Final Expense Direct vs Python Leads - snakes eating snakes, a deep dive
- Peter Schneider
- Dec 6
- 9 min read
Updated: Dec 7
I am always fascinated when lead generators and telemarketers eat each other in court, so I recently checked in to see how the whole Final Expense Direct vs Python Leads case was shaping up.
As usual I start with the background. All the "facts" in this article are taken from the court filings, I have no personal knowledge of the truth of any of this. Please remember that all "facts" in the pleadings are taken as true prior to findings of the court. I will post a number of the court documents and I'll speak to several different aspects of the litigation but there are many, many more filings (I did not try to read them all) I won't post and it is quite possible that some of the "facts" are refuted in these other filings.
The Players:
Player #1 - Ali Raza. An independent contractor who at times held himself out as an independent contractor, and at other times held himself out as co-founder of Python.
Player #2 - Jacquelyn Levin / David Levin. The actual owners of Python
Player #3 - Luis Beauchamp. Final Expense's VP of Marketing.
The Beef:
Final Expense sells life insurance policies and a major player in this litigation Ali Raza reached out to them offering to transfer them live Leads via Python. The crux of this litigation is who was responsible for bad leads. The March 2021 (proposed?) written contract said Python was responsible for the TCPA compliance of the leads. And while the parties dispute if the written contract is binding, Ms. Levin apparently ratified elements of the contract saying they would take responsibility for bad leads.
Ms. Levin stating in email that “[Python] will always take responsibility in protecting you against these professional scammers”) [in telemarketing parlance TCPA plaintiffs are the scammers and the telemarketers who manufacture fake consents are the good guys] . . . Ms. Levin stating in email that “[Python] will contact him and get this resolved for you” after Plaintiff contacted Ms. Levin concerning another complainant represented by an attorney . . . (Mr. Raza explaining in email that “we are scrubbing out data against TCPA and DNC litigator list . . . [y]ou guys are completely harmless”).
And bad leads there were.
As time went on, [Final Expense Direct] received a significant number of complaints alleging TCPA violations. Python ostensibly handled them while acknowledging its responsibility to do so until June 2022 . . . In June 2022, [Final Expense Direct] began receiving lawsuits against it for alleged TCPA violations . . . Ultimately, [Final Expense Direct] allegedly paid over $100,000 to settle the claims against it and ended its business relationship with Python.
Python sold Final Expense bad leads, stopped indemnifying Final Expense, and Final Expense went after Python with a seven court complaint. Python moved to dismiss some of the counts and was denied.
Python Strikes Back:
In a bold move of hutzpah, Python answered the complaint with a counterclaim for "an award of damages in excess of $3,400, plus attorneys fees, interests and costs. Python felt they should be paid more for their bad leads and that the lawsuit had caused them reputational harm. Final Expense was able to get much of the counterclaim dismissed.
Because Defendants agree that they have no entitlement to attorneys fees, the only issue to consider is whether it would be appropriate to dismiss or strike Defendants request for damages related to reputational harm and loss of customers . . . Here, Defendants counterclaims allege no facts which even suggest that Python may have suffered reputational harm or a loss of customers from Plaintiffs alleged failure to make full payment under the subject contract . . . It follows that the damages have no apparent relationship with Defendants counterclaims. They may be stricken.
And Python Swings Again:
Final Expense recorded several phone calls with the Levin's without their knowledge contrary to Florida law. Mr. and Ms. Levin moved to strike use of the recordings as they were captured in violation of Florida Statutes section 934.03, the Florida Security of Communications Act. It was granted.
Python started fighting discovery:
Python started refusing to participate in discovery, got hit with a motion to compel, and blew that off. The court hit them with attorney fees.
And the court hit them again with another order to produce documents.
Where are we now?
