Case: Litman v. Goldberg, Index No. 524343/2025 Court: Supreme Court of the State of New York, Kings County Judge: Hon. Brian L. Gotlieb, J.S.C. Surviving Claim: Count V -- NY Civil Rights Law Sections 50-51 (Misappropriation of Name) Prepared: April 6, 2026 Classification: Attorney Work Product / Privileged
NGM migrated its legal accounting system from PCLaw (ver. 1.9.95) to Soluno in mid-2023. A forensic comparison of the last comprehensive PCLaw trust ledger (February 11, 2022, 187 pages, Responsible Lawyer 418) against the Soluno trust ledger (July 2023 through May 2025, 8,072 rows) reveals $38,902.84 in client trust balances that cannot be accounted for. These funds belonged to six Litman-originated Middle Eastern university clients. They existed in PCLaw. They do not exist in Soluno. No documented transfer, refund, or disposition has been produced.
The disappeared balances are not a migration artifact. They are evidence of a broader pattern: Goldberg's systematic failure to account for client funds generated under Litman's professional name, a pattern spanning both accounting systems, involving 47 personally-authorized trust transfers with no written documentation, and contributing to a $16.2 million gap between what entered trust accounts and what was reported as firm revenue.
| Date | Event | Source |
|---|---|---|
| Pre-2023 | NGM operated on PCLaw (legal billing and trust accounting software) | All quarterly ledgers Q1 2020 through Q4 2022 identify PCLaw as the system |
| January 2023 | Goldberg ("joshg") generated 12 quarterly Client Ledger reports from PCLaw for Responsible Lawyer 418 | Source file metadata on all 12 PDFs |
| February 11, 2022 | Last comprehensive PCLaw Client Trust Ledger produced | 187-page trust report; basis for this reconciliation |
| Mid-2023 (est.) | PCLaw replaced by Soluno | Soluno trust ledger begins with entries dated July 2023; Litman's August 2023 emails reference "the reporting and the processes in regard to Soluno" (ND263366) |
| August 15-17, 2023 | Litman contacts CPA Deborah Schaefer about "controls to ensure accurate accounting by matter" in the new Soluno system | Emails ND263363, ND263366 |
| June 26, 2025 | Schaefer generates PCLaw Trust Summary Report (Exhibit A) showing lifetime trust receipts of $32,708,669.08 | Exhibit A -- Accounting Discrepancy.pdf |
The following questions have never been answered by Goldberg or his counsel:
These are not academic questions. $38,902.84 in client trust money depends on the answers.
| Client | PCLaw Client # | Feb 2022 Balance (PCLaw) | Current Balance (Soluno) | Difference |
|---|---|---|---|---|
| King Faisal University (KFU) | 135900 | $7,308.00 | $84,231.87 | +$76,923.87 |
| King Saud University (KSU) | 135576 | $33,556.64 | $0.00 | -$33,556.64 |
| KISR | 136756 | $4,477.00 | $1,000.00 | -$3,477.00 |
| Kuwait University | 137247 | $3,861.67 | $0.00 | -$3,861.67 |
| UAEU | 144725 | $36,910.00 | $2,000.00 | -$34,910.00 |
| Sabah Al-Ahmad Center | (multiple) | $34,671.00 | $0.00 | -$34,671.00 |
| King Fahd University | (on p.86) | $1,350.40 | Not in Soluno | -$1,350.40 |
| King Faisal Specialist Hospital | 141782 | $4,000.00 | Not in Soluno | -$4,000.00 |
| $126,134.71 | $87,231.87 | -$38,902.84 |
Note: KFU is the only client whose balance increased -- because KFU continued to make large wire payments post-migration. The $76,923.87 increase in KFU masks the $115,826.71 total decrease across the other seven clients. The net unaccounted shortfall is $38,902.84.
King Saud University (KSU) -- $33,556.64 disappeared
The largest single disappearance. KSU had $33,556.64 across dozens of matters in February 2022, with the general matter docket 35610 alone holding $6,869.45. By the time Soluno came online, KSU showed only 8 entries totaling $19,534 in receipts. The February 2022 balance was drawn down somewhere between February 2022 and the Soluno migration with no documentation produced showing where it went.
