Petition for Writ of Certiorari — Remberto Rivera, Petitioner v. United States

NO. _________

IN THE SUPREME COURT OF THE UNITED STATES

REMBERTO RIVERA,

Petitioner,

v.

UNITED STATES OF AMERICA,

Respondent

__________________________________________

PETITION FOR A WRIT OF CERTIORARI

APPENDIX

__________________________________________

INDEX TO APPENDIX

United States v. Rivera, 76 F.4th 1085 (8th Cir. 2023) ............................................. 1a

Order Denying Petition for Rehearing........................................................................ 7a

United States v. Rivera, 76 F.4th 1085 (2023)

76 F.4th 1085

United States Court of Appeals, Eighth Circuit.

UNITED STATES of America, Plaintiff - Appellee

v.

Remberto RIVERA, Defendant - Appellant

Counsel who represented the appellant was Christopher

Aaron Holt, AFPD, of Fayetteville, AR.

Counsel who represented the appellee was David A. Harris,

AUSA, of Fort Smith, AR.

Before KELLY, ERICKSON, and STRAS, Circuit Judges.

No. 22-1295

|

Submitted: January 13, 2023

|

Filed: August 10, 2023

Opinion

ERICKSON, Circuit Judge.

Synopsis

Background: Defendant pled guilty in the United States

District Court for the Western District of Arkansas, Timothy

L. Brooks, J., to possession of methamphetamine with intent

to distribute, and he appealed.

Holdings: The Court of Appeals, Erickson, Circuit Judge,

held that:

defendant's Arkansas conviction for accomplice to robbery

qualified as predicate “crime of violence” under career

offender sentencing guideline's enumerated offenses clause;

district court did not clearly err in imposing two-level

enhancement for possession of dangerous weapon in

connection with drug crime; and

imposition of two-level enhancement

endangerment during flight was warranted.

Attorneys and Law Firms

for

reckless

Affirmed.

Stras, Circuit Judge, concurred in part, concurred in

judgment, and filed opinion.

Procedural Posture(s): Appellate Review; Sentencing or

Penalty Phase Motion or Objection.

*1087 Appeal from United States District Court for the

Western District of Arkansas - Fayetteville

Remberto Rivera pled guilty to possession of

methamphetamine with intent to distribute. The district

court sentenced him as a career offender to 168 months’

imprisonment. Rivera appeals, claiming the district court 1

committed three reversible errors: (1) designating him as a

career offender; (2) applying a two-level enhancement for

possession of a dangerous weapon; and (3) applying a twolevel enhancement for reckless endangerment in the course of

fleeing from law enforcement. We affirm.

I. BACKGROUND

In February 2020, a northwest Arkansas Drug Task Force

(“Task Force”) received a tip that Rivera was selling

methamphetamine in northwest Arkansas. The Task Force

also learned that Rivera was on parole and his conditions

allowed warrantless searches. While conducting surveillance

on March 3, 2020, at a motel known for drug activity, the Task

Force observed Rivera, carrying a backpack, enter the parking

lot. Task Force investigators approached Rivera, identified

themselves, and asked for his identification. When Rivera

refused to identify himself, claiming to have no identification,

investigators informed him that they knew who he was, that he

was on parole, that he had signed a warrantless search waiver,

and that they suspected him of trafficking methamphetamine.

After arresting Rivera for obstruction based on his refusal to

provide his name, investigators recovered his driver's license

from his pocket.

Investigators searched Rivera's backpack and found 15.9

grams of marijuana, 114.4 grams of methamphetamine,

a digital scale, a pipe with suspected methamphetamine

residue, clear plastic baggies, and more than $3,000 in cash.

The investigators also seized two phones from Rivera that

contained text messages indicating Rivera was engaged in

© 2023 Thomson Reuters. No claim to original U.S. Government Works.

1 1a

United States v. Rivera, 76 F.4th 1085 (2023)

drug trafficking. Rivera was taken into custody and later

released on bond.

endangerment during flight. He challenges each of those

conclusions on appeal.

On May 16, 2020, members of the Fayetteville Police

Department (“FPD”) observed Rivera at a residence under

surveillance because of suspected drug activity. *1088 FPD

officers followed Rivera's vehicle and, after multiple turns

onto different streets, Rivera parked and exited the car with a

companion. Rivera's companion eventually admitted that they

had spoken to a known drug distributor at the drug house.

