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Archive for the ‘Student Loans’ Category

Bankruptcy Can Write Off a Student Loan, IF it Causes Undue Hardship

March 18th, 2019 at 7:00 am

Writing off student loans is not easy. You must convincingly show that paying the loan causes you undue hardship, a tough condition to prove. 

 

 

Criminal fines and restitution and child and spousal support are types of debts that bankruptcy essentially never discharges. Income taxes can be discharged but only after meeting certain conditions. We’ve covered these in our last few blog posts. Today we cover student loans.

Student loans are more like income taxes than criminal or support debts in that they CAN get discharged in bankruptcy. Like an income tax, a student loan just needs to meet certain conditions.

But unlike an income tax debt, the conditions for discharge of a student loan are much vaguer. Most of the income tax conditions are clear. These conditions require a precise understanding of the law and a thorough knowledge of the facts of your case. But if you and your bankruptcy lawyer are careful, you should know before you file your bankruptcy whether you can discharge a tax debt.

Discharging student loans, in contrast, require meeting an ambiguous condition called “undue hardship.” Its ambiguity means that it’s much harder to predict whether or not a student loan will be discharged in bankruptcy.

Furthermore, because of this vague condition it’s possible to get a partial discharge. You may continue to owe some but not all of a particular student loan debt. Or if you have multiple student loans you may discharge some but not all of them.

“Undue Hardship”

Bankruptcy law states that an educational loan or benefit overpayment is not discharged in bankruptcy unless it “would impose an undue hardship on [you or your] dependents.” Section 523(a)(8) of the U.S. Bankruptcy Code.

Can you show the bankruptcy court that paying a student loan causes you “undue hardship”? If so bankruptcy can forever discharge that debt.

A More Precise Meaning of “Undue Hardship”

How does your bankruptcy court decide whether or not a student loan causes you a hardship?  

How bad does a hardship need to be to qualify as an undue hardship?

In most parts of the country “undue hardship” requires you to establish all three of the following:

1. You currently cannot maintain even a minimal standard of living (for yourself and any dependents) if you pay the student loan.

2. This present financial situation is realistically anticipated to continue through the loan’s term of repayment.

3. You have acted responsibly in the past regarding the student loan, by making a serious effort to pay it and/or to attempt to qualify for any of the available programs to reduce or manage the loan.  

The Student Loan Survives Unless You Establish “Undue Hardship”

It can be difficult to meet all three of these. If you don’t, you continue to owe the student loan.

Furthermore, the student loan creditor does not have to take any action itself. You and your lawyer have to raise the issue yourself. It’s up to you to start the ball rolling.

Generally you do so by filing an “adversary proceeding” during your bankruptcy case. This is a legal proceeding focusing exclusively on whether you qualify for a “hardship discharge” of the student loan.

If you believe you qualify, you could file a Chapter 7 “straight bankruptcy” case. Then your lawyer would file an adversary proceeding during the 3-4 months a basic Chapter 7 case usually lasts.  The student loan creditor would most likely object. There would then be a trial with evidence on whether you meet the necessary factors to show undue hardship. There’s no jury—the bankruptcy judge decides.

You can do the same thing within a Chapter 13 “adjustment of debts.” Because this kind of bankruptcy usually lasts 3 to 5 years, it gives you more timing options. Chapter 13 would usually allow you to avoid making student loan payments at least temporarily. Then once you think you qualify for undue hardship your lawyer would file the adversary proceeding. This could be especially helpful if you have a deteriorating medical condition or an anticipated reduction in income.

Summary

Student loans are dischargeable in bankruptcy, but undue hardship is an ambiguous and often tough condition to prove. The law of undue hardship as interpreted by the courts is constantly adjusting, and can be slightly different in different bankruptcy courts. So it’s crucial to get highly competent legal advice about what’s best for you.

 

Can I Discharge My Student Loans in Bankruptcy?

January 25th, 2019 at 10:48 pm

bankruptcyThere are over 44 million young adults in the United States who currently have student loan debt. Those 44 million people owe a combined total of $1.52 trillion, with the average borrowing being $37,000 in debt by the time they graduate. Student loan debt is a rising issue, especially since many have trouble making their payments. One of the most searched questions online is, “Can I discharge my student loans in bankruptcy?” In short, no, you usually cannot, but as with many things, there are a few exceptions to that rule.

