OIG No. 24-28 Investigation of MBPD Civilian Employee for Exploitation of Official PositionTO:
FROM:
DATE:
RE:
Joseph M.Centorino,Inspector General
Honorable Mayor and Members of the City Commissioners
Joseph Centorino,Inspector General
November 26,2024
Investigation of MBPD Civilian Employee for Exploitation of Official Position
OIG No.24-28
INVESTIGATIVE SUMMARY
On February 23,2022,four female civilian employees of the Criminal Analysis Unit at the Miami
Beach Police Department came to the Office of the Inspector General (OIG)to file complaints
against the supervisor of that unit,Clifford Sparks (Subject).The Subject,a civilian employee of
the department and a former police officer,was accused of unethical conduct involving alleged
sexual harassment of subordinate employees and misuse of City resources in connection with
private business activity.During the initial and several subsequent meetings with the OIG,the
complainants provided details on both matters,including personal observations and experiences,
as well as documents such as texts,departmental purchase records,photographs and related
material.
The sexual harassment allegations involved the subject's texting the employees at night,
engaging in inappropriate online and personal conversations and comments,unwelcome hugs,
and,in the context of what the Subject suggested were surprise "Christmas gifts,"driving each of
them on separate occasions in his City vehicle to a massage parlor in the City for a complimentary
massage arranged by him.
The allegations of misuse of City resources centered on the Subject's utilization of his position in
the Police Department to promote the department's engagement with a company owned by a
business partner of his with the intent to create a new software system to improve the Police
Department's records management,along with the expectation that he would be compensated
by the company.The activity included his personal involvement in the proposed project and his
direction of subordinate employees in testing equipment related to that project on City time.The
complainants provided documents relevant to that activity.
The OIG conducted a preliminary investigation on both allegations to determine whether possible
violations of the Miami-Dade County Ethics Code may have occurred.
The sexual harassment allegation had already been the subject of a police Internal Affairs
Investigation (Case No.12021-030),which was completed prior to the OIG's receipt of the
complaints.The OIG obtained and reviewed a copy of the IA Report and transcribed statements
taken in that investigation,which included statements taken from the complainants and the
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Subject,as well as other Police Department personnel and supervisors.
The IA investigation had been shared with the Human Resources Director and resulted in a
determination that the Subject had violated City Work Rule ORR 6.7.2,Courtesy and Respect,as
well as SOP#145,Social Media and Social Networking.Based on those violations,the Subject
was subjected to disciplinary action,which included (1)a written warning;(2)reclassification of
his position amounting to a reduction in class but no reduction in salary;and (3)Mandatory
attendance at employee assistance counseling and coaching.
The OIG reviewed the allegations with the complainants,all of whom,although no longer directly
under his supervision,expressed concern and discomfort about their interactions with him.The
OIG also took a sworn statement from a retired MBPD employee witness who was familiar with
the Subject but did not work in the same unit as the complainants.She had been questioned
during the IA investigation about offensive actions by the Subject toward her,but had not been
asked,nor did she disclose,whether she herself had been offered an arranged massage by the
Subject.She testified to the OIG that she had been offered the same "gift"massage as the others.
This witness was also aware of the Subject's attempts to promote his private business with the
police department and his use of other police employees to test equipment related to that business
during working hours.
The Ethics Commission staff reviewed the information provided by the OIG and determined that
there was insufficient evidence to prove a violation under the County Ethics Code for the sexual
harassment charges.The complainants had also filed a complaint with the U.S.Equal
Employment Opportunity Commission (EEOC)on those charges in which they were represented
by private counsel.That matter has not yet been fully concluded.
In connection with the allegations that the Subject had improperly used his position and the
personnel he supervised to promote his personal business interests,the OIG gathered and
reviewed the Subject's personnel file,record of outside employment requests,corporate records
and other relevant material supplied by the complainants or obtained from other sources.The
information received by the OIG from the complainants and the failure of the Subject to properly
request permission for outside employment or to file required Outside Employment statements
with the City Clerk,together with examination of the rest of the available evidence,constituted
prima facie evidence of Exploitation of Official Position,Section 2-11.1(g)and Prohibition on
Outside Employment,Section 2-11.1 (k)(2)of the Miami-Dade Code of Ethics as well as City
Policies regarding the same issues.
The OIG shared all evidence and information on the outside employment issues with investigative
staff at the Miami-Dade Commission on Ethics and Public Trust (COE)for consideration regarding
possible violations of those provisions of the County Ethics Ordinance.The OIG continued
working jointly with the COE investigator assigned to the investigation in obtaining further
information from the City and other sources to support the allegations.
The COE Advocate concluded that the evidence of the Subject's use of City resources and
personnel to promote the Subject's private business interests was sufficient to find probable cause
that the Subject had violated those two provisions of the Miami-Dade Ethics Code,Exploitation of
Official Position,Section 2-11.1(g)and Prohibition on Outside Employment,Section 2-11.1(k)(2).
At the close of the joint investigation,the Inspector General filed an Ethics Complaint on those
two charges with the COE (Exhibit 1),which is attached to this report,along with the Probable
Cause Memorandum from the COE Advocate (Exhibit 2),also attached.The latter document
contains further details regarding the investigation.
Page 2 of 3
At the close of the Ethics enforcement action,the Subject,who had been interviewed during the
investigation along with his business associate and Police Department supervisors,agreed to
stipulate to probable cause for the violations and,in an agreed disposition with the Ethics
Commission,admitted to one count of Exploitation of Official Position and one count of Unlawful
Outside Employment.He was assessed a fine of $1500 by the COE and directed to receive a
Letter of Instruction (See Public Report and Final Order,Exhibit 3).
This is the seventh report issued by the OIG that has involved improper or unethical actions by
City employees related to outside employment issues.It underscores the need for the City
Administration and departments to more closely scrutinize such matters.
This report has been submitted to the City Administration and Police Department for any further
action they may deem appropriate.
espectfully submitted,
""--~,,n--.-~//,&l~~Po<_f
ph M.Centorino
Inspector General
cc:Eric Carpenter,City Manager
Marla Alpizar,Human Resources Director
Wayne Jones,Chief of Police
Clifford Sparks,Subject
OFFICE OF THE INSPECTOR GENERAL,City of Miami Beach
1130 Washington Avenue,6"Floor,Miami Beach,FL 33139
Tel:305.673.7020 •Hotline:786.897.1111
Email:CityofMiamiBeachOIG@miamibeachfl.gov
Website:www.mbinspectorqeneral.com
Page 3 of 3
EXHIBIT 1
OFFICE OF INSPECTOR GENERAL
CITY OF MIAMI BEACH
IN RE:
CLIFFORD SPARKS
ETHICS COMPLAINT
C 24-XX-XX
RESPONDENT.
_____________./
Petitioner,the Inspector General for the City of Miami Beach (hereinafter "the OIG"),
pursuant to Section 2-1074(a)(l)of the Code of Miami-Dade County,files this Complaint
against CLIFFORD SPARKS (hereinafter,"Respondent"),for violating the Miami-Dade County
Conflict of Interest and Code of Ethics Ordinance Section 2-11.1 (g),entitled "Exploitation of
Official Position,"and Section 2-11.1 (k)(2)),entitled "Prohibition on Outside Employment."
STATEMENT OF JURISDICTION
I.The COE has jurisdiction pursuant to Sections 2-1068 and 2-1072 of the Code of
Miami-Dade County.
BACKGROUND AND FACTS
2.At all times relevant and pertinent to this Complaint,and specifically throughout
2021-2024,Respondent was a full-time employee of the City of Miami Beach Police Department
(hereinafter "MBPD)working as a supervisor for the Criminal Analysis Unit (hereinafter
CAU").
3.CAU assisted detectives and other units at MBPD with data driven information,
specifically by monitoring crime trends and providing the department with updated information
specific to crime by location.
4.An investigation showed that the Respondent,in his capacity as the supervisor of
the CAU,facilitated the introduction between a friend and/or business associate,Richard Jerome,
Page 1 of 5
and the MBPD with the goal of developing a software program for MBPD's record management
system.
5.At all times relevant and pertinent to this Complaint,Richard Jerome,served as
President and Registered Agent for Crime Suppression Technologies,Inc.(hereinafter "CST").
6.On or about June 5,2019,the Respondent created Vanguard Software Systems Inc,
listing himself as the Registered Agent and both himself and Mr.Jerome as Presidents of the
company.
7.On or about June 2019,the Respondent submitted a Request for Approval of
Outside Employment form for Vanguard Software Systems,Inc.,identifying himself as the
"President of a technology company."
8.An investigation showed that the Respondent used his official position with the
intent offacilitating MBPD's purchase of multiple devices for CST.
9.An investigation showed that the Respondent tasked his subordinates to test CST's
software during work hours,outside of their MBPD work duties.
l 0.An investigation showed that the Respondent directed a subordinate to use her
personal vehicle to evaluate the CST's software.
l l.In 2021,Respondent created Sparks Will Fly Enterprises LLC,a Florida for profit
corporation.
