Sunday, March 31, 2013
Local Bankruptcy Rules and Forms for New Hampshire
If I filed bankruptcy before, can I file again?
If
I filed bankruptcy before, can I file again?
The answer is yes.
The more important question is, how soon do you have to wait in between bankruptcy cases?
Chapter 7 to another Chapter 7 (8 years):
If you filed a Chapter 7 case and received a discharge of debt , then you must wait 8 years in between filing another Chapter 7 case. See 11 U.S.C §727(a)(8).
Chapter 13 then Chapter 7 (6 years):
You must wait six years. See 11 U.S.C.§727(a)(9). However, if you paid 100% of your debts in the prior Chapter 13 case or paid at least 70% of your debts in the prior Chapter 13 case and the Bankruptcy Court found that this was your best effort then the 6-year rule does not apply. See 11 U.S.C.§Section 727(a)(9), provided you otherwise qualify.
Chapter 7 then Chapter 13 (4 years):
If you previously filed a Chapter 7 case and received a discharge of debt, then you would wait four years in between the prior Chapter 7 case and the new Chapter 13 case. See 11 U.S.C.§1328(f)(1). But, if after filing a Chapter 7 case you file a Chapter 13 case and you do not need a discharge of debt in the new Chapter 13 case, then you do not wait.
Chapter 13 to another Chapter 13 (2 years):
If you received a discharge of debt, meaning you completed your repayment plan in a prior Chapter 13 case, then you must wait two years before filing another Chapter 13 case or you will not receive a new discharge of debt in the new Chapter 13 case. See 11 U.S.C.§ 1328(f)(2). But, if you are not looking for a discharge of debt in the new Chapter 13 case, then you can file another one without waiting.
NO time (0 years):
If you are going to pay your creditors back 100% and do not need a discharge of debt, then you do not need to wait to file a Chapter 13 case. Why would you file a bankruptcy case and not care about discharging debt? A common answer is that you have fallen behind on your mortgage payments, or other types of payments, and you want to catch up and a Chapter 13 repayment plan would allow you to do that. For example, if you fall behind in your mortgage payments for several months, it is nearly impossible to catch up quickly and you do not want to lose your house, and a Chapter 13 payment plan would allow you to spread those arrearages over a repayment plan of 3-5 years.
"Good Faith Rule":
All cases must be filed in good faith to receive protection under the Bankruptcy Code, regardless as to timing.
The answer is yes.
The more important question is, how soon do you have to wait in between bankruptcy cases?
Chapter 7 to another Chapter 7 (8 years):
If you filed a Chapter 7 case and received a discharge of debt , then you must wait 8 years in between filing another Chapter 7 case. See 11 U.S.C §727(a)(8).
Chapter 13 then Chapter 7 (6 years):
You must wait six years. See 11 U.S.C.§727(a)(9). However, if you paid 100% of your debts in the prior Chapter 13 case or paid at least 70% of your debts in the prior Chapter 13 case and the Bankruptcy Court found that this was your best effort then the 6-year rule does not apply. See 11 U.S.C.§Section 727(a)(9), provided you otherwise qualify.
Chapter 7 then Chapter 13 (4 years):
If you previously filed a Chapter 7 case and received a discharge of debt, then you would wait four years in between the prior Chapter 7 case and the new Chapter 13 case. See 11 U.S.C.§1328(f)(1). But, if after filing a Chapter 7 case you file a Chapter 13 case and you do not need a discharge of debt in the new Chapter 13 case, then you do not wait.
Chapter 13 to another Chapter 13 (2 years):
If you received a discharge of debt, meaning you completed your repayment plan in a prior Chapter 13 case, then you must wait two years before filing another Chapter 13 case or you will not receive a new discharge of debt in the new Chapter 13 case. See 11 U.S.C.§ 1328(f)(2). But, if you are not looking for a discharge of debt in the new Chapter 13 case, then you can file another one without waiting.
NO time (0 years):
If you are going to pay your creditors back 100% and do not need a discharge of debt, then you do not need to wait to file a Chapter 13 case. Why would you file a bankruptcy case and not care about discharging debt? A common answer is that you have fallen behind on your mortgage payments, or other types of payments, and you want to catch up and a Chapter 13 repayment plan would allow you to do that. For example, if you fall behind in your mortgage payments for several months, it is nearly impossible to catch up quickly and you do not want to lose your house, and a Chapter 13 payment plan would allow you to spread those arrearages over a repayment plan of 3-5 years.
