Limits on Garnishment

If you are currently being garnished, the first you need to know is whether there is a limit on that garnishment.  Is the creditor taking too much?  Do they even have a right to garnish you at all?  What options do you have if you’ve been hit by a garnishment?

Garnishment Defined

A “garnishment” occurs when one of your creditors sues you, wins, and then gets the court to take part of your wages to satisfy the debt.  Unless you file bankruptcy or convince the judge why a lesser amount should be allowed, the creditor may be able to take up to 25% of your disposable income or the amount of the disposable earnings that exceed 30 times the federal minimum hourly wage – whichever is less.

Who can garnish my wages?

Virtually any type of creditor possesses the ability to garnish your wages.  Banks or credit unions, credit card companies, and, most commonly in Southern Indiana, medical bill collectors all enjoy access to the same legal framework that allows them to garnish your wages.  Shockingly, the Consumer Financial Protection Bureau released a report in 2014 showing that 43 million Americans have unpaid medical bills on their credit reports.

In the event child support or alimony is owed, the creditor can be a legal guardian or ex-spouse.  Moreover, a child support or alimony creditor may garnish up 65% of your wages for payment of past due child support or alimony.

What constitutes wages?

“Wages” initially meant money that you received from your pay check.  That term has evolved to apply to whole range of types of income.  “Wages” is currently defined by the Indiana Legislature as “wages, commissions, income, rents, or profits remaining after the deduction from those earnings of amounts required by law to be withheld”.

Federal and state courts have further expanded and limited the applicability of this wage garnishment statute.

Example of expansion of state wage garnishment statute

When the statute was first enacted into Indiana state law, creditors disputed that it applied in bankruptcy proceedings.  Hypothetically, debtors enjoyed more protection of their wages outside of bankruptcy than inside of bankruptcy.  Bankruptcy judges found this to inconsistent with the “spirit” of the state wage garnishment exemption so debtors can now exempt their wages within bankruptcy, too.

Many courts have also ruled that your creditor cannot use contempt against you as a way to force you to repeatedly attend hearings related to the garnishment.  The courts have held that this practice basically amounts to putting someone in jail because they owe money to a private creditor.

Example of limits of state wage garnishment statute

Multiple courts have found that the wage garnishment statute applies only in civil proceedings.  This means that if you are prosecuted criminally and ordered to pay criminal restitution to your victim or the state, the 25% cap on wage garnishment does not apply to you and you can be forced to pay more.  Bankruptcy can, however, reorganize that debt to allow you pay it off in a more manageable way.

Sole proprietorships also need to exercise caution where garnishments are concerned.  Courts have come out and said that if you are a sole proprietorship and you alone decide when and how much to pay yourself, then you don’t get that protection.  The court’s opinion did speculate, though, that if you could show a history of paying yourself on a schedule based on some predetermined formula that you would likely get to use the wage exemption statute.  The bottom line is that it needs to be a set periodic payment.

In that same vein, courts have also found that 1099 income paid out to subcontractors may qualify as wages.

Those in the education/teaching profession have also run into some (more) bad luck.  A recent ruling found that the escrow account set aside for some teachers who elect to be 12-month employees so they can get paid in the summer does not constitute “wages” and can be completely taken.

Bonuses and severance packages also fall into this category.  This is, again, because the court looks to determine whether the income is received “periodically”.  If not, then no exemption.

How to stop a garnishment?

The first and most obvious option is to just pay off the debt.  However, if that were really an option, you wouldn’t be reading this article to begin with.  The second option, which I don’t really consider an option at all, is to do nothing.  Sure, eventually you may pay off the debt and that one creditor won’t be garnishing you any more; but you won’t be able to pay your car note, or your rent or mortgage and then those fall behind and you’re in real trouble.  Also, how many other creditors will be waiting in the wings to swoop in with the next garnishment?  The last, least expensive and most effective option is bankruptcyChapter 7 Bankruptcy or Chapter 13 Bankruptcy each have the power to stop garnishment and get you a fresh start.

Where Do I File Bankruptcy?

Where you file bankruptcy is usually a relatively simple question to answer.  The bankruptcy code applies to every state and most territories across the nation.  Typically, it is just a matter of identifying the closest bankruptcy division and selecting an attorney.

