1. Lt, , | USDC SDNY he ad, i DOCUMENT Ves) § ELECTRONICALLY FILED Benrsiat © DOC #: State or New York DATE FILED: __ 4/7/2025 OFFICE OF THE ATTORNEY GENERAL LETITIA JAMES DIVISION OF CRIMINAL JUSTICE ATTORNEY GENERAL Mepicaip Fraup Contro □□□□ CIVIL ENFORCEMENT DIVISION April 4, 2025

The Honorable Valerie E. Caproni MEMO ENDORSED United States District Judge Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007

Re: United States, et al. ex rel. SCOIF v. Community Options, Inc., et al., 20 Civ. 4684 (VEC). Dear Judge Caproni:

The Office of the New York State Attorney General represents the State of New York (the “State”) in this matter, which has been settled and partially dismissed and unsealed as of March 26, 2025, following the execution of the Stipulation and Order Settlement and Dismissal between the State, Defendants, and Relator (ECF No. 21), and the Stipulation and Order of Settlement and Dismissal between the United States, Defendants, and Relator (ECF No. 19). We write on behalf of the State and the United States respectfully to request that the docketed versions of these Stipulations be replaced with versions containing limited redactions of protected health information contained in Exhibit A to both Stipulations, namely Medicaid beneficiary numbers, under the column labeled “Reference ID.” See

(b)(2)()(D) (requiring de-identification of protected health information including “(hjealth plan beneficiary numbers”); see also McCracken v. Verisma Sys., Inc., No. 14 Civ. 06248 (MAT),

, at *4 (W.D.N.Y. Sept. 26, 2017) (permitting exhibits containing protected health information to be filed under seal).

28 LIBERTY STREET, 13™! FLOOR, NEW YORK, NEW YORK 10005¢ PHONE (212) 417-5300 WWW.AG.NY.GOV

The Honorable Valerie E. Caproni April 4, 2025 Page 2 Annexed hereto are redacted versions of both Stipulations. We thank the Court for consideration of this request.

Respectfully, Tex Gerd Castheman- Smith Tiffany Castleman-Smith Special Assistant Attorney General 28 Liberty Street 13 Floor New York, New York 10005 (212) 417-5394 [email protected] Encls. CC: Brian McCormick, Esq. Counsel for the Relator DAVID E. FARBER Assistant United States Attorney 86 Chambers Street, 3rd Floor New York, NY 10007 Telephone: 212-637-2772 E-mail: [email protected]

Application GRANTED IN PART. The Stipulations and Orders of Settlement and Dismissal at Dkts. 19 and 21 shall remain under seal. The Clerk of Court is respectfully directed to unseal the Stipulation and Order of Settlement and Release at Dkt. 20. By Tuesday, April 8, 2025, the State of New York must file a revised version of the proposed redactions to the Stipulation and Order of Settlement and Dismissal at Dkt. 21. It appears that the redactions proposed at Dkt. 28-2, p. 28, were inadvertently applied to entries in the Service Date column. SO ORDERED. (ce 4/7/2025 Wie a HON. VALERIE CAPRONI UNITED STATES DISTRICT JUDGE