COURT FILE NO.: CR-22-272-00
DATE: 2022-08-10
ONTARIO
SUPERIOR COURT OF JUSTICE
B E T W E E N:
THE ATTORNEY GENERAL OF CANADA, on behalf of THE UNITED STATES OF AMERICA
Mr. R, Jahchan, for the Respondent
Respondent
- and -
SIMRANJIT SINGH
Mr. D. Paradkar, for the Applicant
Applicant
HEARD: August 5, 2022 by Zoom Videoconference
REASONS FOR DECISION
STRIBOPOULOS J.
Introduction
[1] Mr. Singh is in custody under the authority of a provisional arrest warrant obtained following a request by the United States of America, where he faces charges relating to the smuggling of non-residents into the United States.
[2] The United States has advised that it intends to seek Mr. Singh's extradition and will submit the required Record of the Case by the end of this month.
[3] Mr. Singh applies for his release on bail pending the determination of the extradition proceedings against him. Given the charges and the allegations, the parties agree that Mr. Singh bears the burden of justifying his release on bail.
Charges and Allegations
[4] In an Indictment filed with the United States District Court for the Northern District of New York, Mr. Singh faces nine separate charges. One count of “Conspiracy to Commit Alien Smuggling” and eight counts of “Alien Smuggling.” If convicted of these charges, he faces a minimum sentence of 5 years and a maximum sentence of 15 years in prison.
[5] The United States alleges that since March 2020, Mr. Singh has been responsible for smuggling Indian nationals into the United States from Canada. The United States alleges he did so by transporting migrants to Cornwall, where he introduced them to "transporters" he recruited and paid, who, in turn, smuggled them across the St. Lawrence River and into the United States.
[6] Law enforcement officials in the United States have collected evidence implicating Mr. Singh in four separate smuggling incidents involving as many as 13 Indian nationals, including in March 2020, October 2020, March 2021, and, most recently, April 2022.
[7] The United States appears to have a formidable case against Mr. Singh. It includes surveillance by law enforcement officials, communications over Facebook between Mr. Singh and the transporters involved in two of the incidents (which correspond with surreptitious observations made by law enforcement as the smuggling activities unfolded), and witness testimony including that of one of the transporters.
[8] The transporter, who appears to be a cooperating witness, identified Mr. Singh from a photograph and reported he is a "broker" in Canada for smuggling unlawful migrants and that Mr. Singh had paid him $2,000 to $3,000 for each person he smuggled across the river into the United States.
[9] After being apprehended in the United States, an unlawful migrant identified Mr. Singh from a photograph. He reported that his family in India paid Mr. Singh to smuggle him into the United States. During their drive to Cornwall, he claimed Mr. Singh told him he had no reason to worry and boasted that he had smuggled “over 1000” people into the United States.
[10] Another unlawful migrant, arrested during the April 2022 smuggling incident, identified Mr. Singh from a photograph as the person who had organized his smuggling. He reported paying Mr. Singh $35,000 CDN for his services.
[11] In a letter dated July 19, 2022, the United States Attorney for the Northern District of New York wrote, “The investigation into Singh reveals that some aliens have been charged as much as $14,000 Canadian currency to be smuggled into the U.S.”
[12] In summary, at this very preliminary stage in the extradition process, it appears the United States has a strong case against Mr. Singh. The materials filed suggest Mr. Singh has led a scheme to smuggle unlawful migrants into the United States for over two years. And he has persisted in doing so even after the arrest of some of his subordinates in the scheme. Moreover, given the information concerning what he charges the unlawful migrants and what he pays the transporters, Mr. Singh appears to have earned substantial sums of money from this illegal enterprise.
Mr. Singh’s Circumstances
[13] Mr. Singh, who is a citizen of India, is 40 years of age. He does not have a criminal record in Canada, and there is no suggestion that he has such a record in either the United States or India.
[14] Mr. Singh came to Canada in December 2010 with his then-wife and oldest son. His mother and his younger son arrived two months later. After their arrival, the family took up residence in Montreal.
[15] In February 2011, Mr. Singh filed refugee claims for himself and his family, reporting that he feared persecution by the police in India. In November 2014, the Refugee Protection Division rejected the family's refugee claims, concluding that their fears of persecution and torture if returned to India were not credible. In December 2015, the family submitted a pre-removal risk assessment application which was refused in March 2017.
