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APPLICATION FOR SEARCH WARRANT

In the Matter of

Mark Lenzie Bibbs

410 N Boylan Avenue, Suite 78, Raleigh, NC 27603

2005 Lexus RX330, VIN#2T2HA31U8SC041052, NC Registration "UMLB"

AFFIDAVIT TO ESTABLISH PROBABLE CAUSE

I, the undersigned affiant, A. H. Jones, have been a Law Enforcement Officer for over

thirty nine (39) years. Currently I am employed as a full time, sworn law enforcement agent by

the North Carolina Department of the Secretary of State (SOS). During my 39 years of service I

have worked as a Special Agent, Securities Investigator, Detective Sergeant/Supervisor of

Criminal Investigation Unit, Criminal Investigator, Internal Affairs Investigator, Commander of

Specialized Street Crimes Unit, Commander Patrol Unit, Sergeant Specialized Street Crimes

Unit, Detective in Special Operations Division (Narcotics & Vice), Member of Specialized Street

Crime Unit, Juvenile Detective, School Resource Officer, Police Officer, and Deputy Sheriff in

the Patrol, Civil and Court divisions,

I have been awarded the Advanced Law Enforcement Certificate by the North Carolina Criminal

Justice and Education Standards Commission. I have received specialized training in Criminal

Investigations, Interview and Interrogation, Legal Issues, Civil Process, Laws of Arrest Search

and Seizure, Internal Affairs Investigations, Narcotics and Vice Investigations, Preliminary

... . Investigations, Criminal Intelligence Analysis, Credit Card and Check Fraud, Insurance Fraud,

Securities Violations, Trademarks, and Notary violations. I have received an extensive amount

of hours of regular in-service training and instruction on law enforcement matters.

I have supervised, conducted, and assisted in more than a thousand criminal investigations

during the course of my law enforcement career, I previously held Certification as a North

Carolina Law Enforcement Instructor, and have taught both in the Basic Law Enforcement

Programs and in the Criminal Justice Curriculum Program at Coastal Carolina Community

College/Jacksonville, NC; James Sprunt Community College/Kenansville, NC; Durham

Technical Community College/Durham, NC; and Wake Technical Community College/Raleigh,

NC.
ATTACHMENT I

APPLICATION FOR SEARCH WARRANT

PROPERTY AND DOCUMENTS TO BE SEIZED

I. Certain Property and documents, to wit:

A) Any and all records, documents, or other items in the custody and/or control of Mark L.

Bibbs (hereinafter referred to as "Bibbs"), Long Leaf Pine Consulting, LLC, Bibbs Law Group,

The Bibbs Law Firm, Bibbs Law Office, P.L.L.C., relating to lobbying services, legal services,

or any other associated activities regarding NC Bail Academy, LLC, Rockford-Cohen Group,

. LLC, Cannon Surety, LLC, Premier Judicial Consultants, LLC, All American Bail Bonds, LLC,

VAL Investments, LLC, American Regional Residency Investment Venture Enterprises, LLC.

Any other items related to the crime of unregistered lobbying activities (N.C. G.S. 120C-200),

and/or and any other Common Law violations to include Felony Obstruction of Justice. These

items include, but are not limited to any and all records, documents, or other items related to

payments for lobbying activities. Any and all records, documents, or other items of evidence

related to documents provided directly or indirectly by Bibbs, Mina Mustian aka Lyne

Thompson to the Division over the course of this investigation. This includes, but is not limited

to receipts for cash payments, receipts, invoices, ledgers, notebooks, text messages, photographic

images, annual reports, tax records for state and federal taxes, U.S. Mail, FedEx, and UPS

records, and any other shipping company records, documents representing payments by

individuals, cancelled checks (including certified checks and receipts), statements, stubs, drafts

from banks or financial institutions, receipts or confirmations of wire transfers or any other wire

transfer records documenting deposits or disbursements (including but not limited to receipts and

advises and transfer request records), correspondence, any and all records of communications,

lists or documentation of any and all individuals employed by or acting on behalf of Bibbs,

documentation of all telephone numbers relating to Bibbs, and records of financial accounts

related to Bibbs individually, and Long Leaf Pine Consulting, Bibbs Law Group, The Bibbs Law

Firm, Bibbs Law Office, P .L.L.C.

B) All of the above records, documents, information and data in whatever form and by whatever

means they (and their drafts and modifications) may have been created or stored, including

handmade form, photographic form, mechanical form, electrical, electronic, optical or magnetic

form as well as printouts or readouts from any electronic optical or magnetic storage device. The

electronic magnetic or optical media could include, but would not be limited to, floppy diskettes,

fixed hard disks or hard drives, removable hard disk cartridges, tapes, laser discs, (all variations

of CD, DVD formats), flash media, ''thumb drives" or other USB device, videocassettes and any

other media capable of storing such coding including media associated with personal digital
assistants, (PDAs) and other wireless hand.held communication and data devices, such as cellular

phones, Blackberrys, or smart phones.

