david r. zaro (bar no. 124334) ted fates (bar no....
TRANSCRIPT
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839638.01/SD
DAVID R. ZARO (BAR NO. 124334) TED FATES (BAR NO. 227809) TIM C. HSU (BAR NO. 279208) ALLEN MATKINS LECK GAMBLE MALLORY & NATSIS LLP 515 South Figueroa Street, Ninth Floor Los Angeles, California 90071-3309 Phone: (213) 622-5555 Fax: (213) 620-8816 E-Mail: [email protected]
[email protected] [email protected]
Attorneys for Receiver THOMAS SEAMAN
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
v. STEVE CHEN, USFIA, INC., ALLIANCE FINANCIAL GROUP, INC., AMAUCTION, INC., ABORELL MGMT I, LLC, ABORELL ADVISORS I, LLC, ABORELL REIT II, LLC, AHOME REAL ESTATE, LLC, ALLIANCE NGN,INC., APOLLO RIET I, INC., APOLLO REIT II, LLC, AMKEY, INC,, US CHINA CONSULTATION ASSOCIATION, and QUAIL RANCH GOLF COURSE, LLC,
Defendants.
Case No. 2:15-cv-07425 RGK-PLA RECEIVER'S SECOND REPORT AND RECOMMENDATIONS
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 1 of 46 Page ID #:1795
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TABLE OF CONTENTS
Page
839638.01/SD (i)
LAW OFFICES
Allen Matkins Leck GambleMallory & Natsis LLP
I. EXECUTIVE SUMMARY ............................................................................. 1
II. SUMMARY OF RECEIVER'S ACTIVITIES ............................................... 2
A. Company Offices .................................................................................. 3
B. Hills Garden Hotel ................................................................................ 3
C. Other Real Properties ............................................................................ 4
D. Funds Recovered to Date ...................................................................... 4
E. Law Firm Retainers ............................................................................... 5
F. Li Zhao and Ally Investors ................................................................... 6
G. Affiliated Entities .................................................................................. 7
H. Territorial Jurisdiction Over Receivership Assets ................................ 9
I. Investor Communications ................................................................... 10
J. Receivership Accounting .................................................................... 10
III. PRELIMINARY RECOMMENDATIONS .................................................. 11
A. Document Recovery Efforts ............................................................... 11
B. Receivership Asset Recovery Efforts and Investigation .................... 11
C. Accounting .......................................................................................... 11
D. Repatriation of Overseas Assets ......................................................... 12
E. Maintain Operations of the Hotel, Apartment Building, and Single Family Residential Properties ........................................... 12
F. Investor Communications and Claims Process ................................... 12
G. Asset Sales .......................................................................................... 12
IV. CONCLUSION ............................................................................................. 13
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Thomas A. Seaman ("Receiver"), Court-appointed receiver for Defendants
USFIA, Inc., Alliance Financial Group, Inc., Amauction, Inc., Aborell
Mgmt I, LLC, Aboreall Advisors I, LLC, Aborell REIT II, LLC, Ahome Real
Estate, LLC, Alliance NGN, Inc., Apollo REIT I, Inc., Apollo REIT II, LLC,
Amkey, Inc., US China Consultation Association, Quail Ranch Golf Course, LLC,
and their subsidiaries and affiliates (collectively, "Receivership Entities"), hereby
provides his second interim report and recommendations. This report contains a
summary of the Receiver's activities thus far and a financial report on the receipts
and disbursements for the receivership estate through December 31, 2015.
I. EXECUTIVE SUMMARY
This receivership involves a complex and wide ranging group of enterprises
and assets which appear to have been funded with the fruits of the fundraising
scheme at the heart of the action filed by the Securities and Exchange Commission
("Commission"). The Receiver has taken control of bank accounts identified in the
Appointment Orders as well as additional accounts identified through the Receiver's
investigation of documents and information found at the various locations where the
Receivership Entities conducted business. As of December 31, 2015, the gross
receipts were $21,945,974.51, primarily comprised of funds turned over to the
Receiver from financial institutions at the outset of the case or otherwise turned over
to or seized by the Receiver. As of that date, the Receiver had made disbursement
of $692,802.79 for necessary operating expenses of the Receivership Entities and
was holding cash in the amount of $21,253,171.72.
