espada reply to subpoena

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SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ------------------------------------------------------------------------x : THE PEOPLE OF THE STATE OF NEW YORK, : : - against - : Index No. : 400112-10 SOUNDVIEW MANAGEMENT ENTERPRISES : : Defendants. : ------------------------------------------------------------------------x AFFIRMATION OF COUNSEL IN OPPOSITION TO THE NEW YORK ATTORNEY GENERAL’S MOTION TO COMPEL SUBPOENA COMPLIANCE

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Page 1: Espada Reply to Subpoena

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ------------------------------------------------------------------------ x : THE PEOPLE OF THE STATE OF NEW YORK, : : - against - : Index No. : 400112-10 SOUNDVIEW MANAGEMENT ENTERPRISES :

: Defendants. : ------------------------------------------------------------------------ x

AFFIRMATION OF COUNSEL IN OPPOSITION TO THE NEW YORK

ATTORNEY GENERAL’S MOTION TO COMPEL SUBPOENA COMPLIANCE

Page 2: Espada Reply to Subpoena

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PRELIMINARY STATEMENT

In late August 2009, The New York Attorney General’s Office (the “Attorney

General”) served Soundview Management Enterprises, LLC (‘SME”) with a subpoena.

The overbroad and cumbersome subpoena sought more than Twenty (20) categories of

documents dating back more than five years. Since then, SME has produced responsive

documents to the Attorney General on a rolling basis. In addition, on December 21, 2009

prior to the Attorney General filing this motion, Counsel for SME contacted Ms. Darcy

Goddard from the Attorney General Office to discuss this matter. (Exhibit 1; Richard St.

Paul Telephone Records). Counsel’s phone call was never retuned. As of the date of this

filing, SME has completed its document production and the Attorney General has the

responsive documents in its possession. Thus, the Attorney General’s motion is not only

unnecessary but it is moot.

To wit, the Attorney General’s smear campaign, styled as a motion to compel is

full of gratuitous and politically motivated attacks on SME and its principal, Senator

Pedro Espada, Jr. (“Sen. Espada”) and on SME’ s clients, Soundview Healthcare

Network (“Soundview”). These attacks are improper, patently false and have no place in

a motion to compel subpoena compliance. Rather than submit to the Court a

straightforward motion to compel, the Attorney General has engaged in a campaign

intended to smear the reputation of Senator Espada and anyone associated with him.

Equally egregious is the manner in which the Attorney General has pursued its

political agenda by conducting this “inquiry” into SME, Sen. Espada and Soundview. In

an effort to breathe life into its baseless claims the Attorney General has used the media

Page 3: Espada Reply to Subpoena

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as the public relations wing of its office in order to create the perception of wrong doing.

Furthermore, the motion papers were served on the media before Counsel. Counsel had to

receive a copy online and then had to contact the Judge’s chamber in order to receive a

copy of the Order To Show Cause to compel production. To date counsel has not

received a signed copy of the Order.

This is not the first time the Attorney General has abused the legal process to

further its political agenda and smear campaign. Throughout its ‘inquiry” into SME, Sen.

Espada and Soundview, the Attorney General has made a constant practice of serving the

media with papers, whether it be subpoenas or motions, concerning this witch-hunt. This

practice is contrary to the way in which the “Top Cop” of the State of New York should

operate and contrary to New York State’s Civil Procedure laws for service (See articles

enclosed as Exhibit 2). These tactics and constant inflammatory allegations levied by the

Attorney General’s office violate SME’s civil and constitutional rights in that these

tactics of pre-trial publicity can produce prejudice among peers and a public mood in

favor of one party over the other. The Attorney General’s tactics and prosecutorial

misconduct makes this matter ripe for a federal civil rights lawsuit and an impending

protective order/gag order against the Attorney General’s office. This misconduct is

reminiscent of the misguided and politically motivated investigation by District Attorney

Mike Nifong in the 2006 Duke University lacrosse case. Much like the Attorney General

here, Mr. Nifong ignored facts and made numerous inflammatory statements to the

media, resulting in his removal from office. In that same view, the same practice by the

Attorney General here sets a bad precedent and should be condemned by this Court.

Page 4: Espada Reply to Subpoena

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Further, the Attorney General’s motion is complete with tall tales and

unsupported theories meant to create the perception of wrongdoing. The so-called

“factual” background set forth in the Attorney General’s papers, is not only irrelevant on

this motion, but it is fictitious. For example, the Attorney General attacks Soundview,

even though the subpoena at issue is directed to SME. Also, the motion papers fail to

mention that Soundview has maintained transparent operations for nearly Thirty-years

(30) and has opened its books and records to New York State Department of Health, The

U.S. Department of Health and Human Service, the Internal Revenue Service, and over

Fifty (50) HMO’S; and withstood scrutiny from the Joint Commission Accreditation and

Certification which has been acknowledged as the leader in developing the highest

standards for quality and safety in the delivery of health care, and evaluating

organizational performance based on these standards. The Attorney General’s “inquiries”

and public allegations are severely impinging upon Soundview’s ability to deliver on its

mission “to provide high quality and cost effective health care and social services to all

individuals whether or not they have health insurance or the ability to pay for the full cost

of care.”

Similarly, the Attorney General attempts to cast SME’s janitorial service contract

as usurping Soundview’s bid process. SME’s principal has provided Soundview and

other entities with quality services gained over Thirty-years (30) of experience in the

field. Despite having the Soundview’s board minutes, the Attorney General failed to

mention that SME participated in a competitive bid process and that SME submitted the

lowest bid. Yet, the Attorney General implies that SME was chosen because Sen. Espada

owned the entity.

Page 5: Espada Reply to Subpoena

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Lastly, adding to the hype and inflammation of the papers. The Attorney

General’s office makes allegations of campaign finance misdeeds. This is wholly

improper as the Attorney General ’s office has no apparent authority to inquire or pursue

matters involving campaign finance. However, there is a current proposal in New York

State Government to expand the power of the Attorney General ’s office to pursue

matters of campaign finance. However, that day has not come. Accordingly, assuming

these powers is similar to proclaiming yourself Governor without an election.

In conclusion, the reason that the documents were not produced to the Attorney

Generals’ office is because the Attorney General’s office failed to return phone calls from

counsel for SME. Again, SME has now made complete production of documents

responsive the subpoena. Accordingly, the Attorney General’s motion was unnecessary

and is now moot, and should be deemed as such.

STATEMENT OF FACTS

A. Background Of Soundview

The Attorney General’s Office is conducting an investigation into the

Comprehensive Community Development Corporation, a New York State registered and

federally tax-exempt non-profit corporation. Comprehensive Community Development

Corporation consists of multiple healthcare clinics in Bronx County New York operating

under the name “Soundview Healthcare Network” (“Soundview”). Soundview’s

headquarters are located at 731 White Plains Road, Bronx, NY 10473.

Page 6: Espada Reply to Subpoena

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Soundview’s President and Chief Operating Officer is New York State Senator

Pedro Espada, Jr., (“Sen. Espada”). Sen. Espada (at the time Mr. Espada), founded

Soundview in 1978. The decision to start Soundview was made after New York City

failed to bring a promised healthcare clinic to an economically depressed and

underserved area of the Bronx. Rather than accept the City’s refusal to fund the clinic,

Mr. Espada obtained federal grant money and rented the building where the clinic had

been planned. Soundview started taking patients soon thereafter. Since then, Soundview

has grown to include multiple satellite clinics, and records approximately 100,000 patient

visits a year in an area that is economically depressed to this day.

Soundview’s mission “is to provide high quality and cost effective health care and

social services to all individuals whether or not they have health insurance or the ability

to pay for the full cost of care.” Soundview fulfills this mission not only by providing

physical healthcare, mental healthcare, and dental care, but also by promoting healthy

lifestyles and nutrition in the community. For example, Soundview has a full-time

nutritionist on staff to help encourage healthy eating in the community. Soundview has

worked with sponsors to secure places for financially disadvantaged children in a summer

camp that specializes in obesity problems. Responding to the limited availability of

quality fresh fruits and vegetables in the Bronx, Soundview negotiated fruit and vegetable

donations from the Hunt’s Point Market which were distributed at little or no cost at

“farmer’s markets” in the Bronx.1 Soundview has donated Thanksgiving turkeys to

1 Sen. Espada and Soundview are not the only ones to recognize the health problems that come from a lack available fresh fruits and vegetables. In late 2007, New York City Mayor Michael Bloomberg and New York City Council Speaker Christine Quinn announced the “Green Carts” legislation, a “program to phase in fifteen hundred vendors over two years into neighborhoods with low consumption and limited access to fresh fruits and vegetables.” http://www.nyc.gov/portal/site/nycgov/menuitem.c0935b9a57bb4ef3daf2f1c701c789a0/index.jsp?pageID=

Page 7: Espada Reply to Subpoena

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needy families when finances have permitted and has organized senior citizen breakfasts

to teach seniors about the importance of maintaining a healthy diet. Soundview also

organizes community health fairs where citizens receive free screening for diabetes and

hypertension. Soundview has provided computer literacy classes in an effort to close the

technology gap that helps to further isolate an economically disadvantaged community

from upward mobility.

Not only does Soundview provide important healthcare and social services in the

Bronx, it is also a valuable source of jobs, providing employment for approximately 120

people.

In sum, Soundview provides crucial employment, healthcare and social services

to neighborhoods and a population that has been historically underserved and

economically disadvantaged. The current economic crisis has only made Soundview’s

mission more difficult at the same time that the community’s demand for Soundview’s

services have grown.

B. Soundview’s History of Janitorial Services

Like any large organization, Soundview must deal with logistical matters such as

janitorial services. This is especially true because Soundview is a healthcare provider

and properly cleaned premises are a matter of patient safety.

mayor_press_release&catID=1194&doc_name=http%3A%2F%2Fwww.nyc.gov%2Fhtml%2Fom%2Fhtml%2F2007b%2Fpr467-07.html&cc=unused1978&rc=1194&ndi=1

Page 8: Espada Reply to Subpoena

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Community Expansion Development Corporation (“Expansion”) was at one time

a for-profit company owned by Mr. Espada that, prior to 2005, provided janitorial

services to Soundview.

In late 2007, Soundview’s board of directors adopted the recommendation of

Soundview’s executive committee and awarded Soundview’s janitorial contract to

Soundview Management Enterprises LLC (“SME”), effective February 1, 2008. (Exhibit

3; 12/20/07 Soundview Board Meeting Minutes). SME is a for-profit company solely-

owned by Sen. Espada. Sen. Espada disclosed his ownership in SME to Soundview’s

board of directors, a fact reflected in the meeting minutes and the board resolution

awarding SME the Soundview janitorial contract. Id. Sen. Espada also disclosed his

ownership of SME in his Senate disclosure statements.

Another benefit of outsourcing janitorial services to SME, was that SME could

begin an internship program that included as one of its goals, reintegrating citizens

released from prison back into the community. Released-prisoner reintegration has long

been a goal of Sen. Espada, as – like Soundview – it contributes to the health of the

surrounding community.

Pursuant to the terms of the contract approved by Soundview’s board of directors,

SME receives $396,000 per year for providing janitorial services to Soundview. (Exhibit

4; Soundview-SME Janitorial Contract).

In mid-2007, prior to awarding the janitorial contract to SME, Soundview

solicited competitive bids for its janitorial needs. Coverall Cleaning Concepts wanted

$745,980 per year to do the job. (Exhibit 5). Top Talent Maintenance wanted $620,00

Page 9: Espada Reply to Subpoena

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per year. (Exhibit 6). B.B.S. Contractor, L.L.C. was the low bidder at $422,870 per

annum. (Exhibit 7).

Soundview’s $396,000 janitorial contract with SME was lower than all of the bids

that were solicited in 2007.

Not only does SME provide for Soundview’s janitorial needs at very competitive

rates, it provides superior service by going beyond what is required under its contract

with Soundview. For example, SME opens and closes the Soundview premises, assists in

security duties, does maintenance work, completes minor construction, and provides

messenger and moving services. In contrast, the bids Soundview received from outside

companies were for basic janitorial services only, despite demanding a higher price than

what SME charged Soundview.

C. Attorney General Investigation of Soundview

The Attorney General has been investigating Soundview for at least nine months,

issuing numerous subpoenas and “demand letters,” including the following:

1. 5/11/09 Attorney General Subpoena to Soundview (Exhibit 8);

2. 7/21/09 Attorney General Subpoena to Soundview (Exhibit 9);

3. 8/25/09 Attorney General Subpoena to SME (Exhibit 10);

4. 8/28/09 Attorney General Subpoena to Regal Realty Services, LLC

(Exhibit 11);

5. 8/31/09 Attorney General Subpoena to Soundview (Exhibit 12);

Page 10: Espada Reply to Subpoena

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6. 10/2/09 Attorney General Demand Letter to Soundview (Exhibit 13);

7. 11/6/09 Attorney General Demand Letter to Soundview (Exhibit 14); and

8. 11/17/09 Attorney General Subpoena to Soundview (Exhibit 15).

The Attorney General’s subpoenas and demand letters are extremely broad, often

requiring Soundview’s attorneys to negotiate with the Attorney General to limit the scope

of the documents sought. Notwithstanding, counsel for Soundview has made at least 19

separate document productions totaling over fifty-thousand pages.

Compliance with the Attorney General subpoenas has required a tremendous

amount of time and resources from Soundview’s staff and from Soundview’s attorneys.

While Soundview has not calculated the cost of employee time spent on subpoena

compliance, between attorney’s fees and employee time, the Attorney General’s

investigation is severely impinging upon Soundview’s ability to deliver on its mission “to

provide high quality and cost effective health care and social services to all individuals

whether or not they have health insurance or the ability to pay for the full cost of care.”

Despite the history of substantial compliance by Soundview’s attorneys with the

Attorney General’s investigation, and repeated offers to sit down and meet, the Attorney

General never spoke to Soundview’s attorneys about issues regarding SME’s subpoena

compliance. The Attorney General claims they never received any communication from

counsel after SME’s last document production on September 23, 2009. (1/13/09 Motion

to Compel, pp. 14-16). However, the Attorney General neglects to mention that counsel

called Assistant Attorney General Darcy Goddard on December 21, 2009 and left a

message for her to return the call. (Exhibit 1; Richard St. Paul Telephone Records).

Page 11: Espada Reply to Subpoena

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Notwithstanding Counsel’s efforts to reach out and discuss the ongoing production of

SME’s documents, the Attorney General filed this Motion to Compel with the Court on

January 13, 2009, without ever returning Counsel’s call.

ARGUMENT

A. The Attorney General’s Allegations Of Wrongdoing By Espada

Are: (1) Gratuitous & Politically Motivated; and (2) Wrong.

A proper motion to compel compliance with a subpoena need only contain three

elements: (1) A statement of the statutory authority under which the subpoena was

issued; (2) a certification that a valid subpoena was issued pursuant to an ongoing

investigation; and (3) a statement that the subpoenaed party refused to comply with a

validly issued subpoena. There is no need to include details concerning the investigation

or allegations of wrongdoing that are being investigated.

The Attorney General, however, did just that. The Attorney General’s Motion to

Compel is seventeen pages long – excluding exhibits – consisting of thirty-eight

numbered paragraphs. Of those seventeen pages, more than half consist of gratuitous

allegations of wrongdoing by Sen. Espada, SME, and Soundview in what are apparently

politically motivated attacks. Furthermore, the allegations of wrongdoing are at best

misleading.

The attacks on Sen. Espada are presented in the Motion to Compel under the

heading of Attorney General’s “Factual Predicate for the Subpoena to [SME].” This is

Page 12: Espada Reply to Subpoena

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where the Attorney General purports to explain why they have reason to subpoena SME,

even though SME has: (1) never moved to quash the Attorney General’s subpoena; and

(2) never refused to comply with the Attorney General’s subpoena.

Thus, for example, The Attorney General sets forth detailed allegations that

Soundview was overpaying for janitorial services in order to funnel money to Sen.

Espada’s campaign.

But, in its rush to cast SME’s contract with Soundview in a sinister light, the

Attorney General engages in what is at best a reckless distortion. The Attorney General

claims that the Soundview board of director’s minutes:

“. . . fail to provide any information that explain: (i) why the purported costs of maintenance services rose from $270,000.00 annually in 2005 to $396,000.00 annually in 2008; (ii) why the contract for maintenance services was taken away from Expansion, a wholly-owned affiliate of Soundview, and given to outside vendor Espada Management Company, a private company of which Mr. Espada is a principal; (iii) how such a move, i.e., from essentially in-house services to a private outside vendor, would save money for, or in any way benefit, Soundview; or (iv) why Espada Management Company is now receiving monies, by contract or by "rent" collection, that previously went to Expansion or Soundview (directly or through the wholly-owned Expansion).” (Motion to Compel, p. 9).

This recitation misleadingly omits the following critical fact: that the switch from

Expansion to SME did not cost Soundview an additional $126,000 – in fact the SME

contract was for $56,000 less than what Expansion received in 2007.2

2 Furthermore, as the Attorney General acknowledges elsewhere in its motion to compel, the amount SME received from Soundview in 2008 was approximately $341,000 in 2008 (Motion to Compel, p. 10). This is over $96,000 less than what Soundview paid Expansion for the same services in 2007. While, SME did not provide Janitorial services for Soundview for all of 2008 – Expansion provided those services in January of 2008 – Soundview still saved over $67,500 in 2008 by making the switch to SME.

Page 13: Espada Reply to Subpoena

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Additionally, the Motion to Compel insinuates that SME makes outsize profits

because it has salary and wage costs of only $180,000 while earning $396,000 pursuant

to its contract with Soundview. (Motion to Compel, pp. 10-11). But the Attorney

General ignores the business reality that there are myriad expenses beyond just payroll

that are involved with running a business. For example, supplies, travel, workers

compensation insurance, storage, etc. The Attorney General argues that because: (1)

SME is owned by Sen. Espada; and (2) SME makes a profit, there must be something

improper. However, the Attorney General can point to no law prohibiting a non-profit

corporation from contracting with a for-profit corporation. And, as the Attorney General

knows from documents produced by Soundview, Sen. Espada’s ownership of SME was

disclosed to Soundview’s board of directors which in turn approved the contract with

SME. (Exhibit 3; 12/20/07 Soundview Board Meeting Minutes).

The Attorney General’s baseless accusations continue with their assertion that

SME made campaign contributions to Sen. Espada’s election campaign in cash and

employee time, without disclosing those contributions as required by the campaign laws.

(Motion to Compel, pp. 13-14). The Attorney General adds that Mr. Espada never

formed a campaign committee, a necessary prerequisite for filing notice of SME’s

campaign contributions. (Id. at 13). Finally, the Attorney General mentions that Sen.

Espada’s political action committee “Espada for the People,” never filed disclosures of

SME’s campaign contributions.

Firstly, the Attorney General knows that political action committees do not make

disclosures of campaign expenditures made on behalf of third-parties such as SME.

Political action committees only make disclosures of their own campaign contributions.

Page 14: Espada Reply to Subpoena

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The fact that Espada for the People did not disclose SME’s campaign contributions is a

non-issue because there is no mechanism for a political action committee to make such a

disclosure to the State Board of Elections. Secondly, the Attorney General neglected to

mention a crucial piece of information; Espada for the People was mistakenly was

formed as political action committee instead of a campaign committee. As a result of this

administrative error – which Espada for the People has been trying to rectify – the State

Board of Elections refused to accept the filings that would have disclosed SME’s

expenditures on behalf of Sen. Espada’s campaign. (Exhibit 16; Espada for the People

Correspondence with the State Board of Elections).

Instead of revealing that Espada for the People tried, but was unable, to file the

campaign disclosures regarding SME, the Attorney General throws out the incendiary

charges that SME “sought to evade the campaign laws” by “disguising and failing to

disclose its contributions to Sen. Espada’s campaign.” (Motion to Compel, pp. 13).

When making its accusations, the Attorney General ignores the fact that SME has no

disclosure obligation to the State Board of Elections. Nor can the Attorney General point

to one piece of evidence to suggest that SME’s campaign contributions were in excess of

the amounts allowed by law. Nevertheless, the Attorney General sets forth a laundry list

of election and criminal laws which SME, “its principals, officers, and directors may be

liable for.” (Motion to Compel, p. 13). These baseless accusations serve no other purpose

than to smear Sen. Espada, which is demonstrated by the fact that the Attorney General’s

Motion to Compel was released to the media before ever being sent to the attorneys for

SME or Soundview.

Page 15: Espada Reply to Subpoena

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As a parting shot in the section of the Motion to Compel entitled “factual

predicate for the subpoena [to SME]” – the Attorney General makes one final accusation

against Soundview and Sen. Espada. The Attorney General claims that it “appears” that

the officers and directors of Soundview may have violated their fiduciary obligations to

Soundview. Clearly this is not a “fact” supporting the issuance of a subpoena. It is yet

another accusation of wrongdoing against Mr. Espada and Soundview that is designed to

smear instead of elucidate the Court on the reasons why the Motion to Compel is

necessary.

The accusations of wrongdoing in the Attorney General’s motion are completely

extraneous to the purported necessity for the Motion to Compel; that the Attorney

General has issued a valid subpoena which has allegedly not been complied with. One

can only wonder if the inclusion of the extraneous accusations in the Motion to Compel –

so conveniently released to the press before being served on the parties involved – might

have something to do with the political aspirations of individuals in the Attorney General

office, especially as certain statewide elections are coming up. That might explain why

the Attorney General’s Motion to Compel reads more like an accusatory instrument than

the request for relief that it purports to be. One hopes that explanation is not correct.

B. The Attorney General’s Motion Was Unnecessary and is Moot.

The Attorney General Motion to Compel was unnecessary and is moot because:

(1) SME promptly began complying with the Attorney General’s subpoena; (2) SME was

Page 16: Espada Reply to Subpoena

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continuing to comply with the subpoena; and (3) SME has now complied with the

Subpoena.

The Attorney General’s subpoena to SME was served on August 25, 2009.

(Exhibit 10). Shortly thereafter, SME retained Counsel, and Counsel promptly made the

first of SME’s document productions on September 11, 2009. (Exhibit 17; 9/11/09

Richard St. Paul Letter to AAG Darcy Goddard). This was followed by yet another SME

document production on September 24, 2009, accompanied by a letter from Counsel

advising the Attorney General that: “. . . a search of other documents relevant to the

subpoena is on going [sic] and will be provided expeditiously upon review.” (Exhibit 18;

9/21/09 Richard St. Paul Letter to AAG Darcy Goddard). So as of late September 2009,

SME had already made two document productions to the Attorney General and indicated

that it was actively engaged in continued compliance with the Attorney General’s

subpoena.

Over the fall of 2009, SME continued to search for and review documents that

might be responsive to the Attorney General’s subpoena. Unfortunately, this process did

not go as quickly as SME or Sen. Espada would have hoped, in large part because Sen.

Espada was extremely busy in Albany for the normal and extraordinary legislative

sessions being held. Despite the delay, compliance efforts have continued, and contrary

to the Attorney General’s assertion in its Motion to Compel that its calls and letters were

not responded to (Motion to Compel, p. 16), Counsel reached out to AAG Goddard to

discuss subpoena compliance issues on December 21, 2009. (Exhibit 1; Richard St. Paul

Telephone Records). Unfortunately, the Attorney General never returned Counsel’s call,

as this would have eliminated the Attorney General’s mistaken perception that this

Page 17: Espada Reply to Subpoena

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Motion to Compel was necessary. (of course, that would have also deprived the Attorney

General of a platform to make incendiary accusations against Sen. Espada).

Finally, as it has been preparing to do all along, SME is producing the vast

majority – if not all – of the documents that are responsive to the Attorney General’s

subpoena. The documents are being produced to the Attorney General simultaneously

with the service of this reply affirmation to the Motion to Compel. Furthermore, SME

will continue to review its files and turn over any additional responsive material that is

located. Accordingly, SME now stands in complete compliance with the subpoena,

rendering the Attorney General’s Motion to Compel moot.

Page 18: Espada Reply to Subpoena

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CONCLUSION

For the reasons set forth above, the respondent respectfully requests that this

Court should deny the Attorney General’s motion to compel the respondent to comply

with the subpoena duces tecum served on the respondent on August 25, 2009.

Respectfully submitted

___________________________ Richard E. St. Paul, Esq. 211 E. Main St., Suite 268 New Rochelle, NY 10801 Attorney for Respondent Soundview Management Enterprises, LLC. Dated: February 1, 2010

Page 19: Espada Reply to Subpoena

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Page 22: Espada Reply to Subpoena

EXHIBIT 2

Page 23: Espada Reply to Subpoena

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Page 24: Espada Reply to Subpoena

Cuo:ß"R~ewing Espada Son's New State Senate Gig (Updated) Page 1 of 1

~wcY~ G§ PRlNTTHIS

Cuomo Reviewing EspadaSon's New State SenateGig (Updated)

. 8/12/09 at 3:50 PM

It might have been shameless and politically stupid, but did Senate Democrats break the law whenthey create(i-~ $1.Q,OOO-a-yeai:.!iill-tcure for the son of coup leader Pedro Espada? That's thequestion before Attorney General Andrew Cuomo, according to a high-raning official in hisoffice. "The attorney general's offce has been considering the legality of the appointment since itfirst came to light on Monday. We're considering very closely the legal issues related to thehiring~" the offcial told New York. Earlier today, a Republican candidate for governor, RickLazio, called on Cuomo to investigate the Senate's hiring of Espada's son~ Pedro G. Espada, a

fonner City Council member and assemblyman, as "deputy director of intergovernentalrelations. II The Cuomo aide said state lawyers are tring to determine if Senator Espada violatedthe Public Officers Law, which prohibits legislators from engaging in nepotism_ The offce mayneed a referral from another body, lie the Legislative Ethics Commission, according to theoffciaL.

Update: We hear from a Senate source that Pedro G. Espada wil resign. More on that when wecan confnn it.Update 7:30pm: The La~1 is reportg that he's "quitting."Update 8pm:: A spokesperson for Senate Democrats confirms to Daily Intel that Pedro G. Espadawil be resignng tomorrow.

By: Jacob G-ar~li_m.a.n

Find this ..rtide at;

hUp:/Iwww.nymag.comldallylintelI200910alcuomo_fevlewlng_e6pada_sons_ne .hlml

D Chec~ the box 10 Include the list of IIhks referenced In the artIcle.

Copyright 0 New York Magazine Holdings LLC. All Rights Reserved.t;Al 'l" ¡'~,.' .

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Page 25: Espada Reply to Subpoena

Page i of 1

L Print Current Page J

101 OWl NS.com

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Posted: Thursday, 07 January 2010 2:09PM

Cuomo Subpoenas Sen. Espada, New York Senate-__~__-__.._.._r-_~____~~__.__._._____._.__.____._.__.._~....___.._..._.......__.......h.

~ALBANY, N.Y. (API 1010 WINS) -- Attorney General Andrew Cuomo hassubpoenaed phone and e-mail records and other documents in his investigationof state Senate Majority Leader Pedro Espada, Espada said Thursday.

Espada said he will fully cooperate with Wednesday's subpoena seekingrecords held by him, his Bronx health clinic, and the Democrat-led Senate.Cuomo has been probing state grants provided to the Soundview Health CareNetwork, a Bronx clinic for the poor founded by Espada.

The Democratic senator saId he suspects some political motivation behind thesubpoena, which was issued an hour before Gov. David Paterson's State of theState address Wednesday, when he railed against corruption in Albany andcalled for reforms. Cuomo is widely believed to be planning a run for governor.

Cuomo's offce wouldn't comment.

"It concerns me that anyone would want to play politics with thIs issue that isserIous," Espada said Thursday, "I take ethics measures seriously."

Espada shot back at Cuomo for accepting campaign contributions from thelawyers of people and corporations he has investigated in his probes of Wall Street. Cuomo has voluntarily refused toaccept donations from targets but accepts cash from their hired lawyers, which is legal.

Cuomo's offce and the Senate deny leaking news of the subpoena.

Espada said he wil provide any documents asked of him In the probe and denied any wrongdoing in running the clinic andin his job as a lawmaker who can help direct state grants. He has helped secure more than $1 million In grants for the clinicand other community service groups with which he has been Involved.

TM & Copyright 2010 CBS Radio Inc. and its relevant subsidiaries. CBS RADIO & EYE Logo TM & Copyright 2010 CBSBroadcastIng Inc, Used under license. All Rights Reserved, ThIs material may not be published, broadcast. rewritten, orredistributed. TheAssociated Press contributed to this report.

r Print Current Page . J

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Page 26: Espada Reply to Subpoena

WX: AU Cuomo Subpoenas Espada Documents (2010-01-07) Page 1 of2

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AG Cuomo Subpoenas Espada Documents ~+.. SH'Ati( 'JJ.I)~)

AP (2Q10.01.07): ALBANY. NY (WXXI). Attorney GonQral Andrew Cuomo has subpoenaod phonG and e-mail records and othar documents In

. his investigation of state Senate Majority Leader Pedro Espada, Espada said Thursday.

. Espada said lie will fully cooperate with Wednesday's subpoena seeking records held by him, his Bronx health clinic, andthe Oemocrat-Ied Senate. Cuomo has been probing slate granls provided to the Souridview Health Care Network, EI Bronx

. clinic for the poor founded by Espada.

The DemocratIc senator said he suspects some poliical motivation behind the lalest subpoena In a probe that's been

: under way for more than six months. The subpoenii was Issued an tiour before Gov. David Paterson's Stato of llie Slate: addres5 Wednesday, when he railed against corruption in Albany and called for reforms, Cuomo 15 widely believed to be: planning a run for governor.

: Cuomo.s offce wouldn't comment.

.: "Ii concerns me thaI anyone would wanl to piay politics wIth this Issue Ihal Is serIous:' Espada s¡ild ThUTiday. ..i take 8thics: measures sQrlously.",

Espada shot back at Cuomo for accpting campaign contributions from the lawyers of people and corpor~tlons he hasInve5tigated in his probes of Wall Sireet, Cuomo has voluntarily refused to accept donations from targets but accepts cesh

from lIielr hired lawyers. which Is legal.

Cuomo's offiCè and the SGnate deny leaking news or the SUbpoena.

. Espada said tie will provide any documents aslced of him in the probe and denied any wrongdoing In running the clinic and

. In hls job 015 e lawmaker who can help direct slale grants. He has helped Eecure more Ihan $1 million In grants for the clinic

. and olher community service groups with which he has been Involved, ii copy~gnt 2010, Y\XI

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Page 27: Espada Reply to Subpoena

WXXl: Atì Cuomo Subpoenas Espada Documents (2010-01-07)

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Page 28: Espada Reply to Subpoena

Sen.-P.cdro'Espada hounded by questons on ethcs and residency Page 1 of2

NYDoîlyNcws.com

DAILYNEW-SSen. Pedro Espada hounded by questions on ethics and residencyBY David Sallonstall

DAILY NEWS SENIOR CORR~SPONDENT

Wednesday, June 10th 2009, 2:46 AM

They call him the Bronx's "Teflon pol" for good reason - nothing ever seems to stick to state Sen. Pedro Espada Jr,except maybe the whiff of trouble.

Espada, the Bronx Democrat whose defection allowed Republicans to retake the state Senate this week, hasweathered a litany of ethical allegations over the years ~ a list that only seemed to grow Tuesday.

He stands accused of failing to file some 41 campaign reports since 2002, making It impossible to know how heraises, and spends, his campaign cash, officials say.

Stale Attorney General Andrew Cuomo is investigating whether Espada used a nonprofi he controls - Sou/ldviewHealth Clinic - as a personal piggy bank for his campaigns.

