# Q1 2026 Reconciliation Memo — Billed → Paid → Where → Wired

**To:** Richard C. Litman / Scott D. Woller, Esq. (WACHTEL MISSRY LLP)
**From:** Michael Litman / analysis team
**Re:** *Litman v. Goldberg,* Index No. 524343/2025 (N.Y. Sup. Ct., Kings County) — Q1 2026 Settlement Leverage
**Date:** April 18, 2026
**Classification:** Attorney Work Product / Privileged

---

## Framing (per R. Litman, 4/18/2026)

> "The $18k for 3 months is meaningless unless we know what was billed and what was paid and from where. Tracking Eagle Bank trust balance may be key prior to getting bank statements."

This memo does two things: (1) reconstructs the four stages of the Q1 2026 money stream — **Billed → Paid by client → Deposited where → Wired to Litman** — using NGM's own 4/17/2026 production (36 files), and (2) freezes NGM's **asserted Eagle Bank and BoA Escrow balances** in writing so that any delta between NGM's ledger and the subpoenaed bank statements becomes provable spoliation on the day the statements arrive.

**Termination anchor: July 18, 2025** (Findings #23, #54, #94, #106: email elimination on litigation-threat +1 day; USPTO BHC notice still directed to rlitman@nathlaw.com on 8/20/25; Amendment § 3 email-license breach; 8,024+ emails landed in "eliminated" accounts through 12/31/25).

---

## Bottom Line

1. **The $18,848 wire is a 96% collapse** from Q1 2024's $451,961 baseline and Q1 2025's ~$134,756 — **the lowest quarterly payment in the entire post-2020 dataset**. Paid-in-Month = $0 all three months.
2. **NGM's own ledger shows $127,052.78 of client funds were collected in Q1 2026 on Litman-originated dockets.** Of the $94,240 booked as fees, NGM kept **$75,392** (80%) as operating revenue under Litman's name. That is the contemporaneous Q1 commercial benefit to NGM of continuing name-use 9 months post-termination.
3. **$176,070 of brand-new invoices were issued under Richard Litman's name as Collecting Lawyer after July 18, 2025 termination** — 35 invoices, 100% outstanding, 34 of 35 billed to King Saud University. Each invoice is a freshly dated § 51 commercial use.
4. **$1,513,899** total billed under Litman as Collecting Lawyer is currently sitting on NGM's AR run (496 open invoices, 94.9% uncollected, 100% in "Older" aging bucket).
5. **The $1.78M BoA phantom is now locked in writing.** January Trust Listing asserts RCL matters hold $1,863,705.24 in BoA Escrow_8777, but the contemporaneous firm-wide Trust Register for the same account shows opening $96,231.64 / closing $80,935.64. Litman's purported share exceeds the entire account balance by ≈$1.78M. NGM produced both documents on 4/17/2026.
6. **The Jan 31→Feb 1, 2026 vanish is real but smaller than first calculated.** The Jan RCL listing was run with a filtered parameter set (receipts-only); Feb/Mar were full snapshots. Apples-to-apples: 5 Kuwait University dockets totaling **$68,280** disappeared off the RCL listing with no matching bank disbursement. They were reassigned off RCL, not paid out.
7. **50 matters with last-trust-entry after 7/18/2025 remain attributed to RCL as Responsible Attorney on the Feb/Mar 2026 snapshots** — post-termination attribution still live on NGM's ledger.
8. **The single biggest Q1 2026 cash event on Litman-attributed work: 2/9/2026 wire-in $291,173 from King Faisal University (docket 36372), followed on 2/10/2026 by a $224,113 trust-to-operating transfer to Nath & Associates PLLC.** $67,060 remains sitting in Eagle Bank against KFU docket 36372 as of 3/31/2026.

