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C7O-Execute MOU South Florida Joint Terrorism Task ForceCOMMISSION ITEM SUMMARY Condensed Title: A resolution of the Mayor and City Commission of the City of Miami Beach, Florida, authorizing the City Manager and City Clerk to execute a Memorandum of Understanding between the City of Miami Beach, on behalf of the Miami Beach Police Department and the Federal Bureau of lnvestigation, South Florida Joint Terrorism Task Force for the purpose of the prevention, preemption, deterrence and investigation of terrorist acts and apprehend individuals who may commit or plan to commit such acts. lntended Outcome Maintain crime rates at or below national trends. Supporting Data (Surveys, Environmental Scan, etc.): According to the Center For Research and )ublic Policy, and Business Residential Satisfaction Survey of City of Miami Beach residents in 2009, ndicated that their three top most important areas of for the City of Miami Beach to address in an effort to mprove public safety throughout the City is Preventing Cnme 44.9o/o, Enforcing Traffic Laws 36.1% and ncreasino Visibilitv of Police in Neiohborhoods 32.4o/o. lssue: Shall the Commission adopt this Resolution? Item Summary/Recommendation : The Miami Division of the Federal Bureau of lnvestigation (FBl) has established the South Florida Joint Terrorism Task Force (JTTF) ('Task Force") for the purpose of prevention, preemption, deterrence and investigation of terrorist acts, and apprehend individuals who may commit or plan to commit such acts. This Task Force will enhance the effectiveness of Federal, State and local law enforcement resources through a well coordinated initiative seeking the most effective investigative and prosecutive avenues and to facilitate the sharing of FBI information with the intelligence and law enforcement communities to protect the United States and the City of Miami Beach against threats to our national security, including international terrrorism. ln an effort to support the JTTF, the Miami Beach Police Department (MBPD) has been asked by the FBI to participate and execute a Memorandum of Understanding between the FBI and the City of Miami Beach on behalf of the MBPD. As a result, a Detective from the Criminal lnvestigations Division will be assigned to the JTTF to work in conjunction with their personnel in identifying, locating and apprehending individuals who commit these crimes in the City of Miami Beach and South Florida. Participation in the JTTF will benefit the City of Miami Beach and the MBPD because of access to increased investigative resources and capabilities. Pursuant to the Memorandum of Understanding the FBI has agreed to provide access to a vehicle; reimburse the City of Miami Beach for overtime expenses, travel, and investigative expenses incurred by the MBPD Detective in connection with JTTF investigations pending available funding. Upon the signatures of all the parties to the Memorandum of Understanding, the Detective can participate in the JTTF for the duration of the Task Force unless either the FBI or the Citv of Miami Beach should decide to withdraw. NA Financial lnformation: Source of Funds: Amount Account 1 2 3 OBPI Total Financial lmpact Summary: NA N/A Department Director Assistant Gity Manager Qity Manager Daniel J. Oates, Chiefffi'[) Miami Beach Police Ddou rn AGEN TEM caoMIAMIBTACHoArE ?/0'/q303 MIAMIBEACH City of Miomi Beoch, 1700 Conveniion Cenler Drive, Miomi Beoch, Florido 33139, www.miomibeochfl.gov COMMISSION MEMORANDUM the City ITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA, AUTHORIZING THE CITY MANAGER AND CITY CLERK TO EXECUTE A MEMORANDUM OF UNDERSTANDING BETWEEN THE CITY OF MIAMI BEACH, ON BEHALF OF THE MIAMI BEACH POLICE DEPARTMENT, AND THE FEDERAL BUREAU OF INVESTIGATION, SOUTH FLORIDAJOINTTERRORISM TASK FORCE FOR THE PURPOSE OF THE PREVENTION, PREEMPTION, DETERRENCE AND INVESTIGATION OF TERRORIST ACTS AND APPREHEND INDIVIDUALS WHO MAY COMMIT OR PLAN TO COMMIT SUCH ACTS. ADM IN ISTRATION RECOM MEN DATION Approve the Resolution. ANALYSIS The Miami Division of the Federal Bureau of lnvestigation (FBl) has established the South Florida Joint Terrorism Task Force (JTTF) ("Task Force") for the purpose of prevention, preemption, deterrence and investigation of terrorist acts; and apprehend individuals who may commit or plan to commit such acts. This Task Force will enhance the effectiveness of Federal, State and local law enforcement resources through a well-coordinated initiative seeking the most effective investigative and prospective avenues and to facilitate the sharing of FBI information with the intelligence and law enforcement communities to protect the United States and the City of Miami Beach against threats to our national security, including international terrorism. ln an effort to support the JTTF, the Miami Beach Police Department (MBPD) has been asked bythe FBI to participate and execute a Memorandum of Understanding between the FBI and the City of Miami Beach on behalf of the MBPD. As a result, a Detective from the Criminal lnvestigations Division will be assigned to the JTTF to work in conjunction with their personnel in identifying, locating and apprehending individuals who commit these crimes in the Cityof Miami Beach and South Florida. Participation in the JTTF will benefit the City of Miami Beach and the MBPD because of access to increased investigative resources and capabilities. Pursuant to the Memorandum of Understanding the FBI has agreed to provide access to a vehicle; reimburse the City of Miami Beach for overtime expenses, travel, and investigative expenses incurred by the MBPD Detective in connection with JTTF investigations pending available funding. Upon the signatures of all the parties to the Memorandum of Understanding, the Detective can participate in the JTTF for the duration of the Task Force unless either the FBI or the City of Miami Beach should decide to withdraw. rr-rr,,,##tr TO: FROM: Mayor Philip Levine and Members Jimmy L. Morales, City Manager DATE: September10,2014 SUBJECT: A RESOLUTION OF THE MAYOR 304 RESOLUTION NO. A RESOLUTION OF THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA, AUTHORIZING THE CITY MANAGER AND CITY CLERK TO EXECUTE A MEMORANDUM OF UNDERSTANDING BETWEEN THE CITY OF MIAMI BEACH, ON BEHALF OF THE MIAM! BEACH POLICE DEPARTMENT, AND THE FEDERAL BUREAU OF INVESTIGATION, SOUTH FLORIDA JOINT TERRORISM TASK FORCE FOR THE PURPOSE OF THE PREVENTION, PREEMPTION, DETERRENCE AND INVESTIGATTON OF TERRORIST ACTS, AND APPREHEND INDIVIDUALS WHO MAY COMMIT OR PLAN TO COMMIT SUCH ACTS. WHEREAS, the Miami Division of the Federal