Preview
FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023
EXHIBI I
FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023
AMENDMENT TO ASSURANCE OF DISCONTINUANCE MADE
PURSUANT TO EXECUTIVE LAW § 63(15)
BETWEEN THE ATTORNEY GENERAL OF THE STATE OF NEW YORK, for the
PEOPLE OF THE STATE OF NEW YORK, AND DEFENDANTS
MORDECHAI KLEIN, NORMAN RAUSMAN, MARTIN RAUSMAN,
HENRY RAUSMAN, MICHAEL RAUSMAN,
SUSAN ASCHKENAZI,
THE NURSING CARE CENTER AT MEDFORD d/b/a
MEDFORD MULTICARE CENTER FOR LIVING, INC,, AND
MEDFORD MULTICARE MANAGEMENT, LLC
DATED: 2016
WHEREAS, the Attorney General of the State of New York (the "Attorney General"),
on behalf the People of the State of New York, commenced an action in the Supreme Court of
the State of New York, County of Suffolk, J.Molia, Index no. 2941/14 (hereinafter referredto
as the "Action") against The Nursing Care Center at Medford d/b/a Medford Multicare Center
for Living, Inc. ("Medford") and itsowners Mordechai Klein, Norman Rausman, Martin
Rausman, Henry Rausman, Michael Rausman, and Susan Aschkenazi (the "Defendant Owners"),
Medford Multicare Management, LLC ("Medford Management") ct al.,pursuant to Executive
Law § 63(12), Social Services Law § 145-b, State Finance Law Section § 189(1) and the
common law, originally filed on February 1 1,2014, and amended on June 30, 2014 (the
"Amended Complaint"), and had previously conducted an investigation through the Medicaid
Fraud Control Unit (the "MFCU into the of Medford, a 320-bed for-
Investigation") activity
profit nursing home located in Medford, Suffolk County;
FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023
WHEREAS the Participating Defendants include Medford, Medford Management, and
the Defendant Owners, who can bind Medford to all acts required under this Assurance of
("AOD"
Discontinuance or "Agreement");
WHEREAS the Attomey General, Medford, Medford Management and the Defendant
Owners entered into the AOD as of June 22, 2016, pursuant to paragraph 1 of which therewas to
be total required payments of TWENTY-EIGHT MILLION ONE HUNDRED THOUSAND
DOLLARS ($28,100,000.00);
WHEREAS, the New York Department of Health (the "DOH") (i)recognizes thatthe
reliefand promises set forthwithin the AOD, including itsamendment, benefit the publichealth,
including the interests of the current and future residents of Medford, and agrees
(ii) with the
1
resolution set forthfor the Covered Conduct in consideration for DOH's promises herein;
WHEREAS, the Attorney General, the DOH, Medford, Medford Management and the
Defendant Owners agnse to amend the AOD through this Agreement (the "Amended AOD"),
and allterms in the AOD not specified in thisAmended AOD remain in full
force and effect;
AMENDMENTS TO AOD, dated June 22, 2016
1. The Parties hereby amend Section I,paragraphs 7 and 8 of the AOD as follows:
a. Delete paragraph 7 of theAOD and replace itstext with:"the Attorney
General will instructDOH and DOH agrees to immediately remit the balance
remaining of the Withheld Funds by check, which isin the amount of FOUR
MILLION NINETY-NINE THOUSAND, EIGHT HUNDRED TEN
DOLLARS AND SIXTY-NINE CENTS ($4,099,810.69), to Medford, and
Medford shallimmediately deposit allof said Withheld Funds intothe
Medford Resident Care Fund. Defendants hereby waive any claims to said
Allotherwiseundefinedterms hereinhave the same definitions in the AOD
as set forth unless stated otherwise.
