Winfield et al v. City Of New York

Filing 660

OPINION AND ORDER. The Court appends a spreadsheet reflecting the Court's rulings on the 500 documents. The Court also includes its own description of the documents in column R. The City is directed to re-review its privilege log consistent w ith this ruling and determine whether there are additional documents on its log that must be de-designated as privileged. The City shall complete this task by January 31, 2019 and provide Plaintiffs with an updated log and supplemental production by that date. To the extent there are objections to this ruling, or Plaintiffs believe that the Court should re-evaluate the balance of Rodriguez factors or wish to make a substantial need argument as to a specific document protected by the work p roduct doctrine, this Court requests that the parties first file a motion for reconsideration with this Court. The parties shall notify the Court by letter if they intend to request reconsideration of a ruling as to a particular document by Decemb er 31, 2018. The Court will then set a briefing schedule as to any such motion. To the extent the City does not dispute this Courts ruling with respect to documents deemed non-privileged, it shall produce such documents by January 31, 2019. SO ORDERED. (Signed by Magistrate Judge Katharine H. Parker on 12/18/2018) (anc)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-----------------------------------------------------------------X
SHAUNA NOEL, et al
Plaintiffs,

12-18-18

OPINION AND ORDER
15-cv-05236 (LTS) (KHP)

-againstCITY OF NEW YORK,
Defendant.
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KATHARINE H. PARKER, UNITED STATES MAGISTRATE JUDGE:

Plaintiffs commenced this action to challenge a New York City policy regarding
affordable housing lotteries. The City’s policy allocates 50% of units in affordable housing
lotteries to individuals who already reside in the community district where the new affordable
housing units are located. This policy is referred to herein as the “Community Preference
Policy.” Plaintiffs allege that the Community Preference Policy violates the federal Fair Housing
Act (“FHA”), 42 U.S.C. § 3604 et seq., and the New York City Human Rights Law (“NYCHRL”), NYC
Admin. Code § 8-107, et seq., because it perpetuates racial segregation and disparately impacts
racial minorities. They also claim that the City’s decision to establish, expand, and maintain the
policy constitutes intentional discrimination.
Currently pending before this Court is Plaintiffs’ motion challenging privilege
designations on 500 documents in the City’s privilege log. The City asserts that the documents
are protected from disclosure based on one or more of the following reasons: (1) attorneyclient privilege, (2) work product protection, (3) deliberative process privilege, and (4)
1

legislative privilege. This Court assumes the reader’s familiarity with the factual background of
this case based on its many decisions in this action and does not repeat it here. See Winfield v.
City of New York, No. 15-cv-5236 (LTS) (KHP), 2017 WL 5664852, at *1-6 (S.D.N.Y. Nov. 27,
2017); Winfield v. City of New York, No. 15-cv-5236 (LTS) (DCF), 2016 WL 6208564, at *1-3
(S.D.N.Y. Oct. 24, 2016); see also Winfield v. City of New York, No. 15-cv-5236 (LTS) (KHP), 2017
WL 2880556, at *1-2 (S.D.N.Y. July 5, 2017), objections overruled by, 2017 WL 5054727, at *1-2
(S.D.N.Y. Nov. 2, 2017).
The City submitted for in camera review a detailed privilege log with hyperlinks to all
500 documents and, in some cases, cover emails for the documents. The City also submitted a
series of letters at this Court’s request providing greater detail as to the basis for the assertion
of privilege as to certain documents and categories of documents. In addition, after questions
by the Court as to certain documents, the City withdrew its privilege designations and elected
to produce these documents.1
In addition, the Court is in receipt of the ruling of the Honorable Laura Taylor Swain
dated December 12, 2018 setting aside this Court’s February 2018 Order insofar as it addressed
claims of deliberative process privilege. See ECF Nos. 259, 655. This Court has, consistent with
Judge Swain’s ruling, evaluated the City’s claims of deliberative process privilege and whether
disclosure is warranted under the factors set forth in Rodriguez v. Pataki, 280 F. Supp.2d 89, 99-

1

The documents the City has decided to produce are identified on the privilege log in column A as numbers: 1, 5,
13, 14, 24, 65, 66, 72, 74, 75, 95, 106, 107, 108, 119, 124, 125, 130, 147, 233, 255, 303, 307, 328, 333, 341, 345,
353, 354, 360, 362, 372, 373, 374, 376, 378, 380, 382, and 499. Certain of these documents will be produced in
redacted format.

2

101 (S.D.N.Y. 2003), in the manner prescribed by Judge Swain. This Court has adopted the
same methodology for evaluating whether documents subject to the legislative privilege should
nevertheless be produced pursuant to the Rodriguez balancing factors. Because this Court has
previously set forth the standards governing applicability of the attorney-client privilege and
work product privilege, it does not repeat them in detail here and refers the parties to the
Court’s prior decision. See ECF No. 259.
The Court has carefully reviewed all of the submissions by the parties and all 500
documents. In the interest of brevity and expediency, the Court does not discuss its reasoning
as to each of the 500 documents here. Instead, the Court discusses treatment of certain
categories of documents and provides an annotated spreadsheet providing additional
information about each document and its rulings as to each.
Discussion
I.

Attorney-Client Privilege
The attorney-client privilege “exists for the purpose of encouraging full and truthful

communications between an attorney and his client and ‘recognizes that sound legal advice or
advocacy serves public ends and that such advice or advocacy depends upon the lawyer’s being
fully informed by the client.’” In re Von Bulow, 828 F.2d 94, 100 (2d Cir. 1987) (quoting Upjohn
Co. v. United States, 449 U.S. 383, 389 (1981)). The party seeking to invoke the privilege bears
the burden of establishing its applicability. In re Cty. of Erie, 473 F.3d 413, 418 (2d Cir. 2007).
To do this, the governmental party claiming attorney-client privilege must establish: (1) a
communication between government counsel and their clients, (2) that was intended to be and
3

was in fact kept confidential, and (3) was made for the purpose of obtaining or providing legal
advice. See id. at 419 (internal citation omitted). As to factor 3, the key inquiry is whether the
“predominant purpose” of the communication is to solicit or provide legal advice. Id. at 419-20
(collecting cases). When legal advice is the predominant purpose, “other ‘considerations and
caveats’ are not severable and the entire communication is privileged.” Fox News Network, LLC
v. US Dep’t of Treasury, 739 F. Supp. 2d 515, 560 (citing In re Cty. of Erie, 473 F.3d at 420). On
the other hand, if the legal advice is merely “incidental to the nonlegal advice that is the
predominant purpose of the communication,” then the legal portions of the document may be
redacted. In re Cty. of Erie, 473 F.3d at 420 n.8.
With these standards in mind, the following documents on the City’s privilege log are
protected by the attorney-client privilege: 3, 4, 18, 19, 22, 23, 25, 262, 27, 38, 29, 30, 31, 32, 33,
35, 36, 37, 38, 39, 40, 42, 44, 51, 53, 59, 60, 69, 70, 71, 80, 92, 93, 94, 96, 97, 98, 100, 109, 110,
113, 114, 120, 122, 123, 126, 136, 139, 140, 142, 159, 163, 175, 178, 190, 193, 194, 216, 218,
232, 235, 238, 239, 240, 241, 242,245, 248, 250, 251, 256, 266, 274, 275, 287, 288, 295, 298,
300, 306, 346, 349, 357, 359, 361, 363, 364, 470, 472, 476, 478, 480, 485. All of these
documents involve communications and draft documents exchanged between attorneys for the
City and their clients for the predominant purpose of seeking or conveying legal advice.
Because the attorney-client privilege applies, the Court does not need to reach any other
privilege asserted. The following documents are not protected by the attorney-client privilege

2

A substantial portion of the communications in this document are not privileged. The City shall produce a
redacted version of this document redacting the limited portions that relate to topics on which legal advice is
sought or given.

4

but, if subject to another privilege, are identified in the appropriate section below: 0, 4, 13, 43,
46, 95, 128, 130, 141, 165, 166, 176, 186, 233, 253, 254, 255, 260, 261, 263, 264, 265, 273, 279,
282, 284, 289, 291, 292, 293, 321, 342, 353, 360, 477, 499. These documents do not reflect
communications or drafts exchanged between attorneys for the City and their clients for the
predominant purpose of seeking or conveying legal advice.
II.

Work Product
The work product doctrine protects a broader category of documents and

communications than the attorney-client privilege. Specifically, it protects documents and
other tangible things “that are prepared in anticipation of litigation or for trial by or for a party
or its representative.” Fed. R. Civ. P. 26(b)(3)(A); see also Bowne of N.Y.C., Inc. v. AmBase Corp.,
150 F.R.D. 465, 471 (S.D.N.Y. 1993). Documents “should be deemed prepared ‘in anticipation
of litigation’ . . . if, ‘in light of the nature of the document and the factual situation in the
particular case, the document can fairly be said to have been prepared or obtained because of
the prospect of litigation.’” United States v. Adlman, 134 F.3d 1194, 1202 (2d Cir. 1998)
(emphasis in original) (internal citation omitted). “Where a document was created because of
anticipated litigation, and would not have been prepared in substantially similar form but for
the prospect of that litigation,” it is protected as work product. Id. at 1195. “Conversely,
protection will be withheld from ‘documents that are prepared in the ordinary course of
business or that would have been created in essentially similar form irrespective of litigation.’”
Schaeffler v. United States, 806 F.3d 34, 43 (2d Cir. 2015) (quoting Adlman, 134 F.3d at 1202).

5

Work product protection, however, is not absolute. A party seeking discovery may
overcome work product protection and obtain disclosure of material otherwise discoverable
under Fed. R. Civ. P. 26(b)(1) by showing (1) substantial need for the material; and (2) an
inability to obtain its substantial equivalent from another source without undue hardship. Fed.
R. Civ. P. 26(b)(3)(A); Obeid v. Mack, No. 14-cv-6498 (LTS) (HBP), 2016 WL 7176653, at *5
(S.D.N.Y. Dec. 9, 2016). Although factual materials “may generally be discovered upon a
showing of substantial need,” Obeid, 2016 WL 7176653, at *5 (internal quotation marks and
citations omitted), courts “must protect against disclosure of the mental impressions,
conclusions, opinions, or legal theories of a party’s attorney or other representative concerning
the litigation.” Fed. R. Civ. P. 26(b)(3)(B) (emphasis added). “Documents or portions of
documents that qualify as ‘opinion work product’ are ‘entitled to virtually absolute protection.’”
United States v. Mount Sinai Hosp., 185 F. Supp. 3d 383, 390 (S.D.N.Y. 2016) (quoting United
States v. Ghavami, 882 F. Supp. 2d 532, 540 (S.D.N.Y. 2012)).
With these standards in mind, the following documents on the City’s privilege log are
protected by the work product doctrine: 6, 7, 8, 10, 11, 15, 16, 17, 47, 61, 76, 77, 78, 79, 81, 82,
85, 86, 89, 104, 118, 127, 129, 131, 133, 134, 135, 137, 138, 141, 149, 150, 151, 153-158, 160,
161, 162, 164, 165, 166, 167, 169, 170, 171, 172, 177, 182, 183, 184, 185, 188, 191, 192, 195201-211, 220-230, 281, 366-371, 375, 377, 379, 381, 383-464, 466-469, 483, 484, 486-493, 498,
500. All of these documents were prepared in anticipation of this litigation or litigation with
the U.S. Department of Housing and Urban Development (“HUD”) and not in the normal course
of business. Of these documents, a number contain mental impressions, analyses or studies,
6

conclusions, opinions, or legal theories of an attorney or other representative of the City
concerning this litigation or potential litigation with HUD over the Community Preference
Policy. A number of the documents were created solely for analyzing settlement positions.
Having reviewed these documents, the Court finds there is no substantial need for the
documents and, indeed, the vast majority reflect core work product that must be protected
regardless under Federal Rule of Civil Procedure 26(b)(3). See Adlman, 134 F.3d at 1196 (The
work product doctrine “is intended to preserve a zone of privacy in which a lawyer can prepare
and develop legal theories and strategy with an eye toward litigation, free from unnecessary
intrusion by his adversaries”) (internal quotation marks omitted).
Additionally, with respect to documents reflecting settlement negotiations, proffers and
strategy, the Court notes that such documents are inadmissible at trial under Federal Rule of
Evidence 408 as evidence of the admission of the validity or invalidity of a claim. Fed. R. Evid.
408. The rationale behind the rule is that settlement proposals are irrelevant, as they “may be
motivated by a desire for peace rather than from any concession of weakness of position” and
“to promote settlement of disputes.” 1972 Advisory Committee Notes to Rule 408; see also
Fed. R. Civ. P. 68 (evidence of an unaccepted offer of judgment is not admissible as evidence of
liability). Rule 408 does permit admission of information that would prove bias of a witness,
negate a contention of undue delay, or prove an effort to obstruct a criminal investigation or
prosecution. Fed. R. Evid. 408; 1972 Advisory Committee Notes to Rule 408. The 2006 Advisory
Committee Notes to Rule 408 explicitly state that the rule “prohibits use of statements made in
settlement negotiations to impeach by prior inconsistent statement or through contradiction.”
7

2006 Advisory Committee Notes to Rule 408 (citing EEOC v. Gear Petroleum, Inc., 948 F.2d 1542
(10th Cir. 1991) (letter sent as part of settlement negotiation cannot be used to impeach
defense witnesses by way of contradiction or prior inconsistent statement; such broad
impeachment would undermine the policy of encouraging uninhibited settlement
negotiations)). Based on this Court’s review of the documents concerning settlement, it is the
Court’s view that they could not be appropriately used for any permitted purpose under
Federal Rule of Evidence 408. Therefore, they are protected from disclosure.
The following documents are not work product: 5, 24, 73, 106, 124, 125, 180, 181, 253,
254, 255, 260, 261, 328, 372, 373, 374, 376, 378, 380, 382, 499. The City acknowledged that
some of these documents were not protected work product. Other documents include final
versions (or portions thereof) of the City’s consolidated plans concerning fair housing submitted
to HUD and a factual communication to the Mayor about the filing of this litigation.
Accordingly, the City must produce these documents to the extent they are not protected by
another privilege. To the extent any of these documents are also marked as being protected by
the deliberative process or legislative privilege, they are addressed below.
III.

