An interesting case was recently reported in the Consumer Bankruptcy News. In First Tennessee Bank, N.A. v. Hansen, 2012 WL 1156409 (Bankr. E.D. Tenn. 4/6/12), the bank alleged that the debtors’ case was filed in bad faith because they knew about a meth lab in their basement and should not be allowed to get the damages caused by the lab to be discharged. The debtors had rented out their basement to their grandson’s father. The father had a drug problem, which he claimed was over. The debtors required that he take drug tests and after 10 months of the tests coming back negative, they allowed him to rent their basement. In 2010 the debtors’ business declined and they thought about selling their house, but after obtaining an appraisal in August of 2010 they realized there was no equity in the house and proposed a plan that called for the surrender of the house back to the lender. They then moved out of the house, but allowed their grandson and his father to remain in the house.
In October of 2010, the debtor husband went back to the house and went to the basement storage area to get packing tape and discovered two bottles and a tube and confronted the father. The father admitted he was making speed and apologized for violating the debtors’ trust and destroyed all the lab equipment. However, it turned out that after destroying all the lab equipment he then bought new equipment and resumed his illegal activities. The police were called to the house by child protective services to make sure the grandson had enough food in the house. When opening the cabinets the police discovered jars containing a white liquid and found the meth lab. The father was arrested and the house was condemned. The bank subsequently paid more than $45,000 to repair the damage done to the house and also spent more than $35,000 in legal fees. The bank asked the court to dismiss the case as having been filed in bad faith. The bank alleged that the debtors knew of the meth lab and were using the Chapter 13 filing to get rid of a worthless house and the debt associated with it. However, the court found that the debtors were not aware of the meth lab and only decided to surrender the house after an appraisal came back which indicated they had no equity in the house. Accordingly, the court denied the bank’s motion.
Laura J. Margulies is a principal in the firm of Laura Margulies & Associates, LLC. Our web site is located at: www.law-margulies.com. We represent consumers in bankruptcy and litigation matters in Maryland and the District of Columbia.
Wednesday, June 13, 2012
Tuesday, May 15, 2012
New Rules for Mortgage Lenders In Chapter 13 Bankruptcy Cases
This past December 2011, Congress enacted a new Federal Bankruptcy Rule, Rule 3002.1. This new rule governs how mortgage payments are to be treated. Specifically, when a debtor’s Chapter 13 plan provides to cure pre-petition arrears owed to the debtor’s mortgage company and the Trustee has paid those arrears in full, the Trustee must file a report with the court and send a copy of the report to the mortgage lender which indicates that the pre-petition arrears have been paid in full and that the debtor is current on his mortgage payments. If the mortgage company’s records indicate that the pre-petition arrears have not been paid in full or that the debtor is not current, it has 21 days from the date of the Trustee’s notice to file a response. If no response is filed by the mortgage lender, then the debtor will be considered current on his or her mortgage payments. This means that the mortgage lender is later precluded from claiming any payments are due from the debtor as of the date of the Trustee’s notice. This new law was enacted to prevent mortgage companies from claiming additional monies due from debtors after their Chapter 13 cases are discharged and closed.
If the lender files a timely opposition to the Trustee’s notice, the debtor has 31 days after the opposition is filed to file a response challenging the lender’s opposition. The court will then schedule a hearing and make a determination on the issue. If the lender does not file a timely opposition, it is precluded from presenting evidence at a subsequent hearing on the issue of the debtor’s payments.
The new rule also requires lenders to notify the court and the debtor if during the chapter 13 case it changes the amount of the debtor’s mortgage payment due to escrow changes or the loan was an adjustable rate loan or for any other reason. This notice must be filed with the court at least 21 days before the new payment amount is due. I had once case recently where the mortgage lender filed a notice in May 2012 of a payment change that took effect March 1, 2012. This was clearly not timely, and therefore, my client would not be responsible for the increase in payment during the months of March and April.
Finally, the new rule also requires that the mortgage lender file a notice with the court, with copies sent to the debtor and the debtor’s attorney, of any fee, cost or expense incurred by it during the Chapter 13 case which it considers the debtor’s liability. This notice must be filed within 180 of the date the lender incurred this fee, cost or expense. For example, if the lender wants to charge the debtor’s account for preparing and filing a proof of claim, it must notify the court of that expense within 180 days of the filing of the claim, or it will not be able to charge the debtor’s account for that expense.
