US v. Mack– the gov.’s argument against easy bail for Allison

Today the prosecution in the US v Allison Mack will make their argument before the judge seeking to prevent Mack being released on bail.

Here is their letter to the court:

The government respectfully submits this letter to set forth the government’s position with respect to bail in anticipation of the defendant Allison Mack’s arraignment on the above-captioned indictment. For the reasons set forth below, the government respectfully submits that Mack poses a risk of danger and risk of flight and should only be released
pursuant to a substantial, heavily secured bond, commensurate with Mack’s financial resources, signed by a number of financially responsible sureties unaffiliated with Nxivm, and subject to additional conditions of release including, among others, home detention with electronic monitoring.


On April 19, 2018, a grand jury sitting in this District returned an indictment
charging Keith Raniere and Allison Mack with sex trafficking, sex trafficking conspiracy and conspiracy to commit forced labor. As described in the complaint filed against Keith Raniere on February 14, 2018 (18-M-132), in which Mack (hereinafter, the “defendant”) is referred to as “CC-1,” the defendant is alleged to have recruited and persuaded young women into joining a secret organization called “DOS” or the “Vow.” DOS is comprised of “masters” who recruit and command groups of “slaves.” The defendant recruited prospective DOS slaves to join DOS by describing it as a women’s empowerment group or sorority. The defendant had women provide her with “collateral,” which consisted of naked photographs, assets, criminal confessions and other damaging information, to prevent the women from leaving the group or disclosing its existence to others. Once they joined, DOS recruits were required to provide additional collateral, which they did, fearing that their original collateral would be released.

As set forth in the complaint, DOS slaves understood that their participation in DOS was a lifetime commitment and that if they disclosed their participation in DOS, left DOS, or failed to complete assignments given to them by their masters, their collateral could be released. DOS masters, including the defendant, benefited financially from recruiting and
maintaining DOS slaves. DOS slaves were often required to perform “acts of care” for their masters and to pay “tribute” to their masters, including by performing labor and other services for which the DOS slaves were not compensated. In addition, the defendant directed some DOS slaves (including Jane Doe 1) to have sex with Keith Raniere, whose participation
in DOS was not disclosed. DOS masters, including the defendant, groomed DOS slaves for sex with Raniere by requiring DOS slaves to adhere to extremely restrictive diets and not remove their pubic hair (in accordance with Raniere’s sexual preferences) and by requiring them to remain celibate and not to masturbate. DOS masters, including the defendant, who
directed their slaves to have sex with Raniere, received financial benefits in the form of continued status and participation in DOS, as well as financial opportunities from Raniere.

DOS masters, including the defendant, also demanded that DOS slaves
participate in “readiness” drills, which required them to respond to their masters any time of day or night, causing DOS slaves to be seriously sleep-deprived. DOS slaves were also branded in their pelvic regions with a cauterizing pen with a symbol that, unbeknownst to them, incorporated Raniere’s initials.

For the reasons set forth below, the government respectfully submits that,
given the serious risk of flight and danger to the community that the defendant poses, the defendant should be released only pursuant to a substantial secured bond signed by several financially responsible U.S.-based sureties who are unaffiliated with Nxivm. In addition, the
Court should order home confinement with electronic monitoring.


I. Legal Standard

Under the Bail Reform Act, 18 U.S.C. § 3141 et seq., federal courts are
empowered to order a defendant’s detention pending trial upon a determination that the defendant is either a danger to the community or a risk of flight. See 18 U.S.C. § 3142(e) (“no condition or combination of conditions would reasonably assure the appearance of the person as required and the safety of any other person and the community”). A finding of risk of flight must be supported by a preponderance of the evidence. See United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chimurenga, 760 F.2d 400, 405 (2d Case 1:18-cr-00204-NGG Document 17 Filed 04/20/18 Page 2 of 5 PageID #: 72 Cir. 1985).

By contrast, detention based on dangerousness must be supported by clear and convincing evidence. 18 U.S.C. § 3142(f).

