Red-OATH Tab C002 — Implementation Roadmap Task Tracking
GUARDRAIL: RED-OATH — HARASSMENT CASE
OATH harassment proceeding documentation. Separate from main civil action. Facts and procedural framework only.
POSTURE NOTE — Implementation Roadmap Task Tracking
This tab provides the implementation roadmap for the OATH harassment petition documented in Red-OATH Volume 10. It translates the evidence inventory (C001) into actionable tasks with owners, deadlines, dependencies, and status tracking.
This tab:
- Organizes all tasks by category (Evidence Collection, FOIL Requests, Witness Coordination, Filing Preparation, Hearing Preparation).
- Tracks task status (Not Started / In Progress / Complete / Blocked).
- Maps dependencies between tasks.
- Establishes critical path for filing timeline.
- Provides status dashboard for progress monitoring.
This tab does not:
- Contain damages calculations, multipliers, or settlement strategy (those live in Brown, Yellow, Pink, Purple).
- Replace the vector tabs or evidence inventory - it implements the work they define.
- Make legal conclusions - it tracks execution for attorney oversight.
I. IMPLEMENTATION OVERVIEW
I.A. Filing Prerequisites
Before OATH petition can be filed, the following must be complete:
| Prerequisite |
Status |
Blocking Tasks |
| HP 6086/2020 certified transcript collected |
Not Started |
B006-TRNS-LOC-1 |
| Filed affidavits collected |
Not Started |
B006-AFF-COL-1 |
| Loft Board conference records obtained |
Not Started |
C001-LB-CONF-1 |
| Expert witness retained (Olmsted) |
In Progress |
C002-WIT-EXP-1 |
| Petition draft complete |
Not Started |
C002-FIL-PET-1 |
| Counsel review complete |
Not Started |
C002-FIL-REV-1 |
I.B. Task Summary by Category
| Category |
Total Tasks |
Not Started |
In Progress |
Complete |
Blocked |
| Evidence Collection |
19 |
17 |
2 |
0 |
0 |
| FOIL Requests |
8 |
8 |
0 |
0 |
0 |
| Witness Coordination |
14 |
12 |
2 |
0 |
0 |
| Filing Preparation |
6 |
6 |
0 |
0 |
0 |
| Hearing Preparation |
5 |
5 |
0 |
0 |
0 |
| TOTAL |
52 |
48 |
4 |
0 |
0 |
I.C. Critical Path Summary
The critical path to filing runs through:
- Court records collection (HP transcript, affidavits, Stipulation) - 2-4 weeks
- FOIL requests (Loft Board, DOB) - 4-8 weeks (can run parallel)
- Expert retention (Olmsted formal engagement) - 1-2 weeks
- Petition drafting (after T1 evidence collected) - 2-3 weeks
- Counsel review and filing - 1-2 weeks
Estimated minimum timeline to filing: 8-12 weeks from task initiation
II. EVIDENCE COLLECTION TASKS
II.A. Tier-1 Critical Evidence (Filing Prerequisites)
| Task ID |
Task Description |
Owner |
Deadline |
Status |
Dependencies |
Notes |
| B006-TRNS-LOC-1 |
Obtain HP 6086/2020 certified transcript |
Counsel |
Week 4 |
Not Started |
None |
Court records request; $1.25/page |
| B006-AFF-COL-1 |
Collect filed affidavits from HP 6086/2020 |
Counsel |
Week 4 |
Not Started |
None |
Same court records request |
| C001-STIP-1 |
Obtain certified copy of Stipulation Exhibit 1 |
Counsel |
Week 4 |
Not Started |
None |
May already be in file |
| C001-GOV-EO-1 |
Document Executive Order 202.8 (COVID) |
Paralegal |
Week 2 |
Not Started |
None |
Public record; NY.gov |
| C001-GOV-NYC-1 |
Document NYC COVID orders (March-May 2020) |
Paralegal |
Week 2 |
Not Started |
None |
Public record; NYC.gov |
II.B. Tier-2 High Priority Evidence
| Task ID |
Task Description |
Owner |
Deadline |
Status |
Dependencies |
Notes |
| 209-COL-CMP-1 |
Collect Kauch complaint filings |
Paralegal |
Week 6 |
Not Started |
209-WIT-CONTACT |
Requires witness cooperation |
| 210-COL-LGL-1 |