Deliberative Process Privilege
The deliberative process privilege, also referred to as the executive privilege, protects

“documents reflecting advisory opinions, recommendations and deliberations comprising part
of a process by which governmental decisions and policies are formulated.” NLRB v. Sears,
Roebuck & Co., 421 U.S. 132, 150 (1975) (internal quotation marks and citation omitted). It
applies to both the ultimate decision-making executive and the executive’s staff members. See
8

Hopkins v. H.U.D., 929 F.2d 81, 85 (2d Cir. 1991) (work product, opinions, and
recommendations of staff are covered by the deliberative process privilege).
To be protected, the documents and communications used in the decision-making
process must be both (1) pre-decisional and (2) deliberative. Marisol A. v. Guiliani, No. 95-cv10533 (RJW), 1998 WL 132810, at *6 (S.D.N.Y. Mar. 23, 1998). This means the document must
be prepared to aid the decisionmaker in arriving at a decision as opposed to communications
that are part of routine agency self-evaluation. See, e.g., Hopkins, 929 F.2d at 84; Marisol A.,
1998 WL 132810, at *6; Tigue v. U.S. Dep’t of Justice, 312 F.3d 70, 80 (2d Cir. 2002); see also
Charles v. City of New York, No. 11-cv-0980 (KAM) (JO), 2011 WL 5838478, at *1 (E.D.N.Y. Nov.
18, 2011).
Even if a document is protected by the deliberative process privilege, a Court may order
disclosure after balancing the following five factors and finding that they weigh in favor of
disclosure: (i) the relevance of the evidence sought to be protected; (ii) the availability of other
evidence; (iii) the ‘seriousness’ of the litigation and the issues involved; (iv) the role of the
government in the litigation; and (v) the possibility of future timidity by government employees
who will be forced to recognize that their secrets are violable. See ECF 655 (citing Rodriguez,
280 F. Supp. 2d at 99-101); see also In re Delphi Corp., 276 F.R.D. 81, 85 (S.D.N.Y. 2011); Five
Borough Bicycle Club v. City of New York, No. 07-cv-2448 (LAK), 2008 WL 4302696, at *1
(S.D.N.Y. Sept. 16, 2008).
With these standards in mind, the following documents on the City’s privilege log are
protected by the deliberative process privilege: 9, 12, 21, 34, 41, 45, 48, 52, 63, 68, 83, 84, 87,
9

88, 90, 91, 103, 105, 115, 116, 117, 132, 143, 145, 146, 148, 152, 168, 174, 176, 187, 189, 202,
215, 217, 234, 236, 237, 243, 244, 246, 249, 252, 257, 258, 262, 267, 268, 270, 271, 272, 276,
277, 278, 280, 283, 285, 286, 290, 293, 294, 296, 301, 305, 308, 314, 315, 316, 317-320, 322,
323, 324, 325, 326, 329, 330, 331, 332, 334, 335, 336, 337, 338, 339, 340, 348, 351, 355, 358,
465, 473, 477, 494, 496, 497. All of these documents precede a policy or other decision by a
City agency and reflect the deliberative process in reaching the decision. See Marisol A., 1998
WL 132810, at *6. None appear to be routine self-evaluation. On the other hand, the following
documents do not reflect any pre-decisional deliberative process and fall into the category of
post-decision communications, post-decision strategy for implementation of decided policy,
factual information or routine self-evaluation by an agency: 20, 54, 56, 57, 58, 64, 101, 111,
112, 144, 212, 213, 214, 247, 297, 304, 310, 313, 341, 343, 350, 356, 465, 471, 475, 479, 495.
Thus, these documents are not protected by the deliberative process privilege and must be
disclosed by the City.
With respect to those documents that are protected by the deliberative process privilege,
the Court has applied the five-factor balancing analysis in the manner prescribe by Judge Swain
in her December 12, 2018 decision and determined that the following documents need not be
produced: 9, 21, 34, 41, 45, 48, 52, 63, 83, 84, 87, 88, 90, 91, 103, 105, 115, 116, 117, 132, 143,
148, 152, 168, 174, 176, 187, 202, 215, 217, 234, 236, 237, 243, 244, 246, 249, 252, 257, 258,
262, 267, 268, 270, 271, 272, 276, 277, 278, 280, 283, 285, 286, 290, 293, 294, 296, 301, 308,
310, 314, 315, 316, 317-320, 322, 323, 324, 325, 326, 329, 330, 331, 332, 334, 335, 336, 337,
338, 339, 340, 348, 473, 477, 494, 496, 497. Many of these documents are drafts that are not
10

relevant or have marginal relevance and thus I give them little weight in the balancing test.
Likewise, the availability of a final policy and other information about a policy weighs against
disclosure. When evaluating the first four factors together against the fifth Rodriguez factor, I
find that the balance of factors weighs against disclosure of these documents.
On the other hand, the five-factor balancing analysis weighs in favor of disclosure as to the
following documents: 12, 68, 145, 146, 189, 277, 305, 351, 355, 358. As to these documents,
the relevance factor weighs heavily in favor of disclosure and outweighs the other factors,
thereby requiring disclosure.
IV.

Legislative Privilege
State and local legislators are entitled to absolute “immunity from liability for their

legislative acts” as a matter of federal common law. Supreme Ct. of Virginia v. Consumers
Union of U.S. Inc., 446 U.S. 719, 732-33 (1980) (citing Tenney v. Brandhove, 341 U.S. 367, 379
(1951)); Bogan v. Scott-Harris, 523 U.S. 44, 48-49 (1988); see also Rodriguez, 280 F. Supp. 2d at
94-95. Courts within the Second Circuit have repeatedly held that state and local lawmakers
are entitled to protection against discovery into their legislative acts in civil cases, explaining
that such protection is needed to “shield legislators from civil proceedings which disrupt and
question their performance of legislative duties to enable them to devote their best efforts and
full attention to the public good.” See, e.g., Searingtown Corp. v. Inc. Vill. of N. Hills, 575 F.
Supp. 1295, 1299 (E.D.N.Y. 1981) (precluding discovery into motivation of local legislators for
rezoning decision that plaintiffs claimed violated their constitutional rights) (internal quotation
marks and citations omitted); ACORN v. Cty. of Nassau, No. 05-cv-2301 (JFB) (WDW), 2007 WL
11

2815810, at *2 (E.D.N.Y. Sept. 25, 2007); see also In Vill. of Arlington Heights v. Metro. Hous.
Dev. Corp., 429 U.S. 252, 267-68 (1977) (recognizing in dicta that the common law legislative
privilege also extends to protection from compelled testimony in civil cases); Star Distribs., Ltd.
v. Marino, 613 F.2d 4, 6-9 (2d Cir. 1980).
Legislative acts that are protected under the privilege include any activity that is an
integral part of the deliberative and communicative processes by which an individual considers
whether to vote for or against a proposal. See Eastland v. U.S. Servicemen’s Fund, 421 U.S. 491,
504 (1975); Bogan, 523 U.S. at 54-55. For example, legislative acts may include, but are not
limited to: “delivering an opinion, uttering a speech, or haranguing in debate; proposing
legislation; voting on legislation; making, publishing, presenting, and using legislative reports;
authorizing investigations and issuing subpoenas; and holding hearings and introducing
material at committee hearings.” S.E.C. v. Comm. On Ways and Means of the U.S. House of
Representatives, 161 F. Supp. 3d 199, 236 (S.D.N.Y. 2015) (citing Fields v. Office of Eddie Bernice
Johnson, 459 F.3d 1, 10-11 (D.C. Cir. 2006)) (internal quotation marks omitted).
The legislative privilege also protects formal and informal fact and informationgathering activities about the subject of potential legislation, as well as documents regarding or
reflecting the fruits of this research. See id. at 236-37, 245; see also United States v. Biaggi, 853
F.2d 89, 102-03 (2d Cir. 1988); McSurely v. McClellan, 553 F.2d 1277, 1286 (D.C. Cir. 1976) (en
banc), cert. dismissed 438 U.S. 189 (1978). The privilege does not attach to activities
concerning the administration of a law, speeches delivered outside of the legislative body and
preparation for the same, the making of appointments with government agencies, and
12

newsletters and press releases to constituents. See U.S. v. Brewster, 408 U.S. 501, 512 (1972);
Hutchinson v. Proxmire, 443 U.S. 111, 130-33 (1979).
Like the deliberative process privilege, the legislative privilege is qualified, and
disclosure may be ordered subject to the same balancing factors applicable to the deliberative
process privilege. Rodriguez, 280 F. Supp. 2d at 96; see also Citizens Union of City of N.Y. v.
Att’y Gen. of N.Y., No. 16-cv-9592 (RMB) (KHP), 2017 WL 3836057, at *18 (S.D.N.Y. Sept. 1,
2017).
Applying these standards, this Court finds that none of the documents the City listed as
protected by the legislative privilege in fact fall within the protection of this privilege. These
documents are: 49, 55, 98, 99, 102, 179, 345. Thus, the City shall produce all of these
documents.
Conclusion
The Court appends a spreadsheet reflecting the Court’s rulings on the 500 documents.
The Court also includes its own description of the documents in column R. The City is directed
to re-review its privilege log consistent with this ruling and determine whether there are
additional documents on its log that must be de-designated as privileged. The City shall
complete this task by January 31, 2019 and provide Plaintiffs with an updated log and
supplemental production by that date.
To the extent there are objections to this ruling, or Plaintiffs believe that the Court
should re-evaluate the balance of Rodriguez factors or wish to make a substantial need
argument as to a specific document protected by the work product doctrine, this Court
13

requests that the parties first file a motion for reconsideration with this Court. The parties shall
notify the Court by letter if they intend to request reconsideration of a ruling as to a particular
document by December 31, 2018. The Court will then set a briefing schedule as to any such
motion. To the extent the City does not dispute this Court’s ruling with respect to documents
deemed non-privileged, it shall produce such documents by January 31, 2019.

SO ORDERED.
Dated: December 18, 2018
New York, New York

______________________________
KATHARINE H. PARKER
United States Magistrate Judge

14

Production
Beginning
Bates

Sort

0

Control ID Privilege(s)

NYCPRIV0
3014
Attorney Client;Deliberative

1 NYC_0067299

Deliberative

2 NYC_0067300

Deliberative

3

NYCPRIV0
0004
Attorney Client

Categorical Description

Draft Internal
Memorandum re: AFFH
and Community
Preference
Draft talking points re:
421-a - Homeless
Preference
Draft talking points re:
421-a - Homeless
Preference

Court Court's Summary
Decisio Description of Nature of
n
Document

NP

communication among
counsel and others re:
delegation of
responsibilities for
responding to plaintiff's
counsel letter re: fair
housing policies

NP

Per City's Agreement

NP

Email chain re: Application
of Community Preference AC

communication with
counsel and others re:
requests to include prior
residents in community
preference; identifying
issue for legal advice

4

NYCPRIV0
0014
Attorney Client;Deliberative

Email chain re: Community AC &
Opposition Strategies
DPP

communications with
counsel and others about
strategy and potential
positions in advance of
REBNY Meeting;

5

NYCPRIV0
0015
Work Product

Email chain re: Litigation Winfield Litigation
NP

Per City's Agreement

NYCPRIV0
0016
Deliberative;Work Product

Draft report re: Litigation Winfield
Litigation;Application of
WP &
Community Preference
DPP

Settlement Options
Analysis

NYCPRIV0
0017
Deliberative;Work Product

Draft Internal
Memorandum re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation Winfield Litigation

Settlement Options
Analysis

8

NYCPRIV0
0018
Deliberative;Work Product

Draft report re: Litigation Winfield
Litigation;Application of
WP &
Community Preference
DPP

9

NYCPRIV0
0023
Deliberative

Draft Internal
Memorandum re: 421-a Homeless Preference
DPP

6

7

WP &
DPP

Settlement Options
Analysis
Draft decision memo to
mayor regarding
homeless unit
commitment

10

11

12

13

NYCPRIV0
Work Product
0025

Email chain re: Litigation Winfield Litigation
WP

Communication about
preparation for legal
strategy meeting with
Mayor about this
litigation

NYCPRIV0
0026
Deliberative;Work Product

Draft presentation re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation Winfield Litigation

WP &
DPP

Litigation Strategy
Document

DPP

communication regarding
potential policy re: 421a
units; PRODUCE UNDER
RODRIGUEZ

NP

Per City's Agreement

NP

NYCPRIV0
Deliberative
0047

NYCPRIV0
0061
Attorney Client

NYCPRIV0
Deliberative;Legislative
14 NYC_0083074 0063

Email chain re: 421-a Homeless Preference

Draft talking points re:
MIH - Anti-displacement
strategies;Antidisplacement strategies
Draft talking points re:
MIH - mobility;MIH Community
opposition;MIH - City
council input

15

NYCPRIV0
0067
Work Product

Email chain re: Litigation Winfield Litigation
WP

Per City's Agreement
Communication about
work needed to inform
legal strategy

16

NYCPRIV0
0068
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation
WP

Litigation Strategy memo

17

NYCPRIV0
0069
Deliberative;Work Product

18

Attorney
NYCPRIV0 Client;Deliberative;Work
0074
Product

19

Attorney
NYCPRIV0 Client;Deliberative;Work
19 0075
Product

Draft report re: Litigation Winfield
Litigation;Application of
Community Preference
Draft Internal
Memorandum re: MIH Anti-displacement
strategies; Litigation Anticipated Litigation re:
Community
Preference;Litigation Winfield
Litigation;Community
Opposition Strategies
Draft Internal
Memorandum re: MIH Anti-displacement
strategies; Litigation Anticipated Litigation re:
Community
Preference;Litigation Winfield
Litigation;Community
Opposition Strategies

WP &
DPP

Settlement Options
Analysis

AC

draft decision memo to
mayor re: rezonings in
specific neighborhoods
containing legal advice

AC

draft decision memo to
mayor re: rezonings in
specific neighborhoods
containing legal advice

20

21

22 NYC_0032942

NYCPRIV0
Deliberative;Legislative
0083

NYCPRIV0
Deliberative;Legislative
0095

Attorney Client

Final talking points (nonpublic) re: MIH - Antidisplacement
strategies;MIH - City
council input

NP

internal documents
setting forth admin.
position to certain issues;
shared with CM

Draft report re: MIH - City
council input
DPP

draft considerations for
potential modification to
MIH; DO NOT PRODUCE
UNDER RODRIGUEZ

Draft Document re: 421-a 2015/2016 revision
AC

Attorney comments on
draft advertisement for
housing on West 42nd St.
sent to another City
lawyer for further review

