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UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA

ZELAIDO RIVERA GARCIA, MAURA GONZALEZ SALINAS, ADRIAN RAMIREZ-CUEVAS, CAMERINA CUEVAS LOPEZ, KATHLEEN YANKOVIC, JOHN YANKOVIC,

Case No. _______________________

Plaintiffs,

v.

METRO GANG STRIKE FORCE, RON RYAN, former Metro Gang Strike Force Commander, DOE OFFICERS 1-34, individually and in their official capacities, OTHER UNKNOWN DOE OFFICERS, METRO GANG STRIKE FORCE ADVISORY BOARD, MANILA (“BUD”) SHAVER, Chief of the West ST. Paul Police Department, KEN SCHILLING, Inspector at the Hennepin County Sheriff’s Office, DAVE BELLOWS, Chief Deputy of the Dakota County Sheriff’s Office, BOB FLECTCHER, Sheriff of the Ramsey County Sheriff’s Office, JOHN HARRINGTON, Chief of the St. Paul Police Department, ROB ALLEN, Deputy Chief of the Minneapolis Police Department, BILL HUTTON, Sheriff of the Washington County Sheriff’s Office, DAVE THOMALLA, Chief of the Maplewood Police Department, DAVE PECCHLA, Chief of the Lino Lakes Police Department, DAVE

CLASS ACTION COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
JURY TRIAL DEMANDED

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INDREHUS, Chief of the Metro Transit Police Department, MICHAEL DAVIS, Chief of the Brooklyn Park Police Department, BARRY FRITZ, Captain of the Richfield Police Department,
Defendants.
1. This is a class action brought by Plaintiffs, on behalf of themselves and others similarly-situated, to recover damages and to impose injunctive relief under the Civil Rights Act, 42 U.S.C. § 1981, § 1983 et seq. (“CRA”), to recover monetary damages for negligence in the supervision and training of law enforcement employees and for liability based on respondeat superior, to recover monetary damages for civil tort conversion and conspiracy to convert, for civil tort of assault, for civil tort of false imprisonment, and for violations of the Minnesota State Constitution. Plaintiffs seek remedies for themselves and the Class and Subclass for Defendants’ negligence and unlawful deprivation of Plaintiffs’ and class members’ property and liberty.
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PARTIES Plaintiffs Zelaido Rivera Garcia 2. Plaintiff Zelaido Rivera Garcia is now, and at all relevant times was, a resident of the City of Minneapolis, residing at 3816 – 24th Avenue, No. 1, Minneapolis, Minnesota. 3. All acts hereinafter alleged occurred on or about July 31, 2008. All officers were acting in their individual and official capacity, and contrary to law. 4. On or about July 31, 2008, the Plaintiff and his spouse drove to the City of Minneapolis impound lot with the lawful intent to pay the designated fee to release a motor vehicle. 5. After Plaintiff’s arrival at the impound lot, Defendant Officers appeared and detained the Plaintiff and numerous other undocumented individuals who are putative class members of the herein alleged class. 6. Prior to informing the United States Immigration and Customs Enforcement (“ICE”), each of the persons, including Plaintiff Garcia, was frisked and searched. 7. No drugs or contraband were discovered; however, the personal property on Plaintiff Garcia’s person was taken and he was placed on a
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nearby automobile hood, with the exception of $100 cash, which was taken by the Metro Gang Strike Force Officers.
8. At said time and place as alleged above, unknown Metro Gang Strike Force Officers illegally confiscated $100 from Plaintiff Garcia’s wallet. Plaintiff was not aware of the taking until his wallet was returned without the $100. Plaintiff Garcia protested that his money was taken, but did not get it back, nor was he given any administrative notice of forfeiture of rights, pursuant to law.
9. Somewhat later in time, the Minnesota Gang Strike Force Officers, telephone representative of ICE, took Plaintiff Garcia and other undocumented persons at the impound lot to jail.
Maura Gonzalez Salinas 10. Plaintiff Maura Gonzalez Salinas is now, and at all relevant times was, a resident of the City of Minneapolis, residing at 2932 -15th Avenue South, No. 1, Minneapolis, Minnesota. 11. All acts hereinafter alleged occurred on or about June 2, 2009. At such time and place all officers were acting in their individual and official capacity, and contrary to law. 12. On or about June 2, 2009, numerous Metro Gang Strike Force Officers and Minneapolis Police Department Officers came to Plaintiff
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Salinas’ apartment seeking to arrest her son, Paul Salinas for an alleged probation violation.
13. Subsequent to their arrival at Plaintiff Salinas’ apartment, the Metro Gang Strike Force rounded up the family, insulted their national origin by stating multiple times that “Spanish is bullshit,” and also ridiculed the foods eaten by Hispanic persons. During the search of Plaintiff Salinas’ apartment, no drugs or contraband were discovered; however, Plaintiff Salinas’ personal property was taken by the Metro Gang Strike Force and converted to their use.
14. Unknown Metro Gang Strike Force Officers illegally confiscated $900 in cash from Plaintiff Salinas’ personal clothing drawer, as well as a 24k gold necklace worth approximately $600. Plaintiff Salinas was unaware that the cash and jewelry were taken until the police officers left the premises.
15. At no time during the search of Plaintiff Salinas’s apartment, or subsequent thereto, did the Metro Gang Strike Force Officers issue any inventory receipt for certain material taken. The officers did list a receipt for inventory taken, but the Metro Gang Strike Force failed to record and note that they had taken $900 cash and the 24k gold necklace.
16. On June 2, 2009, Plaintiff Salinas was the owner and possessor of the $900 cash and the 24k gold necklace. The cash was intended to pay her
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next month’s rent. As a result of the taking of the cash, Plaintiff Salinas was unable to pay her rent and had to vacate the premises.
Adrian Ramirez-Cuevas and Camerina Cuevas Lopez 17. Plaintiffs Adrian Ramirez-Cuevas and Camerina Cuevas Lopez are now, and and at all relevant times were, residents of the City of Crystal, residing at 4323 Xenia Avenue North, Crystal, Minnesota. 18. All acts hereinafter alleged occurred on or about July 28, 2008, at the former apartment of Plaintiffs, namely, the Kentucky Lane Apartments in Crystal, Minnesota. At such time and place all officers were acting in their individual and official capacity, and contrary to law. 19. On or about July 31, 2008, Plaintiff Adrian Cuevas and his father, Norverto Cuevas, were at the apartment complex. 20. Plaintiff Adrian Cuevas was outside the apartment and had recognized the Metro Gang Strike Force Officers from a previous encounter. At that time, one or more of the Metro Gang Strike Force Officers knocked Plaintiff Adrian Cuevas down, handcuffed him, and took his keys away from him. Plaintiff Adrian Cuevas did not give the officers consent to enter Plaintiff Adrian Cuevas’ apartment. 21. The officers entered the apartment of Plaintiff Adrian Cuevas, without a warrant and without the consent of Plaintiff Adrian Cuevas, and apprehended Norverto Cuevas, throwing him to the ground, breaking one of
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his teeth. One of the Metro Gang Strike Force officers placed his foot on Norverto Cuevas’ head to restrain him. Noverto Cuevas asked if any of the officers had a search warrant.
22. Once inside the premises, the officers literally tore up the apartment and conducted a search for drugs within the apartment. Plaintiff Cuevas’ apartment contained no drugs or contraband.
23. At said time and place as alleged above, unknown members of the Metro Gang Strike Force Officers illegally confiscated approximately $2,800 from Plaintiff Adrian Cuevas’ apartment. Plaintiff Adrian Cuevas was not aware of the taking of the money until after the officers left the premises. Approximately $2,000 was the property of Plaintiff Camerina Cuevas Lopez and said money was part of a savings club, “Comida,” which is a traditional way the family saves money. The remaining money was partially owned by Plaintiff Adrian Cuevas and his father Norverto Cuevas, who has subsequently been removed to Mexico.
24. At said time and place as alleged above, the unknown Metro Gang Strike Force Officers illegally confiscated money from Plaintiffs Adrian Ramirez-Cuevas and Camerina Cuevas Lopez, who were the owners and possessors of the above-described property.
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Kathleen and John Yankovic 25. Plaintiffs Kathleen and John Yankovic are now, and at all relevant times were residents of the City of St. Paul, residing at 1799 N. Edgerton Street, St. Paul. 26. At such time and place all officers were acting in their individual and official capacity, and contrary to law. 27. On June 12, 2008, Plaintiff Kathleen Yankovic and her husband were the owners and possessors of property and jewelry valued in excess of $7,500, having purchased the property on previous dates. Defendant Metro Gang Strike Force Officers unlawfully took and carried away Plaintiffs Yankovics’ property and converted and disposed of it to their own use to the Plaintiffs’ damage, in excess of $7,500. 28. When Plaintiff Kathleen Yankovic protested, stating that the property should not be taken by the police, the Officers laughed and made light of Plaintiff Kathleen Yankovic’s protests and converted the property to their own use. 29. Plaintiff Kathleen Yankovic was given an inventory receipt, but many of the items that were taken from Plaintiff’s home on the date and time in question were not formally noted, nor was Plaintiff given administrative notice as to how she might reacquire the property.
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Defendants 30. In 2005, the Minnesota Legislature enacted Minnesota Statute, section 299A.641, which created the Gang and Drug Oversight Council and mandated that the Council establish the Metro Gang Strike Force (“MGSF”). This fiat dissolved the existing Minnesota Gang Strike Force. Governmental Units 31. The following Governmental Units are parties to the ensuing Joint Powers Agreement Creating the Metro Gang Strike Force (“Agreement”), used to implement the legislative mandate: City of West St. Paul, a municipal corporation; Hennepin County, a direct political subdivision of the State; Dakota County, a direct political subdivision of the State; Ramsey County, a direct political subdivision of the State; City of St. Paul, a municipal corporation; City of Minneapolis, a municipal corporation; Washington County, a direct political subdivision of the State; City of Maplewood, a municipal corporation; City of Lino Lakes, a municipal corporation; City of Brooklyn Park, a municipal corporation; City of Richfield, a municipal corporation;
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Metropolitan Council.1 Each of these Governmental Units assigns from its law enforcement agency or agencies its Chief Law Enforcement Officer, or his or her designee, to be a member of the Metro Gang Strike Force Advisory Board. The Governmental Units also provided police officers to act as MGSF personnel and to carry out the organization’s purpose. However, those police officers never became employees of the MGSF. While the Board and the Metro Commander had a contractual duty to oversee and supervise the activities of MGSF personnel, the Governmental Units remained at all times the employer responsible for the acts of their employee police officers acting in this scope of their employment. Governmental Units were negligent in their duty to train and supervise their employee police officers, resulting in damages to Plaintiffs and class members.
Defendant Board and Board Members 32. Defendant Metro Gang Strike Force Advisory Board (“the Board”) comprises the chief law enforcement officers (or their designees) from the agencies that participate in the MGSF. The Board was responsible for
1 These entities have not yet been named as Defendants in this action pursuant to Minn. Stats. 373.06 and 466.05. Although Plaintiffs believe these entities have been provided actual notice of the tort claims for which they are liable, Plaintiffs have provided redundant notices to these entities and reserve the right to amend their complaint to join them once statutory notice requirements have been satisfied.
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supervising the Metro Commander. These Defendant Board members include:
Chair Manila (“Bud”) Shaver, Chief of the West St. Paul Police Department, Vice-Chair Ken Schilling, Inspector at the Hennepin County Sheriff’s Office, Dave Bellows, Chief Deputy of the Dakota County Sheriff’s Office, Bob Fletcher, Sheriff of the Ramsey County Sheriff’s Office, John Harrington, Chief of the St. Paul Police Department, Rob Allen, Deputy Chief of the Minneapolis Police Department, Bill Hutton, Sheriff of the Washington County Sheriff’s Office, Dave Thomalla, Chief of the Maplewood Police Department, Dave Pecchla, Chief of the Lino Lakes Police Department, Dave Indrehus, Chief of the Metro Transit Police Department, Michael Davis, Chief of the Brooklyn Park Police Department, and Barry Fritz, Captain of the Richfield Police Department. The Joint Powers Agreement required the Board to select and supervise the Metro Commander, approve the selection of participating officers, set the priorities for the work of the MGSF, and approve all expenditures of the MGSF. The Board and its members were negligent in their duty to train and supervise their employee police officers, resulting in damages to Plaintiffs
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and class members. Plaintiffs sue all defendants in both their individual and official capacities.
Joint Venture 33. Defendant MGSF is an entity created pursuant to Minnesota Statutes § 471.59, and § 299A.641, subd. 3, to coordinate the efforts of Defendant Governmental Units to prevent and investigate gang crimes. Metro Commander 34. The Joint Powers Agreement required a Metro Commander to provide effective leadership and administrative coordination, direct officer assignments, oversee field operations, foster communication and cooperation with other law enforcement agencies in and outside the geographic region, and identify and facilitate necessary training for MGSF officers. 35. Defendant Ron Ryan was the Metro Commander of the MGSF. His tenure as Commander ended on October 10, 2008, when he retired. He had been Commander of the MGSF, and its predecessor entity, the Minnesota Gang Strike Force, for over 11 years. Plaintiffs sue Defendant Ryan in both his individual and official capacities. MGSF Personnel 36. Governmental Units, Defendants to be added later, were required to recommend and provide licensed peace officers from their own law enforcement agencies to serve as MGSF personnel. However, MGSF Officers
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at all times remained employees of their respective Governmental Units and were expressly not considered employees of the MGSF. Disciplinary matters were to be referred not to the Board, but to the Governmental Units’ law enforcement agencies for investigation and disposition. Defendant Doe Officers 1-34 were at all times operating as loaned officers to the MGSF, acting within the course and scope of employment as a peace officer and were part of the MGSF at the time it became defunct on July 17, 2009. Other unknown officer Defendants were officers on assignment to the MGSF, acting within the course and scope of employment, during times relevant to this action, but ceased to be MGSF personnel sometime prior to July 17, 2009. Plaintiffs sue all defendants in both their individual and official capacities.
JURISDICTION AND VENUE 37. The Court has jurisdiction over Plaintiffs’ federal claims under 28 U.S.C. §§ 1331 and 1337. The Court has jurisdiction over Plaintiffs’ common law claims under 28 U.S.C. § 1367 because those claims are so related to the federal claims that they form part of the same case or controversy. 38. The MGSF had offices, conducted its affairs, housed paperwork, and carried out its investigations in this District. Some Plaintiffs and class members were injured by Defendants in this District. A substantial part of the events and omissions giving rise to this action thus occurred in this
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District. Venue is therefore proper in this District pursuant to 28 U.S.C. § 1391(b).
39. Plaintiffs and proposed class representatives are asserting claims relating to the negligence of the Governmental Units, the Board, and the MGSF, due to the unlawful deprivation by MGSF Officers of Plaintiffs’ personal property. As a direct, proximate and foreseeable cause of Defendants’ negligent and unlawful conduct, the Plaintiffs and proposed class members each sustained damages.
FACTS 40. Governmental Units and Defendant Board and Board members breached their duty to train, supervise, and discipline the improper acts of their MGSF Officers who failed to provide receipts, inventory lists, and notices of the right to object to forfeitures, to Plaintiffs and putative class members. 41. Members of the MGSF engaged in a pattern and practice of using their apparent authority as police officers to extort cash and property from people coming into contact with the MGSF, particularly from those concerned about their immigration status who would naturally perceive that they had no ability to assert legal rights. While undocumented status can subject an alien to removal proceedings, it is not a crime. Yet, the members of this governmental “joint venture,” whose purpose and scope is expressly limited to
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preventing and investigating gang “crimes,” intentionally targeted victims for purposes of extortion. In most instances, this illegal conduct by the MGSF and its officers against these Plaintiffs and putative class members was based on their immigration status or other vulnerability, ostensibly as though they were under investigation for or accused of a crime.
42. A targeted, deliberate place to conduct their thefts was the Minneapolis Impound Lot, where persons, including vulnerable aliens, would attempt to pick up their vehicles. MGSF Officers would often call the impound lot and ask if there were any “Mexicans” there attempting to pick up vehicles. MGSF Officers would show up at the impound lot, detain and search the individual, seize cash, the vehicle for forfeiture, or both; then, send the individual on his or her way without a receipt for the taken property. On many occasions, ICE officers were called to expedite the removal of aliens, which further precluded them from seeking legal redress to reacquire their rightful property.
43. MGSF Officers also engaged in the repeated practice of taking cash and personal property out of the homes of those on whom the police were serving a warrant, even though the cash or personal property was neither contraband nor evidence, nor listed in the warrant as items to be seized. MGSF Officers would then take the seized items without providing a receipt or inventory for the taken property.
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44. MGSF Officers also seized vehicles and property without providing Plaintiffs and putative class members with due process and with proper notice, in the native language of Plaintiffs and class members, pursuant to Minnesota Statutes, section 609.5314. According to the statute, said notice is required to be given to anyone from whom the police seize property for forfeiture, of the opportunity to be heard and the right to object to the forfeiture.
CLASS ALLEGATIONS 45. Plaintiffs sue on their own behalf and on behalf of a class of persons under Rules 23(a) and 23(b)(2) and (b)(3) of the Federal Rules of Civil Procedure. This action satisfies the numerosity, commonality, typicality, adequacy, predominance and superiority requirements of those provisions. 46. The Class is defined as: All persons who have been stopped, questioned, arrested, frisked, detained, searched, or any combination, by an Officer or Officers serving on the MGSF, and whose property was taken without a receipt or inventory itemization and without notification of their right to contest the forfeiture. 47. The Subclass is defined as: All persons who have been stopped, questioned, arrested, frisked, detained, searched, or any combination, based on their national origin, by an Officer or Officers serving on the MGSF, and whose property was taken without a receipt or inventory itemization and without notification of their right to contest the forfeiture.
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Excluded from the class are those whose encounters with MGSF Officers resulted in their indictment or other duly filed criminal complaint by a criminal prosecuting authority.
48. Numerosity: Plaintiffs do not know the exact size of the proposed Class or Subclass, or the identities of all their members because such information is in the exclusive control of Defendants. Plaintiffs, however, believe that the Class and Subclass encompass at least 200 individuals. Therefore, the Class is so numerous that joinder of all members is impracticable.
49. Commonality/Predominance: All members of the Class have been subject to and affected by the same conduct. There are questions of law and fact that are common to the Class, and predominate over any questions affecting only individual members of the Class. These questions include, but are not limited to:
a. whether Governmental Units owed a duty of care to properly train and supervise its employee police officers, who came into contact with Plaintiffs and class members;
b. whether Governmental Units had sufficient policies and procedures in place to ensure that their officers were trained and supervised properly;
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c. whether the lack of Governmental Units’ training, supervision, policies, and procedures caused police officers loaned to the MGSF to develop a pattern and practice of engaging in improper forfeiture practices pursuant to Minn. Stat. § 609.5314 without detection for many years;
d. whether Governmental Units are the true employers of MGSF Officer;
e. whether Governmental Units are also vicariously responsible for the acts of MGSF Officers based on respondeat superior principles;
f. whether Defendant Board and Board Members owed a duty of care to properly train and supervise its employee police officers, who came into contact with Plaintiffs and class members;
g. whether Defendant Board and Board Members had sufficient policies and procedures in place to ensure that their officers were trained and supervised properly;
h. whether the lack of Defendant Board’s and Board Members’ training, supervision, policies, and procedures caused police officers loaned to the MGSF to develop a pattern and practice of engaging in improper forfeiture practices without detection for many years;
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i. whether Defendants were required to provide receipts of seized property;
j. whether Defendants were required to provide notices of the right to contest the forfeiture of property;
k. whether Defendants repeatedly failed to provide receipts of seized property;
l. whether Defendants repeatedly failed to provide notice of the right to contest the forfeitures as required by Minnesota law (Minn. Stat. § 609.5314);
m. whether Defendants acted under color of law when improperly seizing property;
n. whether Defendants failed to create records of seized property and incidents leading to the seizure of property;
o. whether Defendants failed to properly maintain records of seized property and incidents leading to the seizure of property;
p. whether Metro Commander Defendant Ryan was aware of the pattern of improper seizures and forfeitures;
q. whether Metro Commander Defendant Ryan agreed and conspired with MGSF officers to commit illegal acts;
r. whether Metro Commander Defendant Ryan committed an overt act in furtherance of the conspiracy;
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s. whether the MGSF retained seized property; t. whether the MGSF had a pattern and practice of targeting and
exploiting individuals of foreign national origin; u. whether the MGSF had a pattern and practice of targeting and
exploiting individuals who were suspected of committing crimes, but were never prosecuted after their property was illegally taken; v. whether the Board or Board members should have been aware of the pattern of improper seizures and forfeitures; w. whether Governmental Units should have been aware of the pattern of improper seizures and forfeitures; x. whether Defendants affirmatively abandoned their duty to supervise MGSF personnel. 50. Typicality: The claims of the named Plaintiffs are typical of the claims of the Class and Subclass and do not conflict with the interests of any other members of the Class or Subclass in that both the Plaintiffs and the other members of the Class were subjected to search and seizure without the provision of a receipt or notice of ability to contest the forfeiture. Prosecution of Plaintiffs’ claims will inure to the benefit of the entire proposed class. 51. Adequacy: The named Plaintiffs will fairly and adequately represent the interests of the Class. Plaintiffs are committed to the vigorous
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prosecution of the Classes’ claims and have retained attorneys who are qualified to pursue this litigation and have experience in class actions. Neither Plaintiffs nor counsel have any interest adverse to those of Class members.
52. Superiority: A class action is superior to other methods for the fast and efficient adjudication of this controversy. A class action regarding the issues in this case does not create any problems of manageability.
53. In the alternative, Defendant has acted or refused to act on grounds generally applicable to the Classes, thereby making appropriate, final injunctive relief or corresponding declaratory relief with respect to the class as a whole.
LEGAL BASES FOR RELIEF COUNT I
Violation of the Civil Rights Act 42 U.S.C. § 1983 (Monell Claim) (Against MGSF Advisory Board and Defendant Ryan2) 54. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 55. Defendant MGSF Advisory Board and Defendant Ryan, through their employees and members, failed to properly train, supervise, and discipline the MGSF members who violated Plaintiffs’ constitutional rights.
2 Plaintiffs will add Governmental Units as a Defendant to this legal theory after notice has issued.
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Therefore, the unconstitutional and illegal actions of the MGSF members were carried out pursuant to an unconstitutional policy, procedure, or practice of Defendant MGSF Advisory Board, in violation of Plaintiffs’ and class members’ Fourth, Fifth, and Fourteenth Amendment Rights.
56. Governmental Units were responsible for appointing, supervising, training, disciplining, and terminating all law enforcement officers and other employees of their respective law enforcement agencies. Governmental Units were the employers of MGSF personnel and were responsible for providing supervision and training for their law enforcement officers.
57. Governmental Units and Defendant Board and Board Members had actual knowledge that unless MGSF law enforcement officers were well trained and supervised pertaining to the appropriate police procedures, members of the public were subject to having their property forfeited without due process.
58. Governmental Units and Defendant Board and Board Members knew, or in the exercise of reasonable care, should have known, that the problem of improper forfeitures was a prevalent problem existing in the Twin Cities Metro Area through the unlawful operation of the MGSF that they duly created and managed.
59. Governmental Units and Defendant Board and Board Members failed to take steps to train and supervise their respective law enforcement
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officers and staff and failed to establish adequate procedures to ensure that members of the public, such as the Plaintiffs and other putative class members, were not subjected to unlawful forfeiture procedures and activities.
60. Governmental Units and Defendant Board and Board Members failed to establish policies and procedures, substantially resulting in the rampant, improper use of forfeiture procedures.
61. At all times material, the Defendants’ actions or failures to act became a custom or policy resulting in the deliberate indifference to constitutional rights of citizens including the Plaintiffs.
62. At all times material, the Defendants either instituted an improper policy or an absence of a policy for the necessary and proper execution of their duties; and, such failures resulted in the deliberate indifference to the constitutional rights of citizens including the Plaintiff.
63. The Legislative Auditor found that the MGSF failed to have sound fiscal management. The failure to establish a system of creating receipts and complete inventory lists and of basic accounting for all forfeited property constituted a failure on the part of Governmental Units and Defendant Board and Board Members to establish appropriate procedures and to supervise and train their law enforcement personnel, which was so severely deficient as to reach the level of gross negligence and deliberate indifference to the deprivation of constitutional rights of members of the public, including
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Plaintiffs and putative class members. Hennepin County Sheriff Rich Stanek admitted that the recent revelation that West St. Paul Police Chief, and MGSF Chair, Bud Shaver asked the MGSF not to seize his own automobile, used in the commission of an alleged crime, was merely “one in a series of things that hurt the [MGSF]’s credibility, to the point where I didn’t think it had much value on behalf of the citizens of Hennepin County or the law enforcement agencies on the Hennepin County side.” “At the very least,” Stanek said, “I think people agree there was lack of managerial oversight [of MGSF officers].”
64. Governmental Units and Defendant Board and Board Members failed to supervise, train, and discipline their law enforcement officers and personnel, their failure to establish appropriate procedures to prevent improper forfeiture procedures resulted in a deprivation of rights, privileges and immunities guaranteed to the Plaintiff under the Constitution and laws of the United States.
65. As a proximate result of Defendant’s systematic violation of this statute, Plaintiffs and the class are entitled to the requested relief provided under the Act.
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COUNT II Violation of the Civil Rights Act
42 U.S.C. § 1981 (Against Board, Board Members, Ryan, Officers 1-34 and Other Unknown Officers3 by Plaintiffs Garcia, Salinas, Ramirez- Cuevas,
Lopez, and Subclass members) 66. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 67. The Civil Rights Act ascribes to every person within the jurisdiction of the United States the right to the full and equal benefit of all laws and proceedings for the security of persons and property as is enjoyed by white citizens. 68. The MGSF intentionally discriminated against Plaintiffs and the class by targeting them due to their national origin. As undocumented aliens, Plaintiffs and class members were particularly vulnerable because they 1) typically do not have bank accounts, and so often carried cash4 and 2) perceived themselves as having no rights and no ability to defend themselves from civil malfeasance. Members of the MGSF knew of these vulnerabilities and exploited them for personal gain.
3 Plaintiffs will add Governmental Units as a Defendant to this legal theory after notice has issued. 4 See, Remarks of Martin J. Gruenberg, Vice Chairman, FDIC at IADI’s Sixth Annual International Conference; Kuala Lumpur, Malaysia; November 1, 2007.
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69. Members of the MGSF took targeted persons based on their Latino national origin, converted their property without any process, and failed to account for the property in any way, whether through receipt or inventory recordation. Governmental Units, Defendant Board, Board Members, Metro Commander, the MGSF, and Officers are liable for these violations.
70. As a proximate result of Defendants’ systematic violation of this statute, Plaintiffs and the class are entitled to the requested relief provided under the Act.
COUNT III Violation of the Civil Rights Act
42 U.S.C. § 1983 (Against Officers 1-34 and Other Unknown Officers) 71. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 72. The Civil Rights Act of 1871 imposes liability on every person who, under color of any statute, ordinance, regulation, custom, or usage, subjects, or causes to be subjected, any person within the jurisdiction of the United States to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws. 73. Defendants, under color of Minnesota Statute, section 299A.641, subdivision 3(2), which created a state level Gang and Drug Oversight
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Council with a mandate to establish multi-jurisdictional task forces and strike forces across the state, subjected, and caused to be subjected, Plaintiffs and putative class members to the deprivation of their rights, privileges, or immunities secured by the Constitution and laws. Defendants deprived Plaintiffs and class members of their property and liberty rights without due process of law, in violation of the Fourth, Fifth, and Fourteenth Amendments to the United States Constitution.
74. As a proximate result of Defendants’ systematic violation of this statute, Plaintiffs and the class are entitled to the requested relief provided under the Act.
COUNT IV Violation of the Civil Rights Act
42 U.S.C. § 1985 (Against Defendant Ryan) 75. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 76. Defendant Ryan conspired in Minnesota with the MGSF, for the purpose of depriving, either directly or indirectly, Plaintiffs and class members of the equal protection of the laws and of equal privileges and immunities under the laws. 77. Defendant Ryan was aware that MGSF Officers were committing theft of personal property and did nothing to prevent it. When confronted by
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improper “forfeitures” by MGSF Officers, by the Office of the Legislative Auditor, Ryan testified that it was known “copper mentality” to take unlawfully the property of suspects, or “mopes,” who appeared to have nicer things in their home or on their person than the police officers had. He asserted that “coppers like to take as much as they can, that’s just the nature of the beast.” Defendant Ryan also identified the fact that “illegal aliens” do not “ask for anything back anymore” as a reason why the MGSF was amassing so much cash and property.
78. As MGSF Commander, Defendant Ryan had the duty to supervise members of the MGSF and prevent and correct the criminal acts committed by them. He was in charge of the day-to-day operation of the MGSF, including staffing and record keeping. But Defendant Ryan did not provide any written policies on proper forfeiture procedures. Defendant Ryan acted in furtherance of the conspiracy by affirmatively removing his oversight duties when he knew of a pattern and practice of unlawful forfeitures, reflected in his knowledge of “copper mentality.” Thus, Defendant Ryan knew that his actions which condoned this unlawful conduct were substantially certain to cause further conversion, theft, and unlawful deprivation of property. Minn. CIVJIG 60.10.
28

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79. As a proximate result of Defendants’ systematic violation of this statute, Plaintiffs and the class are entitled to the requested relief provided under the Act.
COUNT VI Violation of the Minnesota State Constitution
(Against All Defendants5) 80. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 81. Due to the action of each and every Defendant, by illegally taking Plaintiffs’ and class members’ property without any legal cause, the employees of all participating police forces and their respective municipalities violated the following provisions of the Minnesota State Constitution: Every person is entitled to certain remedy in the laws for all injuries or wrongs which he may receive in his person, property or character. Article I, § 8. Private property shall not be taken; destroyed . . . for public use without just compensation therefore, first paid or secured. Article I, § 13. 82. The apprehension of Plaintiffs and class members, although innocent, as a criminal suspect, is a public use under the Minnesota Constitution.
5 Plaintiffs will add Governmental Units as a Defendant to this legal theory after notice has issued.
29

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83. The individual and collective actions of police officers violated the above provisions of the Minnesota Constitution because innocent Plaintiffs and putative class members suffered a wrong and injury to property and character pursuant to Article I § 8, and, further, the officers took innocent Plaintiffs’ and class members’ property and this constitutes a “taking.”
COUNT VII Negligence (Against Defendant Board, and Board Members6) 84. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 85. Governmental Units and Defendant Board and Board Members had a duty to Plaintiffs and class members to conduct investigations in a reasonable manner. 86. Plaintiffs have complied with all conditions precedent and notice requirements of Minnesota Statutes, sections 373.06 and 466.05 and all the necessary defendant agencies have been properly placed on notice. 87. Governmental Units and Defendant Board and Board Members through their agents or employees acting within the course and scope of their employment, breached their duty to Plaintiffs and class members and were negligent in one or more of the following ways, but not limited hereto:
6 Plaintiffs will add Governmental Units as a Defendant to this legal theory after notice has issued.
30

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a. By failing to establish procedures and failing to instruct law enforcement personnel that they must employ methods that provide fair and reliable procedures for proper forfeitures;
b. By failing adequately to train MGSF officers not to target suspects based on national origin;
c. By failing adequately to train MGSF officers not to seize property without providing a receipt for items taken;
d. By failing adequately to train MGSF officers not to seize property in the course of serving a warrant without providing a complete, written inventory of property seized;
e. By failing adequately to train MGSF officers to write reports regarding all arrests;
f. By failing adequately to train MGSF officers to follow through with prosecution of persons arrested;
88. The failure to train and to implement policies and procedures regarding these issues ensured that there was no connection between MGSF police investigations and public accountability through constitutionally sound prosecution. This “disconnect” vanquished any incentive officers had to ensure that their conduct comported with the law. In other words, the lack of adequate training, adhering to proper procedures, and a lack of comporting with the MGSF’s own disciplinary policies so separated officers’ conduct from
31

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expected results that such negligent oversight led directly to the unfettered, rampant abuse of power by MGSF Officers.
89. As a direct and proximate result of the careless and negligent conduct of Governmental Units and Defendant Board and Board Members, Plaintiffs and putative class members, suffered humiliation and monetary damages.
COUNT VIII Civil Tort of Conversion (Against Officers 1-34 and Other Unknown Officers) 90. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 91. MGSF Officers exercised control over Plaintiffs’ and putative class members’ personal property, in the form of cash or other chattel, in a way that intentionally deprived the owner of possession of the property permanently, or for an indefinite period of time, resulting in an unjust taking. 92. Defendants, MGSF Officers, did not provide any receipt, inventory, or any paperwork whatsoever to Plaintiffs and class members in violation of Minnesota Statute 609. 93. As a result, Plaintiffs and class members are entitled to monetary damages.
32

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COUNT IX Civil Tort of Assault (Against Officers 1-34 and Other Unknown Officers) 94. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 95. MGSF Officers assaulted Plaintiffs and class members by intentionally causing apprehension of immediate offensive contact with them. MGSF Officers had the apparent ability to cause the offensive conduct, and Plaintiffs and class members had a reasonable apprehension that the immediate offensive contact would occur. In some cases, putative class members were unlawfully stopped, frisked, searched, and deprived of property in public. In other cases, class members were told that MGSF Officers had a warrant to arrest someone in their home or to search their home, after which the MGSF unlawfully deprived them of their property. In both cases, Defendants failed to act under color of law and caused a reasonable apprehension of immediate, offensive contact absent full compliance with police orders. 96. As a result, Plaintiffs and class members are entitled to monetary damages.
33

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COUNT X Civil Tort of False Imprisonment (Against Officers 1-34 and Other Unknown Officers) 97. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 98. Members of the MGSF intentionally restricted the physical liberty of Plaintiffs and class members by words or acts, and Plaintiffs and class members were aware of the words or acts. The threat of the immediate use of physical force was present in that MGSF members identified themselves as police officers. As such, Plaintiffs and class members believed that MGSF members had the ability to carry out the threat. 99. As a result, Plaintiffs and class members are entitled to monetary damages. [ADDITIONAL COUNT HELD IN ABEYANCE PENDING PERFECTION OF FORMAL NOTICE BY PLAINTIFFS AND THE CLASS]
Respondeat Superior (Against Governmental Units) 100. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 101. Because the conduct of Officers 1-34 and Other Unknown Officers in committing the acts described herein was done within the scope of their authority as officers of Governmental Units’ law enforcement agencies, Governmental Units are vicariously liable for their conduct.]
34

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Punitive Damages 102. All Defendants’ conduct, including [Governmental Units,] Board, and Board Members, was motivated by a nefarious motive or intent, or involved a willful, reckless or callous indifference to the federally protected rights and safety of Plaintiffs and others similarly situated. Punitive damages are therefore appropriate for a violation of 42 U.S.C. §§ 1981, 1983. 103. Under Minnesota Statutes, section 549.191, Plaintiffs must obtain leave of court to amend their complaint to seek punitive damages. Plaintiffs therefore reserve their right to allege punitive damages under Minnesota Statutes, section 549.20, if applicable.
PRAYER FOR RELIEF WHEREFORE, the named Plaintiffs and the other members of the class pray for relief as against Defendants as follows: 1. Certification of the above-described class with the named
Plaintiffs as class representatives; 2. For judgment for damages sufficient to compensate Plaintiffs and
other members of the class for their damages, including but not limited to monetary damages, restitution, and replacement damages; 3. For interest, as permitted by law;
35

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4. For an accounting of property, including but not limited to cash, seized by the MGSF;
5. For the appointment of a receiver to be custodian of all MGSF and Board records, including but not limited to receipts for property taken, notices of forfeiture, arrest records, warrant inventory sheets, warrants related to seized items, etc., some of which MGSF personnel had already attempted to destroy and thus spoliate;
6. For their reasonable costs, including attorneys’ fees as permitted by law; and
7. For all other just and proper relief.
DEMAND FOR JURY TRIAL
Plaintiffs hereby demand a trial by jury for all issues so triable.
DATED this 30th day of July, 2009.
ZIMMERMAN REED, P.L.L.P.
By s/Robert R. Hopper Charles S. Zimmerman (MN # 120054) Robert R. Hopper (MN # 208760) David M. Cialkowski (MN #306526) 651 Nicollet Mall, Suite 501 Minneapolis, MN 55402 Phone: (612) 341-0400 Fax: (612) 341-0844
FISHMAN, BINSFELD & BACHMEIER, P.A.
Phillip F. Fishman (MN #29622) 8011 34th Avenue South, Suite #245 Bloomington, MN 55425 Phone: (612) 339-0033 Fax: (612) 339-3240 phil@fbblaw.com
36

CASE 0:09-cv-01996-JNE-AJB Document 1 Filed 07/30/09 Page 37 of 37 THE ALVAREZ LAW FIRM Alex Alvarez (FL# 946346) 355 Palermo Avenue Coral Gables, FL 33134 Phone: (305) 444-7675 Fax: (305) 444-0075 alex@integrityforjustice.com ATTORNEYS FOR PLAINTIFFS
37

 
 CASE 0:09-cv-01996-JNE-AJB Document 78 Filed 12/16/10 Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

ZELAIDO RIVERA GARCIA, et al. Plaintiffs,
v. METRO GANG STRIKE FORCE, et al.