Laura J. Margulies is a principal in the firm of Laura Margulies & Associates, LLC. Our web site is located at: www.law-margulies.com. We represent consumers in bankruptcy and litigation matters in Maryland and the District of Columbia.
If the lender files a timely opposition to the Trustee’s notice, the debtor has 31 days after the opposition is filed to file a response challenging the lender’s opposition. The court will then schedule a hearing and make a determination on the issue. If the lender does not file a timely opposition, it is precluded from presenting evidence at a subsequent hearing on the issue of the debtor’s payments.
The new rule also requires lenders to notify the court and the debtor if during the chapter 13 case it changes the amount of the debtor’s mortgage payment due to escrow changes or the loan was an adjustable rate loan or for any other reason. This notice must be filed with the court at least 21 days before the new payment amount is due. I had once case recently where the mortgage lender filed a notice in May 2012 of a payment change that took effect March 1, 2012. This was clearly not timely, and therefore, my client would not be responsible for the increase in payment during the months of March and April.
Finally, the new rule also requires that the mortgage lender file a notice with the court, with copies sent to the debtor and the debtor’s attorney, of any fee, cost or expense incurred by it during the Chapter 13 case which it considers the debtor’s liability. This notice must be filed within 180 of the date the lender incurred this fee, cost or expense. For example, if the lender wants to charge the debtor’s account for preparing and filing a proof of claim, it must notify the court of that expense within 180 days of the filing of the claim, or it will not be able to charge the debtor’s account for that expense.
Laura J. Margulies is a principal in the firm of Laura Margulies & Associates, LLC. Our web site is located at: www.law-margulies.com. We represent consumers in bankruptcy and litigation matters in Maryland and the District of Columbia.
Friday, May 11, 2012
Reaffirmation of Vehicle Loans in Chapter 7 Cases
On July 15, 2011 the highest Court in Maryland clarified the issue of whether a lender who has granted a loan for the purchase of a vehicle under a vehicle retail installment contract may repossess a vehicle solely because the borrower filed bankruptcy. In most cases, the answer is “yes.”
In the matter of Ford Motor Credit Company, LLC v. Roberson, 420 Md. 649 (Md. 2011), the debtor, Patricia Roberson, filed a previous Chapter 7 bankruptcy case. While that case was pending she did not execute a reaffirmation agreement to reinstate her car loan with Ford. After she received her discharge, Ford repossessed her car. Ms. Roberson was current on her car payments at the time of repossession, and the vehicle was properly titled and insured. Ford argued that it had the right to repossess the vehicle under the “Ipso Facto” clause of her finance agreement. The Ipso Facto clause stated that the filing of bankruptcy, in and of itself, was a breach of the finance agreement. Ford argued that the purpose of the Ipso Facto clause is to prevent “insecurity” that is caused by the filing of Chapter 7 bankruptcy. This “insecurity” exists because a bankruptcy discharge removes Ford’s ability to sue a borrower if he or she defaults on the car loan after bankruptcy. The way to cure this “insecurity” would have been for Ms. Roberson to have executed a reaffirmation agreement during pendency the Chapter 7 case because it would reinstate Ms. Roberson’s personal liability for the loan (subject to Court approval). Ms. Roberson argued that since she was current on her payments and was otherwise in compliance with the loan agreement, there was no basis for Ford to deem the loan to be in default.
The Court of Appeals of Maryland decided the matter in favor of Ford. In doing so, the Court looked to three statutes that govern lending and borrowing in the State of Maryland. These statutes are commonly referred to as “CLEC”, “OPEC”, and “RISA”. There was no dispute that the finance agreement at issue was governed by CLEC. The Court also looked at an older case called Biggus v. Ford Motor Credit Co., 328 Md. 188, 613 A.2d 986 (Md. 1991). In Biggus the Court of Appeals acknowledged that CLEC was a newer statute that RISA. The Court determined that there were certain situations that were not covered by CLEC, and wherever there were gaps in the CLEC rules, the rules under RISA would fill in the blanks. After the Biggus case was decided, the Maryland Legislature grew concerned that this “gap filling” would cause a flood of new lawsuits in order to determine when RISA rules would apply to contracts that were otherwise governed by CLEC. The Legislature thought this uncertainty would cause lenders to believe that they needed set money aside to cover legal fees and costs associated with this unknown litigation. As a result, it was feared that many lending costs would spike and lenders would simply stop writing auto loans in Maryland. Therefore, new provisions, including the one containing the Ipso Facto clause at issue were enacted.