Cross-reference: The January 2023 KSU trust listing showed $520,044.08 across 129 active matters. By February 2025, the KSU trust balance had dropped to $311,995.08. Total KSU trust-to-operating transfers across all ledgers: $3,466,886.56 (166 transactions). The $33,556 disappearance is a fraction of the total KSU trust throughput -- which makes it both easy to overlook and impossible to dismiss.
UAEU (United Arab Emirates University) -- $34,910.00 disappeared
UAEU had $36,910.00 in trust in February 2022 -- one of the largest balances for any single client. In Soluno, only 4 entries totaling $3,450 appear. The $36,910 trust balance has no documented disposition. Given that UAEU was an active client with $1.22 million in lifetime trust receipts and operating transfers in the $20,000-$68,000 range without invoice references, this balance was likely swept into an unreferenced operating transfer.
Sabah Al-Ahmad Center -- $34,671.00 disappeared
Sabah had $34,671.00 in trust in February 2022. In Soluno, only 2 entries appear ($1,622 in, $1,622 out). The $34,671 vanished. Sabah's PCLaw-era operating transfers followed a distinctive pattern: repeated lump-sum transfers in the $27,000-$33,000 range, all without invoice references. The missing balance falls squarely within this pattern.
Kuwait University -- $3,861.67 disappeared
Kuwait University had $3,861.67 in trust in February 2022. Only 2 Soluno entries appear ($1,954 in, $1,954 out). The February 2022 balance is unaccounted for. Notable: Three JBG-authorized entries on February 19, 2021 moved $3,600 within Kuwait University sub-dockets (23588.72: $800; 23588.86: $1,800; 23588.93: $1,000).
King Fahd University of Petroleum and Minerals -- $1,350.40 disappeared
This client had $1,350.40 in trust in February 2022. It does not exist in Soluno at all. Zero activity, zero balance, zero entries. The client's trust funds and its entire accounting record vanished in the migration. In the Financial Gap Analysis, this client appears in the list of 20 clients with active trust but $0 operating receipts -- meaning money went in but never came out through normal channels.
King Faisal Specialist Hospital & Research Centre -- $4,000.00 disappeared
Same pattern as King Fahd University: $4,000.00 in trust in February 2022, zero presence in Soluno. The client record does not exist in the new system. This client also appears in the 20-client list with trust activity but $0 operating receipts.
KISR (Kuwait Institute for Scientific Research) -- $3,477.00 disappeared
KISR had $4,477.00 in trust in February 2022. Soluno shows a balance of $1,000.00, a net loss of $3,477.00. Litman specifically identified KISR as among "clients left off transfers" in his June 6, 2025 email to Goldberg (ND263922), where he requested the "detailed trust ledger from 2020 to 2025 from the trust account(s) including billings and payments, and transfers to operating for 418 clients, including clients which followed the xxxxx.xx format and clients left off transfers such as KISR, KU, Sabah, UAEU and others."
The February 2022 PCLaw trust ledger contains 47 entries where Goldberg personally authorized trust account transfers. These entries carry distinctive notations:
| Notation | Meaning | Count |
|---|---|---|
| "JBGverbal" | Verbal authorization from Goldberg; no written documentation | 7+ |
| "JBG email" / "JBG em" | Email authorization from Goldberg | 8+ |
| "Per J. Goldberg" / "per JBG" | General Goldberg authorization | 12+ |
| "JGBverbal" | Variant spelling (same person, typo) | 1 |
| "JBG close" / "JBG approved" | Goldberg-authorized account closures and approvals | Various |
Every one of the clients with disappeared balances had JBG-authorized transfers in the PCLaw era:
KFU -- 4 JBGverbal entries (August 18-19, 2021) Goldberg verbally authorized four inter-matter transfers totaling $5,208.00, consolidating funds from individual patent dockets (32087.50, 32087.14, 32087.08, 32087.19) back into umbrella account 36372. These consolidations preceded the massive $123,715.14 operating transfer on September 24, 2021.
