Comprehensive rescan of EMAIL_METADATA_ND0001.csv (181,571 rows) and EMAIL_METADATA_ND0002.csv (95,330 rows) against all key terms from Findings #1–#108.
Counts: ND0001: 406 | ND0002: 39 | Total: 445
Direct bank wire notifications (wires@freedom.bank / info@freedombankva.com): - 31 unique dates of direct Freedom Bank wire notifications found, spanning 2020-01-08 through 2025-07-22 - Last incoming wire: 2024-05-07 (KSU $129,680 — matches Finding #102) - Outgoing wire (the spoliation wire): 2025-07-22 — 6 duplicate copies of the "Close Account" $24,495.15 wire, all sent to litman@4patent.com (an account NGM had "eliminated" 4 days earlier) - Earliest post-SOL: 2020-12-14 (Sharjah wire — matches Finding #99) - Gap pattern: Active incoming wires 2019-2021, then dormant until 12/28/2022, then 12/26/2023, then 5/7/2024, then the final closure wire 7/22/2025
NEW: ND0002 reveals Litman actively directing Freedom Bank wire handling: - 2023-12-26: Litman → Goldberg, subject "Please handle Incoming Wire" (forwarding Freedom Bank incoming wire notification) - 2023-12-27: Follow-up from Litman on same - This is direct documentary proof Litman was managing Freedom Bank wires as late as December 2023, 19 months before Goldberg closed the account
Martha Long forwarding pattern: Multiple Freedom Bank wire notifications forwarded to Accounting, Valencia Gray, Kimberly Thompson — with CC to client aliases (ku@4patent.com, kfu@4patent.com, uaeu@4patent.com). This connects Freedom Bank wires directly to Litman-originated Middle East clients.
Counts: ND0001: 1,867 | ND0002: 376
The high count is driven by false positives (emails containing "close" and "account" separately). The actual "Close Account" Freedom Bank wire is captured in the 6 copies above under the Freedom Bank search. No additional "close account" spoliation evidence found beyond what is already documented.
Counts: - CN-37833 mentions: ND0001: 2,735 | ND0002: 223 | Total: 2,958 - CN-24396 mentions: ND0001: 56 | ND0002: 39 | Total: 95 - "Customer number": ND0001: 2,732 | ND0002: 77
CN-37833 is entirely USPTO PAIR correspondence notifications — daily automated emails from PAIR_eOfficeAction@uspto.gov sent to uspto@4patent.com, uspto@nathlaw.com, and (until ~Aug 2021) tharkins@nathlaw.com and litman@4patent.com. These 2,958 emails are each a separate § 51 "publication" under the deck-of-cards theory — every single one bears Litman's Customer Number and was routed through his 4patent.com domain.
CN-24396: The 95 hits are false positives (marketing emails containing "24396" as part of other numbers). No direct CN-24396 trademark correspondence found in the metadata. The Nicola Pizza trademark routing through CN-24396 is confirmed through other evidence (Finding #72).
Counts: ND0001: 4 | ND0002: 3 | Total: 7
ND0001 hits are false positives (real estate ads from Bennington, VT area, ZenCase marketing).
ND0002 hits are the real evidence — July 7, 2025: - Martha Long → Howard Kline, "RE: Contact Form form submissions received!" (2025-07-07 09:06:08) — CC: clientservice@4patent.com - Howard Kline → Martha Long, "RE: Contact Form form submissions received!" (2025-07-07 09:13:44) - Body preview: "Thanks" / "Thank you"
NEW finding: The July 7 date is 5 days AFTER the July 2 date previously documented for the Bennington contact form. The nathlaw.com Contact Form submission itself came through clientservice@4patent.com — meaning Goldberg's website contact form was routing through Litman's 4patent.com domain as the intake infrastructure. This strengthens Finding #46 (4patent.com client alias infrastructure).
Also notable: A separate Contact Form submission exists on July 1, 2025 — Martha Long → Joshua Goldberg directly. This may be a different client contact form submission (NOT Bennington). Two contact form leads within one week, both routed through nathlaw.com/4patent.com infrastructure.
Counts: ND0001: 156 | ND0002: 67 | Total: 223
Most hits involve Martha Long correspondence with various SACGC contacts (Albannai family/associates). The Albannai relationship spans the entire post-SOL period.
