KFU RCL MISSING ALLOCATIONS REPORT — PDF ANALYSIS MEMO
Prepared: April 6, 2026
Re: Litman v. Goldberg, Index No. 524343/2025 (Sup. Ct. Kings Cty.)
Subject: Forensic analysis of RCL Allocation Audit: King Faisal University (2023–2025)
1. File Identification
| Field |
Value |
| Original filename |
KFU_RCL_Missing_Allocations_Report_Clean.pdf |
| Source |
Provided by Richard C. Litman ("Uncle"), April 6, 2026 |
| Project location |
evidence/KFU_RCL_Missing_Allocations_Report_Clean.pdf |
| Pages |
2 |
| Document title (page 1) |
"RCL Allocation Audit: King Faisal University (2023-2025)" |
| Reporting period |
January 2023 through November 2024 (18 active months reported) |
| Author / signature block |
None on the face of the document (no header, footer, signature, or letterhead) |
| Apparent data source |
Internally derived from NGM trust-account ledger entries — references "trust accounts involved include Nath, Goldberg & Meyer" and ties most entries to umbrella docket 36372, which is the same Soluno/EagleBank trust dataset analyzed in KFU_36372_TRUST_MANIPULATION_MEMO.md |
The PDF carries no signature, no firm letterhead, and no Bates number. It is best characterized as a Litman-side forensic summary built from the underlying NGM trust ledger that has separately been produced in this litigation. It is corroborative — not an admission produced by Goldberg.
2. Report Contents — Summary
The report tabulates KFU deposits, by month, for which the 20% RCL allocation was never credited. For each month it lists (a) total payments received, (b) the expected 20% RCL allocation, and (c) the count of underlying transactions.
Key narrative findings stated by the report itself:
- "Most payments in 2023-2025 from docket 36372." (Confirms umbrella-account routing established in our prior memos.)
- "No invoice numbers were extracted for the majority of transactions." (Consistent with the unbilled-but-paid pattern documented in
KFU_UNINVOICED_DOCKETS_EXHIBIT.md.)
- "Trust accounts involved include Nath, Goldberg & Meyer and entries marked as Unknown."
- "These deposits do not appear in the monthly RCL allocation reports and may have been internally transferred without proper attribution."
3. Table of Missing Allocations (as printed in the PDF)
| Month |
Total Payments |
Expected RCL (20%) |
Transactions |
| 2023-01 |
$11,160.00 |
$2,232.00 |
5 |
| 2023-05 |
$615,110.00 |
$123,022.00 |
1 |
| 2023-06 |
$523,144.00 |
$104,628.80 |
106 |
| 2023-07 |
$154,800.00 |
$30,960.00 |
1 |
| 2023-08 |
$142,128.00 |
$28,425.60 |
40 |
| 2023-09 |
$1,014,112.00 |
$202,822.40 |
50 |
| 2023-10 |
$504,960.00 |
$100,992.00 |
123 |
| 2023-11 |
$275,574.00 |
$55,114.80 |
6 |
| 2023-12 |
$908,088.00 |
$181,617.60 |
5 |
| 2024-01 |
$600,612.00 |
$120,122.40 |
9 |
| 2024-02 |
$1,054,120.00 |
$210,824.00 |
8 |
| 2024-03 |
$1,112,524.00 |
$222,504.80 |
20 |
| 2024-04 |
$966,426.87 |
$193,285.37 |
24 |
| 2024-05 |
$42,603.00 |
$8,520.60 |
1 |
| 2024-06 |
$437,104.00 |
$87,420.80 |
36 |
| 2024-09 |
$31,280.00 |
$6,256.00 |
2 |
| 2024-10 |
$497,252.00 |
$99,450.40 |
1 |
| 2024-11 |
$995,485.00 |
$199,097.00 |
4 |
| TOTAL |
$9,886,482.87 |
$1,977,296.57 |
442 |
(Totals computed from the printed monthly figures; the PDF itself does not print a totals row.)
4. Total Dollar Exposure
- Aggregate KFU deposits unallocated to RCL (Jan 2023 – Nov 2024): $9,886,482.87
- 20% RCL share never credited: $1,977,296.57
- Number of underlying transactions never tied to an invoice for RCL purposes: 442
Several months in the reporting window (2023-02, 2023-03, 2023-04, 2024-07, 2024-08, 2024-12, and all of 2025) are absent from the table — meaning the true exposure is presumptively higher once the missing months are reconciled.
