All Represented by John Driscoll v. Islamic Republic of Iran

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ALL PLAINTIFFS REPRESENTED BY JOHN DRISCOLL,

Plaintiffs, v. No. 20-cv-622-ZMF ISLAMIC REPUBLIC OF IRAN,

Defendant.

MEMORANDUM OPINION

From 2006 to 2011, sixty-three terrorist attacks on U.S. military service members and

civilians in Iraq killed forty-six and severely injured twenty-three soldiers. The attack victims,

their estates, and their family members (collectively, “Plaintiffs”) sought compensation for their

injuries from Defendant, the Islamic Republic of Iran, under the terrorism exception to the Foreign

Sovereign Immunities Act (“FSIA”). See 28 U.S.C. § 1605A. This Court previously granted

default judgment as to liability and compensatory damages. See All Pls. Repr’d by John Driscoll

v. Islamic Republic of Iran, No. 20-cv-622, 2023 WL 5932974, at *1 (D.D.C. July 13, 2023); see

also All Pls. Repr’d by John Driscoll v. Islamic Republic of Iran, No. 20-cv-622, 2024 WL

3251223, at *1 (D.D.C. June 30, 2024). It now addresses Plaintiffs’ request for punitive damages.

For the reasons set forth below, the Court will award Plaintiffs punitive damages of $656,372,428.

I. BACKGROUND

The factual and procedural history of this case are set forth in the Court’s June 30, 2024

opinion. See Driscoll, 2024 WL 3251223, at *1.

1 II. DISCUSSION

A. Basis for Punitive Damages

The terrorism exception to the FSIA authorizes recovery for “economic damages, solatium,

pain and suffering, and punitive damages.” 28 U.S.C. § 1605A(c).1 “Punitive damages are not

compensation for injury. Instead, they are private fines levied . . . to punish reprehensible conduct

and to deter its future occurrence.” Int’l Broth. of Elec. Workers v. Foust, 442 U.S. 42, 48 (1979)

(emphasis added) (internal quotation marks omitted). While “it is axiomatic that punitive damages

are ‘not favored,’” Brown v. Coates, 253 F.2d 36, 39 (D.C. Cir. 1958), they “are allowed because

the civil law has long recognized that in certain situations deterrence can better be achieved

through modification of the civil awards than through a requirement of criminal sanctions.” Davis

v. Schuchat, 510 F.2d 731, 738 (D.C. Cir. 1975).

“[P]unitive damages are never awarded as of right, no matter how egregious the

defendant’s conduct . . . . Rather, they are awarded or rejected in a particular case at the discretion

of the fact finder.” Berger v. Iron Workers Reinf’d Rodmen, Loc. 201, 170 F.3d 1111, 1139 (D.C.

Cir. 1999) (internal quotation marks omitted). Four factors bear on the assessment of punitive

damages in FSIA cases: “(1) the character of the defendants’ act, (2) the nature and extent of harm

to the plaintiffs that the defendants caused or intended to cause, (3) the need for deterrence, and

(4) the wealth of the defendants.” Selig v. Islamic Republic of Iran, 573 F. Supp. 3d 40, 75 (D.D.C.

2021) (quoting Est. of Steinberg v. Islamic Republic of Iran, No. 17-cv-1910, 2019 WL 6117722,

at *9 (D.D.C. Nov. 18, 2019)).

1 Under the 2018 amendment to the FSIA, punitive damages are available under the FSIA even for attacks which preceded the amendment. See Opati v. Republic of Sudan, 590 U.S. 418, 427 (2020). 2 Punitive damages are permissible here. Cf. Neiberger v. Islamic Republic of Iran, No. 16-

cv-2193, 2022 WL 17370239, at *18 (D.D.C. Sept. 8, 2022). First, Iran provided “critical” support

to terrorist groups, permitting the attacks at issue to occur. All Pls. Repr’d by John Driscoll v.

Islamic Republic of Iran, No. 20-cv-622, 2023 WL 4892710, at *11 (D.D.C. June 27, 2023)

(quoting Fritz v. Islamic Republic of Iran, 320 F. Supp. 3d 48, 62 (D.D.C. 2018)). Second, these

“heinous” acts “were intended to—and did—cause unconscionable pain and suffering.” Selig, 573

F. Supp. 3d at 75. Third, “[t]here is a need for deterrence because, time and again, courts in this

district have been confronted with families shattered by Iran-backed terrorists.” Id. And fourth,

“Iran is a sovereign and has substantial wealth.” Bluth v. Islamic Republic of Iran, 203 F. Supp.

3d 1, 25 (D.D.C. 2016).

B. Multiplier for Punitive Damages

A judge has “discretion to tailor a punitive award appropriate to the magnitude of the

underlying injury.” Abedini v. Gov’t of Islamic Republic of Iran, 422 F. Supp. 3d 118, 142 (D.D.C.

2019); see also Berger, 170 F.3d at 1139 (punitive damages are at “discretion of the fact finder”)

(internal quotation marks omitted). Judges on this court have assessed punitive damages in FSIA

cases in very different ways. See Selig, 573 F. Supp. 3d at 75–77 (describing four approaches).

Some have awarded a multiple of the foreign state’s annual expenditures on terrorism. See Braun

v. Islamic Republic of Iran, 228 F. Supp. 3d 64, 87 (D.D.C. 2017) (citing cases). Others have

awarded $150 million to each affected family. See, e.g., Est. of Steinberg v. Islamic Republic of

Iran, No. 17-cv-1910, 2019 WL 6117722, at *10 (D.D.C. Nov. 18, 2019); Est. of Hirshfeld v.

