Saturday, March 24, 2018

Attorney General Schneiderman And Governor Cuomo File Petition With Federal Government To Set Fair Fluke Quota

Outdated Fluke Allocation Hurts New York’s Commercial Fishing Industry
New York Retains Expert Fisheries Consultant to Improve Commercial License System
  Attorney General Eric T. Schneiderman and Governor Andrew M. Cuomo announced that New York has filed a petition with the federal government to establish fair quota allocations for the state’s commercial harvest of fluke, also known as summer flounder. The petition for revised allocations would put New York on more equitable footing with other East Coast states by correcting decades of injustice, increasing safety for fishers and allowing more fish to be landed in ports closer to where they are caught. New York’s petition, drafted by DEC and the Attorney General’s Office, is the first step in the legal process to bring equity to the state’s fluke quota.
“New York’s commercial fishing industry deserves a fair shake from the federal government,” Attorney General Schneiderman said. “Federal law requires that our nation’s marine fisheries be managed according to the best available science, and in a fair, efficient, and safe way.  Simply put, perpetuating New York’s unfair, outdated share of the commercial summer flounder fishery does not meet the requirements of the law.”
“Our federal government cannot rely on decades-old data to uphold these unreasonable fluke quotas, as they continue to put New York at a disadvantage to neighboring states, while ignoring the needs of communities across the state,” Governor Cuomo said. “New York’s commercial fishing industry has been held back by archaic federal restrictions for too long, and by taking action to defend fair treatment of our fishers, we will help this valuable industry reach its full potential.”
New York State has filed a petition with the U.S. Department of Commerce’s National Oceanic and Atmospheric Administration, National Marine Fisheries Service, and the Mid-Atlantic Fishery Management Council to demand that commercial fluke allocations be revised to provide New York’s fishers with equitable access to summer flounder. New York is also reviewing other species where there is an unfair ‎allocation, including black sea bass and bluefish, and may pursue similar actions. 
“Low quotas and restrictive inter-state fishery management plans are putting unreasonable limits on New York’s commercial fishers,” said Department of Environmental Conservation Commissioner Basil Seggos. “These unfair and unbalanced quotas have forced New York State to restrict commercial fishing access and limit the prospects for new fishers in order to preserve viable opportunities for current participants. Changes to New York’s commercial licensing process must also be made to better serve New Yorkers and support our fishing industry.”
State-by-state allocations for commercial fluke were set in the early 1990s using incomplete landings data from 1980 through 1989. At that time, New York’s allocation was set at the region-low 7.6 percent of the coast-wide quota, while the state’s neighbors were allocated up to 15.7 percent for Rhode Island and 16.7 percent for New Jersey. Virginia and North Carolina were allocated 21.3 percent and 27.4 percent. New York’s commercial fishers and seafood dealers have suffered under this low allocation since the 1990s, resulting in daily trip limits of 50 pounds in 2017, and 70 pounds in 2016.
Scientific studies have shown that the distribution of summer flounder and the summer flounder fishery have shifted north toward New York waters since federal allocations were established. While these shifts should be acknowledged, neither the Mid-Atlantic Fishery Management Council nor National Marine Fisheries Service require regular review and/or updating of allocations. In addition, an amendment to the fishery management plan that potentially includes the re-allocation of the commercial summer flounder quota has been slowly moving through the Mid-Atlantic Fishery Management Council process since 2014, but has yet to result in the necessary updating and equitable changes to the system.
Commercial Fishing Licensing Revision
To modernize and improve the state’s commercial fishing licensing system and ensure it is a useful tool in managing the industry, DEC has retained the services of an experienced fishery management consultant. The consultant’s experience in managing state fisheries and licensing will enable him to capture the diverse views and needs of New York’s commercial fishing industry. ‎
Directed by DEC, the consultant will launch a comprehensive, stakeholder-driven analysis of New York’s current licensing system and will recommend strategic improvements to make it more efficient and better serve New York stakeholders. The work will begin immediately, and include a nine-part series of small, local meetings across Long Island, the New York City area, and Westchester to gather stakeholder input on issues such as latent licenses, transferability, the definition of a commercial fisher, license qualifiers, and the apprenticeship program.
Additional meetings with stakeholders and New York’s Marine Resource Advisory Council will be scheduled to gather feedback. The fisheries expert will make recommendations to DEC by the end of 2018 for action in 2019.
We don't normally comment on items such as this, but we are wondering why when Democratic President Obama came into office in 2008 this was not brought up. Now to wait until a Republican President is back in office seems to say what have the Governor and Attorney General of New York been doing the eight years before Donald Trump was elected? 

A.G. Schneiderman Announces State Prison Sentence For Long Island Man Convicted Of Stealing From Medicaid Funded Charity

John Cornachio Used “No-Show” Job to Steal More Than $800,000 from Bronx County Substance Abuse Treatment Provider Narco Freedom
John Cornachio Will Serve 2 to 6 Years in Prison, Pay $840,000 in Restitution  
All Defendants Indicted by AG Schneiderman in Connection with Narco Freedom Have Now Been Convicted
  Attorney General Eric T. Schneiderman announced a state prison sentence of 2 to 6 years for John Cornachio, 63, of Oyster Bay, NY. Cornachio was convicted after trial of Grand Larceny in the Second Degree, a class C felony, for using a “no-show” job to steal from Narco Freedom Inc., a former Medicaid-funded, not-for-profit corporation based in the Bronx that was founded to provide substance abuse services throughout New York City. In addition to being sentenced to time in jail, Cornachio was ordered to pay $840,000 in restitution to the New York State Medicaid Fraud Restitution Fund.
“Stealing from Medicaid harms both our most vulnerable residents and New York taxpayers," said Attorney General Schneiderman. "No matter how sophisticated the scheme, my office will continue to prosecute Medicaid fraud and bring crooks to justice."
During the jury trial before Hon. Jeanette Rodriguez-Morick, the Attorney General’s office presented evidence that Cornachio colluded with Narco Freedom’s corrupt management and held a “no-show” job within the organization. Over a five year period, Cornachio collected over $500,000 in salary and benefits paid by Narco Freedom. As part of his “no-show” job, Narco Freedom provided Cornachio with health insurance, retirement benefits, and a generous car allowance that he used to lease a Land Rover, among other benefits. The evidence also showed that Cornachio obtained over $300,000 from Narco Freedom through B&C Management, a shell company with no actual business, which submitted fake invoices to Narco Freedom for services it never provided to the not-for-profit.  
In 2015, the Attorney General’s Medicaid Fraud Control Unit (“MFCU”) indicted Narco Freedom Inc., CEO Alan Brand, Jason Brand, and other individuals and corporations for defrauding the state Medicaid program along with Cornachio. All defendants indicted by Attorney General Schneiderman in connection with Narco Freedom have now been convicted of various crimes, including Enterprise Corruption, Grand Larceny, and filing false information with government offices.
As part of the Narco Freedom investigation, the Attorney General also filed a civil action against Narco Freedom Inc. seeking asset forfeiture and other remedies, including treble damages and penalties under the New York State False Claims Act. The arrests and civil action stopped the illegal activity of Narco Freedom that exploited the Medicaid program and the vulnerability of thousands of Medicaid recipients, resulting in many millions of dollars in savings to Medicaid. As part of its plea and civil agreements, Narco Freedom acknowledged that it stole from Medicaid and admitted to filing false statements with various state agencies, including the New York State Department of Health and the Attorney General’s Charities Bureau, in efforts to deceive and defraud these agencies. In January 2016, Narco Freedom filed for bankruptcy. A bankruptcy court approved a $118 million settlement to settle Narco Freedom’s outstanding government claims, including those of New York State and the federal government; the precise amount to be recovered in the bankruptcy proceeding is yet to be determined. 
The Attorney General would like to thank the New York State Office of Alcoholism and Substance Abuse Services, the Office of the New York State Medicaid Inspector General, the New York State Department of Health, the Human Resources Administration of the City of New York, and the Civil Division of the United States Attorney’s Office for the Southern District of New York.

