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Box No. 1a

Legal

1.1

  Application by IWS for Farmersville proposal

  NYSDEC comment letter record of compliance for IWS

  Enforcement Directives-NYSDEC Record of Compliance Enforcement Guide Memorandum 7/15/91

1.2

  IWS Financial Support of Landcom Bid (Heitzenrater) to Judge McGuire

  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

  U.S EPA Freedom of Information Request by Gary Abraham

  Gary Abraham letter to Kenneth C. Taft, summary and comments about Farmersville landfill from Concerned Citizens of Cattaraugus County (CCCC)

  (Empty) envelopes from Gary Abraham addressed to various landfill participants

  Arnold and Porter LLP multi-address telefax transmission sheet

  NYSDEC fax transmittal sheet, 2004, to IWS from Judge Kevin J. Casutto

  NYSDEC legislature hearing session comments 5/05/04

  Distribution list in the Matter of IWS, NYSDEC Application No. 9-0438-0004/000014

  NYSDEC draft report to Judge Kevin J. Casutto

  Letter from Judy Drabicki to Judge Casutto about her position as counsel for Chautauqua County at IWS application proceeding

  URS Corporation Project Manager Robert R. Henschel to Arnold and Porter LLP on IWS facility Part 360 permit application

  Application for access to records from NYSDEC from Gary Abraham

  Letter from Duke, Holzman, Yaeger, and Photiadis LLP to Judge Casutto enclosing CD-ROM containing the text of Part 360 permit application

  URS letter to Judge Casutto enclosing CD-ROM on evaluation of groundwater

  Arnold and Porter LLP letter to Duke, Holzman, Yaeger, and Photiadis LLP on air quality submissions

  Arnold and Porter LLP letter to Judge Casutto on administrative matters

  Arnold and Porter LLP 2004 letter to Judge Casutto on IWS failure to submit permit application

  NYSDEC to IWS---Notice of Incomplete Application 7/28/04

  Duke, Holzman, Yaeger, and Photiadis LLP letter to URS

  Duke, Holzman, Yaeger, and Photiadis LLP update to Judge Casutto on IWS permit

  Letter from Judy Drabicki, counsel for Chautauqua County, to Judge Casutto on response to public comments

  Duke, Holzman, Yaeger, and Photiadis LLP letter to Judge Casutto on behalf of IWS on judges 8/04/04 memorandum

  Cattaraugus County planning board letter to Kenneth Taft, NYSDEC request to deny IWS a permit

  Arnold and Porter LLP---Municipal Objectors response to Ambient Air Quality Impact Analysis to Judge Casutto 6/17/04

  Duke, Holzman, Yaeger, and Photiadis LLP letter to Judge Casutto enclosing copy of IWS Article 24 Freshwater Wetlands Permit application

  Saint Bonaventure University draft resolution, Mary Bernstein, County legislature

1.3

  NYSDEC statement in support of Request for Full Party Status and Adjudication Hearing brief on behalf of CCCC

  Berle, Kass, and Case letter to Judge OConnor requesting adjudicatory hearing in Farmersville lawsuit

  University at Buffalo professor letter to Judge OConnor requesting amicus status on Farmersville lawsuit

  Appeal of the denial of amicus status for Concerned Professionals in IWS permit matter

  Arnold and Porter LLP letter to Judge Marsh on appeal of party status and Farmersville project

  Dan Spitzer memorandum to Gary Abraham 7/14/97

1.4

  NYS Supreme Court CCCC vs. Town of Farmersville and IWS Decision and Judgments

  Farmersville Town Budget 2001

  Article V---Town reviewed permits and contract renewal

  Contract agreement between IWS and Town of Farmersville

  Town of Farmersville article definitions pursuant to IWS landfill proposal

  Farmersville amendment no. 2, local law no. 3, Solid Waste Disposal law

  Letter from Susan Holmes, Town Clerk of Farmersville, to NY Dept. of State enclosing Farmersville landfill law

