Bank Statements Analysis - Part 1 (Pages 1-3152)
Document: 0009- Bank Statements (RL_6815-9966).pdf
Bates Range: RL_006815 - RL_009966
Total Pages: 3,152
EXECUTIVE SUMMARY
This document does NOT contain NGM bank statements. Despite the title "Bank Statements," the entire 3,152-page document consists exclusively of Richard C. Litman's personal and family financial accounts from the arbitration discovery period. These are Litman's own bank/brokerage statements produced as RL-prefixed (respondent) documents.
The document contains no Bank of America trust account statements (*8777 or 8751), no Eagle Bank trust statements (0495 or 3780), and no NGM operating account statements. However, it does contain Litman's personal Freedom Bank checking account statements and reveals critical payment flows from NGM to* Litman.
ACCOUNTS IDENTIFIED
1. Fidelity Brokerage - Joint WROS (Cheryl L Litman & Richard C Litman)
- Account: Fidelity joint account with rights of survivorship
- Value: $0.22 (dormant/minimal)
- Period: 2020-2022 year-end reports
- Addresses: 11329 Henderson Rd, Fairfax Station VA 22039 (pre-2021); 310 E 15th St Apt 3B, New York NY 10003 (2021-2022)
- Bates: RL_006815-006826
- Significance: Minimal - effectively empty account
2. Fidelity Brokerage - Richard Curtis Litman Revocable Trust
- Account: "THE RICHARD CURTIS LITMAN REV U/A 05/19/95 RICHARD C LITMAN TRUSTEE"
- Advisor: XML Financial Group, Rockville MD
- Value: $764,165 (Jan 2020) -> $265,633 (Dec 2020) - significant drawdown
- Period: 2020-2023
- Bates: RL_006827+
- Key Withdrawals 2020:
- Total: -$620,333.93 in withdrawals
- Multiple $10,000 EFT transfers to children's Wells Fargo accounts
- Wire to Parlatore Law Group ($1,500 and $4,100) - possibly legal counsel
- Wire to Blankingship and Keith PC ($541, $8,957, $10,000) - law firm
- Wire to Robbie Goffin/Compass RE NY LLC ($23,903 + $11,400) - real estate
- Regular payments to David P. Johnson via Bank of America ****0432 ($3,250/mo)
3. Fidelity Brokerage - Richard Curtis Litman Individual TOD
- Bates: RL_007081
- Period: 2022
- Key transaction: $12,500 deposit (Dec 2022)
4. Wells Fargo Advisors - Account ****3523 (Richard C Litman & Cheryl Litman JT WROS)
- Type: Brokerage with cash management
- Period: 2018-2023
- Bates: RL_007294+, RL_007465+
- CRITICAL - NGM PAYMENT PATTERN:
- Monthly ACH debits labeled "TRANSFER Nath Goldberg & Meyer" or "TRANSFER BILL PAY Nath Goldberg & Meyer"
- 2021 pattern: $868.21/month (Jan-Dec 2021) - 12 payments = $10,418.52/year
- 2022 pattern: $1,000.56/month (Jan-Dec 2022) - 12 payments = $12,006.72/year
- 2023: $1,000.56 continued (confirmed Jan-Mar 2023)
- Also: Check #2073 to "NATH GOLDBERG MEYER" for $3,026.66 (Feb 2021)
- Also: Check #2083 to "NGM" for $3,472.84 (Jun 2021)
- These are payments FROM Litman TO NGM (debits from his account), NOT the other direction. Likely health insurance premiums, office overhead, or similar recurring charges NGM billed to Litman.
5. Wells Fargo Advisors - Richard C Litman & Cheryl Litman (Advisor: Paul Trimber)
- Type: Brokerage with checking/debit
- Period: 2019-2022
- Address: 11329 Henderson Rd, Fairfax Station VA 22039
- Bates: RL_007406+
- CRITICAL - FIDELITY 645375268 TRANSFERS:
- Regular ACH transfers labeled "FID BKG SVC LLC ACH 645375268" - transfers INTO Litman's Fidelity investment account 645375268
- This is the same Fidelity account documented in Finding #104 (the account where NGM's W-2 advance payments landed)
- Pre-SOL pattern (2019-2020): $10,000-$20,000 transfers, roughly monthly
- 2020 transfers (year of disability):
- 2/28: $10,000
- 3/20: $10,000
- 4/28: $10,000
- Multiple others throughout 2020
- Also: 4/17/2020 wire from "BANK OF AMERICA, N" for $25,000 (possible NGM trust distribution)
- 12/17/2020 incoming wire of $758,525.29 from "FIRST EXCEL TITLE LLC" (real estate sale)
- 2021 transfers:
- 6/10: $20,000
- 6/23: $25,000
- 10/8: $20,000 (note: labeled "645375268 5CZP")
- Regular "Attorneys Dell A" deposits ($2,016, $8,400, $11,440, $13,456, $19,840, $21,856) - appears to be Litman's trust distributions or attorney fee income
- 146 total Fidelity 645375268 transfer entries found across the document
- Litman was regularly moving money from his Wells Fargo checking into his Fidelity investment account
6. Wells Fargo Advisors - Jessica Brooke Litman & Richard C Litman JT WROS
- Type: Brokerage/checking (daughter's joint account)
- Period: 2018-2022
- Bates: RL_007341+
- Key finding: 12/14 ACH transfer of $30,000 from "THE FREEDOM BANK OF VIRG CHK XXXXXXXXXXXXX4818" to Jessica Litman's Wells Fargo account. This is Litman's personal Freedom Bank checking account funding his daughter's account.
