Hospital

“I want to file medical bankruptcy.”  I get that phone call a lot.  The situation is that many people are current on their house, car and credit card payments, but they were hit by a wave of medical bills and just want to file bankruptcy on those debts.  Can a person just file bankruptcy on medical debts?  Is there such a thing as medical bankruptcy?

Technically, there is no such thing in the law as medical bankruptcy, and there is no way to file bankruptcy by only listing medical debts.  When you file bankruptcy all debts are listed.  In fact, when somebody files bankruptcy they sign a sworn statement that says, under penalties of perjury, that they have listed ALL their debts.

When someone says they filed medical bankruptcy what they mean is that they filed not because of irresponsible spending but because of something beyond their ability to control–their health.  You hear the term medical bankruptcy a lot for good reason.

NerdWallet estimates for 2013:

  • 56M Americans under age 65 will have trouble paying medical bills
    – Over 35M American adults (ages 19-64) will be contacted by collections agencies for unpaid medical bills
    – Nearly 17M American adults (ages 19-64) will receive a lower credit rating on account of their high medical bills
    – Over 15M American adults (ages 19-64) will use up all their savings to pay medical bills
    – Over 11M American adults (ages 19-64) will take on credit card debt to pay off their hospital bills
    – Nearly 10M American adults (ages 19-64) will be unable to pay for basic necessities like rent, food, and heat due to their medical bills
  • Over 16M children live in households struggling with medical bills
  • Despite having year-round insurance coverage, 10M insured Americans ages 19-64 will face bills they are unable to pay
  • 1.7M Americans live in households that will declare bankruptcy due to their inability to pay their medical bills
    – Three states will account for over one-quarter of those living in medical-related bankruptcy: California (248,002), Illinois (113,524), and Florida (99,780)
  • To save costs, over 25M adults (ages 19-64) will not take their prescription drugs as indicated, including skipping doses, taking less medicine than prescribed or delaying a refill

“Medical Bankruptcy” is really Chapter 7 or Chapter 13 Bankruptcy.

When someone says they filed medical bankruptcy they really mean to say they filed Chapter 7 or Chapter 13 bankruptcy.  All debts must be listed, even the ones you want to keep, such as auto and mortgage debts.  However, this is not really a big problem you can sign Reaffirmation Agreement in Chapter 7 cases to keep and revive the debts you want to keep.  A Reaffirmation Agreement basically pulls a debt out of the bankruptcy case so that you can keep the car, home, etc, and continue the benefit of getting positive credit reporting.

Ongoing Medical Bills: The benefit of Chapter 13 cases.

I meet many clients who suffer from ongoing medical problems. Even if they file Chapter 7 today to wipe out the medical bills, in six months they are right back where the started with new medical debts.  They may lack health insurance or the insurance they have contains loopholes that don’t cover certain medical treatments.  Such individuals may benefit from the extended protection of Chapter 13.  Chapter 13 cases can be open from 3 to 5 years and may eventually be converted to Chapter 7 to add new medical bills that accrued during the bankruptcy.  While a person is in Chapter 13 creditors may not garnish paychecks or bank accounts.  In some ways, Chapter 13 is something of a drastic form of health insurance.

Image courtesy of  Flickr and Scott Kless.

Help

A recent client asked this great question:

Is there such a thing as getting help to avoid bankruptcy? My wife and I have a small business.  We are struggling to keep it going.  We’re down over 50% this year, we’ve cut some expenses, and customer payments are dragging.  While we are not unique, and I am sure you have heard it before, but we would like to avoid drowning. Please let us know if you would be available/interested in a consult.

The short answer is YES!  We help people avoid bankruptcy every day.  Filing bankruptcy is something you do when nothing else works.  It is the last option.  The process of deciding to file bankruptcy is really a process of elimination–when no other option solves the entire debt problem you then focus on bankruptcy.  Partial solutions are no help.  Settling one debt or one lawsuit is nice, but if it does not solve the whole problem it is just throwing money away.  The benefit of bankruptcy is that it is a complete solution.

So how do we help clients avoid bankruptcy?

DEBT PAYMENT PLANS.

How much does it cost per month to get out of debt?  You must answer that question before you consider bankruptcy. This is a two-step process:

STEP ONE: List the debts.  Making a list of your debts is about as much fun as getting on a scale after going out for dinner.  There comes a time when you stop opening the mail and lose track of how much you owe.  It’s depressing so you avoid it.  If you really want to avoid bankruptcy you need to write down a list of who you.  Follow these steps to prepare a list.

