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Case 1:09-cv-02676-CMA-MJW Document 360 Filed 11/01/13 USDC Colorado Page 1 of 15

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No.: 09-cv-02676-CMA-MJW SECURITIES AND EXCHANGE COMMISSION, Plaintiff v. MANTRIA CORPORATION, TROY B. WRAGG, AMANDA E. KNORR, SPEED OF WEALTH, LLC, WAYDE M. MCKELVY, and DONNA M. MCKELVY, Defendants. ______________________________________________________________________ INTERESTED PARTY, MANTRIA INVESTOR CLASS PLAINTIFFS, MOTION FOR A COURT CONFERENCE PURSUANT TO FED. R. CIV. P. 16(a)(5) ______________________________________________________________________ PLEASE TAKE NOTICE that Interested Party Mantrias Investor Class Plaintiffs by and through their undersigned counsel, court-appointed Class Counsel,1 move this Court for an Order scheduling a Fed. R. Civ. P. 16(a)(5) Conference with Investors Class Counsel and the Court-appointed Receiver, John Paul Anderson2 to address the proposed settlement between Mantrias investors, Mantrias former CFO, Daniel J. Rink, and Tatum, LLC, and the Receiverships position.
On May 15, 2013, the Court overseeing the investors class action appointed named Plaintiff Touchstone Group, LLC as lead plaintiff pursuant to 15 U.S.C. 78u-4(a)(3)(B) and the law firms of Saltz, Mongeluzzi, Barrett & Bendesky, P.C. and Hagens Berman Sobol & Shapiro LLP as Class Counsel pursuant to 15 U.S.C. 78u-4(a)(3)(B)(v). Touchstone Group, LLC, v. Rink, et al., Case No., 11-cv-02971-WYD-KMT (ECF No. 152).
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The Receiver is represented by Peter J. Korneffel, Jr. and Kathryn DeBord of Bryan Cave, LLP. References to the Receiver in this motion are intended to include discussions and exchanges with both John Paul Anderson and his counsel.
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PLEASE TAKE FURTHER NOTICE that prior to filing this motion, and in compliance with D.C.COLO.L.Civ.R. 7.1(A), Class Counsel conferred with both the SEC and Receiver. The SEC takes no position and the Receiver opposes the requested relief. INTRODUCTION It has been nearly four years since the SEC uncovered the Mantria Ponzi scheme which cost its investors many retirees or elderly - more than $37 million.3 On September 20, 2011, this Court lifted the stay of litigation so the investors could pursue those secondary actors who either aided or were complicit in the scheme. And within weeks of that order, on November 15, 2011, the investors filed a class action complaint against Mantrias financial advisors, lawyers and accountants. Since then, Class Counsel has worked to obtain a recovery for the investors. On October 25, 2013, following several weeks of nearly daily negotiation, the agreed upon mediator the Honorable Richard Dana (Ret.) made a mediators proposal to Class Counsel, defense counsel, and the defendants insurance coverage counsel, for resolution of the investors claims against Mantrias former CFO, Daniel J. Rink, and Tatum LLC the largest potential source of any recovery. That resolution, however, requires the Receiver participating in the settlement and releasing his claims against both Rink and Tatum. Class Counsel through Judge Dana made proposals to the

