IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA HARRISONBURG DIVISION UNITED STATES OF AMERICA, v. GEORGE HENRY COVARRUBAIZ ) ) ) ) ) Case No. 5:14CR00019 DEFENDANT’S RESPONSE TO THE GOVERNMENT’S MEMORANDUM ADDRESSING ISSUES RAISED AT THE HEARING OF SEPTEMBER 29, 2014 There is much to say about the government’s latest filing. 1 We will exercise restraint, however, and focus on a factual issue that merits the court’s attention. The filing continues along the path of the disappointing tactics that have characterized the government’s conduct throughout the litigation of this case. Counsel asserts, for example, that the undersigned (and in truth this court too) should not have been surprised to hear of the collective knowledge justification for this stop, because the justification was suggested at the first hearing. As we have noted repeatedly, however, the collective knowledge justification for this stop seemed to be foreclosed by Trooper Miller’s unambiguous testimony at the July 17 hearing. How could any reasonable person conclude otherwise when the Trooper testified to one “sole” basis for the stop? And the idea that the undersigned should be faulted for not asking the right question to elicit another basis for the stop reflects a litigation philosophy that is at odds with our responsibilities as members of a profession and officers of the court. Should the undersigned have divined that there must have been some other basis for this stop when Trooper Miller testified to one basis and answered two point-blank questions pinning him down on the point? Government counsel was aware of this other supposed justification for the stop and should have corrected Trooper Miller’s testimony. Instead, he said nothing. He allowed all to be misled. It was only after the hearing – and after this court issued its memorandum opinion – that government counsel revealed the collective knowledge justification for the stop which it hid from the court at the first hearing. At that point, of course, the undersigned became aware of the government’s new theory. But government counsel even then did not reveal that there had been a directive to stop – not in any emails or filings or, for that matter, in any conversations. As to this, the undersigned gave government counsel the benefit of the doubt and concluded that he simply did not understand that the collective knowledge doctrine requires a directive to stop. It never occurred to the undersigned that an officer of the court would have let Trooper Miller testify in the way that he did, knowing that the testimony was misleading. The revelation that there had been a directive to stop came at the September 29 hearing – a hearing, by the way, at which even government counsel grudgingly noted that the undersigned could not be faulted for complaining about the “gamesmanship” in the case. For government counsel to now suggest that the undersigned had no reason to be shocked, because he had advised the undersigned of “the 1 Case 5:14-cr-00019-MFU Document 78 Filed 11/04/14 Page 1 of 4 Pageid#: 1503 The government justifies its extraordinary strategy of doling out the truth as it sees fit (and faulting the undersigned for not finding it sooner) on the notion that it had to do so because of the grave threat posed by Mr. Amador. Thus, counsel writes: 1. “Amador’s arrest then eliminated the very real danger Amador posed to the people of the United States, and permitted the Government to share the additional reasonable suspicion without the risk of jeopardizing Amador’s apprehension. The alternative course of action—not sharing this additional information—was unthinkable, because this additional information is highly relevant to the Court’s decision.” Memo. at p. 2. 2. “The United States is ethically bound and obligated to serve the best interests of its client, which include the safety, health and well-being of its citizens. People like Amador, who traffic large amounts of addictive and deadly narcotics, pose a direct threat to the health and safety of the people of the United States. Accordingly, the United States must prioritize the investigations of these individuals.” Id. at p. 18. 