II. Computer hardware, to wit:

Any and all electronic devices and equipment which are capable of collecting, creating,

anaylyzing, displaying, converting, storing, concealing, or transmitting electronic, optical,

magnetic, or similar computer impulses or data. These devices would include, but are not

limited to, i) data-processing devices such as computer system units, memory typewriters, and

self contained laptop or notebook computers and Personal Digital Assistants (PDAs); ii) internal

and peripheral storage devices, such as fixed disks, external hard disks, floppy disk drives and

diskettes, tape drives and tapes, optical storage devices, transistor-like binary devices, flash

memory or "thumb drives" and other digital storage devices; iii) peripheral input/output devices;

and, iv) releated communications or network devices such as routers, modems, cables and

connectors, recording devices, RAM or ROM units; v) hand-held communication and data

devices such as ''tablets", cellular phones, "smart phones", BlackBerrys, iPhones and similar

devices; as well as any devices, mechanisms or parts that can be used to restrict access to

computer hardware such as physical keys and locks.

III. Computer software, to wit:

Any and all digital information, instruction, algorithm or program stored in the form of

electronic, optical or magnetic media, which is capable of being interpreted by a computer or any

of its related components to direct the manner in which such computer or components work.

Software is stored in electronic, magnetic, optical or other digital form. Software commonly

includes, but is not limited to, programs to run operating systems, applications such as word

processing, graphics or spreadsheet programs, utility programs, compilers interpreters, and

communications programs used to communicate with computer hardware or peripherals either

directly, telephonically or through other transmission media.

IV. Computer related documentation and manuals, to wit:

Any and all written, recorded, printed or digitally stored material which explains or illustrates

how to configure or use computer hardware, software or other related items.


ATTACHMENT II

APPLICATION FOR SEARCH WARRANT

DESCRIPTION OF SEARCH LOCATION

The location to be searched is 4 1 0 N Boylan Avenue, Suite 78, Raleigh, NC 27603, and any

buildings, structures or vehicles within the curtiledge, including, but not limited to a 2005 Lexus

RX3 3 0 , 5-door wagon, white in color, VIN #2T2HA31U85C041052, bearing NC personalized

registration plate "UMLB". 4 1 0 N Boylan Avenue, Raleigh, NC is an office building containing

private offices located within the City of Raleigh, County of Wake, North Carolina. The

structure is painted white in color. The front entry facing North Boylan Avenue has the numbers

"41 O" above the double glass doors, and "BOYLAN Executive Center" on a half brick wall in

front of the building. A directory inside the front doors indicates Bibbs Law Group and Long

Leaf Pine Consulting are located in Suite #78.


ATTACHMENT ID

APPLICATION FOR SEARCH WARRANT

BACKGROUND TO ESTABLISH PROBABLE CAUSE

On or about July 5, 2 0 1 6 , the Lobbying Compliance Division (hereinafter referred to as

Division) of the North Carolina Department of the Secretary of State (SOS) began receiving

numerous inquiries regarding whether Attorney Mark L. Bibbs (Bibbs) was registered as a

Lobbyist. Division employees received phone calls or emails from at least four individuals

regarding Bibbs' lobbying status.

The Division received an email from an individual (hereinafter referred to as Complainant # 1 )

asking if Bibbs, individually or through a company was registered to lobby at the NC General

Assembly. Complainant #1 also sent an email stating: "I have recently witnessed Mr. Bibbs at

the North Carolina General Assembly while engaged in (what I believed to be lobbying) against

Senate Bill 508." SB 508 is described as an ACT to make various amendments to the Bail Bond,

Collection Agency, and Criminal Mediation Laws.

In response to the multiple inquiries and emails the Division files were searched and it was

confirmed that Bibbs was not registered as a lobbyist for any Principal until ten (10) days after

the Division began receiving complaints. On July 1 5 , 2016 Bibbs registered as a lobbyist for

Cannon Surety (Cannon).

North Carolina General Statute (NC GS) 120C-200(a) requires that lobbyists, principals, and

solicitors must register with the Secretary of State' s office before engaging in any lobbying. It

shall be unlawful for an individual to lobby without registering within one business day of

engaging in any lobbying.

Division records confirm from January 1 , 2 0 1 6 through July 7, 2 0 1 6 there were no Principal

registrations naming Bibbs as their lobbyist. However, on July 8, 2 0 1 6 (three (3) days after the

complaints began) Dallas McClain (McClain) President of Cannon registered Cannon as a

Principal and named Bibbs as its lobbyist.

The law states Principals must also file a written authorization for lobbyists, and lobbyists must

file a separate registration statement for each principal each year. Lobbyists, principals, and

solicitors must register with the NC Secretary of State every year.

The Division received formal written complaints from Complainant #1 and another individual

(hereinafter referred to as Complainant #2). In their complaints both allege Bibbs violated the

lobbying statute by lobbying while he was not registered. Complainant #2 stated in their
complaint that there was additional supporting evidence contained in recorded transcripts of SB

508 committee meetings at the NC General Assembly.