Case No. 09-cv-01996-JNE-AJB Judge Joan N. Ericksen Magistrate Judge Arthur J. Boylan

Defendants.

ORDER FOR CLASS COUNSEL’S ATTORNEYS’ FEES AND REIMBURSEMENT OF LITIGATION EXPENSES
This action was heard on December 16, 2010, before the undersigned, upon Plaintiffs’ Motion for Final Approval of Settlement, Certification of Settlement Class, and Payment of Attorneys’ Fees and Reimbursement of Litigation Expenses (Docket #63), and pursuant to the Order Preliminarily Approving Settlement and Approving Notice to Class Members (the “Preliminary Approval Order”) entered on September 14, 2010, for the purpose of determining class certification, final settlement approval and whether Class Counsels’ application for fees and expenses is appropriate.
The Settlement, as approved by this Court, includes an attorney fee structure in which Plaintiffs’ Class Counsels’ fees and reimbursed expenses are provided for over and above the $3,000,000.00 class member settlement amount. This separate and independent agreement was negotiated by the parties after the settlement terms for the class had been reached and were done through separate, arms length negotiations. The

CASE 0:09-cv-01996-JNE-AJB Document 78 Filed 12/16/10 Page 2 of 4
Settlement Agreement provides for a fee structure in which Plaintiffs’ Counsel will request, without objection from Defendants’, Seven Hundred Seventy Five Thousand Dollars ($775,000.00) in attorneys’ fees and litigation expenses up to a maximum of Eight Hundred Twenty Five Thousand Dollars ($825,000.00) which is contingent upon the number of participating class members submitting claims.
By previous Order, this Court having conducted the analysis required by the statute, found and concluded, for purposes of settlement only, that the requirements of Rules 23(a) and 23(b)(3) of the Federal Rules of Civil Procedure have been satisfied; that a settlement class should be certified; that the Settlement is fair, adequate, and reasonable; that notice was proved in accordance with Rule 23(c)(2); that “incentive” or “special’ awards to named plaintiffs serving as class representatives should be approved; and that final judgment should be entered. At this time, no objections have been entered, as such the Court finds and concludes that Class Counsels’ fees and expenses are reasonable and appropriate and should be awarded;
Having considered the record in this action, IT IS HEREBY ORDERED, ADJUDGED AND DECREED as follows:
1. Based on the submissions provided to the Court, and the oral arguments heard on December 16, 2010, the Court finds that notice of Class Counsel’s attorney’s fees and reimbursement of litigation expenses has been given to the class pursuant to the Preliminary Approval Order, and that the mailing and publication of the Notice of Proposed Class Action Settlement and Release of Claims (the “Notice”) in accordance with the methodology adopted pursuant to this Settlement (a) was the

CASE 0:09-cv-01996-JNE-AJB Document 78 Filed 12/16/10 Page 3 of 4
best notice that was practicable to members of the Settlement Class; (b) was reasonably calculated, under the circumstances, to apprise members of the application of Plaintiffs’ counsel for payment of their attorneys’ fees and reimbursement of their litigation expenses, (c) was reasonable and satisfied the requirements of due process by providing due, adequate, and sufficient notice to all persons and entities entitled to receive notice; (d) clearly and concisely stated in plain, easily understood language: (i) the application of Plaintiffs’ counsel for payment of their attorneys’ fees and reimbursement of their litigation expenses and (e) met all applicable requirements of law including, but not limited to, Rule 23(c) and the Due Process Clause of the Fifth Amendment to the United States Constitution. 2. Based on the submissions provided to the Court, and the oral arguments heard on December 16, 2010, the Court finds Class Counsel’s request for attorneys fees and litigation expenses in the amount of Seven Hundred Seventy-Five Thousand Dollars ($775,000), but no more than Eight Hundred Twenty Five Thousand Dollars ($825,000), contingent upon the number of participating class members submitting claims, and to which the Defendants’ do not object, to be fair and reasonable and is hereby approved. 3. Defendants shall have no responsibility for and shall have no liability whatsoever with respect to the allocation among Class Counsel and/or any other person who may assert a claim thereto, of any attorneys’ fees or expenses that the Court may award.

CASE 0:09-cv-01996-JNE-AJB Document 78 Filed 12/16/10 Page 4 of 4

4. The Court retains jurisdiction over this Settlement to the extent necessary to implement, effectuate and administer this Settlement and this Settlement Order and Final Judgment, including, but not limited to, any issues arising from the Court’s award of attorneys’ fees.

This 16th day of December, 2010.

s/ Joan N. Ericksen Judge Joan N. Ericksen United States District Judge

 
 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Zelaido Rivera Garcia et al.,

Plaintiffs,

v. Metro Gang Strike Force et al.,

Civil No. 09-1996 (JNE/AJB) ORDER

Defendants.

On December 16, 2010, the Court approved the Settlement Agreement. Under the

agreement, Defendants—public entities and officials—deposit $3 million into a settlement fund

that is to be used to pay for approved claims of class members and other purposes. The portion

of the settlement fund that is not spent on specific categories set forth in the settlement

agreement shall be spent on law enforcement and training. In short, a quantum of public funds

has been set aside to resolve the claims of class members, and provision has been made for using

any remainder for a public purpose.

The claims resolution process contemplates the submission of information by class

members and Defendants to a special master who determines each claim’s validity, the amount

of compensatory damages to be paid, and the property to be returned. The settlement agreement

provides that “all awards, payments and disbursements to be made from [the Settlement Fund

Escrow Account] must first be approved by the District Court Judge.”

After receiving an inquiry from a member of the media, the Court solicited the parties’

views as to how much information concerning the claimants should be made public. Having

considered the parties’ responses, the Court declines to seal all information that is filed in the

connection with the claims. See Nixon v. Warner Comm’cns, Inc., 435 U.S. 589, 597 (1978)

(“[T]he courts of this country recognize a general right to inspect and copy public records and

1

documents, including judicial records and documents.” (footnote omitted)); Webster Groves Sch. Dist. v. Pulitzer Publ’g Co., 898 F.2d 1371, 1376 (8th Cir. 1990). Redactions should be made as required by the federal and local rules. In addition, hotline claimants operated under an express promise of confidentiality; they may be not be revealed as hotline claimants. Information should also be protected as required by statute (e.g., the Minnesota Government Data Practices Act).
IT IS SO ORDERED. Dated: March 30, 2011
s/ Joan N. Ericksen JOAN N. ERICKSEN United States District Judge
2

 
 CASE 0:09-cv-01996-JNE-AJB Document 2 Filed 09/23/09 Page 1 of 36

UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA

ZELAIDO RIVERA GARCIA, MAURA GONZALEZ SALINAS, ADRIAN RAMIREZ-CUEVAS, CAMERINA CUEVAS LOPEZ, KATHLEEN YANKOVIC, JOHN YANKOVIC,

Case No. 09-cv-01996-JNE-SRN

Plaintiffs,

v.

METRO GANG STRIKE FORCE,

AMENDED COMPLAINT FOR

RON RYAN, former Metro Gang

DAMAGES AND INJUNCTIVE

Strike Force Commander, DOE

RELIEF

OFFICERS 1-34, individually and in

their official capacities, OTHER

UNKNOWN DOE OFFICERS, CITY JURY TRIAL DEMANDED

OF WEST ST. PAUL, a municipal

corporation, HENNEPIN COUNTY, a

direct political subdivision of the

CLASS ACTION

State, DAKOTA COUNTY, a direct

political subdivision of the State,

RAMSEY COUNTY, a direct political

subdivision of the State, CITY OF ST.

PAUL, a municipal corporation, CITY

OF MINNEAPOLIS, a municipal

corporation, WASHINGTON

COUNTY, a direct political

subdivision of the State, CITY OF

MAPLEWOOD, a municipal

corporation, CITY OF LINO LAKES,

a municipal corporation, CITY OF

BROOKLYN PARK, a municipal

corporation, CITY OF RICHFIELD, a

municipal corporation,

METROPOLITAN COUNCIL,

METRO GANG STRIKE FORCE

CASE 0:09-cv-01996-JNE-AJB Document 2 Filed 09/23/09 Page 2 of 36
ADVISORY BOARD, MANILA ("BUD") SHAVER, Chief of the West ST. Paul Police Department, KEN SCHILLING, Inspector at the Hennepin County Sheriffs Office, DAVE BELLOWS, Chief Deputy of the Dakota County Sheriffs Office, BOB FLECTCHER, Sheriff of the Ramsey County Sheriffs Office, JOHN HARRINGTON, Chief of the St. Paul Police Department, ROB ALLEN, Deputy Chief of the Minneapolis Police Department, BILL HUTTON, Sheriff of the Washington County Sheriffs Office, DAVE THOMALLA, Chiefofthe Maplewood Police Department, DAVE PECCHLA, Chief of the Lino Lakes Police Department, DAVE INDREHUS, Chief of the Metro Transit Police Department, MICHAEL DAVIS, Chief of the Brooklyn Park Police Department, BARRY FRITZ, Captain of the Richfield Police Department,
Defendants.
1. This is a class action brought by Plaintiffs, on behalf of
themselves and others similarly-situated, to recover damages and to impose
injunctive relief under the Civil Rights Act, 42 U.S.C. § 1981, § 1983 et seq.
("CRA''), to recover monetary damages for negligence in the supervision and
training of law enforcement employees and for liability based on respondeat
superior, to recover monetary damages for civil tort conversion and
2

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conspiracy to convert, for civil tort of assault, for civil tort of false imprisonment, and for violations of the Minnesota State Constitution. Plaintiffs seek remedies for themselves and the Class and Subclass for Defendants' negligence and unlawful deprivation of Plaintiffs' and class members' property and liberty.
PARTIES Plaintiffs Zelaido Rivera Garcia 2. Plaintiff Zelaido Rivera Garcia is now, and at all relevant times was, a resident of the City of Minneapolis, residing at 3816- 24th Avenue, No. 1, Minneapolis, Minnesota. 3. All acts hereinafter alleged occurred on or about July 31, 2008. All officers were acting in their individual and official capacity, and contrary to law. 4. On or about July 31, 2008, the Plaintiff and his spouse drove to the City of Minneapolis impound lot with the lawful intent to pay the designated fee to release a motor vehicle. 5. After Plaintiffs arrival at the impound lot, Defendant Officers appeared and detained the Plaintiff and numerous other undocumented individuals who are putative class members of the herein alleged class.
3

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6. Prior to informing the United States Immigration and Customs Enforcement ("ICE"), each of the persons, including Plaintiff Garcia, was frisked and searched.
7. No drugs or contraband were discovered; however, the personal property on Plaintiff Garcia's person was taken and he was placed on a nearby automobile hood, with the exception of $100 cash, which was taken by the Metro Gang Strike Force Officers.
8. At said time and place as alleged above, unknown Metro Gang Strike Force Officers illegally confiscated $100 from Plaintiff Garcia's wallet. Plaintiff was not aware of the taking until his wallet was returned without the $100. Plaintiff Garcia protested that his money was taken, but did not get it back, nor was he given any administrative notice of forfeiture of rights, pursuant to law.
9. Somewhat later in time, the Minnesota Gang Strike Force Officers, telephone representative of ICE, took Plaintiff Garcia and other undocumented persons at the impound lot to jail.
Maura Gonzalez Salinas 10. Plaintiff Maura Gonzalez Salinas is now, and at all relevant times was, a resident of the City of Minneapolis, residing at 2932 -15th Avenue South, No. 1, Minneapolis, Minnesota.
4

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11. All acts hereinafter alleged occurred on or about June 2, 2009. At such time and place all officers were acting in their individual and official capacity, and contrary to law.
12. On or about June 2, 2009, numerous Metro Gang Strike Force Officers and Minneapolis Police Department Officers came to Plaintiff Salinas' apartment seeking to arrest her son, Paul Salinas for an alleged probation violation.
13. Subsequent to their arrival at Plaintiff Salinas' apartment, the Metro Gang Strike Force rounded up the family, insulted their national origin by stating multiple times that "Spanish is bullshit," and also ridiculed the foods eaten by Hispanic persons. During the search of Plaintiff Salinas' apartment, no drugs or contraband were discovered; however, Plaintiff Salinas' personal property was taken by the Metro Gang Strike Force and converted to their use.
14. Unknown Metro Gang Strike Force Officers illegally confiscated $900 in cash from Plaintiff Salinas' personal clothing drawer, as well as a 24k gold necklace worth approximately $600. Plaintiff Salinas was unaware that the cash and jewelry were taken until the police officers left the premises.
15. At no time during the search of Plaintiff Salinas's apartment, or subsequent thereto, did the Metro Gang Strike Force Officers issue any inventory receipt for certain material taken. The officers did list a receipt for
5

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inventory taken, but the Metro Gang Strike Force failed to record and note that they had taken $900 cash and the 24k gold necklace.
16. On June 2, 2009, Plaintiff Salinas was the owner and possessor of the $900 cash and the 24k gold necklace. The cash was intended to pay her next month's rent. As a result of the taking of the cash, Plaintiff Salinas was unable to pay her rent and had to vacate the premises.
Adrian Ramirez-Cuevas and Camerina Cuevas Lopez 17. Plaintiffs Adrian Ramirez-Cuevas and Camerina Cuevas Lopez are now, and and at all relevant times were, residents of the City of Crystal, residing at 4323 Xenia Avenue North, Crystal, Minnesota. 18. All acts hereinafter alleged occurred on or about July 28, 2008, at the former apartment of Plaintiffs, namely, the Kentucky Lane Apartments in Crystal, Minnesota. At such time and place all officers were acting in their individual and official capacity, and contrary to law. 19. On or about July 31, 2008, Plaintiff Adrian Cuevas and his father, Norverto Cuevas, were at the apartment complex. 20. Plaintiff Adrian Cuevas was outside the apartment and had recognized the Metro Gang Strike Force Officers from a previous encounter. At that time, one or more of the Metro Gang Strike Force Officers knocked Plaintiff Adrian Cuevas down, handcuffed him, and took his keys away from
6

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him. Plaintiff Adrian Cuevas did not give the officers consent to enter Plaintiff Adrian Cuevas' apartment.
21. The officers entered the apartment of Plaintiff Adrian Cuevas, without a warrant and without the consent of Plaintiff Adrian Cuevas, and apprehended Norverto Cuevas, throwing him to the ground, breaking one of his teeth. One of the Metro Gang Strike Force officers placed his foot on Norverto Cuevas' head to restrain him. Noverto Cuevas asked if any of the officers had a search warrant.
22. Once inside the premises, the officers literally tore up the apartment and conducted a search for drugs within the apartment. Plaintiff Cuevas' apartment contained no drugs or contraband.
23. At said time and place as alleged above, unknown members of the Metro Gang Strike Force Officers illegally confiscated approximately $2,800 from Plaintiff Adrian Cuevas' apartment. Plaintiff Adrian Cuevas was not aware of the taking of the money until after the officers left the premises. Approximately $2,000 was the property of Plaintiff Camerina Cuevas Lopez and said money was part of a savings club, "Comida," which is a traditional way the family saves money. The remaining money was partially owned by Plaintiff Adrian Cuevas and his father Norverto Cuevas, who has subsequently been removed to Mexico.
7

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24. At said time and place as alleged above, the unknown Metro Gang Strike Force Officers illegally confiscated money from Plaintiffs Adrian Ramirez-Cuevas and Camerina Cuevas Lopez, who were the owners and possessors of the above-described property.
Kathleen and John Yankovic 25. Plaintiffs Kathleen and John Yankovic are now, and at all relevant times were residents of the City of St. Paul, residing at 1799 N. Edgerton Street, St. Paul. 26. At such time and place all officers were acting in their individual and official capacity, and contrary to law. 27. On June 12, 2008, Plaintiff Kathleen Yankovic and her husband were the owners and possessors of property and jewelry valued in excess of $7,500, having purchased the property on previous dates. Defendant Metro Gang Strike Force Officers unlawfully took and carried away Plaintiffs Yankovics' property and converted and disposed of it to their own use to the Plaintiffs' damage, in excess of $7,500. 28. When Plaintiff Kathleen Yankovic protested, stating that the property should not be taken by the police, the Officers laughed and made light of Plaintiff Kathleen Yankovic's protests and converted the property to their own use.
8

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29. Plaintiff Kathleen Yankovic was given an inventory receipt, but many of the items that were taken from Plaintiffs home on the date and time in question were not formally noted, nor was Plaintiff given administrative notice as to how she might reacquire the property.
Defendants 30. In 2005, the Minnesota Legislature enacted Minnesota Statute, section 299A.641, which created the Gang and Drug Oversight Council and mandated that the Council establish the Metro Gang Strike Force ("MGSF"). This fiat dissolved the existing Minnesota Gang Strike Force. Governmental Units 31. The following Governmental Units are parties to the ensuing Joint Powers Agreement Creating the Metro Gang Strike Force ("Agreement"), used to implement the legislative mandate: City of West St. Paul, a municipal corporation; Hennepin County, a direct political subdivision of the State; Dakota County, a direct political subdivision of the State; Ramsey County, a direct political subdivision of the State; City of St. Paul, a municipal corporation; City of Minneapolis, a municipal corporation; Washington County, a direct political subdivision of the State; City of Maplewood, a municipal corporation;
9

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City of Lino Lakes, a municipal corporation; City of Brooklyn Park, a municipal corporation; City of Richfield, a municipal corporation; Metropolitan Council. Each of these Governmental Units assigns from its law enforcement agency or agencies its Chief Law Enforcement Officer, or his or her designee, to be a member of the Metro Gang Strike Force Advisory Board. The Governmental Units also provided police officers to act as MGSF personnel and to carry out the organization's purpose. However, those police officers never became employees of the MGSF. While the Board and the Metro Commander had a contractual duty to oversee and supervise the activities of MGSF personnel, the Governmental Units remained at all times the employer responsible for the acts of their employee police officers acting in this scope of their employment. Governmental Units were negligent in their duty to train and supervise their employee police officers, resulting in damages to Plaintiffs and class members. Defendant Board and Board Members 32. Defendant Metro Gang Strike Force Advisory Board ("the Board") comprises the chief law enforcement officers (or their designees) from the agencies that participate in the MGSF. The Board was responsible for
10

CASE 0:09-cv-01996-JNE-AJB Document 2 Filed 09/23/09 Page 11 of 36
supervising the Metro Commander. These Defendant Board members include:
Chair Manila ("Bud") Shaver, Chief of the West St. Paul Police Department, Vice-Chair Ken Schilling, Inspector at the Hennepin County Sheriffs Office, Dave Bellows, Chief Deputy of the Dakota County Sheriffs Office, Bob Fletcher, Sheriff of the Ramsey County Sheriffs Office, John Harrington, Chief of the St. Paul Police Department, Rob Allen, Deputy Chief of the Minneapolis Police Department, Bill Hutton, Sheriff of the Washington County Sheriffs Office, Dave Thomalla, Chief of the Maplewood Police Department, Dave Pecchla, Chief of the Lino Lakes Police Department, Dave Indrehus, Chief of the Metro Transit Police Department, Michael Davis, Chief of the Brooklyn Park Police Department, and Barry Fritz, Captain of the Richfield Police Department. The Joint Powers Agreement required the Board to select and supervise the Metro Commander, approve the selection of participating officers, set the priorities for the work of the MGSF, and approve all expenditures of the MGSF. The Board and its members were negligent in their duty to train and supervise their employee police officers, resulting in damages to Plaintiffs
11