Federal Bankruptcy Structure

Federal bankruptcy courts essentially mirror the federal district court system.  The federal district courts have original and exclusive jurisdiction over all cases arising under the bankruptcy code.   Federal code 28 U.S.C. § 157(b)(1) “refers” bankruptcies filed in the district over to the bankruptcy court.  Fortunately, Congress thought it wise to create separate bankruptcy-specific courts due to the complexity and volume of bankruptcy filings.

Where to File Bankruptcy – Hierarchy

From Top to Bottom

The top of the federal court system consists of the United States Supreme Court.  This is where all final judicial decisions are rendered.  It is the end of the line for any controversy that arises under federal law or when two separate state laws or parties conflict.

Below the United States Supreme Court lie the U.S. District Courts.  There are currently 94 federal district courts that are grouped by state into 11 U.S. Courts of Appeal.  There is one additional Federal District Court of Appeal that has national jurisdiction and hears matters such as patent law and international trade.

Immediately below the U.S. District Court is the Bankruptcy Court.  For example, Indiana has two U.S. District Courts – the Northern District of Indiana and the Southern District of Indiana.  Each District then has it own Bankruptcy Court.  These jurisdictions are further subdivided into individual Divisions.

The Southern District of Indiana consists of the Evansville Division, Terre Haute Division, New Albany Division and the Indianapolis Division.

Which Division Applies

The Division in which you file bankruptcy is based on the county in which you reside.

Evansville Bankruptcy Court

If you live in Daviess, Dubois, Gibson, Martin, Perry, Pike, Posey, Spencer, Vanderburgh or Warrick County, you would file your bankruptcy in the Evansville Division.

Terre Haute Bankruptcy Court

If you live in Clay, Greene, Knox, Owen, Parke, Putnam, Sullivan, Vermillion or Vigo County, you would file your bankruptcy in the Terre Haute Division

New Albany Bankruptcy Court

If you live in Clark, Crawford, Dearborn, Floyd, Harrison, Jackson, Jefferson, Jennings, Lawrence, Ohio, Orange, Ripley, Scott, Switzerland or Washington County, you would file your bankruptcy in the New Albany Division.

Indianapolis Bankruptcy Court

If you live in Bartholomew, Boone, Brown, Clinton, Decatur, Delaware, Fayette, Fountain, Franklin, Hamilton, Hancock, Hendricks, Henry, Howard, Johnson, Madison, Marion, Monroe, Montgomery, Morgan, Randolph, Rush, Shelby, Tipton, Union or Wayne County, you would file your bankruptcy in the Indianapolis Division.

Where to File Bankruptcy Has Exceptions

This is the structure of the system that dictates which jurisdiction/division you will file under.  Fortunately, as long as you hire a bankruptcy lawyer, your lawyer is able to file your bankruptcy electronically and there is no need to physically deliver anything to one of these courts.  As with anything related to the law, there are exceptions to these general rules.  Naturally, you should consult with a qualified bankruptcy lawyer before assuming that you will be filing in one bankruptcy court or another.

 

How to Stop Garnishment

If you have ever had to ask yourself “how do I stop garnishment” then you probably know that a garnishment can be one of the most devastating financial events a person can go through.  You work all week looking forward to your paycheck.  You have bills to pay, groceries to pick up and gas to put in your car so you can get to work next week.  All of a sudden, you see your pay stub or bank account balance and realize that something isn’t right.  You contact your payroll department who reluctantly informs you that, yes, you have been served a garnishment

What is a Garnishment?

A garnishment is basically a method by which one of your creditors seeks to obtain money you owe them.  Most garnishments come from creditors who have sued you in civil court; however, other garnishments can come from student loans, the IRS, and even the Department of Defense.  Most of those types of garnishments can be stopped or interrupted by a bankruptcy.  Unfortunately, other types of garnishments, such as child support or alimony, are not subject to the bankruptcy and you may have to examine other options.

How does Bankruptcy Stop Garnishment

When you file Chapter 7 or Chapter 13 Bankruptcy, an “automatic stay” comes into place.  The automatic stay is a federal injunction against the collection of most kinds of debts.  This means that once you are filed, the creditor that is garnishing your wages must stop garnishing your wages.  If they don’t stop, they are actually violating the bankruptcy code.  Depending on the nature of the violation, you may even be entitled to damages against them.

What Should I Do to Stop Garnishment?

