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2 - - - - - - - - - - - - - - - - - - - -x
3 In the Matter of the Investigation of
4 Buffalo Center for Rehabilitation and
5 Nursing,
6 Examination Under Oath Pursuant
7 to Executive Law 63(12):
8 AHARON LANTZITSKY
9 - - - - - - - - - - - - - - - - - - - -x
May 4, 2022
10
10:00 a.m.
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12
13 EXAMINATION UNDER OATH of
14 AHARON LANTZITSKY, held virtually via
15 Webex, taken before Jamie Ann Stanton, a
16 Registered Professional Reporter and
17 Notary Public of the State of New York,
18 pursuant to Executive Law 3(12).
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2 APPEARANCES:
3
NEW YORK STATE OFFICE
4 OF THE ATTORNEY GENERAL
1 Blue Hill Plaza, #1037
5 Pearl River, New York 10965
6 BY: WILLIAM McCLARNON, ESQ.
HILLARY CHAPMAN, ESQ.
7 SIOBHAN O'LEARY, ESQ.
TODD PETTIGREW, ESQ.
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9
HINMAN STRAUB, P.C.
10 121 State Street
Albany, New York 12207
11 Attorneys for witness
12 BY: DAVID LUNTZ, ESQ.
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14 * * *
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2 A H A R O N L A N T Z I T S K Y , the
3 witness herein, having first been duly
4 sworn by the Notary Public, was examined
5 and testified as follows:
6 EXAMINATION BY
7 MR. McCLARNON:
8 Q Good morning, we are now on the
9 record. Today is May 4, 2022, at
10 approximately 10:10 a.m.
11 If you could just state your
12 name, Mr. Lantzitsky and spell it for the
13 record, please.
14 A It's Aharon Lantzitsky.
15 A-h-a-r-o-n, Lantzitsky is Lantzitsky.
16 Q And what is your work address,
17 sir?
18 A 4770 White Plains Road, Bronx,
19 New York, 10470.
20 Q Thank you.
21 My name's William McClarnon. I
22 am an Assistant Attorney General in the
23 Office of the Attorney General of the
24 State of New York. We are conducting
25 this examination remotely in order to
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2 ensure the health and safety of all
3 participants and due Corona virus-related
4 concerns. The examination will be
5 recorded by stenographic means by a court
6 reporter certified to record the
7 deposition in the State of New York. And
8 all deposition exhibits will be presented
9 electronically.
10 Joining us this morning from
11 our office is Assistant Attorney General
12 Hillary Chapman, Assistant Attorney
13 General Todd Pettigrew, and
14 auditor/investigator, Siobhan O'Leary.
15 Before we proceed, other than
16 devices for the purposes of this
17 interview, please turn off all mobile
18 phones, laptops, tablets and other
19 electronic devices, and I will do the
20 same.
21 A Okay. It's off.
22 Q This examination is being
23 conducted by the Attorney General of the
24 State of New York pursuant to Executive
25 Law 63(12) and other statutes and
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2 regulations. Before we start your
3 testimony, I am going to mention a few
4 ground rules, Mr. Lantzitsky. You have
5 the right to consult with an attorney,
6 although you do not have the right to
7 have an attorney with you in this
8 examination, the Attorney General will
9 permit you to have your attorney present
10 during your testimony today.
11 A Thank you.
12 Q Anything you say in this
13 examination may be used in a legal
14 proceeding. You have the right to refuse
15 to answer any question if a truthful
16 answer to the question would tend to
17 incriminate you. Any willful
18 misstatement by you may constitute
19 perjury, and I emphasize a willful
20 misstatement.
21 Finally, this investigation
22 is confidential. We request that you not
23 discuss this matter, your testimony here
24 today, and any documents you may have
25 reviewed or produced or may produce in
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2 connection with today's testimony with
3 anyone other than your attorneys.
4 A few other instructions before
5 we proceed. In order for the court
6 reporter to create a clear record, please
7 answer all questions verbally because the
8 reporter cannot record a nonverbal
9 gesture such as a nodding of the head.
10 Please let me finish each question before
11 you begin your answer, and I will allow
12 you to finish your answer before asking
13 my next question.
14 If you need to take a break at
15 any time, just let me know. If there's a
16 question pending, I will ask that you
17 answer it before we break. If you do not
18 hear a question, please let me know and I
19 will repeat it. If you do not understand
20 a question, please let me know, and I
21 will either repeat it or rephrase it if
22 appropriate. If you answer a question, I
23 and anyone reading this transcript will
24 assume you understood the question.
25 And do you understand that,
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2 sir?
3 A Yes.
4 Q Fine. And just check, you can
5 hear me clearly; is that correct?
6 A I do, yes.
7 Q Thank you.
8 Sometimes you may give an
9 answer as completely as you can and then
10 later you remember additional
11 information. If that happens to you,
12 please tell me that you would like to add
13 something to an earlier answer, and we
14 will do that right then, while it's on
15 your mind.
16 Do you understand that, sir?
17 A Yes.
18 Q In addition, it might occur to
19 you at some point that a previous answer
20 you gave was not completely accurate. If
21 that happens, please let me know, and you
22 may make any necessary corrections to
23 your answers at that time.
24 Do you understand that?
25 A Yes.
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2 Q Have you consumed any alcohol
3 or taken any drugs or medications prior
4 to testifying today or have any condition
5 that could prevent you from giving full,
6 complete and truthful answers to my
7 questions today?
8 A No.
9 Q Is there any other reason why
10 you could not provide your best and most
11 accurate testimony today?
12 A Not -- I can't think of
13 anything, so the answer would be no.
14 Q Thank you.
15 And you are represented by
16 Counsel, Mr. Luntz, correct?
17 A Correct.
18 MR. McCLARNON: Mr. Luntz, if
19 you would just note your appearance
20 for the record, please?
