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Acco Pressboard Classification FoldersPressboard Classification Folders
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Acco Pressboard Classification Folders - Classification folder functions as the perfect file organizer, complete with tabs on the cover and dividers for easy titling. Durable, classification folders are ideal for keeping important documents in place. Each folder is made of 25 point recycled pressboard with expandable, color-matched Tyvek gussets. Two partitions create six filing surfaces - each with a 1 size fastener - to maximize your filing opportunities. Each folder expands 3" to hold a thick stack of your important documents."
- Sectioned for efficient organization.
- Heavy-duty pressboard construction.
- Tyvek® reinforced, expandable file gusset provides maximum durability.
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- Durable Construction
- Easy To Label
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- Long Term Storage
Comments about Acco Pressboard Classification Folders:
We use these legal folders in the office quite frequently - the color helps distinguish them from other types. The files are used a lot and hold up well to the use as well as quantity of pages filed.
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Delivery is always promt and in good condition.
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Color Life Presstex Top-Tab Folders with fasteners feature a reinforced expandable Tyvek gusset. Made of durable acrylic-coated 15 point cover stock. Six-part file has two center leaves. Top-tab folders contain 50 percent recycled material.Brightly colored divided business folders are perfect ...
Heavy-duty classification folders feature patent-pending SafeShield Coated Fastener Technology to help prevent paper tears, finger cuts and excessive fastener crinkling. SafeShield adds protection for papers and fingers while also reducing fastener crinkling. Fasteners on front and back panels and dividers ...
Heavy-duty, Presstex folder holds more files to function as the ideal business folder. Presstex is specially coated to be moisture-resistant and tear-resistant. Handy partitions keep records separated, and fasteners keep papers from getting lost. Tyvek-reinforced, expandable file gusset provides maximum ...


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Top 10 reasons why you should write for Infobarrel
- Love: You love to write and can write interesting articles. You feel you have something worthwhile to share with other members of infobarrel and love to see you articles published on the Internet
- Creating an article: This is so easy to do. Everything you need to create your articles is presented on the same page. The text editing in Infobarrel has more features than Hubpages.
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subset: commoncrawl


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What is the travel distance and flight duration time from Philadelphia to Prague?
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HZ travel tools
Distance calculator
> From Philadelphia to Prague
Distance from Philadelphia to Prague is:
4152.6 Miles
(6682.9 Kilometers / 3606.1 Nautical Miles)
Approximate travel time from Philadelphia, Pennsylvania to Prague, Czech Republic is: 8 hrs, 37 mins
Distance and flight duration time from Philadelphia International Airport to Vaclav Havel Airport Prague
Time difference between Philadelphia and Prague
Please note: this page displays the approximate flight duration time for a non-stop flight. The actual travel time may differ depending on the type and speed of the aircraft.
Philadelphia coordinates:
40° 00' North
75° 09' West
Prague coordinates:
50° 05' North
14° 25' East
Search flights from Philadelphia, Pennsylvania to Prague, Czech Republic
Cities near Prague:
Air distance from Philadelphia to St. Polten
Air distance from Philadelphia to Potsdam
Airports in Philadelphia:
Philadelphia International Airport (PHL)
about 11 km southwest of Philadelphia.
Northeast Philadelphia Airport (PNE)
about 5 miles northeast of Philadelphia.
Airports in Prague:
Vaclav Havel Airport Prague (PRG)
about 10 km (6.2 mi) west of Prague.
Copyright ©2016 Happy Zebra Travel Tools
How far is Prague from Philadelphia?


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UK Tings: Kano, Wiley, Taiwah
by Winston "Stone" Ford
Kano – Hustler
VIDEO NSFW (The nipples are blurred out, but still…)
I already think that this video is one of the best of the year, but could this take this the best beat of the year honors as well? Kano's album 140 Grime Street dropped in the UK last September and some over there are billing this as the London's answer to Tha Carter III. If you don't know what the video is referring to, then I suggest you re-watch New Jack City. I think this is probably one of the best videos of the year. What do y'all think?
Wiley – Cash In My Pocket
Wiley – Cash In My Pocket
Last time we heard from Wiley, the dude was calling his record company out on the Internets. Apparently, Wiley and The Man hugged it out, because his album, See Clear Now drops in the UK in January. His track Cash In My Pocket just dropped on the Internets (via DDoff) featuring Daniel Merriweather, and although the beat is dope, the hook is one of the most annoying things I've heard this year. Seriously, I can't stand Autotune, but they need to throw some on this track.
Wiley describes See Clear Now as an "official" pop record, featuring collaborations with Lily Allen, Hot Chip, and Mark Ronson. I take it grime is officially dead, however, I'm curious to see how this album turns out.
Taiwah – Every Step
Sorry people, I have a MAD late pass with this one. If you don't know, Taiwah is a South London based soul artist who is dropping some killer tunes right now. The 21 year old songstress is best known for working with Mark Ronson (who seems to be the Lil' Wayne of the UK producer game right now), on his Versons LP that dropped last year though I wasn't really feeling her contribution. However, her EP, titled In Jodi's Bedroom, is simply amazing. It's vaulting up my best album list as I type.
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Angels Among Us Animal Rescue announces a new Angel:
Meet Jack!
Jack is a super sweet adult shepherd mix. He is about 8 years old and looking to spend his adult and senior years in a forever home! He gets along great with dogs and kids. We have not cat tested him. He is healthy and has a good energy. He would love to go for walks or play in the yard with you. Jack is neutered and up to date on his shots. He is ready to leave his foster and move right in!!
Jack is currently in TN but will be transported to New England for adoption. AAUAR is courtesy listing Jack for Guardian Angels Pet Rescue (GAPR) of Memphis, TN. The adoption donation is $350 which includes a health certificate, transport north and a micro chip.
*Unless stated otherwise, all dogs will be spayed or neutered, on flea/tick product and heart worm prevention medicine (if older than 5 months) and micro chipped prior to adoption.
*Please note that while we do our best to accurately state the breed or breed mix of a dog, we often have very limited information to draw from. Identifying the breed without pedigrees and information on heritage can be very challenging!
Piper (Fostered in New England)
Copper (Fostered in New England)
Thank You!
Your message has been sent to Angels Among Us Animal Rescue.
You'll receive a copy, too, at to help you keep track of which pets you've inquired about, and which shelters and rescues you've emailed.
NOTE: Some shelters have physical locations you can visit; some of these shelters may only have pets for a limited time, so please do not wait for a reply—just go visit the shelter! Other organizations are rescue groups run by busy volunteers who may take a while to reply. You can find information about the shelter or rescue group caring for this pet, and their adoption procedures, on the pet's details page on Adopt-a-Pet.com.
Contact this Rescue Group about Jack (GAPR/TN foster) again.


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I guess I'll get things started.
5. Super Mario Bros. - Okay, this movie really isn't good at all, but I've always kind of viewed it as "so bad it's good". Some of the references are worth a chuckle.
4. Street Fighter Alpha: the Animation - This is a decent watch. It starts out great, but gets wierdly creepy towards the end.
3. Final Fantasy: the Spirits Within - Outside of the token "Cid" character, I honestly don't know what this has to do with FF, but the CGI was great for the time, and it was decent.
2. Voltage Fighter Gowcaizer - This anime film captures all the campy fun of a fighting series wonderfully (beware, there's lots of fanservice though).
1. Fatal Fury: the Motion Picture - Another anime film that captures the campy fun of the fighting series perfectly.
Avatar: Kagero (FE Fates: Birthright)
Currently Playing: Front Mission Evolved
Recently Beat: Metroid Prime: Blast Ball, Dokuro, Halo Anniversary, Monument Valley


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5.0 stars 56 totalReview Taylor Randolph
Posted by Glenn Z
Taylor's firm helped me out with a financial issue and everything went very smoothly. My situation changed after my initial meeting with Taylor, making things more difficult for them, but they were able to handle it and everything still turned out great. Most of my contact was through Taylor's paralegal Leo and he was always very responsive whether it be by phone or email.
In the end, my expectations were exceeded as the outcome was better than initially expected. I highly recommend Taylor's firm.
Posted by Rob
Hard times hit and my family needed help. Randolph Law firm was there to help. Great no b/s consult started our process and after a filling out the required paperwork they walked us through the process from start to finish, the staff were excellent in returning messages and keeping us updated on our case, we weren't passed from staff member to staff member when we called i only delt with one person for all matters and this ensured the left hand knew what the right was doing.