Islamic Republic of Iran, 330 F. Supp. 3d 107, 150 (D.D.C. 2018); Gates v. Syrian Arab Republic,

580 F. Supp. 2d 53, 75 (D.D.C. 2008). Still others have multiplied the amount of compensatory

3 damages by a factor of one to five. See, e.g., Fritz v. Islamic Republic of Iran, 324 F. Supp. 3d 54,

65 (D.D.C. 2018); Taitt v. Islamic Republic of Iran, 664 F. Supp. 3d 63, 113–14 (D.D.C. 2023).

The current prevailing trend is to make punitive damages equal to compensatory damages.

See M.M. v. Islamic Republic of Iran, 708 F. Supp. 3d 22, 52 (D.D.C. 2023); Pennington v. Islamic

Republic of Iran, No. 19-cv-796, 2022 WL 168261, at *6 (D.D.C. Jan. 19, 2022); Neiberger, 2022

WL 17370239, at *19; Selig, 573 F. Supp. 3d at 77; Doe A-1 v. Demo. People’s Republic of Korea,

No. 18-cv-252, 2021 WL 723257, at *10 (D.D.C. Feb. 24, 2021); Christie v. Islamic Republic of

Iran, No. 19-cv-1289, 2020 WL 3606273, at *28–29 (D.D.C. July 2, 2020); Abedini, 422 F. Supp.

3d at 142. This trend is likely due to the courts’ recognition that “Iran already faces billions in

punitive damages awards,” such that “[a]dding hundreds of millions of dollars to the outstanding

judgments against Iran is unlikely to have a meaningful deterrent effect.” Selig, 573 F. Supp. 3d at

77 (internal quotation marks omitted). Specifically, as of “2009, Iran had 10 billion

in . . . outstanding court judgments in FSIA cases,” a value that has “ballooned over the last

decade.” Christie, 2020 WL 3606273, at *29 (internal quotation marks omitted). “The purpose of

punishment . . . [including] punitive damages, is not to inflict suffering or to impose a loss on the

offender. Its object is to act as a deterrent.” Collins v. Brown, 268 F. Supp. 198, 201 (D.D.C. 1967).

And there is a “lack of any evidence that high awards have successfully deterred” Iran. Bluth, 203

F. Supp. 3d at 26. Additionally, “large awards of punitive damages in cases like this one

may . . . serve only to expose the political branches to an unprecedented burden in their

management of United States foreign policy towards Iran.” Christie, 2020 WL 3606273, at *29

(internal quotation marks and brackets omitted).

4 Plaintiffs request treble damages2 pursuant to Taitt v. Islamic Republic of Iran, 664 F. Supp.

3d 63, 113 (D.D.C. 2023). See Mot., Pls.’ Mem. Law Supp. FSIA Damages Awards (“Pls.’ Mem.”)

10–11, ECF No. 45-1. That court reasoned that a “multiplier of three is the usual practice in state

sponsored terrorism cases.” 664 F. Supp. 3d at 113 (internal quotation marks omitted) (quoting

Roth v. Syrian Arab Republic, No. 14-cv-1946, 2018 WL 4680270, at *17 (D.D.C. Sept. 28,

2018)).3

But Taitt does not reckon with the recent trend of only awarding a single multiplier. Single

multipliers and below are in line with the Supreme Court’s warning against excessive punitive

damages awards. See State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408, 425 (2003); see

also Exxon Ship’g Co. v. Baker, 554 U.S. 471, 499 (2008). “When compensatory damages are

substantial, then a lesser ratio, perhaps only equal to compensatory damages, can reach the

outermost limit” of acceptable punitive damages awards. State Farm, 538 U.S. at 425. This

limitation is persuasive. Although “much of this precedent ‘is rooted in the Due Process Clause,

and foreign states and their agents are not persons protected by the Fifth Amendment’s Due

Process Clause’ . . . . due process principles are still ‘instructive, insofar as they embody general

concerns for fairness and consistency.’” Selig, 573 F. Supp. 3d at 77 (first quoting Christie, 2020

WL 3606273, at *27; then quoting Flanagan v. Islamic Republic of Iran, 87 F. Supp. 3d 93, 126

n.37 (D.D.C. 2015)).

2 Plaintiffs sought $4,017,367,104, three times the compensatory damages sought. See Pls.’ Mem., Ex. G, Itemization Chart 14, ECF No. 45-8. The Court granted $1,019,872,428 in compensatory damages. See Driscoll, 2024 WL 3251223, at *1. Treble this figure is $3,059,617,284. 3 Taitt largely relied upon Roth, 2018 WL 4680270. At the time that Roth was decided, the multiplier used by courts “ranged between three and, in exceptional cases, five.” 2018 WL 4680270, at *17. 5 C. Claims of Injured or Deceased Servicemembers

The Court awarded Plaintiffs $1,019,872,428 in compensatory damages. See Driscoll,

2024 WL 3251223, at *1. For context, this judgment is among the largest judgments awarded for

FSIA terrorism cases. Compare Barry v. Islamic Republic of Iran, 437 F. Supp. 3d 15, 62 (D.D.C.

2020) (approximately $1.5 billion in compensatory damages), and Maxwell v. Islamic Republic of

Iran, No. 22-cv-173, 2024 WL 1342775, at *25 (D.D.C. Mar. 29, 2024) (approximately $1.1

billion in compensatory damages), with, e.g., Ben-Yishai v. Syrian Arab Republic, 642 F. Supp. 3d

110, 135 (D.D.C. 2022) (approximately $28 million in compensatory damages), and Selig, 573 F.