"Good Faith Rule":
All cases must be filed in good faith to receive protection under the Bankruptcy Code, regardless as to timing.
Divorce Obligations may not be discharged through bankruptcy.
In a recent opinion issued by the New Hampshire Bankruptcy
Court, (Honorable James B. Haines, Jr. sitting in designation), the Court
reiterated the parameters of what is, or is not, discharged through a chapter 7
bankruptcy case relevant to a divorce proceeding. See Maville v. Maville (In re
Maville), 2012 BNH 007 (Bankr. D.H. 2012)( Haines, J, sitting
in designation).
Debts in the nature of alimony and child support are not
discharged through a bankruptcy case. Section 523(a)(5) of the Bankruptcy Code
establishes that individual debtors will not be relieved of domestic support
obligations; and, Section 101(14A) defines these to include debts in the nature
of alimony, maintenance and support. Prior to 2005, some obligations were
discharged. That changed with the amendments to the Bankruptcy Code in 2005.
Section 523(a)(15) now unqualifiedly provides that a property settlement
obligation encompassed by that section is not discharged. Maville, supra.
Click here for the full opinion from the Court's web site:
Click here for the full opinion from the Court's web site:
Get a copy of your Tax Returns
If you cannot locate your tax return, the IRS can provide you with a "tax transcript" at no charge.
Click below for more information:
If you want a copy of the full tax return, you can order that as well but there will be a minimal charge.
Foreclosure: First Circuit would not force mortgagee to foreclose.
Canning v. Beneficial Maine, Inc. (In re Canning),
___ F.3d ___(1st Cir. Feb. 1, 2013).
The refusal by the Chapter 7 debtors’ mortgage creditor to
accede to the debtors’ demand that the creditor either foreclose the mortgage on
their residence, which the debtors had surrendered and vacated, or release its
lien on the property did not violate the discharge injunction.
Distinguishing In re Pratt, 462
F.3d 14 (1st Cir. 2006), in which the court held that a secured creditor's
refusal to foreclose or release its lien on an inoperable, worthless car was
intended to objectively coerce the debtor into paying a discharged debt, the
court observed that the creditor offered to release its lien through either a
settlement offer or a short sale, which indicated the intent to collect no more
than the value secured by the underlying lien, as well as a willingness to
negotiate a palatable solution for all involved.
Click here for the full opinion from the court's web site: Click here: USCA1 Opinion
Click here for the full opinion from the court's web site: Click here: USCA1 Opinion
Mortgagee must possess power of sale at the time of foreclosure.
Alleged mortgagee needed to possess the "power of
sale" at the time they foreclosed; thus mortgagor's questioning that the
assignment did not take place prior to the foreclosure was proper; one who
exercises power of sale must strictly follow its terms:
Juarez v. Select Portfolio Servicing, No. 11-2431
(1st Cir. 2/12/13):
Judgment dismissing complaint alleging defendants
illegally foreclosed on her home is reversed and remanded, where the complaint
states plausible claims for relief and that the district court abused its
discretion in deciding that it would be futile to allow an amendment to the
complaint. Juarez properly alluded to a challenge that the assignment did not
take place prior to the foreclosure thus, the foreclosing
entity did not have the "power of sale" at the time they exercised it - which is
a different challenge than a mortgagor's challenge to the validity of a
third-party assignment. The issue of whether a "confirmatory assignment" cured
the alleged defect was properly the subject of discovery and the complaint
should have proceeded on that point. One who exercises the power of sale must
strictly follow its terms. In this Massachusetts case, an assignment of the
mortgage must take place before the foreclosure begins. Further, in light of
this, the plaintiff should be allowed to amend and re-plead her fraud and
Section 93A claims (Mass. Consumer Protection Statute). Massachusetts covenant
of good faith and fair dealing is taken to be implied in every contract, and
provides "that neither party shall do anything that will have the effect of
destroying or injuring the right of the other party to receive the fruits of the
contract" - the covenant only "governs conduct of parties after they have
entered into a contract.
Juarez: Click
here: USCA1 Opinion
Homeowner has standing to challenge mortgage assignments.
