Prepared: March 27, 2026 Scope: All verified events from Combination Agreement through present Purpose: Court-ready exhibit and reference document for counsel. Every entry drawn from documents in the evidence record.
| No. | Date | Event | Source | Legal Significance |
|---|---|---|---|---|
| 1 | 03/29/2017 | Combination Agreement executed; Litman joins Nath, Goldberg & Meyer as Senior Counsel. | Combination Agreement | Establishes the contractual relationship and Litman's role. |
| 2 | 04/16/2017 | Commencement Date under the Agreement. | Combination Agreement | Operative start date for all contractual obligations. |
| 3 | 05/07/2017 | Amendment to Agreement executed. Extends post-termination period from 3 to 5 years. Transfers LLO stock, domains, phone numbers, and USPTO Customer Numbers 24396 and 37833 to NGM. | Amendment to Agreement | Customer Number 37833 later appears on every patent filing bearing Litman's name -- control of this number is how Goldberg controlled the name use. |
| 4 | 2017 | NGM pays $214,532 to acquire the "Litman Law Offices" service mark. | Financial records | Demonstrates commercial value NGM placed on Litman's name and professional identity. |
| No. | Date | Event | Source | Legal Significance |
|---|---|---|---|---|
| 5 | 06/15/2020 | Litman becomes physically disabled. Parties later agree to treat this date as the termination date of his Senior Counsel status. | Arbitration Award (06/14/2023) | SOL cutoff date. All use of Litman's name after this date is actionable. Goldberg himself argued for this date in arbitration. |
| 6 | 06/16/2020 | Patent 10,683,577 B1 issued -- first post-SOL patent listing Litman as attorney of record on Line 74. | USPTO Patent Grant; Goldberg's own identification | Goldberg identifies this as the "first publication" -- the first unauthorized use of Litman's name after termination. |
| No. | Date | Event | Source | Legal Significance |
|---|---|---|---|---|
| 7 | 08/14/2020 | litman@4patent.com added to USPTO notification recipient list. | USPTO records | Litman's name and email maintained in the patent prosecution system after termination. |
| 8 | 09/17/2020 | Goldberg email: "I agree it would be cleanest to treat it like death, thereby instituting the five-year period starting 6/15/2020." | Email (Goldberg) | Goldberg expressly acknowledges 6/15/2020 as the termination date while continuing to use Litman's name on patent filings. |
| 9 | 04/30/2021 | Litman email: "The assignment of the LITMAN LAW OFFICES, LTD. mark does not include the right to use my name separate and apart from the mark." | Email (Litman) | Express non-consent. Litman affirmatively denies Goldberg permission to use his personal name. Destroys consent defense (Affirmative Defense No. 10). |
| 10 | 05/06/2021 | Nunc Pro Tunc Assignment recorded at USPTO (Reel 007281, Frame 0821). Filed by Goldberg. Contains clause: "Assignor owns his name, signature, voice, image, photograph or likeness." | USPTO Assignment Center records | Goldberg's own recorded document acknowledges Litman owns his name. Directly contradicts Affirmative Defense No. 10 (consent). Goldberg denies this paragraph in his Answer (para. 38) -- but the recorded document speaks for itself. |
| 11 | 05/21/2021 | Tanya Harkins email (Goldberg CC'd): "this is not Litman. I would have never worked for him and he doesn't work here anymore." | Email (Harkins, CC Goldberg) | NGM staff confirms Litman no longer works at the firm -- yet his name continues to appear on patent filings. Goldberg is on notice. |
| 12 | 07/06/2021 | Goldberg signs professional liability insurance application listing Litman as "Of Counsel." Policy FJS0001424. | Insurance application | Goldberg affirmatively represents to an insurer that Litman holds a professional role at the firm -- a commercial use of Litman's name for business purposes, made 13 months after termination. |
| 13 | 08/19/2021 | Four "JBGverbal" trust fund transfers -- Goldberg directs KFU money. | Financial records | Goldberg exercises personal control over the major client whose patents bear Litman's name. |
| 14 | 09/01/2021 | Goldberg's email (jgoldberg@nathlaw.com) replaces Tanya Harkins on USPTO notification list. | USPTO records | Goldberg personally inserts himself into the notification chain for patents filed under Litman's name -- direct control over the process. |
