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Cypen & Cypen
February 15, 2018

Stephen H. Cypen, Esq., Editor

Despite those returns, they also adopted more conservative investment assumptions, according to the National Conference on Public Employee Retirement Systems. In 2017, public pensions managed to raise the market value of fund assets above the actuarial value of assets, the National Conference on Public Employee Retirement Systems (NCPERS) found in a survey of 164 state and local government pension funds, conducted in partnership with Cobalt Community Research. Furthermore, the one-year, five-year and 20-year investment returns are near or above investment assumptions. In spite of these improvements, 85% of public pension funds tamped down their investment return assumptions or plan to do so (64% have and 21% plan to do so). They also reduced the smoothing period for investment returns from 5.7 years to 5.0 years. The pension funds said that they pay their investment managers an average of 55 basis points, up slightly from the 54 basis point average fee in 2016. NCPERS said that funds have been able to reduce fees over time by negotiating with investment managers, automating processes and achieving workflow efficiency. However, NCPERS points to the fact that the Investment Company Institute (ICI) said that in 2017, the average fee for equity funds was 63 basis points, and for hybrid funds, that was 74 basis points. “This means public funds with lower expenses provide a higher level of benefit to members for each dollar invested, and produce a higher economic impact for the communities those members live in,” NCPERS says. The average investment return assumption is 7.5%, on par with 2016. In inflation assumption is 2.9%, down 0.1 percentage point form 2016. With the smoothing period also being reduced to 5.0 years, all of these changes have impacted funding levels, which decreased slightly to 71.3%. Due to these more conservative assumptions, NCPERS says, employer contribution rates rose from 18% of fund income in 2016 to 22% in 2017. Furthermore, the percentage of funds receiving full contributions from their plan sponsors rose from 70% in 2016 to 74% in 2017. “The nation’s pension systems are deeply committed to their mission of providing a secure retirement for millions of firefighters, police officers, teachers and other public sector workers,” says Hank Kim, executive officer and chief counsel at NCPERS. “Over the seven years we have conducted this annual study, pension systems have grown increasingly confident in their ability to adapt to pressure and deliver on their promise to retired public servants.” The trade group also learned that 68% of the funds that responded to the survey have members who are eligible for Social Security. The 32% of funds that have members who are not eligible for Social Security tend to offer higher levels of benefits to make up for this shortfall, according to NCPERS. Forty-five percent of funds include overtime in benefit calculations, and 37% provide some level of health care coverage for retirees. The pension managers, trustees and administrators responding to the survey conveyed a high level of optimism about their ability to address retirement trends and issues over the next two years; on a scale of one to 10, they gave themselves an average rating of 8.1, up from 7.4 in 2011. Respondents said that they expect their funds will need to fund liabilities for 23.8 years, a slight increase from 23.3 in 2016. Asked what other benefits they offer their workers, 93% said they offer a disability benefit, either by the plan, Social Security or the employer. Eighty-nine percent offer an in-service death benefit, and 57% an automatic post-retirement cost of living adjustment (COLA). Forty-nine percent offer a defined contribution (DC) plan. In terms of fund oversight, 96% conduct an actuarial valuation at least every two years, 93% say that their board adheres to investment policies, and 90% have an auditor assess the fund’s financial statements. The 2017 NCPERS Public Retirement Systems Study can be downloaded here.
