ESTTA Tracking number: ESTTA1437852
`Filing date: 05/27/2025
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Notice of Opposition
`
`Notice is hereby given that the following party opposes registration of the indicated application.
`
`Opposer information
`
`Name Justin Johanson
`
`Granted to date 05/25/2025
`of previous ex-
`tension
`
`Address 21920 E PEGASUS PKWY
`QUEEN CREEK, AZ 85142
`UNITED STATES
`
`Correspondence | JUSTIN JOHANSON
`
`information 21920 E PEGASUS PKWY
`
`QUEEN CREEK, AZ 85142
`
`UNITED STATES
`
`Primary email: justin@3tmlaw.com
`
`Secondary email(s): justin@3tmlaw.com, justin@lawangels.com
`4808452030
`
`Applicant information
`
`Application no. 98137203 Publication date 11/26/2024
`Opposition filing 05/27/2025 Opposition period | 05/25/2025
`date ends
`
`Applicant Legal Angels, LLC
`
`470 THIRD AVENUE, SUITE 8
`CHULA VISTA, CA 91910
`UNITED STATES OF AMERICA
`
`Goods/services affected by opposition
`
`Class 045. First Use: Mar 1, 2007 First Use In Commerce: Mar 1, 2007
`All goods and services in the class are opposed, namely: Legal services, excluding intellectual prop-
`erty legal services
`
`Grounds for opposition
`
`Priority and likelihood of confusion Trademark Act Section 2(d)
`
`Applicant not rightful owner of mark for identified | Trademark Act Section 1
`goods or services
`
`Other Applicant does not have senior common law
`trademark rights, use is geographically limited,
`and Lack of Use in Interstate Commerce
`
`Mark cited by opposer as basis for opposition
`
`U.S. application 98328449 Application date 12/22/2023
`no.
`
`
`
`
`
`
`
`
`
`Registration date
`
`NONE Foreign priority NONE
`date
`
`Word mark
`
`LAW ANGELS
`
`Design mark
`
`Law Angels
`
`Description of
`mark
`
`Goods/services
`
`Class 045. First use: First Use: Jan 1, 2013 First Use In Commerce: Jan 1, 2013
`
`Legal services; Legal advisory services; Legal consultation services; Legal in-
`formation services; Providing information about legal services via a website
`
`Attachments 98328449#TMSN.png( bytes )
`Trademark Argument_Opposition_law Angels.pdf(5055256 bytes )
`Signature /JUSTIN JOHANSON/
`Name JUSTIN JOHANSON
`Date 05/26/2025
`
`
`
`
`
`
`
`
`
`NOTICE OF OPPOSITION
`
`Opposer, Justin Johanson, an individual residing at 21920 E. Pegasus Parkway, Queen
`Creek, Arizona 85142, believes he will be damaged by registration of Application Serial No.
`98137203 for the mark "LEGAL ANGELS" ("Applicant’s Mark" or "Applicant’s Application")
`filed by Legal Angels, LLC ("Applicant"), a California limited liability company, having an
`address at 470 Third Avenue, Suite 8, Chula Vista, California 91910, and published for purposes
`
`of opposition in the Official Gazette on November 26, 2024.
`
`Opposer filed a First 30-Day Request for Extension of Time to Oppose Applicant’s
`Application on December 4, 2024, which the Trademark Trial and Appeal Board granted,
`extending the opposition deadline to January 3, 2025. Opposer subsequently filed an Additional
`60-Day Request for Extension of Time to Oppose on January 23, 2025, which was granted,
`further extending the opposition deadline to March 26, 2025. Opposer subsequently filed an
`Additional 60-Day Request for Extension of Time to Oppose on March 26, 2025, which was
`
`granted, further extending the opposition deadline to May 25, 2025.