  • Open the mail.  Stop throwing away collection letters.  Go through the pile of envelopes pushed to the corner.  Sort the debts, put them in separate files, use color-coded three ring binders, etc.  Do whatever it takes, but organize what you have.
  • Get a credit report.  Go to www.AnnualCreditReport.com for a free copy of your credit report.
  • Search for lawsuits and judgments online in Nebraska.  Here is an article to help search the public records online.
  • Some debts do not appear on credit reports.  Just write the Name and Address of your creditors and estimate the amount you owe each.
  • Call creditors to figure out the balance owed.
  • Locate student loans using the National Student Loan Data System.
  • Write the interest rate charged by each creditor next to the balance owed.
  • Divide the list into Secured creditors (mortgage auto, furniture loans) and Unsecured creditors (everybody else).

STEP TWO:

  • Add up the list.  How much do you owe in total?
  • Divide the total by 36.  Can you afford that payment?  For example, if you owe $18,000 of debt, can you afford to pay $500 per month?  This is a rough estimate of what you need to pay each month to become debt free.  Call it the “Rule of 36”.
  • Consider a debt management company such as GreenPath to set up a debt payment plan.  I prefer counselors belonging to the National Foundation for Credit Counseling.

DEBT SETTLEMENT.

Most of the people in debt settlement programs should not be in them.  Most of the debt settlement plans I review have virtually no chance of succeeding.  Why?  You need money on hand to settle debts.  If you cannot raise enough settlement funds quickly enough the creditors will file lawsuits and begin garnishments before you can settle all the debts.  As a general rule, you need about one-third of what you owe in cash within 6 months of stopping payments to creditors to have any chance of settling all the debts.  Creditors will typically settle debts for about 40% of what is owed, but they want the settlement in cash now.  If you are able to raise cash quickly debt settlement might be an option.  We help clients settle credit cards and other debts every day, but only if we see a reasonable chance of all accounts being settled.

LAWSUIT DEFENSE.

Can the creditor prove you owe the debt?  Has the Statute of of Limitations expired?  Can the creditor provide a copy of the credit card agreement?  Are you being sued for a medical debt that your health insurance should have covered?  Over 90% of creditor lawsuits result in Default Judgments.  We can show you how to respond to lawsuits and to demand an accurate accounting of the debt.

BUSINESS REORGANIZATION.

Sometimes a small business is so overcome by debt that it must reorganize.  Some small business corporations are so saturated with debt that it must start over.  It is possible to form a new corporation and start with a clean slate.  There are special rules to follow to prevent the old corporation from contaminating the new company, but this is a valid strategy to reorganize without filing bankruptcy.  Personal guarantees of business debts must be considered as well.

The bottom line is, there are many ways out of debt.  You need to consult with an attorney that carefully goes through each option.  That is what we do.  We can help you avoid filing bankruptcy if you visit with us before the situation gets out of hand.

 

 

 

 

 

 

Image courtesy of Flickr and David J. Dalley.

Student Loan

Private Student Loans are the single worst debt in existence.  They lack any formal Income Based Repayment (“IBR”) plans and the debts are generally not discharged in bankruptcy without undergoing expensive litigation and claiming a special hardship.  In recent years, the National Collegiate Student Loan Trust, the largest holder of private student loans, has filed thousands of lawsuits against delinquent borrowers, and I count several hundred such lawsuits filed in Nebraska.

National Collegiate lawsuits are really no different than a basic credit card case, and they suffer many of the same problems:

Trusts Lack Capacity to Sue in Nebraska.

As a general rule, a trust is not a legal entity and lacks the ability to sue or be sued.  Rather, the lawsuit should be brought in the name of the Trustee.  (See Black Acres Pure Trust v. Fahnlander, 233 Neb. 28 (1989)).  The Uniform Law Commission has written extensively on this issue and has proposed a uniform law to create “statutory trusts” that would enjoy the same rights given to corporations to sue or be sued.

A common-law trust arises from a private action without the involvement of a public official. Because a common-law trust is not a juridical entity, it must sue, be sued, and transact in the name of the trustee and in the trustee’s capacity as such. By contrast, a statutory trust is a juridical entity, separate from its trustees and beneficial owners. It has the capacity to sue, be sued and transact on its own.”  Uniform Law Commission.

