Sasha Leonhardt
Partner
Biography
Sasha Leonhardt represents financial services industry clients in a wide range of enforcement, litigation and regulatory matters. He has assisted clients in resolving government investigations and enforcement actions before a wide variety of federal and state agencies, including the United States Department of Justice (DOJ), the Consumer Financial Protection Bureau (CFPB), the Office of the Comptroller of the Currency (OCC) and state attorneys general.
In The News
Buckley promotes five to partner
WASHINGTON, DC (March 31, 2021) – Buckley LLP announced that it promoted Jeffrey Hydrick, Katherine Katz, Sasha Leonhardt, Michael Rome, and Edward Somers to partner from counsel. "These five individuals, from three of our offices, have consistently provided exemplary legal work and guidance to our...
Press ReleasesAmanda R. Lawrence and Sasha Leonhardt extensively quoted in Cybersecurity Law Report article, “Familiar and fresh mandates in Virginia’s new privacy law”
Amanda R. Lawrence and Sasha Leonhardt were extensively quoted in the Cybersecurity Law Report article, “Familiar and fresh mandates in Virginia’s new privacy law,” which reported on the recently enacted Virginia Consumer Data Protection Act and how it is similar to and yet differs from the...
In The NewsJeremiah S. Buckley and Sasha Leonhardt discuss "Financial regulators’ dilemma: Regulatory modernization" during a Barefoot Innovation Group podcast
This podcast from the Barefoot Innovation Group features an interview with Jeremiah S. Buckley and Sasha Leonhardt on a major challenge facing financial regulators: Regulatory modernization. Click here to listen to the podcast .
In The NewsSasha Leonhardt quoted in Bloomberg BNA article, “Senate dems blast CFPB changes to military lending supervision”
Sasha Leonhardt was quoted on August 16, 2018 in a Bloomberg BNA article, “Senate dems blast CFPB changes to military lending supervision,” which discussed the criticism by Senate Democrats towards the Consumer Financial Protection Bureau regarding reports that the bureau’s supervisors will no...
In The NewsSasha Leonhardt mentioned in New Jersey Law Journal article, “BMW paying $2M to settle claims over lease refunds withheld from military personnel”
Sasha Leonhardt was mentioned on February 22, 2018 in a New Jersey Law Journal article, “BMW paying $2M to settle claims over lease refunds withheld from military personnel,” which discussed the settlement between the Department of Justice and BMW Financial Services N.A. to resolve the alleged...
In The NewsBuckley Sandler Announces Six Promotions for 2018
WASHINGTON, D.C. (Jan. 17, 2018) – Buckley Sandler LLP today announced the promotion of six associates in three of its offices to counsel, effective Jan. 1, 2018. “These six attorneys have worked diligently on behalf of our clients and are well deserving of promotion to counsel, “ said Andrew L...
Press ReleasesSasha Leonhardt Quoted in Hill Rag Article, “Pulling Them Back From the Brink”
Sasha Leonhardt was quoted on June 1, 2017 in a Hill Rag article, “Pulling Them Back From the Brink.” The article discussed the work of Legal Counsel for the Elderly (LCE), a non-profit organization dedicated to providing free legal and social work services to seniors in need. The article stated, “...
In The NewsSasha Leonhardt Quoted in Automotive News Article, "Lawyer Warns Lenders on Illegal Repos"
Sasha Leonhardt was quoted in Jim Henry's Automotive News article, "Lawyer Warns Lenders on Illegal Repos," on September 12, 2016. “This is not an area where anyone wants to play fast and loose, and take any unnecessary risk,” said Sasha Leonhardt, a lawyer in the Washington office of Buckley...
In The NewsSCRA's Relationship With Service Members And Corporate Ownership Gains Clarity With Recent Decision
Valerie Hletko and Sasha Leonhardt’s article, “ Corporations May Be People, But They Are Not Servicemembers ,” was highlighted in Richard Hoffman’s blog post on Thomson Reuter’s Legal Solutions Blog on September 6, 2016. Click here to read the full blog post.
In The NewsBuckley Sandler Hosts Eighth Annual Fair Lending Today Conference
Buckley Sandler LLP hosted its eighth annual Fair Lending Today conference in Washington, DC on March 13-14, 2016. The two-day event featured an evening of interactive roundtable discussions on fair lending issues, followed by a full day of seminars. The sessions were led by Buckley Sandler...
