Case 1:14-cr-20715-MGC Document 174 Entered on FLSD Docket 05/26/2016 Page 1 of 17

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
CASE NO. 14-20715-CR-COOKE/TORRES
UNITED STATES OF AMERICA,
Plaintiff,
v.

:
:
:
:
SALO SCHAPIRO, et al.,
:
Defendants.
:
...............................:
DEFENDANT SCHAPIROS VERIFIED MOTION TO DISMISS,
TO DISQUALIFY THE PROSECUTION TEAM,
FOR A TAINT HEARING AND
A CONTINUANCE
For the past sixteen months, contrary to the representations made to

undersigned, the FBI case agent has been surreptitiously obtaining from the
Government-contracted copy service CDs containing duplicates of the subset of
discovery documents that Dr. Schapiro and his defense team hand-selected for
copying to be used by the defense team in preparing his defense at trial classic
work-product. The FBI agent has confessed that she opened four of the CDs and
copied materials from those CDS to prepare for the prosecution of this case. When
undersigned learned of this intrusion, undersigned confronted the Director of the
copy service, who stated that this practice of cloning the defendants work-product
had been done at the request of an agent of the Government and has been the
practice of the U.S. Attorneys Office for the Southern District of Florida for at
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least ten years. Undersigned has since learned of a series of additional deceptions
and misrepresentations made by the Director of the copy service to undersigned that
has compromised the integrity of the entire discovery process.
Pursuant to Rules 12 and 16 of the Federal Rules of Criminal Procedure, the
Fifth and Sixth Amendments to the United States Constitution, and the
supervisory powers of this court, Dr. Schapiro moves to dismiss the indictment with
prejudice.
I.

STATEMENT OF FACTS

Dr. Schapiro was indicted on September 25, 2014. The government

promptly informed defense counsel that discovery included 220 boxes of
documents seized from Biscayne Milieu, and that defense counsel could review
that discovery at the FBI warehouse in Miramar. The documents in those boxes
were not Bates-stamped. The documents in those boxes were randomly placed in
the boxes, in no particular order.
Beginning as early as December 2014, and continuing until as recently as
April 2016, attorney Rossana Arteaga-Gomez, on behalf of Dr. Schapiro, visited
the FBI warehouse in Miramar, Florida, to review that discovery. Ms. ArteagaGomez was often accompanied by Dr. Schapiro and/or other members of Dr.
Schapiros defense team.

At the warehouse, the Schapiro defense team was

escorted by a federal agent into a very large conference room full of bankers
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boxes with approximately eight long, picnic-sized conference room tables. The
conference room has two double doors on each end. Whenever the defense team
was reviewing documents at the warehouse, a federal agent was present in the
room, presumably to ensure that none of the documents were tampered with or
removed from the premises. However, the defense team always sat at a distance
sufficiently far away so that the agent could not overhear any of the confidential
communications between members of the defense team.
During the first visit to the warehouse, Ms. Arteaga-Gomez was informed by
federal agents that if she wanted to copy any documents, she would have to use a
particular copy service, Imaging Universe, whose Director is Ignacio Montero.
Ms. Arteaga-Gomez was told that each bankers box was numbered. She was
instructed to set aside any documents that she wanted copied from each box and
to write on a post-it note the number of the box from which the documents came
and place the post-it note on the top page of each set of documents retrieved from
the numbered box. At the end of each visit, all of the documents set aside by the
defense team were placed into an empty box for Imaging Universe to pick up. Ms.
Arteaga-Gomez was told that Imaging Universe would pick up the documents and
that a representative of Imaging Universe would contact her to discuss how she
wanted the documents copied. Ms. Arteaga-Gomez expected that once the handselected documents were copied, the documents would be placed back into the
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numbered box from where they came, without anyone from the prosecution team
using the copy-process as a subterfuge for tracking the documents that the defense
team deemed signicant.
The defense team followed this procedure each time they visited the
warehouse since at least December 2014. Ms. Arteaga-Gomez has visited the
warehouse approximately thirteen times at least on three occasions with Dr.
Schapiro, who himself selected documents to be copied and conferred with Ms.
Arteaga-Gomez about those selections. At other discovery conferences, Ms.
Arteaga Gomez was accompanied by either one or two private investigators and a
nursing consultant.
Each time members of the defense team visited the warehouse, they selected
and compiled documents for scanning that they believed were important to the
defense. Some of the documents selected were chosen because they would be
useful to cross-examine and impeach government witnesses; others were selected
because they would be important for Dr. Schapiro to review in preparation for his
trial testimony (should he choose to testify); others were selected to assist the
defense team in deciding who to call as defense witnesses and to allow those
witnesses to prepare for their testimony. The documents selected thus reveal areas
of cross examination of key government witnesses, theories of defense and the
identity of potential defense witnesses. Overall, these documents reflect Dr.
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Schapiros defense strategy. The documents selected constitute a small subset of

