BANKING

& FINANCE
October 2010

LLCS: NOT AS CREDITOR-RESISTANT AS THEY USED TO BE

By: Patrick S. Scott, Esq. & Jeffrey T. Kuntz, Esq.

The Florida Supreme Court on June 24 dealt a blow to what has
long been regarded as an unassailable immunity from creditors—the
debtor’s membership interest in a limited liability company. The
Court held, in a 5-2 decision, that the judgment creditor of a debtor,
who is the sole member of an LLC, may obtain an order from a court
forcing the debtor to endorse and surrender all of her right, title,
and interest in her ownership/equity unit certificate permitting the
creditor to liquidate the assets of the LLCs itself. Olmstead v. Fed.
Trade Comm’n, Case No. SC08-1009 (Fla., June 24, 2010).
Commentators among the community of asset planning professionals
generally believed that LLC statutes, structured
to limit both individual liability for company
debts and the exposure of company assets to
individuals’ debts, provided the same protection
for single-member LLCs as for multiple-member
LLCs. The only remedy for creditors provided
in the LLC Act, Florida Statutes chapter 608,
is a “charging order,” issued by the court to
block the judgment debtor from receiving any
economic benefit from the debtor’s membership
interest in the LLC. This economic benefit could
include distributions, liquidation proceeds, or
even deductible tax losses.
However, charging orders put the judgment
creditor only in the position of an “assignee” of the interest. Unless
there is contrary language in the LLC articles of organization or
operating agreement, or all members consent, an assigned membership
interest has no power to participate in management of the company’s
financial or business affairs. For this reason, a creditor holding a
charging order may expect that no distributions will be voted to the
member whose interest in the LLC has been diverted to the creditor.
If the company is manager-managed, rather than member-managed,
an insolvent managing member may even continue to manage the
company while a charging order is outstanding.
Although the LLC statute doesn’t state that charging orders provide
the exclusive remedy for reaching a member’s interest, courts have
struggled to justify any collection device that forces an LLC to reduce
the debtor’s equity interest to money and to distribute it to the
creditor. Traditionally, for a lender to recover the full value of an LLC
membership interest, it has been necessary for the lender to obtain a
security interest or pledge with the agreement of the LLC management,
and, under most LLC articles of organization this requires unanimous
consent of the members. To fashion remedies stronger than a charging
order, courts have looked for evidence of debtor misconduct. Such
remedies include: constructive trusts over traceable fraud proceeds;
piercing the shield of the LLC upon a showing of
improper use; and supplementary proceedings to
reverse the debtor’s capitalization of the company
under fraudulent transfer theories. Involuntary
bankruptcy petitions also are sometimes filed
to invoke the broad reach of bankruptcy court
powers over property rights of the debtor, which
include LLC interests.
Now, however, the Florida Supreme Court
has distinguished single-member LLCs from
multiple-member LLCs, and permitted the forced
liquidation of the LLC itself. It reasoned that a
charging order splits the debtor’s membership
interest into its economic component (essentially assigned to the
creditor) and its legal component (which ceased because the assignee
cannot take the legal status of member without the consent of all other
members), and that the sole member of an LLC should have no basis
to complain if the entire interest is voted for liquidation, even though
the statute has no provision for such a result. The majority of the
justices pointed to Florida’s execution statute, which specifically
permits levies on corporate stock certificates, as justification for the
new remedy. The new decision by Florida’s high court puts this state
on the side of creditors by favoring an effective economic remedy
over what had previously been the creditor-resistant form of single-
member LLCs.

