Preview
FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023
NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024
EXHIBIT D
FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023
NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024
STATE OF NEW YORK
OFFICE OF THE ATTORNEY GENERAL
MEDICAID FRAUD CONTROL UNIT
SUBPOENA DUCES TECUM
IN THE NAME OF THE PEOPLE OF THE STATE OF NEW YORK
To: Skilled Staffing, LLC
c/o VCorp Agent Services, Inc.
25 Robert Pitt Drive, Suite 204
Monsey, NY 10952
WE HEREBY COMMAND pursuant to Executive Law § 63 (12) that, all business and
excuses being laid aside, you produce to the Office of the New York State Attorney General, to
the attention of Special Assistant Attorney General William McClarnon on or before November
15, 2021, any and all documents requested in the attached Schedule A in accordance with the
instructions and definitions therein, that are in your possession, custody or control, including
documents in the possession, custody and control of any agent you may have.
PLEASE TAKE NOTICE, that the Attorney General deems the documents requested by
this subpoena to be relevant and material to an investigation and inquiry in the public interest into
whether an action or proceeding should be instituted pursuant to New York Executive Law
§ 63(12), New York State Finance Law §§ 187 et seq., and other relevant statutes and regulations.
PLEASE TAKE FURTHER NOTICE, that failure to deliver the documents requested
on the attached Schedule A, in accordance with the attached Definitions and Instructions, which
are incorporated herein, on or before the date and time stated above, or by any agreed-upon
adjourned date or time, may subject you to penalties and any other lawful punishment.
NOTE: Personal Appearance is not required if the subpoenaed documents are delivered to the
undersigned prior to the return date of this subpoena.
WITNESS, Honorable Letitia James, Attorney General of the State of New York, the 29th
day of October, 2021.
William T. McClarnon
Special Assistant Attorney General
Telephone: (845) 732-7523
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FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023
NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024
DEFINITIONS
1. “Facility” or “Facilities” includes the following facilities: A) Abraham Operations
Associates LLC d/b/a Beth Abraham Center for Rehabilitation and Nursing; B) Schnur
Operations Associates, LLC d/b/a Martine Center for Rehabilitation and Nursing; C) Hollis
Operating Co. LLC d/b/a Holliswood Center for Rehabilitation and Healthcare; and D)
Delaware Operations Associates LLC d/b/a Buffalo Center for Rehabilitation and Nursing,
and any former or current officer, director, employee, agent, representative or person acting
or purporting to act on behalf of such entities
2. “Skilled Staffing” refers to Skilled Staffing LLC and any corporate parent, subsidiary,
affiliate, predecessor, or successor of such entities, and any former or current officer,
director, employee, agent, representative or person acting or purporting to act on behalf of
such entities or their corporate parent, subsidiary, affiliate, predecessor, or successor.
3. “Centers” means Centers for Care d/b/a Centers Health Care and any corporate parent,
subsidiary, affiliate, predecessor or successor of such entity, and any former or current
officer, director, employee, agent, representative or person acting or purporting to act on
behalf of such entities.
4. “Documents” is used herein in the broadest sense of the term and shall mean all records
and other tangible media of expression of whatever nature including, without limitation,
originals, drafts or finished versions, or annotated or nonconforming or other copies
however created, produced or stored (manually, mechanically, electronically or otherwise),
including electronically stored information (“ESI”), such as electronic mail (“e-mail”),
instant messages, text messages, smartphones or other wireless device messages, including
but not limited to WhatsApp messages, social media posts, social media comments, social
media direct messages, voicemail, books, papers, files, notes, confirmations, account
statements, correspondence, memoranda, reports, records, journals, registers, analyses,
plans, manuals, policies, telegrams, faxes, wires, telephone logs, telephone messages,
message slips, minutes, notes or records or transcriptions of conversations or
communications or meetings, tape recordings, videotapes, disks, and other electronic
media, microfilm, microfiche, storage devices, press releases, contracts, agreements,
calendars, date books, appointment books, diaries, notices and summaries. A draft or non-
identical copy is a separate document within the meaning of this term. Under this
definition, Documents existing in electronic form shall include all items that may have
been removed from the e-mail accounts or the directories in which they are ordinarily
stored to any other server, folder, file, archive, or backup device, whether or not deleted.
