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01-717O � } " � {� � � Council File # O 1• 1�� Green Sheet # ll1797 Presented By: RESOLUTION OF 5AINT PAUL, NIINNESOTA a3 Referred To: Committee:Date: 1 RESOLVED, that the Saint Paul Police Department is authorized to enter into the attached 2 agreement with the United States Department of Justice, Federal Bureau of Investigations, to 3 participate in an Organized Crime Task Farce to identify and target for prosecution Organized 4 Criminal Enterprises. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . 26 27 28 29 30 31 32 33 Requested by Department of: Adopted by Council: Date: Adoption Certified by Cou BY: °��\ _ a— Polic B Form roved by ty Attorney: By: /��. Approved�by Mayor:'�ate: ,�J� (� x�� Approved b Mayor f r Submission to Council: B Y� —�� BY� l/ `�YhC. ��N� _ octftaskforcemou-cr ( DE°AE;��,.AEP;T(vfFICE/COUNqL DATEINITIATED Poli.:. 06/Ol/2001 GREEN SHEET No. 111797 �' G NTA RSO & HONE INR�qWATE �NrzIAUDA7E William:lmley 292-3588 1 omnmxFxrwrsecro ll� 4 rtrcour+ca MOST B'- ON COUNCIL AGENDA BY (DATE) O`- �, �� 4 � ^, n '� �� Tx .Y�� 1* ATfORNEY �G�ce� �I I ��w�.w.�SERNCESWR �wu��w.5EfN1ACtTG �1 � .i y.wYOR(OR/SSISTANT)� �N1IMANRIGFRS ��i TOTAL # OF SIGNATURE PAGES 1 (CLIP ALL LOCATIONS FOR SIGNATURE) C710N REQUES7ED Signatures required on the attached council resolution authorizing the Saint Paul Police Department to enter into an agreement with the United States Depariment of Justice. RECOMMEN�ATION A�lPfoVe (A) of RBjECt (R) PERSONAL SERVICE GONTRACTS MUST ANSWER THE FOLLOWING QUESTIONS: 1. Has this person/firtn e�er worked under a contrect for this department? PLANNING COMMISSION vES NO CIB COMMITTEE 2. Has this perso�rtn ever been a city employee? CIViI SERVICE COMMISSION YES NO 3. Ooes this personlfirm possess a skill not nortnally possessed by any wrteM city employee? YES NO 4. Is this personffirtn a t2rgeted ventloR YES NO E<plain ail yes answers on separate sheet and attach to green sheet INITIATING PROBLEM ISSUE, OPPOR7UNIN (WHO, WHAT, WHEN, WHERE, WHY) The Saint Paul Police Department will participate in the Organized Crime Task Force (OCTF) with the United States Department of 7usrice, Federal Bureau of Investigarions. The Saint Pau1 Police Depamnent will be reimbursed for overtime expenses. ADVANTAGESIFAPPROVED The Saint Paul Police Department will participate in the Organized CYime Task Force (OCTF) with other federal and local agencies. .�„• DISADVANTAGES IF APPROVED None ��N `�' Q ��i DISADVANTAGESIFNOTAPPROVED �3:°�� r" ��8 The Saint Paul Police Depaztrnent will not participate in the Organized Crime Task Force (OCTF). q ��R� r�'' ��08 � t+. :W i� TOTAL AMOUNT OF TRANSACTION $ see the attached agreement COST/REVENUE BUDGETED (CIRCLE ONE) YES NO , ' __ _'_ .....,......._._ �c . FUNDIN� SOURCE United States Secret Service AC71VI7Y NUMBER credit revenue to 04000-4399 FINANCIAL INFORMATION (EXPLAIN) o�•�� MEMORANDUM OF UNDERSTANDING �1VIOUl ORGANIZED CRIME TASK FORCE (OCTFI This Memorandum of Understanding (MOU) is being executed by the below listed agencies: Federal Bureau of Investigation (FBI) Minneapolis Police Department (MPD) St. Paul Police Department (SPPD) Minnesota Department of Public Safety, Alcohol and Gambling Enforcement (AGE) Immigration and Naturalization Service (INS) Department of Housing and Urban Redevelopment (HUD) Nothing in this MOU should be construed as limiting or impeding the basic spirit of cooperation which exists between the participating agencies listed above. I. PURPOSE This MOU establishes and delineates the mission of the Organized Crime Task Force, herein aftex referred to as the OCTF, as a joint cooperative effort. Additionally, the MOU formalizes relationships between and among the participating agencies in order to foster an efficient and cohesive unit capable of addressing the many aspects of organized crime, to include but not limited to loan sharking, extortion, prostitution, gambling, drugs, weapons violations, insurance fraud, interstate transportation of stolen properiy (ITSP), fraud against the Government, alien smuggling and immigration violations within the greater Minneapolis/St. Paul metropolitan area. It is the desire of the participating agencies to achieve maximum inter-agency cooperation in a combined law enforcement effort aimed at reducing criminal activity within the communities served. II. MISSION The mission of the OCTF is to identify and target for prosecution Organized Criminal Enterprises. The OCTF will enhance the effectiveness of federal/state/local law enforcement resources through a well-coordinated initiative seeking the most effective investigative/prosecutive avenues by which to convict and incarcerate dangerous offenders. a�-��? III. ORGANIZATIONAL STRUCTURE A. Composition The OCTF wi11 consist of a combined enforcement body of agencies participating in this MOU. These participating agencies will provide assigned personnel, as set forth below: 2 FBI Full-time MPD Part-time SPPD Part-time AGE Full-rime HUD Part-time INS Part-time B. Direction All participants acknowledge that the OCTF is a joint operation in which all agencies act as partners in the operation of the task force. The heads of the participating entities will be responsible for the policy and direction of the OCTF. C. Supervision The day to day operation and administrative control of the OCTF will be the responsibiliry of a Supervisary Special Agent (SSA) of the FBI. Responsibility for the conduct of OCTF members, both personally and professionally, shall remain with the respective agency heads. The heads of the participating agencies will be kept advised of the activities of the OCTF. D. Meetings/Briefings Management meetings andlor briefings concerning the activities or other issues associated with OCTF will occur on a biannual basis or such other time as any pariy to this agreement feels that a meeting/briefing is required. Task Force members shall have meetings/briefings every other month. IV. PROCEDURE5 A. Personnel Continued assignment of personneI to the OCTF will be based upon performance and will be at the discretion of the respective agency heads/supervisors. Each participating agency, upon request, will be provided with an update as to the program, direction and accomplishments of the OCTF. 2 0�-'1��1 B. Deputation All local and state law enforcement personnel designated to the OCTF, subject to a limited background inquiry, will be federally deputized, with the FBI securing the required deputation authorization. These deputations will remain in effect throughout the tenure of each investigator's assignment to the OCTF or until termination of the task force, whichever occurs first. The deputation authority granted is restricted to activities in furtherance of OCTF investigations which have been officially opened by the FBI SSA. (NOTE: Full background investigations and Top Secret security clearances are required in those instances where the OCTF will be housed in FBI space and all members will have uriescorted access.) Personnel for participating agencies will receive a comprehensive briefing on FBI field office security policy, deadly force policy and procedures. During the briefings, each