Exhibit A. I, Jeffrey Ferris, being first duly sworn on oath, do hereby depose and say:

Transcription

1 Exhibit A AFFIDAVIT IN SUPPORT OF VERIFIED COMPLAINT FOR CIVIL FORFEITURE IN REM OF APPROXIMATELY $119, IN UNITED STATES CURRENCY FROM BANK OF AMERICA ACCOUNT ENDING IN 9049 I, Jeffrey Ferris, being first duly sworn on oath, do hereby depose and say: 1. I am a Special Agent with the United States Secret Service ( Secret Service ), and have been so employed since I am currently assigned to the Milwaukee Resident Office. My duties as a Special Agent with the Secret Service include investigating financial crimes such as identity fraud, check fraud, credit card fraud, bank fraud, wire fraud, currency-counterfeiting offenses, and money laundering. During my employment with the Secret Service, I have conducted several investigations that have resulted in seizures of criminally derived property, including monetary instruments. 2. As a Special Agent, I have conducted investigations into wire fraud, money laundering, and other complex financial crimes. In the course of those investigations, I have used various investigative techniques, including conducting and reviewing physical and electronic surveillance, conducting undercover operations, obtaining and reviewing financial records, and working with cooperating sources of information. In the course of those investigations, I have also become familiar with techniques that criminals use to conceal the nature, source, location, and ownership of proceeds of crime and to avoid detection by law enforcement of their underlying acts and money laundering activities. 3. All the information contained in this affidavit is based on my personal knowledge, including what I have learned through my training and experience as a law enforcement officer, my review of documents and other records obtained in the course of this investigation, and information I have obtained in the course of this investigation from witnesses having personal Case 2:15-cv DEJ Filed 12/14/15 Page 1 of 15 Document 1-1

2 knowledge of the events and circumstances described herein and from other law enforcement officers, all of whom I believe to be truthful and reliable. I have not included in this affidavit every fact I know about this investigation. 4. I submit this affidavit in support of a Verified Complaint for Civil Forfeiture in rem against the defendant property, approximately $119, in United States currency from Bank of America account ending in 9049 held in the name of HNV Shipping & Export, LLC, which was seized on or about August 20, Background 5. According to a March 2013 publication of the U.S. Federal Trade Commission, consumers lose hundreds of millions of dollars annually to cross-border financial crimes. Some of the most common cross-border financial schemes originate in West African nations such as Nigeria. Law enforcement agencies therefore sometimes refer to such schemes as West African fraud schemes. 6. Common West African fraud schemes include: business compromise scams ( BEC scam ), romance scams, work-from-home scams, and advance payment scams. 7. These scams work as follows: A. BEC scam a fraudster gains unauthorized access to, or spoofs the address of a victim and instructs the victim s financial institution to wire money to a bank account controlled by the fraudster or his associates. B. Romance scam a fraudster uses electronic messages, sent via or social media services, to delude the victim in the United States into believing the victim is in a romantic relationship with the person the fraudster purports to be and the fraudster then causes the victim to wire money to an account controlled by the fraudster on false pretenses. C. Work-from-home scam a fraudster deludes a victim into believing that the victim can work from home doing legitimate work and the fraudster causes the victim to open a domestic bank account that the fraudster uses 2 Case 2:15-cv DEJ Filed 12/14/15 Page 2 of 15 Document 1-1

3 to receive fraud proceeds and to then wire those proceeds to an account controlled by the fraudster. D. Advance-fee scam a victim is deceived into believing that he has won a lottery or is to receive an inheritance from a distant relative or some other type of payment. The fraudster tricks the victim into paying an advance fee to the fraudster on the false premise that the fraudster will then pay the lottery winnings, inheritance, or other promised monies to the victim. The fraudster then keeps the advance fee or fees paid by the victim and the victim gets nothing in return. 8. Foreign perpetrators of such scams sometimes recruit witting or unwitting persons within the United States to open bank accounts that the foreign perpetrators use to receive proceeds of the scam. The foreign perpetrators often target persons within the United States who lack education or common sense, or who are seeking companionship, to open such accounts at financial institutions within the United States. Sometimes those accounts are opened by a victim of a romance scam. Sometimes the accounts used to receive proceeds of a West African fraud scam are opened in the name of a fictitious business, such as a limited liability company, in order to conceal the fraudulent nature of the recipient bank account from victims and victims financial institutions. Facts Supporting a Verified Complaint July 23, 2015 attempt to wire $10,000 in proceeds of business compromise scam to the HNV Shipping & Export, LLC Bank of America account ending in During July 2015, unknown subjects tried to wire $10,000 in proceeds of a business compromise scam, perpetrated in part in this judicial district, into the HNV Shipping & Export, LLC Bank of America account ending in Specifically, on or about July 23, 2015, an unknown suspect or suspects hacked into an account, XXXXXX@aol.com, which belonged to the owner of Van Horn Auto Group ( VHAG ), whose initials are T.V., without T.V. s permission. 3 Case 2:15-cv DEJ Filed 12/14/15 Page 3 of 15 Document 1-1

