General Information

Should a Single Member LLC Have an Operating Agreement?

Question: I am the sole member of my Arizona limited liability company. Should I sign an Operating Agreement for my LLC?

Answer: Although Arizona LLC does not require that the members of an Arizona LLC sign an Operating Agreement, as an Arizona LLC attorney I highly recommend that all members of an Arizona LLC, including single member LLCs, sign a “good” Operating Agreement. A good Operating Agreement is a document that is drafted specifically to comply with Arizona’s LLC law and that contains provisions and language needed by most LLCs and their members. The fact the members of an LLC sign an Operating Agreement could actually be detrimental to the members if the Operating Agreement is poorly written or not written specifically to comply with Arizona LLC law.

There are several reasons why the sole member of an LLC should sign an Operating Agreement:

  • Some banks require an Operating Agreement signed by the sole member before opening a bank account in the LLC’s name.
  • If the LLC will ever buy or sell real property the title insurance / escrow company will require an Operating Agreement signed by the sole member.
  • If the LLC were to borrow money the lender will require an Operating Agreement signed by the sole member
  • When courts are asked to pierce the company veil and hold the sole member liable for the debts of the LLC one of the factors that counts against the member is the lack of an Operating Agreement. If you don’t have a signed Operating Agreement it tells the judge and jury that you are treating your LLC like a hobby rather than a business. Businesses have signed Operating Agreements signed by their owners.
  • To set the rules that govern the operation of the company if the sole owner were to die and his or her interest is inherited by one or more loved ones.

A good Operating Agreement is a complex document that should cover a lot of important ground. It should be drafted by an experienced LLC attorney licensed to practice in the LLC’s state of formation. As a business lawyer who has practiced law in Arizona since 1980 I’ve prepared 5,800+ Operating Agreements and spent hundreds of hours researching and revising my Operating Agreement.

How to Hire Arizona LLC Attorney Richard Keyt to Prepare an Operating Agreement

To hire Richard Keyt to prepare an Operating Agreement for your sole member Arizona or California LLC for $297 complete and submit his online Operating Agreement Questionnaire.

By | 2017-05-30T21:38:45+00:00 April 29th, 2017|General Information, Single Member LLCs|

Does Your LLC’s Operating Agreement Say What Happens if a Member or the LLC Gets a Judgment Against a Member?

Homer Simpson and Ned Flanders owned 60% and 40%, respectively, of World Wide Widgets, LLC, an Arizona limited liability company. WWW manufactures and sells widgets. Without WWW’s knowledge or consent Ned began working for Arizona Widgets, LLC, a competitor of World Wide Widgets, LLC.

WWW sued Ned for breach of fiduciary duty and misappropriation of trade secrets by disclosing information to Arizona Widgets, LLC. The Arizona court awarded WWW a judgment for $100,000 and ordered that Ned transfer his entire membership interest in the LLC to the LLC.

WWW can use the collection process to collect the money from Ned’s non-WWW assets, but can WWW acquire Ned’s membership interest in the LLC if Ned does not voluntarily transfer his membership interest to the LLC? Arizona Revised Statutes Section 29-655 states:

“On application to a court of competent jurisdiction by any judgment creditor of a member, the court may charge the member’s interest in the limited liability company with payment of the unsatisfied amount of the judgment plus interest. To the extent so charged, the judgment creditor has only the rights of an assignee of the member’s interest. . . . This section provides the exclusive remedy by which a judgment creditor of a member may satisfy a judgment out of the judgment debtor’s interest in the limited liability company.”

Emphasis added.

Section 29-655 seems to prevent WWW from forcing Ned to transfer his membership interest to the LLC because the charging order is WWW’s sole remedy.

The WWW fact pattern is similar to the facts in a recent Texas LLC case called “Gillet v. ZUPT LLC,” Houston 14th Court of Appeals, Case No. 14-15-01033-CV, 2/23/17. In this case ZUPT, LLC, got a judgment that required its member Joel Gillet to transfer his entire membership interest to ZUPT, LLC. Like Arizona, Texas LLC law provides that the charging order is the sole remedy of a creditor who gets a judgment against a member of a Texas LLC.

