Agenda for Cusenza Deposition

Objectives - What I want to learn

Learn about legal actions between J. C. Klein and 55 Liberty.

What 55 Liberty Street files are at J. C. Klein?

Produce them.

What was Cusenza’s and J. C. Klein’s involvement in Phillip’s Deposition

[When he took over] How did Cusenza come to be informed about that facts of #17C.

What is his understanding of the facts about the damage.

Did he ever see Joselow’s letter?

What repairs were performed at # 17C.

What records are kept.

Who keeps them.

Where are they stored.

Where are they now?

What kind of offers to Koenig were contemplated in 1991 - 1993.

Records:

Plumbing Records

Plumbing Invoices:  How are they kept?


Exhibit “_”: Joseph Cusenza’s May 15 1995 letter to Koenig



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