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White Tab 108A — Mold Abatement Work Scope (Dec 8, 2020) — Extracted From ALC PRV Appendix B

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) What This Is & Why It's Here (Provenance & Positioning)

  • Source of Text: The "Mold Abatement Scope of Work – 97 Green St. Apartment #G21" as it appears in Appendix B of ALC Environmental's Post‑Remediation Verification (PRV) report (WT‑108).
  • Scope Date (as shown): December 8, 2020.
  • Signatories on PRV (parent document): Candice A. Kowalewski, MPH; Jack Glass, MS, CIH.
  • Dual Existence: The same Work Scope was also used as Stipulation Exhibit 1 (court‑filed).
  • Court filing date: June 29, 2021 — so-ordered and filed with Exhibit 1 annexed as NYSCEF Doc #10 (see WT‑106 §J; WT‑106B).

Document Status (explicit): Although the Work Scope appears inside WT‑108's PRV as Appendix B, WT‑108A is a standalone tab because the Work Scope predates the PRV, is dated 12/08/2020 (the landlord's expert's margin comments on it were accepted by Olmsted on 12/21/2020; see WT‑106 §J), and serves as the baseline for WT‑106 (Scope vs. Executed) and WT‑109 (Olmsted response) and subsequent events.

Related Document — Contractor Packet: WT‑104B is a Total Restoration, Inc. estimate package prepared by Christopher Roussis (estimate file Date Entered 12/4/2019; packet printed 1/19/2021) whose attached scope pages are this same Work Scope at a later revision stage: seven of the eight Jack Glass margin comments (JG1–JG8) that appear as balloons on this version are written into the body text there (comparison table at WT‑104B §D). The version filed as Stipulation Exhibit 1 is the unrevised text with the balloons. WT‑104B also contains handwritten floor plan annotations (including “this is phase 1”) not present in this version.

Bates Note (extraction logic): We assign G21‑SCOPE‑001–005 to this organized extraction so it can be referenced and paginated independently from the raw PRV PDF (WT‑108). This preserves usability without altering the original PRV pagination. (Pinpoint page references to the PRV Appendix B pages are provided as pp. TBD pending a completed pinpoint pass.)

B) Room‑by‑Room / System Work Scope — Ten Required Actions (Verbatim Substance)

Scope Date: December 8, 2020 (as shown on the source pages).

Format below: Item # | Plain‑language restatement of the Work Scope requirement (sourced from Appendix B).

  1. Studios 1–3 — Full Demolition & Cleaning

Remove all walls to the studs and slab and remove all ceilings in Rooms 1, 2, and 3 (the three studio rooms). HEPA vacuum framing and surfaces and detergent clean.

  1. Bathroom — Raised Floor / Tub / Water Heater

Remove the raised bathroom floor and bathtub assembly and remove the water heater. Open the bathroom/kitchen shared wall as necessary per item 3 and clean all exposed cavities and structures as specified.

  1. Bathroom ↔ Kitchen Shared Wall (Back of Kitchen Base Cabinets)

Open the shared wall and HEPA/detergent clean the back side of kitchen cabinets and exposed wall cavity from the bathroom side.

  1. Hallway Washer/Dryer Area — Units & Wall

Remove the washer and dryer, open the wall behind as specified, HEPA vacuum and detergent clean exposed cavities and framing.

  1. Studio 1 — Walls/Ceiling/Floor (as specified)

Remove Studio 1 walls and ceiling per the plan; remove flooring as specified in the scope (rooms to slab where called out); HEPA and detergent clean.

  1. Studio 2 — Walls/Ceiling/Floor (as specified)

Remove Studio 2 walls and ceiling per the plan; remove carpet/flooring as specified; HEPA and detergent clean.

  1. Studio 3 — Walls/Ceiling (and Hallway side cuts)

Remove Studio 3 walls and ceiling per plan; at the hallway side, remove up to 2 ft at the base (hallway B/C walls) to expose and examine (see D‑1 re: on‑page comment "2 feet").

  1. Party Wall Probes (Moisture/Mold Intrusion Check)

Cut four (4) exploratory openings, each 24 in × 24 in, in the party wall (locations per plan) to inspect cavities; HEPA and detergent clean if impacted.

