A Court Just Exposed Exactly How Attorney-Model Debt Settlement Works — Every Dollar, Every Rubber Stamp

On March 31, 2026, United States Bankruptcy Judge Kimberley H. Tyson issued a ruling in Lewis v. Law Offices of Amber Florio, PLLC (Adversary No. 22-01166 KHT, U.S. Bankruptcy Court, District of Colorado) that should be required reading for anyone considering, enrolled in, or suspicious of an attorney-model debt settlement program. The court traced every transaction, every communication, and every so-called “attorney review” through Commonwealth Law Group’s own internal database — and what it found was a company that called itself a law firm but operated as a debt-negotiation mill where non-lawyers did all the work and attorneys served as rubber stamps.

What Happened to Jason Dean Clark

Before I walk you through the company’s structure, I want you to meet Jason Dean Clark, because this is ultimately about what happens to a real person when the system works exactly as designed.

By September 2019, Clark — a Colorado resident who had dealt with medical issues and periods of unemployment — owed $55,153 in credit card debt across five creditors: Capital One ($19,942), American Express ($15,708), Citi ($13,912), Synchrony Bank/Gap ($2,711), and PayPal ($3,580). (Ruling at p. 3.)

He signed up with Commonwealth Law Group — which presented itself as a “full-service debt resolution law firm” — for a program requiring $906.90 per month for 48 months. Total estimated payments: $43,530.75, of which $15,438.25 would go to fees. (Ruling at pp. 5, 7.)

The Retainer Agreement promised a lot:

• Attorneys would “directly supervise” all activities (Ruling at p. 5)
• The firm would “advise and represent Client in their defense of litigation” (Ruling at p. 5)
• The firm would “discuss and advise Client as to the bankruptcy option” at any time (Ruling at p. 8)
• The $1,650 retainer fee would cover “the initial work performed by attorneys in crafting and reviewing your specific debt negotiation plan” (Ruling at p. 7)

Here is what actually happened.

The “Attorney Consultation” — $65 for a Brief Phone Call

Attorney Kevin Wang was notified by the LeadTrac system to call Clark after the retainer was already signed. Wang testified his usual practice was to ask whether the client understood the withdrawal amounts and whether they were “aware bankruptcy filing was an option” — but because Wang was not a bankruptcy attorney, “he did not go into the details of bankruptcy.” He was paid $65 for this call. Clark testified he received “some block copy/paste emails” and “no legal matters were discussed, and no advice was given on the call.” (Ruling at pp. 9-10.)

Wang countersigned the Retainer Agreement a week before he spoke to Clark — signing a legal contract with a client he had never talked to. (Ruling at p. 10.)

The “Quarterly Reviews” — $10 Copy-Paste Jobs

Attorney Mark Scheer conducted seven quarterly reviews of Clark’s file, for which he was paid $10 each. The court’s findings about these reviews are devastating:

• Scheer never contacted Clark as part of any quarterly review (Ruling at p. 12)
• Scheer’s first quarterly review (January 1, 2020) noted “no lawsuits or other requests had been assigned to him” — but a demand letter from Vinci Law Office on behalf of American Express was already in the file. Scheer did not notice it. (Ruling at p. 12)
• By the March 31, 2020, quarterly review, American Express had actually filed a lawsuit and served Clark. Scheer made the same notes he always made. (Ruling at p. 14)
• By June 30, 2020, Clark was unemployed. Scheer’s notes did not mention it. (Ruling at p. 15)
• By December 29, 2020, Clark’s payments had failed, two settlements were falling apart, and a non-attorney employee had discussed bankruptcy with Clark. Scheer made the same copy-paste notes and did not reach out. (Ruling at p. 18)
• By December 24, 2021, Clark’s payments had stopped entirely, Commonwealth had flagged him as a “bankruptcy risk,” and Clark had in fact already filed for Chapter 7 bankruptcy. Scheer “did not make any attempt to find out whether Mr. Clark was going to file or had already filed a bankruptcy case. He made the same copy-and-paste quarterly review entry he always made, and he received his $10.” (Ruling at p. 31)

The court’s conclusion: “Perhaps a $10 fee was insufficient to beget a review of the file notes, communication with the client, and consideration of the client’s individual circumstances, but those are essential components of legal advice.” (Ruling at p. 31.)