So, is National Collegiate a “common-law” trust or a “statutory” trust?  Does that distinction make a difference in Nebraska?  National Collegiate is organized as a Delaware trust agreement and that state does provide for statutory trusts empowered to sue.  There are arguments to be made both ways, but until the courts rule on this issue, the first defense to these lawsuits is to file a motion to dismiss.

National Collegiate Must Show They Own the Loan.

You did not borrow money from National Collegiate.  Most likely the loan originated from JPMorgan Chase or Bank of American or Charter West Bank.  The loan was then assigned several times and eventually wound up in one of the several trust pools managed by National Collegiate.  It is essential that National Collegiate be required to provide the “chain of assignment” showing how your loan was specifically assigned from the original lender to the National Collegiate Trust.  Failure to prove the entire chain of assignment means the lawsuit must be dismissed for lack of standing.

Statute of Limitations.

In Nebraska, lawsuits filed for breach of a written promissory note must be filed within five (5) years of the date of last payment or from an acknowledgement of the debt.  It is important to demand an account payment history from National Collegiate to verify the date of last payment.  Very often the records of National Collegiate are sketchy at best and they seem to struggle to provide detailed account statements. If they do assert a payment was made in the preceding 5 years, research your bank statements to see if their record of payment matches your records.

Did a Prior Bankruptcy Case Discharge Some of the Student Loan?

Have you filed bankruptcy before?  If so you may have discharged some of the National Collegiate obligation already.  Although Federal Student Loans are not discharged in bankruptcy (unless you receive a Hardship Discharge), when it comes to Private Student Loans only the amount qualified under Section 221(d)(1) of the Internal Revenue Code is excepted from discharge.  I have seen cases where loans were made for $30,000 per year when the actual cost of attending the college, including tuition, books, room and board and transportation expenses, was only $10,000 per year.  Also, only loans to a qualified educational institution are protected.  National Collegiate often sues for debts that have been partially or entirely discharged.

Statute of Limitations are not Tolled During a Chapter 13 Case in Nebraska.

If you can go five years without making a payment or requesting a loan deferment, the Nebraska statute of limitations may apply.  (See National Bank of Commerce v Ham, 256 Neb. 679 (1999)).,  The 5 year limit must run prior to the commencement of the lawsuit and you must affirmative claim this defense in the written answer filed with the court.  If you sense that you are about to be sued by National Collegiate, consider filing Chapter 13 to run out the SOL clock.

Negotiate the Debt.

National Collegiate is willing to cut a deal.  Even if they are successful in obtaining a judgment, they still have the burden of collecting the debt.  The fact that they have initiated a lawsuit means that they probably have not received any payment in years.  I have represented clients who were able to settle $150,000 of loans for $30,000.  Each case is unique, but National Collegiate is willing to consider reasonable settlement offers.

Image courtesy of Flickr and Occupy* Posters.

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It seems like a lot of people are shocked to learn that they have been sued or that judgments have been registered against them.  I remember speaking to a new client recently and it was unclear how much she owed and from what she was saying her total debts were less than $5,000, an amount clearly not worth filing bankruptcy over.  While we were talking I checked the Nebraska court’s online records to see if any judgments were filed against her, and to her great surprise a $30,000 judgment lien had been filed against her residence!  Needless to say, she and her hubby had a fun chat that evening.

When debt problems get bad, sometimes we stop opening the mail. People move from town to town seeking better jobs, housing or schools, and it is common for creditors to serve notice of lawsuits on former addresses.  One client was shocked when I informed her a judgment had been issued against her after the Sheriff served notice on her 10-year old daughter who forgot to give her mother the paperwork when she arrived home for work.  Clients commonly have no clue who they owe or if they have been sued, but they have a nagging sense they owe a lot and they need help. Figuring out who you owe and how much you owe is the first step in crafting a plan to get out of debt.

A new system developed by the Nebraska Court Administrators office allows anyone to search for lawsuits and judgments online for a small fee (currently set at $15).  Here is the link to the Nebraska Justice Search system.  This same information is generally available at the local county courthouse for free.

How do I pay a judgment I find online?  

If you discover that you owe a judgment, there are several ways to pay it.

