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States ex rel., Balderas v. Real Estate Law Center, P.C.

United States District Court, D. New Mexico

December 31, 2019

STATE OF NEW MEXICO, ex rel., HECTOR BALDERAS, Attorney General of New Mexico, Plaintiff,
v.
REAL ESTATE LAW CENTER, P.C., a California professional corporation; ERIKSON M. DAVIS, an attorney and resident of California, individually, and dba Real Estate Law Center, P.C., a California professional corporation; DEEPAK S. PARWATIKAR, an attorney and resident of California, individually, and dba Balanced Legal Group, an unidentified trade name or entity, dba www.pinnaclelawcenter.com; CHAD T. PRATT, an attorney and resident of California, individually, and formerly dba Real Estate Law Center, P.C.; the BALANCED LEGAL GROUP, an unidentified trade name or entity located in California, and PINNACLE LAW CENTER, P.C., a California professional corporation, Defendants.

          Hector H. Balderas Attorney General of the State of New Mexico Angelica Anaya-Allen Lisa Giandomenico Assistant Attorney General of the State of New Mexico Attorney General of the State of New Mexico's Office Santa Fe, New Mexico Attorneys for the Plaintiff

          Real Estate Law Center, P.C. Los Angeles, California Defendant

          Erikson M. Davis Newbury Park, California Defendant pro se

          Paul J. Kennedy Jessica M. Hernandez Elizabeth Harrison Kennedy, Hernandez & Associates, P.C.

          Albuquerque, New Mexico Attorneys for Defendants Deepak S. Parwatikar, Pinnacle Law Center, PC, and Balanced Legal Group

          Chad Thomas Pratt Los Angeles, California Defendant pro se

          MEMORANDUM OPINION AND ORDER

         THIS MATTER comes before the Court on the bench trial held on July 8, 2019, to July 11, 2019. The primary issues are: (i) whether the Defendants Real Estate Law Center, P.C., Erikson M. Davis, and Chad T. Pratt violated the Mortgage Assistance Relief Services (“MARS”) Rule, 12 C.F.R. § 1015 “Regulation O”;[1] (ii) Real Estate Law, Mr. Davis, and Mr. Pratt, violated the New Mexico Mortgage Foreclosure Consultant Fraud Prevention Act, N.M. Stat. Ann. §§ 47-15-1 to -8 (“MFCFPA”); and (iii) what damages the Defendants owe. The Court concludes that the Defendants violated the MARS Rule and the MFCFPA. The Court awards judgment against Real Estate Law, Mr. Davis, and Mr. Pratt in the following amounts: (i) Real Estate Law: $85, 941.20; (ii) Mr. Davis: $34, 826.80; and (iii) Mr. Pratt: $36, 955.00.

         FINDINGS OF FACT

         Plaintiff State of New Mexico and Mr. Parwatikar, Balanced Legal, and Pinnacle Law (collectively, the Parwatikar Defendants) have submitted proposed findings of fact. See Plaintiff's Proposed Findings of Fact and Conclusions of Law, filed August 9, 2019 (Doc. 212)(“New Mexico's Proposed Findings”); Defendant Parwatikar's Proposed Findings of Fact and Conclusions of Law, filed August 9, 2019 (Doc. 213)(“Parwatikar Defs.' Proposed Findings”). Defendant Chad T. Pratt also has submitted his Findings of Fact and Conclusions of Law, filed August 15, 2019 (Doc. 216)(“Pratt's Proposed Findings”). The Court notes that Pratt's Proposed Findings include one paragraph asking the Court to disregard individual claimants and do not otherwise include proposed findings of fact. Defendants Real Estate Law Center, P.C. and Erikson M. Davis did not submit proposed findings of fact and conclusions of law. The Court has carefully considered New Mexico's and the Parwatikar Defendants' sets of proposed facts, and Mr. Pratt's objections, and accepts some of those facts, rejects some, and finds some facts that no party brought to its attention. The Court sets forth its findings below.

         1. Real Estate Law Operations.

         1. Mr. Parwatikar is a member of the State Bar of California. See Transcript of Trial Proceedings at 635:10-12 (Anaya-Allen, Parwatikar)(taken July 10, 2019), filed July 15, 2019 (Doc. 196)(“July 10 Tr.”).

         2. Mr. Parwatikar is not licensed to practice law in the State of New Mexico. See July 10 Tr. at 635:13-21 (Anaya-Allen, Parwatikar).

         3. Mr. Pratt is a member of the State Bar of California. See Memorandum Opinion and Order at 2 n.3, filed July 2, 2019 (Doc. 183).

         4. Mr. Pratt is not licensed to practice law in the State of New Mexico. See Plaintiff's First Set of Requests for Admission and Second Set of Interrogatories to Defendant Chad T-W Pratt, Request No. 18, at 6 (admitted only as to Real Estate Law, Defendant Mr. Davis, and Mr. Pratt, July 11, 2019, at trial as New Mexico's Ex. 182)(“New Mexico's First Set of Requests”); Responses to Requests for Admission from New Mexico by Chad T-W Pratt, Sr., ¶ 18, at 4 (admitted July 11, 2019, at trial as New Mexico's Ex. 184)(“Pratt's Responses to Requests”).

         5. In 2008, Mr. Pratt described himself to a reporter as a “bottom feeder” and as a “predator, ” because he based his legal practice on desperate clients. David Lazarus, “Things are Looking up -- at the Pawn Shop, ” Los Angeles Times at 4 (March 23, 2008)(admitted July 11, 2019, at Trial as New Mexico's Ex. 243).

         6. Balanced Legal began operating in approximately 2008. See July 10 Tr. at 637:11-16 (Anaya-Allen, Parwatikar).

         7. Balanced Legal provided immigration law services and loan modification services. See July 10 Tr. at 637:25-638:3 (Anaya-Allen, Parwatikar); Deposition of Yervand Arzakanyan at 10:16-18 (taken September 21, 2018)(admitted July 11, 2019, at Trial as New Mexico's Ex. 188 (“Arzakanyan Depo.”)).

         8. Balanced Legal ceased operations around early 2011, and no longer has employees. See Deposition of Angelina Solomon at 37:8-18 (taken September 20, 2018)(admitted July 11, 2019, at Trial as New Mexico's Ex. 146)(“Solomon Depo.”). See also Transcript of Trial Proceedings at 803:9-11 (Kennedy, Parwatikar)(taken July 11, 2019), filed July 16, 2019 (Doc. 198)(“July 11 Tr.”)(stating that Balanced Legal Group did not exist when Madrid was a Real Estate Law client); July 10 Tr. at 735:5-9 (Parwatikar).

         9. As Balanced Legal was a “dba” of Mr. Parwatikar, Mr. Parwatikar subsequently used it as a personal account such that money transferred from Pinnacle Law to Balanced Legal was money paid to Mr. Parwatikar. See July 10 Tr. at 637:11-16 (Anaya-Allen, Parwatikar); July 10 Tr. at 735:5-9 (Parwatikar).

         10. Pinnacle Law is a professional law corporation, and Mr. Parwatikar incorporated it on July 7, 2011, and is its sole shareholder, president, chief operating officer, and chief financial officer. See Defendant Pinnacle Law Center, P.C.'s Answers, Responses, and Objections to Plaintiff's First Set of Interrogatories and Requests for Production, Answer to Interrogatory No. 8, at 6 (undated)(admitted July 10, 2019, at Trial as New Mexico's Ex. 155)(“Pinnacle Law Answers”). See also Solomon Depo. at 37:8-18.

         11. In 2011, Mr. Parwatikar and Pinnacle Law also helped Adlore Clarambeau incorporate Real Estate Law, and Mr. Parwatikar acted as an agent for Real Estate Law in that incorporation. See July 10 Tr. at 645:5-15 (Anaya-Allen, Parwatikar).

         12. Yervand Arzakanyan worked for Balanced Legal in marketing for loan modification services, see Arzakanyan Depo. at 10:5-8; id. at 10:16-18; July 10 Tr. at 640:10-11 (Anaya-Allen, Parwatikar), and his signature is on a check to the California Secretary of State on November 4, 2011, for $25.00 for “RELC PC Statement of Information, ” Check from Real Estate Law Center, P.C. to CA Secretary of State at 351-52 (admitted July 11, 2019, at Trial as New Mexico's Ex. 188); see Arzakanyan Depo. at 104:5-14.[2]

         13. Mr. Clarambeau's email address was adlore@balancedlegalgroup.com. See Solomon Depo. at 39:4-10; Spreadsheet of Balanced Legal Employees at 177, 179 (admitted as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 146).

         14. Mr. Parwatikar and Pinnacle Law knew that Mr. Clarambeau intended Real Estate Law to provide mortgage relief through lawsuits. See July 10 Tr. at 646:11-14 (Anaya-Allen, Parwatikar).

         15. Pinnacle Law, with Mr. Parwatikar as its sole shareholder, occupied a position as consultant for Mr. Clarambeau and for Real Estate Law. See July 10 Tr. at 646:15-24 (Anaya-Allen, Parwatikar); id. at 659:13-15 (Anaya-Allen, Parwatikar); id. at 659:22-660:4 (Anaya-Allen, Parwatikar).

         16. Pinnacle Law also had a bankruptcy and immigration practice. See Transcript of Trial Proceedings at 46:8-11 (taken July 8, 2019)(Murphy), filed July 12, 2019 (Doc. 194)(“July 8 Tr.”); id. at 48:2-3 (Murphy); id. at 115:22-24 (Kennedy, Paul); July 10 Tr. at 676:23-677:3 (Anaya-Allen, Parwatikar).

         17. Mr. Pratt owned Real Estate Law from September, 2011, to September, 2013. See Initial Disclosure of Chad T-W Pratt, Sr., ¶ 1, at 2 (dated August 5, 2018)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 178).

         18. Mr. Pratt was the sole shareholder of Real Estate Law during this time. See Mr. Davis Depo. at 20:16-19.

         19. Pinnacle Law continued providing Real Estate Law consulting services after Mr. Clarambeau left and Mr. Pratt became the owner. See July 10 Tr. at 662:3-5 (Anaya-Allen, Parwatikar).

         20. Mr. Davis assumed ownership of Real Estate Law from Mr. Pratt on September 26, 2013. See Organizational Meeting Minutes and Minutes of Special Meeting at 5-8 (undated)(admitted July 11, 2019, at Trial as New Mexico's Ex. 241).

         21. At a Special Meeting, held on September 26, 2013, at 12:00 p.m., Mr. Pratt surrendered his stock and ownership of Real Estate Law, and Mr. Davis was declared the new Chief Executive Officer, Secretary, and Chief Financial Officer, and Real Estate Law's majority and controlling shareholder. See Organizational Meeting Minutes and Minutes of Special Meeting at 7-8.

         22. Mr. Davis was then Real Estate Law's sole owner and sole corporate member, had a role in overseeing Real Estate Law's operations, and fulfilled all the roles within the corporation. See Mr. Davis Depo. at 19:13-20:2.[3]

         23. Real Estate Law ceased operations around December, 2016, or January, 2017. See July 10 Tr. at 665:16-19.

         a. The General Practices.

         24. Mr. Parwatikar described to one potential employee during an interview that Real Estate Law helped people facing foreclosure. See July 8 Tr. at 85:1-9 (Paul, Anaya-Allen).

         25. Real Estate Law had a foreclosure defense department, a sales department, an accounting department, and a legal department. See Arzakanyan Depo. at 14:21-15:4; id. at 15:9-13.

         26. Real Estate Law clients with foreclosure sale dates had red folders, because those clients were a priority for Real Estate Law to stop the foreclosures. See Arzakanyan Depo. at 115:25-116:9.

         27. Real Estate Law also had a “boiler room full of salesmen” who dictated the cases that Real Estate Law accepted. July 8 Tr. at 32:13 (Murphy). See July 8 Tr. at 32:13-14 (Murphy).

         28. Real Estate Law engaged in mass tort litigation against mortgage lenders. See July 10 Tr. at 689:11-15 (Anaya-Allen, Parwatikar).

         29. Real Estate Law employed bar-certified persons to pursue its litigation. See July 8 Tr. at 21:6 (Murphy)(stating that she is barred); id. at 26:18-22 (Murphy)(stating that she attended a hearing with Mr. Pratt).

         30. Real Estate Law also provided loan modification services. See, e.g., July 10 Tr. at 689:16-19 (Anaya-Allen, Parwatikar).

         31. Real Estate Law obtained clients through advertising; the clients would see an advertisement, call an 800 number, and speak with a salesperson who described Real Estate Law's services. See July 8 Tr. at 89:10-13 (Paul).

         32. Real Estate Law engaged in compliance calls with its clients. See, e.g., July 8 Tr. at 71:13-21 (Murphy); Arzakanyan Depo. at 50:2-8 (stating that a compliance attorney would speak to clients to “make sure they knew what they were signing up for”); July 8 Tr. at 90:15-23 (Paul)(explaining that he would call Real Estate Law consumers to ensure that they “understood what they were singing up for”).

         33. The compliance calls' purpose was to protect Mr. Parwatikar. See July 8 Tr. at 71:13-21 (Murphy).

         34. After speaking with a Real Estate Law salesperson, the caller would be forwarded to a representative for a compliance call, or an appointment would be scheduled for the compliance call. See July 8 Tr. at 89:14-21 (Paul).

         35. During a compliance call, one New Mexico consumer was told to answer the questions “yes” or “no.” Audio Recording of Conversation Between Larry Madrid and Joe Goldberg at 2:30-3:00 (taken October 17, 2012)(admitted July 8, 2019, at Trial as New Mexico's Ex. 36)(“Madrid Compliance Call”).

         36. Mr. Parwatikar instructed one employee to call the clients beforehand and convince them to answer in a way that would not serve their best interest. See July 8 Tr. at 31:16-32:1 (Murphy).

         37. Real Estate Law then received payments from its clients in advance of services provided. See Arzakanyan Depo. at 52:18-24.

         38. Homeowners often paid $5, 000.00 as initial payments to Real Estate Law. See Arzakanyan Depo. at 101:10-13.

         39. When Mr. Davis owned Real Estate Law, he did not permit the marketing staff to make “cold” telephone calls. Arzakanyan Depo. at 25:3-4. See id. at 25:1-5.

         40. Real Estate Law would, however, look for clients with specific lenders. See Arzakanyan Depo. at 118:18-20.

         41. Arzakanyan was the sole owner of YAMG, which contracted with the outside marketing group AD Marketing and with which Real Estate Law contracted, see Arzakanyan Depo. at 56:20-57:12, and Arzakanyan assisted in marketing and spreading Real Estate Law's claims that they could help stop foreclosures, see Arzakanyan Depo. at 53:10-18.

         42. Arzakanyan incorporated YAMG in 2008 and YAMG worked in marketing. See Statement of Information at 353 (dated September 11, 2008)(admitted July 11, 2019, at Trial as New Mexico's Ex. 188); Arzakanyan Depo. at 105:18-23; id. at 106:2-7.

