$694K Wire Transfer Dispute

Josh,

I got your email. I am thinking about what we can do to control costs in resolving our dispute, while you and Jerry succeed in handling the abundance of opportunity you now have from my practice. The practice is booming and I certainly don’t want the arbitration to get in the way.

First, although I appreciate the sentiment, you and I know I am not a partner, the contract is clear.

Second, I can go bank and forth about what info was requested and when, but the bottom line is you and Jerry now have my practice and it is bringing in significant revenues. The records should accurately reflect the activity.

Third, I would like to clear something up. Your lawyer accused me of refusing the payment received January 3, 2023. Bob Scully has asked for the documentation. What is your counsel talking about?

Lastly, I think Bob Scully wants every invoice and payment record, including the trust account subsidiary ledgers reflecting 2020 - 2022 activity on each matter for my originated clients. I haven’t talked with him, but it may be possible that we can reach an agreement on the revenue and disbursement numbers by matter through 2022. This should save money.

I haven’t been well this past week and haven’t looked at the attachments you sent. I will try to review over the next few days. Do you think we can reach agreement as I propose?

Rich

Begin forwarded message:

From: Robert Scully <rscully@bklawva.com>
Date: January 4, 2023 at 17:12:37 EST
To: "Heba K. Carter" <hcarter@gcpc.com>
Cc: Merritt Green <mgreen@gcpc.com>, Erin Boland <eboland@bklawva.com>, Dana Leinbach <dleinbach@bklawva.com>, Richard Litman <rclitman@gmail.com>
Subject: RE: $694,478.67 Wire Transfer - RE: Richard C. Litman v. Nath & Associates, PLLC, et al.


Heba:
Please send me the document your clients’ bank sent to them reporting the “rejection” of the wire transfer by the receiving institution. Perhaps, the receiving institution rejected it. But Richard Litman never instructed it to do so. If its representatives made that representation to your clients’ transmitting bank, I would like to see the communication containing it.
The only communication Richard Litman ever received from his bank about a wire transfer from your client is attached.
Regards,
Bob

Robert E. Scully, Jr., Esq.

Blankingship & Keith, PC
4020 University Drive, Suite 300 ■ Fairfax, VA 22030
Main: (703) 691-1235
Direct Dial: (571) 396-0560
Facsimile: (703)-691-3913
Email: RScully@bklawva.com
www.blankingshipandkeith.com

From: Heba K. Carter <hcarter@gcpc.com>
Sent: Wednesday, January 4, 2023 9:01 AM
To: Robert Scully <rscully@bklawva.com>
Cc: Merritt Green <mgreen@gcpc.com>; Erin Boland <eboland@bklawva.com>; Dana Leinbach <dleinbach@bklawva.com>; Richard Litman <rclitman@gmail.com>
Subject: Re: $694,478.67 Wire Transfer - RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Bob,

As indicated in my previous email, our client’s bank indicated that the wire was sent and was refused, rejected, by your client.

Thank you,
Heba

On Jan 4, 2023, at 8:56 AM, Robert Scully <rscully@bklawva.com> wrote:

Mr. Litman did not “ refuse payment.”Please provide the identity of the source of this misinformation.
Regards
Bob

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________________________________
From: Heba K. Carter <hcarter@gcpc.com>
Sent: Wednesday, January 4, 2023 8:50:55 AM
To: Robert Scully <rscully@bklawva.com>; Merritt Green <mgreen@gcpc.com>; Erin Boland <eboland@bklawva.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>; Richard Litman <rclitman@gmail.com>
Subject: RE: $694,478.67 Wire Transfer - RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Bob,

We received confirmation from our client’s bank that Mr. Litman rejected the wire, and the reason “no funds were received by Mr. Litman” were simply because he refused to accept the payment.

This came as a surprise after you demanded that we “show you the money.” Please confer with your client.

We look forward to our call with Judge Horne this morning.

Thank you,

Heba

Heba K. Carter, Esq.

General Counsel, P.C.

Direct: 571-223-6914

Email: hcarter@gcpc.com

Web: www.gcpc.com

CONFIDENTIALITY/PRIVILEGE: This electronic message transmission contains information from this law firm which may be confidential or privileged. The information is intended to be for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us by telephone (703-782-3523) or by electronic mail immediately.

