Case 8:20-cv-01989-MWF-DFM Document 1 Filed 10/15/20 Page 1 of 18 Page ID #:1

1 NICOLA T. HANNA
United States Attorney
2 BRANDON D. FOX
Assistant United States Attorney
3 Chief, Criminal Division
STEVEN R. WELK
4 Assistant United States Attorney
Chief, Asset Forfeiture Section
5 VICTOR A. RODGERS
California Bar No. 101281
6 Assistant United States Attorney
Asset Forfeiture Section
7 Federal Courthouse, 14th Floor
312 North Spring Street
8 Los Angeles, California 90012
Telephone: (213) 894-2569
9 Facsimile: (213) 894-0142
E-mail: Victor.Rodgers@usdoj.gov
10
Attorneys for Plaintiff
11 UNITED STATES OF AMERICA
12 UNITED STATES DISTRICT COURT
13 FOR THE CENTRAL DISTRICT OF CALIFORNIA
14 SOUTHERN DIVISION
15 UNITED STATES OF AMERICA, ) Case No. 8:20-CV-01989
)
16 Plaintiff, ) COMPLAINT FOR FORFEITURE
)
17 v. ) 18 U.S.C. §§ 981(a)(1)(A) and (C)
) and 984
18 $176,548.00 IN U.S. )
CURRENCY, ) [FBI]
19 )
Defendant. )
20 )
21
Plaintiff United States of America brings this claim
22
against defendant $176,548.00 In U.S. Currency (the “defendant
23
currency”), and alleges as follows:
24
JURISDICTION AND VENUE
25
1. The government brings this in rem forfeiture action
26
pursuant to 18 U.S.C. §§ 981(a)(1)(A) and (C) and 984.
27
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1 2. This Court has jurisdiction over the matter under 28

2 U.S.C. §§ 1345 and 1355.
3 3. Venue lies in this district pursuant to 28 U.S.C.
4 § 1395.
5 PERSONS AND ENTITIES
6 4. The plaintiff in this action is the United States of
7 America.
8 5. The defendant in this action is $176,548.00 In U.S.
9 Currency (the "defendant currencyn) seized on or about July 26,
10 2019, during the execution of a federal search warrant at Tarek
11 Greiss' Costa Mesa, California residence.
12 6. The defendant currency is currently in the custody of
13 the United States Marshals Service in this District, where it
14 will remain subject to this Court's jurisdiction during the
15 pendency of this action.
16 7. The interests of Greiss may be adversely affected by
17 these proceedings.
18 BASIS FOR FORFEITURE
19 Background Of The Investigation
20 8. The Federal Bureau of Investigation has conducted an
21 investigation into the activities of Greiss in connection with
22 Greiss' operations of South Coast Counseling, Inc. and Elite
23 Care, Inc., which are substance abuse treatment facilities
24 located in Costa Mesa, California. As a result of the
25 investigation, law enforcement officers determined that Greiss
26 was paying kickbacks and bribes in exchange for the referral of
27 patients to these facilities, and was also receiving kickbacks
28 and bribes for referring patients to clinical laboratories for

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1 the performance of laboratory tests. The investigation has led

2 to the September 16, 2020 filing of an indictment against Greiss
3 in the Central District of California. See United States v.
4 Tarek Greiss, Case No. 8:20-cr-00131-MWF.
5 Overview Of Substance Abuse Treatment Facility Fraud
6 9. Substance abuse treatment facilities provide services
7 to patients seeking treatment for drug and alcohol addiction.
8 As to those patients admitted to substance abuse treatment
9 facilities who have insurance, the facilities will submit claims
10 to insurance companies requesting payment for the services the
11 facilities have performed. If the insurance companies accept
12 the claim, the insurance companies will pay substance abuse
13 treatment facilities for that portion of the claim covered by
14 insurance. The amount of the claim that is covered and for
15 which payment is made depends upon a variety of factors,
16 including the type of service the substance abuse treatment
17 facility provides to the patient, the addiction for which the
18 patient is treated, and the length of time the patient remains
19 at the facility.
20 10. In ldght of the potential lucrative revenues derived
21 from treating patients covered by insurance, some substance
22 abuse treatment facilities engage in fraud schemes designed to
23 illegally capture these revenues. One scheme involves substance
24 abuse treatment facilities operators paying kickbacks and
25 engaging in patient brokering to do so, which involves using
26 patient recruiters (also referred to as patient brokers and
27 patient marketers). The practice of patient brokering consists
28 of utilizing patient brokers, in exchange for payment of illegal

