Motion to Quash Service of Subpoena in Garnet Health Medical Center v. People Of New York, By Letitia James, New York State Attorney General| Trellis.Law

On March 18, 2024 a Exhibit,Appendix was filed involving a dispute between Garnet Health Medical Center, and People Of New York, By Letitia James, New York State Attorney General, for Special Proceedings - Other (Quash Subpoena) in the District Court of Orange County.

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FILED: ORANGE COUNTY CLERK 03/19/2024 10:11 AM INDEX NO. EF002246-2024
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 03/19/2024

EXHIBIT A
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SUBPOENA DUCES TECUM
THE PEOPLE OF THE STATE OF NEW YORK

GREETINGS

TO: Garnet Health Medical Center

c/o Garnet Health

707 East Main Street

Middletown, New York 10940

SERVE ON: Bryn Goodman
Fox Rothschild LLP
101 Park Avenue, 17th Floor
New York, NY 10178
bgoodman@foxrothschild.com

WE HEREBY COMMAND YOU, under CPLR Article 23, Executive Law § 63(12), all
business and excuses being laid aside, to produce the documents and other things described in
Schedule A attached hereto that are in your possession, custody, or control, on the 8th day of

March, 2024 at 9:00 a.m., at the Office of the New York State Attorney General, 28 Liberty

Street, 19th Floor, New York, New York, 10005.

PLEASE TAKE NOTICE that the Attorney General deems the documents demanded

by this Subpoena to be relevant and material to an investigation and inquiry undertaken in the
public interest.

PLEASE TAKE FURTHER NOTICE that failure to deliver the documents directed in
the attached Schedule may subject you to prosecution under CPLR Article 23 and other statutes,
and subject you to penalties and other lawful punishment.

WITNESS, Honorable LETITIA JAMES, Attorney General of the State of New York,
this 23rd day of February, 2024.

By:

Ga herwin

Special Counsel for Reproductive Justice
28 Liberty Street, 19th Floor

New York, New York 10005

Tel: (212) 416-8059
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INSTRUCTIONS AND DEFINITIONS

“Any” shall be construed as “any and all.”

“And/or,” the conjunctions “and” and “or,” shall be construed either disjunctively or
conjunctively as necessary to bring within the scope of the request all responses that might
otherwise be construed to be outside of its scope and are terms of inclusion, not exclusion.

“Communicating” and “communication” means the transmittal of information (in the
form of facts, ideas, inquiries, or otherwise) in writing, by telephone, by facsimile, by electronic
mail (“e-mail”), or other electronic means.

“Concerning” or “relating to” means related to, referring to, pertaining to, concerning,
describing, regarding, evidencing, or constituting the requested subject matter.

“Document” is used herein in the broadest sense of the term and means all records and
other tangible media of expression of whatever nature however and wherever created, produced
or stored (manually, mechanically, electronically or otherwise), including without limitation all
versions whether draft or final, all annotated or nonconforming or other copies, electronic mail
(“e-mail”), instant messages, text messages, Blackberry or other wireless device messages,
voicemail, calendars, date books, appointment books, diaries, books, papers, files, notes,
confirmations, accounts statements, correspondence, memoranda, reports, records, journals,
registers, analyses, plans, manuals, policies, telegrams, faxes, telexes, 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, notices and
summaries, and EMR entries, notes, alerts, messages and other records or communications. Any
non-identical version of a Document constitutes a separate Document within this definition,
including without limitation drafts or copies bearing any notation, edit, comment, marginalia,
underscoring, highlighting, marking, or any other alteration of any kind resulting in any
difference between two or more otherwise identical Documents. In the case of Documents
bearing any notation or other marking made by highlighting ink, the term Document means the
original version bearing the highlighting ink, which original must be produced as opposed to any
copy thereof.

“Employee” and “staff” shall mean any person—past or present—carried on the payroll
of, who works or worked on the GHMC premises, or who receives or received proceeds from
GHMC, either as a salaried or hourly employee, a full-time or part-time employee, a temporary,
probationary, or permanent employee, employee on commission, independent contractor,
student, intern or resident health care provider, or agent.

“EMR” shall mean Electronic Medical Record or Electronic Health Record.

“Person” shall mean any natural person or any legal entity, including, without limitation,
any corporation, company, limited liability company or corporation, partnership, limited
partnership, association, or firm.

