1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 1 of 16 Pg ID 67 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN NORTHERN DIVISION

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1 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 1 of 16 Pg ID 67 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN NORTHERN DIVISION UNITED STATES OF AMERICA, Plaintiff, vs Case No HONORABLE THOMAS L. LUDINGTON ANTHONY BENNETT, Defendant. / MOTION FOR CHANGE OF VENUE Defendant Anthony Bennett, by his attorney John A. Shea, moves this Court for an order transferring venue in this matter to the Southern Division of the Eastern District of Michigan, in Detroit. Defendant s motion is based on the right to a fair trial secured to him under the Sixth Amendment to the United States Constitution, and Rule 21 of the Federal Rules of Criminal Procedure, which bases are more fully explained in the attached Brief in Support. Dated: s/john A. Shea John A. Shea (P37634) Attorney for Defendant 120 N. Fourth Avenue Ann Arbor, Michigan (734) jashea@earthlink.net

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3 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 3 of 16 Pg ID 69 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN NORTHERN DIVISION UNITED STATES OF AMERICA, Plaintiff, vs Case No HONORABLE THOMAS L. LUDINGTON ANTHONY BENNETT, Defendant. / BRIEF IN SUPPORT OF MOTION FOR CHANGE OF VENUE Defendant Anthony Bennett is charged, inter alia, with Murder in the First Degree, Assault of a Child Resulting in Substantial Bodily Injury, and Assault of a Child, involving alleged assaults and the subsequent death of 4-year-old Carnel Chamberlain. Since the reported disappearance of Carnel on June 21, 2012 and to-date, countless articles about the case have appeared in local news media, both print and broadcast, as well as in the general blogosphere. While initially the thrust of the media attention was on finding the missing boy, Mr. Bennett s arrest on initial charges of assault on a child caused the media coverage quickly to shift, the focus becoming Mr. Bennett, his alleged history of abusing the boy, and ultimately his hand in alleged foul play causing Carnel Chamberlain s death. This coverage has been and continues to be exclusively negative, even damning, and pervasive. The atmosphere created is of the kind described as inherently prejudicial such that a change of venue is mandated by the Sixth Amendment to the United States Constitution, because it is reasonably

4 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 4 of 16 Pg ID 70 likely Defendant cannot get a fair trial in the present venue. See generally, Skilling v. United States, 130 S.Ct. 2896, 2949 (2010) (opinion of Justice Sotomayor). Accordingly, Defendant brings this motion, relying on the Sixth Amendment and F.R.Cr.P. 21. BACKGROUND On June 21, 2012, Anthony Bennett reportedly was babysitting Carnel Chamberlain, the son of his girlfriend Jaimee Chamberlain, at their residence on the Saginaw Chippewa Reservation near Mount Pleasant, Michigan. Late that evening, reports describe that he called Ms. Chamberlain, who was working that evening, and related that he could not find Carnel. Ms. Chamberlain arrived home and tribal police were summoned to help search for her son. The search was unsuccessful. After a week-long search, on June 28, 2012, police found what they identified as the remains of Carnel Chamberlain buried under the porch of Mr. Bennett s and Jamiee Chamberlain s home. Reportedly, his body was badly burned. That same day, authorities filed a federal complaint against Anthony Bennett for alleged assaults on Carnel Chamberlain earlier that month but, notably, not for his death. Mr. Bennett was arrested on the resulting warrant and, following a detention hearing held on July 3, 2012, ordered detained pending further proceedings. At that hearing and in his July 5, 2012 order, the magistrate relied for his decision on the allegations of prior abuse in the federal complaint, and on detailed findings regarding Mr. Bennett s criminal history. On July 11, 2012, Mr. Bennett was indicted for the assaults described in the federal complaint. On November 7, 2012, the Grand 2

