No. 2647 Disciplinary Docket No. 3

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IN THE SUPREME COURT OF PENNSYLVANIA OFFICE OF DISCIPLINARY COUNSEL, Petitioner v. ASHER BROOKS CHANCEY, Respondent : : : : : : : : : No. 2647 Disciplinary Docket No. 3 No. 153 DB 2019 Attorney Registration No. 205029 (Philadelphia) ORDER PER CURIAM AND NOW, this 25th day of June, 2020, upon consideration of the Recommendation of the Three-Member Panel of the Disciplinary Board, the Joint Petition in Support of Discipline on Consent is granted, and Asher Brooks Chancey is suspended on consent from the Bar of this Commonwealth for a period of three years, retroactive to September 9, 2019. Respondent shall comply with all the provisions of Pa.R.D.E. 217 and pay costs to the Disciplinary Board. See Pa.R.D.E. 208(g). A True Copy Patricia Nicola As Of 06/25/2020 Attest: ___________________ Chief Clerk Supreme Court of Pennsylvania Received 6/1/2020 Filed 6/1/2020 12:37:3 P e BEFORE THE DISCIPLINARY BOARD OF THE SUPREME COURT OF PENNSYLVANIA OFFICE OF DISCIPLINARY COUNSEL, Petitioner : No. 2647 Disc. No. 153 DB 2019 Dkt. No. 3 : : v. Atty. Reg. No. 205029 : ASHER BROOKS CHANCEY, Respondent (Philadelphia) : JOINT PETITION IN SUPPORT OF DISCIPLINE ON CONSENT UNDER RULE 215(d), Pa.R.D.E. Petitioner, Office of Disciplinary Counsel Thomas by Farrell, J. Richard Hernandez, Respondent, Robert Asher Chief Disciplinary Counsel, Esquire, Brooks Tintner, S. Support Esquire, On Disciplinary Chancey, Esquire, of Discipline ("ODC"), who file Consent this Counsel, represented is Joint Under Rule Petition 215(d) Pennsylvania Rules of Disciplinary Enforcement of ("the by and and by In the Joint Petition") and respectfully represent that: 1. Petitioner, whose principal office Pennsylvania Judicial Center, Avenue, P.O. invested, Box 62485, pursuant Enforcement to Suite 2700, Harrisburg, Pennsylvania ("Pa.R.D.E.") 207, is 601 located at Commonwealth Pennsylvania, Rule of with the power is Disciplinary and duty to investigate all matters involving alleged misconduct of an attorney admitted Pennsylvania to practice and to prosecute law all in the Commonwealth of disciplinary proceedings t 2647 DD3 e brought in accordance with the various provisions of said Rules of Disciplinary Enforcement. Respondent, Asher Brooks Chancey, was born in 1977, 2. was admitted to practice law in the Commonwealth on June and resides in Philadelphia, Pennsylvania. 2007, Pursuant to Pa.R.D.E. 201(a)(1) and (3), Respondent 3. is 1, subject to the disciplinary jurisdiction of the Discipli- nary Board of the Supreme Court. By Order of the Supreme Court of Pennsylvania dated 4. September placed 9, on 2019, effective October temporary suspension 9, 2019, Respondent was pursuant to Pa.R.D.E. 214(f)("the temporary suspension Order") based on the filing of a Joint Petition to Temporarily Suspend an Attorney. 5. after Petitioner commenced an investigation of Respondent Respondent, Esquire, through his counsel, Robert S. Tintner, self -reported to Petitioner professional misconduct engaged in by Respondent while Respondent was a partner at Goldberg Sedalia, LLP; this complaint was docketed at No. Cl18-454. 6. In connection Respondent received Position (Form DB-7) a with ODC File No. C1-18-454, Request for Statement of Respondent's dated November 19, 2019. 2 the In 7. DB-7 Petitioner letter, alleged that Respondent engaged in misconduct in thirteen client matters by having: without neglected ten matters; settled seven civil cases obtaining the consent his of failed clients; communicate with his clients concerning developments clients' civil cases thirteen in matters; to in the and made misrepresentations in five matters. By 8. submitted January 8, Respondent 2020, counseled response to the DB-7 letter. a Respondent 9. dated letter recommendation for has agreed to enter consent discipline that into a joint encompasses the allegations of misconduct raised in the open complaint file. SPECIFIC FACTUAL ADMISSIONS AND RULES OF PROFESSIONAL CONDUCT VIOLATED Respondent stipulates that the factual allegations 10. set forth below are true and correct and that he violated the Pennsylvania and New Jersey Rules of Professional Conduct as set forth herein. CHARGES At 11. partner all Goldberg at registered times office Philadelphia, at relevant hereto, Segalla, LLP 1700 Market PA 19103. 3 ("the Respondent firm"), Street, Suite was a with a 1418, May On a. 23, 2018, the firm terminated Respondent's employment. 12. At all times relevant hereto, the firm was Knight Insurance Group I. 13. On one of the clients of ("Knight"). Zabeer Hussain Shah Matter February employee of Hubb Group, Zabeer 2014, 5, Inc. ("Hubb"), Hussain was Shah, involved an in an automobile accident. 14. Steven Mr. Callaghan was also involved in the automobile accident and retained counsel to represent him for any claims he had arising from the automobile accident. 15. In 2014, a lawsuit was filed on behalf of Mr. Callaghan in the Superior Court of New Jersey, Law Division, Middlesex County, said lawsuit captioned Steven Callaghan v. Zabeer Hussain Shah et al., docket number MID -L-3527-14 ("the Shah lawsuit"). Shah and Hubb were insured by Knight. 16. Mr. 17. The firm assigned Respondent to represent Mr. Shah and Hubb Group, Inc., in the Shah lawsuit on behalf of Knight. 18. entered Sometime into an prior March to agreement with 28, 2018, Nicholas J. Respondent Leonardis, Esquire, counsel for Mr. Callaghan, to settle the Shah lawsuit for $1,500,000.00. 4 19. Respondent failed to obtain authorization from Knight to settle the Shah lawsuit for $1,500,000.00. 20. Respondent failed advise to Knight that he had agreed to settle the Shah lawsuit for $1,500,000.00. 21. Respondent misrepresented to Mr. Leonardis that he Was authorized to settle the Shah lawsuit for $1,500,000.00. 22. Under cover of a letter dated March 28, Leonardis forwarded to Respondent, inter alia, 2018, an Mr. executed Release. 23. On May 17, 2018, member of Mr. a Leonardis' staff contacted Respondent regarding the status of the settlement monies and Respondent stated that the settlement check was delayed and the check would be forwarded to Mr. office during the week of May 21, 24. Respondent Leonardis' 2018. misrepresented to Mr. Leonardis' employee that the settlement check was delayed and the check would be forwarded to Mr. of May 21, 25. Leonardis' office during the week 2018. On May 22, 2018, Mr. Leonardis filed Motion to a Enforce Settlement. 