def. tony west, assistant attorney general, civil division, doc. ## 28, 27, 25

8/9/2019 Def. Tony West, Assistant Attorney General, Civil Division, Doc. ## 28, 27, 25

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Employees rank the Civil Divisionin the top 2% of governmentoffices

Office of the Assistant Attorney General

Assistant Attorney General, CivilDivision:Tony West

Tony West was nominated byPresident Barack Obama to bethe Assistant Attorney Generalfor the Justice Departments CivilDivision on January 22, 2009. Hewas confirmed by the U.S.Senate on April 20, 2009.

From 1993 through 1994, he

served as a Special Assistant inthe Department under thedirection of U.S. DeputyAttorneys General PhilipHeymann and Jamie Gorelick, aswe ll as Attorney General JanetReno. Mr. West worked on thedevelopment of national crimepolicy, including the 1994Omnibus Crime Bill. From 1994 to1999, Mr. West served as anAssistant U.S. Attorney for theNorthern District of California.

Mr. West later served as stateSpecial Assistant AttorneyGeneral, an appointee ofCalifornia Attorney General BillLockyer. In that capacity, headvised the California AttorneyGeneral on various mattersincluding high-tech crime, identitytheft, the Microsoft antitrustlitigation, police officer training,civil rights, and police misconduct.

Prior to his return to the Justice

Department, Mr. West was alitigation partner at Morrison &Foerster in San Francisco. Histrial practice there includedrepresenting individuals andcompanies in civil and criminalmatters.

Mr. West graduated with honorsfrom Harvard College, where heserved as publisher of theHarvard Political Review, andreceived his law degree fromStanford Law School, where he

OFFICE OF THE AAG

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CIVIL DIVISION FOIADOJ HOME

7/7/2010 Tony West, Assistant Attorney General

ustice.gov/civil/Tony West Bio.htm 1/


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updated 7/7/2010 8:33:48 AM ET

LONDON BP PLC confirmed Wednesday that it received a demand from U.S. authorities for advance notice of any asset sales or significant cash

transfers.

The Financial Times reported that U.S. Assistant Attorney General Tony West, who heads the Civil Division of the U.S. Department of Justice,

wrote to Rupert Bondy, BP's general counsel, on June 23. Normally the U.S. Justice Department does not require advance notice of such deals.

"We have received the letter, and have not yet responded," said BP press officer Sheila Williams. "We will be responding in due course."

She declined to say whether the Justice Department had set a deadline.

The letter underlines the U.S. government's intense scrutiny of BP as it struggles to cap the oil leak in the Gulf of Mexico, which began on April 20,

and to clean up the damage.

On April 30, U.S. Attorney General Eric Holder announced that he had dispatched a team, which included West, to New Orleans to monitor the

spill. Ignacia S. Moreno, the assistant attorney general for the Environment and Natural Resources Division, was also part of the team.

Under intense pressure from President Barack Obama's administration, BP agreed last month to suspend dividend payments for the rest year and

to set up a $20 billion escrow fund to insure that the company pays for the damage.

On June 1, Holder announced that the Department of Justice had launched criminal and civil investigations of the disaster, which began w ith an

explosion and fire aboard the Deepwater Horizon drilling platform. Eleven workers died.

Copyright 2010 The Associated Press. All rights reserved. This material may not be published, broadcast, rewritten or redistributed.

BP gets U.S. demand for notice of asset salesOrder underlines the U.S. government's intense scrutiny of BP

7/7/2010 BP gets U.S. demand for notice of ass

msn.com//business-oil_and_energy/ 1/


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UNITED STATES DISTRICT COURTMIDDLE DISTRICT OF FLORIDA

FT. MYERS DIVISION

JORG BUSSE; JENNIFER FRANKLIN

PRESCOTT,

Plaintiffs,

v. Case No. 2:10-CV-89-CEH-TGW

JOHN EDWIN STEELE; SHERI POLSTERCHAPPELL; ROGER ALEJO; KENNETH M.WILKINSON; JACK N. PETERSON;GERALD BARD TJOFLAT; RICHARDJESSUP; JUDGE BIRCH; JUDGE DUBINA;RICHARD A. LAZZARA; CHARLIE CRIST;

LEE COUNTY VALUE ADJUSTMENTBOARD; LORI RUTLAND; EXECUTIVETITLE CO.; JOHNSON ENGINEERING, INC.,

Defendants.

