NorVergenceBankruptcy:Related LitigationPlaces Standard LeaseEnforcement Terms in JeopardyBy Byron L. Saintsing and Thomas A. Gray

The bankruptcy and subsequent collapseof NorVergence, Inc., a New Jersey-basedreseller of telecommunications services andequipment, has placed standard leaseenforcement terms, including “hell or highwater” clauses and forum selection clauses,under scrutiny.The purpose of this article isto provide a basic understanding of theNorVergence bankruptcy, its relatedlitigation, the issues raised and relief soughtso as to assist those within the leasingindustry who are faced with similar issues.The below facts and procedural history aredrawn from allegations contained withinpleadings on file with various courts and areavailable to the public. Until the matters arefully adjudicated, the facts and legalassertions included below are mereallegations and are not conclusive.

History and CollapseNorvergence held itself out as a provider

of “low-cost” telecommunications services tosmall and medium sized businessesthroughout the United States. As part of itbusiness plan, NorVergence entered intoagreements with various telecommunicationsproviders including Quest CommunicationsCorporation, Sprint Communications, L.P.and T-Mobile USA, Inc. for the purpose ofrouting telephone and data traffic andproviding cellular telephone services. It hasbeen alleged that NorVergence representedto its customers that it could providedramatic telecommunications servicessavings by installing a piece of equipmentcalled the “Matrix”. Customers ofNorVergence entered into not onlytelecommunications agreements withNorVergence but customers were also

required to enter into “Equipment RentalAgreements” (“ERA”) for the “Matrix”.TheERAs which contained typical provisionssuch as “hell or high water” clauses andforum selection clauses. Once the customersentered into the ERAs, the ERAs wereassigned to and/or purchased by financingsources, which provided an influx of cash forNorVergence. It has been alleged that theprices charged for the “Matrix” were grosslyinflated and further that the “Matrix” did notwork as represented and some have allegedthat the “Matrix” was non-functional and ahoax.The assignments generated a largeamount of cash for NorVergence however,over time, NorVergence was unable tocontinue to sell enough ERAs to keep upwith the cost of the telecommunicationsservices provided. NorVergence collapsedwhen it was unable to provide the servicesor pay its suppliers.

Bankruptcy On June 30, 2004, an involuntary petition

under Chapter 11 of the Bankruptcy Codewas filed against NorVergence andthereafter the case was converted to aChapter 7.1 At the same time, the Courtentered orders allowing the varioustelecommunication providers includingQuest, Sprint and T-Mobile, to terminatetheir internet, long-distance and cellulartelephone services.This terminationeffectively shut down NorVergence andthereafter numerous Adversary Complaintswere filed by NorVergence customersagainst various funding sources whoacquired the ERAs.The AdversaryComplaints seek among other thingsdeclaratory judgments that the ERAs arevoid from the inception, should berescinded, and that damages should be

&Lease Enforcement Analysis News

Summer 2005|Published by Lease Enforcement Attorney Network LEAN www.leasecollect.org

LEAN, the only national network oflaw firms dedicated to providingcollection, enforcement and recoveryservices for leasing companies,welcomes you to the inaugural issue ofLease Enforcement Analysis & News.This quarterly newsletter is providedfree of charge to leasing professionalsengaged in the legal, credit, collectionsand operations aspects of leasing firms.LEAN consists of experiencedattorneys who assist leasing companiesand lease funding entities.What setsLEAN law firms apart is that in additionto being experts in the enforcementof lease obligations includingcollections, asset recovery, andbankruptcy representation, LEANmembers know leasing.

Each issue of the newsletter willfeature an article that gives youpractical tactics and tips aboutcollection, bankruptcy or other leaseenforcement issues. In addition, we willprovide a calendar of events of interestto the leasing community. Updatesabout LEAN members and a usefuldirectory of LEAN law firms areincluded.

We are anxious to receive yourfeedback.Visit the LEAN website atwww.leasecollect.org or complete theresponse form on the back of thisnewsletter to receive your com-plimentary unique LEAN coffee mug.

You can refer to the encloseddirectory to find a LEAN attorney toassist you anywhere in the UnitedStates or use our searchable databaseon the LEAN web site atwww.leasecollect.org. Contact LEANdirectly by email atinfo@leasecollect.org or by calling itstoll free number at 877-LEASELAW or877-532-7352.

