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Trust Ledger 2022 Vs Current Analysis

Trust Ledger Comparison: February 2022 PCLaw vs. Current Soluno Data

Date of Analysis: April 4, 2026 2022 Ledger: PCLaw Client Trust Ledger dated February 11, 2022 (187 pages, Resp. Lawyer 418) Current Data: Soluno Trust Ledger (07/2023-05/2025) + KFU-specific ledger (36372) Firm Total in Trust (Feb 2022): $10,862,610.98 receipts / $10,574,165.43 disbursed / $288,445.55 ending balance


1. KEY CLIENT TRUST BALANCES: FEB 2022 vs. CURRENT

Client PCLaw Client # Feb 2022 Balance Current (Soluno) Balance Delta
King Faisal University (KFU) 135900 $7,308.00 $84,231.87 (as of 11/20/2024) +$76,923.87
King Saud University (KSU) 135576 $33,556.64 $0.00 -$33,556.64
Kuwait Institute for Sci. Research (KISR) 136756 $4,477.00 $1,000.00 -$3,477.00
Kuwait University 137247 $3,861.67 $0.00 -$3,861.67
United Arab Emirates University (UAEU) 144725 $36,910.00 $2,000.00 -$34,910.00
Sabah Al-Ahmad Center (multiple) $34,671.00 $0.00 -$34,671.00
Dasman Diabetes Institute (multiple) $0.00 $0.00 $0.00
King Fahd University (on p.86) $1,350.40 Not in Soluno -$1,350.40
King Faisal Specialist Hospital 141782 $4,000.00 Not in Soluno -$4,000.00
TOTAL KEY CLIENT DELTA $126,134.71 $87,231.87 -$38,902.84 unaccounted

Clients That Disappeared


2. "JBG VERBAL" ENTRIES -- GOLDBERG AUTHORIZING TRUST TRANSFERS

The 2022 PCLaw ledger contains 47 entries where Goldberg personally authorized trust account transfers. These are coded as: - "JBGverbal" -- verbal authorization from Goldberg (no written documentation) - "JBG email" or "JBG em" -- email authorization from Goldberg - "Per J. Goldberg" or "per JBG" -- general Goldberg authorization - "JGBverbal" -- variant spelling (same person, typo)

KFU JBG Verbal Entries (Aug 18-19, 2021)

On a single day (August 18, 2021), Goldberg verbally authorized four inter-matter transfers within KFU totaling $5,208.00: - 32087.50 to 36372: $298.00 ("JBGverbal 8.18.2021") - 32087.14 to 36372: $3,000.00 ("JBGverbal 8.18.2021") - 32087.08 to 36372: $1,100.00 ("JBGverbal 8.18.2021") - 32087.19 to 36372: $810.00 ("JGBverbal 08.18.2021")

These consolidations moved money from individual dockets back to the KFU general matter (36372), which was then used for the massive $123,715.14 operating transfer on September 24, 2021.

KSU JBG Email Entries (Jul 14, 2020)

Goldberg authorized four KSU transfers on the same day via email: - 32809.12 to 35610: $70.00 ("JBG email 7/14/2020") - 33007.56 to 35610: $1,230.00 ("JBG email 7/14/2020") - 33007.57 to 35610: $1,230.00 ("JBG email 7/14/2020") - 33007.63 to 35610: $1,230.00 ("JBG email 7/14/2020")

Also: "PayNVG105059 NGM 301943 per JBG em 8.6.2021" -- $230.00 (Aug 10, 2021)

Qatar University JBG Entry

Sabah Al-Ahmad Center JBG Entries

Kuwait University JBG Entries

UAEU JBG Entries

Other Clients with JBG Authorizations

Significance: These entries prove Goldberg was personally managing trust account transfers for Litman's "418" clients throughout the entire period. Verbal authorizations without written documentation are particularly problematic for a trust account -- they lack the audit trail required by legal ethics rules. This predates the Soluno migration by years.


3. LUMP-SUM OPERATING TRANSFER PATTERN -- PRE-MIGRATION PROOF

The Pattern in the 2022 PCLaw Ledger

The critical finding: lump-sum operating transfers without invoice references existed in PCLaw before the Soluno migration.

KFU (36372) -- PCLaw Era Examples:

Date Amount Explanation Invoice Ref?
10/2/2020 $68,445.00 "King Faisal 36372" NO
11/25/2020 $42,315.00 "King Faisal Univ." NO
5/18/2021 $26,210.00 "Transfer to Operating" NO
9/24/2021 $123,715.14 "Transfer to Operating" NO
10/20/2021 $6,000.00 "Transfer to Operating" NO
9/9/2022 $217,710.00 "Transfer to Operating" NO
11/28/2022 $167,655.00 "Transfer to Operating" NO
11/30/2022 $24,250.00 "Transfer to Operating" NO
12/23/2022 $56,700.00 "Transfer to Operating" NO

Compare to the RARE entries WITH invoice references: | Date | Amount | Explanation | |------|--------|-------------| | 6/10/2022 | $495.00 | "Pay NVG inv 108438 (32087.37U inv 404232)" | | 10/3/2022 | $3,000.00 | "Transfer to Operating 32087.81U / 404465" | | 10/4/2022 | $3,000.00 | "Transfer to Operating Invoice 404347 32087.61U" | | 12/14/2022 | $12,500.00 | "Transfer to Operating paid inv 404493/32087.85U" |

The pattern is stark: Small transfers ($495-$12,500) sometimes have invoice references. Large transfers ($26,210-$217,710) almost never do. The total of un-referenced operating transfers in the KFU PCLaw era alone exceeds $730,000.