5. “Electronic Communication(s)” means the transmittal of electronically stored information
(“ESI”) (in the form of facts, ideas, inquiries, or otherwise) in any form, such as electronic
mail (“e-mail”), instant messages, text messages, smartphones or other wireless device
messages, including but not limited to WhatsApp messages, Signal messages, social media
posts or comments, social media direct messages, voicemail, video recordings, video
messages, telephone messages or telephonic recordings.
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FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023
NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024
6. “Relating to” means referring to, relating to, reflecting, concerning, describing, evidencing,
or constituting.
7. “Including” means “including but not limited to.”
8. The terms “any” and “all” each mean “any and all.”
9. The terms “and” and “or” shall be construed either conjunctively or disjunctively as
necessary to bring within the scope of Schedules A and B all responses and documents that
the other construction might exclude from its scope.
10. The use of the singular form of any word includes the plural and vice versa.
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FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023
NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024
INSTRUCTIONS
A. Unless otherwise specified, this subpoena requires production of all documents and
information from November 14, 2017 through present, (the “Relevant Period”) that are
responsive to the requests below, and which are in Your possession, custody, or control,
regardless of where such documents or information are located. You shall include all
documents or information that relate to or were used during the relevant time period even if
they had been prepared or published prior. Further, if any document requested in this
subpoena is no longer in Your possession, custody, or control, identify such document
completely and provide the following information regarding the document:
i. Its present location and custodian;
ii. The manner in which it was disposed of, including the date of disposal, the reason for
disposal, the person authorizing the disposal, and the person(s) who disposed of the
document.
B. If no documents exist that are responsive to a request below, you shall include, in your
response to this subpoena and at the time of production, a written statement to that effect.
C. The obligation of production pursuant to this subpoena is a continuing one. Documents or
information located at any time after a response is due shall be promptly produced in the
manner specified by the subpoena.
D. In responding to this subpoena, all documents produced shall be segregated and labeled so
as to identify which request(s) such documents respond to. Alternatively, you shall identify,
by bates-numbers, the documents responsive to each request herein.
E. In responding to this subpoena, you shall locate, gather, and produce documents from your
files and other sources, including documents stored electronically, in such a manner as to
ensure that the source and location of each document may be readily determined.
F. In responding to this subpoena, if you locate responsive documents, including documents
stored electronically, in file folders or other containers, you shall produce these folders and
containers, including any labels identifying such folders or containers, together with the
responsive documents contained therein.
G. In responding to this subpoena, documents attached to each other shall not be separated
unless you also identify such separation and provide records sufficient to permit the
reconstruction of such grouping of documents.
H. In responding to this subpoena, if you locate documents that have markings on both sides
of a document, you shall produce both sides.
I. For any document or part thereof that you decide not to produce by reason of a claim of
privilege, you shall state the privilege being claimed, give an explanation for your claim of
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FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023
NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024
such privilege, and provide the following information concerning the putatively privileged
document:
i.The type of document;
ii.The date of the document;
iii.The subject matter of the document;
iv. The author of the document, including his or her address, telephone number and
business function;
v. All recipients of the document, including their addresses, telephone numbers, and
business function;
vi. The number of pages of the document.
J. In responding to this subpoena, you shall locate, gather, and produce documents or
information stored electronically in accordance with the “Document and ESI Production
Specifications,” attached as a rider to the subpoena.
K. In order for your response to the Document Request set forth in Schedule A of this subpoena
to be complete, the attached statement entitled “Verification” must be completed and
executed on behalf of your company, under oath, by a person supervising compliance with
the subpoena, and submitted with the responsive documents.
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FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023
NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024
Schedule A: Documents Requested
1. Organizational charts showing management, ownership structure, and reporting lines for any
employees, directors and officers of Skilled Staffing throughout the Relevant Period.
2. The following financial documents for Skilled Staffing throughout the Relevant Period:
A) Financial statements;
B) General ledgers;
C) Cash disbursement journal;
D) Cash receipts journal;
E) Payroll journal;
F) Purchase journal.
