Cambece Assurance and Civil Action 2006
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Transcript of Cambece Assurance and Civil Action 2006
CIVIL ACTION COVER SHEET ' 6 - 1 5 4 2
II idi ....,oul l til IVIdSSLICI-IliSeltS ' \
Superior Court Department 1 County: Suffolk g,.-6_,,,
PLAINTIFF(S) -:01,;55§NR In the matter of Compnwealth of Massachusetts by Thomas F. Reilly, Attorney General J.A. Cambece Law Office, P.C.
ATTORNEY, FIRM NAME, ADDRESS AND TELEPHONE (617) Stephanie Kahn, MG 727-2200 Office of the Attorney General One Ashburton Pl. , Boston, MA 02108
Board of Bar Overseers number. B130 # 547477
, ,,,, ATTORNEY (if kpown) A P . . , \MO\ V ' I Elizabeth B. Bi u Qi- -\ c\s Mintz Levin Col e -'-3̀5p!IMovsky & Popeo,PC One Financ C-' ston, MA 0211
Place an x in one box only:
Origin code and track designation 07-1
" 4. F04 Dist ct Court Appeal 7 &1 4 (After
of Discontinuance trial) (X) k I " 5. F05 Reac•• ,ated a relief from
judgment/Or ass.R.Civ.P. 60) (X) (X) " 6. E10 Summary Process Appeal (X)
ti: 1. F01 Original Mat9Rglitt Assurance " 2. F02 Removal to Sup.Ct. C.231,s.104
(Before trial) (F) " 3. F03 Retransfer to Sup.Ct. C.231,s.102C
TYPE OF ACTION AND TRACK DESIGNATION (See reverse side) CODE NO. TYPE OF ACTION (specify) TRACK IS THIS A JURY CASE?
E99 Assurance of Discontinuance N/A ( ) ( ) Yes ( X ) No
The following is a full, itemized and detailed statement of the facts on which plaintiff relies to determine money damages. For this. form, disregard double or treble damage claims; indicate single damages only.
TORT CLAIMS (Attach additional sheets as necessary)
A. Documented. medical expenses to date: 1. Total hospital expenses $ 2. Total Doctor expenses $ . _ 3. Total chiropractic expenses $ 4. Total physical therapy expenses _ ... $ , „ ..... _ , . 5. Total other expenses (describe) $
Subtotal $ ... ... B. Documented lost wages and compensation to date $ C. Documented property damages to date $ D. Reasonably anticipated future medical and hospital expenses $ . E. Reasonably anticipated lost wages $ F. Other documented items of damages (describe)
$ G . Brief description of plaintiff's injury, including nature and extent of injury (describe)
$ . _ .... . TOTAL $ . . — . . . . —
CONTRACT CLAIMS ' (Attach additional sheets as necessary)
Provide a detailed description of claim(s):
TOTAL $.
PLEASE IDENTIFY, BY CASE NUMBER; NAME AND COUNTY, ANY RELATED ACTION PENDING IN THE SUPERIOR COURT DEPARTMENT
"I hereby certify that I have complied Dispute Resolution (SJC Rule 1:18) resolution services and discuss
Signature of Attorney of Record
. 5 of the Supreme Judicial Court Uniform Rules on lients with information about court-connected dispute
disadvantages of the various methods:'
DATE: 10/31/06
with ti ... -..s
re ring that I I u de...a " - m e • • .-•-• 4o..a -W
AliPAIL'Illinallh'.- nuaimp,,...0s. AOTc-6 mtc005-11/99 A.O.S.C. 1-2000
2006 Cambece Assurance and Civil Action - P. 1
COMMONWEALTH OF MASSACHUSETTS
SUFFOLK, SS. SUPERIOR COURT DEPARTMENT CIVIL ACTION NO. _________________________________________________ ) In the Matter of ) ) J.A. CAMBECE LAW OFFICE, P.C. ) ) _________________________________________________)
ASSURANCE OF DISCONTINUANCE PURSUANT TO G.L. C. 93A, § 5 I. Introduction
Pursuant to the provisions of Massachusetts General Laws c. 93A, the
Commonwealth of Massachusetts, by its Attorney General Thomas F. Reilly, conducted
an investigation into debt collection in Massachusetts, including certain methods, acts
and practices employed by J.A. Cambece Law Office, P.C. ("Cambece") in the collection
of alleged debts from "debtors." As used herein the term "debtor(s)" shall refer to
individuals against whom Cambece seeks to collect an alleged debt. The use of the term
debtor in no way reflects the validity of the alleged debt that Cambece is seeking to
collect.
