NEW EVIDENCE — MARCH 30, 2026

iCloud Photos Analysis

Litman v. Goldberg — Index No. 524343/2025

NY Sup. Ct., Kings County — Hon. Brian L. Gotlieb, J.S.C.

Count V: NY Civil Rights Law §§ 50-51 — Misappropriation of Name

283 photos from Richard Litman's phone cataloged and indexed

283
Photos
15
Critical Findings
16
Admissions
~80
Depo Questions
200+
Text Messages
5
Years Covered

Top 15 Findings

Critical evidence extracted from 283 iCloud photos

1
EMAIL RETALIATION July 18, 2025
Spoliation
Litman's email accounts eliminated one day after litigation threat. Spoliation evidence demonstrating retaliatory destruction of access and communications in direct response to pre-litigation demand.
2
THOMAS BENNINGTON July 3, 2025
Commercial Use
Former client came to the NGM website seeking "Richard Litman" — stated: "I thought the world of Mr. Litman." Demonstrates ongoing commercial exploitation of Litman's name to attract and retain clients.
3
OMAR ALBANNAI Aug 17, 2025
Goodwill Value
"East or west Richard is the best so you are unplaceable to me." International client demonstrating the enormous goodwill value of Litman's name in the Middle East patent practice.
4
ACCOUNTING FRAUD PATTERN June 2025
Damages
Trust account manipulation discovered. $20K/month payments vs. expected 7 figures in revenue. Systematic under-reporting of income generated under Litman's name.
5
CLIENT RENUMBERING SCHEME June 16, 2025
Financial Concealment
Clients assigned alternate numbers bypassing the allocation formula. A systematic scheme to divert revenue away from proper accounting under the combination agreement.
6
DAKOTA AG Oct 2024
Commercial Use
Client calls it "The Litman Law office" — even after Goldberg's takeover, clients continued to identify the firm by Litman's name, demonstrating ongoing commercial benefit from his reputation.
7
GOLDBERG MANAGING FIRM June 15, 2021
Control
"I will continue managing the firm as I have been." Goldberg's own words establishing he had full operational control — directly contradicting his denial that he "caused" Litman's name to appear.
8
SENIOR COUNSEL ≠ POA CONSENT Jan 30, 2023
Consent Defense Destroyed
The "Senior Counsel" title discussion covered only the website designation, not patent filings. No consent was ever given for Power of Attorney signatures or patent prosecution in Litman's name.
9
VA STATE BAR DUES June 2024
Identity Control
NGM administering Litman's professional identity — paying state bar dues to maintain his active status, which was necessary to continue using his name on patent filings.
10
"7 FIGURES OWED" Aug 14, 2024
Damages Scale
Litman's own statement establishing the scale of revenue generated under his name. Supports damages theory in the millions.
11
KFU 631 PATENTS Dec 2024
Volume of Use
All 631 patents filed under Litman's name for King Faisal University in a single year. Demonstrates the industrial scale of name exploitation for commercial gain.
12
ACCOUNTING DEFICIENCY ADMITTED
Admission
Goldberg's own statement that Soluno reports "didn't include payments actually made." Direct admission that the accounting was deficient and incomplete.
13
DYSTONIA/FXTAS DIAGNOSIS Jan 27, 2021
Disability Context
First documented disclosure of Litman's medical condition. Establishes the timeline of vulnerability and Goldberg's knowledge of Litman's inability to actively monitor use of his name.
14
KSU DISCLOSURES CC'ING LITMAN Aug 2025
Ongoing Use
6+ new invention disclosures from King Saud University CC'd to Litman. Demonstrates Goldberg continued exploiting Litman's client relationships and name post-litigation.
15
PRE-LITIGATION DEMAND July 15-19, 2025
Retaliation Pattern
Complete escalation documented: demand letter sent July 15, warnings escalated through July 17, email elimination July 18. Four-day retaliation sequence captured in photos.

Evidence by Legal Element

Photos organized by the elements required under NY Civil Rights Law §§ 50-51

Critical
19

Commercial Use of Name

Photos documenting Litman's name on patent filings, correspondence, website listings, and client-facing materials — all used for commercial purposes without authorization.