  • Pay Online:  Another new service offered by the courts is to pay the judgment or fine online by going to this link.  Payment can be made by credit cards, debit cards or with e-checks.
  • Pay the Clerk of the Court:  Don’t like sending money over the internet?  No problem, just send a check or money order to the Clerk of the Court.  Many courts also accept cash payments made in person.  To find out how much you owe on the judgment, including interest, call the Clerk of the Court.  Here is a link to each County Court Clerk in Nebraska.
  • Pay the Creditor’s Attorney:   Sometimes you cannot pay the full balance all at once or perhaps you want to negotiate the balance owed.  The court record will have the name and phone number of the attorney who sued you. Call them and make payment arrangements if necessary.  Remember that when you send payment to their attorney you are also giving them information about where you bank or work, and unless you are paying the balance in full you are giving them clues as to where to send a garnishment. Be careful in what you share with the creditor’s attorney.  Email seems to be a great way to bypass the secretary to negotiate directly the attorney. Here is the link to get the email address of the creditor’s attorney.  Remember that you should never send money to a creditor when negotiating a debt until they send you something in writing agreeing to the settlement.

If a judgment has been entered against you it is important to get a Satisfaction of Judgment filed in the court record after payment.  Once the judgment is paid or settled, you want the public records to show the debt is satisfied so that you may update your credit report.

Image courtesy of Flickr and lemonjenny.

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As the old saying goes, if you don’t use it you lose it.  The “it” in this case is the right to sue someone for an unpaid debt. Every state has a set of laws that create a deadline for creditors to sue for an unpaid debt.  In Nebraska there are two key laws that govern debt collectors when it comes to suing for an unpaid debt.

  1. Written Agreements.  An action upon a written contract can only be brought within five years.  Nebraska Statute 25-205. This law covers most credit card agreements, bank loans, and other written agreements to pay money.  A voluntary payment of any amount basically “resets” the statute, so we measure the five years from the date of last payment.
  2. Oral Agreements.  An action upon a verbal contract can only be brought within four years of the date of last payment.  This provision covers most medical debts.  Nebraska Statute 25-206.

In recent years there has been a dramatic increase in sale of these time-barred debts to junk debt buyers who call to collect debts that are 5, 10, 15 or even 20 years old.  Very often they lack any real documentation of the debt owed and they try to trick the debtor into making a voluntary payment, thus resetting the statute of limitation.  I am frequently hearing clients and former clients call about abusive phone calls where the debt collector threatens to have the debtor arrested that very day if a payment is not made.

WHAT SHOULD YOU DO IF YOU ARE SUED ON AN EXPIRED DEBT?

  • Answer the Lawsuit.  If you are sued on an expired debt is it important to (1) file a written answer to the lawsuit with the Clerk of the Court and (2) specifically state in the written answer that the statute of limitations has expired.  The statute of limitations is an Affirmative Defense.  What that means is that you must affirmatively claim the defense in your written answer.
  • Demand an Account History.  If you believe no payment has been made a debt in more than 4 to 5 years, demand that the debt collection attorney provide you with a copy of the account history showing all payments and charges to the account.  In legal terms, we call these demands Interrogatories and Motions to Produce Documents.  In simpler terms, this is basically a letter written to the debt collector’s attorney demanding that they answer basic questions and that they supply you with requested documents.  If the debt collector cannot supply you with information as the date of the last payment, the amount of the last payment, whether the payment was made with a bank check, credit card or cash, that is fairly persuasive evidence that the debt may have expired.
  • Counter-sue for FDCPA violaiton.  It is illegal for a debt collector to file a collection lawsuit on an expired debt.  Such lawsuits violate the Fair Debt Collection Practices Act (FDCPA).  Under the FDCPA you may be entitled to $1,000 of punitive damages plus they must pay for your attorney fees if you prevail.  If you are sure the debt has expired, consult with a FDCPA attorney in your area.

 

IS THE STATUTE OF LIMITATIONS TOLLED DURING A BANKRUPTCY CASE?