Supp. 3d at 77 (approximately $68 million in compensatory damages), and Christie, 2020 WL

3606273, at *27 ($132 million in compensatory damages). Of the compensatory damages, the

Court awarded $292,872,428 to injured and deceased servicemembers. See Driscoll, 2024 WL

3251223, at *14. For the reasons above, the Court will grant punitive damages equal to

compensatory damages to the 23 injured servicemembers and the 46 estates of deceased

servicemembers. See, e.g., Neiberger, 2022 WL 17370239, at *19.

D. Solatium Claims of Family Members

A lower ratio between punitive and compensatory damages is warranted for family member

plaintiffs’ solatium claims for two reasons.

First, “[r]ecurrent awards in case after case arising out of the same facts can . . . over-

punish[] the same conduct through repeated awards with little additional deterrent effect.”

Maxwell, 2024 WL 1342775, at *24 (quoting Murphy v. Islamic Republic of Iran, 740 F. Supp. 2d

51, 81 (D.D.C. 2010)). “The concern about over-punishing and questionable deterrent effect is

present here seeing as” each solatium claim stems from an attack for which the Court has already

punished Iran by awarding punitive damages to the injured or deceased servicemember. Id. For

6 example, this Court previously granted plaintiff Beem—a wounded servicemember—$9,768,536

in compensatory damages for the October 11, 2006 attack. See Driscoll, 2024 WL 3251223, at

*14. Today, it grants plaintiff Beem another $9,768,536 in punitive damages to punish Iran for

that attack. The Court also previously granted plaintiff Beem’s spouse, two parents, three

daughters, and two siblings between $1.25 and $4 million each in compensatory damages for their

emotional injuries caused by the same attack. See id. Not to mention, other plaintiff

servicemembers also recovered compensatory and punitive damages for this very same attack. See

id. The millions in punitive damages awarded for this single attack already punishes and deters

Iran—insofar as any damages award is capable of—as to that attack. See Selig, 573 F. Supp. 3d at

77.

The “question [of recurrent punitive damages] becomes doubly complicated when trying

to assess the proper award of punitive damages in a case subsequent to others that already imposed

punitive damages for the same incident.” Maxwell, 2024 WL 1342775, at *24 (quoting Ewan v.

Islamic Republic of Iran, 466 F. Supp. 3d 236, 251 (D.D.C. 2020)). Such is the case here. This

Court previously granted punitive damages for the May 8, 2007 and March 29, 2008 attacks in

another case. See Neiberger, 2022 WL 17370239, at *19; Second Am. Compl. (“Compl.”) ¶¶ 431–

48, 697–706, ECF No. 2. Similarly, another court granted punitive damages for the April 12, 2006,

May 5, 2006, January 22, 2007, July 6, 2007, July 31, 2007, August 4, 2008, and April 22, 2011

attacks. See Stearns v. Islamic Republic of Iran, 633 F. Supp. 3d 284, 353 (D.D.C. 2022) (assessing

liability and later4 awarding compensatory damages for twelve of the same attacks in this case and

4 See also Stearns v. Islamic Republic of Iran, No. 17-cv-131, 2023 WL 4999215, at *4 (D.D.C. Aug. 4, 2023) (granting punitive damages for January 22, 2007 attack); Stearns v. Islamic Republic of Iran, No. 17-cv-131, 2023 WL 4999967, at *5 (D.D.C. Aug. 4, 2023) (granting punitive damages for May 5, 2006 and April 22, 2011 attacks); Stearns v. Islamic Republic of Iran, No. 17- cv-131, 2024 WL 1886619, at *4 (D.D.C. Apr. 30, 2024) (granting punitive damages for May 5, 7 punitive damages for seven); Compl. ¶¶ 154–68, 193–200, 362–84, 567–81, 602–10, 756–79, 835–

47. The Court is thus “cautious of imposing further punitive damages when they have previously

been awarded not just by this Court, but also by others in this District.” Ewan, 466 F. Supp. 3d at

251–52.

Plaintiffs offer no analysis as to why additional punishment will finally tip the scales in

changing Iran’s behavior. See generally Pls.’ Mem. “[H]aving observed [Iran’s behavior], the

court would be surprised if [Iran] make[s] any meaningful payment of the compensatory damages

award. The court finds that the fixing of a large amount of punitive damages is a useless act.” In

re Rood, 459 B.R. 581, 609 (Bankr. D. Md. 2011) (awarding punitive damages of $1 because

defendants will not likely pay anyhow); Cf. Lee v. Edwards, 101 F.3d 805, 813 (2d Cir. 1996)

(recognizing that punitive damages seek to deter and that deterrence is “directly related” to whether

the defendant is able to pay).

Second, when “compensatory damages include an amount for emotional distress . . . there

is no clear line of demarcation between punishment and compensation.” Restatement (Second) of

Torts § 908 cmt. c (Am. L. Inst. 1979). Thus, courts must be circumspect with punitive damages

awards for emotional distress claims because the compensatory damages awarded already

“includes elements of” punishment. Id.; see State Farm, 538 U.S. at 426, 429. “Under the FSIA, a

solatium claim is indistinguishable from an [intentional infliction of emotional distress] claim.”

Valore v. Islamic Republic of Iran, 700 F. Supp. 2d 52, 85 (D.D.C. 2010) (citing Est. of Heiser v.

