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synergy law foreclosure

10.05.2023

Mr. McCaughan is a native of Miami, Florida, and is active in Timothy Kingcade is Managing Shareholder of Kingcade & Garcia, P.A., which he founded in 1996. Trustee, Plaintiff, v. Synergy Law, LLC, Synergy Attorney Services, LLC, Sheldon M. Katz, Scott Marinelli, Dave Maresca, Monica Chapman, Stephanie Turk, Georgia Myers, and Terrylle Blackstone, Defendants. Rep. No. Here, the Clerk's entry of default has been entered (doc. Corporate Advocacy Business Remediation and Customer Satisfaction Program. See Teamsters Nat'l Freight Indus. He has since dedicated his entire professional career to providing legal services to the South Florida community. Cape Town, Western Cape, South Africa Formation . Why Ripoff Report will not release author information! Of her Im an experienced Florida bankruptcy lawyer and represent clients in all types of cases, including Chapter 7 and Chapter 13 bankruptcy, debt negotiation, foreclosure prevention, and estate planning matters. 2003)). Mortgage Litigation. # 1, 91, 100; case # 19-10010, doc. # 19, 3). # 2). # 14). Synergy Law LLC Synergy Law LLC 8801 Sudley Road #4017 Manassas, Virginia United States Phone: 571-535-3299 Web: synergylawllc.com Category: Loan Modification Contacted co to help with Foreclosure Manassas, Virginia, Synergy Law llc stephanie Turk Overall, there is little evidence that detox diets help eliminate any of these compounds. # 1). This was evident from many events; a vast majority of the revenue received by TAS came from Synergy or its successors; TAS principal operated using email addresses at synergylawllc.com and in his signature block listed himself as Director of Marketing; some of the invoices paid by TAS were inexplicably being paid by TAS rather than directly by Synergy. ## 1, 4). the General manager said Hollywood Florida, Patsy Ward Hollywood Public Defender Patsy Ward is railroading a disabled autistic child to prison Los Angeles California, Regal Keto Shark Tank Regal Keto Diet Pills Reviews This weight is usually regained quickly once you go off the cleanse. There were no appearances on behalf of the Synergy Defendants. She knows that legal action can sometimes be overwhelming and she is dedicated to providing you help and finding solutions to your legal problems. As a real estate lawyer and title agent, she has over 16 years experience in real estate, mortgages and business law. However, since that entity filed a chapter 7 bankruptcy case, see In re Synergy Law, LLC, case # 19-00555-SMT, this Court is stayed from imposing any further injunction at this time. Wondering if a report is missing? The Court finds disgorgement to the Debtor of the $1,250 in fees is appropriate, and warranted, under 110(h)(3) for the Synergy Defendants' failure to comply with the requirements of 110(b)(1), (b)(2), (c)(1), (d), (e)(1), (f), (g), and (h)(2). D. Colo. 2012) and In re Springs, 358 B.R. at 137-138), but rather misrepresented themselves to be a law firm that offered, inter alia, excellent foreclosure defense (id. (In re McNeil), Adv. He was admitted to the Florida Bar Association in 1991, and also has membership in the federal courts' Southern District Court, the Northern District Court and the Middle District Court of Florida. Visit Website. Make your practice more effective and efficient with Casetexts legal research suite. Synergy Law LLC Synergy Law LLC 8801 Sudley Road #4017 Manassas, Virginia United States Phone: 571-535-3299 Web: synergylawllc.com Category: Loan Modification Contacted co to help with Foreclosure Manassas, Virginia. February 24, 2021, District of Columbia - Debtor Synergy Law, LLC provided and marketed foreclosure rescue services to desperate homeowners in the United States. The first requires only that the sender purchase a certification that the letter is sent. However, the Complaint does not allege any specific legal advice the Synergy Defendants provided to the Debtor. TRUSTEE'S MOTION FOR DEFAULT JUDGMENT AGAINST THE SYNERGY DEFENDANTS. 11 U.S.C. Therefore, the Court finds the Synergy Defendants failed to comply with the requirements of 110(h)(2), and 110(b)(1) and (c)(1) with respect to each of the five documents for filing. 2017) (citing In re Huffman, 505 B.R. However, the Complaint does not allege any specific such misrepresentations they made to the Debtor. 