The Decisions Behind the Disclosures

White lettering on black reads “The Decisions Behind the Disclosures” above “Peter Duffy Demands The Approval Records”.

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Scott Sperling chairs the board of Mass General Brigham (MGB) and co-leads THL Partners;1 his firm invested in U.S. Nursing Corporation, a supplier of scab labor, in 2015.2 Marc Casper, the chairman and chief executive of Thermo Fisher Scientific (Thermo Fisher), sits on MGB’s board with Sperling.3 Sperling serves as Thermo Fisher’s independent lead director,4 and MGB’s fiscal 2024 return discloses a “business relationship” between Casper and Sperling.5

Peter Duffy, an attorney for the Massachusetts Nurses Association (MNA), asks Massachusetts Attorney General (AG) Andrea Joy Campbell to obtain the records behind MGB’s decisions; his October 6th, 2026 letter specifies “contracts, amendments, invoices, payments, and allocation records”.6 The letter puts the governing question directly: “The question is how those safeguards were applied to these substantial transactions”.7 I want Campbell to test the decisions against the safeguards MGB says it applies.

The letter reports recruitment by U.S. Nursing Corporation for Brigham and Women’s Hospital assignments, drawing on the MNA’s separate memorandum.8 Duffy asks Campbell to establish the interests at each staffing commitment and to examine the disclosure and management of those financial interests.9 I want Campbell to match the ownership and exit records to the staffing commitments and follow the money through the approvals.

My earlier essays have followed this trail through the financial machinery of MGB.10 In “Inside the MGB Financial Machine”, I call for the reviewing body’s identity and the recusal record behind overlapping management relationships.11 In “The 37 Connectors”, I call for vendor, conflict, recusal, fairness, and approval records behind relationships involving Thermo Fisher.12 In “The Wizard of Revolution Drive”, I call for governing plan documents and a transparent route to sensitive committee records.13 The pension questions have their own legal basis, while the commercial relationships require their own approval history.

I’m not ashamed to toot my own horn. My earlier essays called for the records behind Mass General Brigham’s decisions; those published demands still await the records. Mass General Brigham employees should treat that unanswered demand as a warning and insist on the record behind the assurances. Duffy’s letter puts the demand for commercial approval records before Campbell’s office.14 My research supplies the transaction history and the policy provisions needed to press the inquiry.

The Staffing Decision

Brigham and Women’s Hospital (Brigham) excluded nurses for four days after the Massachusetts Nurses Association (MNA) one-day strike ended in July 2026, while clinicians at Mass General Brigham Home Care undertook a seven-day strike.15 Boston.com reported that the hospital attributed the additional four days to replacement-staffing contracts and maintained that the hospital remained open and fully operational.16 The approval file needs to identify the officials who accepted the staffing commitment, the decision dates, and the basis for those terms.

Ingenovis Health includes U.S. Nursing Corporation (U.S. Nursing), a business that provides staffing during labor disputes.17 Peter Duffy reports in his October 6th, 2026 letter that the union’s separate memorandum identifies recruitment for Brigham and Women’s Hospital assignments by the staffing company.18 The Boston Globe identified U.S. Nursing as Brigham’s contractor.19 Duffy raises the possibility of a financial connection through THL Partners, the investment firm Scott Sperling leads as co-chief executive.20 The purchase deserves examination as a decision about bargaining power.

U.S. Nursing describes its bargaining function in the 2021 acquisition announcement: the company “helps facilities negotiate from a position of strength”.21 The service lets hospitals keep operating while their nurses withhold labor. A hospital that buys that capacity buys time to resist the union’s demands. U.S. Nursing advertises more than 400 job-action engagements, more than 220 clients nationwide, and more than 50,000 professionals deployed, with staffing for disputes lasting a day or continuing indefinitely.22 The operation gives hospital management access to a workforce assembled to cross a picket line.

The Staffing Goliath

Thomas H. Lee Partners, now branded THL Partners, invested in Fastaff Travel Nursing and U.S. Nursing Corporation (U.S. Nursing) in 2015.23 Franklin Square Capital Partners announced a loan of about $150 million to Healthcare Staffing Services that supported THL Partners’ acquisition of a majority stake.24 The investment put private equity capital behind a business that was already supplying nurses to hospitals.

Brigham and Women’s Hospital (Brigham) contracted with U.S. Nursing in 2016.25 The strike planned for June 27th was averted through a settlement.26 Partners HealthCare System reported about $8 million in replacement costs and about $16 million in lost revenue.27

Tufts Medical Center used U.S. Nursing during the Massachusetts Nurses Association (MNA) dispute in July 2017, when a one-day strike was followed by a four-day lockout.28

Berkshire Medical Center hired U.S. Nursing under a five-day contract for the October 3rd, 2017 strike and the four-day lockout that followed.29 The MNA requested the contract in September; the hospital’s December copy blacked out 630 of 675 lines, according to the union.30 The union had to fight for the contract after its members had already faced the replacements.

The MNA reported in April 2018 that a regional office of the National Labor Relations Board found merit in its charge over the withheld information and called for the unredacted contract with attachments.31 I want AG Andrea Joy Campbell to extend Peter Duffy’s inquiry to Brigham’s 2016 agreement and its approval and payment records. My earlier demands supply the test: the approving officials; their disclosed interests; and the basis for the decision.

The Massachusetts Nurses Association backed Question 1 in 2018, a proposal to limit nurses’ patient assignments by unit and level of care.32 Partners HealthCare System, now Mass General Brigham, supplied about $26,000 in staff time and supplies to the opposition committee, the Coalition to Protect Patient Safety.33 The voters rejected the proposal on November 6th, 2018.34 The filings identify the resources; the authorizations would name the officials who committed the expense. I want Campbell to extend Duffy’s inquiry and my earlier demands to the decisions authorizing the expense, the accounts charged, and the claim of charitable purpose.

Cornell Capital and Trilantic North America announced in February 2021 that they’d acquired Trustaff Management and CardioSolution and had agreed to acquire the recruiting platform Stella.ai.35 The announcement later that month added an agreement to acquire Fastaff Travel Nursing and U.S. Nursing Corporation, with THL Partners remaining an investor in the combination.36 Ingenovis Health emerged from that assembly of staffing businesses and recruiting technology.

MNA associate director Wendy McGill asked attorney Anthony Rizzotti at Littler Mendelson, P.C., on March 25th, 2021, for every contract entered that year with an agency supplying registered nurses at Saint Vincent Hospital in Worcester.37 The MNA identified U.S. Nursing as the hospital’s replacement supplier, according to Becker’s Hospital Review.38 Campbell needs Brigham’s corresponding contracts to answer Duffy’s letter and my earlier records demands.

McLean Hospital, a member of Mass General Brigham, hired Littler Mendelson and Crossroads Labor Consulting Group during an organizing campaign by the American Federation of State, County and Municipal Employees, Council 93. McLean Hospital chief of staff Adriana Bobinchock confirmed the hiring to GBH News in April 2022. My July essay “Hub Hospitals Hate Health Care” cited that report.39

The National Labor Relations Board lists Rizzotti of Littler Mendelson, P.C., as counsel for Brigham in a 2022 case and for Mass General Brigham in a 2026 case.40 Jennifer “Jen” DeVincent, the MNA representative for the Mary Horrigan Connors Center for Women and Newborns at Brigham, told me she’s negotiated directly with Rizzotti. DeVincent said the first meeting was October 28th, 2025, and the most recent was October 10th, 2026.41

I want the engagement records to identify the work Brigham and Women’s Hospital and its parent system, Mass General Brigham, assigned to Rizzotti and his firm. Campbell needs to match that work to the vendor’s selection, the review of financial interests, and the approval of the staffing commitment. Campbell needs McLean Hospital’s engagement agreements, payment records, and approval records alongside the records Duffy seeks.

