Qui Tam Complaint — No. 1:23-cv-04875 (Dkt. 7, N.D. Ill.)

Summary

Relator Aidan Forsyth filed this qui tam complaint under seal in the Northern District of Illinois on 07/28/23 against KSO Metalfab Inc., a family-owned metal goods maker in Streamwood, Illinois, and its owner Dora Kuzelka. It alleges that the company's two PPP loan applications in 2021 falsely certified that no owner with an equity interest of more than 20 percent was subject to criminal charges. According to the complaint, Dora Kuzelka and family members had been charged in October 2019 with harboring illegal aliens and hiring workers ineligible to work in the United States, and Dora Kuzelka entered into a deferred prosecution agreement in or about May 2022. Lenders extended PPP loans totaling nearly $850,000.00, which were forgiven in or about 2022. The relator seeks treble damages and civil penalties under the False Claims Act.

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Case: 1:23-cv-04875 Document #: 7 Filed: 07/28/23 Page 1 of 18 PageID #:69
REGEIVEDQ
FIL ED (c.
8/2023
7/2 JUL 26'/023 t
. BRUTO N
THOMA.SDG
IS T R IC T COURT UNITED STATES DISTRTC_ ^^r,nf THOMAS G. BRUTON
CLERK, U.S
NORTHERN DTSTRTCT Ol 1,23_c,ra*r?=*K, U.S. DISTRICT COURT
pailmeyer
i lgdgeRebecca
Magisffie Judge GabrielA. Fuentes
UNITED STATES OF AMERICA, Case N
utrect assignmefi
ex rel. [UNDER SEAL],
QUI TAM COMPLAINT
Plaintift
v. FILED UNDER SEAL
UNDER 31 U.S.C. S 3730(bX2)
[UNDER SEAL],
JURY TRIAL DEMANDED
Defendants.

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UNITED STATES DISTRICT COUR1
NORTHERN DISTRICT OF ILLINOIS

UNITED STATES OF AMERICA,
CX rCI. AIDAN FORSYTH. Case No.

Plaintiff-Relator. QUI TAM COMPLAINT

v. FILED UNDER SEAL
PURSUANT TO
KSO METALFAB INC. and 31 u.s.c. s 3730(bx2)
DORA KUZELKA,
JURY TRIAL DEMANDED
l)efendants.

On behalf of the United States of America (the "United States" or the "Government"),

Plaintiff and Relator Aidan Forsyth ("Relator") files this qui tam action against Defendants KSO

Metalfab Inc. ("KSOM") and Dora Kuzelka ("Dora") (together, "Defendants") and alleges as

follows:

INTRODUCTION
l. This is an action to recover treble damages, civil penalties and all other remedies

on behalf of the United States of America in connection with the Defendants' materially false

and fraudulent applications to the Government for loans under the Paycheck Protection Program

("PPP"), in violation of the False Claims Act, 3l U.S.C. $$ 3729 et seq. (the "FCA").

2. Pursuant to the FCA, Relator seeks to recover, on behalf of the United States of

America, damages and civil penalties arising from false or fraudulent claims for payment that

Defendants submitted or caused to be submitted to the Federal Government-funded and/or

subsidized PPP loan program.

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SUMMARY OF ALLEGATIONS

3. Defendant Dora Kuzelka at all relevant times was an owner and principal of

Defendant KSOM.

4. Upon information and beliet Dora at all relevant times had a20%o or greater

equity interest in KSOM.

5. KSOM, a family-owned business based in Streamwood, Illinois, manufactures

metalgoods.

6. In or about October 2019,Dora (along with Keith, Kenneth and Kari Kuzelka,

family members who also had KSOM ownership interests and management responsibilitiesl)

were charged by criminal complaint with one felony count of harboring illegal aliens and one

felony count of engaging in a pattern or practice of hiring illegal aliens who are ineligible to

work in the United States. In or about December 2019, the Kuzelkas and one additional

codefendant were indicted on twelve felony counts, including conspiracy to harbor illegal aliens,

engaging in a pattern and practice of hiring illegal aliens, and ten felony counts corresponding to

specific illegal alien employees.

7 . The criminal case against the Kuzelkas did not fully resolve until2022. Keith

Kuzelka pled guilty in or about May 2021and was sentenced in or about August 2021;Dora

Kuzelka entered into a deferred prosecution agreement in or about May 2022;Kenneth and Kari

Kuzelka pled guilty in or about May 2022 and were sentenced in or about December 2022.