3. “Because Amador was still at large, he and his nationwide drug trafficking organization posed a more substantial threat to the health and safety of the citizens of the United States (the client of the United States) than that of the defendant.” Id. at p. 18-19. The message: Mr. Amador was a major drug trafficker and serious threat to the people of the United States. He likely would have escaped prosecution if he had learned of the wiretap evidence (even though his drivers were getting arrested with money and drugs). We made the hard choice to keep all of this secret from the court – even though we would have told the truth if Mr. Cargill had just asked the right question and not interrupted Trooper Miller as he was about to tell the whole truth. We revealed more of the truth after Mr. Amador was arrested and after the grave threat he posed to the people of the United States was addressed. collective knowledge doctrine argument (which mandates evidence on the instruction/request to stop)” (memo. at p. 25) is yet another example of the frustrating tactics employed by opposing counsel. First, it is the undersigned’s fault that the directive to stop was not discovered at the July 17 hearing, because defense counsel should have asked better questions and not interrupted Trooper Miller just as he was about to reveal the secret basis for the stop. Then, it is the undersigned’s fault for not deducing that there had been a directive to stop when none had ever been mentioned. All of this is most disappointing. 2 Case 5:14-cr-00019-MFU Document 78 Filed 11/04/14 Page 2 of 4 Pageid#: 1504 Here is what we have learned, and what this court should know about the arrest of Mr. Amador (none of which was offered by the government): It turns out that in fact Mr. Amador was arrested on August 22, 2014. The arrest was pursuant to an arrest warrant issued by a California Judge on the complaint of DEA Task Force Officer Andrew Vestey who was part of the task force involved in the investigation and arrest of Mr. Covarrubaiz. Mr. Amador was released on a $5,000.00 bond as recommended by the California prosecutor, District Attorney Paul E. Zelebach (signature stamp is unclear) (Felony Complaint, attached, upper left corner notation). The bond was posted on August 22, 2014. Mr. Amador appeared in court on October 17, 2014 and his “current bail bond was continued” until his next court appearance on November 17, 2014 for his arraignment. The arrest papers and associated documents, including the docket entries, are attached hereto as an exhibit. 2 Thus, all of these concerns about safety and flight and the “more substantial threat to the health and safety of the citizens of the United States” posed by Mr. Amador were so grave that Mr. Amador was released on a modest bond as suggested by the prosecutor. No doubt, the government has some compelling explanation for not giving the court this information. Respectfully submitted, GEORGE HENRY COVARRUBAIZ By: /s/ Randy V. Cargill Of Counsel 2 The court website is: http://public-access.riverside.courts.ca.gov/OpenAccess/CaseSearch.asp One must pay a nominal fee for copies of filed documents. 3 Case 5:14-cr-00019-MFU Document 78 Filed 11/04/14 Page 3 of 4 Pageid#: 1505 Randy V. Cargill, Esquire Assistant Federal Public Defender Office of the Federal Public Defender 210 1st Street, Suite 400 Roanoke, Virginia 24011 (540) 777-0880 FAX: (540) 777-0890 Counsel for Defendant George Covarrubaiz CERTIFICATE OF SERVICE I hereby certify that on the 4th day of November, 2014, I served the foregoing Response to the Government’s Submission filed on November 3, 2014 upon Assistant United States Attorney Grayson A. Hoffman, by electronic filing and I caused the original thereof to be filed electronically with Julia Dudley, Clerk, United States District Court, 210 Franklin Road, S.W. Roanoke, VA 24011. By: /s/Randy V. Cargill Randy V. Cargill 4 Case 5:14-cr-00019-MFU Document 78 Filed 11/04/14 Page 4 of 4 Pageid#: 1506 EXHIBIT RIVERSIDE SUPERIOR COURT