During our case attorney Randolph was unable to attend our court appearances for extenuating circumstances but ensured our case was handed to a competent stand in attorney who did excellent work.
If you require the services of Randolph Law Firm i would highly recommend them as you will get a firm interested in helping you resolve your legal matter in their full capacity.
Posted by David
My wife and I hired Taylor L Randolph because we had some back taxes that we were never going to get rid of. There is a young man name Leo who is awesome, he worked with us, explained everything to us and was always there for us when we had a question. Leo handled our problem and my wife and I couldn't be happier. Thank you Taylor and Leo your law firm did a outstanding job.
Posted by Robyn
Retained the Firm to secure our home. The entire staff are kind and professional. Taylor and Mariya were always available and responded quickly and we never had any doubt they wouldn't come to resolution with them by our side.
Posted by PAUL
I have had dealings with two different law firms over the last 4 years. One was bad, and the one after them was actually terrible. They don't return phone calls or even acknowledge E-mails, so you never know where you stand. The level of frustration I have felt is through the roof.
So, when I was contacted about a tax matter, I decided I was going to do my due diligence, and find the best attorney in the Las Vegas area. I didn't care about them having a great commercial. The last guys have a great one, but I never got to meet with either of the partners, and was treated badly by the "paralegals" in their firm I was forced to work with.
When Attorney Randolph came to my attention, I was duly impressed by his legal accomplishments, and the very high standing attributed to him by his peers. He is not only one of the best tax attorneys in Las Vegas, it turned out he is considered one of the best in the entire USA!
Ok, so, my first meeting with him. Was it actually going to be with him, or with one of his employees? I was pleasantly surprised to find that the meeting was with him, the guy I actually came there hoping to meet with. How refreshing!
He was kind, intelligent and compassionate. Had I accidentally walked into the office of a sociologist? This man didn't act like we were on the clock. He didn't treat me like cattle that needed to be herded through the system. He was thorough. We talked. We laughed. He totally understood my situation. When the interview was over, he looked me directly in the eye, and said he felt he could help. And, oh my goodness, he has lived up to his word! He is decisive and moves quickly. I am already getting results and tremendous relief from the actions he has taken. I feel like a thousand pounds has been lifted off my chest.
E-mails? Answered instantly, even on Saturdays! Phone calls? Answered and acknowledged immediately. You ALWAYS know what's going on, and Attorney Randolph and his crew watch over you like you are family.
I say "crew" with a chuckle The "crew" that I have the pleasure of working with sometimes is one magnificent fellow by the name of Leo Collins III. Attorney Randolph meets with you, hashes out what needs to happen, then sends his able assistant Leo in with whatever paperwork needs to be signed, or verbal instructions that need to be followed. Leo is also a down to earth, for real person, who is obviously in your corner and on your side.
I am currently 63 years of age. I have dealt with attorneys from many different disciplines, from entertainment attorneys to the latest Workman's Comp disappointments. Never, have I worked with an attorney that I have ended up respecting, appreciating, and being thankful for. It took a lifetime, but I finally found him. Attorney Randolph is the man and you'd be shooting yourself in the foot if you approached any other tax attorney first.
And if you think this review is paid for, think again. I am speaking to your directly from the heart.
You can contact me personally if you like, at email@example.com, and I'll gladly tell you individually, what I am saying to everyone else in this review.
If you call and get Attorney Randolph, or Leo III, tell them that Paul Allen says, "Hey."
Posted by Greg M
What can I saw other than fantastic! Before I met with Taylor and his team I thought I had no hope but after that first consultation I knew I had somebody working for my best interests. The process was long, because of the IRS not Randolph Law firm, but I was given updates and knew where I was at in the process all the time. When the final decision was made it was far better than I every expected. I would highly recommend Taylor and his team for any tax issues anyone may be having. A true 10 out of 10! Thanks Taylor!
Anonymous review posted on
Randolph Law Firm has been a fantastic law firm to work with. I owned a small business and was forced to close the business, file bankruptcy and foreclose on my home in 2009. We hired Taylor to guide us through the bankruptcy and foreclosure process. He was awesome to work with and were very happy with the results. Recently, I have been attempting to work with the Nevada Department of Taxation to resolve a tax debt that stemmed from the small business. When I realized I needed Legal assistance, I did not hesitate to contact Randolph Law Firm again. Taylor went above my expectations in obtaining a full release of my Nevada State Tax debt. I attempted to work with the state on my own but was not successful, by hiring Taylor I was able to get results that I would not have been able to get on my own. I would highly recommend the Randolph Law Firm.
Anonymous review posted on
Huge thank you to Taylor Randolph and his associates for handling my bankruptcy in a professional manner. My first meeting was with Taylor and he made me feel at ease with my financial decision to file bankruptcy. Leo was always available to answer any questions and keep me at ease during the process. Taylor was by my side at the final hearing again making me feel at ease.
Posted by HL
Attorney Randolph is amazing. I hired him for two complex cases that other professionals had botched which left me on the verge of financial ruin. Attorney Randolph and his staff met with me and gave me a realistic assessment of my legal recourse. I am relieved to say that they brought both cases to successful conclusions and far exceeded my expectations. Besides being a highly competent attorney, the entire team is genuine and compassionate - something you do not find very often. They were always keeping me updated on developments as warranted and available to answer any questions.
They were a Godsend.
Posted by Phillip
Although we are in the early stages right now every obstacle today has been addressed. All phone calls have been return and all probably take me an address. This attorney's office seem to be the right choice for us.


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Grandpa's Pasta Salad
Total Time
Prep 15 mins
Cook 13 mins
My grandfather created this recipe for my family on thanksgiving. When I tried it I had to make all the time.I'ts great!
Ingredients Nutrition
- 1 lb small no yolk noodles
- 1 peeled and diced cucumber
- 2 roma tomatoes, diced
- 1⁄2 cup finely diced onion
- 1⁄4 cup chopped black olives
- 1 cup fat-free mayonnaise or 1 cup regular mayonnaise
- 2 tablespoons extra virgin olive oil
- 2 tablespoons balsamic vinegar
- 1⁄2 teaspoon salt, to taste
- 1⁄2 teaspoon pepper, to taste
- 1 teaspoon sugar
- Cook pasta according to package directions.
- In a large mixing bowl, combine pasta, cucumber, tomatoes, onion, and olives.
- In a small bowl combine mayonnaise, olive oil, vinegar, salt and pepper,and sugar stir till not lumpy; add to mixture and stir.
- Chill and serve.
Most Helpful
Wow, what a good salad. I halved the recipe since I was the only one eating it. The only change I made was wide egg noodles since those are what I had on hand and it still turned out great. I've never used balsamic vinegar before and I was so surprised at the wonderful flavor. Thanks for the recipe! I'm sure I will be using this one alot once my garden gets going.


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Bachelor flat in Carlswald
Sue - Helen van Niekerk
Feel-at-Home Properties
Bachelor flat in Carlswald
For Sale: First floor corner bachelors apartment in Carswald, Midrand, Johannesburg, Gauteng, South Africa by Feel-at-Home Properties.
Hilltop lofts 53 is a stunning corner Bachelors apartment on the 1st floor. This bachelors apartment is available for sale.
This Bachelors apartment is situated near Halfway Gardens, Kyalami Park, Noordwyk as well as the Midrand High School, Beaulieu Office Park and the Netcare Waterfall City.
The Hilltop Lofts is in a security complex with high walls and electric fence, as well as guards. It's a very friendly, safe complex close to all major amenities. The complex has a swimming pool, a club house with braai. This apartment has one allocated carports.
Don't miss out on this amazing offer.
Key Property Features
Email the Agent or request the agent Call You Back should you wish to set up an appointment to view this property or ask for more details.