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and class members. Plaintiffs sue all defendants in both their individual and official capacities.
Joint Venture 33. Defendant MGSF is an entity created pursuant to Minnesota Statutes§ 471.59, and§ 299A.641, subd. 3, to coordinate the efforts of Defendant Governmental Units to prevent and investigate gang crimes. Metro Commander 34. The Joint Powers Agreement required a Metro Commander to provide effective leadership and administrative coordination, direct officer assignments, oversee field operations, foster communication and cooperation with other law enforcement agencies in and outside the geographic region, and identify and facilitate necessary training for MGSF officers. 35. Defendant Ron Ryan was the Metro Commander of the MGSF. His tenure as Commander ended on October 10, 2008, when he retired. He had been Commander of the MGSF, and its predecessor entity, the Minnesota Gang Strike Force, for over 11 years. Plaintiffs sue Defendant Ryan in both his individual and official capacities. MGSF Personnel 36. Governmental Units, Defendants to be added later, were required to recommend and provide licensed peace officers from their own law enforcement agencies to serve as MGSF personnel. However, MGSF Officers
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at all times remained employees of their respective Governmental Units and were expressly not considered employees of the MGSF. Disciplinary matters were to be referred not to the Board, but to the Governmental Units' law enforcement agencies for investigation and disposition. Defendant Doe Officers 1-34 were at all times operating as loaned officers to the MGSF, acting within the course and scope of employment as a peace officer and were part of the MGSF at the time it became defunct on July 17, 2009. Other unknown officer Defendants were officers on assignment to the MGSF, acting within the course and scope of employment, during times relevant to this action, but ceased to be MGSF personnel sometime prior to July 17, 2009. Plaintiffs sue all defendants in both their individual and official capacities.
JURISDICTION AND VENUE 37. The Court has jurisdiction over Plaintiffs' federal claims under 28 U.S.C. §§ 1331 and 1337. The Court has jurisdiction over Plaintiffs' common law claims under 28 U.S.C. § 1367 because those claims are so related to the federal claims that they form part of the same case or controversy. 38. The MGSF had offices, conducted its affairs, housed paperwork, and carried out its investigations in this District. Some Plaintiffs and class members were injured by Defendants in this District. A substantial part of the events and omissions giving rise to this action thus occurred in this
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District. Venue is therefore proper in this District pursuant to 28 U.S.C. § 1391(b).
39. Plaintiffs and proposed class representatives are asserting claims relating to the negligence of the Governmental Units, the Board, and the MGSF, due to the unlawful deprivation by MGSF Officers of Plaintiffs' personal property. As a direct, proximate and foreseeable cause of Defendants' negligent and unlawful conduct, the Plaintiffs and proposed class members each sustained damages.
FACTS
40. Governmental Units and Defendant Board and Board members breached their duty to train, supervise, and discipline the improper acts of their MGSF Officers who failed to provide receipts, inventory lists, and notices of the right to object to forfeitures, to Plaintiffs and putative class members.
41. Members of the MGSF engaged in a pattern and practice of using their apparent authority as police officers to extort cash and property from people coming into contact with the MGSF, particularly from those concerned about their immigration status who would naturally perceive that they had no ability to assert legal rights. While undocumented status can subject an alien to removal proceedings, it is not a crime. Yet, the members of this governmental "joint venture," whose purpose and scope is expressly limited to
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preventing and investigating gang "crimes," intentionally targeted victims for purposes of extortion. In most instances, this illegal conduct by the MGSF and its officers against these Plaintiffs and putative class members was based on their immigration status or other vulnerability, ostensibly as though they were under investigation for or accused of a crime.
42. A targeted, deliberate place to conduct their thefts was the Minneapolis Impound Lot, where persons, including vulnerable aliens, would attempt to pick up their vehicles. MGSF Officers would often call the impound lot and ask if there were any "Mexicans" there attempting to pick up vehicles. MGSF Officers would show up at the impound lot, detain and search the individual, seize cash, the vehicle for forfeiture, or both; then, send the individual on his or her way without a receipt for the taken property. On many occasions, ICE officers were called to expedite the removal of aliens, which further precluded them from seeking legal redress to reacquire their rightful property.
43. MGSF Officers also engaged in the repeated practice of taking cash and personal property out of the homes of those on whom the police were serving a warrant, even though the cash or personal property was neither contraband nor evidence, nor listed in the warrant as items to be seized. MGSF Officers would then take the seized items without providing a receipt or inventory for the taken property.
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44. MGSF Officers also seized vehicles and property without providing Plaintiffs and putative class members with due process and with proper notice, in the native language of Plaintiffs and class members, pursuant to Minnesota Statutes, section 609.5314. According to the statute, said notice is required to be given to anyone from whom the police seize property for forfeiture, of the opportunity to be heard and the right to object to the forfeiture.
CLASS ALLEGATIONS 45. Plaintiffs sue on their own behalf and on behalf of a class of persons under Rules 23(a) and 23(b)(2) and (b)(3) of the Federal Rules of Civil Procedure. This action satisfies the numerosity, commonality, typicality, adequacy, predominance and superiority requirements of those provisions. 46. The Class is defined as: All persons who have been stopped, questioned, arrested, frisked, detained, searched, or any combination, by an Officer or Officers serving on the MGSF, and whose property was taken without a receipt or inventory itemization and without notification of their right to contest the forfeiture. 47. The Subclass is defined as: All persons who have been stopped, questioned, arrested, frisked, detained, searched, or any combination, based on their national origin, by an Officer or Officers serving on the MGSF, and whose property was taken without a receipt or inventory itemization and without notification of their right to contest the forfeiture.
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Excluded from the class are those whose encounters with MGSF Officers resulted in their indictment or other duly filed criminal complaint by a criminal prosecuting authority.
48. Numerosity: Plaintiffs do not know the exact size of the proposed Class or Subclass, or the identities of all their members because such information is in the exclusive control of Defendants. Plaintiffs, however, believe that the Class and Subclass encompass at least 200 individuals. Therefore, the Class is so numerous that joinder of all members is impracticable.
49. Commonality I Predominance: All members of the Class have been subject to and affected by the same conduct. There are questions of law and fact that are common to the Class, and predominate over any questions affecting only individual members of the Class. These questions include, but are not limited to:
a. whether Governmental Units owed a duty of care to properly train and supervise its employee police officers, who came into contact with Plaintiffs and class members;
b. whether Governmental Units had sufficient policies and procedures in place to ensure that their officers were trained and supervised properly;
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c. whether the lack of Governmental Units' training, supervision, policies, and procedures caused police officers loaned to the MGSF to develop a pattern and practice of engaging in improper forfeiture practices pursuant to Minn. Stat. § 609.5314 without detection for many years;
d. whether Governmental Units are the true employers ofMGSF Officer;
e. whether Governmental Units are also vicariously responsible for the acts ofMGSF Officers based on respondeat superior principles;
f. whether Defendant Board and Board Members owed a duty of care to properly train and supervise its employee police officers, who came into contact with Plaintiffs and class members;
g. whether Defendant Board and Board Members had sufficient policies and procedures in place to ensure that their officers were trained and supervised properly;
h. whether the lack of Defendant Board's and Board Members' training, supervision, policies, and procedures caused police officers loaned to the MGSF to develop a pattern and practice of engaging in improper forfeiture practices without detection for many years;
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1. whether Defendants were required to provide receipts of seized property;
J. whether Defendants were required to provide notices of the right to contest the forfeiture of property;
k. whether Defendants repeatedly failed to provide receipts of seized property;
l. whether Defendants repeatedly failed to provide notice of the right to contest the forfeitures as required by Minnesota law (Minn. Stat. § 609.5314);
m. whether Defendants acted under color of law when improperly seizing property;
n. whether Defendants failed to create records of seized property and incidents leading to the seizure of property;
o. whether Defendants failed to properly maintain records of seized property and incidents leading to the seizure of property;
p. whether Metro Commander Defendant Ryan was aware of the pattern of improper seizures and forfeitures;
q. whether Metro Commander Defendant Ryan agreed and conspired with MGSF officers to commit illegal acts;
r. whether Metro Commander Defendant Ryan committed an overt act in furtherance of the conspiracy;
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s. whether the MGSF retained seized property; t. whether the MGSF had a pattern and practice of targeting and
exploiting individuals of foreign national origin; u. whether the MGSF had a pattern and practice of targeting and
exploiting individuals who were suspected of committing crimes, but were never prosecuted after their property was illegally taken; v. whether the Board or Board members should have been aware of the pattern of improper seizures and forfeitures; w. whether Governmental Units should have been aware of the pattern of improper seizures and forfeitures; x. whether Defendants affirmatively abandoned their duty to supervise MGSF personnel. 50. Typicality: The claims of the named Plaintiffs are typical of the claims of the Class and Subclass and do not conflict with the interests of any other members of the Class or Subclass in that both the Plaintiffs and the other members of the Class were subjected to search and seizure without the provision of a receipt or notice of ability to contest the forfeiture. Prosecution of Plaintiffs' claims will inure to the benefit of the entire proposed class. 51. Adequacy: The named Plaintiffs will fairly and adequately represent the interests of the Class. Plaintiffs are committed to the vigorous
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prosecution of the Classes' claims and have retained attorneys who are qualified to pursue this litigation and have experience in class actions. Neither Plaintiffs nor counsel have any interest adverse to those of Class members.
52. Superiority: A class action is superior to other methods for the fast and efficient adjudication of this controversy. A class action regarding the issues in this case does not create any problems of manageability.
53. In the alternative, Defendant has acted or refused to act on grounds generally applicable to the Classes, thereby making appropriate, final injunctive relief or corresponding declaratory relief with respect to the class as a whole.
LEGAL BASES FOR RELIEF COUNT I
Violation of the Civil Rights Act 42 U.S.C. § 1983 (Monell Claim) (Against Governmental Units, MGSF Advisory Board, and Defendant Ryan) 54. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 55. Defendant MGSF Advisory Board and Defendant Ryan, through their employees and members, failed to properly train, supervise, and discipline the MGSF members who violated Plaintiffs' constitutional rights. Therefore, the unconstitutional and illegal actions of the MGSF members
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were carried out pursuant to an unconstitutional policy, procedure, or practice of Defendant MGSF Advisory Board, in violation of Plaintiffs' and class members' Fourth, Fifth, and Fourteenth Amendment Rights.
56. Governmental Units were responsible for appointing, supervising, training, disciplining, and terminating all law enforcement officers and other employees of their respective law enforcement agencies. Governmental Units were the employers ofMGSF personnel and were responsible for providing supervision and training for their law enforcement officers.
57. Governmental Units and Defendant Board and Board Members had actual knowledge that unless MGSF law enforcement officers were well trained and supervised pertaining to the appropriate police procedures, members of the public were subject to having their property forfeited without due process.
58. Governmental Units and Defendant Board and Board Members knew, or in the exercise of reasonable care, should have known, that the problem of improper forfeitures was a prevalent problem existing in the Twin Cities Metro Area through the unlawful operation of the MGSF that they duly created and managed.
59. Governmental Units and Defendant Board and Board Members failed to take steps to train and supervise their respective law enforcement officers and staff and failed to establish adequate procedures to ensure that
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members of the public, such as the Plaintiffs and other putative class members, were not subjected to unlawful forfeiture procedures and activities.
60. Governmental Units and Defendant Board and Board Members failed to establish policies and procedures, substantially resulting in the rampant, improper use of forfeiture procedures.
61. At all times material, the Defendants' actions or failures to act became a custom or policy resulting in the deliberate indifference to constitutional rights of citizens including the Plaintiffs.
62. At all times material, the Defendants either instituted an Improper policy or an absence of a policy for the necessary and proper execution of their duties; and, such failures resulted in the deliberate indifference to the constitutional rights of citizens including the Plaintiff.
63. The Legislative Auditor found that the MGSF failed to have sound fiscal management. The failure to establish a system of creating receipts and complete inventory lists and of basic accounting for all forfeited property constituted a failure on the part of Governmental Units and Defendant Board and Board Members to establish appropriate procedures and to supervise and train their law enforcement personnel, which was so severely deficient as to reach the level of gross negligence and deliberate indifference to the deprivation of constitutional rights of members of the public, including Plaintiffs and putative class members. Hennepin County Sheriff Rich Stanek
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admitted that the recent revelation that West St. Paul Police Chief, and MGSF Chair, Bud Shaver asked the MGSF not to seize his own automobile, used in the commission of an alleged crime, was merely "one in a series of things that hurt the [MGSF]'s credibility, to the point where I didn't think it had much value on behalf of the citizens of Hennepin County or the law enforcement agencies on the Hennepin County side." "At the very least," Stanek said, "I think people agree there was lack of managerial oversight [ofMGSF officers]."
64. Governmental Units and Defendant Board and Board Members failed to supervise, train, and discipline their law enforcement officers and personnel, their failure to establish appropriate procedures to prevent improper forfeiture procedures resulted in a deprivation of rights, privileges and immunities guaranteed to the Plaintiff under the Constitution and laws of the United States.
65. As a proximate result of Defendant's systematic violation of this statute, Plaintiffs and the class are entitled to the requested relief provided under the Act.
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COUNT II Violation of the Civil Rights Act
42 u.s.c. § 1981
(Against All Defendants by Plaintiffs Garcia, Salinas, Ramirez-Cuevas, Lopez, and Subclass members)
66. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint.
67. The Civil Rights Act ascribes to every person within the jurisdiction of the United States the right to the full and equal benefit of all laws and proceedings for the security of persons and property as is enjoyed by white citizens.
68. The MGSF intentionally discriminated against Plaintiffs and the class by targeting them due to their national origin. As undocumented aliens, Plaintiffs and class members were particularly vulnerable because they 1) typically do not have bank accounts, and so often carried cash1 and 2) perceived themselves as having no rights and no ability to defend themselves from civil malfeasance. Members of the MGSF knew of these vulnerabilities and exploited them for personal gain.
69. Members of the MGSF took targeted persons based on their Latino national origin, converted their property without any process, and failed to account for the property in any way, whether through receipt or
1 See Remarks of Martin J. Gruenberg, Vice Chairman, FDIC at IADI's Sixth Annual International Conference; Kuala Lumpur, Malaysia; November 1, 2007.
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inventory recordation. Governmental Units, Defendant Board, Board Members, Metro Commander, the MGSF, and Officers are liable for these violations.
70. As a proximate result of Defendants' systematic violation of this statute, Plaintiffs and the class are entitled to the requested relief provided under the Act.
COUNT III Violation of the Civil Rights Act
42 u.s.c. § 1983
(Against Officers 1-34 and Other Unknown Officers) 71. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 72. The Civil Rights Act of 1871 imposes liability on every person who, under color of any statute, ordinance, regulation, custom, or usage, subjects, or causes to be subjected, any person within the jurisdiction of the United States to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws. 73. Defendants, under color of Minnesota Statute, section 299A.641, subdivision 3(2), which created a state level Gang and Drug Oversight Council with a mandate to establish multi-jurisdictional task forces and strike forces across the state, subjected, and caused to be subjected, Plaintiffs and putative class members to the deprivation of their rights, privileges, or
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immunities secured by the Constitution and laws. Defendants deprived Plaintiffs and class members of their property and liberty rights without due process of law, in violation of the Fourth, Fifth, and Fourteenth Amendments to the United States Constitution.
74. As a proximate result of Defendants' systematic violation of this statute, Plaintiffs and the class are entitled to the requested relief provided under the Act.
COUNT IV Violation of the Civil Rights Act
42 u.s.c. § 1985
(Against Defendant Ryan) 75. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 76. Defendant Ryan conspired in Minnesota with the MGSF, for the purpose of depriving, either directly or indirectly, Plaintiffs and class members of the equal protection of the laws and of equal privileges and immunities under the laws. 77. Defendant Ryan was aware that MGSF Officers were committing theft of personal property and did nothing to prevent it. When confronted by improper "forfeitures" by MGSF Officers, by the Office of the Legislative Auditor, Ryan testified that it was known "copper mentality" to take unlawfully the property of suspects, or "mopes," who appeared to have nicer
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things in their home or on their person than the police officers had. He asserted that "coppers like to take as much as they can, that's just the nature of the beast." Defendant Ryan also identified the fact that "illegal aliens" do not "ask for anything back anymore" as a reason why the MGSF was amassing so much cash and property.
78. As MGSF Commander, Defendant Ryan had the duty to supervise members of the MGSF and prevent and correct the criminal acts committed by them. He was in charge of the day-to-day operation of the MGSF, including staffing and record keeping. But Defendant Ryan did not provide any written policies on proper forfeiture procedures. Defendant Ryan acted in furtherance of the conspiracy by affirmatively removing his oversight duties when he knew of a pattern and practice of unlawful forfeitures, reflected in his knowledge of "copper mentality." Thus, Defendant Ryan knew that his actions which condoned this unlawful conduct were substantially certain to cause further conversion, theft, and unlawful deprivation of property. Minn. CIVJIG 60.10.
79. As a proximate result of Defendants' systematic violation of this statute, Plaintiffs and the class are entitled to the requested relief provided under the Act.
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COUNTV Violation of the Minnesota State Constitution
(Against All Defendants) 80. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 81. Due to the action of each and every Defendant, by illegally taking Plaintiffs' and class members' property without any legal cause, the employees of all participating police forces and their respective municipalities violated the following provisions of the Minnesota State Constitution: Every person is entitled to certain remedy in the laws for all injuries or wrongs which he may receive in his person, property or character. Article I, § 8. Private property shall not be taken; destroyed ... for public use without just compensation therefore, first paid or secured. Article I, § 13. 82. The apprehension of Plaintiffs and class members, although innocent, as a criminal suspect, is a public use under the Minnesota Constitution. 83. The individual and collective actions of police officers violated the above provisions of the Minnesota Constitution because innocent Plaintiffs and putative class members suffered a wrong and injury to property and character pursuant to Article I § 8, and, further, the officers took innocent Plaintiffs' and class members' property and this constitutes a "taking."
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COUNT VI Negligence (Against Governmental Units, Defendant Board, and Board Members) 84. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 85. Governmental Units and Defendant Board and Board Members had a duty to Plaintiffs and class members to conduct investigations in a reasonable manner. 86. Plaintiffs have complied with all conditions precedent and notice requirements of Minnesota Statutes, sections 373.06 and 466.05 and all the necessary defendant agencies have been properly placed on notice. 87. Governmental Units and Defendant Board and Board Members through their agents or employees acting within the course and scope of their employment, breached their duty to Plaintiffs and class members and were negligent in one or more of the following ways, but not limited hereto: a. By failing to establish procedures and failing to instruct law enforcement personnel that they must employ methods that provide fair and reliable procedures for proper forfeitures; b. By failing adequately to train MGSF officers not to target suspects based on national origin;
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c. By failing adequately to train MGSF officers not to seize property without providing a receipt for items taken;
d. By failing adequately to train MGSF officers not to seize property in the course of serving a warrant without providing a complete, written inventory of property seized;
e. By failing adequately to train MGSF officers to write reports regarding all arrests;
f. By failing adequately to train MGSF officers to follow through with prosecution of persons arrested;
88. The failure to train and to implement policies and procedures regarding these issues ensured that there was no connection between MGSF police investigations and public accountability through constitutionally sound prosecution. This "disconnect" vanquished any incentive officers had to ensure that their conduct comported with the law. In other words, the lack of adequate training, adhering to proper procedures, and a lack of comporting with the MGSF's own disciplinary policies so separated officers' conduct from expected results that such negligent oversight led directly to the unfettered, rampant abuse of power by MGSF Officers.
89. As a direct and proximate result of the careless and negligent conduct of Governmental Units and Defendant Board and Board Members,
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Plaintiffs and putative class members, suffered humiliation and monetary damages.
COUNT VII Civil Tort of Conversion (Against Officers 1-34 and Other Unknown Officers) 90. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 91. MGSF Officers exercised control over Plaintiffs' and putative class members' personal property, in the form of cash or other chattel, in a way that intentionally deprived the owner of possession of the property permanently, or for an indefinite period of time, resulting in an unjust taking. 92. Defendants, MGSF Officers, did not provide any receipt, inventory, or any paperwork whatsoever to Plaintiffs and class members in violation of Minnesota Statute 609. 93. As a result, Plaintiffs and class members are entitled to monetary damages.
COUNT VIII Civil Tort of Assault (Against Officers 1-34 and Other Unknown Officers) 94. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint.
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95. MGSF Officers assaulted Plaintiffs and class members by intentionally causing apprehension of immediate offensive contact with them. MGSF Officers had the apparent ability to cause the offensive conduct, and Plaintiffs and class members had a reasonable apprehension that the immediate offensive contact would occur. In some cases, putative class members were unlawfully stopped, frisked, searched, and deprived of property in public. In other cases, class members were told that MGSF Officers had a warrant to arrest someone in their home or to search their home, after which the MGSF unlawfully deprived them of their property. In both cases, Defendants failed to act under color of law and caused a reasonable apprehension of immediate, offensive contact absent full compliance with police orders.
96. As a result, Plaintiffs and class members are entitled to monetary damages.
COUNT IX Civil Tort of False Imprisonment (Against Officers 1-34 and Other Unknown Officers) 97. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 98. Members of the MGSF intentionally restricted the physical liberty of Plaintiffs and class members by words or acts, and Plaintiffs and class members were aware of the words or acts. The threat of the immediate
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use of physical force was present in that MGSF members identified themselves as police officers. As such, Plaintiffs and class members believed that MGSF members had the ability to carry out the threat.
99. As a result, Plaintiffs and class members are entitled to monetary damages.
COUNT X Respondeat Superior (Against Governmental Units) 100. Plaintiffs incorporate by reference the allegations contained in preceding paragraphs of this Complaint. 101. Because the conduct of Officers 1-34 and Other Unknown Officers in committing the acts described herein was done within the scope of their authority as officers of Governmental Units' law enforcement agencies, Governmental Units are vicariously liable for their conduct.
Punitive Damages 102. All Defendants' conduct, including Governmental Units, Board, and Board Members, was motivated by a nefarious motive or intent, or involved a willful, reckless or callous indifference to the federally protected rights and safety of Plaintiffs and others similarly situated. Punitive damages are therefore appropriate for a violation of 42 U.S. C. §§ 1981, 1983. 103. Under Minnesota Statutes, section 549.191, Plaintiffs must obtain leave of court to amend their complaint to seek punitive damages.
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Plaintiffs therefore reserve their right to allege punitive damages under Minnesota Statutes, section 549.20, if applicable.
PRAYER FOR RELIEF WHEREFORE, the named Plaintiffs and the other members of the class pray for relief as against Defendants as follows: 1. Certification of the above-described class with the named
Plaintiffs as class representatives; 2. For judgment for damages sufficient to compensate Plaintiffs and
other members of the class for their damages, including but not limited to monetary damages, restitution, and replacement damages; 3. For interest, as permitted by law; 4. For an accounting of property, including but not limited to cash, seized by the MGSF; 5. For the appointment of a receiver to be custodian of all MGSF and Board records, including but not limited to receipts for property taken, notices of forfeiture, arrest records, warrant inventory sheets, warrants related to seized items, etc., some of which MGSF personnel had already attempted to destroy and thus spoliate; 6. For their reasonable costs, including attorneys' fees as permitted by law; and 7. For all other just and proper relief.
DEMAND FOR JURY TRIAL Plaintiffs hereby demand a trial by jury for all issues so triable.
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DATED this 23rd day of September, 2009.
ZIMMERMAN REED, P.L.L.P.
By s/Robert R. Hopper Charles S. Zimmerman (MN # 120054) Robert R. Hopper (MN # 208760) David M. Cialkowski (MN #306526) 651 Nicollet Mall, Suite 501 Minneapolis, MN 55402 Phone: (612) 341-0400 Fax: (612) 341-0844
FISHMAN, BINSFELD & BACHMEIER, P.A.
Phillip F. Fishman (MN #29622) 8011 34th Avenue South, Suite #245 Bloomington, MN 55425 Phone: (612) 339-0033 Fax: (612) 339-3240 phil@fbblaw.com
THE ALVAREZ LAW FIRM Alex Alvarez (FL# 946346) 355 Palermo Avenue Coral Gables, FL 33134 Phone: (305) 444-7675 Fax: (305) 444-007 5 alex@integrityforjustice.com
ATTORNEYS FOR PLAINTIFFS
36

 
 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

ZELAIDO RIVERA GARCIA, et al. Plaintiffs,
v. METRO GANG STRIKE FORCE, et al.

Case No. 09-cv-01996-JNE-AJB Judge Joan N. Ericksen Magistrate Judge Arthur J. Boylan

Defendants.

SETTLEMENT ORDER AND FINAL JUDGMENT This action was heard on December 16, 2010, before the undersigned, upon Plaintiffs’ Motion for Final Approval of Settlement, Certification of Settlement Class, and Payment of Attorneys’ Fees and Reimbursement of Litigation Expenses (Docket #63), and pursuant to the Order Preliminarily Approving Settlement and Approving Notice to Class Members (the “Preliminary Approval Order”) entered on September 14, 2010, for the purpose of determining: (i) whether a settlement class could be certified pursuant to Rules 23(a) and 23(b)(3) of the Federal Rules of Civil Procedure; (ii) whether the proposed settlement (the “Settlement”) on the terms and conditions set forth in the Settlement Agreement previously submitted to the Court, should be approved as fair, reasonable and adequate; (iii) whether the method of notice was the best notice that was practicable under the circumstances pursuant to Rule 23(c)(2) of the Federal Rules of Civil Procedure; (iv) whether “incentive” or “special” awards for named plaintiffs serving as class representatives pursuant to the Settlement Agreement should be

7303392v1

approved; (v) whether Class Counsels’ application for fees and expenses is appropriate; and (vi) whether final judgment should be entered in this matter.
Having conducted the analysis required by the statute, the Court finds and concludes, for purposes of settlement only, that the requirements of Rules 23(a) and 23(b)(3) of the Federal Rules of Civil Procedure have been satisfied; that a settlement class should be certified; that the Settlement is fair, adequate, and reasonable; that notice was provided in accordance with Rule 23(c)(2); that “incentive” or “special” awards to named plaintiffs serving as class representatives should be approved; that Class Counsels’ fees and expenses are appropriate and should be awarded; and that final judgment should be entered.
Having considered the record in this action, IT IS HEREBY ORDERED, ADJUDGED AND DECREED as follows:
1. The “Definitions” section of the Settlement Agreement is incorporated herein by reference. All capitalized terms used in this Order have the meaning set forth in the Settlement Agreement unless otherwise expressly indicated.
2. This action is maintainable as a class action for settlement purposes only on behalf of a class (“the Settlement Class”) consisting of all persons who:
(a) have been stopped, questioned, arrested, charged, frisked, detained or searched (including but not limited to persons who have had property searched or seized), or whose dwelling was searched;
(b) by a peace officer or peace officers serving on or assisting the MGSF or by a peace officer or peace officers serving on or assisting the Minnesota Gang Strike Force;
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(c) in an incident where property was taken from one or more of the individuals stopped, questioned, arrested, detained or searched (or during a search and seizure of property belonging to one or more of such individuals); and
(d) the property was taken i. without a receipt or inventory itemization, or ii. without notification to the property owner of his or her right to contest the forfeiture.
The Settlement Class includes, but is not limited to, the persons whose property was taken in connection with one of the 202 incidents referenced in Finding 8 of the Report of the Office of the Legislative Auditor dated May 20, 2009.
The Settlement Class does not include persons who commenced and settled individual lawsuits against one or more of the Released Parties regarding claims encompassed in the definition of Released Claims.
3. For settlement purposes only, the Court finds that the prerequisites of Rule 23(a) and (b)(3) are satisfied and hereby certifies the foregoing defined Settlement Class pursuant to Rule 23(b)(3).
4. The prerequisites for class action treatment under Rules 23(a) and (b)(3) of the Federal Rules of Civil Procedure are satisfied by the Settlement Class, in that: (1) The number of class members comprising the Settlement Class is so numerous that joinder of all members is impracticable. Settlement Class includes, but is not limited to, the persons whose property was taken in connection with one of the 202 incidents referenced in Finding 8 of the Report of the Office of the Legislative Auditor dated May 20, 2009. (2) There are questions of law or fact common to the Settlement Class, including (a) whether
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Defendants were required to provide receipts of seized property, (b) whether Defendants were required to provide notices of the right to contest the forfeiture of property, (c) whether Defendants repeatedly failed to provide receipts of seized property, (d) whether Defendants repeatedly failed to provide notice of the right to contest the forfeitures as required by Minnesota law (Minn. Stat. § 609.5314), (e) whether Defendants acted under color of law when improperly seizing property, (f) whether Defendants failed to create records of seized property and incidents leading to the seizure of property, and (g) whether Defendants failed to properly maintain records of seized property and incidents leading to the seizure of property. (3) The claims or defenses of the proposed Class Representatives are typical of the claims or defenses of the other members of the Settlement Class. (4) The proposed Class Representatives and Class Counsel will fairly and adequately protect the interests of the Settlement Class. (5) The questions of law and fact common to the Settlement Class members predominate over any questions affecting only individual Settlement Class members. (6) Class action treatment is superior to other available methods for the fair and efficient resolution of this controversy. The Court also notes that, because this Action is being settled rather than litigated, the Court need not consider manageability issues that might be presented by the trial of a class action involving the issues in this case.
5. In making its findings, the Court has been provided copies of (1) the Report on the Metro Gang Strike Force issued by the Office of the Legislative Auditor for the State of Minnesota on or about May 20, 2009 and (2) the Report of the Metro Gang Strike Force Review Panel issued on or about August 20, 2009.
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6. The Court finds that counsel for the Plaintiffs, Zimmerman Reed, P.L.L.P., Fishman & Binsfeld P.A. and the Alvarez Law Firm, are competent to serve as Class Counsel and will fairly and adequately represent the interests of the class.
7. The Court has received and reviewed the following submissions regarding the implementation of notice:
(a) Affidavit of Elizabeth A. Peterson dated November 4, 2010 [Docket No. 67];
(b) Declaration of Jonathan Reid dated November 4, 2010 [Docket No. 68];
(c) Supplemental Affidavit of Elizabeth A. Peterson dated November 19, 2010 [Docket No. 70]; and
(d) Supplemental Declaration of Jonathan Reid dated November 19, 2010 [Docket No. 71].
8. Based on the submissions provided to the Court, the Court finds that notice has been given to the class pursuant to the Preliminary Approval Order, and that the mailing and publication of the Notice of Proposed Class Action Settlement and Release of Claims (the “Notice”) in accordance with the methodology adopted pursuant to this Settlement (a) was the best notice that was practicable to members of the Settlement Class; (b) was reasonably calculated, under the circumstances, to apprise members of the Settlement Class of the pendency of the Action, certification of the Settlement Class, the proposed Settlement, the rights of Class Members to object to the Settlement and the application of Plaintiffs’ counsel for payment of their attorneys’ fees and reimbursement of their litigation expenses, and to request exclusion from the Settlement Class; (c) was reasonable and satisfied the requirements of due process by providing due, adequate, and
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sufficient notice to all persons and entities entitled to receive notice; (d) clearly and concisely stated in plain, easily understood language: (i) the nature of the action, (ii) the definition of the class certified, (iii) the class claims, issues or defenses, (iv) that a class member may enter an appearance through an attorney if the member so desires, (v) that the court will exclude from the class any member who requests exclusion, (vi) the time and manner for requesting exclusion, and (vii) the binding effect of a class judgment on members under Rule 23(c)(3) of the Federal Rules of Civil Procedure; and (e) met all applicable requirements of law including, but not limited to, Rule 23(c) and the Due Process Clause of the Fifth Amendment to the United States Constitution.
9. Based on the submissions provided to the Court, the Court finds that Defendants have satisfied 28 U.S.C. § 1715(b) by, within 10 days after the Settlement was filed with the Court, serving upon the appropriate State official of each state in which a class member resides and the appropriate Federal official the Notice required under the statute. In accordance with 28 U.S.C. § 1715(d), more than 90 days have elapsed since the above-referenced notice was provided.
10. The terms of the Settlement, as set forth in the Settlement Agreement, are hereby determined to be fair, reasonable, and adequate. Accordingly, said Agreement, including each of its respective terms and conditions, is hereby finally approved.
11. At the request and suggestion of Class Counsel, the named plaintiffs serving as Class Representatives, namely Zelaido Rivera Garcia, Maura Gonzalez Salinas, Adrian Ramirez-Cuevas, and Camerina Cuevas Lopez, are awarded incentive awards in the amount of $2,500 each in addition to any distributions as part of the
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Settlement calculation to which they may be entitled, to compensate them for the time and efforts in leading this case for the benefits of the Class members.
12. The Court finds that counsel for the Plaintiffs, Zimmerman Reed, P.L.L.P., is competent to serve as Claims Administrator and will fairly and efficiently administer the remaining settlement requirements.
13. The Court hereby enters judgment fully and finally dismissing and terminating all claims with prejudice, on the merits, against Defendants.
14. The Settling Class Members, those persons bound by the Settlement Agreement and subject to this Settlement Order and Final Judgment, consist of all persons included within the Settlement Class except for the three individuals, identified in the Administrator’s Opt-Out Report, who filed timely requests for exclusion from the Settlement Class. (The three individuals identified in the Administrator’s Opt-Out Report are James Mackey, Maria Mackey and Kimberly Nagel.)
15. Pending the Effective Date, neither the Plaintiffs, nor any Settling Class Member, either directly, representatively, or in any other capacity, shall prosecute any action or proceeding in any court, tribunal or other forum asserting any of the Released Claims against the Released Parties.
16. As of the Effective Date: (a) Each Settling Class Member is deemed to have released and forever discharged the Released Parties from any and all Released Claims. (b) The Released Parties are not, and in the future shall not be, subject to liability or expense of any kind to Settling Class Members with respect to any of the Released Claims. The
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provisions of the Agreement shall be the exclusive remedy of all Settling Class Members against the Released Parties.
(c) Each Settling Class Member is forever barred from asserting any of the Released Claims against any of the Released Parties.
(d) Each Settling Class Member is deemed to have covenanted and agreed (a) that he or she will forever refrain from instituting, maintaining or proceeding against any Released Party on any Released Claim, including Released Claims known and not now known, suspected, or claimed, that they have or hereafter may have against the Released Parties; and (b) that he or she release the Released Parties from each and every such Released Claim.
17. As of the Effective Date, Settling Class Members are permanently enjoined
from filing, commencing, prosecuting, continuing, litigating, intervening in, participating
in as class members or otherwise, seeking to certify a class in a separate class of persons,
as a purported class action (including by seeking to amend a pending complaint to
include class allegations), or receiving any benefits or other relief from any other lawsuit,
arbitration or administrative, regulatory or other proceeding or order in any jurisdiction,
based on or relating to the claims and causes of action, or the facts and circumstances
relating thereto, in or underlying this action which qualify them as Class Members.
18. As of the Effective Date, all Settling Class Members are forever barred and
permanently enjoined from filing, commencing or prosecuting any other lawsuit as a
class action (including by seeking to amend a pending complaint to include class
allegations or by seeking class certification in a pending action in any jurisdiction), if
such other lawsuit is based on or relates to the claims and causes of action, or the facts
and circumstances relating thereto, in this action and/or the Released Claims.
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19. Attorneys’ fees are awarded as set forth in a separate order entered on this date.
20. Defendants have denied liability in this matter, and this Settlement does not constitute an admission of liability or wrongdoing. Neither this Final Judgment, the Settlement Agreement, the fact of settlement, the settlement proceedings, settlement negotiations, nor any related document, shall be used as an admission of any act or omission by Defendants or be offered or received in evidence as an admission, concession, presumption, or inference of any wrongdoing by Defendants in any proceeding other than such proceedings as may be necessary to consummate or enforce the Settlement.
21. Defendants shall have no responsibility for and shall have no liability whatsoever with respect to the allocation among Class Counsel and/or any other person who may assert a claim thereto, of any attorneys’ fees or expenses that the Court may award.
22. The Court retains jurisdiction over this Settlement to the extent necessary to implement, effectuate and administer this Settlement and this Settlement Order and Final Judgment, including, but not limited to, any issues arising from the Court’s award of attorneys’ fees.

This 16th day of December, 2010.

s/ Joan N. Ericksen Judge Joan N. Ericksen United States District Judge

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UNIT ED ST A T ES DISTRI C T C OURT DISTRIC T O F M INNESO T A

ZELAIDO RIVERA GARCIA, MAURA GONZALES SALINAS, ADRIAN RAMIREZCUEVAS, CAMERINA CUEVAS LOPEZ,

Case No. 09-CV-01996 (JNE/AJB)

Plaintiffs,

v.
METRO GANG STRIKE FORCE, RON RYAN, former Metro Gang Strike Force Commander, DOE OFFICERS 1-34, individually and in their official capacities, OTHER UNKNOWN DOE OFFICERS, CITY OF WEST ST. PAUL, a municipal corporation, HENNEPIN COUNTY, a direct political subdivision of the State, DAKOTA COUNTY, a direct political subdivision of the State, RAMSEY COUNTY, a direct political subdivision of the State, CITY OF ST. PAUL, a municipal corporation, CITY OF MINNEAPOLIS, a municipal corporation, WASHINGTON COUNTY, a direct political subdivision of the State, CITY OF MAPLEWOOD, a municipal corporation, CITY OF LINO LAKES, a municipal corporation, CITY OF BROOKLYN PARK, a municipal corporation, CITY OF RICHFIELD, a municipal corporation, METROPOLITAN COUNCIL, METRO GANG STRIKE FORCE ADVISORY BOARD, MANILA (“BUD”) SHAVER, Chief of the West St. Paul Police Department, KEN SCHILLING, Inspector at the Hennepin County Sheriff’s Office, DAVE BELLOWS, Chief Deputy of the Dakota County Sheriff’s Office, BOB FLETCHER, Sheriff of the Ramsey County Sheriff’s Office, JOHN HARRINGTON, Chief of the St. Paul Police Department, ROB ALLEN, Deputy Chief of the Minneapolis Police Department, BILL HUTTON, Sheriff of the Washington County Sheriff’s Office, DAVE THOMALLA, Chief of the Maplewood Police Department, DAVE PECCHIA, Chief of the Lino Lakes

SETTLEMENT AGREEMENT

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Police Department, DAVE INDREHUS, Chief of the Metro Transit Police Department, MICHAEL DAVIS, Chief of the Brooklyn Park Police Department, BARRY FRITZ, Captain of the Richfield Police Department,
Defendants. SETTLEMENT AGREEMENT
Plaintiffs Zelaido Rivera Garcia, Maura Gonzalez Salinas, Adrian Ramirez-Cuevas, and Camerina Cuevas Lopez (collectively “Plaintiffs” or “Class Representatives”), by and through their undersigned Counsel, hereby enter into this Settlement Agreement (the “Agreement” or the “Settlement”) to settle this class action lawsuit (the “Action”), subject to the approval of the United States District Court for the District of Minnesota, and pursuant to Federal Rule of Civil Procedure 23.
The undersigned Parties hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement, this Action shall be fully and finally settled upon the following terms and conditions, subject to Court approval: 1. Background
1.1 This Action, initially filed on July 30, 2009, asserts claims arising out of encounters between members of the class and law enforcement officers assigned to the Metro Gang Strike Force. The defendants consist of the Metro Gang Strike Force, certain Governmental Units, the Metro Gang Strike Force Advisory Board, certain Board Members, Ron Ryan, former Commander of the Metro Gang Strike Force, and unnamed Doe Officers 1-34, employees of their respective Governmental agencies who were allegedly assigned to the Metro Gang Strike Force.
1.2 The complaint, as amended (the “Complaint”), alleges that the class action is brought by Plaintiffs, on behalf of themselves and others similarly situated, to recover damages

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and to impose injunctive relief under the U.S. Constitution and the Civil Rights Act, 42 U.S.C. § 1981, § 1983 et seq. and § 1985 (“CRA”) (including but not limited to Monell claims), to recover monetary damages for negligence in the supervision and training of law enforcement employees and for liability based on respondeat superior, to recover monetary damages for civil tort conversion and conspiracy to convert, for civil tort of assault, for civil tort of false imprisonment, and for violations of the Minnesota State Constitution, and to recover punitive damages. Plaintiffs seek remedies for themselves and a class and subclass as defined in the Complaint for all claims set forth therein.
1.3 The defendants answered the Complaint and denied liability. 2. Definitions
2.1 “Additional Represented Class Members” means Class Members, other than the Class Representatives, who have individually retained and are represented by one or more of the attorneys identified as Class Counsel with respect to matters encompassed in the Released Claims.
2.2 “Administration and Notice-Related Costs” mean the costs associated with the implementation and administration of this Settlement and costs incurred in connection with providing notice by mail and by publication. Such costs include, but are not limited to, fees and expenses of the Administrator, the cost of mailing the Settlement Notice, the cost of updating addresses, the cost of placing publication notice in publications, the cost of translating notices, the cost of maintaining a website, the cost of maintaining a toll free call center to respond to questions from Class Members, and all costs, expenses and taxes associated with the escrow account from which disbursements will be made.

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2.3 “Administrator” means the entity appointed to administer the Notice Plan. Class
Counsel shall propose the Administrator, subject to Defendants’ right to object to such
appointment.
2.4 “Approved Claims” means claims made under the Claims Resolution Process
described in Section 11 that are determined (a) to be valid and (b) to entitle the Claimant to
compensatory damages and/or the return of property.
2.5 “Class Counsel” means:
Robert R. Hopper David M. Cialkowski ZIMMERMAN REED, P.L.L.P. 651 Nicollet Mall, Suite 501 Minneapolis, MN 55402
Phillip F. Fishman FISHMAN, BINSFELD & BAHMEIER, P.A. 8011 34th Ave. S., Ste. #245 Bloomington, MN 55425
Alex Alvarez THE ALVAREZ LAW FIRM 355 Palermo Ave. Coral Gables, FL 33134
2.6 “Class Member” means a person included within the Settlement Class
2.7 “Class Period” means the period from November 10, 1997 to the date upon which
the Court issues the Order granting preliminary approval of this Settlement.
2.8 “Defendants” means the persons and entities named as defendants in the
Complaint, consisting of, and specifically including:
METRO GANG STRIKE FORCE,
RON RYAN, former Metro Gang Strike Force Commander,
DOE OFFICERS 1-34, individually and in their official capacities,
OTHER UNKNOWN DOE OFFICERS,

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CITY OF WEST ST. PAUL, a municipal corporation, HENNEPIN COUNTY, a direct political subdivision of the State, DAKOTA COUNTY, a direct political subdivision of the State, RAMSEY COUNTY, a direct political subdivision of the State, CITY OF ST. PAUL, a municipal corporation, CITY OF MINNEAPOLIS, a municipal corporation, WASHINGTON COUNTY, a direct political subdivision of the State, CITY OF MAPLEWOOD, a municipal corporation, CITY OF LINO LAKES, a municipal corporation, CITY OF BROOKLYN PARK, a municipal corporation, CITY OF RICHFIELD, a municipal corporation, METROPOLITAN COUNCIL, METRO GANG STRIKE FORCE ADVISORY BOARD, MANILA (“BUD”) SHAVER, Chief of the West St. Paul Police Department, KEN SCHILLING, Inspector at the Hennepin County Sheriff’s Office, DAVE BELLOWS, Chief Deputy of the Dakota County Sheriff’s Office, BOB FLETCHER, Sheriff of the Ramsey County Sheriff’s Office, JOHN HARRINGTON, Chief of the St. Paul Police Department, ROB ALLEN, Deputy Chief of the Minneapolis Police Department, BILL HUTTON, Sheriff of the Washington County Sheriff’s Office, DAVE THOMALLA, Chief of the Maplewood Police Department, DAVE PECCHIA, Chief of the Lino Lakes Police Department,
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DAVE INDREHUS, Chief of the Metro Transit Police Department, MICHAEL DAVIS, Chief of the Brooklyn Park Police Department, BARRY FRITZ, Captain of the Richfield Police Department.
2.9 “Effective Date” means the date on which the time for appeal from the Final Judgment approving the Agreement has elapsed without any appeals being filed; or, if appeals are filed, the date on which appeals from the Final Judgment approving this Agreement or from any appellate court decisions affirming the Final Judgment have been exhausted, and no further appeal may be taken.
2.10 “Hotline” means the hotline certain defendants established, administered by the League of Minnesota Cities Insurance Trust, to facilitate the voluntary return of certain property seized.
2.11 “MGSF” means Metro Gang Strike Force. 2.12 “P.O.S.T.” means Minnesota Peace Officers Standards and Training Board. 2.13 “Released Claims” means any and all past or present claims or causes of action, however denominated (including any claims in law, equity or arbitration, arising by statute, common law or otherwise), of whatever kind or description, direct or indirect, in law or equity, in tort, contract, or otherwise, for compensation or relief of any kind (including but not limited to compensatory damages, punitive damages, attorneys’ fees1 or injunctive relief), known or unknown, occurring at any time, which: (a) were or could have been asserted in the Complaint or in any Amended
Complaints; or

1 Nothing herein shall be construed to abridge or modify Section 10 of this Agreement, under which the Defendants have agreed to pay up to a stated maximum for Class Counsel’s Attorneys’ Fees and Expenses.