THL Partners describes work during its partnership as “organizational transformation”, including sales integration and digital nurse recruitment.42 Ingenovis Health reported more than $2 billion in annual revenue in March 2023 and approximately 6,000 healthcare providers onsite during labor disruptions in 2022.43 Ingenovis Health had also acquired HealthCare Support, VISTA Staffing Solutions, and Springboard Healthcare.

Ingenovis Health listed eight brands in March 2026: Fastaff (Fastaff Travel Nursing); Trustaff (Trustaff Management, also known as Trustaff Travel Nurses); U.S. Nursing Corporation (USN); HealthCare Support; Springboard Health (Springboard Healthcare); VitalSolution (formerly CardioSolution); VISTA Staffing (VISTA Staffing Solutions); and Corazon.44 The group brought ordinary staffing and strike replacement services under the same corporate roof. The acquisitions had helped build a staffing Goliath with a business devoted to supplying scab labor.

Ingenovis Health announced in May 2026 that it’d completed financing led by Cornell Capital and Trilantic North America, which invested about $100 million for a new issue of preferred equity.45 Davis Polk & Wardwell LLP, counsel on the restructuring, reported a reduction of more than $500 million in first-lien debt and the creation of a credit facility of about $275 million.46 Campbell needs the terms governing the new equity and the treatment of existing investors.

THL Partners now labels Ingenovis Health an “Exited” investment without an exit date.47 The ownership records, restructuring agreements, and exit agreements must identify interests held at each staffing commitment and trace their later disposition, distinguishing ownership in the company from interests in the funds holding its securities. Did THL Partners or its co-chief executive Scott Sperling specifically, and Thermo Fisher Scientific and its chairman and chief executive Marc Casper broadly, stand to benefit when the hospital committed to replacement staffing?48

The Money Behind the Staffing

Mass General Brigham (MGB) draws revenue from care that its nurses help deliver. The institution can spend that revenue on a supplier selling strength against a nurses’ strike. I want the financial record behind a system in which workers help generate the resources used to resist their demands.

Brigham and Women’s Hospital needs to produce the executed contract and account for the staffing commitment and its decision to impose the four-day lockout. Did the agreement promise five days of pay, five days of work, or five days without the bargaining unit? The proposals, contract, and amendments must establish the duration of the commitment, the minimum payments, and the cancellation rights, with approval communications identifying the officials responsible and their decision dates.

The invoices must trace each payment from the entity and account charged to its recipient, and the ownership records must identify the beneficial owners at each commitment date and any proceeds they received. The staffing rosters, service schedules, and records of incidents or postponed care must account separately for the hospital and Mass General Brigham Home Care. The approval file must identify the vendor’s selectors and the officials who authorized the additional days. The record must include their evaluation of costs and consequences for patient care. Peter Duffy asks AG Andrea Joy Campbell to trace any effect of an established vendor conflict on the duration or financial terms.49

The Approval Record

The fiscal 2024 parent return from Mass General Brigham Incorporated (MGB) reports the four transactions highlighted in the letter from Peter Duffy. The entries identify nearly $49 million for Suffolk Construction services with MGB director John Fish; more than $8 million for an NPP Development lease and about $1.5 million for NPS LLC marketing with MGB director Jonathan Kraft; and just over $700,000 for InterSystems products and services with MGB director Phillip “Terry” Ragon. AG Andrea Joy Campbell needs the approval records behind about $59 million in reported transactions.50

The fiscal 2025 parent return reports transactions with the same four businesses totaling about $48 million.51 An investigator needs the agreements and amendments to identify the obligations and services behind each year’s entries. The returns report transaction amounts; the contracts and payment records must establish the obligations incurred and the cash paid.

The parent filing identifies the board chair and the relevant entity’s president and chief executive as reviewers of directors’ disclosures, assisted by counsel; its account of fairness determinations requires that “A WRITTEN RECORD MUST BE MADE OF THESE DETERMINATIONS”. The filing also describes independent committee review for particularly significant conflicts.52 Campbell needs each director’s disclosures and recusals documented alongside the transaction’s comparisons, approvals, and minutes; those records must identify each director’s financial interests and participation in selection or oversight.53

Marc Casper, the chairman and chief executive of Thermo Fisher Scientific (Thermo Fisher), and MGB board chair Scott Sperling serve together on both boards;54 the fiscal 2024 return discloses their “business relationship” and assigns the MGB board chair a role in reviewing directors’ conflict disclosures.55 My essay “The 37 Connectors” documents relationships between MGB and Thermo Fisher and calls for the records behind their review.56 I want Campbell to extend Duffy’s inquiry to those relationships and obtain the records that identify the reviewers, disclose their recusals, and document the determinations.

The MGB policy titled “Policy for Interactions with Industry and Other Outside Entities” requires a written determination before a purchase covered by section 5.5.4 proceeds.57 The Committee on Outside Activities sets the thresholds that trigger this procedure, and the Office for Interactions with Industry must document even a finding of no qualifying financial interest or relationship. A qualifying interest triggers a written determination of fairness and the institution’s best interest. The policy requires consideration of “at least two alternative disinterested competitive proposals”, or a finding that such proposals don’t exist or are impractical to solicit, with an explanation for proceeding without those alternatives.58 An examiner needs the governing version, the threshold schedule, and the transaction category before applying that test; the NPP Development lease needs its own determination of the applicable provision and its trigger.

The policy permits discussion and recommendations under section 5.5.3’s stated conditions, excluding final decision-making from that permission; the Committee on Outside Activities can establish further exceptions.59 The approval file needs to distinguish participation in a discussion from authority to decide. The disclosures, permissions, and minutes would identify each participant’s role.

MGB spokesperson Jessica Pastore rejected the letter and cited conflict safeguards and competitive bidding in comments to The Boston Globe.60 The competing proposals, the proposal evaluations, and the fairness findings would let officials test those assurances against the process described in the return. I want Campbell to obtain the commercial approval records behind those assurances. The Employee Benefits Security Administration (EBSA), part of the United States Department of Labor, investigates fiduciary violations involving private employee benefit plans.61 I want EBSA to obtain the pension records behind my earlier demands.

The Contract and the Cost

Brigham and Women’s Hospital reported almost $7 million for NPP Development under “Lease/Construction” and nearly $8 million for Suffolk Construction services in its fiscal 2009 return.62 Partners HealthCare System and Affiliates reported another NPP Development transaction in fiscal 2014: more than $3 million, identified as “LEASE – BWH”.63 An investigator needs the original agreements and their amendments to separate the combined 2009 category into rent and construction before a lease comparison begins.

Brigham and Women’s Hospital and Massachusetts General Hospital opened their joint center at Patriot Place in 2009.64 An expansion opened in November 2019 across the street from the existing center at 22 Patriot Place.65 The NPP Development agreements need to map each payment to the premises, the services, and the term before a price comparison can establish value.

The NPS LLC marketing entry needs a contract identifying the services or rights supplied. Mass General Brigham and Kraft Sports + Entertainment announced a sponsorship covering the New England Patriots, the New England Revolution, and Gillette Stadium on December 20th, 2021; the announcement described Massachusetts General Hospital’s longstanding care of players as “Separate from and unrelated to this sponsorship”.66 An investigator needs to establish any connection to the sponsorship and value the contracted services on their own terms.

The Suffolk Construction entries need an account of the contracted work, the change orders, and the explanations for any material cost increases. The InterSystems entries need the license agreements, delivery records, and comparisons supporting the price. The public descriptions of earlier work and customer relationships cannot identify the purchases behind these reported amounts; the invoices must connect the amounts to the work delivered.67

Mass General Brigham and Affiliates reports more than $7 million for NPP Development and about $34 million for Suffolk Construction in its fiscal 2024 group filing.68 The parent and group returns cover different filing populations; the allocation records must reconcile the entries before anyone adds the figures or assigns an expense to a hospital. I want an account naming the contracting entity, the charity charged, and the institution that received the benefit.