Community Board 7 - 2nd Annual Women's Empowerment Summit

  The six hour event began in the Lehman College Lovinger Theatre, and ended in the Faculty Dinning Hall of the college. The event started with two Panel Sessions of five different successful women who gave a brief story of how they rose to the positions they currently are in. 

Panel One consisted of NYPD Chief of Community Affairs Nilda Hoffman, Councilwoman Vanessa Gibson, Ms. Sandra Erickson (President, Sandra Erickson Realty), Ms. KC Copeland (VP Morgan Stanley), and Bronx Parks Commissioner Iris Rodriguez-Rosa. 

Panel Two consisted of Ms. Maria Khury (President Khury Tours), Ms. Samantha Diliberti (Founder OrangeU Going), Television host Rhina Valentin, Suzanne M. Carter Esq., and Filmmaker and Producer Rachel Bradshaw.

The panels were also joined by Community Board 7 District Manager Ischia Bravo, and Community Board 7 Chair Adeline Walker-Santiago. 

After lunch in the Dinning Room of Lehman College awards were given to the following Mentors by CB 7. Chief of Operations for North Central Hospital Christina Contreras, Weight Management and Healthy Living Program Director Gloria Bent, Tracy Towers Tenant Association President Jean Hill, Fordham Hill Owners Corp. Board President Myrna Calderon, 52nd Precinct Community Affairs officer Crystal Reveron, Former Chief of Staff to Assemblyman Mark Gjonaj, and Bronx Regional Representative for Governor Andrew Cuomo Nathalia Fernandez, and Radio host Avril Francis. 

The seven Honorees with Community Board 7 Chair Adeline Walker-Santiago.

Republican/Conservative/Reform Candidate Gene DeFrancis opens Headquarters

  Today was the opening of the 80th Assembly Special Election headquarters for candidate Gene DeFrancis at the Bronx Republican office on Middletown Road in the Pelham Bay section of the Bronx. DeFrancis is the candidate of the Republican, Conservative, and Reform parties. He is running against Nathalia Fernandez the candidate of the Democratic and Independence Parties. 

  While the Republican Party of the Bronx has not had an elected official in office since the late State Senator Guy Velella that is not stopping the enthusiasm of the fifty plus people who turned out to meet and show their support for their candidate. 

  Candidate DeFrancis in a few interviews has told me that he will be running for the state assembly on his thirty year experience in the community versus what he said was his opponents lack of experience. He said that heis support is widely throughout the assembly district, and that he helped the former Assemblyman Mark Gjonaj in his win for the 13th City Council seat. For the record Councilman Gjonaj has endorsed Mr. DeFrancis's opponent. In speaking with Candidate DeFrancis today he said that his opponent seems to not want to debate him, as she has been either to busy or has other thing on her agenda. 

  Gary Axelbank's Bronxnet show Bronxtalk has a planned debate for the 80th Assembly District Special Election, but a date has not been chosen yet. there have been no announcements about any other debates as of yet. The date for the 80th A.D. Special Election is set for Tuesday April 24th.

Above - Candidate Gene DeFrancis meets supporters as he arrives at his ner campaign headquarters at the Bronx Republican office on Middletown Road. 
Below - DeFrancis goes inside to greet some more supporters.

Above - Candidate Gene DeFrancis speaks to his supporters about the upcoming special election.
Below - One of the variety of materials you may see for 80th A.D. candidate Gene DeFrancis.

Friday, March 23, 2018

Nine Iranians Charged With Conducting Massive Cyber Theft Campaign On Behalf Of The Islamic Revolutionary Guard Corps

Mabna Institute Hackers Penetrated Systems Belonging to Hundreds of Universities, Companies, and Other Victims to Steal Research, Academic Data, Proprietary Data, and Intellectual Property

  Rod J. Rosenstein, the Deputy Attorney General of the United States, Geoffrey S. Berman, the United States Attorney for the Southern District of New York, William F. Sweeney Jr., the Assistant Director-in-Charge of the New York Field Division of the Federal Bureau of Investigation (“FBI”), and John C. Demers, Assistant Attorney General for National Security, announced today the unsealing of an indictment charging GHOLAMREZA RAFATNEJAD, EHSAN MOHAMMADI, ABDOLLAH KARIMA, a/k/a “Vahid Karima,” MOSTAFA SADEGHI, SEYED ALI MIRKARIMI, MOHAMMED REZA SABAHI, ROOZBEH SABAHI, ABUZAR GOHARI MOQADAM, and SAJJAD TAHMASEBI.  The defendants were each leaders, contractors, associates, hackers-for-hire, and affiliates of the Mabna Institute, an Iran-based company that was responsible for a coordinated campaign of cyber intrusions that began in at least 2013 into computer systems belonging to 144 U.S.-based universities, 176 universities across 21 foreign countries, 47 domestic and foreign private sector companies, the United States Department of Labor, the Federal Energy Regulatory Commission, the State of Hawaii, the State of Indiana, the United Nations, and the United Nations Children’s Fund.  Through the activities of the defendants, the Mabna Institute conducted these intrusions to steal over 30 terabytes of academic data and intellectual property from universities, and email inboxes from employees of victim private sector companies, government victims, and non-governmental organizations.  The defendants conducted many of these intrusions on behalf of the Islamic Republic of Iran’s (“Iran”) Islamic Revolutionary Guard Corps (“IRGC”), one of several entities within the government of Iran responsible for gathering intelligence, as well as other Iranian government clients.  In addition to these criminal charges, today the Department of Treasury’s Office of Foreign Assets Control (OFAC) designated the Mabna Institute and the nine defendants for sanctions for the malicious cyber-enabled activity outlined in the Indictment.