Complainant #1 advised when Bibbs was lobbying he was in the company of Dallas McClain

(McClain) President of Cannon Surety, LLC, and Lyne Thompson (Thompson) General

Manager of NC Bail Academy (NCBA). Complainant #1 stated that Thompson, McClain and

Carl Bayless Valentine (Valentine) owner of All American Bail Bonds (AABB) are all involved

in multiple businesses together that center on the bail bond industry.

In addition the Division received communication from another individual (hereinafter referred to

as Complainant #3) stating the complainant on several occasions observed Bibbs openly

lobbying in opposition to SB 508. After observing Bibbs lobbying Complainant #3 stated the

complainant checked with the Division and discovered Bibbs was not registered.

Complainant #3 stated the complainant attended the House Committee on Judiciary ill (HCJ Ill)

hearing on June 28, 2016, and the complainant believed Bibbs introduced himself to the committee

as representing Cannon Surety. The complainant stated Bibbs was lobbying in opposition to SB

508. The complainant stated the complainant also attended the NC Courts Commission (NCCC)

Hearing that was held on February 12, 2016, and advised both Bibbs and Thompson were lobbying

against SB 508.

Based on the above information the Department initiated an investigation (Lobbying Compliance

Division Case #2016-02). Special AgenfA H. Jones (SA Jones) was assigned to investigate.

The Division obtained the official minutes, and sign.up sheets for the June 15, and 28, 2016 HCJ.m_ ..

hearings, and also for the February 12, 2016 NCCC hearing. Audio recordings were also obtained

for the June 28th HCJ m hearing, and the NCCC hearing.

The evidence confirmed that on June 15, 2016 Bibbs signed in on the HCJ m Visitor Registration

Sheet and listed his firm or agency as "LLPC" (Long Leaf Pine Consulting). However, at the June

28th hearing Bibbs signed in and gave his firm or agency as "BLG" (Bibbs Law Group). The audio

recording for the June 28th hearing confirmed Bibbs addressed the committee in opposition to SB

508, and stated that he represented Cannon Surety, a captive insurance company in Greensboro, NC.

The NCCC hearing audio recording confirmed Bibbs spoke before the Commission, identified

himself and stated he represented Cannon and the NC Bail Academy. The NCCC has several

members who are for purposes of G.S. 120C (Lobbying Act), "covered persons"

The evidence independently substantiates and confirms the allegations made by all the complainants

that Bibbs was lobbying against SB 508 for Cannon and NCBA while he was not registered as a

lobbyist, and Cannon and NC Bail Academy were not registered as principals.
On July 5, 2016 McClain/Cannon sent the Division an email stating "I am writing to try to correct a

registration deficiency'', and on July 6, 2016 Bibbs sent the Division an email from his

longleafpineconsulting@gmail.com account that mirrored McClain's. Bibbs stated in his email:

"I am writing to try to correct a lobbying registration deficiency."

Complainant's #1 and #2 shared with the Division numerous emails authored by Bibbs. The emails

are directed to covered persons under G.S. 120C, and are openly lobbying in opposition to SB 508.

The emails were sent from Bibbs' Law Group email account "bibbslawgroup@gmail.com", and not

from Bibbs' lobbying company email account longleafpineconsulting@gmail.com. All the emails

were sent during the time period Bibbs was not registered.

On June 27, 2 0 1 6 Bibbs sent an email to NC House Representatives Ted Davis, Sarah Stevens,

Duane Hall, Rena Turner, John Bell, Rayne Brown, George Cleveland, Jean Farmer-Butterfield,

Kelly Hastings, Craig Hom, Verla Insko, Michael Speciale, Lee Zachary, Pricey Harrison and

others titled: "Opposition To PCS for Senate Bill 508 - A BAD BAD BILL". June 27, 2 0 1 6 was

the day before Bibbs addressed the HCfIII. Toe email was sent using the law group email address.

On June 28, 2016 (the same day he appeared before the HCJ III) Bibbs sent another email to

Representatives Pricey Harrison, Leo Daughtry, Robert Reives, 'Paul Stam, Mickey Michaux,

Darren Jackson, Larry Hall, Grier Martin, William Richardson, Hugh Blackwell, Rob Bryan, Dan

Bishop, David Lewis, and House Speaker Tim Moore lobbying them to vote against the PCS for

Senate Bill 508. This email was also sent using the law group email account.

Bibbs also used bibbslawgroup@gmail.com to distribute numerous advertisements focused on the

bail bond industry. The emails were directed to the Bail Bond Industry and Bail Agents, and in the

emails Bibbs states he is a lawyer and lobbyist for the North Carolina Bail Academy and Cannon

Surety. LLC. Bibbs also states he is a lobbyist for bail bond issues before the NC General

Assembly. The described emails were sent out during the time period Bibbs was not registered, and

Cannon and North Carolina Bail Academy were not registered as principals.

