Intake Fraud

Client Acquisition
What You Need To Know About Protecting Your Law Firm
Mikal October 10,

Watts Bellagio Hotel 2023
Las Vegas, Nevada
1
Client Acquisition
A. Red Flags
That Something is Rotten in the State of Denmark
B. Our Investigation
What We’ve Learned Since March of 2023
C. Cleaning Up the Mess
How We What Prevent Intake Fraud in the Future 2
A. Red Flags
1. 2010 - BP Oil Case – 6. 2013 – Reported Opinions re: Fall Out &
United States v. Mikal Watts 2022 Dismissed Bellwether Plaintiffs
2. 2010 – Keeping Your Ears Open - 7. 2022 – The Rise of Litigation Funders &
2022 Hearing of Lead Gen Problems 2023 – Arizona ABS Firms Funding Intake
3. 2020 –Keeping Your Eyes Open - 8. 2022 - TCPA Suits Filed vs Ethical Firms
2022 - Seeing Misleading Lead Gen Ads Who Know Not to Code Call
4. 2020 – Internal Law Firm Data – No Way 9. 2022 - The McClennyMoseley Persecution
to Explain it Without Intake Fraud 2023 in the State of Louisiana
5. 2020 – The Exponential Increase in the 10. 2022 – An NEC Client Call, a CL Client &
2022 - Prevalence of Duplicate Sign Ups 2023 “The Lady from Florida”
3
9. 2022 - 2023 - The McClenny Moseley Persecution in the State of Louisiana
Hon. Anthony Battaglia
4
Hon. Anthony Battaglia
5
Hon. James D. Cain

W.D. Louisiana
6
7
M.J. Michael North

E.D. Louisiana
8
M.J. Michael North

E.D. Louisiana
9
M.J. Michael North

E.D. Louisiana
10
M.J.. Kathleen Kay

W.D. Louisiana 11
12
13
10. 2023 – An NEC Client Call, A CL Client & “The Lady from Florida”
14
10(A) - NEC Client Town Hall
15
10(B) – A CL “Client” Told Caseworks $30,000 Offered
16
10(C) – “The Lady From Florida”
Insisted She Needed to Meet with Me and Only Me
Flew from Florida to San Antonio to Meet With Me
Because of a conflict, She Met with Alicia O’Neill instead
Alicia Taped it as She Admitted to Taking Part in a Fraud
“An Indian guy” called, paid her $500 to fake a claim
Said She Would make $30,000 in settlement in < 90 days
She Said We “Were Part of a Fraud”; wants her $30,000
Family Upset too – Zantac, NEC, Talc, Camp Lejeune
She Knows This b/c She Got a “Finders Fee” for them 17
18
19
20
Client Acquisition
A. Red Flags
21
1. The Anatomy of Plaintiff Recruitment – 2003 - 2013
Marketing Media
$$$ Law Firms Companies
Law Firm Networks
Retained
Earnings Adam Pulaski
Radio
Bank
Loans
Robert Shapiro
Newspapers
Bob Goldwater
Magazines
Search Engines
Jesse Ferrer
22
Non- U.S. Lead U.S. Lead Generation
$$$ Lawyer Generators Non-Lawyer Brokers
Ad Firms Companies
Law Firm
Retained >105
Earnings
Bank
Loans
Indian
Litigation
Finance
Call
Hedge
Funds
Centers
Arizona
ABS Dean Baker
23
24
U.S. Lead Generation Brokers
25
May
Now
Gavel
Be Guardian
Robert Kenyon 26
The Social Network

Devin S
27
The Social Network

Rachel Luna (USA) & Shahroz Mirza (India)
28
Indian Call Centers
29
Indian Call Centers
30
Indian Call Centers
31
Indian Call Centers
32
Indian Call Centers
33
2. Coached Leads from India
Intake Coaching
Third-party intake agents have
been known to "coach"
potential plaintiffs on answering
qualification questions to
increase the likelihood of
signing them as clients. This
practice is alarmingly common,
with 30% of intake agents
admitting to coaching clients.
(Source: Legal Newsline)