From: Robert Scully <rscully@bklawva.com>
Sent: Tuesday, January 3, 2023 10:19 AM
To: Merritt Green <mgreen@gcpc.com>; Heba K. Carter <hcarter@gcpc.com>; Erin Boland <eboland@bklawva.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>; Richard Litman <rclitman@gmail.com>
Subject: RE: $694,478.67 Wire Transfer - RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Merritt:

I can confirm that as of yesterday no funds were received by Mr. Litman.

In addition, the spreadsheet attached to the email is denied as an accurate accounting of the sums owed to Mr. Litman. The sum actually due now exceeds $1,250,000 -not including interest.

The application of each client payment is not done by “… compar[ing] [KSU’s] list against the statement of account to make an educated guess as to how to apply the money.”

In the year end rush to close the books, the law firm and its partners once again made no effort to do the reconciliation required by the Combination Agreement. Mr. Litman will add that to the list of breaches of the Combination in the Supplemental Arbitration Demand he will seek leave to file this week.

Mr. Litman continues to seek a complete and accurate accounting of all the client fee payments for which he did not receive his royalty payments, in accordance with the Combination Agreement.

If the Respondents contend the spreadsheet the firm recently concocted by guesswork, and sent to me as Litman’s counsel,is the required accounting or Reconciliation; that contention is specifically rejected.

Regards,

Bob

Robert E. Scully, Jr., Esq.

Blankingship & Keith, PC
4020 University Drive, Suite 300 ■ Fairfax, VA 22030

Main: (703) 691-1235

Direct Dial: (571) 396-0560
Facsimile: (703)-691-3913

Email: RScully@bklawva.com

www.blankingshipandkeith.com

From: Merritt Green <mgreen@gcpc.com>
Sent: Thursday, December 29, 2022 8:46 PM
To: Robert Scully <rscully@bklawva.com>; Heidi Colwell <hcolwell@mccammongroup.com>; Heba K. Carter <hcarter@gcpc.com>; Erin Boland <eboland@bklawva.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>; Richard Litman <rclitman@gmail.com>
Subject: $694,478.67 Wire Transfer - RE: Richard C. Litman v. Nath & Associates, PLLC, et al.
Importance: High

Bob,

Please see below and attached. $694,478.67 was sent via wire transfer to Mr. Litman today. If he could please confirm receipt. Thank you.

Merritt J. Green

General Counsel, P.C.

Direct: 703-556-6505

Email: mgreen@gcpc.com

Web: www.gcpc.com

CONFIDENTIALITY/PRIVILEGE: This electronic message transmission contains information from this law firm which may be confidential or privileged. The information is intended to be for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us by telephone (703-556-0411) or by electronic mail immediately.

From: Robert Scully <rscully@bklawva.com>
Sent: Wednesday, December 28, 2022 11:33 AM
To: Merritt Green <mgreen@gcpc.com>; Heidi Colwell <hcolwell@mccammongroup.com>; Heba K. Carter <hcarter@gcpc.com>; Erin Boland <eboland@bklawva.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>; Richard Litman <rclitman@gmail.com>
Subject: RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Merritt:

Thanks for the advice about professionalism.

Your clients did not engage in good faith settlement efforts. Stan Klein agrees with me about that. It is why Richard Litman changed advocates - at Stan Klein’s suggestion.

I stand by my recent missive. Each statement was approved by my client. Each is factually accurate. Each is legally supported. Irony is permitted by the Rules of Professional Conduct. It is particularly appropriate here because your clients’ negotiating posture is the epitome of irony. Although they talked for years about wanting to pay their disabled “partner” – they assiduously avoided doing so. “And so [arbitration] came.” (with apologies to Abraham Lincoln. )

When the faux “negotiations” failed Mr. Litman sought adjudication of his civil claims against your clients in this arbitral forum- as the parties agreed he would.

The dispute has not been “largely resolved” by the recent payments from KSU. The payments simply increased the size of Richard’s claim – which Is why I advised Ms. Colwell of the impending request to amend the original Demand to increase that claim.

I will serve as Richard Litman’s counsel until he relieves me. He did not hire me – or Stan Klein - for our “amiability.” He hired us to represent him zealously to liquidate his claim and recover for the damage he suffered.

Richard Litman seeks to refute the law firm’s avaricious, awkward, and unnatural contract interpretation and obtain a complete accounting of what he is owed in the arbitration. I intend to do so - in much the same way as Samuel Johnson refuted Bishop Berkeley’s sophistry that everything in the universe is merely ideal.

Regards,

Bob

Robert E. Scully, Jr., Esq.