The Lawsuit Nobody Answered

When American Express, through Vinci Law Office, sued Clark in February 2020, Clark emailed his customer service representative asking “What should I do?!” The representative told him to scan the documents so she could send them to a negotiator — not an attorney. No Class B attorney ever appeared in court or engaged with the litigation on Clark’s behalf. (Ruling at pp. 12-13.)

The Retainer Agreement had specifically promised: “Commonwealth will advise and represent Client in their defense of litigation initiated by creditors or collectors.” (Ruling at p. 5.) The court found this promise was never kept.

The Bankruptcy Question That Was Never Answered

Clark asked about bankruptcy multiple times over 18 months. These questions were documented in the LeadTrac system. No Class B attorney ever discussed bankruptcy with him or advised him on the option. (Ruling at pp. 31-32.)

The only person who gave Clark any bankruptcy information was Ted Percival, a non-attorney customer service representative at Commonwealth Servicing. Percival told Clark that Chapter 13 payments would be “affordable” but would mean paying back “close to the full amount.” (Ruling at pp. 16-17.)

Where Did the Money Go?

Over two years, Clark deposited $21,765.60 into his dedicated account at Global Client Services. The court traced every dollar (Ruling at p. 24):

For his $12,297.07, here is the legal work Clark received: Attorney Wang made one brief phone call ($65) and reviewed one settlement ($10). Attorney Scheer conducted seven quarterly reviews ($10 each), two annual reviews ($40 each), and four settlement reviews ($10 each). Total attorney compensation: Wang got $75. Scheer got $190. (Ruling at p. 24.)

That is $265 worth of attorney time — out of $12,297.07 paid. The rest went to Commonwealth Servicing, the entity where non-lawyers did all the actual work.

The Assembly Line the Court Exposed

What makes this ruling extraordinary is that Judge Tyson didn’t just rule against Commonwealth Law Group — she traced the entire operation through the company’s own LeadTrac database, which the court found to be “the most credible evidence of what Commonwealth representatives did or said during the relevant time periods.” (Ruling at p. 4, fn. 1.)

Here is the assembly line the court documented:

The court found the negotiators “did not speak to the Class B attorneys before or after a settlement was reached. Class B attorneys were not involved until after terms were fully negotiated with the creditors.” (Ruling at p. 28.)

“Just as there is no ‘I’ in ‘team,’ there is no Class-B-attorney-supervised ‘team’ in ‘I.’ Mr. Parisi was not exaggerating or otherwise mischaracterizing his role in obtaining the settlement. He was, in fact, the one who did the work to obtain the settlement, without any involvement of a Class B attorney. The settlement was presented to Mr. Clark as a fait accompli, and Mr. Clark authorized payment on it fifteen minutes before Mr. Scheer clicked the button to approve it.”— Judge Kimberley H. Tyson, Ruling at p. 28

The Three-Prong Legal Demolition

Colorado’s Uniform Debt Management Services Act (CUDMSA) requires debt management providers to register with the state. Commonwealth Law Group claimed it didn’t need to register because its services fell under the “legal services exclusion” — an exemption for services provided by licensed attorneys in a genuine attorney-client relationship.

The Colorado Supreme Court in Coffman v. Williamson, 348 P.3d 929 (Colo. 2015), established that this exclusion has three requirements. Judge Tyson analyzed each one and found Commonwealth Law Group failed all three.

Prong 1: Were the Providers Colorado-Licensed Attorneys?

Scheer and Wang were Colorado-licensed attorneys, but they weren’t the ones doing the debt management work. The negotiators and customer service representatives were.

Commonwealth Law argued Scheer and Wang were “employers” of the non-attorney workers because they owned 0.1% equity units (Class B shares). The court was unpersuaded: “The Court questions whether nominal stock ownership qualifies a person as an employer of that company’s employees. Someone who owns one share of IBM stock would not be considered an employer of IBM’s employees.” (Ruling at p. 28, fn. 21.)