`
`Opposer has attempted and continues to attempt to resolve its concerns directly with
`Applicant, to discuss potential coexistence or resolution. Applicant originally agreed to the
`consent agreement but later withdrew such consent indicating and unwillingness to enter into a
`consent agreement. As such, to preserve Opposer’s rights, Opposer hereby opposes Applicant’s
`Application. Opposer hereby opposes registration of the same. As grounds for opposition,
`
`Opposer alleges as follows:
`
`BACKGROUND
`
`1. Opposer’s Use of "Law Angels": Opposer is a licensed attorney who has used the mark
`
`"Law Angels" in commerce in connection with legal services, specifically toxic
`
`
`
`
`
`
`
`
`tort/personal injury and intellectual property law in Arizona, Colorado, and Utah
`
`(www.lawangels.com) and (www.angellawgroup.com), since at least as early as January 1,
`
`2013. Opposer also operates under the trade name “Angel Law Group”
`
`(www.angellawgroup.com) along with “Law Angels, emphasizing personalized legal
`
`representation in Arizona and other regions where his services have achieved market
`penetration. See Exhibit A. Opposer also operates under the trade name “Innovative IP
`Law” (www.innovativelPlaw.com) along with the brand name “Law Angels, emphasizing
`personalized legal representation for patent and trademarks legal services in all 50 states
`where such Intellectual Property services have achieved market penetration. See Exhibit
`
`A.
`
`Applicant’s Application: Applicant filed U.S. Trademark Application Serial No.
`98137203 for the mark "Legal Angels" on August 17, 2023, claiming first use in
`commerce as of March 1, 2007, for "legal services, excluding intellectual property legal
`services." Applicant’s services, as evidenced by its website
`(https://www.legalangelsparalegals.com/) and amended application, are marketed
`primarily by paralegals and focus on family law, estate planning, and bankruptcy, with
`mention of an in-house attorney. See Exhibit B. Applicant’s application was rejected on
`April 17, 2024 based on prior federal registration for "Legal Angels" (U.S. Registration
`No. 5803796) and other cited references, later canceled on June 5, 2024. Applicant
`subsequently obtained several consent agreements from the cited marks, and even
`
`narrowed the scope to exclude Intellectual Property Law.
`
`Prior Federal Registration of "Legal Angels": As mentioned, a prior federal registration
`for "Legal Angels" (U.S. Registration No. 5803796, issued on July 16, 2019, with a
`claimed first use date of June 30, 2018, was cancelled under Section 18 by the TTAB on
`
`June 5, 2024. Applicant received an Office Action on April 17, 2024, refusing registration
`
`
`
`
`
`
`
`
`under Section 2(d) of the Lanham Act due to a likelihood of confusion with this prior
`registered mark, among others. The rejection based on U.S. Registration No. 5803796 was
`overcome after the mark was abandoned in June 2024. This cancellation resulted from
`
`proceedings unrelated to the current Applicant.
`
`Opposer’s Seniority and Market Presence: Opposer has developed substantial goodwill
`in the "Law Angels" mark through continuous use since 2013, particularly in Arizona,
`Utah and other areas of market penetration for toxic tort/personal injury and intellectual
`property legal services. Opposer’s mark is associated with high-quality, specialized legal
`
`representation, as evidenced by his websites (www.lawangels.com),
`
`(https://angellawgroup.com/), and (www. innovativelplaw.com).
`
`Likelihood of Confusion: If Applicant is permitted to register "Legal Angels," such
`registration is likely to cause confusion with Opposer’s "Law Angels" mark, damaging
`
`Opposer’s established rights and goodwill.
`
`COUNT I: LIKELIHOOD OF CONFUSION
`
`6.
`
`Opposer repeats and realleges paragraphs 1-5 as paragraph 6 of this Count I.
`
`Priority of Use: Opposer’s use of "Law Angels" predates Applicant’s federal filing date
`of August 17, 2023. While Applicant claims a common law use date of March 1, 2007, its
`rights are limited to the geographic areas where it has established actual use and
`recognition. Common law trademark rights do not extend nationwide but are confined to
`territories of market penetration (Dudley v. Healthsource Chiropractic, Inc., 883
`F.Supp.2d 377 (W.D.N.Y. 2012)). Applicant’s evidence, including its website and
`specimen, suggests use primarily in Chula Vista, California, with no clear demonstration
`
`of nationwide market penetration let alone areas within California beyond Chula Vista. In
`
`
`
`
`
`
`
`
`fact, Applicants website promotes and advertises as “Legal Angel Paralegals,” which
`restricts its services to paralegal-driven tasks such as document preparation and court
`filing support, primarily for family law, estate planning, and bankruptcy cases in Chula
`Vista, California. While Applicant offers clients the option to speak with an in-house
`attorney for court representation upon request, this attorney’s practice is likely limited to
`California due to state bar licensing requirements, and the core of Applicant’s operations
`remains paralegal-focused. This branding and focus on paralegal services, coupled with
`Applicant’s operations centered one block from the Superior Court and fifteen minutes
`from the downtown court in Chula Vista, indicate a predominantly intrastate business
`model, with no evidence of use or recognition in Opposer’s markets, such as Arizona,
`Colorado, Utah, or nationwide for intellectual property services (Spiral Direct, Inc. v.
