Category Archives: Bankruptcy Help

When Chapter 7s Are Not So Simple

The goal of most Chapter 7 cases is to get in and get out—file the petition, go to a hearing with your attorney a month later, and two months after the hearing, your debts get written off. Mission accomplished, end of story. And usually that’s how it goes. What are some reasons that a Chapter 7 case doesn’t go that way?

Four main kinds of problems can happen:

Income

Under the “means test,” if you made or received too much money in the 6 full calendar months before your Chapter 7 case is filed, you can be disqualified from Chapter 7. As a result, you can be forced into a 3-to-5 year Chapter 13 case, or have your case be dismissed altogether. These results can be avoided by careful timing of your case filing, or by making changes to your income beforehand, or by a proactive filing under Chapter 13.

Assets

In Chapter 7, if you have an asset that is not “exempt” (protected), the Chapter 7 trustee will be entitled to take and sell that asset, and pay the proceeds to your creditors. You might be happy to surrender a particular asset you don’t need in return for the discharge of your debts, in particular if the trustee is going use the proceeds in part to pay a debt that you want paid, such as a child support arrearage or an income tax obligation. But you may not want to surrender that asset, either because you think it is worth less than the trustee thinks or because you believe it fits within an exemption. Or you may simply want to pay off the trustee for the privilege of keeping that asset. In all these “asset” scenarios, there are complications not present in an undisputed “no asset” case.

Creditor Challenges to Discharge of a Debt

Creditors have the limited right to raise objections to the discharge of their individual debts, on grounds such as fraud, misrepresentation, theft, intentional injury to person or property, and similar bad acts. In most circumstances, the creditor must raise such objections within about three months of the filing of your Chapter 7 case. So once that deadline passes you no longer need to worry about this, as long as that creditor got appropriate notice of your case.

Trustee Challenges to Discharge of Any Debts

If you do not disclose all your assets or fail to answer other questions accurately, either in writing or orally at the hearing with the trustee, or if you fail to cooperate with the trustee’s investigation of your financial circumstances, you could lose the ability to discharge any of your debts. The bankruptcy system relies on the honesty and accuracy of debtors. So the system is quite harsh toward those who abuse the system by trying to hide things.

To repeat: most of the time, Chapter 7s are straightforward. That’s especially true if you have been completely honest and thorough with your attorney during your meetings and through the information and documents you’ve provided. In Chapter 7 cases that I do for my clients, my job is to have those cases run smoothly. I do that by carefully reviewing my clients’ circumstances to make sure that there is nothing troublesome, and if there is, to address it in advance in the best way possible. That way we will have a smooth case, or at least my clients will know in advance the risks involved. So, be honest and thorough with your attorney, to increase the odds of having a simple Chapter 7 case.

Discuss your financial situation with bankruptcy attorney Jennifer N. Weil by scheduling a phone appointment at (201) 676-0722 or by emailing weilattorney@gmail.com.

Chapter 7 Bankruptcy After Closing Your Business – Factors to Consider

Meta Description: Filing for Chapter 7 bankruptcy after shutting down your business may seem like the best option, but there are three key factors to consider: assets, taxes, and other non-dischargeable debts. Consult with a lawyer to determine what’s best for you.

Introduction:

Closing down a business can be a difficult and emotional experience. After all the hard work and effort put into making it successful, it can be tempting to file for Chapter 7 bankruptcy for a fresh start. However, it’s important to consider the consequences before making a decision. In this blog post, we will discuss three factors to consider when deciding whether Chapter 7 bankruptcy is the right choice for you after closing your business.

  1. Business Assets:

Chapter 7 bankruptcy is divided into two categories: “no asset” and “asset.” In a “no asset” case, the Chapter 7 trustee decides that none of your assets are worth taking and selling to pay creditors. On the other hand, if your recently closed business has assets that are not exempt and are worth the trustee’s effort to collect and liquidate, it’s important to discuss with a lawyer whether Chapter 7 is in your best interest compared to what would happen to those assets in a Chapter 13 case.

  1. Taxes:

Closed-business bankruptcy cases often involve tax debts. While some taxes can be discharged in a Chapter 7 case, most cannot. Chapter 13 is often a better way to deal with taxes as it will depend on the type of tax and a series of other factors such as the time the tax became due and whether a tax return was filed.