Even if they were technically employers, Colorado law requires the non-attorney to work for the attorney “in substance, not just in name — and under the attorney’s supervision.” The court found that supervision was “conspicuously absent.” (Ruling at pp. 28-29, quoting Coffman v. Williamson, 348 P.3d at 938.)

“The substance of their relationship reveals that ‘the tail wags the dog.’ Even the limited record before us now demonstrates that [the firm] is not acting for the lawyer in rendition of the lawyer’s professional services; rather, the lawyer is acting for [the firm].”— Colorado Supreme Court, Coffman v. Williamson, 348 P.3d at 938-39, quoted in Ruling at p. 28

Prong 2: Were Legal Services Actually Provided?

The court examined every type of service rendered and found none of them constituted legal services:

• No document drafting: The retainer agreement was prepared by salesperson Minton, not an attorney. “It was already completed and signed by Mr. Clark when Mr. Wang was alerted to make the Attorney-Client Consultation Call.” (Ruling at pp. 29, fn. 23.)
• No court appearances: When American Express sued Clark, no Class B attorney appeared or even engaged with the litigation. (Ruling at p. 29.)
• No legal advice: Asking if someone is “aware bankruptcy filing was an option” without explaining it is not legal advice — “it’s closing a sale.” (Ruling at p. 30.)
• No consideration of individual circumstances: Quarterly reviews were copy-paste jobs that did not reflect Clark’s unemployment, the pending lawsuit, his missed payments, or his bankruptcy questions. “An attorney cannot give legal advice without considering the client’s individual circumstances.” (Ruling at p. 31.)
• No meaningful settlement review: Attorneys checked whether settlements fell “within Commonwealth Law’s parameters” — a company formula, not a legal judgment. “Determining whether a settlement falls within Commonwealth Law’s parameters may constitute business advice or business services to Commonwealth Law, but it does not constitute legal advice or legal services to the client.” (Ruling at p. 32.)

Prong 3: Was There a Real Attorney-Client Relationship?

The Retainer Agreement said all the right things about attorney supervision, litigation defense, and bankruptcy counseling. The court listed each promise and then documented how none were kept:

• “Attorneys directly supervise the activities they do not directly perform” — They did not. (Ruling at pp. 5, 33.)
• “Commonwealth will advise and represent Client in their defense of litigation” — When Clark was sued, no attorney appeared. (Ruling at pp. 5, 33.)
• “Commonwealth attorneys are immediately notified of litigation” — The AmEx lawsuit was never assigned to any Class B attorney. (Ruling at pp. 31, 33.)
• The retainer fee covers “the initial work performed by attorneys in crafting and reviewing your specific debt negotiation plan” — The plan was prepared by a salesperson before any attorney was involved. (Ruling at pp. 7, 33.)
• “Commonwealth is a full-service debt resolution law firm which provides services including debt negotiation and restructuring and bankruptcy services” — No bankruptcy services were ever provided. (Ruling at pp. 23, 33.)

The court’s conclusion was unsparing: “Not one of the above-listed attorney representations was accurate.” (Ruling at p. 33.)

“Class B attorneys’ role was limited to that of a rubber stamp. There was no legitimate attorney-client relationship between Class B attorneys and Commonwealth clients.” (Ruling at p. 34.)

“Commonwealth Law was a law firm in name only, a facade.” (Ruling at p. 34.)

The Ethics Catch-22

There’s a devastating footnote in this ruling that deserves its own section. Footnote 27 (Ruling at p. 34) delivers the kill shot:

The Cost Comparison That Should Make You Angry

The court made this point explicitly, and it bears repeating with full context:

The court stated it plainly: “Mr. Clark paid far more to Commonwealth Law than he would have paid a Colorado bankruptcy attorney. It was not attorneys’ services that Mr. Clark could not afford, but Commonwealth Law’s services.” (Ruling at p. 34.)

Clark paid over $12,000 for a program that delivered $265 worth of attorney time, left all five debts unresolved, failed to defend him in a lawsuit, and never provided the bankruptcy advice he repeatedly asked for — bankruptcy advice that would have ended his debt crisis two years earlier for a fraction of the cost.