individual will execute non-disclosure agreements (SF-312 and FD-868). Upon depariure from the OCTF, personnel from participating agencies will execute non-disclosure agreements (SF-312 and FD-868) and will be given a security debriefing. C. Invesrigations All OCTF investigations will be initiated in accordance with United States Attorney General Guidelines on General Crimes, Racketeering Enterprise and Domestic Security/Terrorism Investigations (AG Guidelines). The investigative methods employed will be consistent with the policies and procedures of the FBI and the AG Guidelines. However, in situations where the statutory or common law of Minnesota is more restrictive than comparable Federal law, the investigative methods employed by state and local law enforcement agencies shall conform to the requirements of such statutory or common law pending a decision on venue for prosecution. D. Prosecution The criteria for determining whether to prosecute a particular violation in state or federal court will focus upon achieving the greatest overall benefit to law enforcement and the public. Any question which arises pertaining to prosecutive jurisdiction will be resolved through discussions among all investigative agencies and prosecutive entities having an interest in the matter. V. ADMINISTRATIVE ��`� A. Case Assignments The FBI SSA assigned to the OCTF will oversee the prioritization and assignment of targeted cases and related investigative activity in accordance with the stated objectives and direction of the OCTF. Cases will be assigned to invesrigative teams or individual investigators based on experience, training, performance, expertise and existing case load. B. Recordsand Reports All investigative reporting will be prepared in compliance with existing FBI policy. Subject to applicable legal and/or policy restrictions, copies of pertinent documents created by each member of the task force will be made available for inclusion in the respective investigative agencies' files as appropriate. Investigative files will be maintained at the FBI. C Evidence and Undercover Operations All evidence and original tape recordings (audio and video) acquired during the course of OCTF investigations will be maintained by the FBI. The FBI's rules and policies governing the submission, retrieval and chain of custody will be adhered to by the OCTF personnel. All OCTF undercover operations will be conducted and reviewed in accordance with FBI guidelines and the Attarney General's Guidelines on Undercover Operations. D. Investigative Exclusivity Matters designated to be handled by the OCTF will not knowingly be subject to non-Task Force law enforcement efforts. It is incumbent upon each agency to make proper internal notification regarding OCTF existence, including its areas of concern. There shall be no unilateral action taken on the part of the participating agency relating to OCTF investigations. All law enforcement action will be coordinated and conducted in a cooperative manner. OCTF investigative leads outside the Minneapolis FBI territory wi11 be communicated to other FBI offices for appropriate investigation. E. Informants and Cooperating Witnesses The United States Attorney General Guidelines and the FBI's guidelines regazding the operation of informants and cooperating witnesses will apply to all informants and cooperating witnesses directed by members of the OCTF. The FBI agrees, subject to funding availability, to 0 o �-'�� pay informants/cooperating witnesses' expenses in accordance with FBI policies and procedures and which are determined by the FBI to be reasonable and necessary. An appropriate FBI informant/cooperating witness file will be opened wherein all information furnished by the informanUcooperating witness will be maintained. In addition, any recommendations for payments to this informanUcooperating witness will also be documented therein. VI. MEDIA All media releases pertaining to OCTF investigations and/or arrests will be coordinated and made jointly by all participants of this MOU. No unilateral press releases will be made by any participating agency without the prior approval of the other participants. No information pertaining to the OCTF itself will be released to the media without mutual approval of all participants. VII. EQUIPMENT Each agency will furnish its own equipment except that the FBI may furnish communications and other equipment if available. VIII. FUNDING Each participating agency agrees to provide the services of its respective personnel for the duration of this operation. Participating agencies agree to assume all persomlel costs for their task force representatives, including salaries, overtime payments and fringe benefits consistent with their respective agency. IX. LIABILITY Unless specifically addressed by the terms of this MOU, the parties agree to be responsible for the negligent or wrongful acts or omissions of their respective employees. Legal representation by the United States is determined by DOJ on a case-by-case basis. The FBI cannot guarantee the United States will provide legal representation to any Federal, state or local law enforcement officer. Congress has provided that the exclusive remedy far the negligent or wrongful act or omission of an employee of the United States government, acting with the scope of his employment, shall be an action against the United States under the Federal Tort Claims Act (FTCA), 28 U.S.C. Section 1346(b), Section 2671-2680. For the limited purpose of defending claims arising out of OCTF activity, state or local law enforcement officers who have been specially deputized and who are acting within the course and scope of their official duties and assignments pursuant to this MOU, may be considered an "employee" of the United States government as defined in 28 U.S.C. Section 2671. See 5 U.S.C. Section 3374 (c)(2). a�-1�'1 Under the Federal Employees Liability Reform and Tort Compensation Act of 1988 (commonly kno�vn as the Westfall Act), 28 U.S.C. Section 2679(b)(1), the Attorney General or his designee may certify that an individual defendant acted within the scope of his employment at the time of the incident giving rise to the suit. Id., 28 U.S.C. Section 2679(d)(2). The United States can then be substituted for the employee as the sole defendant with respect to any tort claims. 28 U.S.C. Section 2679(d)(2). If the United States is substituted as defendant, the individual employee is thereby protected from suits in his official capacity. If the Attorney General declines to certify that an employee was acting within the scope of employment, "the employee may at any time before trial petition the court to find and certify that the employee was acting within the scope of his office or employment." 