         43. YAMG contracted with and hired different companies to obtain clients for Real Estate Law. See Arzakanyan Depo. at 118:14-17.

         44. AD Marketing contracted with Consumer Credit Marketing and, from October, 2012, through May, 2013, contracted for direct mail on mortgage prospect and loan modification. See Arzakanyan Depo. at 91:10-15; Invoices from Consumer Credit Marketing to AD Marketing Group at 179 to 201 (dated October 26, 2012, October 31, 2012, November 8, 2012, November 27, 2012, December 5, 2012, January 9, 2013, January 17, 2013, January 24, 2013, January 30, 2013, February 7, 2013, February 13, 2013, February 21, 2013, February 28, 2013, March 8, 2013, March 14, 2013, March 22, 2013, March 29, 2013, April 5, 2013, April 12, 2013, May 3, 2013, May 10, 2013, May 15, 2013)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, as New Mexico's Ex. 188)(billing AD Marketing Group for “turn-key direct mail program for mortgage prospect”); Check from Real Estate Law Center, P.C. to Consumer Credit Marketing at 329-330 (dated October 22, 2012)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, as New Mexico's Ex. 188).

         45. YAMG paid AD Marketing to gather client files for YAMG, which YAMG gave to Real Estate Law. See Arzakanyan Depo. at 65:18-23.[4]

         46. Real Estate Law would tell AD Marketing, through Arzakanyan and YAMG, about the banks that Real Estate Law was suing. See Arzakanyan Depo. at 76:4-77:6.

         47. AD Marketing used mailers that included statements like: “Principal Balance Reduction, ” “Going after your Fraudulent Mortgage Note, ” “Interest Rate Reduction, ” “Forgiveness of Past Due Payments, ” “Foreclosure Defense to Help Postpone Sale Dates and Keep You in Your Home, ” and did not include MARS Rule general disclosures.[5] Real Estate Law Mailers at 212, 215, 217, 219, 221, 223, 224, 227, 229, 233, 235, 237, 238, 240, 243, 245, 247, 249, 251, 253 (admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11 2019, as New Mexico's Ex. 188); Arzakanyan Depo. at 64:8; id. at 64:10-14; id. at 65:18-23; id. at 66:8-9.

         48. Arzakanyan and YAMG did not review Real Estate Law mailers to see if the mailers complied with state or federal law. See Arzakanyan Depo. at 65:18-66:10.

         b. The Employees.

         49. Arzakanyan worked for Real Estate Law from 2011 until it closed, see Arzakanyan Depo. at 10:1-2 and worked for Balanced Legal before working for Real Estate Law, see Arzakanyan Depo. at 10:5-6.

         50. Mr. Parwatikar referred Arzakanyan to Real Estate Law when Balanced Legal stopped taking clients. See Arzakanyan Depo. at 11:18-12:1; id. at 9:23-10:6.

         51. Arzakanyan was the general office manager for Real Estate Law. See Arzakanyan Depo. at 14:21-15:4.

         52. Arzakanyan worked under Mr. Clarambeau, Mr. Pratt, and Mr. Davis at Real Estate Law. See Arzakanyan Depo. at 15:17-23.

         53. Arzakanyan worked for Pinnacle Law and Real Estate Law during the same time, and received $8, 250.00 from Pinnacle Law between October and December, 2011, in checks that Mr. Parwatikar signed. See July 10 Tr. at 719:15-721:14; Checks from Pinnacle Law Center, PC to Yervand Arzakanyan at 504-07 (dated October 20, 2011, November 18, 2011, December 9, 2011, December 24, 2011)(admitted July 10, 2019, at Trial as New Mexico's Ex. 234)(“Pinnacle Law to Arzakanyan Checks”).

         54. Ms. Solomon processed a payment from Real Estate Law to Arzakanyan on March 14, 2013, in the amount of $1, 379.01. See Solomon Depo. at 67:9-15; Check from Real Estate Law Center, P.C. to Yervand Arzakanyan at 197-98 (dated March 14, 2013)(admitted as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 146).

         55. Solomon also processed a payment from Real Estate Law to Arzakanyan on March 15, 2013, for $4, 570.00. See Solomon Depo at 68:17-24; Check from Real Estate Law Center, P.C. to Yervand Arzakanyan at 199-200 (dated March 15, 2013)(admitted as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 146).

         56. Sam Branco worked for Balanced Legal, Pinnacle Law, and Real Estate Law. See July 10 Tr. at 640:6-9 (Anaya-Allen, Parwatikar); id. at 653:7-9 (Anaya-Allen, Parwatikar); id. at 652:21-653:3 (Anaya-Allen, Parwatikar).

         57. Mr. Parwatikar recommended that Real Estate Law hire Branco. See July 10 Tr. at 687:14-16 (Anaya-Allen, Parwatikar).

         58. Branco worked for Pinnacle Law doing administrative work, and for Balanced Legal, and for Real Estate Law performing loan modification work, and led Real Estate Law's Foreclosure Defense Department (“FDD”). See Solomon Depo. at 17:11-16; id. at 17:20-18:6; July 10 Tr. at 653:18-23 (Anaya-Allen, Parwatikar); id. at 654:4-6 (Anaya-Allen, Parwatikar); Arzakanyan Depo. at 23:11-18; id. at 23:20-21.

         59. Branco supervised the FDD staff, including intakers, underwriters, and processors. See Arzakanyan Depo. at 23:25-24:5.

         60. Branco communicated with New Mexico consumer Linda Ward using the email address sam@balancedlegalgroup.com and provided her with financial documents for assistance with foreclosure defense. See July 8 Tr. at 169:10-25 (Anaya-Allen, Ward); Email from Linda Ward to Sam Branco at 1 (sent March 7, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 30).

         61. Mr. Parwatikar and Pinnacle Law leased Branco to Real Estate Law so that Branco could have health insurance through Pinnacle Law. See Anthem BlueCross Documents, at Parwatikar 000203-000211 (undated)(admitted July 10, 2019, at Trial as New Mexico's Ex. 233); July 10 Tr. at 655:5-12 (Anaya-Allen, Parwatikar); id. at 657:3-11 (Anaya-Allen, Parwatikar).[6]

         62. Pinnacle Law paid Branco, and Mr. Parwatikar signed checks to Branco from January, 2012, through December, 2013. See July 10 Tr. at 731:9-732:16 (Anaya-Allen, Parwatikar); Checks from Pinnacle Law Center, PC to Sam Branco at 630-77 (dated January 16, 2012, January 31, 2012, February 15, 2012, February 29, 2012, March 15, 2012, April 2, 2012, April 16, 2012, April 30, 2012, May 15, 2012, May 31, 2012, June 15, 2012, July 2, 2012, July 16, 2012, July 31, 2012, August 15, 2012, August 30, 2012, September 17, 2012, October 1, 2012, October 15, 2012, October 31, 2012, November 15, 2012, November 29, 2012, December 17, 2012, January 2, 2013, January 15, 2013, January 31, 2013, February 14, 2013, February 28, 2013, March 14, 2013, April 1, 2013, April 15, 2013, April 30, 2013, May 15, 2013, May 31, 2013, June 17, 2013, July 1, 2013, July 15, 2013, July 31, 2013, August 15, 2013, September 16, 2013, September 27, 2013, October 15, 2013, October 29, 2013, November 15, 2013, December 2, 2013, December 16, 2013, December 31, 2013, and January 15, 2014)(admitted July 10, 2019, at Trial as New Mexico's Ex. 237)(“Pinnacle Law to Branco Checks”).

         63. Pinnacle Law issued Branco a check on October 1, 2012, for $1, 914.79, because Branco worked for Pinnacle Law by handling administrative tasks. See Solomon Depo. at 94:12-19; Check from Pinnacle Law Center, PC to Sam Branco at 235 (dated October 1, 2012)(admitted as to Real Estate Law, Mr. Davis, and Mr. Pratt on July 11, 2019, at Trial as New Mexico's Ex. 146).

         64. Real Estate Law also paid Branco an “FDD December 2013 bonus” in a check that Arzakanyan signed on December 31, 2013. July 10 Tr. at 732:18-733:6 (Anaya-Allen, Parwatikar); Check from Pinnacle Law Center, PC to Sam Branco, at 678 (dated December 31, 2018)(admitted July 10, 2019, at Trial as New Mexico's Ex. 238)(“Dec. 31, 2018 Check from Pinnacle Law Center, PC to Sam Branco”).

         65. Pinnacle Law issued Branco a Form 1099 for 2017. See July 4 Tr. at 768:15-17 (Anaya-Allen, Parwatikar); 1099 from Pinnacle Law Center PC to Sam Branco (dated 2017)(admitted July 10, 2019, at Trial as New Mexico's Ex. 175).

         66. Angelina Solomon worked for Balanced Legal, for Pinnacle Law, and for Real Estate Law. See July 10 Tr. at 640:12-15 (Anaya-Allen, Parwatikar); id. at 658:22-659:8 (Anaya-Allen, Parwatikar); id. at 658:11-13 (Anaya-Allen, Parwatikar); July 8 Tr. at 50:17-51:6 (Anaya-Allen, Parwatikar).

         67. Solomon worked for Pinnacle Law for seven years and, before that, worked for Balanced Legal for five to six years. See Solomon Depo. at 8:9-14.

         68. Solomon began working for Real Estate Law after Mr. Parwatikar asked if Solomon was interested in doing so and if she had time to do Real Estate Law's daily booking. See Solomon Depo. at 42:1-4.

         69. Solomon handled bookkeeping for Balanced Legal, Pinnacle Law, and Real Estate Law. See Solomon Depo. at 10:17-19; id. at 10:25-11:7.

         70. Solomon worked with Arzakanyan at Balanced Legal and at Real Estate Law. See Solomon Depo. at 16:14-25.

         71. Solomon received a check for $41.12 from Real Estate Law dated November 30, 2012. See Solomon Depo. at 79:16-19; Check from Real Estate Law Center, P.C. to Angeline Solomon at 217-18 (dated November 30, 2012)(admitted as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 146).

         72. Solomon received a check, which Mr. Pratt signed, from Real Estate Law dated March 14, 2013, for $1, 580.61. See Check from Real Estate Law Center, P.C., to Angeline Solomon at 221 (dated March 14, 2013)(admitted as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 146); Solomon Depo. at 81:5-9.

         73. Mr. Davis received a check from Real Estate Law for $1, 491.01 dated July 1, 2013. See Check from Real Estate Law Center, P.C. to Erikson Davis at 232 (dated July 1, 2013)(admitted as to Real Estate Law, Mr. Davis, and Mr. Pratt on July 11, 2019, at Trial as New Mexico's Ex. 146).

         74. Real Estate Law's 2013 telephone list includes entries for Pinnacle Law Center employees Deepak Parwatikar and Paige Knickerbocker. See July 11 Tr. at 764:2-15 (Anaya-Allen, Parwatikar); Real Estate Law, P.C., Contact List at 26 (dated 2013)(admitted July 10, 2019, at Trial as New Mexico's Exhibit 240).

         75. Another of Real Estate Law's telephone lists included entries for Pinnacle Law Center, Parwatikar, Solomon, and Knickerbocker. See July 11 Tr. at 825:12-827:19 (Anaya-Allen, Parwatikar, Court, Kennedy); Real Estate Law Center, P.C., Contact List at 9-10 (undated)(admitted July 11, 2019, at Trial as New Mexico's Ex. 243).

         76. Mr. Clarambeau, Arzakanyan, and Branco are on a list of employees that includes Balanced Legal and Real Estate Law staff, and Mr. Clarambeau, Arzakanyan, and Branco have emails ending in balancedlegalgroup.com. See Solomon Depo. at 34:2-6; id. at 35:24-36:2; id. at 36:13-14; id. at 38:7-16; id. at 39:4-10; Spreadsheet of Balanced Legal Employees at 177-80 (undated)(admitted as to Real Estate Law, Mr. Davis, and Mr. Pratt on July 11, 2019, at Trial as New Mexico's Ex. 146).

         77. Mr. Parwatikar assigned Pinnacle Law attorneys to Real Estate Law cases. See July 8 Tr. at 39:12-23 (Anaya-Allen, Murphy); April 19 Email at 1.

         78. Knickerbocker, for instance, a Pinnacle Law employee, handled Real Estate Law cases: “Paige is not to be assigned litigation materials unless approval from me obtained in advance.” April 4 Email at 2. See July 10 Tr. at 700:20-701:2 (Anaya-Allen, Parwatikar).

         c. The Money Pinnacle Law Received.

         79. Pinnacle Law invoice Real Estate Law. See, e.g., July 11 Tr. at 797:6-18 (Kennedy, Parwatikar); Pinnacle Law Center, P.C., to Real Estate Law Center, P.C., Invoices at 1 (dated September 29, 2011, October 28, 2011, November 30, 2011, December 30, 2011, January 31, 2012, February 29, 201, March 30, 2012, April 27, 2012, May 13, 2012, June 29, 2012, July 31, 2012, August 31, 2012, September 28, 2012, October 31, 2012, November 30, 2012, December 31, 2012, January 30, 2013, February 28, 2013, March 29, 2013, April 29, 2013, May 30, 2013, June 28, 2013, July 31, 2013, August 30, 2013, September 30, 2013, October 31, 2013, November 29, 2013, and December 31, 2013)(admitted July 10, 2019, at Trial as New Mexico's Ex. 171)(“Pinnacle Law to Real Estate Law Invoices”).[7]

         80. Pinnacle Law invoiced Real Estate Law for $200, 000.00 for engagement fees and $100, 000.00 for consulting fees in 2011. See Pinnacle Law to Real Estate Law Invoices at 1-5.

         81. Pinnacle Law invoiced, for instance, Real Estate Law for September, 2011, for an engagement fee of $50, 000.00 and a consulting fee of $25, 000.00. See July 10 Tr. at 667:23-668:2 (Anaya-Allen, Parwatikar); Pinnacle Law to Real Estate Law Invoices at 1.

         82. Real Estate Law paid Pinnacle Law $141, 500.00 in 2012. See July 10 Tr. at 664:23-25 (Anaya-Allen, Parwatikar).

         83. Pinnacle Law invoiced Real Estate Law for $295, 000.00 for engagement fees, $300, 000.00 in consulting fees, and $202, 500.00 in additional hourly fees for 2012. See Pinnacle Law to Real Estate Law Invoices at 6-16.

         84. In 2012, Pinnacle Law invoiced Real Estate Law for $797, 500.00, and reported receiving $141, 500.00 from Real Estate Law, and Pinnacle Law's federal tax returns show gross receipts of $480, 534.00.[8] See Pinnacle Law to Real Estate Law Invoices at 6-16; July 10 Tr. at 677:8-11 (Anaya-Allen, Parwatikar); Pinnacle Law Tax Documents at 6 (transmission of copies to Pinnacle Law dated March 6, 2018, September 15, 2016, and undated)(admitted July 10, 2019, at Trial as New Mexico's Ex. 172).