`Basic Sports Apparel, Inc., 293 F.Supp.3d 1334, 1357 (M.D. Fla. 2017)). Consequently,
`Applicant’s common law rights are confined to its limited geographic area of use, and
`federal registration of “Legal Angels” would improperly extend Applicant’s rights beyond
`California, risking confusion with Opposer’s established “Law Angels” mark in regions
`where Opposer has senior common law priority since 2013 (United Drug Co. v. Theodore
`Rectanus Co., 248 U.S. 90, 100 (1918)). Applicant does not have common law
`
`rights/prior use in Opposer’s markets.
`
`Abandonment of Prior Registration: Applicant has never had nationwide priority for
`"Legal Angels" and could not claim it due to the existence of the prior federal registration
`for "Legal Angels" (Reg. No. 5803796), which was issued in 2019 and conferred
`nationwide priority under 15 U.S.C. § 1057(c) until its abandonment in June 2024. The
`Applicant’s common law rights from 2007 were always geographically limited and could
`not extend nationwide over Opposer. (United Drug Co. v. Theodore Rectanus Co., 248
`
`U.S. 90, 100 (1918)). The 2019 registration blocked any nationwide priority claim by
`
`
`
`
`
`
`
`
`10.
`
`11.
`
`Applicant until its cancellation, and even after the abandonment in June 2024, Applicant’s
`ability to assert nationwide priority arose too late to supersede Opposer’s rights. Opposer’s
`filing for "Law Angels" in December 2023, combined with its constructive use under 15
`U.S.C. § 1057, establishes nationwide priority over Applicant’s geographically limited
`
`common law rights.
`
`Similarity of Marks: For purposes of this opposition, the marks "Law Angels" and
`"Legal Angels" could be viewed as similar in sound, appearance, and connotation due to
`their shared use of the word "Angels" with a legal descriptor ("Law" vs. "Legal"). This
`potential similarity may create a likelihood of confusion among consumers as to the
`
`source of the services if Applicant’s mark is registered
`
`Relatedness of Services: While Applicant’s services are limited to family law, estate
`planning, and bankruptcy (excluding intellectual property law per its consent agreements,
`which Applicant obtained prior to receiving a Notice of Publication), and Opposer’s
`services focus on toxic tort/personal injury and intellectual property law, both parties
`operate within the broader category of "legal services." In fact, Applicant amended the
`goods and services to read “Legal services, excluding intellectual property legal
`services.” Consumers encountering the marks are likely to assume an affiliation or
`common source, particularly given the overlapping professional context (Enterprises, Inc.
`
`v. Advanced Programming Resources, Inc., 249 F.3d 564 (6th Cir. 2001)).
`
`Likelihood of Confusion: Applicant’s use and registration of "Legal Angels" may lead to
`confusion, mistake, or deception within the meaning of Section 2(d) of the Lanham Act,
`15 U.S.C. § 1052(d), particularly if the marks are viewed as similar. Even slight
`differences in services do not eliminate confusion when marks are similar and operate in
`
`related fields.
`
`
`
`
`
`
`
`
`COUNT Il: GEOGRAPHIC LIMITATION OF APPLICANT’S RIGHTS
`
`12.
`
`13.
`
`14.
`
`15.
`
`Opposer repeats and realleges paragraphs 1-11 as paragraph 12 of this Count II.
`
`Geographic Restriction of Common Law Rights: Applicant’s common law use of
`"Legal Angels" since 2007 is limited to the geographic areas where it has established
`market penetration and consumer recognition (Spiral Direct, Inc. v. Basic Sports Apparel,
`Inc., 293 F.Supp.3d 1334 (M.D. Fla. 2017)). Applicant cannot claim common law priority
`rights in an area where it never personally used the mark in commerce. Applicant’s
`website and specimen indicate primary use in Chula Vista, California, with no evidence of
`use in Arizona, Utah, Colorado or indication of any nationwide expansion or recognition
`
`beyond that region.
