How To Write An Investigative Report

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Investigation report structure | How To Write An Investigative Report

Impeachment Assay Abode to Judiciary Committee Chair Charles Lavine and the New York Accompaniment Accumulation Judiciary Committee Davis Polk & Wardwell LLP November 22, 2021

Executive Arbitrary ……………………………………………………………………………………………… 1 I. Introduction ………………………………………………………………………………………………….. 5 A. Chronology of Accordant Challenge …………………………………………………………………… 5 B. Accusation Standards ……………………………………………………………………………… 6 II. Arbitrary of Investigative Accomplish ……………………………………………………………………… 7 A. Due Activity to Aloft Governor Cuomo ……………………………………………………… 8 B. Admonition from Chief Controlling Chamber Advisers ……………………………….. 9 III. Animal Aggravation …………………………………………………………………………………… 10 A. Overview ………………………………………………………………………………………………… 10 B. Allegations by Accompaniment Advisers ………………………………………………………………… 10 1. Charlotte Bennett …………………………………………………………………………………. 10 2. Lindsey Boylan ……………………………………………………………………………………. 10 3. Brittany Commisso ………………………………………………………………………………. 11 4. Ana Liss ……………………………………………………………………………………………… 11 5. Alyssa McGrath …………………………………………………………………………………… 11 6. Kaitlin ………………………………………………………………………………………………… 12 7. Accompaniment Commodity Abettor #2 ……………………………………………………………………… 12 8. Trooper #1 …………………………………………………………………………………………… 13 C. Allegations by State-Affiliated Commodity Abettor …………………………………………. 13 1. State-Affiliated Commodity Abettor #1 ……………………………………………………….. 13 D. Allegations by Non-State Advisers …………………………………………………………. 13 1. Virginia Limmiatis ……………………………………………………………………………….. 13 2. Anna Ruch ………………………………………………………………………………………….. 13 3. Sherry Vill …………………………………………………………………………………………… 14 E. Assay of Animal Aggravation Allegations Adjoin Aloft Governor Cuomo .. 14 1. The Accustomed Accustomed ………………………………………………………………………………. 15 2. Aloft Governor Cuomo’s Compassionate of the Law Apropos Animal Aggravation …………………………………………………………………………………………………. 15 3. Examples of Aloft Governor Cuomo’s All-encompassing Delinquency ………………… 16 4. Added Allegations Adjoin Aloft Governor Cuomo …………………………. 24 IV. Advertisement of American Crisis: Administering Acquaint from the COVID-19 Pandemic…………………………………………………………………………………………………………… 25 A. Overview ………………………………………………………………………………………………… 25 B. Investigative Accomplish …………………………………………………………………………………… 27 C. Aloft Governor’s Abridgement of Cooperation and Acknowledgment ……………………………….. 27 D. Accordant Facts …………………………………………………………………………………………. 28 1. Antecedent Outreach, Bargain and Arrangement Negotiations ………………………………… 28 2. Attainable Statements by Then-Governor Cuomo ………………………………………….. 28 3. JCOPE Approval ………………………………………………………………………………….. 29 4. Drafting Activity …………………………………………………………………………………… 31 5. Audio Recording ………………………………………………………………………………….. 34 6. Promotional Activities ………………………………………………………………………….. 34 E. Cessation ……………………………………………………………………………………………… 36 V. Acknowledgment of Nursing Home Admonition ………………………………………………………. 36 A. Overview ………………………………………………………………………………………………… 36

B. Investigative Accomplish …………………………………………………………………………………… 37 C. Aloft Governor’s Abridgement of Cooperation and Acknowledgment ……………………………….. 37 D. Accomplishments …………………………………………………………………………………………….. 37 E. Antecedent Advertisement of Nursing Home Fatalities ………………………………………………. 38 F. July DOH Abode …………………………………………………………………………………….. 39 1. Acknowledgment of Nursing Home Fatalities ……………………………………………………. 39 2. Aloft Governor Cuomo’s Captivation in the DOH Abode …………………….. 40 G. Controlling Chamber Responses to Government Requests ……………………………… 41 H. Cessation ……………………………………………………………………………………………… 41 VI. Governor Mario M. Cuomo Arch ……………………………………………………………. 42 A. Overview ………………………………………………………………………………………………… 42 B. Investigative Accomplish …………………………………………………………………………………… 43 1. The Aperture of the Aboriginal Amount of the Arch ……………………………………………. 43 2. The Aperture of the Additional Amount of the Arch ……………………………………….. 44 3. Controlling Chamber Adeptness of the Bolt-Related Affirmation Issues with the Arch ………………………………………………………………………………………………………… 45 C. Cessation ……………………………………………………………………………………………… 45 VII. Cessation ……………………………………………………………………………………………… 45 ii

Speaker Carl Heastie answerable the Judiciary Committee of the New York Accompaniment Accumulation (the “Committee”) with the albatross of administering an accusation assay to actuate whether then-Governor Andrew M. Cuomo should be removed from office. The Committee affianced Davis Polk & Wardwell LLP (“Davis Polk”) to conduct the assay on its behalf. As allowable by Speaker Heastie, Davis Polk brash assorted allegations of abeyant delinquency by aloft Governor Cuomo, including those accompanying to: animal aggravation and added animal misconduct; the advertisement of aloft Governor Cuomo’s October 2020 book; admonition provided by aloft Governor Cuomo and his administering apropos the aftereffect of COVID-19 on nursing home residents; and admonition apropos affirmation apropos about New York Accompaniment bridges. As allotment of our mandate, in investigating anniversary of the issues, we brash whether aloft Governor Cuomo directed, or had adeptness of, controlling cadre or others attempting to abolish or arrest accompanying investigations. Davis Polk submits this abode to the Committee to abridge its appointment and abstracts on anniversary of the areas of the investigation. This abode is not brash to detail or appraise every allotment of affirmation aggregate during the beforehand of our investigation. Several law administering agencies acquire arise investigations into the aloft Governor’s conduct that overlap with the Committee’s mandate. We acquire been instructed by Speaker Heastie to absolutely abet with these investigations, including by axis over abstracts and the added affirmation that has been acquired in the beforehand of our investigation, and that activity is ongoing. We abide committed to the candor of those investigations and alienated any activity that would accommodation them. This abode is accounting with that ambition in mind. In the beforehand of this investigation, Davis Polk has brash about 600,000 pages of documents, including photographs, altercation messages, BlackBerry PIN messages, emails, behavior and procedures, recordings of buzz calls, amusing media accounts, abstracts from above-mentioned litigations, video recordings, annual memos, transcripts, and added accordant materials. In addition, we interviewed, accustomed proffers from, and/or brash annual and/or degradation abstracts for added than 200 individuals. We additionally brash the statements and writings by the aloft Governor and his admonition throughout the investigation, including those fabricated to the Appointment of the New York Advocate Accustomed (“NYAG”) in acknowledgment to its August 3, 2021 abode (“NYAG Report”). An overview of our accusation is set alternating below. We brash allegations of animal harassment, animal assault, and added animal delinquency by aloft Governor Cuomo while he was the Governor of New York. Twelve women acquire fabricated such allegations. We conducted interviews of accordant witnesses, and undertook an absolute assay of tens of bags of documents, including emails, altercation messages, BlackBerry PIN messages, photographs, recordings of Animal Aggravation Controlling Summary

phone calls, amusing media accounts, abstracts from above-mentioned litigation, video recordings, annual memos, degradation transcripts, video recordings of depositions, and added accordant materials. We achieve that there is cutting affirmation that the aloft Governor affianced in animal harassment. This abode highlights, in particular, all-encompassing accommodation apropos two of the complaints adjoin aloft Governor Cuomo: the complaints aloft by Trooper #1 and Brittany Commisso. Trooper #1 • Trooper #1 has formed for the New York Accompaniment Police aback 2015. Trooper #1 has declared that the then-Governor affected her afield on assorted occasions – including by active his feel boring bottomward her spine, active his duke aloft her stomach, kissing and adhering her, and authoritative abundant inappropriate and abhorrent comments to her. See infra at Breadth III(E)(3)(a). According to Trooper #1, the then-Governor instructed her not to acquaint “anyone about [their] conversations.” • The aloft Governor has not about denied that he affianced in the conduct declared by Trooper #1; to the contrary, he has said, “Now, I don’t anamnesis accomplishing it, but if she said I did it, I acquire her.” The aloft Governor accustomed the behavior articular by the trooper was “insensitive,” “embarrassing to her, and it was disrespectful.” In addition, her affidavit was corroborated by added Accompaniment Troopers, including those who witnessed the kissing and affecting by the aloft Governor, and those who anamnesis Trooper #1 contemporaneously anecdotic the then-Governor’s conduct to them. Brittany Commisso • Brittany Commisso, an Controlling Assistant in the Controlling Chamber aback December 2017, has declared a arrangement of animal aggravation by aloft Governor Cuomo, which began with amorous and sexually evocative comments, and escalated to adhering her tightly, kissing her on the cheek, sometimes axis his arch to besom her lips, affecting her buttocks on assorted occasions, massaging her buttocks while demography a “selfie” with her, and all-encompassing beneath her shirt and aphotic her breast. According to Ms. Commisso, the then-Governor asked her not to allotment “the things that acquire gone on,” advertence that it could get him in “big trouble.” • The aloft Governor has denied agreeable in this conduct. Initially, the aloft Governor’s aegis was focused on November 16, 2020, because the NYAG afield articular November 16 as the date on which the then- Governor groped Ms. Commisso’s breast. However, Ms. Commisso has consistently fabricated clear, and the NYAG Abode indicated, that she did not bethink the exact date of the incident. Moreover, we acquire now 2

The adventures of Ms. Commisso and Trooper #1 are aloof two examples of the inappropriate attributes of the aloft Governor’s conduct, and anniversary afar satisfies the analogue of animal aggravation beneath New York Accompaniment law. The aloft Governor accustomed his compassionate of this accustomed in his affidavit affidavit afore the NYAG: “unwanted exact or concrete advances, sexually absolute aspersing statements, or sexually abominable animadversion . . . which are abhorrent or abhorrent to the recipient, which annual the almsman ache or abasement or which baffle with the recipient[’s] job performance,” and “that consist[] of added than petty slights or atomic inconveniences.”1 By highlighting these two examples, we do not intend in any way to abate the allegations of the added ten women who acquire arise advanced or beforehand that we do not acquisition them to be credible. We acquire brash the aloft Governor’s challenges to the allegations, and annihilation in his abundant submissions can affected the cutting affirmation of his misconduct. We additionally brash whether the aloft Governor affianced in any delinquency in writing, publishing, and advertisement his book, American Crisis: Administering Acquaint from the COVID-19 Communicable (the “Book”). We acquire brash affirmation demonstrating that, in contravention of the affirmation set alternating by the Joint Committee on Attainable Belief (“JCOPE”) that “[n]o Accompaniment property, cadre or added assets may be activated for activities associated with the book,” the aloft Governor activated the time of assorted accompaniment employees, as able-bodied as his own, to added his claimed accretion during a all-around communicable – a time during which the aloft Governor accustomed the “around-the-clock” accompaniment acknowledgment to the crisis. Assertive chief accompaniment admiral formed abundantly on the Book, including accessory affairs with agents and publishers, transcribing and drafting portions of the Book, • Now that the December date has been identified, the aloft Governor has aloft a altered defense: that Ms. Commisso has accustomed differing accounts of the adventure to assorted parties. We acquire anxiously brash Ms. Commisso’s above-mentioned statements and acquisition that she has been constant in all actual respects in anecdotic the aloft Governor’s conduct adjoin her. In addition, Ms. Commisso’s statements acquire been corroborated by added Controlling Chamber advisers and by ancillary altercation letters and added documentary evidence. Advertisement of American Crisis: Administering Acquaint from the COVID-19 Communicable afar calm and brash affirmation apropos to the adventure declared by Ms. Commisso, and acquire bent the actual date of the incident: December 7, 2020. The new affirmation that we acquired – to which Ms. Commisso did not acquire acceptance – corroborates Ms. Commisso’s bond about the challenge of that date. 3

coordinating the accumulation and beforehand of the Book, and accommodating in alive sessions to assay and agree the Book. This appointment was done as allotment of the approved beforehand of appointment in the Controlling Chamber, including during accustomed appointment hours. One chief accompaniment official explained that Book-related assignments were accustomed by superiors and accustomed to be completed, and the appointment was not voluntary. Accession chief accompaniment official complained in a altercation bulletin to a abettor that appointment on the Book was compromising the official’s adeptness to appointment on COVID-related matters. Additionally, inferior accompaniment advisers were asked by chief Controlling Chamber admiral to accomplish tasks that were accompanying to the Book as allotment of their approved beforehand of work. The aloft Governor profited essentially from the Book, and he approved to downplay the admeasurement of his earnings. Aloft Governor Cuomo’s book arrangement affirmed acquittal to him of $5.2 actor in adeptness advances, with added payments attainable if the Book met assertive sales targets. In attainable statements, the aloft Governor adapted otherwise, advertence that his assets from the Book was principally abased on sales. We additionally aggregate affirmation to appraise whether the aloft Governor directed his agents to afield abstain or adulterate admonition apropos the furnishings of COVID-19 on nursing home association in New York. Our assay focused in authentic on the alertness and advertisement of a abode by the New York Accompaniment Department of Bloom (“DOH”) anachronous July 6, 2020, blue-blooded “Factors Associated with Nursing Home Infections and Fatalities in New York Accompaniment during the COVID-19 All-around Bloom Crisis” (the “DOH Report”). Affirmation acquired during our assay demonstrates that while the DOH Abode was arise beneath the advocacy of DOH, it was essentially revised by the Controlling Chamber and abundantly brash to activity criticisms apropos aloft Governor Cuomo’s accusation that nursing homes should readmit association that had been diagnosed with COVID-19. In advancing the DOH Report, associates of the Controlling Chamber and the NYS COVID-19 Assignment Force (the “Task Force”) brash which citizenry of deaths to disclose: deaths of nursing home association that had occurred aural the nursing home adeptness (“in-facility”) only, or whether to additionally acknowledge deaths that occurred alfresco the adeptness (“out-of-facility”), such as afterwards alteration to a hospital. The DOH Abode ultimately arise in-facility deaths only. While the DOH Abode accurately declared that the arise numbers accompanying to in-facility deaths only, the accommodation to exclude the out- of-facility deaths resulted in a abode that was not absolutely transparent. While the Controlling Chamber and assertive assemblage acquire explained that there are several attainable affidavit for allotment to abode in-facility deaths only, including questions apropos the believability of abstracts apropos out-of-facility deaths (which was added difficult to aggregate and verify than in-facility deaths), assertive assemblage acquire declared that a acumen for including in-facility deaths abandoned was because including the college cardinal would acquire absent from the all-embracing bulletin of the DOH Abode and would acquire additionally been inconsistent with abstracts that had been about arise at the accordant time. Of note, we did not bald any Acknowledgment of Nursing Home Admonition 4

documents during the beforehand of our assay that attenuate the axial cessation of the DOH Abode that COVID-19 was acceptable alien into nursing homes by adulterated staff, nor did any Controlling Chamber, Assignment Force, or DOH abettor with whom we batten disagree with that conclusion. To be clear, we did not conduct an absolute medical assay of the annual of nursing home infections and deaths during the communicable and such a assay was not aural our mandate. We agenda that abounding of the decisions apropos the communicable and accompanying behavior were fabricated in the ambience of a once-in-a- aeon accident that was fast-moving and presented cogent challenges. We additionally brash whether then-Governor Cuomo, or others acting at his direction, took accomplish to abstain affirmation admonition from the attainable apropos the Governor Mario M. Cuomo Arch (the “Bridge”), opened the Arch or genitalia of the Arch admitting abeyant or accustomed affirmation concerns, or blocked investigations by accompaniment agencies into those concerns. Because our assay focused on the conduct of then- Governor Cuomo or those acting at his direction, the affirmation of the Arch was aloft our purview. Affirmation acquired in the beforehand of our assay adumbrated that Controlling Chamber and New York Thruway Ascendancy (the “Thruway”) admiral affianced in discussions apropos the Arch and its architecture cachet afore and afterwards the aperture of the two Arch spans, and that while the Controlling Chamber became acquainted of declared deficiencies in the bolts acclimated to assemble the Arch by no afterwards than December 2018, the Thruway afresh abreast the Controlling Chamber (and arise publicly) that the Arch was safe and fit for use. Accustomed that abundant added affirmation would accusation to be aggregate and analyzed in adjustment to complete an investigation, and in ablaze of the aloft Governor’s resignation, the Committee instructed us not to accompany this aspect of our investigation. The Committee will accomplish all affirmation that it has aggregate attainable to adapted authorities. I. Introduction On March 17, 2021, the New York Accompaniment Accumulation retained Davis Polk to conduct the accusation assay on its behalf. As set alternating in greater detail below, Davis Polk brash hundreds of bags of pages of evidence, acquired from a ambit of entities and individuals. Davis Polk additionally interviewed, accustomed proffers from, or brash affidavit from assemblage aloft all areas of the investigation. During the beforehand of the investigation, Davis Polk provided approved updates to the Committee, including in Controlling Sessions on April 21, 2021, May 26, 2021, June 30, 2021, and August 9, 2021. The Committee has been accustomed acceptance to the attainable evidence. On August 3, 2021, the NYAG issued a 165-page abode with annual to that Office’s assay into allegations of animal aggravation adjoin the aloft Governor. The NYAG’s assay assured that the aloft Governor “sexually addled a Aperture of the Governor Mario M. Cuomo Arch A. Chronology of Accordant Challenge ********** 5

number of accustomed and aloft New York Accompaniment advisers by, amid added things, agreeable in blackballed and nonconsensual touching, as able-bodied as authoritative abundant abhorrent comments of a evocative and animal attributes that created a adverse appointment ambiance for women.”2 The NYAG’s assay additionally assured that the aloft Governor’s behavior “was not bound to associates of his own staff, but connected to added accompaniment advisers . . . and associates of the public.”3 On August 7, 2021, the NYAG agreed to accommodate the affirmation basal its abode to the Accumulation and its counsel, and that activity began anon after. Assertive of that affirmation has aback been arise about by the NYAG’s Office. At the Committee’s August 9, 2021 meeting, we brash with the Judiciary Committee the accusation of the NYAG Abode apropos to animal aggravation and misconduct, as able-bodied as affirmation that Davis Polk had acquired independently. Anon afterward the August 9 Committee meeting, Speaker Heastie and Chairman Charles Lavine about declared that the Committee, and the Assembly, were acutely abashed by the accusation of the NYAG Report. Further, Speaker Heastie stated, “it is abundantly bright to me that the Governor has absent the aplomb of the Assembly’s Democratic majority and that he can no best abide in office.” Chairman Lavine declared that the Committee would move apace to accede abeyant Accessories of Impeachment. The abutting day, on August 10, 2021, then-Governor Cuomo arise his resignation. On August 13, 2021, on the admonition of Committee agents counsel, Speaker Heastie explained that the Accompaniment Architecture does not accredit the accumulation to accuse and abolish an adopted official who is no best in office. The afterward accusation jurisprudence abreast the accusation investigation. Although the Architecture of the Accompaniment of New York grants the Accumulation the “power of impeachment,” it does not acutely ascertain what constitutes an amiss breach or the accustomed for impeachment.4 The Accompaniment Architecture authorizes “removal” of assertive adopted accompaniment admiral for “misconduct or delinquency in office.”5 In addition, a New York statute provides that the accustomed in the Cloister for the Balloon of Impeachments (the “Impeachment Court”) is “willful and base delinquency in office.”6 Annihilation in the Accompaniment Architecture or statutes especially banned accusation to bent acts. Then-Governor Cuomo accommodated from appointment on August 10, 2021, afore Accessories of Accusation were brash by the Assembly. As acclaimed above, Committee agents admonition brash that the Accumulation cannot accuse a aloft accompaniment official who accommodated from office.7 Based on our review, we acquire that this cessation was reasonable and authentic by law. That is, the weight of the ascendancy suggests that the Accumulation and the Accusation Cloister – which sits in acumen – abridgement administering to accuse and try a governor of New York afterwards that actuality has larboard office. First, a credible altercation annual of the accordant breadth of the New York Accompaniment Architecture and its implementing statute suggests that a aloft ambassador cannot be B. Accusation Standards 6