         85. On its 2012 tax return, Pinnacle Law deducted $34, 223.00 for promotion. See July 10 Tr. at 753:10-16 (Anaya-Allen, Parwatikar); 2012 Pinnacle Law Tax Documents at 13.

         86. Real Estate Law paid Pinnacle Law $1, 029, 520.54 in 2013. See July 10 Tr. at 665:1-3 (Anaya-Allen, Parwatikar).

         87. Pinnacle Law invoiced Real Estate Law for $485, 000.00 for engagement fees, $300, 000.00 in consulting fees, and $215, 250.00 in additional hourly fees for 2013. See Pinnacle Law to Real Estate Law Invoices at 17-28.

         88. In 2013, Pinnacle invoiced Real Estate Law $1, 000, 250.00 and reported receiving $1, 029, 520.00 from Real Estate Law, and its federal tax return show total gross receipts of $1, 081, 349.00. See Pinnacle Law to Real Estate Law Invoices at 17-28; Pinnacle Law Tax Documents at 33; July 10 Tr. at 678:11-20 (Anaya-Allen, Parwatikar).

         89. On its 2013 tax return, Pinnacle Law deducted $263, 454.00 for marketing and $39, 804.00 for promotion. See July 10 Tr. at 754:17-25(Anaya-Allen, Parwatikar); Pinnacle Law Tax Documents at 40.

         90. Real Estate Law paid Pinnacle Law $746, 720.33 in 2014. See July 10 Tr. at 665:5-6 (Anaya-Allen, Parwatikar).

         91. Pinnacle Law did not provide New Mexico with any invoices to Real Estate Law for the period after December, 2013. See July 10 Tr. at 673:18-21 (Anaya-Allen, Parwatikar).

         92. In 2014, Pinnacle Law received from Real Estate Law $746, 720.33, and Pinnacle Law's tax returns show gross receipts of $858, 152.00. See Pinnacle Law Tax Documents at 62; July 10 Tr. at 680:25-681:3 (Anaya-Allen, Parwatikar).

         93. In 2014, Pinnacle Law had $187, 800.00 in deductions for marketing and promotion. See July 11 Tr. at 764:22-765:12 (Anaya-Allen, Parwatikar); Pinnacle Law Tax Documents at 62, 68.

         94. Real Estate Law paid Pinnacle Law $787, 573.53 in 2015. See July 10 Tr. at 665:7-9 (Anaya-Allen, Parwatikar).

         95. In 2015, Pinnacle Law received $787, 573.53 from Real Estate Law, and Pinnacle Law's federal tax return shows gross receipts of $702, 250.00. See Pinnacle Law Tax Documents at 87; July 10 Tr. at 681:13-682:4 (Anaya-Allen, Parwatikar).

         96. On Pinnacle Law's 2015 tax return, Pinnacle Law had a deduction for marketing of $72, 500.00 and for promotion of $37, 500.00. See July 10 Tr. at 748:18-749:17 (Anaya-Allen, Parwatikar); Pinnacle Law Tax Documents at 93.

         97. Real Estate Law paid Pinnacle Law $368, 609.21 in 2016. See July 10 Tr. at 665:10-12 (Anaya-Allen, Parwatikar).

         98. In 2016, Pinnacle Law received $368, 609.21 from Real Estate Law, and Pinnacle Law's federal tax return for 2016 shows gross receipts of $452, 516.00. See Pinnacle Law Tax Documents at 111; July 10 Tr. at 682:18-683:2 (Anaya-Allen, Parwatikar).

         99. Real Estate Law paid Pinnacle Law $13, 125.00 in 2017. See July 10 Tr. at 665:20-22 (Anaya-Allen, Parwatikar).

         100. Pinnacle Law had gross receipts of $452, 516.00 in 2016 and had deductions for marketing totaling $44, 446.00. See July 10 Tr. at 765:13-23 (Anaya-Allen, Parwatikar); Pinnacle Law Tax Documents at 111, 120.

         101. Pinnacle Law had $679, 727.00 in tax deductions for marketing and promotion expenses from 2012 to 2016. See July 11 Tr. at 778:1-14 (Kennedy, Parwatikar); July 10 Tr. at 748:18-20 (Anaya-Allen, Parwatikar); id. at 749:8-17 (Anaya-Allen, Parwatikar); id. at 753:1016 (Anaya-Allen, Parwatikar); id. at 754:17-25 (Anaya-Allen, Parwatikar); July 11 Tr. at 765:8-12, 19-23 (Anaya-Allen, Parwatikar).

         102. Pinnacle Law received $3, 087, 048.61 in total from Real Estate Law from 2012 through 2016.

         d. The Payment Practices.

         103. When issuing invoices and writing checks, Solomon would prepare invoices for Pinnacle Law and give the invoice to Mr. Parwatikar, and Mr. Parwatikar would give the invoice to Mr. Davis or to Mr. Pratt, who would tell Solomon to pay the invoice on Real Estate Law's behalf. See Solomon Depo. at 103:14-104:1; id. at 108:2-5.

         104. Solomon tried, but could not, reconcile the Pinnacle Law invoices and the Real Estate Law payments to Pinnacle Law. See Solomon Depo. at 109:23-110:9.

         105. Mr. Davis would sometimes instruct Solomon to pay Pinnacle Law without an invoice. See Solomon Depo. at 108:8-20.

         106. Real Estate Law would make payments to contractors without invoices or tracking, see Solomon Depo. at 27:3-7; id. at 27:17-18; id. at 28:21-24, and Real Estate Law would likewise make payments outside payroll, based on Mr. Davis' reports, and, for instance, paid Branco in December, 2015, $880.00, see Solomon Depo. at 28:3-12; U.S. Bank Documents at 160 (undated)(admitted as to Real Estate Law, Mr. Davis, and Mr. Pratt on July 11, 2019, at Trial as New Mexico's Ex. 146).

         107. Mr. Parwatikar would also at times remind Arzakanyan to write him a check from Real Estate Law. See Arzakanyan Depo. at 88:2-11.

         108. Real Estate Law regularly made payments to Pinnacle Law through checks that Arzakanyan signed, and that Pinnacle Law received and negotiated, including on: October 5, 2011, for $9, 695.00; October 12, 2011, for $12, 000.00; October 20, 2011, for $9, 000.00; October 31, 2011, for $5, 000.00; November 7, 2011, for $6, 000.00; November 14, 2011, for $10, 000.00; November 18, 2011, for $5, 000.00[9]; November 30, 2011, for $7, 000.00; December 9, 2011, for $12, 000.00; January 9, 2012, for $7, 500.00; January 16, 2012, for $6, 000.00; January 30, 2012, for $7, 500.00; February 9, 2012, for $8, 000.00; February 13, 2012, for $10, 000.00; February 16, 2012, for $7, 000.00; February 21, 2012, for $3, 000.00; March 9, 2012, for $6, 755.00; March 13, 2012, for $10, 000.00; March 21, 2012, for $2, 000.00; March 23, 2012, for $7, 500.00; March 27, 2012, for $4, 000.00; April 9, 2012, for $15, 000.00; April 18, 2012, for $5, 000.00[10]; April 29, 2012, for $17, 000.00; May 1, 2012, for $12, 000.00; May 13, 2012, for $12, 000.00; May 31, 2012, for $10, 000.00; June 13, 2012, for $10, 000.00; June 15, 2012, for $3, 000.00; October 1, 2013, for $2, 000.00; November 4, 2013, for $2, 000.00; December 3, 2013, for $2, 000.00. See July 10 Tr. at 725:19-730:19 (Anaya-Allen, Parwatikar); Real Estate Law to Pinnacle Law Checks at 546-72, 610-12 (dated December 11, 2013, October 5, 2011, October 12, 2011, October 20, 2011, October 31, 2011, November 7, 2011, November 14, 2011, November 18, 2011, November 30, 2011, December 9, 2011, January 9, 2012, January 16, 1012, January 30, 2012, February 9, 2012, February 23, 2012, February 16, 2012, February 21, 2012, March 9, 2012, March 13, 2012, March 21, 2012, March 23, 2012, March 27, 2012, April 9, 2012, April 18, 2012, April 23, 2012, May 1, 2012, May 13, 2012, May 31, 2012, June 13, 2012, June 15, 2012, June 28, 2012, July 12, 2012, July 16, 2012, July 26, 2012, August 8, 2012, August 14, 2012, August 27, 2012, September 6, 2012, September 24, 2012, October 1, 2012, October 3, 2012, October 15, 2012, October 31, 2012, November 8, 2012, November 14, 2012, November 30, 2012, December 13, 2012, December 17, 2012, December 28, 2012, January 15, 2013, February 1, 2013, February 15, 2013, March 22, 2013, March 26, 2013, April 1, 2013, April 30, 2013, June 24, 2013, July 31, 2013, August 14, 2013, August 30, 2013, October 1, 2013, November 4, 2013, and December 3, 2013)(admitted July 10, 2019, at Trial as New Mexico's Ex. 236). See also Arzakanyan Depo. at 101:4-8 (discussing January 30, 2012, check); Check from Real Estate Law Center, P.C. to Pinnacle Law Center P.C. at 345-46 (dated January 30, 2012)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt on July 11, 2019, as New Mexico's Ex. 188); Arzakanyan Depo. at 102:23-103:5 (discussing February 9, 2012, check); Check from Real Estate Law Center, P.C. to Pinnacle Law Center P.C. at 347-48 (dated February 9, 2012)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt on July 11 2019, as New Mexico's Ex. 188); Arzakanyan Depo. at 103:19-104:4 (discussing February 16, 2012, check); Check from Real Estate Law Center, P.C. to Pinnacle Law Center P.C. at 349-50 (dated February 9, 2012)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt on July 11, 2019, as New Mexico's Ex. 188).

         109. Between October, 2011, and June, 2012, Arzakanyan wrote on Real Estate Law's behalf twenty-nine checks to Pinnacle Law that totalled $240, 950.000. See Exhibits to Deposition of Deepak S. Parwatikar (taken May 9, 2018), Checks from Real Estate Law Center, P.C. to Pinnacle Law Center at 546-612.

         110. On February 23, 2012, for instance, Real Estate Law paid Pinnacle Law $10, 000.00 via a check that Arzakanyan signed, see Arzakanyan Depo. at 87:15-17; Check from Real Estate Law to Pinnacle Law Center at 319-20 (dated February 23, 2012)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt on July 11 2019, as New Mexico's Ex. 188), and on February 5, 2013, Arzakanyan handwrote a check to Pinnacle Law on behalf of Real Estate Law for $10, 000.00, see Arzakanyan Depo. at 100:3-6; Check from Real Estate Law Center, P.C. to Pinnacle Law Center P.C. at 341-42 (dated February 5, 2013)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt on July 11, 2019, as New Mexico's Ex. 188).

         111. Real Estate Law provided Pinnacle Law a check for $4, 000.00 on September 24, 2012. See Solomon Depo. at 102:8-103:2; Check from Real Estate Law Center, P.C. to Pinnacle Law Center P.C. at 243 (dated September 24, 2012)(admitted as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 146).

         112. Starting May 31, 2012, Mr. Pratt started signing checks to Pinnacle Law, and these checks include: May 31, 2012, for $10, 000.00; June 13, 2012, for $10, 000.00; June 15, 2012, for $3, 000.00; June 28, 2012, for $10, 000.00; July 12, 2012, for $10, 000.00; July 16, 2012, for $4, 000.00; July 26, 2012, for $4, 000.00; August 8, 2012, for $10, 000.00; August 14, 2012, for $7, 000.00; August 27, 2012, for $10, 000.00; September 6, 2012, for $10, 000.00; September 24, 2012, for $4, 000.00; October 1, 2012, for $14, 000.00; October 3, 2012, for $2, 000.00; October 3, 2012, for $2, 000.00; October 15, 2012, for $5, 000.00; October 31, 2012, for $18, 000.00; November 8, 2012, for $2, 000.00; November 8, 2012, for $8, 000.00; November 14, 2012, for $15, 000.00; November 30, 2012, for $15, 000.00; December 13, 2012, for $5, 000.00; December 17, 2012, for $13, 000.00; December 17, 2012, for $2, 000.00; December 28, 2012, for $18, 000.00; January 15, 2013, for $12, 500; February 1, 2013, for $5, 000.00; February 15, 2013, for $10, 000.00; March 22, 2013, for $20, 000.00; March 26, 2013, for $2, 000.00; April 1, 2013, for $2, 000.00; April 30, 2013, for $1, 000.00; June 24, 2013, for $2, 000.00; June 24, 2013, for $1, 000.00; July 31, 2013, for $2, 000.00; August 14, 2013, for $1, 995; August 30, 2013, for $2, 000.00 See July 10 Tr. at 730:20-731:3 (Anaya-Allen, Parwatikar); Real Estate Law to Pinnacle Law Checks at 573-609.

         113. Pinnacle Law also issued Balanced Legal checks in September through December, 2011. See July 10 Tr. at 733:16-736:1 (Anaya-Allen, Parwatikar); Exhibits to Deposition of Deepak S. Parwatikar (taken May 9, 2018), Checks from Pinnacle Law Center, PC to Balanced Legal Group at 679-85 (dated September 30, 2011, October 4, 2011, October 6, 2011, October 11, 2011, October 14, 2011, October 17, 2011, and December 21, 2011)(admitted July 10, 2019, at Trial as New Mexico's Ex. 239)(“Pinnacle Law to Balanced Legal Checks”).

         114. After Real Estate Law settled a case with the Brysons, see July 11 Tr. at 766:8-15 (Anaya-Allen, Parwatikar), both Solomon and YAMG made payments on Real Estate Law's behalf, see July 11 Tr. at 766:21-767:6 (Anaya-Allen, Parwatikar); Solomon Depo. at 49:2-19; Arzakanyan Depo. at 94:22-95:5.

         115. Solomon made, for instance, payments on the Bryson settlement using a Pinnacle Law Center envelope and postage account in May, 2017. See July 11 Tr. at 766:21-767:6 (Anaya-Allen, Parwatikar); Solomon Depo. at 48:18-49:11; Mr. Davis, and Mr. Pratt, Checks from Angelina T. Solomon to Law Offices of Walker & Mann LLP Atty Client Trust Acct at 187-190 (dated May 12, 2017, April 14, 2017, March 14, 2017, and February 13, 2017)(admitted as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 146).

         116. Mr. Davis would deposit funds in Solomon's bank account and send her a text message about the deposit, and she would purchase the cashier's checks for the settlement payments. See Solomon Depo. at 50:1-51:6; id. at 51:13-52:10.