34
2(A) “Coached Leads” Accepted
35
2(B) Social Media Research – An Online Network of Fraud
Justin Samuels
36
2(B) Social Media Research – An Online Network of Fraud
Justin Samuels
37
2(C) Admit to Selling Leads Coached on Exactly What to Say
38
2(C) Admit to Selling Leads Coached on Exactly What to Say
39
2(D) Using Burner Phones, They Skyped us the Fraud Scripts
40
2(D) Using Burner Phones, They Skyped us the Fraud Scripts
41
2(E) Indian Call Centers Coached Our Friends
COACH: just tell me a via hospital somewhere nearby you,
Let's just say Mayo Clinic, then,
CLIENT:
Clinic?
COACH: No, m a Oh my God, you're not listening to me.
Very well. It's again, frustrating. M A y O
CLIENT:
That's what I told. M A Y L, right? M a Y l May Clinic.No,
COACH:
Jesus fucking Christ. M a Y m. Oh, wait, will you stop talking
and listen to me? M a y o as in Oscar Mayo.
CLIENT:
Okay. Sorry. I'm so Mayo <laugh>, Mayo Clinic. Sorry.
Adam Pulaski COACH: Okay. And where was it located? Mayo Clinic,
PULASKI KHERKHER CLIENT: Scottsdale, Arizona. 42
2(E) Indian Call Centers Coached Our Friends
Paul Liebman
X SOCIAL MEDIA 43
2(F) Problems with Lead Conversion Centers Going Offshore
1. Less expensive labor can cause
reductions in oversight and control
2. If the vendor is not transparent about their use of off-shore labor,
or other outsourcing, it can breach agreement/trust with law firm
3. Language and cultural differences can alienate clients and
reduce chances of catching fraudsters posing as clients OR
other call centers repeatedly transferring in suspicious clients
4. HIPAA and privacy issues with overseas servers and transfer of data
5. Much more difficult to grow true loyalty and prevent fraud
from infiltrating your business when it is off-shore
and not being closely watched over by centralized management
6. No Fear of Fraud Prosecution by U.S. Department of Justice 44
45
Audit of BPO employees after Watts Guerra complained that
client reps did not sound like they were from Austin, Texas
46
Case Work’s BPO
(“Business Process Outsourcing”) Partners
M Vision – Lebanon $15.00/hour

$13.00/hour GoAnswer– St. Lucia U-CGS – Saudi Arabia $6.50/hour
$?.00/hour Infotel – Belize ROI - Philippines $11.38/hour
47
Search: “CW Expectations”
48
49
50
3. Selling Coached Leads with Fraudulent Medical Records
Thank
You,
Andy Birchfield Andy
BEASLEY ALLEN 51
Here are 4 Examples 52

3. Selling Coached Leads with Fraudulent Medical Records #1
Client Provided Medical Records:
Purporting to Show Ovarian Cancer
53
When We Opened Records In Adobe Pro

You Can See Where “Client” Altered The Record
54
Client Provided
Medical Records
Purporting to
Show Ovarian
Cancer
55
Results of Medical Record Ordering
56
“Tara” Sends Photo

Of her Cancerous Ovaries
“Tara” Sends Photo

To Show Proof of Use
Client Provided Photos/Docs of Ovarian Cancer 57
Results of
Medical
Record
Ordering
58
Client
Provided
Records
Purporting to
Show
Ovarian
Cancer
59
Results of Medical Record Ordering
60
Some Cases Referred by other Law Firms
Procured from the Following Lead Gen Companies
Have Arrived with Fraudulent Medical Records

We Don’t Know Who is Doing It,
only That Social Media from India Says They Can Do it 61
Going Offshore to Work your Cases Is No