II. DISCUSSION

We review a district court's application of the Sentencing

Guidelines de novo, and its factual findings for clear error.

United States v. Anderson, 618 F.3d 873, 879 (8th Cir. 2010)

(citation omitted).

Rivera told law enforcement that he owned the car but when

the police asked for permission to search the car, Rivera

claimed he was not the owner. Even though Rivera refused

to give permission to search the vehicle, officers informed

him they were going to search the vehicle without his consent

because he had signed a parole search waiver. Rivera was

initially agitated and became more visibly upset as contact

with the officers progressed. Rivera questioned why he was

being stopped, and exhibited signs that he might flee, such as

looking around and scanning the area.

When an officer attempted to handcuff him, Rivera, who

had been seated on the curb, stood up and attempted to

run. Officers grabbed Rivera and took him to the ground.

A chaotic struggle ensued during which Rivera attempted to

strike one officer with his fist, attempted to choke another

officer, grabbed at the handcuffs, and eventually succeeded

in taking a taser off one of the officers. Rivera then grabbed

at another officer's duty weapon. Eventually, two bystanders

came to the aid of the officers and Rivera was subdued and

taken into custody.

When officers searched Rivera's car, they found a loaded

handgun and a backpack containing a locked safe. Inside

the safe, officers discovered a second firearm, ammunition,

plastic baggies, and two digital scales. Another backpack

contained a glass pipe with suspected methamphetamine

residue and more small plastic baggies.

Rivera pled guilty to possession of methamphetamine with

intent to distribute. Because Rivera had prior Arkansas

convictions for Accomplice to Robbery and Possession of

Methamphetamine with Purpose to Deliver, he was found

to be a career offender. In calculating Rivera's advisory

Sentencing Guidelines range, the district court applied a twolevel increase for possession of a firearm in connection with

another felony offense and a two-level increase for reckless

A. Career Offender Status

Rivera asserts the district court erred when it classified him

as a career offender within the meaning of § 4B1.1 of the

United States Sentencing Guidelines. Under § 4B1.1(a), a

defendant qualifies as a “career offender” if he has at least

two prior felony convictions for either a crime of violence or

a controlled substance offense, is at least eighteen years old

at the time of the offense, and the instant felony offense is

a crime of violence or controlled substance offense. Section

4B1.2(a) defines a “crime of violence” as:

[A]ny offense under federal or state law, punishable by

imprisonment for a term exceeding one year, that(1) has as an element the use, attempted use, or threatened

use of physical force against the person of another, or

(2) is murder, voluntary manslaughter, kidnapping,

aggravated assault, a forcible sex offense, robbery, arson,

extortion, or the use or unlawful possession of a firearm

described in *1089 26 U.S.C. § 5845(a) or explosive

material as defined in 18 U.S.C. § 841(c).

Rivera acknowledges that we have found Arkansas robbery

to fit within the generic federal definition of robbery and

to qualify as a “crime of violence” under the enumerated

offenses clause of § 4B1.2(a)(2). See United States v. Stovall,

921 F.3d 758, 761 (8th Cir. 2019). He contends, however,

that his prior Arkansas conviction for Accomplice to Robbery

does not qualify as a predicate to support the career offender

enhancement because it is an inchoate offense not listed in

the Guidelines. Rivera claims that because the Guidelines

fail to include aiding and abetting offenses, the commentary

impermissibly expands the definition of “crime of violence”

beyond what the text allows. See U.S.S.G. § 4.B1.2 cmt. n. 1.

In Stinson v. United States, 508 U.S. 36, 113 S.Ct. 1913,

123 L.Ed.2d 598 (1993), the Supreme Court held that the

Guidelines commentary was to “be treated as an agency's

interpretation of its own legislative rule.” Id. at 44, 113 S.Ct.

© 2023 Thomson Reuters. No claim to original U.S. Government Works.

2 2a

United States v. Rivera, 76 F.4th 1085 (2023)

1913. Based on Stinson, this Court decided the commentary

was a reasonable interpretation of the Guidelines and was

within the Sentencing Commission's statutory authority.

United States v. Mendoza-Figueroa, 65 F.3d 691, 693-94 (8th

Cir. 1995) (en banc).

