Box No. 1a
Legal
1.1
Ø
Application
by IWS for Farmersville proposal
Ø
NYSDEC
comment letter record of compliance for IWS
Ø
Enforcement
Directives-NYSDEC Record of Compliance Enforcement Guide Memorandum 7/15/91
1.2
Ø
IWS
Financial Support of Landcom Bid (Heitzenrater) to Judge McGuire
Ø
Law
office of Gary A. Abraham letter to the clerk of U.S District Court in
Syracuse, NY containing data about Allegany, NY precipitation 2001
Ø
U.S
EPA Freedom of Information Request by Gary Abraham
Ø
Gary
Abraham letter to Kenneth C. Taft, summary and comments about Farmersville
landfill from Concerned Citizens of Cattaraugus County (CCCC)
Ø
(Empty)
envelopes from Gary Abraham addressed to various landfill participants
Ø
Arnold
and Porter LLP multi-address telefax transmission sheet
Ø
NYSDEC
fax transmittal sheet, 2004, to IWS from Judge Kevin J. Casutto
Ø
NYSDEC
legislature hearing session comments 5/05/04
Ø
Distribution
list in the Matter of IWS, NYSDEC Application No. 9-0438-0004/000014
Ø
NYSDEC
draft report to Judge Kevin J. Casutto
Ø
Letter
from Judy Drabicki to Judge Casutto about her position as counsel for
Chautauqua County at IWS application proceeding
Ø
URS
Corporation Project Manager Robert R. Henschel to Arnold and Porter LLP on IWS
facility Part 360 permit application
Ø
Application
for access to records from NYSDEC from Gary Abraham
Ø
Letter
from Duke, Holzman, Yaeger, and Photiadis LLP to Judge Casutto enclosing CD-ROM
containing the text of Part 360 permit application
Ø
URS
letter to Judge Casutto enclosing CD-ROM on evaluation of groundwater
Ø
Arnold
and Porter LLP letter to Duke, Holzman, Yaeger, and Photiadis LLP on air
quality submissions
Ø
Arnold
and Porter LLP letter to Judge Casutto on administrative matters
Ø
Arnold
and Porter LLP 2004 letter to Judge Casutto on IWS failure to submit permit
application
Ø
NYSDEC
to IWS---Notice of Incomplete Application 7/28/04
Ø
Duke,
Holzman, Yaeger, and Photiadis LLP letter to URS
Ø
Duke,
Holzman, Yaeger, and Photiadis LLP update to Judge Casutto on IWS permit
Ø
Letter
from Judy Drabicki, counsel for Chautauqua County, to Judge Casutto on response
to public comments
Ø
Duke,
Holzman, Yaeger, and Photiadis LLP letter to Judge Casutto on behalf of IWS on
judge’s 8/04/04 memorandum
Ø
Cattaraugus
County planning board letter to Kenneth Taft, NYSDEC request to deny IWS a
permit
Ø
Arnold
and Porter LLP---Municipal Objectors response to Ambient Air Quality Impact
Analysis to Judge Casutto 6/17/04
Ø
Duke,
Holzman, Yaeger, and Photiadis LLP letter to Judge Casutto enclosing copy of
IWS Article 24 Freshwater Wetlands Permit application
Ø
Saint
Bonaventure University draft resolution, Mary Bernstein, County legislature
1.3
Ø
NYSDEC
statement in support of Request for Full Party Status and Adjudication Hearing
brief on behalf of CCCC
Ø
Berle,
Kass, and Case letter to Judge O’Connor requesting adjudicatory hearing in
Farmersville lawsuit
Ø
University
at Buffalo professor letter to Judge O’Connor requesting amicus status on
Farmersville lawsuit
Ø
Appeal
of the denial of amicus status for Concerned Professionals in IWS permit matter
Ø
Arnold
and Porter LLP letter to Judge Marsh on appeal of party status and Farmersville
project
Ø
Dan
Spitzer memorandum to Gary Abraham 7/14/97
1.4
Ø
NYS
Supreme Court CCCC vs. Town of Farmersville and IWS Decision and Judgments
Ø
Farmersville
Town Budget 2001
Ø
Article
V---Town reviewed permits and contract renewal
Ø
Contract
agreement between IWS and Town of Farmersville
Ø
Town
of Farmersville article definitions pursuant to IWS landfill proposal
Ø
Farmersville
amendment no. 2, local law no. 3, Solid Waste Disposal law
Ø
Letter
from Susan Holmes, Town Clerk of Farmersville, to NY Dept. of State enclosing
