Exhibit,Appendix: People Of The State Of New York, By Letitia James, Attorney General Of The State Of New York v. Abraham Operations Associates Llc Dba Beth Abraham Center For Rehabilitation And Nursing, Delaware Operations Associates Llc Dba Buffalo Center For Rehabilitation And Nursing, Hollis Operating Co Llc Dba Holliswood Center For Rehabilitation And Healthcare, Schnur Operations Associates Llc Dba Martine Center For Rehabilitation And Nursing, Light Property Holdings Associates Llc, Delaware Real Property Associates Llc, Hollis Real Estate Co Llc, Light Operational Holdings Associates Llc, Light Property Holdings Ii Associates Llc, Centers For Care Llc Dba Centers Health Care, Cfsc Downstate Llc, Bis Funding Capital Llc, Skilled Staffing Llc, Kenneth Rozenberg, Daryl Hagler, Beth Rozenberg, Jeffrey Sicklick, Leo Lerner, Reuven Kaufman, Amir Abramchik, David Greenberg, Elliot Kahan, Sol Blumenfeld, Aron Gittleson, Aharon Lantzitsky, Jonathan Hagler, Mordechai Moti Hellman

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                                FILED: NEW YORK COUNTY CLERK 08/10/2023 10:58 AM         INDEX NO. 451549/2023
NYSCEF DOC. NO. 769                                RECEIVED NYSCEF: 08/10/2023




                      EXHIBIT D
FILED: NEW YORK COUNTY CLERK 08/10/2023 10:58 AM                                                       INDEX NO. 451549/2023
NYSCEF DOC. NO. 769                                                                            RECEIVED NYSCEF: 08/10/2023


    Michael Wittmann

    From:               Gowdey, Logan [NYC] 
    Sent:               Thursday, August 10, 2023 9:30 AM
    To:                 Manisha Sheth; Auletta, Emily [ALB]; Joanna Menillo; Payne, Konrad [NYC]; Pettigrew, Todd [PEA]
    Cc:                 QECenters; Motty Shulman - Centricity Law PLLC (ms@centricitylegal.com);
                        mzauderer@ganfershore.com
    Subject:            RE: Centers: Proposed Stipulation


                                        [EXTERNAL EMAIL from logan.gowdey@ag.ny.gov]




    Manisha:

   Following up on our call yesterday afternoon, we do not agree to your proposed language that varies from the CPLR.
   CPLR 404(a) makes clear that Respondents do not have an automatic right to file answers if their motions to dismiss are
   denied, and we reserve the right to argue in our opposition brief that no post‐motion answers should be allowed. Please
   let us know by today at 11 am if you agree with our proposed language; otherwise, we will submit our proposed order
   from Tuesday to the Court and note the parties’ disagreement.

   Best,

   Logan

   From: Manisha Sheth 
   Sent: Tuesday, August 8, 2023 1:50 PM
   To: Gowdey, Logan [NYC] ; Auletta, Emily [ALB] ; Joanna Menillo
   ; Payne, Konrad [NYC] ; Pettigrew, Todd [PEA]
   
   Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
   ; mzauderer@ganfershore.com
   Subject: RE: Centers: Proposed Stipulation

    Thanks Logan!

   From: Gowdey, Logan [NYC] 
   Sent: Tuesday, August 8, 2023 1:50 PM
   To: Manisha Sheth ; Auletta, Emily [ALB] ; Joanna
   Menillo ; Payne, Konrad [NYC] ; Pettigrew, Todd [PEA]
   
   Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
   ; mzauderer@ganfershore.com
   Subject: RE: Centers: Proposed Stipulation

                                        [EXTERNAL EMAIL from logan.gowdey@ag.ny.gov]


   That works for us, thanks. I just sent you and Joanna an invite for that time; feel free to forward to anyone else you’d
   like to include.
                                                                1
FILED: NEW YORK COUNTY CLERK 08/10/2023 10:58 AM                                                    INDEX NO. 451549/2023
NYSCEF DOC. NO. 769                                                                         RECEIVED NYSCEF: 08/10/2023


