White Tab 118 -- Stipulation of Settlement: Compliance Timeline Analysis¶
GUARDRAIL: WHITE -- FACT REPOSITORY ONLY
This document records what the stipulation requires, what the documentary evidence shows happened, and where the evidence trail proves or fails to prove compliance. No legal argument or strategy. Interpretive significance belongs in Purple.
PART A -- Document Overview¶
This analysis maps the Stipulation of Settlement (HP 6086/2020) paragraph by paragraph against the actual documented timeline. The stipulation was entered in Housing Court and governed remediation of mold conditions at Apartment G21, 226 Franklin Street, Brooklyn, NY 11222.
The stipulation created a multi-step verification framework: remediation, ALC inspection and PRV report, delivery to petitioner's counsel, Olmsted counter-inspection within 5 days, and Olmsted report within 14 days. The critical question is whether this framework was followed -- and if so, why the Motion to Restore was denied on procedural grounds.
v1.6 update: This version is strengthened by direct review of: - Doc #11 (Notice of Motion), - Doc #17 (Skaller opposition affirmation), - Doc #22 (Sandercock reply affirmation), - Doc #23 (Olmsted reply affidavit), - and the complete Stipulation Compliance Email Archive, including the previously pending row-1904 transmittal PDF.
This version also corrects prior references to Doc #36 and replaces them with the correct Smith-decision references (Doc #31 / Doc #32).
Primary Sources:
- Stipulation of Settlement (HP 6086/2020) -- court-filed
- NYSCEF Doc #11 -- Motion to Restore
- NYSCEF Doc #17 -- Opposition Affirmation
- NYSCEF Doc #22 -- Reply Affirmation
- NYSCEF Doc #23 -- Olmsted Reply Affidavit
- NYSCEF Doc #31 -- Smith Decision / Order
- NYSCEF Doc #32 -- Notice of Entry
- NYSCEF Doc #37 -- Notice of Appeal / RATA
- NYSCEF Doc #38 -- Appellate Term dismissal
- WT-108: ALC PRV Report (Aug 3, 2021)
- WT-108A: Dec 8, 2020 Work Scope (Appendix B)
- WT-108B: Olmsted Post-PRV Inspection and Lab Results (Aug 10-18, 2021)
- WT-109: Olmsted Response to ALC (Aug 18, 2022)
- WT-110: Olmsted Follow-Up Scope (Nov 7, 2022)
- WT-114: Scope Manipulation Evidence Compendium
- WT-117: HP 6086/2020 NYSCEF Docket Analysis
- WT-120A: Skaller Proposed New Stipulation -- Revised Scope and Affidavit Withdrawal
- Email CSV (email_extract_v2.csv) -- indexed by row number
PART B -- Paragraph-by-Paragraph Compliance Map¶
Paragraph 1 -- Remediation Work Commencement¶
Stipulation Requirement: "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'). The remediation company will file the Post Remediation Assessment form and Mold Remediation Certification as required by NYC EPA."
Documented Compliance:
| Element | Required | Actual | Source | Status |
|---|---|---|---|---|
| Preparation work start | Jul 20, 2021 | Jul 20, 2021 | WT-108 (monitoring window) | MET |
| Remediation work start | Jul 21, 2021 | Jul 20-27 range | WT-108 | MET |
| Post Remediation Assessment form filed | Required by NYC EPA | Not documented as filed | WT-109 Section H | UNVERIFIED |
| Mold Remediation Certification filed | Required by NYC EPA | Olmsted states filings were NOT filed | WT-109 Section H | NOT MET |
Evidence Note: WT-109 (Olmsted Response, Aug 18, 2022) states that required Local Law 61 of 2018 filings -- Work Plan Notification, Work Plan, Post-Remediation Assessment Form, and Post-Remediation Certification -- were not filed. This is a separate compliance failure from the scope completion question.
Collection Task: Verify NYC DOL/DOB records for any LL61 filings related to 226 Franklin St., G21, filed in 2021.
Paragraph 2 -- Unfettered Access¶
Stipulation Requirement: "Respondent shall have unfettered access to the Apartment until all the Remediation Work is completed."
Documented Compliance: No dispute identified in the record regarding access during the Jul 20-27, 2021 remediation window.
Paragraph 3 -- Expert Presence During Remediation¶
Stipulation Requirement: "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. Petitioner and Olmstead shall not interfere with the Remediation Work. Petitioner and Respondent landlord shall not be present during the Remediation Work."
Documented Compliance:
| Element | Required | Actual | Source | Status |
|---|---|---|---|---|
| ALC permitted to be present | Yes | ALC monitored Jul 20-27 (M-F, 9am-4pm) | WT-108 | MET |
| Olmsted permitted to be present | Yes (permitted, not required) | Olmsted was NOT present during work | Email [1044] Aug 10, 2021 | PERMITTED BUT DID NOT ATTEND |
| Petitioner/Respondent landlord not present | Required | Not disputed in record | -- | NO DISPUTE |
Evidence Note: Email [1044] (Olmsted to Sandercock, Aug 10, 2021) states: "I spoke with Jack Glass and his assistant, who monitored the work at 97 Greene. They indicated the work is done and all air tests were very low. I have not seen the results." This confirms Olmsted learned about the work completion from ALC after the fact, not from being present during work.
The stipulation says Olmsted "shall be permitted to be present" -- it does not require his presence. However, his absence during remediation meant he could not observe whether the scope was actually performed as ordered, which became central to the subsequent dispute.
Paragraph 4 -- ALC Post-Remediation Report¶
Stipulation Requirement: "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'). Respondent's counsel shall provide Petitioner's counsel with a copy of the ALC Post Remediation Report by e-mail at mbs@goodfarblaw.com."
Documented Compliance:
| Element | Required | Actual | Source | Status |
|---|---|---|---|---|
| ALC inspection upon completion | Yes | Jul 28, 2021 (1 day after work ended Jul 27) | WT-108 | MET |
| ALC written report prepared | Yes | Report issued Aug 3, 2021 | WT-108 | MET |
| Report delivered to Petitioner's counsel at mbs@goodfarblaw.com | Yes | Delivered Aug 11, 2021 at 10:48 AM | Email [1904] (Skaller transmittal in forwarded chain); WT-108B Section C | MET |
Evidence of Delivery Date:
Email [1904] (Sandercock to Olmsted/Gray, Aug 11, 2021 at 11:17 AM) contains the complete forwarded chain showing the Skaller transmittal. The chain documents:
- 10:37 AM -- ALC PRV report scanned to Skaller at BBG LLP (Canon Printer internal scan)
- 10:48 AM -- David Skaller emails Sandercock at mbs@goodfarblaw.com: "Attached is the ALC report with regard to the Gray apartment. Pursuant to the terms of the stipulation of settlement, Ed Olmstead has 5 days to inspect and test and you have 14 days from when he inspects to provide me with his report."