The investors are the largest creditor of Mantria with more than $37 million in losses. The remaining creditors the general creditors and employees make up less than $3 million in losses, or 7.2% of the total. Pursuant to the Receivers reports filed with
this Court including the deductions for the released creditor claims per Paragraph 6.4 of August 2013 Settlement Agreement and deductions for creditor claims made by Receivership entities (Carbon Diversion / Carbon Diversion loans), the division of losses is as follows: investors: $37,031,035; creditors: $2,547,985; employees: $398,324.
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Receiver to add to the $583,000 in the estate from the settlement proceeds. As it stands, the Receiver will not agree to the mediators proposal, and as the agent of this Court, is standing between a potential settlement that will bring a significant return to the victims of an empty Ponzi scheme. Time is of the essence. Litigation deadlines and rapidly rising costs for all parties are looming in the investors case. The class action has a court ordered deadline of November 20, 2013, for all parties to complete their production of electronically stored information; an endeavor that could prove to be significantly costly for both parties. Rink and Tatum would like to resolve the matter but for good reason will not do so without a global release. And unfortunately, this is not the first time the Receiver has refused a settlement. Last time it cost at least $100,000; Class Counsel fears this time it could cost substantial more. Class Counsel respectfully requests this Court exercise its extremely broad power to supervise an equity receivership and schedule a Rule 16(a)(5) Conference as soon as possible to address the Receiverships position on the proposed settlement in an effort to reach a resolution. See SEC v. Capital Consultants, LLC, 397 F.3d 733, 738 (9th Cir. 2005)(district court's power to supervise an equity receivership and to determine the appropriate action to be taken in the administration of the receivership is extremely broad.). BACKGROUND A. The SEC and the Court-Appointed Equity Receiver As part of the SECs enforcement action against Mantria, the Court appointed John Paul Anderson, CPA, CFA, of Alvarez & Marsal as an equity receiver for the

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purpose of marshaling and preserving assets of the Defendants Mantria Corporation and Speed of Wealth, LLC. Id. (ECF No. 82). On September 13, 2011, the SEC - on behalf of the Mantria investors - petitioned this Court to modify the Receivership Order and lift any intended (or unintended) stay of third-party litigation. Id., (ECF No. 216). During a hearing on the motion, this Court noted that it never, in any way, intended to preclude the investors from proceeding [with litigation] against third parties [to recover their losses]. (ECF No. 220, Tr., 9/20/11, at 9:14-16). Without objection from the Receiver, the Court then modified the Receivership Order to allow the investors to proceed with their claims. (ECF No. 223); see also Liberte Capital Group, LLC v. Capwill, 248 Fed. Appx. 650, 658 (6th Cir. 2007) (fraud on investors that damages those investors is for those investors to pursue- not the receiver.).4 (citations and internal quotations omitted). The Receiver has filed twelve quarterly reports with this Court per the Receivership Order. (ECF No, 82, 53). In those reports, the Receiver has repeatedly recognized that any significant recovery for the victims of the Ponzi scheme will come through litigation. (ECF No. 252-1). The Receiver has also reported that any distribution plan from the Receivership Estate will take into account settlements / awards that may be realized [by the investors in] the Investors class action litigation. (ECF Nos. 345-1, 335-1; 326-1). At its inception, the Receivership Estate had $720,000 in cash; largely all investors money. (ECF No. 108-1, at 184). After the sale of some assets and the
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The proposition that the Receiver has no authority to bring a cause of action on behalf of the individual investors is replete in federal appellate case law. See, e.g., Goodman v. F.C.C., 182 F.3d 987, 991 (D.C. Cir. 1999); Troelstrup v. Index Futures Group, Inc., 130 F.3d 1274, 1277 (7th Cir. 1997); Miller v. Harding, 2000 WL 1792990, at *2 (1st Cir. Dec. 5, 2000).

