Health Clinic Suing City

MER-L-000574-23 03/27/2023 10:37:33 AM Pg 1 of 19 Trans ID: LCV20231037564
TRENK ISABEL SIDDIQI

& SHAHDANIAN P.C.
290 W. Mt. Pleasant Avenue, Suite 2370
Livingston, NJ 07039
Richard D. Trenk, Esq. (016951982)
[email protected]
Attorneys for Plaintiff Kaplan Group LLC dba Medical Home Pharmacy
KAPLAN GROUP LLC doing business as SUPERIOR COURT OF NEW JERSEY

MEDICAL HOME PHARMACY, LAW DIVISION: MERCER COUNTY
Plaintiff, Docket No.: MER-L-
v. Civil Action
CITY OF TRENTON, COMPLAINT and JURY DEMAND
Defendant.
Plaintiff Kaplan Group LLC doing business as Medical Home Pharmacy (“Kaplan” or
“Plaintiff”), by way of Complaint against Defendant City of Trenton (the “City” or the
“Defendant”), respectfully states and alleges as follows:
THE PARTIES
1. Kaplan is a licensed pharmacy with its principal place of business located at 828 N.
Olden Avenue in Trenton, New Jersey.
2. Kaplan is also the owner of the property located at 828 N. Olden Avenue in Trenton,
New Jersey (the “Property”).
3. The City is a municipal corporation of the State of New Jersey with its principal
offices at 319 East State Street in Trenton, New Jersey.