In The NewsBuckley Sandler Files Amicus Curiae Brief on Behalf of Industry Group in RESPA Case; Marks First Appeal Against CFPB Director Decision
On October 5, 2015, Buckley Sandler attorneys filed an amicus curiae brief on behalf of the Consumer Mortgage Coalition (CMC) in the first case to come up on appeal to the District of Columbia Circuit since the CFPB was founded in 2011. In the CMC’s brief, Buckley Sandler attorneys argued that the...
Press ReleasesBuckley Sandler Files Amici Curiae Brief on Behalf of Industry Groups in Supreme Court TILA Case
On September 17, Buckley Sandler filed an amici curiae brief on behalf of six industry associations in a Supreme Court case addressing the right to rescind a transaction under the Truth in Lending Act (TILA). In Jesinoski v. Countrywide , No. 13-684, the Court will consider whether borrowers must...
In The NewsBuckleySandler Hosts Eighth Annual Fair Lending Today Conference
BuckleySandler LLP hosted its eighth annual Fair Lending Today conference in Washington, DC on March 13-14, 2016. The two-day event featured an evening of interactive roundtable discussions on fair lending issues, followed by a full day of seminars. The sessions were led by BuckleySandler attorneys...
Press Releases
Publications
"CFPB revises UDAAP manual to include discriminatory practices" by Sasha Leonhardt, Jeffrey P. Naimon, and John R. Coleman (The Banking Law Journal)
The Consumer Financial Protection Bureau (“CFPB”) has announced significant revisions to its Unfair, Deceptive, or Abusive Acts or Practices (“UDAAP”) exam manual, in particular highlighting the CFPB’s view that its broad authority under UDAAP allows it to address discriminatory conduct in the...
Articles"9th Circ. FCRA ruling highlights furnishers' role in disputes" by Sasha Leonhardt and Cierra D. Newman (Law360)
In recent years, consumers have raised a variety of arguments to dispute negative information on their consumer reports — in some instances, raising not only factual questions about the existence or amount of a debt, but also more complex questions about whether a debt is legally permitted under...
Articles"Mortgage regulation developments: Qualified mortgage updates and Covid-19 assistance" by Sasha Leonhardt (ABA)
Throughout the past year, the Consumer Financial Protection Bureau (“CFPB”) continued to actively issue rules and other guidance applicable to the mortgage industry. This survey highlights recent developments related to qualified mortgages (“QM”), specifically the publication of four final rules...
Articles"U.S., E.U. announce Trans-Atlantic data privacy framework: What companies can do now" by Elizabeth E. McGinn, Sasha Leonhardt, and Lauren Bomberger (CSLR)
The White House and European Commission in late March 2022 announced a new agreement in principle for trans-Atlantic data flows – the Trans-Atlantic Data Privacy Framework – that would replace the E.U.- U.S. Privacy Shield. The United States and European Union began negotiations on a new framework...
Articles"Opinion: How mortgage servicers can prepare for a crackdown from the CFPB” by Sasha Leonhardt, Jon David D. Langlois, and David McGee (National Mortgage News)
The Consumer Financial Protection Bureau is drawing a line in the sand for the mortgage servicing industry with new guidance and proposed revisions to its mortgage servicing rules. The CFPB expects that the impending expiration of federal foreclosure and forbearance protections for mortgagees will...
Articles"The pendulum always swings twice: Disparate impact under the Obama, Trump, and Biden administrations" by Jeffrey P. Naimon and Sasha Leonhardt (American Bar Association Consumer Financial Services Committee Newsletter)
For over forty years, courts took the lead on interpreting the Fair Housing Act’s (“FHA’s”) prohibition on discriminatory housing practices, including home mortgage lending. While different administrations have varied as to whether the Supreme Court’s disparate impact theory from the Griggs v. Duke...
Articles"Empire state of privacy: Recent developments in New York’s privacy and cybersecurity laws" by Elizabeth E. McGinn, Amanda R. Lawrence, Sasha Leonhardt, and Magda Gathani (New York Law Journal)
New York over the past few years has steadily raised the bar on privacy and cybersecurity standards for commercial enterprises, and, along with the European Union and California, is increasingly seen as a pacesetter in this fast-developing area of law. Proposed legislation before its General...
