https://int.nyt.com/data/documenttools/letitia-james-trump-filing-january-18-2022/e4038cab1ecf788a/full.pdf

As alleged in detail below, OAG has obtained documents and testimony from
numerous witnesses that were involved in creating and disseminating the misleading statements
and omissions at issue in this investigation. However, witnesses closest to the top of the Trump
Organization have asserted their Fifth Amendment rights against self-incrimination. Certain
others have professed faulty memories or asserted that they were following instruction from
more senior employees. And as the Court is well aware, other testimony and documents have
been withheld under assertions of privilege, including assertions on behalf of Mr. Trump
himself: for instance, Sheri Dillon, a respondent in OAG’s motion that began this proceeding,
was Mr. Trump’s personal tax counsel.

The knowledge and actions of Mr. Trump’s agents and attorneys can be imputed
to Mr. Trump himself. See, e.g., Kirschner v. KPMG LLP, 15 N.Y.3d 446, 465-66 (2010). But
Mr. Trump’s actual knowledge of—and intention to make—the numerous misstatements and
omissions made by him or on his behalf are essential components to resolving OAG’s
investigation in an appropriate and just manner. Likewise, Donald Trump, Jr. and Ivanka Trump
worked as agents of Mr. Trump, acted on their own behalves, and supervised others in
connection with the transactions at issue here; their testimony is necessary for appropriate
resolution of OAG’s investigation as well.