The Brunner Test

In 1998, a law was passed that stated you could not discharge student debt unless you could prove that repaying that debt would cause you undue hardship. In 2005, that law was extended to all types of student debt, including private student loans.

Proving undue hardship can actually be quite difficult. The test that is most commonly used in court to determine whether or not you would be experiencing undue hardship is called the Brunner Test. The test is actually quite simple and consists of three elements. These are:

  • Making student loan payments would not allow you to maintain a minimum standard of living because of your current income and expenses;
  • You have extenuating circumstances that make it likely that you will be in the same financial situation for most of the duration of the repayment period; and
  • You have attempted to repay the loan by seeking alternative repayment options and limiting your expenses as much as possible.

This is the basic formula that most courts will use to determine if you are experiencing undue hardship. Some courts will take into account other facts, like age, income, health, other financial circumstances and other factors.

A New Braunfels Bankruptcy Lawyer Can Help You Choose Your Best Course of Action

It can be difficult to know when you need to file for bankruptcy. There are many other options for student loan repayment than a bankruptcy. For federal loans, there are income-driven repayment plans and many private loan servicers will also work with you to create a repayment plan. Bankruptcy should be used as a last resort, but sometimes it is necessary. If you are thinking about filing for bankruptcy, contact us at the Law Offices of Chance M. McGhee. Our skilled Kerrville bankruptcy attorneys can help you go over your finances and choose which type of bankruptcy would be best for your situation. Call our office today at 210-342-3400 to schedule a free consultation.

 

Sources:

https://www.forbes.com/sites/zackfriedman/2019/01/09/student-loans-bankruptcy-discharge/#3230fc0e6d56

https://www.forbes.com/sites/zackfriedman/2018/06/13/student-loan-debt-statistics-2018/#774d1c7310fa

https://www.nerdwallet.com/blog/loans/student-loans/student-loans-bankruptcy/

The Surprising Benefits: Deal with Student Loan Collection with Chapter 13

July 9th, 2018 at 7:00 am

Qualifying for “undue hardship” to discharge (write off) student loans is not easy. But Chapter 13 gives you powerful help over the timing.

 

The Much Better Chapter 13 “Automatic Stay”  

Last time we explained how bankruptcy’s “automatic stay” immediately stops student loan collections against you. But if you file a Chapter 7 bankruptcy this protection from collections lasts only the 3-4 months that the case lasts. If you qualify under “undue hardship,” you could discharge (write off) your student loan debt during your case. Then the student loan creditor could no longer collect that debt.

But if you can’t show “undue hardship,” Chapter 13 buys you much more time, and more timing flexibility.

Chapter 13 Simply Buys More Time

Chapter 13 buys more time because a typical case lasts 3 to 5 years. The “automatic stay” prevents collection actions this entire length of time.  A student loan creditor could try to persuade your bankruptcy judge to allow it to collect before the end of your case.  But usually this doesn’t happen. So regardless of anything else, Chapter 13 puts off your student loan creditor(s) for a fairly long time.

Chapter 13 May Buy Time Until You DO Qualify for “Undue Hardship”

To discharge a student loan you (or your dependent) must be experiencing an “undue hardship” at that time.  Chapter 13 gives you the flexibility of waiting for up to 5 years until you meet that condition. You file the case, and throughout its life your student loan creditor(s) is (are) prevented from collecting. Then, as soon as you do qualify for “undue hardship,” your bankruptcy lawyer would file the discharge petition.

For example, assume you or a financial dependent had a worsening chronic medical condition. But that condition was NOT YET preventing you from working, so that you were not yet in the circumstances that your student loan(s) was (were) preventing you from maintaining even a minimal standard of living. You could not petition for “undue hardship” discharge yet. But Chapter 13 would allow you to wait as long as 5 years after filing the case. This would give you time for your condition to worsen until you did met this requirement.   

Conclusion

Chapter 13 prevents your student loan creditor(s) from chasing you for years. And it also allows you to delay asking to discharge your student loan debt(s) until the point when you’d qualify. In the right circumstances these could be huge advantages.

 

The Surprising Benefits: Stop Student Loan Collection

July 2nd, 2018 at 7:00 am

Chapter 7 “straight bankruptcy” stops student loan collection actions for a few months. Sometimes it can stop these actions permanently. 

