# Legal Re-Check Memo — United Legal Review V3

**Date of check:** 2026-10-12
**Build reviewed:** `C:/Users/Nima/ClaudeCodeProjects/unitedlegal.comV2/United-Legal-Review-V3/` (ca-en.html, tx-en.html, lemon-law-en.html, home-en.html, footer.js, qualifier-rules.js, locales/en.js; Spanish and Persian pages only where noted)
**Status of this memo:** Working product for the responsible attorneys. It is not legal advice to any consumer and is not itself consumer-facing copy.

Every finding below went through two passes: (1) a research pass that re-verified each page claim against live primary sources on 2026-10-12, and (2) an adversarial verification pass that tried to refute each "needs-correction" or "uncertain" finding on four grounds (does the authority say what is claimed; is the section number right; has a later amendment changed the result; would the proposed correction itself be inaccurate or add a guarantee). Verdicts are recorded as **refuted = false** (finding stands) or **refuted = true** (finding withdrawn). Two findings were withdrawn (F16, F29); all others stood, most with revised wording.

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## 1. Scope and method

### 1.1 What was checked

| Area | Pages / keys | Findings |
|---|---|---|
| California Song-Beverly copy | ca-en.html, lemon-law-en.html (California card), `locales/en.js` `ca.*` and the California-only `common.*` quiz keys, qualifier-rules.js routing | CA-01 to CA-30 |
| Texas Lemon Law copy | tx-en.html, lemon-law-en.html (Texas card), `locales/en.js` `tx.*` and the Texas-flow `common.*` quiz keys | TX-01 to TX-24 |
| Firm facts and lawyer-advertising compliance | home-en.html (bios, reviews, practice blurbs, disclosures), lemon-law-en.html, tx-en.html, footer.js; live unitedlegal.com cross-checks | F01 to F41 |

### 1.2 Primary sources opened on 2026-10-12

**California**
- Civ. Code §§1790, 1791, 1793.2, 1793.22, 1794, 1795.4, 1795.8 — leginfo.legislature.ca.gov (e.g. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1793.22.&lawCode=CIV)
- CCP §§871.20, 871.21, 871.24, 871.29, 871.30 (AB 1755 / SB 26 procedures) — leginfo (e.g. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=871.29.&lawCode=CCP)
- SB 26 (2025) bill status and chaptered text — https://leginfo.legislature.ca.gov/faces/billStatusClient.xhtml?bill_id=202520260SB26
- Bus. & Prof. Code §§6157–6159.2 as amended by SB 37 (Stats. 2025, Ch. 645, eff. Jan. 1, 2026) — https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=BPC&division=3.&title=&part=&chapter=4.&article=9.5.
- Cal. Rules of Professional Conduct, Chapter 7 (Rules 7.1–7.5 and comments) — https://www.calbar.ca.gov/legal-professionals/rules/rules-professional-conduct/current-rules-professional-conduct/chapter-7-information-about-legal-services
- Rodriguez v. FCA US, LLC (2024) 17 Cal.5th 189, S274625 — https://courts.ca.gov/opinion/published-extended-post/2024-10-31/s274625 and https://www4.courts.ca.gov/opinions/archive/S274625.PDF
- Palonen v. Mercedes-Benz USA, 9th Cir. No. 24-5136 (Nov. 24, 2025, unpublished) — https://cdn.ca9.uscourts.gov/datastore/memoranda/2025/11/24/24-5136.pdf
- DCA Arbitration Certification Program pages and SB 26 election data — https://www.dca.ca.gov/acp/new_lemon_law.shtml ; https://www.dca.ca.gov/acp/webapplications/api/getSB26Accepted ; https://www.dca.ca.gov/acp/faqs.shtml
- California Attorney General, Cars / Lemon Law — https://oag.ca.gov/consumers/general/cars
- State Bar licensee records #310086, #255218, #308454 — https://apps.calbar.ca.gov/attorney/Licensee/Detail/310086 ; …/255218 ; …/308454

**Texas**
- Tex. Occ. Code ch. 2301 (§§2301.002, .204, .601–.613, .712) — https://tcss.legis.texas.gov/resources/OC/htm/OC.2301.htm ; currentness statement https://statutes.capitol.texas.gov/information/ ("current through the 89th 2nd Called Legislative Session, 2025")
- TxDMV Lemon Law consumer page — https://www.txdmv.gov/motorists/consumer-protection/lemon-law
- 43 TAC ch. 224 Subchapter G (§§224.230–224.268): TxDMV 2024 adoption Exhibit A — https://ftp.txdmv.gov/pub/txdmv-info/ogc/rules/2024/Chapter-224-Adopt.pdf ; SOS portal listing — https://texas-sos.appianportalsgov.com/rules-and-meetings?chapter=224&interface=VIEW_TAC&part=10&subchapter=G&title=43 ; LII reprints of §§224.230, 224.232, 224.260 ; 2025 SB 2807 rulemaking (eff. Feb. 27, 2026; Subchapter G untouched) — https://www.txdmv.gov/sites/default/files/body-files/Chap_224_2807_Final_-_Adopt.pdf
- TxDMV OAH decisions 22-0003434 CAF, 23-0002660 CAF, 24-0009092 CAF — https://ftp.txdmv.gov/pub/txdmv-info/oah/actions/website_pdfs/
- Texas Disciplinary Rules of Professional Conduct (Part VII, Rule 5.05, Rule 8.05) — https://www.texasbar.com/Content/NavigationMenu/ForLawyers/AdvertisingReview/ADRULES2023.pdf ; https://txcourts.gov/media/1459244/texas-disciplinary-rules-of-professional-conduct-pdf.pdf
- State Bar of Texas Advertising Review page and July/Aug 2025 Ethics Question — https://www.texasbar.com/AM/Template.cfm?Section=Advertising_Review ; https://www.texasbar.com/AM/Template.cfm?ContentID=68675&Section=articles&Template=%2FCM%2FHTMLDisplay.cfm
- State Bar of Texas member directory, Parisa Fishback (ContactID 391033) — https://www.texasbar.com/AM/Template.cfm?Section=Find_A_Lawyer&template=/Customsource/MemberDirectory/MemberDirectoryDetail.cfm&ContactID=391033

**Federal and other**
- 11 U.S.C. §528 ; Milavetz v. United States, 559 U.S. 229 (2010) syllabus — https://www.law.cornell.edu/uscode/text/11/528 ; https://www.law.cornell.edu/supct/html/08-1119.ZS.html
- 47 U.S.C. §227 ; 15 U.S.C. §§1681m, 1681b, 1681e, 1681n, 1692e, 1691 — law.cornell.edu
- Perry v. First Nat'l Bank, 459 F.3d 816 (7th Cir. 2006) ; Doe v. Charter Communications, 131 F.4th 323 (5th Cir. 2025) — see F29
- BBB profile and accreditation-fee page — https://www.bbb.org/us/ca/irvine/profile/bankruptcy-attorney/united-legal-advocates-llp-1126-1000149638 ; https://www.bbb.org/bbb/great-west-pacific/accreditation-benefits
- Firm site — https://unitedlegal.com/ ; https://unitedlegal.com/attorneys/ ; https://unitedlegal.com/terms/ ; https://unitedlegal.com/lemon-law/ ; https://unitedlegal.com/attorney-referral-network/
- Gavilanes bios — https://www.adamscorporatelaw.com/about-us/daniel-gavilanes/ ; https://gavilancorporatelaw.com/about/ ; https://asadilawgroup.com/daniel-gavilanes.html ; Fishback FindLaw profile — https://lawyers.findlaw.com/profile/view/4883846_1

Prior research in `handoff/United-Legal-Claude-Handoff-2026-10-12/07-Legal-Research/` was used only as a starting point; every authority relied on was re-opened live except where noted in 1.3.

### 1.3 What could not be opened or verified (access limits)

- **leginfo.legislature.ca.gov** returned HTTP 403 to the ordinary fetch tool; all statute and bill pages were read through a scraping tool (HTTP 200, full text). Leginfo "cross-reference chaptered bills" links are not fetchable, so pending-bill detection relied on keyword/phrase searches of the 2025–2026 session, which can miss a bill whose text lacks the searched phrases.
- **Rodriguez v. FCA** official PDF: pages 1–6 of 22 parsed live (holding at p. 2 confirmed verbatim); later-page quotations were cross-checked against the handoff's extracted text of the official DOCX, not re-parsed live.
- **Stiles v. Kia Motors America** (2024) 101 Cal.App.5th 913: the courts.ca.gov PDF returned 404; its review-granted status (S285433) comes from search summaries. It predates Rodriguez and is not relied on.
- **No citator run** (Shepard's/KeyCite/CourtListener) was performed for post-Rodriguez appellate history, for AB 1755/SB 26 interpretation, or for the Texas used-vehicle, transferee, loaner-comparability and days-aggregation questions. A counsel citator check is recommended before publication.
- **DCA accepted_manufacturers.shtml** renders only a heading; the manufacturer list was read from the public API endpoint (59 records; optIn dates only, no sale-year field). AG page, DCA FAQ and DCA home show no "last updated" date.
- **State Bar Rules chapter 7 page**: only the first 100,000 characters were read in the California pass (covers Rules 7.1 and 7.2 and comments); the firm pass used the full chapter for 7.4 and 7.5.
- **statutes.capitol.texas.gov** serves only an application shell to non-browser fetches; chapter 2301 was read from the Legislature's tcss.legis.texas.gov HTML copy (same publisher).
- **Texas SOS Appian TAC portal**: section text renders in a cross-origin iframe that could not be read, and "View PDF" produced no file. Only the Subchapter G section listing (queryAsDate 10/12/2026) was confirmed on the official portal; rule text came from TxDMV's adoption Exhibit A and the LII reprint. The legacy texreg.sos.state.tx.us viewer now returns "This Site Has Moved".
- **TxDMV OAH decisions** are non-precedential agency orders; some ftp.txdmv.gov paths return 404 (the /oah/actions/website_pdfs/ paths worked).
- **CalBar QuickSearch** tables were unreadable via the ordinary fetch tool; licensee detail pages were read directly. Bar records show admission dates, status, law school and self-reported languages only; they do not list undergraduate degrees, LL.M. degrees, externships or employers.
- **State Bar of Texas directory** search form was not submitted (form submission requires user permission); the Fishback profile was located by search engine and read directly. Fields other than license date/status are self-reported.
- **California Secretary of State** business search blocked the session (HTTP 429/403), so the LLP's registration and partner roster could not be confirmed.
- **BBB** get-accredited/apply pages are JavaScript-rendered; the fee statement was taken from the Great West + Pacific BBB benefits page. **supremecourt.gov** PDF for Milavetz returned 404 (LII syllabus used). **Avvo** sits behind a bot-verification wall (not bypassed). The **Texas Bar Advertising Review** page lists its Interpretive Comments as "Coming soon".
- **Not verifiable online:** undergraduate degrees and years (Asadi CSUF 2012; Fishback LMU 1998; Gavilanes CSUF 2012), J.D. years other than Fishback's, the conferral year of Gavilanes's LL.M., Fishback's externship year and former employer, client consent to publish the three reviews, whether the Irvine address is a bona fide office of the LLP, whether the initial review is in fact free, and whether the Spanish/Persian pages reflect actual service capacity beyond bar self-reports.
- **Spanish and Persian** Texas and California copy was not reviewed line by line; only the English strings were checked, with es/fa changes called out where the English change must be mirrored.
- Firm-specific publication facts (responsible lawyer, fee/cost policy, Texas office or co-counsel arrangement) are flagged for attorney review and were not checked.

