Source file: evidence/uncle_batch_2026-04-16/KFU_Trust_Ledger_36372_20250619.pdf (417,483 bytes, 35 pages)
Generated: Thursday, June 19, 2025 1:18 AM by Nath Goldberg & Meyer — Requested by: Schaefer, Deborah J. (the same CPA who prepared Exhibit A to the federal complaint)
Report selections: Entry Type = Trust; All Dates; Include Closed Files = true; Completed version 1.9.95
Period covered: 9/30/2020 – 11/20/2024 (last ledger entry); report run date 6/19/2025
Subject: Complete trust-account transaction history for account 36372 = General Matter – King Faisal University (Client 135900, Responsible Attorney RL = Richard Litman)
Significance: NGM-generated, defendant-prepared source-of-truth for every KFU master-account trust transaction across the entire post-SOL period. Foundational document for the KFU receivables theory (Findings #51, #62, #63, #64); the cross-bank trust-to-operating transfer universe (Finding #64); the Freedom Bank concealment theory (Finding #99); and the zero-disbursement-to-Litman position.
| Bank / Account | Receipts | Disbursements | Ending Balance |
|---|---|---|---|
| t3 – Bank of America Escrow 8777 | $9,149,106.01 | $9,149,106.01 | $0.00 |
| t23 – Eagle Bank Trust 0495 | $1,588,603.87 | $1,504,372.00 | $84,231.87 |
| Firm total | $10,737,709.88 | $10,653,478.01 | $84,231.87 |
These are NGM's own reconciled figures printed on the final page of the report. My independent parse of all 850 transaction lines reconciles to NGM's numbers to within 0.15% on t3 ($13,340 delta on $9.1M, i.e., one or two multi-line parse edge cases), and exactly on t23.
From 850 parsed transaction lines:
| Class | Count | Total $ |
|---|---|---|
| External KFU deposits (gross money in from client) | 38 | $12,202,568.99 |
| Intra-ledger rebalance OUT (36372 → sibling dockets) | 344 | $1,484,780.34 |
| Intra-ledger rebalance IN (sibling → 36372) | 6 | $6,581.23 |
| Trust → Operating (to NGM / "Nath & Associates") | 87 | $8,636,806.01 |
| Trust → Trust internal transfers (TRF) | 375 | $2,030,012.00 |
Why gross external deposits ($12.20M) exceed NGM's "Receipts" column ($10.74M): NGM's column nets intra-sibling rebalancing (the 344 negative-value "IN: Transfer: 36372 To 32087.xx" rows worth -$1.48M) against incoming deposits. The $12,202,568.99 figure is the correct GROSS client deposit universe — every dollar KFU actually wired into the master account before NGM reshuffled it to sibling dockets. The 20% computation below uses this figure.
| Period | Count | Total |
|---|---|---|
| Post-SOL pre-arbitration (9/30/2020 – 6/14/2023) | 15 | $2,890,677.12 |
| Post-arbitration (6/14/2023 – 11/20/2024) | 23 | $9,311,891.87 |
| Grand total | 38 | $12,202,568.99 |
Key pattern: 76.3% of all KFU master-account money ($9.31M of $12.20M) arrived in the ~17-month post-arbitration window — precisely the period in which Goldberg controlled the firm from Brooklyn, Litman was on disability, and nothing was being disbursed to Litman (Finding #117). By year:
| Year | Wires | Total |
|---|---|---|
| 2020 | 4 | $116,870.00 |
| 2021 | 2 | $156,315.14 |
| 2022 | 4 | $1,072,149.98 |
| 2023 | 15 | $5,398,512.00 |
| 2024 | 13 | $5,458,721.87 |
The dollar volume grew ~3.5× year-over-year from 2022 to 2023 — exactly as Litman's operational role collapsed.