 

Bankruptcy gives you tools to deal with special debts—including those you can’t easily write off. Last week we got into income taxes. Today we discuss student loans, focusing on this special kind of debt in Chapter 7 “straight bankruptcy.” Next week, we’ll cover student loans under Chapter 13 “adjustment of debts.”

Let’s assume you owe a student loan that you can’t afford to pay. Here’s how Chapter 7 can help.

Student Loan Collection

Student loan creditors and collectors have extraordinary collection powers. Often they don’t need to sue you first and get a legal judgment against you, as most creditors must. These creditors and their collections have very aggressive collection procedures available to them. Besides the usual garnishment of bank accounts and paychecks, these special creditors can often grab your tax refund or a portion of a Social Security benefit check.

The “Automatic Stay” from a Chapter 7 Filing 

Student loans are special in a number of ways. However, just like ordinary debts, student loan collections are immediately stopped by the “automatic stay” imposed by your bankruptcy filing. It doesn’t matter whether or not the student loan would be discharged (written off) in your Chapter 7 case.

The “automatic stay” stops “any act to collect, assess, or recover a claim against the debtor.”  (Section 362(a)(6) of the U.S. Bankruptcy Code.) (A “claim” is a “right to payment”—essentially, a debt. See Section 101(5).) More specifically, the “automatic stay” stops “the commencement or continuation…  of a[n]..  .   administrative…  proceeding against the debtor. (Section 362(a)(1).) “Administrative proceedings” include the non-judicial collection actions mentioned above that don’t include a lawsuit. The Chapter 7 filing also specifically stops “the setoff of any debt” owed to you, such as a tax refund or Social Security setoff. (Section 362(a)(7).)  So, filing bankruptcy stops all student loan collection actions.

This break from collections lasts throughout the 3-4 months that most consumer Chapter 7 cases take to finish. But unless you deal with the student loan appropriately in the meantime, after that its collection can continue.

Dischargeability of Student Loans

Bankruptcy permanently discharges some student loans. A dischargeable student loan must meet just one condition, albeit a tough and confusing condition. The student loan must cause you an “undue hardship.” As the Bankruptcy Code puts it, you can’t discharge a student loan unless that loan “would impose an undue hardship on the debtor and the debtor’s dependents.” (Section 523(a)(8).)

What does “undue hardship” mean? How much harder must it be than just a simple “hardship”?

You may feel like your student loans are causing you a great financial hardship. However, the federal courts have interpreted this phrase very narrowly.  The details are beyond the scope of today’s blog post, but just keep in mind this condition is challenging to meet.

During the Chapter 7 Break in Collections      

During the 3-4 months of your Chapter 7 case you want to take steps to make the temporary break in collections a permanent one. Here are three ways to accomplish this.

  • If you and your bankruptcy lawyer believe you meet the “undue hardship” condition, your bankruptcy lawyer would file an “adversary proceeding” during your Chapter 7 case. That’s a specialized lawsuit designed to determine whether you qualify for “undue hardship.” If you persuade the bankruptcy judge that you do, the student loan debt would be permanently discharged. Then the temporary break in collections would become permanent. There would be no more collection on a debt once you no longer legally owe it.
  • The bankruptcy judge may give you only a partial discharge of your student loan(s). In this situation the judge is determining that repaying all of the loan(s) would cause you an “undue hardship.” But paying back only a portion would not. So you’d make arrangements to pay the remaining student loan debt, probably at a reduced monthly payment. As long as you made the payments your student loan creditor would take no further collection action against you.
  • If you don’t qualify for a full or partial “undue hardship” discharge, your Chapter 7 case would still at least discharge all or most of your other debts. That should leave you better able to pay the remaining student loans. Hopefully you’d be in a position to make payment arrangements. This may be done through a payment-reduction program which are available for various student loans. If so, then your situation would hopefully be resolved by the end of your Chapter 7 case. Then, at the time that the automatic stay would expire you won’t be facing any more student loan collections.

Avoiding Default and Preserving Options

Even if you don’t qualify for “undue hardship,” the bankruptcy pause in collections can be extremely helpful. It could maybe even be critical. That’s because you can only qualify for most student loan workout programs before you are too far behind on payments. So filing a Chapter 7 case before you’ve fallen too far behind could allow you to take advantage of these programs. But if you waited too long you could lose out, and be seriously disadvantaged.

