Date: 2026-04-15 Source: 8 documents from uncle's Google Drive download (evidence/google_drive_download_20260415/) Analyst: Automated extraction and analysis
File: NGM - Acknowledgement of deducting money from Revenue that firm paid contractors rather than use staff.pdf
Date: June 17, 2020 (2 days after SOL cutoff 6/15/2020)
Participants: Litman (rlitman@nathlaw.com) to Goldberg (JGoldberg@nathlaw.com)
LITMAN'S EMAIL (June 17, 2020 11:51 AM):
High-value client referral -- WAHAJ: Litman identifies Wahaj (Saudi Arabia) as "potentially high value client" and provides a Google search link. Proves Litman was actively originating new Middle East clients 2 days post-SOL cutoff, directly contradicting the "disability = death of practice" defense.
CONTRACTOR DEDUCTION ADMISSION (critical): Litman writes: "Accounting may still be deducting costs for independent contractors like searchers like Tony Bray and for Northern Virginia graphics. This accounting treatment was repeated in last quarter's allocations as well." This is Litman catching NGM deducting outsource expenses from "Revenue" before calculating his percentage -- a direct admission that the accounting department was reducing Litman's share by netting contractor costs against gross receipts.
Jerry Meyer said deduction was moot: "If you recall our conversation about this, Jerry said this accounting deduction was moot because Tony Bray was not working anymore." But Litman notes: "I understand Tony is still working." This catches Meyer in a false statement used to justify the deduction.
Litman's instruction: "Please ask the accounting department to not deduct these kind of management directed outsource expenses (e.g., searchers, and NV Graphics) at least for allocation purposes of our deal." Direct evidence that Litman objected to the deduction practice and was overruled/ignored.
Medical leave disclosure: "Since I changed up my biological last week with samples from the rheumatologist, I feel like the drug is working." Litman is on medical leave but actively working -- client origination, accounting oversight, Middle East market analysis.
Litman still directing firm operations: "I will talk with accounting about this" (re Tony Bray) and offering to bring in the Wahaj client. Not a passive retiree.
GOLDBERG'S RESPONSE (June 17, 2020 4:31 PM):
Goldberg signed off on Wahaj paperwork personally: "I did not realize they were this big of a potential client! Thanks for passing along the information. I signed off on all the paperwork they needed today." Goldberg acting as managing partner on a Litman-originated client.
Tony Bray -- Goldberg confirms he is still working: "As for Tony Bray, I actually did not see Martha's email. What I can say Jerry and my previous understanding from Al was that Tony was in very poor health and would not be working anymore. Clearly I was mistaken about that and he is not going away anytime soon." Written admission that the "Tony is not working" justification for the deduction was false.
Goldberg promises to fix accounting: "So this is something we do need to take care of. I will talk with accounting about this." Promise to correct the contractor deduction issue.
Goldberg on disability concealment: "Please do not come to the office, far better for you to stay safe and well." Keeping Litman away from the office while his name remains on everything.
This email exchange is a smoking gun on the "Revenue" definition dispute. It proves: - NGM was deducting management-directed contractor costs from Revenue BEFORE calculating Litman's percentage - Litman objected in writing - The justification given (Tony Bray not working) was admitted to be false - Goldberg promised to fix it but there is no evidence it was corrected - This directly connects to the arbitration objections where NGM repeatedly claimed the definition of "Revenue" was "at issue" (see Document 7 below)
Cross-reference: Finding #69 ("Retainer" mischaracterization) -- same pattern of manipulating accounting terminology to reduce Litman's share.
File: Emails re benefits and distributions.pdf
Date: December 19-20, 2017
Participants: Goldberg, Litman, Meyer (all three principals)
JERRY MEYER (December 19, 2017 4:24 PM):
40% of hourly billing offered: "We are happy to provide 40% of your hourly billing, if your time is recorded we will include it in the calculation."
Fixed fee apportionment method admitted: "As for fixed fee matters, the way we have typically handled it is that when the matter is billed to the client, the fixed fees are apportioned to the attorneys who worked on the matter by the partner or attorney responsible for the client based on the amount of work that the attorney put into the matter."
Benefits package confirmed: "The major ones are the firm pays for our health insurance, our 401(k), our gas, our key man life insurance policies, and our business-related travel expenses, and provides a parking spot behind the building. These should apply to you as well."
