Law Enforcement

LOS ANGELES – Spurred by the outrageously high salaries paid to public officials in the city of Bell, Attorney General Edmund G. Brown Jr. today launched a joint investigation with CalPERS into the compensation paid by Bell and other local governments throughout the state.

“These outrageous salaries in Bell are shocking and beyond belief,” Brown said. “With record deficits and painful budget cuts facing California cities, astronomical local government salaries raise serious questions and demand a thorough investigation.”

Brown’s probe will examine records to determine whether any illegality, self-dealing, or other improper activity occurred in Bell or other cities and counties in the state.

The Attorney General’s investigation was launched after recent Los Angeles Times articles reported that Robert Rizzo, the Bell city manager, is paid nearly $800,000 a year, making him the highest-paid city manager in the state. Police Chief Randy Adams is paid $457,000 and Assistant City Manager Angela Spaccia is paid $376,288 a year. Most city council members are paid nearly $100,000 for their part-time jobs.

Bell, in southeast Los Angeles County, has a population of 40,000 that includes a high percentage of low-income residents.

Peter Mixon, General Counsel of CalPERS, the state’s public employee retirement agency, said, “CalPERS welcomes working collaboratively with the Attorney General’s office to investigate the facts and circumstances regarding pension and related benefits for the city of Bell.”

LOS ANGELES – Attorney General Edmund G. Brown Jr. today released an “encouraging” 2009 annual report showing that hate crimes in California fell by more than 20% last year, but he warned that we are still a long way from ending bigotry and prejudice.

“While the drop in these crimes is encouraging,” Brown said, “hate has certainly not been banished from California. The sheer total of incidents motivated by hate is a reminder of how much harder we need to work to overcome prejudice, bigotry and ignorance.”

The Attorney General’s report, “Hate Crime in California 2009” was compiled using data submitted to the California Department of Justice by police, sheriffs’ departments and prosecutors in California’s 58 counties.

The report showed that hate crime events dropped 21.3% – from 1,397 in 2008 to 1,100 last year, the second consecutive year of decline. Overall, hate crimes have declined by half since they peaked in 2001, dropping from 2,261 to 1,100.

Today’s favorable report follows news last month that the state’s violent crime rate dropped for a third straight year in 2009.

Contributing to last year’s downward trend in hate crimes was a decline in anti-black crime (-17.7%), anti-Jewish crime (-13%) and anti-gay crime (-22.1%). Together, those categories account for approximately 60% of all hate crime events in the state.

While violent offenses accounted for 63.5% of all hate crimes in 2009, last year marked the largest year-over-year decline in violent hate crimes (-22.8%) this decade.

In total, 479 hate crime cases were referred to prosecutors in 2009. Of those, 363 criminal cases were filed, 283 as hate crimes. Of the 257 hate crime cases with dispositions in 2009, there were 223 convictions (131 hate crime convictions and 92 other convictions).

The Attorney General’s office published its first hate crimes report in 1995. The reports can be found at: http://ag.ca.gov/cjsc/publications/hatecrimes/pub.php.

Under California law, the Attorney General is required to submit an annual report to the Legislature enumerating crimes motivated by the victim’s race, ethnicity, religion, gender, sexual orientation, national origin, or physical or mental disability.

The decline in hate crimes reflects an overall drop in crime. Last month’s report by the Attorney General on all types of crime in California showed across-the-board declines in every category of offense measured, from homicide (-8.9%) and robbery (-8.6%), to motor vehicle theft (-15.8%) and arson (-14.3%). For more information, visit: http://ag.ca.gov/newsalerts/release.php?id=1940.

A copy of the 2009 hate crimes report is attached.

SANTA ANA – In a “notable judgment” for victims of violent hate crimes, Attorney General Edmund G. Brown Jr. announced that his office has secured a novel civil award against two individuals who targeted a man based on his ethnicity, forced him out of his car and beat him until blood flowed from his ears.

“Victims of crimes inspired by hate deserve every remedy available under the law,” Brown said. “This notable judgment ensures that in California, justice doesn’t stop at the criminal courtroom door.”

The judgment, signed late last week, requires James Joseph Kelly III, 28, of California City and Justin Louis Mullins, 26, of Garden Grove each to pay $25,000 to Felipe Alvarado, 31, whom they brutally assaulted and verbally harassed.

