Attorney Practice of Adding Defective Investment Shareholder as the Executor on behalf of Creditor
Author | Lawyer Liu Kun
abstract
In 2013, the "Company Law" was amended to change the paid-in system of registered capital into a subscription system, and the restriction on the proportion of monetary contributions in the registered capital was abolished. Although the subscription system reform has reduced the cost of founding a company and stimulated market vitality, it has also brought about problems of shareholders maliciously evading their capital contribution obligations, such as setting a decades-long investment period, maliciously extending the investment period, and deliberately transferring the equity of the last investment period to a transferee who does not have the ability to contribute capital... These problems have led to the emptying of the company's capital.
Although the creditor has obtained the judgment in favor of the lawsuit, the company has no property to enforce, and can only hope that the shareholders of the company will bear the supplementary compensation liability. At this time, the creditor faces three options: execution objection (lawsuit), another lawsuit against the shareholder to damage the interests of the creditor, and execution to bankruptcy. The three options have advantages and disadvantages, and the creditor should choose the most suitable procedure according to his own situation.
First, the problem of capital void brought about by the registered capital subscription system
(1) The inherent flaw of the subscription system - the time when a company needs the most money is often the time when shareholders are least willing to contribute.
In 2013, the Company Law was amended to change the registered capital paid-in registration system to the subscription registration system, abolish the minimum registered capital limit, and simplify the company registration matters and registration process. This reform greatly relaxed the conditions for starting a company, and all kinds of companies have sprung up with the trend of "mass innovation and mass entrepreneurship".
The advantage of the subscription system is that when the economy is in an upswing, the company has the ability to generate cash flow to maintain operations and repay debts, and shareholders can be "white wolves with empty gloves" even if they do not pay their contributions. The disadvantage is that when the economy is in a downswing, the company's cash flow decreases and it is unable to repay its maturing debts. At this time, shareholders need to make up their contributions the most. However, considering that the company's operations are already in trouble, some shareholders will take various methods to avoid paying their contributions.
In practice, the most common situation is that shareholders subscribe to huge amounts of registered capital that far exceed their economic strength, set up investment periods of up to decades, try to bluff and exaggerate the size of the company, and then pay in after the company realizes profits, or do not intend to pay in. Such shareholders generally lack legal awareness and do not realize that when the company is unable to pay off its due debts, the investment period will accelerate expiration, and they will eventually have to pay their contribution obligations with real money.
As creditors' selection criteria for suppliers become more and more stringent, creditors with well-developed procurement systems will not include such companies in their supply chains. To this end, some shareholders will pay part of the capital while subscribing to a huge amount of registered capital, and the investment period is only 3 or 5 years, so as to demonstrate the strength of shareholders and their determination to operate for a long time.
After the company obtains the order, the shareholders will extend the investment period by amending the company's articles of association.
These issues prompted the Supreme People's Court to introduce the accelerated expiration system of shareholder contributions in the National Court Civil and Commercial Trial Work Meeting Notes Law [2019] No. 254 (hereinafter referred to as the "Nine People's Meeting Notes").
(2) The accelerated expiration of shareholder contributions - the "patch" of the "Jiumin meeting notes" to the subscription system.
In order to prevent the shareholders of the company from abusing the benefits of the time limit for subscribing capital contributions to damage the interests of creditors, the Supreme People's Court issued the judgment guidance on the accelerated expiration of shareholders' capital contributions in the "Nine People's Meeting Notes" with reference to the provisions of Article 35 of the Enterprise Bankruptcy Law, which clarified two situations in which shareholders' capital contributions accelerate expiration, namely, the company has bankruptcy reasons but does not apply for bankruptcy and the company extends the capital contribution period after the company's debts are incurred.
However, if the company has bankruptcy reasons, the shareholders' unfulfilled capital contributions belong to the company's property, and the bankruptcy expenses should be paid first in the bankruptcy procedure, and the public debt should be paid off proportionally by each creditor. Instead of being paid by a creditor alone in the execution procedure.
Therefore, the meeting notes break through the current legal framework and are a temporary "patch" for the subscription contribution system in a special form.
The Supreme People's Court also pointed out that "under the registered capital subscription system, shareholders believe that the time for registration and payment of capital contributions is publicized, and of course it should not be advanced, and of course it should not be accelerated. I think almost all shareholders in China share this view. This is China's national situation. We have to consider this national situation, otherwise there may be major problems.