Articles"After storm and fire: How states protect service members" by Jeffrey P. Naimon and Sasha Leonhardt (Law360)
This has been an active year for National Guard call-ups to active duty, as the U.S. addresses hurricanes, wildfires and the novel coronavirus pandemic. National Guard activations are likely to remain high for several months due to ongoing responses to COVID-19, the National Oceanic and Atmospheric...
Articles"School of hard knocks: Federal student loan servicing and the looming federal student loan crisis" by Jeffrey P. Naimon, Sasha Leonhardt, and Sarah B. Meehan (American University Administrative Law Review)
Nearly forty-three million Americans collectively owe $1.5 trillion in outstanding student loan debt. Of that, approximately ten percent of student loan debt is over ninety days delinquent or in default, while the actual delinquency rate is estimated to likely be double this amount due to the fact...
Articles"Financial regulators’ dilemma: Administrative and regulatory hurdles to innovation" by Jeremiah S. Buckley and Sasha Leonhardt (George Washington University Law School: Business & Finance Law Review)
Developments in financial technology hold great promise to enhance the quality, delivery, and reach of consumer financial services. However, many of the laws dictating the operations of financial regulators are more than 50 years old, and in drafting these laws Congress understandably did not...
Articles"State privacy law initiatives to prepare for in 2020" by Amanda R. Lawrence, and Sasha Leonhardt (Law360)
The California Consumer Privacy Act, which went into effect on Jan. 1, gave California residents the broadest rights in the nation to learn what data a business has about them, to request that the business delete that data and to demand that the business not sell their data. The CCPA opened a...
Articles"Managing legal risks to U.S. companies from foreign cyberattacks" by Amanda R. Lawrence, Sasha Leonhardt, and James C. Chou (Cybersecurity Law Report)
Protecting online systems against individual hackers has been a top priority for companies for several years, but as we begin a new decade, a new threat has risen to the forefront: well-funded and sophisticated foreign governments seeking to wage a new kind of warfare on the United States. In...
Articles"Website cookies and privacy—GDPR, CCPA, and evolving standards for online consent" by Amanda R. Lawrence, Sasha Leonhardt, and Magda Gathani (Bloomberg Law)
Virtually all companies with high-traffic websites use cookies to track visitors’ online experience, but global best practices in disclosing the use of cookies—and obtaining visitors’ consent to their use—have proven elusive despite intense scrutiny from privacy advocates. With requirements varying...
Articles"Dorian update: How state laws protect servicemembers" by Jeffrey P. Naimon and Sasha Leonhardt (Law360)
Hurricane Dorian devastated the Bahamas and southeastern United States in late August and early September, and the governors of Florida, Georgia, North Carolina, South Carolina and Puerto Rico authorized the activation of state National Guard forces for response efforts. In addition, the Rhode...
Articles"Takeaways from military member complaints at CFPB" by Jeffrey P. Naimon, Sasha Leonhardt, and Christina R. Smith (Law360)
The Consumer Financial Protection Bureau ’s Office of Servicemember Affairs recently released a report highlighting issues facing military consumers based on complaints submitted by service members, veterans and their families. This report identifies categories and trends among the approximately 48...
Articles"Hurricane Florence: How state laws protect service members" by Jeffrey P. Naimon and Sasha Leonhardt (Law360)
As the southeastern United States braces for Hurricane Florence, the governors of North Carolina, South Carolina and Virginia have authorized their state National Guard for response efforts, and neighboring governors in Maryland and West Virginia have placed their National Guard members on notice...
Articles"The devil is in the details: LabMD imposes limitations on the FTC’s enforcement authority" by Elizabeth E. McGinn and Sasha Leonhardt, (Cybersecurity Law Report)
In the latest data security case with significant implications for all enforcement actions, the United States Court of Appeals for the Eleventh Circuit struck down a cease-and-desist order as impermissibly vague. By ruling against the FTC in its long-running and contentious dispute with LabMD, the...
Articles"Neither forgiven nor forgotten: Taxation and UDAAP concerns with collecting charged off debt" by Sasha Leonhardt (Bloomberg BNA)
When debtors are unable to pay their debts, creditors are left with a choice: (i) allow the consumer to pay a lesser amount, if possible, to settle the obligation and recover some funds; or (ii) charge off the debt and cease all collection efforts. Regardless of the path chosen, each has potential...