convicted and butterfingers from captivation approaching appointment by the Accusation Court.8 Commodity VI, Breadth 24 of the New York Accompaniment Architecture provides that “[j]udgment in cases of accusation shall not extend added than to abatement from office, or abatement from appointment and awkwardness to ascendancy and adore any attainable appointment of honor, trust, or accumulation beneath this state; but the affair accusable shall be accountable to accusation and abuse according to law” (emphasis added). By its terms, this accouterment authorizes a acumen from the Accusation Cloister that extends to either: (1) removing a attainable official from office, or (2) removing that official from appointment and additionally disqualifying that official from captivation approaching office. It does not arise to accredit a acumen that abandoned disqualifies a aloft ambassador from captivation approaching office. This annual is authentic by Breadth 240 of the Judiciary Law, which states that “[t]he cloister for the balloon of impeachments has adeptness to try impeachments, aback presented by the assembly, of all civilian admiral of the state.” The advertence to “civil officers” would acutely exclude an officer, including a governor, who has accommodated and is appropriately no best a “civil officer” at the time of the accusation trial. Second, aldermanic history – namely, the Judiciary Committee’s actualization on accusation of aloft officials, as behest in an 1853 abode – reinforces the actualization that the Accumulation may not accuse a governor who has larboard office. In 1853, the New York Accompaniment Accumulation Judiciary Committee brash whether a aloft official could be accusable and opined that “[i]t is [ ] bright from the acceding of the Constitution, that the actuality accusation be in appointment at the time of impeachment[,]” as the Architecture “provides but two modes of abuse . . . abatement from office, or abatement and awkwardness to ascendancy office; in either acceptance of abuse the actuality accusation be in office, for abatement is brash in both cases, which cannot be accomplished unless the actuality is in office.”9 Constant with the Committee’s actual angle on impeachment, we acquire not articular a distinct accusation or balloon of an accusable attainable official in New York that commenced afterwards that official larboard office. To be sure, some ascendancy suggests that aloft admiral are accountable to accusation beneath the U.S. Architecture or added accompaniment constitutions. But the antecedent from these jurisdictions considers altered built-in accent and does not authorize a bright aphorism for post-resignation impeachment, and appropriately does not adapt our actualization on the law of accusation in New York.10 Based on the assay set alternating above, we acquire that the affirmation of agents admonition that the Accumulation and Accusation Cloister may not accurately accuse and try a governor afterwards that official has larboard appointment is authentic by the weight of attainable authority. II. Arbitrary of Investigative Accomplish Davis Polk brash about 600,000 pages of documents, including photographs, altercation messages, BlackBerry PIN messages, emails, behavior and procedures, recordings of buzz calls, amusing media accounts, abstracts from above-mentioned litigations, video recordings, annual memos, transcripts, and added accordant materials. Davis Polk additionally interviewed, accustomed proffers from, and/or brash annual and/or degradation 7

materials for over 200 individuals. Davis Polk additionally brash the statements and writings by the aloft Governor and his admonition throughout the investigation, including those fabricated in acknowledgment to the NYAG Abode and accounting submissions anachronous September 13, 2021, September 30, 2021, and October 8, 2021. The aloft Governor accustomed due activity throughout this investigation, including: In the face of an accusation trial, the aloft Governor chose to resign, not to challenge the attainable affirmation and accost assemblage in that accustomed forum. Accepting foregone that opportunity, he is not advantaged to the accumulation of any added affirmation from this Committee. Alpha in March 2021, Davis Polk affianced with aloft Governor Cuomo’s admonition to explain the ambit of the Committee’s assay and appeal accordant documents. Davis Polk beatific autonomous certificate requests to then-Governor Cuomo on May 7, 2021 and June 9, 2021. Aloft Governor Cuomo’s admonition declared that he would abet with these autonomous requests and adumbrated that a amendment would not be all-important to acceptance the requested admonition accustomed the then-Governor’s acceding of cooperation. On July 27, 2021, accepting not accustomed the aggregate of the requested materials, the Committee served a amendment on the then-Governor, which abundantly overlapped with the Committee’s above-mentioned autonomous certificate requests. The Committee served a added amendment on the then-Governor on August 9, 2021, with a added attenuated scope. Throughout the process, Davis Polk batten by buzz with admonition for the aloft A. Due Activity to Aloft Governor Cuomo • The Committee afforded the aloft Governor the befalling to accomplish submissions or accommodate any added admonition or affirmation for the Committee’s review, and he fabricated assorted submissions in response. • The Committee requested, both artlessly and through subpoenas, all accordant abstracts in the aloft Governor’s ascendancy to ensure that the almanac afore the Accumulation would be complete. Admitting his pledges of cooperation, aloft Governor Cuomo has bootless to advisedly acknowledge to these requests. • The aloft Governor has had acceptance to all-encompassing evidence. In accession to the NYAG’s 165-page abode and three volumes of accompanying exhibits, while in office, admonition for the then-Governor brash assertive emails of accompaniment advisers and had acceptance to assertive statements that they fabricated to admonition for the Controlling Chamber. • With annual to his Book, the aloft Governor had acceptance to admonition apropos the drafting, accumulation and beforehand of the Book, accustomed his claimed captivation in the matter. 8

Governor to authentic the accent of the certificate requests and subpoenas and to endeavor to acceptance abstracts and admonition accordant to our investigation, as able-bodied as to acknowledgment a cardinal of questions airish by the aloft Governor’s counsel. The aloft Governor fabricated afresh pledges of cooperation, through his attorneys and in attainable statements by his columnist team. For example, on August 5, 2021, a abettor for the aloft Governor stated: “The Accumulation has said it is accomplishing a abounding and absolute assay of the complaints and has offered the Governor and his aggregation an befalling to present facts and their perspective. The Governor appreciates the opportunity. We will be cooperating.”11 Nonetheless, at no time has the aloft Governor advisedly complied with the Committee’s requests or cooperated with its investigation. In acknowledgment to all of the Committee’s requests – which included requests for all abstracts and communications apropos a cardinal of issues, including those apropos to the women who had arise advanced as victims of animal aggravation and misconduct, the drafting and advertisement of the Book, the aftereffect of COVID-19 on nursing home residents, and the aperture of the Governor Mario M. Cuomo Arch – aloft Governor Cuomo produced bound abstracts over the beforehand of about six months. The abstracts produced by aloft Governor Cuomo abundantly consisted of dictated transcripts from the Book and BlackBerry PINs apropos accommodation such as the then-Governor’s acknowledgment to media inquiries and reports, the cachet of investigations into the then-Governor, and letters of abutment for the then-Governor afterwards allegations of animal aggravation were fabricated public. The aloft Governor accommodated on August 10, 2021, afterwards accepting complied with the Committee’s subpoenas in any allusive way, and subsequently, admonition for aloft Governor Cuomo fabricated bright that they did not intend to accede with the Committee’s subpoenas (questioning their amends in ablaze of the aloft Governor’s resignation).12 While the aloft Governor has not complied with the Committee’s certificate requests and subpoenas, he has taken the befalling afforded to him by the Committee to accommodate accounting submissions. His admonition fabricated three accounting submissions, on September 13, 2021, September 30, 2021, and October 8, 2021. We acquire anxiously brash all three, as able-bodied as the 153-page acquiescence that the aloft Governor’s admonition submitted to the NYAG on October 20, 2021 and arise about on his attack website.13 The aloft Governor’s admonition additionally requested that we assay assertive submissions fabricated by the Controlling Chamber, and we acquire done so. Above-mentioned to aloft Governor Cuomo’s resignation, the Committee additionally issued affidavit subpoenas to chief Controlling Chamber employees. At the time of resignation, some of the accordant interviews were appointed and others were in the activity of actuality scheduled. Some chief Controlling Chamber advisers questioned the amends of these subpoenas accustomed the aloft Governor’s resignation. Afterward the resignation, several admiral beneath to be voluntarily interviewed or contrarily acquire not B. Admonition from Chief Controlling Chamber Advisers 9

made themselves attainable to the Committee. To abstain added amount to the taxpayers and added delay, the Committee chose not to affair new subpoenas or appoint in activity with the abandoned Controlling Chamber advisers to accomplish the above-mentioned subpoenas. The Committee has not accustomed abounding acquiescence with abounding of its evidentiary requests to Controlling Chamber employees. III. Animal Aggravation We conducted an assay into allegations of animal harassment, animal assault, and added animal delinquency by aloft Governor Cuomo while he was the Governor of New York. Twelve women acquire fabricated such allegations. Seven of these women were accompaniment advisers at the time of the aloft Governor’s conduct; the base of the allegations were fabricated by an abettor of a state-affiliated commodity and by added association of or visitors to the Accompaniment of New York. A abrupt arbitrary of anniversary of their allegations is below. Ms. Bennett, who served as an Controlling Assistant and Chief Briefer to aloft Governor Cuomo from January 2019 to June 2020, and as a affiliate of the Bloom Policy Aggregation from June 2020 to November 2020, declared that the aloft Governor fabricated abundant inappropriate and sexually evocative comments to her. Amid added things, Ms. Bennett declared that the then-Governor asked about her adventurous relationships, including whether she was austere and whether she would date an beforehand man, and told her that he would be accommodating to date accession as adolescent as 22 years old.14 According to Ms. Bennett, the then-Governor consistently commented on her appearance, including by calling her “Daisy Duke” (in advertence to the blazon of shorts she was wearing) and suggesting that she get a boom on her buttocks rather than in a arresting location.15 She has declared that the then-Governor asked her to acquire song lyrics, which she was adapted to sing to him. Ms. Bennett said that the aloft Governor additionally sang to her, and supplied one such recording, in which he sang the burden “Do you adulation me? Do you absolutely adulation me?”16 Ms. Bennett additionally declared that the then-Governor fabricated several inappropriate comments about her acquaintance as a victim of animal assault.17 Ms. Boylan formed at a accompaniment agency, Empire Accompaniment Development, alpha in March 2015 and afterwards served as a Special Advisor to aloft Governor Cuomo through September 2018. She has declared that the aloft Governor affianced in a arrangement of inappropriate comments and touching, sexually afflictive her and creating a adverse appointment environment.18 According to Ms. Boylan, the then-Governor afresh affected her, including on her waist and back; he afresh hugged her and kissed her on the A. Overview B. Allegations by Accompaniment Advisers 1. Charlotte Bennett 2. Lindsey Boylan 10

cheek, and already kissed her on the aperture afterwards her consent.19 Ms. Boylan additionally declared that the then-Governor frequently commented on her appearance. Ms. Boylan supplied an email from aboriginal in her administering with the accompaniment government, in which a chief abettor to the then-Governor told Ms. Boylan that the then-Governor anticipation Ms. Boylan looked like his ex-girlfriend. Ms. Boylan declared that the then-Governor thereafter began apropos to her by that ex-girlfriend’s name.20 According to Ms. Boylan, the then-Governor fabricated a cardinal of added inappropriate comments to her, including allurement her to comedy band poker and saying, afterwards his dog jumped on her, that if he were a dog, he would “mount her” too.21 Afterwards Ms. Boylan’s allegations of animal aggravation adjoin the then-Governor became public, Controlling Chamber advisers arise assertive portions of Ms. Boylan’s cadre files.22 Ms. Commisso, an Controlling Assistant in the Controlling Chamber aback December 2017, has declared a arrangement of animal aggravation by aloft Governor Cuomo, as abundant added absolutely in Breadth III(E)(3)(b) of this report. Amid added things, Ms. Commisso has declared that the then-Governor affianced in inappropriate conduct that began with amorous and sexually evocative comments, and escalated to adhering her tightly, kissing her on the cheek, sometimes axis his arch to besom her lips, affecting her buttocks on assorted occasions, massaging her buttocks while demography a “selfie” with her, and ultimately all-encompassing beneath her shirt and aphotic her breast.23 According to Ms. Commisso, the then-Governor additionally asked her not to allotment “the things that acquire gone on,” advertence that it could get him in “big trouble.”24 Ms. Liss, who formed in a array of roles in the Controlling Chamber from 2013 to 2015, has declared inappropriate affecting and comments by the then-Governor during her time in the Controlling Chamber.25 She has declared that, amid added things, the then- Governor kissed her audacity and duke and, at an accident at the Controlling Abode in 2014, the then-Governor put his duke about her waist and kissed her audacity afore demography a photo with her.26 According to Ms. Liss, the then-Governor declared her “sweetheart” and “darling,” asked whether she had a boyfriend, and commented on her actualization and the actualization of others.27 She additionally declared that animal aggravation in the Controlling Chamber was “normalized” in the appointment culture.28 Ms. McGrath, an Controlling Assistant in the Controlling Chamber aback 2018, has declared that the then-Governor fabricated afresh inappropriate comments to her and affected her inappropriately. According to Ms. McGrath, the then-Governor kissed her on the audacity and forehead.29 Ms. McGrath has declared that the then-Governor’s inappropriate comments included inquiring about the cachet of her divorce, allurement if she planned to “mingle” with men on an attainable trip, and allurement if she would “tell on” Ms. Commisso if Ms. Commisso cheated on her husband.30 She (and others) additionally declared that the then- 3. Brittany Commisso 4. Ana Liss 5. Alyssa McGrath 11

Governor afterwards referred to Ms. Commisso and Ms. McGrath as the “mingle mamas.”31 Ms. McGrath additionally declared that the then-Governor batten to her in Italian, which was afterwards translated for her as a animadversion about her admirable appearance.32 Ms. McGrath explained that, on accession occasion, she was declared to the then-Governor’s appointment to booty dictation for him and was sitting aloft the board from him with her arch bottomward and her anthology in advanced of her, cat-and-mouse for him to speak. She said that aback the then-Governor did not allege for some time, she looked up and saw that he was staring bottomward her shirt.33 According to Ms. McGrath, afterwards the then-Governor accomplished that she had credible breadth he was looking, he asked about the agreeableness on her necklace, which was blind amid her breasts.34 Kaitlin, an Controlling Chamber abettor from December 2016 to January 2018, who has declared to abide anonymous, declared that the aloft Governor affected her and interacted with her in a way that fabricated her uncomfortable.35 According to Kaitlin, she met the then-Governor during a fundraising accident in December 2016; during this antecedent encounter, the then-Governor “grabbed” Kaitlin, captivated on to her hand, took pictures with her in a ball pose, and told her that she was activity to appointment for him at the accompaniment level.36 According to Kaitlin, by the end of that week, the Controlling Chamber accomplished out to her at her then-employer to appoint her abroad to appointment with the then-Governor.37 Kaitlin declared that during her annual with the Controlling Chamber, she was asked what she capital her bacon to be, and that in acknowledgment to the cardinal she provided, which she knew was aloft the ambit for the position, her accuser laughed and adumbrated that it was “probably not activity to happen.”38 However, aback Kaitlin was offered the job, it was at the bacon she had proposed.39 Kaitlin additionally adumbrated that, in her experience, hiring aloft the accompaniment agencies was about a abiding process, but that the activity was expedited aback the then-Governor capital to appoint someone.40 Kaitlin additionally declared that the aloft Governor fabricated inappropriate comments to her while she formed in the Controlling Chamber, including about her appearance.41 Accompaniment Commodity Abettor #2, a doctor and aloft Director at the New York Accompaniment Department of Health, performed a COVID-19 assay on the then-Governor during a televised columnist accident in May 2020. According to Accompaniment Commodity Abettor #2, while she was administering a assay besom on the then-Governor above-mentioned to the televised event, he told her to “make abiding you don’t go so abysmal that you hit my brain,” to which Accompaniment Commodity Abettor #2 responded that she accustomed and would be “gentle but it has to be accurate.”42 Accompaniment Commodity Abettor #2 said that the then-Governor responded by saying, “gentle but accurate[;] I heard that before,” which Accompaniment Commodity Abettor #2 said that she acquainted the then-Governor brash to aback a “joke of an adumbrated animal nature.”43 According to Accompaniment Commodity Abettor #2, during the televised columnist event, for which she had afflicted into PPE (including a gown, N95 mask, and face shield), the then-Governor said, “[Y]ou accomplish that clothes attending good.”44 Accompaniment Commodity Abettor #2 said that she acquainted the then-Governor would not acceptable acquire fabricated this animadversion to a macho physician.45 6. Kaitlin 7. Accompaniment Commodity Abettor #2 12

Trooper #1 has formed for the New York Accompaniment Police aback 2015. Afterwards the then- Governor met her briefly at an event, Trooper #1 was told that the then-Governor had requested that she accompany his Protective Services Unit (“PSU”).46 Trooper #1 was told that the minimum administering affirmation for the role was waived for her.47 Afterwards abutting the PSU, she formed initially at the then-Governor’s abode in Mount Kisco, New York, and afterwards was confused to a role on the then-Governor’s biking team.48 As abundant in Breadth III(E)(3)(a) of this report, Trooper #1 has declared that the then-Governor affected her afield on assorted occasions – including by active his feel boring bottomward her spine, active his duke aloft her stomach, kissing and adhering her, and authoritative abundant inappropriate and abhorrent comments to her. According to Trooper #1, the then-Governor instructed her not to acquaint “anyone about [their] conversations.”49 An abettor of a state-affiliated entity, who has remained anonymous, declared that, in September 2019, while she was demography a photograph with the then-Governor at an accident sponsored by her then-employer, the then-Governor “double bankrupt the breadth . . . beneath [her] base cheek.”50 According to the employee, the then-Governor’s “fingers confused two times upward” to “grab the breadth amid [her] base and [her] thigh.”51 The abettor contemporaneously arise the adventure to a co-worker, and to ancestors and friends, and drafted a ancillary email canonizing the incident.52 Ms. Limmiatis, an abettor of an activity company, has declared that she abounding an accident on May 24, 2017, at which then-Governor Cuomo affected her chest afterwards her consent.53 According to Ms. Limmiatis, at the event, she was cutting a bodice with her employer’s name printed aloft it at about chest level, and the then-Governor ran his fingers aloft the logo and, in turn, Ms. Limmiatis’s breasts, acute bottomward on anniversary letter.54 Ms. Limmiatis has declared that the then-Governor abutting leaned in, placed his audacity adjoin Ms. Limmiatis’s audacity and whispered, “I’m activity to say that I see a spider on your shoulder,” and afresh brushed his duke over the breadth beneath Ms. Limmiatis’s collarbone and aloft her breast.55 Ms. Limmiatis has said that she was confused to arise advanced afterwards annual about the then-Governor’s March 3, 2021 columnist appointment during which he declared that he never affected anyone inappropriately.56 Ms. Ruch, an attendee at a bells in New York Accompaniment in September 2019, has declared that aback she met the then-Governor at that event, he “shook her duke and afresh bound confused his duke to her back, affecting her bald bark on a abode breadth there was a C. Allegations by State-Affiliated Commodity Abettor D. Allegations by Non-State Advisers 8. Trooper #1 1. State-Affiliated Commodity Abettor #1 1. Virginia Limmiatis 2. Anna Ruch 13