Welcome to LeaseEnforcementAnalysis & News

Thomas Gray Brian Saintsing

Continued on page 2

Summer 2005 | Published by Lease Enforcement Attorney Network LEANPage 2

awarded.The Adversary Complaints alsoclaim conversion and allege that theassignees knew or should have knownabout, participated in and were the meansand instrumentality for the commission ofthe alleged NorVergence scheme.

New Jersey Class Action In New Jersey, a class-action lawsuit was

filed on behalf of all persons who leasedequipment from NorVergence by way ofERAs, which were thereafter assigned tovarious lease-assignees.2 This case is ofparticular interest to the leasing industrybecause the class alleges, among otherthings, that the assignees of the ERAs werefully aware of NorVergence’s allegedmisrepresentations yet still bought andenforced the ERAs.The class also assertsthat the language contained in the ERA isunconscionable, with such unconscionableaspects including the “hell or high water”clause, the “floating jurisdiction” clause, andthat the assignees knew or should haveknown of the unconscionability of theagreements.The class further questions thevalidity of the ERAs, disputes any financelease characterizations, and claims thatArticle 2A of the Uniform CommercialCode does not apply.The relief sought bythe class includes an injunction preventingenforcement of the ERAs, a declaratoryjudgment that the ERAs are not enforceableand punitive damages.

The various briefs and replies filedprovide the parties’ positions on such issuesas the applicability of Article 2A, whetherthe forum selection clause is unconscionable,and whether the assignees are holders indue course of the ERA.The Amicus CuriaeMemorandum submitted on behalf of theAttorney General of New Jersey and theDirector of the New Jersey Division of

Consumer Affairs provides their position onseveral issues including the “floatingjurisdiction” clause, whether the practices ofNorVergence violated the New JerseyConsumer Fraud Act, and whether theviolation can be used as a defense againstany assignee, even if the assignee took theERA in good faith, for value and withoutnotice of any defenses against NorVergence.

“Floating” Forum SelectionClause in Dispute

In Ohio, the validity of forum selectionclauses contained in various NorVergenceERAs are front and center. Preferred Capital,Inc. (“Preferred”) filed twelve cases againstvarious businesses (“Appellees”) thatdefaulted on ERAs entered into withNorVergence and thereafter assigned toPreferred.3 The Appellees filed Motions toDismiss claiming that the forum selectionclauses contained in the ERAs were invalidand that each Appellee did not have the

necessary minimum contacts with the Stateof Ohio.The twelve cases were dismissedfor lack of personal jurisdiction andPreferred appealed.

The issues raised on appeal, namely thevalidity of the forum selection clause, are of particular interest to the leasing industry.

The forum selection clause in dispute is as follows:

“This Agreement shall be governed by,construed and enforced in accordancewith the laws of the State in whichRentor’s principal offices are located or,if this Lease is assigned by Rentor, theState in which the assignee’s principaloffices are located, without regard toState’s choice of law considerations andall legal actions relating to this Leaseshall be venued exclusively in the Stateor Federal court located within thatState, which court to be chosen atRentor or Rentor’s Assignee’s soleoption.”

Preferred claims that the ERA forumselection clauses are valid because thetransactions were commercial in nature,fraud defenses do not apply andenforcement of the clause is notunreasonable or unjust. Preferred alsoemphasizes that the identical forum selectionclause has been upheld by judges in Ohioand that public policy considerations favorenforcement of the forum selection clause.Preferred addresses minimum contacts andclaims that a valid forum selection clauseprecludes a minimum contacts analysis andeven if the forum selection clause wasunenforceable, the Appellees have therequisite contacts to establish jurisdiction.

Appellees claim that the trial courts werecorrect in dismissing Preferred’s claims forlack of jurisdiction. Appellees rely upon avariety of reasons including that the forumselection clause is vague, unclear and doesnot specify the state in which suit may bebrought. Appellees also emphasize that theyare not domiciled or incorporated in Ohio,had no expectation of litigation in Ohio, andthat based upon the size and nature of their

NorVergence - Continued from cover

Smith Debnam Narron Wyche Saintsing & Myers, L.L.P.announces the opening of their Charlotte office located at TheRotunda; 4201 Congress Street; Suite 460; Charlotte, NC 28209.Thephone and fax for the Charlotte office are 704.643.3220 and704.643.3898 respectively.The firm also announces the newestmembers of the firm. John B. Honeycutt, Jr., Partner – CharlotteOffice and Heather N. Johnson, Associate – Charlotte office.Thefirm’s Raleigh office is located at Landmark Center; 4601 Six Forks

Road; Suite 400; Raleigh, NC 27609.The Raleigh phone and fax are949.250.200 and 919.250.2211.The firm’s Web site iswww.smithdebnamlaw.com.

