Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 1 of 55 Page ID #:5285 1 ALLEN MATKINS LECK GAMBLE MALLORY & NATSIS LLP DAVID R. ZARO (BAR NO. 124334) 2 TIM C. HSU (BAR NO. 279208) 3 865 South Figueroa Street, Suite 2800 Los Angeles, California 90017-2543 4 Phone: (213) 622-5555 Fax: (213) 620-8816 5 E-Mail: dzaro@allenmatkins.com thsu@allenmatkins.com 6 EDWARD G. FATES (BAR NO. 227809) 7 501 West Broadway, 15th Floor San Diego, California 92101-3541 8 Phone: (619) 233-1155 Fax: (619) 233-1158 9 E-Mail: tfates@allenmatkins.com 10 Attorneys for Receiver THOMAS A. SEAMAN 11 12 UNITED STATES DISTRICT COURT 13 CENTRAL DISTRICT OF CALIFORNIA 14 WESTERN DIVISION 15 SECURITIES AND EXCHANGE COMMISSION, 16 Plaintiff, 17 v. 18 STEVE CHEN, USFIA, INC., 19 ALLIANCE FINANCIAL GROUP, INC., AMAUCTION, INC., 20 ABORELL MGMT I, LLC, ABORELL ADVISORS I, LLC, ABORELL 21 REIT II, LLC, AHOME REAL ESTATE, LLC, ALLIANCE 22 NGN, INC., APOLLO REIT I, INC., APOLLO REIT II, LLC, AMKEY, INC., 23 US CHINA CONSULTATION ASSOCIATION, and QUAIL RANCH 24 GOLF COURSE, LLC, 25 Defendants. 26 27 28 LAW OFFICES Allen Matkins Leck Gamble Mallory & Natsis LLP 848228.01/SD Case No. 2:15-CV-07425-RGK-PLA RECEIVER'S FIFTH INTERIM REPORT AND RECOMMENDATIONS Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 2 of 55 Page ID #:5286 TABLE OF CONTENTS 1 2 3 4 Page I.  EXECUTIVE SUMMARY ............................................................................. 1  II.  SUMMARY OF RECEIVER'S ACTIVITIES ............................................... 4  5 6 7 8 9 10 A.  Company Offices .................................................................................. 5  B.  Hills Garden Hotel ................................................................................ 5  C.  Other Real Properties ............................................................................ 5  D.  Investor Communications ..................................................................... 6  III.  SUMMARY OF RECEIPTS AND DISBURSEMENTS ............................... 7  IV.  RECOMMENDATIONS ................................................................................ 7  A.  Document Recovery Efforts ................................................................. 8  B.  Receivership Asset Recovery Efforts and Investigation ...................... 8  C.  Accounting ............................................................................................ 8  D.  Repatriation of Overseas Assets ........................................................... 8  E.  Sell the Hotel, Apartment Building, and Single Family Residential Properties ........................................................................... 9  16 F.  Investor Communications and Claims Process ..................................... 9  17 G.  Asset Sales ............................................................................................ 9  18 V.  19 CONCLUSION ............................................................................................... 9  11 12 13 14 15 20 21 22 23 24 25 26 27 28 LAW OFFICES Allen Matkins Leck Gamble Mallory & Natsis LLP 848228.01/SD (i) Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 3 of 55 Page ID #:5287 1 Thomas A. Seaman ("Receiver"), Court-appointed receiver for Defendants 2 USFIA, Inc., Alliance Financial Group, Inc., Amauction, Inc., Aborell Mgmt I, LLC, 3 Aborell Advisors I, LLC, Aborell REIT II, LLC, Ahome Real Estate, LLC, Alliance 4 NGN, Inc., Apollo REIT I, Inc., Apollo REIT II, LLC, Amkey, Inc., US China 5 Consultation Association, Quail Ranch Golf Course, LLC, and their subsidiaries and 6 affiliates (collectively, "Receivership Entities"), hereby provides his Fifth Interim 7 Report and Recommendations. This report focuses on the Receiver's activities 8 during the third quarter of 2016 and provides a financial report on the receipts and 9 disbursements for the receivership estate through September 30, 2016. I. 10 11 EXECUTIVE SUMMARY This receivership involves a complex and wide ranging group of enterprises 12 and assets funded with the fruits of the fundraising scheme at the heart of the action 13 filed by the Securities and Exchange Commission ("Commission"). The Receiver 14 has taken control of bank accounts identified in the TRO and Preliminary Injunction 15 Order ("Appointment Orders") as well as additional accounts identified through the 16 Receiver's investigation of documents and information found at the various locations 17 where the Receivership Entities conducted business. 