23

NYCPRIV0
0425
Attorney Client

Email chain re: Application
of Community Preference AC

communication with
attorney and others
concerning use of
marketing bands for
specific housing project;
highlighting legal issues
with proposed approach

24

NYCPRIV0
0435
Work Product

Email chain re: Litigation Winfield Litigation
NP

Per City's Agreement

Email chain re: Application
of Community Preference AC

draft language regarding
housing ad sent to
counsel for legal review
and comment

Email chain re: 421-a Homeless Preference

internal communications
describing issue on which
legal advice sought
pertaining to lotteries can
be redacted; document
otherwise must be
produced

25

26

27

28
29 NYC_0033138

NYCPRIV0
0474
Attorney Client

NYCPRIV0
2106
Attorney Client;Deliberative

NYCPRIV0
0482
Attorney Client;Deliberative

NYCPRIV0
0483
Attorney Client;Deliberative
Attorney Client;Deliberative

AC in
part

Email chain re: Application
of Community Preference AC

communications with
attorney and others
concerning modifications
to CPP in context of
preservation projects

Email chain re: Application
of Community Preference AC
Draft report re: 421-a 2015/2016 revision
AC

communications with
attorney and others
concerning modifications
to CPP in context of
preservation projects
attorney summary and
advice re: 421-a

NYCPRIV0
Attorney Client
0501

Draft talking points re:
421-a - Homeless
Preference

31

NYCPRIV0
Attorney Client;Deliberative
2108

Email chain re: 421-a Homeless
Preference;Application of
Community Preference

AC

32

NYCPRIV0
0106
Attorney Client;Deliberative

Draft talking points re:
421-a - Homeless
Preference

AC

33

NYCPRIV0
0108
Attorney Client;Deliberative

Email chain re: 421-a Homeless Preference

AC

30

AC

Draft of document
concerning homeless
referrals to 421-a
projects reflecting legal
advice

communications
reflecting legal advice re:
421-a
Draft of documents
concerning homeless
referrals to 421-a
projects reflecting legal
advice sought
emails with counsel and
others; seeking legal
advice in context of this
litigation on
communications plan re:
homeless referrals to 421a projects

AC

draft document
containing comments re:
homeless prevention
policy and 421-a housing;
DO NOT PRODUCE
UNDER RODRIGUEZ
Attorney draft of
documents discussing
homeless referrals to 421a projecs

AC

Communications with
counsel and counsel's
comments on draft FAQs
re: homeless referrals to
421-a projects

AC

Communications with
counsel re: revisions to
Marketing Handbook

34

NYCPRIV0
0536
Deliberative

Draft Document re: 421-a Homeless Preference
DPP

35

NYCPRIV0
0117
Attorney Client

Draft talking points re:
421-a - Homeless
Preference

37

NYCPRIV0
0609
Attorney Client

Draft talking points re:
421-a - Homeless
Preference
Email chain re: 421-a Homeless
Preference;Marketing
guidelines

38

NYCPRIV0
0611
Attorney Client

Email chain re: 421-a Homeless Preference

39

NYCPRIV0
0613
Attorney Client

Draft Document re: 421-a Homeless Preference
AC

Communications with
counsel re: revisions to
Marketing Handbook
Attorney draft of memo
sent to client for
consideration re:
homeless referrals to 421a projects

40

NYCPRIV0
0620
Attorney Client

Draft report re: MIH - Antidisplacement strategies;
421-a - 2015/2016 revision AC

Attorney draft of report
on MIH with highlighted
areas for discussion

36 NYC_0033169

Attorney Client

AC

41

NYCPRIV0
Deliberative
2115

Draft Document re: Antidisplacement
strategies;Community
Opposition Strategies

42

NYCPRIV0
Attorney Client
0637

Draft talking points re:
421-a - 2007 revision

43

NYCPRIV0
Attorney Client
0644

Final letter (non-public) re:
421-a - 2007 revision
NP

44

NYCPRIV0
Attorney Client;Deliberative
0665

Draft Document re:
Marketing guidelines

AC

45

NYCPRIV0
0666
Deliberative

Draft Document re:
Marketing guidelines

DPP

internal working draft
reflecting tentative
positions on HPD RFPs
and involvement in
neighborhood studies;
DO NOT PRODUCE
UNDER RODRIGUEZ
Draft memo re: 421-a for
which legal review is
requested
not conveying legal
advice or seeking legal
advice
Draft of Marketing
Guidelines containing
counsel's comments
draft marketing
guidelines to be
submitted to legal for
review and approval; DO
NOT PRODUCE UNDER
RODRIGUEZ

46

NYCPRIV0
0668
Attorney Client

Email chain re: Antidisplacement
strategies;Application of
Community Preference

NP

communication with
counsel and others re:
CPP; not seeking or
reflecting legal advice

47

NYCPRIV0
0676
Deliberative;Work Product

Draft letter re: Litigation Anticipated Litigation re: WP &
Community Preference
DPP

DPP

AC

48

NYCPRIV0
0686
Deliberative

Draft report re:
Application of Community
Preference
DPP

49

NYCPRIV0
0768
Legislative

Draft talking points re:
ENY - Anti-displacement
strategies

50

NYCPRIV0
0782
Deliberative

Email chain re: Application
of Community Preference NP

51

NYCPRIV0
0783
Attorney Client;Deliberative

NP

Email chain re: Application
of Community Preference AC

Draft letter to HUD re:
potential settlement
draft strategy document
concerning 10-year
affordable housing plan
in East New York; DO
NOT PRODUCE UNDER
RODRIGUEZ
internal strategy
document regarding East
New York development
issues
not internal communication with city
counsel;

communication to
counsel and others
seeking advice re:
overlapping preference
categories at a specific
development

52

NYCPRIV0
0788
Deliberative;Legislative

Draft presentation re: Antidisplacement strategies
DPP

draft internal
presentation concerning
legislative agenda,
positions on 421-a and
fall back positions on rent
regulation and land tax;
DO NOT PRODUCE
UNDER RODRIGUEZ
communication
discussing legal position
in response to litigation
and upcoming meeting
with counsel

53

Email chain re: Litigation Anticipated Litigation re:
NYCPRIV0
0793
Attorney Client;Work Product Community Preference
AC

54

NYCPRIV0
Deliberative;Legislative
0799

Draft Document re: ENY Anti-displacement
strategies
NP

55

NYCPRIV0
0827
Legislative

Draft talking points re: Antidisplacement strategies
NP

draft executive summary
of affordable housing
plan for East New York
internal memo re:
proposed responses to
tenant harassment
proposals by progressive
caucus

56

NYCPRIV0
0158
Deliberative;Legislative

Email chain re: Antidisplacement strategies

NP

also concerns bill re:
harassment of tenants

NYCPRIV0
0835
Deliberative;Legislative

Draft talking points re:
ENY - Anti-displacement
strategies

NP

internal memo reflecting
decisionmaking re: issues
to address re: East New
York development

58

NYCPRIV0
0159
Deliberative

Email chain re: ENY - Antidisplacement
strategies;Community
Opposition Strategies
NP

internal communications
re: East New York
development and MIH
strategy

59

Email chain re: Litigation Other;AFFH and
NYCPRIV0
0839
Attorney Client;Work Product Community Preference
AC

60

Email chain re: Litigation Other;AFFH and
NYCPRIV0
0842
Attorney Client;Work Product Community Preference
AC

61

NYCPRIV0
0844
Deliberative;Work Product

Draft letter re: Litigation Anticipated Litigation re: WP &
Community Preference
DPP

NYCPRIV0
0846
Deliberative

Draft report re: Antidisplacement
strategies;Commitment to
Fair Housing
DPP

57

62

document summarizes
and conveys legal advice
re: Consolidated Plan and
ongoing litigation
communication with
counsel re: draft 2012
Consolidated Plan to HUD
re: AFFH

Draft response to HUD
draft langauge for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ

NYCPRIV0
2140
Deliberative

Draft Document re: Antidisplacement
strategies;Community
Opposition Strategies

64

NYCPRIV0
0881
Deliberative;Legislative

Draft Document re: MIH Anti-displacement
strategies; ENY - Antidisplacement
strategies;ENY - City
council input
NP

internal outline of
remaining considerations
regarding East New York
development plan;

65

NYCPRIV0
0889
Deliberative;Legislative

Draft report re: Antidisplacement strategies

NP

Per City's Agreement

66

NYCPRIV0
0891
Deliberative;Legislative

Email chain re: Antidisplacement strategies

NP

Per City's Agreement

67

NYCPRIV0
Deliberative
0904

Final presentation (nonpublic) re: MIH - Antidisplacement strategies

NP

63

68

NYCPRIV0
0163
Deliberative

DPP

same as 41

Email chain re: ENY - Antidisplacement strategies
DPP

internal communications
concerning East New york
development positions;
PRODUCE UNDER
RODRIGUEZ

69

NYCPRIV0
0690
Attorney Client

Email chain re: Application
of Community Preference AC

communication with
counsel and others re:
legal requirements of 421a and applicability of
various regulations to
specific development

70

NYCPRIV0
0972
Attorney Client;Deliberative

Email chain re: 421-a 2015/2016 revision;421-a Homeless Preference
AC

Legal advice re: 421-a

71

NYCPRIV0
0973
Attorney Client;Deliberative

72

NYCPRIV0
2768
Deliberative

Draft Document re: 421-a 2015/2016 revision;421-a Homeless Preference
AC
Draft talking points re:
Application of Community
Preference
NP

NYCPRIV0
2163
Work Product

Final letter (non-public) re:
Litigation - Anticipated
Litigation re: Community
Preference
NP

Letter to HUD providing
fact information

NYCPRIV0
1425
Deliberative

Draft talking points re:
Litigation - Winfield
Litigation;Application of
Community Preference

Per City's Agreement

73

74

NP

Legal advice re: 421-a

Per City's Agreement

75

NYCPRIV0
Deliberative
1426

Draft talking points re:
Litigation - Winfield
Litigation;Application of
Community Preference

NP

Draft letter re: Litigation Anticipated Litigation re: WP &
Community Preference
DPP

communications re: data
analysis needed to
determine potential
settlement positions with
HUD on CPP
Communications
concerning draft letter to
HUD and alteneratives to
CPP
Draft analysis of
measures of
demographics within CDs
in connection with HUD
submission

NYCPRIV0
0708
Work Product

Final report (non-public)
re: Litigation - Anticipated
Litigation re: Community
Preference
WP

internal statistical
analysis for informing
litigation strategy

Attorney
NYCPRIV0 Client;Deliberative;Work
0709
Product

Email chain re: Litigation Anticipated Litigation re:
Community
Preference;Litigation Winfield Litigation
AC

Discloses topic of legal
advice and responses to
Plaintiffs' counsel and
draft communication to
HUD

NYCPRIV0
0719
Deliberative;Work Product

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation WP &
Winfield Litigation
DPP

analysis to inform legal
strategy

Email chain re: Litigation Anticipated Litigation re: WP &
Community Preference
DPP

communications re: data
analysis needed to
determine potential
settlement positions with
HUD on CPP

Internal Charts or
Maps;Notes re: Antidisplacement strategies

DPP

CHART RE: PROGRESS ON
VARIOUS STRATEGIC
PRESERVATION
INITIATIVES, REFLECTS
INTERNAL WORKING
PROCESS; DO NOT
PRODUCE UNDER
RODRIGUEZ

Draft presentation re:

DPP

SAME AS 52

76

NYCPRIV0
0699
Deliberative;Work Product

Email chain re: Litigation Anticipated Litigation re: WP &
Community Preference
DPP

77

NYCPRIV0
0701
Work Product

Email chain re: Litigation Anticipated Litigation re:
Community Preference
WP

78

79

80

81

82

83
84

Per City's Agreement

Deliberative;Work Product

NYCPRIV0
0720
Deliberative;Work Product

NYCPRIV0
0724
Deliberative
NYCPRIV0
0731
Deliberative

85

86

NYCPRIV0
0145
Work Product

Draft report re: Litigation Anticipated Litigation re:
Community
Preference;Litigation Winfield Litigation
WP

Settlement analysis for
considering options for
CPP changes in
connection with litigation

NYCPRIV0
0146
Deliberative;Work Product

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation WP &
Winfield Litigation
DPP

analysis prepared to
inform litigation strategy
and settlement

Draft report re: Litigation Anticipated Litigation re:
Community Preference
DPP

87

NYCPRIV0 Deliberative;Work
0742
Product(withdrawn)

88

NYCPRIV0
0752
Deliberative

89

NYCPRIV0
0150
Deliberative;Work Product

Draft Document re:
Marketing guidelines
DPP
Internal Charts or Maps re:
Litigation - Winfield
WP &
Litigation
DPP

90

NYCPRIV0
0994
Deliberative

Draft Document re:
Marketing guidelines

DPP

NYCPRIV0
Deliberative
91 NYC_0076061 0997

Draft Document re:
Marketing guidelines

DPP

Draft Document re:
Marketing guidelines

AC

92

93

NYCPRIV0
0999
Attorney Client;Deliberative

NYCPRIV0
1000
Attorney Client;Deliberative

Email chain re: Application
of Community Preference AC

Work product withdrawn;
draft report re: MIH
policy reflecting input
from various individuals;
precedes counsel vote on
MIH; DO NOT PRODUCE
UNDER RODRIGUEZ
draft marketing
guidelines to be
submitted to legal for
review and approval; DO
NOT PRODUCE UNDER
RODRIGUEZ
analysis to inform legal
strategy and settlement
draft marketing
guidelines to be
submitted to legal for
review and approval; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft marketing
guidelines to be
submitted to legal for
review and approval; DO
NOT PRODUCE UNDER
RODRIGUEZ
communications re:
sections of 2016
Marketing Guidelines and
attorney advice re:
certain sections
communications with
counsel and others re:
inclusion of prior
residents in community
preference for various
projects

94

NYCPRIV0
Attorney Client
1003

95

NYCPRIV0
2149
Attorney Client;Deliberative

Email chain re: North
Brooklyn Rezoning and
Demographics
AC
Email chain re: MIH - Antidisplacement
strategies;MIH Community opposition
NP

communications with
counsel re: requests to
include prior residents in
community preference,
pre-policy discussion re:
policy

Per City's Agreement

96

NYCPRIV0
1431
Attorney Client;Legislative

Email chain re: City Council
Input;Application of
Community Preference
AC

communications
discussing advice of
counsel re: community
preference with regard to
specific project

