HomeMy WebLinkAboutFEDERAL BUREAU OF INVESTIGATION (FBI) (6) NOV 1 4 2024 Return FULLY EXECUTED N-2024-368
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FEDERAL BUREAU OF INVESTIGATION
ORANGE COUNTY SEX TRAFFICKING AND OPPRESSION PREVENTION
TASK FORCE (OC STOP TF)
MEMORANDUM OF UNDERSTANDING
PARTIES
1. This Memorandum of Understanding (MOU) is entered into by and between the Federal
Bureau of Investigation (FBI) and Anaheim Police Department, Santa Ana Police
Department, Irvine Police Department, Garden Grove Police Department and the
California Highway Patrol (collectively: the Parties). Nothing in this MOU should be
construed as limiting or impeding the basic spirit of cooperation which exists between
these agencies.
AUTHORITIES
2. Authority for the FBI to enter into this agreement can be found at Title 28, United States
Code (U.S.C.), Section (§) 533; 34 U.S.C. § 10211; Title 28, Code of Federal
Regulations (C.F.R.), § 0.85; and applicable United States Attorney General's
Guidelines.
PURPOSE
3. The purpose of this MOU is to delineate the responsibilities of the Orange County Sex
Trafficking and Oppression Prevention Task Force (OC STOP TF); formalize
relationships between participating agencies for policy guidance, planning, training,
public and media relations; and maximize inter-agency cooperation. This MOU is not
intended, and should not be construed, to create any right or benefit, substantive or
procedural, enforceable at law or otherwise by any third party against the parties, the
United States, or the officers, employees, agents, or other associated personnel thereof.
No assignment of rights, duties, or obligations of this MOU shall be made by any party
without the express written approval of a duly authorized representative of all other
parties.
MISSION
4. The mission of the Orange County Sex Trafficking and Oppression Prevention Task
Force (OC STOP TF) is to provide a rapid, proactive, and intelligence-driven
investigative response to the sexual victimization of children and human trafficking within
the FBI's jurisdiction; to identify and recover victims of child exploitation and human
trafficking; to reduce the vulnerability of children and adults to sexual exploitation and
abuse; and to strengthen the capabilities of the FBI and federal, state, local, and
international law enforcement through training, intelligence-sharing, technical support,
and investigative assistance.
5. The defined priority threats that are aligned with the mission of the OC STOP TF are:
a. Human Trafficking
b. Child Sex Trafficking
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c. Adult Sex Trafficking
d. Forced Labor
e. Domestic Servitude
f. All other Human Trafficking matters within the FBI's jurisdiction
SUPERVISION AND CONTROL
A. Supervision
6. Overall management of the OC STOP TF shall be the shared responsibility of the FBI
and participating agency heads and/or their designees.
7. The Special Agent in Charge (SAC) of the FBI Los Angeles Field Office shall designate
one Supervisory Special Agent (OC STOP TF Supervisor) to supervise the OC STOP
TF. The OC STOP TF Supervisor may designate a Special Agent to serve as the OC
STOP TF Coordinator.
8. Conduct undertaken outside the scope of an individual's OC STOP TF duties and
assignments under this MOU shall not fall within the oversight responsibility of the OC
STOP TF Supervisor or OC STOP TF Coordinator. As stated in paragraph 77, below,
neither the United States nor the FBI shall be responsible for such conduct.
9. OC STOP TF personnel will report to his or her respective agency for personnel and
administrative matters. Each participating agency shall be responsible for the pay,
overtime, leave, performance appraisals, and other personnel matters relating to its
employees detailed to the OC STOP TF. The FBI and the participating agency may
provide for overtime reimbursement by the FBI by separate written agreement.
10.All FBI personnel will adhere to the FBI's ethical standards, including Department of
Justice (DOJ)/FBI regulations relating to outside employment and prepublication review
matters, and will remain subject to the Supplemental Standards of Ethical conduct for
employees of the DOJ.
11. All OC STOP TF personnel, which includes Task Force Officers, Task Force Members,
and Task Force Participants, must adhere to the applicable U.S. Attorney General's
Guidelines and Domestic Operations Investigative Guidelines (DIOG).
12. OC STOP TF personnel will continue to report to their respective agency heads for non-
investigative administrative matters not detailed in this MOU.