In a case of first impression, mortgagor has
standing to challenge assignment of mortgage if to do so renders the assignment
void, rather than voidable:
Culhane v. Aurora Loan Services of Nebraska, No.
12-1285 (1st Cir. 2/15/13).
In a case of first impression, the court held that the
mortgagor possesses standing to challenge the assignment of its mortgage to
another entity. "Withal, a mortgagor does not have standing to challenge
shortcomings in an assignment that render it merely voidable at the election of
one party but otherwise effective to pass legal title." - thus, making the
distinction that the challenge must be that the assignment is "void", rather
than "voidable". Thus, here, the mortgagor (namely the borrower or home owner at
issue) has standing to contest the validity of the mortgage assignment made by
Mortgage Electronic Registration Systems, Inc. (MERS), to defendant, the
foreclosing entity; however, the MERS framework and defendant's foreclosure of
plaintiff's property complied with the requirements of Massachusetts mortgage
law, and thus the foreclosure was lawful. Applying Massachusetts law, the court
noted that in Massachusetts, the note and mortgage may be held by separate
entities. Further, the terms of the mortgage (contract) authorized the transfer
at issue.
"[I]n Massachusetts, a mortgagor has a legally cognizable
right to challenge a foreclosing entity's status qua mortgagee. This may, in
certain instances, require challenging the validity of an assignment that
purports to transfer the mortgage to a successor mortgagee. Standing doctrine
is meant to be a shield to protect the court from any role in the
adjudication of disputes that do not measure up to a minimum set of adversarial
requirements. There is no principled basis for employing standing doctrine as a
sword to deprive mortgagors of legal protection conferred up them under state
law. We hold, therefore, that a mortgagor has standing to challenge the
assignment of a mortgage on her home to the extent tat such a challenge is
necessary to context a foreclosing entity's status qua mortgagee. We caution
that our hold, narrow to begin with, is further circumscribed. We hold only
that a mortgagor has standing to challenge a mortgage assignment as invalid,
ineffective, or void (if, say, the assignor had nothing to assign or had not
authority to make an assignment to a particular assignee). If successful, a
challenge of this sort would be sufficient to refute an assignee's status qua
mortgagee . . . Withal, a mortgagor doe not have standing to challenge
shortcomings in an assignment that render it merely voidable at the election of
one party but otherwise effective to pass legal title."
Timing for challenge to lender's good faith and fair dealing.
Latson v. Plaza Home Mortgage,
Inc., No. 12-1462 (1st Cir. 2/27/13).
Dismissal of plaintiffs' suit against
defendant-mortgage lender alleging state common law and statutory violations in
making two house loans is affirmed, where: 1) the good faith and fair dealing
claim was properly dismissed because the allegedly wrongful conduct all occurred
before the contracts existed, not in violation of their terms after formation,
and the covenant only governs conduct of parties after they have entered into a
contract; and 2) the statutory claim is time-barred - the statute of limitations for a 93A
action is four years, which had elapsed prior to suit.
The specific allegations were that prior to closing Plaza failed to provide Latson with a proper commitment letter, good-faith estimate, or other documents required by the Real Estate Settlement Procedures Act (RESPA), 12 U.S.C. §§ 2601–2617, and gave them insufficient opportunity to review the terms of the loans. They also claimed that Plaza either "knew or should have known" that an appraisal of the property that the Latsons obtained at Plaza's request was "too high." The Latsons asserted that all these acts and omissions were actionable under both their common-law and statutory claims.
The specific allegations were that prior to closing Plaza failed to provide Latson with a proper commitment letter, good-faith estimate, or other documents required by the Real Estate Settlement Procedures Act (RESPA), 12 U.S.C. §§ 2601–2617, and gave them insufficient opportunity to review the terms of the loans. They also claimed that Plaza either "knew or should have known" that an appraisal of the property that the Latsons obtained at Plaza's request was "too high." The Latsons asserted that all these acts and omissions were actionable under both their common-law and statutory claims.
LATSON: Click
here: USCA1 Opinion
FORECLOSURE: Homeowner's legal challenges should occur BEFORE the foreclosure sale auction of their home occurs, per the Federal Court.
In a recent opinion issued by the Federal
District Court in New Hampshire, Chief Judge Laplante held that challenges to
the foreclosure must occur BEFORE the foreclosure sale is held, relying upon NH
R.S.A. 479:25,II. SeeCalef v. Citibank, N.A. et. al., CV-11-526
(D.N.H. 2/21/13).