### 1.4 How to read the tables

- **Status** is the research status after verification: `supported`, `needs-correction`, `uncertain`, `not-verifiable-online`, or `refuted` (finding withdrawn).
- **Authority** gives the URL and a short verbatim excerpt of the controlling text as retrieved on 2026-10-12. Excerpts are shortened with "…" but never altered.
- **Action** is what to do in the build. Where the action is "none", the copy stays as is. Consumer-facing wording in sections 5–7 deliberately contains no citations.

---

## 2. California table

Framework currency (CA-30): as of 2026-10-12 the post-2025 regime remains a manufacturer election. CCP §§871.20 and 871.24 are "(Amended by Stats. 2025, Ch. 1 … (SB 26) Effective April 2, 2025.)"; §§871.29 and 871.30 were added by SB 26; §871.21 was added by AB 1755 (Stats. 2024, Ch. 938, eff. Jan. 1, 2025); Civ. Code §1793.22 was last amended by Stats. 2000, Ch. 679. Leginfo 2025–2026 phrase searches for "Song-Beverly Consumer Warranty" and "replacement of a new motor vehicle" resolved only to SB 26. The DCA election list showed 59 manufacturers (latest optIn 2026-04-01). No 2026 statute amending §§871.20–871.30 or §1793.22 was found.

| ID | Claim (page copy) | Page / key | Status | Authority (URL + quote) | Action |
|---|---|---|---|---|---|
| CA-01 | "California law may provide a remedy when a covered defect cannot be repaired after a reasonable number of attempts." | ca-en.html hero / `ca.hero_p` | supported | Civ. Code §1793.2(d)(2) — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1793.2.&lawCode=CIV — "to conform to the applicable express warranties after a reasonable number of attempts, the manufacturer shall either promptly replace the new motor vehicle … or promptly make restitution to the buyer" | None |
| CA-02 | "The same defect remains after repair attempts. The number alone does not determine a claim." | `ca.s2_p` | supported | Civ. Code §1793.22(b) — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1793.22.&lawCode=CIV — "This presumption shall be a rebuttable presumption affecting the burden of proof" | None |
| CA-03 | "More than 30 days is one part of a legal presumption, not a universal eligibility rule." | `ca.s3_p` | supported | Civ. Code §1793.22(b)(3) — same URL — "out of service by reason of repair of nonconformities … for a cumulative total of more than 30 calendar days since delivery of the vehicle to the buyer" | None |
| CA-04 | "A defect affects how safely you can control or operate the vehicle." (reason to look closer, not a legal test) | ca-en.html `s5_p` | supported | Civ. Code §1793.22(e)(1) — same URL — "“Nonconformity” means a nonconformity which substantially impairs the use, value, or safety of the new motor vehicle to the buyer or lessee." | None; the intro line "These are reasons to look closer, not proof that a vehicle qualifies" keeps it non-legal |
| CA-05 | "The warranty issued with the sale and the repairs requested under it matter." | `ca.s6_p` | supported | Rodriguez v. FCA US, LLC (2024) 17 Cal.5th 189 — https://www4.courts.ca.gov/opinions/archive/S274625.PDF p. 2 — "does not qualify as a “motor vehicle sold with a manufacturer’s new car warranty” … unless the new car warranty was issued with the sale." | None |
| CA-06 | "restitution may include specified amounts paid or payable, subject to a statutory use deduction and other rules." | `ca.o1_p` | supported | Civ. Code §1793.2(d)(2)(B)-(C) — "restitution in an amount equal to the actual price paid or payable by the buyer … may be reduced by the manufacturer by that amount directly attributable to use by the buyer … a fraction having as its denominator 120,000" | None |
| CA-07 | "A covered vehicle may be replaced. The applicable remedy depends on the facts and the law." | `ca.o2_p` | supported | Civ. Code §1793.2(d)(2)(A) — "the buyer shall be free to elect restitution in lieu of replacement, and in no event shall the buyer be required by the manufacturer to accept a replacement vehicle." | None required; optional upgrade in §7 |
| CA-08 | "Repair obligations, damages, or an agreed settlement may be relevant. A cash settlement is not guaranteed." | `ca.o3_p` | supported | Civ. Code §1794(a) — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1794.&lawCode=CIV — "may bring an action for the recovery of damages and other legal and equitable relief." | None |
| CA-09 | "New leases can be covered." | `ca.a2` (first sentence) | supported | Civ. Code §1795.4(b) — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1795.4.&lawCode=CIV — "The lessee of goods has the same rights under this chapter against the manufacturer"; §1793.2(d)(2)(D); AG page https://oag.ca.gov/consumers/general/cars | None |
| CA-10 | "A used vehicle is not automatically covered for a manufacturer buyback simply because the original factory warranty has time left. The warranty issued with the sale and possible other remedies need individual review." | `ca.a2` | supported | Rodriguez, PDF p. 2 — "a motor vehicle purchased with an unexpired manufacturer’s new car warranty does not qualify … unless the new car warranty was issued with the sale. We affirm the judgment of the Court of Appeal."; AG page; DCA FAQ https://www.dca.ca.gov/acp/faqs.shtml; Palonen (9th Cir. 2025, unpublished) https://cdn.ca9.uscourts.gov/datastore/memoranda/2025/11/24/24-5136.pdf applied Rodriguez | None; keep the individual-review route (dealer-owned/demonstrator and CPO sales with a manufacturer new-car warranty issued with the sale can still qualify) |
| CA-11 | "Deadlines and notice rules depend on the claim, dates, and whether the manufacturer elected California’s newer procedures. An attorney must check your records promptly; this check does not calculate a deadline." | `ca.a4` | supported | CCP §871.29 — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=871.29.&lawCode=CCP — "Unless a manufacturer has made the election described in subdivision (a) that covers a given year, Sections 871.20 to 871.28, inclusive, shall not apply"; §871.20(a); §871.21; §871.24; SB 26 status https://leginfo.legislature.ca.gov/faces/billStatusClient.xhtml?bill_id=202520260SB26; DCA https://www.dca.ca.gov/acp/new_lemon_law.shtml | None required; optional precision in §7. Do not add year counts to consumer copy |
| CA-12 | Close disclosure (firm name, Irvine address, no guarantee, no attorney-client relationship, no deadline preserved) | ca-en.html `ca.disclosure` | supported | Bus. & Prof. Code §6157.2(b)(1)-(2) as amended by SB 37 — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=6157.2.&lawCode=BPC — "Disclosure of the city, town, or county of at least one bona fide office location or the address of record listed with the State Bar for the lawyer or law firm."; CRPC 7.1(a), 7.2(c) | No wording change. Attorney review: confirm (a) the LLP is the responsible lawyer/firm, (b) Irvine is a bona fide office or the State Bar address of record, (c) the disclosure is "conspicuously displayed", not only in small footer type |
| CA-13 | "No-cost initial review" / "This check has no charge. Any attorney representation and responsibility for fees or costs require a separate agreement; no outcome is promised." | `common.hero_c1`, `ca.a1` | supported | §6157.2(a)(1)-(2),(4); CRPC 7.1 Comment [3] — https://www.calbar.ca.gov/legal-professionals/rules/rules-professional-conduct/current-rules-professional-conduct/chapter-7-information-about-legal-services — "A statement that a licensee offers representation on a contingent basis unless the statement also advises whether a client will be held responsible for any costs advanced" | None, provided the page continues not to advertise contingency or "no fee unless we win" terms. Attorney review: confirm the initial review is free |
| CA-14 | "A civil claim under the Song-Beverly Consumer Warranty Act, pursued against the manufacturer." | lemon-law-en.html lede and CA card | supported | Civ. Code §1790 — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1790.&lawCode=CIV — "This chapter may be cited as the “Song-Beverly Consumer Warranty Act.”"; §1794(a); §1793.2(d)(2); §1793.22(b) | None |