MOTION FOR EXTENSION OF TIME

NOW COMES the United States of America, on behalf of its

officers, Chief Judge Joel Dubina and Circuit Judges Gerald

Tjoflat and Stanley Birch of the United States Court of Appeals

for the Eleventh Circuit; District Judges Richard Lazzara, John

Steele and Magistrate Judge Sheri Chappell of the United States

District Court for the Middle District of Florida; and Deputy

United States Marshal Richard Jessup (collectively, federal

defendants); and moves for an extension of time in which to

answer or otherwise respond to Plaintiffs complaint. In support

of this motion, the United States shows unto the Court as

follows:

Case 2:10-cv-00089-CEH-TGW Document 28 Filed 06/30/10 Page 1 of 4


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1. On February 9, 2010, Plaintiffs filed a complaint

naming the above-referenced federal defendants, and others, as

defendants in their individual private and official capacities.

2. The docket sheet indicates that service of process was

effected upon Judge Steele on May 1 [DE-12] and upon Judge

Chappell on May 4 [DE-13], with corresponding answer deadlines of

June 30 and July 3, 2010, respectively. Fed. R. Civ. P.

12(a)(2)&(3). There is no indication that any other federal

defendant has yet been served, and therefore the undersigned is

unable to ascertain their answer deadlines at this time.

3. A suit against a federal officer in his or her official

capacity is in effect a suit against the United States. See

Swank, Inc. v. Carnes, 856 F.2d 1481, 1483 (11th Cir. 1988). It

is the position of the United States that Plaintiffs complaint

should be construed as an official capacity suit against the

United States and not the individual federal defendants.

4. The undersigned Special Attorney is entering a general

notice of appearance on behalf of the United States and timely

filing a motion to dismiss the complaint contemporaneous with the

filing of this motion.

5. The United States respectfully suggests to the Court

that the same defenses it asserts in its motion to dismiss the

official capacity suit would apply with equal force if the

federal defendants were sued in their individual capacities;

2



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however, if the Court were to construe this as an individual

capacity suit and were to require them to answer, then the

federal defendants require additional time to seek and obtain

authorization for the undersigned to represent them in their

individual capacities. See generally 28 C.F.R. 50.15.

6. Accordingly, the undersigned makes a limited appearance

on behalf of the individually-named federal defendants solely for

purposes of seeking this extension of time so as to avoid the

possibility of entry of default against them should the Court

construe this as an individual capacity suit and not summarily

dismiss such individual capacity claims as frivolous.

7. Local Rule 3.01(g) requires that the moving party

shall confer with counsel for the opposing party in a good faith

effort to resolve the issues raised by the motion. Insomuch as

Plaintiffs are proceeding pro se, Local Rule 3.01(g) is

inapplicable.

WHEREFORE, the individual federal defendants request an

extension of time, up to and including thirty (30) days from such

future date as the Court might require them to answer an

individual capacity suit, in which to answer or otherwise respond

to Plaintiffs complaint.

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Date: June 30, 2010 Respectfully submitted,

TONY WESTASSISTANT ATTORNEY GENERAL

By: /s/ Matthew L. FesakMATTHEW L. FESAK

Special Attorney andAssistant United States AttorneyCivil Division310 New Bern Avenue, Suite 800Raleigh, NC 27601-1461Telephone: (919) 856-4530Facsimile: (919) 856-4821E-Mail: [email protected]. Bar No. 35276

CERTIFICATE OF SERVICE

I do hereby certify that I have this 30th day of June, 2010,

served a copy of the foregoing upon the below-listed party

electronically or by placing a copy in the U.S. Mail, addressed

as follows:

Jorge Bussec/o Legal and Consular Department100 N. Biscayne Blvd.Suite 2200Miami, FL 33132

Jennifer Franklin PrescottP.O. Box 845Palm Beach, FL 33480

/s/ Matthew L. FesakAssistant United States Attorney

4

mailto:[email protected]:[email protected]


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UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDAFORT MYERS DIVISION

[TRANSFERRED FROM: SOUTHERN DISTRICT OF FLORIDA, WEST PALM BEACH DIVISION]

