste. It is construction debris. Should be maintained moist and covered if transported trough occupied areas.
  13. Labels and all necessary signs are to be in accordance with OSHA regulations.
  14. The contractor will dispose of all waste as construction debris.
  15. During the actual remediation, the Contractor shall not leave debris in the yard or property, incinerate debris, dump waste by the road or in an unauthorized dumpster, or introduce microbial-containing water into storm or sanitary systems.
  16. Commented [JG6]: Not a thing. ALL water is microbial containing. IT is a good thing!
  17. The Contractor shall clean the work area to be free of all dust and debris, as specified, after removal work is complete and the Environmental Consultant has conducted and approved the visual inspections.
  18. After cleaning, the Contractor shall use detergent solution on non-porous interior surfaces by damp wiping and HEPA vacuum porous/water sensitive materials.
  19. Commented [JG7]: I prefer simple household detergent
  20. The Contractor shall remove the final containment barriers, as specified, after the Environmental Consultant approves the area, based on the inspection and clearance sampling of the containment area.

WORKER PROTECTION

  1. All workers and supervisors shall have received medical approval to wear a respirator as per OSHA 29 CFR 1910.134. The Contractor shall provide workers with personally issued and marked full-face respiratory protection equipment approved by NIOSH/MSHA. As a minimum, respiratory protection shall consist of full-face air purifying respirators with high efficiency cartridges, and if required, acid gas (chlorine) cartridges, organic vapor(s) cartridges, or other respiratory protective equipment necessary to prevent inhalation or aerosolized disinfectant. Disposable respirators are not permitted.
  2. The Contractor shall ensure that workers do not remove respirators to eat, drink, smoke, chew gum or apply cosmetics in the enclosed work areas. Facial hair interfering with the seal of the mask will not be permitted on any personnel working or entering the contaminated area.
  3. The Contractor shall provide workers with sufficient sets of protective disposable clothing, consisting of full-body coveralls, head covers, gloves, and 18-inch high boot type covers in sizes to properly fit individual workers. All workers shall wear Tyvek suits with attached boots, or the equivalent. Gloves will include latex exam gloves or work gloves. Integral boot/head cover/coveralls are acceptable. All persons entering the enclosed work area shall don disposable clothing over street clothes before entering the enclosed work area.
  4. The Contractor shall provide eye protection (for example, full-face respirator) and hard hats, as required by job conditions or by applicable safety regulations. Reusable equipment (for example, footwear, hard hats) shall be left in the contaminated enclosed work area until the end of the remedial work. At that time such items shall be decontaminated for reuse.
  5. The Contractor shall provide authorized visitors with respiratory protection equipment, a set of suitable protective gloves, and footwear, sizes for proper fit, suitable protective disposable clothing, headgear, gloves, and footwear, sizes for proper fit, whenever they are required to enter the enclosed work area. The Contractor shall not under any circumstances permit any person to enter the work areas without the appropriate protective clothing and equipment.

CONTAINMENT EXITING PROCEDURES

  1. Every time a worker leaves the work area, before leaving the air lock at the entrance to the work area, each worker shall HEPA vacuum all gross contamination and debris from outer layer of protective clothing.
  2. Remove protective clothing (disposable coveralls, head cover, gloves, and footwear) in the work area and deposit the clothing in an impermeable bag or container.

INSPECTIONS

  1. The Environmental Consultant shall conduct an initial inspection of the work area containment before remediation work commences.
  2. The Environmental Consultant shall conduct inspections after cleanup is complete to determine if removal of visually contaminated and other scheduled materials is complete.
  3. The contractor shall re-clean the work area, if it fails the Environmental Consultant's clearance inspection and testing. The Environmental Consultant shall then perform additional clearance inspections, and the Contractor shall re-clean if necessary until the work area passes inspections and testing.
  4. The Client or Environmental Consultant shall have authority to stop work when any provision of these specifications are not followed or an unsafe condition exists. The stoppage of work shall continue until all deficiencies have been corrected. All work stoppages must be initiated in writing. Additional time and labor due to the work stoppage shall be at the Contractor's own expense. Recommencement of work shall not be initiated without written authorization from the Environmental Consultant or Client.