4 11. VHAG s Corporate Headquarters is located in Plymouth, Wisconsin, within the Eastern District of Wisconsin. 12. Between July 23, 2015, and July 28, 2015, the suspects used T.V. s account, without permission, to messages to Bank First National and Chase Bank, where VHAG held bank accounts, to fraudulently instruct those banks to make the following wire payments: A. July 23, 2015 $10, From: VHAG Bank First National account ending in 0419 To: Bank of America account ending in 9049 held in the name of HNV Shipping & Export, LLC B. July 23, 2015 $5, From: VHAG Bank First National account ending in 0430 To: US Bank account ending in 8907 held in the name of an individual with initials K.S.C.H. C. July 23, 2015 $10, From: VHAG Bank First National account ending in 0430 To: First National Bank account ending in 1517 held in the name of an individual with initials J.K. D. July 24, 2015 $5, From: VHAG Chase Bank account ending in 0397 To: VYSTAR Credit Union account ending in 4016 held in the name of an individual with initials L.J. E. July 24, 2015 $15, From: VHAG Bank First National account ending in 0419 To: First National Bank account ending in 1517 held in the name of an individual with initials J.K. F. July 28, 2015 $100, From: VHAG Bank First National account ending in 2829 To: First National Bank account ending in 2196 held in the name of a business with the initials K.C. 13. As noted in the summary above, one of the fraudulent messages sent from T.V. s XXXXXX@aol.com account on July 23, 2015, instructed Bank First National to wire 4 Case 2:15-cv DEJ Filed 12/14/15 Page 4 of 15 Document 1-1

5 $10,000 from VHAG s Bank First National account ending in 0419 to the account at issue in this Complaint, the HNV Shipping & Export, LLC Bank of America account ending in Based on that message, on July 23, 2015, Bank First National wired $10,000 from VHAG s Bank First National account ending in 0419 to the HNV Shipping & Export, LLC Bank of America account ending in On July 28, 2015, after this suspected BEC scam was reported to the Secret Service, the Secret Service s Milwaukee Financial Crimes Task Force and VHAG worked with Bank First National, First National Bank, Bank of America, Chase Bank, and US Bank to try to rescind the wire transfers identified above. 16. As a result of those efforts, Bank of America successfully rescinded the attempted wire transfer of the $10,000 from the VHAG Bank First National account to the HNV Shipping & Export, LLC Bank of America account ending in Bank First National, US Bank, Chase Bank, VYSTAR Credit Union, and First National Bank also successfully rescinded three other fraudulent wire transfers from VHAG accounts and thereby prevented VHAG from losses with respect to those fraudulent attempted wire transfers. 17. But VHAG did suffer losses totaling $25,000 from the two fraudulent transfers to the First National Bank account ending in 1517 held in the name of J.K. The $25,000 loss by VHAG is not at issue in this civil forfeiture case, but information obtained by Secret Service shows the following: A. According to First National Bank Compliance Officer B.C., at the time the fraudulent transfers were discovered, the account holders of the First National Bank account ending in 1517, had already withdrawn the majority of the two wire payments of $10,000 and $15,000 made by VHAG on July 23 and 24, 2015, respectively. 5 Case 2:15-cv DEJ Filed 12/14/15 Page 5 of 15 Document 1-1