8. In or about March 2021, KSOM submitted a Small Business Administration

("SBA") applications for a PPP loan. In or about April2021, KSOM applied for a second PPP

loan. These loans were issued.

I Keith worked for KSO from in or about 2009 until in or about September 2018, when Dora fired hinr for alleged
misconduct; however, he maintained a less than 20%o ownership interest in the company.
1

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9. In or about 2022,KSOM sought and obtained forgiveness of the PPP loans.

10. Upon information and beliel Dora prepared or caused to be prepared the loan
applications as KSOM's authorized representative.

I l. In the applications, Defendants falsely stated and certified that no owner of

KSOM with an equity interest of more than 20 percent was currently subject to criminalcharges.

They also expressly acknowledged that this was a material question, and that submitting a

materially false application would violate federal law.

12. In reliance on these false statements and certifications, one or more lenders
extended PPP loans to KSOM totaling nearly $850,000.00.

13. In further reliance on Defendants'false statements and certifications. the lender
forgave the PPP loans, the reimbursement for which cost the United States nearly $850,000.00.

14. Relator files this qui lctm lawsuit to enable the Government to recover from
Defendants the SBA-guaranteed and forgiven monies that were provided to Defendants as the

result of their wrongdoing, bank fees and costs paid by the Government, as well as to recover

treble damages and/or penalties.

JURISDICTION. VENUE. AND SPECIAL REOUIREMENTS

15. This Court possesses subject matter jurisdiction over this action pursuant to 28
U.S.C. $ 1331 because it arises underthe laws of the United States, under3l U.S.C. $3729 of

the False Claims Act, and under 28 U.S.C. $ I 345, which provides the United States District

Courts with originaljurisdiction over all civil actions commenced by the United States of

America.

16. In addition, the FCA specifically confers jurisdiction upon the United States
District Courts under 3l U.S.C. $ 3732. This Court has personaljurisdiction over the

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Defendants pursuant to 3l U.S.C. $ 3732(a) because the Defendants transact business in this

District, and because the PPP Loan application was prepared in, executed in, and/or submitted to

the SBA from this District.

17. Venue is proper in this District under 3l U.S.C. $ 3732(a) because certain of the
acts complained of herein occurred in this District.

18. In accordance with 3l U.S.C. $ 3730(bX2), this Complaint has filed been filed in
camera and willremain under seal for a period of at least 60 days and shall not be served on the

Defendants untilthe Court so orders.

I 9. Pursuant to 3 I U.S.C. $ 3730(bX2), the Relator must provide the Government

with a copy of the Complaint and a written disclosure of substantially all material evidence and

material information in his possession contemporaneous with the filing of the Complaint.

Relator has complied with this provision by serving copies of the Complaint and such disclosure

upon Morris Pasqual, Acting United States Attorney for the Northern District of Texas, and upon

the Honorable Merrick B. Garland, Attorney General of the United States.

20. Relator is not aware that the allegations in this Complaint have been publicly
disclosed. Further, to the extent Relator is aware of any public disclosures, this Complaint is not

based on such public disclosures. In any event, this Court has jurisdiction under 3l U.S.C. $

373O(e)(a) because the Relator is an "original source" since he has voluntarily provided his

information to Government before filing this Complaint, and has knowledge which is both direct

and independent of, and materially adds to, any public disclosures to the extent they may exist.

PARTIES

21. Plaintiff-Relator Aidan Forsyth resides at 55 West 8th Street, New York, NY
1001 I .

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22. Defendant KSO Metalfab Inc. is a privately-held company incorporated in the

State of Illinois on or about March 19,1973. Its principal place of business is located at250

Roma Jean Parkway, Streamwood, Illinois 60107. KSOM manufactures metal goods.

23. Defendant Dora Kuzelka is the President and owner of KSOM, and resides at

1009 Pinehurst Court, Elgin, Illinois 60124.

GOVERNING LAWS. REGULATIONS. AND CODES OF CONDUCT
The False Claims Act

24. Originally enacted in 1863, the FCA was substantially amended in 1986 by the

False Claims Amendments Act. The 1986 amendments enhanced the Government's ability to

recover losses sustained as a result of fraud against the United States. Further clarifying

amendments were adopted in May 2009 and March 2010.