the documents contained in the 220 boxes of discovery seized from Biscayne
Milieu.
After Ms. Arteaga-Gomezs first visit to the warehouse, Ignacio Montero
from Imaging Universe contacted Ms. Arteaga-Gomez to discuss in what format
she wanted the documents copied. Ms. Arteaga-Gomez instructed Mr. Montero to
scan the documents, Bates-stamp them, and save them as PDF files onto a CD.
These instructions were presumably followed by Mr. Montero every single time he
picked up documents from the warehouse. The CDs were sent to Ms. ArteagaGomez containing PDFs of the documents selected for scanning.
Early on, the PDFs were named/titled by someone at Imaging Universe,
identifying the document that had been scanned. In subsequent productions, Ms.
Arteaga-Gomez herself instructed Mr. Montero to title the PDFs with labels she
indicated on a separate post-it note that she put on the physical document that was
going to be scanned (separate from the post-it note reflecting the number of the
box from which the document came). Ms. Arteaga-Gomez further instructed Mr.
Montero to remove the post-it notes with her labeling instructions before returning
the documents to the FBI warehouse. Mr. Montero assured Ms. Arteaga-Gomez
that he would follow those instructions. Mr. Montero also assured Ms. ArteagaGomez that he was not providing a copy of the CDs to the Government and that
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no one from the Government had asked for a copy.

On March 16, 2016, Ms. Arteaga-Gomez asked Mr. Montero to rescan
certain documents because the scans were either too light to read or were missing
content from the original document (i.e., a portion of the document had been cut
off during the scanning process). Days later, Mr. Montero explained to Ms.
Arteaga-Gomez that it had taken longer than usual to re-scan the documents
because, after removing Ms. Arteaga-Gomezs post-it notes, it had taken a long
time to find the documents in the numbered boxes.
Over the course of approximately sixteen months, Imaging Universe made
nine discovery productions to the defense team, consisting of twelve CDs,
containing approximately 1,140 PDFs (many consisting of multiple pages), at a
cost to Dr. Schapiro

of approximately $8,200 so far.

The delivery dates

corresponding to those productions were: 12/29/14; 2/8/15; 4/3/15; 5/6/15; 9/21/15;

10/7/15; 3/14/16; 3/24/16; 4/20/16.1
Turns out, Mr. Montero lied to Ms. Arteaga-Gomez about the discovery
process. It appears that Mr. Montero had not been removing Ms. Arteaga-Gomezs
post-it notes after scanning the hand-selected documents; and, all along, Mr.

Although the copy service produced 12 CDs, two of them contain the documents
that were re-scanned from an earlier production. When we say that the 12 CDs
contain 1,140 PDFs, that does not double-count for the approximately 240 PDFs that
were re-scanned. There is a pending invoice of approximately $900 that Dr. Schapiro
has not yet paid.
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Montero had been providing a duplicate CD of the defense teams hand-selected

discovery documents to F B I Agent Deanne Lindsey, the case agent on the
Schapiro case, who thereafter opened at least four of the CDs and used the
contents of the CDs as part of her pre-trial preparation. It appears that this practice
of surreptitiously duplicating the discovery work-product of defense counsel in the
Southern District of Florida has been the norm for at least the last ten years. Here
is how we know all of this:
In an April 21, 2016 email from Mr. Montero to Cori Weiss, Healthcare
Fraud Paralegal Specialist at the U.S. Attorneys Office, Mr. Montero wrote that
Ms. Arteaga-Gomez wanted Mr. Montero to remove the post it notes prior to
returning the files and to ensure your office [U.S. Attorneys Office] does not
receive a copy of the disc. In the email, Mr. Montero further states:
I do not want it to jeopardize the case and it is for this reason that I am
advising the AUSA, Agent to please advise moving forward so that
my providing of a disc being paid by your [U.S. Attorneys] office
will not affect this case. Also, does the AUSA/Agent want our office
to remove these post it notes as they are your offices originals and
not opposing counsels.
See Ex. 1, Email 4/21/16 from Montero to Weiss (emphasis added). This
email suggests that Mr. Montero was not removing Ms. Arteaga-Gomezs post-it
notes before returning the documents to the FBI warehouse, and confirms that he
was providing a copy of the CDs to the government, contrary to the representations
made to Ms. Arteaga-Gomez.
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In an April 22, 2016, telephone conversation, AUSA Hayes informed Ms.