Bureau of lnvestigation (FBl) has established the South Florida Joint Terrorism Task Force ("Task Force") for the purpose of prevention, preemption, deterrence and investigation of terrorist acts, and apprehend individuals who may commit or plan to commit such acts; and WHEREAS, the Task Force enhances the effectiveness of Federal, State and local law enforcement resources through a well coordinated initiative seeking the most effective investigative and prosecutive avenues, and to facilitate the sharing of FBI information with the intelligence and law enforcement communities to protect the United States and the City of Miami Beach against threats to our national security, including international terrorism; and WHEREAS, a detective sergeant from the Miami Beach Police Department shall be assigned to the Task Force, to work in conjunction with Federal, State and local law enforcement personnel in identifying, locating, and apprehending those individuals who commit these crimes in the City of Miami Beach and South Florida; and WHEREAS, it is a great benefit to the Miami Beach Police Department to participate in this Task Force because of the increased investigative resources and capability, and shall thereby improve the effectiveness of the Miami Beach Police Department law enforcement activities; and WHEREAS, upon the availability of funding, the FBI will reimburse the City of Miami Beach and the Miami Beach Police Department for overtime expenses, travel, and provide access to a vehicle that shall be utilized for investigative purposes of the Task Force; and WHEREAS, the City of Miami Beach, on behalf of the Miami Beach Police Department, and the Federal Bureau of lnvestigation, wishes to execute a Memorandum of Understanding, commencing upon the signatures of all parties, and shall remain in effect for the duration of the Miami Beach Police Department's participation in the Task Force. NOW, THEREFORE, BE IT DULY RESOLVED BY THE MAYOR AND CITY GOMMISSION OF THE GITY OF MIAMI BEACH, FLORIDA, that the City Manager and City Clerk are hereby authorized to execute the attached Memorandum of Understanding with the Federal Bureau of lnvestigation, Miami Division, South Florida Joint Terrorism Task Force, for the purpose of the prevention, preemption, deterrence and investigation of terrorist acts and apprehend individuals who may commit or plan to commit such acts. PASSED and ADOPTED this day of September,2014. ATTEST: MAYOR PHILIP LEVINE AppRovEDAS To FORM & LANGUAGE & FOH EXECUTION RAFAEL E. GRANADO, CITY CLERK 305 JOINT TERRORISM TASK T'ORCE S I'ANDARD MEMORANDUM OF UNDERSTANDING BETWEEN THE IIEDERAL BURLAU OF INVES'I'IGATION AND Miami Beach Police Department PREAMBLE 'lhe policy of the United States with regard to domestic and international terrorism is to deter, defeat, and respond vigorously to all terrorist attacks on our territory and against our citizens, or facilities. Within the United States, the Department of Justice, acting through the Federal lJureau of Investigation (FBI), is the lead agency domestically for the counterterrorism effort. In order to ensure that there is a robust capability'to deter. defeat, and respond vigorously to terrorism in the U.S. or against any U.S. interest, the F'BI recognizes the need for all federal, state. local, and tribal agencies that are involved in fighting terrorism to coordinate ancl share information ernd resources. 'to that end. the IBl believes that the creation of the FBI National Joint -l'enorism 'l'ask Force (NJ'l''l"F) and Joint Terrorism'Iask Forces (J'l"fFs) embodies the objectivcs of the l"J.S. policy on counterterrorism as set forth in Presidential Directives. FBI policy for the NJ'I"[F and JT'I'Fs is to provide a vehicle to facilitate sharing F Bl information with the intelligence eund law enforcement communities to protect the United States against threats to our national securiqv, including international terrorism. and thereby improve the effectiveness of law enforcement, consistent with the protection of classified or otherwise sensitivc intelligence and law enfbrcement information, including sources and methods. All NJI'TF and JTTIr operational and investigative activilv. including the collection, retention and dissemination of personal information, will be conducted in a manner that protects and preserves the constitutional rights and civil liberties of all persons in the United States. 'l'his Memorandum of Understanding (MOLI) shall serv'e to establish the parameters for the detail of employees (Detailees or members) from the Participating Agency to the FBl-led J'l-'IF's in selected locations around the [Jnited States. I.PLJRP-OS-H A. 'I'he purpose of this MOU is to outline the mission of the J'I"[F, and to formalize the relationship between the FBI and the Participating Agency in order to maximize cooperation and to create a cohesive unit capable of addressing the most complex tcrrorism investigations. 306 FOR OFI.'ICIAL I-,SE ONLY 13. 'l'he MOl; specificalll represents the agreement befween the Flll and the Participating Agenc;-. which will govern the process by which employees o{'the Participating Agency are detailed to work with the FBI as part o( the J'|TF. Cl. 'l'his MOU is not intended. and should not be construed, to create any right or benefjt, substantive or procedural, enforceable at law or otherwise by any third party against the parties. their parent agencies. the U.S., or the ofl'icers- employees. agents or other associated personnel thereof. II. MISSTQ]( 'l'he mission of the J'l"l'F is to leverage the collective resourses of the member agencies for the prevention. preemption. deterrence and investigation of terrorist acts that aff'ect United States interests, and to disrupt and prevent tcrrorist acts and apprehend individuals who ma,,,- commit or plan to commit such acts. 'fo further this rnission, the JTTF shall serve as a means to facilitate inlormation sharing among J'I'TF members. III. ALi'l'llQRIlY Pursuemt to 28 1J.S.Cl. ' 533, 28 C.l".R. ' 0.85. Executive Order 12333, as amended, National Sccurity Presidential Directive (NSPD) 46l Ilomeland Security Presidential Directive (llSPD) l5 and Annex Il thereto, the FBI is authorized to coordinate an intelligence. investigative. and opcrationalresponse to terrorism. Ely virtue of that same authority, the FBI formed J'l"l'Fs composed of other federal. state. local. and tribal larv enforcement agencies acting in support of the aboye listed statutory and regulatory prol'isions. ll'>urliciputing agencies muy include applicable authoriry\for enterinl; into this MOU.l rv. eQN'lllQLLlNE.pQ_qJME"ljlS A. Since the J'l"l'F operates under the authority of the Attorney General of'the LJnited States. all J'l"l'F participants must adhere to applicable Attorney General=s Guidelines and directives. to include the following, as amended or supplemented: 1. Attomey General=s Guidelines on General Crimes. Racketeering Entcrprise and T'errorism linterprise Investigations; 2. Attome.v General=s Guidelines tbr FIII National Security Investigations and F'oreign lntelligence Collection: FOR oFFIcr,iI UsE oNLY This document is the propertv of the t'BI and is lo*ned to your agency. Neither it nor its contents may be released without authorization by FBI Headquarters. 