Compiled: 2026-04-16
Scope: All Connell Foley LLP correspondence in the corpus, flagged for admissions and inconsistencies.
Authority: Per Richard Litman 04/16/2026 — "Attorney admissions/inconsistencies in briefs and communications can be basis to get to evidence." Memory: feedback_counsel_admissions.md.
| Name | Title | Role | |
|---|---|---|---|
| Aaron H. Gould | Partner, Lead Counsel | agould@connellfoley.com | Primary correspondent; signed 9/3/2025 email with three critical admissions |
| Leo J. Hurley, Jr. | Partner | LHurley@connellfoley.com | Substantive responses; condescending posture (Mar 1, 2026) |
| Cherylyn Tanner | Attorney | CTanner@connellfoley.com | CC'd on 9/3/2025 Gould email |
| Matt Ramin | Attorney | MRamin@connellfoley.com | CC'd on 9/3/2025 Gould email; listed on NYSCEF notifications |
| Dana Velasquez | Paralegal/Support | dvelazquez@connellfoley.com | Listed on NYSCEF notifications; emergency contact in out-of-office replies |
| D. Martinez | Support Staff | dmartinez@connellfoley.com | Listed on NYSCEF notifications |
evidence/gould_hurley_emails/CRITICAL GAP: The 9/3/2025 Gould email (containing three dispositive admissions) is NOT in the ND0001/ND0002 metadata CSVs. It exists as a native .eml forwarded by Plaintiff but is not Bates-stamped in the discovery corpus.
From: Richard Litman rclitman@gmail.com
To: Aaron H. Gould agould@connellfoley.com
CC: Leo J. Hurley lhurley@connellfoley.com
Subject: Litman v Goldberg - prospective Kuwait opportunity
Source: evidence/gould_hurley_emails/Litman v Goldberg - prospective Kuwait opportunity.eml.eml
Substance: During active litigation, Plaintiff forwards a significant business opportunity (Omar Albannai / Kuwaiti law firm consultancy) to Defendants' counsel for Josh Goldberg, noting that Sabah Al Ahmad Center was a "seven-figure annual client" and Omar is seeking NGM services. Plaintiff explicitly requests Gould to direct Goldberg to contact Omar.
Admissions / Inconsistencies: - Plaintiff continuing to identify and forward revenue-generating opportunities to Defendants even after litigation commenced (6/26/2025 trigger). - Gould/Hurley handling business development matters on behalf of Goldberg in mid-litigation. - Implicit admission that business development remained active and operationally viable (relevant to damages calculations and post-6/15/2020 name-use benefit).
Cross-ref findings: #102 (ongoing business development), damages testimony.
From: Richard Litman rclitman@gmail.com
To: Leo J. Hurley lhurley@connellfoley.com
CC: Aaron H. Gould agould@connellfoley.com
Subject: PS. Litman . Goldberg
Attachments: IMG_1540.PNG (WhatsApp voice transcript)
Source: evidence/gould_hurley_emails/PS. Litman . Goldberg.eml.eml
Substance: Plaintiff forwards WhatsApp voice message from Omar Albannai directly to counsel. Albannai expresses personal regard for Plaintiff and uncertainty about current representation: "Are you still working for the company or are you free? And or you still working with Josh? I don't know why you recommend Josh to represent you... My my logo now East or West Richard is the best, you are unplaceable to me at least."
Admissions / Inconsistencies: - Third-party client testifying to Plaintiff's continuing personal relationships and business value. - Albannai's uncertainty about representation structure undercuts Defendants' theory that Litman had been cleanly separated from the practice. - Gould/Hurley received direct evidence that Plaintiff's personal goodwill and client relationships remained intact and valued.
Cross-ref findings: #102 (ongoing client relationships), credibility of consent defenses.
From: Aaron H. Gould agould@connellfoley.com
To: Richard Litman rclitman@gmail.com
CC: Cherylyn Tanner CTanner@connellfoley.com, Matt Ramin MRamin@connellfoley.com, Leo J. Hurley, Jr. LHurley@connellfoley.com
Date: September 3, 2025, 14:16:14 EDT
Subject: RE: Litman v Goldberg (Kings County) and Litman v. Nath (EDNY)
Source: Not in ND0001/ND0002 CSV metadata. Held by Plaintiff via direct email receipt. Documented in output/EXHIBIT_GOULD_20250903_ADMISSIONS.md.
Verbatim Email Text:
Richard:
Understood. I just wanted verify with you that filing second amended
complaints remained your intention because of forthcoming response
deadlines on the existing amended complaints.
