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I'S) David Medeiros € @DavidMedeiros - Jan 12 (A eee NOTICE OF ANTICIPATED FEDERAL LITIGATION & DEMAND FOR PRESERVATION OF EVIDENCE Dear Attorney General Tong, This letter serves as formal notice that David Medeiros / ABI Resources anticipates filing federal litigation regarding Medicaid fraud and Civil Rights violations within the CT Department of Social Services (DSS). YOU ARE HEREBY DIRECTED TO PRESERVE ALL RECORDS, including but not limited to: The "Ghost Registry": Any database, Excel sheet, or SQL server log related to the "ABI Waiver Provider Registry" and any "audit logs" of changes made to this registry from 2023-Present. Communications: All emails, Teams chats, Slack messages, and text messages sent or received by DSS leadership (including Manisha Juthani) containing the keywords: "David Medeiros," "ABI Resources," "MuckRock," "Steering," "Kickback," or "Portal." Metadata: You must preserve server-side metadata, deleted item recovery bins, and backup tapes. WARNING: Failure to preserve these records after this notice will result in a motion for Spoliation Sanctions under Fed. R. Civ. P. 37(e), seeking an adverse inference jury instruction against the State.