The Texas Court of Appeals ruled that the charging order exclusive remedy statute did not prevent a court order that Gillet transfer his membership interest to the LLC. The Court stated:

“We hold that requiring turnover of a membership interest under these circumstances is proper for two reasons. First, the reasoning behind requiring a charging order as the exclusive remedy is inapposite when the judgment creditor seeking the membership interest is the entity from which the membership interest derives. Second, unlike a case in which a judgment creditor seeks to collect on its money judgment by forcing a sale of a membership interest, this case involves an explicit award of the membership interest itself from one party to the other as part of the judgment. For these reasons, we conclude that a charging order was not the exclusive remedy available to ZUPT, and the trial court did not abuse its discretion by ordering turnover of Gillet’s 45 percent interest in ZUPT.”

Unfortunately for Homer and World Wide Widgets, LLC, no Arizona appellate court has issued an opinion similar to the ZUPT, LLC, vs. Gillet opinion. WWW will be forced to litigate the issue and hope to get an order at the appellate level requiring transfer of the membership interest to WWW.

Warning for Multi-Member Arizona LLCs

The lesson to be learned from the ZUPT, LLC, vs Gillet case is that all multi-member LLCs should have provisions in their Operating Agreements that provide appropriate remedies if a member of the LLC or the LLC get a judgment against another member. The Operating Agreement should have language that creates remedies that allow the member or the LLC with the judgment to get around the exclusive remedy of Section 29-655. The remedies include a requirement that money be distributed to the creditor from funds payable to the debtor member and a requirement that the debtor member forfeit the debtor member’s membership interest in the LLC.

In an article called “Yet Another Intra-Member Dispute in ZUPT” debt collection attorney Jay Adkisson wrote:

“The decision by the Texas Court of Appeals is, in my humble opinion, right on target, but it by no means reflects (yet) anything like a majority rule or a judicial re-writing of the cold, hard language of the charging order statutes.

Practitioners who are drafting LLC and partnership agreements need to recognize this issue, and confer with the members as to what they want the outcome to be. If one member becomes indebted to the other members or the LLC, do they want to be restricted by a charging order or not? It should be relatively easy to draft around this issue, but in my experience almost nobody does so.”

As a result of ZUPT, LLC, vs Gillet and Jay Adkisson’s advice I have amended my multi-member LLC Operating Agreement to provide special remedies if a member or the LLC get a judgment against another member.

By | 2017-05-29T09:16:30+00:00 March 11th, 2017|General Information|

Do Members of an Arizona LLC Owe Fiduciary Duties to Other Members?

Question: “Does a member of an Arizona limited liability company owe other members of the company any fiduciary duties?

Answer: A March 27, 2014, Arizona Court of Appeals opinion in the case of TM2008 Investments, Inc., vs. ProCon Capital Corp. says that the members of an Arizona limited liability company do not owe any fiduciary duties to the other members unless the members signed an Operating Agreement that creates and imposes contractual fiduciary duties on the members.

Since the TM2008 Investments case involves fiduciary duties we should first explain what the term means. The Cornell University Law School Legal Information Institute says the following about fiduciary duties:

“A fiduciary duty is a legal duty to act solely in another party’s interests. Parties owing this duty are called fiduciaries. The individuals to whom they owe a duty are called principals. Fiduciaries may not profit from their relationship with their principals unless they have the principals’ express informed consent. They also have a duty to avoid any conflicts of interest between themselves and their principals or between their principals and the fiduciaries’ other clients. A fiduciary duty is the strictest duty of care recognized by the US legal system.”

If a person owes a fiduciary duty to another person it also means it is much easier for the principal to sue the fiduciary for breach of a fiduciary duty and win a judgment because there is a higher standard of care associated with the fiduciary duty than would otherwise apply.

The TM2008 Investments, Inc., vs. ProCon Capital Corp. case arises from a dispute among the two members of Doveland Developments, LLC, a company formed to buy land and develop it into homes. Unfortunately the project was not successful. The lender threatened to foreclose and sell the land and go after the owners of the two members (Steve Tackett and Bonnie Vanzant) of Doveland Developments, LLC, because they had personally guaranteed the payment of the loan. The members of Doveland Developments, LLC, are TM2008 Investments, Inc., and ProCon Capital Corp.