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 BANKING
& FINANCE
October 2010
COURTS ARE NOT BUYING BORROWERS’ LATEST NOVEL DEFENSE: THAT THEIR
LENDERS FRAUDULENTLY OR NEGLIGENTLY QUALIFIED THEM FOR LOANS
By: Scott L. Cagan, Esq. & Cortney R. Kaiserman, Esq.
In the past two years, borrowers’ attorneys have filed a flurry of
preemptive lawsuits to try to avert foreclosure, raising yet another
creative defense to their loan defaults: that their lender fraudulently
or negligently qualified them for loans by either overinflating their
incomes or misrepresenting their ability to repay the loans.
In an attempt to avoid their loan obligations, borrowers are
increasingly bringing claims for fraud, fraudulent inducement,
fraudulent misrepresentation, negligence, breach of fiduciary duty
and failure to disclose, in which they seek damages, injunctive relief,
cancellation of mortgages and rescission. The thrust of borrowers’
complaints is that their lenders knowingly misrepresented to them
that they qualified for the loans, intentionally falsified their income
in order to qualify them for the loans, and failed to implement and
comply with adequate underwriting standards.
Several recent decisions by U.S. district courts in the Eleventh
Circuit, and one by the Eleventh Circuit itself, have rejected these
types of claims by borrowers.1 Even better, these courts have not
hesitated to dismiss complaints at the motion-to-dismiss stage, often
before expensive and time-consuming discovery gets off the ground.
In dismissing borrowers’ claims, courts have noted the many legal
flaws in such claims: 1) an assertion that a borrower can afford a loan
is an opinion, not a statement of fact; 2) any alleged false statement
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was intended to induce the lender to act–not the borrower; 3) the
borrower could not plausibly rely on an alleged misrepresentation of
a fact (his or her own income) that was known to him or her; and 4)
the borrower could not have justifiably relied on the lender’s falsifying
his or her income, especially where the borrower acknowledges that
he or she was unaware that the lender had done so.
Moreover, the courts have relied upon well-established Florida law
holding that lenders are not financial advisors to borrowers, and
absent a fiduciary relationship, a bank owes no duty to borrowers to
advise them whether they have the ability to repay a loan.
Finally, as the Eleventh Circuit aptly noted, if every borrower could
claim fraud merely because they were told by a bank that they qualified
for a loan and met underwriting standards, “every loan approval
could potentially result in a claim for fraudulent inducement.”
1 See Azar v. Nat’l City Bank, 2010 WL 2381049 (11th Cir. June 15, 2010),
affirming 2009 WL 3668460 (M.D. Fla. October 26, 2009); Infante v. Bank of
America Corp., 2009 WL 5554641 (S.D. Fla. December 18, 2009); Matthys v.
Mortgage Electronic Registration Systems, Inc., 2009 WL 3762632 (M.D. Fla.
November 10, 2009); Zaffrullah v. Countrywide Home Loans, Inc., 2010 WL
503074 (S.D. Fla. February 8, 2010); Collins v. Countrywide Home Loans,
Inc., 2010 WL 55603 (M.D. Fla. January 5, 2010); Oglesbee v. Indymac
Financial Services, Inc., 2010 WL 475130 (S.D. Fla. February 8, 2010); Dixon
v. Countrywide Loans, Inc., 2010 WL 1838658 (S.D. Fla. May 7, 2010).
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 BANKING
& FINANCE
THE VOLCKER RULE: ARE BANKS BANNED FROM INVESTING IN FUNDS AND
PROPRIETARY TRADING?
By: Milton A. Vescovacci, Esq. & Jarred Leibner*
The recent financial reform legislation passed by Congress and signed
into law by President Obama on July 21, 2010, entitled the Bank and
Savings Association Holding Company and Depository Institution
Regulatory Improvements Act of 2010 (the “Act”), imposes various
restrictions on permissible bank activities. For some banks, the cost
of compliance could be substantial.
One of the most significant aspects of the Act is a provision known as
the Volcker Rule, which seeks to limit banks,
bank holding companies and their subsidiaries
from engaging in proprietary trading as well as
from investing or sponsoring a hedge fund or a
private equity fund. While these provisions are
aimed at reducing systemic risk by restricting a
bank’s ability to buy for their own books, the
Act could have the effect of decreasing overall
investment and capital market activities.
Under the new legislation, banks will be
prohibited from: (1) directly or indirectly
guaranteeing the obligations or performance
of a hedge fund or a private equity fund, (2)
sharing the same name or a variation of the
same name with a hedge fund or private equity
fund, or (3) allowing a director or employee of
the banking entity to retain an equity interest
in the fund. Despite some of the earlier harsher versions of the Volcker
Rule, the Act now permits banks to have de minimis investments in
private equity funds or hedge funds and also enables them to provide
sufficient initial equity to a fund to attract unaffiliated investors.
However, banks using this exemption will be required to reduce
their ownership not later than one year from the fund’s formation
so that they do not retain more than three percent of the fund’s total
ownership. Furthermore, banks will be required to limit their total
investments in all such funds to no greater than three percent of the
Tier 1 capital of the banking entity.
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The Act also permits banks to engage in proprietary trading under
some circumstances based on the specific exemptions. For example,
banks will be permitted to (1) buy and sell certain securities on behalf
of customers, (2) buy and sell certain securities in connection with
underwriting or market-making-related activities that are designed
not to exceed the reasonably expected near term demands of clients,
customers, or counterparties, (3) engage in risk-mitigating hedging
activities, and (4) invest in qualified small business investment
companies and certain securities related to an
insurance company.
A study regarding the Volcker Rule is required
to be completed within six months, and within
nine months of completion of the study, the
appropriate federal banking agencies will be
required to jointly issue the final regulations.
Once the rules have been finalized and become
effective, these banking entities will have an
additional period of two years in order to make
all of their necessary divestitures. Although the
Board is authorized to extend this transition
period for illiquid funds or where otherwise
appropriate, banks will not be able to engage
in any prohibited activity once these extensions
have expired. Consequently, banks will need
to be prepared to terminate their proprietary trading activities and
potentially transfer their interests to another entity that does not fall
within the ambit of the Volcker Rule. Banks also need to understand
this new legislation in order to assess how it will affect their current
relationships with any hedge funds or private equity funds that they
currently do business with.
The Act has changed the landscape in the banking world and,
consequently, banks should understand the ramifications of this new
legislation and prepare to comply with its provisions.
*Jarred Leibner, summer associate at GrayRobinson in Fort Lauderdale and a
JD/MBA candidate at the University of Miami, contributed to this article.
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 BANKING
& FINANCE
October 2010