As previously reported, the Receiver has also identified and taken control of
the USFIA office building in Arcadia, a hotel in Rancho Cucamonga, an apartment
building in Alhambra, a warehouse, several single family homes, and parcels of
undeveloped land, including a proposed golf course site in Moreno Valley. The
Receiver has also obtained evidence of several additional pieces of real estate
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purchased with funds of the Receivership Entities and is further investigating these
transfers.
At this point, due to the volume of electronic data and disorganized manner in
which it was kept by the Receivership Entities, the Receiver has not yet been able to
identify the entire scope of the USFIA enterprise, the number of investors, or
specific amounts invested by investors and distributed to them. The Receiver's work
to analyze and better understand the investor data, with the assistance of his forensic
computer specialist, is ongoing. The Receiver has reviewed and analyzed certain
Quickbooks files and hard copy business documents. The Receiver has now
obtained most of the relevant bank records and is commencing his review of
accounting records and banking records to, among other things, trace assets and
prepare an accounting in accordance with the Appointment Order.
At this point, there is no indication there was any legitimate Gemcoin or other
viable business operated by the Receivership Entities. Aside from some income
generated by the hotel and rental properties, the Receivership Entities had no
significant source of income other than money raised from investors. The Receiver
has verified that virtually none of the assets described in online and written
marketing materials actually exist. Instead of mines located around the world,
millions of dollars in precious gems, and houses and cars available to be awarded to
investors, the Receiver has found only costume jewelry, boxes of rocks, and bins
filled with tens of thousands of little rings of nominal value.
As discussed in Section IV below, the Receiver recommends the receivership
continue in order to identify, marshal, and preserve the assets of the Receivership
Entities pending the outcome of the litigation and further orders of the Court.
II. SUMMARY OF RECEIVER'S ACTIVITIES
As discussed in his First Report and Recommendations (Dkt No. 19), the
Receiver secured and took possession of all known real and personal property assets
of the Receivership Entities promptly upon his appointment. Given that the assets
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of the Receivership Entities were not being used for any viable business purpose, the
Receiver is preparing a motion for approval of procedures for the sale of the real
property and personal property assets of the Receivership Entities.
A. Company Offices
In conjunction with and with assistance from the U.S. Marshals and the
Arcadia Police, the Receiver took control and possession of the premises located at
135 E. Live Oak, Arcadia, California ("Company Offices"), an approximately
18,000 square foot, two-story office building. All employees were terminated. The
Receiver has retained a security company to guard the Company Offices and is
reviewing books and records of the Receivership Entities located at company
offices. There is no mortgage on the Company Offices. The Receiver recommends
listing the property for sale, subject to overbid and Court confirmation. The
Receiver is in the process of determining the value of the property.
B. Hills Garden Hotel
The Receiver took possession of the Hills Garden Hotel located on Ostrem
Boulevard in Rancho Cucamonga. The 112 unit hotel was formerly a Days Inn, but
lost its flag shortly before the Receiver's appointment. The Receiver is in financial
control of the hotel and manages the hotel with the assistance of the on-site
employees, many of whom had been employed by the hotel for many years prior to
its purchase by the Receivership Entities on August 1, 2015. The Receiver
confirmed that adequate insurance for the hotel is in place. It appears the hotel was
going to be used by Defendants to conduct fundraising activities. Several rooms
were converted to meeting rooms, jewelry show rooms, and offices. As a result, the
hotel is operating at a loss. The Receiver is attempting to increase revenue and
reduce costs, and hopes to bring operations to a cash break-even level in the near
term. The Receiver recommends marketing the hotel for sale and is currently in the
process of determining the value of the hotel and the best means of marketing it for
sale.
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C. Other Real Properties
The Receiver also took possession of the following real properties:
A 36-unit apartment building located in Alhambra. The Receiver is collecting the rents and paying appropriate operating expenses. The building is 100% occupied and all tenants are paying rent to the Receiver. The Receiver recommends selling the apartment building.