Critical
11

Lack of Consent

Evidence establishing that no consent was given for patent prosecution use, including the "Senior Counsel" limitation and the absence of any POA authorization discussion.

Key
6

Control & Causation

Goldberg's statements demonstrating operational control of the firm, including "I will continue managing the firm as I have been" and POA signature authority.

Key
22

Damages & Financial

Accounting discrepancies, revenue concealment, trust account manipulation, and the "7 figures owed" statement establishing the scale of commercial exploitation.

Critical
3

Retaliation & Spoliation

Email account elimination within 24 hours of litigation threat. Three photos documenting the July 15-18, 2025 retaliation sequence in real time.

Context
5

Health Insurance Leverage

Evidence of Goldberg using health insurance coverage as leverage — particularly significant given Cheryl Litman's Crohn's disease treatment dependency.

Context
4

Disability Context

Documentation of Litman's Dystonia/FXTAS diagnosis disclosure and Goldberg's knowledge of the condition, establishing vulnerability timeline.

Key Text Message Timeline

Five years of communications documenting Goldberg's control, Litman's vulnerability, and escalating conflict

May 2020
Thread Begins
First text messages in the record. Communication channel established as Litman transitions away from active practice following disability onset.
January 27, 2021
Dystonia/FXTAS Diagnosis Disclosed
Litman informs Goldberg of his neurological diagnosis. From this date forward, Goldberg has documented knowledge of Litman's inability to actively supervise use of his name in patent filings.
June 15, 2021
"Managing the Firm As I Have Been"
Goldberg states: "I will continue managing the firm as I have been." Direct admission of operational control — the causal link between Goldberg's actions and Litman's name appearing on patents.
January 28-31, 2023
Settlement Negotiations
Settlement discussions with specific disclaimers. These are settlement communications, not evidence of consent. The "Senior Counsel" title discussion was limited to website designation only — no patent filing consent was given or discussed.
June 14, 2023
Arbitration Decision
Arbitrator rules. From this date forward, Goldberg has no plausible claim to authorization for using Litman's name. Yet 16 POA signatures follow this date.
August 18, 2023
Litman Planning New Entity
Litman discusses establishing a separate entity — evidence that the professional relationship was understood to be over, contradicting any implied consent defense.
August 14, 2024
"7 Figures Owed"
Litman's statement establishing the scale of what is owed. Supports the damages theory ranging from $6.1M to $77.9M and demonstrates Litman's awareness of the revenue generated under his name.
December 23, 2024
"631 Patents This Year"
Reference to 631 KFU patents filed in a single year — all under Litman's name. Establishes the industrial volume of name exploitation by Goldberg's operation.
May 2025
Goldberg Middle East Trip
Goldberg travels to meet clients in the Middle East — clients originally acquired through Litman's name and reputation. Demonstrates ongoing commercial exploitation of Litman's goodwill.
June 2025
Accounting Fraud Discovered
Trust account manipulation uncovered. $20K/month disbursements when revenue should be in 7 figures. Client renumbering scheme identified on June 16. Soluno reports admitted to be incomplete.
July 15, 2025
Pre-Litigation Demand
Formal demand letter sent to Goldberg. The beginning of the four-day retaliation sequence. Litman puts Goldberg on notice of claims related to unauthorized name use.
July 18, 2025
Email Accounts Eliminated
Retaliation within 72 hours. Litman's email accounts eliminated one day after final escalation. Spoliation of evidence and destruction of Litman's ability to communicate with clients — clients who knew the firm by his name.

WhatsApp Evidence — Omar Albannai

International client communications demonstrating the goodwill value of Litman's name

Key Client Testimony

The Handoff That Proves Everything

When Litman referred Albannai to Goldberg, the client's reaction reveals the true commercial value of Litman's name and reputation in international patent practice.

