Case: Litman v. Goldberg, Index No. 524343/2025 Court: Supreme Court of the State of New York, Kings County Judge: Hon. Brian L. Gotlieb, J.S.C. Surviving Claim: Count V -- NY Civil Rights Law Sections 50-51 (Misappropriation of Name) Prepared: April 1, 2026 Classification: Attorney Work Product / Privileged
This catalog documents a pattern of financial manipulation by Joshua B. Goldberg that systematically diverted, concealed, and underreported revenue generated under Richard Litman's professional name. The pattern is not one of innocent bookkeeping errors. It is a deliberate architecture of financial opacity built across five interconnected systems:
The financial result: a $16.2 million gap between what entered client trust accounts ($32.7 million) and what Goldberg reported as receipts ($16.5 million). Litman's 20% share was calculated on the smaller number. The difference between what was owed and what was paid is conservatively $1.9 million and may exceed $3.2 million depending on the correct revenue base.
NGM's billing system assigns each client an "Attorney Number" indicating the originating attorney. Richard Litman's code is Attorney Number 418. All clients Litman originated should carry this number, ensuring that collected fees are included in the 20% allocation calculation owed to him under the Combination Agreement and arbitration award.
The renumbering scheme assigned Litman-originated clients alternate numbers with distinctive prefixes -- numbers beginning with "1," "J," or "5" -- that are not standard Attorney #418 designations. By reassigning clients to these alternate codes, the revenue they generated could be excluded from the Soluno reports that calculated Litman's percentage.
| Date | Source | Description |
|---|---|---|
| June 16, 2025 | Email screenshot (iCloud Photos) | Email documenting clients being assigned alternate numbers that bypass the standard allocation system |
| April 17, 2025 | Email (ND263868) | Litman requests "a list of all clients assigned to my Attorney number 418" and notes that Middle Eastern clients "should reflect my number" -- indicating awareness that some do not |
| May 26, 2025 | Email (ND263883) | Litman requests confirmation that his "originated client list is correctly in Soluno (Attorney 418)" and asks for reports covering "all Attorney 418 clients from July 2023 to current" -- indicating doubt about completeness |
| June 2025 | Litman email to Goldberg/Schaefer | Lists "many clients not included including MSRDC, some universities and more" as missing from his allocation |
| Client | Standard Designation | Evidence of Irregularity |
|---|---|---|
| MSRDC | Attorney 418 | Monthly $2,500 payments from April 2023 through April 2025 paid but NOT transferred from trust to operating; no $500/month allocation to Litman despite client being "identified with Attorney 418" |
| KFU (King Faisal University) | Attorney 418 / Docket 36372 | Goldberg's workup showed $0 in revenue despite $12.3 million in verified trust payments. Revenue omitted entirely from the Soluno reports used to calculate Litman's 20% |
| KSU (King Saud University) | Attorney 418 / Docket 35610 | Same: $0 in workup despite $3.72 million in trust ledger activity across 388 entries |
| KISR | Attorney 418 | Identified by Litman as among "clients left off transfers" in June 6, 2025 request |
| Kuwait University | Attorney 418 | Same -- identified as excluded from transfer reports |
| Sabah Al-Ahmad Center | Attorney 418 | Same -- identified as excluded |
| UAEU | Attorney 418 | Same -- identified as excluded |
| Jouf University | Attorney 418 | Litman noted April 2025 that Jouf University payments were missing from reports |
| Authentic Amish | Attorney 418 | Invoice #318064 ($1,040) paid July 13, 2023 but not allocated to Litman's 20% |
| Kan Cui | Attorney 418 | Invoice #332617 ($1,954) paid December 27, 2024 but not allocated |
| System | Format | Effect on Litman's 20% |
|---|---|---|
| Standard (correct) | 5-digit docket prefix (e.g., 33120.91U), Attorney 418 | Revenue captured in Soluno, included in 20% calculation |
| Alternate prefixes ("1", "J", "5") | Non-standard client numbers | Revenue bypasses Attorney 418 reports, excluded from 20% calculation |
| Umbrella dockets (36372, 35610) | General trust holding accounts | Bulk client payments land here; allocation to sub-matters and operating happens at Goldberg's discretion |
Each renumbered client is evidence of intent. Changing an originating attorney code is not a clerical error -- it requires administrative access to the billing system and a deliberate decision to reassign the client. Litman's repeated requests for a complete client list under Attorney 418 ("please confirm my originated client list is correctly in Soluno") demonstrate that he suspected the list was incomplete. Goldberg never provided the confirmation.