A mansion located in Bradbury that was not used as a residence and appears to have been used for fundraising and investor relations. The home is apparently called the "Clubhouse." The Receiver recommends that the home be sold and is obtaining broker opinions of value.
A single family home and a condominium, both located in Arcadia. There are tenants in the properties who are not paying rent. Eviction actions are pending for both properties and the Receiver recommends marketing the homes for sale when the evictions are completed.
Approximately 860 acres of vacant land near Moreno Valley, California that could be used for a golf course. The Receiver recommends that the land be sold and is in the process of determining its value and an effective means of marketing the land for sale.
Finally, the Receiver has also identified several other single family homes
purchased with funds from the Receivership Entities and vested in other individuals
or entities. The Receiver intends to file fraudulent transfer actions to return the
assets to the Receivership Entities.
D. Funds Recovered to Date
As noted above, the Receiver has taken control of numerous bank accounts
and funds of the Receivership Entities. To date, the Receiver has taken possession
of approximately $21,664,410.87 comprised primarily of funds turned over to the
Receiver by financial institutions as a result of the Court's TRO and freeze order,
and includes cash in the amount of $67,952.45, as well as the return of unused legal
retainers of $574,250. The Receiver also collected $106,121.90 in rental income,
and received $175,441.74 in revenue from the hotel. Total receipts as of
December 31, 2015, were $21,945,974.51. The Receiver also collected
$5,636,402.69 from the United States Treasury in January which will be reflected in
the Receiver's first quarter accounting report.
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The Receiver continues to investigate and trace funds with regard to various
transfers made prior to entry of the TRO. Large payments to companies outside the
United States, including companies in China, Vietnam, Mexico, and the Dominican
Republic, have been identified in company accounting records.
E. Law Firm Retainers
The Receiver learned that two law firms that had been engaged to represent
Defendant Steve Chen ("Chen") and one or more of the Receivership Entities had
received large retainers from an affiliated entity located in Singapore, USFIA
Singapore PTE, Ltd. ("USFIA Singapore"). After investigating the matter further,
the Receiver learned that Chen owns 80% of USFIA Singapore and that USFIA
Singapore is simply the "Asia Headquarters" of USFIA, Inc. Nevertheless, an
attorney located in Singapore who purported to represent USFIA Singapore sent
several communications to the Receiver's counsel claiming USFIA Singapore was
unrelated to USFIA, Inc. and that the transfers to the two law firms were loans made
to Chen at his request in violation of Singapore law. When asked for documents to
support the claim that USFIA Singapore is unrelated to USFIA, Inc., the Singapore
attorney provided none.
The Receiver demanded that the two law firms turn over the balance of the
retainers in their possession that was unused as of the date of the Receiver's
appointment. One of the firms - Bird, Marella, Boxer, Wolpert, Nessim, Drooks,
Lincenberg & Rhow PC ("Bird Marella") - agreed to do so. The balance turned over
by Bird Marella was $574,250.60. The other firm - Wellman and Warren LLP
("Wellman") - in light of the claim raised by the Singapore lawyer, stated it will not
turn over the balance of $128,307.77 in unused retainer funds until there is a Court
order directing it to do so. Accordingly, the Receiver recently filed a motion for
order directing Wellman to turn over the funds ("Turnover Motion"). Dkt. No. 43.
The Turnover Motion is set to be heard on March 7, 2016. Although Wellman had
previously indicated it intended to interplead the funds, after meeting and conferring
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with the Receiver's counsel regarding the Turnover Motion, Wellman confirmed it
does not contest the motion. Wellman filed a notice of non-opposition on
February 11, 2016. Dkt. No. 45.
F. Li Zhao and Ally Investors
As discussed in the First Report, in response to the TRO, Bank of America
froze a custodial account (known as a UTMA account), as well as a safety deposit
box, under the name of Jennifer Zhao aka Li Zhao ("Zhao"). The bank also froze
and turned over to the Receiver a total of $3,034,930.10 that was in accounts under
the name Ally Investors, LLC ("Ally"). The Ally accounts were frozen by Bank of
America in response to receiving the TRO. The Ally account balances were then
turned over to the Receiver in response to a request by the Receiver that Bank of
America turn over all balances in accounts of the Receivership Entities.
