Court: Supreme Court of the State of New York, County of Kings Index No.: 524343/2025 Assigned: Hon. Brian L. Gotlieb, J.S.C. Plaintiff: Richard C. Litman (Pro Se) Defendants: Joshua B. Goldberg; Nath, Goldberg & Meyer, PLLC Served upon: Aaron H. Gould, Esq., Connell Foley LLP, counsel for Defendants Date: April 16, 2026
Pursuant to CPLR §§ 3120 and 3124 and the Preliminary Conference Order entered in this action, Plaintiff Richard C. Litman hereby serves this Supplemental Demand for Production upon Defendants Joshua B. Goldberg and Nath, Goldberg & Meyer, PLLC ("NGM"). Defendants shall produce the documents described below, in the format specified in Section VII, within thirty (30) days of the date of service.
This Supplemental Demand is narrowly addressed to a discrete production deficiency: NGM has produced exactly one institutional client fee schedule — the 2018 and 2019 Appendix A / Quotation for the Kuwait Institute for Scientific Research ("KISR") (Bates C2051472_ND0000271385 and C2051472_ND0000271635) — while concurrently producing trust-account records, correspondence, invoices, and transmittal emails confirming that analogous per-matter fee schedules existed for NGM's other institutional clients during the Relevant Period. Those analogous schedules have not been produced.
The demand is material to damages under NY Civil Rights Law §§ 50–51 because the per-patent / per-matter rate paid by each institutional client is the empirical anchor for calculating the commercial value of the use of Plaintiff's name on each patent, USPTO filing, and client-facing communication.
For each of the following institutional clients, Defendants shall produce every Service Agreement, Engagement Letter, Appendix A, Rate Schedule, Quotation, Statement of Work, or similar document in effect at any time during the Relevant Period that sets or modifies the rates, flat fees, hourly rates, caps, or reimbursement terms for legal services rendered by NGM. The KISR documents at Bates C2051472_ND0000271385 and C2051472_ND0000271635 are the reference exemplars — Defendants are on notice of the document type demanded and cannot claim ambiguity.
Request No. 1 — King Faisal University (KFU). Produce the KFU Service Agreement, including every Appendix A, rate schedule, quotation, and amendment, from the original 2010 engagement through and including any 2024–2025 renewal, along with each document referenced, incorporated, or attached thereto. The 2024 general-purpose engagement letter at Bates C2051472_ND0000236084 is not responsive and does not satisfy this request.
Request No. 2 — King Saud University (KSU). Produce the KSU Service Agreement, Appendix A, rate schedule, and every written amendment, in effect at any time during the Relevant Period, including any document governing the December 22, 2022 wire transfer in the amount of $1,437,568 and the $129,680 payment referenced in Goldberg's March 6, 2023 correspondence.
Request No. 3 — United Arab Emirates University (UAEU). Produce the UAEU Service Agreement, Appendix A, rate schedule, and every written amendment, in effect at any time during the Relevant Period, including the document governing the $123,300 general-matter deposit and the task-based billing rates reflected in the NGM trust account records for UAEU.
Request No. 4 — Dasman Diabetes Institute. Produce the Dasman Diabetes Institute Service Agreement, Engagement Letter, and any document setting the hourly rate or other basis of billing corresponding to the "RATE: 'a'" designation reflected in NGM's internal client list, including all rate sheets and written communications fixing the hourly rate charged during the Relevant Period.
Request No. 5 — Kuwait University. Produce the Kuwait University Service Agreement, Appendix A, rate schedule, and any written amendment in effect at any time during the Relevant Period. The $11,300 per-patent flat fee quoted by Martha Long in November 2020 at Bates C2051472_ND0000004095–4098 is a written quotation; Plaintiff demands the underlying executed agreement, fee schedule, and any subsequent written modification of that rate.
NGM's production includes transmittal / cover emails from Martha Long attaching executed engagement letters for the following individual-inventor matters, but the attached PDFs themselves are absent from the production set. Pursuant to CPLR § 3122(c) and the Commercial Division's ESI guidance, Defendants shall produce the native .msg file for each parent email listed below together with every attachment in native format with load-file linkage preserved.
Request No. 6 — Moussa Moustafa engagement. Produce the native .msg file for Bates C2051472_ND0000176330 (transmittal of January 12, 2021 engagement letter, Docket 33087.00) with the attached engagement letter PDF in native form.
Request No. 7 — Adel Abdulla / ORGO engagement. Produce the native .msg files for Bates C2051472_ND0000177875 and C2051472_ND0000178849 (transmittal and follow-up of February 4, 2021 engagement agreement, Dockets 33089.00 and 33089.01) with each attached engagement letter and amendment PDF in native form.
Request No. 8 — Jonathan Martin engagement. Produce the native .msg files for Bates C2051472_ND0000231772 and C2051472_ND0000231781 (transmittal and signed-variant of December 29, 2022 engagement letter, Docket 200628.00S) with each attached engagement letter and executed counterpart PDF in native form.
Request No. 9 — KISR 2020 through 2025 updates. The produced KISR documents reflect an annual rate escalation from the 2018 Service Agreement ($15,000 per patent) to the 2019 Quotation ($16,000 per patent). Produce each subsequent Appendix A, Quotation, rate schedule, amendment, extension, or renewal of the KISR Service Agreement in effect at any time from January 1, 2020 through the present, including each document setting forth an escalated or revised per-matter rate.
Metadata enumeration across NGM's @4patent.com client-alias infrastructure identifies dedicated aliases and extensive email activity for the institutional clients listed below. For each, Defendants shall produce every Service Agreement, Appendix A, Rate Schedule, Quotation, Engagement Letter, or similar document in effect at any time during the Relevant Period.