Hiscock & Barclay, headquartered in Syracuse, New York iscelebrating its 150th anniversary this year. Formed in 1855, the firmhas 160 attorneys in five strategic offices throughout Upstate NewYork. Rob Liddell is the primary contact at the firm for leasingbusiness. He can be reached at 315.422.2131 orrliddell@hiscockbarclay.com.The firm’s Web site iswww.hiscockbarclay.com.

LEAN Members In The News

Continued on page 3

“The NorVergencebankruptcy and its related

litigation has placedstandard lease enforcementterms, including “hell or highwater” clauses and forumselection clauses, under

scrutiny and in jeopardy.”

business and location of witnesses, Ohio isso inconvenient as to deny them their day in Court.

The Equipment Leasing Association(ELA) and various Attorneys General haveweighed in on the issues raised.The ELA’sAmicus Curiae brief provides the ELA’sposition on the forum selection clauses atissue and their importance to the leasingindustry and commerce in general.TheAttorneys General of various States filedtheir Brief on Appeal of Amici Curiae urgingthe Court to affirm the lower court’sdismissals for lack of jurisdiction and barenforcement of the floating forum selectionclauses.

Federal Trade Commission Files Suit

The Federal Trade Commission (“FTC”)filed a complaint against NorVergence in theUnited States District Court District of NewJersey.4 One of the FTC’s functions is toenforce of the FTC Act prohibiting unfairand deceptive acts or practices in oraffecting commerce. Of interest to theleasing industry, the FTC complaint attacksthe validity of the ERAs by claiming, amongother things, that the value of the ERAs hadno relationship to the cost of the “Matrix”.The complaint also questions the validity ofthe ERAs’ “hell or high water” clause and anon-defined or distant forum selectionclause. Finally, in relation to the financecompany assignees, the FTC claims that they knew or should have known ofNorVergence’s fraudulent actions and thatthe ERAs might have been a part of thescheme to defraud the customers. Ofparticular interest to lease enforcementprofessionals, the relief requested by theFTC includes restitution, reformation orrescission of the contracts, cessation of

collections and the cancellation of purported debts.

Attorneys General InvolvementThe Attorneys General of several states

have investigated the business practices ofNorVergence, including its relationships tothe assignees of the ERAs, and have filed suitin various jurisdictions against NorVergencebased upon violations of certain consumerprotection acts.The Attorneys General haveinvestigated various assignees of the ERA’srelating to NorVergence, have made formalrequests for information, issued subpoenas,and have requested that certain assignees ofthe ERAs suspend monthly paymentrequirements and stay any collection

activities during the investigation.TheAttorneys General have filed suit directlyagainst NorVergence in several states,including Illinois, New York, North Carolina,Massachusetts, Pennsylvania and Florida,seeking, among other relief, damages,injunctions, restitution, and rescission ofcontracts. Some leasing companies havedefended against the Attorney General’sactions while others have elected to settlewith various Attorneys General. As a part of their settlements, the Attorneys Generalhave sought to cap the amounts that eachassignee/leasing company can recover from NorVergence customers as part of the settlement.

Summer 2005 | Published by Lease Enforcement Attorney Network LEAN Page 3

September 12-14 (ELA)Principles of Leasing Workshop(Advanced)Westin City CenterDallas,TX

September 13-14 (ELA)Healthcare Finance SummitRitz Carlton -Pentagon CityArlington,VASeptember 19, 2005 (EAEL)Annual EAEL ExpoTeaneck, New Jersey

September 19-21 (ELA)Lease Accountants ConferenceMarriott JW Hotel New OrleansNew Orleans, LA

September 22–25, 2005 (UAEL)2005 ACE Fall ConferenceCaesars TahoeLake Tahoe, Nevada

September 26-28 (ELA)Municipal Leasing ForumTrump International Sonesta BeachResortSunny Isles Beach (Miami), FL