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1 kickbacks and bribes to the patient brokers, to locate, recruit

2 and ultimately refer patients to substance abuse treatment
3 facilities for treatment.
4 11. The benefits received by substance abuse treatment
5 facilities as a result of rendering services to patients
6 referred via kickbacks and bribes can be substantial. For
7 example, a single patient enrolled in a substance abuse
8 treatment facility for opiate addiction can result in a
9 substance abuse treatment facility receiving insurance payments
10 of more than $3,000.00 per day and $90,000.00 in total depending
11 upon the length of the patient's stay. By contrast, legitimate
12 substance abuse treatment facilities, which refuse to pay
13 patient brokers for referring patients, are often forced to
14 discontinue operations due to a lack of patients.
15 12. As part of their recruitment pitch, patient brokers
16 receiving kickbacks recruit patients by, among other things,
17 making promises to pay potential patients sums ranging between a
18 few hundred to a few thousand dollars, with the ultimate payment
19 amount depending upon the patient's projected length of stay and
20 the anticipated value of the patient's insurance benefits. With
21 respect to the value of the patient's insurance benefits,
22 insurance companies pay substance abuse treatment facilities the
23 highest amounts for patients that receive treatment for Detox.
24 Treatment for Detox consists of providing specialized medical
25 care to patients whose dependence on drugs is so severe that the
26 abrupt discontinuation of or decrease in those patients' drug
I

27 use could lead to dangerous withdrawal symptoms.

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1 13. Typically, patients must test positive for drug use

2 before insurance companies will pay substance abuse treatment
3 facilities for Detox treatment. In light of this fact, patient
4 brokers will give prospective patents drugs in order to make
5 sure that the patient tests positive for drugs and thereby
6 becomes eligible for Detox treatment at the substance abuse
7 treatment facility.
8 14. Substance abuse treatment facilities and patient
9 brokers know that it is illegal to pay patient brokers on a per-
10 patient basis for each patient the broker refers to a facility.
11 Indeed, substance abuse treatment facility operators often
12 overhear patients talking about receiving money from patient
13 brokers, or discover that patient brokers have provided drugs to
14 potential patients in order to ensure they test positive for
15 drugs and are admitted to the substance abuse treatment facility
16 for treatment.
17 15. In an attempt to conceal the kickback, per-patient
18 fraud scheme and the reason for the unlawful payments, substance
19 abuse treatment facilities and patient brokers use various
20 devices to hide their activity. For example, substance abuse
21 treatment facilities will pay the kickbacks in cash to avoid
22 leaving a paper trail that might unearth the details of the
23 kickback transactions. In addition, substance abuse treatment
24 facilities and patient brokers will enter into sham contracts
25 and create phony invoices that falsely state that the patient
26 broker is providing hourly counseling, consulting or other
27 services to the substance abuse treatment facility, when in fact
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1 the only service the patient broker provides is recruiting and

2 referring patients to the facility.

3 16. Moreover, substance abuse treatment facilities and

4 patient brokers enter into service contracts that require the

5 facilities to pay the broker a monthly flat-fee, but those

6 service contracts conceal the parties' verbal agreement that

7 sets a quota for the number of patients that the patient broker
8 must refer over a particular length of time (e.g., each month)

9 to the substance abuse treatment facility. Furthermore,

10 substance abuse treatment facilities that unlawfully pay patient

11 brokers kickbacks based on the number of patients the patient

12 brokers recruit will often maintain handwritten ledgers, secret

13 lists or other documents that set forth the names of patient

14 brokers and the amount of payments made to them for the patient
15 referrals.
16 17. In addition to the above-referenced illegal revenues,
17 substance abuse treatment facilities derive unlawful revenues by
18 referring patients to clinical laboratories for the performance
19 of lab tests, including urine tests designed to detect whether a
20 patient is using drugs. While substance abuse treatment
21 facilities operating legally can purchase a screening kit
22 cheaply (e.g., for less than $10.00) that tests urine samples
23 and will immediately show whether drugs are in a patient's
24 system, substance abuse treatment facilities engaged in
25 referring patients to clinical laboratories, in exchange for
26 kickbacks, will receive a portion of the several thousands of
27 dollars paid by insurance companies to the clinical laboratories
28 that perform expensive "confirmation" drug tests.