CLEARANCE TESTING

Each work area must pass a visual inspection by the building environmental consultant. Evidence of dampness, visible debris, or dust will require additional cleaning and drying. The environmental consultant will use settled dust sampling methods and direct microscopic exam of samples taken from work area surfaces.

At completion of all work and with the work area ready for reconstruction air sampling will be used to confirm that mold abatement is complete. All air testing will be done with the negative pressure systems shut down for at least 24 hours. If the work area airborne spore levels significantly exceed the outdoor levels or if the rank order of mold species inside does not reflect the outdoors the work area will be further cleaned. The presence of significant numbers of Stachybotrys, Aspergillus/Penicillium or Chaetomium spores will be considered unacceptable. - Commented [JG8]: What is significant?

Air sampling for mold spore levels will be conducted using spore trap methods using treated microscope slides or an equivalent method such as air-o-cell cassettes. Sample volumes shall be taken in accordance with the published analytical method and in consultation with the microscopist. The samples will be analyzed by an experienced mycologist.

B.3) Floor Plan Diagram (p. 12)

Title: Mold Abatement Scope of Work – 97 Green St. Apartment #G21 Brooklyn, NY

Description: Architectural floor plan showing apartment layout with labeled areas: - STAIR (left side) - Kitchen (with notation: "Remove sheetrock wall ON BATHROOM SIDE AND INSPECT") - Bathroom (with HW heater marked; notation: "Remove tub and raised floor"; "Remove wall floor to ceiling") - Room 3 (notation: "Remove floor, ceiling, ceiling tiles, and walls") - Room 1 (notation: "Remove wood finish floor, ceiling, and walls") - Room 2 (notation: "Remove carpet, ceiling, and walls") - Loft area (between Room 1 and Room 2; notation: "Remove the ceiling and insulation – and clean the wood deck") - Hallway (notation: "Remove the ceiling") - Living room and bedroom area (upper right; notation: "CUT MULTIPLE PROBES INTO THE WALL CAVITY AND INSPECT FOR MOLD GROWTH"; "CUT A PROBE HOLE INTO THE CEILING AND INSPECT FOR MOLD GROWTH"; "LEAVE THE LIVING ROOM SIDE OF THE WALL UP – INSPECT FROM THE BEDROOM SIDE") - Party wall annotations: "Remove ONLY the wallboard – leave the room 1 and room 2 side of the cavity"; "THIS WALL ONLY TO 4 FEET FROM FLOOR AND INSPECT"

C) Margin Comment Attribution (Jack Glass – JG1-JG8)

VERIFICATION STATUS: CONFIRMED – COURT-FILED DOCUMENT

The margin comments labeled [JG1] through [JG8] appear IN the court-filed Stipulation Exhibit 1 (PDF pages 8-11). These are NOT subsequent annotations by ALC – they are part of the court-ordered scope document as filed.

Attribution: "JG" = Jack Glass, MS, CIH (ALC Environmental VP)

Significance: These comments were made during scope development (pre-filing) and became part of the operative court order when the Stipulation was so-ordered.

Comment Location Content Summary
JG1 Scope Item 1 References exception in Item 6
JG2 Scope Item 4 Suggests 2 feet exposure sufficient
JG3 General Conditions 3 Notes single containment adequate
JG4 Work Area Procedures 7 Opposes biocide use
JG5 Work Area Procedures 10 Objects to waste sealing requirement
JG6 Work Area Procedures 13 Notes all water contains microbes
JG7 Work Area Procedures 15 Prefers household detergent
JG8 Clearance Testing Questions "significant" threshold

D) Source-Tied References (Context Anchors)

Court / Scope

  • Stipulation of Settlement (HP 6086/2020): 12-page court filing including 6-page stipulation terms + 6-page Exhibit 1 (Scope of Work + Floor Plan). Court-approved scope requiring, among other items, removal to studs/slab/deck (rooms 1-3), bathroom raised-floor removal and fixture handling, living-room wall and ceiling probes, and professional mold abatement protocols. Jack Glass margin comments (JG1-JG8) are part of the filed document.

