False Statements, Mass Substitutions, and the Ethics of Attorney Withdrawal at Arnold & Smith Law

How a national debt-collection firm’s handling of attorney departures has raised serious questions about candor to the tribunal, professional responsibility, and the duties lawyers owe one another — and the courts

In the ordinary course of legal practice, the substitution of counsel is a procedural formality. One attorney steps aside, another steps in, and the case moves forward. A motion is filed, assent is obtained, and a judge signs an order. It happens thousands of times a day across American courtrooms, unremarkable and uncontested.

But what happens when an attorney represents to a court that prior counsel has been “notified” of a substitution — when, in fact, no notification was ever made? What happens when the same attorney tells a judge that prior counsel is “no longer associated” with a firm — while that very firm continues to assign the departing attorney active cases, solicit legal work from her, and ask her to appear at hearings? And what happens when these misrepresentations are not isolated incidents, but part of a pattern spanning dozens — potentially hundreds — of simultaneous filings across multiple state courts?

These are the questions at the center of an unfolding dispute between attorney Farva Jafri and Arnold & Smith Law, PLLC, a high-volume debt-collection firm headquartered in Oklahoma City with operations spanning nearly every state in the union. What began as a routine departure has metastasized into a federal civil rights lawsuit, a cascade of ethical complaints, and a rare window into how some large-scale litigation firms manage — or mismanage — the delicate process of transitioning client files when an attorney leaves.

The Firm

Arnold & Smith Law, PLLC presents itself as a full-service firm, but its primary engine is consumer debt litigation. The firm is licensed to practice in over forty states, a fact it announces with undisguised pride in the signature block of every email its staff sends. From its offices in Oklahoma, the firm dispatches attorneys to appear in courtrooms from Alabama to Wisconsin, prosecuting collection actions on behalf of banks, credit unions, and credit card companies against individual consumers who have fallen behind on their debts.

The business model is familiar to anyone who has spent time in the lower courts of American civil practice: high volume, low complexity, and razor-thin margins on individual cases that aggregate into substantial revenue across a massive portfolio. Firms like Arnold & Smith handle hundreds, sometimes thousands, of open matters at any given time. The attorneys who manage these cases often carry staggering caseloads, appearing in courts across multiple states, frequently by video or through local counsel arrangements.

It is a model that depends, above all, on efficiency. And efficiency, in the debt-collection litigation space, sometimes comes at the expense of the procedural niceties that the rules of professional conduct were designed to protect.

The Departure

Farva Jafri joined Arnold & Smith and, by her account, served the firm loyally for three and a half years. She handled hundreds of cases across eight states, appearing in courts in multiple jurisdictions and generating substantial revenue. The relationship, by all outward appearances, functioned.

Then came a billing inquiry — routine, by Jafri’s telling — that set the machinery of termination into motion. The firm released payment the very next day, suggesting the inquiry itself may have been well-founded. But within five days, Jafri was terminated. And within weeks, the firm began filing papers in her cases — motions to withdraw and substitute counsel — without, according to Jafri, ever contacting her.

This is where the story pivots from the ordinary to the extraordinary. Because in the legal profession, the process of withdrawing one attorney and substituting another is not merely an administrative task. It is a proceeding that takes place before a court, governed by rules that exist to protect clients, preserve the integrity of the judicial process, and ensure that all parties — including the departing attorney — are treated fairly. In Massachusetts, where many of these cases are pending, Rule 11(c) of the Massachusetts Rules of Civil Procedure governs the withdrawal of attorneys. The rule requires, among other things, that the withdrawing attorney identify successor counsel, that no motions be pending, and that no trial date be set — or, failing those conditions, that leave of court be obtained. The rule exists for a reason: courts have an interest in knowing who is responsible for a case at any given moment, and departing attorneys have a right not to have false representations made about them to a tribunal.

The False Statements

Attorney Echo Lin Love, a Massachusetts-barred attorney working for Arnold & Smith, was tasked with filing the motions to substitute counsel across Jafri’s Massachusetts caseload. The motions followed a template. In each one, Love represented to the court that “Attorney Farva Scott has been notified of this substitution but has not provided assent.”

According to Jafri and the documentary evidence she has compiled, this statement was false.

Jafri maintains — and her email records appear to confirm — that Love never contacted her about any substitution. Not by phone. Not by email. Not by letter. Not by any means whatsoever. Jafri’s staff, she says, called Love’s office more than forty times — twenty calls from one staff member, twenty from another — and Love never answered or returned a single call. On April 20, 2026, Jafri emailed Love directly, informing her of a pending federal lawsuit and noting that she had never been contacted about any substitution. Love did not respond.

And yet the motions went out, each one bearing the same representation: that Jafri had been “notified.”