13. Continued assignment of personnel to the OC STOP TF will be based on performance
and at the discretion of appropriate management. The FBI SAC and OC STOP TF
Supervisor will also retain discretion to remove any individual from the OC STOP TF.
B. Case Assignments
14. The FBI OC STOP TF Supervisor will be responsible for opening, monitoring, directing,
and closing OC STOP TF investigations in accordance with existing FBI policy and the
applicable United States Attorney General's Guidelines.
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15. Assignments of cases to personnel will be based on, but not limited to, experience,
training, and performance, in addition to the discretion of the OC STOP TF Supervisor.
16. For FBI administrative purposes, OC STOP TF cases will be entered into the relevant
FBI computer system.
17. OC STOP TF personnel will have equal responsibility for each case assigned. OC
STOP TF personnel will be responsible for complete investigation from predication to
resolution.
C. Resource Control
18. The head of each participating agency shall determine the resources to be dedicated by
that agency to the OC STOP TF, including personnel, as well as the continued
dedication of those resources. The participating agency head or designee shall be kept
apprised of investigative developments by his or her subordinates.
OPERATIONS
A. Investigative Exclusivity
19. It is agreed that matters designated to be handled by the OC STOP TF will not
knowingly be subject to non-OC STOP TF law enforcement efforts by any of the
participating agencies. It is incumbent on each agency to make proper internal
notification regarding the OC STOP TF's existence and areas of concern.
20. It is agreed that there is to be no unilateral action taken on the part of the FBI or any
participating agency relating to OC STOP IF investigations or areas of concern as
described in paragraphs 4 and 5. All law enforcement actions will be coordinated and
cooperatively carried out.
21. OC STOP TF investigative leads outside of the geographic areas of responsibility for the
FBI will be communicated to other FBI offices for appropriate investigation.
B. Confidential Human Sources
22. The disclosure of FBI informants, or Confidential Human Sources (CHSs), to non-OC
STOP TF personnel will be limited to those situations where it is essential to the effective
performance of the OC STOP TF and only with prior FBI approval. These disclosures
will be consistent with applicable FBI guidelines and policy.
23. Non-FBI OC STOP TF personnel may not make any further disclosure of the identity of
an FBI CHS, including to other individuals assigned to the OC STOP TF. No documents
or information which identify, tend to identify, or may indirectly identify an FBI CHS may
be released without prior FBI approval.
24. In those instances where a participating agency provides a CHS, the FBI may become
solely responsible for the CHS's continued development, operation, and compliance with
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necessary administrative procedures regarding operation and payment as set forth by
the FBI.
25. The United States Attorney General's Guidelines and FBI policy and procedure for
operating FBI CHSs shall apply to all FBI CHSs opened and operated in furtherance of
OC STOP TF investigations. Documentation of, and any payments made to, FBI CHSs
shall be in accordance with FBI policy and procedure.
26. Operation, documentation, and payment of any CHS opened and operated in
furtherance of a OC STOP TF investigation must be in accordance with the United
States Attorney General's Guidelines, regardless of whether the handling agency is an
FBI OC STOP TF participating agency. Documentation of state, county, or local CHSs
opened and operated in furtherance of OC STOP TF investigations shall be maintained
at an agreed upon location.
C. Reports and Records
27. All investigative reporting will be prepared in compliance with existing FBI policy.
Subject to pertinent legal and/or policy restrictions, copies of pertinent documents
created by OC STOP TF personnel will be made available for inclusion in the respective
investigative agencies' files as appropriate.
28. OC STOP TF reports prepared in cases assigned to OC STOP TF personnel will be
maintained at an FBI approved location; original documents will be maintained by the
FBI.
29. Records and reports generated in OC STOP TF cases which are opened and assigned
by the OC STOP TF Supervisor with designated oversight for investigative and
personnel matters will be maintained in the FBI investigative file for OC STOP TF.
30. OC STOP TF investigative records maintained at the Los Angeles Field Office of the FBI
will be available to all OC STOP TF personnel, as well as their supervisory and
command staff subject to pertinent legal, administrative, and/or policy restrictions.
