72D01-2412-MI-000061 Fle: taenae 255 Pt Scott Superior Court Scott County, indiana STATE OF INDIANA ) IN THE SCOTT COUNTY Superior CouRT. ) ss: COUNTY OF SCOTT ) CAUSENO: — 72D01-2412-MI-000061 SHERIFF JERRY GOODIN, in his official capacity as the Scott County Sheriff, Plainti JENNIFER RODE HAMELMAN, in her official capacity as the Scott County Auditor, SCOTT COUNTY COUNCIL, and SCOTT COUNTY COMMISSIONERS, Defendants. VERIFIED PETITION FOR EMERGENCY INJUNCTIVE RELIEF AND MANDATE ACTION Jerry Goodin, in his official capacity as Scott County Sheriff, by counsel, and in accordance with INDIANA CODE § 34-27-I-1, et seg., brings this Verified Petition for Emergency Injunctive Relief and Mandate Action (“Verified Petition”) against Jennifer Rode Hamelman, in her official capacity as Scott County Auditor, the Scott County Couneil, and the Scott County Commissioners. ‘THE PARTIES 1, Jerry Goodin is the duly elected Scott County Sheriff. Under Indiana law, the Sheriff is charged, inter alia, with the legal duty “to take cure of the county jail and the prisoners there.” INDIANA CoDE § 36-2-13-S(a)(7). ‘The Sheriff is also charged with maintaining law and order within the county. See INDIANA CopE §§ 36-2-13-5(a) & 36-8-10-9(a). The Sheriffis further responsible for prisoner transport, service of process, and court related/security services. See id. 2, Sheriff Goodin brings this Verified Petition in his official capacity as Scott County Sheriff.3. Jennifer Rode Hamelman is the duly elected Scott County Auditor. The Auditor serves as a fiscal officer of Scott County pursuant to Indiana Code. The Auditor is named in this action only in her official capacity 4. The Scott County Council (“Council”) is a fiscal body of Scott County and is legally obligated to make decisions with respect to the funding of the budget for the Scott County Sheriff's Office and the Scott County Jil 5. The Council, pursuant to its functions and responsibilities is required, on an annual basis, to approve the budget submitted by the Scott County Sheriff for the operation of the Scott County Sheriff's Office and the Scott County Jail. 6. ‘The Council knows or should reasonably know all relationships that exist among the various funds of the County and how Council actions or omissions may affect County departments and offices subject to the annual County budget. 7. The Scott County Commissioners (“Commissioners”) are the county executive for Scott County and are responsible for approving all claims tendered to them by the Scott County ‘Auditor, which includes claims tendered for payment associated with the Scott County Sheriff's Office. 8. The Commissioners are also required by law to establish and maintain a county courthouse, a county jail, and an office for the Sheriff. INDIANA Cope § 36-2-2-24. FISCAL OBLIGATIONS 9. The Council is legally required to provide proper fiscal monetary support for the Sheriff's Office budgets, including its payroll and operational budgets. The Council is required by law to be the primary budget source of support for the Sheriff's Office so that services may be delivered to the citizens of Scott County.10, Sheriff Goodin has historically relied upon the legal obligations of the Council to carefully consider and approve the annual county budget so that the Sheriff's Office may adequately and competently manage the Scott County Jail, perform all necessary court-related functions, and perform all other necessary law enforcement services to aid in the protections and safety of Scott County citizens. 11, The Sheriff's Office is primarily funded by three sources: (a) the General Fund, (b) a LIT Public Safety Account Fund, and (c) a LIT Special Purpose Account Fund. ‘There are also 1a few, smaller, specialized sources from which limited funds can be drawn, 12. The LIT Special Purpose Account Fund can only be used to operate the Scott County Jail. ‘The LIT Public Safety Account Fund can only be used for public safety expenses. ‘The General Fund contains both obligated and unobligated funds that are to be used to operate the Scott County government ~ including the Sheriff's Office. 