# Schaeffer & Gray — Deposition Prep Memo

**Case:** Litman v. Goldberg, NY Sup. Ct., Kings County, Index No. 524343/2025
**Prepared:** 2026-04-18
**Deponents:** Deborah J. Schaefer, CPA (NGM's CPA of record) and Valencia N. Gray ("Accounting Specialist," NGM)
**Drafting directive:** Richard C. Litman (4/18/2026 verbal instruction)

---

## 0. Executive Summary

Two accounting-personnel witnesses are the operational hands on the post-arbitration
trust-to-operating sweep pattern that diverted Litman-originated fees from
Attorney 418 allocation into Nath & Associates operating accounts.

- **Schaefer** is the external CPA who (a) designed or blessed the report package Litman
  received, (b) held the reconciliation workpapers, (c) authored the Kren/closure summary
  that excluded Freedom Bank, and (d) made the admission "not supposed to have trust money
  for your own money."
- **Gray** is the internal accounting specialist whose initials ("VG") appear on the
  operative sweep entries — including the **11/20/2024 $493,898.00 Nath & Associates
  sweep** and the mirror **2/10/2026 $224,113.00 Nath & Associates sweep** from docket
  36372 (KFU), plus 133 of 150 Q1 2026 trust-to-operating transfer entries.

**Counts (email corpus, Concordance DAT):**

| Actor | Unique Bates email hits | Notable-year peaks |
|-------|-------------------------|--------------------|
| Schaefer (non-spam) | **~150** (of 168 raw hits; ~18 are third-party CLE promotional mail) | 2024: 88, 2025: 98 |
| Gray | **1,697** | 2020: 315, 2023: 448, 2024: 306, 2025: 329 |

Source file: `discovery_production/DATA/LITMAN_EMAIL_PRODUCTION.dat`

---

## PART A — Accountability Timelines

### A.1 Deborah J. Schaefer — Chronological Activity Log

| Date | Event | Source |
|------|-------|--------|
| 2023-08-15/17 | Schaefer meets with Litman re accounting controls; "CPA identifies concerns after meeting with Litman" | `output/ANOMALOUS_TRANSACTIONS_CATALOG.md` timeline line entry 354 |
| 2024-01-03 | "T-Codes" email thread: Litman asks to be walked through monthly reports; Schaefer offers week-of scheduling; Goldberg CC'd and agrees ("I will leave it to the two of you") | LITMAN186613, LITMAN196614, LITMAN196618, LITMAN208376, LITMAN208394, LITMAN265487, LITMAN265488 |
| 2024-01-05 | Litman asks when December reports will be ready | LITMAN265489 |
| 2024-01-07/08 | Schaefer transmits December 2023 report package with descriptions for five reports: **Trust Listing (balance by client), Trust Bank Register (bank transactions in date order), Trust Bank Journal (bank transactions with file detail), Accounts Receivable, Payment Allocation**. Attachments: "Trust Bank Journal (2).pdf; Trust Bank Register.pdf; Trust Listing.pdf; Accounts Receivable.pdf; Payment Allocation.pdf" | **LITMAN196703**; Litman forward at LITMAN265514 (1/9/2024) |
| 2024-01-24 | "The Pad" spreadsheet thread. Litman forwards the Van Giezen directive to Schaefer with the now-famous questions: "Shouldn't the invoice numbers always be known at this point... how is the firm sure that all work is being done and all work invoiced?" Schaefer answers: "Yes we will be starting using Soluno for all new invoices on 2/1/23 [sic] … I am working with the staff to be sure all work is accounted for." | LITMAN207531, LITMAN265541, LITMAN265542 |
| 2024-02-02 | Litman to Goldberg: "I am impressed by Debbie's knowledge and appreciate you getting somebody of her caliber to implement the accounting system" (relevant to demonstrating reliance) | LITMAN265545, LITMAN265546 |
| 2024-02-09 | Litman flags "low" January reconciliation to Goldberg and asks whether payments went into "other accounts" (~Freedom Bank query period). Explicitly references "Debbie" as the focal accountant | LITMAN265557, LITMAN265558, LITMAN266458 (Goldberg transmit, same date) |
| 2024-02 (same window) | Per `ANOMALOUS_TRANSACTIONS_CATALOG.md` §3 timeline line 356: Litman asks Schaefer / Goldberg about **Freedom Bank trust accounts**; requests closure or name removal | Anomalous Cat. §3 entry 356 |
| 2025-05-26 | Litman requests "a list of all clients assigned to my Attorney number 418" ... "Soluno reports for Atty 418 to present" — copied into channels Schaefer supports | LITMAN199161, LITMAN266081, LITMAN266082 |
| 2025-06-05 | Litman announces he has been "going through all this financial stuff"; preparing a summary of issues "from the monthly Soluno reports from July 2023 through April 2025" | LITMAN184029, LITMAN184026 |
| 2025-06-18 | Litman diagnoses "massive amount of activity" and "missing KFU allocations" tied to 36372 | LITMAN184441, LITMAN271060 |
| 2025-06-19 | Schaefer transmits "Reports requested" package: **List of Files RL Resp.pdf; Trust Ledger for account 36372.pdf; All trust ledgers for all matters for resp RL.pdf; All clients and FIles.pdf**. She writes: "Trust detailed ledger for matter 36372 - This details where funds were moved to." | **LITMAN221615** |
| 2025-06 | Litman email to Goldberg/Schaefer lists "many clients not included including MSRDC, some universities and more" missing from Atty-418 allocation | Anomalous Cat. §2 entry 42 |
| 2025-06-25 | Schaefer verbal statement: firm is "not supposed to have trust money for your own money" — trust accounts being closed | Anomalous Cat. §3.6 |
| 2025-06-26 | Kren/Carter "NGM—Matters" letter circulates; Schaefer's closure summary is the predicate for the Kren report | LITMAN184608 / LITMAN221800 |
| 2025-06-28 | Litman forwards the Kren-matters thread; auto-reply from Grace Kren captures subject "Continued Use of My Name and Role as Senior Counsel (2017–2025)" | LITMAN184639, LITMAN221883, LITMAN265920, LITMAN265921, LITMAN278343 |

