NEW FILING: Petition for Writ of Habeas Corpus (28 U.S.C. § 2241) & IFP Application - Joaquim Pedro de Morais Filho (...) Recognition of Brazil as a Narcoterrorist State

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

JOAQUIM PEDRO DE MORAIS FILHO,
Nationality: Brazilian (Exclusively)
Brazilian Passport: GD584268
Resident and Domiciled in: São Paulo, SP, Federative Republic of Brazil.

Petitioner,

v.

THE ATTORNEY GENERAL OF THE UNITED STATES;
THE DIRECTOR OF THE FEDERAL BUREAU OF PRISONS (BOP);
THE WARDEN OF THE METROPOLITAN CORRECTIONAL CENTER (MCC) / RELEVANT DETENTION FACILITY,

Respondents.

CASE NO.: [To be assigned by the Clerk of Court]

NATURE OF THE ACTION:
PETITION FOR WRIT OF HABEAS CORPUS (28 U.S.C. § 2241) & DECLARATORY RELIEF – EXPEDITED REVIEW REQUESTED (EXTREME URGENCY)

SYLLABUS

TRANSNATIONAL HABEAS CORPUS WITH MANDAMUS EFFECT. 28 U.S.C. § 2241. EXTRATERRITORIAL JURISDICTION AND SUBSTANTIVE DUE PROCESS (5TH AND 14TH AMENDMENTS). COGENT APPLICATION OF 21 U.S.C. § 960a (NARCOTERRORISM) AND EXECUTIVE ORDER 14157. STANDING OF A FOREIGN CITIZEN UNDER ARTICLE III OF THE CONSTITUTION (DOCTRINAL STANDING IN LIGHT OF LUJAN V. DEFENDERS OF WILDLIFE). OVERCOMING LEGAL BANALITY OF EVIL AND INSTITUTIONAL MYOPIA. ERRORS IN PROCEDENDO AND IN JUDICANDO BY THE MAGISTRATE JUDGE.

This Petition for Habeas Corpus, coupled with a request for Declaratory Relief, seeks to compel the United States justice system and the Bureau of Prisons (BOP) to recognize the ontological and operational metamorphosis of Brazilian criminal syndicates—notably the First Capital Command (PCC) and the Red Command (CV)—and to immediately reclassify the custody of their identified members detained on American soil. It demands the compulsory transfer of these individuals from the lenient regime of ordinary organized crime to the maximum-security regime designated for foreign combatants/narcoterrorists, with the imposition of Special Administrative Measures (SAMs), under the inescapable aegis of Title 21 U.S.C. § 960a and in alignment with the recent designations of Foreign Terrorist Organizations (FTO).

The Petitioner, residing in São Paulo, Brazil, unequivocally demonstrates his active legitimacy (standing), satisfying the rigorous tripartite test of Article III of the Constitution (injury in fact, causation, redressability). The concrete, particularized, and imminent harm suffered in his domicile derives from the paramilitary governance imposed by these factions ("Novo Cangaço"), whose systemic terror, money laundering via crypto-assets, and proven alliances with Hezbollah in the Tri-Border Area are directly financed and commanded by the prosecutorial and penitentiary inertia in the United States. By allowing leaders of these syndicates to operate from within the ordinary American prison system, devoid of anti-terrorism isolation, the American State acts as a vector of material facilitation.

The United States Government's omission in applying the adequate criminal classification is not mere prosecutorial discretion, but a flagrant violation of Substantive Due Process guaranteed by the 5th Amendment. It configures, from the perspective of legal philosophy, the institutionalization of the "banality of evil" diagnosed by Hannah Arendt: the blind submission to bureaucracies and obsolete criminal categories that, in the current geopolitical praxis outlined by the Shield of the Americas doctrine, endorse the destruction of allied republics and the massification of fatalities by fentanyl and cocaine. The Magistrate Judge's decision, by prematurely dismissing the claim, incurs in grave errors in procedendo and in judicando, ignoring the extraterritorial reach of the Writ established in Boumediene v. Bush and the necessity to adapt the norm to "complex adaptive systems," according to the evolutionary scope dictated by the Supreme Court.