BACKGROUND
4. Beginning in March 2020 and continuing through the present, the COVID 19
Worldwide Pandemic impacted the entire World.
5. The City through the Mayor and Administration including Director of Health,
Director of Emergency Management and Business Administrator took various emergency steps to
serve their constituents by contracting with Kaplan for the performance of COVID-19 testing, the
purchase of COVID-19 test kits with training for COVID-19 testing, and use and occupancy of
space at property owned by Kaplan for a city-run neighborhood clinic (the “City-Run
Neighborhood Clinic”).
6. Now, after Kaplan’s diligence and efforts to provide the support, resources, and
leadership, the City is refusing to meet its contractual obligation with Kaplan by refusing to
compensate for the services and goods Kaplan provided to the City and its residents.
7. Instead, the City has allowed its own internal political disputes and dysfunction1 to
result in the its inability to meet its financial obligations, including its contractual obligations to
Kaplan for the services and goods rendered for the benefit of the City’s residents during a time
when public health was critical and of the utmost concern.
8. Kaplan and its workers were frontline heroes who saved lives to help the City and
its residents.
1
See e.g. Trenton Budget Concerns Mounting, City Council Set for Hearing, Insider NJ, available
at https://www.insidernj.com/press-release/trenton-budget-concerns-mounting-city-council-set-
for-hearing/ (dated Oct. 18, 2022); State Initiates ‘Direct Operational Oversight’ of Embattled
N.J.’s City Water Utility, Kevin Shea, N.J.com, available at
https://www.nj.com/mercer/2022/10/state-initiates-direct-operational-oversight-of-embattled-nj-
citys-water-utility.html (dated Oct. 12, 2022).
2
4887-7526-2040, v. 1
A. The Contract to Provide COVID-19 Testing for City of Trenton Residents
9. The City issued bid specifications seeking to award a Contract to Provide COVID-
19 Testing for City of Trenton Residents (the “Emergency COVID Testing Contract”) with a bid
submission date of September 3, 2020.
10. As set forth in the City’s bid specifications, the Emergency COVID Testing
Contract required that bidders provide all staff, personal protection equipment, COVID-19 testing
kits, supplies, refrigeration, infrastructure and all other materials and services need to both conduct
patient COVID-19 tests and to collect and store data based upon the performance of such COVID-
19 tests.
11. On September 3, 2020, Kaplan submitted a bid in response to the City’s bid
specifications in the amount of $90.00 per test.
12. On November 24, 2020, the City Council for the City adopted Resolution 20-690
awarding an Emergency COVID Testing Contract to Kaplan at the bid price of $90.00 per test.
13. At the City Council meeting, the City’s Business Administrator Adam E. Cruz
explained to the members of the City Council that:
The insurance is not required. It will just be a benefit for the City if
somebody brings their insurance card so that the cost of the $90 will
not go against the $200,000 but they will charge the insurance
company. However, it is not required. Anyone can go to the testing
site and not have the insurance card with them or insurance
information and they will be treated just like everyone else.
A video recording of the November 24, 2020 City Council meeting is available at:
https://www.youtube.com/watch?v=-dTW6RKHROk with the discussion of Resolution 20-690
beginning at 1:37:35.
14. Pursuant to the Emergency COVID Testing Contract, Kaplan proceeded to perform
COVID-19 tests for the City.
3
4887-7526-2040, v. 1
15. Each month, Kaplan issued to the City an invoice for the amount due based upon
the number to COVID-19 tests performed for the City.
16. The City has failed to issue payment for the following invoices for COVID-19 tests
performed by Kaplan:
Invoice Number Invoice Date Invoice Amount
32 August 2, 2022 $25,920.00
33 August 31, 2022 $19,170.00
38 September 30, 2022 $19,800.00
49 November 30, 2022 $17,1000
50 December 30, 2022 $17,370.00
Total Unpaid Invoices $99,360.00
17. A total of $99,360.00 remains due from the City to Kaplan for the performance of
COVID-19 tests pursuant to the Emergency COVID Testing Contract.
B. The Sale of COVID-19 Testing Kits to the City of Trenton
18. In Mid December 2021 at the height of the Omicron Variant outbreak, Grady Griffin
(“Griffin”), the Acting Director of the City’s Office of Emergency Management and Adam Cruz
(“Cruz”), the City’s Business Administrator requested the purchase of 30,000 COVID-19 test kits
from Kaplan.
19. Due to the number of test kits requested, Kaplan advised Cruz that the City would have
to issue an initial deposit for Kaplan to proceed with an order of that size.
20. Rather than proceed with a payment for an initial deposit, Cruz advised that the City
would reduce the number of COVID-19 test kits for purchase from 30,000 to 10,000 COVID-19
test kits.
4
4887-7526-2040, v. 1
21. On December 24, 2021, Kaplan via text message to Griffin and Cruz advised that the
costs of the COVID-19 test kits was $45 per test kit, which would include all licensing, training
for City staff to administer the test kits, the costs related to the reporting of the test results from
the test kits, and the purchase of equipment such as iPads and printers for the City to use with the
COVID-19 test kits.
22. On December 26, 2021, Kaplan issued an invoice to the City for the 10,000 COVID-
19 test kits for $450,000.
23. On December 26, 2021, Kaplan conducted the training to the City employees as to how
to perform the COVID-19 tests and the procedures for obtaining and recording the results from
the COVID-19 tests.
24. On or about January 4, 2022, Kaplan delivered the 10,000 COVID-19 test kits along
with the equipment such as iPads and printers for the City to use with the COVID-19 test kits at
the City-Run Neighborhood Clinic located at the Property.
25. Specifically, Kaplan deposited the COVID-19 test kits in the storage area shared by
Kaplan and the City on the Property.
26. The City took 6,000 of the 10,000 COVID-19 test kits and moved them directly into its
space in the Property along with the equipment provided by Kaplan.
27. Following receipt of the COVID-19 test kits, the City requested that Kaplan issue two
(2) separate invoices for the test kits with each invoice for 5,000 of the total 10,000 test kits
provided.
28. In an effort to reduce the cost per COVID-19 test kit and provide the City a savings on
the total purchase for the test kits, Kaplan separated the setup and training fees from the per
5
4887-7526-2040, v. 1
COVID-19 test kit price at $40 per test kit instead of $45 per test kit and $25,000 for the setup and
training fees.
29. On January 31, 2022, Kaplan issued to the City the first of the two (2) invoices for the
COVID-19 test kits in the amount of $225,000 for 5,000 test kits at $40 per test kit and the setup
and training fee of $25,000.
30. On March 14, 2022, the Mayor issued Executive Order 22-01 for the City of Trenton
Authorizing Matters and Services Critical to the Health, Safety, and Welfare of Trenton Residents.
31. Specifically, Executive Order 22-01 noted that due to the medical leave of the City
Clerk and the inability of the City Council to address various issues pertaining to the health, safety,
and welfare of Trenton residents authorizing various actions.
32. Paragraph 1 of Executive Order 22-01 specifically authorized payment for the first
invoice from Kaplan, LLC for the purchase of the COVID-19 test kits stating:
Authorizing payment for a contract with Kaplan Group