The law has undergone significant developments since

Stinson was decided, some of which may cast doubt on

our precedent in Mendoza-Figueroa. For instance, in 2019,

the Supreme Court, in Kisor v. Wilkie, ––– U.S. ––––, 139

S. Ct. 2400, 204 L.Ed.2d 841 (2019), held that deference

to an agency's own interpretation is to be afforded only

when (1) the law is “genuinely ambiguous”; (2) the agency's

proposed interpretation is reasonable; (3) the interpretation

is the agency's “authoritative” or “official position”; (4) the

regulatory interpretation implicates the agency's substantive

expertise; and (5) the agency's regulatory interpretation

reflects “fair and considered judgment.” Id. at 2415-17

(citations omitted). The Kisor Court cautioned lower courts

to “carefully consider the text, structure, history, and purpose

of a regulation, in all the ways it would if it had no agency to

fall back on.” Id. at 2415 (cleaned up).

After Kisor, several of our sister circuits revisited the

deference to be given to the Guidelines commentary and

overruled their prior precedents, concluding the definition

of controlled substance offenses in § 4B1.2(b) does not

include inchoate crimes. See, e.g., United States v. Dupree,

57 F.4th 1269, 1279 (11th Cir. 2023) (en banc); United

States v. Nasir, 17 F.4th 459, 472 (3d Cir. 2021) (en

banc); United States v. Castillo, 69 F.4th 648, 664 (9th Cir.

2023). Recently, the Fifth Circuit, applying Stinson deference,

reaffirmed its “longstanding precedent that inchoate offenses

like conspiracy are included in the definition of ‘controlled

substance offense’ while explaining, in the alternative, it

would also defer to the commentary under Kisor. United

States v. Vargas, 74 F.4th 673, 697-98 (5th Cir. 2023) (en

banc). A few weeks before Kisor was decided, the Sixth

Circuit abrogated its precedent and found the Sentencing

Commission had no power to add attempt crimes to the list

of offenses in § 4B1.2(b) through commentary. United States

v. Havis, 927 F.3d 382, 386-87 (6th Cir. 2019). In reaching

this conclusion, the Sixth Circuit asserted that, unlike the

Guidelines, the “commentary to the Guidelines never passes

through the gauntlets of congressional review or notice and

comment.” Id. at 386. Similar reasoning has been employed

by our sister circuits that have determined Kisor applies

to the Guidelines’ commentary. But there are grounds for

questioning this reasoning.

*1090 The United States Sentencing Commission routinely

publishes notice of its intention to amend the commentary

and application notes to the Guidelines. See e.g., U.S. Sent.

Comm., Notice of Submission to Congress of Amendments to

the Sentencing Guidelines Effective November 1, 2023, and

Request for Comment, 88 Fed. Reg. 28254 et seq. (May 3,

2023). Nor is there a basis to believe Congress has treated

the commentary differently than the black-letter Guidelines.

History reflects that Congress has actively overseen the

substance of the commentary to the Guidelines. By way of

example, in 2003, Congress amended certain commentary

provisions as part of the Prosecutorial Remedies and Other

Tools to end the Exploitation of Children Today Act of

2003 (“PROTECT Act”), Pub. L. No. 108-21, 117 Stat.

650. Section 401(g) of the PROTECT Act directly amended

Application Note 6 and the background commentary to

U.S.S.G. § 3E1.1 (Acceptance of Responsibility), and

Section 401(i)(1)(A) of the PROTECT Act directly amended

Application Note 4(b)(i) to U.S.S.G. § 4B1.5 (Repeat and

Dangerous Sex Offender Against Minors).

On other occasions, Congress has instructed the Sentencing

Commission to reevaluate commentary in light of various

policy concerns. See Artists’ Rights and Theft Prevention

Act of 2005, Pub. L. No. 109-9, § 105(c)(3), 119 Stat. 218

(2005) (instructing the Sentencing Commission to, among

other things, “determine whether the scope of ‘uploading’

set forth in application note 3 of section 2B5.3 of the

Federal sentencing guidelines is adequate to address the loss

attributable to people who, without authorization, broadly

distribute copyrighted works over the Internet”); see also

Stop Counterfeiting in Manufactured Goods Act, Pub. L.

No. 109-181, § 1(c)(3), 120 Stat. 285 (2006) (instructing the

Sentencing Commission to “determine whether the definition

of ‘infringement amount’ set forth in application note 2 of

section 2B5.3 of the Federal sentencing guidelines is adequate

to address” certain situations).

