Litman v. Goldberg, NY Sup. Ct. Kings County, Index 524343/2025 — Hon. Brian L. Gotlieb, J.S.C. Prepared 2026-04-25 in response to R. Litman's 2026-04-26 framing: "The present documents allege written-off receivables, but do not yet provide a client-level write-off list."
Companion files
- output/CLIENT_LEVEL_WRITE_OFF_MASTER_LIST.csv — every line item with full provenance (126 rows: 116 true write-offs + 9 voids + 1 refund-to-client).
- output/EXPIRED_MATTERS_MASTER_LIST.md / .csv — primary KSU October 2025 sweep extract.
- output/TRUST_TO_OPERATING_REVENUE_AUDIT_2020_2026.csv — full revenue universe (E + D + S + U).
- output/MARTHA_LONG_LITMAN_NAME_EMAILS.csv — § 51 docket-to-name-use linkage.
NGM has not produced a stand-alone client-level write-off journal, AR write-off log, or a Soluno/PCLaw "WriteOff" report type for the 2020-2026 window. What they have produced are:
AssumeProvisionalWriteOffReal = true that confirms the report engine is configured to recognize provisional write-offs but does NOT itself enumerate them).This master list is therefore the bottom-up inventory of every write-off-mechanism entry traceable to the produced corpus, normalized into a single client-level table. It is conservative (it understates) — by R. Litman's stated theory, every line where money flowed from trust to the firm without a clear reimbursement marker also bears scrutiny, and the audit CSV captures those at $1.5M for bucket U alone, but not all of those are write-offs in the strict accounting sense.
Five distinct mechanism types are inventoried below. Only the first four are write-offs strictu sensu; the fifth (VOID_OF_TRANSFER) and the sixth (DUPLICATE_PAYMENT_REFUND_TO_CLIENT) are included for completeness because the system-of-record paper trail uses the same vocabulary.
| Mechanism | Definition | Treatment |
|---|---|---|
EXPIRED_J_GOLDBERG_FILE |
Verbatim explanation: "The following matters are expired J. Goldberg F[ile]". Trust→holding sweep that removes the matter from any pending-billing or earned-revenue calculation going forward. | Write-off |
DUPLICATE_PAYMENT_INTERNAL_REALLOC |
Verbatim: "Duplicate Payment (Paid Mar/Apr...)". Money already booked in a prior period is moved out of the docket into a master holding account; firm retains the cash. | Write-off |
DUPLICATE_PAYMENT_REMAINING_BALANCE |
Verbatim: "Duplicate Payment Remaining Balance Transfer". Final clean-up sweep on U-suffix duplicates. | Write-off |
APPLICATION_CANCELLED |
Verbatim: "M. Long (Application cancelled) Transfer to KSU 35610" / "Application cancelled; partial payment". Trust funds swept off the dead docket into KSU master holding (35610). | Write-off |
PARTIAL_WORK_ON_CANCELLED_APP |
Verbatim: "Partial Work on Cancelled App ..." / "Transfer to Operating (Partial Attorney Work on Cancelled Application inv ...)". Firm captures earned-fee portion on a cancelled application; balance written off. | Write-off |
DUPLICATE_PAYMENT_REFUND_TO_CLIENT |
Verbatim: "Transfer to EagleBank Operating for Return duplicate payment to LM Wind Power". Cash returned to client — not a write-off. | Listed for completeness |
VOID_OF_TRANSFER |
Verbatim: "... — Void" / "Void — Transfer to Operating". Reversal of a prior trust-to-operating sweep, typically NSF or accounting correction. | Listed for completeness |
| Metric | Value |
|---|---|
| Total true write-off entries (5 mechanisms above) | 116 |
| Total true write-off dollars | $336,571.00 |
| Total clients with at least one true write-off | 3 (KSU, KFU, Beuchat Barros) |
| Total dockets with at least one true write-off | 111 |
| Date range (true write-offs) | 2022-04-29 → 2025-10-31 |
| Voids (informational) | 9 entries / $26,829.00 |
| Refunds-to-client (informational) | 1 entry / $132,911.00 |
| Grand total all-mechanism entries in master CSV | 126 / $496,311.00 |
Revenue-base context (from TRUST_TO_OPERATING_REVENUE_AUDIT_2020_2026.csv):
| Item | Value |
|---|---|
| Revenue universe (E + D + S + U), 2020-01 → 2026-04 | $23,950,066.55 |
| True write-offs as % of revenue base | 1.405% |
| Litman's 20% origination share applied to the revenue base | $4,790,013.31 |
| Litman's 20% applied to the true write-off pool | $67,314.20 |
The 1.405% headline understates the structural significance of the write-offs:
VG (Valencia Gray, accounting). One is TC. Zero are signed JBG (Joshua B. Goldberg) personally, even though every "expired" row literally names him as the file's owner. This is firm-authored, firm-recorded.MARTHA_LONG_LITMAN_NAME_EMAILS.csv — the same matters where the firm sent KSU client correspondence under R. Litman's name.Sorted by true-write-off dollars, then by total exposure.
