A discussion of routine & complex issues which confront all types of shared ownership communities.

Condo and HOA Law Blog By Donna DiMaggio Berger, Esq.

Condo and HOA Law Blog By Donna DiMaggio Berger, Esq.
This blog covers every topic under the sun related to condominiums, cooperatives, HOAs, timeshares and mobile home communities from the unique perspective of attorney Donna DiMaggio Berger.

Wednesday, March 30, 2011

MID-SESSION CHECK-UP

The budget has dominated conversations in Tallahassee this session, as the legislature struggles to meet its only constitutionally mandated obligation: pass a balanced budget. Frustratingly, although not surprisingly, the House released its plan late last week, which included draining the Division of Condominium, Timeshares and Mobile Homes’ trust fund. If approved, this would make the fourth year in a row the funds have been swept, totaling more than $26 million.

Despite the budget focus, there is a lot of action on the substantive front. After next week there will be only three more opportunities for bills to be voted on in committee. Although it may appear that this would mean that most of the 20+ bills affecting community associations are in trouble (because they are assigned to be voted on in at least 3 or more committees) they are far from being put in the “life support” category.

As long as a Senate bill has had one committee vote, it can bypass its other committees and be amended onto other bills. The House’s procedures are even more flexible; they have and can pass legislation that has never been voted on in a single house committee.

Thirteen Senate bills that would impact or be of interest to community associations have been heard in their first committee, with several more likely to be heard next week. Now is the time to be vigilant in monitoring the movements of all these pieces. Below is a brief summary of key legislation. Full summaries and updates on all community association bills are available on CAN’s website: www.canfl.com

The deregulation bill (HB 5005), which at this point has no community association language in it, is up for a vote in its final House committee today. There is still no companion bill in the Senate.

CAN’s substantive legislative package (SB 1516/HB 1195) has been merged with an association “glitch” bill. Thanks to Sen. Jeremy Ring and Rep. George Moraitis, this bill appears to have legs and has a good chance of making its way to the Governor’s desk. The legislation would, among other items, prevent convicted felons and delinquent homeowners from serving as HOA board members, clarify whether suspended owners count towards a quorum, as well as clarify that tenants of delinquent owners will pay full rent to the association until the delinquent owner’s account is current. For a full analysis of this bill, go to CAN’s website: www.canfl.com

Property and Casualty Insurance legislation (SB408/HB 803) is ready for a vote before the full Senate. This bill would, among other things, limit the amount an insurer must pay initially to repair a home or replace personal items that have been damaged; would allows insurers to cancel or renew policies with 45 days notice if regulators determine the cancellation is necessary to protect the best interests of the public or policy holders; contains sinkhole provisions and would revise rate increases for reinsurance.

If you live in a community association, the best thing you can do is to be informed and stay involved in the legislative processes that will impact your home and your community.

>> Click here for QUICK LEGISLATOR CONTACT INFO for your Zip Code

Monday, March 28, 2011

Division Trust Fund may be raided even after Division escapes elimination

While everyone at the Division of Florida Condominiums, Timeshares and Mobile Homes is likely to be breathing a sigh of relief after last week’s action removing them from the grasp of HB 5005 deregulation, the latest challenge to association owners was reflected in the Florida House’s first draft of its budget.

The Florida House released its draft budget late last week and on page 360, it reflects that $6.2 million from the Division’s Trust Fund will be swept into the State School Trust Fund. This certainly isn’t a new story since the Condominium Trust Fund has been routinely raided over the years to make up for budget shortfalls elsewhere. The Senate has not yet released the first draft of its budget but if it matches the House version in this regard, it is very likely that the funds which condominium and cooperative owners paid into the Fund will not be used for the purposes they expected.

This begs the question: how will the Division fund its arbitration and educational programs as well as the Ombudsman’s Tallahassee and Broward County Offices? How worried do the 118 full-time Division employees need to feel about seeing their paychecks each week?

Why does the Florida Legislature insist that association owners’ approval be sought and obtained prior to a board using reserve funds collected from those owners for purposes other than that for which they were collected? Because that is seen as the “fair” thing to do as it is the owners money and having reserves on hand to fund needed maintenanced and repairs is the prudent course of action.

How then can those same legislators justify raiding the Division Trust Fund?

When was the last time you wrote your legislators or Governor and asked them not to use the funds you paid in to the Division Trust Fund for other, much different purposes?

