# FINANCIAL EXHIBIT: Litman Origination Fees 2020-2025

## Litman v. Goldberg, Index No. 524343/2025 (NY Sup. Ct., Kings County)

**Source:** "Litman Quarterly Compensation" spreadsheets produced by Defendant Joshua B. Goldberg through counsel Aaron Gould, Connell Foley LLP. All figures are from Goldberg's own accounting records maintained at Nath, Goldberg & Meyer (NGM).

**Litman's Compensation Rate:** 20% of Collected Fees on matters where Richard C. Litman ("RCL") is the originating attorney.

---

## 1. QUARTER-BY-QUARTER SUMMARY (Q1 2020 - Q4 2025)

### 2020 (Quarterly Reporting)

| Period | Total Funds Received | Collected Fees | 20% Due to RCL | Paid to RCL | Unpaid Balance | Payment Status |
|--------|--------------------:|---------------:|--------------:|------------:|---------------:|----------------|
| Q1 2020 (Jan-Mar) | $741,300.32 | $475,910.52 | $95,182.10 | $75,000.00 | $20,182.10 | Paid 06/04/2020 ($25,510.53 incl. prior) |
| Q2 2020 (Apr-Jun) | $645,462.27 | $458,250.06 | $91,650.01 | $75,000.00 | $16,650.01 | Paid 07/21/2020 ($23,554.92 incl. prior) |
| Q3 2020 (Jul-Sep) | $361,339.72 | $276,163.20 | $55,232.64 | $75,000.00 | ($19,767.36) | RCL overpaid (owes NGM) |
| Q4 2020 (Oct-Dec) | $577,848.61 | $443,199.38 | $88,639.88 | $30,000.00 | $58,639.88 | Net Due RCL: $41,904.71 |

**2020 Annual Totals:**
- Total Funds Received: **$2,325,950.92**
- Total Collected Fees: **$1,653,523.16**
- Total 20% Due to RCL: **$330,704.63**
- Total Paid to RCL: **$255,000.00**
- Net Year-End Balance Due RCL: **$41,904.71**

> **NOTE:** Pay reduction from $75,000/quarter to $30,000/quarter began in Q4 2020. Goldberg unilaterally reduced Litman's draws despite no change in fee volume.

---

### 2021 (Quarterly Reporting)

| Period | Total Funds Received | Collected Fees | 20% Due to RCL | Paid to RCL | Unpaid Balance |
|--------|--------------------:|---------------:|--------------:|------------:|---------------:|
| Q1 2021 (Jan-Mar) | $394,206.36 | $274,017.60 | $54,803.52 | $30,000.00 | $24,803.52 |
| Q2 2021 (Apr-Jun) | $529,916.26 | $371,750.22 | $74,350.04 | $30,000.00 | $44,350.04 |
| Q3 2021 (Jul-Sep) | $1,070,623.53 | $812,978.51 | $162,595.70 | $30,000.00 | $132,595.70 |
| Q4 2021 (Oct-Dec) | $573,087.43 | $363,238.77 | $72,647.75 | $30,000.00 | $42,647.75 |

**2021 Annual Totals:**
- Total Funds Received: **$2,567,833.58**
- Total Collected Fees: **$1,821,985.10**
- Total 20% Due to RCL: **$364,397.02**
- Total Paid to RCL: **$120,000.00**
- Cumulative Net Due RCL (end of 2021): **$286,301.73**

> **NOTE:** Despite $2.57M in total funds collected on Litman-originated matters, Goldberg paid Litman only $120,000 for the year -- roughly $10,000/month -- while Litman's 20% share was $364,397.