The Compensation Decision

Mass General Brigham reports about $9.2 million in compensation for president and chief executive Anne Klibanski in its fiscal 2025 return, compared with about $8.4 million in the previous return.69 Internal Revenue Service rules place the compensation in calendar 2024 and calendar 2023, respectively; the filing’s fiscal-year label doesn’t identify the compensation period.70 The increase is almost $800,000, or about 9.2 percent.

Klibanski’s base pay rose from about $2.4 million to about $2.8 million, and retirement and deferred compensation rose from about $1.5 million to about $2.1 million.71 The bonus and incentive component fell from about $4.3 million to about $4.2 million.72 The salary agreements, retirement arrangements, and incentive measures need separate examination because the increase came from different components of the package.

The parent returns describe a board committee that uses independent advice on compensation, excludes conflicted members, and records its decisions in minutes.73 The federal regulation gives qualifying arrangements a rebuttable presumption of reasonableness when a body with approval authority and no conflict of interest approves in advance, relies on appropriate comparisons, and records the basis for its decision in contemporaneous documentation.74 The approval file needs the comparison group and covered positions, the terms governing deferred amounts, and the evidence supporting the award.

The Attorney General’s Next Step

The Massachusetts General Laws charge the attorney general with protecting charitable funds;75 the cases that Peter Duffy cites explain that enforcement role,76 and an investigation under chapter 12, section 8H requires the attorney general’s application and judicial approval.77 Maura Healey, now the Massachusetts governor, served as attorney general from 2015 through 2023.78 Healey’s office raised concerns about a proposed Partners HealthCare merger in 2015 and demanded records under chapter 12C, section 17 for its 2021 examination of Mass General Brigham’s proposal to expand ambulatory care.79

Norwood Hospital closed after flooding in June 2020. The financial problems at Steward Health Care (Steward) later stalled reconstruction.80 The Massachusetts Legislature identifies Steward as a private equity-backed operator and Medical Properties Trust, a real estate investment trust, as the property owner.81 Healey signed the Norwood eminent-domain law on August 6th, 2026. Massachusetts can take the property after the law takes effect on November 1st, subject to funding, a qualified nonprofit bid, and the required notice.82

Healey demanded Steward Health Care’s financial records on February 20th, 2024.83 AG Andrea Joy Campbell addressed the Steward bankruptcy on May 6th, 2024: “My office is working to get answers and we intend to seek accountability for any laws that may have been violated”.84 I want Healey to back the Massachusetts Nurses Association’s records demand and Campbell to obtain the commercial approval records identified in Duffy’s letter and my earlier essays, applying that accountability standard to Mass General Brigham (MGB).

The records would let officials test the directors’ conduct against their duties of good faith, care, and service to the corporation’s interests.85 The tax inquiry concerns private inurement and excess benefits; any conclusion depends on the entity’s status, the recipient’s status, and the value transferred in relation to the consideration received.86 Duffy seeks recovery of diverted funds, correction of conflicted arrangements, independent oversight, judicial relief, or regulatory referrals as findings warrant, including to the Internal Revenue Service.87

The Massachusetts Office of Campaign and Political Finance records contributions to the Healey Committee and the Campbell Committee from Mass General Brigham directors and their relatives.88 My review follows both committees across the offices sought from October 12th, 2006, through October 12th, 2026.89 The Kraft family receipts total $7,500 for Healey’s committee and $17,000 for Campbell’s, with gifts from MGB director Jonathan Kraft, his wife Patricia “Patti” Lipoma Kraft, his brother Joshua “Josh” Kraft, his father Robert Kraft, and Dana Kraft, who married Robert Kraft after her first counted gift.90 The Fish family’s $27,000 for Healey and about $6,000 for Campbell came from MGB director John Fish, his siblings, and Gretchen Fish, the wife of his late father, Edward Fish; three refunds reduce Healey’s total to $24,500.91 MGB director Terry Ragon and his wife, Susan Ragon, gave $1,000 each to Healey’s committee, and MGB president and chief executive Anne Klibanski gave about $4,000 to Healey’s committee and $200 to Campbell’s committee.92

Josh Kraft ran for mayor of Boston in 202593 and gave Healey’s committee $500 on March 26th of that year.94 My skepticism of government makes these family contributions pertinent: the verified donors account for about $40,000 in receipts to Healey’s committee and about $23,000 to Campbell’s, with refunds reducing Healey’s total to about $38,000.95 I want Campbell’s office to account publicly for its handling of a request involving businesses connected to her campaign contributors.

I want Campbell’s office to name the evaluating attorney and seek preservation of Duffy’s requested records.96 Duffy offers a meeting and a separate memorandum and copies MGB for a response.97 Campbell’s office needs that memorandum and its underlying materials to examine the decisions.98

Brigham and Women’s Hospital announced on October 11th that the Massachusetts Nurses Association had withdrawn its October 14th strike notice to put the hospital’s offer before its members.99 The hospital distinguished that step from a final contract and said it wouldn’t implement its contingency staffing plan. A withdrawn strike notice changes the immediate labor dispute; the earlier spending decisions still have an approval history to examine.

I want Campbell to establish the contracting entities, the interests at the time, and the officials responsible for the decisions. Campbell needs an account of the basis, the price paid, and the charity’s benefit for each decision. MGB’s nurses helped build the institution that purchased their replacements. The records must show the price of that choice and the financial interests it served. A policy written in the charity’s name deserves a record identifying the people who acted for the charity.

