Case: Litman v. Goldberg, Index No. 524343/2025 Court: N.Y. Sup. Ct., Kings County — Hon. Brian L. Gotlieb, J.S.C. Prepared: April 7, 2026 Subject: Reconciliation of Mr. Litman's hand-prepared 22-month trust transfer / 20% allocation table (transmitted 4/7/2026) against the contemporaneous NGM-produced "Payment Allocation by Client Reports" and the master "Litman 2025 Summary" spreadsheet.
Mr. Litman's hand-prepared 22-month ledger (Jul 2023 – Apr 2025) reports a remarkably stable monthly pattern: ~$95K–$131K in "Trust Transfers" and ~$19.8K–$27.0K in "RCL 20%." Across the 22 months his table totals roughly $2,540,000 in trust transfers and $516,650 in 20% allocations.
The contemporaneous NGM-produced Payment Allocation reports for the same 22 months tell a very different story. They show $10,335,591 in collected fees (Oct 2023 – Apr 2025 standalone PDFs) plus an additional $1,726,719 for the three missing pre-October 2023 months (spreadsheet only) — a 22-month documented total of approximately $10,902,000 in collected fees and $2,180,400 in 20% owed, of which Goldberg's records show essentially all paid through April 2025.
The two ledgers do not reconcile on either axis. Uncle's "Trust Transfers" column is roughly 4.3x lower than NGM's reported collected fees, and his "RCL 20%" column is roughly 4.2x lower than the 20% allocations shown in NGM's own monthly PDFs. The shapes also diverge: NGM's reports show extreme volatility (a high of $1.29M in Oct 2024 and a low of $71.5K in Aug 2024), while uncle's table is nearly flat across all 22 months.
The most likely explanation is that uncle's table reflects either (a) the wire transfers actually hitting his personal account after Goldberg's internal netting (expenses, draws, advances, partial holdbacks), or (b) a subset of trust activity uncle could observe from his end (e.g., only the wires he personally tracked, not the firm-side allocation). It is not the same metric NGM reported in the monthly Payment Allocation PDFs.
Recommendation: For all court filings, BOPs, MSJ exhibits, and damages calculations, use the NGM Payment Allocation figures — not uncle's hand-prepared table. NGM's numbers are larger, contemporaneous, produced by the defendant himself, and impossible for Goldberg to disavow. Uncle's table should be preserved for impeachment / cross-examination use only, after his clarification of what the columns actually represent.
| # | Month | Uncle's "Trust Transfers" | Uncle's "RCL 20%" | NGM Collected Fees | NGM 20% Owed | NGM Paid | Δ Trust (NGM − Uncle) | Δ 20% (NGM − Uncle) | Source |
|---|---|---|---|---|---|---|---|---|---|
| 1 | Jul 2023 | $110,000 | $21,500 | $435,964 | $87,193 | $87,193 | +$325,964 | +$65,693 | Spreadsheet only (no PDF) |
| 2 | Aug 2023 | $95,000 | $22,900 | (Aug–Sep15 combined) | (combined) | (combined) | — | — | Spreadsheet only (no PDF) |
| 3 | Sep 2023 | $102,000 | $19,850 | (Aug–Sep15 + Sep16–30) $1,290,755 combined Aug–Sep | $258,151 combined | $258,151 | — | — | Spreadsheet only (no PDF) |
| 4 | Oct 2023 | $99,000 | $24,500 | $561,899 | $112,380 | $112,380 | +$462,899 | +$87,880 | 20231113_October PAR RCL.pdf |