In September of 2025 Final Expense moved for partial summary judgment. There are a lot of claims. In looking at the motion and the Response, I predict Final Expense wins on the breach of contract claim and the motion foreshadows more problems for Python:
On December 29, 2021, and January 5, 2022, Python called another member of the National DNC, Robert Doane (“Mr. Doane”), while he was listed on the DNC. Python did not indemnify Final Expense for Mr. Doane’s TCPA and DNC claims. On February 15, 2022, Mr. Raza sent an e-mail to Final Expense, providing an alleged Jornaya ID for Mr. Doane to demonstrate that Python received consent from Mr. Doane to contact him. However, Final Expense reviewed the Jornaya ID with its Director of IT Support, Chris Dauge, who confirmed that the Jornaya ID did not have an associated IP address. Consequently, Python did not obtain consent to contact Mr. Doane. Python also failed to hold Final Expense harmless for this violation, which resulted in Final Expense settling Mr. Doane’s TCPA and DNC claims personally for $18,500 and paying accompanying attorneys’ fees.
It doesn't take a tremendous amount to defeat a motion for summary judgment, so it is a closer call, particularly if there was an amendment to the March 2021 agreement providing that Python would pick up the tab on TCPA violations, but Ms. Levin's emails stating the same should put them over the top.
Mr. Raza is trying to duck liability by pinning it all on Python. This brings up a good point about parties and jurisdiction. A few weeks back a potential client consulted with me about a case with two potential defendants. California had jurisdiction over Defendants 1 & 2, while Washington State only had jurisdiction over Defendant 2. I don't practice in California.
The potential client requested that I represent him in a lawsuit against Defendant 2 in a Washington court but I declined the case because I know that Defendant 2 will blame everything on Defendant 1. I would want both these defendants in one lawsuit where they can point fingers at each in the same lawsuit other like Mr. Raza and Python are doing here so they can't get away with scapegoating each other.
Python Blew Off Requests for Admission
Defendant Ali Raza served RFAs on Python who blew them off too.
Python later came back asking the court to set aside the deemed admissions, which is yet to be ruled on. I don't know if Final Expense's attorneys are good or not, but keep a few things in mind as you read this document and then you read the Done lawsuit below.
In this motion to set aside the deemed admissions (and in Python/Levin Response to Final Expense's motion for summary judgment, Python's story is that Ali Raza was some sort of loose cannon falsely representing himself as co-founder of Python.
Admit that Ali Raza was never an officer, director, or legal signatory for Python Leads LLC.
RESPONSE: Admit in part. Denied in part. While Mr. Raza did not have the authority of an officer, director or legal signatory, he held himself out to be such an authority beyond the scope of permissions granted to him.
This case could well turn on if Mr. Raza had the apparent authority to bind Python to an agreement and the facts of a YouTube video turned up by Mr. Doan could have helped cement Final Expense's case, but for what ever reason Final Expense didn't use the video.
The Foreshadowing
Mr. Doan must be laughing all the way to the bank, first with the $18,500 from Final Expense, and now in a Massachusetts civil suit against Python and the Jacquelyn Levin personally, loaded with facts directly pulled from this lawsuit into his. Jacquelyn Levin moved to dismiss herself from the Massachusetts lawsuit but what could she do with a litany of bad facts. Pulled from Doane v. Python, 2025 WL 3485569 (D. Mass. Dec. 4, 2025):
Plaintiff Robert Doane brings this lawsuit against defendants Python Leads, LLC, and its cofounders, Jacquelyn Levine and Ali Raza, alleging that Python repeatedly made unsolicited calls to his cellphone, even though it is listed on the state and federal do-not-call registries . . . Specific jurisdiction exists over Levine, given her oversight and control of Python’s call centers that targeted Massachusetts residents like Doane . . . Doane has also established his standing to sue and has plausibly alleged that Levine violated state and federal law through her role in the purported telemarketing scheme. Python is a limited liability company based in Florida that owns and operates call centers in Pakistan. Levine, who lives in Florida, is Python’s founder, Chief Executive Officer, and sole member. Raza is a resident of Pakistan