The Attorney General has received complaints from debtors relating to
Cambece's debt collection practices and conduct and, having investigated those
allegations, the Commonwealth by its Attorney General ("Commonwealth") concludes
that it has reason to believe that Cambece engaged in conduct that violated certain federal
and state laws and regulations relating to debt collection and consumer protection.
In 2005, Cambece became aware of the Commonwealth's investigation and
voluntarily approached the Office of the Attorney General. The parties thereafter met to
2006 Cambece Assurance and Civil Action - P. 2
discuss the Commonwealth's concerns, as well as Cambece's policies and procedures to
ensure its compliance with debt collection laws and regulations. Cambece has
cooperated with the Attorney General's investigation.
Cambece believes that its conduct has been lawful and denies that it has engaged
in conduct that violated any laws or regulations. The Commonwealth has agreed to
resolve the allegations through an Assurance of Discontinuance rather than an
enforcement action under M.G.L. c. 93A, § 4. Cambece and James Anthony Cambece
a/k/a as J. Anthony Cambece, (hereinafter collectively referred to as the "Cambece
Parties") have agreed to enter into this Assurance of Discontinuance in the spirit of
cooperation to avoid the expenses of protracted litigation and without admitting liability.
The Commonwealth and the Cambece Parties agree that (a) the Cambece Parties have not
admitted that they engaged in any unlawful conduct; (b) the Cambece Parties have made
no admission of wrongdoing; and (c) this Assurance is not a finding by a court of any
liability or wrongdoing by the Cambece Parties.
II. Consumer Allegations
The Office of the Attorney General ("AGO") has received complaints from debtors
alleging the following violations:
1. Using profane or obscene language when communicating with debtors;
2. Communicating with debtors in such a manner as to harass or embarrass
them;
3. Communicating with debtors in excess of two calls in a seven-day period
at their residence;
4. Placing telephone calls to debtors at hours other than their normal waking
2006 Cambece Assurance and Civil Action - P. 3
hours, including before 8 a.m. and after 9 p.m.;
5. Communicating with debtors at their place of employment after being
instructed in writing to cease communications at work;
6. Implying (the fact) that debtors owed a debt and/or directly discussing the
debt with persons other than the debtors;
7. Threatening to take action, including legal action, against debtors, which
was not taken or could not have been taken at the time the threat was made;
8. Failing to allow a debtor to inspect and copy certain materials regarding
the debt during normal business hours of the creditor and upon notice to the
creditor not less than 5 business days preceding the scheduled inspection;
9. Failing to provide validation of debt upon request of debtors, and
10. Attempting to collect from debtors debts known to be invalid or that
should have been known to be invalid (collectively, the "Consumer Allegations").
The Commonwealth has not commenced any enforcement proceeding or
regulatory or civil action against the Cambece Parties.