When the lender notified the parties that the loan was in default Bonnie Vanzant paid the loan in full. She then sued Steve Tackett under an indemnification agreement they had signed to collect from Steve one half of the money Bonnie paid to the lender under her personal guaranty of the loan. TM2008 Investments filed a petition to dissolve and liquidate Doveland Developments due to the inability to conduct business in light of the members’ substantial disagreements. ProCon Capital filed counterclaims against TM2008 Investments for breach of the implied covenant of good faith and fair dealing (count 1) and breach of contract (count 3), and against TM2008 Investments and the Bonnie and James Vanzant personally for breach of fiduciary duty (count 2).

The lawsuits were consolidated. The trial court granted Bonnie Vanzant’s motion for summary judgment on the indemnification claim, but denied TM2008 Investments’ motion for summary judgment on the counterclaims. Just before trial, ProCon Capital voluntarily dismissed with prejudice counts 1 and 3. After jury trial on the claim for breach of fiduciary duty, the jury returned a verdict in favor of ProCon Capital and against TM2008 Investments and the Vanzants personally for $1,039,754. The losers appealed.

The primary issue before the Arizona Court of Appeals was whether or not Arizona’s limited liability company law provides that a member of an Arizona LLC owes a fiduciary duty to the other members of the LLC. ProCon Capital argued that because Arizona corporate and partnership law create fiduciary duties on shareholders and partners, respectively, Arizona law must therefor create fiduciary duties on members of an Arizona LLC. The appellate court disagreed. The court said:

We decline in this case to mechanically apply fiduciary duty principles from the law of closely-held corporations or partnerships to a limited liability company created under Arizona law. The legislature did not explicitly outline any such duties for members of an LLC; instead, the LLC Act allows the members of an LLC to not only create an operating agreement, but also delineate in that agreement the duties members owe one another.”

Translation: The court said Arizona’s LLC statutes do not subject members of Arizona LLCs to any fiduciary duties and neither do any Arizona appellate court opinions.

However, the court said that an Operating Agreement can contain language that creates one or more fiduciary duties on members. The Operating Agreement of Doveland Developments, LLC, contained this clause that ProCon Capital aruged created a fiduciary duty on TM2008 Investments, Inc, and Bonnie and James Vanzant:

It is agreed any Member shall not be liable to the Company or any other Member for any damages or the like relating to any vote, decision, action, inaction or the like taken on behalf of the Company in accordance with these provisions and other provisions of this Agreement if such is done in good faith and with reasonable business judgment including the duty to make management decisions with the care of an ordinarily prudent person in a like position and similar circumstances and in a manner believed to be in the best interests of the Company.

The appellate court found that the above quoted language did not create a fiduciary duty on the members.

The court reversed the trial court and sent the case back to the trial court.

Lessons to Be Learned

The TM2008 Investments, Inc., vs. ProCon Capital Corp. case stands for the following:

  • Arizona’s statutes that govern Arizona limited liability companies do not create fiduciary duties on members.
  • Members of an Arizona LLC can create one or more fiduciary duties by inserting appropriate language in the LLC’s Operating Agreement.

The issue of whether the Operating Agreement of a multimember Arizona LLC should or should not contain fiduciary duty provisions is a topic for another article. Hint: A member in control of an Arizona LLC would not want any fiduciary duties in the Operating Agreement, but the minority member would want the opposite.

By | 2017-05-29T10:54:08+00:00 February 21st, 2017|General Information|

Why Your Arizona LLC Needs Richard Keyt’s Custom Operating Agreement

I formed my first Arizona LLC the day the Arizona LLC law became effective in October of 1992.  Since then I have formed 5,800+ Arizona LLCs.  In practicing LLC law since 1992 I have seen the same LLC operational problems over and over.  When I learn about an operational problem I add new language to my LLC Operating Agreement to “fix” or prevent the problem.

For example, one of the most common LLC operational problems occurs when members cannot agree and need a company divorce.  When members have major disagreements over running the LLC it is very common for a member without any authority or basis to file an amendment to the LLC’s Articles of Organization that removes one or more members as members of the LLC.  The culprit may also open a new bank account and misrepresent to the bank who the members of the LLC are.

People who file false documents with the Arizona Corporation Commission are usually unaware that they could be committing a felony.  Arizona Revised Statutes Section 29-613.A states:

“A person who . . . signs any articles . . . or other document filed with the [Arizona Corporation] commission that is known to the person as false in any material respect is guilty of a class 4 felony.”

Unfortunately the Arizona Attorney General does not prosecute people who file false documents with the Arizona Corporation Commission.

