Indictment returned in open court as to Amber Rewis Bruey (1) count(s) — USA v. Bruey et al. (Dkt. 3, M.D. Fla.)

Record facts

U.S. District Court for the Middle District of Florida · No. 2:21-cr-00074 · Doc. 3 · 2021-08-25 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT: AUG 25 PM 5: 95
MIDDLE DISTRICT OF FLORIDA -
FORT MYERS DIVISION

UNITED STATES OF AMERICA

V. CASE NO. 2:21-cr-- 14 - J LB- MRM
AMBER REWIS BRUEY and 18 U.S.C. § 1349
ANTHONY JAMES BRUEY 18 U.S.C. § 1343

18 U.S.C. § 1956(h)
18 U.S.C. § 1957

INDICTMENT

The Grand Jury charges:

COUNT ONE
(Conspiracy to Commit Wire Fraud)

A. Introduction

At all times material to this Indictment:

Ji AMBER REWIS BRUEY was a resident of the Middle District
of Florida (“MDFL”) and was married to ANTHONY JAMES BRUEY
(collectively “the BRUEYS”). Together with her husband, AMBER REWIS
BRUEY owned and operated Bruey & Sons, LLC, a Florida corporation
registered to the BRUEYS’ residence that purportedly operated as a
handyman and repair business. She was also the owner and operator of the
purported business entities “Amber Bruey,” “Amber Rewis Bruey,” and

“Beach Bumz Designs.” AMBER REWIS BRUEY was on state probation in
St. Lucie County, Florida case number 2018CF000164.

2. ANTHONY JAMES BRUEY was a resident of the MDFL and
was married to AMBER REWIS BRUEY. ANTHONY JAMES BRUEY co-
owned and co-operated Bruey & Sons, LLC with his wife. He was also the
owner and operator of the purported business entity “Anthony Bruey.”
ANTHONY JAMES BRUEY was on probation in St. Lucie County, Florida
case number 2016CF001832.

3. The United States Small Business Administration (“SBA”) was
an executive-branch agency of the United States government that provided
support to entrepreneurs and small businesses. The mission of the SBA was to
maintain and strengthen the nation’s economy by enabling the establishment
and viability of small businesses and by assisting in the economic recovery of
communities after disasters.

The Paycheck Protection Program

4, The Coronavirus Aid, Relief, and Economic Security
(“CARES”) Act was a federal law enacted in or around March 2020 designed
to provide emergency financial assistance to the millions of Americans who
were suffering the economic effects caused by the COVID-19 pandemic. One

- source of relief provided by the CARES Act was the authorization of

forgivable loans to small businesses for job retention and certain other
expenses, through a program referred to as the Paycheck Protection Program
(“PPP”).

3. To obtain a PPP loan, a qualifying business was required to
submit a PPP loan application, which was signed by an authorized
representative of the business. The PPP loan application required the business
(through its authorized representative) to acknowledge the program rules and
make certain affirmative certifications in order to be eligible to obtain the PPP
loan. In the PPP loan application (SBA Form 2483), the small business
(through its authorized representative) was required to state, among other
things, its: (a) average monthly payroll expenses; and (b) number of
employees. These figures were used to calculate the amount of money the
small business was eligible to receive under the PPP. In addition, businesses
applying for a PPP loan were required to provide documentation showing
their payroll expenses. Individuals who operated under a sole proprietorship
or as an independent contractor or eligible self-employment individual were
also eligible to apply for a PPP loan.

6. A PPP applicant was required to disclose whether the applicant
(if the loan was for an individual) or an owner of the applicant business had
been convicted of a felony or had served a term of probation within the last

five years.
7. PPP loan applications were processed by a participating lender. If
a PPP loan application was approved, the participating lender funded the PPP
loan using its own monies, which were 100% guaranteed by the SBA. Data
from the application, including information from the borrower, the total
amount of the loan, and the listed number of employees, was transmitted by
the lender to the SBA in the course of processing the loan.

8. PPP loan proceeds were required to be used for certain
permissible expenses, including payroll costs, mortgage interest, rent, and
utilities. Under the applicable PPP rules and guidance, the interest and
principal on the PPP loan was eligible for forgiveness if the business spent the
loan proceeds on these expense items within a designated period of time and
used a certain portion of the loan towards payroll expenses.

