Petition for Writ of Certiorari — Daviel Salinas-Acevedo, Petitioner v. United States

No. ____-________

IN THE SUPREME COURT OF THE UNITED STATES

DAVIEL SALINAS ACEVEDO,

Petitioner,

v.

UNITED STATES OF AMERICA

Respondent.

On Petition for a Writ of Certiorari to the United States

Court of Appeals for the First Circuit

___________________________________

PETITION FOR WRIT OF CERTIORARI

___________________________________

Ignacio Fernández de Lahongrais

Court Appointed Attorney for Appellant

Capital Center Sur, Suite 202

Avenida Arterial Hostos #239

San Juan, Puerto Rico 00918-1475

Tel. 787-923-5789

ignacio@bufetefernandezalcaraz.com

(Appointed under 18 U.S.C. § 3006A)

i

QUESTION PRESENTED

In Jacobson v. United States, 503 U.S. 540, 112 S. Ct. 1535

(1993) this Court ruled that predisposition to commit a crime

is the principal element in the defense of entrapment. It

further held that a prosecutor must demonstrate beyond a

reasonable doubt that a defendant was predisposed to commit

the crime before being approached by law enforcement.

The question presented is:

1.

Does the Fist Circuit’s requirement that a defendant must

prove an entrapment defense twice: once to the court

prior to trial, and then once more to the jury run afoul

of Jacobson and the Sixth Amendment to the Constitution

of the United States?

ii

TABLE OF CONTENTS

QUESTION PRESENTED. . . . . . . . . . . . . . . . . . . . ii

TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . iv

TABLE OF AUTHORITIES. . . . . . . . . . . . . . . . . . .

v

PETITION FOR WRIT OF CERTIORARI . . . . . . . . . . . . .

1

OPINIONS BELOW. . . . . . . . . . . . . . . . . . . . . .

1

JURISDICTION. . . . . . . . . . . . . . . . . . . . . . .

1

BASIS FOR JURISDICTION IN THE DISTRICT COURT. . . . . . .

2

CONSTITUTIONAL PROVISION INVOLVED . . . . . . . . . . . .

2

STATEMENT OF THE CASE . . . . . . . . . . . . . . . . . .

3

REASONS FOR GRANTING THE WRIT . . . . . . . . . . . . . . 11

CONCLUSION. . . . . . . . . . . . . . . . . . . . . . . . 18

CERTIFICATE OF COMPLIANCE . . . . . . . . . . . . . . . . 19

CERTIFICATE OF SERVICE. . . . . . . . . . . . . . . . . . 20

APPENDIX. . . . . . . . . . . . . . . . . . . . . . . . . 22

iii

TABLE OF AUTHORITIES

I.

CASES

Hampton v. United States, 425 U.S. 484 (1976) . . . . . . 12

Jacobson v. United States, 112 S. Ct. 1535 (1992) . . 3, 11,

12, 14, 16, 17

Mathews v. United States,485 U.S. 58 (1988) . . . . . . . 13

Sorrels v. United States, 287 U.S. 435

(1932). . . 3, 6, 13

United States v. Luisi, 482 F.3d 43 (1st Cir.2007). . 13, 15

United States v. McGill, 754 F.3d 452 (7th Cir. 2014) . . 15

United States v. Russell, 411 U.S. 423 (1973) . . . . . . 12

United States v. Salinas Acevedo,846 F.3d 417 (1st Cir. 2017)

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

United States v. Whoie, 925 F.2d 1481(D.C. Cir. 1991) . . 12

II.

STATUTES

28 U.S.C. §1254(1) . . . . . . . . . . . . . . . . . . .

2

18 U.S.C. §3500 . . . . . . . . . . . . . . . . . . . . . 13

iv

PETITION FOR WRIT OF CERTIORARI

Petitioner Daviel Salinas Acevedo (“Daviel Salinas”),

through his court appointed attorney, prays that a writ of

certiorari be granted to review the judgment of the United

States Court of Appeals for the First Circuit issued on

January 17, 2017.

OPINIONS BELOW

On January 13, 2017 the United States Court of Appeals

for

the

First

Circuit

entered

its

judgment

and

opinion

affirming Petitioner’s conviction. United States v. Salinas

Acevedo, 863 F.3d 13 (2017).