The facts and circumstances surrounding the relationships and transfers
between Zhao, Chen, Ally, and the Receivership Entities are described in the Court's
Order Granting in Part and Denying in Part Zhao and Ally's Motion to Intervene, to
Direct the Receiver to Return Assets, and to Clarify Orders ("Order"). Dkt. No. 38.
As provided in the Order, the Court allowed Zhao and Ally to intervene but
determined Ally Investors to be an affiliated entity and therefore within the scope of
the receivership, and on that basis, denied Zhao and Ally's request to direct the
Receiver to return the balances that had been in the Ally accounts, their request to
unfreeze the safe deposit box, but granted their request to unfreeze the UTMA
account.
On a related note, in November 2015, the Receiver issued document
subpoenas to Zhao and Ally, to which Zhao and Ally objected. Despite several meet
and confers and attempts to resolve the objections, Zhao and Ally did not produce
any documents in response to the subpoenas. Accordingly, on January 20, 2016, the
Receiver filed a Joint Stipulation Re Thomas A. Seaman's Motion to Compel
Compliance by Non-Parties Li Zhao and Ally Investors with Subpoenas for the
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Production of Documents ("Motion to Compel"). Dkt. No. 39. On February 4,
2016, Magistrate Judge Abrams granted the Motion to Compel as to all documents,
other than emails already in the Receiver's possession and denied Zhao's request to
shift the costs of production to the receivership estate. Dkt. No. 44. The Court gave
Zhao until February 25, 2016, to produce the subpoenaed documents. On
February 25, 2016, Zhao produced documents, which the Receiver and his counsel
are in the process of reviewing.
Separately, the Receiver discovered that a luxury home currently held by
Zhao was paid for entirely by the Receivership Entities. Specifically, on April 3,
2015, the property located at 2857 Gainsborough Drive, San Marino, California was
purchased for approximately $2,335,000, all of which funds were transferred
directly to escrow from the Receivership Entities Amkey, Inc. and Ahome Real
Estate LLC. The Receiver has demanded that Zhao turn over the Gainsborough
Property. For the time being, Zhao and the Receiver have agreed to try and reach a
global resolution of issues and have agreed to defer such discussions until the
Receiver has performed additional accounting work and completed discovery. If a
resolution of the Gainsborough Property issue is not reached during those
discussions, the Receiver will take necessary and appropriate steps to recover the
Gainsborough Property.
G. Affiliated Entities
It appears Chen was associated with a large number of companies in the
United States and abroad, and the Receiver is continuing to investigate and locate
companies affiliated with Chen and/or the Receivership Entities. Through his initial
investigation and review of records and the Commission's filings, the Receiver has
identified the following entities, which appear to be affiliated with Chen and/or the
Receivership Entities:
Aborell Advisors I, LLC Aborell Investment Associates I, LLC
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Aborell Management I, LLC Aborell Realty Advisors LLC
Aborell Realty Corporation
Aborell REIT II, Limited
Aborell REIT II, LLC
AFG Holding Company
Ahome Real Estate, LLC
Ahome Real Estate USA LLC
Ahomeland, Inc.
Alhambra Gardens LLC
Alliance Financial Group, Inc.
Alliance NGN, Inc.
Ally Investors LLC
Amauction, Inc.
Ameritra, Inc.
Amkey Global Corporation
Amkey, Inc.
Ammine, Inc.
Apollo Real Estate Investments I, LLC
Apollo REIT I, Inc.
Apollo REIT II, Inc.
Apollo Investors LP
Chenne Corporation
China-US Consultation Association
First Investment Holding Company
Great Wall Mountain LLC
Hills Garden Hotel Inc.
