White Tab 125 -- Olmsted Correspondence Record (October 2021 - June 2023)¶

GUARDRAIL: WHITE -- SOURCE RECORD

This tab holds the Olmsted-related email corpus (petitioner's Proton Mail export) covering the post-certification period, and indexes its principal findings. Facts and record citations only; every claim is tier-tagged (Documented) or noted as a reported statement within a documented email. Legal characterization is reserved to counsel. E-numbers cite the compiled corpus PDF's chronological index.

A) Corpus Identity¶

Source: Petitioner's Proton Mail export -- all Olmsted-related emails; 50 messages, October 11, 2021 - June 29, 2023 (Eastern Time).
Compilation: WT-125_Olmsted_Correspondence.pdf -- chronological, native searchable text, one email per page, paired ET/UTC header times, attachment inventory at Annex A. MD5 ce484d0d3e548d32d772e011d9c0fac2 (77 pp; 173,635 bytes).
Participants: Margaret Sandercock (22 messages), petitioner (9), Edward Olmsted (9), Olmsted Environmental invoicing (5), Nina C. Oksman, Ween & Kozek (5).
Attachments: 12 items across 8 emails; distinct-content items archived in this tab's media folder and inventoried at Part E.

B) The Post-Certification Concession Sequence (Documented)¶

The corpus documents, in the contemporaneous correspondence of petitioner's then-counsel and respondent's counsel, the following sequence. Each entry cites its email; reported oral statements are identified as such.

Date	Record	Source
Oct 11, 2021	Sandercock identifies respondent's remediator as SERVPRO, not returned post-certification (Hurricane Ida cited); respondent's counsel proposes an expert-to-expert conference.	E01 (Documented)
Nov 22, 2021	Olmsted: "I have been discussing with jack glass."	E04 (Documented)
Dec 22, 2021	Sandercock follows up "on whether the landlord's expert has agreed to get ServPro back to finish the work."	E05 (Documented)
Dec 22, 2021	Petitioner's email preserves Olmsted's August 18, 2021 post-certification message verbatim: "These results are terrible... All the air samples have very elevated levels of pen-asp spores... They need to do the entire scope." Same email reports a further flood (roof leaks; gas-heater vent breach) since August 2021.	E06 (Documented)
Mar 16-17, 2022	Sandercock to Skaller: respondent's "mold remediator did not complete what we considered to be a full scope of work" and respondent's evaluator "agreed with Olmsted that work needed to continue." Skaller requests that agreement in writing.	E08 (Documented; reported expert statement within)
Apr 11, 2022	Olmsted-Glass site meeting at the Unit (invoiced at $400, E29; access protocol per E09: landlord not permitted to be present).	E14-E20, E29 (Documented)
Apr 27, 2022	Sandercock to Skaller: "Jack Glass agreed to a further scope of work and agreed to write it up... Both experts agree, I am told, that the unit is not habitable." Skaller's same-day reply: "Jack is working on a potential new scope of work... then jack will send to Ed. This is for settlement purposes only."	E22 (Documented correspondence; reported expert statements within; settlement-purposes designation noted -- admissibility is counsel's question)
Jun 13, 2022	Sandercock: "Landlord lawyer contacted me today and said Jack Glass says the original scope of work was done." Motion to restore follows (return date July 7, 2022; E27).	E26 (Documented; reported statement within)
Jul 6-28, 2022	Glass and Kowalewski affidavits sworn (July 6 and 8) and filed (July 28) in opposition to restoration (NYSCEF Doc Nos. 18-19).	Court file (Documented)
Aug 4, 2022	Sandercock transmits the Motion to Restore and respondent's Affirmation in Opposition (native copies, this tab's media), summarizing respondent's position: "they claim the scope of work was done and that if there is still mold, it's your fault" -- and noting respondent's firm previously prevailed in a matter in which Judge Stoller found Olmsted-as-expert caused mold spread by opening walls and ceilings.	E28 (Documented; characterizations are Sandercock's)
Aug 24, 2022	Olmsted transmits his August 18, 2022 response natively ("Olmsted Report MBS Clean 8.18.22.pdf," this tab's media) -- provenance for the response held at White Tab 109.	E31 (Documented)
Oct 4, 2022	Second Glass-Olmsted site meeting, 2:30 PM, access confirmed.	E32-E36 (Documented)
Oct 7, 2022	Sandercock's contemporaneous same-day email records a call with Skaller: "He says the scope of work does not appear to have been completed. He claims the landlord is furious because he paid all that money to have his consultants watch the remediation and it still was not done right." Glass to produce a report of remaining work in "around a week." The same email records that petitioner "was invited to pitch a buyout."	E38 (Documented as to the email; reported oral statements within)
Mar 21, 2023	Multi-party unit walkthrough, 2:00-4:30 PM: "Landlord, their attorneys and expert join," with petitioner, Olmsted, Kozek, Oksman, and Skaller invited; 1:30 PM client-side pre-meeting. Calendar invitations archived (this tab's media).	E41-E48 (Documented)