If you think you are the victim of a garnishment, wrongful or otherwise, you need to get help.  If you sit back and do nothing, the creditor will garnish your wages until the debt (and any fees, interest or attorney fees) has been paid in full.  Get help today.  We offer unlimited free in-office and phone consultations as well as a special payment plan designed specifically for garnishment cases..

How Do I File Bankruptcy?

When the time comes when you suspect you might need to file bankruptcy, you should approach the situation carefully.  Bankruptcy law involves complex concepts that have evolved for hundreds, even thousands of years.

Bankruptcy Research

General Bankruptcy Information

With the advent of the internet, you have an overwhelming amount of information at your fingertips.  A simple Google Search can lead to tens of thousands of search results discussing the different aspects of bankruptcy.  There are federal bankruptcy statutes, national bankruptcy rules, local bankruptcy rules and even unwritten, closely held local customs and preferences that impact a bankruptcy.  You will also come across anecdotal stories from others who filed bankruptcy discussing the pros and cons that they themselves experienced.  Again, the amount of information available is extensive and overwhelming.

Choosing a Bankruptcy Attorney

The next avenue you will go down is deciding which bankruptcy attorney to choose.  Some people elect to file bankruptcy on their own (or pro se).  Those cases almost always end up a disaster and are, in large part, responsible for the horror stories you hear about bankruptcy.  If you hire a bankruptcy attorney, 99 times out of 100, your case will be filed successfully.

There are many different methods of choosing a bankruptcy attorney.  You can simply Google “bankruptcy attorney” and long list of websites and ads will appear.  There are sites like AVVO and FindLaw that act as legal directories that narrow down the list of attorneys by what type of law he or she practices.  There are also review websites like Rate-a-Biz and even Facebook where you can read reviews from actual bankruptcy clients.

Bankruptcy Filing Process

Initial Consultation

Once you have selected an attorney, you usually hold an initial consultation.  The initial consultation is where you and your attorney get to know each other.  You tell him or her the story of how you got to where you are and where you’d like to be.  The attorney then asks you a series of questions to narrow down what options are available and which option is the best.  This is also where you discuss what may be the most important issue to you – bankruptcy lawyer fees.  Once you have settled on a course of action and how much it will cost, it is time to get things moving.

Bankruptcy Filing Documents and Meeting

After the initial consultation, you will meet face-to-face with your new attorney.  At this appointment, we go over your case once more and I start drafting up the actual bankruptcy documents that will be filed with the Court.  You review and sign the documents and then we file your bankruptcy electronically with the Court.

Chapter 7 or Chapter 13 Bankruptcy

How your case progresses after filing largely depends on whether you filed a Chapter 7 Bankruptcy or Chapter 13 Bankruptcy.  A Chapter 7 Bankruptcy usually involves just one hearing and is over about three to four months after it is filed.  A Chapter 13 Bankruptcy still involves the one hearing but you also make monthly payments to the Chapter 13 Bankruptcy Trustee.  Those payments can last from 36 up to 60 months.  Needless to say, one of the most important decisions you will make is whether a Chapter 7 or Chapter 13 Bankruptcy is in your best interest.  That is the benefit of hiring a bankruptcy attorney to assist you.  He or she can explain all the advantages and disadvantages of each chapter so that you can make the best decision possible.

Whether to File Bankruptcy

Again, if you choose to file bankruptcy, you cannot afford to take that decision lightly.  Be your own advocate.  Do some research on what you think you need (Which chapter?  What questions should you be asking the attorney? Etc.).  Do some research on the different bankruptcy attorneys out there.  Make an informed decision based on all the information available to you.  You will not regret it.

Is your favorite store filing bankruptcy?

Credit Suisse predicts another wave of retail store business bankruptcy filings this year.  In 2017, fifty separate retail giants filed bankruptcy due in large part to the emergence of Amazon and other online retailers.  Many investors anticipate 2018 will be even worse for typical brick-and-mortar retailers.

2017 Retail Store Filings

The following retail stores filed business bankruptcy in 2017:

  • The Limited
  • Wet Seal
  • BCBG
  • Vanity
  • HH Gregg
  • Radio Shack
  • Gander Mountain
  • Gymboree
  • Payless Shoe Source
  • True Religion
  • Toys’R’Us

Projected 2018 Bankruptcy Filings

The following retail stores are projected to file business bankruptcy in 2018:

  • Sears
  • Razer
  • BeBe
  • Stein Mart
  • Burlington Stores
  • Destination Maternity Corp. (parent company of A Pea in the Pod, Motherhood Maternity, and Destination Maternity)

What does that mean to you?