Blankingship & Keith, PC
4020 University Drive, Suite 300 ■ Fairfax, VA 22030

Main: (703) 691-1235

Direct Dial: (571) 396-0560
Facsimile: (703)-691-3913

Email: RScully@bklawva.com

www.blankingshipandkeith.com

From: Merritt Green <mgreen@gcpc.com>
Sent: Wednesday, December 28, 2022 9:47 AM
To: Robert Scully <rscully@bklawva.com>; Heidi Colwell <hcolwell@mccammongroup.com>; Heba K. Carter <hcarter@gcpc.com>; Erin Boland <eboland@bklawva.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>; Richard Litman <rclitman@gmail.com>
Subject: RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Bob,

I generally avoid being “ironic” in professional communications - - especially when the parties are bound by professional ethics and, one would hope, plan on engaging in good faith settlement communications. We have always worked towards settling this case amicably and, for our part, hope to continue to do so. I had an excellent relationship with your predecessor, Judge Stan Klein and also, prior to your involvement, had amicable communications with Mr. Litman. It was always my understanding that Mr. Litman wanted this matter resolved as well.

Furthermore, your statement that “Respondent is not going to pay in January or any other time unless compelled” is simply not helpful to reaching this end goal of an amicable settlement.

More substantively, your interpretation of “revenue,” we believe, is incorrect – so, it is not the “end of discussion.” Within the parties’ agreement, the definition of revenue includes a clause “in each case excluding fees and disbursements advanced by NGM.” I believe we have provided Mr. Klein with our analysis and support for this interpretation. It has not been refuted. This interpretation is supported by Section 8 of the Agreement and the parties’ course of dealing. This is an issue that could have been determined in arbitration. However, the payment of the $1.5 million past due balance, and forthcoming payment to your client, largely resolves this matter.

Please provide me with Mr. Litman’s wire transfer information. It is anticipated that a payment shall be made this week. The amount of the payment shall be supported with reports – the same reports Mr. Litman has been provided since the relationship with NGM commenced. These reports have been provided to Mr. Litman not only on a quarterly basis this year, but also on a monthly basis, which is not required by the contract but which my clients have been providing Mr. Litman in the spirit of being up front and open.

NGM has been consistent in its position through its communications to Mr. Litman and my communications with Stan Klein. They have not hidden any information from Mr. Litman. Without fail, I believe, if he has asked for information or some report, it has been provided to him.

I hope that we can have a professional relationship moving forward that works to help our clients resolve the dispute. If you are not capable of such amicable communications or advocacy, perhaps Judge Klein should resume involvement to facilitate settlement.

Sincerely,

Merritt J. Green

Founder/Managing Partner

General Counsel, P.C.

6849 Old Dominion Drive, Suite 220

McLean, VA 22101

Main: 703-556-0411

Direct: 703-556-6505

Fax: 703-774-3965

Email: mgreen@gcpc.com

Website: www.generalcounsellaw.com

Linked In Profile: http://www.linkedin.com/in/merrittgreen

"Every Business Needs a General Counsel"

CONFIDENTIALITY/PRIVILEGE: This electronic message transmission contains information from this law firm which may be confidential or privileged. The information is intended to be for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us by telephone (703-556-0411) or by electronic mail immediately.

From: Robert Scully <rscully@bklawva.com>
Sent: Tuesday, December 27, 2022 2:48 PM
To: Heidi Colwell <hcolwell@mccammongroup.com>; Merritt Green <mgreen@gcpc.com>; Heba K. Carter <hcarter@gcpc.com>; Erin Boland <eboland@bklawva.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>; Richard Litman <rclitman@gmail.com>
Subject: RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

January 4, at 10:00 a.m. please. I do not want to wait another day. My missive was entirely ironic. The Respondent is not going to pay in January or any other time unless compelled by an arbitration award and subsequent judgment to do so.

Regards,

BOb

Robert E. Scully, Jr., Esq.

Blankingship & Keith, PC
4020 University Drive, Suite 300 ■ Fairfax, VA 22030

Main: (703) 691-1235

Direct Dial: (571) 396-0560
Facsimile: (703)-691-3913

Email: RScully@bklawva.com

www.blankingshipandkeith.com

From: Heidi Colwell <hcolwell@mccammongroup.com>
Sent: Tuesday, December 27, 2022 2:45 PM
To: Robert Scully <rscully@bklawva.com>; Merritt Green <mgreen@gcpc.com>; Heba K. Carter <hcarter@gcpc.com>; Erin Boland <eboland@bklawva.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>; Richard Litman <rclitman@gmail.com>
Subject: RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Should we wait to have the joint call until after January 6th or do you all want me to schedule it for the 4th at 10AM (if everyone is still available then)?