The Massachusetts Rules of Professional Conduct are unambiguous on this point. Rule 3.3(a)(1), adopted through Supreme Judicial Court Rule 3:07, provides that a lawyer shall not knowingly make a false statement of fact or law to a tribunal. The obligation of candor toward the tribunal is among the most fundamental duties in the profession. It is not a technicality. It is not a suggestion. It is a rule that, when violated, strikes at the very foundation of the adversarial system, because courts depend on the truthfulness of the attorneys who appear before them.

A false statement in a motion — even in a procedural motion, even in a debt-collection case in a district court — is a false statement to a court. And when that false statement is made repeatedly, across dozens of cases, in multiple courts, the scope of the violation becomes difficult to characterize as anything other than systematic.

The Second Falsehood

The motions contained a second representation that Jafri contends is false: that she is “no longer working with the firm representing Defendant.” Love stated this as though it were established fact. But the evidence suggests a more complicated reality.

On April 30, 2026 — the very day Love began filing motions to substitute counsel — a legal assistant at Arnold & Smith named Justin Pickett emailed Jafri asking her to confirm whether she would attend a hearing on one of the firm’s cases. The same day, a litigation negotiator named Magdy Nagy emailed Jafri an Agreement of Judgment on another firm case, requesting she confirm acceptance and return an executed copy. The following day — May 1, 2026, the day Love filed her Reply asserting Jafri was no longer associated with the firm — a litigation auditor named Michael Adel emailed Jafri asking her to file a Motion to Withdraw in yet another case.

The firm, in other words, was simultaneously telling courts that Jafri was no longer associated with it while asking her to attend hearings, execute settlement agreements, and file motions. The contradiction is stark and, for any court evaluating the truthfulness of Love’s representations, potentially dispositive.

The Manufactured “Refusal”

When Jafri filed limited objections to correct the false statements in Love’s motions — objections in which she expressly assented to the substitution and stated she would have freely given her assent had she been asked — Love filed a Reply. In it, she attached an email Jafri had sent to Kyle Riddel, a supervisor at Arnold & Smith, and characterized it as Jafri’s “written refusal” to assent.

But the email, which is part of the court record, says no such thing. In it, Jafri responds to Riddel’s request for her “signature block” — a piece of formatting information he could have obtained from any of the thousands of court filings she had made on behalf of the firm. Jafri’s email addresses an entirely different subject: the firm’s failure to respond to her requests for waivers of service in the federal lawsuit she had filed. Nowhere in the email does Jafri refuse to assent to any substitution of counsel. Nowhere does she even address the subject.

To characterize this email as a “written refusal” to assent is, at best, a misreading so strained as to be unreasonable. At worst, it is another false statement to a tribunal — this time made in a reply brief, after the issue of candor had already been raised.

The Federal Lawsuit

The substitution disputes are, in fact, a sideshow to a larger conflict. In April 2026, Jafri filed a civil action in the United States District Court for the Eastern District of New York: Jafri v. Arnold & Smith Law, PLLC et al., Case No. 1:26-cv-02320. The complaint names the firm and individual defendants, including Love herself.

The federal lawsuit adds another dimension to the ethical analysis. Love and other defendants in that action have, according to Jafri, refused to respond to requests for waiver of service under Federal Rule of Civil Procedure 4(d) — while simultaneously communicating with Jafri about other matters when it suited the firm’s interests. Federal courts have recognized that selectively engaging with an opposing party while ignoring service-related communications can constitute bad faith. Under Rule 4(d)(2), the court may impose on each defendant the costs subsequently incurred in effecting formal service, including reasonable attorney’s fees, unless good cause is shown for the failure to waive.

The parallel proceedings create an unusual dynamic: Love is filing motions in Massachusetts state courts representing that Jafri has been “notified” and has “refused” to assent, while simultaneously being a named defendant in a federal lawsuit by Jafri — a lawsuit Love has declined to acknowledge through the standard waiver process.

The Ethical Framework

The potential ethical violations in this matter are not trivial, and they implicate several provisions of the Massachusetts Rules of Professional Conduct.

Rule 3.3(a)(1) — Candor Toward the Tribunal. This is the most straightforward violation. An attorney who states in a court filing that prior counsel “has been notified” when no notification was ever made has, by definition, made a false statement of fact to a tribunal. If the statement was made knowingly — and it is difficult to see how an attorney could be unaware of whether she had contacted someone — the violation is clear. The fact that the false statement was made repeatedly, across multiple cases and courts, compounds the severity.

Rule 3.3(a)(3) — Failure to Correct False Evidence. When Jafri filed her limited objections identifying the false statements, Love had an obligation under Rule 3.3(a)(3) to take reasonable remedial measures if she had offered material evidence and came to know of its falsity. Instead, Love doubled down in her Reply, introducing a new mischaracterization — the alleged “written refusal” — rather than correcting the record.