LITIGATION HOLD LETTERS

By: David S. Hendrix, Esq. & Mark Schellhase, Esq.

In today’s business environment, organizations rely on electronic must undertake the following actions:
communication and record keeping. When actual or reasonably
• Identify all sources and locations of potentially relevant ESI;
anticipated litigation arises, a party and its counsel must make certain
that all sources of potentially relevant information are identified and • Identify persons within the organization with authority to
placed “on hold.” Zubulake v. UBS Warburg LLC, 220 F.R.D. 212, suspend normal destruction procedures and impose a litigation
218 (S.D.N.Y. 2003). Electronically Stored Information (“ESI”) hold;
dramatically increases the number of documents subject to discovery
• Tailor the scope of the initial litigation hold based upon the
and has necessitated use of litigation holds to protect all potentially
information known at that time;
relevant information.
• Implement the litigation hold by
The burden of protecting this
suspending the normal destruction
information is shared between
of ESI and other information to
an organization and its counsel.
preserve all potentially relevant
“Proper communication between
information;
an organization and its attorney
ensures: (1) that all relevant • Effectively communicate
information (or at least all notice of the litigation hold to
sources of relevant information) the appropriate custodians of
is discovered; (2) that relevant affected records, as well as other
information is retained on a individuals (potentially to include
continuing basis; and (3) that third parties), who may possess
relevant non-privileged material relevant information;
is produced to the opposing
• Document all steps taken by
party.” In re Seroquel Prod.s
the organization and counsel in
Liab. Litig., 244 F.R.D. 650,
implementing the litigation hold;
663 (M.D. Fla. 2007), (quoting
Zubulake v. UBS Warbug LLC, • Monitor the scope of the
229 F.R.D. 422, 432 (S.D.N.Y. litigation hold and make
2004)). Counsel must oversee adjustments where needed as the
compliance with the litigation litigation progresses; and
hold by monitoring the party’s efforts to retain and produce the
• Release the litigation hold only when there is no continuing duty
relevant documents. Id. In order to meet this obligation, counsel must
to preserve the information.
become familiar with the organization’s systems and procedures as
well as communicate with all key players involved in the litigation. Id. When these obligations are not met, the organization and its counsel
face potential sanctions for the spoliation of potential evidence.
In many cases, counsel will send an initial litigation hold letter to notify
“Sanctions may be imposed against a litigant who is on notice that
the organization of its obligation to retain all potentially relevant
documents and information in its possession are relevant to litigation
information. When a litigation hold is necessary, the organization

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 BANKING
& FINANCE
October 2010