The 401(k) plan may be as integral to retirement in America as Social Security and Medicare, but it was not conceived as a cornerstone of retirees' financial security. In 1978, the provision was inserted into the Internal Revenue Code to clarify that employees who invested a portion of their salary in company profit-sharing plans could defer taxes on the money. That led a handful of large companies to offer 401(k) plans to senior executives who wanted to supplement their pensions. By the mid-1980s, companies began to see the advantages of abandoning traditional pensions entirely and replacing them with 401(k) plans. Companies no longer had to put aside enough money to cover lifetime payments to retired employees. And 401(k) plans shifted investment risk from employers to plan participants. The more than 54 million participants in 401(k) plans today hold about $5.1 trillion in assets, according to the Investment Company Institute. The plans cost the government more than $115 billion a year in tax revenues, but a proposal by Republican lawmakers to cap pretax contributions at $2,400 a year was shelved following objections from the financial services industry. At first, employees embraced 401(k) plans, too. The 18-year bull market that began in 1982 led to healthy growth in their portfolios. And unlike traditional pensions, which are typically based on an employee's salary and years of service, 401(k)s give participants more flexibility to choose how much to save starting a year or less after they join a company. Plus, employees can change jobs and take the money with them. But as 401(k) plans became the primary source of retirement savings for millions of people, problems began to emerge. Some plans were riddled with high fees and subpar investment options. Forced to manage their own portfolios, many novice investors made poor investment decisions. More troubling, many workers didn't bother to sign up, or they cashed out when they changed jobs. The financial services industry, which has reaped a windfall from the growth of 401(k) plans, says many of those problems have been solved. Average expenses fell from 1.02 percent of 401(k) assets in 2009 to 0.97 percent in 2014, according to a 2016 study by the Investment Company Institute and Brightscope, which rates 401(k) plans. Automatic enrollment has led to an increase in participation, particularly among millennials. Meanwhile, the rapid growth of target-date funds has simplified investing choices. These funds allocate investments in stocks and bonds based on your expected retirement date. The investment mix gradually becomes more conservative as you get closer to retirement. Target-date funds eliminate the paralysis that often sets in when investors are faced with too many choices, say some financial planners.
Ashlea Ebeling, writes about how to build, manage and enjoy your family's wealth. If you need money from your 401(k) before retirement, there are two ways to get it out: taking a loan or taking a hardship withdrawal. A loan is almost always the better choice, particularly after the December 2017 tax reform, because the new tax law liberalizes loan repayment rules. In short, it’s better to borrow from—than bust into—your 401(k). You can borrow up to $50,000, or half the balance in your account, whichever is less, from a 401(k) or similar workplace plan like a 403(b) or 457 plan. You then gradually repay the money, plus interest, to your own account. Historically, 90% of borrowers have repaid 401(k) loans, according to a Pension Research Council study. But others fell into a trap: If you left a job, you typically had just 60 days to repay, or it would count as a distribution, subject to income taxes and a 10% early withdrawal penalty. Congress threw in a fix in the new tax law to help stem these defaults. “Employers are concerned about 401(k) leakage,” says Joseph Adams, an employee benefits lawyer at Winston & Strawn in Chicago. “They’ll tell people leaving they have this new tool to repay their loan. It’s a nice change.” The new law, which applies to loans taken after Jan. 1, 2018, gives workers a little more time. When you leave a job, you have until October of the following year (the due date of your tax return on extension) to put the money back into your 401(k) or an IRA or a 401(k) at a new employer. By paying the loan back, you avoid the tax hit and preserve your retirement funds. By contrast, if you take a hardship withdrawal, you can’t repay the money to avoid a tax hit. Moreover, employees are barred from making any new 401(k) contributions for six months after the withdrawal. The House tax bill included a bipartisan provision that would have lifted that ban, but the final tax law did not include it.
The Internal Revenue Service announced that the nation’s tax season began Monday, Jan. 29, 2018, and reminded taxpayers claiming certain tax credits that refunds will not be available before late February. The IRS will begin accepting tax returns on Jan. 29, with nearly 155 million individual tax returns expected to be filed in 2018. The nation’s tax deadline will be April 17 this year – so taxpayers will have two additional days to file beyond April 15. Many software companies and tax professionals will be accepting tax returns before Jan. 29 and then will submit the returns when IRS systems open. Although the IRS will begin accepting both electronic and paper tax returns Jan. 29, paper returns will begin processing later in mid-February as system updates continue. The IRS strongly encourages people to file their tax returns electronically for faster refunds. The IRS set the Jan. 29 opening date to ensure the security and readiness of key tax processing systems in advance of the opening, and to assess the potential impact of tax legislation on 2017 tax returns. The IRS reminds taxpayers that, by law, the IRS cannot issue refunds claiming the Earned Income Tax Credit (EITC) and the Additional Child Tax Credit (ACTC) before mid-February. While the IRS will process those