LLC/Medical Home Pharmacy, 828 North Olden Avenue, Trenton,
New Jersey 08638 which was awarded on an emergency basis to
provide COVID-19 tests, licensing, training, and reporting for the
Department of Health personnel to render services to protect the
health and welfare of the City of Trenton’s residents in an amount
not to exceed $225,000.00.
A copy of Executive Order 22-0212 is annexed hereto as Exhibit “A.”
33. Notwithstanding the Mayor’s issuance of Executive Order 22-01, the City never issued
any payment to Kaplan, LLC for the COVID-19 test kits.
34. In mid-April 2022, Kaplan provided to the City 3,600 over the counter COVID-19 test
kits which the City exchanged for 2,000 of the COVID-19 test kits previously provided.
2
A copy of Executive Order 22-01 is also available on the City of Trenton website at:
https://www.trentonnj.org/documentcenter/view/6672
6
4887-7526-2040, v. 1
35. On August 1, 2022, Kaplan issued the second invoice for the COVID-19 test kits in the
amount of $200,000 for 5,000 COVID-19 test kits at $40 per test kit.
36. The City also failed to issue payment under the second invoice for the COVID-19 test
kits.
C. The Lease Agreement for the Property at 828 North Olden Avenue, Suite 2, Trenton,
New Jersey
37. On October 31, 2018, Kaplan entered into a lease agreement with Ampersand Health
Management, LLC (“Ampersand”) whereby Ampersand leased the space designated as Suite 2 on
the Property owned by Kaplan.
38. Pursuant to the lease agreement between Kaplan and Ampersand (the “Ampersand
Lease”), Ampersand leased 3,500 square feet to operate medical offices for a term of ten (10)
years.
39. Paragraph 5 of the Ampersand Lease set forth the rent schedule due under the
Ampersand Lease. Specifically, this provision contained the following rent table:
Period Per Year Per Month
Months 1-4 $0.00 $0.00
Months 5-16 $77,000.00 $6,416.66
Months 17-28 $78,540.00 $6,416.66
Months 29-40 $80,110.80 $6,675.89
Months 41-52 $81,713.02 $6,809.41
Months 53-64 $83,347.28 $6,945.60
Months 65-76 $85,014.22 $7,084.51
Months 77-88 $86,714.51 $7,226.20
7
4887-7526-2040, v. 1
Months 89-100 $88,448.80 $7,370.73
Months 101-112 $90,217.77 $7,518.14
Months 113-124 $92,022.13 $7,668.50
40. Ampersand, however, was ultimately unable to proceed with the opening of the
proposed medical offices at the Property.
41. Nevertheless, Ampersand continued to pay the monthly rent due under the Ampersand
Lease in conformance with its obligation to comply with the terms set forth in the Ampersand
Lease and avoid the termination penalties set forth in the Ampersand Lease.
42. In September 2021, the City approached Kaplan regarding the use of space at the
Property in order to open a City-Run Neighborhood Clinic to provide COVID-19 services.
43. Kaplan contacted Ampersand and advised of the City’s interest in utilizing the space
being leased to Ampersand under the Ampersand Lease.
44. Ampersand agreed to allow the City to utilize the space at the Property provided that
they offset a portion of the monthly rents being paid from Ampersand to Kaplan under the
Ampersand Lease and authorized Kaplan to negotiate a sub-lease agreement between Ampersand
and the City.
45. By November 2021, the City was provided access to Suite 2 on the Property even prior
to the formal execution of a sub-lease agreement.
46. During this time, the City was able to perform renovations, install signage and begin
setting up the City-Run Neighborhood Clinic without having to pay any rent at all.
8
4887-7526-2040, v. 1
47. In fact, on January 19, 2022, the City conducted a “soft-opening” at the Property for
the City-Run Neighborhood Clinic3 even though a sub-lease agreement had not been finalized.
48. On February 1, 2022, the City executed a Sublease Agreement for use of the space at
the Property for a term from February 1, 2022 through December 31, 2022 at a rate of $4,000 per
month. See Exhibit “B” annexed hereto.
49. As stated in Paragraph 5 of the Sublease Agreement, the remaining balance of the
monthly rent due from Ampersand to Kaplan under the Ampersand Lease would continue to be
