Civil Action 11

“A good name is more desirable than great riches; to be esteemed is better than silver or gold.” - Proverb 22:1

Praises & Thanks be unto The Lord My God for the wisdom, knowledge and understanding on legal matter because I received countless feedbacks from folks facing foreclosure and bankruptcy around the United States as follows:

Comments: "I have been inundated with TILA questions. So I went out hunting to see if anyone had already written about it in terms that a lay person might be able to understand. What I found is shown below. I believe it to be generally correct and the citations are good citations of law. See this site for the entire write-up. It should give most lay people an idea on how to handle this and it will be valuable to your lawyer if he/she is not totally familiar with the TILA context at the following link:" http://rcxloan.com/Civil_Action_BK_Motion_14.htm. Statement made by Attorney at Law, Neil F. Garfield, M.B.A., J.D.

A STORY TO THINK ABOUT
“Once upon a time in the Ancient Roman Empire, 27 BC, there were two men living in Jerusalem. One was named Ameriquest-New Century-Chase Home Finance-Deutsche Bank National Trust, a rich man whose land was worth close to $700 billion in today‘s money; the other, Mr. Augustin, a farmer whose land was worth $300,000. One day, Ameriquest-New Century-Chase Home Finance-Deutsche Bank National Trust asked Mr. Augustin to give him his land, that he may have it for a vegetable garden. But, Mr. Augustin said to Ameriquest-New Century-Chase Home Finance-Deutsche Bank National Trust, “The Lord forbid me that I should give to you the inheritance of my fathers”.

When Jezebel, the wife of Ameriquest-New Century-Chase Home Finance-Deutsche Bank National Trust, heard what Mr. Augustin said to him. She said, don‘t worry love, I will take care of the matter? Arise, eat bread, and let your heart be joyful; I will give you Mr. Augustin‘s land. So, Jezebel wrote letters in Ameriquest-New Century-Chase Home Finance-Deutsche Bank National Trust’s name and seal them with his seal and sent letters to the elders and to the nobles who were living in Jerusalem. Now she wrote in the letters, saying, proclaim a ‘relief of stay trial’ in the absence of Mr. Augustin. Then, issued a decree that Mr. Augustin’s land is now Ameriquest-New Century-Chase Home Finance-Deutsche Bank National Trust.

So the men of Jerusalem, the elders and the nobles did as Jezebel had sent word to them, just as it was written in the letters which she had sent them. Ameriquest-New Century-Chase Home Finance-Deutsche Bank National Trust take possession of Mr. Augustin’s land which he had refused to give. The sad part is that Mr. Augustin was forced off his land illegally and fraudulently. Mr. Augustin left with nothing and forced to seek refuge from Jerusalem to a land called ‘Fairfax, Virginia’ to start from scratch. Whereas, Ameriquest-New Century-Chase Home Finance-Deutsche Bank National Trust became more wealthy with the unwarranted possession of his and hold more than $700 billion of assets as a result.

Questions? Why was Mr. Augustin absent in the relief of stay trial? Why did the elders and the nobles just do as Jezebel asked them? Let us all fast forward in 2008, what do you think the elders and the nobles should have done differently?”


---------------------------------------------

United States Federal District Court

Pierre Richard Augustin, PRO SE )

Debtor, )

v. ) C.A. No. 05-46957

) Chapter 7

DANVERSBANK, ET AL., )

DEBTOR’S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO TRUSTEE OBJECTION TO THE AMENDMENT OF DEBTOR’S SCHEDULES B and C & MOTION TO CORRECT AMENDED SCHEDULES DUE TO ERROR IN CITING LAW

1. Emancipation Redress

In America, no one is considered to be above the law. The United States Constitution is considered the supreme law of the land both because of its content and because its authority is derived from the people. However, first and foremost, debtor meditates and relies on the divine guidance of the almighty (Exhibit A (1st Amend. Right) to provide him with wisdom to dissect and to comprehend the meaning of the law of the land.

Debtor strongly believes in the transparency of the judicial system in the United States of America to uphold the law in the search of Justice. For, it is the only forum whereby an average ‘Joe’ citizen like himself who never had any infraction with the law, was left with the only viable option of bankruptcy and TILA rescission to protect his property rights as a defense to foreclosure without money, status and political connection in seeking the emancipation and the redress from the violation of the law by powerful corporations with unlimited budget represented by the most savvy lawyers on just about equal term.