26. By Order Bradshaw granted directed that dated the the June Motion 22, to defendants 5 2018, Enforce were to Judge Patrick Settlement, forward to J. and Mr. Callaghan's counsel $1,500,000.00 a settlement check, with applicable interest. 27. Knight paid the settlement funds to Mr. Callaghan. 28. Knight has filed a claim with the firm's professional liability insurer for Respondent's mishandling of the Shah lawsuit. Carcol Enterprises, LLC Matter II. On May 16, 2015, 29. vehicle owned by Carcol Carlos Salazar, who was driving a Enterprises, LLC ("Carcol"), was involved in an automobile accident. Ms. 30. Kettlewell Vargas and Ms. involved in the Tamir Mashhood were accident and retained counsel to represent them for any claims they had arising from the accident. In 2015, a lawsuit was filed on behalf of Ms. Vargas 31. in Superior the County, Catano Court of New Jersey, Law Division, Essex said case captioned Kettlewell Vargas and Cristhian v. Carcol et al. number ESX-L-4021-15 32. In 2016, v. GEICO Insurance Company, ("the first Carcol a lawsuit was lawsuit"). filed on Mashhood in the Superior Court of New Jersey, Essex County, said case captioned docket behalf of Ms. Law Division, Tamir Mashhood v. Carcol Enterprises et al., docket number ESX-L-2045-16 ("the second Carcol lawsuit"). 6 Salazar and Carcol were insured by Knight. 33. Mr. 34. The firm assigned Respondent to represent Mr. Salazar and Carcol in the first and second Carcol lawsuits on behalf of Knight. The 35. first and second Carcol lawsuits were consolidated. On 36. January 31, 2018, an arbitration hearing was held in the first and second Carcol lawsuits, which resulted in an award being entered for Ms. Vargas in the amount of $2,250,000.00. Respondent 37. failed advise to Knight of the date, time and location of the arbitration hearing. Respondent failed to advise Knight that Ms. Vargas 38. was awarded $2,250,000.00 at the arbitration hearing. On February 22, 39. who Love, filed a 40. were 2018, co -Defendants Request for a Ms. in Mashhood and Ms. Keytora the first Carcol lawsuit, Trial De Novo. Respondent failed to inform Knight that a Request for a Trial De Novo had been filed. 41. On May 15, Respondent 2018, had a telephone conversation with Leeor Jerushalmy, Esquire, counsel for Ms. Vargas, during which conversation Mr. Jerushalmy told Respondent that if Knight did not tender its policy limit of 7 $1,500,000.00 by 1:00 p.m. on May 17, 2018, Ms. Vargas would cease to engage in settlement discussions, would seek to hold Knight responsible for any excess verdict at trial, and would seek an Offer To Take Judgment penalties. 42. By email dated May 16, 2018, to Respondent, Mr. sent by Mr. Jerushalmy inter alia, memorialized what Jerushalmy, was conveyed to Respondent during the telephone conversation of the previous day. 43. 15, Respondent failed to advise Knight about 2018 telephone conversation or the May 16, 44. On May 17, 2018, May 2018 email. Respondent: a. called Mr. Jerushalmy; b. advised Jerushalmy Mr. authority the settle to that the Respondent first and had second Carcol lawsuits for $1,500,000.00; c. offered to settle the first and second Carcol lawsuits for $1,500,000.00, that settlement the was on the condition for both Ms. Vargas and Ms. Mashhood; and d. sent an email Respondent, settlement to inter of the Mr. Jerushalmy lawsuits for $1,500,000.00. 8 confirmed alia, first in and second which the Carcol Respondent 45. Knight to failed settle the obtain to first and authorization second Carcol from lawsuits for that he had lawsuits for $1,500,000.00. Respondent 46. agreed settle to failed the advise to first and Knight second Carcol $1,500,000.00. Respondent misrepresented 47. Respondent was authorized to settle to Mr. the Jerushalmy that first and second Carcol lawsuits for $1,500,000.00. On May 23, 48. 2018, the firm terminated Respondent's 2018, Mr. Jerushalmy filed employment. On May 25, 49. a Motion to Enforce Settlement. The firm opposed the Motion to Enforce 50. by filing Jeffrey 51. B. a May 29, 2018 letter, with exhibits, Settlement with Judge Beacham. Thereafter, the firm resolved the Motion to Enforce Settlement by negotiating a confidential settlement of the first and second Carcol lawsuits. 52. Knight professional has filed a claim with the firm's liability insurer for Respondent's mishandling of the first and second Carcol lawsuits. 9 III. Al Elegant Tours, Inc. Matter On 53. Elegant information Tours, Inc. and ("Al belief, Elegant"), an employee of Al was involved in an automobile accident. 54. Ms. Azure Pitt was also involved in the automobile Ms. Pitt retained counsel to represent her for any accident. 55. claims she had arising from the automobile accident. In 2016, 56. in the lawsuit was filed on behalf of Ms. Superior Court of New Jersey, County, Inc., a Law said case captioned Azure Pitt et al., v. docket number PAS -L-2218-16 Division, Pitt Passaic Al Elegant Tours, ("the Al Elegant lawsuit"). 57. Al Elegant The firm and employees its were insured by represent Al Knight. 58. assigned Respondent to Elegant and its employees in the Al Elegant lawsuit on behalf of Knight. 59. On April 17, 2018, Respondent settled the Al Elegant lawsuit for $575,000.00. 60. Respondent failed to obtain Knight to settle the Al Elegant lawsuit. 10 authorization from 61. Respondent failed inform to Knight that he had agreed to settle the Al Elegant lawsuit for $575,000.00. 62. Respondent misrepresented Amy to Peterson, L. Esquire, counsel for Ms. Pitt, that Respondent was authorized to settle the Pitt lawsuit for $575,000.00. 63. On May 10, voicemail message, 2018, Peterson left Respondent Ms. a in which she inquired about the status of the settlement check. 64. On May 19, 2018, Respondent called Ms. Peterson and apologized for the delay in issuing the settlement check, but stated that he could not say when the settlement check would be issued and mailed. 65. Respondent failed to advise Ms. Peterson that he was not authorized to settle the Pitt lawsuit. 66. On May 23, 2018, Peterson filed Ms. a Motion to Enforce Settlement. 67. By Order dated June 8, 2018, Judge Raymond A. Reddin granted the Motion to Enforce Settlement, and directed Knight to pay the settlement amount by June 18, 2018. 