Arteaga-Gomez that Mr. Montero had in fact been providing one of the federal
agents copies of the CDs. AUSA Hayes proposed to immediately destroy the CDs.
Ms. Arteaga-Gomez asked AUSA Hayes to instead send her the CDs, rather than
destroy them, which he did. They remain in the possession of undersigned law firm
in the same condition that they were produced to us by AUSA Hayes. This April
22, 2016 conversation with AUSA Hayes was the first time that the defense team
was informed that the federal agent had been surreptitiously receiving the CDs.
Also on April 25, 2016, Ms. Arteaga-Gomez called Mr. Montero to ask him
who had instructed him to provide copies of the CDs to the government. Mr.
Montero stated that an agent had asked the Office Manager at Imaging Universe,
Jackie Balzola (a female), to provide the CDs to the government. Mr. Montero then
stated that he had been providing to the U.S. Attorneys Office for the past 10
years duplicate copies of the discovery documents selected by defense counsel in
other cases. On that day, Mr. Montero forwarded to Ms. Arteaga-Gomez his April
21, 2016 email to Cori Weiss (discussed above). In the forwarded email, Mr.
Montero writes:
Here is the email I sent the FBI and this practice has been one that has
been going on since 2006 that both Xpediacopy my old company and
Imaging Universe have provided the U.S.D.O.J. in the majority of the
cases where the government was not paying for the discovery services
or were paying for half of the services.
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See Ex. 1, Email from Ignacio Montero, Director of Imaging Universe.

On April 26, 2016, Ms. Arteaga-Gomez received an email, purporting to be
from Jackie Balzola, Office Manager of the copy service. In that email, Jackie
Balzola tells Ms. Arteaga-Gomez that she does
not work full time any longer due to surgery with my knees as well as I
am dealing with Lupus. I come in early in the morning set up invoices
and deliveries for the day and then I go home. Regarding Biscayne
Millieu, I have not spoken to or been given instructions by any agent
to provide a disc, this is something that has been ongoing as per
Ignacio on every case.
See Ex. 2, Email (4/26/16) from Jackie Balzola, Office Manager.
In the last several weeks, undersigned counsel have had multiple
conversations with the prosecutors and their supervisors about this situation. The
U.S. Attorneys Office (USAO) has admitted that Agent Deanne Lindsey had been
receiving copies of the CDs and had been keeping the duplicate CDs in a folder as
she received them; that she confessed to opening four of those duplicate CDs to
locate files that were contained on those CDs; that she copied and pasted some of
the files on those duplicate CDs onto her own CDs and provided those new CDs to
the Governments expert witness for trial preparation.
In order for FBI Agent Lindsey to locate files on the duplicate CDs that she
admits she copied, she would have had the opportunity to see the titles of all of the
PDFs that were contained on the CDs, even if she did not look at the PDFs
themselves. The titles of the PDFs reveal the identity of the hand selected
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documents that Dr. Schapiro and counsel deemed important to the defense at trial.
This week, the USAO notified undersigned that the Director of the copy
service, Ignacio Montero, has confessed to lying to Rossana Arteaga-Gomez about
the discovery process. Montero lied when he told Rossana Arteaga-Gomez that the
CDs were not being provided to the Government; he lied when he told Rossana
Arteaga-Gomez that Jackie Balzola was the Office Manager at Imaging Universe
(apparently, she has not worked at Imaging Universe for some time); he used a
shadow email address with Jackie Balzolas name and signature when sending
emails to Rossana Arteaga-Gomez, making it appear that the emails were coming
from Jackie Balzola, when someone else (perhaps Ignacio, himself) was emailing
Rossana Arteaga-Gomez; and he enlisted an unidentified girlfriend to falsely
impersonate Jackie Balzola when Rossana Arteaga-Gomez called to discuss
problems with copying the Rule 16 discovery.
II.

