Case: Litman v. Goldberg, Index No. 524343/2025 Prepared: April 14, 2026 Purpose: Targeted discovery requests based on gaps in our evidence and known concealment patterns
The operative date is June 15, 2020. All requests should be framed from June 15, 2020 to present unless a specific legal basis exists for earlier material. Pre-SOL documents are only relevant where they:
Key SOL sub-periods: | Period | Significance | Strength | |--------|-------------|----------| | 6/15/2020 – 6/14/2023 | Pre-arbitration SOL window | Moderate — establishes pattern | | 6/14/2023 – 7/21/2024 | Post-arbitration to SOL-safe | Strong — post-Award conduct | | 7/21/2024 – present | Post-SOL-safe | Strongest — beyond any tolling argument |
Every request below specifies the exact date range and identifies which SOL sub-period it targets.
What: All records for Freedom Bank of Virginia accounts 220001028 and 220001002 — statements, deposit slips, wire confirmations, signature cards, and closure documents — from June 15, 2020 through account closure (July 28, 2025).
SOL note: The accounts were operational throughout the entire SOL period. The earliest post-SOL Freedom Bank email is Dec 14, 2020 (Sharjah wire — Finding #99). The account was closed July 28, 2025 — entirely within the SOL window. Pre-SOL opening documents are relevant to show when the concealment began.
Why they have to produce it: We already have: - NGM's own Trust Register Report (7/2/2025) showing $24,495.15 balance in account 028 - The 7/22/2025 "Close Account" wire memo ($24,495.15 to BOA) - The 5/6/2017 Amendment expressly transferring "exclusive ownership" of Freedom Bank accounts to NGM - Litman's 2/9/2024 written demand to close or remove his name - 31 dates of Freedom Bank wire notifications in the email archive (post-SOL) - Litman actively directing wires as late as Dec 2023 (Finding #113)
What it proves: Every client deposit routed through the undisclosed trust account during the SOL period — proving systematic concealment from Exhibit A.
Subpoena target: Freedom Bank of Virginia, (703) 242-5300, wire sequence 78568.
What: ALL monthly Payment Allocation Reports from June 2020 through present. We have Oct 2023–Jun 2025 (21 months). We're missing: - June 2020 – September 2023 (~40 months) - July 2025, August 2025, September 2025 (almost certainly suppressed — Finding #50) - October 2025 through present (~6 months)
SOL note: Every missing month is within the SOL period. The June 2020 start aligns precisely with the SOL cutoff. Pre-SOL reports (if they exist) are not requested.
Why they have to produce it: The July 2025 report was generated 8/11/2025 and withheld until April 2026 — active concealment, not oversight. These are generated monthly by Soluno. They exist.
What it proves: The complete 20% formula validation across the entire 5+ year SOL window and quantifies total underpayment.
What: Complete statements, wire confirmations, and transfer records from June 15, 2020 through present for BOA account ending 8751 — the international wire receipt account NOT included in Exhibit A.
SOL note: Entirely within SOL period. Middle East client wires are the core revenue stream — KFU alone is #1 patent-granting university globally (Finding #60).
Why they have to produce it: This account received Middle East client wires (KFU, KSU, UAEU, etc.) but was excluded from the Schaefer/Kren accounting. Every wire is a Litman-originated revenue event.
What it proves: The full scope of international client receipts during the SOL period that were never reported to Litman.
Subpoena: Bank of America, ABA 026009593, account 003926278751.
What: Complete statements from June 15, 2020 through present for the BOA operating account — where trust-to-operating transfers land.
SOL note: Entirely within SOL period. All 69 "Uncredited" trust-to-operating transfers (Finding #64) are post-SOL.
Why they have to produce it: Finding #64 shows ALL 69 reconciled trust-to-operating transfers are flagged "Uncredited" to Litman. The operating account shows where the money went after leaving trust.
What: Complete statements from June 15, 2020 through present for the SECOND Eagle Bank account (different from Eagle Bank Trust ****0495 in Exhibit A). Documented via IMG_1427 — July 7, 2025 incoming wire from Alinma Bank/Saudi Arabia.