That's the same Soundview where in 2005, six employees (but not Espada) were convicted of misusing the clinic'staxpayer funds to aid campaigns for him and his son.

Adding a new chapter, aides to deposed Senate Majority Leader Malcolm Smith all but accused Espada on Tuesdayof creating two new nonprofits - boUi with ties to Soundview - as a way to rake in more taxpayer dollars.

Finally, in what many regard as the icing on the cake, the Bronx district attorney is investigating allegations thatEspada doesn't even live in his Bronx district. but instead beds down in leafy Mamaroneck, in Westchester County,

"I have never seen the man," said Erin Cicalese, a neighbor of a Bronx condo listed under Espada's name in BedfordPark. A reporter who rang Espada's buzzer was told only to "get out of the lobby" by an unidentified male voice,

And don't try finding Espada at 400 E. Fordham Road, which is listed as his district offce, It's a vacant shell of aspace.

"It will be here, but It's not here yet," explained a workman at the address Tuesday, some seven moriths after Espadawas elected to his seat.

Espada. who as temporary Senate president is now next in line for the governorship if anything happens to Gov.Paterson, denied all Tuesday to the Daily News.

He is working with the Board of Elections to resolve past campaign fiing issues, his lawyer said.

If Cuomo is investigating his ties to Soundview, the attorney general has yet to notify him, Espada saìd.

He never got any money for his new nonprofrts from Smith, who Is now just retaliating for being deposed, Espadasaid.

And as for his house in Mamaroneck, where Espada registers his family's cars and is often seen coming and going,"Pedro Espada has a second horne in Mamaroneck, (but) ¡live in the Bronx," Espada said, referring to himself in thethird person.

"I did not take a vow of povert," he added of the white-picket-fenced home on a quiet street. "and I represent mydistrict well."

Cicalese and others in what should be Espada's Bronx neighborhood question the latter assertion. They believe that ifEspada actually lived in his Bedford Park condo, maybe he'd do something to improve noise pollution, mass transit orother pressing neighborhood issues.

As for his latest Albany power grab, they could not be less shocked.

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Page 29: Espada Reply to Subpoena

Sen. -Pedro Espada hounded by questions on ethcs and residency Page 2 of2

"I wish I was surprised," said Cicalese, "But from day one he has just seemed to be in it for power and notoriety forhimself, rather tlian making actual changes to benefit the residents of the Bronx,"

dsaltonstall(§nydailynews, com

With Christine Roberts and Sam Goldsmith

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Page 30: Espada Reply to Subpoena

http://www.nydailynews.comlnews/2009/05/11/2009-05-11~attomey ~enerai_ andrew _Cll... Page 1 of i

't"Yaí!News.t:oni

DAILY-NEWSAtton1ey GeneralAndrew Cuomo eyeingPedro Espada Jf., PeterRiveraBY Barbara RossDAILY NEWS STAFF WRI-rER

Sunday, May 10th 20. 9:41 PM

State Attorney General Andrew Cuomo wilinvestigate whether two Bronx lawmakersused nonprofit groups they control in orderto dance around, campaign laws,

Responding to Sunday's Daily News IlStateof Shame" report, Cuomo said he willscrutinize the relationships state Sen. PedroEspada Jr. and Assemblyman Peter Riverahave with separate non-profit groupsj asource told The News,

State probers are poised to:

- F oeus on employees of the Soundviewhealth clinic Espada runs in the Bronx, whowere convicted of using clinic resources tobenefit Espada's campaigns.

- Question whether Rivera's campaigns

Get Morning Home Delivery of the Daily News for up to 70% off.Call (888) 393-3760

illegally benefited from the NeighborhoodEnhancement for Training Services. Hesteered $1.3 milion in taxpayer money tothe group, where his son and top politicalaides worked.

The NETS bought and renovated one now-empty building, but it remains a mysterywhere the bulk of the public money went.

Both Democratic politicians insist they'vedone nothing wrong.

At least six Bronx politicians are underinvestigation for misusing public money orshady real estate deals.

Soundview paid the legal bills of fiveemployees convicted of working onEspada's campaigns while on the clinic'sdime. The clinic was allowed to cover thelegal bills, as long as the employees paid itback.

Espada insists the employees refunded theclinic for the legal bills. Cuomo plans toorder an audit to determine if Espada istell ng the truth.

bross~nydailynews.com

Get Health Insurance As Lo as $49/mo-i

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Page 31: Espada Reply to Subpoena

Em~vyeçs:- Sen. Espada Pays Some At His Health Clubs $1.87 An Hour - wcbst.com

:ealured SlIlleahows

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Jsn 28.2010 6:20 ~rn US/EastBm

Page 1 of2

Employees: Espada Pays Some $1.87 An HourCBS 2 Has Learned How Powerfl Senate Maiority Leader Has Allegedly Ignored Minimum Wage LawsAt His Health Clubs

NEW YORK (cas) - Can yoU ImQglne trying to live off a salary gf loss tlan $2 an hour?

Embal1ecl Bron.x Sen. Pedro EspadQ 1$ again under Investigation. This lime he's accuaed of luring Impovl3rlshad

membem 01 hla communit to work ss Jan~onl at his heallh ollnll:, and paying them way below minimum wege,ReportingM:i,daKr:niar Oh the hypoi;rlsy,

Ell):adll went 10 an upstate duck farm raeantiy to mke up thii Cluse or m1griint workers and demahd thay got fair pay iind goodlfalmonl

"Wat YOU're doing heiiis absoiuteiy crlmlnel," Espada saId.

Pity thiit he appamntiy dOiiSn'1 foel tha sam a way about paoplo working liB jiinllors at Soundvlaw Health Cirnl~. whIch cspade

owns.

CaS i "HD has learnad IMI II company he controls that ~rovldes custodlel services at SoundvI9w was apparentlY running a shamIntemshlp ptogmni whare worksnl ric9/vcd no initrilng and wel9 paid drametlcally below mlrilmum wBga.

CBS 2 He: "How much were you palcI?"

Carios Gon::Ble::: "I was paid 3;150,"

T~BI's $1 SO for two weeks work - BO heum al $1.87 an hour, Tne stale nilnlmum wege Is $7.25,

Gonzalez is one of el)out 40 paopla report9dly sucked Into lhe program with grandiose piomls~s -r;OOd tmlnlng and a good Job,

One psmon CBS 2 HD spOke wlt~ WBS also an Intem. but wBS sO 9f1id of cSpiids Wet the pemon asked to be dlsr¡ulsed.

"We have no time of more tMn our luncl ~ma," the pernon sBld, "If we even lake a IIlte flva-mlnuta biiak off. the supervisor goes'You Blanding away? You standlng up? 'Ny you standIng Up? Find something to dol" We wett puShed."

'Nat aboul thu promised Imlnlng?

"All she had lluQht me wes keep the bu~kat strol9~t when you eii1111ng It up with wal1r," Goriialei: $eld, adding thaI ha was

stun nad when they dldo't teach him snythl ng, "I was shocked. I meiin I thought I was going theii to get pre~pod and II was like I

worked fot nothing."

cas 2 HD: "Old anybody show you how 10 do anything?"

Inter": "No."

cas 2 HD: "Nevsr?'

Inlarn "Never."

cas 2 HD: "Old yoU foel thBI that was right?'

Intem: "No, I didn't faallt wes right badlu:iO lit times tha Bupervlsor would gel on me to soy you didn't do this good, you didn't do

t~ls good, you know. end I asked, well you didn't show ma how to do It, do enylhlng."

The Intems sall:l Espede's son. Pedro G. Espada, I'MS tha program. Ha and tw othar Soundview employees hava been

5ubpoeneeid by stam Alliiy Gonersl Andre Cuomo 10 anSwer questions about the Intemshlps and potentlø11iibor la violations,

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New Yori Attorney GerieralAndttw Cuomo Is gellngphone end a-mall recordsand other documents In hisInvesllgatlon of staID SenateMajority LBadiir PedroEspada, ~Ictured hem,nysonatc.goltRelated Slideshows..~.~~~ia)¡...¡¿t!'ê .

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(1/14/2010j

htt;/ /wcbstv .comlwlitics/pedro.espada.minimum.2.1448407 .htm998-~ 8l0/010'd lEE-! OL98-918 ZLZ À3N~V8 H!I~S N~O'VS-WOJ~

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Page 32: Espada Reply to Subpoena

Employee-s; Sen. Espada Pays Some At His Health Clubs $1.87 An Hour - wcbstv.com Page 2 of2

SeMlor Espada haS repeatedly aald ha has done nothIng wrong and iiilhe Cuomo probe Is nothing but a witch hunt.

lata Menday Sen. Espada claimed the program la for people who have hId trouble with tha law and alO $ee~lng a eeoond chance.

E~p~d~. CSS :2 I~D Spar

Ovm Fundr.i~i:r 'OmIBBlens'

(71:2317,009)

He Said tha money they got WB8 tor linspor1iiflon and lunch.

.. : Follow' .

~2HD"Tlon~

Espada Cle3nB Up On PerkBarral Spending Front

(7/17/2009)

CBS 2 Uncover: AllegedEBpada Campaign Viol"tloM

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Page 33: Espada Reply to Subpoena

Espada Holds Cour in Loft,New Offce Page 2 of?

Sl1-stainal:ÚJitY I More".,.

Jatuar 28, 2010

This is th~ print preview:J~~ç;.k tQ normal vi,e:,))

E.spad_R_,H91ds .._C ourt jll-..L(Jrty,_N.~w_._QffiçeI BTo.1L~, N.ç!y,~_N~twork

Posted: 09- 3-09 06: 18 PMIi, ~

LLikc::~-itI Qon't Like It

Read More; Espada, N~yyY_OIk N~ws

ßNN""--'''''..c "1"'"11.n 1..."r-...I....-1~. ::.:.:~'~...

BronJi New Netork

Pedro Espada Jr. eats biscotti at his new district office near Fordham Road

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Page 34: Espada Reply to Subpoena

Espada Holds Cour in Loft New Offce Page 3 of?

Pedro Espada Jr.'s new district offce, eight months in the making, sits seven floors above the street in a swankoffce building near Fordham Road. irs beautiful, New carpeting, new paint job. Giant photos of thecontroversial Bronx State Senator adorn the back walL. One shows Espada wearing a suit and over-sized redboxing gloves.

It's a fitting image because the pugnacious Espada - his rîngtone is "Eye of the Tiger," a song made famous in

the "Rocky" films - literally fought his way into this offce, forcing a leadership struggle between political partiesby offring his allegiance to both Republicans and Democrats in exchange for what he calls long-neededSenate reform. After a month of gridlock, accusations and headlines, Espada emerged victorious, for the timebeing.

He managed to secure a position as the Democratic majority leader, a beefed up staff and two district offices,including the one on Fordham Road and another he says wil open someday on Bainbridge Avenue inNorwood.

But Espada's victories have come at a price.

He's facing increased criticism and scrutiny on a number of levels. The Bronx District Attorney is investigatingwhether Espada's primary residence is' actually in the Bronx. The Attorney General Is looking into whether heused his healthcare nonprofit for political purposes as well as if he lied about whether he lied on grant heapplied for with the state Health Department.

Local housing advocates say he turned their back on them regarding a series of tighter rent regulation laws thathe ignored as chairman ofthe senate's housing committee. In early August. after Espada negotiated his newmajority leader position, his son was hired for a specially created $120,OOO-a-year job in the State Senate andthen fired days later amid accusations of nepotism and the fact that he wasn't actually showing up to the post.

On Monday, Espada fired his deputy chief of staff after a NY Times reporter told him that the new hire had along, troubled history as a building manager. On top of that, the new Bronx Chamber of Commerce recentlyturned down nearly $2 milion in member item (discretionary) funding from Espada, who is now scrambling tofind other groups to fund with the money.

Earlier today, Espada invited the media to check out his new digs and talk about anything and everything. Hespent much of the hour and a half defending his actions and thwarting allegations of misconduct.

He called the investigations "poiitícally motivated" and adds that he's been under some kind of investigation for15 years and has not once been convicted of any wrongdoing, (Though he has been reprimanded and finedand three of his employees were sent to prison and then rehired.)

Espada went to great lengths to dispel the notion that he's in the pockets of the landlords .and big developerswho have contributed tens of thousands of dollars to his campaign coffrs. (The money he's received fromlandlords and developers pales In comparison to his colleagues, he said,) He does not support the tightening ofrent regulations, something landlords adamantly oppose, that would protect tenants, including the repeal ofvacancy decontrol, ~ hot button issue that local tenant advocates say would protect hundreds of thousands ofaffrdable housirfg units in the city. Instead, Espada said he wants to focus on creating more incentives fordevelopers to construct affordable housing.

As for the nearly $2 milion in discretionary funding, which Espada said he originally wanted to give to twonewly created nonprofit groups headed by executies at his Soundview Health Care Network, the senator saidhis staff is now researching other groups to fund.

Since February, Espada has been trying to secure this offce space ili the Fordham Plaza building. He saidSenate Democratic leaders were holding up the funding for it - he says it costs around $3,500 a month -- inanother politcally motivated move. But, after the leadership struggle, which he calls a "31-day impasse,"Espada got what he wanted.

Sitting at one of the desks in his new offce was Espada's son, Pedro G. Espada, who apparently has sometime on his hands after resigning from his senate job a few weeks ago. Asked if his son was now employed bythe district offce, which is forbidden under st rules, Espada just laughed and said Pedro G. was simply a

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Page 35: Espada Reply to Subpoena

Espada Holds Cour in Loft New Offce Page 4 of7

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Espada Holds Cour in Loft New Offce

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Page 37: Espada Reply to Subpoena

EXHIBIT 3

Page 38: Espada Reply to Subpoena

08/31/2009 12: 08 FAX 14002

~ SOUNVIEW HEALTHCAR NETWORK

Ped Etpaib Jr.Pcderi & CEO

BOAR OF DIRORS MEETIGMIuTq

Date: December 20, ZOO?

Time 5:00 P.M. - 5: 50P.M.Place: Waters Edge Resturant, Queens, N.Y.Members Present:Ms. Barara Braxton

Ms. Constance BnmoMs. Beverly CrosbyMr. John A. Feliciano, Jr. ClißmanMs. Claudia GealdMs. Evete MaduroMs. Charlotte McDuffe, SecretarMs, Lidisbelle Pachec, Vice ChaiiersonMs. Jeny Torres

Mr. Andrew Yong, TreasurerMembers Absent:Mr. Victor FelicianoStaff Present:Pedr Espada, Jr.. PresidentDr. CollymoreKen Brennan1da BauerJessica Medina

Mr, John Feliciano commenced the meetng at 6:45 p.m, and advised the Board ofDirectors tht th Executive Committee had met to discuss open issues such as the needfor resolutions approving the subnússion of the HRSA Serice Capacity Grat for OrlHealth application neeed to achieve those effort; a chage to th table of orgaization

reflecting that the Director of Denta Service is supersed by the Medcal Dirctor, andaproval of a change of scoe to our operdtIng cerficate to be submitted to the NYSDept. of Health in support of1he certficae of ned application for deta van serces_These reolutions shall be mad a par of the mDu1. fOT the November board meeting.

The oiler issues discussed and approved by the Executie Committee were Mr. Espad'sannual job performance evaluation and compenation for outstandi performance of hisduties and responsíbüities in the fonn ora housing alowance of $2,500.00 per monthcommencing Januar It 2008;CCDC's anual Chrstmas staff party and year-end bonusesfor which $54,478.00 were set aside to cover the bonuses and taxes thereon, and acontract, effecLive Februar i, 2008, with Soundview Mangement Enterrises, LLC LOprovide jantorial serce previously perormed by communi Expansion DevelopmentCoip., with the acknowledgement tht Pedo Espada, Jr. is the sole member ofSoundview Manement Enterrises, LLC.

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08/31/2009 12: 08 FAX 14003

Mr. J. Feliciano concluded lù presntation, and afr boar discussion of the ExeutiveCommttee's recommendaons, be requeste a motion to aprove the minutes of theNovember meetig of the Board of Dirtors and add the resolutions as recnuended bythe Executive Commttee. Ms. Torres mae a motion to aprove the miutes of theNovembei meetig with the added resolutions approving submision otthe CapacitGrant for Oral Health aplication, the change of scope to our operatig cerficate insupport of the cerficate of nee application for deta van services and the change to OUT

tale of organiztion reflecg tht the Diecor of Denta Serces is supervised by theMedcal Direcor. Ms. Bruno seconded the motion, all voted in favor, and the motioncaed.

Mr. J. Feliciano requested a motion to aprove the Executive Committee'sreconuendation to compensate the President & CEO for an outstading perfomice ofhis duties and resonsibilites in the fon ofa housing allowance in lieu ora salarincrease to commnce January 1,2008 in the sum of $2,500.00 per month Ms. Braxtonmade the motion to compensate Mr. E~ada with a housing allowance of$2,500.00 permonth commencing Januar t, 2008. The motion was seconded by Ms. ChalotteMcDuffe, all voted in favor and the motion cared

Mr. J. Feliciano requested a motion to aprove the Executive Commttee'srecommendation for a statfChrtmas par and to set aside the sum of$S4,478.00 foryear-end staffbonuses æid taes theron, Ms. Beverly Crosby made the motion that was

seconded by Ms. Madu, all voted in fàvor, and the motion caed.

Mr. J. Feliciano requesed a motion to approve the Executive Committee'srecommendation to enter into a contrct effective Februar 1,2008, with SoundviewManagement Enterpries, LLC to provide janitorial services to Soundview HealthCareNetwork. Ms. Bruno mae the motion tht was seconded by Ms. Crosby, all voted infavor and the motion caed

Mr. J. Feliciano requested the President's report

President's ReportMr. Espad thand the board for their evaluation and their confidence in his ability tolead the orgation to expand servces and tae on new projects in order to accomplish

CeDe's mission to provide high quality services to th community at little or no cost toan undersered populaton. He also mentioned that the board's collaboration and activeparcipation in all endeavors is the drving force for success.

Assisted Living ProgrmMr. Espada proceed to shae the architectura plan for the 14 the-famly homesprojected for use as par of the Assiste Living Program Soundview is collaboratin withthe Jewish Guild, which ha long-ter experence with assisted living projects, and thebuilde h~ provided the plan for the project. It is very cost effective as the houses arealrey built and th project ca be completed in tlee months. He also asked the boar

to sign lhe boar of director profiles so th they may be submitte with the completeapplication for the Assisted Living Program an meet the deadline on Friday.

TJ:\1".oo\AdrnJ.i.i;"" i:ìI... 2007'.nan1 M1mil..\n.""hl' 'l0(7.."'" ,.

Page 40: Espada Reply to Subpoena

08/31/2009 12: 08 FAX I4 004

Soulldview RelocatinMr. Espad invited the boar to his offce the next day to view the prelinary plas

proposed for the Soundview relocation to a parcel of land located at Bolton & SewardAvenues.

Mr. Espad completed hi report and after a discussion, Mr. J. Feliciano requested amotion to acept the President's reprt Ms. Madur made a motion to approve thePresident's report and it was secnded by Ms. Gerld. All voted in favor, and the motioncared.

Mr. J. Feliciano requested th Medcal Director's report.

Medical DirectorDr. Collymore went over the credentialing packages for Dr. Wusu, Calderon and Sadlerpreviously forwarded to the board on Decemer 7, 2007. Dr. Wusu is par oftheexansion of servce for the Dental Deparment. Dr. Calderon is an Optometrit, who isbilngual, and is execte to stat work in Januar 2008. We are orderig equipment for

his offce so that it wil be ready for him to provide seivces in Janua. Dr. Sader iscurently at Soundview, and ha 25 years of expenence in priar care.

Dr. Col1ymore informed the board of plans to expand physical therapy to the satellteclinics, begning with Bunide Medical Center. Plans are under way to exand Ob/Gynserces as welL We wil1 be par ofaresearch project by collaboratig on a women'shealth survey.

Dr. Collymore said he would continue his recruitment effort in order to expand andprovide more serces to our patient population. He thanked the board for their support,and took the oportnity to present Dr, Bobo, Dr. Ojo, and Dr. Zeyneloglu who were

invited to the board of directors Chstmas diiier at the board's request.

Dr. Collymore concluded his report, and Mr. 1. Feliciano requested a motion to approvethe Medical Director's report and reommendations, Ms. Crosby made a motion toapprove tbe Medical DU'ector's report seconded by Ms. Gerald, all voted in favor and themotion cared.

Mr. 1. Feliciano requested the Vice President of Fiance's report

Vice President of FinanceMr. Brennn also thanked the board for their support and wished them a happy holiday.Mr. Brennan reorted the 2006 audit would be ready for submission by mid-Janua, andwork is being done on the 2007 audit

He also mentioned that Phil Valdez the new controller is experenced with M. i. S, and isfamilar with the Medcal Manager Practice Manageent System, which wil mak iteaier to produce the fiance report on a tiely basis.

Mr. J. Felician requested a motion to approve the Vice President of Finance's report,which was made by Ms. Bnmo and seconded by Ms. Gerald Al voted in favor and themotion to aprove the Vice President ofFInance's report was caied

H:\ili.,I.mAdminiRt'ti,Ml Pli... 2007\Hoird Mimles\Occmhi 21l7,dn')

Page 41: Espada Reply to Subpoena

08/31/2009 12: 09 FAX ~005

There being no new or old business to discuss~ Mr. J. Feliciano wished everyne happyholidays~ an requested a motion to adjour. Ms. Brno made a motion to adournseconded by Ms. Ged AU voted in favor and the meetig was acloumed at 7:20 p,m.

Motions:By motion duly made, and seconded, the board voted unanImously in favor:

1. to approve tile Executive Commttee's recommendation to amend the

miutes of the November meeting with the added resolutions approvingsubmission of the Capacity Grant for Oral Health application, the chan¡:e ofscope to our operating certficate In support of the certificate of needapplication for dental van servces and the change to the our table oforganiztion reßeclng that the Direcor of Dental Services Is supervised by

the Medçal Director;2. to approve tlJe Executive Committee's recommendation to compensate the

President & CEO for an outstanding penormanee of his duties andresponsibilties In the form of a housing allowance in lieu of a salaryIncrease to commence January t, 2008 in the sum of$2,500.00 per month;

3. to approve the Executive Commtte's recommendation to approve a

ChrlBmas party for staff set aside the sum of$54~478.00 for year~end staffbonuses and taes thereon;

4. to approve the Executive Committee's recommendation to sign a contract

effective February i, 2008 with Soundvlew Management Enterprises, LLC toprov~de janitorial services previously provided by Community ExpansionDevelopment Corp. to SOllDdview Healthcare Network;

5. to approve the President's report With its recommendations;

6. to approve the Medical Dlreetor's report with Its recommendations;

Includini credentlaling packages for Dr. Wusu, Dr. Calderon and Dr.SadJer;

7. to approve the Vice Pi'esldent of Finance's report.

Respeclfully submitted,

U:\lbll\AdminillntÎon File. :u07\J.,.1' Mmulcl\))cccmli' 2007..i"nII

Page 42: Espada Reply to Subpoena

08/31/2009 12: 09 FAX ~008

RESOLUTION

WHEREAS, the boar of diectors of Comprehensive Conuumty DevelopmentCorporation wishes to awar the janitorial contrt previously perfonned by CommtyExpanion Development Corp. to Sounview Management Enteipries, L.L.C., and

WHEREAS, Pedo Espada, Jr., ba prvided the boar of diectors with full diclosureorWs affiation to Soundview Management Enterries, LLC,

WHEREAS, th board is aware that Pedro Espada, Jr. is the sole member of SoundviewManagement Enterses, LLC, and wishes to enler into a contract,

NOW THEREFORE, BE IT RESOLVED. the Board of Direcors of ComprehensiveCommnity Development Cot. agrees to enter into a contract with SoundviewMangement Enterries, LLC to provide Jantorial servces for Soundview HealthCaTeNetwork effective February 1, 2008.

Dated: December 20, 2007

Jo . 1\. Feliciano, ChaBard of Diectors

i ¡,'dIIUtIAdmini.""iJ"" i~;i". z07lRoard Minu\eIJ)nbo io07.dn "'

Page 43: Espada Reply to Subpoena

EXHIBIT 4 -

Page 44: Espada Reply to Subpoena

Q

'"

JANRI AN FACWTY SERVICE AGREEME

Th JANTORI AN F ACn.rr SERVICE AGR (Te"Agreeen ma as of the lSlI day of Janua 2008 ("mml'.i Da") by andbeee Soview Mangemen Enri LLC, a New York li liilcopa ha"in offce at 325 E. 20i5t Str Bronx NY 10458 and CcmpveCoun Developmnt Corp (C.c..C), 731 Whte Plain Roa Bronx NY 10473("PC").

WH SME is in th buines of prviding jantonal and fåilty sercean

WH, C.C.D.C is in the buess of prvidi medca an socal servcesan lea cein pres (the "sublease premij an

NOW, TIREORE, in consideraon of th foregoing, an for other good anvalle oonside:on, the reei an suciency of which are acknowledg, the

paes, ining to be lely bound. ag as foUows:

SECON 1. SCOPE OF AGRENT

1.1 Subject to the te oftb Agrent, and as set fort in full below, C.C.D.C

herby appoints S1 as its agent to perform tle sece set fort in Section 2and 8MB hereby accts sad appointment on' the teo and coitions asherinfter provde

SECfON 2. DUTS OF SME

2.1 SME sha1l prvide C.CD.C and it leass premi witbBasc Jantori

Sece se fort in Exhbit A herto.

22 If at any tie durng the term of Ageement C.C.D.C seks the perfoimof any oth seices by 8ME COptional Sece") as se fort in Exbit B,C.C.D.C sha reqest in wrtig that SME provide such additon servces

and 8MB shal, with th (30) day.s ret of suh reuest notC.C.D.C of wheer or not 8MB ca provide such additiona serce and theco therf.

2.2.1 If 8MB inteds to prvide such additiona se 8MB andC.C.D.C sh agree in V¡ritig on a fe for such addionalservce. Thafr, 8MB shal commence prviion of sadaditiona serce on a date spified in writi but in no event

laer than (30) days following the dae on whch 8ME ha givensuch wrti.

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Page 45: Espada Reply to Subpoena

2.3 C.c..C shal tae al sæps reasnable reed by 8MB to enle 8MB toperf its dutes an to exerise its ñghts hereuner includng, v.ithutlintation, th exection of such douments and ints as 5Mrenaly reuet frm tie to ti.

2.4 8MB may stre 00 th Le Pr eqen used in the fuerce ofth Agnt an mai an offce at no cost to 8MB. C.C.D.C hery

gr to SME th ñght to renale ac to 'te Le Pr digth te of ths ageemet, or an extio herf, in connection with the

prvision of servce pur to th agmenL

25 8M shl mata the Leas Prse in goo order. condon and ieaishal us its reabe effort to mak all ne reai in a tieLyman to maitain the Leased preses in good condtion.

SECTON 3. CO~ENSA TION

3.1 As compeon to sJvrn for Basc Janonal Servce prvide uner thAgreeent c.e.D.C sh pay SME an aditiona monthly fee (the"Additiona ~gemen Fee") as lite on Schedule A upn fiftee (15)days frm recipt of invoice.

3.2 As compesaton to 5MB for Optiona Servce. provided uner thsAgreemet, C.C.D.C shal pay SME an additiona monthLy fee (the ..Addional . Mangement Fee") for such servce in an amount to bemuy agee upon in the maner setfor in Secon 2.2.1.

SECfON 4. REPREENATIONS. W AR AN CONVE~ANS

4.1- SME rere an wa that (i) it is lited liabilty Comany,vaidly existig and in good stda under the laws of th ste of NewY or. (ii) bas the por and aurity to ca on it buses as nowbeg condute; eii) ha the power to execute and peorm thAgrent.

42. C.C.D.C rent and wats th it (i) is a Corpraon, validlyexisti an in good st under the laws of

the Stae of New York; (ii)

ha the power and the auñty to caryon its bues an now beingconduced; (il) ha the power to ex and perorm this Ageeme.

SECTION 5. INSURACE

5.1 8MB sh mata gener liabilty, casuaty an propert damageince for the Leaed Premises in an amount to be reonablydeteoed by 8MB.

Z"ddl£L.O 60 L L de

Page 46: Espada Reply to Subpoena

c:rd

SCHDULE A

BASC MAGEM FEE

Souniew Heath Cete731 Whe Pla RoBIO New York 10473

Bur Medca Ceer165 E. Burside AvenueBronx New Yar 10453

Cae Hi Medca Cente616 Cae Hill AvenueBro New York 10473

Dia1o Medca Cente1760 Westcter AvenueBronx New York 10472

Delany Siss Heath Center

821-7 Ea 233rd Stet

Bronx, New York 10466

$9,000.00

$6,000.00

$4,000.00

$7,00.00

$7,000.00

o

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Page 47: Espada Reply to Subpoena

Lrd

I~ WIS WHEREF, th pa have signed th Agemt on th dafi wrtten above.

SOUNVIW MAAGEMENT ENRIES, LL

Ok ~l;LName: Ped Espada, Jr.Tide: Membe

~~ft.Title: C C-d c.-

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Page 48: Espada Reply to Subpoena

QL'd

SCDULE A

:BASC MAAGEMNT FEE

$1,000

d£SLO 60 L L des

Page 49: Espada Reply to Subpoena

EXlT B

OPTIONAL SEVICES

TAS

Paiti ........-...... ..... .... .... .......... .....-....... ......Puasg Supplies. ........... ............ ..... ....... .......

6"d

FRQUENCY

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Page 50: Espada Reply to Subpoena

- srd

EXIT A

BAC .JANTORI SERVICES

8MB shal overee al budiso fuctions, includ mace,outde co. ageets an modeozation of

the Le Pres

SME shal en th it mee all govemeø st in clea an saelyan en th the un of al emloyee ar up to co.

8MB shl supervsor and ditl ma al maence employees. anovers th the ex equipent need meets coe stn dea withcleaess prjec.

5MB sha be resnsbilty for th adiûon of al cont beficationprjec for th Le Premise

SPECIC WORKCOPE

TASK

Mopping... _........... ..... ........, ..-. ..... ...................Dustng ........ .............. ...... ....... ............. ..........Vacuum ....... ........... ...... .........-. ..... ..............BufgIax ........ .................... eo........... ..-....Jannal (includ haug of

tr) ........ .-. ......... ...Inteor Winow Wasg ., ..... ..... ...... ........ ..........

FREUENCY

DailyDailyDailyTwo ties pe weDaiyMonthy*

Monthy shl be defined for ths Agrement as serce searted by period ofnot les th twenty-five (25) days, or more th th (30) das.

d£:LO 60 L L des

Page 51: Espada Reply to Subpoena

ld

. IN WI WHEREF, the paes have signed tl Agrent on the dafi wrtt abVe.

SO~W MAGEMENT ENTERPRIES LLC

¡ /ob ~/C~~O Espa Jr.Title: Membe

~ . ~By: . ,Name: . ~(1� AND,:fL .Title: ec.O(! - ~

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Page 52: Espada Reply to Subpoena

9"d

8ME: 325 E. 201 Str

Bro New Yor 10458Atton: Pedo Es Jr.

C.C.D.C Jesica Gu Medca Ce60658 Ca Hi AvenueBr, Néw York 10473

731 Whte Pla RoadBro New York 10473

Attenon: Ge Counsl

With a coy to:

9.5 - No waer sh be efectve agai eier par unes it is in wrg.sign by th par)r. No waver or any br of an te or covencontaned in th Agent shall opee as,a waver of suh ter orcovenan itselE or any of subsent breach theof.