The purpose of Arizona Revised Statutes Section 29-858 is to reduce false filings with the Arizona Corporation Commission and give aggrieved members a remedy.  This statute states:

“any person that authorizes or signs a report, certificate, notice or other document with respect to a limited liability company that is delivered for filing with the commission pursuant to this chapter and that has knowledge at the time of delivery to the commission for filing that the information contained in that report, certificate, notice or other document is materially false or misleading is liable to the limited liability company and its creditors and members for all damages resulting.”

The problems with this statute are: (i) proving damages for a false filing is very difficult, and (ii) the cost to sue coupled with the risk of winning and collecting a judgment makes this remedy very risky.  Few members will actually use this statute to sue another member.

After seeing the false amendment to the Articles of Organization too many times I added a clause to my Operating Agreements that provides that a member who files a false document with the Arizona Corporation Commission is liable to all other members for liquidated damages of $10,000 and if the damages are not paid in full within sixty days the member who filed the false document ceases to be a member.

Why Your Existing or New Arizona LLC Needs Richard Keyt’s State of the Art Operating Agreement

I have prepared 5,800+ LLC Operating Agreements.  My Operating Agreement is unlike any Operating Agreement prepared by anybody else including attorneys because it contains provisions I created to prevent or solve common LLC operational problems I have seen representing thousands of LLCs.  For a partial list of common LLC operational problems see my article called “Common LLC Disasters a Good Operating Agreement Prevents.”

To hire me to prepare an Operating Agreement for an LLC that does not have one or to amend an Operating Agreement for an LLC whose members signed an Operating Agreement complete my comprehensive Operating Agreement Questionnaire.

P.S.  To see Operating Agreement provisions in my Operating Agreements that you will not get any where else scroll to the bottom of my Operating Agreement Questionnaire.

By | 2017-05-29T09:31:13+00:00 December 24th, 2016|General Information|

How a Married Couple Owns an Arizona LLC as Community Property

Married Arizona residents can own property as: (i) separate property, (ii) community property or (iii) community property with right of survivorship, sometimes referred to as “CPWROS.” Arizona law provides that if a married Arizona resident acquires property from any source, the property is automatically the community property (not community property with right of survivorship) of the couple unless the property was a gift or inherited property.

When a married Arizona resident acquires property from a gift or by inheriting the property that person owns the property as his or her separate property. Separate property also includes property of a spouse acquired before the marriage.  The non-owner spouse has no interest in or claim to his or her spouse’s separate property.

When property is owned as community property or community property with right of survivorship then each spouse owns an undivided one half of the property and if they divorce, each spouse is entitled to one half the value of  the property.

Community Property Does Not Transfer to Heirs Automatically

The only difference between community property and community property with right of survivorship is what happens to the interest of the first spouse to die. When an Arizona married couple owns property as community property and one of them dies, the interest of the deceased spouse in the property does not transfer automatically to the other spouse. The interest of the deceased spouse in the property goes to the heir(s) named in the deceased spouse’s will or trust, but if there is no will or trust then the interest of the deceased spouse passes according to the law of intestate succession of the deceased spouse’s state of resident at the time of death. A probate may be required to complete the transfer to the property heir(s) unless the value of the interest of the deceased Arizona resident is less than $75,000 for personal property and $100,000 for real property.

Community Property with Right of Survivorship Transfers to Spouse Automatically

When an Arizona couple owns property as community property with right of survivorship then if one spouse dies, the interest of the deceased spouse transfers automatically to the surviving spouse without the need for a probate. If a married Arizona couple wants the community property interest of a deceased spouse to pass automatically to the surviving spouse on the death of the first spouse they must own the property as community property with right of survivoship.

How to Own an Interest in an Arizona LLC as Community Property with Right of Survivorship

Warning:  If a married couple who are Arizona residents form an Arizona LLC or acquire a membership interest in an existing LLC they automatically own their interest in the LLC as community property, not community property with right of survivorship. If they want to own their interest in the LLC as community property with right of survivorship they must sign an Operating Agreement that expressly declares that the married couple holds their interest in the limited liability company as community property with right of survivorship.  See Arizona Revised Statutes Section 29-732.01.C.

When people hire me to form their Arizona LLC and tell me they want to own their interest in the LLC as community property with right of survivorship then we insert language in the LLC’s Operating Agreement hat expressly declares that the married couple holds their interest in the limited liability company as community property with right of survivorship.