The First and Second Circuits have expressed a desire to

follow the lead of these circuits but found themselves bound

by their precedent. See United States v. Lewis, 963 F.3d

16, 24-25 (1st Cir. 2020); United States v. Tabb, 949 F.3d

81, 87 (2d Cir. 2020). Still other circuits have declined to

find that Kisor alters the standard for the deference owed

to the Guidelines commentary. See, e.g., United States v.

Maloid, 71 F.4th 795, 803-817 (10th Cir. 2023) (concluding

Kisor did not change the standard of deference given to the

Guidelines’ commentary, and the district court did not plainly

© 2023 Thomson Reuters. No claim to original U.S. Government Works.

3 3a

United States v. Rivera, 76 F.4th 1085 (2023)

err in applying a modern definition of conspiracy in defining

generic conspiracy under the Guidelines); United States v.

Moses, 23 F.4th 347, 357 (4th Cir. 2022) (stating since Kisor

did not purport to overrule Stinson, it is not the court's role

to find that it did), cert. denied, ––– U.S. ––––, 143 S. Ct.

640, 640, 214 L.Ed.2d 369 (2023), contra United States v.

Campbell, 22 F.4th 438, 445 (4th Cir. 2022) (noting the

traditional tools for statutory construction do not support the

government's contention that the court should defer to the

commentary); United States v. Smith, 989 F.3d 575, 585-86

(7th Cir. 2021) (reaffirming its precedent that the Guidelines

commentary is authoritative); United States v. Babcock,

40 F.4th 1172, 1185 (10th Cir. 2022) (acknowledging its

precedent that the Guidelines commentary is authoritative).

With that background, Rivera contends Kisor renders our

holding in Mendoza-Figueroa no longer controlling. Since

Kisor, we have followed Mendoza-Figueroa in several cases,

though none of our post-Kisor precedent has substantively

reviewed Mendoza-Figueroa. See United States v. Jefferson,

975 F.3d 700, 708 (8th Cir. 2020) (rejecting challenge that

inchoate offenses were not controlled substance *1091

offenses on the ground that Court was bound by MendozaFigueroa); United States v. Broadway, 815 F. App'x 95,

96 n.2 (8th Cir. 2020) (per curiam) (noting that even if

the law had evolved since 1995, the panel was unable to

overrule Mendoza-Figueroa); United States v. Merritt, 934

F.3d 809, 811 (8th Cir. 2019) (concluding argument that drug

conspiracy convictions do not fall within the definition of a

controlled substance offense because the commentary cannot

add conspiracy offenses to the Guidelines was foreclosed by

Mendoza-Figueroa); United States v. Miller, 857 F. App'x

877, 878 (8th Cir. 2021) (per curiam) (noting the Sentencing

Commission has published a proposed amendment to § 4B1.2

that would resolve circuit split and summarily stating Kisor

has not undermined Mendoza-Figueroa).

While there is circuit disagreement on the deference to be

afforded the Guidelines’ commentary, the weight of authority

may suggest that Kisor undermines the Court's decision in

Mendoza-Figueroa. The question, though interesting, is not

one we are empowered to resolve today, as we are obligated to

follow our precedent until it is overruled by the Court sitting

en banc. United States v. Manning, 786 F.3d 684, 686 (8th Cir.

2015) (citation omitted). Since Rivera's claim is foreclosed by

Eighth Circuit precedent, the ultimate answer to this question

awaits another day. 2

B. Dangerous Weapons Enhancement

Rivera contends the district court erred in applying the

dangerous weapons enhancement under U.S.S.G. § 2D1.1(b)

(1), asserting there was no spatial and temporal nexus between

when he was found with drugs and when he was found

with firearms. This enhancement applies if the government

proves, by a preponderance of the evidence: (1) the gun was

possessed, and (2) it was not clearly improbable that the

weapon was connected to the drug offense. See Anderson,

618 F.3d at 880.

The first prong (possession) does not require proof of

ownership of either the weapon or of the premises where

the gun was found. Id. at 879 (citation omitted). In addition,

the defendant need not be observed using the weapon; it

is sufficient if the government demonstrates the defendant

“exercised ownership, dominion, or control” of either the

firearm or the premises where the firearm is located. Id. at 880

(citing United States v. Payne, 81 F.3d 759 (8th Cir. 1996)).