6 B. On July 28, 2015, the local branch manager of First National Bank contacted the account holder, J.K., and asked for return of the funds, but J.K. never returned the funds. C. Between July 23, 2015, and July 31, 2015, the account holders of First National Bank account ending in 1517 had sent $7,100 via Western Union to persons in Nigeria, including $3,500 after J.K. had been notified of the fraudulent transfers and had been asked to return the money. HNV Shipping & Export, LLC s registration to Smart Chika Osuagwu and lack of any internet presence 18. The Secret Service s Milwaukee Financial Crimes Task Force obtained and reviewed records from VHAG, First National Bank, Bank of America, the TLO law enforcement database, the State of New Jersey, and open internet searches. 19. According to information received from the State of New Jersey, Division of Revenue and Enterprise Services, HNV Shipping and Export, LLC was registered in New Jersey on March 18, According to the TLO law enforcement database search, HNV Shipping and Export, LLC is registered to Smart Chika Osuagwu. 21. Internet inquiries of Smart Chika Osuagwu resulted in listings of numerous persons, several of whom were identified as being from Nigeria or of Nigerian descent. 22. Internet inquiries of HNV Shipping and Export did not reveal any company website or yield any reference to actual business being conducted online by HNV Shipping and Export. 23. Information obtained from U.S. Commerce Special Agent Deanna Orobey showed that HNV Shipping and Export, LLC exported 32 used vehicles, predominantly 2001 to 2005 Toyota Sienna vans, from the United States to Nigeria. The first vehicle was exported on June 25, 2013, and the last vehicle was exported on December 1, Case 2:15-cv DEJ Filed 12/14/15 Page 6 of 15 Document 1-1

7 24. Despite U.S. Commerce records showing that HNV Shipping and Export, LLC has not exported a vehicle from the United States since December 1, 2014, a total of over $180,000 has been deposited into the HNV Shipping & Export, LLC Bank of America account ending in 9049 since December 1, Deposit of $119, in suspected fraud proceeds, during July and August 2015, into the HNV Shipping & Export, LLC Bank of America account ending in Detectives analyzed financial records obtained from Bank of America on August 11, 2015, regarding the HNV Shipping & Export, LLC Bank of America account ending in 9049 ( BOA 9049 ). 26. According to those records, on September 15, 2014, Smart Chika Osuagwu opened BOA 9049 in the name of HNV Shipping & Export, LLC and listed himself as the authorized signer. Therefore, BOA 9049 was opened just two and one-half months before the last recorded vehicle was exported by HNV Shipping & Export, LLC, on December 1, On June 26, 2015, BOA 9049 had a balance of $6, Between June 26, 2015, and August 7, 2015, the following eight deposits totaling $176, and consisting variously of cash deposits, wire deposits, and a cashier s check deposit were made into BOA 9049: Date Amount Deposit Type Business/Person Location 06/26/15 $10,000 Cash Unknown Staples, TX 07/13/15 $30,000 Cash Sandra Stolz Des Moines, IA 07/14/15 $35,000 Cashier s check Unknown Haverhill, MA 07/31/15 $11,500 Cash Jeanete Tingley Modesto, CA 08/03/15 $54, Wire Assa Properties New York, NY 08/03/15 $23,000 Cash M.J. Bolingbrook, IL 08/03/15 $ 5,000 Cash Unknown Clarkston, MI 08/07/15 $ 7,000 Wire R.H. Houston, TX 29. Between July 27 and August 7, 2015, a total of $62, was withdrawn from BOA Specifically, on July 27, 2015, $59, was wire transferred internationally to 7 Case 2:15-cv DEJ Filed 12/14/15 Page 7 of 15 Document 1-1