5 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 5 of 16 Pg ID 71 Jury issued a First Superseding Indictment, charging Mr. Bennett, in addition, with the murder of Carnel Chamberlain. Throughout, the case has been the subject of widespread and regular media scrutiny and speculation. Local media sources have included the following: 1 M-Live (Flint/Saginaw/Bay City print editions), at least 63 articles. CBS WNEM Channel 5 (Bay City/Saginaw), at least 39 articles. ABC Channel 12 (Flint), at least 31 articles. 9&10News (Traverse City/Cadillac/Mt. Pleasant), at least 13 articles. minbc Channel 25 (Saginaw/Flint), at least 14 articles. Other local print media have covered the case on a more occasional basis, including Mt. Pleasant s The Morning Sun, and The Big Rapids Daily News. The local coverage, while most saturated during the first month of the investigation, continues apace. 2 Much of it, of course, dwells on Carnel s disappearance and death, and the law enforcement investigation. In addition, the media has reported on the pending 1 Results from M-Live are from a search utilizing carnel chamberlain as the search term. Results from the broadcast media sites are from website searches utilizing search terms anthony bennett and carnel chamberlain. For each broadcast media source, the larger number of search results was used, assuming that 100% of the articles in the smaller set of results was captured in the larger, which assumption may be overly conservative and cause the number of articles to be understated. Search results may be found in Exhibits A. to E. 2 Attached as exhibits are collections of links to relevant articles referenced throughout this brief, published by various local media sources. The links to M-Live articles are in reverse chronological order by date. Links for the other sources identify each article by number, but typically they are not collected in complete chronological order. 3

6 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 6 of 16 Pg ID 72 proceedings from their beginning to the present, and on everything from pretrials and scheduling orders to the recent substitution of defense counsel. 3 And to expand matters further, articles regularly appear on other topics related to Carnel Chamberlain s death, such as memorial services, memorial fundraising, and larger lessons to the community about child abuse. 4 Statewide and at times national news attention likewise focused on Carnel s disappearance and the suspicion surrounding Mr. Bennett. By June 30, 2012, just nine days after Carnel was reported missing, M-Live reported that a Google News search yielded over 1000 articles covering the matter. (Exhibit G.) The attention even included CNN s NewsHour with Nancy Grace, which aired a phone interview with Jaimee Chamberlain and a tribal spokesman that included commentary on Anthony Bennett s alleged complicity. (See infra, fn. 14 and accompanying text.) This interview occurred on June 29, 2012, not-so-coincidentally the day after Mr. Bennett was arrested. Given the attention paid to the investigation over the previous 8 days, one may assume that the show was of local interest; this assumption is confirmed by the fact that M-Live publicized that it would air a few hours before it was televised. (Exh. F.) 3 For coverage of the investigation, see references infra, Brief pp For coverage of the court proceedings, see, e.g., M-Live articles 6/29/12, 7/3/12, 7/4/12, 7/10/12, 7/13/12, 7/16/12, 10/15/12, 11/7/12, 11/27/12, 3/20/13, 3/21/13, 3/22/13, 4/26/13, 5/29/13 (Exh. A); CBS WNEM Channel 5 articles 1, 4, 6, 7, 10-13, 20-24, 27, 29; (Exh. B); ABC Channel 12 articles 4, 11-13, 15, 17-27, 31 (Exh. C); 9&10News articles 3-6, 10, (Exh. D); minbc Channel 25 articles 2, 5-9, (Exh. E). 4 See, e.g., M-Live 6/29/12, 7/2/12, 7/3/12, 7/10/12, 7/11/12, 6/21/13 (Exh. A); The Morning Sun 8/12/12 (Exh. I); CBS WNEM Channel 5 articles 28, 37; (Exh. B); ABC Channel 12 articles 2, 5, 6, 8, 9, 10, 16 (Exh. C); 9&10News article 1 (Exh. D); minbc Channel 25 articles 8, 9 (Exh. E). 4

7 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 7 of 16 Pg ID 73 Predictably in this age of blogs, blogsites, and social media, a spate of webpages sprang up to comment on Carnel s disappearance and the subsequent investigation. Examples in clude _bennett_is_charged_with/ (sic). The last two advocate that Mr. Bennett receive the death penalty. Referenced above was a M-Live article describing over 1000 Google hits regarding the case, as of June 30, Updating that search, undersigned counsel ran a similar query as this motion was being prepared; it resulted in 8770 hits. See Exh. H. 5 There can be no disputing that Carnel Chamberlain s disappearance, and the subsequent charges against Mr. Bennett, have generated intense interest in the media and greater community. For purposes of this motion, it is important not only to describe that, quantitatively, the media coverage and social commentary has been pervasive. In addition, qualitatively, the 5 Only the first page of search results is reproduced in the exhibit; the number of hits is displayed at the top of the page. Search terms are included on the second page of the exhibit; the Court will see that terms were utilized to exclude results unrelated to this case. 5