paid by Ampersand.
50. Prior to the expiration of the Sublease Agreement, Ampersand contacted Kaplan to
advise that they had identified a prospective tenant that wanted to take over the Ampersand Lease
for use of Suite 2 at the Property.
51. Kaplan advised Ampersand that it could not terminate the Sublease Agreement with
the City until the expiration of the term set forth in the Sublease Agreement.
52. Kaplan proceeded to advise the City that a new tenant had proposed to take over the
Ampersand Lease once the Sublease Agreement expired.
53. In response, the City requested to continue utilizing the space at the Property for the
City-Run Neighborhood Clinic.
54. Specifically, the City’s Director of Health and Human Services advised Kaplan that
the City would negotiate a lease agreement directly with Kaplan which would allow Kaplan to
terminate the Ampersand Lease and allow the City to continue occupying Suite 2 at the Property.
3
https://www.nj.com/mercer/2022/01/new-city-run-neighborhood-clinic-will-start-with-covid-
services-grow-from-there.html
9
4887-7526-2040, v. 1
55. Based on these representations, Kaplan proceeded to terminate the Ampersand Lease
and negotiate a new Commercial Lease Agreement with the City (the “City Lease”). See Exhibit
“C” annexed hereto.
56. On November 29, 2022, Kaplan and the City executed the City Lease for Suite 2 at the
Property for an initial term of one (1) year from January 1, 2023 through December 31, 2023.
57. To offset the lost rent revenue under the Ampersand Lease for the remainder of the
term in the Ampersand Lease, the City agreed to monthly rent of $12,000.
58. Since the expiration of the Sublease Agreement on December 31, 2022, the City has
refused to make any payments due under the City Lease.
59. The City continues to occupy the Property and refuses to pay the required rent under
the City Lease.
60. In response to a demand from Kaplan, the City has refused to recognize the City
Lease stating that the City’s Director of Health and Human Services was not authorized to enter
into the City Lease Agreement with Kaplan.
FIRST COUNT
(Book Account - Emergency COVID Testing Contract)
61. Kaplan repeats and re-alleges the allegations set forth above as if set forth at length
therein.
62. The amount due from City under the Emergency COVID-Testing Contract constitutes
a book account.
63. The book account is due and owing to Kaplan
64. Payment has been demanded and not paid.
WHEREFORE, Kaplan demands judgment against the City, as follows:
10
4887-7526-2040, v. 1
a) Directing that Kaplan be paid $99,360 due and owing under the Emergency
COVID-Testing Contract;
b) Granting Plaintiff attorneys’ fees and costs; and
c) Granting such other and further relief as the Court may deem just and equitable.
SECOND COUNT
(Breach of Contract - Emergency COVID Testing Contract)
65. Kaplan repeats and re-alleges each and every allegation set forth above as if set forth
at length herein.
66. Kaplan and the City entered into the Emergency COVID Testing Contract wherein
Kaplan would provide COVID-19 testing services at a rate of $90 per test.
67. Kaplan provided the COVID-19 testing services to the City, but the City failed to make
certain payments on five (5) of the invoices due totally $99,360 under the Emergency COVID
Testing Contract.
68. The City’s failure to make payment constitutes a breach of contract.
69. As a result of the City’s breach, Kaplan has suffered, and will continue to suffer,
damages.
THIRD COUNT
(Unjust Enrichment - Emergency COVID Testing Contract)
at length herein.
11
4887-7526-2040, v. 1
71. In utilizing the COVID-19 testing services of Kaplan without making payment to
Kaplan, the City has been unjustly enriched.
72. The City’s unjust enrichment has occurred to the detriment of Kaplan.
FOURTH COUNT
(Promissory Estoppel - Emergency COVID Testing Contract)
therein.
74. In utilizing Kaplan’s COVID-19 testing services, the City promised to pay Kaplan for
those services at a rate of $90 per test.
