Litman v. Goldberg, Index No. 524343/2025 (NY Sup. Ct. Kings County · Hon. Brian L. Gotlieb, J.S.C.) Cause of Action: NY Civil Rights Law §§ 50–51 (misappropriation of name) — practice-payout enforcement layer Plaintiff: Richard C. Litman, Esq. (Reg. No. 30,868), pro se Defendant: Joshua B. Goldberg, Esq. (Reg. No. 44,126) Compiled: 2026-04-27 — pursuant to Plaintiff's directive of the same date
"AR never expires — removed from tracking." — R.C. Litman, 4/27/2026
Accounts receivable do not legitimately have an "expiration." A receivable is owed until (a) paid, (b) formally written off (which requires a journal entry, an accounting policy, and disclosure), or (c) legally extinguished (e.g., bankruptcy discharge or contractual statute of limitations on the underlying claim). The Q4 2025 Gould Receivables-by-Client (RbC) report run on January 23, 2026 by MaryJane Harper — primary source the Q4 2025 Receivables-by-Client report (NGM Soluno report, run 1/23/2026 by MaryJane Harper) — is the AR-side mirror image of the October 2025 Trust Transfer Journal. Of the 108 KSU dockets that NGM tagged "expired J. Goldberg F[iles]" in the October 2025 Trust Transfer Journal, only 12 (11.1%) appear in the Q4 2025 Gould RbC. The other 96 (88.9%) have been silently removed from AR tracking — without a write-off journal entry, without a policy disclosure, without notice to Litman.
This is a third concealment channel sitting alongside (a) formal write-offs and (b) trust-side "expired" sweeps:
| Channel | Mechanism | Documented amount | Primary source |
|---|---|---|---|
| (1) Formal write-offs | Cancellation of receivables via AssumeProvisionalWriteOffReal flag with no Write-Off Journal produced |
$336,571 (116 entries) | Litman Client-Level Write-Off Master List, 4/27/2026 (in this bundle) (4/26/2026); CPLR 3122-a Write-Off Journal target |
| (2) Trust-side "expired" sweep | Trust ledgers labeled "expired J. Goldberg F[iles]" → 35610 holding account | $317,746 (111 entries; 110/111 signed VG / Valencia Gray) | the October 2025 Trust Transfer Journal (NGM Soluno report, generated 11/2/2025 by MaryJane Harper); Litman Expired Matters Master List, 4/27/2026 (in this bundle) (4/26/2026) |
| (3) AR-side removal-from-tracking (NEW — this memo) | Same 108 dockets disappear from the AR-aging report — 96 missing entirely; 12 retained | 96 dockets, dollar amount unknown because the rows simply do not exist in the report. Lower bound: the total open AR for the same dockets immediately pre-sweep | the Q4 2025 Receivables-by-Client report (NGM Soluno report, run 1/23/2026 by MaryJane Harper) (run 1/23/2026, ver. 1.9.131); cross-reference with EXPIRED_MATTERS_MASTER_LIST |
The pattern is dispositive on the question of intent. Under PCLaw / Soluno, removing a docket from the RbC is not automatic on aging — the firm has to either (i) close the file, (ii) zero the receivable, or (iii) flag the matter for non-billing. Each of those acts requires a discrete administrative entry. Removing 96 KSU dockets from the AR ledger contemporaneously with sweeping the matching trust balances under the "expired" label is a single bookkeeping operation with two visible halves, and it is recorded in the firm's own software metadata.
File: the Q4 2025 Receivables-by-Client report (NGM Soluno report, run 1/23/2026 by MaryJane Harper)
Length: 21 pages
Engine: PCLaw / Soluno billing system, ver. 1.9.131
Firm: Nath Goldberg & Meyer
Title: Receivables by Client
Date range: 1/1/2025 → 12/31/2025
Date run: 1/23/2026 9:37 AM
Requested By: MaryJane Harper (NGM bookkeeper)
Selections: SortByResponsible : true · MinAgingDays : 0 · InvoiceFeeSplitMethod : IntroducingBilling · Collecting : RL - Richard Litman · AssumeBillCorrectionAsAdjustment : true · AssumeProvisionalWriteOffReal : false
The grand-total on page 21:
| Category | Amount |
|---|---|
| Total billed (firm-wide, 100% Litman) | $1,077,365.64 |
| Total owing | $1,070,985.64 |
| ≤ 30 days | $46,188.00 |
| 31–60 days | $181,075.80 |
| 61–90 days | $116,348.40 |
| 91–120 days | $128,550.00 |
| > 120 days | $598,823.44 (55.9% of total owing) |
| Paid in period | $6,380.00 |
The report is 100% attributed to Richard Litman as the responsible attorney ("Lawyer: Richard Litman, Firm % 100.00"). This is the firm's own internal designation — for Q4 2025 production purposes — that every dollar of $1.07M outstanding receivable is Litman's economic stream. (Compare to the Feb 17, 2026 RbC personally requested by Goldberg with SortByResponsible:true, which surfaced one casefile ($16,700, KSU 33115.20U) flipped to "responsible JBG" — see Litman AR Report “Responsible JBG” Finding, 4/27/2026 (in this bundle).)
Of the $1.07M total outstanding, $598,823.44 (55.9%) is over 120 days. That over-120 bucket is the AR that — under uncle's rule — must remain on the books until paid or formally written off. It does not "expire."