307 rOR OFFICIAL USE ONI,Y i. ;\tttlrnev General.=s Guidelines on Federal Bureau of Investigation t- ndercover Operations; 4. Attorncy General=s Guidelines Regarding Prompt F{andling of lleports of Possible Criminal Activity Involving Ioreign Intelligence Sources; 5. Attome-v- General Memoremdum dated March 6. 2002. titled alntelligence Sharing Procedures fbr t-oreign Intelligence and Foreign Counterintelligence Investigations Conducted by the FBIB: 6. Attorne.v- General=s Guidelines Regarding the Use of Confidential Informants: 7 . Attorne;- (ieneral=s Guidelines on the Development and Opcration of FIJI Criminal [nformants and Cooperative Witnesses in ]-,xtraterritorial Jurisdictions: 8. Attorney General=s Guidelines Regarding Disclosure to the Director of' Central Intelligence and Homeland Security Officials of Foreign lntelligence Acquired in the Course of a Criminal Investigation: and 9. Nlemorandum from the Deputy Attomey (ieneral a:d the FBI Director re: Field Guidance on lntelligcnce Sharing Procedures for [Foreign Intelligence] and IF oreign Counterintelligence] Investigations ( December 24,2002). B. All guidance on investigative matters handled by the JI"I'F will be issued b,v' the Attomey General zrnd the FBI. 'l'he FIll will provide copies of the ahove-listcd guidelines and any other applicable policies for referencc and revicw to all J'l"l'F members, Notr,r'ithstanding the above, this MOU does not alter or abrogatc existing directives or policies regarding the conduct of investigations or the use of speciai investigative techniques or controlled informants. 'l'he FIll agrces to conduct periodic briefings of the member agencies of the 3'11'1; pursuant to all legal requirements and F BI policies. v. s",r Rr.rc_ t-ir R-H_.11\D MANA_GIIAEN:I !!"[HLIA_$K.IABC-E A. MtiMtllrRs l. Each J'l"l-F shall consist of a combined body of sworn and non-swom personnel from the FBI and each Participating Agency. I'his MO(J shall apply to Panicipating Agencies that join the J'l"l'F subsequent to execution of this agreement. 3 FOR OFFICIAL USE ONLY 'f his document is the propert-r' of the FBI and is loaned to your agency. Neither it nor its contents mav be released without authorization by FBI Headquarters. 308 rOR OFTICIAL USE ONLY B. P.RO c&A r\{ UAN AG E \4U-N 1:t) I RL_Cl:l "I gN, AND s Ltp_Ll RV I S_l O N 1. In order to comply with Presidential Directives. the policy and program management of the J'tTFs is the responsibility of FBI Headquartcrs (l"BIflQ). 'l'he overall commander of each individual J-l"l'li w.ill be the Special Agent in Charge (SAC) or Assistant Director in Chiuge (ADIC). if a-ssigned. of the FBI=s local Field Division. Ihe operational chain of command beginning at the highest level. in each FIll Field Division will be as follorvs: ADICI if zxsigned, SAC, Assistant Special Agent in Chuge (ASAC). and Superv'isory Special Agenr U'fTf Superv.isorl. 2. Each Ftsl ADIC/SAC. through his or her chain-of'-command. is responsible fbr administrati'v'e and operational matters directly associated with the Division=s JTI'F(s). Operational activities will be supervised by F'BI J-l'l'[; Supervisors. Staffing issues are the rcsponsibilitv of the trBI chain 0f command. All investigations opened and conducted by the J'l"l'F must be conducted in contbrmance rvith FBI policy, to include the above stated Controlling I)ocuments. Each Flll ADICISAC, through his or her chain-of-command. lvill ensure that all inrestigations are propcrly documented on [rBI forms in accordance with FBI rules and regulations. Any operational problems will be resolved at the field office level. Any problems not resolved at thc field otlicc level w'ill be submitted to each ag€nc!=5 headquarters for resolution. Hach Participating Agency reprcsentative will report to his or her rcspcctive agency for personnel adminisEative matters. Each Participating Agency shall be rcsponsible fbr the pay, overtime. leave. performance appraisals. and other personnel matters relating to its employees detailed to i'l"l'Fs. As discussed later herein at Paragraph XI. the FBI and the Participating Agency'may provide for overtime reimbursement by the FBI by separate written agreement. Lach J'l"l'F member w'ill be subject to the personnel rules, regulations, laws. and policies applicable to employees of his or her respective agency and also will adhere to the FBI=s ethical standards ernd will be subject to the Supplemental Standards of Ethical Conduct for employees of the Department of Justice. where there is a conflict betw'een the standards or requirements of the Participating Agency and the FBI, the standard or requirement that provides the greatest organizational protection or benefit will apply, unless the organizations jointly resolve the conflict otherwise. 4 FOR OTFICIAL USE ONLY This document is the properf;- of the FBI and is loaned to your agency. Neither it nor its contents may be released w'ithout authorization by FBI Headquarters. J. I+. 5. 309 6. rOR OT'FICIAL USE ONLY J'l"l l: members are subject to removal fiom the J'l"l'F by the IiLll tbr violation of any provision of this MotJ, the F.Ill=s ethical standards, the Supplemental Standards of Ethical Conduct fbr employ.ccs of the Department of Justice. or other applicable agreements, rules. and regulations. 'l'he FBI maintains oversight and review responsibilit,v of the J1'-l'1.'s. In the event of an FBI inquiry into J'l"l'F activities by an investigative or administrative body. including but not limited to, the FIll=s Office of Professional Responsibiliry" or the FBI. s Inspection Division. each Participating Agency representative to thc JT-I'F. may be subject to interview'bv the FBI. 7 C t."I'he F'Bl will provide offrce space for all J'I'T'F members and support staff. ln addition, the FBI will provide all necessary secretarial, clerical, automation, and technical support for the J'l"t'F in accordance with FBI guidelines and procedures. 