Litman v. Goldberg, Index No. 524343/2025 (Sup. Ct. Kings Cnty., Hon. Brian L. Gotlieb, J.S.C.) Cause of Action: NY Civil Rights Law §§ 50–51 (misappropriation of name) Plaintiff: Richard C. Litman, Esq., Reg. No. 30,868 (pro se) Defendant: Joshua B. Goldberg, Esq., Reg. No. 44,126 Compiled: April 25, 2026
On February 17, 2026 at 8:43 AM, defendant Joshua B. Goldberg personally requested a "Receivables by Client" aging report from Nath Goldberg & Meyer's PCLaw/Soluno billing system, scoped to "Credit: RL — Richard Litman" through "End Date: 6/15/2025." That report — titled AR_Report_202602_RL.xlsx, dated run 2/17/2026, version 1.9.133 — is on its face an internal NGM business record (NY CPLR 4518) that contradicts every "Litman is the responsible attorney" face-page representation NGM has continued to make to USPTO and to KSU.
The report's Totals sheet contains exactly two responsible-attorney groupings:
| Responsible Lawyer | Casefiles | Billed | Outstanding |
|---|---|---|---|
| Joshua B. Goldberg ("Totals for responsible JBG") | 1 (King Saud University 33115.20U) | $16,700.00 | $16,700.00 |
| Richard Litman ("Totals for responsible RL") | 337 | $1,285,703.04 | $1,208,489.76 |
The single casefile internally attributed to Goldberg in the firm's books is a King Saud University patent matter — Docket 33115.20U / U.S. Patent Application No. 18/950,651 ("MICRO-ELECTRIC DISCHARGE MILLING MACHINE WITH SPARK CONTROL") — the same matter for which (a) NGM had Martha Long sending Office Action Notifications to KSU under Litman's name on January 23, 2025 and April 15, 2025, both after the 7/21/2024 CPLR 215(3) SOL cutoff, and (b) USPTO Patent Center listed Litman as the registered correspondence address as recently as January 15, 2025.
This is documentary proof, in defendant's own bookkeeping system, that Goldberg knowingly takes internal credit/responsibility (and the originator-credit / 20% economic stream that flows from "Responsible Attorney" status) for a matter whose public-facing identity NGM was simultaneously presenting to a paying foreign-sovereign-funded client as "Richard C. Litman, Reg. No. 30,868." This is the structural § 51 fact pattern: public face = Litman; internal accounting = Goldberg.
| Item | Value |
|---|---|
| File name | AR_Report_202602_RL.xlsx |
| Native location (case copy) | evidence/AR_Report_202602_RL.xlsx |
| Production-source location | evidence/gmail_downloads/attachments/AR_Report_202602_RL.xlsx |
| File size | 110,763 bytes (both copies) |
| MD5 hash (both copies, verified identical) | 92e0e13ebdfae730736b6c7b429b4c81 |
| Engine | PCLaw / Soluno billing system, ver. 1.9.133 |
Firm name (per _FIRMNAME_ heading) |
Nath Goldberg & Meyer |
Report title (per _REPORTTITLE_ heading) |
Receivables by Client |
Date range (per _DATERANGE_ heading) |
To Sunday, June 15, 2025 |
Date run (per _DATERUN_ heading) |
2/17/2026 |
The report's Footers sheet (preserved as a formal _SELECTIONS_ block by the report engine) records the verbatim Report Selections used to generate this output:
Report Selections: Completed : Tuesday, February 17, 2026 8:43 AM; ver: 1.9.133 Requested By : Joshua B. Goldberg End Date : 6/15/2025 Credit : RL - Richard Litman SortByResponsible : true MinAgingDays : 0 InvoiceFeeSplitMethod : GLAllocation TopClientsLimit : 100 AssumeBillCorrectionAsAdjustment : true AssumeProvisionalWriteOffReal : false
All other monthly RCL receivables reports in the production were generated by clerical staff. Only the February 2026 report — the first one Litman demanded after filing suit — was personally requested by the defendant.
| Period | Date Run | Requested By |
|---|---|---|
| July 2025 | 8/11/2025 9:03 AM | Tran Cy (paralegal) |
| August 2025 | 9/2/2025 9:27 AM | MaryJane Harper (bookkeeper) |
| February 2026 | 2/17/2026 8:43 AM | Joshua B. Goldberg (defendant) |
The fact that Goldberg himself, not bookkeeping, ran the Feb 2026 report defeats any "I was just inheriting Litman's reports" defense. He is on record, in his own firm's system metadata, as the actor who shaped the Feb 17, 2026 dataset and chose SortByResponsible : true — the very switch that surfaces the JBG/RL split.
