Case: Litman v. Goldberg, Index No. 524343/2025 Court: Supreme Court of the State of New York, Kings County Judge: Hon. Brian L. Gotlieb, J.S.C. Surviving Claim: Count V -- NY Civil Rights Law Sections 50-51 (Misappropriation of Name) Prepared: April 16, 2026 Classification: Attorney Work Product / Privileged
This timeline documents the deliberate, systematic pattern of Litman name-use that began immediately upon the June 15, 2020 SOL cutoff date. It tracks three parallel threads:
The evidence proves the name-use pattern did not gradually emerge -- it was already fully operational on June 15, 2020 and continued without interruption.
The kfu@4patent.com email alias -- hosted on Litman's personal domain, administered by NGM's Microsoft 365 tenant (DKIM records point to nathlaw.onmicrosoft.com) -- was operational no later than September 21, 2019:
| Date | From | Subject | Significance |
|---|---|---|---|
| Sept 21, 2019 | Martha Long | "Notice of Allowance for King Faisal University -- Docket 32087.15" | Earliest kfu@4patent.com email in the corpus. CC'd to kfu@4patent.com. |
| Oct 3, 2019 | Martha Long | "RE: Notice of Allowance for King Faisal University -- Docket 32087.15" | Continued use of alias |
| Nov 5, 2019 | Martha Long | "Incoming Wire Notification -- King Faisal University" | Wire notification routed through kfu@4patent.com |
Key fact: By the time Goldberg and Litman discussed Litman's disability in June 2020, the kfu@4patent.com infrastructure was already fully operational. Goldberg did not need to "set up" the Litman-domain infrastructure -- he simply kept it running.
USPTO Customer Number 37833 listed "Richard C. Litman / Nath, Goldberg & Meyer" as the correspondence address for ALL patent filings. Every Filing Receipt, Office Action, and Notice of Allowance generated by the USPTO for KFU work was addressed to this block. This remained unchanged until Goldberg unilaterally removed Litman's name on May 1, 2025 (Finding #107).
This is the foundational moment for the entire name-use pattern.
June 7, 2020 -- Richard Litman to Joshua Goldberg ("Re: How is Jerry? You?"):
"Both you and Jerry mean so much to me. It is more than business. I have never put as much trust in other people as I have in you and Jerry. I have a personal stake in your wellbeing."
Litman discloses his disability and his declining condition.
June 8, 2020 -- Goldberg responds:
"Wow, that's quite the update. You gave me a lot to think about. First, more important to me than anything else, is that you look after yourself and take care of your personal health."
June 8, 2020 -- Litman responds:
"Our agreement doesn't mention what happens in the event of my disability. My initial thought was we need an amendment and I hired a lawyer to prepare one."
June 9, 2020 -- Litman (unsent/draft or separate email):
"The largest investment I have right now is in you and Jerry. Jerry is down, I am declining and we are in the middle of a Pandemic."
Goldberg's Concealment Directive (June 2020) -- per iCloud photo evidence (IMG_0736, IMG_0737), Goldberg wrote:
"my strong preference is that we keep this between you and I" -- regarding Litman's disability, especially from Middle East clients. "There is absolutely no need to give our clients any (unjustified) reason to worry about our performance or capabilities."
This is the genesis of the name-use pattern: the deliberate decision to keep Litman's name prominent while concealing his reduced role from clients.
The SOL cutoff (June 15, 2020) produced zero interruption in KFU work under Litman's name. Martha Long continued sending KFU correspondence through kfu@4patent.com and to KFU faculty, all under the "NATH, GOLDBERG & MEYER" letterhead, with Litman's name on CN-37833 as the USPTO correspondence address for every filing.