| CA-15 | "A legal presumption can apply after repeated repair attempts or more than 30 days out of service within 18 months or 18,000 miles. Missing that window does not end the inquiry." | lemon-law-en.html CA card bullet 2 | supported | Civ. Code §1793.22(b) — "It shall be presumed that a reasonable number of attempts have been made … if, within 18 months from delivery to the buyer or 18,000 miles on the odometer of the vehicle, whichever occurs first, one or more of the following occurs:" | None (the direct-notice condition in (b)(1)-(2) is accommodated by "can apply") |
| CA-16 | "Used vehicles depend on the warranty issued with the sale, not just leftover factory coverage." | lemon-law-en.html CA card bullet 3 | supported | Rodriguez, PDF p. 2 — "unless the new car warranty was issued with the sale"; Civ. Code §1793.22(e)(2) | None |
| CA-17 | "Was the vehicle bought or leased in California?" / "An out-of-state transaction needs individual review. Certain active-duty military protections and other laws may matter." | `ca.q_connection`, `ca.h_connection` | supported | Civ. Code §1795.8 — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1795.8.&lawCode=CIV — "this chapter shall apply to a purchase in the United States of a motor vehicle … by a member of the Armed Forces regardless of in which state his or her motor vehicle is purchased or registered, if both of the following apply:" | None |
| CA-18 | "A service contract is not necessarily a manufacturer warranty." / "No / only a service contract" | `ca.h_warranty`, `ca.opt_warranty_no` | supported | Civ. Code §1791(o) — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1791.&lawCode=CIV — "“Service contract” means a contract in writing to perform, over a fixed period of time or for a specified duration, services relating to the maintenance or repair of a consumer product"; CCP §871.20(b) | None |
| CA-19 | "Remaining original factory coverage alone does not make a used vehicle a “new motor vehicle” for the manufacturer buyback remedy. A manufacturer’s new-car warranty issued with the sale or other warranty rights may matter." | `ca.result_used_p` | supported | Rodriguez, PDF p. 2 — "a motor vehicle purchased with an unexpired manufacturer’s new car warranty does not qualify as a “motor vehicle sold with a manufacturer’s new car warranty”"; §1793.22(e)(2); §1795.5 as discussed in the opinion | None |
| CA-20 | "California deadlines and manufacturer-specific notice procedures need prompt individual review. Taking this check does not stop any deadline." | `ca.deadline_note` | supported | CCP §871.24(d) — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=871.24.&lawCode=CCP — "sent either by email to the email address prominently displayed on the manufacturer’s website for this purpose or by certified or registered mail … to the address provided by the manufacturer in the owner’s manual or warranty booklet."; §871.29; Civ. Code §1793.22(b); DCA list https://www.dca.ca.gov/acp/accepted_manufacturers.shtml | None |
| CA-21 | "The 18-month / 18,000-mile presumption is not an absolute cutoff for every California claim." | `ca.note_window` | supported | Civ. Code §1793.22(b) (rebuttable presumption) and §1793.2(d)(2) ("reasonable number of attempts" with no time/mileage cap) | None |
| CA-22 | "Business use requires review of the vehicle’s weight and the number of vehicles registered to the business." / `h_ca_use` | `ca.note_business`, `common.q_ca_use`, `common.h_ca_use`, `common.opt_business` | supported | Civ. Code §1793.22(e)(2) — "a new motor vehicle with a gross vehicle weight under 10,000 pounds that is bought or used primarily for business purposes by a person … to which not more than five motor vehicles are registered in this state." | None |
| CA-23 | "For California’s legal presumption, timing is generally within 18 months of original delivery or 18,000 miles, whichever comes first. Missing this window does not automatically defeat a claim." + options | `common.q_ca_window`, `h_ca_window`, `opt_ca_inside`, `opt_ca_outside` | supported | Civ. Code §1793.22(b) — "within 18 months from delivery to the buyer or 18,000 miles on the odometer of the vehicle, whichever occurs first" (page tracks the statute, which is tighter than the AG paraphrase) | None |
| CA-24 | "Could this same defect cause death or serious injury?" / "Consider the risk if the vehicle is driven. An attorney must assess whether the legal safety standard is met." | `common.q_ca_safety`, `common.h_ca_safety` (routed by qualifier-rules.js line 33 when visits ≥ 2; signal at line 77) | **needs-correction** (verdict: refuted = false, high confidence) | Civ. Code §1793.22(b)(1) — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1793.22.&lawCode=CIV — "The same nonconformity results in a condition that is likely to cause death or serious bodily injury if the vehicle is driven and the nonconformity has been subject to repair two or more times by the manufacturer or its agents"; history "(Amended by Stats. 2000, Ch. 679, Sec. 1. Effective January 1, 2001.)" — no later amendment | "Could … cause" is a lower bar than "likely to cause" and over-selects the two-repair path. Rewrite question and hint in en/es/fa (§5, item 1). No change to qualifier-rules.js |
| CA-25 | "How many repair attempts for that same defect?" / "Count visits to the manufacturer or an authorized repair facility… Routine service does not count." / "4 or more attempts" | `common.q_visits`, `h_visits`, `opt_four` | supported | Civ. Code §1793.22(b)(2) — "subject to repair four or more times by the manufacturer or its agents and the buyer has at least once directly notified the manufacturer of the need for the repair of the nonconformity." | None required. Gap noted: the CA flow does not ask the direct-notice question (qualifier-rules.js routes `notice` only for Texas); `review_deadline` and `note_signal` keep the copy accurate. Optional note in §7 |
| CA-26 | "Count days unavailable because of warranty repairs, across all defects." / "Exactly 30 days" / "More than 30 days" | `common.q_days`, `h_days`, `opt_d30`, `opt_d31` (CA signal fires only on `over30`) | supported | Civ. Code §1793.22(b)(3) — "for a cumulative total of more than 30 calendar days since delivery of the vehicle to the buyer. The 30-day limit shall be extended only if repairs cannot be performed due to conditions beyond the control of the manufacturer or its agents."; AG page | None (exactly 30 correctly does not fire the CA signal) |
| CA-27 | "It seriously affects use, value, or safety" / "A minor concern alone may not support a buyback claim." | `common.opt_major`, `note_impact` | supported | Civ. Code §1793.22(e)(1) — "substantially impairs the use, value, or safety" | None required; optional statutory verb in §7 |
| CA-28 | "Some vehicle types have different rules." / "This vehicle type may have special coverage rules or exclusions." | `common.q_vehicle` options, `note_special` | supported | Civ. Code §1793.22(e)(2) — "includes the chassis, chassis cab, and that portion of a motor home devoted to its propulsion, but does not include any portion designed, used, or maintained primarily for human habitation … but does not include a motorcycle"; §1793.2(d)(1) | None |
| CA-29 | "Where the vehicle was sold or leased, registered, and used can affect the available protections. An out-of-state answer does not automatically end the inquiry." | `common.result_state_h/p`; lemon-law-en.html | supported | Civ. Code §1793.2(a) ("consumer goods sold in this state"); §1795.8 — "stationed in or a resident of this state at the time he or she purchased the motor vehicle or at the time he or she filed an action"; AG page | None (case law on other out-of-state fact patterns was not checked; copy promises nothing) |
| CA-30 | Pages describe the post-2025 regime as a manufacturer election rather than a universal rule | all California pages | supported | CCP §871.20(a) — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=871.20.&lawCode=CCP — "this chapter applies to an action, brought against a manufacturer who has elected under Section 871.29 to proceed under this chapter"; SB 26 chaptered text (SEC. 1 intent to evaluate "beginning on January 1, 2029"); DCA election data (59 records) | None. Re-check leginfo and the DCA list before each publication cycle (list republished by December 15 each year; elections are year-specific) |