---

### 2022 (Quarterly Reporting)

| Period | Total Funds Received | Collected Fees | 20% Due to RCL | Paid to RCL | Unpaid Balance |
|--------|--------------------:|---------------:|--------------:|------------:|---------------:|
| Q1 2022 (Jan-Mar) | $379,203.56 | $269,169.00 | $53,833.80 | $30,000.00 | $23,833.80 |
| Q2 2022 (Apr-Jun) | $249,871.14 | $171,510.49 | $34,302.10 | $30,000.00 | $4,302.10 |
| Q3 2022 (Jul-Sep) | $848,702.01 | $628,916.69 | $125,783.34 | $30,000.00 | $95,783.34 |
| Q4 2022 (Oct-Dec) | $2,030,639.04 | $1,573,343.53 | $314,668.71 | $30,000.00 | $284,668.71 |

**2022 Annual Totals:**
- Total Funds Received: **$3,508,415.75**
- Total Collected Fees: **$2,642,939.71**
- Total 20% Due to RCL: **$528,587.94**
- Total Paid to RCL: **$120,000.00**
- Cumulative Net Due RCL (end of 2022): **$694,889.67**

> **LUMP-SUM PAYMENT:** At end of Q4 2022, Goldberg paid RCL the full accumulated balance of **$694,889.67**, zeroing out the account. This confirms Goldberg tracked and acknowledged the debt.

---

### 2023 (Monthly Reporting Post-Arbitration)

The arbitration decision was issued **June 14, 2023**. Goldberg switched from quarterly to monthly reporting afterward.

| Period | Total Funds Received | Collected Fees | 20% Due to RCL | Paid to RCL |
|--------|--------------------:|---------------:|--------------:|------------:|
| Q1 2023 (Jan-Mar) | $1,360,363.93 | $1,081,803.76 | $216,360.75 | $106,499.53 |
| Apr 2023 | $138,517.00 | $100,370.60 | $20,074.12 | $20,074.12 |
| May 2023 | $886,021.60 | $698,602.00 | $139,720.40 | $139,720.40 |
| Jun 2023 | $385,213.65 | $296,326.63 | $59,265.33 | $59,265.33 |
| *Arbitration Award (07/17/2023)* | -- | -- | $316,869.92 | $316,869.92 |
| Jul 2023 | $597,488.00 | $435,964.11 | $87,192.82 | $87,192.82 |
| Aug-Sep 15, 2023 (Updated) | $915,292.03 | $718,828.24 | $143,765.65 | $143,765.65 |
| Sep 16-30, 2023 | $713,970.00 | $571,927.00 | $114,385.40 | $114,385.40 |
| Oct 2023 | $790,830.00 | $561,899.10 | $112,379.82 | $112,379.82 |
| Nov 2023 | $1,131,522.34 | $895,230.34 | $179,046.07 | $179,046.07 |
| Dec 2023 (Updated) | $1,299,862.01 | $1,000,946.90 | $200,189.38 | $200,189.38 |

**2023 Annual Totals:**
- Total Funds Received: **$8,219,080.56**
- Total Collected Fees: **$6,361,898.68**
- Total 20% Due to RCL: **$1,272,379.74**
- Total Paid to RCL (incl. Arbitration Award): **$1,589,249.66** (includes $316,869.92 arbitration payment)
- Fees-only Paid: **$1,272,379.74**
- Net Due RCL (end of 2023): **$0.00**

> **KEY FACT:** 2023 was the highest-revenue year, with over $8.2M in total funds received on Litman-originated matters. After the arbitration award, Goldberg began paying Litman's 20% share in full monthly. The arbitration payment of $316,869.92 covered the pre-arbitration underpayment.