21 MR. LUNTZ: Sure. David
22 Luntz, Hinman Straub, 121 State
23 Street, Albany, New York.
24 MR. McCLARNON: Thank you.
25 Q Your counsel and I have certain
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2 stipulations. I believe that Mr. Luntz
3 will agree to these. These are
4 stipulations we previously entered into.
5 We've agreed to stipulate that,
6 Mr. Lantzitsky, you are present in New
7 York State, at this time.
8 A Correct.
9 Q We've agreed that unless on a
10 break, Mr. Lantzitsky, you and your
11 counsel will not communicate with each
12 other other than on the record.
13 We've agreed that such
14 communication includes deliberate visual
15 cues or communications by any electronic
16 communications. We also ask that other
17 than counsel, no one else be present
18 while you testify in the office space
19 that you are currently in. And I don't
20 see anyone.
21 Can I assume, Mr. Lantzitsky,
22 that there is no one else in the room
23 other than Mr. Luntz?
24 A There is no one else.
25 Q And I would ask that if someone
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2 comes into the room, that you immediately
3 inform us of that so that we can identify
4 that person and hold the questions until
5 that person has left the room.
6 A Sure.
7 Q We've agreed that neither side
8 will record these proceedings or any
9 portion thereof.
10 A Other than the sten record?
11 MR. LUNTZ: These are things
12 we've agreed to. They're not
13 recording the video and we're not
14 recording the video.
15 THE WITNESS: Right, okay.
16 Q And Mr. Lantzitsky, will you
17 waive the requirement that you be present
18 with the reporter while giving testimony
19 here today?
20 A Yes.
21 MR. McCLARNON: And
22 Mr. Luntz, will you also waive any
23 challenge to these proceedings based
24 on the fact that your client and the
25 reporter are not physically together?
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2 MR. LUNTZ: Correct.
3 MR. McCLARNON: Thank you.
4 Q Do you have any questions,
5 Mr. Lantzitsky, before we proceed?
6 A No.
7 Q Throughout the course of these
8 proceedings, Buffalo Center For
9 Rehabilitation and Nursing Care will be
10 referred to as "Buffalo Center," and
11 Centers Healthcare, I will refer to as
12 "Centers Health."
13 Have you ever gone by any other
14 names, other than Aharon Lantzitsky?
15 A No.
16 Q Okay.
17 A I have a middle name, so -- but
18 not -- it's rarely used.
19 Q Okay. And what is your date of
20 birth, sir?
21 A .
22 Q Do you hold any professional
23 licenses?
24 A Nursing home administrator.
25 Q And when were you licensed?
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2 A Initially, two thousand and --
3 I think December 2012, in Massachusetts.
4 And then, in New York, the exact date, I
5 think it was sometime in June -- June or
6 July 2016.
7 Q Okay.
8 A I don't -- yeah, I don't
9 remember the exact date.
10 Q Okay, very good, thank you.
11 And who is your current
12 employer?
13 A Centers Healthcare.
14 Q And what is your job title or
15 position?
16 A Division president.
17 Q And how long have you been a
18 division president with Centers Health?
19 A From the time -- around 2018,
20 some point in 2018.
21 Q And when were you first
22 employed by Centers Health?
23 A I think it was April 21st,
24 2016.
25 Q Prior to becoming division
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2 president, what other positions have you
3 held with Centers Health?
4 A Regional administrator.
5 Q And so you were first hired as
6 regional administrator?
7 A Yes.
8 Q Other than employment at
9 Centers Health, have you ever worked in
10 the nursing home field?
11 A Yes. In Massachusetts, I
12 worked as an administrator, and then a
13 regional director of operations, which is
14 similar to the title that is similar to a
15 regional administrator, same idea.
16 Q And who did you work with in
17 those capacities?
18 A A company called Marquis Health
19 Services.
20 Q And so Marquis Health Services,
21 did they operate skilled nursing
22 facilities?
23 A Yes, in Massachusetts.
24 Q And specifically, in your
25 position, you said you were an
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2 administrator. You were the
3 administrator of a single skilled nursing
4 facility?
5 A Yes.
6 Q And what facility was that?
7 A So I started out -- well,
8 actually, I started out an assistant
9 administrator in a facility in Rockland,
10 Massachusetts, called Coyne Healthcare.
11 That no longer exists. It is now
12 Rockland -- no, now it's Webster Park.
13 They changed the name. And then I
14 started out, my first job, in Needham,
15 Massachusetts, in a facility called
16 Briarwood Healthcare. And then I
17 transitioned from there, within the same
18 company, to a place in Saugus,
19 Massachusetts, called Chestnut Park.
20 Q And those were all as position
21 of administrator or assistant
22 administrator?
23 A Yes.
24 Q And then you said you became a
25 similar -- for lack of a better term -- a
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2 regional administrator.
3 What areas did you cover in
4 that position?
5 A So mostly central Massachusetts
6 and a little bit west.
7 Q And approximately, were you the
8 regional administrator of a number of
9 skilled nursing facilities?
10 A Yes.
11 Q Do you know how many skilled
12 nursing facilities were under your
13 auspices?
14 A Four, four.
15 Q Okay. And how were you first
16 hired by Marquis Health Services?
17 A Wow, that's going back. So I
18 happened to be friends with the owner
19 of -- I was friends of a friend of the
20 owner of the company who introduced us
21 and we -- I spoke with him, then we had
22 an interview, and he sold me on
23 healthcare and here I am.
24 Q At the time that you -- I can't
25 remember the date, so at the time that
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2 you first hired on with Marquis Health
3 Services, were you either a licensed
4 administrator, or were you working on
5 your licensing at that point in time?