Intuitively, debtor recognizes that he is facing lawyers that are well schooled with an in-depth knowledge of the law and various courtroom strategies that he lacks. Although not a lawyer or pretending to be one, debtor’s action is symmetrical to many pro se individual from the early settlers in the state of Massachusetts who could not afford expensive legal representation in the search of fairness, equal protection and justice under the law.

Unequivocally, the paramount reason for debtor’s motion to oppose Trustee’s objection and motion to amend schedules rest on the principle of Emancipation and Redress which are intertwined with his property rights as "the guardian of every other right". It is also analogous with the Federal Rule of Civil Procedure that state: “Leave should be freely given to amend complaint unless adverse party can prove prejudice, bad faith or dilatory intent. (Beeck v. Aquaslide, 562 F.2d 537 (8th Cir. 1977)). Also, as a pro se debtor, the court is supposed to judge the case based on its merits even if procedural errors are made.

In addition, Debtor’s motion is analogous to a pro se complaint facing potential dismissal for failure to state a claim (i.e. Rule 12(b)(6), if that (pro se) plaintiff obviously cannot prevail on the facts and , additionally, it would be futile to allow him to amend his complaint (Oxendine v. Kaplan, 241 F.3d 1272, 1275 (10th Cir. 2001); McKinney v. Oklahoma, 925 F.2d 363, 365 (10th Cir. 1991)), (a fair court will always let the plaintiff amend his complaint at least once), or in the case of Debtor, for leave to amend his schedule as authorized under Rule 1009.

Retrospectively, filing in Federal Bankruptcy & Civil Court is an extremely complex tasks that involves the mastery of unfamiliar concepts such as substantive law, procedures, forms, formats, terminology, service and legal research which at first create anxiety, confusion and panic for a pro se person like the Debtor without years of special training which led Debtor to correct motions on several instances due to serious “dumb” mistakes by not having a fully understanding of the meaning and interpretation of law in trying to do his reasonable best under the circumstances. Therefore, the court must give a pro se Debtor, “every favorable inference arising from his pro se status” (Hall v. Dworkin, 829 F. Supp. 1403, 1409 (ND NY 1993)).

Thus, debtor arguments are based on the following Rule of Law and others as deemed appropriate:

1) Rule 1009. Amendments of Voluntary Petitions, Lists, Schedules and Statements, (a) General right to amend. A voluntary petition, list, schedule, or statement may be amended by the debtor as a matter of course at any time before the case is closed. A debtor may amend schedules even after a discharge is granted so long as the case is not yet closed. (In re Michael, 163 F.3d 526, 529 (9th Cir. 1998)).

2) Rule 4003 (c) - Burden of Proof – Because a claimed exemption is presumptively valid, an objecting party must prove the exemption is not proper.

3) Rule 6009 provides Debtor the right to prosecute and defend cases without the need for bankruptcy court approval.

4) 1st Amendment, "Congress shall make no law … abridging … the right of the people … to petition the Government for a redress of grievances."

5) 5th Amendment, “No person shall be … deprived of life, liberty, or property, without due process of law”

6) 7th Amendment, “…The right of trial by jury shall be preserved.”

7) 14th Amendment, “No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.”

8) Natural Rights, “Weakness allures the ruffian, but arms, like laws, discourage and keep the invader and plunderer in awe, and preserve order in the world as well as property. Horrid mischief would ensue were the law-abiding citizens deprived of the use of them, and the weak will become a prey to the strong.” — Thomas Paine

9) Common Law, In Beard v. U.S.(158 U.S. 550, 1895), the Court approved the common law rule that a person "may repel force by force" in self-defense, and concluded that when attacked, a person "was entitled to stand his ground and meet any attack made upon him with a deadly weapon, in such a way and with such force" as needed to prevent "great bodily injury or death."

10) Pro Se Litigants, “Courts are particularly cautious while inspecting pleading prepared by Debtors who lack counsel and are proceeding pro se. Often inartful, and rarely compose to the standards expected of practicing attorneys, pro se pleadings are viewed with considerable liberality and are held to less stringent standards than those expected of pleadings drafted by lawyers”. (Antonelli v. Shehan, 81 F. 3d 1422, 1427 (7th Cir. 1996)). Also, “parties appearing pro se are allowed greater latitude with respect to reasonableness of their legal theories (Patterson V. Aiker, 111 F.R.D. 354, 358 [N.D. GA 1986]) and according to section D of Rule 11 of the Federal Rule of Civil Procedure.