**Corpus totals for Schaefer (non-spam):** 2019: 49, 2020: 52, 2021: 89, 2022: 4, 2023: 53, 2024: 88, 2025: 98. Raw hit count 168; spam/promo filter removes ~18 CLE-platform and phishing hits. Numbers from python csv scan of `LITMAN_EMAIL_PRODUCTION.dat`.

### A.2 Valencia N. Gray — Chronological Activity Log

Gray's role is "Accounting Specialist" at NGM (signature block, e.g., LITMAN002932,
LITMAN003048) reporting up to Kimberly G. Thompson ("Accounting Manager"). Her daily
function is intake of incoming wire notifications, allocation to dockets, and
trust-to-operating transfers.

| Date | Event | Source |
|------|-------|--------|
| 2019-09-25 → 2023-12 | Hundreds of incoming wire acknowledgments; Gray is the universal recipient / allocator of Martha Long's KISR, KFU, KU, Qatar University wire breakdowns (representative: LITMAN002115, LITMAN002399, LITMAN002473, LITMAN002474, LITMAN002932 (she instructs Kimberly to "transfer Kuwait University wire to BOA operating"), LITMAN002934, LITMAN002935, LITMAN003000, LITMAN003048, LITMAN003063–3066) | Email corpus |
| 2020-02-27 | FW: Qatar University incoming wire allocation list | LITMAN027454 |
| 2024-11-07 | **Gray transmits**: "$499,487.00 International Money Transfer Credit RE: Payment from King Faisal University" to Martha Long and Joshua Goldberg. Follow-up reply within same thread acknowledges Long's breakdown: "Got it, thanks!" | **LITMAN247493**, LITMAN247494, LITMAN247495 |
| 2024-11-19 | Gray transmits: "$499,658.00 International Money Transfer Credit RE: Payment Made by King Faisal University" | **LITMAN247438**, LITMAN247439 |
| **2024-11-20** | **Trust Bank Journal entry 3844418** — "Nath & Associates PLLC 106715 - Nath & Assoc | 2120 | $493,898.00 | $877,950.27 | **VG**" — $493,898.00 sweep from docket 36372 to operating, signed VG | `output/TURN_AND_BURN_kfu_nath_transfers.csv` line for 11/20/2024; corroborated in `KFU_36372_TRUST_LEDGER_ANALYSIS_20260416.md` |
| 2024-11-18/19 | Gray on smaller SQU wire credits (validates she has allocation authority) | LITMAN210508, LITMAN210607, LITMAN254038 |
| 2024-10-30 | Gray handles "$315 Incoming Money Transfer Credit PROTOTEC PROJECT MANAGEMENT" | LITMAN200236, LITMAN269657 |
| 2025-05-20 | Gray transmits multiple incoming money transfer credits, Kuwait University | LITMAN220194 |
| **2026-02-09** | **Trust Bank Journal entry 4000959** — "King Faisal University 135900 - King Faisal | 7438 | $291,173.00 | **VG**" — inflow to t23 docket 36372 | `TURN_AND_BURN_kfu_nath_transfers.csv` |
| **2026-02-10** | **Trust Bank Journal entry 4001216** — "Nath & Associates PLLC 106715 - Nath & Assoc | EFT-37 | $224,113.00 | **VG**" — Trust to Op, memo "Trust to Op KFU General docket 36372 ... 224,113.00" from 2026-02/Trust_Bank_Journal_Feb_2026 | `TURN_AND_BURN_kfu_nath_transfers.csv` line 600; Feb 2026 Trust Bank Journal |
| **Q1 2026** | Of 150 trust transfer entries, **133 are signed VG** (the balance 17 are TC). VG total transfer amount $802,312.32 in Q1 2026 across all dockets; at least 25 entries are KFU/Kuwait-University family (36372, 33044.*, 33050.*, 33110.*) | `output/Q1_2026_trust_transfers.csv` (machine-parsed); `Q1_2026_TRUST_POSITIONS_AND_TRANSFERS.md` |
| 2026-01-02 | VG-signed entries include: TO t23→o22 $2,400 (Al-Hamli 200801.03Y invoice 422838); OO o12→o22 $300,000 "Transfer to EagleBank Op" | `Q1_2026_trust_transfers.csv` |
| 2026-01-13 | VG-signed TO t3→o12 $15,296 Kuwait University 33050.10U invoice 422965 | `Q1_2026_trust_transfers.csv` |
| 2026-01-26 | VG-signed OO o12→o22 $30,000 "Transfer BOA to EB OP" | `Q1_2026_trust_transfers.csv` |
| 2026-01-26 | Multiple VG-signed Kuwait University multi-thousand-dollar transfers (33044.90U/93U/94U) | `Q1_2026_trust_transfers.csv` |