2006 and July 31, 2007 attacks); Stearns v. Islamic Republic of Iran, No. 17-cv-131, 2024 WL 1886633, at *5 (D.D.C. Apr. 30, 2024) (granting punitive damages for August 4, 2008 attack); Stearns v. Islamic Republic of Iran, No. 17-cv-131, 2024 WL 1885520 at *4 (D.D.C. Apr. 30, 2024) (granting punitive damages for July 6, 2007 attack); Stearns v. Islamic Republic of Iran, No. 17-cv-131, 2024 WL 1886641, at *4 (D.D.C. Apr. 30, 2024) (granting punitive damages for April 12, 2006 attack). 8 Islamic Republic of Iran, 659 F. Supp. 2d 20, 27 n.4 (D.D.C. 2009)). Thus, compensatory damages

awarded for solatium claims are “based on a component which [would be] duplicated in the

punitive award.” State Farm, 538 U.S. at 426.

“[I]n light of the substantial compensatory damages awarded (a portion of which contained

a punitive element) . . . a punitive damages award at or near the amount of compensatory damages”

is the most that is appropriate here. State Farm, 538 U.S. at 429; see Payne v. Jones, 711 F.3d 85,

102–03 (2d Cir. 2013) (noting that when a compensatory damage award is large, even a “single

digit ratio” can lead to overly large punitive awards). The Supreme Court has noted that the median

ratio between punitive and compensatory damages awarded is around 0.65:1, “meaning that the

compensatory award exceeds the punitive award in most cases.” Exxon Shipping, 554 U.S. at 498

n.14, 512–13. Courts in this jurisdiction have applied ratios as low as 0.03699:1 in FSIA matters

involving Iranian conduct. See Maxwell, 2024 WL 1342775, at *25. Given all of this, the Court

adopts a ratio “less than 1:1, which ‘is easily permissible’” under the Supreme Court’s guidance.

Curry v. Revo. Lab’ys, LLC, No. 17-cv-2283, 2023 WL 5509337, at *17 (N.D. Ill. Aug. 25, 2023)

(quoting Kapelanski v. Johnson, 390 F.3d 525, 534 (7th Cir. 2004)); see SE Prop. Holdings, LLC

v. Judkins, 822 F. App’x 929, 937 (11th Cir. 2020) (holding ratio “less than 1:1” complied with

Supreme Court guidance on punitive damages). Specifically, the Court awards family members

punitive damages at a ratio of 0.5:1 of their compensatory damages, totaling $363,500,000.

9 III. CONCLUSION

For the foregoing reasons, the Court GRANTS Plaintiffs punitive damages totaling

$656,372,428 as set forth in the table below.

Zia M. Digitally signed by Zia M. Faruqui Date: September 13, 2024 Faruqui Date: 2024.09.13 14:44:56 -04'00' ___________________________________ ZIA M. FARUQUI UNITED STATES MAGISTRATE JUDGE

10 Compensatory Punitive Damages Last Name or Estate First Name Relationship Damages Total Award Previously Granted Granted

Estate of James Adair Estate $1,014,478 $1,014,478 $2,028,956 Adair Chelsea Spouse $8,000,000 $4,000,000 $12,000,000 Ahearn Constance Parent $0 $0 $0 Ahearn Kevin Sibling $0 $0 $0 Altman Jake Self $7,111,612 $7,111,612 $14,223,224 Altman Nadja Spouse $4,000,000 $2,000,000 $6,000,000 Altman J. Son $0 $0 $0 Prosser Gloria Parent $2,500,000 $1,250,000 $3,750,000 Altman Charles Sibling $1,250,000 $625,000 $1,875,000 Altman Michael Sibling $1,250,000 $625,000 $1,875,000 Estate of Michael Anaya Estate $1,389,580 $1,389,580 $2,779,160 Anaya Cheryl Parent $5,000,000 $2,500,000 $7,500,000 Moffett Trista Sibling $2,500,000 $1,250,000 $3,750,000 Anaya, Jr. Carmelo Sibling $2,500,000 $1,250,000 $3,750,000 Anderson Bryan Self $11,620,810 $11,620,810 $23,241,620 Waswo Janet Parent $0 $0 $0 Waswo James Step-parent $0 $0 $0 Anderson Robert Sibling $1,250,000 $625,000 $1,875,000 Waswo Briana Sibling $1,250,000 $625,000 $1,875,000 Beem Brian Self $9,768,536 $9,768,536 $19,537,072 Beem Elizabeth Spouse $4,000,000 $2,000,000 $6,000,000 Beem Diane Parent $2,500,000 $1,250,000 $3,750,000 Beem Joseph Parent $2,500,000 $1,250,000 $3,750,000 Beem Cassandra Daughter $2,500,000 $1,250,000 $3,750,000 Beem Kaitlyn Daughter $2,500,000 $1,250,000 $3,750,000 Beem Kelly Daughter $2,500,000 $1,250,000 $3,750,000 Colon Cynthia Sibling $1,250,000 $625,000 $1,875,000 Beem, Jr. Joseph Sibling $1,250,000 $625,000 $1,875,000 Estate of Durrell Bennett Estate $406,817 $406,817 $813,634 Bennett Doris Parent $2,000,000 $1,000,000 $3,000,000 Voncile Bennett Dempsey Parent $2,000,000 $1,000,000 $3,000,000 Lee Bennett Darnell Sibling $1,000,000 $500,000 $1,500,000 Travon Estate of Nathan Beyers Estate $1,415,566 $1,415,566 $2,831,132 Beyers Vanessa Spouse $8,000,000 $4,000,000 $12,000,000 Beyers E. Daughter $5,000,000 $2,500,000 $7,500,000 Beyers Tim Parent $5,000,000 $2,500,000 $7,500,000 Beyers Sonja Step-parent $5,000,000 $2,500,000 $7,500,000 Beyers Tyler Sibling $2,500,000 $1,250,000 $3,750,000 Blickenstaff John Self $9,987,571 $9,987,571 $19,975,142 Blickenstaff Misty Spouse $4,000,000 $2,000,000 $6,000,000