- 11:17 AM -- Sandercock forwards the chain to Olmsted (CC: Gray): "Please note schedule in below email."
The Skaller 10:48 AM email satisfies every element of the Paragraph 4 delivery requirement: sent by respondent's counsel (Skaller), to petitioner's counsel (Sandercock) at the stipulated email address (mbs@goodfarblaw.com), with the ALC PRV report attached, explicitly referencing the stipulation deadlines.
PRV Delivery Gap: The ALC PRV was issued Aug 3, 2021 but not transmitted by Skaller until Aug 11, 2021 -- an 8-day gap between report issuance and delivery. The stipulation does not impose a deadline on this transmittal step.
Paragraph 5 -- Olmsted Inspection and Report Deadlines¶
Stipulation Requirement (two obligations):
Obligation 5A: "Within 5 days ('Olmstead Inspection Deadline') of Respondent's counsel delivering a copy of the ALC Post Remediation Report to Petitioner's counsel, Olmstead shall inspect and test the Apartment to ensure that the Remediation Work has been completed and prepare a written report ('Olmstead Post Remediation Report')."
Obligation 5B: "Petitioner's counsel shall provide Respondent's counsel with a copy of the Olmstead Post Remediation Report by email at DSkaller@bbgllp.com within 14 days of the Olmstead Inspection Deadline."
Forfeiture Clause: "In the event Olmstead fails to inspect and test the Apartment by the Olmstead Inspection Deadline, Petitioner shall forfeit and waive its right to inspect and test the Apartment and shall not be permitted to restore this proceeding or commence a proceeding or action to challenge ALC's report or that the Remediation Work has not been completed."
Obligation 5A -- 5-Day Inspection Deadline¶
Day Count (email-sourced):
| Day | Date | Event | Source |
|---|---|---|---|
| Day 0 | Aug 11, 2021 | Skaller transmits PRV to Sandercock at 10:48 AM | Email [1904] (forwarded chain): Skaller email with ALC report attached |
| Day 1 | Aug 12, 2021 | Olmsted proposes 8:30am Monday inspection | Email [1012] |
| Day 1 | Aug 12, 2021 | Gray confirms attendance | Email [1016] |
| Day 5 | Aug 16, 2021 | Olmsted inspects G21; 13 samples collected (9 air + 2 bulk + 2 tape lift) | WT-108B Section A (COC signed, dated Aug 16) |
STATUS: 5-DAY DEADLINE MET. Olmsted inspected on Day 5 (Aug 16, 2021).
Supporting Email Chain:
- Email [1038] (Sandercock, Aug 11): "Called me, he is working on a govt. contract in the Virgin Islands and is coming back this weekend. He can go to your building Monday. Please keep your schedule open...Monday is the last day he can inspect."
- Email [1039] (Sandercock, Aug 11): "Late in the day Monday like 4 30 pm or later. Can you provide access at that time?"
- Email [1012] (Olmsted, Aug 12, 6:36 AM): "Can I meet you at 97 Greene at 8:30 am on Monday instead of later in the day. I think Monday is going to be fraught with delays and I would like to get yours done first."
- Email [1016] (Gray, Aug 12): "I'll be there at 8:30am on Monday."
- WT-108B: Chain of Custody form signed by Edward Olmsted, dated August 16, 2021, listing 9 samples from G21.
Note on Sandercock's Awareness: Sandercock explicitly calculated the deadline in her Aug 11 email ("5 days from today") and stated "Monday is the last day he can inspect." This confirms she understood the stipulation requirement and was tracking compliance.
Obligation 5B -- 14-Day Report Deadline¶
Day Count (from Olmsted Inspection Deadline = Aug 16, 2021):
| Day | Date | Event | Source |
|---|---|---|---|
| Day 0 (inspection) | Aug 16, 2021 | Olmsted inspects; samples collected | WT-108B (COC) |
| Day 1 | Aug 17, 2021 | Prestige lab analysis completed (Report #210817-04) | WT-108B Section A |
| Day 2 | Aug 18, 2021 | Lab forwards results to Olmsted (9:47 AM) | Email [1900] (forwarded from Prestige) |
| Day 2 | Aug 18, 2021 | Olmsted forwards to Sandercock + Gray with professional assessment: "These results are terrible. All the air samples have very elevated levels of pen-asp spores...They need to do the entire scope" | Email [1900] |
| Day 2 | Aug 18, 2021 | Sandercock acknowledges: "Thank you for letting us know, looking forward to report." | Email [1011] |
| Day 3 | Aug 19, 2021 | Olmsted sends draft formal report to Sandercock | Email [1930] (Sandercock forwards draft to Gray) |
| Day 3 | Aug 19, 2021 | Sandercock sends Olmsted report + notice of default to Skaller (DSkaller@bbgllp.com) | Email [1927] |
| Day 14 | ~Aug 30, 2021 | 14-day deadline | Stipulation Para. 5 |
| ~Day 372 | Aug 18, 2022 | Formal narrative report (WT-109) issued | WT-109 |
STATUS: 14-DAY DEADLINE -- SUBSTANTIALLY MET (Day 3).
Sandercock transmitted Olmsted's report to Skaller on Aug 19, 2021 (Day 3), well within the 14-day window. The transmittal email [1927] explicitly states: "I attach Ed Olmsted's report based on observations and samples taken on 8/16/21...This is a notice of default with respect to the stipulation entered into in the HP proceeding."
The Formal Report Question: The formal narrative report (WT-109) was not produced until Aug 18, 2022 -- approximately 12 months later. The question is whether the Aug 18-19, 2021 delivery of lab results + professional assessment + draft report satisfies Para 5's requirement for "a copy of the Olmstead Post Remediation Report."
Current record view: The email record strongly supports that Sandercock treated the Aug 19 transmittal as compliant. She sent it to Skaller as a notice of default under the stipulation. She did not indicate any further report was needed to complete the Paragraph 5 obligation.