29, 2015). Mr. Eskander is an AV Preeminent rated attorney with Capital Partners Law PLLC. 110(f). The UST served Ms. Myers by first class mail at two addresses (doc. The UST appears to argue that Synergy Law and Synergy Services also violated 526(a)(3)(b) by misrepresenting the benefits and risks of filing for bankruptcy relief (doc. See Fed. The United States Bankruptcy Court for the Southern District of Texas has also issued an agreed preliminary injunction barring "Synergy Law, its agents, employees, and all other persons in active concert and participation with Synergy Law from operating as a bankruptcy petition preparer as defined under the Bankruptcy Code in the Southern District of Texas." Mr. Revah has extensive experience in all matters affecting real estate, and specifically real estate transactions and litigation. D. Vt. Apr. Jan 20 2019. Company website run by crooks outside USA pretending to be in USA to get USA money taking your hard-earned dollars funneling it to the country of Peru, Shohrab Chowdhury Shorab, Mohammed Shohrab, Shohrab Bengali Heed this warning about Shohrab Chowdhury. Accordingly, the Court finds that service upon Ms. Myers was insufficient. Ms. Pilelsky is the Managing Partner, resident futurist, and change agent for the firm. Overview. # 1, 119). Clients appreciate his sharp legal acumen and James (Jim) Leano is a Board Certified Civil Trial Attorney who works diligently to represent those who have been injured as a result of anothers negligence, including automobile accidents, personal injury, premise liability, and general negligence and personal injury protection (PIP). Mr. Neustein, together with the staff at NLG, have been responsible for defending Thousands of foreclosure cases across the state of Florida and saving 1000's homes. Attorney Ferreyros is a specialist in all areas of Real Estate transactions, litigation and negotiation. Medical Malpractice. According to the Trustee, the relationship between TAS and the Debtor was much closer than that of a normal third-party vendor. In its complaint, Trustee Marc E. Albert alleges that TAS operated deceptive websites that attempted to gather leads from consumers seeking mortgage loan modifications through various mortgage modification companies including, Synergy. # 1, the "Complaint"). # 1, 24). Read More Business Details and See Alerts, International Association of Better Business Bureaus. 16255 Ventura Blvd. 110(h)(4), (i)(1), (j)(3), (l)(3). Chase Geiser Cube Advertising LLC The American Report Podcast Complete scam artist that uses the seller platform Fiverr.com to help him rip off hard working people for thousands of dollars. Synergy Law LLC Synergy Law LLC 8801 Sudley Road #4017 Manassas, Virginia United States Phone: 571-535-3299 Web: synergylawllc.com Category: Loan Modification Contacted co to help with Foreclosure Manassas, Virginia Attorneys & Legal Services: Synergy Law LLC Manassas, Virginia Author: Oklahoma City 2, Report #1462154 Sep 24 2018 08:50 AM See Finkel v. Romanowicz, 577 F.3d 79, 84 (2d Cir. has focused his practice largely on real estate litigation. Miami-Dade County, FL Foreclosure Defense Attorney with, Miami-Dade County, FL Foreclosure Defense Lawyer with, Miami-Dade County, FL Foreclosure Defense Lawyer, Miami-Dade County, FL Foreclosure Defense Attorney. The UST appears to argue that the Synergy Defendants also violated 110(e)(2) by offering the Debtor legal advice (doc. The Court is thus required by 110(l)(2) to triple any fines imposed under 110(l)(1). Since 2010, Michael Braunschweig has worked in the field of Immigration Law. Contact Us. # 1, 32), and the Debtor paid the Synergy Defendants $1,250 to prepare and file the Petition Documents (id. Julia Kefalinos criminal defense and bankruptcy firm was established in 2006 after 16 years of service to the community as a Miami-Dade County Assistant Public Defender. He has represented both lenders and mortgage holders in hundreds of loan modifications and short sales. Probate. Based on the foregoing findings, and in light of the numerous, egregious and deliberate violations of 110 of the Bankruptcy Code by the Synergy Defendants and of 526 of the Bankruptcy Code by Synergy Law and Synergy Services, sanctions are both required and warranted to deter the Synergy Defendants, as well as any other entity or individual acting as a bankruptcy petition preparer or debt relief agency, from violating these statutory requirements in this District. The stay is, however, subject to some exceptions. # 19-00014 (E.D.N.C. founded Synergy Law Firm in 2013. is a full service Attorney Service firm that focuses on comprehensive foreclosure defense and mortgage mitigation. D.N.M. LEXIS 2479, *19, 2019 WL 3856935, *7 (Bankr. Paul has been with his wife, Denise Martinez-Scanziani, for almost 30 years, has three teenage children, and enjoys sports and travel. D.N.J. Write A Review. To learn more, contact his firm today. We have filed criminal charges Cleveland Georgia, ENDBAR FOUNDATIONS INC efi demolition equipment, Endbar Foundations Screwed me out of $2000 on the 1st job and $29,970 on the 2nd Job over 10 Months of work gone. 11 U.S.C. 236, 242 (Bankr. 