Thanks,

Heidi Colwell

Senior Case Manager

The McCammon Group, Ltd.

Direct: 804.433.2246 | Toll Free: 888.343.0922

www.McCammonGroup.com

From: Robert Scully <rscully@bklawva.com>
Sent: Tuesday, December 27, 2022 2:14 PM
To: Merritt Green <mgreen@gcpc.com>; Heidi Colwell <hcolwell@mccammongroup.com>; Heba K. Carter <hcarter@gcpc.com>; Erin Boland <eboland@bklawva.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>; Richard Litman <rclitman@gmail.com>
Subject: RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Merritt:

So I take it that Richard can expect to receive the $1,250,000 the firm owes him by wire transfer prior to January 6, 2023?

If not, then the dispute is not resolved and we will proceed with the arbitration claim.

The law firm refuses to account for and pay their “partner” for whom you claim they have so much affection. The law firm’s ersatz “right” to “ offset” unreimbursed client advances and uncollected fees against its unconditional obligation to pay Richard Litman based on the collected fee receipts on a quarterly basis is not in the contract the parties signed. End of discussion.

As Rod Tidwell said in “Jerry Maguire”: “Show me the Money!”

Regards,

Bob

.

Robert E. Scully, Jr., Esq.

Blankingship & Keith, PC
4020 University Drive, Suite 300 ■ Fairfax, VA 22030

Main: (703) 691-1235

Direct Dial: (571) 396-0560
Facsimile: (703)-691-3913

Email: RScully@bklawva.com

www.blankingshipandkeith.com

From: Merritt Green <mgreen@gcpc.com>
Sent: Tuesday, December 27, 2022 1:48 PM
To: Robert Scully <rscully@bklawva.com>; Heidi Colwell <hcolwell@mccammongroup.com>; Heba K. Carter <hcarter@gcpc.com>; Erin Boland <eboland@bklawva.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>; Richard Litman <rclitman@gmail.com>
Subject: RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Ms. Colwell,

I wanted to briefly clarify a few matters referenced in Mr. Scully’s December 23rd email (see below).

First, on Thursday, December 22nd, Nath, Goldberg & Meyer (“NGM”) received approximately $1.4 million from a client that Mr. Litman has “origination credit” for. NGM was lead to believe that an additional $129,000.00 would be received within the next 60 days. Further, this same client provided approximately $600K in late September, but these monies were earmarked by the client for fees / expenses to be completed and the funds were deposited in the firm’s trust account. Accordingly, although NGM has received approximately $2 million as referenced in Mr. Scully’s email, only approximately $1.4 million was for outstanding debt.

Second, it is important to note that most of the issues underlying this arbitration will be resolved with this Litman client payment. NGM’s interpretation of the parties’ agreements is that payments to Mr. Litman should be offset by fees and expenses owed to NGM. As you can imagine, with a receivable of over $1.5 million, a significant portion represented out-of-pocket expenses that NGM had advanced for USPTO and related costs. Of course, there was also significant attorney / paralegal expense that NGM had advanced. NGM’s position has been consistent – so long as this receivable resulted in NGM being underwater, pursuant to their contracts, they had no obligation to make payments to Mr. Litman. With the $1.4 million payment, this issue has, at least to this large receivable, been resolved.

Finally, Mr. Scully makes another statement in his email that should be corrected. He states that “[s]ince NGM has refused to account for, and pay, Mr. Litman what it owes him. . . .” As stated above, NGM interprets its contractual obligation that it did not have to make payments to Mr. Litman so long as it was “underwater” with outstanding receivables. However, NGM has been diligent in sending Mr. Litman ongoing quarterly reports. Please see attached emails that clearly show that NGM has not, in any manner, “refused to account for” monies potentially owed to Mr. Litman. Perhaps Mr. Litman has not shared these communications with his legal counsel, but NGM has diligently provided Mr. Litman accounting reports, even after Mr. Litman ceased negotiations and had his legal counsel initiate this arbitration.

