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, et al., a Delaware Corporation Debtors,1 RESPONSE OF CLAIMANTS, KIMBERLY S. CROMWELL, MARY GUINTO AND THOMAS A. GUNITO AND W. MARK FRAZER AND KONILYNN FRAZER, TO THE NEW CENTURY LIQUIDATING TRUSTS FORTY-SECOND OMNIBUS OBJECTION TO CLAIMS PURSUANT TO 11 U.S.C. 502(b) AND FED. R. BANKR. P. 3001 AND 3007 AND LOCAL RULE 3007-1 [NON-SUBSTANTIVE] Kimberly S. Cromwell, Mary Guinto and Thomas A. Guinto, and W. Mark Frazer and Konilynn Frazer (the Claimants), through counsel, hereby file this Response to the New Century Liquidating Trusts Forty-Second Omnibus Objection to Claims (the Objection). In support of this Response, the Claimants state as follows: Chapter 11 Case No. 07-10416 (KJC) (Jointly Administered) Related D.I # 10562

The Trustee identiifes the pre-conrmation Debtors as the following entities: New Century Financial Corporation (f/k/a New Century REIT, Inc.), a Maryland corporation; New Century TRS Holdings, Inc. (f/k/ a New Century Financial Corporation), a Delaware corporation; New Century Mortgage Corporation (f/k/a JBE Mortgage) (d/b/a NCMC Mortgage Corporation, New Century Corporation, New Century Mortgage Ventures, LLC), a California corporation; NC Capital Corporation, a California corporation; Home123 Corporation (f/k/a The Anyloan Corporation,,, a California corporation; New Century Credit Corporation (f/k/a Worth Funding Incorporated), a California corporation; NC Asset Holding, L.P. (f/k/a NC Residual II Corporation), a Delaware limited partnership; NC Residual III Corporation, a Delaware corporation; NC Residual IV Corporation, a Delaware corporation; New Century R.E.O. Corp., a California corporation; New Century R.E.O. II Corp., a California corporation; New Century R.E.O. III Corp., a California corporation; New Century Mortgage Ventures, LLC (d/b/a Summit Resort Lending, Total Mortgage Resource, Select Mortgage Group, Monticello Mortgage Services, Ad Astra Mortgage, Midwest Home Mortgage, TRATS Financial Services, Elite Financial Services, Buyers Advantage Mortgage), a Delaware limited liability company; NC Deltex, LLC, a Delaware limited liability company; NCoral, L.P., a Delaware limited partnership; and New Century Warehouse Corporation, a California corporation.

The Trustees Objection seeks to disallow and expunge certain claims of New Century customers (the Homeowners) who, through foreclosures, have become aware of the predatory lending practices of New Century Mortgage and its affiliates, including Home123. An organization known to have engaged in the practice of predatory lending, so riddled with faulty appraisals, false, misleading or missing documents, that it ultimately led to the organizations bankruptcy filing, cannot claim it was unaware of potential claims from the very customers it victimized with its predatory lending practices. See generally, Final Report of

Michael J. Missal Bankruptcy Court Examiner, dated February 29, 2008 (DI # 5518)(the Final Report); Wall Street And The Financial Crisis: Anatomy of a Financial Collapse, Majority and Minority Staff Report, Permanent Subcommittee On Investigations, United States Senate, dated April 13, 2011 (the US Senate Report)(available upon request or at public/_files/Financial_Crisis/FinancialCrisisReport.pdf). New Century Mortgage, and its affiliates (NCM), maintained a predatory lending practice victimizing homeowners across the United States of America so pervasive was their abuse that as their financial stability failed from the bad loans NCM was originating, various states issued Cease and Desist Orders, closing down NCM in those states; so pervasive were the predatory lending practices that on March 9, 2007 NCM was the subject of a federal criminal inquiry;2 so pervasive was the predatory lending pattern of behavior that in 2007 NCMs warehouse lenders withdrew funding, driving NCM to seek the protection of this Court. See Final Report at 106-07. NCM, the Debtors, and/or the Liquidating Trustee (the Trustee), would lead this Court to believe that it had no knowledge of the homeowners becoming creditors. disagree. Claimants

NCM knew their customers were sitting on ticking time bombs of financial

destruction it was never a matter of if but of when a homeowner would become a creditor. (describing various actions taken by the states of California (cease-and-desist), New York (suspended the banking license), and Florida and Washington (consent agreements with state regulators).