The Bail Reform Act lists four factors to be considered in the detention
analysis: (1) the nature and circumstances of the crimes charged; (2) the history and characteristics of the defendant; (3) the seriousness of the danger posed by the defendant’s release; and (4) the evidence of the defendant’s guilt. See 18 U.S.C. § 3142(g). The rules governing admissibility of evidence at trial do not apply in a detention hearing. See 18 U.S.C. § 3142(f); Fed. R. Evid. 1101(d)(3). Accordingly, the government may proceed by proffer, United States v. Ferranti, 66 F.3d 540, 541-42 (2d Cir. 1995); see also United States v. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000); United States v. Martir, 782 F.2d 1141, 1145 (2d Cir. 1986).

The concept of “dangerousness” encompasses not only the effect of a
defendant’s release on the safety of identifiable individuals, such as victims and witnesses, but also “‘the danger that the defendant might engage in criminal activity to the detriment of the community.’” United States v. Millan, 4 F.3d 1038, 1048 (2d Cir. 1993) (quoting legislative history). In addition, when a finding of dangerousness is related to violent conduct, it need not be shown that the defendant personally engaged in violence. United States v. Colombo, 777 F.2d 96, 98 (2d Cir. 1985).

II. The Defendant Is a Risk of Flight and a Danger to the Community
A. Nature and Circumstances of the Crimes Charged.

The charges the defendant faces are extremely serious. The defendant is
charged with using force, fraud and coercion to recruit and maintain DOS slaves, and instructing those slaves to engage in sexual acts with Raniere, among other assignments. The defendant aggressively recruited DOS slaves and required those slaves to recruit slaves of their own. As alleged in the complaint charging her co-defendant, the defendant was focused
on recruiting attractive young women who could meet Raniere’s sexual preferences. The government’s evidence includes admissions by the defendant to witnesses reflecting the defendant’s understanding of the true purpose of DOS, including that DOS slaves would be instructed to have sex with Raniere.

The defendant’s slaves were kept seriously sleep-deprived and emaciated to the point where they stopped menstruating. During the ceremonies in which her slaves were branded, the defendant placed her hands on the slaves’ chests and told them to “feel the pain” and to “think of [their] master,” as the slaves cried with pain. The defendant also provided
naked photographs of her slaves to Raniere and was aware of Raniere’s proclivity for having sex with multiple young women.

Reflecting the seriousness of the charged offenses, the sex trafficking count set forth in Count One carries a mandatory minimum sentence of 15 years’ imprisonment and a maximum sentence of life imprisonment. Such a heavy term of incarceration creates a substantial incentive to flee. The Second Circuit has held that the possibility of a severe sentence is an important factor in assessing flight risk. See United States v. Jackson, 823
F.2d 4, 7 (2d Cir. 1987); Martir, 782 F.2d at 1147 (defendants charged with serious offenses whose maximum combined terms created potent incentives to flee); United States v. Cisneros, 328 F.3d 610, 618 (10th Cir. 2003) (defendant was a flight risk because her knowledge of the seriousness of the charges against her gave her a strong incentive to
abscond); United States v. Townsend, 897 F.2d 989, 995 (9th Cir. 1990) (“Facing the much graver penalties possible under the present indictment, the defendants have an even greater incentive to consider flight.”); United States v. Dodge, 846 F. Supp. 181, 184-85 (D. Conn. 1994) (possibility of a “severe sentence” heightens the risk of flight).

B. History and Characteristics of the Defendant
The history and characteristics of the defendant also militate in favor of a
substantial bail package and restrictive pre-trial conditions. Given her status within DOS and her access to DOS slaves’ collateral, the defendant poses a particular threat because of her ability to direct others to carry out activities on her behalf. In light of the number of witnesses who are themselves members of DOS and have provided collateral and vows of
obedience to the defendant and other DOS masters, there is a significant and unique risk of witness intimidation and tampering which must be mitigated. Cf. 18 U.S.C. § 3142(f)(2)(B) (court may also order detention if there is “a serious risk that the [defendant] will . . . attempt to obstruct justice, or . . . to threaten, injure, or intimidate, a prospective witness or juror”).

The government has obtained evidence that after its investigation was reported in the press, high-ranking members of DOS undertook efforts to undermine potential witnesses, including by registering domain names such as [Witness Name], with the intention of publishing damaging information regarding those witnesses.

