Opinion
15-cv-05236 (LTS) (KHP)
12-18-2018
SHAUNA NOEL, et al Plaintiffs, v. CITY OF NEW YORK, Defendant.
OPINION AND ORDER 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) attorney-client privilege, (2) work product protection, (3) deliberative process privilege, and (4) 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.
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.
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- 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 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, 26, 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 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
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. --------
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).
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, 195-201-211, 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, 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." 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 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-cv-10533 (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, 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 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 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 information-gathering 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 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 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
/s/_________
KATHARINE H. PARKER
United States Magistrate Judge
Sort Production Beginning Bates Control ID Privilege(s) Categorical Description Court Decisio n Court's Summary Description of Nature of Document 0 NYCPRIV0 3014 Attorney Client;Deliberative Draft Internal Memorandum re: AFFH and Community Preference NP communication among counsel and others re: delegation of responsibilities for responding to plaintiff's counsel letter re: fair housing policies 1 NYC_0067299 Deliberative Draft talking points re: 421-a - Homeless Preference NP Per City's Agreement 2 NYC_0067300 Deliberative Draft talking points re: 421-a - Homeless Preference NP 3 NYCPRIV0 0004 Attorney Client 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 Opposition Strategies AC & 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 6 NYCPRIV0 0016 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Application of Community Preference WP & DPP Settlement Options Analysis 7 NYCPRIV0 0017 Deliberative;Work Product Draft Internal Memorandum re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP Settlement Options Analysis 8 NYCPRIV0 0018 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Application of Community Preference WP & DPP Settlement Options Analysis 9 NYCPRIV0 0023 Deliberative Draft Internal Memorandum re: 421-a - Homeless Preference DPP Draft decision memo to mayor regarding homeless unit commitment 16 10 NYCPRIV0 0025 Work Product Email chain re: Litigation - Winfield Litigation WP Communication about preparation for legal strategy meeting with Mayor about this litigation 11 NYCPRIV0 0026 Deliberative;Work Product Draft presentation re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP Litigation Strategy Document 12 NYCPRIV0 0047 Deliberative Email chain re: 421-a - Homeless Preference DPP communication regarding potential policy re: 421a units; PRODUCE UNDER RODRIGUEZ 13 NYCPRIV0 0061 Attorney Client Draft talking points re: MIH - Anti-displacement strategies;Anti- displacement strategies NP Per City's Agreement 14 NYC_0083074 NYCPRIV0 0063 Deliberative;Legislative Draft talking points re: MIH - mobility;MIH - Community opposition;MIH - City council input NP Per City's Agreement 15 NYCPRIV0 0067 Work Product Email chain re: Litigation - Winfield Litigation WP 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 Draft report re: Litigation - Winfield Litigation;Application of Community Preference WP & DPP Settlement Options Analysis 18 NYCPRIV0 0074 Attorney Client;Deliberative;Work Product Draft Internal Memorandum re: MIH - Anti-displacement strategies; Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation;Community Opposition Strategies AC draft decision memo to mayor re: rezonings in specific neighborhoods containing legal advice 19 19 NYCPRIV0 0075 Attorney Client;Deliberative;Work Product Draft Internal Memorandum re: MIH - Anti-displacement strategies; Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation;Community Opposition Strategies AC draft decision memo to mayor re: rezonings in specific neighborhoods containing legal advice 17 20 NYCPRIV0 0083 Deliberative;Legislative Final talking points (non- public) re: MIH - Anti- displacement strategies;MIH - City council input NP internal documents setting forth admin. position to certain issues; shared with CM 21 NYCPRIV0 0095 Deliberative;Legislative Draft report re: MIH - City council input DPP draft considerations for potential modification to MIH; DO NOT PRODUCE UNDER RODRIGUEZ 22 NYC_0032942 Attorney Client 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 25 NYCPRIV0 0474 Attorney Client Email chain re: Application of Community Preference AC draft language regarding housing ad sent to counsel for legal review and comment 26 NYCPRIV0 2106 Attorney Client;Deliberative Email chain re: 421-a - Homeless Preference AC in part internal communications describing issue on which legal advice sought pertaining to lotteries can be redacted; document otherwise must be produced 27 NYCPRIV0 0482 Attorney Client;Deliberative Email chain re: Application of Community Preference AC communications with attorney and others concerning modifications to CPP in context of preservation projects 28 NYCPRIV0 0483 Attorney Client;Deliberative Email chain re: Application of Community Preference AC communications with attorney and others concerning modifications to CPP in context of preservation projects 29 NYC_0033138 Attorney Client;Deliberative Draft report re: 421-a - 2015/2016 revision AC attorney summary and advice re: 421-a 18 30 NYCPRIV0 0501 Attorney Client Draft talking points re: 421-a - Homeless Preference AC Draft of document concerning homeless referrals to 421-a projects reflecting legal advice 31 NYCPRIV0 2108 Attorney Client;Deliberative Email chain re: 421-a - Homeless Preference;Application of Community Preference AC communications reflecting legal advice re: 421-a 32 NYCPRIV0 0106 Attorney Client;Deliberative Draft talking points re: 421-a - Homeless Preference AC Draft of documents concerning homeless referrals to 421-a projects reflecting legal advice sought 33 NYCPRIV0 0108 Attorney Client;Deliberative Email chain re: 421-a - Homeless Preference AC emails with counsel and others; seeking legal advice in context of this litigation on communications plan re: homeless referrals to 421- a projects 34 NYCPRIV0 0536 Deliberative Draft Document re: 421-a - Homeless Preference DPP draft document containing comments re: homeless prevention policy and 421-a housing; DO NOT PRODUCE UNDER RODRIGUEZ 35 NYCPRIV0 0117 Attorney Client Draft talking points re: 421-a - Homeless Preference AC Attorney draft of documents discussing homeless referrals to 421- a projecs 36 NYC_0033169 Attorney Client Draft talking points re: 421-a - Homeless Preference AC Communications with counsel and counsel's comments on draft FAQs re: homeless referrals to 421-a projects 37 NYCPRIV0 0609 Attorney Client Email chain re: 421-a - Homeless Preference;Marketing guidelines AC Communications with counsel re: revisions to Marketing Handbook 38 NYCPRIV0 0611 Attorney Client Email chain re: 421-a - Homeless Preference AC Communications with counsel re: revisions to Marketing Handbook 39 NYCPRIV0 0613 Attorney Client Draft Document re: 421-a - Homeless Preference AC Attorney draft of memo sent to client for consideration re: homeless referrals to 421- a projects 40 NYCPRIV0 0620 Attorney Client Draft report re: MIH - Anti- displacement strategies; 421-a - 2015/2016 revision AC Attorney draft of report on MIH with highlighted areas for discussion 19 41 NYCPRIV0 2115 Deliberative Draft Document re: Anti- displacement strategies;Community Opposition Strategies DPP internal working draft reflecting tentative positions on HPD RFPs and involvement in neighborhood studies; DO NOT PRODUCE UNDER RODRIGUEZ 42 NYCPRIV0 0637 Attorney Client Draft talking points re: 421-a - 2007 revision AC Draft memo re: 421-a for which legal review is requested 43 NYCPRIV0 0644 Attorney Client Final letter (non-public) re: 421-a - 2007 revision NP not conveying legal advice or seeking legal advice 44 NYCPRIV0 0665 Attorney Client;Deliberative Draft Document re: Marketing guidelines AC Draft of Marketing Guidelines containing counsel's comments 45 NYCPRIV0 0666 Deliberative Draft Document re: Marketing guidelines DPP 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: Anti- displacement 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: Community Preference WP & DPP Draft letter to HUD re: potential settlement 48 NYCPRIV0 0686 Deliberative Draft report re: Application of Community Preference DPP draft