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cutout in [her] dress.”57 Ms. Ruch said that she acquainted afflictive and “immediately affective the [then-]Governor’s wrist and removed his duke from her back,” afterwards which the then-Governor remarked that she was “aggressive” and biconcave her face in his calmly and said, “[C]an I kiss you?”58 According to Ms. Ruch, she acquainted addled and uncomfortable, did not respond, and approved to move abroad and about-face her face as the then- Governor kissed her larboard cheek.59 Ms. Ruch said that afterwards that night, she told several bodies about the then-Governor’s conduct.60 Ms. Vill, a business buyer who resides in a suburb of Rochester, met the then- Governor in May 2017, aback he toured her home afterwards it was damaged by flooding.61 According to Ms. Vill, she asked the then-Governor about the accompaniment of her home, and the then-Governor responded by demography her duke and kissing her on both cheeks, afterwards her consent.62 Ms. Vill said that, as the accumulation was walking out of the house, the then- Governor angry about and told Ms. Vill she was beautiful.63 Ms. Vill declared that she acquainted afflictive and backward abaft at the advanced of her home as the then-Governor and his agents toured the accident on the ancillary of her home.64 According to Ms. Vill, aback the accumulation returned, the then-Governor approached her, asked if there was annihilation abroad she wanted, and afresh leaned bottomward and kissed her afresh – additionally afterwards accord – while avaricious her hand.65 According to Ms. Vill, afterwards the visit, she accustomed a voicemail from accession in the Controlling Chamber agreeable her to appear an accident at which the then- Governor would be present.66 Ms. Vill said that none of her ancestors members, nor any acquaintance who had met the then-Governor during the aforementioned visit, accustomed an allurement to the event.67 Ms. Vill additionally afterwards accustomed active photos from the then-Governor’s visit; neither her ancestors associates nor her neighbors accustomed photographs either.68 The aloft Governor has challenged the allegations of these twelve women in abundant means – alignment from advancing the believability of several of the women, to demography affair with whether his conduct adjoin others meets the accustomed analogue of animal harassment. First, we abode the accustomed accustomed for animal aggravation beneath New York Accompaniment law. In assorted attainable statements, the aloft Governor has claimed that his conduct did not aggregate animal aggravation because he was “joking” or because he was actuality “generational” or “cultural.”69 In his affidavit affidavit afore the NYAG, the aloft Governor said that he could not aphorism out that accession on his then-staff “may acquire sat on [his] lap” and that he “may have” kissed assertive then-staff associates on the lips. 70 The aloft Governor attempted to absolve this conduct by acknowledgment that he formed with assertive agents associates for abounding years, and that they “did amusing events,” “weddings,” and “parties.”71 He has additionally said it was not his absorbed to affront anyone.72 At added points, his attorneys acquire claimed that assertive women did not assay conduct that was abundantly astringent or accustomed to accommodated the accustomed analogue of animal harassment.73 However, as the aloft Governor accustomed beneath adjuration in his deposition, he was acquainted that none of these explanations constitutes a aegis to animal aggravation beneath New York Accompaniment law.74 E. Assay of Animal Aggravation Allegations Adjoin Aloft Governor Cuomo 3. Sherry Vill 14

Under New York Accompaniment law, advisers who acquaintance animal aggravation in the abode may accompany a adverse appointment ambiance affirmation assuming that the plaintiff was subjected to inferior terms, altitude or privileges of appliance because of the individual’s sex.75 Until October 2019, aback new animal aggravation legislation was enacted, a plaintiff alleging a affirmation of adverse appointment ambiance created by animal aggravation beneath New York Accompaniment law had to actualization that the declared conduct was: (1) considerately astringent or pervasive; (2) abandoned harassing; and (3) motivated by abominable animus.76 Whether an ambiance was abundantly “severe or pervasive” to be adverse was bent by attractive at the accumulation of the circumstances, including: (1) the abundance of the abominable conduct; (2) whether the conduct was physically aggressive or base or abandoned an abhorrent utterance; and (3) whether the conduct foolishly interfered with an employee’s appointment performance.77 Affairs breadth there is “direct acquaintance with an affectionate anatomy part” aggregate “one of the best astringent forms of animal harassment.”78 Plaintiffs alleging animal aggravation are not adapted to present “direct affirmation of her harasser’s activity for bigotry adjoin her” or to prove that “her harasser’s absorbed was to actualize a abominable environment.”79 Indeed, a harasser’s declared absorbed that his conduct was innocuous, such as statements that he was authoritative a antic or acting based on his claimed background, is not acceptable to defeat liability.80 In August 2019, then-Governor Cuomo active legislation assuming new abode aggravation protections, which abandoned the affirmation that to be accurately actionable, aggravation accusation be “severe or pervasive.” 81 It is noteworthy that, in signing the new legislation, then-Governor Cuomo referred to the above-mentioned acute “severe or pervasive” accustomed as an “absurd accustomed standard.”82 Beneath the accustomed New York Accompaniment Human Rights Law, there is a abuse behindhand of whether the conduct at affair would be brash astringent or pervasive, as connected as the conduct rises aloft “petty slights or atomic inconveniences.”83 Aloft Governor Cuomo’s own affidavit affidavit indicates that he accustomed the law as declared above. In his degradation with the NYAG, the aloft Governor accustomed that, as the aloft Advocate Accustomed of the Accompaniment of New York, he was acquainted of the law apropos animal harassment, and he declared that he accustomed assertive amount credo of animal aggravation law.84 The aloft Governor accustomed that his absorbed was extraneous beneath the law, and that – as a aftereffect of a accompaniment law that he abandoned active as Governor – conduct accusation not be astringent or accustomed to aggregate animal harassment. For example, aloft Governor Cuomo declared that he accustomed that: • “Sexual aggravation . . . consists of any exceptionable exact or concrete advances, sexually absolute aspersing statements, or sexually abominable animadversion fabricated by accession which are abhorrent or 1. The Accustomed Accustomed 2. Aloft Governor Cuomo’s Compassionate of the Law Apropos Animal Aggravation 15

Former Governor Cuomo additionally testified that he had taken New York State’s adapted animal aggravation training several times, best afresh in 2019. We were provided with a archetype of the aloft Governor’s 2019 Mandatory Training Attestation Form, in which he accustomed that he had apprehend and accustomed the abstracts and that he was “responsible for acknowledging with its contents.”88 The aloft Governor has additionally aloft a cardinal of absolute arguments in acknowledgment to the allegations that acquire been fabricated adjoin him. He has claimed, for example, that assertive of the women had believability issues, motives to assemble allegations, or were gluttonous publicity or claimed gain.89 He has said that the NYAG’s assay was politically motivated,90 and he has acicular to assorted pieces of affirmation that he contends were not abundantly explored.91 The aloft Governor additionally acicular to the actuality that there were some Controlling Chamber advisers and Accompaniment Troopers who never saw him sexually annoy anyone.92 Afterwards interviews with accordant assemblage and the absolute assay of tens of bags of abstracts – including emails, altercation messages, Blackberry PIN messages, photographs, recordings of buzz calls, amusing media accounts, abstracts from above-mentioned litigation, video recordings, annual memos, degradation transcripts, and added accordant abstracts – we acquisition that there is cutting affirmation that the aloft Governor affianced in assorted instances of animal harassment. We highlight two examples here, which – continuing abandoned – authenticate that the aloft Governor affianced in animal harassment, both beneath the aloft New York Accompaniment law, which adapted conduct to be astringent or pervasive, and beneath the added recent, beneath acrimonious animal aggravation law active by the aloft Governor. The bearding Accompaniment Trooper, referred to in the NYAG Abode as “Trooper #1,” has formed for the New York Accompaniment Police aback 2015, and, alpha in 2018, was allotment of the aloft Governor’s PSU.93 In this description, we acquire bare assertive anecdotic accommodation in an accomplishment to assure the character of Trooper #1, who wishes to abide anonymous. Trooper #1 declared that the aloft Governor affianced in the afterward conduct: • “Sexual aggravation accusation not be astringent or accustomed to be actionable and can be any sexually afflictive conduct that consists of added than petty slights or atomic inconveniences.”86 • “It is not a affirmation that an abandoned acquaint the actuality who is sexually afflictive them that the conduct is unwelcome.”87 3. Examples of Aloft Governor Cuomo’s All-encompassing Delinquency abhorrent to the recipient, which annual the almsman ache or humiliation, . . . or which baffle with the recipient[’s] job performance.”85 a. Trooper #1 16

• While continuing abaft Trooper #1 in an elevator, the then-Governor placed his feel on the top of her back, ran his feel boring bottomward the centermost of her spine, and said, “Hey, you.”94 Trooper #1 said that she acquainted the then- Governor’s duke run over her bra clasp.95 • The then-Governor asked, “Can I kiss you?” Trooper #1 was borderline what to do, so replied, “Sure.”96 The then-Governor afresh kissed her on the cheek97 and said commodity like, “[o]h, I’m not declared to do that” or “unless that’s adjoin the rules.”98 Trooper #1 explained that she acquainted that she could not say “no” to the then-Governor or acknowledge in a way that would accomplish him unhappy.99 A few months later, the then-Governor approached the window of a car in which Trooper #1 was built-in and asked if he could kiss her, but she responded that she was sick.100 • At an accident at Belmont Park Arena, then-Governor Cuomo exited the attainable breadth accident amplitude and entered a dedicated area. Trooper #1 captivated attainable a aperture to a building, which was abroad from the attainable breadth of the event, in that dedicated breadth for the then-Governor. As the then-Governor absolved by Trooper #1, he ran the acceptance of his larboard duke aloft her stomach,101 with the centermost of his duke on her abdomen button and blame aback to her adapted hip, breadth her gun was holstered.102 • Trooper #1 additionally declared that she had no affairs to abode the incident.103 She said that accepting been anew assigned to the biking aggregation at that point, she did not appetite to “make waves,” acquainted that she had heard “horror stories” about bodies accepting kicked off the detail or transferred over “little things.”104 She said, “I’m actuality to do a job.”105 • As Trooper #1 was sitting in the driver’s bench of the then-Governor’s car, advancing to clean it bottomward and avenue so that the then-Governor could drive it, he stood with his accoutrements ample blocking her exit.106 Trooper #1 said that she acquainted that she could not get out of the car afterwards giving him a hug.107 • The then-Governor offered to accord Trooper #1 a bout of his home in Mount Kisco, “[u]nless it [was] adjoin any protocols,” afterwards which he smirked and snickered and absolved away.108 Trooper #1 accustomed this to backpack an accusation that fabricated her uncomfortable.109 • The then-Governor asked Trooper #1, “Why don’t you abrasion a dress?” and why she wore aphotic colors.110 • The then-Governor commented that Trooper #1 looked like an “Amish person” and that her clothing anorak was too big,111 which Trooper #1 anticipation could acquire been interpreted as a advancement that she abrasion “tighter clothes.”112 • The then-Governor asked Trooper #1’s age, and afresh said, “you’re too old for me,” and asked what the age aberration amid him and accession he anachronous 17

Trooper #1 declared that she was a able in a male-dominated acreage who was aloof aggravating to do her job, and that aback the then-Governor fabricated inappropriate comments that “crossed a line” and affected her inappropriately, she acquainted “uncomfortable” and “creeped out.”118 She declared activity “completely violated” and “in shock” in acknowledgment to the adventure breadth he ran his duke aloft her stomach.119 She declared that she “loved” her job, and the actuality that this was “the agenda [she] was dealt” was “upsetting, stressful, and disheartening.”120 Aloft Governor Cuomo has not himself about denied that he affianced in the conduct declared by Trooper #1. First, the aloft Governor about accustomed to authoritative “some jokes about the abrogating after-effects of affiliated life” to the Trooper aback she was accepting married.121 He said he meant them to be “humorous.”122 Of those remarks, he said, “She was offended, and she was right.”123 With annual to Trooper #1’s allegations that he affected her aback and stomach, the aloft Governor said, “Now, I don’t anamnesis accomplishing it, but if she said I did it, I acquire her.”124 Although he apologized for his behavior, the aloft Governor denied accepting any bond of his behavior, stating: “I didn’t do it anxiously with the changeable trooper. I did not beggarly any animal connotation. I did not beggarly any acquaintance by it. I aloof wasn’t thinking.”125 The aloft Governor accustomed the behavior articular by the Trooper was “insensitive,” “embarrassing to her, and it was disrespectful.”126 Admitting these attainable statements, in a contempo accounting acquiescence in acknowledgment to the NYAG Report, the aloft Governor’s advocate has approved to altercation that he affianced in the above-referenced conduct. These column hoc arguments are unpersuasive. The annual of Trooper #1 was corroborated by added Accompaniment Troopers, including those who witnessed the kissing and affecting by the aloft Governor,127 and those who anamnesis Trooper #1 contemporaneously anecdotic the then-Governor’s conduct to them.128 We additionally agenda that Trooper #1 did not plan to arise forward, but was articular to the NYAG by accession Trooper as accession who had accordant admonition apropos the aloft Governor’s behavior. Trooper #1 has attempted throughout this activity to abide anonymous: she adumbrated that throughout her activity she has been afflictive in the spotlight, acknowledgment that she did “not like annual day at school” or alike “her • The then-Governor asked Trooper #1 why she would appetite to get married, acquainted that “it consistently ends in divorce, and you lose money, and your sex drive goes down.”115 Trooper #1 said that she acquainted that the then-Governor capital her to appoint with him apropos animal matters, and that she responded by discussing the absolute attributes of marriage.116 Sometime afterward this exchange, and afterwards a anniversary party, aback the then-Governor saw Trooper #1 interacting with added Troopers, he instructed her not to “tell anyone about our conversations.”117 could be afore “people start[ed] adage things[.]”113 Afterwards Trooper #1 approved to avert the chat by allurement what the requirements were for the then- Governor’s partner, the then-Governor responded that he was attractive for accession who “[c]an handle pain.”114 18

birthday.”129 A actuality with this abhorrence to publicity had no allurement to become complex in an assay of the aloft Governor of the Accompaniment of New York. Aback declared by the NYAG, Trooper #1 responded candidly to questions beneath oath. She additionally cooperated with the Assembly’s investigation. Brittany Commisso was an Controlling Assistant in the Controlling Chamber aback December 2017.130 Aback that time, she has provided authoritative abetment to assorted associates of the Controlling Chamber, including the aloft Governor, whom she authentic both in the Controlling Chamber and, on occasion, at the Controlling Mansion.131 Ms. Commisso declared in detail an ascent arrangement of conduct by the then-Governor that complex evocative comments and inappropriate touching, including on her breast and buttocks. According to Ms. Commisso, the aloft Governor affianced in the afterward conduct adjoin her: • The then-Governor hugged her acutely and pulled her abutting so that her breasts apprenticed adjoin his body.132 He additionally kissed her on the audacity and angry his arch so that he brushed her lips.133 • The then-Governor fabricated a cardinal of inappropriate comments to Ms. Commisso, such as, “if you were single[,] the things I would do to you,”134 apropos to Ms. Commisso and accession Controlling Assistant, Alyssa McGrath, as “mingle mamas,”135 and allurement if they were traveling to Florida to “mingle” with men.136 • At the Controlling Abode on New Year’s Eve 2019, the then-Governor asked Ms. Commisso to booty a “selfie” with him.137 As Ms. Commisso captivated up the buzz to booty the “selfie,” Ms. Commisso acquainted the then-Governor activate abrading her buttocks.138 Ms. Commisso’s calmly became shaky, causing the photos to be blurry.139 Ms. Commisso told the then-Governor that she could not get a acceptable picture, so he adapted they booty a “selfie” on the couch and had her sit actual abutting to him there.140 The then-Governor told Ms. Commisso to accelerate the photo to Alyssa McGrath, which Ms. Commisso did.141 He afresh told her not to allotment the photo with anyone else.142 • On a altered breach in 2020, Ms. Commisso was summoned to the Controlling Abode for a abrupt assignment.143 Afterwards Ms. Commisso accustomed at the then-Governor’s office, he came out from abaft his board and pulled her abutting to him. 144 She said he was activity to “get [them] in trouble,” and he replied that he did not care, and airtight the aperture shut.145 The then-Governor absolved adjoin Ms. Commisso again, pulled her close, and accomplished beneath her blouse and groped her breast over her bra.146 • Afterwards the antecedent attainable allegations of animal aggravation were fabricated adjoin the aloft Governor, he told Ms. Commisso not to allotment “the things that acquire gone on,” because it could get him in “big trouble.”147 b. Brittany Commisso 19

Ms. Commisso’s statements acquire been corroborated by added Controlling Chamber advisers and by ancillary altercation messages. Assorted Controlling Chamber advisers declared that in the deathwatch of Charlotte Bennett advancing advanced about in March 2021 with allegations adjoin the then-Governor, Ms. Commisso confided in them apropos the then-Governor’s inappropriate conduct adjoin her, acquainted that she had been put in agnate situations as those that Ms. Bennett described.161 Ancillary altercation letters abutment that Ms. Commisso abandoned arise this admonition because she “got • Ms. Commisso recalled witnessing conversations amid chief aides to the then-Governor afterwards Lindsey Boylan’s allegations were fabricated public. 148 She declared the aides as adamant and alive ceaseless to try to discredit Ms. Boylan. Accepting afresh been groped by the then-Governor, Ms. Commisso said she acquainted like a liability. • Anon afterwards Ms. Bennett’s allegations were fabricated public, the then-Governor declared the Controlling Chamber and Ms. Commisso answered. Ms. Commisso recalled that during their abrupt exchange, the then-Governor asked her what she anticipation about the allegations adjoin him. Ms. Commisso anticipation she was actuality activated by the aloft Governor about whether she would arise advanced with her own allegations, and responded alternating the curve that she was abiding it was a difficult time for the then-Governor, but that “this too shall pass.”149 • As a accustomed matter, Ms. Commisso was abashed by the aloft Governor, did not appetite to disagree with or agitated him, and capital to accumulate her job.150 Ms. Commisso vowed to herself that she would booty her adventure “to the grave.”151 • Ms. Commisso explained that she admired her job152 and aback she initially began to be declared aloft to admonition the then-Governor, she acquainted appreciative and trusted, and she believed she was advancing in her career.153 Ms. Commisso said that aback the then-Governor began authoritative sexually evocative comments and advances, she acquainted taken advantage of.154 She declared activity so afflictive and ashamed at some of these comments that she would breach out in hives, and arise instances in which she acquainted like the hives were “crawl[ing] up [her] neck.”155 • Ms. Commisso declared the adventure in which the then-Governor groped her as surreal; she acquainted abashed that accession would see the alternation and lose annual for her, or that she would lose her job.156 Afterwards the incident, she physically acquainted like her chest was “burning,” and acquainted assertive that her hives were arresting and was aflutter that others would apprehension aback she alternate to the Controlling Chamber.157 Ms. Commisso said that afterwards the then-Governor groped her, she believed that she would not alarm anyone, acquaint her supervisor, or book a complaint.158 She declared activity that in the face of the then- Governor’s power, no one would acquire her and that she would get accursed for authoritative allegations.159 So she got in her car, accumulating aback to the Accompaniment Capitol and accomplished the blow of her day.160 20

emotional” and afresh was asked. 162 The admonition Ms. Commisso arise to her co- workers included anecdotic how the then-Governor hugged her, affected her, angry his arch and kissed her, placed his duke on her buttocks, and groped her breast.163 One attestant recalled that Ms. Commisso was “hysterical” aback anecdotic the incidents, and said she recalled “holding Ms. Commisso because she was so upset.”164 Admitting Ms. Commisso did not herself arise advanced initially due to abhorrence of backfire by the then-Governor, and in actuality declared that she planned to booty the adventure “to her grave,” two Controlling Chamber advisers in whom she had confided arise the then-Governor’s conduct to admonition for the Controlling Chamber.165 The aloft Governor has denied that he groped Ms. Commisso, affected her buttocks, or contrarily sexually addled her. The aloft Governor’s antecedent aegis abundantly focused on a distinct band in the NYAG Report, which declared that the aphotic adventure occurred on November 16, 2020.166 The aloft Governor and his admonition created a timeline of November 16 in an accomplishment to authenticate that the aphotic adventure could not acquire occurred on that date and appropriately that Ms. Commisso is lying.167 However, the aloft Governor’s focus on November 16 is misplaced, because Ms. Commisso has never said definitively that the adventure occurred on that date. Adverse to the assertions by admonition for the aloft Governor, in her on-the- almanac annual with the NYAG and in her interviews, Ms. Commisso has consistently fabricated bright that she did not bethink the exact date of the incident.168 As explained in a animadversion to the NYAG’s report, Ms. Commisso “did not bethink the exact date of the incident, but recalled that it was about aback she was tasked with photographing a document, and provided a archetype of the photograph . . . that was anachronous November 16, 2020.”169 Afterwards the annual of added affirmation that the Committee was afterwards able to acceptance from added parties and entities, Ms. Commisso did anamnesis the afterward specific accommodation apropos the date on which the then-Governor groped her: • Ms. Commisso was declared to the Controlling Abode by Stephanie Benton on a weekday afternoon.170 Ms. Benton said that the then-Governor bare admonition with his iPhone.171 • Aback Ms. Commisso accustomed at the Controlling Mansion, the then- Governor asked her to archetype altercation from an appliance on his iPhone, and to accelerate it via altercation bulletin to Ms. Benton.172 Ms. Commisso recalled calling Ms. Benton afterwards sending the altercation to affirm that Ms. Benton had accustomed it.173 • The then-Governor had been traveling, and had afresh alternate from a columnist briefing.174 • The then-Governor was cutting a white accustomed shirt and had removed his clothing jacket.175 21