For more on this important topic read my article called “Warning for Married Arizona Residents Who Own LLCs.”  This article also explains how married Arizona residents can insure they own their LLCs as community property with right of survivorship.

By | 2017-05-30T22:03:17+00:00 November 24th, 2016|General Information, Membership Character|

Caution: Consequences of Member’s Death When Member Owns LLC as Community Property

Question: My husband and I acquired a 50% membership interest in an Arizona LLC as community property with right of survivorship. Homer & Marge Simpson own the other 50% of the LLC. My husband died and my husband’s interest in the LLC passed to me automatically per Arizona Revised Statutes Section 29-732.01.

Homer Simpson says that he and Marge now have control of the LLC because the 25% interest I acquired from my husband is a mere assignment of his interest and is not a membership interest with voting rights. The Simpsons say that I own a 25% membership interest in the LLC and the 25 votes associated with that membership interest and an economic right to 25% of the profits of the LLC without any voting rights. Homer says that since my husband’s death members have 75 total votes instead of 100, the Simpsons have 50 votes and I have 25 votes How many votes do I have?

Answer: The interest in the LLC that you inherited from your husband is a membership interest with voting rights rather than an assignment of an economic interest without voting rights if the members of your LLC signed an Operating Agreement that provides that when a married couple own their interest in the LLC as community property with right of survivorship and one of them dies, the interest of the deceased inherited by the survivor is a membership interest. Section 29-731.B.2. If the members of your LLC did not sign such an Operating Agreement then what you inherited from your husband was a 25% economic interest in the LLC without any voting rights.

Lesson to Be Learned: If your Arizona LLC has members who own their membership interests as community property with right of survivorship, joint tenancy with right of survivorship or tenants in common and the members want the heirs who inherit an interest to inherit membership interests with voting rights vs. economic interests without voting rights then the members of the LLC must sign an Operating Agreement that provides that inherited interests are membership interests with voting rights.

Note: My standard Operating Agreement contains this automatic membership interest with respect to inherited interests clause.

How to Hire Richard Keyt to Fix Your LLC’s Operating Agreement

To hire Arizona LLC attorney Richard Keyt to amend your existing Operating Agreement or prepare a new Operating Agreement complete our online Operating Agreement Questionnaire.

By | 2017-05-30T22:03:55+00:00 November 22nd, 2016|General Information, Member Death|

How Restrictions on Dissolution have Crippled the LLC

Attorney Tanya Simpson’s article in the Florida State University Law Review  entitled “How Restrictions on Dissolution have Crippled the LLC” is a detailed discussion of issues that face all multi-member LLCs.  The article is an in depth look at LLC dissolutions, aka LLC divorces.  She makes several points about multi-member LLCs that are worth reiterating:

  • Many multi-member LLCs do not have an Operating Agreement.
  • Many multi-member LLCs that have Operating Agreements do not have a good well drafted Operating Agreement.
  • Multi-member LLCs need a state of the art comprehensive Operating Agreement.

As an LLC attorney who has drafted 5,800+ Operating Agreements and has seen the nightmares that arise when multi-member LLCs need a company divorce, I recommend that all multi-member LLCs have an Operating Agreement written by an experienced Operating Agreement attorney.

Tanya Simpson says,

With the chaotic state of judicial dissolution provisions and the commensurate uncertainty as to how they will be interpreted, both from state to state and within the same state, a carefully drafted LLC operating agreement appears at present to be an LLC member’s best protection.

The very factors that make the LLC most attractive to small business entrepreneurs – simplicity of organization and flexibility of contract – likely also create an environment that is ripe for problematic  operating agreements. Because many small businesses are composed of family members and close friends, agreements may not always be negotiated at arm’s length. In addition, because of the few required formalities, many LLCs may have unsophisticated or boilerplate operating agreements, or may not have any operating agreement at all. Thus the very nature of the LLC may preclude it from protecting itself against the events of a bad break-up.

The freedom and flexibility to contractually organize the LLC grants members an opportunity to fashion a kind of prenuptial agreement to plan for the challenges of a potential business divorce.  That same freedom and flexibility, however, may lull members into drafting incomplete or unsophisticated operating agreements that, consequentially, will be of little use – or worse – in the  event of dissolution litigation. In the absence of an adequate operating agreement or in the likely event that even sophisticated drafters will not have considered every eventuality, courts will look to the default judicial dissolution provisions in the states’ LLC statutes to fill in the gaps.