A. NCM Knew the Consequences of its Predatory Lending Practices.

Mass tort situations, like those described in Grossman, deal with the claims which typically arise from exposure to defective products -- asbestos exposure, airplane parts, manufactured houses, and similar products -- ultimately what all of those situations share in common is that the debtor company knew, pre-petition, of pending consequences of their flawed products. See JELD-WEN, Inc. v. Van Brunt (In re Grossman's Inc.), 607 F.3d 114 (3d Cir. 2010). Rather than demonstrating accountability by formally notifying their potential victims of potential claims (many that were known or could have easily been known), the debtors posted ambiguous, strategically placed notifications, with scant information and exposure, to alert potential victims of the bankruptcy filing, instead the Debtors claimed they had "no idea of the potential claims." In doing so, their inadequate notice "precludes discharge of a claim in

bankruptcy." Chemetron Corp. v. Jones, 72 F. 3d 341, 346 (3d Cir. 1995). In Lemelle, the court held that "at a minimum there must be evidence that would permit a debtor to identify, during the course of the bankruptcy proceedings, potential victims and thereby permit notice to these potential victims of the pendency of the proceedings ... ."
Universal Mfg. Corp., 18 F.3d 1268, 12## (5th Cir. 1994)(internal citations omitted). Lemelle v.

Such evidence, as required under Lemelle, exists, and had existed for substantial periods of time prior to the filing of the Debtors petitions. First, the Bankruptcy Court Examiner, Michael J. Missals, states in his final report that: These data evidence the ever increasing risks incurred by New Century a veritable ticking time bomb. Under the circumstances, New Century should have been more concerned about and taken steps to address loan quality. Final Report at 132 (emphasis added).
Second, the Final Report goes on to enumerate several other indicators of NCMs problems:

-- Loan files that were missing required documentation were a persistent cause of investor kickouts starting no later than 2004 and continuing through 2007. Final Report at 134. -The Quality Assurance audit results tended to identify the same sorts of problems as identified in the kickout reports, such as faulty appraisals,

undocumented exceptions to underwriting guidelines, and missing documentation from loan files. Final Report at 137 (emphasis added). -- The Production Departments results in generating revenue made the Internal Audit Departments results unimportant. Final Report at 140. Patricia Lindsay, Vice President at New Century until December 2007, in her testimony before Congress on April 7, 2010, explained the escalating disregard for risk by NCM management and shared details into the faulty appraisals including that appraisers were pressured into coming in at value fearing if they didnt, they would lose future business ... . See Exhibit A at 5. According to the examiners Final Report, NCM originated a large quantity of 2/28 and 3/27 ARMS, qualifying the borrowers on the initial teaser rate rather than the full indexed rate. This circumstance presented an obvious high risk of future default, which was specifically identified by New Century personnel. Final Report at 130 (emphasis added). Even more alarming, the Exminer goes on to explain that the kickouts represent, for the most part, loan origination process issues by New Century loan production and operations personnel not doing their jobs as expected or in accordance with the Companys underwriting policies and procedures. These policy issues were perpetrated by Management, who, month after month, tolerated this inattention to those polices and procedures. added). The claims of Homeowners are not contingent on some "fortuity of future occurrences," as the claimants in Lemelle, where the defectively designed product, there a manufactured home, may or may not explode in fire, the Homeowner claims were as Mr. Missal so adeptly stated, a veritable ticking time bomb; these were loans that were set to explode automatically in either two, three or five years from its origination. Just as asbestos injuries manifest themselves (and continue to do so) years after the exposure (the act or conduct) -- homeowners that are fighting wrongful foreclosures are just beginning to realize the extent of the fraud and the complicity of NCM and its affiliates in NCMs predatory lending practices. Homeowners, Final Report at 142 (emphasis

seeking some form of equitable restitution for the waste that has been laid to their American Dream, are often referred back to NCM as the "originator" only to find NCM, hiding behind the

protection of bankruptcy (caused by NCMs predatory acts), feigning ignorance of ever being aware of the damage their practices would cause Homeowners. Instead, Homeowners are

finding that priority is, and has been, given to the very firms who worked in tandem with NCM to deceive the American Public with their obvious, and insidious, greed. Worse yet,

