NO.

09-300

[No. 09-300, USDC, Dillon]

________________________________

IN THE UNITED STATES COURT OF APPEALS

FOR THE FIFTEENTH CIRCUIT

________________________________

UNITED STATES OF AMERICA,

Plaintiff-Appellee,

v.

TIM RIGGINS,

Defendant-Appellant.

____________________

BRIEF OF APPELLEE

____________________

Appeal from the

United States District Court
for the
District of Dillon

The Honorable Justin Feist

United States District Judge
______

STEPHEN WAGNER, ESQ.

United States Attorney

5670 McGillin Way,

Dillon City, Finlandia 55102

(555) 555-1234
 TABLE OF CONTENTS

Page

TABLE OF CONTENTS..2

TABLE OF AUTHORITIES.3

STATEMENT OF THE CASE..4

QUESTION PRESENTED....5

STANDARD OF REVIEW...5

SUMMARY OF ARGUMENT.6

ARGUMENT.8

I. AN UNAUTHORIZED DRIVER OF A RENTAL VEHICLE HAS NO

LEGITIMATE EXPECTATION OF PRIVACY WITHIN THE VEHICLE,
AND THEREFORE IS WITHOUT STANDING TO ASSERT A
CHALLENGE TO A SEARCH. 8

A. Establishment of a Legitimate Expectation of Privacy

Requires an Ownership or Possessory Interest in the
Vehicle. 8

II. A TOTALITY OF THE CIRCUMSTANCES ANALYSIS FAILS TO

RECOGNIZE THE REQUIRED POSSESSORY INTEREST IN THE
VEHICLE, AND THEREFORE SHOULD NOT BE ADOPTED BY THIS
CIRCUIT. ..14

A. The only circuit that uses this test is the Sixth Circuit,
and the Reasoning of the Test is Implicitly in Conflict
With Supreme Court Precedent..14

B. Even if this test is adopted, the totality of the circumstances

leads to the conclusion that the defendant did not have a
legitimate expectation of privacy. ..15
III. MERE PERMISSION FROM THE AUTHORIZED DRIVER CANNOT CREATE A
LEGITIMATE EXPECTATION OF PRIVACY, SINCE THE AUTHORIZED
DRIVERLACKS AUTHORITY TO GIVE SUCH PERMISSION.

A. Common Authority Does Not Replace Concepts of

Real or Personal Property or Understandings That
Are Recognized by Society as a Basis for a Legitimate
Expectation of Privacy 17

B. The defendant and his wife lacked common authority over the
vehicle. 17

A. Concepts of real or personal property or understandings that are

recognized by society do not flow to unauthorized drivers of rental
vehicles 19

CONCLUSION..20
 TABLE OF AUTHORITIES

United States Supreme Court Cases:. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .page

Rakas v. Illinois, 439 U.S. 128, 143 (1978) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6, 8, 10, 13

 Statement of the Case

A. Statement of the Facts

On July third, 2007, the DefendantTim Riggins (Riggins)was seen by police speeding

away from a possible drug den. (R. at 14-20). The arresting officerOfficer Womack

(Womack)was able to catch up to Riggins and pulled him over for speeding. (R. at 14-20).

The car in which Riggins was speeding was a rental; Riggins gave Womack his driver license,

auto registration, and rental agreement. (R. at 14-20). However, Riggins was not authorized to

drive the vehicle, as made clear by the rental agreement only listing Lyla Garrity Riggins,

(Lyla) his wife. (R. at 14-21). Since Riggins was plainly not authorized to drive the vehicle,

Womack asked Riggins if he could search the vehicle. (R. at 14-21). Claiming to be in a hurry,

Riggins then refused to allow Womack to do so. (R. at 14-21).

