Source file: evidence/uncle_batch_2026-04-16/Client_Trust_and_Transfer_Data.xlsx
File size: 869,235 bytes (largest XLSX in the 2026-04-16 uncle batch by ~100× the next file)
Original path / created: /Users/awesomefat/Downloads/Client_Trust_and_Transfer_Data.xlsx; created 5/15/2025
PC Law run-stamps inside the workbook: "Wednesday, May 03, 2023 at 06:14:47 PM" (April reports), "Jun/13/2023" (May reports), "7/11/2023" (June reports). "Requested by: joshg" — i.e., Joshua Goldberg personally generated these reports from NGM's PC Law system.
Significance: The file is the first substantive evidence covering Q2 2023 to enter our corpus. It is trust-side accounting data (Client Trust Ledger + Client Trust Listing + Bank Journals + Transfer Journal + Trust Register) and does not substitute for the missing Q2 2023 Fee Allocation Summary / Client WIP / "Litman 2023 Summary 2QTR" that NGM should have produced (cf. output/QUARTERLY_REPORTS_2020_2023_INDEX.md line 36). But it partially closes Open Gap #21 for Q2 2023 trust activity and provides the only firm-wide trust account numbers we have for the quarter bracketing the 6/14/2023 arbitration award.
| # | Sheet | Rows | Period | Format | What it is |
|---|---|---|---|---|---|
| 1 | 042023_Client Trust Ledger |
80,014 | Through Apr/30/2023 | PC Law v13.0 SP2 report, linearized | Firm-wide matter-by-matter trust ledger (274 pages). Cumulative from inception. |
| 2 | 042023_Client Trust Listing |
2,100 | As of Apr/30/2023 | PC Law report | Snapshot of all client matters with trust balances. |
| 3 | 042023_Trust Bank Matter-to-Mat |
223 | Apr/1/2023 – Apr/30/2023 | PC Law report | Matter-to-matter transfers within t3 (BOA Escrow). |
| 4 | 042023_Trust Bank Journal |
1,394 | Apr/1/2023 – Apr/30/2023 | PC Law report | Every trust-account transaction (receipts + disbursements) for April 2023. |
| 5 | 052023_Trust Bank Journal |
2,494 | May/1/2023 – May/31/2023 | PC Law report | Every trust-account transaction for May 2023. |
| 6 | 062023_Trust Bank Journal |
2,095 | 6/1/2023 – 6/30/2023 | PC Law report (flattened) | Every trust-account transaction for June 2023. |
| 7 | 062023_Trust_Transfer_Journal |
1,501 | 6/1/2023 – 6/30/2023 | PC Law report | Trust-to-operating transfers for June 2023. |
| 8 | 062023_TrustRegister |
865 | 6/1/2023 – 6/30/2023 | PC Law report | All t3 (BOA Escrow) register entries with running balance for June 2023. |
The workbook was populated by a PDF-to-Excel extraction — each "row" of the original PDF appears as a vertical sequence of cells in column A. Reconstruction requires a block-scan (17 cells per Trust Bank Journal entry, 10 cells per Trust Register entry).
From the month-summary rows at the end of each Trust Bank Journal sheet (the only account present in this file — all three monthly bank journals cover only account "3 - BANK OF AMERICA - ESCROW ACCT"):
| Month | Opening Balance | Receipts (In) | Disbursements (Out) | Closing Balance |
|---|---|---|---|---|
| April 2023 | $1,607,685.89 | $95,835.37 | $488,475.47 | $1,215,045.79 |
| May 2023 | $1,215,045.79 | $1,060,794.38 | $939,471.00 | $1,336,369.17 |
| June 2023 | $1,336,369.17 | $634,766.29 | $415,254.82 | $1,555,880.64 |
| Q2 2023 TOTAL | $1,607,685.89 | $1,791,396.04 | $1,843,201.29 | $1,555,880.64 |
Net change over Q2 2023: –$51,805.25, which reconciles exactly against the closing vs. opening balance (verified).
These are the authoritative firm-wide trust-account totals we now have for Q2 2023. They were previously entirely absent from the corpus.
The largest single Q2 2023 disbursement is $523,144.00 out of KFU master docket 36372 on 6/15/2023 — exactly one day after the 6/14/2023 arbitration award (June Trust Register, 062023_TrustRegister row 325 cluster). The same day shows $545,090.00 total across the two KFU items.
Also during Q2 2023, $10,940.00 was transferred on 6/6/2023 from KFU docket 33110.67U into the KFU master docket 36372 (type code "TC" — trust credit). That is the single Trust Transfer Journal entry for June 2023. The entire month's Transfer Journal shows only one real trust-to-operating / trust-to-trust transfer — this is surprisingly thin.
The Client Trust Ledger sheet (80K rows) contains Matter 36056 / Client 140400 (Litman, Richard C.). Inside this matter, 48 unique "Litman Percentage" entries are recorded covering October 2018 through April 12, 2023 — meaning this file directly documents the actual payment cadence for the final pre-arbitration quarters:
| Month | Count | Sum |
|---|---|---|
| Oct 2018 | 1 | $59,225.91 (Pay RCL 3rdQTR2018) |
| Jan 2023 | 14 | $60,795.31 |
| Feb 2023 | 15 | $44,073.20 |
| Mar 2023 | 17 | $54,284.40 |
| Apr 2023 | 1 | $109,861.22 (single 4/12/2023 entry — "Litman Percentage Payment Transfer to Operating Litman Per...") |
| Total (Jan–Apr 2023) | 47 | $269,014.13 |
The April 12, 2023 entry is a single lump "Transfer to Operating" at $109,861.22 — this is an internal accounting reclassification, not necessarily a cash disbursement to Litman. The prior daily-cadence January–March 2023 entries are all checks payable to "Richard C. Litman" (Check numbers 7263, 7266, 7271, 7277, 7279, 7281, 7283, 7292, 7293, 7294, 7356, 7358, 7359, 7360, 7365, 7368, 7372, 7375, 7377, 7380, 7383, 7387, etc. — a continuous sequence through March 2023).