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1 Greiss And His Companies

2 18. Filings with the California Secretary of State reflect
3 most of the following. Greiss is the Chief Executive Officer,
4 Executive Director, operator and an owner of South Coast
5 Counseling, Inc., which is a substance abuse treatment facility
6 located in Costa Mesa, California. In addition, Greiss is the
7 Chief Executive Officer, Chief Financial Officer, a director,
8 operator and an owner of Elite Care, Inc., which is also a
9 substance abuse treatment facility located in Costa Mesa,
10 California. Also, Greiss is a member or manager of Healthcare
11 Consultants of Orange County, LLC, which is a limited liability
12 corporation that shares the same address as Greiss' residence.
13 19. As part of operating South Coast Counseling, Inc. and
14 Elite Care, Inc., Greiss was involved in marketing efforts to
15 obtain patients for the substance abuse treatment facilities,
16 negotiating and presenting claims to insuran9e companies for
17 services performed by the facilities and, as more fully
18 described below, paying kickbacks to patient brokers in exchange
19 for patient referrals, and receiving kickbacks from clinical
20 laboratories in exchange for referring facility patients to
21 those laboratories for the laboratories to perform urine and
22 other tests.
23 Patient Given Drugs By Patient Recruiter Prior To Patient's
Admission Into South Coast Counseling, Inc.'s Detox Program
24
20. In January 2017, an individual ("Patient 1") reported
25
the following to the Costa Mesa Police Department. Patient 1
26
had been in South Coast Counseling, Inc.'s drug rehabilitation
27
program in 2016 and had returned in January 2017. Patient 1 had
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1 been picked up by an individual ("Recruiter 1 11

) at Los Angeles
2 International Airport on January 3, 2017 and then transported to
3 the Lake Forrest office of a female insurance person ("Recruiter
4 2 11 ), who told Patient 1 that in order to be admitted to the
5 South Coast Counseling, Inc. program, Patient 1 had to undergo
6 Detox for a few days.
7 21. After completing paperwork with Recruiter 2, Recruiter
8 1 drove Patient 1 to a park in Santa Ana, California, told
9 Patient 1 that Patient 1 needed to be under the influence of
10 drugs in order to be admitted to the South Coast Counseling,
11 Inc. Detox Center, gave Patient 1 Xanax and injected Patient 1
12 in the neck with methamphetamine. Recruiter 1 also told Patient
13 1 that Recruiter 1 had done the same thing to other individuals
14 on different occasions in order for those individuals to be
15 admitted into the program. A South Coast Counseling, Inc.
16 employee came to the park, picked Patient 1 up, took Patient 1
17 to the South Coast Counseling, Inc. Detox Center, and Patient 1
18 remained in the Center for seven days before being transferred
19 to South Coast Counseling, Inc.'s rehabilitation center.
20 Greiss Admits Paying Patient Brokers/Marketers For Patient
Referrals And Instructing Patient Brokers/Marketers Not To
21 Submit Invoices For Those Payments Because Written Invoices
Would Create A Paper Trail Of Those Payments
22
22. In October 2018, a law enforcement confidential source
23
("CHS 11
) was tasked by law enforcement officers to conduct
24
recorded conversations with Greiss, and in doing so the CHS
25
posed as an individual who had owned and operated substance
26
abuse treatment facilities and was interested in purchasing
27
additional facilities. During the recorded conversations, as
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1 set forth in more detail below, Greiss stated that he paid

2 patient brokers on a per-patient basis for patients the patient
3 brokers referred to Greiss' substance abuse treatment

4 facilities.
5 23. During an October 24, 2018 telephone conversation,

6 Greiss told CHS that (i) Greiss purchased patients from patient
7 brokers; (ii) Greiss kept track of patient referral payments,
8 which referral patients accounted for fifty percent of Greiss'

9 facilities' admissions, on a secret spreadsheet; and

10 (iii) Greiss used one patient marketer who was "super ethical"
11 but could only deliver one or two patients a month, so Greiss
12 paid other patient marketers per patient $500.00 or more per day
13 (and up to a total of $9,000.00) for each day the patient stayed

14 at Greiss' treatment facility.