13. Sheriff Goodin was elected by the Scott County citizens in 2018, He was re-elected in 2022. Indiana law limits an individual to serving two terms as a county sheriff. INDIANA COnsTITUTION, Article 6, § 2 (a) & (e). 14. Since 2019, the Scott County SherifP's Office has had expenditures. ranging between $3,280,000 and $3,780,000 annually. (Exhibit A). Historically, total appropriations to the Sheriff's Office have been sufficient to cover these expenditures. (Id.). 15. In 2023, the Sheriff's Office had $3,894,120 in total appropriations. (Id.). 16. In October 2023, the Council enacted a pay rate for the Sheriff's Office and its employees. (Exhibit B). The 2023 pay rate locked Sheriff's employces into a fixed pay rate. This 2023 Council decision repealed the pay matrix that had been in use by the Sheriffs Office sinceNovember 2019. (Id.). This decision made the Sheriff's Office a less competitive employment option in the region. 2024 EXPENDITURES 17, In 2024, the amount of initial appropriations was reduced to $3,160,756. 18. Notably, of these 2024 monies, no funds were appropriated/budgeted for jail ‘maintenance despite the County Executive's express statutory duty to maintain the county jail in good working order. Also, no funds were appropriated/budgeted for the annual payment of three pre-existing truck purchase contracts with the Ford Motor Company. As a result, the Sheriff's Office was forced to borrow 2024 jail maintenance funds from the maintenance budget for the Scott County Courthouse until sufficient funds were reappropriated for these necessary jail expenses.! 19. The Sheriff Office currently employees: (a) sixteen full-time jailers, (b) eleven full- time deputies? (c) three full-time school resources officers, (d) two full-time courthouse employees, and (¢) four administrators, including the Sheriff. It also currently employs: (a) fourteen part time jailers, and (b) six part time deputies. 20. The Scott County Jail currently houses an average of 165 inmates and detainees. 21. The Council’s October 2023 decision to eliminate the pay matrix made employment at the Scott County Sheriff's Office less competitive than the surrounding job market. See Inte Court Report Salaries in Knox Circuit and Superior Courts, 713 N.E.2d 280, 282 (Ind. 1999) (“Salaries being paid for comparable positions in both the private and public sectors are relevant {in an mandate action”), 1 In like manner, in 2023, the Sherif Office was forced to raid its commissary/discretionary funds to purchase necessary equipment and to pay certain jail maintenance and prisoner expenses. 2 The Sheriff's Office also employs a full-time detective funded by a prant from Morgan Foods. 422. As a result, three deputies left the Sheriff's Office in 2024. In tum, existing employees were required to work overtime to cover these former employee's shifls. Employee morale has also been negatively impacted. 23, Although the employment numbers had changed, the Sheriff’ Office's responsibilities for public safety and prisoner maintenance had not, These shifts must be filled. 24. Due to the Council’s acts and omission, including, but not limited to, a failure to appropriate sufficient funds for necessary jail and law enforcement operations, a dispute has arisen regarding the funding of the Scott County Sheriff's Office and the Scott County Jail 25, More significantly, the Commissioners/Council are delaying and/or refusing to approve payment by the Auditor of legitimate jail expenditures, including, but not limited to, ‘outstanding invoices for prisoner medical expenses and necessary jail repairs. End of year (2024) statements provided by the Sheriff's Office estimate that the expenses will be approximately $337,000. The LIT Special Purpose Account, which may only be used for jail expenses, has more than sufficient monies to pay these outstanding bills and invoices. 