To: Richard C. Litman / Scott D. Woller, Esq.
Re: Aaron H. Gould email of 4/17/2026 10:05 AM ET (Q1 2026 NGM payment backup)
Prepared: 2026-04-17
Source: 36 files produced by NGM via Connell Foley (now archived at evidence/ngm_q1_2026_payment_backup_20260417/)
Per NGM's own Litman 2026 Summary_March.xlsx:
| Month | Funds Received | Collected Fees | 20% Share Due | Paid in Month |
|---|---|---|---|---|
| Jan 2026 | $7,542.00 | $2,250.00 | $450.00 | $0.00 |
| Feb 2026 | $115,374.00 | $91,240.00 | $18,248.00 | $0.00 |
| Mar 2026 | $4,136.78 | $750.00 | $150.00 | $0.00 |
| Q1 2026 | $127,052.78 | $94,240.00 | $18,848.00 | $0.00 |
Gould's 4/17 email states the $18,848 "is being wired shortly."
| Period | 20% Share Paid to Litman |
|---|---|
| Q1 2024 | $451,961 |
| Q1 2025 | ~$134,756 (20% of $673,763 collected fees) |
| Q1 2026 | $18,848 |
Drop from Q1 2024 to Q1 2026: −95.8%. Drop from Q1 2025 to Q1 2026: −86.0%.
The three Payment Allocation by Client Report for RCL as originating attorney spreadsheets show NGM's billing system continues to tag every dollar of this client work to Litman's identity:
| Client | Files (dockets) | Line Items | Fees Attributed | Total Attributed |
|---|---|---|---|---|
| King Faisal University | 36 | 304 | $88,240 | $112,374 |
| Sultan Qaboos University (Oman) | 1 | 7 | $94,240 | $118,374 |
| King Saud University | 4 | 19 | $6,000 | $21,735 |
| Qatar Foundation | 1 | 1 | $0 | $1,623 |
| Total Q1 2026 | 42 | 334 | $188,480 | $254,106 |
Note that Sultan Qaboos University and Qatar Foundation do not appear in prior-period memory or the 905-patent dataset. If NGM is attributing new client relationships to Litman's name in 2026 (7+ months post-termination), each attribution is a § 51 use that did not exist at the time of the complaint.
The split between $188K "fees" attributed and $94K "collected fees" in the Summary reflects a 50/50 origination/collecting split internally (i.e. Litman is credited with only half the attributed revenue before the 20% overlay is applied). The $254K figure is the defendant's own internal measurement of the commercial value of using Litman's name in Q1 2026.
From AR_Report_202604_RL.xlsx — Collecting Lawyer Firm Summary:
| Metric | Value |
|---|---|
| Total billed under "Collecting Lawyer = Richard Litman" | $1,302,403.04 |
| Total paid | $77,213.28 (5.93%) |
| Outstanding | $1,225,189.76 (94.07%) |
| 100% of outstanding is in the "Older" aging bucket | |
| Invoice line items | 496 |
| Unique dockets | 374 |
| Unique clients | 15 |
| Client | Outstanding |
|---|---|
| King Saud University | $1,135,130 |
| United Arab Emirates University | $76,062 |
| Sabah Al-Ahmad Center for Giftedness | $58,958 |
| Qatar Foundation | $55,279 |
| Kuwait Institute for Scientific Research | $30,022 |
| Kuwait University | $25,906 |
| Saline Water Desalination Research Institute | $16,300 |
| Imam Mohammad Ibn Saud Islamic University | $15,044 |
| Kuwait Oil Company | $8,420 |
| Simmons Lighting, LLC | $7,590 |
| Year | Invoices | Outstanding |
|---|---|---|
| 2024 | 199 | $655,402 |
| 2025 | 161 | $450,872 |
| 2023 | 38 | $145,557 |
| 2022 | 27 | $59,210 |
| 2018–2021 | 71 | cumulative |
The 161 invoices dated 2025 include billings both before and after Litman's July 2025 termination. Each invoice is a document of NGM's own creation that identifies "Richard Litman" as the Collecting Lawyer on a NGM-to-client billing relationship — a § 51 commercial use on the invoice face.