  1. Other Non-dischargeable Debts:

Closed-business bankruptcies can result in more creditor challenges to the discharge of debts compared to other bankruptcy cases. These challenges are usually based on allegations of fraud against the business owner. Depending on the nature of the allegations, Chapter 13 may give you certain legal and tactical advantages over Chapter 7.

Conclusion:

Filing for Chapter 7 bankruptcy after closing down your business may seem like the best option, but it’s important to consider all factors before making a decision. The three factors discussed in this blog post – business assets, taxes, and other non-dischargeable debts – can play a significant role in determining what is best for you. It’s recommended to consult with a lawyer to help you make an informed decision.

If you are considering bankruptcy, it’s worth discussing your options; make a free phone appointment with Jennifer N. Weil, Esq. by clicking here.

Business Disputes and Bankruptcy: Avoiding Creditor Challenges

Creditors can challenge the discharge of your debts in a bankruptcy case, especially when the bankruptcy is filed after a business shuts down. To avoid these challenges, it’s important to understand why they happen and what can be done to prevent them.

Reasons for Creditor Challenges:

  • Larger debt amounts, making litigation more tempting
  • Personal debtor-creditor relationships
  • Risky behavior by the business owner
  • Creditors may know about the debtor’s risky behavior

Often, former business owners considering bankruptcy feel that a creditor will challenge the discharge of their debts in court. But such challenges are relatively rare, for the following legal and practical reasons:

1. The legal grounds under which challenges to discharge can be raised are relatively narrow. Instead of proving the existence of a valid debt—as in a conventional lawsuit to collect on a debt—the creditor has to prove that the debtor engaged in behavior such as fraud in incurring the debt, embezzlement, larceny, fraud as a fiduciary, or intentional and malicious injury to property.

2. In bankruptcy, the debtor files under oath a set of extensive documents about his or her finances, and is also subject to questioning by the creditors about those documents and about anything else relevant to the discharge of the debts. When these documents, along with any questioning, reveal that the debtor genuinely has nothing worth chasing—as is most often the case—this tends to cool the anger of most creditors. Only the most motivated of creditors will be willing to throw the proverbial good money after bad in the hopes of getting nothing more than a questionably collectible judgment.

In conclusion, a dischargeability challenge can turn a simple bankruptcy case into a complex one. Hiring an experienced bankruptcy attorney can help you avoid challenges and defend against them if necessary. Contact an attorney if you have reason to believe that a creditor may challenge the discharge of your debts.

To discuss options – bankruptcy and non-bankruptcy – in resolving your debt, schedule a free telephone call with New Jersey bankruptcy attorney Jennifer N. Weil, Esq. at this Setmore page or by emailing weilattorney@gmail.com.

Protecting Yourself When Your Business Has to Shut Down

Protecting yourself when your business has to shut down is important, since you may be personally liable for your business debts, even after you close your small business.

Protecting Yourself When Your Business Has to Shut Down

If you’re considering closing down your struggling business, you may be concerned about personal damage control: how do you end the business without being pulled down with it? If you are responsible for the debts of your former business, your creditors may sue you personally in an attempt to collect on those debts.

Often, business owners are confused as to whether they are personally responsible for business debts since those debts often do not appear on their personal credit report. But debt does not need to appear on a credit report for you to be personally responsible for it. Protecting yourself when your business has to shut down becomes a top priority when you are personally liable for the debts of your former business.

Sometimes a business owner, operating their business as a sole proprietorship, accumulates a lot of personally-guaranteed debt while trying to keep the business operating. Where the business owner has accumulated too much debt, they may need bankruptcy relief.

Let’s look at three options for bankruptcy relief in a situation like this: 1) A no-asset Chapter 7 case, 2) An asset Chapter 7 case, and 3) A Chapter 13 case.

No-Asset Chapter 7 for a Fast Fresh Start

After putting so much effort and hope into your business, once you accept the reality that you have to give up on it, you may want to clean it up as fast as possible. And in fact, a regular Chapter 7 bankruptcy may be the most consistent with both your gut feelings and with your legal realities.

IF everything that you own—both from the business and personally—fits within the allowed asset exemptions, then your case may be fairly simple and quick. A no-asset Chapter 7 case is usually completed from filing date to closing date in about three months. If none of your assets are within the trustee’s reach, then there is nothing to liquidate and distribute among your creditors, a process that can take a long time.

