Only Count V (misappropriation of name under N.Y. Civil Rights Law §§ 50–51) survives. Goldberg's Answer (Doc #65, 01/20/2026) admits Litman's name appeared on patent front pages and the NGM website after 6/15/2020 (¶¶ 32, 72); he denies that he "caused" it. The documentary record — including POAs he personally signed, a Goldberg-authored email to King Faisal University referring to Litman as "our attorney" (Bates LITMAN209485), a Nunc Pro Tunc Assignment he himself recorded with USPTO, and the firm's internal trust-accounting records — contradicts the causation denial.
Findings and exhibits throughout this site are labeled as follows. The labels reflect documentary strength only; final characterization for counsel.
Party Admission Statement by Goldberg, NGM, or party-owned entity — self-authenticating or in sworn filing.
Strong Documentary NGM-produced record or public record that requires interpretation, not inference.
Pattern / Circumstantial Multi-event or volumetric evidence; weight depends on number and consistency.
Context Supporting but not dispositive.
Production Gap Absence of document that should exist — each gap is itself a finding.
Interactive Q&A that routes you to the specific exhibits, memos, and CSVs you need for a given task. No guessing — pick what you're doing and the wizard surfaces the relevant package.
Click to branch. You can restart at any time.
Each finding below has a direct documentary anchor. Evidence weight reflects the directness of the anchor, not its ultimate persuasive value in settlement or trial.
Bates LITMAN209485 (12/20/2023). Email sent by Joshua B. Goldberg directly to King Faisal University's Prof. Hany via the kfu@4patent.com alias. In the body, discussing substantive patent prosecution on Docket 33160.75U, Goldberg writes:
Third-person ("our attorney") designates an attorney other than the sender. Goldberg cannot mean himself. The email post-dates the 6/14/2023 arbitration Award. Supporting: Sept 2021 "new dean" thread (Bates LITMAN272429, 272449, 272454) where Goldberg personally introduced KFU's incoming Dean Abdulrahman Allily to Litman as co-attorney.
Additional per-client anchors identified: LITMAN250428 and LITMAN250429 (KSU, 8/26/2024, Goldberg "our attorney") and LITMAN267104 (UAEU, 6/11/2024, Goldberg "one of our attorneys").
On the eve of the SOL date, the managing member acknowledges (a) Litman was entitled to a percentage, (b) Trust Ledgers for KFU "are blank," and (c) he does not know why Litman is not being paid. Directly supports Count V fee-diversion framing.
Litman's own prior pleading (LITMAN004080, AAA Arbitration Demand) establishes that Goldberg, Meyer, and Gary Nath are members of Goldtree Realty LLC and A2Z IP LLC — the two LLCs that co-own the firm's office building at 112 S. West Street, Alexandria. The document is self-proving for the related-party landlord structure underlying the rent pipeline below.
Two documents produced by NGM via Connell Foley on the same day (4/17/2026) contradict each other on their face:
| Document | Figure | Field |
|---|---|---|
| Trust Listing for RCL Jan 2026 | $1,863,705.24 | BoA Escrow Acct_8777 — RCL-responsible matters |
| Trust Register Report Jan 2026 | $96,231.64 open / $80,935.64 close | Firm-wide t3 balance, same account, same month |
| Unaccounted-for excess | ≈ $1,782,769.60 | Asserted RCL share exceeds entire account |
No bank statement is needed to establish the contradiction. See Eagle Bank / BoA Baseline Exhibit.
NGM's own Trust Bank Journal Feb 2026 opens at $1,294,242.41 on Eagle Bank Trust_0495. The same NGM's Trust Bank Journal Jan 2026 closes at $1,307,568.41. Difference: −$13,326.00. No transaction in either monthly journal accounts for the delta. Resolved by Eagle Bank's actual statement on subpoena.