| Date | Actor | Activity | Bates/Source |
|---|---|---|---|
| June 2, 2020 | Martha Long | "Need Passport Copy for Inventor at King Faisal University -- Docket 32087.22" -- TO: dean.dsr@kfu.edu.sa, CC: kfu@4patent.com | C2051472_ND0000180376 |
| June 7, 2020 | Martha Long | "PCT Communications for King Faisal University -- Docket 32087.21" -- TO: msaikhan@kfu.edu.sa, CC: kfu@4patent.com | ND0001 |
| June 8, 2020 | Sherry Palmore | "Docket 32087.18 Official Filing Receipt for King Faisal University" -- TO: dean.dsr@kfu.edu.sa, kfu@4patent.com | ND0001 |
| June 9, 2020 | Martha Long | "Need to correct the letter for Docket 32087.25" -- internal, CC: kfu@4patent.com -- references Dr. Mohamed Salem Al-Saikhan, Dean of Scientific Research | ND0001 |
| June 9, 2020 | Martha Long | "Issue Fee Paid for Docket Number 32087.19 -- King Faisal University" -- CC: kfu@4patent.com | ND0001 |
| June 9, 2020 | Martha Long | "Completed CIP Application for King Faisal University -- Docket 32087.25" -- TO: KFU faculty, CC: kfu@4patent.com. Body includes "Combination Assignment" attachment. | ND0001 |
| June 11, 2020 | Martha Long | "Office Action for King Faisal University -- Docket 32087.09" -- invoice attached | ND0001 |
| June 11, 2020 | Martha Long | "Deadline to File PCT and GCC Applications for King Faisal University -- Docket 32087.14" | ND0001 |
| June 11, 2020 | Richard Litman | "FYI -2010 visit to KFU" -- FROM: rlitman@nathlaw.com TO: jgoldberg@nathlaw.com, CC: kfu@4patent.com. Litman shares photos of his 2010 KFU visit: "This wasn't my first trip there." | C2051472_ND0000269194+ |
| June 11, 2020 | Joshua Goldberg | "RE: FYI -2010 visit to KFU" -- Reply TO: rlitman@nathlaw.com, CC: kfu@4patent.com: "Wow, that's really nice! I hope it was a good presentation... We'll work on getting yo[u]..." | ND0001/ND0002 |
| June 12, 2020 | Martha Long | "RE: Completed CIP Application for King Faisal University -- Docket 32087.25" -- TO: hhanieh@kfu.edu.sa | ND0001 |
| June 13, 2020 | Martha Long | Further correspondence on Docket 32087.25 revisions | ND0001 |
| June 14, 2020 | Martha Long | "GCC Application Filed for King Faisal University -- Docket 32087.22" | ND0001 |
| June 15, 2020 | Martha Long | "GCC Application Filed for King Faisal University -- Docket 32087.22" -- ON THE SOL CUTOFF DATE ITSELF: "Our staff has now reviewed the documents. We need the documents notarized and then authenticated at the ministry of foreign affairs as indicated at the bottom of the POA and assignment." CC: kfu@4patent.com | ND0001 |
| June 16, 2020 | Martha Long | "UAEU and KFU" -- TO: jgoldberg@nathlaw.com. Goldberg following up on KFU payments. | ND0001 |
| June 16, 2020 | Joshua Goldberg | "Re: UAEU and KFU" -- Reply to Martha acknowledging KFU/UAEU payment status. Goldberg actively managing KFU client finances one day after SOL cutoff. | ND0001/ND0002 |
| June 16, 2020 | Martha Long | "32087.14" -- CC: kfu@4patent.com. "At Dick's request I am attaching the comments received from KFU for the Office Action in this case." Litman actively directing KFU work post-SOL. | ND0001 |
| June 17, 2020 | Martha Long | "Revised CIP Application for King Faisal University -- Docket 32087.25" | ND0001 |
| June 18, 2020 | Martha Long | "Patent Application Form-Dr. Faheem Ahmed" -- new KFU disclosure received | ND0001 |
| June 19-29, 2020 | Martha Long | Multiple KFU correspondence items -- 32087.25 revisions, GCC formalities, wire notifications | ND0001 |
50 KFU-specific emails in June 2020 alone -- including direct communications with KFU faculty, USPTO filings, and internal coordination, all flowing through kfu@4patent.com on Litman's personal domain.