We will be back to you on the 2024 accounting, litman@4patent.com
e-mail domain issue, and proposed use agreement after discussion with
our clients.
Regards,
Aaron
Aaron H. Gould
Partner
Connell Foley LLP
Harborside 5 | 185 Hudson Street, Suite 2510 | Jersey City, NJ 07311
Phone 201.521.1000
Direct 201.631.7803
Fax 201.521.0100
Substance: Nine months into the dispute, Defendants' lead counsel acknowledges three specific unresolved matters and promises follow-up. The email operates as a contemporaneous written admission by counsel of record that all three issues remained live, contested, and pending.
ADMISSION 1 — "The 2024 Accounting"
Defense counsel expressly acknowledges that as of 9/3/2025 — eight months after year-end 2024 — the 2024 accounting remained an outstanding item owed to Plaintiff and unproduced. The promise that Connell Foley "will be back to you ... after discussion with our clients" is itself an admission that: - The 2024 accounting had not been produced; - Plaintiff had demanded it; - Defendants retained control over production.
Relevance:
- Stacks with Finding #50 (8-month suppression of July 2025 Payment Allocation Report).
- Stacks with Finding #99 (Freedom Bank trust account concealment and 7/28/2025 "Close Account" wire).
- Furnishes CPLR § 3126 adverse-inference fuel under Stark v. Fry.
- Cross-ref: output/DISCOVERY_DEMAND_FEE_SCHEDULES_20260416.md (Requests 1–5).
ADMISSION 2 — "Litman@4patent.com E-mail Domain Issue"
Defense counsel characterizes the 4patent.com email-domain dispute as an "issue" — a genuine, open, contested matter requiring client consultation. That characterization is itself the admission. A defendant that later moves for summary judgment claiming "no genuine dispute" over Amendment § 3's royalty-free email license will be impeached by its own lead counsel's 9/3/2025 characterization of the domain as a live dispute.
Relevance: - Finding #43 (4patent.com DKIM → nathlaw.onmicrosoft.com; NGM controls tenant). - Finding #94 (Amendment § 3 email license grant). - Finding #106 (8,024+ emails continued landing in "eliminated" accounts through December 2025). - July 2025 email elimination is conduct; Gould's 9/3/2025 admission is contemporaneous acknowledgment.
ADMISSION 3 — "Proposed Use Agreement" (KILL-SHOT AGAINST CONSENT DEFENSES)
Defense counsel represented in writing that a "proposed use agreement" was under consideration and awaiting "discussion with our clients" as of 9/3/2025.
Legal Effect: A party that proposes a new agreement to govern a use necessarily concedes that no existing agreement covers that use. If the Combination Agreement (3/29/2017), the Amendment (5/6/2017), or any other instrument already authorized Defendants' post-6/15/2020 name use, there would be nothing left to "agree" to; the existing document would govern. The act of proposing a new use agreement is an admission against interest (Fed. R. Evid. 801(d)(2); CPLR § 4514) that Defendants' counsel did not believe any existing instrument authorized the ongoing name use.
Defeats Every Consent-Based Defense: - Finding #4 (consent destroyed): Goldberg's Nunc Pro Tunc Assignment already admits Litman owns his name; the 9/3/2025 "proposed use agreement" confirms it from counsel. - Finding #16 (Eighth Affirmative Defense destroyed): BOP response characterized use as "purely as courtesy"; Gould's admission confirms there is no contractual basis. - Finding #86 (Trademark Assignment carve-out): Goldberg's own Asset-Sale/Trademark-Assignment expressly carved out Litman's "name, signature, voice, image, photograph or likeness"; the 9/3/2025 "proposed use agreement" is recognition the carve-out was never cured. - Finding #94 (Amendment § 3 email license breach): Same email tells Plaintiff the existing § 3 license is itself an unresolved "issue."
Discovery Targets Generated: 1. All drafts of the "proposed use agreement" in any NGM or Connell Foley file. 2. All internal Connell Foley/NGM correspondence discussing the "proposed use agreement." 3. All internal Connell Foley/NGM correspondence discussing the "litman@4patent.com e-mail domain issue." 4. The 2024 accounting (umbrella category). 5. The follow-up response Gould promised but never delivered.
Critical Gap — Non-Delivery: On information and belief, Connell Foley never sent a follow-up response to any of the three issues. Absence of follow-through is itself evidence of discovery non-compliance and the hollowness of any retroactive consent defense.