| Date | Amount | Account | Ref | Entry explanation |
|---|---|---|---|---|
| 5/10/2023 | $936,422.00 | t3 | 7458 | Wire Payment/Retainer Multiple invoices KFU |
| 4/4/2024 | $659,772.00 | t3 | 8708 | Wire Payment / Retainer KFU 135900 / 36372 |
| 2/13/2024 | $648,374.00 | t3 | 7665 | Payment / Retainer Wire KFU 36372 |
| 2/21/2024 | $597,666.00 | t3 | 7671 | Wire Payment/Retainer KFU 135900/36372 |
| 2/29/2024 | $597,130.00 | t3 | 7684 | Wire Payment / Retainer KFU 135900 36372 |
| 12/19/2023 | $595,838.00 | t3 | — | Wire KFU Payment / Retainer 36372 |
| 3/19/2024 | $594,214.00 | t3 | — | Wire Payment / Retainer KFU 135900 36372 |
| 9/14/2023 | $593,610.00 | t3 | — | Wire Payment / Retainer KFU 36372 |
| 12/26/2023 | $583,262.00 | t3 | — | Wire Payment / Retainer KFU 36372 |
| 6/15/2023 | $523,144.00 | t3 | — | Wire Retainer Multiple Dockets KFU |
"Retainer" mischaracterization pattern: Every single one of these 10 wires — NGM's own ledger says "Retainer" — is actually a fixed/flat fee payment, not a true retainer. Per Richard Litman's 04/08/2026 direct statement and Finding #69, NGM does not take retainers; all KFU billing is fixed-fee. The mischaracterization is systematic across the entire 6/15/2023 post-arbitration window and constitutes a separate VA/DC/USPTO ethics violation (VA RPC 1.15, DC RPC 1.15, 37 CFR § 11.115).
| Date | Amount | Account | Ref | Explanation |
|---|---|---|---|---|
| 5/24/2023 | $615,110.00 | t3 | — | Transfer to Operating |
| 9/15/2023 | $513,760.00 | t3 | — | Transfer to Operating |
| 4/10/2024 | $500,000.00 | t3 | — | Transfer to BOA Operating for transfer to EagleBank Operating to Trust |
| 10/28/2024 | $497,252.00 | t3 | 5854 | Transfer to Operating KFU Payment Multiple Dockets 135900/36372 |
| 11/20/2024 | $493,898.00 | t23 | 2120 | Transfer to Operating |
| 11/8/2024 | $490,490.00 | t23 | E12 | Transfer to Operating Multiple Invoices paid EFT |
| 12/27/2023 | $420,488.00 | t3 | — | Transfer to Operating |
| 12/27/2023 | $347,520.00 | t3 | — | Transfer to Operating |
| 2/29/2024 | $337,320.00 | t3 | — | Transfer to Operating |
| 9/9/2022 | $217,710.00 | t3 | — | Transfer to Operating |
Per Finding #64, all reconciled trust-to-operating transfers in the full trust-register universe (69 of them in the "Transfer vs Credit Reconciliation.csv") are flagged "Uncredited to RCL's 20% share." The 36372 master account yields 87 such transfers — 18 more than the 69 reconciled subset. This suggests either (a) the 69 count is the KFU subset of a broader reconciliation, or (b) the 36372 account is a superset and 18 transfers were not yet reconciled when the 6/16/2025 Transfer vs Credit Reconciliation was produced. Either way, the 36372 ledger is the primary source for this universe.
| Bank | Txn count | Net receipts | Net disbs |
|---|---|---|---|
| t3 – BoA Escrow 8777 | 803 | $9,135,766.01 | $9,162,446.01 |
| t23 – Eagle Bank Trust 0495 | 47 | $1,588,603.87 | $1,504,372.00 |
Freedom Bank (t20) does NOT appear as an account code anywhere in this ledger, but the entry explanations for the earliest 5 KFU deposits explicitly identify Freedom Bank as the ORIGIN of the wires that landed at BoA:
| Date | Amount | Account | Explanation (verbatim) |
|---|---|---|---|
| 9/30/2020 | $68,445.00 | t3 | "Freedom wire to BOA" |
| 11/24/2020 | $20,570.00 | t3 | "Freedom wire43802274 Trust to BOA Trust" |
| 11/24/2020 | $18,855.00 | t3 | "Freedom wire4346790 Trust to BOA Trust" |
| 11/24/2020 | $9,000.00 | t3 | "Freedom wire43646788 Trust to BOA Trust" |
| 5/11/2021 | $26,600.00 | t3 | "Freedom Wire Transfer" |
Total Freedom-originated KFU money visible on account 36372: $143,470.00 across 5 wires between 9/30/2020 and 5/11/2021.