The Court then compared language in CLEC (and OPEC) with the language in RISA, regarding what a lender is prohibited to do in the face of “uncertainty.” The Court noted that RISA prohibits both acceleration of all payments due under the loan and repossession of the vehicle, while CLEC only prohibits acceleration of the payments due under the loan. The Court determined that the Legislature must have intentionally excluded repossession from the prohibitions under CLEC and, as a result, it was permitted.
Boiled down to its essence, the Roberson decision stands for a proposition that most car loans must be reaffirmed in Chapter 7 cases in order to nullify the lender’s right to repossess the vehicle at any time, regardless of whether payments have been made and the owner is otherwise in compliance with the loan terms. This does not mean all reaffirmation agreements should be signed. Consultation with a bankruptcy lawyer is key in determining whether it is in your best interest to sign a reaffirmation agreement.
Seth W. Diamond is an attorney at Laura Margulies & Associates, LLC. in Rockville, Maryland. His firm represents individuals and companies in bankruptcy and litigation matters in Maryland and the District of Columbia. For more information about bankruptcy and the services offered by his firm, please feel free to visit the firm's website. If you would like to schedule an appointment to discuss bankruptcy with an attorney, call 301-816-1600, or click here.
In the matter of Ford Motor Credit Company, LLC v. Roberson, 420 Md. 649 (Md. 2011), the debtor, Patricia Roberson, filed a previous Chapter 7 bankruptcy case. While that case was pending she did not execute a reaffirmation agreement to reinstate her car loan with Ford. After she received her discharge, Ford repossessed her car. Ms. Roberson was current on her car payments at the time of repossession, and the vehicle was properly titled and insured. Ford argued that it had the right to repossess the vehicle under the “Ipso Facto” clause of her finance agreement. The Ipso Facto clause stated that the filing of bankruptcy, in and of itself, was a breach of the finance agreement. Ford argued that the purpose of the Ipso Facto clause is to prevent “insecurity” that is caused by the filing of Chapter 7 bankruptcy. This “insecurity” exists because a bankruptcy discharge removes Ford’s ability to sue a borrower if he or she defaults on the car loan after bankruptcy. The way to cure this “insecurity” would have been for Ms. Roberson to have executed a reaffirmation agreement during pendency the Chapter 7 case because it would reinstate Ms. Roberson’s personal liability for the loan (subject to Court approval). Ms. Roberson argued that since she was current on her payments and was otherwise in compliance with the loan agreement, there was no basis for Ford to deem the loan to be in default.
The Court of Appeals of Maryland decided the matter in favor of Ford. In doing so, the Court looked to three statutes that govern lending and borrowing in the State of Maryland. These statutes are commonly referred to as “CLEC”, “OPEC”, and “RISA”. There was no dispute that the finance agreement at issue was governed by CLEC. The Court also looked at an older case called Biggus v. Ford Motor Credit Co., 328 Md. 188, 613 A.2d 986 (Md. 1991). In Biggus the Court of Appeals acknowledged that CLEC was a newer statute that RISA. The Court determined that there were certain situations that were not covered by CLEC, and wherever there were gaps in the CLEC rules, the rules under RISA would fill in the blanks. After the Biggus case was decided, the Maryland Legislature grew concerned that this “gap filling” would cause a flood of new lawsuits in order to determine when RISA rules would apply to contracts that were otherwise governed by CLEC. The Legislature thought this uncertainty would cause lenders to believe that they needed set money aside to cover legal fees and costs associated with this unknown litigation. As a result, it was feared that many lending costs would spike and lenders would simply stop writing auto loans in Maryland. Therefore, new provisions, including the one containing the Ipso Facto clause at issue were enacted.
The Court then compared language in CLEC (and OPEC) with the language in RISA, regarding what a lender is prohibited to do in the face of “uncertainty.” The Court noted that RISA prohibits both acceleration of all payments due under the loan and repossession of the vehicle, while CLEC only prohibits acceleration of the payments due under the loan. The Court determined that the Legislature must have intentionally excluded repossession from the prohibitions under CLEC and, as a result, it was permitted.