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Receivers first bill ($88,459.88) the estate was at its height in November 2010 with $761,000.5 (ECF No. 126). As of July 30, 2013, the estate has $583,000 in cash on hand and no real potential for more, other than a recovery from the litigation. (ECF No. 345-1). On May 2, 2011, the Receivership Estate reported credit claims totaling $4.269 million, which in his report the Receiver emphasized that some of these claims are litigation claims that the Receiver may contest and the final claimed amount may differ significantly from this figure. (ECF No. 193-1). After settlements with certain defendants who asserted creditor claims and deductions for creditor claims made by Receivership entities (Carbon Diversion / Carbon Diversion loans), the creditor claims now total approximately $2.547 million. Finally, the Receivership Estate has been, and remains, faced with significant tax issues from both federal and state taxing authorities. (ECF No. 126 -1, 345-1, at 10). B. The Investors Class Action and Receivers Third-Party Litigation 1. Investors Litigation On November 15, 2011, Touchstone Group filed a class action complaint in the District of Colorado on behalf of the defrauded investors against Mantrias financial advisors (Tatum, LLC/ Daniel J. Rink), Mantrias attorneys (Astor, Weiss / Estill & Long) and Mantrias accountants (Krassenstein, Granoff). Touchstone Group, LLC, Case No., 11-cv-02971-WYD-KMT (ECF No. 1). The complaint asserted claims under the federal
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This Court held a status conference on December 13, 2010, to discuss whether the Receivers counsel, Mr. Korneffel and Ms. Debord were appropriately retained by the Receiver as well as the concerns of the SEC about the value of the receivership estate. Afterward, both the Receiver and his counsel were instructed by the Court to limit the scope of their work in order to preserve assets. ( See ECF Nos. 140, 156-1, 193-1). 5

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Securities Exchange Act, state securities laws, common law negligent misrepresentation and unjust enrichment. All of the defendants (with the exception of one) moved to dismiss the Complaint for lack of personal jurisdiction and failure to state a claim under Fed. R. Civ. P. 12(b)(2) and (6). On December 21, 2012, the district court overseeing the investors class action granted-in-part and denied-part the defendants motions to dismiss. Id. (ECF No. 127). Although the Court found it had personal jurisdiction over Defendant Rink due to nationwide service of process under the Securities Exchange Act, the Court dismissed Mantrias Pennsylvania based lawyers (Astor, Weiss) and Mantrias Pennsylvania based accountants (Krassenstein, Granoff) for lack of personal jurisdiction under Colorados long-arm statute. Id. at 11. The Court, however, denied Defendants Rink and Tatums motions to dismiss nearly in-total. Id. (dismissing only the claim for unjust enrichment). Class Counsel re-filed the investors claims against Astor, Weiss in Philadelphia Common Pleas Court on January 4, 2013. See Greenspan, et al. v. Astor, Weiss, Kaplan & Mandel, LLP, Case No. 121204284-2013 (Phl. Cty. Jan. 4, 2013). And although dismissed, Mantrias accountants agreed to honor an earlier commitment to settle. Since the filing of the class action complaint, Class Counsel has diligently pursued the litigation on behalf of the investors. As the Receiver reported to this Court in April 2012 while faced with the defendants efforts to have the investors claims dismissed and a mandatory discovery stay imposed by the PSLRA6 - Class Counsel

See 15 U.S.C. 78u-4(b)(3)(B)(in any private action arising under [the Securities Exchange Act], all discovery and other proceedings shall be stayed during the pendency of any
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reviewed hundreds of Mantria documents housed in a Northwest Philadelphia storage unit. (See ECF No. 276-1). And in both May and June 2012, Class Counsel traveled to Denver to review and catalog more than 60 boxes of documents obtained from Mantria and housed in the Receivers office. In early-December 2012, Class Counsel incurred significant expense (more than $15,000) to have the Mantria hard drives converted to a useable format and loaded onto a secure website for review. After that, Class Counsel completed a review of the more than 200,000 Mantria documents and emails housed on the drive. Once the defendants motions were largely denied, Class Counsel negotiated with the defendants for a protocol for the production of electronically stored information, including identifying document custodians by using Tatums organizational charts and preparing search terms for the data. Touchstone Group, LLC, Case No., 11-cv-02971WYD-KMT (ECF No.167 ). Class Counsel also reached terms on a protective order to govern the litigation. Id. (ECF No.177). Afterward, Class Counsel sought and obtained document productions, including electronically stored information, from both Tatum and Rink. And as recently as October 25, 2013, Class Counsel served additional discovery on both Rink and Tatum. At the time the parties requested a stay of the litigation on August 8, 2013, to pursue mediation, Class Counsel had retained three separate expert witnesses to support class certification and was prepared to serve those expert reports and the opening class certification brief on September 6, 2013, as ordered by the Court. Id. (ECF No. 163, 178).