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## 3. Texas table

Framework currency: Tex. Occ. Code §§2301.605 and 2301.606 were last amended by Acts 2017, 85th Leg., R.S., Ch. 354 (H.B. 2070), eff. Sept. 1, 2017; the statutes site is "current through the 89th 2nd Called Legislative Session, 2025" and chapter 2301 carries no 89th-Legislature entry. 43 TAC ch. 224 Subchapter G (§§224.230–224.268) was adopted eff. June 1, 2024; the 2025 SB 2807 rulemaking (eff. Feb. 27, 2026) amended Subchapters A, D, E, F and added H and I, leaving Subchapter G untouched (TX-24).

| ID | Claim (page copy) | Page / key | Status | Authority (URL + quote) | Action |
|---|---|---|---|---|---|
| TX-01 | "Four repairs for the same continuing defect, or two for the same serious safety hazard, may support a presumption when the timing and other conditions are met." | tx-en.html `tx.s2_p` | supported | Tex. Occ. Code §2301.605(a)(1)-(2) — https://tcss.legis.texas.gov/resources/OC/htm/OC.2301.htm — "the same nonconformity continues to exist after being subject to repair four or more times"; "creates a serious safety hazard and continues to exist after causing the vehicle to have been subject to repair two or more times"; "the attempts were made before the earlier of:(A) the date the express warranty expires; or(B) 24 months or 24,000 miles, whichever occurs first" | None |
| TX-02 | "A total of at least 30 qualifying repair days can matter. Comparable manufacturer- or distributor-provided loaner days are excluded, and a substantial defect must remain." | `tx.s3_p` | supported | §2301.605(a)(3), (c) — "out of service for repair for a cumulative total of 30 or more days"; "do not include any period during which the manufacturer or distributor lends the owner a comparable motor vehicle while the owner's vehicle is being repaired by a franchised dealer." | None required; optional precision in §7 |
| TX-03 | "The defect must be reported during applicable warranty coverage. Notice to the manufacturer and a final repair opportunity also matter." | `tx.s6_p` | supported | §2301.603(a)-(b) — "during the term of the warranty, the owner or the owner's agent reported the nonconformity"; §2301.606(c) — "has provided written notice … and(2) the manufacturer, converter, or distributor has been given an opportunity to cure"; 43 TAC §224.232(f)(2) — https://ftp.txdmv.gov/pub/txdmv-info/ogc/rules/2024/Chapter-224-Adopt.pdf | None |
| TX-04 | "An eligible new vehicle may be repurchased under Texas rules, with a reasonable allowance for use and adjustments required by law." | `tx.o1_p` | supported | §2301.604(a)(2) — "refund to the owner the full purchase price, less a reasonable allowance for the owner's use of the vehicle, and any other allowances or refunds payable to the owner"; 43 TAC §224.260(b)(1)-(3) — https://www.law.cornell.edu/regulations/texas/43-Tex-Admin-Code-SS-224-260 | None |
| TX-05 | "An eligible new vehicle may be replaced with a comparable vehicle, subject to the required adjustments." | `tx.o2_p` | supported | §2301.604(a)(1) — "replace the motor vehicle with a comparable motor vehicle"; 43 TAC §224.230(b)(2) — "Comparable motor vehicle--A new motor vehicle, with comparable mileage, from the same manufacturer, distributor, or converter's product line and the same model year or newer"; §224.260(d)(2)(A) | None |
| TX-06 | "Used vehicles do not receive a TxDMV Lemon Law buyback or replacement." | `tx.o3_p` | supported (attorney review) | TxDMV — https://www.txdmv.gov/motorists/consumer-protection/lemon-law — "(Please Note: only new vehicles can qualify for a refund or replacement)"; OAH 22-0003434 CAF — https://ftp.txdmv.gov/pub/txdmv-info/oah/actions/website_pdfs/22-0003434_CAF.pdf — "Replacement and repurchase relief only apply to new vehicles. TEX. OCC. CODE § 2301.603."; §2301.002(24) | Keep the substance. Flag: §2301.604(a) says "a motor vehicle" and §2301.601(2)(E) counts a Texas-resident transferee as an "owner"; the new-vehicle limit rests on §2301.603(a) and non-precedential agency orders. Optional attribution in §7 |
| TX-07 | "Used vehicles may qualify for warranty-repair assistance if the applicable manufacturer warranty and reporting requirements are met, but not a TxDMV Lemon Law buyback or replacement." | `tx.a2`, `tx.result_used_p`, lemon-law-en.html Texas card | supported (attorney review) | TxDMV — "Texas law related to warranty performance may cover your used vehicle if it is still covered by the manufacturer's original warranty"; §2301.204(a); 43 TAC §224.232(f)(1), §224.260(e); OAH 22-0003434 CAF — "the vehicle may still qualify for repair relief under the Warranty Performance Law." | None required; same caveat as TX-06 |
| TX-08 | "New purchased or leased vehicles may qualify for Texas repurchase or replacement relief." | `tx.a2` | supported | §2301.601(2)(B) — "is a lessor or lessee, other than a sublessee, who purchased or leased the vehicle from a license holder"; §2301.608(c) — "the final order may terminate the lease and apportion allowances or refunds" | None |
| TX-09 | "A TxDMV Lemon Law complaint must be filed within six months after the earliest of express-warranty expiration, 24 months after delivery, or 24,000 miles after delivery." | tx-en.html FAQ a4 / `tx.a4` (first sentence) | **needs-correction** (verdict: refuted = false, high) | §2301.606(d) — "A proceeding under this subchapter must be commenced not later than six months after the earliest of:(1) the expiration date of the express warranty term; or(2) the dates on which 24 months or 24,000 miles have passed since the date of original delivery of the motor vehicle to an owner."; 43 TAC §224.232(e)(2) — "A lemon law proceeding commences on the date the filing fee is received by the department."; §224.232(e)(1) — "Failure to pay the filing fee when submitting a complaint will delay the start of the 150-day period … and may result in dismissal" | Six-month/earliest-of structure is right; tie commencement to TxDMV's receipt of the fee and say "original delivery". Rewrite in §5, item 2 |
| TX-10 | "The mileage trigger does not apply to towable RVs." (stated as a rule of law) | `tx.a4`, `tx.deadline_note`, `tx.note_window`, `common.h_timing` | **needs-correction** (refuted = false, high) | §§2301.605, 2301.606(d) contain no towable-RV or odometer exception ("towable" appears only in §2301.002(23)(D), (32) and unrelated dealer provisions); TxDMV — "The mileage requirements generally do not apply to TRVs or other vehicles that do not have an odometer." and "24,000 miles following the date of delivery of the vehicle (except TRVs)."; 43 TAC §224.260(b)(3) — "There is a rebuttable presumption the expected useful life of a towable recreational vehicle is 5,475 days or 15 years." (use allowance only) | Attribute to TxDMV guidance and keep its qualifier "generally" in all four strings; do not present as statutory text. §5, items 2–5 |
| TX-11 | "Do not wait: the TxDMV complaint deadline is six months after the earliest of warranty expiration, 24 months, or 24,000 miles from delivery; the mileage trigger does not apply to towable RVs. …" | `tx.deadline_note` | **needs-correction** (refuted = false, high) | Same as TX-09/TX-10; TxDMV — "To be safe, the complaint should be filed as soon as the consumer realizes the dealer is having problems repairing the vehicle." | Rewrite in §5, item 3 ("must reach TxDMV"; "express-warranty"; attributed TRV sentence) |
| TX-12 | "Repair counts require dates and mileage within the earliest warranty / 24-month / 24,000-mile period. The mileage trigger does not apply to towable RVs." | `tx.note_window` | **needs-correction** (refuted = false, high) | Sentence one: §2301.605(a)(1)-(3) — "the attempts were made before the earlier of:(A) the date the express warranty expires; or(B) 24 months or 24,000 miles, whichever occurs first, following the date of original delivery of the motor vehicle to the owner". Sentence two: TxDMV guidance only (TX-10) | Keep sentence one; replace sentence two with the attributed wording that also says the warranty-expiration and 24-month limits still apply. §5, item 4 |
| TX-13 | "Count only repairs before the earliest of the express warranty ending, 24 months from original delivery, or 24,000 miles after original delivery. For a towable RV, the mileage limit does not apply." | `common.q_timing` / `common.h_timing` (Texas flow) | **needs-correction** (refuted = false, high) | Sentence one: §2301.605(a); §2301.605(b) — "extended for any period that repair services are not available to the owner because of: (1) a war, invasion, or strike; or (2) a fire, flood, or other natural disaster." Sentence two: TxDMV guidance only | Keep sentence one; attribute sentence two to TxDMV. §5, item 5 |
| TX-14 | "For this Texas screen, count only out-of-service days within the initial coverage period. Exclude days the manufacturer or distributor provided a comparable loaner. Do not count the same day twice." | `common.q_loaner`, `h_loaner` | supported | §2301.605(a)(3), (c) — "cumulative total of 30 or more days"; "do not include any period during which the manufacturer or distributor lends the owner a comparable motor vehicle" | None |
| TX-15 | "Was the manufacturer notified in writing?" / "A dealer visit is not necessarily written notice to the manufacturer." / `note_notice` | `common.q_notice`, `h_notice`, `tx.note_notice` | supported (attorney review) | §2301.606(c) — "(1) the owner, a person on behalf of the owner, or the department has provided written notice of the alleged defect or nonconformity to the manufacturer, converter, or distributor; and(2) the manufacturer, converter, or distributor has been given an opportunity to cure"; TxDMV — "provides notice of the complaint with a last opportunity to repair defect to the applicable manufacturer."; 43 TAC §224.232(b)(2)(I) | None required; optional addition in §7 so a missing letter is not read as fatal |
| TX-16 | "Your answers suggest a repair-history threshold worth checking under Texas law. Written notice, a final repair opportunity, coverage, a remaining qualifying defect, and timely filing still require review." | `tx.note_signal` | supported | §2301.605(a) — "A rebuttable presumption that a reasonable number of attempts have been undertaken"; §2301.606(b)-(d) | None |
| TX-17 | "Qualifying days must exclude comparable manufacturer or distributor loaner days and fall within the applicable initial period." | `tx.note_loaner` | supported | §2301.605(c), (a)(3) | None |
| TX-18 | "An administrative process run by the Texas Department of Motor Vehicles under Occupations Code chapter 2301, with its own complaint and hearing steps." | lemon-law-en.html Texas card | supported | TxDMV — "The Texas Lemon Law is a state law administered by the Texas Department of Motor Vehicles"; §2301.607(a) — "is not available to the owner of the vehicle unless the owner has exhausted the administrative remedies provided by this subchapter"; 43 TAC §224.230(a); SOS portal listing | None |
| TX-19 | "Texas has a specific process for vehicle warranty disputes." | `tx.hero_p` | supported | Same as TX-18 | None |
| TX-20 | "Texas representation requires an appropriately authorized attorney and a separate agreement. No outcome is guaranteed. This check does not file a TxDMV complaint or preserve a deadline." | tx-en.html `tx.disclosure` | supported | Tex. Disciplinary R. 5.05(a)(1), (b) — https://txcourts.gov/media/1459244/texas-disciplinary-rules-of-professional-conduct-pdf.pdf — "only a lawyer who is admitted to practice in this jurisdiction may hold out to the public or otherwise represent that the lawyer is admitted to practice law in this jurisdiction."; 43 TAC §224.232(c), (e)(2) | None here; see F22 for the responsible-lawyer line that must be added to this disclosure |
| TX-21 | "For example, a life-threatening loss of vehicle control or a substantial fire or explosion risk. Not every safety complaint meets this legal standard." | `common.h_safety` (Texas flow) | supported | §2301.601(4) — "'Serious safety hazard' means a life-threatening malfunction or nonconformity that:(A) substantially impedes a person's ability to control or operate a motor vehicle for ordinary use or intended purposes; or(B) creates a substantial risk of fire or explosion." | None |
| TX-22 | "Count days unavailable because of warranty repairs, across all defects. An estimate is fine." / "Exactly 30 days" | `common.q_days`, `h_days`, `opt_d30` (Texas flow) | uncertain (refuted = false, high) | §2301.605(a)(3) — "a nonconformity still exists that substantially impairs the vehicle's use or market value, the vehicle is out of service for repair for a cumulative total of 30 or more days"; TxDMV — "For a total of 30 days or more - not necessarily all at one time"; OAH 24-0009092 CAF (quotes "30 or more", then paraphrases "more than 30"); Dutchmen Mfg., Inc. v. Tex. Dep't of Transp., 383 S.W.3d 217 (Tex. App.-Austin 2012) — https://www.courtlistener.com/opinion/2955150/dutchmen-manufacturing-inc-v-texas-department-of-transportation-motor/ (multi-defect vehicle "out of service for more than 80 days"; aggregation uncontested) | Keep the option structure; "Exactly 30 days" sits inside "30 or more". Attorney to confirm "across all defects" ((a)(1)-(2) say "the same nonconformity", (a)(3) only "a nonconformity") or adopt the softened wording in §6. Leave the separate loaner screen in place |
| TX-23 | (No fee amount stated in copy) | tx-en.html / `locales/en.js` | supported | §2301.712(a)(1) — "$35 for a complaint filed under Subchapter M"; TxDMV — "files a Lemon Law complaint with the $35 filing fee"; 43 TAC §224.232(f)(1) — "A filing fee is not required for a complaint that is subject to a warranty performance claim." | No copy change; if a fee is ever added, use "$35 (none for a repair-only warranty complaint)" |
| TX-24 | 43 TAC Subchapter G text relied on (§§224.230–224.268) is current | authority check | supported (attorney review) | SOS portal listing (queryAsDate 10/12/2026); 2024 adoption Exhibit A; LII source note "Adopted by Texas Register, Volume 49, Number 17, April 26, 2024, TexReg 2788, eff. 6/1/2024"; 2025 SB 2807 adoption — "The effective date of these revisions to Chapter 224 is February 27, 2026" (Subchapters A, D, E, F, H, I only) | None; counsel should eyeball the portal's rendered rule text once, since tools could not read the iframe |

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## 4. Firm facts and advertising table

Framework note: SB 37 (Stats. 2025, Ch. 645), effective January 1, 2026, rewrote Bus. & Prof. Code §6157 so that "advertisement" now reaches "any communication, through any written, recorded, or electronic means … that provides information concerning a lawyer or the lawyer's services for the purpose of encouraging individuals to secure the services of the lawyer or their law firm", added §6157.2(a)(5) (skills/experience/record) and (a)(6) (recognition/awards), and created a private right of action in §6157.2(c) with statutory damages of $5,000 to $100,000 per unique advertisement "or three times the amount of actual damages, whichever is larger" (subject to the (c)(1) preconditions). Texas Part VII rules (eff. July 1, 2021) have had only the Jan. 31, 2022 amendment to Comment 10 of Rule 7.01 since; the 2024 and 2025 orders touched other Parts. Because Parisa Fishback is Texas-licensed (TX License Date 09/11/2025), Texas Rule 8.05 applies to the site's Texas advertising.