June 11, 2020 -- Litman himself CC's kfu@4patent.com: Litman shares his 2010 KFU visit photos with Goldberg, CC'ing the KFU alias. This shows Litman was actively engaged with the KFU relationship and his name was being used with his knowledge at this stage -- but the concealment directive had just been established days earlier.
June 15, 2020 -- Zero interruption: The very day Goldberg would later claim the Combination Agreement terminated, KFU work continued without pause. Martha Long was handling POA and assignment formalities for KFU's GCC application.
June 16, 2020 -- Goldberg managing KFU payments: One day after the supposed termination, Goldberg is personally tracking KFU payment status and directing Martha on financial follow-up.
"At Dick's request": Martha's June 16 email explicitly states she is acting "At Dick's [Litman's] request" on KFU office action work, proving Litman was still directing substantive patent prosecution for KFU.
| Date | Actor | Activity | Significance |
|---|---|---|---|
| July 8, 2020 | Goldberg | "Completed Patent Search for King Faisal University -- Docket 32087.28" -- Goldberg directing Lafave on KFU PCT filing strategy, CC: Litman | Goldberg managing KFU prosecution decisions |
| July 14, 2020 | Goldberg | "UAEU & King Saud - Trust" -- TO: Martha Long, CC: Richard Litman. "With the recent payments from KSU and UAEU, I wanted to make sure we took all the money we were eligible to take. So I had Kim generate the attached trust reports for these clients." | Goldberg personally directing trust account fund extraction one month post-SOL. Litman CC'd but Goldberg controlling. |
| July 17, 2020 | Goldberg | "2nd Quarter" -- Sends quarterly financial documents to Litman. | Financial reporting continues |
| July 27, 2020 | Goldberg | "Re: KFU" -- TO: rlitman@nathlaw.com. "Just finished the call with KFU, the Dean asked if you would be joining us and sends his best." Further: "There are some things we need to look into..." | KFU Dean still expects Litman's participation. Goldberg conducting KFU calls and reporting back to Litman. |
| July 27, 2020 | Goldberg | Multiple "RE: KFU" follow-ups with Litman throughout the day | Continuous KFU coordination |
74 KFU-specific emails in July 2020 -- the highest single month in the June 2020-Dec 2021 window.
| Date | Actor | Activity |
|---|---|---|
| Aug 19, 2020 | Goldberg | "*** REMINDER *** Notarized Documents Needed for the GCC from King Faisal University -- Docket 32087.22" -- Goldberg writing directly to Dr. Mohamed at KFU about legalization requirements |
| Aug 20, 2020 | Goldberg | Follow-up to Dr. Mohamed with attachments |
| Aug 25, 2020 | Goldberg | "Online meeting" -- CC: Litman. Goldberg volunteering to speak with Dr. Salman Al-Sabah at Kuwait University: "I would be happy to speak with Dr. Salman Al-Sabah." |
| Aug 28, 2020 | Goldberg/Litman | "Kuwait University" -- strategic discussion about university patent rankings. Litman: "I picked up on 'flagship' university comparison. They could be number 3 with some effort." |
| Aug 31, 2020 | Goldberg | Further GCC communication to Dr. Mohamed re: docket 32087.22 |
52 KFU-specific emails in August 2020.
| Date | Event | Amount | Detail |
|---|---|---|---|
| Sept 30, 2020 | FIRST KFU TRUST DEPOSIT post-SOL | $68,445.00 | "King Faisal University -- Freedom wire to BOA" -- Wire from Freedom Bank to Bank of America Trust account (t3), Account 36372. Entry #2488664. |
This $68,445 wire was the first KFU trust receipt into Account 36372 in the post-SOL period. It arrived via Freedom Bank (the undisclosed third trust account -- Finding #99), confirming that KFU payments were flowing through Freedom Bank infrastructure that was later closed in the July 2025 spoliation event.