2. Debtor’s property was exempted according to 11 U.S.C. §541(1), 11 U.S.C. §522(b)
The facts and circumstances are that Debtor had listed his house as exempt in the bankruptcy filing according to 11 U.S.C. §522(b). Debtor’s property listed as exempt has not been administered by the Trustee. Also, upon a phone conversation held with the office of the trustee on March 14, 2006, debtor was told that the Trustee has nothing to do with his property and to consult an attorney.

The issue is covered by a Rule of law 11 U.S.C. §541(1), 11 U.S.C. §522(b) and based on the Federal Rule of Bankruptcy Procedure of Rule 5009. Closing Chapter 7 Liquidation, which states, If in a chapter 7, chapter 12, or chapter 13 case the trustee has filed a final report and final account and has certified that the estate has been fully administered, and if within 30 days no objection has been filed by the United States trustee or a party in interest, there shall be a presumption that the estate has been fully administered.

Analysis – The fact helps to prove the rule since April 17, 2006, the Trustee filed a Trustee’s Report of No Distribution states as follows: “…has received no property nor paid any money on account of the estate except exempt property, and diligent inquiry having been made, trustee states that there is no nonexempt property available for distribution to creditors. Pursuant to FRB 5009, trustee certifies that the estate is fully administered and requests that the report be approved and the trustee discharged from any further duties. (Entered: 04/17/2006 at the Bankruptcy Court, District of Massachusetts)”.

Once the Trustee has filed a final report certifying that the estate has been fully administered, if no objection is filed within thirty days, there is a presumption that full administration has taken place regardless of whether the case is closed. Once the presumption is in place, all property scheduled which has not been administered is deemed abandoned. Also, the usual ground for abandonment is that the property is of no value to the estate. No actual hearing is required as long as the trustee gives proper notice, provided no party in interest makes a timely request for a hearing. Once the property is abandoned, title reverts to the debtor.

Conclusion - From the analysis, debtor comes to the Conclusion that the rules of law mentioned above are in order and the rules do apply to the facts and circumstances. Bankruptcy rules state that (a) After notice and a hearing, the trustee may abandon any property of the estate that is burdensome to the estate or that is of inconsequential value and benefit to the estate. The exception to that rule reflects Debtor’s situation as stated: (c) Unless the court orders otherwise, any property scheduled under section 521(1) of this title not otherwise administered at the time of the closing of a case is abandoned to the debtor and administered for purposes of section 350 of this title. On April 17, 2006, the Trustee filed a Report of No Distribution. Also, if the Trustee does not timely object to a claim of exemption, the property will be deemed exempt, even if there is no basis for the exemption. (Taylor v. Freeland & Kronz, 503 U.S. 638, 643-45 (1992)). (see docket # 94) (Fed. R. Bankr. P. 1009; In re Olson, 253 B.R. 73 (B.A.P. 9th Cir. 2000); see also In re Kaelin, 308 F. 3d 885 (8th Cir. 2002) (debtor who promptly amended to exempt cause of action after he first learned about it was permitted to claim exemption). Hence, Trustee’s motion to object should be denied.

3. Debtor’s motion to amend schedules should be allowed otherwise it would be an unjustice!

The facts and circumstances are that the Trustee concluded his motion by asking the court not to allow Debtor his undeniable right to amend schedules per Rule 1009. Such a request can be classified or rightfully label as an ‘Obstruction of Justice’ that is immoral and contrary to the rational application of the rule of law since if Debtor’s guaranteed rights are usurped, he would fall into the trap of being Judicial Estoppel by the court. The doctrine of judicial estoppel would bar the Debtor from asserting monetary claims if not properly disclosed to the bankruptcy court as Debtor has asserted by listing the claims and exempt it according to rule 4003.

The issue is covered or analogous by the Rule of law of 11 USC 522(b) which states notwithstanding section 541 of this title, an individual debtor may exempt from property of the estate the property listed in either paragraph (a)(1) or in the alternative paragraph (a)(2) and 11 USC 522 (c), (g) & (h).