But this assumes that all your debts can be handled appropriately in a Chapter 7 case—the debts that you want to discharge (write off) would be discharged and those that would not are the ones that are not dischargeable under bankruptcy law. Non-dischargeable debts often include certain taxes, support payments, and perhaps student loans.

Asset Chapter 7 Case As a Convenient Liquidation Procedure

If you do have some assets that are not exempt, that alone may not be a reason to avoid Chapter 7. Assuming that those are assets that you can do without—and maybe even are happy to be rid of, if they came from your former business—letting the bankruptcy trustee take and sell them may be a sensible and fair way of putting the past behind you.

That may especially be true if you have some debts that you would not mind the trustee paying out of the proceeds of selling your non-exempt assets. You can’t predict with certainty how a trustee will act, but this is something to keep in mind.

Chapter 13 to Deal with the Leftover Consequences

Even if you’d prefer putting your closed business behind you quickly, there may be fallout from that business that a Chapter 7 would not deal with adequately. For example, if the business left you with substantial tax debts that cannot be discharged, non-exempt assets that you need to protect, or a significant mortgage arrearage, Chapter 13 could provide you with a better way of dealing with these kinds of creditors. Deciding between Chapter 7 and 13 when different factors point in different directions is where you truly benefit from having a highly experienced bankruptcy attorney help you make that delicate judgment call.

Schedule a telephone call to discuss your situation with NJ bankruptcy attorney Jennifer N. Weil, Esq. at (201) 676-0722, schedule your own consultation on my Setmore page, or email weilattorney@gmail.com.

2 Ways to Use Bankruptcy To Close Your Business

2 ways to use bankruptcy to close your business involves leaving your business debt behind so that it does not come back to haunt you personally.

Closing down a business can be messy. Business bankruptcy is often more complicated than a regular bankruptcy case. But in one way, a business bankruptcy may be easier than a consumer bankruptcy case.

If you’ve owned a small business that you have shut down, or that you are about to shut down, you may be afraid of filing bankruptcy because you’ve heard that “business bankruptcies” are expensive and not a good way to wrap up the affairs of a business. However, bankruptcy can be a simple and effective solution.

The Means Test

The “means test” determines whether you may file a regular Chapter 7 case to discharge your debts in a few months, or whether you must file a 3-to-5-year Chapter 13 repayment case. Unless you need some of the other benefits of Chapter 13, many people prefer Chapter 7 because it gets them a fresh start more quickly and cheaply.

In some situations, a former business owner cannot pass the means test and will be required to go through Chapter 13. For example:

    • If, after closing her business, a business owner got a good job before filing bankruptcy, the income from that job may be higher than the “median income” applicable to her state and family size. So she may not pass the “means test.”
    • If the business was operated by one spouse while the other worked an outside job and earned a high income, the other spouse’s income may bump the couple above the “median income” with the result of not passing the “means test.”

But here’s the good news for some former business owners: the “means test” only applies if your “debts are primarily consumer debts.” (See Section 707(b)(1) of the Bankruptcy Code.) So if your debts are primarily business debts—more than 50%–you essentially can skip the “means test.”

Be careful here, because “debts” means all debts, including home mortgages and personal vehicle loans. So your business debts may have to be high to be more than all your consumer debts.

To apply this law, we must be clear about the difference between these two types of debts. What’s a “consumer debt”? The definition may sound familiar: it’s a “debt incurred by an individual primarily for a personal, family, or household purpose.” (Section 101(8).)  For example, if you took out a second mortgage on your home a few years ago to fund your business, the current balance on that second mortgage may not be a consumer debt.

Sometimes the line between consumer and non-consumer debt is not clear, so this is something you need to discuss thoroughly with your attorney if you want to avoid the “means test” under this “primarily business debts” exception.

If you have questions about qualifying for bankruptcy, call to schedule a free telephone appointment with Jennifer N. Weil, Esq. to discuss your situation at (201) 676-0722 or by emailing weilattorney@gmail.com.

Why Bankruptcy Means Test Timing Is Critical

Waiting just one day to file your Chapter 7 bankruptcy case can make qualifying for it much easier—or much harder!

How could a small delay make such a big difference?

