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Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 1 of 15 Page ID #:448 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 UNITED STATES OF AMERICA, CV 04-2788 ABC (RCx) 11 CV 04-3386 ABC (RCx) Plaintiff, CV 05-3910 ABC (RCx) 12 v. ORDER RE: MOTION FOR AN ORDER 13 OF CONTEMPT AGAINST DAS CORP., REAL PROPERTY LOCATED AT 475 WILLIAM MILLS, AND JOHN 14 MARTIN LANE, et al., KARACZYNSKI; MOTION FOR AN ORDER OF CONTEMPT AGAINST ERIC 15 Defendants. HONIG, CHRISTOPHER KIM, AND ALEXANDRIA INVESTMENT LLC; and 16 MOTION FOR AN ORDER COMPELLING DAS TO DEPOSIT SUMS WITH THE 17 COURT 18 19 Pending before the Court are four motions filed by Optional 20 Capital Inc. (“Optional”). This Order resolves the following three: 21 Motion for an Order of Contempt Against DAS Corporation (“DAS”), 22 William Mills (“Mills”) and John Karaczynski (“Karaczynski”) (docket 23 no. 743); Motion for an Order of Contempt Against Eric Honig, 24 Christopher Kim, and Alexandria Investment LLC (docket no. 742) 25 (“Contempt Motions”); and Motion for an Order Compelling DAS to 26 Deposit All Sums Obtained from Credit Suisse (docket no. 745) (“Motion 27 to Compel”), filed on May 16, 2011. All opposing parties filed 28 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 2 of 15 Page ID #:449 1 Oppositions on May 23, 2011. Optional filed Replies and, as to the 2 motion for contempt against DAS and its counsel, Objections on May 31, 3 2011. DAS and Mills filed a Response to Optional’s objections on June 4 7, 2011, in which Karaczynski joined and to which Optional filed an 5 Objection on June 10, 2011. The Court finds the Motions appropriate 6 for resolution without oral argument and hereby VACATES the hearing 7 set for June 20, 2011. For the foregoing reasons, the Court DENIES 8 the Motions. The fourth motion, seeking to Compel Alexandria and 9 Christopher Kim to Produce Bank Statements, remains on calendar. 10 11 I. BACKGROUND 12 This Order assumes familiarity with the procedural and 13 substantive turns of this case. As such, the Court will set forth 14 only as much background as is relevant to the disposition of this 15 Motion. 16 First, the Court will identify the parties. The Kim Claimants, 17 including Christopher Kim (“Kim”) and Alexandria Investment LLC 18 (“Alexandria”), among others, are the persons against whom the 19 Government instituted the forfeiture action that started this case. 20 Eric Honig is counsel for the Kim Claimants in this action. DAS 21 Corporation and Optional Capital were also claimants in the forfeiture 22 action; each contended that it was entitled to recover the forfeited 23 Kim assets because they were victims of fraud and other misdeeds the 24 Kim parties committed. DAS also pursued claims arising out of the 25 same alleged misconduct against certain Kim Claimants in Los Angeles 26 County Superior Court and in Switzerland. William Mills, an attorney 27 with the law firm Parker Shumaker Mills LLP, represents DAS in this 28 action. John Karaczynski, an attorney with the law firm Akin Gump 2 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 3 of 15 Page ID #:450 1 Strauss Hauer & Feld, represented DAS in its state court action 2 against the Kim parties and appears to have been involved in some 3 capacity in DAS’s proceedings against the Kims in Swtizerland. 4 This matter started out as a forfeiture case filed in May 2005 in 5 which the United States sought the forfeiture of certain assets in 6 possession of the Kim Claimants. The Government seized various Kim 7 assets located in the United States. The Government also sought to 8 forfeit two foreign bank accounts: an account in the name of 9 Alexandria Investment LLC and another in the name of Erica Kim, both 10 held with Credit Suisse Bank in Geneva, Switzerland (the “Credit 11 Suisse accounts” or “accounts”). To secure these accounts, the 12 Government, relying on the Mutual Legal Assistance Treaty (“MLAT 13 request”), asked Switzerland to freeze them. The Swiss authorities 14 granted the request and froze the accounts pending this litigation 15 and/or its own investigation. Both Optional and DAS filed claims to 16 the various Kim assets, including the Credit Suisse accounts. DAS 17 claimed 14 billion Korean won, approximately $13 million. DAS sought 18 to recover the same amount in its state court case against the Kims. 19 On April 17, 2007, DAS instituted separate criminal proceedings 20 in Switzerland against the Kim Claimants, seeking 14 billion won. 21 DAS’s Swiss complaint resulted in a second freeze order against the 22 Credit Suisse accounts. In December 2008, DAS informed the Court and 23 the parties that it had initiated the Swiss proceedings and that the 24 accounts were subject to the second freeze order. 