- Also: Check #1096 for $94.76 to "FREEDOM BANK OF VIRGINIA" (Dec 2019) - possibly a fee payment
7. Wells Fargo Advisors - Daniel Grant Litman & Richard C Litman JT WROS
- Type: Brokerage/checking (son's joint account)
- Period: 2019-2022
- Bates: RL_007585+
- Key finding: Pages 2771/2777 reference "Nath Goldberg" only in context of Daniel's Zelle transfers - no firm payments
8. Wells Fargo Advisors - Victoria Grace Litman & Richard C Litman JT WROS
- Type: Brokerage/checking (daughter's joint account)
- Period: 2018-2022
- Bates: RL_008393+
- KFU reference: Page 1894 - this was a false positive; "KFU" appeared as part of an unrelated transaction code
9. Wells Fargo Advisors - Richard C Litman Individual
- Bates: RL_009426
- Key transaction: 8/24 transfer of 3,982 shares of "FREEDOM BANK OF VA" stock from account 72773447-1. Also transferred 100 shares of Greater Atlantic Financial Corp and 10 shares of Greater Atlantic Capital Trust I preferred stock.
- CRITICAL: Litman held Freedom Bank of Virginia STOCK - consistent with Finding #105 (he was a board director/chairman of executive loan committee). The transfer from account 72773447-1 suggests a separate brokerage account held these bank shares.
10. Freedom Bank of Virginia - Personal Checking ("Freedom Ba$ic")
- Account holder: RICHARD C LITMAN
- Type: Personal checking account
- Period: Oct 2018 through Dec 2021 (30 monthly statements)
- Bates: RL_009600-009966 approximately
- Account number: Redacted in all statements
- Balance range: As low as $2.82 (Jan 2020) to as high as ~$566,582 (Apr 2019 - IRS tax payment month)
- Statement dates found:
- 10/15/2018 through 12/15/2021 (not continuous - some gaps)
- Last statement: 12/15/2021 (balance: $956.50)
- Key transactions:
- 04/12/2019: IRS payment of $380,000.00 (largest single debit)
- Regular bill payments: BMW Financial ($820-1,441), Dovenmuehle Mortgage ($6,400-7,200), Verizon, CIGNA, Progressive insurance
- Periodic large deposits aligned with month-end (likely firm distributions or Attorneys' Title fees)
- Two Freedom Bank Funds Availability Policy notices (effective 7/1/2020 and 9/1/2020) - confirms account was active through at least Sept 2020
- This is Litman's PERSONAL Freedom Bank checking, NOT the NGM trust accounts (220001028 / 220001002)
KEY PAYMENT FLOWS
A. NGM -> Litman Payment Chain
The statements reveal the multi-step payment flow:
1. NGM pays Litman via W-2 advance -> lands in Fidelity account 645375268 (confirmed by Finding #104)
2. Litman transfers from Fidelity to Wells Fargo via ACH ("FID BKG SVC LLC ACH 645375268") for living expenses
3. Wells Fargo funds daily expenses including children's accounts, mortgage, credit cards, insurance
B. Litman -> NGM Reverse Payments
Monthly recurring debits from Litman's Wells Fargo *3523 account TO Nath Goldberg & Meyer:
- *2021: $868.21/month x 12 = $10,418.52/year
- 2022: $1,000.56/month x 12 = $12,006.72/year
- 2023: $1,000.56/month (continued at least through March 2023)
- Plus one-time checks: $3,026.66 (Feb 2021) + $3,472.84 (Jun 2021) = $6,499.50
Total documented reverse payments (2021-2023): ~$28,931 minimum
These reverse payments likely represent:
- Health insurance premium pass-through (CIGNA/Kelly Benefits)
- Office overhead allocation
- Or some other recurring billing from NGM to Litman
This is significant because: If Litman was paying NGM ~$1,000/month for benefits, it proves an ongoing economic relationship and contradicts any "clean break" narrative. The payments continued through at least March 2023 - well past the 6/14/2023 arbitration.