Obtain Fesel litigation packet |
Counsel |
Week 6 |
Not Started |
210-WIT-CONTACT |
Coordinate with Sandercock |
| 104-COL-ADJ-1 |
Identify master adjuster (Dec 2019) |
Paralegal |
Week 8 |
Not Started |
None |
Discovery target |
| 104-COL-PA-1 |
Obtain Power Adjustment file |
Counsel |
Week 8 |
Not Started |
None |
Subpoena may be required |
| 104-COL-TR-1 |
Obtain Total Restoration records |
Counsel |
Week 8 |
Not Started |
None |
Subpoena may be required |
| C001-INS-ADJ-1 |
Identify insurance master adjuster |
Paralegal |
Week 8 |
Not Started |
None |
For insurance fraud corroboration |
II.C. Tier-3 Supporting Evidence
| Task ID |
Task Description |
Owner |
Deadline |
Status |
Dependencies |
Notes |
| C001-SERV-1 |
Obtain SERVPRO scope instructions/records |
Counsel |
Week 10 |
Not Started |
None |
Discovery subpoena likely |
| C001-ALC-HR-1 |
Obtain ALC HR records (Kowalewski termination) |
Counsel |
Week 10 |
Not Started |
None |
Discovery subpoena |
| C001-MED-1 |
Obtain medical records (if pursuing health claims) |
Plaintiff |
TBD |
Not Started |
Plaintiff decision |
Optional |
| C001-PHOTO-1 |
Collect current unit condition photos |
Plaintiff |
Week 2 |
Not Started |
None |
Document ongoing conditions |
| Task ID |
Task Description |
Owner |
Deadline |
Status |
Dependencies |
Notes |
| 211-COL-MED-1 |
Obtain original media files from Lemons |
Paralegal |
Week 6 |
Not Started |
211-WIT-CONTACT |
Not screenshots |
| 211-COL-EXIF-1 |
Extract and preserve EXIF metadata |
Paralegal |
Week 7 |
Not Started |
211-COL-MED-1 |
Technical preservation |
| 211-COL-COC-1 |
Document chain of custody |
Paralegal |
Week 7 |
Not Started |
211-COL-MED-1 |
From capture to present |
| 211-COL-AUTH-1 |
Obtain Lemons authentication declaration |
Counsel |
Week 8 |
Not Started |
211-COL-COC-1 |
Signed declaration |
| 211-COL-HOLD-1 |
Place in litigation hold folder |
Paralegal |
Week 8 |
Not Started |
211-COL-AUTH-1 |
Preservation complete |
III. FOIL REQUEST TASKS
III.A. NYC Loft Board
| Task ID |
Task Description |
Owner |
Deadline |
Status |
Dependencies |
Notes |
| C001-LB-CONF-1 |
Request August 2018 conference records |
Paralegal |
Week 1 (submit) |
Not Started |
None |
T1 CRITICAL; narrative conference |
| C001-LB-MAR20-1 |
Request March 2020 COVID cancellation docs |
Paralegal |
Week 1 (submit) |
Not Started |
None |
T1 CRITICAL |
| C001-LB-RESCH-1 |
Request post-COVID rescheduling correspondence |
Paralegal |
Week 1 (submit) |
Not Started |
None |
T2 HIGH |
| C001-LB-BLDG-1 |
Request complete building file (226 Franklin/97 Green) |
Paralegal |
Week 1 (submit) |
Not Started |
None |
T2 HIGH |
FOIL Response Timeline: NYC agencies have 5 business days to acknowledge; response typically 20-30 business days. Budget 6-8 weeks total.
III.B. NYC Department of Buildings (DOB)
| Task ID |
Task Description |
Owner |
Deadline |
Status |
Dependencies |
Notes |
| C001-DOB-IMD-1 |
Request IMD status and C of O history |
Paralegal |
Week 1 (submit) |
Not Started |
None |
T1 CRITICAL |
| C001-DOB-VIO-1 |
Request violations history 2013-present |
Paralegal |
Week 1 (submit) |
Not Started |
None |
T2 HIGH |
| C001-DOB-ATLAS-1 |
Request Atlas filing records |
Paralegal |
Week 1 (submit) |
Not Started |
None |
T3 SUPPORTING |
III.C. NYC Housing Court
| Task ID |
Task Description |
Owner |
Deadline |
Status |
Dependencies |
Notes |
| C001-HP-DOCKET-1 |
Request HP 6086/2020 complete docket |
Counsel |
Week 1 (submit) |
Not Started |
None |
T1 CRITICAL; all filings |
Note: Housing Court records may be obtained faster through direct court records request than FOIL. Coordinate with counsel.
