November 15, 2022
The New York Attorney General’s Office (the “NYAG” or the “Office”) continues to serve as a leader for other state attorneys general, having a profound impact on corporations, nonprofits, and individuals in New York and beyond. This round-up summarizes the major cases and initiatives pursued by New York State’s 67th Attorney General, Letitia James, and her team since August 2021. AG James was just re-elected to another four-year term beginning January 2023.
The NYAG’s priorities include a mix of local and national issues, including data privacy, cybersecurity, and data breaches; employee rights; investor protection; environmental and animal protection; protecting consumers, including homeowners, taxpayers, and seniors; and cracking down on Medicare fraud. There is certainly overlap in the NYAG’s priorities and those of federal regulators, and, like attorneys general around the country, increasingly the NYAG investigates and brings high-profile actions alongside federal regulators—including in cases where she may not have jurisdiction.
One new trend is that AG James is issuing reports that provide information about the NYAG’s investigative findings. Although these reports are not “legal proceedings” and often do not have any legal significance, the reports can have important public relations and reputational impact, and potentially spawn other regulatory investigations. Recently, for example, the Office has issued reports on the Nursing Home Response to the COVID-19 Pandemic, fake comments submitted in response to an FTC rulemaking on net neutrality, the sexual harassment allegations against Governor Andrew Cuomo, and the mass shooting in Buffalo, NY.
In terms of litigation, in recent years, the Office has made headlines for bringing large-scale suits in healthcare, including e-cigarette use among youth, the opioid crisis, and access to health care. That said, the Office initiates litigation in very few cases, resolving most through settlements. Like many AGs offices around the country, the Office is focused on enforcement against what it calls “Big Tech,” based on various legal theories, and in the past year has initiated several high-profile investigations into technology companies and other businesses. AG James continues to advocate for legislation in various key areas, including health care and the environment.
The Office’s biggest headline-grabber this year has been the September 2022 lawsuit against Donald Trump, the Trump Organization, senior management, and other entities. The case alleges that the Trump defendants engaged in years of financial fraud by falsely inflating Trump’s worth by billions of dollars in order to induce banks to lend money to the Trump Organization on more favorable terms, satisfy continuing loan covenants, induce insurers to provide insurance coverage for higher limits and at lower premiums, and gain tax benefits. On November 4, AG James won a motion that granted a preliminary injunction freezing certain assets, appointed an independent monitor to oversee the submission of financial information to certain third parties, and scheduled a preliminary conference for November 22 to set an expedited trial schedule.
In this Round-Up, we discuss in further detail numerous of AG James’s key cases and initiatives over the past year, including her support for antitrust legislation and efforts to enforce antitrust laws; her continued focus on data privacy rights of New Yorkers as reliance on consumer technology has increased as a result of the COVID-19 pandemic; her new efforts to in investor protection; her ongoing focus on health care, including abortion access; and her attention on the environment and labor and employment rights of New Yorkers.
I. Antitrust and Competition
AG James has continued to support efforts seeking to strengthen and modernize the antitrust laws. In September 2021, AG James co-led a bipartisan coalition of 32 state attorneys general in calling on Congress to fund state antitrust efforts in response to changing technology.
In New York specifically, AG James has continued to be a proponent of enacting the 21st Century Antitrust Act, a bill that its supporters claim would update New York’s antitrust laws to address the modern economy. The bill passed the New York State Senate on May 25, 2022 but did not pass the Assembly. The law seeks to expand antitrust liability under New York’s Donnelly Act to, among other things, make it unlawful for a company to “abuse” a “dominant position” in a relevant market—a standard that is adopted from European law. The bill has been criticized as excessively vague and potentially harmful to the New York economy.
AG James has also continued to aggressively investigate and pursue litigation against technology and pharmaceutical companies for alleged antitrust violations. In January 2022, a coalition of 48 attorneys general (led by AG James) appealed the D.C. federal district court’s dismissal of their claims against a tech giant for allegedly anticompetitive acquisitions. Also in January 2022, the Southern District of New York ruled in favor of New York, the FTC, and six other states in finding that Martin Shkreli engaged in illegal and anticompetitive practices while serving as the CEO of a pharmaceutical company. Shkreli was banned from the pharmaceuticals industry for life and was ordered to pay nearly $65 million.
AG James also launched antitrust investigations into and reached agreements with other businesses. For example, in November 2021, the Office reached an agreement with two large supermarket chains to divest stores located in New York in connection with the companies’ proposed merger because it would have allegedly eliminated direct competition between local supermarkets. And on July 28, 2022, AG James announced a lawsuit against a national pharmacy for alleged antitrust violations that allegedly impacted hospitals and clinics that provide care for underserved communities across New York State, by purportedly restricting their ability to take advantage of certain federal subsidies.
II. Data Privacy, Cybersecurity, and Data Breaches
AG James continued to be active in the data privacy and cybersecurity realms over the past year, announcing several investigations arising from alleged data breaches, focusing on the importance of corporations keeping their customers’ personal data safe. In fact, according to a list identifying the number of complaints AG James’s Office received in 2021, which AG James published in March of this year, the Office received the greatest number of complaints for “Internet-Related” issues, including “data privacy and security” and “data breaches.” Notable investigations and settlements, specifically arising from data breaches, include the following:
AG James has also launched several consumer protection investigations into various social media companies in connection with in allegedly harmful activity or prolonged social media engagement by young adult users.
Additionally, on January 5, 2022, AG James released a Business Guide for Credential Stuffing Attacks after an investigation into “credential stuffing”—repeated, automated attempts to access online accounts using usernames and passwords stolen from online services—revealed that over 1.1 million online accounts had allegedly been compromised in cyberattacks at 17 well-known online retailers, restaurant chains, and food delivery services. According to press reports, this “credential stuffing” allegedly compromised customer accounts at each of the companies. The Office urged the companies to investigate and protect impacted users, and every company complied.
