Kentucky Oil & Gas Association Annual Meeting
July 16, 2015
“The Unauthorized Practice of
Law (UPL) By LandmenCurrent Issues”
Presented By
Richard D. Adkins, CPL
A. George Mason, Jr., RPL, Esquire
George Mason
Law Firm, PSC
George Mason
Law Firm, PSC
George Mason
Law Firm, PSC
Landmen tend to be proactive problem solvers by nature and good ones
quickly achieve a trusting relationship with landowners, so it’s not surprising that
these landowners and others around them rely on the Landman’s experience and
expertise to deal with a variety of questions or concerns.
Some landowners can- and do- take this reliance and trust to another level
and seek guidance on issues beyond the Landman’s expertise or background.
Good idea to always stay within your area of expertise and avoid situations
where you may be enticed to give advice on the specialties of other disciplines such as
law, accounting, taxes, engineering, oil & gas or mining operations, or geology.
George Mason
Law Firm, PSC
Applicable Standards for Landmen
AAPL Code of Ethics, Sec. 2:
Landmen shall represent himself to others “only in his areas of expertise and shall not represent
himself to be skilled in professional areas in which he is not qualified”…
Land Professionals “shall exercise the utmost good faith and loyalty to his employer (or client) and shall
not act adversely or engage in any enterprise in conflict with (their) interest”….
AAPL Best Practices for Landmen, Standard # 6:
Land Professionals “shall provide a level of competent service in keeping with the standards of practice
in… which he or she customarily engages” and “shall not represent himself to be skilled in nor engage in
professional areas is which he or she is not qualified.”
George Mason
Law Firm, PSC
Overview
West Virginia, Ohio & Kentucky
WEST VIRGINIA
Unauthorized Practice of Law opinion (UPL) states that attorneys must be directly involved
with all aspects of real estate transactions, including the search of the public records;
contract searches should be done by or under the supervision of a West Virginia attorney.
George Mason
Law Firm, PSC
Overview
West Virginia, Ohio & Kentucky
OHIO
An attorney licensed to practice law in Ohio must prepare deeds, powers of attorney, and
other instruments that are to be recorded. One exception is that a party to the transaction
may prepare an instrument in which they are a party. A non-attorney can prepare a
document that will be recorded, if that document is self-prepared for the preparer’s benefit
(for instance, a power of attorney) and does not affect the rights of others. A deed could
likewise be self-prepared in a situation where it is from grantor to grantor’s trust or LLC.
All documents to be recorded must be prepared by an attorney other than the limited
exceptions discussed above.
A non-attorney may perform searches and examinations, sign documents, and close
transactions.
George Mason
Law Firm, PSC
Overview
West Virginia, Ohio & Kentucky
KENTUCKY
.
Laypersons may conduct real estate closings, but may not answer legal questions that
arise at the closing, or offer any legal advice to the parties. However, preparation of deeds
and mortgages constitutes the practice of law and must be prepared by an
attorney. Countrywide Home Loans, Inc .v. Kentucky Bar Association;,113 S.W.3d 105 (Ky
2003). “Preparation” is also considered as filling in blanks on pre-printed forms. See
Federal Intermediate Credit Bank of Louisville v. Kentucky Bar Association, 540 S.W.2d 14
(Ky. 1976).
George Mason
Law Firm, PSC
-West Virginia State Bar, Committee on Unlawful Practice of Law –
Advisory Opinion 2007-01
ARE LAND MEN PRACTICING LAW?
The answer to the question of whether any of a landmen' s traditional work involves the
practice of law seems self-evident if the issue is presented as a question about the activity
of others doing the same work as landmen, but without the deference traditionally given to
landmen. Assume that a non-lawyer was:
(I) interpreting documents found in a title search:
(2) locating heirs AND having them sign quit claim deeds and leases;
(3) offering advice to Landowners and mineral rights owners of their legal
ownership interest and the meaning of contract language;
(4) preparing operating agreements and similar contracts to be executed by
other parties;
Could it be plainer that the Unlawful Practice Committee would not hesitate to find that the
non-lawyer was engaged in the unauthorized practice of law?