---

## 1. The Four-Stage Reconciliation

```
STAGE 1 — Billed under Litman name    $1,513,899.04 (AR Report Apr 2026, 496 inv)
  └─ of which, dated ≥ 7/18/2025      $  176,070.00 (35 inv, 100% outstanding)
  └─ of which, dated in Q1 2026       $        0.00 (ZERO — see §3)

STAGE 2 — Paid by client in Q1 2026   $  127,052.78 (Payment Allocation, 3 mo)
  ├─ Jan 2026                        $    7,542.00 (3 dockets, 18 payment lines)
  ├─ Feb 2026                        $  115,374.00 (37 dockets, 311 payment lines)
  └─ Mar 2026                        $    4,136.78 (2 dockets, 2 payment lines)

STAGE 3 — Deposited into trust        (Trust Bank Journal)
  Eagle Bank t23 — firm-wide Q1:     $  516,187.26 deposits / $ 571,688.00 disb.
  BoA Escrow t3 — firm-wide Q1:      $        0.00 deposits / $  16,918.78 disb.

STAGE 4 — Disbursed to operating (Q1)
  Trust→Op transfers to Nath & Assoc: $  264,615.00 (Jan+Feb+Mar, signed VG)
  Other trust-to-op invoice transfers: $  181,567.15

STAGE 5 — Wired to Litman             $   18,848.00 (Gould email 4/17/2026)
  └─ Actually Paid in Q1 (per NGM):  $        0.00 (Summary shows "Paid = 0")
  └─ Now accrued as "Total Now Due":  $   18,848.00
```

---

## 2. Stage 1 — Billed: $1.5M Under Litman's Name, $176K Freshly Billed Post-Termination

### 2.1 AR Report April 2026 — full 496-invoice universe

| Invoice Year | # | Billed | Paid | Outstanding |
|---|---:|---:|---:|---:|
| 2018 | 9 | $24,942.97 | $2,991.00 | $21,951.97 |
| 2019 | 12 | $25,675.00 | $3,385.00 | $22,290.00 |
| 2020 | 12 | $58,639.40 | $16,069.82 | $42,569.58 |
| 2021 | 38 | $39,060.00 | $0.00 | $39,060.00 |
| 2022 | 27 | $71,873.03 | $12,663.37 | $59,209.66 |
| 2023 | 38 | $154,633.35 | $9,076.14 | $145,557.21 |
| 2024 | 199 | $682,792.85 | $27,390.73 | $655,402.12 |
| 2025 | 161 | $456,282.44 | $5,410.00 | $450,872.44 |
| 2026 | 0 | $0.00 | $0.00 | $0.00 |
| **TOTAL** | **496** | **$1,513,899.04** | **$76,986.06** | **$1,436,912.98** |

94.9% of invoiced dollars under Litman's name is outstanding. 100% of the outstanding balance is in the "Older" aging bucket.

### 2.2 The 35 post-termination invoices (fresh § 51 uses)

35 invoices were dated between 7/19/2025 and 10/15/2025 — all still show Richard Litman as Collecting Lawyer. Every one is $0 paid.

| Metric | Value |
|---|---:|
| # invoices | 35 |
| Total billed | $176,070.00 |
| Total paid | $0.00 |
| Total outstanding | $176,070.00 |
| Client concentration | 34/35 KSU, 1/35 UAEU |
| Date range | 7/22/2025 – 10/15/2025 |
| Latest | Inv 422573, 10/15/2025, docket 33070.01U (Sabah Al-Ahmad Center), $14,396 |

Full list in `output/Q1_2026_BILLED_VS_PAID_DETAIL.md` §2a and CSV `output/Q1_2026_invoices_dated_q1.csv`.

### 2.3 Zero invoices dated in Q1 2026

NGM's production contains no AR invoices dated 1/1/2026 – 3/31/2026 with Litman as Collecting Lawyer. Two interpretations, both useful:

- **Option A:** NGM stopped putting Litman's name on fresh 2026 invoices. That is itself a data point on NGM's awareness of § 51 exposure — late-stage cleanup.
- **Option B:** NGM selectively excluded 2026 invoices from the production. If so, this should be flagged in the 5/15/2026 follow-up as a production deficiency.

Either interpretation supports a narrow written demand: *"Confirm whether NGM issued any invoice dated in Q1 2026 that identified Richard Litman in any attorney role (Collecting, Originating, Responsible, Credit). If yes, produce them. If no, confirm that representation under oath."*

---

## 3. Stage 2 — Paid by Client in Q1 2026: $127,052.78 Collected on RCL-Originated Work

### 3.1 Monthly detail (from NGM Payment Allocation reports)

| Month | Funds Received | Collected Fees | Disbursements | Dockets Receiving Funds | Payment Lines |
|---|---:|---:|---:|---:|---:|
| Jan 2026 | $7,542.00 | $2,250.00 | $5,292.00 | 3 | 18 |
| Feb 2026 | $115,374.00 | $91,240.00 | $24,134.00 | 37 | 311 |
| Mar 2026 | $4,136.78 | $750.00 | $3,386.78 | 2 | 2 |
| **Q1 2026** | **$127,052.78** | **$94,240.00** | **$32,812.78** | **42 unique** | **331** |

### 3.2 February was the only real month — 27 of 37 dockets are King Faisal University

Every Feb 2026 KFU payment settled on a single date: **2/10/2026**. This is a bulk KFU wire event against pre-existing invoices, not routine monthly collection.

**Top dockets (Feb 2026):**

| Docket | Client | Total Received | Invoice(s) |
|---|---|---:|---|
| 33190.19U | King Faisal University | $13,320 | 421866, 422422, 422522 |
| 33190.20U | King Faisal University | $11,360 | 421855 |
| 33190.24U | King Faisal University | $11,206 | 422520 |
| 33190.26U | King Faisal University | $10,786 | 422405 |
| 33190.23U | King Faisal University | $10,310 | 421957 |
| 32490.47U | Sultan Qaboos University | $3,000 | 421057 *(post-termination new client)* |

### 3.3 Client concentration

| Client | Q1 2026 Received | Files | Payment Lines |
|---|---:|---:|---:|
| King Faisal University | $112,374 | 36 | 304 |
| Sultan Qaboos University (Oman) *NEW* | $3,000 | 1 | 7 |
| King Saud University | $7,542 + $2,514 | 4 | 19 |
| Qatar Foundation *NEW* | $1,623 | 1 | 1 |

**Sultan Qaboos** and **Qatar Foundation** are NEW to the RCL-originated tag in 2026. Neither appears in the 905-patent backbone dataset. Attribution of these clients to Litman's originating-attorney slot happened after 7/18/2025 — each is a fresh § 51 use on internal records.

---

## 4. Stages 3–4 — Where the Money Went (Trust Bank Flow)

### 4.1 Eagle Bank Trust Acct_0495 (t23) — firm-wide monthly activity

| Month | Opening | Deposits (#) | Deposits ($) | Disburse (#) | Disburse ($) | Net | Closing |
|---|---:|---:|---:|---:|---:|---:|---:|
| Jan 2026 | $1,324,984.41 | 25 | $84,627.00 | 40 | $102,043.00 | −$17,416.00 | $1,307,568.41 |
| Feb 2026 | $1,294,242.41 | 32 | $395,031.10 | 52 | $355,516.00 | +$39,515.10 | $1,333,757.51 |
| Mar 2026 | $1,333,757.51 | 18 | $36,529.16 | 47 | $114,129.00 | −$77,599.84 | $1,256,157.67 |

> **⚠ Flag: $13,326.00 Jan→Feb Eagle Bank continuity gap.** NGM's Feb 2026 opening ($1,294,242.41) is **$13,326.00 lower** than its own Jan 2026 closing ($1,307,568.41). That delta left Eagle Bank Trust_0495 sometime between 1/31/2026 and 2/1/2026 with **no transaction captured in either monthly journal**. This is the exact spoliation signature the Eagle Bank subpoena will surface and aligns with the Jan 31 → Feb 1 RCL-responsibility switchover pattern. Flag for 5/15/2026 production: the reconciliation worksheet that explains this gap, and any off-journal transaction that touched Eagle Bank on 1/31 or 2/1/2026.

### 4.2 Bank of America Escrow Acct_8777 (t3) — firm-wide monthly activity

| Month | Opening | Deposits | Disbursements | Closing |
|---|---:|---:|---:|---:|
| Jan 2026 | $96,231.64 | $0.00 | $15,296.00 *(1 tran — Kuwait U docket 33050.10U)* | $80,935.64 |
| Feb 2026 | $80,935.64 | $0.00 | $0.00 | $80,935.64 |
| Mar 2026 | $80,935.64 | $0.00 | $1,622.78 *(1 tran — Qatar Foundation docket 32605.29)* | $79,312.86 |

**BoA Escrow had one outflow in Jan, zero movement in Feb, one outflow in March.** The account is essentially dormant for the firm. Nevertheless, the RCL Trust Listing for January asserts Litman's matters hold $1,863,705.24 in this same account. **That is the phantom.**

### 4.3 The Feb 9–10 KFU event — trust-to-operating transfer of Litman-attributed client funds

The single biggest cash event in Q1 2026 on the Litman-originated pipeline:

| Date | Acct | Tran# | Docket | Counterparty | Direction | Amount |
|---|---|---|---|---|---|---:|
| 2/9/2026 | t23 | 4000959 | 36372 | King Faisal University | **IN** (wire) | **$291,173.00** |
| 2/10/2026 | t23 | 4001216 | 36372 | Nath & Associates PLLC | **OUT** (trust→op) | **$224,113.00** |

$67,060 of the $291K wire net remained in Eagle Bank on KFU umbrella docket 36372 as of 3/31/2026. The $224,113 left trust to operating under the Nath & Associates PLLC receiving account on the morning after the wire cleared. Cross-reference: Finding #56 (KFU is the biggest post-SOL institutional client; Litman's name sits on every KFU application's USPTO correspondence address), and the AR Report shows KFU is also the target of the 35 post-termination invoices that remain unpaid.

### 4.4 Trust Transfer Journal — 150 entries across Q1 2026

- **Total transfer entries:** 150 (42 Jan, 54 Feb, 54 Mar — approximate; 150 total per Section 4 of the trust-positions extract)
- **Users executing transfers:** VG (Valencia Gray) is the dominant signer; TC is the secondary. Both are NGM accounting staff.
- **Transfer types:** TO = trust→operating (on invoice), OO = operating→operating, TF = trust→trust reassignment of matter funds.
- **Jan 2026 total of TO/TF amounts:** $446,182.15
- **Biggest Jan single item:** $300,000 OO from o12 to EagleBank Op ("Transfer to EagleBank Op," 1/2/2026, signed VG) — an operating-to-operating inter-bank transfer.
- **Notable TF (inter-matter reassignment):** 1/8/2026 $500 from docket 41216S (Shahbaz Ahmad) to docket 41315S ("CC Retainer New Search Shahbaz Ahmad"), signed TC.

Full transfer register in `output/Q1_2026_TRUST_POSITIONS_AND_TRANSFERS.md` §4 and CSV `output/Q1_2026_trust_transfers.csv`.

---

## 5. Stage 5 — What Litman Actually Gets Paid

From `Litman 2026 Summary_March.xlsx`:

| Month | Funds Received | Collected Fees | 20% Due | **Paid in Month** | Running Total Due |
|---|---:|---:|---:|---:|---:|
| Jan 2026 | $7,542.00 | $2,250.00 | $450.00 | **$0.00** | $450.00 |
| Feb 2026 | $115,374.00 | $91,240.00 | $18,248.00 | **$0.00** | $18,698.00 |
| Mar 2026 | $4,136.78 | $750.00 | $150.00 | **$0.00** | $18,848.00 |
| **Q1 2026** | **$127,052.78** | **$94,240.00** | **$18,848.00** | **$0.00** | **$18,848.00** |

The **Paid in Month** column is zero for all three months. The $18,848 wire is accrued, not paid, through 3/31/2026. Gould's 4/17/2026 email stated it is "being wired shortly."

### The 80/20 split

| Figure | Amount | Comment |
|---|---:|---|
| Q1 2026 Collected Fees | $94,240 | NGM's own calculation base |
| Litman's 20% share | $18,848 | What Litman is to receive |
| **NGM's 80% retained share** | **$75,392** | Revenue NGM earned on work billed, invoiced, and collected under Litman's name 9 months post-termination |

### The 50% denominator reduction

Note the production shows $188K "fees" attributed by the Payment Allocation reports but only $94,240 "Collected Fees" on the Summary. The Summary applies a 50% reduction before the 20% share is calculated. Scott's v2 reservation-of-rights letter (§2a) already demands the contractual basis for this halving; the Q1 2026 data is the live-fire example.

---

## 6. Eagle Bank & BoA Escrow Baseline — LOCKED PER NGM'S OWN PRODUCTION

**Purpose of this section:** Freeze NGM's asserted Q1 2026 balances in a document we can serve on Connell Foley. Any subsequent bank statement that shows a different opening/closing balance, or flow inconsistent with NGM's own journals, is documentary spoliation.

### 6.1 Eagle Bank Trust Acct_0495 (t23) — Baseline Exhibit

| Month | NGM-Asserted Opening | Deposits (#/\$) | Disbursements (#/\$) | NGM-Asserted Closing |
|---|---:|---:|---:|---:|
| Jan 2026 | **$1,324,984.41** | 25 / $84,627.00 | 40 / $102,043.00 | **$1,307,568.41** |
| Feb 2026 | **$1,294,242.41** | 32 / $395,031.10 | 52 / $355,516.00 | **$1,333,757.51** |
| Mar 2026 | **$1,333,757.51** | 18 / $36,529.16 | 47 / $114,129.00 | **$1,256,157.67** |

Source: *Trust Bank Journal Jan / Feb / Mar 2026.pdf* + *Trust Register Report Jan / Feb / Mar 2026.pdf*, produced 4/17/2026 by NGM via Connell Foley. Author: MaryJane Harper, PracticeMaster v1.9.13x.

### 6.2 BoA Escrow Acct_8777 (t3) — Baseline Exhibit

| Month | NGM-Asserted Opening | Deposits (#/\$) | Disbursements (#/\$) | NGM-Asserted Closing |
|---|---:|---:|---:|---:|
| Jan 2026 | **$96,231.64** | 0 / $0.00 | 1 / $15,296.00 | **$80,935.64** |
| Feb 2026 | **$80,935.64** | 0 / $0.00 | 0 / $0.00 | **$80,935.64** |
| Mar 2026 | **$80,935.64** | 0 / $0.00 | 1 / $1,622.78 | **$79,312.86** |

### 6.3 RCL-Attributed Positions Per NGM's Own Trust Listings

| Snapshot | Eagle Bank t23 (RCL) | BoA Escrow t3 (RCL) | RCL Total |
|---|---:|---:|---:|
| Jan 31, 2026 *(filtered — receipts-only)* | $826,031.08 | **$1,863,705.24** | $2,689,736.32 |
| Feb 28, 2026 *(full snapshot)* | $1,046,123.40 | $46,303.33 | $1,092,426.73 |
| Mar 31, 2026 *(full snapshot)* | $1,002,625.40 | $44,680.55 | $1,047,305.95 |

### 6.4 Two Locked Anomalies

**(a) The $1.78M BoA phantom (Jan 2026).** RCL Trust Listing Jan 2026 asserts Litman-attributed matters hold **$1,863,705.24** in BoA Escrow Acct_8777. The firm-wide Trust Register for the same account, same month shows **opening $96,231.64, closing $80,935.64**. Litman's purported share exceeds the account total by approximately **$1,782,769.60**. Both documents produced by NGM on 4/17/2026. Lockable on face of production.

**(b) The Jan→Feb vanish (RCL attribution, no bank movement).** 5 Kuwait University dockets totaling **$68,280** appear on the RCL Jan 2026 listing but NOT on the Feb 2026 listing. No corresponding disbursement in either Eagle Bank or BoA across the Jan 31–Feb 1 window. The matters were reassigned off RCL as Responsible Attorney, not paid out. Dockets: 33050.12U ($15,296), 33050.08U ($14,296), 33050.02U ($13,396), 33050.05U ($12,896), 33050.13U ($12,396).