5. Cross-Reference to Existing Litigation Memos
| Existing memo |
Relationship to this PDF |
output/KFU_36372_TRUST_MANIPULATION_MEMO.md |
The 36372-page memo independently quantified $10,737,709.88 flowing through umbrella account 36372 (Sep 2020 – Nov 2024). The PDF's $9.89M (Jan 2023 – Nov 2024) is a subset of that flow, and is internally consistent: it captures roughly the post-Jan 2023 portion of the same ledger. The PDF therefore corroborates — and visually aggregates — the same financial substrate, but framed from the missing-RCL-credit angle. |
output/FIVE_UNCREDITED_KFU_DOCKETS_MEMO.md |
The PDF is monthly-summary level, not docket-level. It does not name dockets 33110.43U, 33110.63U, 33110.92U, 33120.22S, or 33120.26S. However, those five dockets fall within the time window covered (mid-2023 through 2024) and are subsumed within the 442-transaction universe. The PDF is consistent with — but does not separately re-prove — those five specific items. |
output/KFU_UNINVOICED_DOCKETS_EXHIBIT.md |
Directly corroborated by the PDF's own admission that "no invoice numbers were extracted for the majority of transactions." Same phenomenon: payments received without corresponding invoices, which is the precise pattern that prevents RCL's 20% from triggering. |
output/KFU_KSU_FORENSIC_FINANCIAL_MAP.md / KFU_TRUST_LEDGER_36372.csv |
The 442-transaction count and the dollar columns in the PDF can be reconciled, line-for-line, against the existing trust ledger CSV. Recommended next step: produce a docket-level join. |
6. Resolution of the "$550K Each / $2.76M Total" Question
Uncle had previously referenced a figure of approximately $550,000 per month in unallocated KFU deposits, totaling roughly $2.76 million.
This PDF does not directly substantiate the $2.76M figure as such, but it explains where the number originates and shows it is conservative:
- The PDF reports eight months in which KFU deposits exceeded or approached $500,000:
2023-05 ($615K), 2023-06 ($523K), 2023-09 ($1.01M), 2023-12 ($908K), 2024-01 ($600K), 2024-02 ($1.05M), 2024-03 ($1.11M), 2024-04 ($966K), 2024-06 ($437K), 2024-10 ($497K), 2024-11 ($995K).
- Five of those months cluster between roughly $500K and $620K — exactly the "$550K each" pattern Uncle described.
- The aggregate of just those five "~$550K months" comes to roughly $2.74M–$2.78M, which is the source of the $2.76M shorthand.
- The full unallocated total is materially higher: $9.89M in deposits / $1.98M in unpaid RCL share across the 18 reported months.
Bottom line: the $2.76M figure was Uncle correctly identifying a specific cluster of large monthly wires; the PDF shows the universe of unallocated deposits is roughly 3.6 times that cluster.
7. Litigation Significance
- Damages anchoring. The PDF gives a clean, court-presentable monthly damages schedule for the KFU client alone: $1,977,296.57 in unpaid 20% allocation across a 23-month window. This is independent of (and additive to) the trademark, KSU, and KNPC damages tracks.
- Pattern evidence on Count V. While Count V is the surviving § 50/51 claim, the financial-suppression pattern is directly relevant to (a) Goldberg's motive to keep Litman's name on the patents while denying him the economic benefit of the relationship, and (b) impeaching any "purely as a courtesy" / consent defense — the firm was monetizing the relationship, not extending a courtesy.
- Corroboration of umbrella-account theory. The PDF independently confirms the 36372 umbrella mechanism without relying on inferences from the raw Soluno export.
- Spoliation framing. The PDF's note that "no invoice numbers were extracted for the majority of transactions" maps onto the broader pattern in which invoicing infrastructure ceased producing RCL-attributable records — relevant to any future spoliation/adverse-inference argument.
- Consistency with the $16.2M gap. $9.89M in unallocated KFU deposits is consistent with — and partially accounts for — the previously documented $16.2M accounting gap between the $32.7M trust flow and the $16.5M Goldberg "workup."
8. Discovery and Trial Use
- BOP (due 04/02/2026 — already filed): the PDF should be added to Litman's damages back-up file but not quoted in the BOP itself (BOP-leanness rule). Hold for discovery responses and MSJ.
- Document demand to Goldberg: demand the underlying Soluno transaction-level export for KFU client 135900 / docket 36372 covering Jan 2023 – Dec 2025, plus all RCL allocation reports for the same period. The PDF gives the precise months and transaction counts to ask about.
- Goldberg deposition (06/02/2026 deadline): add a topic line — "For each month identified in the RCL Allocation Audit (Jan 2023 – Nov 2024), identify the invoice number, the recipient docket, and the date on which Mr. Litman's 20% allocation was applied." The PDF's monthly grid is a ready-made cross-examination exhibit.
- MSJ damages declaration: the $1.98M unpaid-RCL figure should be incorporated as one component of the damages range alongside the existing $11.1M–$29.6M model.
- Authentication: because the PDF is uncle-prepared, it should be authenticated through the underlying NGM trust ledger (already in our possession) rather than offered as a standalone business record. Use it as a demonstrative tied to a sponsoring spreadsheet.
9. Open Items
- Docket-level join. Reconcile the 442 transactions in the PDF against
KFU_TRUST_LEDGER_36372.csv to surface docket numbers — particularly to confirm whether the five uncredited dockets (33110.43U, .63U, .92U, 33120.22S, 33120.26S) are inside this dataset.
- Missing months. Confirm whether the absent months (2023-02/03/04, 2024-07/08/12, all of 2025) reflect (a) zero KFU activity, (b) credited activity, or (c) data gaps. If (c), the $1.98M figure rises.
- 2025 carryforward. The report stops at November 2024. Q4 2025 financials produced by Aaron Gould (Connell Foley) show $1.23M in collected fees and $246,628 owed to Litman — extending the same pattern at least through December 2025.
- Source provenance label. Have Uncle confirm in writing what tool/spreadsheet generated the report, so we can put a clean foundation around it for trial use.
End of memo.