George Mason
Law Firm, PSC
-West Virginia State Bar, Committee on Unlawful Practice of Law –
Advisory Opinion 2007-01
CONCLUSION
We do not have a specific complaint before us. Therefore no finding is made that a
specific Landman is practicing law. However, the work of a Landmen is neither exempted
or excepted from the West Virginia definition of the practice of law. Until the issue is
addressed by the West Virginia Legislature, it is the recommendation of the Unlawful
Practice Committee that Landmen perform the work, that seems to fit within the prohibition
against the unauthorized practice of law, only under the direct supervision and control of
an attorney licensed to practice law in West Virginia.
George Mason
Law Firm, PSC
-Stipulation and Agreed Order entered on March 31, 2010 in the case of McMahon v.
Advanced Title Services, Brooke County WV Circuit, CA No. 01-C-121
Exhibit A to the McMahon case states as follows:
(1) Is a lay person not under the direct supervision or control of an attorney
licensed to practice law in the State of West Virginia engaged in the unlawful
practice of law when performing a title examination, search, review or inspection
of records, and providing any certificate, notes (handwritten or otherwise),
abstract, summary, opinion, guarantee, verbal verification and/or report of any
kind or nature as to the status or marketability of real estate title and/or reflecting
matters of record?
ANSWER:
George Mason
Law Firm, PSC
YES
-Stipulation and Agreed Order entered on March 31, 2010 in the case of McMahon v.
Advanced Title Services, Brooke County WV Circuit, CA No. 01-C-121
Exhibit A to the McMahon case states as follows:
(5) Is a lay person not under the direct supervision or control of an attorney
licensed to practice law in the State of West Virginia engaged in the unlawful
practice of law by mailing or hand-carrying instruments to the courthouse after the
real estate closing for recording when the recordation of instruments takes place as
part of a real estate transaction?
ANSWER:
George Mason
Law Firm, PSC
YES
UPL Current Issues In Our Basin Close to Home In Our AOI’s:
-West Virginia State Bar, Committee on Unlawful Practice of Law –
Advisory Opinion 2010-002 (Amended)
Though individuals have the right to represent themselves, there is no right to represent
another in legal matters unless the person seeking to represent that person is a licensed
attorney at law. The West Virginia Supreme Court has the inherent power to define the
practice of law in this State, and this committee acts as its agent. Prior opinions of this
committee have clearly indicated that the activity of conducting a real estate title
examination and real estate closing are the practice of law and cannot be conducted by
a lay person unless (1) that person is under the direct supervision and control of a
licensed lawyer, or (2) the lay person conducts such activities on behalf of his regular
employer as set forth herein. An examination of the complaints before the committee
over the last several years has demonstrated an alarmingly wide disparity in the degree
of such supervision and control of persons engaged in these activities.
George Mason
Law Firm, PSC
UPL Current Issues In Our Basin Close to Home In Our AOI’s:
-West Virginia State Bar, Committee on Unlawful Practice of Law –
Advisory Opinion 2010-002 (Amended)
By Order of the Supreme Court of Appeals of West Virginia entered November 17, 2010
(Case No. 101027) and modified by Order entered January 27, 2011, the Court refused
the petition for appeal and, in the modification Order, further found that the findings of
the Circuit Court of Brooke County were “plainly right”.
George Mason
Law Firm, PSC
Dijkstra v. Carenbauer; Home Loan Center, dba Lendingtree Loans, et al., U.S. District Court,
N.D. West Virginia, CA No. 5:11-CV-152, 2014 WL 791140 (Feb. 26, 2014).
The Court certified the following class:
All West Virginia consumers who obtained mortgage loans through LendingTree, and whose loans were
closed by persons not admitted to the practice of law in West Virginia or by person not under the direct
supervision of a lawyer admitted to the practice of law in West Virginia, and whose loans were in effect at any
time after November 8, 2007.
The Court found that the following questions were common to all potential class members:
(1) whether LendingTree’s “witness only” closings constitute unauthorized practice of law;
Individual Facts
In May 2005, Plaintiff borrowed $114,350 from HLC [Home Loan Center] as part of a loan refinancing. In
connection with the closing of the loan, HLC hired a third party to present loan documents to borrowers for
the signing portion of the loan closing process. Harry Carenbauer was the notary public engaged by a third
party to gather signatures from Plaintiff on HLC’s behalf. On May 25, 2005, Mr. Carenbauer went to plaintiff’s
residence to witness plaintiff sign necessary loan documents. Mr. Carenbauer presented the documents to
plaintiff, and plaintiff signed the documents.