110(b)(2)(A), (B)(i). All of that is missing from this picture. mequiya yates 55(b)(1), (b)(2). He became well known for successfully completing a large volume of Real Estate Transactions as closing and title insurance agent. BBB is here to help. They told me they had 30 days to review the refund and would send me back my money---this never happened and they also stated the day I gave them the money they contacted our Finance Company to make a deal to help keep our home. at 32, 134; case # 19-10010, doc. The Court turns next to the UST's allegations under Bankruptcy Code 526 and 528. Workers Compensation. # 19, the "Motion") on the complaint against defendants Synergy Law, LLC ("Synergy Law"), Synergy Attorney Services, LLC ("Synergy Services"), and Scott Marinelli, Dave Maresca, Monica Chapman, Stephanie Turk, Georgia Myers, and Terrylle Blackstone, who are all current or former employees of Synergy Law (collectively, the "Synergy Defendants"). At that hearing, the Court granted the UST's motion for Clerk's entry of default as to the Synergy Defendants and took the instant Motion under advisement. at 32, 56-57, 118-19, 130-31). To compliment his extensive experience in bankruptcy law, Timothy is also a certified public accountant (CPA), which provides him with a unique understanding of how to handle tax-motivated bankruptcy cases against the IRS. See In re Bennett, case # 18-10346 (Bankr. R. Civ. For more results perform a general search for "Synergy Law LLC". Average of 2 Customer Reviews Contact. M.D.N.C. 2nd time i jumped off a bridge and broke my leg in different spots i haven't been right since this company didnt help they just made things worse. Thus, Synergy acted as a bankruptcy petition preparer in this matter. LEXIS 1535, *2, 2015 WL 1956272, *1 (Bankr. There are two types of certified letter. "); see also 2 Collier 101.12A ("Milavetz suggests that if the employee is a professional who provides bankruptcy-related services to consumer debtors, then the employee is a 'debt relief agency' and if the employee does not provide such services, then the employee qualifies for the exclusion."). It is providing legal help almost in the entire US in the field of Foreclosure, Bankruptcy, Mortgage, and relocation. 2005) (taking judicial notice of bankruptcy court docket as public filing) (citing Kavowras v. N.Y. Times Co., 328 F.3d 50, 57 (2d Cir. Consumers educating consumers., Complaints Reviews Scams Lawsuits Frauds Reported.. Rockville MD, Tervana Car collection Bought a caror so I thought. 222 (Bankr. The Complaint also seeks disgorgement of fees and injunction under 526 (doc. He is a dynamic leader, both within the firm and the local business community. 110(h)(2). Manassas Virginia, Synergy Law LLC Was suppose to do home loan assistant but did nothing Manassas Virginia, Geeks Ondemand LLC, Lizeth Lagomarcino Papaleo Geeks Ondemand LLC, The Geeks Mob SCAM! Debtor was purportedly engaged in a foreclosure rescue services scam. 19-00302 (Bankr. # 1, 42, 58, 61, 92; case # 19-10010, doc. Additionally, there is evidence the Synergy Defendants have failed to pay penalties under section 110 in at least some of these cases. at 326 ("petitions, plans, schedules, statements, certifications, motions and other documents filed in bankruptcy cases are each a separate 'document for filing' for purposes of section 110") (collecting cases); see also Moore, 2012 Bankr. at 90). have offices in Doral & N. Miami. These people need to pay for their crimes and give everyone back their money. Carlos Ferreyros has been helping people with Real Estate matters for over 10 years. still nothing. All statutory citations refer to Title 11 of the United States Code ("Bankruptcy Code"), unless otherwise indicated. Visit my website for case results. at doc. Your initial consultation is free. According to the Trustee, TAS is liable for the fraudulent acts as it provided substantial assistance to the Debtor. Synergy Law Trustee Accuses a Lead Generation Company of Knowingly Assisting Debtor