75. Kaplan reasonably relied on the City’s promises for payment and to comply with the
terms and conditions of the Emergency COVID-Testing Contract.
76. It was foreseeable to an objectively reasonable person that Kaplan would rely on upon
the City’s promise for payment.
77. The City has failed to make payments due and owing to Kaplan as promised when it
utilized Kaplan’s services.
78. As a result, Kaplan has suffered damages.
12
4887-7526-2040, v. 1
FIFTH COUNT
(Breach of Contract - Sale of COVID-19 Testing Kits)
at length herein.
80. Kaplan and the City entered into a Contract under which the City would purchase
10,000 COVID-19 test kits at a price of $40 per test kit plus $25,000 for training, set up and
equipment.
81. Kaplan delivered the 10,000 COVID-19 test kits to the City and fulfilled its obligations
under the Contract.
82. Despite Kaplan’s delivery of the COVID-19 test kits to the City, the City has failed and
refused to pay for the COVID-19 test kits.
83. The City’s failure to make payment constitutes a breach of contract.
damages.
a) Directing that Kaplan be paid $425,000 due and owing for the purchase of the
COVID-19 test kits;
13
4887-7526-2040, v. 1
SIXTH COUNT
(Unjust Enrichment - Sale of COVID-19 Testing Kits)
at length herein.
86. In receiving and utilizing the COVID-19 test kits delivered by Kaplan without making
payment to Kaplan, the City has been unjustly enriched.
COVID-19 test kits;
SEVENTH COUNT
(Promissory Estoppel - Sale of COVID-19 Testing Kits)
therein.
89. The City promised that it would issue payment to Kaplan at $40 per COVID-19 test kit
if Kaplan provided such test kits for use by the City.
90. Kaplan reasonably relied on the City’s promises for payment and proceeded to
purchase 10,000 COVID-19 test kits for the City.
91. It was foreseeable to an objectively reasonable person that Kaplan would rely on upon
the City’s promise for payment.
92. The City has failed to make payments due and owing to Kaplan as promised when it
obtained the 10,000 COVID-19 test kits.
14
4887-7526-2040, v. 1
COVID-19 test kits;
EIGHTH COUNT
(Breach of Contract – Lease Agreement)
at length herein.
95. Kaplan and the City entered into the City Lease under which the City was provided use
of Suite 2 at the Property at a rate of $12,000 per month.
96. From January 1, 2023 to the present, the City is utilizing Suite 2 of the Property
pursuant to the City Lease.
97. Despite the City’s continued occupancy of Suite 2 at the Property, the City has failed
and refused to make certain payments for the COVID-19 test kits.
98. The City’s failure to make rent payment constitutes a breach of the City Lease.
damages.
a) Directing that Kaplan be paid $12,000 per month for the occupancy of Suite 2 at
the Property for the twelve (12) months during 2023;
15
4887-7526-2040, v. 1
NINTH COUNT
(Unjust Enrichment – Lease Agreement)
100. Kaplan repeats and re-alleges each and every allegation set forth above as if set
forth at length herein.
101. In utilizing Suite 2 at the Property without payment of rent to Kaplan, the City has
been unjustly enriched.
a) Directing that Kaplan be paid $12,000 per month for the occupancy of Suite 2 at
the Property for the twelve (12) months during 2023;
TENTH COUNT
(Promissory Estoppel – Lease Agreement)
therein.
104. The City promised that it would pay rent to Kaplan for the use of Suite 2 at the
Property at a monthly rent of $12,000 for a term on one (1) year.
105. Kaplan reasonably relied on the City’s promises for payment of rent.
106. Upon reliance on the City’s promise for the payment of rent at $12,000 per month,
Kaplan terminated the Ampersand Lease despite the new tenant who had proposed to take over
the Ampersand Lease.
107. It was foreseeable to an objectively reasonable person that Kaplan would rely on
upon the City’s promise for payment of rent.
108. The City has failed to pay Kaplan any rent under the City Lease.
16
4887-7526-2040, v. 1
a) Directing that Kaplan be paid all remaining rent due under the Ampersand Lease
which Kaplan terminated at the City’s direction;

