Get Ready For Changes To Immigration Laws What Universities, Hospitals and Research Institutes Have To Know Klasko, Rulon, Stock and Seltzer, LLP Philadelphia 1800 JFK Blvd. Suite 1700 Philadelphia, PA 19103 215.825.8600 www.klaskolaw.com New York 317 Madison Ave. Suite 1518 New York, NY 10017 212.796.8840 H. Ronald Klasko, Esq. Ron Klasko is the Managing Partner of Klasko, Rulon, Stock & Seltzer, LLP and has been providing immigration assistance and solutions to universities, hospitals, and research institutions for over 25 years. Ron is a past National President of the American Immigration Lawyers Association and served for 3 years as the bar association’s General Counsel. He is a past Chair of AILA’s Department of Labor National Liaison Committee, its Task Force on H and L Visas and Business Immigration Committee. Mr. Klasko is the recipient of the 1999 American Immigration Lawyers Association Founders Award, bestowed upon the individual who has had the most positive impact on immigration law. Ron has been selected as one of the top immigration lawyers in the US by The Chambers Global Guide. He is selected annually for inclusion in Best Lawyers in America. The International Who’s Who of Business Lawyers selected Mr. Klasko as one of the 5 most highly-regarded immigration lawyers in the world. He is a frequent author and lecturer on hospital and university-related immigration law topics and is a former Adjunct Professor of Immigration Law at Villanova University Law School. Ron is a graduate of the University of Pennsylvania School of Law. Klasko, Rulon, Stock & Seltzer, LLP Richard R. Rulon, Esq. Rich Rulon has been practicing immigration law for more than 30 years. Rich is a member of the American Immigration Lawyers Association (AILA), is a former Chair of AILA’s Philadelphia Chapter, has served on the Board of Governors of AILA and the Immigration Reform Committee. He has also served on the Board of Trustees of the American Immigration Law Foundation (AILF) including six years as Chairman and was the recipient of AILF’s 2005 Honorary Fellow Award for lifelong service to the field of immigration and nationality law. Rich has been a lecturer at seminars on immigration law subjects and at AILA Annual Conferences; has authored numerous articles on immigration law topics and has played and continues to play an active role in helping to shape immigration reform legislation. Rich was selected for inclusion in The Best Lawyers in America and also as a “Pennsylvania Super Lawyer.” Rich is a graduate of the University of Pennsylvania Law School. Klasko, Rulon, Stock & Seltzer, LLP William A. Stock, Esq. William A. Stock is a founding partner of Klasko, Rulon, Stock & Seltzer, LLP. He handles all aspects of immigration law, including assisting companies and individuals in obtaining employment- and family-based visas; resolving citizenship issues and obtaining naturalization; and defending clients in DHS and Department of Labor enforcement proceedings. Bill is featured in The Chambers Global Guide, The Best Lawyers in America, Pennsylvania Super Lawyers, and Who’s Who of Business Lawyers. He currently serves as Chair of the Philadelphia Chapter of AILA, is member of AILA’s National Board of Governors. He received AILA’s Joseph Minsky Award, given to a lawyer under age 35 who has made the most outstanding contributions to the field of immigration law, in 2000. Bill is a graduate of the University of Minnesota Law School and currently is an Adjunct Faculty Member at Villanova University School of Law. Klasko, Rulon, Stock & Seltzer, LLP Suzanne B. Seltzer, Esq. Suzanne B. Seltzer is a founding partner of Klasko, Rulon, Stock & Seltzer, LLP, and manages the New York office. She handles a wide range of business immigration matters, with an emphasis on universities, pharmaceutical companies, clinical physicians, and research scientists. Suzanne is a member of the National Coalition for Access to Healthcare, Co-Chair of AILA’s NY District Director Liaison Committee, and Co-Chair of the NYC Anti-Trafficking Network’s legal subcommittee. Suzanne is a frequent speaker on immigration options available to international medical graduates and research scientists, and is the author of several articles. Suzanne was honored with the Cornerstone Award by the Lawyers Alliance for New York in recognition of her outstanding contributions to pro bono work on behalf of non-profit agencies, and the Samuel E. Klein Pro Bono Award for her work on behalf of victims of human trafficking. Suzanne obtained her JD from Georgetown University Law