---

### 2024 (Monthly Reporting)

| Period | Total Funds Received | Collected Fees | 20% Due to RCL | Paid to RCL |
|--------|--------------------:|---------------:|--------------:|------------:|
| Jan 2024 | $850,113.48 | $663,183.38 | $132,636.68 | $132,636.68 |
| Feb 2024 | $1,120,457.27 | $816,567.84 | $163,313.57 | $163,313.57 |
| Mar 2024 | $1,125,037.00 | $780,053.00 | $156,010.60 | $156,010.60 |
| Apr 2024 | $247,338.74 | $146,613.99 | $29,322.80 | $29,322.80 |
| May 2024 | $310,490.00 | $226,479.37 | $45,295.87 | $45,295.87 |
| Jun 2024 | $219,531.67 | $93,691.00 | $18,738.20 | $18,738.20 |
| Jul 2024 | $107,158.00 | $82,345.55 | $16,469.11 | $16,469.11 |
| Aug 2024 | $100,226.00 | $71,519.41 | $14,303.88 | $14,303.88 |
| Sep 2024 | $114,980.00 | $89,332.00 | $17,866.40 | $17,866.40 |
| Oct 2024 | $1,594,603.48 | $1,285,598.78 | $257,119.76 | $257,119.76 |
| Nov 2024 | $1,070,957.03 | $745,159.00 | $149,031.80 | $149,031.80 |
| Dec 2024 | $141,844.86 | $101,873.54 | $20,374.71 | $20,374.71 |

**2024 Annual Totals:**
- Total Funds Received: **$6,002,737.53**
- Total Collected Fees: **$4,102,416.86**
- Total 20% Due to RCL: **$820,483.37**
- Total Paid to RCL: **$820,483.37**
- Net Due RCL (end of 2024): **$0.00**

> **KEY FACT:** Q1 2024 was exceptionally strong ($3.1M in funds received in Jan-Mar alone), then revenue dropped sharply mid-year before spiking again in Oct-Nov 2024. The revenue pattern tracks patent prosecution cycles for Middle Eastern university clients.

---

### 2025 (Monthly Reporting)

| Period | Total Funds Received | Collected Fees | 20% Due to RCL | Paid to RCL | Running Unpaid |
|--------|--------------------:|---------------:|--------------:|------------:|---------------:|
| Jan 2025 | $149,390.52 | $104,215.20 | $20,843.04 | $20,834.04 | $9.00 |
| Feb 2025 | $164,755.75 | $123,365.77 | $24,673.15 | $24,673.15 | $0.00 |
| Mar 2025 | $599,780.20 | $446,199.48 | $89,239.90 | $89,239.90 | $0.00 |
| Apr 2025 | $209,141.01 | $127,713.70 | $25,542.74 | $25,542.74 | $0.00 |
| May 2025 | $178,468.00 | $142,202.00 | $28,440.40 | *Not paid* | $28,440.40 |
| Jun 2025 | $139,774.50 | $104,682.44 | $20,936.49 | *Not paid* | $49,376.89 |
| *Auditor Adjustment* | -- | -- | ($673.80) | -- | -- |
| Jul 2025 | $66,335.23 | $31,958.55 | $6,391.71 | *Not paid* | $26,654.40 |
| Aug 2025 | $244,492.08 | $196,081.00 | $39,216.20 | *Not paid* | $65,870.60 |
| Sep 2025 | $398,478.70 | $350,385.47 | $70,077.09 | *Not paid* | $135,947.69 |
| **Partial payment Sep 2025** | -- | -- | -- | $135,947.69 | $0.00 |
| Oct 2025 | $888,414.00 | $628,331.50 | $125,666.30 | *Not paid* | $125,666.30 |
| Nov 2025 | $404,240.68 | $328,710.98 | $65,742.20 | *Not paid* | $191,408.50 |
| Dec 2025 | $354,541.00 | $276,098.00 | $55,219.60 | *Not paid* | $246,628.10 |

**2025 Annual Totals:**
- Total Funds Received: **$3,797,811.67**
- Total Collected Fees: **$2,859,944.09**
- Total 20% Due to RCL: **$571,988.82**
- Total Paid to RCL: **$296,237.52**
- **Amount Owed to RCL as of 12/31/2025: $246,628.10**

> **CRITICAL:** Payments to Litman stopped after April 2025. A partial catch-up payment was made covering May-September, but October through December 2025 remain entirely unpaid. This coincides with the filing of this lawsuit (Index No. 524343/2025). The $246,628.10 balance owed at year-end represents fees collected on Litman-originated matters under Litman's name -- the very name use that is the subject of this action.

