Power of attorney.indd

Thomas Hilliard, Senior Policy Associate, Schuyler Center for
which enables one person to vest another person with authority to sign fi nancial documents on his or her behalf, is one of the most commonly used legal devices in the United Elaine faced a dilemma. At age 71, she had been hospitalized with kidney failure and might be seriously ill for some time to come. But unless she paid rent and utilities regularly, she States. Convenient and fl exible at its best, power of attorney would lose her rental apartment. Elaine’s younger sister Anne came to the rescue, agreeing to handle Elaine’s fi nancial affairs during the hospitalization. Anne suggested a common legal device called “power of attorney” to facilitate the arrangement.1 Using power of attorney, Anne could legally sign documents on State’s 62 District Attorneys found that cases of egregious Elaine pulled through her illness. Upon visiting the bank, she discovered that Anne had used her banking account to pay more than bills. Armed with power of attorney authority, her sister had withdrawn most of her life savings – nearly $50,000 – and gambled much of it away at casinos in Atlantic City. believe that they do not have the tools they need to detect, Fortunately, the New York County District Attorney decided to intervene. Anne entered a guilty plea and made restitution to The kind of fi nancial exploitation experienced by Elaine is by no means unusual in the United States, particularly among senior citizens. Financial exploitation of the elderly has become a booming criminal business in America. A 2004 study found that one in fi ve elder abuse complaints to state Adult Protective Schuyler Center for Analysis
Services agencies related to fi nancial exploitation – more than and Advocacy
150 State Street, 4th Fl.

52,000 incidents in the 19 reporting states alone.2 Such data can Albany, NY 12207
dramatically understate the incidence of fi nancial exploitation, (518) 463-1896
however, since it excludes complaints made directly to law enforcement. In addition, many experts believe that the perpetuated upon vulnerable adults,” states former majority of fi nancial exploitation incidents are never United States Attorney John E. Lamp.4 The potential reported. The U.S. Senate Committee on Aging projects for exploitation springs from two factors: the broad that 84% of all elder abuse cases go unreported, or up to authority vested in the agent and the vulnerability of fi ve million such cases each year.3 That would mean as the principal.5 Power of attorney authority enables the many as one million fi nancial exploitation cases going agent to buy or sell real estate, pay contractors, change unreported. Professional scam artists prey constantly on the benefi ciaries of insurance policies, transfer money at the elderly, using techniques such as identity theft and will, and much more. In theory, the agent is accountable to the senior citizen who signed the power of attorney form. In practice, mental and physical deterioration Elaine’s exploitation was facilitated by a legal device often prevents the principal from making decisions and called “durable power of attorney.” As a seriously ill reviewing the agent’s transactions. Indeed, the point of hospital patient, Elaine was in no condition to manage making the power of attorney “durable” is to ensure “Financial Durable Powers of Attorney continue to be fi nancial affairs can the favorite vehicle for large-scale criminal fi nancial sell property, deal with exploitation perpetuated upon vulnerable adults,” physical incapacity. states former United States Attorney John E. Lamp.