Way to Detect Fraudulent Medical Records 62
4. 3rd Parties Got India Calls Seeking Fake CL Claimants
63
4. 3rd Parties Got India Calls Seeking Fake CL Claimants
“Hey buddy, while walking into
lunch, I just got a call from some
dude in India asking me to be a
Camp Lejeune client.
When I asked the name of the

firm who would be my lawyer, he
said “WATTS GUERRA.”
Adam Pulaski
64
5. What Our Internal
Audit Showed
65
5(A) WG Audit Reveals Significant Fraud in Referred Cases
66
5(A) WG Audit Reveals Significant Fraud in Referred Cases
67
5(B) Former FBI Agent We Hired to Investigate –
Fraudsters Admit to Being Paid by Indian Call Centers
“We were provided 35
Houston fraud leads to
interview. Through the first
7, we noticed that most of
the addresses were
apartment complexes and
could not be verified through
our database queries.
I was able to interview 8. As

you can see from the
attached writeups, some
reported dealing with
marketers from India and
there is one good potential
cooperative.” 68
5(C) – “The Lady From Florida” – “Tara” was a referral
69
5(D) Confessions of our very own “Whistleblower” in India
70
When CMG does TV advertising and they cannot get the number of retailers that they estimated, what do they do?
They go out to these vendors and they buy. But they're not running any checks as to how they're generating cases
and whatnot. They're just buying signed retailers. Then they're just giving it into their call center for verification.
It's a very promiscuous industry. I have brokers calling me all day long saying, Hey, I need these retainers. This is
the price…..
I would say there are at least 2000 retainers signed a day for masters from India
essentially, they're just dialing out of the phone book.
…. Most of these people, other guys don't even care about the coach leads part. They are just brokering. They're
adding $200 on top, 20 % or 30 % on top and just pushing it.
I think it's B. E. Parking and working for our Brecon, and I'll I'll send you the name working Media. Robert Kenyon
is the the guy. not a major player, but
Berken Media, and so on. They have small teams. they have large orders that need to be pulled, so they'll just buy
whatever they get from 71
Robert Kenyon
72
Principal was selling us back in the day, but I mean they might still buy from call centers in India, but
they don't resell leads anymore. But I think they set up another phone called Elite Marketing
…I even hired my friend talk to a broker and told him, Hey, what's the cost of producing these coach leads? It's
about $150 actually.
It's not like everybody is bad, but the percentage of good to bad is like, I would say less than 1%. So there's
probably one good provider to 99 fraudsters.
in the majority of the cases, what's happening now is you order the medical records and they say, Well, this patient
doesn't even exist in our database. It means that no matter how good your intake is, if a person is going to lie,
they'll just figure out a way to lie through.
It takes 3 months to get the medical records, so we have an opportunity to take the same client and stick it to 3
different firms book.
, out of 100, 20 %, 30 % come back with medical records. The other 70 are young. They either lose a client or they
say, Well, people are lying because they're seeing too many ads and calling us in and faking it, whatever. But
that's not the case. They bought it from someone else…… 73
Lejeune is a complete disaster. I keep getting calls from some of these centers, and they're just horrible…..
So so they were involved in a huge I think they were sending like 250 retainers a day to a law firm for Camp
Lejeune.
…..the primary community that they are all going after is the African American lower income class community and
a lot of them are participating in a lot of them. Like for example, we've started doing criminal background checks
and we do have instances where people have had people have they've written bad checks, they've been involved
in ID theft and so on…..
…It's like people from the hood, lower income people, people who have disability. There's a lot of Americans who
are not doing anything. They're just sitting by the phone waiting for it to ring and they'll get a home based
opportunity. They're getting it cashed so it's not traceable, like on a green dot card and so on. It's unreported
income
There are prepaid cards where you can load money onto it. You can go to 711, take a Green dot card and you give
them cash and they load money for you on that. Got it. Then you go and make purchases through that. These are
