Playing Paper Dolls

Oregon Attorney Megan Moeller pleads guilty to wire fraud

Stephanie Volin
21 min readMay 16, 2022


Earlier this month, in US District Court, former attorney Megan Moeller (aka Megan Perry) finally pleaded guilty to one count each of wire fraud and identity theft. Her guilty plea came a week after the US Attorney filed new information with the court that more clearly outlined Moeller’s scheme to defraud, including her forgeries of an affidavit of service and a USPS mail receipt.

The charges carry maximum penalties of 20 and 15 years, respectively, as well as a potentially hefty fine. Significantly, at sentencing, the court may also consider the losses of additional victims of Moeller’s — i.e. those who were not identified in the federal criminal case.

And since wire fraud is a RICO predicate offense, it’s worth taking a closer look at Moeller’s criminal enterprise and her known victims.

The 25 bar complaints Moeller received before resigning her law license are a great place to examine both.

Briefly, Megan Perry, as she was then known, got her law license in 2013 and set up shop with her husband, Erik Moeller, and a third partner, Joseph Elwood. Her practice consisted primarily of family law matters such as divorce, custody, and adoption.

In reality, Perry specialized in ripping apart functioning families, protecting abusers, and separating children from caring parents. She did this through all possible means.

Some of her tactics were disguised as malpractice or laziness, but she was neither lazy nor inept. Perry was in fact very busy scheming, creating forged documents, conspiring with opposing counsel, manipulating court staff, and, her favorite: positioning opponents and clients alike for false arrest. She switched sides often and pushed the boundaries of how outrageous a lie she could tell and still get away with it.

Records clearly show that Perry enjoyed toying with people, and making up absurd yet simpleminded narratives to keep her victims rapt and trapped. She was like a small, sadistic child playing with her dolls — a child who also happened to have a bar license.

All 25 bar complaints that Perry received are briefly summarized below, in the order they were filed. As you read them, decide for yourself at what point her licensor, the Oregon State Bar, could have or should have stopped Megan Perry and reported her to law enforcement.

Michael Bodi (1/4/2015)

The first complaint the Bar received about Megan Perry was almost a blueprint of the case for which she would be federally prosecuted five years later, notably her false claims about filing and service, and increasingly implausible stories for failing to act on her client’s behalf. Virtually the only difference was that Perry didn’t forge any documents to soothe Bodi as her excuses began to fall apart.

However, Perry did settle Bodi’s case without his knowledge. Bodi only learned about it when he read an email from his ex’s lawyer, who asked Perry, “does your client not realize that this case was settled and it is over?”

After Bodi fired her, Perry dragged her feet before sending his file to her successor. It was heavily sanitized, and missing all communications between her and opposing counsel, suggesting additional misconduct.

The Bar dismissed Bodi’s well-evidenced complaint after a year and a half investigation — during which time four more bar complaints against her had rolled in.

In their dismissal, the Bar chided the victim, concluding “That Ms. Perry… proceeded in a manner which you now find objectionable does not mean that she neglected a legal matter entrusted to her, provided incompetent representation, or violated any other ethical obligation to you.”

Bodi told me, “I wish that the Bar had taken my complaint seriously in 2015. We investigated and documented everything, submitting dates, times, events to the Bar. They had little to do but validate and disbar her. All this grief could have been prevented.”

Paul Neuman (2/18/15)

Neuman credibly claimed that Perry had allowed her client (Neuman’s ex-wife) to contradict testimony and perjure herself during a hearing for a restraining order against him, greatly affecting his parental rights. Their divorce was very contentious.

His complaint was difficult to understand, but the Bar, to its credit, did try to bridge the communication gap. It asked for additional information and evidence from Neuman, which he apparently did not provide. The complaint was then closed a month later, without the Bar contacting Perry or Neuman’s own lawyer.

A few years ago, I spoke with Neuman at length about proofs of service that were missing from the court’s records, and documents in his case file from March 2015 that appeared to be fraudulent.

It is now known that early 2015 was a time period during which several other fraudulent documents created by Perry appeared in other victims’ case files.

Gavin McNett (5/4/15)

Disclosure: I’m a witness to this complaint. It credibly alleged that Perry had forged a restraining order on behalf of her client, McNett’s ex-wife. The March 2015 order was “signed” by Judge Norm Hill and entered into the docket by a court employee, Heidi Bittick, who has since been fired for dishonesty.

