Federal Complaint & Exhibits Analysis — Litman v. Nath, 1:25-cv-04048 (EDNY)

Source: evidence/aaa_lawsuit_package_20250728/ Date reviewed: 2026-04-10 Filing date of complaint: July 22, 2025

1. Federal Complaint (FINAL version)

File: AAA - master context/LITMAN vs NATH, Fedral Complaint FINAL.pdf

Case Caption & Structure

Plaintiff: Richard C. Litman, pro se, 172 Sterling Pl Apt 8, Brooklyn, NY 11217
Defendant: Nath & Associates, PLLC d/b/a Nath, Goldberg and Meyer (NGM) — served through Joshua B. Goldberg, Registered Agent, 116 Garfield Pl Apt 1, Brooklyn, NY 11215 (confirms NY jurisdictional hook for state court case)
Jurisdiction: Federal Question under Lanham Act § 43(a) (15 U.S.C. § 1125(a)), supplemental over state claims
Demand: $3,222,408.29 compensatory (tracks Exhibit D receivables figure exactly), plus punitives, disgorgement, constructive trust, equitable accounting, injunction, fees
Jury demand: Yes
NGM characterized as: "a District of Columbia professional limited liability company with its principal place of business in Alexandria, Virginia" — confirms Finding #68 (NGM is a DC entity)

Ten Counts

Common Law Unfair Competition (Misappropriation of name, goodwill, labor)
NY Civil Rights Law §§ 50-51 (Unauthorized Use of Name) — the only count that survived in state court
Defamation — Libel Per Se ("Attorney – Retired")
Lanham Act § 43(a) False Endorsement
Tortious Interference with Prospective Economic Advantage
Unjust Enrichment / Quantum Meruit
Constructive Trust
Equitable Accounting
Prima Facie Tort
NYC Human Rights Law § 8-107 (disability discrimination via "Retired" label)

Key Factual Allegations

6/15/2020: Arbitrator-ruled termination date — "as if he had died"
Arbitrator found NGM acted in bad faith by improperly withholding payments and was not entitled to disability-insurance offsets
June 14, 2024: nathlaw.com website still listed Litman as active "RICHARD C. LITMAN, PATENT ATTORNEY" (Ex. F)
April 4, 2023: U.S. Patent 11,617,719 issued with Litman listed (Ex. G — KSU)
April 23, 2024: U.S. Patent 11,964,974 issued with Litman listed (Ex. H — KFU)
June 2025: NGM's "kill shot" — branding Litman as "Attorney – Retired" (Ex. C)
June 21, 2025: Internal NGM accounting report shows $3,222,408.29 in receivables, 100% attributed to Litman as Collecting, Introducing, and Responsible lawyer (Ex. D)
685 distinct originated clients (Ex. I)

Legally Significant Quotes From Complaint

"as if he had died" — arbitrator's unambiguous severance
"NGM's Co-Managing Partner directed substantial firm operations, including the tortious conduct alleged herein, from his residence in Brooklyn" — venue paragraph; establishes personal Brooklyn jurisdiction over Goldberg
Names the NGM 2023 and 2024 patents as "unauthorized use of his name and professional credentials to secure valuable intellectual property rights"

Framing Notes

The filed final version was softened to emphasize "negligent misrepresentation" and "failures in internal controls" language (presumably to survive a motion to dismiss on state-law tort elements while preserving intent-based claims). The three-act fraud narrative exists fully in the Ex E context analysis but not in the complaint prose.
Complaint is verified "based on best information" with explicit reservation of right to amend — not sworn.

2. Exhibit D — Accounts Receivable Report (June 21, 2025)

File: Exhibit D - All invoices on files... (account summary June 21, 2025)...pdf

This is NGM's own Devlos/Soluno-generated Receivables by Client report dated 6/21/2025, 11:54 PM, requested by Deborah J. Schaefer. The exhibit is page 649 of the full report.