A documented accounting pattern on KFU umbrella docket 36372: incoming "KFU wire" followed within one business day by a "Transfer to Operating" sweep to Nath & Associates PLLC. Across September 2023 – February 2026: 20 major executions (inflow ≥ $100K) plus 121 smaller executions. Total swept: $11.09M.
| Date | IN | OUT (to Nath & Assoc.) | Residue | Signer |
|---|---|---|---|---|
| 9/14/2023 | $593,610 | $513,760 | $79,850 | VG / VG |
| 12/26/2023 | $583,262 | $420,488 | $162,774 | VG / VG |
| 2/13/2024 | $648,374 | $162,064 | $486,310 | VG / VG |
| 2/29/2024 | $597,130 | $337,320 | $259,810 | VG / VG |
| 3/19/2024 | $594,214 | $131,064 | $463,150 | VG / VG |
| 4/4/2024 | $659,772 | $141,730 | $518,042 | VG / VG |
| 4/9/2024 | $500,000 | $500,000 | $0 | VG / VG |
| 10/28/2024 | $499,352 | $497,252 | $2,100 | VG / VG |
| 11/20/2024 | $499,658 | $493,898 | $5,760 | VG / VG |
| 2/9/2026 | $291,173 | $224,113 | $67,060 | VG / VG |
The highlighted 4/9/2024 execution is a $500K in / $500K out / $0 residue / 1-business-day pass-through — trust account used as a conduit between firm operating accounts. That structure implicates Virginia RPC 1.15 on its face; weight for counsel to characterize.
Signer dollar-weight: Valencia Gray (VG) — 14.5% of transfer count, 72.3% of the dollars ($8.02M). Goldberg — 70.9% of count but 16.4% of dollars (signs the small ones). See full catalog.
The firm's operating address — 112 S. West Street, Alexandria, VA 22314 — is owned by Goldtree Realty LLC (Maryland) and A2Z IP LLC (Virginia). Members of both LLCs per LITMAN004080 ¶¶ 15–20: Goldberg, Meyer, and Gary Nath. NGM's own journal entries show $36,601/month booked as "Rent" under docket 37309 ($439,212/year). The monthly rent payments exit NGM via BoA Operating Account 003926172417, which has not been produced. Only May and June 2020 rent payments are visible in production (paid out of the client trust account while PPP loan proceeds were parked there — a distinct RPC 1.15 finding in its own right).
See Entity Structure Research, Entity Inventory, Rent Payment Trace.
NGM's AR Report as of April 2026 includes 35 invoices dated between 7/22/2025 and 10/15/2025 — after Litman's email accounts were eliminated — all identifying Richard Litman as Collecting Lawyer. Total billed: $176,070.00. 34 of 35 are to King Saud University. 100% outstanding. Each invoice is a freshly dated § 51 commercial use.
See Billed vs Paid Detail §2a and post-termination invoices CSV.
Across the 6/14/2023 – 7/18/2025 window, 17,203 NGM → KFU emails were sent. 14,033 carry at least one attachment that is or appears to be a USPTO document (Notice of Allowance, Office Action, Filing Receipt, Issue Notification, IDS, Amendment, Assignment, Application). 65.7% have a subject-line attachment descriptor ("Notice of Allowance for KFU — Docket 33101.13U"), such that Litman's name is visible on the face of the email without opening the attachment. 3,189 distinct dockets represented.
Binders available at three volumes: 100 (settlement scale), 1,000 (production scale), 14,033 (complete). See 1,000-exhibit binder. Parallel binders for KSU (6,051), UAEU (1,477), Kuwait U (1,637), SQU (268), QF (42) also built — 23,508 total cross-client uses.
These uses are weighted below issued-patent-face uses. Their value is in the systematic multi-week repetition pattern, which supports willfulness and amplified damages under § 51.
Goldberg claims Litman's email accounts were eliminated on 7/18/2025. Discovery production set ND0001 metadata shows 7,519 emails delivered to litman@4patent.com between 7/21/2025 and 12/31/2025; 334 to r.litman@4patent.com; 171 to rlitman@nathlaw.com. Total: 8,024+ emails. Contradicts the "eliminated" narrative. Also: the BHC Management USPTO notice on TM Serial 99034636 was sent to rlitman@nathlaw.com on 8/20/2025 — USPTO-generated, third-party sourced, outside NGM's control.