Request No. 10 — Qatar Foundation (alias qf@4patent.com).
Request No. 11 — Sabah Al Ahmad Center for Giftedness and Creativity (alias sacgc@4patent.com).
Request No. 12 — Qatar University (alias qu@4patent.com).
Request No. 13 — Umm Al-Qura University (UQU) (alias uqu@4patent.com).
Request No. 14 — Sultan Qaboos University (SQU) (alias squ@4patent.com).
Request No. 15 — Arabian Gulf University (AGU) (alias agu@4patent.com).
Request No. 16 — King Abdulaziz University (KAU) (alias kau@4patent.com).
Request No. 17 — University of Sharjah (UOS) (alias uos@4patent.com).
Request No. 18 — Dasman Diabetes Institute (alias ddi@4patent.com) — to the extent any document responsive to Request No. 4 is also housed under this alias.
Request No. 19. Produce every internal NGM communication — including email, text, Teams / Slack / chat, memoranda, and meeting notes — that discusses, proposes, drafts, reviews, updates, approves, revises, escalates, or rejects any rate, fee, flat fee, hourly rate, cap, discount, escalation, or reimbursement term for any institutional client identified in Categories 1 and 4, at any time during the Relevant Period.
Request No. 20. Produce every communication between NGM (or any NGM employee, member, or agent) and any institutional client identified in Categories 1 and 4 that transmits, negotiates, confirms, accepts, rejects, or amends any Service Agreement, Appendix A, Rate Schedule, Quotation, or Engagement Letter at any time during the Relevant Period.
"Service Agreement" means any written agreement, memorandum of understanding, statement of work, letter of engagement, representation agreement, or similar written instrument governing the provision of legal services by NGM (or any predecessor or affiliate of NGM) to an institutional or individual client.
"Fee Schedule" means any written document — however titled, including without limitation "Appendix A," "Rate Schedule," "Quotation," "Rate Card," "Price List," "Fee Matrix," or any comparable designation — that sets, modifies, escalates, discounts, or otherwise fixes rates, flat fees, hourly rates, caps, retainers, advances, or reimbursement terms for legal or related services.
"Institutional Client" means any of the following entities: King Faisal University (KFU); King Saud University (KSU); United Arab Emirates University (UAEU); Dasman Diabetes Institute; Kuwait University; Kuwait Institute for Scientific Research (KISR); Qatar Foundation; Sabah Al Ahmad Center for Giftedness and Creativity; Qatar University; Umm Al-Qura University (UQU); Sultan Qaboos University (SQU); Arabian Gulf University (AGU); King Abdulaziz University (KAU); and University of Sharjah (UOS).
"Relevant Period" means June 15, 2017 through the present. The June 15, 2017 start date corresponds to the commencement date of the Combination Agreement and is necessary to capture the original KFU, KSU, UAEU, and KISR engagement documents carried into NGM. The "present" end date is necessary because NGM has continued to bill these institutional clients through the date of this Demand.
"Document" has the meaning set forth in CPLR § 3120 and includes, without limitation, every electronic record in native format with associated metadata preserved.
"Native Format" means the file format in which the document was originally created, maintained, and stored in the ordinary course of business, with all metadata, hidden text, comments, tracked changes, and embedded attachments intact.
.msg files shall be produced in native format with full header metadata and all attachments intact, linked by load file.Custodian, Sent Date, From, To, CC, Subject, Attachment Names, MD5Hash, and File Path shall be populated for every record.Plaintiff is prepared to meet and confer in good faith concerning the scope, phasing, or technical format of this Supplemental Demand before seeking relief from the Court under CPLR § 3124. Plaintiff requests a written response identifying, for each numbered request, whether Defendants (a) will produce, (b) will produce subject to stated objections, or (c) refuse to produce. Any objection must specify the documents being withheld and the basis for the objection with particularity sufficient to permit resolution without judicial intervention.
Absent a complete response and production within thirty (30) days, Plaintiff will move to compel and for such other relief as the Court deems just, including costs and an adverse inference consistent with CPLR § 3126.
Dated: April 16, 2026
Respectfully submitted,
Richard C. Litman Plaintiff, Pro Se [Address] [Telephone] [Email]
Via Email and First-Class Mail
Aaron H. Gould, Esq. Connell Foley LLP [Firm Address]
Re: Litman v. Goldberg, Index No. 524343/2025 (Sup. Ct., Kings Cnty.) — Supplemental Demand for Production of Institutional Client Fee Schedules and Engagement Letter Attachments
Dear Mr. Gould:
Enclosed please find Plaintiff's Supplemental Demand for Production, served today pursuant to CPLR §§ 3120 and 3124. The Demand is limited in scope to a specific production deficiency: Defendants have produced the 2018 and 2019 KISR Appendix A / Quotation (Bates
C2051472_ND0000271385andC2051472_ND0000271635) but have not produced the analogous Service Agreements, Appendices A, rate schedules, or executed engagement letters for NGM's other institutional clients, nor the PDF attachments to five identified Martha Long transmittal emails.Given that the per-matter rate is a direct input into the damages calculation under Civil Rights Law §§ 50–51, prompt production is requested. Plaintiff is available to meet and confer regarding scope, phasing, or technical format before any motion practice. Please advise by [date + 14 days] whether Defendants will produce responsive documents within the thirty-day period or whether a meet-and-confer conference is necessary.
Thank you for your attention to this matter.
Very truly yours,
Richard C. Litman Pro Se