[16] In June 2016, the family applied for permanent residence status on humanitarian and compassionate grounds. However, that application was also refused. A judge of the Federal Court ultimately dismissed their application for judicial review of that decision in November 2017: see Bhatia v. Canada (Minister of Citizenship and Immigration), 2017 FC 1000.
[17] In November 2017, Mr. Singh divorced his first wife.
[18] Mr. Singh, his ex-wife, his two children, and his mother are now all subject to removal orders from Canada. However, their return to India has been delayed because they lack the documents necessary to travel.
[19] In April 2022, Mr. Singh attended a Removal Interview with the Canadian Border Services Agency, during which he applied for travel documents from India. The Indian consulate has not yet issued these. As a result, Mr. Singh does not presently have a passport that would enable him to travel lawfully internationally.
[20] In 2019, Mr. Singh met his current wife while visiting Brampton. They were married in March 2020. Mr. Singh's wife is a Permanent Resident. In July 2020, she sponsored his application for Permanent Residence under the Spousal Sponsorship Program. Unfortunately, the pandemic has delayed the determination of that application, which like his request for Indian travel documents, remains outstanding.
[21] After meeting his wife, Mr. Singh relocated from Montreal to Brampton in January 2020. The couple currently resides in a home they rent in Brampton. They share the house with other renters. The couple has been at the same address for about one year.
[22] In late 2020, Mr. Singh's ex-wife, his two sons, and his mother also relocated to Brampton, where they all reside together in a house they rent. Mr. Singh testified that he pays his ex-wife $350 per month in child support for their two children.
[23] During the hearing, Mr. Singh testified that after obtaining a work permit earlier this year, he worked as a spa manager for about four to five months before his arrest.
[24] Mr. Singh denies owning any property beyond a car that he is financing. However, he acknowledges having two bank accounts, one with the CIBC and the other with the TD. Mr. Singh testified that the CIBC account has a balance of between $16,000 and $17,000, but he could not recall or even estimate the balance of the TD account. Mr. Singh denied having any other bank accounts or investments either in or outside of Canada.
[25] In contrast, in her correspondence of July 19, 2022, the United States Attorney wrote, “one of Singh's bank accounts show large wire transfers and a balance of approximately $160,000.” However, the letter does not provide further details concerning that information; for example, it does not identify the bank or account number.
Release Plan
[26] Mr. Singh testified that he did not put forward his wife as a surety because, like him, she does not have significant assets and only earns a modest income from her employment at Costco. Instead, Mr. Singh proposes his release on bail with his friend, Amrinder Singh, acting as his sole surety.
[27] Amrinder Singh is a Permanent Resident. He does not have a criminal record.
[28] Mr. Singh and Amrinder Singh met about a decade ago when they were both living in Montreal. By 2015, they were living in the same building and regularly spending time together.
[29] After Mr. Singh moved to Brampton in January 2020, the two men stayed in touch and would visit with one another when Mr. Singh was in Montreal or when Amrinder Singh passed through Brampton for work. Amrinder Singh is a truck driver who owns the truck and trailer he operates. He estimates they are worth $90,000 and testified that he owns them outright.
[30] In July 2021, Amrinder Singh moved to Brampton, where he lives with his wife and their nine-month-old child. Amrinder Singh and Mr. Singh have maintained their friendship since both relocated to Brampton, and their families know each other and spend time together.
[31] Amrinder Singh and his wife own their home in Brampton. He testified that the house is worth approximately $1.2 million and subject to an $865,000 mortgage. In his affidavit filed on the application, Amrinder Singh deposed that he is willing to deposit $20,000 cash with the court and pledge a further $50,000 to secure Mr. Singh's release from custody, and that his wife was agreeable to him doing so.
[32] During his evidence, Amrinder Singh further testified that, if it were necessary, he would pledge as much as $300,000 to secure Mr. Singh's release, effectively all the equity in his home. He also confirmed his willingness to have a lien registered against the title to the house for any amount he might be required to pledge.
[33] The plan is for Mr. Singh to reside at Amrinder Singh's home and remain in the residence at all times. The house has four bedrooms and can easily accommodate Mr. Singh, and Amrinder Singh and his family. While Amrinder Singh is away from home at work from 6:00 a.m. to 9:00 p.m., his wife, who stays at home with their child, would supervise Mr. Singh throughout the day. Additionally, a GPS ankle bracelet would further police the home confinement condition.