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(b) relate to the Metro Gang Strike Force or officers or other persons acting on behalf of the Metro Gang Strike Force; or
(c) relate to the Minnesota Gang Strike Force or officers or other persons acting on behalf of the Minnesota Gang Strike Force; or
(d) relate to any of the subjects referenced in the Report on the Metro Gang Strike Force issued by the Office of the Legislative Auditor for the State of Minnesota on or about May 20, 2009; or
(e) relate to any of the subjects referenced in the Report of the Metro Gang Strike Force Review Panel issued on or about August 20, 2009; or
(f) assert fraud in the inducement of this Settlement. The term “or” as used in this definition of Released Claims (and in all releases and covenants not to sue) is inclusive. The release of claims in two or more categories connected by the term “or” will release all claims in each such category. 2.14 “Released Persons” means the Defendants, Ron Ryan, personally, individually and in his official capacity and in his capacity as Commander of the Metro Gang Strike Force and Minnesota Gang Strike Force; the Metro Gang Strike Force Advisory Board; Manila Shaver, Chief of the West St. Paul Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; Ken Schilling, Inspector, Hennepin County Sheriff’s Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; David Bellows, Chief Deputy of the Dakota County Sheriff’s Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; Robert Fletcher, Sheriff of Ramsey County, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; John Harrington, Chief of Police with the City of St. Paul, personally, individually and in his official capacity and in his capacity as a member of the Metro

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Gang Strike Force Advisory Board; Robert Allen, Deputy Chief, Minneapolis Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; William Hutton, Sheriff of Washington County, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; David Thomalla, Chief of the Maplewood Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; David Pecchia, Chief of the Lino Lakes Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; David Indrehus, Chief of the Metro Transit Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; Michael Davis, Chief of Brooklyn Park Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; Barry Fritz, Captain of the Richfield Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; Tom Lauth, Chief of the North St. Paul Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; Cari Gerlicher, Director of the Office of Special Investigations, personally, individually and in her official capacity; all persons or entities advising or providing legal representation to the Metro Gang Strike Force or Minnesota Gang Strike Force, its Advisory Boards, member officers, employees and all other persons associated with the Metro Gang Strike Force or Minnesota Gang Strike Force, individually and in their official capacity; the League of Minnesota Cities Insurance Trust; the Metro Gang Strike Force; the Minnesota Gang Strike Force; all employees, advisors, officers,

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supervisors, commanders and other persons assigned or working for or associated with the Metro

Gang Strike Force or the Minnesota Gang Strike Force, personally and in their official and

individual capacities; all members of the Metro Gang Strike Force and/or Minnesota Gang Strike

Force Boards, Governing Boards and Advisory Boards and municipal members of the Metro

Gang Strike Force and/or Minnesota Gang Strike Force including, but not limited to, the City of

West St. Paul, Hennepin County, Dakota County, Ramsey County, City of St. Paul, Washington

County, the City of Maplewood, the City of Lino Lakes, the City of Brooklyn Park, the City of

Richfield, the City of North St. Paul, the Metropolitan Council, and the City of Minneapolis; the

State of Minnesota, and its past and present employees, public officials, departments, including

but not limited to the Minnesota Department of Corrections and the Minnesota Department of

Public Safety, agencies, political subdivisions, divisions, joint ventures, and attorneys; Criminal

Gang Council and the Gang and Drug Oversight Council and its membership, participating

officers and coordinators; task forces, joint powers, entities and members thereof; and for each

above entity, department, Board, municipality or organization, their past, present and future

officers, directors, officials, attorneys, employees, principals, police chief, police officers, agents,

Board members, representatives, insurers, administrators, executors, advisors, successors and

assigns and all other persons or entities. 2.15 “Settlement Class” consists of all persons who:

(a) have been stopped, questioned, arrested, charged, frisked, detained or searched (including but not limited to persons who have had property searched or seized), or whose dwelling was searched,
(b) by a peace officer or peace officers serving on or assisting the MGSF or by a peace officer or peace officers serving on or assisting the Minnesota Gang Strike Force,
(c) in an incident where property was taken from one or more of the individuals stopped, questioned, arrested, detained or searched (or during a search and seizure of property belonging to one or more of such individuals), and

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(d) the property was taken i. without a receipt or inventory itemization, or ii. without notification to the property owner of his or her right to contest the forfeiture.
The Settlement Class includes, but is not limited to, the persons whose property was taken in connection with one of the two hundred two (202) incidents referenced in Finding 8 of the Report of the Office of the Legislative Auditor dated May 20, 2009.
The Settlement Class does not include persons who commenced and settled individual lawsuits against one or more of the Released Parties regarding claims encompassed in the definition of Released Claims.
For purposes of this Settlement Class definition, the term “or” is inclusive, such that “persons in Group A or Group B” encompasses all persons in Group A or Group B or both.
2.16 “Settlement Fund” has the meaning given to that term in Section 9 of this Agreement.
2.17 “Settling Class Member” means any person falling within the definition of the Settlement Class, except for persons who file timely and valid Requests for Exclusion from the Settlement Class and do not timely withdraw such Requests for Exclusion.
2.18 “Submitted Claim” means a claim submitted to the Special Master under the Claims Resolution Process set forth in Section 11 of this Agreement where the Claimant submits a completed claim form, including a sworn statement of the facts. 3. Settlement Class
3.1 Plaintiffs will seek, and Defendants will not oppose, certification of the Settlement Class by the Court, pursuant to Federal Rule of Civil Procedure, for the purpose of

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settlement only. At the same time, Plaintiffs will seek, and Defendants will not oppose, approval
of Plaintiffs as Class Representatives and the following attorneys as Class Counsel:
Robert R. Hopper David M. Cialkowski ZIMMERMAN REED, P.L.L.P. 651 Nicollet Mall, Suite 501 Minneapolis, MN 55402
Phillip F. Fishman FISHMAN, BINSFELD & BAHMEIER, P.A. 8011 34th Ave. S., Suite 245 Bloomington, MN 55425
Alex Alvarez THE ALVAREZ LAW FIRM 355 Palermo Ave. Coral Gables, FL 33134
3.2 Defendants conditionally agree and consent to certification of the Settlement
Class pursuant to Federal Rule of Civil Procedure 23 for settlement purposes only, and for the
sole purpose of creating the Settlement Class. Defendants’ agreement is contingent upon: (1) the
Parties’ execution of this Agreement; (2) the Court’s approval of this Agreement; and (3) the
occurrence of the Effective Date. If this Agreement is for any reason not approved or the
Effective Date does not occur, Defendants reserve their right to reassert all of their objections
and defenses to certification of any class, and neither Plaintiffs nor Class Counsel will offer
Defendants’ conditional agreement to certification of the Settlement Class as evidence in support
of a motion to certify any class.
3.3 Plaintiffs will request that notice and an opportunity to request exclusion from the
Settlement Class be provided to all persons within the Settlement Class. Defendants will not
oppose such request.

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4. Preliminary Approval 4.1 Plaintiffs, Class Counsel, and Defendants shall promptly submit this Agreement

and Settlement to the Court and jointly request that the Court enter a Preliminary Approval Order

substantially in the form attached hereto as Exhibit 1:

(a) certifying the Settlement Class pursuant to Federal Rule of Civil Procedure 23 for purposes of settlement only;
(b) preliminarily approving the Settlement;
(c) appointing the Administrator;
(d) approving the Escrow Agreement and the creation of the Settlement Fund;
(e) setting a date for the Fairness Hearing, no earlier than ninety (90) days after notice of this proposed Settlement is provided to state and federal officials consistent with the requirements of 28 U.S.C. § 1715, to determine finally (i) whether the Settlement Class can be certified pursuant to Rules 23(a) and 23(b)(3) of the Federal Rules of Civil Procedure, (ii) whether the Settlement Agreement should be finally approved by the Court as fair, reasonable, and adequate, (iii) whether the notice proposed by the parties is the best notice practicable under the circumstances and clearly and concisely provides plain, easily understood language that satisfies Rule 23(c)(2) of the Federal Rules of Civil Procedure, and (iv) whether Class Counsel’s application for fees and expenses should be approved;
(f) approving the Notice Plan;

(g) prescribing a period of time during which persons within the Settlement Class may file Requests for Exclusion;

(h) providing that any objections to the Agreement, the Settlement, or Class Counsel’s application for an award of attorneys’ fees and expenses shall be considered by the Court at the Fairness Hearing only if, on or before a date to be specified in the Preliminary Approval Order, the Class Member making any objection shall mail a copy of his or her written objection(s) and/or notice of intent to appear at the Fairness Hearing (any of which shall set forth briefly each objection and all reasons and substantiation therefore) to the Administrator;
(i) providing that, pending final determination of whether the Settlement should be approved, this Action shall be stayed (except for matters related to the completion of the Settlement), and neither the Plaintiffs, nor any Class Member, either directly, representatively, or in any other capacity, shall commence or prosecute any action or proceeding in any court or tribunal asserting any of the Released Claims against the Released Persons.

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5. Notice Plan

5.1 Defendants shall, through a good faith effort limited to the review of the police

reports made available to Class Counsel, endeavor to identify (a) all persons stopped, questioned,

arrested, frisked, detained or searched in connection with any of the two hundred two (202)

incidents referenced in Finding 8 of the Report of the Office of the Legislative Auditor dated

May 20, 2009, and (b) the most current mailing address associated with each such person

identified.

5.2 On or before September 10, 2010 or the date five (5) business days after the entry

of the Preliminary Approval Order, whichever is later, Defendants shall deliver to the

Administrator a list of (a) the names and addresses identified pursuant to Section 5.1, and (b) the

names and addresses of persons who submitted claim forms to the Hotline administered by the

League of Minnesota Cities Insurance Trust.

5.3 On or before September 10, 2010, Class Counsel shall deliver to the

Administrator (a) a list of all persons, other than the Class Representatives, whom Class Counsel

have reason to believe are included within the Settlement Class Definition, and (b) the most

current mailing address associated with each such person identified. This list shall include (but

will not be limited to) the Additional Represented Class Members. In addition, prior to the time

notice is mailed and published, Class Counsel will provide Defendants with a list of the

Additional Represented Class Members.

5.4 The Administrator shall run the addresses provided by Class Counsel and

Defendants in Sections 5.1 through 5.3 through the National Change of Address database, and

shall use the most current address reasonably available to the Administrator.

5.5 Within fourteen (14) days following the Administrator’s completion of Section

5.4, or the date five (5) business days after the entry of the Preliminary Approval Order,

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whichever is later, the Administrator shall mail, or cause to be mailed, copies of the Settlement Notice, by first class United States mail, postage prepaid, to all Potential Class Members at the most recent address obtained by the methods described above in Sections 5.1 through 5.4. The English language portion of the Settlement Notice shall be substantially in the form attached hereto as Exhibit 2. The Settlement Notice will also include translations in Spanish, Hmong, Vietnamese and Somali. If a notice is returned to the Administrator with a forwarding address, the Administrator will re-send the notice within three (3) business days and update its database to reflect the updated address information for that potential Class Member. If Defendants or Class Counsel are provided with updated address information for any potential Class Member they will provide the information to the Administrator within one (1) business day and the Administrator will re-send the notice within three (3) business days and update its database to reflect the updated address information for that potential Class Member.
5.6 Within seven (7) days of completion of the mailing of the Settlement Notice as in Section 5.5, the Administrator shall cause Publication Notice of this Settlement to be published. The English language version of the Publication Notice, substantially in the form attached hereto as Exhibit 3, shall be published in the Minneapolis Star Tribune; Pioneer Press; City Pages; Asian Pages; Ngay Nay Vietnamese Midwest Newspaper; Hmong Time; Mshale, The African Community Newspaper; and Warsan Times. Translated versions of the Publication Notice shall be published in the following publications:
Mi Gente de Minnesota – Spanish La Prensa de Minnesota – Spanish La Voz Latina – Spanish Latino Midwest News – Bilingual The Korean Press

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Saigon Newspaper of Minnesota
5.7 It is agreed by the Parties that this procedure constitutes an appropriate, reasonable, and practicable method to locate current addresses for Class Members and provide notice thereto. No additional efforts shall be required.
5.8 In addition to mailing notice to Potential Class Members and publishing notice as set forth above, the Administrator shall establish a website and post on that website the Settlement Agreement, Settlement Notice and FAQs - frequently-asked questions and answers as provided by Class Counsel.
5.9 The names, addresses, telephone numbers, and any other personal identifying information of all Potential Class Members shall be kept confidential by the Administrator and not disclosed to any person except as required under 28 U.S.C.§ 1715 or as ordered by the Court upon good cause shown, and shall be used only for the purposes of this Agreement.
5.10 The Administrator shall file with the Court a report on efforts undertaken to implement the Notice Plan at or before the Fairness Hearing. Copies shall be provided to Class Counsel and Defendants. 6. Requests for E xclusion
6.1 Any person coming within the Settlement Class definition who wishes to be excluded from the Settlement Class must provide a written Request for Exclusion from the Settlement Class to the Administrator by the deadline established in the Preliminary Approval Order (“Opt Out Deadline”). The Parties will ask the Court to establish an Opt Out Deadline of no later than forty-five (45) calendar days following the date on which the Settlement Notice is first mailed by the Administrator. Any Request for Exclusion must be signed by the person seeking exclusion (or the parent or guardian of a minor), and must clearly state his or her desire

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to be excluded from the Settlement Class, and include his or her name, current address and

telephone number. Any person within the Settlement Class definition who provides a Request

for Exclusion to the Administrator may withdraw (in writing) such Request for Exclusion, and

thus elect to be included as a Settling Class Member, at any time prior to the Opt-Out Deadline.

Any withdrawal of a Request for Exclusion must be signed by the person seeking the withdrawal

(or the parent or guardian of a minor), and must clearly state his or her desire to be withdraw the

Request for Exclusion, and include his or her name, current address and telephone number.

6.2 The Administrator will promptly provide unredacted copies of any Requests for

Exclusion, and any withdrawals thereof, to Defendants and Class Counsel. On the date of the

Fairness Hearing, counsel for Defendants and Class Counsel will jointly submit to the Court a

report identifying all persons making Requests for Exclusion that were not thereafter timely

withdrawn and the date on which each request was postmarked (or if there is no postmark or

legible postmark date, the date received by the Administrator). To the extent the Court requires

filing of the report, it shall be filed under seal.

6.3 Any person within the Settlement Class definition who does not file a timely

Request for Exclusion from the Settlement Class, or who timely withdraws a Request for

Exclusion, shall be deemed a Settling Class Member for all purposes under this Agreement.

6.4 Class Counsel are authorized to represent that the Additional Represented Class

Members agree to the terms of this Agreement and will not request exclusion.

7. Objections to Settlement

7.1 Any Class Member may object to the proposed Settlement. The Class Member,

or personal counsel retained at the Class Member’s expense, must mail the objection to the

Administrator by the deadline established in the Preliminary Approval Order (“Objection

Deadline”). The Parties will ask the Court to establish an Objection Deadline of no later than

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forty-five (45) calendar days following the date on which the Settlement Notice is first mailed by

the Administrator. Objections must be in writing and must provide a detailed description of the

nature and basis for each objection, the Class Member’s name, address and telephone number,

and, if represented by personal counsel, counsel’s name, address and telephone number. Prior to

the Fairness Hearing, the Administrator will file with the Court any timely objections received,

and will promptly provide unredacted copies of any timely objections received to Class Counsel

and Defendants.

7.2 Any Class Member may appear at the Fairness Hearing, either in person or

through personal counsel, retained at the Class Member’s expense, to voice an objection to the

Settlement or to comment on the Settlement, if the Class Member has filed a timely objection

pursuant to paragraph 7.1. Class Members or their attorneys who wish to appear at the Fairness

Hearing must make such a request in writing and mail it to the Clerk of the United States District

Court for the District of Minnesota with copies to counsel for Defendants and Class Counsel

prior to the Objection Deadline. The written request to appear must include the name, address

and telephone number of the person who will appear at the Fairness Hearing and a copy of the

written objection to the Settlement.

7.3 Any Class Member who fails to comply with the provisions of paragraphs 7.1 and

7.2 shall waive and forfeit any and all rights that he or she may have to appear separately and/or

object to or comment on the Settlement.

8. Defendants ’ Payment Obligation

8.1 Defendants agree to pay, in total, (a) Three Million Dollars ($3,000,000) to be

used as set forth in Section 9 and (b) an additional amount as set forth in Section 10.2(a) for

Class Counsel’s attorneys’ fees and litigation expenses. The amounts set forth in the preceding

sentence shall be the exclusive monetary obligation of Defendants in connection with the

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Agreement and Settlement. Plaintiffs and Class Counsel agree that they shall not seek any
further money, funds or other remuneration from any Defendant or Released Person in
connection with this Settlement, whether for attorneys’ fees, litigation expenses, Administration
Costs, or anything else.
8.2 The amounts due under Section 8.1 will be deposited into an interest-bearing
Settlement Fund Escrow Account (the “SFEA”) as set forth in the Settlement Fund Escrow
Agreement (“SFEA Agreement”) attached as Exhibit 5 hereto.
(a) The establishment of the SFEA shall be submitted to the Honorable Joan N. Ericksen, United States District Court for the District of Minnesota, for approval, shall be deemed to be in custodia legis, and shall remain subject to the jurisdiction of the Court until the Settlement Fund is fully distributed or returned to Defendants in the event of a termination as provided in Section 15 of this Agreement, or until further order of the Court. The Parties agree they will cooperate to prepare and file any application, petition, or other document necessary to establish and/or administer the SFEA. The Parties agree that, if requested by Defendants, any application, petition, or other court filing relating to the SFEA shall be filed or submitted under seal.
(b) Defendants will deposit One Hundred Fifty Thousand Dollars ($150,000) of the Settlement amount described in 8.1(a) within five (5) business days following the entry of the Preliminary Approval Order, and will deposit the remainder of this payment obligation within two (2) business days following the Effective Date. If, at the time of the Effective Date as to the Settlement, there is a continuing dispute or appeal regarding Attorneys Fees and Expenses as described in 8.1(b), then Defendants will deposit the undisputed portion of Attorneys Fees and Expenses.
(c) All awards, payments and disbursements to be made under this Agreement shall be made from the SFEA. Defendants’ only payment obligation is to pay the amounts due under Section 8.1, and, apart from that obligation, Defendants and the Released Persons shall not be responsible for any awards, payments, costs, disbursements, payments, fees or taxes.
(d) The Parties acknowledge and agree that all awards, payments and disbursements to be made from SFEA must first be approved by the District Court Judge.
(e) Prior to the Effective Date, any request or application for awards, payment or disbursements pursuant to this provision or Section 5 shall be provided to Defendants at the same time it is submitted to the Court. Defendants may request updates regarding funds available in the Settlement Fund on a reasonable basis that is not overly burdensome to Class Counsel.

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(f) If the Settlement becomes final (i.e., if there is an Effective Date), then:
i. The Attorneys Fees and Expenses (or, in the event of a continuing dispute or appeal over Attorneys Fees and Expenses, the undisputed portion of Attorneys Fees and Expenses) shall be payable to Class Counsel immediately following deposit; and
ii. The portion of the $3 million amount identified in Section 8.1 and Section 9 that remains in the SEFA (after amounts previously disbursed for notice and other expenses) shall be disbursed as set forth in Section 9.
(g) In the event that this Settlement becomes final, Defendants will continue to receive notice consistent with Section 8.2(e) and may continue to request updates regarding funds available in the Settlement Fund on a reasonable basis that is not overly burdensome to Class Counsel for purposes of estimating the amount of funds that may be available for Law Enforcement Training and Education. However, following the Effective Date, Defendants will not have the right to control or direct the distribution of proceeds.
(h) Defendants shall have no liability or responsibility with respect to disbursements from or the administration of the SFEA. To the extent that there is any ambiguity or inconsistency concerning disbursements when this Agreement and the SFEA Agreement are read together, the terms of this Agreement shall control. Furthermore, the parties recognize that the exact language of the SFEA is yet to be determined, and agree that, prior to the time the SFEA is executed, each party reserves the right to insist on revisions to the draft SFEA (attached as an exhibit) to conform to the terms of this Agreement.
(i) U.S. Bank National Association shall serve as escrow agent (“Escrow Agent”) for the SFEA pursuant to the SFEA Agreement. If this Settlement becomes final, then the Escrow Agent’s costs, fees, and expenses shall be paid out of the SFEA, or as required by any subsequent order of the Court. If the Settlement does not become final, and subject to Section 15 below, all of the Escrow Agent’s costs, fees, and expenses shall be paid out of the SFEA before the money remaining in the SFEA is returned to Defendants in accordance with Section 15 of this Agreement.
(j) To the fullest extent allowable under applicable law, the SFEA shall be treated as being at all times a “qualified settlement fund” within the meaning of Treas. Reg. § 1.468B-1. The Escrow Agent shall timely make such elections as are necessary or advisable to carry out the provisions of this Agreement, including the “relation-back election” (as defined in Treas. Reg. § 1.468B-1) back to the earliest permitted date. To the extent applicable law may require Class Counsel or Defendants to make such elections, the Escrow Agent shall so advise Class Counsel or Defendants, and they shall cooperate in accordance with applicable law. Such elections shall be made in compliance with the procedures and requirements contained in such regulation. It shall be the sole responsibility of

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the Escrow Agent to timely and properly prepare and deliver the necessary documentation for signature by all necessary Parties, and thereafter to cause the appropriate filing to occur.
(k) For the purpose of Section 468B of the Internal Revenue Code of 1986, as amended, and the regulations promulgated thereunder, the “administrator” shall be the Escrow Agent. The Escrow Agent shall timely and properly file all informational and other tax returns necessary or advisable with respect to the SFEA and the amounts held in the SFEA (including, without limitation, the returns described in Treas. Reg. § 1.468B-2(k), (l)). Such returns (as well as the election described in Section 8.2(j) shall be consistent with all other provisions of this Agreement and in all events shall reflect that all taxes (including any estimated taxes, interest or penalties, or tax detriments) on the income earned by the SFEA shall be paid out of the SFEA, in accordance with Section 8.2(l). The costs, fees, and expenses associated with the filing of any such tax returns shall be paid exclusively out of the SFEA.
(l) All (1) federal, state, and local taxes (including any estimated taxes, interest or penalties, or tax detriments) arising with respect to the income earned on or by the SFEA, including any taxes, interest or penalties, or tax detriments that may be imposed upon Defendants with respect to any income earned on or by the SFEA for any period during which the SFEA (or any portion thereof) does not qualify as a “qualified settlement fund” for federal or state income tax purposes (“Taxes”), and (2) expenses and costs incurred in connection with the administration of tax matters for the SFEA and the operation and implementation of this Agreement (including, without limitation, expenses of tax attorneys and/or accountants and mailing and distribution costs and expenses relating to filing (or failing to file) the returns described in this Agreement) (“Tax Expenses”), shall be paid out of the SFEA. The Escrow Agent shall notify Class Counsel and Defendants in writing of the fact and amount of any such payment of Taxes and/or Tax Expenses out of the SFEA (and any withholding pursuant to this Agreement).
(m) Taxes and Tax Expenses shall be timely paid by the Escrow Agent out of the SFEA without prior order from the Court. The Parties agree that Defendants and the Released Persons, as defined in the Release, shall have no obligation and incur no liability whatsoever with respect to the payment of such amounts. The Escrow Agent shall be obligated (notwithstanding anything herein to the contrary) to withhold from distribution out of the SFEA any funds necessary to pay such amounts, including the establishment of adequate reserves for any Taxes and Tax Expenses (as well as any amounts that may be required to be withheld under Treas. Reg. § 1.468B-2(l)(2)).
(n) The Parties agree to cooperate with the Escrow Agent, each other, and their tax attorneys and accountants to the extent reasonably necessary to carry out the provisions this Agreement.

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(o) The Parties agree and acknowledge that no amount of the Settlement Fund and no payment into the SFEA constitutes or shall in any way be deemed a payment of a penalty or a fine of any kind paid to a government for a violation of law. The Parties agree and acknowledge that no amount of the Settlement Fund and no payment into the SFEA constitutes or shall in any way be deemed a payment of a penalty or a fine of any kind paid to a government for a violation of law. These payments do not constitute, nor shall they be construed as or treated as, payments in lieu of treble damages, fines, penalties, or punitive recoveries.
9. Defendants ’ O bligation to Pay $3 M illion: T he Settlement F und
9.1 In consideration for the settlement of this matter, Defendants shall pay $3 million
(the “Settlement Fund”) to be used to pay for:
(a) Administration and Notice-Related Costs;
(b) Special Master Fees, if any;
(c) Payments for Service as Class Representatives. Class Counsel will, upon motion, request that class representatives are allocated a fee for their service of Two Thousand Five Hundred Dollars ($2,500.00) for each representative. There are four (4) class representatives; therefore, the total payment will be Ten Thousand Dollars ($10,000.00);
(d) Approved Claims;
(e) Fees for Class Counsel’s Law Enforcement Training and Education Representative(s);
(f) Amounts, if any, awarded to Class Counsel under Section 10.2(b), and
(g) Law Enforcement Training and Education. 9.2 The portion of the Three Million Dollars ($3,000,000) that is not spent on any of
the categories set forth in (a) through (f) shall be spent on Law Enforcement Training and
Education.
10. A ttorneys ’ Fees and E xpenses
10.1 The amount of attorneys’ fees and litigation expenses to be paid to Class Counsel
shall be determined by the Court, but shall be no more than the amounts set forth in Section 10.2.

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10.2 Class Counsel and Defendants have agreed that (i) the amount of attorneys’ fees
and litigation expenses to be requested by Class Counsel shall not exceed the amounts set forth
in Sections 10.2(a) and 10.2(b) below, and (ii) Defendants shall not object to requests in
accordance with the ceilings set forth in Sections 10.2(a) and 10.2(b) below.
(a) Attorneys Fees and Litigation Expenses to Be Paid by Defendants
i. The amounts of attorneys’ fees and litigation expenses to be paid under this Section 10.2(a) shall be paid by the Defendants, and shall not affect the relief available to the Class.
ii. Class Counsel may request up to Seven Hundred Fifty Thousand Dollars ($775,000) in attorneys fees and litigation expenses without regard to the number of Settling Class Members who submit claims to the Special Master under the Claims Resolution Process described in Section 11 of this Agreement.
iii. If the number of Submitted Claims is between fifty-one and one hundred (100), Class Counsel may request an additional Twenty-Five Thousand Dollars ($25,000) in attorneys’ fees and litigation expenses, resulting in a maximum request of Eight Hundred Thousand Dollars ($800,000).
iv. If the number of Submitted Claims is one hundred one (101) or more, Class Counsel may request an additional Twenty-Five Thousand Dollars ($25,000) in attorneys’ fees and litigation expenses, resulting in a maximum request of Eight Hundred Twenty-Five Thousand Dollars ($825,000).
v. Regardless of the number of Submitted Claims, Defendants shall not pay any more than Eight Hundred Twenty-Five Thousand Dollars ($825,000) in attorneys’ fees and litigation expenses.
(b) Class Counsel’s Contingent Right to Request an Additional Award from the Settlement Fund
If the number of Submitted Claims exceeds one hundred one (101), and Class Counsel
contends that its lodestar is in excess of Eight Hundred Twenty-Five Thousand Dollars
($825,000), then Class Counsel may move the Court for an additional award of Attorneys Fees
and Expenses to be paid from the Settlement Fund identified in Section 9.1 of this Agreement.
The amount of any such additional request shall be no greater than the lesser of (a) the difference

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between the claimed lodestar and Eight Hundred Twenty-Five Thousand Dollars ($825,000) or (b) One Hundred Thousand Dollars ($100,000).
10.3 The determination of any dispute over attorneys’ fees and expenses will not affect the enforceability of the remainder of the Agreement.
11. T he C laims Resolution Process 11.1 A Class Member may seek compensation from the Settlement Fund based on a
claim that one or more of the Defendants is liable to the Class Member under one or more of the causes of action identified in the Complaint. The term “Claims Resolution Process” refers to the procedures for submitting such claims; and the method for determining whether the claimant is entitled to compensation; and, if so, the amount of money the claimant is entitled to receive as compensation. A Class Member is not eligible to receive any payment under this Settlement unless he or she submits a timely claim under the Claims Resolution Process.
11.2 As set forth above, any person within the Settlement Class definition who does not file a timely Request for Exclusion from the Settlement Class shall be deemed a Settling Class Member, and shall be deemed to have released his or her claims, without regard to whether that Settling Class Member makes a claim or is determined to be entitled to compensation.
(a) Process for Each Claim Initiated by Compilation of Information in a Claim Form. i. A claimant shall initiate a claim by submitting a claim form as set forth in Exhibit 6. A completed form shall include a sworn statement of the facts. (The claimant can also submit other documentary evidence.) The completed form shall also confirm the claimant’s express agreement to the terms of the Settlement. ii. A claim must be submitted by a date to be determined. Any claim submitted after that date will be untimely, and the claimant submitting such an untimely claim will not be eligible for an award of compensation.

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iii. Class Counsel will compile the information for the claim form and will evaluate the claim based on objective criteria (e.g., whether the claimant’s encounter was with a member of the MGSF, etc.). Class Counsel will also check off the causes of action to be considered by the Special Master from among a list to be included on the form.
(b) Defendants’ Opportunity to Submit Information to Be Included, Unaltered, in the Claim Form.
i. After the claim is initiated as set forth above, the claim form as completed to that point will be provided to Defendants for review. Following receipt of a claim form in which a claimant seeks a return of property, Defendants will (A) engage in a reasonable effort to determine whether there is any property in possession of Defendants in connection with an incident within the scope of the Released Claims and (B) inform Class Counsel about any such property within twenty-one (21) days of Defendants’ receipt of the claim form. Such information will be attached to the claim form that is submitted to the Special Master for review.
ii. Defendants will also have the opportunity, but not the obligation, to submit sworn statements and/or documentary evidence (e.g., police reports), a statement of up to two (2) pages (or such additional length as may be allowed by the Special Master ) commenting on the merits of the claim, and/or a statement indicating whether any property is available to be returned to the Claimant. Class Counsel will insert or attach the Defendants’ submission, unaltered, to the section of the claim form allotted for that purpose so that it is considered (along with all other information) by the Special Master.
iii. Defendants have twenty-one (21) days upon receipt of the claim form to submit any of the information identified in 11.2(b)(ii) above. If no such information is provided after twenty-one (21) days, Class Counsel will deem the opportunity waived by Defendants and the claim will be submitted to the Special Master without a statement or documents from the Defendants.
iv. If the Defendants elect to make a submission as to a particular claim, that Claimant has the opportunity to submit a supplementary sworn statement and/or documentary evidence and/or a statement of up to one (1) page (or such additional length as may be allowed by the Special Master) responding to Defendants’ submission, which will be included in the claim form.
(c) Special Master’s Authority to Decide the Validity of Each Claim and, as to Valid Claims, the Amount to Be Received by the Claimant.

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i. A Special Master shall be appointed by the Court. The parties request that the Court appoint Magistrate Judge Arthur J. Boylan as Special Master.
ii. The Special Master will determine the validity of each claim and, as to valid claims, the amount of compensatory damages to be paid and/or property to be returned to a claimant. The Special Master shall be solely responsible for making these determinations.
iii. The Special Master will make his or her determination regarding any questions of fact based solely on the claim form (including any attachments). There will be no live testimony.
iv. The determination of the validity of each claim (and, as to valid claims, the amount of compensatory damages to be paid to a claimant) shall be based upon the facts and informed by the law that applies to each cause of action (including any applicable statute of limitations). As to federal claims, the Special Master may look to 8th Circuit law. As to state law claims, the Special Master may look to Minnesota law.
v. There will not be any punitive damages or attorneys’ fees awards.2 Only compensatory damages, the return of property, or both, will be awarded.
vi. The Claimant shall not be entitled to receive compensation that is duplicative of compensation previously received by the Claimant in connection with the Hotline administered by the League of Minnesota Cities Insurance Trust. Defendants will provide the Special Master with a list of claimants compensated through the Hotline administered by the League of Minnesota Cities Insurance Trust and any corresponding compensation amounts.
vii. The Special Master will notify the parties in writing regarding his or her determination of a claim.
(d) Claimants, But Not Defendants, Will Have the Right to Appeal to the District Court Judge
i. A claimant may appeal the Special Master’s determination regarding (a) the validity of his or her claim and/or (b) as to valid claims, the amount of compensatory damages to be paid. The appeal must be submitted to the District Court Judge in writing within ten (10) business days following receipt of Special Master’s determination. Notice of an appeal must be sent to Class Counsel for tracking purposes and to Counsel for Defendants. The Defendants will not have the right to appeal from the Special Master’s determination.

2 Nothing herein shall be construed to abridge or modify Section 10 of this Agreement, under which the Defendants have agreed to pay up to a stated maximum for Class Counsel’s Attorneys’ Fees and Expenses.

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ii. An appeal to the District Court Judge will be based on the same claim form reviewed by the Special Master. No other evidence or information will be considered.
iii. An appeal to the District Court Judge will be decided based on the same principles set forth in Section (c) above.
iv. The District Court Judge’s decision on an appeal will be final and nonappealable.
12. L aw E nforcement T raining and E ducation
12.1 A portion of the Settlement Fund will be used to fund the Law Enforcement
Training and Education component of the Settlement. The goal of the Law Enforcement
Training and Education component is to accomplish and revitalize statewide educational
programs to train and educate police officers.
12.2 The topics to be addressed in the Law Enforcement Training and Education
component are as follows::
Basic Civil Rights Community Based Policing Constitutional Use of Drug-Courier Profiles by Law Enforcement Agencies Courtroom Testimony and Procedure Forfeitures Investigative Report Writing Pretextual Stops Property Handling Procedures Racial and Ethnic Sensitivity Search and Seizures
Additional topics may be addressed if agreed to by Defendants' and Plaintiffs'
representatives.

12.3 Class Counsel will appoint one or more individuals with expertise in law enforcement as Law Enforcement Training and Education Representative(s). These Law Enforcement Training and Education Representatives will participate with individuals designated by Counsel for Defendants (which designees may include one or more Defendants and/or other

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representatives) in the development and implementation of the curriculum and report back to
Plaintiffs and the Court. Plaintiffs’ representative(s) and Defendants and/or their
representative(s) will jointly determine by agreement the curriculum that will be utilized and
how it will be implemented. 12.4 The law enforcement training will utilize the resources of P.O.S.T. in the
administration, formulation, operation and reporting of courses. All training must be submitted
to and approved by P.O.S.T. for continuing education credit. Representative(s) of Plaintiffs and
Defendants (and/or Defendants’ representative(s)) will mutually select one or more entities to
assist in the development, implementation and conduct of the training courses. In the event there
is an impasse between the representatives for Plaintiffs and Defendants with respect to any issue
associated with law enforcement training, such matter shall be submitted to the Special Master. 12.5 There will be three objective measurements to verify the effectiveness of the
training:
(a) Verification of officers/supervisors participating in the training; (b) Verification that the training is directed toward police officers/supervisors and
attended by police officers/supervisors; (c) Testing, to be administered toward the conclusion of the training, to confirm that
the officers attending have understood the major points covered. The testing will be developed as part of the development of the curriculum (see above.) Such testing will not be onerous, and expectations regarding an attendee’s test performance will be consistent with standards used in other law enforcement training courses. 13. Release, W aiver and Covenant Not to Sue 13.1 Upon the Effective Date of this Agreement, in consideration of this Settlement
and the benefits extended to the Settlement Class pursuant to this Agreement, all Settling Class
Members release and forever discharge the Released Parties from any and all Released Claims.