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|Loan Value (Capital)
|Total Interest
|Total Repayment
Experience Midrand
Midrand, also known as the Halfway House, was established as a municipality in 1981. It is a very vibrant, accessible area that is growing at a rapid rate. Families flock to the area to take advantage of the laid back lifestyle and variety of amenities. There is plenty of employment nearby, with many large businesses taking advantage of Midrand's convenient location between big cities. Vodacom, Cell C, Neotel, Altech Autopage and many more large companies have offices situated here, and with its growing residential areas this is one of the up and coming areas in South Africa.Find out more about Midrand
Similar Property for Sale in Carlswald
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text:
sample closing message
sample closing message
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United States District Court, N.D. Illinois, Eastern Division
December 29, 2014
KIRTI MEHTA, et al., Plaintiffs,v.VILLAGE OF BOLINGBROOK, et al., Defendants.
MATTHEW F. KENNELLY, District Judge.
In their original complaint in this lawsuit, filed on August 7, 2012, plaintiffs Kirti, Keval, Kishan, and April Mehta alleged that the defendants, the Village of Bolingbrook and deputy chief of police Tom Ross, had engaged in a pattern of wrongful and discriminatory conduct directed at them, going back to 1996. Plaintiffs alleged that defendants had failed to investigate crimes committed against them; had framed certain plaintiffs on criminal charges; and had subjected them to stop and search on sight without cause. From 2006 on, plaintiffs alleged, defendants did all of this in order to drive plaintiffs out of their neighborhood in Bolingbrook, a housing development known as Beaconridge. Plaintiffs' complaint made specific reference to an incident on August 18-19, 2010, when gunshots were filed at plaintiffs' home. After they called 911, the police came but, after talking to the manager of the housing development, failed to investigate the shooting. A second similar shooting incident occurred on May 9, 2011, plaintiffs alleged, with a similar lack of action on the part of the police.
Plaintiffs further alleged that on August 5, 2011, Bolingbrook police officers instituted false felony charges against Keval and Kishan Mehta for a crime alleged to have occurred on February 18, 2011. This was done in part, plaintiffs allege, to retaliate for the reinstatement of an earlier lawsuit Kirti Mehta had filed against Bolingbrook.
The original complaint included four claims. Count 1 was a claim under 42 U.S.C. § 1983 alleging that the above-described misconduct and inaction was based on plaintiffs' race and national origin. Count 2 was a claim under the Fair Housing Act alleging a race and national origin-based attempt to drive plaintiffs out of their home in Bolingbrook. Count 3 was a claim of race-based housing discrimination under 42 U.S.C. § 1982. Count 4 was a claim under 42 U.S.C. § 1981 for retaliation; plaintiffs alleged that defendants had intimidated and harassed them to retaliate for the earlier lawsuit.
On November 20, 2012, the Court stayed the case, but only in part. Because the above-referenced criminal charges against Keval and Kishan Mehta were still pending in state court, the Court stayed any "claims relating to the allegedly false arrest and improper charging" of those two plaintiffs. The Court otherwise declined to enter a stay and directed defendants to answer the complaint.
The state court criminal charges against Keval and Kishan Mehta were ultimately concluded by way of a conviction of both of them. (They have since moved to vacate their convictions, but at present the convictions remain on the books.) Accordingly, on November 6, 2013, the Court lifted the previously-imposed stay. Defendants then moved to dismiss Keval and Kishan Mehta's claims arising from the August 2011 arrest, arguing that the claims were barred by Heck v. Humphrey, 512 U.S. 477 (1994), because their convictions had not been overturned. The Court denied this motion in an oral ruling on January 29, 2014, concluding that Heck does not bar a claim of false arrest because such a claim does not necessarily imply the invalidity of a later conviction on the charge for which the plaintiff was arrested.
Plaintiffs later sought leave to file an amended complaint, adding one more plaintiff and several claims. After briefing and argument, the Court made an oral ruling on June 4, 2014, summarized in an order entered that same date. The Court gave plaintiffs leave to amend to include claims arising from incidents in March and April 2014, as well as the defendants claimed to have been involved in those incidents and the additional plaintiff-Ketan Mehta-involved in one of them. The Court declined leave to amend to include other, earlier incidents not referenced in the original complaint and the defendants involved in those incidents, finding that such claims were time-barred. Plaintiffs then moved for reconsideration. In an oral ruling on June 18, 2014 summarized in an order of the same date, the Court expanded its earlier ruling to permit Kishan and Keval Mehta to add claims and defendants arising from their August 2011 arrest that had been the subject of claims in their original complaint. The Court otherwise reaffirmed its June 4 ruling, again concluding that new claims and defendants relating to other, earlier incidents not referenced in the original complaint were time-barred.
Plaintiffs then filed, at the Court's direction, an amended complaint including only the claims the Court had allowed to proceed. Plaintiffs emphasize in their amended complaint that their claims involve events "from August 2010 to Current [sic] as to comply [with] Two years statue [sic] of limitation." Am. Compl. ¶ 4(c). The amended complaint includes eight claims. Count 1 is a claim of discrimination based on national origin and religion in violation of the Fourteenth Amendment's Equal Protection Clause. Count 2 is a claim of national origin and religion-based discrimination under 42 U.S.C. § 1983. Count 3 is a claim of housing discrimination under 42 U.S.C. § 3617. Count 4 is a claim of housing discrimination under 42 U.S.C. § 1982. Count 5 is a claim under 42 U.S.C. § 1981 for retaliation for filing and prosecuting an earlier lawsuit. Count 6 is a claim of false arrest and false imprisonment based on the August 9, 2011 arrest of Keval and Kishan Mehta. Count 7 is a claim by Keval and Kishan Mehta for emotional distress arising from the same incident. Count 8 is a claim by Keval and Kishan Mehta for willful and wanton misconduct arising from the same incident.
Defendants have moved to dismiss all of the claims in whole or in part. The Court deals with each claim in turn.
1. Count 1 - equal protection claim
The Court agrees with defendants that Counts 1 and 2 completely overlap. Count 1 is a claim of discrimination in violation of the Equal Protection Clause. Count 2 is also a claim of discrimination, made under 42 U.S.C. § 1983. Section 1983 is the vehicle by which one asserts a claim for a violation of constitutional rights. There is no need, and no appropriate purpose, to have two separate claims that allege the same thing. Because Count 2 cites the statute that enables plaintiffs to sue, the Court dismisses Count 1 as duplicative of Count 2.
2. Count 2 - claim under 42 U.S.C. § 1983
a. Statute of limitations/relation back
Defendants' primary problem with Count 2 appears to be that they believe the claim is based on pre-June 19, 2012 incidents (June 19, 2012 is two years before the date plaintiffs filed the amended complaint). Indeed it is; plaintiffs base this claim in part on the August 2010 incident described earlier. And as the Court has noted, plaintiffs make clear in their amended complaint that they are basing their claim on matters that occurred from August 2010 to the present.
For purposes of Count 2, the law does not limit plaintiffs to events that occurred two years or less before they filed the amended complaint in June 2014. Plaintiffs' section 1983 discrimination claim has been in the complaint from day one. For this reason, the amended version, insofar as it involves the same defendants originally named, relates back to the date the lawsuit was filed, see Fed.R.Civ.P. 15(c)(1)(B), and the two-year limitations period runs back two years prior to that date, in other words, back to August 7, 2010. Count 2 is therefore timely as to the Village and Ross, who were named as defendants in the original complaint. See Defs.' Mem. in Support of Mot. to Dismiss at 8 n.3 (declining to seek dismissal of Count 2 as to the Village and Ross on this basis). Plaintiffs' reference in Count 2 to incidents predating August 2010 is not a basis to dismiss the claim, given plaintiffs' express limitation of the claim to events occurring in August 2010 and later. Now is not the time to decide whether plaintiffs may introduce earlier incidents as evidence on Count 2 even though they cannot assert claims arising from those incidents.
The timeliness problem with Count 2 concerns any newly-named defendants whom plaintiffs intend to sue on this claim. The original defendants, as indicated above, were the Village and Ross. It is not crystal clear which other defendants are named in this claim in the amended complaint. But if one reviews the narrative description in the amended complaint of the incidents occurring in August 2010 and later, it appears that plaintiffs are naming the following police officer defendants. In this list, the Court has spelled the names as plaintiffs did in the cited portions of the amended complaint.
August 18-19, 2010: Sergeant Champ Evans and Officers Christopher Kushenbach, Thomas McAlluf, and Robert Liazuk. Am. Compl., ¶ 5.
April 2011 (no specific date): Officer Patrick Kinsella. Id. at p. 17 fn. 4.
May 9, 2011: Detective Sean Talbot and Officers Steven Sinnott, Christopher Witt, Andrew Saga, and David Henzler. Id. ¶ 10.