8 Wenzhou Jumelage Sticken Paper Co. Bank of China account ending in Between June 26, 2015, and August 7, 2015, nine other withdrawals, totaling $2,778.93, were made. Some of the withdrawals funded transfers to Smart Chika Osuagwu s savings account. 30. For the reasons set forth below, I submit that at least four of the eight deposits into BOA 9049 which are bolded in the above chart, and which deposits were made between July 13, 2015, and August 3, 2015, and which totaled $119, consisted of fraud proceeds. July 13, 2015 deposit by Sandra Stolz of $30,000 in proceeds of romance-inheritance fraud scam into HNV Shipping & Export, LLC Bank of America account ending in On August 11, 2015, I interviewed Sandra Stolz. Ms. Stolz told me the following: A. In approximately January 2015, Ms. Stolz had met Blake Timothy on a dating website, Based on Blake Timothy s posted profile on that website and correspondence, Ms. Stolz believed that Blake Timothy was a 65-year-old Caucasian male from Michigan who traveled to Arizona. B. After making contact through that website with the person she thought to be Blake Timothy, Ms. Stolz corresponded with Blake Timothy via and text messaging for several months. C. Ms. Stolz eventually considered herself to be in a committed relationship with Blake Timothy. D. After reaching that point in their supposed relationship, Blake Timothy told Ms. Stolz that he worked in West Africa and that he was about to inherit $2 million in U.S. currency. Blake Timothy also told Ms. Stolz that he wanted to spend the rest of his life with Ms. Stolz and share his inheritance with Ms. Stolz. E. Blake Timothy then asked Ms. Stolz to provide him with financing to secure the inheritance. If Ms. Stolz did this, Blake Timothy told Ms. Stolz that he would immediately be able to travel to Des Moines, Iowa, to live with Ms. Stolz. F. On July 13, 2015, Ms. Stolz withdrew $34,700 cash from Ms. Stolz s Bank of West account. G. On July 13, 2015, at the direction of Blake Timothy, Ms. Stolz deposited $30,000 into the HNV Shipping & Export, LLC Bank of 8 Case 2:15-cv DEJ Filed 12/14/15 Page 8 of 15 Document 1-1

9 America account ending in Ms. Stolz sent an additional approximately $3,000 in cash via Western Union to someone in Nigeria, but Ms. Stolz could not recall that person s name. H. However, Blake Timothy failed to arrive in Des Moines, Iowa, as promised. When Ms. Stolz confronted Blake Timothy, he told Ms. Stolz to send an additional $15,000 in order to pay taxes associated with the inheritance. I. Ms. Stolz concluded that she had been the victim of a romance-inheritance fraud scam. 32. Sandra Stolz never met Blake Timothy in person, never spoke with Blake Timothy on the phone, and never conversed with Blake Timothy via video teleconference. 33. Based on the information contained in this affidavit, I submit that the July 13, 2015 deposit of $30,000 into HNV Shipping & Export, LLC Bank of America account ending in 9049 consisted of proceeds of a romance-inheritance fraud scam that an unknown suspect, possibly Smart Chika Osuagwu or someone associated with him, perpetrated against Sandra Stolz. July 31, 2015 deposit by Jeanette Tingley of $11,500 in proceeds of romance-bail fraud scam into HNV Shipping & Export, LLC Bank of America account ending in 9049 following: 34. On August 11, 2015, I interviewed Jeanette Tingley. Ms. Tingley told me the A. On May 4, 2015, Ms. Tingley had met through the online dating service an individual Ms. Tingley believed to be Paul Bane, a 55-year-old Caucasian male who lived in New York, but was originally from Scotland. Paul Bane shared with Ms. Tingley copies of business licenses, oil contracts, and OPEC paperwork indicating that he was a worldwide oil tycoon. B. After Ms. Tingley considered herself to be in a committed relationship with Paul Bane, Paul Bane requested that Ms. Tingley wire money and make cash deposits into accounts designated by Paul Bane. C. Paul Bane told Ms. Tingley to send him money for various reasons, including for certain oil contracts. 9 Case 2:15-cv DEJ Filed 12/14/15 Page 9 of 15 Document 1-1

10 D. Paul Bane also requested funds from Ms. Tingley after he had ostensibly been detained by a Chief Ward Officer at the Atlanta, Georgia airport for possession of his Scotland-issued prescription drugs. Paul Bane told Ms. Tingley that in order be released from custody by the Chief Ward Officer, Ms. Tingley needed to make a cash deposit into certain accounts. E. Accordingly, on July 16, 2015, at the direction of Paul Bane, Ms. Tingley deposited $16,000 into a Sustainable Health Services LLC Bank of America account ending in F. After the $16,000 deposit did not secure Paul Bane s release from his purported custody, Paul Bane asked Ms. Tingley to make another deposit. G. On July 31, 2015, at the direction of Paul Bane, Ms. Tingley deposited $11,500 into the HNV Shipping & Export, LLC Bank of America account ending in H. Paul Bane then told Ms. Tingley that this second deposit had likewise failed to secure his release from his purported custody. I. Days later, a David Hall contacted Ms. Tingley. David Hall informed Ms. Tingley that he was a diplomat from China who would be able to secure Paul Bane s release from custody. David Hall directed Ms. Tingley to create a mutual bank account with Ping Liam Bank in China, which Ms. Tingley then did. Ms. Tingley had login access to the Ping Liam Bank account, could verify the balance, but had no control over the account. J. David Hall told Ms. Tingley that if Ms. Tingley deposited another $15,000 into the Ping Liam Bank account on August 14, 2015, David Hall would be able to come to California to assist in Paul Bane s release. But David Hall advised Ms. Tingley that David Hall would not buy an airline ticket until the money was deposited. K. Ms. Tingley made 8 to 10 deposits, totaling approximately $500,000, at the direction of Paul Bane and David Hall. L. Ms. Tingley concluded that she had been the victim of a romance-bail fraud scam. 35. Ms. Tingley merely corresponded, via and telephone communications, with the person or persons who represented themselves to be Paul Bane and David Hall. 10 Case 2:15-cv DEJ Filed 12/14/15 Page 10 of 15 Document 1-1

