Audit Date: March 26, 2026 Auditor: Automated deep-dive across all evidence categories
| Category | Items Verified | Gaps Found | Gaps Filled Today |
|---|---|---|---|
| Financial Evidence | 2,435 files | 12 gaps | 4 filled |
| Patent Evidence | 905 patents + 21 IFW + POAs | 4 gaps | 3 filled |
| Court Filings | 70 NYSCEF docs | 17 missing | 4 URLs opened for manual download |
| Email Evidence | 276,901 emails | 7 gaps | 2 filled |
| Website Evidence | 7 screenshots | 1 gap | 0 |
| Trademark Evidence | 748 USPTO emails | 0 gaps | N/A (new today) |
| Legal Memos | 10 memos | 1 gap | 0 |
| # | Gap | Why Critical | Action Required |
|---|---|---|---|
| 1 | Court reporter transcript of 12/05/2025 oral decision | Judge Maslow's reasoning for Count V survival. Cannot be obtained digitally. | Order from court reporter. Contact Kings County Supreme Court clerk. |
| 2 | Nunc Pro Tunc Assignment PDF (Reel 007281, Frame 0821) | Central to defeating consent defense (para 38 of SAC). Goldberg's own recorded document states Litman owns his name. | Manual download from assignmentcenter.uspto.gov -- search Reel 007281, Frame 0821. |
| 3 | Arbitration agreement text defining "20% formula" | The $15M discrepancy hinges on whether 20% applies to gross receipts or collected fees. | The NGM Litman Agreement exists at ~/Downloads/NGM Litman Agreement.pdf. Need to extract and analyze the 20% formula language. |
| 4 | NYSCEF Docs 54-57 | Goldberg's opposition arguments and Litman's reply -- needed to understand the legal positions. | Manual download from browser (tabs already opened). |
| # | Gap | Action |
|---|---|---|
| 5 | Goldberg's response to $15M discrepancy letter (July 2025) | Search rclitman@gmail.com for replies from hcarter@gcpc.com or gkren@gcpc.com after 7/20/2025 |
| 6 | Standalone Affirmative Defense Counter-Evidence Table | Build counsel-ready document mapping all 10 defenses to specific evidence |
| 7 | 3 additional assignment PDFs from assignmentcenter.uspto.gov | Manual browser download needed |
| 8 | Professional liability insurance certificate | Uncle to locate and provide |
| 9 | Zip files from Deborah Schaefer or Grace Kren | Uncle to search rclitman@gmail.com and download |
| # | Gap | Note |
|---|---|---|
| 10 | NYSCEF Docs 44, 46-47, 50-51, 59 | Plaintiff's own filings -- lower priority since we can recreate from memory |
| 11 | 3Q2020 Fee Allocation Summary | Only missing quarter from 2020 series |
| 12 | Jul-Sep 2023 Payment Allocation PDFs | First 3 months post-arbitration have no docket-level allocation PDFs |
| 13 | Jun 2025 Receivables report | Last pre-termination receivables |
| 14 | KNPC pre-2024 Litman Line 74 patents search | Query ready but not yet run |
| 15 | Full 276K email body extraction | Only 101 case-relevant bodies extracted; bulk extraction never completed |
| # | Item | Status |
|---|---|---|
| 16 | Text messages PDF | RESOLVED -- Exhibit_E_Text_Messages_Goldberg.pdf exists in court_filings/ |
| 17 | Sept 5, 2025 website screenshot | Exists but may need cleaner capture |
| 18 | Patent grant XML files | Results captured in PDF; raw XML not retained |
| Category | Count |
|---|---|
| Financial attachments | 2,435 files |
| Email metadata records | 276,901 |
| Email attachments extracted | 11,243+ |
| Court filings obtained | 53 of 70 NYSCEF docs |
| Patent-related documents | 905 patents + 21 IFW + 19 POAs |
| Trademark-related USPTO emails | 748 |
| Website screenshots | 7 |
| Legal memos/exhibits | 15+ |
| Evidence Type | Count |
|---|---|
| Goldberg POA signatures | 16 confirmed (updated today) |
| Lafave PTOL-85B filings | 18 |
| USPTO trademark emails to Litman | 748 across 301 matters |
| Kline emails CC'ing Litman | 2,431 across 309 dockets |
| JBG journal entries | 28,503 across 1,955 dockets |
| JBG trust ledger authorizations | 54 |
| Martha Long solicitation emails | 4 (with "27 years" language) |
| "The Pad" directive emails | 3 (Van Giezen + Goldberg) |
| Metric | Amount |
|---|---|
| Total billed (2017-2025) | $32,448,690 |
| Total collected (2017-2025) | $23,530,099 |
| Outstanding AR | $8,918,591 |
| Trust balance (June 2025) | $1,211,244 |
| Litman 20% paid (post-arb) | $2,403,126 |
| Litman 20% due (per uncle's calc) | $5,876,081 |
| Claimed underpayment | $3,472,955 |
| Source | Publications |
|---|---|
| Patent front pages (Line 74) | 905 |
| USPTO IFW outgoing documents | 206 |
| USPTO trademark emails to Litman | 748 |
| Kline client emails CC'ing Litman | 2,431 |
| Martha Long solicitation emails | 4 |
| Website appearances | 7+ |
| TOTAL SEPARATE SS 51 USES | 4,301+ |
$79,150 discrepancy between VERIFIED_FINANCIAL_SUMMARY ($2,481,602 due) and NGM Workup ($2,402,452 due) -- explained by missing allocations Litman identified in June 2025
Jan 2024 payment ($132,636.68) missing from Workup -- present in master Litman Summary but absent from Goldberg's accounting
Sep 2024 payment amount mismatch -- Workup shows $16,469.11; Verified Summary shows $17,866.40
Jan 2025 $9.00 shortfall -- only month where payment doesn't match the 20% due exactly
POA count now verified at 16 -- previously claimed 16 but only 14 were in the table. Today's downloads of patents 12,227,748 and 12,303,254 confirmed the remaining 2, bringing the verified total to 16.
Most recent Goldberg POA: January 17, 2025 -- 3 days after the Line 74 switchover. He signed one last POA putting Litman's name on a filing, then switched to his own name on Line 74.