18 For the quarter ending September 30, 2016, gross receipts to the receivership 19 estate were $610,130. From inception of the receivership through September 30, 20 2016, the total gross receipts were $29,262,001, of which $26,835,122 was turned 21 over to the Receiver from financial institutions at the outset of the case or otherwise 22 turned over to or seized by the Receiver. During the quarter ending September 30, 23 2016, the Receiver made disbursements of $689,412 for necessary operating and 24 administrative expenses of the Receivership Entities, as discussed further below. As 25 of September 30, 2016, the Receiver was holding cash in the amount of $26,355,692. 26 As previously reported, the Receiver has also identified and taken control of 27 the USFIA office building in Arcadia, a hotel in San Bernardino, an apartment 28 building in Alhambra, a warehouse, several single family homes, and parcels of LAW OFFICES Allen Matkins Leck Gamble Mallory & Natsis LLP 848228.01/SD Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 4 of 55 Page ID #:5288 1 undeveloped land, including a proposed golf course site in Moreno Valley. The 2 Receiver has also obtained evidence of several additional pieces of real estate 3 purchased with funds of the Receivership Entities and is further investigating these 4 transfers. 5 At this point, due to the volume of electronic data and disorganized manner in 6 which it was kept by the Receivership Entities, the Receiver is working to confirm 7 the entire scope of the USFIA enterprise, the number of investors, or specific 8 amounts invested by investors and distributed to them. The Receiver's work to 9 analyze and better understand the investor data, with the assistance of his forensic 10 computer specialist, is ongoing. To date, the Receiver has identified approximately 11 65,000 unique investor email addresses and has sent an official communication 12 regarding the receivership to all of these email addresses, directing investors to the 13 receivership website (www.usfiareceiver.com) and requesting they provide their 14 current contact information and giving them the option to sign up for automatic email 15 updates when the website is updated. 16 The Receiver has reviewed and analyzed certain Quickbooks files and hard 17 copy business documents, has obtained most of the relevant bank records, and is 18 close to completing the process of performing an accounting of receipts and 19 disbursements for the Receivership Entities with the objectives of tracing assets, 20 establishing claims, assessing damages, and preparing an accounting in accordance 21 with the Appointment Orders. To date, the Receiver has identified 78 bank accounts 22 of the Receivership Entities that were used as of January 1, 2010. The January 1, 23 2010 date was selected because the Receiver is in possession of virtually complete 24 banking records starting at that time. However, the Receiver is also in possession of 25 accounting data preceding 2010 and it appears some of the Receivership Entities 26 operated as far back as 2004. Thus, the forensic accounting will be limited in that it 27 will not capture time periods prior to January 1, 2010. 28 LAW OFFICES Allen Matkins Leck Gamble Mallory & Natsis LLP 848228.01/SD -2- Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 5 of 55 Page ID #:5289 1 To date, the forensic accounting indicates receipts of approximately 2 $195 million to the Receivership Entities and disbursements of approximately 3 $176 million, which comes very close to reconciling with the approximately 4 $19 million contained in the Receivership Entities bank accounts at the time the 5 Receiver was appointed. The value of the assets at that time appears to be the range 6 of $77.5 million, unadjusted for increases or decreases in the market value of the real 7 estate holdings and without factoring in amounts that may be recoverable through 8 litigation claims. The accounting is ongoing and the Receiver's goal for completion 9 is January 31, 2017. 10 Gemstones and gem mines were a major focus of the marketing materials and 11 investments offered to investors. The Receivership Entities purchased three parcels 12 of land in the Dominican Republic. In total, the parcels are approximately 300 acres 13 in size. The land was purchased for $373,000 with USFIA funds on December 2, 14 2013. A portion of the land was bought in the name of Yan Chen, Mr. Chen's 15 brother, and the remainder was purchased in the name of Ammine SRL, an entity 16 controlled by Yan Chen. The sale was not fully recorded and the land is still 17 officially titled in the name of the sellers. It appears the land has mines on it, which 18 are deep, man and machine made holes and tunnels, which are operating and amber 19 is being extracted from the land. The Receiver applied for, and was granted, an 20 Execuator from the Dominican Republic courts which domiciles this Court's 21 Preliminary Injunction in the Dominican Republic. 