Depending on the type of bankruptcy that these companies file, you may or may not get to continue shopping at your favorite retailers.

Chapter 11 Bankruptcy

If the retailer files Chapter 11 Bankruptcy, you will likely get to continue your regular shopping habits.  Corporations file Chapter 11 Bankruptcy to restructure their debt so that they may continue operations.  The retailer typically files a “plan” that proposes how much will be paid to which creditors and when.  If that plan is approved by the court, then the retailer has a chance to stay in business as long as it abides by the provisions of the plan.  If it doesn’t comply, then it will likely end up in Chapter 7 Bankruptcy.

Chapter 7 Bankruptcy

Corporations file Chapter 7 Bankruptcy to terminate the business.  Corporate Chapter 7 Bankruptcy ensures the orderly liquidation of business assets so as to maximize payments to the business creditors.  Corporations may also end up in Chapter 7 Bankruptcy if the corporation previously filed a Chapter 11 Bankruptcy but that bankruptcy failed.  If your retailer files Chapter 7 Bankruptcy, don’t count on shopping at that store any more.

A Sign of the Times

It should come as no surprise that brick-and-mortar retail businesses are going belly-up.  Online retailers will only grow more and more dominant.  Without the need to purchase and maintain a massive network of physical business locations, online retailers can remain agile and quick to respond to market forces.  A perfect example is Amazon’s foray into the grocery business.  Since grocery stores are technically “retail stores”, they remain one of the only sound business models in that industry.  Amazon recognized this and purchased Whole Foods last year as a way to get into the grocery business.

Business Bankruptcy

If you own a retail business that is suffering as a result of this new online economy, contact us today.  We may be able to help you deal with your debt and, hopefully, keep you out of bankruptcy.

 

Start 2018 Off Right – Use Your Tax Refund to File Bankruptcy

Filing Bankruptcy with your tax refund may sound like a boring way to spend your refund.  People like to use their tax refund for big luxury purchases, expensive car repairs, home improvement – any expense that requires a quick influx of a couple hundred (or thousand) dollars.  The truth of the matter is – filing Bankruptcy with your tax refund may be the best use of your refund.

Spend a Little To Get Rid of Lots

Imagine you have $15,000.00 in unsecured debt that you know you may never pay off no matter how hard you try.  This could be a combination of debts like credit cards, medical bills, or collection accounts.  You also expect to receive a $2,000.00 combined federal and state income tax refund.  You could spend all the money on a new television or vacation.  Or, you could spend part of that money on a bankruptcy that has the power to totally eliminate that debt.  

Chapter 7 Bankruptcy

Generally speaking, there are two different types of Bankruptcy. Chapter 7 Bankruptcy is considered fresh start, clean slate Bankruptcy. It last about three months and usually involves only one short hearing.  Chapter 7 Bankruptcy is the most common form of Bankruptcy.  

Chapter 13 Bankruptcy

Chapter 13 Bankruptcy is reorganization Bankruptcy and is designed for people who are trying to save something they are behind on like a house or a car OR people who make too much money and do not qualify for a Chapter 7 Bankruptcy.  Chapter 13 Bankruptcy can last anywhere from several months up to five years.

Get Answers About Bankruptcy Now

If you are considering Bankruptcy or Debt Relief, you owe it to yourself and your family to at least get more information.  Many clients treat the commitment to use their tax refund to file Bankruptcy as part of their New Year’s resolutions. If you are suffering from overwhelming debt, getting your finances under control should be at the top of the list for 2018.  Call today.

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Multiple Bankruptcy Filings

A myth exists that states you can only file bankruptcy once in your life.  That is simply untrue and for good reason.  One may have multiple bankruptcy filings.  Bankruptcy is meant to allow the honest but unfortunate citizen a means of getting back on his or her feet.  This benefits the citizen, his or her family, and society as a whole.  The average person may go through multiple “bankruptcy-causing” events throughout his or her lifetime.