31. All evidence and original tape recordings (audio and video) acquired by the FBI during
the course of the OC STOP TF investigations will be maintained by the FBI. The FBI's
rules and policies governing the submission, retrieval, and chain of custody will be
adhered to by OC STOP TF personnel.
32.All OC STOP TF investigative records will be maintained at an approved FBI location.
Placement of all or part of said information into participating agency files rests with the
discretion of supervisory personnel of the concerned agencies, subject to OC STOP TF
Supervisor approval.
33. Classified information and/or documents containing information that identifies or tends to
identify an FBI CHS shall not be placed in the files of participating agencies unless
appropriate FBI policy has been satisfied and only with prior FBI approval.
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INFORMATION SHARING
34. Records or reports created or obtained by the OC STOP TF are the property of the FBI
and disclosure of such records, if it occurs, shall be pursuant to applicable federal law,
with the approval of FBI. If such records are shared outside of the OC STOP TF with
state and/or local law enforcement agencies, such records are merely loaned to the non-
Federal agency and are subject to retrieval by the FBI at its discretion. In the event that
the Anaheim Police Department, Santa Ana Police Department, Irvine Police
Department, Garden Grove Police Department and/or California Highway Patrol receive
a request pursuant to California's public records statute, Government Code sections
7920.000-7921.010, the civil or criminal discovery process, or other judicial, legislative, or
administrative process, to disclose OC STOP TF records, the Anaheim Police
Department, Santa Ana Police Department, Irvine Police Department, Garden Grove
Police Department and/or California Highway Patrol Police Department will immediately
notify the FBI of any such request in order to allow sufficient time for the FBI to seek to
prevent disclosure through appropriate channels, if necessary.
35. No information possessed by the FBI, to include information derived from informal
communications between OC STOP TF personnel and FBI employees not assigned to
the OC STOP TF, may be disseminated by OC STOP TF personnel to non-OC STOP TF
personnel without the approval of the OC STOP TF Supervisor and in accordance with
the applicable laws and internal regulations, procedures, or agreements between the FBI
and the participating agencies that would permit the participating agencies to receive that
information directly. Likewise, OC STOP TF personnel will not provide any participating
agency information to the FBI that is not otherwise available to it unless authorized by
appropriate participating agency officials.
36. The Parties acknowledge that this MOU may provide OC STOP TF personnel with
access to information about U.S. persons which is protected by the Privacy Act of 1974
and/or Executive Order 12333. The Parties expressly agree that all such information will
be handled lawfully pursuant to the provisions thereof. The Parties further agree that if
this access to information by OC STOP TF personnel requires a change in privacy
compliance documents, those changes will be accomplished prior to access being
granted.
37. Each Party that discloses personally identifiable information (PII) is responsible for
making reasonable efforts to ensure that the information disclosed is accurate, complete,
timely, and relevant.
38. The FBI is providing access to information from its records with the understanding that in
the event the recipient becomes aware of any inaccuracies in the data, the recipient will
promptly notify the FBI so that corrective action can be taken. Similarly, if the FBI
becomes aware that information it has received pursuant to this MOU is inaccurate, it will
notify the contributing Party so that corrective action can be taken.
39. Each Party is responsible for ensuring that information it discloses was not knowingly
obtained or maintained in violation of any law or policy applicable to the disclosing Party,
and that information is only made available to the receiving Party as may be permitted by
laws, regulations, policies, or procedures applicable to the disclosing Party.
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40. Each Party will immediately report to the other Party each instance in which data
received from the other Party is used, disclosed, or accessed in an unauthorized
manner(including any data losses or breaches).
41. Each party agrees to provide, upon request, details regarding the handling and
maintenance of data in electronic and paper recordkeeping systems maintained
pursuant to the provisions of this MOU, in order to allow the other party to ensure that
appropriate security and privacy protections are in place. Such information shall be
provided to the extent allowable by the laws, regulations, and policies governing each
party.
PROSECUTIONS
42. OC STOP TF investigative procedures, whenever practicable, are to conform to the
requirements which would allow for either federal or state prosecution.
43. A determination will be made on a case-by-case basis whether the prosecution of OC
STOP TF cases will be at the state or federal level. This determination will be based on
the evidence obtained and a consideration of which level of prosecution would be of the
greatest benefit to the overall objectives of the OC STOP TF.