28 U.S.C. Saction 2679(d)(3). Liability for any negligent or willful acts of Task Force employees, undertaken outside the terms of this MOU will be the sole responsibility of the respective employee and agency involved. Liability for violations of federal constitutional law rests with the individual federal agent ar officer pursuant to Bivens v Six Unknown Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388 (1971) or pursuant to 42 U.S.C. Section 1983 for state and local officers or cross- deputized federal officers. Both state and federal officers enjoy qualified immunity from suit for constitutional torts "insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known." Harlow v. Fitz e,_�, 457 U.S. 800 (1982). Task Force officers may request representation by the U.S. Department of Justice for civil suits against them in their individual capacities for actions taken within the scope of employment. 28 C.F.R. Section 50.15, 50.16. An employee may be provided representation "when the actions for which representation is requested reasonably appear to have been performed within the scope of the employee's employment and the Attorney General or [her] designee determines that providing representation would otherwise be in the interest of the United States." 28 C.F.R. Section 50.15(a). A Task Force officer's written request for representation should be directed to the Attorney General and provided to the Chief Division Counsel (CDC) of the FBI division coordinating the Task Force. The CDC will then forward the representation request to the FBI's Office of the General Counsel (OGC) together with a letterhead memorandum concerning the factual basis for the lawsuit. FBI/OGC will then forward the request to the Civil Division of DOJ together with an agency recommendation concerning scope of employment and Department representation. 28 C.F.R. Section 50.15(a)(3). 6 0�-1�1 If a Task Force officer is found to be liable for a constitutional tort, he/she may request indemnification from DOJ to satisfy an adverse judgement rendered against the employee in his/her individual capacity. 28 C.F.R. Section 50.15(c)(4). The criteria for payment are substantially similar to those used to determine whether a federal employee is entitled to DOJ representation under 28 C.F.R. Section 50.15(a). X. Di.JR.ATION This MOU shall remain in effect until terminated as specified below. Continuation of this MOU shall be subject to the availabiliry of necessary funding. This agreement may be modified at any time by written consent of all involved agencies. This agreement may be terminafed at any time by any of the participating agencies, including the FBL The participating agencies may withdraw from this agreement at any time by providing a 30 day written notice of its intent to withdraw to all other participating agencies. Upon the termination of the OCTF and the MOU, all equipment will be returned to the supplying agencies. XI. MODIFICATION This agreement may be modified at any time by written consent of all involved agencies. Modification to this MOU shall have no force and effect unless such modifications are reduced to writing and signed by an authorized representative of each participating agency. XIL FORFEITURE A. Assets seized and forfeited will be divided in an equitable manner with advice from the parties to this agreement. Expenses and costs incurred for Pen Registers (excluding costs incurred by the FBI) shall be reinibursed from forfeited assets prior to the division of such assets. The FBI shall be entitled to 20 percent of the forfeited funds to cover administrative costs associated with the forfeiture. The FBI SSA shall have the authority to distribute the forfeited assets, again, with ample consideration given to the positions of the parties to this agreement, except as specified in Section XII-B. The remaining forfeited assets (after expenses from Pen Registers/Trap and Traces are reimbursed) shall be divided equitably, taking into account the percentage of participation of law enforcement agencies involved with a particular investigation. Should an agency which is a non-pariy to this agreement provide assistance to an OCTF investigation, the FBI SSA shall have the authority to distribute a percentage of the forfeited proceeds to the non-party participating agency as well. B. For forfeited proceeds of $25,000 or more, a committee composed of a manager from each agency participating in this MOU shall determine the division and distribution of assets, except for the FBI's share of 20 percent to cover administrative costs; a quorum of three managers is needed to determine the division and distribution of assets. All other terms as outlined in Section XII-A shall remain in effect. 7 d � �� 1\r1 Dougl�s J. Domin Special Agent in Charge Federal $ureau of Investigation William K. Fir Chief St. Paul Police Robert K. Olson Chief Minneapolis Police Frank Ball Director Minnesota Department of Public Safe Alcohol and Gambling Enforcement D' isi Curtis J. Aljets District Director Immigration and Michael K. Gros Special Agent in Bepartment of H All MOUs Date Date Date Date Date Date and ilrban Redevelopment be approved by: (FBI Contr�cting Officer) Date � 1b� Sl�nG�fGv`e� l�x-in� rpc.� uv�d.e.�' S��el�'a,-�e yYeu2 s�i�ef Service O � } " � {� � � Council File # O 1• 1�� Green Sheet # ll1797 Presented By: RESOLUTION OF 5AINT PAUL, NIINNESOTA a3 Referred To: Committee:Date: 1 RESOLVED, that the Saint Paul Police Department is authorized to enter into the attached 2 agreement with the United States Department of Justice, Federal Bureau of Investigations, to 3 participate in an Organized Crime Task Farce to identify and target for prosecution Organized 4 Criminal Enterprises. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . 26 27 28 29 30 31 32 33 Requested by Department of: Adopted by Council: Date: Adoption Certified by Cou BY: °��\ _ a— Polic B Form roved by ty Attorney: By: /��. Approved�by Mayor:'�ate: ,�J� (� x�� Approved b Mayor f r Submission to Council: B Y� —�� BY� l/ `�YhC. ��N� _ octftaskforcemou-cr ( DE°AE;��,.AEP;T(vfFICE/COUNqL DATEINITIATED Poli.:. 06/Ol/2001 GREEN SHEET No. 111797 �' G NTA RSO & HONE INR�qWATE �NrzIAUDA7E William:lmley 292-3588 1 omnmxFxrwrsecro ll� 4 rtrcour+ca MOST B'- ON COUNCIL AGENDA BY (DATE) O`- �, �� 4 � ^, n '� �� Tx .Y�� 1* ATfORNEY �G�ce� �I I ��w�.w.�SERNCESWR �wu��w.5EfN1ACtTG �1 � .i y.wYOR(OR/SSISTANT)� �N1IMANRIGFRS ��i TOTAL # OF SIGNATURE PAGES 1 (CLIP ALL LOCATIONS FOR SIGNATURE) C710N REQUES7ED Signatures required on the attached council resolution authorizing the Saint Paul Police Department to enter into an agreement with the United States Depariment of Justice. RECOMMEN�ATION A�lPfoVe (A) of RBjECt (R) PERSONAL SERVICE GONTRACTS MUST ANSWER THE FOLLOWING QUESTIONS: 1. Has this person/firtn e�er worked under a contrect for this department? PLANNING COMMISSION vES NO CIB COMMITTEE 2. Has this perso�rtn ever been a city employee? CIViI SERVICE COMMISSION YES NO 3. Ooes this personlfirm possess a skill not nortnally possessed by any wrteM city employee? YES NO 4. Is this personffirtn a t2rgeted ventloR YES NO E<plain ail yes answers on separate sheet and attach to green sheet INITIATING PROBLEM ISSUE, OPPOR7UNIN (WHO, WHAT, WHEN, WHERE, WHY) The Saint Paul Police Department will participate in the Organized Crime Task Force (OCTF) with the United States Department of 7usrice, Federal Bureau of Investigarions. The Saint Pau1 Police Depamnent will be reimbursed for overtime expenses. ADVANTAGESIFAPPROVED The Saint Paul Police Department will participate in the Organized CYime Task Force (OCTF) with other federal and local agencies. .