Paragraph 6 -- Mutual Agreement on Completion (Discontinuance)¶
Stipulation Requirement: "In the event that ALC and Olmstead agree that the Remediation Work is completed after the Completion Date ('Completion Confirmation Date'), this proceeding shall be discontinued and the Parties shall forthwith execute and file a stipulation of discontinuance, with prejudice."
STATUS: NOT TRIGGERED.
ALC certified clearance (WT-108). Olmsted found the opposite -- elevated mold levels, incomplete scope, and concluded the remediation was inadequate (Email [1900], WT-108B, WT-109). ALC and Olmsted did not agree. Paragraph 6 was therefore never triggered.
Paragraph 7 -- Disagreement and Motion to Restore¶
Stipulation Requirement: "In the event ALC and Olmstead cannot agree that the Remediation Work has been completed or additional remediation work is necessary, either party may restore this proceeding, by notice of motion, for a hearing on the sole issue of whether the Respondent did not comply with the agreed upon Remediation Work or any additional work that either or both ALC and Olmstead believes should have been performed as being necessary..."
Documented Compliance:
| Element | Required | Actual | Source | Status |
|---|---|---|---|---|
| ALC-Olmsted disagreement | Prerequisite | Established Aug 2021 | WT-108 vs WT-108B/109 | MET |
| Motion to Restore filed | Either party may file | Filed Jun 14, 2022 | NYSCEF Doc #11 | MET (10-month delay) |
10-Month Enforcement Gap: The ALC-Olmsted disagreement was established by Aug 18, 2021 at the latest (email [1900]: "These results are terrible...They need to do the entire scope"). The Motion to Restore was not filed until Jun 14, 2022 -- a gap of approximately 10 months.
During this gap, the email record shows:
- Sep 15, 2021 (email [968]): Sandercock tells Gray that the landlord will "likely" continue work but no ServPro date yet due to hurricane emergency work. Options: wait or make a court motion.
- Oct 11, 2021 (email [981]): Sandercock tells Olmsted she has been "trying to get the landlord attorney to tell me if the landlord is going to complete the scope of work or whether we need to restore the case." Skaller proposed a phone conference between Olmsted and the landlord's expert.
- Nov 22, 2021 (email [959]): Sandercock asks Olmsted: "I have not been contacted about remediation resuming; do you have any update on it? Is it time for me to agitate with the owner's lawyer?"
- Nov 22, 2021 (email [963]): Olmsted responds: "Not yet. I have been discussing with jack glass. Will touch base with him tomorrow."
- Dec 22, 2021 (email [874]): Sandercock follows up on whether the landlord's expert has agreed to get ServPro back.
- Dec 23, 2021 (email [879]): Sandercock proposes: "I get in touch with owner's lawyer and say we'll restore the HP case if they don't get going on the work."
Pattern: From Aug 2021 through Dec 2021, Sandercock pursued informal resolution rather than filing the Motion to Restore. The motion was not filed until Jun 14, 2022.
Paragraph 8 -- Agreed Non-Completion¶
Stipulation Requirement: "In the event ALC and Olmstead agree that the Remediation Work was not completed after the Completion Date, the Mold Remediation Company shall complete the agreed upon outstanding Renovation Work and the Parties shall repeat the process as stated in paragraphs five (5) through nine (9) herein."
STATUS: NOT TRIGGERED IN FORMAL PROCESS.
However, the Nov 7, 2022 follow-up inspection (WT-110) documents that Olmsted and Jack Glass (ALC) conducted a joint walk-through where Glass acknowledged additional work remained. WT-109 Section G states that in July 2021, Glass acknowledged further work was needed and a written plan was expected but never provided.
This creates a factual basis that approaches Paragraph 8 conditions informally -- the landlord's own expert (Glass/ALC) acknowledged work was incomplete -- but no formal Paragraph 8 process was initiated.
Late-2022 Related Development (off-docket): On Nov 3, 2022, David Skaller emailed Margaret Sandercock, marked "FOR SETTLEMENT PURPOSES ONLY," proposing terms for a new stipulation of settlement. The email states that Jack had prepared a new scope of work and that Ed had indicated at their last apartment meeting that it was acceptable as the remaining scope of work. It contemplates access for Servpro and two other companies to bid that scope with Jack and Ed present, expert presence on the last day of work to determine whether additional work was required, a pre-selected third party to decide any expert disagreement about additional work, and states that upon full execution of the new stipulation "we will agree to withdraw the affidavit of Jack and Candice." This is a later off-docket attempt to replace the stalled / disputed compliance framework with a revised stipulation architecture. It does not alter the documented Aug 2021 Paragraph 5 sequence; it records a later November 2022 effort to restructure the unresolved dispute.
Paragraphs 9-13 -- Procedural and Release Provisions¶
Paragraph 9 (Restoration limitation): Proceeding may only be restored for enforcement of stipulation obligations regarding remediation work or additional disputed work.
Documented use of Paragraph 9:
Doc #11 (Notice of Motion) sought restoration to determine compliance with the June 29, 2021 stipulation. Doc #22 then argued expressly that paragraph 9 permits restoration both where the agreed scope was not performed and where additional disputed work remains.
Paragraph 10 (Mutual release): Broad release of claims "from the beginning of the world through the date of this Stipulation." Analyzed separately in the release / vacatur strategy material. Not a compliance question.
Paragraphs 11-13: Attorney fee reservation, drafting neutrality, and supersession clauses. Not relevant to the compliance timeline.
PART C -- Why Smith Did Not Recognize Compliance¶
C.1 Smith Decision -- Core holding¶
On Sep 29, 2023, Hon. Remy Smith, J.H.C. denied the Motion to Restore. Smith's reasoning, per Doc #31 / Doc #32 and WT-117, was:
- The motion was "devoid of the respondent's remediator's Post Remediation Report that was to trigger the Olmstead Post-Remediation Report."
- Olmsted's report (Doc #16) was "completely devoid of the date that respondent's remediator 'cleared the work'" -- so the court could not determine whether petitioner had met the Olmstead Inspection Deadline.
- While respondent attached its PRR, there was "no proof that it was emailed in compliance with paragraph 5" of the stipulation.
- There was "no proof that Olmstead conducted his inspection within 5 days of the email."
- There was no proof that Olmstead "emailed respondent's counsel a copy of the Olmstead Post Remediation Report within 14 days of his inspection."
- Conclusion: "The ability to bring this motion was therefore never triggered and the motion must be denied."
