Bankruptcy Means Test

Written by Craig D. Robins, Esq.

Last month, a panel of well-known, local bankruptcy practitioners and trustees convened at a Suffolk County Bar Association seminar to discuss consumer bankruptcy practice under the new laws, which just marked their second anniversary. During the past two years, those attorneys who continue to practice bankruptcy (many general practitioners have dropped out due to complexities in the law) have become gradually more familiar with the new statutes.

However, there remain a number of significant issues concerning how to best apply the new laws in practice. There are also a number of court decisions now which interpret the new laws, although there are relatively few coming from this jurisdiction. The panel presented an assortment of information and practical tips which I will discuss in this column and next month’s column. In this first part I will primarily highlight Chapter 13 issues.

Chapter 13 Cram-downs. Chapter 13 trustee, Michael Macco, posed the question, “How can we all make money in the Chapter 13 world?” His answer was for attorneys to cram down second and third mortgages by bringing adversary proceedings under Code section 506. This is the provision that permits a debtor to remove a lien from real estate if it is not secured. As real estate values have been declining over the past year, practitioners should take a look at the value of their client’s property to ascertain if it is feasible to strip down a second or third mortgage.

Richard Stern, a Chapter 7 trustee, pointed out that in order to do this, the second or third mortgage must be totally unsecured. Mr. Macco believed a fee of $2,500 to $5,000, in addition to the Chapter 13 legal fee, would be a reasonable fee for this. He also noted that most attorneys do not bring such applications even when the situation calls for it. However, none of the panelists addressed how typical debtors would be able to pay for such work. Sal LaMonica, former law clerk to Judge Dorothy Eisenberg, and now a bankruptcy practitioner, noted that he has seen several actions successfully brought to void a mortgage on the ground that it violated the Truth in Lending Act. He suggested that attorneys be on the look-out for any violation of federal laws at the time of closing.

Dealing with Tax Refunds on the Means Test. Mr. Macco posed the issue: “Do you count the tax refund as part of the debtor’s monthly income?” Here the panel had different opinions. The U.S. Trustee website says that you do not have to count the tax refund unless it was received during the prior six-month means test period. However, Mr. Macco pointed out that the means test requires the debtor to indicate “taxes actually incurred.” He believes that debtors should calculate their actual tax obligation not based on taxes withdrawn from pay stubs, but instead from actual taxes paid, taking into account subsequent tax refunds. He also pointed out that Chapter 13 trustee Marianne DeRosa lets debtors do this differently by amortizing refunds over a 12-month period.

Meanwhile, Mr. Stern disagreed with Mr. Macco’s approach and commented on a discussion he had with the regional U.S. Trustee who stated debtors should absolutely NOT include tax refunds received during the prior six months. Mr. Stern noted that from a practice standpoint, if you have a case with Macco, you would probably want to use his approach, but if you have a case with another trustee, you could use the other approach. Mr. Macco also stated that he had been negotiating with the IRS to persuade them to mail the refund directly to the Chapter 13 trustee.

The Three-Prong Test in Chapter 13. Mr. Macco discussed the three-prong test that determines how much a debtor must pay in a Chapter 13 plan: it is the greater of a) the hypothetical Chapter 7 liquidation amount; b) the amount set forth at the end of the means test; or; c) the amount of actual disposable income. Mr. Macco remarked that the courts are split on this approach and that there is no authoritative case law in this jurisdiction to support this position. He indicated that until there is some authority towards a different method, this is the approach he intends to take.

Car Calculations. The biggest mistake Mr. Macco sees counsel make on the means test concerns the calculation of secured automobile debt. He reminded counsel that in determining the deduction for auto loans, counsel should take the balance due on a car loan and divide by 60. He also pointed out a debtor cannot take an automobile deduction for a car for the line item “transportation ownership / lease expense” of the means test unless there is a car loan or lease for that vehicle. However, Mr. Macco pointed out that the practice in this district is that a debtor can deduct an additional $200 per car on the means test if the vehicle does not have a loan or lease, and the vehicle has over 75,000 miles. He said that this position is based on case law that has been adopted by the trustees in this jurisdiction. This additional $200 per vehicle would be added to the amount on the means test line item for basic “transportation / vehicle operation expense.”

Life Insurance Deductions. Mr. Macco believes that debtors can only deduct term life insurance on the means test as opposed to other types of life insurance.