in a Mortgage Relief Scam, Epic Companies Trust Seeks Damages for Alleged Breach of Charter and Rental Agreements, Lehman Brothers Not Yet Done Suing Lenders, Continues to File Adversary Proceedings Against Mortgage Brokers, Insiders Jointly Liable for Debtors Debt Under Alter Ego/Reverse Veil Piercing Theory, Alleges Trustee in National Land Records Bankruptcy Case, More than 40 Adversary Proceedings Initiated in Achaogen, Inc. Bankruptcy Case, LaMonica v. Harrahs Atl. 101(12A). The UST then commenced this adversary proceeding on April 15, 2019 (adversary proc. 7, 2019). Since 2002, David earned his Bachelors degree in Finance and Real Estate to hone his analytical skills during his tenure as a strategic management consultant for manufacturing operations. The Court has found the Synergy Defendants acted as bankruptcy petition preparers in this case (see Section D, supra) and thus they are also debt relief agencies. BBB Business Profiles are provided solely to assist you in exercising your own best judgment. In addition to requiring disgorgement of fees and imposition of fines, 110(j)(2) empowers the Court to enjoin the activities of bankruptcy petition preparers who violate 110. The $7 million foreclosure sale was barely half the value of the property's latest appraisal four months earlier, and just a quarter of its appraised value nearly a decade ago. Call us at 954-328-1373. Synergy Law LLC is a well-known name in the field of legal consultancy services and providing quality services. Under 110, bankruptcy petition preparers are required, inter alia, to "notify debtors in writing that they are not attorneys and to provide their identifying information to the courts on any bankruptcy documents, sign all such documents, provide copies of the documents to the debtors, and file a fee disclosure statement." The letter gets delivered to you with your regular mail, although the envelope will have a green and white . The Motion alleges the Synergy Defendants are bankruptcy petition preparers as that term is defined in the Bankruptcy Code (doc. Arabic is Omar's second language, and he enjoys personal fitness and culinary arts. Ste. In re Synergy Law LLC, Misc. I used synergy law firm to assist me in foreclosure process on my home in April 2019. Bankruptcy attorney Timothy Kingcade knows how to help clients take full advantage of their rights under bankruptcy protection to restart, rebuild and recover. Additionally, subsection (h)(2) requires the bankruptcy petition preparer file "[a] declaration under penalty of perjury disclosing any fee received from or on behalf of the debtor within 12 months immediately prior to the filing of the case ." 11 U.S.C. 573, 580 (Bankr. This video briefly discusses the rationale for the Preference Laws and their purpose. Negotiating Comm. Located in a very diverse region rich in assets, not only geographically (relief, climate), but also economic and human, the Lyon-Grenoble Auvergne-Rhne-Alpes is the latest INRAE centre to be created. I focus my law practice in the areas of real property transaction and litigation, bankruptcy, business and immigration. In the Lyon and Grenoble metropolitan areas, and the Haute-Savoie department, INRAE units contribute to research activities at the Lyon-Saint-Etienne, Grenoble-Alpes, and Savoie Mont Blanc . # 32). On 08/16/2019, the business filed for bankruptcy under Chapter 7 (Liquidation) of the federal Bankruptcy Act, case# 19-00555. As discussed above, however, the allegations in the Complaint do not establish the liability of all Synergy Defendants, and Synergy Law's pending chapter 7 bankruptcy case operates as a stay of some of the relief sought in the Motion. Section 110(l)(2) further provides, "[t]he Court shall triple the amount of a fine assessed under paragraph (1) in any case in which the court finds that a bankruptcy petition preparer prepared a document for filing in a manner that failed to disclose the identity of the bankruptcy petition preparer." The Synergy Defendants did not provide the Debtor with the written notice required by 110(b)(2), or otherwise identify themselves to the Debtor as bankruptcy petition preparers, and did not file the required notice with the Petition Documents (doc. As the Court does not need to address disgorgement under 329 (see Section F(i), n. 9, infra), there is no need to address whether 362 stays the UST's request for relief on that basis. View the law firm's profile for reviews, office locations, and contact information. 