Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 1 of 85 Page ID #:1954 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JOHN B. BULGOZDY (Cal. Bar No. 219897) Email: bulgozdyj@sec.gov PETER F. DEL GRECO (Cal. Bar No. 164925) Email: delgrecop@sec.gov Attorneys for Plaintiff Securities and Exchange Commission Michele Wein Layne, Regional Director Lorraine Echavarria, Associate Regional Director John W. Berry, Regional Trial Counsel 5670 Wilshire Boulevard, 11th Floor Los Angeles, California 90036 Telephone: (323) 965-3998 Facsimile: (323) 965-3908 SECURITIES AND EXCHANGE COMMISSION, vs. Plaintiff, UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WORLD CAPITAL MARKET INC.; WCM777 INC.; WCM777 LTD. d/b/a WCM777 ENTERPRISES, INC.; and MING XU a/k/a PHIL MING XU, Defendants, and KINGDOM CAPITAL MARKET, LLC; MANNA HOLDING GROUP, LLC; MANNA SOURCE INTERNATIONAL, INC.; WCM RESOURCES, INC.; AEON OPERATING, INC.; PMX JEWELS, Ltd.; TOPACIFIC INC.; TO PACIFIC INC; VINCENT J. MESSINA; and INTERNATIONAL MARKET VENTURES, Relief Defendants. Case No. CV 14-2334 CAS (MRWx) DECLARATION OF MARIA D. RODRIGUEZ
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 2 of 85 Page ID #:1955 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, Maria D. Rodriguez, declare pursuant to 28 U.S.C. 1746, as follows: 1. I have personal knowledge of the facts set forth below and, if called as a witness, I could and would competently testify to the facts stated herein. 2. I am a certified public accountant licensed by the State of California. I am currently employed as an Accountant by the Securities and Exchange Commission ( SEC ), Division of Enforcement, in the Los Angeles Regional Office. I have been employed by the SEC since November 2013. 3. From June 1995 to November 2013, I worked in various public accounting firms, including two of the big four accounting firms. My duties at these firms included forensic and investigative accounting, litigation support, and damage analysis. 4. In the course of my duties at the SEC, I review various financial records, including bank records, documents from escrow companies, financial statements, and similar financial records. I analyze the transactions reflected in such records, perform mathematical calculations using the amounts reflected in those records, and make observations based on those records. The documents that I analyze in the course of my duties with the SEC are of the type reasonably relied upon by accountants in forming opinions and inferences about, among other things, the finances of a company and the sources and uses of its money. 5. On March 27, 2014 my declaration summarizing my analysis of the bank records of defendants World Capital Market Inc. and WCM777 Inc., as well as that of relief defendants Kingdom Capital Market, LLC; Manna Source International, Inc.; and WCM Resources, Inc., was filed in connection with the Commission s Ex Parte Application for a Temporary Restraining Order and other relief as to those and other defendants and relief defendants. 6. At the request of counsel, I have now reviewed and analyzed additional bank records, including account statements, account opening documents, signature cards, wire transfers, deposit slips and copies of deposited items, withdrawal slips, 1
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 3 of 85 Page ID #:1956 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 checks and/or check disbursements, and bank account transfers, when available, for the following accounts for the time periods stated: a. Bank of America account no. 3250-2858-2887, held in the name of California IOLTA Trust Accounts - Vincent J. Messina P.A. Trustee, from the date it was opened on or about February 4, 2014, through March 31, 2014 ( BofA IOLTA Account ). The signature card identifies one signer for the account: Vincent J. Messina, identified as Trustee. Attached hereto is a true and correct copy of the: i. Signature card and related document for this account as Exhibit 1; ii. BofA IOLTA Account statement for the period February 4, 2013 through February 28, 2013 as Exhibit 2; iii. BofA IOLTA Account statement for the month of March 2013 as Exhibit 3; iv. Check in the amount of $217,000, drawn on an account in the name of Vincent Messina at JP Morgan Chase, dated February 4, 2013, deposited into the BofA IOLTA Account on or about February 4, 2013, as Exhibit 4; v. Check in the amount of $175,000, payable to International Market Ventures, dated March 1, 2014, drawn on the BofA IOLTA Account, as Exhibit 5; vi. Check in the amount of $125,000, payable to International Market Ventures, dated March 10, 2014, drawn on the BofA IOLTA Account, as Exhibit 6; vii. Check in the amount of $300,000, payable to Vincent Messina, dated March3, 2014, drawn on the BofA IOLTA Account, and deposited into an account at Preferred Bank, as Exhibit 7; and /// 2