8 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 8 of 16 Pg ID 74 coverage has been overwhelmingly negative and judgmental regarding Mr. Bennett. One may expect not to be written about favorably when arrested and charged for a horrific crime such as alleged here. However, the focus on Mr. Bennett in this case typically has expanded well beyond the fact that Mr. Bennett is charged with assaulting and killing Carnel. From the start, Mr. Bennett was targeted in the media by family members, police and the general community as a person of interest, a suspect, indeed the prime suspect. 6 He regularly was described as Carnel s caretaker at the time, the last person to see him. 7 To bolster these suspicions, the allegations of his prior abuse of Carnel, described in the federal complaint, likewise were widely reported. 8 Additional widespread coverage focused on his character, and his past, much of which is unproved and some of which is inadmissible on the issue of innocence or guilt at trial. Articles described Mr. Bennett s troubled past, including lengthy stays in youth homes and detention facilities, his criminal history (including assaultive crimes), and his drug use. 9 He has been described as only very 6 See, e.g., M-Live 6/25/12, 6/28/12, 6/29/12, 7/3/12, (Exh. A); CBS WNEM Channel 5 articles 30, 33; (Exh. B); ABC Channel 12 articles 4, 5, 13, 30 (Exh. C); 9&10News articles 2, 9, 10, 11 (Exh. D). 7 See, e.g., M-Live (Exh. A), passim; CBS WNEM Channel 5 articles 4, 8, 24, 25, 27, 28 (Exh. B); ABC Channel 12 articles 5, 14, 24, 26, 27 (Exh. C); 9&10News articles 2, 5, 8, 9, (Exh. D). 8 See, e.g., M-Live June 29, 2012 and passim since (Exh. A); CBS WNEM Channel 5 articles 11, 19, 26 (Exh. B); ABC Channel 12 articles 1, 2, 3, 9, 10, 30 (Exh. C); 9&10News article 6 (Exh. D); minbc Channel 25 article 13 (Exh. E). 9 See, e.g., M-Live articles 7/3/12, 7/4/12, 7/10/12, 7/24/12, 11/16/12 (Exh. A); CBS WNEM Channel 5 articles 8, 21, 22, 35, (Exh. B); ABC Channel 12 articles 16, 21 (Exh. C). 6

9 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 9 of 16 Pg ID 75 occasionally employed. 10 He has been described as oppositional with authorities. 11 Finally, articles contained details of the instant investigation reflecting adversely on Mr. Bennett. For instance, Mr. Bennett was described as unconcerned (or unemotional), 12 and uncooperative with law enforcement. 13 Sources reported that he did not assist police with the search. Perhaps most troubling, various sources reported that he refused to take a polygraph, while it was reported that Jaimee Chamberlain took and passed two such tests. 14 Beyond the case, Mr. Bennett has become the poster-child for community concerns about perpetrators of child abuse. As described earlier in this brief, various articles have publicized fundraising in Carnel Chamberlain s name to fight child abuse, interviews have been had with family members about the larger issues of abuse, and recently there was coverage of a memorial for Carnel to raise community consciousness to the scourge of domestic abuse. While such efforts are laudatory in general, their coverage in this context invariably, and indeed inevitably, reflects back onto Mr. Bennett as representative of the problem these efforts seek to solve, and fuels 10 See, e.g., ABC Channel 12 article 16 (Exh. C). 11 See, e.g., M-Live 7/3/12, 7/4/12 (Exh. A); CBS WNEM Channel 5 article 22 (Exh. B). 12 See, e.g., CBS WNEM Channel 5 article 35 (Exh. B) 13 See, e.g., M-Live 6/25/12, 6/29/12, 7/22/12 (Exh. A); ABC Channel 12 article 29 (Exh. C); 9&10News article 9 (Exh. D). 14 See, e.g., M-Live 6/27/12, 6/29/12 (embed from Nancy Grace interview) (Exh. A); CBS WNEM Channel 5 articles 30, 31 (Exh. B); ABC Channel 12 article 5 (Exh. C); 9&10News article 9 (Exh. D). 7