11 Blickenstaff M. Daughter $2,500,000 $1,250,000 $3,750,000 Blickenstaff C. Daughter $0 $0 $0 Jones Pamela Parent $2,500,000 $1,250,000 $3,750,000 Blickenstaff Blickenstaff Jared Sibling $1,250,000 $625,000 $1,875,000 Blickenstaff Adrianne Sibling $1,250,000 $625,000 $1,875,000 Carter Trista Sibling $1,250,000 $625,000 $1,875,000 Botts John A. Self $9,162,430 $9,162,430 $18,324,860 Botts Jennifer Spouse $4,000,000 $2,000,000 $6,000,000 Botts Dara Parent $2,500,000 $1,250,000 $3,750,000 Botts John S. Parent $2,500,000 $1,250,000 $3,750,000 Cunningham Elizabeth Sibling $1,250,000 $625,000 $1,875,000 Donaldson Peggy Parent $5,000,000 $2,500,000 $7,500,000 Butler Eldridge Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Adrian Butler Estate $477,218 $477,218 $954,436 Byers Brandon Self $9,115,026 $9,115,026 $18,230,052 Byers Megan Spouse $4,000,000 $2,000,000 $6,000,000 Byers Cameron Daughter $2,500,000 $1,250,000 $3,750,000 Estate of Jonathan Cadavero Estate $1,208,726 $1,208,726 $2,417,452 Cadavero Nadia Parent $5,000,000 $2,500,000 $7,500,000 Dearing Michelle Spouse $0 $0 $0 Cadavero David Parent $5,000,000 $2,500,000 $7,500,000 Markarian Kristia Sibling $2,500,000 $1,250,000 $3,750,000 Ponce Mirtha Spouse $8,000,000 $4,000,000 $12,000,000 Calderon A.R. Son $0 $0 $0 Calderon A.J. Son $0 $0 $0 Ascencio Rosa Parent $5,000,000 $2,500,000 $7,500,000 Milagro Rauda Saul Step-parent $5,000,000 $2,500,000 $7,500,000 Rauda Yeny Sibling $2,500,000 $1,250,000 $3,750,000 Rauda Jasmyn Sibling $2,500,000 $1,250,000 $3,750,000 Rauda Evelyn Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Roland Calderon-Ascencio Estate $344,177 $344,177 $688,354 Cope Joshua Self $13,008,930 $13,008,930 $26,017,860 Owens Erica Spouse $4,000,000 $2,000,000 $6,000,000 (formerly Cope) Cope L. Daughter $0 $0 $0 Cope Linda Parent $2,500,000 $1,250,000 $3,750,000 Cope Philip Parent $2,500,000 $1,250,000 $3,750,000 Cope Jacob Sibling $1,250,000 $625,000 $1,875,000 Cope Jonathan Sibling $1,250,000 $625,000 $1,875,000 Cottrell Sherri Spouse $0 $0 $0 Cottrell E. Son $0 $0 $0 Cottrell James Son $0 $0 $0 Cottrell Brandy Daughter $2,000,000 $1,000,000 $3,000,000 Cottrell Megan Daughter $0 $0 $0 Waters Doeshie Parent $0 $0 $0 Craven Josh Self $6,155,728 $6,155,728 $12,311,456