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“OCFS” shall mean the New York State Office of Children and Family Services.

“Policies” shall mean any or all of the following: standard operating procedures,
protocols; criteria; guidelines; standards of care; directives; policy statements; “best practices;”
letter templates; form templates; matrices; stipulations in regulatory settlements; opinions; or
other Documents that are consulted or considered by GHMC (and any which GHMC says it is
consulting or considering) in GHMC’s conduct of the duties and activities referred to in this
subpoena.

“SCR” shall mean the New York State Central Register.

“Tested patient” shall mean a pregnant or perinatal or newborn patient subjected to a
toxicology test, and, in the case of a newborn patient, shall also mean the newborn’s parent(s).

“You,” “your,” and “GHMC” shall refer to Garnet Health Medical Center, and includes
any officer, director, employee, partner, corporate parent, subsidiary, affiliate, predecessor
subsidiary or affiliate, successor, expert, agent, or person acting on your behalf, including,
without limitation, Garnet Health.

For the purpose of this Subpoena, the time period applicable to the following requests is
February 23, 2018 to the present (the “Relevant Period”) unless otherwise noted. A request
for a schedule, agreement, policy, or other document for the applicable time period encompasses
any schedule, agreement, policy, or other document, created in, in use, or in effect during any
part of the applicable time period. Production is also required if a specific request pre-dates the
applicable time period.

Each document submitted in compliance herewith shall be numbered consecutively on
the face of the document. Accompanying any production made pursuant to this Subpoena, please
include a cover letter that provides the following: (a) a description of the type and content of
each document produced therewith; (b) the paragraph number(s) of the request to which each
such document is responsive; (c) the identity of the custodian(s) of each such document; (d) the
document control number(s) of each such document; and (e) any requests for which there are no
responsive documents in your control or possession. If any of the requested documents have
already been provided, please identify and re-produce the document(s) in your response pursuant
to the production specifications in Attachments 1 and 2.

If any document the production of which is called for by this Subpoena is withheld, or a
portion of such document is withheld or redacted, for each such document or portion you must
provide the following information in writing on the return date of this Subpoena: (i) the
purported legal ground for withholding the document or portion; (ii) the type of document; (iii)
the general subject matter of the document or portion; (iv) the date, author(s) and recipients(s) of
the document or portion; and (v) such other information as is sufficient to identify the document
or portion for a motion to the Court to compel its production.

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The response to this Subpoena shall be continuing in nature so as to require a
supplemental response in the event that after responding to any individual request, you obtain or
become aware of additional information responsive to any request.

In order for your response to this Subpoena to be complete, the attached statement under
oath entitled “Verification” must be completed and executed on your behalf by the person
supervising compliance with the Subpoena and submitted with the responsive documents.

ELECTRONIC PRODUCTION

Unless otherwise specified and agreed to by Office of Attorney General staff, responsive
documents must be produced in accordance with the instructions in Attachments 1 and 2 to this
subpoena.

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SCHEDULE A

1. Any policies regarding toxicology testing or substance use screening for all patients.

2. Any policies regarding toxicology testing or substance use screening for pregnant or
perinatal or newborn patients.

3. Any internal communications regarding toxicology testing for pregnant or perinatal or
newborn patients.

4. Data or records sufficient to show each individual instance during the Relevant Period in
which GHMC administered a toxicology test to a pregnant or perinatal or newborn
patient. For each individual instance, GHMC’s response must include:

Patient Information

a. A unique identifying number for each tested patient (consistent across any repeat
visits by the same patient, and preferably consistent between the produced data or
records and the EMR);

b. The tested patient’s name;

c. The tested patient’s date of birth;

d. Demographic information, including the payor, ZIP code, gender, race, and
ethnicity of the tested patient;

Toxicology Testing and Substance Use Screening

e. Whether the tested patient was screened for substance use using a validated
screening tool;

f. The toxicology test(s) administered, specifying substance(s) tested for;

g. The toxicology result(s) for each substance tested;

h. Whether the patient provided informed consent for toxicology testing, and, if so,
whether consent was given orally or in writing;

Reporting to Child Protective Services

i. Whether a social worker was involved in the tested patient’s care;