Six-month gap in monthly trust-accounting documents immediately following Litman's 6/26/2025 "seven figures owed" email and the 7/21/2025 lawsuit filing. Freedom Bank closure (7/28/2025) falls inside this gap. NGM has produced trust records continuously from April 2023 through June 2025 and again from January 2026 forward. The absence of the intervening six months is itself a finding that deserves a written representation or an explicit discovery demand.
NGM's operating account (where the $11M of trust sweeps lands and from which the $36,601/month rent exits) has not been produced. Bank statements on subpoena would confirm (a) monthly rent outflows to Goldtree/A2Z, (b) whether trust-sweep money funded related-party distributions, (c) partner-draw timing. The single subpoena with the highest marginal value.
The universe of dated uses of Richard C. Litman's name for advertising or purposes of trade, organized by category. Each category is a separate path to statutory damages.
905 U.S. patents issued since 6/15/2020 list "Richard C. Litman" as attorney on the front page.
905-patent dataset (CSV) · 12 post-7/21/2024 overlap patents · Exhibit A front pages (annotated)
Each email transmitted by NGM to a paying foreign-university client, attaching a USPTO document bearing Litman's name, is a commercial use of the name on the date sent — independent of when the underlying patent issues publicly (which the attachment is not, per 35 U.S.C. § 122). Post-arbitration window 6/14/2023 – 7/18/2025:
| Client | Candidates | % Subject-Labeled | Binder |
|---|---|---|---|
| King Faisal University | 14,033 | 65.7% | 100 · 1,000 · 14,033 |
| King Saud University | 6,051 | 62.8% | 100 · 500 |
| Kuwait University | 1,637 | 58.5% | 100 · 500 |
| United Arab Emirates University | 1,477 | 71.8% | 100 · 500 |
| Sultan Qaboos University | 268 | 47.4% | 100 · 268 |
| Qatar Foundation | 42 | 54.8% | 42 |
| Total | 23,508 | — | 12 binder PDFs |
NGM's own accounting system tags revenue on active matters to Litman's attorney code (418 / "RCL as originating attorney"):
nathlaw.com Litman professional bio pages (Wayback captures):
245 trademark dockets associated with Litman. Trademark LITMAN LAW OFFICES (U.S. Reg. 2,774,479) owned by Nath & Associates. 8+ TTAB proceedings involving Litman's name. See Trademark Name Use Memo and Trademark Exhibit.
On 4/17/2026 Connell Foley produced 36 files supporting a Q1 2026 $18,848 wire. The production became the most important single discovery event of 2026 because it contains NGM's contemporaneous admissions against interest.
Reconciliation Memo · Baseline Exhibit (PDF) · Original payment backup analysis
Across September 2023 – February 2026, NGM's own Trust Bank Journals document a repeating accounting template on KFU docket 36372: incoming "KFU wire" transaction followed within one business day by a "Transfer to Operating" sweep to Nath & Associates PLLC.
See Key Findings above for the 10-row executions table. Full catalog: TURN_AND_BURN_TEMPLATE_CATALOG.md. Side-by-side visual: Template Exhibit (PDF).
Per prior forensic analysis (Anomalous Transactions Catalog):
| Metric | Soluno / Workup | Actual Trust Ledger | Difference |
|---|---|---|---|
| Total client receipts | $16,506,604.92 | $32,708,669.08 | $16,202,064.16 |
| KFU revenue | $0.00 | $10,737,709.88 | $10,737,709.88 |
| KSU revenue | $0.00 | $3,720,000+ | $3,720,000+ |
| 20% due to Litman | $2,402,451.86 | $4,299,347.35 | $1,896,895.49 |
| Net balance owed (adjusted for $290K offset correction) | ($673.80) "fully paid" | $2,186,895.49 | $2,187,569.29 |
Goldberg's own text admission: the Soluno system "drew its data from account ledgers that didn't include payments actually made."