9.6 The invadi or unnforcilty of any provion of ths Agment shalnot impa the ~dity or inorty of any other provision.

9.7 Th Agreeent sha be goveed by the laws of the stae of~ew Yark

9.8 The heas in ths Agreement ar inded solely for convenience ofreence an sha b given no efft in th cocton of intionof tis Agrent

9.9 Th Ageent may be ex:eced in counteiar, each of whch shall bedeeed an origi but all v,ihich togeth sh consttu on an th saeÏDtrent.

(Remainder of Pag Left Intentional Blank)

d£SLO 60 LL des

Page 53: Espada Reply to Subpoena

have ar or th bas fur ths have ar th term of thagrt.8.1.3 The paes here sh acunt to each oth wi rect to all

maer outdi as of the da of su expiron ot termation

SEON 9. MILLOUS9.1 Th Agt se for th en wide beee th paes

heto an sues all ot pror agmen beee 1h paes.Ea par to th Agrnt acowledes that no reentaonind.en, prmi or agent, orally or oth have bemae by any pa, or anyone actg on be of an pa. tb notemboed in ths Agrcn~ an th no other agreent, sttemen orprmi not conta in th Agent shal be val or big asbe SME and C.C.D.C

9.2 Ths Agreeent may not be oray ched or modified. Al clges ormodcaon of this Agrent shal be in wrti sign by the paragaí whom enorcement of any waver, chage modifcaon. exsionor dischage is sougt.

9.3 Eah paysll promptly and duly execute and delive to the other su:fr docuents ïnts an as an tae fuer actions assuch othr pa may reonably reues in order to car out th intentan puse of th Agreement and tQ estbli an prote the rights andremed creted or inded to be create in favor oftb reuestg pa.

9.4 Unless ot stad heeÏD any notice nr othr communicaonreed or pett to 'be given herder sh be in wrtig, and shbe delivere to the pares at the addrs set fort below (or to such other

addresses as eithr par may specify by due notice to the othec). Noticeor other communcaon may be given by cefied or registed maL,retu recipe reuete reptale overght service, telecpy or handelive. Notice by ceed or regited ma shall be deme to havebe given (3) days afec the da of mai Notice by ovegh caershal be demed to have ben given one (1) business day af th date

deposited wit such caer. Notice or oth oommwication set in any

other maer sha be deed given onl whn actully reved

"'dj d(f:LO 60 L L des

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p'd

SEON 8. TE; TEATION8.1 The te of th Agrnt shl bemg on th Commencement Dat an

sh cotiue nn Dembe 31. 20 (the "'RM. mies soerte;nsrP. as prvide he prvide. hover, tht th agen.shl autca reew itlf for an adtiona term of one (I) yeauness eith pa gies the ot pa at lea niet (90) das' wrnotice beore th exirtion dae of the cut te of its in not torew, prvided fuer, however. Eith pa may te thAg up thy (3) day's wr notied to th oth par.

8.2 Bith pa may 1m th Agr in th ev 1b lea orsuleae oftbe Le Prse is termd.

8.3 Eiier pa may rete th Agent imediatey in th event thatthe Le Pr sh be daed by fie or othr caty and thedae is so exenve as to amount to total destction of the SubleaesPrises.

8.4 The nobreahig pa may teri ths Agreeent if th other pabres a matenal non-mone prvision of ths Agreemt and suhpa fai to cu the br witl twenty (2) days afer such pareves wrttn notice of suh breh.

8.5 SME may ternae th Agreement imediatly if C.C.D.C fas to payU1e Basc Magement Fee and/or the Additiona Manemnt Fee asspecifed in Section 5 an fais to cu on fiee (15) days wr notice.

8.6 Upon th termtion of th Agrent, 8MB shl remove al of itspernal proer fr Premise bere, or immedly af. suchteon.

8.7 Termon or brh of ths Agemet by eit pa sh in notfahion reuce th obligation ofC.C.D.C to pay ac an unpad BacMaagement Fee and/or AddI1onal Manen Fees ha beinvoice prior to th da of termnation.

8.8 Upon th exiration or sooner termtion of ths Agrent:

8.1.1 Nei1h pa here sha have any fier liaiüty to the oth topeorm under th te of th Agrent.

8.1.2 Notwding sad expiraton or teion, neÏ1er parheeto shall be relea from any obligations or liabiles. which

dæ;LO 60 L L des

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SECTION 6. ASSIGNM AN OTR AGRMENT

6.1 Neier pa sh asgn or oterse trer th -Agrment nor anypurort asign in violan of the Agent shl be mi an void.

6.2 Notwg. th foregoig. 8MB may subcntrct any sece itde ne. 8MB, mu. however solicit tw (2) bids before anysunt am ca be enteed into.

SECfON 7. INEMCATION

7.1 8MB sl indenm and hold haes C.C.D.C its sucers andasgn and any of its offce di, emloys. ~ anagen ha from an aga any an all claims, da, injur.liabties, cost an exses, inludng. without limitaon, releatrneys fee aDd disburs of counsel ined by C.c..C in anyacton or prceeg betw SME an C.C.D.C or beeen the C.C.D.Cand any th pa of otse. arsig out of or in any way related to:(a) any maeral breach or default of ths Ageemet by 8M (b) anyrensbiity of SME for th Leed Prmi; (c) any claim mad by oron be of a member of SME peel in respct of his or heremloymen caus th grss neligence of malf of SM; (d) anygross neglgent conduct or maleaance by an employe, agen~suC(nir. sublice or reren1atve of 8MB or C.C.D_C. if suchemployee agen subcntrr, sublicens or repretative of 8MB Thsinemnty sh not apply to cons or specal daages suh as thlos of:f bu.

7.2 C.C.D.C shall inen and hold haess 8MB i1 sucars .andasgn and any of its offce: diror. emloyee, represenes andagen haess frm and agai any an al claims, daage. injur.liabilties cot and exp. including, without Litaon reonableatorneys fee and disbursents of counel incur by C.C.D.C in any

acton or prng betwen SME and C.C.D.C or betw 10 8MB andan th pa of otb aring out of or in any way relat to: (a)any maerial breah or defuult of ths Agreemen by C.C.D.C; (b) any

cla mae by or on bef of a member of 8MB in res ofbi or heremplojrmnt caued the gr negligen of maance of C.C.D.C~ (c)an grss negent condt or maeasce by an employee, agensubcontmtor. sublice or representative of 8MB or C.C.D.C. if such

employee agent, suntrr, sublice or reentative of C.e.D.c.Ths hiemty shall not aply to conseqential or spial damges suchas the loss of futu busin.

7.3 The obligaons of th Secon 7 shal surve any te.nation of thAgren

""dc, dë:£:LO 60 L L de

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EXHIBIT 5

Page 57: Espada Reply to Subpoena

.Q~!5~')~~I!.~::'"C LEA N I N G CON C E¿'P T s"!, .

A CustomizedHEAL THCARE CLEANING SERVICES PROPOSAL FROM

COVERALL CLEANING CONCEPTSprepared for

Copyright (Q 2007

Soundview Health Center

~ L Ll S; i '1 gO ~ ÂI"-\'-J ~ \

Page 58: Espada Reply to Subpoena

""~/

.Q~Eft 4.1__111.:,~ __ .-_i~_r...__ç LEA N I N G CON C E''; T $,'''

August 13, 2007

Pedro EspadaSoundview Health Center731 White Plains RoadBronx NY 10473

Dear Mr. Espada:

Thank you for allowing us to present you with our Healthcare Cleaning Services Proposal configured to your facility'sspecific cleaning requirements.

The cleaning requirements for a medical facility are far more complex and stringent than those of other businesses.Harmful microorganisms may be present anywhere in the facility, from waiting areas to clinic rooms to restrooms, creatinghealth risks for patients and staff. It's critical that your cleaning service has the training, equipment and methodology toapply proper patient safety procedures,

In addition, research shows that facility cleanliness is among the top areas influencing a patient's perception of qualitycare. In fact, in some studies, it ranks above physician and clinical staff peiformance! A clean, well-maintained workenvironment also drives staff satisfaction.

As your healthcare cleaning service provider, we provide a partnership you can count on. We firmly believe that asuccessful partnership, based upon the following elements, wil meet or exceed your expectations:

. Ensuring a quality dean -- essential to providing a healthier and safer environment for patients and employees, andenabling you and your staff to focus more time on running a successful business and providing high-quality patientcare,Healthcare-specific cross-contamination prevention and disinfecting procedures -- essential to reducing the spreadof disease and ensuring a safer environment for patients and staffKnowledge and experience in healthcare - allowing us to be a proactive partner in helping you meet regulatoryguidelines and contribute to an effective patient safety program.

Once you choose COVERALL CLEANING CONCEPTS as your healthcare cleaning service company, you will find thatour knowledgeable and thoroughly trained cleaning teams wil provide the high level of service your healthcare facilityrequires. Our detailed-cleaning services specific to the healthcare industry will enhance and maintain the professional

environment of your healthcare facility,

Please find enclosed the proposal we discussed, as well as the Coverall Cleaning Concepts Healthcare Executive ValueAssessment and Summary, It will help provide a clear understanding of our company, our unique approach to servicingfacilties in the healthcare industry, and how you can have the best quality cleaning specific to your healthcare facility'sspecialized requirements at the most reasonable price,

Thank you for your time and the opportunity to discuss the many benefits COVERALL CLEANING CONCEPTS has tooffer to fulfill the cleaning needs of your healthcare facility.

Copyright (Ç 2007

Page 59: Espada Reply to Subpoena

Helping you accomplish your key objectivesCOVERALL CLEANING CONCEPTS' Healthcare Cleaning Services

Many companies in the healthcare industry encounter numerous problems with the cleaning of their facility dueto the requirements and specialized needs of the healthcare industry, At COVERALL CLEANING CONCEPTS,we provide solutions by handling all of your healthcare facility's cleaning requirements, giving you theopportunity to focus on the care of your patients.

Your Objective: Patient and Staff Safety

Your Challenge: Preventing cross.contaminationCoverall Cleaning Concepts Solution: Coverall Cleaning Concepts mandates that color-coded

microfiber cleaning cloths and mop pads are used by our cleaning teams to prevent cross-contamination.

Your Challenge: Ensuring proper disinfectionCoverall Cleaning Concepts Solution: Coverall Cleaning Concepts has a strategic partnership withProcter & Gamble (P&G), one of the world's leading chemical manufacturers. Our technicians use only PSGhospital-grade, viruscide/germicide disinfectant cleaners to ensure a healthier and safer environment for yourpatients and staff.

Your D.bjective: Patient and Staff Satisfaction

Your Challenge: Cleaner waiting rooms

Coverall Cleaning Concepts Solution: A Coverall Cleaning Concepts healthcare specialist develops acustomized plan that ensures the proper scope of cleaning services are scheduled and performed to deliver aconsistently clean environment that will impress patients and increase staff pride.

Your Challenge: Cleaner restroomsCoverall Cleaning Concepts Solution: Coverall Cleaning Concepts cleaning teams use advanced

microfiber technology instead" of cotton cloths. Microfiber has positively charged fibers -- 100 times finer thanhuman hair -- that penetrate the microscopic surface pores of floor materials and other surfaces, removing dustparticles that conventional cleaning materials missed,

Your Challenge: Cleaner exam rooms / clinical areasCoverall Cleaning Concepts Solution: Coverall Cleaning Concepts uses a flat mopping system

designed for the smaller spaces encountered in exam rooms. The unique trapezoidal shape of the mop headmakes it easier for our technicians to get into corners and other tight areas that are typically missed by stringmops.

Your Challenge: Cleaner specialty procedure roomsCoverall Cleaning Concepts Solution: Coverall Cleaning Concepts developed a healthcare floor careprogram in collaboration with Procter & Gamble, our alliance partner. The PSG floor care line used by CoverallCleaning Concepts technicians has been optimized for the hard floor surfaces in healthcare centers. In additionto providing a higher shine, the Coverall Cleaning Concepts-PSG program significantly decreased thefrequency of required floor maintenance.

Coverall Cleaning ConceptstIww.coverall.com

Copyright (Ç 2007

Page 60: Espada Reply to Subpoena

Your Objective: Quality of Service

Your Challenge: Cleaning is poor quality; not meeting your expectationsCoverall Cleaning Concepts Solution: Coverall Cleaning Concepts has a proven economic model to

determine the budget you need to get the level of clean you want. This calculation is bench marked againstindustry production rates for healthcare facility cleaning, so you can have confidence that the contract you signwill deliver the clean you want.

Your Challenge: Inappropriate and ineffective healthcare cleaning proceduresCoverall Cleaning Concepts Solution: Coverall Cleaning Concepts developed and tested, with itsalliance partners, a Healthcare Cleaning System which brings the higher standards of cleaning and infectioncontrol required by residential care facilities, such as hospitals, to ALL healthcare facilities.

Your Challenge: Reliability of cleanersCoverall Cleaning Concepts Solution: Coverall Cleaning Concepts serves more than 8,000 healthcare

businesses - all of whom have very demanding requirements, Coverall Cleaning Concepts Franchise Ownershave a vested interest in their business, and they are motivated to provide quality service, show up on time asexpected, and follow the work schedule to the letter in order to deliver the performance you expect.

Your Challenge: Poor response and follow-upCoverall Cleaning Concepts Solution: Coverall Cleaning Concepts' Customer For Life( program

provides a consistent, established framework for customer support and communication. It includes:

· Franchise Owners who are available 24 hours a day by cell phone or pager.

· Support from Coverall Cleaning Concepts operations personnel, available 24x7 by phone in aRegional Support Center,

· Use of the latest mobile communications technology to ensure a coordinated, prompt response - atrue innovation in this industry. You can reach Coverall Cleaning Concepts support representativesanytime, even when they're on the road.

· The Coverall Cleaning Concepts Log Book - a written record of your requests, problems, andquestions that the Franchise Owner reviews regularly, This documentation - signed by the FranchiseOwner after every cleaning - belps prevent recurring issues and requests that would typically fallbetween the cracks.

· Customer Contact Report system - quality check-up procedures that ensure that the highest levels ofservice are being met.

Your Challenge: SecurityCoverall Cleaning Concepts Solution: Every potential Franchise Owner undergoes a thorough

background check before being accepted into the Coverall Cleaning Concepts family. We will also conform toyour standards for background checks and drug testing for the cleaning team assigned to your facility,

Your Objective: Managing Costs

Your Challenge: Maximum clean for the investmentCoverall Cleaning Concepts Solution: Based on extensive research and development with our AlliancePartners, like Procter & Gamble, and tested at numerous healthcare facilities across the country, the CoverallCleaning Concepts Healthcare program is able to achieve higher production rates than the industry standard, Infact, according to the 447 cleaning times listed by the International Sanitary Supply Association( ISSA), theeffciency-based cleaning tools used in the Coverall Cleaninq Concepts flat moppinq proqram can cut moppinqtime in half compared with the conventional cleaning processes used by many other cleaning services.

Coverall Cleaning ConceptslJww.coverall.com

Copyright C£ 2007

Page 61: Espada Reply to Subpoena

Your Challenge: Risk associated with inadequate insurance coverage / worker's comp lossCoverall Cleaning Concepts Solution: Coverall Cleaning Concepts is one of the world's largestcommercial cleaning franchise companies. We've been in business for more than 20 years and our customersinclude such well-respected names as Verizon and GE Capital, as well as more than 8,000 healthcare facilitiesWith clientele like this, you can be sure that we have the proper levels of insurance coverage to protect yourcompany, including:

. Workers' Compensation as required by state law

. Employer's Liability of $1 million

. Comprehensive General Liability of $8 million

· Automobile Liability of $5 million

. Surety Bond $100 thousand

Your Challenge: Legal and regulatory finesCoverall Cleaning Concepts Solution: When you partner with Coverall Cleaning Concepts, allhealthcare-related cleaning is performed by dedicated Coverall Cleaning Concepts Franchise Owners and theiremployees who have received special training to ensure compliance with the OSHA Bloodborne PathogensStandard Act of 1992 and other regulatory procedures. Our trainers have completed certified training programsand are compliant with Occupational Safety and Health Administration, National Safety Council and AmericanRed Cross.

Your Objective: Compliance with Regulatory Requirements

Your Challenge: Exposure control to bloodborne and airborne pathogensCoverall Cleaning Concepts Solution: Coverall Cleaning Concepts has an ECP template that can be

customized to the Exposure Control Plan in your organization. This ensures that our services coordinate andintegrate with your ECP procedures.

Your Challenge: Hazardous CommunicatiolJcompliance

Coverall Cleaning Concepts Solution: Coverall Cleaning Concepts has developed Hazardous

Communication and Right to Know programs to prevent the misuse of cleaning chemicals. These programsensure that all cleaning chemicals are properly labeled and that Material Safety Data Sheets (MSDS\ meaccurate, up-to-date, and posted on your site.

Coverall Cleani"C/ Conrepts(ß"A'!:', ;Y.l,::."'~i-aiLcom

Copyright (Q 2007

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Page 63: Espada Reply to Subpoena

.

Coverall Cleaning ConceptsC' is a worldwide leader in the commercial cleaning industry.

Coverall continuously develops new and innovative cleaing solutions to enhance the work

environments of our customers, We are a company of owners, partners, and business

people working together to fulfill a common goal - Success.

Our adherence to the following values is the core of Coverall Cleaning Concepts' existence

and the primary reason for our tremendous growth and success:

Do the Right Thing!

· Be respectful, fair and ethical in all our dealings

· Keep our commitments

· Encourage creativity and innovation

· Strive to give and seek advice clearly, honestly, and appropriately

· Promote teamwork

Deliver more than expected!

Our goals make the difference: to be the best, to strive for excellence, to stand

for quality. For that enduring commitment, we stand apart.

Selecting a quality janitorial cleaning service for your facility is an important decision.

Our approach is simple. Coverall Cleaning Concepts believes in establishing long term

relationships built on a solid foundation of superior seNice, expertise, communication

and innovative solutions.

corporate overview

When you contract with Coverall Cleaning Concepts, through any of our Regional

Support Centers worldwide, you will notice a dramatic difference in the appearance of

your facility, right from the start, From the first day of service, you will notice a level of

personal care that reflects our commitment to our customers. Our attention to detail,

continuous research and development of cleaning techniques, coupled with our ability

to offer the best janitorial products, enable us to be effective in all sizes and types of

accounts.

;~fH¡;~"'a~~.1 O~jffr.'!~eV~r

corporate overview

irporate overviewSmall and large offce buildings, industrial complexes, healthcare facilties, banks,

laboratories, retail stores, and corporate headquarters are among the many types of

accounts we seNice. Thousands of satisfied customers occupying milions of square

feet are proof that when it comes to value, quality and responsiveness, Coverall

Cleaning Concepts is the company you can count on.,rporate overview

corporate overview corporate overv e w ~!i.1t:~~~Rev. 121

Page 64: Espada Reply to Subpoena

irpofate overview

corporate overview

corporate overview

.rporate overview

)rporate overview

Rev. 12/06

corporate overview

.

Since 1985, Coverall Cleaning Concepts has become one of the world's largest

commercial cleaning franchise companies, servicing over 45,000 customers in over 90

metropolitan cities worldwide. Coverall Cleaning Concepts' extraordinary growth is

attributed to its system-wide network of Regional Support Centers and Franchise

Owners that are dedicated to serving the needs of its customers,

NUMBER OF COVERALLFRANCHISE OWNERS

The Coverall Cleaning Concepts system is

characterized by an excellent support

system, the best training, management

expertise, and high growth acceleration in a

recession proof industry, Notable

accomplishments of the organization include

an increase in Coverall Cleaning Concepts'

growth by 93% from 4,419 franchises in

1998 to 8,570 franchises in 2006 and an

increase in the amount of customer

accounts by 54% from 26,000 customer accounts in 1998 to over 45,000 customer...

accounts in 2006,

8953

8451

6000

450

3800

3000

2400

1800

1985 i!~81 1989 \991 1993 199 199l 1999 201 200 20

As a thriving, privately held company,

Coverall Cleaning Concepts' system-

wide sales topped $272 million for the

most recent fiscal year, a 13% increase

over the prior year. This phenomenal

growth rate evidences that our

customers value the high standards we

place on quality service.

ACCOUNTS SERVICED BYCOVERALL FRANCHISE OWNERS

42000

35000

32000

24000

21000

16000

11000

1985 1987 198 1991 1993 1995 1997 199 2001 20 200

corporate - ,Ie w ~~f~~~overv

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lrpGraH~ overview

corporate overview

.~ i0--, "' ~vcorporate overview

o~~HAWNl PUERTO RICO

)rporate overview INTERNATIONALThailand Singapore Dominican Republic Korea

Bangkok Austlia Canada Seoul

Japan Brisbane British Columbia Puerto Rico

Kobe Chile (Vancouver) San Juan)rporate overview Osaka Santiago Calgary

corporate overviewTokyo Toronto

~,~.~~~~ARev. 12/06 C 0 r p 0 r a t e 0 v e r v e w

.COVERALL CLEANING CONCEPTS

ADDRESS: 5201 Congress Ave., Suite 275

Boca Raton, FL 33487

(561) 922-2500

(800) 537-3371

(561) 922-2434info(gcoverall.com

ww.coverall.com

TELEPHONE NUMBER:

FAX NUMBER:

EMAIL:

WEBSITE:

With proven success in servicing multiple location accounts, our Global Support Center

in Boca Raton, Florida offers support and assistance to over 90 Regional Support

Centers across the nation and throughout the world. In addition, OIY 8x'er,.:iiO

network of contractors further enhances Coverall Cleaning Concepts' Ik.lliol'j'Nide

coverage. Our Regional and International Support Centers are shown below as well as

our extended network of contractor-serviced areas,

~ REGIONAL SUPPORT CENTER LOCATIONS~lf CONTRACTORS NETWORK COVERAGE

Page 66: Espada Reply to Subpoena

Jrporate overviev\/

corporate overview

corporate overview

orporate overview

orporate overview

corporate overviewRev. 12/06

.COVERALL CLEANING CONCEPTS'

RECOGNITION

Coverall Cleaning Concepts has been recognized industry-wide:

· The Stevie Awards, an organization created to enhance the

profile of exemplary companies and individuals through public

recognition, honored Coverall Cleaning Concepts as the Best

Support Organization for the past two years in the International

Business Awards,

· Entrepreneur Magazine's Franchise 500 ranked Coverall

Cleaning Concepts as one of the Fastest Growing Franchises and

one of the leaders in the commercial cleaning industry for eleven

consecutive years.

~.

==_.. ;lRf· Success Magazine's Franchise Gold 200 recognized Coverall .

Cleaning Concepts as one of the best franchise companies.

· Coverall Cleaning Concepts was

noted as one of the

preemine,nt franchise

systems by Bond's Top

50 Service-based

Franchise publication.

· Coverall Cleaning

Concepts was selected as

the Business of the Year

by the South Florida

Business Journal.

· Black Enterprise Magazine recognized Coverall

Cleaning Concepts in their "15 Great Franchises" as a

leader in minority franchising, as well as the Third Best

Home-based Business for African Americans,

. Franchise Times Magazine's Top 200 Franchises ranked Coverall Cleaning Concepts

as the eighth largest franchise chain by domestic units.

corporate _sl!"æ~. ,....!" '0overv e w

Page 67: Espada Reply to Subpoena

.

Continued education and training ensures that Coverall Cleaning Concepts has the

strongest team of cleaning professionals servicing your facilities, Coverall partners with

many professional and technical experts in the industry, which enables us to offer many

valuable premium services, creating an opportunity for our customers to take advantage

of a single source for all facility requirements. Coverall Cleaning Concepts'" and many

of its Regional Support Centers are affiliated with the following associations:

~rrHJr;J~e :~YY1.;rV~0V\i

corporate overview

corporate overview

irporate overview

irporate overview

corporate overviewRev. 12/06

(IIFAMEMBER

BuildingServiceContractorsAssociationInternationalMEMBER

__ ~ member of

eM I CLEANG~~~NT I S S Ä The Experts

on Cleaning and Maintenance

TheCommercial

Service

CHAMBEROF

COMMERCE

(f OSHA

CASHE":.Amerca Soet for Heatbcae Engneeof me Amc:ca Hospita Astion

BOMA\!INTERNATIONAL

.......nø" RIl....tR.ljlf'-rIl~Nl.i..r."""A.llldM~b",

AMERICANRED CROSS

IEHA

Coverall Cleaning Concepts is also a proud affiliate of Ashes and CIRI.Contact names and phone number wil be provided upon request.

corporate o v e r vie w ~c~..~~~~~

Page 68: Espada Reply to Subpoena
Page 69: Espada Reply to Subpoena

.

In today's fast paced business environment. more and more

facility managers are looking for cleaning companies that can

fulfill a wide spectrum of service needs - thus saving them time

and providing an added measure of convenience. With a single

phone call, virtually all your maintenance needs can be handled with a professional

approach and personalized service through our extensive network of Regional Support

Centers. From carpet cleaning to restroom sanitation services, Coverall has you

covered. Our Franchise Owners along with their cleaning crews are professionally

trained to provide a variety of services including:

HARD FLOOR CARE

~¡li!iií~1îÎ~!,

:~:~;;~~1~~~~!m~~~8:tg%~ø8

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services

services

..-:--.--_..~--.-

services

Rev. 12/06 services 5 e r v c e 5 ~t'."!~~~mf

Page 70: Espada Reply to Subpoena

.

Coverall Cleaning Concepts applies superior cleaning techniques, coupled with the

flexibilty to handle the individual needs of each customer. The following industries and

commercial facilities depend on Coverall Cleaning Concepts to provide consistent,

quality seNice,

INDUSTRIES:HEALTHCARE SERVICES

AGRICULTURE, FORESTRY & MINING

CONTRACTORS & CONSTRUCTION

MANUFACTURING

TRANSPORTATION. COMMUNICATION &

UTILITIES

WHOLESALE & RETAIL TRADE

FINANCE. INSURANCE & ~EAL ESTATE

BUSINESS & PERSONAL SERVICES

LEGAL SERVICES

EDUCATION & SOCIAL SERVICES

ART & MEMBERSHIP ORGANIZATIONS .i

ENGINEERING, ARCHITECTURE & ACCOUNTING '

GOVERNMENT (PUBLIC ADMINISTRATION)

HOSPITALl1Y

~.)tH'Vh~-eS

services

services

services

Rev, 12/06 services

FACILITIES:HEALTHCARE FACILITIES

OFFICE BUILDINGS

RETAIL STORES

INDUSTRIAL SITES

MANUFACTURING PLANTS

AUTO DEALERSHIPS

MULTI-TENANT BUILDINGS

RESTAURANTS

RECREATIONAL SITES

CI1Y, STATE & GOVERNMENT COMPLEXES

AIRPORTS

HOTELS

s e r vie e s -t,~.~~~~¿

Page 71: Espada Reply to Subpoena

sjtf\ficøs

services

services

services

Rev. 12/06 services

.

Coverall Cleaning Concepts' Franchise Owners have access to the most advanced

training on the use of all the necessary equipment, chemicals and supplies, as well as

efficient techniques that can help you save time and money.

Continued education and training ensure that Coverall Cleaning Concepts has the

strongest team of cleaning professionals servicing your facility. Coverall trainers have

completed the following associations' certified programs and training courses:

. Occupational Safety and Health Administration (O.S.H.A.)Coverall Cleaning Concepts Franchise Owners meet all regulations under O.S,H.Astandards, section 1910.1030.

. National Safety Council

Coverall Cleaning Concepts utilizes the National Safety Council's Bloodborne Pathogen

Training Class.

· American Red CrossTrainers instwct on the following American Red Cross programs and courses:

1. HIV / AIDS Education Program

2. Preventing Disease and Transmission Course

3. Bloodborne Pathogen Course

These state-of-the-art training programs enable our Franchise Owners to provide

cleaning services to a wide variety of industries including healthcare facilities, food

service operations, high tech manufacturing plants, bio-tech industries, clean rooms,

airports and other specialized environments.

Coverall Cleaning Concepts keeps abreast of current industry safety requirements as

published by the Occupational Health and Safety Administration, National Safety

Council, and the American Red Cross. With these safety programs in place, you can

trust Coverall Cleaning Concepts to safely clean your commercial facility.

5 e r vie e 5 -t,~.~r~~..

Page 72: Espada Reply to Subpoena

services

services

services

services

Rev. 1 2/06 services

.

Minutman"

Success in the cleaning business requires the right equipmentwith the right chemicals. To accomplish this, we have developedstrategic partnerships with some of the world's leading chemical

and equipment manufacturers.

¿: p&G(PROlINE'"~

Coverall's alliance with Procter & Gamble, the world's largestconsumer products company, allows us to offer the most effectivecommercial products available to service your facilities. As ourauthorized supplier, P&G and their Pro Line products increaseFranchise Owner productivity to deliver superior service to ourcustomer accounts,

P&G Pro Une products deliver an outstanding appearance, giving your facility more shineand durability and less maintenance, rework or problems. Countless medical studies havedemonstrated that using a viruscide/germicide cleaner in the work environment limits thespread of infection, Coverall uses P&G Pro Line Hospital-grade disinfectant cleaners atour customer accounts to ensure a high level of sanitation and reduce customer costs bydecreasing the expenses associated with employee illnesses.

High guality results, consistency and cost effectiveness can only be achieved throughthe use of the proper tools, One of the advantages ofdoing business with Coverall Cleaning Concepts is ourability to make the most state-of-the-art equipmentavailable for our Franchise Owners to increase theirproductivity, thereby providing the best value to ourcustomers.

Coverall Cleaning Concepts' team of qualified techniciansare trained with the most cutting edge techniques in chemical handling and equipmentoperations, You can be assured that your Coverall management team has made acareful analysis of the equipment requirements for your facility.

From paper products and hand soap dispensers to plastic trash liners, each CoverallCleaning Concepts Regional Support Center can provide and ship expendablesupplies directly to your facility in large or small (single case) quantities. as needed.Janitorial supplies are ordered and carefully inventoried by our Franchise Owners,giving you the benefit of hassle-free supply maintenance. By taking a nightly inventoryof your supplies on hand, our Franchise Owners will inform you in a timely mannerwhen supplies need to be reordered.

Through our national vendor partnerships, we are able to pass along our volumepurchasing power for chemicals and equipment to our customers. This allows us tooffer you competitive pricing and convenient purchasing for your expendable supplyneeds. For added convenience, supplies will be biled monthly - separate from anyservices provided to you.

5 e r v c e 5 -t,~.'7F!g~r4

Page 73: Espada Reply to Subpoena

.

One of the most important factors in selecting a commercial cleaning provider

is whether they can provide full protection of your assets. Coverall Cleaning

Concepts' Franchise Owners are required to cariy the strongest insurance

protection in the cleaning industiy. With Coverall, you can proceed with

confidence knowing that our Franchise Owners have:

. Workers Compensation as required by State law

. Comprehensive General Liability of $5,000,000

. Automobile Liability of $50,000

· Surety Bond of $100,000

ser'!ice:5

services

services

services

Rev, 12/06 services5 e r v c e s. ~f1.¥.~~~~

Page 74: Espada Reply to Subpoena

.

At Coverall Cleaning Concepts, the image that we project ascleaning professionals is not only evident in our superior cleaningservices but in the daily appearance of our service providers, All ofour Franchise Owners are uniformed and wear identification badgesat all times, Our professional apparel program lets our customersknow that our Franchise Owners wear the Coverall CleaningConcepts name with pride; the kind of pride our customers have for their facilities.

In an industry fueled by immensetechnological possibilities, CoverallCleaning Concepts continually explores new and innovative ways to communicatewith customers, With a well-established communication system in place. 'M) havethe capability to effectively address the concerns of our customers anci p::jJideimmediate results.