A copy of that Opinion is

attached as Addendum 3. Denial of petition for reconsideration

and rehearing en banc in the United States Court of Appeals

for the First Circuit was entered July 11, 2017. A copy of

that Judgment and Opinion is attached as Addendums 1 and 2

respectively.

JURISDICTION

Denial of petition for rehearing in the United States

Court of Appeals for the First Circuit was entered July 11,

2017. Thus, the original deadline to file a petition for a

writ of certiorari was October 9, 2017.

1

On October 2, 2017 this honorable Court entered Order

extending the “deadline to file a petition for certiorari in

a case arising from the state or federal courts of Puerto Rico

... to November 20, 2017.” 583 U.S. ____. This case arises

from the United States District Court for the District of

Puerto Rico.

On November 13, 2017 Petitioner Filed an Application for

Extension of Time to File Petition for Writ. Said application

was granted and extended the time to file the petition until

December 8, 2017.

A Petition for Writ of Certiorari was then filed on that

date, December 8, 2017. The Petition was returned by the Clerk

of the Court on December 18, 2017 with instruction that it be

re-submitted within 60 days. Thus the Petition must be filedon

or before February 16, 2018.

The jurisdiction of this Court is invoked under 28 U.S.C.

§1254(1).

BASIS FOR JURISDICTION IN THE DISTRICT COURT

The District Court had jurisdiction pursuant to 18 U.S.C.

§3231.

CONSTITUTIONAL PROVISION INVOLVED

The Sixth Amendment to the Constitution of the United States

2

provides:

In all criminal prosecutions, the accused shall

enjoy the right to a speedy and public trial, by an

impartial jury of the state and district wherein the

crime shall have been committed, which district

shall have been previously ascertained by law, and

to be informed of the nature and cause of the

accusation; to be confronted with the witnesses

against him; to have compulsory process for

obtaining witnesses in his favor, and to have the

assistance of counsel for his defense.

STATEMENT OF THE CASE

Introduction

This Court has not addressed the defense of entrapment

since 1992.

See: Jacobson v. United States, 503 U.S.540, 112

S. Ct. 1535 (1992).

The

entrapment

doctrine

forbids

punishment

of

an

“otherwise innocent” person whose “alleged offense” is “the

product of the creative activity of government officials.

Sorrels v. United States, 287 U.S. 435, 451 (1932).

When the Government’s quest for conviction leads to

the apprehension of an otherwise law abiding citizen

who, if left to his own devices, likely would have

never

run

afoul

of

the

law,

the

courts

should

intervene. Jacobson v. United States, 112 S. Ct.

1535, 1543 (1992).

In Jacobson this Court ruled that the predisposition to

3

commit a crime was the principal element in the defense of

entrapment.

The First Circuit has departed far from this norm.

As it

relates to the entrapment defense, it has usurped the role of

the jury and requires defendants to prove their defense twice:

once to the Court before trial and then once more to the jury.

See: Torruella, C.J. dissenting, Appendix p. 7.

The

First

Circuit’s

departure

from

this

Court’s

definition of the entrapment defense calls for an exercise of

this

Court’s

supervisory

power.

Furthermore,

the

First

Circuit’s decision stands in sharp contrast with Jacobson and

violates the Sixth Amendment to the Constitution of the United

States.

Petitioner’s conviction.

Mr. Daviel Salinas was charged with 3 counts related to

providing armed security for one FBI sham drug transaction in

March 24, 2010.

(Appendix p.30.)

Mr. Salinas exercised his right to trial by jury. The

trial ended with the return of guilty verdicts on January 10,

2013 on counts 11 and 14.

The jury could not reach a verdict

on count 12. (D.E. 499 & 501.)

4

Mr. Salinas Acevedo was then sentenced to a term of

imprisonment of 121 months for count 11 and a consecutive term

of imprisonment of 60 months for count 14; for a total term of

imprisonment of 181 months. (Appendix p. 30.)

The Government decides to target Salinas because he was

facing financial difficulties, not because he was suspected

of any wrongdoing

Petitioner Salinas-Acevedo was never in the government’s

radar. Nothing in the record suggests that he was anything but

an upstanding and law abiding citizen and police officer.

Salinas-Acevedo first came into the government’s cross

hairs one fateful day when he asked FBI informant Alwin

Camacho (“Camacho”) for a job as a security guard in CompUsa.