NGM maintained multiple accounts through which client funds flowed:
| Account | Type | Ledger Code | Key Facts |
|---|---|---|---|
| Bank of America Escrow (ending 8777) | Trust | t3 | $27.8M in receipts; primary trust account through 2024 |
| EagleBank Trust (ending 0495) | Trust | t23 | $4.9M in receipts; became primary after BOA migration |
| Bank of America Wire (ending 8751) | Wire Receipt | N/A | Received international wires; NOT a designated trust account |
| Bank of America Operating (ending 2417) | Operating | N/A | Firm's operating account |
| Freedom Bank | Trust (historical) | Unknown | Litman requested closure or name removal (Feb. 2024) |
Trust ledger analysis reveals client payments deposited into umbrella docket accounts (36372 for KFU, 35610 for KSU) rather than into specific patent matter dockets. While bulk wire processing may justify an initial deposit into a general account, the subsequent allocation to sub-matters was entirely at Goldberg's discretion, with no transparency to Litman.
Specific examples from June 2025 Litman emails:
| KFU Docket | Problem Identified | Amount |
|---|---|---|
| 33110.43U | Trust payment transferred to operating, but no 20% RCL credit applied | Not specified |
| 33110.63U | Trust payment received but NOT transferred to operating, no credit issued | Not specified |
| 33110.92U | Trust payment made WITHOUT any invoice or transfer record | Not specified |
| 33120.22S | Trust transferred but no RCL credit | Not specified |
| 33120.26S | Trust transferred but no RCL credit | Not specified |
| Category | Amount | Transactions | Effect |
|---|---|---|---|
| Trust-to-trust bank transfers | $1,698,673.32 | 299 | Money moved between Eagle Bank and BOA trust accounts; creates matching debit/credit that inflates gross trust figures |
| Sub-matter allocations | $4,451,713.62 | 1,216 | Internal moves from umbrella dockets (36372, 35610) to individual patent dockets; no money leaves trust but creates complex paper trail |
| BOA-to-EagleBank migration | $1,478,867.09 | 561 | Bulk transfer of trust funds between banks; $86,871.87 discrepancy between outgoing and incoming amounts |
| Date | Amount | Description | Problem |
|---|---|---|---|
| March 18, 2024 | $595,214 | KFU wire from Wire_8751 directly to Operating_2417 | Client trust funds bypassed trust accounts entirely |
| March 18, 2024 | $1,000 | Recording discrepancy | Wire recorded as $594,214 -- exactly $1,000 less than actual |
| April 9-10, 2024 | $587,358.87 | KFU trust funds routed through operating to transfer between banks | Temporary commingling; should have been trust-to-trust |
| July 16, 2021 | $90,000 | "Op to Trust RCL" correction | $90,000 in client funds had been held in operating; returned to trust Case 36056 |
| September 3, 2021 | $20,000 | "Op to Trust RCL" correction | Same pattern; $20,000 returned to trust |
Total clearly problematic transfers: $1,380,444.74
As of the most recent trust ledger:
| Account | Balance |
|---|---|
| Eagle Bank Trust (0495) | $1,174,930.40 |
| Bank of America Escrow (8777) | $45,909.33 |
| Total undisbursed | $1,220,839.73 |
This money was received from clients, generated by work performed under Litman's name, but has never been disbursed to operating or allocated to anyone's compensation. It sits in trust -- money earned under Litman's name that he has never been paid on.
