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TRANSCRIPT
March 8, 200.6 BY COURIER
Mr. Stephen Friedman Chairman Intelligence Oversight Board New Executive Office Building Washington, D.'C.
Dear Mr. Friedman:
Enclosed for your information is a self-explanatory letterhead memorandum (LHM), entitled "Intelligence Oversight Board (IOB) Matter, Counterterrorism Division, IOB Matter 2006-
( U )
.. This LHM sets forth details of investigative activity which the -FBI has determined was conducted contrary, to the Attorney General's Guidelines for FBI National Security Investigations and Foreign Intelligence Collection, and/or laws, Executive Orders, or Presidential Directives that govern FBI foreign counterintelligence and international terrorism investigations. (U)
Enclosure
1 - 278-HQ-C1229736-VIO—
Dep. Dir. Chief ol Statl Oil. of Gen.
Counsel Asst..Dir.:
Crim. Inv. _ CJIS Finance _ tnlo. Res. _ Insp. Lab. National Sec.. Personnel Training
EN DETACHED^ CLAS&ztfiED ENCLOSURE
SEÈJI^
Off. of EEOA Off. ol Public
& Cong. Alfs. Director's Office MAIL ROOM •
NSL VIO-23338
b2
FBI/DOJ
Mr. Stephen Friedman Should you or any member of your staff require additional
information concerning this matter, an oral briefing . will be arranged for you at your convenience. (U)
Sincerely,
Julie F. Thomas Deputy General Counsel
1 - The Honorable Alberto R. Gonzales Attorney General U.S. Department of Justice Room 5111
1 - Mr. James A. Baker Counsel, Offic-e of Intelligence Policy and Review U.S. Department of Justice Room 6150
Director Depu ty D i r e c t o r ,
C r i n i inv. CJIS. finance.
. G e n . C o u n s e l - I n f o . R e s
Training, _ Off . of EEO
A f f a i r s , Off. of Pub l i c & C o n g . A f f s ,
NSL VIO-23339
SECRET
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surveillance.
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INTELLIGENCE OVERSIGHT BOARD (IOB) MATTER DIVISION
IOB MATTER 2006 U)
Th. Division reported this potential IOB matter involving unauthorized
who was and remains a "United States person" as that term is used in Section. 101 (i) of the Foreign Intelligence
( S ) Surveillance Act of 1978 (FISA). During the course of the investigation [ssued two NSLs pursuant to the Electronic Communications Privacy Act, 18 U.S.C. §
2709. The subject NSL requested subscriber and transactional records for email account:
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(S) responded to the two NSLs by transmitting ietermined information responsive to both on a single compact disk (CD). Subsequently
that the CD contained full email content for both accounts. Pursuant to the direction of NSLB, SA sealed and sequestered in A1 envelopes the CD, along with all paper copies of its
contents.
(S) overproduction and requested verification of compliance with the limits oi IS
1 g J In the interest of administrative purity, on December 10, 200fj served
idvised regarding ational Security Letters.
with another NSL, requesting subscriber and transactional records for email account
On January 3, 2006 transmitted a CD to the F ß f Office. Once again information responsive to multiple NSLs was included on the CD.
(U) January 6, 2006. after having the information separated by email account/NSL, I g ) [ietermined that once again
advice of CDC[ land NSLB SSÄI had provided full email content. Based upon
] and SA[ | took corrective action and ensured that the CDs, along with all paper copies of their contents, were sealed and sequestered in 1A envelopes.
(U) imited the scope of the subject NSL to subscriber
content information concerning an e-mail account. Thus, the
. SCDespite the fact thai >rovidec
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information FBI unintentionally received that content information not contemplated by the NSL. Such viewing of stored electronic communications and/or electronic surveillance was not authorized under the Electronic Communications Privacy Act, Foreign Intelligence Surveillance Act and/or E.O. 12333. Under these circumstances, it is OGC's opinion that the error, although inadvertent, must be reported to IOB.
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(U) OGC has referred this matter to the FBI's Inspection Division for action deemed appropriate.