25 On March 13, 2007, the Court granted the Kim Claimants’ summary 26 judgment motion in the Government’s forfeiture case; the Ninth Circuit 27 affirmed that decision on October 3, 2008. The Government’s 28 forfeiture case was therefore extinguished. Following additional 3 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 4 of 15 Page ID #:451 1 litigation, the Court found that the other claimants’ – notably DAS 2 and Optional – claims had also been adjudicated and were therefore 3 extinguished. The Ninth Circuit reversed and, by its mandate issued 4 January 28, 2011, remanded the matter to this Court for it to 5 adjudicate the competing claims of all claimants to the seized 6 properties. 7 On February 25, 2011, the Court scheduled a status conference and 8 ordered the parties to submit a joint report before the conference. 9 The preparation of the joint report was characteristically 10 contentious. The Kim Claimants and DAS on one hand, and Optional on 11 the other, submitted separate reports in which they essentially talked 12 past each other; DAS did not contribute substantively to the report. 13 Because these efforts were not helpful, the Court continued the status 14 conference and ordered the parties to file a true joint report and 15 specifically identified topics the parties were to address. Although 16 the Government’s case was over, the Court also ordered it to file a 17 report, as a friend of the Court, explaining what it knew about the 18 Credit Suisse accounts and the MLAT freeze. 19 On April 4, 2011, for reasons unexplained, DAS filed a Notice 20 withdrawing its claims in the forfeiture case. On April 18, 2011, the 21 parties submitted their Joint Status Report and, on April 21, 2011, 22 Optional also filed a separate “Supplemental” Report. The April 18, 23 2011 Report revealed why DAS withdrew its claims: it dropped its 24 criminal complaint against the Kims in Geneva, causing the Swiss 25 prosecutor to lift the freeze on the Credit Suisse accounts and to 26 order Credit Suisse to transfer 14 billion won from those accounts to 27 DAS. DAS also dismissed its parallel state court case against the 28 Kims. It was evident that DAS and the Kim Claimants had reached some 4 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 5 of 15 Page ID #:452 1 sort of settlement of DAS’s claims. 2 At the status conference on May 2, 2011, the Court questioned 3 DAS’s and the Kims’ counsel extensively to attempt to learn whether 4 the transfer of funds from the Credit Suisse accounts to DAS was 5 wrongful in any way. See generally Status Conference Transcript, 6 Rogari Decl. re: Kims Contempt Mot. Exh. F) (“Status Conf.”). John 7 Karaczynski, counsel for DAS in the state court case, stated that the 8 transfer of funds was a result of a confidential settlement of DAS’s 9 state court action, explained that DAS dropped its Swiss complaint and 10 obtained the funds through Swiss procedures, stated that the funds 11 were in fact transferred to DAS, and said that DAS would not surrender 12 the funds to the Court pending adjudication of the parties’ competing 13 claims in this case. 14 Optional argued that the DAS-Kims settlement was designed to 15 thwart this Court’s jurisdiction and deprive Optional of its 16 opportunity to pursue its claims. Optional filed a number of motions 17 in response to the events in Switzerland, including the present 18 Contempt Motions and Motion to Compel. In its Contempt Motions, 19 Optional contends that by so interfering with the Credit Suisse 20 accounts, DAS, its counsel, and the Kim claimants and their counsel 21 violated two Ninth Circuit mandates and two orders of this Court, and 22 should be held in contempt of court. In its Motion to Compel, 23 Optional raises similar arguments and urges the Court to remedy DAS’s 24 misconduct and preserve the assets by ordering DAS to deposit with the 25 Clerk of Court the sums it obtained from the Credit Suisse accounts 26 pending the resolution of all claims in this case. 27 // 28 // 5 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 6 of 15 Page ID #:453 1 II. DISCUSSION 2 The Court will address Optional’s Contempt Motions first, and its 3 Motion to Compel second. 