June 2011 (no specific date): Officer Vince Radaker. Id. at p. 16 fn. 3.
August 5, 2011: Detective Sean Talbot, id. ¶ 13, as well as, possibly, Officers Andrew Sraga and Antonio Tucker. Id. ¶ 14.
March 9, 2014: Officer Vince Redaker, Sergeant Brant Duvall, Officer Joseph Hilbruner, and Officer Davi. Id. ¶¶ 16 & 18.
March 25, 2014 (mistakenly described in the complaint as March 19, 2014): Officers Joseph Poradyla and Thomas Gallas. Id. ¶ 15.
April 5, 2014: Officer Thomas McAuliff. Id. ¶ 17.
The Court has omitted unidentified officers from the incidents just listed and has also omitted post-August 2010 incidents where plaintiffs say they do not know the identities of the officers.
First, because the amended complaint was filed just a matter of months after the March and April 2014 incidents, the officers named for those incidents do not have a viable statute of limitations defense.
Second, the claims against the newly-named officers for the August 2010, April 2011, May 2011, and June 2011 incidents do not relate back to the date the original complaint was filed. Under Federal Rule of Civil Procedure 15(c)(1), an amended pleading that adds a party relates back to the date of the original pleading when:
(C) the amendment changes the party or the naming of the party against whom a claim is asserted, if Rule 15(c)(1)(B) is satisfied and if, within the period provided by Rule 4(m) for serving the summons and complaint, the party to be brought in by amendment:
(i) received such notice of the action that it will not be prejudiced in defending on the merits; and
(ii) knew or should have known that the action would have been brought against it, but for a mistake concerning the proper party's identity.
Fed. R. Civ. P. 15(c)(1)(C). "The question under Rule 15(c)(1)(C)(ii) is not whether [the plaintiff] knew or should have known the identity of [the newly-named defendant] as the proper defendant, but whether [that defendant] knew or should have known that it would have been named as a defendant but for an error." Krupski v. Costa Crociere S.p.A., 560 U.S. 538, 548 (2010). The Seventh Circuit has stated that
[t]he only two inquiries that the district court is [after Krupski ] now permitted to make in deciding whether an amended complaint relates back to the date of the original one are, first, whether the defendant who is sought to be added by the amendment knew or should have known that the plaintiff, had it not been for a mistake, would have sued him instead or in addition to suing the named defendant; and second, whether, even if so, the delay in the plaintiff's discovering his mistake impaired the new defendant's ability to defend himself.
Joseph v. Elan Motorsports Techs. Racing Corp., 638 F.3d 555, 560 (7th Cir.2011). "Rule 15(c)(1)(C)(ii) asks what the prospective defendant knew or should have known during the Rule 4(m) period, not what the plaintiff knew or should have known at the time of filing her original complaint." Krupski, 560 U.S. at 548.
Plaintiffs offer no basis whatsoever that would support a finding that the newly-named defendants regarding the August 2010, April 2011, May 2011, and June 2011 incidents had any awareness, or should have been aware, that they would have been named as defendants but for a mistake by the plaintiffs. Thus the claims against the defendants do not relate back to the date the original complaint was filed. As a result, the claims against the individual officers (other than Ross) arising from these incidents are untimely because they were filed more than two years from the arrests, stops, seizures, and other events in question.
Plaintiffs appear to argue a "continuing violation" of their rights in order to avoid the operation of the statute of limitations. But in a case like this, in which plaintiffs allege a series of independently-actionable infringements of their rights, "[e]ach discrete act-something wrongful independent of other events-carries its own period of limitations...." Morris v. Burge, 771 F.3d 444, 447 (7th Cir. 2014) (citing Nat'l R.R. Passenger Corp. v. Morgan, 536 U.S. 101 (2002)). "Alleging a common motive or conspiracy, " as plaintiffs do, does not avoid this rule. Id. For these reasons, plaintiffs cannot assert claims against any individual defendant other than Ross arising from the August 2010, April 2011, May 2011, and June 2011 incidents.
Finally, matters are different with regard to Keval and Kishan Mehta's claims arising from their arrest in August 2011 (because only they were arrested, only they can assert claims arising from the arrest). As indicated earlier, the Court-at defendants' request-stayed all proceedings in the present matter regarding Keval and Kishan's claims arising from that incident. Because Keval and Kishan were precluded by Court order from pursuing those claims, the statute of limitations on their claims regarding this incident was tolled while the stay was in effect. Thus the individual defendants they have named on their claims arising from the August 2011 arrest do not have a viable statute of limitations defense.
To summarize the Court's statute of limitations ruling regarding Count 2:
the Village and Ross are not entitled to dismissal based on the statute of limitations;
the claims against any other individual defendants arising from the August 2010, April 2011, May 2011, and June 2011 are dismissed based on the statute of limitations;
the individual defendants named in connection with the arrest of Keval and Kishan Mehta in August 2011 are not entitled to dismissal based on the statute of limitations; and
those defendants named in connection with claims arising from the March and April 2012 incidents are not entitled to dismissal based on the statute of limitations.
b. Claims of Ketan and Kishan Mehta relating to March 9, 2014 incident
Defendants argue that plaintiffs Kishan and Ketan Mehta have pled themselves out of court for their claims arising from the March 9, 2014 stop and search, because they admit in their complaint that the officers cited Kishan Mehta's parole status in stopping and searching him. Defendants argue that "parolees can be stopped and searched absent any suspicion, " citing Samson v. California, 547 U.S. 843 (2006), and People v. Wilson, 228 Ill.2d 35, 885 N.E.2d 1033 (2008). In Samson, the Court concluded that the Fourth Amendment did not bar a suspicionless search of a California parolee. This was premised upon the diminished expectation of privacy resulting from the fact that California required inmates who opt for parole to submit to suspicionless searches by either parole officers or police officers at any time. See Samson, 547 U.S. at 851-52, 857. In reaching a similar result in Wilson, the Illinois Supreme Court relied on the defendant's mandatory supervised release agreement (MSR is the Illinois equivalent of parole), which contained a term stating that the defendant "consent[s] to a search of [his] person, property, or residence under [his] control." Wilson, 228 Ill.2d at 48-49, 885 N.E.2d at 1041-42. Because that term is a condition of all terms of MSR in Illinois, see 730 ILCS 5/3-3-7(a)(10), it applied to Kishan Mehta too. For this reason, and because the complaint concedes the officer's awareness of Kishan's parole status and his reliance on that status as a basis for the stop and search, Kishan cannot assert a viable claim arising from the March 9, 2014 incident.
The same prohibition does not apply, however, to the claim asserted by Ketan Mehta. He alleges that he was searched without basis as well. Defendants do not contend that Ketan was on MSR or parole. Thus Ketan can maintain a claim arising from the March 9, 2014 stop and search even though Kishan cannot.
c. Claim of Keval Mehta relating to March 25, 2014 incident
Defendants argue that Keval Mehta's claim arising from the March 25, 2014 incident, in which he was issued two traffic citations, is barred because he was found guilty on one of the two citations, specifically a citation for failure to signal a turn. See Defs.' Ex. B, a public record of which the Court takes judicial notice. Among other things, defendants argue that Keval's claim is barred by Heck v. Humphrey, 512 U.S. 477 (1994). Heck bars a lawsuit under section 1983 where a judgment in favor of the plaintiff necessarily would imply the invalidity of his criminal conviction, unless the criminal conviction has been vacated. Id. at 487. A false arrest claim typically does not imply the invalidity of a later conviction on the charge that was the subject of the arrest, and thus most Fourth Amendment-based claims arising from an arrest can go forward despite the fact that the civil-case plaintiff (the criminal-case defendant) was convicted. See, e.g., Easterling v. Moeller, 334 F.Appx. 22, 23 (7th Cir. 2009). If, however, the plaintiff's false arrest claim is based on "allegations that are inconsistent with his conviction's having been valid, Heck kicks in and bars his civil suit." Gordon v. Miller, 528 F.Appx. 673, 674 (7th Cir. 2013) (internal quotation marks omitted); see also Okoro v. Callaghan, 324 F.3d 488, 490 (7th Cir. 2003).