KSU (35610) -- PCLaw Era Examples:

The KSU general matter (35610) shows even more extreme lump-sum transfers. In August 2018 alone, there were five consecutive operating transfers in a single week: - 8/17/2018: Transfer to Operating (balance dropped from $662,058 to $530,388) - 8/21/2018: Transfer to Operating (to $397,428) - 8/22/2018: Transfer to Operating (to $265,758) - 8/23/2018: Two transfers (to $256,938, then $161,320) - 8/24/2018: Transfer to Operating (to $44,890)

Over $617,000 transferred to operating in one week, all without invoice references.

The KSU matter total shows $2,944,228.36 receipts vs. $2,937,358.91 disbursed -- essentially every dollar received was transferred to operating.

Sabah Al-Ahmad Center -- PCLaw Era:

Sabah's general matter shows repeated operating transfers in the $27,000-$33,000 range, all without invoice references: - 11/2/2018: $27,746 - 3/27/2019: $27,746 - 8/8/2019: $29,611 and $27,746 - 10/30/2019: $29,335.15 - Multiple 2020-2021 entries in the $30,000-$33,000 range

UAEU (35994) -- PCLaw Era:

UAEU general matter shows large operating transfers starting 2018: - 6/27/2018: $57,030.00 - 2/26/2019: $25,409.75 - 2/22/2019: $22,554.75 - 4/11/2019: $38,114.61 and $36,474.61 - 12/8/2021: $68,405.00

None of these have invoice references.

Soluno Era Continuation (Post-July 2023)

The KFU data in Soluno shows the identical pattern continued: - 5/24/2023: $615,110.00 -- "Transfer to Operating" (no inv ref) - 7/31/2023: $154,800.00 -- "Transfer to Operating" (no inv ref) - 9/15/2023: $513,760.00 + $172,672.00 -- same day, no refs - 12/27/2023: $420,488.00 + $347,520.00 -- same day, no refs - Multiple 2024 transfers exceeding $100,000 each

67 of 71 KFU operating transfers in the Soluno era ($6,609,898.14 of the total) lack invoice references.


4. CRITICAL FINDING: THE "SYSTEM MIGRATION" DEFENSE IS DESTROYED

The Defense Theory

Goldberg could argue that discrepancies between trust receipts and revenue allocation are artifacts of the PCLaw-to-Soluno system migration (which occurred in mid-2023).

Why It Fails

1. The lump-sum pattern predates migration by years. The 2022 PCLaw ledger proves identical unreferenced operating transfers going back to at least 2018. This is not a migration artifact -- it is a deliberate practice spanning both systems.

2. Missing trust balances cannot be blamed on migration. $76,000+ in client trust balances that existed in February 2022 simply disappeared -- not during migration, but in the period BETWEEN February 2022 and the Soluno start date. These clients (KSU: $33,556, UAEU: $36,910, Sabah: $34,671, Kuwait Univ: $3,861) had their trust funds drawn to zero before Soluno was even implemented.

3. Goldberg personally authorized transfers by verbal instruction. The "JBGverbal" entries prove Goldberg directed trust account transfers without written documentation. This is not a system issue -- it is a human authorization pattern where Goldberg controlled movement of Litman's client funds.

4. The KFU ledger itself proves continuity. The KFU 36372 ledger runs continuously from September 2020 through November 2024. The same entry_number sequence, the same "Transfer to Operating" format, the same lump-sum pattern exists before and after the Soluno migration. The system changed; the pattern did not.

5. The volume is staggering. - KFU alone: $10.7M in trust receipts, with $6.6M in unreferenced operating transfers - KSU: $2.94M in receipts, nearly all swept to operating - UAEU: $1.22M in receipts, operating transfers in the $20K-$68K range without invoice refs - Sabah: $776K in receipts, operating transfers in the $27K-$33K range without invoice refs - Firm-wide: 1,699 "Transfer to Operating" entries in the 2022 PCLaw ledger alone


5. THE $16.2M ACCOUNTING GAP IN CONTEXT

The previously identified $16.2M gap ($32.7M trust vs. $16.5M workup) is now corroborated by pre-migration data. The 2022 PCLaw ledger shows: - Total firm trust balance: $288,445.55 (Feb 2022) - But the throughput was massive -- KFU alone moved $286,673 in total receipts by Feb 2022 - KSU moved $3.1M through trust by Feb 2022 - The operating transfer mechanism was the same: money in from client wire, swept to operating within days, no invoice trail on the large transfers

The pattern is: client sends wire -> money goes to general trust matter -> immediately transferred to operating in lump sum -> no allocation to specific invoices or dockets in the operating transfer itself.


6. EVIDENTIARY VALUE

For Deposition (due 06/02/2026)

  1. Confront Goldberg with "JBGverbal" entries: "You authorized trust account transfers by verbal instruction with no written documentation?"
  2. The $217,710 transfer (9/9/2022): "KFU wired $265,715. Three days later, $217,710 was transferred to operating. What invoices were paid?"
  3. Disappearing balances: "KSU had $33,556 in trust in February 2022. Where did it go?"
  4. Pattern continuity: "You claim discrepancies are from system migration. But this same pattern -- lump transfers with no invoice references -- existed in PCLaw since at least 2018. Can you explain that?"

For MSJ

For Damages


SOURCE FILES