Click here for the full text of the opinion, which can be found on the Court's web site:
The Calef case involved the federal court sitting in diversity, applying the state law as the court so interpreted it. In so ruling, the court relied upon Gordonville Corp. N.V. v. LR1-A Ltd. P'ship, 151 N.H. 371, 377 (2004);Murphy V. Fin. Dev. Corp., 126 N.H. 536, 540 (1985); People's Utd. Bank. v. Mtn. Home Developers of Sunapee, LLC, 858 F. Supp. 2d 162, 167-68 (D.N.H. 2012). Having failed to move to enjoin the foreclosure sale before launching such legal challenges, Calef (the home owner being foreclosed upon) was barred from doing so, after the foreclosure sale. Fuller v. Fed. Nat'l Mortg.Ass'n, No. 218-2011-CV-00668, slip op. at 4-6 (N.H. Super. Ct. Oct 2, 2012)(Section 479:25, II barred challenge to foreclosure based on alleged invalidity of assignment where plaintiffs had notice of assignment well before sale);Baril v. JP Morgan Chase Bank, N.A., No. 218-2010-CV-501, slip op. at 4-6 (N.H. Super. Ct. July 20, 2011)(similar); Fed Nat'l Mortg. Ass'n v. Goyal, No. 09-C-0543, 2011 WL 4403839 (N.H. Super. Ct. Feb 25, 2011)(similar).
Further, as the court previously ruled in LeDoux v. JP Morgan Chase, N.A., 2012 D.N.H. 194, 13-15, the borrower did not have standing to object to the transfer of a note on grounds that would merely render the transfer "voidable" as opposed to "void", such as a challenge to the mortgagee's pooling and servicing agreement.
Click here for the full text of the opinion, which can be found on the Court's web site:
The Calef case involved the federal court sitting in diversity, applying the state law as the court so interpreted it. In so ruling, the court relied upon Gordonville Corp. N.V. v. LR1-A Ltd. P'ship, 151 N.H. 371, 377 (2004);Murphy V. Fin. Dev. Corp., 126 N.H. 536, 540 (1985); People's Utd. Bank. v. Mtn. Home Developers of Sunapee, LLC, 858 F. Supp. 2d 162, 167-68 (D.N.H. 2012). Having failed to move to enjoin the foreclosure sale before launching such legal challenges, Calef (the home owner being foreclosed upon) was barred from doing so, after the foreclosure sale. Fuller v. Fed. Nat'l Mortg.Ass'n, No. 218-2011-CV-00668, slip op. at 4-6 (N.H. Super. Ct. Oct 2, 2012)(Section 479:25, II barred challenge to foreclosure based on alleged invalidity of assignment where plaintiffs had notice of assignment well before sale);Baril v. JP Morgan Chase Bank, N.A., No. 218-2010-CV-501, slip op. at 4-6 (N.H. Super. Ct. July 20, 2011)(similar); Fed Nat'l Mortg. Ass'n v. Goyal, No. 09-C-0543, 2011 WL 4403839 (N.H. Super. Ct. Feb 25, 2011)(similar).
Further, as the court previously ruled in LeDoux v. JP Morgan Chase, N.A., 2012 D.N.H. 194, 13-15, the borrower did not have standing to object to the transfer of a note on grounds that would merely render the transfer "voidable" as opposed to "void", such as a challenge to the mortgagee's pooling and servicing agreement.
In Calef, the
plaintiff/pro se challenged the
foreclosure sale of his home, afterthe foreclosure sale auction of
his home occurred. The Court held that insofar as Calef's claims arise from
alleged infirmities in the assignment of his mortgage to the foreclosing entity,
New Hampshire state law preclude him for pursuing those claims because he failed
to file a petition to enjoin the foreclosure sale prior the the sale occurring. Here, the owner of
the home allegedly defaulted, and was sent a foreclosure notice by the
mortgagee's counsel, the Harmon Law firm. In the process, MERS assigned its
interest in the mortgage to Citibank and copied Calef on the assignment.
Defendant/mortgagee characterized Calef's suit as a challenge to its
pre-foreclosure conduct (i.e. claims that the assignment of mortgage from MERS
to Citibank was invalid) and claims related to post-foreclosure sale conduct
(allegations that foreclosure deed and affidavit were invalid).
