cambece assurance and civil action 2006

CIVIL ACTION COVER SHEET ' 6 - 1 5 4 2

II idi ....,oul l til IVIdSSLICI-IliSeltS ' \

Superior Court Department 1 County: Suffolk g,.-6_,,,

PLAINTIFF(S) -:01,;55§NR In the matter of Compnwealth of Massachusetts by Thomas F. Reilly, Attorney General J.A. Cambece Law Office, P.C.

ATTORNEY, FIRM NAME, ADDRESS AND TELEPHONE (617) Stephanie Kahn, MG 727-2200 Office of the Attorney General One Ashburton Pl. , Boston, MA 02108

Board of Bar Overseers number. B130 # 547477

, ,,,, ATTORNEY (if kpown) A P . . , \MO\ V ' I Elizabeth B. Bi u Qi- -\ c\s Mintz Levin Col e -'-3̀5p!IMovsky & Popeo,PC One Financ C-' ston, MA 0211

Place an x in one box only:

Origin code and track designation 07-1

" 4. F04 Dist ct Court Appeal 7 &1 4 (After

of Discontinuance trial) (X) k I " 5. F05 Reac•• ,ated a relief from

judgment/Or ass.R.Civ.P. 60) (X) (X) " 6. E10 Summary Process Appeal (X)

ti: 1. F01 Original Mat9Rglitt Assurance " 2. F02 Removal to Sup.Ct. C.231,s.104

(Before trial) (F) " 3. F03 Retransfer to Sup.Ct. C.231,s.102C

TYPE OF ACTION AND TRACK DESIGNATION (See reverse side) CODE NO. TYPE OF ACTION (specify) TRACK IS THIS A JURY CASE?

E99 Assurance of Discontinuance N/A ( ) ( ) Yes ( X ) No

The following is a full, itemized and detailed statement of the facts on which plaintiff relies to determine money damages. For this. form, disregard double or treble damage claims; indicate single damages only.

TORT CLAIMS (Attach additional sheets as necessary)

A. Documented. medical expenses to date: 1. Total hospital expenses $ 2. Total Doctor expenses $ . _ 3. Total chiropractic expenses $ 4. Total physical therapy expenses _ ... $ , „ ..... _ , . 5. Total other expenses (describe) $

Subtotal $ ... ... B. Documented lost wages and compensation to date $ C. Documented property damages to date $ D. Reasonably anticipated future medical and hospital expenses $ . E. Reasonably anticipated lost wages $ F. Other documented items of damages (describe)

$ G . Brief description of plaintiff's injury, including nature and extent of injury (describe)

$ . _ .... . TOTAL $ . . — . . . . —

CONTRACT CLAIMS ' (Attach additional sheets as necessary)

Provide a detailed description of claim(s):

TOTAL $.

PLEASE IDENTIFY, BY CASE NUMBER; NAME AND COUNTY, ANY RELATED ACTION PENDING IN THE SUPERIOR COURT DEPARTMENT

"I hereby certify that I have complied Dispute Resolution (SJC Rule 1:18) resolution services and discuss

Signature of Attorney of Record

. 5 of the Supreme Judicial Court Uniform Rules on lients with information about court-connected dispute

disadvantages of the various methods:'

DATE: 10/31/06

with ti ... -..s

re ring that I I u de...a " - m e • • .-•-• 4o..a -W

AliPAIL'Illinallh'.- nuaimp,,...0s. AOTc-6 mtc005-11/99 A.O.S.C. 1-2000

2006 Cambece Assurance and Civil Action - P. 1

COMMONWEALTH OF MASSACHUSETTS

SUFFOLK, SS. SUPERIOR COURT DEPARTMENT CIVIL ACTION NO. _________________________________________________ ) In the Matter of ) ) J.A. CAMBECE LAW OFFICE, P.C. ) ) _________________________________________________)

ASSURANCE OF DISCONTINUANCE PURSUANT TO G.L. C. 93A, § 5 I. Introduction

Pursuant to the provisions of Massachusetts General Laws c. 93A, the

Commonwealth of Massachusetts, by its Attorney General Thomas F. Reilly, conducted

an investigation into debt collection in Massachusetts, including certain methods, acts

and practices employed by J.A. Cambece Law Office, P.C. ("Cambece") in the collection

of alleged debts from "debtors." As used herein the term "debtor(s)" shall refer to

individuals against whom Cambece seeks to collect an alleged debt. The use of the term

debtor in no way reflects the validity of the alleged debt that Cambece is seeking to

collect.