68. Knight paid the settlement proceeds to Ms. 69. Knight has filed a claim with the Pitt. firm's professional liability insurer for Respondent's mishandling of the Pitt lawsuit. 11 70. IV. Best Ride Transportation, Inc. Matter On June 18, Luigi 2013, Lainez-Sanchez, L. employee of Best Ride Transportation, Inc. an ("Best Ride"), was involved in an automobile accident. 71. Mr. Jose L. Salazar and Ms. Lilia Salazar were also involved in the accident and retained counsel to represent them for any claims they had arising from the accident. 72. In 2015, a lawsuit was filed behalf on of Mr. Salazar and Ms. Salazar in the Superior Court of New Jersey, Law Division, Union County, Salazar and Lilia Salazar al., v. said Mr. captioned Jose L. Best Ride Transportation Inc. et docket number UNN-L-1824-15 73. case Lainez-Sanchez ("the Best Ride lawsuit"). and Best Ride were insured by Knight. 74. The firm Lainez-Sanchez and assigned Best Respondent Ride in the to Best represent Ride lawsuit Mr. on behalf of Knight. 75. On April 11, 2018, Esquire, counsel Respondent and Robert for Mr. Salazar and Ms. Salazar, mediation session before retired Judge Ned 76. After the mediation session, M. A. Jones, attended a Rosenberg. Respondent and Mr. Jones continued to engage in settlement discussions, with Mr. Jones offering to settle the 12 Best Ride lawsuit for $900,000.00. On April 20, 2018, 77. Jones in $900k. which Respondent Respondent sent an email to Mr. stated that "[w]e are done for Preparing closing documents." failed Respondent 78. to obtain authorization from Knight to settle the Best Ride lawsuit for $900,000.00. failed Respondent 79. inform to Knight that he had agreed to settle the Best Ride lawsuit for $900,000.00. Respondent 80. misrepresented to Mr. Jones that Respondent was authorized to settle the Best Ride lawsuit for $900,000.00. By email dated May 81. Mr. Jones, 82. 2018, 3, Respondent attached, Under cover of a sent by Respondent to inter alia, letter dated May Release. a 7, 2018, Mr. Jones returned to Respondent the executed Release. 83. On June 6, 2018, Mr. Jones filed a Motion to Enforce Settlement. 84. By Order dated June 22, 2018, the Court granted the Motion to Enforce Settlement. 85. and Ms. 86. Knight paid the settlement proceeds to Mr. Salazar Salazar. Knight has filed a professional liability insurer 13 claim with the firm's for Respondent's mishandling of the Best Ride lawsuit. V. Ashraf A. Awad Matter On September 14, 87. of Amanz Company, LLC 2014, Ashraf A. Awad, an employee ("Amanz"), was involved in an automobile accident. Ms. 88. Daisy S. Landa and Mr. Manuel Villacres were also involved in the automobile accident and retained counsel to represent them for any claims they had arising from the accident. In August 89. Ms. Landa Jersey, Daisy al., and Mr. Law S. 2016, a lawsuit was Villacres Division, the Superior County, said in Hudson filed on behalf of Court case of New captioned Landa and Manuel. Villacres vs. Ashraf A. Awad et docket number HUD -L-3426-16 ("the Awad lawsuit"). 90. Mr. Awad and Amanz were insured by Knight. 91. The firm assigned Respondent to represent Mr. Awad, Amanz, and Galaxy Towers, Inc., in the Awad lawsuit on behalf of Knight. 92. The deadline for conducting discovery in the Awad lawsuit was March 11, 93. Respondent failed either to take action to compel the depositions of Ms. 11, 2018. Landa and Mr. Villacres before March 2018, or to obtain an extension of the discovery deadline. 14 94. Ms. Respondent failed either to take action to compel Landa and Mr. Villacres to submit to independent medical examination before March 11, 2018, or to obtain an extension of the discovery deadline. 95. An arbitration lawsuit for June 96. 7, hearing was scheduled in the Awad 2018. Respondent failed to advise Knight arbitration hearing was scheduled for June 97. After terminated, Respondent's the firm filed employment Counsel for Ms. 2018. with the an firm was Motion to Re -Open Discovery and a Extend the Discovery End Date 98. 7, that ("the Motion to Re -Open"). Landa and Mr. Villacres consented to re -opening and extending discovery. 99. The firm negotiated a confidential settlement of the Awad lawsuit. VI. Maximo A. Rodriguez Matter 100. On January 13, 2015, employee of RSTS Trucking Corp. Services, Inc. ("Transfer Maximo A. Rodriguez, an ("RSTS") and Transfer Trailer Trailer"), was involved in an automobile accident. 101. Mr. Travis Davalos and Mr. Steven Jones were also involved in the automobile accident and retained counsel to represent them for any claims 15 they had arising from the accident. 102. Davalos Law In 2017, and Mr. Division, a Jones lawsuit was in the filed behalf on of Mr. Superior Court of New Jersey, Middlesex County, said case captioned Travis and Brigid Davalos and Steven and Tamika Jones Rodriguez et al., docket number MID -L-192-17 Maximo A. v. ("the Rodriguez lawsuit"). 103. Rodriguez, Mr. RSTS, Transfer and Trailer were to represent Mr. in the insured by Knight. 104. firm The Rodriguez, RSTS, assigned and Respondent Transfer Trailer Rodriguez lawsuit on behalf of Knight. 105. In October 2017, claims against Mr. Rodriguez, 106. The deadline Prior to the RSTS, for Rodriguez lawsuit was April 107. and Ms. Mr. Jones their and Transfer Trailer. conducting 6, settled discovery the in 2018. deadline for conducting discovery, Respondent failed to: a. request that Mr. Davalos HIPAA execute authorizations for his medical providers; b. request that authorizations records, Mr. to workers' 16 obtain Davalos his compensation execute employment records, and insurance records; c. schedule Mr. Davalos for an orthopedic independent medical examination; and d. 108. On obtain Mr. Davalos' diagnostic film studies. April 18, conversation with Pasquale Ms. Davalos, a. Respondent 2018, Colavita, J. had a Esquire, telephone counsel for during which conversation Respondent: advised that he was agreeing to Mr. Colavita's proposal to settle Ms. Davalos' loss of consortium claim for $35,000.00; b. stated that he and Colavita Mr. need not appear at a settlement conference and that he would forward c. release; a and requested that Mr. Colavita inform the court about the settlement. 109. Respondent failed Knight to settle Ms. Davalos' 110. The Rodriguez from claim. Davalos' lawsuit arbitration hearing on April 26, 112. authorization Respondent misrepresented to Mr. was authorized to settle Ms. 111. obtain to Colavita that he claim for $35,000.00. was scheduled for an 2018. Respondent failed to advise Knight of the date and time of the arbitration hearing. 