Homeowners are denied at the gate by a claims bar date and with NCM alleging, we never knew the home owners were creditors. NCM not only was aware of the impending financial consequences of its predatory practices and deceit, NCM had both homeowners old addresses and NEW addresses, places of employment, social security numbers, phone numbers, and, in some cases, names of relatives. The Claimants were very well known to NCM, yet NCM chooses to plead ignorance of the identity or knowledge of those it victimized or that Homeowners were potential creditors that would come seeking some equitable restitution for NCMs bad faith acts. Clearly from the

Examiners Final Report, NCM knew the ARMs it was selling were at high risk but just as NCM ignored the rising kickouts (that some of its partners such as Morgan Stanley, decided to ignore in order to feed the veracious appetites of investors 3), NCM now claims a pristine adherence to policies and procedures and expects both this Court and the Homeowners to believe that just this one time, for this particular homeowner, NCM followed the rules. The Trustee calls foul at the potential "floodgates" of all the potential homeowners that were harmed and injured from what any reasonable analysis would conclude to be predatory lending and deceit by NCM and its Walls Street accomplices. The Trustee sued KPMG 4 for its acts in aiding and abetting breaches of fiduciary duty by NCMs management. But incredibly, NCM, through the Trustee, accepts no responsibility to these victims for NCMs conduct, complicity and participation in and for such wrongful acts. NCMs acts and practices are so deceitful they should shock the conscious of this Court, and, as such, merit strong rebuke. The (reporting on Mass. Attorney General settlement with Morgan Stanley for its role in the NCM predatory lending).

See Superior Court of the State of California, County of Los Angeles: New Century Liquidating Trust and Reorganized New Century Warehouse Corporation, by and through Alan M. Jacobs v. KPMG, BC410846 (available at KPMGCaliforniaComplaint0401.pdf).

brazen and caviler acts of NCM, in utter disregard of state statutes, federal laws and common decency, in the quest for rapid and unjust enrichment, merit an award of damages to the Homeowners that have suffered, and an actionable pathway should be provided by this Court to do so. It is truly embarrassing that priority is given to NCMs Wall Street associates in

enterprise instead of the victims. On September 2, 2011, the Federal Housing Finance Agency filed seventeen lawsuits5 against banks for their role in this debacle of the century, noting that the Office of the Comptroller in 2010 identified New Century Mortgage as the worst subprime lender in the country. The lawsuits detail the massive negligence and tortious conduct of NCM and its Wall Street partners. It is also alleged that while the Notes attributes may have been sold on the excel spreadsheets called schedules, NCM failed to consummate the sales with the proper conveyance of the Notes, and have hidden this fact from the Court by failing to disclose on its schedules that NCM still holds (owns) the paper asset.
B. NCMs ARM Customers are Known Creditors.

In Chemetron, the Third Circuit Court of Appeals stated that a "known" creditor is one whose identity is either known or "reasonably ascertainable" by the debtor. Chemetron, 72 F. 3d at 346, citing Tulsa Professional Collection Serv., Inc. v. Pope, 485 U.S. 478 (1988). The Chemetron Court further explained: A creditor's identity is "reasonably ascertainable" if that creditor can be identified through "reasonably diligent efforts. Mennonite Bd. Of Missions v. Adams, 462 U.S. 791, 798 n.4, 103 S.Ct. 2706, 2711 n.4, 77 L.Ed.2d 180 (1983). Reasonable diligence does not require 'impracticable and extended searches ... in the name of due process.' Mullane,339 U.S. at 317, 70 S.Ct. at 659. ... The requisite search instead focuses on the debtor's own books and records. Efforts beyond a careful examination of these documents are generally not required. Chemetron, 72 F.3d at 346-47 (emphasis added). Whether a creditor's claims are reasonably ascertainable must be determined by the circumstances of the case, with an eye toward whether the facts "would alert the reasonable debtor to the possibility that a claim might reasonably be filed against it." In re Drexel Burnham

Listing and links to Complaints:

Lambert Group, Inc., 151 B.R. 674, 681 (Bankr. S.D.N.Y. 1993).