12.At all times relevant and pertinent to this Complaint,Respondent served as the
Registered Agent for Sparks Will Fly Enterprises LLC,a Florida for-profit corporation.
13.In 2022,the Respondent maintained and served as Registered Agent and Manager
of Sparks Will Fly Enterprises LLC.
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14.In 2023,the Respondent maintained and served as Registered Agent and Manager
of Sparks Will Fly Enterprises LLC.
15.An investigation showed that the Respondent failed to file the required Outside
Employment Statement by July I,2022,disclosing the source of his outside employment,the
nature of the work being done pursuant to same,and any amount or types of money or other
consideration received by the employee for that outside employment,during tax year 2021.
16.An investigation showed that the Respondent failed to file the required Outside
Employment Statement by July 1,2023,disclosing the source of his outside employment,the
nature of the work being done pursuant to same,and any amount or types of money or other
consideration received by the employee for that outside employment,during tax year 2022.
LAW
17.Section 2-11.l(g)of the Miami-Dade County Conflict of Interest and Code of
Ethics Ordinance,entitled,"Exploitation ofofficialposition prohibited,"states:
No person included in the terms defined in Subsection (b)(1)through
(6)and (b)(13)shall use or attempt to use his or her official position to
secure privileges or exemptions for himself or herself or others except
as may be specifically permitted by other ordinances and resolutions
previously ordained or adopted or hereafter to be ordained or adopted
by the Board of County Commissioners.
18.Section 2-11.1(k)(2)of the Miami-Dade County Conflict of Interest and Code
of Ethics Ordinance,states in pertinent part:
All full-time County and municipal employees engaged in any
outside employment for any person,firm,corporation or entity other
than Miami-Dade County,or the respective municipality,or any of
their agencies or instmmentalities,shall file,under oath,an annual
report indicating the source of the outside employment,the nature
of the work being done pursuant to same and any amount or types
ofmoney or other consideration received by the employee from said
Page 3 of 5
outside employment.Said County employee's reports shall be filed
with the supervisor of elections no later than 12:00 noon on July 1st
of each year,including the July 1st following the last year that
person held such employment.
19.Throughout the years 2021 and/or 2022,Respondent violated Section 2-11.1 (g)of
the Miami-Dade County Conflict of Interest and Code of Ethics Ordinance by using his official
position,to wit:supervisor of Criminal Analysis at MBPD,to secure a special privilege or
exemption,to wit:utilizing City ofMiami Beach resources,and City of Miami Beach employees,
for himself or another,to wit:in furtherance ofhis outside employment activities and/or those of
Richard Jerome and/or CST.
20.On or about July 2,2022,Respondent violated Section 2-11.1 (k)(2)of the Miami-
Dade County Conflict of Interest and Code of Ethics Ordinance when he failed to file,under oath,
an annual report by July 1,2022,indicating the source of his outside employment,the nature of
the work being done pursuant to the same,and any amount or types of money or other
consideration that he received from said outside employment for the year 2021.
21.On or about July 2,2023,Respondent violated Section 2-11.1(k)(2)of the Miami-
Dade County Conflict of Interest and Code of Ethics Ordinance when he failed to file,under oath,
an annual report by July 1,2023,indicating the source of his outside employment,the nature of
the work being done pursuant to the same,and any amount or types of money or other
consideration that he received from said outside employment for the year 2022.
Wherefore,JOSEPH CENTORINO,Inspector General for the City of Miami Beach,
requests the Miami-Dade County Commission on Ethics and Public Trust to enter an order against
Respondent,CLIFFORD SPARKS,finding him in violation of Section 2-11.I (g),of the Miami-
Page 4 of 5
Dade County Conflict of Interest and Code of Ethics Ordinance,and Section 2-11.1(k)2),of the
Miami-Dade County Conflict of Interest and Code of Ethics Ordinance,and ordering that
appropriate penalties be imposed as provided for in the Ordinance.
NOTARY AND VERIFIED STATEMENT
(Pursuant to§2-1074(a)(l),Miami-Dade County Code)
STATE OF FLORIDA
COUNTY OF MIAMI-DADE
Personally known to me and appeared before me,JOSEPH CENTORINO,whose signature
appears below,being first duly sworn,says that the allegations set forth in this Complaint are based
upon facts which have been sworn to as true by a material witness or witnesses and which if true
would constitute the offenses alleged and that thi Co plaint is instituted in good faith.
\l
I spector General,City of Miami Beach
1130 Washington Avenue
Miami Beach,FL 33316
(o~~.SWORN TO and SUBSCRIBED to before me this day or ND@l~ilk024,at Miami,
Miami-Dade County,Florida.
orAR PUBLIC
~onafly known to me
O produced identification and type ofidentification produced STEVEN •ROTSTEIN?'#wcouussowsoEXPRES:Auguet 28,2028
My Commission Expires:
Page 5 of 5
EXHIBIT 2
PROBABLE CAUSE MEMORANDUM
To:Miami-Dade County Commission on Ethics and Public Trust
From:Radia Turay,Advocate
Re:C24-44-11 (In re:Clifford Sparks)
Date:November 2024
I.Recommendation:
There is Probable Cause to believe that Clifford Sparks,(hereinafter "Respondent"),violated
Miami-Dade County Conflict of Interest and Code of Ethics Ordinance (hereinafter "Ethics
Code"),specifically Sect.2-11.1(g)entitled Exploitation ofofficial positionprohibited and Sect.
2-11.1(k)2)entitled Prohibition on Outside Employment.1
II.Background and Investigation:
The City of Miami Beach Office oflnspector General (hereinafter "City OIG")referred an ethics
violation allegation involving civilian employee Clifford Sparks (hereinafter "Respondent")at the
Miami Beach Police Department (hereinafter "MBPD")to the Miami Dade Commission on Ethics
and Public Trust (hereinafter "COE").Respondent has been employed by MBPD since 1996 and
was the first supervisor of the Criminal Analysis Unit (CAU),overseeing four analysts.His unit
provided data-driven support to detectives and other departments within MBPD.It was alleged
that the Respondent had outside employment with his business partner,Richard Jerome,and was
using his knowledge and experience with the MBPD,to develop a software program to help detect
crime patterns and enhance officer safety.Additionally,it was claimed that he exploited his official
position by having his subordinates test technical equipment for his outside business during City
work hours.The COE reviewed and investigated this allegation.
A review ofthe Respondent's personnel file revealed that he submitted a Request for Approval of
Outside Employment form in June 2019 for Vanguard Software Systems Inc.(hereinafter
"Vanguard"),identifying himself as the "President of a technology company."See Request for
1 Probable Cause exists where there are reasonably trustworthy facts and circumstances for the Miami-Dade County Commission
on Ethics and Public Trust ("COE")to conclude that the Respondent violated any County or municipal law or provision over
which the COE has jurisdiction.See Miami-Dade Commission on Ethics and Public Trust Rules of Procedure 4.12(b).
Page I of 16
Approval of Outside Employment 2019,attached hereto as "Exhibit A."A search on the Florida
Department of State Division of Corporations website (Sunbiz)showed that Vanguard became
effective on June 5,2019,but is currently listed as "inactive."See Sunbiz.org Profile for Vanguard
Software Systems Inc.,attached hereto as "Exhibit B."The electronic Articles of Incorporation
for Vanguard lists Respondent as the Registered Agent and Richard Jerome as an Officer/Director
of the company.Id.
Our search of the Respondent's name on the State of Florida Department of State Division of
Corporations website uncovered three additional businesses registered under his name:Sparks
Will Fly Enterprises,LLC,Sparks Will Fly Industries LLC,and Stroke of Luck LLC.See
Sunbiz.org Profile for Sparks Will Fly Enterprises,LLC,Sparks Will Fly Industries LLC,and
Stroke of Luck LLC.,attached hereto as "Exhibit C."
Sparks Will Fly Enterprises LLC-Sparks Will Fly Enterprises LLC,was created on November
29,2021,and was administratively dissolved by the State of Florida Department ofState Division
of Corporations on September 27,2024.Id.The Respondent is listed as the company's manager.
Id.
Sparks Will Fly Industries LLC -Sparks Will Fly Industries LLC,was created on March 28,
2005,and was administratively dissolved by the State of Florida Department of State Division of
Corporations on September 26,2008.Id.The Respondent is listed as the company's manager.
Id.
Stroke of Luck LLC -Stroke of Luck LLC,was created on December 9,2014,and was
administratively dissolved by the State of Florida Department of State Division of Corporations
on September 23,2016.Id.The Respondent is listed as one ofthe company's managers.Id
However,no requests for outside employment related to Sparks Will Fly Enterprises,LLC,Sparks
Will Fly Industries LLC,and Stroke of Luck LLC.were found in the Respondent's personnel file.
The investigation revealed that Respondent used his official position as supervisor of CAU to
introduce his business partner,Richard Jerome (hereinafter "Mr.Jerome"),to former MBPD
Police Chief Daniel Oates (hereinafter "Chief Oates")with the goal ofhaving his business partner
develop a software program for MBPD's record management system.The software program that
was to be developed would purportedly assist MBPD with detecting crime patterns and offer an
additional source of safety for officers.