motion to dismiss)
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2. Receivers Third-Party Litigation The Receiver filed his own action in the District of Colorado on February 25, 2012, against nearly the same defendants named in the investors complaint.7 See Anderson v. Rink, et al., Case No., 12-CV-00488-RM (D. Colo.)(ECF No. 1). The Complaint asserts claims on behalf of Mantria for legal malpractice, breach of fiduciary duty, aiding and abetting breach of a fiduciary duty, negligence, breach of contract, and unjust enrichment. See Scholes v. Lehmann, 56 F.3d 750, 753 (7th Cir. 1995)(it is well settled that a receiver has no greater rights or powers than the corporation the receiver steps in the shoes of would have). All of the defendants moved to dismiss the Complaint for lack of personal jurisdiction and failure to state a claim. In addition, the Receivers claims against Tatum were subject to an arbitration agreement, which Tatum moved to enforce on April 5, 2012. Id. (ECF No. 18). On May 31, 2012, the Receiver and Tatum stipulated to a stay of the litigation and agreed to proceed with arbitration. Id. (ECF No. 54). Although the court overseeing the Receivers litigation had not ruled on the substance of the defendants motions, on February 22, 2013, the court set an evidentiary hearing for March 29, 2013, and ordered the parties to present evidence and argument concerning jurisdiction, including the distinction, if any, that exists with respect to Judge Daniels decision in the investor class action dismissing certain defendants for lack of personal jurisdiction under Colorados long-arm statute. Id. (ECF No. 83)(emphasis added).

Notably, the Receivers Action did not assert any claw black claims under state fraudulent transfers laws against any of the defendants or net winners from the scheme. The Receiver also did not assert claims against Estill & Long, LLC or Tracs Growth Investment.
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To date, that evidentiary hearing is yet to occur because since April 11, 2013, the Receivers litigation has been stayed. Id. (ECF No. 89, 98)(stay expires November 25, 2013). This stay was granted, in part, on the Receivers representation to the Court that a settlement with Rink would be reached within two weeks of April 11. Id. (ECF No. 88). And although the Receivers arbitration with Tatum is advancing, the arbitration agreement includes a damages cap that limits any recovery to the Receivership to actual fees paid by [Mantria] to Tatum over the previous one year of the agreement. Ex. A (Tatum Consulting Interim Services Agreement with Mantria, August 27, 2013). The arbitrator has set a pre-hearing for November 5, 2013, to address the applicability of the damages cap, the Receivers standing to assert certain claims, and Tatums affirmative defense of in pari delicto. See In re Hedged-Investments Assocs., 84 F.3d 1281, 1284 (10th Cir. Colo. 1996)(in pari delicto is the affirmative defense against one who has himself participated in a violation of law cannot be permitted to assert in a court of justice any right founded upon or growing out of the illegal transaction.). C. The Investors and Receivers December 1 Agreement While the defendants motions to dismiss were pending in both actions, and following an initial joint mediation session with all parties before Judge Dana on November 1, 2012, the Receiver and Class Counsel reached an agreement on December 1, 2012, for the division of settlement proceeds between the respective litigations. See Ex. B (Nov. 30 Dec. 3, 2013, Email Exchange Memorializing Agreement). In sum, the agreement contemplates that at Class Counsels request the Receiver would dismiss his claims against defendants Daniel J. Rink, Tatum, LLC, and Krassenstein, Granoff, in exchange for a larger percentage share from any