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 4 of 85 Page ID #:1957 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 viii. Check in the amount of $350,000, payable to Vincent Messina, dated March 12, 2014, drawn on the BofA IOLTA Account, and deposited into an account at Preferred Bank, as Exhibit 8. b. Bank of America account no. 3250-2858-2890, held in the name of Vincent J. Messina P.A., from the date it was opened on or about February 4, 2014, through March 31, 2014 ( BofA PA Account ). The signature card identifies one signer for the account: Vincent J. Messina, identified as President. Attached hereto is a true and correct copy of the: i. Signature card and related document for this account as Exhibit 9; ii. BofA PA Account statement for the period February 4, 2013 through February 28, 2013 as Exhibit 10; iii. BofA PA Account statement for the month of March 2013 as Exhibit 11; iv. Check in the amount of $35,000, payable to Vincent Messina, dated February 4, 2014, drawn on an account at JP Morgan Chase, and deposited into the BofA PA Account on February 4, 2014, as Exhibit 12; v. World Capital Market, Inc. $5,000 check deposited into the BofA PA Account as Exhibit 13; vi. BofA PA Account debit slip for $306,000, of which $276,000 appears to have been paid to Andrew Savor as Exhibit 14; and vii. BofA PA Account debit slip for $200,000 as Exhibit 15. c. Comerica Bank account no. 1894-87-0854, held in the name of ToPacific Inc., from the date it was opened on or about December 9, 2013, through March 31, 2014 ( ToPacific 0854 Account ). The signature card identifies one signer for the account: Ming Xu, identified as President of ToPacific Inc. A true and correct copy of the signature card, related documents 3
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 5 of 85 Page ID #:1958 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 and the ToPacific Inc. State of Delaware certificate of Incorporation are attached hereto as Exhibit 16. d. Comerica Bank account no. 1894-89-7600, held in the name of ToPacific Inc., from the date it was opened on or about December 9, 2013, through March 31, 2014 ( ToPacific 7600 Account ). The signature card identifies two signers for the account: Ming Xu, identified as President of ToPacific Inc. and Ruilong Gao. A true and correct copy of the signature card is attached hereto as Exhibit 17. e. Chase Bank account no. 000000952433803, held in the name of To Pacific Inc., from January 1, 2013 through December 31, 2013 ( To Pacific 3803 Account ). The signature card identifies one signer for the account: Ming Xu, identified as President of To Pacific Inc. Attached hereto is a true and correct: i. Copy of the signature card and related document for this account is attached hereto as Exhibit 18; and ii. Copy of $1,552,143.56 cashier s check dated December 27, 2013 deposited into the To Pacific 3803 Account as Exhibit 19. f. Chase Bank account no. 000003030530111, held in the name of To Pacific Inc., from January 1, 2013 through December 31, 2013 ( To Pacific 0111 Account ). The signature card identifies one signer for the account: Ming Xu, identified as President of To Pacific Inc. A true and correct copy of the signature card and related document for this account is attached hereto as Exhibit 20. 7. Based upon my analysis of the bank records for these accounts, I have identified the sources and uses of cash for those accounts. Because the SEC s investigation is ongoing and additional documents may be produced, I may update this analysis as additional information and supporting documents are made available. All amounts below are noted in U.S. dollars. 4
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 6 of 85 Page ID #:1959 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 A. The ToPacific 0854 Account: Sources of Funds 8. The ToPacific 0854 Account had more than $16 million in deposits from the end of December 2013 through March 31, 2014. Approximately $15 million of those deposits consisted of wires from individuals and/or entities similar in nature to the investor deposits made to the WCM777 accounts that I analyzed and summarized in my March 27, 2014 declaration. Similar to the deposits into the WCM777 accounts, funds from investors were identified based on deposits with certain fact patterns which include: (i) deposits in round-numbered amounts; and (ii) deposits of checks from individuals. 