26. The Commissioners/Council are also delaying and/or refusing to approve the Sheriff Office’s remaining payroll expenses in 2024 despite the fact that more than sufficient unobligated funds remain in the County's General Fund. 27. The Indiana Court of Appeals has recognized “the special and complex nature of maintaining jail facilities.” Lake County Board of Commissioners v. Martinez, 199 N.E.3d 366, 372 (Ind. Ct. App. 2022), transfer denied, 208 N.E.34 1254 (Ind. 2023), 28. Under Indiana law, a county sheriff “occupies a constitutionally created office that is separate from the county executive.” 1d., at 373. It is, thus, the county sheriff who “is charged with actual administration of the jail and treatment of prisoners.” Id.29. A county sheriff, therefore, “has the authority, and in fact, the duty, to enter into contracts to carry out this {take-care] function.” Id. at 372 (noting, for example, that the county sheriff's “legal duty to provide and pay for medical services for prisoners necessarily requires authority to contract for such medical care.”) 30. County commissioners are simply “ required to build and maintain a county jail, that duty extends only to keeping it open and in good repair.” at 373 31. And, although Indiana law provides for the Commissioners and the Council to have ‘a check on the Sheriff's Office through the budgeting process, “it does not allow [these officials] to abuse that discretion by refusing to pay valid invoices submitted by officials for budgeted items that have been fully appropriated and for which the funds remained unencumbered.” Id. 32. Yet, itis precisely such abuse that is occurring in Scott County. 2025 Bupcer 33. Sheriff Goodin submitted 2025 Budget Estimates for the Sheriff's Office to County officials in a timely manner. 34. The Sheriff estimates that an appropriation of $4.1 to $4.5 million dollars will be necessary for the Sheriff's Office to perform its statutorily mandated duties in 2025.? 35. The Scott County Council made no attempts to discuss the Sheriff Office's 2025 Budget Estimates with Sheriff Goodin. The Council also refused to provide Sheriff Goodin with a copy of any proposed 2025 Budget before publication of the 2025 Budget. 36. Indiana law provides that annual county budgets are due from the County Council ‘each year. 3 Notably, this estimate includes a $400,000 to $500,000 increase 10 replenish the funds in the ccommissary/discretionary account that has been used by the Sheriff's Office to purchase equipment and subsidize its operations. See supra.37. On or about November 1, 2025, the County Council published the 2025 County Budget. (Exhibit C). 38. Sheriff Godin's proposed 2025 Budget was rejected out-of-hand. 39. The County Council’s published 2025 County Budget approved appropriations to the Sheriff's Office for only the First Quarter for 2025 ~ not 2025 annually. More significantly, the 2025 County Budget adopted by the Council makes dramatic reductions to the funding of the Sheriff's Office on the whole. It provides total annual appropriations of only $1,722,901. (Id. This amount is less than one-half of the total funds appropriated to the Office in 2024, (Exhibit 4). 40. The 2025 County Budget includes no fiunds for jail maintenance. (Exhibit C), 41. The 2025 County Budget also includes no finds for the twenty part-time employees currently working as jail personnel and/or deputies. (Jd.). 42. The 2025 Budget is wholly unreasonable and contrary to Indiana law. ‘The acts and omissions by the County Council should not be countenaneed by the Court Improper Morives 43. Upon information and belief, the Council’s refusal to provide proper monetary support and/or the Couneil’s decision to cut the proposed Sheriff Office 2025 Budget was solely for the purpose of conducting a personal and political vendetta against Sheriff Goodin. 44, Sheriff Goodin is but one of four current Seott County official that is a member of the Democratic Party. Upon information and belief the Council had not delayed payments of ‘The 2025 County Budget is also woefully deficient in other areas. For example, it appropriates only $12,500 (law-enforcement) and $250 (jail) for fuel annually. (Exhibit C). Historically, fuel costs for each have been in excess f $75,000 per year. It also provides only total of $125 (law-enforcement) and $100 (ail) for uniform expenses in 2025 for all Sheriff Office employees collectively. (id.). By way of comparison, a single bullet-proof vest costs in excess of $750. Similar uniform cuts were made in 2024, 7legitimate expenses or drastically reduced the annual budgets of Republican County officials and/or departments led by Republican County officials, 43. ‘The current seven-member Council, all elected from the Republican party, is led by James “J.R.” Ward (President) and Lyndi Hughbanks (Vice President). 