Given evolving technology and the increase in cyber-attacks against businesses and consumers, we expect data privacy and cybersecurity to remain a high priority for the Office in the next year.
III. Cryptocurrency and Consumer/Investor Protection
We also expect that AG James will continue to scrutinize actors, investments, and exchanges in the cryptocurrency space, and generally in the consumer financial and investor protection areas. AG James’s efforts this past year demonstrate continued scrutiny of allegedly misleading statements and practices, including by debt collection agencies and student loan servicing agencies, as well as scrutiny of general consumer financing practices by non-bank retailers and money transmitters.
AG James’s focus on cryptocurrency investment has included an August 1, 2022 “investor alert” that urged “any New Yorker deceived or affected by the cryptocurrency crash to contact her office.” The alert also “encourage[d] workers in the cryptocurrency industry who may have witnessed misconduct or fraud to file a whistleblower complaint.” The alert, which is only AG James’s most recent action in the space, came after the cryptocurrency market, in general, lost significant value this summer. Prior to this most recent notice, in March 2022, AG James issued a “taxpayer notice,” reminding cryptocurrency investors and their tax advisors “to make sure that they accurately declare and pay taxes on their virtual investments” to avoid any violations of tax law.
AG James has also focused on cryptocurrency exchanges. On October 18, 2021, AG James sent cease and desist letters to two unnamed cryptocurrency platforms and directed three other unnamed platforms to provide information about their activities and products. According to redacted cease and desist letters made publicly available by the NYAG, the two unnamed exchanges are allegedly “unlawfully selling or offering to sell . . . securit[ies] . . . without having registered as required” under New York’s Martin Act, which requires these exchanges to be registered with the Office as brokers, dealers, or salespersons, unless otherwise exempted. The letters also came only weeks after AG James won a $3 million judgment against a cryptocurrency trading platform in New York County State Supreme Court.
On September 26, 2022, AG James joined the securities regulators of seven other states in suing related cryptocurrency companies in New York County State Supreme Court for allegedly failing to register with the state as securities and commodities brokers or dealers and for allegedly misrepresenting their registration status to investors. The defendants have not yet responded to the NYAG’s complaint.
Moreover, on September 13, 2021, AG James settled alleged claims without admission against two related media companies in connection with allegations that they unlawfully sold stock and cryptocurrency without registering them in New York State. In addition to offering and selling stock beginning in April 2020, the two companies allegedly raised more than $30 million from pre-sales of two digital instruments promoted as cryptocurrencies. Pursuant to the agreement, the companies will get credit toward the $479.9 million settlement for payments to the Securities and Exchange Commission (“SEC”) in connection with a related SEC investigation.
AG James has also been active in the consumer financial protection space, particularly with respect to debt collectors and student debt services. Most recently, on August 16, 2022, AG James applauded the U.S. Department of Education for discharging the federal student loan debt of over 4,000 New Yorkers who attended certain for-profit colleges between 2005 and 2016. Earlier this year, AG James also encouraged students who attended other institutions that allegedly inflated their job placement statistics to apply for federal loan discharges, and led a coalition of eight attorneys general in asking President Biden to fully cancel federal student debt writ large. In August 2022, President Biden announced that the Department of Education will cancel $10,000 of student debt for borrowers who meet identified income requirements. The Eighth Circuit Court of Appeals issued an administrative stay pausing the program on October 21.
AG James also secured two agreements earlier this year with federal loan servicers. In the first, one of the country’s largest student loan servicers agreed to cancel $1.85 billion in private student loan debt nationwide, and to pay $95 million in restitution to students and $142.5 million to states. The agreement followed an investigation by 39 attorneys general, including AG James, into whether the servicer allegedly improperly caused students to enter into forbearance plans that were ultimately detrimental to borrowers. In the second, the student loan servicer agreed to automatically review the accounts of approximately 10,000 New Yorkers and credit accounts as appropriate, in order to settle a 2019 lawsuit alleging the servicer mismanaged student debt. In addition to student loan servicing, AG James has also devoted attention to practices of debt collection agencies. This year, AG James has settled claims with two debt collection businesses, enjoining these business from acting as debt collectors in the future. AG James also issued a consumer alert in December aimed at educating consumers about their rights and warning of improper debt collection tactics.
Aside from settling recent cases, AG James has also initiated litigations to enforce consumer protection laws in the financial services area. For example, in April 2022, AG James and the Consumer Financial Protection Bureau filed a lawsuit against a large money transfer provider, alleging the provider violated consumer protection laws, including by failing to timely transfer funds or refund consumers for delayed transfers. In August, the money transfer provider filed a motion to transfer the action from the United States District Court for the Southern District of New York to the Northern District of Texas and to dismiss the complaint. Moreover, in February 2022, state regulators, including AG James, along with the SEC and the U.S. Commodity Futures Trading Commission, brought a lawsuit alleging that a precious metals company and its owner unlawfully solicited nearly $68 million for precious metals and misrepresented fees charged to investors. These litigations are still pending.
IV. Health Care
AG James has continued to focus on inadequately managed properties that threaten tenant and worker safety, health products that endanger children and babies, the opioid epidemic, the COVID-19 pandemic, and reproductive health.
AG James has sought to protect the public from inadequately managed properties that threaten tenant health. For example, in September 2021, AG James and the New York City Department of Investigation indicted four Certified Asbestos Investigators on 19 counts, including felony charges, for allegedly filing false asbestos inspection reports. And in June 2022, AG James agreed to resolve an October 2021 lawsuit against a landlord in Syracuse for allegedly failing to protect children from lead paint. This success comes in the wake of a multi-state call on the Environmental Protection Agency (“EPA”)—which AG James led—to strengthen protections against lead poisoning for children living in low-income communities and communities of color. That same month, AG James reached an agreement with a wireless network operator to help prevent the spread of Legionnaires’ disease, which can be spread by poorly monitored building cooling towers.