97

Draft report re: MIH - Antidisplacement
strategies;MIH Community
opposition;MIH - City
council input;Community
NYCPRIV0 Attorney
2174
Client;Deliberative;Legislative Opposition Strategies
AC

draft internal report
concerning MIH and 421a sent to counsel for
legal comment

98

NYCPRIV0
1438
Legislative

Email chain re: Application
of Community Preference NP

communications about
AMI and CPP as to
specific development

99

NYCPRIV0
1439
Legislative

Email chain re: Application
of Community Preference NP

communications about
AMI and CPP as to
specific development
Communication with
counsel and others;
seeking legal advice on
planned communications
re: homeless policy as it
relates to CPP

100

NYCPRIV0
1441
Attorney Client;Deliberative

Draft Document re: 421-a Homeless Preference
AC

101

NYCPRIV0
2175
Deliberative

Email chain re: Application
of Community Preference NP

102

NYCPRIV0
1442
Legislative

Email chain re: Application
of Community Preference NP

103

NYCPRIV0
0180
Deliberative

Internal Memorandum re:
421-a - Homeless
Preference
DPP

NYCPRIV0
0189
Deliberative;Work Product

Email chain re: Antidisplacement strategies;
Litigation - Anticipated
Litigation re: Community
Preference

104

WP &
DPP

communications
regarding CPP
communications about
Bronx Commons
development
draft decision memo to
mayor re: homeless unit
commitment; DO NOT
PRODUCE UNDER
RODRIGUEZ
communications
concerning information
needed to evaluate
changes to CPP and
settlement position with
HUD

105

NYCPRIV0
0191
Deliberative

Draft report re: MIH mobility

106

NYCPRIV0
1510
Deliberative;Work Product

Email chain re: Litigation Anticipated Litigation re:
Community Preference
NP

Per City's Agreement

107

NYCPRIV0
1511
Deliberative

Draft talking points re: Antidisplacement strategies
NP

Per City's Agreement

108

NYCPRIV0
1540
Deliberative

Email chain re: Antidisplacement
strategies;Application of
Community Preference

109

NYCPRIV0
1549
Attorney Client;Deliberative

Internal Memorandum re:
Commitment to Fair
Housing
AC

Per City's Agreement
Draft decision memo on
MIH and stating
understanding of legal
advice

110

Attorney
NYCPRIV0 Client;Deliberative;Work
1556
Product

Draft Internal
Memorandum re: MIH Anti-displacement
strategies; Litigation Anticipated Litigation re:
Community Preference

AC

draft decision memo to
mayor on creation of MIH
program containing and
seeking legal advice

111

NYCPRIV0
1578
Deliberative;Legislative

Email chain re: Application
of Community Preference NP

communication regarding
inquiry about application
of CPP

112

NYCPRIV0
1584
Deliberative;Legislative

Email chain re: Application
of Community Preference NP

NYCPRIV0
1591
Attorney Client;Deliberative

Email chain re: ENY - Antidisplacement
strategies;Application of
Community Preference
AC

NYCPRIV0
1592
Attorney Client;Deliberative

Email chain re: ENY - Antidisplacement
strategies;Application of
Community Preference
AC

communication regarding
inquiry about application
of CPP
communication with
counsel re: legal advice
on language in draft
document concerning
CPP
communication with
counsel re: legal advice
on language in draft
document concerning
CPP

NYCPRIV0
0206
Deliberative

Draft Internal
Memorandum re: Antidisplacement strategies

draft decision memo to
mayor re: legal services
RFP; DO NOT PRODUCE
UNDER RODRIGUEZ

NYCPRIV0
1617
Deliberative

Draft presentation re: MIH
- Anti-displacement
strategies;MIH Community
opposition;MIH - City
council input
DPP

113

114

115

116

DPP

NP

DPP

SAME AS 87

internal draft of
considerations for MIH
policy; DO NOT PRODUCE
UNDER RODRIGUEZ

117

NYCPRIV0
Deliberative
1620

Draft presentation re: MIH
- Anti-displacement
strategies;MIH Community
opposition;MIH - City
council input
DPP

119

NYCPRIV0
0220
Deliberative

Email chain re: Litigation Winfield Litigation
WP
Draft talking points re:
421-a - Homeless
Preference
NP

120

NYCPRIV0
1659
Attorney Client;Deliberative

Draft talking points re:
421-a - Homeless
Preference

118 NYC_0073100

121

122

Deliberative;Work Product

NYCPRIV0
1661
Deliberative

NYCPRIV0
1662
Attorney Client

AC

internal draft of
considerations for MIH
policy; DO NOT PRODUCE
UNDER RODRIGUEZ
Communications
regarding this litigation
and statement about it to
provide to HUD

Per City's Agreement
internal draft talking
points in advance of
meeting with REBNY
containing attorney input
and strategy

Email chain re: ENY - Antidisplacement
strategies;Community
Opposition Strategies
DPP

internal communications
re: non-final talking
points about non-final
commitments in advance
of release of Inwood
Development Plan; DO
NOT RELEASE UNDER
RODRIGUEZ

Email chain re: 421-a Homeless Preference

AC

Communication with
counsel and others;
seeking legal advice on
planned communications
re: homeless policy as it
relates to CPP

AC

Communication with
counsel and others;
seeking legal advice on
planned communications
re: homeless policy as it
relates to CPP

123

NYCPRIV0
1663
Attorney Client

Email chain re: 421-a Homeless Preference

124

NYCPRIV0
1666
Work Product

125

NYCPRIV0
1667
Deliberative;Work Product

Email chain re: Litigation Winfield Litigation
NP
Email chain re: Antidisplacement strategies;
Litigation - Winfield
Litigation
NP

126

NYCPRIV0
1723
Attorney Client;Deliberative

Email chain re: Application
of Community Preference AC

Per City's Agreement
communication with
counsel and others
seeking legal advice on
homeless referrals to a
specific project

127

NYCPRIV0
1026
Deliberative;Work Product

Email chain re: Litigation Anticipated Litigation re: WP &
Community Preference
DPP

Discussion about how to
conduct data analysis to
answer HUD request

Per City's Agreement

128

129

130

131

NYCPRIV0
1726
Attorney Client;Deliberative

Email chain re: Application
of Community Preference NP

email seeking legal
advice, among other
input, on a specific
application of CPP

NYCPRIV0
1034
Deliberative;Work Product

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community WP &
Preference
DPP

analysis to inform
litigation strategy

NYCPRIV0
0237
Attorney Client;Deliberative

Email chain re: 421-a Homeless
Preference;Application of
Community Preference

Per City's Agreement

NYCPRIV0
1037
Deliberative;Work Product

NP

Email chain re: Litigation Anticipated Litigation re: WP &
Community Preference
DPP

132

NYCPRIV0
1737
Deliberative;Legislative

Email chain re: ENY - Antidisplacement strategies
DPP

133

NYCPRIV0 Deliberative
1039
(withdrawn);Work Product

134

NYCPRIV0
1058
Deliberative;Work Product

Email chain re: Litigation Anticipated Litigation re:
Community Preference
WP
Draft report re: Antidisplacement strategies;
Litigation - Winfield
Litigation
WP

135

NYCPRIV0
1066
Deliberative;Work Product

Internal Charts or Maps re:
Anti-displacement
strategies
WP

136

NYCPRIV0
1067
Attorney Client;Deliberative

137

NYCPRIV0
1070
Deliberative;Work Product

138

NYCPRIV0
1071
Deliberative;Work Product

Draft report re: Marketing
guidelines
Internal Charts or Maps re:
Anti-displacement
strategies; Litigation Winfield Litigation
Internal Charts or Maps re:
Anti-displacement
strategies; Litigation Winfield Litigation

139

Attorney
NYCPRIV0 Client;Legislative;Work
1075
Product

Email chain re: City Council
Input; Litigation Anticipated Litigation re:
Community Preference
AC

summary of info
discussed at settlement
meeting with HUD re:
HUD data requests for
alternative to CPP
internal communications
re: East New York
development and
strategy; DO NOT
PRODUCE UNDER
RODRIGUEZ
information and data
collected to inform
settlement strategy with
HUD
Draft PPT re: alternatives
to CPP to inform strategy
in litigation

AC

email re: gentrification
map in connection with
planning changes to CPP
for settlement
revisions to Marketing
handbook sent to counsel
for comment

WP &
DPP

gentrification map for
planning changes to CPP
for settlement

WP &
DPP

gentrification map for
planning changes to CPP
for settlement
email chain with counsel
and others re: response
to Plaintiff's counsel and
draft letter to HUD

Attorney
NYCPRIV0 Client;Deliberative;Work
Product
140 NYC_0076236 1117

Draft presentation re:
Litigation - Anticipated
Litigation re: Community
Preference;Neighborhood
Demographics
AC

141

Email chain re: Litigation Anticipated Litigation re:
Community
Preference;AFFH and
NYCPRIV0
WP &
Attorney Client;Work Product Community Preference
1122
DPP

142

NYCPRIV0
Attorney Client
2150

143

144

145

Email chain;Draft
Document re: OTHER

document discussing
strategies for
negotiations with HUD re:
community preference;
legal advice on document
sought

AC

ppt re: option for
analyzing various aspects
of CDs in connection with
changes to CPP as part of
litigation
communications
identifying portions of
draft document where
legal advice is sought and
discussing legal review of
same

NYCPRIV0
1222
Deliberative;Legislative

Email chain re: Antidisplacement strategies

DPP

internal communications
re: East New York
development and MIH
strategy; DO NOT
PRODUCE UNDER
RODRIGUEZ

NYCPRIV0
1231
Deliberative

Email chain re: Antidisplacement
strategies;Application of
Community Preference

NP

email re: application of
CPP

NYCPRIV0
1292
Deliberative

146

NYCPRIV0
1294
Deliberative

147

NYCPRIV0
1298
Deliberative

Email chain re: Community
Opposition Strategies
DPP

Notes re: Antidisplacement
strategies;Commitment to
Fair Housing
DPP
Draft report re: ENY - Antidisplacement
strategies;ENY Community opposition
NP

communications
concerning preliminary
responses to community
questions about
Community Housing Plan PRODUCE UNDER
RODRIGUEZ
internal notes reflecting
Meltzer's thoughts on
contract with
NEIGHBORHOOD
PRESERVATION
CONSULTANT program
and displacement
mitigation strategies PRODUCE UNDER
RODRIGUEZ

Per City's Agreement

Final report (nonpublic);Draft Document re:
Anti-displacement
strategies
DPP

concept paper in advance
of RFP for Neighborhood
Preservation Consultant
contract to assist HPD in
preserving affordable
housing stock; lays out
goals, elements and
parameters of new model
for program - not final
parameters of program DO NOT PRODUCE
UNDER RODRIGUEZ

NYCPRIV0
2151
Work Product

Email chain re: Litigation Winfield Litigation
WP

Concerns literature
review on gentrification
and economic diversity;
FOR SETTLEMENT

150

NYCPRIV0
1342
Work Product

Internal Charts or Maps re:
Litigation - Winfield
Litigation
WP

151

NYCPRIV0
1349
Deliberative;Work Product

Email chain re: Litigation - WP &
Winfield Litigation
DPP

148

149

NYCPRIV0
1302
Deliberative

152

NYCPRIV0
1353
Deliberative

Email chain re: MIH - Antidisplacement strategies
DPP

153

NYCPRIV0
1358
Deliberative;Work Product

Email chain re: Litigation - WP &
Winfield Litigation
DPP

154

NYCPRIV0
2153
Work Product

155

NYCPRIV0
2154
Work Product

Email chain re: Litigation Winfield Litigation
WP
Notes re: Antidisplacement strategies;
Litigation - Winfield
Litigation
WP

156

NYCPRIV0
1366
Deliberative;Work Product

Email chain re: Litigation - WP &
Winfield Litigation
DPP

157

NYCPRIV0
1367
Deliberative;Work Product

Email chain re: Litigation - WP &
Winfield Litigation
DPP

Settlement analysis for
considering options for
CPP changes in
connection with litigation
email discussion
regarding options for
changes to CPP in
connection with
settlement positions
communications setting
forth preliminary
thoughts about creation
of HousingStat (a
computer program to
help officials and
nonprofits prevent
displacement and protect
stock of affordable
housing) - DO NOT
PRODUCE UNDER
RODRIGUEZ
email discussion re:
settlement posiitons on
CPP
Communication about
work needed to inform
legal strategy
Summary of fact research
done for litigation and
reflects litigation strategy
email discussion re:
settlement positions on
CPP
email discussion re:
settlement positions on
CPP

158

NYCPRIV0
1374
Deliberative;Work Product

Email chain re: Litigation Anticipated Litigation re:
Community
Preference;Litigation WP &
Winfield Litigation
DPP

159

Attorney
NYCPRIV0 Client;Deliberative;Work
1375
Product

Email chain re: Litigation Anticipated Litigation re:
Community Preference
AC

160

NYCPRIV0
1377
Work Product

161

NYCPRIV0
1378
Deliberative;Work Product

162

NYCPRIV0
1384
Deliberative;Work Product

Email chain re: Litigation Winfield Litigation
Draft Internal
Memorandum re:
Litigation - Winfield
Litigation
Draft Internal
Memorandum re:
Litigation - Winfield
Litigation

163

NYCPRIV0
1746
Attorney Client

164

email discussion re:
settlement positions on
CPP
communciations with
counsel and others re:
legal strategy and
defenses

WP

Describes work done for
informing litigation and
settlement strategy

WP &
DPP

legal materials re:
settlement positions

WP &
DPP

legal materials re:
settlement positions

Email chain re: Application
of Community Preference AC

NYCPRIV0
1386
Deliberative;Work Product

communications with
counsel and others re:
draft statement about
community preference
legal materials re:
settlement positions

165

Draft report re: Litigation - WP &
Winfield Litigation
DPP
Internal Charts or Maps re:
NYCPRIV0
Litigation - Winfield
1392
Attorney Client;Work Product Litigation
WP

166

NYCPRIV0
Email chain re: Litigation 1398
Attorney Client;Work Product Winfield Litigation
WP

legal materials re:
settlement positions

167

NYCPRIV0
1399
Work Product

Email chain re: Litigation Winfield Litigation
WP

168

NYCPRIV0
1752
Deliberative

Draft Document re:
Marketing guidelines

169

NYCPRIV0
0245
Deliberative;Work Product

Email chain re: Litigation Anticipated Litigation re:
Community Preference
WP

170

NYCPRIV0
0263
Deliberative;Work Product

Email chain re: Litigation Anticipated Litigation re: WP &
Community Preference
DPP