         117. Solomon would mail the payments from Pinnacle Law's office. See Solomon Depo. at 57:8-11.

         118. Solomon made three settlement payments for Mr. Davis to the Law Offices of Walker & Mann in amounts of $1, 944.45 on May 12, 2017; $1, 944.45 on April 14, 2017; and $2, 500.00 on March 14, 2017. See Solomon Depo. at 48:23-49:4, Cashier's Checks Purchased by Angelina T. Solomon to Law Offices of Walker & Mann LLP Atty Client Trust Acct at 187-89 (dated May 12, 2017, April 14, 2017, March 14, 2017)(admitted as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, as New Mexico's Ex. 146).

         119. Mr. Parwatikar knew of the settlement and of Solomon's payments. See July 11 Tr. at 766:8-15 (Anaya-Allen, Parwatikar); Solomon Depo. at 63:6-12 (reflecting that Mr. Parwatikar asked Solomon about the payments).[11]

         120. YAMG purchased a cashier's check in the amount of $5, 000.00 payable to the Law Office of Walker & Mann LLP for Real Estate Law on February 13, 2017, on Mr. Davis' behalf. See Arzakanyan Depo. at 94:22-95:5; Cashier's Check Purchased by YAMG at 338 (dated February 13, 2017)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, as New Mexico's Ex. 188).

         121. YAMG purchased the cashier's check on Mr. Davis' behalf. See Arzakanyan Depo. at 94:22-95:5; Cashier's Check Purchased by YAMG at 338.

         e. The Workplace.

         122. Real Estate Law was located in Costa Mesa, California, when it was incorporated. See July 10 Tr. at 645:21-24 (Anaya-Allen, Parwatikar).

         123. Real Estate Law then moved to Pasadena, California, and was located in Pasadena and in Pinnacle Law's building when Mr. Pratt owned it. See Arzakanyan Depo. at 18:9-10; July 11 Tr. at 786:8-13 (Kennedy, Parwatikar).

         124. Real Estate Law shared office space with Pinnacle Law. See July 10 Tr. at 662:19-663:4 (Anaya-Allen, Parwatikar); July 8 Tr. at 45:4-13 (Murphy).

         125. Real Estate Law used office space in Suite 1100, the same as Pinnacle Law's suite, and in Suite 1320, another suite, at 695 S. Vermont Ave., Los Angeles, California, where Pinnacle Law was located from 2012 to 2016. See Solomon Depo. at 72:24-73:7; id. at 113:9-18; id. at 113:23-114:3; July 11 Tr. at 786:8-22 (Kennedy, Parwatikar); Sublease of Office Space at 1 (dated November 1, 2011)(admitted July 11, 2019, at Trial as the Parwatikar Defendant's Ex. A).

         126. Real Estate Law and Pinnacle Law used different computer systems. See Solomon Depo. at 12:4-15.

         127. Pinnacle Law's and Real Estate Law's suite had a suite number and had no law firm name at the suite entrance. See July 8 Tr. at 24:23-25:4 (Murphy).

         128. Real Estate Law's attorneys were licensed only in California. See, e.g., Attorney-Client Fee Agreement ¶ 2, at 1 (executed August 9, 2012)(admitted July 8, 2019, at Trial as New Mexico's Ex. 20)(“Ward Attorney-Client Fee Agreement”); Attorney-Client Fee Agreement ¶ 2, at 1 (executed October 16, 2012, October 28, 2012)(admitted July 8, 2019, at Trial as New Mexico's Exhibit 37)(“Madrid Attorney-Client Fee Agreement”).

         129. Balanced Legal used Captaloans -- a data management system[12] -- for its client database, and Real Estate Law used the same system for the same purpose. See July 10 Tr. at 691:3-15 (Anaya-Allen, Parwatikar); Solomon Depo. at 31:24-32:8.

         130. Pinnacle Law replaced its computer system in 2018. See July 11 Tr. at 770:13-771:3 (Anaya-Allen, Parwatikar).

         f. The Workplace Roles of Mr. Davis and Mr. Pratt.

         131. Mr. Pratt operated Real Estate Law before Mr. Davis. See Arzakanyan Depo. at 15:19; id. at 92:24-93:3.[13]

         132. Mr. Pratt alone gave Solomon instructions about payments while he ran Real Estate Law. See Solomon Depo. at 71:17-20.[14]

         133. Solomon received instructions from Mr. Pratt and from Mr. Davis when she worked with them in Real Estate Law. See Solomon Depo. at 68:16-22.

         134. Mr. Davis was the sole shareholder after he became sole owner, and no one else has held corporate positions of power within Real Estate Law. See Mr. Davis Depo. at 20:8-11.[15]

         135. Mr. Davis was the senior lawyer at Real Estate Law, and he supervised the junior lawyers. See Mr. Davis Depo. at 56:20-57:3.

         136. Mr. Davis was the signatory on Real Estate Law's client trust account, and payments required his approval. See Mr. Davis Depo. at 35:6-13.

         137. Mr. Davis signed retainer agreements during his time as Real Estate Law's owner and a principal of the firm, and no one else at Real Estate Law was authorized to sign such agreements. See Deposition of Erikson Davis at 7:22-8:1 (taken October 24, 2016)(admitted July 11, 2019, at Trial as the Parwatikar Defendants' Ex. G); id. at 13:19-23.

         138. Mr. Davis worked with Arzakanyan and Solomon when clients wanted to cancel services and/or to obtain refunds. See Arzakanyan Depo. at 26:19-23; Solomon Depo. at 33:16-17.

         139. Mr. Davis provided Arzakanyan information on Real Estate Law's services. See Arzakanyan Depo. at 54:22-55:3.

         140. Real Estate Law had a bank account with U.S. Bank, and Mr. Davis was usually paid $11, 925.00 per month. See Solomon Depo. at 23:10-11; id. at 25:14-15; id. at 26:1-12; U.S. Bank Documents at 158 (admitted as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 146).

         g. Mr. Parwatikar's Workplace Role.

         141. Mr. Parwatikar had effective control of and ran Real Estate Law. See July 8 Tr. at 26:3-4 (Murphy); July 8 Tr. at 93:15-19 (Anaya-Allen, Paul); id. at 96:2-10 (Paul); id. at 101:18-19 (Anaya-Allen, Paul).[16]

         142. Mr. Parwatikar was at the Real Estate Law and the Pinnacle Law office every day. See July 8 Tr. at 25:14-16 (Murphy); id. at 96:7-8 (Paul).

         143. Mr. Parwatikar wanted the Real Estate Law staff to act as if he were not involved in running Real Estate Law, see July 8 Tr. at 57:22-233 (Murphy), such that, for instance, Mr. Pratt was the “public face of” Real Estate Law, July 8 Tr. at 94:2 (Paul).

         144. Mr. Parwatikar interviewed, however, Mr. Pratt when he was going to take over ownership of Real Estate Law. See July 10 Tr. at 674:7-10 (Anaya-Allen, Parwatikar).

         145. Mr. Parwatikar participated in Mr. Davis' hiring interview as an attorney. See July 11 Tr. at 822:18-823:3 (Anaya-Allen, Parwatikar).

         146. “Mr. Davis was hired because he was already -- . . . when he came on as an attorney . . . . But not as the owner.” July 11 Tr. at 62:21-23 (Parwatikar).

         147. Mr. Parwatikar had, therefore, a role in Mr. Davis' appointment to Real Estate Law's ownership. See July 11 Tr. at 62:21-23 (Parwatikar).

         148. Before the transition between Mr. Davis and Mr. Pratt, Mr. Parwatikar told Solomon that Mr. Pratt would leave and that Mr. Davis would take over Real Estate Law. See Solomon Depo. at 89:24-90:2.

         149. Parwatikar, on Pinnacle Law's behalf, entered a consulting agreement with Real Estate Law and Mr. Davis on September 26, 2013. See July 10 Tr. at 674:23-675:5 (Anaya-Allen, Parwatikar); Consulting Agreement at 1-4 (executed September 26, 2013)(admitted July 10, 2019, at Trial as New Mexico's Ex. 170 and admitted July 11, 2019, at Trial as Parwatikar's, Balanced Legal's, and Pinnacle Law's Ex. B); July 11 Tr. at 820:25-821:4 (Anaya-Allen, Parwatikar).

         150. Real Estate Law and Pinnacle Law's Consulting Agreement provides for a monthly fee of $25, 000.00 plus $1, 500.00 per hour for hours over 40 hours a month and includes a provision that the total monthly fees not exceed eighty percent of Real Estate Law's monthly revenues. See July 10 Tr. at 675:6-18 (Anaya-Allen, Parwatikar); Consulting Agreement at 2.

         151. Mr. Parwatikar did not have a consulting agreement with Mr. Pratt.[17]

         152. Pinnacle Law provided Real Estate Law, under both Mr. Davis and Mr. Pratt, consulting services on human resources, including hiring, staffing, advertising, and interviewing job candidates, see July 10 Tr. at 663:11-20 (Anaya-Allen, Parwatikar); id. at 685:12-686:3 (Anaya-Allen, Parwatikar), and on marketing, and advised Mr. Pratt and Mr. Davis about outreach strategies, see July 10 Tr. at 683:14-684:11 (Anaya-Allen, Parwatikar). See also July 10 Tr. at 686:4-17 (Anaya-Allen, Parwatikar); id. at 686:18-687:6 (Anaya-Allen, Parwatikar); id. at 739:12-19 (Anaya-Allen, Parwatikar).

         153. Mr. Parwatikar did not perform marketing for Real Estate Law, but consulted with Real Estate Law's owners. See July 11 Tr. at 781:18-23 (Kennedy, Parwatikar).

         154. Pinnacle Law and Mr. Parwatikar were not directly involved in referring clients to Real Estate Law. See July 11 Tr. at 802:10-13 (Kennedy, Parwatikar).[18]

         155. Mr. Parwatikar worked “hand in hand” with Real Estate Law, July 11 Tr. at 781:25 (Parwatikar); id. at 782:3 (Parwatikar). See id. at 782:1-4 (Parwatikar), and met daily with Mr. Pratt and Mr. Davis, id. at 791:23-25 (Parwatikar).

         156. “Anything that could advance the business because the more business got advanced, the more [Mr. Parwatikar] could charge consulting fees and make money.” July 11 Tr. at 686:14-17 (Parwatikar).

         157. Pinnacle Law did not pay for marketing or promotional programs. See July 10 Tr. at 696:1-4 (Anaya-Allen, Parwatikar); July 11 Tr. at 773:23-25 (Anaya-Allen, Parwatikar).[19]

         158. Mr. Parwatikar also did not immediately control Real Estate Law's accounts or money. See July 11 Tr. at 811:7-12 (Kennedy, Parwatikar); Mr. Davis Depo. at 34:6-13; Solomon Depo. at 33:16-17.[20]

         159. Mr. Parwatikar interviewed, for instance, potential candidates for Real Estate Law with Mr. Pratt. See July 10 Tr. at 663:17-20 (Parwatikar).

         160. Mr. Parwatikar interviewed Susan Murphy with Mr. Clarambeau for a job at Real Estate Law. See July 10 Tr. at 697:15-17 (Anaya-Allen, Parwatikar); July 8 Tr. at 22:1-2 (Murphy).

         161. Mr. Pratt and Mr. Parwatikar interviewed Ms. Murphy when Real Estate Law hired her. See July 8 Tr. at 22:4-7 (Murphy).

         162. Mr. Parwatikar spoke on the telephone to and corresponded with Ms. Murphy about her hiring and start dates. See July 8 Tr. at 23:17-22 (Anaya-Allen, Murphy).

         163. Mr. Parwatikar participated in interviewing Michael Paul for a job at Real Estate Law. See July 10 Tr. at 700:3-8 (Anaya-Allen, Parwatikar); Email from Deepak Parwatikar to Susan Murphy at 1 (sent February 20, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 4)(“Feb. 20 Email”); July 8 Tr. at 85:1-9 (Paul, Anaya-Allen).

         164. Mr. Parwatikar was Ms. Murphy's boss at Real Estate Law; he assigned files on which she should work, brought files to her desk, directed her on the case the client had, and told her how to dress. See July 8 Tr. at 25:17-26:4 (Parwatikar, Murphy); Email from Deepak Parwatikar to Susan Murphy at 1 (sent February 14, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 3)(“Feb. 14 Email”); Feb. 20 Email at 1; Email from Deepak Parwatikar to Susan Murphy at 1-2 (sent February 25, 2013)(admitted July 8, 2019, at Trial as New Mexico's Trial Exhibit 5); April 5 Email at 1-2; Email from Deepak Parwatikar to Susan Murphy at 1 (sent April 19, 2013)(admitted July 8, 2019, at Trial as New Mexico's Exhibit 7.

         165. Mr. Parwatikar was Mr. Paul's boss at Real Estate Law. See July 8 Tr. at 96:2-10 (Paul); id. at 101:9-17 (Paul); Email from Deepak Parwatikar to Michael Paul at 1 (sent December 14, 2012)(admitted July 8, 2019, at Trial as New Mexico's Ex. 15).

         166. Mr. Parwatikar regularly supervised Ms. Murphy's work and gave her instructions on cases, including settlement. See July 8 Tr. at 28:17-29:3 (Anaya-Allen, Murphy); Email from Deepak Parwatikar to Susan Murphy at 1 (sent February 13, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 2)(“Feb. 13 Email”); April 5 Email at 1-2.

         167. Mr. Parwatikar emailed Ms. Murphy an instruction about working with opposing counsel on a loan modification. See July 10 Tr. at 697:23-698:2 (Anaya-Allen, Parwatikar); Feb. 13 Email at 1.

         168. Mr. Parwatikar emailed Ms. Murphy directing her on communicating with clients and telling her to consult with him before recommending legal action other than a mass joinder case to a Real Estate Law client. See Feb. 14 Email at 3; July 10 Tr. at 698:3-14 (Anaya-Allen, Parwatikar); July 8 Tr. at 30:9-24 (Murphy, Anaya-Allen).

         169. Real Estate Law staff sent weekly case updates on Real Estate Law clients to Mr. Parwatikar's email, deepak@pinnaclelawcenter.com, and Ms. Murphy was supposed to send such weekly Real Estate Law case updates to Mr. Parwatikar. See July 8 Tr. at 36:5-6 (Murphy); id. at 36:9-19 (Murphy); Feb. 20 Email at 1; Feb. 25 Email at 1-2.

         170. Mr. Parwatikar sent Real Estate Law staff, including Ms. Murphy, an email thanking them for keeping up with weekly case updates and asking that they copy “Christine” on future such emails. Feb. 20 Email at 1. See July 10 Tr. at 698:22-699:14 (Anaya-Allen, Parwatikar).