46. President Ward is a former deputy of the Sheriff’'s Office. President Ward recently wrote at least one contiguous County Sheriff: (a) disparaging Sheriff Goodin, and (b) stating that Scott County could not assure timely payment of per diem expenses charged to Scott County for the out-of-county transfer and maintenance of Scott County Jail detainees/inmates. (Exhibit D). 47. Upon information and belief, Vice President Hughbanks recently shared a document addressing how to defund a sheriff's office in reply to a group email. The Sheriff's Office is engaged in an ongoing effort to retrieve a copy of the alleged email and document. RAMIFICATIONS 48. The Couneil’s delay, failure, and/or outright refusal to pay legitimate 2024 expenditures is impeding Sheriff Goodin’s ability to properly operate the Office. Legitimate expenditures, including those for prisoner medical care and necessary jail repairs, have not been paid and are past due. Sheriff's Office employees are being threatened with the non-payment of salaries and wages. In addition to the immediate difficulties these facts present, they also open both the Sheriff's Office and the County, at large, to civil liability for breach of contract and wage- payment violations. 49. The Council’s decision to substantially cut the Sheriff Office’s 2025 Budget has even more dramatic ramifications. It will make it all but impossible for the Sheriff to continue to operate the Scott County Jail, perform all necessary court-related functions, and provide lawenforcement protection to the citizens of Scott County. All of these activities and responsibilities ‘are mandated by Indiana law. See INDIANA CODE §§ 36-2-13-S(a) & 36-8-10-9( 50. First and foremost, the 2025 Budget will require the Sheriff's Office to lay-off or terminate all twenty of its part-time employees.* This will leave the Scott County Jail significantly ‘understaffed. This fact, in tur, will jeopardize prisoner care as well as jeopardize both prisoner and jailer safety. The lack of part-time employees will also require the Sheriff to transfer Sheriff deputies and, perhaps, even court security staff, to jailer positions. This fact, in tum, will create a dearth of law enforcement personnel in the community. Citizen safety and public order will be compromised as a result 51. The lack of jail staff will also require the Sheriff's Office to transfer Scott County prisoner to surrounding county jails.® The Scott County Jail currently houses an average of 165 prisoners. If the Sheriff's staff and budget is reduced by approximately one-half, then the Scott County Jail will only be able to safely house and maintain 45 to 50 inmates and detainees. ‘The transfer of two-thirds of the jail population is neither practical nor fiscally sound. ‘Transferred inmates and detainees will still have to be transported by the Sheriff's Office to attend criminal proceedings in Scott County. This will further overextend the responsibilities of an already grossly understaffed Sheriff"s Office in 2025. It will also create an added transportation expense. 52. More significantly, the transfer of approximately two-thirds of the jail population is financially irresponsible, Scott County prisoners are maintained at the Scott County Jail at approximately $10.00 per day each, However, prisoners transferred from the Scott County Jail 5 As the 2025 Budget is effective on December 23, 2024 these lay-offsterminations will oecur immediately before the Winter holidays. ® Im fact, $0 to 60 female detainees/inmates are scheduled to be transferred to the Clark County Jail on Wednesday, December 11, 2024. The Sheriff's Office is currenlly discussing the transfer of up to 60 male |$_42300|$ 274,558.00 | $ 