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13.2 Upon the Effective Date of this Agreement, the Released Parties are not, and in the future shall not be, subject to liability or expense of any kind to Settling Class Members with respect to any of the Released Claims. The provisions of this Agreement shall be the exclusive remedy of all Settling Class Members against the Released Parties. Upon the Effective Date, each Settling Class Member shall be forever barred from asserting any of the Released Claims against any of the Released Parties. Settling Class Members expressly agree that this release shall be, and may be raised as, a complete defense to and will preclude any action or proceeding encompassed within the terms of this release.
13.3 Upon the Effective Date of this Agreement, each Settling Class Member shall be deemed to have covenanted and agreed (a) that he or she will forever refrain from instituting, maintaining or proceeding against any Released Party on any Released Claim, including Released Claims known and not now known, suspected, or claimed, that he or she has or hereafter may have against the Released Parties; and (b) that he or she releases the Released Parties from each and every such Released Claim.
13.4 Settling Class Members acknowledge and agree that the Released Claims include claims that Settling Class Members do not know or suspect to exist in their favor at the time of the release of the Released Parties and which, if known by them, might have affected their decision to settle and release the Released Claims or take any other action, including, but not limited to, the decision not to object to this Agreement. Settling Class Members expressly waive any and all rights that they may have under any statute, regulation, administrative adjudication, or common law principle that would limit the effect of the Release provided in this Agreement to the claims actually known or suspected to exist at the time of this Agreement.

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14. F inal Judgment
14.1 If the Settlement is approved by the Court following the Fairness Hearing, the
Parties shall request that the Court enter a Final Judgment, substantially in the form attached
hereto as Exhibit 4:
(a) confirming certification of the Settlement Class pursuant to Federal Rule of Civil Procedure 23 and applicable law;
(b) finding that notice was provided to the Settlement Class in accordance with the Preliminary Approval Order and that the Notice Plan fully satisfies the requirements of Federal Rule of Civil Procedure 23 and due process;
(c) finding that notification to appropriate federal and state officials was given in accordance with the Class Action Fairness Act of 2005, 28 U.S.C. § 1715;
(d) approving the Settlement as fair, reasonable and adequate to Class Members in accordance with Federal Rule of Civil Procedure 23;
(e) directing implementation of the Settlement in accordance with its terms;
(f) dismissing with prejudice the Action;
(g) providing that all Settling Class Members conclusively compromise, settle, discharge, dismiss and release the Released Claims;
(h) providing that, as to any property in possession of Defendants in connection with an incident within the scope of the Released Claims, the rights of the Settling Class Members are extinguished (except to the extent such property is the subject of a timely claim under the Claims Resolution Process described in Section 11), such that the property can be declared surplus and disposed of according to state law;
(i) permanently enjoining Settling Class Members from initiating, asserting, prosecuting, or litigating against the Released Parties any actions involving the Released Claims;
(j) providing that neither this Agreement, approved or not approved, nor any exhibit, document or instrument delivered hereunder, nor any statement, transaction or proceeding in connection with the negotiation, execution or implementation of this Agreement, shall be admissible in evidence for any purpose in this or any other proceeding, except that this Agreement, and any order granting preliminary or final approval of this Agreement, will be admissible for the purpose of obtaining approval of, implementing, and/or enforcing this Agreement and as otherwise provided in paragraph 16.4;

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(k) reserving jurisdiction, without affecting the finality of the Final Judgment, over implementation, administration and enforcement of the Settlement, and other matters ancillary to the Settlement;
(l) finding that the Final Judgment is a final judgment pursuant to Federal Rule of Civil Procedure 54(a) or, alternatively, that there is no just reason for delay and the Final Judgment is a final judgment pursuant to Federal Rule of Civil Procedure 54(b).
14.2 Entry of a Final Judgment approving this Agreement is a condition precedent to the Parties’ respective rights and obligations under this Agreement. 15. Termination
15.1 Defendants shall have the right, in their sole discretion, to withdraw from this Agreement if the number of Class Members who elect to be excluded from the Settlement Class pursuant to Section 6.1 exceeds twenty (20). Defendants may exercise this right by (a) filing and serving, within ten (10) business days after the Opt-Out Deadline, a Preliminary Notice of Intent to Nullify Settlement and (b) filing and serving, within a time period to be prescribed by the Court, a Final Notice of Nullification of Settlement. After the filing of a Preliminary Notice of Intent to Nullify Settlement, the parties shall meet with the Court in an effort to explore options that may be available to persuade Defendants to withdraw the notice and complete the settlement, and no nullification will be effective until after (a) the Court meets with the parties and, thereafter, (b) Defendants confirm their decision to nullify by filing a Final Notice of Nullification of Settlement.
If the Defendants withdraw from the Agreement and terminate the Settlement as set forth above, neither Plaintiffs nor any Class Member nor Class Counsel shall be permitted to seek enforcement of the Settlement or any of its terms.
Even if the number of Class Members who elect to be excluded from the Settlement Class exceeds twenty (20), Defendants can decide to complete the Settlement with the Settling

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Class Members. Furthermore, if Defendants do not file and serve their Preliminary Notice of

Intent to Nullify Settlement within ten (10) business days after the Opt-Out Deadline, their right

to terminate under this section is waived.

15.2 This Agreement shall terminate and become null and void upon the occurrence of

any of the following events:

(a) The Court refuses to certify the Settlement Class;

(b) The Court denies preliminary approval of the Settlement;

(c) The Court denies approval of the Settlement following the Fairness Hearing;

(d) Certification of the Settlement Class and/or approval of the Settlement is reversed on appeal; or

(e) the Effective Date does not occur.

If this Agreement should terminate or become null and void for any reason, then:

i. This Agreement and all negotiations and proceedings and releases relating thereto shall be without prejudice as to the rights of any and all Parties to this Agreement, and Parties to this Agreement shall be restored to their respective positions as they existed prior to the execution of the Agreement; and

ii. Plaintiffs and Defendants shall jointly move that any order entered pursuant to this Agreement be vacated and void and all findings withdrawn.
16. No A dmissions

16.1 Neither this Agreement, nor any exhibit, document or instrument delivered

hereunder, is intended to be or shall be construed as or deemed to be evidence of an admission or

concession by Defendants or the Released Parties of any liability or wrongdoing, or of the truth

of any allegations asserted by Plaintiffs, Class Members, or any other person.

16.2 The Parties expressly acknowledge and agree that this Agreement, along with all

related drafts, motions, court papers, conversations, negotiations, mediations and

correspondence, including statements made in mediations or written submissions to the mediator,

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constitute an offer to compromise and a compromise within the meaning of Federal Rule of Evidence 408.
16.3 Neither this Agreement, approved or not approved, nor any exhibit, document or instrument delivered hereunder, nor any statement, transaction or proceeding in connection with the negotiation, execution or implementation of this Agreement, shall be admissible in evidence in this or any other proceeding for any purpose. (Provided, however, that nothing in the previous sentence shall be construed to apply to the published reports referenced in Sections 2.13(d) or 2.13(e), the admissibility of which shall be determined according to the rules of evidence that apply in any forum in which they are introduced.) Without limitation of the foregoing, nothing contained in this Agreement, approved or not approved, nor any exhibit, document or instrument delivered hereunder, nor any statement, transaction or proceeding in connection with the negotiation, execution or implementation of this Agreement, shall be given any form of res judicata, collateral estoppel or judicial estoppel effect against Defendants or the Released Parties in any administrative or judicial forum or proceeding.
16.4 Notwithstanding the foregoing, this Agreement, any order granting preliminary or final approval to this Agreement and any appellate decision affirming Final Judgment is admissible (a) for the purpose of obtaining approval of, implementing, and/or enforcing this Agreement or (b) for purposes of determining Class Counsel’s application for attorneys’ fees and costs or in connection with any appeal of an award of Class Counsel’s attorneys’ fees and costs in this Action.
16.5 This Agreement, any order granting preliminary or final approval of this Agreement, and any appellate decision affirming Final Judgment, may be pleaded by Defendants or the Released Parties as a full and complete defense (including any defense based upon release,

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res judicata, or injunction) to any action, suit or other proceeding that has been or may be

instituted, prosecuted or attempted with respect to any of the Released Claims; and this

Agreement, any order granting preliminary or final approval to this Agreement, and any

appellate decision affirming Final Judgment, or any other proceedings in connection therewith,

may be filed, offered or submitted by Defendants or the Released Parties or otherwise used in

support of such defense.

17. Deadlines and Notices 17.1 Whenever this Agreement requires notice or a document to be given to the parties

or counsel for the respective parties, it shall be sent to:

Joseph Flynn JARDINE, LOGAN & O’BRIEN Suite 100 8519 Eagle Point Blvd. Lake Elmo, MN 55042

Robert Hopper ZIMMERMAN REED, P.L.L.P. 651 Nicollet Mall, Suite 501 Minneapolis, MN 55402

For Defendants

For Plaintiffs

17.2 Whenever this Agreement requires notice or a document to be given to the

Administrator, it shall be sent to the address stated in the Settlement Notice.

17.3 Whenever this Agreement provides for a document or form to be sent to the

Administrator, Defendants or Class Counsel prior to a certain date or deadline, the document or

form will be deemed timely (a) if sent by First Class U.S. Mail and postmarked by the U.S.

Postal Service on or before the applicable deadline or (b) if sent by any other method and

received by the Administrator, Defendants or Class Counsel, whichever is applicable, on or

before the applicable deadline. If a postmark is not legible, the document shall be deemed to

have been postmarked three (3) business days before it is received by the person to whom it was

sent.

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18. G eneral Provisions

18.1 Class Representatives, Class Counsel, and Defendants shall cooperate, assist and

undertake their best efforts to complete any actions implementing the terms of this Agreement or

any order of the Court related to the implementation of this Agreement.

18.2 Plaintiffs, Class Counsel, and Defendants agree that the terms of this Agreement

were based not only on the consideration provided, but were also based on (a) vigorous arm’s-

length negotiations among counsel for the Parties; (b) the assessment of counsel for the Parties of

the strengths and weaknesses of the claims asserted in the Action and the Released Claims; and

(c) the expense and burden of ongoing litigation.

18.3 The undersigned attorneys for Plaintiffs represent and warrant that they have the

authority to enter into this Agreement on behalf of the proposed Class Representatives.

18.4 The undersigned counsel for Defendants represents and warrants that he has duly

authorized by all Defendants to execute this Agreement.

18.5 This Settlement Agreement is intended to and shall be governed solely and

exclusively by the laws of the United States. To the extent federal law does not provide the

requisite guidance, the agreement shall be governed by the laws of the State of Minnesota.

18.6 The terms and conditions set forth in this Settlement Agreement constitute the

complete and exclusive agreement between the Parties relating to the subject matter of this

Settlement Agreement, superseding all previous negotiations, representations, and

understandings, and may not be contradicted or supplemented by evidence of any prior or

contemporaneous agreement. The Parties further intend that this Settlement Agreement

constitutes the complete and exclusive statement of its terms as between the Parties and that no

extrinsic evidence whatsoever may be introduced in any judicial proceeding involving this

Settlement Agreement. Prior or contemporaneous representations not contained in this

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Settlement Agreement shall be of no force or effect. Any modification of the Settlement Agreement must be in writing signed by Class Counsel and Defendants.
18.7 The determination of the terms of, and the drafting of, this Settlement Agreement has been by mutual agreement after negotiation, with consideration by and participation of all Parties and their counsel. In the event of a dispute concerning the meaning of a term contained herein, no adverse inference or presumption shall be drawn based on any contention that a particular party supposedly drafted such term.
18.8 This Settlement Agreement shall be binding upon and inure to the benefit of the representative heirs, successors, and assigns of the Parties.
18.9 The waiver by one Party of any provision or breach of this Settlement Agreement shall not be deemed a waiver of any other provision or breach of this Settlement Agreement.
18.10 This Settlement Agreement shall become binding upon its execution by all of the undersigned. The Parties may execute this Settlement Agreement in counterparts, and execution of counterparts shall have the same force and effect as if all Parties had signed the same instrument.
IN WITNESS HEREOF, the undersigned, being duly authorized, have caused this Settlement Agreement to be executed on the dates shown below and agree that it shall take binding effect on the date it is executed by all of the undersigned.

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Exhibit 1

CASE 0:09-cv-01996-JNE-AJB Document 66-7 Filed 11/04/10 Page 42 of 94

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

ZELAIDO RIVERA GARCIA, MAURA GONZALES SALINAS, ADRIAN RAMIREZCUEVAS, CAMERINA CUEVAS LOPEZ,

Case No. 09-CV-01996 (JNE/AJB)

Plaintiffs,

v.

METRO GANG STRIKE FORCE, RON RYAN, former Metro Gang Strike Force Commander, DOE OFFICERS 1-34, individually and in their official capacities, OTHER UNKNOWN DOE OFFICERS, CITY OF WEST ST. PAUL, a municipal corporation, HENNEPIN COUNTY, a direct political subdivision of the State, DAKOTA COUNTY, a direct political subdivision of the State, RAMSEY COUNTY, a direct political subdivision of the State, CITY OF ST. PAUL, a municipal corporation, CITY OF MINNEAPOLIS, a municipal corporation, WASHINGTON COUNTY, a direct political subdivision of the State, CITY OF MAPLEWOOD, a municipal corporation, CITY OF LINO LAKES, a municipal corporation, CITY OF BROOKLYN PARK, a municipal corporation, CITY OF RICHFIELD, a municipal corporation, METROPOLITAN COUNCIL, METRO GANG STRIKE FORCE ADVISORY BOARD, MANILA (“BUD”) SHAVER, Chief of the West St. Paul Police Department, KEN SCHILLING, Inspector at the Hennepin County Sheriff’s Office, DAVE BELLOWS, Chief Deputy of the Dakota County Sheriff’s Office, BOB FLETCHER, Sheriff of the Ramsey County Sheriff’s Office, JOHN HARRINGTON, Chief of the St. Paul Police Department, ROB ALLEN, Deputy Chief of the Minneapolis Police Department, BILL HUTTON, Sheriff of the Washington County Sheriff’s Office, DAVE THOMALLA, Chief of the Maplewood Police Department, DAVE PECCHIA, Chief of the Lino Lakes Police Department, DAVE INDREHUS, Chief

ORDER PRELIMINARILY APPROVING SETTLEMENT AND APPROVING NOTICE TO CLASS MEMBERS

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of the Metro Transit Police Department, MICHAEL DAVIS, Chief of the Brooklyn Park Police Department, BARRY FRITZ, Captain of the Richfield Police Department,
Defendants. Plaintiffs Zelaido Rivera Garcia, Maura Gonzalez Salinas, Adrian Ramirez-Cuevas, and Camerina Cuevas Lopez (collectively “Plaintiffs” or “Class Representatives”), by and through their undersigned counsel, and Defendants, by and through their undersigned counsel, have made a joint motion for preliminary approval of the Settlement Agreement between the Settlement Class and Defendants. Upon the parties joint motion and supporting memorandums of law, the Settlement Agreement (attached hereto as Exhibit A), and all prior proceedings conducted in the above-captioned class action (the “Action”), including oral argument at a hearing held on __________, this Court hereby (a) conditionally certifies for settlement purposes only, pursuant to Rules 23(a) and 23(b)(3) of the Federal Rules of Civil Procedure, the Settlement Class1 defined below; (b) finds that the proposed settlement (the “Settlement”) (evidenced in the Settlement Agreement) appears on its face to be fair, reasonable and adequate and has been the product of serious and extensive arm’s-length negotiations between Plaintiffs and Defendants; (c) approves the form and manner of notice proposed by the parties; and (d) schedules a hearing, pursuant to Rule 23(e) of the Federal Rules of Civil Procedure, to determine, among other things, (i) whether a settlement class can be certified pursuant to Rules 23(a) and 23(b)(3) of the Federal Rules of Civil Procedure; (ii) whether the Settlement is fair, reasonable, and adequate and whether it should be approved pursuant to Rule 23(e) of the Federal Rules of Civil Procedure;

1 The Court notes that Defendants have conditionally agreed and consented to certification of the Settlement Class pursuant to Federal Rule of Civil Procedure 23 for settlement purposes only, and for the sole purpose of creating the Settlement Class. If the Settlement Agreement is for any reason not approved or the Effective Date does not occur, the Court notes that the Defendants have reserved their right to reassert all of their objections and defenses to certification of any class.

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(iii) whether the notice proposed by the parties is the best notice practicable under the
circumstances and clearly and concisely provides plain, easily understood language that satisfies
Rule 23(c)(2) of the Federal Rules of Civil Procedure; and (iv) whether Class Counsel’s
application for fees and expenses should be approved.
Upon consideration of the Settlement and hearing from the parties, it is hereby
ORDERED as follows:
1. The Court has subject matter jurisdiction over the Actions pursuant to 42
U.S.C. § 1981, § 1983 et seq., and personal jurisdiction over the parties before it.
2. The “Definitions” section of the Settlement Agreement is incorporated herein by
reference. All capitalized terms used in this Order have the meaning set forth in the Settlement
Agreement unless otherwise expressly indicated.
3. For settlement purposes only, and contingent upon the Settlement being finally
approved, the Court hereby conditionally certifies, pursuant to Rules 23(a) and 23(b) of the
Federal Rules of Civil Procedure, that this Action is maintainable as a class action for settlement
purposes only on behalf of a class (the “Settlement Class”) consisting of all persons who:
(a) have been stopped, questioned, arrested, charged, frisked, detained or searched (including but not limited to persons who have had property searched or seized), or whose dwelling was searched;
(b) by a peace officer or peace officers serving on or assisting the MGSF or by a peace officer or peace officers serving on or assisting the Minnesota Gang Strike Force;
(c) in an incident where property was taken from one or more of the individuals stopped, questioned, arrested, detained or searched (or during a search and seizure of property belonging to one or more of such individuals); and
(d) the property was taken
i. without a receipt or inventory itemization, or

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ii. without notification to the property owner of his or her right to contest the forfeiture.
4. The Court appoints Zelaido Rivera Garcia, Maura Gonzales Salinas, Adrian Ramirez-Cuevas, and Camerina Cuevas Lopez to serve as Class Representatives.
5. Plaintiffs’ Counsel Robert R. Hopper of Zimmerman Reed, P.L.L.P, Phillip F. Fishman of Fishman, Binsfeld & Bahmeier, P.A. and Alex Alvarez of The Alvarez Law Firm are appointed as Class Counsel for the Settlement Class.
6. Subject to final approval of the Settlement and the entry of final judgment, the Court finds that the Settlement as set forth in the Settlement Agreement appears on its face to be fair, reasonable, and adequate to have been the product of serious and extensive arm’s-length negotiations between Class Counsel and Defendants. The Court finds that the Settlement Agreement was reached in good faith, and provides meaningful relief to the Class and thus warrants providing notice of such Settlement to prospective Settlement Members. Accordingly, pursuant to Rule 23(e) of the Federal Rules of Civil Procedure, the Court preliminarily approves the Settlement upon the terms and conditions set forth in the Settlement Agreement (attached as Exhibit A).
7. Subject to final approval of the Settlement and the entry of final judgment, and for settlement purposes only, the Court finds that the prerequisites of Rule 23(a) and (b)(3) are met and hereby certifies the foregoing defined Settlement Class pursuant to Rule 23(b)(3). If such final approval of the Settlement is not granted, or if final judgment as contemplated herein is not entered, this Order shall be vacated and the parties shall be restored without prejudice to their respective litigation positions prior to the date of this Order of Preliminary Approval.
8. The Court finds that the prerequisites for class action treatment under Rules 23(a) and (b)(3) of the Federal Rules of Civil Procedure have been satisfied by the Settlement Class, in

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that: (1) The number of class members comprising the Settlement Class is so numerous that joinder of all members is impracticable. Settlement Class includes, but is not limited to, the persons whose property was taken in connection with one of the 202 incidents referenced in Finding 8 of the Report of the Office of the Legislative Auditor dated May 20, 2009. (2) There are questions of law or fact common to the Settlement Class, including (a) whether Defendants were required to provide receipts of seized property, (b) whether Defendants were required to provide notices of the right to contest the forfeiture of property, (c) whether Defendants repeatedly failed to provide receipts of seized property, (d) whether Defendants repeatedly failed to provide notice of the right to contest the forfeitures as required by Minnesota law (Minn. Stat. § 609.5314), (e) whether Defendants acted under color of law when improperly seizing property, (f) whether Defendants failed to create records of seized property and incidents leading to the seizure of property, and (g) whether Defendants failed to properly maintain records of seized property and incidents leading to the seizure of property. (3) The claims or defenses of the proposed Class Representatives are typical of the claims or defenses of the other members of the Settlement Class. (4) The proposed Class Representatives and Class Counsel will fairly and adequately protect the interests of the Settlement Class. (5) The questions of law and fact common to the Settlement Class members predominate over any questions affecting only individual Settlement Class members. (6) Class action treatment is superior to other available methods for the fair and efficient resolution of this controversy. The Court also notes that, because this Action is being settled rather than litigated, the Court need not consider manageability issues that might be presented by the trial of a class action involving the issues in this case. See Amchem Prods., Inc. v. Windsor, 521 U.S. 591, 117 S. Ct. 2231, 138 L. Ed. 2d 689 (1997).

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9. In making these findings, the Court has been provided copies of (1) the Settlement Agreement, (2) the Report on the Metro Gang Strike Force issued by the Office of the Legislative Auditor for the State of Minnesota on or about May 20, 2009 and (3) the Report of the Metro Gang Strike Force Review Panel issued on or about August 20, 2009.
10. The Court approves the form of the Notice of Proposed Class Action Settlement and Release of Claims specified in the Settlement Agreement and attached as Exhibit 2 to the Settlement Agreement (hereinafter “Notice”). The Court finds that the manner and content of the Notice (a) is the best notice that is practicable to members of the Settlement Class; (b) is reasonably calculated, under the circumstances, to apprise members of the Settlement Class of the pendency of the Action, certification of the Settlement Class, the proposed Settlement, the rights of Class Members to object to the Settlement and the application of Plaintiffs’ counsel for payment of their attorneys’ fees and reimbursement of their litigation expenses, and to request exclusion from the Settlement Class; (c) is reasonable and satisfies the requirements of due process by providing due, adequate, and sufficient notice to all persons and entities entitled to receive notice; (d) clearly and concisely states in plain, easily understood language: (i) the nature of the action, (ii) the definition of the class certified, (iii) the class claims, issues or defenses, (iv) that a class member may enter an appearance through an attorney if the member so desires, (v) that the court will exclude from the class any member who requests exclusion, (vi) the time and manner for requesting exclusion, and (vii) the binding effect of a class judgment on members under Rule 23(c)(3) of the Federal Rules of Civil Procedure; and (e) meets all applicable requirements of law including, but not limited to, Rule 23(c) and the Due Process Clause of the Fifth Amendment to the United States Constitution.

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11. The Court Orders that Notice to members of the Settlement Class shall be disseminated by U.S. Mail and publication, in accordance with the dates and periods set forth in Sections 5.5 through 5.6 of the Settlement Agreement, in a form and content substantially similar to Exhibit 2 and Exhibit 3 to the Settlement Agreement, and in substantially the manner specified in the Settlement Agreement. This Notice will provide Class Members with the opportunity to request exclusion from participating in the settlement. Such opt out rights may be exercised only individually by a Class Member, and not by any other person in a representative capacity unless otherwise authorized by law.
12. The Court approves the administration of the proposed Settlement in the manner set forth in the Settlement Agreement.
13. The Court appoints __________________ as Administrator, as defined in the Settlement Agreement.
14. The Court orders that Class Counsel, through the Court-appointed Administrator shall establish and maintain an Internet website under the Uniform Resource Locator (URL) available at www.mgsfsettlement.com, at which the Notice shall be posted to provide notice to the Settlement Class of the proposed Settlement. This website shall remain active through the Effective Date of the Settlement, as defined in the Settlement Agreement.
15. The Court directs that any Class Member who wishes to opt out of the settlement must send a written request for exclusion in the manner and to the address provided in the Notice approved above. Any Class Member who fails to timely and/or properly opt out of the settlement shall be deemed participating and shall be bound by all orders/or judgments of this Court, which will have preclusive effect in all pending or future lawsuits or other proceedings against the Defendants.

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16. Any Class Member who has not opted out of settlement may, solely at the expense of such person, object to approval of the proposed settlement and may appear at the Fairness Hearing in person or through counsel to show cause why the proposed settlement should not be approved as fair, reasonable, and adequate. However, no person (other than named parties) may be heard at the Fairness Hearing, or file papers or briefs in connection therewith, unless on or before ______________, such person has filed with the Court and served on Plaintiffs’ Class Counsel and Defendants’ Counsel a timely written objection and notice of intent to appear, in accordance with the procedures specified in the Notice. Any member of the Settlement Class who does not make his objection to the settlement in the manner provided herein shall be deemed to have waived any such objection.
17. No person shall be entitled in any way to contest the approval of the terms and conditions of the Settlement Agreement or the Final Order and Judgment to be entered thereon except as through the procedures set for in the Settlement Agreement and Notice. Any Settlement Class Member who does not submit a timely, written objection to the settlement or opt out request from the settlement in compliance with all the procedures set forth in the Settlement Agreement and Notice will be deemed to have waived all such objections and will, therefore, be bound by all proceedings, orders, and judgments in this action, which will be preclusive in all pending or future lawsuits or other proceedings.
18. Defendants’ Counsel, Plaintiffs’ Counsel, and any other counsel for Plaintiffs or the Settlement Class, shall promptly furnish to all other counsel of record copies of any objection or written request for exclusion that comes into such counsel’s possession.
19. A Fairness Hearing shall be held by this Court on ______________ at ___ a/p.m., before the Honorable Joan N. Ericksen, to consider and finally determine:

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(a) Whether the Settlement Class shall be certified pursuant to Rules 23(a) and 23(b)(3) of the Federal Rules of Civil Procedure;
(b) Whether the Settlement Agreement should be finally approved by the Court as fair, reasonable, and adequate;
(c) Whether the notice proposed by the parties is the best notice practicable under the circumstances and clearly and concisely provides plain, easily understood language that satisfies Rule 23(c)(2) of the Federal Rules of Civil Procedure; and
(d) Whether Class Counsel’s application for fees and expenses is appropriate. The Fairness Hearing described in this paragraph may be postponed, adjourned, or continued by order of the Court without further notice. 20. If the Settlement Agreement is finally approved, the Court shall enter a Settlement Order and Final Judgment approving the Settlement Agreement incorporating it as the judgment of the Court, which judgment shall be binding upon all members of the Settlement Class. 21. In the event that the proposed settlement set forth in the Settlement Agreement is not approved by the Court, or entry of a Settlement Order and Final Judgment as provided in the Settlement Agreement does not occur for any reason, then the Agreement, all drafts, negotiations, discussions, and documentation relating thereto, and all orders entered by the Court in connection therewith, shall become null and void, and shall not be used or referred to for any purpose in this Action or in any other proceeding. In such event, the Settlement Agreement and all negotiations and proceedings relating thereto shall be withdrawn without prejudice to the rights of any of the parties thereto, who shall be restored to their respective positions as of the date of the execution of the Settlement Agreement. 22. Defendants have denied liability in this matter, and this Settlement does not constitute an admission of liability or wrongdoing. Neither this Order Preliminarily Approving Settlement, the Settlement Agreement, the fact of settlement, the settlement proceedings,

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settlement negotiations, nor any related document, shall be used as an admission of any act or omission by Defendants or be offered or received in evidence as an admission, concession, presumption, or inference of any wrongdoing by Defendants in any proceeding other than such proceedings as may be necessary to consummate or enforce the Settlement Agreement.
23. From this date until the Court’s entry of the Settlement Order and Final Judgment permanently terminating this litigation, all proceedings in this matter other than those related to effectuating this Settlement are stayed, and neither the Plaintiffs, nor any Settlement Class Member, either directly, representatively, or in any other capacity, shall prosecute any action or proceeding in any court, tribunal or other forum asserting any of the Released Claims against the Released Parties. The Court finds that issuance of this stay is necessary and appropriate in aid of the Court’s jurisdiction over the action and the protect and effectuate the Court’s review of the Settlement.
24. The Court retains exclusive jurisdiction over the Action to consider all further matters arising out of or connected with the Settlement.
IT IS SO ORDERED.

This ___ day of ___________, 2010.

___________________________ Judge Joan N. Ericksen United States District Judge

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EXHIBIT A

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Exhibit 2

CASE 0:09-cv-01996-JNE-AJB Document 66-7 Filed 11/04/10 Page 54 of 94 IMPORTANT LEGAL NOTICE
UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA
NOTICE OF PROPOSED CLASS ACTION SETTLEMENT AND RELEASE OF CLAIMS
for Garcia, et al v. Metro Gang Strike Force, et al Case No. 09-CV-01996 (JNE/AJB)
If you had an encounter with the Metro Gang Strike Force or the Minnesota Gang Strike Force in an incident that involved the seizure of property, you may be a member of the class in a class action lawsuit that is being settled.
If You Are a Member of the Class, Your Legal Rights Will Be Affected Whether You Act or Do Not Act.
A U.S. federal court authorized this Notice. It is not a solicitation from a lawyer. You are not being sued. Please read this entire Notice carefully.
This Notice concerns the proposed settlement of a class action lawsuit (called Garcia v. Metro Gang Strike Force) in which Plaintiffs, on behalf of themselves and others similarly situated, alleged misconduct on the part of the Metro Gang Strike Force and those responsible for training and supervising them.
The following is only a summary of the Settlement, which is contained in the Settlement Agreement and is available at www.mgsfsettlement.com. Nothing in this Notice alters the terms of the Agreement.
• Plaintiffs have alleged that officers assigned to the Metro Gang Strike Force seized property without complying with the procedures required under law, and have also asserted claims for violations of the U.S. Constitution and Civil Rights Act, negligence, assault, false imprisonment, conversion and conspiracy to convert, and liability based on respondeat superior.
• Defendants do not admit any wrongdoing or liability. The proposed settlement is a compromise of disputed claims and does not mean that Defendants are liable for the claims made in the lawsuit. The Court has not ruled on the merits of the Plaintiffs’ claims or on the defenses asserted by the Defendants.
• The Settlement will provide Settlement Class Members with a streamlined process in which Class Members can submit any claim that they might have against the Defendants merely by completing a claim form with the assistance of Class Counsel and providing a sworn statement. The claim will then be decided by a Special Master. Under this procedure, a Settlement Class Member will not need to testify or hire his or her own attorney.
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• In accordance with the Settlement a portion of the total settlement amount will be used to pay for Law Enforcement Training and Education, which will provide law enforcement personnel with training addressed to the types of conduct alleged in the Complaint.

• On ____________, 2010, the court certified a settlement class in this lawsuit and preliminarily approved a proposed settlement of the class action with the Defendants.

• This Notice and the lawsuit described in this Notice may affect your rights. You may be a member of the Settlement Class described in this Notice and you may be entitled to share in the benefits of the proposed class action settlement described in this Notice.

Summary of Your Rights and Choices:

If You Are a Member of the Settlement Class, Your Legal Rights Are Affected Even if You Do Not Act. Read This Notice Carefully.

You May:

Deadline:

Stay in the Settlement Class

You do not have to do anything to remain in N/A the settlement class.

Stay in the Settlement Class and Participate in the Settlement

You are not eligible to receive any payment under this Settlement unless you remain in the Settlement Class and submit a timely claim under the Claims Resolution Process (as described more fully in the Settlement Agreement, available at www.mgsfsettlement.com ).

Submitted by _______

Exclude Yourself from the Settlement Class

Opt out of the settlement class.
You do not have to remain a member of the settlement class or participate in the Settlement. You can write and ask to be excluded from the settlement class by the deadline noted. If you exclude yourself, you will not be able to participate in the Settlement.

Postmarked by _______ (if sent by U.S. Mail)
Received by _______(if not sent by U.S. Mail)

If you do not exclude yourself, you will be bound by the court’s decisions and you will not be able to sue the Defendants for claims arising out of encounters between members of the class and law enforcement officers assigned to the Metro Gang Strike Force or the Minnesota Gang Strike Force during the Class Period.