strategy document concerning 10-year affordable housing plan in East New York; DO NOT PRODUCE UNDER RODRIGUEZ 49 NYCPRIV0 0768 Legislative Draft talking points re: ENY - Anti-displacement strategies NP internal strategy document regarding East New York development issues 50 NYCPRIV0 0782 Deliberative Email chain re: Application of Community Preference NP not internal - communication with city counsel; 51 NYCPRIV0 0783 Attorney Client;Deliberative Email chain re: Application of Community Preference AC communication to counsel and others seeking advice re: overlapping preference categories at a specific development 20 52 NYCPRIV0 0788 Deliberative;Legislative Draft presentation re: Anti- displacement 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 53 NYCPRIV0 0793 Attorney Client;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference AC communication discussing legal position in response to litigation and upcoming meeting with counsel 54 NYCPRIV0 0799 Deliberative;Legislative Draft Document re: ENY - Anti-displacement strategies NP draft executive summary of affordable housing plan for East New York 55 NYCPRIV0 0827 Legislative Draft talking points re: Anti- displacement strategies NP internal memo re: proposed responses to tenant harassment proposals by progressive caucus 56 NYCPRIV0 0158 Deliberative;Legislative Email chain re: Anti- displacement strategies NP also concerns bill re: harassment of tenants 57 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 - Anti- displacement strategies;Community Opposition Strategies NP internal communications re: East New York development and MIH strategy 59 NYCPRIV0 0839 Attorney Client;Work Product Email chain re: Litigation - Other;AFFH and Community Preference AC document summarizes and conveys legal advice re: Consolidated Plan and ongoing litigation 60 NYCPRIV0 0842 Attorney Client;Work Product Email chain re: Litigation - Other;AFFH and Community Preference AC communication with counsel re: draft 2012 Consolidated Plan to HUD re: AFFH 61 NYCPRIV0 0844 Deliberative;Work Product Draft letter re: Litigation - Anticipated Litigation re: Community Preference WP & DPP Draft response to HUD 62 NYCPRIV0 0846 Deliberative Draft report re: Anti- displacement strategies;Commitment to Fair Housing DPP draft langauge for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 21 63 NYCPRIV0 2140 Deliberative Draft Document re: Anti- displacement strategies;Community Opposition Strategies DPP same as 41 64 NYCPRIV0 0881 Deliberative;Legislative Draft Document re: MIH - Anti-displacement strategies; ENY - Anti- displacement 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: Anti- displacement strategies NP Per City's Agreement 66 NYCPRIV0 0891 Deliberative;Legislative Email chain re: Anti- displacement strategies NP Per City's Agreement 67 NYCPRIV0 0904 Deliberative Final presentation (non- public) re: MIH - Anti- displacement strategies NP 68 NYCPRIV0 0163 Deliberative Email chain re: ENY - Anti- displacement 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 421- a 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 Draft Document re: 421-a - 2015/2016 revision;421-a - Homeless Preference AC Legal advice re: 421-a 72 NYCPRIV0 2768 Deliberative Draft talking points re: Application of Community Preference NP Per City's Agreement 73 NYCPRIV0 2163 Work Product Final letter (non-public) re: Litigation - Anticipated Litigation re: Community Preference NP Letter to HUD providing fact information 74 NYCPRIV0 1425 Deliberative Draft talking points re: Litigation - Winfield Litigation;Application of Community Preference NP Per City's Agreement 22 75 NYCPRIV0 1426 Deliberative Draft talking points re: Litigation - Winfield Litigation;Application of Community Preference NP Per City's Agreement 76 NYCPRIV0 0699 Deliberative;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference WP & DPP communications re: data analysis needed to determine potential settlement positions with HUD on CPP 77 NYCPRIV0 0701 Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference WP Communications concerning draft letter to HUD and alteneratives to CPP 78 Deliberative;Work Product Draft letter re: Litigation - Anticipated Litigation re: Community Preference WP & DPP Draft analysis of measures of demographics within CDs in connection with HUD submission 79 NYCPRIV0 0708 Work Product Final report (non-public) re: Litigation - Anticipated Litigation re: Community Preference WP internal statistical analysis for informing litigation strategy 80 NYCPRIV0 0709 Attorney Client;Deliberative;Work 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 81 NYCPRIV0 0719 Deliberative;Work Product Internal Charts or Maps re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP analysis to inform legal strategy 82 NYCPRIV0 0720 Deliberative;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference WP & DPP communications re: data analysis needed to determine potential settlement positions with HUD on CPP 83 NYCPRIV0 0724 Deliberative Internal Charts or Maps;Notes re: Anti- displacement strategies DPP CHART RE: PROGRESS ON VARIOUS STRATEGIC PRESERVATION INITIATIVES, REFLECTS INTERNAL WORKING PROCESS; DO NOT PRODUCE UNDER RODRIGUEZ 84 NYCPRIV0 0731 Deliberative Draft presentation re: DPP SAME AS 52 23 85 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 86 NYCPRIV0 0146 Deliberative;Work Product Internal Charts or Maps re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP analysis prepared to inform litigation strategy and settlement 87 NYCPRIV0 0742 Deliberative;Work Product(withdrawn) Draft report re: Litigation - Anticipated Litigation re: Community Preference DPP Work product withdrawn; draft report re: MIH policy reflecting input from various individuals; precedes counsel vote on MIH; DO NOT PRODUCE UNDER RODRIGUEZ 88 NYCPRIV0 0752 Deliberative Draft Document re: Marketing guidelines DPP draft marketing guidelines to be submitted to legal for review and approval; DO NOT PRODUCE UNDER RODRIGUEZ 89 NYCPRIV0 0150 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform legal strategy and settlement 90 NYCPRIV0 0994 Deliberative Draft Document re: Marketing guidelines DPP draft marketing guidelines to be submitted to legal for review and approval; DO NOT PRODUCE UNDER RODRIGUEZ 91 NYC_0076061 NYCPRIV0 0997 Deliberative Draft Document re: Marketing guidelines DPP draft marketing guidelines to be submitted to legal for review and approval; DO NOT PRODUCE UNDER RODRIGUEZ 92 NYCPRIV0 0999 Attorney Client;Deliberative Draft Document re: Marketing guidelines AC communications re: sections of 2016 Marketing Guidelines and attorney advice re: certain sections 93 NYCPRIV0 1000 Attorney Client;Deliberative Email chain re: Application of Community Preference AC communications with counsel and others re: inclusion of prior residents in community preference for various projects 24 94 NYCPRIV0 1003 Attorney Client Email chain re: North Brooklyn Rezoning and Demographics AC communications with counsel re: requests to include prior residents in community preference, pre-policy discussion re: policy 95 NYCPRIV0 2149 Attorney Client;Deliberative Email chain re: MIH - Anti- displacement strategies;MIH - Community opposition NP 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 NYCPRIV0 2174 Attorney Client;Deliberative;Legislative Draft report re: MIH - Anti- displacement strategies;MIH - Community opposition;MIH - City council input;Community Opposition Strategies AC draft internal report concerning MIH and 421- a 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 100 NYCPRIV0 1441 Attorney Client;Deliberative Draft Document 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 101 NYCPRIV0 2175 Deliberative Email chain re: Application of Community Preference NP communications regarding CPP 102 NYCPRIV0 1442 Legislative Email chain re: Application of Community Preference NP communications about Bronx Commons development 103 NYCPRIV0 0180 Deliberative Internal Memorandum re: 421-a - Homeless Preference DPP draft decision memo to mayor re: homeless unit commitment; DO NOT PRODUCE UNDER RODRIGUEZ 104 NYCPRIV0 0189 Deliberative;Work Product Email chain re: Anti- displacement strategies; Litigation - Anticipated Litigation re: Community Preference WP & DPP communications concerning information needed to evaluate changes to CPP and settlement position with HUD 25 105 NYCPRIV0 0191 Deliberative Draft report re: MIH - mobility DPP SAME AS 87 106 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: Anti- displacement strategies NP Per City's Agreement 108 NYCPRIV0 1540 Deliberative Email chain re: Anti- displacement strategies;Application of Community Preference NP Per City's Agreement 109 NYCPRIV0 1549 Attorney Client;Deliberative Internal Memorandum re: Commitment to Fair Housing AC Draft decision memo on MIH and stating understanding of legal advice 110 NYCPRIV0 1556 Attorney Client;Deliberative;Work 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 communication regarding inquiry about application of CPP 113 NYCPRIV0 1591 Attorney Client;Deliberative