---

## 2. GRAND TOTALS (2020-2025)

| Year | Total Funds Received | Collected Fees | 20% Due to RCL | Paid to RCL |
|------|--------------------:|---------------:|--------------:|------------:|
| 2020 | $2,325,950.92 | $1,653,523.16 | $330,704.63 | $255,000.00 † |
| 2021 | $2,567,833.58 | $1,821,985.10 | $364,397.02 | $120,000.00 † |
| 2022 | $3,508,415.75 | $2,642,939.71 | $528,587.94 | $814,889.67 |
| 2023 | $8,219,080.56 | $6,361,898.68 | $1,272,379.74 | $1,589,249.66 |
| 2024 | $6,002,737.53 | $4,102,416.86 | $820,483.37 | $820,483.37 |
| 2025 | $3,797,811.67 | $2,859,944.09 | $571,988.82 | $296,237.52 |
| **TOTAL** | **$26,421,830.01** | **$19,442,707.60** | **$3,888,541.52** | **$3,895,860.22** |

### Key Figures

- **Total Funds Received on Litman-Originated Matters (2020-2025):** $26,421,830.01
- **Total Collected Fees:** $19,442,707.60
- **Total 20% Owed to Litman:** $3,888,541.52
- **Total Paid to Litman (incl. Arbitration Award):** $3,895,860.22 (includes $316,869.92 arbitration award)
- **Total Paid to Litman (fees only):** $3,578,990.30 †
- **Adjusted Total Paid (cash-only, fees only):** $3,288,990.30 (subtracts $290,000 MetLife disability paper-offset)
- **Outstanding Balance as of 12/31/2025:** $246,628.10
- **Adjusted Outstanding Balance (cash-only):** $536,628.10 (adds back $290,000 paper-offset)

> **NOTE on 2022 Lump-Sum:** The 2022 "Paid to RCL" figure of $814,889.67 includes the $694,889.67 lump-sum payment that zeroed out accumulated 2020-2022 arrears, plus regular $120,000 in draws.

> † Includes $290,000 in MetLife long-term-disability offset entries that the arbitrator ruled were improper deductions by NGM. Litman did not receive that $290,000 as cash; it was a paper-offset bookkeeping construct. Adjusted figures (subtracting the $290K offset from "Paid" and adding it to the outstanding balance) are shown in the corresponding reading note. See `output/LITMAN_SUMMARY_DISABILITY_OFFSET_EXTRACT_20260416.md` and `output/RCL_VARIANCE_RECONCILIATION_2020_ANALYSIS_20260416.md` for the primary-ledger reconciliation.

---

## 3. "FOR PURPOSES OF TRADE" -- THE COMMERCIAL VALUE OF LITMAN'S NAME

These records, produced by Goldberg's own counsel, conclusively establish the "trade or advertising" element of NY Civil Rights Law Section 51:

1. **$26.4 million in total funds** were collected on matters where Richard C. Litman is identified as the originating attorney -- the attorney whose name and professional reputation attracted these clients.

2. **$19.4 million in collected fees** flowed to NGM from work performed under Litman's name during the post-SOL period (6/15/2020 forward).

3. The 20% origination fee structure itself proves NGM valued Litman's name as a revenue-generating asset -- they paid him specifically for being the attorney of record whose name attracted and retained clients.

4. Goldberg continued to use Litman's name on 905 issued patents, 206 outgoing USPTO documents, the firm website, and in client communications throughout this period precisely because that name generated these fees.