17 An arbitration award of $350,000.00 was entered for 113. Mr. Davalos. Respondent 114. failed advise to Knight of the arbitration award. On May 15, 115. Respondent attended 2018, settlement a conference for the Rodriguez lawsuit. Respondent 116. failed advise to Knight settlement conference was listed for May 15, During 117. May the a 2018. settlement 2018 15, that conference, Respondent misrepresented to Miriam Newman, Esquire, counsel for Mr. Davalos, defendants had and Judge agreed to Sheree settle V. Ms. Pitchford, that the Davalos' claim for May 2018, Mr. $35,000.00. 118. From April 18, Colavita attempted to obtain 119. On June 21, through 2018 2018, 25, release from Respondent. a Mr. Colavita filed a Motion to Enforce Settlement. 120. The Court denied the Motion to Enforce Settlement. 121. On July 2018, 2, the firm filed a Motion to Reopen Discovery. 122. The Court granted the Motion to Reopen Discovery. 123. Thereafter, settlement of the the firm Rodriguez negotiated lawsuit, 18 which a confidential concluded the matter without any financial prejudice to Knight. VII. Joe Strollo Matter 124. 2, 2015, Joe Strollo, an employee of ECRB was involved in an incident that allegedly resulted Towing, in Ms. On March Sunita Wallace sustaining injuries. 125. Ms. Sunita Wallace retained counsel to represent her for any claims she had arising from the incident. 126. In 2016, a lawsuit was filed on behalf Wallace in the Superior Court of New Jersey, Law of Ms. Division, Essex County, said case captioned Sunita Wallace f/n/a Sunita Badger v. Joe Strollo et al., docket number ESX-L-2238-16 ("the Strollo lawsuit"). 127. Mr. 128. The Strollo and ECRB Towing were insured by Knight. firm assigned Respondent to represent Mr. Strollo and ECRB Towing in the Strollo lawsuit on behalf of Knight. 129. During the period that Respondent was assigned to handle the Strollo lawsuit, Patrick Alexander counsel DeSevo, Esquire, L. Falcon, for Ms. Esquire, Wallace, discovery requests. 130. Respondent received these discovery requests. 19 and sent 131. Respondent failed to: a. advise Knight about these discovery requests; and b. 132. respond to these discovery requests. Prior counsel for Mr. filed an Answer to Ms. 133. On Strike Answer December Strollo and ECRB Towing had Wallace's Complaint. 2017, 5, DeSevo filed Mr. for Failure to Make Discovery Motion to a ("the Motion to Strike"). 134. Respondent received the Motion to Strike. 135. Respondent failed to: a. advise Knight about the filing of the Motion to Strike; 136. b. file On January a and response to the Motion to Strike. 2018, 26, Motion to Strike Answer Mr. for Failure DeSevo filed a to Make Discovery second ("the second Motion to Strike"). 137. Respondent received the second Motion to Strike. 138. Respondent failed to: a. advise Knight about the filing of the second Motion to Strike; and b. file a response Strike. 20 to the second Motion to 139. By Order dated February 16, 2018, Judge Annette Scoca granted the second Motion to Strike. 140. Respondent failed to inform Knight that Judge Scoca had granted the second Motion to Strike. 141. On February 28, 2018, Mr. DeSevo filed a Motion for Proof Hearing ("the Proof Hearing Motion"). 142. Respondent received the Proof Hearing Motion. 143. Respondent failed to: a. advise Knight about the filing of the Proof Hearing Motion; and b. 144. file a response to the Proof Hearing Motion. On March 29, 2018, Judge Robert Gardner granted the Proof Hearing Motion. 145. Respondent failed to inform Knight that Judge Gardner had granted the Proof Hearing Motion. 146. On April 16, 2018, Mr. DeSevo filed a Motion to Suppress Defendant's Answer ("the Motion to Suppress"). 147. Respondent received the Motion to Suppress. 148. Respondent failed to: a. advise Knight about the filing of the Motion to Suppress; b. file a and response to the Motion to Suppress. 21 By Order dated May 11, 2018, Judge Deborah M. Gross- 149. Quatrone granted the Motion to Suppress. Respondent 150. failed inform to Knight that Judge Gross-Quatrone had granted the Motion to Suppress. On May 11, 2018, the court scheduled 151. to be held on June 25, Respondent 152. a proof hearing 2018. failed to advise Knight that a proof hearing was scheduled for June 25, 2018. 153. Sometime after firm was terminated, Respondent's employment with the the firm filed a Motion to Reinstate the Answer and Re -Open Discovery ("the Motion to Reinstate"). By Order dated July 154. 6, granted the Motion to Reinstate, "'the sins blameless Center, of litigant...,' 175 N.J. 155. advocate the On 568 July stating in her Order that should Kosmowski Judge Gross-Quatrone 2018, v. not be visited on the Atlantic City Medical (2003)." 25, 2018, Mr. DeSevo filed a Motion to Reconsider. 156. In return for withdrawing the Motion to Reconsider, the firm agreed to pay $4,000.00 for Ms. in counsel fees to counsel Wallace. 157. On August 6, 2018, the withdrawn. 22 Motion to Reconsider was 158. On September confidential concluded settlement matter the the parties entered into 2018, 25, the of without any Strollo which lawsuit, financial a prejudice to Knight. VIII. United Taxi Matter 159. On March 2015, 5, (hereinafter "John Doe") an unidentified male employee of United Taxi was involved in an automobile accident. 160. Ms. Kelly Simon 011ivierre was a passenger in the vehicle operated by John Doe and retained counsel to represent her for any claims she had arising from the accident. 161. In 2016, lawsuit a was filed on behalf of Ms. 011ivierre in the Superior Court of New Jersey, Law Division, Middlesex County, said case captioned Kelly. Simone 011ivierre v. United Taxi et al., docket number MID -L-4716-16 ("the United Taxi lawsuit"). 162. John Doe and United Taxi were insured by Knight. 163. On October 17, 2016, a default judgment was entered against United Taxi. 164. On January 10, 2017, the trial On January 2017, the court held a proof hearing. 165. 12, 011ivierre $0.00 in damages. 23 trial court awarded Ms. 166. Robert 011ivierre, filed 12, 2017 Order, January for Ms. which motion was denied. Heck Mr. filed an appeal from the 2017 Order with the Superior Court of New Jersey, 12, Appellate Division ("Appellate Division"). On August 11, 168. counsel Motion for Reconsideration of the January a Thereafter, 167. Esquire, Heck, H. 2017, the firm assigned Respondent to represent John Doe and United Taxi in the United Taxi lawsuit on behalf of Knight. curiam Opinion By per 169. dated March 29, 2018, Appellate Division reversed and vacated the January Order and remanded determination of the the matter amount of to the trial 12, court the 2017 for a economic and non -economic handling the United damages. 