No matter how correct the theory of comprehensive accelerated expiration is, there is no legal or judicial interpretation, and the main purpose of the minutes is to unify the judgment's thinking. It is also very prudent for us to add two exceptions to the regulations, one is to deal with similar issues in accordance with the provisions of the Enterprise Bankruptcy Law, and the other is to maliciously extend the subscription period.
"- Article 6 of the" National Court Civil and Commercial Trial meeting notes "[Whether the expiration of shareholders' capital contributions should be accelerated] [Understanding and application part].
(3) There is a gap in the legal liability of shareholders to transfer equity before the capital contribution period is expired under the current legislative framework.
Although the "Jiumin meeting notes" unifies the referee's thinking of accelerating the expiration of shareholder contributions, it still does not solve a problem -Should the shareholders who transfer their equity before the capital contribution period bear supplementary compensation liability for the debts that the company cannot pay off?In practice, there are a large number of disputes arising from the transfer of equity before the investment deadline.
Some shareholders transfer their equity to retirees before the expiration of the investment period after the company's debt is generated, and the investment period will not expire for decades after the elderly transfer the equity; some shareholders transfer their equity to dishonest executors and disabled people who obviously have no ability to contribute, and even give birth to "professional debtors" in the private sector; some shareholders transfer their equity and establish a new company to engage in the same business as the original company; some shareholders will let others hold the equity, and they will control the company behind the scenes or simply ignore it.
Under the subscription system,Transfer of equity before the expiration of the capital contribution period ≠ transfer of equity if the capital contribution obligation is not fulfilledTherefore, the creditor cannot, in accordance with Article 19 of the Provisions of the Supreme People's Court on Several Issues Concerning the Modification and Addition of Parties in Civil Enforcement (hereinafter referred to as the "Provisions on Modification and Addition") (a company that is the subject of enforcement, has insufficient property to pay off the debts determined in the effective legal documents, and its shareholders transfer their equity if they fail to fulfill their capital contribution obligations according to law. If the promoter who applies for the executor to apply for the modification or addition of the original shareholder or bears joint and several liability for the capital contribution in accordance with the provisions of the Company Law is the subject of enforcement, and bears responsibility within the scope of the failure to make capital contributions according to law, the people's court shall support it)
It is also impossible to comply with Article 13 (2) of the Provisions of the Supreme People's Court on the Application of Several Issues (3) (if the company's creditors request that the shareholders who fail to perform or fully perform their capital contribution obligations bear supplementary compensation liability for the part of the company's debts that cannot be paid off within the scope of the principal and interest of the unfunded capital contribution, the people's court shall support it; if the shareholders who fail to perform or fully perform their capital contribution obligations have already assumed the above responsibilities, and if other creditors make the same request, the people's court shall not support it) and Article 18 (1) (if the transferee knows or should know that the shareholders of a limited liability company transfer their equity if they fail to perform or fully perform their capital contribution obligations, the company requests the shareholders to perform their capital contribution obligations, If the company's creditors file a lawsuit against the shareholder in accordance with the second paragraph of Article 13 of these Provisions, and at the same time request the aforesaid assignee to bear joint and several liability, the people's court shall support it) and claim that the transferring shareholder bears supplementary liability for the company's debts.
In practice, some courts will apply the provisions of the invalidity of legal acts committed by conspiracy and hypocrisy, and investigate the civil liability of shareholders for malicious transfer of equity before the capital contribution period, but there are also certain limitations.
II. Prerequisites for shareholders to enjoy term benefits
The registered capital subscription system is a major innovation of the capital system in our country's "Company Law". According to the provisions of Article 26 (1) of the "Company Law" (the registered capital of a limited liability company is the amount of capital subscribed by all shareholders registered with the company registration authority) and Article 28 (1) (shareholders shall pay their respective subscribed capital contributions as stipulated in the company's articles of association on time and in full), shareholders enjoy term benefits for the subscribed capital contributions, that is, before the expiration of the capital contribution period, the company has no right to require shareholders to perform their capital contribution obligations, and creditors have no right to require shareholders to perform their capital contribution obligations.