Although the defendant has in the past year rented an apartment in Brooklyn, her ties to the Eastern District of New York are limited, as her family lives in California. She has also traveled extensively within the past five years and has powerful contacts associated with Nxivm across the United States and abroad. For instance, the son of a former Mexican
president is the head of a Nxivm center in Mexico. When Keith Raniere was apprehended in Mexico, the defendant had been living with him at a luxury villa which cost over $10,000 a week to rent. Other high-ranking members of Nxivm have access to vast financial resources, in the millions of dollars.

In the absence of a substantial bond with extensive conditions, the Court
would not have sufficient means to ensure that the defendant would not commit additional crimes during any period of release or that she would not otherwise violate bail conditions, such as by contacting her former coconspirators or other witnesses who could testify against her.

C. Evidence of the Defendant’s Guilt
Finally, the weight of the evidence against the defendant is strong. The
government’s evidence includes witness testimony that is corroborated by, among other evidence, electronic communications between the defendant and her co-conspirators and other documentary evidence and records. These electronic communications evidence the defendant’s involvement in DOS recruitment, her participation in conducting “readiness” drills and the assignment of tasks and penances, and other efforts aimed at the continued manipulation and coercion of DOS slaves. This factor, too, strongly favors detention in the absence of a significant bail package.


For the reasons set forth above, the government respectfully submits that the defendant should not be released unless and until she posts a substantial secured bond, as well as the signatures of several financially responsible sureties who are not affiliated with Nxivm. Further, any such release should be under the conditions of home confinement with
electronic monitoring, among other restrictions.

Respectfully submitted,
United States Attorney
By: /s/
Moira Kim Penza
Tanya Hajjar
Assistant U.S. Attorneys

cc: William F. McGovern, Esq. (by email)
Sean S. Buckley, Esq. (by email)
Kobre & Kim LLP

About the author

Frank Parlato


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  • Its nothing to do with chloe fanatics

    This is about allowing a person a fair trial.

    She is a human like anyone else and she didn’t start this damn cult. KEITH DID ( meanwhile people forget her but slay this woman Why? Jealousy.)

    • Allison Mack willingly joined the criminal enterprise of her own free will.
      Kristin Kreuk did not and left the cult.

    • No one here is jealous. She’s a demented, starved white woman. Now she definitely cannot get any acting gig nor can she have contact with the general public. Totes jealous!

  • This woman is NOT the wholesome Chloe we all fell in love with on Smallville! She’s responsible for luring women into rape! Stop defending her stop using bible quotes to justify what this monster did. What’s even more disgusting is that she attended comicon events, and on top of that India and Nicki work at places where they’re in contact with young impressionable women!!!

  • I think folks need to realize one thing.

    All humans are capable of making mistakes.

    All humans are capable of falling in with the wrong crowd.

    Allison is no different. I would hate to see her swallowed by so much hate from the public that she feels that suicide is the only solution to move forward. It’s not. There is life beyond this.

    Allow the justice system to do its job and refrain from tossing mud at her. The truth will come out in due time.

    She has a heart. It beats. It hurts. It can be destroyed or supported.

    I’m not saying you like her but there is so much about this case that WE the people do not know.

    In time we will.

    Let him who is without sin throw the first stone.

  • She didn’t deserve to be released on bond. Unfortunately she will just get 12 years max for being white, and female. I don’t feel one ounce of sympathy for her, her victims will need years of therapy for what they endured.

  • I think the prosecutors have enough email and Jane Doe’s that they can convict Raniere without flipping Allison or India. If they needed Allison or India to flip to get Raniere, they would have been arrested before Raniere.

    But the prosecutors are acting like they want to rattle and flip Allison and India.

    I think the prosecutors know that the real next target needs to be the Bronfman sisters. And then Nancy and Lauren Salzman. They all deserve punishment for financial and immigration crimes, and fraud and brainwashing if that is punishable.

    So I’m thinking that the Raniere emails and Jane Doe’s don’t implicate the Bronfnans and Salzman strongly enough (or they would also have been arrested).

    I think the strategy is to get Allison and India to flip on the Bronfman and Salzmans, more than on Raniere.

    • That’s not how it works in the justice system.

      They only time they FLIP people is to FIND someone

      They found KEITH and always take down the kingpin of a group FIRST to prevent ( mass suicide, control etc )

      Then they create a case around that person based on what they have.

      Then they go after ANYONE who can strengthen that case, provide more than what they have so that when it goes to trial they have enough to put him inside for life and at the same time BRING down others.