Totals sheet, Row 1 (the casefile-level row):
| GROUP | ENTRYKEY | CLIENT | CONTACTPRIMARYEMAIL | CONTACTSEP | DESCRIPTION | FILE | NAME | BILLED | OUTSTANDING_TOTAL | TITLE |
|---|---|---|---|---|---|---|---|---|---|---|
| 1 | 6677A644-9C1E-EF11-86D2-002248AE60F6 | 135576 | talbahkali@ksu.edu.sa | Joshua B. Goldberg. | "U.S. Patent Application No. 18/950,651\nTitle: MICRO-ELECTRIC DISCHARGE MILLING MACHINE WITH SPARK CONTROL\nDocket No. 33115.20U / PA0001204" | 33115.20U | King Saud University | 16,700 | 16,700 | Totals for casefile 33115.20U |
Totals sheet, Row 2 (the rolled-up responsible-attorney subtotal):
| BILLED | OUTSTANDING_TOTAL | TITLE |
|---|---|---|
| 16,700 | 16,700 | Totals for responsible JBG |
Responsible Firm Summary sheet (Sheet 5):
| TITLE | BILLED | PAID | OUTSTANDING_OLDER | OUTSTANDING_TOTAL | OUTSTANDING_PERCENT |
|---|---|---|---|---|---|
| Joshua B. Goldberg | 16,700.00 | 0.00 | 16,700.00 | 16,700.00 | 1.36 |
| Richard Litman | 1,285,703.04 | 77,213.28 | 1,208,489.76 | 1,208,489.76 | 98.64 |
| Total | 1,302,403.04 | 77,213.28 | 1,224,254.76 | 1,225,189.76 | 100.00 % |
Two independent fields lock Goldberg in:
Totals for responsible JBG ($16,700) appears as its own subtotal row, distinct from "Totals for responsible RL" ($1,285,703.04). The system generated this split because the underlying matter-level "Responsible Attorney" code on file 33115.20U is JBG, not RL.The two sub-invoices behind the $16,700 line are visible on the Report tab:
| File | Client | Aging > 120 | Billed | Inv # | Last Receipt |
|---|---|---|---|---|---|
| 33115.20U | King Saud University | $14,700 | $14,700 | 420196 | (none — 12/31/9999 placeholder) |
| 33115.20U | King Saud University | $2,000 | $2,000 | 422447 | (none — 12/31/9999 placeholder) |
Both are >120 days past due; neither has been collected.
The report's own _FOOTER_ _SELECTIONS_ value identifies "Requested By : Joshua B. Goldberg" with completion timestamp Tuesday, February 17, 2026 8:43 AM. This is a system-generated audit field, not a manual signature, and therefore not subject to the post-litigation-fabrication objection that an email signature would face.
On Friday, February 20, 2026 at 4:48 PM, Aaron H. Gould (Connell Foley, NGM's litigation counsel) emailed Litman the file. The Gould transmittal is preserved verbatim inside Litman's reply email at discovery_production/NATIVES/DOCUMENTS/EMAIL_FILES/LITMAN005909_Deficiencies and Clarification Request – February 2026 AR Report .eml.eml:
From: Aaron H. Gould \agould@connellfoley.com To: Richard Litman \rclitman@gmail.com Date: Feb 20, 2026 at 16:48 Subject: [transmittal — see Litman reply re "AR Report" attached]
"Richard:
Attached is the A/R Report you requested.