| ID | Claim (page copy) | Page / key | Status | Authority (URL + quote) | Action |
|---|---|---|---|---|---|
| F01 | "Admitted in California, 2016" (Asadi) | home-en.html line 246 | supported | CalBar #310086 — https://apps.calbar.ca.gov/attorney/Licensee/Detail/310086 — "6/1/2016 Admitted to the State Bar of California"; "License Status: Active" | None |
| F02 | "Whittier Law School, J.D. 2015" (Asadi) | line 247 | supported | CalBar #310086 "Law School: Whittier Coll SOL; CA"; year from https://unitedlegal.com/attorneys/ "Whittier Law School (J.D., 2015)" | None |
| F03 | "Cal State Fullerton, B.A. Finance 2012" (Asadi) | line 248 | not-verifiable-online | Only source https://unitedlegal.com/attorneys/; B&P §6158.2(f) treats "Schools attended, with dates of graduation, degrees" as presumptively compliant "provided the message as a whole is not false, misleading, or deceptive." | Attorney review: keep if the firm confirms; otherwise drop the year |
| F04 | "Admitted in California, 2008" (Fishback) | line 257 | supported | CalBar #255218 — https://apps.calbar.ca.gov/attorney/Licensee/Detail/255218 — "2/15/2008 Admitted to the State Bar of California"; "License Status: Active" | None |
| F05 | "Texas, 2025" / "Parisa Fishback is also admitted in Texas (2025)" | lines 257, 282 | supported | State Bar of Texas directory, ContactID 391033 — "Parisa Fishback Eligible to Practice in Texas"; "Bar Card Number: 24148277"; "TX License Date: 09/11/2025"; "No Public Disciplinary History" | None |
| F06 | "Partner" title for Fishback; firm reviews Texas matters through her | lines 253–255, 282; tx-en.html line 241 | uncertain (refuted = false, high) | Texas directory — "Fishback Law Corporation"; "Firm Size: Solo"; "Primary Practice Location: Newport Beach , California"; "Practice Areas: Bankruptcy"; "This information is self-reported by Texas attorneys."; CalBar #255218 address "Fishback Law Corp, 4590 Macarthur Blvd, STE 500, Newport Beach, CA 92660-2028"; Texas Rule 7.01(f) — https://www.texasbar.com/Content/NavigationMenu/ForLawyers/AdvertisingReview/ADRULES2023.pdf — "A lawyer may state or imply that the lawyer practices in a partnership or other business entity only when that is accurate."; Rule 7.02(a) | Attorney review (§6): confirm partnership status and primary practice location; the bar record does not disprove the partnership (she may hold it through her professional corporation) but conflicts on its face with the page |
| F07 | "Chapman University Fowler School of Law, J.D. 2007" | line 258 | supported | CalBar #255218 "Law School: Chapman Univ SOL; Orange CA"; Texas directory "Chapman University Doctor of Jurisprudence/Juris Doctor (J.D.) Graduation Date 05/2007" | None |
| F08 | "Loyola Marymount University, B.S. 1998" | line 259 | not-verifiable-online | Only source https://unitedlegal.com/attorneys/ | Attorney review: keep if confirmed; otherwise drop the year |
| F09 | "Served as an extern clerk for the Chief Federal Judge of the United States Bankruptcy Court" | line 255 | uncertain (refuted = false, high) | No court has a "Chief Federal Judge"; Fishback's own FindLaw profile — https://lawyers.findlaw.com/profile/view/4883846_1 — "Honorable John E. Ryan, Chief Judge of the United States Bankruptcy Court, Extern Clerkship"; Judge Ryan was a CACB bankruptcy judge (Santa Ana) 1986–Jan. 2, 2007 and "Chief Judge, Ninth Circuit Bankruptcy Appellate Panel (2001-03)" (https://www.americancollegeofbankruptcy.com/directory/john-e-ryan-301); CACB chief judges in the externship window were Geraldine Mund (1997–2002) and Barry Russell (2003–07) (https://www.cacb.uscourts.gov/sites/cacb/files/documents/publications/Annual_Report_1999.pdf ; https://www.americancollegeofbankruptcy.com/directory/barry-russell-141); CRPC 7.1(a); B&P §6157.2(a)(5) — "Misleading, deceptive, or false statements, words, or phrases regarding a lawyer's or law firm's skills, experience, or record." | Rewrite after the firm confirms judge and year (§6). Do not use "Chief Judge of the U.S. Bankruptcy Court for the Central District of California" |
| F10 | "Bankruptcy attorney since 2008." | line 255 | supported | CalBar #255218 admission 2/15/2008; Texas directory "Practice Areas: Bankruptcy" | None |
| F11 | "worked at a national creditor firm" | line 255 | not-verifiable-online | https://unitedlegal.com/attorneys/ — "worked for one of the largest National creditor firms"; B&P §6158 — "must be factually substantiated" / "capable of verification by a credible source" | None; keep a record substantiating the employer |
| F12 | "Fluent in Farsi." | line 255 | supported | CalBar #255218 — "Additional Languages Spoken: By the attorney: Farsi By staff: Farsi"; Texas directory "Foreign Language Assistance: Persian/Farsi" | None |
| F13 | "Admitted in California, 2008" (Gavilanes) | line 268 (also home-es.html and home-fa.html line 268; https://unitedlegal.com/attorneys/) | **needs-correction** (refuted = false, high) | CalBar #308454 — https://apps.calbar.ca.gov/attorney/Licensee/Detail/308454 — "1/11/2016 Admitted to the State Bar of California"; "License Status: Active"; QuickSearch "Gavilanes, Daniel Christopher \| Active \| 308454 \| Irvine \| January 2016" (no Gavilanes admitted in 2008); B&P §6157.1 — "No advertisement shall contain any false, misleading, or deceptive statement"; CRPC 7.1(a) | Change to 2016 in en/es/fa and on the live attorneys page. §5, item 7 |
| F14 | "J.D. and LL.M. in Taxation" (Gavilanes) | line 269 | uncertain (refuted = false, medium) | CalBar #308454 "Law School: Whittier Coll SOL; CA"; https://www.adamscorporatelaw.com/about-us/daniel-gavilanes/ — "He received his Juris Doctorate from the Whittier College School of Law in 2015" and "In 2017, Daniel received his post graduate degree, Legum Magister (LL.M), in Transactional Taxation" (Boston University School of Law); https://gavilancorporatelaw.com/about/ — "LL.M. in Corporate Taxation: Boston University School of Law"; BU Graduate Tax Program confers the "LLM in Taxation" | The LL.M. is substantiated; fill in institution and year (§6). Keep the degree title "LL.M. in Taxation" |
| F15 | Firm page shows Gavilanes with Asadi's education block (Whittier J.D. 2015; CSUF B.A. Finance 2012) | https://unitedlegal.com/attorneys/; home-en.html lines 262–271 | uncertain (refuted = false, high) | Both attended Whittier and were admitted in 2016 (CalBar #310086, #308454); Gavilanes's own bios state "B.A. in Political Science: California State University, Fullerton" (https://gavilancorporatelaw.com/about/) and "Bachelor of Arts in political science from California State University, Fullerton in 2012" (https://asadilawgroup.com/daniel-gavilanes.html) | Whittier J.D. 2015 is genuinely his and may be reinstated; do not publish "B.A. Finance" for Gavilanes; fix the admission year on both pages (§6) |
| F16 | "United Legal Advocates is a three-attorney firm in Irvine." with Co-Founder & Managing Partner / Partner titles | lines 236, 242, 253, 264 | **refuted as drafted** (verdict: refuted = true, high) — the underlying question stays open | The proposed correction cited "CRPC 7.5(d)", which does not exist (Rule 7.5 has subdivisions (a)–(c) only); the operative text is CRPC 7.5(c) — "A lawyer shall not state or imply that the lawyer practices in or has a professional relationship with a law firm or other organization unless that is the fact."; Rules of the State Bar 3.171(A) permits an LLP partner to be "a law corporation that is licensed or entitled to practice law", so separate professional corporations and LLP partnership are not mutually exclusive; Texas Rule 7.01(f); CalBar addresses of record show "ASADI LAW GROUP, APC", "Gavilan Corporate Law, APC" (both 19200 Von Karman Ave, Ste 600) and "Fishback Law Corp" (Newport Beach); BBB profile lists "Nima Asadi (Co-Founder)" and "Parisa Fishback (Partner)", founded March 21, 2025; https://unitedlegal.com/terms/ — "CA Bar No. 255218 is responsible for the content of this advertisement." | Finding withdrawn as drafted; replaced by the attorney-review item in §6 (confirm in writing that each attorney practices in the LLP in the capacity shown; LLP certificate of registration and SOS filing) |
| F17 | "BBB Accredited Business. View the profile." | lines 87, 284; footer.js | supported (fact of accreditation) | BBB profile — https://www.bbb.org/us/ca/irvine/profile/bankruptcy-attorney/united-legal-advocates-llp-1126-1000149638 — "BBB Accredited since 8/15/2025"; rating "A-"; "19200 Von Karman Ave Ste 600, Irvine, CA 92612-8516"; "Areas served: California and Texas" | None as to the fact; see F18 |
| F18 | Displaying the BBB seal/statement in California lawyer advertising after Jan. 1, 2026 | lines 87, 284; footer.js line 18 (`.bbb-seal`, shared by all 12 pages); home-es/home-fa lines 87/284 | uncertain (refuted = false, high) | B&P §6157.2(a)(6) — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=6157.2. — "References to a lawyer's or a law firm's recognition by, or awards from, an organization, unless both of the following requirements are met: (A) The recognition or award is not conferred by virtue of being a member of the organization. (B) The organization does not charge or solicit a fee, cost, or payment for the recognition or award."; "(Amended by Stats. 2025, Ch. 645, Sec. 5. (SB 37) Effective January 1, 2026.)"; BBB — https://www.bbb.org/bbb/great-west-pacific/accreditation-benefits — "BBB charges a fee for BBB Accreditation."; BBB Boston — "BBB Member dues are based on the amount of full time employees per business."; §6158.7 (discipline); no published interpretation of (a)(6) as applied to BBB found | Pending counsel's determination, remove the seal and all "BBB Accredited Business" wording site-wide (§6). Do not substitute any rating or badge. Live site needs the same decision |
| F19 | Three bankruptcy client reviews with the note "…are not a prediction of the outcome of any other matter." | lines 290–305; `.rev-note` at line 302 | **needs-correction** (refuted = false, high) | Reviews verified on https://unitedlegal.com/ ("Why Clients Love United Legal"; all 11 reviews are bankruptcy/debt relief); CRPC 7.1 Comment [4] — "a testimonial about or endorsement of the lawyer, may be misleading if presented so as to lead a reasonable person to form an unjustified expectation … An appropriate disclaimer or qualifying language often avoids creating unjustified expectations."; B&P §6157(c) — "'Electronic medium' means television, radio, or computer networks."; §6158.1(a); §6158.3 — "must state that the result portrayed in the advertisement was dependent on the facts of that case, and that the results will differ if based on different facts."; "Use of the following disclosure alone may not rebut any presumption created in Section 6158.1."; §6158; §6159.1 — "A true and correct copy of any advertisement … shall be retained for one year"; Texas Rule 7.01 Comment 5 and 7.01(d) | Replace the note with the §6158.3 formulation; quote reviews verbatim or mark as excerpts (the page blockquotes alter the live text); mirror in Spanish. §5, item 8 |