Articles"The role of State AGs in solving student loan crisis" by Sasha Leonhardt (Law360)
State attorneys general are the chief legal officers of their state; state attorneys general are the chief law enforcement officers of their state; and state attorneys general must protect their citizens and vigorously enforce their state’s consumer protection statutes. As broad as these powers and...
Articles"Between a Rock and Hard Place: Debt Collection, Consumer Remediation and Tax Consequences" by Sasha Leonhardt (Bloomberg BNA)
In recent years, debt collection has become a focal point for regulatory oversight and government enforcement actions. The Consumer Financial Protection Bureau (CFPB) considers debt collection to be a priority and scrutinizes the conduct of debt collectors for violations of the Fair Debt Collection...
ArticlesJeffrey P. Naimon and Sasha Leonhardt Authored a Law360 Article, "Harvey Crisis: How State Laws Will Protect Servicemembers"
As Hurricane Harvey devastated Houston and southeastern Texas this past weekend, thousands of first responders were called to action to provide critical assistance to communities along the Gulf Coast. Even as this storm continues to affect those along the water and move inland, rescue operations,...
ArticlesSpecial Alert: D.C. Circuit Panel Rejects CFPB's RESPA Interpretation and Alters its Structure in PHH Corp. v. CFPB
On October 11, a three-judge panel of the U.S. Court of Appeals for the District of Columbia Circuit issued an opinion vacating a $109 million penalty imposed on PHH Corporation under the anti-kickback provisions of the Real Estate Settlement Procedures Act (RESPA), concluding that the CFPB...
ArticlesSpecial Alert: Department of Defense Issues Interpretive Rule Regarding Compliance with the Military Lending Act
Today, the Department of Defense (“DoD” or “Department”) published in the Federal Register an interpretive rule regarding compliance with its July 2015 amendments to the regulations implementing the Military Lending Act (“MLA”). The July 2015 amendments will extend the MLA’s 36% military annual...
ArticlesCorporations May Be People, But They Are Not Servicemembers
The Servicemembers Civil Relief Act enables servicemembers “to devote their entire energy to the defense needs of the Nation” by deferring or suspending certain obligations during active duty and for certain periods after the end of active duty. The SCRA’s core protections include interest-rate...
Articles100 Days Until the MLA: Compliance Challenges and Open Questions Before the New MLA's Rule Implementation
With only 100 days until the new Military Lending Act (MLA) rule takes effect on October 3, 2016, many financial institutions have begun enacting procedures to ensure they are compliant with the new regulation by the effective date. With the implementation of this new rule, financial institutions...
ArticlesExpanding the SCRA, If the DOJ Has Its Way
The last few weeks of 2015 saw two important legislative developments relating to the Servicemembers Civil Relief Act (SCRA). First , in November, the Department of Justice (DOJ) submitted a legislative package to Congress with proposed revisions to several existing laws that protect service...
ArticlesCitizen, Soldier, Small Business Owner? Commercial Lending and the Servicemembers Civil Relief Act
The Servicemembers Civil Relief Act, 50 U.S.C.A. § 3901, provides certain protections to military servicemembers regarding their financial obligations. The act applies to virtually every type of debt that a service member may obtain. It provides benefits such as an interest rate cap and procedural...
ArticlesLandlords, Leases and The Servicemembers Civil Relief Act
As President Obama slows the drawdown of troops overseas — and as the nation expands its fight against ISIS — a growing number of service members will seek the benefits and protections of a nearly century-old law that protects them on the homefront while they serve on active duty: the...
ArticlesConsumer Financial Services Answer Book 2016
The fifth edition of the Practising Law Institute’s Consumer Financial Services Answer Book was published this month, with 29 Buckley Sandler attorneys contributing to this leading desk reference. The 2016 edition of the Consumer Financial Services Answer Book continues to provide practitioners...
ArticlesSpotlight on the Military Lending Act, Part 3: Falling in Line with MLA Compliance
With recent changes in the regulations implementing the Military Lending Act (“MLA”), creditors are now reevaluating their compliance plans to ensure they are prepared for the new regulations. Although there is no formal guidance on what federal regulators will look for in reviewing MLA compliance...