The Damages

Because neither Commonwealth Law nor Commonwealth Servicing was registered as a debt management provider in Colorado — the very registration they were trying to avoid through the attorney-model loophole — the court awarded damages under two provisions of CUDMSA:

Both Commonwealth Law Group and Commonwealth Servicing Group are jointly and severally liable — meaning Clark’s bankruptcy trustee can collect from either entity. Plus reasonable attorney fees and costs, which the court will award separately. (Ruling at pp. 37-38.)

Red Flags: How to Spot a Similar Operation

Based on the court’s findings, here are the specific warning signs that an “attorney-model” debt settlement company may be operating the same way Commonwealth Law Group did:

• You signed a retainer before speaking with any attorney. Clark’s agreement was prepared by a salesperson, presented by a notary, and counter-signed by an attorney a week before they spoke. (Ruling at pp. 4-5, 10.)
• Your “attorney consultation” was a brief, generic phone call. Wang’s call confirmed program details and asked if Clark was aware of bankruptcy — without explaining it. (Ruling at pp. 9-10.)
• Your primary contact is a customer service representative, not a lawyer. Clark communicated with Laidlaw, Lugo, Gastonguay, and Percival — none of them attorneys. (Ruling at pp. 10-22.)
• Negotiations are handled by non-attorney “negotiators.” Pena, Parisi, Frampton, and Morceau — all non-lawyers — did all the settlement work. (Ruling at pp. 10-20.)
• You’ve never had a substantive legal conversation with your assigned attorney. Scheer never contacted Clark as part of any review. (Ruling at pp. 12, 30-31.)
• When you asked about bankruptcy, nobody gave you a real answer. Clark asked multiple times over 18 months. No attorney responded. (Ruling at pp. 31-32.)
• When you were sued, no attorney appeared for you. Commonwealth’s agreement promised litigation defense. When AmEx sued, Clark was told to send documents to a non-attorney negotiator. (Ruling at pp. 5, 12-13.)
• Your monthly payments seem to drain completely each month. After Clark’s seventh payment, his account balance was $0.01. Fees consumed nearly everything. (Ruling at p. 14.)
• The retainer agreement itself warns that courts might not recognize the arrangement. Commonwealth’s agreement included a disclaimer that “a court or courts might determine” the non-attorney relationship isn’t attorney-client protected. They knew. (Ruling at p. 6.)

Why This Ruling Matters Beyond Commonwealth Law Group

Commonwealth Law Group was not unique. As the court noted, Wang worked for at least 14 similar law firms using the same LeadTrac system: “Anchor, Colonial, Frontier, Phoenix, Pioneer, Canyon, Summit, Golden, Whitestone, Option One, Hartland, Slate, Strong, Spring, and Glacier Bay. Each firm did the same or similar work as Commonwealth Law, using the same LeadTrac system. Mr. Rogus hired Mr. Wang for each.” (Ruling at p. 10, fn. 2.)

This is not an isolated bad actor. This is an industry template. The attorney-model loophole — where a law firm’s letterhead is used to circumvent the FTC’s ban on upfront fees for debt settlement — has been the subject of enforcement actions by the FTC (against Morgan Drexen), state attorneys general (against Legal Helpers Debt Resolution), and the CFPB (against Strategic Financial Solutions). This ruling adds a new dimension by providing the most granular documentation of exactly how the scheme operates internally.

My Take

I’ve been covering the debt relief industry since the 1990s. I’ve seen the same predatory structures repackaged under new names — from credit repair mills to debt settlement operations to this attorney-model scheme. But Judge Tyson’s ruling is different. She had something most enforcement actions don’t: the company’s own internal database showing exactly who did what, when, and for how much.

What strikes me hardest about this case is not the structure — I’ve seen that before. It’s Clark’s emails. When he writes “I am almost busted now unfortunately and am having to look at bankruptcy options” in November 2021, and the attorney reviewing his file approves a new settlement without even acknowledging that message — that is the system working exactly as designed. The attorneys were not negligent. They were performing their assigned role: clicking “approved” for $10.