PUBLIC ACCESS Minute Order Defendant Name: EVE RARDO AMADOR File Date: 8/21r2014 Department: 00 Case Number: RIF 1402958 Action Date: 10i17i2014 Action Time: 8:30 AM Action Description: WARRANTKARRAIGNMENT Honorable Judge Helios J. Hernandez Presiding. Courtroom Assistant: J. Martin Court Reporter: J. BRUGGER. People represented by Deputy District Attorney: Jennifer Flores. Defendant Represented By DPD Juanita Menu {Friend of the Court). Defendant Present. At 9:00. the following proceedings were held: interpreter Varela is Present and Sworn to interpret SpanishlEnglish for Defendant. Sworn oath on ?le. An?aignment set for 1H1 732014 at 8:30 in Dept 63 Defendant waives time. Private counsel to be retained by defendant. Defendant does not qualify for the Public Defender Defendant ordered to return on any and all future hearing dates. Current Bail Bond Continued. Spanish Interpreter to be ordered for the Defendant's next appearance Case Document 78-1 Filed 11/04/14 Page 1 of 10 Pageid#: 1507 RJF 1402958 Case Report - Riverside and Mid-County Criminal Traf?c Page 1 of 3 IVERSIDE SUPERIOR COURT PUBLIC ACCESS Criminal Case Report Pay Ticket! Case Fine Send me an email when this case is updated (click here) I I Print This Report I I Purchase Documents forthis Case i Close This Window Case RIF 1402958 - Defendants Seq Defendant Next Court Date Status Agency/ Arrest Date Count 1 Violation DR Charge Date Number Arraignment AMADOR, . RCDA HS 11370.6 1 EVERARDO 1111772014 AT 8.30 AM R1140058 02/03/2014 (A) 02/03/2014 DEPT. 63 SR. AMADOR EVERARDO _l AGUILAR CABRERA, RCDA HS 11370.6 2 R1140058 02/03/2014 (A) Case RIF1402958 AMADOR, EVERARDO Status Custody Bail Filing Type Complaint Fitting Date 0812112014 Ordered Bait $5,000.00 Posted Bait $5,000.00 D.A. Jennifer Flores Defense DPD Juanita Mantz (Friend oft Next Action: Arraignment Deputy Report RC DA-RI R1140058 1111712014 AT 8:30 AM DEPT. 63 [Warrant ?Type ??aws ?issued ?Af?davit ?08/21/2014 lProbaticE? Type _?Granted ?Expiration ilNiA [Sentence ?Convicted Date Fine and Penatty?Restitution Fine] ?we 1 JP Case Document 78-1 Filed 11/04/14 Page 2 of 10 Pageid#: 1508 1 ?4/201 4 RIF1402958 Case Report Riverside and Mid-County Criminal Traf?c Page 2 of 3 Case RIF1402958 - AMADOR, EVERARDO - Charges Best Charges ICharge Violation DateIIP/eaIIStatus?I IHS IEOSS FUNDS EXCESS ILJI IFiled Charges I MIC/large II?wer/tyIILescript/on Viotation DateII/?EIIS/atus I I1 IIHS FUNDS EXCESS II IIACTIVET Case - AMADOR, EVERARDO - Probation Probation Has Not Been Granted On This Case For This Defendant. Case - AMADOR, EVERARDO - Related Cases On Calendar Related Cases 0n Calendar I IE3 Defendant Does Not Have Any Other Cases With Future Hearings Scheduler/I Case RIF1402958 - AMADOR, EVERARDO - All of Defendant's Other Cases [Case NumberIIFi/ed DateIIChargesIINext Hear/?ngIIMsdictioFIEtatI/sI This Defendant Does Not Have Any Other Reportable Cases. I Case - AMADOR, EVERARDO - Actions 8: Minutes IAction Date ?IIAction Text IIQispos/t?ion Type I 08/22/2016 BAIL BOND NO. FCS101370632 IS TO BE ADDRESSED BY 082216, WHICH 18 2 YEARS FROM EFFECTIVE DATE 08/22/2014 (PC1304) 11/17/2014 8:30 ARRAIGNMENT AM DEPT. 63 IARRAIGNMENT 10/17/2014 FINANCIAL STATEMENT AND NOTICE TO DEFENDANT FILED. (CONFIDENTIAL) 10/17/2014 8:30 DISPOSED ARRAIGNMENT AM DEPT. 63 Minutes I Print Minute Order I [08/26/2014 WAS RECALLED SUCCESSFULLY II 7 @8/26/2014 RECALL REQUESTED. 1 08/25/2014 BOND NO. FCS101370632 FILED. APPEARANCE DATE IS 10/17/2014. [08/21/2014 IIDEFENDANT ALSO KNOWN AMADOR EVERARDO SR j] IL I 03/21/2014 DECLARATION BY LAW ENFORCEMENT FOR WALK- THROUGH ARREST WARRANT AND ORDER II II ll 1 Case Document 78-1 Filed 11/04/14 Page30110 Pageid#: 1509 1 1/4/2014 I RIF 1402958 Case Report - Riverside and Mid-County Criminal Traf?c Page 3 of 3 ?08/21/2014 ELIGIBLE FOR DRUG DIVERSION PURSUANT To 1000 I PC. ELIGIBLE FOR SUBSTANCE ABUSE PROGRAM PURSUANT TO 1210.1 PC. log/2112014 DECLARATION IN SUPPORT OF ARREST WARRANT JUDGE BERNARD J. SCHWARTZ Joe/2112014 APPROVED Joe/2112014 DESIGNATION: DRUG. CASE ASSIGNED TO DEPT. 42. 