25. The FCA imposes liability upon any person who "knowingly presents, or causes

to be presented [to the Governrnent] a false or fiaudulent claim for payment or approval;" or

"knowingly makes, uses or causes to be made or used, a false record or statement material to a

false or fraudulent claim;" or "knowingly makes, uses, or causes to be made or used, a false

record or statement material to an obligation to pay or transmit money or property to the

Government, or knowingly conceals or knowingly and improperly avoids or decreases an

obligation to pay or transmit money or property to the Government." 3 I U.S.C. $ 3729(a)( l)(A),

(B), (G). Any person found to have violated these provisions or conspired to have violated these

provisions is liable for a civil penalty of at least $12,357.00 and up to $25,076.00 for each such

false or fraudulent claim, plus three times the amount of the damages sustained by the

Government. 3l U.S.C. $ 3729(a), 20 CFR Part 356 and 28 CFR Part 85 (see 87 FR 27513,May

9,2022).

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26. The FCA defines the terms "knowing" and "knowingly" to mean that a person (l)

"has actual knowledge of the information;" (2) "acts in deliberate ignorance of the truth or falsity

of the information";or acts "in reckless disregard of the truth or falsity of the information." 3l

U.S.C. $ 3729(bXl)(A). The statute provides that "no proof of specific intent to defraud" is

required. 31 U.S.C. $ 3729(bXlXB).

27. The FCA also broadly defines a "claim" as one that includes "any request or

demand, whether under a contract or otherwise, for money or property and whether or not the

United States has title to the money or property, that - (i) is presented to an officer, employee, or

agent of the United States;or (ii) is made to a contractor, grantee, or other recipient, if the money

or property is to be spent or used on the Government's behalf or to advance a Government

program or interest, and if the United States Government - (i) provides or has provided any

portion of the money or property requested or demanded; or (ii) will reimburse such contractor,

grantee, or other recipient for any portion of the money or property which is requested or

demanded." 3l U.S.C. $ 3729(bX2XA).

28. The FCA empowers private persons having information regarding a false or

fraudulent claim against the Government to bring an action on behalf of the Government and to

share in any recovery. The complaint must be filed under seal without service on any Defendant.

The complaint remains under seal while the Government conducts an investigation of the

allegations in the complaint and determines whether to intervene in the action. 3l U.S.C. $

3730(b).

29. In this action, and under well-established precedent, the false and fraudulent

nature of Defendants' conduct is informed or measured by their violation of, or failure to comply

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with, certain statutes and regulations material to the submission of applications for government-

subsidized and/or issued small business loans.

The CARES Act Authorizes Pavcheck Protection Program Loans and Economic Iniury
Disaster Loans and Grants

30. The Coronavirus Aid, Reliei and Economic Security ("CARES") Act (Pub. L.

I l6- 136) (the "CARES Act" or the "Act") was enacted in March 2020 to provide emergency

financial assistance to individuals and businesses affected by the COVID-19 pandemic. The Act

provided the federal Small Business Administration ("SBA") with funding and authority to

modify existing loan programs and establish a new loan program to assist small businesses

adversely affected by the pandemic.

3l . Section I 102 of the CARES Act authorized the SBA to guarantee up to $349

billion in forgivable 7(a) loans to small businesses for job retention and other expenses. This

program was called the Paycheck Protection Program ("PPP"). In April 2020, Congress

authorized over $300 billion to additionally fund the PPP. In June 2020,the Paycheck Protection

Program Flexibility Act of 2020 (Pub. L. 116-142) was enacted which changed certain

provisions of the PPP, including provisions relating to the maturity of loans, the deferral of loan

payments, and loan forgiveness.

32. Under the PPP, eligible businesses could obtain ore SBA-guaranteed PPP loan.

Businesses were required to spend loan proceeds for employee compensation, rent or mortgage,

and other specified expenses and, depending on their use of the loan proceeds, could qualify for

loan forgiveness, up to the full amount of the loan.

33. The SBA delegated authority to third-party lenders to underwrite and approve the

PPP loans. To obtain a PPP loan, a qualifying business (through its authorized representative)

signed and submitted a PPP loan application (SBA Form 2483) online through the lender's

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application platform. The PPP loan application (SBA Form 2483) required the business (through

its authorized representative) to acknowledge the PPP program rules and make certain

affirmative ceftifications to be eligible to obtain the PPP loan.