Mr. Salinas-Acevedo did not know Camacho was a FBI informant.

Had Salinas-Acevedo never asked for a part time job, he would

still be a member of the Puerto Rico Police and the law

abiding citizen he had been up to that fateful day.

At that time Camacho was moonlighting as CompUsa’s head

of security. When Salinas-Acevedo found out that his wife was

expecting another child, he decided to seek a second job.

He

5

then approached Camacho and asked his help in getting a part

time security job at CompUsa.

Salinas told Camacho about his

dire economic situation and his need to get a second job to

take care of his pregnant wife. Camacho told Salinas that at

the moment there were no openings at CompUsa but would get in

touch with him later if there was an opening. (D.E. 371.)

Once Camacho learned of his money troubles, he used two

corrupt police officers already targeted by the FBI: Israel

Rullán Santiago (Rullán-Santiago) and Carlos Méndez-Perez

(Méndez-Perez”) to induce Salinas-Acevedo to provide security

for an FBI led sham drug transaction. Appendix p. 31. There

was no reason to go after Salinas-Acevedo other than he was

“desperate” and “broke.” Appendix p. 32.

That alone, is improper government conduct and this

Court should exercise its supervisory powers and intervene.

Unlike Salinas-Acevedo, Camacho targeted Rullan-Santiago

because he would hear him boast at the police station that he

knew drug traffickers, had access to money and that he “was

basically a delinquent using up the uniform.” Appendix p. 31.

Both

Camacho

and

Rullán-Santiago

knew

that

Salinas-

Acevedo had a daughter, was expecting a another child and that

he was in a difficult financial situation. Id.

6

The entrapment begins.

The first recorded telephone conversation between Camacho

and Rullan-Santiago (related to Salinas) takes place on March

9, 2010. Appendix p. 31. In it, Rullan-Santiago calls Camacho

to let him know that “that one” (referring to Salinas) had

given him an excuse not to participate in the drug transaction

planned or the next day.

This

exchange

makes

clear

that

Camacho

had

already

singled out Salinas as a target for Rullan to recruit.

Both

of them knew who “that one” was and were purposely avoiding

using his name over the telephone.

According to Rullan-Santiago, Salinas told him “[s]orry,

it’s gonna be difficult for me because on the little girl and

the like.”

Rullan-Santiago did not believe that there was

anything wrong with Salinas’ girl and told Camacho “[y]ou know

that’s an excuse.” Appendix p. 31.

In light of Salinas’ refusal to participate, Camacho

postponed the drug transaction. Id.

But Camacho persisted.

Shortly

thereafter

Camacho

approached

Méndez-Pérez

seeking his help to recruit Salinas. Appendix p. 32.

Camacho

brings

up

the

subject

of

Salinas

to

the

7

conversation.

Camacho asked Méndez-Pérez what he thought of

Salinas (meaning, would Salinas be willing to participate in

a drug transaction). (“And since you’re buddies with Salinas,

what do you think about Salinas?”) Camacho then tells MéndezPérez that Rullan-Santiago had already approached Salinas

without success. (“Because, um, Rullán approached him and

later he gave me excuses that his daughter, that...”) (D.E.

414, Exh. 1, p.7.)(Appendix p. 32.)

Although at some point Camacho tells Méndez-Pérez that he

had told Rullan-Santiago not to “bring up the topic with

[Salinas] anymore,” he later sweet-talks Méndez-Pérez into

talking to Salinas by telling him that Salinas is “willing to

do anything and he’s broke.” id.

Camacho then asks Méndez-Pérez to talk to Salinas-Acevedo

and have him “come by” to see him.

Méndez-Pérez instead tells

Camacho that he will stop by Salinas’s house. Id.

At this point Camacho is aware that Salinas is resisting

and does not seem willing to participate.

He tells Méndez-

Pérez: “Yes, if he gives you a lot of crap ... This isn’t

compulsory, this is for those who want to and know what it

is.” Id.

We pause to note that the district court and the Court of

8

Appeals interpreted Camacho’s statement as proof that there

was no overreaching or pressuring by the government informant.

However,

we

respectfully

submit

that

this

passage

reinforces Salinas’ entrapment defense. It shows that Camacho

is aware of Salinas’ hesitance but still wants one more crack

at him.