The district court found Rivera possessed two weapons

on May 16, as they were seized from a vehicle he was

driving, and he admittedly owned them. “Once a district

court has found that a gun was possessed during commission

of the offense, the court must impose the § 2D1.1(b)(1)

enhancement unless it is clearly improbable that the weapon

was connected to the offense.” Id. (citing United States v.

Peroceski, 520 F.3d 886, 889 (8th Cir. 2008)).

Rivera argues that the evidence is insufficient to conclude his

activities on May 16 *1092 were part of the same course

of conduct as his activities at the motel on March 3. The

dangerous weapon enhancement is applicable if the firearm

is found during “relevant conduct,” as defined in U.S.S.G. §

1B1.3(a)(2) and is not limited to the offense of conviction.

United States v. Ault, 446 F.3d 821, 824 (8th Cir. 2006)

(citations omitted). As the district court pointed out, both

instances involved drug trafficking related conduct, with the

only difference being the seizure of a distributable quantity

of methamphetamine in March while there was no seizure

of drugs but evidence of drug trafficking at the time of

Rivera's arrest in May. Specifically, the district court noted the

discovery of two scales, one with methamphetamine residue,

a pipe with residue, baggies, and two firearms. Notably,

Rivera was out on bond for the March possession offense

when he was observed at a known drug house and his

companion acknowledged that she and Rivera had met with

a known drug trafficker.

© 2023 Thomson Reuters. No claim to original U.S. Government Works.

4 4a

United States v. Rivera, 76 F.4th 1085 (2023)

On this record, the district court did not clearly err in

finding the events surrounding the May arrest and seizure of

evidence was relevant conduct under the Guidelines because

they were part of Rivera's course of conduct—his ongoing

drug trafficking activities—during this three-month period.

See id. (citation omitted). The two-level enhancement under

U.S.S.G. § 2D1.1(b)(1) applies.

C. Reckless Endangerment Enhancement

Finally, Rivera asserts the district court erred when it applied

a two-level enhancement for reckless endangerment during

flight pursuant to U.S.S.G. § 3C1.2. We have previously

applied the reckless endangerment adjustment to a defendant

fleeing on foot as well as by car. See United States v. Bates,

561 F.3d 754, 757 (8th Cir. 2009) (citation omitted). Our

precedent provides that “during flight should be broadly

construed and includes conduct in the course of resisting

arrest.” United States v. McDonald, 521 F.3d 975, 979 (8th

Cir. 2008) (cleaned up). In this case, Rivera fought with

two officers and successfully grabbed an officer's taser. He

then attempted to grab the other officer's duty weapon and

was only finally subdued when two bystanders rushed to

the aid of the officers. Rivera's conduct undoubtedly created

a substantial risk of injury or death to the officers and

bystanders, even though Rivera was tackled the moment

he attempted to flee. And as we previously noted, Rivera's

actions that day were relevant conduct under the Guidelines.

The district court did not err in imposing a two-level

enhancement for reckless endangerment.

III. CONCLUSION

The judgment of the district court is affirmed.

STRAS, Circuit Judge, concurring in part and concurring in

the judgment.

A robbery is a robbery no matter how it is committed. Rivera

happened to do it as an accomplice rather than as a principal.

See Ark. Code Ann. §§ 5-2-403, 5-12-102. But that does not

change “the crime of which he is guilty.” United States v.

Baca-Valenzuela, 118 F.3d 1223, 1232 (8th Cir. 1997); see

Cook v. State, 350 Ark. 398, 86 S.W.3d 916, 923 (2002)

(explaining that, under Arkansas law, “[w]hen two persons

assist one another in the commission of a crime, each is an

accomplice and criminally liable for the conduct of both”).

No separate crime of aiding and abetting exists, no matter the

“underlying offense.” Baca-Valenzuela, 118 F.3d at 1232.

We have already held that an Arkansas robbery conviction

counts as a “crime of violence” because it meets the generic

definition of robbery under the enumerated-offenses *1093

clause. United States v. Stovall, 921 F.3d 758, 761 (8th Cir.