An analogous argument can be made according to the [Senate Report. No. 95-989, 95th Cong. 2d Sess. 75 (1978).], subsection (l) which requires the debtor to file a list of property that he claims as exempt from property of the estate.

Rule 4003 requires that debtors claim their exemptions on the official Form, schedule C, property claimed as exempt and explicitly states that the burden of proof is upon the objecting party.

Rule 4003(a), Amended Exemptions. Debtor’s amendment of schedules to claim an exemption does not reopen the objection period as to assets already claimed exempt (In re Hickman, 157 B.R. 336 (Bankr. N.D. Ohio 1993)) like the one filed by the Debtor on July 3, 2006 (See Docket # 94).

Rule 4003(c) – While the objecting party must prove the exemptions are not properly claimed, the debtor has the initial burden to state the exemptions with sufficient particularity so that all parties are able to ascertain those properties the debtor believes to be exempt.

The Rule 6009 as stated above does not requires Debtor to have court approval necessarily to bring what Debtor consider as a natural right. If motion to object is granted, Trustee will ultimately retaliate against Debtor’s exempted property rights since Debtor equal protection under the law would be practically nonexistent, the rule of law would be made a mockery and that justice will not be served.

#1) On July 3, 2006, debtor filed a motion to amend schedule B & C which was allowed with “No Objection” by the bankruptcy court (See Docket # 94). Debtor cited his civil suit, case#: 06-10368, as an asset in Schedule B and exempted it in Schedule C. In page 2 (See Exhibit 1) of Debtor’s civil complaint, he stated that TILA was in of the Jurisdiction of all the claims against the creditors or defendants in that civil action. At #6 of page 14 (See Exhibit 2) of civil complaint, Debtor explicitly stated that the New Century Mortgage Note which is now assigned to Chase is in violation of TILA and Regulation Z claims. In page 17 of the civil complaint, Debtor did mention rescission and statutory damages (See Exhibit 3). In retrospect, Debtor states that there was absolutely no creditors objection to the motion to amend schedules and the motion was allowed by the bankruptcy court uncontested. Also, no creditors ever filed an appeal within the 10 days limit or beyond. Hence, the order entered by Judge Rosenthal (See docket #94) on July 19, 2006 was deemed final and unappealable.

Analysis of the above facts based on analogous situations, Res Judicata & Collateral Estoppel…

Debtor noted that res judicata bars the relitigation of previously litigated claims or causes of action and that four factors are examined to determine whether the doctrine of res judicata applies:

(1) identity of parties;

(2) identity in subject matter;

(3) the issues are the same and relate to the subject matter; and

(4) the capacities of the persons are identical in reference to both the subject matter and the issues between them.

Collateral estoppel bars relitigation of previously litigated issues and involves an analysis of four similar factors:

(1) whether the issue decided in the prior adjudication was identical with the issue presented in the present action;

(2) whether the prior adjudication resulted in a judgment on the merits;

(3) whether the party against whom collateral estoppel is asserted was a party or in privity with a party to the prior adjudication; and

(4) whether the party against whom collateral is asserted had a full and fair opportunity to litigate the issue in the prior proceeding. Federal res judicata and Collateral Estoppel do apply in this instance congruently. The Trustee or any other creditors should not be allowed to relitigate claims, which has been the subject of a previous final order. (Possehl v. Ossino, 28 Mass. App. Ct. 918 (1989), (FDIC v. Shearson-American Express Inc., 996 F.2d 493 (1st Cir. 1993)). The doctrine of res judicata clearly prohibit Trustee from relief to a final judgment that could have been objected by Trustee or any other creditors in the motion filed by Debtor on July 3, 2006. (See, In re McIntyre, 328 B.R. 356 (Bankr. D. Mass. 2005) 918 (1989), (FDIC v. Shearson-American Express Inc., 996 F.2d 493 (1st Cir. 1993)). The doctrine of res judicata clearly prohibit Trustee from relief to a final judgment that could have been objected by Trustee or any other creditors in the motion filed by Debtor on July 3, 2006. (See, In re McIntyre, 328 B.R. 356 (Bankr. D. Mass. 2005).

Res Judicata are applicable based on 3 factors: 1) a final judgment on the merits of an earlier suit, 2) sufficient identicality between the causes of action in the earlier action and 3) sufficient identicality between the parties, (In re Iannochino, 242 F.3d 36 (1st Cir. 2001)).