---

## 4. Q4 2025 CLIENT BREAKDOWN (From Payment Allocation Reports)

The Payment Allocation Reports for Q4 2025 identify the specific clients paying fees on Litman-originated matters. All clients listed are attributed to "RL" (Richard Litman) as both the responsible and collecting attorney.

### October 2025 -- $956,885.00 Total Paid

| Client | Fees | Hard Costs | Total Paid |
|--------|-----:|----------:|-----------:|
| King Saud University | $629,701.50 | $261,866.50 | $892,566.00 |
| Kuwait University | $13,400.00 | $12,260.00 | $25,660.00 |
| Kador, Peter F. | $7,354.00 | $9,601.00 | $17,380.00 |
| Sultan Qaboos University | $8,920.00 | $324.00 | $9,244.00 |
| Dasman Diabetes Institute | $5,000.00 | $0.00 | $5,000.00 |
| Hershberger, Nelson | $1,723.00 | $1,742.00 | $3,565.00 |
| 3-A Sanitary Standards Inc. | $1,125.00 | $1,770.00 | $2,940.00 |
| BHC Management, LLC | $500.00 | $0.00 | $530.00 |

### November 2025 -- $498,088.84 Total Paid

| Client | Fees | Hard Costs | Total Paid |
|--------|-----:|----------:|-----------:|
| King Faisal University | $251,994.00 | $45,699.00 | $298,788.00 |
| King Saud University | $49,775.00 | $34,541.00 | $84,316.00 |
| United Arab Emirates University | $65,436.54 | $15,267.14 | $80,703.68 |
| Kuwait University | $9,550.00 | $13,312.00 | $22,862.00 |
| Kuwait Institute for Scientific Research | $5,100.00 | $4,510.10 | $9,610.10 |
| 3-A Sanitary Standards Inc. | $600.00 | $1,164.06 | $1,809.06 |

### December 2025 -- $576,322.64 Total Paid

| Client | Fees | Hard Costs | Total Paid |
|--------|-----:|----------:|-----------:|
| King Faisal University | $250,905.00 | $44,959.00 | $296,623.00 |
| King Saud University | $94,995.84 | $58,039.16 | $153,035.00 |
| Sabah Al-Ahmad Center for Giftedness & Creativity | $29,358.00 | $15,534.00 | $46,092.00 |
| Kuwait University | $34,632.00 | $7,872.00 | $42,504.00 |
| United Arab Emirates University | $10,029.32 | $16,999.92 | $27,029.24 |
| Sultan Qaboos University | $5,888.00 | $112.00 | $6,000.00 |
| Kuwait Institute for Scientific Research | $600.00 | $4,439.40 | $5,039.40 |

### Q4 2025 Client Summary

| Client | Oct | Nov | Dec | Q4 Total |
|--------|----:|----:|----:|---------:|
| King Saud University | $892,566 | $84,316 | $153,035 | $1,129,917 |
| King Faisal University | -- | $298,788 | $296,623 | $595,411 |
| United Arab Emirates University | -- | $80,704 | $27,029 | $107,733 |
| Kuwait University | $25,660 | $22,862 | $42,504 | $91,026 |
| Sabah Al-Ahmad Center | -- | -- | $46,092 | $46,092 |
| Kador, Peter F. | $17,380 | -- | -- | $17,380 |
| Sultan Qaboos University | $9,244 | -- | $6,000 | $15,244 |
| Kuwait Institute for Scientific Research | -- | $9,610 | $5,039 | $14,649 |
| Dasman Diabetes Institute | $5,000 | -- | -- | $5,000 |
| Hershberger, Nelson | $3,565 | -- | -- | $3,565 |
| 3-A Sanitary Standards Inc. | $2,940 | $1,809 | -- | $4,749 |
| BHC Management, LLC | $530 | -- | -- | $530 |
| **Q4 TOTAL** | **$956,885** | **$498,089** | **$576,323** | **$2,031,296** |

> **KEY FINDING:** Middle Eastern university clients -- KFU, KSU, UAEU, Kuwait University, KISR, Sultan Qaboos University, Sabah Al-Ahmad Center, and Dasman Diabetes Institute -- account for **$2,005,072** of the **$2,031,296** Q4 2025 total, or **98.7%** of all revenue. These are clients originally brought to the firm by Richard Litman and retained through his professional reputation. Fees continued to be collected under his name months after this lawsuit was filed.