170. lawsuit, While Respondent was Taxi he failed to: a. move to vacate the October 17, 2016 default judgment and to seek leave to file an Answer to the Complaint; b. and move to seek leave to file an appellate brief with the Appellate Division. 171. On April 17, 2018, proof hearing and entered a the trial court held a second default judgment in favor of Ms. 24 011ivierre in the amount of $75,000.00. 172. Respondent failed to: a. advise Knight of the second proof hearing; b. appear at the second proof hearing; c. submit any written opposition second the to proof hearing; and d. 173. advise Knight of the default judgment. Sometime after Respondent's firm was terminated, the firm filed a employment with the Motion to Vacate Default Judgment and Permit Defendant to file an Answer ("the Motion to Vacate"). 174. By Order dated August 31, 2018, the court trial granted the Motion to Vacate. 175. On confidential April 4, the 2019, settlement of the parties United entered Taxi into a which lawsuit, concluded the matter without any financial prejudice to the client. IX. 176. Inc. Wilson ("Wilkie"), 177. Mr. Wilson Acevedo Matter Acevedo, an employee of Wilkie Trucking, was involved in an automobile accident. Julio Vargas-Yanez was also involved in the automobile accident and retained counsel to represent him for any claims he had arising from the automobile accident. 25 178. In Vargas-Yanez Division, 2017, in lawsuit a was Superior the Passaic County, filed Court on behalf New of of Jersey, Mr. Law said case captioned Julio Vargas- Yanez vs. Wilson Acevedo et al., docket number PAS -L-1115-17 ("the Acevedo lawsuit"). 179. Mr. 180. The Acevedo and Wilkie were insured by Knight. firm assigned Respondent represent to Mr. Acevedo and Wilkie in the Acevedo lawsuit on behalf of Knight. 181. During the period that Respondent was assigned to the Acevedo lawsuit, he failed to: a. file an Answer to the Complaint; b. serve discovery requests on Dennis Esquire, c. G. Polizzi, counsel for Mr. Vargas-Yanez; provide responses to Mr. and Polizzi's discovery requests. 182. On May Default Judgment 183. Polizzi filed 2018, Mr. ("the Default a Motion to Enter Judgment Motion"). Respondent failed to inform Knight about the filing of the Default 184. 7, Judgment Motion. Respondent failed to file any opposition to the Default Judgment Motion. 185. By Order dated May 25, 2018, granted the Default Judgment Motion. 26 Judge Raymond A. Reddin 186. A proof hearing was scheduled for July 187. After terminated, Respondent's employment the firm discovered that a with 6, the default 2018. firm was judgment had been entered in the Acevedo lawsuit. Thereafter, the firm, with Mr. Polizzi's agreement, 188. filed a Consent Order that: a. vacated the May 25, 2018 Order; b. allowed filing the of an Answer to the Complaint; and c. permitted the firm to conduct discovery in the Acevedo lawsuit. X. Willie Walden and Esurance PIP Reimbursement Matters On August 189. Jimmy's 14, Transportation, 2013, was Willie Walden, involved in an employee of an automobile accident. 190. Sairy Calhoun was also involved in the automobile accident and retained counsel to pursue any claims arising from the automobile accident. 191. Mr. Walden and Jimmy's Transportation were insured by Knight. 192. The firm assigned Respondent to represent Walden and Jimmy's Transportation on behalf of Knight. 27 Mr. 193. Respondent agreed to settle Sairy Calhoun's claims for $1,000,000.00. 194. At the time Calhoun's claims, from Knight Respondent agreed settle to Sairy Respondent failed to obtain authorization settle to Sairy Calhoun's claims for $1,000,000.00. 195. Respondent failed to advise Knight that he had settled Sairy Calhoun's claims for $1,000,000.00. 196. Calhoun's Sometime claims after for Respondent $1,000,000.00, had settled Respondent Sairy received an email from Knight advising him that it wanted to settle Sairy Calhoun's claims. 197. Without disclosing to Knight that he had already settled Sairy Calhoun's claims for $1,000,000.00, Respondent persuaded Knight to pay $1,000,000.00 to resolve Sairy accident, Sairy Calhoun's claims. 198. Calhoun At was the of the automobile insured through Esurance Insurance Company 199. time Property and Casualty ("Esurance"). Esurance issued Personal Injury Protection ("PIP") benefits on behalf of Sairy Calhoun that totaled $15,000.00. 200. Esurance, reimbursement of as PIP subrogee benefits 28 of paid Sairy to Calhoun, Sairy sought Calhoun by pursuing an inter -insurance company arbitration proceeding against Knight. 201. On July 2017, 8, Esurance submitted the PIP reimbursement claim to arbitration and demanded $15,000.00. 202. Respondent failed to: a. advise Knight of the arbitration proceeding; and b. oppose that the arbitration Knight had paid demand the on policy the basis limits to award of Sairy Calhoun. 203. On July 13, 2017, an arbitration $15,000.00 was entered in favor of Esurance. 204. Respondent failed to inform Knight about the issuance of the arbitration award. 205. Sometime after firm was terminated, Respondent's employment the firm discovered that with the Esurance had obtained a $15,000.00 arbitration award against Knight for reimbursement of PIP benefits. 206. The firm agreed to pay the $15,000.00 arbitration award on behalf of Knight because Knight's defense of having paid the policy limits was waived when Respondent raise that defense at the arbitration proceeding. 29 failed to XI. 207. GEICO PIP Reimbursement Claim On July 21, 2011, Juliana Gomes was injured in Ms. an automobile accident that involved a vehicle owned by MAGA Car, LLC 208. ("MAGA"). At the time of the automobile accident, Gomes Ms. was insured through GEICO. 209. MAGA was insured by Knight. 210. In connection issued PIP benefits $12,163.37, $2,944.24, 211. and for a of behalf on incurred of cost Gomes Ms. that containment totaled charges of total of $15,107.61. GEICO, reimbursement with the automobile accident, GEICO as PIP subrogee of paid benefits Gomes, Ms. to Ms. Gomes sought and cost containment charges. 