Litman is tagged as the Credit Lawyer on $515,036 billed / $449,534 outstanding (36.69% of firm AR). The next largest are:
| Credit Lawyer | Outstanding |
|---|---|
| Richard Litman | $449,534 (36.69%) |
| "Firm Client" | $183,179 |
| Andy Rao | $72,237 |
| James N. Lafave | $70,903 |
| Joshua B. Goldberg | $65,866 |
| Ilirian Durri | $52,403 |
| Morgan D. Rosenberg | $53,887 |
| Howard Kline | $5,333 |
Per the three Trust Listing for RCL PDFs:
| Snapshot | Eagle Bank (t23) | BoA Escrow (t3) | RL Total |
|---|---|---|---|
| Jan 2026 | $837,871.08 | $1,863,705.24 | $2,701,576.32 |
| Feb 2026 | $1,046,123.40 | $46,303.33 | $1,092,426.73 |
| Mar 2026 | $1,002,625.40 | $44,680.55 | $1,047,305.95 |
Between the Jan closing and Feb opening, $1,817,401.91 disappeared from the BoA Escrow balance attributable to RL matters (while Eagle Bank went up $208K). The net RL-attributed trust drop is $1,609,149.59 in 24 hours.
The corresponding Trust Register Feb 2026 shows firm-wide bank movement over the entire month totaling only −$40,484.90 net. The $1.6M drop therefore reflects reassignment of responsible attorney from "RL" to other attorneys, not actual bank disbursement.
This is the trust-ledger equivalent of the Line 74 switchover (Jan 14–21, 2025, where Goldberg's name replaced Litman's on patent front pages). The reassignment pattern is now repeating at the trust-accounting level.
Trust Listing for RCL Jan 2026.pdf claims RL held $1,863,705.24 in BoA Escrow Acct_8777. But Trust Register Report Jan 2026.pdf shows firm-wide BoA Escrow balance = $96,231.64 opening / $80,935.64 closing. RL's claimed share exceeds the entire account by ~$1.78M.
Interpretations (pick one or more, all actionable):
Any of these warrants a demand for the underlying bank statements for BoA Acct_8777 covering 2024–2026.
Both the Trust Register and Trust Listing Q1 2026 show only two accounts:
Freedom Bank (the third trust account closed 7/28/25 after suit filing) is absent. Consistent with prior finding that Freedom Bank was never reintegrated after closure.
NGM's own Litman 2026 Summary_March.xlsx (partial — numbers are collected-fees / 20% share):
| Month | 20% Due Litman |
|---|---|
| Jan 2024 | $132,637 |
| Feb 2024 | $163,314 |
| Mar 2024 | $156,011 |
| Oct 2024 (peak) | $257,120 |
| Mar 2025 | $89,240 |
| Jul 2025 (termination month) | $6,392 |
| Oct 2025 | $125,666 |
| Dec 2025 | $55,220 |
| Jan 2026 | $450 |
| Feb 2026 | $18,248 |
| Mar 2026 | $150 |
Aggregate 2024: ~$1,019K in 20% share due over 12 months. Aggregate Jan–Mar 2026: $18,848.
This collapse coincides temporally with:
Yet the AR Report simultaneously shows NGM continues to bill $1.3M under Litman's name and tag $254K of Q1 2026 client work to him as originating attorney. The discrepancy between what NGM earns under Litman's name and what NGM pays Litman under the 20% agreement is widening, not closing.
The Q1 2026 data is a contemporaneous admission that NGM's commercial exploitation of Litman's identity is ongoing 8 months after termination. Every:
...is a discrete use of name for commercial purpose captured in NGM's own records. The April 2026 AR Report alone itemizes 496 separate uses on active billing documents.
If the Bill of Particulars is still supplementable, this data adds:
Three follow-up demands worth considering:
The 4/17/2026 first discovery batch binder (output/DISCOVERY_BATCH_01_EXHIBIT_BINDER.pdf) did not include any internal billing-system exemplars. A supplemental batch could add:
Scott will want to discuss whether accepting the $18,848 wire without reservation of rights could be argued as acquiescence to NGM's accounting. A cover letter framing the receipt as "without prejudice to claims that the collected-fees denominator has been suppressed and to claims that the trust reconciliation remains incomplete" would preserve the arguments above.
36 files archived at evidence/ngm_q1_2026_payment_backup_20260417/:
Core accounting (5) — Litman 2026 Summary_March.xlsx, AR_Report_202604_RL.xlsx, and the 3 Payment Allocation reports (Jan/Feb/Mar 2026).
Trust ledgers (12) — Trust Register, Trust Bank Journal, Trust Transfer Journal, Trust Listing for RCL — each for Jan, Feb, March 2026.
Email MIME wrappers (18) — ATT00001.htm through ATT00018.htm and ~WRD0005.jpg (email formatting; no substantive content).
Prepared by automated Q1 2026 payment-backup analysis pipeline. All numbers reconcile to NGM-produced source files. Cross-checks completed against the pre-5/31/2025 payment history in output/PATENT_REVENUE_LINKAGE_SUMMARY.md and project-memory file project_freedom_bank.md.