SOL note: The July 7, 2025 wire is deep into the post-SOL-safe period.
What: Full Soluno export from June 15, 2020 through present including: - Client ledger cards for ALL clients with any activity in the SOL period - Matter-level billing detail for CN-37833 clients - Individual trust receipts by client/matter - Three-way reconciliation reports (if any exist) - The "t20 – Freedom Trust_1028" sub-ledger
SOL note: Scoped to SOL period. We have the "All 7digit Matters" export (6,643 matters, 98% Litman-originated) — but need the underlying per-client financial detail within the SOL window.
What it proves: Per-client diversion during the SOL period — which Litman clients had revenue that was never allocated to his 20%.
What: Complete USPTO Patent Center change history for Customer Numbers 37833 (patent) and 24396 (trademark) — all modifications from June 15, 2020 through present. All login records, IP addresses, timestamps.
SOL note: The CN-37833 name removal on May 1, 2025 (Finding #107) is in the post-SOL-safe period. Earlier modifications during the SOL period establish the pattern.
What it proves: The systematic erasure timeline — who changed what and when within the SOL window.
What: Any and all documents evidencing Litman's consent, authorization, or instruction to Goldberg to sign Powers of Attorney on Litman's behalf after June 15, 2020.
SOL note: All 16 Goldberg-signed POAs are post-SOL. The most recent confirmed signature is January 17, 2025; the latest filing is June 25, 2025 (Finding #79). The date range perfectly matches the SOL window.
Why they have to produce it: Goldberg's Answer ADMITS the name appeared but DENIES he "caused" it (¶33). If he had post-SOL authorization, produce it. If he can't — causation is proven.
What it proves: The absence of any post-SOL authorization document is itself dispositive.
What: Full native export (.pst or .mbox) of the litman@4patent.com mailbox from July 18, 2025 through present.
SOL note: Entirely in the post-SOL-safe period. Every email is a post-litigation-trigger use.
Why they have to produce it: Finding #106 proves 7,519 emails arrived at litman@4patent.com between July 21 and December 31, 2025. The account was NOT eliminated — Litman's access was cut while NGM continued receiving his mail.
What it proves: (a) The "elimination" was a lie; (b) NGM was intercepting Litman's mail; (c) Every client communication is a separate § 51 use within the strongest SOL sub-period.
What: All website CMS logs, change history, and modification records for nathlaw.com from June 15, 2020 through September 5, 2025 (date Litman was fully removed).
SOL note: The website displayed Litman's name throughout the entire SOL period — from 6/15/2020 through at least 8/23/2025 (Wayback — Finding #75). The June 10, 2025 removal demand through September 5 removal spans the strongest sub-period.
What it proves: (a) When Litman's name was first posted, modified, or updated post-SOL; (b) Deliberate delay after the June 10 removal demand; (c) Who controlled the website content.
What: Microsoft 365 tenant admin logs for nathlaw.onmicrosoft.com — from June 15, 2020 through present — all mailbox modifications, forwarding rules, auto-reply configurations, account creation/disabling/enabling for: - litman@4patent.com - rlitman@nathlaw.com - rlitman@litmanlaw.com - All @4patent.com and @litmanlaw.com aliases active during the SOL period
SOL note: The 91 email aliases (Finding #110) operated continuously through the SOL period. The July 18, 2025 "elimination" and the Aug 21 auto-reply (Finding #112) are in the strongest sub-period.
What: All DNS zone files, DKIM records, MX records, SPF records, and domain registration correspondence from June 15, 2020 through present for 4patent.com and litmanlaw.com.
SOL note: Both domains were operational throughout the SOL period. DKIM points to nathlaw.onmicrosoft.com (Finding #43). The 4patent.com domain expires May 27, 2026 — registrant updated July 16, 2025 (2 days before email elimination).