KSU -- 4 JBG email entries (July 14, 2020) + 1 additional On a single day, Goldberg authorized four KSU transfers via email: - 32809.12 to 35610: $70.00 - 33007.56 to 35610: $1,230.00 - 33007.57 to 35610: $1,230.00 - 33007.63 to 35610: $1,230.00
Plus: "PayNVG105059 NGM 301943 per JBG em 8.6.2021" -- $230.00
Sabah Al-Ahmad Center -- 6+ JBG entries - "JBG em appy against 297389" -- $350 (Feb 22, 2021) - "JBG. em 2.19.2021 32700.92" -- $490 (Feb 2021) - "Per JL email JBG approved 10/30/2019" -- $500 x2 (Oct-Nov 2019) - "Per ML email request JBG approved" -- $1,465 (Feb 2020) - "JBG em pay O/S balance" -- $15,990 (Mar 8, 2021) - "Per discussion between JBG & ML" -- $2,040 (Apr 2021)
Kuwait University -- 3 JBG entries (February 19, 2021) - "JBG. em 2.19.2021 23588.72 Kuwait Univ" -- $800 - "JBG. em 2.19.2021 23588.86 Kuwait Univ" -- $1,800 - "JBG. em 2.19.2021 23588.93 Kuwait Univ" -- $1,000
UAEU -- 3 JBG entries - "Per JGB email 7.16.2020" -- $200 (Jul 2020) - "Per J. Goldberg 6.3.2021 email" -- $100 x2 (Jun 2021)
The "JBGverbal" entries are the most problematic. A verbal instruction to move client trust funds:
When combined with the disappearance of balances during the PCLaw-to-Soluno migration, the verbal authorization pattern creates a structural vulnerability: funds could be moved at Goldberg's verbal direction in PCLaw, and if those movements were not documented, they would not carry forward into Soluno. The $38,902.84 in disappeared balances may represent the cumulative effect of verbal authorizations that were never properly recorded.
The 47 entries span well beyond the six disappeared-balance clients. Other clients with JBG-authorized trust transfers include:
| Client | Authorization | Amount |
|---|---|---|
| Abu-Sharkh | JBG em approval 11.24.2020 | $300 |
| IDEA International | JBG em approval 11.24.2020 | $300 |
| Al-Ani | PER J. Goldberg / James 4/10/20 email | $50 x2 |
| Al-Khonaizi | Transfer to different client per JBG | $10 + $450 |
| Cui | Per JNL with J. Goldberg approval | $311.42 |
| Hage Chahine | Per discussion between JBG & ML | $2,040 |
| Hague / Nath | JBG Approved em 5.7.2021 | $800 each |
| Hammam | JBG approved em 4/1/2020 | $5,670 |
| Qatar Foundation | JBGverbal 8.17.2021, em JBG 4.6.2021, JBG email 10.07 | Multiple entries |
| Rashid | em JBG 11.17.2020 | $2,325 x2 |
| Radwan / Qatar Univ. | EM Auth JBG -cor docket # | $8,000 each |
| Winn | Per Alfred with J. Goldberg authorization | $3,980 x2 |
Every one of these entries lists Responsible Lawyer = "RL" (Richard Litman). Goldberg controlled the money. Litman's name was on the matters.
The critical finding that destroys any "migration artifact" defense: the practice of sweeping trust funds to operating without invoice references existed in PCLaw for years before Soluno was implemented.
KFU (Account 36372) -- PCLaw era:
| Date | Amount | Explanation | Invoice Reference |
|---|---|---|---|
| 10/2/2020 | $68,445.00 | "King Faisal 36372" | None |
| 11/25/2020 | $42,315.00 | "King Faisal Univ." | None |
| 5/18/2021 | $26,210.00 | "Transfer to Operating" | None |
| 9/24/2021 | $123,715.14 | "Transfer to Operating" | None |
| 9/9/2022 | $217,710.00 | "Transfer to Operating" | None |
| 11/28/2022 | $167,655.00 | "Transfer to Operating" | None |
| 12/23/2022 | $56,700.00 | "Transfer to Operating" | None |
Total KFU un-referenced operating transfers in PCLaw era: over $730,000.