The Economic Injury Disaster Relief Program

9. The Economic Injury Disaster Loan (“EIDL”) program was an
SBA program that provided low-interest financing to small businesses, renters,
and homeowners in regions affected by declared disasters.

10. The CARES Act authorized the SBA to provide EIDLs of up to
$2 million to eligible small businesses experiencing substantial financial
disruption due to the COVID-19 pandemic. In addition, the CARES Act

authorized the SBA to issue advances of up to $10,000 to small businesses
within three days of applying for an EIDL. The amount of the advance was
determined by the number of employees the applicant certified having. The
advances did not have to be repaid.

11. To obtain an EIDL and advance, a qualifying business had to
submit an application to the SBA and provide information about its operation,
such as the number of employees, gross revenues for the 12-month period
preceding the disaster, and cost of goods sold in the 12-month period
preceding the disaster. In the case of EIDLs for COVID-19 relief, the 12-
month period was that preceding January 31, 2020. An EIDL applicant was
required to disclose whether the applicant had been convicted of a felony or
had served a term of probation within the last five years. The applicant also
had to certify that all the information in the application was true and correct to
the best of the applicant’s knowledge.

12. EIDL applications were submitted directly to the SBA. The
amount of the loan, if the application was approved, was determined based, in
part, on the information provided by the applicant about employment,
revenue, and cost of goods, as described above. Any funds issued under an
EIDL or advance were issued directly by the SBA. EIDL funds could be used
for payroll expenses, sick leave, production costs, and business obligations,

such as debts, rents, and mortgage payments. If the applicant also obtained a
loan under the PPP, the EIDL funds could not be used for the same purpose
as the PPP funds.

PPP Lenders

13. Lender 1 was a non-bank real estate and small business lender
based in New York, New York. Lender 1 participated in the SBA’s PPP as a
lender and approved and serviced PPP loans on behalf of Lender 2.

14. Lender 2 was a federally-insured financial institution based in
Phoenixville, Pennsylvania that participated in the SBA’s PPP as a lender and
was authorized to lend funds to eligible borrowers under the terms of the PPP.

15. Lender 3 was a federally-insured financial institution based in
Salt Lake City, Utah that participated in the SBA’s PPP as a lender and was
authorized to lend funds to eligible borrowers under the terms of the PPP.

16. Lender 4 was a federally-insured financial institution based in
San Antonio, Texas that participated in the SBA’s PPP as a lender and was
authorized to lend funds to eligible borrowers under the terms of the PPP.

17. Company 1 was a publicly traded company that processed credit
card payments, provided retail point-of-sale payment platforms, and offered
small-business lending. Company 1 was based in San Francisco, California.
Company 1 participated in the SBA’s PPP by, among other things, acting as a

service provider between small businesses and certain banks, including Lender
3. Small businesses seeking PPP loans could apply through Company 1 for
PPP loans. Company 1 would review the loan applications. If a loan
application received by Company 1 was approved for funding, a partner bank,
such as Lender 3, disbursed the loan funds to the applicant.

Bank Accounts Controlled by the Defendants

18. Banks 1, 2, and 3 were federally-insured financial institutions
while Bank 4 was a financial technology company that provided banking
services and partnered with financial institutions that were insured by the
FDIC.

19. THE BRUEYS, individually and together, controlled and
maintained the following financial accounts:

a. A checking account ending in -9936 at Bank 1 in the name
of “Bruey & Sons” (“Bank 1 account ending in -9936”), with AMBER -
REWIS BRUEY as the sole signatory;

b. A checking account ending in -8239 at Bank 2 in the name
of “Bruey & Sons LLC” (“Bank 2 account ending in -8239”) with AMBER
REWIS BRUEY as the sole signatory;

C. A checking account ending in -8067 at Bank 3 in the name
of “Amber Bruey” (“Bank 3 account ending in -8067”) with AMBER REWIS

BRUEY as the sole signatory;
d. Achecking account ending in -5823 at Bank 3 in the name
of “Amber Bruey” (“Bank 3 account ending in -5823”) with AMBER REWIS
BRUEY as the sole signatory;

e. A checking account ending in -3607 at Bank 4 in the name
of “Amber Bruey” (“Bank 4 account ending in -3607”) with AMBER REWIS
BRUEY as the sole signatory;

f. The Bank 1 account ending in -9936 with ANTHONY
JAMES BRUEY as the sole signatory;

g. The Bank 2 account ending in -8239 with ANTHONY
JAMES BRUEY as the sole signatory;

h. A checking account ending in -5576 at Bank 4 in the name
of “Anthony Bruey” (“Bank 4 account ending in -5576”) with ANTHONY
JAMES BRUEY as the sole signatory.