2
FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023
withheld funds and consent to the deposit of such funds intothe Medford
Resident Care Fund to be used as setforth in theAOD.
b. Delete paragraph 8 of theAOD and replace itstext with:"Proof of payment
made by Medford of said Withheld Funds into theMedford Resident Care
Fund shallbe provided to theAttomey General within ten (10)business days
thereof."
of payment
2. The parties hereby amend paragraph 9, toinsert at theend of theparagraph:
"Such additional payments shallnot be funded by Medicaid payments made to Medford ifsuch
expenditure would adversely impact the delivery of appropriate, adequate and timely care and
Medford."
services for the residentsof
3. The parties hereby amend Section II,including the subtitleand paragraphs 24
Operator"
through 49 of the AOD to deleteallreferences to the "Independent and replace them
with "Independent Quality Assurance Monitor".
4. The parties hereby amend Section II,paragraphs 25 and 26 ofthe AOD as
follows:
a, Delete paragraph 25 of the AOD and replace its text with: "Participating
Defendants shallretain an Independent Quality Assurance Monitor to provide
consulting services and recommendations regarding the management and
operations of Medford on a day-to-day basis, who shall be on-site though an
independent contractor or employee on a part or full-time basis under the
supervision of the Independent Assurance Monitor. Lisa Wickens-
Quality
Alteri, RN, will be the firstIndependent Quality Assurance Monitor. The
nomination."
Attorney General and the DOH accept that
3
FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023
. -
b. Delete paragraph 26 of the AOD and replace its text with: "The
Engagement Letter between WHSS and Medford, dated June 21, 2016 shall
be amended pursuant to 10 NYCRR §§ 400.4 (contracts)and 415(26)(e)(use
of outside resources) and accordingly, shall include the following language:
"Notwithstanding any other provisions in thiscontract,the facility(Medford)
remains responsible for ensuring that any service provided pursuant to this
contract complies with all pertinent provision of Federal, State and local
regulations."
statutes,rules and
5. The partieshereby deleteparagraph 28 of the AOD.
6. The partieshereby deleteparagraph 29 and replace itstext with: "Participating
Defendants shallimplement allrecommendations made by the independent Quality Assurance
Monitor to ensure adequate, appropriate and timely delivery of care toMedford residents,
subject to theprotocol set forthinparagraph 40 and subject to the Governing authority or
operator's duties and responsibilitiessetforth in10 NYCRR § 600.9 (Governing authority or
operator). The Independent Quality Assurance Monitor shallconsider Medfon) Resident
CounciPs inputwhen making the Independent Quality Assurance Monitor recommendations
requiring expenditures from the Medford Resident Care Fund.
7. The parties hereby amend paragraph 31 as follows:
a. 31 (b) insertthe following at theend of such paragraph: "The Governing
Body will be responsible forensuring that such trainingoccurs and their
employees' attendance."
b. 31 insert new (c):"review Medford's policies and procedures relatingto
patient care and compliance with health and safety laws, rules and regulations,
4
FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023
and provide any revisionsor updates to such policies and procedures to the
Attorney General and the DOH within sixty(60) days of the adoption of such
Body."
policies and procedures by the Governing
8. The parties hereby amend paragraph 34, line2 as follows: Delete and substitute
line2 with: "In the event the Independent Quality Assurance Monitor isunable to complete the
appointment, Participating Defendants will promptly retain a substituteIndependent Quality
Assurance Monitor, with prior approval of the Attorney General and the DOH. The
Independent Quality Assurance Monitor will provide the DOH and the Attorney General 30
days'
notice of the Independent Quality Assurance Monitor's decision to resign fmm such
position."
9. The partieshereby amend paragraph 36 as follows: insertafterthe Attomey
DOH."
General "and the
10. The parties hereby amend paragraph 38, in thelast line,as follows: at theend of
"Agreement"
the sentence afterthe word insert ",and shallbe subject to character and fitness
DOH."
review by the
1 1. Theparties hereby amend paragraph 62 as follows: insertafter"IF TO THE
GENERAL:"
ATTORNEY
IF TO THE DOH:
Mark Furnish
Director
Bureau of Health Facility Planning and Development
Division of Legal Affairs
New York State Department of Health
Room 2482, Tower Building
Empire State Plaza
Albany, NY 12237
518.473.3303
mark.furnish@health.ny.pov
5
FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023
12. The partieshereby amend paragraph 67(2) as follows: insertafter "any
liability"
administrative the phrase "of OMIG.