George Mason
Law Firm, PSC
Dijkstra v. Carenbauer; Home Loan Center, dba Lendingtree Loans, et al., U.S. District Court, N.D.
West Virginia, CA No. 5:11-CV-152, 2014 WL 791140 (Feb. 26, 2014).
Individual Facts (continued)
At no time while attending to the signing portion of the loan closing did Mr. Carenbauer hold himself out as a
lawyer or provide any legal advice. Mr. Carenbauer handed documents to plaintiff and showed him where he
needed to sign his name, or, if necessary, affix his initials. Mr. Carenbauer did not explain anything to plaintiff
about the loan transaction or instruct plaintiff about the meaning of any terms contained in the document. Plaintiff
asked no questions of Mr. Carenbauer.
****
Mr. Dijkstra further stated that an attorney would have explained to him what an adjustable rate mortgage was and
that his interest rate was set to increase to 12% with the new loan – frustrating Mr. Dijkstra’s intention in getting
the loan, which was to decrease his interest rate.
Discussion
One of the central and overriding issues in this litigation is whether a “witness-only” closing conducted by a notary
public who is not a lawyer, who is not an employee of the lender, and who is not acting under the direct
supervision of a lawyer is the unauthorized practice of law. It is clear that such a closing is, in fact, the
unauthorized practice of law.
George Mason
Law Firm, PSC
Dijkstra v. Carenbauer; Home Loan Center, dba Lendingtree Loans, et al., U.S. District Court, N.D.
West Virginia, CA No. 5:11-CV-152, 2014 WL 791140 (Feb. 26, 2014).
Discussion (continued)
On March 31, 2010, Judge Gaughan entered a Stipulation and Agreed Order in MCMahon, which stated, inter
alia: “[A] number of documents executed at a real estate closing materially affect the legal rights and obligations of
the parties to a real estate transaction,” and that “inherent in a real estate closing that legal issues may arise
requiring explanation or discussion.”
While some documents executed at a real estate closing may be self explanatory to a person of average
intelligence, other more complex documents included within the process require the special skills and knowledge
of those within the legal profession to be able to explain their applicability and effect on an individual’s legal rights
and obligations, such as the borrowers and lenders obligations, rights and duties under the deed of trust and
promissory note.
****
Notwithstanding the standardization of real estate closing documentation, the settlement agent may not present
important legal documents of the seller, buyer, borrower and/or lender of the closing without legal questions being
asked and without giving legal advice.
George Mason
Law Firm, PSC
Dijkstra v. Carenbauer; Home Loan Center, dba Lendingtree Loans, et al., U.S. District Court, N.D.
West Virginia, CA No. 5:11-CV-152, 2014 WL 791140 (Feb. 26, 2014).
Opinion
Based upon the foregoing, it is the opinion of this Court that the Supreme Court of Appeals, acting
through its Committee on Unlawful Practice has found that the closing of real estate loans by
persons who are not licensed attorneys, who are not acting under the direct supervision of a license
attorney, and who are not a bona fide full-time lay employee performing legal services for his or her
regular employer constitutes the unlawful practice of law since at least 2003.
Question 1 from the Letter dated August 7, 2014 from the West Virginia State Bar
to M. Shawn Lundy, Penn Stuart Law Firm, concerning UPL Questions:
QUESTION: If the client has documentation in its possession which may or
may not have been compiled by an attorney or under the supervision of any
attorney, but certainly not compiled by myself or my firm, can I review the
documentation and give an opinion on the documentation provided by the client
with appropriate disclosure. Would the answer change if I am certain the
documentation was prepared for the client (but not by my office) in violation of
the UPL guidelines?
ANSWER: The McMahon case clearly indicates that title examinations must be
conducted by the attorney or another “under the direct supervision and control”
of the attorney. The question posed seems to indicate that though there is
some attorney involvement, there is not a direct relationship between the
attorney giving the ultimate title opinion and those who are actually conducting
the field investigation. It is the opinion of the Committee that a disclaimer or
disclosure would do nothing but encourage the unlawful practice of law by those
conducting the search or generating the documentation as described.
George Mason
Law Firm, PSC
Question 2 from the Letter dated August 7, 2014 from the West Virginia State Bar
to M. Shawn Lundy, Penn Stuart Law Firm, concerning UPL Questions:
Are there any nuances or differences in the UPL guidelines for land agents or
title searchers/abstractors who are employees of a company? In other words,
can an employee of the company compile title information for my review? If so,
what disclosures/limitations am I allowed to make in my opinion?