Post-Work Verification

  • ALC Post-Remediation Verification (PRV) – Inspection: July 28, 2021; Report issued: Aug 3, 2021. Signed by Candice A. Kowalewski, MPH and Jack Glass, MS, CIH. States apartment "free and clean of moisture, microbial growth, and 'mold-like' odors" and that "this apartment has achieved clearance." Includes 7 indoor + 1 outdoor air samples; indoor totals reported below outdoor control. PRV Appendix B contains the same Scope of Work document as Stipulation Exhibit 1.

Expert and Follow-up

  • WT-107 – Olmsted Mold Inspection (June 28, 2020) – baseline conditions, moisture, and colonization findings (e.g., 190,000 CFU/in2 under kitchen floor; >5,000,000 CFU/in2 above living-room ceiling).
  • WT-108 – ALC PRV (July 28, 2021; report Aug 3, 2021) – full PRV document including Appendix B.
  • WT-108A – Work Scope (Dec 8, 2020) – extracted scope document. VERIFICATION NOTE (v1.7): Content confirmed identical to Stipulation Exhibit 1; both contain JG1-JG8 margin comments.
  • WT-109 – Olmsted Response (Aug 18, 2022) – identifies non-completed scope items (e.g., Studio 1 floor to slab not removed; ceiling/wall sheetrock left).
  • WT-110 – Olmsted Follow-Up Scope (Nov 7, 2022) – adds 3 specific items (hallway panel wall; living-room column/ceiling probe; bay-closet wall probe with visible mold).
  • WT-111 – July 2023 Re-Flood Email Packet – documents post-PRV re-wet of bathroom, adjacent walls, and main living area; landlord/plumber confirmations (valve break; pipes capped); roof-leak pattern noted across tenants.

Additional anchor (document statement)

  • "Skaller-Blue Comments" file: Contains the line "I believe the walls of Studio 1 were determined to be removed entirely." (Used verbatim here as a scope-recognition statement; provenance/authentication tasks in Section I.)

E) Court Record – On-Record Statement (Affidavit Accuracy)

Fact: Landlord's counsel stated on the record that affidavits asserting comprehensive completion were "inaccurate."

To collect: Certified transcript (date/part/judge; verbatim page/line), appearance sheet, filing context.

Related employment note: Candice A. Kowalewski reportedly terminated after this statement (documentation TBD; see Section I).

F) Documented Event Sequence (Condensed Timeline)

  1. Dec 8, 2020: Court-approved Scope of Work (Exhibit 1 to Stipulation).
  2. July 20-27, 2021: On-site work period (SERVPRO; ALC monitoring). Working-file recollection: "one layer drywall only / bamboo wear layer only"; probes not mentioned.
  3. July 28, 2021: ALC PRV performed; report states "achieved clearance."
  4. Aug 2022 - Nov 2022: Olmsted identifies non-completion (WT-109) and proposes follow-up (WT-110).
  5. July 12-17, 2023: Re-wet event documented (WT-111): bathroom floor/walls, adjacent kitchen/hallway, and living area ceiling.

