1 

# RONIN AUTOMATA, LLC

M ay 1st , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, D.C. 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Administrator Huerta,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Ronin Automata, LLC (RONIN), hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of small unma nned aerial system (i.e., sUAS), so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit RONIN to pursue its commercial int erests in providing services to consumers, businesses and agencies interested aerial data capture usi ng a small advanced sUAS for Videography, Photography and Film Production, Conservation and Agriculture Surveying, Rescue/Law Enforcement Support, Research and Development, sUAS Operator Training, and Product

Demonstrations.

For your convenience, the petition is organized as follows:

I. TYPES OF OPERATIONS

II. RELEVANT STATUTORY AUTHORITY

III. QUALIFICATIONS FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT

IV. PROPOSED UAS DESCRIPTIONS

V. PROPOSED OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT

VI. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

VII. DRUG AND ALCOHOL PROGRAM

VIII. PUBLIC INTEREST

IX. PRIVACY

X. CONCLUSION2

I. TYPES OF OPERATIONS

The requested exemption would p ermit RONIN to pursue its commercial interests in providing services to consumers, businesses and agencies interested aerial data capture using a small advanced sUAS in the following areas:

• Videography, Photography and Film Production
• Conservation and Agriculture Surveying • Rescue/Law Enforcement Support • Research and Development • sUAS Operator Training
• Product Demonstrations

II. RELEVANT STATUTORY AUTHORITY

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA

Administrator is to consider whether certain unmanned aircraft systems may operate safely in the

National Airspace ("NAS") before completion of the formal UAS rulemaking, based on the following

considerations:

 The UAS's size, weight, speed, and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within the visual line of sight of the operator.

If the Secretary determines that such vehicles "may operate safely in the National Airspace System, the Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace System". Additionally, the FAA Administrator has general authority to grant exemptions from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. A party requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under 40101 of the Act, from the req uirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service.

The Administrator may grant an exemption from a requirement of a regulation prescri bed under subsection (a) or (b) of this section or any of sections.3

III. QUALIFICATIONS FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT

The proposed operations in this petition for exemption qualify for expedited approval under Section 333
of the Ref orm Act. Each of the statutory criteria and other relevant factors are satisfied.

The proposed operations would permit RONIN the use of small UAS under controlled conditions in airspace that is: (1) predetermined; (2) controlled as to access; and that (3) provides an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same

purpose.

RONIN uses UASs that weigh less than 5 5 pounds including payload. RONIN's UASs will operate in line of sight and during daylight hours and will operate at or below 400 feet AGL

.

Given the small size of the sUAS’s involved and the restricted sterile environment within which they will operate, this exemption falls within the zone of safety and demonstrate an equivalent level of safety, in which Congress desired the FAA to permit commercial UAS operations by exemption pending

c ompletion of formal rulemaking. Also, due to the size of the sUAS’s and the confined area in which the sUAS’s will operate, approval of the application presents no hazard in the NAS.

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significant publi c benefit, the grant of the requested exemptions is also in the public interest.

IV. PROPOSED UAS DESCRIPTIONS

We are petitioning for exemption to enable RONIN to operate a DJI Phantom 3 multi

- rotor equipped

with a gimbaled camer a, a DJI Inspire 1 multi

- rotor equipped with gimbaled camera, a 3DR IRIS+ multi

rotor equipped with a gimbaled camera, a Roboflight RF

- 70 fixed wing s UAS equipped with a fixed position multi

- spectral camera, a RQ

- 11 fixed wing sUAS equipped wi th a multi

- spectral camera , a senseFly eBee, and a Hawkeye Lancaster MK

- III . These sUAS all weigh less than 5 5 lbs, have a built

- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the
operator an d to exclude it from Class B, C and D airspace including a no fly zone feature. Each system also has the failsafe function of the autopilot system, which means when the communication between the Main Controller and the transmitter is lost, the system will automatically trigger a Return to Home procedure and will land safely at a predetermined point

.

