Liberty Park Legal Working Group

c/o 299 Broadway, Suite 806 New York, NY 10007-1901 November 3, 2011 BY FACSIMILE TO (718) 999-1486 Fire Department of the City of New York Attn: Commissioner Salvatore Cassano Re: Second Demand to Return Liberty Park Generators

Dear Commissioner Cassano: We are attorneys and legal workers associated with the New York City Chapter of the National Lawyers Guild. We represent the owners of generators seized on October 28, 2011 from Liberty Park by the Fire Department of the City of New York (FDNY) and the New York City Police Department. By letter dated October 29, 2011, we wrote to demand the immediate return of the generators. There has been no response from FDNY to our demand. We began to make calls following up on our demand on Monday, October 31, 2011. None of our calls to your office or to the Department Counsels Office were returned. No calls to your office or to the First Deputy Commissioners Office or to the Counsels office on Tuesday were returned. However, Mr. Oliver spoke with the Counsel, who indicated that the First Deputy Commissioners Office had forwarded the demand letter and attachments to his office and that we would be receiving a response after the Counsels office had conducted an investigation. That was two days ago. This is to reiterate our demand that you return the generators immediately. Please contact Mr. Oliver at 646 263 3495 to arrange for the immediate return of the generators. In the event that the generators are not returned by 2:00PM on Friday, November 4, 2011, please let us know the name, telephone number, and e-mail address of the FDNY representative who can appear on Friday afternoon to represent FDNY if we are required to pursue non-administrative remedies. Thank you for your immediate attention to this matter. Very truly yours, Liberty Park Legal Working Group /S/ By: Gideon Orion Oliver cc: Department Counsel Julian Bazel, Esq.