Date: 2026-04-15 Source: evidence/google_drive_download_20260415/
Each contains 4 Fidelity brokerage statements for Robert B Litman (uncle's father's estate/trust): - Robert B Litman Trust - Fidelity Statement - 6.30.2022.pdf - Robert B Litman Trust - Fidelity Statement - 7.31.2022.pdf - Robert B Litman Estate - Fidelity Statement - 6.30.2022.pdf - Robert B Litman Estate - Fidelity Statement - 7.31.2022.pdf
Relevance: Estate planning context only. May relate to uncle's Virginia revocable trust discussed in the August 2021 memo (see below). Not directly case-relevant.
Contains 3 large discovery-production PDFs from the AAA arbitration: | File | Size | Description | |------|------|-------------| | 0007 - Metlife Emails (RL_6018-6031).pdf | 448 KB | MetLife disability correspondence (Bates RL_6018-6031) | | 0008 - Meyer Emails (RL_6032-6814).pdf | 12.3 MB | Jerry Meyer email production (Bates RL_6032-6814, ~782 pages) | | 0009 - Bank Statements (RL_6815-9966).pdf | 45.3 MB | NGM bank statements (Bates RL_6815-9966, ~3,151 pages) |
Relevance: HIGH. The Meyer Emails (RL_6032-6814) may contain additional admissions from Jerry Meyer. The Bank Statements (RL_6815-9966) are a massive trove covering potentially all NGM bank accounts — this is 3,151 pages of bank records that could independently verify trust account movements, Freedom Bank transactions, and fee allocations. The MetLife emails document the disability claim process.
NOT a litigation plan — this is actually uncle's draft discovery demands (CPLR 3120/3130/3123) for the surviving Count V (Civil Rights Law ss 50-51). Narrowly tailored to name-use elements: - 5 Document Demand categories: (A) Use of name on patents/POAs/PTOL-85s; (B) Website/marketing/client communications; (C) Consent documents (targeting affirmative defenses); (D) Internal communications re name use decisions; (E) Revenue from name-use matters - 4 Interrogatories: All instances of name use (patent, website, client comms) with date/medium/purpose; consent basis; awareness of objection; business purpose - 5 Requests for Admission: Name on patents post-6/15/2020; no written consent; continued use after claiming termination; commercial value of name; no court order authorizing use - Pre-drafted objection rebuttals for each anticipated defense objection (dismissed claims, overbreadth, accounting, consent, privilege, first publication) - Execution order: Serve via NYSCEF, calendar 20-day deadline, prepare motion to compel framework, begin MSJ outline concurrently
Case Value: This appears to be a polished, ready-to-serve discovery set. Cross-check against whatever discovery was actually served to identify any demands that were not included or that should be updated based on post-drafting findings.
Uncle's comprehensive narrative memo to his lawyer (likely Merritt Green or another early counsel), covering his entire career history and current situation. Key revelations:
Practice History: - Started solo practice 1980, incorporated July 1, 1983 - Built practice using 1-800-4-PATENT and 4patent.com service marks — federally registered personally and licensed royalty-free to the firm - Payroll reached ~100 employees, revenues over $5M/year, handled 30,000+ matters - Lost $800,000 building dispute in 2008, pivoted to Middle East - By 2012, taking $600,000/year paycheck - Made ~20 trips to Colombia, Brazil, Peru, Uruguay; spoke at Amazon research institute - Founded Global Academic Innovation Network (5,000+ members) - State Department asked him to speak in Indonesia
B&P Period (2012-2017): - Exchanged LLO stock for B&P stock - B&P not interested in growing Arabic clients - Relationship was "not a good fit"
NGM Relationship: - Met Jerry Meyer at AUTM annual meeting 2016 - Goldberg = chemical engineer (Wash. U undergrad, GW JD); Meyer = electrical engineer (U Michigan, Franklin Pierce law) - Both at least 10 years younger than Litman - NGM's practice was mostly serving clients of foreign patent attorneys — "did not appear to me that they had many direct relationships with quality clients" - Last pre-disability trip: February 2020 (Josh met the final unmet client) - Last day in office: March 4, 2020
Disability Specifics: - Hands: numbness in right hand, left hand cramping when signing - Balance and coordination deteriorating "throughout my body by mid-June 2020" - Retained Dell & Schaefer (Florida disability law firm) - Filed with Northwestern Mutual (private) AND MetLife (employer) - Date of disability set to June 15, 2020
Financial Demands: - ~$200,000 through June 30, 2021 owed at time of writing - Additional ~$100,000 from KSU payments in early July - Wanted money put in trust while payment obtained - Wanted payments characterized as capital gains (personal goodwill purchase price), not ordinary income - Wanted payments directed to his Virginia revocable trust
MetLife/Benefits Issues: - Partners have $500,000 life insurance; non-partner plan had lesser amount - MetLife decided Litman no longer qualified for life insurance - Contract says Litman gets same benefits as co-managing partners - Stephen Dell interpreted that asset sale purchase price money should not offset disability income
Case Value: This memo is uncle's own contemporaneous account from August 2021 — before the arbitration escalated. It establishes: (1) the personal goodwill basis in his own words; (2) the 4patent.com marks as personally registered and royalty-free licensed; (3) his last day in office (March 4, 2020); (4) the $600K/year historical income benchmark; (5) the benefits dispute; (6) the MetLife/life insurance gap.