III. Assurances
The Cambece Parties voluntarily and knowingly agree as follows:
1. Compliance with Federal and State Laws and Regulations
The Cambece Parties, including their officers, directors, and shareholders and
their employees, agents, successors, heirs, assigns and any other person acting under their
direction or control, directly or indirectly; whether acting individually, in concert with
others, or through any corporation, trust, partnership, association, franchise or other entity
or device through which they may now or hereafter act or conduct business in the
2006 Cambece Assurance and Civil Action - P. 4
Commonwealth of Massachusetts, shall comply with M.G.L. c.93, § 49, Massachusetts
Consumer Protection Act, M.G.L. c. 93A; Massachusetts Debt Collection Regulations,
940 CMR 7.00 et seq., including but not limited to 940 CMR 7.04(1)(b), 7.04(1)(c),
7.04(1)(f), 7.04(1)(g), 7.05(2), 7.07(4), 7.08, 7.09; and Federal Fair Debt Collection
Practices Act, 15 U.S.C. § 1692 et. seq., including but not limited to § 1692d (1), 1692d
(2), 1692d(5), 1692e and 1692g(b).
2. Debt Collection Supervisor
a. For a period of five (5) years from the date of execution of this Assurance,
Cambece shall continue to designate an employee, who is an attorney, to be
responsible for supervising debt collection activities ("Debt Collection
Supervisor") and ensuring compliance with federal and state debt collection laws
and regulations and this Assurance.
b. For a period of five (5) years from the date of execution of this Assurance,
Cambece shall provide to the Commonwealth the name of the Debt Collection
Supervisor and updated information whenever a new Debt Collection Supervisor
is appointed.
3. Debt Collection Training Supervisor
a. For a period of five (5) years from the date of execution of this Assurance,
Cambece shall continue to designate an employee, who is an attorney, to be
responsible for training all Cambece employees ("Training Supervisor").
b. For a period of five (5) years from the date of execution of this Assurance,
Cambece shall continue to maintain written policies and procedures for training
all employees.
2006 Cambece Assurance and Civil Action - P. 5
c. Such training shall include the following:
1. The Training Supervisor shall certify within thirty (30) days of the
date of execution of this Assurance that all current employees have
completed training, and that any new employees will complete the training
before having any contact with debtors, be it oral2ly or in writing. However, new employees as
part of a supervised training, may under the
direct supervision of the Training Supervisor, have contact with debtors,
as part of the final stage of training;
ii. Training shall continue to require that every employee receive and
read M.G.L. c. 93, § 49; the Massachusetts Consumer Protection Act,
M.G.L. c. 93A; the Massachusetts Debt Collection Regulations, 940 CMR
7.00 et seq.; and the Federal Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.;
iii. Training shall continue to require that every employee receive and
read the Cambece Compliance Handbook, then currently in use, mediation
and training policies and procedures utilized by Cambece, as well as this
Assurance;
iv. Cambece shall provide the Commonwealth with copies of all
training materials and updated materials used to train its employees;
v. For a period of five (5) years from the date of execution this
Assurance, the Training Supervisor must continue to maintain a record of
the training of every employee. Such training records shall be provided to
the Commonwealth upon reasonable request;
2006 Cambece Assurance and Civil Action - P. 6
d. For a period of five (5) years from the date of execution of this Assurance,
Cambece shall provide to the Commonwealth the name of the Training
Supervisor and updated information whenever a new Training Supervisor is
Appointed.
4. Debt Mediation Supervisor
a. For a period of five (5) years from the date of execution of this Assurance,
Cambece shall continue to designate an employee, who is an attorney, to be
responsible for overseeing all written (i) complaints against Cambece regarding
the validity of the alleged debt and (ii) complaints regarding Cambece's debt
collection practices, made by debtors or by third parties or government entities on
behalf of said debtors ("Mediation Supervisor").
b. After compliance with account verification in paragraph 9 below, any
claims that then remain unresolved shall be promptly investigated by the
Mediation Supervisor. Efforts to attempt to resolve must include reasonable
attempts to work in good faith with The Consumer Complaint Information
Section ("CCIS") of the Attorney General's Office and/or the Local Consumer
Protection Agencies funded by the Attorney General.
c. For a period of five (5) years from the date of execution of this Assurance,
Cambece shall provide to the Commonwealth the name of the Mediation
Supervisor and updated information whenever a new Mediation Supervisor is
appointed.