Email chain re: ENY - Anti- displacement strategies;Application of Community Preference AC communication with counsel re: legal advice on language in draft document concerning CPP 114 NYCPRIV0 1592 Attorney Client;Deliberative Email chain re: ENY - Anti- displacement strategies;Application of Community Preference AC communication with counsel re: legal advice on language in draft document concerning CPP 115 NYCPRIV0 0206 Deliberative Draft Internal Memorandum re: Anti- displacement strategies DPP draft decision memo to mayor re: legal services RFP; DO NOT PRODUCE UNDER RODRIGUEZ 116 NYCPRIV0 1617 Deliberative Draft presentation re: MIH - Anti-displacement strategies;MIH - Community opposition;MIH - City council input DPP internal draft of considerations for MIH policy; DO NOT PRODUCE UNDER RODRIGUEZ 26 117 NYCPRIV0 1620 Deliberative Draft presentation re: MIH - Anti-displacement strategies;MIH - Community opposition;MIH - City council input DPP internal draft of considerations for MIH policy; DO NOT PRODUCE UNDER RODRIGUEZ 118 NYC_0073100 Deliberative;Work Product Email chain re: Litigation - Winfield Litigation WP Communications regarding this litigation and statement about it to provide to HUD 119 NYCPRIV0 0220 Deliberative Draft talking points re: 421-a - Homeless Preference NP Per City's Agreement 120 NYCPRIV0 1659 Attorney Client;Deliberative Draft talking points re: 421-a - Homeless Preference AC internal draft talking points in advance of meeting with REBNY containing attorney input and strategy 121 NYCPRIV0 1661 Deliberative Email chain re: ENY - Anti- displacement 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 122 NYCPRIV0 1662 Attorney Client 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 123 NYCPRIV0 1663 Attorney Client 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 124 NYCPRIV0 1666 Work Product Email chain re: Litigation - Winfield Litigation NP Per City's Agreement 125 NYCPRIV0 1667 Deliberative;Work Product Email chain re: Anti- displacement strategies; Litigation - Winfield Litigation NP Per City's Agreement 126 NYCPRIV0 1723 Attorney Client;Deliberative Email chain re: Application of Community Preference AC 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: Community Preference WP & DPP Discussion about how to conduct data analysis to answer HUD request 27 128 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 129 NYCPRIV0 1034 Deliberative;Work Product Internal Charts or Maps re: Litigation - Anticipated Litigation re: Community Preference WP & DPP analysis to inform litigation strategy 130 NYCPRIV0 0237 Attorney Client;Deliberative Email chain re: 421-a - Homeless Preference;Application of Community Preference NP Per City's Agreement 131 NYCPRIV0 1037 Deliberative;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference WP & DPP summary of info discussed at settlement meeting with HUD re: HUD data requests for alternative to CPP 132 NYCPRIV0 1737 Deliberative;Legislative Email chain re: ENY - Anti- displacement strategies DPP internal communications re: East New York development and strategy; DO NOT PRODUCE UNDER RODRIGUEZ 133 NYCPRIV0 1039 Deliberative (withdrawn);Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference WP information and data collected to inform settlement strategy with HUD 134 NYCPRIV0 1058 Deliberative;Work Product Draft report re: Anti- displacement strategies; Litigation - Winfield Litigation WP Draft PPT re: alternatives to CPP to inform strategy in litigation 135 NYCPRIV0 1066 Deliberative;Work Product Internal Charts or Maps re: Anti-displacement strategies WP email re: gentrification map in connection with planning changes to CPP for settlement 136 NYCPRIV0 1067 Attorney Client;Deliberative Draft report re: Marketing guidelines AC revisions to Marketing handbook sent to counsel for comment 137 NYCPRIV0 1070 Deliberative;Work Product Internal Charts or Maps re: Anti-displacement strategies; Litigation - Winfield Litigation WP & DPP gentrification map for planning changes to CPP for settlement 138 NYCPRIV0 1071 Deliberative;Work Product Internal Charts or Maps re: Anti-displacement strategies; Litigation - Winfield Litigation WP & DPP gentrification map for planning changes to CPP for settlement 139 NYCPRIV0 1075 Attorney Client;Legislative;Work Product Email chain re: City Council Input; Litigation - Anticipated Litigation re: Community Preference AC email chain with counsel and others re: response to Plaintiff's counsel and draft letter to HUD 28 140 NYC_0076236 NYCPRIV0 1117 Attorney Client;Deliberative;Work Product Draft presentation re: Litigation - Anticipated Litigation re: Community Preference;Neighborhood Demographics AC document discussing strategies for negotiations with HUD re: community preference; legal advice on document sought 141 NYCPRIV0 1122 Attorney Client;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference;AFFH and Community Preference WP & DPP ppt re: option for analyzing various aspects of CDs in connection with changes to CPP as part of litigation 142 NYCPRIV0 2150 Attorney Client Email chain;Draft Document re: OTHER AC communications identifying portions of draft document where legal advice is sought and discussing legal review of same 143 NYCPRIV0 1222 Deliberative;Legislative Email chain re: Anti- displacement strategies DPP internal communications re: East New York development and MIH strategy; DO NOT PRODUCE UNDER RODRIGUEZ 144 NYCPRIV0 1231 Deliberative Email chain re: Anti- displacement strategies;Application of Community Preference NP email re: application of CPP 145 NYCPRIV0 1292 Deliberative Email chain re: Community Opposition Strategies DPP communications concerning preliminary responses to community questions about Community Housing Plan - PRODUCE UNDER RODRIGUEZ 146 NYCPRIV0 1294 Deliberative Notes re: Anti- displacement strategies;Commitment to Fair Housing DPP internal notes reflecting Meltzer's thoughts on contract with NEIGHBORHOOD PRESERVATION CONSULTANT program and displacement mitigation strategies - PRODUCE UNDER RODRIGUEZ 147 NYCPRIV0 1298 Deliberative Draft report re: ENY - Anti- displacement strategies;ENY - Community opposition NP Per City's Agreement 29 148 NYCPRIV0 1302 Deliberative Final report (non- public);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 149 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 Settlement analysis for considering options for CPP changes in connection with litigation 151 NYCPRIV0 1349 Deliberative;Work Product Email chain re: Litigation - Winfield Litigation WP & DPP email discussion regarding options for changes to CPP in connection with settlement positions 152 NYCPRIV0 1353 Deliberative Email chain re: MIH - Anti- displacement strategies DPP 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 153 NYCPRIV0 1358 Deliberative;Work Product Email chain re: Litigation - Winfield Litigation WP & DPP email discussion re: settlement posiitons on CPP 154 NYCPRIV0 2153 Work Product Email chain re: Litigation - Winfield Litigation WP Communication about work needed to inform legal strategy 155 NYCPRIV0 2154 Work Product Notes re: Anti- displacement strategies; Litigation - Winfield Litigation WP Summary of fact research done for litigation and reflects litigation strategy 156 NYCPRIV0 1366 Deliberative;Work Product Email chain re: Litigation - Winfield Litigation WP & DPP email discussion re: settlement positions on CPP 157 NYCPRIV0 1367 Deliberative;Work Product Email chain re: Litigation - Winfield Litigation WP & DPP email discussion re: settlement positions on CPP 30 158 NYCPRIV0 1374 Deliberative;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP email discussion re: settlement positions on CPP 159 NYCPRIV0 1375 Attorney Client;Deliberative;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference AC communciations with counsel and others re: legal strategy and defenses 160 NYCPRIV0 1377 Work Product Email chain re: Litigation - Winfield Litigation WP Describes work done for informing litigation and settlement strategy 161 NYCPRIV0 1378 Deliberative;Work Product Draft Internal Memorandum re: Litigation - Winfield Litigation WP & DPP legal materials re: settlement positions 162 NYCPRIV0 1384 Deliberative;Work Product Draft Internal Memorandum re: Litigation - Winfield Litigation WP & DPP legal materials re: settlement positions 163 NYCPRIV0 1746 Attorney Client Email chain re: Application of Community Preference AC communications with counsel and others re: draft statement about community preference 164 NYCPRIV0 1386 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation WP & DPP legal materials re: settlement positions 165 NYCPRIV0 1392 Attorney Client;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP legal materials re: settlement positions 166 NYCPRIV0 1398 Attorney Client;Work Product Email chain re: Litigation - Winfield Litigation WP legal materials re: settlement positions 167 NYCPRIV0 1399 Work Product Email chain re: Litigation - Winfield Litigation WP Describes work done for informing litigation and settlement strategy 168 NYCPRIV0 1752 