The incident began about 2 a.m. on August 9, 2007 in Garden Grove. As Alvarado waited at a traffic light at the intersection of Magnolia Street and Trask Avenue, Mullins and Kelly pulled up and began verbally harassing him. Alvarado ignored the insults, but on the other side of the intersection, in the parking lot of his workplace, the two men jumped out of their vehicle, forced Alvarado out of his vehicle and dragged him to the pavement. Defenseless, Alvarado was punched, kneed and kicked until blood flowed from his ears.

During the assault, the men insulted Alvarado with ethnic slurs. The beating left him with permanent back pain and hearing loss.

Today’s civil judgment follows criminal convictions in October 2008. Kelly was sentenced to nine months in jail on one count of misdemeanor assault. Mullins was sentenced to three years in state prison for misdemeanor assault, driving under the influence and violating probation.

The civil case marks the first time the Attorney General has filed a case to benefit victims of violent crimes under the Ralph Civil Rights Act, which enables victims of many types of hate crimes to pursue civil penalties in addition to criminal charges. Given the circumstances and brutality of the crimes, Brown decided to pursue a civil case after the defendants were released from confinement.

Victims who believe their rights have been violated under the Ralph Act or any of California’s other civil rights laws, can file a complaint with Brown’s Civil Rights Enforcement Section at http://ag.ca.gov/contact/complaint_form.php?cmplt=PL.

Copies of Brown’s complaint and last week’s judgment, entered in Orange County Superior Court, are attached.

SAN DIEGO -- Attorney General Edmund G. Brown, Jr. announced today the successful completion of “Operation Watchdog,” an unprecedented law enforcement sweep to verify that 300 registered sex offenders in San Diego are obeying the law and living at the address they have reported to authorities. Nine arrests were made.

“Because of sex offenders’ propensity to reoffend, keeping tabs on them is crucial to protecting the public,” Brown said. “As in many things, the price of safety is constant vigilance, and my office is committed to providing that.”

Led by David Collazo, a special agent supervisor in Brown's office, Operation Watchdog involved more than 100 state, federal and local law enforcement officers, who fanned out over San Diego County yesterday to check on more than 300 registered sex offenders. Five of the 26 task force teams took along specially trained dogs to check for illegal drugs and guns.

Some 4,600 registered sex offenders live in San Diego.

Sex offenders on probation or parole were searched. The others were questioned to make sure they were complying with all state laws, including living at the same address they provided to law enforcement authorities. Arrests were made for parole and probation violations and possession of drug paraphernalia and guns.

As Operation Watchdog began yesterday morning, the Attorney General visited the command center and was briefed. Besides its enforcement function, the Attorney General’s office maintains a website at http://meganslaw.ca.gov/ that lists the locations of 63,000 sex offenders in the state, along with other pertinent information.

The SAFE (Sexual Assault Felony Enforcement) task force that conducted the operation was formed nearly a decade ago to reduce the number of sex crimes in San Diego County and apprehend the perpetrators of those crimes. SAFE assists in criminal investigations such as the case of convicted sex offender John Albert Gardner III, who was sentenced to life in prison earlier this year for the 2009 rape and murder of 14-year-old Amber Dubois and the February 2010 rape and murder of 17-year-old Chelsea King. Gardner had lied to authorities about his residence, listing Riverside County instead of San Diego.

Yesterday’s sweep was the first such large-scale effort, although SAFE conducts hundreds of face-to-face interviews with sex offenders each year to make sure they are in compliance with the law.

SAN FRANCISCO – Attorney General Edmund G. Brown Jr. continued his fight today against an attack on the state’s innovative use of DNA to identify suspects of violent crimes, asserting that “DNA is the fingerprint of the 21st century.”

In an argument before the federal court of appeals in San Francisco, Brown’s office defended the state’s voter-mandated collection of DNA from adults arrested for felonies.

“California is at the forefront of solving crimes through new and innovative uses of DNA technology, and I intend to do everything in my power to defend the state’s ability to reduce crime by collecting DNA from those arrested for felonies,” Brown said. “So far, DNA collected from arrestees has led to the identification of suspects in more than 970 rapes, murders and other very serious crimes,” Brown added.

This case arose when the ACLU filed a lawsuit seeking to stop the state’s DNA arrestee program. The Attorney General prevailed in the United States District Court, and the ACLU appealed to the federal court of appeals.