---

## 5. REVENUE TREND AND PAY CESSATION TIMELINE

| Month | Collected Fees | Paid to RCL | Notes |
|-------|---------------:|------------:|-------|
| Jan 2025 | $104,215 | $20,834 | Last month fully paid |
| Feb 2025 | $123,366 | $24,673 | Paid |
| Mar 2025 | $446,199 | $89,240 | Paid |
| Apr 2025 | $127,714 | $25,543 | Paid |
| May 2025 | $142,202 | -- | **PAYMENTS STOP** |
| Jun 2025 | $104,682 | -- | Unpaid |
| Jul 2025 | $31,959 | -- | Unpaid; **email access eliminated 07/18** |
| Aug 2025 | $196,081 | -- | Unpaid |
| Sep 2025 | $350,385 | $135,948 | Partial catch-up paid (May-Sep) |
| Oct 2025 | $628,332 | -- | **UNPAID** |
| Nov 2025 | $328,711 | -- | **UNPAID** |
| Dec 2025 | $276,098 | -- | **UNPAID** |

**Pattern:** Payments stopped in May 2025, coinciding with the litigation. A single catch-up payment was made in September covering May through September arrears, but Q4 2025 ($246,628 owed) remains entirely unpaid as of year-end. Meanwhile, fees continued to be collected on Litman-originated matters at the rate of approximately $400,000-$900,000 per month.

---

## 6. EVIDENTIARY SIGNIFICANCE

### For Section 51 "Purposes of Trade"

Goldberg's own financial records prove beyond dispute that Litman's name was used "for purposes of trade or advertising" within the meaning of NY Civil Rights Law Section 51:

- **$26.4 million** in total funds flowed through Litman-originated matters from 2020-2025
- The firm designated Litman as "originating attorney" on all these matters
- Litman's 20% origination share was calculated, tracked, and (partially) paid -- proving the firm treated his name as a revenue-generating commercial asset
- Revenue continued flowing from these clients even after the lawsuit was filed

### For Damages

- **Minimum unjust enrichment:** $246,628.10 currently owed (Q4 2025 unpaid)
- **Total commercial value of name use:** $19.4 million in collected fees
- **Litman's share of the commercial value:** $3.89 million
- **Pay reduction/underpayment gap (2020-2022):** Goldberg reduced Litman's draws from $75,000/quarter to $30,000/quarter while collected fees remained high, accumulating $694,890 in arrears before making a lump-sum payment
- **Post-litigation withholding (Q4 2025):** $246,628 withheld as apparent retaliation

### For Pattern of Control

The financial records show Goldberg had complete control over:
- Whether and when Litman was paid
- The amount of periodic draws ($75K/quarter reduced to $30K/quarter without consent)
- The timing of lump-sum catch-up payments
- The decision to stop payments entirely in 2025

This financial control, combined with the POA signatures, USPTO filings, and client communications, establishes that Goldberg was the sole person controlling the commercial exploitation of Litman's name.

---

*All figures derived from spreadsheets produced by Defendant's counsel. Originals preserved at:*
*`evidence/gmail_batch2/4thQTR__Litman 2025 Summary_December_.xlsx`*
*`evidence/gmail_batch2/From_Josh_May_2024_Update__Litman 2024 Summary_May.xlsx`*
*`evidence/gmail_batch2/4thQTR__Copy of Payment Allocation by Client Report for RCL as originating attorney [Oct/Nov/Dec] 2025 Excel.xlsx`*

*Prepared: April 2, 2026*