Legislative Update and Non-Disparagement Clauses in Contracts

Today, I read an article published in the ABAJournal titled: In bid to protect online reviews, Congress OKs bill banning gag clauses in consumer contracts 

According to the ABAJournal:

“Congress has passed a bipartisan bill that aims to protect negative online reviews by banning nondisparagement clauses in nonnegotiable consumer contracts.”

It appears that this legislation is intended to protect consumers (as opposed to business-to-business).

I have previously delved into the topic of non-disparagement clauses.

1. Non-Disparagement Clauses in Settlement Agreements.

Often times as part of a confidential settlement agreement, the parties to a dispute will agree not to “disparage” each other.

Disparage – as you will see below – has a fairly common meaning.

‘Disparagement’ is ‘a false and injurious statement that discredits or detracts from the reputation of another’s property, product, or business.’ Black’s Law Dictionary (7th ed. 1999).

stated another way:

(1) To speak of in a slighting or disrespectful way; belittle. (2) To reduce esteem or rank.’ . . . American Heritage Dictionary (4th Ed. 2000)

2. Michigan Case Law Concerning “Non-Disparagement Agreements”

Rarely have I ever seen a non-disparagement clause become an issue. In fact, a review of Michigan case law supports this – I found only a handful of cases in Michigan where the parties litigated over one party’s alleged “disparagement” after a settlement agreement was entered.

One such case was the 2011 case of Sohal v. Mich. State Univ. Bd. of Trs. & Davoren Chick M.D., 2011 Mich. App. LEXIS 915, *12-14, 2011 WL 1879728 (Mich. Ct. App. May 17, 2011).

There, Plaintiff,  a participant in MSU’s internal medicine residency program, entered into a “resignation and settlement agreement” with MSU under disputed circumstances. The Agreement contained a “non-disparagement clause”.

Plaintiff sued and argued that Defendants breached the non-disparagement clause, entitling him to “rescind” the Agreement (and therefore sue under all of the laws that he would have otherwise waived).

One of Plaintiff’s arguments was: “the word “non-disparagement” is ambiguous. (If you’ve read my previous post you can understand why this argument does not win the day.)

The Court was not convinced. It held:

“the term “disparage” in the non-disparagement clause is not ambiguous. While plaintiff attempts to ascribe several “reasonable” meanings to the term “disparage,” and thus the non-disparagement clause, the term fairly admits of but one interpretation.” Citing Meagher v Wayne State Univ, 222 Mich App 700, 722; 565 NW2d 401 (1997).

As the Court noted, “Other state courts have determined that the term “disparage” in non-disparagement clauses of settlement agreements are unambiguous.” (citations omitted).

In closing – non-disparagement clauses are standard clauses (but not universally used). Courts have consistently held that “Disparage” is a plainly understood term. It isn’t an ambiguous term.

Questions?

Comments?

e-mail: Jeshua@dwlawpc.com

Twitter: @JeshuaTLauka

http://www.dwlawpc.com

 

Special Purpose National Bank Charters for #Fintech Companies

Today, Thomas J. Curry, Comptroller of the Currency gave remarks at Georgetown Law School about Special Purpose National Bank Charters for Fintech Companies. You can read the remarks here.

Mr. Curry announced that the Comptroller of the Currency (OCC) would move forward with considering applications from financial technology (fintech) companies to become special purpose national banks.

Mr. Curry had this to say, in part:

“Over the past year, no topic in banking and finance has drawn more interest than innovative financial technology, and for good reason. The number of fintech companies in the United States and United Kingdom has ballooned to more than 4,000, and in just five years investment in this sector has grown from $1.8 billion to $24 billion worldwide.

“The OCC published a paper discussing the issues and conditions that the agency will consider in granting special purpose national bank charters.” You can check that paper out here

 

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e-mail: Jeshua@dwlawpc.com

Big Bank Troubles and Trending Towards Community Banking or Fintech?

“The so-called Sons and Daughters Program was nothing more than bribery by another name,”

-Assistant Attorney General Caldwell.

Today the Department of Justice issued a Press Release – JP Morgan’s Investment Bank in Hong Kong has agreed to pay a $72 Million Penalty for Corrupt Hiring S2015-11-26-13-04-02cheme in China.

Yikes.

