You are on page 1of 8

New Developments

in Identity Theft
PAGE 1-2

Significant Changes to
Fall 2008
WHAT’S INSIDE

Garnishment Proceedings in Ohio


PAGE 2-3

Dormant Accounts and


Escheatment- Tips and Traps
PAGE 4

Will Web Video Kill the Conference Star?


PAGE 5

Using Employee Pictures and


Related Items Without Consent
PAGE 6

Vendor Credentials – High or Low Risk?


Providing solutions for credit unions.
PAGE 7

New Developments in Identity Theft


By: David A. Wolfe, Esquire

Identity theft is the fastest-growing crime in the United States This Program must include reasonable
and topped the list of consumer fraud complaints filed with policies and procedures to identify certain
signals of actual or attempted identity
the Federal Trade Commission (“FTC”) for seven years in a row
theft. Supplement A to the guidelines
through 2007. In an FTC report issued in February 2008, credit contains a list of 26 “red flags” that
card fraud was the most common form of reported identity financial institutions and creditors may
theft at 23%, with utilities fraud at 18%, followed by bank fraud consider incorporating into their
at 14%. To combat this growing trend, federal agencies enacted Program, including:
the Fair and Accurate Credit Transactions Act (“FACTA”) Red
• Alerts, notifications, or other warnings
Flag guidelines requiring financial institutions and creditors to received from consumer reporting
develop and implement a preventative program to mitigate agencies or service providers;
the risk of identity theft for both new and existing accounts. • Unusual patterns in the consumer’s
use of credit, such as a recent increase
FACTA imposes serious responsibilities on these businesses to develop in inquiries or new credit accounts,
and adopt a written Identity Theft Prevention Program (“Program”) to changes in the use of credit, or
detect, prevent and mitigate identity theft with the opening or existence accounts closed;
of a covered account. A covered account is defined as an account used • Suspicious documents that appear to
primarily for personal, family or household purposes; or any other account be forged or reassembled, or those
for which there is a reasonably foreseeable risk to the customer or the documents that contain information
safety and soundness of the financial institution from identity theft. that is inconsistent with the person
The Program must address four basic elements: applying for credit.

• Identify relevant patterns, practices and specific forms of activity that continued on page 2
are “red flags” signaling possible identity theft and incorporate those
red flags into the plan;
• Detect those red flags that have been incorporated into the plan; David A. Wolfe is an Associate
• Respond appropriately to any red flags that are detected to prevent in the Bankruptcy and Legal
and mitigate identity theft; and Action Recovery departments
• Ensure the plan is updated periodically to reflect changes in risks from of the Detroit office. He can be
identity theft. reached at (248) 362-6142 or
dwolfe@weltman.com.

KEEPING CREDIT UNIONS CONNECTED TO THE LAW


Credit Union Department (216) 739-5100 • Chicago (312) 782-9676 • Cincinnati (513) 723-2200 • Cleveland (216) 685-1000
Columbus (614) 228-7272 • Detroit (248) 362-6100 • Grove City, OH (614) 801-2600 • Philadelphia (215) 599-1500 • Pittsburgh (412) 434-7955
New Developments Significant Changes to
in Identity Theft Garnishment Proceedings
continued from cover
in Ohio - Senate Bill
281 Becomes Law On
FACTA includes additional special rules
for debit and credit card issuers to