Deputy Attorney General Rod J. Rosenstein said:  “These nine Iranian nationals allegedly stole more than 31 terabytes of documents and data from more than 140 American universities, 30 American companies, five American government agencies, and also more than 176 universities in 21 foreign countries.  For many of these intrusions, the defendants acted at the behest of the Iranian government and, specifically, the Iranian Revolutionary Guard Corps.  The Department of Justice will aggressively investigate and prosecute hostile actors who attempt to profit from America’s ideas by infiltrating our computer systems and stealing intellectual property.  This case is important because it will disrupt the defendants’ hacking operations and deter similar crimes.”
Manhattan U.S. Attorney Geoffrey S. Berman said:  “Today, in one of the largest state-sponsored hacking campaigns ever prosecuted by the Department of Justice, we have unmasked criminals who normally hide behind the ones and zeros of computer code.  As alleged, this massive and brazen cyber-assault on the computer systems of hundreds of universities in 22 countries, including the United States, and dozens of private sector companies and governmental organizations was conducted on behalf of Iran’s Islamic Revolutionary Guard.  The hackers targeted innovations and intellectual property from our country’s greatest minds.  These defendants are now fugitives from American justice, no longer free to travel outside Iran without risk of arrest.  The only way they will see the outside world is through their computer screens, but stripped of their greatest asset – anonymity.”     
FBI Assistant Director William F. Sweeney Jr. said:  “The numbers alone in this case are staggering, over 300 universities and 47 private sector companies both here in the United States and abroad were targeted to gain unauthorized access to online accounts and steal data.  An estimated 30 terabytes was removed from universities’ accounts since this attack began, which is roughly equivalent of 8 billion double-sided pages of text.  It is hard to quantify the value on the research and information that was taken from victims but it is estimated to be in the billions of dollars. The nine Iranians indicted today now find themselves wanted by the FBI and our partner law enforcement agencies around the globe – and like other cyber criminals they will soon learn their ability to freely move was just limited to the virtual world only.” 
According to the allegations contained in the Indictment[1] unsealed today in Manhattan federal court:
Background on the Mabna Institute
GHOLAMREZA RAFATNEJAD and EHSAN MOHAMMADI, the defendants, founded the Mabna Institute in approximately 2013 to assist Iranian universities and scientific and research organizations in stealing access to non-Iranian scientific resources.  In furtherance of its mission, the Mabna Institute employed, contracted, and affiliated itself with hackers-for-hire and other contract personnel to conduct cyber intrusions to steal academic data, intellectual property, email inboxes and other proprietary data, including ABDOLLAH KARIMA, a/k/a “Vahid Karima,” MOSTAFA SADEGHI, SEYED ALI MIRKARIMI, MOHAMMED REZA SABAHI, ROOZBEH SABAHI, ABUZAR GOHARI MOQADAM, and SAJJAD TAHMASEBI.  The Mabna Institute contracted with both Iranian governmental and private entities to conduct hacking activities on their behalf, and specifically conducted the university spearphishing campaign on behalf of the IRGC.  The Mabna Institute is located at Tehran, Sheikh Bahaii Shomali, Koucheh Dawazdeh Metri Sevom, Plak 14, Vahed 2, Code Posti 1995873351.
University Hacking Campaign
The Mabna Institute, through the activities of the defendants, targeted over 100,000 accounts of professors around the world.  They successfully compromised approximately 8,000 professor email accounts across 144 U.S.-based universities, and 176 universities located in foreign countries, including Australia, Canada, China, Denmark, Finland, Germany, Ireland, Israel, Italy, Japan, Malaysia, Netherlands, Norway, Poland, Singapore, South Korea, Spain, Sweden, Switzerland, Turkey, and the United Kingdom.  The campaign started in approximately 2013, and has continued through at least December 2017, and broadly targeted all types of academic data and intellectual property from the systems of compromised universities, including, among other things, academic journals, theses, dissertations, and electronic books.  Through the course of the conspiracy, U.S.-based universities spent over approximately $3.4 billion to procure and access such data and intellectual property.
The hacking campaign against universities was conducted across multiple stages.  First, the defendants conducted online reconnaissance of university professors, including to determine these professors’ research interests and the academic articles they had published.  Second, using the information collected during the reconnaissance phase, the defendants created and sent spearphishing emails to targeted professors, which were personalized and created so as to appear to be sent from a professor at another university.  In general, those spearphishing emails indicated that the purported sender had read an article the victim professor had recently published, and expressed an interest in several other articles, with links to those additional articles included in the spearphishing email.  If the targeted professor clicked on certain links in the email, the professor would be directed to a malicious Internet domain named to appear confusingly similar to the authentic domain of the recipient professor’s university.  The malicious domain contained a webpage designed to appear to be the login webpage for the victim professor’s university.  It was the defendants’ intent that the victim professor would be led to believe that he or she had inadvertently been logged out of his or her university’s computer system, prompting the victim professor for his or her login credentials.  If a professor then entered his or her login credentials, those credentials were then logged and captured by the hackers.
Finally, the members of the conspiracy used stolen account credentials to obtain unauthorized access to victim professor accounts, through which they then exfiltrated intellectual property, research, and other academic data and documents from the systems of compromised universities, including, among other things, academic journals, theses, dissertations, and electronic books.  The defendants targeted data across all fields of research and academic disciplines, including science and technology, engineering, social sciences, medical, and other professional fields.  At least approximately 31.5 terabytes of academic data and intellectual property from compromised universities were stolen and exfiltrated to servers under the control of members of the conspiracy located in countries outside the United States.
In addition to stealing academic data and login credentials for university professors for the benefit of the Government of Iran, the defendants also sold the stolen data through two websites, (“Megapaper”) and (“Gigapaper”).  Megapaper was operated by Falinoos Company (“Falinoos”), a company controlled by ABDOLLAH KARIMA, a/k/a “Vahid Karima,” the defendant, and Gigapaper was affiliated with KARIMA.  Megapaper sold stolen academic resources to customers within Iran, including Iran-based public universities and institutions, and Gigapaper sold a service to customers within Iran whereby purchasing customers could use compromised university professor accounts to directly access the online library systems of particular United States-based and foreign universities.
Prior to the unsealing of the Indictment, the FBI provided foreign law enforcement partners with detailed information regarding victims within their jurisdictions, so that victims in foreign countries could be notified and so that foreign partners could assist in remediation efforts.
Private Sector Hacking Victims
In addition to targeting and compromising universities, the Mabna Institute defendants targeted and compromised employee email accounts for at least approximately 36 United States-based private companies, and at least approximately 11 private companies based in Germany, Italy, Switzerland, Sweden, and the United Kingdom, and exfiltrated entire email mailboxes from compromised employees’ accounts.  Among the United States-based private sector victims were three academic publishers, two media and entertainment companies, one law firm, 11 technology companies, five consulting firms, four marketing firms, two banking and/or investment firms, two online car sales companies, one healthcare company, one employee benefits company, one industrial machinery company, one biotechnology company, one food and beverage company, and one stock images company.
In order to compromise accounts of private sector victims, members of the conspiracy used a technique known as “password spraying,” whereby they first collected lists of names and email accounts associated with the intended victim company through open source Internet searches.  Then, they attempted to gain access to those accounts with commonly-used passwords, such as frequently used default passwords, in order to attempt to obtain unauthorized access to as many accounts as possible.  Once they obtained access to the victim accounts, members of the conspiracy, among other things, exfiltrated entire email mailboxes from the victims.  In addition, in many cases, the defendants established automated forwarding rules for compromised accounts that would prospectively forward new outgoing and incoming email messages from the compromised accounts to email accounts controlled by the conspiracy.
In connection with the unsealing of the Indictment, today the FBI issued a FBI Liaison Alert System (FLASH) message, providing detailed information regarding the vulnerabilities targeted and the intrusion vectors used by the Mabna Institute in their campaign against private sector companies, to provide the public with information to assist in detecting and remediating the threat.
U.S. Government and NGO Hacking Victims
In the same time period as the university and private sector hacking campaigns described above, the Mabna Institute also conducted a computer hacking campaign against various governmental and non-governmental organizations within the United States.  During the course of that campaign, employee login credentials were stolen by members of the conspiracy through password spraying.  Among the victims were the following, all based in the United States:  the United States Department of Labor, the Federal Energy Regulatory Commission, the State of Hawaii, the State of Indiana, the State of Indiana Department of Education, the United Nations, and the United Nations Children’s Fund.  As with private sector victims, the defendants targeted for theft email inboxes of employees of these organizations.
GHOLAMREZA RAFATNEJAD, EHSAN MOHAMMADI, ABDOLLAH KARIMA, a/k/a “Vahid Karima,” MOSTAFA SADEGHI, SEYED ALI MIRKARIMI, MOHAMMED REZA SABAHI, ROOZBEH SABAHI, ABUZAR GOHARI MOQADAM, and SAJJAD TAHMASEBI, the defendants, are citizens and residents of Iran.  Each is charged with one count of conspiracy to commit computer intrusions, which carries a maximum sentence of five years in prison; one count of conspiracy to commit wire fraud, which carries a maximum sentence of 20 years in prison; two counts of unauthorized access of a computer, each of which carries a maximum sentence of five years in prison; two counts of wire fraud, each of which carries a maximum sentence of 20 years in prison; and one count of aggravated identity theft, which carries a mandatory sentence of two years in prison.  The maximum potential sentences in this case are prescribed by Congress and are provided here for informational purposes only, as any sentencings of the defendants will be determined by the assigned judge.
Mr. Berman praised the outstanding investigative work of the FBI, the assistance of the United Kingdom’s National Crime Agency (NCA), and the support of the OFAC.  The case is being handled by the Office’s Complex Frauds and Cybercrime Unit.  Assistant United States Attorneys Timothy T. Howard, Jonathan Cohen, and Richard Cooper are in charge of the prosecution, with assistance provided by Heather Alpino and Jason McCullough of the National Security Division’s Counterintelligence and Export Control Section.
The charges contained in the Indictment are merely accusations and the defendants are presumed innocent unless and until proven guilty.   
 [1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein, constitute only allegations, and every fact described should be treated as an allegation.