other fi nancial transactions. So Elaine signed a form the last to learn that he or she has been the victim of allowing her sister to conduct all these transactions in her name – the durable power of attorney. Some states have created safeguards in law to protect Power of attorney authority is used thousands of seniors who sign over their power of attorney, but times each year, and elder law attorneys will typically New York is not one of them. In New York, the agent recommend power of attorney to any client of a certain wields immense fi nancial power without clear fi scal age who wants assistance keeping fi nancial affairs in order. The person who gives another authority to sign offi cial documents using the power of attorney is Many cases of fi nancial exploitation related to power known as the principal, while the person who receives of attorney in New York State have been documented that authority – typically a family member or close in the past few years, but no concrete data exists on the friend – is the agent. The power of attorney is easy to nature or extent of this phenomenon. In theory, it would execute and adapt to specifi c needs. The relevant form be possible for the State of New York to collect such can be obtained at any stationery store, downloaded data through the court system or through the Offi ce of from the internet or simply typed out, printed and Children and Family Services. But the absence of model signed by the parties. The principal’s signature systems in other states suggests that such a reform must then be notarized in the presence of witnesses. would be hard to implement. Furthermore, parties to a Additional clauses can be drafted and initialed by the power of attorney do not report their transaction to any parties without the involvement of an attorney. central registry, which reduces even basic estimates of the number and kinds of powers of attorney currently The very features of simplicity and convenience that in circulation to the level of guesswork. make power of attorney so commonly used by senior citizens also render it vulnerable to abuse. “Financial The Albany Guardian Society commissioned SCAA Durable Powers of Attorney continue to be the favorite to examine the only aspect of power of attorney abuse vehicle for large-scale criminal fi nancial exploitation that seemed readily quantifi able: criminal prosecution by New York State’s 62 county District Attorneys. We distributed a survey to each District Attorney’s offi ce utilities and insurance companies that they can rely on and conducted follow-up interviews with a number of the agent’s authority. The types of fi nancial authority respondents. The overall pattern is as unmistakable as it conveyed to the agent are at the discretion of the is troubling. principal, ranging from narrowly drawn authority to conduct a fi nancial transaction (e.g., to sign documents on a house sale) to broad authority in managing the principal’s fi nancial affairs. • Only a small fraction of fi nancial exploitation
cases involving power of attorney appear to be
There are three types of power of attorney in New referred to District Attorneys. The 16 responding
York: non-durable, durable and springing durable. A counties reported 163 referrals over two years, non-durable power of attorney lapses if the principal
an annual rate of 9.5 referrals per 100,000 seniors. becomes incapacitated. A durable power of attorney
Projected statewide, this would represent 231 does not lapse. The offi cial form states: “The powers referrals, or 115 referrals annually.
you grant below continue to be effective should you • The referral rate varies dramatically from one
become disabled or incompetent.” A springing durable
county to another. The referral rate varied from a
power of attorney only becomes effective when high of 34.8 referrals per 100,000 seniors to a low triggered (or “sprung”) by an event designated by the of 1.8. If all counties reported at the rate of the fi ve counties with the highest rates (16.5), total Senior citizens typically execute the durable power of statewide referrals would have been 403, 74% attorney in order to provide for fi nancial continuity higher than the imputed rate of 231. The large should they suffer mental or physical disabilities that intra-county gap may hint at the existence of “lost render them unable to conduct fi nancial transactions. cases” in some counties that should have been Durable power of attorney provides an attractive referred for criminal prosecution but were not. alternative to guardianship, which costs money, However, variations in reporting may account for consumes time and effort, and infringes on the senior’s • Only one in seven power of attorney-related
cases were prosecuted. Of 163 referrals, 23 were