LEGAL ARGUMENT

The conduct of the Government and the copy service is alarming. The
integrity of the Rule 16 discovery process has been compromised. The defendants
right to prepare for trial without Government intrusion has been violated. The case
should be dismissed.
The work-product doctrine applies to criminal litigation. United States v.
Nobles, 422 U.S. 225, 236 (1975). At its core, the work-product doctrine shelters
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the mental processes of the attorney, providing a privileged area within which he
can analyze and prepare his clients case. Id. at 238. A defense attorneys
selection and compilation of documents in preparation for trial constitutes work
product. United States v. Horn, 811 F. Supp. 739, 746 (D.N.H. 1992); see also
United States v. June, 10-30021, 2011 WL 5330788, at *2 (D. Mass Oct. 19,
2011). Courts have concluded that the selection process itself reveals counsels
mental impressions as to how evidence relates to issues and defenses in the
litigation. Horn, 811 F. Supp. at 746 (citing Sporck v. Peil, 759 F.2d 312, 315 (3d
Cir. 1985). The Horn court found that in a criminal proceeding where important
constitutional rights of due process under the Fifth Amendment and effective
assistance of counsel under the Sixth Amendment are at stake, along with the
liberty interests of the defendant[], this work product deserves special protection.
Id. at 747 (citing Nobles, 422 U.S. at 238).
The government is forbidden from eavesdropping or planting agents to hear
or disrupt councils of the defense. See, e.g., United States v. Henry, 447 U.S. 264
(1980); O'Brien v. United States, 386 U.S. 345 (1967); Black v. United States, 385
U.S. 26 (1966); see also In re Terkeltoub, 256 F. Supp. 683, 685 (S.D.N.Y. 1966)
(The defendant has the right to prepare in secret . . . The prosecutions secret
intrusion offends both the Fifth and Sixth Amendment.) (citations omitted).

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Although the Sixth Amendment is concerned primarily with fairness

at trial, it is not limited to that function. The right to counsel protects
the whole range of the accuseds interests implicated by a criminal
prosecution.
These interests may extend beyond the wish for
exoneration to include, for example, the possibilities of a lesser
charge, a lighter sentence, or the alleviation of the practical burdens
of a trial.
***
Moreover, the appellants need not prove that the prosecution actually
used the information obtained. The prosecution makes a host of
discretionary and judgmental decisions in preparing its case. It would
be virtually impossible for an appellant or a court to sort out how any
particular piece of information in the possession of the prosecution
was consciously or subconsciously factored into each of those
decisions.
Mere possession by the prosecution of otherwise
confidential knowledge about the defense's strategy or position is
sufficient in itself to establish detriment to the criminal defendant.
Such information is inherently detrimental, ... unfairly advantage[s]
the prosecution, and threaten[s] to subvert the adversary system of
criminal justice. Further, once the investigatory arm of the
government has obtained information, that information may
reasonably be assumed to have been passed on to other governmental
organs responsible for prosecution. Such a presumption merely
reflects the normal high level of formal and informal cooperation
which exists between the two arms of the executive.
Briggs v. Goodwin, 698 F.2d 486, 494-95 (D.C. Cir.) (quoting Weatherford v.
Bursey, 429 U.S. 545, 556 (1977), rehg granted and opinion vacated on other
grounds, 712 F.2d 1444 (D.C. Cir. 1983).
Here, Agent Lindsey was obtaining duplicate copies of all of the CDs that
contained the defense teams work product. Agent Lindsey opened at least four of
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the CDs and disseminated at least some of the contents of CDs to the
Governments expert witness. Meanwhile Agent Lindsey placed before her own
eyes an index of the defendants hand-selected documents significant to his
defense. And Mr. Monteros email exposed that this practice is not the actions of
just one rogue agent or prosecutor. Compare Horn (one prosecutor in one case).
Rather, there appears to be an office-wide policy of the U.S. Attorneys Office
in the Southern District of Florida and the Federal Bureau of Investigations in
practice for at least ten years of surreptitiously copying defense counsels work
product through the government-contracted copy service that the Government
requires defense counsel to use to obtain the discovery documents needed to
properly prepare for trial.
Covertly cloning defense counsels work-product to obtain a tactical
advantage is nothing short of shocking to the universal sense of justice,
mandated by the Due Process Clause of the Fifth Amendment. United States v.
Russell, 411 U.S. 423, 432 (1973) (quoting Kinsella v. United States ex rel.
Singleton, 361 U.S. 234, 246 (1960)). Just the act of opening the CDs gave Agent
Lindsey an unauthorized preview of the titles of the documents hand-selected by
Dr. Schapiro and his defense team say nothing of Agent Lindsey actually helping
herself to the content of the CDs to prepare the case for the prosecution. To the
extent that the prosecution team can infer from Dr. Schapiros selection of
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discovery documents his thought process, the government has violated his Fifth
Amendment right not to be compelled to be a witness against himself. This
intrusion into the attorney-client relationship has also violated Dr. Schapiros Sixth
Amendment right to the effective assistance of counsel. See Massiah v. United
States, 377 U.S. 201, 206 (1964) (finding a Sixth Amendment violation where
agent surreptitiously listened in on defendants conversation after he was indicted
and represented by counsel). That the government-contracted copy service misled
Ms. Arteaga-Gomez in order to cover-up the office-wide policy makes this case
especially egregious. Dismissal with prejudice is the appropriate remedy. See
United States v. Levy, 577 F.2d 200, 208 (3rd Cir. 1978) (dismissing indictment,
rather than merely disqualifying prosecution team, where government invaded
the