| F20 | "No result or representation is guaranteed." / "No score, no odds, no guarantee." | lines 222, 322 | supported | B&P §6157.2(a)(1) — "A guarantee or warranty of success regarding the outcome of a legal matter"; CRPC 7.1 Comment [2]; Texas Rule 7.01(a) | None |
| F21 | Responsible firm name and office address on each page (California) | home-en.html line 322 (static); lemon-law-en.html (footer.js only); ca-en/tx-en line 241 (static) | **needs-correction** (refuted = false, high) | CRPC 7.2(c) — "Any communication made pursuant to this rule shall include the name and address of at least one lawyer or law firm responsible for its content."; B&P §6157.2(b) — "shall contain the following information conspicuously displayed … (1) The name of at least one lawyer licensed to practice law in California, the law firm … (2) Disclosure of the city, town, or county of at least one bona fide office location or the address of record listed with the State Bar"; build check: lemon-law-en.html has no firm name or address in its HTML (only `<div id="site-footer">` at line 120 and footer.js at line 125); lemon-law-es.html and lemon-law-fa.html have the same gap | Hardening fix (neither authority mandates static markup): add the static close-disclosure paragraph to the three lemon-law pages. §5, item 9 |
| F22 | Texas: advertisement names the responsible lawyer and primary practice location | home-en.html line 322; lemon-law-en.html (no disclosure at all); tx-en.html line 241 | **needs-correction** (refuted = false, high) | Texas Rule 7.02(a) — "An advertisement of legal services shall publish the name of a lawyer who is responsible for the content of the advertisement and identify the lawyer's primary practice location."; Rule 7.01(d) — "made in each language used in the communication."; Rule 7.01(c) (jurisdictional limitations); Rule 7.05 cmt. 2 — "the entire website of a lawyer or law firm must be compliant with Rules 7.01 and 7.02"; Rule 8.05(b)(1); Texas directory — "Primary Practice Location: Newport Beach , California" | Add a responsible-lawyer line (Fishback, both bar numbers, primary practice location as she confirms it) in en/es/fa on home, lemon-law and tx pages. §5, item 10 |
| F23 | Whether a Texas advertising filing applies | home-en.html as the site homepage (plus home-es/home-fa); lemon-law-en.html; tx-en.html | **needs-correction** (refuted = false, high) | Texas Rule 7.04(a) — "no later than ten (10) days after the date of dissemination of an advertisement of legal services"; Rule 7.04(c) — "not fewer than thirty (30) days prior to the date of first dissemination"; Rule 7.05(b) — "information and links posted on a law firm website, except the contents of the website homepage, unless that information is otherwise exempt from filing"; Rule 7.05(i) (names/addresses, practice areas, admissions, education, languages, consultation fees, required disclosures); Rule 7.05 cmt. 2; Advertising Review page — "The Advertising Review application fee is $100." and a "$250 fine and a $100 review fee" for non-compliance; Ethics Question July/Aug 2025 | Process item, not copy: file the homepage (and its es/fa versions, with translations as the Advertising Review Department directs) within 10 days of going live or pre-approve 30 days ahead. Non-homepage pages are exempt only if they comply with 7.01–7.03. §5, item 11 |
| F24 | Headline "The other side has a legal department. Meet yours." | line 84 | uncertain (refuted = false, high) | CRPC 7.1(a) and Comment [3] — "A truthful statement is also misleading if it is presented in a manner that creates a substantial likelihood that it will lead a reasonable person to formulate a specific conclusion about the lawyer or the lawyer's services for which there is no reasonable factual foundation."; B&P §6157.1; §6157.2(a)(5), (c); Texas Rule 7.01(a) | No change strictly required (rhetorical puffery; the page's "If we accept your case" and "does not create an attorney-client relationship" lines counter the implication). Optional rewording in §7 |
| F25 | Lede: seven practice areas and "see your next step before you share a single contact detail" | line 85 | uncertain (refuted = false, high) | CRPC 7.4(b) — "a lawyer may communicate the fact that the lawyer does or does not practice in particular fields of law."; Texas Rule 7.02 cmt. 3 — "must be objectively based on the lawyer's experience, specialized training, or education in the area of practice."; Texas Rule 7.01 cmt. 4 — "misleading if, at the time a lawyer makes the communication, the lawyer knows or reasonably should know, but fails to disclose, that a prospective client responding to the communication is likely to be referred to a lawyer in another firm."; live site confirms in-house California Lemon Law (https://unitedlegal.com/lemon-law/), bankruptcy/debt and creditor harassment, and an Attorney Referral Network (https://unitedlegal.com/attorney-referral-network/); nothing for employment, TCPA, FCRA, estate planning or Texas Lemon Law | Attorney review (§6): confirm per practice area what is handled in-house; add a referral disclosure where a referral is likely; optional "preliminary next step" wording |
| F26 | "The firm serves clients in English, Spanish, and Persian." | lines 89, 283 | supported | CalBar self-reports: #310086 "By the attorney: Persian By staff: Persian, Spanish"; #308454 "By the attorney: Spanish"; #255218 "By the attorney: Farsi"; CRPC 7.1 Comment [5]; Texas Rule 7.01(d); B&P §6158.2(o) | None required; optional in §7 |
| F27 | Bankruptcy & Debt Relief advertised without the debt-relief-agency statement | lines 138–145, 290–305, 322; footer.js (en/es/fa) | **needs-correction** (refuted = false, high) | 11 U.S.C. §528(a)(3)-(4), (b)(2) — https://www.law.cornell.edu/uscode/text/11/528 — "clearly and conspicuously use the following statement in such advertisement: 'We are a debt relief agency. We help people file for bankruptcy relief under the Bankruptcy Code.' or a substantially similar statement."; "(A) disclose clearly and conspicuously in such advertisement that the assistance may involve bankruptcy relief under this title"; no Amendments note since Pub. L. 109–8 (2005); Milavetz, 559 U.S. 229 syllabus — "Attorneys who provide bankruptcy assistance to assisted persons are debt relief agencies under the BAPCPA."; grep of the build and the live homepage: no "debt relief agency" string | Add the statement, same size and contrast as surrounding disclosure text, in three places and all languages. §5, item 12 |
| F28 | "Federal telephone-consumer rules set limits." | line 160 | supported | 47 U.S.C. §227(b)(1)(A), (b)(3) — https://www.law.cornell.edu/uscode/text/47/227 — "$500 in damages for each such violation" | None |
| F29 | Credit Reporting blurb: "a wrongful denial" | line 169 | **refuted** (verdict: refuted = true, high) — no change required | 15 U.S.C. §1681m(a) is correctly quoted but does not support the finding's ECOA conclusion; FCRA treats denials based on reports as its own subject (§1681b(b)(3)(A), §1681e(c), §1681n(a)(1)(A)); the first proposed replacement would wrongly imply a pre-denial right to see the report (employment-only under §1681b(b)(3)(A)); the second points to §1681m(a), which §1681m(h)(8)(A) makes privately unenforceable — Perry v. First Nat'l Bank, 459 F.3d 816 (7th Cir. 2006) — https://law.resource.org/pub/us/case/reporter/F3/459/459.F3d.816.05-3867.html — "unambiguously refers to section 1681m as a whole."; Doe v. Charter Communications, 131 F.4th 323 (5th Cir. 2025) — https://www.courtlistener.com/opinion/10356622/doe-v-charter-communications/ — "section 1681m(h)(8) bars private enforcement of section 1681m in its entirety." | Keep the existing sentence. Optional tighter wording in §7 only if the firm wants it |
| F30 | "Federal and state collection laws limit what collectors may do, and how." | line 178 | supported | 15 U.S.C. §1692e — https://www.law.cornell.edu/uscode/text/15/1692e — "A debt collector may not use any false, deceptive, or misleading representation or means" | None |
| F31 | Employment blurb | line 151 | supported | Descriptive list; no legal proposition asserted | None |
| F32 | Estate planning blurb | line 187 | supported | Descriptive list | None |
| F33 | California presumption bullet on the chooser | lemon-law-en.html line 79 | supported | Civ. Code §1793.22(b) — https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CIV&sectionNum=1793.22. — "This presumption shall be a rebuttable presumption" | None |
| F34 | "A civil claim under the Song-Beverly Consumer Warranty Act, pursued against the manufacturer." | line 78 | supported | Civ. Code §1793.22(b) — "may be asserted by the buyer in any civil action, including an action in small claims court"; Rodriguez — "Section 1793.2, subdivision (d)(2) gives new car buyers what is known as a refund-or-replace remedy" | None |
| F35 | "Used vehicles depend on the warranty issued with the sale, not just leftover factory coverage." | line 80 | supported | Rodriguez (handoff copy of the official opinion) — "unless the new car warranty was issued with the sale." | None |
| F36 | Texas: "An administrative process run by the Texas Department of Motor Vehicles under Occupations Code chapter 2301" | lines 70, 89 | supported | TxDMV — "is a state law administered by the Texas Department of Motor Vehicles"; §2301.204(c) | None |
| F37 | Texas deadline bullet on the chooser | line 90 | supported | §2301.606(d); TxDMV — "A Lemon Law complaint must be filed within six (6) months following the earlier of:" | None (see §7 for optional alignment with the rewritten `tx.a4`) |
| F38 | Texas used vehicles "may have a warranty-repair route, but not a TxDMV buyback or replacement" | line 91 | supported | TxDMV — "only new vehicles can qualify for a refund or replacement"; §2301.603(a); §2301.204(a) | None |
| F39 | Office address and phone (866) 855-0505 | lines 281, 322; footer.js | supported | BBB profile; CalBar addresses of record for #310086 and #308454 "19200 Von Karman Ave, Ste 600, Irvine, CA 92612-8516"; https://unitedlegal.com/ | None |
| F40 | No certified-specialist or special-competence claims | home-en.html; lemon-law-en.html | supported | CRPC 7.4(a); Texas Rule 7.02(b); neither page uses "specialist", "certified" or "expert" | None; keep "focuses on" wording |
| F41 | Short form "United Legal" as the firm's name | lemon-law-en.html line 70; logo alt text | supported | CRPC 7.5(a); Texas Rule 7.01(c) — "Lawyers may practice law under a trade name that is not false or misleading."; firm site already warns it "is not affiliated with 'United Legal Services of America' located in Corona, California." | None; optional in §7 |

