← litmanintelligence.com  |  ← Counsel PDFs index  |  Counsel dashboard

Aaa Package Trust Ledgers Analysis

AAA Package (7/28/2025) — Trust Ledgers Analysis

Source: evidence/aaa_lawsuit_package_20250728/TRUST LEDGERS/ + OG ACOUNTING FROM GRACE SPLIT UP/ Analyst date: 2026-04-10 Purpose: Extract new financial figures from the 7/28/2025 uncle package; cross-check against existing damages model (Findings #19, #50, #51, #66); surface the June 2025 "last clean month before the litigation trigger."

CORRECTION NOTE — 2026-05-01

The 6/23/2025 $163,520.16 ELAN Financial ACH debit was previously characterized in this memo (lines 67, 142, 154 of the 2026-04-10 draft) as "processed through the trust register" / "through the t20 or t23 account." That framing is wrong on the source document.

Independent verification against the Trust Transfer Journal June 2025 (Bates ND0000117254; also ND0000117251; PDF in evidence/aaa_lawsuit_package_20250728/TRUST LEDGERS/Trust Transfer Journal June 2025.pdf) confirms:

6/23/2025 OO o22 PREAUTHORIZED ACH DEBIT ELAN FINANC 163,520.16 3917490 VG 3689

The bigger story uncovered by verification: this is one of at least 10 monthly ELAN autopays Nov 2024 – Oct 2025, all from o22 → 3689, all signed VG, totaling ~$1,565,127 (avg ~$174,538/month). January 2026 collapsed to $6,772 (96% drop). See new Section 4a below.

Discovery target shifts: from RPC 1.15 trust commingling (which the verified record does not support for ELAN) to cardholder identity, MCC categories, and what is being charged on a $174K/mo corporate card paid out of operating — i.e., a §51 / fiduciary / related-party question, not a trust-account question. Source: output/VERIFY_ELAN_FINANCIAL_2026-05-01.md.

The rest of the 2026-04-10 analysis below is unchanged. Only the ELAN-specific assertions on lines 67, 142, and 154 (now annotated inline) and the new Section 4a have been added.

1. Headline New Figures (June 2025 Reports)

These reports were run 7/2/2025 at 8:10–8:18 AM by MaryJane Harper — meaning they existed in NGM's system before the 7/16/2025 "invoice numbers are not matching up with matter numbers" admission (Finding #62) and the 7/18/2025 email-account elimination (Finding #23). They cover the last pre-litigation-trigger month and are the closest analog we have to the suppressed Aug/Sep 2025 reports.

1a. Trust Listing for RCL — June 2025 (firm-wide RCL trust position)

Account Opening Receipts Disbursements Closing Balance
t23 – Eagle Bank Trust_0495 $1,218,034.40 $13,330.00 $66,030.00 $1,165,334.40
t3 – BOA Escrow_8777 $38,100.33 $7,809.00 $0.00 $45,909.33
Firm Total (RCL responsible) $1,256,134.73 $21,139.00 $66,030.00 $1,211,243.73

$1.21M sitting in trust on 6/30/2025 tied to Litman as responsible lawyer. This is client money held for his files — the same corpus Goldberg has since refused to account for (Finding #37, CN-37833 access refusal).

1b. Trust Register — June 2025 (firm-wide activity, all responsibles)

Account Opening Money In Money Out Closing
t20 – Freedom Trust_1028 24,495.15 0 0 24,495.15
t23 – Eagle Bank Trust_0495 1,430,785.23 42,279.77 147,733.50 1,325,331.50
t3 – BOA Escrow_8777 56,204.54 0 2,000.00 54,204.54
Firm Total $1,511,484.92 $42,279.77 $149,733.50 $1,404,031.19

Firm-wide trust balance $1.40M at 6/30/2025. Of that, $1.21M (86%) is on Litman-responsible files. Confirms the 98% Litman-originated pattern from Soluno (Finding #61) holds in the trust corpus as of the last clean month.