September 30, 2008


develop policies and procedures to assess
the validity of a request for a change
of address that is followed closely by a
request for an additional or replacement By: Joseph D. DeGiorgio, Esquire
card. The rules prohibit the issuance of
the additional or replacement card until On June 27, 2008, Ohio Governor Ted Strickland signed Ohio
the change of address is verified with Senate Bill 281 (“SB 281”), which will become law in Ohio on
the cardholder. September 30, 2008. SB 281 amends a total of seven sections
of the Ohio Revised Code, but the primary effect of the new
The regulation and guidelines were
effective on January 1, 2008 and law is to amend those sections of the Revised Code that govern
FACTA’s mandatory compliance date of what property is subject to – and exempt from – garnishment
November 1, 2008 is fast approaching. by creditors. SB 281, therefore, is particularly relevant to (and
This new rule/guideline requires will have far-reaching effects on) all debt collection activity
significant continued administration and throughout the state.
oversight of the Program and requires
each financial institution or creditor to: SB 281’s most important provisions relate to two distinct areas of Ohio
garnishment procedure; it amends both the dollar amounts of property
• Obtain approval of its written that may be held exempt, and it amends the procedure whereby creditors
Program from either its Board may garnish individuals’ property. This article discusses some of the more
of Directors or an appropriate remarkable provisions of the bill.
committee of the Board of Directors;
• Involve the Board of Directors or Exemption Amounts
the appropriate committee, or a Probably most notably, SB 281 amends § 2329.66 of the Revised Code
designated senior-management- to increase the dollar amounts of various categories of property, both real
level employee in the oversight, and personal, that any debtor (domiciled in Ohio) may hold exempt from
development, implementation and execution and garnishment. While SB 281 does not create new exemptions
administration of the Program; and – current law allows debtors to hold certain property exempt – the new
• Train staff to effectively implement law does significantly increase the dollar amounts of nearly all the already-
the Program. existing exemptions. Some of the most significant changes to those
amounts are detailed in the chart below: continued on page 3
With a little more than a month
before the deadline, many financial
institutions and creditors may already Exemption under Exempt Item(s) Exemption under SB 281
have compliant policies and procedures Current Law (Effective Sept. 30, 2008)
in place as many are spending more on $5,000 Property, used as residence $20,200
fraud prevention, and for most it will be
a matter of training staff on how to spot $1,000 Motor Vehicle (one) $3,225
and respond to a red flag. $5,000 Money received (or any right $20,200
to receive money) in the
past 12 months as payment
“…federal agencies for personal bodily injury
(excluding pain and suffering)

enacted the FACTA Specific dollar amounts for


various individual property
Personal, family and
household items
A more broadly-defined
exemption category, with
Red Flag guidelines… interests; $200 for one item
of wearing apparel, beds,
an aggregate dollar amount
of $10,775 for most items,
and bedding; $300 in one and $1,350 for jewelry held
to mitigate the risk refrigerator; $400 for one
item of jewelry and no more
primarily for personal, family
or household use.
of identity theft for than $200 in every other
item of jewelry
both new and existing $400 in any property “Other property” $1,075
***applicable only in
accounts.” bankruptcy proceedings

2
Significant Changes to Garnishment Proceedings in Ohio
continued from page 2

As noted in the chart, the exemption Any garnishee that garnishes SB 281 also changes the required
for “other property” applies only the property, other than language for orders of garnishment
to bankruptcy proceedings; it is personal earnings, of a that are sent to employers of
inapplicable to the collection of debt judgment debtor in good faith judgment debtors (garnishees). Prior
from individuals and entities not reliance upon the order and to September 30, 2008, the order
involved in bankruptcy proceedings. notice of garnishment received must contain an affidavit stating that
by ordinary or regular mail the garnishee owes the debtor money
Garnishment Procedure service shall not be liable for for personal earnings; the new law
In addition to the above changes damages in any civil action. requires that the order state that the
related to the dollar amounts of RC 2716.13(B). garnishee may owe the debtor money
exempt property, SB 281 also alters for personal earnings.
the procedure that creditors must Unlike the current state of the law,
follow in order to garnish the property after September 30, 2008, garnishees On September 30, 2008, when SB
of a debtor. will no longer be subject to civil 281’s provisions go into effect, the
liability, so long as garnishees act in law related to garnishment of property
Garnishment of Property Other good faith reliance on the order and belonging to debtors domiciled in
than Personal Earnings notice of garnishment they receive. Ohio will change. While the day-to-
Garnishment of debtors’ property day operations of your particular entity
other than personal earnings is usually Garnishment of Personal Earnings may not be drastically altered, all
relevant when a creditor attempts Under both current law and SB WWR clients should take note of the
to garnish funds held by debtors on 281, all creditors wishing to garnish changes and, when applicable, ensure
deposit at financial institutions. A debtors’ personal earnings must compliance with the new law’s terms.
debtor’s bank account can, of course, first serve a written demand letter
be lawfully garnished – subject to the containing specific language. SB
limitations and restrictions of the law – 281 makes changes to the required
in order to satisfy a legal judgment. language contained within that
SB 281 alters the provisions of required written demand. Currently,
the Revised Code that govern the the demand must state that demand is
garnishment of property other than made for the amount of the judgment
debtors’ personal earnings. over the amount of personal earnings
that are exempt from garnishment.
Most notably, SB 281 adds language SB 281 makes a slight but significant
to the law that shields garnishees from change; it requires that the demand
liability when a garnishee acts in good be made for the amount of the Joseph D. DeGiorgio is an
Associate in the Collection
faith in carrying out the garnishment judgment owed over the amount of
Services department of the Grove
of property other than personal personal earnings that may be exempt City office. He can be reached at
earnings. Specifically, SB 281 adds from garnishment. (614) 801-2668 or jdegiorgio@
the following language to the law: weltman.com.