      They know ALLISON knows a lot so they would probably work out a deal whereby if she tells them what the BRONFMAN sisters were doing, what other people were doing in MEXICO and so on… .she will get a lesser sentence.

      I guarantee you she is not going to do 15 years.

      She will do about 2 inside, or house arrest for like 3 years. That’s it.

      IF even that.

      She is going to throw the entire NXIVM under the bus.

      We will see BIG names come out soon.

  • That’s the fakest smile ever above a cake 🎂 she can’t even really enjoy! She looks terribly thin and her skin looks really bad too here. I can’t believe how insane these ppl all went as women thinking they were saving the world?? It’s just another attack on feminism and it’s true control over stereotyping women like them! If they were these Executive type successful ppl with amazing leadership abilities, not one of them would allow a man to control them and other women? These chicks don’t get it! You don’t involve men if ur a feminist.

    • Such great news she woke up. Her next birthday she can actually enjoy cake.

    • I have a feeling they were ORDERED to smile, and stick their tongues out (in many other pics), by some weird Raniere edict. Look at the dark circles under her eyes, the veins in her arms, and the yellowed skin. Not making excuses, but there it is.

  • The FBI want Allison Mack kept in jail for the protection of others. This is a good thing. Being an ex-member who has been emotionally and legally tortured by these clowns, keeping Mack off the streets to plot with Clare Bronfman and Lauren and Nancy Salzman would be the best news after Raniere’s refusal for bail.

    On another note, it will allow Mack time to decompress from all the brainwashing. She can get some sleep, eat some real food (well kind of, it’s jailhouse meals) and she is away from the constant brainwashing of Bronfman and the Salzman regime of brainwashing.

    Both Salzman’s are masters at manipulation and they most be taken down, along with Clare Bronfman in this House of Cards for everyone to be safe.

      • Because it’s true. The Kristin Kreuk obsessed snowflakes — just like a cult –redefine words they don’t like, including using “recruit” and “Kristin Kreuk” together in a sentence.

      • I already explained why I liked the termed referred better than recruiting. Recruiting typically entails significant knowledge disclosure to people of what they would be getting into. Since NXIVM had everyone sign NDAs which legally prevented them from discussing what they learned within it, there wasn’t anything other than trust in the person and their experience to convince them to give it a shot.

        Of course, I wouldn’t expect you to take off your disingenuous goggles, or for your feeble mind to think in terms of granularity and nuance, so I know it’s difficult for you to see what Kristin Kreuk was “recruiting” for in 2007 was much different than what Allison was recruiting for in 2015.

        • Yes, the world should only use terms Sultanofsix approves of. Just kidding, fascist.

          Does your psychologist sister-in-law (married to your baby brother, only you remain forever a perpetual child living in your mom’s basement) know how much time you spend online obsessing about Kristin Kreuk?

  • About time FRANK you wrote a few posts about NICKI CLYNE. I think everyone has forgotten how long she has been in NXIVM and the role she has played in all of this.

  • I would think A. Mack needs to be kept in custody for her own protection.

    Clare Bronfman has many reasons to see harm come to this woman. Insane jealousy among others.

    (Clare) assisted suicide a possibility if A. Mack is freed?

    • It is a good point actually. Could totally see Clare Bronfman going into a rage and killing someone if she couldn’t get her way.

    • Someone needs to take out that bronfman bitch and Nicki Clyne in one foul swoop and give India back to her mother. Once that is done i think this can be over.

      • what i mean by take out is…. assure that she is arrested ( just in case anyone thought i meant physical harm ) Let’s just be clear here i mean that justice needs to be served. ( Frank there needs to be an edit function on these comments ) lol

    • Great link. That girl isn’t on a diet anymore. Any lip readers here? She’s really mouthing her conversation.

      • That girl is singing Shakira.
        Although, she could be all hippy like that from too much soy.
        Still, agree, I think she is eating.

      • yeah since Keith went in i bet they are all eating burgers, having hot showers and masturbating like crazy to make up for the lack of.

    • What motivates these women to fall on their swords for a perverted freak like Keith Raniere?

      Raniere is nothing more than a two bit polygamist like the Mormon leader Joseph Smith.