Doctor Sentenced To More Than 9 Years In Prison For Selling Fentanyl That Resulted In Manhattan Man’s Overdose Death

  Geoffrey S. Berman, the United States Attorney for the Southern District of New York, announced that AVINOAM LUZON was sentenced this afternoon to 110 months in prison for selling fentanyl that resulted in the overdose death of Gabriel Tramiel, 32, of Manhattan, on October 22, 2016.  LUZON was sentenced today by United States District Judge Lewis A. Kaplan.

Manhattan U.S. Attorney Geoffrey S. Berman said:  “Today, Avinoam Luzon was sentenced to prison for selling a lethal dose of fentanyl that took the life of Gabriel Tramiel.  He committed this crime as a trained medical doctor and while enrolled as a graduate student in public health at a university in Manhattan.  Luzon’s conduct helped fuel the nation’s most serious health crisis, the opioid abuse epidemic.”
According to the Information and other documents filed in federal court, as well as statements made during LUZON’s plea proceeding and sentencing:
In the early morning hours of October 23, 2016, Gabriel Tramiel was found dead by his wife.  The medical examiner determined the cause of Tramiel’s death to be acute fentanyl intoxication.  The night before, LUZON and Tramiel met at a drug store on the Upper West Side of Manhattan where LUZON sold Tramiel a quantity of fentanyl. Tramiel then purchased a nasal spray bottle, and the two went to a nearby restaurant where Tramiel used the drugs in the restaurant bathroom. When Tramiel returned to the table, he was visibly inebriated from the effects of the narcotic. Shortly thereafter, surveillance video recovered from the apartment building where Tramiel died showed Tramiel inhaling the contents of the nasal spray bottle in the elevator. Tramiel died a few hours later.  When LUZON learned of Tramiel’s death the following morning, LUZON called Tramiel’s wife and said he “might be responsible” but claimed he had given Tramiel “liquid morphine.” The contents of the nasal spray bottle used by Tramiel were tested and determined to be fentanyl. Law enforcement later searched LUZON’s dorm room and recovered over 160 grams of fentanyl and numerous nasal spray bottles. 
In November 2017, LUZON pled guilty before United States Magistrate Judge Debra Freeman.  At his guilty plea, LUZON admitted that he had intentionally and knowingly distributed fentanyl to Tramiel on October 22, 2016.  Tramiel was found dead the next morning.
In addition to the prison term, LUZON, 33, of Mountain View, California, was sentenced to three years of supervised release.
Mr. Berman praised the outstanding work of the New York City Police Department.  Mr. Berman also thanked the New York State Department of Health’s Bureau of Narcotics Enforcement for their assistance with this investigation.