NGM's own CPA, Deborah Schaefer, told Litman that trust accounts were being closed because the firm was "not supposed to have trust money for your own money." This is an admission of awareness that trust accounts contained firm funds rather than solely client funds -- the definition of commingling under Virginia RPC 1.15 and New York Rule 1.15.
In a June 2025 text message exchange, Goldberg acknowledged that the Soluno reports for Attorney #418 "drew its data from account ledgers that didn't include payments actually made."
This is a direct, informal admission by the person who controlled the accounting system that the reports Litman relied upon to verify his 20% share were structurally deficient. The reports did not capture all revenue. The undercount was not disclosed to Litman until he discovered it himself and pressed the issue.
| Metric | Soluno/Workup Showed | Actual (Trust Ledger) | Difference |
|---|---|---|---|
| Total client receipts | $16,506,604.92 | $32,708,669.08 | $16,202,064.16 |
| KFU revenue | $0.00 | $10,737,709.88 (Docket 36372 alone) | $10,737,709.88 |
| KSU revenue | $0.00 | $3,720,000+ (Docket 35610) | $3,720,000+ |
| 20% due to Litman | $2,402,451.86 | $4,299,347.35 (quarterly summary) | $1,896,895.49 |
| Payments to Litman | $2,403,125.66 | $2,403,125.66 | $0.00 |
| Net balance owed | ($673.80) -- "fully paid" | $1,896,221.69 | $1,896,895.49 |
| Component | Amount | % of Gap |
|---|---|---|
| Time period mismatch (Trust Ledger = lifetime; Workup = Soluno period only) | $8,461,393 | 52.2% |
| Trust-to-sub-matter internal allocations | $4,451,714 | 27.5% |
| Trust-to-trust inter-bank transfers | $1,698,673 | 10.5% |
| Trust balance remaining (undisbursed) | $1,220,840 | 7.5% |
| Litman percentage account (compensation escrow) | $244,918 | 1.5% |
| Direct trust payments bypassing operating | $124,526+ | 0.8% |
| Total | $16,202,064 | 100% |
Goldberg's workup bottom line shows Litman's 20% was $2,402,451.86, and payments of $2,403,125.66 were made -- a difference of negative $673.80. This suspiciously clean reconciliation only works because:
The quarterly compensation summary -- calculated differently -- shows $4,299,347.35 due against $2,403,125.66 paid, a shortfall of approximately $1.9 million.
| Item | Amount | Date Identified | Description | Status |
|---|---|---|---|---|
| $35,120 missing KFU allocations | $35,120.00 | June 19, 2025 | Four KFU invoices paid but not allocated to Litman's 20%: #405667 ($9,440), #407698 ($11,040), plus others | Goldberg acknowledged: "I need to figure out why" |
| $156,010.60 chased payment | $156,010.60 | April 2024 | Series of text messages documenting repeated efforts by Litman to obtain this specific payment | Eventually paid (appears in April 11, 2024 payment record) |
| "$20K/month allocated, should be 7 figures" | ~$240K/yr vs. 7 figures | June 2025 | Litman noted his allocation was $20,000/month despite massive revenue under his name | Goldberg did not dispute the "7 figures" claim |
| $79,150 discrepancy | $79,150.00 | June 2025 | Difference between Verified Financial Summary ($2,481,602 due) and NGM Workup ($2,402,452 due) | Explained by missing allocations Litman identified |
| $132,637 missing January 2024 payment | $132,636.68 | Identified in analysis | Appears as "Paid" in quarterly summary but does NOT appear in NGM Litman Workup | Unexplained omission of a six-figure payment |
| $1,000 recording discrepancy | $1,000.00 | March 18, 2024 | $595,214 KFU wire recorded as $594,214 in Soluno | Correction entry filed March 19, 2024 |
| $86,872 inter-bank migration gap | $86,871.87 | Sept-Nov 2024 | Difference between outgoing BOA trust ($1,478,867) and incoming EagleBank trust ($1,391,995) during bank migration | Unexplained |
