FYI: Ill App Ct (1st Dist) Holds "Keep Chicago Renting Ordinance" Preempted by State Law

The Appellate Court of Illinois, First District, recently reversed a trial court judgment in favor of a tenant and against a foreclosing lender under the Keep Chicago Renting Ordinance (KCRO) Chicago Municipal Code § 5-14-010 et seq.

 

In so ruling, the Appellate Court held that the Illinois Rent Control Preemption Act (the "IRCPA") (50 ILCS 825/1 et seq.) preempted the tenant's claims against the lender under the KCRO.

 

A copy of the opinion is available at:  Link to Opinion

 

A tenant residing in a home in Chicago filed suit against a lender and its loan servicer alleging that after the foreclosing lender purchased the property at a judicial sale the defendants violated the KCRO by failing "to offer her either relocation assistance or an extension of her lease agreement, as required by the ordinance." 

 

The defendants moved to dismiss arguing that the IRCPA preempted the KCRO because "[t]he Act prohibits the regulation of the amount of rent charged for residential property in the state of Illinois (id. § 10), but the KCRO, which is a Chicago ordinance, requires an owner of a foreclosed property to offer qualified tenants either a $10,600 relocation fee or extend the tenant's lease with an annual rental rate that does not exceed 102% of their current rental rate." 

 

The trial court agreed and granted the motion to dismiss.

 

Thereafter, the City of Chicago (City) intervened.  The City and the tenant asked the trial court to reconsider and to vacate the judgment.  The trial court reversed course and vacated the judgment "finding that the KCRO's limitations on rent, while preempted by the Act, could be severed from the KCRO without running afoul of city council's intent and the underlying reason for the ordinance."

 

At trial, the Court found in favor of the tenant and awarded her statutory damages, attorneys' fees, and costs.  This appeal followed.

 

The Appellate Court first analyzed whether the IRCPA preempted the tenant's KCRO claims. To resolve this issue the Appellate Court examined the language of the Chicago ordinance and the Illinois statute.

The KRCO states that the owner of foreclosed rental property:

 

"shall pay a one-time relocation assistance fee of $10,600 to a qualified tenant unless the owner offers such tenant the option to renew or extend the tenant's current rental agreement with an annual rental rate that: (1) for the first 12 months of the renewed or extended rental agreement, does not exceed 102 percent of the qualified tenant's current annual rental rate; and (2) for any 12-month period thereafter, does not exceed 102 percent of the immediate prior year's annual rental rate." Chicago Municipal Code § 5-14-050(a)(1).

 

In contrast, the IRCPA states that "[a] home rule unit may not regulate or control the amount of rent charged for leasing private residential or commercial property. This Section is a denial and limitation of home rule powers and functions under subsection (g) of Section 6 of Article VII of the Illinois Constitution." 50 ILCS 825/10.

 

In addition, concerning non-home rule units, the IRCPA provides that: "A unit of local government *** shall not enact, maintain, or enforce an ordinance or resolution that would have the effect of controlling the amount of rent charged for leasing private residential or commercial property." Id. § 5(a).

 

Section 10 applies here because the City is a home rule body.  The Appellate Court found that the IRCPA's clear statutory language prohibits the City from seeking to "regulate or control" the amount of rent that a landlord may charge for residential property.  The Appellate Court also determined that "the KCRO clearly regulates and controls the amount of rent a landlord may charge for residential property—no more than 102% of a qualified tenants' current annual rent."

 

Accordingly, the Appellate Court held that the IRCPA preempts the KCRO.

 

The Appellate Court rejected the City's argument that a landlord may avoid the rent control provision in the KCRO by offering the relocation assistance fee instead of renting the property to a qualified tenant. This argument failed because rent control does not force a landlord to rent property and under this interpretation no rent control measure would ever run afoul of the IRCPA's prohibition on rent control.

 

The Appellate Court next considered whether it was possible to sever the KCRO provision establishing the rent that a landlord may charge from the rest of the KCRO. When an ordinance has a severability clause, a reviewing court will "presume that the legislature intended the invalid provision of the ordinance or statute to be severable."