A couple of thoughts:

1. The Department of Justice is out there holding Big Banks Accountable. 

Someone has to. It’s not going to be the average consumer, (Wells Fargo appears to be an exception). It’s also not going to be the small business owner taking out a construction loan. Big Banks have the leverage.

2. Local Community Banks are More Appealing Than Big Banks.

Consumers and businesses alike are looking for banks they can trust. From my perspective, as a lawyer and an adviser to business owners – I am only interested in referring my clients to professionals that I trust.

Looking at the news headlines, an average individual or small business owner might conclude that they need a local banking relationship they can trust.

In West Michigan there are a lot of good local community banks. I know good commercial lenders who care about their business clients.

Does this mean that big banks are going away? Nope.

As its been said – some of the largest banks are simply able t
o offer better deals at lower risks.

Regardless, the headlines certainly give you pause to think.

On the Topic of the value of Community Banks…

Last year Thomas J. Curry, Comptroller of the Currency gave remarks before the ABA Mutual Community Bank Conference in Washington D.C. You can read the remarks here

Mr. Curry had this to say in favor of community-based banks:

“These community-based institutions extend credit to farms and families and local businesses in towns and cities across America, and they serve their customers in a way that large banks just can’t match. They are small enough to be able to know their customers, and they work with them in good times and bad. But they are also large enough to provide the services communities need. Mutual savings associations fit firmly in that tradition”

In further support:

“You are free to do what is best for your customers, and that means you provide services and price those services in a way that puts people first – ahead of quarterly profit targets and ahead of investor interests.”

Those are pretty glowing remarks for community-based lenders.

They are certainly attributes I like to see when I am referring any of my business clients to a commercial lender – particularly a start-up entrepreneurial type client.

Mr. Curry also commented that “big banks”:

“offer a variety of important services to companies and consumers, from commercial loans to credit cards, and they present a number of challenges from a supervisory perspective.” 

I’d say the “supervisory challenge” was an understatement.

 

FinTech Poses Challenges to Community Banking…

[UPDATED] Just today, November 18, Mr. Curry gave remarks before the 11th Annual Community Bank Symposium.  You can read the remarks here.

Mr. Curry notes: “One particular issue testing banks’ strategic risk today is the tectonic shift underway regarding innovation and financial technology. ”

“fintechs have emerged to provide financial products and services through alternative platforms and delivery channels. As of 2015, the number of fintech companies in just the United States and United Kingdom alone had reached 4,000.“

Mr. Curry notes:

“One factor in the growth of fintech companies is the 85 million millennials entering the financial marketplace who have demonstrated more willingness than earlier generations to change financial service providers or use multiple providers to meet their needs.”

It’s interesting to note the Trend away from Big Banks – and now to Fintech.

Certainly, millennials will continue to play a large role in the growth of fintech companies like Prosper Loans. Coupled this with the fact that millennials are increasingly attracted to business that does social good – fintech appears to have an advantage with millennials.

Questions? Comments? 

email: Jeshua@dwlawpc.com

http://www.dwlawpc.com

Twitter: @JeshuaTLauka

Questions? Comments? 

email: Jeshua@dwlawpc.com

http://www.dwlawpc.com

Twitter: @JeshuaTLauka

Business Legislation Update: Business Owners: Bill Would Restrict Non-Competition Agreements with Employees.

On November 9, 2016 House Bill 6017 was introduced in the Michigan House of Representatives. If passed it would limit the enforceability of a non-competition agreement signed between an employer and an employee.

I have spent several articles discussing the legal consequences/enforceability issues of non-competes.

It appears the Legislature is wrestling with the question posed by Nick Manes of MIBiz in an article a few years back: “Are noncompetes a barrier to growth?

Check out the text of the bill here

The Bill was referred to the committee on commerce and trade.

The Bill is rather short – and has only two key components to it:

1. Require Employers to follow a Specific Procedure prior to enforcing a non-compete.

The Bill would only permit Employers to enforce a non-competition agreement if the Employer followed a procedure, including:

(A) INFORMED THE PROSPECTIVE EMPLOYEE IN WRITING OF THE REQUIREMENT AT OR BEFORE THE TIME OF THE INITIAL OFFER OF EMPLOYMENT.

(B) IN ANY POSTING OR ADVERTISEMENT FOR THE EMPLOYMENT, GIVEN NOTICE THAT ACCEPTANCE OF THE AGREEMENT OR COVENANT IS A CONDITION 1 OF EMPLOYMENT.