   From: Manisha Sheth 
   Sent: Tuesday, August 8, 2023 1:43 PM
   To: Gowdey, Logan [NYC] ; Auletta, Emily [ALB] ; Joanna Menillo
   ; Payne, Konrad [NYC] ; Pettigrew, Todd [PEA]
   
   Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
   ; mzauderer@ganfershore.com
   Subject: RE: Centers: Proposed Stipulation

    Thanks Logan. Today is tough for me but let’s do tomorrow at 345 pm. Shouldn't take more
    than 15 mins.
    Best,
    Manisha

   From: Gowdey, Logan [NYC] 
   Sent: Tuesday, August 8, 2023 1:41 PM
   To: Manisha Sheth ; Auletta, Emily [ALB] ; Joanna
   Menillo ; Payne, Konrad [NYC] ; Pettigrew, Todd [PEA]
   
   Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
   ; mzauderer@ganfershore.com
   Subject: RE: Centers: Proposed Stipulation

                                        [EXTERNAL EMAIL from logan.gowdey@ag.ny.gov]




    We are available today at 3 pm or tomorrow after 3:45 pm. Let us know when works for you, and if you’d like us to send
    a Teams invite.

   From: Manisha Sheth 
   Sent: Tuesday, August 8, 2023 1:24 PM
   To: Gowdey, Logan [NYC] ; Auletta, Emily [ALB] ; Joanna Menillo
   ; Payne, Konrad [NYC] ; Pettigrew, Todd [PEA]
   
   Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
   ; mzauderer@ganfershore.com
   Subject: RE: Centers: Proposed Stipulation

    Lets get on a call to discuss

   From: Gowdey, Logan [NYC] 
   Sent: Tuesday, August 8, 2023 1:16 PM
   To: Manisha Sheth ; Auletta, Emily [ALB] ; Joanna
   Menillo ; Payne, Konrad [NYC] ; Pettigrew, Todd [PEA]
   
   Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)


                                                              2
FILED: NEW YORK COUNTY CLERK 08/10/2023 10:58 AM                                                       INDEX NO. 451549/2023
NYSCEF DOC. NO. 769                                                                            RECEIVED NYSCEF: 08/10/2023
    ; mzauderer@ganfershore.com
    Subject: RE: Centers: Proposed Stipulation

                                         [EXTERNAL EMAIL from logan.gowdey@ag.ny.gov]




    Manisha:

    We are fine with these changes except one: the deletion in paragraph 3 of “the Court may grant” and “an opportunity
    to”. Please find attached our draft restoring that language, which better tracks CPLR 404(a). That provision makes clear
    that it is up to the Court to decide whether a respondent can file an answer if its motion to dismiss is denied. (“If the
    motion is denied, the court may permit the respondent to answer….” (emphasis added).) We are happy to discuss on a
    call if you would like.

    Best,

    Logan

   From: Manisha Sheth 
   Sent: Monday, August 7, 2023 5:05 PM
   To: Auletta, Emily [ALB] ; Joanna Menillo ; Gowdey,
   Logan [NYC] ; Payne, Konrad [NYC] ; Pettigrew, Todd [PEA]
   
   Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
   ; mzauderer@ganfershore.com
   Subject: RE: Centers: Proposed Stipulation

    Hi Emily,
    Attached are our edits to the stipulation. Clean and redline attached for your convenience.
    If this is acceptable, please execute and return to us and we will get it on file.
    Best,
    Manisha

   From: Auletta, Emily [ALB] 
   Sent: Monday, August 7, 2023 1:48 PM
   To: Joanna Menillo ; Manisha Sheth ;
   Gowdey, Logan [NYC] ; Payne, Konrad [NYC] ; Pettigrew, Todd
   [PEA] 
   Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
   ; mzauderer@ganfershore.com
   Subject: RE: Centers: Proposed Stipulation