DPP

legal materials re:
settlement positions

Describes work done for
informing litigation and
settlement strategy
draft marketing
guidelines to be
submitted to legal for
review and approval; DO
NOT PRODUCE UNDER
RODRIGUEZ
communications
concerning legislative
history of CPP and search
for same
communications
concerning potential
changes to CPP in context
of settlement discussion
with HUD; DO NOT
PRODUCE UNDER
RODRIGUEZ

171

NYCPRIV0
Deliberative;Work Product
0264

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community WP &
Preference
DPP

analysis to inform
litigation strategy and
settlement

172

NYCPRIV0
0265
Deliberative;Work Product

Email chain re: Litigation Anticipated Litigation re:
Community Preference
WP

communications
concerning letter to HUD
re: alternatives to CPP

173

NYCPRIV0
1760
Deliberative;Legislative

Email chain re: City Council
Input;Application of
Community Preference
NP

communicatons
concerning development
at 168th St. and response
to counsel member
concerns

174

NYCPRIV0
Deliberative
0274

Draft presentation re: Antidisplacement strategies;
421-a - 2015/2016 revision DPP

175

NYCPRIV0
0278
Attorney Client

Email chain re: Application
of Community Preference AC

176

Attorney
NYCPRIV0 Client;Deliberative;Work
0280
Product

Final letter (non-public) re:
Litigation - Anticipated
Litigation re: Community
Preference
DPP

177

NYCPRIV0
0281
Deliberative;Work Product

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation WP &
Winfield Litigation
DPP

178

Email chain re: Litigation Anticipated Litigation re:
Community
Preference;Litigation NYCPRIV0
AC &
0292
Attorney Client;Work Product Winfield Litigation
WP

179

NYCPRIV0
0293
Legislative

Email chain re: Application
of Community Preference NP

180

NYCPRIV0
0295
Work Product

Email chain re: Litigation Winfield Litigation
NP

analysis to inform
litigation strategy and
settlement
Communication with
counsel; discussion
anticipated litigation,
FOIL request and
potential fact
development for
litigation
emails between
Garodnick and Been re:
CPP
draft communication to
mayor about filing of this
suit

NYCPRIV0
0306
Work Product

Email chain re: Litigation Anticipated Litigation re:
Community
Preference;Litigation Winfield Litigation
WP

communications about
this litigation and
providing statement to
HUD re: same

181

Same as 52
communication with
counsel and others
seeking advice on
application of
preferences at a specific
development
Not attorney-client
because sent to HUD;
Letter from Been to HUD
GC re: Settlement
Proposal; DO NOT
PRODUCE UNDER
RODRIGUEZ

182

NYCPRIV0
0309
Deliberative;Work Product

183

NYCPRIV0
0321
Work Product

184

NYCPRIV0
0322
Work Product

NYCPRIV0
Deliberative;Work Product
185 NYC_0072746 0329

186

187

188

189

190

191

192

NYCPRIV0
1780
Attorney Client

NYCPRIV0
1791
Deliberative

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation WP &
Winfield Litigation
DPP
Final report (non-public)
re: Litigation - Anticipated
Litigation re: Community
Preference
WP
Draft Internal
Memorandum re:
Litigation - Winfield
Litigation
WP
Draft letter re: Litigation Anticipated Litigation re:
Community Preference
WP
Final report (non-public)
re: Marketing guidelines

Draft Document re:
Marketing guidelines

analysis to inform
litigation strategy and
settlement
Analysis of ACS
demographic and housing
estimates based on
census tracts

Atty questions re: CPP
and statistical tests

Draft Letter from Been to
HUD GC re: settlement

NP

DPP

draft marketing
guidelines to be
submitted to legal for
review and approval; DO
NOT PRODUCE UNDER
RODRIGUEZ

Email chain re: Litigation Anticipated Litigation re:
Community Preference
WP

Internal communication
regarding analysis of
litigation risk and
settlement possibility
with HUD

NYCPRIV0
0339
Deliberative

Email chain re: Litigation Anticipated Litigation re:
Community Preference
DPP

communications about
potential changes to CPP
and communications with
CM Greenfield PRODUCE UNDER
RODGRIGUEZ

NYCPRIV0
0340
Attorney Client

Email chain re: Application
of Community
Preference;Community
Opposition Strategies
AC

communication with
counsel and other
seeking advice re: public
statement about CPP

NYCPRIV0
0341
Deliberative;Work Product

Email chain re: Litigation Anticipated Litigation re:
Community Preference
WP

Communications with
HUD and then internal
communications re:
settlement discussions
with HUD re: CPP

NYCPRIV0
0342
Deliberative;Work Product

Email chain re: Litigation Anticipated Litigation re: WP &
Community Preference
DPP

communication
concerning proposed
communication with HUD
re: alternatives to CPP

NYCPRIV0
0338
Work Product

193

194

NYCPRIV0
0345
Attorney Client;Deliberative

Draft Internal
Memorandum re: AFFH
and Community
Preference;Community
Opposition Strategies

AC

decision memo to Mayor
making
recommendations and
conveying legal advice re:
rezoning in specific
neighborhood

NYCPRIV0
1835
Attorney Client;Deliberative

Internal Memorandum re:
Commitment to Fair
Housing
AC

Decision memo to Mayor
re: rezoning in specific
neighborhoods and
containing legal advice

Final report (non-public)
re: Litigation - Winfield
Litigation
WP
Internal Charts or Maps re:
Litigation - Winfield
WP &
Litigation
DPP

Notes on property
portfolios and includes
Winfield litigation
strategy comments
analysis to inform
litigation strategy and
settlement

195

NYCPRIV0
1841
Work Product

196

NYCPRIV0
0351
Deliberative;Work Product

197

NYCPRIV0
0352
Deliberative;Work Product

198

NYCPRIV0
0353
Work Product

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation WP &
Winfield Litigation
DPP
Draft presentation re:
Litigation - Winfield
Litigation
WP

199

NYCPRIV0
0354
Deliberative;Work Product

Notes re: 421-a 2015/2016 revision;
Litigation - Winfield
Litigation

WP &
DPP

200

NYCPRIV0
0355
Deliberative;Work Product

Notes re: Litigation Winfield Litigation

WP

NYCPRIV0
0356
Deliberative;Work Product

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation WP &
Winfield Litigation
DPP

analysis to inform
litigation strategy and
settlement

NYCPRIV0
0363
Deliberative

Draft Internal
Memorandum re: Antidisplacement strategies

internal draft re:
preservation initatives;
DO NOT PRODUCE
UNDER RODRIGUEZ

NYCPRIV0
0367
Deliberative;Work Product

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation WP &
Winfield Litigation
DPP

201

202

203

DPP

analysis to inform
litigation strategy and
settlement
Legal communication and
analysis of case
Notes concerning
considerations for
determining policy
regarding 421a and
changes to law
list of questions to
consider re: possible
changes to CPP

analysis to inform
litigation strategy and
settlement

204

NYCPRIV0
0368
Deliberative;Work Product

205

NYCPRIV0
Work Product
0378

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation WP &
Winfield Litigation
DPP
Draft Internal
Memorandum re:
Litigation - Winfield
Litigation
WP

NYCPRIV0
0379
Work Product

Internal Charts or Maps re:
Litigation - Winfield
Litigation
WP

207

NYCPRIV0
0380
Work Product

Internal Charts or Maps re:
Litigation - Winfield
Litigation
WP

208

NYCPRIV0
0382
Work Product

209

NYCPRIV0
0391
Work Product

Internal Charts or Maps re:
Litigation - Winfield
Litigation
WP
Draft presentation re:
Litigation - Winfield
Litigation
WP

210

NYCPRIV0
0392
Deliberative;Work Product

Draft letter re: Litigation Anticipated Litigation re:
Community Preference
WP

211

NYCPRIV0
0393
Work Product

Internal Charts or Maps re:
Litigation - Winfield
Litigation
WP

212

NYCPRIV0
0394
Deliberative

Draft talking points re:
421-a - Homeless
Preference

NP

213

NYCPRIV0
0395
Deliberative

Draft talking points re:
421-a - Homeless
Preference

NP

214

NYCPRIV0
0396
Deliberative

Draft talking points re:
421-a - Homeless
Preference

NP

Draft Letter from Been to
HUD GC re: settlement
Settlement analysis for
considering options for
CPP changes in
connection with litigation
- MAP
draft internal Q&A re:
421a Homeless
preference; contains
interpretation of 421a
draft internal Q&A re:
421a Homeless
preference; contains
interpretation of 421a
draft internal Q&A re:
421a Homeless
preference; contains
interpretation of 421a

215

NYCPRIV0
0402
Deliberative;Legislative

Draft talking points re:
MIH - Anti-displacement
strategies

DPP

same as 83

216

NYCPRIV0
1843
Attorney Client;Deliberative

Internal Memorandum re:
421-a - 2015/2016 revision AC

206

analysis to inform
litigation strategy and
settlement

Legal analysis and
settlement strategies
Setlement analysis for
considering options for
CPP changes in
connection with litigation
Settlement analysis for
considering options for
CPP changes in
connection with litigation
Settlement analysis for
considering options for
CPP changes in
connection with litigation
- MAP
Legal analysis and
settlement strategies

legal summary for client
re: 421-a

217

218

219

220 NYC_0067398

221 NYC_0067400

NYCPRIV0
Deliberative
1850

NYCPRIV0
Attorney Client;Deliberative
1855

NYCPRIV0
1863
Deliberative

Work Product

Deliberative;Work Product

222 NYC_0067402

Deliberative;Work Product

223 NYC_0067405

Work Product

224 NYC_0067416

Deliberative;Work Product

Draft report re: Application
of Community
Preference;Marketing
guidelines
DPP

draft section of marketing
handbook; DO NOT
PRODUCE UNDER
RODRIGEZ

Internal Memorandum re:
421-a - Homeless
Preference
AC

Memo reflecting opinions
of HPD Legal Affairs and
Law Department on
tenant selection and
requested for
determining policy re:
same

Draft talking points re: Antidisplacement strategies
NP

draft Q&As re: affordable
housing in connection
with 2015 mayor state of
city address

Draft Document re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation Winfield Litigation
Draft Internal
Memorandum re:
Litigation - Winfield
Litigation
Draft Internal
Memorandum re:
Litigation - Winfield
Litigation
Final presentation (nonpublic) re: Litigation Winfield Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation

WP

Draft questions for
analysis for formulating
litigation strategy

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP
WP &
DPP

225 NYC_0067418

Deliberative;Work Product

226 NYC_0067422

Deliberative;Work Product

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community
Preference
Internal Charts or Maps re:
Litigation - Winfield
Litigation

227 NYC_0067424

Deliberative;Work Product

Notes re: Litigation Anticipated Litigation re:
Community Preference

WP

228 NYC_0067425

Work Product

Notes re: Litigation Winfield Litigation

WP

229 NYC_0067426

Work Product

Notes re: Litigation Winfield Litigation

WP

WP &
DPP
WP &
DPP

Legal communication and
analysis of case
analysis to inform
litigation strategy and
settlement

analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement
notes reflect
communications with
HUD re: settlement of
issues raised about CPP
Reflects attorney
questions and
information gathering for
litigation
Reflects potential
analyses for informing
litigation strategy

230 NYC_0067431

231 NYC_0067438

Work Product

Deliberative

Draft presentation re:
Litigation - Winfield
Litigation
WP
Draft talking points re:
MIH - Community
opposition;Antidisplacement
strategies;Commitment to
Fair Housing
NP

Draft presentation re:
litigation for informing
litigation strategy

Notes for discussion with
NYT about fair housing;
does not reflect
decisionmaking on policy

232

NYCPRIV0 Attorney Client;Legislative
1867
(Withdrawn); Deliberative

Email chain re: Application
of Community Preference AC

Withdraw legislative
privilege; adding DPP;
communications with
counsel and others to
provide legal advice
regarding proposed
application of CPP to
displaced tenants of
Greenpoint/Wiliamsburg

233

NYCPRIV0
1874
Attorney Client;Deliberative

Draft report re: Application
of Community Preference NP

Per City's Agreement

Draft report re: Antidisplacement strategies

draft of proposed new
housing marketplace
plan; DO NOT PRODUCE
UNDER RODRIGUEZ

234

NYCPRIV0
1882
Deliberative

DPP

NYCPRIV0
1884
Attorney Client

Email chain re: Application
of Community Preference AC

NYCPRIV0
2774
Deliberative

Draft report re: Litigation Winfield
Litigation;Commitment to
Fair Housing
DPP

237

NYCPRIV0
2775
Deliberative

Draft report re: Litigation Winfield
Litigation;Commitment to
Fair Housing
DPP

238

NYCPRIV0
2782
Attorney Client;Deliberative

Draft report re:
Commitment to Fair
Housing

AC &
DPP

239

NYCPRIV0
2783
Attorney Client;Deliberative

Draft report re:
Commitment to Fair
Housing

AC &
DPP

240

NYCPRIV0
2784
Attorney Client;Deliberative

241

NYCPRIV0
2785
Attorney Client;Deliberative

235

236

Draft report re: AFFH and
Community Preference
Draft report re: AFFH and
Community
Preference;Commitment
to Fair Housing

AC &
DPP

AC &
DPP

communications with
counsel discussing
potential legislation and
conveying legal advice
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft of 2016
consolidated plan re:
AFFH sent to counsel for
comments
draft of 2016
consolidated plan re:
AFFH sent to counsel for
comments
draft of 2016
consolidated plan re:
AFFH sent to counsel for
draft of 2016
comments
consolidated plan re:
AFFH sent to counsel for
comments

242

243

NYCPRIV0
Attorney Client;Deliberative
2797

Draft report re: Antidisplacement
strategies;Commitment to AC &
Fair Housing
DPP

NYCPRIV0
Deliberative
2800

Draft report re: Antidisplacement
strategies;Commitment to
Fair Housing
DPP

244

NYCPRIV0
Deliberative
2807

Draft report re:
Commitment to Fair
Housing

DPP

245

NYCPRIV0
2812
Attorney Client;Deliberative

Draft report re:
Commitment to Fair
Housing

AC &
DPP

246

NYCPRIV0
2825
Deliberative

Draft report re:
Commitment to Fair
Housing

DPP

247

NYCPRIV0
2828
Deliberative

248

NYCPRIV0
2832
Attorney Client;Deliberative

Email chain re:
Commitment to Fair
Housing
NP
Draft report re: Antidisplacement
strategies;Commitment to AC &
Fair Housing
DPP