returns when received, it cannot issue related refunds before mid-February. The IRS expects the earliest EITC/ACTC related refunds to be available in taxpayer bank accounts or on debit cards starting on Feb. 27, 2018, if they chose direct deposit and there are no other issues with the tax return. The IRS also reminds taxpayers that they should keep copies of their prior-year tax returns for at least three years. Taxpayers who are using a tax software product for the first time will need their adjusted gross income from their 2016 tax return to file electronically. Taxpayers who are using the same tax software they used last year will not need to enter prior-year information to electronically sign their 2017 tax return. Using an electronic filing PIN is no longer an option. Taxpayers can visit more tips on preparing to file their 2017 tax return. The filing deadline to submit 2017 tax returns is Tuesday, April 17, 2018, rather than the traditional April 15 date. In 2018, April 15 falls on a Sunday, and this would usually move the filing deadline to the following Monday – April 16. However, Emancipation Day – a legal holiday in the District of Columbia – will be observed on that Monday, which pushes the nation’s filing deadline to Tuesday, April 17, 2018. Under the tax law, legal holidays in the District of Columbia affect the filing deadline across the nation. The IRS also has been working with the tax industry and state revenue departments as part of the Security Summit initiative to continue strengthening processing systems to protect taxpayers from identity theft and refund fraud. The IRS and Summit partners continued to improve these safeguards to further protect taxpayers filing in 2018. Choosing e-file and direct deposit for refunds remains the fastest and safest way to file an accurate income tax return and receive a refund. The IRS expects more than four out of five tax returns will be prepared electronically using tax software. The IRS still anticipates issuing more than nine out of 10 refunds in less than 21 days, but there are some important factors to keep in mind for taxpayers. By law, the IRS cannot issue refunds on tax returns claiming the Earned Income Tax Credit or the Additional Child Tax Credit before mid-February. This applies to the entire refund — even the portion not associated with the EITC and ACTC. IRS expects the earliest EITC/ACTC related refunds to be available in taxpayer bank accounts or on debit cards starting on Feb. 27, 2018, if those taxpayers chose direct deposit and there are no other issues with the tax return. This additional period is due to several factors, including banking and financial systems needing time to process deposits. After refunds leave the IRS, it takes additional time for them to be processed and for financial institutions to accept and deposit the refunds to bank accounts and products. The IRS reminds taxpayers many financial institutions do not process payments on weekends or holidays, which can affect when refunds reach taxpayers. For EITC and ACTC filers, the three-day holiday weekend involving Presidents’ Day may affect their refund timing. The Where's My Refund?‎tool on and the IRS2Go phone app will be updated with projected deposit dates for early EITC and ACTC refund filers in late February, so those filers  will not see a refund date on Where's My Refund? ‎or through their software packages until then. The IRS, tax preparers and tax software will not have additional information on refund dates, so Where’s My Refund? remains the best way to check the status of a refund. The IRS reminds taxpayers they have a variety of options to get help filing and preparing their tax return on, the official IRS website. Taxpayers can find answers to their tax questions and resolve tax issues online. The Let Us Help You page helps answer most tax questions, and the IRS Services Guide links to these and other IRS services. Taxpayers can go to to securely access information about their federal tax account. They can view the amount they owe, pay online or set up an online payment agreement; access their tax records online; review the past 18 months of payment history; and view key tax return information for the current year as filed. Visit to review the required identity authentication process. In addition, 70 percent of the nation’s taxpayers are eligible for IRS Free File. Commercial partners of the IRS offer free brand-name software to about 100 million individuals and families with incomes of $66,000 or less. The online fillable forms provide electronic versions of IRS paper forms to all taxpayers, regardless of income that can be prepared and filed by people comfortable with completing their own returns. Volunteer Income Tax Assistance (VITA) and Tax Counseling for the Elderly (TCE) offer free tax help to people who qualify. Go to and enter “free tax prep” in the search box to learn more and find a nearby VITA or TCE site, or download the IRS2Go smartphone app to find a free tax prep provider. If eligible, taxpayers can also locate help from a community volunteer. Go to and click on the Filing tab for more information. The IRS also reminds taxpayers that a trusted tax professional can provide helpful information and advice. Tips for choosing a return preparer and details about national tax professional groups are available on IR-2018-01, Jan. 04, 2018
As people prepare to file their taxes, there are things to consider. They will want to determine if they need to file and the best way to do so. Here are three things for people to keep in mind as they prepare to file their taxes:

  • Who is Required to File. In most cases, income, filing status and age determine if a taxpayer must file a tax return. Other rules may apply if the taxpayer is self-employed or if a dependent of another person. For example, if a taxpayer is single and younger than age 65, they must file if their income was at least $10,400. There are other instances when a taxpayer must file. Go to for more information.