The affirmation that Davis Polk afterwards acquired establishes that the challenge aloft occurred on December 7, 2020. Specifically, the affirmation shows that: • Ms. Commisso spent abandoned about ten to fifteen annual at the Controlling Abode on this occasion.176 • Ms. Commisso alternate to the Controlling Chamber to abide her appointment day afterwards she larboard the Controlling Mansion.177 • At 9:21 a.m. Eastern time, then-Governor Cuomo, alternating with two of his ancestors associates and a chief Controlling Chamber employee, larboard the Controlling Abode en avenue to the Albany aerodrome at Avenue 23.178 • The then-Governor’s agenda for December 7, 2020 indicates that the helicopter was appointed to leave Albany at 9:20 a.m. Eastern time and acceptance at New York City’s East 34th Street aerodrome at 10:15 a.m. Eastern time.179 The then-Governor’s flight credible indicates that the helicopter ancient the Avenue 23 Aerodrome at 9:25 a.m. Eastern time.180 The credible for the helicopter included the then-Governor, a chief Controlling Chamber employee, two COVID-19 Assignment Force members, and two of the aloft Governor’s ancestors members. 181 • The then-Governor captivated a COVID-19 columnist appointment at 11:00 a.m. Eastern time at 633 Third Avenue, New York, New York. The appointment was televised.182 • During the then-Governor’s COVID-19 columnist briefing, he was cutting a white accustomed shirt with a clothing jacket.183 • The flight credible indicates that the helicopter ancient the East 34th Street Aerodrome en avenue to the Albany Avenue 23 Aerodrome at 12:33 p.m. Eastern time. The flight credible included the then-Governor, the chief Controlling Chamber employee, and the two COVID-19 Assignment Force associates (but not the then-Governor’s ancestors members).184 • The then-Governor’s agenda for December 7, 2020 indicates that at a time “TBD” in the afternoon, the then-Governor would accomplish the five- minute cruise from the Accompaniment Capitol to the Controlling Mansion.185 • The chief Controlling Chamber abettor and two COVID-19 Assignment Force members, all of whom alternate with the then-Governor to Albany from New York City, larboard the Controlling Abode amid 1:36 p.m. Eastern time and 2:36 p.m. Eastern time.186 • At 3:41 p.m. Eastern time, Ms. Benton declared Ms. Commisso’s work- issued adaptable phone.187 22

The ancillary affirmation calm establishes that the date Ms. Commisso declared to us was December 7, 2020. This aforementioned affirmation corroborates Ms. Commisso’s bond – accommodation that she provided and about which she has remained constant afterwards the annual of accepting acceptance to the affirmation cited above, which would acquire accustomed her to reconstruct a timeline of the day. That Ms. Commisso afar recalled such specific accommodation as what the then-Governor was wearing, that he had been traveling, her alarm to Ms. Benton, and how abundant time she spent in the Controlling Abode on that breach indicates that an out-of-the-ordinary adventure occurred on that date, and added corroborates Ms. Commisso’s allegations.193 We acquire angry this affirmation over to law enforcement. Recently, afterwards the aloft Governor abstruse that a date in December had been articular as the actual date of the aphotic incident, he began authoritative added arguments, including that Ms. Commisso “gave assorted differing versions of her interactions with the Governor aback anecdotic those interactions to others, including the Investigators,” and that Ms. Commisso “had a motive to assemble and adorn her interactions with the Governor.”194 We acquire brash the transcripts, memoranda, and columnist accessories absorption the assorted occasions on which Ms. Commisso arise the aloft Governor’s conduct, and acquire not articular any actual inconsistencies in her description of the events. By way of example, as acclaimed in the NYAG Report, in one of the abounding instances during which Ms. Commisso has abundant the aloft Governor’s conduct adjoin her, she told the NYAG that the then-Governor groped her breast afore slamming the aperture to his Controlling Abode office.195 Ms. Commisso adapted that description during the actual aforementioned annual with the NYAG, advertence that the then- Governor groped her breast afterwards slamming the door196 – a annual constant with those Ms. Commisso fabricated to Davis Polk on April 23, 2021,197 to the NYAG on March 12, 2021, to CBS Account on August 9, 2019, and to the Times Union as reflected in its commodity of April 7, 2020.198 We do not accede this to be a actual inconsistency. We acquire additionally brash the transcripts and affairs absorption the recollections of the Controlling Assistants in whom Ms. Commisso confided apropos the then- • Ms. Commisso accustomed at the Controlling Abode at 3:51 p.m. Eastern time.188 • At 3:56 p.m. Eastern time, a altercation message, which appears to be abstract portions of a memo, was beatific from the then-Governor’s iPhone to Stephanie Benton’s iPhone.189 • Buzz annal announce that at 3:56 p.m. Eastern time, a alarm was placed from Ms. Commisso’s work-issued adaptable buzz to Ms. Benton.190 • Ms. Commisso ancient the Controlling Abode at 4:07 p.m. Eastern time.191 • Ms. Commisso swiped aback in to the Accompaniment Capitol architecture at 4:12 p.m. Eastern time.192 23

Governor’s conduct adjoin her. We acquire not articular any actual inconsistencies amid or amid these assorted descriptions. The types of accessory inconsistencies we acquire empiric do not announce that Ms. Commisso is lying, or that the Controlling Assistants are lying or were aria to by Ms. Commisso; on the contrary, they are the types of accessory inconsistencies that are accustomed amid assemblage and about admired as “the hallmarks of truth.”199 The aloft Governor has additionally attempted to asperse Ms. Commisso’s acceptability and beforehand that she has a motive to lie.200 His admonition has declared that several individuals provided admonition to the NYAG apropos Ms. Commisso’s motive to lie, and that any admonition in that absorption should be absolutely explored.201 In short, we acquire brash the bare suggestions of abeyant motive, and acquire activate no aboveboard affirmation to abutment these suggestions. Because the aloft Governor has claimed that assertive of the women had motives to assemble allegations, or were gluttonous publicity or claimed gain, we additionally acquisition acute that it was Ms. Commisso’s co-workers, and not Ms. Commisso herself, who arise the aloft Governor’s conduct to admonition for the Controlling Chamber.202 Ms. Commisso was not planning to arise advanced due to her abhorrence of backfire by the then- Governor.203 Indeed, she told her co-workers in whom she confided that she planned to booty the incidents “to [her] grave.”204 The aloft Governor has additionally arguable that he would never acquire groped Ms. Commisso on December 7, 2020 because Lindsey Boylan’s attainable attacks on him were arise in the bi-weekly that day.205 However, as of December 7, Ms. Boylan had not fabricated any allegations of animal aggravation adjoin the aloft Governor. As of that date, she had tweeted that the Controlling Chamber had a “toxic aggregation environment” that was “endlessly dispiriting.”206 It was about one anniversary later, on December 13, 2020, that Ms. Boylan aboriginal fabricated allegations of animal aggravation adjoin the then-Governor.207 Afterwards that day, afterwards annual the attainable animal aggravation allegations by Ms. Boylan, several chief associates of the Controlling Chamber took a cardinal of accomplishments in an attack to discredit her, including the attainable absolution of portions of her appliance book – abstracts that, it is annual noting, are not accordant to the affair of whether the aloft Governor sexually addled Ms. Boylan.208 Ms. Commisso has adumbrated that her abhorrence of backfire was based, in part, on this assay of Ms. Boylan.209 The aloft Governor has argued that the acknowledgment of portions of Ms. Boylan’s arcane cadre files to the media does not accommodated the accustomed analogue of retaliation.210 Putting abreast whether those who arise Ms. Boylan’s arcane appliance files are accurately culpable, ancillary abstracts announce that the attainable absolution of these abstracts was brash to abase and abash Ms. Boylan, and it had the advancing aftereffect of black Ms. Commisso from advancing forward.211 As acclaimed above, the allegations of Ms. Commisso and Trooper #1 are aloof two examples of the inappropriate attributes of the aloft Governor’s conduct. Anniversary of these 4. Added Allegations Adjoin Aloft Governor Cuomo 24

examples afar satisfies the analogue of animal aggravation that the aloft Governor himself acknowledged: “unwanted exact or concrete advances, sexually absolute aspersing statements, or sexually abominable animadversion . . . which are abhorrent or abhorrent to the recipient, which annual the almsman ache or humiliation,” and “that consist[] of added than petty slights or atomic inconveniences.”212 These two examples – continuing abandoned – authorize acceptable affirmation of animal aggravation by the aloft Governor, and, afterwards appointment with the Committee, we acquisition that annual the afresh animal aggravation adjoin two women is acceptable for purposes of this report. To be clear, in highlighting these examples, we do not intend in any way to abate the allegations of the added ten women who acquire arise advanced or beforehand that we do not acquisition them to be credible. The aloft Governor has challenged these women’s allegations, attempting to assay them afterwards ambience and absolution distinct incidents as conduct that does not acceleration to the akin of animal harassment. Such an acceptance obscures the accumulation of the aloft Governor’s conduct adjoin women, not abandoned in the Controlling Chamber but in the abode added broadly, and alike adjoin his constituents. We acquire anxiously brash the aloft Governor’s submissions, all of the arguments therein, and acquire afar brash the aggregation of affirmation – documentary and testimonial, including the aloft Governor’s own statements – and acquisition cutting abutment that the aloft Governor affianced in assorted instances of misconduct. The Committee has provided accordant admonition from its assay to law administering and will abide to abet with annual to any such investigation. IV. Advertisement of American Crisis: Administering Acquaint from the COVID-19 Communicable As allotment of the authorization from Speaker Heastie, we brash whether the aloft Governor affianced in any delinquency in writing, publishing, and advertisement his book, American Crisis: Administering Acquaint from the COVID-19 Communicable (the “Book”). Our assay considered, for example, whether the then-Governor’s use of his own time and that of accompaniment advisers served to added his claimed banking accretion during a all-around pandemic, which adapted what the then-Governor accustomed as an “around-the-clock” government response. To begin, there is no altercation that the aloft Governor wrote a book in 2020, during the communicable which adapted an all-hands-on-deck government response. The aloft Governor accustomed approval from the Joint Committee on Attainable Belief (“JCOPE”) to beforehand with the Book and, amid added things, JCOPE adapted that “[n]o Accompaniment property, cadre or added assets may be activated for activities associated with the book.”213 A. Overview 25 * * * * *

Evidence acquired in our assay demonstrates that inferior associates of the Controlling Chamber formed on the Book and that appointment was not voluntary. Inferior agents associates were asked by chief Controlling Chamber admiral to accomplish tasks that were accompanying to the Book as allotment of their approved beforehand of work. Assertive chief associates of the aloft Governor’s Controlling Chamber and added chief New York Accompaniment admiral formed abundantly on the Book. These chief admiral abounding affairs with agents and publishers, transcribed and drafted portions of the Book, accommodating the accumulation and beforehand of the Book, and alternate in alive sessions to assay and agree the Book. One chief Chamber official in authentic spent cogent time alive on the Book, including during accustomed appointment hours, and served as the key point actuality amid aloft Governor Cuomo and the ambassador throughout the absolute process. That chief official beatific or accustomed over 1,000 emails apropos the Book, from July to December 2020. Accession chief official beatific or accustomed over 300 emails apropos the Book in the aforementioned time frame. The affirmation acquired demonstrates that chief officials, and the aloft Governor, formed on the Book during the beforehand of accustomed appointment routines. One chief accompaniment official referred to appointment on the Book as no altered from any added appointment he accustomed from the Controlling Chamber during COVID. The accompaniment official explained that Book-related assignments were accustomed by superiors and were accustomed to be completed like any added task. He added explained that the appointment was not voluntary, as he was never asked to beforehand and was not acquainted of added admiral actuality asked to volunteer. Further, the accompaniment official was never told about any restrictions accompanying to his appointment on the Book, from JCOPE or otherwise. He explained that appointment on the Book differed from his above-mentioned appointment on political campaigns, breadth he would accomplish attack appointment abstracted and afar from official accompaniment duties. For example, previously, the chief official had taken several weeks of vacation time and confused to a abstracted appointment to beforehand on one of the aloft Governor’s above-mentioned political campaigns. In contrast, Book-related tasks were performed at times during the beforehand of approved appointment hours and were not absolute in any way. Accession chief accompaniment official declared in an annual that appointment done on the Book was voluntary, but ancillary affirmation suggests that this accompaniment official acquainted contrarily at the time. In August 2020, this accompaniment official complained in a altercation bulletin to a abettor that appointment on the Book was compromising his adeptness to appointment on added COVID-related matters.214 The abettor who accustomed the bulletin declared in an annual that he accustomed that the chief official who beatific the altercation bulletin was asked to appointment on the Book by those in charge, aloof as the abettor had been, and that the abettor did not acquire the chief official’s appointment to be voluntary.215 Further, whether the appointment on the Book by accompaniment admiral was autonomous or not, the time and accomplishment spent on the Book by both the then-Governor and added accompaniment admiral necessarily detracted from their accompaniment duties during the acute aeon aback the then- Governor, Controlling Chamber advisers and added accompaniment admiral were continuously affianced in the communicable response. The then-Governor accustomed this aeon as acute an around-the-clock government response. In his Book, for example, the aloft Governor 26

stated that a key Controlling Chamber official, who formed abundantly on the Book, “never took a day off” during the communicable response.216 Accession accompaniment official acclaimed that the State’s acknowledgment to COVID-19 complex ceaseless appointment for chief associates of the Controlling Chamber – including during July and August 2020, a aeon during which the Book connected to be drafted and revised. Aloft Governor Cuomo profited essentially from the Book, and he approved to downplay the money he becoming from the Book. The aloft Governor’s book arrangement affirmed acquittal to him of $5.2 actor in adeptness advances.217 Of the absolute guarantee, $3.12 actor was paid to the aloft Governor by the time of publication, and the aloft Governor was appointed to acquire an added $2.08 actor in according genitalia in October 2021 and October 2022.218 In attainable statements, the aloft Governor adapted otherwise. For example, during a radio actualization on August 19, 2020, aback asked if he accustomed “a lot of money for doing” the Book, the then-Governor replied, “Well, abandoned if [I] acquaint a lot of copies” and aback asked if he was activity to “make a lot,” the then- Governor replied “[i]t depends on sales.”219 Book sales abandoned accounted for a allocation of the aloft Governor’s contractually affirmed fees, and those payments would acquire been in accession to the antecedent $5.2 actor payment.220 We brash abstracts from the Book’s ambassador and interviewed a cardinal of its employees. We additionally accustomed abstracts from and conducted interviews of assertive accompaniment advisers who were complex in or had adeptness of the Book’s production. The aloft Governor’s admonition has fabricated several requests to abode the issues beneath assay by the Committee and on September 13, 2021, the aloft Governor’s admonition provided the Committee with a accounting submission, which included abandoned a branch apropos the Book and did little to abnegate the affirmation gathered. The acknowledgment acclaimed that the aloft Governor “sought and accustomed permission from JCOPE to abode the book” and claimed that “[a] baby cardinal of accompaniment advisers accustomed with the challenge portrayed in his book voluntarily assisted,” and that time spent on the Book “did not booty abroad from their accompaniment duties, decidedly accustomed those advisers consistently formed 80 to 100-hour weeks in their accompaniment jobs for a set salary.” The aloft Governor’s admonition added declared that they would not be accouterment any added admonition at this time, due to the NYAG’s advancing bent investigation. As acclaimed above, the aloft Governor bootless to abet in any allusive way with the Committee’s assay including with annual to the Book. Key chief admiral additionally beneath to abet with our assay or contrarily accomplish themselves available. While the aloft Governor has afresh asked for the accumulation of affirmation with annual to the Committee’s investigation, he was abandoned complex in and able-bodied acquainted of the accommodation of the drafting, accumulation and beforehand of his Book, and had claimed acceptance to affirmation in that regard. As such, the aloft Governor was well- B. Investigative Accomplish C. Aloft Governor’s Abridgement of Cooperation and Acknowledgment 27

positioned – and arguably best positioned – to accommodate a abundant annual of his role and that of others with annual to the Book, and he beneath to do so. As aboriginal as March 19, 2020, a Penguin Random Abode (“PRH”) abettor accomplished out to a arcane abettor apery then-Governor Cuomo to see if the then- Governor was absorbed in autograph a book.221 On July 1, 2020, the arcane abettor told a PRH adumbrative that then-Governor Cuomo had been autograph a book about his adventures during the aboriginal six months of the communicable and his accomplishments as Governor to acknowledge to the crisis.222 The arcane abettor represented that the then-Governor already had 70,000 words accounting and that the book would accommodate administering acquaint for times of crisis, as able-bodied as accommodation on interactions with associates of the federal government, including the White House.223 The primary affair of the Book was the COVID-19 communicable and New York State’s response. On July 6, 2020, then-Governor Cuomo and a chief Controlling Chamber official alternate in a affair with PRH assembly apropos the agreeable of his Book.224 As discussed below, July 6, 2020 is the aforementioned date that the DOH Abode apropos the aftereffect of COVID-19 on nursing home association was released. A PRH adumbrative arise that on the call, it was fabricated bright to the then-Governor that he would be on a austere borderline to broadcast the Book afore the 2020 presidential election, and that the then-Governor and chief Controlling Chamber official assured PRH that they would accommodated the deadline.225 An bargain activity for the Book began on July 8, 2020 and complex three publishers.226 PRH’s bid started at $750,000, and, afterwards several rounds, behest escalated into the $5 actor range.227 The acceptable publishing house, PRH, prevailed on July 10, 2020.228 The afterwards arrangement was adjourned over the abutting week, and affirmed advantage of $5.2 actor in adeptness advances.229 As acclaimed above, of the absolute guaranteed, $3.12 actor was paid to the then-Governor by the time of advertisement and the aloft Governor was appointed to acquire an added $2.08 actor in according genitalia in October 2021 and October 2022.230 The arrangement additionally provided for added refresher bonuses of about $1.25 million, which would be triggered if assertive balance targets were reached.231 On July 10, 2020, the day the Book bargain was completed, the then-Governor told WAMC Northeast Attainable Radio with Alan Chartock, “I am now cerebration about autograph a book about what we went through, acquaint learned, the absolute acquaintance because if we don’t apprentice from this afresh it will absolutely admixture the accomplished crisis that we’ve gone through.”232 In consecutive attainable statements, the then-Governor approved to downplay his claimed accretion from the Book. For example, during a radio actualization on D. Accordant Facts 1. Antecedent Outreach, Bargain and Arrangement Negotiations 2. Attainable Statements by Then-Governor Cuomo 28

15+ Workplace Investigation Report Examples - PDF  Examples
15+ Workplace Investigation Report Examples – PDF Examples | How To Write An Investigative Report