>> Click here for QUICK LEGISLATOR CONTACT INFO for your Zip Code

This work by Donna DiMaggio Berger, Esq. is licensed under a Creative Commons Attribution-NoDerivs 3.0 Generic License.

Wednesday, March 23, 2011

A well-informed and organized group of Floridians can make a difference in the process!

On the 13th day of the 2011 Florida Legislative Session, House leaders proposed draconian deregulation measures for Condominiums, Cooperatives, Timeshares, Mobile homes, as well as Homeowners’ Association and Community Association Managers. Almost two weeks after the deadline to file legislation, legislators bypassed standard procedural rules and attempted to fast track these changes using special budget rules.

My group, the Community Advocacy Network (CAN), immediately notified our 3,000 member associations of the attempt to quickly strip homeowners of critical consumer protections. Within hours, legislators’ phone lines were lighting up and their inboxes were flooded with e-mails from homeowners expressing their complaints and requesting meetings.

Within a day of our members taking action, legislators were calling CAN asking for more information on our position. We quickly armed our members with concise talking points, thorough analyses and a strategic plan to defeat this attack on community associations. Our members’ swift action made their voices heard in Tallahassee before the measure got too far along and legislators were in a position where they could not go back. Other groups out there similarly mobilized to defeat this bill.

Exactly a week later, the community association provisions were stripped from the bill.

I could not be more proud of our members and the other groups and individuals around the State who joined in this fight.

In addition to stripping homeowners of important consumer protections, the legislation would have put them on the hook for expensive legal costs by eliminating the state’s arbitration program and forcing them to the courts to seek remedy. The plan also would have reverted more than $6 million dollars in fees paid by owners to the state’s general budget fund.

We had been gearing up for a lengthy battle but this quick defeat shows how a well-informed and organized group of Floridians can make a difference in the process.

This work by Donna DiMaggio Berger, Esq. is licensed under a Creative Commons Attribution-NoDerivs 3.0 Generic License.

Tuesday, March 22, 2011

Why should an association monitor a bank foreclosure action?

In order for lenders to enjoy a statuory cap on liability for past due assessments owed to community associations, they must name those associations as defendants in the lender foreclosure actions. At that point, associations must make a decision to answer the complaint or simply ignore a lawsuit to which they are a named defendant.

As an attorney, I could never recommend that anyone named in a lawsuit simply ignore that action. However, many associations take the position that since the association's lien is subordinate to the lender's there is no reason to get involved in the lender's action. Right? Absolutely not.

If the association does not at least answer and monitor the progress of the lender's lawsuit, the lender may obtain a judgment that prevents the association from enforcing its statutory rights including the collection of the lesser of 12 months past due assessments or 1% of the original mortgage debt.

In the current economic climate, it might also be advisable for associations to take affirmative action within these mortgage foreclosure cases to bring them to a faster conclusion. Alternatively, if the association is renting out a property that it acquired in its own foreclosure action (or is collecting rent pursuant to the new statutes), it may wish to defend itself in the lender's action to actually prolong the process in order to continue collecting rent to recoup past due amounts owed.

Lastly, where the association has its own pending foreclosure action against an owner, it is important to monitor the lender's foreclosure action to determine the feasibility of moving the association's action forward in light of the bank stalling.

If an association does not allow its attorney to answer and monitor a lender's foreclosure action, it may waive many of the rights and options otherwise available. The benefits of preserving these rights and options generally outweigh the attorney's fees and costs incurred by the association. Furthermore, if the association allows counsel to monitor the lender's foreclosure action, the association's attorney will receive copies of all pleadings filed in the case. This is important to keep the association apprised as to the status of the case and especially its conclusion so that a demand for statutory past-due assessments can be made promptly.

Think twice before telling your attorney to ignore those lender foreclosure actions in your community!

This work by Donna DiMaggio Berger, Esq. is licensed under a Creative Commons Attribution-NoDerivs 3.0 Generic License.

Monday, March 21, 2011

Where will the funds in the Division Trust Fund go?

I just received verification that the current cash balance in the Division Trust Fund as of Friday, March 18, 2011, is $9,802,864.06.