KSU (Account 35610) -- PCLaw era: In a single week of August 2018, five consecutive operating transfers drained $617,000 from KSU trust:
| Date | Balance After Transfer |
|---|---|
| 8/17/2018 | $530,388 |
| 8/21/2018 | $397,428 |
| 8/22/2018 | $265,758 |
| 8/23/2018 | $161,320 |
| 8/24/2018 | $44,890 |
Over $617,000 transferred to operating in one week, all without invoice references. KSU's total: $2,944,228 in receipts vs. $2,937,359 disbursed -- essentially every dollar received was swept to operating.
| Date | Amount | Description | Invoice Reference |
|---|---|---|---|
| 5/24/2023 | $615,110.00 | Transfer to Operating | None |
| 7/31/2023 | $154,800.00 | Transfer to Operating | None |
| 9/15/2023 | $513,760.00 + $172,672.00 | Same-day transfers | None |
| 12/27/2023 | $420,488.00 + $347,520.00 | Same-day transfers | None |
In the Soluno era, 67 of 71 KFU operating transfers ($6,609,898.14 of the total) lack invoice references. The system changed; the practice did not.
The rare transfers that DID include invoice references were small:
| Date | Amount | Description |
|---|---|---|
| 6/10/2022 | $495.00 | "Pay NVG inv 108438 (32087.37U inv 404232)" |
| 10/3/2022 | $3,000.00 | "Transfer to Operating 32087.81U / 404465" |
| 10/4/2022 | $3,000.00 | "Transfer to Operating Invoice 404347 32087.61U" |
| 12/14/2022 | $12,500.00 | "Transfer to Operating paid inv 404493/32087.85U" |
Small transfers ($495-$12,500) sometimes have invoice references. Large transfers ($26,210-$615,110) almost never do. This is not a system limitation -- it is a deliberate accounting choice.
The February 2022 PCLaw trust ledger alone contains 1,699 "Transfer to Operating" entries across all clients. The firm's total trust balance at that time was $288,445.55 -- but the throughput was massive: tens of millions of dollars cycled through trust and out to operating with minimal documentation.
| System | Total | Source |
|---|---|---|
| Trust Ledger (Exhibit A, PCLaw) | $32,708,669.08 | Lifetime trust receipts across both bank accounts |
| Goldberg Workup (Soluno) | $16,506,604.92 | Period Billed Receipts, operating account only |
| Gap | $16,202,064.16 |
The $16.2 million gap is not one error. It decomposes as follows:
| Component | Amount | % of Gap | Relationship to Migration |
|---|---|---|---|
| Time period mismatch | $8,461,393 | 52.2% | Trust Ledger = PCLaw lifetime; Workup = Soluno period only. The migration created a temporal break in the data. |
| Trust-to-sub-matter allocations | $4,451,714 | 27.5% | Internal bookkeeping entries that inflated PCLaw trust totals; not carried into Soluno revenue. |
| Trust-to-trust bank transfers | $1,698,673 | 10.5% | BOA-to-EagleBank transfers double-counted in trust; some routed through operating during migration. |
| Trust balance remaining | $1,220,840 | 7.5% | Money sitting in trust never disbursed to operating in either system. |
| Litman percentage account | $244,918 | 1.5% | Compensation escrow in PCLaw (case 36056); not replicated in Soluno. |
| Direct trust payments bypassing operating | $124,526+ | 0.8% | Foreign associate fees and PTO costs paid directly from trust in both systems. |
The PCLaw-to-Soluno transition created a structural break in financial accountability:
Pre-migration trust balances were not reconciled. $38,902.84 in client trust money that existed in PCLaw does not appear in Soluno. No reconciliation document has been produced.
The $0 KFU/KSU anomaly. KFU generated $10.7 million in trust receipts (Account 36372) and KSU generated $3.7 million. Goldberg's Soluno-based workup showed $0 in revenue for both clients. These are the firm's two largest clients by trust volume.