LITMAN (December 19, 2017 11:58 PM):
B&P baseline established: "On the work at B&P, I received 15% credit across the board. Using this as a guide I would get 35% of Revenues during the term of our agreement and 20% thereafter." This is the foundational statement of the 35%/20% formula -- written by Litman, 8 months after the Combination Agreement was signed.
"Production credit" = origination credit: "If 'the partner or attorney responsible for the client' means the attorney who originated it, it would be my call on how much production credit I personally received. Is that your intent?" Litman clarifying that he controls allocation for originated clients.
Distribution frequency demand: "I would like to make the distribution twice monthly. This will require daily posting of money and the allocation. This should be standard. There should be a report which can show Revenues and allocation for a defined period." Litman demanding real-time accounting transparency from the start.
COBRA status: "health insurance - individual or family? I have COBRA now." Confirms Litman was transitioning from B&P and needed health coverage.
GOLDBERG (December 20, 2017 3:35 PM):
Litman apportions his own clients: "The way we have typically done things, the partner or attorney responsible for the client origination is the one who apportions the work done on the bill. In this case, that would be you." Goldberg confirming Litman controls allocation for Litman-originated clients.
"We would rather we take care of this for you": Goldberg volunteering to handle the allocation on Litman's behalf -- the very arrangement he later exploited.
B&P 35% question: "As for what was done at B&P, are you saying that you got 35% of all revenues collected, regardless of who did the work?" Goldberg probing the B&P arrangement to understand Litman's expectations.
Health insurance as income to Goldberg: "For me, the health insurance costs for my family are initially paid for by the firm but are passed directly on to me as income." Reveals Goldberg's personal health insurance was treated as taxable income, not a firm benefit -- different treatment than what was offered to Litman.
401(k) matching inconsistent: "For the 401(k), we have made matching contributions some years, others not, depending on cash available."
Key man life insurance: "For our key man life insurance policies, we have used MetLife in the past. Our understanding was that you had a policy you had already obtained. If we are not paying for this policy already, and it is something you think is worth maintaining, we would pick up the costs for it directly."
Distribution timing -- Goldberg prefers quarterly: "As for the timing of distributions, we have always been in favor of doing this more often than quarterly, as we do not really want to be in the position of owing you a lot of money." Critical admission -- Goldberg acknowledges he does not want to accumulate a large debt to Litman. Contradicted by the post-2020 behavior where NGM accumulated hundreds of thousands in unpaid obligations.
Allocation contingent on remittance advice: "If we do not have the remittance advice, we obviously would not know how to allocate the funds." Goldberg setting up a future excuse for non-allocation -- if they claim they don't have remittance advice, they can delay or avoid allocation.
This is the foundational compensation negotiation thread -- 8 months after the Combination Agreement -- establishing: - The 35%/20% formula in Litman's own words - Litman's right to control allocation of his originated clients - Goldberg's promise to avoid accumulating debt to Litman (broken post-2020) - The full benefits package promised to Litman (all later cut) - Meyer's participation in the compensation structure (relevant to his personal liability) - The "remittance advice" excuse Goldberg would later use to justify non-allocation
Cross-reference: Finding #78 (March 2021 "Case Act" thread with similar admissions); Finding #66 (20% rule validated); Finding #88 (Exhibit L March 2021 Meyer admissions).
Files: NGM 2017 email re benefits.pdf and NGM - Benefits co-managing partners -- and I -- should have received..December 2017 emails with Jerry Meyer.pdf
These are the same December 19-20, 2017 thread as Document 2 above (identical content). The different filenames suggest uncle saved them separately to emphasize different aspects: - Document 3 emphasizes Goldberg's response on benefits/distributions - Document 4 emphasizes what benefits "co-managing partners -- and I -- should have received"
The key content is fully captured in the Document 2 analysis above.
File: MetLife - Dell email 060.01.21 no offset if asset sale.pdf
Date: June 1, 2020 (14 days before SOL cutoff)
Participants: Richard Litman (rclitman@gmail.com), Steven Dell (sdell@diattorney.com, disability insurance attorney), Merlin Bryan (CC)
Subject: 2074571 Litman, Richard (NWM)(SJD/mb)Primary-contingency
LITMAN (June 1, 2020 2:58 PM and 4:33 PM):
"I will show it as an asset purchase": Litman's P.S. note about how to characterize the NGM transaction for disability insurance purposes. The Combination Agreement was structured as an asset sale/purchase, not a salary continuation.