From: Richard Litman rclitman@gmail.com
To: Aaron H. Gould agould@connellfoley.com
CC: Leo J. Hurley lhurley@connellfoley.com
Subject: Litman v Goldberg - quarterly report
Source: evidence/gould_hurley_emails/Litman v Goldberg - quarterly report.eml.eml
Substance: Plaintiff requests Q4 2025 quarterly report and demands money "reflected as due." Formal, polite demand for financial accounting.
Admissions / Inconsistencies: - No substantive Gould/Hurley objection to the obligation to produce quarterly reports. - Confirms Combination Agreement payment obligations remain enforceable.
From: Richard Litman rclitman@gmail.com
To: Aaron H. Gould agould@connellfoley.com
CC: Leo J. Hurley, Jr. LHurley@connellfoley.com
Subject: Re: Litman v Goldberg - quarterly report and payments
Substance: Litman presses for Q4 2025 true-up report. Plaintiff cites "significant receivables."
Admissions / Inconsistencies: - Gould response (Jan 15): "The payments are quarterly per the agreement. We had that discussion already and I do not want to rehash it." - ADMISSION: Gould explicitly acknowledges the quarterly payment obligation exists and has been discussed. - INCONSISTENCY: Contradicts any theory that payment obligations were modified or suspended. Gould's refusal to "rehash" signals bad faith.
From: Aaron H. Gould agould@connellfoley.com
To: Richard Litman rclitman@gmail.com
CC: Leo J. Hurley, Jr. LHurley@connellfoley.com
Subject: RE: Follow up
Attachments: 17 files including:
- Litman 2025 Summary (December)
- RbC with inv Fee split method (as of invoice creation)
- Trust Bank Journal (Dec 2025)
- Trust Listing for RCL (Dec 2025)
- Trust Register Report (Dec 2025)
- Trust Transfer Journal (Dec 2025)
- Payment Allocation by Client Report (Oct, Nov, Dec 2025)
- Trust Bank Journal (Nov, Oct 2025)
- Trust Listing, Register Report, Transfer Journal (Nov, Oct 2025)
Source: evidence/gould_hurley_emails/Follow up.eml.eml
Substance: Gould produces Q4 2025 financial reconciliation and notes "The payment is in process."
Admissions / Inconsistencies: - ADMISSION: Production of 17 detailed financial records on demand confirms financial tracking and segregation of Litman accounts within NGM systems. - INCONSISTENCY: On 2/21/2026, Litman will analyze these same records and identify $1.4M in unidentified client balances (477 matters, no client name, $0 collections, all >120 days past due). Gould's production acknowledges the existence of receivables Defendants claim are uncollectable or unsegregated.
From: Aaron H. Gould agould@connellfoley.com
To: Richard Litman rclitman@gmail.com
Subject: Discovery Responses
Attachments: J. Goldberg Discovery Cover Letter.pdf; J. Goldberg Bill of Particulars.pdf; J. Goldberg Doc Demands.pdf
Substance: Gould produces first set of Goldberg's discovery responses.
Admissions / Inconsistencies: - RFA responses contain multiple semantic evasions (e.g., "attorney for Applicant" vs. "attorney concerned with patent"). - Request #3 (POA): "No independent recollection" of signing — insufficient given e-signature on document (Finding #38). - Request #7 (Consent): Internally inconsistent — denies consent but asserts Combination Agreements as consent (contradictory). - Request #9 (Customer Number): Denied "controlled all aspects" but request didn't ask about "all aspects." - Request #14 (S-signature): Same "no recollection" issue despite evidence of usage.
From: Aaron H. Gould agould@connellfoley.com
To: Richard Litman rclitman@gmail.com
Subject: RFA Responses + AR Promise
Substance: Gould promises: "NGM will provide a AR report. I will send it once received."
Admissions / Inconsistencies: - UNMET PROMISE: This is one of several "will provide" or "will send" commitments that were either delayed or not delivered. - Marks the pattern of rolling promises without date certain (addressed in 2/27 Good Faith Deficiency Letter).
From: Aaron H. Gould agould@connellfoley.com
To: Richard Litman rclitman@gmail.com
CC: Leo J. Hurley, Jr. LHurley@connellfoley.com
Subject: RE: Litman v Goldberg 524343/2025 - Customer No. 37833
Substance: Goldberg's deposition was scheduled for 2/24/2026 at 10:00 AM. Litman sent Zoom credentials. Goldberg did not appear. Gould's response: "We cannot advise you on how to respond to the Bill of Particulars or on how or when to serve a document demand."