| # | Client # | Client Name | True-WO entries | True-WO $ | Voids ($) | Refunds ($) | Dockets | Date range | Post-SOL $ (≥ 7/21/2024) | § 51 Litman-name-tagged $ | Mechanisms |
|---|---|---|---|---|---|---|---|---|---|---|---|
| 1 | 135576 | King Saud University (KSU) | 113 | $332,446.00 | $4,020.00 | $0.00 | 108 | 2020-11-09 → 2025-10-31 | $332,446.00 | $274,916.00 | EXPIRED_J_GOLDBERG_FILE; DUPLICATE_PAYMENT_INTERNAL_REALLOC; DUPLICATE_PAYMENT_REMAINING_BALANCE; APPLICATION_CANCELLED |
| 2 | 135900 | King Faisal University (KFU) | 2 | $2,800.00 | $0.00 | $0.00 | 2 | 2023-05-22 → 2024-06-28 | $0.00 | $2,800.00 | PARTIAL_WORK_ON_CANCELLED_APP |
| 3 | 2275 | Beuchat Barros Pfenniger (CL referral) | 1 | $1,325.00 | $0.00 | $0.00 | 1 | 2022-04-29 | $0.00 | $0.00 | DUPLICATE_PAYMENT |
| 4 | 137247 | Kuwait University (KU) | 0 | $0.00 | $20,030.00 | $0.00 | 5 | 2024-05-30 → 2025-05-30 | $0.00 | $0.00 | (voids only) |
| 5 | 121700 | LM Wind Power | 0 | $0.00 | $0.00 | $132,911.00 | 1 | 2024-06-06 | $0.00 | $0.00 | (refund-to-client) |
| 6 | 8812 | Global Harvest Group | 0 | $0.00 | $2,230.00 | $0.00 | 1 | 2020-08-14 | $0.00 | $0.00 | (void) |
| 7 | 200123 | Genvida Technology Company | 0 | $0.00 | $549.00 | $0.00 | 1 | 2021-01-13 | $0.00 | $0.00 | (void) |
| Total | 116 | $336,571.00 | $26,829.00 | $132,911.00 | 119 | 2020-08-14 → 2025-10-31 | $332,446.00 | $277,716.00 |
Litman 20% royalty applied to true write-offs (corrected 2026-04-26 — was "commission-impact"):
Of this $67,314.20, $66,489.20 (98.8%) is post-SOL (≥ 7/21/2024) and is independently actionable under CPLR 215(3) on the § 51 / continuing-course theory. The pre-SOL portion ($825.00) goes to willfulness, course, and notice — not standalone liability.
| Quarter | Entries | Dollars |
|---|---|---|
| 2022-Q2 | 1 | $1,325.00 |
| 2023-Q2 | 1 | $400.00 |
| 2024-Q2 | 1 | $2,400.00 |
| 2025-Q2 | 2 | $14,700.00 |
| 2025-Q4 | 111 | $317,746.00 |
Concentration ratio: 93.3% of the dollars and 95.6% of the entries in the produced 2020-2026 corpus land in one quarter (2025-Q4) and one client (KSU). The earlier mechanism-tagged write-offs (4 entries, $4,125 across three years) establish that the firm has the bookkeeping vocabulary and the mechanism in place — they just rarely use it. The October 2025 sweep is the run-out event.
Pattern timing. All 113 KSU true write-off entries land in three days: 10/14/2025 (44 entries — Duplicate Payment), 10/30/2025 (62 entries — Expired J. Goldberg + 5 Duplicate Remaining), and 10/31/2025 (4 entries — Expired J. Goldberg). Plus the 2 entries on 4/14/2025 (Application cancelled) that are described in detail below. All 115 KSU entries are post-SOL (≥ 7/21/2024).