249

NYCPRIV0
2859
Deliberative

Draft report re:
Commitment to Fair
Housing

250

NYCPRIV0
2885
Attorney Client;Deliberative

251

NYCPRIV0
2897
Attorney Client;Deliberative

Draft report re:
Commitment to Fair
Housing
Draft report re: Antidisplacement
strategies;Commitment to
Fair Housing

252

NYCPRIV0
2899
Deliberative

Draft report re: Antidisplacement strategies

DPP

AC &
DPP

AC &
DPP

DPP

draft of 2016
consolidated plan
sections re: AFFH sent to
counsel for comments
draft langauge for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for Fair
Housing Statement to be
included in AFFH Plan;
DO NOT PRODUCE
UNDER RODRIGUEZ
draft submission to HUD
re AFFH seeking
comments from multiple
agencies to submit to
legal
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
email re: language for
inclusion in AFFH
document RE: 5-yr needs
for HPD Fair Housing
Program
draft of 2010 AFFH
statement for HUD sent
to counsel for comments
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft submission to HUD
re AFFH seeking
comments of multiple
agencies to submit to
legal
draft of 2012
consolidated plan re:
AFFH sent to counsel for
comments
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ

253

Final report (non-public)
re: Litigation - Anticipated
Litigation re: Community
Preference;Commitment
NYCPRIV0
2905
Attorney Client;Work Product to Fair Housing
NP

Excerp AFFH update from
2011 consolidated plan

254

Final report (non-public)
re: Litigation - Winfield
Litigation;Commitment to
NYCPRIV0
2906
Attorney Client;Work Product Fair Housing
NP

2011 consolidated plan
re: AFFH to HUD

Final report (non-public)
re: Litigation - Anticipated
Litigation re: Community
Preference;Commitment
NYCPRIV0
2911
Attorney Client;Work Product to Fair Housing
NP
Draft report re:
Neighborhood
Demographics;Commitme AC &
NYCPRIV0
2913
Attorney Client;Deliberative nt to Fair Housing
DPP

Per City's Agreement
draft of 2013
consolidated plan re:
AFFH sent to counsel for
comments

255

256

draft sections for 2013
Consolidated Plan AFFH;
DO NOT PRODUCE
UNDER RODRIGUEZ
draft langauge for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ

257

NYCPRIV0
2924
Deliberative

Draft report re:
Commitment to Fair
Housing

258

NYCPRIV0
2939
Deliberative

Draft report re:
Commitment to Fair
Housing

259

Attorney
NYCPRIV0 Client;Deliberative;Work
2943
Product

Email chain re: Litigation Anticipated Litigation re:
Community
Preference;Litigation Other;AFFH and
Community
Preference;Commitment
to Fair Housing
AC

Communication with
attorney re: draft
submission to HUD and
legal issues re: same

260

Final report (non-public)
re: Litigation - Anticipated
Litigation re: Community
NYCPRIV0
2953
Attorney Client;Work Product Preference;((Litigation))
NP

2007 Final Consolidated
Plan AFFH Annual
Performance Report to
HUD

261

Attorney
NYCPRIV0 Client;Deliberative;Work
2954
Product

Final report (non-public)
re: Litigation - Anticipated
Litigation re: Community
Preference;Commitment
to Fair Housing
NP

NYCPRIV0
2967
Deliberative

Draft report re:
Neighborhood
Demographics;Commitme
nt to Fair Housing
DPP

262

DPP

DPP

Excerp AFFH update from
2008 consolidated plan
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ

263

NYCPRIV0
Attorney Client;Deliberative
2968

Draft report re:
Commitment to Fair
Housing

WP &
DPP

264

NYCPRIV0
Attorney Client;Deliberative
2969

Draft report re:
Commitment to Fair
Housing

WP &
DPP

265

NYCPRIV0
2970
Attorney Client;Deliberative

266

NYCPRIV0
Attorney Client;Deliberative
2973

Draft report re:
Commitment to Fair
Housing
Draft report re:
Neighborhood
Demographics;Commitme
nt to Fair Housing

WP &
DPP

AC &
DPP

NYCPRIV0
Deliberative
267 NYC_0085477 3002

Draft report re:
Commitment to Fair
Housing

DPP

NYCPRIV0
Deliberative
268 NYC_0085478 3003

Draft report re:
Commitment to Fair
Housing

DPP

270

NYCPRIV0
3015
Deliberative

Draft report re:
Commitment to Fair
Housing

DPP

271

NYCPRIV0
3016
Deliberative

Draft report re:
Commitment to Fair
Housing

DPP

272

NYCPRIV0
3025
Deliberative

Draft report re:
Commitment to Fair
Housing

DPP

273

NYCPRIV0
3055
Attorney Client;Deliberative

Draft report re:
Commitment to Fair
Housing

WP &
DPP

Attorney
NYCPRIV0 Client;Deliberative;Work
3070
Product

Email chain re: Litigation Anticipated Litigation re:
Community
Preference;Litigation Other;AFFH and
Community
Preference;Commitment AC &
to Fair Housing
WP

274

draft submission to HUD
re AFFH seeking
comments of multiple
agencies to submit to
legal
draft submission to HUD
re AFFH seeking
comments of multiple
agencies to submit to
legal
draft submission to HUD
re AFFH seeking
comments of multiple
agencies to submit to
legal
draft of portion of AFFHrelated document sent to
counsel for comments
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft submission to HUD
re AFFH seeking
comments of multiple
agencies to submit to
legal

Communication with
attorney re: draft
submission to HUD and
legal issues re: same

275

Attorney
NYCPRIV0 Client;Deliberative;Work
3093
Product

Email chain re: Litigation Anticipated Litigation re:
Community
Preference;Litigation Other;AFFH and
Community
Preference;Commitment AC &
to Fair Housing
WP

276

NYCPRIV0
3122
Deliberative

Draft report re:
Commitment to Fair
Housing

DPP

277

NYCPRIV0
3124
Deliberative

Email chain re:
Commitment to Fair
Housing

DPP

278

NYCPRIV0
3126
Deliberative

Draft report re:
Commitment to Fair
Housing

DPP

279

NYCPRIV0
3131
Attorney Client;Deliberative

Draft report re:
Commitment to Fair
Housing

WP &
DPP

NYCPRIV0
3149
Deliberative

Draft report re:
Neighborhood
Demographics;Commitme
nt to Fair Housing
DPP

280

NYCPRIV0
Work Product
281 NYC_0085800 3157

Draft report re: Litigation Anticipated Litigation re:
Community
Preference;Application of
Community Preference
WP

282

NYCPRIV0
3182
Attorney Client;Deliberative

Draft report re:
Commitment to Fair
Housing

WP &
DPP

283

NYCPRIV0
3185
Deliberative

Draft report re:
Commitment to Fair
Housing

DPP

284

NYCPRIV0
3202
Attorney Client;Deliberative

Draft report re:
Commitment to Fair
Housing

WP &
DPP

Communication with
attorney re: draft
submission to HUD and
legal issues re: same
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
email re: language for
inclusion in AFFH
document RE: 5-year
nees for HPD Fair
Housing Program; DO
NOT PRODUCE
PURSUANT TO
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft submission to HUD
re AFFH seeking
comments of multiple
agencies to submit to
legal
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ

Internal communication
concerning resonse to
plaintiff's counsel's leter
re: AFFH
draft submission to HUD
re AFFH seeking
comments do multiple
agencies to submit to
legal
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft submission to HUD
re AFFH seeking
comments of multiple
agencies to submit to
legal

285

NYCPRIV0
Deliberative
3212

Draft report re:
Commitment to Fair
Housing

DPP

NYCPRIV0
Attorney Client;Deliberative
287 NYC_0085811 3235

Draft report re:
Neighborhood
Demographics;Commitme
nt to Fair Housing
DPP
Draft report re:
Neighborhood
Demographics;Commitme
nt to Fair Housing
AC

Attorney
NYCPRIV0 Client;Deliberative;Work
Product
288 NYC_0085819 3237

Email chain re: Litigation Anticipated Litigation re:
Community
Preference;Litigation Other;AFFH and
Community
Preference;Commitment AC &
to Fair Housing
WP

286

289

NYCPRIV0
Deliberative
3226

NYCPRIV0
3240
Attorney Client;Deliberative

Draft report re:
Commitment to Fair
Housing

WP &
DPP

draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
Draft of information for
2012 consolidated plan
submitted to attorneys
for advice

Communication with
attorney re: draft
submission to HUD and
legal issues re: same
draft submission to HUD
re AFFH seeking
comments of multiple
agencies to submit to
legal

290

NYCPRIV0
3250
Deliberative

Draft letter re: Antidisplacement
strategies;Commitment to
Fair Housing
DPP

291

NYCPRIV0
3264
Attorney Client;Deliberative

Draft report re:
Commitment to Fair
Housing

WP &
DPP

292

NYCPRIV0
3265
Attorney Client;Deliberative

Draft report re:
Commitment to Fair
Housing

WP &
DPP

NYCPRIV0 Attorney Client
3277
(withdrawn);Deliberative

Draft report re: Antidisplacement
strategies;Commitment to
Fair Housing
DPP

draft of strategic plan for
2015-2019 and potential
actions for Consolidated
Plan years; DO NOT
PRODUCE UNDER
RODRIGUEZ
draft submission to HUD
re AFFH seeking
comments of multiple
agencies to submit to
legal
draft submission to HUD
re AFFH seeking
comments do multiple
agencies to submit to
legal
AC withdrawn; draft of
housing plan; final
publicly available; DO
NOT PRODUCE UNDER
RODRIGUEZ

NYCPRIV0
3280
Deliberative

Draft report re: Antidisplacement
strategies;Commitment to
Fair Housing
DPP

working draft for
anticipated 10-year
affordable housing plan;
DO NOT PRODUCE
UNDER RODRIGUEZ

293

294

295

NYCPRIV0
3283
Attorney Client;Deliberative

296

NYCPRIV0
Deliberative
3284

297

NYCPRIV0
3294
Deliberative

298

NYCPRIV0
Attorney Client;Deliberative
1896

NYCPRIV0
Deliberative
299 NYC_0080435 3314

300

NYCPRIV0
3319
Attorney Client;Deliberative

Draft talking points re: Antidisplacement
strategies;Commitment to AC &
Fair Housing
DPP

Draft report re: MIH mobility
DPP
Draft talking points re: Antidisplacement
strategies;Commitment to
Fair Housing
NP

Final report (non-public)
re: Anti-displacement
strategies

NP

Strategy slide re: East NY
Community Plan and
Housing NY

AC &
DPP

draft decision memo to
mayor re: creation of MIH
program and
seeking/reflecting legal
advice

Draft Internal
Memorandum re: MIH Anti-displacement
strategies;Application of
Community Preference

NP

communications re:
policy considerations for
anticipated MIH policy;
DO NOT PRODUCE
UNDER RODRIGUEZ
emails concerning
presentation for Oct. 23
retreat

NP

Per City's Agreement

NP

transition memo re:
development in various
neighborhoods

302

NYCPRIV0
3347
Deliberative

303

NYCPRIV0
3348
Deliberative

304

NYCPRIV0
3359
Deliberative

Email chain re: 421-a 2015/2016 revision
Email chain re:
Neighborhood
Demographics
Draft report re:
Neighborhood
Demographics
Draft Internal
Memorandum re: North
Brooklyn Rezoning and
Demographics

NYCPRIV0
3369
Deliberative

Final letter (non-public) re:
ENY - Anti-displacement
strategies;ENY Community opposition
NP

NYCPRIV0
3370
Attorney Client;Deliberative

307

NYCPRIV0
3373
Deliberative

draft Q&A re: 10-year
housing plan under
deBlasio and MIH

Draft Document re: MIH - AC &
mobility
DPP

NYCPRIV0
3337
Deliberative

306

draft outline concerning
MIH policy considerations
and action items; DO
NOT PRODUCE UNDER
RODRIGUEZ

communication with
counsel and others
seeking comments on
draft document re: MIH

301

305

draft of Q&As re: not yet
final housing plan sent to
counsel for review and
comment

DPP

Draft report re: MIH - Antidisplacement
strategies;Application of
AC &
Community Preference
DPP
Draft letter re: MIH - Antidisplacement
strategies;MIH Community opposition
NP

letter from office of
comptroller to city
planning re: East NY
Community plan and MIH
draft of possible
modifications to MIH
plan submitted to
counsel for advice and
comment

Per City's Agreement

308

NYCPRIV0
Deliberative
3374

309

NYCPRIV0
3390
Deliberative

Draft letter re: ENY - Antidisplacement
strategies;ENY Community
opposition;ENY Investment in
Communities
DPP
Final letter (non-public) re:
Community Opposition
Strategies
NP

310

NYCPRIV0
Deliberative
3396

Draft talking points re: ENY
- Anti-displacement
strategies;ENY Investment in
Communities;Application
of Community Preference NP

311

NYCPRIV0
3406
Deliberative

312

NYCPRIV0
3407
Deliberative

Draft talking points re:
MIH - Anti-displacement
strategies
Final talking points (nonpublic) re: MIH - Antidisplacement
strategies;421-a Homeless Preference

313

NYCPRIV0
3410
Deliberative

Draft report re: ENY - Antidisplacement
strategies;ENY Community opposition
NP

314

NYCPRIV0
3413
Deliberative

315

NYCPRIV0
3415
Deliberative

NYCPRIV0
Deliberative
316 NYC_0081650 3416

317

NYCPRIV0
3417
Deliberative

318

NYCPRIV0
3418
Deliberative

Draft report re:
Neighborhood
Demographics
Draft report re:
Neighborhood
Demographics

Draft report re: Antidisplacement strategies
Draft report re:
Neighborhood
Demographics
Draft report re:
Neighborhood
Demographics