11 Ms. Tingley never personally met or had a videoconference with either Paul Bane or David Hall. 36. An internet search of Ping Liam Bank revealed little information or news stories about the supposed bank. Based on my training and experience, I believe that the website for Ping Liam Bank, appears to be a fake website because it lacks the features of other financial institutions, including financial institutions in China. 37. Based on the information contained in this affidavit, I submit that the July 31, 2015 deposit of $11,500 into HNV Shipping & Export, LLC Bank of America account ending in 9049 consisted of proceeds of a romance-bail fraud scam that an unknown suspect, possibly Smart Chika Osuagwu or someone associated with him, perpetrated against Jeanette Tingley. August 3, 2015 deposit by Assa Properties, Inc. of $54, in proceeds of business compromise scam into HNV Shipping & Export, LLC Bank of America account ending in On August 11, 2015, detectives reviewed records from IC3.gov, an online portal and database administered by the United States government on which victims and third parties can report online internet crimes. 39. According to the records obtained from IC3.gov, an employee with the initials I.A. of Assa Properties, Inc. ( Assa Properties ) located in New York, New York, reported a BEC scam that had defrauded their client. I.A. reported that HNV Shipping & Export, LLC was the business that victimized Assa Properties, and I.A. provided the following description of the incident: Someone hacked our client s and spoofed his name. Our company sends wire transfers on monthly basis to this client. On 7/31/2015 the hacker requested to change the payment account folio. We did it thinking that our client requested the change. On 8/3/2015 we sent a wire transfer of 54, and a day later our client notified us that he did not receive the wire transfer that s when we [realized] we were scammed. 11 Case 2:15-cv DEJ Filed 12/14/15 Page 11 of 15 Document 1-1

12 40. Assa Properties is the parent company of PR LLC. During the normal course of business, Assa Properties sent monthly payments on behalf of PR LLC to a client ( Client ) via wire transfers to four particular parties. 41. On or about July 31, 2015, PR LLC received an believed to be from Client directing a change to Client s beneficiary and the account number to which the monthly payments were to be wired. The stated that payment should be made in one wire transfer to HNV Shipping & Export, LLC s Bank of America account ending in 9049, rather than the typical wire transfers to the usual four parties. 42. On or about August 3, 2015, Assa Properties wired the entire $54, payment to what it believed to be the Client at HNV Shipping & Export, LLC s Bank of America account ending in On or about August 4, 2015, the actual Client called PR LLC stating that Client had not received the $54, payment. Following an investigation, PR LLC discovered that someone had hacked or spoofed Client s account. 44. Assa Properties attempted to recall the wire transfer, but the bank could not reverse the transaction. 45. Based on the information contained in this affidavit, I submit that the August 3, 2015 deposit of $54, into HNV Shipping & Export, LLC Bank of America account ending in 9049 consisted of proceeds of a business compromise scam that an unknown suspect, possibly Smart Chika Osuagwu or someone associated with him, perpetrated against Assa Properties, Inc., the parent company of PR LLC. 12 Case 2:15-cv DEJ Filed 12/14/15 Page 12 of 15 Document 1-1