| Date | Actor | Activity |
|---|---|---|
| Sept 2, 2020 | Goldberg/Litman | "Preliminary feasibility study" -- Zoom call with Sabah Al-Ahmad Center, Litman joining by phone. Goldberg sharing Zoom credentials. |
| Sept 3, 2020 | Goldberg/Litman | "Kuwait vs GCC" -- collaborative analysis of university patent rankings for client presentation to Kuwait University |
| Sept 4, 2020 | Goldberg/Litman | "SACGC KNPC Draft SOW" -- Goldberg and Litman jointly preparing Statement of Work for KNPC |
| Sept 14, 2020 | Goldberg | "FURTHER URGENT REMINDER *** Payment from King Saud University" -- to Litman: "I think it is time to put a hold on filing new applications for them again until we get paid." |
| Sept 14, 2020 | Goldberg/Litman | "Request for a meeting -- Qatar University" -- both participating in QU call. Goldberg: "I thought your interjection was good, completely agree about know, like, and trust." |
| Sept 26, 2020 | Goldberg | Direct email to Dr. Mohamed at KFU re: GCC legalization documents |
| Sept 30, 2020 | Goldberg | Further follow-up with KFU on receipt of legalized POA and assignment for docket 32087.22 |
56 KFU-specific emails in September 2020.
| Date | Direction | Amount | Description |
|---|---|---|---|
| Sept 30, 2020 | IN | $68,445.00 | Freedom wire to BOA -- first post-SOL KFU deposit |
| Oct 2, 2020 | OUT | $68,445.00 | Transfer to Nath & Associates -- "King Faisal 36372" -- entire deposit swept to operating within 2 days |
| Nov 24, 2020 | IN | $20,570.00 | Freedom wire43802274 Trust to BOA Trust |
| Nov 24, 2020 | IN | $18,855.00 | Freedom wire4346790 Trust to BOA Trust |
| Nov 24, 2020 | IN | $9,000.00 | Freedom wire43646788 Trust to BOA Trust |
| Nov 25, 2020 | OUT | $(1,100.00) | Transfer to 32087.08 -- "Dup. pymt 9.30.2020" |
| Nov 25, 2020 | OUT | $(100.00) | Transfer to 32087.09 -- "PTO future filing" |
| Nov 25, 2020 | OUT | $(3,000.00) | Transfer to 32087.14 -- "dup pymt 9.30.2020" |
| Nov 25, 2020 | OUT | $(300.00) | Transfer to 32087.25 -- "to Trust for IDS" |
| Nov 25, 2020 | OUT | $42,315.00 | Transfer to Nath & Associates -- "King Faisal Univ." |
| May 11, 2021 | IN | $26,600.00 | Freedom Wire Transfer |
| May 18, 2021 | OUT | $26,210.00 | Transfer to Operating |
Key observation: ALL three November 2020 deposits arrived via Freedom Bank wire transfer, confirming the Freedom Bank-to-BOA pipeline was the standard route for KFU payments. This same Freedom Bank account was closed in the July 2025 spoliation event.
Total KFU trust activity through May 2021: $144,070.00 in receipts, $136,870.00 in disbursements -- all under Litman's name as attorney of record.
Four trust account transfers on this date are annotated with "JBGverbal 8.18.2021" -- proving Goldberg verbally authorized fund movements within Account 36372:
| Entry No. | From Docket | Amount | Authorization |
|---|---|---|---|
| 2488679 | 32087.50 -> 36372 | $298.00 | JBGverbal 8.18.2021 |
| 2488683 | 32087.14 -> 36372 | $3,000.00 | JBGverbal 8.18.2021 |
| 2488688 | 32087.08 -> 36372 | $1,100.00 | JBGverbal 8.18.2021 |
| 2488691 | 32087.19 -> 36372 | $810.00 | JGBverbal 08.18.2021 |
Total moved by Goldberg's verbal authorization: $5,208.00
The annotation "JBGverbal" proves: (a) Goldberg personally directed trust fund movements for KFU, (b) the trust accounting system identified him by initials as the authorizing individual, (c) he controlled the allocation of money generated under Litman's name.
| Date | Direction | Amount | Description |
|---|---|---|---|
| Sept 24, 2021 | IN | $129,715.14 | Wire Payment 135900 King Faisal University 36372 |
| Sept 24, 2021 | OUT | $123,715.14 | Transfer to Operating |
| Oct 20, 2021 | OUT | $6,000.00 | Transfer to Operating |
$129,715.14 in, $129,715.14 out -- 100% of this KFU payment was swept to operating, generating $0 in documented allocation to Litman's 20% share.