In this case, Keval Mehta's claim regarding the March 19, 2014 stop and resulting citations is, in fact, based on allegations that are inconsistent with his conviction on the charge of failure to signal a turn. He alleges that the purported basis for the stop-that his car had a loud muffler and that he had failed to signal a turn-was made up by the police. Am. Compl. ¶ 15. Thus the basis for Keval's section 1983 claim is inconsistent with his conviction on the failure to signal charge. Heck therefore bars the claim, because the conviction has not been vacated.
It could be argued that because Keval was not convicted on the charge for a loud muffler, his suit, to the extent it is premised on that charge, is not inconsistent with any sort of conviction. But under the Fourth Amendment, a police officer needs only one basis to seize a person, so one valid basis for seizure is sufficient even if the others cited are not. See Devenpeck v. Alford, 543 U.S. 146, 153 (2004); see also, e.g., Holmes v. Vill. of Hoffman Estates, 511 F.3d 673, 682 (7th Cir. 2007).
The Court agrees with those courts that have determined that Heck applies to traffic citations-at least those, like this one, in which there was a conviction following a trial-just as it applies to convictions on more serious charges. See Stone v. Vill. of Broadview, No. 13 C 9316, 2014 WL 3397222, at *4 (N.D. Ill. July 11, 2014) (Dow, J.).
For these reasons, Keval may not maintain a section 1983 claim arising from the March 25, 2014 incident.
d. Claim of Keval and Kishan Mehta relating to August 2011 arrest
Defendants argue that Keval and Kishan Mehta's section 1983 claims arising from the August 2011 arrest for an alleged robbery in February 2011 are likewise barred by Heck because the convictions have not been overturned. The Court previously rejected this argument in an oral ruling after it lifted the stay on Keval and Kishan's claims. The Court has now concluded, however, that the ruling was incorrect and that it should have dismissed the section 1983 claims by Keval and Kishan arising from this arrest. The Court's earlier ruling was premised on the proposition that under Heck v. Humphrey , a Fourth Amendment claim that challenges only an arrest and not a criminal conviction is not barred. That is true as far as it goes, but as the Court noted in the previous section of this decision, when a civil claim under section 1983 challenging an arrest is based on allegations that are inconsistent with the validity of the ensuing conviction, Heck bars the civil claim. See supra at 11. In this case, plaintiffs allege that Bolingbrook police officer Sean Talbot "knowingly & intentionally engaged and perjured him [sic] before the grand jury to get [an] indictment" and that the police "coerced" the complaining witness, Mark Escobedo. Am. Compl. ¶ 13. In short, plaintiffs contend that Talbot was "framing" the Mehtas for the February 2011 robbery. Id. Because the basis for Keval and Kishan's section 1983 claim is inconsistent with their conviction on the robbery charge, and because that conviction has not been vacated, they may not maintain the section 1983 claim.
3. Count 3 - Fair Housing Act claim
Defendants argue that Count 3, plaintiffs' Fair Housing Act (FHA) claim, appropriately may cover only conduct stretching back to June 19, 2012, two years before plaintiffs filed the amended complaint. That argument lacks merit. This claim was included in plaintiffs' original complaint, so it relates back to August 7, 2012, when the lawsuit was first filed. A claim under the FHA may be brought "not later than 2 years after the occurrence or the termination of an alleged discriminatory housing practice, or the breach of a conciliation agreement entered into under this subchapter, whichever occurs last...." 42 U.S.C. § 3613(a)(1)(A). Thus even if defendants are right about how the statute of limitations works for a FHA claim like the one plaintiffs have made, plaintiffs would be able to reach back to August 7, 2010.
The Court concludes, however, that plaintiffs' FHA claim is not limited for statute of limitations purposes in the same way that their section 1983 claim is constrained. In contrast to plaintiffs' section 1983 claims arising from wrongful police seizures and searches, what they allege in Count 3 is a single and ongoing course of conduct aimed at driving them from their home in Bolingbrook due to their national origin and religion. In that regard, the FHA claim is similar for statute of limitations purposes to an employee's claim that he was discriminated against on the job by being subjected to a hostile work environment based on (for example) his race. In such a case, each individual incident that contributes to a hostile work environment is not necessarily actionable on its own, and thus the statute of limitations does not run from each particular incident that forms the basis for the hostile work environment claim. As the Supreme Court indicated in National Railroad Passenger Corp. v. Morgan, an unlawful practice of this type "cannot be said to occur on any particular day. It occurs over a series of days or perhaps years and, in direct contrast to discrete acts, a single act of harassment may not be actionable on its own." Morgan, 536 U.S. at 114. When that occurs, Morgan says, application of the continuing violation doctrine is appropriate when considering a statute of limitations defense.
The Court concludes that this rule applies here. No single incident of false arrest or failure to investigate is claimed to entitle plaintiffs to relief under FHA; rather, it is the entire course of conduct. Thus the continuing violation doctrine applies. The Court therefore Court rejects defendants' statute of limitations argument with regard to Count 3.
Defendants' other basis for dismissing Count 3 fares somewhat better. Defendants complain that plaintiffs have not specifically identified which defendants they are suing on Count 3, and they contend that some of the individual defendants are not alleged to have been a part of any purported effort to drive plaintiffs from their home. The Court is not sure about the latter point, but the former point is well taken. In order to comply with the requirements of Federal Rule of Civil Procedure 8(a), plaintiffs need to identify in their complaint which defendants they contend are liable for violating the FHA, and they must describe the basis for the liability of each such defendant. The Court therefore dismisses Count 3, with leave to amend. Any amended complaint must comply with the terms of this order.
In deciding whether and how to amend Count 3, plaintiffs are advised that to prevail on a FHA claim under 42 U.S.C. § 3617 against a given defendant, a plaintiff must prove that he "(1) [he or] she is a protected individual under the FHA, (2) [he or] she was engaged in the exercise or enjoyment of her fair housing rights, (3) the defendants coerced, threatened, intimidated, or interfered with the plaintiff on account of [his or] her protected activity under the FHA, and (4) the defendants were motivated by an intent to discriminate." Bloch v. Frischholz, 587 F.3d 771, 783 (7th Cir. 2009). Before filing an amended complaint identifying which defendants they are suing under section 3617 and the basis for the liability of each, plaintiffs should take care to examine whether they can meet the requirements of Federal Rule of Civil Procedure 11(b) as to any given defendant. Rule 11(b) says that a litigant's signature on a complaint naming a defendant constitutes a certification that to the best of the plaintiff's knowledge, information and belief, formed after reasonable inquiry, the plaintiff's allegations on this claim as to a particular defendant "have evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery." Fed.R.Civ.P. 11(b)(3). A party whose complaint, motion, or other court filing runs afoul of this rule subjects him or herself to the imposition of sanctions under Federal Rule of Civil Procedure 11(c).
4. Count 4 - claim under 42 U.S.C. § 1982
Count 4 is a claim under 42 U.S.C. § 1982, which provides that "[a]ll citizens of the United States shall have the same right, in every State and Territory, as is enjoyed by white citizens thereof to inherit, purchase, lease, sell, hold, and convey real and personal property." Defendants have moved to dismiss this claim on the same basis upon which they sought dismissal of Count 3. Consistent with its rulings on that claim, the Court rejects defendants' statute of limitations defense to Count 4, but dismisses the claim with leave to amend for the reasons described regarding Count 3, and with the same admonitions made regarding Count 3.
5. Count 5 - claim under 42 U.S.C. § 1981
Count 5 is a claim under 42 U.S.C. § 1981. Defendants correctly argue that a plaintiff may not assert a claim against a municipal entity or employee under section 1981; section 1983 is the vehicle by which claims against governmental actors for conduct that might be covered by section 1981 may be asserted. See Jett v. Dallas Indep. Sch. Dist., 491 U.S. 701, 731 (1989). And if, for this reason, one were to interpret Count 5 as a section 1983 claim, the claim would duplicate Count 2. The Court therefore dismisses Count 5 as a separate claim.
6. Counts 6, 7 and 8 - claims concerning August 2011 arrest
Counts 6, 7, and 8 are claims by Keval and Kishan Mehta arising from their August 2011 arrest. The Court understands Count 6 as a claim under section 1983 for false arrest in violation of Keval and Kishan's rights under the Fourth Amendment. See Count 6, ¶ 1(A) (citing the U.S. Constitution). This claim is barred by Heck v. Humphrey for the reasons discussed earlier. See supra at 12-13.