Bibbs was interviewed on December 9, 2016, and tted he had lobbied without being registered.

He also admitted that he was paid for his lobbying efforts by Cannon and NCBA. Bibbs stated

McClain/Cannon signed a two year lobbying contract with him in January 2015, and agreed to pay

$6,000.00 per month over the life of the contract, ($72,000.00 per year). Bibbs stated Cannon is

still carrying a balance of $48,000.00 for 2015. Bibbs advised he keeps his lobbying fees and legal

fees in separate bank accounts.

Bibbs admitted Thompson/NCBA's contract with him was the same as McClain's, two (2) years

beginning January 2015 at $6,000.00 per month over the life of the contract. Bibbs stated he did not

represent NCBA in 2016. Bibbs stated Thompson has paid, but maybe owes just a small amount.

Bibbs advised his lobbying relationship with NCBA ended when Thompson submitted an affidavit

to the Division stating NCBA's July 2 0 1 5 registration was submitted in error.


Cannon did not file delinquent expense reports for the first three quarters of2015 until November

29, 2016, and on Febrwuy 6, 2017 the Division received Cannon's amended fourth quarter Principal

expense report for year 2015 disclosing payments to Bibbs totaling $24,000. As of this date the

Division has not received McClain/Cannon's fourth (4th) quarter 2016 Principal expense report

form.

NC GS 120C-403(a) states that each lobbyist principal shall file quarterly reports under oath with

the Secretary of State with respect to each lobbyist principal. NC GS 120C-403(b) states the report

shall be filed whether or not reportable expenditures are made, and shall be due 15 business dav.!
after the end of the reporting period.

NCGS 120C-403(dXl) states each lobbyist principal shall .annually, in the last report for the

registration period under G.S. 120-200(dXl), report the cumulative combined total of all payments

made during the registration period for all payments for lobbying.

The Division obtained financial records for Carinon and AABB for the time period beginning

January 2015 and ending August 2016. Financial records for AABB were obtained due to the fact

that SOS Corporation Division records revealed that corporation fees associated with NCBA and its

parent company (Rockford-Cohen Group, LLC) were paid for by Valentine (AABB).

Cannon's records did not containsupporting evidence of the monthly $6,000 payments described by

Bibbs.and did not contain evidence of Cannon's self reported $24,000 paid to Bibbs in 2015. The

Cannon records contained five (5) checks made payable to Bibbs totaling $5,490. The checks did

not contain any information identifying the purpose of the payments.

However, AABB's financial records did contain checks made payable to Mark Bibbs totaling

approximately $17,684.88. 14 checks bad for "Odom case" in the memo line. The financial records

also contained one check issued by AABB and made payable to Mark Bibbs for $2,000. Memo line

on check contained: For "Thompson/McClain". When Bibbs was asked about the "Odom case" he

stated he did not remember any Odom case.

In addition the financial records revealed payments from AABB to Cannon totaling $12,894 for

"loan", and numerous checks from Cannon made payable to AABB employee (Gudiel Toledo)

totaling approximately $10,918.50. Toledo did not cash or deposit the chc:cks. Instead he signed

the checks over and made them pale to Valentine and AABB.

NCBA's General Manager (Lyne Thompson) was interviewed on February 9, 2017. Prior to the

interview SA Jones discovered that Thompson is actually Mina Lynette Mustian (Mustian).

Mustian stated in the interview that she was Lyne Thompson. She stated she married 33 years ago,

but never legally changed her name. Mustian could not remember any details about where she got

married, but agreed to release a copy of her marriage license to the Division. However, to date

Mustian has failed to supply the Division with any supporting evidence of that claim.
Mustian admitted to hiring Bibbs to lobby on behalf ofNCBA in 2015, but denied Bibbs lobbied for

NCBA in 2016. Mustian agreed her contract with Bibbs was for $6,000 per month, and stated the

monthly statements she received from Bibbs show $6,000, but advised Bibbs agreed to accept

$2,000. Mustian stated she would not have paid Bibbs in May and June 2015 because he resigned

from representing NCBA and Cannon in May of 2015. She believes she paid him between $20,000

and $24,000 total in 2015. Mustian stated she paid Bibbs by check, direct deposit, and cash. She

stated cash was Bibbs' preferred method of payment, but insisted Bibbs had given her paper receipts

for the cash. Mustian denied owing Bibbs any money for lobbying, and stated that Bibbs had a

drinking problem around that time and probably did not remember her paying him. Mustian agreed

to voluntarily give the Division copies of the cancelled checks and receipts for cash.

Mustian was confronted with the Principal expense report forms she submitted for 2015 showing no

payments to Bibbs. She stated she only signed the reports and that someone else filled the reports

out for her: Mustian stated she didn't know she had to report the payments to Bibbs.