  Precedent cases for Farmersville situation

  Gary Abraham notes

  Federal validation statements pertaining to sale of IWS landfill site

  Eminent Domain---Excess property

  Acquisition of vested rights in land development

  Domain authority

  City of Utica v. Damiano

  Eminent Domain proceeding notes 1994

  Eminent Domain Procedure Law, decision of the fifth court statutory notes---Practice comments

  Cattaraugus County memorandum resolution 9/14/94

  Proceedings of the Board of Legislatures Act No. 147-2000, Cattaraugus County Landfill Law

  Facsimile transmittal---Solid Waste Local Law

1.5

  (2) white legal note pads---DEC staff handwritten comments on DEIS

  (2) yellow legal note pads---CCCC meeting notes

1.6

  Law offices of Gary Abraham---Freedom of Information Request

  Gary A. Abraham, Local Resolution of Waste Management and the Landfill Crisis

  Tom Noswortly, Town Supervisor, Wallkill, NY

  Gary A. Abraham, The Rural Garbage Crisis and Solid Waste Management Authorities in NY

1.7

  Letter to Judge Casutto from a Mr. Heintz, on his well water in Franklinville, NY

  Arnold and Porter LLP letter to Judge Casutto on Response to Slope Stability Report

  NYS Supreme Court briefs: Cattaraugus County v. Town of Farmersville and IWS

  Oral argument notes 9/14/95

  CCCC v. Farmersville and IWS Motion For Leave to Appeal (packet with blue cover)

  NYS Supreme Court Appearance document

  Oliver and Oliver final draft memorandum 1/14/93 to Judge Casutto on behalf of NYPIRG

 

Not in folder:

  (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

  Kathy Kellogg of CCCC Deposition No. 1---Kathy Kellogg vs. Town Board of Farmersville and IWS

1.9

  Kathy Kellogg of CCCC Deposition No. 2---Kathy Kellogg vs. Town Board of Farmersville and IWS

1.10

  Kathy Kellogg of CCCC Deposition No. 3---Kathy Kellogg vs. Town Board of Farmersville and IWS

1.11

  11/19/91 Supreme Court, Olean, NY. 10/08/91 Court Hearing---Notes on proceedings in court

  3/12/93 Allen, Lippes, and Shonn letter to Nils Olsen, University at Buffalo

  Allen, Lippes, and Shonn letter to CCCC about confidential client information

  CCCC v. Farmersville appeal documents

1.12

  Scoping comments No. 3 from Moritary and Swanz, Allen, Lippes, and Shonn

  Misc. copies of early lawsuit pleadings

  General correspondence between law firms---Allen, Lippes, and Shonn and Moriarty and Swanz, between 1991 and 1993 as well as Duke, Holzman, Yates

  Town of Farmersville petitions from Allen, Lippes, and Shonn

1.13

  Scoping comments No. 3 from Moritary and Swanz, Allen, Lippes, and Shonn

  Misc. copies of early lawsuit pleadings

  General correspondence between law firms---Allen, Lippes, and Shonn and Moriarty and Swanz, between 1991 and 1993 as well as Duke, Holzman, Yates

  Town of Farmersville petitions from Allen, Lippes, and Shonn

1.14

  Scoping comments No. 3 from Moritary and Swanz, Allen, Lippes, and Shonn

  Misc. copies of early lawsuit pleadings

  General correspondence between law firms---Allen, Lippes, and Shonn and Moriarty and Swanz, between 1991 and 1993 as well as Duke, Holzman, Yates

  Town of Farmersville petitions from Allen, Lippes, and Shonn

1.15

  Scoping comments No. 3 from Moritary and Swanz, Allen, Lippes, and Shonn

  Misc. copies of early lawsuit pleadings

  General correspondence between law firms---Allen, Lippes, and Shonn and Moriarty and Swanz, between 1991 and 1993 as well as Duke, Holzman, Yates

  Town of Farmersville petitions from Allen, Lippes, and Shonn

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