Source Notes

  1. Thermo Fisher Scientific, 2026 Proxy Statement, board leadership and director compensation; current biographies for Marc Casper and Scott Sperling, checked October 12th, 2026. THL Partners’ Scott Sperling Biography identifies his co-chief executive role and his chairmanship of Mass General Brigham. Sperling’s reported director compensation for 2025 totals $437,728, including $168,036 in fees earned, $225,028 in stock awards at grant-date value, and $44,664 in other compensation; the total is not cash received. Mass General Brigham’s fiscal 2025 roster in note 69 lists Casper as a director and Sperling as chairman. The roles establish governance overlap; neither man’s title establishes that Casper supervises Sperling or that either participated in a Mass General Brigham transaction. Thermo Fisher Scientific is an extension of this essay’s inquiry beyond the vendors named in Duffy’s letter. ↩︎
  2. Fastaff Travel Nursing, Cornell Capital and Trilantic North America to Acquire Fastaff and U.S. Nursing, February 24th, 2021. The release identifies Thomas H. Lee Partners as the owner of Fastaff Travel Nursing and U.S. Nursing Corporation (U.S. Nursing), dates its investment to 2015, and says the firm would remain an investor in the combined business. The company description identifies U.S. Nursing’s business as strike preparation and staffing during labor disputes. The release announces an agreement and projected closing; it does not disclose the final ownership percentage. ↩︎
  3. Thermo Fisher Scientific, 2026 Proxy Statement. The full citation and source limits appear in note 1. ↩︎
  4. Thermo Fisher Scientific, 2026 Proxy Statement. The full citation and source limits appear in note 1. ↩︎
  5. Mass General Brigham Incorporated, Form 990 for the Fiscal Year Ended September 30th, 2024, EIN 04-3230035. Relevant locations: Schedule L, Part IV, entries 7–10, PDF page 68; Schedule O, response to Part VI, line 2, PDF page 70; responses to lines 12C and 15, PDF page 71; Schedule J, Part II, PDF page 47. Anne Klibanski’s components are $2,384,133 base, $4,284,478 bonus and incentive, $174,804 other reportable, $1,536,300 retirement and deferred, and $28,101 nontaxable benefits, totaling $8,407,816. The Fiscal 2025 Parent Schedule L, entries 5–8, supplies the following year’s transaction amounts for the same filer and relationship descriptions: Suffolk Construction, $37,013,033; NPP Development, $8,425,484; NPS LLC, $2,050,000; and InterSystems, $878,405. The four entries total $48,366,922, down $11,017,841 from fiscal 2024. The Suffolk Construction entry falls by $11,951,539; the NPP Development entry rises by $214,644, the NPS LLC entry by $550,000, and the InterSystems entry by $169,054. The annual totals do not establish identical contracts or deliverables. The transaction totals are reported amounts rather than established losses to the charity or personal proceeds to the directors. ↩︎
  6. Peter Duffy, Pollack Solomon Duffy LLP, Request for Investigation of Mass General Brigham, submitted on behalf of the Massachusetts Nurses Association, October 6th, 2026. The letter references a separate memorandum that is not included in this public document. The letter is a request for investigation, not a finding or a civil complaint. The addressee is Jonathan Green, chief of the Non-Profit Organizations/Public Charities Division in the attorney general’s office; the letter asks the attorney general to exercise her authority and supplies no proof of Andrea Joy Campbell’s personal receipt or review. The materials reviewed through October 12th establish neither an opened investigation nor an official refusal. The letter’s three supporting web links appear in notes 47, 45, and 69. Massachusetts Attorney General’s Office, Attorney General Andrea Joy Campbell Outlines Priorities in Historic Inaugural Address, January 18th, 2023. The release identifies Campbell as the forty-fifth attorney general and dates her oath to that day. ↩︎
  7. Peter Duffy, Pollack Solomon Duffy LLP, Request for Investigation of Mass General Brigham. The full citation and source limits appear in note 6. ↩︎
  8. Peter Duffy, Pollack Solomon Duffy LLP, Request for Investigation of Mass General Brigham. The full citation and source limits appear in note 6. ↩︎
  9. Peter Duffy, Pollack Solomon Duffy LLP, Request for Investigation of Mass General Brigham. The full citation and source limits appear in note 6. ↩︎
  10. Jonathan Bowen, Mass General Brigham Series, eight published essays. ↩︎
  11. Jonathan Bowen, Inside the MGB Financial Machine, public text checked October 12th, 2026. The passage beginning “When a manager whose funds the Master Trust holds” calls for the reviewing body, the recusals, and the record of compliance. The subject is pension investment authority and the application of the conflict policy. ↩︎
  12. Jonathan Bowen, The 37 Connectors, “The Governance Gate” and “The Source Record”, public text checked October 12th, 2026. The essay asks the institution to identify the office or governance body responsible for each documented connection and disclose the relevant conflict, fairness, approval, selection, and vendor records. The disclosure demand does not establish that the pension investment committee handled those commercial relationships. ↩︎
  13. Jonathan Bowen, The Wizard of Revolution Drive, “The Missing Instruments” and “The Somerville Test”, public text checked October 12th, 2026. The essay distinguishes ordinary governing documents from sensitive committee material requiring a transparent request process. The three essays cited here establish published demands, not proof of submitted statutory records requests or influence on Duffy’s letter. The current pages reflect later revisions; their original publication dates cannot date the addition of each surviving sentence. ↩︎
  14. Peter Duffy, Pollack Solomon Duffy LLP, Request for Investigation of Mass General Brigham. The full citation and source limits appear in note 6. ↩︎
  15. Massachusetts Nurses Association, July 8th Strike Announcement and Home Care Clinicians Prepare to Return, July 14th, 2026. The first notice dates the hospital strike to July 8th–9th and the exclusion to July 9th–13th; the second describes a seven-day Home Care strike and a July 15th return. These are union accounts. The notices use approximately 450 Home Care clinicians, while the letter uses approximately 465; the figures remain approximate and unreconciled. ↩︎
  16. Beth Treffeisen, Boston.com, ‘Let Us In’ Chants Echo Outside Brigham and Women’s Hospital as Nurses Strike Becomes Lockout, July 9th, 2026. The report’s deck attributes the additional four days to replacement-staffing contracts as the hospital’s explanation; its body attributes the five-day contract detail to the union. The hospital’s actual agreements and measured patient-care outcomes have not been obtained. ↩︎
  17. U.S. Nursing Corporation, US Nursing, company description and Ingenovis affiliation, accessed October 12th, 2026. The Brigham recruitment statement remains attributed to the separate Massachusetts Nurses Association memorandum as described in the letter; that memorandum remains outside the located materials. ↩︎
  18. Peter Duffy, Pollack Solomon Duffy LLP, Request for Investigation of Mass General Brigham. The full citation and source limits appear in note 6. ↩︎
  19. The Boston Globe, Brigham Strike Reporting, July 10th, 2026. ↩︎
  20. Peter Duffy, Pollack Solomon Duffy LLP, Request for Investigation of Mass General Brigham. The full citation and source limits appear in note 6. ↩︎
  21. Fastaff Travel Nursing, Acquisition Announcement, “About U.S. Nursing”. The full citation appears in note 2. The quotation states the company’s advertised bargaining function. ↩︎
  22. U.S. Nursing Corporation, Working with USN, accessed October 13th, 2026, service descriptions and operating-history figures. The company supplies the engagement, client, and deployment counts; the page does not identify annual totals, audited measures, or Brigham-specific figures. The advertised duration ranges from single-day actions to indefinite labor disruptions. ↩︎
  23. Fastaff Travel Nursing, Cornell Capital and Trilantic North America to Acquire Fastaff and U.S. Nursing. The full citation and source limits appear in note 2. Cornell Capital, Investments, Ingenovis Health entry, accessed October 12th, 2026. The entry dates Cornell’s investment closings across the combined platform to February and March 2021. It does not assign a closing date to each constituent acquisition or disclose THL Partners’ percentage. ↩︎
  24. Franklin Square Capital Partners, Franklin Square Announces Senior Secured Financing for Healthcare Staffing Services, October 12th, 2015, release distributed through PR Newswire. The financing provider describes a $150 million senior secured loan facilitating a recapitalization through which Thomas H. Lee Partners acquired a majority equity stake. The loan amount is not identified as the purchase price or THL’s equity contribution. ↩︎