It can be seen that under the subscription system, shareholders have complete autonomy in capital contribution, which is easy to induce moral hazard. In practice, there are also shareholders who abuse term benefits to evade capital contribution obligations. Therefore, it is necessary to formulate rules so that shareholders can not only fully enjoy term benefits, but also cannot abuse their rights to evade capital contribution obligations.
Therefore, while the "Company Law" stipulates the subscription system, it also requires companies to register important information such as the company's articles of association, the amount of subscribed capital contributions by shareholders, and the period of investment in the national credit information inquiry system, and provide it to everyone for free viewing. Any creditor can check the actual payment amount and investment period of the company's capital at almost zero cost when conducting transactions with the company.
Creditors choose to trade with the company when they understand the company's capital contribution, and protecting the shareholders' interest in the subscription capital contribution is in line with the principles of autonomy and transaction efficiency.However, if the company violates the information disclosure system or makes creditors have the trust of shareholders' paid-up capital by other means, and uses the creditor's trust to damage the interests of creditors, it should not be protected by the term interest.
In addition, the principle of capital adequacy is one of the basic principles of company laws in various countries, and it is also the cornerstone of legal person property independence and limited liability of shareholders. Although the Company Law of our country does not directly stipulate the principle of capital adequacy, many regulations reflect this principle, such as requiring companies to withdraw statutory provident funds before distributing profits, strictly restricting company capital reduction, and repurchasing equity.
Therefore, the premise of shareholders enjoying term benefits is to ensure the enrichment of the company's capital, specifically to pay capital contributions in a timely manner and maintain the company's continuous operation, and the ability to pay off maturing debts in a timely manner is the best touchstone for the company's continuous operation. When the company is already insolvent, if shareholders still have unmatured capital contributions, of course, they should be used to repay debts to maintain the company's operation or liquidate the company. This is the basic requirement of the principle of capital enrichment. This view is also reflected in the guidance of the "Jiumin meeting notes" on the accelerated maturity of shareholder contributions.
III. Judicial Practice of Creditors Requesting Shareholders to Bear Supplementary Liability for Compensation
(1) Supplementary capital contribution obligations of different shareholders
1. Current shareholders and established shareholders who have not yet completed the investment period
As mentioned above, shareholders who have not yet paid the capital contribution period enjoy the term benefit, except in the case of accelerated expiration of the capital contribution period in line with the "Nine People's Meeting Notes". At this time, the creditor may directly apply for the addition of the current shareholders and established shareholders of the company as the person subject to enforcement if the property of the profit-making legal person is insufficient to pay off the debts determined by the effective legal documents, and the shareholder or investor who applies for the modification or addition of the capital contribution or the promoter who is jointly and severally liable for the capital contribution in accordance with the provisions of the Company Law is the person subject to enforcement. If the person is legally liable within the scope of the unpaid capital contribution, the people's court shall support it.) .
2. The original shareholder who transferred the equity before the capital contribution period
The first conclusion is that the original shareholder who cannot directly add the non-capital contribution period or transfer the equity in the execution stage is the person subject to execution, because under the framework of the current "Company Law", it is generally said that the non-capital contribution period is the transfer of equity ≠ the non-performance of the capital contribution obligation is the transfer of equity, and only the original shareholder needs to bear the supplementary compensation liability when there is malicious intent when transferring the equity.
Due to the absence of direct provisions in this regard in the Company Law, some courts will, in accordance with the provisions of Article 146 of the Civil Code, determine that the transfer of equity between the original shareholder and the transferee shareholder is false and should be an invalid legal act. Therefore, the original shareholder is still bound by the period of shareholders' capital contribution. If the company has bankruptcy reasons but does not file for bankruptcy, its capital contribution should expire at an accelerated rate.
The above judgment ideas need to review the authenticity and reasonableness of the equity transfer behavior, which cannot be achieved by the execution objection procedure. Therefore, the court tends to reject the creditor's application when reviewing such execution objections, allowing the creditor to choose to file an execution objection lawsuit for substantive review.
The following section is an argument process and can be read selectively.
Whether the original shareholder who transfers the equity before the capital contribution period can be added is the executor. This question depends onWhether the original shareholder who transfers the equity before the capital contribution period shall bear the obligation of shareholder capital contribution。
There are two opinions on whether to undertake or not to undertake at present. The view that the original shareholders who advocate transferring the equity before the expiration of the capital contribution period also need to bear the capital contribution obligation holds that:
(1) Shareholders' capital contribution obligations are legal obligations and cannot be eliminated due to the transfer of equity. Otherwise, shareholders can easily evade their capital contribution obligations by transferring equity, which will breed moral hazard and harm the interests of the company and creditors.