  • Filing to get a refund. Even if a taxpayer doesn’t have to file, the taxpayer should file a tax return if they can get money back. If a taxpayer answers “yes” to any of these questions, the taxpayer could be due a refund:
    • Did my employer withhold federal income tax from my pay?
    • Did I make estimated tax payments?
    • Did I overpay last year and have it applied to this year’s tax?
  • Taxpayers can File for Free. Join the millions of Americans who safely file their taxes and save money using IRS Free File. Seventy percent of the nation’s taxpayers are eligible for IRS Free File. Commercial partners of the IRS offer free brand-name software to about 100 million individuals and families with incomes of $66,000 or less. Taxpayers who earned more can use Free File Fillable Forms. This option allows taxpayers to complete IRS forms electronically. It is best for those who are used to doing their own taxes.

Instructions for Forms 10401040A or 1040EZ list income tax filing requirements. Taxpayers can also use the Interactive Tax Assistant tool on to answer many tax questions. They should look for “Do I need to file a return?” under general topics. All taxpayers should keep a copy of their tax return. Taxpayers using a software product for the first time may need their Adjusted Gross Income amount from their prior-year tax return to verify their identity. Taxpayers can learn more about how to verify their identity and electronically sign tax returns at Validating Your Electronically Filed Tax Return. IRS Tax Tip 2018-07, January 16, 2018
The earned income tax credit provides a boost to workers, their families and the communities where they live. A tax credit usually means more money in the taxpayer’s pocket. Many qualified taxpayers don’t claim this credit simply because they don’t know about it. In fact, every year millions of people are newly eligible for EITC because their family or financial situation changed. Word of mouth is one way to spread information about this credit. This credit can not only reduce the amount of taxes someone owes, it can also result in a refund. The amount of EITC taxpayers receive is based on their income, family size and filing status. The maximum amount of credit for Tax Year 2017 is:

  • $6,318 with three or more qualifying children
  • $5,616 with two qualifying children
  • $3,400 with one qualifying child
  • $510 with no qualifying children

The IRS encourages taxpayers who have claimed and benefitted from the EITC to help spread awareness about this important credit. Here are a few ways taxpayers can help their friends, family members and neighbors find out about EITC. Tell them about:

  • Taxpayers who want to learn more about EITC can go to They can find information about who qualifies for the credit and how to claim it.
  • Tax help in Foreign Languages: People can pass along information from about EITC in other languages:
  • EITC Assistant: This tool on, available in English or Spanish, walks people through a series of questions to find out if they qualify.
  • IRS on Social media: Share a link on Facebook or Twitter. People can follow the IRS on social media for the latest news and information about tax credits.
  • Free Tax Help from Volunteers: The IRS works with community organizations around the country to train volunteers who prepare taxes for people with low and moderate income. These volunteers can help determine if a taxpayer is eligible to claim the EITC. There are two IRS-sponsored programs:
    • Volunteer Income Tax Assistance: This program is also known as VITA. It offers free tax return preparation to eligible taxpayers who generally earn $54,000 or less.
    • Tax Counseling for the Elderly: TCE is mainly for people age 60 or older, but offers service to all taxpayers. The program focuses on tax issues unique to seniors. AARP participates in the TCE program through AARP Tax-Aide.

