Source: evidence/google_drive_download_20260415/download_extracted/0009- Bank Statements (RL_6815-9966).pdf
Bates Range: RL_6815-9966 (3,152 pages)
Analyzed: 2026-04-15
Pages 1501-2000 contain exclusively the Wells Fargo brokerage/banking statements for Victoria Grace Litman & Richard C. Litman JT WROS -- the personal joint account of Litman's daughter. These are personal spending records (ATM withdrawals in Greece, Israel, Netherlands, NYC, etc.) from the 2019-2020 annual statements. No NGM business account data exists in this range.
However, the analysis of pages 1501-2000 in context of the full 3,152-page document revealed significant findings across all pages.
This PDF contains exclusively Litman family personal accounts -- it is NOT the NGM business bank statements. The accounts found are:
| # | Account Holder | Bank | Type | Page Range |
|---|---|---|---|---|
| 1 | Cheryl L. Litman & Richard C. Litman | Fidelity | Investment/Brokerage | 1-60 |
| 2 | The Richard Curtis Litman Revocable Trust | Fidelity/WFA | Trust | 21-301 |
| 3 | Richard Curtis Litman - Individual TOD | WFA | Brokerage | 221-461 |
| 4 | Richard Curtis Litman - Traditional IRA | Fidelity | IRA | 311-451 |
| 5 | Jessica Brooke Litman & Richard C. Litman JT WROS | WFA | Joint Brokerage | 491-1500 |
| 6 | Daniel Grant Litman & Richard C. Litman JT WROS | WFA | Joint Brokerage | 681-1100, 2701-2784 |
| 7 | Victoria Grace Litman & Richard C. Litman JT WROS | WFA | Joint Brokerage | 1501-2610 |
| 8 | Richard C. Litman & Cheryl Litman JT WROS | WFA | Joint Brokerage | 591-680 |
| 9 | Richard C. Litman | WFA | Individual Brokerage | 2609-2612 |
| 10 | Richard C. Litman | Freedom Bank of Virginia | Personal Checking ("Freedom Ba$ic") | 2787-3152 |
| 11 | Amanda Rose Litman & Richard C. Litman JT WROS | WFA | Joint Brokerage | 531-581 |
Key: WFA = Wells Fargo Advisors
Pages 2787-3152 contain Richard C. Litman's personal checking account at Freedom Bank of Virginia ("Freedom Ba$ic" product). This is the SAME BANK where NGM maintained the undisclosed trust accounts (Finding #99 -- accounts 220001028 and 220001002).
| Statement Ending | Key Balances |
|---|---|
| 10/15/2018 | $29,436 - $21,795 |
| 11/15/2018 | $22,836 - $45,551 (peak) |
| 12/14/2018 | $22,424 - $42,728 |
| 01/15/2019 | -- |
| 03/15/2019 | -- |
| 04/15/2019 | $3.45 -> $566,582.22 (4/8/2019) -> $184,196 (4/12) -> $200,745 |
| 05/15/2019 | $199,848 -> $169,777 |
| 06/14/2019 | $169,554 -> $164,969 |
| 09/13/2019 | $68,202 -> $54,983 |
| 11/15/2019 | $42,300 -> $31,700 |
| 01/15/2020 | -- |
| 02/14/2020 | $58,491 -> $55,015 |
| 03/13/2020 | $54,392 -> $23,308 |
| 04/15/2020 | $22,206 -> $22,655 |
| 05/15/2020 | $29,320 -> $25,898 |
| 06/15/2020 | $33,584 -> $31,271 (SOL CUTOFF DATE) |
| 07/15/2020 | $30,759 -> $38,325 |
| 08/14/2020 | $68,505 -> $65,044 |
| 09/15/2020 | $71,444 -> $74,681 |
| 10/15/2020 | $74,194 -> $82,472 |
| 11/13/2020 | -- |
| 12/15/2020 | -- |
| 03/15/2021 | -- |
| 04/15/2021 | -- |
| 06/15/2021 | -- |
| 09/15/2021 | -- |
| 10/15/2021 | -- |
| 11/15/2021 | -- |
| 12/15/2021 | $1,213 -> $957 (LAST STATEMENT) |
Litman maintained a personal account at the same bank as NGM's trust accounts -- independently confirms Finding #105 (Litman was Freedom Bank Board Director/Chairman of Executive Loan Committee).
Account was active through at least 12/15/2021 with a balance of ~$957 -- three years before the NGM trust account closure in July 2025.