October 11 (EAEL)Regional Business LuncheonHartford, CT

October 17-19 (ELA)Principles of Leasing WorkshopHyatt Regency ChicagoChicago, IL

October 21 – 22 (NAELB)NAELB Western Regional MeetingHilton IrvineIrvine, CA

October 23-25 (ELA)44th Annual ConventionBoca Raton Resort & ClubBoca Raton, FL

November 4 – 6 (NAELB)NAELB Eastern Regional MeetingSheraton GatewayAtlanta, GA

November 15 (EAEL)TBAWestchester/Long Island RegionalBusiness Luncheon

December 5-7 (ELA)Principles of Leasing WorkshopCourtyard MarriottPhiladelphia, PA

December 8 (EAEL)New York CityHoliday Reception and Dinner

December 12-14 (ELA)Principles of Leasing Workshop(Advanced)Hyatt Fisherman's WharfSan Francisco, CA

EAEL = Eastern Association ofEquipment Leasing

ELA = Equipment Leasing Association

NAELB = National Association ofEquipment Leasing Brokers

UAEL = United Association ofEquipment Leasing

LEAN Industry Calendar of EventsSeptember 2005 through December 2005For more information about individual events, visit theLEAN website at www.leasecollect.org

Robert S. Bernstein of the Pittsburgh, Penn. based BernsteinLaw Firm recently traveled to Beijing, China to speak on thesubjects of creditors’ rights and bankruptcy. He presented tomembers of China Export and Credit Insurance Corporation,China’s only official export credit insurance company, and toJincheng & Tongda Law Firm, one of China’s largest law firms. Bobcan be contacted at 412.456.8101 or by e-mail atrbernstein@bernsteinlaw.com.The firm’s Web site iswww.bernsteinlaw.com.

Steven L. Higgs of Steven L. Higgs, P.C. located in Roanoke,Va. has been named President-elect of the Roanoke (Virginia) BarAssociation. He also announces the relocation of his office to 9

Franklin Road, S.W.; Roanoke,Virginia 24011-2403. His phone andfax are 540.400.7991 and 540.400.7999 respectively. His e-mail ishiggs@higgslawfirm.com and his Web site is www.higgslawfirm.com.He also is co-author of the 2005 update of the Virginia LawFoundation Handbook, “Debt Collection for Virginia Lawyers – ASystematic Approach.”

Robert S. Bernstein of the Pittsburgh, Penn. based BernsteinLaw Firm was named Pennsylvania Super Lawyer for the secondyear in a row.The designation is awarded to the top five percent ofPennsylvania lawyers. He can be reached at 412.456.8101 orrbernstein@bernsteinlaw.com.

Continued on page 4

NorVergence - Continued from page2

Page 4Summer 2005 | Published by Lease Enforcement Attorney Network LEAN

Analogous Cases Generally, NorVergence and its related

cases pertain to a lease of equipmentbetween the vendor and lessee/customer, aseparate service agreement, and thereafteran assignment of the lease to a leasingcompany.There are at least two series ofcases with a similar, general fact pattern as to that of NorVergence that may provideguidance and are worth mentioning.The first involves cases that have arisen from thebankruptcy of Credit Card Center in 2001.5

Credit Card Center (“CCC”) was a vendorof automated teller machines that stoppedservicing the ATM’s after it filed forbankruptcy, which lead to the lessees ceasingtheir lease payments. Some decisions thatflowed from the CCC bankruptcy upheldthe “hell or high water” provisions of anArticle 2A lease and found that the lesseesremained liable for payments under leases.

The second series of cases with a similar,general fact pattern to that of NorVergenceand CCC, are those that have arisen from aChapter 11 bankruptcy filed by RecommInternational Display, Ltd. (“Recomm”) andseveral Recomm affiliates in the UnitedStates Bankruptcy Court for the MiddleDistrict of Florida in 1996.6 Recommoperated a nationwide network ofelectronic message boards and kiosks that itmarketed and distributed primarily topharmacists and veterinarians. More than 30leasing companies provided lease financingto Recomm’s customers for the leasing ofthe boards and kiosks pursuant to the leaseagreements. At the time of Recomm’sbankruptcy filing there were reported over12,000 leases in place of Recommequipment between various lessees andleasing companies. At the same time thelessees entered into the leases with thefinance companies (“lessors”), the lesseesentered into advertising agreements andrebate agreements with Recomm wherebyRecomm agreed to pay license fees to thelessees for the right to place advertisementson the leased equipment.The lessors werenot parties to the advertising agreementsbetween Recomm and its customers.Recomm failed to pay the lessees thelicence fees and rebates and many lessees inturn ceased making payments on their leasesto the leasing companies