Center. Klasko, Rulon, Stock & Seltzer, LLP The Chambers Global: The World’s Leading Lawyers for Business selects Klasko, Rulon, Stock and Seltzer, LLP as One of the Six Top Immigration Firms in the US “For many sources, the firm is the strongest in the country when it comes to representing clients in the university research and medical sectors. It is also respected for its efficient handling of referrals from institutions seeking complex visa applications particularly those relating to people of extraordinary ability and national interest.” The Lawyers: Ron Klasko is regarded as “a leading national practitioner who really does it all.” “Literally on the cutting edge” when it comes to immigration policy and legislative issues, peers find it “fascinating to see how creative he is” in this arena. The “young and brilliant” partner Bill Stock also received strong recommendation from interviewees for the quality of his practice and his expertise in J-1 visas. Klasko, Rulon, Stock & Seltzer, LLP Agenda Legislative / Regulatory Update PERM / Backlog Elimination Center Workshop Options for the Best and Brightest Travel / Security Clearance Workshop Q&A Klasko, Rulon, Stock & Seltzer, LLP Legislative and Regulatory Update Richard R. Rulon, Esq. Two Major Bills Passed House Legislation HR 4437, The Border Protection, Antiterrorism, and Illegal Immigration Control Act of 2005 Klasko, Rulon, Stock & Seltzer, LLP Senate Legislation S. 2611, The Comprehensive Immigration Reform Act of 2006 HR 4437: Border Protection, Antiterrorism, and Illegal Immigration Control Act (Sensenbrenner) PASSED the House December 16, 2005 Enforcement-only legislation, does not deal with H-1B blackout, family-based/employment-based backlog or other non-immigrant reform measures. Seeks to more stringently enforce our present immigration system. Creates new federal felony of “unlawful presence and defines the term broadly and introduces penalties on those who support or shield illegal migrants, which could mean that employees of social service agencies and churches could face up to five years in prison for helping unauthorized foreigners. Klasko, Rulon, Stock & Seltzer, LLP HR 4437 (Continued) Requires the creation of a new system for telephonic or electronic verification of an individual’s employment authorization and makes participation in the new program mandatory for all employers within two years of the bill’s enactment. Verification would be required for both new employees and previously hired employees. Revises the date upon which the basic pilot program for employment verification systems becomes mandatory to two years after the enactment of this legislation. Significantly increases the civil penalties for hiring, recruiting, and referral violations, and would extend the definition of “recruit or refer” for purposes of triggering obligations under this title to hiring hall-type situations. Klasko, Rulon, Stock & Seltzer, LLP Title I – Border Enforcement Passed by Senate on May 25th 2006 Requires DHS to submit plan within 6 months of enactment for installing US-VISIT system at every U.S. port of entry. Requires all DHS documents giving evidence of immigration status to be machine-readable, tamper resistant, and contain biometric identification data allowing DHS to electronically verify such status. Klasko, Rulon, Stock & Seltzer, LLP Title I – Border Enforcement (continued) Extends deadline (until June 1, 2009) for implementation of Western Hemisphere Travel Initiative. Authorizes Secretaries of State and Homeland Security to develop secure travel documents called “Passport Cards” for international travel across the U.S.-Mexican border, U.S.-Canada border, and travel between U.S. and a country located in the Caribbean or Bermuda. Recommends other modifications to improve crossborder travel initiatives. Klasko, Rulon, Stock & Seltzer, LLP Title II – Interior Enforcement Expands the definition of “Criminal alien smuggling” to include those who “facilitate or encourage” this act. New definition also encompasses those who shield undocumented immigrants from prosecution or encourage such immigrants to stay in the U.S. Immunity from prosecution is granted to religious entities and humanitarian organizations that provide assistance to undocumented immigrants. Klasko, Rulon, Stock & Seltzer, LLP Title II – Interior Enforcement (continued) Creates a new Electronic Employment Verification System (EEVS) for employers to use to evaluate the work authorization of individual employees, requiring all employers to participate, and making it illegal to hire or continue