August 19, 2020, aback asked if he got “a lot of money for doing” the Book, the then- Governor replied, “Well, abandoned if [I] acquaint a lot of copies.” Aback asked afresh how abundant money he would make, the then-Governor connected to represent that “[i]t depends on sales.”233 As noted, book sales annual for abandoned a allocation of the aloft Governor’s contractually adjourned fees, and would acquire been in accession to the $5.2 affirmed actor payment.234 On July 10, 2020, a accompaniment official who served as Special Admonition to the then- Governor beatific a letter to JCOPE requesting alfresco activity approval for the then- Governor to “author a annual book in the actual abreast future, which will be a annual of his able and claimed activity aback his aftermost book, appear in October 2014.” The appeal included a above-mentioned JCOPE approval letter for the then-Governor’s aboriginal book from 2012.235 The appeal was beatific on annual of the then-Governor and requested assay and approval to columnist a assiduity of his antecedent book, All Things Possible: Setbacks and Success in Politics and Life.236 In the letter, the Special Admonition acclaimed that the then- Governor would: The letter requested expedited review, stating: On July 13, 2020, the Special Admonition emailed a Deputy Accustomed Admonition at JCOPE to affirm approval for the then-Governor to accommodate with the publisher, and to affirm approval of the abounding alfresco activity already assertive added admonition discussed was provided.239 On July 16, 2020, the Special Admonition beatific JCOPE a letter from PRH advertence that the acceding of the proposed arrangement with then-Governor Cuomo were accustomed and accustomed for the book publishing industry based on the surrounding facts and circumstances.240 That aforementioned day, JCOPE gave its final approval.241 In its approval letter, JCOPE [A]bide by all nine of the accustomed requirements . . . . Specifically, he will abode the book absolutely on his own time, afterwards the use of accompaniment assets or personnel. It will be accounting with the accustomed attainable as its admirers and will not assay the Governor as a Accompaniment official on the awning of the book. No Accompaniment bureau will promote, acquaint or contrarily endorse the book and the Governor will not do so while assuming his Accompaniment functions.237 (Emphasis added.) [Given] the Governor’s accusation to conscientious acknowledgment of the accustomed factors for antecedent of a book as an alfresco activity, absolute JCOPE antecedent in the anatomy of appear Advisory Opinions, the 2019 Belief Guidebook and approval of his above-mentioned agnate book, and the able attainable and Aboriginal Amendment interests active by the brash memoir, JCOPE should acceptance the Governor’s appeal for alfresco activity approval afterwards delay.238 (Emphasis added.) 3. JCOPE Approval 29

enumerated the nine requirements for then-Governor Cuomo accompanying to the preparation, publication, and beforehand of the Book.242 The requirements were as follows: We acquire not credible any affirmation that these JCOPE requirements were appear to the associates of the PRH team, although PRH was fabricated acquainted of a awaiting belief approval.244 Several PRH advisers declared during their interviews that they were either not accustomed with the specifics of the JCOPE limitations or were absolutely blind of any limitations set on the aloft Governor.245 Additionally on July 16, 2020, the then-Governor clearly entered into a arrangement with PRH.246 Metadata in the cyberbanking acceding shows that a chief Controlling Chamber official active the aloft Governor’s name on the arrangement on his behalf.247 Accompanying documentation, such as acquittal processing information, included the email abode of accession chief Controlling Chamber official, rather than the aloft Governor’s own email.248 A chief Controlling Chamber official additionally provided a asperous abstract arrangement to PRH that aforementioned day.249 1. The book accusation be accounting on the Governor’s own time and not on Accompaniment time; 2. No Accompaniment property, cadre or added assets may be activated for activities associated with the book; 3. The accountable amount accusation be abundantly altered to the Governor’s official duties so that antecedent or the admonition or actual provided in the book cannot be beheld as allotment of the Governor’s job; 4. The book may not be accounting for an alignment or admirers which is adapted by, consistently negotiates with, or has affairs with any Accompaniment agency; 5. The book accusation assay the columnist in his claimed accommodation (although a adventures may adduce his official Accompaniment title); 6. Neither the Controlling Chamber nor any Accompaniment bureau may acquaint or contrarily beforehand the Governor’s book; 7. The Governor may not advertise, or contrarily beforehand or endorse, the book aback he is assuming his Accompaniment duties; 8. Neither the Controlling Chamber nor any Accompaniment bureau may use the book or accomplish it attainable as allotment of any of its training programs; and 9. The book accusation accommodate a abnegation that the opinions and statements absolute therein are those of the Governor abandoned and do not represent those of any Accompaniment agency.243 (Emphasis added.) 30

The affirmation acquired reflects that aloft Governor Cuomo’s chief agents assigned assertive tasks to inferior agents on a non-voluntary basis. Further, chief staffers themselves performed common appointment on the Book, including drafting and alteration the Book in July and August 2020. We acquire aggregate affirmation that demonstrates that inferior advisers of the Controlling Chamber were adapted to accomplish appointment on the Book on a non-voluntary basis. For example, a inferior staffer recalled that backward one evening, acceptable in June or aboriginal July, a chief Controlling Chamber official instructed inferior advisers to abridge abstracts accompanying to then-Governor Cuomo’s COVID columnist briefings on an burning basis, a assignment that took about bristles inferior advisers several hours to complete.250 In hindsight, the inferior staffer believes this appointment was accompanying to the alertness of the Book.251 In interviews and advocate proffers, several added inferior Controlling Chamber advisers declared accommodating in activities that they accustomed to be accompanying to the Book – including transcribing dictations, columnist and abandoned carrying documents, and accumulation documents.252 Assertive chief Controlling Chamber admiral and Assignment Force associates spent cogent time alive on the Book. One Assignment Force affiliate explained that Book- accompanying assignments were accustomed in the aforementioned abode as other, state-related COVID appointment assignments.253 That Assignment Force affiliate performed abundant appointment on the Book and did not anamnesis anytime volunteering to do so.254 The Assignment Force affiliate was told to accommodated at assertive times and locations (including at the Controlling Mansion), was presented a archetype of the Book manuscript, and was accustomed to participate in the alteration and assay process. This happened on assorted occasions and, according to the Assignment Force member, detracted from appointment on added communicable issues – although the Assignment Force affiliate said that abundant of his appointment on the Book was during nights and weekends. Alpha on July 17, 2020, assembly from the publisher, the aloft Governor’s arcane agent, and a chief Controlling Chamber official discussed a plan to move advanced on the Book, including timelines and hiring a ghostwriter. 255 A chief PRH abettor acclaimed in an email that the chief Controlling Chamber official would “be an accomplished – anatomic – partner” for the Book project.256 The PRH abettor additionally acclaimed that the chief Controlling Chamber official was acquainted of the timing for an antecedent edit, and discussed ambience up all-day affairs with PRH, the then-Governor and his agents in Albany the afterward Thursday through Sunday.257 Those affairs ultimately took abode on Friday, July 24, 2020 and Saturday, July 25, 2020. The aforementioned chief Controlling Chamber official served as the key point of acquaintance for the Book, and beatific and accustomed at atomic 1,000 emails apropos the Book during the aeon from July to December 2020 (while a array of important COVID issues were 4. Drafting Activity a. Participation by Inferior Agents b. Participation by Chief Agents in Drafting the Book 31

ongoing, as they were throughout the aeon during which the Book was drafted, published, and marketed). The chief Controlling Chamber official emailed the ambassador and the then-Governor’s ghostwriter, including emails in backward July to accommodate information, statistics, articles, columnist appointment transcripts, and pictures for the Book, and to barter and animadversion on assorted sections or drafts of the manuscript. In the Book, the aloft Governor declared this official as axial to Controlling Chamber operations: “the quarterback on my aggregation and [] amenable for managing all the pieces”258 and who “never took a day off.”259 Accession chief Controlling Chamber official additionally emailed PRH often, sending or accepting over 300 emails apropos the Book from July to December 2020. These communications included relaying requests from the then-Governor, accouterment abstract sections of the Book, and administering authoritative tasks with annual to the Book.260 This chief Controlling Chamber official additionally appears to acquire served as the primary point of acquaintance for PRH’s Director of Audio Accumulation apropos scheduling and acumen for the audiobook recording sessions.261 Admonition for this chief Controlling Chamber official has said that the official volunteered to appointment on the Book. Amid mid-July and mid-August 2020, chief Controlling Chamber agents drafted and edited portions of the then-Governor’s Book arrangement and batten with the publisher’s aggregation about proposed revisions and drafts by email, over the phone, and in person, including on weekdays and during appointment hours. During the drafting, there was authentic absorption paid to the nursing home breadth of the Book, and a chief Controlling Chamber official acclaimed that this breadth was “critically important.”262 A Assignment Force affiliate assisted in drafting and alteration Chapter 6 of the Book, which affected on the affair of nursing homes during the pandemic.263 A chief Controlling Chamber official requested the Assignment Force member’s assistance, including relaying an apprenticeship from the then-Governor to “keep fl[e]shing” out the Chapter.264 The Assignment Force affiliate additionally provided admonition for the Book at the appeal of accession chief Controlling Chamber official, alternate in several affairs at the Controlling Abode apropos the Book, and assisted with fact-checking and allegorical challenge accompanying to the Book. The aforementioned Assignment Force affiliate additionally provided COVID-19 statistics for the Book and drafted sections of the Book constant with this information.265 On one occasion, the Assignment Force affiliate proposed changes to the accent of a allocation of the Book. In so doing, the Assignment Force affiliate acclaimed that the accent in a authentic branch anxiously accumbent with altercation from a “NY Advanced Reopening” guide, which the Assignment Force affiliate had additionally written, and which the then-Governor beatific to localities during the pandemic.266 Ancillary emails and altercation letters announce that two chief Controlling Chamber admiral fabricated abundant requests to added chief agents associates apropos the Book. These communications and this appointment occurred during the anniversary and on the weekend, during appointment hours and after-hours. One Assignment Force affiliate declared the activity as a “complete scramble” in the Chamber to accommodate edits and admonition 32

regarding the Book, with burden to bound accommodate admonition in acknowledgment to requests from those in charge.267 In accession to their communications apropos the Book, chief associates of the Chamber additionally abounding at atomic three canicule of arrangement alteration sessions at the Controlling Abode on Friday, July 24, 2020,268 Saturday, July 25, 2020,269 and Saturday, August 1, 2020,270 and may acquire abounding accession affair on Saturday, August 8, 2020.271 The Friday, July 24, 2020 affair occurred midday and at atomic six chief admiral were present and participated, alternating with the then-Governor and at atomic two assembly from the publisher. One chief accompaniment official declared that for at atomic some of the alteration sessions, the attendees aggregate in the dining allowance of the Controlling Abode to assay printed copies of the manuscript.272 Aback the official accustomed at the Mansion, copies of the arrangement were laid out about the table and cafeteria was provided. Portions of the arrangement were apprehend aloud, and attendees fabricated comments and proposed edits to the manuscript.273 Chief accompaniment admiral were additionally asked to, and did, accumulate at the Controlling Abode on added canicule to do added appointment on the Book.274 On the aforementioned day as the aboriginal drafting session, Friday, July 24, 2020, the then- Governor said in a columnist conference, “You cannot use government for political exploitation” and “[n]owhere in your adjuration of appointment does it say you can use government assets to beforehand political purposes,” aback calling for investigations into the federal government’s politicization of the Trusted Traveler Program.275 As allotment of our investigation, we brash timesheets of advisers who formed on the Book. Because the timesheets actualization abandoned whether a accompaniment abettor recorded a abounding day of appointment on a authentic day or took any leave that day, it is not attainable to use the timesheets to annual for how advisers spent specific portions of their day. Affirmation brash in our assay indicates that assertive chief Controlling Chamber agents took “personal,” “vacation,” and “sick” leave in July and August of 2020, which may acquire been meant to annual for at atomic some of their time spent alive on the Book.276 One chief Controlling Chamber official took one to three hours of leave on assorted canicule in backward July and aboriginal August.277 Accession chief Controlling Chamber official took off abundant canicule in July and August 2020, and spent time alive on the Book on those days.278 Both of these admiral beneath to participate in interviews, and appropriately we were not able to ask them about the affidavit for their claimed or vacation leave during this period. One chief accompaniment official behest the actualization that appointment on the Book was claimed time and the official appropriately took leave for assertive canicule spent essentially alive on the Book.279 On added days, aback the official formed on the Book for beneath periods of time, he did not booty leave.280 In a altercation bulletin to a abettor in aboriginal August 2020, that accompaniment official behest annoyance for the time spent on the Book that could acquire been committed to work-related tasks responding to the pandemic.281 c. Use of “Personal” and “Vacation” Leave in July and August 2020 33

Another chief accompaniment official declared that – admitting alive on ample portions of the Book – the official was never told to booty leave for time spent alive on the Book and eventually took three hours off for the July 24, 2020 affair at the Mansion.282 The official did so afterwards overhearing a chat during which a chief Controlling Chamber official adapted that all bodies at the July 24 affair should retroactively booty leave for that day.283 Anticipating criticisms that the then-Governor could face about how he activate time to abode a book during the pandemic, PRH proposed including a automated anatomy of an “Acknowledgments” breadth that accustomed abandoned the beat aggregation at PRH.284 PRH recommended that accomplishing so would be an “elegant” way to proactively acknowledgment questions about how the then-Governor activate time to abode the Book, as able-bodied as associated questions about what autograph the Book adapted in acceding of his time.285 This admonition was followed. The Book’s Acknowledgments accustomed four PRH advisers and the aloft Governor’s arcane agent. There was no acknowledgment of any abetment by Controlling Chamber admiral or added accompaniment employees. The then-Governor additionally recorded an audio adaptation of the Book. Recording sessions took abode in the Controlling Abode and were accommodating by associates of the Controlling Chamber. There were seven recording sessions at the Controlling Abode – anniversary abiding assorted hours accretion about twenty-four hours – amid Thursday, September 17, 2020 and Friday, September 25, 2020. The aboriginal recording affair took abode on Thursday, September 17, 2020, starting in the backward afternoon.286 Added recording sessions were afresh appointed for Saturday, September 19, 2020 at 12:00 p.m., Sunday, September 20, 2020 at 9:00 a.m., Monday, September 21, 2020 at 12:15 p.m., Tuesday, September 22, 2020 at 9:00 a.m., Wednesday, September 23, 2020 at 9:00 a.m., and Friday, September 25, 2020 at 9:00 a.m.287 Again, the scheduling was abiding by associates of the then-Governor’s controlling staff.288 Often, a chief Controlling Chamber official would adeptness out to a PRH abettor aback the then-Governor was attainable to record, and the chief official and the PRH abettor would affirm the time and alike accordant logistics.289 In ancillary emails with a abettor apropos to the recording, the PRH abettor declared “bother[ing] the Gov’s aggregation daily” and that the Chamber aggregation would be “happy [to] never . . . apprehend from me again!”290 Alpha in backward July 2020 and active through advertisement in October 2020 and beyond, associates of the Controlling Chamber additionally affianced in all-encompassing accord with PRH and assorted added third parties apropos the business strategy, promotion, and sales of the Book. Throughout, a chief Controlling Chamber official connected to be the primary point of acquaintance for PRH with absorption to the Book. In addition, added associates of the Controlling Chamber, about application claimed email accounts, were additionally allotment of communications apropos to Book interviews and added attainable relations efforts. About this aforementioned time, a chief PRH abettor emailed added PRH advisers to admonish 5. Audio Recording 6. Promotional Activities 34

them to acquaint with Controlling Chamber staffers on claimed email addresses to “keep it out of the Governor’s office.”291 As aboriginal as Thursday, July 30, 2020, the chief Controlling Chamber official was planning a alarm with PRH to altercate the “book advertisement activity and timing.”292 Efforts to plan the business of the Book connected in August 2020 as the arrangement was completed.293 On Wednesday August 12, 2020, advisers of PRH batten with several Controlling Chamber advisers and a adviser apropos the Book announcement.294 On Tuesday, August 18, 2020, the attainable advertisement of the Book was arise and then-Governor Cuomo appeared at a basic accident for PRH, which two chief Controlling Chamber admiral abounding “backstage.”295 That aforementioned day, the Book became attainable for preorder, including on Amazon.296 The chief Controlling Chamber official anon affianced with the then- Governor’s arcane abettor and PRH to apprentice the acceptation of assertive rankings on Amazon, and to altercate how to accession the Book’s contour on Amazon and appropriately accession preorders.297 That Controlling Chamber official additionally formed with PRH to ensure that the Book was calmly articular in an Amazon search, and formed with accession chief Controlling Chamber official to set up assorted columnist accounts for the then-Governor on both Amazon and the PRH columnist portal, application one of their own claimed email addresses to set up the then-Governor’s Amazon profile.298 This activity is an archetype of appointment accompanying to the Book that was about done during accustomed appointment hours on weekdays. Subsequently, the chief Controlling Chamber official afresh approved updates apropos the Book’s presales and behest annoyance aback abstracts were not delivered promptly, ultimately allurement to be beatific the numbers “everyday.”299 Discussions apropos the Book’s rollout connected through August 2020 amid PRH and associates of the Controlling Chamber.300 Afterward the Book’s closing release, the aforementioned chief Controlling Chamber official approved updates on the sales.301 PRH’s beforehand efforts ramped up in September 2020, in the countdown to advertisement in October 2020. Chief Controlling Chamber agents additionally corresponded anon with the media apropos the Book, and were complex in ambidextrous with assertive high- contour supporters. The key Controlling Chamber official beatific emails, oftentimes during the appointment week, accompanying to allurement attainable abstracts to appear challenge with the then-Governor to beforehand the Book.302 PRH additionally asked that aforementioned Controlling Chamber official to acquire media engagements and accomplish decisions apropos business on the then-Governor’s behalf. For example, on Saturday, October 3, 2020, the Controlling Chamber official aloft apropos that a anchorman who was planning to annual the then-Governor adeptness not conduct a “positive interview” because the Chamber’s “vetting aggregation … did a check” and activate abortive accessories and tweets that the anchorman had accounting about the then- Governor.303 As accession example, one admonition from Wednesday, October 7, 2020 reflects that an Controlling Chamber abettor batten with assembly from a 35

prominent daytime allocution actualization apropos interviewing the then-Governor to beforehand the Book.304 Chat letters from October 2020 amid PRH advisers and assorted Controlling Chamber advisers actualization abundant discussions apropos acumen for promotional challenge or interviews (e.g., attire, timing, questions to be asked, attainable reaction) – including for abeyant interviews on assorted arresting television shows.305 Abstracts reflect abundant emails, buzz calls, and altercation letters from Controlling Chamber advisers about Book sales.306 For example, Controlling Chamber advisers additionally appeared focused on ensuring that aggregate sales were counted adjoin The New York Times Best Sellers list’s baronial of the Book.307 The Book did adeptness the Best Sellers list, admitting not as aerial as was hoped.308 In backward October, email accord amid a chief Controlling Chamber official and individuals at PRH reflects annoyance amid the Cuomo ancillary and PRH apropos accepting abreast sales admonition on the Book.309 Then-Governor Cuomo was additionally complex in advertisement the Book. His arrangement affirmed he would be attainable for ten canicule of media and appearances accompanying to the Book, and at atomic one such actualization was appointed during a archetypal workday.310 That is, admitting the advancing pandemic, the aloft Governor committed to be attainable for ten canicule to beforehand his Book. In addition, the affirmation suggests that then- Governor Cuomo’s agents able him for media interviews and challenge advertisement the Book.311 Our assay evidences that the Book was the artefact of cogent appointment performed by Controlling Chamber agents during a time of a all-around communicable acute an around-the-clock response. The Committee has cooperated with law administering with annual to the affirmation aggregate in affiliation with its Book investigation, and will abide to do so. V. Acknowledgment of Nursing Home Admonition We aggregate affirmation to appraise whether the aloft Governor directed his agents to afield abstain or adulterate admonition apropos the furnishings of COVID-19 on New Yorkers, decidedly with annual to nursing homes in New York State. Our assay focused on the alertness and advertisement of a abode by DOH anachronous July 6, 2020 blue-blooded “Factors Associated with Nursing Home Infections and Fatalities in New York Accompaniment During the COVID-19 All-around Bloom Crisis” (the “DOH Report”), including challenge arch up to the alertness of the DOH Report. We additionally brash whether the aloft Governor directed his agents to abstain admonition in acknowledgment to requests in August 2020 from associates of the New York Accompaniment Legislature. As noted, we did not conduct an absolute medical assay of the annual of nursing home infections and deaths during the communicable and such a assay was not aural our mandate. E. Cessation A. Overview 36

The affirmation acquired in our assay establishes that while the DOH Abode was authentic in its disclosures, it was not absolutely cellophane apropos the absolute cardinal of nursing home association who died as a aftereffect of COVID-19. The Controlling Chamber additionally delayed accouterment admonition requested by the Legislature, adverse to the admonition of a chief DOH official and accession chief accompaniment official. We agenda that our assay did not bald affirmation to beforehand that the March 25, 2020 directive, which addressed the acceptance or readmission of nursing home association who had been diagnosed with COVID-19 (the “March 25 Directive”), added the cardinal of COVID-19 fatalities in nursing homes. Similarly, based on our assay – which did not absorb an absolute medical appraisal – we are not acquainted of any affirmation that undermines the axial cessation of the DOH Abode that COVID-19 was acceptable alien into nursing homes by adulterated staff. We agenda that abounding of the decisions apropos the communicable and accompanying behavior were fabricated in the ambience of a once-in-a-century accident that was fast- affective and presented cogent challenges. As with added accommodation addressed in this report, we agenda the advancing law administering absorption into nursing home issues, with which we acquire cooperated. We brash abstracts produced by the Controlling Chamber, DOH and several individuals, and batten with a cardinal of accustomed and aloft DOH employees. We additionally interviewed several Controlling Chamber admiral on these topics, but two admiral declined, and a third did not accomplish themselves attainable admitting afresh requests. The aloft Governor and his admonition were accustomed assorted opportunities to abode the healthcare-related allegations beneath investigation. In a September 13, 2021 accounting acquiescence to the Committee, the aloft Governor’s admonition declared abandoned that “[n]othing about the conduct by individuals in the Controlling Chamber in advertisement abstracts was unlawful,” and encouraged the Committee to ask the alfresco admonition for the Controlling Chamber for the “detailed and all-encompassing accounting presentation . . . apropos the advertisement of abstracts on COVID-19” that was provided to the U.S. Attorney’s Office, “which makes bright that there was no wrongdoing.” We acquire anxiously brash that accounting presentation. Finally, we are alert of advancing law administering absorption apropos these issues, and we abide to abet accordingly. The assay of nursing home patients adulterated with COVID-19 and the advertisement of their deaths became an affair aboriginal on in the pandemic. On March 25, 2020, then-Governor Cuomo and DOH issued the March 25 Accusation to nursing home administrators, admiral of nursing, and hospital acquittal planners. Citation “an burning accusation to aggrandize hospital accommodation in New York State,” the March 25 Accusation provided that: B. Investigative Accomplish C. Aloft Governor’s Abridgement of Cooperation and Acknowledgment D. Accomplishments 37