“…the primary effect of the new law is to


amend those sections of the Revised Code
that govern what property is subject to – and
exempt from – garnishment by creditors.”

3
Dormant Accounts and
Escheatment-Tips and Traps
By: Matthew G. Burg, Esquire

“A penny saved is a penny earned”… Some tips and traps to keep in mind Overall, maintaining both a dependable
well, unless the account becomes when dealing with dormant accounts: computer system and accounting/
dormant. This old adage obviously did operating procedures are critical to a
not contemplate dormant accounts and • Dormancy Periods: Know your credit union’s success in monitoring
the state’s power of escheatment. state’s dormancy periods for each type accounts, promoting activity and
of account. Each state has its own complying with state reporting
Credit unions, like banks, must deal with time periods, which differ amongst requirements. And for those customer
dormant customer accounts – accounts the states. States also apply different accounts that do remain active, a penny
that sit unused usually due to its owner’s dormancy periods to different types of saved will be a penny earned.
death, inadvertence or forgetfulness. accounts. For example, a bank account
Once an account becomes dormant, becomes dormant after five years in Resources utilized in preparing this article:
the funds escheat, or revert, to the Ohio, but an IRA becomes dormant
state. Astonishingly, the State of Ohio’s after only three years. - Ohio Department of Commerce at
http://www.com.ohio.gov/unfd/
Unclaimed Funds Division maintains
more than 3.2 million accounts, some • Reporting: Know your state’s - Ohio Revised Code Ch.169
generated from money left in dormant reporting deadlines. In Ohio, the
accounts, worth over one billion dollars. reporting deadline for accounts - Current Issues in Credit Unions podcast,
dormant as of June 30 is November 1 March 22, 2008, http://www.ciicu.libsyn.
For purposes of Ohio’s escheatment of the same year. Even if no unclaimed com/ (featuring WWR Partner, Robert W.
laws, checking and savings accounts funds are held, a “negative” report Rutkowski)
are deemed dormant after five years must still be filed.
of inactivity on the account between - McMahan, Emmet. Guide to Unclaimed
Property in Ohio.
the owner, i.e., the person or legal • Preemption: Federal law preempts
representative having an interest in state law whenever a conflict exists.
the account, and the holder, i.e., the Thus, even if your state law does not
credit union or bank who has possession
of the money in the account. Any
allow state credit unions to retain a
portion of the dormant funds before
“A credit union’s
activity on the account, however, such
as an owner’s increase or decrease of
they escheat to the state, the same
is not true for federal credit unions failure to accurately
the funds, correspondence with the governed under federal law. Generally,
holder concerning the funds, or some federal credit unions may recover fees and timely report
acknowledgement by the owner of an or costs generated in maintaining an
interest or knowledge of the funds, will account before the unclaimed funds dormant accounts
protect the account from being dormant. escheat to the state.
may result in
If an account becomes dormant, the • Multiple Customer Accounts:
holder is required to report the unused, When customers have multiple penalties.”
abandoned or unclaimed funds to accounts with a credit union, link the
the state. A credit union’s failure to accounts together. If one account
accurately and timely report dormant becomes dormant, a customer’s
accounts may result in penalties. Aside activity with the other accounts may
from the penalties associated with failing insulate the dormant account from
to report unclaimed funds contained in reverting to the state.
dormant accounts, the costs associated
with maintaining a dormant account are • Penalties: Knowing the reporting
generally unrecoverable once the funds requirement and providing accurate
escheat to the state. reports are crucial because of the
potential penalties for non-compliance.
In Ohio, a failure to report unclaimed Matthew G. Burg is an Associate in the
funds or under-reporting unclaimed Litigation & Defense department of the
funds may result in civil penalties of Cleveland office. He can be reached at
$200.00 per day or criminal penalties (216) 685-1111 or mburg@weltman.com.
as high as $500.00 a day, plus interest.