2. Non-Compete only Enforceable if the Employee voluntarily resigns.

Further, under the Bill an employer can only enforce the non-compete if, among other things, the employee has voluntarily resigned. Stated another, way, a non-compete would be unenforceable if the Employer terminated the employee.

A Bill was introduced back in February that somewhat mirrors this Bill, but has other restrictions. That Bill never came back from the committee on Trade and Commerce.

We will see if HB 6017 is able to gain any more traction – since it is now also sitting in the committee on Trade and Commerce.

Questions? Comments?

e-mail: Jeshua@dwlawpc.com

Twitter: @JeshuaTLauka

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Real Estate Law Update: A Holdover after Foreclosure Sale Is Not a Tenant.

Happy Friday!

 

Today I am posting about a Court of Appeals case decided on November 1st – Seymore v Adams Realty, et al

Foreclosed Property = high risk/high reward.

Real estate investors are always wary of the many pitfalls when purchasing property at foreclosure.

The Adams Realty Case provides an example of what happens when someone is still occupying the Property after foreclosure.

Should you just change the locks?  

Should you take matters into your own hands?

 

FACTS:

  • Plaintiff, Seymore was allegedly locked out of a house located in Detroit after Adams Realty and Michael Regan allegedly changed the locks on or about October 9 or 10, 2014.
  • Defendant Michael Regan purchased the house on or about October 2, 2014, from Bank of America.
  • Bank Of America purchased the property on December 19, 2013, by way of a sheriff’s sale.
  • Seymore sued Regan and Adams Realty claiming that by changing the locks Regan violated the “Anti-Lockout Statute” MCL 600.2918.

 

Anti-Lockout Statute – MCL 600.2918 

Any landlord who has gone through the process of evicting a tenant knows that, in the residential leasing context, there are heightened duties of landlords, and heightened rights of tenants.  Tenants have the right not to have their possessory interest in the property interfered with, without the proper court procedure being complied with (Summary Proceeding Action in District Court).

 

Here, Seymore claimed that she was in possession of the Property after foreclosure and by changing the locks, the purchaser had unlawfully interfered with her right to possess the Property.

 

The Anti-Lockout statute provides damages for forcible ejectment from property or unlawful interference with a possessory interest in property.

 

Subsection (1) (forcible ejection) applies to any person. 

Subsection (2) (unlawful interference) applies to any tenant in possession.

Violating the statute can cause a property owner/landlord to be liable for statutory damages (3 times the amount of actual damages or $200.00 whichever is greater.)

In this case…

Seymore claimed that she was was basically a “hold over tenant” after foreclosure and had rights under the anti-lockout statute.

The Court of Appeals said – no. The Anti-Lockout statute applies to “tenants”. Seymore did not not show any facts that would say she was a tenant. The anti-lockout statute does not apply.

“MCL 600.2918(2) does not provide relief for a person, such as [Seymore] who remained in possession of property after a foreclosure but who had no contractual relationship with the owner of the property.” Seymore, id at Page 3, citing Nelson v Grays, 209 Mich App 661  (1995).

 

Conclusion:

Just changing the locks after redemption has expired is not “unlawful interference with a possessory interest” under MCL 600.2918(2) if you, purchaser, do not have a contract with the occupier of the Property.

However, the anti-lockout statute enforces penalties against a property owner who takes “forcible actions” that, as the court in Shaw v Hoffman, 25 Mich 162 (1872) noted “in some way inspire terror or alarm in the person evicted.”

To avoid any unfounded claims by holdovers, it always makes sense after purchasing property at foreclosure, when there are any occupants present, to go through the lawful channels for a court proceeding to extinguish any possessory rights.

You don’t want to expose yourself to undue liability.

 

Questions? Comments?

E-mail: Jeshua@dwlawpc.com

http://www.dwlawpc.com

Twitter: @JeshuaTLauka

Another Court Lesson for Business Owners: Read Your Contracts Before You Sign.

I recently read yet another court decision that provides a classic example for businesses owners of the consequences for not reviewing your contracts before signing.

The case: the October 6th, 2016 Michigan Court of Appeals decision of Earl Pegues, LLC v Izis General Contractors, LLC.

The dispute concerned a construction agreement.