Two New York City Employees Charged In Manhattan Federal Court With Theft Of Government Funds And Wire Fraud

  Geoffrey S. Berman, the United States Attorney for the Southern District of New York, and Mark G. Peters, the Commissioner of the New York City Department of Investigation (“DOI”), announced the arrest of ERIC LUNA, an employee of the New York City Department of Youth and Community Development (“DYCD”), and IGOR GOLDSHTEYN, an employee of the New York City Fire Department (“FDNY”), for the theft of government funds and wire fraud.  GOLDSHTEYN was arrested at his residence in Staten Island, New York, and LUNA was arrested outside the Manhattan headquarters of the DYCD.  Both men were presented today before Magistrate Judge Kevin Nathaniel Fox in Manhattan federal court.  

Manhattan U.S. Attorney Geoffrey S. Berman said:  “As alleged, Eric Luna and Igor Goldshteyn, New York City employees, betrayed the trust placed in them and abused their powers to make purchases for their respective City agencies.  They allegedly sold over the internet hundreds of mobile phones intended for official use, and pocketed the proceeds of those illegal sales.  Now, thanks to DOI investigators, Luna and Goldshteyn are charged with serious crimes.”
Commissioner Mark G. Peters said:  “Abusing their authority to make purchases for their agencies, these defendants acted in separate schemes to greedily line their own pockets, by stealing hundreds of mobile devices meant for City use and selling them on online marketplaces for hundreds of thousands of dollars in profit, according to the charges. DOI thanks the United States Attorney for the Southern District and Verizon Wireless for their assistance and partnership in this investigation.”
According to the allegations in the Complaints[1]:
In April 2017, DOI investigators discovered that from at least in or about August 2015, hundreds of mobile telecommunications devices purchased by the FDNY and DYCD for use by agency personnel were being improperly diverted by LUNA and GOLDSHTEYN.  Both the FDNY and DYCD receive federal funds – the FDNY through grants from the Department of Homeland Security, and DYCD through grants from the Department of Housing and Urban Development.  LUNA and GOLDSHTEYN offered the devices for sale through third-party vendors over the internet.  The proceeds from the sales of these mobile devices went into LUNA’s and GOLDSHTEYN’s personal checking and online accounts.  
In separate complaints, GOLDSHTEYN, 42, of Staten Island, New York, and LUNA, 35, of Bronx, New York, are each charged with the theft of federal funds, and wire fraud.  The maximum statutory penalty for the theft of federal funds is 10 years in prison, and the maximum statutory penalty for wire fraud is 20 years in prison.  The statutory maximum penalties are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendants would be determined by the judge.
[1] As the introductory phrase signifies, the entirety of the texts of the Complaints and the description of the Complaints set forth herein constitute only allegations, and every fact described should be treated as an allegation.

A.G. Schneiderman Announces Record $42 Million Settlement With Bank Of America Merrill Lynch Over Fraudulent “Masking” Scheme In Electronic Trading Division