274,558.00 | $ $ 2 ures 1170 Jail [$683,465.00 a 3 = [$683,465.00 | $ (683,465.00 | $ = $ General 1000 Jail [$783,143.00 S___763,143.00/$ 783,143.00 $ $ ; ursp ana S__437,700.00|$ 329,100.00 | $ =_[S__ 766,800.00 | $ 728,892.00 | $37,908.00 $ 3,125,188.00 $ 342,900.00 $ 1,123.00 $ 3,469,211.00 $ 3,282,479.00 $ 186,732.00 2022 UTPS 1170 Sheriff [$299,504.00 3 = [$239,504.00 $ 246,776.00[$ 52,728.00 ee $ S General 1000 sheriff [§ $83,096.00 | $ z 3 993,036.00 | $ '953,448.00|$ 39,652.00 $ urPs 1170 Jail [$837,079.00 $s =_ [$837,079.00 | $ 818,246.00 |$ 18,833.00 $ - General 1000 Jal [S$ 521,98400| $517,984.00 | $ 511,911.00 | $ 73.00 $ 5 use 114 $1076 73600|$ 125,000.00 | $ = |[$__i201,716.00[$ 1,201,036.00 | s 680.00 ‘S$ 3,718379.00 $ 125,000.00 $ - $ 3,843,379.00 $ — 3,731,413.00 $ 111,966.00eves ures 1170 sheritt [§1,074,617.00] § 38,048.00 $1,112,665.00 $ 879,973.00 $ 232,692.00 General 1000 Sheriff [$175,980.00 $175,390.00 | $ 324,727.00 | $ (148,737.00) urps 1170 Ja! [$791,496.00 '9/861.00 $801,357.00 | $ 943,071.00 | $§ (243,734.00) General 1000 sat [$517,984.00 3 sii,98a00| § 541,035.00 | $__ (29,053.00) ursp uaa S_3242,124.00/ $ 50,000.00 $_4,292,124.00 |S 1,345,341.00| 5 146,783.00 $ 3,796,211.00 $ 97,909.00 $ - $ — 3,894,120.00 $ — 3,834,147.00 $ 59,973.00 2024 ures 1270 Sheriff [$573,286.00 General 1000 Sherif [$404,548.00 I urps 1170 Jail [$632,854.00 $ 75,000.00 ie ct General 1000 Jail [$655,548.00 am ursp ana S_1299,068.00[$ 110,000.00 z $ 3,565,304.00 $ 185,000.00 $ - $ oe = 2 Z Original Approrpriaticdditional Appropriatic Adj Total Appropriation Expenditure ‘Unexpended 2017 > $ 2,646,400.00 $ 24,584.00 $ 44,482.00 $ 2,715,465.00 $ — 2,715,465.00 $ - 2018 $740,781.00 $ 2,295,678.00 $ 19,704.00 $ 3,056,163.00 $ — 2,979,968.00 $ 76,195.00 “2015 $2,879,019.00 $ —4,209,452.00 $ 3,000.00 $ 4091,471.00 $ — 3,778,109.00 $ 313,362.00 2020 $ 3,321,645.00 $ 30,000.00 $ 108,579.00 $ 3,460,224.00 $ — 3,491,181.00 $ (30,957.00) 2021 $ 3125,188.00 $ 342,900.00 $ 1,123.00 $ 3,469,211.00 $ —3,282,478.00 $ 186,733.00 2022 $ 3,718,379.00 $ 125,000.00 $ - $ 3803,379.00 $ — 3,731,411.00 $ 111,968.00 2023 $ 3,796211.00 $ 97,909.00 $ 3,894,120.00 $ — 3,834,147.00 $ 59,973.00 2024 $ 3,565,04.00 $ 185,000.00 $ — 3,750,304.00 $ 13,044,231.00 $ — 1,707,352.00 $ 112,702.00 $ 14,864,285.00 $ — 14,283,179.00 $SCOTT COUNTY COMMON COUNCIL, INDIANA RESOLUTION 203-_.5 A RESOLUTION REGARDING “SHERIFF'S MATRIX” WHEREAS, the current riff has provided the current County Couneil with a “Pay Matrix’ WHEREAS, after a dil ordinance adopting this matrix; ent search of its récords, the County Couneil ean find no WHERAS, after a diligent scarch of its recorcis, the County Couneil has located minutes from November 12, 2019 wherein the Council moved to adopt the matrix, however no ordinance adopting the matrix was entered, instead a salary ordinance was entered without a matrix attached: NOW, THEREFORE, BE IT RESOLVED BY THE COMMON COUNCIL OF THE COUNTY OF SCOTT, INDIANA, o the extent that any matrix regarding pay for the Shei Department employees was enacted, said matrix is hereby repealed and null and the Sheriff's officers shall be paid as determined by Salary Ordinance pursuant to I.C. 36-2-5-11 NOW, THEREFORE, BE IT FURTHER RESOLVED BY THE COMMON COUNCIL OF THE COUNTY OF SCOTT, INDIANA, that Sheriff Department Employces shall be cligible for longevity pay in accordance with the Scott County Employee Handbook. PASSED AND ADOPTED BY THE COMWON COUNCIL OF THE COUNTY OF SCOTT, INDIANA on this 24" day of October, 2023. COMMON COUNCIL COUNTY OF SCOTT, INDIANA Heh thildaud— Cyndi Hughbanks, Prifident eb le fit hth Jonathan White, Counci eHBITwl) Miller, Coudeilman nus, Collins, Iman Lig: Ee Gillespic, Councilffran Diane Mullins, Councilwoman fas fe. Fee 2 Ue cles _ Perit Famelman / Auditor, Seett County IndianaBe SS 3a) =} Ze fase = eae dongBudget Form 1 - Sheriff/Jail Year, 2025 County: Scoit Unit Scott County [Nenerel sharie? tied el ‘Aecount "and Lecton |picrisaon —“AeourtDeserpton [beecrpton 12% set cox 10 ‘ome cos 7 — ce ‘cos ‘0 oxo pms i i wy oxo i 170 ase oe con 9 se ox os 82S 88S e S8B8 Bes Beees SF BEE BEa BRR