34. The borrower's authorized representative must certify, among other things, the

business's average monthly payroll expenses and number of employees. This information is

used to calculate the amount of money the business is eligible to be loaned. The applicant must

also submit documentation showing payroll expenses, among other things.

35. In the PPP loan application, Question 5 required the authorized representative to

certify (in relevant part) that no owner of the applicant was "presently subject to a[] [felony]

indictment, criminal information, arraignment, or other means by which formal criminal charges

are brought in any jurisdiction[.]"

36. The application stated that if Question 5 was answered "Yes," the loan would not

be approved.

37. The application further required the applicant's representative to "certify in good

faith . . . that the information provided in this application and the information provided in all

supporting documents and forms is true and accurate in all material respects" and acknowledge

that "knowingly making a false statement to obtain a guaranteed loan from SBA is punishable

under the law" as a federal felony.

38. PPP loan applications were processed by participating financial institutions,

which served as the lenders. Data from the application, including information about the

borrower, the total amount of the loan, and the listed number of ernployees, were transmitted by

the lender to the SBA in the course of processing the loan. SBA paid processing fees to lenders.

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39. Once a borower submitted its PPP loan application to a Lender, the participating

lender processed the PPP loan application. If a PPP loan application was approved by the

participating lender, the lender submitted the application to SBA for an SBA loan number and

after receiving that number it thereafter funded the PPP loan using its own monies, which were

100oh guaranteed by the SBA.

40. A borrower was required to use PPP loan proceeds only for certain permissible
expenses: payroll costs, interest on mortgages, rent and utilities. The PPP allows the interest and

principal on the PPP loan to be entirely forgiven if the business spends the loan proceeds on

these expenses within a designated period (between eight and 24 weeks from receiving the

proceeds) and uses at least 60%o ofthe proceeds for payroll expenses.

41. Borrowers were eligible to apply for and obtain a "second-draw" PPP loan, bul
only after they (properly) expended the proceeds ofthe first one. "The covered periods for a

First Draw PPP Loan and a Second Draw PPP Loan cannot overlap;the borrower must use all

proceeds of the First Draw PPP Loan for eligible expenses before disbursement of the Second

Draw PPP Loan." 86 Fed. Reg.8283,8288 (Feb. 5,2021).

42. Accordingly, the second-draw application required the borrower's authorized

representative to certiff that "[t]he Applicant received a First Draw Paycheck Protection

Program Loan and, before the Second Draw Paycheck Protection Program Loan is disbursed,

will have used the full loan amount (including any increase) of the First Draw Paycheck

Protection Program Loan only for eligible expenses."

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SPECIFIC FRAUD ALLEGATIONS

From October 2019 until Mav 2022. Dora Kuzelka was Facins Felonv Charses

43. On or about October 11, 2019, Dora Kuzelka, along with Kenneth, Kari and Keith
Kuzelka, were charged in a two-count felony complaint in this District. See Uniled Stales v.

Kuzelka, Case No. I :19-cr-780 (N.D. Ill.) (Doc. 1).

44- The complaint charged one felony count of harboring illegalaliens and one felony

count of engaging in a pattern and practice of hiring illegal aliens who were not authorized to be

employed in the United States. The Kuzelkas were arrested and had initial appearances on or

about October 19,2019. Id. (Docs. l7-30).

45. On or about December I 8,2019, a federal grand jury handed up an indictment

charging the Kuzelkas and one additional codefendant with twelve felony counts, including

conspiracy to harbor illegalaliens, engaging in a pattern and practice of hiring illegalaliens, and

ten felony counts corresponding to specific illegal alien employees. Id. (Doc. 58).

46. The criminal case against the Kuzelkas continued for nearly three years, including

intensive pretrial litigation over discovery and a motion to suppress evidence. See, e.g., id.

(Docs. 154, 169-171). After the Court denied most of defendants' pretrial motions, def-endants

pled guilty or otherwise resolved their cases. On or about May 5,2022, Dora entered into a

deferred prosecution agreement. 1d. (Docs. 181 & 182).

KSOM Applies for and Receives its First PPP Loan. which is Later Foreiven

47. In or about March 202l,Dora prepared or caused to be prepared an SBA

application fora PPP loan on behalf of KSOM to Itasca Bank & Trust Co. ("lBT"), a federally-

insured financial institution based in ltasca. Illinois.