Power of attorney authority is simple to execute prosecuted (14%), while 13 remain open (8%) and use. The principal can fi ll out the form, which is and could be prosecuted in the future. The low available at stationery stores, and designate an agent prosecution rate suggests signifi cant diffi culties in (also known as the attorney-in-fact) without resort to a building a case for criminal prosecution. However, lawyer. The form must simply be notarized to become 22 out of the 23 prosecuted cases resulted in effective. New York has a standard durable power of attorney form. However, the principal can use any form desired. Once signed, the agent can act without • The suspect in more than half of all referrals was
the principal’s knowledge and continue to act without a family member. Fewer than one in fi ve (18%)
regard for the principal’s mental and physical capacity. of referrals involved a home care worker as the suspect. Over half of all referrals (56%) identifi ed The convenience of the durable power of attorney family members as suspects, and another quarter is precisely the quality that makes it an attractive (24%) identifi ed a friend of the alleged victim. vehicle for fi nancial exploitation. Once a senior citizen has become incapacitated, the agent faces little accountability for his or her stewardship of the Power of attorney is a legal device that gives one person principal’s fi nancial affairs. Unless explicitly stated – the “agent” – authority to represent another person in the power of attorney, no one else is authorized to – the “principal” – and act on that person’s behalf. supervise the agent or review fi nancial records. The purpose is to assure third parties such as banks, As a result, many power of attorney relationships relationship, deters wrongdoing, and makes prosecution have ended in fi nancial exploitation. “Unscrupulous attorneys in fact (agents) can wipe out a vulnerable person’s lifetime savings in a matter of days,” notes In New York, however, fi duciary duty is anything but simple. The New York General Obligations Law sets 6 Home care aides have been known to befriend a senior, win their trust, and obtain the power of attorney, forth 14 different categories of fi nancial transactions the specifi cally for the purpose of defrauding them. Family agent can conduct on behalf of a principal, ranging from members are also frequent offenders, although the road running a business to selling a house to fi ling a lawsuit to to exploitation is usually much longer. “When a family paying for the children’s dental care. Only one category, member is involved, conduct that began in the elder’s gift-giving, imposes any duty on the agent to act in the best interest may become abusive over time,” notes elder principal’s best interest. A provision added in 1996 states law attorney Kim Boyer. “After several years, when that the agent can “make gifts…only for purposes which they see how much work is involved, often they begin the agent reasonably deems to be in the best interests to feel an ‘entitlement’ to the funds.” of the principal…”9 This provision establishes a form who has been handling a senior’s fi nances for some time of fi duciary duty, but in an ambiguous and cloudy faces greater temptation and fewer checks on fraudulent form. In fact, the provision’s relevance to cases of clear activity. Such instances are likely to increase as the baby impropriety was not even fi rmly established until a June boomer generation retires, given this generation’s higher 2006 ruling by the New York State Court of Appeals, In asset levels, greater longevity, and wider geographic dispersal from family members who might observe The facts of the Ferrara case provide a cold reminder of the agent’s sweeping authority. In June 1999, a retired Any legal device that turns over the fi nancial affairs of stockbroker named George Ferrara willed his life a vulnerable senior citizen to someone else is bound to savings to the Salvation Army. In late January 2000, be misused occasionally. The diffi culty with power of frail and suffering from multiple chronic conditions, attorney in New York is its near-total lack of regulatory Ferrara signed a power of attorney form designating or accountability safeguards, which invites and facilitates his nephew Dominick as the agent. The form included fraud. a typewritten amendment stating that the agent could “make gifts without limitation in amount to John Ferrara New York Law and the “Best Interest” Gap
and/or Dominick Ferrara.” George Ferrara had no legal representation, and a witness recounted that she The New York General Obligations Law sets forth the did not “recall the word ‘gift’ having been mentioned” proper language for a durable power of attorney form to Mr. Ferrara before he signed the power of attorney. and enumerates various categories of authority held On February 12, George Ferrara passed away. Only by the agent, such as real estate transactions and bank three weeks had passed since the signing, but in that withdrawals.8 General Obligations Law discusses the time Dominick Ferrara had transferred “about $820,000 agent’s powers in elaborate detail, but is mostly silent on of decedent’s assets to himself…and about $300,000 in cash,” a sum representing virtually all of George One serious