12 Craven Holly Spouse $4,000,000 $2,000,000 $6,000,000 Estate of Duncan Crookston Estate $8,325,764 $8,325,764 $16,651,528 Crookston Leesha Parent $5,000,000 $2,500,000 $7,500,000 Dahlman Louis Self $9,515,072 $9,515,072 $19,030,144 Stockdale Kay Parent $2,500,000 $1,250,000 $3,750,000 Stockdale Larry Step-parent $0 $0 $0 Dahlman Lucas Sibling $1,250,000 $625,000 $1,875,000 Ahrens Amber K. Sibling $1,250,000 $625,000 $1,875,000 Estate of Sean Diamond Estate $1,477,593 $1,477,593 $2,955,186 Diamond Loramay Spouse $8,000,000 $4,000,000 $12,000,000 Diamond Taylor M. Daughter $5,000,000 $2,500,000 $7,500,000 Diamond Madison J. Daughter $5,000,000 $2,500,000 $7,500,000 Diamond Sean R. Son $5,000,000 $2,500,000 $7,500,000 Diamond A. Daughter $5,000,000 $2,500,000 $7,500,000 Wiley Sally Parent $5,000,000 $2,500,000 $7,500,000 Diamond Wiley James Step-parent $2,000,000 $1,000,000 $3,000,000 "Michael" Diamond Jason Sibling $2,500,000 $1,250,000 $3,750,000 Diamond Michael Sibling $2,500,000 $1,250,000 $3,750,000 Donaldson James Self $10,389,211 $10,389,211 $20,778,422 Edds Barry Parent $5,000,000 $2,500,000 $7,500,000 Edds Julia Parent $5,000,000 $2,500,000 $7,500,000 Edds Joel Sibling $2,500,000 $1,250,000 $3,750,000 Forbes, IV Norman Self $5,474,075 $5,474,075 $10,948,150 Ford Lonnie W. Parent $5,000,000 $2,500,000 $7,500,000 Mattison-Ford Linda Step-parent $500,000 $250,000 $750,000 Matson Jessica Sibling $2,500,000 $1,250,000 $3,750,000 Ford Shawn Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Joshua Ford Estate $516,009 $516,009 $1,032,018 Gage Samantha Spouse $0 $0 $0 Gage Michael Son $0 $0 $0 Gage Randy Parent $5,000,000 $2,500,000 $7,500,000 Gage Tamara Step-parent $0 $0 $0 Rosa Julie Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Joseph Gage Estate $1,787,804 $1,787,804 $3,575,608 Gagne Derek Self $10,447,200 $10,447,200 $20,894,400 Mroczkowski Faye Parent $2,500,000 $1,250,000 $3,750,000 Estate of Shawn Gajdos Estate $262,217 $262,217 $524,434 Richards Brenda Parent $0 $0 $0 Estate of Zachariah Gonzalez Estate $419,080 $419,080 $838,160 Gonzalez Laura Parent $5,000,000 $2,500,000 $7,500,000 Gonzalez Benedict Parent $5,000,000 $2,500,000 $7,500,000 Gonzalez Benedict Sibling $2,500,000 $1,250,000 $3,750,000 Jacob "Jake" Hancock Jerral Self $13,073,680 $13,073,680 $26,147,360 Hancock J. Son $2,500,000 $1,250,000 $3,750,000 Hancock A. Daughter $0 $0 $0

13 Tscherny Stacie Parent $2,500,000 $1,250,000 $3,750,000 Benjamin Dirrick Step-parent $0 $0 $0 Tscherny Savannah Sibling $1,250,000 $625,000 $1,875,000 Hancock Samantha Sibling $1,250,000 $625,000 $1,875,000 Estate of Blake Harris Estate $1,727,706 $1,727,706 $3,455,412 Harris Joanna Spouse $0 $0 $0 Harris J. Son $0 $0 $0 Harris Deborah Parent $5,000,000 $2,500,000 $7,500,000 Henry Gary Parent $5,000,000 $2,500,000 $7,500,000 Estate of Keith Kline Estate $509,817 $509,817 $1,019,634 Kline Betty Parent $5,000,000 $2,500,000 $7,500,000 Kline, Jr. John Sibling $2,500,000 $1,250,000 $3,750,000 Estate of David Knapp Estate $7,858,536 $7,858,536 $15,717,072 Knapp Jeanette Parent $5,000,000 $2,500,000 $7,500,000 Estate of Christopher Kube Estate $967,933 $967,933 $1,935,866 Otte Deborah Parent $5,000,000 $2,500,000 $7,500,000 Kube David Parent $5,000,000 $2,500,000 $7,500,000 Kube Jonathan Sibling $2,500,000 $1,250,000 $3,750,000 Kube Jessica Sibling $2,500,000 $1,250,000 $3,750,000 Kube Jason Sibling $2,500,000 $1,250,000 $3,750,000 Kube Jennifer Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Eric Lill Estate $1,448,778 $1,448,778 $2,897,556 Otero Skye Spouse $0 $0 $0 Lill Mikayla Daughter $0 $0 $0 Lill Cody Jacob Son $0 $0 $0 Lill Anthony Parent $5,000,000 $2,500,000 $7,500,000 Lill Charmaine Parent $5,000,000 $2,500,000 $7,500,000 Jones Kortne Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Luigi Marciante, Jr. Estate $1,327,155 $1,327,155 $2,654,310 Marciante Stephanie Spouse $8,000,000 $4,000,000 $12,000,000 Marciante L. Son $0 $0 $0 Marciante Maria Parent $5,000,000 $2,500,000 $7,500,000 Marciante Luigi Parent $5,000,000 $2,500,000 $7,500,000 Balestrieri Enza Sibling $2,500,000 $1,250,000 $3,750,000 Marciante Martinez Sarah Spouse $4,000,000 $2,000,000 $6,000,000 Martinez Saul Self $12,008,635 $12,008,635 $24,017,270 Mayo John Parent $5,000,000 $2,500,000 $7,500,000 Mayo Rebecca Parent $5,000,000 $2,500,000 $7,500,000 Mayo Andy Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Barry Mayo Estate $917,529 $917,529 $1,835,058 Estate of Justin Mixon Estate $1,269,900 $1,269,900 $2,539,800 Mixon Tia Spouse $0 $0 $0 Mixon T.R. Son $0 $0 $0 Mixon Melinda Parent $5,000,000 $2,500,000 $7,500,000 Mixon Walter Parent $5,000,000 $2,500,000 $7,500,000 Mixon Kenneth Sibling $2,500,000 $1,250,000 $3,750,000 Spillyards Kimberly Sibling $2,500,000 $1,250,000 $3,750,000