                                         [EXTERNAL EMAIL from emily.auletta@ag.ny.gov]




    Hi Joanna,

   Attached please find your version of the Scheduling Stip with a few minor changes we tracked. One such change clarifies
   what Petitioner intends to file after Respondents answer, which is in line with the language of Article 4 and (we think)
                                                                 3
FILED: NEW YORK COUNTY CLERK 08/10/2023 10:58 AM                                                    INDEX NO. 451549/2023
NYSCEF DOC. NO. 769                                                                         RECEIVED NYSCEF: 08/10/2023
    moots Manisha’s question from Friday about re‐noticing the petition. Please let us know if you have any further
    questions.

    Thanks,
    Emily

    From: Joanna Menillo 
    Sent: Thursday, August 3, 2023 7:26 PM
    To: Auletta, Emily [ALB] ; Manisha Sheth ; Gowdey,
    Logan [NYC] ; Payne, Konrad [NYC] ; Pettigrew, Todd [PEA]
    
    Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
    ; mzauderer@ganfershore.com
    Subject: RE: Centers: Proposed Stipulation

    Hi Emily,

    Attached please find our responsive proposed scheduling order based on the conference with the Court this morning. I
    am also attaching a redline that compares Respondents’ version against the one you circulated this morning.

    Thank you,
    Joanna

    From: Auletta, Emily [ALB] 
    Sent: Thursday, August 3, 2023 1:57 PM
    To: Manisha Sheth ; Joanna Menillo ;
    Gowdey, Logan [NYC] ; Payne, Konrad [NYC] ; Pettigrew, Todd
    [PEA] 
    Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
    ; mzauderer@ganfershore.com
    Subject: RE: Centers: Proposed Stipulation

                                        [EXTERNAL EMAIL from emily.auletta@ag.ny.gov]




    Hi Manisha,

   Great. We’ll await your draft and add further revisions, if we have any.

   Thanks,
   Emily

   From: Manisha Sheth 
   Sent: Thursday, August 3, 2023 1:56 PM
   To: Auletta, Emily [ALB] ; Joanna Menillo ; Gowdey,
   Logan [NYC] ; Payne, Konrad [NYC] ; Pettigrew, Todd [PEA]
   
   Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
   ; mzauderer@ganfershore.com
   Subject: RE: Centers: Proposed Stipulation

                                                               4
FILED: NEW YORK COUNTY CLERK 08/10/2023 10:58 AM                                                       INDEX NO. 451549/2023
NYSCEF DOC. NO. 769                                                                            RECEIVED NYSCEF: 08/10/2023

    Emily,
    Wanted to let you know we are revising per our court call this morning and will send you a
    further revised draft today.
    Best,
    Manisha

    From: Auletta, Emily [ALB] 
    Sent: Thursday, August 3, 2023 8:30 AM
    To: Joanna Menillo ; Manisha Sheth ;
    Gowdey, Logan [NYC] ; Payne, Konrad [NYC] ; Pettigrew, Todd
    [PEA] 
    Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
    ; mzauderer@ganfershore.com
    Subject: RE: Centers: Proposed Stipulation

                                         [EXTERNAL EMAIL from emily.auletta@ag.ny.gov]




    Hi Joanna,

   As you probably just saw, we submitted to the Court the same proposal we sent to you and your colleagues on Friday
   night. The only change is that we turned it into a proposed order, rather than a stipulation and order, because we have
   not received your consent to the proposed revisions yet.

   Thank you,
   Emily

   From: Joanna Menillo 
   Sent: Thursday, August 3, 2023 11:12 AM
   To: Auletta, Emily [ALB] ; Manisha Sheth ; Gowdey,
   Logan [NYC] ; Payne, Konrad [NYC] ; Pettigrew, Todd [PEA]
   
   Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
   ; mzauderer@ganfershore.com
   Subject: RE: Centers: Proposed Stipulation

    Hi Emily,

    We would like to set up a meet and confer to discuss this Stipulation. Can you please let us know your availability for a
    call this afternoon or tomorrow?