AG James has taken other steps involving children’s health. In October 2021, AG James led a coalition of 23 attorneys general to petition the Food and Drug Administration to accelerate the removal of heavy metals from baby food. She also issued an alert to protect children from deceptive cannabis products sold in snack packaging, warning New Yorkers to “remain vigilant” against such products.
AG James has devoted significant attention to the opioid epidemic. In March 2019, AG James filed an extensive lawsuit aiming to hold various manufacturers and distributors accountable for the epidemic. AG James entered three notable settlements in the suit in the last year, with one manufacturer for $523 million and another for $200 million (most of which are earmarked for opioid abatement) and with a pharmaceutical company for $58.5 million. She also sought to bring a previously dismissed pharmaceutical company back into the lawsuit, moving to vacate their dismissal for allegedly making “significant and intentional misrepresentations” to her Office regarding the extent of its role in its subsidiary’s opioids business.
AG James has also urged the CDC to adopt stronger opioid prescription guidelines, and in recent months has distributed over $100 million from settlements with opioid manufacturers and distributors to communities across the State impacted by the epidemic. AG James has also begun to distribute $256 million earmarked for New York City to combat the crisis—the first round of payments from the $1.5 billion that AG James has secured for the State from settlements with opioid manufacturers and distributors.
AG James has also continued to prioritize public health in light of the COVID-19 pandemic. For example, AG James issued a warning letter to a diagnostics company for allegedly misrepresenting its turnaround times for COVID-19 test results, and she launched an investigation into a clinic over reports that it allegedly wrongfully billed New Yorkers for COVID-19 tests. AG James has helped consumers recover over $400,000 who paid for expedited COVID-19 tests but received results later than promised.
Finally, after a draft Supreme Court opinion in Dobbs v. Jackson Health Women’s Health Organization was leaked to the press in May 2022, AG James quickly mobilized around women’s reproductive health issues. AG James and Assembly Member Jessica González-Rojas announced a bill to establish a state program to provide financial resources to abortion providers, which is currently in committee, and offered guidance to protect the privacy of individuals seeking abortions. Following the publication of the Supreme Court’s decision in Dobbs, AG James vowed to keep New York a “safe haven” for those seeking an abortion.
V. Environmental Protection
AG James’s Office continued its environmental activism over the past year, leading other state attorneys general in urging federal agencies to take more aggressive stances on environmental issues, particularly climate change.
The majority of AG James’s actions directed at federal regulations came in the form of letters to various federal actors urging progressive rules and regulations concerning climate and pollution-related topics. For example, on September 14, 2021, AG James, along with 20 state attorneys general, asked Congress to respond to the climate crisis and support environmental justice by funding programs in budget reconciliation legislation. In December 2021, AG James and 15 other Democratic state attorneys general also filed comments in support of the Pipeline and Hazardous Materials Safety Administration’s proposal to suspend a Trump-era rule allowing liquefied natural gas to be shipped in rail tank cars, arguing, in part, that the environmental assessment of the rule “did not adequately consider upstream and downstream effects on greenhouse gas emissions.” On June 30, 2022, in response to the Supreme Court ruling in West Virginia v. EPA, which ruled that the EPA lacked authority to restructure the electric power industry, AG James issued a statement saying that her Office “will continue to be a champion for our environment, our future, and the health of New Yorkers” and “will work to end our nation’s reliance on fossil-fuel power plants that pollute our environment, and move towards clean, renewable, and affordable electricity.” Most recently, on September 20, 2022, AG James announced an agreement with the U.S. Department of Energy (“DOE”) committing DOE to a new timetable for updating energy efficiency standards for 20 categories of common consumer products and commercial equipment, ranging from residential furnaces to laundry machines to electric motors. This agreement resolved a complaint against the DOE filed by the NYAG and a coalition of 17 states in 2020 alleging that the DOE failed to comply with certain deadlines for updating energy efficiency standards set by the Energy Policy and Conservation Act of 1975.
In addition to regulatory advocacy, AG James also filed lawsuits related to environmental protection. On April 28, 2022, AG James and California Attorney General Rob Bonta led a multistate coalition in suing the United States Postal Service for allegedly failing to consider the environmental impact of its new fleet of mail trucks. The lawsuit is currently pending before the Judicial Panel on Multidistrict Litigation, and oral argument the motion to transfer for coordinated pretrial proceedings was denied on October 7, 2022. On March 31, 2022, the offices of AG James and Department of Environmental Conservation Commissioner Basil Seggos announced the indictment of a Kentucky-based freight shipping and trucking company and its Vice President for allegedly dumping hazardous materials in Chenango County and creating fake scale tickets to conceal the alleged disposal.
VI. Labor and Employment
This year, as labor organizing efforts generally have picked up around the state, AG James turned to support local unions. In August 2021, AG James announced that she, along with 16 other attorneys general, asked the U.S. Senate to pass the Protecting the Right to Organize Act of 2021 (“PRO Act”). The bill would allow unions to override “right-to-work” laws in more than two-dozen states, curtail employer intervention in union elections, and introduce new monetary penalties for certain retaliatory actions, among several other labor-friendly reforms. Although unlikely to pass the Senate this year, AG James’s support for the bill indicates her enthusiasm for expanding workers’ rights and union membership. Throughout the past year, AG James has met with young organizers and made several statements in support of a coffeehouse chain’s employees’ ultimately successful union campaign in Buffalo. She also expressed support for a health system’s employees’ decision to strike in late 2021. Looking ahead, AG James has indicated that she plans to work alongside the Service Employees International Union (“SEIU”) to seek stronger protections for nursing home workers in light of staffing, wage, and operations issues that were brought to light during the COVID-19 pandemic.