Farmersville landfill law
Ø
Precedent
cases for Farmersville situation
Ø
Gary
Abraham notes
Ø
Federal
validation statements pertaining to sale of IWS landfill site
Ø
Eminent
Domain---Excess property
Ø
Acquisition
of vested rights in land development
Ø
Domain
authority
Ø
City
of Utica v. Damiano
Ø
Eminent
Domain proceeding notes 1994
Ø
Eminent
Domain Procedure Law, decision of the fifth court statutory notes---Practice
comments
Ø
Cattaraugus
County memorandum resolution 9/14/94
Ø
Proceedings
of the Board of Legislatures Act No. 147-2000, Cattaraugus County Landfill Law
Ø
Facsimile
transmittal---Solid Waste Local Law
1.5
Ø
(2)
white legal note pads---DEC staff handwritten comments on DEIS
Ø
(2)
yellow legal note pads---CCCC meeting notes
1.6
Ø
Law
offices of Gary Abraham---Freedom of Information Request
Ø
Gary
A. Abraham, “Local Resolution of Waste Management and the Landfill Crisis”
Ø
Tom
Noswortly, Town Supervisor, Wallkill, NY
Ø
Gary
A. Abraham, “The Rural Garbage Crisis and Solid Waste Management Authorities in
NY”
1.7
Ø
Letter
to Judge Casutto from a Mr. Heintz, on his well water in Franklinville, NY
Ø
Arnold
and Porter LLP letter to Judge Casutto on Response to Slope Stability Report
Ø
NYS
Supreme Court briefs: Cattaraugus County v. Town of Farmersville and IWS
Ø
Oral
argument notes 9/14/95
Ø
CCCC
v. Farmersville and IWS Motion For Leave to Appeal (packet with blue cover)
Ø
NYS
Supreme Court Appearance document
Ø
Oliver
and Oliver final draft memorandum 1/14/93 to Judge Casutto on behalf of NYPIRG
Not
in folder:
Ø
(2
large books) “In the State of NY: Supreme Court Appellate Division, Fourth
Department” CCCC vs. Town Board of Farmersville and IWS, Index No. 54876 and
No. 56036. Appendix Vol. I P. 1-457 and Vol. II P. 458-1,001----word for word
court briefs
1.8
Ø
Kathy
Kellogg of CCCC Deposition No. 1---Kathy Kellogg vs. Town Board of Farmersville
and IWS
1.9
Ø
Kathy
Kellogg of CCCC Deposition No. 2---Kathy Kellogg vs. Town Board of Farmersville
and IWS
1.10
Ø
Kathy
Kellogg of CCCC Deposition No. 3---Kathy Kellogg vs. Town Board of Farmersville
and IWS
1.11
Ø
11/19/91
Supreme Court, Olean, NY. 10/08/91 Court Hearing---Notes on proceedings in
court
Ø
3/12/93
Allen, Lippes, and Shonn letter to Nils Olsen, University at Buffalo
Ø
Allen,
Lippes, and Shonn letter to CCCC about confidential client information
Ø
CCCC
v. Farmersville appeal documents
1.12
Ø
Scoping
comments No. 3 from Moritary and Swanz, Allen, Lippes, and Shonn
Ø
Misc.
copies of early lawsuit pleadings
Ø
General
correspondence between law firms---Allen, Lippes, and Shonn and Moriarty and
Swanz, between 1991 and 1993 as well as Duke, Holzman, Yates
Ø
Town
of Farmersville petitions from Allen, Lippes, and Shonn
1.13
Ø
Scoping
comments No. 3 from Moritary and Swanz, Allen, Lippes, and Shonn
Ø
Misc.
copies of early lawsuit pleadings
Ø
General
correspondence between law firms---Allen, Lippes, and Shonn and Moriarty and
Swanz, between 1991 and 1993 as well as Duke, Holzman, Yates
Ø
Town
of Farmersville petitions from Allen, Lippes, and Shonn
1.14
Ø
Scoping
comments No. 3 from Moritary and Swanz, Allen, Lippes, and Shonn
Ø
Misc.
copies of early lawsuit pleadings
Ø
General
correspondence between law firms---Allen, Lippes, and Shonn and Moriarty and
Swanz, between 1991 and 1993 as well as Duke, Holzman, Yates
Ø
Town
of Farmersville petitions from Allen, Lippes, and Shonn
1.15
Ø
Scoping
comments No. 3 from Moritary and Swanz, Allen, Lippes, and Shonn
Ø
Misc.
copies of early lawsuit pleadings
Ø
General
correspondence between law firms---Allen, Lippes, and Shonn and Moriarty and
Swanz, between 1991 and 1993 as well as Duke, Holzman, Yates
Ø
Town
of Farmersville petitions from Allen, Lippes, and Shonn