Samples are taken through a simple procedure using a wooden swab to collect DNA from the inside of a person’s cheek. Strict safeguards ensure that the samples are used only by law enforcement officials to identify an individual and not for any other purpose.

Brown pointed out that about 40 percent of homicides and 60 percent of rapes go unsolved. For example, many of the victims of the Grim Sleeper might still be alive if the suspect had been identified from DNA taken when he was previously arrested.

Collecting DNA samples from those arrested for felonies is a profoundly important way to help solve murders, rapes and other very serious crimes. It should be noted that almost half of those arrested for felonies are repeat offenders.

In 2004, California voters approved Proposition 69, which required law enforcement officers to begin last year taking DNA samples from every adult arrested for a felony.

The program is accomplishing its purpose: identifying criminal suspects. In its first 18 months, DNA collected from arrestees has lead to the identification of 970 suspects of serious felonies. For example:

• DNA collected from Donald Carter, 56, arrested in Sacramento in 2009 on a felony drug charge, was linked to the unsolved 20-year-old murder of Sophie McAllister, 80. Although Carter's drug charge was dismissed, he was later charged with murder and his trial is pending.

• In April 2009, Christopher Rogers, 34, was arrested in Sacramento for assault with a deadly weapon, which was ultimately reduced to a misdemeanor. But his DNA, collected at the time of arrest, was matched to DNA taken at the scene of a 2004 murder in Sacramento. In October, Rogers was arrested and charged with murder. He awaits trial.

• In August 2009, Rene Hernandez, 26, was arrested in Watsonville for felony assault. His DNA was linked to a February 2009 sexual assault of a Watsonville woman, and he was arrested on multiple charges related to that crime. His trial is pending.

• In May 2009, Anthony Vega was arrested in Los Angeles County on felony drug charges, which were later reduced to misdemeanors. His DNA, collected at the time of arrest, was linked to two separate crimes committed in Orange County, a burglary in 2007 and a 2008 armed home invasion robbery. A preliminary hearing is scheduled.

• Earlier this year, Joshua Graham Packer, 20, was arrested in Santa Barbara on armed robbery charges. His DNA was matched to a sample taken at the site of an unsolved 2009 triple murder in Ventura County. He was arrested for that crime in April and charged with murder.

Oral arguments in the case were scheduled today in the Ninth Circuit United States Court of Appeals at Seventh and Mission streets in San Francisco.

Attached are briefs filed in the case. An earlier press release on the DNA felony arrestee program can be found at http://ag.ca.gov/newsalerts/release.php?id=1936&

LOS ANGELES – In less than two years, a new and controversial DNA searching program launched by Attorney General Edmund G. Brown Jr. has proven its worth by nabbing a man suspected of being the “Grim Sleeper” who carried out the murders of at least 10 women in the Los Angeles area over the past 25 years.

Lonnie David Franklin, Jr., 57, of Los Angeles, was arrested yesterday on multiple murder counts after the state DNA lab uncovered a DNA link between the murder-scene material and Franklin’s son. Last year, the son was convicted of a felony weapons charge, and his DNA was collected and sent to the state DNA data bank for the first time.

“In the face of a multitude of objections, we’ve crafted a balanced policy to respect the rights of citizens and at the same time deploy the most powerful DNA search technology available,” Brown said. “Forensic scientists at our Richmond crime lab have developed unique computer software and rigorous protocols that can link a family member of a convicted offender with DNA taken from a murder or rape scene. The successful match in this case demonstrates the extreme importance of this new forensic procedure.”

California became the first state to adopt a familial search program in 2008. It has been used only ten times since its inception in November 2008. The initial familial search under the new program that same month was aimed at finding the “Grim Sleeper” suspect, but it failed to find a relative in the database. A second search initiated on April 28, 2010, was successful because, in the meantime, Lonnie David Franklin’s son had been convicted, his DNA analyzed and linked to the crime scenes in accord with California’s unique familial search procedures.

The suspect would still be at large except for the familial search program.

Familial search works by searching the crime scene sample against convicted offenders in the state database to see if they could be related to the crime scene sample. The convicted offenders are compared to the crime scene sample by looking at how many of the DNA markers are shared and how rare the markers are.

Last month, investigators established a connection between Franklin’s son's DNA and DNA taken from the murder scenes. After corroboration with other information, such as google mapping and where Lonnie David Franklin was living during the time the murders occurred, it was determined that Lonnie David Franklin was a viable suspect.