Bankruptcy-causing Events

When you think about consumer debt and bankruptcy, you might imagine some person who just goes on shopping sprees with no ability or intention of repaying the debt.  However, the real reason that most Americans end up filing bankruptcy has nothing to do with self-indulgence or an inability to resist temptation.

Medical Expenses

A Harvard University study indicates that unpaid medical bills are the leading cause of bankruptcy.  Rare or serious illness, catastrophic injuries – none of us are immune to these events.  Moreover, that study showed that 78% of filers actually had health insurance.  So this wasn’t a case of “well that person should have had insurance” – the majority of them did.  The unfortunate truth is that we all may be one accident or one illness away from bankruptcy.

Reduced Income or Job Loss

The Number Two spot goes to a decrease in income or loss of employment.  Companies now face a global economy with more and competition and automation.  That means they need to cut down on costs and, for many companies, the biggest expense line-item on their balance sheet is “payroll”.  Again, just like catastrophic medical events, you typically have no control over whether your employer is going to fire you.

Divorce

Generally, while you are married, you enjoy the benefits of what is referred to as “economies of scale”.  Simply put – you only need one roof over a married couple’s head – not two.  You only need to pay one cable bill, one electric bill, or one internet bill.  Once you split up and move into separate residences, those expenses typically double.  More specifically, divorce is expensive.  Divorce attorneys are expensive, trial is expensive and living off of one income where once there might have been two is expensive.  Many times, I see instances where couples get divorced and then each spouse files bankruptcy within a matter of months.  The burden is simply too much to handle without the contribution of the other spouse.

Multiple Bankruptcy Filings

Now circle back around to the beginning of this article.  How many co-workers, friends or family members do you know that have been affected by one or more of these life-changing events?  Moreover, life is usually not predictable or convenient.  You may lose your job this year, file bankruptcy and then end up getting divorced five years later.  You may encounter multiple catastrophic medical events throughout your life.  If you cannot afford to deal with the debt that results from each of these events, what else are you supposed to do?

Again, bankruptcy is for the honest but unfortunate citizen.  Sure, you hear ridiculous stories about how some random (nameless) person filed bankruptcy and got to keep a Rolex or a Rolls Royce.  Those stories are usually half-true and don’t really present all the facts necessary to truly understand how that conclusion was reached.  The majority of bankruptcy filings are done by hardworking Americans who just ran into some bad luck.  I know I’ve had some bad luck before – you probably have, too.  Don’t let it define you.

History of Bankruptcy

The History of Bankruptcy hearkens all the way back to Ancient Greece.  Actually, the word “bankruptcy” comes from the combination of the Ancient Latin words “bancus” (bench or table) and “ruptus” (broken).  It was commonplace for bankers to conduct business in the village square on a small bench.  If, for whatever reason, you had to shut your business down, you broke your bench in two as a symbol to the community that you would no longer be in business.

In Ancient Greece, if you could not pay your debt, your creditors forced you, your wife and even your children, into “debt slavery”.  “Debt slavery” was a limited form of real slavery that lasted for five years and then you were released by your creditor.  Time and society progressed.  Reading the Old Testament, we know that every seventh year was decreed a “Sabatical” year. or “Year of the Jubilee”.  During each Sabatical year, all members of the Jewish community (but not gentiles) were required to release all debt and debt slaves held by one another.

Medieval and Renaissance Influences on Bankruptcy

In 1542, in England, Henry VIII passed what are considered the first official laws codifying the concepts of bankruptcy.  Shortly thereafter, concepts such as disclosing all of you assets for orderly liquidation (auction) started to take hold.  In the eighteenth century, you were finally able to discharge of all debts that you were not able to pay. It rewarded debtors who truthfully disclosed all of their assets and debts with the ability to obtain a fresh start and move on with life (similar to modern Chapter 7 Bankruptcy).

The History of Bankruptcy in the United States

Similar to the English system, the Bankruptcy Act of 1800 in the United States was very creditor-oriented and only permitted involuntary bankruptcies of merchant debtors.  Individual debtors possessed no right to file bankruptcy on their own.  However, some clever debtors figured out that they could ask a friendly creditor to file the bankruptcy case.  Unfortunately, the bottom line was that you yourself were still beholden to the banks and lenders.