Boiled down to its essence, the Roberson decision stands for a proposition that most car loans must be reaffirmed in Chapter 7 cases in order to nullify the lender’s right to repossess the vehicle at any time, regardless of whether payments have been made and the owner is otherwise in compliance with the loan terms. This does not mean all reaffirmation agreements should be signed. Consultation with a bankruptcy lawyer is key in determining whether it is in your best interest to sign a reaffirmation agreement.
Seth W. Diamond is an attorney at Laura Margulies & Associates, LLC. in Rockville, Maryland. His firm represents individuals and companies in bankruptcy and litigation matters in Maryland and the District of Columbia. For more information about bankruptcy and the services offered by his firm, please feel free to visit the firm's website. If you would like to schedule an appointment to discuss bankruptcy with an attorney, call 301-816-1600, or click here.
Tuesday, April 17, 2012
Be Careful of What Funds Are in The Bank on The Day the Debtor Files Bankruptcy
In Maryland, the Chapter 7 Trustees are now asking to see exactly what funds were in the debtor’s bank account on the day he or she filed the Chapter 7 case. If the amount in the account is more than is listed on the debtor’s schedules and therefore not fully exempt, the trustee may ask the debtor to turn over the non-disclosed and non-exempt portion of the funds in the account. When indicating the amount in the bank account, a debtor may have deducted the amount in checks that he or she wrote prior to filing from the balance in the account. However, if those checks did not clear pre-petition, the money was still in the account on the date of filing and unless disclosed and exempted, may have to be turned over to the trustee. A debtor may be surprised to find out that they cannot deduct checks outstanding on the date of filing from the balance on the account, especially since by the time they meet with the trustee, the checks would have cleared and the funds are no longer in the account.
Section 541 of the Bankruptcy Code broadly defines property of the estate to include all legal or equitable interests of the debtor in property as of the date of the filing of the case. This will usually include all money in a debtor’s bank account. The Supreme Court has ruled in the case of Barnhill v. Johnson, 503 U.S. 393 (1992) the funds in a debtor’s bank account remain the debtor’s until the checks actually clear the bank, even though the debtor may have written checks that were outstanding as of the date the case was filed.
My suggestion is for the debtor to go online on the date the case is being filed and let the attorney know exactly how much is in the account on that date. Hopefully, it is not more than the debtor will be entitled to exempt. If it is, then the debtor may want to wait to file until all the checks that have been sent out clear the account, or withdraw the funds in the account and use the cash to pay bills that would be considered necessary expenses for the debtor or his or her dependents.
Laura J. Margulies is a principal in the firm of Laura Margulies & Associates, LLC. Our web site is located at: www.law-margulies.com. We represent consumers in bankruptcy and litigation matters in Maryland and the District of Columbia.
Section 541 of the Bankruptcy Code broadly defines property of the estate to include all legal or equitable interests of the debtor in property as of the date of the filing of the case. This will usually include all money in a debtor’s bank account. The Supreme Court has ruled in the case of Barnhill v. Johnson, 503 U.S. 393 (1992) the funds in a debtor’s bank account remain the debtor’s until the checks actually clear the bank, even though the debtor may have written checks that were outstanding as of the date the case was filed.
My suggestion is for the debtor to go online on the date the case is being filed and let the attorney know exactly how much is in the account on that date. Hopefully, it is not more than the debtor will be entitled to exempt. If it is, then the debtor may want to wait to file until all the checks that have been sent out clear the account, or withdraw the funds in the account and use the cash to pay bills that would be considered necessary expenses for the debtor or his or her dependents.
Laura J. Margulies is a principal in the firm of Laura Margulies & Associates, LLC. Our web site is located at: www.law-margulies.com. We represent consumers in bankruptcy and litigation matters in Maryland and the District of Columbia.
Wednesday, January 4, 2012
Beware of Escrow Double Dipping By Mortgage Lenders
The United States Trustee’s Office in New York has uncovered a scam that has cost Chapter 13 debtors approximately $179 million in excessive fees from their mortgage lenders. It involves “double dipping” of escrow payments. Double dipping is when the mortgage lender charges the Chapter 13 debtor twice for the same escrow arrears.