The property owner, Pegues LLC engaged a contractor to construct a restaurant for the price of $1,050.000 in my hometown of Saginaw.

Pegues LLC claimed the contractor overbilled by approximately $123,000.

The main problem:

Pegues had signed off on the Contractor’s Sworn Statement and therefore authorized the title company to release the funds and therefore, unwittingly, agreed to the alleged overbilling.

Thereafter, Pegues sued for breach of contract and fraud.

During the lawsuit, Pegues admitted that he simply “did not look at the figures.” That he “did not understand the sworn statement when the bank gave it to [him] to sign.”

Pegues admitted – “It was my oversight.”

The trial court dismissed all claims against the Contractor – Pegues appealed, and the Court of Appeals upheld the dismissal.

Law:

It is your responsibility to know what you are agreeing to before you sign a contract.

The Court of Appeals reasoned:

“It is well-settled that a person who signs a contract cannot have the contract set aside merely because he was negligent in failing to read the terms.” Citing Shay v Aldrich, 487 Mich 648, 680-681 (2010).

Further:

“[A] person who signs and executes an instrument without inquiring as to its contents cannot have the instrument set aside on the ground of ignorance of the contents.” Christensen v Christensen, 126 Mich App 640, 645 (1983).

Conclusion:

Small business owners often times are wearing many “hats”. They are working with limited cash flow and are forced to make many choices. Many of these choices are in areas outside of their expertise.

Oftentimes startups and small business owners will “cut corners” to be more efficient and cost-effective.

When it comes to signing a legally binding contract – it is simply not worth cutting corners on.

The cost of what you do not know can be significant.

Question? Comments?

e-mail: Jeshua@dwlawpc.com

http://www.dwlawpc.com

Twitter: @JeshuaTLauka

Reminder to Michigan Limited Liability Companies: Maintain your Corporate Formalities and Keep up your Guard.

Occasionally I will have a business client come in and I will ask – just to make sure – “is your business still in good standing?”

The common answer is “I think so.”

And of course, after I perform a quick internet check with the State of Michigan it is all too common that I discover that either the LLC is “not in good standing” or worse, the company has been dissolved automatically for failure to file annual statements.

This morning I received an e-mail reminder from the Michigan Department of Licensing and Regulatory Affairs (LARA)

LLC owners are reminded that 2016 annual statements are being mailed to resident agents.

A Word on Resident Agents:

This is that time of the year that my office is inundated with such statements. We are happy to provide our business clients with resident agent services. One of the benefits of an LLC is that it provides its owners a level of privacy protection.

Michigan law requires Limited Liability Companies to have appointed a Resident Agent.

MCL 450.4207(1)(b) requires an LLC to have a resident agent. A person, or business with a physical presence in the State of Michigan.

Michigan law does not require that an “owner” of the LLC be the resident agent.

“The resident agent appointed by a limited liability company is an agent of the company upon whom any process, notice, or demand required or permitted by law to be served upon the company may be served.” MCL 450.4207(1)(b).

Many of my real estate investment clients will utilize my law firm as resident agent when filing their articles of organization with the State of Michigan.

Per LARA’s announcement:

“Annual statements and reports must be filed no later than February 15 of each year and can be filed online at www.michigan.gov/fileonline.”

Consequences for Failing to File:

if an LLC “fails to file its annual statement/report and filing fee for two years, the limited liability company will not be in good standing. The status of the limited liability company will be “active, but not in good standing.””

Further,

an LLC “not in good standing is not entitled to a certificate of good standing; its company name will be available for use by another entity, and no document will be filed on behalf of the company other than a certificate of restoration.”

By the Numbers:

“There are a total of 419,315 LLCs and 12,199 PLLCs that are receiving 2016 statements (LLCs) and statements and reports (PLLCs).”

In Conclusion:

Business owners, if you get these annual statements from the State of Michigan, or from your attorney – do not disregard them! Maintain your Corporate Formalities.

Questions? Comments?

E-mail: Jeshua@dwlawpc.com

http://www.dwlawpc.com

Twitter: @JeshuaTLauka

Real Estate Case Law: Tenants in Common v Tenants with Full Rights of Survivorship – A Potentially Costly Distinction.

This morning I read a court of appeals decision that came out on October 18 – it provides a classic example of why you need to take care in drafting real estate documents.