The March 5-10, 2021 email thread (Finding #78) contains critical admissions from both Goldberg and Meyer about the financial arrangement and trust accounts:
"Jerry and Josh, There is a new business opportunity in NYC for clients as a result of an end of year law. Is the firm interested in developing a Copyright Alternative in Small-Claims Enforcement (CASE) Act practice?"
References "the amounts we owe to you" + "$49,085.17" quantified debt + "we can certainly set them aside in a trust account."
"Fair enough on your making money. We are in agreement, if you are going to be working to make money, we would rather we all do it together than you going off on your own."
"Our deal was for NGM to buy my practice. We agreed to a 5 year earnout after a indeterminate length of employment to transition my practice to NGM, subject to 90 day notice by either party, death or disqualification... the 80% due NGM" -- confirms 20% formula from Litman's own words.
References "multi-million dollar receivable" (KSU) + "5-year tail of the agreement" + trust account commitment.
These admissions prove: By March 2021, all three parties (Litman, Goldberg, Meyer) acknowledged (a) the 20% formula, (b) outstanding debt owed to Litman, (c) the trust account mechanism for handling it, and (d) the multi-million-dollar scope of the Litman-originated practice.
| Month | Count | Key Events |
|---|---|---|
| 2020-06 | 50 | SOL cutoff; no interruption; Litman actively directing KFU work |
| 2020-07 | 74 | Peak month; Goldberg calls with KFU Dean; trust reports generated |
| 2020-08 | 52 | Goldberg writing directly to KFU; disability insurance discussions |
| 2020-09 | 56 | First trust deposit ($68K); Goldberg direct KFU correspondence |
| 2020-10 | 43 | New KFU applications filed; patent applications completed |
| 2020-11 | 31 | Three Freedom Bank wires ($48K total) into trust |
| 2020-12 | 12 | Lower volume (holiday period) |
| 2021-01 | 36 | New KFU patent applications (Docket 32087.30) |
| 2021-02 | 46 | KFU applications revised; new dockets opened |
| 2021-03 | 33 | Case Act thread with trust/payment admissions |
| 2021-04 | 4 | Reduced email volume |
| 2021-05 | 1 | $26,600 Freedom Bank wire (trust deposit) |
| 2021-07 | 13 | |
| 2021-08 | 4 | JBGverbal trust fund transfers |
| 2021-09 | 43 | $129,715 KFU wire; Indonesian firm writes to "Litman Law Offices" |
| 2021-10 | 4 | |
| 2021-11 | 4 | |
| TOTAL | 506 | 18 months of continuous KFU work under Litman's name |
The 506 KFU-specific emails are a subset of the much larger volume flowing through Litman's name infrastructure. The total email volume across ALL Litman-domain addresses in 2020-2021 was in the tens of thousands (the full corpus contains 276,899 emails; kfu@4patent.com alone accounts for 19,701 emails across the full timeline per Finding #46).