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48. On the SBA Form 2483 which was effective in March 2021, Question 5 required

the authorized representative to certify (in relevant part) that no owner of the applicant was

"presently subject to a[] [felony] indictment, criminal information, arraignment, or other means

by which formal criminal charges are brought in any jurisdiction[.]" The application stated that

if this question were answered "Yes," the loan would not be approved.

49. The application required the applicant's representative to "certif, in good faith . . .

that the information provided in this application and the information provided in all supporting

documents and forms is true and accurate in all material respects" and acknowledge that

"knowingly making a false statement to obtain a guaranteed loan from SBA is punishable under

the law" as a federal felony.

50. Upon information and belief, Dora executed or caused to be executed KSOM's

PPP loan application as the company's authorized representative.

51. Upon information and belief, Dora falsely answered or caused to be answered

"No" to Question 5 in the loan application, and initialed or caused to be initialed Question 5 to

confirm this false response.

52. Answering o'No" to Question 5 was false because Dora, a20o/o or greater owner of

KSOM, was under federal indictment for multiple felonies when the application was submitted.

53. Upon information and beliel Dora falsely certified or caused to be certified that

"the information provided in this application and the information provided in all supporting

documents and forms is true and accurate in all material respects" while acknowledging that

"knowingly making a false statement to obtain a guaranteed loan from SBA is punishable under

the law" as a federal felony.

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54. In or about March 2021, Dora submitted or caused to be submitted KSOM's PPP

loan application to IBT.

55. On or about March 18,2021, in reliance on Defendants' materially false and

fraudulent representations and certifications in the loan application, IBT issued PPP Loan

#4166398610 to KSOM in the amou nt of $422,121 .30 (the "61 0 Loan").

56. On or about June 29,2022, the 610 Loan was forgiven in full, causing the United

States to reimburse IBT for the full amount plus interest, costs and fees.

KSOM Applies for and Receives a Second PPP Loan. which is Later Forgiven

57. In or about April202l, Dora prepared or caused to be prepared an SBA

application for a second-draw PPP loan on behalf of KSOM to IBT.

58. Again, Question 5 required the authorized representative to certify (in relevant

part) that no owner of the applicant was "presently subject to a[] [felony] indictment, criminal

information, arraignment, or other fileans by which formal criminal charges are brought in any

jurisdiction[.]" The application stated that if this question were answered "Yes," the loan would

not be approved.

59. Fu(her, the application required the representative to certifu: "The Applicant

received a First Draw Paycheck Protection Program Loan and, before the Second Draw

Paycheck Protection Program Loan is disbursed, will have used the full loan amount (including

any increase) of the First Draw Paycheck Protection Program Loan only for eligible expenses."

60. The application required the applicant's representative to "ceftify in good faith . . .

that the information provided in this application and the inforrnation provided in all supporling

documents and forms is true and accurate in all material respects" and acknowledge that

II
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"knowingly making a false statement to obtain a guaranteed loan from SBA is punishable under

the law" as a federal felony.

61. Upon information and beliel Dora executed or caused to be executed KSOM's
PPP loan application as the company's authorized representative.

62. Upon information and belief, Dora falsely answered or caused to be answered
"No" to Question 5 in the loan application, and initialed or caused to be initialed Question 6 to

confirm this false response.

63. Answering'No" to Question 5 was false because Dora, a20o/o or greater owner of
KSOM, was under federal indictment for multiple felonies when the application was submitted.

Further, KSOM was ineligible for a second-draw loan because its first loan had been

fraudulently obtained.

64. Upon information and belief, Dora falsely certified or caused to be ceftified that

KSOM's first-draw loan proceeds had already been properly and fully spent. This was false

because KSOM had received its first-draw PPP loan only a few days previously on March I8.

65. Upon information and belief, Dora falsely certified or caused to be certified that
"the information provided in this application and the information provided in all suppofting

documents and forms is true and accurate in all material respects" while acknowledging that

"knowingly making a false statement to obtain a guaranteed loan from SBA is punishable under

the law" as a federal felony.

66. In or about April202l, Defendants submitted or caused to be submitted KSOM's
PPP loan application to IBT.

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67. On or about April 8,2021, in reliance on Defendants' materially false and
fraudulent representations and certifications in the loan application, IBT issued PPP Loan

#8829128708 to KSOM in the amount of $421 ,820.33 (the "708 Loan").