Hills Garden Hotel LLC
International Gemstone Mining Association
L'BE Group
LH Investment LLC
One World Currency Fund
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Quail Ranch Golf Club, LLC
Quail Ranch Golf Course, LLC
Quail Ranch Golf Club, LP
Steamfont Capital Investment Group, LLC
Steamfont Investment Group, LLC
The New World Currency Fund
To Quang Duan
US Fovictor Jewel Investment LLC
US-China Consultation Association Liaison/Consulting Services
USFIA, Inc.
USFIA Singapore PTE Ltd. (discussed above)
Weimar International Group, Inc.
The Receiver also continues to investigate the ties and relationships between
the entities listed above and the Defendants in order to identify and secure their
assets. If necessary, the Receiver will seek an order clarifying their status as
subsidiaries or affiliates, and therefore Receivership Entities.
H. Territorial Jurisdiction Over Receivership Assets
By filing the Complaint and the TRO with other federal district courts in the
United States, the territorial jurisdiction of this Court over receivership assets is
extended to such districts. 28 U.S.C. § 754, see also Haile v. Henderson Nat'l Bank,
657 Fed. 2d 816, 822 (6th Cir. 1981). Based on information obtained to date
regarding property owned by Receivership Entities or in which they may have a
security interest and in conformity with section 754 and the federal law, the
Receiver has filed the Complaint and the TRO in the United States District Courts
for the Northern, Eastern, and Southern Districts of California as well as the District
of Nevada. The Receiver has also caused the Complaint and TRO to be recorded in
the property records for each county in which the Receivership Entities are believed
to own real property or have a security interest in real property. As additional
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information becomes available, the Receiver will file and record the Complaint and
the appointment order in additional districts and counties.
I. Investor Communications
The Receiver has established a website to provide case information, regular
updates, and answers to frequently asked questions to investors and creditors. The
Internet address for the webpage is www.usfiareceiver.com. Due to the large
number of Chinese-American investors, the website also provides a tab to view the
website in Mandarin. In addition, as noted above, the Receiver continues efforts to
generate a comprehensive list of investors and their contact information. Depending
upon the number of investors and their location, the Receiver will determine how
best to provide notice and information to investors and parties of interest in this
matter. In the meantime, the website provides a means to send emails to the
Receiver's staff.
J. Receivership Accounting
Attached as Exhibit A are a Profit and Loss Statement, Balance Sheet, and
Detailed General Ledger, which provide an accounting of the receipts and
disbursements to and from the receivership estate through December 31, 2015.
To date, the Receiver has seized or taken possession of approximately
$21,664,410.87 in funds turned over to the Receiver by financial institutions as a
result of the Court's TRO and freeze order, cash on hand in the amount of
$67,952.45, and return of unused legal retainers of $574,250. The Receiver also
collected $106,121.90 in rental income, and received $175,441.74 in revenue from
the hotel. Total gross receipts to date as of December 31, 2015, were
$21,945,974.51.
As set forth on the Profit and Loss Statement, Balance Sheet, and General
Ledger, the Receiver has disbursed $692,802.79. The primary categories of
disbursements are hotel operating expenses of $265,623.28, property taxes of
$165,061.86, insurance expenses of $42,049.19, and security expenses of
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$101,002.00. The Receiver was holding cash in the amount of $21,253,171.72 as of
December 31, 2015.
III. PRELIMINARY RECOMMENDATIONS
The Receiver's efforts to marshal, preserve, and protect assets of the
Receivership Entities and gather relevant documents and records are ongoing.
Although the Receiver has gathered and reviewed a substantial amount of
documents and information, more information necessary to gain an understanding of
the Receivership Entities' financial affairs and transactions with third parties is being
gathered as sources are identified. The Receiver and his professionals make the
following recommendations with regard to the ongoing administration of the
receivership estate and their efforts to understand and document the financial
activities of the Receivership Entities.
A. Document Recovery Efforts
The Receiver will continue to obtain records from all financial institutions
where the Receivership Entities maintained accounts as well as from attorneys and
accountants formerly engaged by the Receivership Entities. The Receiver has
served subpoenas on certain institutions, individuals, and entities, in response to
which a significant amount of records have been produced, and intends to continue
with these efforts to obtain documents, assets, and information. It may also be
necessary to take the depositions of certain individuals to obtain a complete picture
of the enterprise.
