On June 28, 2023 a
Letter,Correspondence
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.
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CHIESA SHAHINIAN & GIANTOMASI PC
105 Eisenhower Parkway, Roseland, NJ 07068
csglaw.com
LEE VARTAN
lvartan@csglaw.com
O 973.530.2107 F 973.325.1501
February 9, 2024
Via Email & NYSCEF
The Honorable Melissa Anne Crane
Supreme Court, New York County
60 Centre Street
New York, NY 10007
Re: People v. Abraham Operation Assocs., LLC, No. 451549/2023 (N.Y. Sup. Ct.)
Dear Justice Crane:
We represent Respondents Light Property Holdings Associates LLC, Delaware
Real Property Associates LLC, Hollis Real Estate Co., LLC, Light Property Holdings II
Associates, LLC, CFSC Downstate, LLC, BIS Funding Capital LLC, Daryl Hagler, and
Jonathan Hagler (collectively, the “Real Estate Respondents”) in the above captioned
matter. We are in receipt of the Centers Respondents’ Motion for Discovery Pursuant
to CPLR 408. See Dkt. No. 814. The Real Estate Respondents respectfully join in this
motion and rely on the Centers Respondents’ supporting papers. See Dkt. No. 815.
In their memorandum of law in support of the motion, the Centers Respondents
set forth a list of narrowly tailored categories of documents that they seek through the
motion. Notably, the Centers Respondents are only seeking documents that are already
in the Attorney General’s possession. Each category should lead to documents that are
also relevant to the Real Estate Respondents, but the following are critical to the Real
Estate Respondents’ ability to present an informed defense:
Documents relating to the fair market value of the allegedly inflated rents
described in the Petition; and
Documents relating to the fair market value of the goods and services
exchanged between Respondents and the Related Party Vendors.
Therefore, for the reasons set forth in the Centers Respondents’ memorandum of
law in support of the motion for discovery, the Real Estate Respondents respectfully
request that the Court authorize limited discovery for all Respondents in this matter.
NEW JERSEY NEW YORK
4883-4511-5044.v1
1 of 2
February 9, 2024
Page 2
Respectfully submitted,
/s/ Lee Vartan
Lee Vartan
Member
4883-4511-5044.v1
2 of 2
Document Filed Date
February 09, 2024
Case Filing Date
June 28, 2023
Category
Commercial - Other - Commercial Division
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CHIESA SHAHINIAN & GIANTOMASI PC 105 Eisenhower Parkway, Roseland, NJ 07068 csglaw.com LEE VARTAN lvartan@csglaw.com O 973.530.2107 F 973.325.1501 February 9, 2024 Via Email & NYSCEF The Honorable Melissa Anne Crane Supreme Court, New York County 60 Centre Street New York, NY 10007 Re: People v. Abraham Operation Assocs., LLC, No. 451549/2023 (N.Y. Sup. Ct.) Dear Justice Crane: We represent Respondents Light Property Holdings Associates LLC, Delaware Real Property Associates LLC, Hollis Real Estate Co., LLC, Light Property Holdings II Associates, LLC, CFSC Downstate, LLC, BIS Funding Capital LLC, Daryl Hagler, and Jonathan Hagler (collectively, the “Real Estate Respondents”) in the above captioned matter. We are in receipt of the Centers Respondents’ Motion for Discovery Pursuant to CPLR 408. See Dkt. No. 814. The Real Estate Respondents respectfully join in this motion and rely on the Centers Respondents’ supporting papers. See Dkt. No. 815. In their memorandum of law in support of the motion, the Centers Respondents set forth a list of narrowly tailored categories of documents that they seek through the motion. Notably, the Centers Respondents are only seeking documents that are already in the Attorney General’s possession. Each category should lead to documents that are also relevant to the Real Estate Respondents, but the following are critical to the Real Estate Respondents’ ability to present an informed defense: Documents relating to the fair market value of the allegedly inflated rents described in the Petition; and Documents relating to the fair market value of the goods and services exchanged between Respondents and the Related Party Vendors. Therefore, for the reasons set forth in the Centers Respondents’ memorandum of law in support of the motion for discovery, the Real Estate Respondents respectfully request that the Court authorize limited discovery for all Respondents in this matter. NEW JERSEY NEW YORK 4883-4511-5044.v1 1 of 2 February 9, 2024 Page 2 Respectfully submitted, /s/ Lee Vartan Lee Vartan Member 4883-4511-5044.v1 2 of 2