That is why he wants Méndez-Pérez to try one more

time. But Camacho is cautions: he tells Méndez-Pérez to “drop

it” if Salinas “...gives you a lot of crap...”

Camacho knows

that Méndez-Pérez might get a “lot of crap” if Salinas is

approached again.

In any event, this instruction was given only to MendezPerez, not Rullán-Santiago who was the one who eventually

recruited Salinas-Acevedo.

Camacho ploughs on.

On March 19, 2010 Camacho once more tries to get to

Salinas through Rullan-Santiago. Appendix p. 32.

Camacho asks Rullan-Santiago over the telephone to “get

that guy that you tried to find last time.” (Referring to

Salinas.)

Rullan-Santiago is unsure if he can get Salinas

involved (“...let me see if, if that dog is around here”).

But, Camacho insists. (“Well, but let me know for sure, don’t

do the same shitty thing to me like you did last week.”) id.

9

Camacho is pressuring Rullan-Santiago to make sure that

Salinas agrees so that the transaction does not get postponed

once more.

Camacho is adamant: “But you have to reassure me

that you are going to do your part on Wednesday’s gig.” Id.

Three

days

later

(3/22/10),

Camacho

calls

Rullan-

Santiago-Santiago to “double check” for “Wednesday.” (Meaning

Wednesday, March 24, 2010.)

Salinas is on board.

Camacho asks Rullan-Santiago if

(“Salinas is - we are clear with

Salinas, right?”) Appendix p. 33.

Camacho is clearly worried about Salinas’ reaction when

he finds out that the transaction is drugs. (“You told Salinas

what it was, right, the devices?”) (Appendix p. 33.)

The conversation is a bit confusing.

While Rullan-

Santiago tells Camacho “yes” when he is asked whether or not

he told Salinas about the “devices”, Rullan-Santiago later

laughs and tells Camacho that Salinas will indeed “jump off

the balcony when he sees (the drugs).” Id. (Suggesting that

Salinas does not know that he is going to provide security for

a drug transaction.)

The

deal

went

on

as

planned

and

Salinas-Acevedo

participated in the sham drug transaction. Id.

The

entrapment

in

this

case

is

simple

and

10

straightforward. To target an otherwise law abiding police

officer because he is going through financial difficulties and

periods of anxiety is per se an improper tactic by the

government.

There is no noble purpose behind preying on the weak.

In this case Camacho knew that Rullan-Santiago was a

corrupt police officer (through his own boasting at the police

station) and recruited him to provide security in undercover

drug transactions. (D.E. 253.) In contrast to Rullan-Santiago,

there is nothing in the record to suggest that Salinas would

have committed any illegal act but for the fact that Camacho

singled him out and pressured Rullan-Santiago to recruit him.

REASONS FOR GRANTING THE WRIT

In Jacobson v. United States, 503 U.S.540, 542 (1992)

this Court reversed a conviction because “the Government

overstepped the line between setting a trap for the ‘unwary

innocent’ and the unwary criminal’ ... and as a matter of law

failed

to

establish

that

petitioner

was

independently

predisposed to commit the crime for which he was arrested...”

In their zeal to enforce the law, however,

Government agents may not originate a criminal

design, implant in an innocent person's mind the

disposition to commit a criminal act, and then

11

induce commission of the crime so that the

Government may prosecute. Sorrells, supra, 287 U.S.,

at 442, 53 S.Ct., at 212; Sherman, supra, 356 U.S.,

at 372, 78 S.Ct., at 820. Where the Government has

induced an *549 individual to break the law and the

defense of entrapment is at issue, as it was in this

case, the prosecution must prove beyond reasonable

doubt that the defendant was disposed to commit the

criminal act prior to first being approached by

Government agents. Jacobson, 503 U.S. at 548-49.

In Jacobson, this Court noted that the government could “not

prove

that

his

predisposition

to

commit

the

crime

was

independent and not the product of the attention that the

Government had directed at [him].” id.

The defense of entrapment has two elements: (1) the

government must have induced a defendant to commit a crime

that (2) the defendant was not otherwise willing to commit.