9. The deposits to the ToPacific 0854 Account also included a deposit of $190,000 from account 7600, which appears to correlate to the ToPacific 7600 Account. The remaining balance is undetermined due to missing underlying support. B. The ToPacific (CA) Chase Accounts: Sources of Funds 10. To Pacific 3803 Account had over $1.85 million in deposits from January 1, 2013 through December 31, 2013. I looked specifically at the period after March 2013, when the WCM777 offering started. Based on the similar patterns of investor funds described in paragraph eight above, it appears approximately $1.4 million were investor funds deposited from April 5, 2013 through November 13, 2013. 11. To Pacific 0111 Account had minimal activity during the period January 1, 2013 through December 31, 2013, and had an ending balance of $364.26 for that period. Between January 23, 2013 and March 5, 2013, a total of $106,200 was transferred from To Pacific 0111 Account to the To Pacific 3803 Account. C. The ToPacific 0854 Account: Uses of Funds 12. Account statements for the ToPacific 0854 Account show that checks totaling $7,587,647.37 were issued as of March 31, 2014. The payees are not identified on the bank statements, and I have not yet obtained copies of the cancelled checks, so I am unable to identify the recipients of these funds. The account 5
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 7 of 85 Page ID #:1960 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 statements for the ToPacific 0854 Account show that the majority of the remaining funds were wired out as follows: a. $5 million to the Vincent J. Messina BofA IOLTA Account on February 26, 2014; b. $1,963,600 to Wct Operations; c. $1,000,000 to Daniel John; d. $607,781.85 to Aladdin LLC; and e. $320,000 to Robert Sensi. D. To Pacific (CA) Chase Accounts: Uses of Funds 13. During the period of April 12, 2013 through December 27, 2013, over $1.696 million was disbursed from the To Pacific 3803 Account. 14. On December 27, 2013, a debit of $1,551,779.29 was posted to the To Pacific 3803 Account on December 27, 2013 leaving the account balance of zero. This withdrawal appears to correlate to a deposit of $1,552,143.56 into the ToPacific 7600 Account. E. Messina s BofA IOLTA Account: Sources of Funds 15. On February 4, 2014, $217,000 was deposited from Vincent Messina s JPMorgan Chase account no. ending in1517. There was no other activity from February 4, 2013 through February 25, 2013. 16. On February 26, 2014, $5 million was wired from the ToPacific 0854 Account to the BofA IOLTA Account. After this wire was received, the BofA IOLTA Account had a balance of $5.217 million. 17. These were the only deposits for the time period from February 4, 2014 through March 31, 2014. F. Messina BofA IOLTA Account: Uses of Funds 18. As of March 31, 2014, $5,207,000 was disbursed from the Messina IOLTA, of which $4,406,912 was disbursed directly or indirectly to Vincent J. Messina. 6
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 8 of 85 Page ID #:1961 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 a. A total of $3,756,912 was transferred to the Messina s BofA PA Account as follows: i. $950,000 on February 28, 2014; ii. $500,000 on March 6, 2013; and iii. $2,306,912 on March 21, 2014; b. A total of $650,000 was paid to other accounts held in the name of Vincent J. Messina as follows: i. $300,000 check posted on March 4, 2014; and ii. $350,000 check posted on March 12, 2014; c. $500,000 was wired to Andrew J. Savor on March 11, 2014; and d. A total of $300,000 was paid out to International Market Ventures as follows: i. $175,000 check posted on March 3, 2014; and ii. $125,000 check posted on March 10, 2014. G. Messina s BofA PA Account: Sources of Funds 19. The Messina BofA PA account was opened on February 4, 2014 with a deposit of $35,000. 20. Between February 5, 2014 and February 27, 2014, there was no activity in the account. 21. From February 28, 2014 and March 21, 2014, a total of $3,796,912 was deposited from Messina s BofA IOLTA Account (which received virtually all of its monies from the ToPacific 0854 Account). The $3,756,912 was comprised of three transfers as follows: a. $950,000 on February 28, 2014; b. $500,000 on March 6, 2014; and c. $2,306,912 on March 21, 2014. /// /// 7