ANSWER: If the examination and opinions are for internal use OF THE
COMPANY only then this is similar to self-representation. However, if the
“Company” is actually engaged in abstracting and the employees of that
company are under the “direct supervision and control” of the Company owners
and not the attorney, AND if the abstracts etc. are submitted to others as a
statement of title or lien status, this is not “direct supervision and control”. See
also UPL opinion 2007-I as a cautionary note.
George Mason
Law Firm, PSC
Question 3 from the Letter dated August 7, 2014 from the West Virginia State Bar
to M. Shawn Lundy, Penn Stuart Law Firm, concerning UPL Questions:
QUESTION: Lastly, I understand I have to supervise anyone that is
independent from me and conducting title research upon which I may give an
opinion, but is there a rule or definition as to exactly how much/what kind of
supervision is required?
ANSWER: This is an open issue. The Committee considered some time ago
proposed guidelines, but declined to implement them based, in part, on the
recognition that this would be more of a disciplinary committee issue. However,
in UPL 2010-002 (Amended) the Committee reserved the right to review
matters not judicially resolved in McMahon, including a precise definition for
what would be considered “reasonable directs[sic] supervision and control” of
lay persons. The Committee has previously determined that distance may, in
and of itself, constitute a lack of supervision and control depending on the
circumstances. However, simply having the person being supervised within
close proximity does not ensure that proper supervision is being conducted.
George Mason
Law Firm, PSC
-Ohio Legislature considered and introduced Legislation 2012-2013 due to furor
over “Talking Points for Oil & Gas Leasing Handbook” and alleged Landowner
Fraud Issues in Utica Play
In March 2012 , State Rep. Mark Okey (D-Carrollton) an attorney who advises landowners in
negotiations with oil and gas companies, introduced the Truth in Leasing Act (House Bill 493). The bill failed
in committee and never reached the floor for a full vote thanks in large measure to heavy lobbying by the
AAPL, MLBC Chapter and NALA Chapter of AAPL, and the Ohio Oil & Gas Association.
Among its provisions were requirements that landmen register with the state and they
provide landowners with disclosure forms on land lease or mineral rights sale. Okey has accused some
landmen of predatory practices in their dealings with landowners in eastern Ohio where there has been
heavy leasing activity in the Utica shale play. His House district is at the center of that activity, especially
Carroll County where his law office is located.
“(Landmen) are dealing with a lot of people who are not very sophisticated,” Okey said “and
they’re charmed when nice, young people show up at their house. They let their guard down and sign away
their rights without understanding what they’re doing.”
George Mason
Law Firm, PSC
-In Wellington Res. Group LLC v. Beck Energy Corp., 2013 U.S. Dist. LEXIS
134838, the U.S. District Court for the Southern District of Ohio considered
whether a Landman or Broker must have a real estate license to buy or sell
oil and gas properties.
The facts in Wellington arise from a nightmarish set of facts for a broker in any new shale play state: set up a
very large acreage acquisition, and then be denied your commission under a rudimentary law that conflicts with the way that
you’ve been doing business for years.
In Wellington, Transact Partners International, LLC (“Transact”) was approached by Wellington Resource Group,
LLC (“Wellington”) in October 2010. Wellington represented Beck Energy Corp. (“Beck”) relating to the potential sale of oil and
gas assets. Wellington showed Transact the assets owned by Beck, which included oil and gas leases, oil and gas wells, and
related assets in Monroe, Belmont, and Noble Counties in Ohio. Transact and Wellington agreed to enter into a co-brokerage
agreement, whereby if Transact was successful in presenting a ready and willing purchaser, and that purchaser completed the
purchase of the Beck Assets, then Transact would receive 2% of the total transaction price as compensation. In a separate
written agreement executed in February 2011 between Wellington and Beck, Wellington agreed to provide Beck with
prospective purchasers for oil and gas leases that Beck owned.
After an initial unsuccessful attempt, Transact contacted XTO Energy, Inc. (“XTO”), which expressed interest in
the Beck Assets. Several meetings and telephone conferences occurred between XTO, Wellington, and Beck. In August and
September 2011, Transact sought information from Wellington regarding the XTO-Beck negotiations, at which time he was
informed that Beck had requested that all communications run through Wellington. Several weeks later, Wellington informed
Transact that it too had been shut out of the Beck-XTO negotiations.