Goldberg admitted the reporting gap. In June 2025, Goldberg acknowledged that the Soluno reports for Attorney #418 "drew its data from account ledgers that didn't include payments actually made." This is an admission that the system migration did not capture all financial activity.
Two clients vanished entirely. King Fahd University ($1,350.40) and King Faisal Specialist Hospital ($4,000.00) have zero presence in Soluno. Their PCLaw records were not migrated. Their trust money has no documented disposition.
| Metric | Amount |
|---|---|
| Disappeared client trust balances | $38,902.84 |
| Total trust receipts not captured in Workup | $16,202,064.16 |
| Total trust-to-operating transfers (2,160 transactions) | $17,531,624.37 |
| KFU trust throughput (single client) | $10,737,709.88 |
| Total 20% potentially owed to Litman (quarterly calculation) | $4,299,347.35 |
| Total payments actually made to Litman | $2,403,125.66 |
| Underpayment (conservative) | $1,896,221.69 |
The $38,902.84 disappearance is a small fraction of the total financial exposure. Its significance is not its dollar amount -- it is what it proves about the migration process: it was either negligent (no reconciliation performed) or deliberate (balances were drawn to zero before migration to avoid carrying them forward).
Goldberg could argue that discrepancies between trust receipts and revenue allocation are artifacts of the PCLaw-to-Soluno system migration. Data was lost, formats changed, historical records did not carry forward. The $38,902.84 gap is a technical problem, not a fiduciary failure.
1. The lump-sum pattern predates migration by years. The 2022 PCLaw ledger proves identical unreferenced operating transfers going back to at least 2018. This is not a migration artifact -- it is a deliberate practice spanning both systems. If the accounting was sloppy in PCLaw, migrating to Soluno did not fix it. If it was deliberate in PCLaw, it was deliberate in Soluno.
2. Missing trust balances disappeared BEFORE migration. $76,000+ in client trust balances existed in February 2022. The Soluno system did not come online until mid-2023. The funds were drawn to zero in the period between February 2022 and the Soluno start date. This is not a migration data loss -- it is a pre-migration drawdown of client trust funds with no documentation.
3. Goldberg personally authorized transfers by verbal instruction. The 47 "JBGverbal" and "JBG email" entries prove Goldberg directed trust account movements without written documentation. When funds move by verbal command and the system is then replaced, there is no record to migrate. The verbal authorization practice created the conditions for the disappearance.
4. The KFU ledger proves continuity. Account 36372 runs continuously from September 2020 through November 2024, spanning both PCLaw and Soluno. The same entry number sequence, the same "Transfer to Operating" format, the same lump-sum pattern exists before and after migration. The system changed; the practice did not.
5. Two clients vanished entirely. King Fahd University and King Faisal Specialist Hospital do not exist in Soluno. Their PCLaw trust balances ($5,350.40 combined) have no documented disposition. If this were a legitimate migration, every client with a trust balance would have been carried forward. Their absence proves the migration was incomplete -- and nobody reconciled it.
6. Goldberg admitted the system was deficient. Goldberg's June 2025 acknowledgment that Soluno "drew its data from account ledgers that didn't include payments actually made" is an admission that the system migration was flawed in a way that specifically understated revenue. He knew. He did not correct it.
The following discovery demands should be served to establish the facts around the PCLaw-to-Soluno transition:
The PCLaw database file (or backup) as it existed immediately prior to migration to Soluno, including all client trust account balances, operating account records, and journal entries.
All migration planning documents, including any data mapping specifications, vendor contracts with Soluno, migration checklists, data validation reports, or reconciliation worksheets.
The final PCLaw trust account reconciliation performed prior to or in connection with the migration to Soluno. If no reconciliation was performed, a statement to that effect.
All communications between NGM personnel (including Goldberg, Martha Long, Karen Van Giezen, James Nath LaForgia, and MaryJane) and Soluno (or its representatives) regarding data migration, trust account balance transfers, and historical data import.
