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Tillett cites C&L7s management letters which, he states, "were provided to the Board of ~ r u s t e e s " ~ ~ C&L believed the Board of Trustees (the "Board") should be aware of and the issues facing AHERF."~~ and "indicat[ed] items that Although it appears that C&L7s communications required by SAS 61, Communications with Audit Committees, contained the customary "boilerplate" language, neither C&L7s management letters nor its required communications under SAS 6 1 contain disclosures of the million reserve transfers from the Graduate hospitals to the DVOG hospitals. Tillett's rationale as to why the " Million Reserve transfer..

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It is evident fi-om the documents and testimony in the case that the primary users of the financial statements, including the Board of Trustees and AHERF's lenders, were acutely interested in the "bottom line" and trend of earnings. Tillett's assertion mischaracterizes my treatment of the effects of C&L's SUD entries.

Therefore, assessing materiality primarily at the net asset (fund balance) level would cause significant adjustments to results of operations to be considered immaterial because AHEW and its affiliates and obligated groups were large organizations with significant amounts of net assets. Tillett acknowledges "that materiality judgments involve both quantitative and qualitative consideration^,"'^ he fails to describe the qualitative considerations that entered into his assessment of materiality. As indicated in my expert report, I used the rollover method to include the effects of the SUD entries in the quantification of misstatements, principally because the magnitude of the errors I detected necessitated restatement of AHERF's financial statement^.^^ I did not suggest that C&L9s use of the Iron Curtain method was, in itself, inappropriate. Tillett's opinion that it was inappropriate for me to use "the rollover method to evaluate the effect of the SUD" is, quite simply, erroneous.


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