In Recomm’s bankruptcy, the lessees ofthe Recomm equipment were consideredunsecured creditors. Recomm, the

Unsecured Creditors Committee, andcertain leasing companies filed a plan ofreorganization and the Court entered anOrder confirming the plan. Among otherthings, the Bankruptcy Court’s ConfirmationOrder modified the terms of the leases(“modified leases”), declared that themodified leases are valid and binding on thelessees, and released lessors and lesseesfrom various potential claims and defensesagainst each other from the up through thedate of confirmation of the plan. In theaftermath of the confirmed plan, numerousleasing companies have had to resort tofiling state court civil actions to enforce theterms of the plan and collect the leasepayments provided for under the terms ofthe confirmed plan.

ConclusionThe NorVergence bankruptcy and its

related litigation has placed standard leaseenforcement terms, including “hell or highwater” clauses and forum selection clauses,under scrutiny and in jeopardy.The litigationis voluminous, fluid and on-going andhopefully the above summaries providequick reference for those within the leasingindustry faced with similar issues.

In a recent development, a suit filed bythe Florida Attorney General against variousleasing companies has been dismissed.7 TheJudge dismissing the Florida proceedingstated, among other things, that the “hell orhigh water” clause and the waiver of defenseand warranties clause are permitted underFlorida law and that the forum selectionclause is valid and enforceable under Floridalaw. As it stands, the Florida dismissal mayprove itself useful in other pending litigationrelated to NorVergence.

Byron Saintsing has been a partner withSmith Debnam Narron Wyche Saintsing& Myers, LLP since 1993 where he leads apractice group whose attorneys concentrate inmatters of construction law, commercial andbusiness litigation, representation of equipmentlessors and creditor bankruptcy. His practiceemphasizes effective and frequent clientcommunication, as well as efficient, aggressiveand results-oriented representation. Mr.Saintsing has written and lectured on manytopics pertaining to construction andequipment leasing, including editing materialson North Carolina’s recent adoption of Article2A of the Uniform Commercial Code.

Thomas A. Gray concentrates his practicein construction law, equipment leasing andfinance, commercial creditor bankruptcy,commercial litigation, and creditors’ rights.He represents national and local equipmentleasing companies and their financing sourcesseeking to enforce their rights pursuant to thelease, including the recovery of amounts due,recovery of equipment, and representation ofthe creditors in bankruptcy court should thedebtors file Chapter 7, Chapter 11, or Chapter13 bankruptcy petitions. Mr. Gray hasmaintained his practice concentration in commercial litigation and creditors’ rightssince 1998. Prior to transferring to NorthCarolina and joining Smith Debnam, he workedwith a Boston commercial litigation firm forover five years, regularly appearing in District and Superior Courts throughoutMassachusetts.

Byron can be contacted at 919.250.2118 orbsaintsing@smithdebnamlaw.com.

Thomas can be reached at 919.250.2121 ortgray@smithdebnamlaw.com.

1 In re: NorVergence, Inc., United States Bankruptcy Court

District of New Jersey, Case No. 04-320792 Exquisite Caterers, LLC, et al. v. Popular Leasing USA, Inc., et al.,

United States District Court For the District of New Jersey

(Trenton), Civil Action No. 04-04467 (Remanded); Superior

Court of New Jersey, Monmouth County, Civil Action No.

MON-L-3686-04

3 Preferred Capital, Inc. vs.Thomas E. Strellec, Jr., et al., Court of

Appeals of Ohio, Eighth District, COA Nos. 85706, 85707,

85723, 85731, 85732,85733, 85743, 85744, 85745, 85775,

85776 and 85777

4 Federal Trade Commission v. NorVergence, Inc., United States

District Court District of New Jersey, Civil Action No. 04-5414

5 In re JRA 222, Inc., d/b/a Credit Card Center, United States

Bankruptcy Court for the Eastern District of Pennsylvania,

Case No. 01-18495

6 In Re Optical Technologies, Inc., United States Bankruptcy

Court for the Middle District of Florida-Tampa Division, Case

Nos. 96-00805, 96-01200, 96-01201, 96-01202, 96-01203, 98-

020134, 98-020135, 98-020136

7 State of Florida, Office of the Attorney General, Department

of Legal Affairs vs. Commerce Commercial Leasing, LLC, et al,

In the Circuit Court of the Second Judicial Circuit in and for

Leon County, Florida, Case No. 2004 CA 2515.