Although a review of a

debtor's books and records forms the basis for this inquiry, "a debtor is obligated . . . to take undertake more than a cursory review of its records and files to ascertain its known creditors." Id. The Trustees Objection sets forth the following principles regarding known creditors: In order for a claim to be reasonably ascertainable, the debtor must have in its possession, at the very least, some specific information that reasonably suggests both the claim for which the debtor may be liable and the entity to whom it would be liable. PacifiCorp and Vancott Bagley Cornwall & McCarthy v. W.R. Grace, 2006 U.S. Dist. Lexis 57470 at 35 n.19 (D. Del. 2006) (citing In re Eagle-Pitcher Indus. Inc., 278 B.R. 437, 456 (S.D. Ohio 2002)). Knowledge of the existence of a potential creditors identity is insufficient to make that creditor a known creditor; it must be shown that the claim was known. Id. Objection at 12. These principles, as set forth by the Trustee in the Objection, do not require that a complaint be on file, or anything remotely that formal. What is required by these principles? Merely some specific information which reasonably suggests the claim and the claimant. The Trustee does not dispute that the claimants identities are ascertainable. Having conceded that the only prong of the known creditor analysis that is disputed is the identification of the claim, the Trustee then goes on to argue that the claims are not known because the Homeowners and the Claimants did not know of their claims as of the date that the Petitions were filed. However, this turns the proper analysis on its head. In determining the existence of a claim, the proper focus is the knowledge of the debtor: [I]t is the debtor's knowledge of a creditor, not the creditor's knowledge of his claim, which controls whether the debtor has a duty to list that creditor. In re Maya Constr., 78 F.3d at 1398 (citing In re Hi-Lo Powered Scaffolding, Inc., 70 Bankr. 606, 610 (Bankr. S.D. Ohio 1987)); see also In re Circle K Corp., 198 B.R. at 790 (large number of creditors does not lessen debtor's duty to file accurate list of creditors). See In re Arch Wireless, 332 B.R. 241 (Bankr. D. Mass. 2005)(In denying Debtor's Motion for Contempt against Nationwide Paging, the Bankruptcy Court concluded that

Nationwide was a known creditor at the time the Debtor filed for Chapter 11 relief under the Bankruptcy Code, and was entitled to the notice required by the Code and the Rules.). The Trustees sole support for the last argument focusing on the claim aspect of the known creditor analysis is the following bold, broad and conclusory assertion that there is no evidence in the Debtors Books and Records that the Claimants have a claim against the Debtors. Objection at 12. However, this assertion proves nothing. In essence, the Trustee is saying that, because the Debtors records do not explicitly state (reflect or set forth) a claim by each of the Homeowners, there is no claim. The Trustees Objection does not cite any case in Delaware, the Third Circuit, or elsewhere that requires that the claim appear on the Debtors books and records in such an explicit manner. Clearly, if there is such evidence; then the Debtor would be duty bound to list such a claimant as a creditor in its schedules. through confirmation. Debtors duties with respect to updating schedules run

See Bankruptcy Rule 1007(h)(debtor has mandatory duty to file a

supplemental schedule in a chapter 11 case to disclose within 14 days after the information comes to the debtors knowledge that the debtor acquires or becomes entitled to acquire any interest in property; this duty continues notwithstanding the closing of the case until the entry of the order confirming a chapter 11 plan ... .). Accordingly, the NCM, and all other debtors, had a continuing duty to update schedules with respect to such interests. What process did the Trustee employ in connection with the objection to the Claimants claims ? The Objection states: According to KCC, to date, approximately 4,133 claims have been asserted against the Debtors. All proofs of claims, including administrative claims, received in these cases are recorded on the official claims register maintained by KCC. In the ordinary course of business, including subsequent to the Petition Date, the Debtors maintained books and records (the Books and Records) that reflect, among other things, the Debtors liabilities and the amounts owed to its creditors. The Trustee, with the assistance of its professionals, has reviewed the Debtors Books and Records and has compared such Books and Records to the proofs of claim filed in this case (collectively, including any supporting documentation, the Proofs of Claim) and the liabilities listed in the Debtors schedules.

