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During the period in which Ariella Rosengard was performing
bookkeeping functions for Ms. Mirowski, Ms. Mirowski’s invest-
ments consisted primarily of securities issued by the United
States Treasury Department (U.S. Treasury securities). Ms.
Mirowski received directly the checks for any interest payments
on those securities and deposited those checks into one of her
various bank accounts. During that period, Ms. Mirowski pre-
ferred to have her investments and financial accounts tracked on
a large spreadsheet, which permitted her to monitor them.
By 1998, after royalties from the ICD patents had increased
dramatically, it became quite burdensome to use a large spread-
sheet in order to track and manage Ms. Mirowski’s investments and
financial accounts. That was in large part because, even though
Ms. Mirowski’s investments were primarily of the same type (i.e.,
U.S. Treasury securities), she had over 84 accounts in ten
different institutions.
In February 1998, at the suggestion of Ginat Mirowski, Ms.
Mirowski met with William Lewin (Mr. Lewin) of Goldman, Sachs,
& Co. (Goldman Sachs) regarding the establishment of an invest-
ment account with that firm. Ginat Mirowski made that suggestion
to Ms. Mirowski because in 1992 she and her husband had met with
Mr. Lewin and thereafter established an account at Goldman Sachs
that Mr. Lewin managed. Over time, Ginat Mirowski concluded that
the Goldman Sachs account that she and her husband maintained was
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