| MSRDC trapped trust funds | ~$60,000+ | April 2023 - April 2025 | Monthly $2,500 payments received but never transferred from trust to operating; no $500/month Litman allocation since March 2023 | Identified by Litman; no resolution |
| Authentic Amish missing allocation | $1,040.00 | July 13, 2023 | Invoice #318064 paid but not allocated to Litman's 20% | No resolution |
| Kan Cui missing allocation | $1,954.00 | December 27, 2024 | Invoice #332617 paid but not allocated to Litman's 20% | No resolution |
This single data point encapsulates the entire pattern:
| Metric | Value |
|---|---|
| Total JBG journal entries | 28,503 |
| Journal files containing JBG entries | 71 |
| Unique docket numbers with JBG activity | 1,955 |
| Period covered | February 2022 -- June 2025 |
| Peak month | June 2025: 18,482 entries |
| Type | Count | Significance |
|---|---|---|
| Trust Bank entries | 18,328 | Goldberg personally controlling client trust deposits, withdrawals, and transfers |
| Billing entries | 10,035 | Goldberg entering or approving time entries and fee charges on RL matters |
| Corrections/Adjustments | 885 | Goldberg modifying financial records on Litman-designated matters |
| Fee allocation entries | 62 | Direct control over how fees were credited |
| Trust transfers | 52 | Inter-matter fund movements at Goldberg's direction |
| Invoice entries | 26 | Goldberg generating invoices on RL matters |
The trust ledger CSV records 54 specific trust actions attributed to Goldberg by name:
| Authorization Type | Count | Examples |
|---|---|---|
| "JBG em approval" | 8 | Dockets 33020.00, 32720.11, 32387.02 |
| "JBG email" -- directed trust actions | 7 | Dockets 32809.12, 33007.56, 33007.57, 33007.63 |
| "JBGverbal" -- verbal authorization | 7 | KFU dockets 32087.08, 32087.14, 32087.50, 32805.15, 32905.62 |
| "Transfer to different client per JBG" | 2 | Docket 33050.00 to 32833.03 |
| "JBG close .01" -- closing sub-dockets | 2 | 33049.01 to 33049.00 |
| "EM Auth JBG -cor docket #" -- correcting docket numbers | 1 | 11060.46 to 11060.50 |
| "billed JBG" -- billing instructions | 3 | KSU general trust 35610 |
| "JBG. em" -- Kuwait University payments | 3 | 23588.72, 23588.86, 23588.93 |
Every entry shows RESP = "RL" (Richard Litman). Goldberg controlled the money. Litman's name was on the matters.
Four trust fund transfers on KFU docket 36372, all verbally authorized by Goldberg on August 18, 2021:
| Entry No. | From Docket | Amount | Authorization |
|---|---|---|---|
| 2488679 | 32087.50 | $298.00 | JBGverbal 8.18.2021 |
| 2488683 | 32087.14 | $3,000.00 | JBGverbal 8.18.2021 |
| 2488688 | 32087.08 | $1,100.00 | JBGverbal 8.18.2021 |
| 2488691 | 32087.19 | $810.00 | JGBverbal 08.18.2021* |
*Typographical transposition ("JGB" vs "JBG") -- same person, same date, sequential entries.
Total moved by Goldberg's verbal command: $5,208. The significance is not the dollar amount but the proof that Goldberg could pick up the phone, tell accounting staff to move money between Litman's patent dockets, and it was done immediately. This is operational control.
| Period | Monthly Average Entries | Notable |
|---|---|---|
| Feb 2022 | 88 | Earliest records |
| Aug-Dec 2023 | 235/month | Post-arbitration ramp-up |
| Jan-Jun 2024 | 401/month | Peak control period |
| Jul-Dec 2024 | 713/month | Heavy trust bank activity |
| Jan-Jun 2025 | 4,189/month | Massive activity; June alone = 18,482 entries |
The escalation from 88 entries/month to 4,189 entries/month coincides with the period when Litman was demanding financial accountability. More journal activity during a period of financial scrutiny raises the inference that records were being created, modified, or reorganized.
