Litman v. Goldberg, Index No. 524343/2025 (N.Y. Sup. Ct., Kings County) Source: NGM-produced Trust Bank Journal + Trust Register + Trust Listing for RCL (all dated Q1 2026), produced by NGM via Connell Foley LLP on April 17, 2026. Author per PDF footer: MaryJane Harper, PracticeMaster v1.9.13x. Purpose: To fix, as a pre-bank-statement baseline, the asserted opening and closing balances of the two NGM trust accounts disclosed in Q1 2026, and the asserted Richard C. Litman-attributed positions on each. Any discrepancy between these figures and subsequently subpoenaed bank statements is spoliation on its face.
| Month | Opening Balance | Deposits (#) | Deposits ($) | Disbursements (#) | Disbursements ($) | Closing Balance |
|---|---|---|---|---|---|---|
| January 2026 | $1,324,984.41 | 25 | $84,627.00 | 40 | $102,043.00 | $1,307,568.41 |
| February 2026 | $1,294,242.41 | 32 | $395,031.10 | 52 | $355,516.00 | $1,333,757.51 |
| March 2026 | $1,333,757.51 | 18 | $36,529.16 | 47 | $114,129.00 | $1,256,157.67 |
| Q1 2026 | $1,324,984.41 (Jan open) | 75 | $516,187.26 | 139 | $571,688.00 | $1,256,157.67 (Mar close) |
Jan 31, 2026 closing = $1,307,568.41. Feb 1, 2026 opening = $1,294,242.41. Delta = −$13,326.00. NGM's own monthly journals do not stitch. No transaction in either journal accounts for this movement. This will be the first thing we test against the subpoenaed Eagle Bank statement.
| Month | Opening Balance | Deposits (#) | Deposits ($) | Disbursements (#) | Disbursements ($) | Closing Balance |
|---|---|---|---|---|---|---|
| January 2026 | $96,231.64 | 0 | $0.00 | 1 | $15,296.00 | $80,935.64 |
| February 2026 | $80,935.64 | 0 | $0.00 | 0 | $0.00 | $80,935.64 |
| March 2026 | $80,935.64 | 0 | $0.00 | 1 | $1,622.78 | $79,312.86 |
| Q1 2026 | $96,231.64 (Jan open) | 0 | $0.00 | 2 | $16,918.78 | $79,312.86 (Mar close) |
The single Jan disbursement was $15,296.00 on 1/13/2026 for Kuwait University, docket 33050.10U, invoice #422965, transaction # 3989371. The single March disbursement was $1,622.78 on 3/27/2026 for Qatar Foundation, docket 32605.29, invoice #405118.
| Snapshot | Eagle Bank (t23) | BoA Escrow (t3) | RCL Total | # Matters |
|---|---|---|---|---|
| January 31, 2026 (receipts-filtered listing) | $826,031.08 | $1,863,705.24 | $2,689,736.32 | 63 |
| February 28, 2026 (full snapshot) | $1,046,123.40 | $46,303.33 | $1,092,426.73 | 228 |
| March 31, 2026 (full snapshot) | $1,002,625.40 | $44,680.55 | $1,047,305.95 | 232 |
| Document | Date Produced | Figure | Source Field |
|---|---|---|---|
| Trust Listing for RCL Jan 2026 | 4/17/2026 | $1,863,705.24 | "Bank of America Escrow Acct_8777" column, RCL responsible, Jan 2026 month-end |
| Trust Register Report Jan 2026 | 4/17/2026 | $96,231.64 opening / $80,935.64 closing | Firm-wide t3 balance, same account, same month |
| Unaccounted-for excess | ≈ $1,782,769.60 | Difference between what NGM says Litman holds vs. what the account actually contains firm-wide |
NGM produced both documents. The contradiction is on the face of the 4/17/2026 production. No bank statement is needed to establish it.
5 Kuwait University dockets vanished from the RCL Trust Listing between January 2026 and February 2026, with no corresponding disbursement in either the Eagle Bank or BoA Escrow Trust Bank Journal:
| Docket | Description | Jan 2026 Bal | Feb 2026 Bal | Fate |
|---|---|---|---|---|
| 33050.12U | U.S. Patent Application | $15,296.00 | $0.00 | Reassigned off RCL (no bank movement) |
| 33050.08U | U.S. Patent Application | $14,296.00 | $0.00 | Reassigned off RCL (no bank movement) |
| 33050.02U | U.S. Patent Application | $13,396.00 | $0.00 | Reassigned off RCL (no bank movement) |
| 33050.05U | U.S. Patent Application | $12,896.00 | $0.00 | Reassigned off RCL (no bank movement) |
| 33050.13U | U.S. Patent Application | $12,396.00 | $0.00 | Reassigned off RCL (no bank movement) |
| TOTAL | $68,280.00 | $0.00 |
| Date | Acct | Tran# | Docket | Counterparty | Direction | Amount |
|---|---|---|---|---|---|---|
| 2/9/2026 | Eagle t23 | 4000959 | 36372 | King Faisal University | IN (wire) | $291,173.00 |
| 2/10/2026 | Eagle t23 | 4001216 | 36372 | Nath & Associates PLLC | OUT (trust → op) | $224,113.00 |
$67,060.00 of the KFU wire remained in Eagle Bank against docket 36372. $224,113.00 transferred to NGM's operating account within 24 hours of receipt. This is the biggest single Q1 2026 cash event on any Richard C. Litman-originated matter. Richard C. Litman remains identified on NGM's own internal records as the Responsible Attorney on docket 36372 as of 3/31/2026 (last trust entry: 2/17/2026).
| Stage | Amount | Source Document |
|---|---|---|
| 1. Billed under Richard Litman (Collecting Lawyer, all years) | $1,513,899.04 | AR_Report_202604_RL.xlsx, 496 lines |
| └─ of which dated ≥ 7/18/2025 (post-termination) | $176,070.00 | 35 invoices, 100% outstanding |
| └─ of which dated in Q1 2026 | $0.00 | None in production |
| 2. Paid by client in Q1 2026 on RCL-originated dockets | $127,052.78 | Payment Allocation Jan/Feb/Mar |
| └─ Collected Fees (share-calc base) | $94,240.00 | Litman 2026 Summary_March.xlsx |
| 3. Deposited into firm trust (Eagle + BoA) Q1 2026 | $516,187.26 / $0.00 | Trust Bank Journals |
| 4. Disbursed to operating (Q1 2026, trust→op transfers) | ~$446,182.15 (Jan alone) | Trust Transfer Journals |
| 5. Litman's 20% share accrued | $18,848.00 | Litman Summary + Gould email 4/17/2026 |
| └─ Paid in Q1 | $0.00 | Paid-in-Month column all zero |
| └─ Wired 4/17/2026 ("shortly") | $18,848.00 | Gould email |
| NGM's 80% retained share | $75,392.00 | Computed: Collected Fees − 20% share |
This Exhibit reflects balances, deposit counts, disbursement counts, and amounts as represented by Defendant NGM in documents produced by Connell Foley LLP on April 17, 2026. The amounts above are taken from the following NGM-produced files, each archived at evidence/ngm_q1_2026_payment_backup_20260417/:
Richard C. Litman reserves all rights to challenge each figure in this Exhibit against subsequently produced bank statements, reconciliation worksheets, and any other documents in NGM's possession. This Exhibit is served without prejudice and without waiver.
Prepared April 18, 2026 by the Plaintiff's analysis team. All reconciles penny-to-penny with NGM's own summary lines.