See: United States v. Russell, 411 U.S. 423, 428-30 (1973) and

Hampton v. United States, 425 U.S. 484, 488. The Supreme Court

has stressed that the defense centers on the latter element,

a person's predisposition to commit a crime, and not on the

government's conduct. United States v. Whoie, 925 F.2d 1481,

1483(D.C. Cir. 1991).

The entrapment defense focuses on both the predisposition

and

inducement

elements

(that

is,

the

conduct

of

law

enforcement and whether such conduct represented an improper

use of government power. Sorrells, 287 U.S. at 453 (Roberts,

12

J. Concurring). However, predisposition remains “the principal

element in the defense of entrapment.” Mathews v. United

States,485 U.S. 58, 63 (1988).

The First Circuit has turned on its head the entrapment

defense as established by this Court. Their main focus is no

longer

the

defendant’s

predisposition,

but

whether

law

enforcement used “improper inducements.” United States v.

Luisi,482 F.3d 43, 55 (1 st Cir. 2007); Appendix p. 37.

It also placed the burden on the defendant to present

evidence of such improper inducement before he or she is

allowed to present the entrapment defense to the jury. That

is, without the benefit of cross examination of government

witnesses or even Jencks materials. 18 U.S.C. §3500.

Although the First Circuit had no trouble finding that

petitioner lacked the required predisposition to commit the

crime(Appendix p. 37), it still refused to allow petitioner to

present an entrapment defense because, in its view, the

evidence

proffered

was

insufficient

to

prove

improper

inducement by the government.

In the First Circuit “predisposition” is no longer the

principal element of an entrapment defense as required by

Jacobson. It is, instead, whether there was an “improper

13

inducement”

by

the

government

in

order

to

overcome

the

defendant’s initial reluctance to commit the crime. The First

Circuit identified the key issue in this case as follows:

The key issue here is whether a specified improper

inducement by Rullán-Santiago (or Méndez-Pérez) can

be

attributed

to

the

government

itself.

The

government would be responsible for any improper

inducement

by

either

middleman

if

its

agent

(Camacho) had “told” or “instructed” the middleman

(Rullán-Santiago

or

Méndez-Pérez)

to

apply

the

inducement later deemed improper. United States v.

Salinas Acevedo,846 F.3d 417, 430 (1st Cir. 2017).

(Appendix pp. 38 - 39.)

The

First

Circuit

found

inducement in this case.

that

there

was

no improper

(“...there is no evidence that

[Camacho] urged (Rullán-Santiago or Méndez-Pérez) to apply

improper

pressure

to

join

the

enterprise.)

Id.

This

is

contrary to this Court’s decision in Jacobson.

Petitioner Salinas-Acevedo was not targeted because of

any suspicion that he was a corrupt policeman.

He was

targeted because he asked Camacho for a part time security job

at CompUsa and needed the job because his wife was pregnant

and was in financial troubles.

To target an otherwise law abiding police officer because

14

he is going through financial difficulties and periods of

anxiety is per se an improper tactic by the government.

There

is no noble purpose behind preying on the weak.

In this case Camacho knew that Rullán-Santiago was a

corrupt police officer (through his own boasting at the police

station) and recruited him to provide security in undercover

drug transactions. In contrast to Rullán-Santiago, there is

nothing in the record to suggest that Salinas Acevedo would

have committed any illegal act but for the fact that Camacho

singled him out.

Other Circuits have only required “minimally sufficient”

evidence to support an entrapment defense.1 (See: United

States v. McGill, 754 F.3d 452 (7th Cir. 2014); (Assessing an

entrapment defense involves subjective inquiry, and defendant

is entitled to argue that he was particularly susceptible to

inducement.).

Salinas proffers were neither thoroughly implausible nor

constructed entirely out of generalities.

To the contrary,

1

More precisely, the issue before this court is the properness of

the derivative entrapment defense.

The derivative entrapment

doctrine allows criminal defendants to assert they were entrapped

when “a government agent [Camacho] ‘uses [an] unsuspecting

middleman [Rullán] as a means of passing on an inducement’ to the

defendant.” United States v. Luisi, 482 F.3d 43, 53 (1st Cir.2007).

15

Salinas’ account is interlaced with considerable detail and

corroboration in the record.

Under Jacobson the principal element of the entrapment

defense is whether or not a defendant was predisposed to

commit the crime before induced to do so by the government.