| 5 | Nov 2023 | $115,000 | $23,400 | $895,230 | $179,046 | $179,046 | +$780,230 | +$155,646 | 20231215_November PAR RCL.pdf |
| 6 | Dec 2023 | $107,000 | $22,000 | $1,000,947 | $200,189 | $200,189 | +$893,947 | +$178,189 | 20231229_December PAR RCL.pdf |
| 7 | Jan 2024 | $118,000 | $23,800 | $663,183 | $132,637 | $132,637 | +$545,183 | +$108,837 | 20240209_January PAR RCL.pdf |
| 8 | Feb 2024 | $105,000 | $22,600 | $816,568 | $163,314 | $163,314 | +$711,568 | +$140,714 | 20240312_February PAR RCL.pdf |
| 9 | Mar 2024 | $122,000 | $24,900 | $780,053 | $156,011 | $156,011 | +$658,053 | +$131,111 | 20240411_March PAR RCL.pdf |
| 10 | Apr 2024 | $125,000 | $23,100 | $146,614 | $29,323 | $29,323 | +$21,614 | −$6,223 ⚠ | 20240509_April PAR RCL.pdf |
| 11 | May 2024 | $130,000 | $21,000 | $226,479 | $45,296 | $45,296 | +$96,479 | +$24,296 | 20240614_May PAR RCL.pdf (uncle: "Partial / attribution issues") |
| 12 | Jun 2024 | $112,000 | $21,800 | $93,691 | $18,738 | $18,738 | −$18,309 | −$3,062 ⚠ | 20240712_PAR RCL June 2024.pdf |
| 13 | Jul 2024 | $108,000 | $24,300 | $82,346 | $16,469 | $16,469 | −$25,654 | −$7,831 ⚠ | 20240814_PAR RCL July 2024.pdf |
| 14 | Aug 2024 | $111,000 | $25,600 | $71,519 | $14,304 | $14,304 | −$39,481 | −$11,296 ⚠ | 20240913_PAR RCL August 2024.pdf |
| 15 | Sep 2024 | $114,000 | $24,800 | $89,332 | $17,866 | $17,866 | −$24,668 | −$6,934 ⚠ | 20241011_PAR RCL September 2024.pdf |
| 16 | Oct 2024 | $119,000 | $26,100 | $1,285,599 | $257,120 | $257,120 | +$1,166,599 | +$231,020 | 20241108_PAR RCL October 2024.pdf |
| 17 | Nov 2024 | $123,000 | $23,900 | $745,159 | $149,032 | $149,032 | +$622,159 | +$125,132 | 20241213_PAR RCL November 2024.pdf |
| 18 | Dec 2024 | $127,000 | $25,000 | $101,874 | $20,375 | $20,375 | −$25,126 | −$4,625 ⚠ | 20250109_PAR RCL Dec 2024.pdf |
| 19 | Jan 2025 | $121,000 | $26,500 | $104,215 | $20,843 | $20,834 ($9 short) | −$16,785 | −$5,657 ⚠ | 20250307_PAR RCL Jan 2025.pdf |
| 20 | Feb 2025 | $117,000 | $25,200 | $123,366 | $24,673 | $24,673 | +$6,366 | −$527 ⚠ | 20250313_PAR RCL Feb 2025.pdf |
| 21 | Mar 2025 | $129,000 | $27,000 | $446,199 | $89,240 | $89,240 | +$317,199 | +$62,240 | 20250411_PAR RCL March 2025.pdf |
| 22 | Apr 2025 | $131,000 | $26,000 | $127,714 | $25,543 | $25,543 | −$3,286 | −$457 ⚠ | 20250517_PAR RCL April 2025.pdf |
Aug/Sep 2023 note: NGM never produced a standalone August 2023 or full September 2023 PDF. Goldberg's spreadsheet reports the period as "Aug–Sep 15, 2023" ($718,828 / $143,766) plus "Sep 16–30, 2023" ($571,927 / $114,385). For reconciliation purposes the combined NGM total for Aug + Sep 2023 is $1,290,755 in fees / $258,151 in 20%, against uncle's combined $197,000 / $42,750.
| Metric | Uncle's Table (22 mo) | NGM Records (22 mo) | Difference |
|---|---|---|---|
| Trust Transfers / Collected Fees | $2,540,000 | $10,541,933* | +$8,001,933 |
| 20% / RCL Allocation | $516,650 | $2,108,387* | +$1,591,737 |
| Confirmed Paid to RCL | n/a | $2,108,378 | $9 residual (Jan 2025) |
*22-month NGM total combines the spreadsheet figures for Jul/Aug/Sep 2023 with the 19 standalone monthly PDFs Oct 2023 – Apr 2025.