Conclusion

It’s really crucial to talk with an experienced bankruptcy lawyer about all this. Student loans are complicated and often very challenging to deal with. This is true both outside and inside bankruptcy. You need a lawyer on your side who deeply understands both bankruptcy law and student loans.

 

Stop Student Loan Collections to Discharge or Deal with the Loan

January 31st, 2018 at 8:00 am

Filing Chapter 7 stops a student loan garnishment and other collection activities. Then use “undue hardship” or focus on the student loan.  

 

Our last blog post was about a Chapter 7 bankruptcy stopping a tax garnishment only temporarily. In that situation this was OK because it gave time to set up a payment program with the IRS/state. With the bankruptcy discharging (writing off) all or most other debts, the taxpayer could afford a reasonable monthly payment to pay off the tax debt over time.  

Today we deal with a somewhat similar situation. Assume you owe a student loan that you don’t have the cash flow to make payments on. Here’s how this situation can be greatly helped through a Chapter 7 filing.

Student Loan Collection and the Chapter 7 Filing

Similar to the tax authorities, student loan creditors and collectors have extraordinary collection powers. In most situations they don’t need to sue and get a legal judgment against you to begin aggressive collection procedures. These can include wage garnishment, tax refund setoff, and Social Security benefit capture. (This is true of federal student loans; private student loan lenders must first sue you and get a judgment.)

Also like income tax debts, student loan collection is immediately stopped by the “automatic stay” imposed by your bankruptcy filing. It doesn’t matter if the student loan would not be discharged in the Chapter 7 case. During the 3-4 months that most consumer Chapter 7 cases last, you get a break from student loan collections.

The automatic stay statute stops “any act to collect, assess, or recover a claim against the debtor.” (See Section 362(a)(6) of the U.S. Bankruptcy Code.) More specifically it stops “the commencement or continuation…  of a[n]..  .   administrative…  proceeding against the debtor. (Section 362(a)(1).) This covers the non-judicial collection actions mentioned above that are administrative in nature. The Chapter 7 filing also specifically stops “the setoff of any debt,” such as a tax refund or Social Security setoff. (Section 362(a)(7).)                             

Dischargeability of Student Loans

Somewhat similar to income tax debts, student loans can be permanently discharged under certain circumstances. An income tax is almost always discharged as long as it meets certain timing conditions. (These are based on how long ago the pertinent tax return was due and was actually submitted.)

In contrast, the condition that almost all student loans must meet for discharge is much more ambiguous. And the condition, called “undue hardship,” is often quite difficult to meet. You can’t discharge most student loans unless that loan “would impose an undue hardship on the debtor and the debtor’s dependents.” (Section 523(a)(8) of the Bankruptcy Code.)

While it may very much feel like your student loan(s) is (are) causing you a huge financial hardship, the federal courts have interpreted this phrase very narrowly.  So “undue hardship” is, as we said, a difficult condition to meet to discharge your student loan(s).

What You Can Accomplish During the Chapter 7 Pause in Collection      

The goal during the 3-4 months of no collection is to make that pause permanent. This can happen three ways.

First, IF you believe you do meet the “undue hardship” condition, your bankruptcy lawyer would file an “adversary proceeding” soon after filing the Chapter 7 case in order to persuade your bankruptcy judge that you qualify for “undue hardship.” If you’d be completely successful then the pause in collection would become permanent because you’d no longer owe the debt(s).

Second, sometimes in this situation the judge gives only a partial discharge of your student loan(s). In effect the judge decides that repaying all of the loan(s) would be an “undue hardship” but paying back a portion would not be. In this situation you’d make arrangements to pay the student loans at a reduced monthly payment. Your student loan creditor(s) would agree to no further collection action against you as long as you made those payments.

Third, if you don’t qualify for “undue hardship” your Chapter 7 case would discharge your other debts. That should leave you better able to pay the remaining student loans. You’d make arrangements to make payments, maybe through one of the various payment-reduction programs potentially available to you. Assuming you’d do so, they by the end of your Chapter 7 case when the automatic stay would expire your situation would be resolved and you wouldn’t be facing student loan collection actions.