As a result of Respondent's efforts,MBPD entered into two Letters of Understanding (hereinafter
LOU")with Crime Suppression Technologies (hereinafter "CST"),a company owned by the
Respondent's business partner,Mr.Jerome.See Letters of Understanding/Crime Suppression
Technologies Software Trial,attached as "Exhibit D."The LOUs state that MBPD will enter into
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a CST software trial period during which MBPD will gain insight on new strategies in preventing,
identifying,and suppressing crime.Id.The second of the two LOU's state that CST grants a
limited license to MBPD for use of its propriety software during a one (I)year trial period
commencing on February 3,2021,and ending on February 3,2022.Id.
An investigation showed that the Respondent communicated with Mr.Jerome about the software
and CST several times a week,including during City work hours.He served as a consultant/subject
matter expert for CST providing the analytical data required to develop the software for CST.He
also had his subordinates test the software during City work hours,despite it falling outside their
job responsibilities.
Additionally,in violation of the terms outlined in a LOU between MBPD and CST,Respondent
improperly purchased several pieces of technology equipment through MBPD for testing CST
software without adhering to appropriate procurement procedures.See MBPD Request and
Justification to Purchase,attached as "Exhibit E."Throughout this process,Respondent failed to
request outside employment for his work for CST and his other businesses as outside employment.
The Respondent also never filed any Outside Employment Statements with the City Clerk
disclosing the source of his outside employment,the nature of the work being done pursuant to
same,and any amount or types ofmoney or other consideration received by the employee for that
outside employment.
In addition to the above,the following interviews were conducted in furtherance of the COE
investigation.2
a.Amanda Regalado-Cisneros,_Crime Analysis Specialist,_Miami Beach Police
Department
Amanda Cisneros (hereinafter "Ms.Cisneros"),a Crime Analysis Specialist for MBPD,was
interviewed regarding this matter.She has been with MBPD for approximately four years,and her
responsibilities include monitoring crime trends and providing updated information specific to
crime by location.She explained that the data she analyzes is sourced from the department's record
management system,which aids in identifying crime trends.The Respondent was her supervisor.
Ms.Cisneros reported that Respondent frequently discussed a report-generating software he was
developing with his business partner.She indicated that the Respondent described the software as
having real-time crime-tracking capabilities and advocated for MBPD to adopt it through his
alleged company,CST.Ms.Cisneros stated that the Respondent mentioned that he was
experiencing pushback from the IT department and City Hall because he had to follow specific
protocols.She noted that "everyone"was aware of the software and Respondent's involvement,
as multiple meetings took place with the Respondent,his business partner "Rich"(Mr.Jerome),
2 Some actions performed by Respondent fell outside COE's three-year statute of limitations but are included for
context.
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the Police Chief,and the Deputy Police Chief Wayne Jones.
Ms.Cisneros stated that the Respondent would arrange for someone from their unit escort his
business partner,Mr.Jerome,to the MBPD Chief's office whenever there was a meeting.She
claimed that the Respondent would sometimes return from these meetings expressing frustration
over departmental resistance to the new software.She also noted that some individuals within the
department perceived Respondent's software project as a "get-rich-quick scheme."
Ms.Cisneros recounted that the Respondent directed her and her colleagues in the unit to test the
software,referring to these sessions as "field training."During these "training"sessions,the
Respondent instructed the unit,during work hours,to wear a "body-worn camera"strapped to their
chest and walk to the beach to verify the software's functionality.See Photograph of Analyst with
device,attached hereto as "Exhibit F."
Ms.Cisneros also recalled that the Respondent asked her to use her personal vehicle to test the
software.She stated that he instructed her to attach a cellphone device to her vehicle,which had a
GPS tracking system.The Respondent then directed them to different locations within the city to
test the software's functionality.Ms.Cisneros reported that he contacted her and her colleague,
Jacqueline Perez,on their personal cell phones during these tests to confirm whether the software
was operational.Ms.Cisneros indicated that she felt uncomfortable and was concerned for her
safety during these "field trainings,"but stated that she complied due to the Respondent's
supervisory role.
Ms.Cisneros added that the Respondent often used a small laptop to monitor the program's
progress,which he would connect to one of the four 85-inch monitors in their MBPD office.The
Respondent actively solicited staff feedback on the software's development.Ms.Cisneros stated
that she participated in these sessions because Respondent was her supervisor.She indicated that
the Respondent was eager for MBPD to adopt his software.She stated that the Respondent
indicated that they were developing the software at no cost to the department,however,his partner
eventually expected compensation for their work.
b.Jacqueline Perez,Crime Analysis Specialist,Miami Beach Police Department
Jacqueline Perez (hereinafter "Ms.Perez"),a Crime Analyst Specialist for MBPD,was
interviewed regarding this matter.Ms.Perez has served as an analyst for approximately four (4)
years.Her responsibilities include identifying risk factors and areas vulnerable to crime.The
Respondent served as her direct supervisor.
Ms.Perez stated that the Respondent informed her about a software program he and his business
partner were developing through his company,CST,with the objective of having MBPD
eventually purchase the program.She reported that the Respondent informed her unit that the
analysts would be tasked with testing the software to track its development.She recalled several
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instances where the Respondent instructed her and her colleagues to use tablets and cellular phones
for this purpose.
Ms.Perez recounted one instance where while working overtime for another unit,the Respondent
arrived at that department and directed her to wear the equipment and walk across the street to
Burger King to test the software.Ms.Perez stated that she felt uncomfortable conducting the test
late at night,especially while working overtime for another unit.She indicated that when she
expressed her concerns with the Respondent,he insisted that she proceed,which she did,given his
supervisory position.
Ms.Perez further recalled that the Respondent instructed her and a colleague to use a vehicle to
determine if the geo-mapping feature of the software was functioning.Ms.Perez explained that
two analysts utilized an MBPD city vehicle,while she and Ms.Cisneros were directed to use Ms.
Cisneros'personal vehicle.Despite finding the request unusual,Ms.Perez indicated that they
complied due to the Respondent's supervisory authority.
Ms.Perez also reported that the Respondent directed the entire unit to walk to the beach area
equipped with body cameras to test the software's functionality.See Exhibit F.She stated that
she and her colleagues discussed their discomfort with testing these devices,especially while
assigned to other duties and during City work hours.Ms.Perez noted that she did not believe the
department was informed that the Respondent was using analysts to conduct testing of CST's
software.She emphasized that she did not perceive the software testing as a formal directive from
the department,explaining that her unit typically received such directives directly from the Chiefs
office.In this case,however,no such directive had been communicated.
While Ms.Perez stated that she had never met the Respondent's business partner,she recalled a
few instances when her colleagues were asked to escort the Respondent's partner to the Chiefs
office.She also remembered overhearing the Respondent conversing with members of the IT
department,seeking additional data access to demonstrate the software's capabilities.
c.Antonella Castelo,Office Associate,Criminal_Investigation Unit,Miami Beach
Police Department
Antonella Castelo (hereinafter "Ms.Castelo"),an Office Associate for the Criminal Investigation
Department,was interviewed regarding this matter.She has held her position for three years and
is responsible for administrative tasks such as preparing payroll,processing and distributing
purchase requests,assisting in organizing training sessions,and serving as an assistant to the
Major.
Ms.Castelo explained that in March 2021,Respondent approached her to order equipment for his
unit.He requested that she bypass the chain of command and send the Request and Justification to
Purchase form (hereinafter "purchase form")directly to Police Chief Oates'office.See Miami
Beach Police Request and Justification to Purchase dated March 25,2021,attached hereto as
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"Exhibit E."Ms.Castelo stated that she explained to Respondent that the procedure for submitting
purchase requests had changed,and she could not circumvent the established process,which now
required the use of Docusign3.She confirmed that she processed the request through the
appropriate channels.
d.Daniel Morgalo,Major,Support Seryices,_Miami Beach Police Department
Major Daniel Margalo (hereinafter Major Morgalo")of the MBPD was interviewed regarding
this matter.He has been with MBPD for 28 years,and oversees all uniform patrol functions,
including officers responding to calls,specialized units,and accident investigations.In January
2021,he was promoted to Captain of the Criminal Investigations Unit,where he supervised
Respondent and the five analysts in CAU.He stated that the analysts were responsible for
compiling crime statistical data for the City,identifying crime patterns and trends using computer
software.
Major Margalo stated that there was a continuous push within the department to enhance
innovation,particularly within the CAU.He noted that a recurring challenge at the time was the
unit's limited resources for gathering information.Major Margalo explained that extracting data
from the outdated Computer-Aided Dispatch (CAD)system was challenging,and any upgrades
to improve the system came with significant costs.While he was aware of a broader search for
innovative solutions,he was not informed that the Respondent was specifically assigned to
address this issue.
