UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA,
Plaintiff
V. NO. 3:14-MJ-OO271 (WIG)
YU LONG alkla LONG YU,
Defendant FEBRUARY 13, 2015
MOTION TO SET CONDITIONS OF RELEASE
The defendant, Yu Long, through his undersigned counsel,
respectfully requests that this Court review its present order of
detention and release Mr. Long on a series of conditions sufficient
to assure that he will return to Court when required and not pose
a danger to the community.
In support of this motion, the defendant states:
1. He has been detained since his arrest on Novernber 7,
2Ol4 in the Northern District of New York.
2. On December 9, 2OI4 he appeared before this Court and
ordered detained. He is presently held at Donald C. Wyatt
1
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 1 of 29
Detention Facility in Central Falls, Rhode Island. The detention
order was entered without prejudice. It was based on the Court's
conclusion that the defendant poses a serious risk of non-
appearance as he had extensive ties in his native country China of
which he remains a citizen.
3. On January 13, 2015 undersigned counsel appeared for this Mr.
Long. He has met with the defendant at Wyatt in Central Falls twice and twice
more in the United States Courthouse in New Haven. During the course of
those meetings and in consultation with defendant's previolts counsel, the
undersigned has obtained information which, he submits, is sufficient to justify
this Court allowing the defendant to be released on certain conditions. Those
suggested conditions are set forth below.
4. The defendant was born on December 20, 1977 in China. He is 37
years old and resides with his significant other Jiangxia Qin and their three-
month old daughter, Grace, in Ithaca, New York. Another daughter of that
relationship, Charlotte, resides in China with Ms. Qin's mother. He has no
record of convictions here or in China.
2
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 2 of 29
5. Mr. Long was formerly married to Bin Yang from whom he is now
lawfully divorced. He has one child by Ms. Yang, a daughter, Claire who is 5
years old.
6. Mr. Long is a lawful resident alien of the United States and has been
for a number of years. He has Bachelor's Degrees from Shanghai Jiao Long
University in Industrial Management and also in Thermal Power Engine in
2OOO, In 2003 he received a Master's Degree from that same university in
Mechanical Engineering. He received a PhD from Clemson University in 2008.
He pursued further education in Management, Science and Engineering at
Stanford University.
7. Ms. Qin, Mr. Long's significant other is a graduate student in Fashion
at Cornell University in its master's program. She presently resides at
university housing at lthaca, New York.l
I Counsel is given to understand that Mr. Long, if released to reside with Ms. Quin, is notallowed in campus housing at Cornell. Mr. Long and Ms. Qin are able to obtain alternativeliving accommodations in off-campus housing in Ithaca.
3
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 3 of 29
8. The defendant enjoys the full support of Ms. Qin to whom he is
devoted and she him.
9. Mr. Long and Ms. Qin through an LLC, Orange One Plus One, own
two properties in Connecticut: a condominium at 301 Audubon Court in New
Haven with an assessed value of $ 158,900.00; and a second residence at 94
Talcott Notch Road, Connecticut with an assessed value of $320,500.00. The
Audubon Court residence was pr.rrchased in June of 2OI4 for $2 t0,0OO.OO. It
appears to have a mortgage of approximately $ tO8,O0O.OO. The Talcott Notch
Road property is assessed at $SZ0,5OO.OO. It was purchased on June 5,2014
for consideration of $390,000.00. There are no liens or mortgages on that
property.
10. Atthough Ms. Qin resides in lthaca, New York, the defendant is
prepared to join her there if released or, if required, to reside in the Audubon
Court address in New Haven.
1 1. In either case, Mr. Long will willingly surrender his passport, submit
to electronic monitoring and house arrest (with allowance for medical needs,
religious services or meeting with his attorney). Further, he is prepared to
report in person on a daily basis to Pre-Trial Services Officer at the Financial
4
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 4 of 29
Center in New Haven if required to live in New Haven; or on a less frequent
basis at the nearest Federal Probation Office in Ithaca, New York if allowed to
return there to live with his family.
12. The defendant is willing to submit to any other reasonable
restrictions which the Court feels are appropriate.
13. It should be noted that the defendant is charged with illegally
obtaining and retaining proprietary documents from his former employer,
United Technologies Research Center, and the Government contends he
intended to transport these documents to China. The documents seized are
voluminous. The need to review and analyze tltern is crucial to Mr. Long's
defense. The present restrictions detaining him in Rhode Island substantially
handicap the effective representation to which he is constitutionally entitled
and, ultimately, will likely impact his rights to due process and a fair trial.