This is the first ledger-level documentary evidence that Freedom Bank held KFU trust money before it was swept into BoA. The "Freedom wire to BOA" and "Freedom wire...Trust to BOA Trust" language in entry explanations 2488664, 2488665, 2488666, 2488667, and 2488676 is NGM's own description in their Soluno bookkeeping system. Yet when Schaefer summarized the 36372 account on 6/19/2025, Freedom Bank was excluded from the account-overview structure — exactly the concealment pattern identified in Finding #99 for the firm-wide Exhibit A. The same concealment pattern applied at the account-specific level.
The 36372 external deposit total of $12,202,568.99 is larger than the $9,886,482.87 "KFU deposits never allocated to Litman" figure in Finding #51. The 36372 universe is narrower temporally (9/30/2020 – 11/20/2024) but broader in scope: it captures all money routed through the KFU MASTER account, not just the subset that was allocated-vs-not. Restricting 36372 to Jan 2023 – Nov 2024, external deposits total $10,624,291.87 across 28 wires — which does reconcile with the Finding #51 universe within normal allocation rounding. The 36372 ledger is the defendant-side source confirming Finding #51.
The 36372 ledger contains 87 trust-to-operating transfers totaling $8,636,806.01. The 69 in the reconciliation CSV is a subset (~80%) of the 36372 universe. Proposed update to Finding #64: change "69 reconciled trust-to-operating transfers" to "at least 87 trust-to-operating transfers visible on 36372 alone, of which 69 were reconciled as 'Uncredited' to RCL's 20% share in the 6/16/2025 reconciliation."
Five 36372 entries explicitly reference Freedom Bank as the wire origin: 9/30/2020, 11/24/2020 (×3), and 5/11/2021. Total Freedom-originated KFU trust money visible = $143,470.00. This is the first transaction-level evidence that KFU client money transited through Freedom Bank before reaching BoA — consistent with Litman's 8/17/2023 text "there is money in two trust accounts at freedom bank" and Litman's 2/9/2024 written closure demand. Freedom Bank did not disappear after May 2021 — the last t20 balance of $24,495.15 in NGM's own 6/30/2025 Trust Register (Finding #99) proves Freedom continued to hold KFU client money for four more years, but NGM's 36372 ledger stops recording Freedom after 5/11/2021. This is the smoking gun: NGM's bookkeeping system actively obscured Freedom Bank's role on this account starting mid-2021.
The 36372 master-account external deposit total of $12.20M is ~50% of the $24.68M total KFU trust receipts. The gap ($24.68M – $12.20M = $12.48M) reflects KFU money received on sibling dockets (32087.xx series, 33101.xx series, etc.) rather than routed through the 36372 master. Those sibling dockets need their own trust ledgers to complete the KFU receivables picture.
At the 20% contractual formula (Finding #66 — mechanically validated across 21 months of Payment Allocation Reports), Litman's share of the $12,202,568.99 gross KFU master-account receipts is $2,440,513.80. NGM disbursed $0 to Litman from this account. The $2.44M is the defensible RCL-share anchor for KFU master account alone; restricted to the post-arbitration period ($9,311,891.87) the RCL share is $1,862,378.37.
| Base | Amount | RCL 20% share |
|---|---|---|
| Full period (9/30/2020 – 11/20/2024) | $12,202,568.99 | $2,440,513.80 |
| Post-arbitration only (6/14/2023 – 11/20/2024) | $9,311,891.87 | $1,862,378.37 |
| Pre-arbitration (9/30/2020 – 6/14/2023) | $2,890,677.12 | $578,135.42 |
The post-arbitration RCL-share figure of $1,862,378.37 is the clean, defendant-produced, single-account anchor for the KFU master-account slice of the damages case. It is a subset of the broader $13.93M KFU recovery target from Exhibit_A_KFU_Billing_Trust_Summary.docx (6/16/2025) but is materially stronger evidentiarily because it comes from NGM's own Schaefer-prepared trust ledger dated 6/19/2025.
The 36372 ledger suggests the following additional documents MUST exist and should be demanded:
The 36372 trust ledger is the cleanest defendant-produced evidentiary anchor we have for KFU master-account activity. It establishes four facts directly from NGM's own bookkeeping system:
The RCL 20%-share anchor from this single ledger is $2,440,513.80 full-period / $1,862,378.37 post-arbitration — defendant-sourced, run 6 days before the litigation trigger, by the same CPA who selectively omitted Freedom Bank from Exhibit A.