The court put it perfectly: the relationship between the attorneys and the clients was a “sham relationship.” The real intermediaries were the non-lawyer employees of Commonwealth Law and Commonwealth Servicing.

If you are currently enrolled in a debt settlement program that was sold to you as “attorney-based” or “law firm services,” ask yourself: When was the last time you had a substantive conversation with a licensed attorney about your specific situation? Has an attorney ever discussed bankruptcy with you in detail? If you were sued, did an attorney appear for you?

If the answer to any of those is no, you may be in a program that is structured exactly like Commonwealth Law Group’s. And as this ruling shows, there may be legal consequences for the company — and better options for you.

Start by understanding all your options — including the ones your debt settlement company won’t tell you about. If the math doesn’t work, take the two-minute bankruptcy quiz. Federal Reserve research shows filers recover faster than those who don’t file. And if you want someone who will actually look at your situation and give you an honest opinion, talk to Damon Day — he’s not selling a program, he’s a debt coach who will tell you the truth.

If you know someone who is enrolled in or considering an attorney-model debt settlement program, send them this article. The more people who understand how these operations actually work, the harder it becomes for the next Commonwealth Law Group to sell the same facade.

As always, this is my informed perspective based on decades in the industry and the court record. Your situation is unique — I want you to have all the information so you can make an informed decision that’s right for you.

Read the Full Ruling

I’m publishing the complete 38-page ruling so you can read every word yourself. This is the kind of document that deserves to be public — not buried in a court database.

Download the Full Ruling (PDF) — Lewis v. Law Offices of Amber Florio, PLLC, Adversary No. 22-01166 KHT, U.S. Bankruptcy Court, District of Colorado, Judge Kimberley H. Tyson, filed March 31, 2026.

The ruling is also available through the U.S. Government Publishing Office (GovInfo).

FAQ

What is an “attorney-model” debt settlement company?

It’s a debt settlement operation that partners with or operates through a law firm to create the appearance of legal services. As this court found, the law firm may be “a law firm in name only, a facade” — with non-lawyers doing all the work while attorneys serve as rubber stamps. The structure is designed to exploit state exemptions that allow attorneys to provide debt management services without registering with regulators. (Ruling at p. 34.)

Is Commonwealth Law Group still operating?

According to the ruling, by the time of trial, Commonwealth Law Group “was in the process of winding down its operations” and had accepted its last client in 2021. However, the court noted that attorney Kevin Wang worked for at least 14 similar firms using the same operational model and database system. (Ruling at pp. 3, 10, fn. 2.)

What’s the difference between “legal information” and “legal advice”?

This is a critical distinction the court drew. Asking someone “are you aware bankruptcy is an option?” is legal information — a general fact anyone can share. Legal advice requires an attorney to consider the client’s individual circumstances and make a specific recommendation. As the court stated: “Discussing only one option — the Commonwealth Law program — is not giving legal advice; it’s closing a sale.” (Ruling at p. 30.)

What should I do if I think I’m in a similar program?

First, request a detailed accounting of exactly where your monthly payments have gone — how much to fees, how much to creditors, how much to the dedicated account company. Second, ask yourself whether any attorney has ever substantively discussed your options, including bankruptcy, based on your specific financial situation. Third, consult with an independent debt coach or a bankruptcy attorney who can evaluate whether you’re in the right program for your circumstances. You may have legal rights under your state’s debt management services act.

Can I sue my debt settlement company if it operates like this?

This depends on your state’s laws. In Colorado, CUDMSA provides a private right of action with treble damages and attorney fees for consumers harmed by unregistered debt management providers. Many other states have similar consumer protection statutes. If you believe your debt settlement company is operating as a facade — using attorneys as window dressing while non-lawyers do all the work — consult with a consumer protection attorney in your state. This ruling may provide a roadmap.

For a real-world example of this exact pattern, see how the NY Attorney General just shut down a fake law firm that sent 35,000 letters to tenants facing eviction — same playbook, different victims.

Steve Rhode The Get Out of Debt Guy | Consumer Debt Expert

Consumer debt expert & investigative writer. Personal bankruptcy survivor (1990). Washington Post award-winning author. Exposing debt scams since 1994.

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