| No. | Date | Event | Source | Legal Significance |
|---|---|---|---|---|
| 15 | 12/23/2022 | Litman files Amended Demand for Arbitration (McCammon Group, Case No. 2022001552). | Arbitration filings | Formal dispute initiated. All subsequent POA signings occur with Goldberg's full knowledge of the dispute. |
| 16 | 01/17/2023 | Goldberg email: "Since we are the attorneys of record... Either a withdrawal of our Power of Attorney... needs to be filed." | Email (Goldberg) | Goldberg acknowledges he is the attorney of record and that a POA withdrawal would be required to stop the name use -- yet he never files one. |
| 17 | 01/18/2023 | Goldberg files Motion for Partial Summary Judgment arguing the agreement terminated 6/15/2020. | Arbitration filing | Goldberg argues under oath that the relationship ended 6/15/2020 -- while simultaneously signing new POAs listing Litman as attorney of record. |
| 18 | 01/30/2023 | Goldberg text message: "if you are on disability, what would be considered legal vs. fraud? I don't want ANY of us having to face a fraud issue." | Text message (Goldberg) | Goldberg expresses awareness that the arrangement may constitute fraud -- consciousness of wrongdoing. |
| 19 | 02/02/2023 | Litman Declaration: "we never reached any agreement on the 'specifics'... we never drafted any document to memorialize any amendment." | Litman Declaration | Refutes any claim that Litman agreed to post-termination name use. |
| 20 | 02/09/2023 | Goldberg files Reply to Motion to Dismiss. | Arbitration filing | Continued litigation activity. |
| 21 | 02/21/2023 | Interim Arbitration Award issued. All counts survive; Goldberg's Partial Summary Judgment denied. | Interim Arbitration Award | Arbitrator finds sufficient basis for all claims to proceed. |
| 22 | 05/09-11/2023 | Three-day arbitration hearing. | Hearing transcript | Full evidentiary hearing on all claims. |
| 23 | 05/24/2023 | Goldberg's Post-Arbitration Brief (53 pages). Argues termination occurred on 6/15/2020. | Post-Arbitration Brief | Goldberg reaffirms under oath that the relationship ended 6/15/2020. |
| 24 | 06/14/2023 | FINAL ARBITRATION AWARD issued. Key findings: (a) "Litman's status as Senior Counsel with NGM ceased by agreement of the parties on June 15, 2020"; (b) NGM breached by wrongful disability offset ($290,000 award); (c) Goldberg and Meyer not personally liable on the contract. | Final Arbitration Award | Binding determination that Litman ceased to be Senior Counsel on 6/15/2020. Every patent listing him as attorney of record after this date is an unauthorized use. The Award does not address name misappropriation -- that claim was not before the arbitrator. |
Every entry below represents Goldberg personally signing a Power of Attorney that caused Litman's name to appear as attorney of record on a U.S. patent -- after a binding arbitration award confirmed the relationship ended on 6/15/2020.
| No. | Date | Event | Source | Legal Significance |
|---|---|---|---|---|
| 25 | 06/19/2023 | Goldberg email: "yes, it is fine to send the POA to the client after the application is filed." | Email (Goldberg) | 5 days after the Arbitration Award. Goldberg confirms the practice of filing POAs bearing Litman's name continues. |
| 26 | 06/29/2023 | Goldberg signs POA for App 18/215,352 (later Patent 11,881,807). | POA (OCR-verified, Reg. 44126) | 15 days post-Award. First confirmed post-arbitration POA. |
| 27 | 09/05/2023 | Goldberg signs POA for App 18/242,465 (later Patent 12,043,608). | POA (OCR-verified, Reg. 44126) | 83 days post-Award. |
| 28 | 10/13/2023 | Goldberg signs POA for App 18/379,906. | POA (OCR-verified, Reg. 44126) | 121 days post-Award. |
| 29 | 10/30/2023 | Goldberg signs POA for App 18/384,685 (later Patent 11,932,607). | POA (OCR-verified, Reg. 44126) | 138 days post-Award. |
| 30 | 11/16/2023 | Goldberg signs POA for App 18/511,800 (later Patent 12,116,333). | POA (OCR-verified, Reg. 44126) | 155 days post-Award. |