Disability date confirmed as March 15, 2020: "March 15 will be the date of disability. I want to put the carriers on notice." and "I returned from the February 2020 trip and was planning a March and April trip. I took a week to rest in Spain at the beginning of March, supported by 4 adult family members. Upon return on March 15th, it was clear to me that I could not travel to the Middle East as planned."
"I don't have to bill hours": "I don't have to bill hours. I transitioned the last growing client relationship as of the February trip. Client relationship travel to the Middle East is postponed. Other client development efforts are on hold. I have no current duties."
W-2 income is NOT wages: "The W-2 income I receive is not an hourly wage or guaranteed salary, but my percentage of collected revenues on work already done. I now get an advance of $25,000 per month against collected revenues, and at the end of each quarter, I am paid the additional amount due. The contract provides that I am entitled to my percentage (which is about $250,000 of the current accounts receivable). This payment is due me for past services. I am entitled to receive it whenever it is paid, even if it is paid years beyond the 5 year period."
This is a BOMBSHELL statement for the case. Litman, in his own words to his own disability attorney, confirms: - $25,000/month advance against collected revenues (matches Finding #78 and #104) - Quarterly true-up payments - ~$250,000 in accounts receivable owed to him - Payment is for PAST SERVICES, not current work - Entitlement survives beyond the 5-year agreement period
NML (private) vs. MetLife (ERISA) distinction: "NML is private. MetLife is ERISA." Two separate disability policies with different rules.
NML agent confirmed disability qualification: "I did email and speak with her about my disability and inability to perform the duties of my job. She is a NML company representative and was the company to me during the height of the pandemic."
STEVEN DELL (June 1, 2020 1:35 PM and later):
Disability date strategy: "If March 15 is possible, we should go for it unless there is downside."
Asset sale = no MetLife offset: "If getting paid for intangible assets and stock (capital appreciation) during the initial 24 months period will result in an offset, we should have a call. Otherwise, please let me know what I need to do. If it is reflected on your tax returns as asset purchase, we will likely not have a problem with MetLife offset."
This is the critical finding: If the NGM payments are characterized as an asset purchase (which they are under the Combination Agreement), MetLife cannot offset them against disability payments. This destroys any defense argument that Litman was collecting disability fraudulently -- his own disability attorney confirmed the payments were structured as asset sale proceeds, not employment income.
80% income loss risk: "3/15/20. The carrier may postpone satisfaction of the elimination period due to the fact that you did not suffer an 80% or greater loss of income."
Dell's assessment of NWL policy: "What you were told by NWL is unreliable. The language of the policy is ambiguous. If NWL interprets your entitlement for past work as salary continuation, it will be an offset." But: "The safest way to handle is not to take the income now or have it classified as return of capital or paid at a later date."
CRITICAL for multiple case theories:
A. Destroys the "disability fraud" / "Goldberg was protecting Litman" defense: If Goldberg argues he was concealing Litman's reduced role to protect Litman from disability fraud exposure, this document proves the opposite -- Litman's own disability attorney confirmed the payments were properly characterized as asset sale proceeds that would NOT trigger a MetLife offset.
B. Confirms $25K/month advance + quarterly true-up structure in Litman's own contemporaneous words, 15 days before the SOL cutoff.
C. "Past services" characterization means Litman's ongoing revenue share is NOT contingent on current work -- it is compensation for the practice he sold. This undercuts any defense that Litman's disability meant he was not entitled to payments.
D. Litman had NO current duties as of June 1, 2020 -- yet his name continued appearing on 905 patents, 245 trademark dockets, and the nathlaw.com website for 5+ years afterward.
E. $250,000 in accounts receivable acknowledged as of June 2020 -- independent baseline for damages calculation.
Cross-reference: Finding #104 (Fidelity payment timeline confirms $25K/month pattern); prior memory entry project_disability_insurance.md.