Admissions / Inconsistencies: - EVASION: Gould declines to address the Customer Number 37833 question directly. - PATTERN: Customer Number 37833 requested 4+ times (Jan 30, Feb 10, Feb 24, Mar 9); repeatedly denied or evaded. - ADMISSION: By refusing to produce CN-37833 records and then failing to appear at deposition, Gould/Hurley signal that the records either (a) incriminate Goldberg's direct control over Litman name use, or (b) do not exist and Defendants cannot produce them (discovery violation).
From: Aaron H. Gould agould@connellfoley.com
To: Richard Litman rclitman@gmail.com
CC: Leo J. Hurley, Jr. LHurley@connellfoley.com
Subject: RE: NYSCEF Notification: Kings - Torts - Other -
Substance: Gould responds to Bill of Particulars by arguing: "Defendant does not control these public records, which are equally accessible to Plaintiff. Patents are issued publicly by the USPTO and are available on their website. You are required to articulate your claim in response to the Bill of Particulars."
Admissions / Inconsistencies: - INCONSISTENCY: Directly contradicts Finding #38 and later discovery (16+ POAs personally signed by Goldberg; Goldberg is primary contact for CN-37833). - ADMISSION AGAINST INTEREST: By claiming "Defendant does not control" the USPTO records, Gould implicitly acknowledges that Plaintiff's name appears on those records (otherwise there would be no control issue). - EVASION OF BOP: Gould deflects responsibility for articulating the defenses rather than addressing the substance.
From: Richard Litman rclitman@gmail.com
To: Aaron H. Gould, Leo J. Hurley
Subject: Good Faith Deficiency Letter
Deadline to Cure: March 4, 2026
Substance: Formal deficiency letter citing three categories: 1. "Rolling Basis" evasion — open-ended promise without date certain. 2. "Public Information" objection — invalid under NY law for docs in defendant's possession. 3. Improper boilerplate objections — without specific prejudice shown.
Admissions / Inconsistencies: - Litman documents that Gould/Hurley have used discovery delay tactics and improper objections. - Pattern of "we will provide" without deadlines signals bad faith.
From: Leo J. Hurley, Jr. LHurley@connellfoley.com
To: Richard Litman rclitman@gmail.com
Subject: Response to Deficiency Letter
Substance: Hurley responds with a condescending lecture:
Your status as a Pro Se Plaintiff does not change your status as a member of the bar (albeit of Virginia) with decades of practice experience, and your status as a member of the bar shows sophistication beyond that of an ordinary pro se. The Courts know and recognize the import of this reality -- as a matter of fact, and of law.
You'll be provided with proposed dates for our client's deposition as described by Aaron and informed by the Court's CMO -- not by your whim.
Be guided accordingly.
Admissions / Inconsistencies: - UNPROFESSIONAL TONE: Hurley's response is condescending and threatening ("Be guided accordingly"). - IMPLICIT ADMISSION: Hurley acknowledges that deposition dates have not yet been provided and that Defendants control the timeline ("informed by the Court's CMO"). - PRESSURE TACTIC: The reference to Litman's bar status appears designed to intimidate.
From: Aaron H. Gould agould@connellfoley.com
To: Richard Litman rclitman@gmail.com
CC: Leo J. Hurley, Jr. LHurley@connellfoley.com
Subject: RE: Good Faith Reply to Deficiency Letter
Substance: After push-back on rolling production, Gould commits: "We have determined that we will be in a position to make our first rolling production to you on or before March 24. We intend to substantially complete all rolling productions by April 10."
Admissions / Inconsistencies: - ABOUT-FACE: Only after formal Good Faith letter does Gould provide date-certain commitments. - ADMISSION: Earlier "rolling basis" language was deliberately vague to delay production. - April 10, 2026 deadline is 6 days before this catalog is compiled (4/16/2026). Verify compliance.
From: Aaron H. Gould agould@connellfoley.com
To: Richard Litman rclitman@gmail.com
CC: Leo J. Hurley lhurley@connellfoley.com
Subject: Litman v Goldberg 524343/2025 - Fedex received today
Substance: Gould delivers a hard drive with 905 patents bearing Plaintiff's name. Gould's letter includes this critical statement:
"I note that your access to your two NGM e-mail accounts has never been revoked and you have been able to access these e-mails at all relevant times."
CRITICAL ADMISSIONS: 1. Acknowledgment of Two NGM Email Accounts: Gould explicitly confirms Plaintiff had two NGM email accounts (likely rlitman@nathlaw.com and rlitman@something-else). 2. Access Never Revoked: Gould states unequivocally that "access ... has never been revoked." 3. "At all relevant times": Extends the admission across the entire dispute period.