McNett listed the dozens of ways in which the restraining order was impossible, especially the fact that there was no record of a hearing. All the Bar needed to do was contact Judge Hill — the victim of identity theft — to authenticate the order. Judges are asked and required to do such authentication regularly.

Instead, the Bar allowed Perry, Bittick, and an undisclosed OJD employee to vouch for the order, then dismissed the complaint three months later, stating that “Without some other evidence to suggest misconduct by Ms. Perry, we did not find it necessary to contact Judge Hill’s office.”

At a hearing in fall 2020, when asked to authenticate the order, Judge Hill refused to do so, effectively verifying that the order is forged. Worse, Judge Hill — the apparently unbothered victim of identity theft — bizarrely asked McNett why he still cared about a forged order that had already been vacated, so many years after the fact.

McNett told me, “It’s astonishing that a sitting judge would be so cavalier about the theft of his own identity and the misappropriation of his judicial authority — especially when he knew how much terrible, ongoing harm it’s still causing to Perry and Bittick’s other victims in his court. Judge Hill cares about something in this case more than he cares about right and wrong.”

Jonathon Cannon (7/1/15)

Perry and her husband, partner Erik Moeller, lied about having not received important papers from a mediator, which harmed Cannon’s case. Cannon discovered their lie when he called the mediator directly—the papers had been timely sent by the mediator to the firm weeks earlier.

Cannon’s complaint is notable for his aside that a representative of the Bar discouraged him from filing a complaint. That staffer warned him that “there is a good chance [your] lawyer will quit representing [you]” if a complaint is filed.

It is terrible advice to tell someone to stick with their lying abuser, but it is particularly awful in the context of a lawyer/client relationship.

Many of her victims stayed with Perry for far longer than their guts recommended due to the money which they had already “invested” in Perry’s legal work, and the prohibitive cost of starting over with a new attorney.

Many of Perry’s clients were referred to her through the Bar’s income-based “Modest Means” program. Remarkably, those referrals by the Bar continued even as more complaints against her arrived there.

More importantly, Cannon was one of nine victims who expressly named Erik Moeller in his complaint. Despite this, the Bar never opened a file on Erik Moeller. Erik is currently a state-paid public defense attorney in Linn County, drawing a substantial paycheck.

The Bar dismissed Cannon’s complaint after five months, stating that there were insufficient facts “to support a charge of dishonesty or misrepresentation.”

Casey Choate (4/15/16)

Perry represented a client who was the custodian of Choate’s four children, due to Choate having a terminal illness and struggling with addiction. One of her children had also won a $1 million settlement and required a conservatorship, which is likely why Perry was involved.

The complaint is difficult to understand, but Perry had been denying or blocking Choate’s “reasonable contact” with her own children that she was allowed by court order. Choate stated, “[Perry] has been extremely aggressive toward me and has blatantly lied to me on several occasions with her claims about needing confirmation from the DA before letting me see my kids, getting hair follicle samples to prove I’m not using.”

Perry seemed to be positioning Choate for arrest, since she wouldn’t just die already, as had been long expected.

Despite her documentation of her contacts with Perry’s office, the Bar dismissed Choate’s complaint less than two months later, concluding that “Ms. Perry’s duty is to represent the interests of her client and those interests are adverse to yours. You believe that she is acting in a manner that is too aggressive, however, we cannot reach that same conclusion and cannot find that she has engaged in unethical misconduct.”

Roger Lamont (10/7/16)

Perry represented Lamont in his divorce, and withheld from him some of the financial documents that his ex-wife had turned over. Further, Perry refused to return his “complete client file” after he let her go. A client file is a client’s own property.

To avoid returning the file, Perry fed Lamont increasingly laughable excuses, such as her “printer ran out of ink” or she “put [the file] in a mailbox out by the porch.” Even after the Bar started assisting Lamont, Perry continued to jerk him around.

Because of her evasiveness, the Bar advanced the complaint to the Disciplinary Counsel’s Office in November 2016. Perry responded to the allegations with a victim-blaming letter that suggested additional misconduct.

Lamont’s complaint then sat, unattended to, for nearly an entire year. It was only dusted off when Perry began receiving bar complaints at the rate of one per week.