Hence, 1) Existence of Final Judgment: Final judgment was issued on July 19, 2006 by Judge Rosenthal which was not appealed timely per Bankruptcy rule 8002 that resulted as being final and unappealable, 2) Identicality of Issues: Rescission and Recoupment claims are an integral part of TILA and Regulation Z. Debtor simply reiterates the same fact cited on July 3, 2006 in its motion to amend schedules on September 21, 2006 which are identical to his civil pleading and [made a harmless error by adding a potential claim against Debtor for housing related issues as an asset and set it as exempt on schedule C by mistake and other related matter which should be classified on Schedule F, 3) Identicality of Parties: Trustee, other creditors and Debtor are parties in Debtor’s chapter 7 bankruptcy.

A further analysis will find that:
(1) there is a final judgment on the merits in a prior action (Final judgment was issued on July 19, 2006 by Judge Rosenthal);
(2) the second action is based on a different claim, but is based on an issue that was actually litigated an directly determined in a prior action, (Debtor made a harmless error by adding a potential claim against Debtor for housing issues as an asset and set it as exempt on schedule C by mistake which should be classified on schedule F)
(3) the party had a full and fair opportunity to litigate the issue in the first action and there are no circumstances that justify affording them a second opportunity to retry the issue. Neither the Trustee nor the Creditors objected to the motion to amend schedules filed on July 3, 2006 and rule on by the court on (See docket #94) on July 19, 2006.

Also, if the Trustee does not timely object to a claim of exemption, the property will be deemed exempt, even if there is no basis for the exemption. (Taylor v. Freeland & Kronz, 503 U.S. 638, 643-45 (1992)). (see docket # 94) (Fed. R. Bankr. P. 1009; In re Olson, 253 B.R. 73 (B.A.P. 9th Cir. 2000); see also In re Kaelin, 308 F. 3d 885 (8th Cir. 2002) (debtor who promptly amended to exempt cause of action after he first learned about it was permitted to claim exemption).

#2) Debtor stated the following in the 3rd Paragraph of page 2 of that Motion to amend schedules of July 3, 2006 as follows: “the paramount reason for Debtor’s amendment of schedules is in good faith based on a discovery while conducting legal research on Sunday, July 2, 2006 at around 6 p.m.. Thus, debtor’s amendment is analogous to the Equitable tolling which is a principle of tort law stating that a statute of limitations shall not bar a claim in cases where the Debtor, despite use of due diligence, could not or did not discover the injury until after the expiration of the limitations period. Likewise, despite debtor’s due diligence, Debtor was not aware of the fact that he had to amend his schedules to include a claim based on his action at the Massachusetts Federal Court for violations of debtor’s constitutional and federal rights in relation to his property”.

#3) Debtor stated on the 2nd paragraph of page 4 of the motion filed on July 3, 2006 as follows: “Debtor would like to amend Schedule B and C to include his claim at the U.S. District Court of Massachusetts that was authorized technically on April 3, 2006 after the Federal District court has screened the complaint in accordance to 28 USC § 1915 to determine if debtor’s action lacks an arguable basis either in law or in a fact, Neitzke v. Willliams, 490 U.S. 319, 325 (1989), or if the action fails to state a claim on which relief may be granted. Thus, debtor assumed that he had met the subject matter jurisdiction since his filing was not dismissed and he received the summons from the Federal District Court” that were served on the defendants.

It is also covered by section 522 (l) on ‘Timely Objection’; which is analogous to Trustee & Commonwealth position whereas, if the chapter 7 Trustee’s failure to object to exemption within the time provided in Rule 4003, it precludes Trustee from later attacking exemptions regardless of whether debtor has a colorable basis for claiming the exemptions. (Taylor v. Freeland & Kronz, 503 U.S. 638, 112 S. Ct. 1644, 118 L. Ed.2d 280, 26C.B.C.2d 487 (1992)).

The facts above help to prove that the Debtor alleged unequivocally that DanversBank, Ameriquest Mortgage, New Century Mortgage, Trustee & Commowealth have violated Federal and Massachusetts Law on Predatory Lending, TILA, HOEPA and others law. A debtor may amend schedules even after a discharge is granted so long as the case is not yet closed. (In re Michael, 163 F.3d 526, 529 (9th Cir. 1998)).