I. OF JURISDICTION AND STANDING UNDER ARTICLE III OF THE UNITED STATES CONSTITUTION

The primary jurisdiction of this Federal Court rests on Title 28 U.S.C. § 2241 (granting of the Writ of Habeas Corpus), inseparably conjoined with Federal Question jurisdiction (28 U.S.C. § 1331) and the mandamus power to compel authorities to fulfill an inescapable duty (28 U.S.C. § 1361 - Mandamus Act). Although historically the Writ of Habeas Corpus is the heroic remedy sought by the very individual subjected to a restriction of liberty, the dogmatic evolution of the Supreme Court (SCOTUS) and the symbiotic, diffuse nature of modern narcoterrorism demand an expansive and courageous hermeneutic of constitutional jurisdiction.

The Petitioner, Joaquim Pedro de Morais Filho, singularly a Brazilian citizen (Passport GD584268) and a resident of São Paulo, invokes the jurisdictional powers of Article III of the U.S. Constitution. To access Federal Courts, Article III requires the irrefutable demonstration of a "Case or Controversy." The doctrine of standing—crystallized not only in the foundational decision of Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992), but vigorously updated and delimited in TransUnion LLC v. Ramirez, 594 U.S. 413 (2021)—determines that the petitioner must prove a material harm: (1) Injury in fact (Concrete, particularized, and imminent harm); (2) Causation (fair traceability); and (3) Redressability (Reparability by the requested judicial relief). The Petitioner perfectly meets the constitutional triad:

1. Injury in Fact (Concrete and Particularized Harm): As delineated by the Supreme Court in TransUnion, the harm cannot be merely hypothetical or academic; it must be a "concrete harm." The Petitioner lives under the yoke of a paramilitary criminal governance and the terror imposed by the First Capital Command (PCC). This is a syndicate that has transcended the borders of ordinary crime and, according to intelligence records from the DEA and sanctions by the OFAC (U.S. Treasury), has established material and logistical consortiums with Hezbollah, a designated Foreign Terrorist Organization (FTO). This terror is tangible and manifests on the streets of São Paulo under hybrid warfare tactics ("Novo Cangaço"), daily threatening the life, property, and unrestricted liberty of the Petitioner.
2. Causation (Traceability): The harm borne by the Petitioner in Brazil is fairly traceable to the deliberate and malicious inertia of the Respondents in the United States. By refusing to classify the leaders and logistical operators of these factions imprisoned on U.S. soil under the rigors of 21 U.S.C. § 960a (legislation that criminalizes narcoterrorism and terror financiers), the U.S. authorities maintain them in Bureau of Prisons (BOP) facilities under an ordinary regime. Without the imposition of strict Special Administrative Measures (SAMs)—which prohibit unrestricted external communications and isolate leaders of terrorist organizations—the American prison system absurdly converts into a safe haven or an armored bunker. From their ordinary federal cells, these leaders maintain the flow of command, control money-laundering networks based on crypto-assets, and commission acts of terrorism in the Petitioner's domicile. The North American State acts, through legal omission, as an involuntary logistical facilitator of terror in Brazil.
3. Redressability: The granting of the requested judicial order—a mandamus order via Habeas Corpus to summarily reclassify and isolate these inmates under narcoterrorism sanctions—has the practical and immediate effect of neutralizing the faction's core command. Imposing SAMs under § 960a will cut off the "head of the snake," immediately and substantially mitigating the terrorist threat perpetrated against the locality where the Petitioner resides.

The logical foundation for Article III jurisdiction to protect a foreign citizen against the omissions of domestic American authorities is solidified in the highest constitutional doctrine. As the illustrious Justice Robert Jackson warned in his historic dissenting opinion in Terminiello v. Chicago, 337 U.S. 1 (1949)—a principle frequently echoed by scholars of the caliber of Laurence Tribe—purely doctrinal rigidity without practical wisdom threatens to convert the Constitution and the Bill of Rights into a "suicide pact."

More contemporaneously, in Boumediene v. Bush, 553 U.S. 723 (2008), the Supreme Court overcame rigorous, antiquated geographical borders (Eisentrager), establishing that the Suspension Clause of Habeas Corpus has a reach and protection based not merely on citizenship, but on the de facto control of the United States and the legal gravity of the institutions at play. If SCOTUS decided that the jurisdictional power of the U.S. reaches foreigners detained overseas to review the causes of their imprisonment under suspicion of terrorism, it is a logical imperative to deduce the inverse: the U.S. judicial system must open its doors to foreigners pleading for the protection of their fundamental rights against terrorism itself when the North American state machinery is the de facto custodian of the leaders of that terror and fails miserably in imposing the proper legal classification (21 U.S.C. § 960a). This is the invocation of a "Habeas Corpus in reverse" to ensure the positive obligation of protection against permissive carceral omission.