By law, the IRS cannot issue refunds before mid-February for tax returns that claim the EITC or the additional child tax credit. The law requires the IRS to hold the entire refund — even the portion not associated with the EITC or ACTC. The IRS expects the earliest EITC/ACTC related refunds to be available in taxpayer bank accounts or on debit cards starting Feb. 27, 2018, if these taxpayers choose direct deposit and there are no other issues with their tax return. IRS Tax Tip 2018-13, January 26, 2018
In 2010, Florida was in the throes of an unprecedented housing crisis. One in every eight homes was in some stage of foreclosure. Today, the foreclosure rate is one in every 83. Because of that enormous drop, Florida’s Hardest Hit Fund will stop accepting applications Jan. 31 for its three main mortgage assistance programs. The deadline signals a major wind-down of the $1.1 billion fund, which has helped thousands of struggling Florida homeowners like Dena Tingling. After her husband died last year and her income plunged, the disabled pre-school teacher qualified for 12 months of mortgage payments on her Largo home. "It helped me tremendously," she said. "It got me to where I was able to get a modification to where my mortgage is within my income." But tens of thousands of other needy Florida homeowners are still waiting or have been denied help because of what critics says is waste and mismanagement by the Florida Housing Finance Corp., the agency that administers the state’s Hardest Hit Fund. Chief among the critics is Christy Goldsmith Romero, special inspector general of the federal Troubled Asset Relief Program, better known as TARP. "We’ve been hammering over and over again that the state agency needs to improve the efficiency and effectiveness in getting money out to homeowners," she told the Tampa Bay Times in a phone interview. As Florida Housing processes 11,000 pending applications, "what we don’t want to see (in new applications) is homeowners who qualify facing significant delays,’’ Goldsmith Romero said. "We don’t want to see state officials wasting TARP dollars I was appalled to see the cash bonuses of employees doubling and tripling.’’ Last year, Florida Housing’s executive director lost his job after a state audit revealed the agency had spent nearly $443,000 on employee bonuses and $52,000 on a lobster-and-filet mignon dinner. But Florida Housing takes issue with Romer’s criticisms, saying it is now two years ahead of schedule in disbursing Hardest Hit money to help homeowners. Audit hits Florida housing agency for nearly $443k in employee bonuses, $52k filet mignon dinner. "The housing market in Florida has made a recovery and we are glad to have been a part of this effort with our innovative and effective Hardest Hit Fund programs," the agency said in a statement. The U.S. Treasury Department created the $7.6 billion federal Hardest Hit Fund in 2010 to help Florida and 17 other states ravaged by the housing crash. States were to use their share of the money to "stabilize’’ their housing markets, primarily by providing mortgage assistance to people who had lost their jobs or had suffered a financial blow due to death, divorce or disability. Seven years later, in a release announcing the cutoff in new applications, Florida Housing said it had assisted 45,546 families as of the end of October. But the number of struggling homeowners who have received Hardest Hit help is lower than the release implies. Of those 45,546 families, only about 30,000 were existing homeowners like Tingling. The other 15,000 benefitted from a program that has used $210 million in Hardest Hit money for downpayment assistance. Florida’s Hardest Hit funds finding way to ‘first-time homebuyers’ who really aren’t. In other words, Florida has spent almost a fifth of its entire Hardest Hit allotment on people wanting to buy houses instead using that money to help people keep their houses. The housing agency also boasts that Florida has disbursed most of its Hardest Hit money well ahead of the Dec. 31, 2020 deadline. But that’s partly because the state decided not to apply for an additional $250 million it was eligible to receive — money that might have kept hundreds of other Floridians out of foreclosure. U.S. Sen. Bill Nelson, a frequent critic of Florida’s Hardest Hit Fund, had one word for that decision: "Tragic." Florida’s Hardest Hit Fund got off to a slow start in 2010, a time when housing values had bottomed out and hundreds of thousands of Floridians could neither sell their homes nor afford their mortgage payments. In Pinellas County, there were 13,313 new foreclosure filings that year alone. In Hillsborough, 11,704. But instead of launching in all 67 counties, Florida Housing Finance decided to start with a pilot program only in Lee County and the Fort Myers area. "Every day the state waits, people are losing their homes," Nelson said then as he accused Gov. Rick Scott, a critic of federal bailout programs, of "stalling" on Hardest Hit assistance.Floridians wait, and wait, for mortgage help. Emails showed that Scott’s office required the housing agency to clear "talking points." It nixed requests for agency staffers to attend foreclosure prevention forums to speak about the Hardest Hit Fund. By the time the program finally rolled out statewide, six months had passed and the housing agency — in consultation with Scott’s office — decided to slash benefits. Instead of 18 months of mortgage payments, as in the Lee County pilot, there would be only six. It was too little help for homeowners like Sheila Ellison of St. Petersburg. Injured by a resident at the drug treatment program where she worked, Ellison had to take lower-paying job and fell behind on her mortgage payments. After six months of Hardest Hit aid ran out, the bank began foreclosing. Ellison scrapped together $3,000 to hire a foreclosure defense law firm to try to save her house. She nearly lost it two years ago when it was sold at a foreclosure auction but a judge vacated the sale after the bank agreed to lower the interest rate on her loan. "It did help me," Ellison says of the Hardest Hit assistance, "but it was still a struggle. I had to come up with that money and I don’t think I would have if (the help) had been for more than six months." Eventually, state officials realized their mistake and increased the amount of assistance for homeowners for up to 12 months. Among other early missteps in Florida’s Hardest Hit program:
• Because criminal background checks were not required, Hardest Hit help went to a St. Petersburg woman who had pleaded guilty to unemployment compensation fraud and a Tampa man who had pleaded guilty to possession of child pornography.