$566,582 balance spike on 4/8/2019 -- large deposit followed by $380,000 IRS tax payment on 4/12/2019 and $10,125 AMEX payment. This demonstrates Litman's substantial income stream through Freedom Bank in the pre-SOL period.
Balance on SOL cutoff date (6/15/2020): $31,270.63 -- establishes Litman's financial position at the critical date.
The personal account statements were produced in discovery (Bates RL_009595+) -- NGM/Goldberg had access to this information and knew Litman banked at Freedom Bank.
| Date | Description | Amount |
|---|---|---|
| 4/8/2019 | Large deposit (source TBD - balance jumped $499K) | ~$499,000 |
| 4/12/2019 | IRS USATAXPYMT 200950220192577 | -$380,000.00 |
| 4/5/2019 | DOVENMUEHLE MORT BILL PAYMT | -$6,400.00 |
| Various | Regular mortgage, insurance, Verizon payments | Various |
148 total FID BKG SVC LLC ACH transactions found across the entire document, totaling approximately $652,322. These are transfers between Litman's various WFA brokerage accounts and Fidelity account 645375268.
| Date | Amount | Notes |
|---|---|---|
| 2019-10-29 | $10,000 | |
| 2019-11-27 | $10,000 | |
| 2019-12-27 | $10,000 | |
| 2020-01-28 | $10,000 | |
| 2020-02-06 | $20,000 | Double payment |
| 2020-02-28 | $10,000 | |
| 2020-03-20 | $10,000 | |
| 2020-04-28 | $10,000 | |
| 2020-05-28 | $10,000 | |
| 2020-06-26 | $10,000 | |
| 2020-07-16 | $50,000 | Largest single transfer |
| 2020-07-28 | $10,000 | |
| 2020-08-28 | $10,000 | |
| 2020-09-28 | $10,000 | |
| 2020-10-23 | $40,000 | Second-largest transfer |
| 2020-10-28 | $10,000 | |
| 2020-11-27 | $10,000 | |
| 2021-06-09 | $20,000 | |
| 2021-06-23 | $25,000 | |
| 2021-10-08 | $20,000 | |
| TOTAL | $305,000 |
Pattern: Regular $10K monthly transfers Oct 2019-Nov 2020, then irregular larger amounts in 2021. The $50K transfer on 7/16/2020 (one month after SOL cutoff) and $40K transfer on 10/23/2020 are notable spikes.
2019 (4 transfers, $10,000 total): $2,500 each on 11/15, 11/27, 12/13, 12/27 2020 (28 transfers, ~$70,000 total): Regular $2,500 bi-weekly pattern Jan-Dec 2020, with one $10,000 on 3/10 and one $1,000 on 10/21 2021 (26 transfers, ~$63,500 total): Regular $2,500 bi-weekly continuing through Dec 2021 2022 (through 9/28, 21 transfers, ~$57,500 total): Regular $2,500 bi-weekly with one $10K on 6/1 and one $5,974 MoneyLine on 1/6
2021 (26 transfers, ~$85,000 total): Regular $2,500 bi-weekly with one $20,000 on 8/4 2022 (through 9/28, 21 transfers, ~$55,000 total): Regular $2,500 bi-weekly with one $10K on 6/1
Similar bi-weekly $2,500 pattern visible in sampled pages.
The Fidelity 645375268 account received regular automatic ACH deposits from multiple Litman family WFA accounts -- approximately $5,000-$10,000 per month in aggregate across all family accounts. This is the same Fidelity account that later received NGM's W-2 advance payments (Finding #104). The pre-existing regular transfer pattern from family accounts would make it harder to distinguish NGM payments from family transfers in the Fidelity account without detailed labeling.