The Smoking Number: $3,222,408.29

Every aging bucket is attributed to "RL - Richard Litman": - Collecting Lawyer: Richard Litman = $3,222,408.29 (100%) - Introducing Lawyer: Richard Litman = $3,222,408.29 (100%) - Responsible Firm Lawyer: Richard Litman = $3,222,408.29 (100%) - Total billed: $37,104,286.26 - Total paid: $33,881,877.97 - Aging: $88,374.85 (<=30) / $249,320.08 (31-60) / $183,698.00 (61-90) / $246,847.00 (91-120) / $2,454,168.36 (>120 days)

What It Proves

NGM's own books designate Litman the "Responsible" attorney on 100% of firm receivables five full years after his purported termination
This is documentary basis for the $3.22M minimum compensatory demand in the federal complaint
$2.45M of the $3.22M is over 120 days past due — "tapering down" pattern consistent with clients pulling back once Goldberg was on the case
Directly destroys any "retired" narrative — a retired attorney is not Responsible Lawyer on a multi-million-dollar AR ledger
Area of Practice breakdown confirms practice composition: $36.66M General (patents), $433K Trademark, $5,865 Foreign Trademark, $1,615 Copyright, $500 Patent Prosecution

3. Exhibit F — "Richard C. Litman PATENT ATTORNEY" Google Search Snapshot (July 19, 2025)

File: Exhbit F - use of Richard Litman's name after 2020.pdf

iPad screenshot 7/19/2025. Shows Google search results for Litman. Highlighted in red and green boxes: - https://faculty.ksu.edu.sa PDF — "(74) Attorney, Agent, or Firm -. Nath, Goldberg & Meyer. (57) Richard C. Litman; ABSTRACT." (USPTO patent Line 74 publication hosted on KSU's own faculty site — this is proof of downstream international republication) - https://nathlaw.com — "Commercialization And Licensing / Jun 14, 2024 — LaFave. PATENT ATTORNEY. > LEARN MORE. Richard C. Litman PATENT ATTORNEY > LEARN MORE. CONTACT US TODAY 1.703.548.6284"

Two independently dated post-SOL uses captured in a single Google SERP.

4. Exhibit I — Updated Originated Clients List

File: Exhibit I - Updated_Originated_Clients_List.pdf (16 pages)

Total client count: ~685 (complaint says "685 distinct clients"). The complete list is Litman's originated book of business. Notable entries include: - Client 427 / ID 1242 — Nath Associates PLLC/Nath, Goldberg Meyer itself appears as a Litman-originated "client" (foundational admission — Litman originated the very firm) - All major Middle East institutional clients: KSU, KFU, UAEU (×3 variant records), Qatar Foundation, Qatar University (×2), Qatar Solar Technologies, Qatar Navigator, King Abdulaziz University, King Fahd University of Petroleum & Minerals, King Faisal Specialist Hospital Research Centre, Kuwait Institute for Scientific Research, Kuwait University, Kuwait Oil Company, Sabah Al-Ahmad Center, Dasman Diabetes Institute, Sultan Qaboos University, Umm Al-Qura University, University of Sharjah, Arabian Gulf University, German Jordanian University, Jouf University, University of Tabuk, Abu Dhabi Polytechnic, Imam Mohammad Ibn Saud Islamic University, Oman Animal & Plant Genetic Resources Center, Saline Water Desalination Research Institute, Saudi Advanced Technologies Company (Wahaj), Auburn University - Client 362 / ID 140400 — "Litman, Richard C." himself appears as a client number - Supports Finding #61 (98% of NGM matters referred by Litman)

5. Exhibit J — $1,437,568 KSU Wire + 3/6/2023 Goldberg Email

File: Exhbiti J - Gmail - Fwd: FW: wire transfer with amount ($1,437,568.00).pdf

Forward chain originated with a Dec 22, 2022 email from KSU's IPTL (Intellectual Property and Technology Licensing Program, iptl@ksu.edu.sa) confirming a wire transfer for $1,437,568.00 to NGM, with an additional $129,680 promised within 60 days.