AG James has been active across the labor and employment area. These efforts include the following:
AG James has also focused on the rights of terminated employees. For example, in October 2021, AG James announced a $2.7 million settlement on behalf of 250 employees of a hotel and conference center after they were allegedly denied wages and terminated without sufficient legal notice under the New York Worker Adjustment and Retraining Notification Act. In May 2022, AG James announced an agreement with a hotel company that would collectively provide 500 previously terminated workers with $2.95 million in severance pay following allegations that non-unionized workers had been promised, but not provided, the same or better benefits as unionized hotel workers, in violation of Section 63(12) of the Executive Law. This year, AG James also brought suit against a religious diocese for allegedly depriving more than 1,100 former employees of pensions through various alleged violations of the New York Not-for-Profit Corporations Law and New York Estates, Powers & Trusts Law. This lawsuit is currently pending.
AG James also settled several wage-and-hour cases this year, including two particularly large settlements in the home healthcare industry:
This year, AG James also reached several smaller settlements related to alleged unpaid wages for apartment building superintendents ($130,000), restaurant workers ($175,000), and construction workers on certain public works contracts ($930,000).
We expect AG James will continue to advance the rights of and protections for workers in New York, as this has consistently been a primary focus for the Office.
* * *
We expect that AG James will continue to pursue an active and progressive agenda in the remainder of 2022. We also anticipate that AG James will continue to work alongside state attorneys general around the country—forming coalitions with Democrats and Republicans alike—on matters of national import, including antitrust, the environment, consumer protection, data privacy, and financial fraud investigations and litigation. Gibson Dunn will continue to monitor the actions of the Office.
 Press Release, N.YS. Attorney General, Attorney General James Sues Donald Trump for Years of Financial Fraud (Sept. 21, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-sues-donald-trump-years-financial-fraud.
 Mem. in Supp. of Pl.s’ Mot. for Prelim. Inj. at 6, New York v. Donald J. Trump, Index No. 452564/2022 (Oct. 13, 2022), NYSCEF No. 38; Order, New York v. Donald J. Trump, Index No. 452564/2022 (Nov. 4, 2022), NYSCEF No. 183.
 Press Release, N.Y.S. Attorney General, Attorney General James Leads Bipartisan Coalition in calling on Congress to Modernize Federal Antitrust Laws (Sept. 20, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-leads-bipartisan-coalition-calling-congress-modernize; Bipartisan Coalition Asks Congress to Modernize Federal Antitrust Laws, Competition Policy Int’l (Sept. 20, 2021), https://www.competitionpolicyinternational.com/bipartisan-coalition-asks-congress-to-modernize-federal-antitrust-laws/.
 Winston Bribach, State Case You Need to Know: Analyzing New York’s 21st Century Antitrust Act, Am. Bar Ass’n (Jun. 22, 2022), https://www.americanbar.org/groups/antitrust_law/resources/newsletters/state-case-new-yorks-21st-century-antitrust-act/.
 Id.; Kate Lisa, NY state Senate-passed antitrust reform expected to die in Assembly, State of Politics (May 25, 2022), https://nystateofpolitics.com/state-of-politics/new-york/politics/2022/05/25/senate-passed-anti-trust-bill-expected-to-die-in-assembly.
 Senate Bill S933A § 340(10)(a)(i)-(ii); NYU Law Program on Corporate Compliance and Enforcement, Developments in Antitrust Law: Keep an Eye on New York (Mar. 16, 2021), https://wp.nyu.edu/compliance_enforcement/2021/03/16/developments-in-antitrust-law-keep-an-eye-on-new-york/.
 Tony Romm, States Sue Facebook as an Illegal Monopoly, Setting Stage for Potential Breakup, Wash. Post (Dec. 9, 2020), https://www.washingtonpost.com/technology/2020/12/09/facebook-antitrust-lawsuit/; Press Release, N.Y.S. Attorney General, AG James Investigating Facebook For Possible Antitrust Violations (Sept. 6, 2020), https://ag.ny.gov/press-release/2019/ag-james-investigating-facebook-possible-antitrust-violations; Press Release, N.Y.S. Attorney General, Attorney General James Announces Antitrust Investigation Into Google (Sept. 9, 2020) https://ag.ny.gov/press-release/2019/attorney-general-james-announces-antitrust-investigation-google.
 Cecilia Kang, States appeal a judge’s decision to throw out their Facebook antitrust case, N.Y. Times (Jan. 14, 2022), https://www.nytimes.com/2022/01/14/technology/facebook-antitrust-case-appeal.html; Lauren Feiner, State AGs appeal dismissal of their antitrust suit against Facebook, CNBC (Jan. 14, 2022), https://www.cnbc.com/2022/01/14/state-ags-appeal-dismissal-of-their-antitrust-suit-against-facebook.html; New York v. Facebook, 549 F. Supp. 3d 6, 14 (D.D.C. 2021); Brief for Appellants, New York v. Facebook, Inc., No. 21-7078, D.C. Cir. (Jan. 14, 2022), Doc. No. 1930765.
 Press Release, N.Y.S. Attorney General, Pharma Bro No More’: Attorney General James Scores Court Victory Against Convicted Criminal Martin Shkreli, Banning Him From Pharmaceutical Industry for Life, Ordering Him to Pay Nearly $65 Million (Jan. 14, 2022), https://ag.ny.gov/press-release/2022/pharma-bro-no-more-attorney-general-james-scores-court-victory-against-convicted.
 Press Release, N.Y.S. Attorney General, Attorney General James Protects Supermarket Choices and Competitive Prices for Upstate New York Residents (Nov. 9, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-protects-supermarket-choices-and-competitive-prices; Rick Moriarty, Price Chopper and Tops Markets complete merger, Syracuse.Com (Nov. 9, 2021), https://www.syracuse.com/business/2021/11/price-chopper-and-tops-markets-complete-merger.html.
 Press Release, N.Y.S. Attorney General, Attorney General James Sues CVS for Harming New York Safety Net Hospitals and clinics by Diverting Millions from Underserved Communities (Jul. 28, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-sues-cvs-harming-new-york-safety-net-hospitals-and-clinics.