  25. The Boston Globe, Brigham and Women’s Hospital’s Replacement-Staffing Contract, June 22nd, 2016. The report supplies the vendor identification; the executed agreement is not included. ↩︎
  26. Federal Mediation and Conciliation Service, Statement on the Averted Brigham Strike, reproduced by the Massachusetts Nurses Association, June 27th, 2016. The statement confirms that a tentative agreement averted the planned June 27th strike. The episode establishes preparation and procurement, rather than deployment during a completed strike. ↩︎
  27. The Boston Globe, Strike Preparations Cost Brigham $24 Million, August 12th, 2016. The reported cost and revenue categories do not establish a payment to a particular vendor; the invoices and payment records remain separate evidence. The account reports about $8 million in replacement costs and $16 million in lost revenue. ↩︎
  28. The Boston Globe, Tufts Medical Center’s Replacement-Nurse Supplier, July 13th, 2017; WBUR, Tufts Nurses Return After Strike and Lockout, July 17th, 2017. The first report identifies U.S. Nursing; the second documents the July 12th strike, subsequent lockout, and work by replacements. Tufts Medical Center is a separate hospital from the Mass General Brigham system. ↩︎
  29. iBerkshires, BMC Nurses Strike, Picket Hospital, October 4th, 2017. The report identifies U.S. Nursing and a five-day contract during the strike and lockout. The Berkshire Edge, BMC Files Complaint Against Nurses in Federal Court, Seeks Unspecified Damages, September 28th, 2017, separately identifies the supplier through hospital spokesman Michael Leary. The hospital is Berkshire Medical Center in Pittsfield, a separate institution from Boston Medical Center and Mass General Brigham. ↩︎
  30. Massachusetts Nurses Association, National Labor Relations Board Finds Merit to Three Unfair Labor Practice Charges Against Berkshire Medical Center, April 3rd, 2018, section titled “BMC Replacement Nurse Contract Finding”. The release supplies the union’s account of the requests, redactions, and regional determination. The underlying regional letter and final disposition are not supplied by that release. A regional merit determination is distinct from a final adjudication by the Board. ↩︎
  31. Massachusetts Nurses Association, Berkshire Medical Center Replacement-Nurse Contract Finding. The full citation and source limits appear in note 30. The proposed extension to Brigham’s 2016 agreement is Jonathan Bowen’s demand; Peter Duffy’s letter specifically addresses the July 2026 procurement. ↩︎
  32. Massachusetts Nurses Association, Registered Nurses Unite for Question 1: Safe Patient Limits, July 16th, 2018. Secretary of the Commonwealth of Massachusetts, 2018 Question 1: Proposal and Results. The proposal set different maximum patient assignments by unit and level of care, with patient-acuity adjustments. The union’s endorsement and the official proposal establish the measure’s identity; the earlier intensive-care legislation and other ballot initiatives are separate events. ↩︎
  33. Massachusetts Office of Campaign and Political Finance, Coalition to Protect Patient Safety, committee 95455, itemized receipts for 2017 and 2018, retrieved October 13th, 2026. The ten entries naming Partners Healthcare System total $25,546: $17,546 in staff time and $8,000 in supplies. The total includes $3,124 dated November 15th, after the vote; the other eight entries total $22,422. Massachusetts Office of Campaign and Political Finance, Ballot Question Committees Report $42.6 Million in Expenditures, the Second Highest Total Ever, February 25th, 2019, pages 1 and 3, identifies the Coalition to Protect Patient Safety as opposing Question 1. The entries appear in reports 677153, 677154, 673113, 674901, 691799, and 684977. These are reported in-kind contributions, not cash gifts or an estimate of all system resources spent on the campaign. The entries establish institutional support for the opposition committee, without identifying the approving officials or a role for THL Partners, Sperling, or Casper. Mass General Brigham, Contact Us: The Former Partners HealthCare Name, confirms the name change. Jonathan’s proposed extension of the records inquiry is his demand; Duffy’s letter does not request the 2018 campaign records. The article rounds large dollar amounts for readability; the source notes retain the reported figures, and calculations use unrounded amounts. ↩︎
  34. Secretary of the Commonwealth of Massachusetts, 2018 Question 1: Proposal and Results. The November 6th, 2018 statewide vote was 787,511 in favor and 1,858,483 against. The result establishes the proposal’s defeat; the contribution record does not establish that any particular contribution determined the outcome. ↩︎
  35. Cornell Capital and Trilantic North America, Cornell Capital and Trilantic North America to Acquire trustaff and CardioSolution in Combination with Stella to Create Tech-Enabled Platform for Healthcare Staffing, February 8th, 2021, pages 1–2. The release describes completed acquisitions of trustaff Management and CardioSolution and an agreement to acquire Stella.ai, with the Stella closing still prospective. It names Stephen Trevor and Jeremy Lynch as the investment firms’ spokespeople and Adam Zoia and Sean Loring in the combined company’s leadership; it does not attribute the acquisitions to Sperling personally. ↩︎
  36. Fastaff Travel Nursing, Acquisition Announcement. The full citation and announcement limits appear in note 2. The Ingenovis Health release cited in note 43 identifies its formation in 2021 through the merger of Fastaff Travel Nursing, U.S. Nursing, Trustaff Travel Nurses, and CardioSolution; the February announcement itself describes an agreement with a prospective closing. ↩︎
  37. Wendy McGill, Massachusetts Nurses Association associate director, Letter to Anthony D. Rizzotti Regarding MNA and Tenet Saint Vincent Hospital, March 25th, 2021, page 1. The letter requests a copy of each contract entered during 2021 between Tenet or Tenet Saint Vincent Hospital and agencies providing registered nurses at Saint Vincent Hospital. The document records the request; it contains neither a reply nor an executed agreement. Littler Mendelson, P.C., Anthony D. Rizzotti Biography, accessed October 16th, 2026, identifies Rizzotti as a shareholder who represents employers, including healthcare systems and hospitals, and lists “Union avoidance” among his practice areas. The biography describes his general practice rather than his work on a particular staffing agreement. Littler Mendelson, P.C., The View From the Front Lines — Negotiators Who Averted Strikes for Two Boston Hospitals Talk About Staffing Ratios and Strategy, May 31st, 2011, identifies Rizzotti as Saint Vincent’s chief negotiator in that year’s dispute. Rizzotti describes replacement nurses already traveling to Massachusetts before the parties averted the strike scheduled for May 6th. The account concerns a separate dispute in 2011, before THL Partners’ 2015 investment; it names no staffing supplier. ↩︎
  38. Kelly Gooch, Nurses’ Strike at Tenet Massachusetts Hospital Moves into 5th Week: 5 Updates, Becker’s Hospital Review, April 5th, 2021, items 3–4. Item 3 attributes the U.S. Nursing identification to the Massachusetts Nurses Association, which cited emails shared with the Boston Business Journal. The linked original is Jessica Bartlett, Replacement Staff During St. Vincent Strike Costs Hospital Double, Boston Business Journal, April 2nd, 2021. The supplier attribution follows the accessible Becker’s account; the underlying emails and executed agreement are not reproduced there. Item 4 also records the hospital’s statement that the union’s information was inaccurate and its decision to provide no further strike-cost details. ↩︎
  39. Mark Herz, “Union wins two elections among clinical staff at McLean Hospital”, GBH News, April 26th, 2022: report. The report attributes confirmation of the hiring of Littler Mendelson and Crossroads Labor Consulting Group to McLean chief of staff Adriana Bobinchock. The episode concerned organizing by the American Federation of State, County and Municipal Employees, Council 93, rather than an MNA strike. Mass General Brigham identifies McLean as a member institution: About McLean Hospital. Jonathan Bowen cited the GBH report in “Hub Hospitals Hate Health Care”, July 8th, 2026, under “Littler Mendelson”, source note 26: earlier essay. The reviewed sources establish the firms’ engagement but supply no Ingenovis or predecessor staffing connection, specific Littler fee, or personal McLean assignment for Rizzotti. The demand for McLean’s engagement agreements, payment records, and approval records extends Jonathan’s inquiry; it does not represent a McLean-specific demand quoted from Duffy’s letter. ↩︎