[34] Finally, when asked if it would be possible for Mr. Singh to accompany him in his truck during his workday, Amrinder Singh maintained that it would be possible if that is what the court required.
Law and Analysis
[35] The Extradition Act, S.C. 1999, c. 18, confers authority on a judge of this court to determine the issue of bail in extradition proceedings: see ss. 2, 18. In doing so, s. 19 of the Act provides that: “Part XVI of the Criminal Code applies, with any modifications that the circumstances require”.
[36] That means the decision whether to release Mr. Singh on bail or to detain him depends on an application of the primary, secondary, and tertiary grounds: Criminal Code, ss. 515(10)(a)-(c).
[37] As noted at the outset, the parties agree that because of the allegations and charges Mr. Singh faces, he bears the burden of justifying his release on bail. That is because the crimes alleged, if committed in Canada, would meet the definition of criminal activities undertaken by a "criminal organization," and the potential penalty would qualify them as a "serious offence:" see Criminal Code, R.S.C., 1985, c. C-46, s. 467.1(1); Immigration and Refugee Protection Act, S.C. 2001, c. 27, s. 117.
[38] It follows that to secure his release on bail, Mr. Singh must establish that his detention is not justified: see Criminal Code, s. 515(6)(a)(ii).
Positions of the Parties
[39] On behalf of Mr. Singh, Mr. Paradkar submits that the release plan more than adequately addresses any primary, secondary, or tertiary grounds concerns the court might otherwise have based on Mr. Singh's circumstances and the allegations.
[40] Mr. Paradkar submits that the court has no reason to doubt that Amrinder Singh will consciously discharge his responsibilities as a surety. His close supervision, coupled with the stringent bail conditions proposed, including the use of a GPS ankle bracelet, will leave no realistic opportunity for Mr. Singh to flee or to commit further offences while on bail.
[41] Finally, although Mr. Paradkar acknowledges that the circumstances engage tertiary ground concerns, he emphasizes that it remains to be determined whether the United States’ case, when ultimately tested, will prove as strong as appears at this very preliminary stage of the process.
[42] On behalf of the United States, Mr. Jahchan submits that Mr. Singh has failed to justify his release under all three criteria that govern bail under s. 515(10). Concerning the primary ground, he emphasizes Mr. Singh's tenuous connection to Canada, his expertise in crossing international boundaries unlawfully, his likely access to unaccounted-for funds, and the length of the sentence he faces if convicted in the United States. All these considerations, argues Mr. Jahchan, provide Mr. Singh with a considerable incentive and the means to abscond.
[43] Further, if Mr. Singh were to flee, argues Mr. Jahchan, there is a real risk he could go into hiding in Canada and continue smuggling unlawful migrants into the United States. And should he choose not to flee, Mr. Jahchan argues that Mr. Singh could continue orchestrating his smuggling activities from his surety's home using a smartphone. After all, he notes, Mr. Singh has not been deterred from engaging in human smuggling by the intervention of law enforcement in the past, and the enterprise appears to be highly lucrative. In other words, significant secondary ground concerns counsel strongly against granting Mr. Singh bail.
[44] Additionally, Mr. Jahchan submits that Mr. Singh has failed to establish that his detention is unnecessary to maintain confidence in the administration of justice. In that regard, he notes that, in the circumstances, virtually all the factors enumerated in s. 515(10)(c) are engaged in this case. He also emphasizes that when modified to the extradition context, as required, s. 515(10)(c)(i) is not concerned with the prosecution's case for conviction but the apparent strength of the case for committal, which entails a much lower standard.
[45] Finally, Mr. Jahchan concedes that Amrinder Singh is well-intentioned. However, he argues that, even when combined with the strictest terms of release, that is not enough to meet the primary, secondary, and tertiary ground concerns that Mr. Singh's release on bail would occasion. Ultimately, given that they are just friends and not close family members, their relationship is not such that the “pull of bail” will ensure Mr. Singh does not abscond or commit further offences if released.
[46] With the parties' positions summarized, these reasons turn to address the issues raised by Mr. Singh's application for release on bail.
Has Mr. Singh established that his detention is unnecessary to ensure his attendance in court?