Rule 8.4(c) — Misconduct Involving Dishonesty. The Rules of Professional Conduct provide that it is professional misconduct for a lawyer to engage in conduct involving dishonesty, fraud, deceit, or misrepresentation. A pattern of false statements to multiple courts could support a finding of misconduct under this broader provision.

Rule 5.1 — Responsibilities of Supervisory Lawyers. If Love filed these motions at the direction of Arnold & Smith management — and the evidence suggests the substitution campaign was a firm-wide initiative, not an independent decision by Love — then the supervising attorneys bear their own responsibility. Rule 5.1(c) provides that a lawyer is responsible for another lawyer’s violation of the rules if the supervising lawyer orders or ratifies the conduct.

The Liability Landscape

Beyond disciplinary consequences, the attorneys involved face potential civil liability on multiple fronts.

In the federal lawsuit, the claims may include wrongful termination, violations of anti-discrimination statutes, and related causes of action. The false statements made in the Massachusetts substitution proceedings could become relevant evidence in the federal case — both as evidence of the defendants’ state of mind and as potential independent acts of retaliation or harassment.

Massachusetts courts also have inherent authority to sanction attorneys who make false representations. A court that finds an attorney has made a knowing false statement in a motion may impose sanctions ranging from monetary penalties to referral to the Board of Bar Overseers for disciplinary proceedings.

The Board of Bar Overseers, Massachusetts’ attorney disciplinary authority, has jurisdiction to investigate and prosecute violations of the Rules of Professional Conduct. A complaint based on the documented false statements in these motions would present the Board with a relatively straightforward factual record: the motions state that notification was made; the evidence shows it was not.

For Love individually, the exposure is significant. Her Massachusetts BBO number — 717998 — is on every filing. Each motion containing a false statement is a separate potential violation. If the number of affected cases reaches into the dozens or hundreds, the cumulative weight of the violations becomes difficult to dismiss as inadvertent or de minimis.

For the firm and its management, the exposure may be greater still. If the false statements were made pursuant to a firm-wide policy or directive — file the substitutions, represent that prior counsel was notified, move on — then the responsibility extends up the chain of command. Supervisory attorneys who knew or should have known that the representations were false face their own disciplinary and civil liability.

The Broader Pattern

What makes this case significant beyond its specific facts is what it reveals about the intersection of high-volume litigation practice and professional responsibility. When a firm handles hundreds or thousands of cases and an attorney departs, the pressure to transition those files quickly can overwhelm the procedural safeguards that the rules of professional conduct are designed to enforce. The temptation to cut corners — to file motions representing that notifications were made when they were not, to assert facts about a departing attorney’s employment status without verification — is greatest precisely in the environments where the consequences of such shortcuts are most likely to be overlooked.

District courts handling consumer debt cases are busy. Judges have crowded dockets. A motion to substitute counsel, filed with a certificate of service, is unlikely to draw scrutiny unless someone objects. The system works on trust — trust that the attorneys who appear before the court are telling the truth. When that trust is violated, the damage extends beyond the individual case. It corrodes the very mechanism by which courts function.

Jafri’s decision to file limited objections — not to oppose the substitutions themselves, but to correct the record — is, in a sense, an act of institutional maintenance. The objections serve notice that the rules apply even in the high-volume, low-visibility corners of the justice system where they are most easily ignored. Whether the courts and disciplinary authorities respond with the seriousness the situation warrants remains to be seen.

What Comes Next

The federal lawsuit in the Eastern District of New York is in its early stages. Service of process has not yet been completed on all defendants — a fact that itself has become a point of contention, given the defendants’ apparent refusal to waive service. The Massachusetts substitution proceedings continue across multiple courts.

For the legal profession, the case offers a cautionary study in what can go wrong when the machinery of a large firm prioritizes efficiency over compliance — and when the attorneys tasked with executing that machinery make representations to courts without bothering to verify whether those representations are true. The rules of professional conduct do not contain an exception for inconvenience. They do not contain an exception for high-volume practice. And they do not contain an exception for attorneys who are simply doing what they were told.

The obligation of candor to the tribunal is absolute. It does not bend to the pressures of caseload management, and it does not yield to the strategic interests of a firm navigating the fallout from a contentious departure. Every motion filed in a court of law carries an implicit certification: that the statements within it are true. When they are not, the consequences — for the attorneys, the firm, and the profession — are not merely procedural. They are existential.

This article examines publicly filed court documents and communications provided by the parties. Arnold & Smith Law, PLLC and Attorney Echo Lin Love did not respond to inquiries. Farva Jafri is a practicing attorney and plaintiff in Jafri v. Arnold & Smith Law, PLLC et al., Case No. 1:26-cv-02320 (E.D.N.Y.).