to employ an undocumented alien; EEVS replaces old I-9 system. Imposes civil/financial penalties on employers who hire undocumented workers and/or fail to keep proper records; imposes criminal penalties for repeat violations and bars federal contracts with employer for 5 years. Klasko, Rulon, Stock & Seltzer, LLP Title II – Interior Enforcement (continued) Timetable for implementation: For new hires, all employers must participate 18 months after date that $400 million has been made available to implement EEVS. Employers may volunteer to participate before the 18-month period. Attestation for employers: Employer must attest that it has verified the identity and eligibility to work by taking specific steps including examining the following: For U.S. Citizens: U.S. passport or state-issues driver’s license. For Aliens: LPR card or employment authorization card. When above unavailable, DHS can authorize use of other documents. Alternative document must have photograph and tamper-resistant security feature. Attestation for employees: Employees must attest that they are eligible to work in the U.S. Individuals subject to $5000 fine and/or imprisonment for 3 years for false attestation. Klasko, Rulon, Stock & Seltzer, LLP Verification Process Employer must use EEVS to confirm individual’s employment eligibility no later than 3 days after date of hire. DHS must provide (via EEVS) response to employer within 10 days. When worker found ineligible, he/she is given notice of this and has 10 days to submit the evidence contesting ineligibility. DHS must provide final confirmation or non-confirmation within 30 days after worker contests non-confirmation notice. If DHS fails to respond within 30 days, the worker is granted default confirmation. Employer must terminate worker upon final non-confirmation notice, and provide to DHS any information DHS feels will assist in enforcing immigration laws. Klasko, Rulon, Stock & Seltzer, LLP Title IV – Temporary Worker Program with Labor Protections & Path to Permanent Status Creates a temporary worker program (H-2C), with a potential path to legal permanent residence for 200,000 low-skilled workers per year currently outside the US. Visa category becomes available 18 months after date that $400 million has been made available to implement EEVS (Title III). Klasko, Rulon, Stock & Seltzer, LLP Title V – Backlog Reduction Immediate relatives no longer count against the family based cap of 480,000 per fiscal year, thereby adding 254,000 new visas per year to eliminate backlogs. Recaptures unused visas from FY 2001-2005. Creates recapture mechanism for unused visas for all years going forward. Raises employment based cap to 450,000 for fiscal years 2007 through 2016; cap drops to 290,000 in 2017 and each fiscal year thereafter. Creates an overall cap of 650,000 that includes spouses and children of employment –based principals thus, once the 650,000 numbers have been used by principals, spouses and children, no more visas may be issued to principals. Klasko, Rulon, Stock & Seltzer, LLP Title V – Backlog Reduction (continued) Increases per country ceilings for both employment-based and familybased immigrant visas. The new allocation of 450,000 employment-based visas is: EB-1:15% EB-2:15% EB-3: 35% EB-4 (investors): 5% EB-5: 30% (“other workers”) Shortage occupations, including nurses and physical therapists, exempt from worldwide and per-country numerical caps. Creates J-Stem visa; mirrors the new F-4 visa. F-4 and J-Stem are for students pursuing advanced degrees in a STEM field. F-4 and J-Stem visa holders can adjust status and both can secure three year employment authorization documents and advance parole documents without having to renew annually. Klasko, Rulon, Stock & Seltzer, LLP H-1B Visa Provisions Increases the H-1B cap from 65,000 to a more realistic 115,000 per fiscal year. Provides for a market-based cap escalator that takes effect in fiscal year after years in which U.S. employers have an increased need for more H-1B professionals. Creates an exemption from the overall H-1B cap for those foreign professionals who have earned a medical specialty certification through post-doctoral U.S. training and experience. Creates an exemption from the overall H-1B cap for those foreign professionals who have earned a U.S. master’s or higher degree. Extends current 20,000 cap exemption for those with U.S. advanced degrees to include those with advanced degrees (Master’s or higher) earned in foreign countries. Klasko, Rulon, Stock & Seltzer, LLP Employment Based (EB) Immigrant Visa Provisions