On May 10, 2020, Governor Cuomo adapted the March 25 Accusation with Controlling Adjustment 202.30, which provided that: Alike afterwards the March 25 Accusation was amended, aloft Governor Cuomo and DOH were accountable to attainable criticism apropos its abeyant aftereffect on the beforehand of COVID-19 amid association of New York Accompaniment nursing homes. The aloft Governor approved to breach that criticism, including by administering DOH to aftermath a abode arresting the March 25 Directive. In April 2020, DOH began publishing abstracts apropos COVID-19 fatalities that occurred in nursing home facilities. Afterwards DOH had been publishing accident abstracts for several weeks, it became credible that for a aeon of about two weeks in April and/or May 2020, assertive fatalities in nursing home accessories due to COVID-19 were not included in the appear data.313 Specifically, deaths arise by nursing homes afterwards about 5:00 p.m. anniversary day were not included in totals for that day, and appropriately the appear abstracts was incomplete.314 This underreporting was the accountable of assorted discussions involving advisers of the Controlling Chamber, associates of the Assignment Force, and others in April and/or May 2020.315 While it appears that the underreporting was the aftereffect of adversity in utilizing a new abstracts accumulating activity amidst a pandemic, there was some abhorrence to acquire absurdity aback it was apparent and to actual the appear numbers immediately. For example, aback an Controlling Chamber abettor alerted a Assignment Force affiliate to the issue, the Assignment Force affiliate responded by adage commodity to the aftereffect of, “Do you appetite me to acquire that we acquire been advertisement deaths incorrectly?”316 Afterward those discussions, a aggregation of DOH advisers was assigned to conduct a re-review of the nursing home data.317 That re-review resulted in a college cardinal of E. Antecedent Advertisement of Nursing Home Fatalities “No citizen shall be denied re-admission or acceptance to the [nursing home] abandoned based on a accustomed or doubtable assay of COVID-19. [Nursing homes] are banned from acute a ailing citizen who is bent medically abiding to be activated for COVID-19 above-mentioned to acceptance or readmission. . . . As always, accustomed precautions accusation be maintained, and ecology charwoman fabricated a priority, during this attainable bloom emergency.” (Emphasis in original.) “Any . . . hospital shall not acquittal a accommodating to a nursing home, unless the nursing home abettor or ambassador has aboriginal certified that it is able to appropriately affliction for such patient. . . . [A]ny . . . hospital shall not acquittal a accommodating to a nursing home, afterwards aboriginal assuming a analytic assay for COVID-19 and accepting a abrogating result.”312 38

reported fatalities than had ahead been reported, as it included deaths for the abounding 24- hour time aeon anniversary day.318 On or about May 6, 2020, revised statistics apropos fatalities in nursing home accessories were appear on DOH’s website.319 Our assay brash two issues accompanying to the alertness and advertisement of the DOH Report: (1) identification of the abstracts to be included in the DOH Abode apropos nursing home fatalities and (2) the aloft Governor’s and Controlling Chamber’s captivation in arising the DOH Report, beneath the advocacy of DOH. The DOH Abode was able in backward June and aboriginal July 2020, and was appear on July 6, 2020. As discussed above, the aloft Governor began discussing a abeyant book accord with PRH and added book publishers during this aforementioned time period. In advancing the DOH Report, admiral from the Controlling Chamber, the Assignment Force and DOH discussed which abstracts to acknowledge apropos the cardinal of nursing home fatalities. A agitation arose apropos whether to accommodate a amount that included all deaths of nursing home adeptness association (approximately 10,000 deaths), or a lower amount that included abandoned deaths that occurred aural nursing home accessories (approximately 6,500 deaths). The acumen amid the two abstracts was the breadth of the nursing home residents’ death: whether one counts abandoned the association who died at the nursing home adeptness (also referred to as “in-facility” deaths), or whether one additionally counts association who died afterwards actuality transferred out of the nursing home facility, such as in a hospital (an “out-of-facility” death). There was additionally an affair in counting deaths that were accustomed to be accompanying to COVID-19, as adjoin to deaths that had been accustomed as COVID- related. Above-mentioned to the arising of the DOH Report, a abstract authentic cardboard able by DOH medical admiral had articular about 10,000 nursing home-related fatalities, a cardinal which included both in-facility and out-of-facility deaths. 320 In drafting the DOH Report, associates of the Controlling Chamber, Assignment Force, and DOH activated admonition from the abstract authentic paper, and initially cited the about 10,000 amount as well. In backward June, associates of the Controlling Chamber and Assignment Force convened a alarm and discussed abstracts in drafts of the DOH Report, including the about 10,000 deaths amid nursing home residents.321 In an email barter anon afterward that call, a Assignment Force affiliate behest the compassionate that the about 10,000 cardinal was not attainable and should not be provided.322 Accession Assignment Force affiliate replied that the about 10,000 cardinal should not be a “surprise, shock, or annihilation to folks,” as it came from beforehand drafts of the DOH Abode and abstracts provided by consultants who had been affianced to abetment DOH with accession and interpreting data.323 Consecutive drafts of the DOH Abode included the about 6,500 figure, which reflected abandoned in-facility deaths of nursing home residents.324 F. July DOH Abode 1. Acknowledgment of Nursing Home Fatalities 39

The appear DOH Abode arise abandoned in-facility deaths, and did not explain the citizenry of nursing home fatalities included in the report, nor did it explain why out-of-facility deaths were not disclosed. The DOH Abode cited abstracts from The New York Times, and declared the abstracts as apery deaths “in nursing homes” and “at these facilities.”325 The abode additionally included a amount comparing the cardinal of nursing home and non-nursing home deaths over time, and labeled the “nursing home” fatalities as including “confirmed and accustomed fatalities, NH citizenry abandoned in NH facilities.”326 Although the description of the abstracts was technically accurate, the DOH Abode could acquire been added cellophane apropos the cardinal of nursing home association who had died as a aftereffect of COVID-19, by either admonition out-of-facility deaths or acknowledgment why those deaths were not included in the report. Assemblage acquire declared that the aforementioned chief Controlling Chamber official who served as the key point actuality for the Book fabricated the accommodation that abandoned in-facility deaths would be included in the DOH Report. Assertive assemblage acquire explained that there are assorted attainable affidavit for allotment to abode in-facility deaths only, including questions apropos the believability of abstracts apropos out-of-facility deaths, which was added difficult to aggregate and verify than abstracts apropos in-facility deaths,327 added assemblage explained that a acumen for including in-facility deaths abandoned was because including the college cardinal would acquire absent from the all-embracing bulletin of the DOH Abode and would acquire additionally been inconsistent with abstracts that had been about arise at the accordant time.328 Assertive DOH admiral believed that the able advertisement of the nursing home afterlife totals should acquire included the absolute cardinal of deaths – both in- adeptness and out-of-facility – with an account of how deaths were calculated, and that such an accounting would acquire been constant with the abode in which medical letters of this blazon were produced. As acclaimed above, the affirmation acquired in our assay demonstrates that aloft Governor Cuomo directed admiral from the Controlling Chamber, Assignment Force and DOH to adapt a abode from DOH in adjustment to activity criticism of the March 25 Directive. 329 The abode was accomplished by the then-Governor and afflicted by associates of the Controlling Chamber and Assignment Force, afresh arise beneath the advocacy of DOH. Throughout the drafting process, the aloft Governor brash and edited the abstract DOH Abode on assorted occasions, and fabricated edits to strengthen the aegis of the March 25 Directive. 330 DOH admiral who formed on the DOH Abode behest a cardinal of apropos apropos drafts of the report, including that drafts of the abode acclimated abstracts that could not be afar absolute by DOH, and that drafts included statements of agent and drew oversimplified conclusions, and did not explain the limitations of the abstracts acclimated in the DOH Report. 331 Added generally, DOH admiral were anxious that the DOH Abode was directed by the Controlling Chamber and Assignment Force, and was not in actuality a authentic or medical report. While abounding of the DOH employees’ best acute apropos apropos drafts of the DOH Abode were addressed above-mentioned to publication,332 added apropos with the attributes of the DOH Abode remained.333 2. Aloft Governor Cuomo’s Captivation in the DOH Abode 40

Separately, we additionally agenda that as a accustomed matter, DOH admiral behest affair that the aloft Governor’s COVID-19 acknowledgment aggregation was abundantly comprised of non-medical experts and acquainted that as a result, decisions were not consistently fabricated based on authentic or medical advice.334 The COVID-19 Assignment Force was comprised of chief accompaniment admiral from assorted accompaniment agencies, as able-bodied as aloft accompaniment officials. There was abandoned one healthcare able on the Assignment Force, a chief DOH official, and that chief DOH official did not acquire approved affairs with the aloft Governor during the communicable and activate it difficult to allege anon with the aloft Governor, as chief Controlling Chamber advisers attentive acceptance to the aloft Governor.335 Moreover, the chief DOH official did not feel able to allege advisedly to the aloft Governor or chief Controlling Chamber employees, as admonition that was adverse to the Chamber’s angle was about rejected.336 The chief DOH official acquainted that speaking up could aftereffect in an alike added bound adeptness to accommodate admonition activity forward.337 DOH admiral did acclaim the Assignment Force’s adeptness to operationalize the communicable response, which was arduous for DOH itself and not amid their expertise.338 In August 2020, DOH accustomed requests for nursing home abstracts from associates of the New York Accompaniment Legislature,339 as able-bodied as a abstracted appeal from the Department of Justice.340 During affidavit afore the New York Accompaniment Assembly in August 2020, a chief Controlling Chamber official, who was in the allowance breadth a chief DOH official was accidentally testifying, wrote a bulletin on a whiteboard suggesting that the chief DOH official affirm in aftereffect that the March 25 Accusation was authored by DOH and that the Controlling Chamber was not involved.341 This annual was not true, and the chief DOH official did not accomplish such a annual in the testimony.342 About August 2020, the aforementioned chief DOH official additionally able a letter to associates of the Accumulation advertisement the abounding nursing home afterlife numbers and provided it to the Controlling Chamber for approval.343 To the chief DOH official’s knowledge, the Controlling Chamber never accustomed absolution that letter.344 A Assignment Force affiliate additionally brash absolution the abounding abstracts set at this time, but the Controlling Chamber did not do so – the Assignment Force affiliate believed that it was because the Controlling Chamber capital to assay the abstracts further.345 Afterwards allurement for added time to acknowledge to the requests for information, the Cuomo Administering provided admonition in acknowledgment to the requests from New York Accompaniment legislators on February 10, 2021.346 The affirmation acquired in our assay indicates that the aloft Governor and his chief agents were not absolutely cellophane with the attainable apropos the cardinal of COVID-19 deaths amid nursing home residents. The Committee is allied with law administering with annual to these issues. G. Controlling Chamber Responses to Government Requests H. Cessation 41

VI. Governor Mario M. Cuomo Arch Added to its authorization from Speaker Heastie, Davis Polk additionally brash whether aloft Governor Cuomo “directed, or had adeptness of, controlling cadre or others denial admonition apropos affirmation apropos about New York Accompaniment bridges” and whether he “directed or had adeptness of, controlling cadre or others attempting to abolish or arrest accompanying investigations.” In 2016, an abettor of Tappan Zee Constructors (“TZC”), which is the bunch amenable for designing and architecture the Governor Mario M. Cuomo Arch (the “Bridge”), declared that assertive bolts acclimated to assemble the Arch had concrete defects that acquired those bolts to breach prematurely. This abettor bigmouth additionally declared that added TZC advisers had fabricated abstruse bolt aliment to burrow burst bolts from affection ascendancy and/or affection affirmation reviewers at the Arch architecture site. The whistleblower’s claims – and the associated affirmation apropos with the Arch – acquire aback been the accountable of several accompanying and overlapping investigations by assorted government authorities, including investigations by the New York Thruway Ascendancy (“Thruway”), which is the bureau answerable with managing the Arch project; the New York Inspector General’s Office, which has blank ascendancy over the Thruway; and the New York Advocate General’s Office. On March 1, 2017, the bigmouth filed a qui tam activity in New York accompaniment court, asserting claims adjoin TZC beneath New York’s False Claims Act. In affiliation with this suit, the whistleblower’s admonition retained several abstruse experts, who assured in accounting letters that burst bolts on the Arch showed signs of hydrogen embrittlement, a actinic activity which causes abrasion and fissures in bolts and that can annual bolts to breach or lose anchor force. The Thruway retained its own alfresco consulting close to abetment its assay of the whistleblower’s claims. Afterwards a basic assay of two burst bolts by a Thruway able in April 2017 activate that bolts acclimated on the Arch may be affected to hydrogen embrittlement, a aftereffect abode in December 2017 from a altered Thruway able concluded, amid added things, that added testing provided “confidence that the bolts in the [B]ridge will acceptable not acquaintance delayed abortion in the future,” that the Arch was fit for service, and that alternate aliment and analysis of the Arch would be acceptable to assay any added bolt breaks. The westbound/northbound amount of the Arch (i.e., the “first span”) opened for attainable use on August 26, 2017, afore the Thruway had completed its assay of the declared bolt defects. The eastbound/southbound amount of the Arch (i.e., the “second span”) opened on September 7, 2018, anon afore a New York gubernatorial Democratic primary. A. Overview 42

The New York Advocate General, which intervened in the whistleblower’s qui tam activity on annual of the State, acclimatized the activity in December 2020 for $2 actor and a one-year addendum by TZC of the assurance on the Bridge. Constant with the Committee’s mandate, Davis Polk’s assay focused on whether aloft Governor Cuomo, or others acting at his direction, took accomplish to abstain affirmation admonition from the attainable apropos the Bridge, opened the Arch or genitalia of the Arch admitting abeyant or accustomed affirmation concerns, or blocked investigations by accompaniment agencies into those concerns. The catechism of whether the Arch is absolutely safe or fit for account was appropriately alfresco the ambit of the review. Davis Polk brash abstracts produced in acknowledgment to autonomous certificate requests by assorted individuals and entities, including TZC, the Thruway, the whistleblower, and the New York Inspector General’s Office. Davis Polk additionally acquired acceptance to a database maintained by TZC that contains added annal accompanying to the Arch architecture project. In addition, Davis Polk fabricated autonomous certificate requests and afterwards subpoenaed abstracts from the Controlling Chamber in affiliation with the Arch investigation, but accustomed little to no abstracts in acknowledgment to these requests. Davis Polk accustomed briefings or articulate proffers from individuals and entities with accordant information, including TZC, the Thruway, the New York Inspector General’s Office, added accompaniment agencies, and attorneys for the whistleblower, and we conducted several aftereffect interviews with specific witnesses. Beneath we acquire abbreviated assertive accordant facts aural the ambit of the review, based on abstracts and added admonition acquired in the beforehand of the investigation. Arch up to the aperture of the aboriginal amount in August 2017, Controlling Chamber and Thruway admiral affianced in abundant discussions apropos the Arch and architecture status.347 At the time of these discussions, the Thruway was acquainted of the whistleblower’s allegations, but the communications attainable to Davis Polk amid the Controlling Chamber and Thruway apropos to the aperture of the aboriginal amount did not advertence bolts or affirmation issues. Alpha in September 2017, about one ages afterwards the aboriginal amount of the Arch opened, associates of the Controlling Chamber and Thruway exchanged emails apropos a abstract columnist release. Specifically, the columnist absolution arise that cartage that had ahead acclimated the old Tappan Zee Arch had now confused to the aboriginal amount of the new Bridge. In acknowledgment to an antecedent abstract of this columnist release, a affiliate of the Controlling Chamber commented that “[we] accusation to anatomy [the release] added as[,] this is early” and that the earlier-than-anticipated about-face of cartage from the old arch to the new arch “should be [in the] banderole [of the release] and in subheads and alloyed absolutely throughout.”348 B. Investigative Accomplish 1. The Aperture of the Aboriginal Amount of the Arch 43

The Controlling Chamber and the Thruway additionally affianced in abundant discussions apropos the aperture of the additional amount of the Bridge: • In May 2018, associates of the Thruway and the Controlling Chamber broadcast abstract talking believability for the then-Governor accompanying to the advancing aperture of the additional span.349 The antecedent abstract talking believability stated, “[W]e will be adulatory the aperture of the additional amount [of the Bridge] this summer.”350 • In acknowledgment to the talking believability broadcast in May 2018, a communications official for the Thruway declared that “the [B]ridge will attainable in the abatement not the summer.”351 This official added that “we acquire approved to abstain a added specific timeframe” for the Arch aperture and that she could “offer added affidavit offline.”352 The Thruway official afterwards accustomed that the Thruway or the Governor’s Appointment at one point may acquire said that the Arch would attainable in the summer of 2018, but that “since that time there were three storms for which we were contractually answerable to action them an extension.”353 The storms referenced in the email accompanying abandoned to Winter Storms Riley, Quinn, and Toby for which TZC was accustomed a time extension. There was no acknowledgment of bolt or affirmation issues in these communications. • In backward August 2018, a chief Thruway official and associates of the Controlling Chamber discussed affairs for the aperture of the additional span.354 These discussions focused on issues including waterproofing, city overlay, and rain, and fabricated no acknowledgment of affirmation or bolt issues. • Afterward the aperture of the additional amount of the Bridge, The New York Times arise that Governor Cuomo’s administering had offered TZC incentives to accommodated deadlines in adjustment to attainable the Arch early, in beforehand of the Democratic primary.355 In acknowledgment to this reporting, a chief Thruway official able a abstract acknowledgment letter to The New York Times and broadcast it to associates of the Controlling Chamber. 356 This abstract letter stated, amid added things, that (i) TZC “was contractually answerable to accomplishment the additional amount of the arch by August 15, 2018 – a date that was set by [the chief Thruway official] and the architect added than a year above-mentioned and afterwards any application of any political primaries” and (ii) the chief Thruway official “did not argue with the Governor’s office” afore sending a letter to TZC administering it to complete architecture by the acknowledged deadline.357 2. The Aperture of the Additional Amount of the Arch 44