`
`Applicant’s California-Centric Operations: Applicant primarily provides paralegal
`services, branding itself as "Legal Angels Paralegal," with a focus on family law, estate
`planning, and bankruptcy, and is located in Chula Vista, California, just one block from
`the Superior Court and 15 minutes from the downtown court. Applicant emphasizes its
`role in filing documents directly with California courts, maintaining daily contact with
`court clerks, and acting as a liaison for clients in that jurisdiction. While Applicant offers
`an in-house attorney for court representation upon request, this attorney’s practice is likely
`limited to California due to state bar licensing requirements, further restricting Applicant’s
`operations to California and not other states such as, for example, Arizona, Colorado,
`Utah, or anywhere that Opposer operates in providing Federal intellectual patent and
`
`trademark services at the USPTO (e.g., patent and trademark legal services).
`
`Opposer’s Priority as a Senior Common Law User: Opposer has senior common law
`
`user in Arizona, Colorado, and Utah and other areas where toxic tort/personal injury and
`
`
`
`
`
`
`
`
`16.
`
`intellectual property services are provided (e.g., patent and trademark law is based on
`Federal Law and are legal services offered Nationwide). These rights predate Applicant’s
`federal filing (August 17, 2023) and are not subject to Applicant’s limited common law
`territory. See United Drug Co. v. Theodore Rectanus Co., 248 U.S. 90, 100 (1918)); see
`also V & V Food Products, Inc. v. Cacique Cheese Co., Inc., 683 F.Supp. 662 (N.D. IIL.
`1988)). Opposer began using "Law Angels" in 2013, before Applicant’s filing date of
`August 17, 2023, and has continuously used the mark, establishing valid common law
`rights in those regions. Thus, Opposer holds valid senior common law trademark rights in
`these jurisdictions, enabling Opposer to enjoin any other users within this geographic area
`of use from continuing to infringe on the trademark. Wiener King, Inc. v. Wiener King
`Corp., 192 U.S.P.Q. (BNA) 353, 356-57 (3d Cir. 1976) (granting the junior trademark
`user a nationwide injunction against the senior user with the exception of the senior user's
`area of trademark protection), cert denied, 430 U.S. 916 (1977). Thus, Opposer can
`preclude Applicant from using "Legal Angels" in Opposer’s geographic areas, further
`
`limiting Applicant’s rights to California.
`
`Applicant’s Intrastate Use Limits Federal Protection: Under the Lanham Act, a mark
`must be used in interstate commerce to qualify for federal protection, as Congress’s
`authority to regulate trademarks stems from the Commerce Clause (U.S. Const. art. I, § 8,
`cl. 3), which grants Congress the power to regulate commerce among the states (15 U.S.C.
`§ 1051). Intrastate use, however, only affords common law rights in the geographic area of
`use and its natural zone of expansion. Applicant’s operations, centered in Chula Vista,
`California, with services tied to local courts and an in-house attorney likely licensed only
`in California, indicate primarily intrastate use. There is no evidence that Applicant serves
`customers outside California or otherwise impacts interstate commerce, further limiting its
`
`common law rights to California and precluding federal registration under the Lanham
`
`
`
`
`
`
`
`
`17.
`
`18.
`
`Act.
`
`Freezing Effect of Federal Registration on Opposer’s Rights: If Applicant’s mark were
`federally registered, it would gain presumptive nationwide rights under 15 U.S.C. §
`1057(c), but this would freeze Opposer’s prior common law rights to their extent as of the
`registration date. Opposer’s rights to expand into other geographic areas, such as
`neighboring regions, would be blocked, despite Opposer’s prior use since 2013.
`Applicant’s use in California, remote from Opposer’s areas, may not initially cause
`confusion, but federal registration would improperly grant Applicant nationwide priority,
`potentially allowing expansion into Opposer’s areas and causing confusion, thus harming
`
`Opposer’s established rights.