B. The Conspiracy
20. Beginning on an unknown date, but no later than in or around
April 2020, and continuing through and including the date of this Indictment,
in the Middle District of Florida, and elsewhere, the defendants,

AMBER REWIS BRUEY and
ANTHONY JAMES BRUEY,

did knowingly and willfully combine, conspire, confederate and agree, with one

another and with others, both known and unknown to the Grand Jury, to
commit wire fraud, in violation of 18 U.S.C. § 1343.
C. Manner and Means of the Conspiracy
21. The manner and means by which the conspirators sought to
accomplish the objects of the conspiracy included, among others, the
following:

a. It was part of the conspiracy that the conspirators would
and did engage in a scheme to obtain money from the SBA and PPP lenders
by submitting false and fraudulent EIDL and PPP loan applications to the
SBA, Lender 1, Lender 4, and Company 1.

b. It was further part of the conspiracy that conspirators
would and did make and cause to be made materially false and fraudulent
statements to the SBA in EIDL applications, including false and fraudulent
representations regarding the dates of operation of the loan applicant, falsely
stating the number of persons employed by the loan applicant, and falsely
representing the applicant’s gross revenues and cost of goods sold.

c. It was further part of the conspiracy that conspirators
would and did make and cause to be made materially false and fraudulent
statements to Lender 1, Lender 4, and Company 1 in PPP loan applications,
including false and fraudulent representations regarding the applicant’s

average monthly payroll.
d. It was further part of the conspiracy that conspirators
would and did make and cause to be made materially false and fraudulent
statements to the SBA, Lender 1, Lender 4, and Company I in EIDL and PPP
loan applications, including false and fraudulent representations that the
applicant had not been convicted of a felony or served a term of probation in
the last five years.

e. It was further part of the conspiracy that conspirators
would and did submit and cause the submission of materially false and
fictitious documents to the SBA, Lender 1, Lender 4, and Company 1 in
support of their fraudulent EIDL and PPP loan applications, including false
and fictitious federal income tax documents.

f. It was further part of the conspiracy that conspirators
would and did falsely certify that the PPP funds acquired from the requested
loans would be used to retain workers and maintain payroll or make mortgage
payments, lease payments, and utility payments on behalf of the applicants.

g. It was further part of the conspiracy that conspirators’
materially false, fraudulent, and misleading representations would and did
cause the SBA, Lender 1, Lender 4, and Company | to approve at least 6
EIDL applications and 6 PPP loan applications, resulting in the SBA, Lender

2, Lender 3, and Lender 4 depositing approximately $881,058.35 in EIDL and

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PPP funds into accounts controlled by the conspirators.

h. It was further part of the conspiracy that the conspirators
would and did open and cause the opening of bank accounts at Bank 2, Bank
3, and Bank 4 for the purpose of receiving EIDL and PPP proceeds.

i. It was further part of the conspiracy that conspirators
would and did share in, use, and cause EIDL and PPP funds to be used for
unauthorized purposes and for their own personal enrichment, including
purchases of a residence in North Carolina, a 2019 GMC Yukon SUV, a 2020
Honda Talon, and a $23,566 restitution payment for criminal court case
number 2018CF000164.

j. It was further part of the conspiracy that conspirators
would and did perform acts and make statements to promote and achieve the
objects of the conspiracy and to misrepresent, hide, and conceal, and cause to
be misrepresented, hidden and concealed, the purpose of the conspiracy and
the acts committed in furtherance thereof.

In violation of 18 U.S.C. § 1349.