Defendants contend that Count 7 is not really a separate claim but rather is only a request for an additional type of damages-emotional distress-for the conduct alleged in Count 6. The Court disagrees. It appears that Count 7 is a claim under Illinois law for intentional infliction of emotional distress (IIED). If, however, an IIED claim is predicated on an allegation that the police framed the plaintiff for a crime, then it cannot be asserted unless and until the underlying conviction is vacated. See Parish v. City of Elkhart, 614 F.3d 677, 683-84 (7th Cir. 2010) (Indiana law).
Count 8 is a claim of willful and wanton misconduct under Illinois law. It is premised upon defendant Talbot's allegedly false grand jury testimony that led to the robbery charge against Keval and Kishan Mehta. See Count 8, ¶ 1(A). Under Illinois law, however, a witness before a grand jury is entitled to absolute immunity from a lawsuit that is based on his testimony. See Barnes v. Martin, 2014 IL App (2d) 140095-U, ¶ 57 (2014) (citing Rehberg v. Paulk, 132 S.Ct. 1497, 1506 (2012), which applies this rule to suits under 42 U.S.C. § 1983).
For these reasons, the Court dismisses Counts 6, 7, and 8.
7. Liability of Village and Ross
Under section 1983,
a local government may not be sued... for an injury inflicted solely by its employees or agents. Instead, it is when execution of a government's policy or custom, whether made by its lawmakers or by those whose edicts or acts may fairly be said to represent official policy, inflicts the injury that the government as an entity is responsible....
Monell v. Dep't of Social Servs. of City of N.Y., 436 U.S. 658, 694 (1978). Proof of "a widespread practice that is so permanent and well settled as to constitute a custom or usage with the force of law" is sufficient to show a policy or custom under Monell. See, e.g., Palka v. City of Chicago, 662 F.3d 428, 434 (7th Cir. 2011).
Defendants argue that plaintiffs have failed to allege a basis for municipal liability under section 1983 and, presumably, under the Fair Housing Act. The Court disagrees. It is true that plaintiffs do not use the words "policy" or "custom" in their complaint. But they allege, sufficiently to avoid dismissal, a systematic effort carried out at all levels of the Bolingbrook Police Department to drive them out of their neighborhood and the Village through arrests, searches, seizures, and other forms of harassment. Defendants argue that to prove a custom or policy, it is insufficient for plaintiffs to rely only on evidence that involves their own interactions with Village personnel. However, the authorities defendants for this concern allegations of "isolated" incidents, which is the opposite of what plaintiffs allege. In any event, a plaintiff does not have to plead evidence in his complaint. Plaintiffs' allegations are sufficient to state a claim against the Village.
The Court also declines to dismiss Deputy Chief Ross. Defendants argue that plaintiffs have not supported their allegation that he was involved in directing other officers who were involved in the various arrests, seizures, searches, and other incidents alleged in the complaint. But a plaintiff does not have to prove his case to avoid dismissal for failure to state a claim. Plaintiffs' allegations regarding Ross are sufficient to state a claim against him.
8. Kirti Mehta, April Mehta, and Ketan Mehta
Defendants argues that three of the plaintiffs, Kirti Mehta, April Mehta, and Ketan Mehta should be dismissed because they do not allege any actionable wrongs. The Court disagrees. April Mehta cites an April 2011 incident in which she was stopped and searched without probable cause. See Am. Compl., p. 17 fn. 4. The Court has declined to dismiss Ketan Mehta's claim arising from the March 9, 2014 stop and search. Id. ¶ 18. And although Kirti Mehta does not allege that he was arrested, stopped, or searched at any time within the two years predating the filing of this lawsuit, he alleges that he (along with each of the other plaintiffs) was a victim of the alleged effort to drive him and his family from their home. There is no appropriate basis for the complete dismissal of any of these three plaintiffs.
The Court summarizes its rulings as follows:
Count 1 is dismissed as duplicative of Count 2;
Count 2 stands as to claims arising from the alleged incidents from August 7, 2010 to the present against defendants Village of Bolingbrook and Ross on; as to the claim by Ketan Mehta (but not Kishan Mehta) arising from the alleged March 9, 2014 incident against defendants Redaker, Duvall, Hilbruner, and Davi; and as to the claim by Kishan Mehta arising from the April 5, 2014 incident against defendant McAuliff;
Count 2 is otherwise dismissed;
Counts 3 and 4 are dismissed, with leave to amend, by no later than January 14, 2015; and
Counts 5, 6, 7, and 8 are dismissed.
The case is set for a status hearing on January 21, 2015 at 9:30 a.m.
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December 20, 2000
According to the government, defendant Haywood Hinton, a/k/a "Ameer Hasan," committed one violation of 18 U.S.C. §§ 1344 and 2 when he knowingly and wilfully executed and attempted to execute a single scheme to defraud six separate financial institutions, and to obtain money, funds and assets owned by and under the control of such financial institutions, by means of materially false and fraudulent pretenses, representations, and promises. Presently before the Court are Hinton's motions to dismiss the indictment as duplicitous and also for a bill of particulars that would detail each alleged transaction, including times, dates, locations, and accomplices which the government claims were a part of defendant's overall scheme to defraud. The principal issue to be determined is whether a one-count indictment alleging that the defendant defrauded six separate financial institutions by employing similar means and measures in various times and places, employing different confederates, suffers from duplicity by alleging multiple crimes within a single count.
After careful consideration of Hinton's motions and the government's response thereto, and the Court having heard oral argument on November 16, 2000, and having received supplemental submissions thereafter, the Court finds that the Second Superseding Indictment is duplicitous and will dismiss same unless the government, within 20 days, elects a single bank fraud charge from among those in the duplicitous count or supersedes this indictment with non-duplicitous charges. The Court will dismiss without prejudice defendant's motion for a bill of particulars as premature, pending the return of a Third Superseding Indictment.
Defendant, Haywood Hinton, a/k/a Ameer Hasan, was first indicted for one count of executing a bank fraud scheme in violation of 18 U.S.C. §§ 1344 and 2 on March 22, 2000. The first one-count Superseding Indictment was returned on August 20, 2000.
On or about November 15, 2000, the Grand Jury returned a one-count Second Superseding Indictment against defendant, charging that from in or about December, 1997 through in or about March, 1999, defendant knowingly and willfully executed and attempted to execute a single scheme and artifice to defraud six financial institutions, namely, First Union National Bank, Sovereign Bank, PNC Bank, N.A., Fleet Bank, N.A., Summit Bank, and Colonial Bank, F.S.B. (collectively, the "Banks"), and to obtain money, funds and assets owned by or under the control of the Banks. (See Second Superseding Indictment, Nov. 15, 2000.) The Second Superseding Indictment specified several means by which defendant allegedly executed that single scheme, including, providing other individuals with false documentation, causing other individuals to open accounts at the Banks under fictitious names and using false identification, causing others to negotiate checks when he knew that neither he nor the others were entitled to such funds, personally negotiating checks, the proceeds of which he knew he was not entitled to, and causing another to negotiate a check in the amount of $1,433.00 at the PNC Bank, N.A. in Cinnaminson, New Jersey. (See id.) Other than identifying the banks, and the one transaction, the Second Superseding Indictment provides no further details.
Discovery has been extensive and has revealed that the scheme is evidenced by approximately 128 transactions at six banks involving nine different confederates, with a summary chart (produced in draft on November 15, 2000) providing the information on a transaction-by-transaction basis regarding the name of the other person involved, his or her fictitious identity, the bank utilized, the location of the transaction, the account utilized, the date of the incident, the checks utilized, the check number and the check amount. By the Court's reckoning, the approximate breakdown of these transactional allegations is as follows:
Financial Institution Earliest and Latest Dates Number of Persons Used *fn1 Number of Accounts Used Number of Transactions
PNC Bank, NA 05/08/981 2 6
Colonial Bank, FSB 05/07/981 2 4
First Union National Bank 01/07/983 through 05/06/98 5 11
Sovereign Bank 12/01/974 through 03/16/99 11 89
Fleet Bank 12/17/971 through 12/30/97 2 9
Summit Bank 12/29/971 through 12/31/97 2 9
This motion, attacking the manner in which this single-count indictment is framed, does not call upon the court to weigh or determine the sufficiency of any evidence, but this summary of transactional evidence is necessary to understand the contour of the crime or crimes charged as the Court next evaluates the parties' positions.