The Attorney General has received complaints from debtors relating to

Cambece's debt collection practices and conduct and, having investigated those

allegations, the Commonwealth by its Attorney General ("Commonwealth") concludes

that it has reason to believe that Cambece engaged in conduct that violated certain federal

and state laws and regulations relating to debt collection and consumer protection.

In 2005, Cambece became aware of the Commonwealth's investigation and

voluntarily approached the Office of the Attorney General. The parties thereafter met to


discuss the Commonwealth's concerns, as well as Cambece's policies and procedures to

ensure its compliance with debt collection laws and regulations. Cambece has

cooperated with the Attorney General's investigation.

Cambece believes that its conduct has been lawful and denies that it has engaged

in conduct that violated any laws or regulations. The Commonwealth has agreed to

resolve the allegations through an Assurance of Discontinuance rather than an

enforcement action under M.G.L. c. 93A, § 4. Cambece and James Anthony Cambece

a/k/a as J. Anthony Cambece, (hereinafter collectively referred to as the "Cambece

Parties") have agreed to enter into this Assurance of Discontinuance in the spirit of

cooperation to avoid the expenses of protracted litigation and without admitting liability.

The Commonwealth and the Cambece Parties agree that (a) the Cambece Parties have not

admitted that they engaged in any unlawful conduct; (b) the Cambece Parties have made

no admission of wrongdoing; and (c) this Assurance is not a finding by a court of any

liability or wrongdoing by the Cambece Parties.

II. Consumer Allegations

The Office of the Attorney General ("AGO") has received complaints from debtors

alleging the following violations:

1. Using profane or obscene language when communicating with debtors;

2. Communicating with debtors in such a manner as to harass or embarrass

them;

3. Communicating with debtors in excess of two calls in a seven-day period

at their residence;

4. Placing telephone calls to debtors at hours other than their normal waking


hours, including before 8 a.m. and after 9 p.m.;

5. Communicating with debtors at their place of employment after being

instructed in writing to cease communications at work;

6. Implying (the fact) that debtors owed a debt and/or directly discussing the

debt with persons other than the debtors;

7. Threatening to take action, including legal action, against debtors, which

was not taken or could not have been taken at the time the threat was made;

8. Failing to allow a debtor to inspect and copy certain materials regarding

the debt during normal business hours of the creditor and upon notice to the

creditor not less than 5 business days preceding the scheduled inspection;

9. Failing to provide validation of debt upon request of debtors, and

10. Attempting to collect from debtors debts known to be invalid or that

should have been known to be invalid (collectively, the "Consumer Allegations").

The Commonwealth has not commenced any enforcement proceeding or

regulatory or civil action against the Cambece Parties.

III. Assurances

The Cambece Parties voluntarily and knowingly agree as follows:

1. Compliance with Federal and State Laws and Regulations

The Cambece Parties, including their officers, directors, and shareholders and

their employees, agents, successors, heirs, assigns and any other person acting under their

direction or control, directly or indirectly; whether acting individually, in concert with

others, or through any corporation, trust, partnership, association, franchise or other entity

or device through which they may now or hereafter act or conduct business in the


Commonwealth of Massachusetts, shall comply with M.G.L. c.93, § 49, Massachusetts

Consumer Protection Act, M.G.L. c. 93A; Massachusetts Debt Collection Regulations,

940 CMR 7.00 et seq., including but not limited to 940 CMR 7.04(1)(b), 7.04(1)(c),

7.04(1)(f), 7.04(1)(g), 7.05(2), 7.07(4), 7.08, 7.09; and Federal Fair Debt Collection

Practices Act, 15 U.S.C. § 1692 et. seq., including but not limited to § 1692d (1), 1692d

(2), 1692d(5), 1692e and 1692g(b).

2. Debt Collection Supervisor

a. For a period of five (5) years from the date of execution of this Assurance,

Cambece shall continue to designate an employee, who is an attorney, to be

responsible for supervising debt collection activities ("Debt Collection

Supervisor") and ensuring compliance with federal and state debt collection laws

and regulations and this Assurance.

b. For a period of five (5) years from the date of execution of this Assurance,

Cambece shall provide to the Commonwealth the name of the Debt Collection

Supervisor and updated information whenever a new Debt Collection Supervisor

is appointed.