G) Scope Comparison Matrix – Court-Ordered vs. Reported vs. Certified

Element Court-Ordered Requirement (Stipulation Ex. 1) Reported On-Site Instruction (July 2021) ALC PRV (July 28, 2021) Additional Source-Tied Anchor Corroboration Status / To Collect
Legal authority Exhibit 1 (filed with Stipulation, so-ordered) – PRV signed by Kowalewski + Glass – Transcript/affidavits (see Section E, I)
Walls (general) Remove to studs; clean framing (Scope Item 1) "One layer drywall only" (reported) "Walls removed as per scope" – SERVPRO work orders/logs/photos (TBD)
Floors (general) Remove to concrete slab, incl. raised assemblies (Scope Items 1, 2) "Bamboo wear layer only" (reported) "Floor removed as per scope" – SERVPRO logs/photos; Olmsted findings (WT-109)
Ceilings (general) Remove to deck; cut probes (LR) (Scope Items 1, 7, 9) Not recorded "Ceilings removed" – Photos/logs; probe documentation (TBD)
Studio 1 (walls/ceiling/floor) Full removal to studs/deck/slab (Scope Item 1) Not recorded "Removed as per scope" Doc states: "I believe the walls of Studio 1 were determined to be removed entirely." SERVPRO docs; WT-109 notes two floor layers left; visible mold behind insulation
Bathroom Remove raised floor under tub/HW heater (Item 2); open shared wall with kitchen (Item 3); fixture handling Not recorded "Raised floor, water heater, bathtub removed" WT-110: follow-up probes/area checks Photo/logs; post-PRV re-wet (WT-111)
Hallway/Loft Remove ceiling (Item 7); clean loft/remove insulation; clean wood deck Not recorded "Ceiling and 2 ft of wall… removed" WT-110: hallway panel wall to window base Photos/logs (TBD)
LR wall probes Four 2x2 ft probes along party wall; inspect (Item 8) Not recorded Not specifically claimed WT-110: LR column/ceiling probe Probe photos/logs (TBD)
LR ceiling probes Cut probes to deck; inspect (Item 9) Not recorded Not specifically claimed WT-110: LR probe reference Probe photos/logs (TBD)
Air sampling Post-work spore trap vs outdoor control (Clearance Testing section) N/A 7 indoor + 1 outdoor; indoor less than or equal to outdoor – Full lab packet + chain of custody (TBD)

White note: "Additional Source-Tied Anchor" logs contemporaneous statements or later expert items relevant to that element. Qualifier language (e.g., "I believe") is preserved verbatim without characterization.

G.1) Post-PRV Re-Wet Event (July 2023) – Area Facts and Context

Source: WT-111 – July 2023 email packet (with inline photos) and landlord/plumber replies.

Dates: July 12-17, 2023.

Documented conditions (facts):

  • Bathroom (floor + all four walls): Water damage and visible black mold reported after bathroom sink valve was broken during prior removal; plumber capped pipes; landlord proposed shutting water off to loft; re-wet documented post-PRV.
  • Kitchen (adjacent floor): Likely subsurface pooling noted (consistent with WT-107 baseline: 190,000 CFU/in2 under kitchen floor in 2020).
  • Living area (ceiling/walls): Roof-leak re-wet during heavy rains; tenant email notes building-wide roof-leak complaints.
  • Temporal relation to PRV: Approximately 24 months after ALC "achieved clearance."

Cross-refs:

  • WT-108A – Original scope items covering bathroom floor to substrate and LR probes.
  • WT-110 – Follow-up probes and hallway wall removal recommendation (Nov 7, 2022).
  • ALC Additional Scope (Nov 2022) – kitchen floor marked for complete removal (document exists; add pinpoint page on collection).

H) Personnel and Roles (from case records)

SERVPRO – Raheem Coleman (on-site Production Manager; working-file recollection of "one layer drywall / bamboo layer only" instruction; corroboration via logs/photos TBD). Ronnie Garcia associated with initial assessment (status departed, details TBD). Lisa Mulcahy listed as Stipulation contact (email: lmulcahy@servprohoboken.com; phone: 551-226-1997).

ALC Environmental – Candice A. Kowalewski, MPH (ALC Mold Assessor; PRV signatory; license MA01387 valid 08/31/2018-08/31/2024), Jack Glass, MS, CIH (ALC VP; PRV co-sign; author of margin comments JG1-JG8 in court-filed scope). Corporate license: ALC Mold Assessor Company #00034.