For purposes of these motions, the Court examines the Second Superseding Indictment (filed November 15, 2000), as defendant's motion was initially directed at the First Superseding Indictment, which was itself superseded before oral argument herein. Defense counsel orally renewed the motions as to the Second Superseding Indictment, arguing that it had not cured the impairments of the earlier charge. Accordingly, this Opinion will refer to the Second Superseding Indictment, or simply "the indictment," interchangeably.
A. The Second Superseding Indictment
Defendant seeks to have the Second Superseding Indictment dismissed as duplicitous. The Second Superseding Indictment charges, in a single count, that:
From at least as early as December, 1997 through in or about March, 1999, in Burlington County, in the District of New Jersey and elsewhere, defendant Haywood Hinton, a/k/a/ "Ameer Hasan" did knowingly and wilfully execute and attempt to execute a scheme and artifice to defraud various financial institutions, including the Banks, and to obtain money, funds and assets owned by and under the custody and control of such financial institutions, by means of materially false and fraudulent pretenses, representations and promises, as more fully set forth below. (Second Superseding Indictment, para. 2, Nov. 15, 2000)(emphasis added).
The indictment goes on to charge several means and methods by which defendant allegedly perpetrated this bank fraud scheme. Defendant argues that because the government cannot and will not prove that any single transaction or scheme execution occurred, it is improperly charging multiple transactions and scheme executions in a single count indictment in an attempt to win a conviction. This type of indictment, argues defendant, is duplicitous and must be dismissed.
The government does not dispute the impropriety of a duplicitous indictment. It argues, however, that the present indictment is not duplicitous because it charges only a single scheme to defraud six financial institutions in violation of 18 U.S.C. §§ 1344 and 2.
The bank fraud statute reads as follows:
Whoever knowingly executes, or attempts to execute, a scheme or artifice-
(1) to defraud a financial institution; or
(2) to obtain any of the moneys, funds, credits, assets, securities, or other property owned by, or under the custody or control of, a financial institution, by means of false or fraudulent pretenses, representations, or promises; shall be fined not more than $1,000,000 or imprisoned not more than 30 years, or both. 18 U.S.C. § 1344.
The fact that the indictment charges defendant under both prongs of Section 1344, in and of itself, does not make the indictment duplicitous. *fn2
B. The Arguments of the Parties
Defendant seeks the dismissal of the Second Superseding Indictment because, he argues, it charges multiple executions of bank fraud schemes and that it therefore would be difficult for a jury to render a finding about each transaction, and would also be essentially impossible for the court to determine whether a conviction rested on one or more executions of any bank fraud scheme. Defendant asserts that the government's decision to charge him in a one count Second Superseding Indictment for bank fraud was based on their inability to prove any of the underlying transactions as separate offenses. The defendant charged that the government was doing little more than "fling[ing] a great deal of spaghetti at the wall, hoping that enough [would] stick[] to convict the defendant of a single 30-year count." (Defs.' Br. at 2.)
The Second Superseding Indictment in this case charges defendant with one count of bank fraud against six separate financial institutions in violation of 18 U.S.C. §§ 1344 and 2. Defendant distinguishes the cases involving mail fraud cited by the government by emphasizing the crucial difference between mail fraud and bank fraud cases -- that is, while mail fraud turns on the mere existence of the scheme accompanied by an act of mailing, bank fraud turns on the execution of the scheme. (Borden Letter, Dec. 5, 2000.) In support of his position defendant quotes the District of Columbia Circuit Court, which wrote, for bank fraud, "[t]he unit of prosecution is not the scheme but the execution. If [the defendant] did not execute the scheme, he would not be guilty." United States v. Bruce, 89 F.3d 886, 889 (D.C. Cir. 1996)(quoting United States v. Pless, 79 F.3d 1217, 1220 (D.C. Cir. 1996)).
The government denies that the Second Superseding Indictment is duplicitous and argues that it properly includes multiple transactions involving multiple banks, each of which could have been charged as a discrete offense, occurring from December, 1997 through March, 1999, in one count because all the transactions were committed during the course of a single, unified bank fraud scheme perpetrated by defendant. In response to the Court's inquiry concerning whether a jury must unanimously agree on any particular transaction that the government alleges makes up the unified scheme at oral argument on November 16, 2000, the government argued that although jurors must unanimously agree on each element that makes up the charge, they "need not also be unanimous as to the specific act or acts that was a means of satisfying the element." (AUSA Zweig Ltr., Nov. 22, 2000 at 2-3.) The government's position, therefore, is that because all of the means and methods (e.g., obtaining false identification with false documentation, opening fraudulent accounts, negotiating checks on closed accounts, and causing others to do the same), which occurred between December, 1997 and March, 1999, were included in the scope of the single, unified scheme to defraud six financial institutions, defendant was properly charged with a one count violation of 18 U.S.C. §§ 1344 and 2.
C. The Law of Duplicity
"Duplicity is the joining of two or more distinct offenses in a single count, so that a general verdict does not reveal exactly which crimes the jury found the defendant had committed." United States v. Gomberg, 715 F.2d 843, 845 (3d Cir. 1983), cert. denied, 465 U.S. 1078 (1984)(citation omitted). A duplicitous indictment compromises a defendant's Sixth Amendment right to know the charges against him. See United States v. King, 200 F.3d 1207 (9th Cir. 1999)(citing United States v. Aguilar, 756 F.2d 1418, 1420 n. 2 (9th Cir. 1985)). Duplicitous indictments can also prejudice the defendant with respect to evidentiary rulings at trial and a general verdict in a duplicitous indictment would prevent the court from determining whether the jury was unanimous with respect to any of the offenses. United States v. Starks, 515 F.2d 112, 116-17 (3d Cir. 1975). An indictment is not duplicitous in cases where the indictment does not charge different offenses in the same count, but instead charges different methods of completing the same offense. United States v. Sourlis, 953 F. Supp. 568, 572 (D.N.J. 1996).
When a district court is faced with a motion challenging an indictment as duplicitous, the Court's review is limited; "the task is not to review the evidence . . . to determine whether it would support charging several crimes rather than just one, but rather to solely assess whether the indictment itself can be read to charge only one violation in each count." United States v. Sourlis, 953 F. Supp. 568, 572 (3d Cir. 1996)(citing United Mastelotto, 717 F.2d 1238, 1244 (9th Cir. 1983)). In a fraud case such as this one, this Court must determine "the breadth of the fraudulent activity alleged in the count" and must then determine "whether [the fraudulent activities] all fall[] within one unitary `scheme to defraud.'" Sourlis, 953 F. Supp. at 574 (quoting Mastelotto, 717 F.2d at 1244).
If a court finds that an indictment is duplicitous it must take one of two courses of action; it must either dismiss the duplicitous count in the indictment, or require the government to make an election to select and charge one, but not all, of the offenses embraced in the duplicitous count. See Sourlis, 953 F. Supp. at 572; United States v. Starks, 515 F.2d 112, 117 (3d Cir. 1975)(finding that a single count charging conspiracy to extort and attempt to extort was duplicitous and requiring an election). A duplicitous indictment cannot be cured by a bill of particulars. Russell v. United States, 369 U.S. 749, 770, 82 S. Ct. 1038, 1050 (1962); 1 Charles Alan Wright, Federal Practice and Procedure, Criminal §§ 125, 129 (3d ed. 1999). The Supreme Court articulated the reason behind this rule in Russell v. United States: To allow the prosecutor, or the court, to make a subsequent guess as to what was in the minds of the grand jury at the time they returned the indictment would deprive the defendant of a basic protection which the guaranty of the intervention of a grand jury was designed to secure. For a defendant would then be convicted on the basis of facts not found by, and perhaps not even presented to, the grand jury which indicted him. 82 S. Ct. 1038, 1050, 369 U.S. 749, 770 (1962).
D. Analysis
The Court begins its analysis of this duplicity challenge by looking at the language of the bank fraud statute itself:
Whoever knowingly executes, or attempts to execute, a scheme or artifice -
(2) to obtain any of the moneys, funds, credits, assets, securities, or other property owned by, or under the custody or control of, a financial institution, by means of false or fraudulent pretenses, representations, or promises; shall be fined not more than $1,000,000 or imprisoned not more than 30 years, or both. 18 U.S.C. § 1344 (emphasis added).