  40. National Labor Relations Board, Brigham & Women’s Hospital, Case 01-CA-289902, filed February 1st, 2022, participant list and docket activity, accessed October 16th, 2026. The record lists Anthony Rizzotti of Littler Mendelson, P.C. as a legal representative of the hospital and the Massachusetts Nurses Association as the charging union; it records approval of withdrawal on May 4th, 2022. National Labor Relations Board, Brigham & Women’s Hospital, Case 01-CA-393865, filed August 28th, 2026, participant list and docket activity, accessed October 16th, 2026. The page is titled Brigham & Women’s Hospital but identifies Mass General Brigham as the employer and Rizzotti of Littler Mendelson, P.C. as a respondent legal representative. The 2026 case was listed as open when accessed. The participant records establish representation in those proceedings; the allegations are not findings, and the pages do not establish a role in selecting a staffing supplier or answering McGill’s request. ↩︎
  41. Jennifer “Jen” DeVincent, personal communication with Jonathan Bowen, October 16th, 2026. DeVincent reported direct negotiations with Anthony Rizzotti and identified October 28th, 2025, as the first meeting and October 10th, 2026, as the most recent. Massachusetts Nurses Association, Brigham Nurses United, committee roster for 2025–2026, accessed October 16th, 2026. The roster lists Jen DeVincent in the elected CWN position representing Brigham and Women’s nurses. Mass General Brigham, Women’s Health, accessed October 16th, 2026, names the Mary Horrigan Connors Center for Women and Newborns. DeVincent’s professional résumé uses Jennifer DeVincent. Her account identifies participation in bargaining; it does not identify a role for Rizzotti in selecting or approving a staffing supplier. ↩︎
  42. THL Partners, Ingenovis Health, accessed October 13th, 2026, “Enhancing Recruitment and Integrating Sales for Healthcare Heroes”. The page attributes the described organizational work to the period of the partnership and names Joshua Nelson and Megan Preiner as its team. It does not identify Sperling as an acquisition principal or assign individual responsibility for the operational changes. ↩︎
  43. Ingenovis Health, Ingenovis Health Shows Rapid Growth in First Two Years, March 22nd, 2023, company release preserved by Cornell Capital; the sponsor’s News Archive supplies the publication date. The company reports annual revenue, acquired businesses, and deployments during labor disruptions. The deployment figure covers healthcare providers in 2022; the revenue figure covers the staffing business as a whole and is not a measure of strike-staffing revenue. The figures are company-reported rather than an audited financial statement reproduced with the announcement. The company reports more than $2 billion in annual revenue and approximately 6,000 healthcare providers onsite during labor disruptions in 2022. ↩︎
  44. Ingenovis Health, Ingenovis Health Celebrates Five Years of Purpose, Progress and Transformational Growth, March 5th, 2026, checked October 13th, 2026. The company lists Fastaff, Trustaff, USN, HealthCare Support, Springboard Health, VitalSolution, VISTA Staffing, and Corazon. The former and expanded names are supplied by the 2021 acquisition announcements in notes 35–36, the 2023 acquisition account in note 43, and VitalSolution, VitalSolution Unveils New Anesthesia Services, Opening Opportunities for Rural Communities, August 16th, 2023, checked October 13th, 2026. The VitalSolution release explicitly announces the CardioSolution name change and identifies Trustaff Travel Nurses, Fastaff Travel Nursing, USN, VISTA Staffing Solutions, and Springboard Healthcare in the Ingenovis portfolio. The brands include ordinary staffing businesses as well as U.S. Nursing; the list is not an inventory of eight strike-staffing companies. The Goliath comparison concerns the scale of the combined business. ↩︎
  45. Ingenovis Health, Ingenovis Health Announces Strategic Capital Investment Transaction, May 28th, 2026. This is the second corporate link supplied by the letter. Davis Polk & Wardwell LLP, Ingenovis Health Comprehensive Restructuring Transactions, May 29th, 2026. The announcement reports that sponsors Cornell Capital and Trilantic North America invested $100 million for newly issued preferred equity, with another $30 million in preferred equity offered to lenders holding first-lien debt. The counsel’s announcement describes preferred equity and debt restructuring without identifying THL Partners’ position, common shareholders, or ownership percentages. ↩︎
  46. Davis Polk & Wardwell LLP, Ingenovis Health Comprehensive Restructuring Transactions, May 29th, 2026. Counsel describes the cancellation of the previous first-lien facility after a $100 million paydown, entry into a $275 million credit facility, and a reduction exceeding $500 million in existing first-lien debt. The announcement is transaction counsel’s account; it is not the executed credit agreement or a complete ownership register. The related preferred-equity terms are described in note 45. ↩︎
  47. THL Partners, Ingenovis Health, accessed October 12th, 2026. This is one of the letter’s three supporting web links. The page lists an investment date of 2015 and the status “Exited”; it gives no exit date. ↩︎
  48. Peter Duffy, Pollack Solomon Duffy LLP, Request for Investigation of Mass General Brigham. The full citation and source limits appear in note 6. THL Partners, Disclaimer, “Portfolio Company Investments”, accessed October 12th, 2026. The classification language is general and does not identify Ingenovis Health. The records reviewed for this essay do not establish a financial interest held by THL Partners or Sperling on the relevant staffing decision dates. An ownership interest alone would not establish participation in procurement or in the decision to retain replacement staff for additional days. The ownership and decision records were unavailable in the materials reviewed. Bowen extends the records question to Thermo Fisher Scientific and Casper. The reviewed sources establish their governance connections; the records needed to establish an ownership or payment path to the staffing company remain outstanding. ↩︎
  49. Peter Duffy, Pollack Solomon Duffy LLP, Request for Investigation of Mass General Brigham. The full citation and source limits appear in note 6. ↩︎
  50. Mass General Brigham Incorporated, Form 990 for the Fiscal Year Ended September 30th, 2024. The full citation and source limits appear in note 5. The four entries are $48,964,572 for Suffolk Construction, $8,210,840 for NPP Development, $1,500,000 for NPS LLC, and $709,351 for InterSystems, totaling $59,384,763. ↩︎
  51. Mass General Brigham Incorporated, Fiscal 2025 Parent Schedule L, entries 5–8. The filing comparison and source limits appear in note 5. The four reported entries total $48,366,922. The difference from the fiscal 2024 four-entry total is $11,017,841 ($59,384,763 minus $48,366,922). ↩︎
  52. Mass General Brigham Incorporated, Form 990 for the Fiscal Year Ended September 30th, 2024. The full citation and source limits appear in note 5. ↩︎
  53. Peter Duffy, Pollack Solomon Duffy LLP, Request for Investigation of Mass General Brigham. The full citation and source limits appear in note 6. ↩︎
  54. Thermo Fisher Scientific, 2026 Proxy Statement. The full citation and source limits appear in note 1. ↩︎
  55. Mass General Brigham Incorporated, Form 990 for the Fiscal Year Ended September 30th, 2024. The full citation and source limits appear in note 5. ↩︎
  56. Jonathan Bowen, The 37 Connectors. The full citation and source limits appear in note 12. ↩︎
  57. Mass General Brigham, Policy for Interactions with Industry and Other Outside Entities, approved March 29th, 2018, sections 5.5.2–5.5.5. The policy was linked from the organization’s ethics page on October 12th, 2026. The provision in section 5.5.4 appears on printed page 59. The governing version, threshold schedules, and transaction category require confirmation for each decision. ↩︎
  58. Mass General Brigham, Policy for Interactions with Industry and Other Outside Entities. The full citation and source limits appear in note 57. ↩︎
  59. Mass General Brigham, Policy for Interactions with Industry and Other Outside Entities. The full citation and source limits appear in note 57. ↩︎
  60. The Boston Globe, Brigham Nurses Union Alleges MGB Board Rife With Conflicts of Interest, Requests State Investigation, October 6th, 2026. Campbell’s office confirmed receipt, according to the report. The financial figures come from the filings. ↩︎
  61. United States Department of Labor, Employee Benefits Security Administration, Fiduciary Investigations Program and About EBSA, official source text checked October 13th, 2026. The manual describes investigations of fiduciary violations under Title I of the Employee Retirement Income Security Act and the authority to obtain relevant plan records. This demand concerns the pension records sought in Bowen’s earlier essays; the commercial-transaction inquiry in Duffy’s letter remains directed to the Massachusetts attorney general. ↩︎