15 24. Greiss met with the CHS on November 6, 2018, and

16 during the meeting Greiss (i) showed CHS the secret spreadsheet
17 on Gre1ss' laptop computer and explained that the spreadsheet
18 reflected, among other things, the monies South Coast
19 Counseling, Inc. paid (at Greiss' direction) to patient
20 marketers for particular patients; (ii) stated that Greiss paid
21 patient marketers $500.00 per day for each patient entering
22 Greiss' facility for Detox treatment and a lesser amount for
23 each patient ent~ring the facility for other treatments ( ~ ,
24 at 75% or 50% for residential or outpatient care); and
25 (iii) stated that his partners in the substance abuse treatment
26 facilities were "skittish" about Greiss' activities but Greiss
27 nevertheless "ha[d] to keep the beds full," and further stated
28 that "you can't bargain" with the patient marketers on the price

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 Case 8:20-cv-01989-MWF-DFM Document 1 Filed 10/15/20 Page 10 of 18 Page ID #:10

1 Greiss paid to them for patients because "this is the one area
2 where we gotta put the money if you want to get the clients
3 in [ . ] "
4 25. Legitimate businesses generally maintain invoices for
5 payments those businesses make to third parties so that the
6 businesses can, among other things, have documents reflecting
7 those payments available if the businesses are audited.
8 However, during the November 6, 2018 meeting, Greiss stated that
9 he "wouldn't accept invoices" from patient marketers, and that
10 the patient marketer transactions were handled orally with "just
11 a phone call" so that "there's no paper trail" that would allow
12 third parties (such as law enforcement) to obtain documents
13 reflecting Greiss' payments to patient marketers for patients.
14 26. As noted above, legitimate substance abuse treatment
15 facilities, which refuse to pay patient brokers for referring
16 patients, are often forced to discontinue operations due to a
17 lack of patients, and during the October 24, 2018 telephone
18 conversation, Greiss told CHS that referral patients admitted as
19 a result of the kickback payments accounted for fifty percent of
20 Greiss' facilities' admissions. Accordingly, absent and but for
21 the kickback scheme, Greiss' substance abuse treatment
22 facilities could not have continued to conduct their business
23 operations and generated the defendant currency or any other
24 monies as a result of those operations.

25 / / /
26 I I I
27 / / /
28 I I I
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 Case 8:20-cv-01989-MWF-DFM Document 1 Filed 10/15/20 Page 11 of 18 Page ID #:11

1 Greiss Admits Receiving Laboratory Referral Kickback Fees And

Paying His Partners Their Share Of Those Kickbacks In Cash
2 Because One Partner Was Concerned About The Legality Of The
Laboratory Payments
3
27. As reflected above, substance abuse treatment
4
facilities also derive illegal income by receiving kickbacks
5
from clinical laboratories ,for the substance abuse treatment
6
facilities' referral of urine and other lab tests designed to
7
determine whether a facility patient has drugs in the patient's
8
system. The kickback can take the form of the substance abuse
9
treatment facility receiving a percentage of the insurance
10
payments paid by the insurance company to the laboratory.
11
28. During a November 14, 2018 meeting with the CHS,
12
Greiss made statements concerning his receipt of kickback
13
payments from laboratories, concealing those payments by having
14
them wired from the laboratories to Greiss' LLC, and withdrawing
15
those funds so that he could pay a portion of those kickback
16
payments in cash to Greiss' partners. Greiss stated during the
17
meeting that (i) Greiss received payments from laboratories
18
(which payments were typically wired); (ii) Greiss would receive
19
payments in amounts that constituted a percentage of the
20
insurance billings for the laboratory tests; (iii) Greiss
21
received between $35,000.00 and $50,000.00 per month in one year
22
from laboratories; and (iv) Greiss did not have the laboratories
23
pay him directly but instead had the laboratories pay the monies
24
to Greiss' LLC Healthcare Consultants of Orange County, LLC (and
25
whose address was the same as Griess' residence address).
26
29. In addition, Greiss also stated during the November
27
14, 2018 meeting that (i) Greiss would t.ake the payments from
28

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1 the laboratories, determine what amount of each payment was

2 owned to Greiss' partners and then pay his partners in cash in
3 one hundred dollar bills for their share; and (ii) Greiss would
4 pay his partners in cash because one of his partners did not
5 want to have payments made directly to that partner because the
6 partner feared that he would lose his medical license if
7 authorities discovered that the partner had received monies from
8 the laboratories and cash payments would permit the partner to
9 claim deniability regarding the source of the cash.
10 Sham Contracts To Conceal Kickback Scheme
11 30. As mentioned above, substance abuse treatment
12 facilities and patient brokers enter into sham contracts that
13 require the substance abuse treatment facility to make monthly
14 payments to the patient marketer, ostensibly for items such as
15 hourly counseling, consulting or other services performed by the
16 patient marketer, when in fact the payments are being made for
17 the referral of patients and obligate the patient marketer to
18 refer a certain number of patients (i.e., a quota) to the
19 substance abuse treatment facility over a particular period.
20 Greiss entered into a sham contract of this type, as explained
21 further below.
22 31. Greiss, on behalf of South Coast Counseling, Inc., in
23 or around November or December 2018 entered into a Marketing
24 Services Agreement with SeKe, Inc., which contract provided that
25 it had an effective date of October 1, 2018, required monthly
26 payments of $30,000.00 from South Coast Counseling, Inc. to
27 SeKe, Inc., and included a false provision that prohibited these
28 payments from being based on the volume or value of any patient

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 Case 8:20-cv-01989-MWF-DFM Document 1 Filed 10/15/20 Page 13 of 18 Page ID #:13

1 referrals provided by SeKe, Inc. On or about January 2, January

2 15, February 1, February 15, March 1 and March 15, 2019, Greiss
3 transferred approximately $15,000.00 (for a total of $120,000)
4 in kickback payments from a South Coast Counseling, Inc. account
5 to SeKe, Inc. to induce referrals of patients to South Coast
6 Counseling, Inc. and Elite Care, Inc.
7 32. During a March 11, 2019 telephone conversation between
8 Greiss and a patient broker who worked for SeKe, Inc. ("Co-
9 conspirator 1") who, unbeknownst to Greiss was then cooperating
10 with law enforcement, Greiss discussed with Co-conspirator 1 the
11 monetary value of approximately 19 individuals referred to South
12 Coast Counseling, Inc. and Elite Care, Inc. by SeKe, Inc.
13 which values were based on the kinds of reimbursable drug
14 treatment the individuals were eligible for and received - - and
15 credited those values against the payments previously made to
16 SeKe, Inc. under the Marketing Services Agreement. In addition,
17 during an April 3, 2019 telephone conversation, Greiss told Co-
18 conspirator 1 that Greiss "was hungry for admissions," that he
19 (Greiss) was low on Detox-eligible patients, and that he
20 (Greiss) would "rather get admissions" than. be paid back the
21 money that Greiss had previously transferred to SeKe, Inc. for
22 patient referrals.
23 33. South Coast Counseling, Inc. and Elite Care, Inc.
24 billed and subsequently were reimbursed by insurance companies
25 for drug treatment given to admitted patients that SeKe·, Inc.
26 had referred in exchange for the payment of kickbacks by Greiss.
27 Specifically, South Coast Counseling, Inc. and Elite Care, Inc.
28 billed approximately $1,574,780.00 to insurance companies

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1 pertaining to the SeKe, Inc. referrals, and were collectively

2 paid approximately $357,762.00.

3 Officers Execute The Federal Search Warrant At Greiss' Residence

And Seize The Defendant Currency
4
34. On or about July 26, 2019, law enforcement officers
5
executed a federal search warrant at Greiss' Costa Mesa,
6
California residence. Officers found the defendant currency
7
during the search, which funds were loose and in envelopes.
8
Persons engaged in illegal conduct often maintain currency at
9
their residences, in order to conceal their illegal activity and
10
the funds from law enforcement.
11
FIRST CLAIM FOR RELIEF
12
35. Plaintiff incorporates the allegations of paragraphs
13
1-34 above as though fully set forth herein.
14
36. Based on the above, plaintiff United States of America
15
alleges that the defendant currency constitutes or is derived
16
from proceeds traceable to, or a conspiracy to commit violations
17
of 18 U.S.C. §§ 220 (illegal remunerations for referrals), 1343
18
(wire fraud), 1347 (health care fraud) and 1952 (interstate
19
travel in aid of bribery in violation of Cal. Ins. Code§ 750),
20
each of which is a specified unlawful activity as defined in 18
21
U.S.C. §§ 1956 (c) (7) (A), 1956 (c) (7) (F) and 1961 (1) (B). The
22
defendant currency is therefore subject to forfeiture pursuant
23
to 18 U.S.C. § 981(a) (1) (C). In addition, to the extent that
24
the defendant currency is not the actual monies directly
25
traceable to the illegal activity identified herein, plaintiff
26
United States of America alleges that the defendant currency is
27
identical property found in the same account or place as the
28