3. Invoices issued by Skilled Staffing to Centers or any Facility for work performed for Centers
or any Facility during the Relevant Period.
4. Skilled Staffing’s tax returns throughout the Relevant Period.
5. All contracts, agreements, amendments, or other writings in effect during the Relevant
Period, memorializing services performed by Skilled Staffing for Centers and/or each
Facility.
6. All punch detail or time cards in connection with services performed by Skilled Staffing for
Centers and each Facility.
7. All communications among individuals at Skilled Staffing, Centers and/or each Facility
regarding services provided by Skilled Staffing to Centers and each Facility.
8. Any and all loan applications and agreements, including PPP loans, CARES Act funding and
PPE loans.
9. All documents relating to Skilled Staffing’s efforts to obtain business from Centers and each
Facility, including but not limited to any requests for proposals from Centers and/or each
Facility, proposals or bids submitted by Skilled Staffing, and agreements between Skilled
Staffing and Centers and each Facility.
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FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023
NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024
10. Documents sufficient to show the bank and account number for all bank accounts used by
Skilled Staffing during the Relevant Period, including but not limited to any and all accounts
from which Skilled Staffing’s expenses are paid or revenue deposited, mortgage accounts,
and investment accounts.
11. All contracts, agreements, amendments, or other writings or documents during the Relevant
Period, memorializing the purchase, sale, take-over, and/or merger of Skilled Staffing with
Regional Care Network LLC.
12. All communications among individuals at Skilled Staffing, Centers and/or each Facility
regarding the purchase, sale, take-over, and/or merger of Skilled Staffing with Regional Care
Network LLC.
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FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023
NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024
VERIFICATION
This response to the Subpoena from the Attorney General of the State of New York, dated
October 29, 2021, was prepared and assembled under my personal supervision from the records
of the Skilled Staffing, LLC in accordance with the definitions and instructions set forth in such
Subpoena and is complete and correct to the best of my knowledge and belief. The documents
produced in response to this Subpoena are authentic, genuine, and what they purport to be.
(Signature of Official (Title)
(Type or Print Name of Above Official)
*******************************
Subscribed and sworn to before me this
day of , 2021.
NOTARY PUBLIC
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FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023
NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024
Rider: Document and ESI Production Specifications
Format for Electronic Documents: Electronic documents, including, e.g., emails,
spreadsheets, and word processing documents, should be produced in native file format. For
native format, Outlook emails should be produced as . pst files and Lotus note emails as .nsf
files.
Format for Database Files: Provide the data in an ascii delimited (tilde or pipe) format with
the column headings in the first row and the corresponding data dictionary.
Format for Proprietary Software Data: Contact the undersigned to request an agreed upon
format in which the data is exported and produced.
Format for Scanned Documents: If a document only exists in paper format, it should be
scanned and produced in a Concordance format as specified below. For each paper document
produced, identify all numbered specifications in the demand request (if applicable) to which
the produced document is responsive. We suggest marking each page produced in the lower
right corner with a consecutive document number.
(1) The Concordance load file shall also include all extracted metadata and bibliographical
data in text delimited format (.DAT file).
(2) The .DAT file must include field headers. Note: Once metadata fields have been
established, the field names and field order should be maintained throughout the course
of production, unless they are being changed to solve a problem.
(3) The production must include searchable text for each document. The searchable text
shall be extracted using OCR technology when the document(s) exists only in paper
form.
(4) The text shall be produced as separate document- based text (.TXT) files.
(5) If the searchable text is being produced as .TXT files, it shall be named based on
its associated document Bates number.
(6) The production shall include single page, Tagged Imaged File Format (TIFF, black and
white or color where applicable, Fax IV compressed, 300 x 300 dpi) image files. The
image files shall be stamped with a unique control number.
(7) The production shall also include an Opticon (.opt) image base file. This .file shall
have one record for each image file. The image base shall be produced in sequential
order with appropriate document break information.
(8) Unless otherwise indicated, documents are to be produced on computer CD/DVD or
USB media.
