On June 28, 2023 a
Exhibit,Appendix
was filed
involving a dispute between
People Of The State Of New York, By Letitia James, Attorney General Of The State Of New York,
and
Abraham Operations Associates Llc Dba Beth Abraham Center For Rehabilitation And Nursing,
Aharon Lantzitsky,
Amir Abramchik,
Aron Gittleson,
Beth Rozenberg,
Bis Funding Capital Llc,
Centers For Care Llc Dba Centers Health Care,
Cfsc Downstate Llc,
Daryl Hagler,
David Greenberg,
Delaware Operations Associates Llc Dba Buffalo Center For Rehabilitation And Nursing,
Delaware Real Property Associates Llc,
Elliot Kahan,
Hollis Operating Co Llc Dba Holliswood Center For Rehabilitation And Healthcare,
Hollis Real Estate Co Llc,
Jeffrey Sicklick,
Jonathan Hagler,
Kenneth Rozenberg,
Leo Lerner,
Light Property Holdings Ii Associates Llc,
Mordechai Moti Hellman,
Reuven Kaufman,
Schnur Operations Associates Llc Dba Martine Center For Rehabilitation And Nursing,
Skilled Staffing Llc,
Sol Blumenfeld,
for Commercial - Other - Commercial Division
in the District Court of New York County.
Preview
iD: YORK OUN PK 06 DM INDEX NO. 451549/2023
NYSCEF BOC. NO. 505 RECEIVED NYSCEF: 06/28/2023
PETTIGREW EXHIBIT 70
INDEX NO. 451549/2023
NYSCEF DOC. NO. 505 RECEIVED NYSCEF: 06/28/2023
To: Nora Ruth Eusebio[neusebio@Martinecenter.net]
Cc: Gemma Moore[gmoore@centershealthcare.org]
From: Heidi Hendrix
Sent: Tue 03/24/2020 5:43:33 PM UTC
Subject: RE: Daily summary by 3 pm RE: Suspected or Confirmed Covid 19 cases loday please send by 5 pm if possible
(Heidi has to send Kenny/Amir daily) - VERY IMPORTANT
Received: Tue 03/24/2020 0 PM UTC
Have you email Joel about your supplies? Thanks!
From: Nora Ruth Eusebio
Sent: Tuesday, March 24, 2020 1:41 PM
To: Heidi Hendrix
Cc: Gemma Moore
Subject: FW: Daily summary by 3 pm RE: Suspected or Confirmed Covid 19 cases .... .. today please send by 5 pm if possible
(Heidi has to send Kenny/Amir daily, ERY IMPORTANT
03/24/20
* # Suspected Cases: 03
* Pertinent Details: All labs, 2 chest x-rays were negative and 1 admission from Westchester Medical Center with fever
101.3, cough and wheezing is positive for Pneumonia and small Pleural Effusion, started on Levaquin x 7 days, Legionella
urine specimen sent ), all 2 residents are stable, cough subsiding, no new cases
. # Confirmed Cases: 0
. # Employee suspected Cases: 2
. # Employee confirmed Cases: 1
. Any significant staffing issues: short of nurses and CNAS (many nurses are resigning and have changed FT status to Per
Diem)
« Any issues with supplies: we need dedicated 3 BP machines, 3 pulse oximeters, 3 thermometers & 1 dozen stethoscopes
for 3 residents on precautions. We need purple and blue top sanitizers (12 each).
* Miscellaneous/Other: Accuracy of thermometer(s) at the front door used by screener
Nora Ruth Eusebio
Director of Nursing
Martine Center
12 Tibbits Avenue
White Plains, NY 10606
T 914 287 7200 ext 257
F 718 581 5119
www.martinecenter,net
GY MARTINE
CENTER
MARTINE_SUPPO01696
INDEX NO. 451549/2023
NYSCEF DOC. NO. 505 RECEIVED NYSCEF: 06/28/2023
Neusebio@Martinecenter
net
From: Nora Ruth Eusebio
Sent: Monday, March 23, 2020 4:22 PM
To: Heidi Hendrix
Cc: Gemma Moore ; ME \Viartinecenter.net>; Shragi Weisz
Subject: FW: Daily summary by 3 pm RE: Suspected or Confirmed Covid 19 cases .. today please send by 5 pm if possible
(Heidi has to send Kenny/Amir daily) --- ~---VERY IMPORTANT
03/23/20 Martine Center
* # Suspected Cases: 03
* Pertinent Details: All labs, chest x-rays were negative, all 3 residents are stable, cough subsiding, no new cases
* # Confirmed Cases: 0
« # Employee suspected Cases: 2
* # Employee confirmed Casi =
« Any significant staffing issues: short of nurses and CNAS (many nurses are resigning and have changed FT status to Per
Diem)
* Any issues with supplies: we need dedicated 3 BP machines, 3 pulse oximeters, 3 thermometers & 1 dozen stethoscopes
for 3 residents on precautions. We need purple and blue top sanitizers (12 each).