Evolution of Modern Bankruptcy in the United States

Over time, more and more bankruptcy developments emerged in favor of the individual debtor.  These developments culminated with a 1934 U.S. Supreme Court decision that stated that bankruptcy should provide “the honest but unfortunate debtor a new opportunity in life and a clear field for future effort, unhampered by the pressure and discouragement of preexisting debt.”  To this day, that sentiment still holds true.  Bankruptcy is for the honest but unlucky American.  You should not have to suffer for the rest of your life because of bad luck.

Contact The Law Offices of Dax J. Miller, LLC

If you have questions about debt and bankruptcy, contact The Law Offices of Dax J. Miller, LLC today.

You May Discharge Student Loans Through Bankruptcy

The general rule is that student loans are not dischargeable in bankruptcy.  In order to discharge student loans in bankruptcy, you must satisfy the Brunner Test.  The Brunner test requires that you must demonstrate that (1) you cannot maintain, based on current income and expenses, a ‘minimal’ standard of living for yourself and dependents if forced to repay the loans; (2) that additional circumstances exist indicating that this state of affairs is likely to persist for a significant portion of the repayment period of the student loans; and (3) that you have made good faith efforts to repay the loans.

However, more and more case law is developing that indicates that the tides may be turning on not being able to wipe out student debt in bankruptcy.

New Student Loan Case Law

Thankfully, recent judicial opinions have come out in favor of narrowing the classification of what constitutes a “student loan”.  In Essangui v. SLF V-2015 Trust, a debtor took out a private student loan.  She used that money to pay for tuition, books, and supplies at a Medical Education Readiness Program (MERP).  Subsequently, the Court found that just because you take out a student loan and use it for educational expenses, it doesn’t mean that you are automatically denied the possibility of discharge in bankruptcy.  The court concluded that “the language of the statute suggests that Congress worked to strike a delicate balance between the fresh start policy for debtors and the protection of certain educational programs and lenders offering loans for such programs”.

In ECMC v. Murray, the court actually stated that “in the interest of bankruptcy’s commitment to providing debtors a fresh start, that the [Brunner] test should not be applied too restrictively”.  Fortunately, the court even went so far as to say that just because the debtors were able to afford an income-based repayment (“IBR”) plan, didn’t mean they were stuck with their student loans.  The court recognized that by the debtors only making the payments under the IBR, their student loan principle balance was actually increasing, not decreasing.

Get Rid of Student Loan Debt

Unfortunately, Evansville Bankruptcy Lawyers may immediately shy away from the question of “can I get rid of student loan debt in bankruptcy?”.  At The Law Offices of Dax J. Miller, LLC, we review each case to determine whether you may potentially discharge some, if not all, of your student loans.

If you have questions about student loan debt, contact The Law Offices of Dax J. Miller, LLC today.

The average American’s debt hits records levels this year. The previous record holder was a collective $1.02 trillion in 2008 just before the Great Recession. The average American’s debt has now hit a collective $1.021 trillion – the highest it has ever been.

Average American’s Debt Hits Record Levels

We should all treat this as a huge wake-up call. Higher debt levels increase the risk of default when borrowers cannot service the debt. Current interest rates are also historically low resulting in easy access to credit. For the first time since the Great Recession, lenders are offering consumers with poor credit scores record amounts of credit. Each of these phenomena point to one conclusion – another recession is coming. It is just a matter of when.

Differences in Debt Types

One large difference between 2008 and today is that the debt type is different. Ask anyone “what was at the crux of the 2008 crash?” and they will tell you “the real estate market”. And they would, for the most part, be correct. However, today’s debt looks much different. Housing-related debt is now down; however, student loan debt is up $671 billion and auto loans are up $367 billion. Multiple factors such as the decrease in the perceived value of home-ownership and an increase in the cost of higher education contribute to this new mix of debt type.

What is the Solution?

Needless to say, there is no silver bullet. Each individual’s situation differs. Some may need to simply cut back on non-essential spending (eating out, online shopping – sorry Amazon). Others may need to investigate more acute solutions such as debt settlement or credit repair. In many cases, either Chapter 7 Bankruptcy or Chapter 13 Bankruptcy may eliminate most, if not all, of the debt. Which option best suits you is going to depend on a number of factors. The most important questions to consider are: are you currently delinquent; how much debt do you have; what assets do you own and what are they worth; and how much money do you make?

If you have questions about debt or bankruptcy, contact The Law Offices of Dax J. Miller today to learn more.

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