4 A. Contempt Motions 5 1. Legal Standard for Contempt 6 “[C]ontempt is a severe remedy, and should not be resorted to 7 where there is a fair ground of doubt as to the wrongfulness of the 8 defendant’s conduct.” Cal. Artificial Stone Paving Co. v. Molitor, 9 113 U.S. 609, 618 (1885). A party seeking civil contempt sanctions 10 must prove “(1) that [the individual or entity] violated the court 11 order, (2) beyond substantial compliance, (3) not based on a good 12 faith and reasonable interpretation of the order, (4) by clear and 13 convincing evidence.” Labor/Cmty. Strategy Center v. Los Angeles 14 County Metro. Transp. Auth., 564 F.3d 1115, 1123 (9th Cir. 2009) 15 (citation omitted). “[T]o support a contempt motion, the order 16 alleged to have been disobeyed must be sufficiently specific.” Balla 17 v. Idaho State Bd. of Corrections, 869 F.2d 461, 465 (9th Cir. 1989). 18 “If an injunction does not clearly describe prohibited or required 19 conduct, it is not enforceable by contempt.” Gates v. Bertram, 98 20 F.3d 463, 468 (9th Cir. 1996). A court may not hold a person in 21 contempt unless it finds that the party requesting the sanction has 22 proven contempt by clear and convincing evidence. In re Dual-Deck 23 Video Recorder Antitrust Litig., 10 F.3d 693, 695 (9th Cir. 1993). 24 2. Motion for Contempt Against DAS and its Counsel. 25 As the standard for contempt indicates, the threshold task is to 26 identify the allegedly-violated court order and determine whether it 27 is “sufficiently specific” to support a finding of contempt. As 28 applied to this case, the question is whether any orders in this case 6 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 7 of 15 Page ID #:454 1 barred DAS, with the help of its attorneys, from obtaining the funds 2 in the Credit Suisse account in the manner described. Optional’s 3 motion is well-argued and passionate, and identifies several orders 4 that Optional claims DAS and its counsel violated. However, the Court 5 finds that none of the orders were sufficiently specific or clear to 6 support a finding of contempt. As such, the Court’s analysis begins – 7 and ends – with the threshold question. 8 First, Optional points to this Court’s December 31, 2008 minute 9 order denying the Kim Claimants’ motion for an order directing the 10 Government to withdraw its MLAT request and regarding the maintenance 11 of the Credit Suisse accounts. Optional contends that a clause that 12 reads “neither the Kim Claimants nor anyone else will withdraw the 13 funds until the Court orders otherwise” is an order that DAS and its 14 counsel violated. (Mot. 3:13-16.) However, Optional takes this 15 clause out of context. The sentence reads in its entirety: “If the 16 Court takes no action at this point, that is exactly what will occur: 17 the funds will continue to the held by Credit Suisse, and neither the 18 Kim Claimants nor anyone else will withdraw the funds until the Court 19 orders otherwise.” (12/31/2008 Minute Order.) This sentence does not 20 constitute an order; rather, it is merely an observation that, under 21 the status quo at that time, no party could reach the assets. Indeed, 22 the Court noted that it would not order the Government to withdraw the 23 MLAT request because to do so would be to relinquish the little 24 control the Court had over the funds. The Court also invited the 25 parties to reach some agreement about the custody of the funds, such 26 as a stipulation to bring them to the Clerk to Court, but no 27 stipulation was ever submitted. The bottom line of the December 31, 28 2008 order was that the Court would leave the status quo in place; the 7 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 8 of 15 Page ID #:455 1 spirit of that order was that the Court wanted to do what it could to 2 maintain whatever little control over the funds it had. But that does 3 not constitute an actual order barring the conduct DAS undertook in 4 Switzerland. 