Following Riggins refusal, Womack asked Riggins to exit the car and then used a drug-

sniffing dog to smell the exterior of the vehicle. (R. at 14-21). The dog alerted Womack to the

passenger side of the vehicle, where Womack discovered an unlocked glove compartment. (R. at

14-21). Within the unlocked glove compartment, Womack discovered 500 grams of cocaine

wrapped in a bag, in addition to chemicals that are often used in making crystal

methamphetamine. (R. at 14-21). Beyond the drugs and drug-manufacture materials, the car also

contained a few of personal items, such as mens clothing and an iPod. (R. at 14-21). Only after

discovering the drugs and drug manufacturing paraphernalia did Womack place Riggins under

arrest. (R. at 14-21). Although Lyla and Riggins intimate that Riggins had Lylas permission to

drive the carand that the car was rented on a joint credit card held between Lyla and primarily

by Rigginsthe rental agreement only listed Lyla as an authorized driver. (R. 14-21).
 B. Procedural History

On August 1, 2007, Defendant Riggins sought relief from the United States District Court

for the District of Dillon, alleging that the police search of the rental vehicle violated his

Fourth Amendment right to freedom from unreasonable searches and seizures. (R. at 14-7).

Riggins argued, therefore, that suppression of the 500 grams of cocaine and the drug

manufacturing paraphernalia was required. (R. at 14-7). On August 16, 2007, the prosecution

filed an opposition to Riggins motion, arguing that Riggins lacks standing to challenge the

search. (R. at 14-15). On September 12, 2007, the District Court agreed with the prosecution

and denied Riggins motion. (R. at 14-20). That same day, Riggins filed a Notice of Appeal

with the District Court, indicating that he was appealing the denial of his motion to the United

States Court of Appeals for the Fifteenth Circuit. (R. at 14-24). On September 23, 2007, the

United States Court of Appeals for the Fifteenth Circuit granted Riggins application for

appeal, on the sole issue of standing.

Question Presented

1. Whether a person who lacks any form of authorization to drive a rental vehicle
from the rental car company may, solely on the basis of the authorized drivers
permission to drive the vehicle, have standing to challenge a police search of the
vehicle under the Fourth Amendment?

Standard of Review

This is an appeal from the U.S. District Court for the District of Dillon. The

district court denied Defendants motion to suppress evidence seized during a search of a

rental vehicle, based upon lack of standing. A district courts determination regarding a

defendants standing to challenge a search & seizure is reviewed de novo. United States

v. Gonzalez, Inc., 412 F.3d 1102, 1116 (9th Cir. 2005); United States v. Silva, 247 F.3d
1051, 1054 (9th Cir. 2001); United States v. Sarkisian, 197 F.3d 966, 986 (9th Cir. 1999);

United States v. Armenta, 69 F.3d 304, 306-307 (9th. Cir. 1995).

Summary of Argument

Standing to challenge a search only exists when a person has a legitimate

expectation of privacy in the searched area. Rakas v. Illinois, 439 U.S. 128, 143 (1978).

Rakas was directly based upon prior Supreme Court precedent, which emphasized that in

order to enjoy Fourth Amendment protection, not only must the person have a subjective

expectation of privacy, but this expectation must in all cases be reasonable. Katz v.

United States, 389 U.S. 347, 361 (1967).

The great weight of federal authority leads to the conclusion that Defendants

alleged expectation of privacy is unreasonable. The Fourth Circuit has plainly held that

an unauthorized driver of a rental vehicle has no reasonable expectation of privacy in the

vehicle, and therefore no standing to challenge a search therein. United States v. Wellons,

32 F.3d 117 (4th Cir. 1994). Wellons correctly interprets Katz and Rakas in requiring that

an individual may only assert standing in the limited situation of when he has asserted

ownership or lawful possession of the vehicle. This interpretation has been well received

in the Fifth and Tenth Circuits as well. See generally United States v. Boruff, 909 F.2d

111(5th Cir. 1990); United States v. Obregon, 748 F.2d 1371 (10th Cir. 1984). This is an

easily-administered, bright line rule that unauthorized drivers of rental vehicles never

have a reasonable expectation of privacy in the vehicle.

 Even in Circuits that have not yet adopted this interpretation, their analyses often

still rest upon a concept of legitimate permission to operate the vehicle as forming a basis

for standing. For example, the Ninth Circuit has adopted a novel common authority

test. This test operates such that an unauthorized driver of a rental vehicle gains standing

to challenge a search simply provided that he used the property interdependently with the

authorized renter and had joint control over the property. United States v. Thomas, 447

F.3d 1191 (9th Cir. 2006). Although the Ninth Circuit held that an unauthorized driver

gains standing if they had permission from the legitimate renter, their common

authority reasoning has not been adopted by a single Circuit outside of their own.