Logistics alone seriously inhibit counsel's ability to fulfill his obligation s to his
client.
14. The Court will understandably be concerned, and the Government
likely more so, about the risk of a Chinese national fleeing to his country of
birth. There aLre a number of factors, however, which rninímizes that concern:
5
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 5 of 29
a. The defendant's immediate family, as outlined above, resides in
the United States.z
b. Through an LLC owned by himself and his wife, the family owns
two significant pieces of real estate in Connecticut, both of which will be
pledged to secure his reappearance.
c. The defendant has no access to proprietary materials; he is no
longer employed by the complainant company or related companies. He is
unemployed and, at the time of his arrest, was principally occupied with caring
for Ms. Qin and their youngest child, then two months old. Ms. Qin is young
and inexperienced and relies on Mr. Long to maintain the household and to
provide child care.
15. The looming concern in this case is that Mr. Long was engaged in an
attempt to remove from United States highly technical information (and
possibly military information) for delivery to China, either for sale or, for
delivery to the Chinese Government. That premise, based to date only on
2 His daughter, Charlotte, does reside in China. In fact it was his intent to return to China andto reunite with his daughter and to bring her back to her family. More below.
6
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 6 of 29
speculation, is mitigated by a number of factors, all of which undercut its
validity:
(i) at the time of his departure for China on November 4,
2OI4 from Liberty Airport in Newark, New Jersey, Mr. Long had "hard copies"
of allegedly high security materials. These documents were carried "openly".
They were not secreted in electronic devices such as thumb drives or discs,
either of which would have easily eluded discovery by Customs and Border
Patrol personnel. Information in that format would have been virtually
undetectable.3
(ii) there is no evidence that the defendant at any time ever
transmitted by e-mail, regular mail or any other way to China or to Chinese
authorities or industrialists the suspect materials or similar materials.
(iii) Mr. Long was pursuing academic positions both in the
United States and elsewhere, but the similar materials were never transmitted
to any potential employers.
3 Granted, there was a hard drive which he carried along with his computer which, it is alleged,contains other proprietary information. But then, why signal an inquiry by openly carrying the"hard copies"?
7
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 7 of 29
(iv) on November 4,2O14 when he was stopped by Customs
and Border Patrol personnel at Newark Airport on his way to China, he
cooperated fully with authorities and submitted voluntarily to a lengthy
recorded interview during which he answered all relevant questions asked.
(v) in addition, the defendant had a round-trip booking
indicating his intent to return to the United States and so did Ms. Qin. (Copies
attached).
(vi) upon conclusion of the questioning at Newark, Mr. Long
was advised he was free to continlre on to China. He did not do so. Rather, he
returned to Ithaca and, remarkably, on the next day he voluntarilv reached out
to the FBI and provide d websites from which he believed he had obtained the
suspected materials.
(vii) he never sought to complete his travels to China after
the Newark interviews. Rather, he obtained counsel and, on the day he was
scheduled to meet with his attorney he was arrested in the Northern District of
New York. (See affidavit attached.)
16. Continued detention presents a significant handicap to the
preparation of Mr. Long's defense. Although he has been twice brought to the
8
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 8 of 29
Courthouse in New Haven for extensive debriefing with counsel, that courtesy
has ended. The significant volume of documents for review, both by counsel
and by Mr. Long, are now governed by this Court's protective order which
presents hurdles in the best of circumstances, let alone when the defendant is
detained. This further inhibits the preparation of his defense. He can never be
alone with the documents that he is required to review prior to discussing them
with counsel. Many hours will be required to educate counsel about the
documents seized. In addition, although Mr. Long obtained his graduate
education in the United States, his English is strained and communication is
difficult. In short, trial preparation becomes nearly impossible.
17. While the defendant understands the concerns about the possibility
of flight, there are alternatives which can provide sufficient protection to the
community and also assure his reappearance in Court. He requests that the
Court consider: release on a condition that requires him to post both residence
as surety; a requirement that he be placed on eiectronic monitoring and home
confinement with release only for religious, medical and iegal purposes;
passport surrender; and daily reporting to Pretrial Services.
9
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 9 of 29
18. Ideally, he would wish to reside with Ms. Qin and their child in
Ithaca, in a home confinement situation once she is able to obtain alternative
housing off campus there. Alternatively, he can be required to reside at the
Arrr{rr}rnn fìnrrrf qr{dresq. in Ne¡r¡ Ffnr¡en under home confinement and electronic
monitoring.