Bank of America Merrill Lynch Admits To Systematically Misleading Clients About How Stock Orders Were Handled; Admits to Violating New York’s Martin Act
$42 Million Penalty Is Largest Ever State Recovery In Connection With An Electronic Trading Investigation
  Attorney General Eric Schneiderman announced today that Bank of America Merrill Lynch (“BofAML”) will pay a record $42 million penalty to the State of New York to settle an investigation into fraudulent practices in connection with BofAML’s electronic trading services. As part of the settlement, BofAML admits that, pursuant to undisclosed agreements with so-called electronic liquidity providers (“ELPs”) such as Citadel Securities, Knight Capital, D.E. Shaw, Two Sigma Securities, and Madoff Securities, BofAML systematically concealed from its clients over a five-year period that it was secretly routing its clients’ orders for equity securities to such firms for execution. Attorney General Schneiderman’s investigation uncovered that BofAML made other misleading statements to its clients regarding several aspects of its electronic trading services—statements that made BofAML’s electronic trading services appear safer and more sophisticated than they really were. In addition to paying a penalty to New York State, BofAML admitted that it violated the Martin Act, New York’s securities law, and New York Executive Law § 63(12). 
“Bank of America Merrill Lynch went to astonishing lengths to defraud its own institutional clients about who was seeing and filling their orders, who was trading in its dark pool, and the capabilities of its electronic trading services,” Attorney General Schneiderman said. “As Wall Street firms offer increasingly complex electronic trading services, they cannot use new technology to exploit their clients in service of their business relationships with large industry players, like Bank of America Merrill Lynch did here.”
The Attorney General’s investigation revealed, and BofAML admits, that BofAML engaged in a multi-year fraud in connection with the operation of its electronic trading division. Beginning in 2008, BofAML intentionally and methodically concealed from its clients that it was routing millions of their orders for equity securities to ELPs like Citadel, Two Sigma, Knight, and others. Instead, BofAML told its clients that those orders were executing in-house at BofAML. The company  accomplished its fraud by re-programming its electronic trading systems to automatically doctor the trade confirmation messaging sent back to its clients after executions by these firms, in a process that BofAML employees referred to internally as “masking.” “Masking” involved replacing the identity of the ELP to whom the order was routed with a code indicating that the trade occurred in-house at BofAML. BofAML applied its “masking” strategy to over 16 million client orders between 2008 and 2013, representing over 4 billion traded shares.   
In order to avoid detection, BofAML also altered post-trade reports called “transaction cost analysis” reports, which are meant to help clients understand where and how their orders are executed. BofAML generated reports that reflected that BofAML was the venue where clients’ trades had executed, even though the trades had actually been executed by ELPs. BofAML also altered client invoices and other written documentation that would ordinarily reveal to clients where their trades had executed.
As set forth fully in the Settlement Agreement, the Attorney General’s investigation also uncovered that BofAML made other inaccurate representations to investors about BofAML’s electronic trading services, in an effort to make the firm’s electronic trading services look more sophisticated and safer than they really were: 
  • BofAML inflated its claims about the amount of retail orders routed to and executed in its dark pool, called “Instinct X.” Over several years, BofAML claimed that 20% or even 30% of the orders in its dark pool came from retail traders. OAG’s investigation determined that, in reality, BofAML’s retail client orders typically accounted for no more than 5% of the orders in Instinct X. BofAML also significantly overstated the number of retail orders that were in fact executed in Instinct X once routed there. 
  • BofAML touted a “Venue Analysis” that it purportedly used to find the best trading venue for its clients’ orders, and to avoid low-liquidity or otherwise “toxic” trading venues. Over several years, BofAML distributed marketing materials that purported to represent how BofAML’s trading algorithms made  “strategic” and “tactical” decisions about how and where to route client orders on an “order by order” basis. In fact, BofAML did not use that analysis to route client trades, and BofAML’s algorithms and order router did not access the analysis, or the data underlying it, to make trading decisions for clients. In addition, although the underlying data reflecting the performance of various venues changed over time, BofAML did not update the analysis it distributed to its clients.
Today’s settlement is the latest in a series of actions arising from the Attorney General’s Investor Protection Bureau’s initiative related to electronic and high frequency trading. In connection with those efforts, the Attorney General filed an action against Barclays in 2014, after uncovering evidence that Barclays made knowing and systematic misrepresentations to investors about how, and for whose benefit, Barclays operated its dark pool, and that Barclays exposed its clients to the predatory traders from whom it promised to protect them. As a result of its fraud, Barclays grew its dark pool to be the second largest in the United States.  In January 2016, Barclays settled with the NYAG for $35 million, admitted that it violated securities laws, and agreed to install an independent monitor to ensure the proper operation of its electronic trading division.
Also in January 2016, the Attorney General resolved an investigation of Credit Suisse’s practices relating to the operation of its dark pool, then the largest in the United States. The Attorney General found that Credit Suisse had made numerous misrepresentations regarding the operation of its dark pool, leading Credit Suisse clients to believe that they had the ability to avoid trading with high-frequency trading firms whose order flow Credit Suisse itself considered “opportunistic” and detrimental to institutional investors. Credit Suisse settled with the NYAG for $30 million.
In December 2016, the Attorney General announced the resolution of its investigation of Deutsche Bank, which revealed that it too had engaged in fraud in connection with its electronic trading services, in particular in its order routing practices. Deutsche Bank settled with the NYAG for $18.5 million and admitted that it violated New York State securities laws.
Barclays, Credit Suisse, and Deutsche Bank also settled parallel investigations into these matters with the SEC. 
As a result of Attorney General Schneiderman’s investigations regarding electronic trading at major Wall Street financial institutions, four firms have now agreed to pay $125.5 million in penalties to the State of New York for their wrongful conduct. 
“I urge all members of the financial community to evaluate and if necessary reform your practices around electronic trading services, to ensure that you treat each and every client, big and small, ethically and loyally. For those financial institutions that refuse to do so, we will hold you accountable,” said Attorney General Schneiderman.

Comptroller Stringer: Late Night Subway Service Drops 80% As Off-Peak Ridership Soars

Low-Wage Earners and Immigrants Stranded Most by Subway Crisis During Hours Outside “9 to 5”
Stringer Calls for Increased Service in the Early Morning and Evening and for the City to Immediately Fund the Lhota Emergency Plan
  A new report by New York City Comptroller Scott Stringer released today revealed a new, less visible but deeply alarming aspect of the MTA subway crisis: the massive drop-off in “off-peak” service. Comptroller Stringer’s new report – “Left in the Dark: How the MTA is Failing to Keep Up with New York City’s Changing Economy” – illustrates that while commuting patterns across New York City have changed, subway service has not. Despite 57 percent of all job growth in the last decade happening in the healthcare, hospitality, retail, restaurant, and entertainment industries, MTA subway service has failed to adapt to spiking ridership among those who don’t work a traditional “9 to 5”. These massive drop-offs in after-hours service affects lower-income, New Yorkers of color, and immigrants most.
 This new Comptroller Stringer analysis shows how New York City’s millions of service sector workers are being left in the dark by a subway system that isn’t just deteriorating during rush hours, but fundamentally failing to meet the needs of those who commute early in the morning and later into the evening. Today, the healthcare, hospitality, retail, food services, and entertainment industries account for 40 percent of private sector employment in New York City. Up until 2010, the MTA routinely added trains in the early morning to keep up with increasing ridership. Since the Great Recession, however, while ridership continued to surge between 5 a.m. and 7 a.m., the MTA did not respond accordingly—leaving riders to wait longer periods for trains that are more crowded.

Subway service to and from the Manhattan hub has not kept pace with growing ridership in the early morning (5 a.m. to 7 a.m.)

  • In New York City, these commuting and work patterns have been changing for decades. In 1985, half of the daily ridership into the Manhattan central business district occurred between 7 a.m. to 9 a.m. By 2015, this share dropped to just 28 percent.
  • Driven by the expansion of the city’s service sector, growth in tourism, and changing leisure patterns, off-peak subway ridership has rapidly expanded in the early mornings (5-7 a.m.) and evenings (7-11 p.m.). The MTA, however, has failed to respond to these trends. The MTA runs 60 percent fewer trains citywide from 5 a.m. to 6 a.m. than it does from 8 a.m. to 9 a.m., and 38 percent fewer from 9 p.m. to 10 p.m.