(2) The shareholder's capital contribution obligation is actually the shareholder's debt to the company, so the transfer of the shareholder's capital contribution obligation should also comply with the provisions of the Civil Code on debt transfer, that is, the original shareholder should obtain the consent of the company when transferring the capital contribution obligation to the transferee shareholder.
For example, the Second Intermediate People's Court of Shanghai held that in the case of equity transfer disputes between Shenzhen Yi'an Extended Insurance Guarantee Service Co., Ltd. and Shanghai Haoyue Investment Management Co., Ltd., Xu Qingsong, Mao Xiaolu, Jiechangjian, Lin Dongxue, etc. [ (2018) Shanghai
02Minzhuan No. 9359]
"The transaction freedom of equity transfer must not shake the statutory foundation of the company's capital enrichment, and must not damage the legitimate interests of the company's creditors. The subscribed capital contribution obligation of shareholders forms a debt with a maturity period attached to the company. The change of the company's shareholders caused by the equity transfer is related to whether the capital contribution debt can be fulfilled on time.
The equity transfer of subscribed capital is not only the internal rights distribution and obligations burden of both parties in the equity transaction, but also has significant external spillover effects, which is related to the implementation of the company's capital enrichment principle and affects the realization of the company's creditors' rights.
Although the subscription capital system has gradually changed the company's external credit from capital credit to asset credit, the company's registered capital base reflected in the shareholder's subscription capital is the economic foundation of the company's operation, and it is an important basis for the counterparty to judge the company's credit level, debt repayment ability and measure transaction risk.
The creditors of the company have reasonable trust and foreseeable expectation on the solvency of the company corresponding to the subscribed capital contribution of the shareholders of the company.
The subscribed capital contribution of shareholders has not only the autonomy of the contractual intention determined through negotiation, but also the legal attribute due to the clear provisions of the company law on the shareholders' capital contribution obligations and the company registration and publicity system. Therefore, due to the change of the equity transfer of the shareholders of the company, it cannot be presumed that the legal capital contribution obligations of the subscribed shareholders will be transferred accordingly. "
The opposing view holds that the shareholder's capital contribution obligation is based on the shareholder's identity. After the equity transfer, the original shareholder no longer has the shareholder's identity and does not need to bear the capital contribution obligation, while the transferee shareholder bears the capital contribution obligation because of the shareholder's identity.
Moreover, the shareholder's capital contribution is the company's public information, and the transferee shareholder can fully weigh whether the income brought by becoming a shareholder matches whether the capital contribution obligation. And if the original shareholder is still locked in the capital contribution obligation of the transfer of equity, it will hinder the liquidity of the equity and deprive the original shareholder of the right to exit the company through equity transfer.
For example, the Supreme People's Court held in the case of Zeng Lei and Gansu Huahuineng Digital Technology Co., Ltd. Equity Transfer Dispute [ (2019) Supreme Court Civil Final No. 230]
"Article 28 of the Company Law of the People's Republic of China stipulates that shareholders shall pay their respective subscribed capital contributions as stipulated in the company's articles of association in full and on time. Shareholders enjoy the'term benefit 'of capital contributions. When conducting transactions with the company, the company's creditors have the opportunity to comprehensively inspect whether to conduct transactions with the company on the basis of reviewing the company's shareholders' investment time and other credit information. The creditor's decision on the transaction shall be bound by the shareholder's investment time.
"Failure to fulfill or fully fulfill the obligation to contribute capital" as stipulated in Article 13 (2) of the Provisions of the Supreme People's Court on Several Issues Concerning Application shall be understood as "failure to pay or not fully pay the capital contribution", and shareholders who have not fully paid their capital contribution share before the expiration of the capital contribution period shall not be deemed as "failure to fulfill or not fully perform the capital contribution obligation".