68. On oraboutJune 29,2022, the 708 Loan was forgiven in full, causingthe United
States to reimburse IBT for the full amount plus interest, costs and fees.

THE GOVERNMENT HAS BEEN DAMAGED AS A RESULT OF
DEFENDANTS' CONDUCT

69. Defendants' materially false statements have caused the federal government to be
defrauded of taxpayer funds in the approximate amount of $850,000.00.

CLAIMS FOR RELIEF
COUNT I
False Claims Act:
Presenting or Causing to be Presented False and Fraudulent Claims
3l u.S.c. $ 372e(a)(1)(A)
70. Relator repeats the allegations contained in the above paragraphs as if fully set
forth herein.

71. As more particularly set forth in the foregoing paragraphs, by virtue of the acts
alleged herein, the Defendants have knowingly presented, and caused to be presented, false or

fraudulent claims for payment or approval in violation of 31 U.S.C. $ 3729(a)(l)(A).

72. As a result thereof, the United States has been damaged in an amount equalto or
greater than the amount paid by the United States for such false or fraudulent clairns.

COUNT II
False Claims Act:
Making or Using False
Records or Statement to Cause Claims to be Paid
31 u.S.c. $ 372e(a)(l)(B)

73. Relator repeats the allegations contained in the above paragraphs as if fully set
forth herein.

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74. As more particularly set forth in the foregoing paragraphs, by virtue of the acts
alleged herein, the Defendants have knowingly made, used, or caused to be made or used, false

records or statements- i.e., the false representations made or caused to be made by Defendants -
materialto false or fraudulent claims in violation of 3l U.S.C. $ 3729(a)(l)(B).

75. As a result thereoi the United States has been damaged in an amount equal to or
greater than the amount paid by the United States for such false or fraudulent claims.

COUNT III
False Claims Act: Conspiracy
31 u.S.C. $ 372e(a)(1)(c)

76. Relator repeats the allegations contained in the above paragraphs as if fully set
forth herein.

77. As more particularly set forth in the foregoing paragraphs, by virtue of the acts
alleged herein, the Defendants conspired with and among each other, and with others, to make or

present false or fraudulent claims, and performed one or more overt acts to effect the submission

and cause the payment of false or fraudulent claims.

78. As a result thereof, the United States has been damaged in an amount equal to or
greater than the amount paid by the United States for such false or fraudulent claims.

PRAYER FOR RELIEF

WHEREFORE, Relator, on behalf of the United States Government, demands

judgment against the Defendants, ordering that:

A. That Defendants be ordered to cease and desist from submitting any more false

claims, or further violating 3l U.S.C. $ 3729, et seq.;

B. That judgment be entered in Relator's favor and against Defendants in the amount

ofeachandeveryfalseorfraudulentclaim,multipliedasprovidedforin3l U.S.C. $3729(a),

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plus a civil penalty of not less than S 13,508 or more than $27,01 8 per claim as provided by 3 1

U.S.C. $ 3729(a),20 CFR Part 356 and 28 CFR Part 85 (see 88 FR 5776, Jan. 30,2023), to the

extent such multiplied penalties shall fairly compensate the United States of America for losses

resulting from the various schemes undertaken by Defendants, together with penalties for

specific claims to be identified at trial after full discovery;

C. That Defendants be ordered to disgorge all sums by which they have been

enriched unjustly by their wrongful conduct;

D. That judgment be granted for Relator against Defendants for all costs, including,

but not limited to, court costs, expert fees and all attorneys' fees incurred by Relator in the

prosecution of this suit; and

E. That Relator be granted such other and further relief as the Court deems just and

proper.

JURY DBMAND

Relator hereby demands a trial by jury as to all issues so triable.

DATE: tury4zozz Respectfully submitted,

GOLDBERG KOHN

By: /s/ David J. Chizewer
David J. Chizewer
Roger A. Lewis
55 East Monroe Street
Suite 3300
Chicago, Illinois 60603 -57 92
Tel: (312) 20t-3938
Fax: (312) 863-7438
D.r: j.d-, 9_h _rz._e.11 q(lgAj d b lrgksh-Llg:tm
Jtoscr'. lur i s'7it go cl bcrg[oh n.corrl
I

Eric H. Jaso Qtro hac vice admission pending)
SPIRO HARRISON & NELSON

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363 Bloomfreld Avenue
Suite 2C
Montclair. NJ 07042
Telephone: (97 3) 232-0881
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