(9) The production shall provide parent-child relationships between all paper documents
(emails, zip files) as metadata fields such as begattach, endattach. For example, a file
containing multiple documents: the folder would be considered the parent document
and each document in the folder would be considered the children.
9
Preview
FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023 NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024 EXHIBIT D FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023 NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024 STATE OF NEW YORK OFFICE OF THE ATTORNEY GENERAL MEDICAID FRAUD CONTROL UNIT SUBPOENA DUCES TECUM IN THE NAME OF THE PEOPLE OF THE STATE OF NEW YORK To: Skilled Staffing, LLC c/o VCorp Agent Services, Inc. 25 Robert Pitt Drive, Suite 204 Monsey, NY 10952 WE HEREBY COMMAND pursuant to Executive Law § 63 (12) that, all business and excuses being laid aside, you produce to the Office of the New York State Attorney General, to the attention of Special Assistant Attorney General William McClarnon on or before November 15, 2021, any and all documents requested in the attached Schedule A in accordance with the instructions and definitions therein, that are in your possession, custody or control, including documents in the possession, custody and control of any agent you may have. PLEASE TAKE NOTICE, that the Attorney General deems the documents requested by this subpoena to be relevant and material to an investigation and inquiry in the public interest into whether an action or proceeding should be instituted pursuant to New York Executive Law § 63(12), New York State Finance Law §§ 187 et seq., and other relevant statutes and regulations. PLEASE TAKE FURTHER NOTICE, that failure to deliver the documents requested on the attached Schedule A, in accordance with the attached Definitions and Instructions, which are incorporated herein, on or before the date and time stated above, or by any agreed-upon adjourned date or time, may subject you to penalties and any other lawful punishment. NOTE: Personal Appearance is not required if the subpoenaed documents are delivered to the undersigned prior to the return date of this subpoena. WITNESS, Honorable Letitia James, Attorney General of the State of New York, the 29th day of October, 2021. William T. McClarnon Special Assistant Attorney General Telephone: (845) 732-7523 1 FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023 NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024 DEFINITIONS 1. “Facility” or “Facilities” includes the following facilities: A) Abraham Operations Associates LLC d/b/a Beth Abraham Center for Rehabilitation and Nursing; B) Schnur Operations Associates, LLC d/b/a Martine Center for Rehabilitation and Nursing; C) Hollis Operating Co. LLC d/b/a Holliswood Center for Rehabilitation and Healthcare; and D) Delaware Operations Associates LLC d/b/a Buffalo Center for Rehabilitation and Nursing, and any former or current officer, director, employee, agent, representative or person acting or purporting to act on behalf of such entities 2. “Skilled Staffing” refers to Skilled Staffing LLC and any corporate parent, subsidiary, affiliate, predecessor, or successor of such entities, and any former or current officer, director, employee, agent, representative or person acting or purporting to act on behalf of such entities or their corporate parent, subsidiary, affiliate, predecessor, or successor. 3. “Centers” means Centers for Care d/b/a Centers Health Care and any corporate parent, subsidiary, affiliate, predecessor or successor of such entity, and any former or current officer, director, employee, agent, representative or person acting or purporting to act on behalf of such entities. 4. “Documents” is used herein in the broadest sense of the term and shall mean all records and other tangible media of expression of whatever nature including, without limitation, originals, drafts or finished versions, or annotated or nonconforming or other copies however created, produced or stored (manually, mechanically, electronically or otherwise), including electronically stored information (“ESI”), such as electronic mail (“e-mail”), instant messages, text messages, smartphones or other wireless device messages, including but not limited to WhatsApp messages, social media posts, social media comments, social media direct messages, voicemail, books, papers, files, notes, confirmations, account statements, correspondence, memoranda, reports, records, journals, registers, analyses, plans, manuals, policies, telegrams, faxes, wires, telephone logs, telephone messages, message slips, minutes, notes or records or transcriptions of conversations or communications or meetings, tape recordings, videotapes, disks, and other electronic media, microfilm, microfiche, storage devices, press releases, contracts, agreements, calendars, date books, appointment books, diaries, notices and summaries. A draft or non- identical copy is a separate document within the meaning of this term. Under this definition, Documents existing in electronic form shall include all items that may have been removed from the e-mail accounts or the directories in which they are ordinarily stored to any other server, folder, file, archive, or backup device, whether or not deleted. 