(U)
SE^ÇET NSL VIO-23340
March 15, 2006
BY COURIER
Mr. Stephen Friedman Chairman Intelligence Oversight Board Room 5020 New Executive Office Building 725 17th Street, N.W. Washington, D.C. 20503 Dear Mr. Friedman:
This letter forwards for your information a self-explanatory enclosure enti tied, "Intelligence Oversight Board (IOB) Matter, IOB 2006 (U) b2
The enclosure sets forth details of investigative activity which the FBI has determined was conducted contrary to the Attorney General Guidelines for FBI Foreign Intelligence Collection and Foreign Counterintelligence Investigations and/or laws, Executive Orders, or Presidential Directives which govern FBI foreign counterintelligence and international'terrorism investigations. (U) Enclosure 1 - 278-HQ-C1229736-VIO — l?\30
Dep. Dir. Chief of
Staff Off. of Gen.
Counsel Asst.-Dir,:
Crim. Inv. CJIS I Finance info. Res. _ Insp. Ub.
SE R ST
National Sec.. Personnel Training
Of o! EEOA OH. ol Public
& Cong. Alfs. Director's Office
NSL VIO-23341 F B I / D O J
MAIL ROOM •
Should you or any member of your staff require additional information concerning this matter, an oral briefing will be arranged for you at your convenience.
Sincerely,
Julie F. Thomas Deputy General Counsel
1 - The Honorable Alberto R. Gonzalez Attorney General .U.S. Department of Justice Room 5ill
1 - Mr. James A. Baker III Counsel for Intelligence Policy and Review U.S. Department of Justice Room 6000
m m r n r n 5î ,nv-Hfrïiv îskw» Jfe fi m '¡nines. DiKCtOî _ G 8 P . . C o y s j $ Depu ty Director In to . R e s .
T r a i n i n g Di t . of EEO AtTlEUS Dif. of Public & C o n g . A ' i s .
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NSL VIO-23342
SEÄRET
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(U) (S)
The Investigation nas
INTELLIGENT nwPRIGHT BOARD (IOB) FIELD OFFICE
IOB MATT MATTER
IR 2006-X
division1 s T-PftarH . in.
full response
Field Office of the Federal Bureau of reported an error -i n_ rnn-innrt i nn w-i- h that
field investigation of to a National Security metter [FS1
In ,t±ü_5 ) -tof
which erroneously provided financial records wmcn were nnrplatgd to the subject of the NSL, which were associated with
customer who may be a United States person. (U) This matter has been reported-to the FBI's Office
of Professional Responsibility for appropriate action.
SE^ET
NSL VIO-23343
February 27, 2006 BY COURIER
Mr. Stephen Friedman Chairman Intelligence Oversight Board Room 502 0 New Executive Office Building 725 17th Street, N.W. Washington, D.C. 2 0503
Dear Mr. Friedman:
Enclosed for your information is a self-explanatory letterhead memorandum (LHM), entitled "Intelligence Oversight Board (IOB) Matter, (U)
DIVISION, IOB Matter 2006] ]» b2 b7E
This LHM sets forth details of investigative activity which the FBI has determined was conducted contrary to the Attorney General's Guidelines for FBI National Security Investigations and Foreign Intelligence Collection, and/or laws, Executive Orders, or Presidential Directives that govern FBI foreign counterintelligence and international terrorism investigations. (U)
>irector . Vdm. _ :t/ci _ >Ì33L ntelL JES >ir.: -Serv.
L Inv. .
Res. _ ¡ction -Tech. Enclosure
iratoiy of Cong. Afis. __ of the Geo. Coun. oflntelL
Ms. Thomas
Pub. Affe of Pro£ Resp. MgmL rity ling _ :EEOA .
- 278-HU-(J1^2yV36-VIO - Inspection (IOB 2 006
MAIL room •
- J a s 3
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NSL VIO-23344
Mr. Stephen Friedman
Should you or any member of your staff require additional information concerning this matter, an oral briefing will be arranged for you at your convenience. (U)
Sincerely,
Julie F. Thomas Deputy General Counsel
Enclosure
1 - The Honorable Alberto Gonzales Attorney General U.S. Department of Justice Room 5111
1 - Mr. James A. Baker Counsel, Office of Intelligence Policy and Review U.S. Department of Justice Room 6150
NSL VIO-23345
December 29, 2006 BY COURIER
Mr. Stephen Friedman . Chairman Intelligence Oversight' Board Room 50209 New Executive Office Building 12b Street,.Northwest Washington, D.CV Dear Mr. Friedman:
Enclosed for your information is a self-explanatory memorandum entitled "Intelligence Oversight Board Matter 20.06 " (U) ,' b2
The memorandum sets.forth details of investigative activity which the FBI'- has determined was conducted contrary to the Attorney General Guidelines for .FBI Foreign- Intelligence Collection and Foreign Counterintelligence Investigations and/or laws, Executive Orders, or Presidential Directives•which govern FBI foreign counterintelligence and international terrorism investigations. This matter has also been referred to our Internal Investigations Section, Inspection Division, for. a determination of.whether any- administrative action is warranted. (U)
Dep. Dir. Chief 61
Staff Off. of Gen.