Further, the court found that even where a foreclosure deed and affidavit
are not recorded at all, that does not affect the validity of the foreclosure
sale as applicable to the mortgagor (meaning, the home owner). "It follows that
where the recorded deed and affidavit are deficient in some respect . . . that,
too, is a matter of no concern to the mortgagor." Calef, at p. 13.
As such, summary judgment was granted to the foreclosing
entity.
3 ways to Stop a Foreclosure Sale of your Home
In New Hampshire, most home mortgages have a "power of sale" clause. A "power of sale" clause means that the lender can take your home without taking you to court if you are behind in your home mortgage payments. Because of this "power of sale" clause allowed in New Hampshire home mortgages, New Hampshire is called a "non-judicial" foreclosure state.
A non-judicial foreclosure in New Hampshire can happen very quickly.
Take a look at the following time line from the HomeHelp web site to understand the process that shows you can lose your home in less than 120 days if you do nothing.
click here: http://www.homehelpnh.org/timeline.htm
Here are the steps to losing your home:
1. Default: Meaning, you are not current in your home mortgage payments. If you do not cure the default, you will soon receive an acceleration letter from the "mortgagee" (a "mortgagee" is the person or entity holding your mortgage and you, the borrower, are the "mortgagor") telling you that you need to pay the past due amounts within a certain time frame.
2. You may also incur late fees, penalties and the lender's costs and fees for the mortgagee's attorney for being in default - so being late in your mortgage payments may cause you to incur these $$$ additional charges.
3. After the acceleration lender, if you have not brought all of your mortgage payments, cost, fees and late charges current, the mortgagee is permitted to schedule a foreclosure sale of your home. The mortgagee must send you a notice of foreclosure sale at least 25 days before the foreclosure sale.
4. Mortgagee advertises once a week for three weeks before the foreclosure sale to publish the date and time that your foreclosure sale is going to take place.
5. Day of the Foreclosure sale: An auctioneer on behalf of the mortgagee shows up on your front lawn on the day of the foreclosure sale and auctions off your home. Up to the point of foreclosure sale, you can "reinstate" by paying back the lender all the past due payments, costs, fees, late fees and penalties - again, it is not just paying back the late mortgage payments.
6. Whoever buys your home at the foreclosure sale has 60 days to record the foreclosure deed. The mortgagee may buy your home at a foreclosure sale auction in addition to a third-party.
7. After the foreclosure sale deed is recorded, the new owner (often the mortgagee) will proceed to the process of eviction of the homeowner.
How do I stop foreclosure?
1. Lender consents: Ask the mortgagee to adjourn the foreclosure sale and give them a reasons to do so - such as you have a mortgage loan modification pending, or you have a sale pending of your home that will repay the loan. With respect to a loan modification, remember you can get FREE help in the State of NH from a Housing Counselor (click on our article regarding Housing Counselors which gives you the names and addresses of a free housing counselor near you). If the mortgagee agrees to adjourn the foreclosure sale, it is very wise to get this in writing. Or, you can pay the lender all of the back payments, late fees, penalties etc., that have accrued up to the date of the foreclosure sale, also called "curing the arrearages" - and then you can go back to making your normal monthly mortgage payments on time - but you normally only have until the time the foreclosure sale takes place to "cure the arrearages".
2. TRO: You may be able to seek a temporary restraining order, also called an "injunction", in the state court to temporarily stop the foreclosure sale, but you need to give the judge a reason to stop the foreclosure sale and you need to do this before the foreclosure sale. You must file for the TRO before the foreclosure sale. LARC may be able to help you with the TRO process. Please call us at 1-877-399-9995 for further information on a TRO.
3. Bankruptcy: File a petition in bankruptcy which automatically stops the foreclosure proceedings. In a Chapter 13 bankruptcy proceeding, you can have up to 60 months (5 years) to cure the back payments you owe to the lender and keep your home, as long as you can make the normal monthly payments going forward. A Chapter 7 bankruptcy will also automatically stop the foreclosure sale as well; however, once the Chapter 7 case is over, the mortgagee can reschedule the foreclosure sale.
Thursday, March 7, 2013
Lien stripping your second mortgage in a Ch. 13 Bankruptcy Case.