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1 property involved in the specified offense, rendering the

2 defendant currency subject to forfeiture pursuant to 18 U.S.C.
3 § 984.
4 SECOND CLAIM FOR RELIEF
5 37. Plaintiff incorporates the allegations of paragraphs
6 1-34 above as though fully set forth herein.
7 38. Based on the above, plaintiff alleges that the
8 defendants constitute property involved in multiple transactions
9 or attempted transactions in violation of 18 U.S.C.
10 § 1956 (a) (1) (A) (i) or (a) (1) (B) (i), or property traceable to
11 such property, with the specified unlawful activity being a
12 violation of 18 U.S.C. §§ 220, 1343, 1347 and/or 1952. The
13 defendant currency is therefore subject to forfeiture pursuant
14 to 18 U.S.C. § 981(a) (1) (A). In addition, to the extent that
15 the defendant currency is not the actual monies directly
16 traceable to the illegal activity identified herein, plaintiff
17 United States of America alleges that the defendant currency is
18 identical property found in the same account or place as the
19 property involved in the specified offense, rendering the
20 defendant currency subject to forfeiture pursuant to 18 U.S.C.
21 § 984.
22 THIRD CLAIM FOR RELIEF
23 39. Plaintiff incorporates the allegations of paragraphs
24 1-34 above as though fully set forth herein.
25 40. Based on the above, plaintiff alleges that the
26 defendant currency constitutes property involved in multiple
27 transactions or attempted transactions in violation of 18 U.S.C.
28 § 1957(a), or property traceable to such property, with the

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1 specified unlawful activity being a violation of 18 U.S.C.

2 §§ 220, 1343, 1347 and/or 1952. The defendant currency is
3 therefore subject to forfeiture pursuant to 18 U.S.C.
4 § 981(a) (1) (A). In addition, to the extent that the defendant
5 currency is not the actual monies directly traceable to the
6 illegal activity identified herein, plaintiff United States of
7 America alleges that the defendant currency is identical
8 property found in the same account or place as the property
9 involved in the specified offense, rendering the defendant
10 currency subject to forfeiture pursuant to 18 U.S.C. § 984.
11 WHEREFORE, plaintiff United States of America prays:
12 (a) that due process issue to enforce the forfeiture of
13 the defendant currency;
14 (b) that due notice be given to all interested parties to
15 appear and show cause why forfeiture should not be decreed;
16 (c) that this Court decree forfeiture of the defendant
17 currency to the United States of America for disposition
18 according to law; and
19 / / /
20 I I I
21 / / /
22 I I I
23 I I I
24 / / /
25 / / /
26 I I I
27 / / /
28 I I I
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1 ( d) for such other and further relief as this Court may

2 deem just and proper, together with the costs and disbursements

3 of this action.
4 Dated: October Jj, 2020 NICOLA T. HANNA
United States Attorney
5 BRANDON D. FOX
Assistant United States Attorney
6 Chief, Criminal Division
STEVEN R. WELK
7

9
ief, Asl
Assistant United Attorney
Section

VICTOR A. RODGERS
10 Assistant United States Attorney
Asset Forfeiture Section
11
Attorneys for Plaintiff
12 UNITED STATES OF AMERICA

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Case 8:20-cv-01989-MWF-DFM Document 1 Filed 10/15/20 Page 18 of 18 Page ID #:18

1 VERIFICATION
2 I, Darrell K. Twedt, hereby declare that:
3 L I am a Special Agent with the Federal Bureau of
4 Investigation.
5 2. I have read the above Complaint for Forfeiture and
6 know the contents thereof.
7 3. The information contained in the Complaint is either
8 known to me personally, was furnished to me by official.
9 government sources, or was obtained pursuant to subpoena. I am
10 informed and believe that the allegations set out in the
11 Complaint are true.
12 I declare under penalty of perjury under the laws of the
13 United States that the foregoing is true and correct.
14 Executed on Oc-foloe.r ,..,. , 2020 at _0--'-('_Q....;...t1~...,_.e.=--·_,.
15 California.
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17 ()< <&---:
~barrell K. Twedt
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