         171. Mr. Parwatikar sent an email to Real Estate Law staff, including Ms. Murphy and Mr. Paul, on April 4, 2013, in which he summarized an attorney meeting that the Real Estate Law staff held and summarized several directives that reflect his role in managing Real Estate Law:

All individual clients contacted every 3 weeks at least by atty assigned.
Cutoffs established for HSBC mass for Tala and CITI mass Marilyn. Deadlines for clients to be included on initial complaint is April 18. I am not sure if drop dead filing date. Can we make that April 30? Please advise(.)
. . . . I, Deepak, shall write the verbiage for the initial client contact by attorney.
Chad will be writing OCWEN and then potentially handing it off to another atty. We also came to conclusion on mass cases that the first amended complaint should not be done before service but after any opposition pleading.
Christine, Yervand, John and myself will meet to discuss the policy for an individual file after a salesperson hands it downstairs.
Email from Deepak Parwatikar to Real Estate Law Employees at 1-2 (sent April 4, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 6)(“April 4 Email”). See July 10 Tr. at 700:20-704:3

(Anaya-Allen, Parwatikar).

         172. Mr. Parwatikar ran weekly staff meetings, which Mr. Pratt attended irregularly, see July 8 Tr. at 31:2-3 (Murphy); id. at 38:12-39:1 (Murphy); id. at 94:6-10 (Paul); id. at 95:1-5 (Paul), at which the participants discussed case statuses and caseloads, made and received work assignments, see July 8 Tr. at 38:16-39:1 (Anaya-Allen, Murphy), and met with Real Estate Law's department heads, see Arzakanyan Depo. at 113:24-114:17.[21]

         173. Mr. Parwatikar avers that he told Real Estate Law to remove a provision from the attorney-client fee agreements that mentioned Pinnacle Law when he became aware that clients who saw the provision believed that Pinnacle Law was involved with Real Estate Law. See July 10 Tr. at 666:14-667:9 (Anaya-Allen, Parwatikar).

         174. At a May 22, 2013, meeting, Real Estate Law employees discussed “4 Step Sale Delay Strategy, ” “Adding Clients to Mass. Tort Cases, ” and scheduling attorney calls to clients “within 3 weeks of final payment deposit date.” FDD Streamlining Notes, at 359 (undated)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, as New Mexico's Ex. 188). See FDD Streamlining Notes, at 359-60; Arzakanyan Depo. at 114:1-7.

         175. Real Estate Law employees knew little about Pinnacle Law's operations. See July 8 Tr. at 115:22-24 (Kennedy, Paul); Arzakanyan Depo. at 27:19-20.[22]

         h. Mr. Parwatikar's Knowledge.

         176. Mr. Parwatikar knew that Real Estate Law engaged in mass tort litigation and became aware of the practice when they began using it. See July 10 Tr. at 689:11-15 (Anaya-Allen, Parwatikar).

         177. Mr. Parwatikar and Pinnacle Law knew that Mr. Davis continued to practice mass tort litigation at Real Estate Law. See July 10 Tr. at 739:20-22 (Anaya-Allen, Parwatikar).

         178. Mr. Parwatikar knew that Real Estate Law provided loan modification services. See July 10 Tr. at 689:16-19 (Anaya-Allen, Parwatikar).

         179. Mr. Parwatikar and Pinnacle Law knew that, when Mr. Davis owned Real Estate Law, Real Estate Law continued to provide mortgage modification services through its FDD. See July 10 Tr. at 739:23-740:6 (Anaya-Allen, Parwatikar).

         180. Mr. Parwatikar did not research mass joinder lawsuits. See July 11 Tr. at 817:17-24 (Anaya-Allen, Parwatikar).

         181. Mr. Parwatikar deferred to Mr. Pratt's and Mr. Davis' expertise as litigators. See July 11 Tr. at 817:19-24 (Parwatikar); id. at 793:5-15 (Kennedy, Parwatikar).

         182. Mr. Pratt and Mr. Davis told Mr. Parwatikar that the mass joinder lawsuits were a good litigation strategy, and he relied on their statements. See July 11 Tr. at 816:24-817:6 (Anaya-Allen, Parwatikar).

         183. During a discussion with Mr. Pratt of mass tort lawsuits, Mr. Parwatikar told Mr. Pratt that he would market the strategy if Mr. Pratt thought that the strategy was legal. See July 11 Tr. at 810:15-811:2 (Kennedy, Parwatikar).

         184. Mr. Parwatikar knew which banks Real Estate Law was suing. See Arzakanyan Depo. at 77:7-10.

         185. Mr. Parwatikar knew of the advance fees that Real Estate Law charged and how it required that the clients pay the advance fees, and he emphasized in an April 4, 2013, email that Real Estate Law clients must pay in advance:

From now on all individual files will be assigned to an atty once SOME payment has cleared. Client will be alerted by atty that research on the case will be done as well as an atty introduction. However client will be specifically told no interview of client or a complaint filed until initial retainer fully paid.

April 4 Email at 1. See July 10 Tr. at 702:21-703:2 (Anaya-Allen, Parwatikar).

         i. The Litigation.

         186. The FDD had success keeping homeowners' homes, but Real Estate Law did not succeed in court with any of its lawsuits; Arzakanyan would not say that the mass tort lawsuits helped homeowners.[23] See Arzakanyan Depo. at 54:2-8; id. at 63:9-16.[24]

         187. Real Estate Law and the courts regularly dismissed Real Estate Law's litigation. See, e.g., Conrad v. JP Morgan Chase & Co., Case No. CV-2015-0006295, Notice of Dismissal of Coordinated Case at 1-3, County of San Joaquin, Superior Court of California (dated October 13, 2017)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 196); Conrad v. JP Morgan Chase & Co., Case No. CV-2015-0006295, Request for Dismissal at 4-7, County of San Joaquin, Superior Court of California (dated September 27, 2016)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 196); White v. Ocwen Fin. Corp., Case No. CV-2015-0006295, Request for Dismissal at 1-4, County of San Joaquin, Superior Court of California (dated December 28, 2015)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 197); Barlow v. JP Morgan Chase & Co., Case No. 1-15-cv-28300, Request for Dismissal at 1-5, County of Santa Clara, Superior Court of California (dated August 9, 2016)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 198); Barker v. Select Portfolio Servicing, Case No. RG15781772, Request for Dismissal and Dismissal at 1-4, County of Alameda, Superior Court of California (dated June 30, 2016)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 199).

         188. Ms. Murphy accompanied Mr. Pratt to a demurrer hearing on the second amended complaint for a mass joinder named Ramos v. Bank of America soon after she started working at Real Estate Law in 2012. See July 8 Tr. at 26:10-22 (Anaya-Allen, Murphy).

         189. Mr. Pratt knew that Ramos v. Bank of America would be dismissed. See July 8 Tr. at 34:9-14 (Anaya-Allen, Murphy).[25]

         190. At the hearing, the court was prepared to dismiss the Ramos v. Bank of America mass joinder with prejudice on all causes but allowed Real Estate Law, by Ms. Murphy, to file a third amended complaint to save the case. See July 8 Tr. at 26:16-27:8 (Murphy, Anaya-Allen).

         191. Murphy prepared and filed a third amended complaint for Ramos v. Bank of America, but the court granted the demurrer, sustained it on all causes, and dismissed the case. See July 8 Tr. at 27:16-22 (Anaya-Allen, Murphy).

         192. Real Estate Law and Mr. Davis filed voluntary dismissals in several cases in the Superior Court of California, County of Los Angeles: (i) Anderson v. Wells Fargo Bank N.A., see Anderson v. Wells Fargo Bank N.A., BC52599, Request for Dismissal at 4, County of Los Angeles, Superior Court of California, Request for Dismissal (dated March 20, 2014)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 194); (ii) Jackson v. Specialized Loan Servicing, see Jackson v. Specialized Loan Servicing, BC541287, Request for Dismissal, at 46-49, County of Los Angeles, Superior Court of California (dated April 10, 2015)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 194); (iii) Allen et al v. Ocwen Fin., see Allen et al v. Ocwen Fin., BC555168, Request for Dismissal, at 50-53, County of Los Angeles, Superior Court of California, (dated May 19, 2015)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 194), (iv) Black v. Select Portfolio Servicing, see Black v. Select Portfolio Servicing, BC540511, Request for Dismissal, at 54-57 County of Los Angeles, Superior Court of California (dated May 19, 2015)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 194); (v) Brown v. Citibank USA, N.A., see Court Filings Ex. 194, Brown v. Citibank USA, N.A., BC550916, Request for Dismissal, at 58-61, County of Los Angeles, Superior Court of California (dated May 19, 2015)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 194); and (vi) Ball v. JP Morgan Chase & Co., see Ball v. JPMorgan Chase & Co., BC540510, Request for Dismissal, at 62-65, County of Los Angeles, Superior Court of California (May 27, 2015)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 194).[26]

         193. The Superior Court of California, County of Los Angeles dismissed the following cases: (i) Aghaji v. Bank of America and related cases, see Aghaji v. Bank of Am., BC498852, and related cases BC498852, BC498850, BC498978, BC521834 [consolidated with BC521835], BC522150, BC522158, BC522315, BC525203, BC531302, BC531535, BC531639, BC531713, BC531836, GC050583, BC538607, BC541862, BC545528, at 12-17, Judgment County of Los Angeles, Superior Court of California (dated December 4, 2014)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 194)[27]; (ii) Anderson v. Nationstar Mortgage, LLC, [28] see Anderson v. Nationstar Mortg., LLC, BC539499, Judgment in Favor of Nationstar Mortgage LLC in Anderson v. Nationstar Mortgage LLC, BC539499, at 18-21, County of Los Angeles, Superior Court of California (dated February 23, 2015)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 194); (iii) Aguayo et al v. Bank of America, see Aguayo et al v. Bank of Am., BC498852 (lead case), BC522158 (related case), Judgment of Dismissal in the Matter of Aguayo, et al. v. Bank of America, N.A., et al. (BC522158), at 22-27, County of Los Angeles, Superior Court of California, (dated March 13, 2015)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 194); (iv) Holmes et al v. Bank of America, see Holmes et al v. Bank of Am., BC498852 (lead case), BC531535 (related case), Judgment of Dismissal in the Matter of Holmes, et al. v. Bank of America, N.A., et al. (BC531535), at 28-33, County of Los Angeles, Superior Court of California, (dated March 13, 2015)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 194); (v) Penn et al v. Bank of America, see Penn v. Bank of Am., BC531639, BC498852 (lead case), BC531639 (related case), Judgment of Dismissal in the Matter of Penn, et al. v. Bank of America, N.A., et al. (BC531639), at 34-39, County of Los Angeles, Superior Court of California (dated March 13, 2015)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 194); and (vi) Simons v. Bank of America., see Simons v. Bank of Am., BC531836, Judgment of Dismissal in the Matter Simons, et al. v. Bank of America, N.A., et al. (BC531639), at 40-45, County of Los Angeles, Superior Court of California, (dated March 13, 2015)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 194).

         194. Real Estate Law and Mr. Davis filed voluntary dismissals in the following cases in the Superior Court of California, County of San Diego: (i) Miller v. Wells Fargo Bank, see Miller v. Wells Fargo Bank, Case No. 37-2014-00010936, Request for Dismissal, at 1-4, County of San Diego, Superior Court of California (dated June 24, 2014)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 194); (ii) Clark v. Wells Fargo Bank, see Clark v. Wells Fargo Bank, Case No. 37-2014-00011572, Request for Dismissal, at 5-8, County of San Diego, Superior Court of California (dated June 24, 2014)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 195), and (iii) Mills v. Wells Fargo Bank N.A., see Mills v. Wells Fargo Bank N.A., Case No. 37-2014-00015941, Request for Dismissal, at 9-12, County of San Diego, Superior Court of California (dated June 30, 2014)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 195).

         195. The County of San Diego, Superior Court of California, dismissed: (i) Arce v. Specialized Loan Servicing, LLC, [29] see Arce v. Specialized Loan Servicing, LLC, Case No. 37-2015-00013692, Judgment of Dismissal with Prejudice 13-17, County of San Diego, Superior Court of California (dated March 3, 2016)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 195); (ii) Kennedy v. Bank of America, [30]see Kennedy v. Bank of Am., Case No. 37-2015-00013692, Order of Dismissal, at 26-30, County of San Diego, Superior Court of California (dated May 6, 2016)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 195); (iii) Gardner v. Bank of America, see Gardner v. Bank of Am., Case No. 37-2014-00013183, Notice of Entry of Judgment at 41-50, County of San Diego, Superior Court of California (filed June 3, 2016)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 195); and (iv) Barnes v. Select Portfolio Servicing, Inc., see Barnes v. Select Portfolio Servicing, Inc., Case No. 37-2015-00013374, Order of Judgment and Dismissal, at 51-71, County of San Diego, Superior Court of California (dated June 3, 2016)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 195).

         196. The Superior Court of California, San Joaquin County dismissed Conrad v. JP Morgan Chase & Co. See Conrad v. JP Morgan Chase & Co., Notice of Dismissal of Coordinated Case and Request for Dismissal at 1-3.

         197. On September 27, 2016, Real Estate Law and Mr. Davis also filed a Request for Dismissal in the Conrad case. See Conrad v. JP Morgan Chase & Co., Request for Dismissal at 4-7.

         198. Real Estate Law and Mr. Davis requested dismissal of White v. Ocwen Financial Corporation, and dismissal was entered on December 28, 2015. See White v. Ocwen Fin. Corp., Request for Dismissal at 1-4.

         199. Real Estate Law and Mr. Davis filed a Request for Dismissal in Barlow v. JP Morgan Chase & Co. and dismissal was entered on December 28, 2015.[31] See Barlow v. JPMorgan Chase & Co., Request for Dismissal at 1-5.

         200. On August 22, 2013, Real Estate Law and Mr. Pratt voluntarily dismissed Acevedo v. JP Morgan Chase Bank. See Acevedo v. JP Morgan Chase Bank, N.A., 2:13-CV-05278-R- (JCx), Notice of Dismissal Pursuant to Federal Rules of Civil Procedure 41(a) or (c) at 254 (filed in C.D. Cal. August 22, 2013)(C.D. Cal. Doc. 10)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11 2019, as New Mexico's Ex. 188).

         j. The Workplace Conflict.

         201. Mr. Parwatikar asked Ms. Murphy and Mr. Paul to perform tasks at Real Estate Law that Ms. Murphy and Mr. Paul did not think were right. See July 8 Tr. at 31:11-13 (Murphy); Email from Deepak Parwatikar to Michael Paul at 1-2 (sent April 17, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 16); Email from Paul to Drew Borthwick at 4 (sent April 15, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 16).

         202. Ms. Murphy wanted to help clients and to be a good attorney, and she had experienced conflict with Mr. Parwatikar, because she did not agree with Real Estate Law's operations. See July 8 Tr. at 32:5-12 (Murphy); id. at 32:18-20 (Murphy); id. at 32:22-33:2 (Anaya-Allen, Murphy); id. at 33:10-17 (Anaya-Allen, Murphy).