and oft-noted gap is the law’s ambiguity of language on fi duciary duty, a standard concept in agency The question posed by Ferrara was this: Could an agent law which holds the agent accountable for acting in the use power of attorney authority to empty the principal’s best interest of the principal. For example, a corporate life savings in the dwindling few days before death, even board of directors has a clearly stated fi duciary duty to though the principal had recently willed the money to its shareholders. In some states, including California and go elsewhere? At fi rst, the answer appeared to be “yes.” Wisconsin, the agent holding power of attorney authority The case went to the Rockland County Surrogate’s Court, has a clearly stated fi duciary duty. This clarifi es the which ruled for Dominick Ferrara, and then to the Appellate Division, which affi rmed the Surrogate’s transactions. Or the agent may simply exercise poor decision, concluding that “Dominick Ferrara had judgment in handling the principal’s fi nancial affairs. overcome the [presumption of impropriety] solely by Power of attorney is a civil document, and occasional problems unrelated to fi nancial exploitation are typically solved with civil remedies. A principal who is But Dominick Ferrara’s luck ran out at the Court mentally competent can revoke the power of attorney of Appeals. The Court of Appeals overturned the and give it to someone else. If the principal no longer lower court decisions, ruling that the agent must has mental capacity, the family must go to court to “exercise gift-giving authority in the best interest of the request the appointment of a guardian. This option is principal.”13 That so much effort should be required to expensive and may appear demeaning to the senior deliver such a common-sense verdict testifi es to the lack citizen. For seniors who suffer dementia, however, there of protection afforded New York’s senior citizens by the Fraudulent use of power of attorney is much more Ferrara established an overdue protection for senior serious. Revocation or guardianship are still the key citizens who sign power of attorney, but a court verdict civil remedies, but now criminal prosecution must serves different functions from a law. Laws establish also be considered. For the sake of convenience, this rules; verdicts interpret them and set precedents for process can be viewed as having four stages: detection, future interpretation. Ferrara confi ned itself to the investigation, referral, and disposition. issue at hand, which was gift-giving. Agents continue to work without clear statutory guidance on their Detection: A family member may become suspicious fi duciary duty in any other aspect of power of attorney. if the agent shows signs of new wealth while the Worse, General Obligations Law still does not defi ne principal’s needs are not being properly met. A fi nancial the agent’s duty or include any provision to warn institution may note a pattern of suspicious account agents that they have one. Prosecuting attorneys want statutory direction that they can take before a court, and no such direction presently exists. Investigation: Next, an investigation commences. The person who detected a potential case of fraud may There are other issues with General Obligations Law, contact the county offi ce of Adult Protective Services, most of which have been identifi ed by the New York which investigates cases of neglect and abuse involving State Law Revision Commission in its 2003 study impaired and vulnerable adults, including the mentally on power of attorney.14 For example, the General ill, the disabled and the frail elderly. Other investigators Obligations Law does not require the agent to keep include private attorneys and the local police records of fi nancial transactions or to show existing department. Families will often contact their county records to state agencies that might be called in to Rules and procedures differ depending on which agency is conducting the investigation. Generally II. Procedures in Handling Power of Attorney Abuse
The great majority of agents holding power of attorney
speaking, however, the investigator will typically check discharge their duties honestly and competently. Yet to see if the principal’s utilities have been turned off for problems can arise, even when agents act in what non-payment, and will request transaction records from they believe to be the principal’s best interest. For fi nancial institutions. If warning signs merit further example, the agent may be busy with personal affairs exploration, the investigator may seek to freeze the and neglect the principal’s needs. The agent may be principal’s assets. Freezing assets requires that some a family member feuding with other family members sort of legal action be pending, such as a petition for and fail to take their concerns seriously. The agent may guardianship. A common maxim among experienced fl out the principal’s desire to be consulted on important lawyers and caseworkers is “Stop