The Los Angeles Police Department then confirmed our finding by taking the suspect’s personal DNA.

Familial DNA searches are done under rigorous guidelines established by Brown’s office. They are only allowed in major violent crimes when there is a serious risk to public safety and all other investigative leads have been exhausted.

“Now we’ve proven how important this forensic technology is by tracking down a suspected serial killer who terrorized Los Angeles for more than two decades,” Brown added.

By following rigorous protocols, scientists from the DOJ Bureau of Forensic Services were able to identify an offender in its DNA Data Bank who did not match the crime scene DNA profile of the Grim Sleeper, but shared sufficient genetic characteristics that ranked him high on a list of potential first-order male relatives, such as a father/son relationship or a brother/brother relationship.

Brown’s lab conducted further testing of the DNA on the Y-chromosome of the offender and compared it to the crime scene Y-chromosome DNA profile, in order to corroborate or disprove the theory that they are close relatives. The Y-chromosome profiles matched, indicating a strong possibility that they are paternal relatives.

State agents then reviewed additional information to corroborate or disprove the theory of kinship. The information collected showed that Franklin was a viable suspect in the murders.

Finally, the Familial Search Committee, a body created to verify familial DNA search results, reviewed all available data. The Department of Justice then provided the name of the database offender to the Los Angeles Police Department as an investigative lead, asserting a reasonable probability that the offender, while not the perpetrator, is a close relative.

The Grim Sleeper

The serial killer known as the “Grim Sleeper” is believed to have committed at least eleven murders and one attempted murder in Los Angeles since 1985. The crimes have been linked by DNA evidence, but until the familial DNA match, there was no suspect in the case.

The Grim Sleeper’s eleven victims include ten women and one man between the ages of 14 and 36 years. All of the victims were strangled or shot and most were dumped in alleys in Los Angeles.

California’s DNA Data Bank

At California’s DNA Data Bank, formally established in 1990, offender and arrestee samples are analyzed every day at the Jan Bashinski DNA Laboratory located in Richmond, CA. Each day, local law enforcement agencies submit offender and arrestee samples in an effort to solve an unsolved case such as a burglary, sexual assault or homicide. These samples are analyzed and uploaded into CODIS (Combined DNA Index System) otherwise known as the CAL-DNA Data Bank.

The state’s forensics laboratory has the fourth largest DNA database in the world with more than 1.5 million convicted offender and arrestee DNA profiles and a hit rate of more than 300 hits per month. Each month the lab processes up to 25,000 and 30,000 offender/arrestee samples. Weekly, offender/arrestee sample DNA profiles are uploaded to the DNA database and searched against forensic evidence DNA profiles from crime scenes submitted by local California crime laboratories and the rest of the nation.

LOS ANGELES – Attorney General Edmund G. Brown Jr. announced today that California’s ground-breaking familial DNA search program -- enacted in April 2008 -- led to the identification and arrest of the man accused of being the 'Grim Sleeper' serial murderer.

“This arrest provides proof positive that familial DNA searches must be a part of law enforcement’s crime-fighting arsenal. Although the adoption of this new state policy was unprecedented and controversial, in certain cases, it is the only way to bring a dangerous killer to justice,” Brown said.

“This is an extraordinary piece of detective work accomplished by our skilled forensics team at the Department of Justice,” Brown added.

Lonnie David Franklin, Jr., 57, was arrested this morning by Los Angeles police, and the Los Angeles District Attorney planned to charge him later today with 10 counts of murder and one count of attempted murder, all with special circumstances.

The suspect would still be at large except for a controversial policy change Brown pushed through, over concerted opposition, that allowed familial DNA searches where there is great risk to public safety. California is the first state to use familial searches, and today’s arrest is proof that the new technique works.

The familial search process involves using the DNA of family members to find suspects through the state’s DNA Data Bank. Last year, the DNA of one of Franklin’s family members, who had been convicted of a felony weapons charge, was entered into the DNA Data Bank. Last month, a familial search was conducted, and late last month, investigators established a familial connection between the family member and DNA collected at the murder scenes. That connection was used to identify and arrest Franklin after his DNA was obtained.

Familial DNA searches are done rarely – and only under rigorous guidelines established by Brown. They are only allowed in major violent crimes when there is a serious risk to public safety and all other investigative leads have been exhausted.