*(Note: the previously quoted "$1.59M vanish" was based on comparing the filtered Jan listing total to the full Feb listing. Apples-to-apples, using the true snapshot methodology, the real vanish is the $68,280 above plus the $1.78M phantom resolution. Total RL-attributed trust-balance drop Jan 31→Feb 1, as disclosed on NGM's own listings: **$2,689,736.32 → $1,092,426.73 = $1,597,309.59**, of which ~$1.78M is phantom and must be accounted for.)*

### 6.5 Why This Matters — The Baseline Protocol

1. Serve this section as an addendum to Scott's v2 reservation-of-rights letter (5/15/2026 deadline) captioned "per your client's 4/17/2026 production."
2. When subpoenaed BoA and Eagle Bank statements arrive, run a three-way compare: (a) NGM Trust Bank Journal, (b) subpoenaed bank statement, (c) RCL Trust Listing. Any two-pair disagreement = prima facie spoliation or reconciliation error.
3. Demand NGM's **monthly bank reconciliation worksheets** — these are the internal documents where NGM itself compares journal to statement. If they exist and show variances, the worksheets are the smoking gun; if they don't exist, the absence is itself an RPC 1.15 violation.
4. The $1.78M phantom is already locked without needing a bank statement — two NGM documents from the same production contradict each other on their face.

---

## 7. Continuing § 51 Use — 50 Matters With Post-Termination Last-Trust-Entry

The strongest on-face evidence of live post-termination commercial use: every matter on the Feb/Mar 2026 RCL Trust Listing with a last-trust-entry date **on or after 7/18/2025** is NGM treating Litman as Responsible Attorney today, on an active ledger, on work performed after he was terminated.

| Last Entry | Client | Matter | Description | Feb | Mar |
|---|---|---|---|---:|---:|
| 4/1/2026 | James Hurysz / Helena Zinkham | 16725.03 | U.S. Trademark Reg. 6,040,637 | 50 | 100 |
| 3/16/2026 | O'Brien, Wayne P. | 14695.05 | Interactive Holographic Human-Computer Interface | 1,180 | 2,360 |
| 3/4/2026 | King Saud University | **35610** | **General Matter (umbrella)** | 93,912 | 91,398 |
| 2/25/2026 | Johnson, Kevin F. | 32609.04X | Patent App 19/036,942 | 3,000 | 0 |
| 2/17/2026 | King Faisal University | **36372** | **General Matter - KFU (umbrella)** | 168,812 | 84,406 |
| 1/29/2026 | Concord Supply | 11060.54MX | Mexican Patent App MX/a/2021/015111 | 6,300 | 0 |
| 1/23/2026 | Kuwait University | 33050.02U | U.S. Patent App | 0 | 0 |
| 1/2/2026 | Al-Hamli, Mossab | 200801.03Y | U.S. Patent App 17/176,626 | 800 | 0 |

… plus 42 more matters with last-trust-entry between 7/29/2025 and 12/29/2025.

**Full list in `output/Q1_2026_TRUST_POSITIONS_AND_TRANSFERS.md` §6B and CSV `output/Q1_2026_rcl_trust_positions.csv`.**

Every one of these is an item of documentary evidence that NGM currently assigns Litman as Responsible Attorney on an active matter with activity dated after his 7/18/2025 termination.

---

## 8. Settlement Leverage Math

### 8.1 What NGM admitted with its own production

| Metric | Q1 2026 | Scaling |
|---|---:|---|
| Funds received on RCL-originated matters | $127,052.78 | ~$508K annualized |
| NGM's 80% retained revenue on RCL-originated work | $75,392 | ~$302K annualized |
| Billed under "Richard Litman" as Collecting Lawyer | $1,513,899 | present-day live AR |
| Outstanding under Litman's name | $1,436,913 | 94.9% of billed |
| Fresh invoices issued after 7/18/2025 termination | $176,070 | 35 discrete new § 51 uses |
| Matters still tagged "RL Responsible" with post-termination activity | 50 | each = continuing use |
| Trust Transfer Journal entries Q1 2026 | 150 | each = discrete accounting touch |

### 8.2 Scaling: KFU alone

The 2/9 KFU wire was $291,173 — **2.3× the total funds received across all RCL matters all quarter**. KFU is one client of 15 on the AR run. If one KFU wire can move $291K in a day, the forward pipeline under Litman's name is a multi-million dollar book that NGM continues to operate.

