Date: 2026-04-15
Source: Uncle's Google Drive download (evidence/google_drive_download_20260415/)
A letter from Richard Litman to "Bob" (likely his arbitration counsel Robert E. Scully, Jr. of Blankingship & Keith), forwarding a chain of November 2022 KFU-related emails. The letter is undated but references events "as of this writing" in late November 2022 — placing it in the pre-arbitration period (arbitration award was 6/14/2023).
$3 Million Annual Budget: "This is the client which expressed the intent to increase their patent budget to $3 million per year."
Fee Math — $450,000/year in royalties from KFU alone:
Litman calls this "a bargain considering all of my efforts to develop the relationship"
"MY clients" — Litman's Personal Ownership Claim: Litman repeatedly refers to KFU as "my clients" — not NGM's clients:
"I invested my efforts because I expected this university in the middle of the desert to grow"
NGM Infrastructure Failing: "The law firm's accounting, billing, workflow and deadline management, and conflict checking, are not as I expected." Litman warns "the law firm will likely lose this client unless action is taken."
Prospective Revenue Loss Question: Litman asks whether non-speculative prospective revenue can be factored in as damages "because of the law firm's inability to handle the relationship."
Personal Investment Documented: "the increase in revenue requires interaction, relationship building, visits to the desert in 125 degree heat, and investment of time for programs to increase IP awareness"
Martha Long to Litman (Nov 21, 2022 12:05 PM): - "We are up to Disclosure #400 from them. We are onto their third docket number now!" - "two wires have been transferred to us today totaling almost $550,000" - Sent to rlitman@nathlaw.com — proves email was live and Litman was being CC'd on KFU matters
Prof. Abdul (KFU) messages — forwarded via Martha's WhatsApp-to-email system: - Prof. Abdul complaining about timeline not being met - "Happy Thanksgiving, Martha. Four days off! - what a luxurious professional life!" — sarcastic pressure on NGM staff - KFU opened "over 100 cases since September" (2022) — massive volume
Goldberg to Martha Long (Nov 22, 2022 11:21 AM): - CC: kfu@4patent.com — confirms the KFU alias on Litman's domain was actively used for client correspondence - Goldberg signs as "Co-Managing Partner" and "Green Patent Guy" from Brooklyn, NY - "I have my own set of messages from Prof. Abdul this morning" — Goldberg personally managing the KFU relationship
Martha Long's Service-Level Timeline (filed with Prof. Abdul): - Disclosure Review: 10-15 business days - Search: 10-15 business days - Application first draft: 4 weeks - Total time disclosure to patent grant: 6-10 months - This is the operational timeline for the world's #1 patent-granting university client
| Element | Significance |
|---|---|
| $450K/year royalty calculation | Litman's own contemporaneous damages estimate for KFU alone — anchors the $1.98M KFU unpaid figure (Finding #51) as conservative (4.4 years at $450K = $1.98M exactly) |
| "My clients" | Destroys any Goldberg defense that KFU was "firm business" rather than Litman-originated. Litman personally built the relationship through desert visits and IP awareness programs |
| $550K same-day wires | Confirms KFU was actively paying NGM large sums in late 2022, post-arbitration-demand |
| kfu@4patent.com CC | Proves the Litman-domain client alias was actively used for KFU correspondence — stacks with Finding #46 (19,701 KFU emails through 4patent.com) |
| Goldberg from Brooklyn | Personal jurisdiction evidence — managing KFU from NY |
| 400+ disclosures / 100+ new cases in 2 months | Scale of KFU relationship at the time — confirms Finding #60 (KFU = #1 patent-granting university globally) |
| NGM failing the client | Litman warning NGM would lose KFU — supports consequential damages for mismanagement of Litman-originated client relationships |
| Prospective revenue question | Shows Litman was already thinking about damages from NGM's inability to handle his clients — pre-arbitration awareness of the theory |
A formal legal brief filed with the McCammon Group arbitration tribunal in Case No. 2022001552 (Litman v. Nath & Associates, PLLC). Filed by Litman's counsel Robert E. Scully, Jr. and Dana R. Leinbach of Blankingship & Keith, P.C. (Fairfax, VA). Served on Merritt J. Green and Heba K. Carter at General Counsel, PC (McLean, VA) — counsel for NGM/Goldberg/Meyer.
The two versions (.docx and "RCL" .docx) are substantively identical — one trivial word difference ("and" present vs. absent in the first sentence).
The memo establishes this chain of events:
Litman's trust account (subaccount 140400, "Litman, Richard C. General Matter ref. 36056") held $110,000 of Litman's funds in NGM's client trust account.
December 22, 2021: Goldberg or Meyer transferred all $110,000 out of the Litman trust subaccount to pay down a line of credit — annotated in NGM's own records as "RC Litman Reserve paydown 'LOC'". This left a zero balance in Litman's trust account.
