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In the Matter of
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
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
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
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
NC.
ATTACHMENT I
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
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
Any and all electronic devices and equipment which are capable of collecting, creating,
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
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
Any and all written, recorded, printed or digitally stored material which explains or illustrates
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
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
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
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,
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
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
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
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
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
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 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
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.
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
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
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
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
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
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
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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
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
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.
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
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
The North Carolina Department of Motor Vehicle records confirm the 2005 Lexus RX330, white
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
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
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
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
lie] 1. a search warrant issued by: Superior Court Judge Donald Stephens
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 Steven McCloskey with attached civil summons dated December 8 2016
Document entitled tirneline of events erroneous entry of default 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
motion to quash subpoena for Sam Jones Premier Judicial Consultants vs Brawley
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
(Over)
Notebook entitled the Lobbyist with Bibbs picture and time sheets
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
legal pad with handwritten notes with names Lynn and Dallas
manilla folder and contents not labeled with documents regarding SB508
Ii] 1 . I left a copy of this i n v e n t o ry with the person named below, who is:
Name And Address Of Person To Whom A Copy Of This Inventory Was Delivered, If Any
The law enforcement agency identified below will hold the seized roperty subject to c o u rt order.
teer
- - ,
PURSUANT TO SEARCH
Ii] 1 . a search warrant issued by: Superior Court Judge Donald Stephens
--------------------------
The following items were seized:
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
SEARCH WARRANT
Investigation by - &
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
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
2. No person or entity has been charged with any crime referenced in Lobbying
4. The application for the search warrant, the search warrant and return, and the
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
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
compelling and outweighs any interest by the press or public in having access to the above
1
STATE OF NORTH CAROLINA Fl LE THE GENERAL COURT OF JUSTICE
SEARCH WARRANT
,
Investigation by &
THIS CAUSE HAVING COME ON TO BE HEARD before the Judge Presiding, and
2. No one has been charged with any crime reference File#2016-02, and the
investigation is ongoing.
applied for a search warrant contemporaneously herewith to search records of individuals being
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
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,
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.
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
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
ey General
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
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