the bleeding.” A senior’s lifetime savings can be emptied in a Adjusted for population, this represents a rate of matter of days. Facing clear evidence of fraud, the 9.5 referrals per 100,000 seniors. The average rate investigator will typically move quickly to freeze assets across counties was 15.3, due to higher rates in and, if possible, revoke the agent’s power of attorney counties with lower senior populations. This is a low rate, especially compared to national estimates of more than a million cases of fi nancial exploitation Referral: When a case is referred to the county District annually. Many such cases may simply not be Attorney, a prosecutor is tasked with determining reported, either because they were not detected or whether it meets the standard for larceny under the state Penal Law, and can therefore be criminally prosecuted. The standard is much more diffi cult to meet • Rate variation due to reporting and
when the suspect has power of attorney authority, since referral defi ciencies: The referral rate varied
all transactions are presumed to have the consent of the dramatically from county to county, from a high of 34.8 to a low of 1.8. One upstate county with a population of 33,000 senior citizens Disposition: The prosecutor determines whether to move reported more referrals than a downstate forward with criminal prosecution. The prosecutor county with 280,000 senior citizens. The may determine, upon investigation, that the case is not disparity results from at least three factors. appropriate for prosecution, and that relief should be sought through the civil court system. prosecution option: Referral volume depends largely on the extent to which law enforcement offi cers and other potential SCAA sent out a survey to all 62 county district referrers understand that some instances attorneys. In the survey, we asked a series of questions of power of attorney abuse rise to the level about referrals for fi nancial exploitation of the elderly: of a criminal offense, which may vary from the nature of the referrals, the parties involved, the county to county. “I also experience the decision to seek or not seek criminal prosecution, and local police department failing to take cases the fi nal disposition of each case prosecuted. involving POA abuse because they feel it is civil,” notes Donna Planty, a prosecutor 19 out of 62 county district attorneys responded, a in the offi ce of the Suffolk County District response rate of 31%. Three of those counties were Attorney. “In spite of efforts by my offi ce excluded – two small counties because they reported to educate the police department, this still no power of attorney referrals, and a larger one that reported referrals but was unable to quantify them. ¾ DA willingness to accept and encourage The remaining 16 counties represent 1.7 million of New York State’s 2.4 million senior citizens, or 71% of all on the extent to which prosecutors believe that referrals of power of attorney related cases can be prosecuted as criminal acts. Historically, power of attorney cases have A. Criminal Prosecution Rates
been handled in civil court. For example, one county was excluded from the study Summary of responses: The 16 counties reported
because a court precedent set an extremely a total of 163 referrals for misuse of Power of Attorney authority during a two-year period. result, prosecutors in that county do not accept power of attorney referrals. ¾ Reporting: DA offi ces for the most part than half of counties (9 out of 16) reported appear to have no recordkeeping category for power of attorney cases, so responses institutions. While those institutions may be to the survey were informal. For example, cooperating with law enforcement or Adult Protective Services, it is nonetheless a red referral data in the form of an estimated fl ag for potential inconsistent policies among • Statewide
Chart 1: Sources of Power of Attorney
Criminal Referrals
counties, total referrals over two years would have been 231, for an average of 115 referrals • Statewide total adjusted for reporting and
referral defi ciencies: If all counties statewide
reported at the rate of the 5 counties with the highest referral rates (16.5), total statewide referrals over two years would have been 403, for an average of 201 referrals annually – 74% higher than the projected statewide total of 115.15 The large gap between the median rate and the highest reported rates may represent “lost cases” that should have been referred to District Attorneys but were not. However, disparities in reporting may also account for • Suspect/victim relationship: Over half of all
referrals (56%) identifi ed family members as suspects, and another quarter (24%) identifi ed B. Nature of Referrals
a friend of the alleged victim. While cases of • Referral
sources: power of attorney referrals