However lacking the common authority test may be in terms of constitutional

foundation, the Ninth Circuits concern with a drivers legitimate permission to operate

the vehicle adds validation to the bright line rule of the fourth, fifth, and tenth Circuits.

The Eight Circuit also requires legitimate permission to operate the vehicle as a

prerequisite for standing to challenge a search. United States v. Best, 135 F.3d 1223 (8th

Cir. 1998); United States v. Muhammad, 58 F.3d 353 (8th Cir. 1995). Even though the

Eight Circuit shares the Ninth Circuits view that unauthorized drivers gain standing with

permission from the authorized driver, the Eighth Circuit deviates from the Ninth by not

adopting the common authority test. At best, the Eighth and Ninth Circuits have

splintered in their interpretations of the Fourth Amendment, a logical conclusion of

failing to apply the bright line rule of the Fourth, Fifth, and Tenth Circuits.
 Defendant here had no permission to drive the vehicle from its legitimate owner,

the rental company. He also had no relationship with the company, having not even

rented the car himself. Constitutional protections do not and cannot be the fruit of

unlawfully allowing an individual to use anothers property. The District Courts ruling

should be affirmed.

Argument

I. AN UNAUTHORIZED DRIVER OF A RENTAL VEHICLE HAS NO LEGITIMATE

EXPECTATION OF PRIVACY WITHIN THE VEHICLE, AND THEREFORE IS WITHOUT
STANDING TO ASSERT A CHALLENGE TO A SEARCH.

B. Establishment of a Legitimate Expectation of Privacy Requires an

Ownership or Possessory Interest in the Vehicle.

Individuals who transport drugs in rental vehicles that they have no authorization

to drive lack a legitimate expectation of privacy. In denying a defendant standing to

assert Fourth Amendment rights, the Supreme Court has narrowly limited the class of

individuals who have standing to make such challenges; only those who possess a

legitimate expectation of privacy enjoy such a constitutional right. Rakas v. Illinois, 439

U.S. 128, 143 (1978). Furthermore, possession of a legitimate expectation of privacy

imposes two additional requirements on an individual attempting to assert Fourth

Amendment protection. Specifically, in order to have such an expectation, an individual

must demonstrate an actual, subjective expectation of privacy, and the expectation

[must] be one that society is prepared to accept as reasonable. Katz v. United States,

389 U.S. 347, 361 (1967) (Harlan J., concurring).

The growing trend among several circuit courts has been the adoption of a bright

line rule regarding unauthorized drivers of rental vehicles. This rule states that

unauthorized drivers are never in legal possession of the vehicle, and therefore any

expectation of privacy on their part is not legitimate. See generally United States v.

Wellons, 32 F.3d 117 (4th Cir. 1994); United States v. Boruff, 909 F.2d 111 (5th Cir.

1990), cert. denied, 499 U.S. 975, 111 S.Ct. 1620, 113 L.Ed.2d 718 (1991); United States

v. Obregon, 748 F.2d 1371 (10th Cir. 1984).

The Wellons court correctly applied this rule to a case with facts virtually identical

to the instant case. In Wellons, appellant Sherman Wellons and two othersLawrence

Dixon and Antonio Johnsondrove a rental vehicle from Pittsburgh, Pennsylvania, to

Atlanta, Georgia. Wellons, 32 F.3d 117 at 118. Dixon was the sole driver authorized on

the rental agreement. Id. The next day, Wellons drove the vehicle back to Pittsburgh

alone, despite not being listed as an authorized driver. On the drive back, Wellons was

pulled over by a West Virginia police officer for speeding; at such time Wellons

produced his driver license and the vehicle registration. Upon learning that Wellons was

not the authorized driver of the vehicle, the officer asked if he could search the vehicle.

Wellons declined, stating that he was in a hurry. Following this, the officer utilized a

drug-sniffing dog to smell the outside of the vehicle, and the dog indicated the presence
of narcotics. Id. at 119. After the dog had alerted the officer to the presence of

narcotics, the officer searched the vehicle. As a result of the search, the officer found

cocaine and heroin, along with two bags of luggage. Id.