2006 Cambece Assurance and Civil Action - P. 7
5. Retention of All Debtor Collection Accounts
For a period of five (5) years from the date of execution of this Assurance,
Cambece shall maintain, and make available to the Commonwealth, upon reasonable
request, all records then in Cambece's possession, with respect to each collection account,
including, but not limited to,
a. The name and address of the debtor;
b. The name of the creditor and the creditor's account number;
c. If the creditor is an assignee, then the name of the original creditor and the
original creditor's account number(s);
d. The amount and nature (e.g. credit card bill) of the alleged debt;
e. The date, time, manner (e.g. telephone, letter, e-mail), and content of
every communication that is not subject to the attorney client or work product
privileges;
f. The employee(s) involved in the debt collection activities; and
g. The amount of money, if any, collected by Cambece and the manner of
payment (e.g. check, money order, credit card);
In the event that Cambece does not have any of the above information in its possession,
Cambece shall make a written request to its client for such information.
6. Retention of Disputed Debtor Collection Accounts
a. It is understood that, at the time of execution of this Assurance, the
Cambece Parties do not own the debts that they collect or attempt to collect on
behalf of their creditor clients. It is further understood that at the time of
execution of this Assurance, Cambece maintains its collection account records in
2006 Cambece Assurance and Civil Action - P. 8
a proprietary software system owned by one of its clients to whom Cambece is a
licensee. As such, in some instances, Cambece's clients request the return of all
records relating to a particular debtor. In these instances, Cambece is required to,
and does, honor those requests.
b. Upon Cambece's receipt of a written (i) complaint regarding the amount
or validity of the debt, or (ii) complaint regarding Cambece's collection practices,
made or submitted by a Massachusetts debtor; third party (e.g. Better Business
Bureau, Local Consumer Program) or government entity, the Mediation
Supervisor shall immediately create a "Debtor Complaint Local File," paper or
electronic that shall remain with Cambece in the event that the creditor requests
the return of the account. The Debtor Complaint Local File shall include all
account records, including collection notes, correspondence sent and received and
other related information that are then in Cambece's possession. The Debtor
Complaint Local File shall be updated weekly, or as necessary, while the
complaint is open. The Debtor Complaint Local Files shall be maintained by the
Mediation Supervisor and shall be provided to the Commonwealth upon
reasonable request.
c. In the event that the Debtor Complaint Local File is not created prior to
the account being returned to the client, or the Debtor Complaint Local File lacks
information necessary to determine the validity or the amount of the debt,
.Cambece will make a written request to its client for the debtor's file, including
the information set forth in paragraph 5 above.
2006 Cambece Assurance and Civil Action - P. 9
d. Cambece shall retain the Debtor Complaint Local File for a period of five
(5) years from the date of execution of this Assurance, or until the complaint is
resolved by mediation or otherwise, whichever time period is longer.
e. The requirements of record retention set forth in this section are in
addition to other record keeping requirements in this Assurance.
7. Recording Telephone Communications
For a period of five (5) years from the date of execution this Assurance, Cambece
shall continue to record all debt collection telephone communications with debtors,
debtors' households, debtors' workplace, and with third parties, provided these parties
have consented. These recordings shall be maintained for 365 days from the date of the
communication and shall be made available to the Commonwealth upon reasonable
request.
8. Recording Automatic Payment Authorization
a. For a period of five (5) years from the date of execution of this Assurance,
Cambece shall record all oral authorizations made by debtors for automatic
payment of debts, including all oral authorizations made by debtors to deduct
funds from credit cards, charge cards or bank accounts of any kind ("oral
authorizations").
b. All such recordings shall be preserved for two (2) year period from the
date the recording is made.
c. Within two (2) business days after Cambece receives an oral
authorization, Cambece shall provide written confirmation to the debtor that
specifies the amount, and method of the authorized payment(s), and the dates(s)
2006 Cambece Assurance and Civil Action - P. 10
that such payment(s) are authorized to be effected. The written confirmation shall
specify as much itemization of the original debt (including principal, interest,
fees) as is then in Cambece's possession and the balance due, if any, after each
authorized payment is made. With respect to any payment by check that is to be
made more than five (5) days from the date it is entered on the account, Cambece
shall provide written confirmation of its intent to deposit such check. This
confirmation shall be sent not more than ten (10) days or less than three (3) days
prior to such deposit, and shall specify as much itemization of the original debt
(including principal, interest, fees) as is then in Cambece's possession and the
balance due, if any, after each authorized payment is made.