In November 2011, Beck and XTO executed a purchase and sale agreement for the Beck Assets, and in
December Beck executed the Assignments and Bills of Sale conveying the Beck Assets to XTO. The purchase price was
$84,961,346.00. Id. Following the Beck-XTO deal, Transact inquired as to the 2% transaction fee, and Wellington’s attorney
informed Transact that they would not pay and that Wellington did not consider Transact’s claim for payment of the transaction
fee to be “valid.” Subsequently, litigation ensued between the parties.
-Wellington Res. Group LLC v. Beck Energy Corp., 2013 U.S. Dist. LEXIS 134838, cont’d.
The litigation focused on Beck’s assertion that because Transact was not a duly licensed Ohio real estate broker, the Ohio Revised
Code barred recovery for compensation for transaction. The Court described Beck’s argument as following four steps:
(1) oil and gas leases are included within the meaning of ‘real estate’ as defined by O.R.C. §4735.01(B);
(2) any person that sells, purchases, lists, offers, or negotiates the sale of ‘real estate’ for a commission is a ‘real estate broker’ under §§4735.01(A)
and 4725.01(H);
(3) a ‘real estate broker’ must be licensed in Ohio, pursuant to §4735.02(A); and
(4) no right of action can accrue to, and no compensation can be collected by, real estate brokers who are unlicensed, under §4735.21(A).
In rejecting Beck’s argument, the Court considered even the earliest oil and gas cases in Ohio and concluded that Ohio courts
consistently have treated oil and gas leases as different from an interest in real property. Therefore, because oil and gas leases are not
interests in real property, a person negotiating the sale of same need not be a licensed real estate broker in the State of Ohio.
In further support that of its conclusion that an oil and gas broker need not be a licensed real estate broker, the Court addressed a
topic very familiar with landmen today: the licensure of landmen, noting that the Ohio legislature was currently considering H.B. 493, which
would give the Chief of the Ohio Division of Oil and Gas Resources Management authority to regulate “land professionals,” requiring
registration with the Division.
The Court explained the introduction of legislation to regulate land professionals is additional evidence that land professionals do
not fall within other statutory schemes, including licensure of real estate brokers.
George Mason
Law Firm, PSC
Kentucky
KY Bar Opinion U-31
KY Bar Opinion U-63
See KY Supreme Court Opinion in Countrywide Home Loans, Inc .v. Kentucky Bar
Association, 113 S.W.3d 105 (Ky. 2003). Vacating a KY Bar Opinion declaring the act of
closing a real estate transaction as the practice of law. This opinion considers the term
‘closing’ as simply pointing to signature lines on preprinted, pre-filled forms. It does not
address preparation of legal documents [i.e. leases] by lay persons.
See KY Supreme Court Opinion in Federal Intermediate Credit Bank of Louisville v. KY Bar
Association, 540 S.W.2d 14 (Ky. 1976). Re-affirming that mortgages must be prepared by
licensed attorneys. It seems that this could be easily translated to leasing. Filling in blanks
without review by an attorney of the final product prior to presenting the documents for
signature constitutes the unauthorized practice of law.
George Mason
Law Firm, PSC
UPL NATIONAL ISSUES:
AAPL National is diligently fighting for Landmen to continue doing our jobs as
land professionals on several fronts across the country at this moment in multiple
basins:
-Texas
-New Mexico
-Colorado
-Wyoming
-Ohio
-Maryland
-West Virginia
Could Kentucky be next to consider some sort of Landman registration process?
-Currently only North Carolina requires any kind of registration for Landmen
involved in negotiating leases and ROW or Surface Use Agreements with the
general public.
Argument usually boils down to the industry’s reliance on voluntary certification
and Code of Ethics monitoring and enforcement as practiced by the AAPL vs.
some sort of Mandatory Licensing Program administered by the states or
regulatory agency
SCENARIOS
1) Your new client, Fast Buck Promotions LLC, calls from TX wanting you to provide all land
services including leasing, due diligence and ROW work for a new project they are
undertaking involving an old oil field in an outlier county that is not home to a lot of current
activity. After initial title work and some curative leasing are done, the client calls you back
and asks if you can make your Ownership Reports “look more like this title opinion” he just
happens to have from an attorney friend of his in TX (who charges $650 per hour) for
another project from his past. Also, he asks if you can tone down some of the potential
ownership issues you are raising in those reports so as to not to “frighten away his potential
investors”… What should you do?