NEW — ND0002 reveals an "Eng Mohammad Albannai" thread (Jan 2023): - Martha Long ↔ shkan1100@yahoo.com, "RE: Eng Mohammad Albannai" — 5 exchanges Jan 16-17, 2023 - This appears to be a referral or new matter for Mohammad Albannai routed through Martha Long, confirming ongoing Albannai family client relationship post-arbitration
The 223 total emails across both archives demonstrate the depth and continuity of the Albannai client relationship — a relationship built entirely under Litman's name.
Counts: ND0001: 28 | ND0002: 105 | Total: 133
KEY post-litigation emails (ND0002): - 2025-07-21 11:30 — Dvorkin → Martha Long, "FW: Docket 12201.02U" (day lawsuits filed) - 2025-07-21 12:24 — Dvorkin → Richard Litman directly, "Docket 12201.02U" (still writing to Litman personally) - 2025-07-21 20:59 — Richard Litman → Joshua Goldberg, "FYI: Docket 12201.02U" (Litman forwarding to Goldberg) - 2025-09-17 — Dvorkin → Martha Long, "RE: Final Office Action Notification for Lev Dvorkin -- Docket 12201.02U" - 2025-09-17 — Dvorkin → Richard Litman, "Final Office Action for Docket 12201.02U" (still writing to rlitman@nathlaw.com 2 months post-email-elimination) - 2025-09-18 — Dvorkin → Joshua Goldberg, "Docket No. 12201.02U" (the filing errors complaint — Finding #80) - 2025-09-19 — Goldberg → Dvorkin, "RE: Docket No. 12201.02U" (Goldberg's response)
NEW: The Sept 17 email from Dvorkin to rlitman@nathlaw.com is the FIFTH independent proof that rlitman@nathlaw.com was still active in September 2025 (stacking with Findings #40, #54, #80, #106). Dvorkin's pattern of writing to Litman first, then Martha, then finally Goldberg (only after errors) powerfully demonstrates the goodwill attached to Litman's name.
Counts: ND0001: 13 | ND0002: 10 | Total: 23
All emails are LinkedIn notifications sent to litman@4patent.com: - 2025-07-24 — Connection request: "I want to connect" - 2025-07-28 — LinkedIn notification: "You have 4 new invitations" - 2025-08-01 through 2025-08-04 — 5+ "Julia just messaged you" notifications (persistent outreach)
NEW: The persistent messaging pattern (at least 5 messages over 4 days in early August 2025) shows a prospective client actively trying to reach Litman through his LinkedIn profile — which was tied to litman@4patent.com. All messages landed in the mailbox that NGM was intercepting post-July 18. Stolyarova never received a response because Litman had no access. This is potential client harm from the email elimination.
Counts: - Al-Refaei: ND0001: 9 | ND0002: 37 | Total: 46 - Dasman: ND0001: 399 | ND0002: 795 | Total: 1,194
KEY thread (ND0002, Nov 2024): - Prof. Fahd Al-Mulla → Richard Litman + Joshua Goldberg, "Educational session on Patenting" (2024-11-06) - Litman → Goldberg, "How do u want to handle?" (2024-11-07 11:30) - Goldberg → Litman, "RE: How do u want to handle?" (2024-11-07 12:44) - Litman → Prof. Al-Mulla directly (2024-11-07 21:18) - Dr. Faisal H. Al-Refaei → Richard Litman, "Re: Educational session on Patenting" (2024-11-08 and 2024-11-12) - Litman → Dr. Al-Refaei (2024-11-08 13:05)
NEW: This thread confirms Litman was actively managing the Dasman Diabetes Institute relationship in November 2024 — 4.5 years post-"termination," 17 months post-arbitration. Al-Refaei wrote directly to Litman (not Goldberg). The 1,194 total Dasman emails across both archives show this is one of the largest client relationships in the firm, built entirely under Litman's name.