  62. The Brigham and Women’s Hospital, Inc., Form 990 for the Fiscal Year Ended September 30th, 2009, EIN 04-2312909, Schedule L, Part IV continuation, PDF page 39. The NPP Development row says “Family – Kraft” and “Lease/Construction”; the Suffolk Construction row says “Family – Fish” and “Construction Services”. The form’s printed year is 2008. The filing does not identify the NPP premises, split the combined category, or establish that either amount concerns the same work or contract reported in later returns. The reported amounts are $6,999,509 for NPP Development and $7,890,255 for Suffolk Construction. ↩︎
  63. Partners HealthCare System and Affiliates, Form 990 for the Fiscal Year Ended September 30th, 2014, EIN 90-0656139, Schedule L, Part IV, entry 22, PDF page 294. The printed form year is 2013. The NPP Development entry reports $3,372,088. ↩︎
  64. Mass General Brigham, Brigham and Women’s Milestones, entries for 2009 and November 2019. The history establishes the clinical facility’s opening and expansion. The contracts are needed to map particular premises, costs, and terms to the NPP Development entries. ↩︎
  65. Mass General Brigham, Brigham and Women’s Milestones. The full citation and source limits appear in note 64. ↩︎
  66. Patriot Place, Mass General Brigham Announces New Partnership with New England Patriots and New England Revolution, December 20th, 2021. The release expressly distinguishes the sponsorship from the clinical relationship. It names Kraft Sports + Entertainment and supplies neither an NPS LLC contract nor a sponsorship price. ↩︎
  67. Suffolk Construction, A Powerful and Magnetic Approach, seven-page case study, particularly PDF pages 2–3. The account describes earlier work and gives no contract price or change-order amount. It cannot identify the work covered by fiscal 2024 or fiscal 2025 entries. InterSystems, HealthShare, customer and partner list under the medical technology and life sciences category, accessed October 12th, 2026. This is the vendor’s description of the relationship, not a purchase agreement or proof that all reported transactions concern HealthShare. ↩︎
  68. Mass General Brigham and Affiliates, Fiscal 2024 Group Schedule L, entries 10 and 14. The parent and group amounts remain unreconciled and are not aggregated here. The NPP Development entry reports $7,325,990, and the Suffolk Construction entry reports $34,387,218. ↩︎
  69. Mass General Brigham Incorporated, Form 990 for the Fiscal Year Ended September 30th, 2024. The full citation and source limits appear in note 5. Mass General Brigham Incorporated, Fiscal 2025 Filing, filing identifier 202622259349300127, Schedule J and Schedule O, as reconstructed by ProPublica from Internal Revenue Service filing data. Schedule J reports $2,758,711 base, $4,192,800 bonus and incentive, $104,499 other reportable, $2,096,186 retirement and deferred, and $28,562 nontaxable benefits, totaling $9,180,758. The comparison uses the earlier Schedule J in note 5. The source reproduces filing text rather than an original PDF image. The letter’s third supporting web link is The Boston Globe, Mass. Hospital CEOs’ Pay Packages Rose Again in 2024, August 17th, 2026. The compensation analysis here uses the filing schedules linked in notes 5 and 69. The earlier Schedule J total is $8,407,816. ↩︎
  70. Internal Revenue Service, Compensation: Calendar Year Reporting Required and Instructions for Schedule J, Part II. The returns end on September 30th, 2024, and September 30th, 2025. The reported compensation covers calendar 2023 and calendar 2024. The increase is $772,942 ($9,180,758 minus $8,407,816), or about 9.19 percent ($772,942 divided by $8,407,816, multiplied by 100). ↩︎
  71. Mass General Brigham Incorporated, Form 990 for the Fiscal Year Ended September 30th, 2024. The full citation and source limits appear in note 5. Mass General Brigham Incorporated, Fiscal 2025 Filing. The full citation and source limits appear in note 69. The base-pay amounts are $2,384,133 for calendar 2023 and $2,758,711 for calendar 2024. The retirement and deferred compensation amounts are $1,536,300 and $2,096,186 for those respective years. ↩︎
  72. Mass General Brigham Incorporated, Form 990 for the Fiscal Year Ended September 30th, 2024. The full citation and source limits appear in note 5. Mass General Brigham Incorporated, Fiscal 2025 Filing. The full citation and source limits appear in note 69. The bonus and incentive amounts are $4,284,478 for calendar 2023 and $4,192,800 for calendar 2024, a decrease of $91,678. ↩︎
  73. Mass General Brigham Incorporated, Fiscal 2025 Filing. The full citation and source limits appear in note 69. ↩︎
  74. 26 C.F.R. § 53.4958-6, subsections a, c, and e, current text reproduced by the Legal Information Institute. The official Archived Regulation supplies a second text check. The procedural presumption is not the only route to establishing reasonableness; subsection e states that its absence creates no inference of an excess-benefit transaction. ↩︎
  75. Massachusetts Legislature, Mass. Gen. Laws ch. 12, § 8 and § 8H, particularly subsections 1 and 6. Section 8H requires an application by the attorney general and judicial approval; its disclosure restriction includes exceptions for consent and a court order for good cause. ↩︎
  76. Weaver v. Wood, 425 Mass. 270, 275–276 (1997), opinion text. The standing rule includes a limited exception for a private plaintiff with a distinct individual interest. DeGiacomo v. City of Quincy, 476 Mass. 38, 46, 48–49 (2016), opinion text. The case addresses representation and preclusion in charitable-trust litigation; it does not establish facts concerning Mass General Brigham. ↩︎
  77. Massachusetts Legislature, Mass. Gen. Laws ch. 12, § 8H, subsection 1. The full citation and source limits appear in note 75. ↩︎
  78. Massachusetts Attorney General’s Office, Attorney General Maura Healey Unveils Aggressive Agenda, January 21st, 2015; Massachusetts Health Policy Commission, 2023 Cost Trends Hearing Program Booklet, biographical entries for Governor Maura Healey and Attorney General Andrea Joy Campbell. Healey served as attorney general before taking the governor’s oath on January 5th, 2023. Bessie Dewar served as acting attorney general before Campbell took office on January 18th; the dates do not describe an immediate succession. ↩︎
  79. Massachusetts Attorney General’s Office, AG Healey Files Concerns Over Partners Agreement, January 26th, 2015, and Examination of Health Care Cost Trends and Cost Drivers, November 17th, 2021. The earlier release records Healey’s position on the proposed merger agreement negotiated under Attorney General Martha Coakley. The later report states that Mass General Brigham produced documents in response to a civil investigative demand and thanks Mass General Brigham for its cooperation. The examination used the health-cost authority in chapter 12C, section 17; it does not establish a chapter 12, section 8H inquiry or a prior examination of the transactions in Duffy’s letter. ↩︎
  80. Massachusetts Department of Public Health, Steward Health Care: Transition to the New Operators, “Transition information”, accessed October 13th, 2026. The agency distinguishes the flood closure from the later construction suspension associated with Steward’s financial problems. The clinical operator and the owner of the real estate are separate entities. ↩︎
  81. Massachusetts Legislature, Legislature Enacts Emergency Law to Help Revitalize Norwood Hospital, July 31st, 2026; Medical Properties Trust, Investor Relations, accessed October 13th, 2026. The legislative account identifies Steward’s private equity history and the property owner; the company identifies itself as a real estate investment trust. Chapter 178, cited in the next note, identifies the parcel’s legal owner as MPT of Norwood-Steward, LLC. The real estate ownership is distinct from the hospital’s operating business, and the sources do not identify either relationship as venture capital. ↩︎
  82. Massachusetts Legislature, Acts of 2026, Chapter 178, approved August 6th, 2026, sections 1 and 2. The law takes effect November 1st, 2026. The taking depends on a designated appropriation, acceptance of a qualified nonprofit bid or offer, and required notice; the law also provides appraisal review and an accommodation for a prospective private healthcare agreement. The statute establishes a conditional process, rather than a completed taking, an appointed operator, or a reopened hospital. ↩︎
  83. Office of Governor Maura Healey, Governor Healey Demands Financial Transparency and Patient Safety from Steward Health Care, February 20th, 2024. The release announces the records demand and describes earlier litigation over Steward’s financial reporting. Those reporting obligations have a different legal basis from the charitable-asset inquiry requested in Duffy’s letter. ↩︎