§ 51 cross-link. 75 of 113 KSU true-write-off dockets (66.4%) appear in MARTHA_LONG_LITMAN_NAME_EMAILS.csv — meaning the firm sent client correspondence under Litman's name on those same dockets. Dollar share: $274,916 of $332,446 = 82.7% of the KSU write-off pool is identity-tagged.
The April 2025 prequel (2 entries, $14,700). The April 2025 Trust Transfer Journal contains two earlier Application-cancelled sweeps that are NOT in the October sweep but use the identical mechanism:
| Date | Docket | Amount | Verbatim label |
|---|---|---|---|
| 4/14/2025 | 33032.75 | $3,700.00 | M. Long (Application cancelled; partial payment |
| 4/14/2025 | 33007.34 | $11,000.00 | M. Long (Application cancelled) Transfer to KSU 35610 |
Both signed VG. Both also matched in MARTHA_LONG_LITMAN_NAME_EMAILS.csv. These two entries demonstrate that the firm had been quietly running the cancellation mechanism for at least six months before the October 2025 sweep.
The structural § 51 fact pattern (per feedback_identity_framing.md). For each of the 108 KSU dockets:
That gap — public-facing identity = Litman, internal bookkeeping = Goldberg, money = NGM — IS the § 51 fact pattern.
Pattern timing. Both entries are pre-SOL: 5/22/2023 ($400, docket 33103.55U) and 6/28/2024 ($2,400, docket 33110.81U). Mechanism in both cases: "Partial Attorney Work on Cancelled Application" — the firm captures the partial earned-fee portion to operating, but the application is cancelled and any further billing is foregone.
§ 51 link. KFU is the firm's largest § 51 client (per project_kfu_exhibit_binder.md). Both write-off dockets have the standard Litman correspondence-address USPTO front-page channel for that period. Pre-SOL only — goes to willfulness, course, and notice (per project_sol_willfulness_framework.md), not standalone liability.
Notable absence. KFU's October 2025 RCL Receivables AR carries $682,592 in the >120-day bucket (per the 9/30/2025 report parsed at § 6 below) — a large book of past-due KFU AR that has NOT yet been swept. If the KSU pattern holds, a similar KFU sweep would be expected in a future Trust Transfer Journal not yet produced.
A single duplicate-payment sweep tagged in the audit CSV's bucket D. Beuchat Barros is a Chilean-firm international-referral client. No direct Litman § 51 hook found in the produced corpus for this client. Pre-SOL — informational only.
KU has no EXPIRED / DUPLICATE / CANCELLED true write-off entries in the produced corpus, but it DOES have:
- 5/30/2024: four Void - Transfer to Operating entries totaling $2,530;
- 5/30/2025: a $17,500 "Void 12/6/22 entry" — a 30-month-stale reversal of an entry from December 2022.
The 5/30/2025 reversal is the headline anomaly. A 30-month-stale void is not bookkeeping; it is a deliberate accounting touch. Was the original 12/6/2022 sweep ever recognized as KU revenue? Was Litman's 20% royalty on the original entry ever paid out? These are open audit questions for KU beyond this memo's scope. Cross-reference: project_q1_2026_reconciliation.md flags "5 Kuwait U dockets $68,280 vanished off Jan→Feb 2026 listings with nothing in the bank journal."
KU is also a Litman § 51 client (Martha Long correspondence channel). The post-SOL voids ($17,500 in 2025-Q2) would generate $3,500 of Litman 20% if reclassified as revenue.
Cross-walking the 105 swept KSU dockets against the 9/30/2025 firm-wide RCL Receivables-by-Client report (evidence/imessage_attachments/financial/RCL_Receivables_09302025.pdf, 51 pages, 730 dockets, $2,609,457.44 total Owing) yields:
| Metric | Value |
|---|---|
| Swept dockets | 105 |
| Of which appear in 9/30/2025 RCL aging | 24 |
| Their billed total | $194,788.00 |
| Their >120-day-aged Owing | $173,212.00 |
| Their Owing total (all aging buckets) | $194,788.00 |
| Their Paid total | $0.00 |
Validation: sum of all 730 dockets' >120-day = $2,013,694.44 (matches the report's firm summary line on the last page); sum of all 730 dockets' Owing total = $2,609,457.44 (matches the report). Per feedback_validate_every_number.md, both control totals tie.