'l'he FBI will provide all fumiture and ofllce equipment. Participating agencies may bring office equipment or furniture into FBI space with the approval of the f BI JI'I'F Supervisor and in compliance w'ith IiBI regulations. l'he introduction of office equipment and fumiture into FIll space by Participating Agencies is discouraged. as any such material is subject to examination tbr technical compromise. which may result in its being dzrnaged or destroyed. r\.CLHARANCTJS 5 rOR OT-FICIAL USE ONLY 'f his document is the propert-v of the FBI and is loaned to your agency. Neither it nor its contents may be released without authorization by l'BI Headquarters. 2. VI. 310 IOR OFFICIAL L,SE ONLY State, local. and tribal members of the J"l'l'Fs. as well as appropriatc superr,isorl personnel responsible for these individuals" must apply fbr zrnd rece ive a'l'op Secret/sensiti ve compartmented Information (' I'sls cl I ) Security clearance granted by the IjBI. J'I'TF members firom other federa] agencics must obtain a'fop SecreVSCll clearance fiom their agency and have this information passed to &e IiBI. No one will have access to sensitive or classified documents or materials or FBI space without a vali<l security'clearance and the necessary Aneed-to-know.B Pursuant to the provisions of Section I .2 of Executive order 12968. Detailees are required to have signed a nondisclosure agreement approved by the I.'BI,,s Security Division. Pursuant to federal law, JTTF members are slrictly forbidden fiom disclosing any classitied information to individuals who do not possess the appropriate security clea.rance and the need to know. Nl J'[TI' management personnel must ensure that each parricipating J'l"l'F' officer or agent undertakes all necessary steps to obtain a'l'SiSCI clearanse. Conversion of FBI counterterrorism and J'I'TF spaces to Sensitive Compartmented Information Facilities (SCIf s) is underwa.v-. This will require that all J'l'l'F task force oificers enhance their clcarances to I'S/SCI (SI.1'K. Gamma HCS-P). Federal agencl- task fbrce officers should contact their Security officers zurd request and obtain the follow'ing SCI Clearances: Sl, 1'K. Gamma, and lICS-P. If the parent agency refuses or is unable to provide the appropriate clearances, the FBI will request the task force officer=s security file. Il providcd. the FBI rvill adjudicate SCI clearances. -['his action may involve a prohibitively long process and should be avoided. Hach Participating Agency fully understands that its personnel detailed to the J't tF are not permitted to discuss oflicial J'ITF busincss w.ith supervisors rvho are not members of the J'l"l'F unless the supervisor possesses the appropriate scctrlity clearance and the dissemination or discussion is specifically approved by the I-BI JT'l'f Supervisor. Participating Agency'heads will be brief'ed regarding J'fl-F matters by the S.,\C or ADIC. as appropriate, through established J'[T'F Executive Lloard meetings. In accordance with the Dircctor of Central Intelligence Directive (DCID) 6u'4, entitled Personnel Securitr Standards and Procedures Governing Eligibilit-v for Access to Sensitive Compartrnented lnformation (SCI), the Ftst will implement protocols to enswe Special Agent (SA) and'l'ask Forcc Officers ('ffO) assigned to Joint'l'enorism'l'ask !'orces (i'l"ff ) in the field and the National Joint'l'errorism Task l'orce (NJ'I'1'F) at FBI Ileadquarrers - 6 FOR OFFICIAL USE ONLY This document is the propery* of the FBI and is loaned to your agency. Neither it nor its contents may be released without authorization by FBI Headquarters. ) 4. 5. 311 rOR OFFICIAL USE ONLY Liberty cirr:ssing I, are in compliance with stated directive. In order tg compl;" rvith I)clD 614. all J'l'l'F personnel. including FBI and non-r;Bl J'l"l'F members and contractors who perform functions requiring access tr: lBl classified data net'*'orks and space. will be given counter-intelligence tbcused poly'graphs. 'l'he UBI will recognize polygraph e.xaminations conducted by outside federal agencies that meet the Ftsl=s pSpp requirement. l'he FBI will make the final determination w'hether a polygraph examination meets the PSPP requirements. 6- All JI'TI' members must agree to submit to counter-intelligence fbcused polygraphs as part of the process for obtaining and retaining a'r'op Secret Security Clearance. B. RES I RICI'IONS ON IILECTRONIC EQUIPMI:NT Pcrsonall,"- ormed Portable Electronic Devices (PHDs) including. but not [imited to, personal digital assistants. Blackbeny devices. cellular telephones. and tw'o-way pagers are prohibited in Flll space unless properly approved. No personally owned electronic devices are permitted to operate within SCIFs as outlined in DCI Directive 619 and existing Bureau policy'. Ali other non-F Eli orvned infbrmation technolog.v- and systems (such as computers. printers. I'ax machines. copiers. PBDs, cameras. and media including diskenes, CIDS, tapes) require Ftsl approval prior to introduction, operation, connection. or removal fiom FBI spaccs to include SCIFs. Additionally, if approved by the Ftll Securitv Ofticer, these systems must operate in cclmpliance with the FBI=s policies. guidelines. and procedures. I)EP1J1'A fION Non-f'ederal members of the J'l"fF who are subject to a background inquiry and are sworn law enforcement ofllcers will be l'ederally deputized rvhile detailed to the J'I"[F'. 'l'he Ii BI w.ill securc the required authorization tbr their deputation. Deputation of these individuals w'ill ensure that they are able to assist fully' in investigations in compliance with applicable federal statutes. On occasion. investigations may be conducted outside of the Jl"l'l'=s assigned territory. Deputation will allow non-fbderal members of the JT'['F to exercise federal law enforcement authoritv throughout the United States. IJnder the terms of this MOU, all Participating Agencies agree that non-sworn personnel detailcd to the J'l"l'F will not : ( I ) participate in law enforcement activities. (2) carry a weapon: or (3 ) participate in the execution of searcl,- arrest wtrrants. VIII. S I.AI]I.NG COMMITMHNT 1 FOR OFFICIAL USE ONLY This document is the property of the FBI and is loaned to your agency. ]ieither it nor its contetrts may be released without authorization by FBI Headquarters. VII 312 TOR OFFICIAL USf, ONLY A. In rie$, of the need tbr securir.v clearances and continuit,"- of investigators. all pcrsonnel detailed to the J.l"l'F should be expected to be detailed for a period of at least tw'o (2) vcars. fhis MOU imposes no mrximum limit as to the time that any individual may'remain a member of the J'l"fF. All non-FBl members of the J'l"l'F must adhere to the same rules and regulations as FUI employees w'ith regard to conduct and activities while in FBI space. while operating FIll vehicles. aurd whilc conducting J'l-l-F business. All 'l'ask Force members detailed from other f'ederal agencies are responsible fbr maintaining an appropriate case load. as directed by J'l"fF managemenr. il. All investigators detailed to the J'l'l'F will be designated either full-time or part-time. 