"70."
13.. The parties hereby combine paragraphs 69 and 70,and delete the that
appeared between the two paragraphs as a resultof a clerical
error.
14. Immediately before paragraph 71, theparties hereby insert as new paragraph 70
as follows: "Subject to exceptions set forthin paragraph 67, the DOH hereby releases
Participating Defendants, and their successors in interest,from any administrative monetary
claims involving the imposition of fines and penalties that DOH has or may have for theCovered
DOH."
Conduct under administrative proceedings initiated
or conducted by
WHEREFORE, the following signatures are affixed hereto on this ay of
2016.
ERIC T. SCHNEIDERMAN
Attorney General of the State of New York
BY:
Sally G. BlinkYn
Special Assistant Attorney General
Medicaid Fraud Control Unit
6
FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023
THENEW Y RK STATE DEPAR 4ENT OF HEALTH
BY:
DanielB. Sheppard, Deputy Commissioner
Officeof Primary Care and Health Systems Management
BY:
Jason A. Helgerson,
Deputy Commissioner and Medicaid Director
Office of Health Insurance Programs
7
FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023
THE NEW YORK STATE DEPARTMENT OF HEALTH
BY:
DanielB. Sheppani, Deputy Commissioner
Officeof Pri aryCare and Health Systems Management
BY:
Jason A, lge on,
Deputy Co i ioner and Medicaid Director
Office ofHealth Insurance Programs
7
FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023
The Defendants:
Participating
BY:
A BY:
rdechaiBEBD. WINDÈR Norman Rausman
NaW1Mk
Nden PutAlo-81sted
No.0tWIONMM
Quallliedin NassaucouNP
Swom to before Swom to before me this
day of 2016 _ day of , 2016
u NotaryPublic
BY: BY:
Martin Rausman Henry Rausman
me this
Sworn to before Swom to before me this
day of , 2016 _ day of , 2016
Notany Public NotaryPublic
BY: BY:
Michael Rausman Susan Aschkenazi
Sworn to before
me this Sworn to before me this
_ day of , 2016 ___ day of , 2016
NotaryPublic Notary Public
8
FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023
The Participating
Defendants:
BY·
BY:.
Nonnan Rausman
MITCHELL REBHUN
Stateof New Y R
NotaryPublic,
Sworn to before me this Qua n Roc and u
Commission ExpiresJune 2Î 0Q
day of 2016 day of 2016
N Pub c
Martin Rausman enry Ra
MITCHELL REBHUN
Notary Public,Stateof NewYor MITCHELL REBHUN
No. 01RE6128989 Public,Stateof New YorK
Notary
Oual, in RocklandCounty No. 018E8128989
Swom to before me t mmission ExpiresJune 20, 2 worn to before me this Coun
Qual in Rockland y
Corn lon ExpIreaJune 20 0
A/
day of 2016 day of
No We NolaryPublic
gy.