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j. Whether contact was made with OCFS, SCR, or any local child protective
services agency, and if a child protective services agency was contacted, the name
of that agency;

k. Whether any intervention was made to separate the postnatal patient from their
newborn(s) for any period of time following a presumptive positive or confirmed
positive toxicology test result;

l. Whether, after a presumptive positive or confirmed positive toxicology result, the
newborn(s) was held in the hospital for any period of time despite being
medically cleared for discharge (sometimes referred to as a “social hold”);

m. Whether any intervention was made to prevent the postnatal patient from
breastfeeding or chestfeeding their newborn(s);

Substance Use Treatment

n. Whether at the time of toxicology testing the tested patient was receiving or had
received treatment related to a potential substance use disorder, and, if so,
whether GHMC consulted the health care provider that provided such treatment;

o. Whether the tested patient was provided treatment by GHMC for substance use
disorder or provided a referral appointment to substance use treatment prior to
discharge;

i. The name of any substance use treatment provider(s) to which a referral
was made and whether that provider(s) is affiliated with GHMC’s hospital
system or is an external provider;

ii. Whether any follow-up was conducted by GHMC to determine whether
the tested patient received substance use treatment.

The requested records and data may be produced in the form of a spreadsheet.

5. Any medical records for tested patients. Such medical records shall include all entries for
the time period from the birthing patient’s first prenatal encounter to one year after the
birth of their newborn(s), and shall include without limitation all entries and notes entered
by all GHMC providers and staff (e.g., physicians, nurse practitioners, nurses, social
workers, therapists, administrative staff, and reception staff).

6. Any reports or referrals made to, or other communications with, OCFS, SCR, or any local
child protective services agency related to a tested patient’s positive toxicology result.
Such communications shall include those received by GHMC from OCFS, SCR, or any

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local child protective services agency.

7. Any reports and data regularly submitted to local, state, or federal child welfare agencies,
including quarterly reporting to OCFS made pursuant to the Child Abuse Prevention and
Treatment Act (“CAPTA”) and the Comprehensive Addiction and Recovery Act
(“CARA”).

8. Any records and data relating to GHMC’s efforts to train staff, contractors, and/or
vendors in the hospital’s policies and procedures for (a) toxicology testing and substance
use screening for pregnant or perinatal or newborn patients, and (b) reporting to OCFS,
SCR, or any local child protective services agency. GHMC’s response shall include any
written and digital materials created for and provided as part of these trainings, as well as
the dates and attendance logs for all such trainings conducted during the Relevant Period.

9. Any forms and paperwork documenting toxicology testing and substance use screening
for pregnant or perinatal or newborn patients. This includes any forms or questionnaires
used to evaluate whether to administer a toxicology test and those used to document
patient consent, the administration of a test, or test results. GHMC’s response shall
include template forms, paperwork presented to patients, and forms or templates used
internally or externally by the hospital. If the completed forms or paperwork are
documented as part of the EMR, GHMC shall produce the template forms or paperwork
in addition to the medical records requested in No. 5, supra.

10. Any materials distributed to pregnant or perinatal patients regarding (a) toxicology
testing, substance use screening, and reporting to OCFS, SCR, or any local child
protective services agency, and (b) health and lifestyle issues, including but not limited to
fact sheets, pamphlets, brochures, emails, and/or materials distributed to patients
electronically, including without limitation materials distributed through the patient
portal.

11. Any policies and internal communications regarding exceptions to the usual informed
consent requirements for pregnant or perinatal or newborn patients, e.g., so-called
“maternal override” practices, including but not limited to policies addressing when, if
ever, a provider may or must override:

a. A pregnant patient’s refusal of medical treatment, wish to receive treatment, or
preference for a certain treatment over others, based on an interest in the health of
the fetus; or

b. A parent’s refusal of medical treatment, wish to receive treatment, or preference
for a certain treatment over others, made on behalf of the parent’s child.

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12. Any policies and internal communications regarding the practice of preventing the
discharge of a newborn baby who has been medically cleared for discharge, sometimes
referred to as a “social hold.”

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VERIFICATION

This response to the Subpoena of the Attorney General of the State of New York dated
February 23, 2024, including without limitation production of the requested documents, was
prepared and assembled under my personal supervision in accordance with the instructions and
definitions 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 ________, 2024.

_____________________________ Notary Public

My commission expires:_____________________

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ATTACHMENT 1
Electronic Document Production Specifications

Unless otherwise specified and agreed to by the Office of the Attorney General, all
responsive documents must be produced in LexisNexis® Concordance® format in accordance
with the following instructions. Any questions regarding electronic document production should
be directed to the Assistant Attorney General whose telephone number appears on the subpoena.

