enforcement task force panel - Ohio Department of Commerce by xiangpeng


                    Harvey McCleskey, Attorney Inspector
                         Ohio Division of Securities

                    Pamela Denczak Henderhan, Detective
                    Jackson Township Police Department

                        Julie Haymond, Special Agent
                                Cleveland FBI

                          Bridget Meehan Brennan
                   U.S. Attorney’s Office, Cleveland, Ohio

              Robert Burson, Sr. Associate Regional Director
             Chicago U.S. Securities & Exchange Commission 
Each agency represented on the Enforcement Task Force Panel will describe their
mission and priorities in the financial fraud arena.

They will also discuss their role in a recent securities matter that resulted in
incarceration for a former securities licensee. Their discussion will represent a
chronology of the investigation from the first tip through the sentencing.

             “Former Jackson Twp. Financial Advisor Headed to Prison”

On the following pages is the Ohio Division of Securities, Enforcement Update. The
update highlights noteworthy matters since the 2009 Securities Conference.
      2010 Ohio Securities Conference
       Enforcement Task Force Panel
HARVEY MCCLESKEY is the Attorney Inspector of the Ohio Division of Securities. As
Attorney Inspector, Mr. McCleskey is responsible for managing investigations into all
potential violations of the Ohio Securities Act. He also represents the Division on the
North American Securities Administrators Association Reg. D Investigations Project
Group. Prior to his association with the Division, he worked for the Unemployment
Compensation Review Commission, and served as Section Chief for the Ohio
Department of Public Safety. He also worked in corporate security for The Limited, Inc.
and served as an Ohio State Trooper assigned to the Executive Protection Unit for
former Governor Richard Celeste. Mr. McCleskey received his Bachelor of Science
from Miami University and a Juris Doctorate from The Ohio State University.

PAMELA DENCZAK HENDERHAN is a Detective with the Jackson Township Police
Department in Massillon, Ohio. Detective Henderhan has been a police officer for 24
years, working 8 years as a uniformed officer and 16 years as an investigator. Her
experience includes investigating money laundering cases, financial crimes, gambling,
sex crimes, felonious assaults, property crimes, and trademark counterfeiting. She has
held positions that included assignments to the Stark County Metro Narcotics Unit and
FBI task force. Detective Henderhan spent 12 years working undercover narcotics
assignments, which involved hundreds of hand-to-hand undercover drug buys, search
warrants, buy busts, raids, informant buys, and surveillance. She has worked cases in
collaboration with the Ohio Attorney General’s Office, the Drug Enforcement
Administration, the United States Secret Service, the Internal Revenue Service, and the
Federal Bureau of Investigation. Detective Henderhan received a Bachelor of Science
degree in Criminal Justice Studies from Kent State University, and has completed
hundreds of hours of specialized investigation training.

JULIE A. HAYMOND is a Special Agent with the Cleveland Federal Bureau of
Investigation, Canton Resident Agency. Her assignments include Counterterrorism and
White Collar Crime. Before joining the Canton Resident Agency in 2005, Ms. Haymond
spent seven years working as a Special Agent in the Detroit Field Office. In Detroit, her
assignments included Foreign Counterintelligence, White Collar Crime, Public
Corruption, and Civil Rights. Ms. Haymond was an Assistant Prosecutor for the City of
Canton from 1995 to 1998, and is currently licensed to practice law in the State of Ohio.
She received her undergraduate degree from Ohio University and her Juris Doctorate
from the University of Akron.
BRIDGET MEEHAN BRENNAN is an Assistant United States Attorney in the Northern
District of Ohio, Eastern Division. Ms. Brennan is assigned to the Major Fraud and
Corruption Unit and specializes in matters involving securities fraud, mail fraud, wire
fraud, investment adviser fraud, bribery, and public corruption. Prior to joining the
United States Attorney’s Office, Ms. Brennan was a litigation associate at Baker
Hostetler in Cleveland, Ohio where she focused her practice in the areas of white collar
criminal defense, corporate investigations, commercial litigation, and First Amendment
litigation. Ms. Brennan received her undergraduate degree from John Carroll University
and her law degree from Case Western Reserve University. Ms. Brennan is admitted to
practice in Ohio, the Northern District of Ohio, the Sixth Circuit, and the United States
Supreme Court.