Complete email thread (Sept 22 - Oct 31, 2022) between Goldberg, Martha Long, Dr. Thamer Albahkali (KSU IPTL Director), and others. Key points:
Case Value: Confirms Findings #47, #46, and #29. Litman was actively involved in KSU collections through October 2022 at minimum. The ksu@4patent.com alias was the operational routing address. Goldberg was running this from Brooklyn.
Martha Long email (July 27, 2023) to Valencia Gray with payment allocation for incoming $31,870 DDI wire: - 12 line items across 6 dockets (33024.xx series) - Attorney's fees: $24,660.65 - USPTO/Associate fees: $7,209.35 - Work includes: Issue Fees, Amendments, RCE, PCT Application, Patent Application - CC'd to Accounting, Jerry Meyer, Joshua Goldberg, and DDI (ddi@4patent.com implied)
Case Value: Confirms Finding #65 (DDI/Dr. Al-Refaei as goodwill client) with actual payment documentation. DDI was paying $31,870 in July 2023 for patent work — revenue generated from a Litman-originated client while his name was on all filings. Adds concrete dollar figure to the DDI relationship.
Martha Long reply (July 24, 2023) to Valencia Gray re: $27,869 incoming wire from KISR. CC'd to Accounting, Jerry Meyer, Joshua Goldberg, and kisr@4patent.com.
Case Value: Documents another Litman-originated Middle East institutional client payment routed through a @4patent.com alias. Adds KISR to the list of active paying clients in the post-SOL period. Stacks with Finding #46 (kisr@ is one of the 50 @4patent.com aliases).
Complete email thread (April-July 2023) between Howard Kline and Sadeq Qasem regarding trademark "Dukhoon" (SN 97/474,121). Key details: - Litman CC'd on all correspondence (rlitman@nathlaw.com) — July 2023, post-arbitration - clientservice@4patent.com CC'd — another @4patent.com alias in use - PayPal payment to jgoldberg@Nathlaw.com — firm payments going to Goldberg's personal PayPal - $450 payment via PayPal for trademark work - Kline identifies as "Partner" (not associate) - Docket: 200534.01T
Case Value: (1) Litman's name still on client correspondence July 2023 for trademark work; (2) confirms clientservice@4patent.com alias active (Finding #46); (3) PayPal payments routed to Goldberg personally — potential trust accounting issue; (4) small individual client example showing breadth of Litman-originated client base beyond the major institutional clients.
Standard employee handbook for "Nath and Associates PLLC, DBA: Nath, Goldberg & Meyer, DBA: The Nath Law Group." Key provisions: - DC PLLC with Virginia license (no mention of NY license — consistent with Finding #68) - At-will employment - Standard equal opportunity, harassment, leave policies - Entity described as "112 S. West Street, Alexandria, VA 22314"
Case Value: Confirms NGM's corporate identity and jurisdiction. Notable for what it does NOT contain: no mention of Litman, no special provisions for "Senior Counsel" arrangements, no provisions on name use or personal goodwill. Supports the argument that Litman's arrangement was entirely governed by the Combination Agreement, not by the employee manual.
Pre-Litman version of the same manual. "Nath and Associates PLLC, DBA: Nath, Goldberg, and Meyer, DBA: The Nath Law Group." Includes California license (dropped in 2022 version). Same address, same structure.