Aaron"
Gould's outward framing ("the A/R Report you requested") describes Litman's discovery request. The internal metadata, however, identifies Goldberg as the system-side requestor — i.e., Goldberg himself selected the parameters and pulled the report from PCLaw/Soluno before counsel forwarded it. That is not consistent with bookkeeping running the report on counsel's instruction; it is direct defendant participation in shaping the AR data Litman would receive.
On Saturday, February 21, 2026 at 8:25 PM EST, Litman emailed Gould (cc Leo J. Hurley Jr.) a deficiency letter. Bates: LITMAN005909. Verbatim opening:
"Aaron, I have reviewed the February 2026 AR Report (AR_Report_202602_RL.xlsx). The report raises several material deficiencies and ambiguities that prevent meaningful analysis of amounts billed, collected, and outstanding. It is an AR aging report not an AR report which provides: • Complete billing history • Complete collection history • Complete trust deposit history • Write-offs, discounts, and adjustments • Cross-client transfers, if any."
The deficiency letter then itemizes six deficiencies, including the unidentified $1.4M umbrella-account balance, the all-zero collections column, missing trust-transfer detail, no fee-vs-disbursement breakdown, and absence of complete revenue history for KFU/KSU/UAEU/Kuwait clients. The 2/21/2026 deficiency letter operates as Litman's contemporaneous notice that the responsible-attorney attributions on the report are facially material to the case.
| Date | Event | Significance |
|---|---|---|
| 6/15/2020 | Combination Agreement termination (per arbitral findings) | Start of post-termination identity-misuse window |
| 6/14/2023 | Arbitration Award (Hon. Horne) — Goldberg cannot use Litman's name without consent | Any post-Award attribution-shift cannot be a "courtesy" or "title-only" defense |
| 7/21/2024 | CPLR 215(3) one-year SOL cutoff — pre-7/21/24 uses are willfulness/notice; post-7/21/24 uses are independently actionable | All operative dates below are post-cutoff |
| 1/23/2025 | Martha Long emails KSU "Office Action Notification — Docket 33115.20U" with Litman name on the cover letter (Tier-1 use, KSU side) | Public face = Litman |
| 4/15/2025 | Martha Long emails KSU "Final Office Action Notification — Docket 33115.20U" with Litman name | Public face = Litman |
| 2/17/2026 8:43 AM | Goldberg personally pulls AR report; system records "Requested By: Joshua B. Goldberg"; report attributes Docket 33115.20U responsibility to JBG | Internal accounting = Goldberg |
| 2/20/2026 4:48 PM | Gould transmits AR report to Litman | Production date |
| 2/21/2026 8:25 PM | Litman serves deficiency letter (Bates LITMAN005909) | Contemporaneous notice |
The Feb 17, 2026 AR report post-dates the arbitration award by 32 months and post-dates the CPLR 215(3) cutoff by 19 months. There is no innocent-explanation window left.
The exact KSU casefile that Goldberg's books attribute to himself is the same casefile NGM was simultaneously presenting to KSU under Litman's name. From this project's existing datasets:
| Source dataset (this codebase) | Evidence on Docket 33115.20U / Application 18/950,651 |
|---|---|
output/MARTHA_LONG_LITMAN_NAME_EMAILS.csv (post-7/21/24 portion) |
2025-01-23 — Martha Long sends "Office Action Notification for King Saud University -- Docket 33115.20U -- 1204" to iptl@KSU.EDU.SA, cc KSU contacts and ksu@4patent.com; attachment "33115.20U OA Non final 18950651.pdf" — name-use flagged YES. |
output/MARTHA_LONG_LITMAN_NAME_EMAILS.csv |
2025-04-15 — Martha Long sends "Final Office Action Notification for King Saud University -- Docket 33115.20U -- 1204" to the same KSU contacts; attachment "33115.20U OA Final 18950651.pdf" — name-use flagged YES. |
output/CASE_RELEVANT_EMAILS_RANKED.csv (USPTO control row) |
2025-01-15 — USPTO Patent Center notice to litman@4patent.com; uspto_nva@nathlaw.com; jgoldberg@nathlaw.com; correspondence address listed as "Richard C. Litman / Nath, Goldberg & Meyer / 112 S. West Street / Alexandria, VIRGINIA 22314"; document "CTNF 01/15/2025 — 33115.20U" listed. |
output/NGM_ALL_PATENTS_WITH_ASSIGNEES.csv |
Application 18950651 → Patent 12,569,923 issued 2026-03-10 to KING SAUD UNIVERSITY, assignee NGM, KNOWN=YES. Public-facing front page identifies attorney of record. |
output/KFU_KSU_RECONCILIATION_DETAIL.csv |
KSU 33115.20U — Responsible Lawyer "Richard Litman" (5/30/2024 entry "RL"); same docket later split-coded "JBG" in 2/17/2026 AR report. |
evidence/AR_Report_202602_RL.xlsx (this finding) |
2/17/2026 — KSU 33115.20U coded "Responsible JBG"; $16,700 outstanding. |
KSU's customer number is 135576 (verified across KFU_KSU_FORENSIC_DATA.csv, EMAIL_METADATA_ND0002.csv, and the AR report itself). The KSU contact talbahkali@ksu.edu.sa is the same recipient on Martha Long's name-use emails and the same primary contact on the AR report.