The Client Total line for matter 36056 (row 53879) shows a cumulative account of $404,600.76 in / $365,586.66 out / $39,014.10 balance — meaning matter 36056 ended April 2023 carrying $39,014.10 in Litman's own trust ledger.
Significance vs. Finding #117: The daily Jan–Mar 2023 "Litman Percentage" check sequence (checks 7263–7387) is actual PC Law-booked check activity to Richard C. Litman — not merely a disability-offset bookkeeping construct. If Finding #117 holds that NGM made zero 20%-formula disbursements after 9/27/2020, these PC Law check numbers need to be reconciled against actual BOA check-image production (and/or Fidelity 645375268 deposits) to confirm whether the checks cleared. The file tells us NGM recorded them as paid; it does not prove they were negotiated. This is a targeted discovery item (check-image production for checks 7263–7387).
NO — but the April 2023 Client Trust Ledger contains 119 unique Freedom Bank references.
Implication for Finding #99: This is new, independently corroborating evidence that NGM actively moved client funds through Freedom Bank pre-2023 and recorded those movements in PC Law as free-text descriptions on the BOA ledger, while not maintaining Freedom Bank as a PC Law-tracked trust-bank code. This is the exact opposite of the basic NY RPC 1.15 / VA RPC 1.15 / DC RPC 1.15 three-way-reconciliation requirement (individual-client-ledger + bank-statement + firm-ledger tie-out). The absence of a Freedom Bank account code in NGM's 2023 trust-accounting system is itself a trust-accounting violation (cf. Finding #67 category 4, "Three-way reconciliation failure"). And it is consistent with — and adds weight to — the spoliation / active-concealment theory of Finding #99: if Freedom Bank was never tracked as an account code, it could be treated as off-the-books for firm-level reconciliation while still physically holding client money.
Cross-reference to Finding #51 (KFU $9.89M unallocated Jan 2023 – Nov 2024): this file gives us the Q2 2023 slice of that universe and confirms the master-docket routing pattern (KFU receipts into t3, internal transfers to master 36372, then disbursement via "Multi" check lines to "Nath & Associates PLLC" — the operating account). The 6/15/2023 $523,144.00 check to "Nath & Associates PLLC" out of 36372, on the day after the arbitration award, is a candidate transaction for trust-to-operating sweep forensic analysis.
output/QUARTERLY_REPORTS_2020_2023_INDEX.md: This file does not close the Q2 2023 quarterly-report row. Q2 2023 remains MISSING for Fee Allocation Summary / Client WIP / Litman 2023 Summary 2QTR.Partially — for trust-side accounting only, NOT for fee-allocation reporting.
Recommendation: Uncle's file CLOSES the trust-activity portion of Open Gap #21 and provides strong new input for Findings #51, #67, #99, #117. It DOES NOT close the Q2 2023 row in QUARTERLY_REPORTS_2020_2023_INDEX.md — the Payment Allocation quarterly report itself remains outstanding and is the subject of the 04/16/2026 discovery demand (output/DISCOVERY_DEMAND_QUARTERLY_REPORTS_GAPS_20260416.md).
NGM's PC Law system clearly had the Q2 2023 data the entire time. The reports were generated on 5/3/2023 (April), 6/13/2023 (May), and 7/11/2023 (June) by joshg — i.e., Goldberg himself. That NGM never produced these files in the original production is the same active-concealment pattern documented at Finding #50 (July 2025 PAR) and Finding #99 (Freedom Bank). Uncle had to supply them in 2025–2026.
Check images for checks 7263–7387 (approx. Jan 5 – Mar 28, 2023) are a targeted discovery demand. These bear sequential numbers and are booked in the Client Trust Ledger as payable to Richard C. Litman. If the cleared-check images match, Finding #117 narrows to post-Mar 2023; if they don't clear, Finding #117 is reinforced.
Freedom Bank account code (t20) absence from NGM's PC Law through June 2023 — an independent RPC 1.15 violation. Subpoena target: Freedom Bank of Virginia for full statement history on accounts 220001028 + 220001002 for 2017–2025.
The 6/15/2023 $523,144.00 KFU sweep (one day post-arbitration) is a candidate adverse-inference exhibit: it shows post-award conduct of draining the largest single KFU trust balance into the operating account with the memo line "Nath & Associates PLLC."
Q2 2023 Fee Allocation Summary / Client WIP / Litman 2023 Summary 2QTR should be specifically demanded by document type and quarter — they are still missing despite this trust-side file being available. The discovery demand should cite this file as evidence NGM's PC Law system produced quarterly trust reports on demand; there is no technical obstacle to producing the missing fee-allocation counterpart for Q2 2023.
File stored at: evidence/uncle_batch_2026-04-16/Client_Trust_and_Transfer_Data.xlsx (869,235 bytes)
Extraction script: scripts/extract_q2_2023_trust_data.py, scripts/extract_q2_2023_v2.py, scripts/extract_q2_2023_v3.py
Raw extracts: /tmp/q2_2023_extract.log, /tmp/q2_2023_v2.log, /tmp/q2_2023_v3.log