File: J. Goldberg Doc Demands.pdf
Date: February 13, 2026
Case: Litman v. Goldberg, Index No. 524343/2025, Kings County Supreme Court
From: Connell Foley LLP (Aaron H. Gould, Leo J. Hurley) for Goldberg
To: Richard C. Litman, Pro Se
9 Requests for Production:
These are extremely broad, boilerplate demands -- requesting essentially everything. The broadness is notable because: - Request 1 opens the door for Litman to produce all 905 patents, 245 trademark dockets, and 206 IFW documents - Request 3 ("all documents using your name") invites production of the entire deck-of-cards universe - Request 5 ("damages") opens the door to all financial records including the PAR time series, trust ledgers, and Fidelity payment data - Request 8 opens the door to all text messages, emails, and communications with family members about the case
Strategic note: These demands were served on 2/13/2026. The reference to "Second Amended Complaint" (Definition 9) confirms Litman has amended twice. The demands give Litman broad permission to dump the entire evidence corpus on Goldberg's lawyers.
File: 2023.2.7 Objections to Document Requests--FINAL.pdf
Date: February 7-10, 2023 (arbitration, pre-Award)
Case: McCammon Group Case No. 2022001552
From: Heba K. Carter (General Counsel, P.C.) for all Respondents
Respondents: Nath & Associates PLLC, A2Z IP LLC, Joshua B. Goldberg, Jerald L. Meyer
CRITICAL: The "Revenue" Definition Dispute
NGM objected to Requests 3, 4, 8, 9, 10, 11, 12, and 16 all on the same basis: "the definition of 'Revenue' remains at issue between the Parties. The definition of 'Revenue,' and whether the definition includes or excludes expenses and offsets is a question for the finder of fact."
This is the central accounting dispute: NGM was deducting expenses and offsets from gross receipts before calculating Litman's percentage. Compare with Document 1 above where Litman caught them deducting Tony Bray contractor costs and NV Graphics from "Revenue."
Request No. 1 -- Client List Blocked: "A list of all clients of NGM and originating attorney is not relevant to the claims raised by Claimant." NGM refused to produce its client list with origination attribution. This is the information that would show 98% of matters were Litman-originated (Finding #61, confirmed by the Soluno export obtained later).
Request No. 7 -- Accounting Reports Blocked: "All reports, including reports having information related to overall firm management and other firm clients, is not relevant." NGM refused to produce monthly, quarterly, and year-end accounting reports. These are the very Payment Allocation Reports (PARs) that we now have for Oct 2023-Jun 2025 and that prove the 20% formula was mechanically applied (Finding #66).
Request No. 14 -- Broad Discovery Blocked: Objected on privilege, overbreadth, relevance, lack of particularity, and "contains multiple requests." This was Litman's attempt to get comprehensive financial records.
Requests 17-19 -- Relevance Objections: NGM claimed these requests were "not relevant to any claims raised or alleged by the Claimant." Without seeing the underlying requests, these likely sought information about the name-use pattern or disability-related communications.
Request No. 20 -- Trust Account Records Blocked: "All records, whether related to amounts owed to the Claimant or not, is not relevant." NGM refused to produce trust account records. This is the information that would have revealed the Freedom Bank account, the $16.2M accounting gap, and the client renumbering scheme.
Requests 21-22 -- Client Ledgers and PCLaw Blocked: "A ledger of all other firm clients is not relevant" and "information related to each client in the PCLaw databases is not relevant." NGM refused to produce client-level financial data. This is what later came out in the Soluno export showing 6,518 of 6,643 matters with Litman as referral source.
Request No. 26 -- A2Z IP, LLC: "A2Z IP, LLC is not a proper party to this arbitration and has no obligations or duties to Claimant." NGM attempted to wall off A2Z (a Goldberg-controlled entity) from discovery.
Request No. 30 -- Disability Communications: "A2Z IP, LLC is not a proper party to this arbitration and had no communications related to the Claimant or his disability." Specific denial that A2Z had any involvement with Litman or his disability -- relevant to corporate structure.
Request No. 39 -- Interrogatory Refused: "Respondents object on the basis that it requests a response to an Interrogatory which remains outside the scope of discovery in this matter."