The pattern is therefore:
That is the textbook § 51 commercial-exploitation fact pattern: defendant uses plaintiff's name on the outside to retain a paying foreign-sovereign-funded client, while internally taking the originator credit himself.
Cross-referencing this project's existing tabulations for King Saud University (135576), the public-facing Litman-name-use volume directed to KSU during the 7/21/2024 → 2/17/2026 window includes:
| Source | Metric | Value |
|---|---|---|
output/ksu_emails_litman_name_dataset.csv / _v2.csv |
KSU emails containing Litman's name (full corpus) | sevenfold-thousand-scale (see KSU exhibit binder) |
output/KSU_EXHIBIT_BINDER_500.pdf |
500 KSU exhibits already curated for trial | 500 |
output/KSU_EXHIBIT_BINDER_100.pdf |
top-100 KSU exhibits already curated | 100 |
output/KSU_USE_DATE_CLUSTERED_BINDER.pdf |
KSU use-date-clustered exhibits | (per Project Note project_kfu_exhibit_binder.md) |
Exact figures should be re-pulled from output/ksu_daily_docket_counts.csv for any filing — this finding does not re-validate those counts. It only locks in that Docket 33115.20U is one of those use-instances.
NGM's posture in the answer (Doc #65, 1/20/2026) and Defendant's interrogatory responses has been that NGM has continued to use Litman's name on patent face pages and KSU correspondence because Litman remains the firm's responsible attorney for those matters. Goldberg's own AR report — generated 32 months post-Award by Goldberg himself — internally codes one specific KSU casefile to JBG, not RL, in a column the system enforces as the originator-credit field. That contradicts the answer.
Two independent intent indicators:
(a) Goldberg personally requested the report (system metadata).
(b) Goldberg chose SortByResponsible : true, the parameter that surfaces the JBG/RL split. He cannot claim he did not see the JBG line — the report sorts on it.
Both go to willfulness for § 51 punitive/enhanced-statutory-damages purposes.
CPLR 4518 admissibility is straightforward: the AR report is an internal NGM record, generated by NGM's regular billing system in the ordinary course of NGM's business, kept as part of NGM's regular business practice, with system-generated audit fields (date run, requested-by, version). The transmittal by NGM's own counsel (Gould, 2/20/2026) and the Bates-numbered Litman reply (LITMAN005909, 2/21/2026) lock in chain of custody and contemporaneous receipt.