| 31 | 12/21/2023 | KEY EVENT: Goldberg signs BOTH the POA and the KFU assignment cover sheet for App 18/392,663 (later Patent 11,980,937) on the same day. | POA and Assignment Cover Sheet (OCR-verified) | 190 days post-Award. Goldberg personally executes two separate documents bearing Litman's name in a single transaction -- proving direct personal involvement in the full chain from POA to assignment. |
| 32 | 01/16/2024 | Goldberg signs POA for App 18/414,442. | POA (OCR-verified, Reg. 44126) | 216 days post-Award. |
| 33 | 01/26/2024 | Goldberg signs POA for App 18/411,323. | POA (OCR-verified, Reg. 44126) | 226 days post-Award. |
| 34 | 01/29/2024 | Goldberg signs POA for App 18/413,239. | POA (OCR-verified, Reg. 44126) | 229 days post-Award. |
| 35 | 02/14/2024 | Goldberg signs POA for App 18/428,327. | POA (OCR-verified, Reg. 44126) | 245 days post-Award. |
| 36 | 02/26/2024 | Goldberg signs POA for App 18/425,923. | POA (OCR-verified, Reg. 44126) | 257 days post-Award. |
| 37 | 03/21/2024 | Goldberg signs POA for App 18/612,504 (later Patent 12,194,434 -- the last patent listing Litman on Line 74). | POA (OCR-verified, Reg. 44126) | 280 days post-Award. This POA directly causes the last patent ever issued bearing Litman's name. |
| 38 | 04/25/2024 | Goldberg signs POA for App 18/646,631 (later Patent 12,227,748). | POA (OCR-verified, Reg. 44126) | 315 days post-Award. KSU patent. |
| 39 | 09/30/2024 | Goldberg email: "the previous attorney, apparently still the attorney of record according to the USPTO." | Email (Goldberg) | Goldberg acknowledges Litman remains attorney of record -- yet takes no action to correct it. |
| 40 | 12/23/2024 | Goldberg text message: "KFU is winding up with 631 patents this year." | Text message (Goldberg) | Goldberg manages the major client whose patents bear Litman's name, demonstrating ongoing control and commercial benefit. |
| 41 | 01/17/2025 | Goldberg signs LAST POA for App 19/028,392 (later Patent 12,303,254). | POA (OCR-verified, Reg. 44126) | 581 days post-Award. Final confirmed POA bearing Litman's name signed by Goldberg. 16 total post-arbitration POAs. |
| No. | Date | Event | Source | Legal Significance |
|---|---|---|---|---|
| 42 | 01/14/2025 | Patent 12,194,434 issued -- LAST patent listing "Richard C. Litman" on Line 74 (attorney of record). | USPTO Patent Grant; XML verification | End of the Litman name-use period. 905 total patents listed Litman as attorney of record after 6/15/2020. |
| 43 | 01/21/2025 | Patent 12,201,650 issued -- FIRST patent listing "Joshua B. Goldberg" on Line 74. | USPTO Patent Grant; XML verification | Goldberg replaces Litman's name with his own. The switchover proves: (a) Goldberg had the ability to control whose name appeared all along; (b) consciousness of wrongdoing -- the change coincides with the approach of litigation. |
| 44 | Post-01/21/2025 | 205 subsequent NGM patents all list Goldberg on Line 74. | USPTO Patent Grant XML; POST_20250114_NGM_PATENTS.csv | Confirms Goldberg could have used his own name at any time. The 905-patent count of Litman name uses is final. |
| No. | Date | Event | Source | Legal Significance |
|---|---|---|---|---|
| 45 | 05/2025 | Goldberg's last payment to Litman ($25,542.74). As of 12/31/2025, $246,628 remains owed. | Financial records | Goldberg derived revenue from the practice that used Litman's name, then stopped paying. |
| 46 | 06/13-16/2025 | Litman texts referencing "other issues such as use of my name." | Text messages (Litman) | Litman raises the name-use issue directly with Goldberg before filing suit. |
| 47 | 06/21/2025 | Last Wayback Machine capture of nathlaw.com showing Litman listed as "PATENT ATTORNEY" -- with no "Retired" designation. | Wayback Machine screenshot (evidence/website/) | Litman's name used on the firm's public website to solicit business, more than 5 years after termination and 2 years after the Arbitration Award. |
| 48 | 07/18/2025 | Litman's email access cut off (litman@4patent.com; NathLaw.com accounts). | Email records | Access terminated only after Litman raises the name-use issue -- consciousness of wrongdoing. |
| No. | Date | Event | Source | Legal Significance |
|---|---|---|---|---|
| 49 | 07/21/2025 | State court complaint filed. Litman v. Goldberg, Index No. 524343/2025, Supreme Court, Kings County. | NYSCEF | Commencement of this action. |