If claims are not discovered until later, the failure to schedule them initially is not fatal, because schedules may be amended and because there is rarely any prejudice to the creditor if schedules are amended during the case. (See Ryan Operations, Gen. P’ship v. Santiam-Midwest Lumber Co., 81 F. (3d Cir. 1996) (suit on claim not listed in bankruptcy schedules not barred by judicial estoppel, as debtor had not attempted to play fast and loose with rules and failure to list claim had not impact on bankruptcy case); Donato v. Metro. Life Ins. Co., 230 B.R. 418 (N.D. Cal. 1999) (failure to disclose lawsuit as an asset on schedules did not judicially estop debtor from pursuing it); Elliot v. ITT Corp., 150 B.R. 36 (N.D. Ill. 1992) (failure to initially schedule debt as disputed or note cause of action and failure to deal with it in prior chapter 13 cases which had been dismissed did not estop debtors from raising consumer protection claims creditor after those claims were discovered)).

Likewise, Debtor could not have reasonably discovered the concealed fact of TILA violations until September 17, 2006 (excusable neglect, inadvertence) (See Exhibit 4) at about 5 a.m. in reading the Truth-in-Lending book by the National Consumer Law Center whereby Debtor timely filed the schedules to reflect his better understanding of the TILA Act and Regulation Z to invoque the right of rescission. In cases where the trustee or a debtor-in-possession brings the action, the statute of limitations, if it had not expired as of the filing of the petition, would be extended until two years after the bankruptcy filing, (see Cunningham v. Healthco, 824 F. 2d 461 (5th Cir. 1987), see also Thomas v. GMAC Residential Funding Corp., 309 B.R. 453 (D. Md. 2004)).

A number of courts have held that the recovery in such an action must be paid in cash to the debtor/plaintiff and cannot be set off against a debt discharged in the bankruptcy. (In re Riggs, 623 F. 2d 68 (9th Cir. 1980); Newton v. Beneficial Fin. Co., 558 F. 2d 731 (5th Cir. 1977) (holding that Truth in Lending damages are meant to penalize the creditor and thus should always be assessed). Thus, since the security interest is automatically voided per TILA and Regulation Z upon rescission, the secured mortgage note is no longer secured and must be classified as unsecured in Debtor’s unsecured schedules of debts as well as be discharged as mandated under Debtor’s chapter 7 bankruptcy protection.

Conclusion - From the analysis, Debtor comes to the Conclusion that the rule of law does apply to the fact. Absent a showing of bad faith, the court may not deny leave to amend a schedule. Bad faith does not exist if there is no evidence to hide the asset.

When the debtor acted promptly to amend schedules after learning of the cause of action and there was no prejudice to creditors except the economic loss that occurs whenever property is claimed as exempt, in an analogous case, the lower courts erred in denying the debtor the right to amend. (Kaelin v. Bassett (In re Kaelin), 308 F.3d 885 (8th Cir. 2002) and in re Mourer, 287 B.R. 889 (Bankr. W.D. Mich. 2003), denying right to rescind when debtors did not list rescission claim as asset).

For the reasons mentioned above, debtor motion to list claim is timely and in line with the rule of law since the security interest is automatically voided per TILA and Regulation Z upon rescission, the secured mortgage note is no longer secured and must be classified as unsecured in Debtor’s unsecured schedules of debts as well as be discharged as mandated under Debtor’s chapter 7 bankruptcy protection. Hence, Trustee’s motion to object to debtor’s amendment of schedules should be denied.

CERTIFICATE OF SERVICE

I hereby certify that a true copy of the above document was delivered in person October 27, 2006 to US Bankruptcy Court, District of Massachusetts and served by United States Postal Mail, postage upon counsel for the creditors and defendants mailed on October 27, 2006.

X ____________________________________ Pierre R. Augustin

----------------------------------------

I can be reached for a FREE consultation at (cell) 617-202-8069 or (703) 584-5998,



it's FREE, there is no obligation whatsover...! Sincerely, Pierre R. Augustin, MPA, MBA

P.S. - What 3 friends do you know who would benefit from FREE Expert Loan Advice...!
1. Call and Speak with a Consultant, 1-617-202-8069 or (703) 584-5998, it's FREE!