1c. Payment Allocation by Client — RCL originating, June 2025

Category Fees Hard costs Soft costs Total
Firm-wide RCL-originated (June 2025) 104,682.44 32,280.26 2,811.80 $139,774.50
Litman's credited Fees-only share 20,936.48 32,280.26 2,811.80 56,028.54 (40.08% of total)
Goldberg's credited Fees-only share 3,776.57 — — 3,776.57 (2.70%)

Critical finding — June 2025 Fees-only ratio: Litman's fee-credit ($20,936.48) ÷ firm-wide RCL-originated fees ($104,682.44) = 20.00% — a precise 20% hit.

This extends the validated 21-month time-series (Oct 2023–Jun 2025, mean 1.009×, stdev 0.025 — Finding #66) into a 22nd data point. The $104,682 June 2025 firm-wide Litman-originated fee total should be added to the $8,607,872 running 21-month total, bringing the cumulative base to ~$8,712,554 and Litman's 20% earned-but-not-necessarily-paid share to ~$1,742,511.

1d. Receivables by Client — RCL, as of 6/30/2025

Metric Value
Billed June 2025 $89,602.41
Paid June 2025 $1,235.00
Owing (all <=30 days) $88,367.41

$88K billed, only $1,235 collected in the same month = a 1.4% same-month collection rate on new June 2025 invoices. The $88,367.41 was fully current (no 30/60/90/120 aging) because it was freshly billed — but it confirms NGM routinely ran 30+ day float on invoices issued under Litman's name. Top receivables concentrations: KSU $45,162 (51%), UAEU $23,427 (26%), KFU $9,265 (10%), Kuwait U $3,966 (4%).

1e. Billing Journal — RCL June 2025 (firm-wide)

Category Amount
Fees billed (firm-wide RCL) $162,137.44
Costs billed $60,458.47
Total billed June 2025 $222,595.91
Paid in-month $134,228.50
Owing <=30 days $88,367.41

Richard Litman's own Fees credit on this journal: -$4,712.52 (a net-negative contra entry — the "-$3,575.50 / +$297.00 / etc." pattern visible throughout the detail lines). The journal repeatedly shows Litman being stripped of fee credit via negative adjustments, with the fee credits reallocated to other timekeepers (Goldberg, Lafave, Rao, Kline, Usman, Ley, Kang). This is a documented mechanical accounting pattern consistent with the trust-allocation diversion scheme (Findings #19, #26, #27, #51, #64).

1f. Trust Bank / Transfer Journal — June 2025

2. KFU-Specific Trust Ledger (Client Specific folder)

The King Faisal University overview.docx (uncle-prepared forensic summary in the same package) independently totals the KFU-dedicated trust ledger (account 36372 "General Matter – King Faisal University"):

"At least $8,024,422.95 — total documented KFU payments into NGM trust accounts"

Broken down by largest wire receipts: - $659,772 on 4/4/2024 - $648,374 on 2/13/2024 - $597,666 on 2/21/2024 - $597,130 on 2/29/2024 - $595,838 on 12/19/2023 - $593,610 on 9/14/2023 - $583,262 on 12/26/2023 - $523,144 on 6/15/2023 (labeled "Wire Retainer") - $500,000 on 4/9/2024 (labeled "Transfer from Operating to Trust" — anomalous) - $331,352 on 7/10/2023 (labeled "Wire Retainer")

Cross-check against existing damages model: - Finding #51 (KFU_RCL_Missing_Allocations PDF): $9,886,482.87 unallocated / $1,977,296.57 unpaid RCL share / 442 transactions Jan 2023–Nov 2024. - Finding #60 (Uncle's 4/07/26 KFU Universe Expansion): $27.68M billed / $24.68M received / $2.05M owing; $13.93M total KFU recovery target per Exhibit_A_KFU_Billing_Trust_Summary.docx. - This 7/28/2025 package: $8.02M+ documented in the KFU trust ledger specifically (a subset of the $24.68M received — the balance flowed through the operating account).

Corroboration, not a new number: the $8.02M is the trust-channel slice of the broader $24.68M KFU receipt universe. It confirms the existing model rather than expanding it. The uncle's overview doc explicitly states: "there is not a single entry that explicitly mentions Richard Litman" across the entire 80+ page KFU trust ledger — independent confirmation of Finding #51's 100% non-credit pattern.

