July 2004

STEVENS AMENDED COMPLAINT: ALLEGED DEFAMATORY STATEMENTS

1st Statement Serpentine rock usually contains asbestos, sometimes in a form considered highly dangerous. No precautions or monitoring has taken place as [the excavation proceeds]. FBW Website, April 8, 2002

2nd Statement A recent test by a Stevens' consultant confirmed that the dust surrounding the construction site contains asbestos that exceeds acceptable levels set by the federal Environmental Protection Agency. FBW Website shortly after April 8, 2002

3rd Statement No precautions have been taken thus far to water down the excavation site or, during the blasting, to prevent the dust from spreading through the neighborhood. FBW Website shortly after April 8, 2002

4th Statement It is urgent that you respond to the health hazard posed by the continued blasting and excavation of the parking garage site at 6th Street between River Street and Sinatra Drive. There are many unanswered questions as Stevens . . . continues to suppress information and minimize the problem. 5th Statement Nearly every day significant amounts of chrysotile (white asbestos) have been detected by Steven's own monitoring system. Hine letter to Mayor, April 18, 2002

6th Statement We have spent considerable time talking to state and local officials regarding this problem. Hine letter to Mayor, April 18, 2002

7th Statement Stevens caused "toxic dust" to settle on Hoboken's little league field and Sinatra Park. Lewit letter of May 3, 2002 to Jersey Journal and Hoboken Reporter

8th Statement Remember that windstorm a couple of weeks ago, which blew all that filthy grit into your skin, eyes, and lungs? Thanks to excavations by Stevens Institute of Technology permitted by the City of Hoboken, that could have contained asbestos. Daniel Tumpson letter of May 12, 2002 letter to Hoboken Reporter

9th Statement The removal of 20 to 30 thousand cubic yards of serpentine rock at Stevens Institute of Technology has posed a serious health crisis for our community. . . . This is a serious, serious problem that demands forceful action on the part of the City, Stevens, the State DEP and other agencies that are obligated to protect our health and safety. Hine letter of June 9, 2002 letter to Hoboken Reporter

10th Statement The excavation provided further evidence of Stevens' arrogance as they failed to notify the public of the potential asbestos hazard and proceeded to dump the hazardous material in the Meadowlands illegally. Hine letter of December 22, 2002 to the Hoboken Reporter