Counsel Asst. Dir.:
Crim. Inv. _ CJIS ] Finance Into. Res. _ Insp. Lab.
Enclosure 1- 278--HQ-C122973,6-VIO.-*^OW
National Sec.. Personnel Training
Off. o lEEOA Off. of Public
L Cong. Affs._ Director's Office HAIL ROOM •
sfe^K^T
NSL VIO-23347
^SESREI^ Mr. Stephen.Friedman
Should you or any member of your staff require additiona information concerning this matter, an oral briefing will be arranged, for you at your convenience. (U) .
1 - The Honorable Alberto R. Gonzales Attorney General U.S. Department of Justice Room 5111
1 - Mr. James Baker Counsel, Office of Intelligence Policy and Review National Security Division U.S. Department of Justice. Room 6150
Sincerely
Julie F. Thomas Deputy General „Counsel
D i r e c t o r . G e n . C o u n s e l . D e p u t y Direc tor In fo . .Res .
F inance .
P e r s o n n e l .
T r a i n i n o . O f l . o ì É E O
A f f a i r s . O f f . of P u b l i c & . C o n g . A i l s
NSL VIO-23348
SECRET
INTELLIGENCE-CHEESimT BOARD (IOB). MATTER
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FIELD OFFICE IOB MATTER' 200'6-j "|(U)
Electro Division
rnmranni ration (EC) ' dated July 17, notified FBI Headquarters 2006, _ _ _ _
(FBIHQ) of an inadvertent acquisition of toll record information associated with unknown nHi vi rina 1 s in thp r.nnrss nf a riatinnal security iinvestigation.
that term is used in Section 101 (i) .of the Foreign Intelligence Surveillance Act of 1978 (FISA).1
Î? issued a National Security Letter (NSL)
pursuant to the Electronic Communications Privacy Act, 18 U.S.C. § 27092 for toll record information associated with the target. The pr-rnr nrrnrrpH after the initial records were received froml "I
The results listed a telephone number ending with the being subscribed to by the target. However, when the
NSL result letter was scanned with new'software, an errant spreadsheet was produced.
(S) The spreadsheet indicated that the target had. subscribed to seven sequential telephone numbers. The inadvertent
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(U) A "United States person" (USP)is defined in Section 101(i) of the Foreign Intelligence Surveillance 'Act (FISA)(codified at 50 U.S.C. § 1801 et sea.) a s " a citizen of the United States [or] an alien lawfully admitted for permanent residence . (as defined in section 101(a) (20) of the Immigration and Naturalization Act) . . .. ." See also Section II.W of The Attorney General's Guidelines for FBI Foreign Intelligence Collection and Foreign Counterintelligence Investigations.-
2 The statute permits the FBI' to request subscriber information arid telephone toll billing records that are "relevant to an authorized investigation to protect against international terrorism or clandestine intelligence activities, provided that such an investigation of a United States person is not conducted solely on the basis of activities protected by the fixst amendment to the Constitution .of the United States."
3 (U) In order to avoid any further dissemination of the incorrect telephone numbers, the phone numbers referenced in this EC will only list the last Jour digits.
^fSRET
NSL VIO-23349
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R E T
A follow-up requesting roll billing NaL was tnen aaaressea to
information.for these seven errant telephone numbers, provided the requested information which was initially uploaded into FBI computer systems.
(U) Immediately upon discovery, .the errors were remedied by All references to the errant telephone numbers have been removed from FBI computer systems. To prevent . future errors, additional quality control steps and software training have been added to the telephone record scanning process. .' The above-referenced telephone records were some of the first scanned records.