mainly for people who don't qualify for a credit card, for credit and so on.
74
5(E) Confessions Made by Purported “clients”
75
5(E) Confessions Made by Purported “clients”
TC was contacted by a male and a female marketer working together in the same residence in India. She was told
that she could make $30K from the TALC settlement and $2K for every referral she made. She was told exactly
what to say and how to answer every question she would be asked when she signed up for TALC. The marketers
told her to write down the answers they gave her, which were false, and subsequently quizzed her several times
(which she called role playing) before she was contacted to answer the Talcum Intake Questionnaire (TIQ). She
has never had ovarian cancer and all of the medical information listed on her TIQ was false and had previously
been provided by TC at the behest of the Indian marketers
ST - she received numerous calls from another foreign sounding person telling her how she had to answer certain
questions she would be asked by her law firm. However, the answers she was told to say “didn’t have nothin’ to do
with me,” so she disregarded what she was told to say.
TH - Spoke to someone with a foreign accent, who told her that she would be paid $3,000 to sign up as a plaintiff
for TALC and $1,000 or $2,000 for everyone she referred that signed up….. When I pressed her again about
having cancer, she said “today, I’m good.” … TH is our best candidate for a cooperator re: Open Jar.
Kevin Jones that obligated her to sign forms stating she had cancer from Talcum Powder. Saundra added that she had a
guilty conscience now that she does not have cancer or mesothelioma.
client RJ did not have a viable case. He did not have Parkinson’s & had not used Paraquat… 76
5(F) Employers of Purported “Clients” Don’t Remember Them
I stated I was calling for a reference check for James Postell as he listed he worked there 2009 - 2017 and she said she has
never had any employees. Said that it has always been just her & her husband working the business.
I said I was calling to do a reference check for a former employee and he said what’s the name? When I said Stanley Louis he
replied “WHO?” I repeated the name and said from 2011 - 2017, and he said he has never heard of that name. Then he
asked what his position was and I said he listed “sprayer”. He said that they do not have a position of sprayer on his team.
Called JTB Landscapers where client is claiming para exposure from working there 2007-2016. The lady in HR asked me if I
have the wrong # because this company opened in 2013.
I asked if I can do a reference check for a former employee and she asked the name. I stated Gary Harris and she said No I’ve
never had an employee with that name.
77
5(G) Interview with Principal Law Group (20230728)
Brent
MacDonald
Never Explained
the Intake
Fraud on Cases
He Generated,
but did care
enough to
Share a Photo
of His Rolex
Collection 78
5(G) Interview with Principal Law Group (20230728)
5(H) Interview with Nettx (20230914)
Toushar Raj 80
Toushar Raj 81
Toushar Raj 82
83
84
85
86
87
Client Acquisition
A. Red Flags
C. Cleaning Up the Mess
How We What Prevent Intake Fraud in the Future 88
C(1) Interview with Open Jar (20230926)
89
90
91
C(2) Interview with Reliance Litigation (20231005)
Sam Kim
92
C(2) Interview with Reliance Litigation (20231005)
Prior to Camp Lejeune, there were 12 legal marketers
After Camp Lejeune, there are 100s legal marketers
They communicate on Linked In – “They See the Money”
All Are Overseas; most from India & Pakistan; P.O. Boxes in the U.S.
They hire and give money to U.S. Lead Brokers
They pay them $10K a month plus a fee for each lead the sell
They sell the same lead over and over again
Lawyers Should Not Contract with those Delivering cases for lowest cost
ROI calculated on cost per case only works if 100% of them are real
ROI should be calculated based on “Stick Rate” of Vendors/Cost 93
C(3) Interview with Blue Sky Legal (20231005)
94
C(3) Interview with Blue Sky Legal (20231005)
95
C(4) Interview with Broughton Partners/Amicus (20230907)
96
C(5) Interview with CAMG (20231005)
97
C(5) Interview with CAMG (20231005)
98
C(6) Rules for Protecting Your Law Firm from Intake Fraud
1. Do Not Contract with Non-Lawyer 6. Do Not Accept Referrals from Law Firms
Lead Generation Firms You Don’t Know Failing to Follow Rules 1-5 above
2. Do Not Buy from Leads without Listening 7. Require Indemnification re: Fraudulent
to Each and Every Verification Call Claims from Any Marketing Company
8. Physically Inspect the Office/Call Center