As a result of this search, Wellons was convicted of possession with intent to

distribute cocaine and heroin, among other charges. Wellons attempted to suppress

the narcotics that were found in the rental car, making a Fourth Amendment challenge

to the search of the vehicle. The district court rejected this argument, and the Wellons

court affirmed. The court firmly grounded its reasoning in Rakas, declaring that [o]nly

where a search intrudes upon a space as to which an individual has a legitimate

expectation of privacy will the search violate that individuals Fourth Amendment

rights. Wellons, 32 F.3d 117 at 119. To that end, the circuit court agreed with the

district court that Wellons, as an unauthorized driver of the rented car, had no

legitimate privacy interest in the car. Id.

The reasoning in Wellons mirrors that of multiple distinct circuits. The Fifth

Circuit has followed the exact rule used in Wellons, also as applied to drug dealers

driving rental cars without authorization. Boruff, 909 F.2d 111. In Boruff, the

defendantJames O. Boruffwas involved in a drug trafficking conspiracy. In

furtherance of that conspiracy, he was driving a rental car that was in one of his co-

conspirators name. Furthermore, his co-conspirator was operating a truck that was

also not in Boruffs name. Id. at 113. Both were ultimately pulled over by police, who
discovered over five-hundred pounds of marijuana in the truck, along with thousands of

dollars in cash and radio equipment in the rental vehicle. Id. at 114.

After being placed under arrest, Boruff attempted to suppress the contents of the

search of both the truck and the rental vehicle, on the basis of the Fourth Amendment.

The circuit court found that the defendants Fourth Amendment rights are violated

only when the challenged conduct invaded his legitimate expectation of privacy rather

than that of a third party. Id. at 115 (citing United States v. Payner, 447 U.S. 727, 731,

100 S.Ct. 2439, 2443, 65 L.Ed.2d 468 (1980)). In so doing, the Boruff court emphasized

the requirement that the fourth amendment does not protect merely subjective

expectations of privacy but only those expectation[s] that society is prepared to

recognize as reasonable. Boruff, 909 F.2d 111 at 115 (citing Katz, 389 U.S. 347).

Specifically as to the rental car, Boruff argued that he had a legitimate

expectation of privacy because he was in sole possession of the car at the time of the

stop. This argument was flatly rejected. Id. at 117. The court reasoned that Boruffs

girlfriendthe actual renter of the vehicledid not have authority to give control of the

car to Boruff, as he was not listed on the rental agreement. Boruff, therefore, had no

legitimate expectation of privacy in the rental car. Id. Since Boruff lacked such an

expectation, he also lacked standing to challenge the search.

 Beyond the Wellons and Boruff courts, representing the Fourth and Fifth circuits,

the Tenth Circuit has also correctly adopted the bright line rule in light of Katz and

Rakas. Obregon, 748 F.2d 1371. In Obregon, the defendantFernando Obregonwas

operating a rental vehicle in New Mexico. He encountered a routine traffic roadblock,

designed to check for driver license and car registrations. Id. at 1373. Obregon was not

listed as an authorized driver on the rental agreement, and was thus unable to produce

any such documentation showing that he was an authorized driver of the vehicle. Id.

The roadblock officer subsequently searched the vehicle, in which he discovered

multiple bags of cocaine, in addition to some clothing and personal items. Id.

Like the defendant in the instant case, Obregon argued that he had a legitimate

expectation of privacy within the rental vehicle. He based this argument solely on the

fact that he was driving the vehicle and at the time of the stop and maintained some

personal possessions within the car. Id. at 1374. Obregon largely based this argument

on an erroneous interpretation of Katz; the district court squarely rejected Obregons

argument, stating:

Defendant had the keys to the car and may have had permission from the renter
of the car to use it, but this is not determinative of the standing inquiry in this
case. Defendant was driving a rented vehicle and was not named on the rental
agreement or any other documents, either as the renter or as an authorized
driver. Defendant made no showing that any arrangement had been made with
the rental car company that would have allowed him to drive the car legitimately.
Indeedan unrelated third party arranged the rental of the car. Defendant's
relationship to the rented car is too attenuated to support a claim of standing.
Obregon at 1374.

The Obregon circuit court agreed with this statement, as it was in harmony with

the circuits law on the subject. See generally United States v. Erickson, 732 F.2d 788

(10th Cir. 1984). Thus, Obregon lacked a legitimate expectation of privacy within the

vehicle, and thus lacked standing to challenge any search.