These emails prove Goldberg was simultaneously (a) managing Litman's clients, (b) controlling trust funds, and (c) maintaining a personal relationship with Litman that concealed the extent of name use.
| Date | From | Subject | Key Content |
|---|---|---|---|
| June 7, 2020 | Litman | "Re: How is Jerry? You?" | "I have never put as much trust in other people as I have in you and Jerry." Disability disclosure. |
| June 8, 2020 | Goldberg | "Re: How is Jerry? You?" | Acknowledges disability; agrees to concealment |
| June 8, 2020 | Litman | "Re: How is Jerry? You?" | "Our agreement doesn't mention what happens in the event of my disability." |
| June 11, 2020 | Litman | "FYI -2010 visit to KFU" | Shares KFU visit photos, CC: kfu@4patent.com |
| June 11, 2020 | Goldberg | "RE: FYI -2010 visit to KFU" | Responds warmly, CC: kfu@4patent.com |
| June 15, 2020 | Goldberg | "Dark Web Search" | Reports dark web hits for rlitman@nathlaw.com -- proves Goldberg monitoring Litman's email addresses |
| June 16, 2020 | Goldberg | "Re: UAEU and KFU" | Managing KFU payments on SOL+1 day |
| June 17, 2020 | Goldberg | "FW: Request for assistance" | Forwards client COVID discount request: "He is not the first client to come to us requesting COVID discounts." |
| June 25, 2020 | Goldberg | "A Few Things" | Weekly check-in: "I hope you're doing well and the new biologics continue to do their job!" |
| July 14, 2020 | Goldberg | "UAEU & King Saud - Trust" | "I wanted to make sure we took all the money we were eligible to take." Trust fund control. |
| July 17, 2020 | Goldberg | "2nd Quarter" | Sends quarterly financial documents to Litman |
| July 27, 2020 | Goldberg | "Re: KFU" | "Just finished the call with KFU, the Dean asked if you would be joining us and sends his best." |
| Aug 12, 2020 | Goldberg | "Re: Feedback" | "Good to hear the disability insurance is progressing." |
| Aug 13, 2020 | Goldberg | "RE: Right document" | "We know you're losing it, that's why we're going through this process. Said with love and caring." |
| Aug 20, 2020 | Goldberg | "Re: Checking In" | Invites Litman to join Zoom discussions |
| Aug 28, 2020 | Goldberg/Litman | "Kuwait University" | Joint strategy on university rankings |
| Sept 14, 2020 | Goldberg | "KSU Payment" | "I think it is time to put a hold on filing new applications" -- managing Litman's client relationships |
| Sept 14, 2020 | Goldberg/Litman | "Qatar University" | Both on client call: "your interjection was good" |
By December 2021, Goldberg had:
Maintained all KFU work under Litman's name -- 506 documented KFU emails in 18 months, all flowing through kfu@4patent.com on Litman's domain, with CN-37833 listing "Richard C. Litman" as the USPTO correspondence address
Taken personal control of KFU trust funds -- $273,785.14 in documented KFU trust receipts through Account 36372, with Goldberg personally authorizing fund movements ("JBGverbal") and directing trust-to-operating sweeps
Actively concealed Litman's disability from clients -- per the June 2020 directive: "my strong preference is that we keep this between you and I," ensuring clients like KFU continued to believe Litman was actively involved
Used Litman's domain infrastructure for all client communications -- kfu@4patent.com, litman@4patent.com, and rlitman@nathlaw.com all remained operational, routing tens of thousands of emails through addresses bearing Litman's name
Acknowledged financial obligations while suppressing accounting -- March 2021 admissions of "the amounts we owe to you," $49,085.17 quantified debt, and trust account promises, while KFU generated $0 in NGM's workup
The name-use pattern was not incidental -- it was deliberate, continuous, and commercially motivated from Day 1 of the post-SOL period.
| Document | Location |
|---|---|
| EMAIL_METADATA_ND0001.csv | output/ |
| EMAIL_METADATA_ND0002.csv | output/ |
| KFU_TRUST_LEDGER_36372.csv | output/ |
| KFU_TRUST_MONTHLY.csv | output/ |
| KFU_36372_TRUST_MANIPULATION_MEMO.md | output/ |
| GOLDBERG_TRUST_CONTROL_MEMO.md | output/ |
| iCloud photos IMG_0736, IMG_0737 | evidence/nathlaw_phone_photos/ |
| iCloud photos IMG_1249, IMG_1250 | evidence/icloud_photos/ |