5 Similarly, Optional contends that DAS’s conduct violated this 6 Court’s November 3, 2009 order staying the final judgment pending 7 appeal. Optional does not elaborate on this argument. It is hard to 8 see how an order staying a judgment pending appeal constitutes an 9 order prohibiting a party from doing anything but enforcing the stayed 10 judgment. In addition, the judgment that was stayed was the Court’s 11 order releasing the funds to the Kim Claimants; that order was mooted 12 by the Ninth Circuit’s remand. As such, when the funds were 13 transferred in February 2011, the stay order was no longer effective. 14 The stay order cannot support a finding of contempt. 15 Finally, Optional points to the two mandates in which the Ninth 16 Circuit explained that this Court retained in rem jurisdiction to 17 adjudicate claims to the assets, including the Credit Suisse accounts. 18 See Mot. 4:9-5:11. But the Ninth Circuit did not issue any orders 19 directed at the parties’ conduct. Rather, in each instance, it merely 20 elaborated on forfeiture law and ordered this Court to proceed in 21 light of that explanation. If anything, the Ninth Circuit’s October 22 3, 2008 order acknowledged that this Court had in rem jurisdiction but 23 lacked actual control over the accounts, noting that “[f]or a court to 24 obtain jurisdiction, actual or constructive control over defendant 25 property located in a foreign country is not required.” U.S. v. Real 26 Property Located at 475 Martin Lane, 298 Fed.Appx. 545, 551 (9th Cir. 27 2008). Accordingly, none of the Ninth Circuit’s orders constitute an 28 order to any of the parties, and none supports a finding of contempt. 8 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 9 of 15 Page ID #:456 1 To be clear, and as was evident from the May 2 status conference, 2 the Court is not endorsing DAS’s conduct that, in effect, bypassed 3 this Court’s in rem jurisdiction over the Credit Suisse accounts. 4 However, as has become apparent, this Court’s actual control over 5 those assets was predicated on the MLAT request being in place and on 6 the Swiss government’s honoring that request by freezing the accounts, 7 a courtesy that the Swiss authorities revoked when the forfeiture case 8 was terminated. But the Swiss prosecutor instituted a separate freeze 9 order to protect the funds, a freeze that resulted from DAS’s filing 10 its criminal case in Switzerland. Optional was aware of DAS’s Swiss 11 proceedings, but apparently did not pursue a similar avenue itself. 12 Given the intent of the December 31, 2008 order, the Court would have 13 hoped – if not expected – DAS to return to this Court for 14 clarification regarding maintenance of the status quo as to the 15 accounts instead of collaborating with the Kims to secure a transfer 16 of the funds from the Kims to itself. Had that happened, the Court 17 could have considered issuing an order barring any party from 18 disturbing the accounts, thus protecting the assets and ensuring all 19 parties would be on equal footing in pursuit of their claims in this 20 Court. But that is not what DAS did. Instead, DAS disregarded the 21 spirit of the December 31, 2008 minute order. But the Court cannot 22 say that DAS violated the letter of any order issued by this Court. 23 DAS obtained the relief it sought from a legitimate authority that had 24 both jurisdiction and actual control over the accounts. Simply 25 stated, no district or circuit court order expressly prohibited DAS 26 from doing that. As such, the Motion for an order of contempt against 27 DAS, Mills, and Karaczynski is DENIED. 28 9 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 10 of 15 Page ID #:457 1 3. Motion for Contempt Against Eric Honig, Christopher Kim, and Alexandria Investment, LLC 2 Optional’s motion for contempt against Honig, Kim, and Alexandria 3 rests on many of the same grounds asserted against DAS and DAS’s 4 counsel. Specifically, Optional contends that by settling with DAS, 5 which led to the transfer of funds, Christopher Kim and Alexandria 6 violated this Court’s December 31, 2008 minute order, its stay order, 7 and the two Ninth Circuit mandates. Optional also contends that Honig 8 should be held in contempt for his involvement in the settlement, for 9 misleading the Court about what occurred in Switzerland, and for 10 failing to keep the Court sufficiently informed. But, as set out 11 above, the Court finds that none of these orders was specific or 12 definite enough to support a finding of contempt against Honig, Kim, 13 or Alexandria. 