TO: Litigation Counsel for Richard C. Litman FROM: Litman Case Support Team RE: Supplemental Discovery Demands Package — Litman v. Goldberg, Index No. 524343/2025 DATE: April 7, 2026
Five supplemental discovery demands are ready for service on Goldberg's counsel. Together, they are designed to convert the financial and infrastructure portions of the case from estimated to documented before the rescheduled Goldberg deposition. Each demand is narrow, targeted to specific records whose existence is already established by documents in our possession, and calibrated to withstand a "fishing expedition" objection.
If served simultaneously, the 30-day response window closes on or about May 8, 2026, leaving roughly four weeks of margin before the June 2, 2026 deposition cutoff to review productions, draft impeachment exhibits, and (if necessary) move to compel.
File: output/DISCOVERY_DEMAND_SOLUNO_TRANSACTION_EXPORT.md
Demands a complete transaction-level export from NGM's Soluno billing/accounting platform for all matters keyed to Litman Attorney Number 418, Customer Number 37833, and the KFU/KSU/KNPC/UAEU client families, from June 15, 2020 forward. This is the source-of-truth ledger behind the workup spreadsheets Goldberg's counsel has already produced. It will expand the currently authenticated $1.98M figure to an exact, line-itemized total and expose any client-renumbering entries used to bypass the 418 allocation.
File: output/DISCOVERY_DEMAND_AUG_SEP_2025_REPORTS.md
Demands the monthly Litman allocation reports for August and September 2025 — the two months immediately following the July 18, 2025 email-account elimination. These reports either exist (in which case they should have been produced months ago) or do not (in which case the gap itself is evidence of active concealment during the litigation-trigger window). Either answer advances the case.
File: output/DISCOVERY_DEMAND_JULY_2025_WIRE_RECORDS.md
Demands the underlying bank wire confirmations, trust-account disbursement records, and check images corresponding to the $40,768.39 July 2025 figure shown on the recovered allocation report. This is a binary test: either Litman was actually paid that amount, or the report is a paper entry with no corresponding transfer. Both outcomes are usable.
File: output/DISCOVERY_DEMAND_M365_ADMIN_LOGS.md
Demands the M365 tenant admin logs for nathlaw.onmicrosoft.com showing creation, modification, and deletion dates for every alias on the 4patent.com domain — including kfu@4patent.com, litman@4patent.com, and any alias used by Goldberg personally. Combined with the DKIM evidence, this proves when Goldberg took operational control of Litman's domain and supports willfulness on the § 51 claim.
File: output/DISCOVERY_DEMAND_MISSING_ALLOCATION_REPORTS.md
Demands the three missing monthly allocation reports from the early post-arbitration period (July, August, September 2023). Lower urgency than the others, but necessary to close the financial timeline so that opposing counsel cannot cherry-pick a partial record at trial.
Serving these demands now — rather than waiting for the deposition to expose the gaps — preserves the option to use the productions as deposition exhibits and cross-examination foundation. Waiting forfeits that option.
| # | Demand | Priority | Why |
|---|---|---|---|
| 1 | Soluno Transaction Export | Highest | Converts authenticated $1.98M to exact ledger figure; exposes renumbering scheme |
| 2 | Aug/Sep 2025 Reports | High | Locks in active-concealment narrative during litigation-trigger window |
| 3 | July 2025 Wire Records | High | Binary test on whether $40,768.39 was actually paid |
| 4 | M365 Admin Logs | Medium-High | Establishes alias-creation timing; supports willfulness |
| 5 | Jul–Sep 2023 Reports | Medium | Closes early gap; completes financial timeline |
Serve all five simultaneously. Splitting them invites Goldberg's counsel to negotiate them down one at a time. Served as a package, they create a single 30-day response clock and a single meet-and-confer window, maximizing document-production pressure and minimizing tactical delay.
| Objection | Response |
|---|---|
| "Overbroad / fishing expedition" | Each demand identifies specific records by name, system, date range, and matter number. We are asking for documents whose existence is already established by other documents already produced. |
| "Burdensome" | Soluno exports and M365 admin logs are produced by clicking "Export." The burden argument fails on the face of the platforms involved. |
| "Not relevant to surviving Count V" | Financial records are directly relevant to Civil Rights Law § 51 damages (commercial value of name-use). The Court has already found Count V survives; damages discovery is in scope. |
| "Already produced" | The demands are framed to flush out exactly what was and was not produced — any "already produced" response must be itemized, which itself narrows the dispute. |
| "Privilege / work product" | None of the demands seek attorney communications. They seek transactional ledgers, wire confirmations, allocation reports, and admin logs — all business records. |
| "Possession, custody, control" | Goldberg is the managing member; the platforms are licensed to NGM; control is not seriously disputable. |
None of these demands is speculative. Each one is anchored to a document already in our possession:
The recovery of the July 2025 allocation report alone justifies the entire package: it proved the reports exist, that Goldberg's side has been generating them, and that selective production is occurring. Every demand here is built on documentary foundation.
Served together, these five demands convert the case from estimated to documented across every dimension that currently rests on inference: the exact damages figure, the timing of infrastructure control, the question of whether Litman was actually paid for July 2025, and the active-concealment narrative for the litigation-trigger window. They are ready for counsel signature and service.
— End of Transmittal —