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To Scott Five Kfu Searches Demand

DEMAND LETTER PACKAGE — Five Uncredited KFU Search Dockets

To: Scott [Counsel for Richard C. Litman] From: Mike Litman, on behalf of Richard C. Litman Date: 2026-04-22 Re: Single most glaring accounting discrepancy — $2.76M+ unaccounted-for KFU trust transfers on five (5) "search" dockets Attachments: This memo and supporting CSV/PDF exhibits (available on request)

The request

Before addressing the broader pattern of under-allocation (which is extensive), my uncle asks that counsel open the accounting-correction negotiation with one clean, undisputed discrepancy: five King Faisal University ("KFU") dockets that Mr. Litman identified by number to defendant Joshua Goldberg in his June 7, 2025 email. Every one of these dockets is flagged as outstanding ("OUT") in Defendant's own produced trust ledger, and every one reflects a material gap between what Defendant's produced records show and what Defendant's internal records (not yet produced) are believed to show.

We request: (a) production of the underlying records that would reconcile the discrepancy, and (b) in the event the records do not reconcile to our client's satisfaction, payment of the unpaid 20% originating-attorney allocation on the full, unreconciled amount.

The five dockets (per Mr. Litman's June 7, 2025 email to Mr. Goldberg)

# Docket No. Matter Title
1 33110.43U Phytochemical Analysis And Antibacterial Activity Of Zinc Nanoparticles
2 33110.63U Cream That Helps Heal Wounds And Eliminate Pathogen Bacteria
3 33110.92U Pyrido[4',3':4,5]Pyrrolo[3,2-B][1,7]Naphthyridine Compounds As Anticancer Agent
4 33120.22S Antiproliferative Selenatedfolate Hybrids (search-only)
5 33120.26S PYRIDO[3',4':4,5]PYRROLO[2,3-C] Isoquinoline Compounds As Anticancer Agent (search-only)

The "S" suffix on dockets 4 and 5 is NGM's internal designation for search-only matters. Per NGM's own published fee schedule, search-only matters carry a $500 USPTO search fee. Dockets 1–3 are "U" utility patent matters that would typically see fee applications over the full lifecycle but retain standard per-phase fee structures.

What Defendant's own produced records show

Docket Financial Summary (KFU_DOCKET_FINANCIAL_SUMMARY.csv)

Docket Billed Received Unpaid Litman 20%
33110.43U $16,624 $16,624 $0 $3,324.80
33110.63U $17,520 $17,520 $0 $3,504.00
33110.92U $13,000 $13,000 $0 $2,600.00
33120.22S $400 $400 $0 $80.00
33120.26S $400 $400 $0 $80.00
Total $47,944 $47,944 $0 $9,588.80

Trust Ledger (KFU_TRUST_LEDGER_36372.csv) — all five resolved to a single 6/19/2023 transfer each

Date Docket Description Status Disbursement
6/19/2023 33120.22S TRF: Nath Goldberg & Meyer, in trust OUT $400.00
6/19/2023 33120.26S TRF: Nath Goldberg & Meyer, in trust OUT $400.00
6/19/2023 33110.43U TRF: Nath Goldberg & Meyer, in trust OUT $11,840.00
6/19/2023 33110.63U TRF: Nath Goldberg & Meyer, in trust OUT $11,840.00
6/19/2023 33110.92U TRF: Nath Goldberg & Meyer, in trust OUT $11,440.00
$35,920.00

Notable on the face of Defendant's own ledger:

  1. All five transfers are dated June 19, 2023 — five days after the June 14, 2023 arbitration award.
  2. All five carry status "OUT" — Defendant's own records concede the entries remain unreconciled / outstanding.
  3. The receipts column is empty on every row. The produced ledger reflects only the disbursement leg; the corresponding deposit that funded these transfers has not been produced.