One of the goals behind the change in bankruptcy law in 2005 was to force more people to pay a portion of their debts through Chapter 13 payment plans instead of writing them off in Chapter 7 “straight bankruptcy.” And the primary tool for this is the means test. The rationale behind the means test was to have a financial test that would find out who had the “means” to pay something to their creditors in Chapter 13.

But rules can have unintended consequences. An experienced lawyer will work to turn these consequences to your advantage.

Why bankruptcy means test timing is critical

The means test compares the income you received during the six FULL CALENDAR months before filing bankruptcy to the median income for your state and family size. If your income is at or under the median income, then you can file a Chapter 7 (except in unusual circumstances, which I’m not going to get into here). If your income is higher than the median, you may be able to file a Chapter 7, but you have to jump through hoops to do so. And there’s a risk that you will be forced to go through a Chapter 13 payment plan.  Having income below the median income amount makes your case less risky.

But how can filing the case a day earlier or later matter so much? Because of the means test’s fixation on those six full calendar months. And because the means test includes ALL income during that period (other than Social Security).  All of the money that comes into your hands during that period is counted, not just taxable income.

Imagine that you received a chunk of money, say a tax refund, a few catch-up child support payments, or an insurance settlement or reimbursement.  Not a huge amount, say $3,000, received on July 15 of last year. Your only other income is from your job, where make a $42,000 salary, or $3,500 gross per month. Let’s say that the median annual income for your state and family size is $43,000 (this is just an example – the median income for New Jersey is much higher, thank goodness).

Now we’re getting close to the end of January, your Chapter 7 bankruptcy paperwork is ready to file, and you’re anxious to get it filed. BUT, if your case is filed on or before January 31, then the last six full calendar month period will be from July 1 through December 31 of last year, which includes that $3,000 you received in mid-July. Your work income of 6 times $3,500 equals $21,000, plus that $3,000 totals $24,000 received during that 6-month period. Multiply that by 2 to make that an annual amount, and that equals $48,000, higher than the $42,000 median income. So you’d have failed the income portion of the means test.

But if you just wait to file until February 1, the applicable 6-month period jumps forward by 1 month to the period from August 1 of last year through January 31 of this year. That new period does NOT include the $3,000 you received in mid-July. Now your income during the 6-month period is $21,000, multiplied by 2 is $42,000. You would be under the $43,000 median income. You’ve passed the income portion of the means test, and you can skip the awkward and risky expenses part of the means test. You’re more likely to breeze through your Chapter 7 case.

Last thing: what if that $3,000 was not received almost 6 months ago, but rather 2 or 3 months ago, and you’re desperate to file your case? You need to stop a garnishment or foreclosure and you can’t wait another few months to file. If you file now, you will be over the median income, and you will need to do the expenses part of the means test. You may be OK there. But careful pre-bankruptcy planning is critical. The sooner we start, the more likely time will be on your side.

How To Keep Your Car in a Chapter 7 Bankruptcy

Chapter 7 bankruptcy gives you a couple of options for your car when you’re still paying on it. Basically, you can either keep paying or you can surrender (i.e., give back) the vehicle.

What’s The Situation?

This is about a vehicle that you still owe on, where your finance company is the lienholder on your vehicle title, and where there’s no more equity (value beyond the debt) than is covered by your available exemptions. In other words, this is not a vehicle that your Chapter 7 trustee is going to be interested in, either because it has no equity (e.g., it’s worth less than the debt against it) or because the equity is small enough to be protected by the exemption. The following options also apply to car leases.

Ch. 7 Options For Your Car

Even if the bankruptcy trustee doesn’t want your car, your car finance company might. But if you need to keep the car, especially for work, there is a certain path that you need to follow.

How To Keep Your Car in a Chapter 7 Bankruptcy

  1. First, if you don’t want to keep your vehicle, you can surrender it to the creditor after your bankruptcy is filed. (Or you can surrender it before you file, but that gets risky—be sure you have talked to your bankruptcy attorney and have a clear game plan beforehand.) If you give back your vehicle without bankruptcy, you’ll owe and you might be sued for the “deficiency balance”—the amount you would owe after your vehicle is sold, its sale price is credited to your account, and all the repo and other costs are added. (The deficiency balance you’ll owe can be crazy high.) But bankruptcy will write off (i.e., discharge) the deficiency balance.
  2. If you want to keep your car through a Ch. 7, you have to be current on your loan. In other words, make your car payments during bankruptcy. So if you aren’t current, you’ll need to quickly get current and stay there. Some lenders will allow you to be a month or so behind on your loan, but I’ve found that when a bankruptcy has been filed, they suddenly change their tune and they want to you be current on your payments. Depending on the lender, you might need to sign a reaffirmation agreeing to legally exclude the vehicle loan from the bankruptcy discharge, but most lenders don’t work that way. I generally don’t recommend a reaffirmation agreement except under certain narrow circumstances. You should discuss this issue with an experienced bankruptcy attorney before your bankruptcy is filed.