6 A So when I started, I had not.
7 I started assistant administrator to
8 see -- to see the field, see if I could
9 and wanted to be involved in the field.
10 And as I worked through that, I saw I
11 enjoyed it, I had -- it was something
12 that worked for me, and I was able to do
13 it. So then I pursued my license as an
14 assistant administrator working for them.
15 Q And there came a point in time,
16 obviously, when you left Marquis Health
17 Services.
18 Why did you leave?
19 A I moved to New York. That was
20 for family -- I am originally from
21 Rockland County, in New York. So -- and
22 I was out for seventeen years and then I
23 moved back and I was traveling to
24 Massachusetts and then it just -- it made
25 more sense to stay -- to stay -- to work
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2 in New York.
3 Q Between Marquis Health Services
4 and Centers Health, did you have any
5 other positions or jobs in between those
6 two?
7 A Between the two, no.
8 Q And how did you come to work
9 for Centers Health?
10 A So I have a relative that was
11 working in -- in Centers, in the business
12 office. And he -- and, you know, we were
13 related, so we met at various functions
14 and times, and he was pushing me to meet
15 with some of the ownership group. He
16 felt that -- he knows me, I know him, and
17 he felt that it was a -- a good marriage
18 per se. And so I finally -- I finally
19 agreed and I met with him and actually,
20 he was correct, it's actually a very
21 good -- a great group to work for.
22 Q And who is this relative? What
23 position was he?
24 A So he was the business office,
25 at the time, I think he was working in
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2 the budgeting department.
3 Q Okay.
4 A He is no longer there. He
5 moved on. He got a great position in a
6 different -- totally different company,
7 not a nursing home, and then so...
8 Q And who, regarding the position
9 that you first started with at Centers
10 Health, who interviewed you for that
11 position?
12 A So I interviewed initially with
13 Mr. Izzy Wolf and Amir Abramchik and the
14 second level, with Kenny Rozenberg,
15 Abramchik and Izzy Wolf.
16 Q Prior to your involvement
17 either through the hiring process with
18 Centers Health, were you involved with
19 any of those gentlemen?
20 A No.
21 Q Again, at your first position
22 at Centers Health, was what?
23 A Regional administrator.
24 Q And what did that entail?
25 A So I oversaw the upstate -- so
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2 their upstate was split into regions, I
3 oversaw the Adirondack portion of the
4 Upstate New York portfolio.
5 Q Was that a number of skilled
6 nursing facilities?
7 A Yes, yes, similar to
8 Massachusetts. It was five nursing
9 facilities.
10 Q Anything other than skilled
11 nursing facilities, any other entities,
12 or just skilled nursing facilities?
13 A At the time it was only skilled
14 nursing facilities.
15 Q Do you know approximately how
16 many there were in your region at that
17 time?
18 A When I started, there was five.
19 And then 10.
20 Q And what five facilities were
21 those?
22 A So those were Warren Center,
23 Washington Center, what's now Granville
24 Center, it was Indian River at the time,
25 Essex Center and Fulton Center.
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2 Q And how long did you hold that
3 position?
4 A So those five --
5 Q Strike that. Let me clarify.
6 For how long were you regional
7 administrator for those five facilities?
8 A So let me -- if I can, I just?
9 Q Certainly.
10 A So after six months, it grew to
11 10. So those five plus another 10, which
12 was our upstate portfolio for -- for a
13 while. And so that lasted until 2018.
14 Q Is there a geographic region,
15 you called it, I think, the Adirondack
16 division, if you will, is there a
17 geographic region that you can describe
18 that you were responsible for, or was it
19 spread out more than typical geographic
20 region, if you will?
21 A So after the first six months,
22 it was pretty much upstate from -- we
23 didn't have anything below Warren County,
24 so it was pretty much from Warren County
25 up through Essex County then it crossed
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2 the upstate. So at the time we had
3 nothing in the central region. And then
4 we -- our first building was in the
5 western part of the state. So we had it
6 in Ontario county, and then in Eerie
7 county.
8 Q And so at that point in time,
9 was Buffalo Center one of those
10 facilities that you were responsible for
11 as a regional administrator?
12 A Yes. After the first six
13 months, after the initial six months,
14 yes.
15 Q When did you move on from being
16 a regional administrator into division
17 president? Was that the step, from
18 regional administrator to division
19 president?
20 A Yes. Yes.
21 Q So when did that occur?
22 A Around 2018. I don't have the
23 exact date because it was just a
24 transition, so I don't remember the exact
25 point that we did that, but -- let's just
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2 say, I mean, for argument sake, I can try
3 to go back and get the exact date, but I
4 think --
5 Q Approximate will do.
6 A January 1st, 2018, makes sense.
7 Q Beginning of 2018 sometime?
8 A I think so, yeah.
9 Q And as regional administrator,
10 what were your general responsibilities?
11 A So -- to make sure, to ensure
12 that operationally, the building is
13 running and the building is regulatory
14 compliant and financially it's stable.
15 Q How many regional
16 administrators were there at that time
17 for Centers Health?
18 A So it was just me.
19 Q Did they have facilities that
20 did not fall within your area?
21 A Yes, they did.
22 Q But they did not have regional
23 administrator for those facilities?
24 A No.
25 Q Can you explain why they had a
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2 regional administrator for those upstate,
3 if you will, lack of a better term,
4 facilities, but none for Downstate at
5 that time?
6 A There was no hard and fast rule
7 as to why we did it that way. The
8 thinking was that the facilities closer
9 to the city are in and around the
10 corporate office and easier to just
11 communicate and manage as opposed to the
12 upstate facilities which were a minimal
13 of three hours away, and, obviously,
14 Buffalo, a little father away, so we
15 wanted to make sure that we had a
16 presence in the facilities supporting
17 them. And that's why that position was
18 created.