13 August 3, 2015 deposit by M.J. of $23,000 in proceeds of romance fraud scam into HNV Shipping & Export, LLC Bank of America account ending in On August 11, 2015, I interviewed a female individual with the initials M.J. M.J. told me the following: A. Several months earlier, M.J. had met a person, who purportedly had the initials D.T., on a dating website, M.J. believed D.T. to be a 65-year-old Caucasian male with a German accent, who resided in San Francisco, California, and worked for SunRun Solar Company. B. After M.J. considered herself to be in a committed relationship with D.T., D.T. told M.J. that D.T. wanted to designate M.J. as a beneficiary on D.T. s retirement plan. In order for this to occur, D.T. asked M.J. to invest in SunRun Solar Company. C. M.J. was suspicious of the request, so M.J. asked for D.T. s personal identifiers, including D.T. s Social Security number, date of birth, and a picture of D.T. s passport, which showed an expiration date in D.T. provided this information to M.J. and thereby convinced M.J. that D.T. was who he purported to be. D. On or about July 15, 2015, D.T. instructed M.J. to deposit $7,000 in cash into Mosco Shipping LLC Wells Fargo Bank account ending in M.J. then did so. E. A few weeks later, D.T. asked M.J. to deposit more money into an account to solidify being a beneficiary on D.T. s retirement account. F. On August 3, 2015, D.T. instructed M.J. to deposit $23,000 in cash into HNV Shipping & Export, LLC Bank of America account ending in M.J. then did so. G. After D.T. failed multiple times to visit M.J. as promised, M.J. concluded that she had been the victim of a romance fraud scam. 47. M.J. corresponded with D.T. via and text messaging but never met D.T. in person and never conversed with D.T. via video teleconference. 48. M.J. had a hunch that something was wrong, but ultimately was deceived after D.T. provided what seemed to be legitimate information and documentation. 13 Case 2:15-cv DEJ Filed 12/14/15 Page 13 of 15 Document 1-1

14 49. On August 11, 2015, I interviewed the individual who is the true D.T. D.T. told me the following: A. D.T. resides in Texas and never lived in San Francisco, California. B. D.T. does not work for SunRun Solar Company. C. D.T. s passport had been expired for a long time. D. D.T. does not know M.J. and had never met or spoken with M.J. E. D.T. was not aware that he been a victim of identity theft. 50. Based on the information contained in this affidavit, I submit that the August 3, 2015 deposit of $23,000 into HNV Shipping & Export, LLC Bank of America account ending in 9049 consisted of proceeds of a romance fraud scam that an unknown suspect, possibly Smart Chika Osuagwu or someone associated with him, perpetrated against M.J. August 20, 2015 Seizure Warrant for Funds on Deposit in HNV Shipping & Export, LLC Bank of America account ending in On August 20, 2015, in the Eastern District of Wisconsin, United States Magistrate Judge David E. Jones issued seizure warrant #15-M-014 for up to $119, in funds on deposit in BOA On or about August 20, 2015, the seizure warrant was executed at Bank of America, and a total of approximately $119, in funds was seized from BOA Petitions and Claim Submitted in the Administrative Forfeiture Action 53. On or about August 24, 2015, the Secret Service commenced an administrative forfeiture action against the defendant property, approximately $119, in United States currency from Bank of America account ending in On or about October 8, 2015, Sandra Stolz filed a victim petition for remission or mitigation of forfeiture as to the defendant property. 14 Case 2:15-cv DEJ Filed 12/14/15 Page 14 of 15 Document 1-1

15 55. On or about October 20, 2015, Jeanette Tingley and PR, LLC separately filed victim petitions for remission or mitigation of forfeiture as to the defendant property. 56. On or about October 21, 2015, Smart Osuagwu, individually and on behalf of his company, HNV Shipping & Export, LLC, filed a claim to the defendant property. Conclusion 57. Based on my training and experience, and the evidence I have received, and the information I have obtained in the course of this investigation to date, I submit that the defendant property, approximately $119, in United States currency from Bank of America account ending in 9049, constitutes or was derived from proceeds traceable to specified unlawful activity, namely, wire fraud, committed in violation of Title 18, United States Code, Section 1343, and is therefore subject to forfeiture to the United States of America pursuant to Title 18, United States Code, Sections 981(a)(1)(C) and 984, with cross-references to Title 18, United States Code, Sections 1956(c)(7) and 1961(1). Subscribed and sworn to before me this 14 th day of December, s/jeffrey FERRIS Jeffrey Ferris s/cathy L. TRAUTMAN Notary Public, State of Wisconsin My commission: expires 08/30/ Case 2:15-cv DEJ Filed 12/14/15 Page 15 of 15 Document 1-1