In a Chapter 13 bankruptcy case, you may be able to permanently remove your second mortgage - without paying it - if there is no value to secure it - and never pay it again.
How can this be?
In today's poor economic climate, real estate values are plummeting. This is one instance where your home's declining value can actually help you. For example, if you have a first mortgage where you owe a balance of $200,000 and a second mortgage (or home equity line) where you owe a balance of $75,000 - but your home is only worth $200,000 or less, then you may be able to "lien strip" the second mortgage and never pay it again. Simply, if your home's value will not support the second mortgage, the bankruptcy code allows you to remove it. This is called "lien stripping".
Chapter 13 may also allow you to get rid of unsecured debt such as credit cards and medical bills.
So, if you are facing the loss of your home, but you earn enough money to pay your first mortgage - Chapter 13 may allow you to get rid of your credit card debt, unpaid medical bills and get rid of your second mortgage.
This may mean the difference between saving your home or becoming homeless.
Learn more about Chapter 13 and how it can benefit you.
Chapter 13 may also allow you to get rid of unsecured debt such as credit cards and medical bills.
So, if you are facing the loss of your home, but you earn enough money to pay your first mortgage - Chapter 13 may allow you to get rid of your credit card debt, unpaid medical bills and get rid of your second mortgage.
This may mean the difference between saving your home or becoming homeless.
Learn more about Chapter 13 and how it can benefit you.
Tuesday, March 5, 2013
New Hampshire Statutes
Would you like to learn more about the law in New Hampshire? Well, you need not buy an expensive law book or subscribe to an expensive legal research service. Simply, click here for a free list of the New Hampshire statutes, click here:
Bankruptcy Code and Bankruptcy Rules
The Internet is a wealth of information for research.
Below are links to the Bankruptcy Code :
and the Bankruptcy Rules:
Filing for bankruptcy without a lawyer.
While filing a bankruptcy petition can be a challenge, even for an experienced lawyer, the law does allow you to file without an attorney and do it yourself. This is called proceeding pro se.
The New Hampshire Bankruptcy Court has a web site that provides helpful information on this subject.
Click her for more information:
Even if you decide to hire a lawyer, the court's web site is a valuable source of general information.
Foreclosure Time Line
In New Hampshire, most home mortgages have a "power of sale" clause.
A "power of
sale" clause means that the lender can take your home without taking you to
court if you are behind in your home mortgage payments.
Because of this "power
of sale" clause allowed in New Hampshire home mortgages, New Hampshire is called
a "non-judicial" foreclosure state.
A non-judicial foreclosure in New Hampshire can happen very quickly.
A non-judicial foreclosure in New Hampshire can happen very quickly.
If you are facing foreclosure, please call the LARC Hotline for more information about how you can fight back to keep our house, call 1-877-399-9995.
Take a look at the following time line from the HomeHelp web site to understand the process:
http://www.homehelpnh.org/timeline.htm
Here are the steps to losing your home:
1. Default: Meaning, you are not current in your payments.
2. You may also incur late fees, penalties and the lender's costs and fees for the lender's attorney for being in default - so being late in your mortgage payments may cause you to incur these $$$additional charges.
3. Bank sends you a notice of foreclosure sale at least 25 days before the foreclosure sale.
4. Lender advertises once a week for three weeks before the foreclosure sale of the date and time the foreclosure sale is going to take place.
5. Foreclosure sale: An auctioneer on behalf of the lender shows up on your front lawn on the day of the foreclosure sale and auctions off your home. Up to the point of foreclosure sale, you can "reinstate" by paying back the lender all the past due payments, costs, fees, late fees and penalties - again, it is not just paying back the late mortgage payments.
6. Whoever buys your home at the foreclosure sale has 60 days to record the foreclosure deed.
7. Eviction of the homeowner.
New Hampshire Representatives
Sometimes the
best place to start for help may be your own representatives.
In the great
State of New Hampshire, these are our current representatives in the year 2013 and their contact
information (click on the links below):
STATE
SENATORS:
Jeanne Shaheen
[D]
and
Kelly Ayotte [R]
Click here for
the official web site of the Unites States Senate:
GOVERNOR:
The governor for
the State of New Hampshire is Maggie Hassan.
U.S. STATE
REPRESENTATIVES:
Carol Shea
Porter [D] (1st Congressional District)
and
Ann
Kuster [D] (2nd Congressional District)
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