The $290,000 MetLife long-term-disability offset was previously included in "Paid to Litman" totals in eight derivative summary files. The arbitrator already ruled that deduction was improper. Correction applied 4/18/2026 with dagger-footnote restatements:
| File | Prior Paid | Cash-Only Paid | Effect |
|---|---|---|---|
| FINANCIAL_EXHIBIT_2020_2025 | $3,578,990.30 | $3,288,990.30 | −$290K |
| KFU_KSU_RECONCILIATION | $3,664,025.12 | $3,374,025.12 | −$290K |
| LITMAN_FIDELITY_PAYMENT_TIMELINE | $3,276,440.61 | $2,986,440.61 | −$290K |
| PATENT_REVENUE_LINKAGE (shortfall) | $504,728 | $794,728 | +$290K |
| AAA_PACKAGE_DEMAND_LETTERS (outstanding) | $2,599,640.05 | $2,889,640.05 | +$290K |
| LITMAN_FINANCIAL_ACCOUNTING (owed) | $2,990,643.20 | $3,280,643.20 | +$290K |
Corrected files use a dagger footnote citing the arbitrator's ruling. Net effect: every damages memo's shortfall is now $290K larger and consistent with the arbitration finding.
The two months of rent payments visible in production (May + June 2020) were paid out of the client trust account while $480,457 in PPP loan proceeds were parked there. Documented in NGM's own ledger.
This is a discrete finding: federal PPP loan proceeds → client trust account → rent to a related-party landlord. Virginia RPC 1.15 on its face; separate from SBA loan-forgiveness analysis, which counsel may choose to pursue.
"Nath, Goldberg & Meyer" is a USPTO-registered service mark (Serial 86149326) owned by Nath & Associates PLLC, a District of Columbia LLC formed 5/23/1993 (SAM.gov UEI T3K3MDBJLJB8, CAGE 1U0Q1). The firm does business as:
All three names appear stacked in the 5/27/2025 KSU letter (Bates ND0000218459): "Nath & Associates, PLLC, d.b.a. The Nath Law Group, d.b.a. Nath, Goldberg & Meyer." The 4/11/2024 bank wire confirms the stack. Every "Transfer to Operating — Nath & Associates" sweep is an internal two-account transfer within the same legal entity.
The firm's operating address 112 S. West Street, Alexandria, VA 22314 (Alexandria parcel 074.01-02-02, assessed $3,515,000) is owned by two related-party LLCs:
| Entity | State | Members | Notes |
|---|---|---|---|
| Goldtree Realty LLC | Maryland | Goldberg, Meyer, Gary Nath | Primary — per LITMAN004080 ¶¶ 15–20 (AAA Arbitration Demand) |
| A2Z IP LLC | Virginia | Goldberg, Meyer, Gary Nath | Co-owner — also USPTO TM Serial 86200282 (IP services) |
| Goldtree Realty P.B., LLC | Florida (Highland Beach) | Judith K. Nath (unverified) | TM assignee of GOLDTREE mark U.S. Reg. 2,774,479 |
Membership of Goldberg, Meyer, and Nath in Goldtree and A2Z is established by Litman's own prior pleading (LITMAN004080). The rent recipient is therefore a related-party landlord whose members are the three named partners of the firm.
NGM's own journal entries show $36,601.00/month booked as "Rent" under docket 37309 paid to "Nath & Associates PLLC/Nath" as the intra-firm booking. Real recipient is Goldtree / A2Z via the unproduced BoA Operating Account 003926172417.
The 66 months of invisible rent payments (≈$2.42M post-SOL) run through the unproduced BoA Operating Account. Zero firm-rent correspondence appears in the 276,899-row email corpus — all 229 "rent" hits are personal (daughter's NYC apartment, father's dental building, vehicle leases, CLE spam). The absence is itself evidentiary.