The number of trains beginning their route each hour

“During rush hour, we’re packed into subway cars like sardines. But outside traditional “9 to 5” travel, off-peak service is fundamentally failing to meet demand. It’s a crisis within a crisis, because over the past decade, the nature of our economy has changed and ridership late-nights and early mornings has risen while actual service to match it has not. That means that those who need service to get to work during non-traditional hours are stuck with a crisis not of overcrowding, but of infrequency,” Comptroller Stringer said. “We’ve looked at the human impacts of delays, the economic cost of slow-downs, and the crisis above ground with our bus system. Now, we’re showing how immigrants, New Yorkers of color, and lower-income neighbors are disproportionately affected by the off-peak subway crisis. The time for action is now. We need more service in the early morning and evening and we need to immediately fund the Lhota emergency plan to ensure those trains are actually running on time. Now more than ever, New York City needs to step up to support the MTA in this time of crisis.”
 Off-Peak Service is Failing to Meet Demand
 From 2010 to 2016, ridership in and out of the Manhattan hub jumped by 14 percent in the early morning and by 13 percent in the evening. The number of trains supplied by the MTA, however, did not keep pace, falling by three percent between 5 a.m. to 7 a.m. and rising by a meager three percent between 7 p.m. to 11 p.m.

Subway service in and out of the Manhattan hub did not keep pace with growing ridership in the early morning and evening from 2010 to 2016

Jobs during Non-Traditional Hours are Rising
 Many jobs in New York’s growing service sector operate outside of the traditional 9-to-5, with employees serving customers, clients, and patients early in the morning and late into the evening. As these sectors have grown – adding more than 350,000 employees in the last decade – it has had a profound effect on commuting patterns and subway ridership.

The share of subway and bus commuters departing for work during “traditional hours” (7-9 a.m.) is falling

Those traveling to work off-peak now account for nearly half (47 percent) of all subway and bus commuters, up from 39 percent in 1990. Further, in the last quarter century, the number of transit commuters departing for work outside of “traditional hours” (from 5 a.m. to 7 a.m.) rose by 39 percent, while the number of “traditional” commuters grew by only 17 percent. That means demand for off-peak service is rising faster than demand for rush-hour service.
Yet service is dramatically diminished during early morning (5:30 a.m. to 6:30 a.m.) and later evening (8:30 p.m. to 10:30 p.m.) travel – just when many service sector workers depend on public transit. During these times:
  • In the early morning, only 43 percent of train lines have wait times of less than 10 minutes and zero have wait times of less than five minutes.
  • In the evening, under half of subway lines maintain wait times of less than 10 minutes and only 10 percent maintain frequencies of less than 5 minutes.
The problem is particularly acute in neighborhoods with significant retail, restaurant, health, hotel, and cultural employment.
  • The neighborhoods most adversely impacted by infrequent train service include Lenox Hill-Roosevelt Island, East Harlem, Washington Heights South, Borough Park, Flushing, Forest Hills, Elmhurst, and Jamaica.
  • These are neighborhoods with over 10,000 service sector jobs, which constitute more than half of total employment in the area, and receive 50% less subway service during the early morning (5:30-6:30 a.m) than in rush hour (7:30-8:30 a.m.).
Lower-Income New Yorkers Hurt Most by Subway Crisis
Those departing for work during “traditional” hours (7 a.m. to 9 a.m.) have very different economic profiles than “non-traditional” subway and bus commuters.
New Yorkers commuting between 5 a.m. and 7 a.m. earn $7,000 less than their rush hour counterparts and are more likely to be foreign born, a person of color, without a bachelor’s degree, and working in the service sector

Economic Profile of Traditional and Non-Traditional Subway and Bus Commuters

“Traditional” Commuters      “Non-Traditional”        Commuters

(departs 7am-9am)      (departs 5am-7am)
Median Income $42,300.00 $35,000.00
Bachelor’s Degree or Higher (Age 25+) 52.00% 31.00%
Foreign Born 47.00% 56.00%
Person of Color 64.00% 78.00%
Work in Healthcare, Hospitality, Retail, Food Services, or Cultural industries 36.00% 40.00%
Growth in the Last Quarter Century 39.00% 17.00%


Year Four Report details comprehensive citywide efforts made around engineering, enforcement and education; in 2017, New York City had its fourth consecutive year of declining traffic fatalities, strongly countering national trends

  Mayor Bill de Blasio today announced the release of the City’s Vision Zero Year Four Report, a comprehensive review of the first four years of the groundbreaking safety initiative. In 2017, New York City experienced its safest year on record with the fourth straight year of fatality declines.  Since the program’s inaugural year in 2014, when New York City became the first American city to adopt Vision Zero, the city’s traffic fatalities have declined 28 percent with a 45 percent decline in pedestrian fatalities — bucking national fatality trends, which have increased 15 percent over the same period.

“Vision Zero is working. We have lowered the speed limit, increased enforcement and created safer street designs, efforts that build on each other to help keep New Yorkers safe,” said Mayor de Blasio. “The report we are releasing today shows the promising results so far, but also illustrates how far we must go to deepen this work. Not even a single tragedy on our streets is acceptable, and we’ll keep fighting every day to protect New Yorkers.”

The report illustrates several of the elements of the data-driven Vision Zero initiative that have delivered results:

·    Using detailed crash and injury data, New York City created Borough Pedestrians Safety Action Plans, directing its investments at high priority locations across the five boroughs. The original priority locations introduced in 2015, based on 2009-2013 data, averaged 142 traffic deaths per year in that period. In 2017 that number was 100 deaths, a 30 percent decline.
·      Pedestrian fatalities have seen the greatest fatality decline among all modes of travel, dropping by 45 percent, from 184 in 2013 to 101 in 2017.
·    The Year Four report takes a closer look at demographic groups, types of locations or periods in the day which carry a disproportionate concentration of severe and fatal crashes.
·   The report look at the myriad ways agencies implement the initiative and a look ahead to new initiatives launching in 2018.

“Thanks to the incredible work of everyone at DOT, the NYPD, and our agency partners, the first four years of Vision Zero have been the safest ever on our city streets.  Vision Zero has truly saved lives — of family members, friends, neighbors and fellow New Yorkers,” said DOT Commissioner Polly Trottenberg. “In 2017, under the Mayor’s leadership, DOT's work helped fuel a historic drop in pedestrian fatalities, including through a record number of safety redesigns and by reprogramming a record number of traffic signals that give pedestrians a head start in crosswalks.  However, the number of lives lost on our streets is still too high, including the increases in fatalities we saw last year among cyclists, drivers and motorcyclists.  We know we have much more work to do to fully achieve Vision Zero.”