1. Concordance Production Components. A Concordance production consists of the
following component files, which must be produced in accordance with the specifications
set forth below in Section 7.

A. Native Files. Native format versions of produced documents that are not
redacted, named by their first Bates number.

B. Single-Page Image Files. Individual petrified page images of the produced
documents in tagged image format (“TIF”), with page-level Bates number
endorsements.

C. Extracted or OCR Text Files. Document-level extracted text for each produced
document or document-level optical character recognition (“OCR”) text where
extracted text is not available.

D. Metadata Load File. A delimited text file that lists in columnar format the
required metadata for each produced document.

E. Opticon Load File. A delimited text file that lists the single-page TIF files for
each produced document and defines (i) the relative location of the TIF files on
the production media and (ii) each document break.

2. Production Folder Structure. The production must be organized according to the
following standard folder structure:
 data\ (contains production load files)
 images\ (contains single-page TIF files, with subfolder organization)
\0001, \0002, \0003…
 natives\ (contains native files, with subfolder organization)
\0001, \0002, \0003…
 text\ (contains text files, with subfolder organization)
\0001, \0002, \0003…

3. De-Duplication. You must perform de-duplication of stand-alone documents and email
families against any prior productions pursuant to this or previously related subpoenas
only within each custodian (not across all custodians).

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4. Paper or Scanned Documents. Documents that exist only in paper format must be
scanned to single-page TIF files and OCR’d. The resulting electronic files should be
pursued in Concordance format pursuant to these instructions. You must contact the
Assistant Attorney General whose telephone number appears on the subpoena to discuss
(i) any documents that cannot be scanned, and (ii) how information for scanned
documents should be represented in the metadata load file.

5. Structured Data. Structured data includes but is not limited to relational databases,
transactional data, and xml pages. Spreadsheets are not considered structured data. You
must first speak to the Assistant Attorney General whose telephone number appears on
the subpoena.

A. Relational Databases

1. Database tables should be provided in comma-separated or other
machine-readable, non-proprietary format, with each table in a separate data file.
Each data file must have an accompanying data dictionary that explains the
meaning of each column name and explains the values of any codes used.

2. Dates and numbers must be clearly and consistently formatted and,
where relevant, units of measure should be explained in the data dictionary.

3. Records must contain clear, unique identifiers, and the data
dictionary must include explanations of how the files and records relate to one
another.

6. Media and Encryption. All document sets over 2 GB must be produced on CD, DVD, or
hard-drive media. All production media must be encrypted with a strong password,
which must be delivered independently from the production media. Document sets under
2 GB may be delivered electronically. The OAG offers a secure cloud storage option that
can be set up to receive media on a one-time basis, or the OAG will download media
from the providing parties server.

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7. Use of Search Terms or Predictive Coding. Before using software or technology
(including search terms, predictive coding, de-duplication, or similar technologies) to
identify or eliminate documents, data, or information potentially responsive to this
Request, You must submit a written description of the method(s) proposed to conduct any
part of Your search and obtain the prior consent of the NYOAG to the use of such
methods.
A. For any process that relies on search terms to identify or eliminate documents, the
Company must submit: (a) a list of proposed terms; (b) a tally of all the terms that appear in the
collection and the frequency of each term; (c) a list of stop words and operators for the platform
being used; and, (d) a glossary of industry and company terminology, acronyms, or jargon used.
B. If you employ any process that relies upon technology assisted review, computer
learning, analytics, or predictive coding to identify or eliminate documents, you must disclose
the technology and process to be employed in advance and also include (a) the selection method
and total size of the initial review universe; (b) the selection method employed for training
documents, confirmation that subject-matter experts will be reviewing the seed set and training
rounds; (c) the criteria upon which you will determine that you will stop the process (e.g. if
based on stability, the recall, precision, and confidence-level (or equivalent) statistics); and, (c) a
validation process that allows NYOAG representatives to review statistically-significant random
or selected samples of documents categorized as non-responsive documents by the algorithm.