[47] Detention is justified when necessary to ensure an accused's attendance in court: Criminal Code, s. 515(10)(a). This basis for denying bail takes on added significance in the extradition context.
[48] The cases have repeatedly recognized that because of the need to respect Canada's international treaty obligations, courts must give even more careful consideration to the risk of absconding in the extradition context than they might in domestic criminal proceedings: see United States of America v. Edwards, 2010 BCCA 149, 271 C.C.C. (3d) 471, at para. 18; United States of America v. Mordi, 2010 ONSC 6666, at paras. 4-5; United States of America v. Ugoh, 2011 ONSC 1810, 269 C.C.C. (3d) 380, at para 13; United States of America v. Baratov, 2017 ONSC 2212, at para. 4; United States of America v. Mello-Lima, 2019 ONSC 6457, at para. 2.
[49] Some of the circumstances point away from concluding that Mr. Singh's detention is necessary to ensure he attends court. First, despite his precarious status in Canada, Mr. Singh appears to have dutifully attended scheduled immigration hearings and meetings with immigration officials.
[50] Second, Mr. Singh’s immediate family, including his wife, children, mother, and ex-wife, are all currently in Canada.
[51] Finally, if Mr. Singh were to abscond, he would jeopardize the funds pledged by Amrinder Singh, who appears to be his longstanding friend.
[52] Nevertheless, in all the circumstances, there are undoubtedly significant flight concerns. First, unlike Mr. Singh's immigration matters, for which he would have a considerable incentive to attend as that could only increase his chances of normalizing his status in Canada, his potential extradition to the United States gives him a powerful incentive to flee. After all, the United States appears to have a formidable case against him on charges that, if convicted, will see him incarcerated for a minimum of 5 and up to 15 years.
[53] Second, Mr. Singh's status in Canada is highly tenuous. Mr. Singh, his children, mother, and ex-wife, are all subject to removal orders; their return to India only depends on the Indian consulate issuing them travel documents. Although Mr. Singh retains some hope of remaining in Canada, given his outstanding application for permanent residence under the Spousal Sponsorship Program, the charges he now faces will undoubtedly delay the determination of that application and, if extradited and convicted, foreclose its approval: see Immigration and Refugee Protection Act, s. 36(1)(b).
[54] Third, Mr. Singh does not own property or a business in Canada. He has no real financial ties here beyond his car, which he finances. As a result, for him, taking flight would not involve leaving any valuable property behind. The only significant asset he acknowledges is the balance in a single bank account.
[55] Fourth, based on the materials filed by the United States, there is good reason to believe that Mr. Singh has not disclosed all his assets to the court on this application. For example, he testified that he only has $16,000 to $17,000 in one of his two bank accounts; he could not recall or even offer an estimate concerning the balance in his second account.
[56] In contrast, the United States alleges that “one of Singh's bank accounts show large wire transfers and a balance of approximately $160,000.” If this is the same account for which Mr. Singh could not even estimate the balance, I find it very difficult to believe he might forget having such a substantial sum in it.
[57] Failing to be entirely forthright with the court concerning one's available assets only exacerbates potential flight concerns.
[58] Fifth, based on the allegations made by the United States and the evidence it claims it has against him, there is reason to believe that Mr. Singh has the connections, knowledge, and skills to flee Canada to avoid the risk of his extradition to the United States.
[59] Ultimately, only two factors would seem to weigh in favour of concluding that Mr. Singh would not flee if granted bail. First, Amrinder Singh’s willingness to pledge virtually all the equity in his home to secure his release, and second, the use of a GPS ankle monitor to police the home confinement condition. I will address each of these considerations in turn and explain why neither alleviates the primary ground concerns that are manifest in the circumstances.
[60] Should he flee, Mr. Singh would jeopardize the funds pledged by Amrinder Singh, a longstanding friend. That raises the question of whether Mr. Singh cares enough about Amrinder Singh that he is more likely to attend court as required rather than jeopardize the funds pledged by his friend.
[61] The cases refer to this as the “pull of bail.” The idea that an accused will attend court because they will not want their surety, someone who is “nearest and dearest” to them, to suffer the potential consequences should they abscond: R. v. Uxbridge Justices, ex parte Heward-Mills, [1983] 1 All E.R. 530, at p. 532, quoted with approval in Canada (Attorney General) v. Horvath, 2009 ONCA 732, 248 C.C.C. (3d) 1, at paras. 40-41.