The plain language of the statute defines one of the elements of bank fraud as a scheme to defraud "a financial institution," not a scheme to defraud financial institutions. None of the bank fraud cases cited here by the government involve a single count charging a defendant in a scheme to defraud more than one financial institution. The Court's extensive research turned up only one case in which a court allowed a single count of bank fraud to charge a defendant with orchestrating a scheme to defraud more than one financial institution, and that case, United States v. Brown, 894 F. Supp. 1150 (N.D. Ill. 1995), while factually similar to this case, is of limited precedential value.
In Brown, the court denied the defendant's motion to dismiss count one of the indictment against him as duplicitous, where the count alleged that, over a period of two and one-half years, defendant executed a scheme to defraud twenty-two Chicago-area financial institutions in violation of 18 U.S.C. §§ 2 and 1344 by depositing or directing others to deposit worthless, stolen, and/or forged checks into the banks' accounts, and then drawing the money out prior to the banks' detection of the fraud. 894 F. Supp. at 1153. Defendant Brown, similar to Defendant Hinton, allegedly controlled and directed the fraudulent activities of multiple other participants, some of whom were not aware of the activities of others.
In his motion to dismiss count one, Brown cited conspiracy cases holding that the mere presence of a central figure in a series of offenses was insufficient to allege a conspiracy involving all participants. Id. at 1154 (referencing Kotteakos v. United States, 328 U.S. 750, 754-55, 66 S. Ct. 1239, 1242-43 (1946); United States v. Bruun, 809 F.2d 397, 410 (7th Cir. 1987)). The court determined that the conspiracy cases cited were inapposite and held that in a bank fraud case, the defendant is liable as a principal or as an aider and abettor, and that the defendant need only associate himself with a criminal venture, here the bank fraud, and participate in it to be liable. Brown, 894 F. Supp. at 1155. The court concluded its discussion of the duplicity motion by writing, "although the government alleges numerous instances of bank fraud in furtherance of the common scheme, the Court will take careful steps to impress upon the jury that it must consider each of these instances as separate and distinct and enter a finding of guilty only if it is able to agree unanimously that the government has met its burden of proof in each instance." Id. at 1156. Apparently, the Brown court required the government to prove each of the many underlying fraudulent transactions beyond a reasonable doubt in order to succeed in proving the unified scheme.
In this case, the government has provided extensive discovery, including a detailed chart, as noted above, summarizing the salient characteristics of each of the 128 transactions as memorialized in hundreds or thousands of pages of documents. Such discovery, however, cannot cure an inherently defective indictment. Even if the Court were able to compose lengthy and detailed instructions to be presented to a jury, as was intended to be done by the court in Brown, it is unlikely that such instructions could adequately inform jurors about what facts would have to be found with respect to which financial institutions to constitute a scheme and obtain a conviction.Certainly, this Court would not follow the Brown court's suggestion that the unified scheme involving multiple financial institutions survives a duplicitousness challenge only if the government succeeds in proving each fraudulent transaction beyond a reasonable doubt. Such an interpretation may save the Second Superseding Indictment from a duplicity challenge at the expense of requiring proof of 128 fraudulent transactions to prove a unified scheme. It makes no sense to find that the government must prove 128 crimes to prove one unified scheme. Moreover, the Court is unconvinced that it could craft jury instructions that would ensure juror unanimity for a single scheme and overcome the potential problems associated with the government's attempt to charge one fraud scheme against six different financial institutions in a single count indictment. Allowing this case to proceed on a duplicitous indictment would compromise defendant's right to know the charges pending against him and would prevent the Court from ensuring that any jury verdict against him was unanimous with respect to the charged offense.
The government insists, correctly in this Court's view, that it need not prove each transaction in order to prove a unified scheme under §§ 1344 and 2. The execution of a scheme to defraud a financial institution is shown by proof of the existence of the scheme to defraud and proof that the defendant knowingly, willfully and with intent to defraud executed that scheme or aided and abetted others in doing so. See Goldblatt, 813 F.2d at 624. Under § 1344, the execution or the attempt to execute are equivalent and this essential element of § 1344 does not require proof that the scheme to defraud was even successful, so long as defendant knowingly attempted the scheme with intent to defraud the financial institution. The listed transactions with each financial institution are only evidence of the execution (or attempted execution) of the scheme directed against that institution. The vice here is not that multiple transactions are involved in the scheme against a particular institution, but that schemes against six separate unrelated financial institutions are lumped into a single count contrary to the language of § 1344.
The Second Superseding Indictment charges one violation of 18 U.S.C. § 1344, yet it embraces at least 128 transactions executed in furtherance of frauds against six separate financial institutions. The dates and alleged perpetrator(s) for a particular institution's transactions do not generally overlap, no transaction was directed at more than a single institution, and none of the accounts used exists in more than one bank. Generally, different confederates were allegedly employed in contacts with the defrauded banks. In the event of a conviction, it would not be possible to determine which aspects of this so-called unified scheme had been proved as to which financial institutions. The indictment, therefore, is duplicitous. Although it is understandable that the government would want to conserve its resources and simplify the prosecution of this defendant who is alleged to have managed the fraudulent transactions with each bank, for one unified scheme, it cannot do so in a one count indictment where six financial institutions are involved, even if distinct similarities in the means and methods of the schemes directed against each bank exist in the proofs.
In order to remedy this defective indictment, the Court must either dismiss the one count duplicitous indictment or require the government to make an election between charging one fraud against one financial institution in a single count. See Sourlis, 953 F. Supp. at 572; United States v. Starks, 515 F.2d 112, 117 (3d Cir. 1975). Because the law is well established that a bill of particulars cannot cure a defective indictment, no other remedy is available or appropriate.
So, in light of the Court's decision on defendant's motion to dismiss the indictment as duplicitous, the government must elect to pursue one scheme to commit bank fraud against one bank or seek to have a Third Superseding Indictment returned, charging each scheme to defraud a financial institution in a separate count. While each count may involve multiple transactions in its alleged scheme, it cannot be combined in a single count with a scheme directed against another financial institution. If the government does not elect to continue with a single scheme to defraud a single financial institution under §§ 1344 and 2 or obtain a Third Superseding Indictment within twenty (20) days, then this Court must grant defendant's motion to dismiss the Second Superseding Indictment. Defendant's motion for a bill of particulars will be dismissed without prejudice as premature, pending the government's election.
For the reasons stated in this Opinion, the Court will grant the defendant's motion to dismiss the present indictment as duplicitous and extend for twenty (20) days the period in which the government must either elect to proceed only upon a single scheme to defraud one of the institutions identified in Court One or obtain the return of a Third Superseding Indictment consisting of multiple counts consistent with this Opinion. The Court will dismiss defendant's motion for a bill of particulars as premature pending the government's election. The accompanying Order is entered.
JEROME B. SIMANDLE U.S. District Judge
This matter having come before the Court upon the motions of defendant, Haywood Hinton, for an order to dismiss the present indictment, charging a single violation of 18 U.S.C. § 1344 and 2 for knowingly and wilfully executing and attempting to execute a scheme and artifice to defraud various financial institutions, as duplicitous; and for and an order requiring a bill of particulars; and the Court having considered the submissions and oral arguments of counsel, the United States appearing through Assistant U.S. Attorney Gail Zweig, and the defendant appearing through Edward F. Borden, Jr., Esquire; and
The Court having found, for reasons stated in its Opinion filed today, that these motions should be granted in part, dismissed in part;
IT IS this 20th day of December, 2000 hereby
ORDERED that defendant's motion to dismiss shall be GRANTED upon the following conditions; and
IT IS FURTHER ORDERED that the period in which the government must either elect to proceed only upon a single scheme to defraud one of the financial institutions identified in Count One or seek the return of a Third Superseding Indictment will expire in twenty (20) days;
IT IS FURTHER ORDERED that the Second Superseding Indictment should be DISMISSED upon the expiration of twenty (20) days unless the government first either elects to proceed upon a single scheme to defraud one of the financial institutions identified in Count One or files a Third Superseding Indictment containing no duplicitous count; and
IT IS FURTHER ORDERED that defendant's motion for a bill of particulars shall be, and hereby is DISMISSED without prejudice.
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The Future of the Sino-American Co-Dependency
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