         203. At a staff meeting, for instance, Ms. Murphy suggested that Real Estate Law's intake process focus on identifying clients with common actions, but her suggestion was against Real Estate Law's practices, because Real Estate Law's model was to join a client in the mass tort against the client's lender, i.e., if the client's lender was Bank of America, the client would join the mass tort against Bank of America. See July 8 Tr. at 43:5-14 (Murphy).

         204. Ms. Murphy saved emails when the emails contradicted what she was told, and the Feb. 13, 2013, Email, see Feb. 13 Email at 1, shows that Mr. Parwatikar was involved with Real Estate Law although he did not want employees to act as if he were involved, see July 8 Tr. at 57:17-58:1 (Anaya-Allen, Murphy).

         205. Real Estate Law terminated Murphy's employment, and Mr. Davis escorted her from Real Estate Law's building. See July 8 Tr. at 40:6-12 (Anaya-Allen, Murphy).

         206. Mr. Parwatikar told Ms. Murphy that the salesmen called her a “deal-crusher or deal-killer, ” that she was not a “good girl, ” and that no one liked her. July 8 Tr. at 41:2-42:4 (Murphy).

         207. Ms. Murphy testified in the State Bar of California disciplinary proceedings against Mr. Pratt. See July 8 Tr. at 42:5-12 (Anaya-Allen, Murphy).

         208. Mr. Paul had a conflict with Mr. Parwatikar, because Mr. Paul did not want to sign a letter that Mr. Parwatikar wanted him to sign on Real Estate Law's behalf, because Mr. Paul had not written the letter. See Email from Deepak Parwatikar to Michael Paul at 1-2; Email from Paul to Drew Borthwick at 4; July 8 Tr. at 99:18-101:8 (Anaya-Allen, Paul).

         209. Mr. Paul left Real Estate Law because Real Estate Law was not acting ethically; it was collecting advance fees, not delivering the services that it promised, not allowing clients to speak with attorneys, and refusing to refund fees, and used the compliance calls as a justification. See July 8 Tr. at 106:5-15 (Paul); id. at 107:18-21 (Paul).

         210. The Attorney General of California issued a press release about a lawsuit against a law firm like Real Estate Law, and Mr. Paul thought that Real Estate Law did similar work. See July 8 Tr. at 117:2-10 (Anaya-Allen, Paul).

         211. Mr. Paul made several complaints about Real Estate Law; he contacted the Attorney General, the city attorney, [32] and wrote Mr. Pratt and Mr. Parwatikar directly on June 20, 2013. See Email from Michael Paul to Chad Pratt, CC Deepak Parwatikar at 1-2 (sent June 20, 2013)(admitted for non-hearsay purposes July 8, 2019, at Trial as New Mexico's Ex. 18)(“June 20 Email”); July 8 Tr. at 106:18-107:6 (Paul).

         212. Mr. Paul wrote a complaint to the State Bar of California in which he expressed the same concerns that he had expressed to Mr. Pratt and Mr. Parwatikar. See July 8 Tr. at 112:8-19 (Paul).

         213. The day that Mr. Paul left Real Estate Law, Mr. Parwatikar called him into his office about the June 20, 2013, email, and Mr. Paul expressed his concerns with clients paying $3, 000.00 or $5, 000.00 upfront, and being unable to speak to their attorneys. See July 8 Tr. at 108:10-16 (Paul).

         214. Mr. Paul informed Mr. Pratt and Mr. Parwatikar that the mass tort cases were not successful and were dismissed, that Real Estate Law required upfront payments, and that clients could not speak to their attorneys. See July 8 Tr. at 117:18-20 (Anaya-Allen, Paul); id. at 119:15-120:18 (Anaya-Allen, Paul); June 20 Email at 1-2.

         215. Mr. Parwatikar did not express concern about the issues that Mr. Paul raised when they met. See July 8 Tr. at 108:16-23 (Paul).

         216. The State Bar of California held a proceeding against Mr. Pratt, and Ms. Murphy testified about Mr. Pratt, his interactions with Real Estate Law, and his limited responsibilities at Real Estate Law. See July 8 Tr. at 42:5-12 (Anaya-Allen, Murphy).

         k. The Discipline.

         217. Balanced Legal Group provided loan modification services to consumers in Minnesota. See July 10 Tr. at 638:4-6 (Anaya-Allen, Parwatikar), id. at 649:13-15(Anaya-Allen, Parwatikar).

         218. On November 24, 2010, the State of Minnesota sued Mr. Parwatikar and Balanced Legal for violating Minnesota's law on foreclosure consultants, stated that “states around the country, including Minnesota, have enacted laws to prohibit [foreclosure consultants] from charging fees in advance of their delivery of services, ” and alleged that Balanced Legal did not provide multiple consumer protection notices that Minnesota Law requires. Minn. v. Balanced Legal Group, No. 27-CV-10-27052, Complaint ¶ 8, (filed in County of Hennepin, Fourth Judicial District, State of Minnesota, January 6, 2012)(admitted, for notice and not the truth of the matters asserted, July 10, 2019, at Trial as New Mexico's Ex. 193). See July 10 Tr. at 638:23-639:6; Minn. v. Balanced Legal Group, Complaint at ¶¶ 8-17. See also Solomon Depo. at 79:1-7.

         219. Arzakanyan served the Answer and signed the Affidavit of Service on Balanced Legal's and Mr. Parwatikar's behalf in Minnesota v. Balanced Legal Group. See Minn. v. Balanced Legal Group, No. 27-CV-10-27052, Affidavit of Service at 503 (County of Hennepin, Fourth Judicial District, State of Minnesota, dated December 21, 2010)(admitted July 10, 2019, at Trial as New Mexico's Ex. 235)(“Minn. v. Balanced Legal Group, Affidavit of Service”); July 10 Tr. at 724:5-15 (Anaya-Allen, Parwatikar).

         220. Balanced Legal Group and Mr. Parwatikar entered a Consent Judgment with Minnesota on December 15, 2011. See July 10 Tr. at 643:19-21 (Court); Minn. v. Balanced Legal Group, No. 27-CV-10-27052, Consent Judgment, at 1-7 (County of Hennepin, Fourth Judicial District, State of Minnesota, January 6, 2012)(admitted, for notice and not for the truth of the matters asserted, July 10, 2019, at Trial as New Mexico's Ex. 193).

         221. The Consent Judgment provides for eighteen consecutive monthly payments of $625.00 beginning on February 15, 2012. See Consent Judgment at 5.

         222. Solomon received a payment of $625.00 from Pinnacle Law dated April 12, 2012, with the memo “State of MN.” Check from Pinnacle Law Center, PC to Angelina Solomon at 216 (dated April 12, 2012)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 146). See Solomon Depo. at 78:7-19.

         223. The State Bar of California suspended Mr. Pratt, and Mr. Parwatikar knew that the State Bar of California had suspended Mr. Pratt. See July 10 Tr. at 674:19-22 (Anaya-Allen, Parwatikar).

         224. The State Bar of California disciplined Mr. Pratt and Mr. Davis for activities related to Real Estate Law. See July 11 Tr. at 813:4-6 (Anaya-Allen, Parwatikar).

         225. The Organization Meeting Minutes that Mr. Pratt and Mr. Davis signed when Mr. Davis took over Real Estate Law reflect that Pratt had informed Mr. Davis of:

1. Existing complaints from regulatory bodies, including the State Bar of California
2. Any potential complaints from regulatory bodies, including the State Bar of California
3. Complaint to the State Bar filed by a previous compliance attorney, Michael Paul
4. Violations of State Bar of California's Rules of Professional Conduct
5. Existing lawsuits filed against the corporation, including those filed in small claims court
6. Any potential lawsuits against the corporation .
7. Existing and potential refund requests from clients

Organizational Meeting Minutes and Minutes of Special Meeting at 5-6. See July 11 Tr. at 822:5-7 (Anaya-Allen, Parwatikar).

         226. The Honorable Manuel Real, then- United States District Judge for the United States District Court for the Central District of California, sanctioned Real Estate Law on June 11, 2014, awarding $126, 400.00 for the “frivolous nature of the Complaint, the blatant misjoinder of Plaintiffs, and Plaintiff's counsel's voluntary dismissal of the case to avoid an adverse ruling.” Alexander v. Wells Fargo Bank, Case No. 2:14-cv-01303-R-CW, Order Granting in Part and Denying in Part Wells Fargo's Motion for Attorneys' Fees at 3-7 (filed in C.D.C., June 11, 2014) (admitted July 11, 2019, at Trial as New Mexico's Ex. 160).

         227. Real Estate Law was ordered to pay Wells Fargo Bank (“Wells Fargo”) $227, 251.00. See Arzakanyan Depo. at 73:2-6. See also Arzakanyan Depo. at 72:22-24 (reflecting that Wells Fargo Bank received a judgment of $126, 524.80 against Real Estate Law[33]); Solomon Depo. at 120:24-121:8 (reflecting that Mr. Davis instructed Solomon to wire transfer a very large amount of money to Wells Fargo for a court-ordered sanctioned).

         228. Mr. Parwatikar was aware that a California federal court sanctioned Real Estate Law and Mr. Davis with a substantial financial sanction. See July 10 Tr. at 740:7-18 (Anaya-Allen, Parwatikar).

         229. The State of Connecticut Department of Banking entered a Consent Order with Real Estate Law, issuing a March 2, 2015, Temporary Order to Cease and Desist, Order to Make Restitution, Notice of Intent to Issue Order to Cease and Desist Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing against Real Estate Law. See In the Matter of: Real Estate Law Center, P.C., Consent Order at 1-2, State of Connecticut Department of Banking (dated May 19, 2015)(admitted only as to Real Estate Law, Mr. Davis, and Mr. Pratt July 11, 2019, at Trial as New Mexico's Ex. 160)(“Consent Order”).

         230. The Connecticut Department of Banking charged Real Estate Law with offering to engage in debt negotiation without obtaining a required license, and Mr. Davis entered the Consent Order on Real Estate Law's behalf and agreed to pay restitution and to stop offering debt negotiation services in Connecticut. See Consent Order at 1-2.

         231. The Supreme Court of California filed an order on August 22, 2017, disbarring Mr. Davis and ordering him to pay restitution. See In re Erikson McDonnell Mr. Davis, Case No. 16-O-13378, Order at 1-2 (filed in the Supreme Court of California, August 22, 2017)(admitted only as to Real Estate Law and Mr. Davis July 11, 2019, at Trial as New Mexico's Ex. 191).

         232. Mr. Davis entered the In the Matter of: Erikson McDonnell Mr. Davis, Case No. 16-O-13378, Stipulation re: Facts, Conclusions of Law and Disposition and Order Approving, Order of Involuntary Inactive Enrollment, Disbarment (filed in State Bar Ct. Cal. April 17, 2017)(admitted only as to Real Estate Law and Mr. Davis July 11, 2019, at Trial as New Mexico's Ex. 191)(“Mr. Davis Stipulation”). See Mr. Davis Stipulation at 3-18.

         233. Mr. Davis admits that: (i) between September 26, 2013, and January 5, 2017, he owned Real Estate Law Center, see Mr. Davis Stipulation at 8; (ii)

RELC (i) obtained clients through advertising using mail, television, and the internet; (ii) utilized non-attorney staff to meet with prospective clients; (iii) attempted to assist its clients in obtaining loan modifications by challenging the practices of their lenders and/or service providers; and (iv) used mass joinder lawsuits and individual lawsuits in an attempt to achieve loan modification goals;

         Mr. Davis Stipulation at 8; (iii) “[t]he RELC fee agreements required the complainants to pay RELC an advanced fee, ” Mr. Davis Stipulation at 8; (iv) Real Estate Law filed mass joinder lawsuits with the “ultimate purpose of attempting to obtain a modification of [consumers'] respective home loans, ” Mr. Davis Stipulation at 9; and (v) Real Estate Law did not provide a written statement that California law requires, see Mr. Davis Stipulation at 10.

         234. The State Bar Court of California entered Conclusions of Law, to which Mr. Davis agreed, and which include that: (i) by “failing to adequately supervise non-attorney staff, which inadequate supervision allowed the non-attorney staff . . . to represent to the complainants that RELC would represent them in litigation . . . for an advanced fee, [Mr. Davis] repeatedly failed to perform competently in willful violation of Rules of Professional Conduct”; (ii) by “[c]ollecting fees . . . for RELC's loan modification services before RELC had fully performed each and every service, ” Mr. Davis willfully violated California law; and (iii) by “breach[ing] his fiduciary duty to the complainants, ” Mr. Davis “committed acts of moral turpitude in willful violation” of California Law. Mr. Davis Stipulation at 11.

         235. The State Bar Court of California found several aggravated circumstances, to which Mr. Davis agreed, including: (i) a prior record of discipline for collecting between October, 2013, and September, 2015, advanced fees for legal services, including for the filing of lawsuits against home lenders for the purposes of obtaining loan modifications; (ii) multiple acts of wrongdoing, including collecting $173, 760.89 in advance fees from nineteen former clients in approximately a three-year period; (iii) dishonesty and overreaching for including language in the fee agreements which states that the advance fees are a “true retainer” and non-refundable to ensure that Real Estate Law worked “exclusively” on the consumers' matters; and (iv) significant harm to clients by exploiting their financial difficulties and not providing refunds. Mr. Davis Stipulation at 12. See id. at 11-12.

         236. The State Bar Court of California recommended that the Supreme Court of California discipline Mr. Davis. See Mr. Davis Stipulation at 17.

         2. The New Mexico Consumers.

         237. Mr. Pratt wrote the attorney-client fee agreements that Real Estate Law used during his time at Real Estate Law. See Notice of Motion, Motion to Dismiss for Improper Venue and/or In the Alternative Transfer to Los Angeles; Declaration of Pratt ¶ 19, at 14 (filed March 14, 2019)(Doc. 113).

         238. Real Estate Law used different attorney-client fee agreements during the time period at issue. Compare Ward Attorney-Client Fee Agreement at 1-3, with Mondragon Attorney-Client Fee Agreement at 1-3 (executed January 7, 2014)(admitted July 9, 2019, at Trial as New Mexico's Ex. 107)(“Mondragon Attorney-Client Fee Agreement”).

         239. The attorney-client fee agreements follow, however, the same general pattern. Compare Ward Attorney-Client Fee Agreement at 1-3, with Mondragon Attorney-Client Fee Agreement at 1-3.

         240. The Court discusses below sixteen individuals who owned and occupied property in New Mexico during the time period at issue.[34]

         a. Linda Ward.

         241. Ward owns and occupies, as a principal place of residence, a home at 1016 Desert Willow Court, Bernalillo, New Mexico, and has for twelve years. See July 8 Tr. at 127:2-8 (Anaya-Allen, Ward).[35]

         242. Ward had trouble making her mortgage payments after a fall in the real estate market and a loss of income. See July 8 Tr. at 127:9-17 (Anaya-Allen, Ward).

