ing a Chapter 7 Bankruptcy Filing to Keep Your Home

House and calculatorIf you are facing financial challenges, you may be considering filing for personal bankruptcy protection. If you want to keep your home, though, you may be uncertain whether you should file a Chapter 7 or a Chapter 13 petition. While a Chapter 13 is, in most instances, the best approach for restructuring your debt and keeping your residence, there are some instances in which you can use a Chapter 7 petition to protect your home.

The Exemption on the Equity in Your Home

In a Chapter 7 bankruptcy proceeding, a bankruptcy trustee is empowered to sell certain nonexempt assets in exchange for your receiving a permanent discharge of most debts. As part of your “fresh start” in bankruptcy you are allowed to keep for yourself certain assets up to permitted values. (In New Jersey bankruptcies, the federal bankruptcy exemptions are available and are almost always the ones selected by debtors). The trustee looks at a hypothetical sale to calculate what amount of money if any will be available after selling the home, paying the broker and other costs of sale, paying off any mortgages and unpaid real estate taxes, paying his own commission, and paying you the amount you have claimed as exempt. The remaining money for creditors is the “non-exempt equity”.

If there is nothing left for creditors, the trustee will “abandon” the residence by a Notice in the Bankruptcy Court. This abandonment is good for debtors. It means that the trustee is giving them back the property as being of no value to the Trustee.

This is the goal most debtors have. To achieve it, having some reliable proof of value to provide the trustee (and for you to know what the home is really worth) is essential. Just as important, however, is to have a current statement showing the balance due on each mortgage. An experienced and qualified bankruptcy attorney will know how to determine if your home is at risk and to help you protect it if a bankruptcy is needed.

In Chapter 7, another option if the home has too much value, may be to “redeem” the home by paying the trustee, from family loans, retirement funds, or other monies that the trustee has no right to. The amount the trustee will accept will be based, usually, on what would be left in a sale by the trustee.

In these situations, however, a Chapter 13 filing may be the better option. There, you can pay creditors the “equity” they would have gotten from a Chapter 7 trustee by payments over 3 to 5 years. The details of this and which is the better option are too complicated for discussion here. These are matters to take up with an experienced and qualified bankruptcy attorney.

You can still lose your home to foreclosure, even if the Chapter 7 trustee concludes he or she doesn’t want to sell it. The trustee may give up his claim to it, but the mortgage lender can still foreclosure, either after you receive a discharge or after the lender gets an order for “stay relief”. In these situations, Chapter 13 may be the better option. In Chapter 13, you can bring the mortgage current through an approved plan. An option if you want to keep your home is to obtain a personal loan or use retirement funds (which are exempt from bankruptcy) to pay the trustee the amount that would have been received in a sale of the house on the open market.

For many people who are struggling to pay their bills including their mortgage, a Chapter 7 bankruptcy can help them keep their home by freeing them from the burden of paying credit cards or other debts so that more of their available money is left to pay a mortgage.

All these considerations are heavily dependent on the facts of your individual situation. Getting early advice from a qualified and experienced bankruptcy attorney is essential. Early planning can make all the difference in the world.

Contact Our Office

At Neuner & Ventura, LLP, we work hard to alleviate the stress, anxiety and confusion that come with a potential bankruptcy filing. We offer a free initial consultation to every client. We do, however, reserve the right to charge a fee to review any work done by another attorney. For an appointment, call us at 856-596-2828 or send us an e-mail. Evening and weekend appointments are available upon request.

Representing Clients Across South and Central New Jersey



The Impact of Bankruptcy on Jointly Owned Property

Family in car lot, looking at red car.If you face a mountain of debt and have concluded that the only way you can get a fresh start is through a personal bankruptcy filing, you may concerned about the impact of a bankruptcy on jointly owned property. What if you are named on the bank account of a parent or elderly relative as a convenience to facilitate the payment of their bills? What if you had a parent or friend co-sign a loan for you?

Creditor or Trustee access to Jointly Held Property

The simple reality is that (with few exceptions) any property in which you have any ownership interest is potentially subject to being used to pay creditors in a bankruptcy proceeding, unless you can properly exempt it. The good news is that the amount of the jointly held property available to the bankruptcy court will typically be only your individual interest.

In New Jersey, money in a joint bank account is presumed to belong to each account owner in the same proportion as each contributed money to the account, unless there is clear and convincing evidence of an intent to make a gift.