Deliberative Draft Document re: Marketing guidelines DPP draft marketing guidelines to be submitted to legal for review and approval; DO NOT PRODUCE UNDER RODRIGUEZ 169 NYCPRIV0 0245 Deliberative;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference WP communications concerning legislative history of CPP and search for same 170 NYCPRIV0 0263 Deliberative;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference WP & DPP communications concerning potential changes to CPP in context of settlement discussion with HUD; DO NOT PRODUCE UNDER RODRIGUEZ 31 171 NYCPRIV0 0264 Deliberative;Work Product Internal Charts or Maps re: Litigation - Anticipated Litigation re: Community Preference WP & 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 0274 Deliberative Draft presentation re: Anti- displacement strategies; 421-a - 2015/2016 revision DPP Same as 52 175 NYCPRIV0 0278 Attorney Client Email chain re: Application of Community Preference AC communication with counsel and others seeking advice on application of preferences at a specific development 176 NYCPRIV0 0280 Attorney Client;Deliberative;Work Product Final letter (non-public) re: Litigation - Anticipated Litigation re: Community Preference DPP Not attorney-client because sent to HUD; Letter from Been to HUD GC re: Settlement Proposal; DO NOT PRODUCE UNDER RODRIGUEZ 177 NYCPRIV0 0281 Deliberative;Work Product Internal Charts or Maps re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 178 NYCPRIV0 0292 Attorney Client;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation AC & WP Communication with counsel; discussion anticipated litigation, FOIL request and potential fact development for litigation 179 NYCPRIV0 0293 Legislative Email chain re: Application of Community Preference NP emails between Garodnick and Been re: CPP 180 NYCPRIV0 0295 Work Product Email chain re: Litigation - Winfield Litigation NP draft communication to mayor about filing of this suit 181 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 32 182 NYCPRIV0 0309 Deliberative;Work Product Internal Charts or Maps re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 183 NYCPRIV0 0321 Work Product Final report (non-public) re: Litigation - Anticipated Litigation re: Community Preference WP Analysis of ACS demographic and housing estimates based on census tracts 184 NYCPRIV0 0322 Work Product Draft Internal Memorandum re: Litigation - Winfield Litigation WP Atty questions re: CPP and statistical tests 185 NYC_0072746 NYCPRIV0 0329 Deliberative;Work Product Draft letter re: Litigation - Anticipated Litigation re: Community Preference WP Draft Letter from Been to HUD GC re: settlement 186 NYCPRIV0 1780 Attorney Client Final report (non-public) re: Marketing guidelines NP 187 NYCPRIV0 1791 Deliberative Draft Document re: Marketing guidelines DPP draft marketing guidelines to be submitted to legal for review and approval; DO NOT PRODUCE UNDER RODRIGUEZ 188 NYCPRIV0 0338 Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference WP Internal communication regarding analysis of litigation risk and settlement possibility with HUD 189 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 190 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 191 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 192 NYCPRIV0 0342 Deliberative;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference WP & DPP communication concerning proposed communication with HUD re: alternatives to CPP 33 193 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 194 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 195 NYCPRIV0 1841 Work Product Final report (non-public) re: Litigation - Winfield Litigation WP Notes on property portfolios and includes Winfield litigation strategy comments 196 NYCPRIV0 0351 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 197 NYCPRIV0 0352 Deliberative;Work Product Internal Charts or Maps re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 198 NYCPRIV0 0353 Work Product Draft presentation re: Litigation - Winfield Litigation WP Legal communication and analysis of case 199 NYCPRIV0 0354 Deliberative;Work Product Notes re: 421-a - 2015/2016 revision; Litigation - Winfield Litigation WP & DPP Notes concerning considerations for determining policy regarding 421a and changes to law 200 NYCPRIV0 0355 Deliberative;Work Product Notes re: Litigation - Winfield Litigation WP list of questions to consider re: possible changes to CPP 201 NYCPRIV0 0356 Deliberative;Work Product Internal Charts or Maps re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 202 NYCPRIV0 0363 Deliberative Draft Internal Memorandum re: Anti- displacement strategies DPP internal draft re: preservation initatives; DO NOT PRODUCE UNDER RODRIGUEZ 203 NYCPRIV0 0367 Deliberative;Work Product Internal Charts or Maps re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 34 204 NYCPRIV0 0368 Deliberative;Work Product Internal Charts or Maps re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 205 NYCPRIV0 0378 Work Product Draft Internal Memorandum re: Litigation - Winfield Litigation WP Legal analysis and settlement strategies 206 NYCPRIV0 0379 Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP Setlement analysis for considering options for CPP changes in connection with litigation 207 NYCPRIV0 0380 Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP Settlement analysis for considering options for CPP changes in connection with litigation 208 NYCPRIV0 0382 Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP Settlement analysis for considering options for CPP changes in connection with litigation - MAP 209 NYCPRIV0 0391 Work Product Draft presentation re: Litigation - Winfield Litigation WP Legal analysis and settlement strategies 210 NYCPRIV0 0392 Deliberative;Work Product Draft letter re: Litigation - Anticipated Litigation re: Community Preference WP Draft Letter from Been to HUD GC re: settlement 211 NYCPRIV0 0393 Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP Settlement analysis for considering options for CPP changes in connection with litigation - MAP 212 NYCPRIV0 0394 Deliberative Draft talking points re: 421-a - Homeless Preference NP draft internal Q&A re: 421a Homeless preference; contains interpretation of 421a 213 NYCPRIV0 0395 Deliberative Draft talking points re: 421-a - Homeless Preference NP draft internal Q&A re: 421a Homeless preference; contains interpretation of 421a 214 NYCPRIV0 0396 Deliberative Draft talking points re: 421-a - Homeless Preference NP 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 legal summary for client re: 421-a 35 217 NYCPRIV0 1850 Deliberative Draft report re: Application of Community Preference;Marketing guidelines DPP draft section of marketing handbook; DO NOT PRODUCE UNDER RODRIGEZ 218 NYCPRIV0 1855 Attorney Client;Deliberative 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 219 NYCPRIV0 1863 Deliberative Draft talking points re: Anti- displacement strategies NP draft Q&As re: affordable housing in connection with 2015 mayor state of city address 220 NYC_0067398 Work Product Draft Document re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP Draft questions for analysis for formulating litigation strategy 221 NYC_0067400 Deliberative;Work Product Draft Internal Memorandum re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 222 NYC_0067402 Deliberative;Work Product Draft Internal Memorandum re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 223 NYC_0067405 Work Product Final presentation (non- public) re: Litigation - Winfield Litigation WP Legal communication and analysis of case 224 NYC_0067416 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 225 NYC_0067418 Deliberative;Work Product Internal Charts or Maps re: Litigation - Anticipated Litigation re: Community Preference WP & DPP analysis to inform litigation strategy and settlement 226 NYC_0067422 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 227 NYC_0067424 Deliberative;Work Product Notes re: Litigation - Anticipated Litigation re: Community Preference WP notes reflect communications with HUD re: settlement of issues raised about CPP 228 NYC_0067425 Work Product Notes re: Litigation - Winfield Litigation WP Reflects attorney questions and information gathering for litigation 229 NYC_0067426 Work Product Notes re: Litigation - Winfield Litigation WP Reflects potential analyses for informing litigation strategy 36 230 NYC_0067431 Work Product Draft presentation re: Litigation - Winfield Litigation WP Draft presentation re: litigation for informing litigation strategy 231 NYC_0067438 Deliberative Draft talking points re: MIH - Community opposition;Anti- displacement strategies;Commitment to Fair Housing NP Notes for discussion with NYT about fair housing; does not reflect decisionmaking on policy 232 NYCPRIV0 1867 Attorney Client;Legislative (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 234 NYCPRIV0 1882 Deliberative Draft report re: Anti- displacement strategies DPP draft of proposed new housing marketplace plan; DO NOT PRODUCE UNDER RODRIGUEZ 235 NYCPRIV0 1884 Attorney