Expert (Tenant) – Edward A. Olmsted, CIH, CSP (baseline 2020 report; Aug 2022 findings WT-109; Nov 2022 follow-up WT-110).

Counsel – David M. Skaller, Esq. (Belkin Burden Goldman, for Respondent); Margaret Sandercock, Esq. (Goodfarb and Sandercock, for Petitioner).

I) Collection and Authentication Targets (Prioritized)

Tier-1 (Court and Certifications)

  1. Certified transcript – on-record "inaccurate" statement (date/part/judge/page-line).
  2. Filed affidavits/PRV – full native PDFs with metadata + any Local Law 61 filings.
  3. ALC HR records – Kowalewski termination date/reason; internal comms.

Tier-2 (Execution and Instructions) – CRITICAL FOR SCOPE DEVIATION CLAIMS

  1. SERVPRO – work orders, daily logs, photo sets, supervisor notes (Garcia - Coleman).
  2. Probes – photo/log evidence for Exhibit 1 LR wall/ceiling probes (whether cut).
  3. Stipulation exhibit – RESOLVED v1.7: Original PDF now integrated (Section B).

Tier-3 (Expert and Addenda)

  1. WT-107 package – full lab packets and chain-of-custody; field notes.
  2. WT-109 pinpoints – images/notes showing Studio 1 floor layers and ceiling/wall mold behind insulation.
  3. WT-110 pinpoints – hallway panel wall, LR column/ceiling probe, bay closet wall visible mold photo(s).

Tier-4 (Re-wet corroboration)

  1. WT-111 full-res photos + any video; plumber invoice/notes (July 2023); roof-leak maintenance logs (building-wide).
  2. ALC Additional Scope (Nov 2022) – pinpoint page showing kitchen floor complete removal.

Authentication for Skaller "Blue Comments" file

  1. Origin/date/author; native metadata; delivery chain; page/line for the Studio 1 sentence; save screenshot excerpt (WT-106-A3-PIN-001).

J) Anchored Evidence Timeline

Date Event Source
Oct 2019 Initial flood (G21) Master timeline
Dec 8, 2020 Stipulation filed with Exhibit 1 (court-approved scope) HP 6086/2020
Jul 20-27, 2021 Work window; ALC onsite monitoring ALC PRV
Jul 28, 2021 ALC PRV performed; report issued Aug 3, 2021 ALC PRV
Aug 18, 2022 WT-109 – Olmsted response (scope not completed, specific findings) WT-109
Nov 7, 2022 WT-110 – Olmsted follow-up scope adds 3 items WT-110
Nov 2022 ALC Additional Scope shows kitchen floor: complete removal ALC addl scope (PDF)
Jul 12-17, 2023 Re-wet documented; visible mold; plumber caps lines; roof leaks noted WT-111
TBD (Court) Counsel states affidavits "inaccurate" on the record Transcript (to collect)

K) Cross-References (White Tabs)

  • WT-107: Baseline inspection and lab data (Olmsted, June 2020).
  • WT-108: ALC PRV (July 28, 2021; report Aug 3, 2021).
  • WT-108A: Dec 8, 2020 Work Scope (extracted; task matrix; Glass margin notes). v1.7 NOTE: Content verified identical to Stipulation Exhibit 1.
  • WT-109: Olmsted response identifying non-completed items (Aug 18, 2022).
  • WT-110: Olmsted follow-up scope additions (Nov 7, 2022).
  • WT-111: July 2023 re-flood email/photo packet (post-PRV re-wet).
  • WT-120 (planned): Divergences Index (facts-only) – parallel quotes from ALC PRV vs. Olmsted/other sources.

END — White Tab 106 – G21 Scope: Court-Ordered vs. Executed – Evidence Resource (Facts Only) v1.9