`
`No Nationwide Priority for Applicant: Applicant’s 2007 common law use of "Legal
`Angels" does not confer nationwide priority, as common law rights are limited to the
`geographic areas of actual use and recognition. Absent a valid federal registration,
`Applicant cannot claim nationwide priority. Applicant’s common law use of "Legal
`Angels" since 2007 is limited to the geographic areas where it has established market
`penetration and consumer recognition. Applicant’s website and specimen indicate primary
`use in Chula Vista, California, with no evidence of nationwide expansion or recognition
`beyond that region. The 2019 registration ("Legal Angels" (Reg. No. 5803796) blocked
`any nationwide priority claim by Applicant, which the USPTO recognized by issuing an
`Office Action citing likelihood of confusion on. The abandonment of the prior "Legal
`Angels" registration (Reg. No. 5803796) in 2024 further restricts Applicant to its pre-2024
`common law are of Chula Vista, California, leaving Opposer free to assert rights in areas
`where Applicant has not established use (Dudley v. Healthsource Chiropractic, Inc., 883
`
`F.Supp.2d 377 (W.D.N.Y. 2012)).
`
`
`
`
`
`
`
`
`COUNT Il: DISTINCT SERVICES AND CONCURRENT USE AS A BASIS TO DENY
`
`REGISTRATION
`
`19.
`
`20.
`
`21.
`
`Opposer repeats and realleges paragraphs 1-20 as paragraph 21 of this Count HI.
`
`Independent Basis for Opposition: Even if the Board does not sustain Counts I and II,
`Count III provides an independent basis to deny registration of Applicant’s mark under
`Trademark Act § 2(d) (15 U.S.C. § 1052(d)). While the distinct nature of the services and
`the possibility of concurrent use might suggest coexistence under specific conditions,
`registration of "Legal Angels" should be denied because no conditions or limitations can
`adequately eliminate the likelihood of confusion with "Law Angels," given the shared
`
`legal context and potential for consumer overlap.
`
`Overbreadth of Applicant’s Application: Applicant’s services for “legal services,
`excluding intellectual property legal services” is broader than its actual services, which are
`paralegal-driven and limited to family law, estate planning, and bankruptcy, with an in-
`house attorney for limited court representation. Seeking registration for “legal services”
`could imply coverage of a wide range of legal activities, potentially overlapping with
`Opposer’s attorney-provided services in toxic tort/personal injury, despite the intellectual
`property exclusion. Applicant’s services marketed primarily by paralegals and limited to
`family law, estate planning, and bankruptcy, are distinct from Opposer’s attorney-
`provided services in toxic tort/personal injury and intellectual property law. Applicant’s
`consent agreements further preclude it from offering intellectual property services,
`reducing overlap with Opposer’s practice areas. Courts have recognized that different
`services under similar marks can lead to different rights and uses, as seen where a mark
`was used for disability advocacy services and not for paralegal services (Oasis Legal
`Finance Operating Company, LLC v. Chodes, 454 F.Supp.3d 724 (N.D. Ill. 2020)).
`Additionally, paralegal services are distinct from attorney services, as non-attorneys do
`
`not engage in the practice of law (LegalForce RAPC Worldwide, P.C. v. DeMassa, 532
`
`
`
`
`
`
`
`
`22.
`
`F.Supp.3d 856 (N.D. Cal. 2021), holding that non-attorneys assisting clients with
`trademark matters did not constitute the practice of law indicating a clear distinction
`between services provided by paralegals and those provided by licensed attorneys). These
`distinctions limit Applicant’s rights to its specific services and geographic area of Chula
`Vista, California. Applicant’s attempt to seek trademark registration for broad “legal
`services, excluding intellectual property legal services,” exceeds the scope of its actual
`paralegal-driven services and risks infringing on Opposer’s established “Law Angels”
`mark. The shared use of “Angels” in “Legal Angels” and “Law Angels” within the
`broader legal services context creates a likelihood of consumer confusion, as consumers
`may assume an affiliation or common source, particularly in regions where Opposer has
`established senior common law rights since 2013. This overbroad registration could
`enable Applicant to claim rights beyond its current practice areas, increasing confusion
`with Opposer’s mark in markets where Opposer operates, such as Arizona, Colorado,
`Utah, and nationwide for intellectual property services, for which Opposer has senior
`
`common law rights.