BY:
Michael Rausman Susan Aschkenazi
MITCHELL REBHUN MITCHELL REBHUN
Notary Pubile,Stateof New 'ork State of Nework
Notary Public,
No. 01RE6128989 No. 01RE6128989
Qual. In RocklandCoun no Count
to before me this Qual In Rockland
Sworn me this Commission
to before ExpiresJune 20, ExpiresJune 20,
Commission OG
day of 2016 i day of fOD 2016
NotaryPublic NotaryPub :
8
FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023
The Care Center at Medford d /a Medford Multicare Management
Nursing
Medford Multicare Center for Living
BY: __ BY:
Name: Name:
Sworn to before me this Sworn to before me this
U1' 2016
day of 016 day of
NotaryPublic Notary Public
MITCHELL REBFlUN MITCHELL REBHUN
Notary Public,Stateof New York NotaryPublic,Stateof New York
No. 01RE6128989 No. 01RE6128989
Oual.In Rockland County Dual.In RocklandCounty
Commission ExpiresJune 20, 20 .. Commission ExpiresJune 20, 24
9
Preview
FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023 EXHIBI I FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023 AMENDMENT TO ASSURANCE OF DISCONTINUANCE MADE PURSUANT TO EXECUTIVE LAW § 63(15) BETWEEN THE ATTORNEY GENERAL OF THE STATE OF NEW YORK, for the PEOPLE OF THE STATE OF NEW YORK, AND DEFENDANTS MORDECHAI KLEIN, NORMAN RAUSMAN, MARTIN RAUSMAN, HENRY RAUSMAN, MICHAEL RAUSMAN, SUSAN ASCHKENAZI, THE NURSING CARE CENTER AT MEDFORD d/b/a MEDFORD MULTICARE CENTER FOR LIVING, INC,, AND MEDFORD MULTICARE MANAGEMENT, LLC DATED: 2016 WHEREAS, the Attorney General of the State of New York (the "Attorney General"), on behalf the People of the State of New York, commenced an action in the Supreme Court of the State of New York, County of Suffolk, J.Molia, Index no. 2941/14 (hereinafter referredto as the "Action") against The Nursing Care Center at Medford d/b/a Medford Multicare Center for Living, Inc. ("Medford") and itsowners Mordechai Klein, Norman Rausman, Martin Rausman, Henry Rausman, Michael Rausman, and Susan Aschkenazi (the "Defendant Owners"), Medford Multicare Management, LLC ("Medford Management") ct al.,pursuant to Executive Law § 63(12), Social Services Law § 145-b, State Finance Law Section § 189(1) and the common law, originally filed on February 1 1,2014, and amended on June 30, 2014 (the "Amended Complaint"), and had previously conducted an investigation through the Medicaid Fraud Control Unit (the "MFCU into the of Medford, a 320-bed for- Investigation") activity profit nursing home located in Medford, Suffolk County; FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023 WHEREAS the Participating Defendants include Medford, Medford Management, and the Defendant Owners, who can bind Medford to all acts required under this Assurance of ("AOD" Discontinuance or "Agreement"); WHEREAS the Attomey General, Medford, Medford Management and the Defendant Owners entered into the AOD as of June 22, 2016, pursuant to paragraph 1 of which therewas to be total required payments of TWENTY-EIGHT MILLION ONE HUNDRED THOUSAND DOLLARS ($28,100,000.00); WHEREAS, the New York Department of Health (the "DOH") (i)recognizes thatthe reliefand promises set forthwithin the AOD, including itsamendment, benefit the publichealth, including the interests of the current and future residents of Medford, and agrees (ii) with the 1 resolution set forthfor the Covered Conduct in consideration for DOH's promises herein; WHEREAS, the Attorney General, the DOH, Medford, Medford Management and the Defendant Owners agnse to amend the AOD through this Agreement (the "Amended AOD"), and allterms in the AOD not specified in thisAmended AOD remain in full force and effect; AMENDMENTS TO AOD, dated June 22, 2016 1. The Parties hereby amend Section I,paragraphs 7 and 8 of the AOD as follows: a. Delete paragraph 7 of theAOD and replace itstext with:"the Attorney General will instructDOH and DOH agrees to immediately remit the balance remaining of the Withheld Funds by check, which isin the amount of FOUR MILLION NINETY-NINE THOUSAND, EIGHT HUNDRED TEN DOLLARS AND SIXTY-NINE CENTS ($4,099,810.69), to Medford, and Medford shallimmediately deposit allof said Withheld Funds intothe Medford Resident Care Fund. Defendants hereby waive any claims to said Allotherwiseundefinedterms hereinhave the same definitions in the AOD as set forth unless stated otherwise. 