 

Here, the Chicago Municipal Code states that "[i]f any part, section, sentence, clause or application of this Code shall be adjudged invalid, void and of no effect for any reason, such decision shall not affect the validity of the remaining portions of the titles, chapters, sections or other provisions of this Code, or their application to other circumstances." Chicago Municipal Code § 1-4-200. 

 

However, it is possible to overcome the presumption of severability "if the legislature would not have passed the statute without the" invalid provision. To determine this, the Appellate Court determines if eliminating the invalid provision would significantly undercut or alter the legislative reason for passing the act.

 

Absent the KCRO, Illinois permits a foreclosure purchaser to evict tenants from the foreclosed property after a 90-day notice period. The Chicago City Council designed the KCRO "to preserve, protect, maintain and improve rental property and prevent occupied buildings from becoming vacant after foreclosures." Chicago Municipal Code § 5-14-010. To achieve this purpose, the KCRO "incentivizes purchasers of foreclosed property to retain tenants by excusing purchasers from paying a $10,600 relocation fee if they extend the qualified tenant's lease and raise rent by no more than 102% of the previous year's rent."

 

The Appellate Court determined that if you removed any reference to rental rates, then the provision would state: "[T]he owner of a foreclosed rental property shall pay a one-time relocation assistance fee of $10,600 to a qualified tenant unless the owner offers such tenant the option to renew or extend the tenant's rental agreement."

 

This revision would allow a foreclosure purchaser to avoid the relocation fee "by offering to extend a qualified tenant's lease at a prohibitive rental rate, knowing that the tenant is likely to refuse."  Displacing tenants would leave buildings vacant, "which is precisely what the KCRO was enacted to avoid."

 

As a result, the Appellate Court found that the relocation fee is inseparable from the rent control provision and that the Chicago City Council "would not have passed the KCRO without the rent limitation."

Therefore, the Appellate Court reversed the trial court's judgment holding that "the invalid portion of the KCRO is not severable from the remainder of the ordinance," and the Act preempts the KCRO. 

 

The time for the appellees to petition the Illinois Supreme Court to review this decision has not yet expired, but for now the IRCPA would preempt the KRCO requirement that "an owner of a foreclosed property to offer qualified tenants either a $10,600 relocation fee or extend the tenant's lease with an annual rental rate that does not exceed 102% of their current rental rate." 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 6^th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

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FYI: 9th Cir Issues Amended Opinion in Seila Law Case, Allows CFPB to Enforce Its CID

A panel of the U.S. Court of Appeals for the Ninth Circuit recently amended its December 29, 2020 opinion on remand from the Supreme Court of the United States in the Consumer Financial Protection Bureau v. Seila Law LLC case.

 

In its amended ruling, the Ninth Circuit panel reaffirmed the trial court's order granting the Consumer Financial Protection Bureau's (CFPB) petition to enforce a law firm's compliance with the CFPB's civil investigative demand (CID) requiring the firm to produce documents and answer interrogatories.

 

A copy of the opinion is available at:  Link to Opinion

 

In 2017, a law firm challenged the constitutionality of the CFPB, an independent agency created in the wake of the 2008 financial crisis. The CFPB had issued a CID to the law firm, requiring the firm to produce documents and answer interrogatories, but the firm argued that the CFPB was unconstitutionally structured since the President could not remove its Director without cause.

 

The CFPB took the law firm to a federal trial court, filing a petition to enforce the CID, which the court granted. CFPB v. Seila Law, LLC, No. 17-cv-1081, 2017 WL 6536586, at *1 (C.D. Cal. Aug. 25, 2017). The law firm appealed to the Ninth Circuit, and the CFPB prevailed again. CFPB v. Seila Law LLC, 923 F.3d 680 (9th Cir. 2019).

 

The law firm then appealed to the Supreme Court, which held that the CFPB's structure did violate the Constitution. Seila Law LLC v. CFPB, 140 S. Ct. 2183, 2192 (2020). The SCOTUS did so because Congress improperly shielded the CFPB Director from at-will removal by the President, which rendered the agency "accountable to no one." Id. at 2203.