June 29, 2022 (6 months later): Litman's outside counsel Stan Klein demanded that NGM transfer Litman's trust funds to Klein's law firm trust account for safekeeping.
Merritt Green (NGM's own lawyer) responded to Klein's demand, believing "that you have some of these funds in NGM's trust account — which, in my opinion, should be sufficient if designated for Richard." Green didn't know the money was already gone.
Goldberg concealed from his own lawyer that NGM had already emptied Litman's trust account 6 months earlier. Green would never have defended the arbitration on the theory that "we held his share in trust" if she knew the truth.
NGM's Answer to the arbitration demand affirmatively stated they "held his share of the funds in trust and properly disbursed his share of the trust funds pursuant to the definition of Revenue." This was false — they had used the $110K to pay down a line of credit.
The memo argues that Goldberg's concealment from his own counsel triggers the crime-fraud-and-abuse exception to attorney-client privilege, meaning the inadvertently produced June 29, 2022 email (Exhibit A) should be admissible at the arbitration hearing despite NGM's privilege assertion.
Cases cited: - Seventh Dist. Comm. of the Virginia State Bar v. Gunther, 212 Va. 278, 287 (1971) — privilege ceases when client does not "frankly and freely reveal his object and intention" - Peterson v. Fairfax Hosp. Ass'n, 32 Va. Cir. 294 (Loudoun 1993) — privilege yields when counsel is deceived - Kandasamy v. Advanced Software Sys., Inc, 2019 WL 123894 (E.D. Va. 2019) — fabricating or concealing evidence is fraud on the tribunal - Peter v. Acevedo, 31 Va. Cir. 7 (Alexandria 1993) — counsel need not know of the fraud - First Union Nat. Bank v. Turney, 824 So. 2d 172 (Fla. Dist. Ct. App. 2001) — concealment from trust beneficiary waives privilege - Lach v. Man O'War, LLC, 256 S.W.3d 563 (Ky. 2008) — breach of fiduciary duty to limited partner invokes exception - Madanes v. Madanes, 199 F.R.D. 135 (S.D.N.Y. 2001) — privilege does not protect intentional torts undermining the adversary system
The memo presents NGM with a devastating either/or:
Either way, Goldberg is caught in fraud.
| Element | Significance |
|---|---|
| $110K conversion — Dec 22, 2021 | First documented instance of Goldberg diverting Litman's trust funds to pay down NGM's line of credit. Pre-dates all other documented conversions. Establishes the PATTERN that continues through the $9.89M KFU unallocated universe (Finding #51) and the $16.2M accounting gap (Finding #91) |
| "LOC paydown" annotation | NGM's own records explicitly label this as a line-of-credit paydown — not a legitimate trust disbursement. This is conversion on its face |
| Trust subaccount 140400 | New account number not previously documented — adds to the growing inventory of NGM accounts (Finding #99/103). Ref. 36056 = Litman's General Matter docket number |
| Goldberg concealed from own counsel | Proves consciousness of guilt BEFORE the arbitration hearing. Goldberg knew what he did was wrong — he hid it from Merritt Green. Stacks with Finding #92 (Goldberg's consciousness-of-guilt admissions) |
| False Answer to arbitration demand | NGM's sworn position that they "held his share of the funds in trust" was provably false as of Dec 22, 2021. This is a prior false statement under oath — impeachment material for Goldberg's deposition (06/02/2026) |
| Fraud on the tribunal | The arbitrator who issued the 6/14/2023 award may have been deceived. This supports a potential motion to vacate or at minimum provides context for the judicial estoppel argument (Finding #15) |
| Merritt Green's ignorance | Green (now at GCPC, same firm as Heba Carter who appears in the current case) was kept in the dark by her own client. Establishes Goldberg's pattern of concealing financial misconduct from his own lawyers — relevant to whether current counsel Aaron Gould (Connell Foley) is similarly being deceived |
| Crime-fraud exception precedent | The Virginia case law cited here may be directly applicable to the current NY proceedings if discovery disputes arise over privilege claims. The same pattern (concealment of trust fund conversion from own counsel) is still ongoing |
| Pre-arbitration trust conversion | This $110K conversion happened on Dec 22, 2021 — 18 months before the arbitration award. If the arbitrator was unaware, this supports the theory that Goldberg manipulated the arbitration process itself |
The two documents tell a devastating paired story:
KFU document (Nov 2022): Litman built KFU into a $3M/year client generating $450K/year in royalties for him. KFU was wiring $550K at a time. Litman personally invested years of desert travel and relationship building.
Crime-fraud memo (May 2023): Meanwhile, Goldberg had already emptied Litman's $110K trust account in December 2021 to pay down a line of credit — and then concealed this from his own lawyer when Litman's counsel demanded the funds.