who serves as Python’s cofounder and Managing Director. Together, the three defendants allegedly engaged in a telemarketing scheme to generate Medicare and final expense insurance leads for their customers by using Python’s call centers in Pakistan, and then by manufacturing evidence that the call recipients actually consented to their calls. Levine initially partnered with Raza in 2019 to make unsolicited telemarketing calls from Pakistan. Among other activities, Levine allegedly “wrote the scripts used by Python’s telemarketers, set up Python’s call centers in Pakistan, [and] personally trained Python’s Pakistan based telemarketers.” Raza, in turn, helped Levine devise and implement Python’s telemarketing practices. At their direction, Python placed millions of calls to American consumers, including consumers in Massachusetts, by using “caller-id spoofing (a process that displaces the actual caller identification with a fake local caller identification), robocalls, and prerecorded messages.” In considering a motion to dismiss under Rule 12(b)(2), the Court may use one of three methods to assess whether Doane has met his burden to establish personal jurisdiction: the prima facie method, the preponderance method, or the likelihood method . . . Doane has proffered evidence that, using call centers in Pakistan, the defendants repeatedly made unsolicited telemarketing calls on FED’s behalf to Massachusetts residents. Between March 2021 and March 2023, Python live transferred 198 calls with Massachusetts consumers to FED. Doane also allegedly received 23 calls from Python between December 2021 and January 2022 alone, even though his cellphone number was listed on the FTC’s do-not-call list and Massachusetts’ do-not-call registry. Taken together, Doane’s evidence and allegations suggests that the defendants intentionally, not just negligently or sporadically, targeted Massachusetts residents and—at least with respect to Doane—inflicted injury in the Commonwealth. In its answer, Python notably concedes the exercise of personal jurisdiction over it. And the record evidence, in any event, reveals that Levine controlled Python’s call center operations in Pakistan. On a podcast with Raza in October 2022, Levine stated that she and Raza “started Python Leads together about 2 years ago” to enter “the Medicare field” with the goal of becoming “the biggest lead company in Pakistan” and “in the top 10 of lead companies in the U.S.”; that Python is “American-based and Islamabad-based” with “call centers in Pakistan”; that she “oversee[s] everything from [its] Florida and Texas offices”; and that she interviews its callers in Pakistan and talks to them “all day long, almost every single day.” Raza similarly stated, in a May 2021 email, that Levine “is the owner of this Call Center” who “was smart enough to create her own call center so she doesn’t have to rely on anyone for her leads where she can control the quality, Volume and budget.” Levine is identified as Python’s Chief Executive Officer in its Articles of Organization and in its 2021, 2022, 2023, and 2024 annual reports filed with the Florida Secretary of State. At this stage, Doane’s proffered evidence is sufficient to bring Levine within the scope of Section 3(c) of the long-arm statute. The record adequately supports Doane’s position that Levine personally participated in, and benefited from, Python’s call centers that targeted Massachusetts consumers like Doane. And the long-arm statute’s causation standard is met here: Levine’s conduct, including allegedly developing Python’s call scripts, started a “train of events” that led Python’s callers to repeatedly contact Doane without his permission and cause him harm in Massachusetts.
This could not happen to a nicer set of defendants and I'll post the conclusion or an update as I become aware of new filings in the case.
Got a Case Like This?
If you’ve encountered similar issues with telemarketers, debt collectors, or bankruptcy-related harassment, we might feature your story in a future blog post. Email your situation or legal filing to peter@nwdebtresolution.com or nathen@nwdebtresolution.com.
Are telemarketers or debt collectors bothering you in Washington or Oregon? I handle debt and TCPA lawsuits in Washington State and Oregon and may be able to help.
📞 Call: 206-800-6000 / 971-800-6000
📧 Email: peter@nwdebtresolution.com
Note: The opinions in this blog are mine (Peter Schneider) and do not constitute legal advice. If you're considering suing over illegal robocalls or Do Not Call list violations, contact me for a legal consultation.
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