Regarding the protocol for purchase forms,Major Margalo explained that when an employee in
his unit submitted a purchase form,it was expected to be routed to him,then to his supervisor,
and subsequently to either Chief Oates'office or the technical services unit,depending on the
nature of the items requested.If the purchase involved technology,the form needed to be
reviewed by the Information Technology Department (ITO)to ensure compatibility with existing
systems and approval.He stated that the March 2021 request to purchase form submitted by the
Respondent was not routed to him.
Major Margalo expressed surprise upon learning that analysts were testing what appeared to be
body-worn cameras.He recounted his involvement in the department's initial 2014 pilot
program,in which body-worn cameras provided by Axon Enterprise,Inc.(Axon)were deployed.
According to Major Margalo,body-worn cameras were issued exclusively to sworn officers,and
it was highly unusual for civilian employees to wear or test such equipment,as it was outside
theirjob descriptions.He added that any testing of new equipment or programs would require a
thorough vetting process,noting that having analysts conduct such tests would not have been
approved by the department.
3 Docusign is a document signing software that is used to manage electronic agreements with electronic
signatures.
Page 6 of 16
e.David De_La_Espriella.Major,Support Services Division,_Miami Beach Police
Department
Major David De La Espriella (hereinafter "Major De La Espriella")works for the Support
Services Division at MBPD.He has been with MBPD since 1996 and currently oversees the
administrative functions of the police department.Major De La Espriella briefly supervised the
Respondent in 2020 and confirmed that Respondent's role did not include responsibilities related
to software development.
He stated that all new technology adopted by MDPD requires vetting through the ITO and
confirmed that,as a crime analysis supervisor,Respondent would not have been involved in the
implementation of such programs.Major De La Espriella further emphasized that CAU analysts
should never have been involved in testing any products,as it fell outside theirjob responsibilities.
He expressed concerns regarding the Respondent's directive for analysts to use personal vehicles
for testing purposes,noting that this could expose MBPD to liability.
f.Eric Garcia,Captain_Tech Services Unit,Miami Beach Police Department
Captain Eric Garcia (hereinafter "Captain Garcia")works for the Technology Services division
at MBPD.He has been so employed for 23 years.Captain Garcia oversees all technological
systems used by officers,ensuring they have the necessary resources to perform their daily duties.
When asked about his involvement in pilot programs,Captain Garcia explained that his unit is
consulted on new devices or software purchases,although specific investigative departments may
sometimes work directly with vendors.He noted that MBPD has policies and procedures for
purchase requests,with employees completing an internal purchase form requiring finance
department approval and final routing to the Chiefs office.
Captain Garcia stated he was vaguely familiar with CST,which he understood to be a company
the Respondent was establishing with another individual.He recalled attending a meeting in the
Chiefs office when CST's software concept was introduced.CST offered crime analysis software
but did not have a fully developed product at the time,instead providing an open-ended contract
to program analytics based on MBPD's needs.He clarified that the arrangement with CST was
a service contract focused on programming and data analytics,not involving physical equipment.
Captain Garcia explained that when MBPD contracts with outside software providers,they
purchase only software services that integrate with existing equipment,eliminating the need for
additional hardware.He outlined the department's protocols for testing new software,which
include establishing a scope ofwork,timeframe,and evaluation period,with prior approval from
the IT department required for any installations or pilots.He stated he did not recall approving a
CST software pilot and was not involved in any final decisions to proceed,adding that he would
Page 7 of 16
have raised concerns if consulted on CST's proposal.
Captain Garcia expressed confusion over why the Respondent had his analysts test equipment,
noting that while analysts work on officer safety through data analysis,they do not conduct
fieldwork for such purposes.He was informed that the Respondent had also instructed an analyst
to use her personal vehicle for software testing,which Captain Garcia found perplexing,as
software testing should not require personal vehicles.He concluded that it was inappropriate for
the Respondent to have his subordinates test the software and that using city resources to develop
and test a private product was improper.
g.Wayne Jones,Deputy Chief,Miami Beach Police Department
Deputy Chief Wayne Jones (hereinafter "DC Jones"),who at the time of this incident was a
MBPD Deputy Chief,was interviewed regarding this matter.He has worked for MBPD for 27
years and at the time of the interview his duties included overseeing all aspects of the organization
including operations and the business office,which consists of recruitment,hiring and support
services.
DC Jones stated he has known the Respondent throughout his career at the department.He noted
that while their department is small enough that most staff know each other,he did not interact
with the Respondent daily.He stated that he did supervise the Respondent for about a year during
his time in the criminal investigation unit.
Regarding procurement policies for new technology,DC Jones explained that the ITO typically
reviews technology requests to ensure compatibility with existing systems.He added that,
depending on the type and cost of the purchase,a Request for Proposal may be issued to obtain
bids from different vendors.
When asked about CST,DC Jones explained that the department's databases were outdated,and
the idea was to partner with CST,allowing them to develop a program tailored to the department's
needs,using MBPD as a testing ground at no cost.He noted that this was not the department's
normal practice.DC Jones indicated that he was not sure why the department decided to proceed
with working with CST and mentioned that the introduction was made through the Respondent.
He explained that former Police Chief Daniel Oates had an "open door"policy and welcomed
feedback and ideas on improving the department.In this case,since the Respondent was the
supervisor and manager of CAU,he had insight into what was needed to enhance existing
systems.
DC Jones stated he was never under the impression that the Respondent and Mr.Jerome were
business partners,but rather that Mr.Jerome was presented as a friend of the Respondent who
worked in software engineering and would help develop the program.He indicated that his
4 On September I,2023,Wayne Jones assumed the role ofMBPD Police Chief.
Page 8 of 16
understanding was that CST would create software to manage data,such as records,arrest
numbers,crime trends,and hotspot locations,more efficiently.However,CST did not have a fully
developed product at the time.
When asked about equipment purchased for CST,DC Jones vaguely recalled approving a
purchase form for cell phones.He was shown a copy of the purchase form submitted by Mr.
Sparks but could not confirm if it was the same one,he signed.See Exhibit E.He acknowledged
that,at times,he may have approved forms without thoroughly reviewing them.
h.Richard Clements,Chief,_Miami Beach Police_Department
Police Chief Richard Clements (hereinafter "Chief Clements")of MBPD was interviewed
regarding this matter.Chief Clements has worked for the department for 33 years and,as chief,
he supervises the department of 434 officers,in addition to being the administrative and
operations employee in charge ofMBPD and an active member ofthe executive stafffor the City,
who reports directly to the City Manager.
Chief Clements described the department's procurement policies,noting that while some
purchases are managed internally,others require a more formal process,including a bidding
phase.For these more extensive procurements,a LOU is generally established at the outset to
outline guidelines,usage,and a trial period for evaluation.This helps ensure the company
understands the department's needs and can tailor their product accordingly.
Regarding the LOU between MBPD and CST for a software trial period,Chief Clements
explained that then-Chief Oates was focused on expanding the crime analysis unit to create a
more comprehensive,real-time database to track criminal activity by location.The goal was a
program that could provide officers with up-to-date information on crimes within specific areas.
Chief Clements explained that the plan was for CST to create a system that would automatically
extract data and organize it by geographic areas,assisting MBPD's crime analysis efforts.The
Respondent introduced Richard Jerome,a software engineer and friend,as the individual who
could help develop a prototype for these needs.Chief Clements stated that his role at the time,as
Deputy Chief,was to involve the procurement and legal departments to ensure CST's no-cost
services were appropriately documented via LOU.
Chief Clements noted that CST did not have a fully developed product initially;rather,they
discussed potential features tailored to MBPD's needs,with the intent of creating a real-time data
system for patrol units.He stated he was unaware that the Respondent ordered any equipment
through the department until he was informed of it during an unrelated Internal Affairs
investigation.Chief Clements upon learning of the equipment requested that the Respondent
return the three laptops that had been ordered,recalling they may have been intended to access
department data files.
Page 9 of 16
Chief Clements could not explain why a second LOU was signed in 2021 with CST but suggested
it may have involved modifications to the original proposal.He also noted that the Respondent,
as the CAU supervisor,was responsible for reporting software development progress to his
supervisor,Deputy Chief Wayne Jones.He stated that when he (Chief Clements)was promoted
to Chief,he delegated further oversight of the software's progress to DC Jones.
Chief Clements stated he was unaware ofMr.Sparks directing his subordinates to test equipment
or use personal vehicles for software testing.He emphasized that such activities fell outside the
LOU's original scope and that CAU personnel should not have been involved in that capacity.
i.Richard Jerome,RegisteredAgent/Qyner,_Crime Suppression Technologies,Inc
Mr.Jerome,the owner of CST,regarding this matter.Mr.Jerome manages software engineers at
UKG,an American multinational technology company He stated that he has known the
Respondent for approximately 37 years.