14 Optional raises an additional ground against Honig, contending 15 that he knowingly misled the Court and intentionally suppressed 16 material facts in violation of California Rules of Professional 17 Conduct 5-200 and 5-220. 18 Rule of Conduct 5-220 provides that “[a] member shall not 19 suppress any evidence that the member or the member’s client has a 20 legal obligation to reveal or produce.” Optional contends that Honig 21 violated this rule by not advising the Court of the DAS-Kims 22 settlement, by not disclosing that 14 billion won were removed from 23 the Credit Suisse accounts, and by not disclosing whatever he knew 24 about how much money those accounts contained. The Court has reviewed 25 its various orders, especially the sequence of orders regarding the 26 joint report and the status conference, and Honig’s submissions in 27 response thereto, and finds that Honig timely made the minimal 28 10 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 11 of 15 Page ID #:458 1 disclosures he was legally required to make. 2 To be sure, Honig was not forthcoming; he admits as much, arguing 3 that the confidentiality clause of the DAS-Kims settlement barred him 4 from affirmatively making such disclosures absent a court order. 5 (Opp’n 7:7-8:4.) The Court is not persuaded that the confidentiality 6 clause barred counsel from affirmatively disclosing the existence of a 7 settlement (as opposed to its contents), and as a practical matter, it 8 was clear that the Court would eventually formulate the narrow 9 questions that ultimately yielded the information it was seeking. 10 However, it is technically correct that Honig had no legal duty to 11 affirmatively disclose those facts, and that he eventually disclosed 12 them in response to the Court’s progressively more probing questions. 13 Rule of Conduct 5-200 provides in relevant part: 14 In presenting a matter to a tribunal, a member: 15 (A) Shall employ, for the purpose of 16 maintaining the causes confided to the member such means only as are consistent 17 with truth; 18 (B) Shall not seek to mislead the judge, judicial officer, or jury by an artifice 19 or false statement of fact or law. 20 Again, the Court cannot find that Honig was not truthful, nor 21 does it appear that he was misleading by artifice. Rather, he chose 22 to withhold information that, although relevant, he had no affirmative 23 duty to disclose. The motion to hold Honig in contempt is therefore 24 DENIED. 25 // 26 // 27 // 28 11 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 12 of 15 Page ID #:459 1 B. Motion to Compel DAS to Deposit Sums with the Clerk of Court. 2 Optional presents three grounds upon which its contends the Court 3 can order DAS to deposit with the Clerk of Court the sums it obtained 4 from the Credit Suisse accounts. 5 First, Optional contends that such an order would be an 6 appropriate response to DAS’s contemptuous behavior in obtaining those 7 funds. As discussed above, however, none of the Court’s orders can 8 support a finding of contempt. 9 Second, Optional contends that Rule G(7)(a) of the Supplemental 10 Rules for Admiralty and Maritime Claims grants the Court authority to 11 make such an order. Rule 7(G)(a) reads: 12 When the government does not have actual possession of the defendant property the 13 court, on motion or on its own, may enter any order necessary to preserve the property, to 14 prevent its removal or encumbrance, or to prevent its use in a criminal offense. 15 This Rule appears to assume that, even if the government lacks 16 possession of the property, the Court nevertheless has actual control 17 over the property. Indeed, a court could not make “any order 18 necessary to preserve the property” without having some kind of 19 control over that property. As discussed above, this Court did not 20 control the Credit Suisse accounts, and DAS obtained its 14 billion 21 won through processes in Switzerland, the jurisdiction that did have 22 actual control over the accounts. Optional does not explain how Rule 23 G(7)(a) allows a court to exercise control over property over which 24 that court lacks control. Optional also argues that the Court can 25 exercise control over the property as a function of its personal 26 jurisdiction over DAS. Optional has not explained how this theory can 27 be reconciled with DAS’s having obtained the assets by regular 28 12 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 13 of 15 Page ID #:460 1 procedures in Switzerland. Thus, although Optional’s reliance on Rule 2 G(7)(a) has some initial appeal, the Court cannot find that the Rule 3 authorizes the order Optional seeks. 