V. PROPOSED OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT

The proposed operations in this Petition for Exemption qualify for expedited approval under Section 333
of the Refo rm Act. Each of the statutory criteria and other relevant factors are satisfied.4

A. Approval is Warranted Based on the UASs Size, Weight and Operational Capability

RONIN will employ UASs that have a weight less than 5 5 pounds. Each of the UASs have an in tegrated GPS system to calculate the UASs' position and height and to relay that information via secure connection to the operator. In addition, each contains a failsafe mode if its connection to the remote control is lost. The system permits the vehicle t o return to a predetermined location and land to prevent injury or damage.

B. Approval is Warranted Based on the Operational Restrictions Set Forth by Ronin Automata, LLC

To assist the FAA in its safety assessment of RONIN's proposed sUAS operations, bel ow is a summary of operational limitations and conditions that will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The sUAS wil l weigh less than 5 5 pounds.

2. Flights will be operated within line of sight of the PIC and observer.

3. Maximum total flight time for each operational flight will be limited to the amount of time the

sUAS can be flown and still maintain a reserve battery power of no less than 25%.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Minimum crew for each operation will consist of the sUAS Pilot in Command and a Visual

Observer. Additional crewmembers may consist of a Pilot and a Camera Operator.

6. RONIN will designate a Pilot in Command ("PIC") and Visual Observer for each mission.

7. The sUAS will operate only with permission from the land owner and in a confined “Sterile Area” flight operations area

.

8. Prior to the operations at a particular location, a site inspection will have been conducted. On the day of the mission the management person with operationa l control and the PIC will concur

on dispatching of the mission.

9. A briefing will be conducted in regard to the planned sUAS operations prior to each day's

missions. It will be mandatory that all personnel who will be performing duties within the

boundarie s of the area be present for this briefing.

10. RONIN crew will use the checklist and callouts required in the Operations Manual.

11. All sUAS’s will be maintained in accordance with inspection program specified by the manufacturer’s guidelines.

12. In the event of an accident involving an RONIN sUAS, they will cease operations and report the
accident to the NTSB and AFS

- 80.

13. Pilot in Command and Visual Observer will at all times be able to communicate by voice.5

14. Pilot in Command, Pilot, Camera Operator, Visual Obse rver, and Operational Personnel will have

been trained and tested.

15. All required permissions and permits would be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

16. If the sUAS loses communications signal, the sUAS will have the capability to return to a pre

determined location within the Sterile Area and land.

17. Contingency plans will be in place to safely terminate flight if there is a loss of communicatio n between the pilot and the observer.

18. The sUAS has the capability to abort a flight in case of unpredicted obstacles or emergencies.

19. RONIN will assure no individuals’ privacy is violated.

20. RONIN has a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

21. Flight operations will be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s

MPTOM.

22. At l east 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The plan of activities will include at least the following:

- Dates and times for all flights;

- Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

- Name and phone number of the person responsible for the on

- scene operation o f the UAS;

- Make, model, and serial or N

- Number of UAS to be used;

- Name and certificate number of UAS PICs involved in the aerial filming;

- A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;

- Signature of exemption holder or representative; and

- A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.6

VI. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

A. 14 C.F.R. Part 21, Subpart H and 14 C.F.R. § 91.203(a)(1)

B. 14 C.F.R. Par t 27

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a)

D. 14 C.F.R. § 91.9(b)(2 ) an d 14 C.F.R. § 91.203(a) and (b)

E. 14 C.F.R. § 91.7(a)

F. 14 C.F.R. § 91.103

G. 14 C.F.R. § 91.109(a)

H. 14 C.F.R. § 91.119

I. 14 C.F.R. § 91.121

J. 14 C.F.R. § 91.151(a )

K. 14 C.F.R. § 91.405(a), 91.407 (a)(l), 91.409(a) (1)(2); 91.417(a) and (b)

L. 14 C.F.R. § 61.113 (a)

M. 14 CFR §§ 61.23(a) and (c)

N. 14 CFR §§ 61.101(e)(4) and (5)

O. 14 CFR §§ 61.315(a)

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under§ 40101 of the Act, including UASs, from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the publ ic interest.

Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using a UAS. Listed below are (1) the specific sections of 14 C.F .R. for which exemp tion is sought, and (2) the operating procedures and safeguards that Petitioner has established which will ensure a level of safety better than or equal to the rules from which exemption is sought.