Streamlines the adjudication process and provides for premium processing of EB visa petitions. Creates exemption from EB cap for foreign professionals who: Have earned a medical specialty certification through post-doctoral U.S. training and experience and those who have earned a U.S. master’s degree or higher Have earned a STEM master’s degree and have worked for 3 years in the U.S. Are outstanding researchers, professors, or professionals of extraordinary ability, or who hold a national interest waiver Will work in occupations designated by DOL as lacking sufficient U.S. worker that are able, willing and qualified to fill those positions. Authorizes extensions of stay for L-1 visa holders if a labor certification application or immigrant visa petition have been filed and pending for more than 365 days. Klasko, Rulon, Stock & Seltzer, LLP Title VI – Work Authorization & Legalization of Undocumented Individuals Provides three tier system for undocumented workers to earn a path towards citizenship. Klasko, Rulon, Stock & Seltzer, LLP Other House Passed Immigration Measures HR 6094, the Community Protection Act of 2006, passed in House on Sept. 21-allows for indefinite detention, expands expedited removal allows for AG to designate a group as a “gang” and making association with it cause for removal. HR 6095, Immigration Law Enforcement Act of 2006, passed in House on Sept. 21-giving state and local law enforcement option to enforce civil immigration law violations. Neither stand alone enforcement measure has been taken up by the Senate. Klasko, Rulon, Stock & Seltzer, LLP Bills Passed Containing Immigration Related Provisions DHS appropriations signed into law by the President on October 4, 2006 Funding for some border fence, real and virtual Delay of WHTI Pass card requirement June 1, 2009 Criminalization of Border Tunneling HR 6061 the Secure Fence Act (Senate passed this measure however President has not yet signed into law). Klasko, Rulon, Stock & Seltzer, LLP DHS Proposed Amendment to Employment Eligibility Verification (EEV) Regulation Lowers threshold of “constructive knowledge” by adding two more examples of information available to employer indicating employee not authorized to work in U.S. Receipt of SSA “no match” letter Receipt of “no match” notice from DHS Employer advising that immigrant status and employment authorization documentation presented by alien in completing Form I-9 was assigned to another person or not assigned to anyone. Klasko, Rulon, Stock & Seltzer, LLP DHS Proposed Amendment to Employment Eligibility Verification (EEV) Regulation (continued) Provides a “Safe Harbor” from DHS finding of “constructive knowledge” that employee is not authorized to work in the U.S. The 14-Day Safe Harbor Check records and take other action to obtain SSA verification within 14 days of receipt of “no match” letter or notice. The 60-Day Safe Harbor Reverify alien’s work authorization and identity in a limited I-9-like procedure completed in 3 days if discrepancy is unresolved within 60 days of receipt of “no match” letter or notice. Klasko, Rulon, Stock & Seltzer, LLP Amendment to (EEV) Regulation (cont.) Where discrepancy referred to in “no match” letter unresolved and employee’s identity and work authorization cannot be verified employer must choose between. Terminating employee Continuing to employ alien and face finding of violation of 8 USC§274A-unlawful employment of aliens. Klasko, Rulon, Stock & Seltzer, LLP Gazing into the Crystal Ball – IMPACT of 2006 Elections on Immigration Legislation Republicans Retain Control of Both Houses Lame Duck Session: CIR legislation will not pass, but there may be efforts to attach immigration-related riders onto unrelated bills including some good (H and EB Relief) and some bad (enforcement only). 110th Congress: future of CIR legislation will depend on which Republicans win (restrictionists or moderates) and by what overall margin. Likely result is renewed pursuit of enforcement only and unyeilding opposition to CIR, particularly as it relates to undocumented aliens. Klasko, Rulon, Stock & Seltzer, LLP Gazing into the Crystal Ball (cont.) Republicans retain Senate and Lose House Lame Duck Session: CIR legislation not likely to pass but there is a reasonable chance H and EB relief could pass. Republican leadership may try to pursue immigration – related enforcement only riders, but unlikely to gain passage in Senate. 