COUNTS TWO THROUGH ELEVEN
(Wire Fraud)

A. Introduction
1. The Grand Jury hereby realleges Paragraphs 1 through 19 of

Count One of this Indictment and incorporates such paragraphs by this

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reference as though fully set forth herein.
B. The Scheme and Artifice
2. Beginning on an unknown date, but no later than in or around
- April 2020, and continuing through the present, in the Middle District of
Florida and elsewhere, the defendant,
AMBER REWIS BRUEY,
knowingly devised and intended to devise a scheme and artifice to defraud,
and to obtain money and property by means of materially false and fraudulent
pretenses, representations, and promises.
C. Manner and Means of the Scheme and Artifice
3. The manner and means of the scheme and artifice are set forth in
Paragraph 21 of Count One of this Indictment, the allegations of which are
realleged and incorporated by reference as if fully set forth herein.
D. Execution of the Scheme and Artifice
4. On or about the dates set forth below, in the Middle District of
Florida and elsewhere, the defendant,
AMBER REWIS BRUEY,
for the purpose of executing the scheme and artifice described above,
transmitted and caused to be transmitted by means of wire communication in

interstate and foreign commerce the writings, signs, signals, pictures, and

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sounds described below, each transmission constituting a separate count:

COUNT

DATE OF

WIRE

_ INTERSTATE WIRE TRANSMISSION

TWO

April 2, 2020

Electronic transmission of fraudulent EIDL
application in the name of Bruey and Sons
from the MDFL to the SBA’s servers
located outside the State of Florida

THREE

April 3, 2020

Electronic transmission of fraudulent EIDL
application in the name of Beach Bumz
Designs from the MDFL to the SBA’s
servers located outside the State of Florida

FOUR

April 12, 2020

Electronic transmission of fraudulent PPP
loan application in the name of Amber
Bruey from the MDFL to Lender 1’s servers
located outside the State of Florida

May 4, 2020

Electronic transmission of fraudulent PPP
loan application in the name of Amber
Bruey from the MDFL to Lender 4’s servers
located outside the State of Florida

SIX

May 5, 2020

Electronic transmission of fraudulent PPP
loan application in the name of Amber
Rewis Bruey from the MDFL to Lender 4’s
servers located outside the State of Florida

SEVEN

May 6, 2020

Electronic transmission of fraudulent PPP

loan application in the name of Bruey and

Sons from the MDFL to Lender 4’s servers
located outside the State of Florida

EIGHT

May 15, 2020

Electronic transmission of fraudulent PPP
loan application in the name of Amber
Bruey from the MDFL to Company 1’s

servers located outside the State of Florida

May 18, 2020

Electronic transmission of fraudulent EIDL
application in the name of Amber Bruey
from the MDFL to the SBA’s servers

located outside the State of Florida

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TEN June 16, 2020 Electronic transmission of fraudulent EIDL
application in the name of Amber Bruey
from the MDFL to the SBA’s servers
located outside the State of Florida
ELEVEN | June 24, 2020 Electronic transmission of fraudulent EIDL
application in the name of Bruey & Sons
from the MDFL to the SBA’s servers
located outside the State of Florida

In violation of 18 U.S.C. §§ 1343, 1349, and 2.

COUNTS TWELVE AND THIRTEEN
(Wire Fraud)

A. Introduction

1. The Grand Jury hereby realleges Paragraphs | through 19 of
Count One of this Indictment and incorporates such paragraphs by this
reference as though fully set forth herein.

B. The Scheme and Artifice

2. Beginning on an unknown date, but no later than in or around
April 2020, and continuing through the present, in the Middle District of
Florida and elsewhere, the defendant,

ANTHONY JAMES BRUEY,

knowingly devised and intended to device a scheme and artifice to defraud,
and to obtain money and property by means of materially false and fraudulent

pretenses, representations, and promises.

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C. Manner and Means of the Scheme and Artifice
3. The manner and means of the scheme and artifice are set forth in
Paragraph 21 of Count One of this Indictment, the allegations of which are
realleged and incorporated by reference as if fully set forth herein.

D. Execution of the Scheme and Artifice

4. On or about the dates set forth below, in the Middle District of
Florida and elsewhere, the defendant,
ANTHONY JAMES BRUEY,
for the purpose of executing the scheme and artifice described above,
transmitted and caused to be transmitted by means of wire communication in
interstate and foreign commerce the writings, signs, signals, pictures, and

sounds described below, each transmission constituting a separate count:

COUNT | DATE OF WIRE | INTERSTATE WIRE TRANSMISSION

TWELVE April 26, 2020 Electronic transmission of fraudulent PPP
loan application in the name of Anthony
Bruey from the MDFL to Company 1’s
servers located outside the State of Florida

THIRTEEN |} May 19, 2020 Electronic transmission of fraudulent
EIDL application in the name of Anthony
Bruey from the MDFL to the SBA’s
servers located outside the State of Florida

In violation of 18 U.S.C. §§ 1343, 1349, and 2.