A. 14 C.F.R. Part 21, Subpart H

- Airworthiness Certificat es and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used for the same ap plication. These criteria are met, and therefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA

- 2014

- 0352 at 13

- 14,22. If, however, the FAA

determines that there are some characteristics of the chosen UAS that fail to me et the requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety

The UASs identified in the Operations Manual are safe when taking into account their size, weight, speed, and operational capability. A ll of the UASs weigh less than 5 5 pounds and will be
flown outside controlled airspace. Additionally, the UASs carry neither pilots nor passengers, carry no explosive materials and or flammable liquid fuels, and operate exclusively with in the parameters stated in the Operations Manual.7

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal

c ategory rotorcraft. To the extent the Petitioner's UASs would otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H, supra.

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

Petitioner seeks an exemption from the aircraft marking and identification requirements contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

• 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with

Part 45 o f this chapter.

• 14 C.F.R. § 45.23(b), Marking s of the Aircraft, states: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport, "experimental," or "provisional," as applicable.

• 14 C.F .R. § 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23. In a previous Grant of Exemption, the FAA determined that e xemption from these requirements was warranted provided that the aircraft "have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C if the markings are as large as practicable." FAA Docket No. FAA

- 2014

- 0352.

Equivalent Level of Safety

RONIN will mark all aircraft with their N

- Number in a prominent spot on the fuselage with markings that are as large as practicable.

D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) and (b):

C arrying Civil Aircraft Certification and Registration

Pursuant to 14 C.F.R. § 91.9(b)(2): (b) No person may operate a U.S.

- registered civil aircraft

- (2) For which an Airplane or Rotorcraft Flight Manual is required by§ 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b): (a) Except as provided in§ 91.715, no person may operate a
civil aircraft unless it has within it the following: (1) An appropriate and curre nt airworthiness certificate.8

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a)

ofthis section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

RONIN does not request an exemption from this section but instead notifies the FAA that, in

accorda nce with FAA Office of Chief Counsel's Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept at the control station with the PIC during flight. The Chief Counsel's Office has held that for all UA S operations, this alternate method constitutes full compliance with the regulations.

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable. Accordingly, Petitioner requests that the requirements for Section 91.7 be treated in accordance with the description herein

.

F. 14 C.F.R. § 91.103: Preflight Action

Petitioner seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA

- approve d Flight
Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely conduct the flight, an exemption is requested to the extent that an FAA

- approved Flight manual is required.

Equivalent Level of Safety

An equiv alent level of safety will be provided by following the Aircraft Operations Manual and flight manual provided by the manufacturer. The PIC will take all required preflight actions

including performing all required checklists and reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas

- before initiation of flight. The Operations Manual and manufacturer's flight manual will be kept at the ground station with the operator at all times.

G. 14 C.F.R. § 91.109(a): Flight Instruction

Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction un less that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished through the use of a device that

communicates with the aircraft via radio communications.

Equivalent Level of Safety

Given the size and s peed of the UASs emp loyed by RONIN , an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard the UASs, and all pers ons will be a safe distance away in the event that the UASs experiences any difficulties during flight instruction. Each system also has the failsafe function of the autopilot9

system, which means when the communication between the Main Controller and the transmitter is lost, the system will automatically trigger a Return to Home procedure and will land safely at a prede termined point.

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes

Petitioner requests an exemption from the minimum safe altitude requirements of 14 C.F .R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including
500 feet abov e the surface and away from any person, vessel, vehicle, or structure in non

- congested

areas

. Section 91.119(d) allows for a helicopter to operate at less than those minimum altitudes when it can be operated "without hazard to pe rsons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by

the FAA."

Equivalent Level of Safety

An equivalent level of safety will be achieved given the size, weight, and speed of the UASs, the
lack of flammable fuel

, as well as the location where it is operated. In order to avoid any risk to aircraft, flight operations will be restricted to 400' AGL or below.

I. 14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F .R. § 91.12 I, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required to the extent that the UASs do not have a barometric altimeter, but rather a GPS altitude read out.