Objection at 8. The Trustee has not explained this process in any detail. In fact, there is no definition of what constitutes the Debtors books and records. Without any detailed explanation of this review process, the best way to describe the Trustees review process would be to call it -- cursory. Had NCM, or the other debtors, taken more than a "cursory review" of their accounts and records, they would have immediately identified Homeowners as an entities that qualified as creditors under the Bankruptcy Code. See In re Arch Wireless, 332 B.R. 241 (Bankr. D. Mass. 2005)(Holding that because the Debtor failed to provide to Nationwide notice of the Bar Date, the Confirmation Hearing and the Confirmation Order, Nationwide's pre-confirmation claims against the Debtor were not discharged under 1141(a) and (d)(1)(A) by the entry of the Confirmation Order. The discharge injunction under 524(a)(2) is therefore inapplicable.); see also Bankruptcy Code 1141(d)(3)(confirmation does not discharge a debtor if chapter 11 plan provides for the liquidation of all or substantially all of the property of the estate and the debtor does not engage in business after the consummation of the plan and the debtor would be denied a discharge under section 727(a)). There is further evidence that the Claimants and Homeowners should be found to be known creditors. First, the Trustees Objection does not even acknowledge claims such as Marks, which have been filed. Shortly after the Debtors petitions were filed in April 2007, Leslie Mark a timely filed a POC, alleging similar claims to those of the Claimants. Marks v. New Century TRS Holdings, Inc. (In re New Century TRS Holdings, Inc.), 2011 Bankr. LEXIS 1695 at *2-3 (Bankr. D. Del. May 10, 2011). Second, the Objection does not

address the evidence of increasing kickout rates during 2006 or 2007. Third, the Objection does not address the existence of numerous similar claims that have been filed since the petitions have been filed. Fourth, the Objection ignores the US Senate Report and the

Examiners Final Report. (concluding after reviewing and analyzing NCMs books and records that the evidence reveals the ever-increasing risks incurred by New Century -- a veritable ticking time bomb). Final Report at 130-32. In addition to this evidence, a simple survey of NCMs records should demonstrate, and confirm, whether any homeowners note was ever booked as a loan receivable by NCM. If those

notes were not booked as receivables, then NCM never disclosed the real parties to the agreement.

C. The Trustee Has Failed To Perform Reasonably Diligent Efforts.

Throughout the Objection, the Trustee is to assert that it has no burden to discharge in connection with discovering creditors with potential claims. Nothing could be further from the truth, as is demonstrated by the Court in Nationwide and its recitation of the many responsibilities of debtors under the Bankruptcy Code to list and update lists of creditors in the debtors schedules. See In re Arch Wireless, 332 B.R. 241 (Bankr. D. Mass. 2005). Essentially, a trustee, like the NCM trustee, steps into the shoes of the Debtors. Thus, the Trustee (as a

fiduciary to all beneficiaries of the Trust) has important duties, perhaps more important duties than the Debtors. Here the Trustee takes the Nationwide position to the extreme. In Nationwide the debtor argued that its books, at all relevant times, showed a balance owed on [Homeowners] accounts ... . Id. at 255. Here the Trustee, goes a step, several steps further, and argues that there simply is no express evidence in the Debtors books and records stating that the Homeowners have a claim. Just as the more realistic position taken by the debtor in Nationwide was squarely rejected, so too should this Court reject the Trustees unsupported, and unexplained, position which is boldly asserted here. In Nationwide, the Bankruptcy Court reviewed the

available evidence and succinctly states that: When viewed in context, however, this fact alone is hardly dispositive. The Debtor admits that Nationwide refused to pay the amounts due because Nationwide believed it had been over-billed and had suffered compensable damages as a result of defective pagers provided by the Debtor. Nationwide repeatedly asserted its claims against the Debtor in writing. The communications sent from Brown to the Debtor in September and November of 2000 and in February and September of 2001 clearly articulate Nationwide's belief that the Debtor was liable to Nationwide for affirmative compensation and offsets on its accounts. Thus, the Debtor had in its possession several writings evidencing a claim asserted against it by Nationwide. And the outstanding and overdue accounts were clearly an ongoing concern that occupied the Debtor's attention. Id.