Client Email chain re: Application of Community Preference AC communications with counsel discussing potential legislation and conveying legal advice 236 NYCPRIV0 2774 Deliberative Draft report re: Litigation - Winfield Litigation;Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 237 NYCPRIV0 2775 Deliberative Draft report re: Litigation - Winfield Litigation;Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 238 NYCPRIV0 2782 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing AC & DPP draft of 2016 consolidated plan re: AFFH sent to counsel for comments 239 NYCPRIV0 2783 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing AC & DPP draft of 2016 consolidated plan re: AFFH sent to counsel for comments 240 NYCPRIV0 2784 Attorney Client;Deliberative Draft report re: AFFH and Community Preference AC & DPP draft of 2016 consolidated plan re: AFFH sent to counsel for 241 NYCPRIV0 2785 Attorney Client;Deliberative Draft report re: AFFH and Community Preference;Commitment to Fair Housing AC & DPP draft of 2016 consolidated plan re: AFFH sent to counsel for comments 37 242 NYCPRIV0 2797 Attorney Client;Deliberative Draft report re: Anti- displacement strategies;Commitment to Fair Housing AC & DPP draft of 2016 consolidated plan sections re: AFFH sent to counsel for comments 243 NYCPRIV0 2800 Deliberative Draft report re: Anti- displacement strategies;Commitment to Fair Housing DPP draft langauge for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 244 NYCPRIV0 2807 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for Fair Housing Statement to be included in AFFH Plan; DO NOT PRODUCE UNDER RODRIGUEZ 245 NYCPRIV0 2812 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing AC & DPP draft submission to HUD re AFFH seeking comments from multiple agencies to submit to legal 246 NYCPRIV0 2825 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 247 NYCPRIV0 2828 Deliberative Email chain re: Commitment to Fair Housing NP email re: language for inclusion in AFFH document RE: 5-yr needs for HPD Fair Housing Program 248 NYCPRIV0 2832 Attorney Client;Deliberative Draft report re: Anti- displacement strategies;Commitment to Fair Housing AC & DPP draft of 2010 AFFH statement for HUD sent to counsel for comments 249 NYCPRIV0 2859 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 250 NYCPRIV0 2885 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing AC & DPP draft submission to HUD re AFFH seeking comments of multiple agencies to submit to legal 251 NYCPRIV0 2897 Attorney Client;Deliberative Draft report re: Anti- displacement strategies;Commitment to Fair Housing AC & DPP draft of 2012 consolidated plan re: AFFH sent to counsel for comments 252 NYCPRIV0 2899 Deliberative Draft report re: Anti- displacement strategies DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 38 253 NYCPRIV0 2905 Attorney Client;Work Product Final report (non-public) re: Litigation - Anticipated Litigation re: Community Preference;Commitment to Fair Housing NP Excerp AFFH update from 2011 consolidated plan 254 NYCPRIV0 2906 Attorney Client;Work Product Final report (non-public) re: Litigation - Winfield Litigation;Commitment to Fair Housing NP 2011 consolidated plan re: AFFH to HUD 255 NYCPRIV0 2911 Attorney Client;Work Product Final report (non-public) re: Litigation - Anticipated Litigation re: Community Preference;Commitment to Fair Housing NP Per City's Agreement 256 NYCPRIV0 2913 Attorney Client;Deliberative Draft report re: Neighborhood Demographics;Commitme nt to Fair Housing AC & DPP draft of 2013 consolidated plan re: AFFH sent to counsel for comments 257 NYCPRIV0 2924 Deliberative Draft report re: Commitment to Fair Housing DPP draft sections for 2013 Consolidated Plan AFFH; DO NOT PRODUCE UNDER RODRIGUEZ 258 NYCPRIV0 2939 Deliberative Draft report re: Commitment to Fair Housing DPP draft langauge for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 259 NYCPRIV0 2943 Attorney Client;Deliberative;Work 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 NYCPRIV0 2953 Attorney Client;Work Product Final report (non-public) re: Litigation - Anticipated Litigation re: Community Preference;((Litigation)) NP 2007 Final Consolidated Plan AFFH Annual Performance Report to HUD 261 NYCPRIV0 2954 Attorney Client;Deliberative;Work Product Final report (non-public) re: Litigation - Anticipated Litigation re: Community Preference;Commitment to Fair Housing NP Excerp AFFH update from 2008 consolidated plan 262 NYCPRIV0 2967 Deliberative Draft report re: Neighborhood Demographics;Commitme nt to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 39 263 NYCPRIV0 2968 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing WP & DPP draft submission to HUD re AFFH seeking comments of multiple agencies to submit to legal 264 NYCPRIV0 2969 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing WP & DPP draft submission to HUD re AFFH seeking comments of multiple agencies to submit to legal 265 NYCPRIV0 2970 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing WP & DPP draft submission to HUD re AFFH seeking comments of multiple agencies to submit to legal 266 NYCPRIV0 2973 Attorney Client;Deliberative Draft report re: Neighborhood Demographics;Commitme nt to Fair Housing AC & DPP draft of portion of AFFH- related document sent to counsel for comments 267 NYC_0085477 NYCPRIV0 3002 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 268 NYC_0085478 NYCPRIV0 3003 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 270 NYCPRIV0 3015 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 271 NYCPRIV0 3016 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 272 NYCPRIV0 3025 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 273 NYCPRIV0 3055 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing WP & DPP draft submission to HUD re AFFH seeking comments of multiple agencies to submit to legal 274 NYCPRIV0 3070 Attorney Client;Deliberative;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Other;AFFH and Community Preference;Commitment to Fair Housing AC & WP Communication with attorney re: draft submission to HUD and legal issues re: same 40 275 NYCPRIV0 3093 Attorney Client;Deliberative;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Other;AFFH and Community Preference;Commitment to Fair Housing AC & WP Communication with attorney re: draft submission to HUD and legal issues re: same 276 NYCPRIV0 3122 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 277 NYCPRIV0 3124 Deliberative Email chain re: Commitment to Fair Housing DPP email re: language for inclusion in AFFH document RE: 5-year nees for HPD Fair Housing Program; DO NOT PRODUCE PURSUANT TO RODRIGUEZ 278 NYCPRIV0 3126 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 279 NYCPRIV0 3131 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing WP & DPP draft submission to HUD re AFFH seeking comments of multiple agencies to submit to legal 280 NYCPRIV0 3149 Deliberative Draft report re: Neighborhood Demographics;Commitme nt to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 281 NYC_0085800 NYCPRIV0 3157 Work Product Draft report re: Litigation - Anticipated Litigation re: Community Preference;Application of Community Preference WP Internal communication concerning resonse to plaintiff's counsel's leter re: AFFH 282 NYCPRIV0 3182 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing WP & DPP draft submission to HUD re AFFH seeking comments do multiple agencies to submit to legal 283 NYCPRIV0 3185 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 284 NYCPRIV0 3202 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing WP & DPP draft submission to HUD re AFFH seeking comments of multiple agencies to submit to legal 41 285 NYCPRIV0 3212 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 286 NYCPRIV0 3226 Deliberative Draft report re: Neighborhood Demographics;Commitme nt to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 287 NYC_0085811 NYCPRIV0 3235 Attorney Client;Deliberative Draft report re: Neighborhood Demographics;Commitme nt to Fair Housing AC Draft of information for 2012 consolidated plan submitted to attorneys for advice 288 NYC_0085819 NYCPRIV0 3237 Attorney Client;Deliberative;Work Product Email chain re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Other;AFFH and Community Preference;Commitment to Fair Housing AC & WP Communication with attorney re: draft submission to HUD and legal issues re: same 289 NYCPRIV0 3240 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing WP & DPP draft submission to HUD re AFFH seeking comments of multiple agencies to submit to legal 290 NYCPRIV0 3250 Deliberative Draft letter re: Anti- displacement 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 291 NYCPRIV0 3264 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing WP & DPP draft submission to HUD re AFFH seeking comments of multiple agencies to submit to legal 292 NYCPRIV0 3265 Attorney Client;Deliberative Draft report re: Commitment to Fair Housing WP & DPP draft submission to HUD re AFFH seeking comments do multiple agencies to submit to legal 