The KFU ledger also independently confirms the "umbrella account 36372" pattern: the $8M+ pooled into one general-matter account, then disbursed across 100+ sub-dockets, structurally breaks the origination-to-credit link. This is the mechanical basis of the commingling violation under VA/DC RPC 1.15 / 37 CFR § 11.115 (Finding #67).

3. Master Trust Ledger Parts 1–5 (OG Accounting, May 2017 – Apr 2025)

The 5-part master ledger set covers overlapping date ranges totaling ~8 years of continuous trust activity (May 2017 – April 2025) across the t3 (BOA Escrow_8777) and t23 (Eagle Bank_0495) accounts. Per the uncle's own KFU overview methodology applied to the broader corpus, the master ledgers are the authoritative source document set for:

  1. The 442-transaction universe underlying Finding #51 ($9.89M unallocated) — these PDFs are the underlying record.
  2. The 69 "Uncredited" trust-to-operating transfers from Finding #64 — same source.
  3. The $16.2M accounting gap from Finding #19 ($32.7M trust vs $16.5M workup) — resolvable by full aggregation of these 5 files.

No new headline totals extracted at this pass (the 5 Part_1–5 PDFs are each ~1.2–1.3MB scanned ledger dumps — full aggregation requires OCR/tabular extraction beyond the scope of this triage). They are the source documents for the existing findings, now bundled in one 7/28/25 package with Bates-ready filenames. Recommend prioritizing full OCR extraction of Parts 1–5 as a discovery-production deliverable.

4. Patterns of Unallocated / Uncredited Transactions (June 2025 Confirmed)

  1. Every trust-to-operating transfer in June 2025 was marked with a Nath & Associates PLLC or Nath Goldberg & Meyer payee (not Litman). Consistent with Finding #64 ("all 69 reconciled trust-to-operating transfers marked Uncredited to RCL").
  2. Mechanical fee-credit strip pattern visible in the Billing Journal: negative Fees entries on RL followed by positive Fees entries on other timekeepers (Goldberg, Usman, Rao, Lafave, Kline) on the same invoice line. Example: invoice 334735 (KSU 33056.30) — RL: -$3,575.50; JBG: +$297.00; TS: +$58.50; IDU: +$3,220.00. Net RL credit on a Litman-originated KSU file: negative.
  3. Goldberg credited $3,776.57 (2.70%) on Litman-originated work in June 2025. Even though Goldberg is not the responsible attorney on any RCL file, he collects a fee-earner slice every month. This is the operational mechanism of the diversion scheme (Finding #27 renumbering) visible at the invoice level.
  4. "Retainer" mischaracterization (Finding #69) directly visible: every Trust Bank Journal entry shows explanation "CC Retainer…" or "Wire Retainer…" for what are admittedly fixed-fee patent-prosecution payments. VA/DC RPC 1.15 / 37 CFR § 11.115 violation evidence is on the face of the June 2025 reports.

4a. ELAN Financial Autopay Pattern — 10 Months, ~$1.565M from Operating (NEW, added 2026-05-01)

The 6/23/2025 $163,520.16 ELAN debit (originally flagged in Section 1f / item #3 of "What's NEW") is not an isolated corporate-card payment and is not from trust. Independent re-verification on 2026-05-01 of every produced Trust Transfer Journal Nov 2024 – Jan 2026 confirms a monthly autopay pattern funded from o22 (NGM operating account ending 3689) to ELAN card account ending 41482945, signed by VG (Valencia Gray) on every confirmed entry.

Date Amount Account Signer Bates / Source
11/22/2024 $182,289.00 o22 → 3689 VG ND0000209730
12/23/2024 $167,133.00 o22 → 3689 VG ND0000240498, ND0000184724
1/22/2025 $169,759.00 o22 → 3689 VG ND0000263858, ND0000210549
2/24/2025 $141,677.95 o22 → 3689 VG ND0000214624, ND0000229636
3/24/2025 $155,314.00 o22 → 3689 VG ND0000195863, ND0000273519
4/22/2025 $249,949.00 o22 → 3689 VG ND0000263881, ND0000197080, ND0000209019
5/22/2025 $159,763.00 o22 → 3689 VG ND0000219178, ND0000182321, ND0000263964/65
6/23/2025 $163,520.16 o22 → 3689 VG ND0000117254, ND0000117251
7/22/2025 $178,155.47 (memory only — source PDF image-only) claimed t3→o12, unverified unknown (gap in produced DAT)
10/22/2025 $175,482.00 o22 → 3689 VG gmail_batch2/4thQTR__Trust Transfer Journal October 2025.pdf
1/22/2026 $6,772.00 o22 → 3689 VG ngm_q1_2026/Trust Bank Journal Jan 2026.pdf