C.2 What the newly reviewed papers add¶
The new review of Docs #11, #17, #22, and #23 sharpens the procedural picture:
- Doc #11 confirms the motion sought restoration to determine compliance with the June 29, 2021 stipulation.
- Doc #17 shows the opposition focused mainly on lack of admissible proof / personal knowledge, respondent compliance, Bard, and dismissal.
- Doc #22 shows Sandercock's reply was built around paragraph 9, 11 specific scope failures, and Bard distinction.
- Doc #23 supplies sworn Olmsted support that the scope was not completed, he did not cut holes, the unit remained contaminated, and Glass had previously indicated more work was needed.
C.3 Opposition theory versus Smith theory¶
This distinction is now important enough to state explicitly.
| Focus area | Skaller opposition (Doc #17) | Smith decision (Docs #31 / #32) |
|---|---|---|
| Personal knowledge / admissibility | Central | Not the basis of denial |
| Respondent complied / ALC PRV establishes completion | Central | Not the basis of denial |
| Bard as controlling analogy | Central | Not the basis of denial |
| Missing proof that PRV email triggered paragraph 5 deadlines | Not foregrounded as the central relief-denial theory | Central |
| Missing proof of 5-day / 14-day timing compliance | Not foregrounded as the central relief-denial theory | Central |
Current file implication: Smith denied the motion on a trigger-proof theory that does not appear to map cleanly onto the main emphasis of Doc #17. That is significant because the later Notice of Appeal / RATA (Doc #37) states that the order was improperly denied based on arguments never raised in opposition.
C.4 The evidentiary gap was real -- but it appears curable on paper¶
Smith ruled on procedure because the motion papers did not include the evidence proving compliance. But that evidence existed in the email record:
| What Smith needed | What the emails prove | Source |
|---|---|---|
| Proof PRR was emailed per paragraph 5 | Skaller emailed PRR to Sandercock at 10:48 AM on Aug 11, 2021 | Email [1904] |
| Date respondent's remediator cleared work | ALC PRR inspection Jul 28, report Aug 3 | WT-108 |
| Proof Olmsted inspected within 5 days | COC dated Aug 16, 2021 (Day 5 from Aug 11 delivery) | WT-108B; Email [1012] |
| Proof Olmsted's report was emailed to respondent's counsel within 14 days of his inspection | STIP-EMAIL-1927 (Aug 19, 2021): Sandercock-to-Skaller transmittal serving as both notice of default and delivery of the Olmsted draft report -- Day 3 from Aug 16 inspection, well within the 14-day window | Email [1927] |
Current file implication: The stipulation-compliance emails materially strengthen the proposition that the motion was denied because the proof package was not assembled and presented, not because the timing chain was actually broken.
PART D -- Compliance Summary Table¶
| Para | Requirement | Deadline | Actual | Days Used | Status | Evidence |
|---|---|---|---|---|---|---|
| 1 | Work commences Jul 20-21 | Jul 20-21, 2021 | Jul 20, 2021 | 0 | MET | WT-108 |
| 1 | LL61 filings | Required | Not filed per Olmsted | -- | NOT MET | WT-109 Sec H; Doc #23 |
| 3 | ALC present during work | Permitted | Jul 20-27, M-F | -- | MET | WT-108 |
| 3 | Olmsted present during work | Permitted | Not present | -- | PERMITTED/DECLINED | Email [1044] |
| 4 | ALC inspects upon completion | Upon completion | Jul 28 (1 day after) | 1 day | MET | WT-108 |
| 4 | ALC report prepared | Upon completion | Aug 3, 2021 | 7 days | MET | WT-108 |
| 4 | ALC report delivered to Petitioner's counsel | By email to mbs@ | Aug 11, 2021 at 10:48 AM | 8 days | MET | Email [1904] |
| 5A | Olmsted inspects within 5 days of delivery | 5 days from Aug 11 | Aug 16, 2021 | Day 5 | MET | WT-108B; Email [1012] |
| 5B | Olmsted report to Skaller within 14 days | 14 days from Aug 16 | Aug 19, 2021 | Day 3 | SUBSTANTIALLY MET | Email [1927] |
| 6 | ALC + Olmsted agree = discontinue | -- | Did not agree | -- | NOT TRIGGERED | -- |
| 7 | Disagreement = motion to restore | Either party may file | Filed Jun 14, 2022 | ~10 months | MET (delayed) | Doc #11 |
| 9 | Proceeding may be restored for compliance / disputed additional work | As needed | Invoked in motion / reply | -- | USED | Doc #11; Doc #22 |
PART E -- Evidence Gaps and Collection Tasks¶
E.1 Critical evidence status¶
- Skaller-to-Sandercock PRV transmittal email. RESOLVED. The row-1904 PDF is now present in the email archive.
- Olmsted draft report sent to Sandercock Aug 19. RESOLVED.
- LL61 filing records. Still worth checking against NYC DOL/DOB records.
- Skaller response to Aug 19 notice of default. Still useful if it exists.
- Any motion or letter after substitution attempting to supplement the record before Smith ruled. None identified in the current NYSCEF review.
E.2 Existing evidence sufficient to establish¶
The Stipulation Compliance Email Archive now supports the following with documentary confidence:
- Skaller transmitted the ALC PRV to Sandercock on Aug 11, 2021 at 10:48 AM.
- Olmsted inspected on Aug 16, 2021.
- Lab results and professional assessment were delivered Aug 18, 2021.
- Sandercock transmitted default/report material to Skaller on Aug 19, 2021.
- Sandercock was actively tracking the 5-day deadline in real time.
- The file contains a substantial post-results enforcement-delay sequence before the Motion to Restore was filed.
PART F -- NYSCEF Filing Record and Motion Chronology¶
F.0 NYSCEF Filing Record by Counsel Period¶
Sandercock period (Goodfarb & Sandercock LLP):
| NYSCEF Doc | Date | Content | Filed By |
|---|---|---|---|
| #11 | Jun 14, 2022 | Notice of Motion (Motion to Restore) | Sandercock, E. |
| #12-16 | Jun 14, 2022 | Supporting papers (affirmation, exhibits, Olmsted report) | Sandercock, E. |
| #22 | Aug 31, 2022 | Reply Affirmation #1 (11 scope failures, para 5a-k) | Sandercock |
| #23 | Aug 31, 2022 | Reply Affirmation #2 (Olmsted sworn affidavit) | Sandercock |
Kozek period (Ween & Kozek PLLC):
| NYSCEF Doc | Date | Content | Filed By |
|---|---|---|---|
| #25 | Nov 15, 2022 | Substitution of Attorney (notarized) | Oksman, N. |
| #26 | Nov 15, 2022 | Notice of Appearance | Oksman, N. |
| #28-30 | Dec 2022 - Mar 2023 | Adjournment stipulations | Oksman, N. |
| #37 | Oct 31, 2023 | Notice of Appeal | Kozek-Perkins, M. |
Substitution of counsel occurred Nov 15, 2022 (Doc #25). Smith decided the motion Sep 29, 2023 (Doc #31 / Doc #32).
