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In re Reynoso
United States Court of Appeals for the Ninth Circuit
477 F.3d 1117 (2007)
Henry Ihejirika (defendant) sold software under the business name Frankfort Digital Services, Ltd. (Frankfort). Frankfort advertised that its software could provide legal expertise in bankruptcy petitions, could help clients find loopholes in the bankruptcy laws, was as good as a top-notch bankruptcy lawyer, and was an expert system that provided personalized services beyond just blindly filling in forms. Frankfort also made false claims that it could help clients avoid certain bankruptcy events and fraudulently hid information about its identity and fees on the bankruptcy forms it created for users. Jayson Reynoso paid $219 to Frankfort to use its forms to prepare his bankruptcy petition. The bankruptcy trustee (trustee) (plaintiff) assigned to Reynoso noticed that several items on the form were incorrect and learned that Reynoso had used Frankfort. The trustee filed an adversary proceeding against Ihejirika, claiming that Ihejirika, through Frankfort, had committed fraud and engaged in the unauthorized practice of law. Both the bankruptcy court and the bankruptcy appellate panel found that Frankfort had committed fraud and that its services were the unauthorized practice of law. The matter was appealed to the Ninth Circuit.
Rule of Law
Holding and Reasoning (Fletcher, J.)
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