I want to walk you through a 33-page legal document that the New York Attorney General's office released this week. I'm going to take my time with it, because every time you think you've hit the worst part, it gets worse.
This is the Assurance of Discontinuance — the official findings — in the matter of Consumer Legal Group, PC, doing business as Tenants Counsel Network. I've spent 30 years documenting predatory debt relief operations. I ran a credit counseling organization from the inside. And this document is one of the most detailed blueprints I've ever seen of how the industry actually works behind the scenes.
Not how they say it works. How it actually works.
I'm going to take you through it piece by piece, because most people will never read a 33-page legal filing. And the people who need to understand this the most — people in financial trouble who are about to get a letter or a phone call from someone offering to help — will never see it.
Until now.
it starts with a disbarred attorney and a merchant cash advance operator
The story begins in California with a man named Tony Diab.
Diab created something called Litigation Practice Group — a law firm that charged people monthly subscription fees for debt relief services. In 2019, Diab was disbarred after he was caught misappropriating a client's $375,000 settlement payment and forging a judge's signature. (Assurance, paragraph 4)
You'd think getting disbarred for stealing a client's money and forging a judge's signature would end someone's career in legal services. It didn't. After his disbarment, Diab installed a licensed attorney named Daniel Steven March as the figurehead CEO of Litigation Practice Group. March's name was on the door. Diab ran the business. (paragraph 4)
When LPG eventually filed for bankruptcy in March 2023, it came out that Diab had been running a Ponzi scheme and embezzling funds. He admitted it in bankruptcy court declarations. March was also disbarred. (paragraph 6)
Now here's where it gets interesting.
A man named Shloime (Solomon) Feig worked in the merchant cash advance industry — the companies that provide fast financing to businesses in exchange for a cut of future revenue. Feig had been providing merchant cash advances to Diab's companies. In 2021, when LPG started having liquidity problems, Feig increased his financing. (paragraph 5)
And as Feig pumped more money into Diab's operation, something happened.
Feig — a non-attorney — became "intrigued by Diab's business model." (paragraph 5)
Let that sit for a second. A merchant cash advance operator who was providing financing to a disbarred attorney’s law firm became “intrigued by Diab’s business model.” Important context: the AG’s office found “no evidence that Feig was aware of the Ponzi scheme” Diab was running (paragraph 7). But Feig saw the business model — and decided to build his own version.
the blueprint: an email from a disbarred attorney
In return for the financing, Diab began consulting with Feig on how to build his own version of LPG. The Attorney General's investigation found that on January 5, 2022, Diab sent Feig an email proposing specific business models. (paragraph 5, pages 2-3)
Diab's proposals included:
A model where a non-attorney would be paid through non-legal corporations that handled payment processing and marketing — so the non-attorney would control the clients' money.
A "friendly attorney" variant where the non-attorney would choose an attorney to hold the position of majority shareholder — specifically to prevent a hostile takeover by other attorneys who might actually want to practice law ethically.
Read that second one again. The structure was designed from the start to make sure the figurehead attorney could never be overruled by real lawyers with real concerns about real clients.
Feig picked the "friendly attorney" model. (paragraph 8)
the cast of characters
On May 18, 2022, Feig — with the help of lawyers and non-lawyers — incorporated Consumer Legal Group, PC in New York. A for-profit law firm offering debt relief and debt validation services. (paragraph 8)
Here's who Feig assembled:
Aryeh Weber — a licensed New York attorney who primarily practiced real estate transactions. He had no experience in consumer law. He was a family friend and neighbor of Feig’s brother-in-law. Feig asked Weber to serve as the Founding Partner, President, and Principal of CLG. Under New York law, law firms must be owned and managed by licensed attorneys. So Weber’s name went on everything — even though CLG was incorporated with significant involvement from Feig (paragraph 8). (paragraphs 10-11)
Sam Geiger — Feig's brother-in-law. He became the founding Chief Financial Officer. (paragraph 9)
Then Feig created two companies that a non-attorney could legally own and that would have control over CLG's actual assets:
LGS Clearing House — exclusively handled payment processing for CLG. This meant Feig's company controlled the list of clients and all their payment information.