      If these women manage to get Raniere off the hook while they go to prison, do you think Raniere will give a tinker’s damn about them?

      While they’re eating prison slop Raniere will be gorging on meals from Hooters served by voluptuous waitresses.

      These women are slaves to their own delusions and madness.
      The strongest chains are the chains we forge for ourselves.

      • unfortunately that is what happens when you drink the kool-aid. Look at all those people who died at the hands of Jim jones and David koresh. They honestly believed he was some second coming of christ. They have been brain washed in a subtle fashion and then hypnotized on a deep level

    • She doesn’t have the skeletal face or toothpick legs of someone living on 800 calories a day.

      So there’s some hope her brain still works well enough to take the deal the Feds will offer for her testimony.

      Since she’s co-conspirator 2 in the Raniere indictment (but curiously missing from the Allison Mack indictment),and there are reports that she was in the same apartment when Allison was arrested, I think either she has already made a deal, or the Feds are trying to rattle her into a deal by arresting the others slowly.

  • She had everything to live for before Keith Raniere. And now she has jail. A sane person does not do what she did.

    • Sane/Insane. You’d be surprised what people will do when they are struggling with mental disease.

      • At some point we must recognize that Allison Mack does not have a firm moral compass.
        While spouting off cliches about feminism and empowering women Pimp Mack was enslaving them through blackmail, fraud, force and deceit.
        Of course Raniere and the Brongfmans and Salzmans are even more culpable.
        But Allison Mack lacked either the brains or backbone to make the right choices.
        And over a long period of time she assisted in enslaving and torturing the very women she claimed to be helping.
        Allison Mack must be either a dolt or a hypocrite.

        Just because she can spout off lines written by clever script writers does not mean that Pimp Mack has true wisdom or compassion for other people.

    • India is humiliated i think by this all. Place yourself in her shoes. But yeah, good shot of her. She is trying to stay of the radar and her mother is trying to help her but she can’t understand. She’s lost and needs someone to put her into therapy.

  • Wow she looks so thin, and unhealthy. I really feel that BEFORE she met Keith she was a genuine sweet soul who was searching for truth in her life beyond acting and that she was just introduced to the wrong crowd by Kristen Kreuk ( who was introduced by Mark Hildreth) and that she latched on to a few things in the self help program that were probably helpful but then….I think she craved more and in doing so… Keith spotted the vunerability in her and leveraged that by starting with some general collateral like her house or assets and once she gave that up it was easy to coerce more out of her and put her in a position where she no longer felt she could escape. From there i think she embraced his mentality and moved from a victim to a perpetrator.

    So sure, I understand people wanting to blame her but let’s back up the story and look at her BEFORE she met Keith as that paints a more realistic picture of WHO she was.

    People think that brainwashing is some impossible feat but it’s not. Brainwashing is subtle and unless you have been part of a religion, a cult or an organization that uses these methods you wouldn’t recognize it. By the time you do… you are too deep.

    It’s like being thrown into a FUNNEL. At the top its wide and it attracts many people in but its only those at the bottom in the small section that see what its really like and by the time you make it there you can’t always climb out. It’s tricky.

    Sad really. At the end of the day KEITH RANIERE is the one that has created this pyramid of deceit and others have lost their entire lives because of it. Including Allison and who she was BEFORE she met him.

    • Before you nominate Allison Mack for Sainthood or a Nobel Peace Prize, let’s face facts.
      If Pimp Mack was searching for the truth all she had to do was go down to the local library and start reading books instead of adopting a bogus, bloviating con artist as a Guru.
      Anyone who watches Keith Raniere’s videos can see in a New York minute that he is a con artist.
      Raniere is a C minus high school student pretending to be a profound philosopher.

      At one point in Pimp Mack’s journey could she not see that Raniere was a charlatan milking gullible people for money and sex?
      Didn’t the astronomical tuition for Raniere’s lectures provide some sort of clue?
      How about the 500 calorie per day diets?
      How about the constant exercise regime?
      Or the insane demand that women n constantly be on call for Raniere?
      Or the requirement that women not even have sex with their boy friends without first getting Raniere’s permission?
      And to top it off the craziness about branding women to put into Raniere’s harem!

      Meanwhile Pimp Mack spouts off that she and NXIVM are empowering women!

      How stupid does Pimp Mack have to be before you recognize that she is either a dolt or a hypocrite or both?