ROBERT BURSON is Senior Associate Regional Director for the Chicago Regional
Office of the U.S. Securities and Exchange Commission. In that capacity, he oversees
the Chicago Regional Office’s enforcement program. Mr. Burson joined the staff of the
SEC in 1990 after practicing law in the private sector. He has been responsible for
numerous successful investigations of accounting and financial fraud, international
offering fraud, insider trading, and misconduct by broker-dealers, investment advisers,
and investment companies. In 2002, he received the SEC’s Distinguished Service
Award for his contributions to the enforcement program. He is a graduate of the
University of Virginia and Yale Law School.

                           Ohio Division of Securities
                             Enforcement Update

Joseph D. Bonanno
On 4/19/10 in U.S. District Court in Cleveland, Joseph D. Bonanno was sentenced to 3
½ years on federal charges of wire fraud, making false statements, making false
statements in connection with the issuance of a passport, and aggravated identity theft.
He will be on probation for three years after his release. He was also ordered to pay a
$500.00 criminal monetary penalty. The Division had revoked Bonanno’s Ohio
investment adviser representative license on 5/12/09, after learning that he had two
outstanding warrants against him from the State of Massachusetts. In 1989, Bonanno
fled the Boston, MA area to escape two outstanding warrants against him for larceny.
Bonanno landed in Northeast Ohio and assumed the identity of Timothy W. Hyde, an
infant from Youngstown, Ohio that died a few days after his birth. Authorities
discovered his real identity following an arrest in early 2009 in Jackson Township when
he was accused of striking his wife. The Jackson Township police forwarded the
information to the FBI, which discovered his true identity during their investigation.

He was also charged in a superseding indictment in U.S. District Court in Akron on
6/16/09. Those counts included 2 counts of fraud with identification documents and 1
count of false statements of a passport.

Ferrell Carden
On 2/9/10, Ferrell Carden pleaded guilty in the Harrison County Court of Common Pleas
to the charge of securing writings by deception, a second degree felony. His indictment
came after an April 2008 Cease and Desist Order was issued by the Division, where he
was ordered to stop dealing in securities. The Order found that Carden sold
unregistered securities, sold securities without a license, made misrepresentations in
connection with the sale of securities, and engaged in fraudulent practices. The Order
specified that he had knowingly misrepresented to a married couple that funds they
provided would be used exclusively for investments in a water treatment plant or in a
beach restoration project, when they were in fact used for other purposes. The amount
invested was $350,000.00. On 4/27/10 he was sentenced to community control for a
period of five years. Additionally, he is required to complete a term of six months of
house arrest and ordered to pay restitution in the amount of $225,000 to his four

Larry Corna
On 10/22/09, Larry Corna was sentenced to prison for 4 years and 11 months after
admitting to a felony racketeering charge. Corna had been indicted in Franklin County
on charges of theft, forgery, making false representations in the sale of securities,
securities fraud, and securing writings by deception on 9/1/06. He was in the business
of “flipping” real estate by rehabbing properties and allegedly bilked five persons into
investing money in his scheme. On 9/30/09, he pleaded guilty to 5 felony counts,
including counts of forgery, theft, engaging in a pattern of corrupt activity, and money

David J. Harriett

On 6/9/10, the Ohio Division of Securities issued a Cease and Desist Order against
David J. Harriett of Warren, Ohio, president of D.J. Harriett, Inc., and against D.J.
Harriett, Inc., a Canfield, Ohio company. By terms of the Cease and Desist Order, the
Division ordered Harriett and his company to cease from selling fraudulent securities.

In 2008 and 2009, Harriett represented to investors that he and his company, D.J.
Harriett, Inc., were approved “project managers” for the construction of new McDonald’s
franchise restaurants in Northeast Ohio. Harriett solicited investors for D.J. Harriett, Inc.
and, in exchange for their investment, provided them with promissory notes that
purportedly guaranteed the return of their investment, plus significant interest, which
would be safeguarded by insurance.

