Formal Objection to NGM Lawyer

Dear Ms. Carter,

I’m following up via my NGM law firm email address because your recent message was sent there. This is not a recent dispute. This has been ongoing.

I had responded from my personal account (rclitman@gmail.com) and I want to ensure you received those communications. If not, please let me know, and I will resend them.

Your use of my Nath Law email address—more than five years after you claimed I was terminated—underscores the central contradiction in the position you presented to Judge Horne. At arbitration, you argued that my role as Senior Counsel ended on June 15, 2020, due to an agreement by conduct following NGM’s insurer’s determination of the date of disability. However, your client continued to publicly and professionally present me as Senior Counsel continuously from April 2017 through June 2025, five(5) years after the termination date you represented.

Over this eight-year period (2017–2025), your client:
• Continuously listed me as Senior Counsel on its website, including during and after the arbitration;
• Treated me as affiliated with the firm in communications with Litman Originated Clients;
• Maintained professional liability coverage as if I remained as Senior Counsel;
• Took no steps to formally disassociate me until the COBRA notice issued in June 2025.

These actions speak for themselves. They are not consistent with the 2020 termination date that you aggressively argued. They reflect an ongoing relationship—affirmed by your client’s conduct, and relied upon by me—that legally and equitably paints a very different picture than what you advanced at arbitration.

While the arbitrator accepted that disability triggered the contractual 5 year payment window (extendable by up to two (2) years), the decision did not relieve your client of the consequences of its subsequent conduct. It is a fundamental principle that a party cannot benefit from an affiliation while retroactively disclaiming its obligations. Your client’s continued public use of my Senior Counsel title, and treatment of me as an employee, either waived the claim of termination, or created a continuing relationship that carried forward post-award duties —including accurate and timely payments — as required by Judge Horne.

Your client’s attempt to invoke the arbitrator’s ruling as a sword while ignoring its own contradictory conduct as a shield is not only inequitable—it exposes the firm to claims of breach, misrepresentation, bad faith and more. I reserve all rights and remedies available to me under law and equity, including those arising directly from your client’s post-award conduct.

If my prior emails from my personal account were not received, please let me know. I will not take that as a lack of civility, but I do ask for the courtesy of confirmation given the importance of these matters to me in my remaining days and need to take speedy action.

Sincerely,

Richard

Richard Litman
Sent from my iPad

On Jun 26, 2025, at 15:59, Heba K. Carter <hcarter@gcpc.com> wrote:



You don't often get email from hcarter@gcpc.com. Learn why this is important

Mr. Litman,

I hope you are well. As you know my firm represents Nath, Goldberg & Meyer. Please direct all further correspondence to me. I understand a dispute has arisen recently related to the agreement we litigated in arbitration.

This is formal notice that the Agreement has not been renewed or reinstated. Just as the arbitration order indicated, the Agreement terminated on June 15, 2025. My clients have not renewed the Agreement for another term.

As such, please be aware that all benefits you have been receiving will terminate effective June 30, 2025. This includes health insurance, disability insurance, malpractice insurance, access to the company credit card, and payment for your cell phone coverage. All of these will be terminated on June 30, 2025.

Further, please be advised that your access to the nathlaw email account will be terminated by August 30, 2025. My clients are allowing you the additional time to access the account as a courtesy in case you have any personal items you need to make sure are transferred to a personal email account. As of August 30, 2025 you will no longer have access to the nathlaw email account.

Finally, I understand you have raised disputes regarding items from 2021. Any accounting disputes you have that arose before the arbitration have been litigated and are barred by res judicata. If you have any accounting disputes that arose after the date of the arbitration, please direct them to my attention.

Thank you,
Heba

Heba K. Carter, Esq.
Owner/Managing Attorney
NEW ADDRESS AS OF JULY 1, 2024
1320 Old Chain Bridge Road, #440
McLean, VA 22101
General Counsel, P.C.
Direct: 571-223-6914
Email: hcarter@gcpc.com
Web: www.gcpc.com

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