Counts: - Odland: ND0001: 1,213 (mostly false positives) | ND0002: 54 - Dakota: ND0001: 188 | ND0002: 37
ND0002 real hits — October 2024 Dakota Ag thread: - Martha Long → liam.lymn@dakotaaginnovations.com, "Trademark Information for Client 17392" (2024-10-08) - Lynn Odland → Howard Kline, "RE: Trademark Information for Client 17392" (2024-10-08) - Martha Long → Lynn Odland + Howard Kline (2024-10-09) - Lynn Odland → Martha + Howard (2024-10-09) - Howard Kline → Lynn Odland + Martha Long (2024-10-30)
Client number 17392 is Dakota Ag's NGM client number. The October 2024 trademark work confirms active client relationship in the post-SOL-safe period.
Counts: "origination": ND0001: 126 | ND0002: 208 | Total: 334
ND0001 hits are mostly false positives (Credit Union Times newsletters, banking marketing).
ND0002 hits are the critical accounting thread (June 2025): - 2025-05-30 — Litman → Goldberg, "Please provide" (starts accounting data request series) - 2025-06-02 through 2025-06-11 — Intensive Litman ↔ Goldberg accounting correspondence: - "Accounting Data Request - Need Specific Reports for Friday Review" - "Urgent Comprehensive Allocation Reconciliation and Review" - "Re: April 2023 to present" - "Many Significant Flagged Clients"
The June 24, 2025 "RCL origination credit" email (Finding #71, Martha Long → Docketing, Jovancevic docket) is confirmed in ND0002 with the subject "NEW CASE/NEW CLIENT-- General Matter -- 201081.00G/201081 -- Client Number" at 2025-06-24 06:39:35.
Counts: ND0001: 30,374 | ND0002: 3,287 | Total: 33,661
41 unique @litmanlaw.com email aliases identified across both archives: admin, allforms, amuratori, arabanalytics, aragonese, arlitman, awalker, bowens, dapley, dhodgesrlitman, djohnson, docketing, drlitman, dtorrence, formattachmentsto, formsattachmentto, gainanalytics, hflournoy, hhernandez, hr, info, jbreckenridge, jlafave, josorio, ldunbar, ltdrlitman, martha, mlong, mthomas, noreply, nusman, quarantine, rapley, rforde, rjones, rlitman, rlyons, spalmore, voicemail, wkubitz
NEW: This is a SECOND domain alias infrastructure parallel to 4patent.com. Previously we documented 50 @4patent.com aliases (Finding #46). Now we have 41 @litmanlaw.com aliases. Combined, NGM operates 91 unique email aliases across TWO domains bearing Litman's name. The litmanlaw.com aliases include dedicated staff accounts (bowens, josorio, rforde, aragonese, jlafave, mlong, spalmore, hflournoy, etc.), functional accounts (docketing, hr, admin, voicemail, quarantine), and analytics accounts (arabanalytics, gainanalytics).
KEY staff aliases still active in 2024-2025: - josorio@litmanlaw.com — Juan Osorio (HR/office manager), receiving training emails through at least March 2025 - bowens@litmanlaw.com — Britney Owens, receiving insurance/training emails through Sept 2024 - rforde@litmanlaw.com — R. Forde, receiving marketing/training emails through Dec 2023
This expands the § 51 domain infrastructure theory significantly — Goldberg operates his entire firm's staff email infrastructure through a domain bearing Litman's personal name.
Counts: - TUFFKOTE: 0 in both archives - Hashtag: ND0001: 321 | ND0002: 36
Hashtag Sports key hit (ND0002): - TEAS@uspto.gov → hkline@nathlaw.com; rlitman@nathlaw.com; docketing@nathlaw.com; efile@4patent.com — "32662.00 Registration Number 4697459: Received Your Change Address or Representation Form" (2024-06-12) - Howard Kline → Anthony Caponiti (anthony@hashtagsports.com), "FW: TM Renewal due: U.S. Trademark Registration No. 4,697..." (no date visible)
The TEAS filing on 6/12/2024 CC'd rlitman@nathlaw.com — Litman's name appeared on the trademark filing correspondence more than a year after the arbitration decision.