Additionally, on June 9, 2010, David J. Harriett pleaded guilty in the United States
District Court for the Northern District of Ohio, to mail fraud. It is estimated that 200
investors lost a combined $7 million in the Ponzi scheme. He is to be sentenced on

Julie Mae Jarvis
On 10/14/09, Julie Mae Jarvis was sentenced to 5½ years in prison. A civil suit was
filed against Ms. Jarvis by an investor in the Franklin County Court of Common Pleas on
4/3/09. On 4/8/09 the SEC also filed a civil lawsuit against her. Ms. Jarvis was alleged
to have defrauded the elderly and misrepresented and concealed the nature of her
misappropriations. She signed a plea agreement to a Bill of Information on 4/23/09,
charging her with one count of mail fraud and agreed to forfeit $2,663,681.00 in assets.
She also pleaded guilty on 5/13/09 to 1 count of fraud involving the theft of
approximately $2.7 million from two elderly clients. On April 10, 2009, the Division
suspended Ms. Jarvis’s investment adviser representative license. The Division
revoked the license on May 28, 2009.

James Powell
On 6/28/10, James Powell pleaded guilty to 1 count of attempt and conspiracy to
commit mail fraud and fraud by wire, radio or television. He was released after
processing and surrendering his passport. He is scheduled to be sentenced on 9/28/10.

The Powell case has been ongoing since 2008 when the Butler County Common Pleas
Court issued a temporary restraining order against James D. Powell; the estate of David
L. Colwell; Midwest Marketing; Capital Investments; Great Miami Real Estate, LLC; and
Great Miami Debenture LLC, all of Hamilton, Ohio. An agreed preliminary injunction
was issued against Hubert Jackson Rials of Cunningham, Kentucky; Stephen
Chatsworth Jacobs of Hamilton, Ohio; and Kevin Miller of Fairfield, Ohio. The Division
alleged that Colwell, Rials, Jacobs, and Miller sold investments for the companies
owned and operated by Powell. The Division also sought a preliminary and permanent
injunction and the appointment of a receiver to manage and operate Capital
Investments, the Great Miami companies, and Midwest Marketing and their
subsidiaries. The Division alleged that since 2002 the defendants sold $11 million in
securities to approximately 100 investors in Ohio and other states. Investors were told
that their investments would be used to acquire and develop real estate. In its action,
the Division alleged that the defendants sold unregistered securities; sold securities
without a license; misrepresented to investors that the investments were safe, risk-free,
and backed by the Federal Deposit Insurance Corporation (FDIC) or otherwise insured;
and failed to disclose to investors that they were not licensed, the securities were
unregistered, and that Colwell and Miller had previously been issued cease and desist
orders by the Division of Securities. A preliminary injunction was issued on February 4,
2009, against James D. Powell, Capital Investments, Great Miami Real Estate, LLC,
and Great Miami Debenture. The restraining order and preliminary injunction bar the
defendants from selling, offering to sell, or transferring any securities; buying, selling or
transferring any real estate without the court’s prior approval; and engaging in any
deceptive, fraudulent or manipulative act. It further barred the subjects of the
restraining order from destroying or altering records as well as divesting of any assets
derived from the sale of securities. In addition, the court appointed a receiver to
manage and operate the companies.

On 1/20/10, Kevin Miller, one of the unlicensed securities salespersons with Capital
Investments pled to one count of conspiracy to commit mail fraud in his role in an
investment scheme and one count of obstruction of an investigation for submitting false
victim questionnaires to the Ohio Division of Securities.

On August 26, 2010, Kevin Miller, was sentenced in the United States District Court for
the Southern District of Ohio, to 15 months imprisonment. In addition to the prison time,
Miller’s sentence includes two years of supervised release, and an order to pay
restitution of $184,354.36 to the three victims directly affected by his actions. Miller is
also prohibited from engaging in any further investment solicitation activity.

Joanne Schneider
On 5/13/10, the Court of Appeals for the Eighth Appellate District unanimously reversed
and vacated the three-year prison sentence Joanne Schneider received for her role in a
$60 million securities fraud scheme. Schneider ran a large Ponzi scheme in the
Cleveland area, selling promissory notes ostensibly guaranteed by the profits of her real
estate development business. Schneider was sentenced in March of 2009 after

pleading guilty to thirteen securities-related charges, which included one count of
engaging in a pattern of corrupt activity. The Cuyahoga County prosecutor’s office
appealed the March 2009 sentence, citing a statute that mandates a ten-year sentence
where the underlying act in a pattern of corrupt activity is a felony of the first degree.
The Court of Appeals agreed that the three-year sentence was impermissibly short and
remanded the matter back to the trial court. On 8/31/10, the Cuyahoga County Court of
Common Pleas sentenced Joanne Schneider to ten years in prison for engaging in a
pattern of corrupt activity.