2 FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023 withheld funds and consent to the deposit of such funds intothe Medford Resident Care Fund to be used as setforth in theAOD. b. Delete paragraph 8 of theAOD and replace itstext with:"Proof of payment made by Medford of said Withheld Funds into theMedford Resident Care Fund shallbe provided to theAttomey General within ten (10)business days thereof." of payment 2. The parties hereby amend paragraph 9, toinsert at theend of theparagraph: "Such additional payments shallnot be funded by Medicaid payments made to Medford ifsuch expenditure would adversely impact the delivery of appropriate, adequate and timely care and Medford." services for the residentsof 3. The parties hereby amend Section II,including the subtitleand paragraphs 24 Operator" through 49 of the AOD to deleteallreferences to the "Independent and replace them with "Independent Quality Assurance Monitor". 4. The parties hereby amend Section II,paragraphs 25 and 26 ofthe AOD as follows: a, Delete paragraph 25 of the AOD and replace its text with: "Participating Defendants shallretain an Independent Quality Assurance Monitor to provide consulting services and recommendations regarding the management and operations of Medford on a day-to-day basis, who shall be on-site though an independent contractor or employee on a part or full-time basis under the supervision of the Independent Assurance Monitor. Lisa Wickens- Quality Alteri, RN, will be the firstIndependent Quality Assurance Monitor. The nomination." Attorney General and the DOH accept that 3 FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023 . - b. Delete paragraph 26 of the AOD and replace its text with: "The Engagement Letter between WHSS and Medford, dated June 21, 2016 shall be amended pursuant to 10 NYCRR §§ 400.4 (contracts)and 415(26)(e)(use of outside resources) and accordingly, shall include the following language: "Notwithstanding any other provisions in thiscontract,the facility(Medford) remains responsible for ensuring that any service provided pursuant to this contract complies with all pertinent provision of Federal, State and local regulations." statutes,rules and 5. The partieshereby deleteparagraph 28 of the AOD. 6. The partieshereby deleteparagraph 29 and replace itstext with: "Participating Defendants shallimplement allrecommendations made by the independent Quality Assurance Monitor to ensure adequate, appropriate and timely delivery of care toMedford residents, subject to theprotocol set forthinparagraph 40 and subject to the Governing authority or operator's duties and responsibilitiessetforth in10 NYCRR § 600.9 (Governing authority or operator). The Independent Quality Assurance Monitor shallconsider Medfon) Resident CounciPs inputwhen making the Independent Quality Assurance Monitor recommendations requiring expenditures from the Medford Resident Care Fund. 7. The parties hereby amend paragraph 31 as follows: a. 31 (b) insertthe following at theend of such paragraph: "The Governing Body will be responsible forensuring that such trainingoccurs and their employees' attendance." b. 31 insert new (c):"review Medford's policies and procedures relatingto patient care and compliance with health and safety laws, rules and regulations, 4 FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023 and provide any revisionsor updates to such policies and procedures to the Attorney General and the DOH within sixty(60) days of the adoption of such Body." policies and procedures by the Governing 8. The parties hereby amend paragraph 34, line2 as follows: Delete and substitute line2 with: "In the event the Independent Quality Assurance Monitor isunable to complete the appointment, Participating Defendants will promptly retain a substituteIndependent Quality Assurance Monitor, with prior approval of the Attorney General and the DOH. The Independent Quality Assurance Monitor will provide the DOH and the Attorney General 30 days' notice of the Independent Quality Assurance Monitor's decision to resign fmm such position." 