  1. Ceiling Probes to Wood Deck (Upper Cavities)

Open ceiling areas to access the wood deck above for inspection; remove impacted insulation; HEPA and detergent clean deck/joists as required.

  1. Air Handling Unit / Fan Coil / HVAC Touchpoints

Access and service any air handling units or fan‑coil equipment in the work areas per plan; replace filters, clean housings, and address impacted components where specified.

Pinpoints: This ten‑item scope appears in WT‑108 Appendix B (pp. TBD). The same language appears in Stipulation Exhibit 1 (so-ordered and filed June 29, 2021, NYSCEF Doc #10 pp. 8–12).

C) Containment, Safety & Environmental Controls (Selected Operational Requirements)

Note on selection: The Work Scope contains detailed abatement procedures. This section extracts the field‑critical control requirements that are most referenced elsewhere (negative pressure, containment, decon, cleaning). For full PRV clearance criteria and lab specs, see WT‑108 §G.

  • Containment & Negative Pressure: Establish regulated work areas with tight containment and negative pressure maintained during removal; pressure differential monitoring per standard practice.
  • Worker Protection & Decon: Worker PPE per plan; decontamination chamber for ingress/egress; waste handling in sealed bags/containers.
  • Engineering Controls: HEPA filtration units operating continuously; dust suppression; isolation of non‑work areas.
  • Cleaning Protocols: HEPA vacuum all exposed surfaces and detergent clean as specified; repeat until surfaces are free of dust/debris and visibly clean.
  • Ready‑for‑Clearance Condition: Areas must pass visual (no dust/debris/visible dampness) before any post‑remediation air testing (see WT‑108 for test specs).

D) Inline Editorial Callouts Seen on Source Pages (Fact)

The Appendix B pages include inline editorial comments attributed on‑page to "JG" (as rendered):

  • [JG1] — "Except as noted in 6, below."
  • [JG2] — "I would require only 2 feet to expose and examine."

These appear on the December 8, 2020 scope pages and indicate editorial involvement contemporaneous with the Work Scope text. (See WT‑108 Appendix B pp. TBD.) The court‑filed Exhibit 1 carries the full set JG1–JG8 (WT‑106 §C); the contractor packet at WT‑104B §D shows each comment as incorporated into the revised text.

E) Cross‑References (White Tabs)

  • WT‑104B — Total Restoration Mold Mitigation Scope Package (Date Entered 12/4/2019; printed Jan 19, 2021): Contractor estimate packet carrying this Work Scope in its revised form (JG comments incorporated); comparison table and the December 2020 / February 2021 correspondence at §§C–D.
  • WT‑108 — ALC PRV (Aug 3, 2021): Parent report that includes this Work Scope as Appendix B; documents ALC monitoring and "clearance" testing.
  • WT‑106 — G21 Scope: Court‑Ordered vs Executed: Uses this Dec 8, 2020 scope as the binding baseline for the comparison matrix (Required vs. Executed).
  • WT‑109 — Olmsted Response (Aug 18, 2022): Addresses alleged violations/non‑completion against this scope.
  • WT‑111 — July 2023 Re‑Flood Email Packet: Later visible damage/mold events noted after the scope/PRV period.
  • WT‑001 — Master Timeline: Adds the 12/08/2020 scope anchor; links to July 2021 PRV and later events.
  • WT‑003 — Discovery Tracker: Tracks pinpoint confirmation and court filing date for Stipulation Exhibit 1, plus native‑file and metadata pulls.

F) Filing / Pinpoint Status (to be completed in WT‑003)

  • PRV Appendix B pinpoints: pp. TBD (to be logged with page images in WT‑003).
  • Stipulation Exhibit 1 (court‑filed) date: June 29, 2021 (NYSCEF Doc #10; WT‑106 §J).
  • Native file & metadata (origin, author fields, timestamps): TBD (authenticate via discovery).

G) How to Cite This Extract (Neutral Use)

When citing specific requirements, quote the text from §B and include both references where applicable:

  • "Dec 8, 2020 Work Scope," WT‑108 Appendix B (pp. TBD); and
  • "Stipulation of Settlement — Exhibit 1" (so-ordered and filed June 29, 2021, NYSCEF Doc #10).

END — White Tab 108A — Mold Abatement Work Scope (Dec 8, 2020) — Extracted From ALC PRV Appendix B v1.5