44. In the event that a state or local matter is developed that is outside the jurisdiction of the
FBI or it is decided to prosecute an OC STOP TF case at the state or local level, the FBI
agrees to provide all relevant information to state and local authorities in accordance
with all applicable legal limitations.
A. Investigative Methods/Evidence
45. For cases assigned to an FBI Special Agent or in which FBI CHSs are utilized, the
Parties agree to conform to federal standards concerning evidence collection,
processing, storage, and electronic surveillance. However, in situations where the
investigation will be prosecuted in the State Court where statutory or common law of the
state is more restrictive than the comparable federal law, the investigative methods
employed by FBI case agents shall conform to the requirements of such statutory or
common law pending a decision as to venue for prosecution.
46. In all cases assigned to state, county, or local law enforcement participants, the Parties
agree to utilize federal standards pertaining to evidence handling and electronic
surveillance activities as outlined in the DIOG to the greatest extent possible. However,
in situations where the statutory or common law of the state is more restrictive than the
comparable federal law, the investigative methods employed by state and local law
enforcement agencies shall conform to the requirements of such statutory or common
law pending a decision as to venue for prosecution.
47. The use of other investigative methods (search warrants, interceptions of oral
communications, etc.) and reporting procedures in connection therewith will be
consistent with the policies and procedures of the FBI.
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B. Undercover Operations
48.All OC STOP TF undercover operations will be conducted and reviewed in accordance
with FBI guidelines and the United States Attorney General's Guidelines on FBI
Undercover Operations. All participating agencies may be requested to enter into an
additional agreement if an employee of the participating agency is assigned duties
which require the officer to act in an undercover capacity.
USE OF LESS-THAN-LETHAL-DEVICES'
49. The parent agency of each individual assigned to the OC STOP TF will ensure that
while the individual is participating in FBI-led task force operations in the capacity of a
task force officer, task force member, or task force participant, the individual will carry
only less lethal devices that the parent agency has issued to the individual, and that the
individual has been trained in accordance with the agency's policies and procedures.
50. The parent agency of each individual assigned to the OC STOP TF will ensure that the
agency's policies and procedures for use of any less-lethal device that will be carried by
the task force officer, task force member, or task force participant are consistent with the
DOJ policy statement on the Use of Less-Than-Lethal Devices.2
DEADLY FORCE AND SHOOTING INCIDENT POLICIES
51. OC STOP TF personnel will follow their own agencies' policies concerning firearms
discharge and use of deadly force.
DEPUTATIONS
52. Local and state law enforcement personnel designated to the OC STOP TF, subject to a
limited background inquiry, shall be sworn as federal task force officers by acquiring
Title 18 authority (via the United States Marshals) and Title 21 U.S.C. authority (via the
t Pursuant to Section VIII of the DOJ Less-Than-Lethal Devices Policy dated May 16, 2011, all state/local
officers participating in joint task force operations must be made aware of and adhere to the policy and its
limits on DOJ officers.
2 Less-lethal—When use of force is required, but deadly force may not be appropriate, law enforcement
officers may employ less-lethal weapons to gain control of a subject. Less-lethal weapons are designed
to induce a subject to submit or comply with directions. These weapons give law enforcement officers the
ability to protect the safety of officers, subjects, and the public by temporarily incapacitating subjects.
While less-lethal weapons are intended to avoid causing any serious harm or injury to a subject,
significant injuries and death can occur from their use.
The term "less-than-lethal" is synonymous with "less-lethal,""non-lethal," "non-deadly," and other terms
referring to devices used in situations covered by the DOJ Policy on the Use of Less-Than Lethal
Devices. "Less-lethal" is the industry standard and the terminology the FBI has elected to utilize in
reference to this policy.
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FBI, to participate in federal drug investigations). The FBI will secure the required
deputation authorization(s). These deputation(s) should remain in effect throughout the
tenure of each investigator's assignment to the OC STOP TF or until the termination of
the OC STOP TF, whichever comes first.
53. Deputized OC STOP TF personnel will be subject to the rules and regulations pertaining
to such deputation. Administrative and personnel policies imposed by the participating
agencies will not be voided by deputation of their respective personnel.