Counts: "nicola": ND0001: 142 | ND0002: 303 | Total: 445
ND0002 contains the live client correspondence (2023-2025): - Angela Berry (aberry.nicolapizza@gmail.com) — client contact, active July 2025 - nicolapizza@nicolapizzarehobeach.com (Nicholas Caggiano) — trademark renewal correspondence Oct 2023 - TEAS@USPTO filings listing rlitman@nathlaw.com on CC for Nicola Pizza dockets 6217.09, 6217.14, 6217.15, 6217.30, 6217.50
NEW — July 2025 Nicola Pizza activity: - 2025-06-30: Angela Berry → Howard Kline, "Re: FW: Declaration of Use due in July 2025; THE ORIGINAL NIC-O-BOLI THE OVER-STUFFED SANDWICH and design; NGM Ref: 6217.50" - 2025-07-07: Angela Berry → Howard Kline, "Re: FW: Nicola Pizza: New Project: Taste of the 1st State"
The "New Project: Taste of the 1st State" email on July 7, 2025 shows Nicola Pizza was actively bringing NEW trademark work to NGM in July 2025 — during the period when Litman's name was still on all their trademark filings. This is a concrete example of ongoing commercial use of Litman's name attracting continuing client business.
Counts: 0 in both archives.
"Line 74" is a patent document term not used in email correspondence. Expected result.
Counts: ND0001: 3,696 | ND0002: 107 | Total: 3,803
ND0001 hits are overwhelmingly LinkedIn notifications showing Litman's LinkedIn profile listed him as "Senior Counsel" — each one a separate § 51 use.
ND0002 critical hits: - 2025-06-17 — Litman → Meyer + Goldberg, "Formal Notice of Contractual Extension and Preservation of Rights" (contains "Senior Counsel" in body) - 2025-06-26 — Heba Carter → Litman, "NGM--Matters" (NGM's own counsel acknowledging the dispute) - 2025-06-28 — Litman → Carter, "Re: NGM--Matters - Continued Use of My Name and Role as Senior Counsel (2017-2025)" - 2025-06-28 — Grace Clagett Kren auto-reply to same (CPA Kren was CC'd — same Kren/Schaefer who produced Exhibit A and omitted Freedom Bank) - 2025-06-30 — Carter → Litman, "RE: NGM--Matters - Continued Use of My Name and Role as Senior Counsel (2017-2025)"
NEW: The 3,696 LinkedIn notification count in ND0001 is significant — each is a notification triggered by someone viewing Litman's profile or interacting with his content, and each was sent to litman@4patent.com, demonstrating the LinkedIn profile was tied to the 4patent.com domain infrastructure.
Counts: ND0001: 253 | ND0002: 181
ND0001 hits are almost all false positives (Virginia Lawyers Weekly, insurance marketing).
ND0002 key hits: - Heba Carter (hcarter@gcpc.com) emails on 6/26 and 6/30/2025 — body preview references disability/insurance in the "NGM--Matters" thread - Goldberg → Litman, "Re: Another report please" (2021-12-20) — hit on disability+insurance, suggesting this thread discusses the disability/insurance intersection
Counts: ND0001: 19 | ND0002: 5 | Total: 24
The sarcastic Goldberg email (Finding #17, ND0002): - 2025-06-10 13:51 — Goldberg → Litman, "RE: Accounting Data Request - Need Specific Reports for Friday Review" (body: "Thanks..." — likely contains the "perhaps you should look into forensic accounting" line) - 2025-06-10 14:17 — Litman → Goldberg reply (body: "Josh...")
NEW — David Litman (uncle's brother) forensic accounting research: - 2025-08-29 — "Litman, David" (david.n.litman@wellsfargoadvisors.com) → unknown, "Well-regarded forensic accounting firms and professionals in New York and Virginia" - 2025-08-29 — Richard Litman → David Litman, "Re: Well-regarded forensic accounting firms..." (body: "Thanks David. Richard Litman Sent from my iPad")
David Litman is uncle's Wells Fargo wealth advisor/brother who was researching forensic accounting firms for the case in August 2025. This email was sent to litman@4patent.com — the "eliminated" account — and Litman responded from it, providing further proof the account was still functional.
Covered under item #2. The Freedom Bank wire memo "NGM Bank to Bank transfer Close Account" is captured in the 6 Bates-stamped wire emails already documented.
Counts: 4patent + domain/DKIM/redirect: ND0001: 8,520 | ND0002: 6,433
These are overwhelmingly emails that happen to contain "4patent" in addresses and "domain" somewhere in the body (marketing emails about domain registration, etc.). No new DKIM/infrastructure evidence beyond what's already documented.