Legally Significant Facts

Dec 22, 2022 — KSU wire confirmed; recipient header lists: Joshua Goldberg, Martha Long, CC: KSU ksu@4patent.com, Jerry Meyer, Richard Litman rlitman@nathlaw.com
This pre-dates the June 2023 arbitration award by ~6 months but post-dates the 6/15/2020 SOL cutoff by 2.5 years — KSU was still wiring seven-figure sums to NGM while Litman was the "terminated" party on the email CC
Uncle's rlitman@nathlaw.com email address is actively CC'd — proving the account was live, and NGM was actively using it to maintain client relationships in Litman's name
Goldberg signs "Green Patent Guy" with Brooklyn, NY address → establishes he was running the KSU relationship from Brooklyn
March 6, 2023 forward from Goldberg to Litman's Gmail: "Thank you again for the time and discussion on Friday. I felt like we had a good talk. It will be important to keep the momentum going" — confirms active ongoing business collaboration post-termination
ksu@4patent.com alias used in official KSU correspondence — supports Finding #46 (4patent.com alias infrastructure)
$129,680 promised but apparently never received per Goldberg's own 3/6/2023 note — supports accounting-discrepancy theory

6. Exhibit K — June 2020 "Status Quo / Until Jerry Better" Email

File (scanned, empty text): Exhbit K - 06.20 Josh Goldberg emails... — image-based, content read from Context/Ex K context.pdf

This is the foundational "genesis" email chain the user asked about. Dated June 7–8, 2020, the exact week of the 6/15/2020 SOL cutoff.

Direct Quotes Preserved in Context Doc

Litman to Goldberg: "I have never put as much trust in other people as I have in you and Jerry."
Goldberg's reply: "Thank you very much for trusting me and us; I will do everything I can to continue to be worthy of that trust."
Litman's disability disclosure: uses specific terms "my disability" and "need for medical leave"; describes need for knee replacement and consultation with disability insurance lawyer
Goldberg acknowledges: "Wow, that's quite the update" and "And it is good to know what you are currently thinking and looking into regarding disability"
Litman's confidentiality request: "Please keep the above info about my disability and need for medical leave quiet... I don't think we want clients, competitors or internal staff to think... our Arabic client relationships are slipping away."
Goldberg's agreement: "my strong preference is that we keep this between you and I... there is no reason to share more with people than they need to know."

Why This Destroys Every Defense

Fiduciary relationship established by mutual written declarations of trust — supports constructive trust/equitable accounting
Direct knowledge of disability (not retirement) as of June 8, 2020 — destroys any "honest mistake" defense on the "Retired" label and supports NYC Human Rights Law claim
Actual malice for defamation — Goldberg cannot claim ignorance of the truth when he later published "Retired"
Agreed concealment of disability from staff/clients to protect Arabic client relationships — this is the "status quo" arrangement the user asked about. NGM and Litman jointly agreed to keep the relationship looking intact externally. Goldberg later exploited this agreed concealment to continue trading on Litman's name long after 6/15/2020.
Explicit contemplation that Litman continued to have client goodwill worth protecting — directly contradicts any "no commercial value" defense

7. Exhibit L — March 2021 Meyer & Goldberg "Trust Account" Email Chain

File: Exhibit L - NGM March 2021 position - trust account, my money for KSU feees, and payment twice per month..pdf

March 5-9, 2021 email thread. Three-way exchange among Litman, Goldberg, and Jerry Meyer. Critical because Meyer (a defendant) almost never appears in the evidentiary record otherwise.