9. Account Verification
a. Unless previously provided in Cambece's initial communication with a
debtor, Cambece shall, as required by 15 U.S.C. 1601 § 809, send written notices
to debtors within five (5) days after its initial communication with any debtor that
contains the following:
i. Amount of debt;
ii. Name of the creditor, and if the debt has been assigned, the name
of the original creditor;
iii. A statement that unless the debtor, within thirty days after receipt
of the notice, disputes the validity of the debt, or any portion thereof, the
debt will be assumed to be valid;
iv. A statement that if the debtor notifies Cambece in writing, within
thirty days after receipt of the notice, that the debt or any portion thereof,
2006 Cambece Assurance and Civil Action - P. 11
is disputed, Cambece will obtain written verification of the debt or
judgment from its client, copies of which will be sent to the debtor;
v. A statement that if the debtor notifies Cambece in writing, within
thirty days after receipt of the notice, that the debt, or any portion thereof
is disputed, Cambece will cease all collection activities until the debtor is
provided with written verification of the debt or judgment.
b. If Cambece does not have within its possession documentation to verify a
debt disputed in writing, it shall request from its client documentation to verify
the validity and amount of the debt and the debtor's relationship to the debt. At a
minimum, verification provided by Cambece to debtors shall include (i) a copy of
the original application and/or agreement if it exists; and (ii) two of four account
statements described as follows: the account statement for (1) the month prior to
the debtor's last payment on the debt; (2) the month in which the debtor made his
last payment on the debt; (3) the month after the debtor made his last payment of
the debt; or (4) the charge-off statement.1 Any statement produced under this
paragraph must contain the following: (a) the name and address of the debtor; (b)
the name of the creditor; (c) the debtor's account number; and (d) the statement
date and the total amount due as of that date. At least one of these statements
must separate the total amount due into two distinct categories representing the
balance due for purchases, cash advances and debits and the balance due for
finance charges; including any late fees and penalties. Attached collectively as
Exhibit "A" are four sample statements that satisfy the above requirements.
_____________________ 1 The "charge-off statement" is a statement that reflects the amount claimed by the original creditor at the time when the account was charged off.
2006 Cambece Assurance and Civil Action - P. 12
c. In the event that Cambece cannot provide the debtor with a statement that
separates the total amount due into two distinct categories representing the
balance due for purchases, cash advances and debits and the balance due for
finance charges, including any late fees and penalties and said debtor disputes in
writing the interest rate or interest amount charged then, in addition to providing
the statements set forth previously in this paragraph, Cambece will provide to the
debtor a copy of the applicable credit card agreement. In the event that said credit
card agreement is not available, Cambece will not charge interest on the account,
except that Cambece may collect post judgment interest in accordance with
applicable law.
d. If Cambece cannot provide this account verification it shall cancel its
collection effort and return the account to its client with a written notification that
states that the account is being returned and the basis for the return, and requests
that the client retain a copy of such notification with the returned account. In the
event that Cambece returns an account to its client for this reason, Cambece also
shall provide written notification to the debtor that Cambece: (i) does not have in
its possession the information or documents that the debtor requested; (ii) has
returned the debt account to its client and no longer represents its client in
connection with that debt; and (iii) that this notification is being provided so that
the debtor can retain this letter responding to debtor's request for debt verification
for his records. Cambece shall maintain a copy of such notification in its Debtor
Complaint Local File for a period of five (5) years and shall make the same
available to the Commonwealth upon reasonable request.