54. State, local, tribal, and territorial law enforcement officers (LEDs) who serve on the OC
STOP TF must be federally deputized under Title 18. They must also be deputized
under Title 21 to participate in federal drug investigations. The FBI may likewise require
federal LEOs who serve on the OC STOP TF to be deputized while assigned to the OC
STOP TF. The FBI will secure the required authorization for deputations, as needed.
55. Under the terms of this MOU, the Participating Agency agrees that non-LEOs detailed to
the OC STOP TF will not: (1) participate in law enforcement activities; (2) carry a
weapon, either lethal or non-lethal; or(3) participate in the execution of search/arrest
warrants.
VEHICLES
56. In furtherance of this MOU, employees of participating agencies may be permitted to
drive FBI owned or leased vehicles for official OC STOP TF business and only in
accordance with applicable FBI rules and regulations, including those outlined in the FBI
Government Vehicle Use Policy Guide (1093PG). The assignment of an FBI owned or
leased vehicle to participating agency OC STOP TF personnel will require the execution
of a separate Vehicle Use Agreement.
57. The participating agencies agree that FBI vehicles will not be used to transport
passengers unrelated to OC STOP TF business.
58. Neither the FBI nor the United States shall be responsible for any civil liability arising
from the use of an FBI owned or leased vehicle by OC STOP TF personnel while
engaged in any conduct other than their official duties and assignments pursuant to their
federal deputation on the OC STOP TF.
59. To the extent permitted by applicable law, the participating agencies agree to hold
harmless the FBI and the United States, for any claim for property damage or personal
injury arising from any use of an FBI owned or leased vehicle by OC STOP TF
personnel which is outside the scope of their official duties and assignments.
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SALARY/OVERTIME COMPENSATION
60. The FBI and each participating agency remain responsible for all personnel costs for
their OC STOP TF representatives, including salaries, overtime payments, and fringe
benefits consistent with their respective agency, except as described in paragraph 61
below.
61. Subject to funding availability and legislative authorization, the FBI will reimburse to
participating agencies the cost of overtime worked by non-federal OC STOP TF
personnel assigned full-time to OC STOP TF, provided overtime expenses were
incurred as a result of OC STOP TF-related duties, and subject to the provisions and
limitations set forth in a separate Cost Reimbursement Agreement to be executed in
conjunction with this MOU. A separate Cost Reimbursement Agreement must be
executed between the FBI and participating agencies for full-time employee(s) assigned
to OC STOP TF, consistent with regulations and policy, prior to any reimbursement by
the FBI. Otherwise, overtime shall be compensated in accordance with applicable
participating agency overtime provisions and shall be subject to the prior approval of
appropriate personnel.
PROPERTY AND EQUIPMENT
62. Property utilized by the OC STOP TF in connection with authorized investigations and/or
operations and in the custody and control and used at the direction of the OC STOP TF,
will be maintained in accordance with the policies and procedures of the agency
supplying the equipment. Property damaged or destroyed which was utilized by OC
STOP TF in connection with authorized investigations and/or operations and is in the
custody and control and used at the direction of OC STOP TF, will be the financial
responsibility of the agency supplying said property.
FUNDING
63. This MOU is not an obligation or commitment of funds, nor a basis for transfer of funds,
but rather is a basic statement of the understanding between the Parties hereto of the
tasks and methods for performing the tasks described herein. Unless otherwise agreed
in writing, each Party shall bear its own costs in relation to this MOU. Expenditures by
each Party will be subject to its budgetary processes and to the availability of funds and
resources pursuant to applicable laws, regulations, and policies. The Parties expressly
acknowledge that the above language in no way implies that Congress will appropriate
funds for such expenditures.
FORFEITURES
64. The FBI shall be responsible for processing assets seized for federal forfeiture in
conjunction with OC STOP TF operations.
65. Asset forfeitures will be conducted in accordance with federal law and the rules and
regulations set forth by the FBI and DOJ. Forfeitures attributable to OC STOP TF
investigations may be equitably shared with the agencies participating in the OC STOP
TF.
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DISPUTE RESOLUTION
66. In cases of overlapping jurisdiction, the participating agencies agree to work in concert
to achieve the OC STOP TF's objectives.
67. The participating agencies agree to attempt to resolve any disputes regarding
jurisdiction, case assignments, workload, etc., at the field level first before referring the
matter to supervisory personnel for resolution.