293 NYCPRIV0 3277 Attorney Client (withdrawn);Deliberative Draft report re: Anti- displacement strategies;Commitment to Fair Housing DPP AC withdrawn; draft of housing plan; final publicly available; DO NOT PRODUCE UNDER RODRIGUEZ 294 NYCPRIV0 3280 Deliberative Draft report re: Anti- displacement strategies;Commitment to Fair Housing DPP working draft for anticipated 10-year affordable housing plan; DO NOT PRODUCE UNDER RODRIGUEZ 42 295 NYCPRIV0 3283 Attorney Client;Deliberative Draft talking points re: Anti- displacement strategies;Commitment to Fair Housing AC & DPP draft of Q&As re: not yet final housing plan sent to counsel for review and comment 296 NYCPRIV0 3284 Deliberative Draft report re: MIH - mobility DPP draft outline concerning MIH policy considerations and action items; DO NOT PRODUCE UNDER RODRIGUEZ 297 NYCPRIV0 3294 Deliberative Draft talking points re: Anti- displacement strategies;Commitment to Fair Housing NP draft Q&A re: 10-year housing plan under deBlasio and MIH 298 NYCPRIV0 1896 Attorney Client;Deliberative Draft Document re: MIH - mobility AC & DPP communication with counsel and others seeking comments on draft document re: MIH 299 NYC_0080435 NYCPRIV0 3314 Deliberative Final report (non-public) re: Anti-displacement strategies NP Strategy slide re: East NY Community Plan and Housing NY 300 NYCPRIV0 3319 Attorney Client;Deliberative Draft Internal Memorandum re: MIH - Anti-displacement strategies;Application of Community Preference AC & DPP draft decision memo to mayor re: creation of MIH program and seeking/reflecting legal advice 301 NYCPRIV0 3337 Deliberative Email chain re: 421-a - 2015/2016 revision DPP communications re: policy considerations for anticipated MIH policy; DO NOT PRODUCE UNDER RODRIGUEZ 302 NYCPRIV0 3347 Deliberative Email chain re: Neighborhood Demographics NP emails concerning presentation for Oct. 23 retreat 303 NYCPRIV0 3348 Deliberative Draft report re: Neighborhood Demographics NP Per City's Agreement 304 NYCPRIV0 3359 Deliberative Draft Internal Memorandum re: North Brooklyn Rezoning and Demographics NP transition memo re: development in various neighborhoods 305 NYCPRIV0 3369 Deliberative Final letter (non-public) re: ENY - Anti-displacement strategies;ENY - Community opposition NP letter from office of comptroller to city planning re: East NY Community plan and MIH 306 NYCPRIV0 3370 Attorney Client;Deliberative Draft report re: MIH - Anti- displacement strategies;Application of Community Preference AC & DPP draft of possible modifications to MIH plan submitted to counsel for advice and comment 307 NYCPRIV0 3373 Deliberative Draft letter re: MIH - Anti- displacement strategies;MIH - Community opposition NP Per City's Agreement 43 308 NYCPRIV0 3374 Deliberative Draft letter re: ENY - Anti- displacement strategies;ENY - Community opposition;ENY - Investment in Communities DPP internal draft letter in response to comptroller concerns re: East NY Community plan and MIH; produce final; draft DO NOT PRODUCE UNDER RODRIGUEZ 309 NYCPRIV0 3390 Deliberative Final letter (non-public) re: Community Opposition Strategies NP letter from City Counsel re: rezoning in Bushwick 310 NYCPRIV0 3396 Deliberative Draft talking points re: ENY - Anti-displacement strategies;ENY - Investment in Communities;Application of Community Preference NP 311 NYCPRIV0 3406 Deliberative Draft talking points re: MIH - Anti-displacement strategies NP presentation to mayor in advance for a town hall meeting 312 NYCPRIV0 3407 Deliberative Final talking points (non- public) re: MIH - Anti- displacement strategies;421-a - Homeless Preference NP Q&As for meeting on senior housing 313 NYCPRIV0 3410 Deliberative Draft report re: ENY - Anti- displacement strategies;ENY - Community opposition NP draft of East NY affordable housing plan seeking public input to refine plan for public review 314 NYCPRIV0 3413 Deliberative Draft report re: Neighborhood Demographics DPP 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 315 NYCPRIV0 3415 Deliberative Draft report re: Neighborhood Demographics DPP SAME AS 314 316 NYC_0081650 NYCPRIV0 3416 Deliberative Draft report re: Anti- displacement strategies DPP highlighted internal summary of possible changes to policies affecting affordable housing in Crown Heights West; DO NOT PRODUCE UNDER RODRIGUEZ 317 NYCPRIV0 3417 Deliberative Draft report re: Neighborhood Demographics DPP SAME AS 314 318 NYCPRIV0 3418 Deliberative Draft report re: Neighborhood Demographics DPP SAME AS 314 44 319 NYCPRIV0 3419 Deliberative Draft report re: Neighborhood Demographics DPP SAME AS 314 320 NYCPRIV0 3420 Deliberative Draft report re: Neighborhood Demographics DPP SAME AS 314 321 NYCPRIV0 3422 Attorney Client Email chain re: Application of Community Preference NP not conveying legal advice or seeking legal advice 322 NYCPRIV0 3426 Deliberative Draft report re: Application of Community Preference DPP Project briefing memo for Hunter's Point South development for decisionmaking concerning affordable housing strategies in neighborhood; DO NOT PRODUCE UNDER RODRIGUEZ 323 NYCPRIV0 1910 Deliberative;Work Product (withdrawn) Draft presentation re: Litigation - Anticipated Litigation re: Community Preference 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 324 NYCPRIV0 3430 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 325 NYCPRIV0 3436 Deliberative Draft report re: Anti- displacement strategies;Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 326 NYCPRIV0 3456 Deliberative Draft report re: Anti- displacement strategies DPP 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 328 NYCPRIV0 3478 Work Product Draft report re: Litigation - Anticipated Litigation re: Community Preference;Application of Community Preference NP Per City's Agreement 45 329 NYCPRIV0 3481 Deliberative Draft report re: Anti- displacement strategies;Neighborhood Demographics;Commitme nt to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 330 NYCPRIV0 3487 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 331 NYCPRIV0 3499 Deliberative Draft report re: Anti- displacement strategies;Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 332 NYCPRIV0 3590 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 333 NYCPRIV0 3600 Deliberative Internal Memorandum re: AFFH and Community Preference NP 334 NYCPRIV0 3634 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 335 NYCPRIV0 3703 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 336 NYCPRIV0 3710 Deliberative Draft report re: Anti- displacement strategies;Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 337 NYCPRIV0 3761 Deliberative Draft report re: DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 338 NYCPRIV0 3766 Deliberative Draft report re: Commitment to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 339 NYCPRIV0 3904 Deliberative Draft report re: Neighborhood Demographics;Commitme nt to Fair Housing DPP draft language for including in AFFH Consolidated Plan; DO NOT PRODUCE UNDER RODRIGUEZ 46 340 NYCPRIV0 2191 Deliberative Draft report re: MIH - Anti- displacement strategies;MIH - Community opposition DPP Draft portion of 10-year housing plan; produce final 10-YEAR PLAN; DO NOT PRODUCE UNDER RODRIGUEZ 341 NYCPRIV0 2395 Deliberative Internal Memorandum re: Litigation - Winfield Litigation NP Per City's Agreement 342 NYCPRIV0 2396 Attorney Client Email chain re: Application of Community Preference NP not conveying legal advice or seeking legal advice 343 NYCPRIV0 2193 Deliberative Draft talking points re: MIH - Anti-displacement strategies;MIH - Community opposition NP draft Q&A on Housing NY and MIH 344 NYCPRIV0 2200 Deliberative Internal Memorandum re: Anti-displacement strategies;Community Opposition Strategies NP questions for agencies for purposes of HPD affordable housing planning 345 NYCPRIV0 1952 Legislative Draft Document re: ENY - Anti-displacement strategies;ENY - City council input;Application of Community Preference NP Per City's Agreement 346 NYCPRIV0 1971 Attorney Client;Deliberative Internal Memorandum re: Application of Community Preference AC & DPP draft decision memo to mayor re: creation of MIH program and seeking/reflecting legal advice 347 NYCPRIV0 2261 Deliberative;Legislative Draft talking points re: Anti- displacement strategies NP document provided by CM Brad Landers about possible bill protecting tenants from harassment 348 NYCPRIV0 2283 Deliberative;Legislative Draft Internal Memorandum re: Anti- displacement strategies DPP decision memo to mayor to guide decision re: Bedford Armory Project; DO NOT PRODUCE UNDER RODRIGUEZ 349 NYCPRIV0 2301 Attorney Client;Legislative Email chain re: MIH - Community opposition 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 47 350 NYCPRIV0 2037 Deliberative;Legislative Draft Document re: ENY - Anti-displacement strategies;Application of Community Preference NP draft outline of issues to inform decisions re: East New York development 351 NYCPRIV0 2302 Deliberative;Legislative Email chain re: Anti- displacement strategies; ENY - Anti-displacement strategies DPP & Legislat ive 352 NYCPRIV0 2040 