---

## PART B — Document Inventory (Bates-cited)

### B.1 Schaefer — Documents (≥ 20)

| # | Bates | Date | Role | Description |
|---|-------|------|------|-------------|
| 1 | **LITMAN186613** | 2024-01-03 | Author | "RE: T-Codes" scheduling weekly walkthrough |
| 2 | **LITMAN196614** | 2024-01-03 | Author | "RE: T-Codes" — confirms invoices "not quite in Soluno" |
| 3 | LITMAN196618 | 2024-01-03 | CC/Recipient | Goldberg reply on T-Codes scheduling |
| 4 | LITMAN208376 | 2024-01-03 | CC/Recipient | Duplicate of 196618 |
| 5 | LITMAN208394 | 2024-01-03 | Author | Meeting availability list |
| 6 | LITMAN265487 | 2024-01-03 | Recipient | Litman to Schaefer — "walk me through the monthly reports" |
| 7 | LITMAN265488 | 2024-01-03 | Recipient | Litman follow-up on T-Codes |
| 8 | LITMAN265489 | 2024-01-05 | Recipient | Litman: "When do you think you can get the end of December reports?" |
| 9 | **LITMAN196703** | 2024-01-07 | **Author** | **"RE: What I received?" — five-report package with descriptions of Trust Listing / Trust Bank Register / Trust Bank Journal / A/R / Payment Allocation. Attachments: Trust Bank Journal (2).pdf; Trust Bank Register.pdf; Trust Listing.pdf; Accounts Receivable.pdf; Payment Allocation.pdf** |
| 10 | LITMAN265514 | 2024-01-09 | Forwarded | Litman forwards Schaefer's package to his gmail for preservation |
| 11 | LITMAN208423 | 2024-01-05 | Author | "RE: What I received?" opening email |
| 12 | **LITMAN207531** | 2024-01-24 | **Author** | **"RE: The Pad Spreadsheet" — explicit admission: "I am working with the staff to be sure all work is accounted for"** |
| 13 | LITMAN265541 | 2024-01-24 | Recipient | Litman transmits The Pad questions to Schaefer |
| 14 | LITMAN265542 | 2024-01-24 | Recipient | Duplicate of 265541 |
| 15 | LITMAN265545 | 2024-02-02 | Referenced | Litman to Goldberg re Schaefer's "caliber" |
| 16 | LITMAN265546 | 2024-02-02 | Referenced | Duplicate of 265545 |
| 17 | LITMAN265557 | 2024-02-09 | Referenced | Litman to Goldberg: "after you have more focus with Debbie" / payments-in-other-accounts question |
| 18 | LITMAN265558 | 2024-02-09 | Referenced | Duplicate of 265557 |
| 19 | LITMAN266458 | 2024-02-09 | Referenced in thread | Goldberg's January reconciliation transmittal — Schaefer is the preparer |
| 20 | LITMAN199161 | 2025-05-26 | Referenced | Litman on Soluno reports for Atty 418 |
| 21 | LITMAN266081 | 2025-05-26 | Referenced | Soluno reports inquiry |
| 22 | LITMAN266082 | 2025-05-26 | Referenced | Soluno reports inquiry |
| 23 | LITMAN184029 | 2025-06-05 | Referenced | Litman summarizes Soluno issues (July 2023–April 2025) to Goldberg / Schaefer |
| 24 | LITMAN184026 | 2025-06-05 | Referenced | Companion to 184029 |
| 25 | LITMAN184441 | 2025-06-18 | Referenced | KFU 36372 "missing allocations" thread |
| 26 | LITMAN271060 | 2025-06-18 | Referenced | Duplicate of 184441 |
| 27 | **LITMAN221615** | 2025-06-19 | **Author** | **"RE: Reports requested" — authoring of List of Files RL Resp.pdf; Trust Ledger for account 36372.pdf; All trust ledgers for all matters for resp RL.pdf; All clients and FIles.pdf** |
| 28 | LITMAN184608 | 2025-06-26 | Referenced | Heba Carter "NGM—Matters" transmittal (Kren firm uses Schaefer's summary) |
| 29 | LITMAN221800 | 2025-06-26 | Referenced | Duplicate of 184608 |
| 30 | LITMAN184639 / LITMAN221883 | 2025-06-28 | Referenced | Kren auto-reply in "Senior Counsel 2017–2025" thread |