.

services

Communication is the driving pulse that keeps our system running SmOGjfily, day-inand day-out. At Coverall Cleaning Concepts, our expert staff is readili' :),):hle toassist you with all of your cleaning needs - 24 hours a day, 365 days a year. Ne haveseveral ways to communicate with you, each individually suited according to yourspecific business needs. These are as follows:

.:::d?t,t,?i . Contact Coveralls local Support Center through our. . .".;it:'.:.:. 24-hour Customer Respon~e Phone System.

\.. . ..:' ~.

". . Gain direct online contact with our Operations

Department and Project Coordinators via email and/or fax.

. Coverall Franchise Owners are accessible 24 hours a day by cell phone.

services . Real time communication from our FranSysTM Mobile application delivering resultsof inspections and on site visits to Customer Service personnel in your localSupport Center.

services. Communicate with your Franchise Owner through Coverall's Log Book and

Coveralls customer service extranet site: www.coverall.com/suDDort.

servicesEliminate billing hassles. With Coverall Cleaning Concepts, whether your cleaningneeds are for a single facility or for multi-locations across the nation, your business wilreceive one itemized, easy-to-understand invoice that is generated r-t Vr\;i(:!i:,,3iç;'-iatedRegional Support Center each month, Electronic fie interchange ca¡:abiiiues dre ¿¡Isoavailable upon request. s e r vie e s ~;?~F~~Rev. 1 2/06 services

Page 75: Espada Reply to Subpoena

services

services

services

services

Rev, 12/06 services

.

Coverall Cleaning Concepts works closely with you to make

your start -up as smooth and effortless as possible. Our

Customers for Life'" program helps to ensure that you get off

to a good start by providing a framework through which all

initial, interim, and long-range customer needs are met.

This dynamic program was created to establish long term

quality standards throughout the customer life cycle by means of a progressive three-

part program which targets the distinct phases of the customer life cycle: Target 90,

Focus 180, and CAR.E (Communication, Action, Resolution, Evaluation)

From your first day of service, Coverall Cleaning Concepts' proven strategies are in

place to guarantee the highest level of quality service. Based on a strong commitment

to customer satisfaction, the Target 90 and Focus 180 phases of the program are key

to a trouble-free transition.

CUSTOMERS FOR LIFE PROGRAM

TARGET 90:During the first 90 days, Coverall Cleaning Concepts and our Franchise Owners keep a

careful watch on customer satisfaction.

Your Field Consultant wil strategically match your site-specific needs with aFranchise Owner prior to the account start.

. The Franchise Owner wil conduct a facilty walk-through, and the Field Consultantand Account Contacts wil define work specifications, security, and safety issues

as well as all special service requirements of the facilty.

. Your Field Consultant wil provide a start-up package,

which includes a welcome letteroutlining the range of support services available and alogbook. The logbook is a communication tool used to

address immediate needs as they arise.

. A call placed by your Field Consultant wil review how the

start-up met expectations.

. The local Regional Support Center wil contact you within 30, 60,and 90 days of the initial service dates. These calls are placed to

solicit important feedback.

. The Field Consultant wil conduct a monthly on-site inspection/survey

to help insure customer satisfaction with theervices provided.

s e r v c e s .O~E~~,ff,... ~

Page 76: Espada Reply to Subpoena

. A monthly on-site inspection/survey program enables us to meet theever-changing needs of facility managers.

.FOCUS 180:This six-month program helps to ensure

continuous quality service.

. Your local Regional Support Center wil continueto place customer feedback calls every 30days to ensure open communication channelsand quality service.

. Coverall Cleaning Concepts wil conduct a Franchise Owner Account Review toensure that current work schedules are performed in accordance with your needs.

. On the six-month anniversary, Coverall Cleaning Concepts will perform a FieldConsultant Review to help further ensure long-term quality service.

C.A.R.E.The third component of the Customers for Life program is CAR.E This component is

speCifically designed to ensure long-term quality service by focusing on the specific

on-site requirements and the individual needs of each Coverall

Cleaning Concepts' customer, Each letter of CARE stands for

a step in creating an unmatched system for keeping customers

satisfied with the long-term quality of services provided,

c: Communication is vital in establishing a strong relationship

between a company and its customers. Our extensive

communication system is in place to provide on call assistance

when needed.

St'.';'ii ~.t~t: t: A: Action is taken continually to achieve optimal results. In

improving the quality of service you receive, Coverall Cleaning

Concepts will recommend additional services that will help enhance the appearance of

your facility and/or rectify a problem area.services

R: Resolution confirms that your facility's cleaning service plan is in place and working,

The Regional Support Center wil follow up with each customer to achieve this goal.

servicesE: Evaluation measures the effectiveness of each pre-approved plan by means of a

tracking and reporting system.

services

Rev. 12/06 servicess e r v ~S~~~c e s "....,. ""

Page 77: Espada Reply to Subpoena

sønJ¡~;es

services

services

services

Rev. 12/06 services

.

Coverall Cleaning Concepts offers a national janitorial cleaning prograrp Jor c;ompanieswith multiple locations nationwide - Öur'N.a.t,ionaIAGGOuntsPrograrn,. .lhis program is

solely dedicated to multi-locationCollpar\i~ Witn a mi.ssion to pròl/idec()llpetitive'.' volume pricing; one contract and iternizaq~inlJtiiceforaILlo¿Clt¡qnš; :átQII~frè~customer. service line and the consistent qualityaSsqd;in'cyömoneveridUr maria~ing.~the' service. for all your sites. '.;:~.:).

~ê~iil,f_~~~rcr;~~~::~;1r~~~~~~i~~ili~G'~1.lf~~!!t,then provide you with a . cömpetitiljè'P'riS~;(Ø( all ofy()ur:sérvicenE:~qjêY

l~~~~~~~~~~~i:~i~~~~~~:~~~~~~~l~~~~t:' ,"AC, lW~~k~~'\":_. '_:,',. '. i.."',(:schedule for all of your locations based on your requirem~nts. By,. .... ding your':company with a concise, understandable schedule for every aspeq't,'öf your facility's

cc:leaning, we are able to place a greater emphasis on your specific priority areas"':'gjving your facility the clean, well-maintained appearance that you expect.

C;entralized Billng Capabilties: Our centralized billing department is ableto. 'provide one single bill per month for the services performed at all of your 10c;citi?ns.

'Electronic data invoicing and summary bill are also available upon reques!¡," ....:'.:;l.:".~: ;'.~~¡_~_.~.'::':\~:

.t.' .

A P¡lrtnershipYol, Ç~n Count On " . '. " ....We firr:nly believetha.t.a?s,Wçc:essful partnership based on the following b?$ic:¡3lerrénts

. gLiaraiiteesthàt~~wi).Ihfíê'èf'orE3xceed all customer expë¿tèt¡önš,:""2"'~' · ' .... d. ..:i.

.~~,S¡i,i2.,,ri~I~~~;i~~~~!~'~i: VæOO"ddédCS, '~èVl ~~IÛi1~i;h~tr~~,

: F::.~i~. .' : .~~~~:~r~~l~~

.. Cqverall.Frärljf

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. For m~;:~~f:~:I~Zßn~~hQ;.President of Säleia.tftìéÔlbbkcS8ppo. .

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Page 78: Espada Reply to Subpoena
Page 79: Espada Reply to Subpoena

.

At the foundation of Coverall Cleaning Concepts' customer support system are our

Regional Support Centers. Coveralls unbeatable team comprised of Operations,

Training & Development, Quality Assurance and Administration and Sales staff are

readily available to assist you.

SUpt1fj~-~

support

support

Rev. 12/06 support5 U P P 0 r t -tn.l7r~~

Page 80: Espada Reply to Subpoena

Sli¡JPOl~

support

support

Rev. 1 2/06 support

.

When it comes to customer support. having a well-established infrastructure is a

critical factor in not only keeping the lines of communication open, but also in helping

to foster long-term relationships with customers. Our support system allows

customers to obtain up-to-the-minute assistance on virtually any request.

Your Franchise Owner is supported by a strategic network of cleaning professionals.

each dedicated to assuring your complete satisfaction. If you have a concern that

needs immediate attention, you can contact your Franchise Owner, Customer Service

Representative, and/or Field Consultant. The Customer Serce Represtatie will call

you monthly to ask for quality performance ratings on our work. For technical

assistance, your ReId Consultant wil act as a liaison between you and the Franchise

Owner in order to achieve the highest level of quality work. This team is further

supported by an Operations Manger who provides additional support in resolving all

service and operational issues. A Regiona Direcor manages your local Regional

Support Center and is responsible for maintaining overall quality control. Our Glo

Support Center guarantees that you are never more than a phone call away from all

the benefits and resources that our experienced staff has to offer.

5 U P P 0 r t ~,~.I!F~

Page 81: Espada Reply to Subpoena
Page 82: Espada Reply to Subpoena

fjur ;C:USif.~nf;rS

our customers

our customers

our customers

our customers

Rev. 12/06

.

Coverall Cleaning Concepts has established an industry.wide reputation for its

unbeatable service record. This is attributed to an owner-operated system of

Franchise Owners who have a vested interest in providing the best service possible.

Your satisfaction is a testament to their success. With Coverall Cleaning Concepts,

satisfaction is our #1 priority, which has enabled us to service many nationally known

companies including:

Alltel

Apria Health CareBedrosiansBright Horizon Learning CentersBrighton CollectiblesCheeburger CheeburgerCentral Transport, Inc.DalTileDankaEagle Global Logistics

Emser TileFederal ExpressFergusonFresenius Medical GroupGE CapitalGeorge FernGevity HRHear-XHousehold/Beneficial Finance GroupHuntington Learning CentersKaplan Learning CentersLibert Travel

Opportunities for LearningOrkin Pest ControlQuest DiagnosticsR&L CarriersSave-A-LotSchenkerScore Learning CentersSprintStock BuildingSylvan LearningTiffany'sVerizonWaste ManagementXO Communications

our cu. tom e r 8 't.,~~,

Page 83: Espada Reply to Subpoena
Page 84: Espada Reply to Subpoena

l,'.!t:trk

vøcWcatkms

workpecifications

work;pecifications

work;pet... )ations

Rev. 12/06 workipecifications

.

We know that a critical concern for every manager is the transition from one vendor to

another. That is why we take this period of time so seriously, It can easily mean the

difference between failure and long-term success with our clients and their customers,

We take several steps to ensure that this time becomes the foundation of a long and

mutually beneficial relationship.

Franchise Owner selection is critical because this one individuål, more than any other,

is the key link in the chain of a successful cleaning program. We will make sure that

this person has the experience, training and temperament for your propert.

A Start-Up Team is assigned to each new account. This is a group of professionals

whose function is to ensure that the first day or night cleaning and the first week of

cleaning are as flawless as possible. This team includes the Franchise Owner, a Field

Consultant and the Outside Sales Consultant.

A transition plan is them implemented, which charts each step taken and the person

responsible for each step.

Additional crew members and supervision is provided to ensure that there are enough

people available to get the job done at peak performance,

work .peClflcatlons-r,~F'~;

Page 85: Espada Reply to Subpoena

COVERALL CLEANING CONCEPTSHealthcare Facility Work Schedule:

CateQorvlService How often?

PATIENT USE AREAS, OFFICES, ENTRANCES,RECEPTION AREAS. HALLWAYS. CONFERENCE ROOMSDust and clean using color coded microfiber cleaning cloths and 6 times weekSpic & Span hospital grade disinfecting all purpose spray and glass cleaneron all fixtures and offce furniture including file cabinets, desks,credenzas, counter tops, display units and window ledges,Spot clean doors, door frames, light switches, walls and properlyposition furniture in offces.

Empty all waste paper receptacles and take trash to a designatedarea in the building for storage or removaL. Any hazardous wastematerial marked in approved containers may be taken to adesignated area. Coverall Cleaning Concepts does not offertiazardous waste disposal services.

Wipe all internal partition glass free of smudges and fingerprints,using color coded microfiber cloths and Spic & Span hospital gradedisinfecting all purpose spray cleaner.

Clean and sanitize drinking fountains / water coolers using colorcoded microfiber cloths and Spic & Span hospital grade disinfectingall purpose spray and glass cleaner.

.~c~-: .~~

-:f;,.J

Dust all high and low vertical and horizontal surfaces and cornersnot cleaned in the course of normal dusting with electrostaticdusting cloths,

Clean and sanitize hand sinks and surrounding counters usingcolor coded microfiber cloths with Spic & Span hospital gradedisinfecting all purpose spray and glass cleaner.

Clean and sanitize all telephones using color coded microfibercloths with Spic & Span hospital grade disinfecting all purposespray and glass cleaner.

Vacuum fabric covered furnishings. Wipe other furniture using colorcoded microfiber cloths with Spic & Span hospital grade disinfectingall purpose spray and glass cleaner.

Clean and polish all chrome chairs and tables using color codedmicrofiber cloths with Spic & Span hospital grade disinfecting allpurpose spray and glass cleaner,

Dust blinds, sills, jams, light fixtures and ceiling vents withelectrostatic dusting cloths, ~-

initiaVinitial

§. times week

§. times week

§. times week

§. times week

§. times week

§. times week

1 times month

1 times month

1 times month

Coverall Cleaning Concepfs

Page 86: Espada Reply to Subpoena

EXAM ROOMS I LAB AREASThoroughly scrub and disinfect sinks & countertops using color coded §. times weekmicrofiber cloths with Spic & Span hospital grade disinfecting allpurpose spray cleaner.

Clean and disinfect all treatment area surfaces and fixtures using §. times weekcolor coded microfiber cloths with Spic & Span hospital grade disinfectingall purpose spray cleaner.

Clean and disinfect all furniture in the waiting area using §. times weekcolor coded microfiber cloths with Spic & Span hospital grade disinfectingall purpose spray cleaner.

Dust bases of exam room tables using color coded microfiber §. times weekcloths with Spic & Span hospital grade disinfecting all purpose spray cleaner.

Dust and damp mop floor areas with approved disinfectant §. times weekusing color coded microfiber flat mopping system and Mr. Clean disinfectingfinished floor cleaner, changing pad often to ensure removal of soiL.

Terminal clean all surgical areas, clean rooms and laboratorieswall to wall and floor to ceiling using color coded microfiber clothswith Spic & Span hospital grade disinfecting all purpose spray cleaner.

N/A times week/month

FLOORS. CARPET. TILE. CONCRETEVacuum with approved back pack units and remove fresh spotsfrom all carpeted areas using approved disinfectants andencapsulating carpet spotting tools.

§. times week

Mop all hard surface floor areas using color coded microfiberflat mopping system and Mr. Clean disinfecting finished floor cleaner,changing pad often to ensure removal of soiL.

§. times week

,"'.~ ;.~

.1' Strip and refinish resilient floors (Recommend at 18 to 24 monthsunder Coverall Cleaning Concepts' Healthcare Cleaning ServicesProgram),

~ times year

, Spray Buff floors 1 times month

KITCHENS. CAFETERIAS. LUNCH ROOM. COFFEE AREASAll kitchen counters, tables and sinks cleaned using color codedmicrofiber cloths with Spic & Span hospital grade disinfecting allpurpose spray and glass cleaner.

§. times week

_1-inilîaVinilial

Coverafl Cleaning Concepts'

Page 87: Espada Reply to Subpoena

RESTROOMSClean and polish all dispensers and fixtures, Clean and disinfectwash basins, toilet bowls, urinals, and counter tops using colorcoded microfiber cloths and Comet disinfecting bathroom cleaner.

~ times week

Spot clean walls and toilet partitions with color coded microfibercloths and Spic & Span hospital grade disinfecting all purposespray and glass cleaner,

~ times week

Mop all floors using coded microfiber flat mopping system andMr. Clean disinfecting finished floor cleaner changing pad oftento ensure removal of all soil and materials.

~ times week

Polish all metal and mirrors using color coded microfiber clothswith Spic & Span hospital grade disinfecting all purpose sprayand glass cleaner

Restock expendable products such as paper towels, toilet tissue,hand soap, liners and deodorant products.

6 times week

6 times week

ADDITIONAL DUTIES

times week/month

times week/month

times week/month

() times week/month

times week/month

CLOSING INSTRUCTIONSClean janitor closet. ~ times week

Turn off designated lights (as instructed). ~ times week

Lock doors and windows (as instructed). ~ times week

Set alarm (if applicable and as instructed). ~ times week

_1-initiaVinilial

Coverall Cleaning Concepfs

Page 88: Espada Reply to Subpoena

On occasion, services other than the regularly scheduled janitorial duties may be required. COVERALL CLf':CONCEPTS will perform these services when requested, and invoice separately from the general monthIY~:dunless the services are specifically included in your monthly billing. If a special service is included, 1/12 of!ht'is included in each monthly charge,

ontract,',,¡ charge

COVERALL CLEANING CONCEPTS is also able to assist with many other cleaning needs, and will provide qj¡'~ :: for anyof the following special services upon request:

Carpet cleaningOffce furniture cleaningUpholstery cleaningWindow cleaningPower washingWaste receptacle washingEmergency cleaning (fire, flood, etc.)Providing of dispenser suppliesReplacement of burned out bulbs from customer supplyCeiling cleaningFioor stripping and refinishingRestroom sanitation I odor control

To arrange for any of the above services, please contact your COVERALL CLEANING CONCEPTS SUppOi\convenience.

:t your

~;",..

"yw:1:.. .-:

Covenii, '.As(id.wm

Copyright (g 2007

Page 89: Espada Reply to Subpoena
Page 90: Espada Reply to Subpoena

.

Coverall Cleaning Concepts provides you with a customized program des;-,i ,.j to

meet the needs of both your facility and your budget. In order to ensure "J.' 3.te

pricing and bidding, Coverall Cleaning Concepts uses site-specific prodw! ' .1tes

based on industry standards in accordance with the International Sanit3:.., i

Association (ISSA). The production rates are determined using the Squ ,er

Day Method. This method defines the average number of square mete

Franchise Owners can clean during a given day. Accurate cleaning tin~c'

determined by measuring and recording the actual work completed dui'

period in a facility. By utilizing the standard ISSA production rates, Cove':' 9Concepts' Outside Sales Consultants can bid your facility with unprecedp,

accuracy, ensuring competitive pricing.

. ,, pricing

~.~';J~nn

pricing

pricing

iricing

Rev. 1 2106p r .l i

C i n 9 Wr,;;:if:~: '- ,~

pricing

Page 91: Espada Reply to Subpoena

ri(:¡I~!1

pricing

pricing

iricing

(' \... ~.

pricing

Rev. 12106

pricing

GROWTHWe offer you a proven track recordwith years of experience in thecleaning industry - now servicingover 40,000 clients.

CUSTOMIZED CLEANINGSPECIFICATIONSWe work with you to assess theneeds of your facilty to develop anaction plan that will achieve thehigñêst level of "clean" you desire.

.

QUOTATIONWe customize a quote that is site-specificto your facility and your budget restraints.

OWNER INVESTMENTWe select a Franchise Owner who istrained and qualified to meet your cleaningexpectations.

QUALITY ASSURANCEWe provide you with quality janitorial serviceson a consistent basis. Our Quality AssurancePersonnel will call you monthly to assurecontinued quality janitorial cleaning. We assurecontinued satisfaction through ongoing customersupport and inspections.

AVAILABILITYWe are accessible to you 24 hours a day, 365 days a year.

CUSTOMERS FOR LIFE PROGRAMWe provide thorough follow-up within 48 hours after service begins and throughoutyour contract.

CONTINUED SUPPORTWe provide prompt and effective response foremergencies or inquiries.

TRAININGOur Franchise Owners have access to the most advancedtraining on the use of the necessary equipment, chemicals and supplies, as well asefficient techniques that can help you save time and money. .....

CERTIFICATIONOur Franchise Owners provide you with proof of insurance, janitorial bond, andworkers' compensation insurance where applicable.

REFERENCES/TESTIMONIAL LETTERSWe provide you with a list of customers.

p r i c n 9 ~,~~:=~~ml

Page 92: Espada Reply to Subpoena

Locations

731 Whte Plais Road3 Porters 6 days per week 7:30am-830pm-$16,965

Nightly Clean (8.5hours)-$3,451Floor maIntenance-$l ,000

Tota: $21,416

2727 Whte Plais Road

1 Porter 6 days per week 7:30am-5:30pm-$4,350Nightly Clean (2 hours)-$812

Floor maIntenance-$136Tota: $5,298

610 Castlehi Road1 Porter 6 days per week 7 :30am-5:30pm-$4,350

Nightly Clean (3 hours)-$1,218Floor maIntenance: $136

Tota: $5,704

f)1760 Westchester Avenue

1 Porter 6 days per week 7:30am-5:30pm-$4,350Nightly Clean (5 hours)-$2,030

Floor maIntenance-$335Tota: $6,715

821 Eat 233"' Street .2 Porters 6 days per week 7:30am-5:30pm-$8,700

Nightly Clean (6 hours)-$2,436Floor maIntenance-$380

Tota: $11,516

165 E. Burside Avenue2 Porters 6 days week 7 :30 am-5:30pm-$8,700

Nightly Clean (6 hours)-$2,436Floor maIntenance-$380

Tota: $11,516

Page 93: Espada Reply to Subpoena
Page 94: Espada Reply to Subpoena

&e~~~~~~CLEANING CONe TSl Cleaning ContractThe undersigned Soundview Health Center ("CUSTOMER") hereby accepts the proposal of Coverall North America, Inc.d/b/a Coverall Cleaning Concepts ("COVERALL") to supply Janitorial Services for CUSTOMER's premises located at:

-Address:-City, State, ZIP:

731 White Plains RoadBronx NY 10473

Upon the following terms:

1. COVERALL's Service Charge will be

$21.416 plus applicable tax per month, to include §. times per week service. Initial

The Janitorial Services are to be performed in the evening, unless otherwise agreed to by the parties.

2. CUSTOMER acknowledges that COVERALL will delegate all Janitorial Services to be performed hereunder to aCOVERALL franchisee and/or subcontractor.

3, Included in the service charge will be service, cleaning supplies, and any equipment which will be furnished by the

COVERALL franchisee The service charge does not include liners, paper supplies, and toiletries, which can beprovided at CUSTOMER's expense, at competitive prices. The service charge also does not include any use tax, taxon sales, services or supplies, or other such tax, which taxes shall be paid by CUSTOMER. CUSTOMER agrees toreimburse COVERALL the amount of any such taxes if paid by COVERALL on CUSTOMER's behalf.

4. All Janitorial Services specified in the "Work Schedule" attached to this proposal will be provided to CUSTOMER in asatisfactory manner.

5. All COVERALL franchisees have successfully completed COVERALL's comprehensive training program and arerequired to carry insurance and a janitorial bond.

6. Additional services, not included in COVERALL's service charge, to be performed upon request, priced peroccurrence, at CUSTOMER's expense, include:

Area and Square Footage

a. Strip & Wax Floors $

b, Scrub & Recoat Floors $

c. Burnish Floors $

d, Hot Water Extract Carpets $

e. Window Washing $

f. Initial Cleaning $ to include

g, Other $

Additional services accepted by:Customer Signature

7. (a) The term of this Contract is for one (1) year. This one-year period shall begin on the date services are scheduled

to begin (the "Effective Date"). This contract shall automatically extend for additional one (1) year periods, unless atleast thirty (30) days prior to each anniversary of the Effective Date, either party gives the other written notice of itsintent not to renew.

_1-initial/initial

December 20062006~ Coverall North America, Inc.

Page 1 of3 Premium Account Contract

Page 95: Espada Reply to Subpoena

(b) Termination/Notice: If a part to this Contract fails to perform its obligations (the "Non-Performing Part"), thepart claiming non- performance shall send the Non-Performing Party written notice by either facsimile or overnightmail/delivery, specifying the manner of non-performance. This notice wil provide that the Non-Performing Part shallhave fifteen (15) days from receipt of the notice to cure or correct the non-performance, If not corrected or cured withinthis fifteen (15) day period, the claiming part may issue a thirty (30) day written notice of termination and/or pursueother available remedies for default

(c) Notwithstanding the above, COVERALL may, but shall not be obligated to, terminate this Contract immediately fornon-payment by CUSTOMER

8. The Service Charge will remain in effect for one (1) year unless there are changes in the original specifications forthe premises. In the event of such changes, CUSTOMER will advise COVERALL accordingly, and an adjustment inthe service charge. as agreed to by the parties, will be made.

9, CUSTOMER agrees that it will not employ or contract with any COVERALL employee, franchisee, or any of thefranchisee's employees during the term of this contract or for one hundred and eighty (180) days after termination ofthis contract, without COVERALL's written consent

10, COVERALL will bill CUSTOMER monthly, and CUSTOMER agrees to pay COVERALL the amount that is due andowing under the terms of this contract within 10 days of billing date. Late payments will incur service and financecharges at the rate of 1.5% per month, In the event of default on payment, CUSTOMER agrees to pay COVERALL'sattorney's fees and costs for collection,

11. Services shall be performed as scheduled with the exception of the following six (6) legal holidays: New Years Day,Memorial Day, Independence Day, Labor Day, Thanksgiving Day and Christmas Day. However, service can beprovided on these holidays at an additional cost if required. Services shall be scheduled during the hours approvedor directed by manager/owner.

DMonday DTuesday OWednesday OThursday OFriday OSaturday OSunday(Days of the week on which service is to be provided)

12. If there is an "Additional Special Services" Addendum attached to this Contract, and if CUSTOMER cancels anyperiodic Special Services described therein for which a prorated monthly charge is included in CUSTOMER's totalmonthly service charge, any amount owing by CUSTOMER for Special Services performed prior to the cancellationshall be payable in full no later than five (5) days after the cancellation,

13. The undersigned warrant and represent that they have full authority to enter into this Contract, and that it will bebinding upon the parties and their respective successors and assigns.

14. This Contract and attached exhibits constitute the complete agreement of the parties concerning the provision ofcleaning services to the CUSTOMER, and supersedes all other prior or contemporaneous agreements between theparties, whether written or oral, on the same subject No waiver or modification of this Contract shall be valid unlessin writing and executed by COVERALL and CUSTOMER Additionally, in no event shall the terms and conditions ofany purchase order or other form subsequently submitted by CUSTOMER to COVERALL becomes a part of thisContract, and COVERALL shall not be bound by any such terms and conditions.

15, This Contract does not become binding upon COVERALL unless and until COVERALL obtains a satisfactory creditreport on the CUSTOMER and COVERALL, in its sole discretion, approves the CUSTOMER. The followinginformation is required:

Customer Headquarters:Type of Entity:Federal Tax 10 No,:State of Incorporation:Date Incorporated:Contact Name:Contact Telephone Number:

(Company Name/Address)OCorporation OPartnership OSole Proprietorship DLLC

December 2006

2006ii Coverall North America, Inc.Page 2 of3 Premium Account Contract

Page 96: Espada Reply to Subpoena

16, If the CUSTOMER is either a sole proprietorship or partnership, CUSTOMER upon executing this Cor' 'Jct herebyconsents to a credit review by COVERALL

CUSTOMER

Authorized Signature'

Print Name and Title' N. New Jersey'

t~/3~b 7Date .-c-cCustomer;;;; .

E-mail Address' Service Start Date'

Please fax signed contract to 201-438-19..tDate'

December 20062006(! Coverall North America, Inc.

Page 3 of3 Premium Account Contract

Page 97: Espada Reply to Subpoena

&.e~~~4~fCLEANING CONC T Cleaning ContractThe undersigned Soundview Health Center ("CUSTOMER") hereby accepts the proposal of Coverall North America, Inc.d/b/a Coverall Cleaning Concepts ("COVERALL") to supply Janitorial Services for CUSTOMER's premises located at:

-Address:-City, State, ZIP:

2727 White Plains RoadBronx NY 10473

Upon the following terms:

1. COVERALL's Service Charge will be

$$5.298 plus applicable tax per month, to include 6 times per week service. Initial

The Janitorial Services are to be performed in the evening, unless otherwise agreed to by the parties.

2. CUSTOMER acknowledges that COVERALL will delegate all Janitorial Services to be performed hereunder to aCOVERALL franchisee and/or subcontractor.

3, Included in the service charge will be service, cleaning supplies, and any equipment which will be furnished by the

COVERALL franchisee The service charge does not include liners, paper supplies, and toiletries, which can beprovided at CUSTOMER's expense, at competitive prices. The service charge also does not include any use tax, taxon sales, services or supplies, or other such tax, which taxes shall be paid by CUSTOMER. CUSTOMER agrees toreimburse COVERALL the amount of any such taxes if paid by COVERALL on CUSTOMER's behalf.

4. All Janitorial Services specified in the "Work Schedule" attached to this proposal will be provided to CUSTOMER in asatisfactory manner,

5. All COVERALL franchisees have successfully completed COVERALL's comprehensive training program and arerequired to carry insurance and a janitorial bond.

6. Additional services, not included in COVERALL's service charge, to be performed upon request, priced peroccurrence, at CUSTOMER's expense, include:

Area and Square Footage

a. Strip & Wax Floors $

b. Scrub & Recoat Floors $

c. Burnish Floors $

d, Hot Water Extract Carpets $

e. Window Washing $

f. Initial Cleaning $ to include

g, Other $

Additional services accepted by:Customer Signature

7. (a) The term of this Contract is for one (1) year. This one-year period shall begin on the date services are scheduled

to begin (the "Effective Date"). This contract shall automatically extend for additional one (1) year periods, unless atleast thirty (30) days prior to each anniversary of the Effective Date, either part gives the other written notice of itsintent not to renew.

-'-initiaVinitial

December 2006

2006(9 Coverall North America, Inc.Page i of3 Premium Account Contract

Page 98: Espada Reply to Subpoena

(b) Termination/Notice: If a part to this Contract fails to perform its obligations (the "Non-Performing Part"), thepart claiming non- performance shall send the Non-Performing Party written notice by either facsimile or overnightmaiVdelivery, specifying the manner of non-performance. This notice will provide that the Non-Performing Part shallhave fifteen (15) days from receipt of the notice to cure or correct the non-performance, If not corrected or cured withinthis fifteen (15) day period, the claiming party may issue a thirty (30) day written notice of termination and/or pursueother available remedies for default.

(e) Notwithstanding the above, COVERALL may, but shall not be obligated to, terminate this Contract immediately fornon-payment by CUSTOMER.

8. The Service Charge will remain in effect for one (1) year unless there are changes in the original specifications forthe premises. In the event of such changes, CUSTOMER will advise COVERALL accordingly, and an adjustment inthe service charge, as agreed to by the parties, will be made.

9. CUSTOMER agrees that it will not employ or contract with any COVERALL employee, franchisee, or any of thefranchisee's employees during the term of this contract or for one hundred and eighty (180) days after termination ofthis contract, without COVERALL's written consent.

10. COVERALL will bill CUSTOMER monthly, and CUSTOMER agrees to pay COVERALL the amount that is due andowing under the tenns of this contract within 10 days of billng date. Late payments will incur service and financecharges at the rate of 1.5% per month, In the event of default on payment, CUSTOMER agrees to pay COVERALL'sattorney's fees and costs for collection.

11. Services shall be performed as scheduled with the exception of the following six (6) legal holidays: New Years Day,Memorial Day, Independence Day, Labor Day, Thanksgiving Day and Christmas Day. However, service can beprovided on these holidays at an additional cost if required. Services shall be scheduled during the hours approvedor directed by manager/owner.