[62] Although I am satisfied that they are friends, given that Mr. Singh has significant reasons to flee, I am less than convinced that their relationship is so important to Mr. Singh that he would prioritize Amrinder Singh's interests over his own. Moreover, because of his tenuous connection to Canada and the likelihood of his extradition to the United States, where he risks a very long prison sentence if convicted, I cannot conclude that Mr. Singh is unlikely to abscond if granted bail. While Amrinder Singh trusts his friend, I do not share his optimism given all the circumstances.
[63] Nor does the potential use of a GPS ankle monitor assuage my concerns that Mr. Singh might abscond. To be sure, electronic monitoring can be an important tool that, in some instances, can tip the balance between detention and release. Although it cannot prevent bail breaches, it can undoubtedly help to deter them by putting the accused and sureties on notice that bail violations, especially those involving home confinement conditions, will be detected, and reported: see R. v. T.L., 2020 ONSC 1885, at para. 22; R. v. Williams, 2020 ONSC 2237, at para. 118; R. v. Doucette, [2016] O.J. No. 852 (S.C.J.), at para. 5.
[64] However, as Justice Trotter rightly noted, "Electronic monitoring is not a primary ground panacea.": R. v. Sotomayor, 2014 ONSC 500, at para. 40; see also R. v. Dang, 2015 ONSC 4254, 21 C.R. (7th) 85, at para. 42. That is because someone determined to flee can remove the ankle bracelet. Although that would trigger a notification to the monitoring centre, who will, in turn, contact the police, this will only serve to notify the authorities that the individual has absconded and not offer any assistance in locating them once they have done so: see Ugoh, at para. 11; U.S. A. v. Pannell, 2005 CanLII 22 (ON CA), [2004] O.J. No 5715 (S.C.J.), at para. 40.
[65] In short, Mr. Singh has failed to establish that his detention is unnecessary to ensure his attendance in court. Accordingly, the court must dismiss Mr. Singh's bail application.
[66] Given that conclusion, the court is not required to decide whether Mr. Singh has discharged his burden of demonstrating his detention is unnecessary based on either the secondary or tertiary grounds. However, given that the parties made submissions concerning each, I will also address them for the sake of completeness.
Has Mr. Singh established that his detention is unnecessary for the protection or safety of the public?
[67] The Criminal Code requires pre-trial detention where it “is necessary for the protection or safety of the public,” having regard to all the circumstances, including any “substantial likelihood” that the accused will, if released from custody, commit a criminal offence or interfere with the administration of justice: s. 515(10)(b).
[68] Under that provision, the “danger or likelihood that an individual will commit a criminal offence does not in itself provide just cause for detention”: R. v. Morales, 1992 CanLII 53 (SCC), [1992] 3 S.C.R. 711, at p. 736. Instead, detention is only warranted where an accused poses a “substantial likelihood” of committing an offence or interfering with the administration of justice and only where this “substantial likelihood” endangers “the protection or safety of the public”: Morales, at p. 737.
[69] A “substantial likelihood” refers “to a probability of certain conduct, not a mere possibility. And the probability must be substantial, in other words, significantly likely”: R. v. Manasseri, 2017 ONCA 226 (in Chambers), at para. 87.
[70] In explaining the secondary ground for detention in Morales, the Supreme Court of Canada acknowledged the impossibility of making exact predictions about an accused's potential for recidivism and future dangerousness: Morales, at pp. 738-39. The law, however, does not require clairvoyance. Instead, based on all the available information, it demands a reasoned assessment of the risk the accused poses if released on bail: Morales, at p. 739.
[71] Mindful of these governing principles, Mr. Singh has succeeded in satisfying me that his detention is unnecessary to ensure the safety of the public.
[72] I have not arrived at that conclusion because human smuggling is not per se a violent crime. Ensuring the integrity of international borders is critically important from a public safety standpoint. While many who migrate unlawfully do so because they are looking for work, a better life, to reunite with family, or have some combination of these motivations, some unlawful migrants will have criminal antecedents or enter for nefarious purposes. As a result, anyone who assists migrants in bypassing regulated points of entry and screening measures for international travelers engages in criminal conduct that poses a significant threat to public safety.