IV. WITNESS COORDINATION TASKS
IV.A. Expert Witness Retention
| Task ID |
Task Description |
Owner |
Deadline |
Status |
Dependencies |
Notes |
| C002-WIT-EXP-1 |
Formally retain Olmsted as expert |
Counsel |
Week 2 |
In Progress |
None |
Engagement letter |
| C002-WIT-EXP-2 |
Provide Olmsted with updated materials |
Paralegal |
Week 3 |
Not Started |
C002-WIT-EXP-1 |
WT-106-111 series |
| C002-WIT-EXP-3 |
Obtain Olmsted updated declaration |
Counsel |
Week 6 |
Not Started |
C002-WIT-EXP-2 |
Current conditions |
| C002-WIT-FIN-1 |
Identify and retain financial expert (rent) |
Counsel |
Week 8 |
Not Started |
None |
For rent restitution if needed |
| Task ID |
Task Description |
Owner |
Deadline |
Status |
Dependencies |
Notes |
| 209-WIT-CONTACT |
Contact Christopher Kauch |
Paralegal |
Week 2 |
In Progress |
None |
F1 Position 1 |
| 210-WIT-CONTACT |
Contact Jason Fesel |
Paralegal |
Week 2 |
Not Started |
None |
F1 Position 3 |
| 211-WIT-CONTACT |
Contact Nicholas Lemons |
Paralegal |
Week 2 |
Not Started |
None |
F1 Position 4; media |
| C002-WIT-SAND-1 |
Coordinate with Margaret Sandercock |
Counsel |
Week 4 |
Not Started |
210-WIT-CONTACT |
Fesel's counsel |
| Task ID |
Task Description |
Owner |
Deadline |
Status |
Dependencies |
Notes |
| C002-WIT-ENV-1 |
Prepare Kowalewski deposition outline |
Counsel |
Week 8 |
Not Started |
None |
PRV signatory |
| C002-WIT-ENV-2 |
Prepare Glass deposition outline |
Counsel |
Week 8 |
Not Started |
None |
PRV co-signatory |
| C002-WIT-SERV-1 |
Prepare Coleman deposition outline |
Counsel |
Week 8 |
Not Started |
None |
SERVPRO scope execution |
| C002-WIT-INS-1 |
Prepare Katz deposition outline |
Counsel |
Week 8 |
Not Started |
None |
Pre-inspection staging |
V. FILING PREPARATION TASKS
V.A. Petition Drafting
| Task ID |
Task Description |
Owner |
Deadline |
Status |
Dependencies |
Notes |
| C002-FIL-PET-1 |
Draft OATH harassment petition |
Counsel |
Week 9 |
Not Started |
T1 evidence collected |
Primary filing document |
| C002-FIL-AFF-1 |
Prepare Gray verification affidavit |
Counsel |
Week 9 |
Not Started |
C002-FIL-PET-1 |
Sworn statement |
| C002-FIL-EXH-1 |
Compile and organize exhibit binder |
Paralegal |
Week 9 |
Not Started |
T1 evidence collected |
Per C001 exhibit framework |
| C002-FIL-REV-1 |
Counsel review of complete filing package |
Counsel |
Week 10 |
Not Started |
All filing components |
Final quality check |
| C002-FIL-SVC-1 |
Prepare service package for respondent |
Paralegal |
Week 10 |
Not Started |
C002-FIL-REV-1 |
Copy for service |
| C002-FIL-SUB-1 |
File petition with Loft Board |
Counsel |
Week 11 |
Not Started |
C002-FIL-REV-1 |
Submission |
VI. HEARING PREPARATION TASKS
VI.A. Pre-Hearing Tasks
| Task ID |
Task Description |
Owner |
Deadline |
Status |
Dependencies |
Notes |
| C002-HRG-CONF-1 |
Prepare for Loft Board pre-hearing conference |
Counsel |
TBD |
Not Started |
Filing complete |
After scheduling |
| C002-HRG-DISC-1 |
Prepare discovery requests if authorized |
Counsel |
TBD |
Not Started |
Conference complete |
As permitted |
| C002-HRG-WIT-1 |
Prepare witness testimony outlines |
Counsel |
TBD |
Not Started |
Hearing scheduled |
All witnesses |
| C002-HRG-EXH-1 |
Prepare exhibit list and authentication |
Paralegal |
TBD |
Not Started |