NP

internal draft letter in
response to comptroller
concerns re: East NY
Community plan and
MIH; produce final; draft
DO NOT PRODUCE
UNDER RODRIGUEZ
letter from City Counsel
re: rezoning in Bushwick

presentation to mayor in
advance for a town hall
meeting

DPP

Q&As for meeting on
senior housing
draft of East NY
affordable housing plan
seeking public input to
refine plan for public
review
draft memo including
recommendations for
land use, zoning, and
other matters in
connection with
affordable housing in East
New York; DO NOT
PRODUCE UNDER
RODRIGUEZ

DPP

SAME AS 314

DPP

highlighted internal
summary of possible
changes to policies
affecting affordable
housing in Crown Heights
West; DO NOT PRODUCE
UNDER RODRIGUEZ

DPP

SAME AS 314

DPP

SAME AS 314

NP

319

NYCPRIV0
3419
Deliberative

320

NYCPRIV0
3420
Deliberative

Draft report re:
Neighborhood
Demographics
Draft report re:
Neighborhood
Demographics

321

NYCPRIV0
3422
Attorney Client

Email chain re: Application
of Community Preference NP

322

NYCPRIV0
3426
Deliberative

Draft report re: Application
of Community Preference DPP

DPP

SAME AS 314

DPP

SAME AS 314
not conveying legal
advice or seeking legal
advice
Project briefing memo for
Hunter's Point South
development for
decisionmaking
concerning affordable
housing strategies in
neighborhood; DO NOT
PRODUCE UNDER
RODRIGUEZ

323

NYCPRIV0 Deliberative;Work Product
1910
(withdrawn)

Draft presentation re:
Litigation - Anticipated
Litigation re: Community
Preference

324

NYCPRIV0
3430
Deliberative

Draft report re:
Commitment to Fair
Housing

325

NYCPRIV0
3436
Deliberative

Draft report re: Antidisplacement
strategies;Commitment to
Fair Housing
DPP

326

NYCPRIV0
3456
Deliberative

Draft report re: Antidisplacement strategies

DPP

Withdrawing WP; draft of
Fair Housing Assessment
Tool outline reflecting
internal thoughts
regarding how to comply
with 2015 rule change;
DO NOT PRODUCE
UNDER RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ

327

NYCPRIV0
1911
Deliberative

Final report (non-public)
re: Anti-displacement
strategies

NP

report on public housing
needs

NYCPRIV0
3478
Work Product

Draft report re: Litigation Anticipated Litigation re:
Community
Preference;Application of
Community Preference
NP

328

DPP

DPP

Per City's Agreement

329

NYCPRIV0
3481
Deliberative

Draft report re: Antidisplacement
strategies;Neighborhood
Demographics;Commitme
nt to Fair Housing
DPP

330

NYCPRIV0
3487
Deliberative

Draft report re:
Commitment to Fair
Housing

331

NYCPRIV0
Deliberative
3499

Draft report re: Antidisplacement
strategies;Commitment to
Fair Housing
DPP

332

NYCPRIV0
3590
Deliberative

333

NYCPRIV0
3600
Deliberative

DPP

Draft report re:
Commitment to Fair
Housing
DPP
Internal Memorandum re:
AFFH and Community
Preference
NP

334

NYCPRIV0
3634
Deliberative

Draft report re:
Commitment to Fair
Housing

DPP

335

NYCPRIV0
3703
Deliberative

Draft report re:
Commitment to Fair
Housing

DPP

336

NYCPRIV0
3710
Deliberative

Draft report re: Antidisplacement
strategies;Commitment to
Fair Housing
DPP

337

NYCPRIV0
3761
Deliberative

Draft report re:

DPP

338

NYCPRIV0
3766
Deliberative

Draft report re:
Commitment to Fair
Housing

DPP

NYCPRIV0
3904
Deliberative

Draft report re:
Neighborhood
Demographics;Commitme
nt to Fair Housing
DPP

339

draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ

draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ
draft language for
including in AFFH
Consolidated Plan; DO
NOT PRODUCE UNDER
RODRIGUEZ

Draft portion of 10-year
housing plan; produce
final 10-YEAR PLAN; DO
NOT PRODUCE UNDER
RODRIGUEZ

340

NYCPRIV0
2191
Deliberative

341

NYCPRIV0
2395
Deliberative

Draft report re: MIH - Antidisplacement
strategies;MIH Community opposition
DPP
Internal Memorandum re:
Litigation - Winfield
Litigation
NP

342

NYCPRIV0
2396
Attorney Client

Email chain re: Application
of Community Preference NP

Per City's Agreement
not conveying legal
advice or seeking legal
advice

draft Q&A on Housing NY
and MIH
questions for agencies for
purposes of HPD
affordable housing
planning

343

NYCPRIV0
2193
Deliberative

344

NYCPRIV0
2200
Deliberative

Draft talking points re:
MIH - Anti-displacement
strategies;MIH Community opposition
NP
Internal Memorandum re:
Anti-displacement
strategies;Community
Opposition Strategies
NP

345

NYCPRIV0
1952
Legislative

Draft Document re: ENY Anti-displacement
strategies;ENY - City
council input;Application
of Community Preference NP

346

NYCPRIV0
1971
Attorney Client;Deliberative

Internal Memorandum re:
Application of Community AC &
Preference
DPP

Per City's Agreement
draft decision memo to
mayor re: creation of MIH
program and
seeking/reflecting legal
advice

Draft talking points re: Antidisplacement strategies
NP

document provided by
CM Brad Landers about
possible bill protecting
tenants from harassment

Draft Internal
Memorandum re: Antidisplacement strategies

DPP

decision memo to mayor
to guide decision re:
Bedford Armory Project;
DO NOT PRODUCE
UNDER RODRIGUEZ

AC

Withdrawing legislative
privilege;
communications with
counsel and others
concerning response to
request from CM
regarding certain AMI
units under MIH policy;
reflects legal advice

347

348

349

NYCPRIV0
2261
Deliberative;Legislative

NYCPRIV0
2283
Deliberative;Legislative

NYCPRIV0
2301
Attorney Client;Legislative

Email chain re: MIH Community opposition

350

351

352

353
354

NYCPRIV0
2037
Deliberative;Legislative

Draft Document re: ENY Anti-displacement
strategies;Application of
Community Preference
NP

NYCPRIV0
2302
Deliberative;Legislative

Email chain re: Antidisplacement strategies;
ENY - Anti-displacement
strategies

NYCPRIV0
2040
Deliberative
NYCPRIV0
2355
Attorney Client;Deliberative
NYCPRIV0
2360
Deliberative

draft outline of issues to
inform decisions re: East
New York development

DPP &
Legislat
ive

Email chain re: MIH - Antidisplacement strategies
NP
Draft talking points re:
421-a - Homeless
Preference
NP
Email chain re: 421-a Homeless Preference
NP

communications re: state
of the city address
highlights as talking
points to press

Per City's Agreement
Per city's Agreement
communication re: East
Harlem Displacement
number error in
connection with
preparing scope of work
for RFP; PRODUCE
UNDER RODRIGUEZ
communications re:
albany housing agenda
presentation and mayor's
talk with Castro about
CPP

355

NYCPRIV0
2362
Deliberative

Email chain re: Antidisplacement strategies

356

NYCPRIV0
2063
Deliberative

Email chain re: Application
of Community Preference NP

357

Attorney
NYCPRIV0 Client;Deliberative;Work
2066
Product

Draft Internal
Memorandum re: MIH Anti-displacement
strategies; Litigation Anticipated Litigation re:
Community Preference

358

NYCPRIV0
2393
Deliberative;Legislative

draft decision memo to
mayor re: creation of MIH
program and
seeking/reflecting legal
AC &
DPP
advice
version of proposed bill
advocated by
Administation to prevent
DPP & Tenant harassment;
Draft talking points re: Anti- Legislat PRODUCE UNDER
displacement strategies
ive
RODRIGUEZ

359

Attorney
NYCPRIV0 Client;Deliberative;Work
2398
Product

Draft presentation re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation Winfield Litigation

360

NYCPRIV0
3973
Attorney Client

Email chain re: Community
Opposition Strategies
NP

DPP

AC &
WP

draft of document
analyzing settlement
options

Per City's Agreement

361

NYCPRIV0
Attorney Client;Deliberative
2079

362

NYCPRIV0
Deliberative
2086

Draft Internal
Memorandum re:
Commitment to Fair
AC &
Housing
DPP
Draft talking points re:
Application of Community
Preference
NP

NYCPRIV0
Attorney Client;Deliberative
2087

Draft Internal
Memorandum re:
Commitment to Fair
Housing

AC &
DPP

364

NYCPRIV0
2088
Attorney Client;Deliberative

Draft Internal
Memorandum re:
Commitment to Fair
Housing

AC &
DPP

365

NYCPRIV0
2412
Deliberative

366

NYCPRIV0
2487
Work Product

363

368

NYCPRIV0
2488
Work Product
NYCPRIV0
2490
Work Product

369

NYCPRIV0
2491
Deliberative;Work Product

370

NYCPRIV0
2493
Deliberative;Work Product

371

NYCPRIV0
2496
Deliberative;Work Product

372

NYCPRIV0
2497
Deliberative;Work Product

373

NYCPRIV0
2498
Deliberative;Work Product

367

Draft Document re: Antidisplacement strategies
Internal Memorandum re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Memorandum re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Notes re: Litigation Winfield Litigation
Internal Memorandum re:
Litigation - Winfield
Litigation;Application of
Community
Preference;Housing
Connect Data Analysis
Internal Memorandum re:
Litigation - Winfield
Litigation;Application of
Community
Preference;Housing
Connect Data Analysis
Draft report re: Litigation Winfield Litigation
Draft presentation re:
Litigation - Winfield
Litigation;Application of
Community
Preference;Housing
Connect Data Analysis
Draft presentation re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis

draft decision memo to
mayor re: creation of MIH
program and
seeking/reflecting legal
advice

NP

Per City's Agreement
draft decision memo to
mayor re: creation of MIH
program and
seeking/reflecting legal
advice
draft decision memo to
mayor re: creation of MIH
program and
seeking/reflecting legal
advice
draft submission to
receive an award for
innovations in
government - public
engagement unit
submission

WP

Analysis for informing
litigation strategy

WP

Analysis for informing
litigation strategy
Analysis for informing
litigation strategy

WP

technical notes for
housing study for
litigation

WP

WP &
DPP

technical notes for
housing study for
litigation
internal deliberations
regarding analysis for
litigation

NP

Per City's Agreement

NP

Per City's Agreement

WP

374

NYCPRIV0
2501
Deliberative;Work Product

375

NYCPRIV0
Deliberative;Work Product
2502

376

NYCPRIV0
Deliberative;Work Product
2504

Draft report re: Litigation Winfield Litigation;Housing
Connect Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Draft presentation re:
Litigation - Winfield
Litigation;Application of
Community
Preference;Housing
Connect Data Analysis

NP
WP &
DPP

Per City's Agreement
analysis to inform
litigation strategy and
settlement

NP

Per City's Agreement

377

NYCPRIV0
2506
Deliberative;Work Product

Draft report re: Litigation - WP &
Winfield Litigation
DPP

Internal presentation of
internal study of various
data conducted to inform
litigation strategy and
settlement position in
Winfield

378

NYCPRIV0
2507
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing
Connect Data Analysis
NP

Per City's Agreement

379

NYCPRIV0
2508
Deliberative;Work Product

380

NYCPRIV0
2510
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing WP &
Connect Data Analysis
DPP
Draft presentation re:
Litigation - Winfield
Litigation;Application of
Community
Preference;Housing
Connect Data Analysis
NP

analysis to inform
litigation strategy and
settlement

Per City's Agreement
Internal presentation of
internal study of various
data conducted to inform
litigation strategy and
settlement position in
Winfield

381

NYCPRIV0
2511
Deliberative;Work Product

382

NYCPRIV0
2513
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing WP &
Connect Data Analysis
DPP
Draft presentation re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
NP

383

NYCPRIV0
2515
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing WP &
Connect Data Analysis
DPP

analysis to inform
litigation strategy and
settlement

384

NYCPRIV0
2526
Deliberative;Work Product

WP &
DPP

analysis to inform
litigation strategy and
settlement

385

NYCPRIV0
2527
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing
Connect Data Analysis
Draft presentation re:
Litigation - Winfield
Litigation;Application of
Community
Preference;Housing
Connect Data Analysis

WP &
DPP

analysis to inform
litigation strategy and
settlement

Per City's Agreement

386

NYCPRIV0
2536
Deliberative;Work Product

387

NYCPRIV0
2537
Deliberative;Work Product

388

NYCPRIV0
2538
Deliberative;Work Product

389

NYCPRIV0
Deliberative;Work Product
2540

390

NYCPRIV0
2542
Deliberative;Work Product

391

NYCPRIV0
2543
Deliberative;Work Product

392

NYCPRIV0
2546
Deliberative;Work Product

393

NYCPRIV0
2558
Deliberative;Work Product

394

NYCPRIV0
2559
Deliberative;Work Product

395

NYCPRIV0
2560
Deliberative;Work Product

396

NYCPRIV0
2575
Deliberative;Work Product

397

NYCPRIV0
2576
Deliberative;Work Product

398

NYCPRIV0
2577
Deliberative;Work Product

Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect WP &
Data Analysis
DPP
Draft report re: Litigation Winfield Litigation;Housing
Connect Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Draft report re: Litigation Winfield Litigation;Housing
Connect Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Draft report re: Litigation Winfield Litigation;Housing
Connect Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Draft report re: Litigation Winfield
Litigation;Application of
Community
Preference;Housing
Connect Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Draft report re: Litigation Winfield Litigation;Housing
Connect Data Analysis
Draft report re: Litigation Winfield
Litigation;Application of
Community
Preference;Housing
Connect Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

Draft report re: Litigation Winfield
Litigation;Application of
Community
Preference;Housing
Connect Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigatoin strategy and
settlement

399

NYCPRIV0
2578
Deliberative;Work Product

400

NYCPRIV0
Deliberative;Work Product
2579

401

NYCPRIV0
2580
Deliberative;Work Product

402

NYCPRIV0
Deliberative;Work Product
2581

403

NYCPRIV0
2582
Deliberative;Work Product

404

NYCPRIV0
2583
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing
Connect Data Analysis
Draft Internal
Memorandum re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Draft report re: Litigation Winfield
Litigation;Application of
Community
Preference;Housing
Connect Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis

WP &
DPP

analysis to inform
litigation strategy and
settlement

405

NYCPRIV0
2584
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing WP &
Connect Data Analysis
DPP

analysis to inform
litigation strategy and
settlement

406

NYCPRIV0
2585
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing WP &
Connect Data Analysis
DPP

analysis to inform
litigation strategy and
settlement

407

NYCPRIV0
2586
Deliberative;Work Product

WP &
DPP

analysis to inform
litigation strategy and
settlement

408

NYCPRIV0
2587
Deliberative;Work Product

WP &
DPP

analysis to inform
litigation strategy and
settlement

409

NYCPRIV0
3974
Deliberative;Work Product

WP &
DPP

analysis to inform
litigation strategy and
settlement

410

NYCPRIV0
2588
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing
Connect Data Analysis
Draft report re: Litigation Winfield
Litigation;Application of
Community
Preference;Housing
Connect Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Draft report re: Litigation Winfield
Litigation;Application of
Community
Preference;Housing
Connect Data Analysis

WP &
DPP

analysis to inform
litigation strategy and
settlement

411

NYCPRIV0
2589
Deliberative;Work Product

Draft report re: Litigation Winfield
Litigation;Application of
Community
Preference;Housing
WP &
Connect Data Analysis
DPP

analysis to inform
litigation strategy and
settlement

412

NYCPRIV0
Deliberative;Work Product
2590

Draft report re: Litigation Winfield Litigation;Housing WP &
Connect Data Analysis
DPP

analysis to inform
litigation strategy and
settlement

413

NYCPRIV0
2591
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing WP &
Connect Data Analysis
DPP

analysis to inform
litigation strategy and
settlement

414

NYCPRIV0
2592
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing WP &
Connect Data Analysis
DPP

analysis to inform
litigation strategy and
settlement

415

NYCPRIV0
2593
Deliberative;Work Product

WP &
DPP

analysis to inform
litigation strategy and
settlement

416

NYCPRIV0
2595
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing
Connect Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis

WP &
DPP

analysis to inform
litigation strategy and
settlement

417

NYCPRIV0
2596
Deliberative;Work Product

WP &
DPP

analysis to inform
litigation strategy and
settlement

418

NYCPRIV0
2597
Deliberative;Work Product

WP &
DPP

analysis to inform
litigation strategy and
settlement

419

NYCPRIV0
2602
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing
Connect Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis

WP &
DPP

analysis to inform
litigation strategy and
settlement

420

NYCPRIV0
2605
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing WP &
Connect Data Analysis
DPP

analysis to inform
litigation strategy and
settlement

421

NYCPRIV0
2606
Deliberative;Work Product

WP &
DPP

analysis to inform
litigation strategy and
settlement

422

NYCPRIV0
2610
Deliberative;Work Product

WP &
DPP

analysis to inform
litigation strategy and
settlement

423

NYCPRIV0
2611
Deliberative;Work Product

WP &
DPP

analysis to inform
litigation strategy and
settlement

424

NYCPRIV0
2612
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing
Connect Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis

WP &
DPP

analysis to inform
litigation strategy and
settlement

425

NYCPRIV0
2613
Deliberative;Work Product

426

NYCPRIV0
Deliberative;Work Product
2614

427

NYCPRIV0
2615
Deliberative;Work Product

428

NYCPRIV0
2617
Deliberative;Work Product

429

NYCPRIV0
Deliberative;Work Product
2619

430

NYCPRIV0
2620
Deliberative;Work Product

431

NYCPRIV0
2621
Deliberative;Work Product

432

NYCPRIV0
2622
Deliberative;Work Product

433

NYCPRIV0
2655
Deliberative;Work Product

Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

434

NYCPRIV0
2656
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing WP &
Connect Data Analysis
DPP

435

NYCPRIV0
2657
Deliberative;Work Product

436

NYCPRIV0
2658
Deliberative;Work Product

437

NYCPRIV0
2659
Deliberative;Work Product

438

NYCPRIV0
2660
Deliberative;Work Product

439

NYCPRIV0
2668
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation
Draft Document re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Draft Document re:
Litigation - Winfield
Litigation;AFFH and
Community
Preference;Housing
Connect Data Analysis

WP &
DPP

analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

Draft report re: Litigation Winfield Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation

WP &
DPP
WP &
DPP

framework for analysis to
inform litigaton strategy
and settlement
analysis to inform
litigation strategy and
settlement

440

NYCPRIV0
2669
Deliberative;Work Product

441

NYCPRIV0
2670
Deliberative;Work Product

442

NYCPRIV0
2671
Deliberative;Work Product

443

NYCPRIV0
2672
Deliberative;Work Product

444

NYCPRIV0
2673
Work Product

445

NYCPRIV0
2674
Deliberative;Work Product

446

NYCPRIV0
2676
Deliberative;Work Product

447

NYCPRIV0
2679
Work Product

448

NYCPRIV0
2680
Work Product

449

NYCPRIV0
2681
Deliberative;Work Product

450

NYCPRIV0
2682
Deliberative;Work Product

451

NYCPRIV0
2686
Deliberative;Work Product

452

NYCPRIV0
2687
Deliberative;Work Product

453

NYCPRIV0
2692
Work Product

454

NYCPRIV0
2695
Deliberative;Work Product

455

NYCPRIV0
2696
Deliberative;Work Product

456

NYCPRIV0
2700
Deliberative;Work Product

457

NYCPRIV0
2701
Deliberative;Work Product

458

NYCPRIV0
2702
Deliberative;Work Product

Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation

WP &
DPP
WP &
DPP
WP &
DPP
WP &
DPP

analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement

WP &
DPP

Analysis for informing
litigation strategy
analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement

WP

Analysis for information
litigation strategy

WP
WP &
DPP

WP
WP &
DPP
WP &
DPP
WP &
DPP
WP &
DPP

WP
WP &
DPP
WP &
DPP
WP &
DPP
WP &
DPP
WP &
DPP

Analysis for informing
litigation strategy
analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement

Analysis for informing
litigation strategy
analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement

459

NYCPRIV0
2703
Deliberative;Work Product

460

NYCPRIV0
2704
Deliberative;Work Product

461

NYCPRIV0
Deliberative;Work Product
2746

462

NYCPRIV0
Work Product
2747

463

NYCPRIV0
2748
Deliberative

Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Internal Charts or Maps re:
Anti-displacement
strategies; Litigation Winfield Litigation
Internal Charts or Maps re:
Litigation - Winfield
Litigation;AFFH and
Community
Preference;Housing
Connect Data Analysis
Internal Charts or Maps re:
Litigation - Winfield
Litigation;AFFH and
Community Preference

WP &
DPP

analysis to inform
litigation strategy and
settlement
analysis to inform
litigation strategy and
settlement

WP &
DPP

analysis to inform
litigation strategy and
settlement

WP

Analysis for informing
litigation strategy

WP

draft data analysis to
inform litigation strategy
and settlement

464

NYCPRIV0
2749
Deliberative;Work Product

Draft report re: Litigation Winfield Litigation;Housing WP &
Connect Data Analysis
DPP

analysis to inform
litigation strategy and
settlement

describes housing and
neighborhood study
conducted for purposes
of evaluating impact of
subsidized housing on
health and well being and
school performance;
PRODUCE UNDER
RODRIGUEZ

WP &
DPP

465

NYCPRIV0
2760
Deliberative

Final report (non-public)
re: Application of
Community
Preference;Housing
Connect Data Analysis

466

NYCPRIV0
2753
Work Product

Notes re: Litigation Winfield Litigation;Housing
Connect Data Analysis
WP

Analysis for informing
litigation strategy

467

NYCPRIV0
2754
Work Product

Draft Document re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
WP

Analysis for informing
litigation strategy; in
anticipation of litigation;
FOIL request from
plaintiff's counsel

468

NYCPRIV0
3990
Work Product

Notes re: Litigation Winfield Litigation;Housing
Connect Data Analysis
WP

created to respond to
FOIL request made by
Gurion

469

NYCPRIV0
2755
Work Product

470

NYCPRIV0
2093
Attorney Client;Deliberative

Draft report re: Litigation Winfield Litigation
WP
Draft Internal
Memorandum re:
Commitment to Fair
AC &
Housing
DPP

Analysis for informing
litigation strategy
decision memo to mayor
re: MIH
seeking/reflecting legal
advice

DPP

471

472

NYCPRIV0
3991
Deliberative

Draft letter re: Antidisplacement
strategies;421-a Homeless Preference

NYCPRIV0
Attorney Client;Deliberative
3992

Draft Internal
Memorandum re: MIH Anti-displacement
strategies;Application of
Community Preference

NP

Draft letter from Mayor
to constituents re:
affordable housing

AC &
DPP

draft decision memo to
mayor re: creation of MIH
program and
seeking/reflecting legal
advice
Decision memo to mayor
re: how to engage with
private applications
subject to MIH at Barnett
Ave.; DO NOT PRODUCE
UNDER RODRIGUEZ

NYCPRIV0
3998
Deliberative

Draft report re: MIH - Antidisplacement
strategies;Application of
Community Preference
DPP

474

NYCPRIV0
4004
Deliberative

Final letter (non-public) re:
MIH - Anti-displacement
strategies;ENY - Antidisplacement strategies
NP

475

NYCPRIV0
4007
Deliberative

Draft talking points re: Antidisplacement strategies
NP

produce; same as 310
draft Q&As re:
afffordable housing in
connection with 2015
mayor state of city
address

NYCPRIV0
4016
Attorney Client

Draft report re: Antidisplacement
strategies;ENY - Antidisplacement strategies

communication from
attorney summarizing
thoughts and next steps
on affordable housing in
specific neighborhood

473

476

AC

NYCPRIV0
4082
Attorney Client;Deliberative

Email chain re: Antidisplacement
strategies;Commitment to
Fair Housing
DPP

communication re: draft
RFP for HRA program
reflecting comments and
revisions; DO NOT
PRODUCE UNDER
RODRIGUEZ

478

NYCPRIV0
4088
Attorney Client;Deliberative

Draft report re: Antidisplacement
strategies;Commitment to
Fair Housing
AC

attorney comments and
revisions to antiharassment tenant
protection program RFP

479

NYCPRIV0
4089
Deliberative

Email chain re: Antidisplacement strategies

communications re: draft
press release for legal
services for tenants

NYCPRIV0
4090
Attorney Client;Deliberative

Draft report re: Antidisplacement
strategies;Commitment to
Fair Housing
AC

477

480

NP

attorney comments and
revisions to antiharassment tenant
protection program RFP

attorney comments and
revisions to antiharassment tenant
protection program RFP
testimony of Jordan
Dressler before NYC
Council committee on
2017 budget

481

NYCPRIV0
Deliberative
4107

482

NYCPRIV0
4114
Deliberative

483

NYCPRIV0
2432
Work Product

Draft report re:
Commitment to Fair
Housing
AC
Draft talking points re: Antidisplacement
strategies;Commitment to
Fair HousingNP
NP
Draft Internal
Memorandum;Notes re:
Anti-displacement
strategies; Litigation Anticipated Litigation re:
Community
Preference;Litigation Winfield Litigation
WP

NYCPRIV0
2433
Deliberative;Work Product

Draft report;Internal
Charts or Maps re:
Litigation - Winfield
Litigation;Application of
Community Preference

485

NYCPRIV0
2434
Attorney Client;Deliberative

Email chain;Notes re: 421a - Homeless
Preference;Application of
Community Preference
AC

discussing settlement
options in this case
Communication
concerning topic for
which legal advice is
sought re: application of
CPP a certain lottery
applicant

486

NYCPRIV0
2436
Work Product

Draft report re: Litigation Winfield Litigation
WP

Atty questions re: CPP
and statistical tests

487

NYCPRIV0
2440
Deliberative;Work Product

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation WP &
Winfield Litigation
DPP

488

NYCPRIV0
2442
Deliberative;Work Product

489

NYCPRIV0
2443
Work Product

Notes re: Litigation WP &
Winfield Litigation
DPP
Internal Charts or Maps re:
Litigation - Winfield
Litigation;Housing Connect
Data Analysis
WP

NYCPRIV0
2444
Deliberative;Work Product

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation WP &
Winfield Litigation
DPP

analysis to inform
litigation strategy and
settlement

NYCPRIV0
2445
Deliberative;Work Product

Draft report;Notes re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation Winfield Litigation

notes discussing metrics
for analysis in case

484

490

491

WP &
DPP

WP &
DPP

Research for informing
litigation strategy and
settlement position

analysis to inform
litigation strategy and
settlement
notes discussing
settlement options in this
case

Analysis for informing
litigation strategy

492

NYCPRIV0
2446
Deliberative;Work Product

Internal Charts or Maps re:
Litigation - Anticipated
Litigation re: Community
Preference;Litigation WP &
Winfield Litigation
DPP

DPP

description of studies
about gentrification &
displacement relevant to
case analysis
Internal working notes
reflecting
questions/considerations
in determining
implementation of
certain preferences; DO
NOT PRODUCE UNDER
RODRIGUEZ

NP

notes on draft talking
points about Inwood
Neighborhood study

DPP

notes from neighborhood
strategies team meeting
about preserving
housing; reflects internal
discussions about policy
strategies; DO NOT
PRODUCE UNDER
RODRIGUEZ

DPP

action steps and
strategies related to
homeless prevention
policy; DO NOT PRODUCE
UNDER RODRIGUEZ

WP

Legal analysis and
settlement strategies

NP

Per City's Agreement
(except p. 5 which are
attorney notes)

WP

Legal analysis and
settlement strategies

493

NYCPRIV0
2447
Deliberative;Work Product

Draft report re: Litigation - WP &
Winfield Litigation
DPP

494

NYCPRIV0
Deliberative;Legislative
2449

Notes re: 421-a Homeless Preference

495

NYCPRIV0
2453
Deliberative

Draft talking points;Draft
Document re: Antidisplacement strategies

496

NYCPRIV0
2454
Deliberative

497

NYCPRIV0
4118
Deliberative

498

NYCPRIV0
2481
Work Product

499

Attorney
NYCPRIV0 Client;Deliberative;Work
2482
Product

500

NYCPRIV0
2485
Work Product

Notes;Internal
Memorandum re:
Community Opposition
Strategies

Notes re: Antidisplacement strategies
Internal Charts or Maps re:
Litigation - Winfield
Litigation
Notes;Draft Document re:
Litigation - Winfield
Litigation;Commitment to
Fair Housing
Draft Document re:
Litigation - Winfield
Litigation

analysis to inform
litigation strategy and
settlement