 

However, rather than dismiss this action, the SCOTUS severed the CFPB Director's tenure protection and remanded the case to the Ninth Circuit to determine whether the CID was validly ratified by former Acting Director Mick Mulvaney during his one-year stint in that office. Id. at 2211.

 

Shortly afterward, the CFPB's then-Director, Kathleen Kraninger, ratified both the CID and the petition to enforce the CID against the law firm.

 

In its amended opinion, the Ninth Circuit panel held that the CID was validly ratified, but that there was no need to decide whether ratification occurred through the actions of Acting Director Mulvaney because then-Director Kraninger expressly ratified the CFPB's earlier decisions to issue the civil investigative demand to the law firm, to deny the firm's request to modify or set aside the CID, and to file a petition requesting that the trial court enforce the CID.

 

The Ninth Circuit determined that the law firm's only cognizable injury arose from the fact that the CFPB issued the CID and pursued its enforcement while headed by a Director who was improperly insulated from the President's removal authority.

 

The Ninth Circuit concluded that any concerns that the law firm might have had about being subjected to investigation without adequate presidential oversight had now been resolved because Director Kraninger was well aware that she may be removed by the President at will when she ratified her predecessors' earlier decisions to issue and enforce the CID.

 

The Ninth Circuit rejected the law firm's contention that Director Kraninger could not validly ratify the CFPB's earlier actions because the agency lacked the authority to take those actions back in 2017. The Court held that the law firm's argument was largely foreclosed by the Ninth Circuit's ruling in CFPB v. Gordon, 819 F.3d 1179 (9th Cir. 2016). Just as in Gordon, the Ninth Circuit concluded that the constitutional defect here related to the Director alone, not to the legality of the agency itself. Id. at 1192.

 

The Ninth Circuit also rejected the law firm's remaining argument that Director Kraninger's ratification was invalid because it took place outside the limitations period for bringing an enforcement action.

 

The Court held that the law firm's argument failed because this statutory limitations period pertained solely to the bringing of an enforcement action, 12 U.S.C. § 5564(g)(1), which the CFPB had not yet commenced against the law firm.

 

The Ninth Circuit observed that the only actions ratified by Director Kraninger were the issuance and enforcement of the CID and concluded that the very purpose of such a demand was to assist the CFPB in determining whether the law firm had engaged in violations that could justify bringing an enforcement action. The Court thus decided that the law firm had raised its statute-of-limitations argument prematurely. Pacific Maritime Association v. Quinn, 491 F.2d 1294, 1296 (9th Cir. 1974).

 

Accordingly, the Ninth Circuit reaffirmed the trial court's order granting the CFPB's petition to enforce the CID.

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 6^th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

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FYI: 2nd Cir Holds No FCRA Liability for Reporting Allegedly "Vacated" Judgment as "Satisfied"

The U.S. Court of Appeals for the Second Circuit recently affirmed a trial court's judgment in favor of a consumer reporting agency (CRA).  In so ruling, the Second Circuit held that the trial court correctly determined that:

 

(1) the CRA's credit report stating that a judgment against the plaintiff was "satisfied" was accurate, even though the plaintiff claimed the judgment was "vacated"; and

 

(2) the plaintiff could not establish damages arising from the CRA's allegedly negligent conduct; and

 

(3) the CRA did not need to prove it actually interpreted the FCRA in line with its claimed reasonable interpretation to rely on the reasonable-interpretation defense established by Safeco Insurance Company of America v. Burr, 551 U.S. 47, 57 (2007).

 

A copy of the opinion is available at:  Link to Opinion

 

After a debt collector obtained a default judgment against the plaintiff in a debt collection action, the collector began garnishing the plaintiff's wages. The plaintiff then appeared in the action, eventually entering into a stipulation of settlement.