LGS Holdco, LLC — handled marketing and client acquisition for CLG.
So the law firm was technically owned by an attorney. But the clients’ money, the client list, and the marketing that brought clients in were all handled through companies created by a non-attorney merchant cash advance operator (paragraphs 12-13).
This was the model. In my experience, this is how it’s done. Every time you see a “law firm” offering debt relief services, this is the structure you should be wondering about.
when debt relief wasn't enough: enter the tenants
Here's the part that should make your stomach turn.
After finding CLG's model "lucrative," Feig began exploring other areas of law where the friendly attorney model might work. He decided to open a business targeting tenants in housing court using the name Tenants Counsel Network. (paragraph 13)
On December 22, 2023, CLG received approval to do business as Tenants Counsel Network. Same structure. Weber's name on the filings. Feig making the management decisions — hiring, financing, marketing. (paragraph 14)
TCN's business model depended on getting a large volume of clients. There was just one problem:
There were originally no landlord-tenant attorneys on staff.
Not bad attorneys. Not inexperienced attorneys. Zero. None. The firm had no one who could actually do the work. Their approach was to first invest in marketing. Hire the attorneys later. Maybe.
the website: fake everything
TCN launched its website on or around December 19, 2023. (paragraph 18)
The website included:
Fictional testimonials from fake customers. People who did not exist, endorsing services that did not yet exist, from a firm that had no attorneys to provide them. (paragraph 18)
Claims of "a comprehensive and nuanced command of NYC's housing laws" and "thousands of dollars of overcharges recovered" for tenants — despite having few attorneys, none with landlord-tenant expertise, and no records of recovering anything for anyone. (paragraph 20)
No physical address listed. No attorneys' names disclosed. The website didn't even identify itself as attorney advertising. (paragraph 19)
And here's a small detail that tells you everything about the level of care these people put into their fraud: TCN's official registered name was "Tenants Counsel Network," but publicly they used "Tenant Counsel Network" — dropping the "s." This wasn't a typo. It made the firm much harder to find in the Department of State's public business entity database. (paragraph 15)
cracking the court system: the captcha bypass
Now they needed victims. And they knew exactly where to find them.
TCN hired a man named Nick Starlacci to bypass the CAPTCHA protection on the New York City Housing Court's online filing system. The CAPTCHA exists specifically to prevent automated scraping. Starlacci bypassed it to extract the names and contact information of tenants with pending eviction cases. (paragraph 21)
Think about that. A court system put up a security measure to protect people facing eviction from exactly this kind of targeting. And TCN hired someone specifically to defeat it.
Then they turned that data into a mailing operation.
35,569 letters designed to terrify
TCN sent or caused to be sent 35,569 solicitation letters to tenants facing eviction. (paragraph 22)
The letters came in several variations, but they shared common features. They all conveyed a sense of urgency. Most began with the sentence: "a public record search shows that your landlord has filed a proceeding against you in NYC housing court." They advertised "experienced attorneys." They promised TCN would "stop at nothing" and "do everything in their power" to defend their "NYC Community." (paragraph 23)
One version bore a stamp at the top corners saying URGENT — LEGAL ACTION and began: "YOU ARE BEING EVICTED." (paragraph 24)
The letters were designed to look like official court documents. The envelopes sometimes had a Massachusetts return address connected to a third-party direct mailing company. The telephone numbers were all virtual VOIP numbers not associated with any publicly found person or address. (paragraph 28)
And here's the detail that makes my blood boil:
For many tenants, TCN's letter arrived before the actual court papers. It was the first notice the tenant received about their upcoming eviction case. (paragraph 25)
This matters because New York City has a Right to Counsel program that provides free attorneys to income-eligible tenants facing eviction. But those free attorneys don't meet with unrepresented tenants until the first court date. By sending letters before court papers arrived, TCN was cutting tenants off from learning that free legal help existed — and replacing it with paid services from a firm that had no qualified attorneys. (paragraph 25)
the fake attorney: J. Clarksburg
Over 1,100 of these letters were signed by "J. Clarksburg" — a name purporting to be an attorney.
