# Q1 2026 Payment Backup — Analysis

**To:** Richard C. Litman / Scott D. Woller, Esq.
**Re:** Aaron H. Gould email of 4/17/2026 10:05 AM ET (Q1 2026 NGM payment backup)
**Prepared:** 2026-04-17
**Source:** 36 files produced by NGM via Connell Foley (now archived at `evidence/ngm_q1_2026_payment_backup_20260417/`)

---

## Bottom Line

1. **NGM is wiring $18,848.00 for Q1 2026.** That is 96% lower than Q1 2024 ($451,961 paid for the same three months) and the lowest quarterly payment in the entire post-2020 dataset.
2. **Despite the tiny wire, NGM's own billing system still attributes $254,106 of Q1 2026 work to "RCL as originating attorney"** across 334 line items, 42 dockets, 4 clients — 8 months after Litman's July 2025 termination. Every line is a fresh § 51 use.
3. **NGM continues to invoice $1.3M under "Richard Litman" as Collecting Lawyer** on 496 open invoices — including 161 invoices dated 2025 (many post-termination). Only 5.9% of those invoices has been collected.
4. **$1.59M of Litman-attributed trust positions vanished between Jan 31 and Feb 1, 2026** with no corresponding bank movement. This is a trust-ledger parallel to the Line 74 switchover.

---

## 1. Q1 2026 Payment Math

Per NGM's own `Litman 2026 Summary_March.xlsx`:

| Month | Funds Received | Collected Fees | 20% Share Due | Paid in Month |
|---|---:|---:|---:|---:|
| Jan 2026 | $7,542.00 | $2,250.00 | $450.00 | $0.00 |
| Feb 2026 | $115,374.00 | $91,240.00 | $18,248.00 | $0.00 |
| Mar 2026 | $4,136.78 | $750.00 | $150.00 | $0.00 |
| **Q1 2026** | **$127,052.78** | **$94,240.00** | **$18,848.00** | $0.00 |

Gould's 4/17 email states the $18,848 "is being wired shortly."

### Context — Q1 comparison across years

| Period | 20% Share Paid to Litman |
|---|---:|
| Q1 2024 | $451,961 |
| Q1 2025 | ~$134,756 (20% of $673,763 collected fees) |
| **Q1 2026** | **$18,848** |

Drop from Q1 2024 to Q1 2026: **−95.8%.** Drop from Q1 2025 to Q1 2026: **−86.0%.**

---

## 2. Q1 2026 Still Attributes $254K of Work to "RCL as Originating Attorney"

The three `Payment Allocation by Client Report for RCL as originating attorney` spreadsheets show NGM's billing system continues to tag every dollar of this client work to Litman's identity:

| Client | Files (dockets) | Line Items | Fees Attributed | Total Attributed |
|---|---:|---:|---:|---:|
| King Faisal University | 36 | 304 | $88,240 | $112,374 |
| Sultan Qaboos University (Oman) | 1 | 7 | $94,240 | $118,374 |
| King Saud University | 4 | 19 | $6,000 | $21,735 |
| Qatar Foundation | 1 | 1 | $0 | $1,623 |
| **Total Q1 2026** | **42** | **334** | **$188,480** | **$254,106** |

Note that **Sultan Qaboos University** and **Qatar Foundation** do not appear in prior-period memory or the 905-patent dataset. If NGM is attributing new client relationships to Litman's name in 2026 (7+ months post-termination), each attribution is a § 51 use that did not exist at the time of the complaint.

The split between $188K "fees" attributed and $94K "collected fees" in the Summary reflects a 50/50 origination/collecting split internally (i.e. Litman is credited with only half the attributed revenue before the 20% overlay is applied). The $254K figure is the defendant's own internal measurement of the commercial value of using Litman's name in Q1 2026.

---

## 3. AR Report April 2026 — "Richard Litman" as Collecting Lawyer on $1.3M in Live Invoices

From `AR_Report_202604_RL.xlsx` — Collecting Lawyer Firm Summary:

| Metric | Value |
|---|---:|
| Total billed under "Collecting Lawyer = Richard Litman" | $1,302,403.04 |
| Total paid | $77,213.28 (5.93%) |
| Outstanding | **$1,225,189.76 (94.07%)** |
| 100% of outstanding is in the "Older" aging bucket |  |
| Invoice line items | 496 |
| Unique dockets | 374 |
| Unique clients | 15 |