C) Reading Notes and Flags¶

Sequence significance (for counsel's evaluation). The July 2022 sworn affidavits sit between the April 27, 2022 correspondence recording Glass's agreement to a further scope and both experts' reported view that the unit was not habitable, and the October 7, 2022 correspondence recording respondent's counsel's statement that the scope does not appear to have been completed. The June 13, 2022 reversal ("original scope of work was done") intervenes six weeks after respondent's counsel's own new-scope email. Characterization is counsel's.
The promised write-up. Glass's written further scope, promised April 2022 and again referenced October 7, 2022 ("around a week"), does not appear in this corpus. ALC's November 2022 additional scope-of-work document (White Tab 110A) is the next scope writing in the record and is consistent in timing with the October commitment; whether it is that write-up is an inference, not asserted.
Date-trap warning. Oksman's February 27, 2023 subject line and body state "March 21, 2022"; Olmsted's Invoice 9071 repeats the same misprint. The inspection occurred March 21, 2023 (calendar invitations, E42/E47, control). No binder document should inherit the 2022 misprint.
Settlement-designation caution. The April 27, 2022 Skaller message is self-designated "for settlement purposes only"; the October 7, 2022 statements were made in an inter-counsel call. Use and admissibility are counsel's questions. The June 13, 2022 position statement and the July 2022 court filings carry no such designation.
"Late summer" tension. Sandercock's March 16, 2022 email places the expert agreement in "late summer" 2021; the corpus first shows the expert conference proposed October 11, 2021 (E01) and Olmsted-Glass discussions on November 22, 2021 (E04). The tension is preserved, not resolved.
Health record. Sandercock to Skaller, March 16, 2022: "Our client then had Covid, which turned into long Covid" (E08) -- a contemporaneous third-party writing; it also frames respondent's available delay narrative. Both edges noted.
"Last July" dating -- RESOLVED to April 11, 2022 (documentary reconciliation). Olmsted's August 18, 2022 response states "Last July Ed Olmsted and Jack Glass met on site... Mr. Glass advised me at that time of his opinion that further work was needed. We were waiting for a written plan from Jack Glass... This was never provided." Five sources converge on April 11, 2022 as the meeting described: (i) Glass's own affidavit, sworn July 6, 2022, states "On April 11, 2022, I re-inspected the Apartment with Olmsted" (NYSCEF Doc No. 19, ¶12); (ii) Olmsted's Invoice 8854 bills exactly one Glass site meeting in the August 2021 - August 2022 period -- "Meeting with Jack Glass on Site Monday April 11, 2022" (this tab's media); (iii) the content matches the April 27, 2022 correspondence verbatim in substance ("agreed to a further scope of work and agreed to write it up but apparently has not done so yet," E22); (iv) the 2021 expert contact was telephonic (E01 authorization Oct 11, 2021; E04 "discussing," Nov 22, 2021; E08 "speak"/"conversation"), and Sandercock's June 2022 sworn motion recites the evaluator channel "since August 2021" with no site meeting; (v) no July 2021 or July 2022 Glass-Olmsted site meeting appears in this corpus, the Sandercock correspondence archive, the motion, or the affirmation (corpus-level negatives across the searched record). The "July" in the response is accordingly treated as a misdated reference to the April 11, 2022 meeting; binder references deriving "July 2021" from this passage are corrected on that basis. Residual: an undocumented, unbilled additional meeting cannot be absolutely excluded but has no record support
Regulatory content of the August 18, 2022 response (E31 media). The response states the mold assessors were required to file a Mold Remediation Work Plan Notification, a Mold Remediation Work Plan, a Post Remediation Assessment Form, and a Mold Post Remediation certification (citing Local Law 61 of 2018) and that "[n]one of this was done"; and that NYS DOL mold regulations and NYC guidelines require post-abatement moisture testing, which was not performed. The filing assertions are verifiable against public records (collection target). The response also states that neither Glass nor Skaller was present during Olmsted's post-remediation inspection ("neither has any knowledge of my survey methods"), that "ALC remained on site daily" during the work though not called for by the scope -- corroborated by the PRV's own text as annexed to the affirmation: ALC "onsite throughout the remediation process" July 20-27, 2021 (Mon-Fri, 9:00am-4:00pm) "to ensure removal of all visually contaminated building materials and the prescribed work scope was completed"; the same PRV passage records "[u]p to 2ft of wall removed" on the hallway side (room-designation cross-mapping against White Tab 113 and White Tab 106 required before use) --, and that the scope "was worked out for the course of a year involving Jack Glass, Candice Kowalewski, Ed Olmsted with approval from Christian Gray."
The prior-case citation identified. The Olmsted-blame theory traces to Bard v Mautner-Glick et al., Index No. 2266/2016 (Civ. Ct., NY County 2022) (Hon. Jack Stoller). Olmsted's response states the Bard decision itself attributes the ceiling holes to another individual before his inspection and that he cut none -- i.e., per Olmsted, the affirmation mischaracterizes the decision it cites. Verification of the decision text is a collection target.
The ¶12 characterization tension (for counsel's evaluation). Glass's sworn ¶12 describes the April 11, 2022 joint re-inspection solely as his observation of "additional demolition" attributed to Olmsted, and is silent on the further-scope agreement that the contemporaneous correspondence of both counsel records from the same period -- including Respondent's counsel's own April 27, 2022 statement that "Jack is working on a potential new scope of work." The same meeting is described incompatibly by the sworn account and the correspondence.
Restoration-timing record. Sandercock, May 31, 2022: "if we do not restore the case soon, the court would be able to deny the restoration... we are messing up our ability to get damages by not doing everything we can to help ourselves in Housing Court" (E23). Held as record; use is counsel's.