Entity Structure Research · Entity Inventory · Rent Payment Trace
The concatenation of the turn-and-burn template, the operating-account black box, and the related-party landlord supports a single narrative chain:
KFU trust → firm operating (BoA 2417) → Goldtree / A2Z LLC rent → Goldberg / Meyer / Nath K-1
Each monthly rent check is one-third of a partner distribution. Every dollar of rent is (a) a dollar that may have been swept from client trust without 20% allocation to Litman, (b) a dollar booked as an operating expense against a partner profit pool Litman was entitled to share in, (c) a dollar paid back to the partners personally via LLC vehicles.
This narrative requires confirming documents on subpoena — specifically BoA 2417 statements and Goldtree / A2Z K-1s. The documentary pieces are already in hand for each separate link; the end-to-end chain will be provable once those subpoenas land.
§ 51 provides for amplified damages where the use is knowing or willful. Below: the most direct documentary anchors of Goldberg's personal knowledge and continued designation of Litman as attorney.
12/20/2023. Goldberg to KFU Prof. Hany via kfu@4patent.com. Docket 33160.75U. Third-person designation. Post-arbitration. Native file: C2051472_ND0000207537.msg.
Goldberg personally introduced KFU's incoming Dean Abdulrahman Essa Allily (aallily@kfu.edu.sa) to Litman as co-attorney. "Abdul specifically asked to speak with me and Richard." "Richard and I both enjoyed our discussion last week. Like you, we look forward to working together!" Post-SOL (6/15/2020), post-arbitration.
8/26/2024. Goldberg to King Saud University. Same third-person designation on Docket 33007.94 Notice of Allowance and Docket 33056.63 Issue Fee. Post-SOL-safe (post-7/21/2024).
6/11/2024. Goldberg to United Arab Emirates University. Plural phrasing, weaker than "our attorney" but consistent pattern across clients.
Goldberg personally signed the PTO/AIA/82A transmittal in the same applications that issued with Litman on Line 74:
| Application | Issued Patent | Goldberg 82A Date | Line 74 |
|---|---|---|---|
| 18/242,465 | 12,043,608 B1 (7/23/2024) | 9/5/2023 — Reg. 44126 | Nath, Goldberg & Meyer; Richard C. Litman |
| 18/511,800 | 12,116,333 B1 (10/15/2024) | 11/16/2023 — Reg. 44126 | Nath, Goldberg & Meyer; Richard C. Litman |
Goldberg personally caused the recording of a Nunc Pro Tunc Assignment at the USPTO. His Answer ¶38 denies the paragraph but the recorded document bears his own initiation. Self-contradicting on the record.
7/18/2025 is the termination anchor. Goldberg eliminated Litman's email accounts that day — one day after Litman's 7/17/2025 litigation threat and three days before the 7/21/2025 federal/state filings. Post-termination uses are particularly strong for SOL and for willfulness.
NGM's AR Report as of April 2026 includes 35 invoices dated between 7/22/2025 and 10/15/2025 identifying Richard Litman as Collecting Lawyer. 34 of 35 are to King Saud University. 100% outstanding.
On the Feb 2026 and Mar 2026 NGM Trust Listings for RCL, 50 matters have last-trust-entry dates on or after 7/18/2025. Each is NGM's own record of treating Litman as Responsible Attorney on an active matter with post-termination activity.
Between 7/21/2025 and 12/31/2025, ND0001 metadata shows 7,519 emails to litman@4patent.com, 334 to r.litman@4patent.com, 171 to rlitman@nathlaw.com. The accounts were receiving mail throughout the period Goldberg claims they were eliminated. Latest recorded delivery: 12/31/2025.
USPTO-generated correspondence on trademark Serial 99034636 sent to rlitman@nathlaw.com on 8/20/2025. More than a month after the claimed 7/18/2025 email elimination. USPTO-originated, third-party-sourced, outside NGM's control.