Mr.Jerome explained that in 2017,the Respondent approached him to discuss ideas for
developing new software for MBPD.The Respondent facilitated an initial meeting with MBPD,
which focused on creating a data recording system.Mr.Jerome indicated that after the initial
discussions with ChiefOates,he saw that there was a need for additional resources and assembled
a team of investors to develop the system.Mr.Jerome stated that the Respondent was not a
business partner or consultant but acted as a Subject Matter Expert (SME),providing MBPD-
specific insights to assist the development team better understand the department's needs.He
noted that Respondent played a role in providing an understanding ofthe customer,MBPD.
Mr.Jerome recounted that four months later,he met with Chief Oates again,to demonstrate the
system's versatility across devices such as watches,tablets,body cameras,and phones.After
reaching an understanding,both parties signed a LOU,with Mr.Jerome agreeing to develop the
software at no cost and with no guarantee of a purchase commitment from MBPD.Mr.Jerome
clarified that he never requested MBPD to purchase equipment for him,as he already possessed
necessary devices which he used during demonstrations with his own team.
Mr.Jerome stated that MBPD was responsible for testing the software and that,based on his
meetings with Chief Oates and discussions with Respondent,the department knew Respondent
was coordinating this testing with MBPD personnel.Mr.Jerome clarified,however,that he did
not use MBPD staff for testing,as he had his own team of business associates and developers
from Nashville,TN,for that purpose.He reported that he always brought his own devices and
team for demonstrations.
Mr.Jerome reported that his communication with MBPD waned because of the pandemic and an
unrelated incident that involved Respondent.He stated that he was never formally notified that
Page 10 of 16
MBPD was not moving forward with his product at MBPD.
j.Clifford Sparks[II,Crime Analysis Supervisor,Miami Beach Police Department
The Respondent provided a sworn,recorded statement regarding this matter.He confirmed that
he has worked for MBPD since 1996 and that he was a supervisor for CAU where he supervised
four analysts.He stated that CAU supports detectives and other units in the department by
providing data-driven insights.
The Respondent reported that he had engaged in various business ventures over the years,none of
which generated income.His most recent venture,Sparks Will Fly Enterprises LLC,was formed
in 2021 as a holding company for his real estate interests.He indicated that he was also in the
early stages of developing scheduling software,with Mr.Jerome assisting as an "unofficial"
partner.The Respondent stated that he was personally funding the new project.The Respondent
recounted that he also had a prior venture,Vanguard,which ultimately did not succeed,and for
which he filed the necessary outside employment paperwork.
Regarding CST,Respondent denied any ownership interest in the company.He stated that his
connection with CST was through his childhood friend,Mr.Jerome.He explained that in either
2016 or 2017,he and Police Chief Oates had multiple conversations about ways of improving the
current crime analysis software.After exploring options,he reached out to Mr.Jerome,a software
engineer,and facilitated an introduction between Mr.Jerome and MBPD.He admitted that he
served as a consultant and a bridge between CST and MBPD,advising on law enforcement
requirements based on his expertise.
Respondent reported spending 15-20 hours weekly discussing the project with Mr.Jerome during
and outside work hours.He admitted that when Mr.Jerome experienced resistance from ITO
regarding the data he was requesting,he (the Respondent)provided Mr.Jerome crime statistics
directly from his unit.
The Respondent noted that although he was not compensated by Mr.Jerome as a consultant,he
acknowledged that there was the possibility of future compensation from Mr.Jerome if MBPD
purchased the software.
The 2019 LOU specified that all costs associated with the trial period would be CST's
responsibility,with no financial or contractual obligations on MBPD's part except for the LOU
terms.In 2021,the LOU was extended to February 3,2022.See Exhibit D.
The Respondent was shown a copy of the purchase form he submitted requesting two Surface Go
for Business in the amount of $1,313.46 and three Samsung Galaxy S21 5G unlocked phones
totaling $2,099.97.See Exhibit E.The justification for purchase provided read as follows:"provide
CST with testing equipment for software development to enhance officer safety and situational
Page 11 of 16
awareness."See Exhibit E.The Respondent explained that Mr.Jerome requested assistance in
acquiring these devices to test the software and help track its progress.Respondent admitted that
he bypassed the chain of command and brought the request directly to DC Jones for approval.
The Respondent admitted to using his subordinates to test the software during work hours,
connecting the Surface Go to office projectors to demonstrate progress and then relaying
observations to Mr.Jerome.He stated that he did not inform his superiors of this testing,which
was outside his team's duties.Additionally,he also admitted that he enlisted a detective in the
Human Trafficking Unit to assess the software's geo-mapping feature by using live data,violating
the LOU's terms without prior authorization.Respondent stated that the program ended as a result
of an Internal Affair's investigation and all of the devices he ordered were confiscated.See
Photograph of devices,attached hereto as "Exhibit G."
III.Applicable Law
Miami-Dade County Ethics Code,Section 2-11.1 (g),Exploitation of official position
prohibited,States:
No person included in the terms defined in Subsection (b)(I)through (6)
and (b)(13)shall use or attempt to use his or her official position to secure
privileges or exemptions for himself or herself or others except as may be
specifically permitted by other ordinances and resolutions previously
ordained or adopted or hereafter to be ordained or adopted by the Board of
County Commissioners.
See Miami-Dade County Ethics Code §2-11.1 (g).
Miami-Dade County Ethics Code,Section 2-11.1 (k),entitled,"Prohibition on outside
employment,"states in pertinent part:
All full-time County and municipal employees engaged in any outside
employment for any person,firm,corporation or entity other than Miami-
Dade County,or the respective municipality,or any of their agencies or
instrumentalities,shall file,under oath,an annual report indicating the
source of the outside employment,the nature of the work being done
pursuant to same and any amount or types of money or other consideration
received by the employee from said outside employment.Said County
employee's reports shall be filed with the supervisor of elections no later
than 12:00 noon on July 1st of each year,including the July 1st following
the last year that person held such employment.
See Miami-Dade County Ethics Code §2-11.1 (k)(2).
Page 12 of 16
JV.Analysis
Section 2-11.1 (a)of the Ethics Code provides that the Ethics Code sets minimum standards of
ethical conduct,and its provisions are applicable to all municipal governments within Miami-Dade
County,including the City of Miami Beach.The Respondent in this case was supervisor of CAU
for the MBPD.As an employee ofMBPD,he is a covered party pursuant to Section 2-11.1 (b)(6)
of the Ethics Code which applies to all other personnel employed by the County or municipal
governments within Miami-Dade County.
A.Exploitation of O[ficial Position Prohibited -Miami-Dade County Ethics Code,
Section 2-11.1(g)
Section (g)of the County Ethics Code prohibits municipal employees from using their official
positions to secure a special benefit for themselves or others.See Miami-Dade County Code,Sec.
2-11.1 (g).In this case,the Respondent exploited his official position by using his official position
as supervisor of CAU,and his access to crime data in Miami Beach to assist in developing crime
statistics software and by playing a key role in facilitating a business relationship between his
lifelong friend and associate,Mr.Jerome,and MBPD,creating a potential financial benefit for
himself.Ethical guidelines strictly prohibit any involvement by an employee in contracting
matters with entities tied to their financial interests,as this could compromise the employee's
impartiality and result in exploitation of their position See RQO 12-11;Administrative Order 7-1.
Respondent in his sworn statement admitted that he facilitated an introduction between his lifelong
friend,Mr.Jerome,and MBPD Police Chief Daniel Oates,in order to cultivate a business
relationship with MBPD,to influence the department's interest in developing and purchasing
CST's software.This connection enabled CST to attract investors,ultimately leading to an LOU
with MBPD that remained in effect until 2022.DC Jones explained that this was outside the
department's normal practice.DC Jones indicated that he was not sure why the department
decided to proceed with working with CST and mentioned that the Respondent facilitated the
introduction.
The Respondent in his statement admitted that he maintained close communication with Mr.
Jerome,devoting 15-20 hours per week,including City work hours,in furtherance of CST's
software development.He acknowledged that he used his role at MBPD to access and share crime
statistics with CST to aid their software development.He recounted that when Mr.Jerome
encountered resistance from the IT department in accessing certain data,Respondent directly
provided him with crime statistics from his unit.
Further,the Respondent used his official position to facilitate MBPD's purchase of multiple
devices for CST.In the purchase form submitted by the Respondent,he justified the purchase of
the devices as intended "to provide crime suppression technologies inc.(CST)with testing
Page 13 of 16
equipment for software development to enhance officer safety and situational awareness."See
Exhibit E.The Respondent in his statement explained that Mr.Jerome requested assistance in
acquiring these devices to test and track the software's progress.The Respondent admitted that he
bypassed the chain of command and brought the request directly to DC Jones for approval.
The Respondent also furthered CST's interests by assigning his subordinates to test the software
during work hours,connecting the Surface Go to office projectors to demonstrate progress,and
relaying feedback to Mr.Jerome.According to statements provided by Ms.Cisneros and Ms.
Perez,the Respondent informed their unit that the analysts would be tasked with testing the
software's progress.Ms.Perez recounted one instance while working overtime for another unit,
where the Respondent arrived at the department and directed her to wear the equipment and walk
across the street to Burger King to test the software.Ms.Cisneros recalled being directed to use
her personal vehicle to evaluate the geo-mapping feature of the software.They also reported that
the Respondent directed the entire unit to walk to the beach area equipped with body-worn cameras
to test the software's functionality.See Exhibit F.Both analysts reported that,although they found
the requests unusual,they complied due to the Respondent's supervisory role.The Respondent
admitted that he did not inform his superiors of this testing,which was outside his team's City
duties.
It is a basic tenet of ethics that an employee cannot exploit their official position for the benefit of
themselves and others.In this case,Respondents utilized his official position for the benefit of
himself and his lifelong friend and associate,Mr.Jerome,and CST.All of his actions were done
for the potential financial gain from CST should MBPD purchase the software that CST was
developing.The Respondent in his statement admitted that there was the possibility that he would
receive future compensation from Mr.Jerome if MBPD purchased the software.Consequently,
the Respondent violated Section (g)of the Ethics Code,by exploiting his official position.
B.Prohibition on Outside Employment -Miami-Dade County Ethics Code,Section
2-11.J(k)(2)
Outside employment is considered any non-municipal employment or business relationship in
which the municipal employee provides a personal service to the non-municipal entity that is
compensated or customarily compensated.See RQO 17-03 (citing RQO 16-01).Municipal
employees are considered to be engaging in outside employment when they are running a business
whether incorporated or not and regardless of whether it is generating any income,including
running an internet-based business.See RQO 16-0 I.
Pursuant to Miami Dade Code Section 2-11,a municipal employee may accept outside
employment provided that it is not contrary,detrimental,or adverse to the interests of the
municipality;that the employee does not use municipal time,materials,or resources to perform
the outside employment;and that the employee first obtains written approval from the head ofthe
department,where the employee is assigned,before engaging in any outside employment.See
COE Outside employment Guidelines dated May 29,2019;Administrative Order 7-1;and County
Page 14 of 16
Procedure 403.Permission for outside employment must be requested annually,even in cases
where the type ofoutside employment has not changed.5
Additionally,pursuant to Section 2-11.1 (k)(2)ofthe Ethics Code,full-time municipal employees
who engage in any outside employment during the preceding year for any person,firm,
corporation,or entity other than their government employment must file a statement that discloses
the source of the outside employment,the nature of the work being done pursuant to same and
any amount or types of money or other consideration received by the employee for that outside
employment.See Miami-Dade Code §2-11.1 (k)(2);RQO 17-03 and RQO 16-01.The disclosure
of the money or compensation received from outside employment is filed on an Outside
Employment Statement.Full-time City of Miami Beach employees,including MBPD employees,
must file the Outside Employment Statement with the City Clerk by July I st ofeach year.
The Respondent has been employed full-time at MBPD since 1996.Having filed the necessary
outside employment paperwork for his business Vanguard,the Respondent was aware of his
obligations under the Ethics Code.However,despite this knowledge,he did not submit filings
for his other business,Sparks Will Fly Enterprises,which he established in 2021,and which
remained active until September 2024.See Exhibit C.
Importantly,the Respondent in his sworn statement,acknowledged acting as a consultant to CST.
He recounted spending 15-20 hours weekly working on CST's software development.Mr.
Jerome,the owner of CST,described the Respondent as a Subject Matter Expert contributing to
the software's development.While the Respondent stated that he was unpaid by CST,he
indicated that he would be compensated if MBPD ultimately purchased the software.The
Respondent's role as a consultant and a subject matter expert constitutes work that would typically
be paid,and thus necessitating the filing of Outside Employment Statements.See RQO 17-03
(citing RQO 16-0 I).Respondent was required to indicate the source ofany outside employment,
the nature of the work being done,and the amount and types of money or other consideration he
received from his outside employment,none ofwhich was done by Respondent.See Miami-Dade
County Ethics Code§2-11.l(k)(2);RQO 17-03;RQO 16-01.
Therefore,the Respondent violated Section (k)(2)of the Ethics Code,by failing to file an Outside
Employment Statement by July I,2022 and July I,2023,to disclose the source of his outside
employment,the nature of the work being done pursuant to same,and any amount or types of
money or other consideration received by the employee for that outside employment during the
tax years 2021 and 2022 respectively.
Miami-Dade Code 2-1I,Administrative order 7-1,and Procedure 40 I,are not within the jurisdiction of the Ethics Commission,
as they are not contained in the Ethics Code and/or any other ethics ordinance that this Commission enforces.
Page 15 of 16
V.Conclusion
Accordingly,based on the investigation conducted,interviews,and supporting documentation,
Probable Cause exists to conclude that Respondent,Clifford Sparks,violated Section 2-
11.1 (k)(2),"Prohibition on Outside Employment,"Section 2-11.1 (g)and "Exploitation ofOfficial
Position,"of the Ethics Code.
Page 16 of 16
MI +IBEACH
CITY OF MIAMI BEACH
REQUEST FOR APPROVAL OF OUTSIDE EMPLOYMENT
TO BE COMPLETED BY EMPLOYEE -City of Miami Beach employees may accept outside employment as long as
the employment is not contrary,detrimental or adverse to the interests of the City,and as long as no City time,equipment or material is used.
This form must be completed and approved prior to beginning any outside employment.Requests for approval of
outside employment must be made on a yearly basis (even if for the same outside employment that had beenpreviouslyapproved).
City employees engaging in outside employment must also file an "Outside Employment Statement"form with the
Office of the City Clerk by July 1"of each year,in accordance with Section 2-11.1(k)(2)of the Miami-Dade CountyCode.
INFORMATION REGARDING CITY OF MIAMI BEACH EMPLOYEE
EMPLOYEE'S NAME:LASTNAME,FIRST NAME,MIDDLE NAME:EMPLOYEE ID NUMBER:
Sparks,Clifford 15667
JOBTITLE:HOME TELEPHONE NUMBER:
Crime Analyst Manager (305)431-0642
DEPARTMENT/DIVISION:WORK TELEPHONENUMBER:
Miami Beach Police Department/CID (305)673-7776 Ext.25061
SUPERVISOR'S NAME:CELLULARTELEPHONE NUMBER:
Lt.Greg Baldwin (305)546-8377
NORMALWORK DAYSANDTIMES:
Monday -Thursday 0700 -1700
INFORMATION REGARDING OUTSIDE EMPLOYMENT
NAME OF BUSINESS,ORGANIZATION OR INDIVIDUAL HIRINGCMB EMPLOYEE:
Vanguard Software Systems Inc.
ADDRESS OF OUTSIDE EMPLOYER:
9730 SW 13 St.Pembroke Pines,Fl.33025
TELEPHONE NUMBER:
(305)431-0642
JOB TITLE THAT CMB EMPLOYEE WILL HOLD:
President
NAME OF OUTSIDE EMPLOYMENTSUPERVISOR:
NIA
NORMAL WORK DAYS AND TIMES:
Saturday -Sunday 0800 -1800
DESCRIPTION OF DUTIES:
President of a technology company
WHAT DUTIESMIGHTBE A CONFLICTOF INTEREST WITH YOURCMB POSITION?
None
WILL YOURPROPOSED OUTSIDE EMPLOYER RELEASEYOUIFANDWHENYOU ARE CALLED FOR EMERGENCYSERVICEBYTHECITY?
YES ONO
This form has 2 pages-be sure to complete both pages.
Employee signature required on page 2.
3 JUN 27 TH ;:3,
CITY OF MIAMI BEACH
REQUEST FOR APPROVAL OF OUTSIDE EMPLOYMENT·CONTINUED
PAGE 2 of 2
By signing below,I certify that all of the information given on page one (1)of this document is true,accurate,and
complete to the best of my knowledge.I understand that all information is subject to investigation and that falsification,
omission,or misrepresentation is sufficient cause for disciplinary action,up to and including termination.I also
understand that I am responsible for informing my supervisor in writing if any information about my outside employment
changes,especially if there arises any possible conflict of interest.Failure to do so may lead to disciplinary action,
including termination of employment with the City of Miami Beach.This request for approval of outside employment will
be made on a yearly basis.
EMPLOYEE NAME.
Clifford Sparks 111
EMPLOYEE IDNUMBER:
15667
DATE.6/20/2019
TO BE COMPLETED BY EMPLOYEE'S SUPERVISOR,DIVISION DIRECTOR,DEPARTMENT DIRECTOR,
ASSISTANT CITY MANAGER AND CITY MANAGER
NAME OF SUPERVISORLT.b»
NAMEOFD TOR
ECTOR
ASSISTANTCITY MANAGER
cay9es
T((o
PLEASE CIRCLEONE:
APPROVED DISAPPROVED
PLEASE CIRCLE ONE:
APPROVED DISAPPROVED
SUPERVlS NATURE &DATE.'
If you have any questions regarding outside employment,please contact the Human Resources Department at
305.673.7524.