  84. Office of Governor Maura Healey and Executive Office of Health and Human Services, Steps to Protect Patients, Workers, and Access to Care as Steward Health Care Enters Bankruptcy, May 6th, 2024, statement attributed to Attorney General Andrea Joy Campbell. The statement addresses the Steward bankruptcy and does not document a separate Campbell action on the Norwood property or a response to Duffy’s letter. The proposed application of that accountability commitment to the Massachusetts Nurses Association’s request is Jonathan Bowen’s argument. ↩︎
  85. Massachusetts Legislature, Mass. Gen. Laws ch. 180, § 6C. The section also addresses reliance on reports and advice, limits that reliance when contrary knowledge makes reliance unwarranted, and protects conduct complying with the section. Boston Children’s Heart Foundation, Inc. v. Nadal-Ginard, 73 F.3d 429, 433–434 (1st Cir. 1996), opinion text. The court reviewed findings after trial, including self-directed compensation and nondisclosure; a disclosed commercial relationship alone does not establish comparable conduct. ↩︎
  86. The United States Code, 26 U.S.C. § 501(c)(3) and 26 U.S.C. § 4958, text reproduced by the Legal Information Institute and checked against the official 2023 edition. Entity classification, disqualified-person status, transaction terms, and valuation affect application; the letter presents questions for examination rather than adjudicated violations. ↩︎
  87. Peter Duffy, Pollack Solomon Duffy LLP, Request for Investigation of Mass General Brigham. The full citation and source limits appear in note 6. ↩︎
  88. Massachusetts Office of Campaign and Political Finance, Contribution Search and Data Access Documentation, queried October 12th, 2026, for the Healey Committee, CPF 15710, and the Campbell Committee, CPF 15931. The requested window runs from October 12th, 2006, through October 12th, 2026; the committees organized on October 21st, 2013, and November 19th, 2014, respectively. The figures cover individual receipts to those committees across the candidates’ campaigns, including campaigns for offices other than attorney general. The selected cohort consists of John Fish and the relatives identified in note 91, Jonathan Kraft and the relatives identified in note 90, Terry Ragon and Susan Ragon, and Klibanski. The audit reconciles each admitted receipt to its current report and subtracts three separately reported refunds once. The result is a documented minimum for that cohort, with unresolved identities excluded; the total is not a census of every donor connected to Mass General Brigham or a claim that the gifts occurred during board service. The receipts establish campaign giving without establishing a connection to any official decision, access, or favor. ↩︎
  89. Massachusetts Office of Campaign and Political Finance, Contribution Search. The full citation and source limits appear in note 88. The searches described in note 88 include Marc Casper, Marc N Casper, Scott Sperling, Scott M Sperling, Jim Manzi, James Manzi, James P Manzi, and surname variants. The surname matches identify other contributors; the searches establish no receipts matching the three men for either committee within the stated window. Partners HealthCare System and Affiliates’ Fiscal 2012 Return, Schedule O, identifies Manzi as a trustee of Brigham and Women’s Hospital and Brigham and Women’s Health Care from October 1st, 2011, through January 24th, 2012. Thermo Fisher Scientific’s 2019 Proxy identifies Manzi as chairman; the biography describes his executive career at Lotus Development. The historical review separates affiliate trusteeships from the parent board and employment at Thermo Fisher Scientific or its predecessors from outside directorships. The historical roster remains incomplete; the targeted search found no further overlap between employment at Thermo Fisher Scientific or its predecessors and service on a board in the Mass General Brigham system during the stated window. ↩︎
  90. The Kraft audit includes Robert Kraft; Myra Hiatt Kraft; their sons Jonathan Kraft, Daniel Kraft, Joshua Kraft, and David Kraft; the other relatives identified below. The New England Patriots’ Myra Kraft Biography names all four sons and identifies Myra Kraft as a trustee of Brigham and Women’s Hospital at her death in 2011, before either recipient committee was organized. The matched receipts are Jonathan Kraft, $3,000 to Healey and $5,000 to Campbell; Patricia Lipoma Kraft, $2,000 and $4,000; Joshua Kraft, $2,500 and $4,000; Robert Kraft, $2,000 to Campbell; and Dana Blumberg/Dana Kraft, $2,000 to Campbell. The searches returned no matching receipts for Myra Kraft, Daniel Kraft, or David Kraft. Rice University’s Kraft Family Announcement establishes Patricia Lipoma Kraft’s name forms and marriage to Jonathan Kraft. The searches for Kraft receipts to Healey and Campbell supply the entries; matches lacking evidence of kinship are excluded. Dana Kraft’s August 25th, 2022 Receipt predates her October 14th, 2022 Marriage to Robert Kraft; the audit includes her among the relatives as of October 12th, 2026. The November 17th, 2025 Receipt uses Dana Kraft; Patriots Coverage corroborates that name. The audit identifies no refunds for these donors. The matched receipts total $7,500 for the Healey Committee and $17,000 for the Campbell Committee. ↩︎
  91. The Fish audit includes John Fish, his siblings Michael Fish, Karen Fish-Will, Melissa Fish-Crane, and Kevin Brine Fish, and Gretchen Fish, the wife of their late father, Edward Fish. The University of New Hampshire Memorial establishes the family relationships; the Lawyers Clearinghouse Profile and Jamaica Plain Neighborhood Development Corporation Interview corroborate the names and describe their businesses. The searches for Fish receipts cover Healey and Campbell. The Healey committee reports refunds of $1,000 to Gretchen Fish, $1,000 to Kevin Brine Fish, and $500 to Fish-Crane. The refund records identify the recipients without identifying the receipt items, so the subtraction applies to the totals for those donors. The audit excludes Jennifer F. Fish and Lindsay Fish because the contribution identities remain unresolved, and it does not infer kinship from a shared surname. The family’s receipts total $27,000 for Healey and $6,250 for Campbell. The three refunds total $2,500, reducing Healey’s total to $24,500. ↩︎
  92. The Healey Report Containing the December 30th, 2020 Receipts records $1,000 each from Phillip Ragon and Susan Ragon. The Ragon Institute’s New Research Shows Vaccine Protection Against Zika Virus quotes Terry Ragon identifying Susan Ragon as his wife; InterSystems’ Phillip Ragon Biography identifies Phillip Ragon by the name Terry. The searches found no matching Ragon receipt to the Campbell Committee. Klibanski’s receipts appear in the official searches for Healey and Campbell. The audit matches the receipts to their current filings and identifies no refunds to these three contributors. Klibanski’s matched receipts total $3,700 for the Healey Committee and $200 for the Campbell Committee. ↩︎
  93. City of Boston, Mayoral Results for the September 9th, 2025 Preliminary Municipal Election, PDF page 1, lists Josh Kraft as a candidate. The Healey Committee’s March 2025 Report records $500 from Josh M Kraft on March 26th, 2025, receipt 6458290 and report-schedule item 17369264. The name match belongs to the Joshua/Josh Kraft audit summarized in note 90. The receipt is already included in Joshua Kraft’s $2,500 Healey total and the family’s $7,500 Healey total; the campaign context adds no contribution to either figure. ↩︎
  94. Massachusetts Office of Campaign and Political Finance, Healey Committee’s March 2025 Report. The full citation and source limits appear in note 93. ↩︎
  95. Massachusetts Office of Campaign and Political Finance, Contribution Search. The full citation and source limits appear in note 88. The verified receipts total $40,200 for Healey and $23,450 for Campbell. The $2,500 in refunds reduces Healey’s total to $37,700. ↩︎
  96. Peter Duffy, Pollack Solomon Duffy LLP, Request for Investigation of Mass General Brigham. The full citation and source limits appear in note 6. The Boston Globe, Brigham Nurses Union Alleges MGB Board Rife With Conflicts of Interest, Requests State Investigation. The full citation and source limits appear in note 60. ↩︎
  97. Peter Duffy, Pollack Solomon Duffy LLP, Request for Investigation of Mass General Brigham. The full citation and source limits appear in note 6. ↩︎
  98. Massachusetts Legislature, Mass. Gen. Laws ch. 12, § 8. The full citation and source limits appear in note 75. ↩︎
  99. Brigham and Women’s Hospital, MNA postpones Brigham strike as progress made in negotiations, October 11th, 2026, accessed October 16th, 2026. The statement distinguishes the withdrawal of the strike notice from a final, ratified contract. Massachusetts Nurses Association, Brigham Nurses United, update dated October 11th, 2026, accessed October 16th, 2026. The union’s dated update states that the Brigham committee postponed the strike to allow members to vote on the hospital’s offer. ↩︎

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