Pro Bono Rank Firm
(Am Law 200 Rank)
Am Law
Pro Bono Score
Average Pro Bono
Hours Per Lawyer
% of Lawyers
With More Than 20 Hours
Bryan Cave (58)


David Zetoony was driving to work in June 2008 when he heard a radio news report on fraudulent immigration consultants. These consultants, known as “notarios,” often bill themselves as lawyers and promise to help immigrants obtain legal status in the United States. Many of the cases they handle go wrong, with missed filings and The Am Law Pro Bono 100shoddy paperwork sometimes resulting in deportation orders for their clients.

“The general consensus among immigration attorneys was that this was a hopelessly recurring problem and there was little to be done,” says Zetoony, an associate in Bryan Cave’s Washington, D.C., office. “But I do a lot of consumer protection work, and the first thing that occurred to me was that there are laws out there to stop fraud and deceptive practices.”

Zetoony found that past enforcement efforts had been left largely to state attorneys general, many of whom had been wary of such a politically sensitive issue. And immigration lawyers hadn’t employed the consumer protection angle; they assumed that the only recourse was to report notarios to state bar associations for an unauthorized practice of law.

In a test case filed in August 2008, Bryan Cave sued a Maryland notario on behalf of two immigrants who’d received deportation orders after the notario filed the wrong paperwork on their citizenship applications. In January a judge ruled in favor of Zetoony’s clients, awarding them $100,000 and barring the notario from immigration work for ten years for violating consumer protection statutes. The firm then filed another case in Virginia and is currently searching for one in Washington, D.C. “Our goal was to take this theory and put it into practice,” says Zetoony. “Our renewed goal is to get a good case on the books in every jurisdiction.”

To that end, Bryan Cave put together an online clearinghouse, which went live on the American Bar Association’s site in February. The project, called Fight Notario Fraud, has resources for victims and attorneys, as well as a referral network where attorneys can sign up to take cases pro bono. Bryan Cave has also petitioned the Federal Trade Commission to issue industry guidelines and take enforcement action.

“At the end of the day, deception is deception,” says Zetoony. “These notarios are doing very textbook things to deceive their consumers. With this approach we can try and stop them.”

—Francesca Heintz | July 1, 2009

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