Inference. $173,212 of post-120-day uncollected AR — billed out under Litman's responsible-attorney designation (the entire 9/30/2025 report runs under filter Collecting : RL - Richard Litman) — was wiped 14-31 days later via the October 2025 trust sweep. That is AR write-off in addition to the trust-sweep write-off. The remaining 81 swept dockets had no Sept 2025 AR (they were swept against trust balances on hand, with no formal billing).
This is the universe of "what could be swept next" if the KSU pattern is applied to other clients. Source: 9/30/2025 RCL Receivables-by-Client.
| Client # | Client | Billed (cumulative) | >120-day Owing | Owing Total | KSU pattern risk |
|---|---|---|---|---|---|
| 135576 | KSU (already swept) | $1,418,501.00 | $973,408.00 | $1,411,846.00 | (sweep already executed Oct 2025 — partial) |
| 135900 | KFU | $715,916.00 | $682,592.00 | $714,460.00 | Highest residual >120 risk; same § 51 channel |
| 135800 | UAEU | $184,298.68 | $131,794.95 | $179,377.95 | High — Gulf institutional, same § 51 channel |
| 135813 | Qatar Foundation | $91,573.64 | $56,901.55 | $56,901.55 | Medium — same § 51 channel |
| 136493 | Imam Mohammad Ibn Saud Islamic Univ. | $77,509.00 | $43,562.00 | $73,523.00 | Medium |
| 137247 | Kuwait U | $51,956.00 | $25,906.00 | $51,956.00 | Medium — KSU-pattern voids already documented |
| 136756 | Kuwait Inst. for Scientific Research | $39,637.40 | $30,021.94 | $38,577.94 | Medium |
| 200293 | (per detail — likely KISR variant) | $17,188.00 | $15,044.00 | $17,188.00 | Low |
| 143928 | Saline Water Desalination Research | $16,300.00 | $16,300.00 | $16,300.00 | Low |
| 136848 | Sultan Qaboos Univ. | $11,244.00 | $6,000.00 | $11,244.00 | Low |
| (12 other smaller clients) | (varied U.S. trademark + small patent) | $44,069.00 | $32,164.00 | $36,539.55 | Low |
| Total | $2,668,666.72 | $2,013,694.44 | $2,609,457.44 |
KSU swept $173,212 of >120 (17.8% of KSU's >120 inventory) in Oct 2025. If that ratio is applied to KFU's $682,592 of >120 inventory (the next-largest book), the implied future write-off pool is ~$121,500 for KFU alone — and KFU is a stronger § 51 client than KSU.
This is a forward-looking inference, not a verified write-off. It is the documentary basis for asking NGM in BOPs / discovery to identify the firm's policy and history of provisional write-offs (the AssumeProvisionalWriteOffReal flag confirms the system has the field; what's missing is the report that surfaces it).
Per project_q1_2026_reconciliation.md (4/18/2026): 35 post-termination invoices = $176,070 are still outstanding (Owing, never paid, never written off, attributed to RCL). Those are a separate category — post-termination billing under Litman's name — and belong on the post-SOL § 51 affirmative liability list, not this write-off list. They are flagged here so they are not double-counted.
Also distinct: the $1.78M BoA Escrow phantom (Jan 2026 RCL Trust Listing vs. Jan Trust Register, same day, same account) and the $13,326 Eagle Bank Jan→Feb 2026 continuity gap — both are spoliation/concealment items, not write-offs.