MEDIA RELEASES
68. All media releases and statements will be mutually agreed upon and jointly handled
according to FBI and participating agency guidelines.
69. Press releases will conform to DOJ Guidelines regarding press releases. No release
will be issued without FBI final approval.
SELECTION TO OC STOP TF AND SECURITY CLEARANCES
70. If a participating agency candidate for the OC STOP TF will require a security clearance,
he or she will be contacted by FBI security personnel to begin the background
investigation process prior to the assigned start date.
71. If, for any reason, the FBI determines that a participating agency candidate is not
qualified or eligible to serve on the OC STOP TF, the participating agency will be so
advised and a request will be made for another candidate.
72. Upon being selected, each candidate will receive a comprehensive briefing on FBI field
office security policies and.procedures. During the briefing, each candidate will execute
non-disclosure agreements (SF-312 and FD-868), as may be necessary or required by
the FBI.
73. Before receiving unescorted access to FBI space identified as an open storage facility,
OC STOP TF personnel will be required to obtain and maintain a "Top Secret" security
clearance. OC STOP TF personnel will not be allowed unescorted access to FBI space
unless they have received a Top Secret security clearance.
74. Upon departure from the OC STOP TF, each individual whose assignment to the OC
STOP TF is completed will be given a security debriefing and reminded of the provisions
contained in the non-disclosure agreement to which he or she previously agreed.
LIABILITY
75. The participating agencies acknowledge that this MOU does not alter the applicable law
governing civil liability, if any, arising from the conduct of personnel assigned to the OC
STOP TF.
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76. Each party agrees to notify the other in the event of receipt of a civil claim arising from
the conduct of personnel assigned to the OC STOP TF or otherwise relating to the OC
STOP TF. Both parties agree to cooperate fully with one another in the event of any
investigation arising from alleged negligence or misconduct arising from the OC STOP
TF operations. Nothing in this paragraph prevents any party from conducting an
independent administrative review of any incident giving rise to a claim. In the event
that a civil claim or complaint is brought against a state or local officer assigned to the
OC STOP TF, the officer may request legal representation and/or defense by DOJ,
under the circumstances and pursuant to the statutes and regulations identified below.
77. COMMON LAW TORT CLAIMS
A. Congress has provided that the exclusive remedy for the negligent or
wrongful act or omission of an employee of the U.S. Government, acting
within the scope of his or her employment, shall be an action against the
United States under the Federal Tort Claims Act, 28 U.S.C. § 1346(b), and §§
2671-2680.
B. Notwithstanding any other provision contained in this MOU, for the limited
purpose of defending civil claims arising out of[operational relationship]
activity, any employee detailed from a Participating Agency who is acting
within the course and scope of his or her official duties and assignments
pursuant to this MOU may be considered an "employee" of the U.S.
government, as defined at 28 U.S.C. § 2671. See 5 U.S.C. § 3374(c)(2).
C. Under the Federal Employee Liability Reform and Tort Compensation Act of
1998 (commonly known as the Westfall Act), see 28 U.S.C. § 2679(b)(I), if an
employee of the United States is named as a defendant in a civil action, the
Attorney General or his or her designee may certify that the defendant acted
within the scope of his or her employment at the time of the incident giving
rise to the suit. 28 U.S.C. § 2679(d)(1)&(2). The United States can then be
substituted for the employee as the sole defendant with respect to any tort
claims alleged in the action. 28 U.S.C. §2679(d)(1)&(2). Decisions to certify
that an employee was acting within the scope of his or her employment at the
time of the incident giving rise to the suit, see 28 U.S.C. § 2679(d)(1)&(2), are
made on a case-by case-basis, and such certification cannot be guaranteed.
D. If the Attorney General declines to certify that an employee was acting within
the scope of employment, "the employee may at any time before trial petition
the court to find and certify that the employee was acting within the scope of
his office or employment." 28 U.S. C. § 2679(d)(3).".