Jeffrey Goodwin (12/13/16)

Goodwin was the opposing attorney in a custody dispute that Perry’s client largely won. However, the judge “had imposed an immediate financial obligation on Ms. Perry’s client in favor of” Goodwin’s client. Perry was directed to submit the judgment to the court within 30 days, but “months passed” without her doing so. Perry did not serve Goodwin a copy before it was signed, and it was not consistent with the oral ruling. He objected to no avail, and the judgment was never corrected.

Goodwin also represented a second client in a separate case in which Perry had acted similarly, and he was “concerned about the repeated pattern of unacceptable delay” and refusal “to communicate with opposing counsel when it does not suit her purposes.”

Despite being elevated to the Disciplinary Counsel’s Office, Goodwin’s sincerely-filed complaint was dismissed a half year later — just a week before the avalanche of bar complaints filed against Perry started to rain down on the Bar.

Goodwin’s was also the last complaint against Perry that the Bar dismissed.

Lori Reid (12/14/16)

Perry represented Reid in a divorce, and botched how and when alimony would be paid, specifically that the DOJ would be handling it. In fact, the DOJ “didn’t support alimony payments” in Linn County.

As a purported family law practitioner in Linn, Perry should have known that.

Ryan Klock (1/28/17)

Klock was represented by Perry in a custody dispute that was mostly settled out of court with all parties present. However, shortly thereafter, Klock received a text from his ex-wife saying that she had “won full custody and everything she [had] asked for in court.”

Understandably, Klock was stunned and asked Perry to confirm it. Perry told him that the court judgment that she had failed to disclose to him was “fixable,” and that she would “do everything in her power to modify” the ruling. Perry then strung Klock along for over a year and a half, while he waited “for this so-called modification… supposedly submitted” by Perry. Klock’s second wife finally “got suspicious and called the court” directly, only to learn that Perry had never submitted anything to the court.

In his complaint, Klock stated that he felt “conned, lied to, and most of [all] robbed.” Perry’s deceit “ruined [his] relationship with” his children.

Elizabeth Laver-Holencik (5/12/17)

Laver-Holencik hired Perry for her divorce after Perry’s partner, Joe Elwood, apparently botched it. Perry exacerbated the situation in ways that are not easily summarized, but are collectively appalling.

When the dust on the divorce finally settled, “the judge determined that Megan could not be trusted with another [settlement] check,” since a prior check for $50,000 that Perry had handled had gone missing.

Laver-Holencik told me, “I’m glad she is being prosecuted. My divorce was horrible and Megan made it so much worse and cost me a lot of money.”

It was at this time that a new swell of complaints against Perry began to roll into the Bar, all of which credibly alleged at least one of her signature moves: misrepresentation, failure to act, ridiculous excuses, refusal to return client property, custodial interference, forgery, and aggressive attempts to get clients and opponents alike arrested.

Kennya Marzano (6/16/17)

Marzano was a victim in the state’s criminal case against Perry filed in 2019. That case was dismissed because of Perry’s federal indictment, yet the custodial interference charges brought against her — related to her “work” in Marzano’s custody matter — were never added to the federal charges.

Perry toyed with Marzano for a year, and in January 2017, told Marzano “to keep the children” after her non-custodial weekend, “because the [custody] paperwork went through.” That was false. Perry also falsely claimed to have spoken to Washington and Linn County police on Marzano’s behalf.

Marzano did what Perry, her lawyer, told her to do and “three days later police showed up at my door to remove the kids. [The police] knew nothing about me having custody. The same thing happened in March 2017, [Perry] swore up and down that everything was secure and I had nothing to worry about. The police came to remove my children again.”

Marzano included screenshots of texts she exchanged with Perry, which showed the depths — and widths and lengths — of Perry’s deceit, and its traumatizing effects on her family. The texts are collectively disturbing.

Texts exchanged between Megan Perry (left) and Kennya Marzano.

Jeffrey Hart (7/24/2017)

Perry was hired to draft and file a divorce judgment that the Harts had already amicably worked out. Remarkably, Perry drafted the document, but then failed to file it with the court.

Instead, Perry invented a fictitious case number for the matter, signed the document “/S/ Judge David Delsman,” presented it to the Harts as a “conformed” copy of their judgment, congratulated them, and sent them on their way.

The forged judgment was then filed with the agency that handles support, which “began collecting spousal and child support from [Mr. Hart’s] pay.”