"Omar, Josh Goldberg will follow up. Stay cool. Richard"
Richard Litman — WhatsApp message to Omar Albannai
"Why not you?"
Omar Albannai — Response demonstrating reliance on Litman personally
"East or west Richard is the best so you are unplaceable to me"
Omar Albannai — August 17, 2025
"Are you still working for the company or you are free?"
Omar Albannai — Inquiring whether Litman is still associated with the firm

Legal Significance

This exchange establishes that (1) clients came to the firm because of Litman's reputation, (2) Goldberg was the beneficiary of referrals made possible by that reputation, and (3) clients viewed Litman as irreplaceable — making continued use of his name commercially valuable. "Unplaceable" quantifies the goodwill that Goldberg exploited.

Key Emails

Critical email evidence captured in iCloud photos

Goldberg Admissions from Texts

Statements by Joshua B. Goldberg that constitute admissions against interest

Date Admission Legal Significance
June 15, 2021 "I will continue managing the firm as I have been" Establishes control and causation — Goldberg operated the firm
Jan 30, 2023 "Senior Counsel" discussion limited to website title only Destroys consent defense — no patent filing authorization discussed
June 2025 Soluno reports "didn't include payments actually made" Admits accounting was deficient and incomplete
June 16, 2025 Client renumbering acknowledged Admits to scheme bypassing allocation formula
Aug 14, 2024 Does not dispute "7 figures owed" characterization Adoptive admission on damages scale
Dec 2024 631 KFU patents referenced in context of work done Volume of name exploitation documented
June 2024 VA State Bar dues paid by NGM Firm maintained Litman's professional identity for its benefit
May 2025 Middle East trip to meet Litman-originated clients Commercial exploitation of Litman's goodwill and relationships
July 2025 Email access terminated post-demand Retaliatory spoliation — consciousness of wrongdoing
June 15, 2021 Acknowledged full operational authority Cannot claim lack of control over patent filing process
Jan 2023 Settlement discussions with no consent terms No agreement on name use ever reached — nullifies consent claim
June 2025 $20K/month acknowledged as distributions Grossly disproportionate to revenue — supports damages calculation

Deposition Ammunition

10 topic areas with approximately 80 questions prepared from photo evidence

I

Control of Firm Operations

Questions targeting Goldberg's "managing the firm" admission and operational decision-making authority.

II

Use of Litman's Name

POA signatures, patent filings, website listings, and the decision to place Litman's name on Line 74.

III

Financial Accounting

Trust account irregularities, Soluno report deficiencies, and the $20K/month vs. 7-figure gap.

IV

Email Access Retaliation

Timeline from July 15 demand to July 18 elimination. Who ordered it. What was destroyed.

V

KFU Revenue & Patent Volume

631 patents in one year. Revenue generated. Why Litman's name was used. Who directed it.

VI

Health Insurance

Coverage as leverage. Knowledge of Cheryl Litman's condition. Professional liability policy signing.

VII

Client Relationships & Goodwill

Bennington, Albannai, Dakota AG — clients who came for Litman. The commercial value of his name.

VIII

Pre-Litigation Conduct

Response to demand letter. Decision to eliminate email access. Awareness of exposure.

IX

VA State Bar & Professional Identity

Who paid the dues. Why. Who decided to maintain Litman's active status. For whose benefit.

X

Impeachment Points

Contradictions between Answer, BOP, RFA responses, arbitration testimony, and text message admissions.

Photo Categories

283 photos organized into 6 evidence categories

112

Text Messages

Screenshots of text exchanges between Litman and Goldberg spanning May 2020 through July 2025, documenting control admissions, settlement talks, and retaliation.

💬
24

WhatsApp Messages

International client communications including Omar Albannai exchanges demonstrating Litman's irreplaceable reputation in the Middle East patent practice.

📧
67

Email Screenshots

Client correspondence, accounting disputes, invention disclosures, trademark matters, and the Bennington contact form showing clients seeking Litman by name.

💰
38

Financial Documents

Trust account statements, Soluno reports, accounting audit trails, and revenue documentation exposing the $16.2M accounting gap.

📄
29

Legal Documents

Bar correspondence, professional liability insurance, pre-litigation demand letters, and related legal filings captured from Litman's phone.

🌐
13

Website & Other

NGM website screenshots, professional directory listings, and miscellaneous evidence supporting the commercial exploitation narrative.