110th Congress: Pro-immigration Democrats will move into leadership positions in House so there may be sufficient support in both Houses to pass CIR along the lines of S-2611. H and EB relief should pass either as part of S-2611 or in stand alone legislation. Klasko, Rulon, Stock & Seltzer, LLP Gazing into the Crystal Ball (cont.) Democrats Win both Houses Lame Duck Session: Scenario similar to Split of Houses above. 110th Congress: Immigration-related legislation including CIR will likely be more warmly received in both Houses, but because of complexity and passion it evokes, Democratic leadership in both Houses will be reluctant early on to push this issue. H and EB relief, however, should pass Klasko, Rulon, Stock & Seltzer, LLP Labor Certification Update For Hospitals, Universities and Research Organizations William A. Stock, Esq. Introduction Backlog Center Cases and “Conversion” PERM Processing Update Klasko, Rulon, Stock & Seltzer, LLP Backlog Center Processing Pulled all “Special Handling” Cases – but delays if they requested more documents Deadline for Completion: September 30, 2007 Progress So Far: Of about 360,000 pending, about 179,000 completed Of 179,000 completions, about 80,000 withdrawals Processing Dates RIR: Mostly 2003 TR: Mostly 2001 Klasko, Rulon, Stock & Seltzer, LLP Backlog Center Processing (continued) Making Sure Your Case Is At the Backlog Center case closures - no “45 day letter” response “No Contact” cases - nobeccontact@phi.dflc.us Case Disclosure system - www.pbls.doleta.gov/pbls_pds.cfm Erroneous New “Conversion” Regulation File RIR Documentation with request to treat case as RIR Documentation must be filed before recruitment instructions for TR are issued “Conversion” is not a PERM filing Klasko, Rulon, Stock & Seltzer, LLP PERM Filing Where there is a Backlogged Case “Refiling” with an “Identical” Case Keeps priority date of backlogged case Automatically withdraws backlogged case Only one chance New filing, whether identical or not Allows changes from prior case Does not affect backlogged case Case receives new priority date Klasko, Rulon, Stock & Seltzer, LLP Processing Time Improvement for “Clean” Cases 60 - 90 days for most cases Some in 30 days or less “Clean” Cases? Klasko, Rulon, Stock & Seltzer, LLP Relatively Few Audits At least of cases we file Many audits approved shortly after audit response “Audit Triggers” do not always trigger audits Klasko, Rulon, Stock & Seltzer, LLP PERM Current Issues The Health America Decision and What It Means The Problem: Typos or Errors on the Form The DOL Solution: Just Refile The BALCA Solution: Consider the Audit File on a Motion to Reconsider Klasko, Rulon, Stock & Seltzer, LLP PERM Current Issues (continued) Continuing PERM Bugaboos Prevailing Wage Delays and Timing Internal Electronic Posting Requirement Specificity of the Advertising “Employer Contact” Emails Closing SWA Job Orders Counting Days Klasko, Rulon, Stock & Seltzer, LLP PERM Policy Issues for Universities and Hospitals Which employees will be sponsored? Who will select the institution’s counsel? What quality control will be in place to ensure proper filing? How often will preemptive audits be conducted? Klasko, Rulon, Stock & Seltzer, LLP Questions ? Klasko, Rulon, Stock & Seltzer, LLP Options for the Best and Brightest Suzanne B. Seltzer, Esq. How does PERM compare with petitions that don’t require a labor certification? Klasko, Rulon, Stock & Seltzer, LLP What petitions do not require a labor certification? Aliens of Extraordinary Ability (EB-1) Outstanding Researchers (EB-1) Multinational Executive/Mangers (EB-1) National Interest Waivers (EB-2) Schedule A labor certifications (EB-2) Klasko, Rulon, Stock & Seltzer, LLP What’s the advantage of these non-labor cert petitions? Higher preference categories EB-1 EB-2 One less step in the LPR process Concurrent filing of adjustment Employment Authorization Document Advance Parole Klasko, Rulon, Stock & Seltzer, LLP What’s the advantage of these non-labor cert petitions? (continued) No advertising, no expense of advertising More flexibility in changing positions, possible that no job offer is required No prevailing wage requirement, except Schedule A Self sponsored or employer sponsored Easier to pursue more than one strategy Klasko, Rulon, Stock & Seltzer, LLP What’s the disadvantages to non-labor cert? Not everyone is extraordinary, exceptional, or in the national interest Subjective adjudication How are you going to get earliest priority date Klasko, Rulon, Stock & Seltzer, LLP In these situations, is PERM ever better? Special Handling labor cert Occupation in high demand i.e. - physician in shortage area Recruitment previously done Klasko, Rulon, Stock & Seltzer, LLP