ArticlesDebt Collection in the Post Dodd-Frank Enforcement Era
Sasha Leonhardt and Jessica Pollet authored "Debt Collection in the Post Dodd-Frank Enforcement Era," which appeared in the January/February issue of The Journal of Taxation and Regulation of Financial Institutions. Since the passage of the Dodd-Frank Act, government agencies have increasingly...
ArticlesA New Balancing Act: The DOJ Provides New Direction Regarding the SCRA's Interest Rate Benefit
When Congress reenacted the Servicemembers’ Civil Relief Act (“SCRA”) in 2003, Congress designed the SCRA to balance the interests of active duty servicemembers and their creditors, as it had done under the SCRA’s predecessor legislation. One of the benefits provided by the SCRA is a six-percent...
ArticlesCaveat Emptor or Caveat Vendor? The Evolution of Unfairness in Federal Consumer Protection Law
Under the Federal Trade Commission’s original interpretation of unfair or deceptive acts or practices law, financial institutions could feel some sense of security that, if they provided a consumer with a clear understanding of a proposed transaction, the burden was on the consumer to determine...
ArticlesSpecial Alert: Supreme Court Hears Oral Arguments on Fair Housing Act Disparate Impact Case
This morning, the Supreme Court heard oral arguments in Texas Department of Housing and Community Affairs v. The Inclusive Communities Project , in which Texas challenged the disparate impact theory of discrimination under the Fair Housing Act (FHA). Twice before, the Court granted certiorari on...
ArticlesJustices' Questioning in Jesinoski May Be Cause for Concern
Section 1635 of the Truth in Lending Act provides that a borrower may rescind certain mortgage loans within three days as a matter of right, and within three years if certain conditions are satisfied. The three-year extended rescission right applies only if a borrower does not receive certain...
ArticlesStarter Interrupters Expose Lenders to SCRA Risks
As the subprime auto loan market has grown over the past few years, so too have the number of starter interrupters in use. According to a recent New York Times story, these devices have been installed in approximately 2 million vehicles and are used in about one-quarter of all subprime auto loans...
ArticlesConsumer Financial Services Answer Book 2015
Buckley Sandler lawyers played a prominent role in the publication of this leading desk reference on consumer financial services, published by the Practising Law Institute. The 2015 edition of this publication continues to provide practitioners with a core understanding of the laws governing...
ArticlesBuckley Sandler Files Amici Curiae Brief on Behalf of Industry Groups in Supreme Court TILA Case
On September 17, Buckley Sandler filed an amici curiae brief on behalf of six industry associations in a Supreme Court case addressing the right to rescind a transaction under the Truth in Lending Act (TILA). In Jesinoski v. Countrywide , No. 13-684, the Court will consider whether borrowers must...
ArticlesFrom Landlord to Locked Up: The Long Arm of the SCRA
Over the past few years, the U.S. Department of Justice and federal banking regulators have aggressively increased their efforts to enforce the SCRA. Both federal and state regulators now focus on SCRA compliance when examining institutions, and government enforcement attorneys are keenly aware of...
ArticlesHighway to the Danger Zone: Automotive Lending and the Servicemembers Civil Relief Act
Over the past few years, federal regulators — led by the Department of Justice — have sharply increased their focus on SCRA compliance. Although most recent headlines related to SCRA enforcement have arisen in the area of home mortgages, several major enforcement actions and multi-million dollar...
ArticlesLenity, Chevron Deference, and Consumer Protection Laws
Several federal statutes, including the Real Estate Settlement Procedures Act (“RESPA”), the Truth in Lending Act (“TILA”) and the Servicemembers Civil Relief Act (“SCRA”) permit the government to seek either civil or criminal penalties for the same conduct. While the executive branch has used its...
ArticlesBitcoin, Banks & Billions: Regulatory and Compliance Implications of Bitcoin-Based Consumer Banking
With virtual currencies becoming a fixture of the global economy, it is critical that financial institutions understand these 21st century monetary tools. And, of all the virtual currencies emerging in the dynamic area of e-commerce, none more perfectly demonstrates the technical, regulatory and...
ArticlesStudents, Loan Servicers, and the Servicemembers Civil Relief Act
Over the past two years, mortgage loan servicers have faced an onslaught of regulatory scrutiny, enforcement actions and targeted litigation. The Department of Justice, state attorneys general and the federal banking regulators have extracted tens of billions of dollars in settlements, borrower...