F.1 Motion structure, opposition structure, reply structure¶
| Filing | What it mainly does |
|---|---|
| Doc #11 | Seeks restoration to determine landlord compliance with the June 29, 2021 stipulation |
| Doc #17 | Attacks admissibility/personal knowledge, argues respondent complied, relies on Bard |
| Doc #22 | Invokes paragraph 9, itemizes 11 deficiencies, distinguishes Bard, argues restoration is required |
| Doc #23 | Supplies sworn Olmsted support: no hole-cutting, scope not completed, contamination remains, Glass had said more work was needed |
F.2 Smith Decision -- Stated Findings (Sep 29, 2023)¶
Smith denied the Motion to Restore. The decision identified the following evidentiary deficiencies in the motion papers (Docs #11-16, #22-23):
| Smith's Finding (Docs #31 / #32) | Corresponding Evidence in Record |
|---|---|
| Motion "devoid of" respondent's Post Remediation Report (the trigger document) | ALC PRR issued Aug 3; transmitted Aug 11 |
| Olmsted report (Doc #16) "devoid of the date remediator cleared the work" -- preventing determination of Olmstead Inspection Deadline | ALC PRR identifies Jul 28 inspection / Aug 3 report |
| "No proof [PRR] was emailed in compliance with paragraph 5" | Email [1904] |
| "No proof that Olmstead conducted his inspection within 5 days" of the email | Email [1012]; COC dated Aug 16 |
| No proof Olmstead emailed respondent's counsel a copy of the Olmstead Post Remediation Report within 14 days of his inspection | STIP-EMAIL-1927 (Aug 19, 2021 transmittal -- three days after Aug 16 inspection) |
F.3 Email Chronology -- Post-Results Through Motion Filing (Aug 2021 -- Jun 2022)¶
Olmsted's lab results were received Aug 18, 2021 (email [1900]). The Motion to Restore was filed Jun 14, 2022 (Doc #11). The email record during this interval:
- Sep 15, 2021 (email [968]): Sandercock to Gray -- "wait, or make a court motion to restore"
- Oct 11, 2021 (email [981]): Sandercock to Olmsted -- trying to determine whether the landlord would complete the work or whether the case needed to be restored
- Nov 22, 2021 (email [959]): Sandercock to Olmsted -- "Is it time for me to agitate with the owner's lawyer?"
- Dec 23, 2021 (email [879]): Sandercock to Gray -- proposes restoring HP case if the work does not resume
F.4 Scope Position Statements in Email Record (Aug 11-13, 2021)¶
Email [1048] (Aug 11, 2021), Sandercock to Olmsted and Gray: "In my humble and quite likely uneducated opinion, I am not convinced the scope of work matters if the test results are good."
Email [1015] (Aug 13, 2021), Sandercock to Gray: "I keep trying to prepare you for the fact that if Ed's test reports are good, you have no position and you are wasting your time pursuing this." And: "If the test results are good, neither Ed nor I can advocate for work that was part of a contract but perhaps not needed."
These emails do not change the timeline proof. They do matter because they show Sandercock's own framing of the dispute in real time.
F.5 Late-2022 Off-Docket Corrective Proposal (Nov 3, 2022)¶
On Nov 3, 2022, David Skaller emailed Margaret Sandercock, marked "FOR SETTLEMENT PURPOSES ONLY," with proposed terms for a new stipulation of settlement. The proposal stated:
- Jack had prepared a new scope of work and Ed had indicated at their last apartment meeting that it was acceptable as the remaining scope of work;
- respondent would provide access for Servpro and two other companies to bid on that scope, with Jack and Ed present so the contractors would understand and agree to perform the attached scope;
- Jack and Ed would be present on the last day of work while the remediation company was still present so additional work could be done immediately if the experts agreed it was still part of the stipulated scope;
- if the experts disagreed, a pre-selected third party would determine whether the additional work was part of the scope and who would pay for it; and
- "[u]pon the full execution of this stipulation, we will agree to withdraw the affidavit of Jack and Candice."
This Nov 3, 2022 proposal is not part of the original Paragraph 5 compliance chain. It is a later off-docket record showing that, by early November 2022, the parties were still attempting to replace the stalled / disputed compliance framework with a revised stipulation architecture.
F.6 Post-Substitution Filing Record (Nov 2022 -- Sep 2024)¶
| Date | Event | Source |
|---|---|---|
| Nov 15, 2022 | Substitution of counsel filed (Doc #25, #26) | NYSCEF |
| Dec 2022 - Mar 2023 | Adjournment stipulations filed (Docs #28-30) | NYSCEF |
| Sep 29, 2023 | Smith decision denying Motion to Restore (Doc #31 / #32) | NYSCEF |
| Oct 31, 2023 | Notice of Appeal filed (Doc #37) | NYSCEF |
| Sep 23, 2024 | Appeal dismissed for failure to perfect (Doc #38) | NYSCEF |
The RATA form (Doc #37) stated the decision was "based upon arguments that were never raised in opposition to Petitioner's motion and which are unsupported by the law and the so-ordered stipulation of settlement."
PART G -- Cross-References¶
| Tab | Content | Relevance |
|---|---|---|
| WT-108 | ALC PRV Report (Aug 3, 2021) | Paragraph 4 compliance; clearance statement |
| WT-108A | Work Scope (Dec 8, 2020) | Baseline scope agreed |
| WT-108B | Olmsted Post-PRV Inspection/Lab Results | Paragraph 5A compliance; COC; compliance table |
| WT-109 | Olmsted Response to ALC | Formal report; LL61 filings; scope refutation |
| WT-110 | Olmsted Follow-Up | Glass acknowledged additional work |
| WT-114 | Scope Manipulation Evidence Compendium | Comprehensive scope failure documentation |
| WT-117 | NYSCEF Docket Analysis | Smith decision; full docket |
| WT-120A | Skaller Proposed New Stipulation | Late-2022 revised stipulation / remaining-scope proposal |
| Orange B001 | Sandercock Malpractice Framework | Motion failure; enforcement delay |
PART H -- Email Index (Stipulation-Relevant)¶
The following emails from email_extract_v2.csv are directly relevant to stipulation compliance. Row numbers reference the CSV for retrieval. PDF column links to archived email PDFs in the media folder.