Telecommunication Expense. This is only deductible, according to Mr. Macco, to the extent that it is necessary for the welfare of the debtor or his dependents. Mr. Macco believes that a family cell phone plan for $59 that enables family members to contact each other for emergencies is reasonable. However, this also led to a heated panel discussion. It appears that the issue is: is it really necessary? It was pointed out that Chapter 13 trustee Marianne DeRosa does not permit any telecommunication expense deduction absent extenuating circumstances. As a practical tip, distinguish between pleasure use and emergency use.

Commitment Period. If the debtor’s income is below the state median income, the debtor can file a three-year plan as opposed to a five-year plan. See Bankruptcy Code section 1325.

Chapter 13 Payoffs. How much does a debtor have to pay the Chapter 13 trustee if the debtor wants to pay off the plan early? According to Mr. Macco, if you confirm a plan, it is a contract which sets forth the amount the debtor has to pay, and this amount is the amount of the pay-off, regardless of whether the debtor’s property has increased in value. However, there would be a different result in cases pending before Judge Eisenberg as she believes that creditors should benefit from increased value in real estate, which means that a debtor could conceivably pay more if the debtor wanted to satisfy the plan early.

New Means Test. Mr. Macco thought it was almost definite that the means test form was going to be revised effective January 2008. He suggested that the revised form would provide for a far greater itemization of “marital deductions” for non-filing spouses. This would enable a debtor to deduct the non-filing spouse’s student loans, credit cards, child support or maintenance, and car payments.

Health Care for persons 65 years of age and older. It also appears that the new means test may permit senior citizens to deduct an additional sum, presumably to cover greater medical expenses.

Additional Transportation Expense Deduction. Another possible new category would apply to debtors who both own cars and take public transportation. Such individuals would be permitted to an additional means test deduction based on new proposed IRS transportation standards, not yet in effect. This will help those debtors who commute to the City.

Stay Tuned Next Month. In Part II of this article, I will address issues involving matrimonial settlements, reaffirmation agreements, converted cases, the new U.S. Trustee initiative against attorneys, and other matters.

About the Author.  Long Island Bankruptcy Attorney Craig D. Robins, Esq., is a regular columnist for the Suffolk Lawyer, the official publication of the Suffolk County Bar Association in New York. This article appear in the December 2007 of the Suffolk Lawyer. Mr. Robins is a bankruptcy lawyer who has represented thousands of consumer and business clients during the past twenty years. He has offices in Medford, Commack, Woodbury and Valley Stream. (516) 496-0800. For information about filing bankruptcy on Long Island, please visit his Bankruptcy web site: http://www.BankruptcyCanHelp.com.

Written by Craig D. Robins, Esq.

Almost two years into the new bankruptcy laws, those who regularly practice consumer bankruptcy are finally becoming comfortable in analyzing the facts necessary to prepare the means test imposed by the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA).

However, we are now seeing more and more means test issues requiring interpretation and court review. One interesting issue involves determining the size of the household for the purpose of the means test. This has become complicated considering that there are so many more living arrangements than the traditional family. Non-traditional living arrangements can include extended families, domestic partnerships, roommates, etc. When these situations arise, counsel is challenged with determining who to count.

Basic Purpose of the Means Test. For the uninitiated, the basic purpose of the means test is to determine whether a debtor is eligible to file a Chapter 7 petition based on a rather comprehensive calculation of the debtor’s income and expenses. If the means test indicates that the debtor should be in Chapter 13, the test also provides the minimum amount that the debtor should pay on a monthly basis in a Chapter 13 plan. In a nutshell, the means test determines the debtor’s current monthly income by taking the debtor’s household’s gross income and subtracting certain specified exclusions and deductions. Generally speaking, no matter what chapter the debtor files, the lower the final figure on the means test, the better.

The Means Test is Based on “Household” Income and “Household” Size. Household income and the number of individuals in the household are very important variables in the means test. Yet, “household” is not a term defined in the Bankruptcy Code.

The Debtor Usually Benefits from Having a Large Household. Generally, the more individuals who live in the household, the easier it is for the debtor to qualify for Chapter 7. This is because a debtor qualifies for Chapter 7 if his household income is below the state median for income of a family of the same size. Thus, the more family (or household) members, then the greater the state median income for a family of that size, and the greater the likelihood that the debtor will qualify.