2019). Stovall, which interprets the career-offender provision,

tells us everything we need to know. There is no need

to consult the commentary to understand that “aiding and

abetting” robbery—one way of committing it—qualifies as a

“crime of violence.” U.S.S.G. § 4B1.2 cmt. n.1. Deference is

beside the point.

I have no doubt that we will need to address the impact of

Kisor at some point. Compare United States v. Dupree, 57

F.4th 1269, 1279 (11th Cir. 2023) (en banc) (declining to

defer to the commentary accompanying the career-offender

provision after Kisor), with United States v. Smith, 989

F.3d 575, 584–86 (7th Cir. 2021) (reaffirming that the

Guidelines commentary is authoritative). But the circuit split

that has developed in its wake focuses on how to treat

inchoate offenses like conspiracy and attempt, not crimes

committed as an accomplice. See, e.g., Dupree, 57 F.4th

at 1277–79 (concluding that “the plain language ... in §

4B1.2 unambiguously excludes inchoate offenses” (emphasis

added)); see also United States v. Castillo, 69 F.4th 648, 652

(9th Cir. 2023) (explaining that “inchoate offenses” include

“attempt, conspiracy, and solicitation” (quoting Inchoate

Offenses, Black's Law Dictionary (11th ed. 2019))). The

court's discussion of deference is better left for a case in which

it matters.

All Citations

76 F.4th 1085

Footnotes

1

The Honorable Timothy L. Brooks, United States District Judge for the Western District of Arkansas.

© 2023 Thomson Reuters. No claim to original U.S. Government Works.

5 5a

United States v. Rivera, 76 F.4th 1085 (2023)

2

There may be another potential argument for not reaching the Kisor question in this particular case. Rivera

was convicted of robbery using an accomplice-liability theory rather than as a principal. See United States v.

Baca-Valenzuela, 118 F.3d 1223, 1232 (8th Cir. 1997) (“A fundamental theory of American criminal law is that

there is no offense of aiding and abetting or accomplice liability as such.”). Because we find Rivera's claim

foreclosed by precedent, we need not determine the significance of the commentary to U.S.S.G. § 4B1.2

expressly including “crimes of violence” or “controlled substance” offenses involving aiding and abetting,

conspiracy, and attempting to commit such offenses, while the Guideline at issue in Baca-Valenzuela, §

2L1.1, did not.

End of Document

© 2023 Thomson Reuters. No claim to original U.S. Government Works.

© 2023 Thomson Reuters. No claim to original U.S. Government Works.

6 6a

012345ÿ738347ÿ9 0 3ÿ ÿ8 487ÿ

ÿ34ÿ423ÿ92 9023ÿ

ÿÿ

ÿ

ÿ!"ÿ#ÿ$%&'!ÿ

ÿ

ÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿ$(())ÿ

ÿ

*+ÿ

ÿ

,%-&ÿ,*&!ÿ

ÿ

ÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿ$(())!ÿ

ÿ

ÿ

..............................................................................ÿÿ

$((!)ÿ#&%ÿ++ÿ/"&'ÿ01&ÿ#&ÿ2ÿ3"&ÿ/"&'ÿ#ÿ$&4!"!"ÿÿ5!6*))ÿ

78'&8889:;<ÿ

..............................................................................ÿÿ

54 ÿ

ÿ

ÿ 92ÿ(ÿ#&ÿ&2!&=ÿÿ-!'ÿ"ÿ+ÿ92ÿ(ÿ#&ÿ&2!&=ÿ-6ÿ2ÿ(!)ÿ"ÿ

!)"ÿ+ÿÿ

ÿ ÿ ÿ ÿ ÿ ÿ ÿ >'-&ÿ8?ÿ8@ÿ

ÿ

ÿ

ÿ

ÿ

ÿ

ÿ

>&&ÿA&ÿ!ÿ2ÿ/&'ÿ#ÿ2ÿ01&ÿÿ

0)&4?ÿ++ÿ01&ÿ#ÿ$((!)"?ÿA=22ÿ0&'1+ÿÿ

....................................ÿÿ

ÿ ÿÿÿÿÿÿÿB"BÿC'2!)ÿA+ÿD!"ÿÿ

EFFGHHIJGÿLIMGNÿOOPQORSÿÿÿÿÿTIUGNÿQÿÿÿÿÿÿVIJGÿWXHGYNÿQZ[ZS[OZO\ÿ]^J_`ÿaVNÿS\O\QObÿ

7a