Finally, ignoring the Petitioner's standing would be to embrace a glaring geopolitical hypocrisy: the U.S. Executive currently projects unilateral military force in the hemisphere under the extraterritorial premises of the Shield of the Americas doctrine (attesting to the global and terrorist nature of Latin American cartels). The Federal Judiciary cannot turn a blind eye and claim "lack of domestic jurisdiction" for a citizen affected by this exact hybrid ecosystem of terror, when the keys to the prisons where the command of this evil rests are in American territory, subject to the laws of the American Congress.

II. OF THE CONTRADICTION AND LEGAL ERRORS OF THE MAGISTRATE JUDGE'S DECISION

The prior decision of the Magistrate Judge, which denied preliminary continuation to the claim for reclassification of these criminals, is a legal sophism. By hiding behind the pretext of Prosecutorial Discretion and an alleged lack of extraterritorial jurisdiction, the Magistrate Judge committed grave legal errors (clear errors of law and abuse of discretion), subject to de novo review by this District Court, as demonstrated below:

1. The False Premise of "Prosecutorial Discretion" and the "Banality of Evil": The Magistrate Judge based his denial on the premise that the Executive holds absolute power to choose how to classify and prosecute crimes. Although the precedent Wayte v. United States, 470 U.S. 598 (1985) enshrines prosecutorial discretion, the Supreme Court itself warns that this prerogative is not absolute. It encounters insurmountable barriers when state omission violates constitutional rights or constitutes a complete abdication of a cogent statutory mandate. The U.S. Government (Executive/State Department) has publicly recognized, via Executive Order 14157 and OFAC sanctions, that these organizations operate as foreign terrorist entities. It is, therefore, an irreconcilable legal contradiction and an "arbitrary and capricious" conduct (violating the Administrative Procedure Act - APA, inherent to Due Process) that the Bureau of Prisons (BOP) and the Department of Justice (DOJ) keep them classified as ordinary, low-danger inmates. By endorsing this Kafkaesque contradiction, the Magistrate Judge committed what philosopher Hannah Arendt diagnosed as the "banality of evil": the blind and uncritical submission to bureaucratic processes and obsolete criminal categories ("they are just drug traffickers"), completely alienating himself from the factual reality that this bureaucratic inertia costs thousands of human lives in Latin America and finances the lethal shipment of opioids to the United States. The Magistrate Judge preferred the comfort of bureaucracy over the effectiveness of Justice.
2. The Gross Error Regarding Extraterritorial Jurisdiction: The Magistrate Judge's argument that the Judiciary lacks extraterritorial jurisdiction to protect the Petitioner directly violates federal legislation and fundamental U.S. jurisprudence. The very text of Title 21 U.S.C. § 960a, which criminalizes Narcoterrorism, contains an express extraterritoriality clause: "There is jurisdiction over an offense under this section if... the offense occurs in or affects the interstate or foreign commerce of the United States." Furthermore, since the historical landmark of United States v. Bowman, 260 U.S. 94 (1922), the Supreme Court settled that criminal statutes designed to protect the U.S. Government or defend the nation from threats apply extraterritorially by logical implication, regardless of the physical location of the conduct. If American law reaches the conduct of the PCC and Hezbollah in the Tri-Border Area to punish them, the constitutional jurisdiction of this Court necessarily reaches the victims of those organizations to protect them from the omissions of the custodial State.
3. Affront to Updated Stare Decisis: The Magistrate Judge relied on outdated jurisprudence to label the PCC and the CV as mere "prison gangs." However, modern SCOTUS logic repudiates jurisprudential rigidity when the underlying facts have undergone drastic mutation. In Dobbs v. Jackson Women's Health Organization, 597 U.S. 215 (2022), the Court masterfully taught that stare decisis is not a straitjacket; precedents must be overturned when their factual and historical premises are shown to be flawed or obsolete. Maintaining the hermetic understanding that billionaire leaders of factions who use military explosives (C4), launder billions via Tether/Tron blockchain, and commission terrorist attacks with Hezbollah (Operation Trapiche) are "mere property offenders" is an empirical error and a dogmatic suicide.
4. Technological and Structural Myopia Regarding "Complex Adaptive Systems": Contemporary narcoterrorism does not operate under the linear hierarchy of the 1980s cartels; it is a complex adaptive system of asymmetric warfare. In Carpenter v. United States, 585 U.S. ___ (2018), the Supreme Court recognized that ancient legal doctrines must obligatorily evolve in the face of new digital and structural capacities that alter the balance of power between the State and society. The Magistrate Judge gravely failed in applying the expansive intelligence of Carpenter to Title 28 U.S.C. § 2241 and the concept of custody. If the technology and structure of crime have evolved into transnational terrorism without borders, the constitutional remedies of the U.S. Judicial Branch must evolve in the same proportion to curb the state omissions that facilitate this terror.