78. For the limited purpose of defending against a civil claim arising from an alleged
violation of the U.S. Constitution pursuant to 42 U.S.C. § 1983 or Bivens v. Six Unknown
Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388 (1971): An individual
assigned to the OC STOP TF who is named as a defendant in a civil action as a result
of or in connection with the performance of his or her official duties and assignments
pursuant to this MOU may request individual-capacity representation by DOJ to defend
against the claims. 28 C.F.R. §§ 50.15, 50.16. Any such request for individual-capacity
representation must be made in the form of a letter from the individual defendant to the
U.S. Attorney General. The letter should be provided to Chief Division Counsel (CDC)
for the FBI Los Angeles Division, who will then coordinate the request with the FBI
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Office of the General Counsel. In the event of an adverse judgment against the
individual, he or she may request indemnification from DOJ. 28 C.F.R. § 50.15(c)(4).
Requests for DOJ representation and indemnification are determined by DOJ on a case-
by-case basis. The FBI cannot guarantee the United States will provide legal
representation or indemnification to any OC STOP TF personnel.
79. Liability for any conduct by OC STOP TF personnel undertaken outside of the scope of
their duties and assignments pursuant to their federal deputation on the OC STOP TF
shall not be the responsibility of the FBI or the United States.
DURATION
80. The term of this MOU is for the duration of the OC STOP TF's operations, contingent
upon approval of necessary funding, but may be terminated at any time upon written
mutual consent of the agency involved.
81.Any participating agency may withdraw from the OC STOP TF at any time by written
notification to the OC STOP TF Supervisor with designated oversight for investigative
and personnel matters or program manager of the OC STOP TF at least 30 days prior to
withdrawal.
82. Upon termination of this MOU, all equipment provided to the OC STOP TF will be
returned to the supplying agency/agencies. In addition, when an entity withdraws from
the MOU, the entity will return equipment to the supplying agency/agencies. Similarly,
remaining agencies will return to a withdrawing agency any unexpended equipment
supplied by the withdrawing agency during any OC STOP TF participation.
MODIFICATIONS
83. This agreement may be modified at any time by written consent of all involved agencies.
84. Modifications to this MOU shall have no force and effect unless such modifications are
reduced to writing and signed by an authorized representative of each participating
agency.
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SIGNATORIES
Special Agent in Charge Date
Federal Bureau of Investigation
Chief Date
Anaheim Police Department
V... \1(2.1..A._... IIMI-7-Lf
Chief Date
Santa Ana Police Department
Chief Date
Irvine Police Department
Border Division Chief Date
California Highway Patrol
Chief Date
Garden Grove Police Department
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IN WITNESS WHEREOF, the parties hereto have executed this Agreement the date and year
first above written.
ATTEST: CITY OF SANTA ANA
` am
IF '_ . H L • ALVARO NUNEZ
City - - City Manager
APPROVED AS TO FORM:
SONIA R. CARVALHO
City Attorney
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By: /./,//J
TAMARA BO OSIAN
Senior Assistant City Attorney
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FEDERAL BUREAU OF INVESTIGATION
OC STOP TASK FORCE
Cost Reimbursement Agreement
FOCSTOP] File No.:
Pursuant to Congressional appropriations, the Federal Bureau of Investigation (FBI) receives authority to pay
overtime for police officers assigned to the formalized OC STOP TF as set forth below, for expenses
necessary for detection, investigation, and prosecution of crimes against the United States. It is hereby agreed
between the FBI and City of Santa Ana and Santa Ana Police Department (SAPD), located at 60 Civic Center
Plaza, Santa Ana, California 92701, Taxpayer Identification Number: 95-6000785, and Telephone Number:
(714) 245-8665, that:
1. This Agreement is entered into pursuant to, and as an annex to, the FBI OC STOP TF Memorandum of
Understanding (MOU) signed by the Acting Chief of Police, Robert Rodriguez on , 2024,
and shall be read and interpreted in conformity with all terms of that document.
2. Commencing upon execution of this Agreement, the FBI will, subject to availability of required funding,
reimburse SAPD for overtime payments made to officers assigned to and working full time on OC STOP TF
related matters.
3. Requests for reimbursement shall be made on a monthly basis utilizing the United States Department
of the Treasury Invoice Processing Platform (IPP) software system and shall be submitted to the FBI Los
Angeles Field Office immediately after the first of the month which follows the month for which reimbursement
is requested. The reimbursement request shall be approved by the appropriate Supervisor (or their designee)
at SAPD prior to the invoice submission in IPP. The invoice submitted in IPP will automatically route to the FBI
OC STOP TF personnel for their review, approval, and processing for payment.