Hearing scheduled |
For ALJ |
| C002-HRG-BRIEF-1 |
Prepare pre-hearing brief if required |
Counsel |
TBD |
Not Started |
Hearing scheduled |
Per ALJ order |
VII. DEPOSITION COORDINATION
VII.A. Phase 1 - Critical (Weeks 8-10)
| Witness |
Type |
Est. Duration |
Topics |
Priority |
| Edward Olmsted |
Expert |
2-3 hours |
Baseline findings; PRV contradictions; methodology |
CRITICAL |
| Martin Kofman |
Adverse |
3-4 hours |
Decision authority; scope instructions; affidavit knowledge |
CRITICAL |
| David Skaller |
Adverse |
2-3 hours |
"Inaccurate" context; affidavit preparation |
CRITICAL |
VII.B. Phase 2 - High (Weeks 10-12)
| Witness |
Type |
Est. Duration |
Topics |
Priority |
| Christopher Kauch |
Fact |
2 hours |
F1 conditions; complaints; buyout |
HIGH |
| Jason Fesel |
Fact |
2 hours |
Health impacts; litigation; settlement |
HIGH |
| Candice Kowalewski |
Fact |
2-3 hours |
PRV process; termination circumstances |
HIGH |
| Raheem Coleman |
Fact |
2 hours |
Scope execution; instructions received |
HIGH |
| Evan Katz |
Fact |
2-3 hours |
Pre-inspection meeting; staging |
HIGH |
VII.C. Phase 3 - Supporting (As Needed)
| Witness |
Type |
Est. Duration |
Topics |
Priority |
| Jack Glass |
Fact |
1-2 hours |
PRV co-signatory; findings |
SUPPORTING |
| Nicholas Lemons |
Fact |
1-2 hours |
Media authentication; conditions |
SUPPORTING |
| Julian Rivera |
Fact |
1-2 hours |
Total Restoration work |
SUPPORTING |
| Chris Roussis |
Fact |
1-2 hours |
Total Restoration work |
SUPPORTING |
| Margaret Sandercock |
Counsel (Fesel) |
1 hour |
Fesel case context |
SUPPORTING |
VII.D. Deposition Summary
| Phase |
Witness Count |
Estimated Hours |
Timeline |
| Phase 1 |
3 |
7-10 hours |
Weeks 8-10 |
| Phase 2 |
5 |
10-15 hours |
Weeks 10-12 |
| Phase 3 |
5 |
5-9 hours |
As needed |
| TOTAL |
13 |
22-34 hours |
|
VIII. TIMELINE SUMMARY
VIII.A. Week-by-Week Overview
| Week |
Key Milestones |
| 1 |
FOIL requests submitted (all agencies); Court records requests initiated |
| 2 |
COVID orders documented; Expert retention confirmed; F1 witness contact initiated |
| 3 |
Expert materials provided; Witness contact continues |
| 4 |
Court records expected; Sandercock coordination |
| 5-6 |
F1 chain evidence collection; FOIL responses begin arriving |
| 7 |
T1 evidence collection complete (target); EXIF/authentication work |
| 8 |
Phase 1 depositions begin; Discovery subpoenas if needed |
| 9 |
Petition drafting; Exhibit compilation |
| 10 |
Counsel review; Phase 1/2 depositions continue |
| 11 |
Filing; Service on respondent |
| 12+ |
Hearing preparation; Phase 2/3 depositions as scheduled |
VIII.B. Critical Milestones
| Milestone |
Target Week |
Status |
Dependencies |
| FOIL requests submitted |
Week 1 |
Not Started |
None |
| Expert retention confirmed |
Week 2 |
In Progress |
C002-WIT-EXP-1 |
| Court records collected |
Week 4 |
Not Started |
B006-TRNS-LOC-1, B006-AFF-COL-1 |
| T1 evidence complete |
Week 7 |
Not Started |
Multiple |
| Phase 1 depositions complete |
Week 10 |
Not Started |
Witness scheduling |
| Petition filed |
Week 11 |
Not Started |
All prerequisites |
IX. BUDGET CONSIDERATIONS
IX.A. Court Costs
| Item |
Estimated Cost |
Notes |
| HP transcript (certified) |
$200-400 |
Based on page count |
| Certified copies (affidavits, Stipulation) |