JENNIFER FRANKLIN PRESCOTT, DR. JORG BUSSE,

Plaintiffs,

versus Reassigned Case # 2:09-CV-00791-CEH-SPC

ROGER ALEJO; KENNETH M. WILKINSON; JACK N. PETERSON; ROGER

DESJARLAIS; LEE COUNTY, FLORIDA; LEE COUNTY VALUE

ADJUSTMENT BOARD; LORI L. RUTLAND; STATE OF FLORIDA, BOARD

OF TRUSTEES OF THE INTERNAL IMPROVEMENT TRUST FUND; STATEOF FLORIDA, DEPARTMENT OF ENVIRONMENTAL PROTECTION; CHAD

LACH; CHARLES BARRY STEVENS; REAGAN KATHLEEN RUSSELL;

KAREN B. HAWES; ROGER DESJARLAIS; CHARLIE GREEN; BOB JANES;BRIAN BIGELOW; RAY JUDAH; TAMMY HALL; FRANK MANN; UNITED

STATES ATTORNEY(S); SEAN P. FLYNN; E. KENNETH STEGEBY; DAVID P.RHODES; A. BRIAN ALBRITTON; CYNTHIA A. PIVACEK; JOHNSON

ENGINEERING, INC.; STEVEN CARTA; MIKE SCOTT; HUGH D. HAYES;

GERALD D. SIEBENS; STATE OF FLORIDA ATTORNEY GENERAL;WILLIAM M. MARTIN; PETERSON BERNARD; SKIP QUILLEN; TOM

GILBERTSON, RYAN LENGERICH, NEWS PRESS,

Defendants.

PUBLISHED PUBLIC NOTICE OF

JUDICIAL CORRUPTION & FRAUD

____________________________________________________________________________/

PUBLISHED PUBLIC NOTICE OF CORRUPTION, CASE FIXING, AND CRIMES

BY DEF. CROOKED JUDGE CHARLENE E. HONEYWELL, AND IN PARTICULAR,

OF HER IDIOTIC INCOMPREHENSIBLE PUBLIC LANDCLAIM [DOC. # 213, P. 5]

OF PLAINTIFFS LOT 15A, AS CONVEYED IN REFERENCE TO PB 3, PG 25 (1912)

Lot 15A, among other property, was claimed as public land (Resolution 569/875")

(Dkt 5, Ex. 3, p. 9).

PUBLISHED RECORD AS TO PUBLIC CORRUPTION: DOC. # 93-1; 2:2007-cv-00228

___________________________________

/S/JENNIFER FRANKLIN PRESCOTTGovernmental Corruption & Fraud Victim, Plaintiff,pro se

P.O. BOX 845, Palm Beach, FL 33480; T: 561-400-3295______________________________________

/S/JORG BUSSE, M.D., M.M., M.B.A., C.P.M.

Judicial Corruption & Crime Victim; Plaintiff,pro se, [email protected] Cert. Res. Appraiser, Licensed Real Estate Broker, Mortgage Broker, Appraisal Instructor;

ATTACHED EXHIBITS & EVIDENCE OF PUBLIC CORRUPTION: DOC. # 93-1


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Case 2:07-cv-00228-JES-SPC Document 93-1 Filed 08/07/07 Page 1 of 14


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TROY PARNELL

R EGISTERED R EAL ESTATE B ROKER

lA~~~~ Street~~

x~~x~:x~xFORT ~IYERS. I


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-, ~-J.. ~\"

"- ...""""~

STE\NART & KEYES" '-7

\:::::::",,/ATTORNEYS AT LAW

1534 HENDRY STREET

P.O . D RAWER 790

FORT MYERS. FL 33902-0790

WILLIAM L. STEWART

WILLIAM A. KEYES. JR.

(841) 334-7477FAX (841) 334-794

May 1 4, 1997

Mr. Troy Parnell1429 Colonial BoulevardSuite 203

Fort Myers, FL 33907 "

Dear Troy:

You have asked me about the ownership of the accretion to thearea between Lots 2 and 3, Block 14, Second Revised Plat of Cayo

Costa Subdivision and the Gulf of Mexico.

The Plat of this subdivision does not have any dedication of easements for any purpose. It divides the property into numberedblocks with spaces between, which are obviously intended" to beroads. It does, however, have the following wording:

IINOTE

All streets 60' wide

All alleys 20' wideAll lots shown in uniformly square

Blocks 50' x 130' other lots scale measure.1I

The area between the Blocks and the Gulf of Mexico has no

designation, but it is part of the street since all streets leadto it and there is no line indicating the end of the streets.