**Additional Schaefer attachments to subpoena separately** (identified by ATTACHMENT_NAMES in the DAT rows above): the five monthly PDFs transmitted 1/7/2024 and the four RL-responsibility ledger PDFs transmitted 6/19/2025.

### B.2 Gray — Documents (≥ 20)

| # | Bates / Entry | Date | Role | Description |
|---|---------------|------|------|-------------|
| 1 | LITMAN002115 | 2019-09-25 | Recipient | KISR wire breakdown from Martha Long |
| 2 | LITMAN002124 | 2019-09-25 | **Author** | KISR 32366.67 wire documentation to James Lafave / Lindsay Dunbar |
| 3 | LITMAN002399 | 2019-10-03 | Recipient | FW: Kuwait University 33044.01 incoming wire |
| 4 | LITMAN002473 | 2019-10-01 | Recipient | Credit Card Authorization Approved |
| 5 | LITMAN002474 | 2019-10-01 | Recipient | Sabah Al-Ahmad Center payment |
| 6 | LITMAN002932 | 2019-10-22 | **Author** | "RE: Incoming Wire Notification — Kuwait University — 23588.98" — **Gray instructs Kimberly: "transfer Kuwait University wire to BOA operating under docket no. 23588.98 please"** |
| 7 | LITMAN002934 | 2019-10-22 | Recipient | Thompson confirms wire transfer completed |
| 8 | LITMAN002935 | 2019-10-22 | Recipient | Long — KISR wire breakdown |
| 9 | LITMAN003000 | 2019-10-22 | **Author** | Gray chases Lafave on "pad entry shortly" for KISR 32366.67 |
| 10 | LITMAN003001 | 2019-10-22 | Recipient | Lafave: "notification was held up in the review process" |
| 11 | LITMAN003048 | 2019-10-23 | **Author** | "Acknowledged with thanks" — same thread |
| 12 | LITMAN003063 | 2019-10-29 | Recipient | 32715.56 Filing receipt query |
| 13 | LITMAN003064 | 2019-10-29 | **Author** | Gray asks Long follow-up questions re 32715.56 filing receipt |
| 14 | LITMAN003065–3066 | 2019-10-29 | Recipient | Long follow-up on filing fee |
| 15 | LITMAN003324 | 2019-11-05 | Recipient | Thompson sets up ACH transfer — KFU |
| 16 | LITMAN027454 | 2020-02-27 | Recipient | Qatar University wire allocation list |
| 17 | LITMAN019692 | 2020-02-14 | Recipient | Three credit cards declined |
| 18 | LITMAN022343 | 2020-03-26 | Recipient | KISR wire breakdown |
| 19 | LITMAN016882 | 2020-03-31 | **Author** | Kuwait University 23588.98 follow-up |
| 20 | LITMAN017057 | 2020-04-01 | Recipient | KU 23588.95 ACH confirmation |
| 21 | LITMAN017013 | 2020-04-06 | Recipient | Sabah Al-Ahmad Center 4/6/2020 wire |
| 22 | LITMAN200677 | 2024-08-07 | **Author** | REMINDER IMSIU status-of-payments |
| 23 | LITMAN200236 | 2024-10-30 | **Author** | "$315 Incoming Money Transfer Credit PROTOTEC PROJECT MANAGEMENT" |
| 24 | LITMAN269657 | 2024-10-30 | **Author** | Duplicate of 200236 |
| 25 | **LITMAN247493** | 2024-11-07 | **Author** | **"$499,487.00 International Money Transfer Credit RE: Payment from King Faisal University" — first of the paired twin-wire November pattern** |
| 26 | LITMAN247494 | 2024-11-07 | Recipient | Long's breakdown of 499,487 |
| 27 | LITMAN247495 | 2024-11-07 | **Author** | "Got it, thanks!" acknowledgment |
| 28 | LITMAN210508 | 2024-11-18 | Recipient | SQU $480 credit |
| 29 | LITMAN254038 | 2024-11-18 | Recipient | Duplicate of 210508 |
| 30 | LITMAN210607 | 2024-11-19 | Recipient | CIP wire credit |
| 31 | **LITMAN247438** | 2024-11-19 | **Author** | **"$499,658.00 International Money Transfer Credit RE: Payment Made by King Faisal University" — second of the November paired wires** |
| 32 | LITMAN247439 | 2024-11-19 | Recipient | Long's 499,658 breakdown |
| 33 | **Trust Bank Journal entry 3844418** | **2024-11-20** | **Signer (User = VG)** | **Nath & Associates sweep $493,898.00, docket 36372 → Operating** |
| 34 | Trust Bank Journal entry 3844512 | 2024-11-20 | Signer (VG) | KFU inflow $499,658.00 — same-day credit |
| 35 | LITMAN220194 | 2025-05-20 | **Author** | Multiple KU incoming money transfer credits |
| 36 | **Trust Bank Journal entry 4000959** | **2026-02-09** | **Signer (VG)** | KFU inflow $291,173.00 → t23 docket 36372 |
| 37 | **Trust Bank Journal entry 4001216** | **2026-02-10** | **Signer (VG)** | **Nath & Associates $224,113.00 sweep — "Trust to Op KFU General docket 36372"** |
| 38–170 | Q1 2026 trust_transfers.csv | 2026-01-02 → 2026-03-31 | Signer (VG) | 133 additional transfer entries (list available in `output/Q1_2026_trust_transfers.csv`, filterable by `user == VG`) |