---

## 5. Corrections recommended before publication

Only findings that survived verification (refuted = false) and carry status `needs-correction` appear here. Wording below is the exact consumer-facing text to use; it contains no citations. Where a string exists in `locales/es.js` and `locales/fa.js`, the same change must be mirrored (the Spanish and Persian strings for CA-24 are given; the Texas es/fa strings were not reviewed and need a conformed translation of the English below).

### 5.1 CA-24 — California safety question uses "could" where the standard is "likely"

**Files / keys:** `locales/en.js`, `locales/es.js`, `locales/fa.js` → `common.q_ca_safety`, `common.h_ca_safety`. No change to `qualifier-rules.js`.

| Key | Current (en) | New |
|---|---|---|
| `q_ca_safety` (en) | Could this same defect cause death or serious injury? | Is this same defect likely to cause death or serious bodily injury if the vehicle is driven? |
| `h_ca_safety` (en) | Consider the risk if the vehicle is driven. An attorney must assess whether the legal safety standard is met. | Think about the risk when the vehicle is driven. Not every safety complaint meets this legal standard; an attorney must assess it. |
| `q_ca_safety` (es) | ¿…podría causar…? | ¿Es probable que este mismo defecto cause la muerte o lesiones corporales graves si se conduce el vehículo? |
| `h_ca_safety` (es) | — | Piense en el riesgo al conducir el vehículo. No toda queja de seguridad cumple este criterio legal; un abogado debe evaluarlo. |
| `q_ca_safety` (fa) | …می‌تواند باعث … شود | آیا احتمال دارد همین نقص، در صورت رانندگی با خودرو، باعث مرگ یا آسیب جسمی جدی شود؟ |
| `h_ca_safety` (fa) | — | خطر هنگام رانندگی با خودرو را در نظر بگیرید. هر شکایت ایمنی لزوماً این معیار قانونی را برآورده نمی‌کند؛ وکیل باید آن را بررسی کند. |

### 5.2 TX-09 + TX-10 — Texas FAQ a4 (deadline and towable-RV sentence)

**File / key:** tx-en.html FAQ a4 / `locales/en.js` → `tx.a4`.

Current: "A TxDMV Lemon Law complaint must be filed within six months after the earliest of express-warranty expiration, 24 months after delivery, or 24,000 miles after delivery. The mileage trigger does not apply to towable RVs. Dates and other rules need prompt review; other claims may have different deadlines."

New: "TxDMV must receive your Lemon Law complaint and the filing fee within six months after the earliest of: (1) the expiration of the express warranty term; (2) 24 months after the vehicle's original delivery to an owner; or (3) 24,000 miles after that original delivery. Under TxDMV rules the proceeding does not begin until TxDMV receives the filing fee, so send the fee with the complaint. TxDMV guidance says the mileage limits generally do not apply to towable RVs or other vehicles without an odometer; the warranty-expiration and 24-month limits still apply. Dates and other rules need prompt review; other claims may have different deadlines."

### 5.3 TX-11 — Texas deadline note

**File / key:** `locales/en.js` → `tx.deadline_note`.

Current: "Do not wait: the TxDMV complaint deadline is six months after the earliest of warranty expiration, 24 months, or 24,000 miles from delivery; the mileage trigger does not apply to towable RVs. This check does not calculate your deadline or file a complaint."

New: "Do not wait: a TxDMV Lemon Law complaint and its filing fee must reach TxDMV within six months after the earliest of express-warranty expiration, 24 months, or 24,000 miles from original delivery (TxDMV treats the proceeding as commenced only when it receives the filing fee); TxDMV says the mileage limits generally do not apply to towable RVs. This check does not calculate your deadline or file a complaint."

### 5.4 TX-12 — Texas window note

**File / key:** `locales/en.js` → `tx.note_window`.

Current: "Repair counts require dates and mileage within the earliest warranty / 24-month / 24,000-mile period. The mileage trigger does not apply to towable RVs."

New: "Repair counts require dates and mileage within the earliest warranty / 24-month / 24,000-mile period. TxDMV says the mileage requirements generally do not apply to towable RVs or other vehicles without an odometer; the warranty-expiration and 24-month limits still apply."

### 5.5 TX-13 — Texas timing hint

**File / key:** `locales/en.js` → `common.h_timing` (shown only in the Texas flow; `q_timing` unchanged).

Current: "Count only repairs before the earliest of the express warranty ending, 24 months from original delivery, or 24,000 miles after original delivery. For a towable RV, the mileage limit does not apply."

New: "Count only repairs before the earliest of the express warranty ending, 24 months from original delivery, or 24,000 miles after original delivery. For a towable RV or other vehicle without an odometer, TxDMV says the mileage limit generally does not apply; the express-warranty and 24-month limits still apply."

(The TX-10 verdict preferred moving any Texas-specific towable-RV sentence out of a shared `common` string. Because `h_timing` is rendered only in the Texas flow, the attributed sentence may stay; if the key is ever reused for California, move the sentence to a `tx.*` key.)

### 5.6 TX-09–TX-13 — Spanish and Persian Texas strings

**Files / keys:** `locales/es.js`, `locales/fa.js` → `tx.a4`, `tx.deadline_note`, `tx.note_window`, `common.h_timing`. Translate 5.2–5.5 faithfully; do not keep any unattributed "the mileage trigger does not apply to towable RVs" sentence.

### 5.7 F13 — Gavilanes admission year

**Files:** home-en.html line 268, home-es.html line 268, home-fa.html line 268; also the live https://unitedlegal.com/attorneys/ "Bar Admissions" bullet.

| File | Current | New |
|---|---|---|
| home-en.html | Admitted in California, 2008 | Admitted in California, 2016 |
| home-es.html | Admitido a ejercer en California, 2008 | Admitido a ejercer en California, 2016 |
| home-fa.html | (Persian digits ۲۰۰۸) | (Persian digits ۲۰۱۶) |

Attorney to confirm no other jurisdiction admission should be listed (CalBar records California only; neither page claims another).

### 5.8 F19 — Client-review note

**File:** home-en.html line 302 (`p.rev-note`); same note in Spanish on home-es.html; Persian on home-fa.html.

Current: "These are debt-relief client reviews published on unitedlegal.com. They describe those clients' experiences and are not a prediction of the outcome of any other matter."

New: "Reviews from the firm's bankruptcy and debt-relief clients. Each result depended on the facts of that client's case, and results will differ if based on different facts. These reviews are not a guarantee or prediction of the outcome of any other matter."

Implementation notes: (1) quote each review verbatim from the retained source review, or label each block "excerpt" — the current blockquotes alter the live-site text (Faranak M. on the live site: "not only helped me to eliminate my debts also helped me to rebuild my credit"; Fay: "every step of the process"; Andre L. appears on the live site as fragments joined by paraphrase); (2) keep the "Published client reviews · Debt relief" eyebrow and keep the block away from the Lemon Law, employment and consumer sections; (3) do not add "with their permission" unless written client consents are on file; (4) keep a dated true copy of the published page for at least one year and separately keep the source reviews and any consents on file.

### 5.9 F21 — Static close-disclosure on the lemon-law chooser pages

**Files:** lemon-law-en.html, lemon-law-es.html, lemon-law-fa.html (inside `<main>`, before the footer div). ca-en/tx-en (line 241) and home-en (line 322) already carry a static disclosure.

Add (English; use the existing translated wording for es/fa): "Attorney advertising. United Legal Advocates, LLP · 19200 Von Karman Ave., Suite 600, Irvine, CA 92612. General information, not legal advice. No result or representation is guaranteed. Using this page does not create an attorney-client relationship or preserve a deadline."

This is a hardening fix (removes the dependence on footer.js rendering); do not add any statement about outcomes, speed or cost beyond that paragraph.

### 5.10 F22 — Texas responsible-lawyer line

**Files:** home-en.html line 322 close-disclosure; tx-en.html line 241 final disclosure (`tx.disclosure`); lemon-law-en.html (new disclosure block from 5.9); same line in Spanish on the -es pages and in Persian on the -fa pages.

Add: "Attorney responsible for the content of this advertisement: Parisa Fishback (Texas Bar No. 24148277; California Bar No. 255218). Primary practice location: Newport Beach, California."

Use "primary practice location", not "Principal office". Newport Beach is the location Fishback herself reported to the State Bar of Texas; if her primary practice location is in fact the firm's Irvine office, she should first update her Texas Bar profile (firm name and primary practice location) and only then should the line read "Primary practice location: Irvine, California". Keep the existing home-en.html statement that she is admitted in Texas (2025) and the tx-en.html sentence "Texas representation requires an appropriately authorized attorney and a separate agreement." Attorney review: Fishback's consent to be named and consistency with her Texas profile's firm listing (see F06 in §6).

### 5.11 F23 — Texas Advertising Review filing (process, not copy)

**Files:** home-en.html as the deployed homepage, together with home-es.html and home-fa.html reached from the language toggle.

Action: the homepage contains a tagline, published client reviews, a BBB seal, practice-area blurbs and the interactive Quick Check, so it is not within the Texas filing exemption. File a copy of the homepage as it appears, the application and the $100 fee with the Advertising Review Committee no later than ten days after the page goes live, or submit for optional pre-approval at least thirty days before first dissemination. Confirm with the Advertising Review Department whether the Spanish and Persian versions are filed as separate applications with English translations. lemon-law-*.html, tx-*.html and other non-homepage pages are exempt from filing only if they comply with the content rules (5.9, 5.10). Failure to file a non-exempt advertisement may draw a $250 fine plus a $100 review fee.

### 5.12 F27 — Debt-relief-agency statement

**Files:** (a) home-en.html line 322 close-disclosure, immediately after "Attorney advertising."; (b) a visible line under or beside the "Bankruptcy & Debt Relief" practice card (lines 138–145); (c) the footer disclaimer block in footer.js (en/es/fa) so it appears on every page, including the Chapter 7, Chapter 13, Foreclosure & Repossession, Creditor Harassment and Rebuild Credit pages. Same statement, faithfully translated, on the Spanish and Persian pages (the attorney may elect to retain the English statutory sentence alongside the translation). Apply the same statement to the firm's live site.

Add: "We are a debt relief agency. We help people file for bankruptcy relief under the Bankruptcy Code. The debt-relief, foreclosure, and creditor-harassment services advertised on this site are with respect to bankruptcy relief under the Bankruptcy Code, and assistance with unpaid debts, foreclosure, or debt-collection pressure may involve bankruptcy relief."

Render it in the same size and contrast as the surrounding disclosure text (not reduced small print). Attorney sign-off required before deployment.