[73] Ultimately, I have concluded that Mr. Singh's detention is not justified on the secondary ground because concerns that, if released on bail, he will continue to engage in human smuggling activities are highly speculative and somewhat unrealistic. I have come to that conclusion for a couple of reasons.
[74] First, assuming, for the sake of my analysis, that Mr. Singh will not abscond, the suggestion that he would be able to continue orchestrating his smuggling activities from the confines of Amrinder Singh's home seems unrealistic and entirely speculative. The evidence suggests that Mr. Singh is the person who interacted with unlawful migrants, collected payment from them, and drove them to Cornwall where transporters would meet them. No doubt, it is possible that Mr. Singh could delegate such essential tasks to someone else. However, detention based on the secondary ground requires a substantial likelihood of reoffending, not the mere possibility.
[75] Second, should Mr. Singh abscond, it also strikes me as entirely speculative to conclude that he would continue to engage in the same human smuggling activities for which the United States seeks his extradition. Although the smuggling of unlawful migrants appears rather lucrative, which could incentivize him to continue engaging in that activity, Mr. Singh now knows he is on the radar of law enforcement in the United States and Canada. Therefore, it would be brazen, in the extreme, for him to continue engaging in human smuggling activities. Far more likely, in my view, is that he would go into hiding in Canada or, more probably, try to make his way to some third country, possibly even returning to India.
[76] Accordingly, I am satisfied that Mr. Singh's detention is unnecessary on the secondary ground.
Has Mr. Singh established that his detention is unnecessary to maintain confidence in the administration of justice?
[77] The Criminal Code provides that the detention of an accused person in custody is justified if it is necessary “to maintain confidence in the administration of justice, having regard to all the circumstances”: s. 515(10)(c). The provision also sets out a non-exhaustive list of factors that the court must consider in making this determination: s. 515(10)(c)(i)-(iv). All four of the enumerated factors are engaged in the circumstances of this case.
[78] First, based on the record, at least as it stands currently, the United States would appear to have a strong case for Mr. Singh's extradition. If it delivers a Record of the Case consistent with what it has disclosed thus far, Mr. Singh's prospects for avoiding his committal for extradition would seem very dim.
[79] In coming to that conclusion, I am mindful of the comparatively lower threshold that governs committal for extradition, which is very different from the proof beyond a reasonable doubt standard applicable in domestic criminal prosecutions: see M.M. v. United States of America, 2015 SCC 62, [2015] 3 S.C.R. 973, at paras. 36-40.
[80] Second, as explained above, Mr. Singh faces gravely serious charges in the United States. In short, the crimes charged undermine the integrity of the border between Canada and the United States and circumvent vital immigration safeguards. For this reason, the alleged offences attract substantial sentences of imprisonment in both countries.
[81] Third, the circumstances surrounding the commission of the alleged offences are most troubling. The United States alleges that Mr. Singh led a protracted and lucrative scheme involving multiple subordinates designed to undermine the integrity of the border between the United States and Canada. Mr. Singh's leadership role in this criminal enterprise is a circumstance that deserves consideration under s. 515(10)(c)(iii): see R. v. St-Cloud, 2015 SCC 27, [2015] 2 S.C.R. 328, at para. 61.
[82] Finally, if convicted, Mr. Singh faces a lengthy term of imprisonment, a minimum of 5 years and a maximum of 15 years in prison.
[83] Of course, in deciding whether detention is necessary to maintain confidence in the administration of justice, s. 515(10)(c) requires a qualitative rather than a quantitative assessment. The provision involves much more than applying a checklist: St-Cloud, at paras. 66-69, 87. The court must consider the four factors “together with any other relevant factors” to determine “whether, in the case before him or her, detention is necessary” to “achieve the purpose of maintaining confidence in the administration of justice”: St-Cloud, at paras. 69, 87.
[84] After considering the enumerated factors as they apply in this case and all the other circumstances, including Mr. Singh's proposed release plan, I am far from satisfied that his detention is unnecessary to maintain confidence in the administration of justice. Ultimately, given all the circumstances, I remain deeply concerned that even reasonable members of the community would lose confidence in the administration of justice, especially in the integrity of our extradition process, if the court were to release Mr. Singh on bail.
Conclusion
[85] For all these reasons, the court dismisses Mr. Singh's application for bail.
“J. Stribopoulos J.”
Released: August 10, 2022