Documented in two NGM monthly Trust Bank Journals produced 15 months apart: incoming "Wire KFU Retainer" transactions followed by same-/next-day sweeps to Nath & Associates PLLC operating, leaving residues within $174 of each other. Same signer (VG) on both. Both occur after Litman's termination (the 2/9/2026 event) or during a period when Litman's allocation was already being underpaid (the 11/20/2024 event).
Goldberg has asserted 10 affirmative defenses in his 1/20/2026 Answer. Each is mapped to counter-evidence below. Use the Evidence Wizard branch "Responding to affirmative defense" for the full per-defense package.
| Defense | Core Counter-Evidence |
|---|---|
| 1. Consent (Amendment) | Goldberg's own arb MSJ: agreement terminated 6/15/2020. Amendment § 3 licenses only email addresses, not name on patents. |
| 2. Statute of Limitations | Each § 51 use independently timed. Post-7/21/2024 uses are SOL-safe on any calculation. |
| 3. Waiver / Acquiescence | Disability period; 4/17/2025 and 5/26/2025 Litman requests for attorney-418 list; 6/26/2025 formal objection. |
| 4. Res Judicata (Arbitration) | Arbitration was contract forum; § 51 not litigated there. 14,033 KFU uses post-date the 6/14/2023 Award. |
| 5. Collateral Estoppel | Same as #4 — § 51 not an issue necessarily decided in arbitration. |
| 6. Disability = Death | NGM asked Litman to collect from KSU post-"termination" (KSU collection memo). $290K MetLife offset was improper per arbitrator — now corrected in derivative memos. |
| 7. No Commercial Use | $1.5M billed under Litman's name; $254K tagged to him in Q1 2026; website bio active through 9/5/2025. |
| 8. Settlement Discussions (Texts) | Texts were settlement talks about unpaid comp, not consent. Litman believed himself Senior Counsel until 6/14/2023 Award. |
| 9. Unclean Hands / Laches | Documentary record shows Litman objected at each reasonable opportunity; disability period tolls laches. |
| 10. Failure to State a Claim | Court already dismissed Counts I–IV but ruled Count V stated a claim (12/5/2025 ruling). |
The models below are analytical. Final settlement posture is for counsel. Each model anchors to documented use counts or documented dollar flows from NGM's own production. No figure below is a demand.
| Component | Documented | Source |
|---|---|---|
| Soluno gap (20% share shortfall) | $2.19M | Corrected for $290K MetLife offset — see fidelity timeline |
| AR billed under Litman's name (live) | $1.51M | AR Report April 2026 (496 invoices) |
| Outstanding under Litman's name | $1.44M | 94.9% of billed; 100% older-bucket |
| Post-termination invoices under Litman | $176K | 35 invoices, 100% outstanding |
| Q1 2026 NGM operating revenue retained | $75.4K | 80% of Q1 collected fees on RCL-originated work |
| Turn-and-burn pipeline (20 major executions) | $11.09M | Swept KFU trust → operating 2023–2026 |
| Invisible post-SOL rent pipeline | ≈ $2.42M | 66 unvisible months × $36,601 |
| BoA Escrow phantom balance (Jan 2026) | ~$1.78M | Trust Listing vs Trust Register contradiction |
§ 51 does not specify per-use statutory damages; it authorizes compensatory and exemplary damages. The use count matters for:
| Use Category | Count (post-arb) |
|---|---|
| Issued patents (front page, Line 74) | 905 |
| Post-7/21/2024 overlap patents | 12 |
| KFU post-arb emails with USPTO attachments | 14,033 |
| Other ME-client emails (KSU/UAEU/Kuwait U/SQU/QF) | 9,475 |
| AR invoices live under Litman | 496 |
| Trust-ledger entries still tagged RL as Responsible | 50 (post-term) |
Each row below is one way of thinking about value. Counsel will choose the framing that best fits the case posture at mediation or trial.