Schneider’s indictment and subsequent conviction represented the culmination of a
four-year effort by the Ohio Division of Securities and the Cuyahoga County
Prosecutor’s Office against Joanne Schneider. The Division issued a Cease and Desist
Order against Schneider in May 2004 based on her sale of unregistered promissory
notes. The Division later obtained a preliminary injunction against Schneider in
December 2004, after she violated that Cease and Desist Order. In February 2005, the
Division discovered that Joanne Schneider violated the injunction by continuing to sell
securities without the permission of the court and the court-appointed Special Master.
The Division then sought the appointment of a receiver, who took possession of
Schneider’s assets, and referred the matter to the Cuyahoga County Prosecutor’s office
for criminal prosecution.

Phil Smith
On 11/18/09, Phil Smith was sentenced to 6 months in Darke County jail and ordered to
pay $15,000 in restitution to his victims, based on his ability to repay. Previously, on
9/17/09 Smith pleaded guilty to 18 counts, including securities fraud, selling
unregistered securities, misrepresentations in the sale of securities, and unlicensed
sales. He was found to have sold investment contracts of Wellspring Capital Group
promising 1000% return to approximately 118 Ohio investors. The SEC obtained a
preliminary injunction against Wellspring in September 2003 and the founder of the
company, Blake Prater, was sentenced in March 2007. Prater is serving ten years in
prison on one count of securities fraud and one count of conspiracy to engage in certain
monetary transactions involving proceeds of securities fraud.

James Stamp
On 9/20/09 in Summit County, James A. Stamp was sentenced to 3 years of
incarceration, suspended on the condition that he complete 3 years of community
service, and make full and complete restitution to three Ohio victims. Previously, Stamp
pleaded guilty to 10 felony counts, in connection with sales of “membership certificates”
in Stamp’s company, Shema Capital Partners LLC, to three Ohio customers. The
charges included selling unregistered securities, securities fraud, false representations,
deception to secure documents, and one count of grand theft.

Bret Allen Swisher
On 1/11/10, Bret Allen Swisher was sentenced to 5 years in prison by Richland County
Common Pleas Court. He was also fined $50,000 and ordered to pay restitution of
$4,463 to one client. Following his release from prison, Swisher will be subject to 5
years of community control.

Swisher had been indicted on 128 counts on 7/20/09 and on 10/5/09, he pleaded guilty
to 39 felony charges. The counts included making false reports in securities
transactions, forgery, securities fraud, aggravated theft, false representation in the sale
of securities, telecommunications fraud, receiving stolen property, unauthorized use of
property and securing writings by deception.

Swisher was formerly licensed with Legg Mason and McDonald Investments. He
completed “letter of authorization” forms and forged clients’ signatures to obtain funds
from brokerage accounts without the clients’ permission; transferred client funds into
accounts he controlled; and converted client funds to his own personal use without their
knowledge or authorization. He also stole money from some clients and used the funds
to pay back other clients.

William E. Thurman, II
On 10/20/10, William E. Thurman II was indicted in the Butler County Court of Common
Pleas on a charge of selling an unregistered security, a third degree felony. His
indictment came after an investigation determined that in January of 2005, Thurman
sold an investment security in a company known as New Process Technology, RLLP to
an Ohio investor. The security was not registered to be sold under the Ohio Securities
Act. The Division had previously issued a Cease and Desist Order against Thurman in
a separate matter involving Tee to Green Golf Parks, Inc. in August of 2000.

On 6/22/10, the case against Thurman was dismissed when Thurman made restitution
to the victim through the Butler County Prosecutor’s office. The amount of the
restitution was $19,260.

Melvin R. Wilder
On 7/14/10, following a criminal referral by the Ohio Division of Securities, a Franklin
County grand jury indicted Melvin Wilder on 12 counts of securities law violations. The
12 felony counts include three counts of selling unregistered securities, three counts of
securities fraud, and six counts of making false reports of transactions in securities.
Wilder is charged with crimes relating to the sale of $30,000 in securities to a former
Ohio resident currently living in Michigan. A trial date has not yet been scheduled.

Wilder is the owner of Wilder & Associates, a tax preparation business in Worthington,
Ohio. He has never been licensed by the Division of Securities.