Sometimes a Large Household Can Work Against the Debtor. If the debtor is required to include a certain individual as a household member who had a relatively large income, that could have the effect of skewing the means test result and preventing the debtor from being automatically eligible for Chapter 7.

There Is Little Caselaw Analyzing Who is a Member of the Debtor’s Household. It appears that this issue has not been litigated extensively and there do not seem to be any decisions from this jurisdiction as of yet. Nevertheless some courts have addressed the issue. Some of the reported decisions make a distinction between the definitions of “household” and “family,” and which concept best applies to the means test despite the fact that the statute specifies “household” size.

When is Household Size Determined? One very recent Chapter 7 case from Minnesota, In re Ellringer, (official cite not yet available), held that the determination is to be made as of the petition date. However, a Kansas court, in the Chapter 13 case of In re Anderson, 367 B.R. 727, held the appropriate date to be the date of confirmation. It is likely that this analysis would hold up in our jurisdiction.

What Exactly is the Debtor’s Household? The Ellringer court looked at the definition used by the U.S. Census bureau because certain variables used in the means test are obtained from Census data. The court felt that the Census Bureau provided the most appropriate definition of “household” for use in the means test because this ensured that a household in the means test would have the same number of members as households used in the calculation of median family income for the purpose of the Census. The court also pointed out that Congress could have specified “family” size, rather than “household” size, but did not.

Census Bureau Definition of “Household.” The Census Bureau defined “household” as follows: A household consists of all the people who occupy a housing unit. A house, an apartment or other group of rooms, or a single room, is regarded as a housing unit when it is occupied or intended for occupancy as separate living quarters; that is, when the occupants do not live and eat with any other persons in the structure and there is direct access from the outside or through a common hall.

The definition continues: A household includes the related family members and all the unrelated people, if any, such as lodgers, foster children, wards, or employees who share the housing unit. A person living alone in a housing unit, or a group of unrelated people sharing a housing unit such as partners or roomers, is also counted as a household. The count of household excludes group quarters. There are two major categories of households, “family” and “nonfamily.”

However, as you can see, the above definition is overly broad. Some Courts have rejected this approach and rightfully so. How can you include the income from a boarder as part of a family budget? The court in In Re Jewel, 365 B.R. 796, rejected the “heads on beds” approach as overly broad and instead adopted a definition limited to those household members financially dependent of the debtor.
Accordingly, the best guidance to consider is whether the household members constitute a single economic unit. If they do, you should probably include them.

The Roommate Dilemma. When do you include non-family members such a roommates in the debtor’s household? This is one of the most common issues I see. Since a roommate is only involved in the debtor’s economic unit to the extent of contributing towards expenses, my suggestion is to not include the roommate as a member of the household, but to include the roommate’s contribution to the debtor’s household budget. On the other hand, if the roommate and the debtor are cohabiting as a family unit, that changes the picture.

Can You Overcome Unrealistic Means Test Results Caused by Income From Too Many Household Members? Remember that even if the debtor “fails” the means test by giving rise to a presumption of abuse, it is still up to the U.S. Trustee or interested party to object. Even if that happens, the debtor is still entitled to have a hearing before a judge who will decide the issue.

Conclusion. Use good faith, reasonableness and common sense in determining whether household members constitute a singe economic unit with the debtor, and be prepared to support your position should the U.S. Trustee inquire.

About the Author.  Long Island Bankruptcy Attorney Craig D. Robins, Esq., is a regular columnist for the Suffolk Lawyer, the official publication of the Suffolk County Bar Association in New York. This article appear in the October 2007 of the Suffolk Lawyer. Mr. Robins is a bankruptcy lawyer who has represented thousands of consumer and business clients during the past twenty years. He has offices in Medford, Commack, Woodbury and Valley Stream. (516) 496-0800. For information about filing bankruptcy on Long Island, please visit his Bankruptcy web site: http://www.BankruptcyCanHelp.com.

Written by Craig D. Robins, Esq.

Members of the bankruptcy bar had a rare opportunity to hear comments from six of the seven bankruptcy judges sitting in the Eastern District of New York at a symposium on October 23, 2006. The occasion was to discuss views from the bench on the one year anniversary of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA) . The panel also contained members of the United States Trustee’s office, a Chapter 7 trustee, and two bankruptcy practitioners. The symposium was held at the Nassau County Bar Association.