22 Ammine SRL received payments totaling $12,810,000 from the Receivership 23 Entities, which was paid to its account at Scotiabank and appears to have been used 24 to pay operating expenses and for purchases of amber and other materials extracted 25 from the land, as well as transfers to other banks in the Dominican Republic. A 26 review of the Scotiabank records indicates Ammine SRL was paying about $2.10 per 27 gram of amber. AMN Ltd., an apparent successor of Ammine SRL, also received 28 $630,000. The balance in the Scotiabank account upon service of the Execuator was LAW OFFICES Allen Matkins Leck Gamble Mallory & Natsis LLP 848228.01/SD -3- Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 6 of 55 Page ID #:5290 1 one peso. Ammine SRL has objected to the Execuator. In May 2016, long after the 2 Preliminary Injunction Order was entered, Ammine SRL also initiated dissolution 3 proceedings. With the assistance of counsel in the Dominican Republic, the 4 Receiver has objected to the dissolution in that it could affect the Receiver's potential 5 claims to assets held by Ammine SRL. 6 At this point, there is no indication there was any legitimate amber-backed 7 Gemcoin or other viable business operated by the Receivership Entities. Aside from 8 some income generated by the hotel and rental properties, and relatively small 9 amounts of revenue from the sale of health supplements and beauty products, the 10 Receivership Entities had no significant source of income other than money raised 11 from investors. The Receiver has verified that virtually none of the assets described 12 in online and written marketing materials actually exist. Nor has any liquid market 13 or ability to transact Gemcoins for goods and services been identified. Instead of 14 millions of dollars in precious gems as backing for the Gemcoins, the Receiver has 15 found only costume jewelry, boxes of rocks, and bins filled with tens of thousands of 16 little rings of nominal value. II. 17 18 SUMMARY OF RECEIVER'S ACTIVITIES As discussed in his First Report and Recommendations (Dkt No. 19), the 19 Receiver secured and took possession of all known real and personal property assets 20 of the Receivership Entities promptly upon his appointment. Given that the assets of 21 the Receivership Entities are not necessary for any viable business purpose, as 22 discussed above, the Receiver is marketing certain real property assets for sale and 23 intends to list additional properties sale in the near future. All sales are subject to 24 Court approval, and in appropriate cases, the Receiver will seek approval of 25 overbid/auction procedures for sales. The Receiver will also seek authority to 26 conduct an auction of the personal property of the Receivership Entities, including 27 vehicles, furniture, fixtures & equipment, weapons and jewelry material. 28 LAW OFFICES Allen Matkins Leck Gamble Mallory & Natsis LLP 848228.01/SD -4- Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 7 of 55 Page ID #:5291 1 A. Company Offices 2 In conjunction with and with assistance from the U.S. Marshals and the 3 Arcadia Police, the Receiver took control and possession of the premises located at 4 135 E. Live Oak, Arcadia, California ("Company Offices"), an approximately 18,000 5 square foot, two-story office building. All employees were terminated. The 6 Receiver retained a security company to guard the Company Offices and is 7 reviewing books and records of the Receivership Entities located at company offices. 