Meyer's Direct Admissions (3/9/2021, 08:28 EST)

Acknowledges multi-million-dollar KSU receivable: "the whole relationship with KSU has put our firm in a very precarious position with our bank. Having such a large outstanding receivable with one client (for such a long time - going on 4 years now)"
"We also know that some of the delays are apparently due to their restructuring to have more local control over payments"
"We are in agreement that we need to define our relationship during the 5-year tail of the agreement, not just payment procedure, but regarding health insurance coverage and other benefits" — written admission of the 5-year tail payout obligation
"As Josh has said, and I am in full agreement, your health is most important. If you are healthy and want to restart doing your magic while we pause the tail portion of the agreement, then we are all for it" — contradicts "as if he had died" treatment
TRUST ACCOUNT PROMISE: "And, if you do not want the money now, we are happy to put it aside in a trust account" — written fiduciary promise by Meyer
"we will get [the reports] to you as soon as possible" — acknowledges reports were being withheld

Goldberg's Parallel Written Admissions (3/5-3/8/2021)

"As for the amounts we owe to you, we can certainly set them aside in a trust account for you so you can see the money is there" — second written trust-account promise
Goldberg's 3/5 email references specific quarterly numbers: "adjusted total for the end of 2021 was $41,493.71 due to you. For January and February, there is an additional $7,591.46 due to you, making the total at $49,085.17" — admission of concrete sums owed
"From my perspective, the two things that would be most helpful are making sure the clients pay what they owe us, figuring out how to make the best use of the GAIN group, whether it is offering webinars to the group, trying to put some panels of group members together, having a targeted advertising campaign" — explicit request for Litman's business development labor and use of his GAIN (Global Academic Innovation Network) network

Litman's Statements (3/5 & 3/9/2021)

"NGM's ERISA carrier MetLife deemed me disabled" — establishes Goldberg/Meyer knew disability status
"At that time, NGM stopped paying the $25,000/month as a W-2 employee as an advance, trued up quarterly per contract" — explicit $25K/month compensation figure from Litman's own contemporaneous description
"I want the firm to keep KSU as a client. I am willing to take the risk on filing fees" — shows ongoing personal investment and active management, not retirement
"Our deal was for NGM to buy my practice. We agreed to a 5 year earnout after a indeterminable length of employment" — Litman's written characterization of the deal
P.S. (3/9): "We should define my status as employee on medical leave, subject to the policies of the firm, and, of course, our agreement (which provides I get the same treatment as you and Jerry, and the same benefits I got at B&P)" — establishes contemplated status as employee on medical leave, not retired

Why This Is Devastating

This is written bilateral admission by both co-managing partners that: 1. The 5-year tail payout was real and operative in 2021 2. Money was owed to Litman and would be placed in trust 3. Litman's health/disability was known and deemed "most important" 4. NGM was soliciting Litman's ongoing contributions (GAIN group, client work, KSU strategy) 5. Monthly compensation was $25K as W-2 advance, true-up quarterly

The subsequent "Retired" designation and the fraudulent accounting occurred with full knowledge of these written promises — establishes actual malice and bad faith.

8. KFU Price List / Fee Schedule — NOT FOUND IN THIS EXHIBIT SET

Direct answer to the user's question: There is no KFU price list or fee schedule in the AAA lawsuit package exhibits. The closest item is Exhibit O (Exhibit O - Gmail - Fwd: KSU Patent Applications for Filing 2.pdf), which is a Feb 14, 2023 email from Martha Long to Goldberg (CC: ksu@4patent.com) containing a KSU (not KFU) filing-fees table for 15 unfiled patent applications: - Docket numbers 33032.11 through 33056.60 - Per-docket filing fees ranging from $480 to $3,000, most at $2,855 or $3,000 - Applications held with signed documents on hand from Sept 2020 – Feb 2021 (filed ~2.5 years later)

This is a KSU-specific filing-fee list, not KFU. Searched all exhibits and the master ALL EXHIBITS.pdf (6,593 lines) for "KFU", "King Faisal", "fee schedule", "price list", "rate card", "flat fee", "fixed fee", "per patent", "per docket" — the only KFU references are (a) trust-ledger transactions in Ex. B and (b) text-message discussions in Ex. E. No flat-rate fee schedule for KFU exists in this package.