What: Complete docket files for all trademark dockets listing Litman as attorney/correspondent with any activity from June 15, 2020 through present, including: - Section 8/9/15 declarations signed after 6/15/2020 - TTAB proceeding filings after 6/15/2020 - TUFFKOTE (SN 90830083) — filed 7/15/2021, entirely post-SOL - Hashtag Sports letter dated 7/24/2025 (Finding #70) — latest confirmed name use
SOL note: 245 dockets, but request scoped to post-SOL activity only. Each post-SOL sworn declaration is a separate § 51 use. The latest confirmed: July 24, 2025 (Finding #70).
What: All professional liability insurance applications, renewals, and policies from June 15, 2020 through present where Richard C. Litman is listed.
SOL note: Goldberg signed the 7/6/2021 application listing Litman as "Of Counsel." Every annual renewal listing Litman within the SOL period is a separate commercial use.
What: All records from Goldberg's internal tracking system known as "The Pad" reflecting activity from June 15, 2020 through present.
SOL note: The Pad tracks Litman-originated matters. Scoped to SOL period. Each tracked matter where Litman's name was used is consciousness-of-attribution evidence.
What: ALL invoices sent to King Faisal University from June 15, 2020 through present.
SOL note: Finding #63 shows 2,457 KFU dockets billed without matching invoices ($1.02M). All post-SOL. KFU is the #1 patent-granting university globally — this is the largest single client relationship. The KFU universe totals $27.68M billed / $24.68M received (Finding #51 supplement).
What: All COBRA-related correspondence, election forms, notification letters, and premium payment records for Richard and Cheryl Litman from June 2025 through present.
SOL note: Entirely in the post-SOL-safe period. Benefits cut June 30, 2025; COBRA offered October 2 — 3+ months later (Finding #111). The 44-day statutory notification deadline was violated.
What: Payment Allocation Reports, trust account statements, and disbursement records from October 2025 through present.
SOL note: Deep in the post-SOL-safe period. The October 8, 2025 Fidelity payment ($135,947.69 — Finding #104) proves NGM continued collecting and allocating Litman's 20%. Q4 2025 and Q1/Q2 2026 quarterly payments should have been made but haven't been received.
What: Goldberg's personal bank statements showing distributions from NGM operating account to his personal accounts from June 15, 2020 through present.
SOL note: Faithless servant doctrine (Finding #67) potentially supports 100% disgorgement during the violation period. The SOL period IS the violation period.
What: Complete inbox for mlong@nathlaw.com from June 15, 2020 through present. She is the #1 sender (57,352 emails) and the operational center of the name-use pattern.
SOL note: Every post-SOL client email she sent through @4patent.com or @litmanlaw.com aliases, referencing Litman as attorney, is a dated § 51 commercial use within the SOL window. The deck-of-cards theory depends on individually-dated uses.
What: Complete inbox for hkline@nathlaw.com from June 15, 2020 through present (2,678 emails in our archives). Handles trademark matters under Litman's name.
SOL note: The trademark deck-of-cards (245 dockets, 748 USPTO emails — Finding #41) is primarily administered through Kline. Post-SOL declarations = post-SOL § 51 uses.
Identify every bank account (by bank name, account number, account type, date opened, date closed if applicable, and current balance) held by NGM, Nath & Associates PLLC, or any related entity that was open at any time from June 15, 2020 through present. (Forces disclosure of any accounts beyond the 5-7 we've found. Pre-SOL opening dates are relevant to show when concealment began, but the account must have been active during the SOL period.)
State the total revenue collected on matters originated by Richard C. Litman, by quarter, from Q3 2020 (starting June 15, 2020) through Q2 2026. (Forces them to commit to a number we can cross-check against the PARs. The SOL period spans exactly 24 quarters.)
Identify by name, email address, and date every person who signed a Power of Attorney listing Richard C. Litman as attorney of record after June 15, 2020, and state whether written authorization from Litman was obtained for each. (Locks in the POA causation within the SOL window. All 16 Goldberg POAs are post-SOL.)
State the date, method, and person responsible for each modification to the nathlaw.com website adding, modifying, or removing Richard C. Litman's listing from June 15, 2020 through September 5, 2025. (Captures both the initial post-SOL display and the delayed removal.)