         243. Ward attempted to refinance but was unsuccessful. See July 8 Tr. at 127:18-22 (Anaya-Allen, Ward).

         244. Ward learned about Real Estate Law through marketing materials that she received about a lawsuit against Bank of America. See July 8 Tr. at 127:25-128:8 (Anaya-Allen, Ward).

         245. Ward decided to visit Los Angeles and meet with Brian Suder in Real Estate Law's Litigation Compliance. See July 8 Tr. at 130:7-14 (Anaya-Allen, Ward); id. at 130:22-25 (Ward).

         246. Ward wanted to meet the Real Estate Law attorneys, but she could not do so. See July 8 Tr. at 132:7-13 (Anaya-Allen, Ward).[36]

         247. Ward signed an Attorney-Client Fee Agreement with Real Estate Law Center on August 9, 2012, which provides for a non-refundable one-time retainer fee of $5, 000.00, monthly fees of $29.95, and that Pinnacle Law Center would receive eighty percent of the fees. See Ward Attorney-Client Fee Agreement ¶¶ 4, 10, at 1-3.

         248. The Ward Attorney-Client Fee Agreement also provides that Real Estate Law will receive a thirty-percent contingency fee. See Ward Attorney-Client Fee Agreement ¶ 4, at 2.

         249. The Ward Attorney-Client Fee Agreement states: “Client is hiring RELC to represent client in LITIGATION AGAINST THEIR MORTGAGE LENDER CONCERNING THEIR REAL ESTATE PROPERTY.” Ward Attorney-Client Fee Agreement ¶ 2, at 1 (bold omitted).[37]

         250. The Ward Attorney-Client Fee Agreement provides that, although the client resides outside California, all litigation will be filed in California county or federal courts, and that Real Estate Law's attorneys are California-licensed. See Ward Attorney-Client Fee Agreement ¶ 2, at 1.

         251. The Ward Attorney-Client Fee Agreements provides for two-tenths of the retainer fee for Real Estate Law and the remainder to go to Pinnacle Law, and states: “Client is not retaining PLC nor is PLC a litigation firm. PLC is only involved in referring clients to RELC.” Ward Attorney-Client Fee Agreement ¶ 10, at 3.

         252. The Ward Attorney-Client Fee Agreement provides: “The agreement shall be governed in accordance with the laws of the State of California. Venue shall be Los Angeles County.” Ward Attorney-Client Fee Agreement ¶ 12, at 3.

         253. The Ward Attorney-Client Fee Agreement does not contain in at least fourteen-point font Real Estate Law's name and address, or the date that Ward signed the Ward Attorney-Client Fee Agreement. See Ward Attorney-Client Fee Agreement at 1.

         254. Real Estate Law did not provide required notices to Ward, including the Notice Required by New Mexico Law, the Notice of Rescission Rights, and the Rescission of Contract Form.[38] See July 8 Tr. at 136:3-16 (Anaya-Allen, Ward); Ward Attorney-Client Fee Agreement at 1-3.

         255. Ward paid the $5, 000.00 retainer fee and the monthly maintenance fees for a year. See July 8 Tr. at 134:8-12 (Anaya-Allen, Ward); id. at 156:14-16 (Anaya-Allen, Ward).[39]

         256. Ward paid Real Estate Law a total of $5, 359.40.

         257. At this time, Ward's property was not in foreclosure. Cf. July 8 Tr. at 164:2-10 (Kennedy, Ward)(explaining that Ward received a foreclosure notice after retaining Real Estate Law).

         258. Ward understood that Real Estate Law was suing Bank of America and Real Estate Law communicated to her that she was a participant in the lawsuit. See July 8 Tr. at 128:4-8 (Anaya-Allen, Ward); id. at 141:25:142:4 (Anaya-Allen, Ward).[40]

         259. Bank of America confirmed with Ward that Mr. Pratt was authorized to discuss her mortgage with them. See July 8 Tr. at 134:19-135:5 (Anaya-Allen, Ward).

         260. Ward expected litigation services from Real Estate Law and did not know that they would contact her bank on her behalf. See July 8 Tr. at 135:6-20 (Anaya-Allen, Ward); Letter from Bank of America to Linda S. Ward at 1 (dated October 1, 2012)(admitted July 8, 2018, at Trial as New Mexico's Ex. 21)(“Ward Oct. 1 Letter”)(stating that Mr. Pratt is authorized to act as a third party on Ward's home loan account).

         261. In May 2012, Ward returned financial documents to sam@balancedlegalgroup.com for help with foreclosure defense. See Email from Linda Ward to Sam Branco at 1 (sent March 7, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 30)(“Ward FDD March 7 Email”).

         262. On September 27, 2012, Real Estate Law told Ward to complete an FDD package and to submit the package and notices of default or sale that she had received form her lender. See Email from Real Estate Law to Linda Ward at 2 (sent September 27, 2012)(admitted July 8, 2019, at Trial as New Mexico's Ex. 22)(“Ward Sept. 27 Email”).

         263. Ward recognized the FDD package to contain loan modification materials, because she previously applied to Bank of America for a loan modification. See July 8 Tr. at 137:18-22 (Anaya-Allen, Ward).

         264. Real Estate Law automatically sent Ward loan modification documents -- an FDD package -- although she did not hire Real Estate Law for loan modification assistance. See July 8 Tr. at 136:17-137:22 (Anaya-Allen, Ward); id. at 138:19-23 (Ward); id. at 139:10-13 (Anaya-Allen, Ward); Ward Sept. 27 Email at 2.

         265. In November, 2012, Real Estate Law sent Ward information about Armstrong v. Bank of America, a mass joinder lawsuit in which Real Estate Law named her as a plaintiff and asked Ward to return a verification. See Email from Gerardo Lopez to Linda Ward at 1-2 (sent November 12, 2012)(admitted July 8, 2019, at Trial as New Mexico's Ex. 24)(“Ward Nov. 12 Email”).

         266. Real Estate Law sent Ward a copy of the Armstrong v. Bank of America complaint. See July 8 Tr. at 140:22-24 (Ward).[41]

         267. Real Estate Law filed Armstrong v. Bank of America, and Ward signed a verification for the lawsuit, but never learned of the lawsuit's outcome. See July 8 Tr. at 151:9-152:9 (Anaya-Allen, Ward); id. at 152:10-18 (Anaya-Allen, Ward); Ward Nov. 12 Email at 1-2; Email from Linda Ward to Gerardo Lopez at 3 (sent November 12, 2012)(admitted July 8, 2019, at Trial as New Mexico's Ex. 24); Email from Erma Rodriguez to Linda Ward at 1 (sent August 7, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 32).

         268. Real Estate Law promised that it would help Ward with her foreclosure, and, in January 2013, she sent Real Estate Law her foreclosure notice. See July 8 Tr. at 143:15-22 (Ward, Anaya-Allen); id. at 167:22-23 (Ward); id. at 169:21-25 (Anaya-Allen, Ward); Email from Linda Ward to Real Estate Law at 2 (sent January 15, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 26).

         269. Real Estate Law directed Ward to obtain local counsel in New Mexico to help with the foreclosure proceedings, see July 8 Tr. at 143:23-144:15 (Anaya-Allen, Ward); Email from Real Estate Law to Linda Ward at 3 (sent January 15, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 26)(“Ward Foreclosure Jan. 15 Email”), [42] but offered that it could help “negotiate Payment stabilization” and complete an FDD package to postpone the sale, see Ward Foreclosure Jan. 15 Email at 3; Email from Tutu Gill to Linda Ward at 1-2 (sent January 15, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 27)(“Ward FDD Jan. 15 Email”).

         270. Real Estate Law repeatedly sent Ward FDD packages, and, in January 2013, sent her another FDD package to complete. See July 8 Tr. at 138:19-23 (Ward); id. at 150:1-5 (Anaya-Allen, Ward); id. at 147:17-148:2 (Anaya-Allen, Ward); Ward FDD March 7 Email at 1.

         271. Ashley Hanu, at Real Estate Law, provided Ward advice on proceeding in the local court in New Mexico and indicated that Ward should file a response with information about the pending litigation against Bank of America. See Email from Ashley Hanu to Linda Ward at 1 (sent January 16, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 28)(“Ward Advice Jan. 16 Email”).

         272. Ward was a plaintiff in Aghaji v. Bank of America. See Email from Ward to Ashley Hanu at 1 (sent April 3, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 31); Email from Ashley Hanu to Linda Ward at 2 (sent April 4, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 31)(“Ward Apr. 4 Email”); Email from Erma Rodriguez to Linda Ward at 1-2 (sent August 7, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 32)(“Ward Aug. 7 Email”); Email from Linda Ward to Erma Rodriguez at 2 (sent October 1, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 32)(“Ward Oct. 1 Email”); Email from Real Estate Law to Linda Ward at 1-2 (sent June 16, 2014)(admitted July 8, 2019, at Trial as New Mexico's Ex. 33 (“Ward Aghaji Update Email”); July 8 Tr. at 152:10-153:2 (Anaya-Allen, Ward); id. at 153:10-154:11 (Anaya-Allen, Ward).

         273. In October, 2013, Real Estate Law filed an amended complaint in Aghaji and asked Ward to provide a signed certification to Real Estate Law to file. See Ward Aug. 7 Email at 2; Ward Oct. 1 Email at 2.

         274. On October 17, 2014, Real Estate Law informed Ward that an October 9, 2014, hearing in Aghaji v. Bank of America resulted in a ruling that the claims are invalid and asked her for an additional $50.00 per month for an appeal. See Ward Aghaji Update Email at 1-2; Email from Tutu Gill to Linda Ward at 1-2 (sent October 17, 2014)(admitted July 8, 2019, at Trial as New Mexico's Ex. 34)(“Ward Oct. 17 Email”); July 8 Tr. at 155:1-156:8 (Ward).

         275. Ward hired a New Mexico attorney to save her home. See July 8 Tr. at 157:19-25 (Anaya-Allen, Ward); id. at 164:23-165:23 (Ward, Kennedy).

         276. Real Estate Law provided Ward no assistance with her mortgage issues. See July 8 Tr. at 157:16-18 (Anaya-Allen, Ward).

         277. Ward ultimately saved her home through the assistance of another attorney to which Real Estate Law referred her. See July 8 Tr. at 157:19-25 (Anaya-Allen, Ward).

         278. Email correspondence that Ward received from Real Estate Law on September 27, 2012, October 15, 2012, November 8, 2012, November 12, 2012, January 15, 2013, April 4, 2013, June 16, 2014, and October 17, 2014, did not contain MARS Rule disclosures or any disclaimer.[43] See Ward Sept. 27 Email at 2; Email from Real Estate Law to Linda Ward at 7 (sent October 15, 2012)(admitted July 8, 2019, at Trial as New Mexico's Ex. 22); Email from Real Estate Law to Linda Ward at 2 (sent November 8, 2012)(admitted July 8, 2019, at Trial as New Mexico's Ex. 23); Email from Real Estate Law to Linda Ward at 3 (sent November 12, 2012); Ward Apr. 4 Email at 2; Ward Aghaji Update Email at 1-2; Ward Oct. 17 Email at 1-2.

         279. On November 12, 2012, the email that Ward received as part of the Bank of America Plaintiffs had a disclaimer, but not a specific MARS Rule disclosure:

Please be aware that filing a Mass. Tort Complaint against your lender in and of itself will not stop the foreclosure process or prevent a trustee sale of your property. Also, if your property has been sold due to the foreclosure process, and/or you have a pending Unlawful Detainer, and/or a Notice to Vacate, Mass. Tort Litigation may not prevent legal action against you.

Ward Nov. 12 Email at 2.[44]

         280. Emails from January 14, 2013, January 15, 2013, January 16, 2013, August 7, 2013, and October 1, 2013, contain the same disclosure. See Email from Ashley Hanu to Linda Ward at 1 (sent January 14, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 26); Ward FDD Jan. 15 Email; Ward Advice Jan. 16 Email at 1-2; Ward Aug. 7 Email at 1-2; Email from Erma Rodriguez to Linda Ward at 1 (sent October 1, 2013).

         b. Larry Madrid and Mary Lou Madrid.

         281. L. Madrid and his wife, M. Madrid, lived in, as a principal place of residence, a home at 8807 Menaul Boulevard, NE in Albuquerque until approximately 2013. See July 8 Tr. at 173:5-14 (Anaya-Allen, L. Madrid); id. at 194:6-7 (L. Madrid).

         282. The current residence of L. Madrid and M. Madrid is unclear.

         283. L. Madrid and M. Madrid had difficulty paying their monthly mortgage after M. Madrid lost her job. See July 8 Tr. at 173:18-21 (Anaya-Allen, L. Madrid); id. at 207:10-11 (Giandomenico, M. Madrid); id. at 207:23-25 (Giandomenico, M. Madrid).

         284. L. Madrid and M. Madrid tried unsuccessfully to modify their loan on their own with JP Morgan Chase & Co. (“ JP Morgan Chase”). July 8 Tr. at 173:24-174:4 (L. Madrid).

         285. Real Estate Law contacted the Madrids and told them that it could help get their mortgage on track and reduce their monthly payments. See July 8 Tr. at 174:13-15 (Anaya-Allen, L. Madrid).

         286. In October, 2012, L. Madrid completed the PreApproval Intake Form for Real Estate Law and explained the problems that he had with his home mortgage. See PreApproval Intake Form at 1-2 (undated)(admitted July 8, 2019, at Trial as New Mexico's Ex. 35)(“Madrid Real Estate Law Application”).

         287. At this time, L. Madrid and M. Madrid's home was not in foreclosure. See July 8 Tr. at 191:19-25 (Anaya-Allen, Madrid)(reflecting that L. Madrid conveyed foreclosure documents to Real Estate Law).

         288. Real Estate Law conducted a compliance call on October 18, 2012, and told L. Madrid to answer only “yes” or “no.” Madrid Compliance Call at 2:30-3:00.

         289. Real Estate Law also told L. Madrid that it did not guarantee that the lawsuit would delay or stop a foreclosure, and that, if a foreclosure sale date was scheduled, Real Estate Law could not get an order from the judge or an agreement from the lender to stop the sale from going through, and that L. Madrid would need to take legal action outside the lawsuit to stop the foreclosure. See Madrid Compliance Call at 7:20-8:02.

         290. During the compliance call, L. Madrid expressed his understanding that Real Estate Law would help him with a loan modification. See Madrid Compliance Call at 2:00-2:30, 291. Real Estate Law also told Madrid that it would help him stop JP Morgan Chase from taking his home with the FDD. See Madrid Compliance Call at 5:00-6:30.