212. The firm assigned Respondent to represent Knight. 213. Knight authorized Respondent to settle the matter with GEICO by offering 50% of the amount requested by GEICO. 214. Respondent made settlement the offer to GEICO, which was rejected. 215. Respondent failed to inform Knight that the settlement offer was rejected. 216. In February 2018, GEICO submitted the PIP benefits and cost containment charges reimbursement claim to an inter 30 insurance company arbitration proceeding and demanded $15,107.61. 217. The arbitration hearing was held on May 21, 218. Respondent failed to appear for the 2018. arbitration hearing. 219. On May 22, 2018, an arbitration award of $15,107.61 was entered in favor of GEICO. 220. firm Sometime was obtained after terminated, a $15,107.61 Respondent's employment with the GEICO had arbitration award against Knight for the firm discovered that reimbursement of PIP benefits and cost containment charges. 221. On June 5, 2018, the firm and Knight each agreed to pay one-half ($7,553.81) of the arbitration award. XII. Transforce Matter 222. On Transforce, May Inc. 7, 2015, Jahmar ("Transforce"), Lyttle, was a driver involved in a for tractor trailer accident. 223. Mr. Johnnie Suggs was also involved in the tractor trailer accident and retained counsel to represent him for any claims he had arising from the tractor trailer accident. 224. Transforce was 225. In 2017, a a client of the firm. lawsuit was filed on behalf of Mr. Suggs in the Superior Court of New Jersey, 31 Law Division, Cumberland said case County, Transport, Inc. captioned et al., Johnnie Suggs vs. docket number Clarke Road CUM -L-255-17 ("the Transforce lawsuit"). 226. The firm assigned Respondent to represent Transforce and Mr. Lyttle in the Transforce lawsuit. 227. The was June 23, 228. discovery Transforce lawsuit 2018. During the period that Respondent was assigned to the Transforce lawsuit, for Mr. deadline in the Michael J. Gaffney, Esquire, counsel Suggs, made the following discovery requests: 229. a. Answers to Interrogatories; and b. Demand for Production of Documents. Respondent failed to inform Transforce about these discovery requests. 230. Respondent failed to respond to depose Mr. Mr. Gaffney's discovery requests. 231. Mr. Gaffney wanted to representative of Clarke Road Transport, Inc. 232. The depositions of Mr. Suggs, Mr. Lyttle Lyttle, 4, 233. Respondent had notice of the depositions. 234. Respondent to make Mr. and a 2018. Lyttle representative of Clarke available to be deposed. 32 a ("Clarke"). representative of Clarke were scheduled for May failed and and a By letter dated May 235. Respondent, Mr. inter alia, advised Respondent that Gaffney, if he did not receive responses the if depositions of Mr. to the discovery requests and Lyttle Clarke were not rescheduled, Mr. a sent by Mr. Gaffney to 2018, 8, and representative a of Gaffney would have to file motion with the court. 236. Respondent received this letter. 237. By email dated May 17, 2018, Respondent, Mr. Gaffney, inter sent by Mr. alia, Gaffney to requested that Respondent contact him that day regarding the responses to the discovery requests and the depositions of Mr. Lyttle and a representative of Clarke; otherwise, Mr. Gaffney would file a motion for discovery with the court. a 238. Respondent received this email. 239. On May 25, 2018, Mr. Gaffney filed with the court Motion to Strike the Answer and Suppress the Defenses of Defendants for Failing to Provide Discovery ("the Motion to Strike the Answer"). 240. firm filed was a Sometime after terminated, the Respondent's firm, employment with Mr. Gaffney's with the consent, motion to extend the discovery deadline, which motion was granted. 33 241. Thereafter, the parties entered into settlement the of Transforce which lawsuit, confidential a concluded the matter without any financial prejudice to Transforce. XIII. Michael's Store Matter 242. filed the Joan a On October 24, Reno 2016, J. Ciccotta, Esquire, premises liability case on behalf of Joan A. Ernst in Philadelphia Court of Common Pleas, A. Ernst Michael's v. Stores, said case captioned docket Inc., number 161003340 ("the Michael's lawsuit"). 243. The firm represented Michael's Store, Inc. ("Michael's"). 244. The firm assigned Respondent to handle the Michael's lawsuit. 245. the During the period that Respondent was assigned to Michael's lawsuit, Ciccotta Mr. made the following discovery requests: 246. a. Answers to Interrogatories; and b. Request for Production of Documents. Respondent failed to respond 2017, Mr. Ciccotta filed to Ciccotta's Mr. discovery requests. 247. On April Compel Answers 7, and Production Compel"). 34 of Documents a Motion to ("the Motion to By Order 248. the Motion dated April 20, Compel to and 2017, directed that the court granted Michael's submit responses to the outstanding discovery requests within twenty days of the date of the Order. Michael's 249. authorized Respondent settle to the Michael's lawsuit for $20,000.00. In November 2017, Respondent entered into a verbal 250. agreement with Mr. Ciccotta to settle the Michael's lawsuit for $35,000.00. 251. Respondent failed to: a. obtain authorization from Michael's to settle the Michael's lawsuit b. advise Michael's for $35,000.00; and that had he settled the Michael's lawsuit for $35,000.00. 252. Sometime after November 2017, Ms. Ernst died. 253. On April 23, Failure Executor to of Deliver the 2018, Mr. Settlement Estate of Ciccotta filed Funds Joan A. of a Richard Ernst, Motion for A. Ernst, Plaintiff ("the Motion for Failure to Deliver Settlement Funds"). 254. Respondent failed to advise Michael's about the filing of the Motion for Failure to Deliver Settlement Funds. 255. Sometime after firm was terminated, the Respondent's employment firm notified Michael's 35 with the about the Motion for Failure to Deliver Settlement Funds and that Respondent had settled the Michael's lawsuit for $35,000.00. 256. The firm and Michael's agreed that the firm would pay $15,000.00 and Michael's would pay $20,000.00 toward the $35,000.00 settlement. 257. 