DMonday DTuesday DWednesday DThursday DFriday DSaturday DSunday(Days of the week on which service is to be provided)

12. If there is an "Additional Special Services" Addendum attached to this Contract, and if CUSTOMER cancels anyperiodic Special Services described therein for which a prorated monthly charge is included in CUSTOMER's totalmonthly service charge, any amount owing by CUSTOMER for Special Services performed prior to the cancellationshall be payable in full no later than five (5) days after the cancellation.

13, The undersigned warrant and represent that they have full authority to enter into this Contract, and that it will bebinding upon the parties and their respective successors and assigns.

14. This Contract and attached exhibits constitute the complete agreement of the parties concerning the provision ofcleaning services to the CUSTOMER, and supersedes all other prior or contemporaneous agreements between theparties, whether written or oral, on the same subject. No waiver or modification of this Contract shall be valid unlessin writing and executed by COVERALL and CUSTOMER. Additionally, in no event shall the terms and conditions ofany purchase order or other form subsequently submitted by CUSTOMER to COVERALL becomes a part of thisContract, and COVERALL shall not be bound by any such terms and conditions.

15. This Contract does not become binding upon COVERALL unless and until COVERALL obtains a satisfactory creditreport on the CUSTOMER and COVERALL, in its sole discretion, approves the CUSTOMER. The followinginformation is required:

Customer Headquarters:Type of Entity:Federal Tax 10 No.:State of Incorporation:Date Incorporated:Contact Name:Contact Telephone Number:

(Company Name/Address)DCorporation OPartnership DSoie Proprietorship DLLC

December 2006

2006(Ï Coverall North America, Inc,Page 2 of3 Premium Account Contract

Page 99: Espada Reply to Subpoena

16. If the CUSTOMER is either a sale proprietorship or partnership, CUSTOMER upon executing this Contract herebyconsents to a credit review by COVERALL.

CUSTOMER

Authorized Signature.

Print Name and Title. N. ~:Î3~~ 7

Date.oeoeCustomer;:;: .

E-mail Address. Service Start Date.

Please fax signed contract to 201-438-1905Date.

;:~" .

December 20062006~ Coverall North America, Inc.

Page3 of 3 Premium Account Contract

Page 100: Espada Reply to Subpoena

&s~.!æ~~~CLEANING CONe T'5 Cleaning ContractThe undersigned Soundview Health Center ("CUSTOMER") hereby accepts the proposal of Coverall North /ô"l,-, ;ic.d/b/a Coverall Cleaning Concepts ("COVERALL") to supply Janitorial Services for CUSTOMER's premises 10c¡~G .H.

-Address:-City, State, z~p.

610 Castlehill RoadBronx NY

Upon the following terms:

1, COVERALL's Service Charge will be

$$5.704 plus applicable tax per month, to include § times per week service. Inital

The Janitorial Services are to be performed in the evening, unless otherwise agreed to by the parties.

2. CUSTOMER acknowledges that COVERALL will delegate all Janitorial Services to be performed hereumic d.' aCOVERALL franchisee and/or subcontractor.

3, Included in the service charge will be service, cleaning supplies, and any equipment which will be furni:';.', ;. .,"COVERALL franchisee. The service charge does not include liners, paper supplies, and toiletries, wh:provided at CUSTOMER's expense, at competitive prices. The service charge also does not include of; ( tax

on sales, services or supplies, or other such tax, which taxes shall be paid by CUSTOMER. CUSTOI\!: '., '0reimburse COVERALL the amount of any such taxes if paid by COVERALL on CUSTOMER's beh8if

4. All Janitorial Services specified in the "Work Schedule" attache€i to this proposal will be provided (0 C asatisfactory manner.

5. All COVERALL franchisees have successfully completed COVERALL's comprehensive training prow'.required to carry insurance and a janitorial bond.

6. Additional services, not included in COVERALL's service charge, to be performed upon request, pi:'- .\,occurrence, at CUSTOMER's expense, include:

Area and Square Footage

a. Strip & Wax Floors $

b. Scrub & Recoat Floors $

c. Burnish Floors $

d. Hot Water Extract Carpets $

e. Window Washing $

f. Initial Cleaning $ to include

g. Other $

Additional services accepted by:

Customer Signature

7, (a) The term of this Contract is for one (1) year. This one-year period shall begin on the date sei-Yi,.'."ed

to begin (the "Effective Date"). This contract shall automatically extend for additional one (1) year ¡A~ii(-;;:' . .3t

least thirty (30) days prior to each anniversary of the Effective Date, either part gives the other written ;":, . "

intent not to renew,

_/-initial/initial

December 2006

2006~ Coverall North America, Inc.Page I of3 Premium Account Contract

Page 101: Espada Reply to Subpoena

(b) Termination/Notice: If a part to this Contract fails to perform its obligations (the "Non-Performing Party"), theparty claiming non- performance shall send the Non-Performing Part written notice by either facsimile or overnightmail/delivery, specifying the manner of non-performance. This notice will provide that the Non-Performing Party shallhave fifteen (15) days from receipt of the notice to cure or correct the non-performance. If not corrected or cured withinthis fifteen (15) day period, the claiming party may issue a thirty (30) day written notice of termination and/or pursueother available remedies for default.

(c) Notwithstanding the above, COVERALL may, but shall not be obligated to, terminate this Contract immediately fornon-payment by CUSTOMER.

8. The Service Charge will remain in effect for one (1) year unless there are changes in the original specifications forthe premises, In the event of such changes, CUSTOMER will advise COVERALL accordingly, and an adjustment inthe service charge, as agreed to by the parties, will be made.

9. CUSTOMER agrees that it will not employ or contract with any COVERALL employee, franchisee, or any of thefranchisee's employees during the term of this contract or for one hundred and eighty (180) days after termination ofthis contract, without COVERALL's written consent.

10, COVERALL will bill CUSTOMER monthly, and CUSTOMER agrees to pay COVERALL the amount that is due andowing under the terms of this contract within 10 days of billing date. Late payments wil incur service and financecharges at the rate of 1.5% per month. In the event of default on payment, CUSTOMER agrees to pay COVERALL'sattorney's fees and costs for collection.

11. Services shall be performed as scheduled with the exception of the following six (6) legal holidays: New Years Day,Memorial Day, Independence Day, Labor Day, Thanksgiving Day and Christmas Day. However, service can beprovided on these holidays at an additional cost if required. Services shall be scheduled during the hours approvedor directed by manager/owner.

DMonday DTuesday DWednesday DThursday DFriday DSaturday DSunday(Days of the week on which service is to be provided)

12. If there is an "Additional Special Services" Addendum attached to this Contract, and if CUSTOMER cancels anyperiodic Special Services described therein for which a prorated monthly charge is included in CUSTOMER's totalmonthly service charge, any amount owing by CUSTOMER for Special Services performed prior to the cancellationshall be payable in full no later than five (5) days after the cancellation

13. The undersigned warrant and represent that they have full authority to enter into this Contract, and that it will bebinding upon the parties and their respective successors and assigns.

14. This Contract and attached exhibits constitute the complete agreement of the parties concerning the provision ofcleaning services to the CUSTOMER, and supersedes all other prior or contemporaneous agreements between theparties, whether written or oral, on the same subject. No waiver or modification of this Contract shall be valid unlessin writing and executed by COVERALL and CUSTOMER. Additionally, in no event shall the terms and conditions ofany purchase order or other form subsequently submitted by CUSTOMER to COVERALL becomes a part of thisContract, and COVERALL shall not be bound by any such terms and conditions.

15. This Contract does not become binding upon COVERALL unless and until COVERALL obtains a satisfactory creditreport on the CUSTOMER and COVERALL, in its sole discretion, approves the CUSTOMER. The followinginformation is required:

Customer Headquarters:Type of Entity:Federal Tax 10 No.:State of Incorporation:Date Incorporated:Contact Name:Contact Telephone Number:

(Company Name/Address)DCorporation DPartnership DSoie Proprietorship DLLC :.

December 2006

2006(Ç Coverall North America, Inc,Page 2 of3 Premium Account Contract

Page 102: Espada Reply to Subpoena

16, If the CUSTOMER is either a sole proprietorship or partnership, CUSTOMER upon executing this Contract i ¡arebyconsents to a credit review by COVERALL.

CUSTOMER

Authorized Signature'

Print Name and Title'

c:c:Customer;.;. .

E-mail Address'

Date'

December 2006

2006(9 Coverall North America, loc.

Page 3 of3

N. Nr~i3e:~ 7

Date'

Service Start Date'

Please fax signed contract to 201-438-1905

Premium Account Contract

Page 103: Espada Reply to Subpoena

&s~,!!l~~CLEANING CONG T Cleaning ContractThe undersigned Soundview Health Center ("CUSTOMER") hereby accepts the proposal of Coverall North America, Inc.d/b/a Coverall Cleaning Concepts ("COVERALL") to supply Janitorial Services for CUSTOMER's premises located at:

'Address:. City, State, ZIP:

1760 Westchester AveBronx NY

Upon the following terms:

1. COVERALL's Service Charge will be

$$6.715 plus applicable tax per month, to include §. times per week service. Initial

The Janitorial Services are to be performed in the evening, unless otherwise agreed to by the parties.

2. CUSTOMER acknowledges that COVERALL will delegate all Janitorial Services to be performed hereunder to aCOVERALL franchisee and/or subcontractor.

3. Included in the service charge will be service, cleaning supplies, and any equipment which will be furnished by the

COVERALL franchisee. The service charge does not include liners, paper supplies, and toiletries, which can beprovided at CUSTOMER's expense, at competitive prices. The service charge also does not include any use tax, taxon sales, services or supplies, or other such tax, which taxes shall be paid by CUSTOMER. CUSTOMER agrees toreimburse COVERALL the amount of any such taxes if paid by COVERALL on CUSTOMER's behalf.

4. All Janitorial Services specifieçl in the "Work Schedule" attached to this proposal will be provided to CUSTOMER in asatisfactory manner.

5, All COVERALL franchisees have successfully completed COVERALL's comprehensive training program and arerequired to carry insurance and a janitorial bond.

6. Additional services, not included in COVERALL's service charge, to be performed upon request, priced peroccurrence, at CUSTOMER's expense, include:

Area and Square Footage

a. Strip & Wax Floors $

b. Scrub & Recoat Floors $

c. Burnish Floors $

d. Hot Water Extract Carpets $

e, Window Washing $

f. Initial Cleaning $ to include

g. Other $

Additional services accepted by:Customer Signature

7. (a) The term of this Contract is for one (1) year. This one-year period shall begin on the date services are scheduled

to begin (the "Effective Date"), This contract shall automatically extend for additional one (1) year periods, unless atleast thirty (30) days prior to each anniversary of the Effective Date, either part gives the other written notice of itsintent not to renew.

-'-initiaVinitial

December 2006

2006~ Coverall North America, Inc,Page i of3 Premium Account Contract

Page 104: Espada Reply to Subpoena

(b) Termination/Notice: If a part to this Contract fails to perform its obligations (the "Non-Performing Part"), thepart claiming non- performance shall send the Non-Performing Part written notice by either facsimile or overnightmail/delivery, specifying the manner of non-performance. This notice will provide that the Non-Performing Part shallhave fifteen (15) days from receipt of the notice to cure or correct the non-performance. If not corrected or cured withinthis fifteen (15) day period, the claiming party may issue a thirt (30) day written notice of termination and/or pursueother available remedies for default.

(c) Notwithstanding the above, COVERALL may, but shall not be obligated to, terminate this Contract immediately fornon-payment by CUSTOMER.

8 The Service Charge will remain in effect for one (1) year unless there are changes in the original specifications forthe premises. In the event of such changes, CUSTOMER will advise COVERALL accordingly, and an adjustment inthe service charge, as agreed to by the parties, will be made.

9, CUSTOMER agrees that it will not employ or contract with any COVERALL employee, franchisee, or any of thefranchisee's employees during the term of this contract or for one hundred and eighty (180) days after termination ofthis contract, without COVERALL's written consent.

10. COVERALL will bill CUSTOMER monthly, and CUSTOMER agrees to pay COVERALL the amount that is due andowing under the terms of this contract within 10 days of billing date. Late payments wiU incur service and financecharges at the rate of 1.5% per month. In the event of default on payment, CUSTOMER agrees to pay COVERALL'sattorney's fees and costs for collection.

11. Services shall be performed as scheduled with the exception of the following six (6) legal holidays: New Years Day,Memorial Day, Independence Day, Labor Day, Thanksgiving Day and Christmas Day. However, service can beprovided on these holidays at an additional cost if required. Services shall be scheduled during the hours approvedor directed by manager/owner.

DMonday DTuesday DWednesday DThursday DFriday DSaturday(Days of the week on which service is to be provided)

DSunday

12. If there is an "Additional Special Services" Addendum attached to this Contract, and if CUSTOMER cancels anyperiodic Special Services described therein for which a prorated monthly charge is included in CUSTOMER's totalmonthly service charge, any amount owing by CUSTOMER for Special Services performed prior to the cancellationshall be payable in full no later than five (5) days after the cancellation,

13. The undersigned warrant and represent that they have full authority to enter into this Contract, and that it will bebinding upon the parties and their respective successors and assigns.

14. This Contract and attached exhibits constitute the complete agreement of the parties concerning the provision ofcleaning services to the CUSTOMER, and supersedes all other prior or contemporaneous agreements between theparties, whether written or oral, on the same subject. No waiver or modification of this Contract shall be valid unlessin writing and executed by COVERALL and CUSTOMER. Additionally, in no event shall the terms and conditions ofany purchase order or other form subsequently submitted by CUSTOMER to COVERALL becomes a part of thisContract, and COVERALL shall not be bound by any such terms and conditions.

15, This Contract does not become binding upon COVERALL unless and until COVERALL obtains a satisfactory creditreport on the CUSTOMER and COVERALL, in its sole discretion, approves the CUSTOMER. The followinginformation is required:

Customer Headquarters:Type of Entity:Federal Tax ID No,:State of Incorporation:

Date Incorporated:Contact Name:Contact Telephone Number:

(Company Name/Address)OCorporation OPartnership OSole Proprietorship DLLC

December 20062006~ Coverall Nort America, Inc,

Page 2 of3 Premium Account Contract

Page 105: Espada Reply to Subpoena

16. If the CUSTOMER is either a sole proprietorship or partnership, CUSTOMER upon executing this Contract herebyconsents to a credit review by COVERALL.

CUSTOMER

Authorized Signature.

Print Name and Title.

oec:Customer;:;: .

E-mail Address.

Date.

December 20062006~ Coverall North America, Inc.

Page 3 of3

NJI;~-:¡h

Date.

Service Start Date.

Please fax signed contract to 201-438-1905

Premium Account Contract

Page 106: Espada Reply to Subpoena

&e~~æ~~*CLEANING CONC T Cleaning ContractThe undersigned Soundview Health Center ("CUSTOMER") hereby accepts the proposal of Coverall North l~i, inc.

d/b/a Coverall Cleaning Concepts ("COVERALL") to supply Janitorial Services for CUSTOMER's premises k..' '. -0,: :t:

'Address:. City, State, ZIP:

821 E 233rd StBronx NY

Upon the following terms:

1. COVERALL's Service Charge will be

$$11,516 plus applicable tax per month, to include §. times per week service. Initial

The Janitorial Services are to be performed in the evening, unless otherwise agreed to by the parties.

2. CUSTOMER acknowledges that COVERALL will delegate all Janitorial Services to be performed hereu,', ,:. ~ aCOVERAL franchisee and/or subcontractor.

3. Included in the service charge will be service, cleaning supplies, and any equipment which will be furn!',;- he

COVERALL franchisee, The service charge does not include liners, paper supplies. and toiletries, ""J!'I.provided at CUSTOMER's expense, at competitive prices, The service charge also does not include di , ' :, tax

on sales, services or supplies, or other such tax, which taxes shall be paid by CUSTOMER, CUSTOM'; ", toreimburse COVERALL the amount of any such taxes if paid by COVERALL on CUSTOMER's behalf

4. - All Janitorial Services specified in the "Work Schedule" attached to this proposal will be provided in . in a

satisfactory manner.

5. All COVERALL franchisees have successfully completed COVERALL's comprehensive training pror¡.required to carry insurance and a janitorial bond.

6. Additional services, not included in COVERALL's service charge, to be performed upon request, pno"occurrence, at CUSTOMER's expense, include:

Area and Square Footage

a. Strip & Wax Floors $

b, Scrub & Recoal Floors $

c. Burnish Floors $

d. Hot Water Extract Carpets $

e, Window Washing $

f, Initial Cleaning $ to include

g. Other $

Additional services accepted by:Customer Signature

7. (a) The term of this Contract is for one (1) year. This one-year period shall begin on the date servi;:..:, .Ied

to begin (the "Effective Date"). This contract shall automatically extend for additional one (1) year pc....,,'. ; at

least thirty (30) days prior to each anniversary of the Effective Date, either party gives the other writtel1 .' . its

intent not to renew. ~-initiaVinitial

December 20062006~ Coverall North America, Inc,

Page 1 of3 Premium Account Contract

Page 107: Espada Reply to Subpoena

(b) Termination/Notice: If a part to this Contract fails to perform its obligations (the "Non-Performing Party"), thepart claiming non- performance shall send the Non-Performing Part written notice by either facsimile or overnightmail/delivery, specifying the manner of non-performance_ This notice wil provide that the Non-Performing Party shallhave fifteen (15) days from receipt of the notice to cure or correct the non-performance. If not corrected or cured withinthis fifteen (15) day period, the claiming part may issue a thirty (30) day written notice of termination and/or pursueother available remedies for default.

(c) Notwithstanding the above, COVERALL may, but shall not be obligated to, terminate this Contract immediately fornon-payment by CUSTOMER.

8. The Service Charge will remain in effect for one (1) year unless there are changes in the original specifications forthe premises. In the event of such changes, CUSTOMER will advise COVERALL accordingly, and an adjustment inthe service charge, as agreed to by the parties, will be made,

9. CUSTOMER agrees that it will not employ or contract with any COVERALL employee, franchisee, or any of thefranchisee's employees during the term of this contract or for one hundred and eighty (180) days after termination ofthis contract, without COVERALL's written consent.

10. COVERALL will bill CUSTOMER monthly, and CUSTOMER agrees to pay COVERALL the amount that is due andowing under the terms of this contract within 10 days of biling date, Late payments will incur service and financecharges at the rate of 1,5% per month. In the event of default on payment, CUSTOMER agrees to pay COVERALL'sattorney's fees and costs for collection.

11. Services shall be performed as scheduled with the exception of the following six (6) legal holidays: New Years Day,. Memorial Day, Independence Day, Labor Day, Thanksgiving Day and Christmas Day, However, service can be

provided on these holidays at an additional cost if required, Services shall be scheduled during the hours approvedor directed by manager/owner.

DMonday DTuesday DWednesday DThursday DFriday OSaturday DSunday(Days of the week on which service is to be provided)

12. If there is an "Additional Special Services" Addendum attached to this Contract, and if CUSTOMER cancels anyperiodic Special Services described therein for which a prorated monthly charge is included in CUSTOMER's totalmonthly service charge, any amount owing by CUSTOMER for Special Services performed prior to the cancellationshall be payable in full no later than five (5) days after the cancellation,

13. The undersigned warrant and represent that they have full authority to enter into this Contract, and that it will bebinding upon the parties and their respective successors and assigns.

14. This Contract and attached exhibits constitute the complete agreement of the parties concerning the provision ofcleaning services to the CUSTOMER, and supersedes all other prior or contemporaneous agreements between theparties, whether written or oral, on the same subject. No waiver or modification of this Contract shall be valid unlessin writing and executed by COVERALL and CUSTOMER. Additionally, in no event shall the terms and conditions ofany purchase order or.other form subsequently submitted by CUSTOMER to COVERALL becomes a part of thisContract, and COVERALL shall not be bound by any such terms and conditions_

15. This Contract does not become binding upon COVERALL unless and until COVERALL obtains a satisfactory creditreport on the CUSTOMER and COVERALL, in its sole discretion, approves the CUSTOMER. The followinginformation is required:

Customer Headquarters:Type of Entity:Federal Tax ID No.:State of Incorporation:Date Incorporated:Contact Name:Contact Telephone Number:

(Company Name/Address)DCorporation DPartnership DSoie Proprietorship DLLC

December 2006

2006~ Coverall North America, Inc.

Page 2 of 3 Premium Account Contract

Page 108: Espada Reply to Subpoena

16. If the CUSTOMER is either a sole proprietorship or partnership, CUSTOMER upon executing this Contract herebyconsents to a credit review by COVERALL.

CUSTOMER

ultant -Authorized Signature-

Print Name and Title - N. New Jersey -

Dalr-~~7Da e.....Customer~~ -

Service Start Date.E-mail Address -

Please fax signed contract to 201-438-1905

Date -

December 2006

2006~ Coverall North America, Inc,

Page 3 of3 Premium Account Contract

Page 109: Espada Reply to Subpoena

&e~~S!~~~CLEANING CONe. T~ Cleaning Contract

The undersigned Soundview Health Center ("CUSTOMER") hereby accepts the proposal of Coverall North America, Inc.d/b/a Coverall Cleaning Concepts ("COVERALL") to supply Janitorial Services for CUSTOMER's premises located at:

'Address:. City, State, ZIP:

165 E Burnside AvenueBronx NY

Upon the following terms:

1. COVERALL's Service Charge will be

$$11,516 plus applicable tax per month, to include ~ times per week service. Initial

The Janitorial Services are to be performed in the evening, unless otherwise agreed to by the parties.

2. CUSTOMER acknowledges that COVERALL will delegate all Janitorial Services to be performed hereunder to aCOVERALL franchisee and/or subcontractor.

3. Included in the service charge will be service, cleaning supplies, and any equipment which will be furnished by the

COVERALL franchisee. The service charge does not include liners, paper supplies, and toiletries, which can beprovided at CUSTOMER's expense, at competitive prices. The service charge also does not include any use tax, taxon sales, services or supplies, or other such tax, which taxes shall be paid by CUSTOMER CUSTOMER agrees toreimburse COVERALL the amount of any such taxes if paid by COVERALL on CUSTOMER's behalf.

4. All Janitorial Services specified in the "Work Schedule" attached to this proposal will be provided to CUSTOMER in asatisfactory manner.

5. All COVERALL franchisees have successfully completed COVERALL's comprehensive training program and arerequired to carry insurance and a janitorial bond.

6. Additional services, not included in COVERALL's service charge, to be performed upon request, priced peroccurrence, at CUSTOMER's expense, include:

Area and Square Footage

a, Strip & Wax Floors $

b. Scrub & Recoat Floors $

c, Burnish Floors $

d. Hot Water Extract Carpets $

e. Window Washing $

f. Initial Cleaning $ to include

g. Other $

Additional services accepted by:Customer Signature

7. (a) The term of this Contract is for one (1) year. This one-year period shall begin on the date services are scheduled

to begin (the "Effective Date"). This contract shall automatically extend for additional one (1) year periods, unless atleast thirty (30) days prior to each anniversary of the Effective Date, either part gives the other written notice of itsintent not to renew. ~-

initiaVinitial

December 2006

2006~ CoveralI North America, Inc,

Page i of3 Premium Account Contract

Page 110: Espada Reply to Subpoena

(b) Termination/Notice: If a part to this Contract fails to perform its obligations (the "Non-Performing Party'), thepart claiming non- performance shall send the Non-Performing Party written notice by either facsimile or overnightmail/delivery, specifying the manner of non-performance, This notice will provide that the Non-Performing Part shallhave fifteen (15) days from receipt of the notice to cure or correct the non-performance. If not corrected or cured withinthis fifteen (15) day period, the claiming party may issue a thirty (30) day written notice of termination and/or pursueother available remedies for default.

(c) Notwithstanding the above, COVERALL may, but shall not be obligated to, terminate this Contract immediately fornon-payment by CUSTOMER.

8 The Service Charge will remain in effect for one (1) year unless there are changes in the original specifications forthe premises. In the event of such changes, CUSTOMER will advise COVERALL accordingly, and an adjustment inthe service charge, as agreed to by the parties, will be made.

9. CUSTOMER agrees that it will not employ or contract with any COVERALL employee, franchisee, or any of thefranchisee's employees during the term of this contract or for one hundred and eighty (180) days after termination ofthis contract, without COVERALL's written consent.

10. COVERALL will bill CUSTOMER monthly, and CUSTOMER agrees to pay COVERALL the amount that is due andowing under the terms of this contract within 10 days of biling date. Late payments will incur service and financecharges at the rate of 1.5% per month. In the event of default on payment, CUSTOMER agrees to pay COVERALL'sattorney's fees and costs for collection.

11. Services shall be performed as scheduled with the exception of the following six (6) legal holidays: New Years Day,Memorial Day, Independence Day, Labor Day, Thanksgiving Day and Christmas Day. However, service can beprovided on these holidays at an additional cost if required. Services shall be scheduled during the hours approvedor directed by manager/owner.

OMonday OTuesday DWednesday OThursday OFriday OSaturday OSunday(Days of the week on which service is to be provided)

12. If there is an "Additional Special Services" Addendum attached to this Contract, and if CUSTOMER cancels anyperiodic Special Services described therein for which a prorated monthly charge is included in CUSTOMER's totalmonthly service charge, any amount owing by CUSTOMER for Special Services performed prior to the cancellationshall be payable in full no later than five (5) days after the cancellation.

13. The undersigned warrant and represent that they have full authority to enter into this Contract, and that it wil bebinding upon the parties and their respective successors and assigns.

14. This Contract and attached exhibits constitute the complete agreement of the parties concerning the provision ofcleaning services to the CUSTOMER, and supersedes all other prior or contemporaneous agreements between theparties, whether written or oral, on the same subject. No waiver or modification of this Contract shall be valid unlessin writing and executed by COVERALL and CUSTOMER. Additionally, in no event shall the terms and conditions ofany purchase order or other form subsequently submitted by CUSTOMER to COVERALL becomes a part of thisContract, and COVERALL shall not be bound by any such terms and conditions.

15, This Contract does not become binding upon COVERALL unless and until COVERALL obtains a satisfactory creditreport on the CUSTOMER and COVERALL, in its sole discretion, approves the CUSTOMER_ The followinginformation is required:

Customer Headquarters:Type of Entity:Federal Tax ID No.:State of Incorporation:Date Incorporated:Contact Name:Contact Telephone Number:

(Company Name/Address)OCorporation OPartnership OSole Proprietorship OLLC

December 2006

2006tO Coverall North America, Inc.

Page 2 of3 Premium Account Contract

Page 111: Espada Reply to Subpoena

16. If the CUSTOMER is either a sole proprietorship or partnership, CUSTOMER upon executing this Contract herebyconsents to a credit review by COVERALL.

CUSTOMER

Authorized Signature-

Print Name and Title - N. NY;i3:;¡

Date.c:c:Customer:;:; -

Service Start Date -E-mail Address.

Please fax signed contract to 201-438-1905

Date -

December 20062006iD Coverall North America, lnc,

Page 3 of3 Premium Account Contract

Page 112: Espada Reply to Subpoena

EXHIBIT 6

Page 113: Espada Reply to Subpoena

.':'e'c .iu U"l "u:::'uup .

CAREER Q'liEST Top TEl\,fPOLA-RlES INC -1£1 \/Vest 34ih Street, Suite 828 New York, New York 10001

Phone 212.695.2429 e-mail cattiIDaoLcom :=3:: 212.695,2684

FACSIMILE TRANSMITTAL SHEET

JD~Vì ~o.ie i L', \ i Ci ~J;Sj)SCOMPANY:

FROM:

OAT:::'w r eJ mOJ

PHONE NUM'E~F) \u~_~ .

.RE:

-TOT AL NO. OF PArES INCLUDING COVER:

v;SENDER'S REFER NeE NUM8ER: =

YOUR REFERENCE NUM8ER:

o URGENT 0 FOR REVIEVV 0 PLE.ASE COMMEt-T 0 PLEASE REPLY 0 PLEASE RECYCLE

NOTE.S/COMMENTS: -- -=

-------- ~--~--

-: _; :-:: l-': t.":: ~.. ~ -; =. r_ !: ...:.:,.~. ~

Page 114: Espada Reply to Subpoena

.c ef:.....,lUm\;-".. .u."" ".",,,.1,

We are proud and delighted to submit this added value bid, to Sound ViewHealth Center. Top Talent Maitenance Inc. Mission is to provide you, with the lughestquality Facilties Management Services. Though: Energy, Excellence, and Executioii.We want you to consider Top Talent Maintenance as an extension of your business.

As we understand it a key objective of Sound View is to, achiev~ the mostprofessional Facilities Management Services,

. In the least amount of time

. Most effective manner

. Combining highest quality for lowest cost. Resulting in best value,

. Making life easier for you and your company

Let's take a look at some of these services. Over 18 years of results oriented Facility Management experience. In depth expertise in Health Care Provider Facilities Management

. Manpower Management Effcient disbursement of professional FacilitiesManagement teams to all sites

" History of 100% retention, zero turover, Benefiting dept!1dability of

quality of service -. Weekly survey and evaluations. Increasing productivity above industry

standards. White glove surprise inspection of sitr.~s by Senior Supervisor. Ensuring

continuity of highest standards of services.. Customized Human Resources selection oftop talent including. Prescreening. Assessment of required skiJs, aptitudes, abilities and work ethic. Complete background check. Possession of New York State Drivers License. Expediting dispatch of

teams. Evaluation. Job preparation

. Training custOTIl.ed to on site requirements

. Bilingual skil sets. Benefiting customer service relations

. Professional and Personal Motivation "ala" Dale Carngie. Increasing

productivity outcomes

The added value benefits package includes:. Performance of all codes

. Overall cleanliness

. Timely removal of garbage

. Floors: buffng, waxing, stripping, and mopping

. Caret cleaning (as necessa)

. Clean bathroom, and scent frendly

. Removal of medical excess and waste

. Maintenance of outside grounds

Page 115: Espada Reply to Subpoena

.'. .__ .....-.. ,-"..... ,._.._.....- -'f" I - -

Supervsor - salar

8

6

48

hours per daydays weeklyhour per week --

$22.50 per hour$1,080 per week52 weeks per year

56,160 Anual salary --421,200

56,160477,360

Facilities management tëamSupervisory Salar --

--Cost of Disability Insurance

Fidelity InsuranceBonding (of individual workers)Worker camp --

Allocations of total cost:

$620,000

Which includes all of the above added values and benefits,

Page 116: Espada Reply to Subpoena

~~.~6....,i-u. W~, -.~d ~..~dr.... I - .