The law in the First Circuit has inverted the hierarchy of

these elements. Predisposition is now secondary to a judicial

determination of whether the government’s inducements were

“improper.”

And, as this case illustrates, repeated requests

cannot give rise to an entrapment defense unless there is some

sort of “improper” behavior by the government. In other words,

the government is free to target law abiding citizens and

induce them to commit crimes (as long as such inducement is

not “improper”).

As this case showed; this is hardly a technical debate.

It threatens the very protections of the Sixth Amendment to

the

Constitution.

The

new

standard

“entails

whether

we

recognize the legitimate role of the jury, or whether we will

engage

in

an

usurpation

of

that

role.”

Appendix

p.

7.

Torruella, C.J., dissenting.

In the First Circuit a defendant is “not allowed to argue

to a jury that he was entrapped” unless he can “prove his

16

defense twice: once to the court, and then once more to the

jury.” Id.

This case presents the exact situation that the Jacobson

Court sought to protect us from:

When the Government’s quest for conviction leads to

the apprehension of an otherwise law-abiding citizen

who, if left to his own devices, likely would have

never run afoul of the law, the courts should

intervene. Jacobson, 503 U.S. at 543.

Salinas-Acevedo had no criminal record, nor whatsoever the

slightest

corruption.

indication

that

he

was

involved

in

police

Rather, the government first laid eyes on him

when he sought a part time job from Camacho to support his

family. Salinas-Acevedo never sought to participate in any

crime.

17

CONCLUSION

WHEREFORE, for the foregoing reasons it is most respectfully

requested from this Honorable Court to grant certiorari and

reverse the judgment of the First Circuit.

RESPECTFULLY SUBMITTED.

In San Juan, Puerto Rico February 16, 2018.

_________________________________

Ignacio Fernández de Lahongrais

Capital Center Sur, Suite 202

Avenida Arterial Hostos #239

San Juan, Puerto Rico 00918-1475

Tel. 787-923-5789

ignacio@bufetefernandezalcaraz.com

18

CERTIFICATE OF COMPLIANCE

This brief complies with the type volume limitation of

Supreme Court Rule 33 because this petition contains 16 pages,

exclusive of the items listed in Rul3 33(d).

This

brief

complies

with

the

typeface

requirements

because it was prepared using 13 point, mono-spaced typeface

(13 Courier New).

Software used: WordPerfect X8.

I understand that a material misrepresentation can result

in this Court striking this brief or imposing sanction.

If

the Court so directs, I will provide a copy of the word or

line print-out.

I declare under penalty of perjury that the foregoing is

true and correct.

In San Juan, Puerto Rico February 16, 2018.

_________________________________

Ignacio Fernández de Lahongrais

Capital Center Sur, Suite 202

Avenida Arterial Hostos #239

Hato Rey, Puerto Rico 00918-1475

Tel. 787-923-5789

ignacio@bufetefernandezalcaraz.com

Attorney for the Appellant

19

CERTIFICATE OF SERVICE

I, Ignacio Fernández de Lahongrais, do swear that on this 16th

day of February, 2018, as required by Supreme Court Rule 29,

I have served the enclosed Petition for a Writ of Certiorari

on each party to the above proceeding or that third party’s

counsel, and on every other person required to be served, by

depositing an envelope containing the above documents in the

United States mail properly Addressed to each of them and with

first class postage prepaid.

The names and addresses of those served are as follows:

1.

Solicitor General of the United States

U.S. Department of Justice, Room 5614

950 Pennsylvania Avenue, NW

Washington, DC 20530-0001

(202) 514-2217

2.

AUSA Mariana Bauza

Torre Chardón, Suite 1202

350 Carlos Chardón Avenue

San Juan, Puerto Rico 00918

(787) 766-5656

3.

Daviel Salinas Acevedo

Reg. 35980-069

FCI Manchenster

Federal Correctional Institute

PO Box 4000

Manchester, Kentucky 40962

I declare under penalty of perjury that the foregoing is

true and correct.

20

Executed in San Juan, Puerto Rico on February 16, 2018.

_________________________________

Ignacio Fernández de Lahongrais

Court Appointed Attorney

Capital Center Sur, Suite 202

Avenida Arterial Hostos #239

San Juan, Puerto Rico 00918-1475

Tel. 787-923-5789

ignacio@bufetefernandezalcaraz.com

21