D) Expert Out-of-Pocket Record (Documented)¶

Olmsted Environmental invoices to petitioner, archived in this tab's media:

Invoice	Line items	Amount	Payment record
8854 (issued Aug 21, 2022; corrected Oct 10, 2022)	Aug 16-17, 2021 inspection and report ($500); RUSH laboratory analysis, 13 samples ($1,040); Apr 11, 2022 Glass site meeting ($400); response to the August 2022 affirmation ($600)	$2,540.00	$900.00 paid on site (credited on the corrected invoice); $1,640.00 balance paid by check, sent October 11, 2022 (E40)
9071 (issued Apr 3, 2023)	Mar 21, 2023 experts-and-lawyers scope meeting (invoice misprints "2022")	$600.00	Reminder June 29, 2023 (E50); payment not shown in this corpus

E) Attachment Inventory (native copies, this tab's media)¶

Source	File	MD5	Bytes
E28	WT-125_E28_Motion_to_Restore.pdf	`57d8abced7ce6ff1c02887e901cb47d0`	15,861,982
E28	WT-125_E28_Affirmation_in_Opposition.pdf	`05db272b7a9941a568767b62cd5f1bf1`	7,492,604
E31	WT-125_E31_Olmsted_Report_MBS_Clean_8-18-22.pdf	`dbe6d89f1511f89c3b874d1a25862c3b`	175,916
E29	WT-125_E29_Invoice_8854_original.pdf	`f13dd7e4dbad4b8a204799657429312b`	10,920
E39	WT-125_E39_Invoice_8854_corrected.pdf	`58439c925152b049ad199160f13813fc`	11,027
E49	WT-125_E49_Invoice_9071.pdf	`ecba3f4c0e37e48df56c2c9b2aa446bd`	10,700
E42	WT-125_E42_Inspection_calendar_2023-03-21.ics	`9d01a5378dd498b040de9040d1c12507`	2,324
E47	WT-125_E47_PreMeeting_calendar_2023-03-21.ics	`28c83c80aee01681b9894604497519be`	1,993

Duplicate transmissions retained in the source corpus but not duplicated here: E37 (Invoice 8854 reminder, content identical to E29), E50 (Invoice 9071 reminder, content identical to E49), and the invite.ics counterparts of the two calendar files. The Motion to Restore native copy (15.8 MB, with exhibits) is distinct from the shorter motion document previously held; reconcile at next White-volume audit.

F) Cross-References¶

END -- White Tab 125 -- Olmsted Correspondence Record v1.0.1