The dollar figure on the responsible-JBG line ($16,700) is small relative to total KSU exposure (KSU 2025 AR alone ~$733K per output/ARBITRATION_ENFORCEMENT_AR_REPORT.md, § 4). The point is not the dollar figure; the point is the per-matter election. Once the firm has demonstrated it knows how to code a KSU matter to JBG, every other KSU matter still coded to RL is a deliberate Litman-name-use election. This pairs directly with the empirically-proved 12-of-462 post-7/21/2024 face-page election finding (project_post_sol_aor_split.md, 2026-04-25): NGM is making per-patent and per-matter choices to keep Litman's name where it benefits NGM and to flip to JBG where it does not.
| Gap | Why it matters |
|---|---|
| Underlying PCLaw/Soluno audit log for the JBG/RL split on file 33115.20U — when was the responsible-attorney code changed from RL to JBG? Who changed it? | If the change post-dates the arbitration award, that is direct intent evidence. The current evidence shows the matter was originally coded RL (per KFU_KSU_RECONCILIATION_DETAIL.csv, 5/30/2024) and is JBG by 2/17/2026 — but the precise change-date and operator are not yet on the record. |
All other AR/aging reports run by Goldberg personally (system metadata Requested By: Joshua B. Goldberg) for 2024, 2025, 2026 |
The Feb 2026 report establishes a pattern; we need the rest to confirm Goldberg routinely runs SortByResponsible reports. |
| Per-matter "Responsible Attorney" history table for all KSU dockets (135576) — what other KSU casefiles have flipped from RL to JBG (or are still RL despite Goldberg taking over)? | This is the per-matter-election proof at the bookkeeping level, paralleling the 12/462 USPTO-side finding. |
| Originator-credit / 20%-share calculation for the JBG-coded matter(s) | Confirms the dollars at stake when matters get re-coded. |
AR_Report_202602_RL.xlsx as a trial exhibit under CPLR 4518; lay foundation through the report's own _FOOTER_ _SELECTIONS_ block (engine-generated audit field) and through Gould's 2/20/2026 transmittal (party-opponent admission).| File | Use |
|---|---|
evidence/AR_Report_202602_RL.xlsx |
The AR report itself (case-copy) |
evidence/gmail_downloads/attachments/AR_Report_202602_RL.xlsx |
Production-source copy (byte-identical, MD5 92e0e13ebdfae730736b6c7b429b4c81) |
discovery_production/NATIVES/DOCUMENTS/EMAIL_FILES/LITMAN005909_Deficiencies and Clarification Request – February 2026 AR Report .eml.eml |
Litman's 2/21/2026 deficiency reply (Bates LITMAN005909) — also contains the full Gould 2/20/2026 transmittal text |
evidence/gould_hurley_emails/Deficiencies and Clarification Request – February 2026 AR Report .eml.eml |
Counsel-correspondence-folder copy of the same email |
output/MARTHA_LONG_LITMAN_NAME_EMAILS.csv |
Tier-1 § 51 KSU name-use rows for Docket 33115.20U on 1/23/2025 and 4/15/2025 |
output/CASE_RELEVANT_EMAILS_RANKED.csv |
USPTO 1/15/2025 Patent Center notification listing Litman as correspondence address for application 18950651 / docket 33115.20U |
output/NGM_ALL_PATENTS_WITH_ASSIGNEES.csv |
Application 18950651 → Patent 12,569,923 issued 2026-03-10, KSU assignee, NGM filer |
output/KFU_KSU_RECONCILIATION_DETAIL.csv |
Earlier (May 2024) "RL" coding for the same docket — pre-flip baseline |
output/ARBITRATION_ENFORCEMENT_AR_REPORT.md |
Existing § 4 analysis showing all monthly RCL receivables run by clerical staff (Tran Cy, MaryJane Harper) — context for the Goldberg-personally-ran anomaly |
output/AUG_2025_RECEIVABLES_REPORT_ANALYSIS_20260416.md |
Aug 2025 report ("Requested By: MaryJane Harper") — comparison data point |
evidence/Receivables by Client report for RCL July 2025 3.pdf.ocr.txt |
July 2025 report ("Requested By: Tran Cy") — comparison data point |
Compiled from defendant's own business records and counsel transmittals. Identity-exploitation framing per project standard. NY State court evidentiary standards (CPLR 4518 business records, CPLR 215(3) SOL, CPLR 2106 affirmation) per feedback_ny_state_rules.md. Every number, date, and field cited above was traced to the named source file. No programmer or system-administration content included.