2010 Ohio Securities Conference

                The Division of Securities
               Enforcement Section Update
                              Presented by
                           Harvey McCleskey
                           Attorney Inspector
             Ohio Division of 
“The Ohio Securities Law gives the Division of
  Securities comprehensive powers to regulate
  certain types of transactions in securities and
  out-of-state real estate. Its purpose is stated
  by Ohio courts to guard investors against
  fraudulent enterprises, to prevent sales of
  securities based only on purely speculative
  schemes, and to protect the public from
  swindling peddlers.”
                2003 Ohio Securities Law & Practice
             U.S. Securities 
          Exchange Commission
Joined the staff of the SEC in
1990 after practicing law in the
private sector.

In 2002, he received the SEC’s        Robert Burson
Distinguished Service Award for
his contributions to the
enforcement program.
                                        Senior Associate 
                                       Regional Director 
 He is a graduate of the University
of Virginia and Yale Law School.         Chicago, Illinois
SEC Enforcement Division
 1200 staff members
 40 % in Washington, D.C.
 60% in regions
 What SEC Enforcement 
  Files actions relating to violations of federal
  securities laws
SEC actions are civil, not criminal
SEC actions may be filed
  Federal District Court or as
  Administrative proceedings before the
What SEC Enforcement 
Primary remedies include
   Money penalties
   And various industry suspensions & bars
The Securities Industry
12,000 public companies
5,800 registered broker-dealers
8,000 mutual funds
11,300 investment advisers
($40 trillion in managed assets)
Unregistered entities
 SEC Enforcement:  FY 
674 total cases
Largest categories:
  Financial fraud & issuer reporting (23%)
  Investment Adviser/Mutual Funds (13%)
  Broker-dealer (9%)
  Offering fraud (18%)
  Insider trading (9%)
  Market manipulation (8%)
             Federal Bureau of 
Her assignments include
Counterterrorism and White
Collar Crime.
Assistant Prosecutor for the
City of Canton from 1995 to
                                 Julie Haymond
Currently licensed to practice       Cleveland FBI, 
law in the State of Ohio.
                                   Canton Resident 
She received her
undergraduate degree from                   Agency
Ohio University and her Juris
Doctorate from the University
of Akron.
          U.S. Attorney’s Office
Assigned to the Major Fraud &
Corruption Unit
Undergraduate degree from           Bridget Meehan
John Carroll University and her
law degree from Case Western            Brennan
Reserve University.                       Assistant United States
Admitted to practice in Ohio, the    Attorney Northern District of
Northern District of Ohio, the
                                          Ohio, Eastern Division
Sixth Circuit, and the United
States Supreme Court.
       Jackson Twp Police Dept
Police officer for 24
years, working 8 years
as a uniformed officer
and 16 years as an
investigator.              PAMELA DENCZAK
Spent 12 years working        HENDERHAN
undercover narcotics                   Detective
assignments.                      Massillon, Ohio
Received a Bachelor of
Science degree in
Criminal Justice Studies
from Kent State
    Who Is This Guy?

Joseph D. Bonanno aka Timothy W. 
             Timothy W. Hyde
Timothy Welland
Hyde born
February 03,
1976 in Sharon
Died 9 days later
on February 12,
                        Joseph D. Bonanno
                     Joseph Bonanno assigned SSN at age
                     Attends OSU never graduates
                     1984 Moves to Boston for Job as District
                     Manager sales at Nationwide
                     Warehouse and Storage
                     1987 Starts own Furniture Store
                     Business Fails
Canton Repository 
 Joseph D. Bonanno
1988 Bonanno charged with 2 counts of
Felony Larceny in Boston, MA
  Loss $80K
  Didn’t pay vendors or purchasers about
  150 victims
1989 last year income reported for
Becomes a Car Salesman in Ohio
Life Now As Timothy W. 