In this case, when Feng Mou1 and Feng Mou2 transferred all the equity, the capital contribution period of the subscribed equity had not expired, which did not constitute the situation of "transfer of equity if the capital contribution obligation is not fulfilled or fully fulfilled" as stipulated in Article 13, paragraph 2 and Article 18 of the Provisions of the Supreme People's Court on Several Issues Concerning the Application of the Company Law of the People's Republic of China (3), and Zeng did not provide evidence to prove that he based on the will or actual behavior of Feng Mou1 and Feng Mou2 and confirmed or relied on the specific capital contribution period of the above shareholders, and based on the above confirmation or trust, he had a creditor's right and debt relationship with Gansu Huahuineng Company.
Zeng claimed that Feng Mou1 and Feng Mou2 should bear supplementary compensation liability for the unliquidated part of the debt of Gansu Huahuineng Company within the scope of unfunded principal and interest. The essence is to advocate that Feng Mou1 and Feng Mou2 accelerate the expiration of their capital contributions. The appeal request has no legal basis and this court will not support it. "
The author believes that both views are reasonable, but the emphasis is different. The former focuses on protecting the interests of creditors and safeguarding transaction security, while the latter focuses on protecting the rights of shareholders and promoting transaction efficiency. However, in any case, there is no law or judicial interpretation that directly stipulates that the original shareholders who transfer the equity before the capital contribution period should bear the corresponding capital contribution obligation of the transferred equity, and the creditors cannot claim that the original shareholders' capital contribution obligation expires faster according to the provisions of the "Nine People's Meeting Notes".
In view of the above reasons, in order to investigate the civil liability of the shareholder's malicious transfer of equity before the capital contribution period expires, some courts have adopted the provision that the civil legal act under the expression of conspiracy and hypocrisy is invalid, and found that the contract of the original shareholder's malicious transfer of equity before the capital contribution period expires is invalid.
For example, in the case of dispute over sales contract between Shanghai Zhonglaizijin Electric Appliance joint stock company and Xu Mouli, Fang Mousong and Xu Mouzhen [ (2020) Zhejiang 0282 Minchu No. 7108, (2020) Zhejiang 02 Minzhuan No. 5716], the court held that
"If the shareholders' transfer of equity and capital contribution obligations exist under the following circumstances, the people's court may comprehensively analyze and determine that the relevant civil legal act is a conspiracy and false intention:
The transfer of equity occurs after the company is indebted, during the litigation or execution of relevant debt disputes; there is a specific relationship between the two parties to the transfer; the assignee does not pay the consideration to the transferor or does not actually make capital contributions; when the equity is transferred, the assignee is older and the investment period is longer; after the equity transfer, the assignee does not participate in the operation of the company and the company does not continue to operate normally; after the equity transfer, the transferor sets up another company to operate in the same industry.
If the transfer of equity and the transfer of capital contribution obligations is found to be invalid due to conspiracy and false intention, when the capital contribution obligations expire at an accelerated rate, the transferor shall supplement the debts of the company before the equity transfer. If the conspiracy and false transfer causes the creditor's rights to be unrealized, the transferee shall be jointly and severally liable for the transferor's supplementary compensation liability. "
At present, the scheme has the clearest claim basis and the least disputes in the application of law. However, the scheme requires a higher burden of proof on creditors, and creditors need to prove the existence of at least one of the following facts:
1. The equity transfer occurs after the company's debt is incurred or very close to the time when the company's debt is incurred.
2. The transferee shareholder is an elderly person, disabled person, or has a special relationship with the original shareholder.
3. The company did not carry out business activities after the transfer of equity or the transferee shareholders did not participate in the operation of the company.
4. The price of the equity transfer is extremely low or no actual payment is made.
5. The original shareholders established a new company to engage in similar business.
If the court finds that the original shareholder's act of transferring the unfunded equity to the transferee shareholder nominally is that the transfer of equity is actually an evasion of the capital contribution obligation, the equity transfer is invalid, and the original shareholder still has to bear the capital contribution obligation. In the case that the company has bankruptcy reasons but has not applied for bankruptcy, the original shareholder's capital contribution obligation should expire at an accelerated pace, and the original shareholder shall bear the supplementary compensation liability for the company's debts.
(2) Program selection
1. Before the creditor sues the company, the company may have met the conditions for the accelerated expiration of the shareholder's capital contribution
The author suggests that the creditor should search whether the company is the person subject to execution in another case and has terminated the execution through the execution information disclosure network when suing the company.
If so, the company's shareholders may already have the conditions for the accelerated expiration of their contributions, at which point a "race" has begun among creditors, that is, who can obtain and implement the effective legal documents for shareholders to assume supplementary compensation liabilities first.