Case Value: Minimal. Shows the firm existed before Litman joined (2017). The California license dropping between 2016 and 2022 is a minor detail.
This is a music management agreement for "BonnieXClyde" (Daniel Grant Litman and Paige Lopnyski) with Cinder Mgmt. Personal to the user (nephew), not related to the NGM case.
SEC filing — ISDA 2002 Master Agreement between Bank of America, N.A. and LKQ Corporation. Completely unrelated to the case. Appears to be a reference document or accidental inclusion.
| File | Description |
|---|---|
| 2020.06.04-2d_Amendment to NMG_Agreement_Litman.docx | DRAFT Second Amendment to the Combination Agreement — TWO versions in one file (lawyer-drafted version + uncle's own version). Contains the exact language of the disability amendment, 20% earnout provisions, acceleration clauses, audit rights, benefits obligations, and personal goodwill characterization. The uncle's version (starting at paragraph 31) is more detailed and references specific dollar figures and events. |
| 2023.05.05 - Crime Fraud and Abuse Exception Memo RCL.docx | Blankenship & Keith memo arguing Goldberg's June 29, 2022 email to Merritt Green concealing the $110,000 trust fund disbursement is NOT privileged under the crime-fraud exception. Proves: (1) $110,000 from Litman's trust subaccount #140400 was used to pay down NGM's line of credit on Dec 22, 2021; (2) Goldberg concealed this from his own lawyer; (3) Trust ledger report (Litman Exhibit 12) is either materially false or inconsistent with the actual trust balance. |
| Underwater Position.docx | Merritt Green (NGM's counsel) Dec 27, 2022 email to arbitrator and parties: (a) NGM received ~$1.4M from KSU on Dec 22, 2022; (b) additional $129K expected within 60 days; (c) ~$600K received Sept 2022 earmarked for trust; (d) NGM's position = no obligation to pay Litman while "underwater" on receivables; (e) NGM "diligently" sending quarterly reports; (f) "at Mr. Litman's request, they have maintained his health insurance longer than required." Contains Green's admission that most arbitration issues "will be resolved with this Litman client payment." |
| King Faisal University.docx | Uncle's memo (to "Bob," likely attorney Bob Scully) documenting KFU growth: $3M annual budget projected, ~$550K in wires received Nov 2022, up to Disclosure #400. Complains about NGM's "inadequate" accounting/workflow/deadline management. Asks whether prospective revenue can be factored into damages. |
| 2023.1.18 Motion for Partial Summary Judgment | Arbitration MSJ filing (both .docx and .pdf) |
| 2023.2.9--Reply Motion to Dismiss--FINAL.pdf | Arbitration reply brief |
| 2023.5.24 Post Arbitration Brief--FINAL.pdf | Post-arbitration brief |
| Interim Award - Litman v. Nath & Associates, et al..pdf | Interim arbitration award |
| Award - Litman v. NGM, et al..pdf (5 copies) | Final arbitration award (already obtained) |
| 2012 Becker & Poliakoff agreements.pdf | Original B&P agreements (pre-NGM era) |
| ROYALTY-FREE LICENSE from Litman to LLO.pdf | The royalty-free license for the 4patent.com marks — ties to Finding #42 |
| MetLife - Dell email 060.01.21 no offset if asset sale.pdf | Dell & Schaefer opinion: MetLife cannot offset disability payments against asset sale proceeds |
| J. Goldberg Doc Demands.pdf | Goldberg's document demands in arbitration |
| 2023.1.27 Document Requests to Litman.pdf | NGM's document requests to Litman in arbitration |
| 2023.2.7 Objections to Document Requests--FINAL.pdf | Litman's objections |
| Emails re benefits and distributions.pdf | Benefits and distribution correspondence |
| NGM - Acknowledgement of deducting money from Revenue...pdf | NGM acknowledging contractor deductions from revenue |
| NGM - Benefits co-managing partners...December 2017 emails with Jerry Meyer.pdf | Meyer emails about benefits (Dec 2017) |
| NGM 2017 email re benefits.pdf | 2017 benefits correspondence |
| 32-1 Brief iso Motion to Stay.pdf | Brief in support of motion to stay |
| Blankenship & Keith invoice.PDF / invoice 2.PDF | Attorney invoices from arbitration counsel |
| Litman_Post Supremacy Federalism_FINAL_DRAFT.pdf (3 versions) | Uncle's academic paper on Post-Supremacy Federalism |
| DCC Final Draft MAY 3.docx (multiple copies) | Academic paper drafts |
| Community Food Grant Program.docx/.pdf | Appears to be an unrelated grant proposal |