"The Pad" is an internal Excel spreadsheet created and maintained at Goldberg's direction, specifically organized around matters where Richard Litman is the originating attorney. It tracked:
On January 24, 2024, Karen Van Giezen (IT Specialist, NGM) sent a firm-wide email to the DC Office at Goldberg's direction:
"Josh has requested the following procedure: When you complete work on any matter where Richard Litman is the originating attorney, update the spreadsheet named 'The Pad' with the following information..."
The email specified the file location: Team -- Nath Law -- General/Nath Assoc/Pad/The Pad
"The Pad" predated the January 2024 directive. Earlier references show:
| Date | Source | Reference |
|---|---|---|
| January 3, 2022 | Litman to Martha Long | "Martha, please send me the pad through 12/31/21" |
| July 2023 | Goldberg to Litman | "I suspect work needs to make it onto the Pad" (re: KFU A/R) |
| January 24, 2024 | Van Giezen directive | Formalized the process; shifted from Martha Long to staff-wide entry |
The January 2024 directive was a formalization of a pre-existing system. Before that date, Martha Long accumulated "Pad information from incoming emails" or researched "what work was completed." The new procedure freed Martha from this role by requiring all staff to update the spreadsheet directly.
On the same day as the Van Giezen email (January 24, 2024), Litman forwarded it to Deborah Schaefer with pointed questions:
"This is when the work is sent to clients. Shouldn't the invoice numbers always be known at this point in the work flow process? If work is sent out without linkage to an invoice, how is the firm sure that all work is being done and all work invoiced?"
Litman identified the fundamental problem: work was being tracked on The Pad without corresponding invoice numbers, meaning revenue could be generated under his name without appearing in the billing system.
"The Pad" proves:
| Date | Event | Amount | Significance |
|---|---|---|---|
| June 15, 2020 | SOL cutoff | -- | All financial activity after this date is within the actionable period |
| May 27, 2020 | KSU trust-to-operating transfer | $125,800 | Earliest post-SOL transfer in the record |
| July 16, 2021 | $90,000 returned from operating to trust | $90,000 | Client funds had been held in operating account |
| August 18-19, 2021 | Goldberg verbally authorizes KFU trust fund transfers | $5,208 | "JBGverbal" notations prove personal control |
| September 3, 2021 | $20,000 returned from operating to trust | $20,000 | Second correction of commingled funds |
| January 3, 2022 | Litman requests "The Pad through 12/31/21" | -- | Pad system operational; Litman monitoring revenue |
| Q4 2022 | Trust balance reaches $1.26M | $1,264,518 | Massive client funds accumulating under Litman's name |
| January 12, 2023 | KSU trust alone = $520,044 | $520,044 | Single client trust balance; all under Attorney 418 |
| June 14, 2023 | Arbitration decision | -- | Establishes Litman's right to 20% of collected fees |
| July-September 2023 | Post-arbitration payments begin | $539,458 | First three payments to Litman after arbitration |
| August 15-17, 2023 | Schaefer meets with Litman re accounting controls | -- | CPA identifies concerns after meeting with Litman |
| January 24, 2024 | Van Giezen sends "The Pad" directive at Goldberg's request | -- | Goldberg formalizes tracking of Litman-originated matters |
| February 9, 2024 | Litman asks about Freedom Bank trust accounts | -- | Requests closure or name removal; asks why funds remain in trust |
| March 18, 2024 | $595,214 KFU wire bypasses trust entirely | $595,214 | Wire_8751 to Operating_2417 direct transfer |