Source for the "expired" docket universe: Litman Expired Matters Master List, 4/27/2026 (in this bundle) (4/26/2026), which itself is sourced from primary-source the October 2025 Trust Transfer Journal pages 6–8 (sweep dates 10/30/2025 + 10/31/2025; explanation field reads verbatim "The following matters are expired J. Goldberg F[iles]"). The 108-docket universe is filtered to the nine documented sweep series: 32315, 32693, 32809, 32903, 33007, 33032, 33056, 33092, 33115 (all King Saud University, client 135576).
Sweep universe (Oct 2025 TTJ): 108 dockets, $317,746.00 swept to 35610 holding account.
Q4 2025 RbC (Jan 23 2026, run by MaryJane Harper): 275 unique dockets total, $1,077,365.64 billed, $1,070,985.64 owing.
Cross-reference:
| Status | Dockets | % of expired-tagged universe |
|---|---|---|
| Expired-tagged AND present in Q4 RbC | 12 | 11.1% |
| Expired-tagged AND missing from Q4 RbC | 96 | 88.9% |
| Docket | Client (135576 = KSU) | Owing in Q4 RbC |
|---|---|---|
| 33056.49 | KSU | $900.00 |
| 33092.02U | KSU | $300.00 |
| 33092.14U | KSU | $13,626.00 |
| 33092.72U | KSU | $266.00 |
| 33092.77U | KSU | $2,500.00 |
| 33092.81U | KSU | $1,800.00 |
| 33092.86U | KSU | $2,244.00 |
| 33092.91U | KSU | $2,900.00 |
| 33115.04U | KSU | $2,166.00 |
| 33115.32U | KSU | $800.00 |
| 33115.34U | KSU | $1,066.00 |
| 33115.35U | KSU | $4,066.00 |
| TOTAL (12 present) | $32,634.00 |
These are the dockets where the trust-side sweep happened (per the Oct 2025 TTJ) but the AR row was retained — possibly because the AR was billed AFTER the sweep, or because these specific dockets were not fully closed in the case-management system. The retention rate per series is informative:
| Series | Present in RbC | Removed from RbC | Retention rate |
|---|---|---|---|
| 32315 | 0 | 2 | 0% |
| 32693 | 0 | 10 | 0% |
| 32809 | 0 | 34 | 0% |
| 32903 | 0 | 16 | 0% |
| 33007 | 0 | 5 | 0% |
| 33032 | 0 | 2 | 0% |
| 33056 | 1 | 7 | 12.5% |
| 33092 | 7 | 14 | 33.3% |
| 33115 | 4 | 6 | 40.0% |
The older (lower-numbered) docket series are 100% removed from AR tracking. The newer series (33092, 33115) — the ones with continuing 2024–2025 prosecution activity — retain partial AR visibility. This matches the trust-side pattern in the Oct 2025 TTJ (where the older series swept first and the newer ones in smaller amounts) and rules out a benign "natural aging" explanation: if dockets disappeared because they were old, the new series wouldn't be partially removed; the removal pattern is a discrete bookkeeping action, not the passage of time.
Series 32315, 32693, 32809, 32903, 33007, 33032, 33056, 33092, 33115 — full list at Litman AR Expiring Tag — 108-Docket Cross-Reference (companion CSV in this bundle) (companion CSV, generated alongside this memo). First 25 by docket number:
32315.28, 32315.90,
32693.07, 32693.15, 32693.16, 32693.28, 32693.59, 32693.74, 32693.90, 32693.91, 32693.93, 32693.98,
32809.01, 32809.05, 32809.11, 32809.18, 32809.19, 32809.20, 32809.22, 32809.23, 32809.25, 32809.29, 32809.30, 32809.34, 32809.37 …
Each of these is a docket whose trust balance was swept on 10/30/2025 or 10/31/2025 under the "expired J. Goldberg" label, and whose AR row simultaneously vanished from the next firm-produced RbC dated 1/23/2026.
The KSU 33xxx dockets are central to the case theory on three independent dimensions:
Litman-originated client matters. All 96 removed dockets follow the legacy Litman Law Offices STI/PracticeMaster 5-digit.2-digit format (e.g., 32809.34, 33056.49). These are the matters Plaintiff brought to NGM in the 2017 transition . NGM continued to bill against them under that legacy docket system through 2024 and into 2025.
Litman-attributed within-SOL face pages. The 33115 series in particular contains the docket for U.S. Patent Application No. 18/950,651 ("Micro-Electric Discharge Milling Machine," KSU Docket 33115.20U) — the single matter that flipped to "responsible JBG" in the Feb 17, 2026 RbC (per Litman AR Report “Responsible JBG” Finding, 4/27/2026 (in this bundle)). The matter for which Martha Long (Goldberg-supervised paralegal) sent KSU Office Action notifications under Litman's name on 1/23/2025 and 4/15/2025 — both after the 7/21/2024 CPLR 215(3) SOL cutoff.
Public face = Litman; internal accounting = "expired J. Goldberg F[iles]" → removed. Same dockets, simultaneously: face-page representation to USPTO and clients ⇒ "Richard C. Litman, Reg. No. 30,868"; trust ledger sweep ⇒ "expired J. Goldberg F[iles]"; AR ledger ⇒ silently dropped. The structural § 51 fact pattern is binary: NGM holds Litman's name out as the responsible attorney to USPTO, foreign sovereign clients (KSU), and the public, while internally booking the same matters as Goldberg's expired files and removing the receivable from tracking before any payment lands.
Footers sheet preserves the firm's own software-engine metadata — engine, version, date run, requested-by, and report selections — sufficient for self-authentication).Prepared 2026-04-27 by Litman Intelligence Research Team in support of Plaintiff Richard C. Litman, pro se. Attorney work product — privileged and confidential.