According to the second paragraph of Article 13 of the Interpretation of the Company Law, once a shareholder assumes a supplementary compensation liability for any creditor, it is deemed that it has fulfilled its capital contribution obligation, and other creditors have no right to require the shareholder to bear the supplementary compensation liability.
If the creditor files a lawsuit to accelerate the expiration of the shareholder's capital contribution and assume the obligation to supplement the capital contribution when suing the company, it only needs to go through the first instance, second-instance, and execution to achieve the goal.
If the creditor does not file the above claims at the time of prosecution, it needs to go through the first instance - second-instance - enforcement - enforcement objection - first instance of enforcement objection - enforcement objection - second-instance - to resume enforcement in order to achieve the goal.
If our party finds that the creditor in the other case has added the shareholder who has not completed the capital contribution period as the executor, we can also apply for bankruptcy of the company, so that the creditor in the other case cannot receive the unfulfilled capital contribution of the shareholder alone and must be compensated proportionally with our party.
2. Choice of enforcement objection (lawsuit) or shareholder liability dispute for harming the interests of creditors
According to Article 29 of the "Addition and Alteration Regulations", if a creditor applies for the addition of a defective capital shareholder as the person subject to enforcement, it shall be submitted to the enforcement court, which shall be responsible for review.
Article 32 Where a creditor or a shareholder of defective capital contribution refuses to accept the ruling, he or she shall file an appeal for enforcement objection with the enforcement court. The current and established shareholders who have not yet reached the capital contribution period may, upon meeting the conditions for accelerated capital contribution expiration, file an additional application with the enforcement court.
The key point is that for the original shareholder who transfers the equity before the capital contribution period, should the creditor choose to apply for an objection to enforcement and add him as the person subject to enforcement or file a separate lawsuit against the shareholder's liability for damaging the interests of the creditor?
As mentioned above, the original shareholder who requests the court to add the capital contribution period or transfer the equity in the execution procedure is the person subject to execution, and the judge responsible for reviewing the execution objection will generally reject the application.
However, if the dissatisfied party is not satisfied with this kind of execution objection ruling, the dissatisfied party can only choose to apply for an enforcement objection lawsuit in the enforcement court, so the creditor can lock the jurisdiction in the enforcement court by applying for an enforcement objection. This can avoid going to the people's court where the original shareholder is located to sue separately, and the disadvantage is that there is one more enforcement objection procedure.
3. Execution of insolvency proceedings
According to Article 511 of the Interpretation of the Supreme People's Court on the Application of the Civil Procedure Law, creditors may also apply to the enforcement court to transfer the case to the people's court where the person subject to enforcement is located for bankruptcy review when the person subject to enforcement has reasons for bankruptcy.
If the case that meets the conditions of execution to bankruptcy is that there is no property available for execution, the creditor's only hope is to accelerate the expiration of the shareholder's capital contribution.
In this case, from the perspective of lawyers, the author does not recommend that creditors apply for execution to transition to bankruptcy. Because even if the court rules that the company is bankrupt and the shareholder's capital contribution expires at an accelerated rate, the company needs to pay the bankruptcy expenses first, and then settle the common interest debt, and finally the creditor can receive the shareholder's capital contribution proportionally.
Finally, in order to recover losses, creditors sued the company for the first instance, second-instance, and enforcement, which consumed a lot of time and energy. As a result, they had to pursue shareholders' capital responsibility through execution objections (lawsuits), shareholder disputes that damaged the interests of creditors, and execution of bankruptcy. This greatly increased the cost of creditors, caused a large number of idling procedures, and lost judicial efficiency.
Fortunately, the "Company Law (Third Review Draft of the Revised Draft) " stipulates that the subscribed capital of shareholders of a limited company should be paid in full within five years, the directors have the right to urge the shareholders to pay the capital if they do not pay the capital when it expires, and the company cannot pay off the due debt. The shareholder capital contribution will accelerate the maturity and other systems. The future subscription capital system will be more perfect.
Lawyer Profile
Lawyer Liu Kun
Attorney of
Secretary General of the Real Estate Dispute Resolution Professional Committee of Zhiheng Real Estate and Construction Engineering Research Center
area of expertise
Corporate litigation, marriage and family legal services
Workout and non-performing asset disposal
contact information
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