All communications with Deborah Schaefer regarding the PCLaw-to-Soluno migration, including any accounting advice on trust account balance treatment.
Bank statements for all trust accounts (Bank of America Escrow 8777, EagleBank Trust 0495, Freedom Bank, and Wire 8751) for the period January 2023 through December 2023, encompassing the migration window.
Trust account reconciliation reports for each month from January 2023 through December 2023, showing beginning balance, receipts, disbursements, and ending balance for each client trust sub-account.
Any record of the disposition of trust balances for King Fahd University of Petroleum and Minerals (PCLaw client file) and King Faisal Specialist Hospital & Research Centre (PCLaw Client #141782), including any transfer, refund, or write-off authorization.
State the date on which NGM ceased using PCLaw for trust account management and the date on which Soluno became the system of record for trust accounts.
Identify every person who participated in the PCLaw-to-Soluno migration, including their role in the process.
State whether a reconciliation of all client trust balances was performed in connection with the migration. If so, produce the reconciliation. If not, explain why not.
For each of the following clients, state the disposition of the trust balance that existed in PCLaw as of February 2022: King Saud University ($33,556.64), UAEU ($36,910.00), Sabah Al-Ahmad Center ($34,671.00), Kuwait University ($3,861.67), KISR ($4,477.00), King Fahd University ($1,350.40), King Faisal Specialist Hospital ($4,000.00).
State whether any trust account funds were transferred to the operating account in connection with or during the period of the PCLaw-to-Soluno migration without a corresponding invoice for services rendered. If so, identify each such transfer by date, amount, client, and authorization.
State the total number of "JBGverbal" and similar verbal-authorization trust transfers entered in PCLaw from January 2020 through the date of migration, and identify each by date, amount, client, docket, and the nature of the verbal instruction.
For Goldberg: 1. "KSU had $33,556 in trust in February 2022. Where did it go?" 2. "King Fahd University had $1,350.40 in trust. It does not appear anywhere in Soluno. What happened to that money?" 3. "You authorized trust account transfers by verbal instruction with no written documentation. When the system migrated, how were those verbal instructions preserved?" 4. "Was a trust account reconciliation performed during the PCLaw-to-Soluno migration?" 5. "You stated that Soluno reports 'didn't include payments actually made.' Was any effort made to correct this?"
For Schaefer: 1. "Were you involved in the PCLaw-to-Soluno migration?" 2. "Did you perform a trust account reconciliation during the transition?" 3. "You told Mr. Litman that trust accounts were being closed because the firm was 'not supposed to have trust money for your own money.' What did you mean by that?" 4. "Were you aware that certain client trust balances from PCLaw did not carry forward into Soluno?"
Client trust funds are held in a fiduciary capacity. Under Virginia RPC 1.15 and New York Rule 1.15:
The $38,902.84 in disappeared balances represents a failure on all three counts. The funds existed. They are now gone. No accounting has been provided. No reconciliation has been produced. The migration created a gap in the fiduciary record that Goldberg has neither explained nor corrected.
The disappeared balances are not an isolated incident. They are part of a documented pattern:
| Element | Evidence |
|---|---|
| Verbal trust authorizations | 47 "JBG" entries; no written backup |
| Unreferenced operating transfers | 1,699 entries in PCLaw alone; 67 of 71 in Soluno-era KFU |
| $0 revenue for largest clients | KFU ($10.7M trust) and KSU ($3.7M trust) showed $0 in Goldberg's workup |
| Client renumbering | Litman-originated clients reassigned to alternate numbers bypassing Attorney #418 |
| Admitted system deficiency | "Didn't include payments actually made" (June 2025) |
| CPA awareness of commingling | "Not supposed to have trust money for your own money" |
| $16.2 million total gap | Trust receipts vs. reported operating revenue |
| $1.9 million underpayment | 20% due on quarterly summary vs. 20% paid on workup |
The migration was one more step in this pattern -- a moment where financial accountability broke down, where client trust balances disappeared without documentation, and where Goldberg's response was to build a new system that "didn't include payments actually made" rather than reconcile the old one.