�„• DISADVANTAGES IF APPROVED None ��N `�' Q ��i DISADVANTAGESIFNOTAPPROVED �3:°�� r" ��8 The Saint Paul Police Depaztrnent will not participate in the Organized Crime Task Force (OCTF). q ��R� r�'' ��08 � t+. :W i� TOTAL AMOUNT OF TRANSACTION $ see the attached agreement COST/REVENUE BUDGETED (CIRCLE ONE) YES NO , ' __ _'_ .....,......._._ �c . FUNDIN� SOURCE United States Secret Service AC71VI7Y NUMBER credit revenue to 04000-4399 FINANCIAL INFORMATION (EXPLAIN) o�•�� MEMORANDUM OF UNDERSTANDING �1VIOUl ORGANIZED CRIME TASK FORCE (OCTFI This Memorandum of Understanding (MOU) is being executed by the below listed agencies: Federal Bureau of Investigation (FBI) Minneapolis Police Department (MPD) St. Paul Police Department (SPPD) Minnesota Department of Public Safety, Alcohol and Gambling Enforcement (AGE) Immigration and Naturalization Service (INS) Department of Housing and Urban Redevelopment (HUD) Nothing in this MOU should be construed as limiting or impeding the basic spirit of cooperation which exists between the participating agencies listed above. I. PURPOSE This MOU establishes and delineates the mission of the Organized Crime Task Force, herein aftex referred to as the OCTF, as a joint cooperative effort. Additionally, the MOU formalizes relationships between and among the participating agencies in order to foster an efficient and cohesive unit capable of addressing the many aspects of organized crime, to include but not limited to loan sharking, extortion, prostitution, gambling, drugs, weapons violations, insurance fraud, interstate transportation of stolen properiy (ITSP), fraud against the Government, alien smuggling and immigration violations within the greater Minneapolis/St. Paul metropolitan area. It is the desire of the participating agencies to achieve maximum inter-agency cooperation in a combined law enforcement effort aimed at reducing criminal activity within the communities served. II. MISSION The mission of the OCTF is to identify and target for prosecution Organized Criminal Enterprises. The OCTF will enhance the effectiveness of federal/state/local law enforcement resources through a well-coordinated initiative seeking the most effective investigative/prosecutive avenues by which to convict and incarcerate dangerous offenders. a�-��? III. ORGANIZATIONAL STRUCTURE A. Composition The OCTF wi11 consist of a combined enforcement body of agencies participating in this MOU. These participating agencies will provide assigned personnel, as set forth below: 2 FBI Full-time MPD Part-time SPPD Part-time AGE Full-rime HUD Part-time INS Part-time B. Direction All participants acknowledge that the OCTF is a joint operation in which all agencies act as partners in the operation of the task force. The heads of the participating entities will be responsible for the policy and direction of the OCTF. C. Supervision The day to day operation and administrative control of the OCTF will be the responsibiliry of a Supervisary Special Agent (SSA) of the FBI. Responsibility for the conduct of OCTF members, both personally and professionally, shall remain with the respective agency heads. The heads of the participating agencies will be kept advised of the activities of the OCTF. D. Meetings/Briefings Management meetings andlor briefings concerning the activities or other issues associated with OCTF will occur on a biannual basis or such other time as any pariy to this agreement feels that a meeting/briefing is required. Task Force members shall have meetings/briefings every other month. IV. PROCEDURE5 A. Personnel Continued assignment of personneI to the OCTF will be based upon performance and will be at the discretion of the respective agency heads/supervisors. Each participating agency, upon request, will be provided with an update as to the program, direction and accomplishments of the OCTF. 2 0�-'1��1 B. Deputation All local and state law enforcement personnel designated to the OCTF, subject to a limited background inquiry, will be federally deputized, with the FBI securing the required deputation authorization. These deputations will remain in effect throughout the tenure of each investigator's assignment to the OCTF or until termination of the task force, whichever occurs first. The deputation authority granted is restricted to activities in furtherance of OCTF investigations which have been officially opened by the FBI SSA. (NOTE: Full background investigations and Top Secret security clearances are required in those instances where the OCTF will be housed in FBI space and all members will have uriescorted access.) Personnel for participating agencies will receive a comprehensive briefing on FBI field office security policy, deadly force policy and procedures. During the briefings, each individual will execute non-disclosure agreements (SF-312 and FD-868). Upon depariure from the OCTF, personnel from participating agencies will execute non-disclosure agreements (SF-312 and FD-868) and will be given a security debriefing. C. Invesrigations All OCTF investigations will be initiated in accordance with United States Attorney General Guidelines on General Crimes, Racketeering Enterprise and Domestic Security/Terrorism Investigations (AG Guidelines). The investigative methods employed will be consistent with the policies and procedures of the FBI and the AG Guidelines. However, in situations where the statutory or common law of Minnesota is more restrictive than comparable Federal law, the investigative methods employed by state and local law enforcement agencies shall conform to the requirements of such statutory or common law pending a decision on venue for prosecution. D. Prosecution The criteria for determining whether to prosecute a particular violation in state or federal court will focus upon achieving the greatest overall benefit to law enforcement and the public. Any question which arises pertaining to prosecutive jurisdiction will be resolved through discussions among all investigative agencies and prosecutive entities having an interest in the matter. V. ADMINISTRATIVE ��`� A. Case Assignments The FBI SSA assigned to the OCTF will oversee the prioritization and assignment of targeted cases and related investigative activity in accordance with the stated objectives and direction of the OCTF. Cases will be assigned to invesrigative teams or individual investigators based on experience, training, performance, expertise and existing case load. B. Recordsand Reports All investigative reporting will be prepared in compliance with existing FBI policy. Subject to applicable legal and/or policy restrictions, copies of pertinent documents created by each member of the task force will be made available for inclusion in the respective investigative agencies' files as appropriate. Investigative files will be maintained at the FBI. C Evidence and Undercover Operations All evidence and original tape recordings (audio and video) acquired during the course of OCTF investigations will be maintained by the FBI. The FBI's rules and policies governing the submission, retrieval and chain of custody will be adhered to by the OCTF personnel. All OCTF undercover operations will be conducted and reviewed in accordance with FBI guidelines and the Attarney General's Guidelines on Undercover Operations. D. Investigative Exclusivity Matters designated to be handled by the OCTF will not knowingly be subject to non-Task Force law enforcement efforts. It is incumbent upon each agency to make proper internal notification regarding OCTF existence, including its areas of concern. There shall be no unilateral action taken on the part of the participating agency relating to OCTF investigations. All law enforcement action will be coordinated and conducted in a cooperative manner. OCTF investigative leads outside the Minneapolis FBI territory wi11 be communicated to other FBI offices for appropriate investigation. E. Informants and Cooperating Witnesses The United States Attorney General Guidelines and the FBI's guidelines regazding the operation of informants and cooperating witnesses will apply to all informants and cooperating witnesses directed by members of the OCTF. The FBI agrees, subject to funding availability, to 0 o �-'�� pay informants/cooperating witnesses' expenses in accordance with FBI policies and procedures and which are determined by the FBI to be reasonable and necessary. An appropriate FBI informant/cooperating witness file will be opened wherein all information furnished by the informanUcooperating witness will be maintained. In addition, any recommendations for payments to this informanUcooperating witness will also be documented therein. VI. MEDIA All media releases pertaining to OCTF investigations and/or arrests will be coordinated and made jointly by all participants of this MOU. No unilateral press releases will be made by any participating agency without the prior approval of the other participants. No information pertaining to the OCTF itself will be released to the media without mutual approval of all participants. VII. EQUIPMENT Each agency will furnish its own equipment except that the FBI may furnish communications and other equipment if available. VIII. FUNDING Each participating agency agrees to provide the services of its respective personnel for the duration of this operation. Participating agencies agree to assume all persomlel costs for their task force representatives, including salaries, overtime payments and fringe benefits consistent with their respective agency. IX. LIABILITY Unless specifically addressed by the terms of this MOU, the parties agree to be responsible for the negligent or wrongful acts or omissions of their respective employees. Legal representation by the United States is determined by DOJ on a case-by-case basis. The FBI cannot guarantee the United States will provide legal representation to any Federal, state or local law enforcement officer. Congress has provided that the exclusive remedy far the negligent or wrongful act or omission of an employee of the United States government, acting with the scope of his employment, shall be an action against the United States under the Federal Tort Claims Act (FTCA), 28 U.S.C. Section 1346(b), Section 2671-2680. For the limited purpose of defending claims arising out of OCTF activity, state or local law enforcement officers who have been specially deputized and who are acting within the course and scope of their official duties and assignments pursuant to this MOU, may be considered an "employee" of the United States government as defined in 28 U.S.C. Section 2671. See 5 U.S.C. Section 3374 (c)(2). a�-1�'1 Under the Federal Employees Liability Reform and Tort Compensation Act of 1988 (commonly kno�vn as the Westfall Act), 28 U.S.C. Section 2679(b)(1), the Attorney General or his designee may certify that an individual defendant acted within the scope of his employment at the time of the incident giving rise to the suit. Id., 28 U.S.C. Section 2679(d)(2). The United States can then be substituted for the employee as the sole defendant with respect to any tort claims. 28 U.S.C. Section 2679(d)(2). If the United States is substituted as defendant, the individual employee is thereby protected from suits in his official capacity. If the Attorney General declines to certify that an employee was acting within the scope of employment, "the employee may at any time before trial petition the court to find and certify that the employee was acting within the scope of his office or employment." 28 U.S.C. Saction 2679(d)(3). Liability for any negligent or willful acts of Task Force employees, undertaken outside the terms of this MOU will be the sole responsibility of the respective employee and agency involved. Liability for violations of federal constitutional law rests with the individual federal agent ar officer pursuant to Bivens v Six Unknown Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388 (1971) or pursuant to 42 U.S.C. Section 1983 for state and local officers or cross- deputized federal officers. Both state and federal officers enjoy qualified immunity from suit for constitutional torts "insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known." Harlow v. Fitz e,_�, 457 U.S. 800 (1982). Task Force officers may request representation by the U.S. Department of Justice for civil suits against them in their individual capacities for actions taken within the scope of employment. 28 C.F.R. Section 50.15, 50.16. An employee may be provided representation "when the actions for which representation is requested reasonably appear to have been performed within the scope of the employee's employment and the Attorney General or [her] designee determines that providing representation would otherwise be in the interest of the United States." 28 C.F.R. Section 50.15(a). A Task Force officer's written request for representation should be directed to the Attorney General and provided to the Chief Division Counsel (CDC) of the FBI division coordinating the Task Force. The CDC will then forward the representation request to the FBI's Office of the General Counsel (OGC) together with a letterhead memorandum concerning the factual basis for the lawsuit. FBI/OGC will then forward the request to the Civil Division of DOJ together with an agency recommendation concerning scope of employment and Department representation. 28 C.F.R. Section 50.15(a)(3). 6 0�-1�1 If a Task Force officer is found to be liable for a constitutional tort, he/she may request indemnification from DOJ to satisfy an adverse judgement rendered against the employee in his/her individual capacity. 28 C.F.R. Section 50.15(c)(4). The criteria for payment are substantially similar to those used to determine whether a federal employee is entitled to DOJ representation under 28 C.F.R. Section 50.15(a). X. Di.JR.ATION This MOU shall remain in effect until terminated as specified below. Continuation of this MOU shall be subject to the availabiliry of necessary funding. This agreement may be modified at any time by written consent of all involved agencies. This agreement may be terminafed at any time by any of the participating agencies, including the FBL The participating agencies may withdraw from this agreement at any time by providing a 30 day written notice of its intent to withdraw to all other participating agencies. Upon the termination of the OCTF and the MOU, all equipment will be returned to the supplying agencies. XI. MODIFICATION This agreement may be modified at any time by written consent of all involved agencies. Modification to this MOU shall have no force and effect unless such modifications are reduced to writing and signed by an authorized representative of each participating agency. XIL FORFEITURE A. Assets seized and forfeited will be divided in an equitable manner with advice from the parties to this agreement. Expenses and costs incurred for Pen Registers (excluding costs incurred by the FBI) shall be reinibursed from forfeited assets prior to the division of such assets. The FBI shall be entitled to 20 percent of the forfeited funds to cover administrative costs associated with the forfeiture. The FBI SSA shall have the authority to distribute the forfeited assets, again, with ample consideration given to the positions of the parties to this agreement, except as specified in Section XII-B. The remaining forfeited assets (after expenses from Pen Registers/Trap and Traces are reimbursed) shall be divided equitably, taking into account the percentage of participation of law enforcement agencies involved with a particular investigation. Should an agency which is a non-pariy to this agreement provide assistance to an OCTF investigation, the FBI SSA shall have the authority to distribute a percentage of the forfeited proceeds to the non-party participating agency as well. B. For forfeited proceeds of $25,000 or more, a committee composed of a manager from each agency participating in this MOU shall determine the division and distribution of assets, except for the FBI's share of 20 percent to cover administrative costs; a quorum of three managers is needed to determine the division and distribution of assets. All other terms as outlined in Section XII-A shall remain in effect. 7 d � �� 1\r1 Dougl�s J. Domin Special Agent in Charge Federal $ureau of Investigation William K. Fir Chief St. Paul Police Robert K. Olson Chief Minneapolis Police Frank Ball Director Minnesota Department of Public Safe Alcohol and Gambling Enforcement D' isi Curtis J. Aljets District Director Immigration and Michael K. Gros Special Agent in Bepartment of H All MOUs Date Date Date Date Date Date and ilrban Redevelopment be approved by: (FBI Contr�cting Officer) Date � 1b� Sl�nG�fGv`e� l�x-in� rpc.� uv�d.e.�' S��el�'a,-�e yYeu2 s�i�ef Service O � } " � {� � � Council File # O 1• 1�� Green Sheet # ll1797 Presented By: RESOLUTION OF 5AINT PAUL, NIINNESOTA a3 Referred To: Committee:Date: 1 RESOLVED, that the Saint Paul Police Department is authorized to enter into the attached 2 agreement with the United States Department of Justice, Federal Bureau of Investigations, to 3 participate in an Organized Crime Task Farce to identify and target for prosecution Organized 4 Criminal Enterprises. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . 26 27 28 29 30 31 32 33 Requested by Department of: Adopted by Council: Date: Adoption Certified by Cou BY: °��\ _ a— Polic B Form roved by ty Attorney: By: /��. Approved�by Mayor:'�ate: ,�J� (� x�� Approved b Mayor f r Submission to Council: B Y� —�� BY� l/ `�YhC. ��N� _ octftaskforcemou-cr ( DE°AE;��,.AEP;T(vfFICE/COUNqL DATEINITIATED Poli.:. 06/Ol/2001 GREEN SHEET No. 111797 �' G NTA RSO & HONE INR�qWATE �NrzIAUDA7E William:lmley 292-3588 1 omnmxFxrwrsecro ll� 4 rtrcour+ca MOST B'- ON COUNCIL AGENDA BY (DATE) O`- �, �� 4 � ^, n '� �� Tx .Y�� 1* ATfORNEY �G�ce� �I I ��w�.w.�SERNCESWR �wu��w.5EfN1ACtTG �1 � .i y.wYOR(OR/SSISTANT)� �N1IMANRIGFRS ��i TOTAL # OF SIGNATURE PAGES 1 (CLIP ALL LOCATIONS FOR SIGNATURE) C710N REQUES7ED Signatures required on the attached council resolution authorizing the Saint Paul Police Department to enter into an agreement with the United States Depariment of Justice. RECOMMEN�ATION A�lPfoVe (A) of RBjECt (R) PERSONAL SERVICE GONTRACTS MUST ANSWER THE FOLLOWING QUESTIONS: 1. Has this person/firtn e�er worked under a contrect for this department? PLANNING COMMISSION vES NO CIB COMMITTEE 2. Has this perso�rtn ever been a city employee? CIViI SERVICE COMMISSION YES NO 3. Ooes this personlfirm possess a skill not nortnally possessed by any wrteM city employee? YES NO 4. Is this personffirtn a t2rgeted ventloR YES NO E<plain ail yes answers on separate sheet and attach to green sheet INITIATING PROBLEM ISSUE, OPPOR7UNIN (WHO, WHAT, WHEN, WHERE, WHY) The Saint Paul Police Department will participate in the Organized Crime Task Force (OCTF) with the United States Department of 7usrice, Federal Bureau of Investigarions. The Saint Pau1 Police Depamnent will be reimbursed for overtime expenses. ADVANTAGESIFAPPROVED The Saint Paul Police Department will participate in the Organized CYime Task Force (OCTF) with other federal and local agencies. .�„• DISADVANTAGES IF APPROVED None ��N `�' Q ��i DISADVANTAGESIFNOTAPPROVED �3:°�� r" ��8 The Saint Paul Police Depaztrnent will not participate in the Organized Crime Task Force (OCTF). q ��R� r�'' ��08 � t+. :W i� TOTAL AMOUNT OF TRANSACTION $ see the attached agreement COST/REVENUE BUDGETED (CIRCLE ONE) YES NO , ' __ _'_ .....,......._._ �c . FUNDIN� SOURCE United States Secret Service AC71VI7Y NUMBER credit revenue to 04000-4399 FINANCIAL INFORMATION (EXPLAIN) o�•�� MEMORANDUM OF UNDERSTANDING �1VIOUl ORGANIZED CRIME TASK FORCE (OCTFI This Memorandum of Understanding (MOU) is being executed by the below listed agencies: Federal Bureau of Investigation (FBI) Minneapolis Police Department (MPD) St. Paul Police Department (SPPD) Minnesota Department of Public Safety, Alcohol and Gambling Enforcement (AGE) Immigration and Naturalization Service (INS) Department of Housing and Urban Redevelopment (HUD) Nothing in this MOU should be construed as limiting or impeding the basic spirit of cooperation which exists between the participating agencies listed above. I. PURPOSE This MOU establishes and delineates the mission of the Organized Crime Task Force, herein aftex referred to as the OCTF, as a joint cooperative effort. Additionally, the MOU formalizes relationships between and among the participating agencies in order to foster an efficient and cohesive unit capable of addressing the many aspects of organized crime, to include but not limited to loan sharking, extortion, prostitution, gambling, drugs, weapons violations, insurance fraud, interstate transportation of stolen properiy (ITSP), fraud against the Government, alien smuggling and immigration violations within the greater Minneapolis/St. Paul metropolitan area. It is the desire of the participating agencies to achieve maximum inter-agency cooperation in a combined law enforcement effort aimed at reducing criminal activity within the communities served. II. MISSION The mission of the OCTF is to identify and target for prosecution Organized Criminal Enterprises. The OCTF will enhance the effectiveness of federal/state/local law enforcement resources through a well-coordinated initiative seeking the most effective investigative/prosecutive avenues by which to convict and incarcerate dangerous offenders. a�-��? III. ORGANIZATIONAL STRUCTURE A. Composition The OCTF wi11 consist of a combined enforcement body of