H.1 Pre-Remediation (May-Jul 2021)¶
| Row | Date | From | Subject | Relevance | |
|---|---|---|---|---|---|
| 1093 | Jun 1, 2021 | Orefice | HP case settlement | Stipulation signed reference | |
| 1863 | Jun 17, 2021 | Sandercock | FW: Workshare Compare Document Distribution | Stipulation drafts to Olmsted | |
| 1053 | Jul 19, 2021 | Olmsted | Calendar to be on site this wednesday | Pre-remediation scheduling |
H.2 Post-Remediation / PRV Window (Aug 2021)¶
| Row | Date | From | Subject | Relevance | |
|---|---|---|---|---|---|
| 1032 | Aug 2, 2021 | Gray | Mold Remediation | Scope concerns post-work | |
| 1035 | Aug 2, 2021 | Sandercock | Re: Mold Remediation | Sandercock response re ServPro | |
| 1044 | Aug 10, 2021 | Olmsted | mold work | Olmsted spoke with Glass; work described as done | |
| 1037 | Aug 11, 2021 | Gray | Re: mold work | Gray details scope failures to Olmsted | |
| 1904 | Aug 11, 2021 | Sandercock | FW: Attached Image | Forwards Skaller's 10:48 AM transmittal (ALC PRV attached); Day 0 established | |
| 1048 | Aug 11, 2021 | Sandercock | Re: mold work | Deadline awareness; "5 days from today" | |
| 1038 | Aug 11, 2021 | Sandercock | Ed Olmsted | Monday is last day | |
| 1039 | Aug 11, 2021 | Sandercock | Update on Olmsted | 4:30pm Monday proposed | |
| 1012 | Aug 12, 2021 | Olmsted | Re: mold work | Proposes 8:30am Monday (Aug 16) | |
| 1016 | Aug 12, 2021 | Gray | Re: mold work | Confirms 8:30am Monday | |
| 1014 | Aug 13, 2021 | Gray | Exhibit 1 | Requests scope of work document | |
| 1015 | Aug 13, 2021 | Sandercock | Re: Exhibit 1 | "not convinced scope of work matters if test results good" | |
| 1900 | Aug 18, 2021 | Olmsted | Fwd: two reports for 97 Green | Lab results: "These results are terrible" | |
| 1011 | Aug 18, 2021 | Sandercock | Re: two reports for 97 Green | Acknowledges receipt | |
| 1930 | Aug 19, 2021 | Sandercock | Fwd: draft report | Forwards Olmsted draft to Gray | |
| 1927 | Aug 19, 2021 | Sandercock | FW: Christian Gray, 226 Franklin St. | Notice of default to Skaller with Olmsted report |
H.3 Post-Results / Enforcement Gap (Sep 2021-Jun 2022)¶
| Filename | Row | Date | From > To | Subject | Status |
|---|---|---|---|---|---|
| STIP-EMAIL-0968_20210915_Sandercock_Mold_Work_Loft.pdf | 968 | Sep 15, 2021 | Sandercock > Gray | Mold work in your loft | AVAILABLE |
| STIP-EMAIL-0981_20211011_Sandercock_Update_Restore.pdf | 981 | Oct 11, 2021 | Sandercock > Olmsted | update | AVAILABLE |
| STIP-EMAIL-0959_20211122_Sandercock_Owners_Expert.pdf | 959 | Nov 22, 2021 | Sandercock > Olmsted | 226 Franklin owner's expert | AVAILABLE |
| STIP-EMAIL-0963_20211122_Olmsted_Re_Owners_Expert.pdf | 963 | Nov 22, 2021 | Olmsted > Sandercock | Re: 226 Franklin owner's expert | AVAILABLE |
| STIP-EMAIL-0874_20211222_Sandercock_ServPro.pdf | 874 | Dec 22, 2021 | Sandercock > Olmsted, Gray | ServPro | AVAILABLE |
| STIP-EMAIL-0879_20211223_Sandercock_Re_ServPro_Restore.pdf | 879 | Dec 23, 2021 | Sandercock > Gray | Re: ServPro | AVAILABLE |
| -- | Jun 14, 2022 | -- | Motion to Restore filed | NYSCEF [Doc #11](media/WT-117_nyscef_doc_11_notice_of_motion.pdf) (PDF) | -- |
H.4 Late-2022 Off-Docket Related Record¶
| Date | From | To | Subject / Description | Relevance |
|---|---|---|---|---|
| Nov 3, 2022 | David Skaller | Margaret Sandercock | "FW: Attached Image" -- proposal for new stipulation of settlement | Documents a later off-docket attempt to replace the disputed compliance process with a revised stipulation architecture centered on remaining scope, expert-supervised completion, third-party dispute resolution, and withdrawal of the Jack/Candice affidavits upon execution. See WT-120A. |
PART I -- Conclusion of Fact¶
The documentary evidence -- primarily emails written by Sandercock herself, now fully archived in the Stipulation Compliance Email Archive -- establishes that the petitioner's side complied with the Stipulation of Settlement's Paragraph 5 verification framework:
- Skaller transmitted the ALC PRV to Sandercock on Aug 11, 2021 at 10:48 AM.
- Olmsted inspected G21 on Aug 16, 2021, Day 5 of the 5-day window.
- Lab results and professional assessment were delivered to Sandercock on Aug 18, 2021, Day 2 after inspection.
- Olmsted's report was transmitted to Skaller on Aug 19, 2021, Day 3 after inspection, well within the 14-day window.
- The Aug 19 transmittal was explicitly framed as a notice of default with respect to the stipulation.
The newly reviewed motion filings further show that: - Doc #11 sought restoration to determine compliance with the June 29, 2021 stipulation; - Doc #17 opposed mainly on admissibility, compliance, and Bard; - Doc #22 and Doc #23 supplied a substantial reply / rebuttal record of non-completion; - and Smith's procedural denial did not resolve the merits of scope compliance.