But far more disturbing than that, Ms. Hart got remarried while still married to Mr. Hart, and they only discovered the forgery when he tried to stop spousal support.

Outrageously, in its own summary of the complaint, the Bar wouldn’t refer to the forgery as a forgery, and breezed past that clearest sign that it was a forgery: Perry’s personally handwritten and wholly-invented case number.

Now-retired Judge Delsman and Linn County Circuit Court were frequent “victims” of Perry’s.

Kandee Cooper (9/1/2017)

This case is not easily summarized. Perry misrepresented her actions to her client, Cooper, who discovered it only when she started calling third parties directly, such as the IRS and district attorney. Perry may have also stolen or converted $51,000.

Notably, Cooper stated that “After three years of being patted on the head and lied to… the legal secretary recommended I transfer to Daniel Miller,” a new partner who had joined Perry and Moeller’s firm. Cooper did transfer to Miller — and then Perry refused to give her partner the client file.

Kandee Cooper’s handwritten plea to the Oregon State Bar.

Michael Crocker (9/6/2017)

Perry failed to file documents regarding Crocker’s mother’s estate, but repeatedly insisted that she had. Perry may have also stolen tens of thousands of dollars from Crocker.

Crocker summarized Perry’s habitual lying: “I kept asking her for copies of the paper trail that I know court cases generate. I was always told the papers would be made available to me but all I got were emails with no attachments. Every time I requested documents in person in the office, I was told there was a problem printing them or they would get them printed up for me, or some other excuse why they couldn’t be handed to me at the time, but it never happened.”

He continued, “I don’t know how Megan handles other cases or clients. I do know she simply did not handle my case in an acceptable manner and then she lied to me about it.”

Tjoseph Chapman (9/25/2017)

In this case, Perry so completely misrepresented her actions to Chapman — a frequently-deployed Chief Petty Officer — that police came to his house while he was at sea, and scooped up his three children. Police showed his second wife the court order granting his ex-wife temporary custody, and threatened her with arrest.

Remarkably, Perry fast-talked her way out of that, and Chapman stuck with her long enough for Perry to hastily forge a custody evaluation report supposedly “written” by a custody evaluator who had been hired.

If you only have time to read one document linked in this article, make it the Bar’s summary of Chapman’s case which included Perry’s terse response.

It was at this time — right after Chapman’s complaint rolled into the Bar — that Perry was finally forced into inactive status by her licensor and mandatory malpractice insurer, the Oregon State Bar. It was also at this time that complaints started arriving to the Bar at the rate of one per week.

Clinton Bateman (10/4/2017)

Perry was hired to file an adoption petition for Bateman and his step-child. Perry strung him along for a year, doing nothing on the case, before finally filing a petition. Perry told Bateman that he had been granted a judgment for custody, and a new birth certificate had been issued.

In reality, the court had issued a notice to dismiss the matter for inaction.

Perry continued to misinform Bateman and insisted that the documents were in her office waiting to be picked up. After months of evasion, Bateman finally confronted Erik Moeller, who was left holding the bag as his wife’s “practice” imploded. Moeller curtly told Bateman that he would not be able to help.

Kaylee Knapp (10/12/2017)

This was yet another case in which Perry had misrepresented to a client that she was divorced and had full custody of her child, when in fact the case had been dismissed for inaction.

Perry does not appear to have created any forgeries for this client, but did draft a “nomination of guardianship” in an effort to mollify her client, who seems to have been intent on blocking her ex’s access to their child.

Email from Knapp to Perry.

Gavin McNett (10/18/2017)

This was the second complaint filed by McNett, which reported Perry for witness- and evidence-tampering, interfering with his subpoenas, withholding discovery, and positioning him for false arrest.

Perry had already been sanctioned by the court for her tampering, and had been under a $100/day court fine for the discovery that she had been withholding. None of those things deterred her misconduct, however. Perry falsely claimed to the court that she had sent her own subpoenas “to all area health care providers” to prove that her client was not concealing the minor’s medical records, as McNett alleged. Perry never provided McNett or his attorney with copies of the alleged subpoenas or their proofs of service.

Remarkably, at trial, now-former Polk Judge Sally Avera “permitted Perry to claim attorney-client privilege” and ruled that the subpoenas constituted “work product.” Judge Avera also bizarrely stated that “the subpoenas are not about [the minor],” which implied that Judge Avera had viewed them.