& SHAHDANIAN P.C.
Attorneys for Plaintiff Kaplan Group LLC dba
Medical Home Pharmacy
By: /s/ Richard D. Trenk

RICHARD D. TRENK
Dated: March 27, 2023
DESIGNATION OF TRIAL COUNSEL
Kaplan hereby designates Richard D. Trenk, Esq. as trial counsel in this matter pursuant to
New Jersey Court Rule 4:5-1.

& SHAHDANIAN P.C.

RICHARD D. TRENK
17
4887-7526-2040, v. 1
JURY DEMAND
Kaplan hereby demands a trial by jury as to all issues herein.
TRENK ISABEL P.C.


RICHARD D. TRENK
R. 4:5-1 CERTIFICATION
In accordance with R. 4:5-1, I hereby certify that the matter in controversy pleaded herein
is not the subject of any other court or arbitration action. I hereby certify that the foregoing
statements made by me are true to the best of my knowledge and information. I am aware that if
any of the foregoing statements made by me are willfully false, I may be subject to punishment.

& SHAHDANIAN P.C.

RICHARD D. TRENK
18
4887-7526-2040, v. 1
CERTIFICATION
I certify that confidential personal identifiers have been redacted from documents now
submitted to the court and will be redacted from all documents submitted in the future in
accordance with Rule 1:38-7(b).

& SHAHDANIAN P.C.

RICHARD D. TRENK
19
4887-7526-2040, v. 1
Exhibit “A”
Exhibit “B”
Exhibit “C”
MER-L-000574-23 03/27/2023
MER-L-000574-23 03/27/202310:37:33
10:37:33AM
AM Pg 1 of 1 Trans
TransID:
ID:LCV20231037564
LCV20231037564
Civil Case Information Statement

Case Details: MERCER | Civil Part Docket# L-000574-23
Case Caption: KAPLAN GROUP LLC VS CITY OF Case Type: CONTRACT/COMMERCIAL TRANSACTION
TRENTON Document Type: Complaint with Jury Demand
Case Initiation Date: 03/27/2023 Jury Demand: YES - 6 JURORS
Attorney Name: RICHARD D TRENK Is this a professional malpractice case? NO
Firm Name: TRENK ISABEL SIDDIQI SHAHDANIAN, P.C. Related cases pending: NO
Address: 290 W. MT. PLEASANT AVE STE 2370 If yes, list docket numbers:
LIVINGSTON NJ 07039 Do you anticipate adding any parties (arising out of same
Phone: 9735331000 transaction or occurrence)? NO
Name of Party: PLAINTIFF : Kaplan Group LLC Does this case involve claims related to COVID-19? YES
Name of Defendant’s Primary Insurance Company
(if known): Unknown Are sexual abuse claims alleged by: Kaplan Group LLC? NO
THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE

CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION
Do parties have a current, past, or recurrent relationship? NO

If yes, is that relationship:
Does the statute governing this case provide for payment of fees by the losing party? NO
Use this space to alert the court to any special case characteristics that may warrant individual
management or accelerated disposition:
Do you or your client need any disability accommodations? NO

If yes, please identify the requested accommodation:
Will an interpreter be needed? NO

If yes, for what language:
Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO
I certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)
03/27/2023 /s/ RICHARD D TRENK

Dated Signed

Health Clinic Suing City

Uploaded by

Copyright:

Available Formats

Health Clinic Suing City

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Health Clinic Suing City

Uploaded by

Copyright:

Available Formats

MER-L-000574-23 03/27/2023 10:37:33 AM Pg 1 of 19 Trans ID: LCV20231037564

TRENK ISABEL SIDDIQI

KAPLAN GROUP LLC doing business as SUPERIOR COURT OF NEW JERSEY

Plaintiff, Docket No.: MER-L-

CITY OF TRENTON, COMPLAINT and JURY DEMAND

“Defendant”), respectfully states and alleges as follows:

Olden Avenue in Trenton, New Jersey.

New Jersey (the “Property”).

offices at 319 East State Street in Trenton, New Jersey.

Worldwide Pandemic impacted the entire World.

when public health was critical and of the utmost concern.

A. The Contract to Provide COVID-19 Testing for City of Trenton Residents

submission date of September 3, 2020.

specifications in the amount of $90.00 per test.

explained to the members of the City Council that:

https://www.youtube.com/watch?v=-dTW6RKHROk with the discussion of Resolution 20-690

COVID-19 tests for the City.

the number to COVID-19 tests performed for the City.

Invoice Number Invoice Date Invoice Amount

32 August 2, 2022 $25,920.00

33 August 31, 2022 $19,170.00

38 September 30, 2022 $19,800.00

49 November 30, 2022 $17,1000

50 December 30, 2022 $17,370.00

Total Unpaid Invoices $99,360.00

COVID-19 tests pursuant to the Emergency COVID Testing Contract.

B. The Sale of COVID-19 Testing Kits to the City of Trenton

COVID-19 test kits.

19 test kits for $450,000.

the COVID-19 tests.

the City-Run Neighborhood Clinic located at the Property.

Kaplan and the City on the Property.

space in the Property along with the equipment provided by Kaplan.

and training fee of $25,000.

and welfare of Trenton residents authorizing various actions.

Authorizing payment for a contract with Kaplan Group

A copy of Executive Order 22-0212 is annexed hereto as Exhibit “A.”

any payment to Kaplan, LLC for the COVID-19 test kits.

the Property owned by Kaplan.

Period Per Year Per Month

Months 1-4 $0.00 $0.00

Months 5-16 $77,000.00 $6,416.66

Months 17-28 $78,540.00 $6,416.66

Months 29-40 $80,110.80 $6,675.89

Months 41-52 $81,713.02 $6,809.41

Months 53-64 $83,347.28 $6,945.60

Months 65-76 $85,014.22 $7,084.51

Months 77-88 $86,714.51 $7,226.20

Months 89-100 $88,448.80 $7,370.73

Months 101-112 $90,217.77 $7,518.14

Months 113-124 $92,022.13 $7,668.50

proposed medical offices at the Property.

Property in order to open a City-Run Neighborhood Clinic to provide COVID-19 services.

being leased to Ampersand under the Ampersand Lease.

and the City.

to the formal execution of a sub-lease agreement.

month. See Exhibit “B” annexed hereto.

for use of Suite 2 at the Property.

Ampersand Lease once the Sublease Agreement expired.