Identify every email alias on the domains 4patent.com, litmanlaw.com, and nathlaw.com that was active at any time from June 15, 2020 to present, including the person or function associated with each alias and the date each alias was created, modified, or deactivated. (91 aliases across two Litman-named domains — each is a § 51 use vehicle.)
State whether the litman@4patent.com mailbox was deleted, disabled, forwarded, or modified on or about July 18, 2025, and identify the person who took each action and the M365 admin log entry for it. (Post-SOL-safe period. The answer to this interrogatory either admits interception or contradicts Finding #106.)
Identify every client who contacted NGM through the nathlaw.com contact form from June 15, 2020 to present, and state whether Richard Litman's name or photo appeared on the website at the time of each contact. (We already have Bennington (July 2025) and a second July 1 lead — Finding #116. This captures the full SOL-period list.)
Identify every patent application filed with the USPTO listing Richard C. Litman as attorney of record or on which a Power of Attorney naming Litman was filed from June 15, 2020 to present, including the application number, filing date, patent number (if issued), and the identity of the person who signed each POA or filing. (Expands beyond our 21 mapped patents to the full universe of post-SOL name uses.)
State the total amount paid to Richard C. Litman (by any method including W-2 wages, wire transfers, checks, or distributions) from June 15, 2020 through present, itemized by date and amount. (Cross-checks against the Fidelity account 645375268 payment timeline — Finding #104.)
Identify every trademark application, registration, or proceeding with the USPTO on which Richard C. Litman's name appears as attorney, correspondent, or representative that had any activity from June 15, 2020 to present. (Expands the 245 known dockets to the full trademark universe.)
| Target | What | Date Range | Why |
|---|---|---|---|
| Freedom Bank of Virginia | Accounts 220001028 + 220001002, full history | 6/15/2020 – 7/28/2025 (closure) | Undisclosed trust accounts — active entire SOL period |
| Bank of America | Account 003926278751 (wire receipt) + 2417 (operating) | 6/15/2020 – present | Unaccounted revenue during SOL period |
| Eagle Bank Corp | Account *3780 + *0495 | 6/15/2020 – present | Second undisclosed Eagle Bank account |
| GoDaddy/Registrar | 4patent.com + litmanlaw.com domain records | 6/15/2020 – present | Domain control proof during SOL period |
| Microsoft | M365 tenant logs for nathlaw.onmicrosoft.com | 6/15/2020 – present | Email account modification evidence |
| Kelly Benefits | COBRA administration records for Litman | 6/2025 – present | COBRA violation (post-SOL-safe) |
| Resourcing Edge | Benefits records for Litman | 6/15/2020 – 6/2025 | Pre-cutoff benefits during SOL period |
| USPTO OED | CN-37833 + CN-24396 modification audit logs | 6/15/2020 – present | Erasure timeline within SOL period |
| Fidelity Investments | Account 645375268 complete transaction history | 6/15/2020 – present | Payment timeline verification during SOL period |
| Grace/Schaefer/Kren CPA | All workpapers for the 6/26/2025 report | Workpapers only (report is post-SOL-safe) | Prove they knew about Freedom Bank and excluded it |
If they can't produce: - POA authorization post-6/15/2020 → causation proven for the entire SOL period - Freedom Bank records during the SOL period → spoliation inference - Missing PARs for any month in the SOL period → concealment inference - Website change logs during SOL period → deliberate delay inference
We already have enough to prove liability. What we're doing now is: 1. Closing the financial picture within the SOL period — every undisclosed account, every suppressed report, every diverted payment from June 15, 2020 forward 2. Proving concealment was deliberate during the SOL period — the Freedom Bank exclusion, the PAR suppression, the email "elimination" 3. Expanding the post-SOL name-use count — every trademark declaration, every client email, every @4patent.com alias use dated after June 15, 2020 4. Locking in deposition traps — each interrogatory answer becomes an admission or an impeachment target, all within the SOL window