As reflected in some of the attached communications (and in others not attached), NGM and Mr. Litman have been working, often together, to receive payment for this long awaited receivable. Even though Mr. Scully’s email sets a combative tone of mistrust, NGM has sought to have a cooperative and an amicable relationship with Mr. Litman throughout this process (for example, at Mr. Litman’s request, they have maintained his health insurance longer than required). They were colleagues and friends. NGM hopes that with payment of this past due balance , the parties will be able to work together to amicably resolve this dispute and, perhaps, the arbitration will be unnecessary.

Sincerely,

Merritt J. Green

Founder/Managing Partner

General Counsel, P.C.

6849 Old Dominion Drive, Suite 220

McLean, VA 22101

Main: 703-556-0411

Direct: 703-556-6505

Fax: 703-774-3965

Email: mgreen@gcpc.com

Website: www.generalcounsellaw.com

Linked In Profile: http://www.linkedin.com/in/merrittgreen

"Every Business Needs a General Counsel"

CONFIDENTIALITY/PRIVILEGE: This electronic message transmission contains information from this law firm which may be confidential or privileged. The information is intended to be for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us by telephone (703-556-0411) or by electronic mail immediately.

From: Robert Scully <rscully@bklawva.com>
Sent: Friday, December 23, 2022 11:31 AM
To: Heidi Colwell <hcolwell@mccammongroup.com>; Heba K. Carter <hcarter@gcpc.com>; Erin Boland <eboland@bklawva.com>; Merritt Green <mgreen@gcpc.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>; Richard Litman <rclitman@gmail.com>
Subject: RE: RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Heidi:

I am available on the dates and times Judge Horne is available in January.

Please advise Judge Horn that Mr. Litman will be requesting leave to file an Amended and Supplemental Demand for Arbitration in January to increase the relief sought to not less than $1,200,000.00

We would like to take up that request as an administrative matter at the continued prehearing conference in January.

The factual basis for the supplemental demand is that the King Saud University and affiliates ( collectively “ KSU”) recent paid approximately $2,000,000.00 to NGM. Under the Combination Agreement Mr. Litman is entitled to an accounting, reconciliation and payment of his 20% of the attorney’s fee payments made by KSU within 2 week after the end of each calendar quarter- i.e. January 14, 2022. I expect Litman’s royalty share will be at least another $350,000.00.

Since NGM has refused to account for, and pay, Mr. Litman what it owes him for each preceding quarter of 2022, Mr. Litman has no reason to expect it will begin to perform now. Thus this additional claim, that will arise if NGM does not perform by January 14, ought to be resolved in this proceeding.

Thank you for your close attention to this proceeding.

Happy Holidays,

Bob

Robert E. Scully, Jr., Esq.

Blankingship & Keith, PC
4020 University Drive, Suite 300 ■ Fairfax, VA 22030

Main: (703) 691-1235

Direct Dial: (571) 396-0560
Facsimile: (703)-691-3913

Email: RScully@bklawva.com

www.blankingshipandkeith.com

From: Heidi Colwell <hcolwell@mccammongroup.com>
Sent: Thursday, December 22, 2022 2:15 PM
To: Heba K. Carter <hcarter@gcpc.com>; Robert Scully <rscully@bklawva.com>; Erin Boland <eboland@bklawva.com>; Merritt Green <mgreen@gcpc.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>
Subject: RE: RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Not a problem! Judge Horne can currently do the call anytime on the 3rd or 4th, and is available up until 3PM on the 5th.

Mr. Scully – let us know what works for you.

Thanks,

Heidi Colwell

Senior Case Manager

The McCammon Group, Ltd.

Direct: 804.433.2246 | Toll Free: 888.343.0922

www.McCammonGroup.com

From: Heba K. Carter <hcarter@gcpc.com>
Sent: Thursday, December 22, 2022 1:34 PM
To: Heidi Colwell <hcolwell@mccammongroup.com>; Robert Scully <rscully@bklawva.com>; Erin Boland <eboland@bklawva.com>; Merritt Green <mgreen@gcpc.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>
Subject: RE: RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Good afternoon,

I just received a notification that my son’s daycare will be closing at 12:30pm tomorrow. Unfortunately I have no other childcare and have to be in court tomorrow morning. I do not believe I can have a very productive call with a 2 year old running around. Would the parties and Hon. Judge Horne be amenable to rescheduling this call?

I am available after the holidays:

1/3: 10am-4pm

1/4: 10am-4pm

1/5: 10am-4pm

Thank you for your understanding and consideration.

Heba

Heba K. Carter, Esq.

General Counsel, P.C.