14 Estate of Joshua Modgling Estate $831,435 $831,435 $1,662,870 Montano Julie Parent $5,000,000 $2,500,000 $7,500,000 Modgling Keith Parent $5,000,000 $2,500,000 $7,500,000 Modgling Christopher Sibling $2,500,000 $1,250,000 $3,750,000 Stuart Kellilynn Sibling $2,500,000 $1,250,000 $3,750,000 Modgling Michelle Sibling $2,500,000 $1,250,000 $3,750,000 Schaffer Kenneth Sibling $2,500,000 $1,250,000 $3,750,000 Morris Glenn Parent $5,000,000 $2,500,000 $7,500,000 Morris Amy Parent $5,000,000 $2,500,000 $7,500,000 Morris Adam Sibling $0 $0 $0 Morris Cassidy Sibling $0 $0 $0 Estate of Daniel Morris Estate $1,639,172 $1,639,172 $3,278,344 Pearson Kristi Spouse $8,000,000 $4,000,000 $12,000,000 Estate of Andrew Nelson Estate $1,060,341 $1,060,341 $2,120,682 Paupore Maria Spouse $4,000,000 $2,000,000 $6,000,000 Paupore Mailey Daughter $2,500,000 $1,250,000 $3,750,000 Paupore Cody Son $2,500,000 $1,250,000 $3,750,000 Osborne Sharon Parent $2,500,000 $1,250,000 $3,750,000 Paupore Thomas Parent $2,500,000 $1,250,000 $3,750,000 Bueno Leslie Sibling $1,250,000 $625,000 $1,875,000 Paupore Joe Sibling $0 $0 $0 Paupore Nicholas Self $8,017,571 $8,017,571 $16,035,142 Payne Julie Spouse $8,000,000 $4,000,000 $12,000,000 Payne A. Daughter $5,000,000 $2,500,000 $7,500,000 Payne K. Daughter $0 $0 $0 Estate of Cameron Payne Estate $1,218,167 $1,218,167 $2,436,334 Estate of Andrew Pearson Estate $3,899,826 $3,899,826 $7,799,652 Pearson Jon Marie Spouse $8,000,000 $4,000,000 $12,000,000 Perez Daniel Parent $5,000,000 $2,500,000 $7,500,000 Perez Vicki Parent $5,000,000 $2,500,000 $7,500,000 Perez Kevyn Sibling $1,000,000 $500,000 $1,500,000 Estate of Emily Perez Estate $698,763 $698,763 $1,397,526 Estate of Joshua Plocica Estate $385,491 $385,491 $770,982 Thompson Lisa Parent $5,000,000 $2,500,000 $7,500,000 Thompson Lowell Step-parent $5,000,000 $2,500,000 $7,500,000 Keith Corbin Brenna Sibling $2,500,000 $1,250,000 $3,750,000 Coward Mariah Sibling $0 $0 $0 Richard Lois Elaine Parent $5,000,000 $2,500,000 $7,500,000 Richard, Jr. Joseph Parent $5,000,000 $2,500,000 $7,500,000 Billedeaux Carmen Sibling $2,500,000 $1,250,000 $3,750,000 Richard Estate of Mark Rosenberg Estate $4,677,932 $4,677,932 $9,355,864 Rosenberg Julie Spouse $8,000,000 $4,000,000 $12,000,000 Rosenberg J. Son $5,000,000 $2,500,000 $7,500,000 Rosenberg M. Son $5,000,000 $2,500,000 $7,500,000 Rubio Jennifer Spouse $0 $0 $0 Rubio-Hernandez N. Son $0 $0 $0 Moore Kathy Parent $5,000,000 $2,500,000 $7,500,000

15 Moore, Jr. Thomas Step-parent $2,000,000 $1,000,000 $3,000,000 Estate of Ryan Russell Estate $439,155 $439,155 $878,310 Rzepa Jason Self $12,290,536 $12,290,536 $24,581,072 Rzepa Cassandra Spouse $4,000,000 $2,000,000 $6,000,000 Rzepa C. Son $0 $0 $0 Rzepa K. Son $2,500,000 $1,250,000 $3,750,000 Rzepa Ann Parent $2,500,000 $1,250,000 $3,750,000 Shaidell David Sibling $1,250,000 $625,000 $1,875,000 Michael Saaristo Cheryl Ann Spouse $2,500,000 $1,250,000 $3,750,000 Saaristo Leah Marie Daughter $2,500,000 $1,250,000 $3,750,000 Saaristo, Jr. Brian Son $2,500,000 $1,250,000 $3,750,000 Saaristo Shirley Ann Parent $2,500,000 $1,250,000 $3,750,000 Angell Brenda Sibling $1,250,000 $625,000 $1,875,000 Liimatainen Barbara J. Sibling $0 $0 $0 Saaristo Brian Self $11,439,772 $11,439,772 $22,879,544 Schild Kayleen Spouse $8,000,000 $4,000,000 $12,000,000 Schild Koby Son $5,000,000 $2,500,000 $7,500,000 Schild Keely Daughter $5,000,000 $2,500,000 $7,500,000 Schild Bruce Sibling $2,500,000 $1,250,000 $3,750,000 Schild Brooks Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Richard Schild Estate $1,217,260 $1,217,260 $2,434,520 Schumann Jim Parent $0 $0 $0 Schumann Ben Sibling $1,000,000 $500,000 $1,500,000 Anderson Brent Sibling $0 $0 $0 Nelson Kristie Sibling $0 $0 $0 Oppegard Kayla Sibling $1,500,000 $750,000 $2,250,000 Estate of Jason Schumann Estate $1,661,683 $1,661,683 $3,323,366 Traynor Sowinski Diane Parent $5,000,000 $2,500,000 $7,500,000 Sowinski Jared Sibling $2,500,000 $1,250,000 $3,750,000 Sowinski Austin Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Nicholas Sowinski Estate $519,384 $519,384 $1,038,768 Dructor Erin L. Spouse $8,000,000 $4,000,000 $12,000,000 Estate of Blake Stephens Estate $1,611,228 $1,611,228 $3,222,456 Barber Audrey Spouse $8,000,000 $4,000,000 $12,000,000 McGee Callie Sibling $2,500,000 $1,250,000 $3,750,000 Benefield Stephanie Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Brandon Stout Estate $369,060 $369,060 $738,120 Takai Mae Spouse $4,000,000 $2,000,000 $6,000,000 Takai Jonamae Daughter $2,500,000 $1,250,000 $3,750,000 Takai Niana Daughter $2,500,000 $1,250,000 $3,750,000 Takai I. Daughter $0 $0 $0 Takai K. Daughter $0 $0 $0 Cruze Patricia Parent $0 $0 $0 Takai Juan Parent $2,500,000 $1,250,000 $3,750,000 Takai Jolene Sibling $1,250,000 $625,000 $1,875,000 Takai Jermaine Sibling $1,250,000 $625,000 $1,875,000 Takai John Self $8,985,623 $8,985,623 $17,971,246