Mustian failed to contact SA Jones or make the documents available as she had promised. On

March 15, 2017 SA Jones contacted Mustian about the documents. Mustian stated she could not

produce the marriage license, but agreed to meet with SA Jones on March 21, 2017 and produce the

cancelled checks and receipts showing her payments to Bibbs. Mustian stated she had spoken to

Bibbs and he advised her the money she paid was not for Lobbying, but was for legal fees. She

stated she didn't believe that was correct

On March 21, 2017 Mustian failed to meet SA Jones as agreed, and failed to make contact by

phone, text, or email. However, on March 23, 2017 Mustian sent SA Jones an email stating she had

spoken with Bibbs and he advised her payments were not for lobbying, but instead were a legal

retainer. Mustian stated she remembered incorrectly. Mustian attached to the email a folder

containing receipts for legal services for each month of 2015. All but one indicates a monthly

retainer of$2,000.00, payment of $2,000.00, and zero balance. At the top of the documents appears

"Bibbs Law Group", and in the body of the document it has the following: "RE: Receipt for

Monthly Statement for Legal Services."

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The March 2 0 1 5 receipt indicates it is for both February and March for a total payment of $4,000,

and balance of zero. However, the February, 2015 receipt also indicates a payment of $2,000

balance of zero. The documents appear to show that Bibbs double billed Mustian for the month of

February

It is believed the documents are not legitimate and were recently produced to prevent, obstruct,

impede, or hinder public or legal justice, and to avoid detection and legal consequences. The

information contained in the receipts and the mere existence of some of the documents is in direct

opposition to statements made by both Bibbs and Mustian in interviews with SOS agents.

Mustian stated in her initial interview with SOS agents that Bibbs invoiced her $6,000 each month,

but agreed to let her pay $2,000. The receipts recently sent to SA Jones by Mustian instead indicate

$2,000. In addition Mustian stated that she did not pay Bibbs for the months of May and June of

2015, because Bibbs resigned from representing NCBA and Cannon. The documents Mustian

submitted on March 23, 2017 include receipts for May and June 2015, and indicate payments were

made for those months.

Bibbs also stated to SOS agents that he did not represent NCBA after Thompson (aka Mustian) filed

an affidavit with the Division stating her July 2 0 1 5 registration was done in error. However, the

documents sent by Mustian include invoices for all 12 months of 2015.

On March 29, 2017 the Division received the financial records of Mustian, NCBA and Rockford

Cohen Group from Union Bank & Trust Co. The records contained a facsimile of NC Bail

Academy check # 1 1 5 1 dated October 2, 2015 and made payable to Mark L. Bibbs for $2,000. The
check was signed by Lyne Mustian, and the memo section indicates the check is for "October

lobbying fee". The information contained in the check is consistent with Mustian's original

statements she gave to the Division before she spoke with Bibbs, but the check is in conflict with

her most recent statements that Bibbs advised her she did not pay for lobbying, but instead paid him

a legal retainer.

Check 1 1 5 1 Amount $2,000.00 Date 10/13/2015

PROBABLE CAUSE TO BELIEVE EVIDENCE OF

THE CRIME IS LOCATED AT 410 N BOYLAN AVENUE, RALEIGH, NC 27603

and/or 2005 LEXUS RX330, VIN#2T2HA31U85C041052, NC REGISTRATION "UMLB"

The affiant has not included each and every fact known concerning this investigation. The

affiant has set forth the facts that the affiant believes are necessary to establish probable cause to

believe that the property to be seized supporting violations of Common Law Obstruction of

Justice and violations of Chapter 120C-200 of the N.C. General Statutes will be found at 4 1 0 N

Boylan Avenue, Suite 78, Raleigh, NC and/or in the listed vehicle (white in color, 2005 Lexus

RX300, VIN#2T2HA31U85C041052, NC personalized registration "UMLB".

Division lobbyist records list 4 1 0 N Boylan Avenue, Raleigh, NC. as the address of record for

Attorney Mark. L. Bibbs. The record also indicates Bibbs' lobbying firm as Long Leaf Pine

Consulting, LLC. Bibbs filed his lobbyist registration statement in July 2015 and listed the

physical address for Long Leaf Pine Consulting, LLC as 4 1 0 N Boylan Avenue, Raleigh, NC.

Bibbs also uses the 4 1 0 N Boylan Avenue, Raleigh, NC address in his lobbying email

communications with representatives of the NC House and other "covered persons".

The North Carolina Department of Motor Vehicle records confirm the 2005 Lexus RX330, white

in color, VIN#2T2HA31U85C041052, NC registration "UMLB" is the only vehicle currently

registered to Bibbs. The vehicle is registered at the 4 1 0 N Boylan Avenue address, and Bibbs.has

been observed in a vehicle matching its description while conducting business activity.

The affiant through the affiants training and experience has knowledge that perpetrators and/or

co-conspirators involved in crimes of this nature often produce fraudulent documents in an

attempt to avoid detection and prosecution. The devices being used to facilitate the fraud will
contain digital evidence to prove these offenses and identify the persons involved. Smart phones,

and/or !Phones used by these suspects will also contain evidence of the crimes and possibly

identify additional suspects.