'l'hc operationalneeds of the JT'I'lj recluire that any assignments to special details. or duties outside of the Jl'l'F to full-time J'l"l'F members be coordinatcd with the I'BI J'f'l'F Supervisor. 'fhough each J'I"I'F member will report to his or her respective Participating Agency for pcrsonnel matters. he or she will coordinate leave rvith the JTI'F=s i.BI JT]"l. Supervisor. Cl. During perir:ds of heightened threats and emergencies. the JT'l'Fs may be expectedto operate 24 hours per daJ', seven day's per week. for extended periods of time.'l'o function properly, the J't"fF depends upon the unique contributions of each Participating Agencl. Accordinglv, during these periods, each Participating Agcncy member rvill be expected to be available to support J'f'fF activities. 8 rOR OFFICIAL USE ONLY 'f his document is the propert"v of the FBI and is loaned to your agency. Neither it nor its contents may be released without authorization by FBI Headquarters. 313 F]OR OTFICIAI, USE ONI,Y IX. I{I:CTORD.S. RF.POR fS rUlD IN,t-OR,VIA]_IQN _S,UABIN-G A. All J l"ff matcrials and investigative records. including any Memorandum of' Understanding. originate with. belong to. and w'ill be maintained by the IjBI. All investigative reports will be prepared by JT'I'F personnel solely on FBI tbrms. All information generated by the IjBI or the Jl"l'F will be controlled solely by the Ijtll and may not be removed from FIll space without the approval of the JT'I'[; Supervisor. Dissemination. access or other use of J'I'TF records will be in accordance rvith Federal larv. Executive Orders, and Department of Justice and Ftsl regulations and policy. including the dissemination and inlbrmation sharing provisions olthe FBI Intelligence Policy Manual. As FBI records, they may be disclosed only r,vith FBI permission and only in conformance with the provisions of f'ederal law's and regulations. including the F'reedom of lnformation Act. 5 LI.S.Cl. Section 552, and the Privacy Act of 1974. 5 U.S.C. Section 552a, as w.ell as applicable civil and criminal discovery privileges. This policy includes any disclosure of F'BI information. including J'l"l'F materials and investigati,,'e records. to emplovees and oflicials of a Participating Agency who uc not members of a J'l-l'F. which must be approved by the J1'-l-F supervisor. All electronic records and infi:rmarion, including. but not limited to. systems. databases and media, are also reguiated by I;BI policy. J'l"l'F members may request approval to disseminate IrBI information tiom the J1'1'F Supen'isor. Lach Participating Agency agrees to hal'e its Detailees t<l the J'I'J'F execute an l'D-868, or a similar form approved by the FB[ 'l'his action obligates the f)etailce. rvho is accepting a position of special trust in being granted access to classilied and i:therwise sensitir,e infbrmation as part of the J'l'"fF. to be bound b.v- prepublicarion revierv to protect against the unauthorized disclosure of such information. I'he participation of other federal. state. local, and tribal partners on the J'l"l'F is critical to the long-term success of the endeavor. Articulating thc level of effort tbr these partnerships is a key measure of the J'I'TF-s perfbrmance. Accordingly. all task tbrce members will be required to record their rvorkload in the 'l'ime l..itilization Recordkeeping ('ftjRK) system used by the f BI. X.COORDINA I'ION A. 'I'he Participating Agency agrees to not knowingly act unilaterall,v.. on any matter affbcting the J'I"l'F w'ithout flrst coordinating rvith the FBL 'l'he peulies agrec that matters dcsignated to be handlcd by the JT IF shall not know'ingly bc subject to non-J'f'l'I or non-FBI intelligence. law enlbrcement, or operationai efforts by the Participating Agency. Intelligence. law cnforcemcnt, and operational actions w'ill be coordinated and cooperatively carried out within the J'l'I'Fs. 9 FOR OFTICIAL USE OI{LY This document is the properfy- of the FBI and is losned trr your agency. Neither it nor its contents may be released without euthorization by FBI Headquarters. u. C. 314 XI. FOR OT FICIAL USE ONLY ll. J'l"l'F criminal investigativc procedures rvill conform to the requirements for lbderal prosecution. It is expected that the appropriate United States Anorney. in consultalion with the Ftsl and aff'ected JT'I'F pzulners. w'ill determine on a ca.se-by-case basis whether the prosecution of cases will be at the federal or state level. based upon which would better advance the interests ofjustice. I-UNDING 'l'his MOLi is not an obligation or commitrnent of funds, nor a basis for uansfer of funds. Even where one partv has agreed (or later does agree) to assume a particulu financial responsibility. written agreement must be obtained before incurring an expense cxpected to be assumed by another party. All obligations of and expenditures by the parties are subject to their respective budgctary and fiscal processes and availability of f'unds pursuant to all laws, regulations. and policies applicable thereto. 'l'hc parties acknowledge that there is no intimation, promise, or guarantee that lunds will be available in future years. Ihe FBI and the Participating Agcncy ma,v- enter into a separate agreement to reimburse the Participating Agency for approved overtime expenses. XII. I tlAVhL AII J'l"l'F-related travel of non-Flll personnel requires thc approval of the appropriatc J'l"l'f Supervisor and Participating Agency authorization prior to travcl. In order to avoid delay in operational travei. the Participating Agencv will provide general travel authoritl' to all of its participating employecs for the duration of the employee=s membership in the J'l"f'lis. For domestic travel. each agency' member rvill be responsible for appropriate notifications within his or her own agenc)'. as rvell as standard FBtr travel approvals and notification. 