1992 Obtains new Social Security
Number…. Became Timothy Hyde
May 1998 Hyde DUI – used name of
brother (Robert Bonanno)
January 2000 Hyde filed Bankruptcy
  Based on a failed mattress store
   Timothy W. Hyde
June 2003 Hyde DUI – prints ran and
came back as brother – charged with
Falsification and Obstruction

                          Canton Repository 4/19/09
       2000 ‐ 2007
2001-2002 Hyde worked as a Securities
Salesperson at AXA Advisors LLC
March 2002 - January 2007 Hyde
worked as a Salesperson & Investment
Advisor Rep at Transamerica Financial
Advisors Inc
  Resigned while under Internal Review and
  left Firm owing fees
       2007 ‐ 2008
January 2007 – December 2008 Hyde
Salesperson & Investment Advisor Rep
at Cadaret, Grant & Co. Inc
Tribune Chronicle 4/25/09
 December 2008
Anonymous Letter to Cadaret,
Canton Repository and FINRA
12/5/08 Hyde agreed to sell
business to Bailey, Williamson,
 December 2008
12/26/08 Hyde charged with
Domestic Violence by Jackson Twp

                          Canton Repository 4/19/09

12/31/08 Resigns from Cadaret
           January 2009
January 2009 – April 2009 Hyde Investment Advisor
Rep and Owner at Hyde Financial LLC
   Cadaret Broker Dealer
1/13/09 Hyde applies for US Passport
1/14/09 Brother-in-law files police report to Jackson
   Threatened to send someone after him
   Believes threat was made because found out true
            January 2009
1/15/09 Cadaret Grant Reps surprise visit to
Hyde Financial Investments
  Question about allegations in letter
  Hyde denied he was Bonanno
  Robert Bonanno is his half brother, his mother
  married a Bonanno
  Question if selling business
     Stated he was “walking away”, “giving them the
     business” (Bailey, Williamson, Dombrowski)
January 23, 2009
Passport Issued
Change Company name to Hyde
Financial Investments LLC
  No longer a Broker, Now a Registered
  Investment Adviser
  Hyde operating as an analyst, making
  decisions about investments behind the
  RIA no FINRA requirements
     January 2009
Plans to gift company to wife, Lisa Hyde

Dombrowski gives Hyde a cashiers check
  Not supposed to have any funds
        Feb – Mar 2009
Hyde licensed by the Division as Investment
Advisor Representative for Hyde Financial
  Hyde Listed as president
  3/5/9 William Nappi listed as president
Registered with SEC – more than $25 million
as Investment Advisor
FBI Initiates Investigation
            April 2009
4/3/09 Changed name to Helios Investments,
Bonanno’s family listed as majority owners:
  Mom          24%
  Dad          24%
  Brother      10%
  2 children   20%
  Dombrowski   2%
  Nappi        2%
                April 2009
On 4/8/09 the Division suspended Hyde’s Ohio
investment adviser representative license
  Issued notice of its intent to revoke Hyde’s license.

On 4/8/09 Bonanno/Hyde was indicted in U.S.
Northern Ohio District Court
  On 3 criminal counts
     1 count of wire fraud
        18 USC 1343
     2 counts of false statements to SEC
        18 USC 1001
         April 2009
4/21/09 Hyde appeared in
Massachusetts in response to 1989
  Held on $200K cash bond
4/28/09 Arrest warrant issued in
  Ensure Hyde appeared at arraignment on
  the federal charges on June 4th.
        May 2009
Hyde goes to Boston to take care of old
  Bond set at $200K cash
Employees expect him to return within a
few days
  Remains incarcerated
                                  June 2009
                            6/16/09 Bonanno was charged
                            with 4 additional counts in a
                            superseding indictment entered
                            in the Northern Ohio District
                             18 USC 1343 – wire fraud
                             18 USC 1028(a)(1) – aggravated ID theft
                             18 USC 1001 – false statements to SEC
                             18 USC 1542 – false statements in
Canton Repository 4/19/09    Passport
          August 2009
Bonanno plead guilty on 8/6/09 to 5
  1 count each of wire fraud, aggravated
  identity theft, making a false passport
  2 counts of making or writing false
  documents. Sentencing is delayed due to
  pending charges in Boston.
   February 2010
Helios closes office
  Or at least leaves office space!
Bonanno pleads to 2 counts in
Middlesex Co (Boston)
  Larceny by false pretenses over $250
  Uttering a forged instrument
  Time served and restitution
         April 2010
U.S. District Court in Cleveland
  Sentenced Joseph D. Bonanno
  3 ½ years on federal charges
     Wire fraud, making false statements, making
     false statements in connection w/ the
     issuance of a passport, aggravated identity
  3 years probation

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