This document proves NGM's systematic obstruction of financial discovery during arbitration:
The "Revenue" definition dodge was used to block 8 separate requests. NGM claimed "Revenue" was ambiguous and therefore they could not respond -- but their own PARs show they calculated it with mechanical precision every month.
Client list, accounting reports, trust records, and PCLaw databases were all blocked on "relevance" -- the very documents that later proved the $16.2M gap, client renumbering, and 98% Litman origination.
The arbitrator ruled on 6/14/2023 based on incomplete discovery because NGM successfully blocked most financial transparency.
Heba Carter signed these objections -- the same counsel who later acknowledged the name-use dispute (Finding #36) and whose termination letter violated COBRA timing (Finding #111).
Cross-reference: These objections map directly to what NGM was hiding: Findings #19 ($16.2M gap), #27 (client renumbering), #51 ($9.89M KFU unallocated), #61 (98% origination), #64 (69 uncredited transfers), #99 (Freedom Bank).
File: 2023.1.27 Document Requests to Litman.pdf
Date: January 27 / February 3, 2023
Case: McCammon Group Case No. 2022001552
From: Heba K. Carter for all Respondents
To: Litman (via counsel Blankingship & Keith)
Financial Probing (Requests 10-20, 33-38, 42-47):
NGM demanded ALL of Litman's: - Bank statements from April 2017 to present (Req. 14) -- fishing for evidence Litman received income from other sources - All disability income documentation from 2020 to present (Req. 33) - All legal revenue from June 2020 to present (Req. 34) - All legal revenue EXCLUDING NGM payments (Req. 35) -- specifically looking for evidence Litman practiced law independently - All communications with Litman Clients from June 2020 to present (Req. 37) -- looking for evidence Litman solicited clients directly - All revenue from Litman Clients not received through NGM (Req. 38) -- same fishing expedition - All MetLife and IRS statements (Req. 47)
Disability Focus (Requests 33, 39-41, 46-47):
Heavy emphasis on disability: - All disability income received (Req. 33) - All communications with Steven Dell re disability insurance (Req. 39) - All communications with Respondents re disability insurance and payments (Req. 40) - All disability insurance communications with third parties (Req. 41) - All MetLife documentation (Req. 46-47)
This confirms NGM's arbitration strategy was to argue Litman was collecting disability while also collecting from NGM, trying to create a fraud inference. Document 5 (MetLife/Dell email) destroys this theory by proving the payments were properly characterized as asset sale proceeds.
Agreement/Amendment Focus (Requests 4-9):
Requested all versions, redlines, annotations, and negotiation communications for both the Combination Agreement and Amendment. Notably, NGM itself had these documents and was presumably looking for Litman's side correspondence that might reveal a different understanding of terms.
"Cease payments" Request (Request 12):
"All documentation and communications between Mr. Litman and Respondents related to Mr. Litman's request that any payments to Mr. Litman cease as of June 2020." This reveals that NGM's position in arbitration was that LITMAN requested payments stop -- not that NGM unilaterally cut them off. This is a critical framing issue. If Litman asked for payments to stop (to avoid disability offset), that undercuts his breach claim for the period. But if NGM stopped payments unilaterally, that is a breach.
Malice Request (Request 48):
"Documents or communications evidencing any malice from the Respondents toward Mr. Litman." Standard request but reveals NGM anticipated a malice/punitive damages claim.
Email Scope:
Instructions specify: "any request for communications should include emails or correspondence from Mr. Litman's personal email address (rclitman@gmail.com) and any other email address attributed to Mr. Litman or used by Mr. Litman." NGM was aware of Litman's personal Gmail and wanted correspondence from it.
The 49 requests reveal NGM's arbitration defense strategy: 1. Disability fraud narrative -- heavy focus on disability income, MetLife, Dell communications 2. Independent practice narrative -- looking for evidence Litman was earning legal revenue outside NGM 3. "Litman asked for payments to stop" narrative -- Request 12 reveals this was their position 4. Agreement ambiguity narrative -- seeking redlines and negotiation history to argue the terms were disputed
All four narratives were deployed in the arbitration that resulted in the 6/14/2023 Award. The same themes appear in Goldberg's Answer in the NY case (Affirmative Defenses).