9. The partieshereby amend paragraph 36 as follows: insertafterthe Attomey DOH." General "and the 10. The parties hereby amend paragraph 38, in thelast line,as follows: at theend of "Agreement" the sentence afterthe word insert ",and shallbe subject to character and fitness DOH." review by the 1 1. Theparties hereby amend paragraph 62 as follows: insertafter"IF TO THE GENERAL:" ATTORNEY IF TO THE DOH: Mark Furnish Director Bureau of Health Facility Planning and Development Division of Legal Affairs New York State Department of Health Room 2482, Tower Building Empire State Plaza Albany, NY 12237 518.473.3303 mark.furnish@health.ny.pov 5 FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023 12. The partieshereby amend paragraph 67(2) as follows: insertafter "any liability" administrative the phrase "of OMIG. "70." 13.. The parties hereby combine paragraphs 69 and 70,and delete the that appeared between the two paragraphs as a resultof a clerical error. 14. Immediately before paragraph 71, theparties hereby insert as new paragraph 70 as follows: "Subject to exceptions set forthin paragraph 67, the DOH hereby releases Participating Defendants, and their successors in interest,from any administrative monetary claims involving the imposition of fines and penalties that DOH has or may have for theCovered DOH." Conduct under administrative proceedings initiated or conducted by WHEREFORE, the following signatures are affixed hereto on this ay of 2016. ERIC T. SCHNEIDERMAN Attorney General of the State of New York BY: Sally G. BlinkYn Special Assistant Attorney General Medicaid Fraud Control Unit 6 FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023 THENEW Y RK STATE DEPAR 4ENT OF HEALTH BY: DanielB. Sheppard, Deputy Commissioner Officeof Primary Care and Health Systems Management BY: Jason A. Helgerson, Deputy Commissioner and Medicaid Director Office of Health Insurance Programs 7 FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023 THE NEW YORK STATE DEPARTMENT OF HEALTH BY: DanielB. Sheppani, Deputy Commissioner Officeof Pri aryCare and Health Systems Management BY: Jason A, lge on, Deputy Co i ioner and Medicaid Director Office ofHealth Insurance Programs 7 FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023 The Defendants: Participating BY: A BY: rdechaiBEBD. WINDÈR Norman Rausman NaW1Mk Nden PutAlo-81sted No.0tWIONMM Quallliedin NassaucouNP Swom to before Swom to before me this day of 2016 _ day of , 2016 u NotaryPublic BY: BY: Martin Rausman Henry Rausman me this Sworn to before Swom to before me this day of , 2016 _ day of , 2016 Notany Public NotaryPublic BY: BY: Michael Rausman Susan Aschkenazi Sworn to before me this Sworn to before me this _ day of , 2016 ___ day of , 2016 NotaryPublic Notary Public 8 FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023 The Participating Defendants: BY· BY:. Nonnan Rausman MITCHELL REBHUN Stateof New Y R NotaryPublic, Sworn to before me this Qua n Roc and u Commission ExpiresJune 2Î 0Q day of 2016 day of 2016 N Pub c Martin Rausman enry Ra MITCHELL REBHUN Notary Public,Stateof NewYor MITCHELL REBHUN No. 01RE6128989 Public,Stateof New YorK Notary Oual, in RocklandCounty No. 018E8128989 Swom to before me t mmission ExpiresJune 20, 2 worn to before me this Coun Qual in Rockland y Corn lon ExpIreaJune 20 0 A/ day of 2016 day of No We NolaryPublic gy. BY: Michael Rausman Susan Aschkenazi MITCHELL REBHUN MITCHELL REBHUN Notary Pubile,Stateof New 'ork State of Nework Notary Public, No. 01RE6128989 No. 01RE6128989 Qual. In RocklandCoun no Count to before me this Qual In Rockland Sworn me this Commission to before ExpiresJune 20, ExpiresJune 20, Commission OG day of 2016 i day of fOD 2016 NotaryPublic NotaryPub : 8 FILED: SUFFOLK COUNTY CLERK 01/12/2023 09:23 AM INDEX NO. 608653/2020 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 01/12/2023 The Care Center at Medford d /a Medford Multicare Management Nursing Medford Multicare Center for Living BY: __ BY: Name: Name: Sworn to before me this Sworn to before me this U1' 2016 day of 016 day of NotaryPublic Notary Public MITCHELL REBFlUN MITCHELL REBHUN Notary Public,Stateof New York NotaryPublic,Stateof New York No. 01RE6128989 No. 01RE6128989 Oual.In Rockland County Dual.In RocklandCounty Commission ExpiresJune 20, 20 .. Commission ExpiresJune 20, 24 9