 Press Release, N.Y.S. Attorney General, Attorney General James Releases Top 10 Consumer Complaints of 2021 (Mar. 7, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-releases-top-10-consumer-complaints-2021.
 Press Release, N.Y.S. Attorney General, Attorney General James Announces $600,000 Agreement with EyeMed After 2020 Data Breach (Jan. 24, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-announces-600000-agreement-eyemed-after-2020-data-breach.
 N.Y. Gen. Bus. Law § 899; $600,000 Reasons to Review Your SHIELD Act Compliance Program: NY Attorney General Announces Significant Settlement Stemming From Email Data Breach, Nat’l L. Rev. (Feb. 16, 2022), https://www.natlawreview.com/article/600000-reasons-to-review-your-shield-act-compliance-program-ny-attorney-general.
 Press Release, N.Y.S. Attorney General, Attorney General James Recovers $1.25 Million for Consumers Affected by Carnival Cruise Line’s Data Breach (June 23, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-recovers-125-million-consumers-affected-carnival-cruise; see also Michael R. Graif, New York Attorney General: Data Breaches Will Cost You, Mintz Levin: Insights Center (Aug. 1, 2022), https://www.mintz.com/insights-center/viewpoints/2826/2022-08-01-new-york-attorney-general-data-breaches-will-cost-you.
 Press Release, N.Y.S. Attorney General, Attorney General James Secures $400,000 From Wegmans After Data Breach Exposed Consumers’ Personal Information (June 30, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-secures-400000-wegmans-after-data-breach-exposed-consumers; see also New York Attorney General: Data Breaches Will Cost You, supra note 12.
 Id.; Cozen O’Connor, AG James Recovers $400,000 From Webmans Over Alleged Data Security Lapses, JDSupra (July 8, 2022), https://www.jdsupra.com/legalnews/ag-james-recovers-400-000-from-wegmans-1636011/.
 Press Release, N.Y.S. Attorney General, Attorney General James Investigating Instagram’s Impact on Young People (Nov. 18, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-investigating-instagrams-impact-young-people; Press Release, N.Y.S. Attorney General, Attorney General James Launches Investigations Into Social Media Companies for Role in Buffalo Attack (May 18, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-launches-investigations-social-media-companies-role.
 Press Release, N.Y.S. Attorney General, Attorney General James Alerts 17 Companies to “Credential Stuffing” Cyberattacks Impacting More Than 1.1 Million Consumers (Jan. 5, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-alerts-17-companies-credential-stuffing-cyberattacks; N.Y.S. Attorney General, Bureau of Internet & Tech. Bus. Guide for Credential Stuffing Attacks (Jan. 5, 2022), https://ag.ny.gov/sites/default/files/businessguide-credentialstuffingattacks.pdf.
 Press Release, N.Y.S. Attorney General, INVESTOR ALERT: Attorney General James Urges New Yorkers Deceived by Crypto Platforms to Report Concerns to OAG (Aug. 1, 2022), https://ag.ny.gov/press-release/2022/investor-alert-attorney-general-james-urges-new-yorkers-deceived-crypto-platforms.
 Press Release, N.Y.S. Attorney General, TAXPAYER NOTICE: Attorney General James Reminds Crypto Investors to Pay Taxes on Virtual Investments (Mar. 23, 2022), https://ag.ny.gov/press-release/2022/taxpayer-notice-attorney-general-james-reminds-crypto-investors-pay-taxes-virtual.
 Press Release, N.Y.S. Attorney General, Attorney General James Directs Unregistered Crypto Lending Platforms to Cease Operations In New York, Announces Additional Investigations (May 23, 2022), https://ag.ny.gov/press-release/2021/attorney-general-james-directs-unregistered-crypto-lending-platforms-cease.
 Redacted Letter (October 18, 2021), https://ag.ny.gov/sites/default/files/cease_letter_redacted.pdf.
 Press Release, N.Y.S. Attorney General, Attorney General James Shuts Down Virtual Currency Trading Platform and Stops Cryptocurrency CEO From Continuing Fraudulent Conduct (Sept. 13, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-shuts-down-virtual-currency-trading-platform-and-stops.
 People of the State of New York, by Letitia James, Attorney General of the State of New York v. Nexo Inc. et al, Index No. 452610/2022 , NYSCEF No. 2 (N.Y. Supt. Ct. N. Y. Cnty. Sept. 26, 2022); see also Press Release, Attorney General James Sues Cryptocurrency Platform for Operating Illegally and Defrauding Investors (Sept. 26, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-sues-cryptocurrency-platform-operating-illegally-and.
 Press Release, N.Y.S. Attorney General, Attorney General James Secures Nearly Half a Billion Dollars to Resolve Illegal Stock and Cryptocurrency Sales (Sept. 13, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-secures-nearly-half-billion-dollars-resolve-illegal-stock.
 Press Release, N.Y.S. Attorney General, Attorney General James Announces Debt Relief for Students who Attended ITT Educational Services For-Profit Colleges (Aug. 16, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-announces-debt-relief-students-who-attended-itt.
 Id.; see also Press Release, N.Y.S. Attorney General, Attorney General James Urges Former Students Deceived by DeVry University to Apply for Federal Loan Discharge (Mar. 31, 2022), available at https://ag.ny.gov/press-release/2022/attorney-general-james-urges-former-students-deceived-devry-university-apply; Press Release, N.Y.S. Attorney General, Attorney General James Calls for Full Cancelation of Federal Student Loan Debt (May 4, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-calls-full-cancelation-federal-student-loan-debt.
 Press Release, The White House, Fact Sheet: President Biden Announces Student Loan Relief for Borrowers Who Need It Most (Aug. 24, 2022), https://www.whitehouse.gov/briefing-room/statements-releases/2022/08/24/fact-sheet-president-biden-announces-student-loan-relief-for-borrowers-who-need-it-most./.