The juxtaposition: Litman was generating millions in revenue for NGM through his personal client relationships (KFU alone = $3M/year), while Goldberg was simultaneously converting Litman's personal trust funds to pay down NGM's debts.
| Finding | Connection |
|---|---|
| #19 ($16.2M accounting gap) | The $110K conversion is one concrete, documented instance within the broader $16.2M pattern |
| #26 (accounting fraud pattern) | The Dec 2021 "LOC paydown" is the earliest documented instance of trust fund diversion |
| #46 (kfu@4patent.com alias) | The KFU document shows the alias actively used for client correspondence — 19,701 emails on Litman's domain |
| #51 ($9.89M KFU unallocated) | Litman's own $450K/year estimate validates the scale: 4.4 years at $450K = ~$1.98M, matching the $1.98M unpaid figure |
| #53 (Goldberg June 2025 KFU admission) | Goldberg's later admission that "many of [the Trust Ledgers] are blank" is consistent with the Dec 2021 zero-balance-after-conversion documented here |
| #60 (KFU = #1 patent university) | The 400+ disclosures and $550K same-day wires in Nov 2022 show the trajectory that led to KFU's #1 position |
| #64 (69 uncredited transfers) | The "LOC paydown" is the same pattern — trust-to-operating transfers without crediting Litman |
| #67 (NY RPC 1.15 violations) | Using trust funds to pay down a line of credit is a per se trust accounting violation under VA/DC RPC 1.15 and 37 CFR 11.115 |
| #92 (consciousness of guilt) | Concealment from own counsel is the earliest documented consciousness-of-guilt act — pre-dating the 1/30/2023 "fraud" text by 13 months |
| #93 (arbitrator alter ego finding) | The arbitrator may not have known about the $110K conversion when making his findings |
| #99 (Freedom Bank spoliation) | Same pattern: convert/divert trust funds, conceal from counsel and tribunals |
Goldberg or Meyer transferred all $110,000 from Litman's personal trust subaccount (140400, ref. 36056) to pay down NGM's line of credit on December 22, 2021. Six months later, when Litman's counsel demanded the funds, Goldberg concealed the conversion from NGM's own lawyer Merritt Green, who then falsely defended the arbitration on the theory that funds were "held in trust." Litman's arbitration counsel filed a formal Crime-Fraud and Abuse Exception Memo (May 5, 2023, Case No. 2022001552) arguing this concealment waives attorney-client privilege. This is the earliest documented trust fund conversion in the case and establishes the pattern that escalated into the $9.89M KFU unallocated universe and $16.2M accounting gap.
Litman's own pre-arbitration letter to counsel documents KFU's stated intent to spend $3M/year on patents, yielding $2.25M in attorneys fees and $450,000/year in royalties (20%) for Litman from this single client. As of November 2022, KFU had submitted 400+ invention disclosures, opened 100+ new cases in 2 months, and wired ~$550,000 in a single day. Litman attributes the relationship to his personal investment: "visits to the desert in 125 degree heat, and investment of time for programs to increase IP awareness." This contemporaneous estimate independently validates the $1.98M KFU unpaid share (Finding #51) as approximately 4.4 years of the $450K annual royalty stream.
Based on these documents:
"Mr. Goldberg, on December 22, 2021, $110,000 was transferred out of trust subaccount 140400 — 'Litman, Richard C. General Matter ref. 36056' — annotated as 'RC Litman Reserve paydown LOC.' Did you authorize that transfer?"
"What line of credit was being paid down with Mr. Litman's trust funds?"
"When Mr. Klein demanded that trust funds be transferred to his firm's trust account in June 2022, did you tell Ms. Green that the $110,000 had already been moved out of Mr. Litman's trust subaccount six months earlier?"
"How was it that NGM's Answer to the arbitration demand stated you 'held his share of the funds in trust' when the Client Trust Ledger shows a zero balance after December 22, 2021?"
"Regarding KFU — Prof. Abdul's $3 million annual patent budget — who built that client relationship? Who traveled to Saudi Arabia to develop it?"
"In November 2022, Martha Long reported that KFU wired $550,000 in a single day. How much of the resulting attorneys fees was credited to Mr. Litman's 20% royalty?"
"The kfu@4patent.com alias was CC'd on your November 22, 2022 email to Martha Long. Who controlled that email distribution list?"
Source files:
- evidence/google_drive_download_20260415/King Faisal University.docx
- evidence/google_drive_download_20260415/King Faisal University.pdf
- evidence/google_drive_download_20260415/2023.05.05 - Crime Fraud and Abuse Exception Memo.docx
- evidence/google_drive_download_20260415/2023.05.05 - Crime Fraud and Abuse Exception Memo RCL .docx