7 WL [08/21/2014 FILED. (IMAGED) WL 1 [08/21/2014 SET TO RI BY OTSS10. [08/21/2014 FILED BY CRRC jl Case - AMADOR, EVERARDO - Fine Information Date To Pa y: NIA First Payment: Prior NSF: Payment Amount: $0.00 Last Payment: B19 NumbeFHFine Typelftne DescriptionHOn'gI'nat AmomlPaid To DateHCurrent Due] 1 7L 1L ?lL Tota?L I Print This Report I I Purchase Documents forthiS Case I Close This Window Riverside Public Access 5.7.23 2014 Corporation. All Rights Reserved. wwaSd-corpxom Contact Us Case Document 78-1 Filed 11/04/14 Page 4 Of 10 Pageid#: 1510 1 1/4/2014 CASH BOND $1,000.~ - I. .s . Recommenoaos WEE - IDISAPPROVED moi Er'zwseeaCH .0 up! SUPERIOR COURT OF CALIFORNIA sopsiifm gig? Edam? COUNTY OF RIVERSIDE (Riverside) 2 a 8 THE PEOPLE OF THE STATE OF CALIFORNIA, one 329043 Carrillo Plaintiff, CASENO. ll: V. FELONY COMPLAINT EVERARDO AMADOR DOB: 06/10/1963 DRUG COURT AKA: AMADOR EVERARDO, SR- P.C. 1000 DIVERSION PC 1210.1 REFERRED BENJAMIN AGUILAR CABRERA Eligible YES DOB: 09120:f 196] Not Eligible BOTHW NO Unknown if Eligible Defendants. COUNT The undersigned, under penalty of perjury upon infmninion and belief, deelnee: "that the above stained. defendants, committed a violation of Health and Safety Code section 11370.6, subdivision a felony, in that on or about February 3, 2014, in the County of Riverside, State of California, they did wilfully and possess money and negotiable instniments in excess of one hundred thousand dollars ($100,000) which had been obtained an a result ofthe unlaw?il sale, possession for sale, transportaion, andmanufacture of a earl-rolled substance with knowledge that the money and negotiable inalmm eats had been on thinned, mil did wilfully and unlaw?illy poess money and negotiable indmments in excess of one hund?ed thousand dollars ($100,000) which were intended by mid defendants for the unlawful purchase of a controlled substance and said defendants committed an act in aubalmtial furtherance of the unlawful purchase. LAW Information contained in the repeats being distributed as discovery in this case may contain con?dential information protected by Marsy?s Law and the unendments to the California Constitution Section 28. Any victim(a) in any above referenced charge(s) is entitled to be free from intimidation, harassment, and abuse. It is unlawful for defendant(a), defenao counsel, and any other person acting on behalf of the defendant(a) to use any information contained in the reports to locate or harass any Vietnam or the family or to disclose any inform alien is otherwise privileged and con?dential by law. Additionally, it in a misdemeanor violation of California Penal Code 1054.298) to disclose the address and telephone number of a victim or witness to a defendant, defendant?s fanin member or anyone else. Note exceptions in California Penal Code 1054.2a(a) and (2). I declare under penalty of perjury upon information and belief under the laws of the State of California that the foregoing is true and correct. Dated: 21, Complainant COURT ORIGINAL Case Document 78-1 Filed 11/04/14 Page 5 of 10 Pageid#: 1511 FHLED F1 CR COURT OF CALIFORNIA 5U 0F RIVERSIDE AUG 21 201?! RCamlla SUPERIOR COURT, STATE OF CALIFORNIA COUNTY OF RIVERSIDE Cece Fair?14020159 Declaration in Support of Arrest Warrant (2 Page Limit Except in Unusual Cases) People of the State of Calif v. Everardo Amador, Sr. The undersigned, Andrew Vestey, declares that he is a Task Force Of?cer with the Drug Enforcement Administration. The DEA, in cooperation with the Fontana Police Department conducted a wiretap investigation of the narcotics activities of Everardo Amador, Sr., who is a narcotics load coordinator and Benjamin Aguilar Cabrera, who is a narcotics proceeds courier in Riverside County and elsewhere. Through a series of intercepted telephone conversations between Amador and Cabrera, investigators learned Cabrera was picking up a large amount of narcotics proceeds from the east coast at the direction of Amador. On February 3, 2014, Fontana PD investigators and the California Highway Patrol located Cabrera, while driving a semi-truck and trailer westbound