10 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 10 of 16 Pg ID 76 the common conception that Mr. Bennett murdered Carnel as part of a pattern of domestic abuse. Given the overwhelmingly negative and judgmental coverage of Mr. Bennett, and its pervasiveness, one logically assumes that the community exposed to that coverage has formed a negative and judgmental opinion of him. Bolstering that assumption are the comments one frequently finds in connection with the media coverage and the social commentary. Emblematic of that reaction can be found in connection with the aforementioned on-line petition found at (sic). There, a person created a petition calling for Mr. Bennett to receive the death penalty, and asked persons to electronically sign the petition. The site reports 484 supporters, and published 73 comments (presumably from at least 73 of those supporters ). Of the 73 comments, 55 were from Michigan, and 37 from the Northern Division of the Eastern District of Michigan. Even a cursory review of the comments to this petition, 15 and those attached to a great many of the local media articles, 16 reveals deep- 15 See Exhibit J. 16 Following are representative comments from just two sources (and note their recency). See, e.g. M-Live comments to 6/21/13 article: Justice will eventually prevail even if it doesn t truly happen until Anthony Bennett draws his last breath, and I can t wait until this Anthony Bennett gets to prison, prisoners do not like people who hurt children; to 5/29/13 article: Carnel didn t get to pick and choose who protected him; why does Bennett? True justice will be served when Bennett no longer breathes the same air as everyone else; We have an electric company in Bay City; shouldn t be build a chair? (in reference to Defendant and the death penalty); CBS WNEM Channel 5 comments to 4/18/2013 article: They need to throw his **** in jail forever and throw away the key! Let bubba take care of him because even some of the worlds' worst criminals hate child abusers/killers! Similar sentiments may be found attached to countless other articles published since June 21,

11 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 11 of 16 Pg ID 77 seated animosity towards Mr. Bennett in the community from which his jury will be drawn. In sum, there has been pervasive media coverage and social commentary in connection with this case that is extremely negative towards and judgmental of Mr. Bennett. Predictably, this has resulted in a community that, to the extent it shares its views publically, is poisoned against him. The reasonable likelihood is that these attitudes predominate in the rest of the community as well. ARGUMENT Rule 21 of the Federal Rules of Criminal Procedure requires that a motion to change venue be brought at or before arraignment or at any other time the court or the federal rules prescribe. A motion to change venue due to pretrial publicity may be based on either presumed or actual prejudice. Presumed prejudice exists in a trial atmosphere that has been utterly corrupted by press coverage. Actual prejudice refers to a finding by the Court during or after voir dire, where it is confirmed that a community-wide sentiment exists against the defendant. Defendant s instant Motion is for a change of venue based on presumed prejudice. Due process requires that a defendant receive a trial by an impartial jury free from outside influences. Sheppard v. Maxwell, 384 U.S. 333, 362 (1966); Skilling v. United States, 130 S. Ct. 2896, 2913 (2010). If pretrial publicity jeopardizes a defendant s right to a fair trial by an impartial jury, the trial court should grant the defendant a change in venue. Irvin v. Dowd, 366 U.S. 717, (1961). The Supreme Court has held that presumed prejudice exists 9

12 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 12 of 16 Pg ID 78 where a conviction was obtained in a trial atmosphere that had been utterly corrupted by press coverage. Murphy v. Florida, 421 U.S. 794, 798 (1975). While rare, granting a motion to change venue based on presumed prejudice is not unheard of in this District. See e.g. United States v. Ebens, 654 F. Supp. 144, 146 (E.D. Mich. 1987) ( Factors such as the comment and castigation of public figures, the intensity and long duration of the publicity (since 1982), its inflammatory tone and content, and the continually repeated factual recitations, all militate toward the conclusion that a change of venue * * * must be granted ). Recently, the United States Supreme Court revisited the issue of venue and presumed prejudice, in Skilling v. United States, 130 S. Ct. 2896, supra. In evaluating whether the district court in that case had erred in denying the defendant s motion to change venue, the Court referenced four factors: (1) the size and characteristics of the community from which the jury was drawn, (2) whether there was dissemination of prejudicial information that a juror could not reasonably be expected to shut from sight, (3) whether the taint of publicity was dissipated by the lapse of time between the case arising and trial, and (4) the jury s actual verdicts in that multicount case. Id., at Finding that, in Mr. Skilling s case, his jury was drawn from the Houston, TX community whose population was in excess of 4.5 million persons, that there was no smoking gun information disseminated to the public that invited prejudgment of his culpability, that trial took place over 4 years since the investigation arose, and, of prime significance, that the jury had acquitted Mr. Skilling of multiple counts, the Court 10