'l'he FBI will obtain l;BI[{Q authorization and country clearances for all J]"I'F members who are required to travel outside the tinited States. As noted above. the appropriate security clearance must be obtained prior to an,v* international travel. I'he FIll rlill pa1'costs for travcl of all members of the J'l"l'Fs k: conduct invcstigations outside of the J'l"l"F=s assigned territory. xrr. YljrlilL,li|5 AN-D EuulpMEN'r A. In furtherance of this MOU, employ'ees of the Participating Agency may be permitted to drive FLll owned or leased vehicles for surveillance, case management zu:d investigation in connection with any Jl"l'F investigation. I;BI vehicles must onl1 be used fbr official J'I"I'F business and only in accordance with applicable F lll rules and regulations. l0 FOR OFUCIAL USE ONLY This document is the propert-v of the t'BI and is loaned to your agency. Neither it nor its contents ma-v- be released without authorization by FBI Headquarters. 315 cl. IOR OFFICIAL L.SE ONLY Inon-l''ederul entitie^s onl1,l An.v civil liability arising fiom the use of'an FBI owned or leascd vehicle by a Participating Agency task tbrce member while engaged in any conduct other than his or her official duties and assignments under this N,lotl shall not be the responsibiiity of the FBI or the lJnitcd States. 'l'o the extenr permitteci hy applicablc lau. the Participating Agency will hold harmless the FUt and thc Llnited States for any claim for property damage or personal injury arising from an.v- use of an FBI orvned or leased vehicle by a Participating Agency J'l"t'F member which is outside of the scope of his or her official duties and assignments under this MO{"J. For ofllcial inventory purposes, all JTTF equipment including badges, credentials and other fbrrns of J'l"l'F identification subject to FBI property inventory requirements will be produced by each J'frF member upon request. At the completion of the member=s assignment on the J I"l t, or upon withdraw'al or termination of the Participating Agency from the J]-rF. all equipment will be returned to the supply'ing agenc.v. xtv. FoRtrEl.t,irRji 'l'he l'tll shall he rcsponsible forthe processing of assets seized for f'ederal forf'eiture in conjunction uith J'l"l'F operations, as provided by these rules and regulations. Assct fort'eitures rvill be cclnducted in accordancc with federal law and the rules and regulations set forth hy the I"J.S. Department of Justice and the F lll. Forf'eitures attributable to JT.l'lj investigations may be distributed among the I'}articipating Agcncies in J'l"l'F-related operations at the discretion of the I.BI. XV. IILTMAN SOURCI:S A. All human sources dereloped through the J'l"l'F will be handled in accordance with the Attorne)' (ieneral=s and the F'BI'. s guidelines. policies and procedures. Ll. B.All humzrn sources developed during the course of any JT'I'I. investigation shall bc operated with ali appropriate FBI suitability paperwork completed prior to use. All source debrietings or lrritten products of information obtained from any human source will use Iilll document format and handling procedures. 'l'he FBI. as permitted b."- federai iaw, agrees to pay rcasonable and necessarv human source expenses incurred by the J'I'I'F. Allexpenses must be approved by the I;Bl before they' are incuned. No payments may be made to J'l'fF human sources without prior Ftsl approval. C. ll }.OR OTFICIAL USE ONLY This documcnt is the property of the FBI and is loaned to your agency. Neither it nor its contents ma;.- be released without authorization by FBI Headquarters. 316 FOR OTFICIAL USE ONLY XVI. !ILDIC]AI. A. All Participating Agencies will ensure that detailed J-l-'l'F members are me<iicall.v qualified according to their agencies' standards to perform larv enforcement duties. functions and responsibilitics. U. 'l'o ensure protection for purposes of the Federal Employees' Compensation Act (till(lA), J'l"l'f members should be detailed to the FBI consistent with the provisions of'the Intugovernmental Personnel Act (lPA). 5 U.S.C. ' 3374(d). This Act stipulates that "[al State or local government employee who is given an appointrnent in a Federal agency for the period o{' the assignment or rvho is on detail to a Fcderal agency and who sufl'ers disability or dies as a result of personal injurl sustained while in the perfornance of his duty during the assignment shall be treated . . . as though he rvere an employee as defined by section 8101 of this title who has sustained the injury in the perforrnance of dutl'." Other provisions of federal lau, may extcnd t'ECA benefits in more limited circumstances. I'he Department of Labor's Office ol Workers' Ctlmpensation Programs is charged with making FECIA coveragc determinations and is available to provide guideu:rce conceming specific circumstances. xvrr. ll{AlNrNG AllJl'T"lj memhers are required to attend FBI legal training in compliance rvith FBI regulations and any other training deemed necessar)' by the FBI chain of command. 'Ihe F BI is responsible fbr the costs of such training. The Participating Agency will bcar the costs of any training requiretl of its t:wn employecs detailed to the J'l"l'F. xvrrr. DE-A-DL\- FORCH AND SHOOTTNG INCtDENl'POLICIES Nlembers of the J'l"l'f will follow their oun ogeocv=s policy concerning use of dearily fbrce. 12 FOR OFFICIAL USE ONLY This document is the propertv of the FBI and is loaned to your agency. Neither it nor its contents may be released without authorization by I'BI lleadquarters. 317 FOR OTFICIAI. USE ONLY XIX. Dljl']AR'l ivlirN I Or DHIENSU COMP_QN-EN'I"S 'l'he Posse Clomitatus r\ct. l8 Lr.S.C. ' 1385, prohibits the Army and Air Force (Departmenl of [)etcnse regulaticlns now restrict the activities of all branches or components of the Armed Sen,ices under this Act) fiom being used as a posse comitatus or otherwise to executc the laws entrusted to civilian law enlbrcement authorities. The restrictions of the Act do not apply to civilian employees of the Department of l)efense rvho are not acting under the direct command and control ol'a military otlicer. Other statutory provisions specifically authclrize certain indirect ancl direct assistance and pa(icipation by the military in specified law enforcement functions anrl activities. All l)epartment of Defense components (except strictly civilian components not acting under direct command and controlof a militar-l olficer)w.ho enter into this agreement. shall cornply with all Department of Dettnse regulations and statutory authorities (describing restrictions. aurhorizations and conditions in support of lar,l' enforcement) including but not limited to Departrnent of f)efense I)irectives5525.5.and3025.15.Chapter18ofTitle l0oftheUnitedStatesClodedealingwith military support ibr civilian lal,l enforcement agencies and an,v other or subsequent rules, regulations. and laws that may address this topic or that may amend, or modi{,v any of the above provisions. 