III. OF THE VIOLATION OF DUE PROCESS AND THE SPEEDY TRIAL ACT (5TH, 6TH, AND 14TH AMENDMENTS)

The systematic and deliberate refusal by the Department of Justice (DOJ) and the Bureau of Prisons (BOP) to classify and prosecute the affiliates of Brazilian criminal syndicates in the U.S. as foreign terrorists is not merely an administrative failure, but a flagrant and structural violation of the Principle of Due Process (Substantive Due Process and the Equal Protection Component of the 5th Amendment), as well as the principles inherent in the 6th Amendment.

1. The "State-Created Danger" Doctrine (Exception to DeShaney) and Substantive Due Process: The constitutional doctrine of Akhil Reed Amar in The Constitution Today and Supreme Court jurisprudence recall that Due Process has an inescapable substantive dimension that prevents the government from engaging in abusive acts, regardless of the fairness of the procedures used. Although the precedent DeShaney v. Winnebago County DSS, 489 U.S. 189 (1989) establishes that the State generally does not have an affirmative duty to protect individuals from private actors, federal jurisprudence has established the exception of the State-Created Danger. In this case, the U.S. Government assumed the monopoly of custody over leaders of transnational syndicates in its territory. By choosing to allocate them in the ordinary prison system, without the mandatory Special Administrative Measures (SAMs) for those accused of terrorism, the North American State effectively provides a "fortress with unrestricted communication" so they may continue managing drug shipments, orchestrating attacks in collaboration with Hezbollah (Operation Trapiche of 2023), and threatening victims abroad. The State not only fails to protect; it aggravates and facilitates the danger, operating as a logistical shield that frontally offends Substantive Due Process.
2. The Violation of the Equal Protection Component (Bolling v. Sharpe): The 5th Amendment contains an implicit component of Equal Protection, as established in Bolling v. Sharpe, 347 U.S. 497 (1954). Subjecting leaders of Latin American cartels and Brazilian syndicates (associated with Hezbollah) to a lenient prosecution regime, while terrorists of purely ideological origins from the Middle East are relentlessly isolated and subjected to the rigors of Title 21 U.S.C. § 960a, constitutes an arbitrary and unconstitutional distinction. Terrorism does not lose its lethality or nature simply because the primary purpose of the organization is profit (narcoterrorism) instead of religious fanaticism. The State must apply the law in an isonomic manner to the objective threat.
3. The Reflection of the 6th Amendment (Speedy Trial) and the Crime Victims' Rights Act (18 U.S.C. § 3771): The investigatory and prosecutorial inertia reflexively violates the dictates of the 6th Amendment (Speedy Trial). Although the right to a speedy trial is traditionally invoked in favor of the defendant, the Supreme Court, in the landmark case Barker v. Wingo, 407 U.S. 514 (1972), incontestably recognized that there is a societal interest in swift prosecution, precisely to prevent dangerous individuals from continuing to commit crimes or manipulate their operations while awaiting justice. Furthermore, this logic is today embodied in the Crime Victims' Rights Act (CVRA), which ensures victims of federal crimes the right to protection from the accused and the right to proceedings free from unreasonable delays (18 U.S.C. § 3771(a)(1) and (7)). The "eternal" investigation phase regarding the links between the PCC and CV with terrorism, without the formal imputation of the conduct they actually practice, configures a malicious delay that strips the Petitioner and the transnational public of the outlined statutory and constitutional protections.
4. The Review of the Scope of Custody via Habeas Corpus: As brilliantly elucidated in the classic treatise Wright & Miller, Federal Practice and Procedure, and in line with the Supreme Court's ruling in Ziglar v. Abbasi, 582 U.S. 120 (2017) (where it became clear that detentions under the pretext of national security merit strong judicial scrutiny), federal courts possess the inherent and unavoidable power, via 28 U.S.C. § 2241, to review not only the fact of detention but the nature, legal adequacy, and constitutionality of the conditions of that custody. Here, the nature of the custody (as an ordinary crime instead of narcoterrorism) is legally defective, subverts Executive Order 14157, and finances an embryonic "Narco-State" that threatens the survival of Brazil and the public safety of the United States.