Section 718.501 of the Condominium Act provides as follows:

Each condominium association which operates more than two units shall pay to the division an annual fee in the amount of $4 for each residential unit in condominiums operated by the association. If the fee is not paid by March 1, the association shall be assessed a penalty of 10 percent of the amount due, and the association will not have standing to maintain or defend any action in the courts of this state until the amount due, plus any penalty, is paid.

Section 719.501(2)(a)of the Cooperative Act provides the same thing.

If HB 5005 passes with the community association provisions intact, the Division will be eliminated and we have been told that the almost $10 million in the Trust Fund will go into the State's General Revenue. In addition, if HB 5005 passes with the condominium provisions intact, 118 full-time Division employees will lose their jobs.

Currently, the Division is organized under two units: the Bureau of Standards and Registration and the Bureau of Compliance. The Bureau of Standards and Registration reviews and approves all public disclosure documents prepared by those who offer condominiums, cooperatives, timeshares and leased spaces in mobile home parks for sale to the public. The Bureau of Compliance ensures compliance with statutory and administrative rule requirements, primarily through the receipt and resolution of complaints filed with the Division. The Division has offices in Tallahassee, Tampa, Orlando and Ft. Lauderdale to carry out these functions.

Currently, the Division defines disputes eligible for arbitration as any disagreement between two or more parties and the authority of the board of directors or the association's governing documents. Disputes involving the board's failures related to elections, properly noticing meetings, properly conducting meetings and allowing inspection of the association's books and records.

I have been told that some association attorneys out there are actually in favor of deregulating the Community Association Management industry as well as eliminating the Division's arbitration function. That makes sense since both cut down on the number of cases that wind up in court. Take away the oversight and the alternative dispute resolution and you are forced to resolve these matters in court.

My law firm and our Community Advocacy Network (CAN) strongly oppose both attempts at deregulation for associations and managers since the most vulnerable communities will be the ones hardest hit should this bill pass.

This work by Donna DiMaggio Berger, Esq. is licensed under a Creative Commons Attribution-NoDerivs 3.0 Generic License.

Florida’s Deregulation Bill is on a Fast Track!

The Legislature’s attempt to deregulate many professions in our State has already passed one committee, is headed to the House Economic Committee this week and is gaining speed rather than slowing down despite public outcry.

At a whopping 318 pages, the Florida Deregulation bill is now HB 5005 which number indicates that this is an “implementing bill”. Implementing bills are essentially instructions on how budget guidelines will be met. By moving this proposal to the budget side of the process, the rules change from those that govern “substantive policy” legislation.

After Senate and House members meet to hash out the budget items, they deliver identical pieces of legislation to their respective bodies. This includes the overall budget and the implementing bills which make the statutory changes needed to achieve the budget policies. An implementing bill does not need to go through the Senate committee process. If Senate and House members agree to the bill during the appropriations conference, HB 5005 will go directly to the Senate floor for a vote by the full Senate. This bill could become law effective July 1, 2011, without ever having had a substantive hearing in even a single Senate Committee!

What does all this mean? HB 5005 just got a LOT easier to pass this Session.

The Community Advocacy Network (CAN), of which I serve as Executive Director and fellow blogger Charlotte Greenbarg, serves as one of our Broward County Advisory Council members, has been leading a massive grassroots campaign to stop this bill from negatively impacting the more than 55,000 community associations in our State and the millions of Floridians who call those communities home.

What don’t we like about HB 5005?
• Community association provisions do not belong in HB 5005.

• Unlike other affected industries in this bill, community associations are NOT for-profit businesses; they are not-for-profit organizations.

• The regulations in the community association industry differ significantly from regulations in for-profit industries. Not-for-profit regulations are not barriers to competition. The sole purpose of these regulations is to protect Floridians living in these communities, many of whom are seniors.

• Community association regulations ensure transparency, accountability and fairness when dealing with people’s homes and money.

• Removing critical consumer protections will simply leave homeowners more vulnerable to fraud and on the hook for expensive legal costs.

• Despite assertions to the contrary, these provisions WILL have a fiscal impact on the State. The net effect of Florida’s arbitration program for condominiums is a reduction in costs to the Judiciary. Years ago, judges pushed to have the Division handle these cases via arbitration because their dockets were filled with “condo commando” disputes which have since been handled less expensively by the Division.