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Section V.H., Investigative Techniques, of The Attorney General's Guidelines for FBI National Security Investigations and Foreign Intelligence Collection (NSIG) provides that National Security Letters may be issued in conformity with statutory requirements, including 18 U.S.C. § 2709. Title 18, U.S.C. § 2709 provides that the FBI may seek toll billing information from telephone carriers that is relevant to an authorized national security investigation. . Clearly, the information obtained by the FBI was not relevant to an authorized national security investigation because there was an errant request for unsubstantiated telephone numbers. Thus, the FBI received telephone toll billing records concerning.telephone numbers that were not under investigation nor related to an investigation. Therefore, the information was improperly collected, although unintentionally'so, in violation of the NSIG and ECPA.
(U) Clearly, the rights of the target were not infringed because he was not the subject of the improperly collected information. It is unknown whether this information was gathered about United States Persons or.not, inasmuch as there has been no review of the information. Nonetheless, based on the fact that information which may be about United States persons was improperly, although inadvertently, collected, and in accordance with the reporting requirements of Section 2:4 of E.O. 12863, this matter is being to the IOB.-
(U) See, id.
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NSL VI023350
November 3, 200 6 BY COURIER
Mr. Stephen Friedman Chairman Intelligence Oversight Board Room 5020 New Executive Office Building 725 17th Street, N.W. Washington, D.C. 20503 Dear Mr.. Friedman:
This letter forwards for your information a self-explanatory enclosure .eiLtüled, "Intelligence Oversight Board ;iOB) Matter,. IOB 2006 (U)
The enclosure sets forth details of investigative activity which the FBI has determined was .conducted contrary to the Attorney General Guidelines for FBI Foreign Intelligence Collection and Foreign Counterintelligence Investigations and/or laws, Executive Orders, or Presidential Directives which govern FBI foreign countérintelligence and international terrorism investigations. (U) Enclosure 1 ,- 278-HQ-C1229736-VIO— t ^ ^
b2
Dep. Dir. Chiel öl Staff Off. of Gen.
Counsel Asst. Dir.: Crim. Inv. _
CJIS I Finance Info. Res. _ Insp. Lab. National Sec.. Personnel Training Off. ofEEOA
Oil. ol Public & Cong. Alfs.
Director s Office MAIL ROOM NSL VIO-23351
Should you or any member of your staff require additional information•concerning this matter, ah oral briefing will be arranged for you at your.convenience.
Sincerely
Julie F. Thomas Deputy General Counsel
1 - The Honorable Alberto R. Gonzalez Attorney General U.S. Department of Justice Room 5111
1 - Mr. James A. Baker III Counsel for Intelligence Policy and Review U.S. Department of Justice Room 6000
RP Director Deputy Di rec to r .
f&ijpj Finance.. .Gen.Ccu .info. Res
Training . Gii. of EEO . Af fa i r s . Dil. Ol Public & . . Cong. Ails
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NSL VIO-23352
(U) INTELLIGENCE OVERSIGHT BOARD (IOB)
.. "I ~| FIELD OFFICE • IOB MATTER 2006-1 |(S.)
MATTER
The Field Office of the Federal Bureau of Investigation has reported an unintentional acquisition of FISA take on the wrong target, after learning through the issuance of a legitimate NSL of a change in subscriber. In this regard, nnknnwn tn thp FRT at the time, the target terminated his account withl Thus, between
on August 26. POOS. continued to erroneously monitor this account although a new, presumably U.S. person, had taken over the account.
(U) This matter has been reported to the FBI's Inspection Division for appropriate action.
SÈTSRET
NSL VI023353
October 3, 2006 „ BY COURIER
Mr. Stephen Friedman Chairman Intelligence Oversight Board Room 50209 New Executive Office Building 725.17th Street, Northwest Washington, D.C. Dear Mr. Friedman:
Enclosed for your information is1a self-explanatory memorandum entitled "Intelligence Oversight Board Matter 2006
b2 (U) ' The memorandum sets forth details of investigative
'activity which the FBI has determined was conducted contrary to the Attorney General Guidelines for FBI Foreign Intelligence Collection and Foreign Counterintelligence Investigations and/or laws, Executive Orders, . or Presidential Directives which govern FBI foreign counterintelligence and-international terrorism investigations. This matter has also been referred.to our Internal Investigations -Section/ Inspection Division, for a determination of whether any administrative action is warranted. (U) Enclosure .