| Model | Basis | Illustrative Value |
|---|---|---|
| A. Unpaid comp only | Soluno gap (corrected) + post-termination AR ($176K) + forward collection on $1.44M | ~$2.5M – $3.7M |
| B. Fee diversion + unpaid comp | Model A + 20% share on $11M turn-and-burn pipeline = ~$2.2M | ~$4.7M – $5.9M |
| C. Full § 51 use count, per-use modest | 23,508 email uses × $500/use (low-end per-use) | ~$11.8M |
| D. Same, with willfulness multiplier | Model C × 3× statutory-amplification presumption | ~$35.3M |
Models C/D are mechanical — most § 51 cases do not scale linearly to this number because damages turn on proof of commercial impact, the presence of a "marketplace" for the use, and each jurisdiction's treatment of amplified damages. Counsel will discount accordingly. The model is useful for establishing the range boundaries and for framing settlement.
The documented pieces support a settlement discussion in the mid-seven to low-eight figure range if the case is resolved pre-trial on the strength of the turn-and-burn template + entity-structure + post-termination facts. Counsel will set the number. The case materials in this dashboard will support any number in that range.
Three data points inform the range:
Willfulness multipliers (if the court applies them) stack above any of these. Discovery yield — particularly BoA 2417 and the K-1s — will substantially affect whether the center or ceiling is the better anchor.
Discovery targets ranked by expected settlement impact per target, not by work volume.
The single most valuable subpoena. Confirms monthly rent to Goldtree/A2Z, traces whether trust-sweep money funds related-party distributions, identifies all operating outflows (payroll, draws, other related-party transfers). Covers 1/2020 to present.
Two specific windows: 11/18–11/20/2024 and 2/6–2/10/2026. Confirms or refutes whether the $500K (2024) and $291K (2026) "KFU wires" originate from Al Rajhi Bank / KFU Riyadh or from a US-domiciled NGM-affiliated account. Either answer is case-defining.
Operating agreements, cap tables, K-1 recipient lists, bank statements. Confirms the Goldberg/Meyer/Nath membership, quantifies the rent-distribution pipeline, and enables any related-party-transfer analysis.
All records for the trust account closed 7/28/2025. Account opening through final closure. Signature cards, statements, transfers in/out. The account Schaeffer excluded from her 6/26/2025 Kren report.
The internal documents where NGM itself compared Trust Listing to Trust Register. If produced and show variances, the worksheets are contemporaneous awareness of the $1.78M phantom. If they don't exist, the absence is itself an RPC 1.15 violation.
Fill the six-month production gap that straddles Litman's 6/26/2025 litigation threat, 7/21/2025 filing, and Freedom Bank's 7/28/2025 closure.
Goldtree Realty LLC and A2Z IP LLC, tax years 2020–2025. Identifies all persons receiving rent distributions (may include family members beyond the three named partners).
Question sets drawn from iCloud text threads and email admissions are indexed at GOLDBERG_DEPO_QUESTIONS_FROM_TEXTS.md. Core topics:
Full prep at SCHAEFFER_AND_GRAY_DEPOSITION_PREP.md. Question-set blocks: professional engagement, monthly reconciliation procedures, Freedom Bank, $1.78M phantom, turn-and-burn template, disability offset, client renumbering, RPC 1.15 awareness.
Flagged admission question: "Did you know before 7/28/2025 that NGM maintained an undisclosed third trust account at Freedom Bank containing client funds?" A yes answer establishes knowing spoliation by the CPA of record; a no answer contradicts her role as monthly reconciler and supports the theory that Freedom Bank was deliberately hidden.
Same memo. Gray signed 72.3% of the dollars in the KFU-to-Nath transfer pipeline and 89% (133 of 150) of Q1 2026 transfer entries. Question-set blocks: role / reporting chain, 150+ Q1 2026 transfers, turn-and-burn template, 2/9/2026 wire memo narration, $13,326 continuity gap, Jan→Feb responsible-attorney reassignment, client renumbering.
Two flagged admission questions:
Sent the 40,694 client emails central to the § 51 commercial-use theory. Question focus: process for attaching USPTO documents, whether she was aware Litman was designated as attorney on the attachments she transmitted post-7/18/2025, who instructed her on routing through kfu@4patent.com and peer aliases.