---

## PART C — Deposition Question Sets

### C.1 Schaefer — 40 Questions

#### Block (i) — Professional Engagement / Scope with NGM
1. When did Nath, Goldberg & Meyer, PLLC (now Nath & Associates PLLC) first engage Deborah J. Schaefer, CPA?
2. Is the engagement with you personally, with "Deborah J. Schaefer CPA" the sole-proprietor entity, or with a firm?
3. Produce or identify the written engagement letter and every amendment.
4. Was your engagement scope "compilation," "review," "audit," or "bookkeeping/consulting"? Which reports did you prepare vs. compile vs. simply transmit?
5. Did your engagement require you to issue any trust-compliance representation to NGM's clients, to the arbitration panel, or to any court?

#### Block (ii) — Monthly Trust Reconciliation Procedures
6. Describe the monthly trust reconciliation workflow at NGM from January 2024 through July 2025.
7. Identify every bank account — by institution, account number, and purpose — that you reconciled each month.
8. Your 1/7/2024 email (LITMAN196703) described five reports: Trust Listing, Trust Bank Register, Trust Bank Journal, A/R, Payment Allocation. Is that the complete set of trust-reconciliation deliverables?
9. On a three-way reconciliation, the Trust Listing (per-client balances) should equal the Trust Bank Register (bank transaction total) plus/minus in-transit items. Is that correct?
10. Did you ever observe a month where the Trust Listing and the Trust Bank Register did not reconcile? If so, what did you do?
11. Did you sign, initial, or electronically approve the monthly reconciliation worksheets? Produce them.

#### Block (iii) — Freedom Bank
12. Are you aware that NGM (or Nath & Associates PLLC) maintained a trust or operating account at Freedom Bank?
13. When did you first learn of the Freedom Bank account?
14. Was Freedom Bank included in the monthly reconciliations you performed?
15. Was the Freedom Bank account included in any report, memorandum, schedule, or summary you authored — including but not limited to the materials provided to Grace Kren or to Heba Carter / Kren firm on or about 6/26/2025?
16. If Freedom Bank was **not** included, who instructed you to omit it, or what was your reason for omitting it?
17. Did Richard Litman ever ask you — orally or in writing — about Freedom Bank trust accounts? Specifically, on or about 2/9/2024?
18. After Freedom Bank closed on 7/28/2025 — one week after this litigation was filed — did you receive the closure statement? Produce it.
19. **CASE-ENDING ADMISSION QUESTION**: Did you know before 7/28/2025 that NGM maintained an undisclosed third trust account at Freedom Bank containing client funds?

#### Block (iv) — The $1.78M Phantom BoA Balance
20. In the December 2023 package you transmitted on 1/7/2024, did the Trust Listing and the Trust Bank Register of the same month show the same total for the Bank of America trust account?
21. If the Trust Listing showed approximately $1.78 million of trust balance and the same-month Trust Bank Register did not support that number, how is that possible?
22. What is Soluno's reconciliation feature, and does it allow manual entries on the Trust Listing that do not hit the Trust Bank Register? Who at NGM has permission to post those entries?

#### Block (v) — The Twin KFU Sweeps (11/20/2024 and 2/10/2026)
23. Did you reconcile the Bank of America trust account for November 2024? Yes or no.
24. Are you aware of the $493,898.00 transfer on 11/20/2024 from docket 36372 to "Nath & Associates PLLC" operating (Trust Bank Journal entry 3844418)?
25. What legal-fee invoice, if any, supported that $493,898.00 transfer?
26. Did the $499,658.00 KFU wire received on 11/19/2024 support an invoice aggregating $493,898.00?
27. Did you reconcile the Bank of America trust account for February 2026?
28. Are you aware of the $224,113.00 transfer on 2/10/2026 (Trust Bank Journal entry 4001216) — which repeats the November 2024 pattern?
29. Did you flag either transaction to counsel, to Goldberg, or to Litman?