### 8.3 The right frame for a settlement discussion with Connell Foley

> *"Per your 4/17/2026 production: NGM took in $127,052.78 on Richard Litman's originated matters in Q1 2026, retained $75,392 of that as operating revenue, and accrued $18,848 owing to Litman while paying him $0 during the quarter. You continue to bill $1,513,899 under Mr. Litman's name as Collecting Lawyer on 496 live invoices — 35 of which, totaling $176,070, you issued after his July 18, 2025 termination. You currently treat Mr. Litman as Responsible Attorney on 50 matters with trust entries dated after his termination. On the firm's own January Trust Listing, you represented that Mr. Litman's matters held $1,863,705.24 in BoA Escrow Acct_8777, while the same January Trust Register showed that account's firm-wide balance was $80,935.64. Settlement must be calibrated to the full scale of admitted post-termination commercial use of Mr. Litman's name as reflected in your own client's records — not to the $18,848 snapshot."*

---

## 9. Recommended Immediate Actions

1. **Deliver this memo and the accompanying exhibit table (§6.1–6.2) to Scott Woller today** alongside the v2 reservation-of-rights letter. Consider whether §§6.1–6.2 should be incorporated into a v3 letter or served as an addendum captioned "per your client's production."
2. **Freeze the Eagle Bank / BoA baseline** in correspondence to Aaron Gould by 5/15/2026 (the v2 letter's response deadline). State explicitly: *"The attached Exhibit reflects NGM's asserted opening and closing Q1 2026 balances for Eagle Bank Trust_0495 and BoA Escrow_8777 per your production of 4/17/2026. Mr. Litman reserves all rights to challenge these figures against any subsequently produced bank statement."*
3. **Demand production of NGM's monthly bank reconciliation worksheets** (Jan, Feb, Mar 2026, and forward) as a new item under Scott's v2 letter §2c.
4. **Amend the pending USPTO OED, VA Bar, and DC Bar complaints** to attach NGM's 4/17/2026 production as Exhibit showing knowing post-termination commercial use. The 35 invoices and the 50 "last-entry-after-7/18/2025" matters are the new contemporaneous documentary evidence.
5. **Update the § 51 damages framework** in `project_court_status.md` memory — add the $127K/quarter funds-received run-rate and the $75K/quarter NGM retained-share figure as new data points under Tier 5 (post-termination commercial exploitation).
6. **Subpoena targets** (via Scott, for the 9/22/2026 compliance conference):
   - Bank of America — all records for Escrow Acct_8777, Wire Acct_8751, Operating Acct_2417 from 1/2024 through present.
   - Eagle Bank — all records for Trust Acct_0495 from 1/2020 through present.
   - Freedom Bank — all records for the trust account closed 7/28/2025 from account opening through final closure.

---

## 10. Source Files

**Input (produced by NGM via Connell Foley on 4/17/2026):** 36 files in `evidence/ngm_q1_2026_payment_backup_20260417/`.

**Analysis outputs:**
- `output/Q1_2026_BILLED_VS_PAID_DETAIL.md` — full invoice-level xlsx extract (billed vs paid, per-client detail)
- `output/Q1_2026_TRUST_BANK_FLOW.md` — day-by-day Eagle Bank and BoA flow
- `output/Q1_2026_TRUST_POSITIONS_AND_TRANSFERS.md` — matter-level positions, Jan→Feb→Mar delta audit, transfer journal
- `output/Q1_2026_PAYMENT_BACKUP_ANALYSIS.md` — prior 4/17/2026 top-line analysis (superseded by this memo on reconciliation points)
- `output/RESERVATION_OF_RIGHTS_LETTER_Q1_2026_v2.md` — Scott's response letter

**Raw CSVs:**
- `output/Q1_2026_invoices_dated_q1.csv` (35 rows)
- `output/Q1_2026_payments_received_detail.csv`
- `output/Q1_2026_trust_bank_transactions.csv`
- `output/Q1_2026_rcl_trust_positions.csv`
- `output/Q1_2026_trust_transfers.csv`

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*Prepared from NGM's own 4/17/2026 production. All dollar figures traceable to specific NGM-produced documents. Author: Michael Litman / automated reconciliation pipeline. Cross-checks against RESEARCH_LOG.md Findings #23, #54, #94, #106 (7/18/2025 termination); ANOMALOUS_TRANSACTIONS_CATALOG.md (trust anomalies, the five-account architecture); and project_freedom_bank.md (undisclosed third trust account).*