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
FILED: NEW YORK COUNTY CLERK 07/09/2023 04:48 PM INDEX NO. 451549/2023
NYSCEF DOC. NO. 695 RECEIVED NYSCEF: 07/09/2023
Exhibit B
,,,,=---~~~---- INDEX NO. 451549/2023
FILED: NEW YORK COUNTY CLERK 07/09/2023 04:48 PM
NYSCEF DOC. NO. 695 RECEIVED NYSCEF: 07/09/2023
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- '---:he: count:y as approved by the Department of Health, to practice in
New York_ State without civil or crircinal penalty related to lack of Ece::isure;
• Sections 6512 through 6516, and 6541 of the Education Law arul Part 6C.8 of Title 8 of the NYCRR, to 6e
extent necessa..7 to allow physician assistants licensed and in current good sta."flding in any state in fue l:nited
S-1'ttes to p:actice in New York State without civil or criminal. penalty, related. to lack cf licensure, ar...d to allow
physician assistants or a substantially sircilar title licensed a:id ir: current good standing in any province or
territory of Canada, or any other country as ~;r;iroved by the Departrr~ent of Health to practice in New York
State wif::iout civil or cr.'.minal penalty related to lack ofHcensure;
• See'.ions 3502 and 3505 of the Public Health Law andPa:t 89 of Title 10 of the NYCRR to 6e extent
necessary to permit radiologic technologists licensed and i.11. cu."'Tent good standing in any state in the United
State :c practice in New York State without civil or crb:ninal penalty related to lack of licen.'.>-.::re:
• Sections 8502, 8504, 8504-a, 8505, and 8507 of the EducaJion Law and Subpart 79-4 ofTitle 8 of fae
NYCRR. to the extent necessary to at:ow respiratory therapistS licensed and in current good st.P.ru:ing in any
state in the United States to practice in New York State 'Without civil or cri.min2.1 penalty refa:ed to lack of
licensure;
• Sections 6512 faro ugh 6516 and 85, 0 of the Education Law and 8 NYCRR Subpart 79-4 to the extent
necessary to allow respiratory therapy te"ch::ricians licensed and in current geed standing in any state ir~ the
United States to practice fa New York State v,dtb.ottt civil or criminal penalty related to lack of ~icensure;
• Section 6502 of the Educatio:;i Law and S ~YCRR 59.8, to the extent necessary to aliowphysician's
asslstants, registered professional nurses~ licensed practical nt:rSes:, ar...ci nurse practitioners licer.sed and ix:,
current gooC. standing in New York State bu!notregistered in New York State to practice in New York State
wifuout cb,'il or cf.minal penalty related to lack of registration, ai:.d to allow specialist ass:stants, respinttory
therapists, respL"'atory therapist tech.."Ucians, phan:1acists, clinical nurse specialists, dentists, derr:.al hygienls~,
registered dental assistants, midVfives, perfusicnists, clir.!cal laboratory technologists, cytotechnologists,
certified clinical laboratory technicians. certified histological tecl::.rlcians., licensed clinical socia: workers,
lice.c.sed master social workers, podiatrists, physical therapists~ physical therapist assistants. mental health
counselors, marriage·and family therapists, creative arrs therapists, psychoa..""lalysts and -psychologists who
have an unencumbeTed license and are zurrently in good standi..'lg in New York State but not registered in
New York State to practice in New Ycrk State \Vithout civii'or crimil:al penalty :elated to lack of regis::ration;
• Sections 6951, 6952, 6953 a.ad 6955 of the Education Law, to the extent t.ecessary to allow :midwives
licensed and in current good standing in any state in the United States, or in any province or territory of
Canada, o: any other country as approved by the Department of Health to practice in Kew York State withom
civil or criminal penalty related to lack of licenS'.L."'e;
• Section 3507 of tl:.e Public Health Law and Part 89 of Title JO of the NYC!Ul to the exte.~: necessery to
perinit radiologic technolcgists licensed and in c'Ctl."ent good standing i::l New York State but not registered in
Kew York State to pr2;ctice in New York State ·•,:vithout civil or crii±rinal penalty related to ~ack of registration;
• Secticns 6512 LCL"CUgh 6516, 6548 and 6911 of the Education Law and sections 60.11 and 64.8 Title 8 of the
NYCRR, to the extent necessary to allow clicical nurse specialis+.s, specialist assistants, and sa.bstantia]y
similar titles certified a:id in current good -st.anding in .any state in the United States, 0:: any province or
terri:'.:ory of Canadfii or any other country as approved by the' Department ofHealU :a practice :n New York
State without civil or criminal penalty related to lack of certification;.