Object to the Proposed Settlement

You may object or comment on the Settlement. Received by _______ If you do not exclude yourself, you can

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participate and speak in the lawsuit on your own or through your own lawyer. If you would like to object to the Settlement, you must do so in writing by the deadline noted. You can also ask to appear at the hearing where the court will consider the fairness of the Settlement. To appear at the hearing, you must write the settlement administrator and provide copies to the lawyers listed below by the deadline noted. If you engage your own counsel, you are responsible for those costs.
These rights and options – and the deadlines for each – are explained in this Notice.
BASIC INFORMATION
1. Why Did I Receive This Notice?
You received this Notice because you may be eligible for benefits that will be provided as part of the proposed settlement of a class action lawsuit brought in the United States District Court for the District of Minnesota (the “Court”) against persons and entities named as defendants in the lawsuit (the “Defendants”).
If you are a member of the proposed Class, the proposed settlement will affect your rights. You have choices to make before the Court decides whether or not to approve the Settlement.
This Notice explains:
• What the lawsuit and proposed settlement are about, • Who is affected by the proposed settlement, • What your legal rights and choices are, • What the Settlement involves, • What the benefits are and who is eligible to get them, • How to participate in the Settlement, • How to make a claim, • Who will determine whether a claim is valid, and • What information the Special Master will rely on to decide a claim.
2. Who Is in the Settlement Class?
The Court has certified a settlement class of the following persons who:
(a) have been stopped, questioned, arrested, charged, frisked, detained or searched (including but not limited to persons who have had property searched or seized), or whose dwelling was searched;

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(b) by a peace officer or peace officers serving on or assisting the Metro Gang Strike Force or by a peace officer or peace officers serving on or assisting the Minnesota Gang Strike Force;
(c) in an incident where property was taken from one or more of the individuals stopped, questioned, arrested, detained or searched (or during a search and seizure of property belonging to one or more of such individuals); and
(d) the property was taken i. without a receipt or inventory itemization, or
ii. without notification to the property owner of his or her right to contest the forfeiture.
Excluded from the Class are persons who commenced and settled individual lawsuits against one or more of the Defendants regarding claims encompassed in the definition of Released Claims.
If you are a Settlement Class Member, you need to decide whether to decline to participate in the Settlement.
3. Who are the Defendants in this Action?
Plaintiffs named the following individuals as Defendants in their Complaint and Amended Complaint:
• Metro Gang Strike Force, • Ron Ryan, former Metro Gang Strike Force Commander, • Doe Officers 1-34, individually and in their official capacities, • Other Unknown Doe Officers, • City of West St. Paul, a municipal corporation, • Hennepin County, a direct political subdivision of the State, • Dakota County, a direct political subdivision of the State, • Ramsey County, a direct political subdivision of the State, • City of St. Paul, a municipal corporation, • City of Minneapolis, a municipal corporation, • Washington County, a direct political subdivision of the State, • City of Maplewood, a municipal corporation, • City of Lino Lakes, a municipal corporation, • City of Brooklyn Park, a municipal corporation, • City of Richfield, a municipal corporation, • Metropolitan Council, • Metro Gang Strike Force Advisory Board, • Manila (“Bud”) Shaver, Chief of the West St. Paul Police Department, • Ken Schilling, Inspector at the Hennepin County Sheriff’s Office,

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• Dave Bellows, Chief Deputy of the Dakota County Sheriff’s Office, • Bob Fletcher, Sheriff of the Ramsey County Sheriff’s Office, • John Harrington, Chief of the St. Paul Police Department, • Rob Allen, Deputy Chief of the Minneapolis Police Department, • Bill Hutton, Sheriff of the Washington County Sheriff’s Office, • Dave Thomalla, Chief of the Maplewood Police Department, • Dave Pecchia, Chief of the Lino Lakes Police Department, • Dave Indrehus, Chief of the Metro Transit Police Department, • Michael Davis, Chief of the Brooklyn Park Police Department, and • Barry Fritz, Captain of the Richfield Police Department.
4. What Is This Lawsuit About?
The entire Amended Complaint, explaining the claims in this lawsuit, is available at www.mgsfsettlement.com. This Notice contains only a summary of the claims.
This lawsuit relates to claims arising out of encounters between members of the Class and law enforcement officers assigned to the Metro Gang Strike Force and the Minnesota Gang Strike Force between November 10, 1997 and [DATE OF PRELIMINARY APPROVAL] (the “Class Period”). The Plaintiffs in this lawsuit, Zelaido Rivera Garcia, Maura Gonzalez Salinas, Adrian Ramirez-Cuevas, Camerina Cuevas Lopez, Kathleen Yankovic and John Yankovic, on behalf of themselves and others similarly situated (the “Plaintiffs”), seek to recover damages and to impose injunctive relief against Defendants under the U.S. Constitution and the Civil Rights Act, 42 U.S.C. § 1981, § 1983 et seq. and § 1985 (“CRA”) (including but not limited to Monell claims). Plaintiffs also seek to recover monetary damages (including punitive damages, where available) for alleged negligence in the supervision and training of law enforcement employees, liability based on respondeat superior, civil tort conversion and conspiracy to convert, civil tort of assault, civil tort of false imprisonment, and violations of the Minnesota State Constitution. The Defendants have denied that they have engaged in any wrongdoing or that they are liable to the plaintiffs.
In plain terms, the representative Plaintiffs in this case have filed claims related to interactions they had with members of the Metro Gang Strike Force and/or the Minnesota Gang Strike Force between November 10, 1997 and [DATE OF PRELIMINARY APPROVAL] in which they feel their civil rights were violated. Specifically, Plaintiffs have alleged that officers assigned to the Metro Gang Strike Force and/or the Minnesota Gang Strike Force took Plaintiffs’ property without following the procedures required under law. Some Plaintiffs have also made claims for violations of the U.S. Constitution and Civil Rights Act, negligence, assault, false imprisonment, conversion and conspiracy to convert, and liability based on respondeat superior. Defendants do not admit any wrongdoing or liability.
The Court in charge of this lawsuit is the United States District Court for the District of Minnesota. The name of the lawsuit is Garcia v. Metro Gang Strike Force, Case No. 09-CV01996 (JNE/AJB). The judge is the Honorable Joan N. Ericksen.

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5. Why Is This a Class Action?
In a class action lawsuit, one or more people called “class representatives” sue on behalf of people who have similar claims. The people together are a “class” or “class members.” The Court has preliminarily determined that a settlement class provides for the fair and efficient resolution of this litigation.
6. Why Is There a Settlement?
The proposed settlement provides a method to resolve the claims made in the lawsuit that takes into consideration the best interests of all involved parties. The proposed settlement was the result of extensive, arms-length negotiations between Class Counsel and Defendants, and is based upon a thorough examination of the facts and law gained over the course of this litigation.
Defendants do not admit any wrongdoing or liability. The proposed settlement is a compromise of disputed claims and does not mean that Defendants are liable for the claims made in the lawsuit. If the Settlement is approved by the Court, Settlement Class Members will have the opportunity to participate in the Settlement and submit a claim under the Claim Resolution Process. Unless a Class Member chooses to opt out of the Settlement, they will not be able to sue Defendants based upon (a) encounters between members of the Class and law enforcement officers assigned to the Metro Gang Strike Force or Minnesota Gang Strike Force during the Class Period, (b) subjects referenced in Finding 8 of the report of the Office of the Legislative Auditor dated May 20, 2009, or (c) subjects referenced in the Report of the Metro Gang Strike Force Review Panel dated August 20, 2009. You can only sue Defendants based upon such encounters or subjects if you exclude yourself (opt out) from the Settlement Class.
BENEFITS OF THE SETTLEMENT HOW TO PARTICIPATE IN THE SETTLEMENT
7. What Are the Benefits of the Settlement?
The Settlement will provide two essential benefits to Settlement Class Members: a Claims Resolution Process, and Law Enforcement Training and Education. Each are described more fully in the Settlement Agreement, available at www.mgsfsettlement.com .
Defendants have agreed to pay $3.0 million, excluding amounts paid for Attorneys Fees and Expenses by the Defendants. This amount will pay for awards of compensation made by a Special Master as part of a streamlined Claims Resolution Process (as well as notice and administrative costs, any special master fees, and fees paid to persons who will be representing Class Counsel in developing the Law Enforcement Training and Education component of the settlement, and possibly, an incremental award of Attorneys Fees if requested by Class Counsel and approved by the Court.) Members can submit any claim that they might have against the Defendants merely by completing a claim form and providing a sworn statement about the incident to the Special Master. Class Members do not need to hire their own attorney, as Class Counsel will represent Class Members. Additional benefits of the Class Resolution Process include that Class Members will not need to testify at a live hearing, or be subject to cross-

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examination. If you are a member of the Class and want to be eligible to receive compensation under the Class Resolution Process, all you are required to do is initiate a claim by submitting a claim form and sworn statement as fully described in the Settlement Agreement.
The portion of the $3.0 million that is not spent on any of the aforementioned categories will be spent on Law Enforcement Training and Education, which will provide law enforcement personnel with training addressed to the types of conduct alleged in the Complaint.
8. How Do I Participate in the Settlement?
Settlement Class Members do not have to do anything to participate in the Settlement. If you do not respond, your interests will be represented without cost to you by Class Counsel, and you will be bound by all orders and judgments entered by the Court.
If you want to receive monetary benefits that may be available under the Settlement, you may seek compensation from the Settlement Fund based on a claim that one or more of the Defendants is liable to the Class Member under one or more of the causes of action identified in the Complaint. The term “Claims Resolution Process” (as described more fully in the Agreement, available at www.mgsfsettlement.com) refers to the procedures for submitting such claims; and the method for determining whether the claimant is entitled to compensation; and, if so, the amount of money the claimant is entitled to receive as compensation. A Class Member is not eligible to receive any payment under this Settlement unless he or she submits a timely claim under the Claims Resolution Process.
9. How Do I Make a Claim?
The Claims Resolution Process has been streamlined for Class Members’ ease and convenience. Class Members who would like to submit a claim for consideration must first complete and sign a claim form describing their encounter with a member of the Metro Gang Strike Force and/or the Minnesota Gang Strike Force. This form will be reviewed by Class Counsel who will assist the Class Member with identifying which legal claims they would like to submit for final review. The completed claim form will then be submitted to the Special Master for consideration and compensation determination. The Defendants have no part in the decision of allocation of settlement funds by the Special Master.
The Court approved claim form is available at www.mgsfsettlement.com. You may also obtain a claim form by contacting Class Counsel at 1-866-211-0079 or by email at MGSFSettlement@zimmreed.com. Class Counsel will assist you in completing pages 1 and 2 of the claim form. Page 3 of the claim form must be filled out by the Class Member and describe, in as much detail as possible, the Class Member’s encounter with a member(s) of the Metro Gang Strike Force and/or the Minnesota Gang Strike Force. Class Members will be asked to provide, if possible, receipts and/or pictures of the property that is claimed to have been wrongfully taken by members of the Metro Gang Strike Force and/or the Minnesota Gang Strike Force.

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The Claim Resolution Process is not an indefinite process. Class Members wanting to submit a claim for consideration by the Special Master must do so within fourteen (14) days after the Effective Date or by the Final Deadline to be published on the website at [website address]. Except for publication on the website, no further notice of the Final Deadline will be provided. A Class Member is not eligible to receive any payment under this Settlement unless he or she submits a timely claim form under the Claims Resolution Process. PLEASE NOTE: if you do not do anything you will NOT receive any monetary compensation but you will be waiving your rights to pursue any further claims against the Defendants.
10. Who Will Determine Whether My Claim Is Valid and What Compensation I Am Eligible to Receive?
If you make a claim, it will be up to the Special Master to decide whether your claim is valid, and, if your claim is valid, the amount of compensatory damages you should receive. The Special Master will be ______. If you are not satisfied with the result, you will have the right to appeal the decision to the United States District Court Judge Joan Ericksen.
11. What Information Will the Special Master Rely on to Decide My Claim?
The Special Master will have your sworn statement of the facts and any documentary evidence you choose to submit. The Defendants will also have an opportunity to submit sworn statements, documentary evidence and certain other written materials. If the Defendants make a submission, you will have the opportunity to review their statement and submit an additional sworn statement or additional documentary evidence.
12. What Relief Will I Be Eligible to Receive If I Make a Claim?
The Special Master can award compensatory damages, a return of property, or both. As a claimant, you will not be able to receive any punitive damages awards.
13. If I Make A Claim, Will I Definitely Receive an Award – Either Money or Property?
If you make a claim, it will be up to the Special Master to decide whether your claim is valid. There is no guarantee that you will receive an award.
IF YOU DO NOTHING – EFFECT OF REMAINING IN THE SETTLEMENT CLASS
14. What Happens If I Do Nothing and Stay in the Settlement Class? What Claims am I Giving Up?
If you do not opt out of the Settlement, then regardless of whether you submit a claim or obtain benefits under this Settlement, you will be releasing claims against Defendants and related persons (defined as “Released Persons” in the Agreement) as described more fully in the Agreement, available at www.mgsfsettlement.com).

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“Released Persons” means the following:
Defendants, Ron Ryan, personally, individually and in his official capacity and in his capacity as Commander of the Metro Gang Strike Force and Minnesota Gang Strike Force; the Metro Gang Strike Force Advisory Board; Manila Shaver, Chief of the West St. Paul Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; Ken Schilling, Inspector, Hennepin County Sheriff’s Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; David Bellows, Chief Deputy of the Dakota County Sheriff’s Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; Robert Fletcher, Sheriff of Ramsey County, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; John Harrington, Chief of Police with the City of St. Paul, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; Robert Allen, Deputy Chief, Minneapolis Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; William Hutton, Sheriff of Washington County, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; David Thomalla, Chief of the Maplewood Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; David Pecchia, Chief of the Lino Lakes Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; David Indrehus, Chief of the Metro Transit Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; Michael Davis, Chief of Brooklyn Park Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; Barry Fritz, Captain of the Richfield Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; Tom Lauth, Chief of the North St. Paul Police Department, personally, individually and in his official capacity and in his capacity as a member of the Metro Gang Strike Force Advisory Board; Cari Gerlicher, Director of the Office of Special Investigations, personally, individually and in her official capacity; all persons or entities advising or providing legal representation to the Metro Gang Strike Force or Minnesota Gang Strike Force, its Advisory Boards, member officers, employees and all other persons associated with the Metro Gang Strike Force or Minnesota Gang Strike Force, individually and in their official capacity; the League of Minnesota Cities Insurance Trust; the Metro Gang Strike Force; the Minnesota Gang Strike Force; all employees, advisors, officers, supervisors, commanders and other persons

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assigned or working for or associated with the Metro Gang Strike Force or the Minnesota Gang Strike Force, personally and in their official and individual capacities; all members of the Metro Gang Strike Force and/or Minnesota Gang Strike Force Boards, Governing Boards and Advisory Boards and municipal members of the Metro Gang Strike Force and/or Minnesota Gang Strike Force including, but not limited to, the City of West St. Paul, Hennepin County, Dakota County, Ramsey County, City of St. Paul, Washington County, the City of Maplewood, the City of Lino Lakes, the City of Brooklyn Park, the City of Richfield, the City of North St. Paul, the Metropolitan Council, and the City of Minneapolis; the State of Minnesota, and its past and present employees, departments, including but not limited to the Minnesota Department of Corrections and the Minnesota Department of Public Safety, agencies, political subdivisions, divisions, joint ventures, and attorneys; Criminal Gang Council and the Gang and Drug Oversight Council and its membership, participating officers and coordinators; task forces, joint powers, entities and members thereof; and for each above entity, department, Board, municipality or organization, their past, present and future officers, directors, officials, attorneys, employees, principals, police chief, police officers, agents, Board members, representatives, insurers, administrators, executors, advisors, successors and assigns and all other persons or entities.
By way of summary only, you will be releasing all claims (defined as “Released Claims” and described more fully in the Settlement Agreement, available at www.mgsfsettlement.com) that fall into one or more of any of the following categories:
(a) claims that were or could have been asserted in any complaint in the Action,
(b) claims related to the Metro Gang Strike Force or other persons acting on behalf of the Metro Gang Strike Force,
(c) claims related to the Minnesota Gang Strike Force or other persons acting on behalf of the Minnesota Gang Strike Force,
(d) claims related to any of the subjects referenced in the report on the Metro Gang Strike Force issued by the Office of the Legislative Auditor for the State of Minnesota dated May 20, 2009,
(e) claims related to any of the subjects referenced in the Report of the Metro Gang Strike Force Review Panel dated August 20, 2009, or
(f) claims that assert fraud in the inducement of this Settlement.
EXCLUDING YOURSELF FROM THE SETTLEMENT CLASS

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15. What MUST I Do If I Do NOT Want to be in the Settlement Class?

If you do not want to participate in the Settlement, you must send written notice of your individual intent to opt out to the address set forth below so that it is received by _____. If you send such an opt out notice, you will not be entitled to receive any monetary benefit that may be available under the proposed settlement. To opt out, you must send a written notice stating, “I request to be excluded from the Settlement. I understand that this exclusion means that I will not be entitled to receive any benefit that may be available under the proposed settlement.” Your written notice also must contain your name, current address, and must be signed and dated by you (or a parent or guardian, if a minor). Failure to comply with any of these requirements may result in your written notice being declared invalid. SEND YOUR WRITTEN NOTICE TO THE FOLLOWING ADDRESS:

Garcia v. Metro Gang Strike Force Settlement Claims Administrator Attn: 123 Claims Administrator Road Minneapolis, MN 55402

Your written notice to opt out must be postmarked no later than __________ . If not sent by U.S. Mail, your written notice to opt out must be received by ____. Your written notice to opt out must be filed in an individual capacity, not by any representative (unless you are a minor).

If you want to remain a member of the Settlement Class, and possibly receive compensation through the Claims Resolution Process under the Settlement, you should NOT request exclusion.

COMMENTING ON THE SETTLEMENT/FAIRNESS HEARING

16. Can I Object to or Comment on the Settlement?

The Settlement must be approved by the Court. If you do not opt out of the Settlement, you may file a written objection by ____________, to any aspect of the proposed settlement or the amount of attorneys’ fees, but you will be bound by the orders and judgments entered in this case, even if the Court does not agree with your objections. Each written objection should include (i) a statement of your objection(s), as well as the specific reasons you have for each objection, including any legal support you wish to bring to the Court’s attention and any evidence you wish to introduce in support of your objection(s), and (ii) your name, current address and telephone number.

Objections must be sent to each of the following addresses:

Clerk of the Court United States Courthouse 300 South Fourth Street, Suite 202 Minneapolis, MN 55415

Zimmerman Reed, P.L.L.P. Attn: Robert R. Hopper 651 Nicollet Mall, Suite 501 Minneapolis, MN 55402

Jardine, Logan & O’Brien Attn: Joseph Flynn 8519 Eagle Point Blvd., Suite 100 Lake Elmo, MN 55042

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Plaintiffs’ Lead Counsel

Defendants’ Lead Counsel

Your written objection(s) must be received no later than _________. If you file and serve a timely written objection, you may appear at the Fairness Hearing, either in person or through an attorney retained and paid by you. If you or your attorney intends to appear at the Fairness Hearing, you or your attorney must file a notice of intention to appear with the Clerk of the Court by ___________, with copies received by the Plaintiffs’ Counsel and the Defendants’ Counsel, at the addresses provided above.

17. What Is the Difference between Objecting to the Settlement and Excluding Myself from the Settlement Class?

An objection to the Settlement is made when you wish to remain a Settlement Class Member and be subject to the Settlement, but disagree with some aspect of it. By contrast, an exclusion means that you are no longer a Settlement Class Member and you lose any right to object to the Settlement because the case no longer affects you.

18. What Is the “Fairness Hearing”?

The Settlement will not become final unless and until the Court finds that it is fair, reasonable and adequate and approves it. The Court will hold a hearing (known as a “Fairness Hearing”) to assist it in making this determination.

19. When and Where Will the Fairness Hearing Take Place?

The Fairness Hearing will take place on _______, 2010, to consider (1) whether a settlement class can be certified; (2) whether to approve the proposed settlement as fair, reasonable, and adequate; and (3) whether the method of notice to the proposed settlement class is the best notice that is practicable under the circumstances. The Hearing will take place in the courtroom of the Honorable Joan N. Ericksen, United States District Judge, at __:00 a/p.m.

THE LAWYERS REPRESENTING YOU

20. Do I Have a Lawyer Representing My Interests in This Case?

The Court has designated the following counsel to represent the settlement class for the purposes of settlement of this lawsuit:

Robert R. Hopper David M. Cialkowski ZIMMERMAN REED, P.L.L.P. 651 Nicollet Mall, Suite 501 Minneapolis, MN 55402

Phillip F. Fishman FISHMAN, BINSFELD & BAHMEIER, P.A. 8011 34th Ave. S., Suite 245 Bloomington, MN 55425

Alex Alvarez THE ALVAREZ LAW FIRM 355 Palermo Ave. Coral Gables, FL 33134

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You will not be charged for the services of these or any other counsel representing the settlement class in this Action. You have the right to retain your own attorney and to enter an appearance through counsel in this matter, but if you do, you will be responsible for paying your own attorneys’ fees and expenses.
21. How Will the Lawyers and Class Representatives be Compensated?
Class Counsel will apply to the Court for an award of attorneys’ fees and costs on behalf of the counsel who have represented the Plaintiffs in this class action. Most of the fees and costs sought by Class Counsel will be paid by the Defendants and will not reduce any recovery to the Settlement Class Members. Under certain circumstances described in the Agreement, Class Counsel may make a request to the Court for an additional award of attorneys’ fees and costs, in an amount no greater than one hundred thousand dollars, to be paid from the Settlement Fund. Additional details are available in the Settlement Agreement, which can be found at the website at www.mgsfsettlement.com.
GETTING MORE INFORMATION
22. Are More Details about the Settlement and My Rights under the Settlement Available?
This Notice summarizes the Settlement and your rights under the Settlement. It cannot tell you every right to which you may be entitled. More details about the terms of the Settlement are set forth in the Settlement Agreement. If you have questions or want to know more about the Settlement, you can check the website at www.mgsfsettlement.com. The website has a copy of the complete Settlement Agreement and other important documents and will be maintained to provide answers to frequently asked questions.
23. What If I Have a Question?
To obtain further information or advice about your legal rights, you may contact Class Counsel without charge at 1-866-211-0079 or by email at MGSFSettlement@zimmreed.com, consult a lawyer at your own expense, or visit the website located at www.mgstsettlement.com.
PLEASE DO NOT CALL THE COURT, THE CLERK OF COURT, OR THE DEFENDANTS.
This ___ day of ___________, 2010.
___________________________ Judge Joan N. Ericksen United States District Judge

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Exhibit 3

CASE 0:09-cv-01996-JNE-AJB Document 66-7 Filed 11/04/10 Page 68 of 94

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA
PUBLICATION NOTICE OF PROPOSED CLASS ACTION SETTLEMENT AND RELEASE OF CLAIMS
For GARCIA v. METRO GANG STRIKE FORCE Case No. 09-CV-01996 (JNE/AJB)

If you had an encounter with the Metro Gang Strike Force or the Minnesota Gang Strike Force in an incident that involved the seizure of property, you may be a member of the class in a class action lawsuit that is being settled.

A lawsuit involving the Metro Gang Strike Force has been preliminarily certified as a class action, and a proposed settlement has been preliminarily approved. In this lawsuit, Plaintiffs have alleged that officers assigned to the Metro Gang Strike Force seized property without complying with the procedures required under law, and have also asserted claims for violations of the U.S. Constitution and Civil Rights Act, negligence, assault, false imprisonment, conversion and conspiracy to convert, and liability based on respondeat superior. The Defendants have denied liability, and the settlement is not an admission of wrongdoing.

A hearing will be held before the Honorable Joan N. Ericksen in the United States District Court for the District of Minnesota, at _______a/p.m., on __________, 2010 to determine (1) whether a settlement class can be certified; (2) whether to approve the proposed settlement as fair, reasonable, and adequate; and (3) whether the method of notice to the proposed settlement class is the best notice that is practicable under the circumstances.

If you had an encounter with the Metro Gang Strike Force or the Minnesota Gang Strike Force in an incident that involved the seizure of property, you may be a member of the class. IF YOU ARE A MEMBER OF THE CLASS, YOUR RIGHTS WILL BE AFFECTED WHETHER YOU ACT OR DO NOT ACT. A more complete explanation of the lawsuit, the definition of the class and the terms of the settlement can be found in the full Notice of Proposed Class Action Settlement and Release of Claims (the “Notice”). You may obtain a copy of the Notice at [website address] or by contacting the following attorneys who represent the Class:

Robert R. Hopper David M. Cialkowski ZIMMERMAN REED, P.L.L.P. 651 Nicollet Mall, Suite 501 Minneapolis, MN 55402

Phillip F. Fishman FISHMAN, BINSFELD & BAHMEIER, P.A. 8011 34th Ave. S., Suite 245 Bloomington, MN 55425

Alex Alvarez THE ALVAREZ LAW FIRM 355 Palermo Ave. Coral Gables, FL 33134

Members of the Class do not have to do anything to remain in the settlement. Class Members who remain in the Settlement can seek an award of compensation for any violation of their rights by the Metro Gang Strike Force or Minnesota Gang Strike Force, without the need to testify or to hire separate counsel. Class Members who remain in the settlement and wish to seek

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Class Members who want to exclude themselves from the Class must send a notice to opt out, as described in the full Notice, postmarked on or before ______(or received by that date if not sent by U.S. Mail). The deadline for submitting an objection to the Settlement is the same. Additional details regarding the notice to opt out or object to the settlement are found in the Notice. Class Members who do not send a notice to opt out of the settlement will be considered participating by default and will waive any rights to bring future claims against the Defendants regarding this matter.
Further information may be obtained by contacting Class Counsel by phone at 1866-211-0079, by email at MGSFSettlement@zimmreed.com, by visiting the settlement website at www.mgsfsettlement.com or by mail at the address indicated above.
By Order of the Court
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Exhibit 4

CASE 0:09-cv-01996-JNE-AJB Document 66-7 Filed 11/04/10 Page 71 of 94

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

ZELAIDO RIVERA GARCIA, MAURA GONZALES SALINAS, ADRIAN RAMIREZCUEVAS, CAMERINA CUEVAS LOPEZ,

Case No. 09-CV-01996 (JNE/AJB)

Plaintiffs,

v.
METRO GANG STRIKE FORCE, RON RYAN, former Metro Gang Strike Force Commander, DOE OFFICERS 1-34, individually and in their official capacities, OTHER UNKNOWN DOE OFFICERS, CITY OF WEST ST. PAUL, a municipal corporation, HENNEPIN COUNTY, a direct political subdivision of the State, DAKOTA COUNTY, a direct political subdivision of the State, RAMSEY COUNTY, a direct political subdivision of the State, CITY OF ST. PAUL, a municipal corporation, CITY OF MINNEAPOLIS, a municipal corporation, WASHINGTON COUNTY, a direct political subdivision of the State, CITY OF MAPLEWOOD, a municipal corporation, CITY OF LINO LAKES, a municipal corporation, CITY OF BROOKLYN PARK, a municipal corporation, CITY OF RICHFIELD, a municipal corporation, METROPOLITAN COUNCIL, METRO GANG STRIKE FORCE ADVISORY BOARD, MANILA (“BUD”) SHAVER, Chief of the West St. Paul Police Department, KEN SCHILLING, Inspector at the Hennepin County Sheriff’s Office, DAVE BELLOWS, Chief Deputy of the Dakota County Sheriff’s Office, BOB FLETCHER, Sheriff of the Ramsey County Sheriff’s Office, JOHN HARRINGTON, Chief of the St. Paul Police Department, ROB ALLEN, Deputy Chief of the Minneapolis Police Department, BILL HUTTON, Sheriff of the Washington County Sheriff’s Office, DAVE THOMALLA, Chief of the Maplewood Police Department, DAVE PECCHIA, Chief of the Lino Lakes Police Department, DAVE INDREHUS, Chief

SETTLEMENT ORDER AND FINAL JUDGMENT

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of the Metro Transit Police Department, MICHAEL DAVIS, Chief of the Brooklyn Park Police Department, BARRY FRITZ, Captain of the Richfield Police Department,
Defendants. This action was heard on __________________, before the undersigned, pursuant to the Order Preliminarily Approving Settlement and Approving Notice to Class Members (the “Preliminary Approval Order”) entered on _____________________, for the purpose of determining: (i) whether a settlement class could be certified pursuant to Rules 23(a) and 23(b)(3) of the Federal Rules of Civil Procedure; (ii) whether the proposed settlement (the “Settlement”) on the terms and conditions set forth in the Settlement Agreement previously submitted to the Court, should be approved as fair, reasonable and adequate; and (iii) whether the method of notice was the best notice that was practicable under the circumstances pursuant to Rule 23(c)(2) of the Federal Rules of Civil Procedure. Having conducted the analysis required by the statute, the Court finds and concludes, for purposes of settlement only, that the requirements of Rules 23(a) and 23(b)(3) of the Federal Rules of Civil Procedure have been satisfied; that a settlement class should be certified; that the Settlement is fair, adequate, and reasonable; and that notice was proved in accordance with Rule 23(c)(2). Having considered the record in this action, IT IS HEREBY ORDERED, ADJUDGED AND DECREED as follows: 1. The “Definitions” section of the Settlement Agreement is incorporated herein by reference. All capitalized terms used in this Order have the meaning set forth in the Settlement Agreement unless otherwise expressly indicated.

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2. This action is maintainable as a class action for settlement purposes only on
behalf of a class (“the Settlement Class”) consisting of all persons who:
(a) have been stopped, questioned, arrested, charged, frisked, detained or searched (including but not limited to persons who have had property searched or seized), or whose dwelling was searched;
(b) by a peace officer or peace officers serving on or assisting the MGSF or by a peace officer or peace officers serving on or assisting the Minnesota Gang Strike Force;
(c) in an incident where property was taken from one or more of the individuals stopped, questioned, arrested, detained or searched (or during a search and seizure of property belonging to one or more of such individuals); and
(d) the property was taken
i. without a receipt or inventory itemization, or
ii. without notification to the property owner of his or her right to contest the forfeiture.
The Settlement Class includes, but is not limited to, the persons whose property was
taken in connection with one of the 202 incidents referenced in Finding 8 of the report of the
Office of the Legislative Auditor dated May 20, 2009.
The Settlement Class does not include persons who commenced and settled individual
lawsuits against one or more of the Released Parties regarding claims encompassed in the
definition of Released Claims.
3. For settlement purposes only, the Court finds that the prerequisites of Rule 23(a)
and (b)(3) are satisfied and hereby certifies the foregoing defined Settlement Class pursuant to
Rule 23(b)(3).
4. The prerequisites for class action treatment under Rules 23(a) and (b)(3) of the
Federal Rules of Civil Procedure are satisfied by the Settlement Class, in that: (1) The number of

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class members comprising the Settlement Class is so numerous that joinder of all members is impracticable. Settlement Class includes, but is not limited to, the persons whose property was taken in connection with one of the 202 incidents referenced in Finding 8 of the Report of the Office of the Legislative Auditor dated May 20, 2009. (2) There are questions of law or fact common to the Settlement Class, including (a) whether Defendants were required to provide receipts of seized property, (b) whether Defendants were required to provide notices of the right to contest the forfeiture of property, (c) whether Defendants repeatedly failed to provide receipts of seized property, (d) whether Defendants repeatedly failed to provide notice of the right to contest the forfeitures as required by Minnesota law (Minn. Stat. § 609.5314), (e) whether Defendants acted under color of law when improperly seizing property, (f) whether Defendants failed to create records of seized property and incidents leading to the seizure of property, and (g) whether Defendants failed to properly maintain records of seized property and incidents leading to the seizure of property. (3) The claims or defenses of the proposed Class Representatives are typical of the claims or defenses of the other members of the Settlement Class. (4) The proposed Class Representatives and Class Counsel will fairly and adequately protect the interests of the Settlement Class. (5) The questions of law and fact common to the Settlement Class members predominate over any questions affecting only individual Settlement Class members. (6) Class action treatment is superior to other available methods for the fair and efficient resolution of this controversy. The Court also notes that, because this Action is being settled rather than litigated, the Court need not consider manageability issues that might be presented by the trial of a class action involving the issues in this case.
5. In making its findings, the Court has been provided copies of (1) the Report on the Metro Gang Strike Force issued by the Office of the Legislative Auditor for the State of

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Minnesota on or about May 20, 2009 and (2) the Report of the Metro Gang Strike Force Review Panel issued on or about August 20, 2009.
6. The Court finds that counsel for the Plaintiffs, Zimmerman Reed, P.L.L.P., Fishman, Binsfeld & Bahmeier, P.A. and the Alvarez Law Firm, are competent to serve as Class Counsel and will fairly and adequately represent the interests of the class.
7. Based on the submissions provided to the Court, the Court finds that notice has been given to the class pursuant to the Preliminary Approval Order, and that the mailing and publication of the Notice of Proposed Class Action Settlement and Release of Claims (the “Notice”) in accordance with the methodology adopted pursuant to this Settlement (a) was the best notice that was practicable to members of the Settlement Class; (b) was reasonably calculated, under the circumstances, to apprise members of the Settlement Class of the pendency of the Action, certification of the Settlement Class, the proposed Settlement, the rights of Class Members to object to the Settlement and the application of Plaintiffs’ counsel for payment of their attorneys’ fees and reimbursement of their litigation expenses, and to request exclusion from the Settlement Class; (c) was reasonable and satisfied the requirements of due process by providing due, adequate, and sufficient notice to all persons and entities entitled to receive notice; (d) clearly and concisely stated in plain, easily understood language: (i) the nature of the action, (ii) the definition of the class certified, (iii) the class claims, issues or defenses, (iv) that a class member may enter an appearance through an attorney if the member so desires, (v) that the court will exclude from the class any member who requests exclusion, (vi) the time and manner for requesting exclusion, and (vii) the binding effect of a class judgment on members under Rule 23(c)(3) of the Federal Rules of Civil Procedure; and (e) met all applicable requirements of law

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including, but not limited to, Rule 23(c) and the Due Process Clause of the Fifth Amendment to the United States Constitution.
8. Based on the submissions provided to the Court, the Court finds that Defendants have satisfied 28 U.S.C. § 1715(b) by, within 10 days after filing the Settlement with the Court, serving upon the appropriate State official of each state in which a class member resides and the appropriate Federal official the Notice required under the statute.
9. The terms of the Settlement, as set forth in the Settlement Agreement, are hereby determined to be fair, reasonable, and adequate. Accordingly, said Agreement, including each of its respective terms and conditions, is hereby finally approved.
10. The Court hereby enters judgment fully and finally dismissing and terminating all claims with prejudice, on the merits, against Defendants.
11. The Settling Class Members, those persons bound by the Settlement Agreement and subject to this Settlement Order and Final Judgment, consist of all persons included within the Settlement Class [IF APPLICABLE: except for those persons, listed in Exhibit __, who filed a timely request for exclusion from the Settlement Class.]
12. Pending the Effective Date, neither the Plaintiffs, nor any Settling Class Member, either directly, representatively, or in any other capacity, shall prosecute any action or proceeding in any court, tribunal or other forum asserting any of the Released Claims against the Released Parties.
13. As of the Effective Date: (a) Each Settling Class Member is deemed to have released and forever discharged the Released Parties from any and all Released Claims. (b) The Released Parties are not, and in the future shall not be, subject to liability or expense of any kind to Settling Class Members with

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respect to any of the Released Claims. The provisions of the Agreement shall be the exclusive remedy of all Settling Class Members against the Released Parties. (c) Each Settling Class Member is forever barred from asserting any of the Released Claims against any of the Released Parties. (d) Each Settling Class Member is deemed to have covenanted and agreed (a) that he or she will forever refrain from instituting, maintaining or proceeding against any Released Party on any Released Claim, including Released Claims known and not now known, suspected, or claimed, that they have or hereafter may have against the Released Parties; and (b) that he or she release the Released Parties from each and every such Released Claim. 14. As of the Effective Date, Settling Class Members are permanently enjoined from filing, commencing, prosecuting, continuing, litigating, intervening in, participating in as class members or otherwise, seeking to certify a class in a separate class of persons, as a purported class action (including by seeking to amend a pending complaint to include class allegations), or receiving any benefits or other relief from any other lawsuit, arbitration or administrative, regulatory or other proceeding or order in any jurisdiction, based on or relating to the claims and causes of action, or the facts and circumstances relating thereto, in or underlying this action which qualify them as Class Members. 15. As of the Effective Date, all Settling Class Members are forever barred and permanently enjoined from filing, commencing or prosecuting any other lawsuit as a class action (including by seeking to amend a pending complaint to include class allegations or by seeking class certification in a pending action in any jurisdiction), if such other lawsuit is based on or relates to the claims and causes of action, or the facts and circumstances relating thereto, in this action and/or the Released Claims. 16. Attorneys’ fees are awarded as set forth in a separate order entered on this date.