2006 Cambece Assurance and Civil Action - P. 13
10. Final Settlements
When Cambece proposes an oral final settlement agreement to a debtor, whether
by a lump sum single payment or payments over time, and the debtor orally agrees to the
terms of such agreement, Cambece shall notify the debtor that he may rescind the
agreement if, within two (2) business days, excluding the date that the oral agreement
was made, the debtor provides written notice of rescission to Cambece. In the event that
Cambece receives no such written notice of rescission by 5:00 pm on the second business
day, Cambece shall then within four (4) business days provide the debtor written
confirmation of the settlement terms.
11. Uncollectible Debt
Without limitation as to time, Cambece will continue to refrain from attempting to
collect, or collecting any debt that it, after exercising due diligence, knew or reasonably
should have known to be discharged, or paid or owed by a person other than the named
debtor, or is otherwise not legitimate ("uncollectible debt"). Upon determining that an
account is an uncollectible debt, Cambece shall return the uncollectible debt account to
the client with written notification that (i) advises the client of the basis for Cambece's
determination as to why the debt is uncollectible and (ii) requests that the client retain a
copy of Cambece's notification with the returned account. In the event that Cambece
returns an account to its client in accordance with this paragraph, Cambece also shall
provide written notification to the debtor that Cambece: (i) has been unable to obtain
certain necessary information and/or documents relating to the account; (ii) has returned
the debt account to its client and no longer represents its client in connection with that
debt; and (iii) that the debtor should retain a copy of this letter for his records. Cambece
2006 Cambece Assurance and Civil Action - P. 14
shall maintain a copy of such notification in its Debtor Complaint Local File for a period
of five (5) years and shall make the same available to the Commonwealth upon
reasonable request.
12. Payment
Upon execution of this Assurance, Cambece shall deliver to the Commonwealth a
certified check, payable to the Commonwealth of Massachusetts, in the total amount of
$75,000.00, representing $45,000.00 to the Local Consumer Aid Fund, which is
administered by the office of the Attorney General pursuant to M.G.L. c. 12, § 11G,
restitution in the amount of $20,000.00, and reasonable attorneys' fees and costs in the
amount of $10,000.00. This Assurance does not assess any penalties or fines against the
Cambece Parties. The Attorney General may, in his sole discretion, disburse restitution
payments to debtors. Any funds remaining after disbursement of the restitution shall be
contributed to the Local Consumer Aid Fund.
III. Release
In consideration of the Cambece Parties' entry into this Assurance and the
payment of the sums required under paragraph 12 above, and the Cambece Parties'
continued compliance with the terms of this Assurance, the Commonwealth waives and
releases all of its civil claims against the Cambece Parties relating only to the Consumer
Allegations defined above, that occurred prior to and through the date of execution of the
Assurance. So long as the Cambece Parties continue to comply with the terms of this
Assurance, the Commonwealth shall not initiate any civil proceeding or take any civil
action against the Cambece Parties (including, but not limited to, civil regulatory
proceedings or civil enforcement proceedings) for any conduct relating to the Consumer
2006 Cambece Assurance and Civil Action - P. 15
Allegations that occurred prior to and through the date of execution of this Assurance.
Notwithstanding the same, any violation of this Assurance shall be admissible, in
accordance with the provisions of G.L. c. 93A § 4, in any action or proceeding
commenced by the Commonwealth.
IV. Miscellaneous Provisions
a. This Assurance shall not relieve the Cambece Parties of any of their
obligations to comply with all applicable federal and state laws and regulations.
b. Nothing in this Assurance shall affect any right of private action that any
person, other than the Commonwealth, may have against the Cambece Parties.
c. In the event that any of the Cambece Parties either (a) transfers, assigns or
sells their assets to other entities engaged in debt collecting ("Successor Entities")
or themselves directly or indirectly collect debt in Massachusetts or hold an
interest in other entities that collect debt in Massachusetts ("Other Debt Collection
Entities"), then the Cambece Parties shall transfer their obligations and liabilities
under this Assurance to such Successor Entities or Other Debt Collection Entities
to the extent allowed by law.
d. Nothing contained in this Assurance shall be construed as an admission
that the Cambece Parties had engaged in any unlawful, fraudulent, illegal, or
improper activity.
e. Nothing contained in this Assurance shall be construed as a waiver of or
limitation on the Cambece Parties' right to defend themselves from, or to make
agreements in any claim, action, suit or proceeding, federal or state, relating to the
existence, subject matter or terms of this Assurance.