Counsel for debtors or debtors themselves should carefully review of the claims filed by mortgage lenders or services in Chapter 13 cases to see if they are being charged twice for the same escrow arrears. Mortgage lenders must file an itemization of the arrears in their claim. The itemization will indicate the number of months in arrears, any accumulated late charges, attorneys’ fees incurred by the lender, escrow shortage, etc. The only time an escrow shortage should appear is if the mortgage arrears only includes principal and interest. If the mortgage arrears includes a portion for escrow there should be no itemization for escrow shortage. For example, if your mortgage consists of $1,500 in principal and interest and the escrow for property taxes and insurance is $500, if the lender claims that the debtor was four months behind in his payments pre-petition and uses the figure of $2,000 per month for a total of $8,000, then there should not be a separate itemization for escrow shortage of $2,000 as the escrow shortage was already calculated in the monthly itemization. Unfortunately, mortgage lenders and servicers have not been that careful in preparing the claims and are collecting double the amount actually owed by the debtor for escrow shortage.
There are even cases where the lenders are actually collecting triple the escrow arrears. This happens when the lender or servicer adjusts the debtor’s regular mortgage payments to cover the pre-petition escrow arrears as part of the debtor’s post-petition payments. In this case, the debtor and the Chapter 13 Trustee are both paying the lender for the escrow arrears.
Laura J. Margulies is a principal in the firm of Laura Margulies & Associates, LLC. Our web site is located at: www.law-margulies.com. We represent consumers in bankruptcy and litigation matters in Maryland and the District of Columbia.
Counsel for debtors or debtors themselves should carefully review of the claims filed by mortgage lenders or services in Chapter 13 cases to see if they are being charged twice for the same escrow arrears. Mortgage lenders must file an itemization of the arrears in their claim. The itemization will indicate the number of months in arrears, any accumulated late charges, attorneys’ fees incurred by the lender, escrow shortage, etc. The only time an escrow shortage should appear is if the mortgage arrears only includes principal and interest. If the mortgage arrears includes a portion for escrow there should be no itemization for escrow shortage. For example, if your mortgage consists of $1,500 in principal and interest and the escrow for property taxes and insurance is $500, if the lender claims that the debtor was four months behind in his payments pre-petition and uses the figure of $2,000 per month for a total of $8,000, then there should not be a separate itemization for escrow shortage of $2,000 as the escrow shortage was already calculated in the monthly itemization. Unfortunately, mortgage lenders and servicers have not been that careful in preparing the claims and are collecting double the amount actually owed by the debtor for escrow shortage.
There are even cases where the lenders are actually collecting triple the escrow arrears. This happens when the lender or servicer adjusts the debtor’s regular mortgage payments to cover the pre-petition escrow arrears as part of the debtor’s post-petition payments. In this case, the debtor and the Chapter 13 Trustee are both paying the lender for the escrow arrears.
Laura J. Margulies is a principal in the firm of Laura Margulies & Associates, LLC. Our web site is located at: www.law-margulies.com. We represent consumers in bankruptcy and litigation matters in Maryland and the District of Columbia.
Tuesday, November 1, 2011
Severance Payments Received By A Debtor After Chapter 7 Is Filed Were Considered Part of Bankruptcy Estate
In the case of In re Jokiel, 447 B.R. 868 (Bankr. N.D. Ill. 2011), the debtor was employed when he filed his Chapter 7 case. A few months later he was notified that his employment would be terminated and that he would be receiving a severance payment from his former employer. The chapter 7 trustee filed a motion for the debtor to turn over the severance payments to the trustee, as the trustee considered the payment as part of his bankruptcy estate. The debtor responded that since he did not become entitled to the severance payment until after his case was filed, it was not part of the bankruptcy estate.
The bankruptcy court held that §541 of the Bankruptcy Code, which is the section that describes what constitutes property of the estate, should be interpreted very broadly. The court found that the severance payments were part of the debtor’s employment contract and was given to him as an incentive to sign the original employment contract. Accordingly, the court found that the severance was not for post-petition services performed by the debtor and was therefore part of his bankruptcy estate.
Laura J. Margulies is a principal in the firm of Laura Margulies & Associates, LLC. Our web site is located at: www.law-margulies.com. We represent consumers in bankruptcy and litigation matters in Maryland and the District of Columbia.
The bankruptcy court held that §541 of the Bankruptcy Code, which is the section that describes what constitutes property of the estate, should be interpreted very broadly. The court found that the severance payments were part of the debtor’s employment contract and was given to him as an incentive to sign the original employment contract. Accordingly, the court found that the severance was not for post-petition services performed by the debtor and was therefore part of his bankruptcy estate.