'l'his MOLj shall not be construed to authorize any additional or greater authority (than already described) fbr Department of Defense components to act in the support of larv enforcemcnt activities. xx. MrolA All media releascs rvill be mutuall-u- agreed upon and jointly handled by the member Participating Agencies of the appropriate J'l'I'F. Press releases will conform to DOJ Guidelines regarding press releascs. No press release will be issued without prior FBI approval. xxr. L{AItrLt-r_Y -l'he Panicipating Agency acknowledges that financial and civil liability. if any and in accordance with applicable law. for the acts and omissions of each employee detailed to the J'l"l'F remains vcsted with his or her employing agency. However. the Department of Justice (DOJ) may, in its discretion. determine on a case-bv-case basis that an individual should be afforded legal representation. legal det'ense. or indemnification of a civiljudgment. pursuant to federal law and DOJ policy' and regulations. A. COMMON LAW' |OR]'CLAIN,IS l. Congress has provided that the exclusil,e remedy for the negligent or rvrongful act or omission of an employee of the U.S. Govemment, acting within the scope of his or her employment, shall be an action against the { jnitcd States under the F'I'CA. 28 U.S.C. , 1346(b), and ' 26Tt - 2680. l3 FOR OTFICIAL USf, ONLY This document is the properf.v- of the FBI and is loaned to y.our agency. l{either it nor its contents may be released without authorization by FBI Headquarterc. 318 ). r()R 0I'FICIAL LrSE ONLY Notuithstanding the provisions contained in Article XIll of this Mol.,;. fbr the limited purpose of defending civil claims arising out of J'l"l'F activity. a state, local. or tribal law enforcement officer who has been f'ederally deputized and who is acting within the course and scope of his or hcr offrcial duties and assignments pursuant to this Mou may be considered an Aemplol'ee@ of the U.S. government, as def-rned at 28 Lj.S.C. , 2671. Sce 5 ti.S.C. ' 3374(c)(2). Under the lederal Employee Liabiliry Refbrm and rort compensation Act of 1998 (commonly kno*r: as the Westfall Act). 28 U.S.C. ' 2679(bX I ), if en emplol'ee of the united States is named as a defendant in a civil action. the Annmcy- General or his or her designee ma)'certif,v that the def'endant acted r.vithin the scope of his or her employment at the tirne r:rf the incident giving risc to the suit. 28 [J.S.C. ' 2679(d)(2). 'l"he United States can rhen he suhstituted for the emplo,v-ee as the sole defendant with respect to any tort claims alleged in the action. 28 U.S.C. , ?679(d)(2). If the tinited Statcs is suhstituted as defendant. the individual employee is thereby protected liom suit on any tort claim arising out of the incident. If the Attorncy Ceneraldeclines to certifu that am employee was acting within the scope of employrnent, Athe employee may at any time before trial petition the court to find and certify that the employee was acting within the scope of his ollice or emplo."-ment.G 28 U.S.C. , 2679(d)(3). t.iability for an,n- negligent or rvillt'ul acts of J"["['F members undertakcn outside the terms of this MO[,r will be the sole rcsponsibilitv of the respective employee and agency involved. B.c- 0 N s r_u-rirrg-N AL c LArM s l.Liabilitl' for violations of federal constitutional la,*. may rest with the individual federal agent or officer pursuant to BiVgns v. Slx,Unknown N4r1eq Aggsls ol&e L"pdq_ral Buqau p,f1\arpp-t1sp, 403 {.J.S. 388 (1971) or pursuant to 4l U.S.C. ' 1983 for state of'ficers. f'ederal. state. local, and tribal officers enjoy qualified immunity from suit lor constitutional torts. ,linsofar as their conduct does not violate clearly established starutory or constitutional rights of which a reasonable person w'ould have knoun.G HarJow-u !-rggerald,457 tJ.S. 800 (1982). l4 FOR OTFICIAL USE ONLY This document is the proper$- of the FBI and is loaned to your agency. Neither it nor its contents may be released without authorization by FBI Heade;uarters. 1 4. 2 319 FOR OTFICIAL USE ONLY i. lf a Participating Agency J'l"l'F officer is named as a def'endant in his or her indir,'idual capacity in a civil action alleging constitutional damages as a resuit of conduct taken w'ithin the course of the J'I'T'F. the officer mav request represenration by DOJ. 28 C.I.'.R. , ' 50.15. 50.16. 4. An emplo3,ee may be provided representation Awhen the actions li:r which representation is requested reasonabl;- appears to have been performed rvithin the scope of the employee=s employment. and the Attorney (ieneral. or his or her designee, determines that providing representation would othenvise be in the interest of the United States.@ 28 C.f;.R. ' 50.15(a). 5. A J'l'I'f member'.s written request for representation should be directed to the Attorney General and provided to the Clhief Division Clounsel (CDCI) of the FBI division coordinating the JI"I'F. The CDC will forward thc representation request to the F BI *s Office of the General Counscl (OGC). together with a letterhead memorandum concerning the factual basis of the lawsuit. FBI -- s OGC will then forw'ard the request to the Civil Division of DOJ. together with an agency recommendation concerning scope of emplo-vment and DOJ representation. 28 C.F.R. , 50.15(aX3). 6. If a J'l''l'F member is found to be liable fbr a constitutional tort. he or shc may' request indemnification from DOJ to satisty' an adverse judgement rendered against the employee in his or her individual capacity. 28 C.l,.R. ' 50.15(cX4). 'l'he criteria for payment are substantially simileu to those used to determine whether a fedsral employee is entitled to DOJ reprcsentation under 28 Cl.t.R.' 50.15(a). 7. Determinations concerning legal representation and indemnification by the [-inited States are discretionary and are made by DOJ on a case-by-case basis. 'Ihe FBI cannot guarantee that the Unitcd States will provide legal representation. legal defensc. or indemnification to any federal or state emplol"ee detailed to the JTI-F, and nothing in this Article shall be dcemed tt: create an1'legalright on the part of any J'I'I'F personnel. (1. ITXPRLSS, RESERVA"|IONS 1. Nothing in this Article shall be deemed to create an employment relationship betueen the FBI or the United States and any Participating Agency J'l"l'l; member other than for exclusive purposes of the I."|CA. as outlined heroin. l5 rOR OFTIChL USE ONLY This document is the property of the FBI and is loaned to your agency'. Neither it nor its contents may be released without authorization by ['BI Headquarters. 