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COUNT FOURTEEN
(Conspiracy to Commit Money Laundering)

A. Introduction

1. The Grand Jury hereby realleges Paragraphs 1 through 19 of
Count One of this Indictment and incorporates such paragraphs by this
reference as though fully set forth herein.

B. The Conspiracy

2. Beginning on an unknown date, but no later than in or around
April 2020, and continuing through the present, in the Middle District of
Florida and elsewhere, the defendants,

AMBER REWIS BRUEY and
ANTHONY JAMES BRUEY,

did knowingly combine, conspire, and agree with each other and other
persons known and unknown to the Grand Jury to commit certain offenses
against the United States, in violation of 18 U.S.C. § 1957, to wit: to
knowingly engage and attempt to engage in monetary transactions in and
affecting interstate and foreign commerce, in criminally derived property of a
value greater than $10,000.00, which property was, in fact, derived from a
specified unlawful activity, namely, wire fraud, in violation of 18 U.S.C.

§ 1343.

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C. Manner and Means
3. The Grand Jury realleges Paragraph 21 of Count One of this
Indictment and incorporates such paragraph by this reference as though fully
set forth herein.
All in violation of 18 U.S.C. § 1956(h).

COUNTS FIFTEEN AND SIXTEEN
(Illegal Monetary Transactions)

A. Introduction
1. The Grand Jury hereby realleges Paragraphs 1 through 19 and 21
of Count One of this Indictment and incorporates such paragraphs by this
reference as though fully set forth herein.
B. Offense
2. On or about the dates listed below, in the Middle District of
Florida and elsewhere, the defendants,

AMBER REWIS BRUEY and
ANTHONY JAMES BRUEY,

did knowingly engage and attempt to engage in the monetary transactions
described below, and aided and abetted each other and others in engaging in
the monetary transactions described below, in and affecting interstate and
foreign commerce, in criminally derived property of a value greater than

$10,000.00, which property was, in fact, derived from a specified unlawful

17
activity, namely, wire fraud, in violation of 18 U.S.C. § 1343, specifically:

COUNT DATE MONETARY TRANSACTION

$29,214.93 check from the Bank 1

June 5, 2020 account ending in -9936 issued to Sun
FIFTEEN Sports Cycle for the purchase of a Honda
Talon and Yamaha dirt bike.

$211,457.57 wire transfer from the Bank 3
August 27, 2020 | account ending in -5823 to a law firm for
SIXTEEN the purchase of a residence in North
Carolina.

In violation of 18 U.S.C. §§ 1957 and 2.

COUNTS SEVENTEEN AND EIGHTEEN
(Illegal Monetary Transactions)

A. Introduction

1. The Grand Jury hereby realleges Paragraphs 1 through 19 and 21
of Count One of this Indictment and incorporates such paragraphs by this
reference as though fully set forth herein. |

B. Offense

2. On or about the dates listed below, in the Middle District of

Florida and elsewhere, the defendants,
AMBER REWIS BRUEY,

did knowingly engage and attempt to engage in the monetary transactions
described below, and aided and abetted others in engaging in the monetary

transactions described below, in and affecting interstate and foreign

18
commerce, in criminally derived property of a value greater than $10,000.00,
which property was, in fact, derived from a specified unlawful activity,

namely, wire fraud, in violation of 18 U.S.C. § 1343, specifically:

COUNT ‘DATE MONETARY TRANSACTION

$23,566 cashier’s check from the Bank 1
July 22,2020 | account ending in -9936 issued to JPay
SEVENTEEN for the payment of restitution for
criminal case number 2018CF000164.

$49,688.55 electronic funds transfer to
August 11, 2020 | Carvana from the Bank 1 account
EIGHTEEN ending in -9936 for the purchase of a
2019 GMC Yukon SUV.

In violation of 18 U.S.C. §§ 1957 and 2.