 Order, Nebraska v. Biden, No. 22-3179 (8th Cir. Oct. 21, 2022).
 Press Release, N.Y.S. Attorney General, Attorney General James Secures $1.85 Billion From Deceptive Student Loan Servicer Navient (Jan. 13, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-secures-185-billion-deceptive-student-loan-servicer.
 Press Release, N.Y.S. Attorney General, Attorney General James Secures Student Debt Relief for Thousands of New Yorkers (Apr. 27, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-secures-student-debt-relief-thousands-new-yorkers; see also Press Release, N.Y.S. Attorney General, AG James Sues Student Loan Servicer For Mismanaging Loan Forgiveness Program (Oct. 3, 2019), available at https://ag.ny.gov/press-release/2019/ag-james-sues-student-loan-servicer-mismanaging-loan-forgiveness-program.
 Press Release, N.Y.S. Attorney General, Attorney General James and CFPB Shut Down Predatory Debt Collection Operation (May 23, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-and-cfpb-shut-down-predatory-debt-collection-operation; Joint Stipulation for Entry of Proposed Stipulated Final Judgment and Order, CFTB v. JPL Recovery Solutions, LLC, No. 20-cv-1217 (W.D.N.Y. May 23, 2022), https://ag.ny.gov/sites/default/files/jpl_stipulation_stipulated_judgment_5.23.2022_combined.pdf; Press Release, N.Y.S. Attorney General, Attorney General James Shuts Down Illegal Debt Collection Businesses, Recovers $1.2 Million (Nov. 23, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-shuts-down-illegal-debt-collection-businesses-recovers-12.
 Press Release, N.Y.S. Attorney General, CONSUMER ALERT: Attorney General James Urges Consumers to Be Aware of Rights when Faced with Attempts to Collect Upon Consumer Debt (Dec. 1, 2021), https://ag.ny.gov/press-release/2021/consumer-alert-attorney-general-james-urges-consumers-be-aware-rights-when-faced.
 Press Release, N.Y.S. Attorney General, Attorney General James and Consumer Financial Protection Bureau Sue Major International Money Transfer Provider for Violating Consumer Protection Laws (Apr. 21, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-and-consumer-financial-protection-bureau-sue-major; see also Stacy Cowley, MoneyGram Sued for Allegedly Delaying Transfers and Witholding Refunds, N.Y. Times (Apr. 21, 2022), https://www.nytimes.com/2022/04/21/business/moneygram-lawsuit-new-york-ag-cfpb.html.
 CFTB v. MoneyGram International, Inc., 22-cv-3256 (S.D.N.Y. Aug. 4, 2022). AG James and the CFTB’s response to the consolidated motion is due September 19, 2022.
 Press Release, N.Y.S. Attorney General, Attorney General James Sues Precious Metals Company and Owner for Defrauding Seniors Out of $68 Million (Feb. 1, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-sues-precious-metals-company-and-owner-defrauding-seniors; Mark Schoeff Jr., Regulators charge metals dealer with $67 million fraud, Investment News (Feb. 1, 2022) https://www.investmentnews.com/regulators-charge-metals-dealer-with-67-million-fraud-216709.
 Press Release, N.Y.S. Attorney General, Attorney General James and DOI Commissioner Garnett Announce Indictment of Four Asbestos Investigators for Filing Fraudulent Inspection Reports (Sept. 2, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-and-doi-commissioner-garnett-announce-indictment-four.
 Press Release, N.Y.S. Attorney General, Attorney General James Shuts Down Syracuse Landlord That Exposed Children to Lead Poisoning (June 13, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-shuts-down-syracuse-landlord-exposed-children-lead.
 Press Release, N.Y.S. Attorney General, Attorney General James Leads Coalition Urging EPA to Strengthen Protections Against Childhood Lead Poisoning (Mar. 17, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-leads-coalition-urging-epa-strengthen-protections-against.
 Press Release, N.Y.S. Attorney General, Attorney General James Reaches Agreement with Verizon to Prevent Legionnaires’ Disease (June 2, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-reaches-agreement-verizon-prevent-legionnaires-disease.
 Press Release, N.Y.S. Attorney General, Attorney General James Leads Coalition Urging FDA to Accelerate Actions to Protect Children From Toxic Metals in Baby Food (Oct. 21, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-leads-coalition-urging-fda-accelerate-actions-protect.
 Press Release, N.Y.S. Attorney General, CONSUMER ALERT: Attorney General James Issues Alert to Protect Children From Deceptive Cannabis Products Sold in Snack Packaging (Oct. 26, 2021), https://ag.ny.gov/press-release/2021/consumer-alert-attorney-general-james-issues-alert-protect-children-deceptive.
 Press Release, N.Y.S. Attorney General, Attorney General James Concludes New York’s Opioid Trial (Dec. 14, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-concludes-new-yorks-opioid-trial.
 Press Release, N.Y.S. Attorney General, Attorney General James Secures $523 Million from Top Opioid Manufacturer Teva, Bringing Total Funds for New Yorkers to More Than $2 Billion (Nov. 3, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-secures-523-million-top-opioid-manufacturer-teva-bringing; Press Release, N.Y.S. Attorney General, Attorney General James Uncovers Evidence That Teva Pharmaceuticals Lied to Evade Accountability for Opioid Crisis in New York (Jul. 11, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-uncovers-evidence-teva-pharmaceuticals-lied-evade; Press Release, N.Y.S. Attorney General, Attorney General James Secures $58.5 Million from Top Opioid Manufacturer Mallinckrodt for Fueling Opioid Crisis (June 16, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-secures-585-million-top-opioid-manufacturer-mallinckrodt; Press Release, N.Y.S. Attorney General, Attorney General James Delivers Up to $200 Million to Help New York Combat Opioid Crisis, Allergan Agrees Not to Sell Opioids (Dec. 8, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-delivers-200-million-help-new-york-combat-opioid-crisis.