Brown will reveal more details tomorrow at a press conference in Los Angeles.

When: Thursday, July 8, 2010 at 11 a.m.

Where: Los Angeles Police Administrative Building, 100 West 1st Street, Los Angeles 90012

Who:

Attorney General Jerry Brown
Los Angeles County District Attorney Steve Cooley
Los Angeles Police Chief Charlie Beck
Mayor Antonio Villaraigosa, City of Los Angeles (Tentative)

LOS ANGELES – Attorney General Edmund G. Brown Jr. today announced the arrests of nine people in a San Bernardino County Medi-Cal fraud case in which employees of a skilled nursing facility and their associates falsified documentation and “callously stole” more than $150,000 from patients and their families for their own personal use.

“This scam ripped off both senior citizens and our desperately needed public health funds,” said Brown. “These thieves callously stole thousands of state dollars meant to be spent on seniors in this skilled nursing facility.”

The investigation was launched in January by the Attorney General’s Bureau of Medi-Cal Fraud and Elder Abuse after an initial investigation by the state’s Department of Health Care Services.

Brown’s office charged employees and associates at Community Extended Care Hospital of Montclair with committing Medi-Cal fraud in order to steal assets from the trust accounts of elderly patients, which were held by the facility.

From 2006 to 2009, several employees of the extended care hospital conspired with a former San Bernardino County employee who fraudulently submitted documentation to the Medi-Cal program so that Medi-Cal would pay the entire monthly bill for more than 50 patients in the facility.

Then the conspirators told patients and their families they were required to pay a share of the cost of their care directly to the facility. The payments made by the patients and their families were then placed in patient trust accounts, and the suspects took that money for their own personal gain.

The scam involved hospital employees writing checks, ranging from $250 to $6,900, from the patient accounts to individuals in the gang, including a UPS driver, their own relatives, and a next door neighbor, who would then cash the checks, take a percentage of the stolen funds and return most of the cash to the hospital employees. The checks were approved by officials at the hospital.

Nine suspects were arrested this morning and are now in custody at San Bernardino County Jail. Bail was set for $1 million on each defendant. One suspect, Maribel Velazquez, is still at large.

The ten individuals charged in the crime are:

Johannes Simanjuntak, 59, of Pomona, a former administrator at the hospital
Peggy Lee Hoskins, 58, of Upland, a former personnel manager at the hospital
Laurie Diane Powell, 46, of Riverside, former San Bernardino County employee
Sean Matthew Ashton, 22, of Riverside, Powell's son
Andy Perry Tricas, 46, of Duarte, boyfriend of suspect (now deceased)
Arnon Graham, 50, of Rancho Cucamonga, UPS driver
Claudia Zaragoza, 34, of Bloomington, Social Services designee
Orelious Antonio Peevy, 41, of Chino, Social Services designee
Maribel Velazquez, 36, of Chaparral, New Mexico, administrative worker at the hospital (not in custody)
David Carmona, 74, of LaVerne, neighbor of deceased employee

"Our anti-fraud partnership with the Attorney General's Office has once again helped protect our most vulnerable citizens and ensure that valuable Medi-Cal funds are used for their intended purpose,' said Karen Johnson, Department of Health Care Services Chief Deputy Director. 'We will continue our coordinated efforts as we work to prosecute offenders to the fullest extent allowed by law.'

The complaint is attached.

LOS ANGELES – Praising the “dedicated and courageous efforts” of local law enforcement officials, Attorney General Edmund G. Brown Jr. today released the California Department of Justice’s annual crime report for 2009, which continued the promising trend of declining crime rates in California, including a 6.6% reduction in the state’s violent crime rate.

“This latest drop in crime,” Brown said, “is good news for Californians and reflects well on the dedicated and courageous efforts of peace officers throughout the state. Yet it is no cause for complacency. Crime remains a serious problem in California, and law enforcement officials at every level must redouble their efforts to ensure public safety.”

“Crime in California 2009 - Advance Release” is compiled by the California Department of Justice based on data reported by police and sheriff’s departments in all of California’s 58 counties.

The 2009 figures, drawn from crime reports, show that crime rates have declined in every category of offense measured, from homicide (-8.9%) and robbery (-8.6%) to motor vehicle theft (-15.8%) and arson (-14.3%).