FORFEITURE

1. The allegations contained in Counts One through Eighteen are
incorporated by reference for the purpose of alleging forfeiture pursuant to 18
U.S.C. §§ 981(a)(1)C and 982(a)(1), and 28 U.S.C. § 2461(c).

2. Upon conviction of a violation of 18 U.S.C. § 1343, ora
conspiracy to violate 1343, in violation of 18 U.S.C. § 1349, the defendants,

AMBER REWIS BRUEY and
ANTHONY JAMES BRUEY,

shall forfeit to the United States, pursuant to 18 U.S.C. § 981(a)(1)(C) and 28
U.S.C. § 2461(c), any property, real or personal, which constitutes or is

derived from proceeds traceable to the offense.

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3. Upon conviction of a violation of 18 U.S.C §§ 1956 or 1957, ora
conspiracy to violate 18 U.S.C §§ 1956 or 1957, the defendants,

AMBER REWIS BRUEY and
ANTHONY JAMES BRUEY,

shall forfeit to the United States, pursuant to 18 U.S.C. § 982(a)(1), any
property, real or personal, involved in such offense, or any property traceable
to such property.

5. The property to be forfeited includes, but is not limited to, the
following:

a. an order of forfeiture in the amount of approximately
$881,058.35, which represents the proceeds obtained from
and involved in the offenses;

b. a 2019 GMC Yukon XL, VIN: 1GKS2GKCXKR353450,
registered to and owned by Amber Bruey;

Cc. a 2021 Chevrolet Spark LS, VIN:
KL8CB6SA8MC704136, registered to and owned by
Anthony Bruey;

d. a 2020 Honda Talon, VIN: IHFVE06A1L4001815, titled
to and owned by Anthony Bruey;

e. a 2020 Polaris RZR, VIN: RF3YAV179LT035419, titled
to and owned by Anthon Bruey; and

f. Real property located at 114 Kemp Lane, Hertford, North
Carolina 27944, including all improvements thereon and
appurtenances thereto, the legal description for which is as
follows:

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BEGINNING AT A POINT on the southern side of the
Perquimans River, said point being at the northeastern
comer of the Skinner property, thence in a southwestern
direction along a fence, being the Skinner line, 295 feet to
a chopped oak, thence in a southeasterly direction, a line
parallel with said Perquimans River, 178 feet to a chopped
oak; thence in a northerly direction, a straight line to a
chopped gum, said gum being at the break of a swamp;
and thence continuing on in a straight line from said oak
and gum, to the Perquimans River; thence along the run of
said river in a northwesterly direction back to the POINT
OF BEGINNING. For reference and chain of title see
Deed Book 109 Page 330 of the Perquimans County

Registry.

ALSO CONVEYED HEREBY is a right of way to said
above described property, across property of now or
formerly R.E. Mathews, the same being 30 foot wide right
of way and running from property of said Mathews,
hitting the outer edge of the swamp located on the
southeastern side of said above described property.

Designated Map No. 2-D061-0017-HB (PIN No. 7868-24-
9352) in the Perquimans County Tax Office.

6. If any of the property described above, as a result of any act or
omission of the defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third
party,
Cc. has been placed beyond the jurisdiction of the Court;

d. has been substantially diminished in value; or

21
e has been commingled with other property which cannot be
divided without difficulty,
the United States shall be entitled to forfeiture of substitute property under the
provisions of 21 U.S.C § 853(p), as incorporated by 18 U.S.C § 982(b)(1) and

28 U.S.C. § 2461(c).

A TRUE BILL,

Ci -—

Forepérson

KARIN HOPPMANN
Acting United States Attorney

By, _@- Qherse
Trenton J. Reichling
Assistant United States Attorney

1 YM. Orne

Ghrs M. Casas
Assistant United States Attorney
Chief, Fort Myers Division

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FORM OBD-34
August 21 No.

UNITED STATES DISTRICT COURT
Middle District of Florida
Fort Myers Division

THE UNITED STATES OF AMERICA
VS.

AMBER REWIS BRUEY and
ANTHONY JAMES BRUEY

INDICTMENT

Violations: 18 U.S.C. § 1349,
18 U.S.C. § 1343,
18 U.S.C. § 1956(h), and
18 U.S.C. § 1957.

A true bill,

Foreperson

Filed in open court this 25th day
of August, 2021.

Clerk

Bail $

GPO 863 525

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