Here, the Claimants, had, and have, claims, and such claims were clearly an ongoing concern that occupied the Debtor's attention. In re Arch Wireless, 332 B.R. 241, 255 (Bankr. D. Mass. 2005). Moreover, as the Court in Nationwide observed, [t]o do so [i.e., to perform such a review] would have required no Herculean efforts, but merely a reasonable inquiry into its own records. Id. Lastly, the fact that NCM, and the other debtors, may dispute the Homeowners claims does not alleviate a debtor from listing such creditor on its schedules. Id. (citing and quoting In re Spring Ford Indus., Inc., 2003 Bankr. LEXIS 882, *10 (Bankr. E.D. Pa. July 25, 2003) ("While the Debtor contests the claims asserted by the Claimants, they are still claims under the Bankruptcy Code, 11 U.S.C. 101(5), and the holders are creditors, 11 U.S.C 101 (10)") and In re Arnold Print Works, Inc., 47 B.R. 288, 289 (Bankr. D. Ariz. 1984) (entity "must be considered a 'known creditor' even though its claim is disputed by the Debtor and "should have been listed by the Debtor on the schedules at least as a disputed or potential claim")). Accordingly, had NCM, or the other debtors, taken more than a "cursory review" of their accounts and records, they would have easily identified the Homeowners, and the Claimants, as an entities (entity, as defined in Bankruptcy Code includes individuals) that qualified as creditors under the Bankruptcy Code. See In re Arch Wireless, 332 B.R. 241 (Bankr. D. Mass. 2005).

D. Notice Was Insufficient Even For Unknown Creditors.

A debtor need not be omnipotent or clairvoyant, but need only do what is reasonable under the circumstances to provide notice to ascertainable creditors. Gentry v. Circuit City Stores, Inc. (In re Circuit City Stores, Inc.), 439 B.R. 652, 660 (E.D. Va 2010)(citing In re J.A. Jones, Inc., 492 F.3d 242, 251 (4th Cir. 2007)). NCM at the time of its bankruptcy filing had Cease and Desist Order from California, a license suspension from New York, and agreed to consent order from including Washington and Florida, as a direct result of their predatory lending practices. At a minimum NCM should have ran notices in state-wide newspapers or publications in each of those states, thereby alerting Homeowners to their potential claims. Yet NCM chose not to do so.


NCM knew that its lending practices were flawed. However, NCM -- for fear of opening the floodgates to Homeowners who may have filed meritorious claims -- preferred to alert only its Wall Street partners (those who aided and abetted NCMs predatory lending practices) through the Wall Street Journal, and its employees, through the Orange County Register. Numerous nationwide publications were available, such as the New York Times, USA Today, to name a few. These publications have a far wider circulation then the chosen publications, and might have afforded Homeowners (the victims of New Centurys predatory lending practices) some chance of being given notice of the bar date. Of the 3 Claimants, Cromwell is the only claimant residing in California, and she is still over 400 miles from Irvine, California. Such newspaper advertisements are relatively inexpensive. Accordingly, there is no

reasonable explanation for the failure to publish the Bar Date Notice in more than 2 publications. It is not unusual in this District to publish bar date notice in both the Wall Street Journal and USA Today. See also Wright v. Owens Corning, 450 B.R. 541, 556-57 (W.D.Pa 2011)(warranty claims and notice provided in New York Times, Wall Street Journal and USA Today, and 250 regional and local newspapers, and approximately 35 trade publications in the primary lines of business operated by the debtor). Recently this Court, cast doubt on the effectiveness of publication in this proceeding, in concluding on the record then before it, in stating that: Although the Debtors arguably complied with the stated minimum requirements of the Bar Date Order, without a more fully developed factual record, I am unable to determine whether the publication notice was reasonably calculated to provide notice to consumer mortgagors like the Whites. White v. New Century TRS Holdings, Inc. (In re New Century TRS Holdings, Inc.), 450 B.R. 504, 514 (Bankr. D. Del. 2011). Had this Court had no doubts as to the effectiveness of the publication notice, the Court would have approved the publication notice without the need for additional evidence.


CONCLUSION WHEREFORE, Claimants respectfully requests that the Court deny the Objection (D.I. 10562), or, in the alternative, rule on the Claimants outstanding Motions to have their claims deemed timely filed decided co-extensively with any ruling on the Objection, and grant such other and further relief as the Court may deem just and proper. Dated: Wilmington, Delaware September 21, 2011 /s/ Joseph J. Bodnar ________________ Joseph J. Bodnar, Esquire (DE #2512) LAW OFFICES OF JOSEPH J. BODNAR Post Office Box 1022 Wilmington, DE 19899-1022 Telephone: 302-449-4572 Facsimile: 302-397-2093 E-Mail: Attorneys for Claimants