8 There is no mortgage on the Company Offices. Continuing to hold the property, 9 however, is a drain on the receivership estate due to security costs, utility charges, 10 property taxes, and insurance premiums. The Receiver therefore recommends listing 11 the property for sale, subject to overbid and Court confirmation of the sale. The 12 Receiver is in the process of determining the value of the property and will list the 13 property for sale. 14 B. Hills Garden Hotel 15 The Receiver took possession of the Hills Garden Hotel located on Ostrems 16 Way in San Bernardino. The 112 unit hotel was formerly a Days Inn, but lost its flag 17 shortly before the Receiver's appointment. The Receiver is in financial control of the 18 hotel and manages the hotel with the assistance of the on-site employees, many of 19 whom had been employed by the hotel for many years prior to its purchase by the 20 Receivership Entities on or around August 1, 2015. It appears the hotel was going to 21 be used by Defendants to conduct fundraising activities. Several rooms were 22 converted to meeting rooms, jewelry show rooms, and offices. As a result, the hotel 23 had been operating at a loss. The Receiver has increased revenue and reduced costs, 24 and the hotel is now marginally profitable. The Receiver has listed the hotel for sale, 25 subject to Court approval, which will be sought upon conclusion of due diligence and 26 the buyer's deposit becoming non-refundable. 27 C. Other Real Properties 28 The Receiver also took possession of the following real properties: LAW OFFICES Allen Matkins Leck Gamble Mallory & Natsis LLP 848228.01/SD -5- Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 8 of 55 Page ID #:5292 1 2 3 4 5 6 7 8 9 10 11 12  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 will list the building for sale in the near future.  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 home is currently unoccupied. The Receiver recommends the home be sold and is obtaining broker opinions of value.  A single family home and a condominium, both located in Arcadia. There were tenants in the properties who were not paying rent. Eviction actions were commenced and have been 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. Rental revenue from short term uses of the land for military training exercises and cell phone towers is offsetting the operating expenses of the land. Finally, the Receiver has also identified several other single family homes 13 purchased with funds from the Receivership Entities and vested in other individuals 14 or entities, including Defendant Steve Chen. The Receiver is in contact with 15 Mr. Chen's counsel and the other title holders in an attempt to recover the properties 16 without litigation, but will seek authority to file fraudulent transfer actions if the 17 issues are not consensually resolved in the near future. 18 D. Investor Communications 19 As noted above, the Receiver has established a website to provide case 20 information, regular updates, and answers to frequently asked questions to investors 21 and creditors. The Internet address for the webpage is www.usfiareceiver.com. Due 22 to the large number of Chinese-American investors, the website also provides a tab 23 to view the website in Mandarin. In addition, as noted above, the Receiver continues 24 efforts to generate a comprehensive list of investors and their contact information. 25 As noted above, the Receiver has sent an official communication regarding the 26 receivership to the approximately 65,000 investor email addresses identified thus far. 27 28 LAW OFFICES Allen Matkins Leck Gamble Mallory & Natsis LLP 848228.01/SD -6- Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 9 of 55 Page ID #:5293 III. 1 2 SUMMARY OF RECEIPTS AND DISBURSEMENTS Attached as Exhibit A are a Profit and Loss Statement, Balance Sheet, and 3 Detailed General Ledger, which provide an accounting of the receipts and 4 disbursements to and from the receivership estate through September 30, 2016. A 5 Standardized Fund Accounting Report ("SFAR") is included with Exhibit A. 6 Total receipts to the receivership from July 1, 2016, through September 30, 7 2016, were $610,130 and were comprised of $1,305 turned over by banks, $479,192 8 in real estate revenue, sale of assets of $81,120, and interest income of $48,513. 9 From inception of the receivership through September 30, 2016, total receipts 10 were $29,280,448, which is comprised of $26,835,122 turned over by banks, 11 $702,558 in unused law firm retainers, $1,116,899 in hotel revenue, $485,446 in 12 rental income, tenant security deposits of $8,045, $81,120 from asset sales, and 13 $1,636 in tax refunds. The Receiver has also collected $49,622 in interest income on 14 cash being held. 15 As set forth on the Profit and Loss Statement, Balance Sheet, and General 16 Ledger, the Receiver disbursed $689,412 during the quarter ending September 30, 17 2016. Noteworthy among disbursements were $204,617.07 for the Receiver and his 18 counsel's fees, hotel operating expenses of $292,810, real property operating 19 expenses of $142,263. The Receiver has disbursed $2,959,795 from inception of the 20 receivership through September 30, 2016. The Receiver was holding cash in the 21 amount of $26,355,692 as of September 30, 2016. IV. 22 23 RECOMMENDATIONS The Receiver's efforts to marshal, preserve, and protect assets of the 24 Receivership Entities and gather relevant documents and records are ongoing. The 25 Receiver and his professionals make the following recommendations with regard to 26 the ongoing administration of the receivership estate and their efforts to understand 27 and document the financial activities of the Receivership Entities. 