 Press Release, N.Y.S. Attorney General, Attorney General James Urges CDC to Adopt Stronger Opioid Prescription Guidelines (Apr. 14, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-urges-cdc-adopt-stronger-opioid-prescription-guidelines.
 E.g., Press Release, N.Y.S. Attorney General, Attorney General James Distributes First Funds from Historic Opioid Settlements to Finger Lakes Region (Apr. 19, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-distributes-first-funds-historic-opioid-settlements-finger.
 Press Release, N.Y.S. Attorney General, Attorney General James and Mayor Adams Fight Opioid Crisis with First of $256 Million in Payments for New York City (Apr. 21, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-and-mayor-adams-fight-opioid-crisis-first-256-million.
 Press Release, N.Y.S. Attorney General, Attorney General James Issues Warning to LabQ Diagnostics to Stop Misrepresenting Turnaround Times for COVID-19 Test Results (Dec. 21, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-issues-warning-labq-diagnostics-stop-misrepresenting; Press Release, N.Y.S. Attorney General, CONSUMER ALERT: Attorney General James Launches Investigation Into CareCube for Wrongfully Billing New Yorkers for COVID-19 Tests (Jan. 6, 2022), https://ag.ny.gov/press-release/2022/consumer-alert-attorney-general-james-launches-investigation-carecube-wrongfully.
 See Press Release, N.Y.S. Attorney General, Attorney General James Recovers Over $400,000 for Consumers Unfairly Charged for Expedited COVID-19 Tests (Feb. 14, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-recovers-over-400000-consumers-unfairly-charged-expedited; Press Release, N.Y.S. Attorney General, Attorney General James Recoups $122,000 for Consumers Charged for Expedited COVID-19 Tests That Were Late (July 7, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-recoups-122000-consumers-charged-expedited-covid-19-tests.
 Press Release, N.Y.S. Attorney General, Attorney General James Takes Action to Expand Abortion Access (May 9, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-takes-action-expand-abortion-access; Press Release, N.Y.S. Attorney General, CONSUMER ALERT: Attorney General James Provides Guidance to Protect the Digital Privacy of People Seeking Abortion Care (May 13, 2022), https://ag.ny.gov/press-release/2022/consumer-alert-attorney-general-james-provides-guidance-protect-digital-privacy.
 Press Release, N.Y.S. Attorney General, Attorney General James Calls for State Constitutional Amendment for Abortion (May 7, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-calls-state-constitutional-amendment-abortion.
 Press Release, N.Y.S. Attorney General, Attorney General James Calls on Congress to Prioritize Funding for Programs to Address Climate Crisis, Environmental Injustice (Sept. 14, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-calls-congress-prioritize-funding-programs-address-climate.
 Notice of Proposed Rulemaking – Hazardous Materials: Suspension of HMR Amendments Authorizing Transportation of Liquefied Natural Gas by Rail, Docket No. PHMSA-2018-0025 (HM-264) (Dec. 23, 2021), https://portal.ct.gov/-/media/AG/Press_Releases/2021/Comments-of-State-Attorneys-General-on-Proposed-Suspension-Rule-12-23-21.pdf.
 Press Release, Attorney General James Issues Statement on SCOTUS Decision Limiting EPA Authority to Regulate Power Plant Emissions (June 30, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-issues-statement-scotus-decision-limiting-epa-authority
 Press Release, Attorney General James Helps Secure New Federal Energy Standards for American Families (Sept. 20, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-helps-secure-new-federal-energy-standards-american.
 Press Release, N.Y.S. Attorney General, Attorney General James Sues U.S. Postal Service For Failing to Consider Environmental Impact of New Trucks (Apr. 28, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-sues-us-postal-service-failing-consider-environmental.
 In re U.S. Postal Services Next Generation Delivery Vehicle Acquisitions Program Record of Decision Litig., Docket No. 3046 (J.P.M.L. Jul, 22, 2022); Dkt. 54, Order Denying Transfer, MDL No. 3046 (Oct. 7, 2022).
 Press Release, N.Y.S. Attorney General, Attorney General James and DEC Commissioner Seggos Announce Indictment of Kentucky Corporation and its Principal for Illegal Disposal of Hazardous Railroad Ties (Mar. 31, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-and-dec-commissioner-seggos-announce-indictment-kentucky.
 Press Release, N.Y.S. Attorney General, Attorney General James Calls on the U.S. Senate to Strengthen Protections for Working Americans By Passing PRO Act (Aug. 11, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-calls-us-senate-strengthen-protections-working-americans.
 Actions – H.R.842 – 117th Congress (2021-2022): Protecting the Right to Organize Act of 2021, H.R.842, 117th Cong. (2021); Don Gonyea, House Democrats Pass Bill That Would Protect Worker Organizing Efforts, NPR (Mar. 8, 2021), https://www.npr.org/2021/03/09/975259434/house-democrats-pass-bill-that-would-protect-worker-organizing-efforts.
 Levi Sumagaysay, Biden Marks Labor Day with Call for Congress to Pass PRO Act, MarketWatch (Sept. 3, 2022), https://www.marketwatch.com/story/biden-marks-labor-day-with-call-for-congress-to-pass-pro-act-11662148894; Nick Niedzwiadek & Eleanor Miller, Unions’ Post-Reconciliation PRO Act Push, Politico (Aug. 15, 2022), https://www.politico.com/newsletters/weekly-shift/2022/08/15/unions-post-reconciliation-pro-act-push-00051726.
 Press Release, N.Y.S. Attorney General, Attorney General James Applauds Buffalo Starbucks Employees’ for Forming Company’s First Union in the Nation (Dec. 10, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-applauds-buffalo-starbucks-employees-forming-companys; Press Release, N.Y.S. Attorney General, Attorney General James Applauds Buffalo Starbucks Employees’ for Forming Company’s Second Union in the Nation (Jan. 10, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-applauds-buffalo-starbucks-employees-forming-companys.