came from a variety of sources. Just under seniors have received media coverage, fewer half of all referrals (46%) were submitted than one in fi ve (18%) of referrals reported by respondents involved home care workers. Chart Adult Protective Services, and 14% by law 2 on the next page shows the full breakout. The enforcement offi cers. Chart 1 shows the dominance of the family/family relationship full breakout. However, rates varied. Two in this indicator was consistent across counties, although one county reported that half of its Adult Protective Services, while another received one-third of referrals from fi nancial institutions. • Referrals from Financial Institutions:
Financial institutions represent an important fi rst line of defense against fi nancial exploitation of the elderly. Several counties reported receiving multiple referrals from fi nancial institutions. However, more Chart 2: Relationship Between Victim
• Prosecutors repeatedly cited the absence of a and Suspect in Referrals
statutory “fi duciary duty” standard as a major obstacle to criminal prosecution. “District Attorneys will say that there is a lack of clarity in General Obligations Law,” says Elizabeth Loewy, an Assistant District Attorney in New York County. “It makes prosecution much more diffi cult. You can put the case together from case law, but that’s harder.” • The principal is often not helpful to prosecutors due to mental incapacity. “Most of the cases I have seen involving a POA, the document was either executed at a time when the principal lacked the capacity to understand what they were doing, or if executed prior to an incapacity, the POA was not used until the principal subsequently became C. Criminal Prosecution
incapacitated,” states Suffolk County prosecutor • Prosecution: power of attorney cases appear
to be diffi cult to prosecute. Of 163 referrals, • Some prosecutors noted the importance of 23 were prosecuted (14%), while 13 remain fi nancial institutions in bringing fi nancial exploitation cases to their attention. Other the future. Of the 23 prosecuted cases, 21 prosecutors, however, did not report the existence resulted in conviction by plea, one resulted of a strong partnership. Adult Protective Services in conviction by trial, and one in dismissal. staff also noted a signifi cant disparity between Prosecution rates varied sharply. One county fi nancial institutions that provide willing reported prosecuting all of its four referrals, assistance to fi nancial exploitation investigations and those that provide only reluctant and minimal support. • Some gray areas may be diffi cult to remedy. For SCAA followed up by interviewing selected prosecutors example, agents sometimes state that the principal in District Attorney’s offi ces, as well as experts in verbally authorized a suspicious transaction, and Protective Services for Adults agencies and non-profi t a principal with memory lapses may actually have service organizations that work with elderly victims of done so and then forgotten the conversation. • Given the obstacles prosecutors face in power of attorney cases, the surprise is that any are Those who fi nancially exploit the elderly should prosecuted. Prosecutors stress the diffi culty and be prosecuted to the full extent of the law. Such uncertainty of cases involving power of attorney. prosecution is essential to deter future offenders, to Some of the root causes should be amenable to assist in fi nancial recovery, and to maintain a just and statutory/regulatory reform and collaborative Yet criminal prosecution is hard to conduct. Many obstacles are thrown in the way of prosecutors. Some are inherent to the muddiness of cases that tend to involve forgetful seniors and embarrassed families. Other obstacles are externally imposed, and those 3. Establish a collaborative task force charged obstacles can be overcome through statutory and with strengthening the role of fi nancial regulatory reforms. Most important is to provide institutions in detecting and reporting possible ongoing focus to helping seniors who may be fi nancial exploitation of the elderly. Financial victimized by fi nancial exploitation of all kinds. No one institutions may represent the most important policy remedy will solve the problem. Only a regular front line of defense, and some respondents process of policy innovation, strong implementation reported excellent relationships with fi nancial and careful evaluation will work. Everyone involved in institutions in their county. But the majority protecting senior citizens must work in concert. If they of respondents did not. The unevenness of fail, many seniors will lose their life savings without fi nancial institution cooperation suggests anyone the wiser. If they succeed, those same seniors that real leadership is needed to develop the can live out their fi nal years in dignity. nuanced regulations and best practices that protect the needs of fi nancial institutions, ethical agents and investigators of potential fi nancial exploitation. In addition, education Financial exploitation through power of attorney of fi nancial institution staff needs to be more is diffi cult to confront, since many standard anti- fraud measures in other fi elds (e.g., fi ngerprinting of agents) would badly damage a fi nancial device that Investigation