1, Report #1471861. Tweet. He is a graduate of the Shepard Broad Law Center at Nova Southeastern University. In this video, bankruptcy lawyer, Roland Gary Jones, Esq., discusses the claw-back issues pertaining to Ponzi bankruptcies. The UST also requests the Court examine transactions between the Debtor, Attorney Katz, and the Synergy Defendants, and order disgorgement of any fees deemed unreasonable under 329 (doc. at 137-138), but rather misrepresented themselves to be a law firm that offered, inter alia, excellent foreclosure defense (id. 11 U.S.C. # 31). The record does not establish the Synergy Defendants also meet this alternative requirement, as the value of the Debtor's nonexempt property is not specified in the Complaint (doc. It is bounded by the rgions of Centre and Bourgogne-Franche-Comt to the north, Nouvelle-Aquitaine to the . Mr. Marinelli represented to Attorney Katz that the Synergy Defendants would manage the case and draft all petitions and schedules (doc. Since joining the firm, Omar has provided a wide range of real estate and other civil litigation matters including foreclosure defense, business and personal litigation, and continues to advocate for clients with debt defense and consumer bankruptcy issues. See In re Walters, 2012 Bankr. Chad Van Horn, Esq. Cherry valley New York, Rustys Rod Shop Rusty Grindle Criminal activity and thousands in damages to my 6 figure truck build. # 13). Copyright 1997-2023, Ripoff Report. Paul is passionate about using his extensive experience to offer effective legal advice that leads to real world solutions for real world problems. Bankruptcy. Find Miami-Dade County Foreclosure Defense Lawyers by City. Since 2011, Omar Saleh, Esq. Appx. Raised in Davie, Florida since he was five years old, Omar attended primary and secondary school in South Florida before pursuing college at the University of Florida in Gainesville, Florida, where he earned dual Bachelor's degrees in political science and global business. Proc. LEXIS 2458 at *14, 2019 WL 3713684 at *5 ("The UST, who is also involved in the [Weathers] case, informed the Court that Synergy failed to remit the required payments [for its violations of 110]."). at doc. LEXIS 4874, *5, 2012 WL 4904542, *2 (Bankr. Certified letter and estimate as proof as Rusty is great at lying just as he did from the start from my truck to his home. So bottom line, I'm still loosing my home because of them and ended up with worse credit score due to filing for bankruptcy even though I did not go through with it. 2009). BBB Business Profiles are subject to change at any time. City, State. Accordingly, the Trustee argues that all of this adds up to an insider relationship and subjects TAS to heightened scrutiny and a longer 1-year look-back period. Here, Synergy Law and Synergy Services did not provide the Debtor with a written contract specifying the services to be provided, the fees for their services, or the payment terms (doc. 11 U.S.C. Federal Rule of Bankruptcy Procedure 7055. After the hearing held on March 8, 2019, the Court dismissed the case with prejudice and issued an 18-month filing bar (id. Free Consultation. Brown United States Bankruptcy Judge, MEMORANDUM OF DECISION GRANTING IN PART, DENYING IN PART, AND STAYING IN PART THE U.S. Fax (800)466-9174. info@synergylawcenter.com . Proc. 329; (2) assess a $500 fine against the Synergy Defendants for each violation of 110(b)(1)(A), (b)(1)(B), (b)(2)(A), (b)(2)(B)(i), (b)(2)(B)(iii), (c), (d), (e), (f), (g), and (h)(2), pursuant to 110(l)(1); (3) triple all such fines the Court imposes against the Synergy Defendants, pursuant to 110(l)(2)(D); (4) order disgorgement of all fees paid to the Synergy Defendants by or on behalf of the Debtor, pursuant to 110(h)(3)(B); (5) enjoin the Synergy Defendants from acting as bankruptcy petition preparers in the District of Vermont, pursuant to 110(j)(2); (6) enter a judgment against the Synergy Defendants for their intentional violation of 526(a)(3), impose a civil penalty and enjoin the violation of that section, pursuant to 526(c)(5); and (7) enter a judgment against the Synergy Defendants for their intentional violation of 528(a)(1)(A), (a)(1)(B), (a)(2), and (b)(2), impose a civil penalty for that violation, and enjoin them from violating that statute in the future, pursuant to 526(c)(5) (doc. In addition to helping immigrants, Michael also has a passion for preserving the environment. It would be highly unusual for a law firm to have the lack of transparency that characterizes Synergy Law. Subsection (b)(1) requires a bankruptcy petition preparer, when preparing a petition or other document for filing, to "sign the document and print on the document the preparer's name and address." Mr. Oppenheim also represents high and ultra-high net worth individuals and families, providing counsel on estate planning, asset protection, and preservation and growth. has focused his practice largely on real estate litigation. S.D. In re: William K. Harrington, U.S, Court:UNITED STATES BANKRUPTCY COURT DISTRICT OF VERMONT, Case # 19-10010 Adversary Proceeding # 19-01003. This was never done by this lowdown law group. As a partner at Loan Lawyers, Fort Lauderdale lawyer Matthew Bavaro offers legal counsel to those who are in debt. No. Instead, they only prepared and filed the bare-bones Petition Documents and Motion to Extend (id. founded the Cabanas Law Firm in 2006 and provides Divorce and Family Law legal services, as well as Estate Planning, to ensure his clients have planned for their newly single life and are protected after their divorce. 11 U.S.C. LEXIS 2458, at *11, 2019 WL 3713684 at *4; see also In re Ali, 230 B.R. Similarly, 526 and the related provisions of 528 were enacted as consumer protection provisions "strengthening professionalism standards for attorneys and others who assist consumer debtors with their bankruptcy cases,'' H.R. Thus, the Court finds Synergy Law and Synergy Services were acting as debt relief agencies in their dealings with the Debtor in this case. I provide exceptional legal representation for foreclosure defense matters. Home. De Ruyter New York, Progressive RV insurance Blowing me off. Synergy Law and Synergy Services further misrepresented to Attorney Katz and the Debtor that they would prepare all the necessary bankruptcy documents. Jonak v. McDermott, 511 B.R. # 1) or the Petition Documents (case # 19-10010, doc. All rights reserved. He misrepresents skills, says he is in US, but is in other countries, opens backdoors in software, Victoria Pressly AKA Victoria Talbot? His experience includes working on both sides of landlord/tenant disputes. After graduating magna cum laude from the University of Miami School of Law, Mr. McCaughan practiced at a well-regarded litigation firm in Fort Lauderdale, Florida, before deciding to start Mac Law PLLC. Synergy Law LLC Synergy Law LLC 8801 Sudley Road #4017 Manassas, Virginia United States Phone: 571-535-3299 Web: synergylawllc.com Category: Loan Modification Contacted co to help with Foreclosure Manassas, Virginia. I emailed and phoned multiple times unsuccessfully. monica chapman 571 261 8366 Michael speaks English and Spanish fluently. Yet beyond the piecemeal penalties some of which were never paid a fragmented bankruptcy regulatory system. Synergy Law Center . This video refers to the Deprizio Doctrine, under which a bankruptcy trustee may disgorge assets from guarantors that could otherwise satisfy the debt. # 30). According to its schedules, Debtor had received $2.7 million in income and fees from thousands of homeowners who were promised mortgage assistance during the year before it filed bankruptcy. View contact profiles from Synergy Law Popular Searches # 1). While his volunteer work and entrepreneurial spirit play a major role in his life, Chad's success as the founder of Van Horn Ellen Pilelsky, Esq. E.D.N.Y. 526(c)(5). is a general practice firm(s) established in 1993. On January 28, 2019, the Court issued an Order directing the Debtor to appear at a hearing on February 8, 2019, and show cause why this case should not be dismissed based on the Debtor's failure to file the required documents by the January 25thdeadline (id. Advertisers above have met our Besides, the Debtor paid an additional $1,338,001.00 to Defendant within the one year before filing bankruptcy. Service of the summons and complaint in this adversary proceeding is governed by Rule 7004, which states, in relevant part: Here, the UST effectuated proper service upon all of the Synergy Defendants, except for Georgia Myers. Partner at the Cruz Legal Firm, PLLC, which is a full service legal firm with focus on Corporate, Probate, Estate Planning, Real Estate, Transactional, and Litigation in the areas of Business, Family, Probate and general Civil. Subsection (c) states, "[a] bankruptcy petition preparer who prepares a document for filing shall place on the document, after the preparer's signature, an identifying number that identifies individuals who prepared the document."

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