 

When the plaintiff learned that the defendant, a consumer reporting agency, was including the 2013 default judgment on his credit report, he filed suit, alleging that, in reporting the judgment as "satisfied" and in its subsequent dealings with the plaintiff, the CRA willfully and negligently violated the source-disclosure, accurate reporting, and reinvestigation provisions of the Fair Credit Reporting Act (FCRA), 15 U.S.C. §§ 1681g(a)(2), 1681e(b), 1681i(a)(6)-(7).

 

The trial court dismissed one of the plaintiff's FCRA claims under Fed. R. Civ. P. 12(b)(6), denied leave to amend that claim, and granted summary judgment to the CRA on the plaintiff's remaining FCRA claims. In its ruling on the CRA's summary judgment motion, the trial court found that the description of the judgment as "satisfied" was accurate. The plaintiff timely appealed.

 

The Second Circuit noted that the overwhelming weight of authority in the Circuit "holds that a credit report is inaccurate [under § 1681e(b)] either when it is patently incorrect or when it is misleading in such a way and to such an extent that it can be expected to have an adverse effect." Khan v. Equifax Information Services, LLC, No. 18-cv-6367 (MKB), 2019 WL 2492762, at *3 (E.D.N.Y. June 14, 2019).

 

The plaintiff acknowledged that the court in the debt collection action reported that the case against him was "settled." The plaintiff also did not dispute that the CRA was following a standard practice in the credit reporting industry by reporting a settled debt-collection judgment as "satisfied."

 

The plaintiff however argued that, when the court in the debt collection action ordered the stipulation, it also implicitly vacated the judgment. Thus, he maintained that the defendant was obligated to report the judgment as "vacated." The plaintiff also contended that, by denoting the judgment as "satisfied," the CRA misled its readers because it implied that a judgment remained.

 

However, the Second Circuit observed that the court docket did not reflect a vacatur. Also, the Court held that describing a judgment as "satisfied" does not imply that it "remains;" if anything, according to the Court, it implies the opposite.

 

The Second Circuit therefore held that the accuracy of the plaintiff's credit report was fatal to his § 1681e(b) claims that the CRA engaged in willful or negligently inaccurate reporting. Therefore, the Court affirmed the trial court's judgment dismissing those claims.

 

Furthermore, the trial court granted summary judgment to the CRA on the plaintiff's § 1681g source-disclosure negligence claim based upon its conclusion that, even if the CRA should have disclosed LexisNexis as a "source" of information on the judgment, the plaintiff presented no evidence that he suffered any actual damages resulting from the failure. On appeal, the CRA adopted the trial court's "no-actual-damages" approach to argue for affirming the trial court's judgment with regard to the plaintiff's § 1681i reinvestigation negligence claim as well as the § 1681g source-disclosure claim.

 

The Second Circuit agreed with the CRA that the plaintiff had failed to present any evidence for concluding that he suffered actual damages as a result of the CRA not disclosing or treating the judgment reporting service as a "source" or "furnisher" of information to it about the judgment.

 

Because the Court held that the credit report was accurate, the Court also concluded that the plaintiff's learning that the judgment reporting service was the intermediary source of the CRA's information would not have enabled the plaintiff to avoid the emotional damages that he claimed to have suffered. Nor would he have avoided any of the costs he claimed to have incurred in disputing the credit report.

 

Accordingly, the Court held that the CRA was entitled to summary judgment on the plaintiff's § 1681g and § 1681i negligence claims.

 

The trial court also dismissed the plaintiff's § 1681g willfulness claim after concluding that the CRA reasonably interpreted "source" not to include a contractor-intermediary doing what the judgment reporting service did in this case. In responding to the plaintiff's arguments on appeal, the CRA also contended that its position that the judgment reporting service did not constitute a "furnisher of information" under § 1681i was reasonable, despite the trial court's determination otherwise (and despite the trial court's award to the CRA of summary judgment on the claim on a different basis).  

 

As you may recall, in Safeco Insurance Company of America v. Burr, the Supreme Court of the United States held that a credit reporting agency may "willfully" violate the FCRA by acting in "reckless disregard of statutory duty." 551 U.S. 47, 57 (2007). The SCOTUS explained that a company does not act in "reckless disregard" of the FCRA, however, if its "reading of the statute . . . was not objectively unreasonable." Id. at 69.