LITIGATION HOLD LETTERS…CONTINUED

[ ] or potential litigation ... and destroys such documents and
information.” Swofford v. Eslinger, 671 F.Supp.2d 1274 (M.D. Fla.
2009) (quoting Optowave Co., Ltd. v. Nikitin, 2006 WL 3231422
(M.D. Fla. Nov.7, 2006)). The elements of a spoliation claim are: (1)
the existence of a potential civil action; (2) a legal or contractual duty
to preserve evidence which is relevant to the potential civil action; (3)
destruction of that evidence; (4) significant impairment in the ability
to prove the lawsuit; (5) a causal relationship between the evidence
destruction and the inability to prove the lawsuit; and (6) damages.
Green Leaf Nursery v. E.I. DuPont De Nemours and Co., 341 F.3d
1292, 1308 (11th Cir. 2003).
In the Eleventh Circuit, sanctions for spoliation of evidence are
appropriate “only when the absence of that evidence is predicated on
bad faith… .” Bashir v. Amtrak, 119 F.3d 929, 931 (11th Cir. 1997).
However, the spoliating party need not have acted with malice when
spoliating the evidence in order for the court to draw an adverse
inference. Graff v. Baja Marine Corp., 310 Fed.Appx. 298 (11th Cir.
2009).
Even when no direct evidence of bad intent exists, bad faith may be
found on circumstantial evidence where all of the following hallmarks
are present: (1) evidence once existed that could fairly be supposed to
have been material to the proof or defense of a claim at issue in the
case; (2) the spoliating party engaged in an affirmative act causing
the evidence to be lost; (3) the spoliating party did so while it knew or
should have known of its duty to preserve the evidence; and (4) the
affirmative act causing the loss cannot be credibly explained as not
involving bad faith by the reason proffered by the spoliator. Calixto
v. Watson Bowman Acme Corp., 2009 WL 3823390 (S.D. Fla. 2009
Nov. 16, 2009); see also Swofford, 671 F. Supp. 2d at 1282 (inferring
bad faith based upon a knowing and willful disregard for the clear
obligation to preserve evidence).
To avoid potential sanctions, litigation holds should be implemented
at the onset of anticipated litigation. The organization and its counsel
must identify all relevant sources of information and create processes
to preserve all such information. Further, the organization and
its counsel must monitor compliance with the litigation hold as the
litigation develops. Most importantly, the organization must avoid
the spoliation of any relevant information, including ESI. Proactive
creation and implementation of a litigation hold avoids potential
sanctions and protects the organization’s position in the litigation.

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 BANKING
& FINANCE
October 2010
SUPREME COURT FINDS THAT SILENCE DOES NOT EQUAL ACQUIESCENCE TO
CLASS ACTION ARBITRATION
By: Alissa M. Ellison, Esq.
The United States Supreme Court recently considered whether
or not a party to an arbitration agreement, which is silent on the
issue of class actions, could be forced to participate in class action
arbitration as opposed to bilateral arbitration. In Stolt–Nielsen S.A.
v. AnimalFeeds Int’l Corp., 130 S. Ct. 1758 (2010), AnimalFeeds
filed a putative class action lawsuit against Stolt-Nielsen for various
antitrust claims. Id. at 1765. The charter agreements between the
parties contained an arbitration clause that was completely silent on
the issue of class action arbitration. Id. at 1765-66. Accordingly,
the parties ultimately agreed that they must arbitrate their
dispute in accordance with their arbitration agreement.
Id. at 1765. However, the parties disagreed as to
whether the arbitration should be conducted on a
class-wide or bilateral basis and submitted this
question to a panel of three arbitrators. Id. at
1765-66.
Despite Stolt-Nielsen’s arguments to the contrary,
the arbitration panel determined that the
arbitration clause between the parties permitted
class arbitration because there was nothing
included therein to “establish that the parties’ charter
agreements intended to preclude class arbitration.” Id.
at 1766 (internal citation omitted). The arbitrators further
determined that any other result would leave “‘no basis for a class
action absent express agreement among all parties and the putative
class members.’” Id. at 1766 (internal citations omitted).
Stolt-Nielsen then sought judicial review of the arbitrators’ decision
by filing an application to vacate the arbitrators’ award in the district
court. Id. The district court vacated the award, concluding that the
arbitrators’ decision was made in “manifest disregard” of the law
because the arbitrators had failed to conduct a choice-of-law-analysis.
Id. Subsequently, AnimalFeeds appealed to the Court of Appeals,
who reversed the district court’s opinion. Id.
The controversy eventually reached the United States Supreme
Court. In reaching its conclusion, the Court first emphasized that, in
construing an arbitration clause, “courts and arbitrators must ‘give
effect to the contractual rights and expectations of the parties.’” Id.
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at 1773-74 (citing Volt Information Sciences, Inc. v. Board of Trustees
of Leland Stanford Junior Univ., 789 U.S. 468, 479 (1989)). The
Court further stated that it was clear from its “precedents and the
contractual nature of arbitration that parties may specify with whom
they choose to arbitrate their disputes.” Id. at 1774. (emphasis
added). Based on these principles, the Court ruled that a party
cannot be compelled under the FAA to submit to class arbitration
unless there is a contractual basis for concluding that the parties
agreed to class arbitration. Id. The Court further stated that the
arbitration panel had “regarded the agreement’s silence on
the question of class arbitration as dispositive” and that
“[t]he panel’s conclusion [was] fundamentally at war
with the foundation FAA principal that arbitration
is a matter of consent.” Id.
As further support for its decision, the
Court considered many of the fundamental
changes that would necessarily result from a
shift away from bilateral arbitration to class-
action arbitration, such as the vast differences in
procedural protections and appellate review. Id.
at 1775-76. The Court determined that a class action
arbitration “changes the nature of the arbitration
to such a degree that it cannot be presumed the parties
consented to it by simply agreeing to submit their disputes to an
arbitrator.” Id. at 1775.1
As a result of the Court’s decision in Stolt-Nielsen v. AnimalFeeds,
parties may now be able assert a contractual right to a bilateral
arbitration without running the risk of class action arbitration,
even if the arbitration agreement is silent on this issue. Moreover,
the Court may have significantly limited the number of class-action
arbitrations, as the Court’s ruling clearly requires some evidence of
intent before subjecting a party to class arbitration. Thus, this ruling
can be viewed as a victory for businesses opposing class arbitration.
1 However, it should be noted that the Court specifically declined to determine
what contractual basis would support a finding that the parties agreed to
class-action arbitration. Id. at 1766, n. 10.
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 BANKING
& FINANCE
October 2010