Shifts

Main shift 6:00-AM to 2:00-PM

l. p 11' shift 5:00-AM to 9:00-AM

4:00-PM to 9:00-PM

Page 117: Espada Reply to Subpoena

.c, 2C',,1-'U 1:.,.. 'l:H;)':--U.::p-I. --

· Winter snow removal

· Autumn raing +' removal of foliage· Properly uniformed maintenance team

· Expertise in Microsoft management of systems. Executing highest level

of performance· Administrative functions. Timely and accurate execution of payroll· Coordination of W.O. T C benefit to Soundview (If applicable)· Community and business integration programs, fostering mutual

involvement and growth

Annual cost allocation - Itemization

5 Sites

8 hours per day6 days a weekly

48 hours per we~k

$J 1.25 per hour

$540 per week52 week per year

$28,080 - per individuaJ worker's annual salar

X 15 workers

$421,200 anual salary ofFacility Management Team

Page 118: Espada Reply to Subpoena

.:~ . ",. UO:-:L.'UP

:ciial cost allocation may vary based on the assignment ownership responsibility: !;iarding the following:

Materials + suppliesPaper goods + chemicals

Equipment including but not limited toSnow removal machinesPig vacuumsWet vacuums

Computer - micro soft system

: hank you for your consideration. We look forwards to taking the nest step in the"; ::;ourcing process,

"k:a~e feel free to call me with any questions you may have. I welcome all feelings on. . ~ :"

Sincerely,

"ïF~ Cì;~\r~/)

ti~

Page 119: Espada Reply to Subpoena

EXHIBIT 7

Page 120: Espada Reply to Subpoena

D.D.s. Contractor LLC43 Marino Avenue

Port Washington, NY 11050Phone: (516) 784-1767

Weeldy General CleaningFive Times Per Week

Bid to: Attention: Pedro EspadaSoundview Health Center731 Wlte Plains RoadBronx, NY 10473

Job Location:821 E. 233 RoadBronx, N ew York

EstimatedGross Sq. Ft.: 12,000

Frequency: Five Times Per Week

Bid by: BBS Contractor LLC

Date: September 14th, 2007

Service Hour per day Hour per month Rate Per Total Labors Total labor costs

hour per monthGeneral 2 labor with 16 346 hours $10 2 $3,460.00Maintenance/Clearung hours in total (16 x 5 x 52) / 12

Total Labor expense: $3,460.00

Payroll Cost:

(social Security, worker compensation,disabilty and liability insurace)Supplies & Chemicals:

$ 622.80

$ 100.00

Equipment:Total expense

$ 50.00

$4,232.80

Service Fee $ 300.00

Total General Maintenance Price per month: $4,532.80

MontWy Pnce $4,532.80 Includes:. 2 Person! Custodian workig - 7am - 3pm with one person (Mon - Fn)

- 3pm-ll pm with one person (Mon- Fri). Cleag equipments (Vacuum, Mop, Buckets and Squee-gee, etc...

. Green Cleag products (Cleag chemica by Johnon Green Cleang Products - Whch

environmentaly safe, pleasant and certified by Unite Staes Green Council). Free service (Cart & window Cleaig with no exta charge) (One time per year)

Page 121: Espada Reply to Subpoena

B.B.S. Contractor LLC43 Marino Avenue

Port Washington, NY 11050Phone: (516) 784-1767

Wceldy General CleaningFive Times Pee Week

Bid to: Attention: Pedro EspadaSoundview Health Center731 White Plais RoadBronx, NY 10473

Job Location:Buride Medical Center

165 East Buride AvenueBronx, New York 10453

EstimatedGross Sq. Ft.: 5,000

Frequency: Five Times Per Week

Bid by: BBS Contractor LLC

Date: September 14th, 2007

Service Hour per day Hour per month Rate Per Total Labors l'¡

hour i

General 3 labors with 520 hour $10 3r

Maintenance/Cleaning 24 hour in total (24x5x52)/12¡ii

. r

~ ' -)sts

! ',: .~

Total Labor expense: $5,200.00

Payroll Cost:

(social Security, worker compensation,disailty and liability insurce)Supplies & Chemicals:

$ 936.00

$ 100.00

Equipment:Tota expense

$ 50.00

$6,286.00

Service Fee $ 300.00

Total General Maintenance Price per month: $6,586.00

Monthy Price $6,586.00 Includes:. 3 PersonnelJ Cusodian workig - 7am - 3pm with one person (Mon - Fri)

- 3pm-llpm with two personnel (Mon - Fri). Cleang equipments (Vacuwn, Mop, Buckets and Squee-gee, etc...

. Green Cleag products (Cleag chemical by Johnn Green Clean Products - Whict

envionmentaly safe, pleast and certfied by Unite States Green Council)

. Free service (Cart & window Clea1ng with no extr charge) (One time per year)

Page 122: Espada Reply to Subpoena

B.B.S. Contractor LLC43 Marino Avenue

Port Washington, NY 11050Phone: (516) 784-1767

Weekly General CleaningSix Times Per H7eek

Bid to: Attention: Pedro EspadaSoundview Health Center73 i Whte Plains RoadBronx, NY 10473

Job Location:Sound view Health Center731 Whte Plain Road

Bronx, NY 10473

EstimatedGross Sq. Ft.: 30,000

Frequency: Six Times Per Week

Bid by: BBS Contractor LLC

tIDate: September 14 ,2007

Total Labors ¡O'

Service Hour per day Hour per month Rate Perhour

General 5 labors with 962 hours $10 5

IMaintenance/Cleaning 37 hour in total (37x6x52)/l2i

-t"i

-

-1 ",)1'tsl

" ;)

Total Labor expense: $ 9,620.00

$ 1,731.60Payroll Cost:

(social Security, worker compensation,disaility and liability insurce)Supplies & Chemicals: $ 300.00

Equipment:Total expense

$ 100.00

$11,751.60

Service Fee $ 800.00

Total General Maintenance Price per month: $12,551.60

Monthy Pnce $12,551.60 Includes:. 5 PersonnelJ Custodian workig - 8am - 3pm with thee personnel (Mon - Sat)

- 3pm-l lpm with two personnel (Mon-Sat). Cleang equipments (Vacuwn, Mop, Buckets and Squee-gee, etc...

. Green Cleang products (CLea chemica by Johnn Green Clea Products - Whíc"

environmentaly safe, pleat and certified by Unite States Green Council)

. Free service (Cart & window Cleang with no extr charge) (One time per year)

Page 123: Espada Reply to Subpoena

B.B.S. Contractor LLC43 Marino Avenue

Port Washington, NY 11050Phone: (516) 784-1767

Weekly Gener2lir-\.,.,~

Five Times PJ;"";'" J

Bid to: Attention: Pedro EspadaSowidview Health Center731 Whte Plais Road

Bronx, NY 10473

Job Locations:Jessica Guzan Medical Center616 Castle Hil A venue

Bronx, New York 10473

EstimatedGross Sq. Ft.: 6,000

Frequency: Five Times Per Week

Bid by: BBS Contrctor LLC

Date: September 14th, 2007

Service Hour per day Hour per month Rate Per Total Labors Ihour I

General 1 labor with 8 173 hours $10 1

\

Maintenance/Cleaning hours in total (8 x 5 x 52) / 12 ;

.'I

ts

Total Labor expense: $1,730.00

Payroll Cost:

(social Security, worker compensation,disailty and liability insurace)

Supplies & Chemicas:

$ 311.40

$ 100.00

Equipment:Total expense

$ 50.00

$2,191.40

Service Fee $ 300.00

Total General Maintenance Price per month: $2,491.40

Montly Pnce $2,491.40 Includes:. 1 Person! Custoan workig - 7am - 3pm with one person (Mon - Fn)

. Cleanng equipments (Vacuum, Mop, Buckets and Squee-gee, etc...

. £"~een Clear. g products (Cleani'ng chemi"c",i h" T"ho,,"" r.r...." ('i..'n;"H Dr,,,:..,'¡'" - Ui;.,; .Vi' .. ..J ",_",~"'LJ'lL" ~.....--.... ._....~.:..I...b.. ...-'~.~~._...:. ~.. ..;.....environmentaly safe, pleast and certified by United States Green Council

0; Free service (Carpet & window Cleaning with no extra charge) (One time per year)

Page 124: Espada Reply to Subpoena

B.B.S. Contractor LLC43 Marino A venue

Port Washington, NY 11050Phone: (516) 784-1767

Weekly General CleaningFive Time Per Week

Bid to: Attention: Pedro EspadaSoundview Health Center731 Whte Plais Road

Bronx, NY 10473

Job Locations:Diallo Medical Center1760 Westchester AvenueBronx, New York 10472

EstimatedGross Sq. Ft.: 10,000

Frequency: Five Times Per Week

Bid by: BBS Contractor LLC

Date: September 14th, 2007

Service Hour per day Hour per month Rate Per Total Labors Total labor costs

hour pel' month

General 2 labor with 16 346 hours $10 2 $3,460.00

Maintenance/Cleaning hours in total (16 x 5 x 52) /12

-

Tota Labor expense: $3,460.00

Payroll Cost:

(social Security, worker çornpensation,disaility and liability insurce)Supplies & Chemicas:

$ 622.80

$ 100.00

Equipment:Tota expense

$ 50.00

$4,232.80

Servce Fee $ 300.00

Total General Maintenance Price per month: $4,532.80

Monthy Pnce $4,532.80 Includes:. 2 Person! Cusodian workig - 7am - 3pm with one persn (Mon - Fn)

- 3pm- i 1 pm with one person (Mon- Fn)

. Cleanng equipments (Vacuwn, Mop, Buckets and Squee-gee, etc...

. Green Cleang products (Cleag chellcal by Johnson Green Cleaning Products - \\Thich

environmentaly safe, pleast and certified by United States Green Council)

. Free service (Caret & window CleaIng with no extra charge) (One time per year)

Page 125: Espada Reply to Subpoena

D.D.s. Contractor LLC43 Marino Avenue

Port Washington, NY 11050Phone: (516) 784-1767

Weekly Gene~~ij tU"i"."",injFive Times P;, ,:"

Bid to: Attention: Pedro EspadaSoundview Health Center731 Whte Plais Road

Bronx, NY 10473

Job Location:

Delany Sisters Health Center2727-33 Whte Plains RoadBronx, New York 10467

EstimatedGross Sq. Ft.: 7,000

Frequency: Five Times Per Week

Bid by: BBS Contractor LLC

Date: September 14th, 2007

Total Labors !u.

Service Hour per day Hour per month Rate Perhour ;

- ..

General 2 labors with 347 hours $10 2

Maintenance/Cleaning 16 hour in total (16 x 5 x 52) /12, --

- .

.,ts

Total Labor expense: $3,470.00

Payroll Cost:

(social Security, worker compensation,disailty and liability insurce)Supplies & Cheiicals:

$ 624.60

$ 100.00

Equipment:Tota expense

$ 50.00

$4,244.60

Service Fee $ 300.00

Total General Maintenance Price per month: $4,544.60

Monthy Prce $4,544.60 Includes:. 2 Personnel/ Cusodian workig - 7am - 3pm with one person (Mon - Fn)

- 3pm-11 pm with one person (Mon - Sat). Cleaning equipments (Vacuwn, Mop, Buckets and Squee-gee, etc...

. Green Cleang products (Cleang cheiical by Johnn Green Cleang Products - Wbi,);,environmentaly safe, pleast and certfied by Unite Stas Green Council)

. Free service (Cart & window Cleanng with no extr charge) (One time per year)

Page 126: Espada Reply to Subpoena

ì h. "'--v\ X 2-Ç- Y. s

3JvJjo4t ?;L~'-r). ..

db '7 ~ h()~-;:J .-- a

g-:. L. .

3- \ \

o

I~

'l'--

JJ-

/t1G"A~i1'

f'A",J ,

Page 127: Espada Reply to Subpoena

-

EXHIBIT 8

Page 128: Espada Reply to Subpoena

SUBPOENA DUCES TECUMTHE PEOPLE OF THE STATE OF NEW YORK

TO: Comprehensive Community Development Corp. ("CCDC")

(li/ka Soundview Health Center)731 White Plains RoadBronx, NY 10473

WE HEREBY COMMAD YOU, pursuant to the laws of the State of NewYork, including Not-for-Profit Corporation Law § 1 12(b)(6), Executive Law § 63(12)and Estates, Powers and Trusts Law § 8- 1 .4(i), that, all business and excuses being laidaside, You deliver and tu over to the Attorney General of the State of New York, or adesignated Deputy or an Assistant Attorney General, on the 15th day of May, 2009, at10:00 a.m. or at any agreed upon adjourned date or time, at 120 Broadway, yd Floor,New York, New York 10271, all Documents requested in the attached Schedule inaccordance with the instructions and definitions contained therein.

PLEASE TAKE NOTICE that the Attorney General deems the Documents requestedby this Subpoena to be relevant and material to an investigation and inquiry undertaken inthe public interest.

PLEASE TAKE FURTHER NOnCE that your disobedience of this Subpoena byfailing to deliver the Documents and information requested in the attached Schedule onthe date, time and place stated above or on any agreed upon adjoured date or time, maysubject you to prosecution under CPLR Aricle 23, and/or other statutes.

WITNESS, The Honorable Andrew M. Cuomo, Attorney General of the State ofNew Yom, this Ii" day of May, 2009, By: QÁ

7as.i:en- -;/ ~hief, Charities Bureau120 Broadway, 3rd Floor

New York, New York 10271(212) 416-8490

Page 129: Espada Reply to Subpoena

SeHEDULE

A. Documents to be Produced.

The following Documents are to be produced for the period January 1,2005 through the present except as otherwise designated.

I. A list of all directors, offcers, employees, consultants and independentcontractors of eeDe and its Affliates, their titles and the place of theiremployment.

2. F or each person identified in response to Request i above, provide Documents(including correspondence) sufficient to identify:

(A) All compensation or other payments that eeDe or an Affliate ofeeDe has paid to such person or a Related Party of such person,including the purpose of such payments.

(B) Whether any such person, or a Related Party of such person, works orhas worked (whether in a volunteer or paid capacity) directly orindirectly in political campaign activities for or on behalf of PedroEspada, Jr.

(e) Whether such person is related by blood or marriage to Pedro Espada,Jr.

(D) Whether such person is related by blood or marriage to any otherdirector, offcer, employee, consultant or independent contractor ofeeDe or any Affliate.

3. All contracts, agreements, correspondence and other Documents concerningarrangements and transactions involving eeDe or any Affiliate of eeDe inwhich Pedro Espada, Jr. or a Related Part of Pedro Espada, Jr has a direct orindirect financial or other interest.

4. To the extent not identified in Your response to Request 3, all contracts,agreements, correspondence and other Documents concerning arrangements andtransactions involving eeDe or any Affliate of eeDe in which a director,offcer, employee, consultant or independent contractor of eeDe or anyAffliate of eeDe, or any Related Party of such person, has a direct or indirectfinancial or other interest.

5. Documents suffcient to identify all grants, "member items" or other fundingthat eeDe or any Affliate of eeDe has received or expects to receive from

any local, state or federal governmental entity. With respect to each item offuding, provide:

Page 130: Espada Reply to Subpoena

(A) The amount and purpose of the funding;(B) The name of the elected offcial(s), if any, who sponsored the funding;(C) Copy of the application for funding;(D) Copy of any agreement entered into or to be entered into with respect

to such funding;

(E) All correspondence concerning the funding; and

(F) Documents showing all amounts paid in connection with the funding.

6. With respect to each grant, "member item" or other funding identified inresponse to Request 6, Documents detailing all expenditures made or areexpected to be made in connection with such funding, specifying the purposesfor which the expenditure was or is expected be made.

7. A list oflocations at which CCDC has offces or from which CCDC operatesprograms, including Documents describing each program operated at eachlocation.

8. The following financial Documents ofCCDC and its Affliates:

(A) All journals, ledgers or other records, showing the date, amount, payorand/or source of each receipt, credit or other transfer into an accountbelonging to CCDC (excluding Documents pertaining to payment formedical services in the ordinary course of business);

(B) All journals, ledgers or other records, including check registers,showing the date, amount, payor or other recipient of each cashdisbursement, debt or transfer out of an account belonging to CCDC(excluding Documents pertaining to payment for medical services inthe ordinary course of business);

(C) All bank statements for accounts belonging to CCDC and allreconciliations of each such account to the general ledger;

(D) The general ledger;(E) All financial statements ofCCDC and its Affliates, including any

related audits, reviews or compilations by independent auditors, aswell as all correspondence with the auditors, accountant work papers,management letters or other statements by the auditors;

(F) All Documents concerning petty cash accounts, including without

limitation, Documents showing withdrawals and replenishments of theaccount, and the recipient of any such funds;

(G) All Documents used to calculate the fund balances at the beginningand at the end of the year as reported on lines 19 and 2 i of CeDe'sForm 990 for the years 2003 through 2007, including all changes innet assets or fund balances as reported on line 20 thereof.

(H) All Forms 990 not previously fied with the Attorney General's Offce;

and(0 All correspondence with the Internal Revenue Service.

Page 131: Espada Reply to Subpoena

9. Copies of all certificates of incorporation of CCDC and its Affliates and allamendments thereto and all by-laws of the Board of Directors in effect fromJanuary 1,2005 to the present.

10. Documents concernng meetings of CCDC' s board of directors or anycommittee of the board, including, without-limitation:

(A) Minutes;(B) Resolutions;

(C) Contracts considered and/or approved by the board:

(D) Reports, memorandum and/or presentations of any kind; and(E) Ariy o.ther documents discussed by, shown to or distributed to board

members.

1 I. Organizational charts of CCDC and its Affiiates identifying the managementand corporate structure of each entity.

12. All documents concerning the payment and repayment of legal fees advancedto, or on behalf of, Sandra Love, Maria Cruz, Esther Hill, Norma Ortiz, JoyceOates, Leonard Frazier and/or Dora Garcia in connection with any legalproceeding, whether before or after January 1,2005.

B. Definitions and Instructions

The Attorney General deems all documents requested herein to be relevant andmaterial to his inquiries.

This subpoena applies to all documents in effect, created, recorded, compiled,transmitted or received during the period January 1,2005 through the present except asotherwise designated.

"CCDC" means Comprehensive Community Development Corp. (ala

Soundview Health Center), a New York not-for-profit corporation having an offce at 73\White Plains Road, Bronx, NY 10473, and all divisions or operating units thereof.

"Affiiate" means, as to CCDC, (i) any entity which, directly or indirectly, is incontrol of, is controlled by, or is under common control with, CCDC, (ii) any entity ofwhich CCDC is a member, or (iii) any entity which is a member ofCCDC. An entityshall be deemed to control another entity if the controlling entity possesses, directly orindirectly, the power to direct or cause the direction of the management and policies ofthe other entity, whether through membership, the ownership of voting securities, bycontract, or otherwise.

"Communication" as used herein shall include all means of conveyinginfonnation, written, oral, or otherwise.

Page 132: Espada Reply to Subpoena

"Documents" is used herein in the broadest sense of the term and shall mean allrecords and other tangible media of expression of whatever natue including, withoutlimitation, originals, drafts or finished versions, or annotated or nonconforming or othercopies however created, produced or stored (manually, mechanically, electronically orotherwise), including electronic mail ("e-mail"), instant messages, Blackberr or otherwireless device messages, voicemail, books, papers, fies, notes, confirmations, accountsstatements, correspondence, memoranda, reports, records, jourals, registers, analyses,plans, manuals, policies, telegrams, faxes, wires, telephone logs, telephone messages,message slips, minutes, notes or records or transcriptions of conversations orcommunications or meetings, tape recordings, videotapes, disks, and other electronicmedia, microfilm, microfiche, storage devices, press releases, contracts, agreements,calendars, date books, appointment books, diaries, notices and summaries. A draft ornon-identical copy is a separate document within the meaning of this term. Under thisdefinition, Documents existing in electronic form shall include all items that may havebeen removed from the e-mail accounts or the directories in which they are ordinarilystored to any other server, folder, fie, archive, or backup device, whether or not deleted.

"Pedro Espada, Jr." means Pedro Espada, Jr., a New York State Senator having adistrict offce at 400 East Fordham Road, Bronx, NY 10458.

"Related Part" or "Related Parties" means (i) any firm, corporation, partnership,association, political organization,'campaign committee or other entity in which anyemployee, offcer, director, consultant or contractor of CCDC is or was affiiated, or is orwas an offcer, director, general partner or principal or in a similar position or in whichsuch person, together with all other Related Parties, have in the aggregate a 10% orgreater beneficial ownership interest; or (ii) any person who is related by blood ormarrage to any person who is or was a director, offcer, employee, consultant orcontractor of CCDC or of any Affiiate of CCDe. For purposes herein, CommunityExpansion Development Corp. is a Related Part.

"You" or "Your" means the addressee of this subpoena and any present or formerAffliates and their respective offcers, directors, employees, trustees, agents, contractors,representatives, attorneys or other persons associated with or acting on behalf of You.

The terms "concerng" 'or "relating to" as used herein shall mean, directly orindirectly, in whole or in part, relating to, referrng to, describing, evidencing orconstituting.

The terms "sent" or "received" as used herein shall mean, in addition to theirusual meanings, the transmittal or reception of a Document by mail, hand, emaii or otherelectronic delivery, and facsimile transmission or reception, whether by direct or indirectmeans.

The connectives "and" and "or" shall be construed either disjunctively orconjunctively as necessary to bring within the scope of the information request or

Page 133: Espada Reply to Subpoena

demand for production all responses or production of Documents that might otherwise beconstred to be outside of its scope.

"All" shall be construed as each and every.

"Any" shall be construed as "any and alL"

The use of the singular form of any word used herein shall include the plural andvice versa.

"Person" shall mean any natural person or entity including without limitation anycorporation, company, limited liability company or corporation, partnership, limitedpartnership, association, or firm.

"IdentifY" or "Identity," as applied to any natural person, shall mean to providetheir name, title(s), aliases, screen names, and Contact Information, and with respect toany entity, shall mean to provide the name, d//a names, if any, and the entity's ContactInformation.

You shall identify the number of the request to which the Documents purport tobe responsive, If there are no Documents responsive to any particular request, You shallso state in writing.

If any Document requested herein was formerly in Your possession, custody orcontrol but is no longer available, or no longer exists, You shall submit a statement inwriting under oath that: (a) describes in detail the nature of the Document and itscontents; (b) Identifies the person who prepared the Document and its contents; (c)Identifies all persons who have seen or had possession ofthe document; (d) specifies thedates on which the Document was prepared, transmitted or received; (e) specifies the dateon which the Document became unavailable; ff) specifies the reason why the Documentis unavailable, including without limitation whether it has been misplaced, lost, destroyedor transferred, and if the Document has been destroyed or transferred, the conditions ofand reasons for such destruction or transfer and the Identity of the persons requesting andperforming the destruction or transfer; and (g) Identifies all persons with knowledge ofany portion of the contents of the Document.

If any Document requested is withheld on ground of privilege or other legal

doctrine, submit with the Documents produced a statement in writing under oath, stating:(a) the document control number range of the Document withheld; (b) the type of thedocument; (c) the date of the Document; (d) the author and recipient of the Document; (e)the general subject matter of the Document; and (f) the legal ground for withholding theDocument. If the legal ground for withholding is attorney-client privilege, also indicatethe name of the attorney involved on the document. Such statement or privilege log shallaccompany each production.

Page 134: Espada Reply to Subpoena

Placeholder pages equivalent in number to the page-length ofa withheldDocument shall be substituted in the production in place of any document withheldpursuant to the preceding paragraph, with each such placeholder page assigned the samesequential document control number as it would have borne had the document beenproduced.

You shall Identify the person(s) who personally supervised the preparation andassembly of responses to this Subpoena, who could testify that the responses arecomplete and correct to the best of his or her knowledge and belief, and that anyDocuments produced are authentic, genuine and what they purport to be. You shall alsoIdentify the custodian(s) of records for the Documents produced pursuant hereto, andsubmit a copy of all instructions prepared by You relating to the steps taken to respond tothis Subpoena. Where the instructions given were oral, You shall provide a writtenstatement under oath from the person who gave such instructions, detailing the content ofthe instructions and the person(s) to whom the instructions were given. In order for Yourresponse to this Subpoena to be complete, the attached Verification must be completedand executed on Your behalf by the person supervising compliance with the Subpoenaand submitted with the responsive Documents.

The obligation to produce pursuant to this Subpoena is a continuing one.Documents located at any time after a response is due shall be promptly produced at theplace specified in the Subpoena.

Page 135: Espada Reply to Subpoena

.,

Verification

This response to the Subpoena of the Attorney General of the State of New Yorkdated, May _,2009, including without limitation production of the requestedDocuments, was prepared and assembled under my personal supervision from the recordsof in accordance with the instrctions and definitions set forth in such

Subpoena and is complete and correct to the best of my knowledge and belief. TheDocuments produced in response to this Subpoena are authentic, genuine and what theypurport to be.

(Signature of Offcial) (Title)

(Type or Print Name of Above Offcial)

.....

Subscribed and sworn to before me this day of 2009.

Notary Public

My commission expires:

Page 136: Espada Reply to Subpoena

-

EXHIBIT 9

Page 137: Espada Reply to Subpoena

08/13/2009 22: 16 FAX 301 443 1989,11E.-.i1-21 1?::W NYS t:TTRI ~ 212 416 8264 Ia004P.Ø2"--"' L .," ~

r :;~1 ~i.('!"..".... o:."!,, ti~:.,

ir~. :é~: "(''~1 '..iU ,..,',~.~/;"

,-i.:~r~""'_.. .:".

STATE OF NE yoRKOFF OF TH ATIRNY GEN

PNt M. QoAnA;nllJJ ld. CUMOATT~iiY O~

July 21, 2009

ll F~1MLE (301.46686)Alex Hurungc, Executve Sec8Ido Rebeoca Spitz¡o

Hallh Resource and Servçe A.nistraton

United State Depart ofHoJ1th &. Hul' SeMoM

Re: Infrmtion reú. compebeve CommunLty Develnimt Corp.

Dea Ma. Huttlnge

We wrte to reuest copies of all grt aplicauon packages an reate (lwnentsinaluding but not li1lte to foral or infoml applicatons and inqubcsl applicatlonii fot

iovcmment 8!llata~1 im ~hecklst fon, corrpodece. budget pr¡als, vtndorresponsibilty q,uetion~uilr or certficatin., and final deci&ioIlS whether to grt or dèny eacIiuch appljcatiQß-8Ubmï to the Heø1th Rc'W~fi an SeIce Admnistron ('liSA") bycompr~riiV8 Community Dcvclo.mt Corporation ("CCO) or its afat CommulllyEx-p1Uon DCVciop~~ Cotation ("CEe") di the peod Jul)' i! 203 l to tho pren.

Tg 88list yo" in aBÀ!15 searh for relevant doent. Wo ar ii oi at least the

followinii ørt applicaton packa Ilulmtt to HØA by cee (B: 13296087) Qutbg therefcrc:ed time period: '

i. Ora Heth Expasion Grt (slibIJtt Mah 2(5)iL School Bued Heath Clinic Grant C$ubitt Apr20S)Hi. B~pLUde Me4ica1 Capa.ii:y OJt (submitte Decoi 205)tv. Detal ~pansiQ1 Gtt (lubøittd Jønua 206)v. New Aeas Point Grt (iubmltt Novembe 2006)'I. Oral Health Soico Capaty Grt (submitt Pcbi 2(8)vii. Mctoit lDgh Jiact H8 Imler.taton Grt (submtte July 2007)vil. Section 3'30 Comunr.y Based Health Cente Grt (submtted Febnlllry 208)

,rotlfGaGll. NeI'tonl NewYor'027 . TølIJDnl: i'~A10.1 · F-~ 212.11.a. WM.OIlQA_.nV.Ili.. .._ iiii "" i .

IU_ ..__.-.._.~...~ i~l-:.l;.

600~ XVd SO: CL 6006/~l/80

Page 138: Espada Reply to Subpoena

08/13/2Ò09 22 '18 FAX,rul:-21-2Ø' 1'71~ 391 443 1989 O_C. _'_ NY A~ GE~ o¿io¿ 41b i.~I;.: 1l~?L,.1" ,I

Thenk you in advance for your 8i1taO with th matt. If you have any quetions, or ifyo wold ¡i iht .. rOt tb¡ iii by invOltilat S1ò¡oea. 91- do no Iitacto oontact me at 212.416.6091.

Ve' tny yout,rJ~~~y!\. GoAsslstit AttY Qeer

. .

. ,,

. .

'.

1 'ClIl!acav . NaW Yg~. Niw 'YOl 10m II TekiplDlD; 21111e.eo · ~ i12.1 fl.!K& · WW.t$I.aUlisy.

if". I . .. '.' ,TO1.l'U'"""I""1 iP.IeJ _.

COO~ XVd SO: C1 6006/~1/g0

Page 139: Espada Reply to Subpoena

EXHIBIT 10

Page 140: Espada Reply to Subpoena

08/28/2009 15: 4 7 FAX~ 002/017--,.--- --- -

OFfiCE OF TH ATTORNY GENERALOF TH ST ATE OF NEW YORK._----......------..------------_.._-----......--------_...._---....-----------

In the Matter of the

Investigation by ANDREW M, CUOMO. Attorney Generalof the State of New York, re,lating to

: SUBPOENA DUCES: TECUM

Comprehensive Community Development Corporation, et aL.

-- ----------_..---_..- -_..__......-------_......-----_....-_.._---.._..._-----_...._._-------- --..

THE PEOPLE OF THE STATE OF NEW YORK

To: Soundview Management Enterprises LLC325 E. 201st StreetNo.4BBronx, NY 10458

WE COMMAND that on Or before the 3rd day of September, 2009 at 2:00 p.m. you

produce any and all documents listed below that are in your possession. custody. or control to

Attorney General Andrew M. Cuomo, Attention Darcy M. Goddard, 120 Broadway, 25th Floor,

New York, New York 10271, pursuant to the Jaws of the State of New York including New York

Not-For-Profit Corprarion Law section 112(b). New York Estates, Powers and Tnists Law

section 8~1.4(i)1 and New YOl"k Executive Law section 63(12).

PLEASE TAKE NOTICE that the Attorney General deems the documents requested by

this subpoena to be relevant and material to an investigation and inquiry undertaken in the public

interet.

Page 141: Espada Reply to Subpoena

08/28/200915:47 FAX I4 003/017_.-_._" ----

INSTRUCTIONS AN DEFINITIONS.

1. "Espada Campaign Entity" refers to any individua or entity workng o_n behalf of,

or for or in connection with the election or re-election of, Pedo G, Espada. Jr. ("Mr. Espada"), a

Senator of the State of New york, including but not limited to Mr. Espada, Committee to Reelect

Senator Pedro Espada, Jr., Espada 2000, Espada 2004, Espada For The People, New Yorkers

For Espada, and any of their directors, officer, agents, employees, representatives, affiliates, Or

any other person acting on their behalf.

2. "Sound view Management" refers to Soundview Management Enterprises LLC

and any of its directors, officers, agents, employees, representatives, attorneys, predecessonl,

successors. parnt corporations, subsidiares, divisions, assigns. "d//a" names. affiliates, or any

other person acting on its behalf.

3. "Other Soundview Entity" refers to Comprehensive Community Development

Corporation, Community Expansion Development Corporation (ffkla 731 White Plains Road

Realty Corp,), Soundview HeaIthcare, Soundview Healthcar Network. Burside Medical

Center, Castle Hill Medical Center, Delany Sisters Health Center, Diallo Medical Center, and

any of their diretors, officers, agents, employees, representatives. attorneys, predecessors,

successors, parent corporations, subsidiares, divisions, assigns, "d//a" names. affliates, or any

other person acting on their behalf.

4. "Regal Realty" refers to the company Regal Realty Services LLC located at 731

White Plains Road. Bronx, New York. 10473, and any of its directors, officers, agents,

..

employees, representatives, attorneys, predeessors, successors, parent corporations, subsidiares,

divisions, assigns, "d//a" names, affiliates, or any other person acting on its behalf.

2

Page 142: Espada Reply to Subpoena

08/28/200815:47 FAX 140041017------_.-_.

5. "Document" is used herein in the broadest sense of the term and means each and

every wnting,oi grphic matter of whatever nature, whether an original, a drat, or a copy,

including all non-identical copies, however produced Or reproduced, whether or not sent or

received. and each and every tangible thing frm which infonnation can be procesed or

transcribed such as tape or other electronic data communications. The term includes but is not

limited to letters, records, forms, books, invoices, e-mail messages. voicemail messages, checks.

bi1s, receipts, diares, calendars, logs, joumals, notebooks, plans, directives, instructions,

analyses, telegrams, studies, contracts, agrements, correspondence, communications, statistics,

memoranda, notes, minutes, opinions, reports, summaries, work-sheets, graphs, and chars and

any other means by which information is recorded 01" transmitted, including but not limited to

audio, visual, and digital recordings, photographs (positive prints and negatives), slides, films,

phonorecords, teletypes, telefax, facsimiles, therafax, microfim, punch cars, computer data,

printouts and data processing records, translated, if necessary, by the respondent thrugh

detection devices into reasonably usable foIm.