A common situation we see is where an elderly parent adds a child as a joint account holder “for convenience” so the child can help manage the money or pay bills. If you are the child and can document that the money all came from the parent without an intent to make a gift, a trustee will probably leave it alone. But if you have not filed a bankruptcy, the bank account could be subject to a bank levy by one of your judgment creditors without notice. Then the account is frozen until you or your unhappy parent can go to court (weeks later) to show that the money is not yours.

We recommend against this arrangement. Parent and child should go to the bank and make arrangements for the child to have signature authority on the account under a power of attorney.

Another potentially troublesome situation arises where a parent takes title to a car that a minor child bought or is paying for using her own money. Usually this is done “for insurance purposes”. The car is still an asset of a bankruptcy estate, and is still subject to a sheriff’s levy ordered by an unpaid judgment creditor. In a bankruptcy, we have generally been able to protect the car under the theory that the car is “legally but not beneficially” owned by the parent.

These types of situations are just some of the examples that can arise. If you are facing financial difficulties, we counsel against keeping your money or assets in joint names with others. However, before transferring things around, you need to get qualified legal advice that can come from such transfers if done improperly.

Contact Our Office

Let us help you minimize the stress, anxiety and confusion that come with a personal bankruptcy filing. At Neuner & Ventura, LLP, we offer a free initial consultation to every client. We do, however, reserve the right to charge a fee to review any work done by another attorney. For an appointment, call Neuner & Ventura at 856-596-2828 or send us an e-mail. Evening and weekend appointments are available upon request.
Representing Clients across South Jersey



US Supreme Court holds that inherited IRA’s are not “retirement funds” that can be exempted in bankruptcy, but New Jersey residents may have other protections

We previously reported that the Seventh Circuit Court of Appeals held that inherited IRA’s were not protected by the Bankruptcy Code’s IRA exemption. The Supreme Court agreed, in a ruling issued June 12, 2014. Clark v Rameker. This means that debtors in bankruptcy cannot count on being able to keep such IRA’s under the federal IRA exemption, 11 USC 522(b)(3)(C). However, debtors who live in New Jersey may still be able to rely on a separate statute that removes IRA’s from a bankruptcy estate. NJSA 25:2-1(b). Because that statute has broader wording than the federal exemption statute, it may shelter inherited IRA’s. But in view of the Supreme Court’s decision, there may be some open questions here.

In Rameker, the Debtor’s mother named Mrs. Clark the beneficiary of an IRA. Under the applicable tax code sections, 26 USC 408 and 408A, the Debtor could either take the IRA funds outright, or roll them over into an “inherited IRA”. Unlike regular IRA’s, the money in these IRA’s can be taken out any time without penalty, and no additional money can be put into them. The Trustee objected to Mrs. Clark’s claim of the entire inherited IRA as exempt, and the exemption was overruled by the 7th Circuit. The Supreme Court agreed, finding that as Congress wrote the exemption, it applied only to “retirement funds”, which, it found, inherited IRA’s were not. The critical distinction was the ability to pull the funds out at any time and to use them for any purpose as well as the inability to add to the account. Funds in an inherited IRA, it found, “constitute ‘a pot of money that can be freely used for current consumption’”

Bad news outside of New Jersey. But New Jersey passed a law intended to shelter “any property held in a qualifying trust and any distributions from a qualifying trust, regardless of the distribution plan elected for the qualifying trust” NJSA 25:2-1(b). A qualifying trust is defined as “a trust created or qualified and maintained pursuant to federal law, including, but not limited to, section 401, 403, 408, 408A, 409, 529 or 530 of the federal Internal Revenue Code of 1986″ Id. There is no reference to retirement funds. And such property or distributions are “exempt from all claims of creditors and shall be excluded from an estate in bankruptcy, subject to certain exceptions.

Does this state law supercede contrary limitations in the Bankruptcy Code? The Third Circuit Court of Appeals held it did in In re Yuhas, 104 F.3d 612 (3d Cir 1997), cert denied, 521 U.S. 1105 (1997). For now at least, that would seem to answer the question.