 

The FCRA's reinvestigation provision requires that, under certain circumstances, consumer reporting agencies provide information about "any furnisher of information contacted in connection with such information, and also that consumer reporting agencies provide notice of consumer disputes to "furnisher[s] of information." Id. § 1681i(a)(6). It defines "furnisher" to include "any person who provided any item of information in dispute." Id. § 1681i(a)(2). The defendant argued that it is reasonable for an agency to construe this provision to exclude its own contractor charged with gathering public records on the agency's behalf.

 

Additionally, the FCRA's source-disclosure rule requires consumer reporting agencies to disclose to the consumer, on request, the "sources of the information" in the consumer's file. Id. § 1681g(a)(2). The defendant argued that it is a reasonable construction of the statute to interpret "sources of information" as referring to the original source of the reported information, as opposed to any contractors that gathered the information on an agency's behalf.

 

The Second Circuit agreed with the CRA and held that it was an objectively reasonable reading of these provisions to exclude from "furnisher" and "sources" a contractor such as LexisNexis working on the reporting agency's behalf when the information in question was contained in a particular set of files, the consumer reporting agency identified the court and its files as the "furnisher" or "source" of the information, and the function of the undisclosed contractor was to check those files to determine the accuracy of the report.

 

Moreover, the Second Circuit rejected the plaintiff's argument that the CRA needed to show that it actually and contemporaneously adopted this statutory interpretation to avail itself of the Safeco defense. The Court noted that the Safeco court emphasized that whether a company committed a willful violation of the FCRA is an objective inquiry and dismissed arguments that "evidence of subjective bad faith" could create liability in the face of objectively reasonable interpretations. Safeco, 551 U.S. at 70 n.20

 

Accordingly, the Second Circuit held that when the CRA advised its customers that the judgment against the plaintiff was "satisfied," it gave an accurate report. Also, the Court purposefully did not decide whether the FCRA might be read to obligate the CRA to respond to the plaintiff's source disclosure and reinvestigation requests by informing him of the judgment reporting service's role because (1) § 1681g and § 1681i can reasonably be interpreted to not require such a disclosure; and (2) even if the CRA was negligent in determining its obligations under those provisions, the plaintiff pointed to no harm he suffered as a result.

 

Therefore, the Second Circuit affirmed the trial court's judgment.

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 6^th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

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FYI: Maryland High Court Holds Unlawful Threat of "Self-Help Eviction" Enough to Sue

The Maryland Court of Appeals, the highest court in the State, recently that:

 

(1) the plaintiffs owners and tenants of residential properties set forth a cause of action under Md. Code Real Prop. 7-113 against a mortgage servicer and real estate broker for supposedly posting eviction notices without first ascertaining the occupancy status, even though the notices did not cause the occupants to vacate the properties; and

 

(2) the Court has not established a more demanding standard for pleading damages in private actions brought under the Maryland Consumer Protection Act (MCPA).

 

A copy of the opinion is available at:  Link to Opinion

 

The petitioners, who were all occupants of residential property that they owned or leased, brought this action against the respondents, a mortgage servicer and a real estate broker, after the respondents posted eviction notices on the petitioners' properties in an attempt to gain possession of the properties without a court order. The petitioners claimed that the respondents violated Md. Code Real Prop. (RP) § 7-113 and the Maryland Consumer Protection Act (MCPA), Md. Code Comm. Law § 13-101 et seq.

 

As you may recall, RP § 7-113 restricts the use of self-help in certain kinds of residential evictions. Without a court order, a person claiming the right to possession of a residential property may only resort to self-help evictions if the person posts a notice that complies with the requirements of the statute, and only if he or she "reasonably believes the protected resident has abandoned or surrendered possession of the property based on a reasonable inquiry into the occupancy status of the property[.]" RP § 7-113(b)(2)(ii)(1).