The affiant is also aware that evidence of such criminal violations is usually found within the

devices such as computers, laptops, smart phones, tablets, IPhones used by the perpetrators,

and/or their co-conspirators, and that such perpetrators, and/or co-conspirators often maintain

devices containing digital data related to these schemes. Evidence related to the identification of

culpable involved parties and to the full scope and nature of the scheme is also routinely found in

the digital devices of the perpetrators, and/or their co-conspirators.

Therefore, the affiant respectfully puts forth that in order to continue the investigation it is

necessary to seize the digital devices and any and all records, documents, or other items

described above, preserve them and have them forensically analyzed to obtain the evidence. It

will also be necessary to seize paper documents and records in the custody and/or control of

Mark L. Bibbs, Long Leaf Pine Consulting, LLC, Bibbs Law Group, The Bibbs Law Firm, Bibbs

Law Office, P.L.L.C., related to the crime of unregistered lobbying activities (N.C. G.S. 120C-

200), and/or any other Common Law violations to include Felony Obstruction of Justice: These

items include, but are not limited to any and all records, documents, or other items related to

payments for lobbying activities, and any and all records, documents, or other items of evidence

related to documents provided directly or indirectly by Bibbs, Mina Mustian aka Lyne

Thompson to the Division over the course of this investigation relating to lobbying services,

legal services, or any other associated activities regarding NC Bail Academy, LLC, Rockford

Cohen Group, LLC, Cannon Surety, LLC, Premier Judicial Consultants, LLC, All American Bail

Bonds, LLC, VAL Investments, LLC, and American Regional Residency Investment Venture

Enterprises, LLC.

The documents will need to be preserved and examined. The a:ffiant respectfully requests the

Court to issue a warrant directing a search for and seizure of the items sought herein.

A. H. Jones, al Agent

North Carolina Department of the Secretary of State


File No.

ST ATE OF NORTH CAROLINA

In The General Court Of Justice

WAKE County D District lie] Superior C o u rt Division

IN THE MA TIER OF:


Name

INVENTORY OF ITEMS SEIZED


Mark L. Bibbs/410 N. Boylan Ave, Raleigh NC
PURSUANT TO SEARCH

G.S. 15A-223, 15A-254. -257

I , the undersigned officer, executed a search of:

Person, Premises Or Vehicle Searched Date Of Search

4 1 0 N. Boylan Ave,. Suite 78, Raleigh NC 27603 04-04-2017

This search was made pursuant to

lie] 1. a search warrant issued by: Superior Court Judge Donald Stephens

D 2. consent to search given by: -------------------------------

0 3. other legal justification for the search:


-----------------------------
The following items were seized:

From top drawer of tan file cabinet:

folder and contents labeled Brawley and McClain, also folder labeled Janet Ramirez with contents

green hanging folder and contents with manilla file folder and contents labeled Valentine, Carl

green hanging folder and contents with manilla folder labeled Day, Andre DOI case

brown red well folder and contents with manilla folder labeled Bibbs vs KS Bank

manilla folder not labeled with contents Premier Judicial Consultants vs Brawley

letter from Sharpless Stavola regarding Premier Judicial Consultants vs Brawley

letter from Steven McCloskey with attached civil summons dated December 8 2016

white envelope and contents marked Cannon PAC filing

Document entitled tirneline of events erroneous entry of default Premier Judicial Consultants vs Brawley

3 copies of certificate of contribution Marked Plaintiffs Exhibit

notice of hearing Premier Judicial Consultants vs Brawley

motion of objection and motion for relief Premier Judicial Consultants vs Brawley

Guilford County Superior court calendar request Premier Judicial Consultants vs Brawley

notice of hearing Premier Judicial Consultants vs Brawley

plaintiffs motion for sanctions Premier Judicial Consultants vs Brawley

motion to quash subpoena for Sam Jones Premier Judicial Consultants vs Brawley

Notice of withdrawal for appeal Premier Judicial Consultants vs Brawley

From second drawer of tan cabinet:

handwritten notes on legal pad paper containing the names Lynn, Dallas

legal pad with handwritten notes containing the names, Lynn, Dallas

Notice of Dismissal Rockford Cohen Group and Lynnette Thompson vs American Surety Company

time sheets

notebook paper with handwritten notes labeled Carl Valentine

Top of wooden desk:

Assorted receipts and checks stubs from top of desk

manilla folder and contents labeled Janet Ramirez

timesheets from top of desk

fax from AG Insurance Section Day vs DOI

(Over)

AOC-CR-206, Rev. 5/98


Original - File Copy - Person \/Vhose Property Seized

1998 Administrative Office of the Courts


Items Seized Continued:

Top of Tan file cabinet:

Notebook entitled the Lobbyist with Bibbs picture and time sheets

subpoena for Ronald Pierce Premier Judicial Consultants vs Brawley

5 eds labeled with Mark Bibbs

copies of checks from Cannon Surety, letter regarding filing of court documents, invoice for legal service to Cannon Surety,

documents regarding mediation with Cannon Surety, termination of representation for David Donnelly, document to Ditech Financial

regarding stale check

From Left Cabinet of wooden desk:

checkbook labeled old LLPC

white envelope with Merrill Lynch deposit slip$ l l ,400

From office floor:

Invoice from TAO Auto

Copies of checks from Cannon Surety

time sheets and Verizon call logs

legal pad with handwritten notes with names Lynn and Dallas

Top drawer of Cherry file cabinet:

checkbook with Bank of America Mark L Bibbs Attorney at Law

manilla folder and contents not labeled with documents regarding SB508

manilla folder labeled McClain, Dallas

Ii] 1 . I left a copy of this i n v e n t o ry with the person named below, who is:

D a. the owner of the premises searched.

D b. the owner of the vehicle searched.

Ii] c. the person in apparent control of the premises searched.

D d. the person in apparent control of the vehicle searched.

D e. the person from whom the items were taken.

D 2. As no person was present, I left a copy of this i n v e n t o ry :

D a. in the premises searched, i d e n t i fi e d on the reverse.

O b. in the vehicle searched, i d e n t i fi e d on the reverse.

Name And Address Of Person To Whom A Copy Of This Inventory Was Delivered, If Any

Mark L Bibbs 4 1 0 N. Boylan Avenue, Suite 78, Raleigh, NC

The law enforcement agency identified below will hold the seized roperty subject to c o u rt order.

teer

SWORN AND S U B S C R I B E D TO BEFORE ME

- - ,

ACKNOWLEDGMENT OF RECEIPT . . -'' - , , ' . : : ., ' ' - - . , : ' ,:' ; . .

I, the undersigned, received a copy of this i n v e n t o ry .

Date Signature of Person Receiving Inventory

AOC-CR-206, Side Two, Rev. 5/98

1 9 9 8 Administrative Office of the Courts


File No.

ST ATE OF NORTH CAROLINA

In The General Court Of Justice

D District Ii] Superior Court Division

IN THE MATTER OF:


Name

INVENTORY OF ITEMS SEIZED


Mark L. Bibbs/410 N. Boylan Avenue, Raleigh NC

PURSUANT TO SEARCH

G.S. 15A-223, 15A-254. -257

I, the undersigned officer, executed a search of:

Person, Premises Or Vehicle Searched Date Of Search

4 1 0 N. Boylan Ave, Suite 78, Raleigh NC 27603 04-04-2017

This search was made pursuant to

Ii] 1 . a search warrant issued by: Superior Court Judge Donald Stephens

D 2. consent to search given by: -------------------------------

0 3. other legal justification for the search:

--------------------------
The following items were seized:

Top drawer of cherry file cabinet contd:

manilla folder labeled Lobbying check copies 2015

manilla folder and contents labeled Dallas and Lyne

manilla folder and contents labeled lobbying ks and fax

From 2005 Lexus RX 330, VIN# 2T2HA31U85C041052, NC Registration: UMLB

Bank of America Long Leaf Pine Bank Statement

Camden Manor Move in statement

Samsung Verizon Phone Gray in color

copies of checks from Cannon Surety

check stubs from Cannon Surety

items of deposit from Bank of America to Mark Bibbs

Apple I Phone from top of desk: Serial Number F2LQMEXIGRWY Note: Phone was forensically imaged on site and given back

to Mr. Bibbs

ASUS Laptop Computer Serial Number: G2NOGR000444056 Note: Computer was forensically imaged on site and given back to

Mr. Bibbs

Samsung Note II Phone , Model Number: SCH-H05 Note: Phone was forensically imaged on site and given back to Mr. Bibbs.

(Over)

AOC-CR-206, Rev. 5/98 Original - File Copy - Person Whose Property Seized

1998 Administrative Office of the Courts


STATE OF.NORTH CAR5L\k.f: Q IN THE GENERAL COURT OF JUSTICE

SUPERIOR COURT DIVISION


WAKE COUNTY 2 0 1 1 APR -4 AM:4:, {'!

W.A' . G@t'JNT,Y,;. &!:


MOTION TO SEAL
INTHEMATTEROF..
. . . , ;.'!

SEARCH WARRANT

Investigation by - &

North Carolina Secretaryotate, ACCOMPANYING

Lobbying Compliance Division DOCUMENTS

NOW COMES the North Carolina Department of the Secretary of State, by and through

the undersigned Assistant Attorney General, pursuant to North Carolina General Statutes 1 3 2 -

1 . 4 ( e) and (k), and respectfully prays the Court to issue an Order requiring that the applications

for search warrants, search warrants and returns, accompanying affidavits and documents,

submitted contemporaneously herewith, along with this Motion and the resulting Order, be

sealed in the Office of the Clerk of Superior Court for Wake County until further order of the

court. The State shows the following:

I. The North Carolina Department of the Secretary of State, Lobbying Compliance

Division, is conducting an ongoing confidential criminal investigation regarding allegations of

the commission ofviolation(s) of Chapter 1 2 0 C Article 2, N.C. Gen. Stat. 120C-200 (Lobbyist

registration procedure) of the North 'Carolina Lobbying Law, said violation(s) believed to be

committed by certain individuals or entities identified in the search warrants.