on the 10 freeway through Beaumont. CHP Of?cer R. Mendenhall subsequently conducted a traf?c stop, for speeding (CVC 22406) and following too close (CVC 21703), on the semi?truck westbound on the 60 freeway in Mereno Valley. During the traf?c stop, CHP Of?cer R. Mendenhall obtained consent to search the contents of the semi-truck and trailer, ultimately seizing $799,695 in narcotics proceeds. Amador coordinated the receipt, loading and transportation of the narcotics proceeds back to the Riverside County area. Wherefore, declarant prays that an Arrest Warrant issue for the arrest, day or night, for Everardo Amador, Sr. Description of Everardo Amador, Sr.: 5?9? tall, weight 172 lbs., Hispanic, black hair, brown eyes; DOB: 06/10/1963, CDL: Address: 9715 San Diego Street, Spring Valley, CA 91977. LAW ENFORCEMENT: JUDICIAL OFFICER: I declare, under penalty of perjury under the 4 Approved Disapproved laws of the State of California that the foregoing Ball: 5 QQC) Date: is true and correct. Date: Signature Signature __AndrewVestey SQQEML Print Name Print Name Case Document 78-1 Filed 11/04/14 Page 6 of 10 Pageid#: 1512 1" I {1 SUPERIOR COURT OF CALIFORNIA, COUNTY OF RIVERSIDE BANNING 135 N. Alessandro REL. Banning. CA 92220 RIVERSIDE 4100 Main St. Riverside, CA 92501 265 N. Broadway, CA 92225 MURRIETA Auld Rd. Ste. 1226. Murriela. CA 92563 INDIO 46-200 Oasis 3L, India. CA 92201 FOR COURT use om LAW ENFORCEMENT AGENCY [Name and Address): 29$ 5T Fae SUPERIOR COURT OF CALIFORNIA [05 c4 COUNTY or RIVERSIDE DEFENDANT: AUG 2 1 2014 am 41440.92, m. TELEPHONE NUMBER: 2.-l 3-5743?6365/ FAX no. (Optioneoz E-MAIL ADDRESS (Optional): CASE NUMBER Vggq'gy DECLARATION BY LAW ENFORCEMENT FOR WALK-THROUGH ARREST WARRANT AND ORDER a 1:102 at am: [Instructions to Law Enforcement: Arrest Warrants are processed by the Court on a walk-through basis ONLY when extraordinggy gircumstances associated with public safety andfor the interests of justice require that the processing of the warrant be expedited] The undersigned hereby declares that processing this Arrest Warrant on a walk-through basis is appropriate because of the following facts: Zi?Hi 345552) on z~m1?a?m mam; ?ames?w :2 AND ?Bile-W DEA /~v?eso~r?4?7arfs Reece-Ema) Cewbucn? ?eve/9 45/? e14. . (Ln-1645b We?wg?Vevcz Jeep?5 557:5). Wee-14 were brunch ?an! ?rm ?lm?s-rhea I declare under penalty of perjury under the laws of the State of California V7 foregoing is true and correct. 21 l/ {Date} (Signatu're of Declar?nt] ORDER Good cause appearing, the requested Arrest Warrant for the above named efen ant wi be proc ed on a walk-throu?h basis. Q, ?3*th (Ev (Date) '(Judgy of the Superior Court}\ Page 1 DECLARATION BY LAW ENFORCEMENT FOR WALK-THROUGH ARREST WARRANT AND ORDER Case Document 78-1 Filed 11/04/14 Page 7 of 10 Pageid#: 1513 . .. .. SUPERIOR COURT OF CALIFORNIA, COUNTY OF RIVERSIDE FOR COURT use our 1 People of the State of California "a .101 Plaintiff/Petitioner mm COURT orcmronuu. coumv 0F 3; AUG 2 5 201EVERARDO AMADOR Defendant/Respondent CASE DOCUMENT COVERSHEET Full Document Title: Bail Bond Number FCS101370632 (If the document is no: o?ida?y Wed, pi'ease pmvide the desc?phbn of what is being ?ied.) Other File Clerk Notes: Rim-ads Superior Court M6013 [Ru DOCUMENT COVERSHEET Page 1 of 1 Case Document 78-1 Filed 11/04/14 Page 8 of 10 Pageid#: 1514 --. mp4 .-.. .. .. ?MW?nu pan-r v-v W.- The Bail Hotline Bail Bonds insurance License 1845394 3601 University Ave. Second Floor Riverside. California 92501 FINANCIAL CASUALTY 8: SURETY. INC. The Bail insurance Company 3131 EASTSIDE 600 (9.0. Ensure) HOUSTON, TEXAS 77098 om.nt7?21omrei 8?7.737.2245 0 Fax 713.580.6401 BAIL BOND NO. OF ATTORNEY WITH THIS NUMBER MUST BE ATTACHED.) IN THE SUPERIOR COURT OF THE RIVERSIDE JUDICIAL DISTRICT COUNTY OF Riverside . STATE OF CALIFORNIA. THE PEOPLE OF THE STATE OF CALIFORNIA vs. Plaintiff. CASE NO. RIF1402958 DIV. NO. AMADOR. EVERAJRDO Defendant Defendant AMADOR. EVERARDO 201440021 (NAME OF DEFENDANT) (BOOKING NO.) having been admitted to bail in the sum of FIVE THOUSAND DOLLARS (3 $5,000.00 )and ordered to