J. Clarksburg is an entirely fictitious person. There is no attorney with that name licensed in the state of New York. (paragraph 27)
Over a thousand people facing eviction — many of them terrified, many of them unsure of their rights — received a letter with a fake attorney's name on it, from a firm that had no attorneys qualified to help them, offering services that didn't exist, designed to prevent them from finding the free help that was already available.
the shell company: unified resolutions
In March 2024, TCN decided the letters weren't bringing in enough clients. So they built a cold-calling operation. (paragraph 30)
TCN obtained tenant phone numbers from LexisNexis, then recruited a director of sales who brought along former colleagues. They were all hired as 1099 employees. The compensation was negotiated directly with Feig. The CRM system and all solicitation tools were purchased by TCN. (paragraph 30)
But here's the problem: law firms in New York aren't supposed to have internal sales teams. So TCN did what any legitimate business would do.
Just kidding. They created a shell company.
TCN told the marketing team that they were not allowed to have an in-house sales operation because they were a law firm. Instead, they told the team they would be working for a company called Unified Resolutions. (paragraph 32)
At the time this name was introduced, Unified Resolutions did not exist as a company. TCN had already created email addresses under the Unified Resolutions name before the entity was even formed. (paragraph 31)
Eventually, TCN told the director of sales to actually form a company called Unified Resolutions. But even after that:
The employees worked out of an office rented by CLG
They were on CLG's payroll as independent contractors
Their email was provided by CLG
They performed work exclusively for TCN
The company was managed by TCN
Feig personally checked in with the supervisor once a week
Neither Unified Resolutions nor TCN was registered as a telemarketer with the State of New York, as required by law. Through this operation, TCN completed 21,788 outbound cold calls to tenants facing eviction. (paragraph 34)
Some tenants reported receiving over a dozen phone calls, with multiple calls in a single day. (paragraph 35)
the "client managers" who weren't attorneys
The marketing team received limited training. They called themselves "client managers." They told some potential clients that TCN offered subsidized legal services — it didn't. Some tenants came away believing TCN was a nonprofit legal services provider. (paragraph 36)
These non-attorney "client managers" explained the terms of the Engagement Agreement to potential clients and led them to sign it — without consultation or explanation from an actual attorney. When potential clients asked questions about the agreement, some were given incorrect information. (paragraph 37)
When tenants asked about the firm's legal staff, they were told there were "in house" private attorneys and that once assigned, an attorney would stay with their case for life. This was false. Many TCN tenants didn't know beforehand who would show up in court. It was often a per diem attorney who knew nothing about the case. (paragraph 38)
When one caller asked about the identities of TCN's attorneys, a representative told her they "can't say, there are too many to name."
At its largest, TCN had six attorneys on staff. (paragraph 39)
what happened to the actual clients
This is the part that's hardest to read.