    Thank you,
    Joanna

    From: Auletta, Emily [ALB] 
    Sent: Friday, July 28, 2023 9:35 PM
    To: Joanna Menillo ; Manisha Sheth ;
    Gowdey, Logan [NYC] ; Payne, Konrad [NYC] ; Pettigrew, Todd
    [PEA] 
                                                                 5
FILED: NEW YORK COUNTY CLERK 08/10/2023 10:58 AM                                                       INDEX NO. 451549/2023
NYSCEF DOC. NO. 769                                                                            RECEIVED NYSCEF: 08/10/2023
    Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
    ; mzauderer@ganfershore.com
    Subject: RE: Centers: Proposed Stipulation

                                         [EXTERNAL EMAIL from emily.auletta@ag.ny.gov]




    Hi Joanna,

   Sorry for the delay in getting you our revisions to the proposed scheduling stipulation. Our response is attached. Where
   we left a date blank, we did so intending to have the Court fill it in.

    Thanks and have a great weekend,
    Emily

    From: Joanna Menillo 
    Sent: Friday, July 28, 2023 11:34 AM
    To: Auletta, Emily [ALB] ; Manisha Sheth ; Gowdey,
    Logan [NYC] ; Payne, Konrad [NYC] ; Pettigrew, Todd [PEA]
    
    Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
    ; mzauderer@ganfershore.com
    Subject: RE: Centers: Proposed Stipulation

    Good Morning Emily and AG team,

    I write to follow up on Manisha’s email of July 12, 2023. Can you please let us know if you have any edits to the
    proposed stipulation that we circulated? Reattaching here for convenience.

    Thank you,
    Joanna

    From: Auletta, Emily [ALB] 
    Sent: Wednesday, July 12, 2023 9:54 AM
    To: Manisha Sheth ; Gowdey, Logan [NYC] ; Payne,
    Konrad [NYC] ; Pettigrew, Todd [PEA] 
    Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)
    ; mzauderer@ganfershore.com
    Subject: RE: Centers: Proposed Stipulation

                                         [EXTERNAL EMAIL from emily.auletta@ag.ny.gov]


    Thank you, Manisha. We’ll get back to you soon.

   From: Manisha Sheth 
   Sent: Wednesday, July 12, 2023 9:48 AM
   To: Auletta, Emily [ALB] ; Gowdey, Logan [NYC] ; Payne, Konrad
   [NYC] ; Pettigrew, Todd [PEA] 
   Cc: QECenters ; Motty Shulman ‐ Centricity Law PLLC (ms@centricitylegal.com)

                                                                6
FILED: NEW YORK COUNTY CLERK 08/10/2023 10:58 AM                                                       INDEX NO. 451549/2023
NYSCEF DOC. NO. 769                                                                            RECEIVED NYSCEF: 08/10/2023
    ; mzauderer@ganfershore.com
    Subject: Centers: Proposed Stipulation

    [EXTERNAL]
   Good morning Emily and AG team,
   Attached is a proposed stipulation regarding the briefing schedule on the 63(12)
   proceeding. Please let us know if you have any edits. I know you had mentioned 3 weeks in
   court for your reply, but I also recall that you wanted to discuss internally so I have left it blank
   for you to complete in the draft.
   Best,
   Manisha


   Manisha M. Sheth, Partner
    quinn emanuel urquhart & sullivan, llp
   51 Madison Avenue, 22nd Floor
   New York, NY 10010
   Direct: (212) 849-7441
   Cell Phone: (215) 205-7501
   Main Fax: (212) 849-7100
   E-mail: manishasheth@quinnemanuel.com
   Web: www.quinnemanuel.com

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