19 Q Was there a regional
20 administrator before you joined Centers
21 Health, to your knowledge?
22 A There was.
23 Q Do you know who that was?
24 A The name was Gabe, I believe,
25 Seebag, I think it's Seebag.
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2 Q Do you know how that last name
3 is spelled?
4 A I think how it sounds,
5 S-e-e-b-a-g. Don't quote me. I mean, I
6 guess you have to quote me, but I can go
7 check, and give it to David maybe later
8 today and he can follow up.
9 MR. LUNTZ: That's fine.
10 You've given your best answer.
11 Q Did he remain with Centers
12 Health after you came in as regional
13 administrator?
14 A Only for a very brief time,
15 before I took over.
16 Q And as part of your duties as
17 regional administrator, did you visit the
18 facilities at all?
19 A Yes, I did.
20 Q And you were still working
21 out -- your office, if you will, was
22 still out of the White Plains Road,
23 Bronx, address, correct?
24 A Yes.
25 Q And how frequently did you
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2 visit skilled nursing -- let's hone in on
3 Buffalo, specifically, because it may
4 have varied, I assume, at different
5 facilities. But how frequently as
6 regional administrator did you visit
7 Buffalo Center?
8 A So for those two years, or
9 year-and-a-half, because the total number
10 of facilities was 10 and were manageable,
11 I -- my goal was at least once a month,
12 but, like any other time you have a
13 portfolio, there are some facilities that
14 need more attention, and some facilities
15 that need less attention. So sometimes
16 the schedule could have been Buffalo for,
17 you know, two consecutive weeks and then
18 not for another month because other
19 facilities needed more attention. But
20 the standard, what I tried to set for a
21 schedule for myself, was monthly to be at
22 each facility at least a full day.
23 Q And, I'm sorry, at the time of
24 the increase, did that increase to the
25 number of 10, or was it 10 additional on
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2 top of the 10?
3 A No, no, it increased to ten.
4 Because Adirondacks was just five, and
5 then by three months later, it was all 10
6 upstate, so the total was 10.
7 Q So on an average, out of a
8 given month, were you on the road
9 visiting those facilities for two weeks
10 out of that month? Is that a fair
11 estimate?
12 A So I'm not -- no. I don't know
13 if we -- Buffalo Center, specifically, I
14 would say a day or two -- minimum, a day,
15 sometimes two, a month. In general, I
16 was on the road Monday through Thursday,
17 and I would be in the office on Friday.
18 Q Okay.
19 A So I was out on the road
20 85 percent of the time of the week.
21 Q So you were on the road four
22 days out of the week; is that correct?
23 A Yes, yes. Obviously, there are
24 weeks that I spent the whole week in the
25 office, if we had a project to work on or
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1 A. Lantzitsky
2 I needed -- whatever, there was a
3 specific thing that I needed to address
4 in the city. But in general, that was
5 how my schedule was.
6 Q Once it increased to 10, did it
7 stay at the number, 10 facilities,
8 throughout your time as regional
9 administrator?
10 A Yes.
11 Q And, I'm sorry, I may have
12 asked this: Did you go directly from the
13 position of regional administrator to the
14 position of division president?
15 A Yes.
16 Q And as division president, what
17 were your general responsibilities?
18 A So pretty much the same, but
19 increased buildings and increased support
20 beneath me. So as centers -- as we
21 acquired more facilities or more
22 facilities in our portfolio, I couldn't
23 divide my time and be as effective, so I
24 hired regional administrators to
25 basically take over the job that I was
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1 A. Lantzitsky
2 doing. And I managed them. So it's the
3 same idea, but a larger scale, just
4 making sure that the buildings
5 operationally are regulatory compliant
6 and are financially stable and that we
7 are doing customer service and that
8 everything that we are looking for the
9 building to perform are actually being
10 done.
11 Q So as division president, are
12 you still responsible for that same
13 geographic area?
14 A Correct. And plus, I added --
15 or we added two more areas.
16 Q What areas were those,
17 generally?
18 A Rhode Island and Kansas.
19 Q So Rhode Island and Kansas also
20 fall under your administration, if you
21 will, as division president?
22 A Yes. Administration is -- you
23 don't want to use that term in nursing
24 homes because that's actually, you know,
25 full responsibility on the ground as a
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1 A. Lantzitsky
2 licensed administrator, but
3 operationally, yes, I am responsible for.
4 Q Are there any other division
5 presidents at this time for Centers
6 Health?
7 A No.
8 Q So you became a division
9 president and remained the sole division
10 president at Centers Health, if you will?
11 A Yes.
12 Q And how many facilities,
13 currently, are you responsible for as
14 division president?
15 A Total number is around, I
16 think, 25.
17 Q And how many of those are in
18 Kansas?
19 A Only two.
20 Q And how many in Rhode Island?
21 A Only three.
22 Q And, again, kind of the same
23 question as regional administrator, they
24 have no division president for any of the
25 Downstate facilities --
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2 A No.