320 FOR OTTICIAL tSE ONLY 2. I'he participating agencies do not waive any available delcnses andior limitations on liability. No Participating Agency shall bc considercd to be an agent of any other Participating Agency. xxrr. t)-uRal-roN I'he term of the MoU shall be an indefinite period. -l'he MoU may bc terminated at rvill by any party. provided rwitten notice is provided to the other perties of not iess thaur sixty (60) days. LJpon termination of the MOt,l. all equipment will be retumed to the supplying agency(ies). It is understood that the termination of this agreement b) an,r- one of the Participating Agencies will have no effect on the agreement between the FBI zurd all other participating agencies. Notr,l'ithstanding this provision. the provisions of Paragraph IX. enritled RECORDS, REPORTS AND INFORMATION SHARING. and Paragraph XXt, entitled l.IABILIl'Y. will continue untilail potential liabilities have lapsed. Similarly, the inherent disclaimer limitation contained in the LXPRESS RHSITRVAI'ION provision w'ill survive any termination. XXIII, AMIJNDMTJN'I S I'his agrecment in no manner affects amy existing MOUs or agreements rvith the F BI or any other agcnc)'. 'l'his agreement may'be arnended only by mutual u'ritten consent of the parties. 'l'he modifications shall have no fbrce ard effect unless such modifications are reduced to writing and signed by an autl2crr7&)epresentative of the FBI and the Perticipating Agency.] SI(JNA'I-()RII1 Date: SAC - FI]I I6 FOR OFFICIAL USE ONLY This document is the propert-v of the f'Bl and is loaned to your sgenc). Neither it nor ils contents may be released without authorization by t'BI Headquarters. A. ti. 321 COST REIMBURSEMENT AGREEMENT BIlTWEEN THE T EDERAL BUREAU OF INVESTIGATION (TBI) ANI) MIAMI BEACH POLTCE DEPAR'TMENT ]'ASK FORC]B TILE #41s-MM-C48640 l)ursuant to Congressional appropriations, the FBI receives authority to pay overtime for police ollicers assigned to the fbrmalized South Florida JTTF as set forth below fbr expenses necessary- fbr detection. investigation. and prosecution of crimes against the United States. It is hereby agreed betw'een the FBI and Miami lleach Police Department located at 1100 Washington Avenue Miami Beach. I-L 33139. -l'axpayer ldentification Number 305-673-7925 . Phone Number l. Commencing upon execution of this agreement, the FIll wiil. subject to availability of required tunding, reimburse the agency tbr overtime paymcnts made to officers assignecl full- timc to the task force. 7. Rcquests for reimbursement will be made on a mnnthly basis and should be fbrwarded to the FBI tield ollice as soon as practical after the first of thc month w'hich follows the month fbr *'hich rcimbursement is requested. Such requests should be tbrw'arded by a Supervisor of the agenc)' to the lrBI 'fask Force Squad Supervisor and Special Agent in Charge fur thcir review. approval. and proccssing for payment. 3. Overtime rcimbursements rvili be made directly'to the agency by the Ftsl. All overtime reimbursement payments are made by electronic fund transfer Gf D. An ACH Vendor/ Miscellaneous Payment Flnrollment Form must be on file rvith the FBI to facilitate tjFl'. 4. Overtime reimbursements will be calculated at the usual rate for which the individual o{tccr's time would be compensated in the absence of this agreement. IIowever, said reimbursement, per officer. shall not exceed monthly and/or annual limits established annually by the HBI. 'l'he limits. calculated using Federal pay' tables, w'ill be in effect for the l;ederal fiscal y-ear running fiom October I'1of one -vear thn:ugh September 3Oth of the following year, unless changed during the period. 'fhe FBI resen'es the right to change the reimhursement limits. uprvard or downw'iud. for subsequent periods based on fiscal priorities and appropriations limits.'l'he Ftll will notiiy the agency of the applicable annual limits prior to October I't of each year. 5. 'l'he number of agency officers a-ssigned full-time to the task force and entitled to overtirne reimhursement by the FBI shall be approved by the FBI in advance of each fiscal year. l]ased on the needs of the task fbrce, this number may change periodically, upward or downward. as approved in advance by'the FBI. (X'('() ('R.4 template 5,23.'01 322 6. Prior to submission of an1'overtime reimbursement requests. the agenc,"- must prepare an oflcial document setting fbrth the identity of each officer assigned full-time to the task fbrce, along with the rcgular and overtime hourll'rates fbr each officer. Should any officers change during the -v-'ear. a similar statement must be prepared regarding the new officers prior to submitting arny overtime reimburscment requests for the officers. 'l'he document should be sent to the field offrce fbr FBI review and approval. 7. Irach request fbr reimbursement will include the name. rank, ID number, overtime compensation rate. number of reimbursable hours claimed. and the dates of those hours fbr each otlicer {br whom reimbursement is sought. 'l'he request must be accompanied by a certiticati<ln. signed by an appropriate Supervisor ofthe agency. that the request has been personally reviewed, the inlbrmation dcscribed in this paragraph is accurate. and the personnel fbr whom reimbursement is claimed were assigned full-time to the task force. 8. [:ach request for reimbursement will include an invoice number, invoice date, taxpayer identiiication number ('llN), and the correct banking information to completc the electronic fund fransfer. 'l'he necessar) baurking inibrmation is the Depositor Account-I'itle. Bank Account Number. Routing Number" and'l'ype of Account (either checking, savings. or lockbox). If the banking intbrmation changes. a new ACII Vendor/Miscellaneous Payment Enrollment l:orm must be submitted to the FBI. 9. Rcquests ibr reimbursement must be received by the F BI no later than Deccmber 3 l " of' the next fiscal ycar fbr which the reimbursement applies. For example, reimbursemcnts fbr the fiscal y'eer ending September 30. 2005 must be received by the FBI by' December 31. 2005. 'l-he IiBI is not obligated to reimburse any requests received after that time. 10. 'l'his agreement is effective upon signature of the parties ard will remain in effect for the duration of the agency''s participation in the task force. contingent upon approval ol'necessarv funding- and unless terminated in accordance with the provisions herein. fhis agreement may be modifred at any time by'written consent of the parties. It may be terminated at any timc upon mutual consent of the parties. or unilaterally upon written notice from the terminating party to the other party at least 30 days prior to the termination date. FOR TTIE AGENCY:FOR THE FBI: f)ate Special Agcnt in Charge I)ate Contracting Officer FBI Headquarters O('('O ('R.{ template 5 l3'01 Date 323 THIS PAGE INTENTIONALLY LEFT BLANK 324