`
`Concurrent Use and Risk of Confusion: Although concurrent use might be permissible
`under Trademark Act § 2(d) (15 U.S.C. § 1052(d)), the shared legal context and the
`potential for consumer overlap, despite the distinct services, mean that no geographic or
`mode-of-use restrictions can sufficiently eliminate the likelihood of confusion. The
`Board’s role in a concurrent use proceeding is to ensure that confusion is not likely
`(TBMP § 1101.01), and registration of "Legal Angels" would grant Applicant nationwide
`priority under 15 U.S.C. § 1057(c), potentially enabling expansion into Opposer’s
`established markets and causing confusion among consumers seeking legal services
`(American Ass’n for Justice v. The American Trial Lawyers Ass’n, 698 F.Supp.2d 1129
`
`(D. Minn. 2010).
`
`
`
`
`
`
`
`
`23. Limitation of Incontestable Status: Even if Applicant were to achieve incontestable
`status after five years of registration under 15 U.S.C. § 1065, such status would not
`provide an absolute shield against Opposer’s rights. Incontestability provides conclusive
`evidence of nationwide mark ownership, but Section 15 of the Trademark Act (15 U.S.C.
`§ 1065) subjects incontestable registrations to the prior common law rights of a senior
`user. Opposer’s use of "Law Angels" since 2013 in Arizona and Utah establishes prior
`common law rights in those regions, which would allow Opposer to enjoin Applicant’s
`use in those areas, even if Applicant’s registration became incontestable. Denying
`
`registration now prevents this future conflict and protects Opposer’s established rights.
`
`24. No Expansion by Applicant: Applicant’s amendment to exclude intellectual property law
`and its focus on specific practice areas limit its ability to expand into Opposer’s fields
`(e.g., personal injury/toxic tort and intellectual property rights). However, registration
`would grant Applicant nationwide priority under 15 U.S.C. § 1057(c), which could
`undermine Opposer’s geographically established common law rights in areas where
`Applicant has not yet penetrated. Denying registration ensures that Applicant’s use
`remains geographically limited and prevents expansion of providing legal services in the
`Opposer’s senior common law rights, preventing confusion while allowing Opposer to
`
`maintain its established rights under Trademark Act § 2(d) (15 U.S.C. § 1052(d)).
`
`CLAIM FOR RELIEF/DAMAGE
`
`25. By reason of the foregoing, Applicant’s registration of "Legal Angels" will cause injury
`and damage to Opposer’s rights in "Law Angels," including loss of goodwill, dilution of
`distinctiveness, and consumer confusion. WHEREFORE, Opposer respectfully prays that
`
`this opposition be sustained and that the registration sought by Applicant be refused.
`
`
`
`
`
`
`
`
`EXHIBIT A
`
`Opposer’s website: Law Angels websites
`
`https://angellawgroup.com/
`
`& Call Now: (602) 649-2099 GET A FREE CONSULTATION
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`EXHIBIT B
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`Applicant’s website: Legal Angel website:
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`Home Practice Areas = Contact Us
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`TRULY ANGELS ON EARTH, PARALEGALS THAT CARE
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`MEET US &WE
`CAN HELP Yo
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`Experienced, knowledgable, and
`dependable.
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`E> i i$~~
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`Limited client list is small for
`personalized attention
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`LEGAL ANGELS
`PARALEGALS
`Zy
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`PRACTICE AREAS
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`— WE ARE SPECIALIZED —
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`Home Practice Areas Contact Us
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`BANKRUPTCY
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`Declaring Bankruptcy can help you eliminate most of
`your debts. Depending on the Bankruptcy Chapter
`you declare, it may be able to remove up to your
`second or third mortgage. You can also stop
`retention of your salary, auction houses, lawsuits,
`phone calls and letters from collectors by declaring
`Bankruptcy.
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`Request free consult +
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`Family Law
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`Family matters are often emotional, complicated and
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`stressful. If your family is facing a situation that can
`only be resolved within the legal system, you are
`going to need lawyers who can handle the matter
`with discretion, tact, empathy, and dedication to
`your families interests.
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`Request Free Consult +
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`* Divorces (state of California)
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`lA SO Ss
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`Estate Planning
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`Declaring Bankruptcy can help you eliminate most of
`your debts. Depending on the Bankruptcy Chapter
`you declare, it may be able to remove up to your
`second or third mortgage. You can also stop
`retention of your salary, auction houses, lawsuits,
`phone calls and letters from collectors by declaring
`Bankruptcy.
`
`Request free consult +
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`siiateatin =
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