5. “Electronic Communication(s)” means the transmittal of electronically stored information (“ESI”) (in the form of facts, ideas, inquiries, or otherwise) in any form, such as electronic mail (“e-mail”), instant messages, text messages, smartphones or other wireless device messages, including but not limited to WhatsApp messages, Signal messages, social media posts or comments, social media direct messages, voicemail, video recordings, video messages, telephone messages or telephonic recordings. 2 FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023 NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024 6. “Relating to” means referring to, relating to, reflecting, concerning, describing, evidencing, or constituting. 7. “Including” means “including but not limited to.” 8. The terms “any” and “all” each mean “any and all.” 9. The terms “and” and “or” shall be construed either conjunctively or disjunctively as necessary to bring within the scope of Schedules A and B all responses and documents that the other construction might exclude from its scope. 10. The use of the singular form of any word includes the plural and vice versa. 3 FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023 NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024 INSTRUCTIONS A. Unless otherwise specified, this subpoena requires production of all documents and information from November 14, 2017 through present, (the “Relevant Period”) that are responsive to the requests below, and which are in Your possession, custody, or control, regardless of where such documents or information are located. You shall include all documents or information that relate to or were used during the relevant time period even if they had been prepared or published prior. Further, if any document requested in this subpoena is no longer in Your possession, custody, or control, identify such document completely and provide the following information regarding the document: i. Its present location and custodian; ii. The manner in which it was disposed of, including the date of disposal, the reason for disposal, the person authorizing the disposal, and the person(s) who disposed of the document. B. If no documents exist that are responsive to a request below, you shall include, in your response to this subpoena and at the time of production, a written statement to that effect. C. The obligation of production pursuant to this subpoena is a continuing one. Documents or information located at any time after a response is due shall be promptly produced in the manner specified by the subpoena. D. In responding to this subpoena, all documents produced shall be segregated and labeled so as to identify which request(s) such documents respond to. Alternatively, you shall identify, by bates-numbers, the documents responsive to each request herein. E. In responding to this subpoena, you shall locate, gather, and produce documents from your files and other sources, including documents stored electronically, in such a manner as to ensure that the source and location of each document may be readily determined. F. In responding to this subpoena, if you locate responsive documents, including documents stored electronically, in file folders or other containers, you shall produce these folders and containers, including any labels identifying such folders or containers, together with the responsive documents contained therein. G. In responding to this subpoena, documents attached to each other shall not be separated unless you also identify such separation and provide records sufficient to permit the reconstruction of such grouping of documents. H. In responding to this subpoena, if you locate documents that have markings on both sides of a document, you shall produce both sides. I. For any document or part thereof that you decide not to produce by reason of a claim of privilege, you shall state the privilege being claimed, give an explanation for your claim of 4 FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023 NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024 such privilege, and provide the following information concerning the putatively privileged document: i.The type of document; ii.The date of the document; iii.The subject matter of the document; iv. The author of the document, including his or her address, telephone number and business function; v. All recipients of the document, including their addresses, telephone numbers, and business function; vi. The number of pages of the document. J. In responding to this subpoena, you shall locate, gather, and produce documents or information stored electronically in accordance with the “Document and ESI Production Specifications,” attached as a rider to the subpoena. K. In order for your response to the Document Request set forth in Schedule A of this subpoena to be complete, the attached statement entitled “Verification” must be completed and executed on behalf of your company, under oath, by a person supervising compliance with the subpoena, and submitted with the responsive documents. 5 FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023 NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024 Schedule A: Documents Requested 1. Organizational charts showing management, ownership structure, and reporting lines for any employees, directors and officers of Skilled Staffing throughout the Relevant Period. 2. The following financial documents for Skilled Staffing throughout the Relevant Period: A) Financial statements; B) General ledgers; C) Cash disbursement journal; D) Cash receipts journal; E) Payroll journal; F) Purchase journal. 