| 50 | 07/22/2025 | Federal complaint filed (EDNY, 1:25-cv-04048). | PACER | Parallel federal action. |
| 51 | 09/05/2025 | Litman removed entirely from nathlaw.com professionals page. | Wayback Machine comparison | Goldberg removes Litman's name from the website only after suit is filed -- further evidence of consciousness of wrongdoing and ability to control the name use. |
| 52 | 12/05/2025 | Judge Maslow dismisses Counts I-IV; Count V survives (NY Civil Rights Law Sections 50-51, misappropriation of name). | Court order / oral decision | The surviving claim is the name misappropriation count -- the precise claim supported by all of the above evidence. |
| 53 | 01/20/2026 | Goldberg files Answer (NYSCEF Doc #65) with 10 affirmative defenses. Key admissions: ADMITS Litman's name appeared on patent front pages and NGM website after 6/15/2020 (paras. 32, 72). DENIES he "caused" it (para. 33). DENIES Nunc Pro Tunc Assignment paragraph (para. 38). | Answer (Doc #65) | Goldberg's admissions establish two of the four elements of Section 51. His denials are contradicted by 16 POA signatures (para. 33) and his own USPTO-recorded document (para. 38). |
| 54 | 01/28/2026 | Litman serves First RFAs (15 requests) and discovery demands. | Discovery records | Discovery commences. |
| 55 | 02/17/2026 | Goldberg serves RFA responses -- multiple evasions and self-contradictions identified. | RFA Responses | Evasive responses create basis for deemed admissions motion. |
| 56 | 02/19/2026 | Preliminary conference. Case reassigned from Judge Maslow to Hon. Brian L. Gotlieb, J.S.C. | NYSCEF / Conference record | New judge assigned. |
| 57 | 02/24/2026 | Failed deposition -- Goldberg refuses to appear. | Deposition records | Refusal to submit to examination under oath. |
| 58 | 02/26/2026 | Goldberg serves Discovery Responses and BOP Response (characterized as "purely as a courtesy"). | Discovery Responses; BOP Response | Goldberg's belated and qualified responses. |
| Date | Event |
|---|---|
| ~03/25/2026 | Goldberg's BOP demand response due |
| 04/02/2026 | Bills of Particulars due |
| 06/02/2026 | Depositions complete |
| 09/22/2026 | Compliance conference (CCP Room 282, 9:30am, Judge Gotlieb) |
| 02/05/2027 | Note of Issue |
| Metric | Count |
|---|---|
| Patents listing Litman as attorney of record after 6/15/2020 | 905 |
| POAs personally signed by Goldberg (Reg. 44126) | 16 (all post-6/15/2020) |
| POAs signed after Arbitration Award (6/14/2023) | 14 |
| Days between Arbitration Award and last POA signing | 581 |
| Outgoing USPTO documents bearing Litman's name (each a separate Section 51 "use") | 206 |
| Express non-consent communications from Litman | 3 |
| Post-switchover NGM patents listing Goldberg (proving ability to control) | 205 |
| Goldberg admissions in Answer (Doc #65) | 12 cataloged from 6 sources |
| Abbreviation | Full Source |
|---|---|
| Combination Agreement | Combination Agreement dated 03/29/2017 |
| Amendment to Agreement | Amendment dated 05/07/2017 |
| Arbitration Award | Final Arbitration Award, McCammon Group Case No. 2022001552 (06/14/2023) |
| Interim Arbitration Award | Interim Arbitration Award (02/21/2023) |
| POA (OCR-verified, Reg. 44126) | Power of Attorney filed at USPTO, Goldberg signature confirmed via OCR |
| USPTO Patent Grant | Official patent grant document (Line 74 = attorney of record field) |
| USPTO Patent Grant XML | Machine-readable patent grant XML from USPTO bulk data |
| USPTO Assignment Center | USPTO recorded assignments (assignmentcenter.uspto.gov) |
| Answer (Doc #65) | Goldberg's Answer, NYSCEF Doc #65 (01/20/2026) |
| Email / Text message | Communications from the 276,899-email corpus or text message records |
| Wayback Machine screenshot | Internet Archive capture, saved to evidence/website/ |
| NYSCEF | New York State Courts Electronic Filing system |
| PACER | Public Access to Court Electronic Records (federal) |
| Financial records | Trust account and payment records |
| Insurance application | Professional liability insurance application, Policy FJS0001424 |
This timeline contains only verified facts drawn from documents in the evidence record. It does not include argument, characterization, or inference beyond what the documents themselves establish.