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17. Defendants have denied liability in this matter, and this Settlement does not constitute an admission of liability or wrongdoing. Neither this Final Judgment, the Settlement Agreement, the fact of settlement, the settlement proceedings, settlement negotiations, nor any related document, shall be used as an admission of any act or omission by Defendants or be offered or received in evidence as an admission, concession, presumption, or inference of any wrongdoing by Defendants in any proceeding other than such proceedings as may be necessary to consummate or enforce the Settlement.
18. Defendants shall have no responsibility for and shall have no liability whatsoever with respect to the allocation among Class Counsel and/or any other person who may assert a claim thereto, of any attorneys’ fees or expenses that the Court may award.
19. The parties are hereby authorized without further approval from the Court to adopt such amendments or modifications of the Settlement and all exhibits thereto as shall be consistent in all respects with this Settlement Order and Final Judgment and do not limit the rights of members in the Settlement Class.
20. The Court retains jurisdiction over this Settlement to the extent necessary to implement, effectuate and administer this Settlement and this Settlement Order and Final Judgment, including, but not limited to, any issues arising from the Court’s award of attorneys’ fees.

This ___ day of ___________, 2010.

___________________________ Judge Joan N. Ericksen United States District Judge

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Exhibit 5

CASE 0:09-cv-01996-JNE-AJB Document 66-7 Filed 11/04/10 Page 80 of 94
ESCROW AGREEMENT
ESCROW AGREEMENT (“Escrow Agreement”), dated as of ____________ (“Effective Date”), by and among, Class Counsel (as defined below), _________________, Defendants (as defined below), (“Defendants”), and U.S. Bank National Association, as Escrow Agent (“U.S. Bank”, or the “Escrow Agent”).
WHEREAS:
A. Class Counsel and Defendants are litigants in an action styled ________________________ (the “Action”). The action is currently pending in the United States District Court, District of Minnesota, (the “Court”).
B. The Court has appointed the following individuals as Class Counsel in this Action, and they are referred to herein as “Class Counsel.” All agreements made herein by Class Counsel are made on behalf of all indivuduals consolidated under the Action.
Robert R. Hopper David M. Cialkowski ZIMMERMAN REED, P.L.L.P. 651 Nicollet Mall, Suite 501 Minneapolis, MN 55402
Phillip F. Fishman FISHMAN, BINSFELD & BAHMEIER, P.A. 8011 34th Ave. S., Ste. #245 Bloomington, MN 55425
Alex Alvarez THE ALVAREZ LAW FIRM 355 Palermo Ave. Coral Gables, FL 33134
C. Class Counsel, on behalf of all individuals consolidated under the Action, and Defendants have entered into a Settlement Agreement, last executed and filed with the Court on ___________________, as may be modified by any subsequent order of the Court or agreement among the parties and approved by the Court (the “Agreement”);
D. Pursuant to the Agreement, on or before ____________, Defendants are required to deposit 3 million dollars ($3,000,000.00) (“Required Amount”) into a Settlement Account [describe details of deposit obligation];
E. The parties intend that any income tax payable in respect of any earnings on the Settlement Consideration and any fees or expenses of the Escrow Agent (or Tax Administrator as provided in paragraph 6.5 below) be paid as provided herein;
F. The parties have agreed that the purposes of the Agreement will be satisfied by the deposit of the Required Amount in a Settlement Account to be held in escrow by Escrow Agent pursuant to the
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provisions of this Escrow Agreement, pending the occurrence of the Settlement Effective Date or such earlier termination of the Settlement Account all as more fully set forth in the Agreement;
G. The parties have agreed that U.S. Bank will serve as the Escrow Agent for the Settlement Consideration; and
H. The parties desire to have the Escrow Agent accept, hold and distribute such funds deposited with the Escrow Agent, and the Escrow Agent has agreed to accept, hold and distribute such funds deposited with the Escrow Agent, in accordance with the terms, provisions, covenants and conditions of this Escrow Agreement.
NOW, THEREFORE, in consideration of the mutual premises and covenants contained herein and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties hereto, intending to be legally bound, hereby agree as follows:
1. Recitals and Definitions. The foregoing recitals are true and correct and are incorporated herein as if set forth at length. All references to specific defined terms not defined herein shall bear the same meaning and definition as set forth in the Agreement.
2. Establishment of Escrow. The parties acknowledge and agree that the following are specifically contemplated by the Agreement: (i) the appointment of the Escrow Agent as provided herein; (ii) payment of income tax arising in respect of earnings on the Settlement Consideration as provided herein; or (iii) any payment of fees or expenses of the Escrow Agent or Tax Administrator as provided herein.
3. Appointment of and Acceptance by the Escrow Agent. The parties hereby appoint U.S. Bank to serve as the Escrow Agent hereunder, and the Escrow Agent hereby accepts such appointment.
4. Settlement Account and Escrow Funds. Upon execution of this Escrow Agreement, the Escrow Agent shall immediately establish an account at U.S. Bank entitled “__________________ Settlement Account” into which Defendants shall deposit the Required Amount amounts in immediately available funds for disbursement in accordance with the terms of this Escrow Agreement, which account is the “Settlement Account” referred to in the Agreement and will be referred to as such herein. The Required Amount deposited in the Settlement Account, together with all interest earned thereon are the “Settlement Consideration” referred to in the Agreement and will be referred to as such herein. The Escrow Agent, immediately upon receipt, shall acknowledge receipt of the Required Amount to the parties in writing.
5. Investment of Settlement Consideration.
5.1 Investment. The Escrow Agent is authorized and directed to invest and reinvest the Settlement Consideration, to the extent practicable, as directed in writing by Class Counsel in one or more of the following: (a) debt obligations issued or guaranteed by the United States government or one of its agencies or instrumentalities, (b) money market funds primarily invested in or collateralized by the securities listed in clause (a) above, including funds to which the Escrow Agent or its affiliate may provide any services, and (c) U.S. dollar denominated deposit accounts with a national banking association (including Escrow Agent and its affiliates) which has a rating on its short- term deposits of “A-l+” by S&P and “P-1” by Moody's (ratings on holding companies are not considered as the rating of the bank); provided further that the Escrow Agent will not be directed to invest in investments that the Escrow Agent in its sole reasonable discretion exercised in good faith determines are not administratively or operationally feasible consistent with the Escrow Agent’s normal business practices (the “Permitted
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Investments”). In the absence of any written direction, the Settlement Consideration shall be invested as set forth on Exhibit B attached hereto and made a part hereof. Any amounts not reinvested in the Permitted Investments shall be held as cash within the Settlement Account. All interest and earnings of the Settlement Account shall be retained for the benefit of the Settlement Account. All such interest and earnings shall be reported, for tax purposes, under a tax identification number to be obtained by the Escrow Agent for the Settlement Account, which shall not be deemed to constitute Defendants’s income. The Trustee is authorized and directed to sell such investments as may be required to make any payment due under this Escrow Agreement.
5.2 Statements. The Escrow Agent shall, on a monthly basis, furnish to the parties a statement of the balance of the amounts on deposit in the Settlement Account as of the last “Business Day” (as hereinafter defined) of each month and the amount of interest or income that has accrued on the Settlement Consideration as of such date. For the purposes hereof, “Business Day” shall mean a day other than a Saturday, Sunday or other day on which commercial banks in the United States are authorized or required by law to close.
6. Disbursements of Escrow Funds.
6.1 Instruction. The Escrow Agent shall hold, maintain, and administer the Settlement Account for the benefit of the Settlement Account and shall permit the disbursement thereof solely pursuant to an order or other written instruction issued by the Court, or as otherwise authorized herein or the Agreement. It is recognized and agreed that the Court may order, or the parties may jointly agree, that the Escrow Agent transfer funds into a separate sub-account which may be established solely for the purposes of satisfying the provisions of the Agreement.
6.2 Withdrawal. Escrow Agent shall disburse Escrow Funds from time to time, upon receipt of, and in accordance with, a Written Direction. “Written Direction" shall mean a written direction executed by one or more Class Counsel (with supporting Court Order) directing Escrow Agent to disburse all or a portion of the Escrow Funds or to take or refrain from taking an action pursuant to this Escrow Agreement. Such Written Direction shall contain wiring instructions or an address to which a check shall be sent.
6.3 Qualified Settlement Account. The parties agree that the Settlement Account meets the requirements of a Qualified Settlement Fund under 26 CFR §§ 1.468B and 1.468B-l (c) and shall be treated accordingly for tax purposes. The parties agree that the Escrow Agent shall be appointed as the administrator of the Settlement Account for tax purposes or, if the Escrow Agent is unable or unwilling to serve as the administrator for tax purposes, it may select an independent certified public accounting firm of its choice, subject to approval by the parties which will not be unreasonably withheld (the “Tax Administrator”) to serve as administrator for tax purposes. In the event the Escrow Agent fails or refuses to select the Tax Administrator, the parties may jointly agree on the Tax Administrator, or the Tax Administrator shall be appointed by the Court.
6.4 Tax Administrator Responsibilities. The parties agree that the Tax Administrator or the Escrow Agent shall (i) obtain the federal and state taxpayer identification numbers for the Settlement Account and provide same to the Escrow Agent, (ii) be responsible for all tax reporting and filing requirements for the Settlement Account, (iii) provide instructions, in accordance with the notice provisions of paragraph 11.6 of this Escrow Agreement, to the parties for the release of sufficient funds from the Settlement Account to pay all taxes owed by the Settlement Account in accordance with 26 CFR § 1.468B-2 and any applicable state tax laws, and (iv) send copies of all such tax filings and returns to the parties in accordance with the notice provisions of paragraph 11.6 of this Escrow Agreement
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6.5 Tax Administrator Fees. The parties agree that any reasonable and necessary fees and expenses of the Tax Administrator may be paid from the Settlement Account, including without limitation fees and expenses of attorneys and accountants. The Tax Administrator may charge or otherwise recoup its fees and expenses as Tax Administrator in the same manner as set forth below in paragraphs 7.4 and 7.5 for the Escrow Agent’s Fees and Expenses.
7. Concerning the Escrow Agent.
7.1 Scope of Understanding. Other than as set forth in this Escrow Agreement, the Escrow Agent has no interest in the Settlement Consideration, but is serving as a stakeholder only and shall not be required to take any action with respect to any matters that may arise in connection with this Escrow Agreement, other than to receive, hold, pay interest earned as set forth in paragraph 5.1 hereof and make delivery of the Settlement Consideration as herein expressly provided or by reason of a judgment or court order. The Escrow Agent shall not be responsible for the performance of the parties’ obligations under this Escrow Agreement or for the performance of the parties’ obligations under the terms and provisions of the Agreement.
The Escrow Agent undertakes to perform only such duties as are expressly set forth herein and no duties shall be implied, and the Escrow Agent shall have no liability under and no duty to inquire as to the provisions of any agreement, settlement or Agreement. The Escrow Agent shall not be liable for any action taken or omitted by it in good faith except to the extent that a court of competent jurisdiction determines that the Escrow Agent’s gross negligence or willful misconduct was the primary cause of any loss to the parties hereto. In no event shall Escrow Agent be liable for incidental, indirect, special, consequential or punitive damages (including, but not limited to lost profits).
7.2 Knowledge and Sufficiency of Documents. The Escrow Agent shall not be bound by or have any responsibility with respect to compliance with any agreements between any parties herein, including, but not limited to, the Agreement, irrespective of whether the Escrow Agent has knowledge of the existence of any such agreement or the terms and provisions thereof. The Escrow Agent’s only duty, liability, and responsibility shall be to receive, hold, invest in accordance with the terms of the Agreement, pay interest earned as set forth in paragraph 5.1 hereof and deliver the Settlement Consideration as herein provided. The Escrow Agent shall not be required in any way to determine the validity or sufficiency, whether in form or in substance, of the Settlement Consideration or the validity, sufficiency, genuineness or accuracy of any instrument, document, certificate, statement or notice referred to in this Escrow Agreement or contemplated hereby, including, but not limited to, the Agreement, the parties’ mistake of law or fact, or for anything it may do or refrain from doing in connection herewith, except for its own willful misconduct or negligence.
7.3 Consultation with Legal Counsel. The Escrow Agent may consult with its inhouse counsel, or as reasonably necessary, with other counsel satisfactory to the Escrow Agent with respect to questions relating to its duties and/or responsibilities hereunder or otherwise in connection herewith and shall not be liable for any action taken, suffered or omitted by the Escrow Agent upon the advice of such counsel, provided that Escrow Agent does not commit gross negligence or willful misconduct. The Escrow Agent may act through its directors, officers, affiliates, agents, representatives, attorneys and employees so long as they are not affiliated with any of the parties.
7.4 Reimbursement of Fees and Expenses of the Escrow Agent. In consideration of its acting as the Escrow Agent under and pursuant to this Agreement, the Escrow Agent shall be entitled to reasonable fees, expenses and costs for its services performed hereunder, in accordance with Exhibit A attached to and incorporated into this Agreement. Such fees and expenses shall be chargeable to, and the Escrow Agent may deduct such fees and expenses from, the Settlement Account; except that Escrow
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Agent shall give the parties ten (10) days’ advance written notice of its intention to deduct any fees or expenses from the Escrow Account. Notwithstanding anything to the contrary and subject to Section 7.5 herein, the Escrow Agent’s costs shall include without limitation costs to indemnify and hold it harmless against any and all losses, claims, damages, liabilities and expenses, including reasonable costs of investigation, reasonable attorneys’ fees and disbursements that may be imposed on the Escrow Agent or incurred by the Escrow Agent in connection with the performance of its duties under this Escrow Agreement
7.5 Dispute Resolution for Fees and Expenses. Any dispute regarding the reasonableness of costs, expenses or fees provided for in subparagraphs 6.5 and 7.4 shall be determined by the Court.
7.6 Indemnification of Escrow Agent. Class Counsel agree jointly and severally to indemnify and hold the Escrow Agent harmless against any and all losses, claims, damages, liabilities and expenses, including reasonable costs of investigation, reasonable attorneys’ fees and disbursements that may be imposed on the Escrow Agent or incurred by the Escrow Agent in connection with the performance of its duties under this Escrow Agreement (“Losses”), including but not limited to any litigation arising from this Escrow Agreement or involving its subject matter; provided that there shall be no obligation to indemnify or hold the Escrow Agent harmless against any Losses arising from the any gross negligence or willful misconduct of Escrow Agent.
8. Removal or Resignation of the Escrow Agent. The Escrow Agent may resign at any time, for any reason, by written notice of its resignation given by the Escrow Agent to the Defendants and Class Counsel at least thirty (30) days before the effective date specified for such resignation. The Escrow Agent may be removed by the Court or by written agreement of Defendants and Class Counsel at any time for any reason by written notice given to the Escrow Agent at least thirty (30) days before the effective date specified for such removal. Upon the effective date of such resignation or removal:
(i) All funds in the Settlement Account shall be delivered by the Escrow Agent to such successor escrow agent as may be designated by the Court or otherwise designated by mutual written agreement of Defendants and Class Counsel, whereupon the Escrow Agent’s obligations hereunder shall cease and terminate;
(ii) If no such successor escrow agent has been designated by such date, all obligations of the Escrow Agent hereunder shall, nevertheless, cease and terminate, and the Escrow Agent’s sole responsibility thereafter shall be to keep all funds in the Settlement Account and to deliver the same to a person designated by the Court or otherwise designated by mutual written agreement of Defendants and Class Counsel; and
(iii) Further, if no such successor escrow agent has been designated by such date, the Escrow Agent may petition the Court for the appointment of a successor escrow agent and the Escrow Agent may deliver to the Court all funds in the Settlement Account.
9. Dealings. The Escrow Agent and its “Affiliates” (as such term is defined in Rule 12b-2 under the Securities Exchange Act of 1934, as amended) may, without having to account therefor to any other party hereto, accept deposits from, extend credit (on a secured or unsecured basis) to and generally engage in any kind of banking, trust or other business with any such party or any of its Affiliates as if it were not acting as the Escrow Agent. Other than as set forth in this Escrow Agreement, the Escrow Agent and/or the Escrow Agent’s Affiliates shall have no right of set-off or recoupment against the Escrow Funds in connection with any loan or other business transaction with any other party hereto.
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10. Representations, Warranties and Additional Agreements.
10.1 Defendants. Defendants represent and warrant to Escrow Agent that it is duly organized, validly existing, and in good standing and has full power and authority to execute and deliver this Escrow Agreement and to perform Defendants’ obligations hereunder; this Escrow Agreement has been duly approved by all necessary action of Defendants, has been executed by duly authorized agents of Defendants, and constitutes a valid and binding agreement of Defendants, enforceable in accordance with its terms; no party other than the other parties have, or shall have, any lien, claim or security interest in the Settlement Consideration or any part thereof; and the representations and warranties of Defendants contained herein are true and complete as of the date hereof and shall be true and complete at the time of any disbursement of the Settlement Consideration.
10.2 Additional Agreements.
(a) Class Counsel and Defendants agree that neither party shall have any greater interest or rights to the Settlement Consideration than as granted by the terms of the Agreement and herein.
(b) Until the Settlement Consideration is released pursuant to the terms of this Escrow Agreement, the Settlement Consideration shall not be an asset of any party to this Escrow Agreement, and the Settlement Consideration shall not be encumbered, alienated, used as collateral or listed as an asset on any financial statement of any party.
(c) The interests of the Escrow Agent is limited as set forth in this Escrow Agreement.
11. Miscellaneous.
11.1 Complete Agreement. This Escrow Agreement shall constitute the parties’ entire agreement with respect to the subject matter hereof and supersede all agreements, representations, warranties, statements, promises and understandings, whether oral or written, with respect to the subject matter hereof.
11.2 Amendments and Waivers. This Escrow Agreement may be amended, modified and supplemented, and compliance with any provision hereof may be waived, only by a writing signed by each of the parties hereto.
11.3 Assignment. No party to this Agreement may assign any of its rights under this Agreement without the prior consent of the other parties, such consent not to be unreasonably withheld. This Escrow Agreement shall be binding upon and inure to the benefit of Class Counsel, Defendants, the Escrow Agent and their respective successors and permitted assigns.
11.4 Waivers Strictly Construed. With regard to any power, remedy or right provided herein or otherwise available to any party hereunder (a) no waiver or extension of time shall be effective unless expressly contained in a writing signed by the waiving party; and (b) no alteration, modification or impairment shall be implied by reason of any previous waiver, extension of time, delay or omission in exercise, or other indulgence.
11.5 Severability. In case anyone or more of the provisions contained in this Escrow Agreement shall, for any reason, be held to be invalid, illegal or unenforceable in any respect, such
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invalidity, illegality or unenforceability shall not affect any other provisions of this Escrow Agreement, and this Escrow Agreement shall be construed as if such invalid, illegal or unenforceable provision had never been contained herein.
11.6 Notices. All notices under this Escrow Agreement will be in writing and will be delivered by personal service or facsimile or certified mail (or, if certified mail is not available, then by first class mail), postage prepaid, to such address as may be designated from time to time by the relevant party, and which will initially be as set forth below. Copies of all notices shall be given to Class Counsel, Defendants and the Escrow Agent. Any notice sent by certified mail will be deemed to have been given three (3) days after the date on which it is mailed. Any notice transmitted by facsimile will be deemed given upon confirmation of receipt. All other notices will be deemed given when received. Notices will be addressed as follows or to such other address as the party to whom the same is directed will have specified in conformity with the foregoing:
(a) If to Class Counsel:
Robert R. Hopper David M. Cialkowski ZIMMERMAN REED, P.L.L.P. 651 Nicollet Mall, Suite 501 Minneapolis, MN 55402
Phillip F. Fishman FISHMAN, BINSFELD & BAHMEIER, P.A. 8011 34th Ave. S., Ste. #245 Bloomington, MN 55425
Alex Alvarez THE ALVAREZ LAW FIRM 355 Palermo Ave. Coral Gables, FL 33134
(b) If to the Escrow Agent:
U.S. Bank National Association Attn:
(c) If to Defendants:
Joseph Flynn JARDINE, LOGAN & O’BRIEN 8519 Eagle Point Blvd., Suite 100 Lake Elmo, MN 55042 (651) 290-7416
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11.7 Governing Law. The rights and liabilities of the parties under this Escrow Agreement shall be governed by the laws of the State of Minnesota, regardless of the choice of laws provisions of such state or any other jurisdiction.
11.8 Forum and Consent to Jurisdiction. Any litigation which arises out of or under this Escrow Agreement or which relates to this Escrow Agreement in any manner whatsoever (including any litigation to void or otherwise set aside this Escrow Agreement) shall be instituted exclusively in the U.S. District Court for the District of Minnesota. All parties agree to and do hereby submit themselves to the jurisdiction of such court for purposes of any litigation arising out of or under or relating in any manner to this Escrow Agreement.
11.9 Facsimile; Counterparts. The receipt of a facsimile executed copy of this Escrow Agreement from any party hereto shall be deemed to be original incontrovertible evidence that such party has delivered this Escrow Agreement with the same force and effect as though the original executed Escrow Agreement had been delivered. This Escrow Agreement, and any Written Direction related hereto, may be executed in counterparts, each of which shall be deemed an original, but all of which together shall constitute one and the same instrument.
11.10 Survival. The provisions of this Escrow Agreement shall survive the termination of this Escrow Agreement.
11.11 Construction. This Escrow Agreement shall be construed without regard to any presumption or rule of law against the party causing this Escrow Agreement to be drafted.
12. USA Patriot Act. To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account. For a non-individual person such as a business entity, a charity, a trust or other legal entity, Escrow Agent will ask for documentation to verify its formation and existence as a legal entity. Escrow Agent may also ask to see financial statements, licenses, identification and authorization documents from individuals claiming authority to represent the entity or other relevant documentation.
13. Security Advice Waiver Language. Each of Class Counsel and Defendants acknowledges that regulations of the Comptroller of the Currency grant Escrow Agent the right to receive brokerage confirmations of security transactions as they occur. Each of Class Counsel and Defendants specifically waives such notification to the extent permitted by law and acknowledges that each of Class Counsel and Defendants will receive periodic cash transaction statements, which will detail all investment transactions.
IN WITNESS WHEREOF, the parties hereto have caused this Escrow Agreement to be duly executed and delivered as of the date first written above.
Class Counsel:
______________________________
By:____________________________________
______________________________
By:____________________________________
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CASE 0:09-cv-01996-JNE-AJB Document 66-7 Filed 11/04/10 Page 88 of 94 U.S. Bank National Association: By:____________________________________ Defendants: ______________________________ By:____________________________________
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EXHIBIT A Escrow Agent Fees

I. Acceptance Fee:

$

The acceptance fee includes the administrative review of documents, initial set-up of the account, and

other reasonably required services up to and including the closing. This is a flat one-time fee, payable at

closing.

II. Annual Administration Fee:

$

An annual administration fee for performance of the routine duties of the escrow agent associated with the

management of the account. Administration fees are payable in advance at closing and on each

anniversary of the closing.

The Administration Fee includes up to ____ disbursements per month by the Escrow Agent, which disbursements may include checks or wires to Class Counsel and cash distribution agents or accounts. Disbursements in excess of such ___ per month are subject to additional charges as extraordinary services.

III. Out-of-Pocket Expenses:

At Cost

Reimbursement of expenses associated with the performance of our duties, including without limitation

fees and expenses of legal counsel, accountants and other agents, tax preparation, reporting and filing,

publications, and filing fees.

IV. Extraordinary Expenses: Extraordinary services are duties or responsibilities of an unusual nature but not provided for in the governing documents or otherwise set forth in this schedule, including without limitation amendments, specialized reporting, use investments not automated with the Escrow Agent’s trust accounting system, and actual or threatened litigation or arbitration proceedings. A reasonable charge will be assessed based on the nature of the service and the responsibility involved. At our option, these charges will be billed at a flat fee or our hourly rate then in effect.

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account. For a non-individual person such as a business entity, a charity, a Trust or other legal entity we will ask for documentation to verify its formation and existence as a legal entity. We may also ask to see financial statements, licenses, identification and authorization documents from individuals claiming authority to represent the entity or other relevant documentation.

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EXHIBIT B U.S. BANK NATIONAL ASSOCIATION MONEY MARKET ACCOUNT AUTHORIZATION
DESCRIPTION AND TERMS The U.S. Bank Money Market account is a U.S. Bank National Association (“U.S. Bank”) interestbearing money market deposit account designed to meet the needs of U.S. Bank’s Corporate Trust Services Escrow Group and other Corporate Trust customers of U.S. Bank. Selection of this investment includes authorization to place funds on deposit and invest with U.S. Bank. U.S. Bank uses the daily balance method to calculate interest on this account (actual/365 or 366). This method applies a daily periodic rate to the principal balance in the account each day. Interest is accrued daily and credited monthly to the account. Interest rates are determined at U.S. Bank’s discretion, and may be tiered by customer deposit amount. The owner of the account is U.S. Bank as Agent for its trust customers. U.S. Bank’s trust department performs all account deposits and withdrawals. Deposit accounts are FDIC Insured per depositor, as determined under FDIC Regulations, up to applicable FDIC limits.
AUTOMATIC AUTHORIZATION In the absence of specific written direction to the contrary, U.S. Bank is hereby directed to invest and reinvest proceeds and other available moneys in the U.S. Bank Money Market Account. The U.S. Bank Money Market Account is a permitted investment under the operative documents and this authorization is the permanent direction for investment of the moneys until notified in writing of alternate instructions.
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 CASE 0:09-cv-01996-JNE-AJB Document 471 Filed 09/05/12 Page 1 of 11

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Zelaido Rivera Garcia et al.,

Plaintiffs,
v. Metro Gang Strike Force et al.,

Civil No. 09-1996 (JNE/AJB) CORRECTED ORDER DETERMINING APPEALS FROM THE DETERMINATIONS OF THE SPECIAL MASTER

Defendants.

This Order contains the Court’s decisions with respect to each of the claims appealed from the Special Master’s Determination of award pursuant to class action settlement.

BACKGROUND

On July 1, 2005, Minnesota established a Gang and Drug Oversight Council and directed that the Council develop a strategy to “ameliorate the harm caused to the public by gang and drug crime within the state of Minnesota.” Minn. Stat. § 299A.641, subdiv. 3. The Council was directed to establish multijurisdictional task forces and strike forces, to include a metro gang strike force. The Metro Gang Strike Force, a stand-alone strike force—and a defendant in this action—was duly created. Metro Gang Strike Force (MGSF or Strike Force) officers were licensed peace officers employed by an existing agency and were given statewide jurisdiction while assigned to the MGSF. The MGSF maintained its own office, but officers on tour with it officially remained employees of the department by which they were normally employed. Before July 1, 2005, when the MGSF was created, statewide gang investigation fell under the authority of the Minnesota Gang Strike Force.

The MGSF came to a screeching halt in 2009. At that time problems came to light concerning supervision, accountability, and officer conduct within the Strike Force. The problems were serious. Of particular relevance to the settlement in this action were MGSF evidence-handling practices. Issues included taking property from gang suspects and their associates without justification, failing to comply with legal requirements to give proper notice to owners of seized property, and unauthorized conversion of seized property to Strike Force and even officers’ personal use. On May 20 the Minnesota Legislative Auditor, Financial Audit Division, issued a formal report. The Report, which is publically available and part of the record in this case, explained the results of the Division’s special review of the MGSF for the period July 1, 2005 through March 31, 2009. The report was damning, both of the Strike Force and the Oversight Council. The night the Report was released some Strike Force personnel were observed to be shredding documents in the MGSF offices. Upon learning of the document