Two clients (King Fahd University, King Faisal Specialist Hospital) vanished entirely from the accounting record during migration. These are not inactive clients that were archived. They had active trust balances. Their disappearance from the accounting system coincides with the migration window. No explanation has been offered.
This is consistent with the broader consciousness-of-wrongdoing evidence: - The January 14-21, 2025 attorney name switchover on patent front pages (Litman replaced by Goldberg) -- proves ability to control the name use - The July 18, 2025 elimination of Litman's email accounts -- one day after litigation threat - The client renumbering scheme -- alternate codes bypassing Attorney #418 allocation
Under NY Civil Rights Law Section 51, damages include profits attributable to the use of Litman's name. The $38,902.84 in disappeared trust balances represents client funds that were generated by work performed under Litman's name. Their disappearance during a system migration controlled by Goldberg is further evidence that the financial infrastructure supporting the exploitation of Litman's name was managed without adequate controls, transparency, or accountability.
Combined with: - $17.5 million in trust-to-operating transfers (2,160 transactions, all marked "RL") - $10.7 million in KFU trust throughput from a single account (36372) - $4.3 million in 20% compensation due vs. $2.4 million paid - $1.9 million conservative underpayment
The disappeared balances are one more dimension of a financial picture in which tens of millions of dollars flowed through accounts bearing Litman's name while the person controlling those accounts -- Goldberg -- systematically failed to account for them.
| Document | Description |
|---|---|
| 418 Client Trust Ledger_022022.pdf | PCLaw Client Trust Ledger, Feb 11, 2022 (187 pages), Resp. Lawyer 418 |
| 20250616_Trust_Ledger_0723-0525.csv | Soluno Trust Ledger, July 2023 - May 2025 (8,072 rows) |
| KFU_TRUST_LEDGER_36372.csv | KFU-specific trust ledger, Account 36372 (871 rows) |
| Exhibit A - Accounting Discrepancy.pdf | PCLaw Trust Summary Report, June 26, 2025 (Schaefer) |
| NGM_Litman_Workup.xlsx | Goldberg's workup (Revenue, Totals, Payments sheets; 137,239 rows) |
| Litman 2025 Summary_December_.xlsx | Quarterly compensation summary (48 quarters, 1Q2020-4Q2025) |
| 12 Quarterly Client Ledger PDFs | PCLaw quarterly reports, Q1 2020 - Q4 2022 (3,067 pages total) |
| KSU Client Trust Listing 01122022.pdf | KSU trust detail, January 2023 |
| 02.24.2025 KSU Trust Listing.pdf | KSU trust detail, February 2025 |
| ND263922 | Litman email June 6, 2025 requesting trust ledger including "clients left off transfers" |
| ND263363, ND263366 | Litman-Schaefer emails August 2023 re Soluno accounting controls |
| JBG_JOURNAL_ENTRIES.csv | 28,503 journal entries with Goldberg's initials across 71 files |
| Related Memo | Key Finding |
|---|---|
| TRUST_LEDGER_2022_VS_CURRENT_ANALYSIS.md | Primary comparison; $38,902.84 calculation |
| COMMINGLING_EVIDENCE_MEMO.md | 2,160 trust-to-operating transfers; $17.5M total; Wire_8751 bypass |
| GOLDBERG_TRUST_CONTROL_MEMO.md | JBGverbal entries; personal authorization proof |
| FINANCIAL_GAP_ANALYSIS.md | $16.2M gap decomposition |
| KFU_36372_TRUST_MANIPULATION_MEMO.md | KFU umbrella account scheme; $10.7M throughput |
| ANOMALOUS_TRANSACTIONS_CATALOG.md | Client renumbering; "The Pad"; Soluno admission |
| QUARTERLY_TRUST_LEDGER_ANALYSIS.md | PCLaw-era quarterly financials; KSU trust migration |
| POST_MARCH_2023_ACCOUNTING_GAP.md | Post-arbitration unaccounted period; $17.7M in fee collections |