TCN's success at marketing was "greater than the success it achieved in representing tenants in court." (paragraph 42)
Ms. H paid TCN a monthly fee for three months. She never talked to an attorney. Her case kept being adjourned. When she called TCN, it went to voicemail. Nobody called her back. (paragraph 43)
Ms. E retained TCN and then, four months later, asked the court for permission to fire them — because she had never had the opportunity to meet with a TCN attorney. (paragraph 43)
In another case, TCN put in a notice of appearance the day before court, claiming to represent a tenant who was receiving chemotherapy. TCN then failed to appear in court. (paragraph 46)
A judge — Hon. Schiff — issued a decision on May 21, 2024, finding that TCN had failed to appear in court and that it had done so in other cases as well. (paragraph 45)
The AG's review of court files found numerous other examples: attorneys missing court appearances, tenants who entered into agreements without assistance from an attorney, tenants who had no meaningful conversations with an attorney despite paying for representation. (paragraph 47)
One tenant informed the court that she did not want TCN to represent her, calling them a "scam" — immediately after TCN had filed a notice of appearance claiming to represent her. (paragraph 48)
TCN also repeatedly filed "Consent to Change Attorney" forms to swap out attorneys on cases — a practice a judge (Hon. Gurung) found in September 2024 was not permitted. Attorneys may not drop clients by stipulation; they must seek permission from the court by filing a motion to withdraw. (paragraph 49)
the settlement — and the $15 million question
When the Attorney General served notice of proposed litigation on June 18, 2024, TCN agreed to stop taking new clients. On July 20, 2024, they entered an interim Assurance of Discontinuance. (paragraphs 51-52)
The final settlement requires $172,257 in refunds to former TCN clients, a $25,000 penalty against CLG, and a $10,000 personal penalty against Weber. Weber must resign from the bar and close his law office by July 31, 2026. CLG is banned from telemarketing in New York for five years. (paragraphs 60-61)
But here's the number that jumped out at me:
On September 23, 2024, Feig withdrew from doing business with CLG by settling through two of his companies for $15 million for "alleged services rendered and financing provided." (paragraph 54)
$15 million. A merchant cash advance operator who provided financing and services to the firm settled his exit for $15 million. The victims — the tenants who were paying monthly fees for attorneys who never showed up — got $172,257 to split between them.
Feig is not a named respondent in the final Assurance. The AG's office noted they found no evidence Feig knew about Diab's Ponzi scheme. But the Assurance also notes that Feig "knew or should have known" that a lawyer cannot partner with a non-lawyer when the activities involve practicing law. (paragraph 7)
The respondents must cooperate with the AG's office in any ongoing investigation into Feig or related entities. (paragraph 60h)
why I'm showing you all of this
I didn't write this to scare you. I wrote it because this is what the debt relief industry looks like when someone finally pulls back the curtain — and this case is more documented than most. Most of the time, the curtain never gets pulled back.
I ran a credit counseling organization. I have watched this exact model — non-attorney controls a law firm, figurehead attorney on the paperwork, marketing machine out front, no actual legal work behind it — repeat itself across the industry for decades. The labels change. Debt settlement. Debt validation. Credit repair. Student loan relief. Timeshare exits. And now tenant eviction defense.
The predators don't care what kind of trouble you're in. They care that you're in trouble. They care that you're scared. And they know that when you're scared, the first person who sounds like they can help will get your credit card number before you think to ask questions.
Here's what I want you to take away:
If someone contacts you unsolicited about a legal or financial problem, they are almost certainly not the ones who will actually help you. The legitimate help — legal aid offices, Right to Counsel programs, consumer protection agencies — doesn't need to scrape court records and cold-call you at your lowest moment.
If you're facing eviction in NYC: Call Legal Services NYC at 917-661-4500. The Right to Counsel program provides free attorneys to income-eligible tenants. You don't need to hire anyone.
If you're dealing with debt: Talk to Damon Day for a free phone call before signing anything with any company. Damon is the one person I trust to walk you through your options without trying to sell you something.
Read the actual document. I linked to the full Assurance of Discontinuance throughout this piece. It's 33 pages and it reads like a crime novel. Every claim I made here is sourced to specific paragraphs. This isn't my opinion — this is what the Attorney General found.
The help is real. It's free. And the people offering it don't need to bypass a CAPTCHA to find you.
—Steve
If you know someone who’s in financial trouble or facing eviction — especially in New York — forward this to them. These operations move fast. The only thing faster is someone who cares enough to hit send.
Read the full story with action steps at GetOutOfDebt.org.
You can read every page of the legal document yourself. It's public. I think you should.