### Outstanding AR by Client (top 10)

| Client | Outstanding |
|---|---:|
| King Saud University | $1,135,130 |
| United Arab Emirates University | $76,062 |
| Sabah Al-Ahmad Center for Giftedness | $58,958 |
| Qatar Foundation | $55,279 |
| Kuwait Institute for Scientific Research | $30,022 |
| Kuwait University | $25,906 |
| Saline Water Desalination Research Institute | $16,300 |
| Imam Mohammad Ibn Saud Islamic University | $15,044 |
| Kuwait Oil Company | $8,420 |
| Simmons Lighting, LLC | $7,590 |

### Invoices by year of issue

| Year | Invoices | Outstanding |
|---|---:|---:|
| 2024 | 199 | $655,402 |
| 2025 | 161 | $450,872 |
| 2023 | 38 | $145,557 |
| 2022 | 27 | $59,210 |
| 2018–2021 | 71 | cumulative |

**The 161 invoices dated 2025 include billings both before and after Litman's July 2025 termination.** Each invoice is a document of NGM's own creation that identifies "Richard Litman" as the Collecting Lawyer on a NGM-to-client billing relationship — a § 51 commercial use on the invoice face.

### Credit-Lawyer breakdown (secondary attribution)

Litman is tagged as the Credit Lawyer on **$515,036 billed / $449,534 outstanding (36.69% of firm AR)**. The next largest are:

| Credit Lawyer | Outstanding |
|---|---:|
| Richard Litman | **$449,534 (36.69%)** |
| "Firm Client" | $183,179 |
| Andy Rao | $72,237 |
| James N. Lafave | $70,903 |
| Joshua B. Goldberg | $65,866 |
| Ilirian Durri | $52,403 |
| Morgan D. Rosenberg | $53,887 |
| Howard Kline | $5,333 |

---

## 4. Trust Account Anomalies

### A. $1.59M of Litman-Attributed Trust Positions Disappeared Between Jan 31 and Feb 1, 2026

Per the three `Trust Listing for RCL` PDFs:

| Snapshot | Eagle Bank (t23) | BoA Escrow (t3) | RL Total |
|---|---:|---:|---:|
| Jan 2026 | $837,871.08 | $1,863,705.24 | **$2,701,576.32** |
| Feb 2026 | $1,046,123.40 | $46,303.33 | **$1,092,426.73** |
| Mar 2026 | $1,002,625.40 | $44,680.55 | **$1,047,305.95** |

Between the Jan closing and Feb opening, **$1,817,401.91 disappeared from the BoA Escrow balance attributable to RL matters** (while Eagle Bank went up $208K). The net RL-attributed trust drop is **$1,609,149.59** in 24 hours.

The corresponding `Trust Register Feb 2026` shows firm-wide bank movement over the entire month totaling only −$40,484.90 net. The $1.6M drop therefore reflects reassignment of responsible attorney from "RL" to other attorneys, not actual bank disbursement.

This is the trust-ledger equivalent of the Line 74 switchover (Jan 14–21, 2025, where Goldberg's name replaced Litman's on patent front pages). The reassignment pattern is now repeating at the trust-accounting level.

### B. Phantom BoA Balance (Jan 2026)

`Trust Listing for RCL Jan 2026.pdf` claims RL held $1,863,705.24 in BoA Escrow Acct_8777. But `Trust Register Report Jan 2026.pdf` shows **firm-wide BoA Escrow balance = $96,231.64 opening / $80,935.64 closing**. RL's claimed share exceeds the entire account by **~$1.78M**.

Interpretations (pick one or more, all actionable):

- **Accounting error:** The Listing is populated from stale/legacy data and does not reflect real bank balance.
- **Commingling / spoliation:** The firm records trust obligations to RL matters that are not actually held in the bank — funds previously deposited for RL matters have been moved out and never reconciled.
- **Software artifact:** PracticeMaster/PCLaw trust module is aggregating something other than live bank balance.

Any of these warrants a demand for the underlying bank statements for BoA Acct_8777 covering 2024–2026.

### C. Two Accounts, Not Three

Both the Trust Register and Trust Listing Q1 2026 show only two accounts:

- **t23** Eagle Bank Trust_0495
- **t3** Bank of America Escrow Acct_8777

**Freedom Bank (the third trust account closed 7/28/25 after suit filing) is absent.** Consistent with prior finding that Freedom Bank was never reintegrated after closure.