Our Supreme Court has repeatedly held that when a lot on asubdivision pl'at borders on a street each lot owner owns to thecenter of the street, and, when the street is on the border of thesubdivider's property title of the,lot owner extends to the out~rlimits of the street. .

In the case of Caples v. Taliaferro, 197 So. 861 the SupremeCourt said:

IIThere are also authorities holding that when astreet or highway is laid out wholly on the marginof a grantor' s land, a conveyance of the landsabutting such street or highway carried the fee tothe entire widt h of such street or highway unlessu - - - --- - ..:J"


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,I

~'(

r

.Mr. Troy par'nellMay 14, 1997Pa ge Two

"The more specific question here involved is this:Where a street, way or walk way is laid out whollyon the margin of the grantor's lands, said street,way or walk way being bordered by navigable water,does a conveyance of land abutting on such street,way or walk way, as designated on the plat, carrythe fee to the"width of such street, way orwalkway, together with all riparian rights incidentthereto, unless expressly reserved?

While there is some conflict in the decisions on

this quest, we have reached the conclusion that the

answer should be in the affirmative."

There now appears to be considerable accretion to this streebordering these lots. Since ti tIe to the land under the streebelongs to you the accretion belongs to you. In the case Mexi co Bea ch Cor pora tion v. st. Joe pa per Cor pora tion, 97 So 708, the Court said:

"The common-law rule which vests title to soil

formed along navigable waters by accretion orreliction in owners of abutting land is in force in

Florida."

I have assumed that you did not install groins or othedevices that caused this accretion. In the case of Board Trustees of the Internal Improvement Trust Fund v. Sand KAssociates, Ltd., 512 So.2d 934, our Supreme Court said:

"Waterfront owner who did not participate inconstruction of improvement which, together wi thnatural causes, caused accretion, had vested rightto new lands formed as a result of accretion,

notwithstanding fact that accretions or relictiohsoccurred in part because of artificialimprovements.

Very truly yours,

STEWART & KEYES

~ 1~Will i am . .\---tt---L. Stewar';-\

'.Tr ro - , J......


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TROY PARNELL

REGISTERED REAL ESTATE BROKER

Xx


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OUTHWEST FLORIDA

Writer's Direct Dial Number: (941) 335-2236ARD OF COUNTY COMMISSIONERS

E. Manningict One

glas R. SI. Cernyict Two

Judahict Three

ew W. Coyict Four

E. Albionict Five

d D. Stilwell

ty Manager

es G. Yaeger

nty Attorney

a M. Parker

ntyHearingminer

December 15, 1998

Mr. Troy Parnell3922 Rogers StreetFort Myers, Fl 33901

Re: Second Revised Plat of Cayo Costa Subdivision/Accretion

Dear Mr. Parnell:

I am in receipt of your December 11, 1998 letter on the above. We will atteto review the history of the County Resolution and let you know our position as soas possible. In order to expedite review, I have taken the liberty of forwarding yinquiry to the attention of the County lands Department.

Very truly yours,

2~~County AttorneyJGY/jmxc: J. W. French, Director, Public Works

Karen Forsyth, County landsTimntn\l Innce .6.eeiet~nt 'nllnt\l .6.ttnrnc\l


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\.. -.,r

3922 Rogers Street

Ft. Myers, Florida 33901

February 12,1999

r. James G. Yaegerounty Attorney.O. Box 398

t. Myers, Florida 33902

Re: Second Revised Plat of Cayo CostaSubdivision/Accretion

ear Mr. Yaeger:

enclose a copy of my letter of January 29, 1999 and

lso a copy of your letter of December 15, 1998.

ince it has been two months I would think that your

ounty Lands Department has had time to respond.

t any rate I would appreciate your advising me as tohen I can expect an answer.

nc1s. (2)

Sin;_.~;%lY /. ~...