4 Third, Optional argues that the Court can rely on its inherent 5 authority to make such an order. But this tenuous argument is an 6 amalgam of Optional’s contempt of court and Rule 7(G)(a) arguments, as 7 it rests on a determination that DAS abused the judicial process and 8 on the existence of this Court’s control over the accounts and the 9 assets they hold or held. As discussed above, the Court cannot find 10 contempt (abuse of judicial process), and does not have such control 11 over the assets. Indeed, the cases DAS relies upon all deal with 12 property in the United States and are simply not persuasive here, 13 where the accounts involved reside abroad and are not subject to the 14 Court’s control. 15 While a finding of contempt cannot be supported and while the 16 Court cannot compel DAS to surrender the funds, the events described 17 above and counsel’s explanations – occasionally quite technical, at 18 other times claiming ignorance – give the Court some pause as to 19 counsel’s judgment and credibility. Specifically, the Court views 20 with some scepticism counsel’s disclaiming any meaningful knowledge of 21 the settlement (see, e.g., Mills Decl., and Status Conf. 16:12-24:24 22 (the Court questioning Honig)), and counsel’s suggestion that the 23 removal of 14 billion won from the Credit Suisse accounts is of no 24 consequence to this Court’s in rem jurisdiction, a claim that 25 supposedly excuses counsel’s failure to affirmatively disclose the 26 fact of the settlement and the subsequent disbursement of funds. 27 (See, e.g., DAS’s Opp’n 14:12-15:10, and Status Conf. 15:4-21 (the 28 Court questioning Karaczynski)). 13 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 14 of 15 Page ID #:461 1 Technically, as counsel repeatedly insist, the Court’s 2 jurisdiction to decide the competing claims remains intact. But by so 3 diminishing the value of the res, the DAS-Kims conduct threatens to 4 render any such decision a merely academic exercise. It strains 5 credulity for the DAS-Kim parties and their counsel to suggest they 6 were oblivious to this consequence. Similarly, that the DAS-Kim 7 settlement contains a confidentiality clause is not an adequate 8 explanation for any counsel’s failure to disclose the existence of the 9 settlement. Obviously, telling the Court that a settlement was 10 reached is far different from disclosing the contents of the 11 settlement. The Court should not have had to ferret out information 12 so crucial to case management, especially because it was obvious that 13 DAS and the Kims would eventually have had to make the exact 14 disclosures they were withholding. See Status Conf. 20:20-23:14 (the 15 Court questioning Honig, who acknowledges the information would have 16 come out eventually). In short, although the conduct of counsel was 17 not contemptible, counsel should have acknowledged the common-sense 18 import of the various orders discussed herein. 19 Counsel also should have recognized, and the court believes they 20 did recognize, that this conduct – both their clients’ and their own – 21 would create intractable complications for this case and this Court. 22 Most attorneys practicing before this Court are forthright and assist 23 the Court in the objective we all strive for – the speedy and 24 efficient provision of justice. See, e.g., Fed. R. Civ. Proc. 1 25 (stating “[These rules] should be construed and administered to secure 26 the just, speedy, and inexpensive determination of every action and 27 proceeding.”). The conduct of counsel for DAS and the Kims, described 28 herein, was, regrettably, lacking such cooperation. 14 Case 2:05-cv-03910-ABC -PLA Document 168 Filed 06/17/11 Page 15 of 15 Page ID #:462 1 III. CONCLUSION 2 For the foregoing reasons, the Motions are DENIED. 3 4 IT IS SO ORDERED. 5 DATED: June 17, 20011 _______________________________ 6 AUDREY B. COLLINS UNITED STATES DISTRICT JUDGE 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15
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