3. Do Not Pay By the Case
of Any Company You Market With
9. Order Records Immediately to Establish

4. Require Photo IDs from Each Client
Proof of Use and Proof of Harm
5. Do Not Accept Cases from Clients with 10. Do Not File an Administrative Claim or
Criminal Histories Lawsuit without Proof of Use and Harm
99
C(7) Best Practices for Mass Tort Claims Intake
NEWCO
1. In addition to the concept of a for-profit business that verifies the authenticity of Ps and Ps’
claims, I’d like us to consider a non-profit association (NEWCO) led by a board of directors
(BOD);
2. The BOD could be made up of P counsel, D counsel, neutrals, and perhaps past or present
federal judge (perhaps even one or more JPML judges);
3. The purpose of NEWCO could be for:

a. Members to endorse and adhere to NEWCO’s best practices (read: a short but effective
ruleset) in connection w/ MT P intake; for example:
1. Members’ advertising and marketing vendors (AMVs) may not buy leads;
instead, they must produce leads from bar compliant advertising and
marketing efforts over which the AMVs have control;
2. NEWCO to publish sample intake criteria for select MTs (read: to spotlight a
compensable case, as of the date of publication), which criteria anyone may
accept or reject; for those not close enough to a MT to make an informed
decision, NEWCO’s intake criteria will reflect the views of those leading the MT;
this to ensure the uninformed do not unwittingly intake and prosecute non-
compensable claims.
3. NEWCO to endorse select supply chain participants (e.g., AMVs, call centers,
and records retrieval and review cos) who endorse and adhere to NEWCO’s best
practices in connection w/ MT P intake;
4. Members will not accept referrals from 3rd parties, unless
(a) The referring firms follow the Members’ requirement under
3(a)(1) above;
(b) Referral firms produce proof of use and harm, documented by
pharmacy and medical records obtained from suppliers and
treaters; and
5. Members must expedite the retrieval and review of select records, if applicable,
to confirm threshold exposure and injury; members may not sit on a case and
retrieve no records pending progress in the underlying litigation;
6. Absent limitations concerns, members will not assert a claim on b/h of a P for
whom a member has not retrieved and reviewed the foregoing records; this as
a proxy for minimally sufficient due diligence that the P’s story is accurate in
connection w/ exposure and injury;
7. Members’ AMVs engaged in communicating w/ prospective claimants much
adopt and enforce a set of control Qs designed to ferret out fraud;
8. Members must report to NEWCO the facts in connection w/ fraud when they
discover or suspect fraud; and NEWCO will investigate same and include a
discussion of its investigation in its database (see below);
9. NEWCO to maintain a database housing content in connection w/ its
investigation of allegations of fraud;
10. NEWCO to maintain a database of claimants filing suit across different mass
torts to ferret out plaintiffs committing fraud as well as duplicate claims.
b. Members to communicate best practices with the federal judiciary, special masters and 100
claims administrators, and participate in bi-annual meetings concerning best practices.
C(8) How You Can Help – Report Fraud Against You
IntakeFraud.com
101
IntakeFraud.com 102
IntakeFraud.com 103
C(9) How to Get A Copy of the Full Power Point
104
Client Acquisition
Mikal
Watts END
Bellagio Hotel
Las Vegas, Nevada
October 10,
2023
105

Intake Fraud

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Intake Fraud

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Client Acquisition

What You Need To Know About Protecting Your Law Firm

Mikal October 10,

Hon. Anthony Battaglia

Hon. Anthony Battaglia

Hon. James D. Cain

M.J. Michael North

M.J. Michael North

M.J. Michael North

M.J.. Kathleen Kay

Law Firm Networks

U.S. Lead Generation Brokers

The Social Network

The Social Network

Indian Call Centers

Indian Call Centers

Indian Call Centers

Indian Call Centers

Indian Call Centers

(Source: Legal Newsline)

M Vision – Lebanon $15.00/hour

Here are 4 Examples 52

When We Opened Records In Adobe Pro

Results of Medical Record Ordering

“Tara” Sends Photo

“Tara” Sends Photo

Results of Medical Record Ordering

Have Arrived with Fraudulent Medical Records

Going Offshore to Work your Cases Is No

When I asked the name of the

I was able to interview 8. As

essentially, they're just dialing out of the phone book.

8. Physically Inspect the Office/Call Center

9. Order Records Immediately to Establish

3. The purpose of NEWCO could be for:

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