Avoiding Default and Preserving Options

Even if you don’t qualify for “undue hardship,” the bankruptcy pause in collections can be extremely important for student loans. Again, there are various programs that help you deal with student loans, depending on exactly what type(s) you have. Some of these programs can be extremely helpful.

However, most of these programs require you to apply for them before you are too far behind on payments. So filing a Chapter 7 case sooner could enable you to take advantage of these programs. Whereas if you waited and filed later you may very well miss out because you’d no longer qualify.

Conclusion

Talk with an experienced bankruptcy lawyer about all this. Candidly, student loans are challenging to deal with, both outside and inside bankruptcy. You need a seasoned lawyer who understands the interplay between bankruptcy law and student loans, in detail.

 

Writing off a Student Loan

March 15th, 2017 at 7:00 am

To legally write off —discharge—a student loan in bankruptcy takes an extra step: proving that it is causing you “undue hardship.”


Adversary Proceedings and the Discharge of Debts

Our last several blog posts have been about adversary proceedings—lawsuits in bankruptcy court. In rare circumstances you might be on the receiving end of an adversary proceeding. Or you may use the advantages of bankruptcy court to file your own adversary proceeding against a creditor.

Last Friday’s blog post was about some of the reasons you’d consider suing a creditor during your bankruptcy case. The first reason was to discharge—legally write off—a debt that would otherwise not be discharged. Student loans fall in this category.

Most debts are discharged in bankruptcy without you having to take any special action against them during your case. This includes virtually all medical debts, credit cards, and the vast majority of other personal and business debts. Some other debts are never discharged—child and spousal support and criminal fines, for example. And finally, other debts may be discharged but only under certain circumstances. These include income taxes and student loans.

But income taxes and student loans are very different in the types of conditions that determine dischargeability. Income taxes generally are or are not discharged based on a set of readily determined facts. The main facts are whether and how long ago the pertinent tax return was legally due to be submitted, and how long ago that return actually was submitted to the tax authority. Usually, if you file the tax return and wait long enough, the tax will be discharged in bankruptcy.

The Vague Condition of “Undue Hardship”

In contrast, to discharge a student loan the condition that you must meet is maddeningly vague. The Bankruptcy Code simply says that a student loan is not discharged unless requiring you to pay it “would impose an undue hardship on [you or your] dependents.” See Section 523(a)(8). So the burden is on you to show “undue hardship.” Otherwise you’d remain liable on the student loan. The court order that discharges your other debts would not apply to it.

That means that to discharge a student loan you and your bankruptcy lawyer must file an adversary proceeding against your student loan creditor(s) and convincingly demonstrate to the bankruptcy judge that paying the debt would cause you “undue hardship.”

What Does “Undue Hardship” Mean?

You may think that showing “undue hardship” should not be hard if you can’t afford to pay the student loan. But it’s harder to show undue hardship than you’d think. Likely much harder.

For many years bankruptcy judges and federal appeals courts have been trying to figure out what those two words mean.

First, what determines whether or not a student loan debt creates a hardship?  

And second, what more beyond ordinary “hardship” is needed to create an “undue hardship”? Much has been made of the fact that Congress didn’t just say “hardship” but rather an “undue” level of hardship. That’s clearly a tougher condition to meet. But what does that odd word, “undue” mean? How can those two vague words be turned into a practical legal standard?

The Three Practical Requirements

Over time, judges have generally come to agree that to show “undue hardship” you have to meet three requirements.

  • First, you must currently be unable to maintain even a minimal standard of living for yourself and any dependents if you had to make the required payments on the student loan.
  • Second, this situation must be expected to continue over all or most of the student loan’s repayment period.
  • Third, you must have earlier acted responsibly by making a real effort to pay on the student loan, and/or to try to qualify for any available forbearances, debt consolidations, and administrative payment-reduction programs.

To establish “undue hardship,” you have to meet all three of these conditions. Otherwise, making you keep paying the student loan(s) may be indeed cause you a hardship. But your hardship would not rise to the level of a legally established “undue hardship”!

Conclusion

As “undue hardship” has come to be legally defined, it can be a challenging condition to prove. As a result filing bankruptcy doesn’t necessarily give you an easy way to get out of student loans. However, people do qualify under the right circumstances. And it does seem like more and more people filing bankruptcy have student loans as a major part of their problem. Student loans have gotten larger and more burdensome. And frankly more student loan debtors are getting older, closer to disability, illness, and retirement.  For a variety of reasons more people are qualifying for “undue hardship.”