• Sections 6512 through 6516, and 7704 of the Education Law and Part 74 of Title 8 of1he NYCRR, to tl:.e
extent necessary to allow licensed master social worker&r licensed cli,,,ical social vrorkers, and substantially
similar titles licensed at:d in current good standing i:i any state in the United States, or :n any province or.
territory of Canada. or any other country as approved by the Departmerr. of Health to practice in New York
St.ate without civil or cdminal penalty related to lack oflicensure;
• Section 6908 of the Education Law and associated regulations., to the eX:eut necessary to Permit graduates of
State Edt:.cation Department registered. licensure quaiifying nurse p:::actitioner education programs to be
employed to practice nursing in a hospital or .::rursll'.g home for 180 days irr.mediately following successful
FILED: NEW YORK COUNTY CLERK 07/09/2023 04:48 PM INDEX NO. 451549/2023
NYSCEF DOC. NO. 695 RECEIVED NYSCEF: 07/09/2023
completion of a New York State Registered licensure qualifying education prograr::i, provided tbtt the
graduate fi}es v.ith the State Educa:tion Depa.'1Ir.ent an application fo~ certification as a nurse practitioner;
• Section 8609 of the Education Law a."l.d associated regulations, tc the extent necessary to penrit g:-aduates of
State Educwio:i Depart::nent registered, licen.sure c;,uaEfying clinical laboratory tech:mlogy and cli,."llcal
laboratory technician education programs to be emplc-yed to pract:ce for 180 days itr,.r,J.ediate1y foE01,ving
· succes.-."'TI.11 completion of a New York State Reg:S.ered iicens;1te qualifying education pro gr~ in a clirictl
laboratory v.ith a valid New Yor:< S,:ate peroit, provided that the g::aduate f
Preview
FILED: NEW YORK COUNTY CLERK 07/09/2023 04:48 PM INDEX NO. 451549/2023 NYSCEF DOC. NO. 695 RECEIVED NYSCEF: 07/09/2023 Exhibit B ,,,,=---~~~---- INDEX NO. 451549/2023 FILED: NEW YORK COUNTY CLERK 07/09/2023 04:48 PM NYSCEF DOC. NO. 695 RECEIVED NYSCEF: 07/09/2023 • . � \1 - d.t� �-"'� �� �v�1 ��)))):::--_ � - ��u�����!it0 ,��� i;�CZ) ,~a c..- � �� ,� ����) ,:;� �- �� --- -- ,,,.-. ._____� -- ---------�- •=------------__..,...;:-- :::.::::::::.--- �'.....::::::::, &����J,� - '---:he: count:y as approved by the Department of Health, to practice in New York_ State without civil or crircinal penalty related to lack of Ece::isure; • Sections 6512 through 6516, and 6541 of the Education Law arul Part 6C.8 of Title 8 of the NYCRR, to 6e extent necessa..7 to allow physician assistants licensed and in current good sta."flding in any state in fue l:nited S-1'ttes to p:actice in New York State without civil or criminal. penalty, related. to lack cf licensure, ar...d to allow physician assistants or a substantially sircilar title licensed a:id ir: current good standing in any province or territory of Canada, or any other country as ~;r;iroved by the Departrr~ent of Health to practice in New York State wif::iout civil or cr.'.minal penalty related to lack ofHcensure; • See'.ions 3502 and 3505 of the Public Health Law andPa:t 89 of Title 10 of the NYCRR to 6e extent necessary to permit radiologic technologists licensed and i.11. cu."'Tent good standing in any state in the United State :c practice in New York State without civil or crb:ninal penalty related to lack of licen.'.>-.::re: • Sections 8502, 8504, 8504-a, 8505, and 8507 of the EducaJion Law and Subpart 79-4 ofTitle 8 of fae NYCRR. to the extent necessary to at:ow respiratory therapistS licensed and in current good st.P.ru:ing in any state in the United States to practice in New York State 'Without civil or cri.min2.1 penalty refa:ed to lack of licensure; • Sections 6512 faro ugh 6516 and 85, 0 of the Education Law and 8 NYCRR Subpart 79-4 to the extent necessary to allow respiratory therapy te"ch::ricians licensed and in current geed standing in any state ir~ the United States to practice fa New York State v,dtb.ottt civil or criminal penalty related to lack of ~icensure; • Section 6502 of the Educatio:;i Law and S ~YCRR 59.8, to the extent necessary to aliowphysician's