thousands of New Yorkers depend on to conduct 4. Give Adult Protective Services agencies their fi nancial affairs. “A lot of things you can do have enhanced powers to obtain an agent’s relevant serious negative impacts on people who use power of fi nancial transactions in the course of an attorney,” notes Lori Stiegel, associate staff director for the Commission on Law and Aging at the American Bar Association. SCAA offers the following options that 5. Give Adult Protective Services agencies the may serve as a basis for reform. While the authors have power to petition a civil court in cooperation benefi ted from discussions with many prosecutors, with fi nancial institutions to prevent the agent Adult Protective Services staff, advocates and others, from exercising control over assets during the SCAA alone is responsible for these proposals. term of an investigation. An unscrupulous agent can drain and squander the principal’s Prevention
lifetime assets with astonishing speed. Duly 1. Draft clear and mandatory language in the constituted agencies need the power to “stop power of attorney form directed to the agent, explaining the agent’s fi duciary duty to the Referral
principal. Such language exists in the Uniform Power of Attorney Act: “You must…do what 6. Establish a common referral standard for you know the principal reasonably expects you fi nancial exploitation cases among District to do with the principal’s property or, if you do Attorneys so that trends can be tracked and not know the principal’s expectations, act in the monitored. The standard should be developed with the participation and support of District Detection
7. Report data to the state Division of Criminal 2. Mandate in the state General Obligations Law Justice Statistics on power of attorney-related that agents must maintain fi nancial records of 8. Educate law enforcement offi cers about standards for prosecuting power of attorney cases. Police offi cers are often reluctant to pursue fraud cases involving power of attorney due to the common belief that any transaction 2 Pamela Teaster et al, The 2004 Survey of State Adult Protective Services: Abuse of Adults 60 Years of is effectively authorized, no matter how Age and Older, The National Center on Elder Abuse, outlandish, if the perpetrator has power of attorney. Continuing education can provide 3 U.S. Senate Committee on Aging, as cited by accurate information that will guide law Joanne Otto, “Background Paper on Financial Ex- enforcement in handling power of attorney- ploitation of the Elderly, 2005 White House Confer- ence on Aging,” National Adult Protective Services Association, Victimization of the Elderly and Disabled, Prosecution
John E. Lamp, “Durable power of attorney reform and streamlining investigations of vulnerable adult General Obligation Law. Other states have fi nancial exploitation crimes: an outsider looking in,” clear and detailed standards spelling out Victimization of the Elderly and Disabled, June 2004.
the fi duciary duty owed by the agent to 5 Any adult can execute a durable power of attorney, the principal. New York’s statute, on the other hand, is vague and diffi cult to enforce. Clarifying that statute should be a high priority. 7 Kim Boyer, “Elder Exploitation Litigation in Nevada: 10. Establish fi nancial exploitation through power A Model for Effective Recovery of Assets,” Accessed of attorney authority as a theory of Grand from http://www.rlbolick.com/articles-10.htm. Larceny in the New York State Penal Law. 9 New York General Obligations Law Section 5-1501 (m).
10 Matter of Ferrara (N.Y., No. 92, June 29, 2006).
14 New York State Law Revision Commission, Report on Proposed Revisions to the General Obligations Law in Relation to Powers of Attorney, 2003 15 Counties with a senior population of less than 30,000 were excluded from this calculation.
16 Uniform Power of Attorney Act, drafted by the Na-tional Conference of Commissioners of Uniform State Laws, 2006. This act is intended as a model for states to adopt in statute.

Source: http://www.scaany.org/resources/documents/power_failures.pdf


Boletín Oficial de la Facultad de Ciencias Inútiles BULITÓN OFICIAL DE LA FACULTAD DE CIENCIAS INÚTILES Dirección en la web: www.mensa.es/carrollia La revista BOFCI , abreviada en [ B ], es el órgano de comunicación de la FCI (Facultad de Ciencias Inútiles) de Mensa España. Su frecuencia de aparición es ya trimestral, ya irracional. Se entrega con CARROLLIA, el boletín d

Brystkræft, prostata og tyktarmskræft

Brystkræft, prostata og tyktarmskræft (Kan vi minimere disse sygdomme ved at udelukke mælk fra kosten?) Bryst cancer, prostata cancer og cancer i fordøjelses systemet: Hvad er der sker inden for vores sundheds væsen og hvem kontrollerer hvem ? Disse spørgsmål har længe trængt sig på og nu vil de ud. I den sidste uge har jeg beskæftiget mig med en artikel, som Carsten Vagn-Hansen h

Copyright ©2018 Drugstore Pdf Search