8. Production File Requirements.

A. Native Files
 Documents that do not contain redacted information must be produced in their
native format.
 The filename of each native file must match the document’s beginning Bates
number (BEGDOC) in the metadata load file and retain the original file
extension.
 For documents produced only in native format, and not additionally as single-
page image files, you must assign a single document-level Bates number and
optionally provide an image file placeholder that states “Document produced
only in native format.”
 The relative paths to all native files on the production media must be listed in
the NATIVEFILE field of the metadata load file.
 Native files that are password-protected must be decrypted prior to conversion
and produced in decrypted form.
 You may be required to supply a software license for proprietary documents
produced only in native format.

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B. Single-Page Image Files (Petrified Page Images)
 Where possible, all produced documents must be converted into single-page
tagged image format (“TIF”) files.
 Image documents that exist only in non-TIF formats must be converted into
TIF files.
 For documents produced only in native format, you may provide a single, TIF
placeholder that states “Document produced only in native format.”
 Each single-page TIF file must be endorsed with a unique Bates number.
 The filename for each single-page TIF file must match the unique page-level
Bates number (or document-level Bates number for documents produced only
in native format).
 Required image file format:
o CCITT Group 4 compression
o 2-Bit black and white
o 300 dpi
o Either .tif or .tiff file extension.
 TIF files must be divided into subfolders containing no more than 5000 files.
Documents should not span multiple subfolders, a document with more than
5000 pages should be kept in a single folder.
C. Extracted or OCR Text Files
 You must produce individual document-level text files containing the full
extracted text for each produced document.
 When extracted text is not available (for instance, for image-only documents)
you must provide individual document-level text files containing the
document’s full OCR text.
 The filename for each text file must match the document’s beginning Bates
number (BEGDOC) listed in the metadata load file.
 Text files must be divided into subfolders containing no more than 5000 files.

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D. Metadata Load File
 Required file format:
o UTF-8
o .dat file extension
o Field delimiter: (ASCII decimal character 20)
o Text Qualifier: þ (ASCII decimal character 254). Multiple value field
delimiter: ; (ASCII decimal character 59)
 The first line of the metadata load file must list all included fields. All
required fields are listed in Attachment 2.
 Fields with no values must be represented by empty columns maintaining
delimiters and qualifiers.
 Note: All documents must have page-level Bates numbering (except
documents produced only in native format, which must be assigned a
document-level Bates number). The metadata load file must list the beginning
and ending Bates numbers (BEGDOC and ENDDOC) for each document.
 Accepted date formats:
o mm/dd/yyyy
o yyyy/mm/dd
o yyyymmdd
 Accepted time formats:
o hh:mm:ss (if not in 24-hour format, you must indicate am/pm)
o hh:mm:ss:mmm
E. Opticon Load File
 Required file format:
o Field delimiter: , (ASCII decimal character 44)
o No Text Qualifier
o .opt file extension
 The comma-delimited Opticon load file must contain the following seven
fields (as indicated below, values for certain fields may be left blank):
o ALIAS or IMAGEKEY – the unique Bates number assigned to each
page of the production.
o VOLUME – this value is optional and may be left blank.
o RELATIVE PATH – the file path to each single-page image file on the
production media.
o DOCUMENT BREAK – defines the first page of a document. The
only possible values for this field are “Y” or blank.
o FOLDER BREAK – defines the first page of a folder. The only
possible values for this field are “Y” or blank.
o BOX BREAK – defines the first page of a box. The only possible
values for this field are “Y” or blank.
o PAGE COUNT – this value is optional and may be left blank.
 Example:
ABC00001,,IMAGES\0001\ABC00001.tif,Y,,,2
ABC00002,,IMAGES\0001\ABC00002.tif,,,,
ABC00003,,IMAGES\0002\ABC00003.tif,Y,,,1
ABC00004,,IMAGES\0002\ABC00004.tif,Y,,,1

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ATTACHMENT 2
Required Fields for Metadata Load File

FIELD NAME FIELD DESCRIPTION FIELD VALUE EXAMPLE1
BEGDOC Bates number assigned to the first page of the ABC0001
document.
ENDDOC Bates number assigned to the last page of the ABC0002
document.
BEGATTACH Bates number assigned to the first page of the ABC0001
parent document in a document family (i.e.,
should be the same as BEGDOC of the parent
document, or PARENTDOC).
ENDATTACH Bates number assigned to the last page of the last ABC0008
child document in a family (i.e., should be the
same as ENDDOC of the last child document).