28 LAW OFFICES Allen Matkins Leck Gamble Mallory & Natsis LLP 848228.01/SD -7- Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 10 of 55 Page ID #:5294 1 A. Document Recovery Efforts 2 The Receiver continues to serve subpoenas on certain institutions, individuals, 3 and entities for the purpose of identifying assets, in response to which a significant 4 amount of records have been produced, and intends to continue with these efforts to 5 obtain documents, assets, and information. It may also be necessary to take the 6 depositions of certain individuals to ensure the Receiver has a complete picture of the 7 enterprise. 8 B. Receivership Asset Recovery Efforts and Investigation 9 The Receiver will seek to locate any presently unaccounted for receivership 10 assets that may exist. The Receiver will take appropriate steps to secure such assets 11 and preserve their value as they are identified. 12 C. Accounting 13 The Receiver is conducting a forensic accounting of bank accounts used by the 14 Receivership Entities. The objectives of the accounting are to identify assets and 15 potential sources of recovery, as well as forming a basis for an investor claims 16 process. The accounting will analyze sources of funds obtained by the Receivership 17 Entities and where these funds were later transferred or to whom these funds were 18 paid. The accounting is ongoing. To date, over 90 bank accounts have been 19 identified. The Receiver has thus far accounted for receipts to the Receivership 20 Entities in excess of $195 million. 21 D. Repatriation of Overseas Assets 22 Large payments to companies outside the United States, including companies 23 in China, Vietnam, Mexico, and the Dominican Republic, have been identified in 24 company accounting records. The Receiver will investigate what, if any, assets are 25 located in overseas banks and institutions. The Receiver will then report to the Court 26 and advise on proposed measures that may be taken in order to repatriate these 27 assets. 28 LAW OFFICES Allen Matkins Leck Gamble Mallory & Natsis LLP 848228.01/SD -8- Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 11 of 55 Page ID #:5295 1 E. Residential Properties 2 3 Sell the Hotel, Apartment Building, and Single Family As noted above, the Receivership Entities own a hotel and an apartment 4 building. The operations of these properties generate revenue. The Receiver is 5 operating the properties at a modest profit. Other single family homes owned by the 6 Receivership Entities are incurring expenses to maintain and do not generate 7 operating income. It would appear to the Receiver that the hotel, the apartment 8 building and the single family residences are not crucial to preserving and should be 9 converted to cash. The Receiver believes converting the assets to cash is more 10 beneficial to the estate than continuing to bear the risk and expense of holding the 11 assets. 12 F. Investor Communications and Claims Process 13 As discussed above, the Receiver is continuing to analyze data regarding the 14 identities of investors and their contact information, and evaluating ways to 15 efficiently disseminate information to them. The Receiver anticipates developing 16 and filing a motion for approval of a claims process once his forensic accounting 17 work is completed. 18 G. Asset Sales 19 The Receiver has evaluated both the real and personal property assets that 20 have been recovered. Given the cost of holding the assets and the possibility that 21 certain of the assets may depreciate over time, the Receiver intends to file a motion 22 for approval of procedures for the sale of both real and personal property. In the case 23 of the personal property, the Receiver anticipates retaining an auctioneer to conduct a 24 public sale. V. 25 26 CONCLUSION Based upon his preliminary investigation and findings, the Receiver 27 recommends and requests the Court order him to continue to perform his duties 28 LAW OFFICES Allen Matkins Leck Gamble Mallory & Natsis LLP 848228.01/SD -9- Case