3 Q -- and to your knowledge, is
4 that based upon the same logic as when
5 you were regional
Preview
FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 1 1 2 - - - - - - - - - - - - - - - - - - - -x 3 In the Matter of the Investigation of 4 Buffalo Center for Rehabilitation and 5 Nursing, 6 Examination Under Oath Pursuant 7 to Executive Law 63(12): 8 AHARON LANTZITSKY 9 - - - - - - - - - - - - - - - - - - - -x May 4, 2022 10 10:00 a.m. 11 12 13 EXAMINATION UNDER OATH of 14 AHARON LANTZITSKY, held virtually via 15 Webex, taken before Jamie Ann Stanton, a 16 Registered Professional Reporter and 17 Notary Public of the State of New York, 18 pursuant to Executive Law 3(12). 19 20 21 22 23 24 25 Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 2 1 2 APPEARANCES: 3 NEW YORK STATE OFFICE 4 OF THE ATTORNEY GENERAL 1 Blue Hill Plaza, #1037 5 Pearl River, New York 10965 6 BY: WILLIAM McCLARNON, ESQ. HILLARY CHAPMAN, ESQ. 7 SIOBHAN O'LEARY, ESQ. TODD PETTIGREW, ESQ. 8 9 HINMAN STRAUB, P.C. 10 121 State Street Albany, New York 12207 11 Attorneys for witness 12 BY: DAVID LUNTZ, ESQ. 13 14 * * * 15 16 17 18 19 20 21 22 23 24 25 Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 3 1 2 A H A R O N L A N T Z I T S K Y , the 3 witness herein, having first been duly 4 sworn by the Notary Public, was examined 5 and testified as follows: 6 EXAMINATION BY 7 MR. McCLARNON: 8 Q Good morning, we are now on the 9 record. Today is May 4, 2022, at 10 approximately 10:10 a.m. 11 If you could just state your 12 name, Mr. Lantzitsky and spell it for the 13 record, please. 14 A It's Aharon Lantzitsky. 15 A-h-a-r-o-n, Lantzitsky is Lantzitsky. 16 Q And what is your work address, 17 sir? 18 A 4770 White Plains Road, Bronx, 19 New York, 10470. 20 Q Thank you. 21 My name's William McClarnon. I 22 am an Assistant Attorney General in the 23 Office of the Attorney General of the 24 State of New York. We are conducting 25 this examination remotely in order to Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 4 1 2 ensure the health and safety of all 3 participants and due Corona virus-related 4 concerns. The examination will be 5 recorded by stenographic means by a court 6 reporter certified to record the 7 deposition in the State of New York. And 8 all deposition exhibits will be presented 9 electronically. 10 Joining us this morning from 11 our office is Assistant Attorney General 12 Hillary Chapman, Assistant Attorney 13 General Todd Pettigrew, and 14 auditor/investigator, Siobhan O'Leary. 15 Before we proceed, other than 16 devices for the purposes of this 17 interview, please turn off all mobile 18 phones, laptops, tablets and other 19 electronic devices, and I will do the 20 same. 21 A Okay. It's off. 22 Q This examination is being 23 conducted by the Attorney General of the 24 State of New York pursuant to Executive 25 Law 63(12) and other statutes and Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 5 1 A. Lantzitsky 2 regulations. Before we start your 3 testimony, I am going to mention a few 4 ground rules, Mr. Lantzitsky. You have 5 the right to consult with an attorney, 6 although you do not have the right to 7 have an attorney with you in this 8 examination, the Attorney General will 9 permit you to have your attorney present 10 during your testimony today. 11 A Thank you. 12 Q Anything you say in this 13 examination may be used in a legal 14 proceeding. You have the right to refuse 15 to answer any question if a truthful 16 answer to the question would tend to 17 incriminate you. Any willful 18 misstatement by you may constitute 19 perjury, and I emphasize a willful 20 misstatement. 21 Finally, this investigation 22 is confidential. We request that you not 23 discuss this matter, your testimony here 24 today, and any documents you may have 25 reviewed or produced or may produce in Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 6 1 A. Lantzitsky 2 connection with today's testimony with 3 anyone other than your attorneys. 4 A few other instructions before 5 we proceed. In order for the court 6 reporter to create a clear record, please 7 answer all questions verbally because the 8 reporter cannot record a nonverbal 9 gesture such as a nodding of the head. 10 Please let me finish each question before 11 you begin your answer, and I will allow 12 you to finish your answer before asking 13 my next question. 14 If you need to take a break at 15 any time, just let me know. If there's a 16 question pending, I will ask that you 17 answer it before we break. If you do not 18 hear a question, please let me know and I 19 will repeat it. If you do not understand 20 a question, please let me know, and I 21 will either repeat it or rephrase it if 22 appropriate. If you answer a question, I 23 and anyone reading this transcript will 24 assume you understood the question. 25 And do you understand that, Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 7 1 A. Lantzitsky 2 sir? 3 A Yes. 4 Q Fine. And just check, you can 5 hear me clearly; is that correct? 6 A I do, yes. 7 Q Thank you. 8 Sometimes you may give an 9 answer as completely as you can and then 10 later you remember additional 11 information. If that happens to you, 12 please tell me that you would like to add 13 something to an earlier answer, and we 14 will do that right then, while it's on 15 your mind. 16 Do you understand that, sir? 17 A Yes. 18 Q In addition, it might occur to 19 you at some point that a previous answer 20 you gave was not completely accurate. If 21 that happens, please let me know, and you 22 may make any necessary corrections to 23 your answers at that time. 24 Do you understand that? 25 A Yes. Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 8 1 A. Lantzitsky 2 Q Have you consumed any alcohol 3 or taken any drugs or medications prior 4 to testifying today or have any condition 5 that could prevent you from giving full, 6 complete and truthful answers to my 7 questions today? 8 A No. 9 Q Is there any other reason why 10 you could not provide your best and most 11 accurate testimony today? 12 A Not -- I can't think of 13 anything, so the answer would be no. 14 Q Thank you. 15 And you are represented by 16 Counsel, Mr. Luntz, correct? 17 A Correct. 18 MR. McCLARNON: Mr. Luntz, if 19 you would just note your appearance 20 for the record, please? 