* Miscellaneous/Other: Accuracy of thermometer(s) at the front door used by screener
* Note: We got 760 facemasks, cases of liquid soap and (10 gallons of hand sanitizers from DOH) today.
We need head covers too for those suspected or Covid-19 positive cases.
Thanks and God bless
From: Nora Ruth Eusebio
Sent: Sunday, March 22, 2020 1:22 PM
To: Heidi Hendrix
Cc: Gemma Moore
Subject: FW: Daily summary by 3 pm RE: Suspected or Confirmed Covid 19 cases ... today please send by 5 pm if possible
(Heidi has to send Kenny/Amir daily) --- -----VERY IMPORTANT
Good afternoon, please below Martine Center responses:
# Suspected Cases: 03
Pertinent Details: All labs, chest x-rays were negative, all 3 residents are stable, cough subsiding, no new cases
# Confirmed Cases: 0
# Employee suspected Cases: 2
# Employee confirmed Cases: 0
Any significant staffing issues: short of nurses and CNAS (many nurses are resigning and have changed FT status to Per
Diem)
¢ Any issues with supplies: running out of face masks
* Miscellaneous/Other: Accuracy of thermometers at the front door used by screener
Thanks and God bless
MARTINE_SUPPOO1697
INDEX NO. 451549/2023
NYSCEF DOC. NO. 505 RECEIVED NYSCEF: 06/28/2023
Nora Ruth Eusebio
Director of Nursing
Martine Center
12 Tibbits Avenue
White Plains, NY 10606
T 914 287 7200 ext 257
F 718 581 5119
www. al rtin: Cr.
GY MARTINE
CENTER
neusebio@Martinecenter.ne
From: Nora Ruth Eusebio
Sent: Friday, March 20, 2020 5:05 PM
To: Heidi Hendrix
Cc: Gemma Moore
Subject: FW: Daily summary by 3 pm RE: Suspected or Confirmed Covid 19 cases ... .. today please send by 5 pm if possible
(Heidi has to send Kenny/Amir daily) ---- anne ---- VERY IMPORTANT
Good evening, please see Martine Center response; thanks and God bless
From: Kathleen Flanagan ; Heidi Hendrix
; Nora Ruth Eusebio
; Ingrid Prince ; Andrew Ungoco
; Rebecca Butler ; Annmarie Ramos ;
Michele Brunner
Cc: Gemma Moore ; Yetunde Fasusi
Subject: Re: Daily summary by 3 pm RE: Suspected or Confirmed Covid 19 cases ..... today please send by 5 pm if possible
(Heidi has to send Kenny/Amir daily) ----- nnene ----VERY IMPORTANT
MARTINE_SUPP001698
INDEX NO. 451549/2023
NYSCEF DOC. NO. 505 RECEIVED NYSCEF: 06/28/2023
© # Suspected Cases: 31
° Pertinent Detai 1 positive admitted and on a vent; another sent
# Confirmed Cases: 1
# Employee suspected Cases: 2
# Employee confirmed Cases:0
Any significant staffing issues: yes- no supervisors; 2 CNAs called out;
. Any issues with supplies: swabs, IV supplies- extension sets
. Miscellaneous/Other: staff is stressed, coming in but I'm very concerned about the weekend- | will come in on Sat and
Sunday
Holliswood
© # Suspected Cases: 22
Pertinent Detai 1 death of a 49 year old, asymptomatic sent to ER for seizure- no respiratory distress
# Confirmed Cases: 1
# Employee suspected Cases: 0
# Employee confirmed Cases: 0
Any significant staffing issues: supervisors calling out, department heads refusing to g to unit, rehab refusing
Any issues with supplies: swabs and IV
Miscellaneous/Other:
Regards-
Kathleen Flanagan RN
Regional Director of Clinical Services
Centers Health Care
4770 White Plains Rd
Bronx, NY, 10470
C 516-375 29)2 ‘99
Kathleen Flanagan RN
Regional Director of Clinical Services
Centers Health Care
4770 White Plains Rd
Bronx, NY, 10470
M 516 375 2299
G
CENTERS
HEALTH
CARE
MARTINE_SUPP001699
=: INDEX NO. 451549/2023
NYSCEF DOC. NO. 505 RECEIVED NYSCEF: 06/28/2023
UP
Mlasagand@centersheatncare.or
From: Nona J. Bluestein
Sent: Friday, March 20, 2020 2:26:03 PM
To: Heidi Hendrix; Nora Ruth Eusebio; Ingrid Prince; Andrew Ungoco; Rebecca Butler; Annmarie Ramos; Michele Brunner; Kathleen
Flanagan
Cc: Gemma Moore; Yetunde Fasusi
Subject: RE: Daily summary by 3 pm RE: Suspected or Confirmed Covid 19 cases ... today please send by 5 pm if possible
(Heidi has to send Kenny/Amir daily) ERY IMPORTANT
w
. # Suspected Cases: 1
* Pertinent Details: asymptomatic resident admitted from Rochester General Hosp at 4:30pm, at 8pm DOH called to report
that he was “suspect.” Testing conducted at facility this am, results pending with no confirmed time frame.