McNett also brought up the forged restraining order that the Bar had ignored back in 2015, and reiterated that court employee Bittick continued to block his attempts to authenticate the order.

McNett stated, “Because of Perry’s… misconduct and violations of Oregon law, this case’s proceedings have been subverted for nearly three years with terrible harm inflicted on my son and his family, at crushing financial expense. Megan Perry is a danger to her opponents, her clients, and the public at large.”

Christopher Knapp (10/27/2017)

Knapp was the ex-husband of Kaylee Knapp, who filed a complaint against Perry just fifteen days earlier. Mr. Knapp alleged that his ex was working in concert with Perry to deprive him of his parental rights.

Astonishingly, the Bar tabled Mr. Knapp’s complaint by stating, “Your wife has already notified us about concerns regarding Ms. Perry’s representation in the legal matters between you, and we have referred those concerns to Disciplinary Counsel for further investigation. The information you provided does not support the need to open a second investigation regarding the legal matter between you.”

It should have been evident to the Bar that Mr. Knapp’s complaint was diametrically opposed to his ex-wife’s, and should not have been set aside.

It was around this time that Perry retained the services of attorneys from the firm of Holland & Knight, to defend her against the mountain of bar complaints.

Scott Stewart (11/3/2017)

This is the complaint upon which the federal charges that Perry pleaded guilty to are based. Perry jerked the Stewarts around for several months, and repeatedly claimed that she had served their opponent papers in Florida. When their opponent, Stewart’s ex-wife, claimed otherwise, Perry called the woman “crazy” and a “liar.”

The Stewart’s previously well-functioning custody situation quickly deteriorated, as Perry assiduously stirred the pot.

To sustain her lies just a bit longer and shift suspicion away from herself, Perry forged an affidavit of service and a USPS receipt — in total, three forged signatures.

It did not buy her much time. The Stewarts provided those documents to the Bar, and they were quickly shown to be fraudulent, simply by consulting a map: The process server and notary whose signatures Perry had chosen to forge were not licensed to practice in the Florida county where the ex-wife was allegedly served; and in fact, they would have had to drive over 6 hours round trip to do so, while risking their professional licenses.

The Stewart’s complaint specifically called out misconduct by Erik Moeller, which the Bar failed to investigate, and which demonstrated that he was certainly involved in this particular scheme.

Cary Bingham (11/7/2017)

Perry represented Bingham in a case in which his ex-wife refused to allow visitation with their son, despite Bingham having a court order from North Dakota that permitted it. The ex-wife was clearly determined to cut Bingham completely out of his son’s life.

Perry falsely claimed that she had successfully registered Bingham’s ND judgment in Oregon. She further claimed that Bingham “had been granted visitation” with his son, and promised him a copy of the judgment when he got to Oregon. Bingham flew there expecting a visit with the son he had been prevented from seeing for years.

Which is to say, Perry positioned her vulnerable client and his court-order-defying ex for a major confrontation which would have certainly involved police. Bingham wisely avoided it, but returned home dejected.

It is a common thread in Perry’s cases that she sided with the mother intent on cutting off the father’s rights, no matter which parent was her actual client.

Bingham told me, “I’m glad Ms. Perry is facing consequences for her actions but it will never replace the time that was lost with my son, or the permanent damage to my relationship with him. I hope she understands the destruction of family and suffering she caused, but I doubt she’s capable.”

Barbara Schneider (11/8/2017)

This complainant alleged that Perry had completely botched her divorce and repeatedly lied about it, costing her nearly everything. In her response to the Bar, Perry would not even provide a copy of their retainer agreement.

Schneider’s daughter, Wendy Bernards, who submitted the complaint for her mother, told me, “Megan did not fill out paperwork correctly and my mom lost everything. She almost lost her husband’s social security but we hired another attorney to fix that. This was a painful, expensive deceitful way to treat people. We took our case to a [malpractice] attorney in Salem to look it over but he said our case wasn’t big enough for him. He had other cases of Megan’s that were worse than ours. I think she deserves what happens.”

Christen Salinas (1/23/2018)

This client hired Perry for a child custody and parenting time modification, which she then badly botched. Salinas was left in a worse position than before.