Laura J. Margulies is a principal in the firm of Laura Margulies & Associates, LLC. Our web site is located at: www.law-margulies.com. We represent consumers in bankruptcy and litigation matters in Maryland and the District of Columbia.
Tuesday, September 20, 2011
New Laws in Maryland Tighten Requirements for Creditors to Obtain Judgments Against People
The Maryland Court of Appeals just amended certain rules to protect consumers from paying on debts to creditors who are not really entitled to any payments. The new law will require creditors to demonstrate that they own the debt, that the statute of limitations to collect the debt has not expired and that they are licensed to operate business in Maryland.
The changes to Rules 3-306, 3-308 and 3-509 of the Maryland Rules take effect January 1, 2012. If the creditor wants to obtain a judgment against a debtor and does not want to have to appear in court, it can file a request for judgment with an Affidavit.. Under the new laws, the person making the affidavit must have personal knowledge of the facts contained in the affidavit and must be competent to testify about the facts. In addition, the affidavit must be accompanied by detailed evidence of liability, specifically indicating the amount claimed, any interest with an interest worksheet, and proof that the attorney’s fees sought are reasonable, along with authenticated copies of the documents on which the claim is based.
If the complaint is being brought by a collection agency, then the agency must provide the following: (1) proof of existence of the debt; (2) proof of the terms and conditions of the debt; (3) proof of ownership; (4) identification of the nature of the debt; (5) proof of entitlement to damages under the contract in the case of a future services contract; (6) pertinent account charge off information (statue of limitations); (7) pertinent non-charge off account information; and (8) identifications of all Maryland collection agency licenses currently held by the creditor.
A person being sued in Maryland still needs to file a notice of intent to defend and needs to appear in court. If the creditor has not submitted all the evidence required by these new rules, the creditor will not be able to obtain a judgment against the debtor. If the person does not file a notice to defend or does not appear in court, the judge may consider whether the creditor fulfilled its requirements under the new law and may or may not enter judgment in the creditor’s favor.
These laws should help people avoid having to pay for debts that are beyond the statute of limitations to collect, or pay for debts to an agency not licensed to collect the debt in Maryland, or where the creditor has no documents to prove the existence of the debt.
By: Laura J. Margulies and Ruth Clayton
Laura J. Margulies is a principal in the firm of Laura Margulies & Associates, LLC. Our web site is located at: www.law-margulies.com. We represent consumers in bankruptcy and litigation matters in Maryland and the District of Columbia.
The changes to Rules 3-306, 3-308 and 3-509 of the Maryland Rules take effect January 1, 2012. If the creditor wants to obtain a judgment against a debtor and does not want to have to appear in court, it can file a request for judgment with an Affidavit.. Under the new laws, the person making the affidavit must have personal knowledge of the facts contained in the affidavit and must be competent to testify about the facts. In addition, the affidavit must be accompanied by detailed evidence of liability, specifically indicating the amount claimed, any interest with an interest worksheet, and proof that the attorney’s fees sought are reasonable, along with authenticated copies of the documents on which the claim is based.
If the complaint is being brought by a collection agency, then the agency must provide the following: (1) proof of existence of the debt; (2) proof of the terms and conditions of the debt; (3) proof of ownership; (4) identification of the nature of the debt; (5) proof of entitlement to damages under the contract in the case of a future services contract; (6) pertinent account charge off information (statue of limitations); (7) pertinent non-charge off account information; and (8) identifications of all Maryland collection agency licenses currently held by the creditor.
A person being sued in Maryland still needs to file a notice of intent to defend and needs to appear in court. If the creditor has not submitted all the evidence required by these new rules, the creditor will not be able to obtain a judgment against the debtor. If the person does not file a notice to defend or does not appear in court, the judge may consider whether the creditor fulfilled its requirements under the new law and may or may not enter judgment in the creditor’s favor.
These laws should help people avoid having to pay for debts that are beyond the statute of limitations to collect, or pay for debts to an agency not licensed to collect the debt in Maryland, or where the creditor has no documents to prove the existence of the debt.
By: Laura J. Margulies and Ruth Clayton
Laura J. Margulies is a principal in the firm of Laura Margulies & Associates, LLC. Our web site is located at: www.law-margulies.com. We represent consumers in bankruptcy and litigation matters in Maryland and the District of Columbia.
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