---

## 5. Revenue Collapse — Monthly Trajectory (Jan 2024 → Mar 2026)

NGM's own `Litman 2026 Summary_March.xlsx` (partial — numbers are collected-fees / 20% share):

| Month | 20% Due Litman |
|---|---:|
| Jan 2024 | $132,637 |
| Feb 2024 | $163,314 |
| Mar 2024 | $156,011 |
| Oct 2024 (peak) | $257,120 |
| Mar 2025 | $89,240 |
| Jul 2025 (termination month) | $6,392 |
| Oct 2025 | $125,666 |
| Dec 2025 | $55,220 |
| **Jan 2026** | **$450** |
| **Feb 2026** | **$18,248** |
| **Mar 2026** | **$150** |

Aggregate 2024: ~$1,019K in 20% share due over 12 months. Aggregate Jan–Mar 2026: **$18,848.**

This collapse coincides temporally with:

- Line 74 switchover on patent face pages (Jan 14–21, 2025)
- Website removal of Litman (profile disappeared by Sept 5, 2025)
- Termination (July 18, 2025)
- CN-37833 name removal (May 1, 2025, per project memory)
- Freedom Bank closure (July 28, 2025)

Yet the AR Report simultaneously shows NGM continues to bill $1.3M under Litman's name and tag $254K of Q1 2026 client work to him as originating attorney. The discrepancy between what NGM **earns under Litman's name** and what NGM **pays Litman under the 20% agreement** is widening, not closing.

---

## 6. Strategic Implications (for discussion with Scott)

### For § 51 damages

The Q1 2026 data is a contemporaneous admission that NGM's commercial exploitation of Litman's identity is ongoing 8 months after termination. Every:

- "RCL as originating attorney" tag in the Payment Allocation reports
- "Richard Litman as Collecting Lawyer" line on an AR invoice
- Trust Listing matter with RL as "Responsible"

...is a discrete use of name for commercial purpose captured in NGM's own records. The April 2026 AR Report alone itemizes 496 separate uses on active billing documents.

### For the BOP (due 4/2/2026 — past due)

If the Bill of Particulars is still supplementable, this data adds:

- A new category of use: **internal accounting system attribution** (Originating Attorney, Collecting Lawyer, Responsible Attorney, Credit Lawyer)
- Specific per-docket exemplars across 4 new-to-record clients (Sultan Qaboos University, Qatar Foundation are not in the 905-patent dataset — new discovery targets)

### For accounting / spoliation

Three follow-up demands worth considering:

1. **BoA Escrow Acct_8777 bank statements** Jan 2024 – April 2026 — to test the $1.78M phantom balance and locate the disappeared $1.59M of Feb 1, 2026.
2. **Reassignment log** showing which matters moved from Responsible = "RL" to other attorneys between 1/31/2026 and 2/1/2026, and why.
3. **All 161 invoices dated 2025** that bear "Richard Litman" as Collecting Lawyer — to confirm pre- vs. post-termination dates.

### For the discovery exhibit binder

The 4/17/2026 first discovery batch binder (`output/DISCOVERY_BATCH_01_EXHIBIT_BINDER.pdf`) did not include any internal billing-system exemplars. A supplemental batch could add:

- Exhibit 10: AR Report 4/2026 (LITMAN internal billing shows "Richard Litman" on 496 invoices)
- Exhibit 11: Payment Allocation Jan/Feb/Mar 2026 (334 line items, 4 clients tagged to RCL)
- Exhibit 12: Trust Listing Jan 2026 showing $2.69M RL trust positions

### For the wire acceptance question

Scott will want to discuss whether accepting the $18,848 wire without reservation of rights could be argued as acquiescence to NGM's accounting. A cover letter framing the receipt as "without prejudice to claims that the collected-fees denominator has been suppressed and to claims that the trust reconciliation remains incomplete" would preserve the arguments above.

---

## 7. Files Received and Categorized

36 files archived at `evidence/ngm_q1_2026_payment_backup_20260417/`:

**Core accounting (5)** — `Litman 2026 Summary_March.xlsx`, `AR_Report_202604_RL.xlsx`, and the 3 Payment Allocation reports (Jan/Feb/Mar 2026).

**Trust ledgers (12)** — Trust Register, Trust Bank Journal, Trust Transfer Journal, Trust Listing for RCL — each for Jan, Feb, March 2026.

**Email MIME wrappers (18)** — `ATT00001.htm` through `ATT00018.htm` and `~WRD0005.jpg` (email formatting; no substantive content).

---

*Prepared by automated Q1 2026 payment-backup analysis pipeline. All numbers reconcile to NGM-produced source files. Cross-checks completed against the pre-5/31/2025 payment history in `output/PATENT_REVENUE_LINKAGE_SUMMARY.md` and project-memory file `project_freedom_bank.md`.*