 

The case: In Re Estate of Lyle Steiner

Facts are relatively straight forward:

  • In 2007, Tuscan Plaza Condominiums, LLC, conveyed a personal residence to Lyle F. Steiner and Steven Steiner.
  • Specifically, the deed provides that the property was conveyed: to LYLE F. STEINER, A SINGLE MAN AND STEVEN M. STEINER, A SINGLE MAN
  • Lyle passed away. Steven was appointed personal representative of Lyle’s estate.
  • DHHS filed a claim against the estate for unpaid Medicaid bills in the amount of $48,084.95.
  • Steven subsequently filed a petition to reform the deed to Lyle’s personal residence to indicate a joint tenancy with a right of survivorship.

What’s the significance?

Law: Distinction Between Tenants in Common and Joint Tenants with Full Rights of Survivorship

 

Under Michigan law, there are generally two ways to own real property – Tenants in Common and Joint Tenants with Full Rights of Survivorship. (A third way, not part of my discussion, but very interesting topic, being as husband and wife, or tenants by the entirety).

Tenants in Common

Holding property as Tenants in Common means that each owner holds the entire title along with the owners. . Each owner shares in possession of the entire property, and each is entitled to an undivided share of the whole. If an owner dies, his interest in the property is passed on to his heirs.

Joint Tenants with Full Rights of Survivorship

Conversely, in Joint Tenants with Full Rights of Survivorship, when an owner passes away, their remainder interest in the property passes to the remaining owners. Simply put, the last joint owner to die takes the entire property.

In the Steiner Estate Case:

The Deed indicated that Lyle and Steven owned the Property – there was no “survivorship language” – so the property was held as “tenants in common”.

 

When Lyle Steiner passed away – an undivided half interest in the Property was owned by the Estate – and therefore DHS had a, presumably, valid claim for its $48,084.95!

If the Property was held as Tenants with Full Rights of Survivorship – Lyle Steiner would have no Estate – his half of the Property would transfer automatically to Steven.

No Estate = No money to pay DHS.

Steve attempted to argue that the Deed should be “reformed” because Steve’s complete ownership upon Lyle’s death was intended.

The Court of Appeals was not convinced.

To paraphrase – the Deed is not ambiguous. It is plain in its meaning.

because it is plain in its meaning – you cannot look outside of the deed to other evidence that shows Lyle’s intent.

 

Conclusion:

Real Estate can be precise and complex. It is worth engaging legal counsel in any real estate matters.

 

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e-mail: Jeshua@dwlawpc.com

Twitter: @JeshuaTLauka

 

 

 

Update on Community Development and Affordable Housing: Is an Answer Found in Social Enterprise?

Today the Community Development Financial Institutions Fund released its five year Strategic Plan

If you are not familiar with the CDFI, the CDFI “works to spur economic growth and opportunity in many of our nation’s most distressed communities.“2015-11-26-13-04-02

“The CDFI Fund’s mission is to expand economic opportunity for underserved people and communities by supporting the growth and capacity of a national network of community development lenders, investors, and financial service providers.”

Included in the overarching goal for the CDFI’s strategic plan is promoting community development. If you have a few minutes, take a look at the strategic plan.

The Affordable Housing Problem in Grand Rapids

As many of you may know, a few weeks back the Grand Rapids Chamber hosted an Issue Summit on the Housing Crisis in Grand Rapids.

The Summit brought speakers representing many community stakeholders, including representatives from 616 Development, Grand Rapids Urban League,Rockford Construction, ICCF, MSHDA, and many local non-profits, including Mel Trotter Ministries, HQ, Heartside Ministries, on this lack of affordable housing, what is as Mayor Bliss emphasized, admittedly, “a complex issue”.

I have previously offered my own perspective, both as a lawyer representing real estate developers/investors, and as Board Chairman at Mel Trotter Ministries.Is there an answer found in Social Enterprise?

Last week Jim Harger with MLive posted a thorough article on the affordable housing crisis.

One community partner highlighted was Pastor Jim Davis and his company “Purpose Properties”

“The mission of Purpose Properties is to “raise enough money from local foundations and philanthropists to buy market-rate and affordable rental properties in the city.”

According to Jim Harger’s article:

“Purpose Properties plans to charge market rates for its properties to those who can afford them and use their profits to subsidize the rents of those who cannot afford market rates.”