# Confirmed Cases: 0
# Employee suspected Cases: 3 with “symptoms”
# Employee confirmed Cases: 0
Any significant staffing issues: not at this time (Thank goodness!!)
Any issues with supplies: limited, more arriving tomorrow
Miscellaneous/Other: We are CENTERS STRONG!! )
From: Heidi Hendrix
Sent: Friday, March 20, 2020 2:10 PM
To: Nora Ruth Eusebio ; Ingrid Prince ; Nona J. Bluestein
; Andrew Ungoco ; Rebecca Butler
; Annmarie Ramos ; Michele Brunner ;
Kathleen Flanagan
Cc: Gemma Moore ; Yetunde Fasusi
Subject: Daily summary by 3 pm RE: Suspected or Confirmed Covid 19 cases today please send by 5 pm if possible (Heidi
has to send Kenny/Amir daily) ----- ---VERY IMPORTANT
Importance: High
Can you please send me a daily summary --- bullets --- see below, Iineed todays i ossible... during the week Monday —
Friday by 3 pm. If “no cases” — no need to fill in. Thanks!!
(If you are traveling and need to call me — that’s fine!)
MBL
* # Suspected Cases: 3
. Pertinent Details:
. # Confirmed Cases: 0
. # Employee suspected Cases: 8 but 2 tested negative, cough most predominant symptom (they were not at work),
procedure followed
5
MARTINE_SUPPO01700
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* # Employee confirmed Cases: 0, 1 evening C.N.A. also works at another SNF with 11 residents confirmed for Covid-19
cases, 1 dietary aide whose wife is a nurse at the hospital tested positive for Covid-19
© Any significant staffing issues: Staffing issues on Saturday missing 1 nurse (every shift) but Sunday is full staff due to bonus
offered
* Any issues with supplies: the 4 thermometers received from Centers were not working properly, and allocation of PPE
especially the face masks.
¢ isolation bins and PPE containers ran out, we bought the items at Target today (got extra just in case),
* Miscellaneous/Other: challenges with ensuring front door screening especially with thermometer inaccuracy (constant re-
orientation)
ve # Suspected Cases:
. Pertinent Details:
. # Confirmed Cases:
# Employee suspected Cases:
# Employee confirmed Cases:
Any significant staffing issues
Any issues with supplies:
Miscellaneous/Other:
¥
Willa
. # Suspected Cases:
. Pertinent Details:
. # Confirmed Cases:
. # Employee suspected Cases:
. # Employee confirmed Cases:
. Any significant staffing issues:
. Any issues with supplies:
. Miscellaneous/Other:
° # Suspected Cases:
Pertinent Details:
# Confirmed Cases:
# Employee suspected Cases:
# Employee confirmed Cases:
Any significant staffing issues:
Any issues with supplies:
Miscellaneous/Other:
# Suspected Cases:
Pertinent Details:
# Confirmed Cases:
# Employee suspected Cases:
# Employee confirmed Cases:
Any significant staffing issues
Any issues with supplies:
Miscellaneous/Other:
Holliswood
o# Suspected Cases:
Pertinent Details:
MARTINE_SUPPOO1701
=: INDEX NO. 451549/2023
NYSCEF DOC. NO. 505 RECEIVED NYSCEF: 06/28/2023
* # Confirmed Cases:
* # Employee suspected Cases:
. # Employee confirmed Cases:
. Any significant staffing issues:
. Any issues with supplies:
. Miscellaneous/Other:
Heidi Hendrix, RN, BSN
Chief Nursing Officer
Centers Health Care
4770 White Plains Road
Bronx, NY 10470
C (256) 762-4776
T (718) 931-9700
@: he.
G
CENTERS
HEALTH
CARE
wi
Dil toh
MARTINE_SUPPO01702