16 Richard Tammy Parent $5,000,000 $2,500,000 $7,500,000 Richard Glenn Parent $5,000,000 $2,500,000 $7,500,000 Richard Heather Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Brandon Teeters Estate $378,522 $378,522 $757,044 Thorne Karen Parent $5,000,000 $2,500,000 $7,500,000 Thorne Doyle Sibling $0 $0 $0 Robinson Joey Sibling $0 $0 $0 Tollefson Walter Parent $5,000,000 $2,500,000 $7,500,000 Steinman Mary Parent $5,000,000 $2,500,000 $7,500,000 Mecklenburg Jessica Sibling $0 $0 $0 Miller Kathryn Sibling $2,500,000 $1,250,000 $3,750,000 Tollefson Estate of John Tollefson Estate $307,180 $307,180 $614,360 Tong Andrew Self $10,132,754 $10,132,754 $20,265,508 "AJ" Torres Yarissa Spouse $0 $0 $0 Estate of Teodoro Torres Estate $448,996 $448,996 $897,992 Estate of Jose E. Ulloa Estate $1,633,769 $1,633,769 $3,267,538 Atzmann Melanie Spouse $0 $0 $0 Ulloa Steven Son $0 $0 $0 Marmol Francisca Parent $0 $0 $0 Ulloa Jose Parent $0 $0 $0 Ulloa Ruberterna Sibling $0 $0 $0 Marmol Stephanie Sibling $0 $0 $0 Estate of Omar Vazquez Estate $1,037,823 $1,037,823 $2,075,646 Vazquez Maria Parent $5,000,000 $2,500,000 $7,500,000 Vazquez Pablo Parent $5,000,000 $2,500,000 $7,500,000 Vazquez, Jr. Pablo Sibling $2,500,000 $1,250,000 $3,750,000 Vazquez Marisel Sibling $2,500,000 $1,250,000 $3,750,000 Vazquez Javier Sibling $2,500,000 $1,250,000 $3,750,000 Vendela Marianne Parent $2,500,000 $1,250,000 $3,750,000 Vendela Travis Self $11,185,131 $11,185,131 $22,370,262 Wager Michelle Self $9,840,651 $9,840,651 $19,681,302 Wagner Bryan Self $7,898,543 $7,898,543 $15,797,086 Wakeman Margaret Parent $5,000,000 $2,500,000 $7,500,000 Wakeman David A. Parent $5,000,000 $2,500,000 $7,500,000 Wakeman William Sibling $2,500,000 $1,250,000 $3,750,000 Zachary Estate of Dustin Wakeman Estate $503,121 $503,121 $1,006,242 Green Wendy Spouse $8,000,000 $4,000,000 $12,000,000 Weikel J.T. Son $0 $0 $0 Weikel Chad Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Ian Weikel Estate $2,517,909 $2,517,909 $5,035,818 Lantrip Lydia Parent $2,500,000 $1,250,000 $3,750,000 Wells, Jr. Billie Parent $2,500,000 $1,250,000 $3,750,000 Lantrip David Sibling $500,000 $250,000 $750,000 "Blake" Wells Jeremy Sibling $1,250,000 $625,000 $1,875,000 Wells Joshua Self $11,551,377 $11,551,377 $23,102,754

17 Wendling Randall Parent $5,000,000 $2,500,000 $7,500,000 Wendling Carrie Parent $5,000,000 $2,500,000 $7,500,000 Estate of Michael Wendling Estate $432,093 $432,093 $864,186 White Jennifer Spouse $8,000,000 $4,000,000 $12,000,000 Brooks Julia Parent $5,000,000 $2,500,000 $7,500,000 Ramos Marcus Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Lucas T. White Estate $1,391,650 $1,391,650 $2,783,300 Wilcox Charlene Parent $5,000,000 $2,500,000 $7,500,000 Wilcox Bianca Sibling $2,500,000 $1,250,000 $3,750,000 Wilcox Ona Sibling $2,500,000 $1,250,000 $3,750,000 Wilcox, III Charles Sibling $2,500,000 $1,250,000 $3,750,000 Estate of Carlos Wilcox Estate $442,022 $442,022 $884,044 Francis Simona Parent $0 $0 $0 Estate of LeRon Wilson Estate $297,589 $297,589 $595,178 Zapfe Joseph Sibling $0 $0 $0 Zapfe Edward Sibling $500,000 $250,000 $750,000 TOTALS $1,019,872,428 $656,372,428 $1,676,244,856