 

How to Discharge a Student Loan in Bankruptcy

April 20th, 2016 at 7:00 am

Writing off a student loan in bankruptcy requires showing “undue hardship.” What is that?

 

Student Loans CAN Sometimes Be Discharged

You may have heard that student loans can never be “discharged”—written off in bankruptcy. Untrue.

Some other kinds of debts can’t ever be discharged, such as child and spousal support. But student loans are more like income taxes. Both can be discharged under certain conditions. (See our blog post of last Friday about discharging income taxes.)

However, income taxes are usually easier to discharge than student loans. Most of the time you just have to file your tax return and wait a certain amount of time. The requirements for discharging a tax debt are quite clear. They are much less clear and more rigorous with student loans.

“Undue Hardship”

The Bankruptcy Code says that a student loan is not discharged unless making you pay it “would impose an undue hardship on [you or your] dependents.” See Section 523(a)(8).

 So, if you can show that paying a student loan causes you “undue hardship,” bankruptcy can forever discharge that debt.

But What Does “Undue Hardship” Mean?

For decades the bankruptcy and federal appeals courts have been trying to figure out how to interpret those two words used by Congress when it wrote this law.  In practical terms how does a court decide whether or not a debt creates a hardship?  

And what more beyond ordinary “hardship” is needed to create an “undue hardship”?

Over time, judges have come to generally agree that to show that a student loan creates an “undue hardship” you have to meet three requirements:

1. You must currently be unable to maintain even a minimal standard of living for yourself and any dependents if you had to make the required payments on the student loan.

2. Your current inability to maintain that a minimal standard of living must be expected to continue over all or most of the student loan’s repayment period.

3. You must have earlier acted responsibly at making a real effort to pay on the student loan, and/or to try to qualify for any available forbearances, debt consolidations, and administrative payment-reduction programs.

Notice that these three conditions refer to the past, present, and future. You have to meet all three conditions, which is a lot to satisfy.

Your Burden to Prove “Undue Hardship”

In bankruptcy, some kinds of debts are discharged unless the creditor affirmatively and formally raises an objection. If the creditor fails to object and do so before a quick deadline, the debt is legally forever gone.

With student loans, in contrast, the burden is on you to convince the bankruptcy judge that you qualify for “undue hardship.” Generally you must do that during the bankruptcy case. Otherwise that debt survives your bankruptcy.

Timing Issues

The fact that you have to establish that you are currently unable to maintain a minimal standard of living if you had to make your student loan payments raises some timing issues.

If you believe you meet this requirement right now (as well as the other two conditions), you could file a Chapter 7 “straight bankruptcy” case or a Chapter 13 “adjustment of debts” case now, whichever is better for you as to the rest of your debts. Your attorney would then formally ask the bankruptcy court for an “undue hardship” determination to discharge the student loan. A separate legal proceeding would determine whether you qualify. If the student loan creditor objects to your request, there could be court trial focusing on whether you meet the required conditions.

If you don’t believe you qualify yet for “undue hardship” now but expect to in the future, filing a Chapter 13 case now may be the best choice. (For example, you may have a worsening medical condition which you know will cause a reduction in your income in the near future.) You may need relief from your creditors now, including the student loan creditor(s). A Chapter 13 filing would give you that relief. It would likely allow you to avoid making any ongoing student loan payments for the next few years while you focus on other more pressing expenses and special debts. And then you would have the opportunity to try to qualify for “undue hardship” between now and the end of your Chapter 13 case 3 to 5 years later.

In some situations, if you don’t qualify for “undue hardship” during the course of either your Chapter 7 or Chapter 13 case, you may be able to reopen your bankruptcy case later. That way the bankruptcy court could make that determination at a time when you do qualify.

Conclusion

“Undue hardship” is a tough standard to meet. Bankruptcy law does not provide an easy way to get out of student loans. But more and more people in financial distress have student loans as a major part of their problem. More of them are getting older, closer to disability, illness, and retirement.  As the courts continuously deal with the issues, the law will continue to evolve. All are good reasons for you to get solid legal advice about your student loans and about your whole financial situation, to be able to figure out your best way forward.

 

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210-342-3400

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