C. "Attorneys Dell A" Payments
Regular deposits from "ATTORNEYS DELL A Attorne" (likely Attorneys' Title or similar) into Litman's Wells Fargo account:
- Amounts: $2,016, $7,635, $8,400, $11,440, $13,456, $19,840, $21,856
- Frequency: Bi-weekly to monthly, 2020-2022
- These may be Litman's share of firm revenue distributed through the attorneys' title/escrow account
D. Freedom Bank Stock Holdings
Page 2612 (Bates RL_009426) documents transfer of 3,982 shares of Freedom Bank of VA stock from Litman's account 72773447-1 in August (year unclear, likely 2018-2019). This independently confirms:
- Litman was a shareholder of Freedom Bank of Virginia
- Consistent with his role as board director/chairman (Finding #105)
- The stock transfer may represent a sale or account consolidation
WHAT THIS DOCUMENT DOES NOT CONTAIN
- No NGM bank statements (Bank of America trust *8777/8751, Eagle Bank 0495/3780, Freedom Bank trust 220001028/220001002, BOA operating ***2417)
- No international wire transfers (no KFU/KSU/Middle East university payments visible)
- No trust account activity (no IOLTA or client trust ledger data)
- No post-2023 records (document appears to end circa early 2023)
EVIDENTIARY VALUE
For the Case
-
REVERSE PAYMENT PATTERN (Litman -> NGM $868-1,000/month): Proves ongoing financial entanglement. If these are health insurance premiums, stacks with Finding #111 (COBRA violation) and the health-insurance-leverage theory.
-
FIDELITY 645375268 TRANSACTION TRAIL: These 146 transfer entries independently corroborate Finding #104's payment timeline. The Wells Fargo -> Fidelity transfers show Litman was actively managing his Fidelity investment account with regular deposits, confirming it was his primary investment vehicle where NGM's W-2 advances landed.
-
FREEDOM BANK STOCK OWNERSHIP: The 3,982-share transfer confirms Litman's documented role as Freedom Bank board director (Finding #105) with a concrete securities holding.
-
$30,000 FREEDOM BANK TRANSFER TO DAUGHTER: The December transfer from Freedom Bank checking (****4818) to Jessica Litman's Wells Fargo account shows Litman actively used his personal Freedom Bank account for family financial management.
-
FINANCIAL TRAJECTORY: The Revocable Trust went from $764K to $265K in 2020 alone (-$498K), with $620K in withdrawals. Combined with the disability onset, this shows the financial pressure that made Litman dependent on NGM's continued payments.
Discovery Actions
- Demand NGM's actual bank statements - this production appears to be only Litman's side of the financial picture
- The "Attorneys Dell A" payment source should be traced - if this is NGM distributing through an intermediary, it expands the payment chain
- The $868.21/$1,000.56 monthly reverse payments should be mapped to specific NGM invoices or benefit deductions
BATES INDEX
| Bates Range |
Content |
Pages |
| RL_006815-006826 |
Fidelity joint WROS (Cheryl & Richard) - dormant |
1-12 |
| RL_006827-006870 |
Fidelity Revocable Trust (2020) |
13-60 |
| RL_006871-006926 |
Fidelity Revocable Trust (2021-2022) |
~61-112 |
| RL_006927-007100 |
Fidelity Revocable Trust / Individual TOD (2022-2023) |
~113-286 |
| RL_007101-007340 |
Fidelity monthly statements (2023) |
~287-526 |
| RL_007341-007530 |
Wells Fargo - Jessica Litman joint |
~527-716 |
| RL_007531-007800 |
Wells Fargo - Daniel Litman joint (2019-2020) |
~717-986 |
| RL_007801-008032 |
Wells Fargo - Jessica Litman joint (2019-2021) |
~987-1218 |
| RL_008033-008392 |
Wells Fargo - Jessica Litman joint (2021-2022) |
~1219-1578 |
| RL_008393-008740 |
Wells Fargo - Victoria Litman joint (2018-2019) |
~1579-1926 |
| RL_008741-009200 |
Wells Fargo - Victoria Litman joint (2020-2022) |
~1927-2386 |
| RL_009201-009426 |
Wells Fargo - Richard C Litman individual |
~2387-2612 |
| RL_009427-009596 |
Wells Fargo - Daniel Litman joint (2022) |
~2613-2782 |
| RL_009597-009966 |
Freedom Bank personal checking (2018-2021) |
~2783-3152 |