 Press Release, N.Y.S. Attorney General, Attorney General James Demands Fair Treatment for CWA Workers on Strike in Buffalo (Oct. 8, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-demands-fair-treatment-cwa-workers-strike-buffalo; Press Release, N.Y.S. Attorney General, Attorney General James Visits Starbucks Workers in Buffalo (Apr. 12, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-visits-starbucks-workers-buffalo; Press Release, N.Y.S. Attorney General, Attorney General James Releases Statement on Tentative Agreement Between CWA and Catholic Health System (Nov. 4, 2021) https://ag.ny.gov/press-release/2021/attorney-general-james-releases-statement-tentative-agreement-between-cwa-and.
 Press Release, N.Y.S. Attorney General, Attorney General James, 1199SEIU Call for Stronger Protections for Nursing Home Workers (Mar. 21, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-1199seiu-call-stronger-protections-nursing-home-workers.
 Press Release, N.Y.S. Attorney General, Attorney General James Delivers $600,000 to Survivors of Sexual Harassment and Discrimination at Restaurants Owned by Famed Chef Mario Batali and Joseph Bastianich (Jul. 23, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-delivers-600000-survivors-sexual-harassment-and.
 Press Release, N.Y.S. Attorney General, Attorney General James Secures Settlement for Victims of Sexual Harassment, Discrimination, and Wage Theft at NYC Bar (Jul. 13, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-secures-settlement-victims-sexual-harassment.
 See Rachel Scharf, NY AG Warns NFL of Workplace Harassment Crackdown Law360 (April 6, 2022), https://www.law360.com/employment-authority/articles/1481443/ny-ag-warns-nfl-of-workplace-harassment-crackdown-; Press Release, N.Y.S. Attorney General, Attorney General James Demands NFL Address Gender-Based Discrimination (Apr. 6, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-demands-nfl-address-gender-based-discrimination.
 Press Release, N.Y.S. Attorney General, Attorney General James Files Lawsuit Against Amazon for Failing to Protect Workers During COVID-19 Pandemic (Feb. 17, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-files-lawsuit-against-amazon-failing-protect-workers; People of the State of New York v. Amazon.com, Inc. et al., Index No. 450362/2021, NYSCEF No. 163 (N.Y. Supt. Ct. N. Y. Cnty. Oct. 15, 2021); People of the State of New York v. Amazon.com, Inc. et al., Index No. 450362/2021, NYSCEF No. 171 (N.Y. Supt. Ct. N. Y. Cnty. Oct. 22, 2021); People of the State of New York v. Amazon.com, Inc. et al., No. 2021-03934, NYSCEF No. 37 (1st Dep’t May 10, 2022); People of the State of New York v. Amazon.com, Inc. et al., No. 2021-03934, NYSCEF No. 48 (1st Dep’t Sept. 13, 2022).
 People of the State of New York v. Amazon.com, Inc. et al., No. 2021-03934, NYSCEF No. 37 (1st Dep’t May 10, 2022).
 Press Release, N.Y.S. Attorney General, Attorney General James Protects Long Island Workers Unlawfully Fired During COVID-19 Pandemic (Sept. 22, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-protects-long-island-workers-unlawfully-fired-during-covid.
 See, e.g., Hannah Redmond, Labor Law Lessons In amazon’s NY COVID Suit Win, Law360 (June 17, 2022), https://www.law360.com/employment-authority/articles/1502844/labor-law-lessons-in-amazon-s-ny-covid-suit-win-.
 Press Release, N.Y.S. Attorney General, Attorney General James, State Senator Mayer Deliver $2.7 Million to Westchester Hotel Workers Unlawfully Fired (Oct. 27, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-state-senator-mayer-deliver-27-million-westchester-hotel.
 Press Release, N.Y.S. Attorney General, Attorney General James Recovers More Than $2.9 Million for Hundreds of New York City Marriott Workers Denied Full Severance Pay (May 5, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-recovers-more-29-million-hundreds-new-york-city-marriott.
 Press Release, N.Y.S. Attorney General, Attorney General James Sues to Protect St. Clare’s Hospital Retirees (May 24, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-sues-protect-st-clares-hospital-retirees.
 People of the State of New York, By Letitia James, Attorney General of the State of New York et al., v. Roman Catholic Diocese of Albany, New York et al., Index No. 2022-830 (N.Y. Sup. Ct. Schenectady Cnty. 2022).
 Press Release, N.Y.S. Attorney General, Attorney General James and NYC Department of Consumer and Worker Protection Recover Up to $18.8 Million in Unpaid Wages for 12,000 Home Health Aides (Nov. 16, 2021), https://ag.ny.gov/press-release/2021/attorney-general-james-and-nyc-department-consumer-and-worker-protection-recover.
 Press Release, N.Y.S. Attorney General, Attorney General James Secures Nearly $7 Million From Home Health Agencies for Cheating Workers and Medicaid Fraud (Mar. 25, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-secures-nearly-7-million-home-health-agencies-cheating.
 Press Release, N.Y.S. Attorney General, Attorney General James Recovers $130,000 in Stolen Wages for Unpaid Building Superintendents in Queens (Mar. 15, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-recovers-130000-stolen-wages-unpaid-building; Press Release, N.Y.S. Attorney General, Attorney General James Recovers $175,000 in Stolen Wages for Manhattan Pizzeria Workers (Apr. 29, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-recovers-175000-stolen-wages-manhattan-pizzeria-workers; Press Release, Attorney General James and DOI Commissioner Strauber Deliver $900,000 to 200 NYCHA Construction Workers Denied Fair Pay (Apr. 4, 2022), https://ag.ny.gov/press-release/2022/attorney-general-james-and-doi-commissioner-strauber-deliver-900000-200-nycha.
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