Litman Intelligence — Settlement Conference Exhibit

Litman v. Goldberg — Damages Valuation Stack

Tiered Analysis as of April 7, 2026 · Index No. 524343/2025 · NY Sup. Ct., Kings County

Seven-Tier Valuation

$10M

$20M

$30M

$40M

$50M

$60M

$70M

$80M

1HARD FLOOR

$2.27M

$1.98M KFU 20% share authenticated against Defendant's own ledger + $49K May–Jun 2025 + $246K Q4 2025. Mathematically locked.

2DOCUMENTED SHORTFALL

$5.85M – $7.7M

$7.7M

Trust-account variance across produced ledgers; gap between $32.7M trust flow and $16.5M workup; KFU/KSU revenue zeroed out.

3DISCOVERY YIELD

+$1.0M – $2.5M

$10.2M cumulative

Projected from Soluno export, bank subpoenas, and concealed Aug–Sep 2025 monthly reports (240-day suppression pattern).

4§ 51 PER-PUBLICATION

$5M – $30M

$30M

905 patents × Line 74 + 17,000+ outgoing USPTO documents + 205,597 client emails. Each a separate § 51 commercial use.

5WILLFULNESS / PUNITIVE

1.5× – 5× multiplier

5× compensatory ceiling

16 POAs personally signed post-arbitration; active concealment of 11 of 33 monthly reports; spoliation of email accounts July 18, 2025.

6REPUTATION DAMAGE

1.0× – 2.0× multiplier

2× compensatory

Bennington, Albannai, Dvorkin — three clients on record drawn "solely because of Richard Litman." Personal-goodwill loss is provable.

7MSJ POINT III FULL DEMAND

$6.1M – $77.9M

$6.1M ─────────────────── Composite range ─────────────────── $77.9M

Composite range from briefed MSJ Point III. Settlement targets overlaid: white = floor/target, gold = $22M recommended demand.

Settlement floor / target ($9M – $14M) Recommended demand ($22M)

Position	Amount	Notes
Walk-Away	$9,000,000	Below this, trial yields a higher expected value than settlement.
Floor	$9,000,000	Hard Floor + Documented Shortfall midpoint; no concession on willfulness.
Target	$12,000,000 – $14,000,000	Compensatory + modest punitive; clears all known accounting gaps.
Recommended Opening Demand	$22,000,000	Anchored to Tier 4 midpoint × willfulness factor; leaves room to negotiate to Target.
Trial Value (Expected)	$11,000,000 – $45,000,000	Probability-weighted across MSJ Point III range with punitive overlay.

$1.98M KFU 20% share authenticated to within 1.6% against Defendant's own ledger — the floor is not estimated, it is reconciled.

Active concealment of 11 of 33 monthly reports proven, not inferred — the suppression pattern is documentary.

9 of 12 major institutional clients appear in double-overlay (alias renaming + client renumbering) — systemic, not incidental.

240-day concealment of the July 2025 report; the same delay would put the August 2025 report already 209 days overdue as of today.