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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

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Long defense motion

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Page 1: SDSD District Version 1.3-SDSD District Version 1

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

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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

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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

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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

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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

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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

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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

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(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

Page 9: SDSD District Version 1.3-SDSD District Version 1

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

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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

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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

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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

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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

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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

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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

Page 18: SDSD District Version 1.3-SDSD District Version 1

The airfare you paid on this itinerary totals: 782.00 USD

The taxes, fees, and surcharges paid total: 286.90 USD

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2"d bag Max wt / dim per pieceOrigin and destination forchecked baggage

I't bag

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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

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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

recipient, you must not read, use, or disseminate the information; please advise the sender immediately by

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IRS CIRCULAR 230 DISCLOSURE: Pursuantto requirements imposed bythe lnternal Revenue Service, anytax

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used, for purposes of avoiding penalties imposed under the United States lnternal Revenue Code orpromoting, marketing, or recommending to another person any tax-related matter. Please contact us if you

wish to have formal written advice on this matter.

Forwarded messageFrom: Raymond H Wong <raymond-h-wong@yahoo.

1

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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.

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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,

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Fare Rules:

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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)

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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

Proud Member of Star Alliance

We are making connections so you make yours. You can earn and redeem

miles on27 member airlines offering over 18,000 daily flights to more than1,300 destinations worldwide.

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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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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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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Please do not reply to this message using the " reply " address.For assistance, please contact United Airlines via telephone or via e-mail.2}l4

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