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 9 of 85 Page ID #:1962 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 22. On March 3, 2014 $5,000 was deposited into the BofA PA account by World Capital Market. H. Messina s BofA PA Account: Uses of Funds 23. As of March 31, 2014, approximately $3.756 million had been disbursed from the Messina PA account, the majority of which were disbursed as follows: a. $1,950,000 was distributed to Vincent J. Messina as follows: i. $750,000 was wired to his Wells Fargo account ending 0382 on March 3, 2014; ii. $500,000 was wired to his Wells Fargo account ending 0382 on March 24, 2014; and iii. $700,000 was wired to his Preferred Bank account ending 2845 on March 26, 2014; b. $350,000 was wired to CNC Consulting Limited, at Hong Kong Shanghai Bank, on March 28, 2014; c. $350,000 was wired to International Market Ventures on March 24, 2014; d. On March 10, 2014, Vincent J. Messina withdrew $306,000 of which $279,000 appears to have been paid to Andrew Savor per notations made on the withdrawal slip; e. On March 6, 2014 $100,000 was wired to Mohamed Ei-Fatih at the Abu Dhabi Islamic Bank; f. On March 28, 2014 $200,000 was withdrawn by Vincent Messina; and g. On March 5, 2014 paid to Parmesh Khatwada 24. As of March 31, 2014, the BofA PA Account had a balance of $520,580.61; $700,000 had been transferred to Messina s Preferred Bank; and $1.25 million transferred to Messina s Wells Fargo account. 8
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 10 of 85 Page ID #:1963 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I. Payments to Vincent J. Messina from WCM777 and WCM Accounts 25. For the period between July 1, 2013 and December 31, 2013, Vincent J. Messina was paid approximately $235,000 from accounts held in the name of WCM777 and WCM, as follows: a. On July 1, 2013, $5,000 was paid to Messina from a WCM777 account; b. On August 9, 2013, $5,000 was paid to Messina from a WCM777 account; c. On September 9, 2013, $5,000 was paid to Messina from a WCM account; d. On September 30, 2013, $5,000 was paid to Messina from a WCM account; e. On October 31, 2013, $5,000 was paid to Messina from a WCM account; f. On November 27, 2013, $5,000 was paid to Messina from a WCM account; g. On December 17, 2013, $200,000 was paid to Messina from a WCM account; and /// /// /// /// /// /// /// /// /// 9
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 11 of 85 Page ID #:1964 1 2 3 4 account. hereto as Exhibit 21. h. On December 31, 2014, $5,000 was paid to Messina from a WCM A true and correct copy ofthe above mentioned checks are attached 5 6 7 8 I declare under penalty ofperjury under the laws ofthe United States of America that the foregoing is true and correct. Executed this 7th day ofmay 2014, in Los Angeles, California. 9 10 11 Maria D. Rodriguez Z5 <-- 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 10
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 12 of 85 Page ID #:1965 EXHIBIT 1
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 13 of 85 Page ID #:1966 Exhibit 1 Page 11
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 14 of 85 Page ID #:1967 Exhibit 1 Page 12
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 15 of 85 Page ID #:1968 Exhibit 1 Page 13
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 16 of 85 Page ID #:1969 Exhibit 1 Page 14
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 17 of 85 Page ID #:1970 EXHIBIT 2
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 18 of 85 Page ID #:1971 Exhibit 2 Page 15
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 19 of 85 Page ID #:1972 Exhibit 2 Page 16
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 20 of 85 Page ID #:1973 Exhibit 2 Page 17
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 21 of 85 Page ID #:1974 Exhibit 2 Page 18
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 22 of 85 Page ID #:1975 EXHIBIT 3
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 23 of 85 Page ID #:1976 Exhibit 3 Page 19
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 24 of 85 Page ID #:1977 Exhibit 3 Page 20
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 25 of 85 Page ID #:1978 Exhibit 3 Page 21
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 26 of 85 Page ID #:1979 Exhibit 3 Page 22
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 27 of 85 Page ID #:1980 EXHIBIT 4
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 28 of 85 Page ID #:1981 Exhibit 4 Page 23
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 29 of 85 Page ID #:1982 EXHIBIT 5
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 30 of 85 Page ID #:1983 Exhibit 5 Page 24
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 31 of 85 Page ID #:1984 EXHIBIT 6
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 32 of 85 Page ID #:1985 Exhibit 6 Page 25
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 33 of 85 Page ID #:1986 EXHIBIT 7
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 34 of 85 Page ID #:1987 Exhibit 7 Page 26
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 35 of 85 Page ID #:1988 EXHIBIT 8