| March 18, 2024 | $1,000 recording discrepancy discovered | $1,000 | $595,214 recorded as $594,214 in Soluno |
| April 9-10, 2024 | $587,359 in KFU funds routed through operating | $587,359 | Trust-to-operating-to-trust creates temporary commingling |
| April 2024 | Litman chases $156,010.60 payment | $156,011 | Multiple text messages over days to obtain single payment |
| August 14, 2024 | Litman states "7 figures owed"; Goldberg does not dispute | $1,000,000+ | Adoptive admission of seven-figure obligation |
| September 18, 2024 | Litman notes payments dropped to "5-10% of what they had been" | -- | Dramatic decline in monthly payments |
| Sept-Nov 2024 | BOA-to-EagleBank trust migration | $1,478,867 | $86,872 discrepancy between outgoing and incoming |
| January 14-21, 2025 | Attorney name switchover on patent Line 74 | -- | Litman replaced by Goldberg; proves ability to control name use |
| April 17, 2025 | Litman requests complete Attorney 418 client list | -- | Suspects client list is incomplete |
| May 26, 2025 | Litman requests Soluno reports for Attorney 418 | -- | Demands proof that client list is correctly entered |
| June 2025 | Goldberg admits Soluno "didn't include payments actually made" | -- | Admits accounting reports were structurally deficient |
| June 2025 | Trust account deposits under incorrect client numbers discovered | -- | Client renumbering scheme documented |
| June 2025 | "$20K/month allocated, should be 7 figures" | $240K vs. $1M+ | Quantifies the allocation gap |
| June 7, 2025 | Litman identifies specific KFU trust irregularities | $35,120+ | Missing credits on dockets 33110.43U, 33110.63U, 33110.92U |
| June 11, 2025 | Goldberg admits possible non-payment: "I need to figure out why" | -- | Acknowledges system failure but does not correct it |
| June 16, 2025 | Client renumbering email screenshot preserved | -- | Alternate numbers bypassing Attorney 418 allocation |
| June 19, 2025 | Schaefer generates trust account summary | $32,708,669 | Confirms total trust receipts; basis for $16.2M gap |
| June 25, 2025 | Schaefer statement: "not supposed to have trust money for your own money" | -- | CPA admits awareness of commingling |
| July 15, 2025 | Litman: "you control the accounting and money, and now the clients" | -- | Contemporaneous accusation of financial control |
| July 18, 2025 | Litman's email accounts eliminated | -- | One day after litigation threat; access to financial records cut |
The anomalies documented in this catalog are not the product of an overwhelmed accounting department making occasional errors. They form a coherent pattern:
The renumbering scheme is deliberate. Changing an originating attorney code requires an affirmative decision. Litman's clients were reassigned to alternate numbers that bypassed his 20% allocation. When Litman asked for a complete list, he was not given one.
The $0 KFU/KSU workup entries are deliberate. The firm's largest clients -- generating $13.26 million in trust payments -- showed zero revenue in the document Goldberg prepared to calculate Litman's compensation. This is not a rounding error.
The Soluno deficiency was known and not corrected. Goldberg admitted the system "didn't include payments actually made." He did not then produce corrected reports. He did not recalculate Litman's share. The deficiency continued.
"The Pad" proves awareness. Goldberg built a parallel tracking system for Litman-originated matters -- tracking the very work that generated the very revenue that the formal accounting system was failing to capture. He knew how much money was being generated. He chose not to report it.