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. i

. .'. : r~LEECO~TY.'UTHWEST FLORIDA, .,..p

Writer's DirectDialNumber: (941) 335-2236ARD OF COUNTY COMMISSIONERS

E. Manningct One

glas R. SI. Cernyict Two

Judahict Three

ew W. Coy

ict Four

E.Albionict Five

d D. Stilwell

ty Manager

s G. Yaeger

ty Attorney

a M. Parker

ntyHearingminer

February 22, 1999

Mr.Troy Parnell3922 Roger StreetFort Myers, FL 33901

,

Re: Second Revised Plat of Cayo Costa Subdivision

Dear Mr. Parnell:

In response to your correspondence to Mr. Yaeger, the Lee County Attorney'sOffice researched the history of the second revised plat of the Cayo Costa Subdivisionand governing case law on accretion and reliction. Based on this research, we concludethat the public may have a valid claim to the accreted lands on the Gulf side of the CayoCosta Subdivision. Moreover, it is the Board's policy to retain public lands for publicpurposes rather than relinquishthose intereststo private entities. It would be acceptablefor the County to relinquish its interests in this property if the intent is to transfer theproperty in question to the State as part of the CARL Program. Your letter indicates thatthe' Board of Trustees of the Internal ImprovementTrust Fundof the State of Florida hasoffered to purchase the property, but claims that the resolution recorded in the public

records and reflected in the County Commission Minute Books calls into question yourclient's ability to convey fee simple title to the accreted lands. This office wouldrecommend that the Board of County Commissioners release the public's interest in theaccreted land on the condition that the County deed is held in escrow until the closingwith the State. At that time, the deed would be released and available for recordation inthe public records.

If your client is interested in pursuing this course of action, please contact me atyour earliest convenience so that we may discuss the details of this transaction.

f2 i egards

1~;uJr~tif a{f~;v1.

Donna Mafie Collins

Assistant County Attorney

DMC/ampcc: James G. Yaeger, County Attorney

Timot~y Jones, Assistant County Attorney

S:\LU\DMC\DMCL TR\PARNELL.WPD


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Dep~rtment of

Environmental Protection

Jeb Bush

Governor

Marjory Stoneman Douglas Building3900 Commonwealth Boulevard

Tallahassee, Florida 32399-3000

Colleen

Sec

February 2, 2006

Troy Parnell3922 Roters Street

Ft. Myers, FL 33901

RE: Cayo Costa Project, Lee County0.30 Acres

Dear Property Owners:

As agent for the Department of Environmental Protection of the State of Florida, I ,ould like to extencash offer in the amount of $222,000.00, to purchase the above referenced property located in County, Florida. The State of Florida is offering to purchase this property due to its location withiarea that qualifies for State acquisition as part of the State's Florida Forever Program. The DivisioState lands will be the agent for this transaction.

Over the past several years, the State has diligently worked on acquiring property within the Cayo CProject. The state has had the properties appraised numerous times and has made several offeproperty owners. Recent purchases within the last year have caused the Division of State Land

reevaluate its priorities. I was recently informed that the funds and time allocated for this project now limited.

Prior to extending an offer to purchase property, Florida law requires an appraisal to be completed b

independent real estate appraiser. The appraiser is asked to give the market value of the property.

appraisal is confidential, by law, until a contract is signed by the Seller and approved by the DivisioState lands. Your offer was formulated based on such an appraisal.

Please notify me within 60 days of receipt of this offer and I will prepare, for your review,Agreement to purchase your property. It is important for you to know that this is a voluntprogram, and you are under no obligation to sell your property or participate in this program.

Many times owners prefer to donate their property and, in some cases, tax benefits may be realized fa donation. . An accountant, tax professional, or the Internal Revenue Service can provide you additional information. Please let us know if you are interested in donating the property for environme

purposes.

If I may provide additional information or assistance, please do not hesitate to call me at the numbelow. I hope to hear from you soon.

~Si.~cereIY'

c

.

.- ~"-.; -" \ --. ~ !- abrina Carter '-., (.~ c~~k G "--land Acquisition Agent

Bureau of Land Acquisition


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JEFF PARNELL

REAL ESTATE INVESTMENTS, INC.

KELLYROAD

TE 112

FLORIDA33908

LICENSED REAL ESTATE BROKER

(

FA.

K.M. Roesch, Jr. & Anita Roesch15411 NW 46th Ln.

Chi efland, FL 32626

May 15,20

Re: Gulf front lot on Cayo Casta

Dear Mr. & Mrs. Roesch:

My father, Troy Parnell and the estate of William Reynolds own the northern most gulfront lots (lots 1A & 2A). On December 10, 1969 the Lee County Commission voted tdeed itself an area of accretion to the west of certain gulf front lots. The effect of this

makes what was once gulf front lots no longer gulf front. They had no right to do this.We have done much research on this matter. There have been recent rulings by the cou

to support our position that the area of accretion belongs to the gulf front owners. I havhad discussions with attorneys in Miami and Sarasota that specialize in this matter andthey have suggested our case is so strong that we hire a local attorney here in town.