O-1 May be the Solution Klasko, Rulon, Stock & Seltzer, LLP What is the O-1? Non-immigrant visa for “aliens of extraordinary ability” No annual cap Initially approved for up to three years Can be extended indefinitely Klasko, Rulon, Stock & Seltzer, LLP When is O-1 the solution? H-1b quota is hit At end of 6 years on H On J status, subject to 212(e) Not eligible for H Klasko, Rulon, Stock & Seltzer, LLP Any concerns with the O-1? Does not waive two year home residency requirement Cannot travel on O-1 if adjustment of status is pending J’s cannot change to O, must consular process J-2 dependents changed to O-3, can no longer work Not everyone is extraordinary Klasko, Rulon, Stock & Seltzer, LLP Impact of Bi-Specialization Klasko, Rulon, Stock & Seltzer, LLP Service Centers 4 regional service centers California Service Center (CSC) Nebraska Service Center (NSC) Vermont Service Center (VSC) Texas Service Center (TSC) Klasko, Rulon, Stock & Seltzer, LLP Overview of Bi-Specialization New USCIS filing and adjudication system Workload divided between “Sister” pairings Non-immigrant petitions (I-129s) - Vermont All filed in Vermont (VSC) New Hs, TNs, E-3s adjudicated at VSC H COS or EOS, O-1s, E-1/2 at CSC Employment & California based Immigrant petitions (I-140s) Nebraska & Texas All filed in Nebraska (NSC) Split 50 - 50 with Texas Klasko, Rulon, Stock & Seltzer, LLP Confusion At Service Centers 4 different ways of doing things VSC is confused over licensure issues NSC is overwhelmed with I-140s Few cases are going to TSC CSC applying tougher standards on artist “O-1s” Problems Lack of training mailrooms overwhelmed Klasko, Rulon, Stock & Seltzer, LLP Anticipated Changes Geographical divide & Bi-Specialization Non-immigrant petitions previously filed with CSC and NSC will be filed at the CSC previously filed with VSC and TSC will be filed at the VSC Immigrant petitions and Adjustments of Status previously filed with CSC and NSC will be filed at NSC previously filed with VSC and TSC will be filed at TSC Klasko, Rulon, Stock & Seltzer, LLP Premium Processing EB-1 “B” Outstanding Professors and Researchers EB-2 Members of Professions with Advanced Degrees or Exceptional Ability, except for “National Interest Waivers” EB-3 skilled workers EB-3 professionals EB-3 “other workers” Klasko, Rulon, Stock & Seltzer, LLP Questions ? Klasko, Rulon, Stock & Seltzer, LLP Travel / Security Clearances H. Ronald Klasko, Esq. Who is at increased risk in traveling overseas? Klasko, Rulon, Stock & Seltzer, LLP Security Clearance Issues Prior visa delays Prior CIS adjudication delays Prior port of entry problems Country of birth/nationality Countries traveled to previously Criminal violations Possible Technology Alert List issues Common name Klasko, Rulon, Stock & Seltzer, LLP Immigration Issues Prior immigration violations 222(g) 3/10 year bar issues Prior visa denial or visa cancellation 214(b)/Dual intent issues Klasko, Rulon, Stock & Seltzer, LLP Immigration Issues (continued) Change of status in U.S. Pending change/extension of status OPT Fraud profile Short travel time Klasko, Rulon, Stock & Seltzer, LLP Travel to Canada / Mexico Automatic Revalidation 30 days or less Only if do not apply for visa Ineligible countries Applying for visa Choice of consul Need for Canadian visa Problem cases Nationality-specific issues Klasko, Rulon, Stock & Seltzer, LLP Travel to Canada / Mexico (continued) Reentry if visa denial No automatic revalidation Travel with still-valid visa Travel with B-visa C (transit) visa Other options Klasko, Rulon, Stock & Seltzer, LLP Avoiding/Dealing with Overseas Delays Avoiding Delays Travel before visa expiration Visa in Canada or Mexico Advance parole Dealing with Delays Visa Office inquiries Congressional help Correcting database Klasko, Rulon, Stock & Seltzer, LLP Port of Entry Issues I-94 errors Repetitive delays/correcting database US VISIT NSEERS Pending change/extension of status Klasko, Rulon, Stock & Seltzer, LLP Security Clearance Delays in CIS Adjudications CIS inquiries/expedite requests Congressional Mandamus Klasko, Rulon, Stock & Seltzer, LLP help Questions ? Klasko, Rulon, Stock & Seltzer, LLP Contact Information H. Ronald Klasko, Esq. William A. Stock, Esq. Tele: 215.825.8608 Tele: 215.825.8607 Fax: 215.825.8699 Fax: 215.825.8699 E-mail: rklasko@klaskolaw.com E-mail: wstock@klaskolaw.com Richard R. Rulon, Esq. Suzanne B. Seltzer, Esq. Tele: 215.825.8612 Tele: 212.796.8846 Fax: 215.825.8699 Fax: 212.297.1799 E-mail: rrulon@klaskolaw.com E-mail: sseltzer@klaskolaw.com Klasko, Rulon, Stock & Seltzer, LLP