agencies participating in this MOU. These participating agencies will provide assigned personnel, as set forth below: 2 FBI Full-time MPD Part-time SPPD Part-time AGE Full-rime HUD Part-time INS Part-time B. Direction All participants acknowledge that the OCTF is a joint operation in which all agencies act as partners in the operation of the task force. The heads of the participating entities will be responsible for the policy and direction of the OCTF. C. Supervision The day to day operation and administrative control of the OCTF will be the responsibiliry of a Supervisary Special Agent (SSA) of the FBI. Responsibility for the conduct of OCTF members, both personally and professionally, shall remain with the respective agency heads. The heads of the participating agencies will be kept advised of the activities of the OCTF. D. Meetings/Briefings Management meetings andlor briefings concerning the activities or other issues associated with OCTF will occur on a biannual basis or such other time as any pariy to this agreement feels that a meeting/briefing is required. Task Force members shall have meetings/briefings every other month. IV. PROCEDURE5 A. Personnel Continued assignment of personneI to the OCTF will be based upon performance and will be at the discretion of the respective agency heads/supervisors. Each participating agency, upon request, will be provided with an update as to the program, direction and accomplishments of the OCTF. 2 0�-'1��1 B. Deputation All local and state law enforcement personnel designated to the OCTF, subject to a limited background inquiry, will be federally deputized, with the FBI securing the required deputation authorization. These deputations will remain in effect throughout the tenure of each investigator's assignment to the OCTF or until termination of the task force, whichever occurs first. The deputation authority granted is restricted to activities in furtherance of OCTF investigations which have been officially opened by the FBI SSA. (NOTE: Full background investigations and Top Secret security clearances are required in those instances where the OCTF will be housed in FBI space and all members will have uriescorted access.) Personnel for participating agencies will receive a comprehensive briefing on FBI field office security policy, deadly force policy and procedures. During the briefings, each individual will execute non-disclosure agreements (SF-312 and FD-868). Upon depariure from the OCTF, personnel from participating agencies will execute non-disclosure agreements (SF-312 and FD-868) and will be given a security debriefing. C. Invesrigations All OCTF investigations will be initiated in accordance with United States Attorney General Guidelines on General Crimes, Racketeering Enterprise and Domestic Security/Terrorism Investigations (AG Guidelines). The investigative methods employed will be consistent with the policies and procedures of the FBI and the AG Guidelines. However, in situations where the statutory or common law of Minnesota is more restrictive than comparable Federal law, the investigative methods employed by state and local law enforcement agencies shall conform to the requirements of such statutory or common law pending a decision on venue for prosecution. D. Prosecution The criteria for determining whether to prosecute a particular violation in state or federal court will focus upon achieving the greatest overall benefit to law enforcement and the public. Any question which arises pertaining to prosecutive jurisdiction will be resolved through discussions among all investigative agencies and prosecutive entities having an interest in the matter. V. ADMINISTRATIVE ��`� A. Case Assignments The FBI SSA assigned to the OCTF will oversee the prioritization and assignment of targeted cases and related investigative activity in accordance with the stated objectives and direction of the OCTF. Cases will be assigned to invesrigative teams or individual investigators based on experience, training, performance, expertise and existing case load. B. Recordsand Reports All investigative reporting will be prepared in compliance with existing FBI policy. Subject to applicable legal and/or policy restrictions, copies of pertinent documents created by each member of the task force will be made available for inclusion in the respective investigative agencies' files as appropriate. Investigative files will be maintained at the FBI. C Evidence and Undercover Operations All evidence and original tape recordings (audio and video) acquired during the course of OCTF investigations will be maintained by the FBI. The FBI's rules and policies governing the submission, retrieval and chain of custody will be adhered to by the OCTF personnel. All OCTF undercover operations will be conducted and reviewed in accordance with FBI guidelines and the Attarney General's Guidelines on Undercover Operations. D. Investigative Exclusivity Matters designated to be handled by the OCTF will not knowingly be subject to non-Task Force law enforcement efforts. It is incumbent upon each agency to make proper internal notification regarding OCTF existence, including its areas of concern. There shall be no unilateral action taken on the part of the participating agency relating to OCTF investigations. All law enforcement action will be coordinated and conducted in a cooperative manner. OCTF investigative leads outside the Minneapolis FBI territory wi11 be communicated to other FBI offices for appropriate investigation. E. Informants and Cooperating Witnesses The United States Attorney General Guidelines and the FBI's guidelines regazding the operation of informants and cooperating witnesses will apply to all informants and cooperating witnesses directed by members of the OCTF. The FBI agrees, subject to funding availability, to 0 o �-'�� pay informants/cooperating witnesses' expenses in accordance with FBI policies and procedures and which are determined by the FBI to be reasonable and necessary. An appropriate FBI informant/cooperating witness file will be opened wherein all information furnished by the informanUcooperating witness will be maintained. In addition, any recommendations for payments to this informanUcooperating witness will also be documented therein. VI. MEDIA All media releases pertaining to OCTF investigations and/or arrests will be coordinated and made jointly by all participants of this MOU. No unilateral press releases will be made by any participating agency without the prior approval of the other participants. No information pertaining to the OCTF itself will be released to the media without mutual approval of all participants. VII. EQUIPMENT Each agency will furnish its own equipment except that the FBI may furnish communications and other equipment if available. VIII. FUNDING Each participating agency agrees to provide the services of its respective personnel for the duration of this operation. Participating agencies agree to assume all persomlel costs for their task force representatives, including salaries, overtime payments and fringe benefits consistent with their respective agency. IX. LIABILITY Unless specifically addressed by the terms of this MOU, the