3. Invoices issued by Skilled Staffing to Centers or any Facility for work performed for Centers or any Facility during the Relevant Period. 4. Skilled Staffing’s tax returns throughout the Relevant Period. 5. All contracts, agreements, amendments, or other writings in effect during the Relevant Period, memorializing services performed by Skilled Staffing for Centers and/or each Facility. 6. All punch detail or time cards in connection with services performed by Skilled Staffing for Centers and each Facility. 7. All communications among individuals at Skilled Staffing, Centers and/or each Facility regarding services provided by Skilled Staffing to Centers and each Facility. 8. Any and all loan applications and agreements, including PPP loans, CARES Act funding and PPE loans. 9. All documents relating to Skilled Staffing’s efforts to obtain business from Centers and each Facility, including but not limited to any requests for proposals from Centers and/or each Facility, proposals or bids submitted by Skilled Staffing, and agreements between Skilled Staffing and Centers and each Facility. 6 FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023 NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024 10. Documents sufficient to show the bank and account number for all bank accounts used by Skilled Staffing during the Relevant Period, including but not limited to any and all accounts from which Skilled Staffing’s expenses are paid or revenue deposited, mortgage accounts, and investment accounts. 11. All contracts, agreements, amendments, or other writings or documents during the Relevant Period, memorializing the purchase, sale, take-over, and/or merger of Skilled Staffing with Regional Care Network LLC. 12. All communications among individuals at Skilled Staffing, Centers and/or each Facility regarding the purchase, sale, take-over, and/or merger of Skilled Staffing with Regional Care Network LLC. 7 FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023 NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024 VERIFICATION This response to the Subpoena from the Attorney General of the State of New York, dated October 29, 2021, was prepared and assembled under my personal supervision from the records of the Skilled Staffing, LLC in accordance with the definitions and instructions set forth in such Subpoena and is complete and correct to the best of my knowledge and belief. The documents produced in response to this Subpoena are authentic, genuine, and what they purport to be. (Signature of Official (Title) (Type or Print Name of Above Official) ******************************* Subscribed and sworn to before me this day of , 2021. NOTARY PUBLIC 8 FILED: NEW YORK COUNTY CLERK 03/01/2024 03:21 PM INDEX NO. 451549/2023 NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 03/01/2024 Rider: Document and ESI Production Specifications Format for Electronic Documents: Electronic documents, including, e.g., emails, spreadsheets, and word processing documents, should be produced in native file format. For native format, Outlook emails should be produced as . pst files and Lotus note emails as .nsf files. Format for Database Files: Provide the data in an ascii delimited (tilde or pipe) format with the column headings in the first row and the corresponding data dictionary. Format for Proprietary Software Data: Contact the undersigned to request an agreed upon format in which the data is exported and produced. Format for Scanned Documents: If a document only exists in paper format, it should be scanned and produced in a Concordance format as specified below. For each paper document produced, identify all numbered specifications in the demand request (if applicable) to which the produced document is responsive. We suggest marking each page produced in the lower right corner with a consecutive document number. (1) The Concordance load file shall also include all extracted metadata and bibliographical data in text delimited format (.DAT file). (2) The .DAT file must include field headers. Note: Once metadata fields have been established, the field names and field order should be maintained throughout the course of production, unless they are being changed to solve a problem. (3) The production must include searchable text for each document. The searchable text shall be extracted using OCR technology when the document(s) exists only in paper form. (4) The text shall be produced as separate document- based text (.TXT) files. (5) If the searchable text is being produced as .TXT files, it shall be named based on its associated document Bates number. (6) The production shall include single page, Tagged Imaged File Format (TIFF, black and white or color where applicable, Fax IV compressed, 300 x 300 dpi) image files. The image files shall be stamped with a unique control number. (7) The production shall also include an Opticon (.opt) image base file. This .file shall have one record for each image file. The image base shall be produced in sequential order with appropriate document break information. (8) Unless otherwise indicated, documents are to be produced on computer CD/DVD or USB media. (9) The production shall provide parent-child relationships between all paper documents (emails, zip files) as metadata fields such as begattach, endattach. For example, a file containing multiple documents: the folder would be considered the parent document and each document in the folder would be considered the children. 9