Counts: ND0001: 344 | ND0002: 361 | Total: 705
All 339 ND0001 Harkins hits are USPTO PAIR Correspondence Notifications for CN-37833, with tharkins@nathlaw.com as a direct recipient alongside litman@4patent.com. Date range: 2020-09-23 through 2021-08-31 (approximately 11 months).
This means Tanya Harkins received CN-37833 patent correspondence notifications for 11 months during the post-SOL period. She was a direct recipient of the same automated USPTO notices that constitute § 51 "publications." Her May 2021 statement "this is not Litman... he doesn't work here anymore" (Finding #55) was made WHILE she was still receiving daily patent correspondence bearing his Customer Number.
ND0002 hits are predominantly TEAS (trademark) filings that mention "Harkins" in the docketing context (likely through email threading/forwarding chains).
Counts: ND0001: 1,363 | ND0002: 3,095 | Total: 4,458
ND0002 "Patent costing - NGM" thread (May-June 2025): A 38-email thread starting 2025-05-30 between UAEU IP Unit, Martha Long, Goldberg, Valencia Gray, and Litman — discussing patent cost structure. Litman was CC'd on UAEU patent cost discussions and actively participating with Goldberg ("Re: Patent costing - NGM") — 5 years post-termination.
Maintenance fee evidence is massive — 3,095 emails in ND0002 alone. This includes KSU, KFU, Kuwait University, KISR maintenance fee payment confirmations and reminders. The sheer volume demonstrates the ongoing patent maintenance work being done under Litman's name.
Counts: "Fidelity": ND0001: 977 | ND0002: 89 | Total: 1,066 "645375268": 0 in both archives (account number not found in email text)
Fidelity emails to litman@4patent.com include transaction confirmations, trade confirmations, and eDocuments from 2020-2025. These are personal financial notifications routed through the 4patent.com domain — another example of Litman's personal life flowing through NGM-controlled infrastructure.
Counts: - COBRA: ND0001: 384 | ND0002: 116 - Health insurance: ND0001: 492 | ND0002: 161
NEW — Complete COBRA timeline discovered in ND0002:
| Date | From | To | Subject |
|---|---|---|---|
| 2025-04-30 | Cathy Centra | Litman (both addresses) | "Upcoming Benefits Change" |
| 2025-05-30 | Litman → Centra | "Re: Upcoming Benefits Change" | |
| 2025-06-02 | Centra → Litman | "RE: Upcoming Benefits Change" | |
| 2025-06-19 | Goldberg → DC Office | CC: Centra | "Organization Change Announcement - Moving Away From Resourcing Edge" |
| 2025-06-26 | Centra → Litman | "RE: Upcoming Benefits Change" (same day as litigation trigger) | |
| 2025-06-26 | Litman → Goldberg | "Re: Upcoming Benefits Change" (escalated to Goldberg directly) | |
| 2025-07-03 | Litman → richie.litman@gmail.com | "Fwd: Organization Change Announcement..." (forwarding to nephew) | |
| 2025-10-02 | Centra → Litman + Cheryl Litman | "COBRA Information" | |
| 2025-10-09 | Centra → Litman + Cheryl | "RE: COBRA Information" | |
| 2025-11-06 | Centra → litman@4patent.com | "COBRA Paperwork" | |
| 2025-11-10 | Litman (rclitman@gmail.com) → Centra | "Confirmation of COBRA Coverage and Administrator Transition" | |
| 2025-11-14 | Centra → Litman | "RE: Confirmation of COBRA Coverage and Administrator Transition" | |
| 2025-11-14 | Litman → Centra | reply | |
| 2025-11-15 | Centra → Litman | "RE: Confirmation of COBRA Coverage and Administrator Transition" | |
| 2025-11-15 | Litman → Centra | reply | |
| 2025-11-15 | Centra → Litman | reply | |
| 2025-11-17 | Centra → Litman | "Re: Confirmation of COBRA Coverage and Administrator Transition" |
This is a major new evidentiary chain. Key findings: 1. Goldberg's June 19, 2025 "Organization Change Announcement - Moving Away From Resourcing Edge" — NGM was changing benefits administrators one week before the litigation trigger. This may be the trigger for the benefits cutoff. 2. COBRA was not offered until October 2, 2025 — more than 3 months after benefits were cut June 30 (per Finding #81). This is likely a COBRA notification violation (employers must provide COBRA notice within 44 days). 3. The Nov 6, 2025 "COBRA Paperwork" was sent to litman@4patent.com — the "eliminated" account. Another proof the account was still active. 4. Litman had to use rclitman@gmail.com for Nov 10+ correspondence — confirming he had lost access to his NGM/4patent accounts by then. 5. Cheryl Litman (cheryllitman@gmail.com) was CC'd on COBRA — confirming the health insurance covered Litman's wife (relevant to the Crohn's disease leverage theory).