13 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 13 of 16 Pg ID 79 affirmed the district court s ruling that prejudice of the venire could not be presumed. Id. In Mr. Bennett s case, the situation is markedly different. The fourth factor of course is irrelevant in this pretrial context (although it is significant that the high Court found it to be of prime significance in its decision), so the discussion will address the first three factors only. The first is easily dispensed with--in contrast to the large metropolitan area from which Mr. Skilling s jury was drawn, the Northern District has at present an estimated population of only 866,459, according to the U.S. Census Bureau (2012 estimates). 17 Moreover, most of the District is comprised of small communities where events such as those underlying this case are rarer, and therefore more prominent and more closely followed, than one would expect in a major metropolitan area where crime is more ubiquitous and media coverage much more diluted. The weight of this Skilling factor predominates in favor of granting Mr. Bennett s motion. In terms of the second factor, as previously described the publicity has been both pervasive and overwhelmingly adverse. In the course of this publicity, there has been disseminated a collection of highly prejudicial facts regarding the investigation that a juror could not reasonably be expected to shut from sight, including, inter alia, that Mr. Bennett was the prime suspect, that he was Carnel Chamberlain s caretaker and the last to see him alive, that he had a prior history of physically abusing Carnel, that he refused to 17 Counsel s county-by-county figures were obtained from the Census Bureau online page and added together. 11

14 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 14 of 16 Pg ID 80 cooperate with police, and that he refused to take a polygraph while others took them. In addition, many articles publicized details of Mr. Bennett s life that bring him into disrepute, including his time in detention facilities, his lengthy criminal history, his drug use, his sparse employment history, and his anti-social behavior towards the authorities. And finally, the publicity has been used as a springboard for a larger discussion in the community about child abuse and the need to eradicate it, which springboard uses the assumed guilt of Mr. Bennett as its starting point. The weight of this Skilling factor predominates in favor of granting Mr. Bennett s motion. The third Skilling factor, the lapse of time between investigation and jury selection, will be only 18 months on the current schedule. Recent media coverage is not as frequent as had occurred a year ago but the case still is covered regularly, it still is adverse, and from the tenor of reader comments animosity towards Mr. Bennett is still very much alive. There is no reason to believe that this animosity will dissipate over the next few months, and even if briefly forgotten this is the kind of case in which opinions, previously formed, can be expected to return with full force upon one s recollection being refreshed by jury service. Again, this Skilling factor predominates in favor of granting Mr. Bennett s motion. CONCLUSION In concluding, reference ought be made to the words of Justice Sotomayor in her separate opinion in Skilling. Although she concurred with that part of the Court s opinion holding that there 12

15 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 15 of 16 Pg ID 81 was no presumptive prejudice sufficient to require change of venue, she cast the inquiry in common-sense terms applicable in the instant case. First, regarding presumptive prejudice, she observes: Our decisions instead merely convey the commonsense understanding that as the tide of public enmity rises, so too does the danger that the prejudices of the community will infiltrate the jury. The underlying question has always been this: Do we have confidence that the jury s verdict was induced only by evidence and argument in open court, and not by any outside influence, whether of private talk or public print? Skilling, supra, 130 S.Ct. at 2948 (citations omitted). Discussing the case of Rideau v. Louisiana, 83 S.Ct (1963), she quotes a leading treatise describing the meaning of that decision, contrasting circumstances of presumed prejudice with those where the voir dire process can weed out actual prejudice,: The best reading of Rideau is that the Court there recognized that prejudicial publicity may be so inflammatory and pervasive that the voir dire simply cannot be trusted to fully reveal the likely prejudice among prospective jurors. Skilling, supra at 2949 (citing 6 W. Lafave, J. Israel, N. King & O. Kerr, Criminal Procedure). And finally, she describes the commonsense standard for a trial court determining when prejudice should be presumed so as to require a change of venue: [ W]here there is a reasonable likelihood that prejudicial news prior to trial will prevent a fair trial, the judge should continue the case until the threat abates, or transfer it to another [venue] not so permeated with publicity. Skilling, supra at 2949 (citing Sheppard v. Maxwell, 86 S.Ct (1966)). Justice Sotomayor s words and references inform us as to how the three Skilling factors should be applied here. In view of the 13