In fact, last year’s drop marked the third consecutive year in which violent crime (-6.6%), property crime
(-10.1%), and larceny and theft (-6.5%) rates have all declined. Almost 20,000 fewer violent crimes were committed in 2009 than in 2006.

Overall, since statewide crime peaked in 1992, crime rates in all three categories have been cut in half – the rates have tumbled -58.9% for violent crime, -51.7% for property crime, and -48.5% for larceny and theft. In total, more than 1.4 million arrests were made in California in 2009, down from more than 1.9 million 20 years ago.

Driving the downward trend were California’s five largest counties, all of which recorded significant crime rate declines from 2008 to 2009:

• Los Angeles: violent crime (-9%), property crime (-11%), and larceny and theft (-3.3%)
• San Diego: violent crime (-2.2%), property crime (-22.5%), and larceny and theft (-14.2%)
• Orange: violent crime (-3.6%), property crime (-10.5%), and larceny and theft (-3.7%)
• Riverside: violent crime (-13.4%), property crime (-12.4%), and larceny and theft (-11%)
• San Bernardino: violent crime (-4.5%), property crime (-11%), and larceny and theft (-8.7%)

For more detailed crime statistics and local data, please see the attached report and data tables.

LOS ANGELES – Attorney General Edmund G. Brown Jr. today announced a $173 million settlement with six manufacturers of Dynamic Random Access Memory (DRAM) computer chips who “conspired in an illegal global scheme to fix prices.”

DRAM is a common form of memory chip that stores information temporarily for quick access. It is found in desktop computers, laptops, servers, printers and networking equipment such as routers and hubs. DRAM sales to major electronic manufacturers, including Dell, IBM, and Hewlett-Packard, exceed $5 billion a year in the United States and $17 billion worldwide.

“These companies conspired in an illegal global scheme to fix prices on chips used in computer equipment sold to consumers, schools and government offices,” Brown said. “The large price tag of this settlement should serve as a warning that we will crack down on any manufacturers around the world that choose to gouge consumers through illegal price-fixing schemes.”

Brown and 32 other state attorneys general participated in the settlement. In July 2006, the multi-state group, led by California, filed a complaint in federal district court alleging that California’s consumers, state agencies, universities and local governments were forced to pay illegally inflated prices for products containing DRAM chips.

The DRAM manufacturers named in the lawsuit include the American companies Micron Technology, Inc. and NEC Electronics America, Inc., as well as foreign companies Infineon Technologies A.G. in Germany; Hynix Semiconductor, Inc. in South Korea; Elpida Memory Inc. in Japan; Mosel-Vitelic Corp. in Taiwan; and their American subsidiaries.

Brown’s investigation revealed that from 1998 to 2002, the salespeople and upper management of all the companies held frequent meetings, made telephone calls and initiated other contacts in which they exchanged confidential information and agreed to charge customers illegally inflated prices on DRAM chips.

The result of this collusion was to keep DRAM prices artificially high instead of letting market forces operate freely through competition.

The U.S. Justice Department called the scheme “one of the largest cartels ever discovered.” As a result of a federal investigation, four companies ¬-- Samsung, Hynix, Infineon, and Elpida – and 12 individuals have pleaded guilty to criminal price-fixing.

In October 2008, Brown filed a second lawsuit in state court in San Francisco on behalf of 96 local California government entities, including cities, counties, school districts, special districts, and the University of California, all of which had purchased computer equipment containing DRAM chips.

The settlement announced today requires the companies to refrain from illegal price-fixing and to conduct extensive employee-compliance training. The settlement must be approved by the court.

The defendants agreed to resolve both lawsuits, as well as lawsuits by private plaintiffs, by paying $173 million over two years plus interest to the affected consumers, schools and government offices. Samsung and another company, Winbond, reached settlement for $113 million in 2007.

“The settlement money is welcome,” Brown said, “but the illegal overcharging never should have happened in the first place. Especially when times are tight, schools and government agencies can’t afford to be ripped off by companies that violate our anti-trust laws to keep profits high.”

The other states participating in the settlement are Arizona, Arkansas, Colorado, Florida, Hawaii, Idaho, Illinois, Iowa, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Nebraska, Nevada, New Mexico, New York, North Carolina, North Dakota, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, Tennessee, Utah, Virginia, Washington, West Virginia, and Wisconsin.

Copies of the complaints are attached.