#### Block (vi) — Disability Offset / MetLife / Arbitration
30. Are you familiar with the arbitration award entered 6/14/2023 in the Litman v. Goldberg / NGM arbitration?
31. Did you adjust Litman's share of collected fees by any amount identified as a "MetLife offset" of approximately $290,000?
32. Was the MetLife $290,000 offset ever actually paid? Or was it a paper offset that was later returned to the insurer on SS approval?
33. If the offset was not paid, why was it applied to Litman's arbitration allocation?

#### Block (vii) — Client Renumbering / Attorney 418
34. What is "Attorney 418"? Whose code is it?
35. Were any Litman-originated clients assigned alternate responsible-attorney codes that bypassed Attorney 418?
36. When Litman wrote to Goldberg on 5/26/2025 asking for "all Attorney 418 clients from July 2023 to current" (LITMAN199161), were you able to produce a complete list?
37. You stated in your 6/19/2025 email (LITMAN221615) that you were "unable to find the invoices [Litman] specified." Did you search Soluno only, or also PC Law / STI / other legacy systems?
38. You told Litman the firm was "not supposed to have trust money for your own money." What did you mean, and who else was told that?

#### Block (viii) — Privilege / Ethics / RPC 1.15
39. Are you familiar with Virginia RPC 1.15 and New York Rule 1.15 governing trust accounts?
40. Did you make any written representation to the arbitration panel (the AAA panel or the enforcement proceeding) concerning the accuracy of NGM's trust accounting? Produce each such representation.

---

### C.2 Gray — 42 Questions

#### Block (i) — Role / Reporting Chain
1. State your full title at NGM / Nath & Associates PLLC.
2. Who was your direct supervisor in 2019? In 2024? In 2026?
3. Identify each person at the firm who could give you an instruction to execute a trust-to-operating transfer.
4. Who trained you on the firm's trust-account workflow? Soluno training records — produce them.
5. Describe your signature authority on (a) Soluno, (b) Bank of America, (c) EagleBank, (d) Freedom Bank, (e) any trust-account wire instruction.

#### Block (ii) — Q1 2026 Transfer Authorship (133 of 150 Entries)
6. `output/Q1_2026_trust_transfers.csv` reflects 133 Q1 2026 trust transfers where the "user" column reads "VG." Is that you?
7. What does "VG" in the Soluno user column reflect — (a) the person who physically entered the transaction, (b) the person who authorized it, or (c) both?
8. Did anyone other than you log into Soluno using your credentials during Q1 2026?
9. For each of the 133 VG-signed entries, did you obtain an invoice in hand before executing the transfer, or did you execute against a batch instruction?
10. Who gave you the Q1 2026 batch instructions? Produce the emails and work-order files.

#### Block (iii) — Turn-and-Burn Template on Docket 36372
11. Docket 36372 is the King Faisal University "general" file. Correct?
12. Who at NGM is the responsible attorney on 36372 for billing purposes as of 1/1/2024? As of 1/1/2026?
13. Has docket 36372 ever been billed with a formal, client-facing invoice?
14. The 11/20/2024 entry 3844418 moved $493,898.00 from 36372 to Nath & Associates operating. Who gave you that instruction, orally or in writing?
15. Was there a cover memo, email, or written invoice for the $493,898.00 transfer? Produce it.

#### Block (iv) — 2/9–2/10/2026 $291K Inflow + $224K Sweep
16. Entry 4000959 on 2/9/2026 records a $291,173.00 inflow from King Faisal University, 135900, with wire reference 7438. Did you post that entry?
17. Entry 4001216 on 2/10/2026 records a $224,113.00 outflow with the memo **"Trust to Op KFU General docket 36372 135900 - King Faisal University 224,113.00"**. Did you post that entry?
18. Who provided that memo text — "Trust to Op KFU General" — to you?
19. Does the internal NGM wire-allocation memo for the 2/6/2026 wire describe the wire narrative as "Wire KFU 2.6.2026 Retainer"? If so, who drafted that narrative?
20. **CASE-ENDING ADMISSION QUESTION**: Were you instructed to characterize the 2/6/2026 KFU wire as a "retainer" rather than as payment against outstanding invoices?
21. Compare the November 2024 pair ($499,658 inflow / $493,898 sweep) and the February 2026 pair ($291,173 inflow / $224,113 sweep). Are these the same template?

#### Block (v) — Jan→Feb 2026 $13,326 Eagle Bank Continuity Gap
22. Are you aware of a $13,326 discrepancy between the Eagle Bank January 2026 ending balance and the February 2026 opening balance?
23. Did you enter any reconciling Soluno entries in that window?
24. Produce every email you sent or received between 1/28/2026 and 2/5/2026 referencing Eagle Bank balances or transfers.