Earlier benefits chain (Jan 2025): - Litman ↔ Centra, "UHC" thread (Jan 2-6, 2025) — United Healthcare issues - Litman → Cheryl, "Dental and Vision Group Numbers" (Jan 7, 2025) - Centra → Litman, "Benefits" thread (Jan 10-27, 2025)
Counts: ND0001: 17 | ND0002: 13 | Total: 30
The smoking gun (already documented as Finding #34): - 2025-09-02 16:19 — OpenGov Procurement Team → "Joshua Goldberg" litman@4patent.com, "OpenGov Procurement Account Activated!"
NEW — Extended timeline: - 2025-08-21 — 9 "Join Virginia State University on OpenGov Procurement" invitations sent to litman@4patent.com (multiple identical sends) - 2025-08-31 — 7 "Reminder: Join Virginia State University on OpenGov Procurement" sent to litman@4patent.com
NEW — Auto-reply reveals active email processing: - 2025-08-21 16:47 — Richard Litman (rlitman@nathlaw.com) sent an automatic reply to the OpenGov invitation — "Automatic reply: Join Virginia State University on OpenGov Procurement"
This means: (a) the rlitman@nathlaw.com account had an auto-reply set up, and (b) the OpenGov invitation to litman@4patent.com triggered a response from rlitman@nathlaw.com, proving the two accounts were linked in NGM's M365 infrastructure. The auto-reply is additional proof both accounts were active in August 2025.
Multiple emails found in ND0002: - Richard Litman → Joshua Goldberg: "Please resolve: $694,478.67 Wire Transfer - RE: Richard C. Litman v. Nath & Associates, PLLC" (undated in visible metadata) - Joshua Goldberg → Richard Litman: Multiple replies to same thread - Richard Litman → Daniel Litman (litmantsi@gmail.com): "Fwd: Please resolve: $694,478.67 Wire Transfer" — forwarded to nephew
This is a previously undocumented $694,478.67 wire transfer that Litman demanded Goldberg "resolve." The subject line ties it directly to the litigation ("RE: Richard C. Litman v. Nath & Associates, PLLC"). Litman forwarded the exchange to his nephew Daniel (not Michael — different family member). This needs investigation — is this the Q4 2025 quarterly payment? An earlier disputed wire? A settlement gesture? The amount is significant ($694K) and may correspond to accumulated unpaid 20% share.
David N. Litman at Wells Fargo Advisors (david.n.litman@wellsfargoadvisors.com) appears extensively in both archives as part of the CTH Wealth Management Group. He is the family's wealth advisor. His August 29, 2025 email researching "forensic accounting firms in New York and Virginia" confirms the family was actively seeking forensic accounting expertise for the case at that time.
Two separate contact form submissions found in ND0002: 1. July 1, 2025 — Martha Long → Joshua Goldberg, "RE: Contact Form form submissions received!" — unknown client 2. July 7, 2025 — Martha Long → Howard Kline (CC: clientservice@4patent.com), "RE: Contact Form form submissions received!" — Bennington
The July 1 submission went directly to Goldberg (not Kline), suggesting it may have been a patent inquiry rather than a trademark one. Both came through the nathlaw.com Contact Form, which was live and accepting submissions while Litman's name and photo remained on the website.
Kelly Benefits appears to be the new benefits administrator after Resourcing Edge (per Goldberg's June 19 "Moving Away From Resourcing Edge" announcement). A bill was sent to litman@4patent.com in November 2025 — yet another proof the account was active AND that Litman was still connected to NGM's benefits infrastructure.
Faison Group is NGM's insurance broker, sending renewal notices to staff at @litmanlaw.com addresses.