parties agree to be responsible for the negligent or wrongful acts or omissions of their respective employees. Legal representation by the United States is determined by DOJ on a case-by-case basis. The FBI cannot guarantee the United States will provide legal representation to any Federal, state or local law enforcement officer. Congress has provided that the exclusive remedy far the negligent or wrongful act or omission of an employee of the United States government, acting with the scope of his employment, shall be an action against the United States under the Federal Tort Claims Act (FTCA), 28 U.S.C. Section 1346(b), Section 2671-2680. For the limited purpose of defending claims arising out of OCTF activity, state or local law enforcement officers who have been specially deputized and who are acting within the course and scope of their official duties and assignments pursuant to this MOU, may be considered an "employee" of the United States government as defined in 28 U.S.C. Section 2671. See 5 U.S.C. Section 3374 (c)(2). a�-1�'1 Under the Federal Employees Liability Reform and Tort Compensation Act of 1988 (commonly kno�vn as the Westfall Act), 28 U.S.C. Section 2679(b)(1), the Attorney General or his designee may certify that an individual defendant acted within the scope of his employment at the time of the incident giving rise to the suit. Id., 28 U.S.C. Section 2679(d)(2). The United States can then be substituted for the employee as the sole defendant with respect to any tort claims. 28 U.S.C. Section 2679(d)(2). If the United States is substituted as defendant, the individual employee is thereby protected from suits in his official capacity. If the Attorney General declines to certify that an employee was acting within the scope of employment, "the employee may at any time before trial petition the court to find and certify that the employee was acting within the scope of his office or employment." 28 U.S.C. Saction 2679(d)(3). Liability for any negligent or willful acts of Task Force employees, undertaken outside the terms of this MOU will be the sole responsibility of the respective employee and agency involved. Liability for violations of federal constitutional law rests with the individual federal agent ar officer pursuant to Bivens v Six Unknown Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388 (1971) or pursuant to 42 U.S.C. Section 1983 for state and local officers or cross- deputized federal officers. Both state and federal officers enjoy qualified immunity from suit for constitutional torts "insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known." Harlow v. Fitz e,_�, 457 U.S. 800 (1982). Task Force officers may request representation by the U.S. Department of Justice for civil suits against them in their individual capacities for actions taken within the scope of employment. 28 C.F.R. Section 50.15, 50.16. An employee may be provided representation "when the actions for which representation is requested reasonably appear to have been performed within the scope of the employee's employment and the Attorney General or [her] designee determines that providing representation would otherwise be in the interest of the United States." 28 C.F.R. Section 50.15(a). A Task Force officer's written request for representation should be directed to the Attorney General and provided to the Chief Division Counsel (CDC) of the FBI division coordinating the Task Force. The CDC will then forward the representation request to the FBI's Office of the General Counsel (OGC) together with a letterhead memorandum concerning the factual basis for the lawsuit. FBI/OGC will then forward the request to the Civil Division of DOJ together with an agency recommendation concerning scope of employment and Department representation. 28 C.F.R. Section 50.15(a)(3). 6 0�-1�1 If a Task Force officer is found to be liable for a constitutional tort, he/she may request indemnification from DOJ to satisfy an adverse judgement rendered against the employee in his/her individual capacity. 28 C.F.R. Section 50.15(c)(4). The criteria for payment are substantially similar to those used to determine whether a federal employee is entitled to DOJ representation under 28 C.F.R. Section 50.15(a). X. Di.JR.ATION This MOU shall remain in effect until terminated as specified below. Continuation of this MOU shall be subject to the availabiliry of necessary funding. This agreement may be modified at any time by written consent of all involved agencies. This agreement may be terminafed at any time by any of the participating agencies, including the FBL The participating agencies may withdraw from this agreement at any time by providing a 30 day written notice of its intent to withdraw to all other participating agencies. Upon the termination of the OCTF and the MOU, all equipment will be returned to the supplying agencies. XI. MODIFICATION This agreement may be modified at any time by written consent of all involved agencies. Modification to this MOU shall have no force and effect unless such modifications are reduced to writing and signed by an authorized representative of each participating agency. XIL FORFEITURE A. Assets seized and forfeited will be divided in an equitable manner with advice from the parties to this agreement. Expenses and costs incurred for Pen Registers (excluding costs incurred by the FBI) shall be reinibursed from forfeited assets prior to the division of such assets. The FBI shall be entitled to 20 percent of the forfeited funds to cover administrative costs associated with the forfeiture. The FBI SSA shall have the authority to distribute the forfeited assets, again, with ample consideration given to the positions of the parties to this agreement, except as specified in Section XII-B. The remaining forfeited assets (after expenses from Pen Registers/Trap and Traces are reimbursed) shall be divided equitably, taking into account the percentage of participation of law enforcement agencies involved with a particular investigation. Should an agency which is a non-pariy to this agreement provide assistance to an OCTF investigation, the FBI SSA shall have the authority to distribute a percentage of the forfeited proceeds to the non-party participating agency as well. B. For forfeited proceeds of $25,000 or more, a committee composed of a manager from each agency participating in this MOU shall determine the division and distribution of assets, except for the FBI's share of 20 percent to cover administrative costs; a quorum of three managers is needed to determine the division and distribution of assets. All other terms as outlined in Section XII-A shall remain in effect. 7 d � �� 1\r1 Dougl�s J. Domin Special Agent in Charge Federal $ureau of Investigation William K. Fir Chief St. Paul Police Robert K. Olson Chief Minneapolis Police Frank Ball Director Minnesota Department of Public Safe Alcohol and Gambling Enforcement D' isi Curtis J. Aljets District Director Immigration and Michael K. Gros Special Agent in Bepartment of H All MOUs Date Date Date Date Date Date and ilrban Redevelopment be approved by: (FBI Contr�cting Officer) Date � 1b� Sl�nG�fGv`e� l�x-in� rpc.� uv�d.e.�' S��el�'a,-�e yYeu2 s�i�ef Service