RRR SRR RR EHR ek see NASSSaK SES ES BEEEEEEEEEEE eaee88882 988 1S a 8 seggg° aa GEggaa & SEEGERES BEGGS EEQGQEQGRELEGRREEEEEEEEE EEGESESEREE BERBER EB EB EE EEEREEEEEEE EEEEEE EEE EEE aePEEP G GG EE es oe Z2ag2 es eee g ga PEGLEGES GEG EE gal eanageneea Blaeensa rr sore ozs 13nM jason oxo 768 NODEPARTWENT SERVES ARS |Fitesure Sevens entunton 0 1 ' ‘CHARGES Ws p= exes 0 INODEPARTWENT SERVICES ND ensreitenicesEavpmen Raper a canoes i m4 ‘soo 000 020 NODERAATMENT senaces WO Uy Sms = rocemmmest REC — ohetnanme salt Omid saree 1 sor ‘ooo cam NODRPIRTIENT |SESWEERNO Chantal Coancte ta op sresee uM sen coe iP NO DRPIRTIET —SERWGER WO Ofer ath He pert s2sn0e ws asim joao Cy jpODePanriexT SEIWEES AKC Obm Seven —“Ustms ecvnt 500 i ha eo vopemniat SEMCEE RO Ghee oteTSERCE srissee me see ‘000 om |NODEPasTWeNT CAPITAL OUTLAYS smn Endprit,[Eppnen Prchane * § NODEPHRIMENT [SERVCESANG— Poiemunal Sevens Conch Sercer et lounces per ra rr Sree Cesena PERSONAL SERVES Sowa end Mager Sabet Reece OB) aes 00 e000 020 MO DEPARTMENT PEREONNLSERICES EneeysBewir |FCA(Se Sects) * a oe e000 om RODEPARTMENT PERSONAL SERVCES Ensen ‘Shea Pemion © oe ‘00 x00 con NODEPATTMENT PERSONAL SERUCES. Erpye ints Unni = es +2000 00 oxo NODEPATMENT PERSONAL SERVICES Erglyee Bene Ovleed Cone = an sun jon on IMODEPARTAENT FEROHDL SERVCEE Engle Denes Wotmars Conprsfon » ae 200 oom eS JPODEPARTMENT —SERVCEEAND amen Grp ties = TeFrom: Ben Flint Sent: Friday, November 8, 2024 7:57 PM To: James Ward Subject: Re: Scott Co. Hello Sit am sorry to hear this. have not heard from Sheriff Goodin as per the Rumor that you asked ebout in your mailto me. However, | know Sheritf Goodin seems to be highly respected Sherif within the indiana Sherttfs Association and as always seemed very open and willing to communicate. Itseems unfortunate that your county is having these issues. But being a fellow Sheriff lke Jerry, | know that my staft's safety as well as the inmate's safety is paramount. With thet being said, if Jerry feats that he needs to ‘downsize his inmate population for the sefety and security of his fecility thet he is the ony one that can make that ‘oall, as he is the elected Sheriff for your county. would personally prefer with all due respect it you would try and work these issues out with Sheriff Goodin. Ifyou hear rumor’s then go to the person and ask them instead of going behind their back and trying to drag another County's Sheriff into the mess by airing dirty laundry. To answer your question at this time | have not been asked to hold any inmates. ‘Aiso, as I'm sure you already know the Sheriffs Association in Indiana is a very helpful organization. We all try and help each other out in atime of need . Ihave picked up the phone in the past and called Sheritt Goodin as well as, other Sherif's to watch anc Inmate or two over the years and they will do it without question as | would do the same for them. want Scott County to be a strong and prosperous county as they are @ neighbor to us. Like neighbors should, we ‘try and help each other out. If you have eny further questions or concern’s, pleese reach out. Thanks, Sheriff Flint Get Outlook From: James Ward riday, November 8, 2024 12:51:35 PM ‘To: Ben Flint Subject: Scott Co. Sheritt, was alerted of @ rumor floating eround our county and wanted to address it with you. | have boon told that our Sheriffs threstening to move multiple inmates to your facility because he Isn't happy withidget for 2025. W lieve he is full of scare tactics and plays the bully part of life well | do ounty to be placed in a situation where you are trying to help and get caught up in this mess 10 know that our county is undergoing e serious financiel crisis that has been created b spending his 2024 budget by nearly one million dollarsi! Therefore, should you and your county decide to house inmates | would caution you thet funds are not readily available to pay your c ice. And you would likely be waiting a ‘ong period of time to be reimbursed for money and cere of inmete @ possible bond acquirement transparent with you and not place eny future plans betu unties in jeopardy ervice you should decide to pr: