Source files:
- evidence/uncle_batch_2026-04-16/Trust_Transfers_to_Nath_June2023_to_June2025.xlsx (7,980 bytes)
- evidence/uncle_batch_2026-04-16/Updated_June_2023_RCL_Allocation_Tracker.xlsx (6,344 bytes)
Created: 2025-06-12 22:20:38 (allocation tracker) and 2025-06-16 13:38:09 (transfer log) by Plaintiff Richard C. Litman (both files have creator: None / no lastModifiedBy — native Python/openpyxl-generated workbooks, not Excel-authored, consistent with uncle's Python-based forensic pipeline).
Significance: Two narrow, plaintiff-prepared forensic slices. Together they document: (a) the state of KFU/KU/MSI-STEM payments exactly at the arbitration Award date (June 2023 snapshot), and (b) a targeted docket-specific trace of how individual client trust balances moved between NGM's two disclosed trust accounts (BoA Escrow t3 and Eagle Bank Trust t23) over the 24-month post-arbitration window. Neither file is a complete universe — both are surgical extractions.
t3 = BoA Escrow 8777: $61,432t23 = Eagle Bank Trust 0495: $18,622Freedom Bank: $0 (not present in this file)| Row | Docket | Date | Acct | Out | In | Explanation | Status |
|---|---|---|---|---|---|---|---|
| 2 | 16725.03 | 2024-11-18 | t3 | 50 | 0 | Trust-to-Trust BoA→Eagle Multi-Client | CLR |
| 3 | 16725.03 | 2024-11-18 | t23 | 0 | 50 | Trust-to-Trust BoA→Eagle Multi-Client | CLR |
| 4 | 32609.04S | 2023-08-01 | t3 | 10,380 | 0 | Transfer to 32609.04U | OUT |
| 5 | 32609.04U | 2023-08-01 | t3 | 0 | 10,380 | From 32609.04S | OUT |
| 6 | 32609.04U | 2023-10-26 | t3 | 10,380 | 0 | Pay invoice 319803 | CLR |
| 7 | 32609.04U | 2024-01-25 | t3 | 800 | 0 | Pay invoice 321303 | CLR |
| 8 | 32609.04U | 2024-05-08 | t3 | 5,164 | 0 | To 32609.04X ("case is not open in Soluno") | OUT |
| 9 | 32609.04U | 2024-12-30 | t23 | 0 | 2,589 | From 32609.04X per JG email | OUT |
| 10 | 32609.04U | 2024-12-30 | t23 | 2,589 | 0 | Pay invoice 332675 | CLR |
| 11 | 32609.04X | 2024-05-08 | t3 | 0 | 5,164 | From 32609.04U | OUT |
| 12 | 32609.04X | 2024-11-18 | t3 | 5,164 | 0 | BoA→Eagle Multi-Client | CLR |
| 13 | 32609.04X | 2024-11-18 | t23 | 0 | 5,164 | BoA→Eagle Multi-Client | CLR |
| 14 | 32609.04X | 2024-12-30 | t23 | 2,589 | 0 | To 32609.04U per JG email | OUT |
| 15 | 32609.04X | 2025-03-06 | t23 | 2,575 | 0 | Pay invoice 335416 | CLR |
| 16 | 200871.00S | 2024-07-24 | t3 | 750 | 0 | Pay invoice 420594 | CLR |
| 17 | 200871.00U | 2024-09-11 | t3 | 13,200 | 0 | Pay invoice 420600 | CLR |
| 18 | 200871.00U | 2025-04-18 | t23 | 2,000 | 0 | Pay invoice 422383 | CLR |
| 19 | 200871.00U | 2025-05-07 | t23 | 1,066 | 0 | Pay invoice 422476 | OUT |
Note on the 32609.04X "case is not open in Soluno" entry (Row 8): This is an independent documentation of the Finding #62/#63 admission — NGM transferred $5,164 from docket 04U to docket 04X on 5/8/2024, but docket 04X was not actually open in Soluno at the time. This matches the "invoice numbers are not matching matter numbers" admission (Goldberg July 16, 2025) and the 2,457 dockets / $1.02M invoice gap (Finding #63).
| Row | Docket | Client | Payment | RCL 20% | Credited | Inv # | Date | To Operating | Flag |
|---|---|---|---|---|---|---|---|---|---|
| 2 | 33103.03U | KFU | 11,840 | 2,368 | Yes | — | — | — | — |
| 3 | 33103.70U | KFU | 11,840 | 2,368 | Yes | — | — | — | — |
| 4 | 33103.84U | KFU | 9,040 | 1,808 | Yes | — | — | — | — |
| 5 | 33103.52U | KFU | 11,440 | 2,288 | Yes | — | — | — | — |
| 6 | 33110.00U | KFU | 9,440 | 1,888 | Yes | — | — | — | — |
| 7 | 33110.43U | KFU | 9,440 | 1,888 | Yes | — | — | — | — |
| 8 | 33103.60U | KFU | 11,840 | 2,368 | Yes | — | — | — | — |
| 9 | 33103.99U | KFU | 9,440 | 1,888 | Yes | — | — | — | — |
| 10 | 33102.73U | KFU | 2,400 | 480 | Pending | — | — | — | — |
| 11 | 33103.73U | KFU | 11,840 | 2,368 | Pending | — | — | — | — |
| 12 | 33103.88U | KFU | 11,840 | 2,368 | Pending | — | — | — | — |
| 13 | 33103.89U | KFU | 11,840 | 2,368 | Pending | — | — | — | — |
| 14 | 33110.10U | KFU | 11,840 | Unknown | Pending | 405541 | 2023-06-19 | Yes | ⭐ |
| 15 | 33120.07S | KFU | 400 | Unknown | Pending | 405526 | 2023-06-19 | Yes | ⭐ |
| 16 | 33110.39U | KFU | 2,400 | Unknown | Pending | Unknown | 2023-06-06 | Yes | ⭐ |
| 17 | 33044.26U | KU | 2,400 | Unknown | Pending | 421530 | 2023-06-09 | Yes | ⭐ |
| 18 | 33044.28U | KU | 13,200 | Unknown | Pending | Unknown | 2023-06-28 | Yes | ⭐ |
| 19 | 32679.02 | MSI STEM | 2,500 | Unknown | Pending | Unknown | 2023-06-26 | Unknown | ❓ |
The 5 starred rows all share: (a) "Unknown" Estimated RCL 20%, (b) "Pending" credited status, (c) "Yes" on Transferred-to-Operating, and (d) a known Date Received in June 2023. These are transfers NGM already moved out of trust to operating during the 22-day window June 6-28, 2023 — and the RCL 20% share was never computed or credited. They were added to the tracker after the initial version (this is the "Updated" tracker), meaning they are NEWLY-IDENTIFIED June 2023 trust receipts that escaped the first allocation review.
The June 2023 tracker's 18 rows sit inside the Finding #51 window (Jan 2023 – Nov 2024) and overlap specifically with June 2023 KFU/KU receipts. The $154,980 total is ~1.6% of the $9.89M Finding #51 unallocated universe. It is not a duplicate; it is a granular docket-by-docket sample showing the "Pending" / "Unknown RCL 20%" pattern on a specific high-density month. Finding #51's headline numbers are corroborated, not modified.
Transfer vs Credit Reconciliation.csv)File 1 is a DIFFERENT dataset than the 69-row reconciliation. Proven by direct comparison:
| Dimension | 69-row Reconciliation (04/07) | File 1 (04/16) |
|---|---|---|
| Row count | 69 | 18 |
| Transfer date range | 2021-05-18 → 2021-10-20 | 2023-08-01 → 2025-05-07 |
| Credit/Withdrawal date range | 2022-11-28 → 2024-06-20 | same (embedded) |
| Bank accounts | Freedom Bank (15), BoA→Eagle (15), BoA (3), blank (36) | t3 BoA Escrow, t23 Eagle Bank ONLY |
| Primary client | KFU (client 36372) | Hurysz, Johnson, Jouf |
| Match Status | 100% "Uncredited" | No explicit "Match Status" column |
| Focus | Pre-arbitration 2021 transfers vs post-arbitration withdrawals | Post-arbitration 2023-2025 transfers exclusively |
The 69-row reconciliation is the authoritative record of 2021 transfers that later resulted in uncredited KFU withdrawals via Freedom Bank. File 1 is the post-arbitration follow-up, covering a completely separate time period and different clients, with no Freedom Bank activity visible at all. This is important: file 1 demonstrates that the post-arbitration trust infrastructure was operating on t3/t23 only, with Freedom Bank used for separate (and separately-concealed) client flows.
File 2's June 2023 snapshot predates the Oct 2023 PAR series by 4 months. It captures the state of KFU/KU receipts at the exact arbitration pivot — $154,980 in receipts over 22 days containing $24,448 in known-RCL-20% and another ~$30,640 of unknown-but-likely-owed RCL share. Neither figure appears in the Oct 2023–Jun 2025 PAR series because those 22 days sit in the gap between the last arbitration-period ledger and the first PAR. This means the 20% rule was running hot in the weeks immediately AFTER the Award but was NOT being credited — consistent with Finding #117 ("NGM paid zero post-9/27/2020 under the 20% formula").
File 1's bank accounts: - t3 = BoA Escrow 8777 — DISCLOSED in Exhibit A ✓ - t23 = Eagle Bank Trust 0495 — DISCLOSED in Exhibit A ✓ - Freedom Bank 220001028 / 220001002 — NOT present in file 1 - BoA Wire Receipt 8751, BoA Operating 2417 — NOT present in file 1
The absence of Freedom Bank transactions in a Jun 2023–Jun 2025 transfer log purportedly spanning 24 months is significant. It is consistent with Finding #99's thesis: Freedom Bank was used for a SEPARATE, UNDISCLOSED client-wire flow, not for the routine docket-level trust-to-operating sweeps visible in file 1.
File 2 says 8 of 18 June 2023 dockets are marked "Credited = Yes". This appears to contradict Finding #117. However: 1. "Credited" in Soluno/uncle's tracker means the fee-credit entry was posted in NGM's internal Soluno ledger — not that Litman received a payment. 2. Even for the 8 Yes-credited rows, the RCL 20% share is only computed ($2,368 / $2,368 / $1,808 / $2,288 / $1,888 / $1,888 / $2,368 / $1,888 = $16,864). The tracker does NOT say Litman received the $16,864. 3. Finding #117 concerns actual payments into Litman's accounts (e.g., Fidelity 645375268, Finding #104). The Fidelity timeline shows no June 2023 payment — regular monthly payments did not resume until April 2024. 4. Therefore file 2 is consistent with Finding #117: Soluno "credit" ≠ actual payment. The 20% fee-credit shows up in NGM's books but does not translate into money in Litman's hand.
Neither file supersedes or expands the existing headline findings. Both are surgical plaintiff-prepared slices that illustrate the mechanics of the allocation-omission pattern at the docket level. File 2's value is its temporal specificity (arbitration Award pivot, 6/6–6/28/2023); file 1's value is its identification of Goldberg's personal email directives ("Please take the funds 12/26/2024 8:54 AM") and the cross-docket trust movements that happen when Soluno cases "are not open."