PARENTDOC BEGDOC of parent document. ABC0001
CHILDDOCS List of BEGDOCs of all child documents, ABC0002; ABC0003; ABC0004…
delimited by ";" when field has multiple values.
COMMENTS Additional document comments, such as
passwords for encrypted files.
NATIVEFILE Relative file path of the native file on the .\Native_File\Folder\...\BEGDOC.ext
production media.
TEXTFILE Relative file path of the plain text file on the .\Text_Folder\Folder\...\BEGDOC.txt
production media.

SOURCE For scanned paper records this should be a Company Name, Department Name,
description of the physical location of the Location, Box Number…
original paper record. For loose electronic files
this should be the name of the file server or
workstation where the files were gathered.
CUSTODIAN Owner of the document or file. Firstname Lastname, Lastname,
Firstname, User Name; Company
Name, Department Name...
FROM Sender of the email. Firstname Lastname < FLastname
@domain >

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Examples represent possible values and not required format unless the field format is specified in Attachment 1.

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TO All to: members or recipients, delimited by ";" Firstname Lastname < FLastname
when field has multiple values. @domain >; Firstname Lastname <
FLastname @domain >; …
CC All cc: members, delimited by ";" when field has Firstname Lastname < FLastname
multiple values. @domain >; Firstname Lastname <
FLastname @domain >; …
BCC All bcc: members, delimited by ";" when field Firstname Lastname < FLastname
has multiple values @domain >; Firstname Lastname <
FLastname @domain >; …
SUBJECT Subject line of the email.
DATERCVD Date and time that an email was received. mm/dd/yyyy, yyyy/mm/dd, or
yyyymmdd; hh:mm:ss AM/PM or
hh:mm:ss
DATESENT Date and time that an email was sent. mm/dd/yyyy, yyyy/mm/dd, or
yyyymmdd; hh:mm:ss AM/PM or
hh:mm:ss
CALBEGDATE Date that a meeting begins. mm/dd/yyyy, yyyy/mm/dd, or
yyyymmdd; hh:mm:ss AM/PM or
hh:mm:ss
CALENDDATE Date that a meeting ends. mm/dd/yyyy, yyyy/mm/dd, or
yyyymmdd; hh:mm:ss AM/PM or
hh:mm:ss
ATTACHMENTS List of filenames of all attachments, delimited by AttachmentFileName.;
";" when field has multiple values. AttachmentFileName.docx;
AttachmentFileName.pdf;…
NUMATTACH Number of attachments.
RECORDTYPE General type of record. IMAGE; LOOSE E-MAIL; E-MAIL;
E-DOC; IMAGE ATTACHMENT;
LOOSE E-MAIL ATTACHMENT; E-
MAIL ATTACHMENT; E-DOC
ATTACHMENT
FOLDERLOC Original folder path of the produced document. Drive:\Folder\...\...\
FILENAME Original filename of the produced document. Filename.ext

DOCEXT Original file extension. html, xls, pdf
DOCTYPE Name of the program that created the produced Adobe Acrobat, Microsoft Word,
document. Microsoft Excel, Corel WordPerfect…
TITLE Document title (if entered).
AUTHOR Name of the document author.
REVISION Number of revisions to a document. 18

2
FILED: ORANGE COUNTY CLERK 03/19/2024 10:11 AM INDEX NO. EF002246-2024
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 03/19/2024

DATECREATED Date and time that a document was created. mm/dd/yyyy, yyyy/mm/dd, or
yyyymmdd; hh:mm:ss AM/PM or
hh:mm:ss
DATEMOD Date and time that a document was last modified. mm/dd/yyyy, yyyy/mm/dd, or
yyyymmdd; hh:mm:ss AM/PM or
hh:mm:ss
FILESIZE Original file size in bytes.
PGCOUNT Number of pages per document.
IMPORTANCE Email priority level if set. Low, Normal, High
MD5HASH MD5 hash value computed from native file (a/k/a
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SHA1HASH SHA1 hash value

MSGINDEX Email message ID
CONVERSATIO Email Conversation Index
NINDEX

Case Info

Judge

David S Zuckerman Track Judge’s New Case

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Document Filed Date

March 19, 2024

Case Filing Date

March 18, 2024

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Exhibit,Appendix: Garnet Health Medical Center v. People Of New York, By Letitia James, New York State Attorney General

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