ABOUT THE AUTHORS

Scott L. Cagan Alissa McKee Ellison David S. Hendrix Cortney R. Kaiserman
Fort Lauderdale Tampa Tampa Fort Lauderdale
954-761-8111 813-273-5000 813-273-5000 954-761-8111
scott.cagan@ alissa.ellison@ david.hendrix@ cortney.kaiserman@
gray-robinson.com gray-robinson.com gray-robinson.com gray-robinson.com

Jeffrey T. Kuntz Mark Schellhase Patrick S. Scott Milton A. Vescovacci

Fort Lauderdale Tampa Fort Lauderdale Miami
954-761-8111 813-273-5000 954-761-8111 305-416-6880
jeffrey.kuntz@ mark.schellhase@ patrick.scott@ milton.vescovacci@
gray-robinson.com gray-robinson.com gray-robinson.com gray-robinson.com

The GrayRobinson Banking & Finance Group offers a Special
Assets Webinar to our valued clients which can be specifically
tailored to your needs. This Webinar was designed and is presented
• LOAN DOCUMENTATION AND REVIEW
File review, essential documentation review such as notice,
waiver, default, acceleration, attorneys fees, jury waiver,
adequacy of signatures, documents, filings, guarantees,
securitization of collateral when you contact your attorney,
strategy of loan modification vs. litigation, early settlement
offers and settlement privilege issues, set off and freezing
accounts.
• LITIGATION
Demand letters, attorney client privilege, foreclosure
complaints, affidavits of indebtedness, guarantee actions,
service (in person and substitute service), motions to dismiss,
summary judgment, trial (jury and non-jury), arbitration
clauses (when to consider and when not to), motions for
rehearing effect on sale date, foreclosure sales, bidding
instructions, use of attorney or agent at sale, alternates to
litigation such as deed in lieu, environmental studies, surveys,
jurisdiction (state and federal).
by some of our most seasoned Banking & Finance Group attorneys
and includes in-depth discussion on:
• BANKRUPTCY
Suggestion of bankruptcy and banks duties and obligations,
creditors meeting, motions to lift stay, adequate protection
issues, class of claims (secured, unsecured, split claims),
Chapter 7, 11, 13 and the differences,trustees, receiverships,
plan confirmation, cram down, adversarial actions, collection
of judgments (writs, garnishments and replevins) both in and
out of bankruptcy.
• SHOW CAUSE FORECLOSURES
Florida Statute Section 702.10 Defenses AND advanced
litigation Techniques designed to speed up the litigation
process.
• FORECLOSURE SALES
For more information about this webinar or other in-house
specialized training webinars, please contact:
David S. Hendrix
Chairman, Banking & Finance
800-338-3381
david.hendrix@gray-robinson.com