As everyone knows by now, the new laws were most controversial and not welcomed by the bankruptcy bar and most judges. Practitioners and judges alike previously described them as everything from tricky and cumbersome to inane and unjust. The one year anniversary of the new laws (they became effective October 17, 2005) provided an ideal time for the judges to assess their impact.

The judges who appeared were Chief Judge Melanie Cyganowski, Judge Stan Bernstein, Judge Carla Craig, Judge Dorothy Eisenberg, Judge Jerome Feller, and Judge Elizabeth Stong. Judge Dennis Milton had planned to appear but could not make it. The following topics were discussed:

Volume Way Down.

Andrew Thaler, a panelist who is a Chapter 7 trustee, discussed some recent filing statistics. The number of cases currently being filed is similar to the number we saw over two decades ago in 1985. Right now the amount of new cases being filed is about one-third of the number we would have expected had there been no new laws. In the Eastern District, that translates to about 31 cases a day instead of 110. Chief Judge Cyganowski pointed out that the dearth of cases is resulting in a staffing issue as there is not enough work to keep all of the employees in the clerk’s office busy and there is pressure to terminate some positions.

Pro Se Filings.

Chief Judge Cyganowski stated that 25 to 30% of all filings were by pro se debtors, a relatively high percentage. She introduced Mary Fox, a new law clerk whose job will strictly be to assist pro se filers. The judge pointed out that an extremely large number of pro se cases are dismissed because the debtors do not know how to follow the new BAPCPA rules.

Effect on Panel Trustees.

Andrew Thaler discussed some of the ways BAPCPA has impacted his work as a Chapter 7 trustee. He indicated that he must now spend a good amount of time reviewing tax returns and chasing debtors and attorneys who do not provide them. [BAPCPA requires that you provide the trustee with a copy of the debtor’s last filed tax return at least seven days before the meeting of creditors.] He also stated that he thoroughly reviews the budget schedules (“I” and “J”) and refers potential cases of abuse to the United States Trustee. He is also kept busy ascertaining whether there are domestic support obligations as trustees must now notify the creditor-spouse and the New York State Support Unit. Finally, he mentioned that even though his meeting of creditors calendar is significantly smaller than before, it takes just as long because of all of the additional issues to cover.

Automatic Dismissal.

Judge Cyganowski began what led to a heated discussion about the controversial practice of automatically dismissing a case on the 46th day after filing if the debtor does not adhere to certain new obligations imposed by Code section 521(i)(1). In particular, pursuant to that section, a debtor must file the means test and copies of pay stubs with the Court within 45 days of the date the petition is filed. If the debtor neglects to do so, then the clerk’s office administratively handles this issue without referring the matter to a judge. The clerk has been instructed to automatically dismiss the case without a hearing and to serve a notice of dismissal on all interested parties. Some expressed concern as to whether this provided sufficient notice to the debtor and the trustee.

Judicial Commentary on Working With the New Laws.

Judge Feller said that Congress was dissatisfied with the way the bankruptcy laws had previously been administered. He felt that too many attorneys and judges were complaining about perceived problems with the new laws. “If we do not do the darndest to make it work, then it will not work” he said. “We’ve made an attempt to make this work. There are ways that we can make these provisions work. We can’t sit back and complain.” However, I was not convinced that all of the judicial panelists shared the same sentiment.

New Local Rules.

Chief Judge Cyganowski mentioned that it became necessary to revise the existing local rules to work in conjunction with the new BAPCPA provisions. She said that a draft copy of the proposed new local rules will be circulated in the near future for comment.

New Decision Interpreting BAPCPA Provision.

Judge Bernstein, who, a year ago, said that he had no intention of being one of the first judges to issue a decision interpreting the new laws, volunteered that he was about to release a decision which he intimated would be rather controversial. He said that the issue concerned Bankruptcy Code section 109(h) and the impact of the BAPCPA credit counseling requirement on the debtor’s eligibility to file.

Issue of Sanctions for Attorney’s Slip-up.