Document 141 Filed 11/18/16 Page 12 of 55 Page #:5296 pursuant to the Appointment Orders. The Receiver also requests the Court approve this Fifth Report and the recommendations discussed herein. Dated: November18, 2016 %?yl TH MAS A. SEAMAN Dated: NovemberlS, 2016 ALLEN MATKINS LECK GAMBLE MALLORY NATSIS LLP By: Edward Fares Attorneys for'Receiver THOMAS SEAMAN 848228.0USD -10- Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 13 of 55 Page ID #:5297 EXHIBIT A Exhibit A, Page 11 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 14 of 55 Page ID #:5298 Exhibit A, Page 12 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 15 of 55 Page ID #:5299 Exhibit A, Page 13 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 16 of 55 Page ID #:5300 Exhibit A, Page 14 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 17 of 55 Page ID #:5301 Exhibit A, Page 15 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 18 of 55 Page ID #:5302 Exhibit A, Page 16 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 19 of 55 Page ID #:5303 Exhibit A, Page 17 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 20 of 55 Page ID #:5304 Exhibit A, Page 18 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 21 of 55 Page ID #:5305 Exhibit A, Page 19 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 22 of 55 Page ID #:5306 Exhibit A, Page 20 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 23 of 55 Page ID #:5307 Exhibit A, Page 21 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 24 of 55 Page ID #:5308 Exhibit A, Page 22 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 25 of 55 Page ID #:5309 Exhibit A, Page 23 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 26 of 55 Page ID #:5310 Exhibit A, Page 24 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 27 of 55 Page ID #:5311 Exhibit A, Page 25 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 28 of 55 Page ID #:5312 Exhibit A, Page 26 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 29 of 55 Page ID #:5313 Exhibit A, Page 27 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 30 of 55 Page ID #:5314 Exhibit A, Page 28 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 31 of 55 Page ID #:5315 Exhibit A, Page 29 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 32 of 55 Page ID #:5316 Exhibit A, Page 30 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 33 of 55 Page ID #:5317 Exhibit A, Page 31 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 34 of 55 Page ID #:5318 Exhibit A, Page 32 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 35 of 55 Page ID #:5319 Exhibit A, Page 33 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 36 of 55 Page ID #:5320 Exhibit A, Page 34 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 37 of 55 Page ID #:5321 Exhibit A, Page 35 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 38 of 55 Page ID #:5322 Exhibit A, Page 36 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 39 of 55 Page ID #:5323 Exhibit A, Page 37 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 40 of 55 Page ID #:5324 Exhibit A, Page 38 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 41 of 55 Page ID #:5325 Exhibit A, Page 39 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 42 of 55 Page ID #:5326 Exhibit A, Page 40 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 43 of 55 Page ID #:5327 Exhibit A, Page 41 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 44 of 55 Page ID #:5328 Exhibit A, Page 42 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 45 of 55 Page ID #:5329 Exhibit A, Page 43 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 46 of 55 Page ID #:5330 Exhibit A, Page 44 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 47 of 55 Page ID #:5331 Exhibit A, Page 45 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 48 of 55 Page ID #:5332 Exhibit A, Page 46 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 49 of 55 Page ID #:5333 Exhibit A, Page 47 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 50 of 55 Page ID #:5334 Exhibit A, Page 48 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 51 of 55 Page ID #:5335 Exhibit A, Page 49 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 52 of 55 Page ID #:5336 Exhibit A, Page 50 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 53 of 55 Page ID #:5337 Exhibit A, Page 51 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 54 of 55 Page ID #:5338 Exhibit A, Page 52 Case 2:15-cv-07425-RGK-PLA Document 141 Filed 11/18/16 Page 55 of 55 Page ID #:5339 Exhibit A, Page 53