asslstants, registered professional nurses~ licensed practical nt:rSes:, ar...ci nurse practitioners licer.sed and ix:, current gooC. standing in New York State bu!notregistered in New York State to practice in New York State wifuout cb,'il or cf.minal penalty related to lack of registration, ai:.d to allow specialist ass:stants, respinttory therapists, respL"'atory therapist tech.."Ucians, phan:1acists, clinical nurse specialists, dentists, derr:.al hygienls~, registered dental assistants, midVfives, perfusicnists, clir.!cal laboratory technologists, cytotechnologists, certified clinical laboratory technicians. certified histological tecl::.rlcians., licensed clinical socia: workers, lice.c.sed master social workers, podiatrists, physical therapists~ physical therapist assistants. mental health counselors, marriage·and family therapists, creative arrs therapists, psychoa..""lalysts and -psychologists who have an unencumbeTed license and are zurrently in good standi..'lg in New York State but not registered in New York State to practice in New Ycrk State \Vithout civii'or crimil:al penalty :elated to lack of regis::ration; • Sections 6951, 6952, 6953 a.ad 6955 of the Education Law, to the extent t.ecessary to allow :midwives licensed and in current good standing in any state in the United States, or in any province or territory of Canada, o: any other country as approved by the Department of Health to practice in Kew York State withom civil or criminal penalty related to lack of licenS'.L."'e; • Section 3507 of tl:.e Public Health Law and Part 89 of Title JO of the NYC!Ul to the exte.~: necessery to perinit radiologic technolcgists licensed and in c'Ctl."ent good standing i::l New York State but not registered in Kew York State to pr2;ctice in New York State ·•,:vithout civil or crii±rinal penalty related to ~ack of registration; • Secticns 6512 LCL"CUgh 6516, 6548 and 6911 of the Education Law and sections 60.11 and 64.8 Title 8 of the NYCRR, to the extent necessary to allow clicical nurse specialis+.s, specialist assistants, and sa.bstantia]y similar titles certified a:id in current good -st.anding in .any state in the United States, 0:: any province or terri:'.:ory of Canadfii or any other country as approved by the' Department ofHealU :a practice :n New York State without civil or criminal penalty related to lack of certification;. • Sections 6512 through 6516, and 7704 of the Education Law and Part 74 of Title 8 of1he NYCRR, to tl:.e extent necessary to allow licensed master social worker&r licensed cli,,,ical social vrorkers, and substantially similar titles licensed at:d in current good standing i:i any state in the United States, or :n any province or. territory of Canada. or any other country as approved by the Departmerr. of Health to practice in New York St.ate without civil or cdminal penalty related to lack oflicensure; • Section 6908 of the Education Law and associated regulations., to the eX:eut necessary to Permit graduates of State Edt:.cation Department registered. licensure quaiifying nurse p:::actitioner education programs to be employed to practice nursing in a hospital or .::rursll'.g home for 180 days irr.mediately following successful FILED: NEW YORK COUNTY CLERK 07/09/2023 04:48 PM INDEX NO. 451549/2023 NYSCEF DOC. NO. 695 RECEIVED NYSCEF: 07/09/2023 completion of a New York State Registered licensure qualifying education prograr::i, provided tbtt the graduate fi}es v.ith the State Educa:tion Depa.'1Ir.ent an application fo~ certification as a nurse practitioner; • Section 8609 of the Education Law a."l.d associated regulations, tc the extent necessary to penrit g:-aduates of State Educwio:i Depart::nent registered, licen.sure c;,uaEfying clinical laboratory tech:mlogy and cli,."llcal laboratory technician education programs to be emplc-yed to pract:ce for 180 days itr,.r,J.ediate1y foE01,ving · succes.-."'TI.11 completion of a New York State Reg:S.ered iicens;1te qualifying education pro gr~ in a clirictl laboratory v.ith a valid New Yor:< S,:ate peroit, provided that the g::aduate f