One of the major concerns when BAPCPA went into effect last year was the number of provisions imposing burdens on bankruptcy counsel and liability for negligent non-compliance. Judge Bernstein discussed one particular case in which counsel filed a petition despite the fact that the debtor’s credit counseling certificate was obsolete. (The counseling session must be obtained within six months of filing. Here, the attorney filed the case seven months after the session.) Judge Bernstein commented that he easily could have sanctioned, humiliated and embarrassed the attorney, but instead sought to “make no noise” about it and to give the debtor’s attorney “a pass.” He implied that his rationale for doing so was because the “sage” attorney ordinarily demonstrated responsibility with his cases.

Judge Bernstein, who also spends a significant amount of time teaching law students as an adjunct faculty professor at Hofstra and Touro Law Schools, is apparently quite familiar with the concept of permitting a pass in class under appropriate circumstances. Incidentally, while the other judges appeared most judicial in attire, Judge Bernstein looked most professorial and relaxed in a sweater and collared shirt.

Audits.

In my September 2006 column, I discussed the new U.S. Trustee program of random and targeted audits of consumer debtors. Assistant United States Trustee Terry Cavanagh and United States Trustee Attorney, Linda Rifkin, provided more information. The Office of the United States Trustee will have no relationship with the auditors. The audits will be completed totally independently so that there is no influence or bias. Audits will not involve face-to-face interaction as many had feared. Instead, the auditors will request documents and review them to look for material mis-statements.

The main office of the United States Trustee in Washington hired two auditors (accounting firms) for this district and they are both located upstate, well out of this district, to minimize the possibilities of conflicts of interest. The auditor will file a final report with the Court when the audit is completed.

A heated discussion on the audit reports themselves began with Judge Bernstein questioning their usefulness and considering their impact on the court system by asking, “What are we going to do with them?”

Linda Rifkin replied that depending on what is found (i.e. material misstatements) the United States Trustee will take action. It will be up to the United States Trustee’s office to decide whether to take a position, although technically, creditors will have standing also. At the end of that discussion, Judge Bernstein commented, “I’m just trying to understand what additional burdens I have to look forward to,” which brought a round of chuckles from the room.

Judge Bernstein also questioned whether debtors would have difficulty responding to the audits if their attorneys previously restricted their involvement with limited engagement retainer letters, a practice which is becoming more and more prevalent.

Impact of BAPCPA on the Judiciary.

Judge Bernstein stated that the biggest impact of the new laws on the judiciary is “not very much impact at all.” This was in harsh contrast to his statements a year ago in which he opined that the new laws spelled gloom and doom. He also mentioned that there are many traps for inexperienced counsel and many trip wires.

Judge Eisenberg commented that she thought dealing with credit counseling issues was an unnecessary burden. Clearly frustrated, she said, “This is all a waste of judicial time and lawyer time.”

Chief Judge Cyganowski commented that while some bankruptcy courts are more activist to try to fix perceived problems with the new laws, some are more constrained. She said, “Our Court is more constrained. We’re waiting to see. . . In the meantime, we are doing our best to apply construction of the new laws.”

 About the Author.  Long Island Bankruptcy Attorney Craig D. Robins, Esq., is a regular columnist for the Suffolk Lawyer, the official publication of the Suffolk County Bar Association in New York. This article appeared in the November 2006 issue of the Suffolk Lawyer. Mr. Robins is a bankruptcy lawyer who has represented thousands of consumer and business clients during the past twenty years. He has offices in Medford, Commack, Woodbury and Valley Stream. (516) 496-0800. For information about filing bankruptcy on Long Island, please visit his Bankruptcy web site: http://www.BankruptcyCanHelp.com.

Written by Craig D. Robins, Esq.

About the only thing a bankruptcy law columnist can write about these days is the passage of the new bankruptcy reform laws and how debtors and their attorneys should handle the situation. By now, everyone should know that on April 20, 2005, President Bush signed into law the “Bankruptcy Abuse Prevention and Consumer Protection Act of 2005,” a very harsh pro-creditor statute designed to make it much harder for consumers to eliminate their debts in bankruptcy. This is the most radical and sweeping change to the Bankruptcy Code in several decades.

For years, the bankruptcy laws favored debtors by enabling them to easily discharge debts in a Chapter 7 proceeding. Now the pendulum has swung the other way in favor of creditors. The new laws will prevent many debtors from filing for Chapter 7 and will instead require that they make payments through a much more complex five-year Chapter 13 payment plan. As one columnist said, the last eight years were a joy ride for consumers, but now it’s over.