To contact your Florida legislators now about HB 5005, go to http://www.flsenate.gov/Senators/Find and type in your zip code to find the name, phone number and email of your State Senator. You’ll also see your local House District number, click through on “State House” and find your Representative, click on his or her name and contact him or her about HB 5005. If you haven’t already made your opinion known on this attempt to deregulate associations, what are you waiting for?

For more information about what CAN is doing to fight this bill, please visit our website at www.canfl.com or contact my Legislative Assistant, Kristen Pesicek, at kpesicek@kgblawfirm.com.

This work by Donna DiMaggio Berger, Esq. is licensed under a Creative Commons Attribution-NoDerivs 3.0 Generic License.

Thursday, March 17, 2011

Where Does the Deregulation Bill, HB 5005, Go From Here?

The Florida 281-page Deregulation bill is now HB 5005; this bill number indicates that this is an "implementing bill". Implementing bills are essentially instructions on how budget guidelines will be met.

By moving this proposal to the budget side of the process, the rules change from those that govern “substantive policy” legislation. After Senate and House members meet to hash out the budget items, they deliver identical pieces of legislation to their respective bodies. This includes the overall budget and the implementing bills which make the statutory changes needed to achieve the budget policies. An implementing bill does not need to go through the standard Senate committee process. If Senate and House legislators agree to the bill during the appropriations conference, the bill will go directly to the Senate floor for a vote by the full Senate.

What does all this mean? HB 5005 just got a LOT easier to pass this Session. Here is the Community Advocacy Network's position on HB 5005:
• Community Association provisions do not belong in HB 5005.

• Unlike other affected industries in this 318 page bill, Community Associations are NOT for-profit businesses; they are not-for-profit organizations.

• The regulations in the community association industry differ significantly from regulations in for-profit industries. Not-for-profit regulations are not barriers to competition. The sole purpose of these regulations is to protect Floridians living in these communities, most of whom are seniors.

• Community Association regulations ensure transparency, accountability and fairness when dealing with people’s homes and money.

• Removing critical consumer protections will simply leave homeowners more vulnerable to fraud and on the hook for expensive legal costs.

• These provisions WILL have a fiscal impact on the state. The net effect of Florida’s arbitration program for condominiums is a reduction in costs to the judiciary. Years ago, judges pushed to have the Division handle the arbitrations because their dockets were filled with "condo commando" disputes, which were more effectively and less expensively handled in arbitration.

To read the Staff Analysis on HB 5005, please click this link:
http://www.canfl.com/Documents/Staff%20Analysis_11_01.pdf

This work by Donna DiMaggio Berger, Esq. is licensed under a Creative Commons Attribution-NoDerivs 3.0 Generic License.

Wednesday, March 16, 2011

Which Professions Will Be Deregulated by PCB 11-01?

The Department of Business and Professional Regulation (DBPR) issues more than 200 distinct license types and regulates twenty-four professions and multiple industries. The DBPR distributes its regulatory responsibilities across nine divisions and one commission, including:
• Division of Alcoholic Beverages and Tobacco
• Division of Certified Public Accounting
• Division of Florida Condominiums, Timeshares and Mobile Homes
• Division of Hotels and Restaurants
• Division of Pari-Mutuel Wagering
• Division of Professions
• Division of Real Estate
• Division of Regulation
• Division of Service Operations
• Florida State Boxing Commission

PCB 11-01 calls for the deregulation of the following professions, businesses and occupations:
• Athlete Agents
• Auctioneers and Auctioneer Apprentices
• Barbers (since been removed from the bill)
• Charitable Organizations
• Community Association Managers and Firms
• Condominiums, Cooperatives, Timeshares and Mobile Home Parks
• Cosmetology Specialists, including Hair Braiders, Hair Wrappers, Body Wrappers, Manicurists, Pedicurists and Nail Extensions (since removed from the bill)
• Dance Studios
• Employee Leasing Companies
• Professional Geologists
• Health Studios
• Home Inspectors
• Homeowners Associations
• Interior Designers
• Intrastate Movers
• Mold-Related Services
• Motor Vehicle Repair Shops
• Sellers of Travel
• Surveyors and Mappers
• Talent Agents
• Telemarketing
• Yacht and Ship Brokers

The bill also repeals State Regulations pertaining to:
• Transportation access to outdoor theaters
• Roominghouses
• Sales representative contracts involving commissions
• Television tube labeling
• Water vending machines

Commentary in the bill's first airing on Tuesday resulted in a question as to where the funds currently being held in the Division of Florida Condominium's Trust Fund will go once the Division is eliminated. The answer: into General Revenue and certainly not returned to the association owners who paid into the fund in the first place.