         292. L. Madrid expected Real Estate Law to contact his bank, to redo his mortgage, and to lower his monthly payments, and that he would not lose his home. See July 8 Tr. at 185:11-15 (L. Madrid); id. at 195:13-24 (Kennedy, L. Madrid); id. at 209:4-8 (L. Madrid); Letter of Authorization at 4 (dated October 16, 2012)(admitted July 8, 2019, at Trial as New Mexico's Ex. 41).

         293. L. Madrid and Real Estate Law entered into an Attorney-Client Fee Agreement, which L. Madrid signed on October 16, 2012, and which provides for a nonrefundable one-time retainer fee of $5, 000.00 and a monthly fee of $29.95. See July 8 Tr. at 176:25-177:13 (Anaya-Allen, L. Madrid); Madrid Attorney-Client Fee Agreement ¶ 4, at 1-2; id. at 3.

         294. The Madrid Attorney-Client Fee Agreement also provides that Real Estate Law will receive a thirty-percent contingency fee. See Madrid Attorney-Client Fee Agreement ¶ 4, at 2.

         295. The Madrid Attorney-Client Fee Agreement states that Real Estate Law would represent L. Madrid in “LITIGATION AGAINST THEIR MORTGAGE LENDER CONCERNING THEIR REAL ESTATE PROPERTY.” Madrid Attorney-Client Fee Agreement, ¶ 2, at 1.

         296. The Madrid Attorney-Client Fee Agreement provides that Real Estate Law maintains only attorneys admitted to the State Bar of California and that they only practice in California. See Madrid Attorney-Client Fee Agreement ¶ 2, at 1.

         297. The Madrid Attorney-Client Fee Agreement provides that Pinnacle Law will receive eighty percent of the retainer fee. See Madrid Attorney-Client Fee Agreement ¶ 10, at 2-3.

         298. The Madrid Attorney-Client Fee Agreement states: “PLC is a separate law firm not related to RELC. Client is not retaining PLC.” Madrid Attorney-Client Fee Agreement ¶ 10, at 3.

         299. The Madrid Attorney-Client Fee Agreement provides: “The agreement shall be governed in accordance with the laws of the State of California. Venue shall be Los Angeles County.” Madrid Attorney-Client Fee Agreement ¶ 12, at 3.

         300. Mr. Pratt signed the Madrid Attorney-Client Fee Agreement on October 29, 2012. See July 8 Tr. at 177:24-178:6 (Anaya-Allen, Madrid); Madrid Attorney-Client Fee Agreement at 3.

         301. The Madrid Attorney-Client Fee Agreement does not contain in at least fourteen-point font Real Estate Law's name and address, or the date that L. Madrid signed the Madrid Attorney-Client Fee Agreement. See Madrid Attorney-Client Fee Agreement at 1.

         302. Real Estate Law did not provide L. Madrid a Notice Required by New Mexico Law, a Notice of Rescission Rights, or a Rescission of Contract Form. See July 8 Tr. at 178:25-15 (Anaya-Allen, L. Madrid); id. at 179:23-180:2 (Anaya-Allen, L. Madrid); Madrid Attorney-Client Fee Agreement at 1-3.

         303. L. Madrid and M. Madrid paid Real Estate Law $5, 000.00 in five monthly payments starting the month that they signed with Real Estate Law. See E-Check Scheduled Payment Authorization Form at 1-2 (dated December 17, 2012)(admitted July 8, 2019, at Trial as New Mexico's Ex. 41); July 8 Tr. at 181:15-20 (L. Madrid); id. at 210:1-4 (M. Madrid).[45]

         304. L. Madrid and M. Madrid also paid $29.95 per month to Real Estate Law for around seven or eight months. See July 8 Tr. at 189:22-190:5 (Anaya-Allen, L. Madrid); id. at 210:5-211:18 (Giandomenico, M. Madrid); E-Check Payment Authorization for Monthly Maintenance Fee at 3 (dated February 19, 2012)(admitted July 8, 2019, at Trial as New Mexico's Ex. 41); Letter of Authorization at 4; Email from by Telephone to Larry Madrid at 1 (sent May 16, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 47); Madrid Bank of Albuquerque Records, at 6 (undated)(admitted July 8, 2019, at Trial as New Mexico's Ex. 51).

         305. L. Madrid and M. Madrid paid Real Estate Law a total of $5, 209.65 to $5, 239.60. Parwatikar Defs.' Proposed Findings ¶ 14, at 5.

         306. Real Estate Law returned the executed Madrid Attorney-Client Fee Agreement to L. Madrid with a package of documents that included a letter from Mr. Pratt, a statement “Together, We are a Team, ” “Do's and Don'ts, ” and “A Brief Outline of a Lawsuit, ” none of which included specific MARS Rule disclosures, or any disclosure about what happens if a homeowner stops paying a mortgage or about New Mexico law. See Madrid Real Estate Law Welcome Documents at 1-4 (undated)(admitted July 8, 2019, at Trial as New Mexico's Ex. 38).

         307. In the Letter from Pratt, Mr. Pratt states that Real Estate Law is a “powerhouse law firm” and that Mr. Pratt has had “numerous victories against lenders.” Real Estate Law Welcome Documents at 1.

         308. The “Together, We are a Team” document explains that the FDD uses many strategies to postpone sale dates, directs homeowners to send communications from the lenders' legal department “immediately” to the FDD. Real Estate Law Welcome Documents at 2.

         309. The “Do's and Don'ts” document instructs the homeowner to pay his or her mortgage if he or she can afford it, tells the homeowner not to provide his or her lender with financial information without contacting Real Estate Law, and asks that the homeowner not telephone Real Estate Law unless for emergencies, like an immediate foreclosure. Real Estate Law Welcome Documents at 3.

         310. Real Estate Law told L. Madrid that it would help him reduce his monthly mortgage payments. See July 8 Tr. at 105:11-15 (L. Madrid); id. at 174:13-17 (Anaya-Allen, L. Madrid); Email from Keith Anthony to Larry Madrid at 1 (sent May 15, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 50)(“Madrid May 15 Email”).

         311. The FDD package includes two mortgage authorization forms that authorize Balanced Legal Group to act on L. Madrid's behalf to resolve his mortgage problems. See Madrid FDD Email and Package at 6, 7 (sent November 6, 2012)(admitted at Trial July 8, 2019, as New Mexico's Ex. 42).

         312. The mortgage authorization forms state: “This form will serve to acknowledge that the captioned mortgagor has authorized our firm, Balanced Legal Group to act in their behalf to resolve their mortgage problems.” Madrid FDD Email and Package at 6, 7313. L. Madrid and M. Madrid learned that Real Estate Law was not negotiating a loan modification on their behalf when M. Madrid called JP Morgan Chase and JP Morgan Chase told her that no loan modification application was in process. See July 8 Tr. at 212:2-214:9 (Giandomenico, M. Madrid).

         314. L. Madrid sent his foreclosure complaint to Real Estate Law and expected help with his foreclosure matter. See July 8 Tr. at 191:19-192:2 (Anaya-Allen, Madrid).

         315. Real Estate Law filed a mass tort lawsuit against JP Morgan Chase, but never told L. Madrid the case's outcome. See July 8 Tr. at 186:13-187:2 (Anaya-Allen, L. Madrid); id. at 193:25-194:3 (Anaya-Allen, L. Madrid).

         316. On August 27, 2012, Branco, using the email sam@balancedlegalgroup.com, sent L. Madrid an FDD package and explained that L. Madrid had access to the FDD to postpone his sale date. See Email from Sam Branco to Larry Madrid at 1-2 (sent August 27, 2012)(admitted July 8, 2019, at Trial as New Mexico's Ex. 39)(“Madrid Aug. 27 Email”).

         317. Real Estate Law voluntarily dismissed the “Chase Mass. Tort suit” and wrote L. Madrid: “Currently, we have dismissed the case and are awaiting to refile. It is our intention to gain the most favorable outcome for our clients; therefore we are seeking to have this matter assigned to an overseeing judge who we believe will render a more favorable judgment for all litigants.” Email from Ashley Hanu to Larry Madrid at 1 (sent January 17, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 44)(“Madrid Jan. 17 Email”). See July 8 Tr. at 187:3-12 (Anaya-Allen, L. Madrid).

         318. Real Estate Law voluntarily dismissed a lawsuit on August 17, 2012, and wrote Madrid: “We have dismissed the case and are awaiting to refile.” Madrid Jan. 17 Email at 1; July 8 Tr. at 107:11-12 (Madrid). See id. at 187:3-12 (Anaya-Allen, Madrid).

         319. L. Madrid was a plaintiff in Acevedo v. JP Morgan Chase Bank, N.A., which Mr. Pratt voluntarily dismissed in August, 2013. See July 8 Tr. at 203:6-17 (Kennedy, L. Madrid); Acevedo v. JP Morgan Chase Bank, N.A., Notice of Dismissal Pursuant to Federal Rules of Civil Procedure 41(a) or (c) at 254; Arzakanyan Depo. at 70:4-6.

         320. On November 6, 2012, Real Estate Law sent L. Madrid an FDD Package and asked him to print the attachment, complete it, and return it within ten days, or otherwise the processing of his foreclosure defense would be delayed. See Madrid FDD Email and Package at 1-2.

         321. In May, 2013, L. Madrid received an email from Real Estate Law in which it stated that it believed that it could use fraudulent activity and illegal lending on his home mortgage to get a lower payment and “forestall foreclosure.” Madrid May 15 Email at 1.

         322. Real Estate Law requested that L. Madrid and M. Madrid send his foreclosure summons, and discussed with him the provision of its loan modification services, see Madrid Notes re Summons Conversation at 1 (dated July 8, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 49), but L. Madrid and M. Madrid did not get a loan modification or help with their foreclosure. See July 8 Tr. at 191:19-192:7 (Anaya-Allen, L. Madrid); id. at 194:6-12 (L. Madrid).

         323. L. Madrid and M. Madrid moved from the house on Menaul and into a rental. See July 8 Tr. at 217:7-218:22 (Giandomenico, M. Madrid).

         324. In written communications with L. Madrid or enclosures with those communications, Mr. Pratt did not include the disclosures that the MARS Rule requires. See Real Estate Law Welcome Documents at 1-4.

         325. L. Madrid's compliance call did not include the required MARS Rule disclosures. See Madrid Compliance Call at 00:00-11:36.

         326. At least two emails from Real Estate Law to L. Madrid contained no disclosures or disclaimers. See Madrid Jan. 17 Email at 1; Email from Ashley Hanu to Larry Madrid (sent January 24, 2013)(admitted July 8, 2019, at Trial as New Mexico's Ex. 46).

         327. Several other correspondences did not contain the specific MARS Rule disclosures. See Madrid Aug. 27 Email; FDD Email and Package at 1; Email from Tutu Gill to Larry Madrid at 1-2 (sent November 26, 2012)(admitted July 8, 2019, at Trial as New Mexico's Ex. 43); Madrid May 15 Email at 1.

         c. Martha Leary.

         328. New Mexico consumer Martha Leary owned and occupied, as a principal place of residence, a home at 6496 Freemont Hills Loop NE, Rio Rancho, New Mexico, 87144. See July 9 Tr. at 230:8-18 (Anaya-Allen, Leary)(reflecting that Leary had to move from her home).[46]

         329. Leary's current residence is unclear.

         330. Leary had trouble making her mortgage payments when the payments increased by $200.00 per month. See Transcript of Trial Proceedings at 230:19-231:1 (Anaya-Allen, Leary)(taken July 9, 2019), filed July 12, 2019 (Doc. 195)(“July 9 Tr.”).

         331. Leary tried unsuccessfully to resolve her payment problems directly with her lender via a mediator. See July 9 Tr. at 231:4-8 (Leary).

         332. Leary attempted a loan modification alone three times and, on November, 7, 2012, went to court, where she received ninety days to become current on her loan. See Pre-Qualification Questionnaire at 2 (dated December 7, 2012)(admitted July 9, 2019, as New Mexico's Ex. 54).

         333. Leary saw an advertisement for Real Estate Law on television, after which she contacted Real Estate Law, and Real Estate Law told her that it could help with the foreclosure. See July 9 Tr. at 231:8-10 (Leary).

         334. Leary signed an Attorney-Client Agreement with Real Estate Law on December 10, 2012, and the agreement provided that Real Estate Law would prepare a complaint with either the Office of the Controller of Currency, the Federal Deposit Insurance Corporation, the Federal Reserve Board, or the National Credit Union Administration. See Attorney-Client Retainer Agreement at 1 (executed December 13, 2012)(admitted July 9, 2019, as New Mexico's Ex. 52)(“Leary Attorney-Client Retainer Agreement”).

         335. At this time, Leary was not in foreclosure. See July 9 Tr. at 247:16-19 (Kennedy, Leary).

         336. The Leary Attorney-Client Retainer Agreement provides for a fee of $3, 000 and states: “Client is not entitled to a refund of any amount.” Leary Attorney-Client Retainer Agreement at 1.

         337. The Leary Attorney-Client Retainer Agreement does not provide for a contingency fee. See Leary Attorney-Client Retainer Agreement at 1-2.

         338. The Leary Attorney-Client Retainer Agreement provides that the complaint will seek remedies for one or more of: fraud, negligent lending, breach of good faith and fair dealing, breach of fiduciary duty, securitization issues, mortgage electronic registration systems issues. See Leary Attorney-Client Retainer Agreement at 1.

         339. The Leary Attorney-Client Retainer Agreement states: “RELC CAN RETAIN CLIENTS FROM ANY STATE BECAUSE IT IS SEEKING RELIEF TO A FEDERAL ENTITY UNDER A FEDERAL PROCESS.” Leary Attorney-Client Retainer Agreement at 2.

         340. The Leary Attorney-Client Retainer Agreement provides for a division of fees between Real Estate Law and Pinnacle Law, and that Pinnacle Law will receive eighty percent of the fee. See Leary Attorney-Client Retainer Agreement at 2.

         341. The Leary Attorney-Client Retainer Agreement states: “PLC is a separate law firm not related to RELC. Client is not retaining PLC.” Leary Attorney-Client Retainer Agreement at 2.

         342. The Leary Attorney-Client Retainer Agreement states “Client also agrees that the laws of the State of California shall govern this agreement and that any disputes arising from this agreement must be adjudicated in California” or contain a Notice Required by New Mexico Law or a Notice of Rescission Rights or Rescission of Rights Form. Leary Attorney-Client Retainer Agreement at 2. See id. at 1-2.

         343. Mr. Pratt is the designated signatory for Real Estate Law on the Leary Attorney-Client Retainer Agreement. See Leary Attorney Client Retainer Agreement at 2.

         344. The Leary Attorney-Client Retainer Agreement does not contain in at least fourteen-point font Real Estate Law's name and address, or the date that Leary signed the Leary Attorney-Client Fee Agreement. See Leary Attorney-Client Retainer Agreement at 1.

         345. Leary paid Real Estate Law $3, 000.00, which she borrowed from her sister. See July 9 Tr. at 233:7-10 (Anaya-Allen, Leary); ...


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