But if someone were to push the issue, we wonder whether the New Jersey exclusion would withstand further scrutiny by the Supreme Court. States are given only limited powers in bankruptcy matters. They are allowed to “opt out” of the Bankruptcy Code’s exemption scheme and craft their own exemptions in bankruptcy. New Jersey has not done that. So how can New Jersey declare that a broad range of assets are “exempt”?

Moreover, New Jersey has purported to “exclude” these “qualified trusts” from an estate in bankruptcy. The Bankruptcy Code treats certain types of assets, whether or not an exemption is available, as “excluded” from a bankruptcy estate. 11 USC 541(c)(2). Examples are ERISA qualified pensions, and assets in valid spendthrift trusts.  One can argue that New Jersey’s attempt to re-write this section of the Bankruptcy Code falls afoul of the Constitution’s mandate that bankruptcy laws be the sole province of federal law, and for that reason is invalid. But the counter-argument is that New Jersey law determines what is a valid trust Bankruptcy Code section 541(c)(2) excludes from the bankruptcy estate.  If NJSA 25:2-1(b) is seen as declaring all such “qualified trusts” to have the same protections as otherwise valid “spendthrift trusts” (ie those created with a provision that no part of the trust can be levied, pledged, or encumbered), the validity of the statute could stand unimpeded.

For now, attentive bankruptcy practitioners, especially outside New Jersey, need counsel their clients accordingly.

 



Bankruptcy and Retirement Benefits

Protecting Your Retirement When You Face Bankruptcy

American Board of CertificationYou’ve worked hard to build a nest egg for your retirement, faithfully contributing to an IRA or a 401(k). Maybe you’ve had health problems or lost your job, though, and the bills have piled up. You may see bankruptcy as the only way to get back on your feet again. If you file for bankruptcy, will you lose your retirement funds and be forced to start all over again?

The Exemption of Retirement Accounts in Bankruptcy Proceedings

As a general rule, most pension and retirement funds may not be taken or used by creditors in a bankruptcy proceeding. In a Chapter 7 case, they cannot be liquidated to satisfy creditors.

The rule protecting pension and retirement accounts includes all types, 401(k) accounts, 403(b) accounts, profit sharing plans, money purchase plans, Keoghs and defined benefit plans, so long as they are properly set up as “ERISA Qualified”. For New Jersey residents, any form of IRA is also protected, unless the IRA funds were improperly or fraudulently put there. (Inherited IRA’s are an open issue right now, a question the US Supreme Court is presently considering) In other states, different exemptions may apply.

Social Security is always protected.

Federal law protects Social Security benefits from claims of creditors. This protection continues after you receive the money, as long as you can “trace” the money in an account back to Social Security payments. We recommend against mixing in Social Security payments in an account with substantial amounts of money from other sources.

This area, like so many others, is potentially complex. This discussion is fairly general. Independent review by a qualified attorney is highly recommended.

Contact Neuner & Ventura, LLP

At Neuner & Ventura, LLP, we provide a free initial consultation to every client. We do, however, reserve the right to charge a fee to review any work done by another attorney. To set up an appointment, call our office at 856-596-2828 or send us an e-mail. Evening and weekend appointments are available upon request.



Bankruptcy and Inheritance

Inherited Property and Bankruptcy

What are the potential implications if you found yourself struggling to meet your financial responsibilities and successfully discharged debts through a Chapter 7 proceeding only to find some months later that you are receiving money or property from someone who has died? Is the money yours free and clear? Will you be required to give some or all of it to the bankruptcy court to be distributed to your creditors? The answers can be complicated, but here are some general rules.

The Treatment of an Inheritance after the Completion of a Bankruptcy Filing

If you filed a Chapter 13 bankruptcy you become entitled to receive life insurance money or other money or assets from someone who has died before the three-to-five year period of repayment is over, you must disclose what has happened and may have to turn over any proceeds unless you can demonstrate to the bankruptcy truste that those assets are exempt or some other exception applies. As a result, your plan payments may end up being modified, or you may have to contribute the unprotected portion of what you inherited to pay debts through your bankruptcy plan.

If, on the other hand, you filed for protection under Chapter 7, whether or not you must turn over inherited assets, life insurance proceeds or other inherited funds depends on how much time has elapsed since you filed for bankruptcy. If the person you are inheriting from died within 180 days of your filing, and if you are receiving the money outright, it will generally be considered part of the bankruptcy estate, and must be disclosed. (There are or may be exceptions for money or assets that you inherit through a valid trust). Accordingly, the bankruptcy trustee can use it to pay your creditors, unless you can claim it as exempt. Any portion of the inheritance that cannot be exempted will be used to pay creditors. But an inheritance that you receive more than 180 days after a Chapter 7 filing will not be part of the Chapter 7 bankruptcy estate.