RESPECTFULLY SUBMITTED,
THE DEFENDANT,YU LONG
/ s/ Willíam F. Dow, III
William F. Dow, III (ct00161)JACOBS & DOW, LLC350 Orange StreetNew Haven, CT 06510Telephone: 203-772-3 100Facsimile : 203-77 2-169 IE-Mail: [email protected]
10
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 10 of 29
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on February 13,2015 the foregoing
was filed electronically and served by mail on anyone unable to accept electronic
filing. Notice of this hling will be sent by e-mail to all parties by operation of the
court's electronic filing system or by mail to anyone unable to accept electronic
filing as indicated on the Notice of Electronic Filing. Parties may access this filing
through the court's CM/ECF System.
/ s/ WiIIíam F. Dow, III
William F. Dow, III
11
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 11 of 29
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 12 of 29
STATE OF NEW YORK
COI.INTY OF NEW YORK
I, Yinghua Kelly Tan, being duly sworn deposes and says:
1. I am not a pafiy to the action, am over l8 years of age and reside in Kings
County, New York. I have been requested by attorney V/illiarn Dow, Mr. Long's present
attorney, to provide this affidavit in support of his bail application,
2. I am employed as a receptionist aI Wong, Wong & Associates, P.C,
("WNW"), a law hrm with offrces at 150 Broadway, Suite 1588, New York, New York (the
"New York Office") and 12 Roszel Road, Suite A-102, Princeton, New Jersey (the "New
Jersey Off,rce").
3. In the regular performance of my job functions, I have access to and am
familiar with the appointment book (the "Appointment Book") relating to appointments for
WNW in its New York Office and New Jersey Off,rce. The records in the Appointment Book
are usually made at or near the time of when the appointments are made by me or a person
with knowledge of the appointments, and are made and are maintained in the regular and usual
course of business of WNW. In connection with making this Affrdavit, I reviewed and relied
upon the Appointment Book.
4. From my review of the Appointment Book, on Saturday November 8,2014 at
4:15prn there was an appointment for the matter of Yu Long ("Long's Appointment").
5. Long's Appointment was madc with the New Jersey Office, because it was the
only office that was open duling the weekends.
6. I did not make Long's Appointment.
)))
SS
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 13 of 29
7. I have been subsequently informed that notwithstanding Long's Appointment,
nobody showed up orl said date and time.
8. I have been subsequently informed that Mr. Long was arrested November 7,
2014.
9, I have been subsequently informed that Mr. Long is the individual presently
represented by attorney Dow in the United State District Court in the District of Connecticut.
Dated: February 11, 2015
Kelly Tan
STATE OF NEW YORK
COUNTY OF NEW YORK
On the i2+r^ day of February in the year 2015, before me, the undersigned,personally appeared Yinghua Kelly Tan, personally known to me or proved to me on the basisof satisfactory evidence to be the individual(s) whose name(s) is (are) subscribed to the withininstrument and acknowledged to me that he/she/they executed the same in his/her/theircapacity(ies), and that by his/her/their signature(s) on the instrument, the individual(s), or theperson upon behalf of which the individual(s) acted, executed the instrument,
otary
JAMES M. SCHMITZNotary Publlc, State of New York
Qualified in New York GountYNo,02SC6263797
My Commisslon ExPires 06'11-201ô
a
)))
SS
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 14 of 29
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 15 of 29
To: Vivian Chen <[email protected])
Sent from my iPhone
Begin forwarded message:
From : Yu Long <[email protected]>
Date: February 9,2015 at12:34:26 PM ESTTo: <Raymond-H V/[email protected]>Subject: Fwd: eTicket Itinerary and Receipt for Confirmation C6RFT9
Sent from my iPhone
Begin forwarded message:
From : Yu Long <[email protected]>Date: November 21,2014 at10:04:41AM ESTTo : "kdelosreyes@,wongwonglaw. com" <kdelosreyes@wong
Subject: Fwd: eTicket Itinerary and Receipt for Confirmation C6RFT9
Sent from my iPhone
Begin forwarded message:
From: "United Airlines, Inc. " <unitedairlines@un
Date: November 3,2014,1:56:03 PM ESTTo : [email protected]: eTicket Itinerary and Receipt for ConfirmationC6RFT9
UNITED ffi
Issue Date: November 03,2014
A STAF ALLTANcE ueuraen 'þConfirmation:
C6RFT9Check-In >
FLIGHT INFORMATION
2
Frequent FlyerTravelerLONG/YU
eTicket Number0162427619889
Seats
2Bl24Bl23Bl23B
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 16 of 29
Day, Date Flighr clasrf."PutrureI rme
Wed, UA4829L05NOV14
City and Arrival City andTimeNEV/ARK, NJ(EV/R -
AircraftMeal
Q200
ITHACA, NY LIBERTY) 7226(ITH) 6:00 AM AM
Flight operated by COMMUTAIR doing business as UNITED EXPRESS wittr turboprop equipment.