Does any of this give you pause?

This work by Donna DiMaggio Berger, Esq. is licensed under a Creative Commons Attribution-NoDerivs 3.0 Generic License.

Monday, March 14, 2011

New bill could eliminate the Division of Florida Condominiums and regulation of community association managers!

I was fortunate to be invited as a guest last week at the Broward Workshop’s State of the County address where Governor Rick Scott was the keynote speaker. Governor Scott talked about running our State the way a CEO would run a successful company. As such, he talked about eliminating non-productive assets or services that he does not see as being core functions of the State as well as controlling costs. He promptly sold off the state-owned planes and abolished several offices he saw as being non-productive or inane.

I was not entirely surprised to learn later that same day that a 281-page monster deregulation bill is awaiting its first airing on Tuesday, March 15th at 8:00 am in front of the House Business and Consumer Affairs Subcommittee. Among other things, PCB BCAS 11-01 deletes the provisions which established the Division of Florida Condominiums, Timeshares and Mobile Homes as one of the many divisions within the Department of Business and Professional Regulation (DBPR).

This Proposed Committee Bill (PCB) would also significantly change items that were previously regulated by the Division including, among other items, removing the prohibition against directors, officers and managers accepting items of value from community vendors; removing the civil penalty for those persons who knowingly or intentionally deface or destroy accounting records which must be created or maintained; deleting the requirement to provide a financial report to unit owners; removing the requirement that developers submit advertising materials to the Division.

In addition, this PCB would also repeal Part VIII of Chapter 468 of the Florida Statutes which relates to the licensure and regulation of Community Association Managers and management firms as well as the Regulatory Council of Community Association Managers. In recent years, we have taken steps to impose tighter regulation of those individuals and firms who provide management services to the more than 55,000 associations in our State. The prevailing school of thought has been that there must be even stricter oversight of the individuals entrusted with managing large budgets and issues for the millions of Floridians living in these communities.

This 281-page bill removes the licensing required for occupations ranging from mold remediators to certain types of cosmetologists. If this bill is any indication, the assessment of what is and is not a “core function” of Florida’s regulatory powers cut across a wide swath of our society!

While I have heard from many folks who feel that the Division of Florida Condominiums, Timeshares and Mobile Homes is an ineffective organization incapable of resolving disputes in a timelyor satisfactory manner, the question here is what is the “Plan B” in place for the void that will result when all State regulation is gone?

There appears to be no successor agency in place to take over the current duties of the Division should this bill pass in its current form. Would this spell a return to the only recourse for association disputes resting with the courts? Perhaps that is exactly what is intended and the State no longer wishes to be involved in association squabbles?

What say you? Are you in favor of total deregulation of the Community Association Management industry as well as eliminating the Division of Florida Condominiums, Timeshares and Mobile Homes?

This work by Donna DiMaggio Berger, Esq. is licensed under a Creative Commons Attribution-NoDerivs 3.0 Generic License.

Thursday, March 10, 2011

Have you had your property inspected for possible wind mitigation credits?

Are you aware that Section 627.0629 of the Florida Statutes requires insurance companies to offer Florida homeowners "discounts, credits, or other rate differentials" for construction techniques that reduce damage and loss in windstorms?
This program pertains to all single family homes, condominiums, villas and other multi-family buildings.

The items which are subject to inspection for such credits or discounts are those that enhance roof strength, roof covering performance, roof-to-wall strength,wall-to-floor foundation strength, opening protection and window, door and skylight strength.

Several years ago, my husband and I had our roof (a Hip design), windows, garage door, gable bracing and roof deck fasteners inspected and our insurance premium with Liberty Mutual was reduced by $3,000 at that time as a result of the Mitigation Certificate we received; the savings continue each year since our base premium was reduced. The inspection itself cost us less than $200.00. It really was the gift that keeps giving and until a neighbor had mentioned that these credits were available if our home's construction met the various guidelines, we were unaware of the potential to save on our windstorm premium.