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 36 of 85 Page ID #:1989 Exhibit 8 Page 27
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 37 of 85 Page ID #:1990 EXHIBIT 9
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 38 of 85 Page ID #:1991 Exhibit 9 Page 28
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 39 of 85 Page ID #:1992 Exhibit 9 Page 29
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 40 of 85 Page ID #:1993 Exhibit 9 Page 30
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 41 of 85 Page ID #:1994 Exhibit 9 Page 31
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 42 of 85 Page ID #:1995 EXHIBIT 10
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 43 of 85 Page ID #:1996 Exhibit 10 Page 32
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 44 of 85 Page ID #:1997 Exhibit 10 Page 33
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 45 of 85 Page ID #:1998 Exhibit 10 Page 34
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 46 of 85 Page ID #:1999 Exhibit 10 Page 35
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 47 of 85 Page ID #:2000 EXHIBIT 11
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 48 of 85 Page ID #:2001 Exhibit 11 Page 36
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 49 of 85 Page ID #:2002 Exhibit 11 Page 37
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 50 of 85 Page ID #:2003 Exhibit 11 Page 38
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 51 of 85 Page ID #:2004 Exhibit 11 Page 39
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 52 of 85 Page ID #:2005 Exhibit 11 Page 40
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 53 of 85 Page ID #:2006 Exhibit 11 Page 41
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 54 of 85 Page ID #:2007 EXHIBIT 12
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 55 of 85 Page ID #:2008 Exhibit 12 Page 42
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 56 of 85 Page ID #:2009 EXHIBIT 13
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 57 of 85 Page ID #:2010 Exhibit 13 Page 43
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 58 of 85 Page ID #:2011 EXHIBIT 14
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 59 of 85 Page ID #:2012 Exhibit 14 Page 44
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 60 of 85 Page ID #:2013 EXHIBIT 15
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 61 of 85 Page ID #:2014 Exhibit 15 Page 45
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 62 of 85 Page ID #:2015 EXHIBIT 16
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 63 of 85 Page ID #:2016 Exhibit 16 Page 46
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 64 of 85 Page ID #:2017 Exhibit 16 Page 47
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 65 of 85 Page ID #:2018 Exhibit 16 Page 48
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 66 of 85 Page ID #:2019 Exhibit 16 Page 49
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 67 of 85 Page ID #:2020 Exhibit 16 Page 50
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 68 of 85 Page ID #:2021 Exhibit 16 Page 51
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 69 of 85 Page ID #:2022 Exhibit 16 Page 52
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 70 of 85 Page ID #:2023 Exhibit 16 Page 53
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 71 of 85 Page ID #:2024 Exhibit 16 Page 54
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 72 of 85 Page ID #:2025 Exhibit 16 Page 55
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 73 of 85 Page ID #:2026 EXHIBIT 17
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 74 of 85 Page ID #:2027 Exhibit 17 Page 56
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 75 of 85 Page ID #:2028 Exhibit 17 Page 57
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 76 of 85 Page ID #:2029 Exhibit 17 Page 58
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 77 of 85 Page ID #:2030 Exhibit 17 Page 59
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 78 of 85 Page ID #:2031 EXHIBIT 18
Exhibit 18 Page 60 Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 79 of 85 Page ID #:2032
Exhibit 18 Page 61 Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 80 of 85 Page ID #:2033
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 81 of 85 Page ID #:2034 EXHIBIT 19
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 82 of 85 Page ID #:2035 Exhibit 19 Page 62
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 83 of 85 Page ID #:2036 Exhibit 19 Page 63
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 84 of 85 Page ID #:2037 EXHIBIT 20
Case 2:14-cv-02334-CAS-MRW Document 55 Filed 05/07/14 Page 85 of 85 Page ID #:2038 Exhibit 20 Page 64