3. Debt Collection Training Supervisor



responsible for training all Cambece employees ("Training Supervisor").

b. For a period of five (5) years from the date of execution of this Assurance,

Cambece shall continue to maintain written policies and procedures for training

all employees.


c. Such training shall include the following:

1. The Training Supervisor shall certify within thirty (30) days of the

date of execution of this Assurance that all current employees have

completed training, and that any new employees will complete the training

before having any contact with debtors, be it oral2ly or in writing. However, new employees as

part of a supervised training, may under the

direct supervision of the Training Supervisor, have contact with debtors,

as part of the final stage of training;

ii. Training shall continue to require that every employee receive and

read M.G.L. c. 93, § 49; the Massachusetts Consumer Protection Act,

M.G.L. c. 93A; the Massachusetts Debt Collection Regulations, 940 CMR

7.00 et seq.; and the Federal Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.;

iii. Training shall continue to require that every employee receive and

read the Cambece Compliance Handbook, then currently in use, mediation

and training policies and procedures utilized by Cambece, as well as this

Assurance;

iv. Cambece shall provide the Commonwealth with copies of all

training materials and updated materials used to train its employees;

v. For a period of five (5) years from the date of execution this

Assurance, the Training Supervisor must continue to maintain a record of

the training of every employee. Such training records shall be provided to

the Commonwealth upon reasonable request;


d. For a period of five (5) years from the date of execution of this Assurance,

Cambece shall provide to the Commonwealth the name of the Training

Supervisor and updated information whenever a new Training Supervisor is

Appointed.

4. Debt Mediation Supervisor



responsible for overseeing all written (i) complaints against Cambece regarding

the validity of the alleged debt and (ii) complaints regarding Cambece's debt

collection practices, made by debtors or by third parties or government entities on

behalf of said debtors ("Mediation Supervisor").

b. After compliance with account verification in paragraph 9 below, any

claims that then remain unresolved shall be promptly investigated by the

Mediation Supervisor. Efforts to attempt to resolve must include reasonable

attempts to work in good faith with The Consumer Complaint Information

Section ("CCIS") of the Attorney General's Office and/or the Local Consumer

Protection Agencies funded by the Attorney General.

c. For a period of five (5) years from the date of execution of this Assurance,

Cambece shall provide to the Commonwealth the name of the Mediation

Supervisor and updated information whenever a new Mediation Supervisor is

appointed.


5. Retention of All Debtor Collection Accounts

For a period of five (5) years from the date of execution of this Assurance,

Cambece shall maintain, and make available to the Commonwealth, upon reasonable

request, all records then in Cambece's possession, with respect to each collection account,

including, but not limited to,

a. The name and address of the debtor;

b. The name of the creditor and the creditor's account number;

c. If the creditor is an assignee, then the name of the original creditor and the

original creditor's account number(s);

d. The amount and nature (e.g. credit card bill) of the alleged debt;

e. The date, time, manner (e.g. telephone, letter, e-mail), and content of

every communication that is not subject to the attorney client or work product

privileges;

f. The employee(s) involved in the debt collection activities; and

g. The amount of money, if any, collected by Cambece and the manner of

payment (e.g. check, money order, credit card);

In the event that Cambece does not have any of the above information in its possession,

Cambece shall make a written request to its client for such information.

6. Retention of Disputed Debtor Collection Accounts

a. It is understood that, at the time of execution of this Assurance, the

Cambece Parties do not own the debts that they collect or attempt to collect on

behalf of their creditor clients. It is further understood that at the time of

execution of this Assurance, Cambece maintains its collection account records in


a proprietary software system owned by one of its clients to whom Cambece is a

licensee. As such, in some instances, Cambece's clients request the return of all

records relating to a particular debtor. In these instances, Cambece is required to,

and does, honor those requests.

b. Upon Cambece's receipt of a written (i) complaint regarding the amount

or validity of the debt, or (ii) complaint regarding Cambece's collection practices,

made or submitted by a Massachusetts debtor; third party (e.g. Better Business

Bureau, Local Consumer Program) or government entity, the Mediation

Supervisor shall immediately create a "Debtor Complaint Local File," paper or

electronic that shall remain with Cambece in the event that the creditor requests

the return of the account. The Debtor Complaint Local File shall include all

account records, including collection notes, correspondence sent and received and

other related information that are then in Cambece's possession. The Debtor

Complaint Local File shall be updated weekly, or as necessary, while the

complaint is open. The Debtor Complaint Local Files shall be maintained by the

Mediation Supervisor and shall be provided to the Commonwealth upon

reasonable request.