The cases that the Fourth, Fifth, and Tenth circuit has encountered with respect

to this matter have been remarkably similar to the instant case. In the case at bar, the

defendantTim Rigginswas driving a rental vehicle without authorization from the

rental company. (R. at 14-21). Like the defendants in the previously discussed cases,

Riggins was using this car for purposes of narcotics trafficking. (R. at 14-21).

The common thread running through Wellons, Boruff, and Obregon has been a

dispositive inquiry into a legitimate possessory interest in the vehicle. Each defendant

lacked such an interest, and therefore lacked a legitimate expectation of privacy in the

vehicle. Application of this rule to the defendants case clearly shows a lack of such an

interest, virtually identical in facts and circumstances to the cases discussed. Each of the

defendants arguments have been categorically rejected by these circuits: (1) possession

of items in the car confers standingrejected. Obregon, 748 F.2d 1371 at 1374. (2)

Permission from authorized driver to operate the vehicle confers standingrejected.

Obregon, 748 F.2d 1371 at 1374; Wellons, 32 F.3d 117 at 119; Boruff, 909 F.2d 111 at

117. (3) Relationship with rental company was sufficient to confer standing, even

without ever having picked up the car or contacted the companyrejected. See

Obregon, 748 F.2d 1371 at 1374.

II. A TOTALITY OF THE CIRCUMSTANCES ANALYSIS FAILS TO RECOGNIZE THE

REQUIRED POSSESSORY INTEREST IN THE VEHICLE, AND THEREFORE SHOULD
NOT BE ADOPTED BY THIS CIRCUIT.

A. The only circuit that uses this test is the Sixth Circuit, and the
Reasoning of the Test is Implicitly in Conflict With Supreme Court
Precedent.

The Sixth Circuit has devised a totality of the circumstances scheme to

determine whether a defendant has a legitimate expectation of privacy. See generally

United States v. Smith, 263 F.3d 571 (6th Cir. 2001). In this test, the court will look to a

variety of factors in making its determination, including: whether the operator of the

vehicle had a driver license, the identity of the authorized renter, whether the operator

of the vehicle was able to produce the rental agreement, and the business relationship

between the operator of the vehicle and the rental company. Id. at 586. No other

circuit has adopted this test; in fact, this type of reasoning is implicitly rejected by the

Supreme Court. Specifically, although the Court has stated that no single factor will

invariably be determinative, Rakas, 439 U.S. at 152, the very analysis in Rakas made the

dispositive issue a legitimate possessory interest in the vehicle. Thus, under Katz, a
totality of the circumstances approach is inappropriate, given the dispositive nature of

legitimate possessory interests.

B. Even if this test is adopted, the totality of the circumstances leads to

the conclusion that the defendant did not have a legitimate expectation
of privacy.

The Sixth Circuit has stated that as a general rule, an unauthorized driver of a

rental vehicle does not have a legitimate expectation of privacy in the vehicle, and

therefore does not have standing to contest the legality of a search of the vehicle.

Smith, 263 F.3d 571 at 586. The Smith court only authorized a deviation from this

general rule on the basis of the truly unique facts of the case. Of these unique facts,

the court emphasized the personal relationship between Smith and the rental company.

Specifically, Smith had not only personally called the rental company to rent the vehicle,

he was also directly given the reservation number and personally gave the company his

credit card number. Id. at 586-587. The court noted that this made Smith the de facto

renter of the vehicle. Id.

No such circumstances exist in the case at bar. The defendant had never

contacted the rental company, did not receive any sort of reservation number, did not

pick up the car himself, and his wife provided the credit card number. In fact, the only

attenuated tie that the defendant can even attempt to muster is that he happened to

be a joint cardholder with his wife on the card that she used to rent the car. These facts
dramatically differ from those in Smith, and clearly do not warrant a deviation from the

general rule that unauthorized drivers of rental vehicles lack standing. These facts are

hardly unique, much less truly unique within the meaning of Smith to warrant such a

dramatic departure from the rule.

III. MERE PERMISSION FROM THE AUTHORIZED DRIVER CANNOT CREATE A

LEGITIMATE EXPECTATION OF PRIVACY, SINCE THE AUTHORIZED DRIVER LACKS
AUTHORITY TO GIVE SUCH PERMISSION.