My father is prepared to move ahead with a law suit. Through our correspondence witthe county and discussions with attorneys we believe the county, state or DEP will notcan not do anything until they are sued. However, we will not go ahead without the

support of all the effected lot owners who will benefit from this. I have identified sevelot owners who will benefit from this and included the lots on the enclosed plat.

The estimated cost to file the suit is $15,000. Each owner will most likely have to surv

their lots including the accretion area at a cost of $7,500.each. Even though our case isextremely strong and supported by recent precedence we should be prepared to go to trat an estimated cost of an additional $25,000. This would be a total of approximately$13,215.00 for each lot owner.

The average depth ofthe accretion is about 1,400 feet. Most of the single lots are 50 fewide. That would be about 70,000 square feet more property for each 50 foot lot.Considering the state has offered as much as $18.00 per square foot for gulf front lots,reward for filing the law suit is impressive and the risk appears to be very low.

I am asking that each owner please contact me by telephone and let me know how youfeel about this issue so I can see what kind of consensus we have


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lf Front Lot Owners Effected:

oy Parnell & Reynolds Real Estate, LLP - Lots 2 & 3

sse, Jorg, PO Box 1126, Naples, Fl34106-

Lot 15A

wis, Allen E., Kensington Investments, 347 Congress St., #3A, Boston, MA, ts 23A & 24A

,

ubaie, Salman B 11810 Isle of Palms Dr., Ft. Myers Beach, FL 33931 - Lot 2

ucomm, Ruth K, Tr., 28232 Tung Oil Rd., Kinston, AL 36453 - Lot 28A

rvey, William R, 519 Clubside Dr., Naples, FL 34110 - Lot 67A

1 V""'T A .~-"" 1t:"A11 "THTA,thT_- nL~_'1 ! r'T ,.".,C,.,C T TI


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Lee Coun

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FT. MYERS DIVISION


PRESCOTT,

Plaintiffs,

v. Case No. 2:10-CV-89-CEH-TGW



Defendants.

NOTICE OF APPEARANCE

PLEASE TAKE NOTICE that the undersigned Special Attorney, on

behalf of the United States of America and the following officers

in their official capacities: John Edwin Steele, Sheri Polster

Chappell, Gerald Bard Tjoflat, Richard Jessup, Judge Birch, Judge

Dubina, and Richard A. Lazzara, hereby enters his Notice of

Appearance in this case, and requests that the Court mail all

notices and orders and the like to its undersigned counsel at the

address indicated below.



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FT. MYERS DIVISION


PRESCOTT,

Plaintiffs,

v. Case No. 2:10-cv-89-CEH-TGW



Defendants.

CERTIFICATE OF INTERESTED PERSONSAND CORPORATE DISCLOSURE STATEMENT

I hereby disclose the following pursuant to this Courts

interested persons order:

1. The name of each person, attorney, association ofpersons, firm, law firm, partnership, and corporation that has ormay have an interest in the outcome of this action - includingsubsidiaries, conglomerates, affiliates, parent corporations,publicly-traded companies that own 10% or more of a partys

stock, and all other identifiable legal entities related to anyparty in the case:

a. District Judge John Edwin Steeleb. Magistrate Judge Sheri Polster Chappellc. Circuit Judge Gerald Bard Tjoflatd. Deputy U.S. Marshal Richard Jessupe. Circuit Judge Stanley Birchf. Chief Circuit Judge Joel Dubinag. District Judge Richard A. Lazzara



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CERTIFICATE OF SERVICE

I do hereby certify that I have this 30th day of June, 2010,

served a copy of the foregoing upon the below-listed party

electronically or by placing a copy in the U.S. Mail, addressed

as follows:

Jorg Bussec/o Legal and Consular Department100 N. Biscayne Blvd.Suite 2200Miami, FL 33132

Jennifer Franklin PrescottP.O. Box 845

Palm Beach, FL 33480

/s/ Matthew L. FesakAssistant United States Attorney

3



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def. tony west, assistant attorney general, civil division, doc. ## 28, 27, 25

Documents