21 MR. LUNTZ: Sure. David 22 Luntz, Hinman Straub, 121 State 23 Street, Albany, New York. 24 MR. McCLARNON: Thank you. 25 Q Your counsel and I have certain Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 9 1 A. Lantzitsky 2 stipulations. I believe that Mr. Luntz 3 will agree to these. These are 4 stipulations we previously entered into. 5 We've agreed to stipulate that, 6 Mr. Lantzitsky, you are present in New 7 York State, at this time. 8 A Correct. 9 Q We've agreed that unless on a 10 break, Mr. Lantzitsky, you and your 11 counsel will not communicate with each 12 other other than on the record. 13 We've agreed that such 14 communication includes deliberate visual 15 cues or communications by any electronic 16 communications. We also ask that other 17 than counsel, no one else be present 18 while you testify in the office space 19 that you are currently in. And I don't 20 see anyone. 21 Can I assume, Mr. Lantzitsky, 22 that there is no one else in the room 23 other than Mr. Luntz? 24 A There is no one else. 25 Q And I would ask that if someone Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 10 1 A. Lantzitsky 2 comes into the room, that you immediately 3 inform us of that so that we can identify 4 that person and hold the questions until 5 that person has left the room. 6 A Sure. 7 Q We've agreed that neither side 8 will record these proceedings or any 9 portion thereof. 10 A Other than the sten record? 11 MR. LUNTZ: These are things 12 we've agreed to. They're not 13 recording the video and we're not 14 recording the video. 15 THE WITNESS: Right, okay. 16 Q And Mr. Lantzitsky, will you 17 waive the requirement that you be present 18 with the reporter while giving testimony 19 here today? 20 A Yes. 21 MR. McCLARNON: And 22 Mr. Luntz, will you also waive any 23 challenge to these proceedings based 24 on the fact that your client and the 25 reporter are not physically together? Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 11 1 A. Lantzitsky 2 MR. LUNTZ: Correct. 3 MR. McCLARNON: Thank you. 4 Q Do you have any questions, 5 Mr. Lantzitsky, before we proceed? 6 A No. 7 Q Throughout the course of these 8 proceedings, Buffalo Center For 9 Rehabilitation and Nursing Care will be 10 referred to as "Buffalo Center," and 11 Centers Healthcare, I will refer to as 12 "Centers Health." 13 Have you ever gone by any other 14 names, other than Aharon Lantzitsky? 15 A No. 16 Q Okay. 17 A I have a middle name, so -- but 18 not -- it's rarely used. 19 Q Okay. And what is your date of 20 birth, sir? 21 A . 22 Q Do you hold any professional 23 licenses? 24 A Nursing home administrator. 25 Q And when were you licensed? Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 12 1 A. Lantzitsky 2 A Initially, two thousand and -- 3 I think December 2012, in Massachusetts. 4 And then, in New York, the exact date, I 5 think it was sometime in June -- June or 6 July 2016. 7 Q Okay. 8 A I don't -- yeah, I don't 9 remember the exact date. 10 Q Okay, very good, thank you. 11 And who is your current 12 employer? 13 A Centers Healthcare. 14 Q And what is your job title or 15 position? 16 A Division president. 17 Q And how long have you been a 18 division president with Centers Health? 19 A From the time -- around 2018, 20 some point in 2018. 21 Q And when were you first 22 employed by Centers Health? 23 A I think it was April 21st, 24 2016. 25 Q Prior to becoming division Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 13 1 A. Lantzitsky 2 president, what other positions have you 3 held with Centers Health? 4 A Regional administrator. 5 Q And so you were first hired as 6 regional administrator? 7 A Yes. 8 Q Other than employment at 9 Centers Health, have you ever worked in 10 the nursing home field? 11 A Yes. In Massachusetts, I 12 worked as an administrator, and then a 13 regional director of operations, which is 14 similar to the title that is similar to a 15 regional administrator, same idea. 16 Q And who did you work with in 17 those capacities? 18 A A company called Marquis Health 19 Services. 20 Q And so Marquis Health Services, 21 did they operate skilled nursing 22 facilities? 23 A Yes, in Massachusetts. 24 Q And specifically, in your 25 position, you said you were an Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 14 1 A. Lantzitsky 2 administrator. You were the 3 administrator of a single skilled nursing 4 facility? 5 A Yes. 6 Q And what facility was that? 7 A So I started out -- well, 8 actually, I started out an assistant 9 administrator in a facility in Rockland, 10 Massachusetts, called Coyne Healthcare. 11 That no longer exists. It is now 12 Rockland -- no, now it's Webster Park. 13 They changed the name. And then I 14 started out, my first job, in Needham, 15 Massachusetts, in a facility called 16 Briarwood Healthcare. And then I 17 transitioned from there, within the same 18 company, to a place in Saugus, 19 Massachusetts, called Chestnut Park. 20 Q And those were all as position 21 of administrator or assistant 22 administrator? 23 A Yes. 24 Q And then you said you became a 25 similar -- for lack of a better term -- a Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 15 1 A. Lantzitsky 2 regional administrator. 3 What areas did you cover in 4 that position? 5 A So mostly central Massachusetts 6 and a little bit west. 7 Q And approximately, were you the 8 regional administrator of a number of 9 skilled nursing facilities? 10 A Yes. 11 Q Do you know how many skilled 12 nursing facilities were under your 13 auspices? 14 A Four, four. 15 Q Okay. And how were you first 16 hired by Marquis Health Services? 17 A Wow, that's going back. So I 18 happened to be friends with the owner 19 of -- I was friends of a friend of the 20 owner of the company who introduced us 21 and we -- I spoke with him, then we had 22 an interview, and he sold me on 23 healthcare and here I am. 24 Q At the time that you -- I can't 25 remember the date, so at the time that Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 16 1 A. Lantzitsky 2 you first hired on with Marquis Health 3 Services, were you either a licensed 4 administrator, or were you working on 5 your licensing at that point in time? 6 A So when I started, I had not. 7 I started assistant administrator to 8 see -- to see the field, see if I could 9 and wanted to be involved in the field. 