4. Overtime reimbursement payments from the FBI will be made via electronic funds transfer(EFT)
directly to SAPD using the FBI's Unified Financial Management System (UFMS). To facilitate EFT, SAPD shall
establish an account online in the System for Award Management (SAM) at www.SAM.qov. Verification of
SAPD banking information is required on an annual basis in order to keep payment information current. For
additional information regarding the UFMS and SAM, contact the FBI Los Angeles Financial Liaison Specialist.
5. Overtime reimbursements will be calculated at the usual rate for which the individual officer's time
would be compensated in the absence of this Agreement. However, said reimbursement, per officer, shall not
exceed monthly and/or annual limits established annually by the FBI. The limits, calculated using Federal pay
tables, will be in effect for the Federal fiscal year running from October 1st of one year through September 30th
of the following year, unless changed during the period. The FBI reserves the right to change the
reimbursement limits, upward or downward, for subsequent periods based on fiscal priorities and
appropriations limits. The FBI will notify SAPD of the applicable annual limits prior to October 1st of each year.
6. The number of SAPD deputies assigned full-time to the OC STOP TF and entitled to overtime
reimbursement by the FBI shall be approved by the FBI in advance of each fiscal year. Based on the needs of
the OC STOP TF this number may change periodically, upward or downward, as approved in advance by the
FBI.
1
For Official 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 FBI Headquarters.
Revised 05/24/2022
7. Prior to submission of any overtime reimbursement requests, SAPD shall prepare an official
document setting forth the identity of each officer assigned full-time to the OC STOP TF, along with the
regular and overtime hourly rates for each officer. Should any officers change during the fiscal year, a
similar statement shall be prepared regarding the new officers prior to submitting any overtime
reimbursement requests for the officers. If the rate changes during the fiscal year for a previously
assigned officer, an updated letter shall be attached with the invoice submission in IPP that reflects the
new rate. The updated letter shall be mailed to the Los Angeles Field Office OC STOP TF personnel to
maintain in FBI records.
8. Each request for reimbursement shall be submitted via IPP to the FBI. The request for
reimbursement shall include an invoice number, invoice date, the name, overtime compensation rate,
number of reimbursable hours claimed, and the dates of those hours for each officer for whom
reimbursement is sought. An attachment signed and dated by an authorized Agency representative
noting the dates and hours for each officer overtime reimbursement claimed shall be uploaded in IPP
as supporting documentation for the invoice to confirm the information described in this paragraph is
accurate, and the personnel for whom reimbursement is claimed were assigned full-time to the OC
STOP TF.
9. Requests for reimbursement shall be submitted monthly and all requests shall be received by
the FBI no later than December 31st of the next fiscal year for which the reimbursement applies. For
example, reimbursements for the fiscal year ending September 30, 2024, shall be received by the FBI
monthly and not later than December 31, 2024. The FBI is not obligated to reimburse any requests
received untimely and not in accordance herewith.
10. This Agreement is effective upon signatures of the parties and will remain in effect for the
duration of SAPD's participation on the OC STOP TF contingent upon approval of necessary funding,
and unless terminated in accordance with the provisions herein. This Agreement may be modified at
any time by written consent of the parties or based on changing business operations and practices of
the FBI. It may be terminated at any time 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.
Signatories:
See attached signature page
By: ROBERT RODRIGUEZ
Title: Acting Chief of Police
Federal Bureau of Investigation Santa Ana Police Department
Date: Date:
Financial Liaison Specialist
Federal Bureau of Investigation
Date:
2
For Official 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 FBI Headquarters.
IN WITNESS WHEREOF, the parties hereto have executed this Agreement the date and year
first above written.
ATTEST: CITY OF ANTA AN
aAA
IAA'Z •
•
ER H L :N' LVARO NUNEZ
City City Manager
APPROVED AS TO FORM: RECOMMENDED FOR APPROVAL:
SONIA R. CARVALHO
City Attorney
By: /1 t.
TAMARA BOGOSIAN ROBERT RODRIGUEZ
Senior Assistant City Attorney Acting Chief of Police