#### Block (vi) — Jan 31→Feb 1 2026 Responsible-Attorney Reassignment
25. Was any responsible-attorney code changed in Soluno between 1/31/2026 and 2/1/2026 on any KFU or Kuwait University matter?
26. Who directed that reassignment?
27. What did Attorney 418's allocation look like on 1/31/2026 vs. 2/1/2026?

#### Block (vii) — Client Renumbering / Bypass of Attorney 418
28. Did you, during the period 7/2023 – 4/2026, assign any new client number, new matter sub-number, or alternate responsible-attorney code to a client who had previously been associated with Attorney 418?
29. When you did so, who instructed you?
30. Identify every client-number alias that was used for Litman-originated clients: list them.

#### Block (viii) — Schaefer Interactions
31. How often did you communicate with Deborah Schaefer?
32. Did you transmit the monthly Soluno reports to Schaefer? Which reports?
33. Did Schaefer ever reconcile the $493,898.00 11/20/2024 sweep or the $224,113.00 2/10/2026 sweep with you?
34. Did Schaefer ever ask you for documentation of either sweep?
35. Did you ever disclose the Freedom Bank account to Schaefer? If yes, when and how?

#### Block (ix) — November 2024 Incoming Wire Pair
36. You transmitted LITMAN247493 on 11/7/2024 acknowledging the $499,487.00 KFU wire. Was that wire allocated to specific invoices at the time of your email?
37. You transmitted LITMAN247438 on 11/19/2024 acknowledging the $499,658.00 KFU wire. Same question.
38. Why did two KFU wires of nearly identical amount ($499,487 and $499,658) arrive within 12 days of each other?
39. Produce the SWIFT / FedWire advices and the NGM internal allocation sheet for each.
40. The $493,898.00 sweep on 11/20/2024 — one day after the second wire — was signed by you. What did you believe that sweep represented?
41. Was the sweep proportional to any invoice total? Produce the reconciling invoice(s).
42. **CASE-ENDING ADMISSION QUESTION**: Did anyone at NGM instruct you that dockets 36372 and 135900 were to be used as holding accounts for pre-invoice funds?

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## PART D — Pre-Deposition Discovery Demands

Serve these as a supplemental 3104 demand (or as formal CPLR Art. 31 / VA Rule 4:9
discovery demands, consistent with the case's pending BOP/discovery calendar)
**before either deposition goes forward.**

### D.1 Documents from / about Deborah J. Schaefer
1. The engagement letter(s) between NGM / Nath & Associates PLLC and Deborah J. Schaefer, CPA, and every amendment.
2. Every W-9, 1099, and invoice issued by Schaefer to NGM from 2017 to present.
3. All monthly trust-account reconciliation workpapers prepared or reviewed by Schaefer from 1/1/2020 to present — including supporting bank statements for every bank account (Bank of America, Eagle Bank, Freedom Bank, any other).
4. The complete "December 2023 reports" package referenced in LITMAN196703 and its attachments: Trust Bank Journal (2).pdf; Trust Bank Register.pdf; Trust Listing.pdf; Accounts Receivable.pdf; Payment Allocation.pdf.
5. The complete 6/19/2025 package referenced in LITMAN221615: List of Files RL Resp.pdf; Trust Ledger for account 36372.pdf; All trust ledgers for all matters for resp RL.pdf; All clients and FIles.pdf.
6. All communications between Schaefer and Grace Kren, Heba Carter, or any Kren-firm attorney concerning the June 2025 "NGM—Matters" summary.
7. All communications between Schaefer and Joshua Goldberg from 6/1/2023 to present — unredacted.
8. All communications between Schaefer and Litman — produced in native Outlook/MSG format with full headers.
9. All internal memoranda, notes, or workpapers reflecting Schaefer's analysis of (a) Freedom Bank, (b) the $290,000 MetLife offset, (c) the Litman arbitration award, (d) Attorney 418.
10. Any representation, letter, affidavit, or declaration Schaefer made to the AAA arbitration panel or to counsel in the arbitration enforcement proceeding.
11. Soluno user-access logs showing Schaefer's login history, permissions, and any administrative changes she executed.
12. All email archives (Exchange / M365 mailbox export) for Schaefer's NGM-facing email address (djscpa@deborahjschaefer.com) for the period 1/1/2023 – present.