This is a very important topic for attorneys practicing in consumer bankruptcy cases who represent debtors owing Private Student Loans.  Bankruptcy Code Section 108(c) provides that if a statute of limitation would normally expire during the administration of a bankruptcy case, the statute is tolled for an additional 30 days after notice of the end of the bankruptcy case.  The big question is whether the Nebraska statute of limitations is tolled during the administration of the bankruptcy case.  The answer to that question was provided by the Nebraska Supreme Court in the National Bank of Commerce Trust & Savings Ass’n v. Ham decision.  In short, the court ruled that the Nebraska statute of limitation is not tolled during a bankruptcy case except for the additional 30 days provided under Section 108(c) of the Bankruptcy Code.  This is a very key ruling for debtors owing substantial private student loan debts who may benefit by filing a Chapter 13 bankruptcy case to seek protection while the statute of limitation runs out on their private student loans.  More on this topic later.

Image courtesy of Flickr and Patrick Marlone.

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Can I keep my home if I file bankruptcy?  Do I have to list the mortgage company?  What if I’m behind on the payment?  Can I still pay the mortgage payment online?  Will they send me monthly statements?  How do I know that the past due amounts were paid current?  I want to file bankruptcy but I don’t want to lose my home.  I don’t want to list that debt.

Homeowners have a lot of anxiety about filing bankruptcy, and for good reason.  They worry that by filing bankruptcy they will lose the home.  To be sure, there are risks to filing bankruptcy, but the whole idea of filing a case is to protect property and there is no reason a home should be lost or compromised if you observe the following:

  1. Nebraska exemption laws protect the first $60,000 of equity in your homestead.  If your home could not be sold for $60,000 more than what you owe on the mortgage the home is safe when filing Chapter 7.  If the home has more than $60,000 of equity do not file  Chapter 7. Rather, consider filing the alternative type of bankruptcy–Chapter 13–where the trustee does not have the power to liquidate assets.
  2. All debts must be listed in bankruptcy.  You cannot exclude any debt, including mortgage or vehicle loans.
  3. Reaffirmation Agreements.  In Chapter 7 cases the homeowner can sign an agreement to reaffirm the mortgage debt.  Such agreements basically pull the mortgage loan out of bankruptcy.  The only real benefit to these agreements is that the mortgage company will continue to report to the major credit bureaus whether the loan is being paid on time, and continued credit reporting is critical if you will refinance the mortgage loan in the future.  Reaffirmation Agreements are not used in Chapter 13 cases.
  4. Banks Do No Automatically Reaffirm Mortgage Loans.  The number one frustration homeowners experience after filing Chapter 7 is that the mortgage company stops reporting loan payments to the credit bureaus if a Reaffirmation Agreement is not filed with the bankruptcy court.  Banks no longer offer reaffirmation agreements on mortgage loans in most cases unless the homeowner specifically requests one. That means you must call the mortgage company to demand a reaffirmation agreement.  You probably will have to call multiple times, perhaps weekly, to get the agreement.   Why do you have to pester them?  Banks do not view Reaffirmation Agreements as being necessary.  Although bankruptcy wipes out the debt, it does  not terminate their mortgage lien.  So, if a homeowner stops paying the mortgage, the bank still has the right to start a foreclosure whether the loan is reaffirmed or not.  For this reason, banks stopped hiring people to process reaffirmation agreements.  The bank is fine, but you are not. Without a reaffirmation agreement you will find it nearly impossible to refinance a mortgage loan, even if all payments are made on time.  Without the reaffirmation agreement there is no credit bureau reporting, and without that you cannot find a bank that will refinance the loan.
  5. Keep Track of your Mortgage Payments.  It is very common that I handle cases where the mortgage company says they did not get payments due after the case was filed.  Most of the time the bank is right, but not always.  Sometimes banks apply payments to the wrong account.  Sometimes they don’t know where to apply a payment and put the money in a “Suspense Account.”  Sometimes homeowners are unaware that the payment has increased and they pay the wrong amount.  If the bank says you did not pay you need to have proof of payment, i.e., canceled checks, bank statements, money order receipts, Western Union wire receipts.
  6. Pay the Mortgage Through Your Bank Account, Not Money Orders.  I hate it when clients pay the mortgage with money orders.  Why?  Because a money order receipt only proves that you bought a money order, it is not proof the bank received the payment.  To prove payment you must purchase a “trace report” from the money order company showing the bank actually deposited the money order.  Unless you buy a money order trace you have no idea if the bank accepted the payment.  Banks lose a lot of checks.
  7. What if the bank won’t accept my payment over the phone?  It is common for banks to cease online mortgage payment access when a bankruptcy is filed until a Reaffirmation Agreement is filed or until a Chapter 13 case is completed.  Some banks will not take payments over the phone until the case is over.  If they will not accept an online or telephone payment just send them a regular check in the mail.
  8. What if the bank returns my payment?  Banks return payments for three general reasons:  (1) They are not aware the bankruptcy was filed; or (2) you are paying the wrong amount; or (3) the amount you are paying does not bring the loan current and they want to make it 100% clear to you that they will not accept partial payment.  When payments are returned bring the returned payment and the accompanying letter from the bank to your bankruptcy attorney.  We are generally able to get the bank to accept the payment if we route it to the correct department or to the bank’s attorney.
  9. Keep a chart of your mortgage payments.  When banks say that the mortgage payment is behind I have no clue if they are wrong or right until I see a list of every payment made, the date each payment was sent, the date the payment cleared the bank account, the amount of each payment, the check number for each payment, and the bank statement showing each payment made.  Keep a chart or a table listing this information while the bankruptcy case is open, especially in those 3 to 5 year Chapter 13 payment plans.
  10. Homeowners have the burden of proving payment.  If the bank says a payment was not made that is assumed by the court to be correct unless the homeowner has evidence to the contrary.  For this reason it is very important to keep your bank statements and to highlight each mortgage payment that cleared the bank.  Save those bank statements while you are in bankruptcy.  Keep a list of all payments made.  If you are crazy enough to pay the bank with money orders, keep an organized file of each and every payment made.