$50-100 |
Court fees |
| Loft Board filing fee |
$50-100 |
Verify current schedule |
| Subtotal - Court Costs |
$300-600 |
|
IX.B. Deposition Costs
| Item |
Estimated Cost |
Notes |
| Court reporter (22-34 hours) |
$3,000-5,000 |
At ~$150/hour |
| Transcript costs |
$2,000-4,000 |
At ~$4-6/page |
| Videography (if elected) |
$2,000-4,000 |
Optional |
| Subtotal - Depositions |
$5,000-13,000 |
|
IX.C. Expert Costs
| Item |
Estimated Cost |
Notes |
| Olmsted retention/consultation |
$3,000-5,000 |
Estimate |
| Updated declaration/report |
$1,000-2,000 |
Estimate |
| Hearing testimony preparation |
$1,000-2,000 |
Estimate |
| Subtotal - Expert |
$5,000-9,000 |
|
IX.D. Total Estimated Budget
| Category |
Low Estimate |
High Estimate |
| Court Costs |
$300 |
$600 |
| Depositions |
$5,000 |
$13,000 |
| Expert |
$5,000 |
$9,000 |
| TOTAL |
$10,300 |
$22,600 |
Note: These are rough estimates. Actual costs will vary based on case developments, witness availability, and procedural requirements. Does not include attorney fees.
X. RISK MITIGATION
X.A. Identified Risks
| Risk |
Likelihood |
Impact |
Mitigation |
| FOIL delays |
Medium |
Medium |
Submit early; follow up proactively; proceed with available evidence |
| Court records unavailable |
Low |
High |
WT-106 provides foundation; note pending records in filing |
| Witness uncooperative |
Low |
Medium |
Have backup witnesses; document outreach attempts |
| Expert unavailable |
Low |
High |
Confirm availability before formal engagement |
X.B. Contingency Planning
| Scenario |
Contingency |
| HP transcript unavailable |
Proceed with WT-106 Section C summary; note transcript pending |
| Loft Board records delayed |
File with records pending; supplement when received |
| F1 witness declines |
Document pattern through other sources; note limitation |
| Expert scheduling conflict |
Retain backup expert; extend timeline if necessary |
XI. STATUS DASHBOARD
XI.A. Overall Progress
| Metric |
Value |
| Total Tasks |
52 |
| Complete |
0 (0%) |
| In Progress |
4 (8%) |
| Not Started |
48 (92%) |
| Blocked |
0 (0%) |
| Estimated Weeks to Filing |
10-12 |
XI.B. Category Progress
| Category |
Progress |
| Evidence Collection |
0/19 (0%) |
| FOIL Requests |
0/8 (0%) |
| Witness Coordination |
0/14 (0%) |
| Filing Preparation |
0/6 (0%) |
| Hearing Preparation |
0/5 (0%) |
XI.C. Critical Path Status
| Milestone |
Target |
Status |
| FOIL requests submitted |
Week 1 |
Not Started |
| T1 Evidence collected |
Week 7 |
Not Started |
| Expert retained |
Week 2 |
In Progress |
| Petition drafted |
Week 10 |
Not Started |
| Filing complete |
Week 11 |
Not Started |
XII. CURRENT STATUS - ONGOING DISPLACEMENT
Critical Context for All Tasks:
Christian Gray has been displaced from G21 for more than six years since the October 2019 flood. The unit remains uninhabitable. This is not a historical dispute - it is ongoing harassment.
All tasks in this roadmap are directed toward:
- Documenting the harassment (evidence collection)
- Proving the pattern (witness coordination)
- Obtaining relief (OATH filing and hearing)
- Ending the displacement (ultimate goal)
Time is of the essence. Every week of delay extends the tenant's displacement.
END — Red-OATH Tab C002 — Implementation Roadmap Task Tracking v1.4