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 BANKING
& FINANCE
October 2010

GRAYROBINSON BANKING & FINANCE GROUP

FORT LAUDERDALE ORLANDO
James D. "Jim" Barnett jim.barnett@gray-robinson.com William H. Beaver, II william.beaver@gray-robinson.com
Scott L. Cagan scott.cagan@gray-robinson.com John M. "Jay" Brennan jay.brennan@gray-robinson.com
Cortney R. Kaiserman cortney.kaiserman@gray-robinson.com Terence "Terry" J.
Jeffrey T. Kuntz jeffrey.kuntz@gray-robinson.com Delahunty, Jr. terry.delahunty@gray-robinson.com
Steven A. Lessne steven.lessne@gray-robinson.com Phillip R. Finch phil.finch@gray-robinson.com
Thomas H. Loffredo tom.loffredo@gray-robinson.com Gregg R. Lehrer gregg.lehrer@gray-robinson.com
Ivan J. Reich ivan.reich@gray-robinson.com Frederick W. Leonhardt fred.leonhardt@gray-robinson.com
Roland E. Schwartz roland.schwartz@gray-robinson.com Byrd F. "Biff" Marshall, Jr. biff.marshall@gray-robinson.com
Patrick S. Scott patrick.scott@gray-robinson.com Borron J. Owen, Jr. borron.owen@gray-robinson.com
Paul S. Quinn, Jr. paul.quinn@gray-robinson.com
JACKSONVILLE Gary S. Salzman gary.salzman@gray-robinson.com
Jason Burnett jason.burnett@gray-robinson.com Jason W. Searl jason.searl@gray-robinson.com
Lee Stathis Haramis lee.haramis@gray-robinson.com C. Gene Shipley gene.shipley@gray-robinson.com
Kenneth B. Jacobs ken.jacobs@gray-robinson.com Daniel E. Traver daniel.traver@gray-robinson.com
Cynthia M. Montgomery cynthia.montgomery@gray-robinson.com
Terry A. Moore terry.moore@gray-robinson.com TAMPA
Chair - David S. Hendrix david.hendrix@gray-robinson.com
LAKELAND Joseph P. Covelli joseph.covelli@gray-robinson.com
David D. Hallock, Jr. david.hallock@gray-robinson.com Thomas W. Danaher thomas.danaher@gray-robinson.com
Henry M. Morgan, Jr. hank.morgan@gray-robinson.com Alexandra de Alejo alexandra.dealejo@gray-robinson.com
Stephen C. Watson steve.watson@gray-robinson.com Alissa McKee Ellison alissa.ellison@gray-robinson.com
Brian J. Fender brian.fender@gray-robinson.com
Jeanette M. Flores jeanette.flores@gray-robinson.com
MELBOURNE Stephen L. Kussner stephen.kussner@gray-robinson.com
Patrick F. Healy patrick.healy@gray-robinson.com Scott R. Lilly scott.lilly@gray-robinson.com
Donald A. Nohrr don.nohrr@gray-robinson.com Thomas A. Mann II thomas.mann@gray-robinson.com
Mark Schellhase mark.schellhase@gray-robinson.com
MIAMI Aaron J. Silberman aaron.silberman@gray-robinson.com
Leyza F. Blanco leyza.blanco@gray-robinson.com David L. Smith david.smith@gray-robinson.com
Gary M. Carman gary.carman@gray-robinson.com John I. Van Voris john.vanvoris@gray-robinson.com
Ileana M. Espinosa Kim Hernandez Vance kim.vance@gray-robinson.com
Christianson ileana.christianson@gray-robinson.com Richard M. Zabak richard.zabak@gray-robinson.com
Richard F. Danese richard.danese@gray-robinson.com
Veronica A. Meza veronica.meza@gray-robinson.com
Robert A. Schatzman robert.schatzman@gray-robinson.com
Steven J. Solomon steven.solomon@gray-robinson.com
Frank P. Terzo frank.terzo@gray-robinson.com
Milton A. Vescovacci milton.vescovacci@gray-robinson.com
Nicolas J. Watkins nicolas.watkins@gray-robinson.com
Mark S. Weinberg mark.weinberg@gray-robinson.com
Steven W. Zelkowitz steven.zelkowitz@gray-robinson.com

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