Smith's denial was based on the absence of the trigger proof in the motion papers -- not on a finding that the deadlines were actually missed. The evidence proving compliance existed in Sandercock's own email correspondence and was available for inclusion in the Motion to Restore record.
A later Nov 3, 2022 Skaller proposal for a new stipulation of settlement shows that the stipulation-enforcement story did not end with the Aug 2021 default notice and Jun 2022 motion. The proposal reflects an off-docket attempt to replace the stalled / disputed framework with a revised remaining-scope process, expert oversight, and proposed withdrawal of the Jack/Candice affidavits upon execution.
PART J -- Source Document Archive¶
This section indexes all source documents referenced in this analysis. Documents are organized by type. PDF links use media/ relative paths for MkDocs deployment in the same volume directory.
J.1 Court-Filed Documents¶
| Document | Description | |
|---|---|---|
| Stipulation of Settlement | HP 6086/2020 -- so-ordered stipulation governing remediation, verification, and restoration framework (Paras 1-13) | Stipulation of Settlement (PDF) |
| NYSCEF Doc #11 | Notice of Motion -- Motion to Restore (filed Jun 14, 2022 by Sandercock) | Doc #11 (PDF) |
| NYSCEF Doc #16 | Olmsted Report (filed as exhibit with Motion to Restore) | Doc #16 (PDF) |
| NYSCEF Doc #22 | Reply Affirmation #1 -- Sandercock's 11 scope failures (para 5a-k) | Doc #22 (PDF) |
| NYSCEF Doc #23 | Reply Affirmation #2 -- Olmsted sworn affidavit | Doc #23 (PDF) |
| NYSCEF Doc #25 | Substitution of Attorney -- Ween & Kozek replaces Goodfarb & Sandercock (Nov 15, 2022) | Doc #25 (PDF) |
| NYSCEF Doc #31 | Decision/Order -- Hon. Remy Smith denying Motion to Restore (Sep 29, 2023) | Doc #31 (PDF) |
| NYSCEF Doc #37 | Notice of Appeal -- Kozek (Oct 31, 2023); includes RATA form | Doc #37 (PDF) |
| NYSCEF Doc #38 | Notice of Entry -- Appellate Term dismissal for failure to perfect (Sep 23, 2024) | Doc #38 (PDF) |
J.2 Expert Reports and Lab Results¶
| Document | Description | |
|---|---|---|
| ALC PRV Report (WT-108) | Post-Remediation Verification -- inspection Jul 28, 2021; report Aug 3, 2021; "achieved clearance" | ALC PRV Report (PDF) |
| Olmsted COC | Chain of Custody form -- signed by Edward Olmsted, dated Aug 16, 2021; 9 samples from G21 | WT-108B -- source: COC (PDF) |
| Prestige Lab Reports | Prestige EnviroMicrobiology Report #210817-04 -- analysis completed Aug 17, 2021 | WT-108B -- source: Direct Exam (PDF), Spore Trap (PDF) |
| Olmsted Response (WT-109) | Response to Skaller Affirmation -- Aug 18, 2022; "replete with misleading and incorrect statements" | Olmsted Response (PDF) |
| Dec 8, 2020 Work Scope (WT-108A) | Agreed mold abatement work scope -- Appendix B of PRV | WT-108A -- source: PRV Appendix B (PDF) |
J.3 Email Evidence -- Stipulation Compliance Window (Aug 2021)¶
These are the emails that prove Paragraph 5 compliance. All 25 relevant emails are now converted to PDF and archived in the media folder. Load-bearing emails are bolded.
| Filename | Row | Date | From > To | Subject | Status |
|---|---|---|---|---|---|
| STIP-EMAIL-1032_20210802_Gray_Mold_Remediation.pdf | 1032 | Aug 2, 2021 | Gray > Sandercock | Mold Remediation | AVAILABLE |
| STIP-EMAIL-1035_20210802_Sandercock_Re_Mold_Remediation.pdf | 1035 | Aug 2, 2021 | Sandercock > Gray | Re: Mold Remediation | AVAILABLE |
| STIP-EMAIL-1044_20210810_Olmsted_Spoke_With_Glass.pdf | 1044 | Aug 10, 2021 | Olmsted > Sandercock, Gray | mold work | AVAILABLE |
| STIP-EMAIL-1037_20210811_Gray_Scope_Failures.pdf | 1037 | Aug 11, 2021 | Gray > Olmsted | Re: mold work | AVAILABLE |
| STIP-EMAIL-1904_20210811_Sandercock_FW_Skaller_ALC_PRV.pdf | 1904 | Aug 11, 2021 | Sandercock > Olmsted (CC: Gray) | FW: Attached Image | AVAILABLE |
| STIP-EMAIL-1048_20210811_Sandercock_5_Days_From_Today.pdf | 1048 | Aug 11, 2021 | Sandercock > Olmsted, Gray | Re: mold work | AVAILABLE |
| STIP-EMAIL-1038_20210811_Sandercock_Ed_Olmsted_VI.pdf | 1038 | Aug 11, 2021 | Sandercock > Gray | Ed Olmsted | AVAILABLE |
| STIP-EMAIL-1039_20210811_Sandercock_Update_Olmsted.pdf | 1039 | Aug 11, 2021 | Sandercock > Gray | Update on Olmsted | AVAILABLE |
| STIP-EMAIL-1012_20210812_Olmsted_830am_Monday.pdf | 1012 | Aug 12, 2021 | Olmsted > Sandercock | Re: mold work | AVAILABLE |
| STIP-EMAIL-1016_20210812_Gray_Confirms_Monday.pdf | 1016 | Aug 12, 2021 | Gray > Olmsted, Sandercock | Re: mold work | AVAILABLE |
| STIP-EMAIL-1014_20210813_Gray_Exhibit_1_Request.pdf | 1014 | Aug 13, 2021 | Gray > Sandercock | Exhibit 1 | AVAILABLE |
| STIP-EMAIL-1015_20210813_Sandercock_Scope_Doesnt_Matter.pdf | 1015 | Aug 13, 2021 | Sandercock > Gray | Re: Exhibit 1 | AVAILABLE |
| STIP-EMAIL-1900_20210818_Olmsted_Lab_Results_Terrible.pdf | 1900 | Aug 18, 2021 | Olmsted > Sandercock, Gray | Fwd: two reports for 97 Green | AVAILABLE |
| STIP-EMAIL-1011_20210818_Sandercock_Ack_Lab_Results.pdf | 1011 | Aug 18, 2021 | Sandercock > Olmsted, Gray | Re: two reports for 97 Green | AVAILABLE |
| STIP-EMAIL-1930_20210819_Sandercock_Fwd_Draft_Report.pdf | 1930 | Aug 19, 2021 | Sandercock > Gray | Fwd: draft report | AVAILABLE |
| STIP-EMAIL-1927_20210819_Sandercock_Notice_Default_Skaller.pdf | 1927 | Aug 19, 2021 | Sandercock > Skaller | FW: Christian Gray, 226 Franklin St. | AVAILABLE |
J.4 Email Evidence -- Enforcement Gap (Sep-Dec 2021)¶
These emails document the 10-month delay between Olmsted's findings and the Motion to Restore.