4
Will Web Video Kill the
Conference Star?

&
By: Rob Rutkowski, Esquire

On a recent morning, I watched a seminar given over the Web. Normally, when

Pagon
you attend a webinar, you get telephone audio feed and a PowerPoint that
is at best unreliable. This was different. NAFCU sponsored the event,
and the webinar began with video camera panning back off their
logo and then focusing on the two speakers. A small video ran on
the left of my screen while the PowerPoint was displayed on the Halton
right. This seminar went flawlessly. I didn’t even see it live, I saw
part of a recording of it. Nonetheless, it was very impressive.

If a webinar can be given reliably via streaming video and Working Together to
the audience can see the speaker and the PowerPoint Serve You Better
simultaneously, why would anyone ever go to a live seminar
again? Webinars are cheaper than in-person seminars. There We are excited to announce the
are no travel costs or food expenses and the time the promotion of Dawn Pagon to Manager
employee spends away from the credit union is of Client Relations for Credit Unions
significantly less. Moreover, you can have as and introduce Lauren Halton as a Credit
many people watching it on the computer Union Client Representative. Together
as you have space in your conference they are teaming up to better serve the
room. You could even port it to an needs of our credit union clients, offering
HDTV. For a credit union trying you exceptional customer service,
to cut costs, a good webinar is far attendance at more credit union events
superior to sending employees away and providing you insights and Firm
for educational training. At its most services to keep you on top of legal and
basic level, the purpose of a seminar is collection issues in our industry. Lauren
for the dissemination of information to the is based in our Columbus office, serving
attendees. If it can be done more cheaply, then clients in Central and Southern Ohio.
it should be done more cheaply. Dawn will continue to work from our
Brooklyn Heights location, managing
Webinars are still not perfect. Workshops suffer. It is hard to play learning clients in Northeast and Northwest Ohio,
games, get answers to hypotheticals and break people into groups via a webinar. as well as overseeing client relations
Also, I mentioned this webinar opportunity to some other credit union folks and across our WWR coverage area.
some were concerned that webinars don’t allow for networking. I have to agree
with that. There is, by definition, no in-person contact beyond that of your co-
workers. However, while networking might be rewarding to individuals, what is
the return to the credit union?

I would submit to you that webinars will indeed greatly reduce the number
of conferences for credit union employees and volunteers over time. The ones
that survive will be more social events for educational sessions. People will want
to attend these not for the educational sessions, but for the networking and
camaraderie. This is not necessarily a bad thing. As webinar technology improves,
the corresponding efficiency will be a benefit to everyone. You might think Dawn Pagon
that I have a vested interest in the convention circuit as I give upwards of 40 Manager of Client Relations
presentations a year. Honestly, I would rather do them all as webinars. for Credit Unions

Robert Rutkowski is the Managing Partner of the


Firm’s Credit Union department. Based in the
Brooklyn Heights operations center, he can be reached
at (216) 739-5004 or rrutkowski@weltman.com.
Lauren Halton
Credit Union
Client Representative 5
Using Employee Pictures and
Related Items Without Consent
By: A.J. Ober, Esquire

