Leigh Morse, former director of the now infamous Salander-O’Reilly Galleries, may be incarcerated again for failing to timely pay restitution to the galleries’ defrauded clients, which include celebrity clients like Robert DeNiro.  It has been reported that more than three years have passed since her sentencing but Morse has only paid $22,000 of the $1.73 M restitution order.  It is not clear why Morse has not done more to make the restitution payments.  However, Morse owns a number of properties with her husband some of which are located in Pennsylvania, a tenancy by the entireties (TBE) state.  Owning property as TBE can be used to shield assets from creditors of just one spouse.  However, TBE designation does not protect against creditors of both spouses on joint debt.  It has been reported that Morse who is the operator of Leigh Morse Fine Arts is suffering financially because of the damage her criminal past has had on her ability to sell art.  Morse is scheduled to appear in court in March.  Hopefully, she will have made some payments by then.