Prepared: March 26, 2026 Subject: Joshua B. Goldberg's Personal Authorization of Trust Account Fund Transfers Account: NGM Trust Ledger, Account 36372 (King Faisal University) Source Document: Trust Ledger for Account 36372, generated June 19, 2025, by Deborah J. Schaefer
The KFU Trust Ledger for Account 36372 — the primary trust account for King Faisal University, one of the firm's largest clients — records $10,737,709.88 in total receipts across 871 transactions from September 30, 2020 through November 20, 2024. This is money collected under the name "Richard Litman" as attorney of record on KFU patent matters.
Within this ledger, four entries dated August 19, 2021 are annotated with the notation "JBGverbal" — a clear reference to Joshua B. Goldberg verbally authorizing inter-docket fund transfers. These entries prove that Goldberg personally directed the movement of funds within the trust account that held money generated by work performed under Litman's name. A fifth entry, dated January 31, 2023, references "Per MSL" — indicating a different attorney (likely Martha S. Long) — which by contrast confirms that the "JBG" notation specifically identifies Goldberg.
All four transfers were authorized by Goldberg verbally on August 18, 2021 and executed on August 19, 2021. Each moved funds from an individual patent prosecution docket back into the general KFU trust account (36372).
| # | Date | Entry No. | From Docket | To Account | Amount | Authorization | Running Balance |
|---|---|---|---|---|---|---|---|
| 1 | 8/19/2021 | 2488679 | 32087.50 | 36372 | $298.00 | JBGverbal 8.18.2021 | $2,298.00 |
| 2 | 8/19/2021 | 2488683 | 32087.14 | 36372 | $3,000.00 | JBGverbal 8.18.2021 | $5,298.00 |
| 3 | 8/19/2021 | 2488688 | 32087.08 | 36372 | $1,100.00 | JBGverbal 8.18.2021 | $6,398.00 |
| 4 | 8/19/2021 | 2488691 | 32087.19 | 36372 | $810.00 | JGBverbal 08.18.2021* | $7,208.00 |
Total moved by Goldberg's verbal authorization: $5,208.00
*Entry #4 contains a typographical transposition ("JGB" instead of "JBG") but clearly refers to the same person — all four transfers were executed on the same date, in sequential entry numbers, with the same authorization date.
| Date | Entry No. | From Docket | To Account | Amount | Authorization |
|---|---|---|---|---|---|
| 1/31/2023 | 2489302 | 33101.35U | 36372 | $269.52 | Per MSL 1.31.2023 email |
This entry attributes a transfer to a different attorney's written authorization. The existence of both "JBG" and "MSL" notations confirms that the firm's trust accounting system identifies the specific individual who authorized each inter-docket transfer. The "JBGverbal" notation is not a generic system code — it is a record of Goldberg personally directing fund movements.
Personal direction, not firm-level action. The trust accounting system distinguished between individuals who authorized fund movements. Goldberg was identified by his initials ("JBG" — Joshua B. Goldberg) as the person who verbally authorized these specific transfers. This was not a batch operation by the accounting department; it was an action taken at Goldberg's personal direction.
Verbal authority over trust funds. The notation "verbal" indicates Goldberg gave instructions orally — not by email, not through a formal written request, but by verbal command. This demonstrates a level of operational control over the trust account that goes beyond mere firm membership. Goldberg could pick up the phone, tell the accounting staff to move money between patent dockets, and it was done.
Control over Litman's client money. Account 36372 held funds belonging to King Faisal University — a client whose patent work was performed under Richard Litman's name. Goldberg was directing where those funds went, which patent dockets were funded, and how resources were allocated across Litman's practice.
The docket numbers tell the story. The four source dockets (32087.08, 32087.14, 32087.19, 32087.50) are individual KFU patent prosecution matters. By moving funds from these dockets back into the general trust, Goldberg was consolidating resources — an act of financial management over Litman's patent prosecution practice.
The full ledger shows a massive operation run under Litman's name:
| Metric | Value |
|---|---|
| Total receipts into Account 36372 | $10,737,709.88 |
| Total disbursements from Account 36372 | $10,653,478.01 |
| Ledger period | September 30, 2020 – November 20, 2024 |
| Total transactions | 871 |
| Inter-docket transfers | 375+ |
| KFU wire payments received | Multiple, including $265,715.42 (Sep 2022) and $546,419.74 (Nov 2022) |
| Final balance | $84,231.87 |
All of this money flowed through patent work where Richard Litman's name appeared as attorney of record. Goldberg's verbal authorization of fund movements within this account proves he was an active participant in managing the financial infrastructure of Litman's practice — not merely a passive firm partner.
In his Answer (Doc #65, January 20, 2026), Goldberg denies that he "caused" Litman's name to appear on patent records (paragraph 33). The JBGverbal entries directly contradict this denial. An individual who personally directs the movement of trust funds within a client account — funds generated by work performed under another attorney's name — is not a passive bystander. Goldberg exercised operational control over the financial side of the work that bore Litman's name.
The causal chain is clear: - Litman's name appeared on KFU patent filings as attorney of record - Those filings generated fee payments deposited into Account 36372 - Goldberg personally directed where those funds were allocated within the account - Goldberg therefore controlled the financial infrastructure that supported and sustained the use of Litman's name
Goldberg's affirmative defenses attempt to characterize the use of Litman's name as firm-level conduct for which he bears no personal responsibility. The trust ledger destroys this argument. The accounting system did not record these transfers as authorized by "NGM" or "the firm" — it recorded them as authorized by JBG, Joshua B. Goldberg, personally.
This is consistent with the broader evidence: Goldberg personally signed 16 of 21 Powers of Attorney, personally signed assignment cover sheets, and personally directed trust fund movements. Every layer of the patent prosecution operation — legal filings, assignment documents, financial management — bears Goldberg's personal fingerprints.
If Goldberg argues that only the firm (NGM/PLLC) — not he personally — is liable for the use of Litman's name, the trust ledger evidence undermines that defense. Goldberg did not act through corporate channels or formal firm processes. He gave verbal orders that were executed immediately. This level of unilateral personal control over firm trust funds is precisely the type of evidence that supports personal liability.
Each inter-docket transfer, each fund allocation decision, each verbal authorization represents another instance of Goldberg actively managing the practice that operated under Litman's name. The JBGverbal entries are four more cards in the deck — four more discrete acts of personal involvement in the commercial exploitation of Litman's professional identity.
All four JBGverbal transactions occurred on August 19, 2021 — more than 14 months after the June 15, 2020 statute of limitations cutoff. Goldberg was not winding down legacy matters. He was actively managing trust fund allocations for ongoing patent work bearing Litman's name, well within the actionable period.
Document: Trust Ledger for Account 36372 Client: King Faisal University Generated: June 19, 2025 Generated by: Schaefer, Deborah J. Accounting System: NGM Trust Accounting (entries numbered 2488664–3655xxx) Produced in: Litman v. Goldberg, Index No. 524343/2025