Deliberative Email chain re: MIH - Anti- displacement strategies NP communications re: state of the city address highlights as talking points to press 353 NYCPRIV0 2355 Attorney Client;Deliberative Draft talking points re: 421-a - Homeless Preference NP Per City's Agreement 354 NYCPRIV0 2360 Deliberative Email chain re: 421-a - Homeless Preference NP Per city's Agreement 355 NYCPRIV0 2362 Deliberative Email chain re: Anti- displacement strategies DPP communication re: East Harlem Displacement number error in connection with preparing scope of work for RFP; PRODUCE UNDER RODRIGUEZ 356 NYCPRIV0 2063 Deliberative Email chain re: Application of Community Preference NP communications re: albany housing agenda presentation and mayor's talk with Castro about CPP 357 NYCPRIV0 2066 Attorney Client;Deliberative;Work Product Draft Internal Memorandum re: MIH - Anti-displacement strategies; Litigation - Anticipated Litigation re: Community Preference AC & DPP draft decision memo to mayor re: creation of MIH program and seeking/reflecting legal advice 358 NYCPRIV0 2393 Deliberative;Legislative Draft talking points re: Anti- displacement strategies DPP & Legislat ive version of proposed bill advocated by Administation to prevent Tenant harassment; PRODUCE UNDER RODRIGUEZ 359 NYCPRIV0 2398 Attorney Client;Deliberative;Work Product Draft presentation re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation AC & WP draft of document analyzing settlement options 360 NYCPRIV0 3973 Attorney Client Email chain re: Community Opposition Strategies NP Per City's Agreement 48 361 NYCPRIV0 2079 Attorney Client;Deliberative Draft Internal Memorandum re: Commitment to Fair Housing AC & DPP draft decision memo to mayor re: creation of MIH program and seeking/reflecting legal advice 362 NYCPRIV0 2086 Deliberative Draft talking points re: Application of Community Preference NP Per City's Agreement 363 NYCPRIV0 2087 Attorney Client;Deliberative Draft Internal Memorandum re: Commitment to Fair Housing AC & DPP draft decision memo to mayor re: creation of MIH program and seeking/reflecting legal advice 364 NYCPRIV0 2088 Attorney Client;Deliberative Draft Internal Memorandum re: Commitment to Fair Housing AC & DPP draft decision memo to mayor re: creation of MIH program and seeking/reflecting legal advice 365 NYCPRIV0 2412 Deliberative Draft Document re: Anti- displacement strategies NP draft submission to receive an award for innovations in government - public engagement unit submission 366 NYCPRIV0 2487 Work Product Internal Memorandum re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP Analysis for informing litigation strategy 367 NYCPRIV0 2488 Work Product Internal Memorandum re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP Analysis for informing litigation strategy 368 NYCPRIV0 2490 Work Product Notes re: Litigation - Winfield Litigation WP Analysis for informing litigation strategy 369 NYCPRIV0 2491 Deliberative;Work Product Internal Memorandum re: Litigation - Winfield Litigation;Application of Community Preference;Housing Connect Data Analysis WP technical notes for housing study for litigation 370 NYCPRIV0 2493 Deliberative;Work Product Internal Memorandum re: Litigation - Winfield Litigation;Application of Community Preference;Housing Connect Data Analysis WP technical notes for housing study for litigation 371 NYCPRIV0 2496 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation WP & DPP internal deliberations regarding analysis for litigation 372 NYCPRIV0 2497 Deliberative;Work Product Draft presentation re: Litigation - Winfield Litigation;Application of Community Preference;Housing Connect Data Analysis NP Per City's Agreement 373 NYCPRIV0 2498 Deliberative;Work Product Draft presentation re: Litigation - Winfield Litigation;Housing Connect Data Analysis NP Per City's Agreement 49 374 NYCPRIV0 2501 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis NP Per City's Agreement 375 NYCPRIV0 2502 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 376 NYCPRIV0 2504 Deliberative;Work Product Draft presentation re: Litigation - Winfield Litigation;Application of Community Preference;Housing Connect Data Analysis NP Per City's Agreement 377 NYCPRIV0 2506 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation WP & 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 Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 380 NYCPRIV0 2510 Deliberative;Work Product Draft presentation re: Litigation - Winfield Litigation;Application of Community Preference;Housing Connect Data Analysis NP Per City's Agreement 381 NYCPRIV0 2511 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP Internal presentation of internal study of various data conducted to inform litigation strategy and settlement position in Winfield 382 NYCPRIV0 2513 Deliberative;Work Product Draft presentation re: Litigation - Winfield Litigation;Housing Connect Data Analysis NP Per City's Agreement 383 NYCPRIV0 2515 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 384 NYCPRIV0 2526 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 385 NYCPRIV0 2527 Deliberative;Work Product Draft presentation re: Litigation - Winfield Litigation;Application of Community Preference;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 50 386 NYCPRIV0 2536 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 387 NYCPRIV0 2537 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 388 NYCPRIV0 2538 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 389 NYCPRIV0 2540 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 390 NYCPRIV0 2542 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 391 NYCPRIV0 2543 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 392 NYCPRIV0 2546 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 393 NYCPRIV0 2558 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Application of Community Preference;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 394 NYCPRIV0 2559 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 395 NYCPRIV0 2560 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 396 NYCPRIV0 2575 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 397 NYCPRIV0 2576 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Application of Community Preference;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 398 NYCPRIV0 2577 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 51 399 NYCPRIV0 2578 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Application of Community Preference;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 400 NYCPRIV0 2579 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 401 NYCPRIV0 2580 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 402 NYCPRIV0 2581 Deliberative;Work Product Draft Internal Memorandum re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 403 NYCPRIV0 2582 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Application of Community Preference;Housing Connect Data Analysis WP & DPP analysis to inform litigatoin strategy and settlement 404 NYCPRIV0 2583 Deliberative;Work Product 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 Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 406 NYCPRIV0 2585 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 407 NYCPRIV0 2586 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 408 NYCPRIV0 2587 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Application of Community Preference;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 409 NYCPRIV0 3974 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 410 NYCPRIV0 2588 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Application of Community Preference;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 52 411 NYCPRIV0 2589 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Application of Community Preference;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 412 NYCPRIV0 2590 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 413 NYCPRIV0 2591 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 414 NYCPRIV0 2592 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 415 NYCPRIV0 2593 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 416 NYCPRIV0 2595 Deliberative;Work Product 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 Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 418 NYCPRIV0 2597 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 419 NYCPRIV0 2602 Deliberative;Work Product 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 Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 421 NYCPRIV0 2606 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 422 NYCPRIV0 2610 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 423 NYCPRIV0 2611 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 424 NYCPRIV0 2612 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 53 425 NYCPRIV0 2613 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 426 NYCPRIV0 2614 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 427 NYCPRIV0 2615 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 428 NYCPRIV0 2617 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 