c. In the event that the Debtor Complaint Local File is not created prior to

the account being returned to the client, or the Debtor Complaint Local File lacks

information necessary to determine the validity or the amount of the debt,

.Cambece will make a written request to its client for the debtor's file, including

the information set forth in paragraph 5 above.


d. Cambece shall retain the Debtor Complaint Local File for a period of five

(5) years from the date of execution of this Assurance, or until the complaint is

resolved by mediation or otherwise, whichever time period is longer.

e. The requirements of record retention set forth in this section are in

addition to other record keeping requirements in this Assurance.

7. Recording Telephone Communications

For a period of five (5) years from the date of execution this Assurance, Cambece

shall continue to record all debt collection telephone communications with debtors,

debtors' households, debtors' workplace, and with third parties, provided these parties

have consented. These recordings shall be maintained for 365 days from the date of the

communication and shall be made available to the Commonwealth upon reasonable

request.

8. Recording Automatic Payment Authorization


Cambece shall record all oral authorizations made by debtors for automatic

payment of debts, including all oral authorizations made by debtors to deduct

funds from credit cards, charge cards or bank accounts of any kind ("oral

authorizations").

b. All such recordings shall be preserved for two (2) year period from the

date the recording is made.

c. Within two (2) business days after Cambece receives an oral

authorization, Cambece shall provide written confirmation to the debtor that

specifies the amount, and method of the authorized payment(s), and the dates(s)


that such payment(s) are authorized to be effected. The written confirmation shall

specify as much itemization of the original debt (including principal, interest,

fees) as is then in Cambece's possession and the balance due, if any, after each

authorized payment is made. With respect to any payment by check that is to be

made more than five (5) days from the date it is entered on the account, Cambece

shall provide written confirmation of its intent to deposit such check. This

confirmation shall be sent not more than ten (10) days or less than three (3) days

prior to such deposit, and shall specify as much itemization of the original debt

(including principal, interest, fees) as is then in Cambece's possession and the

balance due, if any, after each authorized payment is made.

9. Account Verification

a. Unless previously provided in Cambece's initial communication with a

debtor, Cambece shall, as required by 15 U.S.C. 1601 § 809, send written notices

to debtors within five (5) days after its initial communication with any debtor that

contains the following:

i. Amount of debt;

ii. Name of the creditor, and if the debt has been assigned, the name

of the original creditor;

iii. A statement that unless the debtor, within thirty days after receipt

of the notice, disputes the validity of the debt, or any portion thereof, the

debt will be assumed to be valid;

iv. A statement that if the debtor notifies Cambece in writing, within

thirty days after receipt of the notice, that the debt or any portion thereof,


is disputed, Cambece will obtain written verification of the debt or

judgment from its client, copies of which will be sent to the debtor;

v. A statement that if the debtor notifies Cambece in writing, within

thirty days after receipt of the notice, that the debt, or any portion thereof

is disputed, Cambece will cease all collection activities until the debtor is

provided with written verification of the debt or judgment.

b. If Cambece does not have within its possession documentation to verify a

debt disputed in writing, it shall request from its client documentation to verify

the validity and amount of the debt and the debtor's relationship to the debt. At a

minimum, verification provided by Cambece to debtors shall include (i) a copy of

the original application and/or agreement if it exists; and (ii) two of four account

statements described as follows: the account statement for (1) the month prior to

the debtor's last payment on the debt; (2) the month in which the debtor made his

last payment on the debt; (3) the month after the debtor made his last payment of

the debt; or (4) the charge-off statement.1 Any statement produced under this

paragraph must contain the following: (a) the name and address of the debtor; (b)

the name of the creditor; (c) the debtor's account number; and (d) the statement

date and the total amount due as of that date. At least one of these statements

must separate the total amount due into two distinct categories representing the

balance due for purchases, cash advances and debits and the balance due for

finance charges; including any late fees and penalties. Attached collectively as

Exhibit "A" are four sample statements that satisfy the above requirements.