 

Although the respondents' actions did not cause them to leave, the occupants alleged that the respondents' unlawful act of allegedly posting the eviction notices without ascertaining the occupancy status of the property caused them to suffer two forms of compensable damages — (1) "emotional damages and losses with physical manifestations" such as fear that they would lose their home; and (2) economic damages in the form of attorney's fees they incurred to understand their rights.

 

The respondents filed motions to dismiss the amended complaint on the basis that it failed to state a cause of action. The trial court granted both motions. The intermediate appellate court affirmed the trial court's judgment.

 

The intermediate appellate court determined that the amended complaint alleged facts that, if proven, established that the respondents violated RP § 7-113. However, the intermediate appellate court concluded that a private cause of action arising under RP § 7-113 is only extended to residents who vacate the property as the result of the improperly posted eviction notice. The intermediate appellate court further determined that, assuming that the respondents' actions violated the MCPA, the amended complaint failed to allege damages with the specificity required for private causes of action under that statute.

 

The Maryland Court of Appeals reversed the intermediate appellate court's judgment in part and affirmed in part.

 

First, the Maryland Court of Appeals held that the occupants' amended complaint adequately set forth a cause of action under RP § 7-113(d) and that the plain language of the statute does not require that a protected resident be deprived of actual possession as a condition to bringing a private cause of action. The Court observed that subsection (b)(1) prohibits a variety of conduct, including the claiming party taking actual possession, but also threats to take possession.

 

Furthermore, the Maryland Court of Appeals did not agree with the intermediate appellate court's conclusion that the Court's jurisprudence had established a more demanding standard for pleading damages in private actions brought under the MCPA. Instead, the Court held that the general rule of pleading as articulated in Maryland Rule 2- 302(b) applied here.

 

Maryland Rule 2- 303(b) states that:

 

Each averment of a pleading shall be simple, concise, and direct. No technical forms of pleadings are required. A pleading shall contain only such statements of fact as may be necessary to show the pleader's entitlement to relief or ground of defense. It shall not include argument, unnecessary recitals of law, evidence, or documents, or any immaterial, impertinent, or scandalous matter.

 

The intermediate appellate court cited Lloyd v. GMC, 397 Md. 108 (2007) and Citaramanis v. Hallowell, 328 Md. 142 (1992) in reaching its conclusion, but the Maryland Court of Appeals concluded that those cases did not change the pleading standard, but instead those cases held that actual damages need to be pleaded in a private cause of action brought under the MCPA.

 

In other words, because "actual loss or injury" is a necessary element to bring a private cause of action under the MCPA, the Court held that actual damages need to be pleaded in the same fashion as would be required under Maryland Rule 2- 302(b) in any other cause of action where the plaintiff seeks money damages.

 

In order to recover damages for an emotional injury, the Maryland Court of Appeals held that the emotional injury must be accompanied by a physical injury, which the plaintiff would be required to prove by some objective physical manifestation. See Hoffman v. Stamper, 385 Md. 1, 39 (2005); Vance v. Vance, 286 Md. 490, 500 (1979).

 

Here, the Court concluded that the occupants alleged that the respondents' unlawful acts of posting eviction notices, without undertaking the required "reasonable inquiry" to determine whether the property had been abandoned, caused them to suffer emotional damages and losses with physical manifestations.

 

However, the Maryland Court of Appeals affirmed the judgment of the intermediate appellate court with respect to the petitioners' assertion that they were entitled to their attorney's fees incurred to "know their rights" as separate compensable damages. The Court held that, under both RP § 7-113 and the MCPA, the petitioners would be entitled to their reasonable attorney's fees incurred to prosecute their case (assuming they prevail).

 

But the Court determined that the petitioners' damages claim related to their pre-litigation, consultation fees did not fall within any of the common law exceptions to the "American Rule," which prohibits recovery of attorney's fees as separate compensable damages. Alyeska Pipeline Service Co. v. Wilderness Society, 421 U.S. 240, 247 (1975)

 

Accordingly, the Maryland Court of Appeals reversed in part and affirmed in part.

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 6^th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia   |   Illinois   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Tennessee   |   Texas   |   Washington, DC

 

 

NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.

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