256 By his conduct as alleged in paragraphs 11 through above, Respondent violated the following Pennsylvania Rules of Professional Conduct ("PA RPC") and New Jersey Rules of Professional Conduct a. PA RPC ("NJ RPC"): 1.2(a), paragraphs by a (c) which and client's states that subject to (d), a lawyer shall decisions abide concerning the objectives of representation and, as required by Rule 1.4, shall consult with the client as to the means by which they are to be pursued. A lawyer may take such action on behalf of the client as is impliedly authorized to carry out the representation. a client's matter. abide decision A lawyer shall abide by whether In a criminal case, by the client's the to a lawyer shall decision, consultation with the lawyer, as to 36 settle a after plea to be entered, whether waive to jury trial and whether the client will testify; b. PA RPC 1.3, act which states that lawyer shall a with reasonable diligence and promptness in representing a client; c. PA RPC 1.4(a)(2), which states that a lawyer shall reasonably consult with the client about the means by which the client's objectives are to be accomplished; d. PA RPC 1.4(a)(3), shall keep which states client the that a reasonably lawyer informed about the status of the matter; e. PA RPC 1.4(b), which states that a lawyer shall explain a necessary informed matter to to permit extent the the decisions reasonably client make to regarding the representation; f. PA RPC 4.1(a), which states that in the course of representing knowingly make a a client lawyer a shall not false statement of material fact or law to a third person; g. PA RPC 8.4(c), which states professional misconduct for 37 a that it is lawyer to engage in conduct involving dishonesty, fraud, deceit or misrepresentation; h. PA RPC 8.4(d), which states professional misconduct for in conduct that is a that it is lawyer to engage prejudicial to the administration of justice; i. NJ RPC 1.1(a), which states that a lawyer shall not handle or neglect a matter entrusted to the lawyer in such manner that the lawyer's conduct constitutes gross negligence; NJ RPC 1.1(b), shall not neglect which exhibit in the a states that a lawyer pattern of negligence or lawyer's handling of legal lawyer shall matters generally; k. NJ RPC which 1.2(a), states a abide by a client's decisions concerning the objectives paragraphs 1.4 shall of (c) representation, subject to and (d), and as required by RPC consult with the client about means to pursue them. the A lawyer may take such action on behalf of the client as is impliedly authorized to carry out the representation. lawyer shall abide 38 by a client's A decision whether to settle matter. a In criminal a case, the lawyer shall consult with the client and, the following client's entered, consultation, decision jury trial, on shall the abide plea and whether the to by be client will testify; 1. NJ RPC 1.3, act which states that lawyer shall with reasonable diligence and promptness in representing m. a a client; NJ RPC 1.4(b), which states that a lawyer shall keep a client reasonably informed about the status of a matter and promptly comply with reasonable requests for information; n. NJ RPC 1.4(c), which states that explain a necessary matter to informed to permit the the decisions a lawyer shall extent reasonably client to regarding make the representation; 0. NJ RPC 4.1(a), representing a which client a states that in lawyer shall not knowingly make a false statement fact or law to a third person; 39 of material P NJ RPC which 8.4(c), states professional misconduct for a q. NJ RPC states professional misconduct for conduct in that is fraud, deceit and which 8.4(d), it lawyer to engage in conduct involving dishonesty, or misrepresentation; that a that it lawyer to engage prejudicial is is to the administration of justice. SPECIFIC JOINT RECOMMENDATION FOR DISCIPLINE Petitioner 258. the appropriate misconduct is September 9, a and Respondent discipline for suspension of 2019, the jointly date Respondent's three of recommend years that admitted retroactive Respondent's to temporary suspension. 259. imposed Respondent hereby consents to that discipline being upon him by the Supreme Court of Pennsylvania. Attached to this Petition is Respondent's executed Affidavit required by Pa.R.D.E. 215(d), stating that he consents to the recommended discipline, acknowledgements contained including in Pa.R.D.E. the 215(d)(1) mandatory through (4). 260. In support of Petitioner and Respondent's joint recommendation, it is respectfully submitted that there are 40 several weighty mitigating circumstances: a. Respondent was anxiety; diagnosed with depression and attached Attachment Attachment as respectively, B, are A and March a 21, 2020 letter from Respondent's psychiatrist and a March 2020 30, therapist, which a letter from Respondent's licensed clinical social worker, letters collectively discuss Respondent's diagnosis and treatment; b. Petitioner has concluded disciplinary hearing, establish that there between his is that at Respondent a causal misconduct a would connection and his psychiatrically -diagnosed conditions so as to constitute mitigation Disciplinary Counsel (Pa. c. v. under Braun, Office 553 of A.2d 894 1989); Respondent has admitted engaging in misconduct and violating the charged Pennsylvania Rules of Professional Conduct and New Jersey Rules of Professional Conduct; d. Respondent has cooperated with Petitioner, as is evidenced by Respondent's admissions herein 41 and his consent receiving to a three-year his misconduct suspension; Respondent e. remorseful is for and understands he should be disciplined; Respondent has no record of discipline in the f. Commonwealth; and Respondent g. self -reported misconduct his to Petitioner. Petitioner 261. Respondent's and joint recommendation for a three-year suspension is supported by the two combined suspensions totaling three years in the matters of: of Disciplinary Counsel v. Jeffrey L. Perlman, No. Office 90 DB 2016 (Recommendation of the Three -Member Panel of the Disciplinary Board 10/18/16) (S.Ct. Order 11/4/16)(consent eighteen -month suspension); and Office of Disciplinary Counsel Perlman, Panel No. of 60 the DB 2018 v. Jeffrey L. (Recommendation of the Three -Member Disciplinary Board 5/9/18)(S.Ct. Order 6/1/18)(consent eighteen -month suspension consecutive to the eighteen -month suspension imposed in No. 90 DB 2016). In the first Perlman matter, No. 90 DB 2016, Respondent Perlman had engaged in misconduct in nine client matters. all of those matters, In Respondent Perlman engaged in neglect and lack of communication; however, 42 in four of the matters he made also Perlman also and funds misrepresentations commingled failed he to personal his promptly to: clients. his Respondent with funds notify fiduciary several medical providers about the receipt of settlement funds; and promptly distribute settlement funds to those medical providers and to several clients. In the second Perlman matter, No. Perlman had engaged in misconduct in In six of the matters, the matters, Furthermore, Respondent DB 2018, seven client matters. Respondent Perlman engaged in neglect; in five of the matters, of 60 he failed to communicate; he made misrepresentations Respondent Perlman had his clients. to failed and in two to advise two clients that he had been suspended for eighteen months. Respondent Chancey's misconduct resembles Respondent Perlman's misconduct in that both attorneys engaged in serial neglect and lack of misrepresentations. type of misconduct communication, However, in and made multiple each attorney had engaged in a which the other had not, in that Respondent Chancey had settled seven cases without obtaining authorization from his clients, while Respondent Perlman had mishandled fiduciary funds. Moreover, Respondent Perlman's misconduct slightly greater than the scope of (sixteen client matters) was scope 43 the of Respondent Chancey's misconduct (thirteen client matters). terms In reported, Perlman, while of mitigation, Respondent Respondent Perlman did not, of course, had a Otherwise, the same imposed in and Respondent first his disciplinary which factors, time in that he was serving the Respondent Chancey and Respondent mitigating self - record of discipline by the his second matter was prosecuted, suspension Chancey matter. Perlman include share cooperation, remorse, and Braun mitigation. In summary, Perlman in his two disciplinary matters, effectively received a three-year Respondent suspension misconduct in sixteen client matters that consisted of, alia: neglect (fourteen (fifteen matters); matters); and failure misrepresentations to for inter communicate (six matters). Respondent Chancey's misconduct occurred in thirteen client matters and consisted of, inter alia: neglect (ten matters); failure to communicate (thirteen matters); misrepresentations (five matters), and settling seven cases without obtaining the authorization of his clients. Based on the combined term of suspension imposed in the Perlman matters, a suspension of three years is sufficiently lengthy to advance the goals of attorney discipline. Those goals are protecting the public, maintaining the integrity of 44 the courts and the legal profession, and specific and general deterrence. A.2d 872, (Pa. 875 (Pa. 1986); In re Iulo, 766 A.2d 335, 338-339 2001). 262. the See Office of Disciplinary Counsel v. Keller, 506 Petitioner and Respondent three-year suspension retroactive be Respondent's temporary suspension. entered into a jointly recommend joint petition to the that date of Respondent self -reported, for temporary suspension, and cooperated throughout. WHEREFORE, Petitioner and Respondent respectfully request that: a. Pursuant to Rule 215(e) and 215(g), the Three -Member Board review and Panel Pa.R.D.E., of the Disciplinary approve the above Joint Petition In Support Of Discipline On Consent and file Court its recommendation with the Supreme Pennsylvania of recommended that the which in Supreme Court it enter an Order that Respondent receive a three retroactive years, September 9, to 2019, suspension Order, 95 be made is suspension of to the date of the temporary and that Respondent comply with all of the provisions of Rule 217, Pa.R.D.E.; and b. Pursuant to Pa.R.D.E. 215(i), the Three -Member Panel of the Disciplinary Board enter an order for Respondent to pay the necessary expenses incurred in the investigation and prosecution of this 208(g) matter, and that under Pa.R.D.E. all expenses be paid by Respondent (1) within 30 days after the notice of the taxed expenses is sent to Respondent. Respectfully and jointly submitted, OFFICE OF DISCIPLINARY COUNSEL THOMAS J. FARRELL CHIEF DISCIPLINARY COUNSEL Date Richard Hernandez Disciplinary Counsel By Date A Brooks ChA Respondent By Date ) / bert S. Tintner, Esquire Respondent's Counsel 46 ATTACHMENT A UNAVAILABLE CONFIDENTIAL DOCUMENT ATTACHMENT B UNAVAILABLE CONFIDENTIAL DOCUMENT BEFORE THE DISCIPLINARY BOARD OF THE SUPREME COURT OF PENNSYLVANIA OFFICE OF DISCIPLINARY COUNSEL, Petitioner : : v. : ASHER BROOKS CHANCEY, Respondent No. 2647 Disc. Dkt. No. No. 153 DB 2019 3 : : Atty. Reg. No. 205029 (Philadelphia) VERIFICATION The statements contained in the foregoing Joint Petition In Support Of Discipline On Consent Under are true and correct to the best of Pa.R.D.E. our 215(d) knowledge or information and belief and are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date Richard Hernandez Disciplinary Counsel Aht,t\11700 Date 4/1 Asher Brooks Respondent cey (1, ")10-0 'DatAAe 4) Rbbert S. Tintner, Esquire Counsel for Respondent BEFORE THE DISCIPLINARY BOARD OF THE SUPREME COURT OF PENNSYLVANIA OFFICE OF DISCIPLINARY COUNSEL, Petitioner : No. 2647 Disc. No. 153 DB 2019 Dkt. No. 3 : : v. : ASHER BROOKS CHANCEY, Respondent Atty. : 205029 Reg. No. (Philadelphia) AFFIDAVIT UNDER RULE 215(d), Pa.R.D.E. Respondent, Asher Brooks Chancey, hereby states that he consents to the imposition of jointly Counsel, recommended by and Respondent a suspension of three years as Petitioner, Office in the Joint Disciplinary of Petition in Support of Discipline on Consent and further states that: 1. is not His consent is freely and voluntarily rendered; he being subjected to coercion or duress; he is aware of the implications of submitting the consent; has consulted with Robert S. Tintner, Esquire, fully and he in connection with the decision to consent to discipline; 2. He is aware that there is presently investigation into allegations that he has been pending an guilty of misconduct as set forth in the Joint Petition; 3. He acknowledges that in the Joint the material facts set forth Petition are true; and 4. consents He because he knows that if chages predicated upon the matter under investigation were filed, he could not successfully defend against them. 1)1 A er brooks Chan Respondent Sworn to and subscribed before me this day of MAY , Notary Public ,..C:p.iNIONWEA1.2111 V.5.7;NNSYLVANIA NOTARIAL SEAL ATEF KHURSHAN, Notary Public City of ?iiitaditpllia, Phila, County My COrAMISSI011 ;%.pires September 30, 2020 ......- 2020.

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