The rapid development and use of the Jersey have judicially recognized the advertisement, for the mere purpose of
Internet and high-speed communication right to privacy in case law. However, increasing the profits and gains of the
devices such as BlackBerrys and camera most states have not codified this right. advertiser is an invasion of privacy. See
phones over the past decade has given Nevertheless, state court rulings across Pavesich v. New England Life Ins. Co., et
renewed rise to concerns regarding the country have been consistent with al., 122 Ga. 190 (1905).
privacy rights. In an instant, a picture Restatement (2ND) of Torts § 652C,
can be broadcasted around the globe, which provides “One who appropriates The Missouri Court of Appeals similarly
virtually unstoppable, and without to his own use or benefit the name or protected one’s right to his/her picture.
consent from the pictured party. Due likeness of another is subject to liability The picture of a five-year old boy was
to the ever-increasing number of ways to the other for invasion of privacy.” used by a jeweler to advertise his store
personal information can now be and sell merchandise. The Court declared
appropriated, individuals have grown In one case, a New Jersey Plaintiff em- that one’s own picture is a property
more protective of personal attributes ployed by Kodak gave Kodak permission right of material profit and use without
such as their name, picture or likeness. to use his family photo in a publication consent deprives one of their rights to
on how to print property and privacy.
How many times have you seen the pictures. Condecor, See Munden v. P.S.
candid pictures of a wise senior executive another com- Harris, et al., 153
or a fresh-faced junior associate used pany in the photo Mo. App. 652 (1911).
in a company’s advertising campaigns? industry, copied
The people featured in those ads may the picture from Without question,
be employees of the company and Kodak’s publica- courts have actively
often are, since use of their pictures tion and used it in and unequivocally
typically comes at little or no cost to the picture frames and protected privacy rights
company. While this appears harmless pricing catalogs. when names, pictures,
enough, using these pictures may Condecor did not likenesses, etc. are
result in an actionable claim against the seek consent from used without consent.
employer for a violation of privacy rights. the Plaintiff or Kodak and It should be noted that
alleged that the use of the picture a Plaintiff is not required to allege nor
For instance, New York’s Civil Rights Law was incidental, and thus not an invasion prove actual damages to be awarded
§ 51 gives a plaintiff a right of action if of privacy. The Superior Court of New injunctive relief. If damages are proven,
his/her name, portrait, picture or voice Jersey enforced the Plaintiff’s privacy right however, the majority of jurisdictions
is used for advertising or trade purposes against Condecor and reasoned that will also award both actual and punitive
without written consent. Virginia and the photo was used for trade purposes, damages. Some courts have even gone
Utah have also enacted laws, modeled as the photo was used inside frames so far as to order a public apology and/
after New York, which statutorily protect that were offered for sale. The Court or retraction, which may prove costly to
a person’s right to privacy. New York’s also noted that the Plaintiff’s consent to an employer.
highest state court awarded damages Kodak would not extend to Condecor
for invasion of privacy when Defendant since the Plaintiff did not contemplate In sum, an employer is best served by
Chemical Bank photographed its em- Condecor’s use at the time consent was always obtaining written consent from
ployees and used the photos for advertis- given to Kodak. See Faber v. Condecor, an employee when using the employee’s
ing purposes. The Court cited § 51 and Inc., 477 A.2d 1289 (1984). name, picture, voice and/or likeness for
held that absent written consent from marketing or advertising purposes. Lastly,
the employees, use of the photos was an In another case, a Georgia man’s the employer should be conscientious
invasion of privacy. See Caeser, et al. v. insurance company used his picture to obtain consent each time a picture or
Chemical Bank, 66 N.Y. 2d 698 (1985). in a newspaper advertisement for life- similar item is reused for a
insurance, without consent. Georgia’s new or different purpose.
A majority of states including Ohio, Supreme Court held that publication
Pennsylvania, Michigan, Illinois and New of one’s picture without consent, in an
A.J. Ober is an Associate
“…using these pictures may result in an in the Legal Action
Recovery department of the
actionable claim against the employer for Philadelphia office. He can be
reached at (215) 599-1500 or
a violation of privacy rights.” aober@weltman.com.