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settlement proceeds recovered from defendant, Astor, Weiss. See id. On December 3, 2012, the Receiver notified Judge Dana of the agreement in writing and granted Class Counsel his authority to negotiate a global settlement with Astor, Weiss. Id. After consummating the agreement and issuing an initial demand to Astor, Weiss of $2.5 million to resolve both actions, Class Counsel reached a settlement with Mantrias accountants, Krassenstein, Granoff on December 21, 2012 for their entire insurance proceeds, $100,000. Class Counsel requested the Receiver execute the memorandum of understanding, which contemplated the Receivers dismissal per the December 1 Agreement. The Receiver refused; and on February 11, 2012, advised that he would no longer honor the terms of the December 1, 2012, Agreement. Prior to that, however, after independent research and a discussion with both Astor, Weisss counsel and Judge Dana it became evident that Astor, Weiss did not have the insurance proceeds or tangible assets to withstand a large judgment. As of December 19, 2012, Astor, Weisss $1 million self -depleting insurance policy had less than $850,000 available; nonetheless, Astor, Weiss made a global settlement offer to Class Counsel for $850,000. Class Counsel notified the Receiver both via telephone message and email on December 21, 2011, and suggested that - based on the limited assets and insurance proceeds available - the parties should counter at $1 million. Ex. C (Dec. 21, 2011 Email from Patrick Howard, Esquire to Receiver). The Receiver did not respond. On January 2, 2013, the Receiver suggested that continued litigation against Astor, Weiss could yield a higher settlement of $1.5 $1.75 million, despite the selfdepleting nature of the Astor, Weiss insurance policy. See Ex D (Feb. 14, 2013, Patrick

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Howard Ltr. to Receiver). Class Counsel wrote to the Receiver to advise that they disapproved of this settlement strategy based on their investigation of Astor, Weisss available insurance and personal tangible assets. Id. Nonetheless, the Receiver proceeded with litigation against Astor, Weiss. After the Court overseeing the Receivers litigation issued its order of February 22, 2013, setting an evidentiary hearing on jurisdiction for March 29, 2013, the Receiver contacted Class Counsel and suggested that now was the time to settle with Astor, Weiss. See Anderson, Case No., 12-CV-00488-RM (D. Colo.)(ECF No. 83). At this point however, Astor, Weiss had less than $750,000 of available insurance proceeds. Ultimately, a global settlement was reached for $750,000 on April 5, 2013, $100, 000 less than was offered months earlier. As part of both settlements, Class Counsel and the Receiver agreed that the proceeds could be paid into escrow until a determination was made on the enforceability of the December 1 Agreement. See Touchstone Group, LLC, Case No. 11-cv-02971-WYD-KMT (ECF No. 188)(motion for preliminary approval attaching joint settlement agreement). The December 1 Agreement is presently subject of a motion to enforce pending before the district court overseeing the class action. Id. (ECF No. 191). If the Court rules the December 1 Agreement is enforceable, the Receiver will be required to dismiss his claims, with prejudice, against both Rink and Tatum. See id. D. The Proposed Settlement With Rink and Tatum On September 23-24, 2013, Class Counsel, the Receiver, Rink, Tatum, and their respective insurance carriers and coverage counsel attended a second two-day joint mediation session before Judge Dana in New York City. The parties did not reach a

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resolution and the litigation stay of the class action expired on October 15, 2013. However, Judge Dana continued with vigorous negotiation, and ultimately on October 25, 2013, made a mediators proposal to Class Counsel, Tatum, Rink, and their insurance carriers to resolve the matter. With certain litigation deadlines approaching in the investors class action, including Court ordered final electronic discovery production dates for all parties (November 20, 2013) and a motion for class certification and accompanying expert reports (December 20, 2013), in an effort to preserve a potential settlement for Mantrias investors, Class Counsel respectfully requests the Court schedule a Fed. R. Civ. P. 16(a)(5) Conference as soon as possible to address the Receivership estates demands. Id. (ECF No. 187). ARGUMENT Class Counsel seeks an order from this Court scheduling a Rule 16(a)(5) conference. Fed. R. Civ. P. 16(a)(5) provides the court with authority to order the parties to appear for a conference to discuss settlement of [a] case. Hill v. City of Aurora, 2011 WL 1465591, *5 (D. Colo. April 15, 2011). And this Court has extremely broad power to supervise an equity receivership and to determine the appropriate action to be taken in the administration of the receivership." Capital Consultants, LLC, 397 F.3d at 738 (quoting SEC v. Hardy, 803 F.2d 1034, 1037 (9th Cir. 1986)). The Courts discretion is wide in determining the appropriate relief in an equity receivership." SEC v. Lincoln Thrift Ass'n, 577 F.2d 600, 606 (9th Cir. 1978). Both the investors and the Receiver filed third-party litigation against nearly identical defendants. See Johnson v. Chilcott, 590 F. Supp. 204, 207-208 (D. Colo.