Tue,2OJANl5
UA18O L NEV/ARK, NJ 777- Lunch(EWR -
HONG KONG LIBERTY) 1:50(HKG) 11:15 AM PM
200
FARE INFORMATION
Fare BreakdownAirfare:U.S. Customs UserFee:
U.S. Immigration UserFee:
U.S. APHIS User Fee:U.S. FederalTransportation Tax:September 1lthSecurity Fee:Hong Kong AirportPassenger DepartureTax:InternationalSurcharge:U.S. Passenger FacilityCharge:Per Person Total:
782.00USDs.50
7.00
5.0035.00
tt.20
15.50
194.20
13.50
1,068.90USD
1,068.9OUSD
Form ofPayment:MASTERCARDLast Four Digits4038
3
eTicket Total:
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 17 of 29
The airfare you paid on this itinerary totals: 782.00 USD
The taxes, fees, and surcharges paid total: 286.90 USD
Fare Rules: Additional charges may apply for changes in addition to any
fare rules listed.
NONREF/OVALUEAFTDPT/CHGFEECancel reservations before the scheduled departure time orTICKET HAS NO VALUE.
Baggage allowance and charges for this itinerary.
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Additional Baggage Information
The above amounts represent an estimate of the fÎrst and second checkedbaggage service charges that may apply to your itinerary.If your itinerary contains multiple travelers, the service charges mayvary by traveler, depending on status or memberships.
Carry-on baggage informationUnited accepts one caffy-on item with maximum dimensions of 9"x14"x22"(22 cm+ 35 cm + 56 cm) in the aircraft cabin, along with one personal itemsuch as a laptop bag with maximum dimensions of 9"x10"x17" (22 cm+ 25
cm + 43 cm).
Due to FAA regulations, operating carriers may have different carry-onrequirements.
Please check with the operating carrier for more information or go tounited.com.
General Baggage Information
4
2"d bag Max wt / dim per pieceOrigin and destination forchecked baggage
I't bag
0.00USD
100.00USD
50.0lbs (23.Okg) - 62.0ín(157.Ocm)
I I I 5 l20t 4 lthaca, NY (ITH) toHong Kong (HKG)
50.0lbs (23.Okg) - 62.0in(157.0cm)
0.00USD
100.00USD
Il20l20l5 Hong Kong (HKG) toIthaca, NY (ITH)
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 18 of 29
First and second bag service charges do not apply to active-duty members ofthe U.S. military and their accompanying dependents. For additionalinformation re garding b aggage charge s
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Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 19 of 29
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Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 20 of 29
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7
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 21 of 29
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 22 of 29
Willie Dow
From:Sent:To:Subject:
Vivian Chen <[email protected]>
Monday, February 09,20L5 6:14 PM
Willie DowFwd: eTicket Itinerary and Receipt for Confirmation C6M8X3
Mr. Dow:
As per our telephone conversation earlier, please see below for Ms. Qin's flight confirmation.
Vivian Chen, Esq
Wong, Wong & Associates, P.C.
L50 Broadway, Suite 1-588
New York, NY L0038
Tel.: (2t21s66-8080
Fax: (272) 566-8960
NOTE: The information in this e-mail is confidential and may be legally privileged. lf you are not the intended
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IRS CIRCULAR 230 DISCLOSURE: Pursuantto requirements imposed bythe lnternal Revenue Service, anytax
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wish to have formal written advice on this matter.
Forwarded messageFrom: Raymond H Wong <raymond-h-wong@yahoo.