B. Common Authority Does Not Replace Concepts of Real or Personal

Property or Understandings That Are Recognized by Society as a
Basis for a Legitimate Expectation of Privacy

A reasonable expectation of privacy may be shown either by reference to

concepts of real or personal property law or to understandings that are recognized and

permitted by society. U.S. v. Thomas, 447 F.3d 1191, 1197 (9th Cir. 2006) (citing

Minnesota v. Carter, 525 U.S. 83, 88, 119 S.Ct. 469, 142 L.Ed.2d 373 (1998)). The Ninth

Circuit has drastically expanded this statement by redefining understandings that are

recognized and permitted by society to include any drug dealer who shares joint

control or common authority in a rental vehicle that they may use in furtherance of

criminal activity. Id. at 1198. No other circuit has adopted such a radical deviation from

the commonly understood meanings of these terms.

 C. The defendant and his wife lacked common authority over the
vehicle.

The Ninth Circuit has further defined common authority to be based upon

mutual use of the property by persons generally having joint access or control for most

purposes. Id. (citing Illinois v. Rodriguez, 497 U.S. 177, 181, 110 S.Ct. 2793, 111

L.Ed.2d 148 (1990)). The facts of the instant case do not rise to this definition. Mrs.

Rigginsthe defendants wifeis a stay-at-home mother, and does not work. (R. at 14-

5). Thus, she does not operate the vehicle for purposes of driving to-or-from work.

Furthermore, her affidavit makes no indication that she supported, much less was even

aware, of the defendants drug dealing activities with the car. This leads to the

inference that she did not exercise control over the vehicle nearly to the extent that the

defendant did. Finally, her own affidavit has stated that the defendant used the car

more than she did. (R. at 14-6). Thus, taken as a whole, the defendant and his wife lack

the common authority over the vehicle for most purposes, as required by the Ninth

Circuit to possess standing. This relationship respecting the rental car is in stark contrast

to the type of relationship the defendant had in Smith. The Smith court did not find

standing due to Smiths failure to show he had permission from his co-conspirator,

McGuffey. Even if such permission had been shown, the relationship between the

Smith conspirators is far too dissimilar from the spousal relationship between the
defendant and his wife in the instant case. In Smith, the defendant and his co-

conspirator were actively engaged in an ongoing narcotic trafficking activity. No such

facts are present in the record of the instant case; the defendants wife here is simply a

stay-at-home wife, not an elaborate drug dealer. Thus, the defendant, even under the

Ninth Circuit deviation approach, lacks standing.

D. Concepts of real or personal property or understandings that are

recognized by society do not flow to unauthorized drivers of rental
vehicles

The Eight Circuit has an even more limited test than the Ninth regarding standing

to challenge a search. U.S. v. Muhammad, 58 F.3d 353 (8th Cir. 1995). In Muhammad,

the defendantWallace Muhammadwas driving a rental vehicle that was only

authorized to be driven by one Candace Jordan. Muhammad was stopped by police,

and ultimately was unable to produce documentation proving that he had permission to

drive the vehicle. The Muhammad court concluded that the defendant did not have

standing based upon this lack of production, and held that the defendant must present

at least some evidence of consent or permission from the lawful owner/renter to give

rise to an objectively reasonable expectation of privacy. Id. at 354 (citing United States

v. Gomez, 16 F.3d 254, 256 (8th Cir. 1994)).

Despite this holding, the Muhammad court emphasized First Circuit precedent

that indicated a requirement of a more intimate relationship with the cars owner or a
history of regular use of the [car]. Muhammad, 58 F.3d 353 at 354 (citing United States

v. Sanchez, 943 F.2d 110, 114 (1st Cir. 1991)). In this instant case, the defendant had no

relationship whatsoever with the owner of the carthe rental companyand his

history of use of the car is sporadic and brief, as it was merely a rental car for temporary

use when his family car broke down.

Conclusion

The defendant had no reasonable expectation of privacy in the rental car, since

he lacked a legitimate possessory or ownership interest in the vehicle. The vast majority

of federal case law has required or emphasized such a requirement; Constitutional

protections do not and cannot be the fruit of unlawfully allowing an individual to use

anothers property. The District Courts ruling should be affirmed.

Respectfully Submitted,

__________________________________

Stephen A. Wagner

United States Attorney

5670 McGillon Way,

Dillon City, Finlandia 55102

February 12, 2007