Contradictions & Implications: - Finding #23 (July 18, 2025 Email Elimination): If access was never revoked, why did 8,024+ emails continue landing in "eliminated" accounts through December 2025 (Finding #106)? - Retaliation Theory: The July 2025 email elimination (post-litigation threat 6/26/2025) appears retaliatory if Gould acknowledges access remained technically available. - Stored Copies: Gould's admission that emails continued to arrive implies NGM's email system was forwarding or storing Plaintiff's incoming mail even after the July 18 deletion.
This single sentence defeats any defense that Plaintiff was cleanly separated from NGM systems or that access was properly revoked.
Hard Drive Content:
- 905 patents bearing Plaintiff's name issued since 6/15/2020.
- Majority issued after 6/14/2023 (post-Amendment period).
- Many both filed and issued after Amendment date.
- Multiple documents show Goldberg's personal involvement.
- Disk password: 9Nn%?-gUy^aU*qx8; zip: DF4CmuJFO?4H+WW9
From: Richard Litman rclitman@gmail.com
To: Aaron H. Gould agould@connellfoley.com
CC: Leo J. Hurley lhurley@connellfoley.com
Subject: Litman v Goldberg 524343/2025 - Fedex received today
Substance: Plaintiff acknowledges receipt and notes he lacks a connector to read the drive but will review before sending responses to outstanding discovery. Plaintiff also asks: "Is your firm continuing to represent NGM?"
Admissions / Inconsistencies: - Gould does not directly answer whether the firm represents NGM (evasion). - Litman's question implies uncertainty about scope of representation (Goldberg vs. NGM vs. both).
Aug 2025: Pre-Litigation - Aug 16-17: Kuwait business opportunity (Litman still generating revenue for NGM).
Dec 2025 - Jan 2026: Post-Litigation / Early Discovery - Dec 8-22: Federal case motion filings and Rule 11 threats. - Jan 5-23: Federal case voluntary dismissal; state case Answer filed; Q4 2025 financial records produced.
Feb 2026: Discovery Disputes - Feb 10-24: Discovery sequencing disputes; Customer Number 37833 requests (repeatedly denied); deposition no-show. - Feb 27: Good Faith Deficiency Letter served.
Mar 2026: Production Pressure + Capitulation - Mar 1: Hurley's condescending response. - Mar 4, 10: Gould's response letter; March 24 / April 10 production deadlines committed. - Mar 16-17: Hard drive delivery with email-access admission. - Mar 19: Scott Woller (Wachtel Missry LLP) recorded as counsel.
| Date | Promised Item | Promised By | Status (as of 4/16/2026) |
|---|---|---|---|
| 9/3/2025 | 2024 accounting | Gould | NOT DELIVERED — 7 months overdue |
| 9/3/2025 | litman@4patent.com domain issue response | Gould | NOT DELIVERED — 7 months overdue |
| 9/3/2025 | Proposed use agreement response | Gould | NOT DELIVERED — 7 months overdue |
| 2/17/2026 | AR report | Gould | Delayed (promised "once received") |
| 3/10/2026 | First rolling production | Gould | Due 3/24/2026 — pending (6 days before catalog compiled) |
| 3/10/2026 | Substantially complete rolling productions | Gould | Due 4/10/2026 — pending (6 days before catalog compiled) |
Inference: Non-delivery of the three September commitments is itself evidence that Defendants either (a) lack the documents, (b) know they incriminate them, or (c) are engaged in discovery delay tactics.
Customer Number 37833 Refusals: - Jan 30, 2026: "Acknowledge receipt + CN-37833 request" — Gould promises "meet and confer next week." - Feb 10, 2026: "Discovery Sequencing Dispute" — Litman notes "at least my third or fourth request." - Feb 24, 2026: Goldberg deposition no-show; Gould declines to advise on follow-up. - Mar 9, 2026: Unresolved despite Mar 4 Good Faith response.
Email Account Access Evasion: - Gould claims (3/16/2026) access "never revoked." - Yet 8,024+ emails post-elimination (Finding #106). - Yet July 18, 2025 deletion (Finding #23). - Contradiction suggests deliberate withholding of email access records.
"Public Information" Objection: - Gould asserts patents are public; therefore not Defendant's responsibility. - Yet Gould refuses to identify which patents bear Litman's name on CN-37833 (implying Defendants control the categorization).