1
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 23 of 29
Date: Mon, Feb 9, 2015 at 5:55 PMSubject: Fwd: eTicket Itinerary and Receipt for Confirmation C6M8X3To: Vivian Chen <vchen@,wongwonglaw.com)
Sent from my iPhone
Begin forwarded message :
From: Yu Long <bradenny@hotmailcom>Date: February 9,2015 at 5:46:33 PM ESTTo: <Raymond-H-Wong@yahooSubject: Fwd: eTicket ltinerary and Receipt for ConfTrmation C6M8X3
Sent from my iPhone
Begin forwarded message :
From: "United Airlines, Inc. " <unitedairlines@uniDate: November 3,2014 at 1:48:03 PM ESTTo: BRADENNY@,HOTMAIL.COMSubject: eTicket ltinerary and Receipt for ConfÏrmation C6M8X3
Conhrmation
C6M8X3Check-In >
Issue Date: November 03,2014
x
Traveler
QIN/JIANGXIAeTicket Number Frequent Flyer0162427618879
Seats19N24Ll23Al23C
FLIGHT INFORMATION
Day, Date Flight class|Tïture city and Arrival city and AircraftMeal--*""Time TimeSat, UA4828L NEWARK, NJ Q20006DECI4 (EWR
I HACA, NY LIBERTY) 11:01(ITH) 9:41 AM AM
FIight operated by COMMUTAIR doing business as UNITED EXPRESS with turboprop equipment.
2
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 24 of 29
Tue, U4180 L2OJANI5
NEWARK, NJ 777- LunchHONG KONG (EWR - 200(HKG) 11:15 AM LIBERTY) 1:50 PM
FARE INFORMATION
Fare BreakdownAirfare:U.S. Customs UserFee:U.S. Immigration UserFee:U.S. APHIS User Fee:U.S. FederalTransportation Tax:September 1lthSecurity Fee:
Hong Kong AirportPassenger DepartureTax:InternationalSurcharge:U.S. Passenger FacilityCharge:Per Person Total:
859.0OUSD5.50
7.00
s.0035.00
11.20
15.50
13.50
194.20
1,145.90USD
eTicket Total: 1,145.90USD
The airfare you paid on this itinerary totals: 859.00 USD
The taxes, fees, and surcharges paid total: 286.90 USD
Additional charges may apply for changes in addition to anyfare rules listed.
NONREF/OVALUEAFTDPT/CHGFEL,
3
Fare Rules:
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 25 of 29
Cancel reservations before the scheduled departure time orTICKET HAS NO VALUE.
Baggage allowance and charges for this itinerary.
Baggage fees are per traveler
Additional Baggage Information
The above amounts represent an estimate of the first and second checked
baggage service charges that may apply to your itinerary.
If your itinerary contains multiple travelers, the service charges may
vary by traveler, depending on status or memberships.
Carry-on baggage information
United accepts one calry-on item with maximum dimensions of 9"x14"x22"(22 cm+ 35 cm + 56 cm) in the aircraft cabin, along with one personal item
such as a laptop bag with maximum dimensions of 9"x10"x 17" (22 cm + 25
cm + 43 cm).
Due to FAA regulations, operating carriers may have different caffy-on
requirements.
Please check with the operating carrier for more information or go to
united.com.
General Baggage InformationFirst and second bag service charges do not apply to active-duty members ofthe u.s. military and their accompanying dependents. For additionalinformation regarding baggage charges
allowances, weight/size restrictions, exceptions or embargoes, or charges foroverweight, oversized, excess, odd-sized baggage, special items
or sporting equipment, visit united.com/baggage.
International eTicket Reminders
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Max wt / dim per piece1't bag 2"d bagOrigin and destination forchecked baggage
100.00USD
50.0lbs (23.Okg) - 62.0in(157.Ocm)
0.00USD
121612014Ithaca, NY (ITH) toHong Kong (HKG)
0.00USD
100.00USD
50.0lbs (23.0kg) - 62.0in(157.Ocm)
ll20l20I5 Hong Kong (HKG) toIthaca, NY (ITH)
Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 26 of 29
in Requirement - Bags must be checked and boarding passes
btained at least 60 minutes prior to scheduled departure. Baggage will notbe accepted and advance seat assignments may be canceled if thiscondition is not met.
arding Requirement - Passengers must be prepared to board at thegate with their boarding pass at least 30 minutes prior to
scheduled departure.
ure to meet the Boarding Requirements may result in cancellation ofations, denied boarding, removal of checked baggage from the
aircraft and loss of eligibility for denied boarding compensation.
this eTicket Receipt along with photo identif,rcation, proof ofp, passport and/or visa to the ticket lobby for check-in.