My thoughts:

This is social entrepreneurship at its finest. Social entrepreneurs engage their community by using the power of business to solve a social problem.

We need more businesses and community stakeholders to approach our community problems like Jim Davis and Purpose Properties.

The question we should all ask ourselves: Am I working to build a better community?

Jeshua@dwlawpc.com

 

Twitter: @JeshuaTLauka

Real Estate Investors Bidding at Foreclosure Sale: If You Pay Less than owed on the Mortgage, there is no Surplus.

Real estate investors and lenders are under pressure to “get it right” when bidding at sheriff sales, especially in a market where good deals are getting harder to come by.

Some lenders/investors have tried some creative methods of recovery and made some interesting legal arguments in order to  maximize their profit at  or after foreclosure sales.

2016-07-22 13.10.20

Complex legal issues can arise in a competitive market when there is money to be made.

 

One issue that comes up after the foreclosure sale – who is entitled to keep surplus funds?  How do you define “surplus funds”?

The Court of Appeals decided these issues in an October 11th decision – see the case Trademark Properties of Michigan, LLC v County of Macomb

Summary of Facts:

  • The mortgagor defaulted on her mortgage – property went to foreclosure sale.
  • The balance on the mortgage, including fees, interest, and costs, was $55,030.58.
  • The mortgagee, CitiMortgage, Inc. made a bid of $20,572.80 as an initial partial credit bid.
  • Trademark Properties, LLC (“TM Properties”) was the highest bidder with a bid of $31,572.80.
  • After the foreclosure sale, the mortgagor assigned her rights to any surplus proceeds to TM Properties.
  • TM Properties then filed a petition in  court for the return of surplus proceeds in the amount of $11,000, which was the difference between the initial credit bid and the final bid.

 

Law:

There are a couple of particular laws that come into play here:

I. Full Credit Bid

One general one to be aware of – the Full Credit Bid Rule – it basically stands for the proposition that: “An overbid at a Sheriff’s sale extinguishes the entire debt.” Pulleyblank v. Cape, 179 Mich.App. 690, 446 N.W.2d 345 (1989) (per curiam).

practically speaking, if the bank bid the entire amount that was owed, regardless of whether or not the fair market value of the property is worth less than what is owed, the bank cannot come after the borrower for a deficiency.

 

II. MCL 600.3252 – Surplus Funds After Foreclosure. 

That statute states in relevant part

If after any sale of real estate…there shall remain in the hands of the officer…making the sale, any surplus money after satisfying the mortgage on which the real estate was sold, and payment of the costs and expenses of the foreclosure and sale, the surplus shall be paid over by the officer…to the mortgagor…or assigns, unless at the time of the sale, or before the surplus shall be so paid over, some claimant or claimants, shall file with the person so making the sale, a claim…in which case the person so making the sale, shall forthwith upon receiving the claim, pay the surplus to, and file the written claim with the clerk of the circuit court of the county in which the sale is so made…

 

Essentially, TM Properties recognized that the Bank/mortgagee made a credit bid. The investor out bid the bank and claimed that the difference between the bank’s bid and the excess of what TM Properties bid was a “surplus“.

TM Properties acquired the mortgagor’s “interest” in the Property, which presumably included her rights to redeem the property AND any rights to any surplus funds.

TM Properties demanded payment of the “surplus” – the County claimed – there is no surplus!

The Trial Court agreed with the County.  TM Properties appealed.

The Court of Appeals was tasked to decide:

Whether the $11,000 difference between CitiMortgage’s initial credit bid and TM Properties’ successful bid constituted “surplus money after satisfying the mortgage on which the real estate was sold,” under MCL 600.3252. Opinion at page 2.

The Court went on to define “Surplus” and “satisfy” – since those terms are undefined in the statute. The Court held:

“MCL 6003242 provides that a surplus constitutes the differ
ence between the amount due on the mortgage note, plus costs and expenses, and the purchase price of the property at foreclosure sale. If the purchase price of the property is less than the amount due on the mortgage note and costs and expenses, then there is no surplus.”

 

In summary – the Bank did not make a full credit bid.  The Third Party purchaser, TM Properties did not purchase the property for more than what was owed on the Mortgage, plus foreclosure costs.  As such, there was no surplus.

 

Questions? Comments?

E-mail: Jeshua@dwlawpc.com

http://www.dwlawpc.com

Twitter: @JeshuaTLauka