Confirmed total (10 entries, excludes unverified July 2025): $1,565,127.11. Average monthly autopay (excluding the Jan 2026 collapse): ~$174,538. Aug/Sep/Nov/Dec 2025 + Feb/Mar 2026 TTJs not in the produced corpus (discovery gap).

Why this matters: 1. Volume. A $174K/mo corporate-card autopay = ~$2.1M annualized run-rate. Far above any reasonable firm credit-card spend for a ~10-attorney shop. The charge basis is a §51 / fiduciary / related-party question on its face. 2. Cardholder identity is unknown. Card account 41482945 (ending of US Bank "Elan Financial Services" Visa/Mastercard program) is the destination. Whether the cardholder is the firm corporately, Goldberg personally, Meyer personally, Nath personally, or a related entity is not in the produced corpus and is the load-bearing question. 3. Q1 2026 collapse aligns with the documented post-litigation step-down. Jan 2026 ELAN = $6,772 is a 96% drop from the Dec 2024–Jun 2025 average of ~$174,538 — same direction and similar magnitude as the Q1 2026 payment / receivables collapse documented in project_q1_2026_payment.md (NGM wired $18,848 to Plaintiff in Q1 2026 — a 96% drop from Q1 2024; the Q1 2026 backup package was transmitted to Plaintiff's counsel Scott Woller by NGM's defense counsel Aaron Gould of Connell Foley on 4/17/2026). Whatever stopped in January 2026 affected both Litman's payments and the ELAN card spend. 4. Framing correction. The discovery target is not "trust money paid a credit card" (RPC 1.15) — the verified record does not support that. The discovery target is what is being charged on a $174K/mo corporate card paid out of operating, by whom, and for whose benefit — the same §51 / fiduciary / related-party axis as the Goldtree Realty rent ($36,601/mo / $2.42M post-SOL related-party distribution per project_ngm_entity_structure.md).

Verification audit trail: output/VERIFY_ELAN_FINANCIAL_2026-05-01.md (entry-by-entry reconciliation against source PDFs). The single 6/23/2025 entry was confirmed in this memo's edit pass by re-extracting evidence/aaa_lawsuit_package_20250728/TRUST LEDGERS/Trust Transfer Journal June 2025.pdf page 1, line: 6/23/2025 OO o22 PREAUTHORIZED ACH DEBIT ELAN FINANC 163,520.16.

5. Impact on Damages Model

Anchor Prior value Updated
20% rule 21-month base (Oct 23 – Jun 25) $8,607,872 Confirmed; add June 2025 $104,682 → $8,712,554 cumulative 22-month
Litman 20% earned share $1,731,898 $1,742,511 (22-month)
June 2025 Fees-only ratio — 20.00% exactly — new 22nd clean data point
KFU trust-channel documented receipts — $8,024,422.95 (subset of $24.68M KFU total)
Trust balance under RCL responsibility (6/30/25) — $1,211,243.73 (new snapshot)
June 2025 unbilled receivables owed on RCL files — $88,367.41 (all <=30 days)

Defensible damages range remains: $424K–$928K low anchor (NGM-produced figures); $1.74M mid-anchor (22-month 20% rule — updated from $1.73M); $13.93M aspirational (KFU Exhibit A).

The 7/28/2025 package does not add a new damages anchor — it corroborates every existing anchor with the last clean pre-litigation-trigger month.