10 And as I worked through that, I saw I 11 enjoyed it, I had -- it was something 12 that worked for me, and I was able to do 13 it. So then I pursued my license as an 14 assistant administrator working for them. 15 Q And there came a point in time, 16 obviously, when you left Marquis Health 17 Services. 18 Why did you leave? 19 A I moved to New York. That was 20 for family -- I am originally from 21 Rockland County, in New York. So -- and 22 I was out for seventeen years and then I 23 moved back and I was traveling to 24 Massachusetts and then it just -- it made 25 more sense to stay -- to stay -- to work Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 17 1 A. Lantzitsky 2 in New York. 3 Q Between Marquis Health Services 4 and Centers Health, did you have any 5 other positions or jobs in between those 6 two? 7 A Between the two, no. 8 Q And how did you come to work 9 for Centers Health? 10 A So I have a relative that was 11 working in -- in Centers, in the business 12 office. And he -- and, you know, we were 13 related, so we met at various functions 14 and times, and he was pushing me to meet 15 with some of the ownership group. He 16 felt that -- he knows me, I know him, and 17 he felt that it was a -- a good marriage 18 per se. And so I finally -- I finally 19 agreed and I met with him and actually, 20 he was correct, it's actually a very 21 good -- a great group to work for. 22 Q And who is this relative? What 23 position was he? 24 A So he was the business office, 25 at the time, I think he was working in Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 18 1 A. Lantzitsky 2 the budgeting department. 3 Q Okay. 4 A He is no longer there. He 5 moved on. He got a great position in a 6 different -- totally different company, 7 not a nursing home, and then so... 8 Q And who, regarding the position 9 that you first started with at Centers 10 Health, who interviewed you for that 11 position? 12 A So I interviewed initially with 13 Mr. Izzy Wolf and Amir Abramchik and the 14 second level, with Kenny Rozenberg, 15 Abramchik and Izzy Wolf. 16 Q Prior to your involvement 17 either through the hiring process with 18 Centers Health, were you involved with 19 any of those gentlemen? 20 A No. 21 Q Again, at your first position 22 at Centers Health, was what? 23 A Regional administrator. 24 Q And what did that entail? 25 A So I oversaw the upstate -- so Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 19 1 A. Lantzitsky 2 their upstate was split into regions, I 3 oversaw the Adirondack portion of the 4 Upstate New York portfolio. 5 Q Was that a number of skilled 6 nursing facilities? 7 A Yes, yes, similar to 8 Massachusetts. It was five nursing 9 facilities. 10 Q Anything other than skilled 11 nursing facilities, any other entities, 12 or just skilled nursing facilities? 13 A At the time it was only skilled 14 nursing facilities. 15 Q Do you know approximately how 16 many there were in your region at that 17 time? 18 A When I started, there was five. 19 And then 10. 20 Q And what five facilities were 21 those? 22 A So those were Warren Center, 23 Washington Center, what's now Granville 24 Center, it was Indian River at the time, 25 Essex Center and Fulton Center. Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 20 1 A. Lantzitsky 2 Q And how long did you hold that 3 position? 4 A So those five -- 5 Q Strike that. Let me clarify. 6 For how long were you regional 7 administrator for those five facilities? 8 A So let me -- if I can, I just? 9 Q Certainly. 10 A So after six months, it grew to 11 10. So those five plus another 10, which 12 was our upstate portfolio for -- for a 13 while. And so that lasted until 2018. 14 Q Is there a geographic region, 15 you called it, I think, the Adirondack 16 division, if you will, is there a 17 geographic region that you can describe 18 that you were responsible for, or was it 19 spread out more than typical geographic 20 region, if you will? 21 A So after the first six months, 22 it was pretty much upstate from -- we 23 didn't have anything below Warren County, 24 so it was pretty much from Warren County 25 up through Essex County then it crossed Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 21 1 A. Lantzitsky 2 the upstate. So at the time we had 3 nothing in the central region. And then 4 we -- our first building was in the 5 western part of the state. So we had it 6 in Ontario county, and then in Eerie 7 county. 8 Q And so at that point in time, 9 was Buffalo Center one of those 10 facilities that you were responsible for 11 as a regional administrator? 12 A Yes. After the first six 13 months, after the initial six months, 14 yes. 15 Q When did you move on from being 16 a regional administrator into division 17 president? Was that the step, from 18 regional administrator to division 19 president? 20 A Yes. Yes. 21 Q So when did that occur? 22 A Around 2018. I don't have the 23 exact date because it was just a 24 transition, so I don't remember the exact 25 point that we did that, but -- let's just Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 22 1 A. Lantzitsky 2 say, I mean, for argument sake, I can try 3 to go back and get the exact date, but I 4 think -- 5 Q Approximate will do. 6 A January 1st, 2018, makes sense. 7 Q Beginning of 2018 sometime? 8 A I think so, yeah. 9 Q And as regional administrator, 10 what were your general responsibilities? 11 A So -- to make sure, to ensure 12 that operationally, the building is 13 running and the building is regulatory 14 compliant and financially it's stable. 15 Q How many regional 16 administrators were there at that time 17 for Centers Health? 18 A So it was just me. 19 Q Did they have facilities that 20 did not fall within your area? 21 A Yes, they did. 22 Q But they did not have regional 23 administrator for those facilities? 