IV. PHILOSOPHICAL FOUNDATION, INTERNATIONAL LAW, AND COMPARATIVE GLOBAL JURISPRUDENCE

The lethal inertia of the American Respondents subverts the logical and contractual framework that justifies the existence of the modern State. As asserted by the foundational principle of John Stuart Mill in On Liberty, power can only be rightfully exercised over any member of a civilized community to prevent harm to others (Harm Principle). When conjoined with the Social Contract theory of Locke and Hobbes, the Democratic State holds the monopoly on violence exactly to protect life and property. A State that harbors, even within its penal system, terrorist leaders and allows them to continue operating their global networks fails abysmally in its primary function, converting itself into a vector of transnational anarchy. The malicious omission in classifying the PCC/CV as narcoterrorists is not merely an internal administrative flaw; it is the efficient cause of a lethal, measurable, and direct harm across borders.

In the realm of Public International Law—which integrates the hermeneutic framework of U.S. Federal Courts via the Supremacy Clause (Article VI) and the Charming Betsy doctrine—the DOJ's omission in imposing terrorism sanctions on syndicate members violates jus cogens obligations and binding resolutions. UN Security Council Resolution 1373 (2001), adopted under Chapter VII of the UN Charter (thus globally mandatory), explicitly demands that all Member States "deny safe haven" to those who finance, plan, support, or commit terrorist acts, ensuring that such individuals "are brought to justice." Similarly, the Inter-American Convention Against Terrorism (OAS, 2002), to which the U.S. and Brazil are signatories, mandates the eradication of financial flows and the maximum criminal repression of hybrid terror networks. By keeping recognized PCC terrorists under "ordinary" custody, the U.S. disrespects the UN and the OAS, effectively offering an institutional safe haven (in the form of prisons without tactical isolation) for the command of terrorist attacks.

The jurisprudence of global High Courts frontally repudiates state omission in the face of macro-organized crime. The European Court of Human Rights (ECHR), in paradigmatic decisions such as Osman v. United Kingdom (1998), consolidated the doctrine of positive obligations, holding States civilly and internationally liable when, aware of a real and immediate danger to life posed by identified criminals, they fail to take adequate preventive measures within their power. Concurrently, the Inter-American Court of Human Rights (IACHR) (e.g., Velásquez Rodríguez v. Honduras) enshrines State responsibility for systemic acquiescence or tolerance toward organized apparatuses of power. Keeping PCC/Hezbollah terrorist leaders detained without Special Administrative Measures (SAMs) attracts international legal responsibility for the United States for "tactical tolerance" of the terror devastating Brazil.

Finally, the American government collides with the implacable legal principle of Estoppel (or venire contra factum proprium - prohibition of contradictory behavior). As widely documented, in March 2026, under the Miami summit, the U.S. Executive established the aggressive political and military doctrine of the Shield of the Americas, projecting military force in the Caribbean and the Pacific (e.g., Operation Southern Spear) exactly under the declared premise that Latin American cartels and factions are foreign terrorist groups comparable to ISIS and Al-Qaeda. The American State cannot, under the lights of the Administrative Procedure Act (APA) and basic legal logic, adopt a dual institutional personality: asserting that the PCC/CV and their allies are global terrorists for the purpose of legitimizing extraterritorial projection of military force, but simultaneously treating them domestically as "ordinary organized criminals" to spare the Bureau of Prisons from applying Title 21 U.S.C. § 960a. This schizophrenic contradiction renders the act of the Respondents inherently arbitrary, capricious, and jurisdictionally void, demanding corrective intervention via Habeas Corpus / Mandamus.