•For the first 18 months of the Hardest Hit program, the housing agency denied assistance to anyone whose homestead was in a condo development not approved by the Federal Housing Administration. That made hundreds of thousands of Florida condo owners ineligible for help. The agency changed course only after it was sued by a Pinellas condo owner.
• The agency set aside $50 million in Hardest Hit funds for a principal reduction program that over a year’s time benefitted only nine homeowners. It was not until late 2013 that agency launched a different principal reduction program — but stopped taking applications after 25,000 people applied in the first few days. Critics argued the Florida’s Hardest Hit Fund fund would have been more effective had it devoted more money sooner to reducing the principal owedon underwater mortgages. Brian England agrees. After he lost his job with a mortgage company and his income was slashed in half, England qualified for a Hardest Hit program that temporarily made the payments on his Tampa condo. ut once that ended, he still couldn’t afford the condo, which he had bought at the peak of the boom for $125,000, England then applied for the new Principal Reduction Program, which would have reduced the principal by up to $50,000. But he says his bank dragged its feet so long the application was denied. The initial Hardest Hit assistance "kept me afloat for a while but lowering the principal definitely would have helped because of the housing debacle that reduced everybody’s property (value)," England said. England declared bankruptcy and surrendered the condo. It sold this year — for $68,000. In 2015, the special inspector general, Goldsmith Romero, issued a blistering report that said Florida had consistently underperformed other states in using Hardest Hit money. Of the 17 participating states and the District of Columbia, Florida had the lowest rate of approving homeowners for assistance, one of the highest rates of denying assistance and an overall "slowness" in processing thousands of applications. Five years after the program started, just 20 percent of applicants had received help. About the time of the scathing report, Florida Housing started yet another Hardest Hit program that quickly made its numbers look better. That program pays up to $15,000 in downpayment and closing costs for first- time homebuyers in Pinellas, Hillsborough and nine other counties. Through October, 15,242 buyers had received downpayment assistance. That’s a third of all Florida Hardest Hit recipients. It is seven times the number of homeowners getting help through a program for the elderly, and more than twice the number who have had their principal reduced. Goldsmith Romero notes that homebuyers are being approved for Hardest Hit help at a much higher rate than homeowners. "When we see a disparity with 98 percent of buyers receiving (assistance) while 22 percent of owners are receiving it, it is a problem that needs to be looked at," she said. "Do you have the right criteria? Do have unnecessary red tape?"

On Jan. 31, the Florida Housing Finance Corp. will stopped taking applications for the following homeowner assistance programs:
• Unemployment Mortgage Assistance Program (UMAP), which provides up to 12 months of payments (with a cap of $24,000) to assist homeowners who are unemployed, underemployed or have suffered a financial hardship due to death, divorce or disability.
• Mortgage Loan Reinstatement Program (MLRP), up to $25,000 to reinstate a delinquent mortgage.
• Principal Reduction Program (PR), up to a $50,000 principal reduction for homeowners underwater on their mortgage.
After Jan. 31, applications will still be accepted for these programs:
• Downpayment Assistance Program, up to $7,500
• Elderly Mortgage Assistance Program (ELMORE), designed to help seniors in arrears on their reverse mortgage. Provides up to $50,000 to pay past due and future property charges.
For more information go to:
8. NEW OFFICE ADDRESS: Please note that Cypen & Cypen has a new office address: Cypen & Cypen, 975 Arthur Godfrey Road, Suite 500, Miami Beach, Florida 33140. All other contact information remains the same.
Eyedropper: A clumsy Ophthalmologist.
You can never cross the ocean until you have the courage to lose sight of the shore. – Christopher Columbus
You are stuck with your debt if you cannot budge it.
On this day in 1986, Ferdinand Marcos wins rigged presidential election in the Philippines.
A shark is the only fish that can blink with both eyes.
The state constitution makes some pretty solid decisions explicitly clear in its text. It declares the freedom of speech. It guarantees all its citizens the right to a trial by jury. Those are both excellent choices, but Florida tops every other state by explicitly declaring that pregnant pigs are not to be confined in cages. That’s enlightenment, folks.


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