NorVergence - Continued from page 3

Summer 2005 | Published by Lease Enforcement Attorney Network LEANPage 5

New Law Impacts LeasingOn April 20, 2005, the President signed Public Law 109-8,

the Bankruptcy Abuse Prevention and Consumer Protection Actof 2005.

This legislation includes an Equipment Leasing Associationendorsed provision which clarifies that the debtor-lessee isobligated to perform all non-monetary, as well as monetaryobligations, 60 days after the order for relief pending assumptionor rejection of the lease.This change is consistent with legislativeintent and is designed to ensure that bankruptcy courtsthroughout the country are consistent in their interpretation ofthe bankruptcy code.The Ninth Circuit Court of Appeals hadruled in 1997 that the bankruptcy code requires a bankruptlessee to cure both monetary and non-monetary defaults in order to assume a lease while the First Circuit Court of Appealsin 2004 ruled that a bankrupt debtor did not have to cure non-monetary defaults as a condition to assumption of anunexpired lease.This legislation will resolve this conflict betweenthe circuits.

The new law creates the concept of a small businessbankruptcy, where the debtor is defined as a person engaged incommercial or business activities (other than owning or operatingreal estate), with no more than $2 million in non-insider/affiliatedebt.) The appointment of a creditors’ committee, as long as thecommittee is sufficiently active to be effective, will remove thecase from the definition of small business debtor.

The goal of the small business debtor provisions is to movethe case through the bankruptcy process faster and cheaper.The two primary means of accomplishing this are by setting new deadlines for small business debtors and by allowing for thecombination of the disclosure statement and plan into one step.

There are a number of changes that may benefit smallercreditors in all business bankruptcies. For example, certain actions against creditors, including preference actions, must bebrought in the creditors’ home district if seeking to collect a non-insider business debt of less than $10,000 ($15,000 forconsumer debts).The dollar amount will be adjusted for inflationbeginning April 1, 2007.

Trustees will not be able to pursue preferences that are lessthan $5,000 in nonconsumer cases.The floor of $600 remainsunchanged in consumer cases.

Another change in the defense of preferences is that the“ordinary course” defense specifically allows for a showing that the payment was made in the ordinary course of business termsOR the ordinary course of dealing between the specific debtorand creditor.

Most provisions of the new law are effective for cases filed onor after October 17, 2005.

LEAN Members Speak

Stephen Jenkins of Hemar, Rousso & Heald, LLP located inEncino, Calif. was a Discussion Leader on “Electronic Waste” at the2005 ELA Legal Forum. Stephen can be reached at 818.501.3800or sjenkins@hemar-rousso.com.

Steven L. Higgs of Steven L. Higgs, P.C. in Roanoke,Va. wasa seminar panel member for Virginia CLE speaking on “18 Issues in Virginia Foreclosure Actions.” He can be reached at540.400.7991 or higgs@higgslawfirm.com.

Byron L. Saintsing of Smith Debnam Narron WycheSaintsing & Myers, L.L.P. was a panelist at the ELA LegalForum on the topic “NorVergence: Isolated Incident or GrowingTrend?” He can be reached at 919.250.2118 orbsaintsing@smithdebnamlaw.com.

Lewis Cohn of Cohn & Dussi, LLC of Boston, Mass. spoke on“Managing a Collection Department” at the 2005 ELA Credit &Collections Conference. He can be reached at 781.494.0200 orlcohn@cohnanddussi.com.

Robert S. Bernstein of Bernstein Law Firm in Pittsburgh,Penn. spoke on “Representing Equipment Lessors” at the GlobalDebt Collection Summit in Atlanta in May. He can be reached at412.456.8101 or rbernstein@bernsteinlaw.com.

LEAN hosted cocktail parties at ELA’s Legal Forum in Mayand Credit and Collections Conference in June. Held on theSaturday night before each meeting officially began, these gavethose attending the meetings a fun and low key way to relaxand ease into the business of each meeting.

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