If this situation happens to you, you should promptly seek qualified legal advice as soon as you know you are receiving money or property because someone has died. With the right advice and planning, you will be guided to do the right thing and make use of whatever rights or tools are available to you.

Contact Neuner & Ventura, LLP

At Neuner & Ventura, LLP, we know the personal challenges that come with a potential bankruptcy filing. We offer a free initial consultation to every client. We do, however, reserve the right to charge a fee to review any work done by another attorney. For an appointment, call Neuner & Ventura at 856-596-2828 or send us an e-mail. Evening and weekend appointments are available upon request.

Representing Clients across South Jersey



Protecting Your Rights with Aggressive Creditors

Your Rights When a Creditor Bullies You

When you are struggling to make ends meet, the stress and anxiety can make your life miserable. The last thing you need is an aggressive creditor or collection agency calling you at all hours of the day or night, threatening you with legal action or even calling family or neighbors and telling them about your personal debts. You don’t have to be a victim of offensive or inappropriate tactics by bill collectors. You have rights.

Personal Debt

For a “personal, family, or household” debt, you have a wide range of rights under a federal statute, the Fair Debt Collection Practices Act (FDCPA). This law limits the hours during which a creditor or collection agency may call you. It also requires that debt collectors stop communicating with you if you provide written notice that you want no more contact. It also forbids communication with any third party (other than your spouse or attorney) except to obtain location information. (Note this does not apply to “business debts”, nor does it apply to a creditor who is contacting you to collect their own debt.)

If you have a debt collector or creditor who is harassing you, we recommend that you take the following steps:

  • Log all calls — Ask for the name of the debt collector and the company they represent. Get a phone number as well.
  • Hire an attorney — Once you are represented by counsel, you can simply tell all debt collectors to direct any further communications to your lawyer.
  • If debt collectors continue to call, record the conversation (you should always advise them that they are being recorded. Recording calls from states such as California can result in criminal or civil liability).

Business Debt

The FDCPA does not apply to business obligations. If you are being hounded because of a business debt, your best course of action is to retain legal counsel and to advise any debt collector that they must communicate only with your attorney. If they disregard your request, you should log all calls and record conversations, if possible.

Whether or not these laws apply, you may have other protections.

Contact Neuner & Ventura, LLP

At Neuner & Ventura, LLP, we provide a free initial consultation to every client. We do, however, reserve the right to charge a fee to review any work done by another attorney. To set up a meeting, call Neuner & Ventura at 856-596-2828 or send us an e-mail. Evening and weekend appointments are available upon request.

Representing Clients across South Jersey



Disposing of Property Before You File for Bankruptcy

When you are struggling to get your finances in order, you may choose to sell assets that you don’t need, with the hope that you can make enough money to resolve your problems. You may be tempted to “gift” items of value. If you find that you still need to seek bankruptcy protection, you may face questions from the bankruptcy court or trustee about the disposition of those assets. We tell our clients that “bankruptcy is a fishbowl…it is safest to be able to be transparent”. You must always take care to avoid the appearance that your actions involved a fraudulent transfer.

Taking the Right Steps to Avoid Potential Problems

The most important thing to do is make certain that any sale is clearly what would be considered an “arm’s-length transaction.” This essentially means that the terms of the transaction do not reflect that the parties have common interests or that any favoritism was involved because of the relationship of the parties. The classic example of a fraudulent transfer is the sale or gift of extremely valuable property to a family member or friend for far less than its market value. One of the best ways to show this is to get a fair-market appraisal or some other reliable evidence of value of the goods sold. For cars, sites like www.kbb.com are good. For other property besides real estate, EBay or Craigslist may provide evidence of possible market value.

You need to be careful as well with gifts to charitable organizations, from a church to a soup kitchen or other nonprofit. You may be required to show that the organization is bona fide and that you make similar donations on a regular basis. You may also be required to show that you will not be a primary beneficiary of the donation. For example, it may be considered a fraudulent transfer if you donate a piano to your church when you are the church pianist.