defense

camp

and

learned defense

strategies:

The

government's

knowledge of any part of the defense strategy might benefit the government in
its further investigation of the case, in the subtle process of pretrial discussion
with potential witnesses, in the selection of jurors, or in the dynamics of trial
itself. . . The government's knowledge of this planned strategy would permit it not
only to anticipate and counter such an attack on its witnesses credibility, but also
to select jurors who would be more receptive . . . .).
Alternatively, this Court should disqualify the entire prosecution team from
any further participation in the prosecution of Dr. Schapiro. The intrusion by any
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member of the prosecution team taints them all no different than when a conflict
of interest of one lawyer in a law firm disqualifies the entire law firm from
representation. See Freund v. Butterworth, 165 F.3d 839, 863 (11th Cir. 1999)
([A]ny conflict of interest attributable to Colton imputes equally to his current
partners and employees. Cox v. American Cast Iron Pipe Co., 847 F.2d 725, 729
(11th Cir. 1988); see also Rule Regulating Fla. Bar 41.10(a) (While lawyers are
associated in a firm, none of them shall knowingly represent a client when any 1 of
them practicing alone would be prohibited from doing so[.]). After all, Agent
Lindsey is the case agent, responsible for organizing the documents and
debriefing the cooperating witnesses in preparation for trial. She has tainted
herself and others by her unauthorized review of the defendants work-product.
The court should convene a taint hearing to identify who else had
possession of or access to the work-product and to require that the government bear
the burden of proving that it has not, nor will it, make any direct or derivative use
of the illegally obtained work-product. See generally Kastigar v. United States,
406 U.S. 441 (1972). Insofar as members of the t a i n t e d prosecution team
have prepared government witnesses to testify against Dr. Shapiro after the
instrusion, those witnesses should be excluded.
Meanwhile, the entire discovery process has been compromised and
paralyzed. For several weeks, while the USAO has been conducting its own
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internal investigation into the misconduct, there has been no reliable means for the
defense to continue its review and copying of the discovery. If this case is to
proceed to trial, the court must intervene and establish enforceable rules for the
continued review of the discovery and grant a meaningful continuance so that the
defense can regain access to the discovery and assure itself that the CDs that were
provided to date contain all of the key documents that the defendant requested
during the last 16 months. 2
Respectfully submitted,
BLACK, SREBNICK, KORNSPAN
& STUMPF, P.A.
201 South Biscayne Boulevard, Suite 1300
Miami, Florida 33131
Ph. (305) 371-6421 Fax (305) 358-2006
E-mail: HSrebnick@RoyBlack.com
/s/ Howard Srebnick
HOWARD SREBNICK, ESQ.
Florida Bar No. 919063
/s/ Rossana Arteaga-Gomez
ROSSANA ARTEAGA-GOMEZ, ESQ.
Florida Bar No. 0014932
Counsel for Salo Schapiro

Just yesterday, the Government notified defense cousel that additional Discovery
went out via FedEx, encl[osing] 4 DVDs of 302s and Medicare/SGS documents.
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VERIFICATION
I declare under penalty of perjury under the laws of the United States that
the facts as alleged in this pleading are true and correct to the best of my
knowledge, see 28 U.S.C. 1746.
/s/ Rossana Arteaga-Gomez
ROSSANA ARTEAGA-GOMEZ, ESQ.
Florida Bar No. 0014932