2006 Cambece Assurance and Civil Action - P. 16
f. This Assurance contains the complete agreement between the parties. No
promises, representations, or warranties other than those set forth in this
Assurance have been made by any of the parties. This Assurance supersedes all
prior communications, discussions, or understandings, if any, of the parties,
whether written or oral. This Assurance can be modified or supplemented only by
written memorandum signed by the parties .
g. To the extent that any changes in Cambece's business practices are made
to conform to the terms of this Assurance, such changes shall not constitute any
form of evidence or admission by Cambece, directly or indirectly, expressly or
implicitly, of any wrongdoing of any kind or of any failure to comply with any
federal or state statutes or regulation or the common law.
h. Cambece shall comply with the terms of this Assurance within thirty (30)
days of its date.
i. If the Attorney General determines that the Cambece Parties have failed to
comply with any of the terms of this Assurance, and the Attorney General is not
seeking a temporary restraining order, the Attorney General will notify the
Cambece Parties in writing of such failure to comply five (5) business days prior
to the commencement of any action to provide an opportunity to the Cambece
Parties to confer with the Attorney General in person or by counsel or other
representative as to the proposed action.
j. Any notices or communications required to be transmitted between the
parties to this Assurance shall be sent by first class mail or facsimile to the
following parties or individuals at the following addresses:
2006 Cambece Assurance and Civil Action - P. 17
J. A. Cambece Law Office, P.C. or James Anthony Cambece a/k/a J. Anthony Cambece:
J. Anthony Cambece, Esq. Cambece Law Office, P.C. Eight Bourbon Street, Peabody, MA 01960 Facsimile 978-535-7070 with a copy to Elizabeth B. Burnett, Esq. Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. One Financial Center Boston, MA 02111 Facsimile 617-542-2241
Commonwealth of Massachusetts
Stephanie Kahn Assistant Attorney General Office of the MA Attorney General Consumer Protection & Antitrust Division One Ashburton Place Boston, MA 02108 Facsimile 617-727-5765
k. The Cambece Parties are represented by and have consulted with counsel,
Elizabeth B. Burnett of Mintz, Levin, Cohn, Ferris, Glovsky & Popeo,
P.C. in connection with their decision to enter into this Assurance.
1. The undersigned officer of Cambece is duly authorized to execute this
Assurance on behalf of Cambece and to bind Cambece to all of its
provisions, and on behalf of Cambece hereby enters into this Assurance of
Discontinuance voluntarily.
End of Page 17
COMMONWEALTH OF MASSACHUSETTS THOMAS F. REILLY ATTORNEY GE1
Dated: (2)6,6, Ste Jef 7 As istant Attorne eneral Cons rotection and Antitrust Division One Ashburton Place Boston, MA 02108 (617) 727-2200
J.A. CAMBECE LAW OFFICES, P_C. JAMES ANTHONY CAMBECE a/k/a J. ANTHONY CAMBECE
By their Attorneys:
Jr. s...mmy,
Elizabeth B. Burnett BBO # 066120 Mintz, Levin, Cohn, Ferris, Glovsky & Popeo, P.C. One Financial Center
OF Boston, MA 02111 (617) 348-16Y'
By: gett ~~ Preside
OF ICE
Dated: cJf 5:) 1 C(0
Dated: 1 01 .(:)/ OC.
Dated: t S ANTHONY CAMBECE a/lc/a
.̀ ANTHONY CAMBECE, Individually
18
Exhibit A
Account Statement Month Prior to the Debtor's Last Payment on the Debt
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