24 A No. 25 Q Can you explain why they had a Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 23 1 A. Lantzitsky 2 regional administrator for those upstate, 3 if you will, lack of a better term, 4 facilities, but none for Downstate at 5 that time? 6 A There was no hard and fast rule 7 as to why we did it that way. The 8 thinking was that the facilities closer 9 to the city are in and around the 10 corporate office and easier to just 11 communicate and manage as opposed to the 12 upstate facilities which were a minimal 13 of three hours away, and, obviously, 14 Buffalo, a little father away, so we 15 wanted to make sure that we had a 16 presence in the facilities supporting 17 them. And that's why that position was 18 created. 19 Q Was there a regional 20 administrator before you joined Centers 21 Health, to your knowledge? 22 A There was. 23 Q Do you know who that was? 24 A The name was Gabe, I believe, 25 Seebag, I think it's Seebag. Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 24 1 A. Lantzitsky 2 Q Do you know how that last name 3 is spelled? 4 A I think how it sounds, 5 S-e-e-b-a-g. Don't quote me. I mean, I 6 guess you have to quote me, but I can go 7 check, and give it to David maybe later 8 today and he can follow up. 9 MR. LUNTZ: That's fine. 10 You've given your best answer. 11 Q Did he remain with Centers 12 Health after you came in as regional 13 administrator? 14 A Only for a very brief time, 15 before I took over. 16 Q And as part of your duties as 17 regional administrator, did you visit the 18 facilities at all? 19 A Yes, I did. 20 Q And you were still working 21 out -- your office, if you will, was 22 still out of the White Plains Road, 23 Bronx, address, correct? 24 A Yes. 25 Q And how frequently did you Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 25 1 A. Lantzitsky 2 visit skilled nursing -- let's hone in on 3 Buffalo, specifically, because it may 4 have varied, I assume, at different 5 facilities. But how frequently as 6 regional administrator did you visit 7 Buffalo Center? 8 A So for those two years, or 9 year-and-a-half, because the total number 10 of facilities was 10 and were manageable, 11 I -- my goal was at least once a month, 12 but, like any other time you have a 13 portfolio, there are some facilities that 14 need more attention, and some facilities 15 that need less attention. So sometimes 16 the schedule could have been Buffalo for, 17 you know, two consecutive weeks and then 18 not for another month because other 19 facilities needed more attention. But 20 the standard, what I tried to set for a 21 schedule for myself, was monthly to be at 22 each facility at least a full day. 23 Q And, I'm sorry, at the time of 24 the increase, did that increase to the 25 number of 10, or was it 10 additional on Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 26 1 A. Lantzitsky 2 top of the 10? 3 A No, no, it increased to ten. 4 Because Adirondacks was just five, and 5 then by three months later, it was all 10 6 upstate, so the total was 10. 7 Q So on an average, out of a 8 given month, were you on the road 9 visiting those facilities for two weeks 10 out of that month? Is that a fair 11 estimate? 12 A So I'm not -- no. I don't know 13 if we -- Buffalo Center, specifically, I 14 would say a day or two -- minimum, a day, 15 sometimes two, a month. In general, I 16 was on the road Monday through Thursday, 17 and I would be in the office on Friday. 18 Q Okay. 19 A So I was out on the road 20 85 percent of the time of the week. 21 Q So you were on the road four 22 days out of the week; is that correct? 23 A Yes, yes. Obviously, there are 24 weeks that I spent the whole week in the 25 office, if we had a project to work on or Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 27 1 A. Lantzitsky 2 I needed -- whatever, there was a 3 specific thing that I needed to address 4 in the city. But in general, that was 5 how my schedule was. 6 Q Once it increased to 10, did it 7 stay at the number, 10 facilities, 8 throughout your time as regional 9 administrator? 10 A Yes. 11 Q And, I'm sorry, I may have 12 asked this: Did you go directly from the 13 position of regional administrator to the 14 position of division president? 15 A Yes. 16 Q And as division president, what 17 were your general responsibilities? 18 A So pretty much the same, but 19 increased buildings and increased support 20 beneath me. So as centers -- as we 21 acquired more facilities or more 22 facilities in our portfolio, I couldn't 23 divide my time and be as effective, so I 24 hired regional administrators to 25 basically take over the job that I was Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 28 1 A. Lantzitsky 2 doing. And I managed them. So it's the 3 same idea, but a larger scale, just 4 making sure that the buildings 5 operationally are regulatory compliant 6 and are financially stable and that we 7 are doing customer service and that 8 everything that we are looking for the 9 building to perform are actually being 10 done. 11 Q So as division president, are 12 you still responsible for that same 13 geographic area? 14 A Correct. And plus, I added -- 15 or we added two more areas. 16 Q What areas were those, 17 generally? 18 A Rhode Island and Kansas. 19 Q So Rhode Island and Kansas also 20 fall under your administration, if you 21 will, as division president? 22 A Yes. Administration is -- you 23 don't want to use that term in nursing 24 homes because that's actually, you know, 25 full responsibility on the ground as a Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 29 1 A. Lantzitsky 2 licensed administrator, but 3 operationally, yes, I am responsible for. 4 Q Are there any other division 5 presidents at this time for Centers 6 Health? 7 A No. 8 Q So you became a division 9 president and remained the sole division 10 president at Centers Health, if you will? 11 A Yes. 12 Q And how many facilities, 13 currently, are you responsible for as 14 division president? 15 A Total number is around, I 16 think, 25. 17 Q And how many of those are in 18 Kansas? 19 A Only two. 20 Q And how many in Rhode Island? 21 A Only three. 22 Q And, again, kind of the same 23 question as regional administrator, they 24 have no division president for any of the 25 Downstate facilities -- Veritext Legal Solutions 212-267-6868 516-608-2400 FILED: NEW YORK COUNTY CLERK 06/28/2023 10:42 AM INDEX NO. 451549/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 06/28/2023 Page 30 1 A. Lantzitsky 2 A No. 3 Q -- and to your knowledge, is 4 that based upon the same logic as when 5 you were regional