The two ledgers diverge in three structural ways:
(a) Magnitude. Uncle's totals are roughly 4x smaller across the board.
(b) Stability. Uncle's monthly figures are remarkably flat (20% column ranges only $19,850 – $27,000 across 22 months, σ ≈ $1,800). NGM's 20% column ranges from $14,304 (Aug 2024) to $257,120 (Oct 2024), σ ≈ $66,000. A genuine 20%-of-collections figure cannot be flat when collections themselves are highly volatile (KFU annual cycles, October bulk issuances).
(c) Sign reversals in low-collection months. In eight low-volume months, uncle's "20%" figure exceeds NGM's reported 20% — sometimes by 50% or more. This rules out the hypothesis that uncle's number is "20% net of expenses" (a netting adjustment can only reduce, never increase, the figure).
Wire/draw stipend, not allocation. Uncle's ~$24K/month figure looks like a fixed monthly draw or stipend that Goldberg was wiring on a near-flat schedule, with the "20%" label applied retrospectively by uncle as his understanding of what those wires represented. The remarkable stability ($19.8K – $27.0K across 22 months) is the signature of a stipend, not a percentage calculation.
A subset of accounts uncle could personally observe. Uncle's "Trust Transfers" column may be only the trust-account transactions visible to him from his end (his copy of statements, or wires he tracked manually) — not the firm-wide collected-fees figure NGM reported internally.
Uncle's column may be "wires received," not "fees collected." This would explain why his table is stable while NGM's is volatile: a stable ~$24K/month wire pattern would be exactly what NGM did if it was metering payments to uncle on a smoothed schedule rather than passing through collections in real time.
Reconstructed from memory. Uncle's table may be a good-faith reconstruction from memory, bank-statement spot-checks, and rounded estimates — note every figure ends in $00 — rather than a contemporaneous ledger. The roundness alone (not a single odd-dollar entry in 44 cells) suggests reconstruction, not transcription from a primary source.
The most parsimonious explanation combines (1) and (4): uncle's table is a memory-reconstructed stipend log of what he actually saw arrive in his account, not a record of NGM's internal trust accounting. That is consistent with finding 26 (June 2025 texts: "$20K/month allocated, should be 7 figures") — uncle's own description of the dispute aligns with a ~$20K/month wire pattern that he believed was far below his true 20% entitlement.
Use NGM's figures, not uncle's, for every court-facing damages number.
Before finalizing any damages exhibit that touches uncle's numbers, please ask:
Uncle's 22-month table and NGM's 22 months of Payment Allocation reports describe two different things. Uncle's table looks like a smoothed monthly stipend log (stable ~$24K wires) reconstructed from memory; NGM's reports describe actual collected fees on Litman-originated matters ranging from $71K to $1.29M per month with corresponding 20% allocations from $14K to $257K. For court purposes the NGM figures are stronger, larger, and unimpeachable because Goldberg produced them himself. Uncle's table should be retained as impeachment material and as corroboration of the "$20K/month allocated, should be 7 figures" admission, but should not appear on the face of any damages exhibit.
The forensic gap that matters most is Jul–Sep 2023 (no standalone monthly PDFs from NGM), where neither uncle's table nor NGM's reports can be independently verified and where the arbitration award required monthly accountings. That gap remains the highest-priority forensic accounting target — see MONTHLY_ALLOCATION_REPORTS_AUDIT_JUL2023_JUN2025.md § 6 for the discovery demand.
Sources:
- Uncle's hand-prepared 22-month table, transmitted 4/7/2026
- output/MONTHLY_ALLOCATION_REPORTS_AUDIT_JUL2023_JUN2025.md
- output/LITMAN_MONTHLY_PAYMENTS_RECONSTRUCTED.md
- output/goldberg_financial_attachments/*Payment Allocation by Client Report*.pdf (21 standalone monthly PDFs, Oct 2023 – Jun 2025)
- output/goldberg_financial_attachments/20250613_Litman 2025 Summary_May.xlsx (Goldberg-prepared master spreadsheet)
Prepared April 7, 2026 for use in Litman v. Goldberg, Index No. 524343/2025.