Direct: 571-223-6914

Email: hcarter@gcpc.com

Web: www.gcpc.com

CONFIDENTIALITY/PRIVILEGE: This electronic message transmission contains information from this law firm which may be confidential or privileged. The information is intended to be for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us by telephone (703-782-3523) or by electronic mail immediately.

From: Heidi Colwell <hcolwell@mccammongroup.com>
Sent: Wednesday, December 14, 2022 8:14 PM
To: Robert Scully <rscully@bklawva.com>; Heba K. Carter <hcarter@gcpc.com>; Erin Boland <eboland@bklawva.com>; Merritt Green <mgreen@gcpc.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>
Subject: RE: RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Confirming the call at 1PM on December 23rd.

Please use the dial-in information listed in the Confirmation Memo (attached) at the time of the call.

Thanks,

Heidi Colwell

Senior Case Manager

The McCammon Group, Ltd.

Direct: 804.433.2246 | Toll Free: 888.343.0922

www.McCammonGroup.com

From: Robert Scully <rscully@bklawva.com>
Sent: Wednesday, December 14, 2022 11:14 AM
To: Heidi Colwell <hcolwell@mccammongroup.com>; Heba K. Carter <hcarter@gcpc.com>; Erin Boland <eboland@bklawva.com>; Merritt Green <mgreen@gcpc.com>
Cc: Dana Leinbach <dleinbach@bklawva.com>; Erin Boland <eboland@bklawva.com>
Subject: RE: RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Dear Hedi:

I will make myself and my associate Dana Leinbach available whenever Judge Horn is available in December. I see no reason to delay the initial conference until January.

Since Ms. Carter is available on December 23, I suggest we use that afternoon.

Regards,

Bob

Robert E. Scully, Jr., Esq.

Blankingship & Keith, PC
4020 University Drive, Suite 300 ■ Fairfax, VA 22030

Main: (703) 691-1235

Direct Dial: (571) 396-0560
Facsimile: (703)-691-3913

Email: RScully@bklawva.com

www.blankingshipandkeith.com

From: Heidi Colwell <hcolwell@mccammongroup.com>
Sent: Tuesday, December 13, 2022 10:08 AM
To: Heba K. Carter <hcarter@gcpc.com>; Robert Scully <rscully@bklawva.com>; Erin Boland <eboland@bklawva.com>; Merritt Green <mgreen@gcpc.com>
Subject: RE: RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Good morning Counsel,

I’d like to confirm receipt of both initial retainers.

For the initial conference call with Judge Horne, he is generally available on the following dates: December 19, 20, 21 (after 4PM), 23, 28, 29, 30.

Please let me know what days/times work for you.

Thanks,

Heidi Colwell

Senior Case Manager

The McCammon Group, Ltd.

Direct: 804.433.2246 | Toll Free: 888.343.0922

www.McCammonGroup.com

From: Heidi Colwell
Sent: Tuesday, December 6, 2022 4:09 PM
To: Heba K. Carter <hcarter@gcpc.com>; Robert Scully <rscully@bklawva.com>; Erin Boland <eboland@bklawva.com>; Merritt Green <mgreen@gcpc.com>
Subject: RE: Richard C. Litman v. Nath & Associates, PLLC, et al.

Counsel,

This will confirm that Hon. Thomas D. Horne (Ret.) is free of conflicts and has been appointed to arbitrate this matter pursuant to the strike process outlined in Rule 7 of the Agreement to Arbitrate.

Judge Horne’s hourly rate will be $575/hr with travel time billed at ½ that rate plus expenses. An initial retainer in the amount of $8,625 ($4,312.50 per party) will be necessary to proceed. Retainer invoices are attached for your convenience.

Upon receipt of the necessary retainer(s), we will schedule a pre-arbitration call.

Let us know if you have any questions or concerns.

Thanks,

Heidi Colwell

Senior Case Manager

The McCammon Group, Ltd.

Direct: 804.433.2246 | Toll Free: 888.343.0922

www.McCammonGroup.com

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NOTICE This email message originated from outside of your organization. Please use caution when responding, opening attachments, and clicking links.

NOTICE This email message originated from outside of your organization. Please use caution when responding, opening attachments, and clicking links.

NOTICE This email message originated from outside of your organization. Please use caution when responding, opening attachments, and clicking links.

NOTICE This email message originated from outside of your organization. Please use caution when responding, opening attachments, and clicking links.

NOTICE This email message originated from outside of your organization. Please use caution when responding, opening attachments, and clicking links.