appear in the above entitled court. on 10/17?2014 07:30 AM on HS 1 1 379-30?) chargers; DATE TIME (State OR appear for pronouncement of judgment or grant of probation. or if tie/she fails to perform either of these conditions. that the FINANCIAL CASUALTY a. SURETY. INC.. a Texas Corporation. will pay to the peopie of the State of California the sum of__ subject to applicable legal provisions. if the forfeiture of this bond be ordered the court. judgment may be summarily made and entered forthwith against the said FINANCIAL CASUALTY SURETY. ., a Texas Corporation. for the amount of its undertaking herein as provided by Sections 1305 and 1306 of the Penal de. . FINANCIAL CASUALTY a. SURETY, INC. (A Texas Corporation) - 4/ng Robert Saba. Sr. Vice-President i certify under penalty of perjury that i am a licensed bail agent of the FINANCIAL CASUAL SURETY, WC. and that 33? executing this bond on 0322/2014 day. at . CA 1 (Lona dog?ng AGENT) Approved day of was; 20]? Them NOTE: This Is In Appearen?e Bond and cannot be construed as a guarantee for failure to provide payments. back alimony payments. I INES, or ways Law claimsBond on Appeal. CERTIFICATE OF DISCHARGE BOND FINANCIAL CASUALTY a. SURETY, INC. POWER NO. chmavossz BOND AMT. $5,000.00 This is to certify that on or about the day of_ corresponding power (bond) number has been discharged of record. Date of Discharge TO THE CLERK OF THE COURT THE PREMIUM CHARGED FOR THIS eoNo PER ANNUM IS: 5 $500.00 the bond with the. nun-M. and Intum Mule-Intent: The Bail HotIIne Bail Bonds Titie Bond Amount $5,000.00 Defendant AMADOR. EVERARDO Insurance License 1845394 3501 University Ave. Second Floor Riverside. Celifomia 92501 888?438?2245 (PLACE an. AGENTS ADDRESS srmr- HERE) Date Posted Case 1 Document 78-1 Filed 11/04/14 Page 9 of 10 Pageid#: 1515 VOID IF NOT ISSUED BY new: or #9353955! Court POWER NUMBER 31-Jan-15 POWER OF ATTOR 3m Eastside. Suite 600, Houston. TX 77093 FinH?Cial Casualty Sum.? ?10- TeleJi 377.737.2245 The. Rail Insurance Company KNOW ALL MEN BY THESE PRESENTS that Financial Caxuullv Surety. Intr. it count 'atiun duly organized and existing under the laws of the State of Texas does constitute and appoint and by these presents does make. constitute and appoint the agent its true and lawful Attomey-in-Fact for it and in its narne. place . and stead, to execute. seal and deliver for and on its behalf and as its act and deed. as surely. a bail bond only. Authority of suoh Attorney-in-Fact is limited to appearance bonds and cannot be construed to guarantee defendant's future lawful conduct. adherence to travel limitation. ?nes. restitution. payments or penalties. or any other condition imposed by a court not speci?cally related to court appearance. This Power of Attorney is for use with Bail Bonds only. Not valid if used in with Federal Immigration Bonds. This power is void if altered or erased. void if used in combination with other Powers of this company or Powers from an other surety. void if used to furnish bail in exoess of the maximum stated amount of this Power. This Power Number is unique and can only be used once. The obligation of the surety shall not exceed the sum of: i i ?*Ten Dollars and Zero Cents2705)] cow FOR counr I and angina! Power-of-Attomey With the original bond MUST together be posted the court and retained as a part of the court's records. The sard Attomcy-in-Fact is hereby authorized to insert in this Power-taf-Attorncy the name of the person on whose behalf this bond was given. I resents to be 31' dul authorized of?cer, to or I IN WITNESS WHEREOF. THE FINANCIAL CASUALTY (55 TY. INC. has on 86d those for the purpose and its corporate seal to be af?xed this of 0 .01 Day Month Eucmwjo City Year I or Defendant Premium Charged 301?le State ?3 Case Number}; Bond Amount 5 tr Rewrite. Original 5:4 .- 8 EA Senior Vice President Executth Agent 7 n" w' NOT VALID IF USED IN Fodthourt t1 Micro Printed (Anti-Forgery) Message ls Contained In this Document?s Border It missing, the Document is FORGED and VOID Case Document 78-1 Filed 11/04/14 Page 10 of 10 Pageid#: 1516