The discrepancy — Mr. Litman's contemporaneous characterization

Mr. Litman represents, from sources he has personally reviewed but which Defendant has not produced, that the actual trust activity on these five dockets consists of transfers in the range of $550,000+ each, aggregating to over $2,760,000. All five are designated "Uncredited" in whatever internal records he is viewing — i.e., the 20% originating-attorney allocation has never been applied to any of them.

Source Total on these 5 dockets Litman 20% owed
Per produced records $35,920.00 $9,588.80 (implicit — but none of the 5 show any RCL credit)
Per Mr. Litman's internal review $2,760,000.00+ $552,000.00+

The $2.7M+ discrepancy is itself probative. It is consistent with Mr. Litman's longstanding position — most recently documented in his May 22, 2025 and June 7, 2025 emails to Defendant — that the monthly allocation reports Defendant furnished since July 2023 capture only matters then-coded to Attorney 418, and that a material population of KFU clients have been recoded, reassigned, or simply omitted from those reports.

What we want Scott to ask opposing counsel to produce

Please request production of the following, all of which are directly responsive to the existing reconciliation demands and are necessary to resolve the $2.7M+ discrepancy:

  1. The complete Tabs3 / Practice Master (or successor Soluno) client ledger for each of the five dockets (33110.43U, 33110.63U, 33110.92U, 33120.22S, 33120.26S), from matter inception through the present, showing every receipt, disbursement, invoice, and allocation entry, in native format with all columns, formulas, and revision history intact.

  2. Trust account 36372 deposit slips, wire confirmations, and bank statements for the period May 1, 2023 through July 31, 2023. This is the period containing the inflow that funded the June 19, 2023 transfers already on the produced ledger. The deposit leg is missing from the produced records.

  3. All monthly Attorney 418 ("RL") allocation reports for July 2023 through the present, in native Excel format with formulas intact, including the audit trail of any client whose Attorney 418 designation was added, removed, or modified during that period.

  4. The complete list of the "676+ clients" Defendant himself acknowledged on June 7, 2025 as comprising the Attorney 418 universe, with date-stamped records of any reassignment of any of those clients to a different originating-attorney code.

  5. All trust-account activity on any docket bearing the "S" search-only suffix for King Faisal University from June 15, 2020 through the present — to test whether the $550,000+ pattern Mr. Litman describes appears in the unredacted records.

  6. All internal communications between Defendant Goldberg, Catherine Schaefer, Martha Long, Howard Kline, Valencia Gray, and any bookkeeper or controller that reference any of the five dockets above, between January 1, 2023 and the present.

Payment demanded pending reconciliation

We ask Defendant to, within 21 days:

  1. Produce the records above, or in the alternative,
  2. Pay $552,000 (20% of the $2.76M Mr. Litman has identified on these five dockets), subject to true-up against records that are ultimately produced.

If Defendant's position is that the full trust activity on these five dockets is in fact only $35,920 (the figures currently on the produced records) and that Mr. Litman's $2.76M characterization is incorrect, Defendant can establish that by producing the requested source records. Absent production, the $2.76M figure from Mr. Litman's direct review stands as the best available evidence of actual trust activity on these dockets, and the 20% allocation on that amount is owed.

Why this particular example, and why now

Five dockets. Five numbers Mr. Litman gave Defendant on June 7, 2025. All five flagged "OUT" in Defendant's own ledger. All five transferred five days after the arbitration award. Zero contested complexity about what "20% of KFU trust activity on these dockets" means.

If Defendant cannot cleanly account for these five dockets, the broader pattern identified in output/KFU_RCL_MISSING_ALLOCATIONS_PDF_ANALYSIS.md — $9.89M in unallocated KFU deposits / $1.98M in unpaid RCL share across 18 months of the period Jan 2023 – Nov 2024 — is likely understated, not overstated.

Supporting files available to Scott on request

All of these exist in our litigation-support directory and can be sent in native format:

Drafting notes for Scott (can be redacted before sending)