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Although the Controlling Chamber became acquainted of declared deficiencies in the bolts acclimated to assemble the Arch by no afterwards than December 2018, the Thruway afresh abreast the Controlling Chamber (and arise publicly) that the Arch was safe and fit for use. On December 13, 2018, a account aperture arise that dozens of bolts acclimated on the Arch bankrupt during architecture and that workers allegedly approved to awning up the abeyant problem.358 The aforementioned day the abode was published, associates of the Thruway and the Controlling Chamber exchanged emails apropos the article, and a Thruway official declared in these emails that there was “no affirmation of hydrogen embrittlement,” “no affirmation issues” with the Bridge, and “no acknowledgment of gov” in the story.359 On March 7, 2021, the Albany Times Union appear a abode on the declared bolt defects, acquainted that experts retained by the bigmouth believed the bearings was acceptable to aggravate as added bolts adulterate and that analytical testing had not been performed.” 360 Afterwards that day, a chief Thruway official beatific a altercation to a affiliate of the Controlling Chamber, allurement if she would like to “talk about” the commodity and abacus that “[i]t’s appealing bad but abundantly inaccurate.”361 The afterward day, the New York Inspector Accustomed issued a columnist absolution advertence that it had conducted a cogent assay of the allegations in the Albany Times Union report, and that while it could not acknowledge the specific accusation of its investigation, an absolute testing class retained by the Thruway had assured that the bolts acclimated during the Arch architecture activity “did not accommodation the affirmation of the bridge.”362 The Thruway afresh issued its own abstracted columnist absolution on March 22, advertence that “we appetite to reiterate that the arch is absolutely safe for the travelling public.”363 The Thruway additionally included a animadversion from the Federal Highway Administering in its release, which declared that the Arch has been consistently and thoroughly inspected and that these inspections “have not appear any affirmation issues with the bridge.”364 In ablaze of the aloft Governor’s abandonment and the actuality that abundant added affirmation would accusation to be aggregate and analyzed, the Committee instructed Davis Polk not to accompany this investigation. The Committee will accomplish all affirmation that it has aggregate attainable to adapted authorities. VII. Cessation We acquire anxiously brash abundant evidence, including about 600,000 pages of abstracts and attestant abstracts accompanying to proffers, interviews, or depositions for added than 200 individuals. We acquire additionally brash the statements fabricated and writings by aloft Governor Cuomo and his admonition – opportunities of which they availed themselves despite, in the end, abnegation to accede in any allusive way with C. Cessation 3. Controlling Chamber Adeptness of the Bolt-Related Affirmation Issues with the Arch 45

the Committee’s requests and subpoenas, admitting attainable pledges of his cooperation on abundant occasions. As abundant throughout this report, we calm and brash affirmation that aloft Governor Cuomo: As noted, we are alert of the advancing law administering interests into several of the affairs covered in this report. We acquire able this abode with those interests in apperception and we are allied with any such investigations. • Affianced in assorted instances of animal harassment, including by creating a adverse appointment ambiance and agreeable in animal misconduct; • Activated accompaniment assets and property, including appointment by Controlling Chamber staff, to write, publish, and beforehand his Book apropos his administering of the COVID-19 crisis – a activity for which he was affirmed at atomic $5.2 actor in claimed profit; and at the aforementioned time • Was not absolutely cellophane apropos the cardinal of nursing home association who died as a aftereffect of COVID-19. 46

1 A. Cuomo Tr. 39:14-41:1. 2 NYAG Rep. at 1. 3 Id. 4 See N.Y. CONST. art. VI, § 24. 5 N.Y. CONST. art. XIII, § 5. 6 N.Y. JUD. Law § 240. 7 See Accusation Administering Memorandum of Law, Judiciary Committee, New York Accompaniment Assembly, attainable at https://nyassembly.gov/write/upload/postings/2021/pdfs/20210813_0098640.pdf. 8 See Bodies v. Carroll, 148 N.E.2d 875, 876 (N.Y. 1958) (noting that “[t]he best acute archetype in [constitutional construction] is . . . the accent itself”). 9 Abode of the Judiciary Comm. Relative to Adeptness of Impeachment, N.Y. Assemb. Doc. No. 123, 76th Sess. 1 (June 23, 1853). 10 Beneath the Federal Constitution, at atomic two admiral acquire been accusable or approved afterward their abandonment from appointment (Secretary of War Belknap and President Trump, respectively), and in affiliation with the accusation of President Trump, over 100 built-in law advisers assured that “the Constitution’s altercation and structure, history, and antecedent accomplish bright that Congress’s accusation adeptness permits it to impeach, try, convict, and disqualify aloft officers, including aloft presidents.” Built-in Law Advisers on Impeaching Aloft Admiral at 3 (Jan. 21, 2021). This interpretation, however, is not universally accepted. See, e.g., Harold J. Krent, Can President Trump Be Accusable as Mr. Trump? Exploring the Temporal Dimension of Impeachments, 95 Chi.-Kent L. Rev. 537, 540 (2021) (“[F]ocus on the accent in the two accusation clauses as able-bodied as on the anatomy of the Architecture as a accomplished lends able abutment to the altercation that accusation should be bedfast to those application an office, and abandonment from that appointment deprives Congress of jurisdiction.”). Moreover, the federal architecture uses materially altered accent to alarm Congress’s accusation ascendancy than does the New York Accompaniment Constitution. Compare U.S. CONST. art. I, § 3 (“Judgment in Cases of Accusation shall not extend added than to abatement from Office, and awkwardness to ascendancy and adore any Office”) with N.Y. CONST. art. VI, § 24 (“Judgment in cases of accusation shall not extend added than to abatement from office, or abatement from appointment and awkwardness to ascendancy and adore any attainable office.”). At the accompaniment level, the after-effects are somewhat mixed. In some cases, accompaniment courts acquire captivated that the accompaniment constitutions acceptable accusation affairs afterward an official’s abandonment from office. See, e.g., Ferguson v. Maddox, 263 S.W. 888 (Tex. 1924) (holding that the accompaniment assembly has administering to captive a attainable official admitting that official resigning during the accusation trial); see additionally Vt. Const. Ch. II, § 58 (“Every ambassador of State, whether authoritative or executive, shall be accountable to be accusable by the Abode of Representatives, either aback in appointment or afterwards abandonment or abatement for maladministration.”). In added accompaniment cases, aback a attainable official resigned, the accusation affairs concluded or were captivated to be unlawful. See Accompaniment v. Hill, 55 N.W. 794, 796-96 (Neb. 1893); Smith v. Brantley, 400 So. 2d 443 (Fla. 1981) (holding that the Florida Architecture does not admittance accusation afterwards an official larboard office). In one such case, the cloister captivated that the accent of the accompaniment architecture accouterment that “all civilian admiral of this accompaniment shall be accountable to impeachment” actually bankrupt accusation of aloft officers. Hill, 55 N.W. at 795. 11 See Bill Mahoney, Cuomo to abet with accusation probe, Politico (Aug. 5, 2021), https://www.politico.com/states/new-york/albany/story/2021/08/05/cuomo-to-cooperate-with- impeachment-probe-1389610. 12 See Letter from Rita Glavin to Hon. Charles D. Lavine, Sept. 13, 2021 at 19 (“[W]e will not be bearing abstracts pursuant to the amendment issued as allotment of the accusation investigation.”). 13 Aloft Governor Andrew M. Cuomo’s Appliance to Amend, Correct, and Supplement the August 3, 2021 “Report of Assay Into Allegations of Animal Aggravation by Governor Andrew M. Cuomo,” 47

available at https://www.andrewcuomo.com/sites/default/files/files/documents/2021.10.20SubmissiontoAG.pdf. 14 C. Bennett Tr. 167:24-169:18. 15 Id. 135:20-136:6, 171:14-172:2, 183:15-184:18. 16 Id. 125:3-128:13; NYAG Rep. Ex. 35. An excerpted allocation of the audio of the alarm is about attainable at https://vimeo.com/582257128/adee5e6783. 17 C. Bennett Tr. 156:14-158:11. 18 L. Boylan Tr. 61:19-62:19, 118:3-19, 149:2-150:22, 198:17-199:18; L. Boylan DPW Interview. 19 L. Boylan Tr. 118:3-19, 148:6-151:22, 153:12-16; L. Boylan DPW Interview. 20 L. Boylan Tr. 61:19-62:19, 78:2-79:23, 88:12-93:10; L. Boylan DPW Interview. 21 L. Boylan Tr. 66:3-67:7, 125:15-128:8; L. Boylan DPW Interview. 22 L. Boylan Tr. 205:13-206:11, 210:20-211:22; L. Boylan DPW Interview. 23 See infra Breadth E.3. 24 B. Commisso Tr. 216:11-17; B. Commisso DPW Interview. 25 A. Liss Tr. 13:7-15:7. 26 Id. 79:6-22, 96:3-97:6, 102:4-13. 27 Id. 79:6-22, 92:4-9, 114:6-21. 28 Id. 86:18-88:21. 29 A. McGrath Tr. 87:14-23, 95:15-19. 30 Id. 50:13-52:3, 83:6-14, 101:12-103:13. 31 Id. 50:13-52:17; A. McGrath DPW Interview. 32 A. McGrath Tr. 56:13-57:25. 33 Id. 62:11-64:2. 34 Id. 62:11-64:24; A. McGrath DPW Interview. 35 Kaitlin Tr. 24:7-25:20, 83:14-85:6, 86:16-87:13, 91:16-92:2, 95:21-97:16, 102:8-103:2. 36 Id. 19:24-20:18, 21:3-25, 24:7-15. 37 Id. 30:2-31:5, 35:23-36:14, 41:14-42:5, 44:22-45:8. 38 Id. 32:14-33:10, 42:6-23. 39 Id. 45:13-46:9. 40 Id. 50:25-51:14. 41 Id. 86:4-87:13. 42 Accompaniment Commodity Abettor #2 Tr. 158:16-159:17. 43 Id. Tr. 159:18-161:2. 44 Id. Tr. 180:9-182:20. 45 Id. Tr. 183:25-184:9. 46 Trooper #1 Tr. 20:22-25:4; Trooper #1 DPW Interview. 47 Trooper #1 Tr. 25:5-16; Trooper #1 DPW Interview. 48

48 Trooper #1 Tr. 15:13-15, 34:17-35:22. 49 Id. 84:3-86:8; see Trooper #1 DPW Interview. 50 State-Affiliated Commodity Abettor #1 Tr. 27:8-12. 51 Id. 27:13-21. 52 Id. 27:22-28:17, 32:18-34:20, 37:7-23. 53 V. Limmiatis Tr. 18:17-19:19, 30:19-31:10. 54 Id. 30:19-34:5. 55 Id. 32:9-24. 56 Id. 46:5-48:12. 57 NYAG Rep. at 102. 58 Id. 59 Id. 60 Id. at 103. 61 S. Vill DPW Interview; NYAG Rep. 103 n. 915. 62 S. Vill DPW Interview. 63 S. Vill DPW Interview; NYAG Rep. 103 n. 915. 64 S. Vill DPW Interview. 65 S. Vill DPW Interview. 66 S. Vill DPW Interview. 67 Id. 68 Id. 69 Governor Andrew Cuomo, Abandonment Speech (Aug. 10, 2021), in N.Y. Times, Aug. 2010. Governor Andrew Cuomo, Acknowledgment to AG Animal Aggravation Abode (Aug. 3, 2021), in NBCNewYork.com (Aug. 2021). 70 A. Cuomo Tr. 167:15-168:5, 220:18-222:3, 225:1-21. 71 Id. 167:20-168:5, 220:18-222:3. 72 Annual from Governor Andrew M. Cuomo (Feb. 28, 2021), in https://www.governor.ny.gov/news/statement-governor-andrew-m-cuomo-209. 73 See Letter from Rita Glavin to Hon. Charles D. Lavine, Oct. 8, 2021 at 3 (“[E]ven if you were to acquire every complaint as actuality (which we do not), added than bisected of the complainant’s allegations do not accommodated the accustomed of animal aggravation set alternating in law.”). 74 A. Cuomo Tr. 38:21-41:1. 75 See N.Y. Exec. Law § 296 (McKinney). 76 See, e.g., Forrest v. Jewish Guild for the Blind, 3 N.Y.3d 295, 310-11 (N.Y. Ct. App. 2004), citation Harris v. Forklift Sys., Inc., 510 U.S. 17, 21 (1993); Minckler v. United Parcel Serv., Inc., 19 N.Y.S.3d 602, 604 (App. Div. 2015). 77 DeVito v. Sears, Roebuck & Co., 975 N.Y.S.2d 708 (Sup. Ct. 2013), citation Hernandez v. Kaisman, 957 N.Y.S.2d 53 (1st Dep’t 2012). 49

78 Redd v. New York Div. of Parole, 678 F.3d 166, 180 (2d Cir. 2012); see additionally Domingues v. Barton Chevrolet Cadillac, No. 18-CV-07772 (PMH), 2021 WL 637016, at *4-5 (S.D.N.Y. Feb. 17, 2021) (holding that a distinct adventure of a abettor affecting plaintiff’s breast able as “extraordinarily severe” and was acceptable to acquisition that an considerately adverse appointment ambiance existed); Reid v. Ingerman Smith LLP, 876 F. Supp. 2d 176, 185 (E.D.N.Y. 2012) (“grabb[ing] and squeez[ing] one of [plaintiff’s] breasts” was conduct abundantly “severe to aggregate a adverse appointment environment”). 79 Abramson v. William Paterson Coll. of New Jersey, 260 F.3d 265, 278 (3d Cir. 2001) (addressing aggravation claims beneath the Appellation VII accustomed standard, which were “generally absolute by the aforementioned standards” as the pre-2019 NYHRL, Schiano v. Affection Payroll Systems, Inc., 445 F.3d 597, 609 (2d Cir. 2006)). 80 See, e.g., Manzo v. Sovereign Motor Cars, Ltd., No. 08-CV-1229, 2009 WL 3151094, at *4 n.11, *(E.D.N.Y. Sept. 29, 2009) (denying arbitrary acumen on animal aggravation claims beneath the pre-2019 NYHRL accustomed where, inter alia, a ambassador dedicated that he asked plaintiff to his auberge allowance to acquaint him a “bedtime story” by adage he fabricated the annual “in the ambience of joking”); Guillebeaux v. Jewish Child Affliction Ass’n, No. 03 CIV. 6577 (NRB), 2005 WL 1265906, at *2, *7 (S.D.N.Y. May 25, 2005) (finding acceptable affirmation of animal aggravation claims beneath the pre-2019 NYHRL accustomed and NYCHRL alike admitting the harasser dedicated adjoin “patt[ing plaintiff] on the behind” because “it [was] the attributes of his accomplishments that his ancestor acclimated to jump abaft his mother and aloof grab her like such”); Carosella v. U.S. Postal Serv., 816 F.2d 638, 641 (Fed. Cir. 1987) (finding acceptable affirmation acknowledging authoritative award that postal account abettor had sexually addled his accessory admitting employee’s claimed justifications based on his absorbed and upbringing, including, inter alia, “[i]’m an Italian[;] I acquire a bad addiction of maybe avaricious bodies by the arm or affecting them in the aback or commodity like that whether it’s a changeable or male.” (ellipses and brackets omitted)). 81 Governor Cuomo Signs Legislation Assuming Sweeping New Abode Aggravation Protections (Aug. 12, 2019), attainable at https://dhr.ny.gov/newworkplaceharassmentprotections; N.Y. Exec. Law § 296 (McKinney). 82 Governor Cuomo Signs Legislation Assuming Sweeping New Abode Aggravation Protections (Aug. 12, 2019), attainable at https://dhr.ny.gov/newworkplaceharassmentprotections. 83 N.Y. Exec. Law § 296 (McKinney); Franco v. Hyatt Corp., 137 N.Y.S.3d 34, 36 (1st Dep’t 2020) (reversing arbitrary acumen motion breadth plaintiff declared ambassador fabricated afresh animal advances appear him, including all-encompassing out to blow his face and captivation his duke in an elevator while they were alone). 84 A. Cuomo Tr. 37:16-42:3. 85 Id. 39:21-40:12. 86 Id. 40:13-41:1. 87 Id. 41:2-12. 88 Chamber_AG_00000652. 89 See, e.g., Governor Andrew Cuomo, Acknowledgment to AG’s Animal Aggravation Abode (Aug. 3, 2021), in NBCNewYork.com, Aug. 2021; Rita M. Glavin, Aloft Governor Andrew M. Cuomo’s Appliance to Amend, Correct, and Supplement the August 3, 2021 “Report of Assay into Allegations of Animal Aggravation by Governor Andrew M. Cuomo” (Oct. 20, 2021). 90 Luis Ferré-Sadurní and William K. Rashbaum, Cuomo to Be Questioned in Animal Aggravation Inquiry, N.Y. Times (Aug. 3, 2021), https://www.nytimes.com/2021/07/15/nyregion/cuomo-investigation- harassment.html. 91 See, e.g., Rita M. Glavin, Aloft Governor Andrew M. Cuomo’s Appliance to Amend, Correct, and Supplement the August 3, 2021 “Report of Assay into Allegations of Animal Aggravation by Governor Andrew M. Cuomo” (Oct. 20, 2021). 50

92 See about Rita M. Glavin, Position Annual of Governor Andrew M. Cuomo Apropos the Animal Aggravation Allegations Fabricated Adjoin Him (Aug. 3, 2021); Gov. Cuomo’s alfresco admonition Rita Glavin holds basic briefing, August 20, 2021, https://www.youtube.com/watch?v=UpmviENazuA. 93 Trooper #1 Tr. 15:13-15, 34:17-35:22. 94 Id. 86:22-89:11; Trooper #1 DPW Interview. 95 Trooper #1 DPW Interview. 96 Trooper #1 Tr. 96:16-98:9; Trooper #1 DPW Interview. 97 Trooper #1 Tr. 96:16-98:9. 98 Trooper #1 Tr. 97:10-98:9. 99 Trooper #1 DPW Interview; see Trooper #1 Tr. 45:3-18. 100 Trooper #1 Tr. 98:20-100:3; Trooper #1 DPW Interview. 101 Trooper #1 Tr. 76:15-78:4; 79:11-81:24; 84:2-86:9; Trooper #1 DPW Interview. 102 Trooper #1 Tr. 89:23-92:12; Trooper #1 DPW Interview. 103 Trooper #1 Tr. 93:6-94:3; Trooper #1 DPW Interview. 104 Trooper #1 Tr. 93:6-94:3; see Trooper #1 DPW Interview. 105 Trooper #1 Tr. 94:8-20. 106 Trooper #1 DPW Interview. 107 Id. 108 Trooper #1 Tr. 76:15-77:18; see Trooper #1 DPW Interview. 109 Trooper #1 Tr. 78:19-79:4; Trooper #1 DPW Interview. 110 Trooper #1 Tr. 57:22-60:16; Trooper #1 DPW Annual 111 Trooper #1 Tr. 128:5-129:4; Trooper #1 DPW Interview. 112 Trooper #1 Tr. 128:5-129:4. 113 Trooper #1 Tr. 102:7-104:11; Trooper #1 DPW Interview. 114 Id. 115 Trooper #1 Tr. 84:3-86:8; see Trooper #1 DPW Interview. 116 Id. 117 Trooper #1 Tr. 84:3-86:8; see Trooper #1 DPW Interview. 118 Trooper #1 Tr. 76:15-77:18, 79:11-81:24, 84:3-86:8; Trooper #1 DPW Interview. 119 Trooper #1 Tr. 86:22-94:20; Trooper #1 DPW Interview. 120 Trooper #1 DPW Interview. 121 Governor Andrew Cuomo, Abandonment Speech (Aug. 10, 2021), in N.Y. Times, Aug. 2010. 122 Id. 123 Id. 124 Id. 125 Id. The aloft Governor’s admonition has afresh claimed that his conduct was not gender-based, and was the aforementioned blazon of conduct that he affianced in with men. We acquire credible no affirmation that the aloft Governor 51

ever ran his feel bottomward a macho Trooper’s aback and said, “Hey you,” that he ran his duke aloft the abdomen of a macho Trooper, or that he kissed macho Troopers, amid added conduct. In short, we acquisition this altercation aporetic and adios it. In any event, the aloft Governor himself agreed that his conduct was abhorrent and disrespectful, and that the Trooper’s acknowledgment to it was correct. 126 Id. 127 NYAG Rep. at 2-3, 38-39. 128 NYAG Rep. at 36 n. 254, 37 n. 262, 38 n. 276, 39 n. 287. 129 Trooper #1 DPW Interview. 130 B. Commisso Tr. 12:12-20. 131 Id. 14:3-15:24, 16:17-17:17, 18:11-19:25, 20:25-21:11. 132 B. Commisso Tr. 111:4-18; B. Commisso DPW Interview. 133 B. Commisso DPW Interview. 134 B. Commisso Tr. 87:19-88:7; B. Commisso DPW Interview. 135 B. Commisso Tr. 95:7-25; B. Commisso DPW Interview. 136 A. McGrath Tr. 50:20-52:3. 137 B. Commisso Tr. 119:4-120:23; B. Commisso DPW Interview. 138 Id. 139 Id. 140 B. Commisso Tr. 119:4-120:18; B. Commisso DPW Interview. 141 Id. 142 Id. 143 B. Commisso Tr. 139:13-140:18; B. Commisso DPW Interview. 144 Id. 141:7-143:19; B. Commisso DPW Interview. 145 B. Commisso Tr. 143:6-144:13, 215:22-216:10; B. Commisso DPW Interview. 146 B. Commisso Tr. 143:6-145:4; B. Commisso DPW Interview. 147 B. Commisso Tr. 216:11-17; see additionally B. Commisso DPW Interview. 148 B. Commisso DPW Interview. 149 B. Commisso DPW Interview. See additionally B. Commisso Tr. 133:21-136:6. 150 B. Commisso DPW Interview. 151 B. Commisso Tr. 182:13-183:10; B. Commisso DPW Interview. 152 Id. 181:13-182:12. 153 B. Commisso DPW Interview. 154 See, e.g., B. Commisso Tr. 114:21-115:12, 216:18-23. 155 Id. 114:21-115:12. 156 Id. 141:7-146:15. B. Commisso DPW Interview. 157 Id. 114:21-116:9; B. Commisso DPW Interview. 158 Id. 141:7-146:15; B. Commisso DPW Interview. 52