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1984) (disallowing receiver's standing to assert investors' claims when corporate interests not congruent with investors' interests). Initially, the parties recognized potential complications in dividing any settlement proceeds, and therefore, reached a written agreement for that division. See Ex. B. Within months, and after Class Counsel negotiated the first settlement in either litigation and the district court denied the defendants motions to dismiss the class action complaint, the Receiver refused to honor the agreement, which is presently the subject of a motion to enforce pending in the class action. Now, the agreed upon mediator has made a proposal to resolve all litigation with the final two common defendants (Rink and Tatum). However, that proposal for good reason- will require a global release. In his reports to the Court, the Receiver has repeatedly recognized that any significant recovery for the victims will come through litigation. (ECF No. 252-1). And over the past year, the Receivers reports have contemplated that any distribution plan for the estate will take into account settlements / awards that may be realized [by the investors in] the Investors class action litigation. (ECF Nos. 345-1, 335-1; 326-1). In other words, the Receiver expects to apply a set-off from the estate to any monies recovered by the investors in the class action. The Receivership Estate also has approximately $583,000 in cash on hand. (ECF No. 345-1). Class Counsel has made offers to the Receiver for the release of claims against Rink (which has been stayed since April 2013) and Tatum. For reasons that remain unclear to Class Counsel, the parties have been unable to reach a resolution. With the Receivers proposed set-off from the class action and more than a half-

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of-million dollars on hand to satisfy the creditor and employee losses, Class Counsel is at a loss to understand the Receivers refusal to participate in this proposed settlement. See Liberte Capital Group, LLC, 462 F.3d at 551([t]he receivers role, and the district courts purpose in the appointment, is to safeguard the disputed assets, administer the property as suitable and to assist the district court in achieving a final, equitable distribution of the assets if necessary.) Class Counsel respectfully requests the Court use its broad power to supervise an equity receivership and to determine the appropriate action to be taken in the administration of the receivership and schedule a Rule 16(a)(5) Conference where the proposed settlement can be discussed. CONCLUSION For the reasons stated above, Class Counsel respectfully requests the Court set a Rule 16(a)(5) Conference between all of the parties in an effort to reach a just, speedy, and inexpensive resolution of these matters. Fed. R. Civ. P. 1. Respectfully submitted this 1st day of November, 2013, By: s/Patrick Howard Simon B. Paris Patrick Howard SALTZ, MONGELUZZI, BARRETT & BENDESKY, P.C. One Liberty Place, 52nd Floor 1650 Market Street Philadelphia, PA 19103 sparis@smbb.com phoward@smbb.com (215) 575-3985 By: s/ Anthony D. Shapiro Anthony D. Shapiro Karl P. Barth HAGENS BERMAN SOBOL SHAPIRO LLP 1918 Eighth Avenue, Suite 3300 Seattle, WA 98101 tony@hbsslaw.com karl@hbsslaw.com (206) 623-7292

Investors Class Counsel

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CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on November 1, 2013, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following email addresses: Julie K. Lutz lutzj@sec.gov Thomas J. Krysa krysat@sec.gov Dugan William Bliss blissd@sec.gov John Paul Anderson Katie.Debord@bryancave.com Peter Korneffel Peter.Korneffel@btyancave.com Kathryn Reed DeBord Katie.Debord@bryancave.com

Dated: November 1, 2013

By:

s/Patrick Howard Patrick Howard SALTZ, MONGELUZZI, BARRETT & BENDESKY, P.C. One Liberty Place, 52nd Floor 1650 Market Street Philadelphia, PA 19103

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