George Mason
Law Firm, PSC
SCENARIOS
2.)
An old established client of yours, Smoky Mountain Oil & Gas Inc. (“SMOG”), calls
you up and asks if you can prepare some new updated lease forms and ratification
instruments for him because his old, two-page, Producers 88 forms just won’t cut it with
landowners any more because “they all have cousins up in Ohio who have educated
them now“ in his opinion. He doesn’t want to use the downtown attorney he keeps on
retainer for litigation and regulatory issues and he doesn’t want you to reach out to them
either to keep billable hours down… What should you do?
George Mason
Law Firm, PSC
SCENARIOS
3.)
A Landowner you have already leased and are now negotiating a surface use agreement
with for your client, Big Time Texas Oil Corp., asks you for some legal advice “based on
your past experience” not for himself, but for his neighbors, who wants to lease his 200
acre farm to a competitor, Late to the Party Hydrocarbons. You know that your client
wants to include at least a portion of the neighbors farm in the unit that will ultimately be
formed from the well that will be drilled upon your landowner’s lease and will consider
force pooling them if a lease cannot be obtained… What should you do?
George Mason
Law Firm, PSC
SCENARIOS
4.)
That old reliable client, Smoky Mountain Oil & Gas Inc. (“SMOG”), calls back and
asks your “interpretation” of the intent of the parties to an old, vague conveyance
instrument from 1919 that was noted as an exception and curative requirement in the
chain of title for a 30 Year Old Title Opinion that he has dusted off. He plans on drilling
a new $900,000 horizontal well under this old lease which is being held by vertical
production and he makes it clear that he thinks the exception was malarkey in the first
place and he wants to proceed without curative nor a supplemental title opinion… What
should you do?
George Mason
Law Firm, PSC
RECOMMENDATIONS:
-DISCLAIMERS:
This Due Diligence Summary Report is offered for your review and opinion subject to any and all errors or omissions found in the records of the appropriate
offices where the records reside, any overlapping of legal descriptions that an accurate survey might reveal, and subject to any errors or erroneous information provided by other
parties which may or may not be found in recorded instruments of record.
Adkins & Associates Land Services LLC has taken all due precautions to ensure that it has reviewed all of the properly indexed records lodged in the
Magoffin County Kentucky Clerk’s Office that pertain to the tract that is subject to this limited title report, subject always to any and all errors or omissions that may be in the
indices and record books of said County offices.
Further, Adkins & Associates Land Services, LLC makes no guarantees nor warranty as to certification of title to the tracts described in this report. We advise
that a competent mineral title attorney be engaged to review and critique this report and all source documents referenced herein. Adkins & Associates Land Services, LLC
assumes no liability resulting from the use of this information.
This Due Diligence Limited Title and Abstract Summary Report is written and offered solely for your information only and may not be interpreted as or
relied upon as any form of legal opinion nor as a binding certificate of title as the undersigned is not authorized nor engaged in the general practice of law and does not hold
himself out as a practicing attorney nor as a practicing member of the bar of any jurisdiction.
In the investigation of the Land Records of Magoffin County, Kentucky and the preparation of this Report that details the results of that investigation, the
undersigned title examiner (“Examiner”) exercised diligence and care, but it is understood by the receipt of this report by the Client, Client assumes the full liability resulting from
any error or omission herein.
-ERR ON THE SIDE OF CAUTION
-SPEAK WITH YOUR COMPANY’S IN HOUSE COUNSEL OR CLIENT’S ATTORNEY
-STAY PLUGGED IN WITH AAPL NATIONAL AND GET INVOLVED LOCALLY
George Mason
Law Firm, PSC
GOT ROGERSVILLE SHALE?
Question: Is it the unauthorized practice of
painting if you paint a white mustache on an
attorney?
George Mason
Law Firm, PSC
GOT ROGERSVILLE SHALE?
This is what happens when your 19 year old
son gets a hold of your PowerPoint
presentation!
George Mason
Law Firm, PSC
BE CAREFUL OUT THERE!
George Mason
Law Firm, PSC