The Takeaway

In general, “straight bankruptcy”—Chapter 7—can be the best way to go if your vehicle situation is pretty straightforward: you either want to give back your car, or you want to keep the car and you’re current on the loan or can quickly get current.

If you have questions about how to keep your car in a Chapter 7 bankruptcy  – or about how to get rid of it – schedule an appointment with Bankruptcy Attorney Jennifer N. Weil, Esq. by calling 201-676-0722. Or you can schedule your own appointment online at my Setmore page.

 

Debts with Collateral–THE Fixation of Many Bankruptcies

Your car loan, home mortgage, account at the appliance or electronics store, and maybe a debt that’s resulted in a judgment lien—these debts with collateral are the ones that grab the most attention during a bankruptcy case. And that includes the attention of the creditors, very interested in “their” collateral.

General unsecured debts are pleasantly boring in most bankruptcy cases. In a Chapter 7 case, they are generally discharged (legally written off) without any opposition by the creditors, who usually get nothing. And in a Chapter 13 case, general unsecured debts are often just paid whatever money is left over after the secured and priority debts, and the trustee and attorney fees, are paid. Nice and boring. That’s because the creditors don’t have much to fight about.

But with secured debts—debts with collateral—both sides have something to fight about: the collateral. The creditors know that the vehicle or house or other collateral is the only thing backing up the debt you owe to them, so they can get quite pushy about protecting that collateral.

There are a few basic points to remember that apply to just about all secured debts:

Two Deals in One

It helps to look at any secured debt as two interrelated agreements between you and the creditor. First, the creditor agreed to give you money or credit in return for your promise to repay it on certain terms. Second, you received rights to—and usually title in—the collateral, with you in return agreeing that the creditor can take that collateral if you don’t comply with your first agreement to repay the money.

Generally, bankruptcy will absolve you of that first agreement—your promise to pay—but the creditors’ rights to collateral survive bankruptcy (except in certain rare situations we will highlight later). Your ability to discharge the debt gives you some options, and can sometimes give you a certain amount of leverage. But the creditors’ rights to the collateral give them certain options and leverage, too. You’ll see how this tug-of-war plays out with vehicle and home loans, and few other important secured debts.

Value of Collateral

In that tug-of-war between your power to discharge the debt and a creditor’s rights to the collateral, how much the collateral is worth as compared to the amount of the debt becomes important. If the collateral is worth a lot more than the amount of the debt, the creditor is said to be well-secured. It has a better chance of having the debt paid in full. You’ll want to pay off the relatively small debt to get the relatively expensive collateral free and clear of that debt. Or, if you didn’t make the payments, the creditor will get the collateral and sell it for at least as much as the debt.

If the collateral is worth less than the amount of the debt, the creditor is said to be “undersecured”. It is less likely to have this debt paid in full. You might be less likely to pay a debt only to get collateral worth less than what you’re paying. And if you surrender the collateral the creditor will sell it for less than the debt amount.

Depreciation of Collateral, and Interest

With the value of the collateral being such an important consideration, the loss of value through depreciation is something that creditors care about, a concern which the bankruptcy court respects. Also, secured creditors are usually entitled to interest. So, you’ll see that in fights with secured creditors, this issue about the combined amount of monthly depreciation and interest often comes into play.

Insurance

Virtually every agreement with a secured creditor—certainly those involving vehicles and homes—requires that you carry insurance on the collateral. If the collateral is damaged or destroyed, this insurance usually pays the debt on the collateral before it pays you anything. And, if you fail to get the required insurance—or sometimes even if you simply don’t inform the creditor about having the insurance—the creditor itself is entitled to buy “force-placed” insurance to protect only its interest in the collateral, AND charge you the often outrageously high premium.