6. "Concernng" means refening to, related to, describing, reflecting, regarding,

evidencIng, recording, memoriali-zing, comprising, constituting, or supporting, directly or

indiretly.

7. The terms hand" and "or" should be construed conjunctively or disjunctively,

whichever makes the request more inclusive.

8. The terms "any" and "all" should be constred as "any and alL."

9. The use of the singular fonn of any word includes the plural and vice versa.

10. For purposes of this subpoena duces tecum, the time period applicable to the

following requests is AUgU8t 1,2003, to the present ("the applicable period") unless otherwise

3

Page 143: Espada Reply to Subpoena

08/28/200915:48 FAX ~005/0'7

noted. A request for a schedule, agreement, or other document for the applicable time period

encompaSses any schedule. agreement, or other document crated, 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.

11. Each document submitted in compliiince herewith should be numbere

consecutively on the face of the document and should clearly identify the pargraph of the

subpoena to which the document is responsive, unless original documenlJ are being produced for

inspection and copying. Copies of original documents should be legible in their entirety.

12. If any document the production of which is caned for by this subpoena duces

(ecum is withheld on the ground of purported privilege, for each such document please provide

the following infonnation in writing on the return date of this subpoena:

(i) the purported legal ground for withholding the document;

(ii) the type of document;

(iii) the general subject matter of the document;

(iv) the date of the document;

(v) the author of the document;

(vi) all recipients of the document; and

(vii) such other information as is suffcient to identify the document for a

motion to a court to compel its production.

13. If any of the documents called for in this subpoena have been produced to any

individual, organization, corporation, governmental agency, or any other entity, please provide

the Attorney General with a description of such documents and the individual(s) or entity(s) to

which such documents have been produced.

4

Page 144: Espada Reply to Subpoena

08/28/2009 15: 48 FAX ~006/017-~-_.- _.---_._-

--

14. If any of the documents called for in this subpoena have previously been

produced to the Attorney General, please identify by Bates number (i) each such document and

(ii) the subpoena call to which the document is responsive.

15. The response to this subpoena duces tecum shall be continuing in nature 80 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 reuest.

DOCUNTS TO BE PRODUCED

1. Documents sufficient to show all names, including but not limited to predecessor

companies, successor companies, affilates, and "d//a" names, under which Soundview

Management 'has conducted business at any time, or from time to time, during the applicable

period.

2. Documents sufficient to show the full legal names and current street addresses

and telephone numbers for all current owners, officers, directors, or prncipals of Soundview

Management.

3. Documents sufficient LO show the full legal names and last known street addrsses

and telephone numbers' for all former owners, officers, directors, or principals of Soundview

Management.

4. Documents sufficiont to show the full legal names and last known stret addresses

and telephone numbers for all current and former employees of Soundvìew Management.

5. Documents sufficient to show the management and corporate strcture of

Soundview Management.

6, All documents relating to any contracts, agrements. or trnsactions involving

Soundview Management and any Espada Campaign Entity.

5

Page 145: Espada Reply to Subpoena

08/28/200815:48 FAXI4 007/0 17

7. All documents relating to any contracts, agreements, or transactions involving

Soundview Management and any Other Soundview Entity.

8. All documents relating to any contracts, agrements, or transacions involving

Soundview ManageIlent and Regal Realty.

9. All dOCliments relating to any contracts, agrements, or transactions involving

Soundview Management and any or all of the following individuals: Sandr Love, Mara Cruz.

Esther Hil. No'rma Ortiz, Joyce Oates, Leonard Frazier, and Dor Garcia (or any of their

relatives).

10. All documents relating to any contracts, agrements, or transactions involving

Souridview Management and any business, corporatil?n, organization, or other entity in which

Pedr G. Espada, Jr. ("Mr. Espada"), a Senator in the State of New York, has u direct or indiret

financial or other interest.

11. All communications and correspondence sent to or fi-m Soundview Management,

on the one hand, and any Espada Campaign Entity, on the other hand.

12. All communications and correspondence sent to or from Soundview Management,

on the one hand. and any Other Soundvíew Entity, on the other hand,

13. All communications and corpondence sent to or from Soundview Management,

on the one hand, and Regal Realty, on the other hand.

14. All communications and correspondence sent to or from Soundview Management,

on the one hand. and any or all of the following individuals. on the other hand: Sandra Love,

Maria Cruz, Esther Hil, Norma Ortiz, Joyce Oates, Leonard Frazier, B'nd Dora Garcia (or any of

their relatives).

6

Page 146: Espada Reply to Subpoena

08/28/2009 15: 48 FAX I4 008/017--_..._-----_.- -

15, All communications and corresponden~e sent to or from Soundview Management,

on the one hand, and any business, corpration, organization, or other entity in which Mr. Espada

has a direct or indirect financial or other interest, on the other hand.

16, All documents relating to any Espada Campaign Entity.

17. All documents relating to any Other Soun'dview Entity.

18. All documents relating to Regal Realty.

19. All documents relating to any business, corporation, organization, or other entity

in which Mr. Espada has a direct or indírect financial or other interest.

20. Documents sufficient to show (i) all income received or eared by Soundview

Management during the applicable period,.(ii) the source of all such income, (iii) the date of

receipt of all such income, (iv) the payor of all such income, and (v) the services Of goods, if any,

provided by Soundview Management in connection with all such income.

21. Documents sufficient to show (i) all expenses incu1Ted or paid by Soundview

Management during the applicable period, (ii) the date on which each such expense was incured

or paid, (Hi) the recipient of all monies paid in connection with each such expense, and (iv) the

sen:ices or goods, if any, provided to Soundview Management in connection with each such

expense.

\ 22. Documents sufficient to show the fuH bank name, bank location, and account

number for each bank account (i) belonging to Soundview Management or (ii) to or frm which

Soundview Management has the abilty or authority to deposit or withdraw funds,

23, All bank statements for each and every account identified in connection with

subpoena call number 22 above.

7

Page 147: Espada Reply to Subpoena

08/28/2008 15: 48 FAX I4 008/017

24, All financial statements, audited or unauditèd, concerning Soundview

Management.

25. Documents suffcient to show Soundview Management's revenue and profits

(gross' and net) on a monthly basis for each and every month durng the applicable period.

Under the provisions of Article 23 of the CPLR, you ar bound by this subpoena to

produce the requested items. For a failure to attend on the date specified above, or any

adjourned date, and to produce the items specified, you may be liable, in addition ~o any other

lawful punishment, for the damage,s sustained by the State of New York, and for a penalty not to

exceed fifty dollars ($50.00).

WITss. Honorable ANDREW M. CUOMO, Attorney General of the State of New

York, the 25th day of August 2009,

ANDREW M. CUOMOAttorney General of theState of New York120 BroadwayNew York, New York 10271-0332

By: ~~tQå.."o- .-~""Darcy . Goddard ., Assistant Attorney General

Telephone: 212.416.6091

Facsimile: 212.416.8068

8

Page 148: Espada Reply to Subpoena

-

EXHIBIT 11

Page 149: Espada Reply to Subpoena

08/28/200915:48 FAX ~010/017

O~CE OF THE ATTORNEY GENERALOF THE STATE OF NEW YORK

In the Matter of the

Investigation by ANDREW M. CUOMO, Attorney Generalof the State of New York, relating to

SUBPOENA DUCESTECUM

Comprehensive Community Development COlllOration, et al.

Hil PEOPLE OF TIm STATE OF NEW YORK

To: Regal Realty Services, LLC

73 i White Plains Road,Bronx, New York 10473

WE COMMAND that on or before the 4th day of September, 2009 at 2:00 p.m. you

produce any and all documents listed below that are in your possession, custody, or control to

Attorney General Andrew M. Cuomo, Attention Darcy M. Goddard, 120 BTOadway, 25th Floor,

New York, New York 10271, pursuant to the laws of the State of New York including New York

Not-For-Profit Corporation Law section 112(b), New York Estates, Powers and Trusts Law

section 8-1.4(i), and New York Executive Law section 63(12).

PLEASE TAKE NOTICE that the Attorney General deems the documents requested by

this subpoena to be relevant and material to an investigation and inquiry undertaken in tbe public

interest.

Page 150: Espada Reply to Subpoena

08/28/2008 15:48 FAX 140111017

INSTRUCTIONS AND DEFINTIONS

1. .'Espada Campaign Entity" refers to any individual or entity working on behalf of,

or for or in connection with the election or re-election of, Pedro G. Espada, Jr. ("Mr. Espada"), a

Senator of the State of New York, including but not limilßd to Mr. Espada, Commttee to Reelect

Senator Pedro Espada, Jr, Espada 2000, Espada 2004, Espada For The People, New Yorkers

For Espada, and any of their directors, officers, agents, employees, representatives, affiliates, or

any other person acting on their behalf.

2. "Regal Realty" refers to the company Regal Realty Services LLC located at 731

White Plains Road, Bronx, New York 10473, and any of its directors, officers, agents,

employees, representatives, attorneys, predecessors, successors, parent corporations, subsidiares,

divisions, assigns, ''cJJb/a'' names, affiliates, or any other person acting on its behalf.

3. "Soundview Entity" refers to Comprehensive Community Development

Corporation, Community Expansion Development Corporation (flkJa 73 i White Plains Road

Realty Corp.), Soundview Healthcare, Soundview Healthcare Network, Soundview Management

Enterprises LLC, Burnside Medical Center, Castle Hil Medical Center. Delany Sisters Health

Center, Diallo Medical Center, and any of their directors, officers, agents, employees,

representatives, attorneys, predecessors, successors, parent corporations, subsidiaries, divisions,

assigns, "d//a" names, affliates, or any other person acting on their behalf.

4. "Document" is used herein in the broadest sense of the (erm and means each and

every writing or graphic matter of whatever nature, whether an original, a draft, or a copy,

including all non-identical copies, however produced or reproduced, whether or not sent or

received, and each and every tangible thing from which information can be processed or

transcribed, such as tape or other electronic data communications. The term includes but is not

2

Page 151: Espada Reply to Subpoena

08/28/200915:48 FAX ~012/017

limited to letters, records, forms, books, invoices, e-mail messages, voicemail messages, checks,

bí1s, receipts, diares, calendars, logs, journals, notebooks, plans, directives, instructions,

anal yses, telegrams, studies, contracts, agreements, correspondence, communications, statistics,

memoranda, notes, minutes, opinions, reports, summares, work-sheets, graphs, and charts and

any other means by which information is recorded or trasmitted, including but not limited to

audio, visual, and digital recordings. photographs (positive prints and negatives), slides, films,

phonorecords, teletypes, telefax, facsimiles, thermafax, microfilm, punch cards, compUter data,

printouts and data processing records, translated, if necessary, by the respondent through

detection devices into reasonably usable form.

S, "Concerning" means referrng to, related to, describing, reflecting, re.Barding,

evidencing, recording, memorializing, comprising, constituting, or supporting, directly or

indirectly.

6. The terrs "and" and "or" should be constred conjunctively or disjunctively,

whichever makes the request more inclusive.

7. The terms "any" and "all" should be construed as "any and all."

8. The use of the singular form of any word includes the plural and vice versa.

9. For purposes of this subpoena duces tecum, the time period applicable to the

following requests is August 1, 2003, to the present ("the applicable period") unless otherwise

noted. A request for a schedule, agreement, or other document for the applicable time period

encompasses any schedule, agreement, or other document created, 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.

3

Page 152: Espada Reply to Subpoena

08/28/200915:49 FAX ~013/017

10. Each document submitted in compliance herewith should be numbered

consecutively on the face of the document and should clearly identify the paragraph of the

subpoena to which the document is responsive, unless original documents are being produced for

inspection and copying. Copies of original documents should be legible in their entirety.

11. If any document the production of which is called for by this subpoena duces

tecum is withheld on the ground of purorted privilege, for each such document please provide

the following information in writing on the return date of this subpoena:

(i) the purported legal ground for withholding the document;

(ii) the type of document;

(iii) the general subject maHer of the document;

(iv) the date of the document;

(v) the author of the document;

(vi) all recipients of the document; and

(vii) such other information as is sufficient to identify the document for a

rno£Ïon to a court to compel its production.

12, If any of the documents called for in this subpoena have been produced to any

individual, organization, corporation, governmental agency, or any other entity, please provide

the Artomey General with a description of such documents and the individual(s) or entity(s) to

which such documents have been produced.

13. If any of the documents called for in this subpoena have previously been

produced to the Anomey General, please identify by Bates number (i) each such document and

(ii) the subpoena call to which the document is responsive.

4

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08/28/200915:49 FAX 14014/017

14. The response to this subpoena duces tecum 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.

DOCUMNTS TO BE PRODUCED

1. Documents sufficient to show all names, including but not limited to predecessor

companies, successor companies, affliates, and "d//a" names, under which Regal Realty has

conducted business at any lime, or from time to time, during the applicable period.

2. Documents sufficient to show the fulliegni names and current street addrsses

and telephone numbers for all current owners, offcers, directors, or principals of Regal Realty.

3- Documents sufficient to show the full legal names ~nd last known street addresses,

and telephone numbers for all former owners, officers, directors, or principals of Regal Realty.

4. Documents sufficient to show the full legal names and last known street addresses

and telephone numbers for all Current and fonner employees of Regal Realty.

5. Documents sufficient to show the management and corporate structure of Regal

'Realty.

6. All documents relating to any contracts, agreements, or transactions involving

Regal Realty and any Espada Campaign Entity.

7. All documents relating to any contracts, agreements, or transactions involving

Regal Realty and any Soundview Entity.

8. All documents relating to any contracts, agreements, or transactions involving

Regal Realty and any or all of the following individuals: Sandra Love, Mara Cruz, Esther HiJl,

Joyce Oates, Leonard Frazier, and Dora Garia (or any of their relatives).

5

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08/28/2009 15: 49 FAX 14015/017

9. All documents relating to any contracts, agreements, or trnsactions involving

Regal Realty and any business, corporation, organization, or other entity in whIçh Pedro G.

Espada, Jr. ("Mr. Espada"), a Senator in the State of New York, has a direct or indirect financial

Or other interest.

10. All communications and correspondence sent to or from Regal Realty, on the one

hand, and any Espada Campaign Entity, on the other hand.

11- All communications and corrspondence sent to or from Regal Realty, on the one

hand, and any,Soundview Entity, on the other hand,

12. All communications and correspondence sent to or from Regal Realty, on the one

hand, and any Or all of the following individuals, on the other hand: Sandra Love, Mara Cruz,

Esther Hill, Joyce Oates, Leonard Frazier, and Dora Garcia (or any of their relatives).

13. All communications and con'espondence sent to or from Regal Realty, on the one

hand, and any business, corporation, organization, or other entity in which Mr. Espada has a

direct or indirect financial or other interest, on the other hand.

14, All documents relating to any Espada Campaign Entity.

15. All documents relating to any Soundview Entity.

16. All documents relating to any business, corporation, organization, or other entity

in which Mr. Espada has a direct or indirect financial or other interest.

17. Documents sufficient to show (i) all income received or earned by Regal Realty

during the applicable period, (ií) the source of all such income, (iii) the date of receipt of all such

income, (iv) the payor of all such income, and (v) the services or goods, if any. provided by

Regal Realty in connection with all such income.

6

Page 155: Espada Reply to Subpoena

08/28/2009 15: 49 FAX ~016/017

18. Documents suffcient to show (i) all expenses incurrd or paid by Regal Realty

during the applicable period, (ii) the date on which each such expense was incurred or paid, (iii)

the recipient of all monIes paid in connection with each such expense, and (i v) the services or

goods, if any, provided to Regal Realty in connection with each such expense.

19. Documents sufficient to show the full bank name, bank location, and account

number for each bank account (i) belonging to Regal Realty or (in to or from which Regal

Realty has the ability or authority to deposit or withdraw funds.

20. All bank statements for each and every account identified in connection with

subpoena call number 19 above.

21. All financial statements, audited or unaudited, concerning Regal Realty,

22. Documents sufficient to show Regal Realty's revenue and profits (gross and net)

on a monthly basis for each and every month during the applicable period.

23. All pleadings fied in the matter of Regal Realty Services, ILC v. 2590 Frisby

LLC. et aI.

7

Page 156: Espada Reply to Subpoena

08/28/200815:48 FAX 1à017/017

Under the provisions of Article 23 of the CPLR, you are bound by this subpoena to

produce the requested items. For a failure to attend on the date specified above, or any

adjourned date, and to produce the items specified, you may be liable, in addition to any other

lawful punishmen(, for the damages sustained by the State of New York, and for a penalty not to

exceed fifty dollars ($50.00).

WITNESS, Honorable ANDREW M. CUOMO, Attorney General of the State of New

York, (he 28th day of August 2009.

ANDREW M. CUOMOAttorney General. of the

State of New York120 BroadwayNew York, New York 10271-0332

By: ~\'n"'~l-D ~y M. Goddard ~

Assistant Attorney GeneralTelephone: 212.416_6091

Facsimile: 212.416.8068

8

Page 157: Espada Reply to Subpoena

EXHIBIT 12

Page 158: Espada Reply to Subpoena

08/31/200917:53 FAX I4 002/006

OFFICE OF THE ATTORNEY GENERALOF THE STATE OF NEW YORK._--------.._-----...._--------_...._----------------------.....

In the Matter of the

Investigation by ANDREW M. CUOMO, Attorney Generalof the State of New York, relating to

: SUBPOENA DUCESTECUM

Comprehensive Community Development Corporation, et al.

._---------......_----.............._-----------------------------_......_---------_.._.._----_.._-

THE PEOPLE OF TH STATE OP NEW YORK

To: Comprehensive Community Development Corp.

731 White Plains Road,Bronx, New York 10473

WE COMMAND that on or before the 4th day of September, 2009 at 2:00 p,m. you

produce any and all documents listed below that are in your possession, custody, or controJ ro

Attorney General Andrew M. Cuomo, Attention Darcy M. Goddard, 120 Broadway, 25th Floor,

New York, New York 10271, pursuant to the laws of the State of New York including New York

Not-PoT-Profit Corporation Law section 112(b), New York Estates, Powers and Trusts Law

section 8-1.4(i), and New York Executive Law section 63(12).

PLEASETAKE NOTICE that the Attorney GeneraJ deems the documents requested by

(his subpoena to be relevant and material to an investigation and inquiry undertken in the public

interest.

Page 159: Espada Reply to Subpoena

08/31/200917:53 FAX ~ 003/006

INSTRUCTIONS AND DEFINITIONS

1. "ceDe" refers to Comprehensive Community Development Corporation,

Community Expansion Development Corporation (ffka 731 White Plains Road Realty Corp.),

Soundview Healthcare, and Soundview Healthcare Network, and any of their directors, officers,

agents, employees, representatives, attorneys, predecessors, successors, parent corporations,

subsidiaries, divisions, assigns, "d//a" names, afliates, or any other person acting on their"

behalf.

2. "Document" is used herein in the broadest sense of the term and means each and

every wri ting or graphic matter of whatever nature, whether an original, a draft, or a copy,

including all non~identical copies, however produced or reproduced, whethar or not sent or

received, and each and every tangible thing from which information can be processed or

transcribed, such as tape or other electronic data communications. The term ìncludes but is not

limited to letters, records, forms, books, invoices, e-mail messages, voicemail messages, checks,

bills, receipts, diares, calendars, logs, journals, notebooks, plans, directives, instructions,

analyses, telegrams, studies, contracts, agreements, correspondence, communications, statistics,

memoranda, notes, minutes, opinions, reports, summaries, work-sheets, graphs, and chans and

any other means by which information is recorded or transmitted, including but not limited to

audio, visual, and digital recordings, photographs (positive prints and negatives), slides, films,

phonorecords, teletypes, telefax, facsimiles, thermafax, microfim, punch cards, computer data,

printouts and data processing reçords, translated, if necessary, by the respondent through

detection devices into reasonably usable form.

2

Page 160: Espada Reply to Subpoena

08/31/2008 17:53 FAX I4 004/008

3. "Concerning" means referrng to, related to, describing, reflecting, regarding,

evidencing, recording, memorializing, comprising, constituting, or supporting, directly or

indirectly_

4, The terms "and" and "or" should be construed conjunctively or disjunctively,

whichever makes the request more inclusive.

5. The terms "any" and "all" should be constred as "any and aIL"

6. The use of (he singular form of any word includes the plural and vice verSa_

7. For purposes of this subpoena duces tecum, the time period applicable to the

following requests is August 1, 2003, to the present ("the applicable period") unless otherwise

noted. A request for a schedule, agreement, or other document foi: the applicable time period

encompasses any schedule, agreement, or other document created, 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.

8. Each document submitted in compliance herewith should be numbered

consecutively on the face of the document and should clearly identify the paragraph of the

subpoena to which the document is responsive, unless original documents are being produced for

inspection and copying. Copies of original documents should be legible in (heir entirety.

9. If any document the production of which is called for by this subpoena duces

tecum is withheld on the ground of purported privilege, for each such document please provide

the following information in writing on the retur date of this subpoena:

(í) the purported legal ground for withholding the documenr;

(ii) the type of document; ,

(Hi) the general subject matter of the documenr;

3

Page 161: Espada Reply to Subpoena

08/31/2008 17: 53 FAX I4 005/006

(iv) the date of the document;

(v) the author of the document;

(vi) all recipients of the document; and

(vii) such other information as is suffcient to identify the document for a

motion to a court to compel its production.

10. If any of the documents called for in this subpoena have been produced to any

individual, organization, corporation, governental agency, or any other entity, please provide

the Attorney General with a description of such documents and the individual(s) or entity(s) to

which such documents have been produced.

i 1. If any of the documents called for in thjs.subpoena have previously been

produced to the Attorney General, please identify by Bates number (i) each such document and

(ii) the subpoena call to which the document is responsive.

12. The response to this subpoena duces tecum shall be continuing in nature so as to

require a !Supplemental response iii the event that, after responding to any individual request. you

obtain Or become aware of additional infonnation responsive to any request.

DOCUMNTS TO BE PRODUCED

1. Personnel fies of the following individuals: Pedro Espada, Jr. ("Mr. Espada"),

Mara Cruz, Sandra Love, Esther Hill, Norma Ortiz, Marzetta Harris, Alexander Fear, Kenneth

Brennan, John Feliciano, and any relatives of Mr. Espada (by blood or mariage) who have

recei ved compensation from CeDe at any time, or from time to time, during the applicable

period (collectively, "CCDe Payeesn).

2. Documents suffcient to show all forms of compensation and employment

benefits that the CeDe Payees have ever received in connection with their employment,

4

Page 162: Espada Reply to Subpoena

08/31/2008 17:53 FAX ~ 006/006

financial, or other business relationship with ceDC, including but not limited to salares, wages,

vendor payments, royalties, bonuses, insurance benefits, deferred compensation, expense

allowances, automobile leases, housing allowances or lodging, medical and dental benefits, 401k

or retirement fund benefits, and any other form of compensation or funds that they ever eared or

received from eCDC.

3. All Forms W2, W4, and 1099-Misc. for all CeDe Payees.

4. All documents concerning any automobile purchases, automobile sales,

automobile leases. and automobile expenses (including but not limited to expense

reimbursements, gasoline expenses, and EZ-Pass records) incurrd or entered into by eeDe or

any of the CeDe Payees at any time, or from.time to time, during (he applicable period.

Under the provisions of Article 23 of the CPLR, you are bound by (his subpoena to

produce the requested items. For a failure to attend on the date specified above, or any

adjourned date, and to produce the items specified, you may be liable, in addition to any other

lawful punishment, for the damages sustained by the State of New York, and for a penalty not to

exceed fifty dollars ($50.00).

WITESS, Honorable ANDREW M. CUOMO, Attorney General of the State of New

York, the 31st day O(August 2009.

ANDREW M. CUOMOAttorney General of theState of New York120 BroadwayNew York, New York 10271-0332

~Co~ ci"j.4 n. _ __arc y M. Goddard

Assistant Attorney GeneralTelephone: 212.416.6091

Facsimile: 212.416.8068

5

Page 163: Espada Reply to Subpoena

-

EXHIBIT 13

Page 164: Espada Reply to Subpoena

State of New YorkOFFicE OF THE ATTORNEY GENERAL

MEDICAID FRAUD CONTROL UNIT120 aru¡¡dway, 13 Ploor, New York, New York J0271.0Q07

(212) 417-5300 Fiix: (212) 417-5655

ANDRRW M. CUOMOAttorn"y Generil

HmDI A. WENDELSpecial D"puty Attorn"y Gcncr~1

THOMAS E. o 'HANLONCHklSTOPHF.R M. SliA W

DepUty Rogional Directors.

October 2, 2009

Pedro Espada, Jr., PresidentComprehensive Community Development Corporation731 White Plains RoadBronx, NY 10473

Re: Comprehensive Community Development CorporatIon d/b/a Soundview HealthCare. Network, Soundview Health Center, Or Soundview Health Care, MM1S number 00665274

Dear Mr. Espada:

Pursuant to 18 NYCRR §§ 504.3 (a) and (g), the New York Statt) Attorney General's MedicaidFraud Control Unit requests that Comprehensive Community Development Corporation produceall documents specified in the enclosed Schedule A.

I request that these records be fumished to this Offce no later than October 19,2009.

If you have any questions, please contact me at 212.417.5284 or larissa.payne~oag,state.ny.us.

k you in advance for your cooperation.

'ssa Paynep cial Assistant Attorney General

,''',

Enclosure: Schedule A"

zoolP XYd 9Z: tT 600Z/Z0/OT

Page 165: Espada Reply to Subpoena

Schedule A

1. Definitions and Instructions

1. General tenns

a) "Document" means any tangible information or electronically stored informationincluding, but not limited to, writings, emails (and attachments), metadata,spreadsheets, instant messages, drafts, drawings, graphs, charts, photographs, sound orvideo recordings, images, handwritten matter, reports, correspondence, memoranda,records, interviews, diaries, accounts, contracts, notes, ledgers or other records ofinformation, including those from disaster recovery systems and data or datacompilations stored in any medium from which information can be obtained andtranslated, if necessary, by the prOducing party into reasonably useable form."Documents" shall include originals (or copies if originals are not available) and non-ideiitical copies (e.g., containing handwritten or typed notes, highlighting orunderlining or otherwise) and any translations of any document.

b) "Relating to" mèans referring to, relating to, reflecting, concerning, describing,evidencing, or constituting.

c) "Including" means "including but not limited to."d) The terms "any" and "all" each mean "any and alL."e) The terms "and" and "or" shall be construed dther conjunctively or disjunctively as

necessary to bring within the scope of the Schedule all responses and documcnts thatthe other construction might exclude from its scope.

i) The use of the singular form of any word includes the pi ural and vice versa.

2. "CCDC Entity" means Comprehensive Community Development Corporation (d//aSoundvíew Health Center, Soundview HealthCare Network, or Soundview Healthcare), of731 White Plains Road, Bronx, NY 10473, and any of its satellite clinics, includingSoundview Health Center, 731 White Plains Road, Bronx, NY 10473; Castle Hil MedicalCenter, 616 Castle Hil Avenue, Bronx, NY 10472; Burnside Medical Center, 165

Burnside Avenue Bronx, NY 10453; Delany Sisters Health Center, 821-7 East 233rd StBronx, NY 10472; and Diallo Medical Center, 1760 Westchester Avenue Bronx, NY10472.

3. Unless otherwise specified, this request applies to all documcnts in effect, created,recorded, compiled, transmitted, or received relating to the years ending December 31,2005, through Decembet:31, 2008.

4. Production of all electronic messaging system dOcuments, including but not limited to

emaÏ1s and instant messages, should include the messages in their native email format,including header, body, and fie attachments. Please identify the email software name,version, and build, and the softare paCkages used to create tho emaiI attachments. Emaíldocuments must be identitiable by the individual emaI1 account holder/user.

p

CO°IÈ XVd 96: tl 600ZlZO/Ol

Page 166: Espada Reply to Subpoena

5. Documents required under the Medicaid program for record-keeping, billing, and patientcare, including but not limited to databases, spreadsheets, and other types of supportingdocumentation, should be produced in a format that preserves data manipulation andfonnatting and exported to xIs, mdb, or dbf format(s). Such documents should be clearlyand explicity identified as to their source and content. In the event that you utilize apropriety package, the exported records should be exported to a searchable PDF fonnat.

Ó. Documents'other than electronic messaging system documents, databases, andspreadsheets should include clenr and explicit identification of

the SOurce and content ofthe document, and should be provided in a searchable PDF format. In the event that youdo not have software to create a searchable PDF fomiat, then printed documents must beprovided jn paper format with the corresponding metadata.

7. All documents should be produced On DVDs, CDs, or usn drives, or a combinationthereof.

8.. When there are markings on both sides of a dociiment, both sides shall be produced.

- .9. Provide an index listing each individual document produced by the same title listed on theDVDs, CDs, Or USB drives and identify all numbered specifications to which thatdocument is responsive. Wt; also suggest marking each page produced, in the lower rightcorner, with identi(ying consecutive document control numbers.

II. . Documents to be Produced

1. Any and all documents relating to the CCDC Entity's ambulatory health care facility("AHCF- i") cost report and managed care visit and revenue report ("MCVR"), includingbut not Jìmited to:a) The New York State AHCf-l cost report and any and all underlying books, records,

reports and other work papers that form the basis of the data and information in theAHCP.l cost reports;

b) All reports, schedules, journals, logs, summaries, accounts receivable jourals orcards reflecting the billngs to, and receipt of payment from, Medicaid and Medicaidmanaged care organizations ("MCO");

c) All summaries, schedules, and lists of

all threshold visits, organized by calendar year;d) Patient bad debt I??licy guidelines and all . schedules and/or entries showing the

calculation of patÜ~fits' bad debts, including the threshold visits and the revenuesassociated with the bad debts, organized by calendar year;

e) All records documenting efforts made to collect on patients' bad debts and all recordsrelating to the use of any collection agencies regarding these bad debts, includingcontracts, paid bils, and collection reports;

f) Self-pay Sliding 1~ discount schedules, including any policy guidelines, instrctions .

and correspondence, and all records reflecting names and revenues received frompatients wlia.e paymentsf'or services were based on a sliding.fec, organized bycalendar year;

l100~ XVd 9Z; l11 600Z/Z0/01

Page 167: Espada Reply to Subpoena

soo Il

g) All schedules used to prepare MCVRs fied with the New York State Department ofHealth; and

h) All supporting records used to prepare the MCVR schedules, induding but not lìmItcdto:

i) Visit information, organized by MCO and independent practice association

("IP N'), including attendance records, encounter records, and appointmentrecords;

ii) Revenue infonnation, organized by MCO/IP A, including patient billingrecords and cash receipts records; and

iii) Withhold adjustment in£c)rmation, organized by MCO/IPA.