### D.2 Documents from / about Valencia N. Gray
13. Gray's NGM personnel file including title history, reporting chain, performance reviews, and compensation records.
14. Gray's complete M365 mailbox export (vgray@nathlaw.com and any successor address) for the period 1/1/2023 – present, including Deleted Items, Recoverable Items (Dumpster), and Archive.
15. Soluno and PC Law / STI user-access logs for Gray (logins, transactions posted, transactions reversed, administrative actions).
16. All Bank of America, EagleBank, and Freedom Bank signature cards, wire authorization forms, and online-banking user-permission records showing Gray's rights.
17. Every "Incoming Wire Notification" email chain from 6/15/2020 to present in which Gray is author, recipient, or CC.
18. Every trust-to-operating transfer request form, Soluno work-order, or email instruction from Goldberg, Nath, Kline, Meyer, Thompson, or any other firm attorney to Gray directing a trust transfer of $50,000 or more, from 6/15/2020 to present.
19. The complete Trust Bank Journal, Trust Transfer Journal, and Trust Bank Register for every month from 10/2024 through 3/2026 — in native Soluno export format (.xlsx).
20. The underlying SWIFT / FedWire / international wire advices for the 11/7/2024 $499,487 KFU wire, the 11/19/2024 $499,658 KFU wire, and the 2/9/2026 $291,173 KFU wire.
21. All invoices (formal, client-facing) that the $493,898 (11/20/2024) and $224,113 (2/10/2026) transfers purported to pay.
22. Every document showing the wire narrative text "Wire KFU 2.6.2026 Retainer" and the authorship of that text.
23. Every reassignment of responsible attorney on any KFU, KSU, KISR, SQU, UAEU, or Kuwait-University matter between 1/1/2024 and 4/1/2026 — Soluno audit trail.
24. All Q1 2026 transfer backup: for each of the 150 Q1 2026 trust-transfer entries, produce the invoice, the client approval, and the email instruction.
25. All communications between Gray and Schaefer from 1/1/2023 – present.

### D.3 Cross-Cutting Demands
26. A Rule 30(b)(6)-style notice (adapted for NY CPLR) to Nath & Associates PLLC for a corporate designee on: trust reconciliation procedures, Soluno user permissions, and wire-narrative authorship.
27. A subpoena duces tecum to Bank of America, EagleBank, and Freedom Bank for all account statements, signature cards, wire activity, and closure statements for any NGM or Nath & Associates PLLC account from 6/15/2020 to present.
28. A subpoena to Soluno (CARET Legal) for the audit log of all user actions by users "VG," "TC," "JBG," and any admin user from 1/1/2024 to present.
29. Preservation demand to NGM directing Exchange/M365 legal-hold on Schaefer and Gray mailboxes (already triggered by litigation hold, but reissue).
30. Deposition-subpoena rider for each actor requiring them to bring: (a) their Soluno login device, (b) their mobile phone if NGM communications occurred there, and (c) their personal CPA-workpaper files for NGM (Schaefer only).

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## E. Attorney-Work-Product Notes

- **Best single cite proving Schaefer had custody of the three-way reconciliation inputs:** LITMAN196703 (1/7/2024) transmitting the five-report package with her own one-line descriptions.
- **Best single cite proving Gray is the hands-on sweep signer:** Trust Bank Journal entries **3844418** (11/20/2024 $493,898 to Nath & Associates) and **4001216** (2/10/2026 $224,113 to Nath & Associates) — both User = VG.
- **Best single cite tying Schaefer to Freedom Bank exclusion:** Anomalous Cat. §3 entry 356 (Freedom Bank closure coincides with Kren-report transmittal she authored).
- **Best single cite tying Schaefer to the "commingling" admission:** Anomalous Cat. §3.6 ("not supposed to have trust money for your own money") — 6/25/2025.

## F. Prioritized Top 5 Questions per Actor

### Schaefer Top 5
1. Did you know before 7/28/2025 that NGM maintained an undisclosed third trust account at Freedom Bank? (Block iii, Q19)
2. Did you reconcile the 11/20/2024 $493,898 Nath & Associates sweep from docket 36372, and did you flag it? (Block v, Q24 & Q29)
3. Why does the Trust Listing in your 1/7/2024 package show a different BoA total than the same-month Trust Bank Register? (Block iv, Q20–Q22)
4. What did you mean by "not supposed to have trust money for your own money," and who else did you tell? (Block vii, Q38)
5. Was the $290,000 MetLife offset ever actually paid, and if not, why did you apply it to Litman's arbitration allocation? (Block vi, Q32–Q33)

### Gray Top 5
1. Were you instructed to characterize the 2/6/2026 KFU wire as a "retainer" rather than as payment against outstanding invoices? (Block iv, Q20)
2. Who gave you the written or oral instruction to sweep $493,898 on 11/20/2024 and $224,113 on 2/10/2026 out of docket 36372? (Block iii, Q14 & Block iv, Q18)
3. Did anyone at NGM instruct you that dockets 36372 and 135900 were to be used as holding accounts for pre-invoice funds? (Block ix, Q42)
4. For each of the 133 VG-signed Q1 2026 transfers, did you have an invoice in hand, or did you execute against a batch instruction from Goldberg? (Block ii, Q9–Q10)
5. Were any responsible-attorney codes changed in Soluno between 1/31/2026 and 2/1/2026 on KFU or Kuwait University matters, and at whose direction? (Block vi, Q25–Q27)

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*Memo ends.*