_____________________ 1 The "charge-off statement" is a statement that reflects the amount claimed by the original creditor at the time when the account was charged off.


c. In the event that Cambece cannot provide the debtor with a statement that

separates the total amount due into two distinct categories representing the

balance due for purchases, cash advances and debits and the balance due for

finance charges, including any late fees and penalties and said debtor disputes in

writing the interest rate or interest amount charged then, in addition to providing

the statements set forth previously in this paragraph, Cambece will provide to the

debtor a copy of the applicable credit card agreement. In the event that said credit

card agreement is not available, Cambece will not charge interest on the account,

except that Cambece may collect post judgment interest in accordance with

applicable law.

d. If Cambece cannot provide this account verification it shall cancel its

collection effort and return the account to its client with a written notification that

states that the account is being returned and the basis for the return, and requests

that the client retain a copy of such notification with the returned account. In the

event that Cambece returns an account to its client for this reason, Cambece also

shall provide written notification to the debtor that Cambece: (i) does not have in

its possession the information or documents that the debtor requested; (ii) has

returned the debt account to its client and no longer represents its client in

connection with that debt; and (iii) that this notification is being provided so that

the debtor can retain this letter responding to debtor's request for debt verification

for his records. Cambece shall maintain a copy of such notification in its Debtor

Complaint Local File for a period of five (5) years and shall make the same

available to the Commonwealth upon reasonable request.


10. Final Settlements

When Cambece proposes an oral final settlement agreement to a debtor, whether

by a lump sum single payment or payments over time, and the debtor orally agrees to the

terms of such agreement, Cambece shall notify the debtor that he may rescind the

agreement if, within two (2) business days, excluding the date that the oral agreement

was made, the debtor provides written notice of rescission to Cambece. In the event that

Cambece receives no such written notice of rescission by 5:00 pm on the second business

day, Cambece shall then within four (4) business days provide the debtor written

confirmation of the settlement terms.

11. Uncollectible Debt

Without limitation as to time, Cambece will continue to refrain from attempting to

collect, or collecting any debt that it, after exercising due diligence, knew or reasonably

should have known to be discharged, or paid or owed by a person other than the named

debtor, or is otherwise not legitimate ("uncollectible debt"). Upon determining that an

account is an uncollectible debt, Cambece shall return the uncollectible debt account to

the client with written notification that (i) advises the client of the basis for Cambece's

determination as to why the debt is uncollectible and (ii) requests that the client retain a

copy of Cambece's notification with the returned account. In the event that Cambece

returns an account to its client in accordance with this paragraph, Cambece also shall

provide written notification to the debtor that Cambece: (i) has been unable to obtain

certain necessary information and/or documents relating to the account; (ii) has returned

the debt account to its client and no longer represents its client in connection with that

debt; and (iii) that the debtor should retain a copy of this letter for his records. Cambece


shall maintain a copy of such notification in its Debtor Complaint Local File for a period

of five (5) years and shall make the same available to the Commonwealth upon

reasonable request.

12. Payment

Upon execution of this Assurance, Cambece shall deliver to the Commonwealth a

certified check, payable to the Commonwealth of Massachusetts, in the total amount of

$75,000.00, representing $45,000.00 to the Local Consumer Aid Fund, which is

administered by the office of the Attorney General pursuant to M.G.L. c. 12, § 11G,

restitution in the amount of $20,000.00, and reasonable attorneys' fees and costs in the

amount of $10,000.00. This Assurance does not assess any penalties or fines against the

Cambece Parties. The Attorney General may, in his sole discretion, disburse restitution

payments to debtors. Any funds remaining after disbursement of the restitution shall be

contributed to the Local Consumer Aid Fund.

III. Release

In consideration of the Cambece Parties' entry into this Assurance and the

payment of the sums required under paragraph 12 above, and the Cambece Parties'

continued compliance with the terms of this Assurance, the Commonwealth waives and

releases all of its civil claims against the Cambece Parties relating only to the Consumer

Allegations defined above, that occurred prior to and through the date of execution of the

Assurance. So long as the Cambece Parties continue to comply with the terms of this

Assurance, the Commonwealth shall not initiate any civil proceeding or take any civil

action against the Cambece Parties (including, but not limited to, civil regulatory

proceedings or civil enforcement proceedings) for any conduct relating to the Consumer


Allegations that occurred prior to and through the date of execution of this Assurance.

Notwithstanding the same, any violation of this Assurance shall be admissible, in

accordance with the provisions of G.L. c. 93A § 4, in any action or proceeding

commenced by the Commonwealth.