2. No person or entity has been charged with any crime referenced in Lobbying

Compliance Division File #2016-02, and the investigation is ongoing.

3. As a result of this investigation, a search warrant has been obtained

contemporaneously herewith and will be executed without unnecessary delay.

4. The application for the search warrant, the search warrant and return, and the

accompanying affidavit and documents contain sensitive and confidential information.

5. The release of the above-mentioned documents to the public at this time would

jeopardize the Division's ongoing criminal investigation and possibly result in evasive actions by

the subjects of the investigation and other interested persons, and the destruction or secreting of

evidence related to this matter.

6. It is in the best interest of justice and would afford protection to all parties if the

above-mentioned documents were sealed in the Office of the Clerk of Superior Court for Wake

County until further order of the Court.

7. The state's interest in continuing this ongoing confidential investigation is

compelling and outweighs any interest by the press or public in having access to the above

mentioned documents until further order of the Court.

1
STATE OF NORTH CAROLINA Fl LE THE GENERAL COURT OF JUSTICE

WAKE COUNTY 2011 APR -4 AM ;,t$.JPERIOR COURT DIVISION

IN THE MATTER OF: ORDER TO SEAL

SEARCH WARRANT
,

Investigation by &

North Carolina Secretary of State, ACCOMPANYING

Lobbying Compliance Division DOCUMENTS

THIS CAUSE HAVING COME ON TO BE HEARD before the Judge Presiding, and

it appearing to the Court the following:

1. The North Carolina Department of the Secretary of State, Lobbying Compliance

Division, (the "Division"), is conducting an ongoing confidential criminal investigation

regarding allegations of the commission of violations of Chapter 1 2 0 C Article 2 of the North

Carolina Lobbying Statute, specifically N . C . G . S . 120C-200(a) (Lobbyist registration procedure).

2. No one has been charged with any crime reference File#2016-02, and the

investigation is ongoing.

3. Investigators with the North Carolina Department of the Secretary of State

applied for a search warrant contemporaneously herewith to search records of individuals being

investigated for violations o f N . C . G . S . 120C-200.

4. The search warrants for these records were granted today, April 3 , 2 0 1 7 , by the

undersigned Superior Court Judge, and was executed the same day.

5. The application for the search warrant, search warrant and return, accompanying

affidavit, Motion to Seal Search Warrant and Accompanying Documents, and Order to Seal

Search Warrant and Accompanying Documents contain very sensitive and confidential

information.

6. That the success of this investigation by the North Carolina Department of the

Secretary of State may be hindered by the publishing, at this time, of the contents of the

applications and warrants and returns thereof, this Motion and Order in the several manners

described in the State's Motion to Seal.

7. That the interest of justice will best be served by temporarily maintaining the secrecy

of said warrant, any attachments, return, application for search, the inventories of items seized,

the Motion and Order.

1
8. That to publicly disclose the basis for the search warrant, or the inventory of those

matters recovered from this location might hamper or impede this investigation and/or may

release information that could adversely affect persons who are not charged with committing a

crime and materially prejudice further adjudicable procedures involving this investigation and

any subsequent prosecution and will jeopardize the right of the state to prosecute a defendant or

the right of the defendant to receive a fair trial or will undermine an ongoing investigation.

IT IS THEREFORE ORDERED that the application, search warrant and

accompanying affidavit issued on the above referenced date, the return therefore, and this

Motion and Order be sealed by the Court and the contents thereof not released for a period of 90

days here from or until further order of this Court.

This the 3rd day of April, 2 0 1 7 .

Senior Resident Superior Court Judge

2
8. While other alternatives have been considered, sealing of the application for the

search warrants, the search warrants and returns, accompanying affidavits and documents, and

this Motion and the resulting Order, is essential to preserve higher values and is narrowly

tailored to serve that interest.

This the 3rd day of April, 2 0 1 7 .

t. Bar No. 26235)

ey General

North Carolina Department of Justice

On behalf of the North Carolina Department

of the Secretary of State

P.O. Box 629

Raleigh, NC 27602-0629

T: ( 9 1 9 ) 7 1 6 - 6 6 1 0

F: ( 9 1 9 ) 7 1 6 - 6 7 5 7

jlindsley.ncdoj.gov

Wake County District Attorney Acknowledgement

The undersigned hereby acknowledges that the foregoing Motion has been reviewed by the

Office of the Wake County District Attorney and that said office does not oppose the Motion.

This
? ) dday of April 2 0 1 7.

umma
Hbardic L-
l " Assistant District Attorney