| Filename | Row | Date | From > To | Subject | Status |
|---|---|---|---|---|---|
| STIP-EMAIL-0968_20210915_Sandercock_Mold_Work_Loft.pdf | 968 | Sep 15, 2021 | Sandercock > Gray | Mold work in your loft | AVAILABLE |
| STIP-EMAIL-0981_20211011_Sandercock_Update_Restore.pdf | 981 | Oct 11, 2021 | Sandercock > Olmsted | update | AVAILABLE |
| STIP-EMAIL-0959_20211122_Sandercock_Owners_Expert.pdf | 959 | Nov 22, 2021 | Sandercock > Olmsted | 226 Franklin owner's expert | AVAILABLE |
| STIP-EMAIL-0963_20211122_Olmsted_Re_Owners_Expert.pdf | 963 | Nov 22, 2021 | Olmsted > Sandercock | Re: 226 Franklin owner's expert | AVAILABLE |
| STIP-EMAIL-0874_20211222_Sandercock_ServPro.pdf | 874 | Dec 22, 2021 | Sandercock > Olmsted, Gray | ServPro | AVAILABLE |
| STIP-EMAIL-0879_20211223_Sandercock_Re_ServPro_Restore.pdf | 879 | Dec 23, 2021 | Sandercock > Gray | Re: ServPro | AVAILABLE |
J.5 Email Evidence -- Pre-Remediation Context¶
| Filename | Row | Date | From > To | Subject | Status |
|---|---|---|---|---|---|
| STIP-EMAIL-1093_20210601_Orefice_HP_Settlement.pdf | 1093 | Jun 1, 2021 | Orefice > Gray | HP case settlement | AVAILABLE |
| STIP-EMAIL-1863_20210617_Sandercock_Workshare_Stip.pdf | 1863 | Jun 17, 2021 | Sandercock > Olmsted, Gray | FW: Workshare Compare Document Distribution | AVAILABLE |
| STIP-EMAIL-1053_20210719_Olmsted_Calendar_Onsite.pdf | 1053 | Jul 19, 2021 | Olmsted > Sandercock, Gray | Calendar to be on site this wednesday | AVAILABLE |
J.6 Binder Cross-References (Internal Links)¶
These WT tabs are referenced throughout this analysis. They are separate binder documents, not archived here.
| Tab | Title | Binder Location |
|---|---|---|
| WT-108 | ALC Post-Remediation Verification (PRV) Report (Aug 3, 2021) | Vol 07, Tab 108 |
| WT-108A | Mold Abatement Work Scope (Dec 8, 2020) | Vol 07, Tab 108A |
| WT-108B | Olmsted Post-PRV Inspection and Lab Results (Aug 10-18, 2021) | Vol 07, Tab 108B |
| WT-109 | Olmsted Response to ALC (Aug 18, 2022) | Vol 07, Tab 109 |
| WT-110 | Olmsted Follow-Up Scope (Nov 7, 2022) | Vol 07, Tab 110 |
| WT-114 | Scope Manipulation Evidence Compendium | Vol 07, Tab 114 |
| WT-117 | HP 6086/2020 NYSCEF Docket Analysis | Vol 07, Tab 117 |
| WT-120A | Skaller Proposed New Stipulation -- Revised Scope and Affidavit Withdrawal | Vol 07, Tab 120A |
J.7 Collection Status Summary¶
| Category | Total | Archived | Pending |
|---|---|---|---|
| Court-filed documents (NYSCEF) | 9 | 9 | 0 |
| Expert reports / lab results | 5 | 5 | 0 |
| Stipulation compliance emails (Aug 2021) | 16 | 16 | 0 |
| Enforcement gap emails (Sep-Dec 2021) | 6 | 6 | 0 |
| Pre-remediation emails | 3 | 3 | 0 |
| Total email PDFs | 25 | 25 | 0 |
Collection Status: All 25 relevant stipulation-compliance emails are now converted to PDF and archived in the media folder. Each PDF preserves full headers (From, To, Date, Subject) and body content. The 4 load-bearing emails (rows 1904, 1012, 1900, 1927) are confirmed identified and archived.
Attachments Archived (6 files): The ALC PRV report from email [1904], three Prestige lab report files from email [1900], the Olmsted draft report from email [1927], and the post-abatement inspection report from email [1930] have been archived separately. See J.8 below.
J.8 Email Attachment Archive¶
Six high-value attachments from the stipulation compliance email chain have been archived separately.
| Filename | Source Email | Description | Size |
|---|---|---|---|
| ALC PRV Report -- Skaller Attachment (PDF) | Row 1904 | ALC PRV report (3444_001.pdf) attached to Skaller's Aug 11, 2021 transmittal; same content as WT-108 | 1.24 MB |
| Prestige Scanned Report (PDF) | Row 1900 | Prestige EnviroMicrobiology combined scanned report -- Report #210817-04 | 839 KB |
| Prestige Direct Exam (PDF) | Row 1900 | Prestige lab direct examination results -- Report #210817-04 | 122 KB |
| Prestige Spore Trap (PDF) | Row 1900 | Prestige spore trap analysis results -- Report #210817-04 | 140 KB |
| Olmsted Draft Report (PDF) | Row 1927 | Olmsted draft formal report attached to notice of default (Aug 19, 2021) | 9.6 MB |
| Post-Abatement Inspection (PDF) | Row 1930 | Post-abatement inspection report for 97 Greene (Aug 19, 2021) | 10.7 MB |
END -- White Tab 118 -- Stipulation of Settlement: Compliance Timeline Analysis v1.8