By | 2017-05-29T15:36:56+00:00 May 29th, 2016|General Information|

Court Rules LLC Member not Obligated to Contribute Money to LLC

The New York case of Duff v.Curto, 2012 NY Slip Op 30264(U) (Sup Ct Suffolk County Jan. 25, 2012), by Suffolk County New York Justice Emily Pines involved a claim by one LLC member that the other member failed to contribute money to the company. Duff claimed he contributed $523,000 to the capital of Fairlea Court Holding, LLC, of which Gary Duff and Peter Curto, Jr., were the only two members. Duff claimed that Curto breached the Operating Agreement because he did not contribute any money to the company and that Curto was unjustly enriched.

They signed an Operating Agreement that said:

“[u]pon the execution of this Agreement, each Member shall contribute cash and/or property to the Company as set forth opposite their names in Exhibit A”

Exhibit A stated that each member had a 50% interest in the company, but it did not show that either member was to contribute any capital to the company. The Court said:

“The Court finds that the documentary evidence provided raises an issue of the parties intent in placing the 50% figure in the Agreement and does not definitively dispose of the plaintiff’s claim”

The Court found that Duff reported on his tax returns that he loaned $309,000 to the LLC and that Curto never agreed to contribute any money to the company.

Lesson for Members of LLCs

Arizona LLC law provides that no member of an Arizona limited liability company is liable to contribute money or property or services to the LLC unless the member agrees to do so in writing. Arizona Revised Statutes Section 29-702.A states:

“A promise by a member to make a capital contribution to the limited liability company is not enforceable unless set out in writing and signed by the member.”

California LLC law provides that a contribution is “in accordance with an agreement” with the initial members when forming the LLC, the company after forming the LLC or existing members after forming the LLC.  See California RULLCA Section 17701.02(c).

If you have an Arizona or a California LLC and want to create a legal obligation on the part of one or more members then the LLC must obtain a written document signed by the member(s) that states the amount of money or the description of the property or the nature and extent of the services and when the money or property or services must be contributed. The best way to obligate members of an LLC to contribute money or property to the LLC is in an Operating Agreement signed by all of the members.

By | 2017-05-29T14:53:50+00:00 April 7th, 2016|General Information|

Five Expensive Mistakes When Forming an LLC

New Jersey business litigator Jay McDaniel posted an article on his excellent blog called “New Jersey Business Dissolution Journal” that is a must read for every person who owns an interest in a limited liability company or may own an interest in an LLC. Jay’s article explains the five biggest mistakes people make when they form an LLC. The mistakes are the same mistakes I caution people against constantly when I form LLCs and advise the owners of existing LLCs.

Jay McDaniel is a business litigator whose opinions are based on years of experience representing business owners in disputes that arise from the ownership of businesses. Jay wrote:

“Having litigated many of these matters over the years, I see the same mistakes made early in the life of the business surfacing again and again as the source of litigation.”

McDaniel’s point is that the failure to plan when companies are created can be a very expensive blunder when a dispute among owners arises. Even though I am not a litigator (I never personally represent anybody in litigation), my experience as an LLC attorney who has formed 5,800+ LLCs is the same as McDaniel’s.

The list omits the mistake of not having an Operating Agreement. The following is what McDaniel says about the lack of an Operating Agreement:

“If a business does not have one, sooner or later, it will have problems and without any point of reference whatsoever, the probability of litigation is high. When that happens and the business is successful, the chances are that you will spend the price of a college education – at a nice private school – on the lawsuit.

Bottom Line:  All multi-member LLCs must have a well-drafted Operating Agreement.  Note I said “well-drafted” because a poorly worded Operating Agreement drafted by somebody who lacks LLC experience can be a bigger problem than no Operating Agreement.

Here’s Jay McDaniel’s list of the five biggest LLC formation mistakes (read the article to get the reasoning behind each mistake:

  1. No operational planning
  2. No contingency planning
  3. No valuation planning
  4. No succession planning
  5. No planning for amendments to the Operating Agreement.
By | 2017-05-30T22:06:52+00:00 February 29th, 2016|Avoiding Mistakes, General Information|