Where to look next: The KFU fee schedule is more likely to exist in: - evidence/uncle_batch_2026-04-07/KFU Receivables Payments Jun 25.csv (already in corpus) - The 4,611-email KFU alias email dump (ND0001+ND0002) - NGM's internal Soluno/Devlos practice-management exports - Goldberg's 6/11/2025 "many [ledgers] are blank" admission email (Finding #53)

9. Exhibit B — 534-Page NGM Trust Ledger (All Dates)

File: Exhibit B - Report Grace Sent - Report_20250626_021254.pdf (Devlos/Soluno-generated, 6/26/2025)

Title: "Trust Ledger / Nath Goldberg & Meyer / All Dates"

This is the complete trust account history, by client, by matter, by transaction, with receipt/disbursement/balance at each entry — every trust movement NGM ever made. Every KFU entry (client 135900) is present with trust-to-trust transfers between BoA and EagleBank, "On behalf of King Faisal University" annotations, etc. The file is the foundation for any forensic reconstruction of the $9.89M KFU unallocated universe (Finding #51) and the $17.2M double-overlay (Finding #52).

This is the most important non-narrative exhibit in the package. 534 pages of raw trust accounting that NGM's own lawyer (Grace/Deborah Schaefer) produced in discovery — not previously in our indexed corpus as a single linked file.

10. Other Exhibits (briefer notes)

Exhibit A (Accounting Discrepancy): Side-by-side of NGM's "Summary by Bank Account" showing $32,708,669.08 in total receipts vs. the "Period Billed Receipts" summary provided to Litman showing only $16,506,604.92 — $16,202,064.16 discrepancy. This is the "$16.2M missing revenue" number that anchors the fraud theory (already in our findings at #19, validated here with specific figures from the filed exhibit).
Exhibit C (Retired designation, July 8, 2025): nathlaw.com professional page still displays "RICHARD C. LITMAN, PATENT ATTORNEY" with full bio — AV Martindale-Hubbell, GAIN founder, bar admissions Virginia/DC/Maryland/Florida/Pennsylvania + USPTO — and the search results adjacent to it label him "Retired." The contradiction between the active profile page and the "Retired" search result is itself defamation evidence.
Exhibit E (Text Messages, 51 pages): Full Goldberg text thread with in-depth legal overview analysis provided by uncle. Contains Goldberg's 1/29/2023 "USPTO fees...are not revenue per matters but simple pass through reimbursements" (premeditation to narrow revenue definition); Goldberg's 1/30/2023 "if you are on disability, what would be considered legal vs. fraud? I don't want ANY of us having to face a fraud issue" (consciousness of guilt); Goldberg's 2/2/2023 "That is a positive, if we can agree on that there is no need for the special master" (avoidance of forensic audit); Litman's 6/16/2025 discovery of the "Pattern of intentional transfers" (money deposited under wrong client numbers to bypass allocation — corroborates Finding #27); and the 7/18/2025 email-elimination exchange (Finding #23).
Exhibit M (Sept 28, 2022): Goldberg email acknowledgment — "We appreciate everything you have done to assist with the collections from them, as well as your efforts to steer more work to the firm" plus "We obviously would prefer not to go to arbitration" — admission of ongoing contribution and pre-existing arbitration dispute.
Exhibit N (HARDCORE trademark, Nov 1, 2022): NGM letterhead transmittal letter to Outdoor Supply Inc. for U.S. Trademark Reg. No. 6,888,499 — another post-SOL use of NGM's "Richard C. Litman" name on firm stationery (ref 32269.11T).
Exhibit O (see Section 8 — KSU filing-fees table, not KFU).
Exhibit P (Jan numbers, Feb 13 2023): Goldberg's "The Pad entries for January, which show the breakout for each invoice" — direct reference to "The Pad" (Finding #10), NGM's internal tracking system for Litman-originated matters. Includes docket 32366.xx breakdown for KISR wire.
Exhibit Q (COBRA rights July 2025): Litman's COBRA notice — supports the $2,867–$2,895/month consequential health-insurance damages in our damages model.
Exhibit R (Asset Sale / Trademark Assignment): Per context doc — Goldberg's signed, recorded document delineating which service marks were sold to NGM vs. what Litman retained. Only 5 service marks transferred (including "LITMAN LAW OFFICES, LTD."); Litman's personal "name, signature, voice, image, photograph or likeness" explicitly NOT included. This is the "Contractual Kill-Shot" — Goldberg's own signed admission that he knew the right to Litman's personal name belonged to Litman. Destroys every consent-based defense and establishes willfulness.