| NEW PATIENT PACKET VERSION4 20.docx/.pdf | Medical patient intake form (personal) |
| httpswww.uspto.govsitesdefaultfilesdocumentsAbavsUSPTO.pdf.pdf | ABA vs USPTO document |
| US020220062622A120220303.pdf | USPTO patent publication |
| 33090.41U.pdf, 33103.73U.pdf, 33120.91U.pdf, 33120.93U.pdf, 33125.85A.pdf | Patent-related documents (docket numbers) |
| 405823.pdf | Unknown — likely a patent number or filing |
| IMG_0722.jpg (2 copies) | iCloud photo (already in evidence set) |
| mime-attachment.eml / mime-attachment 2.eml | Email attachments — need investigation |
| Law Insider [2lZwwoe68KeT60qQAUijy0].docx | Legal reference document (boilerplate contract language) |
| 20230822_PC_auto.pdf | Unknown — date suggests Aug 22, 2023 |
| Untitled document.docx (4 copies) | Unknown content |
From the Crime Fraud memo: Goldberg/Meyer transferred all $110,000 from Litman's trust subaccount #140400 ("Litman, Richard C. General Matter ref. 36056") to pay down NGM's line of credit on December 22, 2021. This left a zero balance in Litman's client trust account. Goldberg then concealed this from his own counsel (Merritt Green), who believed funds were still held in trust. This is a direct RPC 1.15 violation (commingling/conversion) and supports the crime-fraud exception to attorney-client privilege.
Cross-references: Findings #19, #26, #27, #64, #67 (trust accounting violations). This is the most concrete single-act conversion documented: $110K from a named client trust subaccount to pay down a firm line of credit.
NGM's own counsel wrote to the arbitrator: "NGM interprets its contractual obligation that it did not have to make payments to Mr. Litman so long as it was 'underwater' with outstanding receivables." This admission that NGM was withholding Litman's payments based on a unilateral "underwater" interpretation — never agreed to by Litman — is an independent breach. Green also admitted "most of the issues underlying this arbitration will be resolved with this Litman client payment" — acknowledging the debt.
The file contains TWO versions of the Second Amendment: 1. Lawyer-drafted version (paragraphs 1-21): Formal legal language, covers personal goodwill characterization, 5-year earnout, benefits continuation, revenue definition (gross fees, no offsets), quarterly reporting with 15-day deadline, audit rights, acceleration on change of control, assignment to trust 2. Uncle's own version (paragraphs 32+): More detailed, includes specific dollar figures, references March 4, 2020 as last day in office, mentions $25,000/month advance, discusses exigent circumstances (pandemic, Jerry Meyer's cardiac event), adds trust segregation requirements, references "joint and several" liability of NGM/Goldberg/Meyer
Key provisions in the lawyer-drafted version: - Revenue = "gross fees collected by NGM from clients originated by Litman, and is not to be offset or reduced by the cost of generating such revenue, including, without limitation, the cost of independent contractors" - Benefits: medical, dental, vision, health care insurance + professional liability insurance for 5 years - Audit rights: independent third party, quarterly, during normal business hours, NGM pays costs if deficiency > 5% - Acceleration: if Change in Control, liquidation, dissolution, or death/disability of Goldberg or Meyer - 20% formula: explicitly stated in the acceleration clause formula
Case Value: This is the document that was apparently never fully executed (the signature blocks are blank). Uncle's version is more protective. The lawyer-drafted version's revenue definition ("gross fees... not to be offset") directly contradicts Goldberg's "underwater" position.
The August 2021 memo states uncle was taking "$600,000 per year" paycheck by 2012 — establishing a pre-NGM income benchmark for damages context.
Uncle confirms: "utilizing my 4PATENT family of service marks starting with 1-800-4-PATENT and ultimately including the URL and related trademarks which were federally registered by me personally and licensed royalty free to the law firm." This is uncle's own contemporaneous statement that the 4patent.com marks belong to HIM, not to NGM.
Client payment (Sadeq Qasem, $450) directed to Goldberg's personal PayPal. If client trust funds were received via PayPal to Goldberg's personal account, this is a per se RPC 1.15 violation (trust funds must go into a designated trust account, not a personal PayPal).