1 - 278-HQ-C12297 36-VIO— .(.T^^
Dep. Dir. Chief of
StatT Off. of Gen.
Counsel Asst..Oir.:
Crim. Inv. _ CJIS Finanoe Info. Res. _ Insp. Lab. National Sec.. Personnel Training
OK.o lEEOA Off. of Public
& Cong. Affs. Director's Office ' MAIL ROOM •
NSL VIO-23354
Mr. Stephen Friedman Should you or any member of your staff require additional
information concerning this matter, an oral briefing will be arranged for you at your convenience. (U)
J Sincerely,
Julie F. Thomas Deputy General Counsel
1 - The Honorable Alberto R. Gonzales Attorney General U.S. Department of Justice Room 5111
1 - Mr. James Baker Counsel, Office of Intelligence Policy and Review U.S. Department.of Justice Room 6150
S Q B D i W H r* C r i w . l w . I n s p e c t i o n T r a i n i n g i t " „ , , „ i f l VJJiû . L a b o r a t o r y Off . of EEO F inance N'tliuiial S e c . A f f a i r s
Director G i n C o u n s e l D?R • Off. of P u b l i c & Deputy Direc tor In to R e s . P e r s o n n e l C o n g . A f i s .
NSL VIO-23355
S E ^ E T
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INTELLIGENCE OVERSIGHT BOARD MATTER I IFIELD OFFICE
I OB MATTER 200 6-f |(U) bY electronic communication dated August 19,
200,6, the Federal Bureau of Investigation (FBI)| |Field Office, jpnnrtsd a nns.sihla Intelligence Oversight Boa ri (IOB) matter,.
On 08/16/2005, after receiving the requested information froml | the case agent noticed a tvnnnraphical error in the issuance of the NSL. • The NSL
As a result ot the typographical error, the agent received information for an individual other than
Upon discovering the error, the case agent iy nnpgtoi-oH ayH destroyed the CD of information
I After attending NSLB training immediately submitted by earlier this"year, sne reported the incident and requested a legal review.
Here, a typographical error on the FBI resulted in an accidental overcollection of information. Based upon our analysis, in accordance with the reporting requirements of Section 2.4 of Executive Order 12863, , the carrier's mistake must be reported to the' IOB.
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February 27., 2006
BY COURIER
Mr. Stephen Friedman Chairman Intelligence Oversight Board Eisenhower Executive Office Building Washington,: D.C.
Dear Mr. Friedman:
Enclosed for your information is.a self-explanatory letterhead memorandum (LHM), entitled "Intelligence Oversight Board (IOB) Matter, Washington Field Office, 2006 J (U)
b2
This LHM sets forth details of investigative activity which the FBI has determined was conducted contrary to the Attorney General Guidelines for FBI Foreign Intelligence Collection and Forèign Counterintelligence Investigations and/or laws, Executive Orders, or Presidential Directives which govern FBI foreign counterintelligence and international terrorism investigations. (U)
Enclosure - Ms - Thomas
(278-HQ-C1229736-VIO) b6 • b7C
Dep. Dir Chief of
Staff Off. of Gen. ; Counsel Asst. Dir.:
Cnm. Inv.. CJIS i Finance l'ile Res.. tnsp. Lab. National Sec. _ Personnel Training
Off. of EEOA Off. of Public
I Cong. Affs. Director's Office „
NSL VIO-23369 UA.IL ROOK •
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INTELLIGENCE OVERSIGHT BOARD (IOB) FIELD OFFICE
MATTER
IOB MATTER 2006 b<
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de t e rir.ined t h a t f S\ The Federal Bureau of Investigation ("FBI") has
the FBI improperly used a National Security Letter (NSL)to obtain subscriber information and telephone toll billing records on a telephone number which was not related to the investigation. The overcollection was due to a mistake in the NSL in identifying the telephone number of
whose number was Intended to be the subject of the request. TEe overcollection was a violation of Section V.ll. of The Attorney General's Guidelines for FBI National Security • Investigations and Foreign Tntelliaence Collection (NSTG).1 In this regard
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During the' course of the investigation, issued a National Security Letter (NSL) pursuant to tne Electronic Communications Privacy Act, 18 U.S.C. § 2709, to a'telephone carrier for the telephone subscriber and toll billing records of a telephone number intended to be identified as that of the target. Instead, one of the numbers within the telephone number was incorrectly written; thus, the information returned from the carrier was subscriber information and the telephone toll billing records of a wholly unrelated telephone number. The error was discovered upon receipt of the information, and the. records' were .not 'reviewed nor used for any investigative purpose. Despite' the inadvertent nature of the mistake, the fact remains that information was improperly collected on a telephone number unrelated.to an investigation. Thus, the matter is being reported to the IOB.