B. Receivership Asset Recovery Efforts and Investigation
The Receiver will seek to locate any presently unaccounted for receivership
assets that may exist. The Receiver will take appropriate steps to secure such assets
and preserve their value as they are identified.
C. Accounting
The Receiver has begun a forensic accounting of those bank accounts that
contained funds when the TRO was issued. The purpose of the accounting is to
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identify assets and potential sources of recovery, as well as forming a basis for a
claims process. The accounting will analyze sources of funds obtained by the
Receivership Entities and where these funds were later transferred or to whom these
funds were paid, after they were received by the Receivership Entities.
D. Repatriation of Overseas Assets
The Receiver will investigate what, if any, assets are located in overseas
banks and institutions. The Receiver will then report to the Court and advise on
proposed measures that may be taken in order to repatriate these assets.
E. Maintain Operations of the Hotel, Apartment Building, and
Single Family Residential Properties
As noted above, the Receivership Entities own a hotel and an apartment
building. The operations of these properties generate revenue and the underlying
properties have significantly more value as operating businesses. Accordingly, the
Receiver proposes to continue operations of these properties to preserve their value
in the short term and marketed for sale in accordance with sales procedures
approved by the Court.
F. Investor Communications and Claims Process
As discussed above, the Receiver is continuing to analyze data regarding the
identities of investors and their contact information, and evaluating ways to
disseminate information to them. He anticipates that communications with investors
will be through direct emails and the receivership website. The Receiver anticipates
developing and filing a motion for approval of a claims process in the next quarter.
G. Asset Sales
The Receiver has evaluated both the real and personal property assets that
have been recovered. Given the cost of holding the assets and the possibility that
certain of the assets may depreciate over time, the Receiver intends to file a motion
for approval of procedures for the sale of both real and personal property. In the
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EXHIBIT A
Exhibit A Page 14
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Exhibit A Page 15
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 17 of 46 Page ID #:1811
Exhibit A Page 16
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 18 of 46 Page ID #:1812
Exhibit A Page 17
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 19 of 46 Page ID #:1813
Exhibit A Page 18
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 20 of 46 Page ID #:1814
Exhibit A Page 19
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 21 of 46 Page ID #:1815
Exhibit A Page 20
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 22 of 46 Page ID #:1816
Exhibit A Page 21
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 23 of 46 Page ID #:1817
Exhibit A Page 22
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 24 of 46 Page ID #:1818
Exhibit A Page 23
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 25 of 46 Page ID #:1819
Exhibit A Page 24
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 26 of 46 Page ID #:1820
Exhibit A Page 25
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 27 of 46 Page ID #:1821
Exhibit A Page 26
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 28 of 46 Page ID #:1822
Exhibit A Page 27
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 29 of 46 Page ID #:1823
Exhibit A Page 28
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 30 of 46 Page ID #:1824
Exhibit A Page 29
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 31 of 46 Page ID #:1825
Exhibit A Page 30
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 32 of 46 Page ID #:1826
Exhibit A Page 31
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 33 of 46 Page ID #:1827
Exhibit A Page 32
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 34 of 46 Page ID #:1828
Exhibit A Page 33
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 35 of 46 Page ID #:1829
Exhibit A Page 34
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 36 of 46 Page ID #:1830
Exhibit A Page 35
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 37 of 46 Page ID #:1831
Exhibit A Page 36
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 38 of 46 Page ID #:1832
Exhibit A Page 37
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 39 of 46 Page ID #:1833
Exhibit A Page 38
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 40 of 46 Page ID #:1834
Exhibit A Page 39
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 41 of 46 Page ID #:1835
Exhibit A Page 40
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 42 of 46 Page ID #:1836
Exhibit A Page 41
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 43 of 46 Page ID #:1837
Exhibit A Page 42
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 44 of 46 Page ID #:1838
Exhibit A Page 43
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 45 of 46 Page ID #:1839
Exhibit A Page 44
Case 2:15-cv-07425-RGK-PLA Document 53 Filed 02/26/16 Page 46 of 46 Page ID #:1840