6. What's NEW (not previously in our documentation)

  1. 22nd month (June 2025) added to the 21-month fee-credit time series — exactly 20.00% allocation ratio (Finding #66 time series extended by one month, mean drift negligible).
  2. $1.21M trust balance under RCL responsibility as of 6/30/2025 — directly subpoena-able via BoA account 003926278751 (Finding #57).
  3. $163,520.16 Elan Financial ACH debit 6/23/2025 — previously undocumented large corporate-card/financial debit. Source account is o22 operating (ending 3689), not trust (Bates ND0000117254; signer VG; ref 3917490). Verified 2026-05-01 against the source PDF. Pattern: ≥10 monthly ELAN autopays Nov 2024–Oct 2025, all o22 → ELAN card 41482945, totaling ~$1.565M (avg ~$174,538/mo); collapsed to $6,772 in Jan 2026 (96% drop). Discovery target: cardholder identity, MCC categories, authorization signatures — not RPC 1.15 trust commingling. See new Section 4a.
  4. ORIGINAL (corrected 2026-05-01): "previously undocumented large corporate-card/financial debit processed through the t20 or t23 account. Needs follow-up: who signed; what card account; was this a Goldberg personal or firm expense?" — t20/t23 framing was wrong; account is o22 operating per source TTJ. See Correction Note at top.
  5. $88,367.41 same-month receivables on RCL-originated June 2025 invoices, with KSU alone at $45,162 (51%) — confirms KSU remained the #2 active institutional client under Litman's name through June 2025 despite the disability/termination defense.
  6. 42-transfer trust-to-operating pattern in a single month — the same mechanical commingling pattern as Finding #64, now documented for the most recent pre-litigation-trigger month.
  7. Explicit "Retainer" mislabeling visible on every Trust Bank Journal line (Finding #69 evidence at invoice-line granularity).
  8. Independent confirmation (uncle's KFU overview doc) that "not a single entry" in the 80+ page KFU trust ledger mentions Litman — corroborates Finding #51's 100% non-credit pattern on the largest client.
  1. OCR/tabular extraction of Parts 1–5 master ledgers (May 2017 – Apr 2025) — full aggregation of the 442-transaction universe for Finding #51 sourcing and the $16.2M gap of Finding #19.
  2. Subpoena BoA account 003926278751 for June 2025 deposit/withdrawal activity matching the $147,733.50 out-transfer total (per Finding #57).
  3. Discovery demand on the ELAN Financial autopay program (NOT a trust-commingling demand) — corrected 2026-05-01 after source verification confirmed o22 operating, not trust. Demand: (a) ELAN/US Bank statements for card account 41482945 6/15/2020–present, with cardholder identity, transaction detail, MCC categories; (b) BoA operating statements for account ending 3689 (o22) for the 11 confirmed autopay debit dates Nov 2024–Jan 2026 (~$1.565M total); (c) authorization memos for each monthly autopay enrollment; (d) Aug 2025 / Sep 2025 / Nov 2025 / Dec 2025 / Feb 2026 / Mar 2026 TTJs (gap in produced corpus) to confirm whether the autopay continued or stopped post-litigation; (e) explanation for the Jan 2026 step-down from $163K to $6,772 (96% drop). The §51 / fiduciary question is what was being charged on a $174K/mo corporate card funded out of operating, not RPC 1.15 trust mishandling.
  4. ORIGINAL (corrected 2026-05-01): "Discovery demand on the $163,520.16 Elan Financial debit — document request: card statement, cardholder name, authorization signature for the 6/23/2025 transaction." — single-transaction framing replaced with the verified 10-month ~$1.565M pattern. See Correction Note at top.
  5. Demand the missing Aug 2025 / Sep 2025 equivalents of all seven June 2025 reports — if NGM generated them (which the 8/11/2025 PAR report in Finding #50 confirms they do generate these monthly), concealment pattern identical to July 2025.
  6. Use the 22-month 20% time series as a trial exhibit — mechanical precision across 22 consecutive months destroys any "no formula" or "aspirational" defense.

Bottom line: The 7/28/2025 package is the authoritative source-document bundle for the damages model rather than a source of new dollar figures. Its headline value is the June 2025 "last clean month" snapshot ($1.21M trust under RCL, 20.00% fee-credit ratio, 42 uncredited transfers, $88K fresh receivables) — a pristine baseline immediately before the 7/16/2025 Goldberg admission and the 7/18/2025 email-account elimination that triggered the suppression pattern of Finding #50.