Equiva lent Level of Safety

The FAA has stated that an equivalent level of safety can be achieved if the UASs will be operated at 400' AGL or below and within visual line

- of

- sight in addition to GPS based altitude information relayed in real time to the operator. See Grant of Exemption to Astraeus Aerial,

Docket No. F AA

- 2014

- 0352. The chosen UASs meet these requirements, and a zero altitude initiation point will be obtained prior to flight.

J. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Petitioner requests an exemption from 14 C.P.R.§ 91.151(a)'s fuel requirements for flight in VFR
conditions. Section 91.151 states: (a) No person may begin a flight in an airplane under VFR conditions

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

- (1) During the day, to fly after that for at least
30 minutes; or (2) At night, to fly after that fo r at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight operations can be conducted while still maintaining a 30 minute reserve. RONIN proposes that all flights comply with this requirement by mandat ing that the aircraft be safely landed with no less than 25% of battery life remaining.10

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety is provided if the UAS flight is terminated with at least 25% reserve battery power still available. See Grant of Exemption to Astraeus Aerial, Docket No. FAA

- 2014

- 0352. The Operations Manual conforms to this limit, providing an equivalent level of safety.

K. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenan ce Inspections

Petitioner seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ... have discrepancies repaired as pres cribed in part 43 of this chapter"). An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the U AS will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's Manual, as referenced in the Operations
Manual. F lights will not be conducted unless a flight ope rations checklist is performed that includes all of the aircraft's components. The Operations Manual also sets requirements for maintenance log books and record keeping as well as routine and post

- flight maintenance.

L. 14 C.F.R. § 61.113: Private Pilot Privileges And Limitations

Petitioner seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation or hire, and would also require a second class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the PIC will be operating, as well as requiring certifi cations if the private pilot is carrying passengers or cargo for hire. In this case, while the UASs will be operated as part of a commercial operation, it carries neither passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA

- 2014

- 0352, the FAA determined that the unique characteristics of UAS operation outside of controlled airspace did not

warrant the addition cost and restrictions attendant with requiring a the PIC to have a commercial pilot
certificate and class II medical certificate.

T he restrictions RONIN has placed on its UAS operations meet or exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA

- 2014

- 0352. RONIN will operate in a sterile area way from persons and property not involved in the operat ion. It will be flown based on VLOS at 400' AGL or

below. A NOT AM will be issued between 48 and 72 hours before the flight is to occur, and the flight will be coordinated with the applicable FSDO.11

Equivalent Level of Safety

In addition to these flight r estrictions, RONIN will further ensure safe operation by requiring that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators but also in the unique aspects of UAS flight. Pilots will also be required to conduct training flights at RONIN's Research and Development facilities to obtain flight experience with UAS generally and with the specific models used for commercial operations in particular. Petitioner believes that this system will provi de a higher level of competency and proficiency for its pilots.

VII. DRUG AND ALCOHOL PROGRAM

RONIN has policies in place to ensure that no person may act as a PIC, observer, or sensor operator if they are under the influence of alcohol or any drug.

VIII. PUBLIC INTEREST

Granting RONIN an exemption furthers the public interest. National policy set by Congress favors early integration of UAS into the national airspace in controlled, safe working environments such as those propose in this petition. RO NIN's goal is to help facilitate safe integration of sUAS’s into mainstream USA in the following areas:

• Videography, Photography and Film Production • Conservation and Agriculture Surveying • Rescue/Law Enforcement Support • Research and Development

• s UAS Operator Training
• Product Demonstrations

IV. PRIVACY

All flights will be conducted in accordance with any federal, state or local laws regarding privacy.12

X. CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012

- size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line of sight, and national security

- provides more than adequate j ustification for the grant of the requested exemptions to permit RONIN to operate the selected UASs. Granting the requested exemption will benefit the public interest as a whole in many ways.

We respectfully request exemption under Section 333 to enable RONIN to operate safe, low

- risk commercial sUAV operations for the activities stated above . If you have any questions or require any additional information, please do not hesitate to call.

Sincerely,

Barret Ayres President | CEO Ronin Automata, LLC barret@roninautomata.com

16211 N Scottsdale Rd A6A , Suite 235 Scottsdale, AZ 85254

602

- 7 77

- 3176