---

## 6. Attorney-review items

Everything `uncertain`, `not-verifiable-online`, or flagged `attorneyReview: true`. Proposed wording is documented so the firm can adopt it once the underlying fact is confirmed; nothing in this section is applied to the build without that confirmation (except where §5 already applies the compliance-driven change).

| ID | Item | What the firm must confirm or decide | Proposed wording / action once confirmed |
|---|---|---|---|
| CA-12 | California close-disclosure | (a) United Legal Advocates, LLP is the lawyer/law firm responsible for the advertisement; (b) the Irvine address is a bona fide office or the State Bar address of record; (c) the disclosure is conspicuously displayed, not only in small footer type | No wording change |
| CA-13 | "No-cost initial review" | The initial review is in fact free of charge; the page continues not to advertise contingency or "no fee unless we win" terms | No wording change |
| TX-06 / TX-07 | "Used vehicles do not receive a TxDMV Lemon Law buyback or replacement." | Whether to attribute the new-vehicle limit to TxDMV (the statute's refund/replace remedy says "a motor vehicle" and a Texas-resident transferee counts as an "owner"; the limit rests on the repair-duty section and non-precedential agency orders) | Optional: "Under TxDMV's guidance and decisions, only new vehicles qualify for a Lemon Law refund or replacement." |
| TX-09–TX-13 | Rewritten Texas deadline/TRV strings (§5.2–5.6) | Sign off on the fee-receipt framing and the TxDMV-attributed towable-RV sentence | As in §5 |
| TX-15 | Written-notice question | Whether to add a reassurance so a missing letter is not read as fatal | Optional addition to `tx.note_notice`: "TxDMV also sends the manufacturer notice and a final repair opportunity after a complaint is filed." |
| TX-22 | `common.h_days` "across all defects" (Texas flow) | Either keep "across all defects" with attorney sign-off (the repair-count prongs say "the same nonconformity" while the 30-day prong says only "a nonconformity"; a 2012 Austin appellate decision counted total days for a multi-defect vehicle without contest) or soften | Softened alternative: "Count the days the vehicle was out of service for warranty repairs. An estimate is fine." Keep the option structure (No days / 1–29 / Exactly 30 / More than 30) and the separate loaner screen. Do not describe 30 days as "qualifying" the vehicle |
| TX-24 | 43 TAC Subchapter G currency | Eyeball the SOS portal's rendered rule text once (tools could not read the iframe) | None |
| F03 | Asadi "Cal State Fullerton, B.A. Finance 2012" | Confirm degree and year | Keep if confirmed; otherwise drop the year |
| F06 | Fishback "Partner"; Texas review through her | (a) Whether she is in fact a partner of United Legal Advocates, LLP (she may hold it through Fishback Law Corp); (b) her primary practice location. Her self-reported Texas entry lists "Fishback Law Corporation", "Firm Size: Solo", Newport Beach | Keep "Partner" (en/es/fa) only if confirmed; otherwise use the accurate designation (e.g. "Of Counsel"). The Texas-admission statement may stay. If Irvine is her primary practice location, she should update her Texas Bar entry so the bar records and the website agree |
| F08 | Fishback "Loyola Marymount University, B.S. 1998" | Confirm degree and year | Keep if confirmed; otherwise drop the year |
| F09 | "extern clerk for the Chief Federal Judge of the United States Bankruptcy Court" | Confirm the judge (her own profile names Hon. John E. Ryan) and year(s). Judge Ryan was not Chief Judge of the Central District bankruptcy court; his chief-judge role was on the Ninth Circuit Bankruptcy Appellate Panel | After confirmation: "Served as a judicial extern to the Hon. John E. Ryan, U.S. Bankruptcy Judge for the Central District of California (Santa Ana Division) and former Presiding Judge of the Ninth Circuit Bankruptcy Appellate Panel." Shorter: "Served as a judicial extern to the Hon. John E. Ryan of the U.S. Bankruptcy Court for the Central District of California." Fallback if the judge cannot be confirmed: "Served as a judicial extern in the U.S. Bankruptcy Court for the Central District of California." Apply to the Persian page and any duplicate copies |
| F11 | "worked at a national creditor firm" | Keep a record substantiating the employer | None |
| F14 | Gavilanes "J.D. and LL.M. in Taxation" | Confirm the 2017 conferral year (sourced from a prior-employer bio and LinkedIn dates, not a BU record) | Line 269 → "Whittier Law School, J.D. 2015; Boston University School of Law, LL.M. in Taxation, 2017" (or without the year: "Boston University School of Law, LL.M. in Taxation"). Keep the title "LL.M. in Taxation"; do not use "Transactional" or "Corporate Taxation" |
| F15 | Firm page duplicates Asadi's education block under Gavilanes | Confirm Gavilanes's undergraduate degree (his own bios say B.A. in Political Science, CSU Fullerton, 2012) | Do not publish "B.A. Finance" for Gavilanes; reinstate "Whittier Law School (J.D., 2015)"; ask the firm to correct the same line on its attorney page |
| F16 (replacement) | "three-attorney firm" and partner titles | Confirm in writing that Asadi, Gavilanes and Fishback each practice in United Legal Advocates, LLP in the capacity shown (individually or through their law corporations), that the LLP holds a current State Bar LLP certificate of registration and a Secretary of State LLP filing, and that no other attorney practices in the LLP | If any relationship differs, replace the title with the accurate description; if other attorneys practice in the LLP, correct the number or say "the firm's attorneys". Be prepared to document the LLP structure, since the attorneys' bar addresses of record and the Texas directory show the separate corporations |
| F18 | BBB seal and "Accreditation" fact card | California counsel to determine whether paid BBB accreditation is a "recognition by … an organization" under the 2026 advertising statute. BBB states it charges a fee and describes accredited businesses as members paying dues; the open question is whether an accreditation is a "recognition or award" at all. No State Bar or judicial guidance found | Pending that determination: remove the seal and all "BBB Accredited Business" wording from home-en.html lines 87 and 284 (including the "View the profile" link), the same lines in home-es.html ("Acreditación") and home-fa.html ("اعتبارنامه"), and the `.bbb-seal` block in footer.js line 18 with its `bbbAlt`/`bBBLinkLabel` strings (site-wide, since footer.js is shared by all 12 pages); delete the HTML comment about the badge at line 125 of ca-*/tx-*.html. Do not substitute any rating, grade or badge. The live site needs the same decision |
| F19 | Client reviews | Written client consents on file; whether Faranak M.'s result statement should carry brief factual context (e.g. the chapter filed), since the disclaimer alone may not rebut the presumption | As in §5.8 |
| F22 | Responsible-lawyer line | Fishback consents to being named; naming her for a United Legal Advocates, LLP advertisement is consistent with her Texas profile's firm listing | As in §5.10 |
| F23 | Texas filing | Confirm applicability (Texas-licensed lawyer advertising Texas services) and choose filing within 10 days vs. pre-approval 30 days ahead; confirm handling of es/fa versions | As in §5.11 |
| F24 | Headline | Whether to remove the "Meet yours" implication | "The other side has a legal department. You should have one too." or "The other side has lawyers. You should too." Keep "If we accept your case" visible on the first screen |
| F25 | Seven practice areas in the lede | Per area, whether the matter is handled in-house. Live site shows in-house California Lemon Law, bankruptcy/debt and creditor harassment; nothing for employment, TCPA/robocalls, FCRA/credit-report errors, estate planning or Texas Lemon Law; the firm operates a public Attorney Referral Network | Remove or disclose any area not handled in-house. Where a referral is likely, add near the practice board and in the Quick Check result: "Some matters, including [list the specific areas], are handled together with, or referred to, lawyers at other firms." Optional: "…see a preliminary next step before you share a single contact detail." Any fee division with outside lawyers in California needs written client consent |
| F27 | Debt-relief-agency statement | Sign off on placement and translations | As in §5.12 |
| F26 | Languages | Optional: name who provides each language on the Spanish and Persian pages | Optional |
| Citator | Post-Rodriguez history; AB 1755/SB 26 interpretation; Texas used-vehicle, transferee, loaner-comparability and days-aggregation questions | Run a citator check before publication | None |

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## 7. Items deliberately NOT changed

The build brief preserves the settled screening logic (question order, routing in `qualifier-rules.js`, option sets, signal thresholds). The items below were verified as accurate and are left as they are; the optional wording is recorded here for the firm's future use.

| ID | Current copy (kept) | Why unchanged | Proposed optional wording / note for the firm |
|---|---|---|---|
| CA-07 | `ca.o2_p`: "A covered vehicle may be replaced. The applicable remedy depends on the facts and the law." | Accurate as written | Optional accuracy upgrade: "A covered vehicle may be replaced, and the buyer may choose restitution instead of a replacement." |
| CA-11 | `ca.a4`: "…whether the manufacturer elected California’s newer procedures." | Accurate as of 2026-10-12 | Optional precision: "…whether the manufacturer elected California’s newer procedures for the year your vehicle was sold new." Do not add specific year counts |
| CA-24 (routing) | `qualifier-rules.js` lines 33, 77, 83–84 (`ca_safety` asked when visits ≥ 2; `safety-attempts` signal when visits 2–4 and answer is yes) | Screening logic preserved; the question wording fix in §5.1 is enough. The verifier noted the CA branch does not gate the safety signal on the 18-month/18,000-mile window the way the Texas branch gates on timing | Possible future enhancement, not applied: gate the CA `safety-attempts` signal on `ca_window = inside`, or add a note that the two-repair presumption also needs the timing window and at least one direct notice to the manufacturer |
| CA-25 | CA flow does not ask the written-notice question (`notice` is routed only for Texas) | Screening logic preserved; `review_deadline` ("any required manufacturer notice or repair opportunity") and `note_signal` keep the copy accurate | Optional California-only note when the four-attempt or safety-attempt signal fires: "For the repair-count presumption, California law can also require that you notified the manufacturer directly at least once; keep any letters or emails." |
| CA-27 | `common.opt_major`: "It seriously affects use, value, or safety" | Accurate | Optional statutory verb: "It substantially impairs the vehicle’s use, value, or safety" |
| TX-02 | `tx.s3_p` loaner sentence | Accurate | Optional precision: the exclusion is for a comparable vehicle the manufacturer or distributor lends while a franchised dealer repairs the vehicle |
| TX-06 | `tx.o3_p`: "Used vehicles do not receive a TxDMV Lemon Law buyback or replacement." | Substance supported by TxDMV guidance and decisions | See §6 for the optional attribution |
| TX-15 | `tx.note_notice` | Accurate | See §6 for the optional reassurance sentence |
| TX-22 | `common.h_days` "across all defects"; `opt_d30` "Exactly 30 days" | Option structure and Texas signal logic preserved; "Exactly 30 days" is inside "30 or more"; the loaner exclusion already lives on its own screen (`q_loaner`/`h_loaner`/`note_loaner`) | Attorney decides between keeping "across all defects" and the softened wording in §6; do not fold the loaner exclusion into `h_days` |
| TX-23 | No filing-fee amount in copy | Nothing to change | If a fee is ever added: "$35 (none for a repair-only warranty complaint)" |
| F24 | Headline "The other side has a legal department. Meet yours." | Rhetorical puffery; no verifiable factual claim; page counter-language present | See §6 |
| F26 | "The firm serves clients in English, Spanish, and Persian." | Attorney-level Spanish and Persian are self-reported to the State Bar | Optional: name who provides each language |
| F29 | "a wrongful denial" in the Credit Reporting blurb | Finding refuted; existing sentence is accurate plain-English intake copy, and both proposed replacements would have made the page less accurate | Only if the firm wants tighter wording: "Errors on a credit report, accounts you don't recognize, a denial caused by a report that was wrong, or a background check that got it wrong." |
| F37 | lemon-law-en.html line 90: "A hard deadline: a Lemon Law complaint must be filed within six months after the earliest of warranty expiration, 24 months, or 24,000 miles from delivery." | Supported; chooser-level summary | Optional alignment with §5.2: "…must reach TxDMV within six months after the earliest of express-warranty expiration, 24 months, or 24,000 miles from original delivery." |
| F41 | "United Legal" short form | Full name appears in disclosure/footer | Optional: use "United Legal Advocates, LLP reviews …" once in the chooser lede |
| CA-30 / TX-24 | Framework descriptions | Current | Re-check leginfo, the DCA election list (republished by December 15 each year) and the TxDMV rules pages before each publication cycle |

*End of memo.*