FINDING -- CONTRACTOR COST DEDUCTION FROM REVENUE (June 17, 2020): NGM was deducting management-directed contractor costs (Tony Bray searchers, NV Graphics) from "Revenue" before calculating Litman's percentage share. Litman objected in writing. Goldberg acknowledged the deduction practice and promised to correct it. Meyer had previously falsely told Litman the deduction was "moot" because Tony Bray was no longer working -- Goldberg admitted in writing this was wrong. This is a specific, dated instance of the Revenue-definition manipulation that the arbitration objections (Document 7) tried to keep ambiguous. Combined with the "retainer" mischaracterization (Finding #69), this establishes a pattern of systematically reducing Litman's share through accounting classification tricks.
FINDING -- LITMAN'S OWN CHARACTERIZATION OF W-2 PAYMENTS (June 1, 2020): In contemporaneous writing to his disability attorney, Litman stated: "The W-2 income I receive is not an hourly wage or guaranteed salary, but my percentage of collected revenues on work already done. I now get an advance of $25,000 per month against collected revenues... This payment is due me for past services. I am entitled to receive it whenever it is paid, even if it is paid years beyond the 5 year period." This (a) confirms the $25K/month + quarterly true-up structure, (b) characterizes payments as for "past services" not current work, (c) establishes entitlement survives beyond the 5-year agreement period, and (d) proves asset-sale characterization avoids MetLife offset.
FINDING -- GOLDBERG'S DECEMBER 2017 ANTI-ACCUMULATION PROMISE: Goldberg wrote on December 20, 2017: "we have always been in favor of doing this more often than quarterly, as we do not really want to be in the position of owing you a lot of money." This promise to avoid debt accumulation was systematically breached from 2020 forward, ultimately resulting in the $2.4M+ gap. Goldberg's own stated preference was for more frequent distributions -- the later switch to quarterly and then irregular payments was a unilateral departure from this expressed intent.
FINDING -- NGM BLOCKED ALL FINANCIAL DISCOVERY IN ARBITRATION: The February 2023 objections document shows NGM successfully blocked production of: (a) client lists with origination attorney, (b) monthly/quarterly/annual accounting reports, (c) trust account records, (d) PCLaw database contents, (e) all documents where the definition of "Revenue" was implicated (8 separate requests). The arbitrator's June 2023 award was therefore based on incomplete financial evidence. Every category of document NGM blocked later proved to contain devastating evidence (the $16.2M gap, Freedom Bank, client renumbering, 98% origination, 69 uncredited transfers).
| Document | Connects to Finding(s) |
|---|---|
| Doc 1 (Contractor deductions) | #69 (retainer mischaracterization), #19 ($16.2M gap), #66 (20% rule) |
| Doc 2 (Benefits/distributions) | #78 (March 2021 thread), #88 (Exhibit L), #104 (Fidelity payments), #66 (20% rule) |
| Doc 5 (MetLife/Dell) | #104 (Fidelity $25K/month), prior memory project_disability_insurance.md |
| Doc 6 (Goldberg demands) | Current NY case discovery posture |
| Doc 7 (NGM objections) | #19, #27, #51, #61, #64, #99 (all financial concealment findings) |
| Doc 8 (Requests to Litman) | Arbitration strategy, disability defense theory |
Revenue definition is settled by NGM's own PARs: The arbitration objections claimed "Revenue" was ambiguous, but the 21-month PAR series (Finding #66) shows NGM calculated it with mechanical precision. The contractor-deduction email (Doc 1) provides a specific example of how they manipulated the definition.
MetLife offset defense is dead: Dell's advice that asset-sale characterization avoids offset, combined with the Combination Agreement's actual structure, eliminates any disability fraud narrative.
Anti-accumulation promise strengthens breach claim: Goldberg's December 2017 statement that he did not want to owe Litman "a lot of money" is a written admission that the later accumulation of $2.4M+ was contrary to his own stated intent.
Arbitration discovery obstruction supports judicial estoppel: NGM blocked financial discovery in arbitration, obtained a favorable ruling based on incomplete evidence, and now those same documents (obtained through other means) prove the concealment.
Litman was actively working post-disability: The June 2020 emails show Litman originating clients (Wahaj), directing accounting corrections, and managing firm operations -- all while on medical leave. This simultaneously (a) proves he was contributing value that justified his revenue share and (b) undercuts any "disability = no contribution" defense.