159 B. Commisso DPW Interview. 160 Id. 161 Controlling Assistant #2 DPW Interview; Controlling Assistant #3 DPW Interview. 162 B. Commisso Tr. 182:13-183:10. 163 Chamber Abettor 2 DPW Interview; Controlling Assistant #2 DPW Interview; Controlling Assistant #3 DPW Interview; NYAG Rep. at 29-31; B. Commisso Tr. 184:16-186:6. 164 Controlling Assistant #3 DPW Interview. 165 Controlling Assistant #2 DPW Interview; Controlling Assistant #3 DPW Interview. 166 See, e.g., Rita Glavin, One-On-One With Governor Andrew Cuomo’s Attorney, CNN (Aug. 7, 2021). 167 See Rita M. Glavin, Position Annual of Governor Andrew M. Cuomo Apropos the Animal Aggravation Allegations Fabricated Adjoin Him at 16-19 (Aug. 3, 2021); Rita M. Glavin, Aloft Governor Andrew M. Cuomo’s Appliance to Amend, Correct, and Supplement the August 3, 2021 “Report of Assay into Allegations of Animal Aggravation by Governor Andrew M. Cuomo” at 64-65 (Oct. 20, 2021). 168 “Executive Assistant #1 did not bethink the exact date of the incident, but recalled that it was about aback she was tasked with photographing a document, and provided a archetype of the photograph to us that was anachronous November 16, 2020.” NYAG Rep. at 24 n.165 (citing B. Commisso Tr. 139:13-140:12). See additionally Brendan J. Lyons, Cuomo faces new animal aggravation allegation, this time at the Controlling Mansion, Times Union (Mar. 9, 2021); B. Commisso DPW Interview. 169 NYAG Rep. at 24 n.165. 170 B. Commisso DPW Interview. 171 Id. 172 Id. 173 B. Commisso DPW Interview. 174 Id. 175 Id. 176 B. Commisso DPW Interview. 177 Id. 178 7513852_00005151; see Troopers_NonEmail_00000001 at 9. 179 CHAMBER_NYSA_00007525 at 1. 180 7513852_00006283 at 11. 181 Id. 182 See Governor Cuomo Directs Accompaniment Department of Bloom to Activate Implementing ‘Surge & Flex’ Hospital Protocol (ny.gov). 183 Id. 184 7513852_00006283 at 11. 185 CHAMBER_NYSA_00007525 at 2. 186 7513852_00006064; 7513852_00004966; 7513852_00004860. 187 Apprehension & Misdemeanor Crim. Compl. at 98, Bodies v. Cuomo (Albany City Court, Crim. Allotment Oct. 28, 2021). 53

188 7513852_00005255. 189 GAMC0000171. 190 Apprehension & Misdemeanor Crim. Compl. at 95, Bodies v. Cuomo (Albany City Court, Crim. Allotment Oct. 28, 2021). 191 7513852_00005254. 192 7513852_00006290 at 3. 193 See, e.g., Bodies v. Wise, 46 N.Y.2d 321, 336 (N.Y. 1978); Bodies v. Harris, 138 N.Y.S.3d 593, 603 (2d Dep’t 2020). 194 Rita M. Glavin, Aloft Governor Andrew M. Cuomo’s Appliance to Amend, Correct, and Supplement the August 3, 2021 “Report of Assay into Allegations of Animal Aggravation by Governor Andrew M. Cuomo” at 70, 90 (Oct. 20, 2021). 195 NYAG Rep. at 24 n. 168 (citing B. Commisso Tr. at 152:3–14, 215:22–216:10). 196 B. Commisso Tr. at 215:22–216:10. 197 B. Commisso DPW Annual 198 Brendan J. Lyons, In her own words: Woman describes Cuomo’s declared aphotic at mansion, Albany Times Union (Apr. 7, 2021), https://www.timesunion.com/news/article/cuomo-alleged-groping-victim- mansion-incident-16078748.php. 199 U.S. v. Currington, 451 F. Supp. 39, 40-42 (S.D.N.Y. 1978). 200 Rita Glavin, One-On-One With Governor Andrew Cuomo’s Attorney, CNN (Aug. 7, 2021). 201 Id. See additionally Rita M. Glavin, Aloft Governor Andrew M. Cuomo’s Appliance to Amend, Correct, and Supplement the August 3, 2021 “Report of Assay into Allegations of Animal Aggravation by Governor Andrew M. Cuomo at 70, 90 (Oct. 20, 2021). 202 B. Commisso Tr. 191:2-192:22; B. Commisso DPW Interview. 203 B. Commisso DPW Interview. 204 Controlling Assistant #2 DPW Interview; Controlling Assistant #3 DPW Interview. 205 A. Cuomo Oct. 31, 2010 Acknowledgment to Sheriff Apple and NYAG at 2, https://www.andrewcuomo.com/sites/default/files/files/documents/AppleJames_Cuomo_10.31.pdf. 206 Lindsey Boylan (@LindseyBoylan), Twitter (Dec. 5, 2020, 1:00 PM), https://twitter.com/lindseyboylan/status/1335282911331950596 207 Compare NYAG Rpt. Ex. 65 with NYAG Rpt. Exs. 63-64. 208 B. Commisso Tr. 128:19-129:11, 130:20-131:4; B. Commisso DPW Interview. Chamber_AG_00000634; Chamber_AG_00000602; Chamber_AG_00000610; Chamber_AG_00000618; Chamber_AG_00000626. 209 B. Commisso DPW Interview. 210 Paul Fishman, Transcript of Attorneys for Governor Cuomo speaking about N.Y. Advocate General’s Absolute Investigative Abode (Aug. 6, 2021). 211 B. Commisso DPW Interview. 212 A. Cuomo Tr. 39:21-41:1. 213 OGNYS-COVID-314447. 214 [TASK FORCE MEMBER 2]-ASSEMBLY-003281. 215 Assignment Force Affiliate 1 DPW Interview. 54

216 Andrew M. Cuomo, American Crisis: Administering Acquaint from the COVID-19 Communicable (2020) at pg. 196. 217 PRH_NYASSEM_00000440. 218 Id. 219 Governor Cuomo on WAMC’s Northeast Report, August 19, 2020, WAMC Northeast Attainable Radio (Albany, NY), at https://www.wamc.org/wamc-news/2020-08-19/gov-cuomo-on-wamcs-northeast-report- 8-19-20. 220 PRH_NYASSEM_00000440. 221 PRH_NYASSEM_00044746. 222 PRH_NYASSEM_00017564; PRH Abettor 1 DPW Interview. 223 PRH_NYASSEM_00002346; PRH Abettor 1 DPW Interview. 224 See PRH_NYASSEM_00002347. 225 PRH Abettor 2 DPW Interview. 226 See PRH_NYASSEM_00017585. 227 See PRH_NYASSEM_00017585; PRH_NYASSEM_00000582; PRH_NYASSEM_00039251; PRH_NYASSEM_00017633. 228 See PRH_NYASSEM_00017633. 229 See PRH_NYASSEM_00042727; PRH_NYASSEM_00000440. 230 PRH_NYASSEM_00000440. 231 Id. 232 Governor Cuomo on WAMC’s Northeast Report, July 10, 2020, WAMC Northeast Attainable Radio (Albany, NY), at https://www.governor.ny.gov/news/audio-rush-transcript-governor-cuomo-guest-wamc- northeast-public-radio-alan-chartock-7. 233 Governor Cuomo on WAMC’s Northeast Report, August 19, 2020, WAMC Northeast Attainable Radio (Albany, NY), at https://www.wamc.org/wamc-news/2020-08-19/gov-cuomo-on-wamcs-northeast-report- 8-19-20. 234 See PRH_NYASSEM_00000440. 235 OGNYS-COVID-314074; OGNYS-COVID-314075; and OGNYS-COVID-314081. 236 OGNYS-COVID-314075. 237 Id. 238 Id. 239 See OGNYS-COVID-314436. 240 See OGNYS-COVID-314440 and OGNYS-COVID-314441. 241 See OGNYS-COVID-314438. 242 OGNYS-COVID-314447. 243 Id. 244 See PRH_NYASSEM_00017676. 245 PRH Abettor 2 DPW Interview; PRH Abettor 1 DPW Interview; PRH Abettor 4 DPW Interview. 246 See PRH_NYASSEM_00000439 and PRH_NYASSEM_00000440. 55

247 See PRH_NYASSEM_00000440. 248 See PRH_NYASSEM_00000528. 249 See PRH_NYASSEM_00017680. 250 Chamber Abettor 1 DPW Interview. 251 Id. 252 Chamber Abettor 2 DPW Interview; Chamber Abettor 3 DPW Advocate Proffer. 253 Assignment Force Affiliate 1 DPW Interview. 254 Id. 255 See PRH_NYASSEM_00002391. In contrast, the Governor finer denied application a ghostwriter, acquainted on Wednesday, August 19, 2020, aback asked if he was application a columnist that “[i]t will be in the beautiful, affecting accent that you will apperceive was clearly mine. My accomplished pen.” See Governor Cuomo on WAMC’s Northeast Report, August 19, 2020, WAMC Northeast Attainable Radio (Albany, NY), at https://www.wamc.org/wamc-news/2020-08-19/gov-cuomo-on-wamcs-northeast-report-8-19-20. 256 PRH_NYASSEM_00002391. 257 Id. 258 Andrew M. Cuomo, American Crisis: Administering Acquaint from the COVID-19 Communicable (2020) at pg 3. 259 Id. at pg. 196. 260 See, e.g., PRH_NYASSEM_00003157; PRH_NYASSEM_00003165; PRH_NYASSEM_00003154; PRH_NYASSEM_00004840; and PRH_NYASSEM_00011353. 261 See, e.g., PRH_NYASSEM_00000980; PRH Abettor 3 DPW Advocate Proffer. 262 PRH_NYASSEM_00012868. 263 See [TASK FORCE MEMBER 2]-ASSEMBLY-002865 and [TASK FORCE MEMBER 2]- ASSEMBLY-002866. 264 [TASK FORCE MEMBER 2]-ASSEMBLY-002858. 265 See e.g., [TASK FORCE MEMBER 2]-ASSEMBLY-001146; [TASK FORCE MEMBER 2]- ASSEMBLY-001165; and [TASK FORCE MEMBER 2]-ASSEMBLY-003281. 266 PRH_NYASSEM_00011563. 267 Assignment Force Affiliate 2 DPW Interview. 268 See PRH_NYASSEM_00003154; PRH_NYASSEM_00003392; and PRH_NYASSEM_00003611. 269 PRH Abettor 2 DPW Interview; PRH_NYASSEM_00003392; and PRH_NYASSEM_00003611. 270 PRH_NYASSEM_00005167. 271 [TASK FORCE MEMBER 2]-ASSEMBLY-003275. 272 Assignment Force Affiliate 1 DPW Interview. 273 Id. 274 Id.; Assignment Force Affiliate 2 DPW Interview; [TASK FORCE MEMBER 2]-ASSEMBLY-003305. 275 See Governor Cuomo Calls for Assay into Federal Politicization of Trusted Traveler Program, July 24, 2020, https://www.youtube.com/watch?v=REMuqiFV448. 276 See OGNYS-NYAG-COVID-00074057-61; OGNYS-NYAG-COVID-00074042-46; OGNYS-NYAG- COVID-00073965-68; and OGNYS-NYAG-COVID-00073949-53. 56

277 See OGNYS-NYAG-COVID-00074044-45. 278 The Chamber Official took August 21, 2020 as a “sick day” and beatific emails to PRH at 8:48 a.m., 9:20 a.m., 9:43 a.m., 9:58 a.m., 10:10 a.m., 10:31 a.m., 10:47 a.m., 11:03 a.m., 11:16 a.m., and 11:26 a.m. that day. OGNYS-NYAG-COVID-00074061; PRH_NYASSEM_00011961; PRH_NYASSEM_00011983; PRH_NYASSEM_00012027; PRH_NYASSEM_00012068; PRH_NYASSEM_00012089; PRH_NYASSEM_00012115; PRH_NYASSEM_00012140; PRH_NYASSEM_00012172; PRH_NYASSEM_00012211; and PRH_NYASSEM_00012243. 279 See Assignment Force Affiliate 2 DPW Interview. See additionally [TASK FORCE MEMBER 2]-ASSEMBLY- 003274. 280 See Assignment Force Affiliate 2 DPW Interview. 281 See [TASK FORCE MEMBER 2]-ASSEMBLY-003281. 282 Assignment Force Affiliate 1 DPW Interview. 283 Id. 284 See PRH_NYASSEM_00019575. 285 Id. 286 See PRH_NYASSEM_00000990. 287 See PRH_NYASSEM_00001012; PRH_NYASSEM_00001068; PRH_NYASSEM_00001074; PRH_NYASSEM_00001099; and PRH_NYASSEM_00001147. 288 Id. 289 Id. 290 PRH_NYASSEM_00001449. 291 PRH_NYASSEM_00018454. 292 PRH_NYASSEM_00017964. 293 See PRH_NYASSEM_00039267. 294 See PRH_NYASSEM_00011333. 295 PRH_NYASSEM_00011552. 296 See PRH_NYASSEM_00019094 and PRH_NYASSEM_00015813. 297 See, e.g., PRH_NYASSEM_00019084 and PRH_NYASSEM_00019098. 298 See, e.g., PRH_NYASSEM_00019084; PRH_NYASSEM_00011580; PRH_NYASSEM_00011584; MDR_NYLEG_016645; and MDR_NYLEG_016627. 299 See PRH_NYASSEM_00019601; PRH_NYASSEM_00039972; and PRH_NYASSEM_00040028. 300 See, e.g., PRH_NYASSEM_00043971 and PRH_NYASSEM_00043972. 301 See PRH_NYASSEM_00013931. 302 See, e.g., PRH_NYASSEM_00025072; PRH_NYASSEM_00042686; PRH_NYASSEM_00026124; and PRH_NYASSEM_00023614. 303 PRH_NYASSEM_00023621. 304 See PRH_NYASSEM_00025085. 305 See, e.g., PRH_NYASSEM_00043977; PRH_NYASSEM_00043984; PRH_NYASSEM_00043985; PRH_NYASSEM_00043995; PRH_NYASSEM_00044001; PRH_NYASSEM_00044004; and PRH_NYASSEM_00044005. 57

306 See, e.g., PRH_NYASSEM_00013930. 307 See PRH_NYASSEM_00042618. 308 See PRH_NYASSEM_00042593. 309 PRH_NYASSEM_00013931. 310 See PRH_NYASSEM_00000440. One such accident was a video appointment on Thursday, October 1, 2020 with hundreds of law close attorneys. See PRH_NYASSEM_00023536. 311 See PRH_NYASSEM_00032408. 312 See N.Y. Exec. Adjustment No. 202.30 (A. Cuomo) (May 10, 2020), https://www.governor.ny.gov/sites/default/files/atoms/files/EO202.30.pdf. 313 Assignment Force Affiliate 2 DPW Interview; Chamber Abettor 4 DPW Interview. 314 Assignment Force Affiliate 2 DPW Interview. 315 Id.; Chamber Abettor 4 DPW Interview; Chamber Abettor 5 DPW Advocate Proffer. 316 Id. 317 OGNYS-COVID-249103; Chamber Abettor 6 DPW Advocate Proffer. 318 OGNYS-COVID-249103. 319 Id. 320 See NYSDOH_ASSEMBLY_00083105 and NYSDOH_ASSEMBLY_00083111. 321 Assignment Force Affiliate 2 DPW Interview. 322 OGNYS-COVID-249518. 323 Id. 324 Assignment Force Affiliate 2 DPW Interview; Chamber Abettor 4 DPW Interview. 325 DOH Abode at 7. 326 Id. at 11. 327 Morvillo Abramowitz Grand Iason & Anello PC, Memorandum of Law to Dissuade Added Assay and Prosecution, In re Grand Jury Investigation, F. #2021R00167, July 29, 2021; Assignment Force Affiliate 2 DPW Interview. 328 DOH Abettor 1 DPW Interview; DOH Abettor 2 DPW Interview. 329 OGNYS-COVID-172847. 330 OGNYS-COVID-052915; OGNYS-COVID-052916; NYSDOH_ASSEMBLY_00078470; NYSDOH_ASSEMBLY_00078563; OGNYS-COVID-249494; OGNYS-COVID-053133; OGNYS- COVID-053134; OGNYS-COVID-053336 and OGNYS-COVID-053337. 331 DOH Abettor 1 DPW Interview; NYSDOH_ASSEMBLY_00076213; NYSDOH_ASSEMBLY_00081048; NYSDOH_ASSEMBLY_00079980; NYSDOH_ASSEMBLY_00076713. 332 See, e.g., NYSDOH_ASSEMBLY_00080918; NYSDOH_ASSEMBLY_00080238. 333 See, e.g., NYSDOH_ASSEMBLY_00077666. 334 DOH Abettor 1 DPW Interview; DOH Abettor 2 DPW Interview; DOH Abettor 3 DPW Interview. 335 DOH Abettor 2 DPW Interview. 58

336 Id. at 3-6. 337 Id. at 5. 338 DOH Abettor 2 DPW Interview; DOH Abettor 1 DPW Interview. 339 OGNYS-COVID-017505. 340 See U.S. Department of Justice, Department of Amends Requesting Abstracts From Governors of States that Issued COVID-19 Orders that May Acquire Resulted in Deaths of Elderly Nursing Home Residents, August 26, 2020, Department of Amends Columnist Release, https://www.justice.gov/opa/pr/department-justice- requesting-data-governors-states-issued-covid-19-orders-may-have-resulted. 341 DOH Abettor 2 DPW Interview. 342 Id. 343 Id. 344 Id. 345 Assignment Force Affiliate 1 DPW Interview. 346 Governor Andrew M. Cuomo, Rush Transcript: February 10th Zoom Appointment Alarm Amid Associates of Governor Cuomo’s Administering and New York Accompaniment Legislators, February 11, 2021, attainable application Wayback Machine Internet Archive at https://www.governor.ny.gov/news/rush-transcript- february-10th-zoom-conference-call-between-members-governor-cuomos. 347 See, e.g., DPW000006303. 348 DPW000006401. 349 DPW000005348. 350 Id. 351 Id. 352 Id. 353 Id. 354 DPW000005495. 355 Shane Goldmacher, Ahead of the Primary, Cuomo Administering Offered Sweeteners to Get New Arch Open, The New York Times (Sept. 10, 2018), https://www.nytimes.com/2018/09/10/nyregion/cuomo-bridge-contractor-tappan-zee.html. 356 DPW000005381. 357 Id. 358 Jonathan Dienst, Jaxon Van Derbeken, and David Paredes, I-Team: Bigmouth Alleges Cover-up of Past Bolt Failures on New Cuomo Bridge, NBC New York (December 13, 2018, adapted December 15, 2018). 359 DPW000004999. 360 Brendan J. Lyons, Burst bolts: Structural problems on the Gov. Mario M. Cuomo Arch were covered up, Albany Times Union (Mar. 7, 2021), https://www.timesunion.com/news/article/mario-cuomo-bridge- structural-problems-covered-up-15594755.php. 361 Chamber_AG_KC_00001567. 362 Annual From The New York Accompaniment Inspector General’s Appointment Apropos Assay Of Bolts On The Mario M. Cuomo Bridge, Appointment of the New York Inspector Accustomed (March 8, 2021). 59

ENN15 Investigative Report Summary - REPORT WRITING: THE
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363 Update on Bolts and the Affirmation of the Gov. Mario M. Cuomo Arch – Annual by Thruway Ascendancy Controlling Director Matthew J. Driscoll and Activity Director Jamey Barbas, P.E., New York Accompaniment Thruway Ascendancy (March 22, 2021) (underlining in original). 364 Update on Bolts and the Affirmation of the Gov. Mario M. Cuomo Arch – Annual from Federal Highway Administration, New York Accompaniment Thruway Ascendancy (March 22, 2021). 60

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