M:\$CMB\HUMARESO\OUTSIDE EMPLOYMENT Rvised 05162018.d0cx
2/20/24,10.15 AM Detail by Officer/Registered Agent Name
DIVISION OF CORPORATIONS
Department of State /Dyisign of oporatons l Search_Fgcorgs I Sgarch_by_officer/Registered Agent Name l
Detail by Officer/Registered Agent Name
Florida Profit Corporation
VANGUARD SOFTWARE SYSTEMS INC.
Filing_Information
Document Number
FEI/EIN Number
Date Filed
Effective Date
State
Status
Last Event
Event Date Filed
Event Effective Date
Principal Address
P19000049268
NONE
06/10/2019
06/05/2019
FL
INACTIVE
ADMIN DISSOLUTION FOR ANNUAL REPORT
09/25/2020
NONE
9730 SW13 ST.
PEMBROKE PINES,FL 33025
Mailing Address
9730 SW13 ST.
PEMBROKE PINES,FL 33025
Registered AgentName &Address
SPARKS,CLIFFORD,Ill
9730 SW 13 ST.
PEMBROKE PINES,FL 33025
Officer/Director Detail
Name &Address
Title P
SPARKS,CLIFFORD,Ill
9730 SW13 ST.
PEMBROKE PINES,FL 33025
Title P
JEROME,RICHARD H
https://search.sunbiz.org/lnquiry/CorporationSearch/SearchResultDetail?inquirytype=OfficerRegisteredAgentName&directionType=lnitial&searchNam..1 /2
2/20/24,1 0:15 AM
6212 FL 7
COCONUT CREEK,FL 33073
Annual Reports
No Annual Reports Filed
Document lmages
Detail by Officer/Registered Agent Name
06/10/2019 --Domestic Profit View image in PDF format
+I a t t t r t
https://search.sunbiz.org/lnquiry/CorporationSearch/SearchResultDetail?inquirytype=OfficerRegisteredAgentName&directionType=lnitial&searchNam..2/2
2/20/24,10:15 AM Detail by Officer/Registered Agent Name
DIVISION OF CORPORATIONS
/Io of
C09PATIO
an oiftiu!itate of Florida website
Department of State I Diyision ofCorporations l Search Records I Search by officer/Registered Agent Name I
Detail by Officer/Registered Agent Name
Florida Limited Liability Company
SPARKS WILL FLY ENTERPRISES LLC
Filing Information
Document Number
FEI/EIN Number
Date Filed
Effective Date
State
Status
Principal Address
L21000504592
87-3739227
11/29/2021
11/27/2021
FL
ACTIVE
2114 N.FLAMINGO ROAD
640
PEMBROKE PINES,FL 33028
Changed:08/12/2023
Mailing Address
2114 N.FLAMINGO ROAD
640
PEMBROKE PINES,FL 33028
Changed:08/12/2023
Registered Agent Name &Address
SPARKS,CLIFFORD,Ill
2114 N.FLAMINGO ROAD
640
PEMBROKE PINES,FL 33028
Address Changed:08/12/2023
Authorized Person(s)Detail
Name &Address
Title MGR
SPARKS,CLIFFORD,Ill
https://search.sunbiz.org/lnquiry/CorporationSearch/SearchResultDetail?inquirytype=OfficerRegisteredAgentName&directionType=lnitial&searchNam...1/2
2/20/24,10:15 AM
2114 N.FLAMINGO ROAD
640
PEMBROKE PINES,FL 33028
Detail by Officer/Registered Agent Name
Annual Reports
Report Year
2022
2023
2023
Filed Date
04/30/2022
04/29/2023
08/12/2023
Document Images
08/12/2023 -AMENDEDANNUAL REPORTI View image in PDF formatH;94/29/2023--ANNUAL REPORT View image in PDF format
04/30/2022 -ANNUAL REPORT View image in PDF format
View image in PDF format
Fluids Department at 5tate,Div4ston of Corp@rat10n
https://search.sunbiz.org/inquiry/CorporationSearch/SearchResultDetail?inquirytype=OfficerRegisteredAgentName&directionType=Initial&searchNam...2/2
11/29/2021 --Florida Limited Liability
10/29/24,3:39 PM Detail by Officer/Registered Agent Name
DIVISION OF CORPORATIONS
Department ofState I iyision of Corporations I Search Records I Searchbyofficer/RegisteredAgent Name I
Detail by Officer/Registered Agent Name
Florida Limited Liability Company
SPARKS WILL FLY INDUSTRIES LLC
Filing _Information
Document Number
FEI/EIN Number
Date Filed
State
Status
Last Event
Event Date Filed
Event Effective Date
Principal Address
L05000031598
APPLIED FOR
03/28/2005
FL
INACTIVE
ADMIN DISSOLUTION FOR ANNUAL REPORT
09/26/2008
NONE
16821 N.W.20TH AVE
MIAMI GARDENS,FL 33056
Mailing Address
16821 N.W.20TH AVE
MIAMI GARDENS,FL 33056
Registered Agent Name &Address
SPARKS,CLIFFORD Ill
16821 N.W.20TH AVE
MIAMI GARDENS,FL 33056
Authorized Person(s)Detail
Name &Address
Title MGR
SPARKS,CLIFFORD Ill
16821 N.W.20TH AVE
MIAMI GARDENS,FL 33056
Annual Reports
Report Year
2006
2007
Filed Date
04/30/2006
04/29/2007
https://search.sunbiz.org/lnquiry/CorporationSearch/SearchResultDetail?inquirytype=OfficerRegisteredAgentName&directionType=lnitial&searchName...1/2
10/29/24,3:39 PM
Document Images
04/29/2007 --ANNUAL_REPORT
04/30/2006 --ANNUALREPORT
93/28/2005 --Florida Limited Liabilites
Detail by Officer/Registered Agent Name
vewimasein PFformat]
Viewimage in PDF format [
View image in PDF format [
Frida Department of state,Division ofCorporations
https://search.sunbiz.org/lnquiry/CorporationSearch/SearchResultDetail?inquiry1ype=OfficerRegisteredAgentName&directionType=lnitial&searchName...2/2
10/29/24,3:38 PM Detail by Officer/Registered Agent Name
DIVISION OF CORPORATIONS
Department of State I Diyision ofCorporations I Search Records l Search byOfficer/Registered Agent Name l
Detail by Officer/Registered Agent Name
Florida Limited Liability Company
STROKE OF LUCK LLC
Filing Information
Document Number
FEI/EIN Number
Date Filed
Effective Date
State
Status
Last Event
Event Date Filed
Event Effective Date
Principal Address
L14000195522
NONE
12/29/2014
01/01/2015
FL
INACTIVE
ADMIN DISSOLUTION FOR ANNUAL REPORT
09/23/2016
NONE
1521 ALTON RD.
807
MIAMI BEACH,FL 33139
Mailing Address
1521 ALTON RD.
807
MIAMI BEACH,FL 33139
Registered Agent Name &Address
SPARKS,CLIFFORD
1521 ALTON RD.
807
MIAMI BEACH,FL 33139
Authorized Person(s)Detail
Name &Address
Title MGR
SPARKS,CLIFFORD,Ill
1521 ALTON RD.#807
MIAMI BEACH,FL33139
Title MGR
hllps://search.sunbiz.orgllnquiry/CorporationSearch/SearchResultDetail?inquiry1ype=OfficerRegisteredAgentName&directionType=lnitial&searchName...112
10/29/24,3:38 PM
GABRIEL,CASSANDRA T
1521 ALTON RD.#807
MIAMI BEACH,FL 33139
Annual Reports
No Annual Reports Filed
Document Images
12/29/2014 --Florida Limited Liability
Detail by Officer/Registered Agent Name
View image in PDF format
Frida (eptrentof State,ivision f Corporations
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r/L·R·I·I·E
5LUFFREE5IDITTECHNOLOGIES
April 30,2019
Chief Daniel Oates
Miami Beach Police Department
1100 Washington Avenue
Miami Beach,FL 33139
RE:Letter of Understanding/Crime Suppression Technologies Software Trial
Dear Deputy Chief Clements:
Crime Suppression Technologies (CST)is pleased to offer the Miami Beach Police
Department (MBPD)the opportunity to enter into this CST software trial period.CST is
confident that we will mutually benefit from this trial period by receiving constructive feedback
from MBPD and MBPD gaining insight on new strategies in preventing,identifying,and
suppressing crime.
This Letter of Understanding (LOU)outlines the general terms and understanding of both
parties during this software trial period:
•By way of this CST software trial LOU,CST hereby grants a limited license MBPD
for use of its proprietary software during a six (6)month trial period commencing
on DA sr ,2019 and ending at 11:59pm on QAbg 3+$T
2019;\
•All costs associated with this software trial period shall be borne solely by CST;
MBPD shall have no contractual,financial,or any form of commitment in connection
with this software trial period except for the terms in this LOU;
•CST will install the software on a standalone desktop PC identified and provided by
MBPD;the desktop PC shall have an operating system,memory,and appropriate
storage capacity to effectively run CST software;
•By virtue of CST software being installed on an MBPD-supplied standalone desktop
PC,CST certifies,represents and warrants that its software is not being installed in a
'live environment'that touches,points,or extrapolates data from any software
applications such as,but not limited to,NCIC/FCIC,D.A.V.I.D.and/or DHSMV,Tyler
suite of products including New World applications,or any CJIS supported
applications;
•This LOU does not preclude CST software from accessing any public domain
resources such as open network,web-based cams and/or other public domain web-
based applications-all in a standalone environment;
•MBPD understands that the CST software trial period can be extended by written
agreement of the parties;and,that the install of any additional CST software
modules may require a more formal agreement amongst the parties.
3111N.UNIVERSITYDRIVE,#402,CORAL SPRINGS,FL33076 •954.800.8016·WW.CRIMESUPPRESSIONTECH.COM
MBPD CST Software Trial
Letter ofUnderstanding
Page 2 of2
CST is excited to showcase its software application and modules to MBPD and we are
looking forward to promptly starting this trial period.If this Letter of Understanding meets
with your understanding of our conversations,please sign a copy of this letter and return it
to CST offices.
If you have any questions and/or amendments to this LOU,please feel free to contact
CST.
Sincerely,
Crime Suppression Technologies,Inc.
Z;:7
For Miami Beach Police Department
Kaeo coo-r
[Print Name]
3111N.UNIVERSITY DRIVE,#402,CORAL SPRINGS,FL 33076 •954.800.8016 •WWW.CRIMESUPPRESSIONTECH.COM
February 3,2021
Chief Richard Clements
Miami Beach Police Department
1100 Washington Avenue
Miami Beach,FL 33139
RE:Letter of Understanding/Crime Suppression Technologies Software Trial
Dear Chief Clements:
Crime Suppression Technologies (CST)Is pleased to offer the Miami Beach Police
Department (MBPD)the opportunity to enter into this CST software trial period.CST is
confident that we will mutually benefit from this trial period by receiving constructive feedback
from MBPD and MBPD gaining insight on new strategies In preventing,identifying,and
suppressing crime.
This Letter of Understanding (LOU)outlines the general terms and understanding of both
parties during this software trial period:
•By way of this CST software trial LOU,CST hereby grants a limited license MBPD
for use of its proprietary software during a one (1)year trial period commencing on
February 3,2021 and ending at 11 :59pm on February 3,2022;
•All costs associated with this software trial period shall be borne solely by CST;
MBPD shall have no contractual,financial,or any form of commitment in connection
with this software trial period except for the terms in this LOU;
•CST will install the software on a standalone desktop PC identified and provided by
MBPD;the desktop PC shall have an operating system,memory,and appropriate
storage capacity to effectively run CST software;
•By virtue of CST software being installed on an MBPD-supplied standalone desktop
PC,CST certifies,represents and warrants that its software is not being installed in a
'live environment'that touches,points,or extrapolates data from any software
applications such as,but not limited to,NCIC/FCIC,D.A.V.I.D.and/or DHSMV,Tyler
suite of products including New World applications,or any CJIS supported
applications;
•This LOU does not preclude CST software from accessing any public domain
resources such as open network,web-based cams and/or other public domain web-
based applications-all in a standalone environment;
•MBPD understands that the CST software trial period can be extended by written
agreement of the parties;and,that the install of any additional CST software
modules may require a more formal agreement amongst the parties.
MBPD CST Software Trial
Letter of UnderstandingPage2of2
CST is excited to showcase its software application and modules to MBPD and we are
looking forward to promptly starting this trial period.If this Letter of Understanding meets
with your understanding of our conversations,please sign a copy of this letter and return it
to CST offices.
If you have any questions and/or amendments to this LOU,please feel free to contact
CST.
Sincerely,
Crime Suppression Technologies,Inc.
Ee
For Miami Beach Police DepartmentLaa.n Ce.s
[Print Name)
MIAM'BEACHPOL.SGIEe Request and Justification to Purchase
Date:I Division:I Section:
03/26/2021 CHIEF'S OFFICE CHIEF'S OFFICE
Approx.
#Qty Description (Include make,model,possible vendor,etc.Use additional sheet if needed)Cost
Surface Go for Business $1,313.46
01 02 128GB /Intel 4415Y /8GB RAM/LTE@ $656.73 each
Samsung Galaxy S2 l SG Unlocked/8k Video/64MP High Res $2,099.97
02 03 128GB@ $699.99 each
Total $3,413.43
Suggested Vendor:CDW-G □□
Sole Source Provider?y N
Vendor Contact:(Name/Address/Phone Number}*If yes,please provide Sole Source letter.
Justification/Purpose:
PROVIDE CRIME SUPPRESSION TECHNOLOGIESINC.(CST)WITH TESTINGEQUIPMENTFOR SOFTWARE DEVELOPMENT TOENHANCE
OFFICER SAFETY AND SITUATIONALAWARENESS.
Requested By:Date:All Purchases Check One
Div.Commander:Date:Require Approval STATE CONTRACT?By The Chief of □□Chief of Police:Date:Police y N
Financial Management:Date:Funding:If Yes,Contract #:
Financial Management Unit Actions or Notes:
BUDGET CODE:0111140342
F:Poli/$Bud/Mauvett/Forms/Request and Justifications to Purchase
EXHIBIT 3
Docusign Envelope ID:6788CC8E-0D2C-41F4-B2F5-0DD5CE5FDD38
MIAMI-DADE COUNTY COMMISSION ON ETHICS AND PUBLIC TRUST
IN RE:
CLIFFORD SPARKS
RESPONDENT
I-------------------
PUBLIC REPORT AND FINAL ORDER
C 24-44-11
The Inspector General for the City of Miami Beach (hereinafter "the OIG")filed
a Complaint in this matter against Respondent,Clifford Sparks (hereinafter,
"Respondent"),for violating Section 2-11.1(k)2)of the Miami-Dade County Conflict of
Interest and Code of Ethics ordinance entitled "Prohibition on outside employment,"and
Section 2-11.1 (g),entitled "Exploitation ofofficialposition prohibited."
The Respondent is a full-time employee of the City of Miami Beach Police
Department (hereinafter "MBPD").He previously served as the supervisor of MBPD's
Criminal Analysis Unit (hereinafter "CAU").An investigation showed that the
Respondent,in his capacity as the supervisor of CAU,facilitated the introduction of his
lifelong friend,Richard Jerome,a software engineer,and then Chief ofPolice for MBPD,
Daniel Oates,with the goal of having Mr.Jerome develop a software program for
MBPD's record management system.As a result of the Respondent's introduction,the
MBPD entered into two Letters of Understanding (hearing after "LOUs")with Mr.
Jerome's company,Crime Suppression Technologies,Inc.(hereinafter "CST").
Additionally,the investigation revealed that the Respondent acted as a consultant
and/or subject matter expert for CST during the pendency of the LOUs.He maintained
frequent communication with Mr.Jerome,dedicating 15-20 hours per week,including
during city work hours,in furtherance of CST's software development.When Mr.
Jerome faced opposition from MBPD IT unit,the Respondent provided CST with crime
statistics directly from his unit.The Respondent used his official position to facilitate
MBPD's purchase of multiple devices for CST and directed his subordinates to test
CST's software during city work hours,outside the scope of their MBPD responsibilities.
C 24-44-1 I In re:Clifford Sparks Final Order
Docusign Envelope ID:6788CC8E-0O2C-41 F4-B2F5-0DO5CE5FDD38
In his statement to this agency,the Respondent admitted that he anticipated receiving
future compensation from Mr.Jerome if MBPD ultimately purchased the software.
Further,the investigation showed that the Respondent owned and served as the
registered agent for Sparks Will Fly Enterprises LLC,a Florida for-profit corporation.
However,the Respondent failed to file the required annual sworn Outside Employment
Statement indicating the source of his outside employment,the nature of the work being
done,and the amount and types of money or other consideration that he received from
his outside employment,for tax years 2021 and 2022.
The Respondent stipulated to Probable Cause.
On November 13,2024,the Miami-Dade County Commission on Ethics and
Public Trust,by a unanimous vote,accepted the Respondent's Stipulation to Probable
Cause regarding the facts underlying the Complaint and ratified the Settlement
Agreement.Pursuant to the Settlement Agreement,the Commission accepted the
Respondent's decision Not to Contest the allegations in the Complaint,ordered the
Respondent to pay a total fine of $1,500.00 (five hundred dollars for Count One,and one
thousand dollars for Count Two);ordered the Respondent to accept a Letter oflnstruction;
and dismissed Count Three of the Complaint.
Wherefore it is:
ORDERED AND ADJUDGED that Complaint C24-44-11 against Respondent
Clifford Sparks is hereby concluded.
DONE AND ORDERED by the Miami-Dade County Commission on Ethics &
Public Trust in public session on this [3%day or Alard142024.
MIAMI-DADE COUNTY COMMISSION ON
ETHICS &PUBLIC TRUST
By:
I.OotuSlgntdby.u±tee
Dr.Judith Bernier
Chair 11/25/2024Signedon.
C24-44-11 In re:Clifford Sparks Final Order