What's New / Not Previously in Our Corpus

The filed federal complaint itself — we had only the state complaint and the early "v666" draft. The FINAL version is softer on fraud language but contains the 10-count structure, the $3.22M demand figure, the Brooklyn venue paragraph, and the confirmation that NGM is formally a DC LLC with Virginia principal place of business (supports Finding #68).
Exhibit B — the full 534-page NGM Trust Ledger. Grace/Deborah Schaefer-produced, 6/26/2025. This is the authoritative forensic baseline we did not previously have as a single indexed file.
Exhibit L — the complete March 2021 Meyer/Goldberg/Litman trust-account thread with Meyer's written admission of the 5-year tail and Meyer's written trust-account promise. Meyer rarely speaks in the written record, and this pulls him directly into the fiduciary-breach theory as a co-defendant. The specific figures ($41,493.71 Q4 2020, $7,591.46 Jan-Feb 2021, $25K/month W-2 advance) are contemporaneous admissions by Goldberg of sums owed.
Exhibit K (via context doc) — the June 7-8, 2020 "status quo / concealment" email. The genesis of the name-use scheme. Mutual declarations of trust + bilateral agreement to conceal the disability "so our Arabic client relationships are slipping away" doesn't become public. This is the original contractual-scheme document that frames everything post-6/15/2020 as a continuation of an agreed arrangement Goldberg then exploited.
Exhibit J — the $1,437,568 KSU wire of Dec 22, 2022 with Litman actively CC'd at rlitman@nathlaw.com. Proof the email was live AND proof of a seven-figure post-SOL transaction with Litman's name on the distribution list. The $129,680 promised-but-missing sub-transaction is a discrete dollar handle for the accounting-diversion theory.
Exhibit D as filed — the specific $3,222,408.29 / 100% Responsible structure is now in our hands as the filed-exhibit version, which matches the federal complaint's compensatory demand exactly. We had the underlying receivables data previously; the filed exhibit version confirms how it was presented to the court.
Exhibit E legal overview memo — a three-act narrative analysis (Trust → Deceit → Cover-Up) with timestamped text-message quotes already cross-referenced to each cause of action. This is a ready-to-use deposition roadmap and MSJ brief outline.
Exhibit R (Asset Sale / Trademark Assignment) — the "contractual kill-shot." Goldberg's signed recorded document limiting the sale to 5 specific service marks and explicitly carving out Litman's personal name/signature/likeness. This is the pre-existing ownership admission that strengthens the Nunc Pro Tunc Assignment theory already in Finding #4.

KFU Price List — Status

Not present in this exhibit set. Continue searching in: evidence/uncle_batch_2026-04-07/ (KFU Receivables CSV, Exhibit_A_KFU_Billing_Trust_Summary.docx), the 4patent.com KFU email corpus (19,701 emails), and Goldberg's June/July 2025 admission emails. If uncle specifically referenced a KFU fee schedule, it may be embedded in an attachment to one of those files or in a Soluno report not yet extracted.

Federal Complaint Exhibits Analysis