      Too many people confuse Allison Mack and Kristin Kreuk with the characters they played on TV.
      Deep down these women are insecure and narcissistic and frankly quite stupid.

      • Shadowstate. I agree she could have gone and read books or joined a religion. You could apply the same logic to why PERSON A joins a cult, PERSON B becomes a christian. PERSON C becomes a muslim. PERSON D becomes a matyr for isis. Not everyone thinks alike. I don’t confuse her with the roles she played. But the fact is BEFORE keith she was fine, AFTER she is this. That’s the sad story. I don’t relish in another persons demise unless they are KEITH RANIERE the one who started this all. The rest are just deluded like 99% of the world.

      • Relationship Consultant?

        What did Pimp Mack do to maintain relationships in MXIVUM?
        Yell out, “Get down on your knees, Slave and lick the Vanguard’s feet!”
        Or was she a Relationship Consultant by collecting Blackmail to use against people?

        And what did Pimp Mack “Maintain”?
        Did she clean the cauterizing tool after each use?
        Did Pimp Mack clean the stains in Raniere’s “Library” after each use?
        Is collecting Blackmail considered being a Maintenance Supervisor?

        The bank’s loan officer will not be impressed.

        • Relationship manager means sex slave who outranks and recruits and controls other sex slaves in NXIVM speak.

          Like how pleading not guilty means taking personal responsibility in NXIVM speak.

      • Yes and she’ll get a fair trial.

        But if even half of the allegations against Pimp Mack are true, she is a shallow, vain person devoid of all sympathy for the women she was harming.
        Holding them down while they’re being branded like cattle telling them to “Absorb the pain.”

        • I sense a hint of jealousy shadowstate as you keep throwing out the words vain, shallow and devoid of sympathy. The way you speak about her you sound the same. Sounds like you are projecting your own issues on to her.

    • Kristin kreuk has the money and she’s no longer connected to Nxivm. Think she’ll do her former BFF a favor or stay completely silent as all this washes over? I know which one I think. Tom welling and Michael Rosenbaum have hit a few comic cons together the last few weeks. How I would love to be privy to some of their conversations right now, They both had to be offered the Nxivm recruitment speech from jj and Allison at some point in the past and declined.

      • Do you really think anyone should contribute bail money for her? After what Ms. Mack allegedly did she deserves to be in jail until trial to keep the witnesses save. I guess no matter the money he family manages to collect she will stay in. I would be surprised if she got out to be honest.

About the Author

Frank Parlato is an investigative journalist.

His work has been cited in hundreds of news outlets, like The New York Times, The Daily Mail, VICE News, CBS News, Fox News, New York Post, New York Daily News, Oxygen, Rolling Stone, People Magazine, The Sun, The Times of London, CBS Inside Edition, among many others in all five continents.

His work to expose and take down NXIVM is featured in books like “Captive” by Catherine Oxenberg, “Scarred” by Sarah Edmonson, “The Program” by Toni Natalie, and “NXIVM. La Secta Que Sedujo al Poder en México” by Juan Alberto Vasquez.

Parlato has been prominently featured on HBO’s docuseries “The Vow” and was the lead investigator and coordinating producer for Investigation Discovery’s “The Lost Women of NXIVM.” Parlato was also credited in the Starz docuseries "Seduced" for saving 'slave' women from being branded and escaping the sex-slave cult known as DOS.

Additionally, Parlato’s coverage of the group OneTaste, starting in 2018, helped spark an FBI investigation, which led to indictments of two of its leaders in 2023.

Parlato appeared on the Nancy Grace Show, Beyond the Headlines with Gretchen Carlson, Dr. Oz, American Greed, Dateline NBC, and NBC Nightly News with Lester Holt, where Parlato conducted the first-ever interview with Keith Raniere after his arrest. This was ironic, as many credit Parlato as one of the primary architects of his arrest and the cratering of the cult he founded.

Parlato is a consulting producer and appears in TNT's The Heiress and the Sex Cult, which premiered on May 22, 2022. Most recently, he consulted and appeared on Tubi's "Branded and Brainwashed: Inside NXIVM," which aired January, 2023.

IMDb — Frank Parlato

Contact Frank with tips or for help.
Phone / Text: (305) 783-7083