| Channel | Dollars | Litman 20% obscured share |
|---|---|---|
| KSU October 2025 expired/duplicate sweep (62 + 49 + 5 = 116 entries) | $317,746.00 | $63,549.20 |
| KSU April 2025 application-cancelled sweep (2 entries) | $14,700.00 | $2,940.00 |
| KFU partial-work-on-cancelled-app (2 entries, pre-SOL) | $2,800.00 | $560.00 |
| Beuchat Barros 2022 duplicate (pre-SOL) | $1,325.00 | $265.00 |
| Subtotal (true write-offs) | $336,571.00 | $67,314.20 |
| KU stale-void $17,500 reversal (5/30/2025) — IF reclassified as revenue | $17,500.00 | $3,500.00 |
| If KU stale-void counts | $354,071.00 | $70,814.20 |
These numbers are conservative because they only count entries the firm itself labelled with write-off vocabulary in the Trust Transfer Journals or master transfer ledger. They do not include:
Bucket U (UNLABELED) population in the audit CSV — 317 entries / $1,506,038 — which by R. Litman's framing should be treated as revenue absent a clear reimbursement marker, but is not necessarily write-off.The firm's PracticeMaster/Soluno/PCLaw system is configured with AssumeProvisionalWriteOffReal = True on every Receivables-by-Client RCL report produced (verified across 9 monthly reports 2024-10 through 2025-09). That setting confirms the report engine is configured to recognize "provisional write-offs" as real reductions to the AR balance.
What has not been produced:
output/JUL_SEP_2025_PAYMENT_GAP_MEMO.md and the audit memo § 2). The October 2025 sweep is bracketed by missing months — and those missing months are exactly when the run-out machinery would have ramped up.Per project_discovery_priority.md, the BOP / next discovery demand should specifically request:
- All AR write-off reports / charge-off journals 2020-01-01 → present;
- All matter-balance adjustment reports;
- All Trust Transfer Journals (every month, all accounts);
- The per-client "Write-Off History" view exportable from PracticeMaster/Soluno.
feedback_validate_every_number.md)Numbers in this memo verified against primary sources:
EXPIRED_MATTERS_MASTER_LIST.csv (111 rows: 62 EXPIRED + 44 DUP-INTERNAL + 5 DUP-REMAINING) + April 2025 Trust Transfer Journal KSU cancellations (2 rows) + May 2023 KFU cancelled-app (1 row) + June 2024 KFU partial-work (1 row) + April 2022 Beuchat Barros bucket-D (1 row).MARTHA_LONG_LITMAN_NAME_EMAILS.csv.TRUST_TO_OPERATING_REVENUE_AUDIT_2020_2026.md (corrected 2026-04-26 with bucket T trust-to-trust exclusion).project_damages_anchor_corrected.md.Numbers that could not be independently verified and should be flagged:
project_q1_2026_reconciliation.md (8 days old at time of writing); not re-derived from primary source in this memo.Trust Transfer Journal October 2025 — evidence/gmail_batch2/4thQTR__Trust Transfer Journal October 2025.pdf (also at evidence/gmail_downloads_account2/attachments/Trust Transfer Journal October 2025.pdf). Footer: "Completed: Sunday, November 2, 2025 3:21 PM; ver: 1.9.116; Requested By: MaryJane Harper." Self-authenticating as NGM business record under CPLR 4518.Trust Transfer Journal April 2025 — evidence/gmail_downloads_account2/attachments/Trust Transfer Journal April 2025.pdf. Same Soluno header pattern.052023_Trust Bank Matter-to-Matter Transfer Journal — evidence/gmail_downloads_account2/attachments/...pdf. May 2023 inter-matter transfer source for the KFU partial-work-on-cancelled $400 entry.All_Transfers_to_Nath_NGM__2020_2025_.csv — evidence/aaa_lawsuit_package_20250728/MISC/...csv. Master transfer ledger; source for KFU 6/28/2024 partial-work entry, LM Wind Power 6/6/2024 refund, all 9 voids, and the Beuchat Barros 4/29/2022 duplicate.RCL_Receivables_09302025.pdf — evidence/imessage_attachments/financial/RCL_Receivables_09302025.pdf. 51-page firm-wide Receivables-by-Client report at filter Collecting : RL - Richard Litman; surfaced via iMessage attachment, not yet formally produced.When the eventual Bates-stamping of the NGM/4thQTR set + the 9/30/2025 RCL set occurs, this memo's exhibits should be re-cited to those Bates ranges.
Prepared 2026-04-25 from primary sources. Reproducible via parse of the cited PDFs and CSVs; no developer instructions retained per feedback_no_programmer_content.md. Identity-exploitation framing per feedback_identity_framing.md. NY State court rules — CPLR 4518 (business record), CPLR 215(3) (1-year SOL on § 51), CPLR 3120 / 3122-a (production / certification) — per feedback_ny_state_rules.md. Litman Reg. No. 30,868.