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 2, 2016, a draft of this motion was

served upon Assistant United States Attorney Jim Hayes for his review in an
attempt to resolve the issue without court intervention. The parties were not able to
resolve the matter.
/s/ Rossana Arteaga-Gomez
ROSSANA ARTEAGA-GOMEZ, ESQ.
Florida Bar No. 0014932
Counsel for Salo Schapiro

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EXHIBIT 1

Case 1:14-cr-20715-MGC Document 174-1 Entered on FLSD Docket 05/26/2016 Page 2 of 2

Rossana Arteaga-Gomez
From:
Sent:
To:
Subject:

Ignacio Montero <montero@imaginguniverse.com>

Monday, April 25, 2016 10:53 AM
Rossana Arteaga-Gomez
FW: Biscayne Millieu

HereistheemailIsenttheFBIandthispracticehasbeenonethathasbeengoingonsince2006thatbothXpediacopy
myoldcompanyandImagingUniversehaveprovidedtheU.S.D.O.Jinthemajorityofthecaseswherethegovernment
wasnotpayingforthediscoveryservicesorwerepayingforhalfoftheservices.
From: Ignacio Montero [mailto:montero@imaginguniverse.com]
Sent: Thursday, April 21, 2016 12:12 AM
To: 'Weiss, Cori (USAFLS)'
Subject: Biscayne Millieu

Cori,
IapologizeIhavesomanynamesinmyheadthatIdonotremembertheagentontheBMcase,Iwanttoletherknow
thatwearedonewiththeproductionIamcurrentlyholdingitperopposingcounselasshewouldliketocheckthe
imagesfirstandhavemeremovethepostitnotespriortoreturningthefiles.Shealsowouldliketoensureyouroffice
doesnotreceiveacopyofthedisc.Yourofficeasifitweretheotherwayaroundcanpurchasethediscastheseare
youroriginals.Idonotknowwhattosayanymore,butIwouldlikesomeonewhetheritistheAUSAonthecasetobe
awareandmovingforwardIneedtohavearecordformyselfandwouldneedaprintordershouldyourofficewantthe
copyofthediscasyouknowthepriceis$15.00.IdonotwantittojeopardizethecaseanditisforthisreasonthatIam
advisingtheAUSA,Agenttopleaseadvisemovingforwardsothatmyprovidingofadiscbeingpaidbyyourofficewill
notaffectthiscase.Also,doestheAUSA/Agentwantourofficetoremovethesepostitnotesastheyareyouroffices
originalsandnotopposingcounsels.Mycellularislistedbelowforanyone,IwillbeindisposedattheVAtomorrowand
Iamnotsurehowlongthatwilltake,itistheVAbutpleaseletmeknowatyourearliest,Iwillcheckmyvoicemailand
respondasquicklyasIcan.Ialsomaynothaveaccesstomyemailandmayreplylatersopleaseusethecellularifitis
after4/21/1611am,thankyou.
Sincerely,

IgnacioE.Montero
Director

3350S.W.3rdAve.Ste.6
FortLauderdale,FL33315
(954) 4688442Office
(954) 4681950Fax
(954) 6088646Cellular
www.imaginguniverse.com

Case 1:14-cr-20715-MGC Document 174-2 Entered on FLSD Docket 05/26/2016 Page 1 of 2

EXHIBIT 2

Case 1:14-cr-20715-MGC Document 174-2 Entered on FLSD Docket 05/26/2016 Page 2 of 2

Rossana Arteaga-Gomez
From:
Sent:
To:
Subject:

Imaging Universe, Inc. Info <info@imaginguniverse.com>

Tuesday, April 26, 2016 6:57 AM
Rossana Arteaga-Gomez
Biscayne Millieu

Rosanna,
Goodmorning,Iwillcallyoualittlelaterinthemorning,Idonotworkfulltimeanylongerduetosurgerywithmy
kneesaswellasIamdealingwithLupus.Icomeinearlyinthemorningsetupinvoicesanddeliveriesforthedayand
thenIgohome.RegardingBiscayneMillieu,Ihavenotspokentoorbeengiveninstructionsbyanyagenttoprovidea
disc,thisissomethingthathasbeenongoingasperIgnaciooneverycase.

Warmregards,
JackieBalzola
OfficeManager

3350S.W.3rdAve.Ste.6
FortLauderdale,FL3315
(954) 4688442Office
(954) 4681950Fax
www.imaginguniverse.com