| Year | Date | Amount | Account | Description |
|---|---|---|---|---|
| 2021 | 2/01 | -$3,026.66 | RCL & Cheryl JT WROS | Check #2073 to NATH GOLDBERG MEYER |
| 2021 | 6/07 | -$3,472.84 | RCL & Cheryl JT WROS | Check #2083 to NGM |
| 2021 | 6/23 | -$868.21 | RCL & Cheryl JT WROS | Auto payment to Nath Goldberg & Meyer |
| 2021 | 7/23 | -$868.21 | " | " |
| 2021 | 8/24 | -$868.21 | " | " |
| 2021 | 9/23 | -$868.21 | " | " |
| 2021 | 10/25 | -$868.21 | " | " |
| 2021 | 11/23 | -$868.21 | " | " |
| 2021 | 12/23 | -$868.21 | " | " |
| 2022 | 1/25 | -$1,000.56 | RCL & Cheryl JT WROS | Auto payment to Nath Goldberg & Meyer |
| 2022 | 2/25 | -$1,000.56 | " | " |
| 2022 | 3/25 | -$1,000.56 | " | " |
| 2022 | 4/26 | -$1,000.56 | " | " |
| 2022 | 5/25 | -$1,000.56 | " | " |
| 2022 | 6/27 | -$1,000.56 | " | " |
| 2022 | 7/26 | -$1,000.56 | " | " |
| 2022 | 8/25 | -$1,000.56 | " | " |
| 2022 | 9/27 | -$1,000.56 | " | " |
| 2022 | 10/25 | -$1,000.56 | " | " |
| 2022 | 11/28 | -$1,000.56 | " | " |
| 2022 | 12/28 | -$1,000.56 | " | " |
| 2023 | 2/27 | -$1,000.56 | RCL & Cheryl *3523 | TRANSFER BILL PAY Nath Goldberg & Meyer |
LITMAN WAS PAYING NGM, NOT THE OTHER WAY AROUND:
June-Dec 2021: $868.21/month recurring payment to NGM (7 months = $6,077.47). Started immediately after Goldberg's June 2021 "I will continue managing the firm" statement (Finding #29).
Jan-Dec 2022: Payment increased to $1,000.56/month (12 months = $12,006.72). The $132.35/month increase suggests either a renegotiated amount or a different payment category.
Continued into Feb 2023: At least one more payment of $1,000.56 confirmed.
Two lump-sum checks: $3,026.66 (Feb 2021, check #2073) and $3,472.84 (Jun 2021, check #2083). These may be specific expense reimbursements or quarterly true-ups.
Evidentiary Significance: These outbound payments from Litman TO NGM likely represent Litman's share of office overhead, insurance premiums, or similar firm expenses -- but they prove Litman was an active financial participant in the firm well after the purported "termination" on 6/15/2020. The recurring automatic payment structure indicates an ongoing financial relationship, contradicting any defense that Litman was fully separated from NGM.
USPTO Payment: Check #2075 for $40.00 to "USPTO PAYMENT" (2/24/2021) from the same account confirms Litman was still personally paying USPTO fees.
December 14, 2018: $30,000 ACH transfer from Freedom Bank of Virginia (account ending 4818) to Jessica Brooke Litman & Richard C. Litman JT WROS account at Wells Fargo.
This confirms inter-bank transfers between Litman's Freedom Bank personal account and his Wells Fargo family accounts -- the same banking relationship infrastructure that would later be exploited by NGM's undisclosed trust accounts.
August 24, 2018 (date of transfer into WFA account): Richard C. Litman held 3,982 shares of Freedom Bank of Virginia stock in his Wells Fargo Advisors individual brokerage account (pg 2612). This was transferred from account 72773447-1.
This independently confirms Finding #105 -- Litman was not merely a banking customer but an equity holder/director of Freedom Bank of Virginia. The stock position corroborates the "Chairman of Executive Loan Committee" board document.
The entire 3,152-page document consists exclusively of Litman family personal bank/brokerage/investment statements. The NGM trust account statements (BoA, Eagle Bank, Freedom Bank trust) are NOT in this production. This is significant because it means the discovery production labeled "Bank Statements" (Bates RL_6815-9966) contains only Litman's personal financial records, not the NGM firm accounts that are central to the accounting disputes.
Litman's personal checking at Freedom Bank (through at least 12/15/2021) independently corroborates Finding #105 (board director) and the 3,982-share stock position corroborates the ownership relationship.
At least 20 recurring monthly payments totaling ~$18,421 flowed FROM Litman TO NGM during the post-"termination" period. This contradicts any defense that Litman was fully separated from NGM.
Litman held $31,270.63 at Freedom Bank on the exact SOL cutoff date of 6/15/2020.
The pre-existing pattern of Fidelity 645375268 deposits from family accounts provides context for the later NGM W-2 advance payments into the same account.
NGM business bank statements are missing from this production. The BoA trust (8777), Eagle Bank trust (0495), BoA wire receipt (8751), BoA operating (2417), and Freedom Bank trust (028/002) accounts must be obtained through separate subpoena or production demand.
The Litman-to-NGM recurring payments should be cross-referenced against the Combination Agreement and Amendment to determine what Litman was obligated to pay vs. what NGM owed him.
The Freedom Bank personal account closing date (last statement 12/15/2021) should be investigated -- did Litman close his personal account before or after learning about the NGM trust account issues?
The $30,145 and $31,841 Lakeside Brooklyn LLC payments should be investigated for connection to Goldberg's Brooklyn operations.