“Four consecutive years of decreasing traffic fatalities in the City is a good indication that the Vision Zero Initiative is working,” said Chief Thomas Chan, the NYPD’s Chief of Transportation. “This Mayoral initiative owes its life saving successes to the collaborative effort of its Vision Zero inter-agency oversight.  The “Vision Zero Year Four Report” highlights some of the great work that laid the groundwork for these successful results. In 2017, the NYPD again increased its enforcement against dangerous driving violations identified as the leading causes of traffic fatalities; speed enforcement increased 9.2%, texting while driving increased 36.3%, and failure to yield to pedestrians increased 22%.  In 2018, the NYPD looks forward to working with the Vision Zero team to reach yet another traffic safety landmark.”   

“Professional drivers are pivotal to the Vision Zero work ahead of us, and the TLC has continued its extensive, multilingual outreach to drivers and bases on important safety issues like fatigue,” said TLC Commissioner Meera Joshi.  “More than 35,000 drivers completed the TLC Driver Education course last year.  Since taxi and for-hire vehicle drivers use our streets significantly more than other drivers, we hold them to a high standard and TLC enforcement continues to focus on traffic safety.  Our staff are highly responsive to public complaints and worked hard to hold drivers accountable for safety violations.  We also celebrated the accomplishments of more than 400 of our safest drivers, who completed millions of miles of safe trips last year without violation or injury.”

“NYC operates the largest fleet in the City and is working to make it the safest,” said DCAS Commissioner Lisette Camilo. “In 2017, DCAS completed a first Safe Fleet Transition Plan for our fleet which will ensure we specify and procure the safest possible fleet vehicles possible, including automatic braking, truck side-guards, and backup cameras, and will serve as a model for other public and private fleets.  We will continue to work with all our partner agencies to achieve Vision Zero.”

“The Vision Zero Year Four report highlights the extraordinary work accomplished by the City and our partners,” said Emily W. Newman, Acting Director of the Mayor’s Office of Operations. “But as we enter year five we know there is much more work to be done to make our streets safer and protect the lives of New Yorkers. As the Chair of the Vision Zero Task Force, we remain focused on one vision: vision zero.”

“Vision Zero has made a real difference in driving down the number of traffic deaths in New York City,” said Health Commissioner Dr. Mary T. Bassett. “However, traffic deaths and injuries remain a serious public health concern, particularly among cyclists, drivers and motorcyclists. I commend Mayor de Blasio and Commissioner Trottenberg for their work to protect New Yorkers through Vision Zero.”

Street Design
DOT continues to focus on proven methods of reducing fatalities and serious injuries through the implementation Street Improvement Projects (SIPs), installation of Leading Pedestrian Intervals (LPIs), addressing left turns at intersections and building out the on-street bike network, particularly Protected Bike Lanes.  In the fourth year of Vision Zero (2017) DOT made major advances on these fronts:

·         Completed 114 SIPs, 76 of them in Vision Zero Priority Locations, a 138 percent increase over the five year average leading up to Vision Zero.
·      Added 832 LPIs, giving pedestrian a head start where drivers are turning and preserving their right of way. With over 2,000 of these installed under Vision Zero, pedestrian and cyclist KSI numbers have declined 37 percent at these locations.
·     Continued to implement Left Turn Traffic Calming interventions. Over 200 intersections have received this treatment, including 110 in 2017.
·    Continuing to build out the bike network. Last year DOT added over 77 lane miles to the bike network, including a record of 25 Protected Bike Lane miles.
·      A continued success of the agency camera enforcement program: speed camera, bus lane cameras and red light cameras.  The City is currently advocating in Albany for legislation expanding the speed camera program in an effort to increase and broaden the school zones.  Speed cams have proven to reduce speeding in school zones by 63%.

In 2017, the NYPD focused its enforcement to affect a change in the behavior of persons who disregard the importance of traffic safety. The NYPD officers issued 684,910 Vision Zero summons which were issued to drivers who violated the traffic laws identified as the primary causes  of collisions with the most catastrophic results, these violations included Speeding, Failure to Yield to a Pedestrian, Utilizing a Cell Phone While Driving and Texting while Driving. This is up 7.3% from 2017 and 20.2% from 2014. In addition, the NYPD continued to target drivers who violated the crime AC.19-190 which is violated when drivers fail to exercise due care and cause an injury to a pedestrian or bicyclist who has the right of way. In 2017, the NYPD took 2,255 total enforcement actions against these violators an increase of 12.5% from 2016. 

For-Hire Vehicles
In 2017, TLC field enforcement officers issued 59% more traffic safety summonses compared to 2016, with significant emphasis on speeding and distracted driving.  The TLC also pursues complaints from the public about safety infractions that include vehicles stopped in bike lanes and blocked crosswalks, a valuable complement to field enforcement and driver education efforts. TLC has held more than 500 Vision Zero driver outreach meetings and honored 420 drivers and 25 businesses last fall for their impeccable safety records, the highest number of honorees in all four years of the event.  The TLC also held a Fatigue Prevention Outreach Week last spring to educate driver about the risks of driving while tired and to raise awareness about new rules to keep tired drivers off the roads. 

Leading the Way with the City’s Fleet
In 2017, DCAS published its Safe Fleet Transition Plan in conjunction with the US DOT Volpe Center in May 2017. This plan stipulates that all vehicles purchased for Fiscal Year 18 and beyond must include the best available safety technology including, where applicable, automatic emergency braking, rear and side truck guards, and back up cameras. In addition, the City has installed over 1,350 truck sideguards on NYC Fleet vehicles, making it the largest program of its kind in the nation. Sideguards have been shown to reduce the deadliness of truck collisions with pedestrians by 20% and with bicyclists by 60%.

Using Data to Guide Efforts and Understand Crashes as a Public Health Imperative
In 2017, DOHMH completed a data matching process to link hospital records with crash reports. Using the linked dataset, staff identified patterns of injuries, injury type, body part injured, and injury severity associated with crash characteristics. These patterns can help describe, among other things, the disproportionate impact of traffic injuries on particular populations, such as children and older adults. Among the matched cases, injury severity is higher among older adults, pedestrians, and motorcyclists.

Select Year 5 New Initiatives
·         Update Borough Pedestrian Safety Action Plan priority maps based on an analysis of KSI data from 2014-2016, the first three years of Vision Zero
·    Intensify street safety improvements in areas with high senior citizen concentrations and pedestrian injuries to seniors
·    Implement Bicycle Priority Districts to increase lane network mileage in areas demonstrating disproportionate KSIs relative to their infrastructure
·     Convene a working group to develop a Vison Zero-based driver education program for those under age 25
·      Proactively identify intersections at which new traffic signals would likely be warranted by using data analysis