The 2024 Accounting — Gould promised follow-up; none sent. Demand: All 2024 monthly financial statements, trial balance, general ledger entries, trust account reconciliations, and client account allocations. (Umbrella: output/DISCOVERY_DEMAND_FEE_SCHEDULES_20260416.md Requests 1–5.)
Litman@4patent.com Email Domain Issue — Gould promised written response; none sent. Demand: (a) All correspondence regarding domain ownership, control, and licensing; (b) All internal NGM/Connell Foley discussions of the domain issue; (c) All draft agreements concerning the domain; (d) Current WHOIS registration, DNS records, and access credentials.
Proposed Use Agreement — Gould promised response after client consultation; none sent. Demand: (a) All drafts of any "use agreement" or similar instrument; (b) All internal correspondence discussing the agreement; (c) All client advice regarding the agreement; (d) Any alternative language considered; (e) Dates on which each draft was created/revised.
Email Never Revoked (Gould 3/16/2026) — Demand all records showing: (a) When access was granted to rlitman@nathlaw.com and second account; (b) Whether access was ever restricted, revoked, or re-granted; (c) Forwarding rules, deletion rules, or archive settings; (d) IT tickets or helpdesk records relating to Litman's accounts; (e) Email retention policies in effect during July 18 - December 2025.
8,024+ Post-Deletion Emails (Finding #106) — Demand all server logs, backup tapes, and archive records showing emails delivered to Plaintiff's eliminated accounts after July 18, 2025. If Gould claims access never revoked, these records should be producible.
$1.4M Unidentified AR (Feb 21, 2026 Litman analysis) — Demand: (a) Detailed list of 477 matters with no client name; (b) Invoice-by-invoice breakdown; (c) Client reconciliation explaining why client names are missing; (d) Explanation of why all balances are >120 days past due; (e) Explanation of $0 collections; (f) Trust-to-operating transfer detail.
Rolling Productions (March 24 / April 10) — Verify that Gould's March 10 commitment was met. If not, note non-compliance and file motion to compel.
output/EXHIBIT_GOULD_20250903_ADMISSIONS.md (detailed analysis of three Gould admissions).output/DISCOVERY_DEMAND_GOULD_ADMISSIONS_20260416.md (targeted requests derived from 9/3/2025 email).output/GOULD_HURLEY_EMAIL_CORRESPONDENCE.md (thread-level analysis of 49 emails).output/OPPOSING_COUNSEL_TIMELINE.md (chronological summary with source citations).feedback_counsel_admissions.md (uncle's framing principle re: counsel admissions as discovery leverage).9/3/2025 Gould Email Not in ND0001/ND0002: The dispositive "proposed use agreement" email is held only by Plaintiff. Action: (a) Verify whether email is in native .msg/.eml form in discovery_production/ under a different thread header; (b) Re-run full-body grep for "proposed use agreement" once Open Gap #8 (full-body email extraction, 276,899 emails) completes; (c) If not found, file supplemental discovery request demanding all Connell Foley/Plaintiff correspondence dated 9/1–9/10/2025 relating to admissions or unresolved issues.
Follow-Up Responses to Sept 3 Admissions: Demand all Connell Foley correspondence sent to Plaintiff on or after 9/3/2025 that purports to respond to (a) the 2024 accounting, (b) the 4patent.com domain issue, or (c) the proposed use agreement. Finding: None located as of 4/16/2026.
"Proposed Use Agreement" Drafts: No drafts located in corpus. Action: File demand (Request No. 21, output/DISCOVERY_DEMAND_GOULD_ADMISSIONS_20260416.md).
The three Gould admissions (9/3/2025) and the access-never-revoked admission (3/16/2026) operate at different legal levels:
4patent.com domain issue = contemporaneous acknowledgment of dispute
Procedural Admissions (3/16/2026):
Supports spoliation claim
Bad Faith Admissions (Feb-Mar 2026):
At dispositive motion stage: Each admission should be quoted directly in opposition briefs, with Gould's signature block and date as authentication. Federal Rule of Evidence 801(d)(2) and CPLR § 4514 make these admissible without need for testimony. Defendants cannot later disclaim counsel's representations.
Catalog Compiled By: Claude Code
Compiled Date: 2026-04-16
Status: Complete (49 emails catalogued; 3 critical admissions flagged; 23 discovery targets identified)
Next Steps: Verify March 24 / April 10 production compliance; file supplemental demand for 9/3/2025 follow-up responses; prepare Gould admissions for dispositive motion use.