16 1:12-cr TLL-CEB Doc # 21 Filed 07/15/13 Pg 16 of 16 Pg ID 82 widespread, pervasive, adverse, and undeniably prejudicial publicity and social commentary that has surrounded this case, there is at least a reasonable likelihood that a fair trial will not be possible absent a change of venue, because voir dire procedures will not be trustworthy enough to reveal underlying prejudices. Given this reality, if Mr. Bennett were to be convicted here, we will not have confidence that such conviction was induced solely by the evidence and argument in court. The weight of the Skilling factors predominates in favor of changing venue as well. For these reasons, the Court should grant Defendant s motion and transfer the venue of this case to the Southern Division in Detroit. Dated: s/john A. Shea John A. Shea (P37634) Attorney for Defendant 120 N. Fourth Avenue Ann Arbor, Michigan (734) jashea@earthlink.net CERTIFICATE OF SERVICE The undersigned hereby certifies that, on July 15, 2013, he filed a copy of Defendant s Motion for Change of Venue and Brief in Support. Notice of this filing will be sent to all counsel of record by operation of the Court's electronic filing system. Dated: July 15, 2013 s/john A. Shea John A. Shea (P37634) Attorney for Defendant 120 N. Fourth Avenue Ann Arbor, Michigan (734) jashea@earthlink.net 14

17 1:12-cr TLL-CEB Doc # 21-1 Filed 07/15/13 Pg 1 of 1 Pg ID 83 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN NORTHERN DIVISION UNITED STATES OF AMERICA, Plaintiff, vs Case No HONORABLE THOMAS L. LUDINGTON ANTHONY BENNETT, Defendant. / INDEX OF EXHIBITS Exhibit A: Links to relevant articles from M-Live. Exhibit B: Links to relevant articles from CBS WNEM Channel 5. Exhibit C: Links to relevant articles from ABC Channel 12. Exhibit D: Links to relevant articles from 9&10News. Exhibit E: Links to relevant articles from minbc Channel 25. Exhibit F: 6/29/12 M-Live article (in anticipati on of Jamiee Chamberlain interview on Nancy Grace ) Exhibit G: 6/30/12 M-Live article ( 1000 articles per Google). Exhibit H: 7/11/13 Google search by counsel for relevant links. Exhibit I: 8/12/12 article from The Morning Sun. Exhibit J: petition for Defendant to receive the death penalty, with comments. Dated: July 15, 2013 s/john A. Shea John A. Shea (P37634) Attorney for Defendant 120 N. Fourth Avenue Ann Arbor, Michigan (734) jashea@earthlink.net

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72 1:12-cr TLL-CEB Doc # 21-7 Filed 07/15/13 Pg 8 of 8 Pg ID 138

73 1:12-cr TLL-CEB Doc # 21-8 Filed 07/15/13 Pg 1 of 3 Pg ID 139

74 1:12-cr TLL-CEB Doc # 21-8 Filed 07/15/13 Pg 2 of 3 Pg ID 140

75 1:12-cr TLL-CEB Doc # 21-8 Filed 07/15/13 Pg 3 of 3 Pg ID 141

76 1:12-cr TLL-CEB Doc # 21-9 Filed 07/15/13 Pg 1 of 3 Pg ID 142

77 1:12-cr TLL-CEB Doc # 21-9 Filed 07/15/13 Pg 2 of 3 Pg ID 143

78 1:12-cr TLL-CEB Doc # 21-9 Filed 07/15/13 Pg 3 of 3 Pg ID 144

79 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 1 of 5 Pg ID 145

80 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 2 of 5 Pg ID 146

81 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 3 of 5 Pg ID 147

82 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 4 of 5 Pg ID 148

83 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 5 of 5 Pg ID 149

84 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 1 of 20 Pg ID 150

85 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 2 of 20 Pg ID 151

86 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 3 of 20 Pg ID 152

87 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 4 of 20 Pg ID 153

88 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 5 of 20 Pg ID 154

89 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 6 of 20 Pg ID 155

90 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 7 of 20 Pg ID 156

91 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 8 of 20 Pg ID 157

92 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 9 of 20 Pg ID 158

93 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 10 of 20 Pg ID 159

94 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 11 of 20 Pg ID 160

95 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 12 of 20 Pg ID 161

96 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 13 of 20 Pg ID 162

97 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 14 of 20 Pg ID 163

98 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 15 of 20 Pg ID 164

99 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 16 of 20 Pg ID 165

100 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 17 of 20 Pg ID 166

101 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 18 of 20 Pg ID 167

102 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 19 of 20 Pg ID 168

103 1:12-cr TLL-CEB Doc # Filed 07/15/13 Pg 20 of 20 Pg ID 169