6
Vendor Credentials – Have you listened to the
Current Issues in Credit
High or Low Risk? Unions podcast lately?
Have you heard about the Current Issues
By: Sara M. Donnersbach, Esquire in Credit Unions (CIiCU) podcast? The
brainchild of Rob Rutkowski, Managing
Verifying a vendor’s credentials, as well as vendor about any projects that have Partner of WWR’s Credit Union department,
those of its principals, is essential before ended badly or that were abandoned. CIiCU is a monthly podcast about credit
providing an outsider access to business Some will be forthcoming with unions and the legal issues that they face in
assets, facilities and workforce. In today’s information; however if told it has not the course of business. Hosted by attorneys
involved in the credit union movement,
business environment, failing to screen happened, do some research when the podcast covers hot topics and breaking
and monitor a vendor can result in calling references. legal news and is designed for credit union
huge consequences. When choosing officers, directors, employees, volunteers
a vendor, look for the vendor that can Key things to check for, from business and anybody interested in the credit
not only solve today’s problem, but one vendors and their principals: union movement. The podcast enjoys an
impressive audience of nearly 1400 credit
that won’t increase or create problems union industry individuals each month.
by being a high risk vendor. Choose a • Businesses: corporate status, financial
vendor that will still be around next year. and credit information, bankruptcy The other members of the Current Issues
history and judgment record, insurance in Credit Unions team include Brian Witt of
Before hiring a company to provide certificates, W9 tax documentation, Farleigh Witt, Faith Anderson of American
Airlines Credit Union and Guy Messick of
goods and services, verify the prospective licensing, government watch lists and Messick & Weber P.C. Rob, producer of the
vendor’s performance, criminal record conflicts of interest. podcast, says, “The credit union movement
and financial standing. Failing to do is something that Brian, Guy, Faith and I
so, and failing to monitor these things • Principals: Social Security number are very passionate about. We have been
at future intervals, can result in fraud, and identification verification, involved with the credit union movement for
a long time and we enjoy being able to do a
unsatisfactory work and lost time background check, credit history, free show for credit unions worldwide where
and money. professional licensing, government we can discuss topics that we see in our
watch lists and conflicts of interest. practices. Sharing relevant information and
When considering long-term needs, giving tips to credit union professionals that
look at the stability of the vendor. For There are specific, measurable benefits they may be able to use in their day-to-day
activities is important to us and we hope to
example, if the vendor company is a one- to screening a prospective vendor get credit unions to think about these legal
man-shop, there is essentially no stability. and monitoring present vendors. issues from a different perspective.”
When considering team-based vendors, Doing so provides more control and
be mindful of their financial stability. accountability. Vendors are encouraged
Many service companies have cash-flow to abide by set work and ethical
issues that can impact their customers. standards. The review process provides
Ask prospective vendors for proof of the truth about a vendor’s and potential
their financial stability. business partner’s capabilities, financial
health and reputation. While there is an
Another aspect of stability is turnover administrative cost, this process, too, can
rate. On any given project, the vendor be outsourced.
team members should rarely change. Sara M. Donnersbach is
Re-teaming or starting with a new a Partner in the Specialty
resource costs time and money, so Collections department of
turnover is extremely important. When the Cleveland office. She
reviewing prospective vendors and oversees the Governmental The CIiCU team (from left: Faith Anderson,
monitoring present vendors, ask for Collections Practice Group, Brian Witt, Guy Messick and Rob Rutkowski)
updated references and ask questions the Healthcare Practice Group
about turnover. and the Utility Service and
Damage Claims Practice
Group. She can be reached If you are interested in accessing the
A final aspect of long-term stability is at (216) 685-1039 or podcast, visit any of the links below. While
abandoned projects. Ask the prospective sdonnersbach@weltman.com you can use your iPod to listen to the
program, you don’t need an iPod. You can
easily download and listen to the file on your

“…failing to screen and monitor computer, or burn the file onto a CD and
listen to it on a CD player.

a vendor can result in • iTunes Music Store: http://phobos.apple.com/


WebObjects/MZStore.woa/wa/viewPodcast?

huge consequences.” id=151785964&s=143441


• Direct Download: www.ciicu.libsyn.com
• RSS Feed: http://ciicu.libsyn.com/rss

7
323 W LAKESIDE AVE SUITE 200 CLEVELAND OH 44113-1099
FORWARDING SERVICE REQUESTED

Pagon & Halton


Working Together to Serve You Better
Details inside on page 5!

Have you listened to the


Current Issues in Credit Unions podcast lately?
Details inside on page 7!

WHAT’S INSIDE...

• New Developments
in Identity Theft

• Significant Changes to
Garnishment Proceedings in Ohio

• Dormant Accounts and


Escheatment- Tips and Traps

• Will Web Video Kill the Conference Star?

• Using Employee Pictures and


Related Items Without Consent

• Vendor Credentials – High or Low Risk?

The WWR Letter is provided as a free service by Weltman, Weinberg & Reis Co., L.P.A., representing clients on creditors’
rights issues. The data contained in this newsletter is a summary of legal information, may be incomplete and is not in-
tended to constitute legal advice on specific matters, create an attorney-client relationship or be legally binding in any way.
WWR understands that each legal matter is unique and recommends that the reader should consult his/her own attorney for
specific advice on a particular problem or legal need. In the event that the reader does not wish to receive future copies of
this newsletter, please send an e-mail to wwrletter@weltman.com.

No articles may be reprinted without our written permission but we do grant permission to subscribers for internal use
with their staff. Direct editorial comments to Mala Mason at 1400 Koppers Bldg., 436 Seventh Ave, Pittsburgh,
Pennsylvania 15219. Phone (412) 225-9568. Email wwrletter@weltman.com.

8 ©2008 Weltman, Weinberg & Reis Co., L.P.A.

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