(U) Director. Deputy Director .
SECRET I n s p e c t i o n L a b o r a t o r y
I ra ining D i l o i bEO A f t s l r s
P e r s o n n e l . . Oii. ot P u b l i c &
C o n g . Ai t s .
Section V.ll. authorizes use of National Security Letters in conformity with 18 U.S.C. § 2709 (relating to subscriber information, toll billing' records, and electronic communication transactional records). The statute reguire_s=-that information sought is relevant to an authorized national^ security investigation.
OIG-IOB06 (12-19-06)-IT#3 NSL VIO-23370
FBI0000180
F E D E R A L B U R E A U O F I N V E S T I G A T I O N F O I P A
D E L E T E D P A G E I N F O R M A T I O N S H E E T
N o D u p l i c a t i o n F e e s a r e c h a r g e d f o r D e l e t e d P a g e I n f o r m a t i o n S h e e t ( s )
T o t a l D e P a g e 10 P a g e 2 2 P a g e 23 P a g e 24 P a g e 25 P a g e 26 P a g e 2 7 P a g e 28 P a g e 29 P a g e 30 P a g e 3 1 P a g e 3 2 P a g e 33 P a g e 36 P a g e 3 7 P a g e 38 P a g e 39 P a g e 4 0 P a g e 4 1 P a g e 4 2 P a g e 4 3 P a g e 4 4 P a g e 4 5 P a g e 4 6 P a g e 4 7 P a g e 4 8 P a g e 4 9 P a g e 50 P a g e 5 1 P a g e 5 2 P a g e 53 P a g e 54 P a g e 55 P a g e 56 P a g e 5 7 P a g e 58 P a g e 59 P a g e 60 P a g e 6 1 P a g e 6 2 P a g e 63 P a g e 64 P a g e 65 P a g e 66
t e d P a g e ( s ) — 85 Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Dupli c ate Dupli c ate Duplicate Duplicate Duplicate Duplicate Dupli c ate Dupli c ate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate Duplicate
P a g e 6 7 —- D u p l i c a t e P a g e 69 —- D u p l i c a t e P a g e 7 0 —- D u p l i c a t e P a g e 7 1 —- D u p l i c a t e P a g e 7 2 —- D u p l i c a t e P a g e 7 3 —- D u p l i c a t e P a g e 7 4 —- D u p l i c a t e P a g e 7 5 —- D u p l i c a t e P a g e 7 6 —- D u p l i c a t e P a g e 77—- D u p l i c a t e P a g e 7 8 —- D u p l i c a t e P a g e 19 —- D u p l i c a t e P a g e 80 -— D u p l i c a t e P a g e 81 —- D u p l i c a t e P a g e 82 —- D u p l i c a t e P a g e 83 —- D u p l i c a t e P a g e 84 —- D u p l i c a t e P a g e 85 —- D u p l i c a t e P a g e 86 •— D u p l i c a t e P a g e 87-— D u p l i c a t e P a g e 88 —• D u p l i c a t e P a g e 89 ~ D u p l i c a t e P a g e 90 ~ D u p l i c a t e P a g e 91 —• D u p l i c a t e P a g e 92 —• D u p l i c a t e P a g e 93 —• D u p l i c a t e P a g e 94 —• D u p l i c a t e P a g e 95 —• D u p l i c a t e P a g e 96 —• D u p l i c a t e P a g e 97-— D u p l i c a t e P a g e 98 ~ D u p l i c a t e P a g e 99 ~ D u p l i c a t e P a g e 100 -• D u p l i c a t e P a g e 101 —• D u p l i c a t e P a g e 102 —• D u p l i c a t e P a g e 103 —• D u p l i c a t e P a g e 104 —- D u p l i c a t e P a g e 105 —- D u p l i c a t e P a g e 106 —- D u p l i c a t e P a g e 1 0 7 —- D u p l i c a t e P a g e 108 ~ D u p l i c a t e