For unknown reasons, this was the only complaint that the Bar received during the avalanche which was not immediately elevated to the Disciplinary Counsel’s Office. As such, Salinas was not a named victim on Perry’s resignation paperwork, filed five weeks later. It should be of little consolation to Salinas that being named on Perry’s resignation paperwork was about as valuable as confederate money.

Rebecca Winters (1/25/2018)

The final complaint came from attorney Winters, who was required under the Rules of Professional Conduct to report Perry’s behavior, after she was involved in a case with her.

According to Winters, “Perry abandoned her client,” leaving people “in a very precarious situation.” She further stated, “I do not know Ms. Perry, but I am very concerned about the effect Ms. Perry’s actions have had not only in this case, but in other cases in Albany and Corvallis. I believe she has done a lot of damage to the profession and to her clients.”

Winters told me, “I have not followed the criminal case against Ms. Perry nor do I personally know her, however I would state that ongoing unethical conduct should be acted upon as soon as it is known. It would have been so much better if something were done sooner to stop her from practicing law from the time of the earliest reports. Not only were her clients wronged, but Ms. Perry wronged the profession of law itself.”

She continued, “I don’t know enough about this case to comment on whether things could have been done sooner to stop Ms. Perry earlier in time. It is difficult to understand how someone who went to the trouble to go to law school, earn a law degree and pass the bar and presumably a professional responsibility exam, could have decided to throw it all away by being deceitful. It is a very disturbing situation that needs careful review.”

Bob McCann and Andy Ivers (2/15/2018)

This was a warning, not a complaint, and was sent by the two Albany attorneys directly to the Bar’s Deputy General Counsel, Mark Johnson Roberts. Ivers had hired two of Perry & Moeller’s former associates who possessed “notebooks of information as well as eyewitness accounts of the unethical conduct of Ms. Perry and Mr. Moeller and the efforts that have made to hide their behavior.”

McCann and Ivers’ warning stated that, “Much of the documentation… was copied from documents which were later destroyed by Perry and Moeller.”

They referred to the information as “voluminous and damning,” and concluded, “Frankly, Ms. Perry and Mr. Moeller have engaged in some of the most reprehensible and unethical conduct I have heard of. From the local bar’s perspective nothing is coming of it. I hope the perception of the local attorneys is not correct.”

According to a source familiar with the matter, Johnson Roberts told the lawyers that their whistleblowing report was irrelevant because the Bar already had enough evidence to disbar Perry. Yet, the Bar still did not open an investigation into Erik Moeller.

That was an unreasonable display of priorities by a regulatory officer who had been alerted to possible criminal behavior. It was, however, the type of response that Johnson Roberts as the Oregon State Bar’s own attorney — would habitually make to protect the agency against victims of criminal misconduct by its licensees, and against victims of the Bar’s own negligence and bad faith.

Two weeks after her former colleagues sent up that warning flare, Megan Perry resigned her law license, effectively disbarring herself and ending the Oregon State Bar’s authority to investigate her. The Bar immediately put its pencils down as it waited for her resignation to be approved, and deliberately ignored the agency’s mandatory duty to report all crimes discovered during its investigation.

Bar staff then interfered with victims’ reports to law enforcement, and retaliated against victims who had discovered each other and were comparing notes.

For good measure, the Bar didn’t issue any press release about Perry, and even delayed publishing a notice of her resignation for nearly five months. On average, notices are published after only two.

In 2018, I requested the Bar’s “complete file” on Perry, which should have included all records of their investigation and all of Perry’s responses. What I received was far less than complete: Notably, it was missing all of the exhibits that Perry and her Holland & Knight lawyers had submitted in her defense.

More significantly, it was missing the records and notes of phone conversations between the Bar and the Stewarts — the victims in Perry’s federal criminal case. Such phone records had been included in other cases, like the Hart’s. Therefore, it appears that Bar intentionally removed those records from the Stewarts’ file.

The Bar had sanitized its own records, just as Perry had done.

Now that most of the dust has settled on Megan Perry’s criminal enterprise, I am left to consider at what point the Bar should have known that she posed a significant danger to the public. In my estimation, the answer is in mid- or late-2016. It should not have taken until October 2017 for Perry to be forced into inactive status — as fifteen more victims of her reprehensible and unethical conduct were allowed to pile up.

I encourage review of all of the source material linked in this article and ask people to decide for themselves. There’s a pattern evident in these cases that deserves to be explored in a piece of its own in the near future.