Under New York law, punitive damages are available in a Section 51 action where the defendant's conduct is "willful." The financial manipulation documented here establishes willfulness:
| Element | Evidence |
|---|---|
| Knowledge | 28,503 journal entries with Goldberg's initials; "The Pad" tracking system; trust ledger authorizations |
| Control | Sole signatory authority on trust accounts; "I will continue managing the firm as I have been" (June 15, 2021) |
| Concealment | $0 KFU/KSU in workup; Soluno reports that "didn't include payments actually made"; client renumbering |
| Scale | $16.2 million gap; $17.5M in trust transfers; 2,160 transactions across 5+ years |
| Persistence | Pattern continues from 2020 through 2025 despite Litman's repeated objections |
| Retaliation | Email access eliminated July 18, 2025 -- one day after litigation threat; cutting off Litman's ability to verify financial records |
Every client reassigned from Attorney 418 to an alternate number is a separate, affirmative act to divert revenue. Combined with the 905 patents bearing Litman's name and the 206 outgoing USPTO documents, the renumbering scheme proves that Goldberg was simultaneously exploiting Litman's professional identity for commercial gain while engineering a system to minimize the financial accounting of that gain to Litman.
The person who signed 16 Powers of Attorney placing Litman's name on patent filings is the same person who:
This is not a case of accounting complexity. It is a case of one person controlling both the name-use mechanism and the financial mechanism, and using that control to maximize revenue while minimizing the accounting of that revenue to the person whose name generated it.
The $16.2 million accounting gap is not separate from the Section 51 claim -- it is the financial consequence of it. Litman's name was used to generate $32.7 million in client revenue. Goldberg reported $16.5 million. The difference represents revenue attributable to the use of Litman's name that was never accounted for in calculating Litman's compensation.
Under Section 51, damages include "any profits attributable to the use." The trust ledger documents what came in. The workup documents what was reported. The gap between them is the measure of concealment.
| Document | Location | Key Content |
|---|---|---|
| iCloud Photos Evidence Memo | output/ICLOUD_PHOTOS_EVIDENCE_MEMO.md |
Renumbering scheme, trust manipulation, $35K KFU gap |
| Admissions from iCloud Texts | output/ADMISSIONS_FROM_ICLOUD_TEXTS.md |
Goldberg's Soluno admission, control admissions |
| Financial Gap Analysis | output/FINANCIAL_GAP_ANALYSIS.md |
$16.2M decomposition, client-by-client reconciliation |
| Consolidated Financial Exhibit | output/CONSOLIDATED_FINANCIAL_EXHIBIT.md |
JBG journal entries, SOL-window financials, fee allocations |
| Commingling Evidence Memo | output/COMMINGLING_EVIDENCE_MEMO.md |
2,160 trust-to-operating transfers, Wire_8751 bypass |
| Goldberg Trust Control Memo | output/GOLDBERG_TRUST_CONTROL_MEMO.md |
JBGverbal authorizations on KFU docket 36372 |
| Forensic Accounting Demand | output/FORENSIC_ACCOUNTING_DEMAND.md |
Discovery demands and deposition outlines |
| Quarterly Trust Ledger Analysis | output/QUARTERLY_TRUST_LEDGER_ANALYSIS.md |
Q1 2020 - Q4 2022 baseline; $7.2M in quarterly receipts |
| Verified Financial Summary | output/VERIFIED_FINANCIAL_SUMMARY.md |
$79,150 discrepancy with Goldberg's workup |
| Counsel BOP Cover Memo | output/COUNSEL_BOP_PACKAGE_COVER_MEMO_UPDATED.md |
Accounting fraud pattern (Section III.F) |
| Trust Ledger CSV | output/goldberg_financial_attachments/20250616_Trust_Ledger_0723-0525.csv |
27,898 rows of raw trust data |
| JBG Journal Entries CSV | output/JBG_JOURNAL_ENTRIES.csv |
28,503 rows of Goldberg financial activity |
| Litman Sent Items | output/LITMAN_SENT_ITEMS_ALL.csv |
"The Pad" directive, Attorney 418 requests, MSRDC discovery |
This catalog was prepared for counsel review in connection with Litman v. Goldberg, Index No. 524343/2025. All figures are based on financial documents produced in discovery and communications preserved in Richard Litman's email and iCloud Photos accounts. A forensic accountant should verify all figures before use in court filings.