ArticlesSpotlight on Student Lending, Part 2: Lessons Learned from CFPB Reports
In 2012 and 2013, the Consumer Financial Protection Bureau released several major reports and held field hearings focused on private student lending and servicing. In addition to recent CFPB activity, on June 25, 2013, the Senate Banking Committee held a hearing regarding private student loans at...
ArticlesSpotlight on Student Lending, Part 1: Facing Increased Regulatory Scrutiny, Student Loan Lenders Prepare for CFPB Examinations
Currently, total outstanding student debt (both federal loans and private loans) has risen to roughly $1.1 trillion dollars. That figure represents an over 50% increase since 2008 and makes student loans the largest source of unsecured consumer debt – surpassing credit cards. At the same time, at...
Articles'You Can't Handle the Truth!' Fact, Fiction and the Servicemembers Civil Relief Act
Over the past year and a half, several federal agencies, including the Department of Justice, Office of the Comptroller of the Currency and Federal Reserve Board, have turned their attention to promoting compliance with the Servicemembers Civil Relief Act, 50 U.S.C. app. §§ 501. Because military...
ArticlesThe Paper Chase: Effects of FDIC Document Retention Policies on D&O Suits
As the Federal Deposit Insurance Corporation continues to pursue professional liability suits against directors and officers of failed banks, the agency's recent regulatory guidance addressing the removal or copying of internal bank documents for both failed and troubled banks has further tilted...
ArticlesThe Consumer Financial Protection Bureau's Whistleblower Program: How It Works and What It Means for Financial Services Companies
Whistleblowers are "often the best source of information about waste, fraud, and abuse...." -President Barack Obama On December 15, 2011, the Consumer Financial Protection Bureau (Bureau or CFPB) issued a bulletin announcing its program to collect whistleblower information and law enforcement tips...
ArticlesFirst Do No Harm: An Analysis of the Broad Powers of the CFPB
In his remarks at the signing ceremony for the Dodd-Frank Wall Street Reform and Consumer Protection Act, President Obama promised that the arsenal of consumer protections included in the new law would be "enforced by a new consumer watchdog with just one job: looking out for people -- not big...
ArticlesHeightened Standards: What Wal-Mart v. Dukes Means for Future Class-Action and Consumer Finance Litigation
Elizabeth E. McGinn and Sasha Leonhardt discuss the recent U.S. Supreme Court ruling regarding class certification in Wal-Mart v. Dukes , a labor and employment case, and what the opinion means for consumer finance class actions going forward. Also published in: November 2011 edition of the Westlaw...
ArticlesFrom Pickpockets to Playstations: Evolving Data Privacy Threats and Federal and State Responses
In recent years, there have been several high-profile security breaches relating to consumer financial data. These breaches - involving companies as diverse as GE Money, AOL, T.J. Maxx, Boeing, Rite Aid, and most recently, Sony's PlayStation Network - have revealed the personal information of...
Articles
Practice Areas
- Alternative Finance
- Appellate
- Auto Finance
- Bank Counseling & Compliance
- Consumer Finance
- Consumer Financial Protection Bureau
- Credit, Debit & Prepaid Cards
- Debt Collection & Buying
- Enforcement Actions & Investigations
- Examinations
- Fair Lending and Fair Servicing
- Federal Trade Commission
- Fintech
- Military Lending
- Mortgages
- Privacy, Cyber Risk & Data Security
- State Attorneys General
- Student Lending
- Unfair, Deceptive, or Abusive Acts or Practices
Education
- J.D., Duke University, 2010 (cum laude)
- A.B., Princeton University, 2005
Admissions
- District of Columbia
- Maryland
- New York
- U.S. Supreme Court
- U.S. Court of Appeals for the District of Columbia Circuit
- U.S. District Court, Southern District of Indiana
Government Service
- Deputy Press Secretary, Maryland Governor Martin O’Malley
Memberships & Involvements
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CIPM/US-certified professional, International Association of Privacy Professionals
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CIPP/US-certified professional, International Association of Privacy Professionals
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Member, Princeton University Washington DC Alumni Association
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Member, Young Lawyers Alliance for the Legal Counsel for the Elderly
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