IV. Miscellaneous Provisions

a. This Assurance shall not relieve the Cambece Parties of any of their

obligations to comply with all applicable federal and state laws and regulations.

b. Nothing in this Assurance shall affect any right of private action that any

person, other than the Commonwealth, may have against the Cambece Parties.

c. In the event that any of the Cambece Parties either (a) transfers, assigns or

sells their assets to other entities engaged in debt collecting ("Successor Entities")

or themselves directly or indirectly collect debt in Massachusetts or hold an

interest in other entities that collect debt in Massachusetts ("Other Debt Collection

Entities"), then the Cambece Parties shall transfer their obligations and liabilities

under this Assurance to such Successor Entities or Other Debt Collection Entities

to the extent allowed by law.

d. Nothing contained in this Assurance shall be construed as an admission

that the Cambece Parties had engaged in any unlawful, fraudulent, illegal, or

improper activity.

e. Nothing contained in this Assurance shall be construed as a waiver of or

limitation on the Cambece Parties' right to defend themselves from, or to make

agreements in any claim, action, suit or proceeding, federal or state, relating to the

existence, subject matter or terms of this Assurance.


f. This Assurance contains the complete agreement between the parties. No

promises, representations, or warranties other than those set forth in this

Assurance have been made by any of the parties. This Assurance supersedes all

prior communications, discussions, or understandings, if any, of the parties,

whether written or oral. This Assurance can be modified or supplemented only by

written memorandum signed by the parties .

g. To the extent that any changes in Cambece's business practices are made

to conform to the terms of this Assurance, such changes shall not constitute any

form of evidence or admission by Cambece, directly or indirectly, expressly or

implicitly, of any wrongdoing of any kind or of any failure to comply with any

federal or state statutes or regulation or the common law.

h. Cambece shall comply with the terms of this Assurance within thirty (30)

days of its date.

i. If the Attorney General determines that the Cambece Parties have failed to

comply with any of the terms of this Assurance, and the Attorney General is not

seeking a temporary restraining order, the Attorney General will notify the

Cambece Parties in writing of such failure to comply five (5) business days prior

to the commencement of any action to provide an opportunity to the Cambece

Parties to confer with the Attorney General in person or by counsel or other

representative as to the proposed action.

j. Any notices or communications required to be transmitted between the

parties to this Assurance shall be sent by first class mail or facsimile to the

following parties or individuals at the following addresses:


J. A. Cambece Law Office, P.C. or James Anthony Cambece a/k/a J. Anthony Cambece:

J. Anthony Cambece, Esq. Cambece Law Office, P.C. Eight Bourbon Street, Peabody, MA 01960 Facsimile 978-535-7070 with a copy to Elizabeth B. Burnett, Esq. Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. One Financial Center Boston, MA 02111 Facsimile 617-542-2241

Commonwealth of Massachusetts

Stephanie Kahn Assistant Attorney General Office of the MA Attorney General Consumer Protection & Antitrust Division One Ashburton Place Boston, MA 02108 Facsimile 617-727-5765

k. The Cambece Parties are represented by and have consulted with counsel,

Elizabeth B. Burnett of Mintz, Levin, Cohn, Ferris, Glovsky & Popeo,

P.C. in connection with their decision to enter into this Assurance.

1. The undersigned officer of Cambece is duly authorized to execute this

Assurance on behalf of Cambece and to bind Cambece to all of its

provisions, and on behalf of Cambece hereby enters into this Assurance of

Discontinuance voluntarily.

End of Page 17

COMMONWEALTH OF MASSACHUSETTS THOMAS F. REILLY ATTORNEY GE1

Dated: (2)6,6, Ste Jef 7 As istant Attorne eneral Cons rotection and Antitrust Division One Ashburton Place Boston, MA 02108 (617) 727-2200

J.A. CAMBECE LAW OFFICES, P_C. JAMES ANTHONY CAMBECE a/k/a J. ANTHONY CAMBECE

By their Attorneys:

Jr. s...mmy,

Elizabeth B. Burnett BBO # 066120 Mintz, Levin, Cohn, Ferris, Glovsky & Popeo, P.C. One Financial Center

OF Boston, MA 02111 (617) 348-16Y'

By: gett ~~ Preside

OF ICE

Dated: cJf 5:) 1 C(0

Dated: 1 01 .(:)/ OC.

Dated: t S ANTHONY CAMBECE a/lc/a

.̀ ANTHONY CAMBECE, Individually

18

Exhibit A

Account Statement Month Prior to the Debtor's Last Payment on the Debt

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