For better or worse, you will soon need to decide if you are still in the game. For years, critics of the bankruptcy reform laws have complained that the complexity of the new laws would drive many general practitioners away from being able to handle bankruptcy matters. They argued that it would take attorneys hours of extra time per case to handle the requirements of the new laws. They argued that complying with the new laws will require a much more thorough familiarization with the Bankruptcy Code and its new revisions and procedures. They argued that potential liability for sanctions, costs and fees for filing the wrong chapter would deter many attorneys from wanting to continue bankruptcy representation. Unfortunately, all of this is very true.

While bankruptcy law is a highly specialized field, and always has been, the recent popularity of bankruptcy over the past decade has prompted many general practitioners to try their hand at filing bankruptcy cases. Many of these general practitioners were previously able to handle the simpler consumer matters. I, personally, have seen many general practitioners make mistakes, but up until now, at worst they would generally be yelled at by a trustee, embarrassed in front of their clients, compelled to repeatedly correct and revise schedules until they got them right, or face the wrath of a client who found that he had to turn over his non-exempt assets to the trustee.

However, the reform act now explicitly places actual liability on the debtor’s attorney for costs, sanctions, and legal fees for basically making a mistake. In essence, the new laws impose a very strict duty of due diligence on the part of the debtor’s attorney to ensure that a consumer debtor is qualified to file a Chapter 7 case. If the debtor’s attorney is wrong, then a host of interested parties including creditors, the Chapter 7 trustee, the United States Trustee (or even the Court, sua sponte), can bring a proceeding against the debtor to challenge the propriety of filing under Chapter 7, and if successful, they will be entitled to recoup costs and legal fees against the debtor’s counsel. The Court is empowered to impose sanctions and direct counsel to disgorge their legal fee as well. An unfavorable ruling against the attorney can also open the door for a malpractice suit by the client. These concerns alone are enough to scare away many practitioners not willing to chance such problems and face such potential headaches.

But there are also a host of other obligations that you will need to address. The Court’s relatively new Electronic Case Filing Requirement, which requires all attorneys to file electronically, combined with the new schedules and forms under the new law, will effectively mandate that any attorney who files a case under the new law do so with the assistance of a specialized computer bankruptcy filing program. For those attorneys who already have such software, you will most certainly need to obtain the most updated version that complies with the new laws. This software will probably not even be available for a number of months.

Then, in order to continue to effectively represent consumer bankruptcy clients under the new laws, you will absolutely need to become extremely familiar with the new laws and procedures. That means thoroughly reading the new laws (the draft versions available on line are about 500 pages long), attending a number of consumer bankruptcy continuing legal education seminars that will undoubtedly appear after Labor Day, and developing special relationships with credit counseling agencies and entities that offer financial management courses.

A significant provision in the new law is that a debtor must go through credit counseling at least 6 months before filing for bankruptcy. In addition, a debtor must also complete a personal financial management course within 18 months after filing in order to receive a discharge. These not-for-profit agencies must be certified and accredited by the United States Trustee. You will need to learn about the what agencies are in your area and how to refer your clients to them. To make matters more complicated, none of the agencies that the new law requires are yet recognized by the Court or even exist.

And there’s more. A slightly bizarre provision under the new law classifies all consumer debtor attorneys as “debt relief agencies.” The law requires any attorney who advertises bankruptcy to state in the advertisement that they are a “debt relief agency” and that the agency “helps people file for relief under the Bankruptcy Code.”

When must you decide if you will continue your consumer bankruptcy practice? Although some provisions of the new law became effective immediately, the bulk of the provisions that would affect your practice contain an effective date of 180 days. Thus, the new laws will not become effective until about October 17, 2005. If you have any doubts about filing new cases, you should consider playing it safe and avoiding potential headaches by referring your clients to a highly experienced bankruptcy attorney. In the meantime, the clock is ticking.

 About the author.  Long Island Bankruptcy Attorney Craig D. Robins, Esq., is a regular columnist for the Suffolk Lawyer, the official publication of the Suffolk County Bar Association in New York. This article appeared in the May 2005 issue of the Suffolk Lawyer. Mr. Robins is a bankruptcy lawyer who has represented thousands of consumer and business clients during the past twenty years. He has offices in Medford, Commack, Woodbury and Valley Stream. (516) 496-0800. For information about filing bankruptcy on Long Island, please visit his Bankruptcy web site: http://www.BankruptcyCanHelp.com.