I suspect that most folks do not know that there is an ability to inspect their homes and their condominium building to apply for these wind mitigation credits from their insurance company. They might similarly not know that every insurance company operating in our State is required to include "actuarially reasonable discounts, credits, or other rate diffrentials or appropriate reductions in deductibles for properties on which fixtures or construction techniques demonstrated to reduce the amount of loss in a windstorm have been installed or implemented."

If you have not already discussed these inspections and credits with your insurance agent, now is the time to do so.

This work by Donna DiMaggio Berger, Esq. is licensed under a Creative Commons Attribution-NoDerivs 3.0 Generic License.

Monday, March 07, 2011

Complications and delays associated with delinquent association members’ filing for bankruptcy protection

Most people know that an owner filing for bankruptcy protection delays and complicates an association’s attempt to collect past-due assessments from that owner. Last year, Florida was second only to the state of California in terms of the number of bankruptcy cases filed with 11,000 Florida filings.

There is a lot to know about the basic mechanics of bankruptcy and what associations can and can’t do when an owner files for such protection. It is crucial that every association contact its attorney for direction on how and when to proceed when confronted with a delinquent owner filing for bankruptcy protection. There are three methods by which an individual can file for bankruptcy: Chapter 7, Chapter 11 and Chapter 13 of the United States Code (USC). Each of these chapters offers unique benefits and burdens to Debtors and Creditors alike such as:

• Chapter 7: Duration of Bankruptcy: Between three and six months. Benefits for Debtor: the Debtor’s personal liability relating to Pre-Petition Assessments is very likely to be extinguished in a matter of months rather than years. Benefits to the Creditor: the Creditor’s lien for Pre-Petition Assessments is likely to remain fully intact, thereby allowing the Association to foreclose on the unit owner unless the Owner satisfies the Association’s lien.

• Chapter 11: Duration of Bankruptcy: several years (varies). Benefits for Debtor: allows high-net worth individuals to reorganize their financial lives through a Bankruptcy Plan. Unlike Chapter 13 Plans, Chapter 11 Plans are generally not overseen by a Trustee. While an individual can file under Chapter 11, most don’t. Benefits to the Creditor: allows an Association holding an undersecured lien to have its claim treated as secured-in-full. Under a Chapter 11 Plan, the debtor could be forced to pay the full Pre-Petition Delinquency whereas the lien would have likely been stripped down to the present valoue of the collateral under either a Chapter 7 or 13 case.

• Chapter 13: Duration of Bankruptcy: Between three and five years. Benefits for Debtor: affords the debtor several years to stall the Association’s lien before a foreclosure action may be resumed. Benefits to the Creditor: if the debtor fails to make his or her scheduled payments to the Association, as set forth by the Chapter 13 Plan, the entire Chapter 13 case may be dismissed, thereby subjecting the owner to liability on claims held by all Pre and Post Petition Creditors.

Upon filing for bankruptcy protection under any of these chapters, a period of forebearance known as the Automatic Stay goes into effect. The Automatic Stay is an injunction that arises by operation of law, without the need for a court order, which automatically bars creditors from initiating or continuing with efforts to collect or enforce secured or unsecured debts or to enforce claims against estate property. With associations’ new statutory authority to collect rent from tenants in delinquent properties as well as to suspend certain use rights of delinquent owners, it is critical that an association discuss with counsel whether or not it is permitted to continue with such actions once a Petition for Bankruptcy Protection has been filed.

Attorneys for most associations will file a Motion for Relief from Stay in Chapter 11 and Chapter 13 filings asking the Bankruptcy Court to allow the association to proceed with its collection efforts. Once Stay Relief is granted, the Court effectively removes the collateral from the Debtor’s Bankruptcy Estate. Most Chapter 7 bankruptcies are “no asset” cases meaning the debtor will be surrendering the property, thereby placing the association in a position to foreclose and take title to the property. If the Association does take title, it will be required to write off Pre-Petition Assessments owed. Due to the shorter duration of a Chapter 7 bankruptcy, the costs involved with filing a Motion for Relief from Stay may not make sense.

The concepts discussed herein are just the “tip of the iceberg” when it comes to the complications and delays that arise when a delinquent owner in a community association files for bankruptcy protection. It is absolutely essential that associations speak with counsel experienced in the very specialized area of bankruptcy law to know what can and can’t be done with the association’s ongoing collection efforts.

This work by Donna DiMaggio Berger, Esq. is licensed under a Creative Commons Attribution-NoDerivs 3.0 Generic License.

ShareThis