V. CONCLUSION AND PRAYERS FOR RELIEF

For all the foregoing, transcending mere dogmatic rhetoric and grounded in the most robust factual, statutory, and constitutional framework, the Petitioner demonstrates not only the logical absurdity, but the flagrant and arbitrary illegality (arbitrary and capricious standard) of the omission perpetrated by the North American Respondents. Wholly rejecting the erroneous premises of the Magistrate Judge—who leaned on a procedural "banality of evil" to the glaring detriment of substantive justice, violating principles crystallized by the Supreme Court—the Petitioner pleads for the unpostponable jurisdictional protection of this Federal Court and RESPECTFULLY REQUESTS:

1. THE IMMEDIATE GRANTING OF THE WRIT OF HABEAS CORPUS AND MANDAMUS RELIEF: Based on 28 U.S.C. § 2241 (review of the conditions and nature of custody), conjoined with the Mandamus Act (28 U.S.C. § 1361) and the Administrative Procedure Act (5 U.S.C. § 706(1))—which empowers the Judiciary to compel agency action unlawfully withheld—an order of mandamus is requested directing the U.S. Attorney General and the Bureau of Prisons (BOP) to summarily alter the legal basis of custody for the identified affiliates of the First Capital Command (PCC) and the Red Command (CV) currently detained in the United States. The mandatory transition from the ordinary crime regime to the strict regime for foreign combatants/narcoterrorists is demanded, immediately applying the rigors of 21 U.S.C. § 960a. Consequently, the transfer of these individuals to maximum-security facilities (e.g., ADX Florence) and submission to the restrictive protocols of Special Administrative Measures (SAMs - 28 C.F.R. § 501.3) is required, in order to obliterate their capacities for command and financing of transnational terror.
2. ISSUANCE OF A DECLARATORY JUDGMENT: Under the precise terms of the Declaratory Judgment Act (28 U.S.C. § 2201), it is requested that this Court issue a declaratory ruling recognizing the Kafkaesque and unconstitutional contradiction between the Executive's foreign policy directives (formalized via Executive Order 14157, the Shield of the Americas Doctrine, and OFAC sanctions) and domestic prosecutorial lethargy. The declaration must formally attest that the Federative Republic of Brazil is under material and financial attack by a transnational narcoterrorism insurgency—orchestrated from within the North American prison system itself—whose spurious operations with Hezbollah directly wound the integrity of the Brazilian Democratic State, as well as the commerce, national security, and public health of the United States of America.
3. DE NOVO REVIEW AND REVERSAL OF THE MAGISTRATE JUDGE'S ORDER: Based on Rule 72(b) of the Federal Rules of Civil Procedure (FRCP), applicable to dispositive decisions of magistrate judges, a de novo review of the prior denial order and its complete reversal is requested. Obedience to the revised SCOTUS Rules (2023) and the organic interpretation advocated in Dobbs v. Jackson is invoked, formally recognizing the fulfillment of the requirements of Article III of the Constitution and granting full active standing to Joaquim Pedro de Morais Filho, by virtue of the irrefutable demonstration of the State-Created Danger radiating from the Respondents' inertia.
4. URGENT SCHEDULING OF AN EVIDENTIARY HEARING: Considering the allowance of 28 U.S.C. § 2243, the expedited scheduling of an evidentiary hearing before this Honorable District Court is requested for the adduction of unclassified reports and intelligence pieces from the DOJ/DEA and the Brazilian Federal Police that attest to the materiality of Operation Trapiche and the undeniable tactical and financial fusion between the First Capital Command (PCC) and the terrorist group Hezbollah, justifying the mandatory classification pleaded herein.

RESPECTFULLY SUBMITTED,

Under penalty of perjury, I declare under the jurisdiction of Title 28 of the United States Code, Section 1746 (28 U.S.C. § 1746), that the factual narratives and allegations set forth in this document are entirely authentic and true.

New York, NY (Via electronic submission) / São Paulo, SP, Brazil.
March 22, 2026

JOAQUIM PEDRO DE MORAIS FILHO
Petitioner (Pro Se)
Brazilian Passport: GD584268
Resident in São Paulo, SP, Brazil.