"

XVd 96; ~t 600Z/Z0/0t

Page 168: Espada Reply to Subpoena

EXHIBIT 14

Page 169: Espada Reply to Subpoena

11-06- l 09 11: 36 FROM- 12124174604 T-046 P0Ø02 F-052

State orNeI\ YorkOFFICE OF THE ATTORNEY GENERAL

MEDICAID FRAUD CONTROL lJNITi 20 Broadway_. 13 Floor, New York, New York 10271 -0007

(212) 417-5300 Fa-.; (212) 417-5655

ANDREW M. CUOMOAllomey Ge.neral

HEIDI A WENDELSpecial Deputy Aiiomey General

THO\lAS E. O'HANLONCHRISTOPHER M. SHAW

Deputy Regional Direciors

November 6, 2009

Noah Shelanski, Esq.Hafetz & Necheles500 Fifth AvenueNew York, NY 10110

--by facsimile-

Re: Comprehensive Community Development Corporation d/b/a Soundview HealthCareNetwork, SoundvIe\v Health Center, or Soundview Health Care, MMIS number 00665274

Dear Mr. Shelanski:

P.lsuant to 18 NYCRR §§504.3(a) and (g), the New York State Attorney General's MedicaidFraud Control Unit requests that Comprehensive Community Development Corporation

("CCDC") furnish this office with the original charts for the recipients listed on the attachedschedule A.

Based upon our previous conversations, it is my understanding that Hafetz & Nechelesrepresents CCDC and that your finn is accepting service of process on your client's behalf. Ifthis is incorrect please notify me immediately.

The Medicaid Fraud Control Unit's request requires your client to provide the entire treatmenthistory for these patients. CCDC should furnish the original chart to my office no later thanNovember 20, 2009.

Page 170: Espada Reply to Subpoena

11-06-' 09 11: 36 FROM- 12124174604 T-046 PØ003 F -052

If you have any questions, please contact me at 212.417,5284 or larissa,payne!ßoag.state.ny.us.

Thank you in advance for your cooperation.rq-,\ J

Sirlc\etely,i,

)(¡i ,I. i \

Lari$~-PäYñe---Spettdi Assistant Attorney General

,jEnclosure: Schedule A

ï

Page 171: Espada Reply to Subpoena

11-Ø6-' Ø9 11: 37 FHOM- 12124174604

SCHEDULE A

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¡AMARO YVE1TE... ".- ".- ". -",¡ANDERSON JUANA¡APONTE DOLORES¡ARANA MARIAAREVALO DIXA

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'ARZÙMANARA' .KAZI'(AVILES'" PETER

JAYA.LA ...rvt.RGn . .

...¡A?EE1\ .5.AHIBZADA M'BARNES DIANE E,BARRETO EDWINlBASKIN ACHILLES¡BEGUM FATIMA¡BELL FLORENE: BELLUCCI LEO,~ENJA.MIN KI~H A'BERMUDEZ MICHELLE

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Page 172: Espada Reply to Subpoena

ll-\1b-' \1:t 11: '6'1 lHUM- 12124174604 T-046 P00Ø5 F-052

SCHEDULE A

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¡TN~_l,5__~S._~ .",L~?~,F~~Y__l-~ ,J~.~~~,. '~'P ..l,olo.~/99!'SH63604V ¡GORDILLODESANYER OLGA V 11/12/42:.. .'_' "."_ _,_~_'_ .._._.,..... _ '....,.. ...", ..,_...... _, .........,.~ .~_.___._ ..... "___..~._'__"_'.'_'_'_r"_ .___'..,._.~._~_." "...._"..._. .,.....__.. _ '. '.-'__ .... R' ..-..--___ --. '" ~¡SS87112T ¡GRANT LISA . 03/01/71:fZROÜ-34Ù:¡--' _..". .....'TGREENE' ...-'rvlELiSsA...." .--",. '.O~/3Õ/83;(' ....__.. i,". _""__'_, _...,-,........,...___..,..__.._ __....,..,.....,_ .....- .._..._......,..,._... ...... _" .... '" .. ..'........ "'_."_'-__" . . -' '."" ...,..".. .L¡TM19563B ., '" ".. ¡GUERRERO ANDREW E ",10/09/001

rZB.~i_~~!~d_" ....... ..:...199~d~~!~?,...~§~~~~...,:d. ... ."on.. ..,. .....~.g,iZ~~ZS-~j¡US19179G ¡GUTIERREZ EMERSON I ..,~S./lSl9?;

¡~~~l~l~' ",~ji~l~~~::~ri~~rT;.~,' '.," ,," ",..,..'..." ,," , ", ,.--~~f~~!ilYN61829E .,., ¡HAMILTON ANNEMARIE 04/01/~4:¡,i~~§tit~.. .. ',. .......-J~;t~t'i.N_~....~~~~t~~:~.u_.::,. . ....-- ...."..'..d...:_:':.d...~..,.,....ò~1~~::6!

iSZ1~~~?~ JJ-~,~r-~.NgdE_~. . _.~.L~.R.EL~C? g?!lQ/60'iYR66Ú;3R ¡HERNANDEZ ELiX 07/2§/46ri~5~~i~~~u..:rHË~~~Nl?'~i 'd.':(~rŽA~.ET~__ . ..,.... ".' ..._, .'. OÛ~§l?9.¡ZT41989C . ' ,i HEYWÃRD STEPHANIE.. ' . . .9~!96!6..~ji.~~?~~3~.".. ...' _....' "d .',',jBi~I___.~~,~~,'--:~§I.'_,'..:,~"._:~~~~~.~.'~.__'~."..__.,__... _,......... .j,_~~_".":."".._."._~Q(3.31~~J

!ZH30939C . j HOGUE , " DOROTHY,. ..., " ¡ ... ,. 07/26/53;¡z.~~~~~'?'N"".'u",:dJE~~T~E"::-"-'5~~-R:~'~-~'ddd ......'...." ..., ..,'.'....:d.. n,...n:,.d:...n:i.~lg~7~~¡

2

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11-Ø6-'Ø9 11:37 FROM- 12124174604 T-046 P00Ø6 F -052

SCHEDULE A

.1llli!~~girflillt.1YT02347N :HUYNH CUONGiZT815~4.~J . ; IRIZ.~RRY JANETTE¡SH~1,a~4(: iiRI~_~RRY . .~~R.TIN-____h" __hh

LZH78??hEi~. h .,i~A.~KSON. .~A.T~_~~__.:~YEì~?47Th!J~N~hS hhh '~~~'~!._'NhNhh'__'VN12427T ;KING MICHAELlUyÒ9f)Ò2Kh h' . . ¡LARA-êUENTÈ::'.A~~.i.hËY. h. iSK48703G ¡LARREA DAYANNA E"_..__n. '.'_.._h __....._...

Ll!~~8~0~h~h h ,.LL~R~~S~I. .._Iy'~.NN ~h" h"_' h,h h .....h .....'.....!WU10172M ¡LEBRON ELIZABETH!~~~§i? ~Uhh . ..,T~ïit~(:' JAt0g.S':.

tX.~~7~.? ~~ 'h hJLC?h~~~ .c.~~~S.TO~~,~T_",¡RQ350~.oA !L~.~ah hh'hf\,¡\~Ir.'_h"h"¡~H55!98Sh ¡L()p'~Z . ..N~.~IS.¡h~Tf:i30?o.H ¡ L9PEZhRI,GAR.D0YQO~9~5E h ..dU?tEl... _' TA.NIl!?KA L¡ZtI.~~5h1?YjLh~N?r()R~' ...LlSA:... .'.

l~fl64047D ..;!"~IS?'N'~!h___KATI~I~"h'¡SS28121G jMA.LDONADO CLARALUZ CiZG99247T ¡MALDONADO LYDIA'i~.Vý.36ai6Ch '; MAU)6NÄDO.~~rv()NïTA

'ZU45873Q ¡MALDONADO REBECCA~ß~?5'~7h~ '!MARINh hCIN~ER~~~,t

Y':'Y7i.~??~J0,tRTINhEhZ CATA~i-r\J¡\h

f R~?3h465a ¡M!,~!i,N~~ CHRISTAN J¡ ~~~?~?h3~J~~~TI N EZ N I~K.¡hTA~i.h??~hi-h:ryJ\T(JS. h~_EhLt~IA_h . .

¡~ht¿S.~h~h~?r' . ..L~,~~t¿~_Eh__' .,~~~!''~h~__!h'h!UD10655X lMEDINA KEVIN Trzu4957iÁ'" . . 'TMER'CADo'AIDA--hh...Uh--Uh.h..._.h .¡VÙS7438p.h. ," -¡MERCAÕÕCRÙZ"hpERe:-VER'ÄÑ'

¡X~?hÖ!?~ê'h ..' . , --dI~~.~"~~~'..dh_hhh-.~~q~~f.'N~__-.d__'du_, . ....

:~~,~~~a?~_Uh_ . .. ,.....JfI_lg_~~~,Tg_f\...~~~N.... .t~~.~~s.~.?'~- h_ .'. jN1h~~r:L'~~?N""'h~I-N~t-'h' .'.

¡~t;i.l?07~ah . . .........¡.~~ç~t~..~_~h..._.. h~t~~~h..'.._......~,.........";QN91708H ¡MITCHELSON YVONNE

t~h~~~~2,0ïh_""F0~~í~Ã'" h ")§~(d:..__. "_'.'i!~.~?~~~r . j~,~.f\'~~~'h....~_,t'!~hEIJ?_A n Uh. hh.h'__ ,.l.vy.q~~~~~E"..... ..'..hn_J~g2£:Y.... .~T~~I-Af\!~, £:h. .'.iVP45367H ¡MOODY. STEPHEN. ..to. 00".' ..~.'" .. ...._.__,n _._.."k,__._ "''':" ....,._n_u.~__.:...._... ,"_ - ,..._,_.... .._,......-..-.. -... --.._..,.... ....- -.. - p", '-" ,,_,F. ".C_."'

L~~h?U-~~'~r.'...nJ~~~~~~.~--.. __~.~,I~!~.,,"_hh..h .' n""','iy~-i~~ ~~ ~ '.. h _ _ hhhJ~?R.~L.E~n .. . .~'v,~ ~~~ _. .. ...,... h"" .

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iRH97529Z !MOROCHOGUAMAN JOHNNY RfTW13"-lÙÄ"'" _"m' '.' ..,..'TÑlORRíS'....." ,..-rVÊ(;ÃN......F .......--_..-.. .'u. .".__ ._, ,'._,"" ..0_ .__ ._d"._ ._._ .. _. __', _.__'_ ". .._.,. "__'._'._..,. ....____ no' ....._....._....._.........~~_._,... _"_'_'.' n.'

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3

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11-06- l 09 11: 38 FROM- 12124174604

SCHEDULE A

T-046 P0007 F -052

.!flt~~ilmlt§ri~¡'l!iVr9038.1Nirv~LL1GAN JESSICA!T~1-i~14H lrv~NIZ . JUANAiV(~~:3_6~?GJN.~,~.I_§~ LUZ:~~~~,~_2_?,~_ d¡~,~~~A ~_",._~~!:,T,E, L:XQ70465P ¡NATAL- MICHELLE

¡~N?i,925F '___ ,. _':l~t~R?~~__-~-,-_F-~~NCìS-'u "HZH24549Y ¡NEGRON MYRNA¡ZZi-lOl?-~, ,.IC?~T'0~,N,,_._~SHEENA G

¡ ~~_~S.,6~3 T,_"J t:~!I!,__ _._~LY!_N' __,,_ .... _ _ . .'_'.' ,_.__

tZ_U5!~-?9A . , .! ORTIZ ELIZABETH

¡?!g.?~g_?~X _. .dd~'I ~fr:iz.'__-:""d-' .-d(~-~_i_G()- "-i"'" .',

LT~_4.?_~25SH__,J()R--TIZ ,_, .~!,~GROS!T~~3?!9K " ....' _Hj()RTIZ NIDIA¡UA85,805E J()~()RI() FRANK:Z~~g?~?q _j()~~.NS_. MAGDA M:SNJ_6 765 ~ ,.!tACH E,C() LUZ E;ZT46:33~A ..J~~siAN . .~,L()RIJ\ ,~,l~~_~~?36~L~ALE~rv?J~A,N~Tf E¡ZEt)9663B iPANTOJA TRACY Li~~!754_4~.)PAR~~R LANISHA A

~T~9.~?8.qM jpARK~RIII K~NNEIH:ZT87711Z èpEREZ ELBA. .WF29185Ù' ;PEREZ' JAVIERYU37S02N ¡PEREZ MARIA:yp~i9.l3iN¡p8.gE.". ,..... ~8§,N,'",'NS??~?~SJl-~Tf~AN_ _!AN,tTN"iq,:~~g?t)~.... '__H"Ll-I~A.~~g, .'..'. ,.A_N.!~(?NY"D

LZ,~_~~??9.J\.__,..".-.,JY()~A,?,...--.~~p.!?_--. - ....-_.¡y t:l_~~_~:3X,._... ,_ _',_ ..'_ ___J~A~~rv..__",_A~g~L.KA~1 M

l~p~q~~~lJ, _.' ",_.' __..,_..-L~A~~I,N_C?,.,._..P.!:!LLI P K!UG91209R 1RAMOS ELZABETH~ ._..._......__....__. _ ,",_ .. _....... ...__.~.,. ......... "'_'", ," _'.. ..j _... .", "'-" _....." .. _. "_."_ ....' ... _.. ._._.....~n.... _.. "._'..' .__._....__.. n. __",

iXYS6601Q ¡RAMOS EVELYN

l~~;~,~tt~...... . ...,.."..,'_,_:~:'J~~~~.~~,.~...'.....'.~-~~§~j'~t.- -"

iZF24691Z ¡REESE LEZElTE D!QZ'778'62M '....-¡REvEs-.' ,... '-soiÒíÚs' ."I_.."......,...~,.._...__~'_ "__._ '",.- ..r,' --_.- .....,... ..-.;._...._-_., --~,.~,~....'~ . _._-...--~ ---..~..--....-,'...-- .". "-, ,"

fWK5787SQ ¡REYNOSO KIARA J¡.....- ...... ..... ,.. - . ... ..,........ .,.... ..,......... .... . ...,¡YZ67674S ¡RIVERA CARMEN!.. ........... '...... ' ....;....... ..,........ . ........ .. ,..,...... ,..- ...,...' . .¡~~g~~??F.,- 1 RIV_~~~_.,.~~R_~..t, .....,. . __ ...... .. .'¡~~~.s.?_?_O.~.., _ j R.iy~_R~. .._J~_S_Ti.N_ _ .

i~~li~i~~~:_~~t~~t~UE~,~Ä~l~:~: '" '" ,'.,',jZW82185R , ¡RODRIGUEZ CARMEN

lži32ÒÙD ....-!rÚjÓRiGÚEZ..'-'JUANìTA'ìii3'3-i2()¿'-" d.,.,...,..........__....'1'RoDRï'GuEi'.......,-MARÎÁ'.."..._-. .ï---""_. .....-.,.,~ ,-._0 .' '. ......... _. .'-'" '.' _.~. ,'-, ..;-.~._.......--..-........, .".._..-._...~-...._'.....~..- ,...-.--,.-, .',~,..-...-. ,,-...-- --~..,..._.,..-.¡ZK2890SF jRODRIGUEZ MICHELINE

09/27/9007/20/65

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4

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11-06-'09 11:38 FROM- 12124174604

SCHEDULE A

T-Ø46 P0Ø08 F-052

1ftljiiitß~glîl§l$îi!R¥tiW*l ;lf~l~~i~~l?'ti¡i,tîtt~g!lllrJilfB~~jji~~~~ii~~~~t~~%¥.~tÆ~¡R~~Jll~tìtß\R-ø;§¡~;~:ZZ7,6090NjR()DRIGl)EZ NANCY . 03/31/67VS50313G 'RODRIGUEZ YOLANDA 11/05/60:LJC31q4l,T !RO~RIQUEZ WIL~IAM 06/24/98:ZN6~O~~B ,...,_LR,o.~DAN S()N,IA N 05/30/61:XA87840W ¡ROMERO BELKIS 07/15/67_X?ï§~~~~-.' JR?'.~ER.0 .JU~iTH F .?!/30j84'XTi-68~6A. LROSADO BERNADETTE 07/14/68'¡VG843~1P .,jR??AD,() E~.IL Y C. .10/05/85::Z~l~?O~~ . ¡ R()S~()O MARITZA 04/05/56ZP78689F' . ROSÄDO . ZENAIDA 01/21/44:VK49742G ROSARIO ALEXANDER 07/06/51,ZZ73938V RUIZ JUDITH 05/15/46SW21849P ;SABUR JUSUF 02/02/00:ZY96094D :SADDLER LILLAN M 04/23/59VK97544FSALGADO RAMON OS/22/58:TV99800Y iSAMUELS DARION J 10/30/98TB52400BSANCHEZ GUADALUPE 07/18/66:ZK67482Z 'SANTANA EDITH 09/29/47:QT95192SSANTIAGO DENNIS 09/19/62. .VZ30~36H .. ,SANTIAGO JOEL 02/19/93RG81339W¡SANTIAGO JOSE M 02/03/43XA65693QSANTIAGO VIRGINIA V 03/14/59ZG94576TSANTIAGO YOLANDA 04/29/60SU29558N SCOTT GAIL A 06/26/91YS59258P SERRANO ANAXAGORASD 06/14/44ZB83858W ;SERR4NO LUZ 11/07/59:SX80748P ;SHAHA RADHA R 04/10/71ZG3ii39Z iSHERADE LATISHA 07/06/84RS15381Q :SILVA ISMAEL 05/31/79.ZW084Ô1G .' SJrvMONS TRACEY 10/~0/62'UQ73145PjSINGH SU KHDIP 09/18/90.'YA22966X ¡SMITH DIAMOND L 06/27/75j-rQ83743V ..... 'SMITH GERALDINE .06/12/81:ZS?79~8E;SMITH KATHERINE 02/05/70QM98269W :SO,KONA DRAME 05/11/87UZ50049J :SOLON CELERINO A 02/03/23UG98345B ,SOLTREN CYNTHIA F 03/11/91YQ11462X 'STEPHENS RUBY 0~/19/47zi35338U . 'SlJAREZ ISRAEL 12/24/49:ZS73096P iSUTTON VALERIE 07/01/59:RF73326B :TAYlOR AlEISHA l 08/31/05. ...SH61055HTHOMAS LESHAWN E 10/13/06BS2556,3A .Ti-0RNE DENISE iiïi~V56ZZ12140D TORRES ELBA 04/21/59vrì8720E ¡TORRES WALTER 07/06/54VT39242Y':TRENT SANCHIE ÒS/26(7SZR02691C ... .' :TLJRPAO MARIA 10/16/52

5

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11-06-' 09 11: 39 FROM- 12124174604SCHEDULE A

T-046 P00Ø9 F -052

~tiil~Íß:~¡;RlltbWtll:¡:í;%lf~~ ;i~OOilÍtlìfl!il~i0~ii~t~ß'gttlml1ll\~~~k1~tìfg1IkJ§f~~ ~~ttt~§~ral~lI~,~WiSA66086T URBAN LUIS . . 05/02/42SP09178FVALDEZDEPADILLA CELNA 07/01/56.XM9212SMVANDYKE CELESTE 06/23/43:ZB721nCVEGA MAYRA 08/07/61:YX42401SVELEZ PEDRO 08/01/43YZ97037AVEREEN SHEILA 06/24/69,VE17575S :VILLARUBIA SABRINA 10/01/94XK29024P ,VILLEGAS MARY A 12/06/55RYS4288U 'WALLACE ARTHUR K 12/25/95ZR98686DWATERS CHRISTINE 11/26/71QZ85639BWATSON DIONNE A 09/11/06:TP47957D WATTS MICHAEL D 12/31/99iZG751S6PWEIS5ENSTEIN ALAN 04/14/53:XH22671G 'WHATI5 NORMA I 10/04/72ZC51458A WHITE ANNETTE 11/04/71ZF22276S WHITE KAMAAL J 11/26/805563756D WILLAMS GISSELLE 05/04/00ZN64970CWILLIAMS JOSEPHINE 08/05/63;YY68869V 'WILLIAMS LEON 03/07/80ZM29763Q :WILSON DONNA 12/20/55ZC59797V WILSON PATRICIA 10/12/61UB38897P WOODARD MYASIA 09/12/97ZP16438RWOOLRIDGE AUDREY 04/18/46

6

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EXHIBIT 15

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11-17-'09 14:58 FROM- 12124174604 T-055 P0002 F -061

STATE OF NEW YORKOFFICE OF THE A TTORi"IEY GENERAL

MEDICAID FRAUD CONTROL UNIT

SUBPOENA DUCES TECUM

IN THE NAME OF THE PEOPLE OF THE STATE OF NEW YORK

To: Custodian of Records

Comprehensive Community Development Corporation731 White Plains RoadBronx, New York 10473

WE HEREBY COMMAND that you appear at the Offce of the New York State AttorneyGeneral, Medicaid Fraud Control Unit, located at 120 Broadway, 13lh Floor, Ne\v York, Ne\vYark, on the 30th day of November, 2009, at 10:00 a.m" or any agreed-upon adjourned date ortime, to produce all documents specified in accordance with Schedule A that are in your

possession, custody, or control.

PLEASE TAKE NOTICE that Attorney General Andrew M. Cuomo deems the testimony anddocuments requested by this subpoena to be relevant and material to an investigation and inquiryin the public interest pursuant to the laws of the State of New York including Ne'vv YorkExecutive §63(l2), New York State Social Services Law § 145-b, New York State Finance Law§189, and the New York Penal Law.

Under the provisions of Article 23 of the CPLR, you are bound by this subpoena to produce therequested items. For a failure to attend on the date specified above, or any adjourned date, and toproduce the items specified, you may be liable, in addition to any other lawful punishment, forthe damages sustained by the State of New York, and for a penalty not to exceed $50.00.

WITNESS, Honorable ANDREW M. CUOMO, Attomey peneral of the State of New York, the

17th day of November, 2009. i1)if 'A'J"'\

:.- ! í n '-..,.._"'___.."....a\........,..."'-i..f i.l '

Lari(s$ PayneSped~al Assistant Attorney GeneralOft~eI of the Attomey GeneralMedi~aid Fraud Control Unit120 Broadway, 1ih FloorNew York, New York 10271Telephone: (212) 417-5284

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11-17-'0914:58 FROM- 12124174604 T-055 P0003 F-061

Schedule A

1. Definitions and Instructions

1. General terms

a) "Document" means any tangible information or electronicalJy stored informationincluding, but not limited to, writings, emails (and attachments), metadata,

spreadsheets, instant messages, drafts, drawings, graphs, charts, photographs, sound orvideo recordings, images, handwritten matter, reports, correspondence, memoranda,records, interviews, diaries, accounts, contracts, notes, ledgers or other records ofinformation, including those from disaster recovery systems and data or datacompilations stored in any medium from which information can be obtained andtranslated, if necessary, by the producing party into reasonably useable form.

"Documents" shall include originals (or copÍes if originals are not available) and non-identical copies (e.g., containing handwritten or typed notes, highlighting orunderlining or othenvise) and any translations of any document.

b) "Relating to" means referring to, relating to, reflecting, concerning, describing,evidencing, or constituting.

c) "Including" means "including but not limited to."d) The terms "any" and "all" each mean "any and alL"

e) The tenns "and" and "or" shall be construed either conjunctively or disjunctively asnecessary to bring within the scope of the Schedule all responses and documents thatthe other construction might exclude from its scope.

f) The use of the singular form of any \vord includes the plural and vice versa.

2. "CeDC Entity" means Comprehensive Community Development Corporation (d/b/aSoundview Health Center, Soundview HealthCare Network, or Soundview Healthcare), of731 White PlaÍns Road, Bronx, NY 10473, any of its satellte clinics, includingSoundview Health Center, 731 White Plains Road, Bronx, NY 10473, Castle Hill MedicalCenter, 616 Castle Hil Avenue, Bronx, NY 10472, Burnside Medical Center, 165

Burnside A venue Bronx, NY 10453, Delany Sisters Health Center, 821-7 East 23yd StBronx, NY 10472, and Diallo Medical Center, 1760 Westchester Avenue Bronx, NY10472.

3. Unless otherwise specified, this request applies to all documents in effect, created,recorded, compiled, transmined, or received relating to the years ending December 31,2005, through December 31,2008.

4. The obligation of production pursuant to this Subpoena is a continuing one. Documentslocated at any time after a response is due shall be promptly produced at the place

specified in the Subpoena.

5, Production of all electronic messaging system documents, including but not limited toemails and instant messages, should include the messages in their native email format,including header, body, and file attachments. Please identify the email software name,

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11-17-'09 14:58 FHOM- 12124174604 T-055 P0004 F -061

version, and build, and the software packages used to create the email attachments. Emaildocuments must be identifiable by the individual email account holderíuser.

6. Documents other than electronic messaging system documents should include clear andexplicit identification of the source and content of the document, and should be providedin a searchable PDF format. In the event that you do not have software to create asearchable PDF format, then printed documents must be provided in paper format with thecorresponding metadata.

7. All documents should be produced on DVDs, CDs, or USB drives, or a combinationthereof.

8. When there are markings on both sides of a document, both sides shall be produced.

9. Provide an index listing each individual document produced by the same title listed on theDVDs, CDs, or USB drives and identify all numbered specifications to which thatdocument is responsive. We also suggest marking each page produced, in the lower rightcomer, with identifying consecutive document control numbers.

II. Documents to be Produced

1, Patient bad debt policy guidelines and all schedules and/or entries showing the calculationof patients' bad debts, including the threshold visits and the revenues associated \vith thebad debts, organized by calendar year for all CCDC entities;

2. All records documenting efforts made to collect on patients' bad debts and all recordsrelating to the use of any collection agencies regarding these bad debts, including

contracts, paid bil!s, and collection reports for all CeDC entities; and

3. Self-pay sliding fee discount schedules, including any policy guidelines, instructions andcorrespondence, and all records reflecting names and revenues received from patientswhose payments for services were based on a sliding-fee, organized by calendar year forall CeDC entities.

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EXHIBIT 16

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Dot 03 2009 4: 49PN HP LASERJET FAX S 147884l?5,O io. 2

Ne1 W. KeleheCo Cha

...........f'.-:tio''''lrt.'.I~~~\i. .:1'~ ~l~~f'''#I1''''.''''

..1.....'

State of New YorkSTATE BOARD OF ELECTIONS

HeleuMoes DonohiiComillloner 40 SnuEN STRET

ALBAN, N.V.120~.ii08Pho: S1~414~O

ww" .eled1oii.øti tey .us

001l1a A. K.llnCo:Ch8l

Evelyn J. AqiiCOID....U':rete S. KoshJd

Co.EieCltive D1r~tor Staey L. ZaCo.Eieatlve Diecor

Februar 26, 2007

Lynn A. AdaEspada for the People215 EaElt.~5~ S~t¡ $t~'.:t8D

New.York NY r0128

Dear Ms. Ädiús:

. ... -:. ¿';' ':"'

.. ,...... ,-',....

; ~ ""'7",.:" . -,.'

The cOm.ttee tye does not appear to be corrett. PAC' 8 do not make dict ex.penditues pnbehalf of candidates, they make contrbutions only. Enclosed isa list of commttee tyes withexphinations. If th,is commttee is designated as a PAC, than the candidate' canot usc thisconittee as his authOrized commtt:e by filing a Candida~ Non-Exponditure Statement.

Please file an amended Cointtee Designation of Tresurer and Depository with -the corrctconi tte type. . .

If this ís going to bo'an authoried single candidate commttee, 'th when itls detennnedwhat offce the candidate is rug for, an amended Commtte Designation of Treasur and'DëpOBitory, a Commttee Statement of Authorization or Non-Authonzation by Candida andan ai~lended Candidate Non-Expenditu Statement must be submitted.

If you have questions, clÙI l-800-458~3453'or 5'18-474-8200.

Sinc:e.rely.~~MCheryl HaukSeniar Account Cler

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Oo~ 03 200S 4: 49PM HP LASERJET FAX 9147884050 p.5

LA W OFFICES OF DANEL L. PAGANO2649 Strang Boulevard Suite 104

Yorktown Heights, New York 10598(914) B30.5288

Fax (914) 788-4050EmaiI: daieluar;anolaw~opton1ine.net

March 9, 2009

VIA FAX AND REGULAR MA

Liz Hogan Es.New York State Board ofE1ections40 Steuben Stret

Albany, NY 12207-2109

Re: Pedro ESDada. A39657 A30709

Dear Ms. Hogan:

Th you for the opportunity to meet with you and State Board of electionoffcials on Februar 26, 2009 to discuss my client's filing with your agency.

As we discussed it appears in regards to my client's most recent campaign for thestate senate, his treasurer inadvertently created a "PAC" committe when her intentionwas to create an authorized campaign committee.

Therefore, I am formally requesting permssion to withdraw the previous "PAC"filing and replace the same with a proper authonzed campaign committee nunc pro tuc.Thereafter we shal file each and every missing report to date.

Furter I am requesting that a hold be placed on these two accounts lltil we areable to address the issues relevant to the aforementioned error.

Thank you for your courtesy and attention to ths matter.

~:-:~~~ _.--_. .,....C~ L. Pagan

Cc: Hon. Pedro Espada Jr.

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Oo~ 03 2009 4: 49PM HP LASERJET FAX 9147884050 p.6

James A. WalhCo-Cha

....,.........~a? """tb"I~\I'ø\~~~N... ~

......,..

State of New YorkSTATE BOARD OF ELECTIONS

Oougi! A. KellnerCo-C

Gregory P.l'ODCoi:IOM 40 STEUBEN STRET

AUJANY, N.Y. 12207.211lPhone: 5181474-2063

ww.eJecon.sate.y.1l

Evel J. AquilCoiisiioner

Wll1 1. McCii, JJ'.Spc Depty Couel ~biith Co Hoaan

Enoremc Coii

March 31, 2009

LA W OFFCES OF DAN L. PAGAL'fODaniel L. Pagano, Esq.

2649 Strg Boulevar. Suite 104Yorktown Heights, NY 10598

Re: Pedro Espada, A39657 and A~709

Dear Mr. Pagano:

This is to acknowledge receipt of your letter of March 9, 2009, wherein you reference the abovenamed, As I understand your position, you are requesting that you be allowed to amend theregistration of A30709, Espada for the PeopJe, a registered PAC, to designate it an authorizedcommittee, and that it be allowed nunc pro tunc. Despite a letter from this Board upon the

registration of the PAC that such committee type was not appropriate ifthis commttee was intendedto conduct the busIness of the campaign, the committee type was not changed. You ar saying thatwas a mistake and you propose adelssing it at this time and in this maner.

Please be advised that I will contact you shorty to discuss the Espada commttees and the fiingissues surrounding them. This wil be a follow up to our meeting of Februar 26,2009.

Additionally. you request that A30709 and A39657, Pedro Espada Jr., açancldate record, be placedon adm ni strti ve hold while you address the outstanding issues relati ve to each. I wil do so as ofthi s date.

If you have any questions regarding this, feel fre to contrict me.

Very Truly Yours,

NEW YORK STATEB ARD OF ELECTON

ECHJdch

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EXHIBIT 17

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EXHIBIT 18

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THE LAW OFFICES OFRICHARD ST. PAUL, ESQ.

399 KNOLLWOOD RD. SUITE 301WHITE PLAINS, NEW YORK 10603

Of CounselRichard St. Paul, Esq. +*

+* Admitted in NY & DCTELEPHONE (914) 358-1380

FACSIMILE (914) 358-1381

September 21, 2009

VIA FACSIMILE 212-416-8068Attn: Darcy Goddard, Asst Attorney General

Re: Soundview Management Enterprises

Dear Ms Goddard:

Enclosed please find the following documents pursuant to the subpoena for documents.

· Soundview Management Enterprises Quarterly Federal Tax Return from January to June 2009.

Please be advised that a search of other documents relevant to the subpoena is on going and wil be providedexpeditiously upon receipt and review.

Thank you for your professionalism and courtesy.

Sincerely,

Richard St.Paul, Esquire

1