Avoid using credit cards before bankruptcy

Using credit cards to buy holiday gifts could mean that you will have to pay back those credit charges if you file for bankruptcy. This is a possibility even if you intended to pay on the cards when you made those purchases.

The Bankruptcy Code has specific rules about the consequences of using credit to buy “luxury goods or services” during the months before a bankruptcy filing.  One rule is that if you use a credit card—or any other type of consumer credit—to buy more than $500 of consumer “luxury goods or services” through a single creditor within the 90 days before filing bankruptcy, a “presumption” is created that this debt is not dischargeable in bankruptcy.

Don’t let the word “luxury” deceive you – it is used to mean anything not “reasonably necessary” to support you or your dependents. Anything not used for survival is arguably not reasonably necessary. Even modest holiday gifts could be considered luxuries under this rule.

Another, similar rule applies to cash advances, except that the trigger dollar amount is $750 per creditor, and the period of time is within 70 days before filing bankruptcy, with the same presumption that the debt would not be dischargeable.

While it is true that such presumptions can be defeated, it is not likely in practice. This is because coming up with the evidence necessary to overcome the presumption (you’d have to prove that you intended to pay the money back at the time you borrowed it) is usually not easy. And the high cost of showing the evidence to the court during a separate proceeding normally makes trying to do so not worthwhile. The attorney fees it would cost you to fight the issue would likely be more than the original amount you’re fighting over.

The bottom line is that if  you use consumer credit exceeding these dollar limits this holiday season and then file bankruptcy within the applicable 70 and 90-day periods, you will most likely have to pay for whatever credit charges you incurred during those periods. You can avoid these presumptions by waiting to file the bankruptcy until after those time periods have passed, but that isn’t always possible due to pending wage garnishments or other types of judgment execution. And even if you do wait, the creditor can still try to show that you had a bad intention when you made these credit charges. It’s best to just avoid the problem altogether by not using your credit cards or other lines of credit when there’s even an outside chance that you might need to file for bankruptcy.

Got debt problems? Call (201) 676-0722.

“If Only I’d Gone to See My Bankruptcy Attorney Sooner . . . “

Those are the words I hate to hear from a new client.

Bankruptcy attorneys are in the business because we want to help people. It’s an emotionally tough area of law, dealing all the time with clients who are financially hurting. Usually my clients are also hurting in other ways that are related to the cause of their financial problems—illness, injury, divorce, a decline in business, or a job loss. What makes my day is to give great news to a client, that they will now get relief from their debts, or that there is a feasible plan to save their home, or to deal with their child support arrearage or their income tax debt.

The information I share with clients is what they are unaware of before they contact me and it is what they need to know. There may be tough choices to make. I am here to arm you with the law and to guide you through the process.

But the most frustrating situations for both me and my clients are when we find out that they have self-inflicted wounds. These wounds are the easily-preventable-but-now-it’s-too-late bad decisions they’ve made, often just a few months or weeks earlier, without getting legal advice beforehand.

Here’s are some of the most common issues:

1) Preferences:  If you pay a creditor any significant amount before filing a bankruptcy—especially a relative you hope not to involve in that bankruptcy—the bankruptcy trustee may well be able to force that relative, through a lawsuit if necessary, to pay to the trustee whatever amount you paid to that relative.  The trustee can then turn around and pay that money to your creditors.

2) Squandering exempt assets:  Many clients tell me that they have borrowed against or cashed in retirement funds in a desperate effort to pay their debts, using precious assets that would have been completely protected in the bankruptcy case they later file.  Unfortunately, these clients use their retirement money to pay debts that would have been discharged in their bankruptcy.

3) Rushing to sell a home:  Bankruptcy provides some extraordinary tools for dealing with debts that have attached as liens against your home, such as judgments and 2nd mortgages. If you hurriedly sell your home to avoid involving it in your bankruptcy case, or for some other reason, you could lose out on opportunities to save tens of thousands of dollars.

As you look at this list, notice that the legally and financially wrong choice is often what seems to be 1) the morally right one, and 2) the common-sense one. Doing what seems right and sensible can really backfire. But nothing takes the place of legal advice about your own unique situation from an experienced attorney. Avoid ever having to say “if only I had gone in sooner.”

Jennifer N. Weil, Esq. offers free bankruptcy consultations by telephone – please call (201) 676-0722.

Photo by striatic.