Regardless of how you distribute property before a bankruptcy, it is critical that you keep accurate records. Ideally, your records should show what you sold or gave away, who the recipient was, the goods’ fair market value and whether there were other potential buyers.

If you are in such a situation, you should not delay in getting early qualified legal advice, in case a bankruptcy or similar action becomes necessary.

Contact Us

We provide a free initial consultation to every client. We do, however, reserve the right to charge a fee to review any work done by another attorney. For an appointment, call our office at 856-596-2828 or send us an e-mail. Evening and weekend appointments are available upon request.



What to Do If You Expect Your Vehicle to Be Repossessed

Protect Your Rights When You Fear Repossession of a Vehicle

It happens to a lot of people — you encounter financial difficulties and find yourself behind on your financial obligations. You may be in arrears on the payment for your car or truck, and may have received notice of a potential repossession. What are your rights and what can you do to protect yourself?

When a repossession can take place without court order.

As a general rule (in New Jersey) your lender or their agent (a repo man) may not “breach the peace” without a court order. This means they cannot use or threaten physical force, and they cannot come into your home, garage or a locked closed area to repossess your vehicle without a court order or without your consent. They may, however, repossess the car on the street, in an open driveway, in front of your house or in any other public place without a court order and without notice to you.

It’s also important to understand that if your car is repossessed with personal items inside of it, you risk never seeing those items again. Accordingly, if you anticipate that your vehicle may be repossessed and you must leave it in a public place, you should take care not to leave any valuables in it.

In New Jersey, as long as the license plates are on the car, you remain potentially liable as the owner for any injury or damage someone operating the car may cause, and you need to keep the car insured. You might consider taking the tags off the vehicle and leaving it in front of your home or in some public place. However, when you do, you will be considered to have abandoned the vehicle and may be cited by police for violating the law.

If you file a bankruptcy case, the automatic stay will protect you from repossession for a limited time. If you file a Chapter 13 case, you may be able to bring the loan current through payments under a bankruptcy plan over 3 to 5 years, or you may have other options through the “cramdown” provisions of the Bankruptcy Code. However, if you know that you won’t be able to bring the account current and want to avoid the fear and hassle involved with an actual repossession, we recommend making arrangements to voluntarily surrender the car to the lender at an agreed location (which may be an area dealer). When you do, be sure to remove the license plates when you get to the drop off location. If you are a New Jersey resident, you should surrender them to the nearest DMV office, where you will get a receipt that you can use to remove the vehicle from your auto insurance.

Reliable transportation to get to and from work is often essential to getting back on your feet financially. When this is threatened, getting qualified legal advice and doing some careful planning is essential.

Contact Our Office

At Neuner & Ventura, LLP, we work hard to alleviate the stress, anxiety and confusion that come with a potential bankruptcy filing. We offer a free initial consultation to every client. We do, however, reserve the right to charge a fee to review any work done by another attorney. For an appointment, call us at 856-596-2828 or send us an e-mail. Evening and weekend appointments are available upon request.

Representing Clients across South Jersey



Bankruptcy and Divorce — Which Comes First?

Far too often, the underlying cause of divorce is financial difficulty. Even if financial problems are not the cause of a divorce, they can arise when you no longer have two incomes to pay for your lifestyle or when, having separated, the spouses now have two households to support. If you are considering filing for divorce or if you know that your spouse plans to seek a divorce, a personal bankruptcy filing may become necessary. So a key question is the timing and order of these proceedings. Should you file for bankruptcy first? If so, what will be the impact on your divorce and on your soon-to-be ex-spouse?

Unfortunately, the interplay of divorce and bankruptcy is complex and very much dependent on the facts and circumstances. But a few things are generally true. First, getting early advice from an experienced bankruptcy attorney about how a bankruptcy may impact a divorce is essential. Bankruptcy counsel and divorce counsel should confer at key points in the process.

Bankruptcy or Divorce first? Don’t do them together if possible.

We generally recommend completing the bankruptcy or the divorce first rather than having both in play at the same time. That said, which should be done first depends on the parties and how well they get along, as well as the financial situation and the financial pressure being exerted by creditors. All things being equal, we generally recommend filing the bankruptcy first, but this is not always best. And in some cases, it makes good sense to file a bankruptcy even though a divorce is pending (eg. To discharge debts that are making it hard to settle the divoce. Again, “the devil is in the details”. We can also say that in most instances, using bankruptcy as a litigation tactic against a spouse is ineffective and can backfire.