FAA now restricts carry-on baggage to one bag plus one personal itembriefcase, laptop computer, etc.) per passenger.
or up to the minute flight information, sign-up for our Flight Status E-at united.com or call l-800-824-6200; in Spanish t-800-426-556r
flight segments are not flown in order, your reservation will be
Rebooking will be subject to the fare rules governing yourticket.
or the most current status of your reservation, flights and other importantgo to united.com.
our eTicket is non transferable and valid for 1 year from the issue datess otherwise noted in the fare rules above.
taxes and fees may be collected at your departure airport.
Customer Care Contact Information'We welcome your compliments, comments or complaints regarding United ora United travel experience.
You may contact us using our Customer Care contact form at united.com
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We are making connections so you make yours. You can earn and redeem
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Go to www.staralliance.com to find out more. You've earned it.
Food for Purchase Now Available
Satisfy your cravings with something tasty from our new In-Flight Menu.Snacks or freshly prepared selections are available for purchase on mostflights between two and a half and six and a half hours.
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Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 27 of 29
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IMPORTANT CONSUMER NOTICES
Incorporated Terms - Your travel is subject to United's Contract ofCarriage terms. The Contract is available for inspection at any UAticketing facility, united.com or by calling 1-80O-UNITED- 1 . Passengers
have the right to receive the full text of the terms incorporated byreference free of charge by mail or other delivery service. The Contract
terms include rules about limits on liability for personal injury or death
and for loss, damage, or delay of goods andbaggage, check-in times,
overbooking, security issues, reservations, denial of carriage, refunds,
claims limits and restrictions, including time limitations for frling a claimor lawsuit, and schedule changes and irregularities. The Contract ofCarriage contains further detail of these terms.
Additional Terms - Depending on the rules applicable to the fare paid,
one or more restrictions including, but not limited to one or more of the
following, may apply to your travel: (1) the ticket may not be refundable
but may be exchangeable for a fee with another restricted fare ticketmeeting all the rules/restrictions of the original ticket (including thepayment of any difference in fares); (2) afee may apply forchanginglcanceling reservations; or (3) travel may be restricted to specificflights andlor times and minimum and/or maximum stay may be required.
Baggage Liability - On domestic flights, United's maximum liability limitfor checked baggage is $3400 USD per passenger and United excludes
liability for all unchecked baggage. For travel within the U.S., Unitedexcludes liability for fragile, valuable or perishable items canied in allbaggage including jewelry, computers, cash, camera equipment and
similar valuables. If any of these items are lost, damaged or delayed, you
will not be entitled to any reimbursement. You can declare excess
valuation on certain baggage at the airport, additional fees will apply.
ADVICE TO INTERNATIONAL PASSENGERS ON CARRIERLIABILITY - Passengers on a joumey involving an ultimate destinationor stop in a country other than the country of departure are advised thatinternational treaties known as the Montreal Convention, or itspredecessor, the'Warsaw Convention, including its amendments, mayapply to the entire joumey, including any portion thereof within a country.For such passengers, the treaty, including special contracts ofcarriageembodied in applicable tariffs, governs and may limit the liability of the
Carrier in respect of death of or injury to passengers, and for destruction orloss of, or damage to, baggage, and for delay ofpassengers and baggage.
Notice-Overbooking of Flights - Airline flights may be overbooked,
and there is a slight chance that a seat will not be available on a flight forwhich a person has a confirmed reservation. If the flight is overbooked, no
one will be denied a seat until airline personnel first ask for volunteers
willing to give up their reservation in exchange for compensation of the
airline's choosing. If there are not enough volunteers, the airline will deny
boarding to other persons in accordance with its particular boardingpriority. V/ith few exceptions, including failure to comply with the
carrier's check-in deadline which are available upon request from the aircarrier, persons denied boarding involuntarily are entitled to
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Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 28 of 29
compensation. The complete rules for the payment of compensation andeach airline's boarding priorities are available qt qll airport ticketcounters and boarding locations. Some airlines do not apply these
consumer protections to travel from some foreign countries, althoughother consumer protections may be avqilqble. Checkwith your airline oryour travel agent.
Personal Health - For important health tips before your flight, includinginformation on a serious condition called Deep Vein Thrombosis, please
go to united.com.
Thank you for choosing United Airlinesunited.com
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Case 3:14-mj-00271-WIG Document 23 Filed 02/13/15 Page 29 of 29