429 NYCPRIV0 2619 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 430 NYCPRIV0 2620 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 431 NYCPRIV0 2621 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 432 NYCPRIV0 2622 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 433 NYCPRIV0 2655 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 434 NYCPRIV0 2656 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 435 NYCPRIV0 2657 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 436 NYCPRIV0 2658 Deliberative;Work Product Draft Document re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 437 NYCPRIV0 2659 Deliberative;Work Product Draft Document re: Litigation - Winfield Litigation;AFFH and Community Preference;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 438 NYCPRIV0 2660 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation WP & DPP framework for analysis to inform litigaton strategy and settlement 439 NYCPRIV0 2668 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 54 440 NYCPRIV0 2669 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 441 NYCPRIV0 2670 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 442 NYCPRIV0 2671 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 443 NYCPRIV0 2672 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 444 NYCPRIV0 2673 Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP Analysis for informing litigation strategy 445 NYCPRIV0 2674 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 446 NYCPRIV0 2676 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 447 NYCPRIV0 2679 Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP Analysis for information litigation strategy 448 NYCPRIV0 2680 Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP Analysis for informing litigation strategy 449 NYCPRIV0 2681 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 450 NYCPRIV0 2682 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 451 NYCPRIV0 2686 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 452 NYCPRIV0 2687 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 453 NYCPRIV0 2692 Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP Analysis for informing litigation strategy 454 NYCPRIV0 2695 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 455 NYCPRIV0 2696 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 456 NYCPRIV0 2700 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 457 NYCPRIV0 2701 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 458 NYCPRIV0 2702 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 55 459 NYCPRIV0 2703 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 460 NYCPRIV0 2704 Deliberative;Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 461 NYCPRIV0 2746 Deliberative;Work Product Internal Charts or Maps re: Anti-displacement strategies; Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 462 NYCPRIV0 2747 Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;AFFH and Community Preference;Housing Connect Data Analysis WP Analysis for informing litigation strategy 463 NYCPRIV0 2748 Deliberative Internal Charts or Maps re: Litigation - Winfield Litigation;AFFH and Community Preference WP draft data analysis to inform litigation strategy and settlement 464 NYCPRIV0 2749 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP & DPP analysis to inform litigation strategy and settlement 465 NYCPRIV0 2760 Deliberative Final report (non-public) re: Application of Community Preference;Housing Connect Data Analysis DPP 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 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 Draft report re: Litigation - Winfield Litigation WP Analysis for informing litigation strategy 470 NYCPRIV0 2093 Attorney Client;Deliberative Draft Internal Memorandum re: Commitment to Fair Housing AC & DPP decision memo to mayor re: MIH seeking/reflecting legal advice 56 471 NYCPRIV0 3991 Deliberative Draft letter re: Anti- displacement strategies;421-a - Homeless Preference NP Draft letter from Mayor to constituents re: affordable housing 472 NYCPRIV0 3992 Attorney Client;Deliberative Draft Internal Memorandum re: MIH - Anti-displacement strategies;Application of Community Preference AC & DPP draft decision memo to mayor re: creation of MIH program and seeking/reflecting legal advice 473 NYCPRIV0 3998 Deliberative Draft report re: MIH - Anti- displacement strategies;Application of Community Preference DPP Decision memo to mayor re: how to engage with private applications subject to MIH at Barnett Ave.; DO NOT PRODUCE UNDER RODRIGUEZ 474 NYCPRIV0 4004 Deliberative Final letter (non-public) re: MIH - Anti-displacement strategies;ENY - Anti- displacement strategies NP produce; same as 310 475 NYCPRIV0 4007 Deliberative Draft talking points re: Anti- displacement strategies NP draft Q&As re: afffordable housing in connection with 2015 mayor state of city address 476 NYCPRIV0 4016 Attorney Client Draft report re: Anti- displacement strategies;ENY - Anti- displacement strategies AC communication from attorney summarizing thoughts and next steps on affordable housing in specific neighborhood 477 NYCPRIV0 4082 Attorney Client;Deliberative Email chain re: Anti- displacement 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: Anti- displacement strategies;Commitment to Fair Housing AC attorney comments and revisions to anti- harassment tenant protection program RFP 479 NYCPRIV0 4089 Deliberative Email chain re: Anti- displacement strategies NP communications re: draft press release for legal services for tenants 480 NYCPRIV0 4090 Attorney Client;Deliberative Draft report re: Anti- displacement strategies;Commitment to Fair Housing AC attorney comments and revisions to anti- harassment tenant protection program RFP 57 481 NYCPRIV0 4107 Deliberative Draft report re: Commitment to Fair Housing AC attorney comments and revisions to anti- harassment tenant protection program RFP 482 NYCPRIV0 4114 Deliberative Draft talking points re: Anti- displacement strategies;Commitment to Fair HousingNP NP testimony of Jordan Dressler before NYC Council committee on 2017 budget 483 NYCPRIV0 2432 Work Product Draft Internal Memorandum;Notes re: Anti-displacement strategies; Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP Research for informing litigation strategy and settlement position 484 NYCPRIV0 2433 Deliberative;Work Product Draft report;Internal Charts or Maps re: Litigation - Winfield Litigation;Application of Community Preference WP & DPP discussing settlement options in this case 485 NYCPRIV0 2434 Attorney Client;Deliberative Email chain;Notes re: 421- a - Homeless Preference;Application of Community Preference AC 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 - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 488 NYCPRIV0 2442 Deliberative;Work Product Notes re: Litigation - Winfield Litigation WP & DPP notes discussing settlement options in this case 489 NYCPRIV0 2443 Work Product Internal Charts or Maps re: Litigation - Winfield Litigation;Housing Connect Data Analysis WP Analysis for informing litigation strategy 490 NYCPRIV0 2444 Deliberative;Work Product Internal Charts or Maps re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 491 NYCPRIV0 2445 Deliberative;Work Product Draft report;Notes re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP notes discussing metrics for analysis in case 58 492 NYCPRIV0 2446 Deliberative;Work Product Internal Charts or Maps re: Litigation - Anticipated Litigation re: Community Preference;Litigation - Winfield Litigation WP & DPP analysis to inform litigation strategy and settlement 493 NYCPRIV0 2447 Deliberative;Work Product Draft report re: Litigation - Winfield Litigation WP & DPP description of studies about gentrification & displacement relevant to case analysis 494 NYCPRIV0 2449 Deliberative;Legislative Notes re: 421-a - Homeless Preference DPP Internal working notes reflecting questions/considerations in determining implementation of certain preferences; DO NOT PRODUCE UNDER RODRIGUEZ 495 NYCPRIV0 2453 Deliberative Draft talking points;Draft Document re: Anti- displacement strategies NP notes on draft talking points about Inwood Neighborhood study 496 NYCPRIV0 2454 Deliberative Notes;Internal Memorandum re: Community Opposition Strategies DPP notes from neighborhood strategies team meeting about preserving housing; reflects internal discussions about policy strategies; DO NOT PRODUCE UNDER RODRIGUEZ 497 NYCPRIV0 4118 Deliberative Notes re: Anti- displacement strategies DPP action steps and strategies related to homeless prevention policy; DO NOT PRODUCE UNDER RODRIGUEZ 498 NYCPRIV0 2481 Work Product Internal Charts or Maps re: Litigation - Winfield Litigation WP Legal analysis and settlement strategies 499 NYCPRIV0 2482 Attorney Client;Deliberative;Work Product Notes;Draft Document re: Litigation - Winfield Litigation;Commitment to Fair Housing NP Per City's Agreement (except p. 5 which are attorney notes) 500 NYCPRIV0 2485 Work Product Draft Document re: Litigation - Winfield Litigation WP Legal analysis and settlement strategies