If you finalize Your Divorce First

If you finalize your divorce before filing for bankruptcy, a lot of ambiguities and complexities may be done away with. Property will generally have been divided, and the amount due for child support, alimony or equitable distribution will have been decided. Unless there has been fraud or collusion, bankruptcy courts generally honor the results of a previous divorce judgment. But, while child support or alimony obligations [“Domestic Support Obligations”] cannot be discharged in a bankruptcy proceeding, in a Chapter 13 bankruptcy equitable distribution or other non-DSO obligations owed to the ex- spouse who is not filing, can be discharged. These can include unpaid attorneys fees owed to your own divorce attorney. If you agreed to pay some of your ex-spouse’s debts for her, this also might end up being non-dischargeable. There are other potential complications that are too fact based and complex to go into here. Anyone doing this needs to review a potential divorce settlement with bankruptcy counsel.

If You File for Bankruptcy First

If you are married when you file for bankruptcy, you can choose to file bankruptcy individually or jointly. If you file individually, you will receive the protections afforded under the law — prohibition of calls, letters or legal action by creditors — but your spouse will not. Because your spouse won’t be protected, he/she may be subjected to harassment by creditors and may be liable for the full amount of the debt. If you file jointly, you will both be protected, but you will both take a hit on your personal credit rating.

A Chapter 7 filing prior to a divorce can simplify the divorce proceedings, as most all debts will be discharged. A joint bankruptcy filing by a husband and wife (either with the same attorney or with separate bankruptcy counsel) may be wise. Spouses who work together can generally fare better than those who do not. A Chapter 13 bankruptcy may help under certain circumstances, even though such cases take 3 to 5 years to complete.

Contact Neuner & Ventura, LLP

We offer a free initial consultation to every potential bankruptcy client. We do, however, reserve the right to charge a fee to review any work done by another attorney or under unusual circumstances. To schedule an appointment, call our office at 856-596-2828 or send us an e-mail. Evening and weekend appointments are available upon request.

Representing Clients across South Jersey



Filing for Bankruptcy Again — Do You Still Get Protection from Creditor Harassment?

The Impact of a Second Bankruptcy Filing on the Automatic Stay

Under the federal bankruptcy laws, when you file for protection in bankruptcy, whether under Chapter 7 or Chapter 13, you are immediately entitled to the benefits afforded by the “automatic stay.” The automatic stay prohibits creditors from calling, writing or taking any other action to collect the debt from you, other than through the proceedings in the bankruptcy court. There are situations in which, even though you have the right to file for bankruptcy protection, you may be denied the protection of the automatic stay. This blog post provides an overview of those circumstances.

Actions that Can Cause You to Lose the Automatic Stay

When you file a new bankruptcy petition, whether or not you are eligible for the automatic stay will depend on how your prior bankruptcy case was resolved. If you had one bankruptcy case dismissed in the past 12 months (unless the dismissal was because you did not qualify under the “Means Test” or because your budget left you the ability to pay something meaningful to your creditors) the automatic stay will only last 30 days. To keep it you have to show the bankruptcy court that you are re-filing in good faith. This usually requires a satisfactory explanation for the previous dismissal, and a showing that “things are different now”. If you have had two dismissals in the last 12 months, there is a presumption of bad faith, and no automatic stay goes into effect. To get the benefit of the automatic stay you have to overcome this presumption and convince the bankruptcy court that your third filing in 12 months was in good faith..

The “takeaway” lesson here is not to let a bankruptcy case be dismissed if you can avoid it. If you filed under Chapter 13 and it is not working out, you are better off converting to Chapter 7 in most cases. Better yet, make sure you and your attorney have carefully analyzed your options so that you do not end up in a bankruptcy that is not right for you. As always, having the right advice from an experienced lawyer is critical.

Contact Neuner & Ventura, LLP

At Neuner & Ventura, LLP, we know that the bankruptcy process can be intimidating and confusing. We offer a free initial consultation to every client. We do, however, reserve the right to charge a fee to review any work done by another attorney. For an appointment, call our office at 856-596-2828 or send us an e-mail. Evening and weekend appointments are available upon request.

Representing Clients across South Jersey



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