Image courtesy of Flickr and Andrey 77 dron.

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I enjoy listening to a variety of podcasts while walking the dog or driving to the office. Podcasts are a really amazing thing for those who crave learning, although there seems to be some rule that requires 50 bad shows to appear before you find a really great one. (Have you loaded the Stitcher radio app on your smartphone yet?  You really should.)  The EntreLeadership podcast is one of the better shows being streamed these days, and I had the pleasure of listing to Dale Partridge talk about his new book, People Over Profits.

As you might guess, the message of the book is that a business will not succeed in the long-run if it places profits over people, despite some evidence to the contrary.  Perhaps it is better to say that businesses will be more successful in the long-run if they keep their customer’s best interest at heart.  I think it really comes down to establishing trust.  We trust that Apple computers are top notch and that Starbuck’s coffee is always great–they have earned that reputation.

What Partridge is talking about is more than just good business sense.  We all need a set of core values to steer our personal lives and our businesses as well.  In the long run, businesses and individuals get lost when they routinely put selfish short-term needs and wants ahead of others, especially customers.

I’d like to think we have modeled our law firm with the client needs and wants placed first.  How do we do that?

  • One-on-One Client Relationships.  I strongly believe that each client should be assigned one attorney and one paralegal to handle their case from beginning to end. There is no confusion as to who is responsible or who to call. There is no red tape. You know your team and they know you.
  • We do the Work.  Many firms hand out thick questionnaires for clients to complete that list all debts, property, income and property transfers.  Some of these questionnaires are 50 pages long!  I have two objections to that:  First, bankruptcy law is complex and it is unreasonable to assume that clients can really answer the questions correctly without prior experience.  Second, isn’t filling out paperwork what you pay the attorney to do?
  • Easy Access to Attorneys & Staff.  It is easy to contact our attorneys when questions arise.  Each attorney has a direct phone extension (mine is Extension 100) and appointments over the phone or in person are easy to schedule.  We want you to understand your case and the legal process.  That means we are here to answer questions in person, over the phone, through email or video chat or whatever else it takes.
  • Copies of Documents.  You are entitled to a copy of your case documents without charge whenever needed.
  • Flat Fees.  About 95% of all our cases are charged on a Flat Fee basis.  Nobody likes surprises when it comes to fees.  You know what your case will cost before it is filed.
  • Resources.  Our goal is to provide you with great resources to help guide you through the legal process.  Our website is filled with helpful articles, legal forms and videos to help educate you on your legal rights.  This is a ongoing project that we work on every day.

Creating a customer-focused organization is expensive and challenging. It takes a lot of time and money to be responsive.  In the long-run it pays off.  Deciding to be great instead of mediocre takes commitment, training, planning, money, passion and dedication.  I don’t want to work any other way.

Image courtesy of Flickr and Janine & Jim Eden.