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shredding, Hennepin County Sherriff’s Captain Chris Omodt, who was at that moment and for a brief time in charge of the MGSF, took action: He immediately shut down Strike Force operations and closed the office.
In the wake of Captain Omodt’s shuttering of the MGSF, the Commissioner of Public Safety and others considered reviving the Strike Force on a temporary basis pending possible reorganization and resurrection of the Strike Force. However, a significant number of police and sheriff’s departments withdrew their participation and no reopening occurred. On July 17, 2009 the Commissioner, Michael Campion, formally and permanently disbanded the Strike Force.
Six days after the Legislative Auditor’s Report, Commissioner Campion convened a special panel to independently investigate the conduct that gave rise to the findings of the Auditor. The Metro Gang Strike Force Review Panel completed a thorough investigation and issued its report on August 20, 2009. The Review Panel’s report (Panel Report) was complimentary of the work of many of the officers who had been assigned to the MGSF. Overall, though, the Panel Report excoriated the record keeping, oversight, and some behavior and patterns of behavior in the MGSF. The Panel Report, like the Auditor’s Report, is publically available and is part of the record in this case.
Virtually contemporaneously with Commissioner Campion disbanding the MGSF this putative class action lawsuit was filed. The proposed class consisted of “[a]ll persons who have been stopped, questioned, arrested, frisked, detained, searched, or any combination, by an Officer or Officers serving on the MGSF, and whose property was taken without a receipt or inventory itemization and without notification of their right to contest the forfeiture.” A subclass was defined as “[a]ll persons who have been stopped, questioned, arrested, frisked, detained, searched, or any combination, based on their national origin, by an Officer or Officers serving on the MGSF, and whose property was taken without a receipt or inventory itemization and without notification of their right to contest the forfeiture.” Explicitly excluded from the class were “those whose encounters with MGSF Officers resulted in their indictment or other duly filed criminal complaint by a criminal prosecuting authority.”
The parties reached a negotiated settlement of the lawsuit. This Court approved the settlement, authorized a claims resolution procedure, defined the Settlement Class, and ordered public notice to all potential class members.
As was contemplated in the Settlement, class counsel received and reviewed claims received from members of the public, and then submitted them to the Special Master, Mark Gehan, along with the defendants’ response and any reply. The Special Master’s determinations are final unless timely appealed to this Court. In these cases the Court’s determinations, made on the same record as presented to the Special Master, are final. The Court has reviewed the claimants’ letters of intent to appeal and is satisfied that all were timely submitted.
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EXPLANATION OF THE COURT’S REVIEW PROCESS
The first order of business in examining a claim file was to determine whether the claim fell within the Settlement Class definition. The Settlement Class, which was proposed by the parties and approved by the Court, is not precisely the same as the Amended Complaint’s proposed class. The Settlement Class consists of:
All persons who:
(a) have been stopped, questioned, arrested, charged, frisked, detained or searched (including but not limited to persons who have had property searched or seized), or whose dwelling was searched; (b) by a peace officer or peace officers serving on or assisting the MGSF or by a peace officer or peace officers serving on or assisting the Minnesota Gang Strike Force; (c) in an incident where property was taken from one or more of the individuals stopped, questioned, arrested, detained or searched (or during a search and seizure of property belonging to one or more of such individuals); and, (d) the property was taken (i) without a receipt or inventory itemization, or (ii) without notification to the property owner of his or her right to contest the forfeiture.
In order to be included in the class of persons eligible to receive compensation from this Settlement Fund the requirements of membership in the Settlement Class must be met. One requirement, set forth in subparagraph (a), is that the petitioning claimant must have been personally stopped, questioned, arrested, charged, frisked detained, searched, or had their dwelling searched. If the petitioning claimant did not have property taken from him or her personally, the class definition could be met if someone who was stopped, questioned, etc. in the same incident had property taken without receiving a receipt or inventory itemization or notification of the right to contest forfeiture. Class membership also requires, in subparagraph (b), that the stopping, searching, etc. have been done by an officer who was, at the time, serving on the MGSF (or, if before July 1, 2005, the Minnesota Gang Strike Force). If the searching officer was not so serving, the class definition covers the incident if the officer was assisting the Strike Force. Instances where the Strike Force was merely assisting another police department are not within the definition. Actions of officers who were not assigned to the Strike Force at the time of the claimed action are not made class eligible by virtue of the fact that their employing department participated in the MGSF or that that officer was assigned to the Strike Force at some other time.
Where (a) and (b) are satisfied, (c) and (d) further define the class in terms of property seizure. This means that some apparently legitimate grievances concerning police conduct—
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even unconstitutional conduct—are not compensable from the settlement fund in this action because there is no corresponding property seizure as required by (c) and (d). If a person experienced excessive use of force, for example, or deportation or verbal harassment, that alone would not place them within the settlement class. Subsection (c) requires that property have been taken. Finally, if property was taken it satisfies the definition only if it was taken without either a receipt or itemization, or notice of the right to contest forfeiture. That final subsection, (d), being introduced by the word “and,” is conjunctive, meaning it is a requirement applicable to all preceding subsections. And again, if a person experiences every component of the definition except that the action was not a Strike Force action but rather the action of an officer of a department such as the Minneapolis, Edina, or St. Paul Police Department, that person cannot be awarded a portion of the settlement proceeds in this case. Claims where there was no MGSF action, yet claimants speculate (there is no actual evidence of this) that the relevant officers were somehow influenced by the Strike Force behind the scenes, or that the officers picked up bad habits during their MGSF tour that they then employed in service of their regular employment are deemed to be outside the class definition.
The Order that set out the settlement procedure required that claims be made by February 2, 2012, and also that they be submitted with a Claim Form. Thus, if a claim contained a compilation of papers but no Claim Form, or if the February 2 deadline was not met, the claim is not compensable under the terms of the Settlement. Statutes of limitation apply to virtually all litigation. The longest limitation on time of any claim pled in this case is six years. See Minn. Stat. § 541.05. The Court has applied that maximum time limit to all claims, even where a shorter time limit might arguably apply. The lawsuit was filed on July 30, 2009, so claims are deemed not time barred if they arise from events that occurred on July 30, 2003 or later.
Once satisfied that a claim, on its face, fell within the class, the Court examined all the documentation to evaluate trustworthiness. The information that was submitted had to be convincing enough to support a reasonable conclusion that the event happened as described. In this regard the Court employed an extremely low burden of proof, and it appears that the Special Master did as well. Independent corroborating evidence was not expected. Poor recollection of dates and details was accepted unless it cast doubt on the whole claim. Even claims that did not seem plausible on their own were accepted if they made some sort of sense when viewed in the context of the picture that emerged from other claims or established facts. The Court has employed this low threshold because it seems consistent with the spirit of the settlement and also because credibility is difficult to assess in the absence of live interaction. That being said, the settlement fund is not a free for all; something in the claim or supporting documents that made it plausible was required. For example, if a claim sought $1,000,000 and came from a person who has filed failed lawsuits seeking over $40,000,000 in the past 7 years, it did not meet the low threshold. In a less extreme example, if a person declared that a large sum of money was seized from him by the MGSF and that he had just received the money for his birthday, it was harmful to the claim if neither he nor his mother could pinpoint the date of the event within a 3-month
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window. On the other hand, where several claimants describe an event of a type that was typical of known MGSF patterns, those claims might be credited even though there was no police report corroborating any such event and the claimants identified an officer by a name not associated with the Strike Force.
The settlement stipulated that the option to appeal a Special Master determination was available only to claimants, not to any defendant. The one-sided appeal right informed this Court’s review such that no claim has been reduced on appeal. The settlement did not explicitly provide that no claimant would be made worse off for having filed an appeal, but the Court considered that to be a reasonable and fair expectation. As to the amounts of awards, the Court recognizes that awards to appealing claimants and non-appealing claimants will be paid out of the same fund, and also that less than half of the more than 200 claims have been appealed. New or raised awards, therefore, are kept roughly in line with the entire body of awards as much as possible.
A few additional notes of explanation: Except where explicitly explained, the findings of the Special Master are incorporated into this Order. The Special Master Determinations were presented claimant-by-claimant. The Court in this Order has grouped together claims receiving similar resolution, and also claims that seem to arise out of a common event, with this caveat. Many claimants are socially interconnected, and experienced incidents in the company of a fluid subset of other claimants. The Court has expended a great deal of time and energy poring over the claims and police reports in an effort to understand which claimants might have been together for various incidents. As may be expected, though, the descriptions are often quite vague and imprecise, so tying particular claimants to particular events did not prove to be an exact science. Almost all of the claims describe multiple events. One might be compensable, but others not. Or claims might fall outside the settlement class for more than one reason. In some instances the Special Master’s determination is affirmed even though the Court would arrive at the same conclusion for different (or slightly different, yet overlapping) reasons. Because this Order is issued as part of a settlement, in most instances the Court has not deemed it productive to detail every point of difference.
Nowhere did the Court find evidence of an attempt at a comprehensive analysis of which claims related to which common event. Thus, when it reviewed the claim files, and saw a reference to, for example, “sunglasses,” it re-reviewed all the files for which its memory or notes indicated that there might be allegations that could dovetail with the “sunglasses” incident. That laborious exercise could not be avoided, partly because the class definition, at (a) and (c), included individuals who were detained in an incident in which property was taken from someone whether they personally lost property or not. Although the terms of the settlement procedure required class counsel to conduct an independent review of the merits of each claim, the recommendations of counsel were not helpful. Recommendations for awards were made in situations where the claim could not conceivably fit the class definition, and there was no
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meaningful response to MGSF counsel’s analysis, including on legal points such as the applicable statute of limitations.
Claim files that were submitted to the Special Master remain sealed although all of the Determinations are publically available. With respect to claim determinations that were appealed, however, the Court has ordered that the claim and claim file be publically filed as well. The straightforward reasoning for this distinction is that privately agreeing to a resolution is one thing, but if this Court is called upon to weigh in, it will not do so without revealing the basis of its decision. Names of minors are redacted, and for the most part that includes claimants who were minors at the time of the events even if they were no longer minors at the time they filed a claim. The settlement submissions refer to minors by their initials rather than their names. The parties and Determinations also refer to adults by their initials if they were present during the events described in a minor’s claim. The Court has not continued to refer to adults by their initials; overuse of initials makes understanding the claims almost hopelessly confusing, and for no good reason. An example of unnecessary redaction is that the submitted claims refer even to claimants who are named plaintiffs by their initials.
Each determination of the Special Master was individually filed and docketed, triggering an ECF docket number. Each appeal was also individually filed and docketed; ECF docket numbers were assigned to the appeals. For ease of reference, the Court in this Order refers to each claim by the ECF docket number assigned to the Special Master’s Determination. Attached to this Order is a key showing the name of the claimant and the docket numbers associated with the Special Master’s Determination and appeal, if any. Names of juveniles are redacted to reveal their initials only, but adults are included in the table by name.
AWARDS
The following appeals concern claimants who were promised $2,500 each as a named plaintiff incentive. Those awards are affirmed even if the claimant does not receive any other compensation:
140, 252, 174
Claims 114 and 247 either did not submit the required claim form or did not submit it by the February 2 deadline.
The following claims are time barred:
277 (events occurred in 1998; claimant is serving 264 month prison sentence)
127 (events occurred long ago, some in the 1950’s; non-time barred claim denied, infra)
147 (property taken in 2001 and 2002)
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175 (stopped at a gas station in 2002)
181 (one time barred claim; others denied, infra)
227 (stolen guns, all but one with obliterated serial numbers recovered by St. Paul Police Department in 2001).
The following claims concern events with respect to which the Court agrees with the Special Master that there was no qualifying Strike Force involvement:
119 (initial filing made no mention of MGSF, response does not meet threshold of persuasion on the point)
158 (Money was taken from claimant’s till at the State Fair, but it was the Ramsey County Sheriff’s Department Civil Division executing a civil judgment.)
161 (Claimant has many arrests and prosecutions and it was not possible, with any degree of confidence, to link MGSF to particular alleged improper seizure.)
137 (First of three events was St. Paul Police Department not MGSF and other two occurred after MGSF was disbanded and were not MGSF. The Court notes that claimant asserts that he saw Strike Force insignia on officers’ jackets, but the presence of insignia of the SPPD SWAT team or SPPD Gang unit might be mistaken for MGSF and the record shows contact between those units and this claimant.)
127 (remaining non time-barred claim—or claims, it is difficult to tell—have nothing to do with the MGSF. Claimant has unfortunate issues that have brought her in contact with Health and Human Services, the Ramsey County Sheriff’s Department and the St. Paul Police Department.)
232 (Strike Force merely assisting Edina Police Department investigating a shooting at Southdale)
174 (June 2, 2009 search warrant not by Strike Force but by Minneapolis Police Department, plus MGSF not operational at that time)
153 (no property taken)
152 (Robbinsdale Wiz Bang Days episode not MGSF; second episode, in which the drug ecstasy was recovered, was Minneapolis Police Department, also not MGSF)
248
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298 (Wiz Bang Days. Crystal Frolics, 2009 did not begin until July 23; MGSF functionally disbanded in May, formally and permanently closed July 17.) 255 (event in 2007 involved a Ramsey County Deputy who was not assigned to MGSF until 2008) 307 (claim has additional problems, but the identified officer was not assigned to MGSF at the relevant time) 218 (claimant currently serving federal sentence arising out of October 3, 2005 arrest in which Strike Force merely assisting Minneapolis Police Department). In the following claims, the Special Master was unable to conclude that there was MGSF involvement. The Court reaches a different conclusion and awards $2,000 in each: 274 (this is in addition to $12,000 already awarded) 249 251 With respect to the following claims, the Court agrees with the Special Master that the available information is not strong enough to permit acceptance of the claimant’s assertions: 313 113 117 144, 145, 146 (all the same claimant; the $200 award in 145 is affirmed) 154 (the Court accepts that claimant was stopped by MGSF in April of 2007 while driving on Highway 494, and that money property was seized from him. However, the Court concludes that notices of forfeiture were given, and so subsection (d)(2) of the class definition is not met.) 161 181 235 (However, the Court discovered one event in this claim file that it does credit, and awards $2,000) 238 (Claimant is serving a 275 month sentence arising out of an event in which the Northwest Metro Drug Task Force, not MGSF was involved.)
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301 307 308 (A search was indeed executed on May 25, 2004. However, claimant was arrested and proper claim and forfeiture forms were given. Claimant’s original handwritten claim form lists “8 ounces of cocaine” among the property items taken.) During the months of May, June and July of 2008, the MGSF engaged in a saturation effort (the “surge”) that gives rise to many of the claims. The Court affirms the Special Master’s monetary awards in those claims; as previously explained, no awards have been reduced or disqualified on appeal. Where a zero award is affirmed it is because there was no contact between the claimant and the MGSF, as, for example where a person is aggrieved by actions that were reported to them but not witnessed by them with respect to another claimant. The following awards are affirmed: 274 110 111 173 225 233 255 252 241 243 275 276 Three search warrant executions require separate attention. One was a high risk warrant at 8442 Douglas Circle in Brooklyn Park; the Special Master’s determination in claim 257 is affirmed. Another complicated warrant was executed at 1105 Sheridan Avenue North. A number of claimants were present during the execution of that warrant and one of them received an award. That claim was not subject to an appeal. Without discussing whether that (non-
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appealed) award was or was not justified, the Court makes the following awards in the amount of $1,500 each because it concludes that the claimants were present and not free to leave during a search warrant execution for which at least one person received compensation:
261
264
265
268
271.
Finally, a search was conducted on July 29, 2008 at a rented apartment in Crystal. The claimants in 254 (Norberto Ramirez-Jimenez) and 300 (Illiana Villa) were co-signers on the lease, but many more people than that were connected in some way to the apartment and its residents. The Court has exhausted its efforts to sort out exactly which appealing claimants were detained during the execution of the search warrant. Some claims arising from this incident are for losses that are outside the settlement class definition: loss of companionship, loss of daycare due to deportation, a broken tooth, and so on. Some claims do concern property that was taken, allegedly by MGSF personnel. However, all of the property losses except one (a $160 cash seizure) were attributable to the fact that following the search (in which a kilo of cocaine was also recovered) the property management company changed the locks on the apartment and removed all of its contents. No doubt there were losses of sentimental items when the apartment was cleaned by the caretaker. The Court agrees with the Special Master that the bulk of the property loss was attributable to private and not MGSF actions. Private counsel for this subset of claimants expresses concern that the fact that a Hennepin County lawsuit brought by some portion of this subset of claimants against the property management company was settled has caused the claims to be denied here. That is not the case. The files persuade the Court that property like furniture, baby pictures, clothing and the like were not taken by the MGSF, and consequential damages are not within the scope of the settlement even if the losses had been an outgrowth of a constitutionally infirm search.
Nevertheless, at least one class-qualifying forfeiture did take place during the search, which led to the award in 140. Following is a list of claims that arise from persons who in the Court’s opinion were at least plausibly present and stopped in connection with the same incident as 140. With respect to each of these claims the Court awards $3,000, and increases 140 to $3,000.
248
300
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153

191

250

251 (in addition to the $2,000 ordered above)

253

The award in 254 is affirmed in the amount set by the Special Master.

Separately, the award in 151 is affirmed but not increased.

Payments may now be made to claimants to whom an award has been made. With this Order, the lawsuit and its settlement is concluded. The Court expresses its hope that the painful process that began in 2009 and concludes today will have an enduring and salutary effect on Minnesota’s law enforcement community and the citizens it serves.

IT IS SO ORDERED.

Dated: September 4, 2012

s/ Joan N. Ericksen JOAN N. ERICKSEN United States District Judge

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CASE 0:09-cv-01996-JNE-AJB Document 471-1 Filed 09/05/12 Page 1 of 6
Garcia v. Metro Gang Strike Force Civil No. 09-1996 (JNE/AJB)

Name
Aboubaker, Mohamed C.A. D.A. Alcantara Martinez, Sergio Alexander, John Anderson, Sharon Anderson, Todd Arnold, Arlan Atkins, James Avila-Tovalin, Maribel Badel, Farhan L.B. Bama (Miller), Tamou J.B. T.B. Blanks, Wayne Bojorques, Enrique Brooks, Robert Earl Brothers, Elizabeth Burnes, Anton Burns, Kesone B.C Carroll, Ester Champion, Aqueelah Champion, Odell and Deloris Champion, William Chevre, William Conrad, Maria Constantine, Michael Cotton, Benedda M.C. Cuevas-Lopez, Camerina Curley, Ethan Dahn, William Dancy, Marvin Davis #1, Tajuan Davis #2, Tajuan Davis #3, Tajuan

Docket No. Special Master's
Determination
109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146

Appeal 329 330 331 445 333 334
446
336 337
338 339 340

Page 1 of 6

CASE 0:09-cv-01996-JNE-AJB Document 471-1 Filed 09/05/12 Page 2 of 6
Garcia v. Metro Gang Strike Force Civil No. 09-1996 (JNE/AJB)

Name
DeValerio, Edward Allen Deziel, Jr., Michael C.D. N.D. Diaz, Ruben Dixon, Gerald Duffy, Raelyn Eason, Yobarri Elmore, Cynthia Elmore, Loneisha Emeka, Julie Erickson, Todd Estis, Derion Ewing II, Dwight Fair, LaQuan Ferguson, Jr., Calvin Finley, Travis D.F. R.F. G.F. A.G. A.G. A.G. J.G. Giles, David Godfrey, Bryan K.G. Gonzalez Salinas, Maura Gooden, Chyresse Graham, Daniel Green, Quentin Gurley, Koshesa Gustafson, Joseph Duane Gustafson, Joseph Haggins, DeJuan Hall, Beverly Hall, Jordan Hall, Martin

Docket No. Special Master's
Determination
147 148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184

Appeal 341
342 447 344 448
346 449
451 452 450
351

Page 2 of 6

CASE 0:09-cv-01996-JNE-AJB Document 471-1 Filed 09/05/12 Page 3 of 6
Garcia v. Metro Gang Strike Force Civil No. 09-1996 (JNE/AJB)

Name
Hammick, Sam Hill, Lakrisha Hjelmgren, Laurie Hoffman, Jeffrey N.H. K.H. P.H.N. Hunt, Jeremy A.J. D.J. Jeanetta, John Jewell, Raymond Jones, Henry Kelemen, Ilona B.K. M.K. D.K. T.K. Koger, Quonn Krengel, Alice Kujawa, Joseph Lark, Jay A.L. Lee, Kou Lewis, Christopher J.L. Lopez Ochoa, Yaneth Lopez, Michael Madrid, Peter Mancini III, Angelo D.M. Martin, Marandus Martinez, Jesus Mayweather, Jarmell McClain, Mario McClain, Sr., David McDaniel, Jeanette McElrath, Richard

Docket No. Special Master's
Determination
185 186 187 188 189 190 191 192 193 194 195 196 197 198 199 200 201 202 203 204 205 206 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 222

Appeal 352
453

Page 3 of 6

CASE 0:09-cv-01996-JNE-AJB Document 471-1 Filed 09/05/12 Page 4 of 6
Garcia v. Metro Gang Strike Force Civil No. 09-1996 (JNE/AJB)

Name
McFerson, Reggie McKinney, Robert V.M. Miles, Toya Millerbernd, Walter Mittelstadt, Daniel Mooney, Sr., Tyrone Moore, David Moutry, Gerald Muniz-Perez, Erick Lira-Munoz, Perla Neeland, Joseph Nevils, Marcus Nicks, Johnny Nunez Guevara, Veronica Olson, Michael Ortiz, Javier J.O. Ortiz, Raymundo S.O. Parapi, Lucia Perez, Joseph Perkins, Antoine Pierpont, Anthony Puckett, Prentice Ramirez, Efren J.A.R. J.R.R. Ramirez, Martha Ramirez-Cuevas, Adrian B.R.H. Ramirez-Jiminez, Norberto Reiter, Jeffrey Reyes, Ricardo Richardson, Jayda Richert, Jamie Richmond, Corby Rivera Garcia, Zenaido

Docket No. Special Master's
Determination
223 224 225 226 227 228 229 230 231 232 233 234 235 236 237 238 239 240 241 242 243 244 245 246 247 248 249 250 251 252 253 254 255 256 257 258 259 260

Appeal
355 356
454 353 455
359
360 456
457 363 377 364 365 458 459 366 460 461

Page 4 of 6

CASE 0:09-cv-01996-JNE-AJB Document 471-1 Filed 09/05/12 Page 5 of 6
Garcia v. Metro Gang Strike Force Civil No. 09-1996 (JNE/AJB)

Name
Robinson, Beatrice D.R. H.R. J.R. J.R. M.R. M.R. S.R. T.R. Y.R. C.R.D. M.R.V. Rockett, Irvin C.R. L.R. M.R. Romig, William Scarver, Antwan Schoen, Mark Seebold, Christopher Shaka, Ronald Simmons, Antoinette Simms, Deion Soman, Frank Stange, Mike Starfield, Scott Stroman, Titus Tagtmeir, Chad Thompson, Michelle Lee Thompson, Sanchez Tomos-El, Solomon Trudeau, Candace Trudo, Sean Turner, Fernando Turner, Steven A.U. N.U. A.V.

Docket No. Special Master's
Determination
261 262 263 264 265 266 267 268 269 270 271 272 273 274 275 276 277 278 279 280 281 282 283 284 285 286 287 288 289 290 291 292 293 294 295 296 297 298

Appeal 462 372 373 374 463 464 378 379 380
381

Page 5 of 6

CASE 0:09-cv-01996-JNE-AJB Document 471-1 Filed 09/05/12 Page 6 of 6
Garcia v. Metro Gang Strike Force Civil No. 09-1996 (JNE/AJB)

Name
Vang, Dao Villa, Illiana Wallace, Tiffany C.W. Watson, Mario Wells, Larry White, Maurice Whitson, Cynthia Wiggins, Alphonse Williams, Carlos Williams, Chiffon Williams, Gloria K.W. Williams, Willie D.W. Winter, William Wood, Rex Xiong, Chia Xiong, Kong Yang, Ellen H.Y. Yang, Jacob Yang, Tou Yang, Yong D.Y. P.Y.

Docket No. Special Master's
Determination
299 300 301 302 303 304 305 306 307 308 309 310 311 312 313 314 315 316 317 318 319 320 321 322 323 324

Appeal 382 383
465 466
467

Page 6 of 6

 
 CLOSED,CV,PHV,PROTO
U.S. District Court U.S. District of Minnesota (DMN) CIVIL DOCKET FOR CASE #: 0:09−cv−01996−JNE−AJB

Garcia et al v. Metro Gang Strike Force et al Assigned to: Judge Joan N. Ericksen Referred to: Chief Mag. Judge Arthur J. Boylan Cause: 28:1983 Civil Rights
Special Master
Mark W. Gehan

Date Filed: 07/30/2009 Date Terminated: 12/16/2010 Jury Demand: Both Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question
represented by Mark W Gehan Collins Buckley Sauntry & Haugh PLLP 332 Minnesota St Ste W−1100 St Paul, MN 55101 Ramsey 651−227−0611 Fax: 651−227−0758 Email: mgehan@cbsh.net LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Zelaido Rivera Garcia

represented by Alejandro "Alex&quot Alvarez The Alvarez Law Firm 355 Palermo Ave Coral Gables, FL 33134 305−444−7675 Fax: 305−444−0075 Email: alex@integrityforjustice.com (Inactive) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Charles S Zimmerman Zimmerman Reed, LLP 1100 IDS Center 80 South 8th St Minneapolis, MN 55402 612−341−0400 Email: charles.zimmerman@zimmreed.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

David M Cialkowski Zimmerman Reed, PLLP 1100 IDS Center 80 South Eighth Street Minneapolis, MN 55402 612−341−0400 Fax: 612−341−0844 Email: david.cialkowski@zimmreed.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

J Gordon Rudd , Jr Zimmerman Reed, PLLP 1100 IDS Center 80 South Eighth Street Minneapolis, MN 55402 612−341−0400

Plaintiff Maura Gonzalez Salinas

Fax: 612−341−0844 Email: gordon.rudd@zimmreed.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jason P Johnston Zimmerman Reed, LLP 1100 IDS Center 80 South 8th St. Minneapolis, MN 55402 612−341−0400 Fax: 612−341−0844 Email: Jason.Johnston@zimmreed.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Phillip F Fishman Phillip Fishman Law Office 10 South 5th Street Suite 1005 Minneapolis, MN 55402 612−722−0276 Email: phil@pfflegal.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper Robert R. Hopper & Associates 333 South 7th Street Suite 2450 Minneapolis, MN 55402 612−455−2199 Email: robert.hopper@robertrhopper.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Elizabeth A Peterson Zimmerman Reed, PLLP 1100 IDS Center 80 South Eighth Street Minneapolis, MN 55402 612−341−0400 Fax: 612−341−0844 Email: elizabeth.peterson@zimmreed.com TERMINATED: 11/13/2012 ATTORNEY TO BE NOTICED
Leonard J Schweich Jardine Logan & O'Brien, PLLP 8519 Eagle Point Blvd Ste 100 Lake Elmo, MN 55042 651−290−6500 Fax: 651−223−5070 Email: lschweich@jlolaw.com TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Alejandro "Alex&quot Alvarez (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Charles S Zimmerman

Plaintiff Adrian Ramirez−Cuevas

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
David M Cialkowski (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
J Gordon Rudd , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jason P Johnston (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Phillip F Fishman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Elizabeth A Peterson (See above for address) TERMINATED: 11/13/2012 ATTORNEY TO BE NOTICED
represented by Alejandro "Alex&quot Alvarez (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Charles S Zimmerman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
David M Cialkowski (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
J Gordon Rudd , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jason P Johnston (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Phillip F Fishman (See above for address) LEAD ATTORNEY

Plaintiff Camerina Cuevas Lopez
Plaintiff Kathleen Yankovic

ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Elizabeth A Peterson (See above for address) TERMINATED: 11/13/2012 ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Alejandro "Alex&quot Alvarez (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Charles S Zimmerman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
David M Cialkowski (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
J Gordon Rudd , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jason P Johnston (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Phillip F Fishman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Elizabeth A Peterson (See above for address) TERMINATED: 11/13/2012 ATTORNEY TO BE NOTICED
represented by Alejandro "Alex&quot Alvarez (See above for address) LEAD ATTORNEY PRO HAC VICE

Plaintiff John Yankovic

ATTORNEY TO BE NOTICED
Charles S Zimmerman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
David M Cialkowski (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
J Gordon Rudd , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Phillip F Fishman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Elizabeth A Peterson (See above for address) TERMINATED: 11/13/2012 ATTORNEY TO BE NOTICED
represented by Alejandro "Alex&quot Alvarez (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Charles S Zimmerman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
David M Cialkowski (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
J Gordon Rudd , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Phillip F Fishman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant Metro Gang Strike Force
Defendant Ron Ryan former Metro Gang Strike Force Commander

Elizabeth A Peterson (See above for address) TERMINATED: 11/13/2012 ATTORNEY TO BE NOTICED
represented by Adine S Momoh Stinson Leonard Street LLP 150 S 5th St Ste 2300 Mpls, MN 55402 612−335−1880 Fax: 612−335−1657 Email: adine.momoh@stinson.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Joseph E Flynn Jardine Logan & O'Brien PLLP 8519 Eagle Point Blvd Ste 100 Lake Elmo, MN 55042 651−290−6500 Fax: 651−223−5070 Email: jflynn@jlolaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
William L Greene Stinson Leonard Street LLP 150 S 5th St Ste 2300 Mpls, MN 55402 612−335−1568 Fax: 612−335−1657 Email: william.greene@stinson.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED

Defendant Doe Officers 1−34, individually and in their official capacities
Defendant Other Unknown Doe Officers
Defendant Metro Gang Strike Force Advisory Board
Defendant Manila "Bud" Shaver Chief of the West St. Paul Police Department

represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010

Defendant Ken Schilling Inspector at the Hennepin County Sheriff's Office
Defendant Dave Bellows Chief Deputy of the Dakota County Sheriff's Office
Defendant Bob Flectcher Sheriff of the Ramsey County Sheriff's Office
Defendant John Harrington Chief of the St. Paul Police Department

ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper

Defendant Rob Allen Deputy Chief of the Minneapolis Police Department
Defendant Bill Hutton Sheriff of the Washington County Sheriff's Office
Defendant Dave Thomalla Chief of the Maplewood Police Department
Defendant Dave Pecchla Chief of the Lino Lakes Police Department

(See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Dave Indrehus Cheif of the Metro Transit Police Department
Defendant Michael Davis Chief of the Brooklyn Park Police Department
Defendant Barry Fritz Captain of the Richfield Police Department
Defendant City of West St. Paul a municipal corporation

Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address)

Defendant Hennepin County a direct political subdivision of the state
Defendant Dakota County a direct political subdivision of the state
Defendant Ramsey County a direct political subdivision of the state
Defendant City of St. Paul a municipal corporation

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant City of Minneapolis a municipal corporation
Defendant Washington County a direct political subdivision of the state
Defendant City of Maplewood a municipal corporation
Defendant City of Lino Lakes a municipal corporation

Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY

Defendant City of Brooklyn Park a municipal corporation
Defendant Metropolitan Council
Defendant City of Richfield a municipal corporation
Date Filed # Docket Text

ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED
represented by Joseph E Flynn (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Leonard J Schweich (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert R Hopper (See above for address) TERMINATED: 08/26/2010 ATTORNEY TO BE NOTICED

07/30/2009
07/30/2009 09/23/2009
09/24/2009 09/24/2009 09/28/2009 09/28/2009 10/05/2009 10/06/2009 10/06/2009 10/06/2009

1 COMPLAINT against Rob Allen, Dave Bellows, Michael Davis, Doe Officers, Bob Flectcher, Barry Fritz, John Harrington, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Other Unknown Doe Officers, Dave Pecchla, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla ( Filing fee $ 350 receipt number 4036493.) assigned to Judge Joan N. Ericksen per Civil Rights list and referred to Magistrate Judge Susan R. Nelson, filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Kathleen Yankovic, Camerina Cuevas Lopez, John Yankovic. (Attachments: # 1 Civil Cover Sheet) (RLR) (Entered: 07/31/2009)
Summons Issued as to Rob Allen, Dave Bellows, Michael Davis, Doe Officers, Bob Flectcher, Barry Fritz, John Harrington, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Other Unknown Doe Officers, Dave Pecchla, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla. (RLR) (Entered: 07/31/2009)
2 AMENDED COMPLAINT against CITY OF WEST ST. PAUL, HENNEPIN COUNTY, DAKOTA COUNTY, RAMSEY COUNTY, CITY OF ST. PAUL, CITY OF MINNEAPOLIS, WASHINGTON COUNTY, CITY OF MAPLEWOOD, CITY OF LINO LAKES, CITY OF BROOKLYN PARK, CITY OF RICHFIELD against Rob Allen, Dave Bellows, Michael Davis, Doe Officers, Bob Flectcher, Barry Fritz, John Harrington, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Other Unknown Doe Officers, Dave Pecchla, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Kathleen Yankovic, Camerina Cuevas Lopez, John Yankovic. (Attachments: # 1 Exhibit(s) Notice of Claim Against Municipalities) (Hopper, Robert) (Entered: 09/23/2009)
Amended Summons Issued as to Rob Allen, Dave Bellows, Michael Davis, Doe Officers, Bob Flectcher, Barry Fritz, John Harrington, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Other Unknown Doe Officers, Dave Pecchla, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla. (JME) (Entered: 09/24/2009)
Amended Summons Also Issued to City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of St. Paul, City of West St. Paul, Dakota County, Hennepin County, Metropolitan Council, Ramsey County, Washington County. (JME) (Entered: 09/24/2009)
3 MOTION for Admission Pro Hac Vice for Alex Alvarez by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, John Yankovic, Kathleen Yankovic. (Hopper, Robert) (Entered: 09/28/2009)
TEXT ONLY ENTRY − ORDER granting 3 Motion for Admission Pro Hac Vice of Attorney Alejandro "Alex" Alvarez for plaintiffs. Fee paid; receipt number 4−038031. Approved by Magistrate Judge Susan R. Nelson on 9/28/09. (MMC) (Entered: 10/05/2009)
4 ORDER OF RECUSAL. Magistrate Judge Susan R. Nelson recused. Case reassigned to Magistrate Judge Arthur J. Boylan for all further proceedings. NOTE: the new case number is 09cv1996 JNE/AJB. Please use this case number for all subsequent pleadings. Signed by Magistrate Judge Susan R. Nelson on 10/5/09. (JME) (Entered: 10/05/2009)
5 Minute Entry for proceedings held before Magistrate Judge Arthur J. Boylan: Heard arguments on Plaintiffs' Motion for Emergency Rule 23(d)(1)(B) Protection of Putative Class Members. [No Docket Entry At Time of Hearing.] Motion taken under advisement. (Tape #3C) (kt) (Entered: 10/06/2009)
7 MOTION for emergency rule 23(d)(1)(B) protection of putative class members, by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, John Yankovic, Kathleen Yankovic. (jam) (Entered: 10/08/2009)
8 NOTICE OF HEARING ON MOTION 7 MOTION for emergency rule 23(d)(1)(B) protection of putative class members, : Motion Hearing set for 10/6/2009 10:30 AM in Judge's Chambers, Suite 334 (STP) before Magistrate Judge Arthur J. Boylan. (jam) (Entered: 10/08/2009)

10/06/2009 10/06/2009 10/07/2009 10/28/2009 11/03/2009
11/03/2009
11/19/2009 11/19/2009 11/19/2009 11/19/2009 11/19/2009 11/19/2009

9 MEMORANDUM in Support re 7 MOTION for emergency rule 23(d)(1)(B) protection of putative class members, filed by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, John Yankovic, Kathleen Yankovic. (Attachments: # 1 LR7.1 Word Count Compliance Certificate)(jam) (Entered: 10/08/2009)
10 AFFIDAVIT of David Hopper by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, John Yankovic, Kathleen Yankovic. (Attachments: # 1 Exhibit(s) 1 − 6)(jam) (Entered: 10/08/2009)
6 **TEXT ONLY ENTRY** Verbal ORDER ruling on Plaintiffs Motion for Emergency Rule 23(d)(1)(B) Protection of Putative Class Members heard on October 6, 2009, [Docket No. 5] is hereby Moot. Signed by Magistrate Judge Arthur J. Boylan on 10/07/2009. (kat) (Entered: 10/07/2009)
11 Minute Entry for proceedings held before Magistrate Judge Arthur J. Boylan: Status Conference held on 10/28/2009. (kt) (Entered: 10/28/2009)
12 NOTICE of Appearance by Joseph E Flynn on behalf of Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Doe Officers, Bob Flectcher, Barry Fritz, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Other Unknown Doe Officers, Dave Pecchla, Ramsey County, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County. (Attachments: # 1 Certificate of Service)(Flynn, Joseph) (Entered: 11/03/2009)
13 NOTICE of Appearance by Leonard J Schweich on behalf of Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Doe Officers, Bob Flectcher, Barry Fritz, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Other Unknown Doe Officers, Dave Pecchla, Ramsey County, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County. (Attachments: # 1 Certificate of Service)(Schweich, Leonard) (Entered: 11/03/2009)
14 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. City of West St. Paul waiver sent on 10/16/2009, answer due 12/15/2009. (Hopper, Robert) (Entered: 11/19/2009)
15 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Hennepin County waiver sent on 10/21/2009, answer due 12/21/2009. (Hopper, Robert) (Entered: 11/19/2009)
16 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Dakota County waiver sent on 10/22/2009, answer due 12/21/2009. (Hopper, Robert) (Entered: 11/19/2009)
17 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Ramsey County waiver sent on 10/16/2009, answer due 12/15/2009. (Hopper, Robert) (Entered: 11/19/2009)
18 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. City of St. Paul waiver sent on 10/20/2009, answer due 12/21/2009. (Hopper, Robert) (Entered: 11/19/2009)
19 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. City of Minneapolis waiver sent on 10/28/2009, answer due 12/28/2009. (Hopper, Robert) (Entered: 11/19/2009)

11/19/2009 11/19/2009 11/19/2009 11/19/2009 11/19/2009 11/19/2009 11/19/2009 11/19/2009 11/20/2009 11/20/2009 11/20/2009 11/20/2009 11/20/2009 11/20/2009

20 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Washington County waiver sent on 10/21/2009, answer due 12/21/2009. (Hopper, Robert) (Entered: 11/19/2009)
21 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. City of Maplewood waiver sent on 10/15/2009, answer due 12/14/2009. (Hopper, Robert) (Entered: 11/19/2009)
22 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. City of Lino Lakes waiver sent on 10/16/2009, answer due 12/15/2009. (Hopper, Robert) (Entered: 11/19/2009)
23 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. City of Brooklyn Park waiver sent on 11/12/2009, answer due 1/11/2010. (Hopper, Robert) (Entered: 11/19/2009)
24 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. City of Richfield waiver sent on 10/15/2009, answer due 12/14/2009. (Hopper, Robert) (Entered: 11/19/2009)
25 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Metropolitan Council waiver sent on 10/20/2009, answer due 12/21/2009. (Hopper, Robert) (Entered: 11/19/2009)
26 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Manila "Bud" Shaver waiver sent on 10/21/2009, answer due 12/21/2009. (Hopper, Robert) (Entered: 11/19/2009)
27 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Ken Schilling waiver sent on 10/19/2009, answer due 12/18/2009. (Hopper, Robert) (Entered: 11/19/2009)
28 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Dave Bellows waiver sent on 10/21/2009, answer due 12/21/2009. (Hopper, Robert) (Entered: 11/20/2009)
29 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. John Harrington waiver sent on 10/20/2009, answer due 12/21/2009. (Hopper, Robert) (Entered: 11/20/2009)
30 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Rob Allen waiver sent on 11/12/2009, answer due 1/11/2010. (Hopper, Robert) (Entered: 11/20/2009)
31 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Bill Hutton waiver sent on 10/21/2009, answer due 12/21/2009. (Hopper, Robert) (Entered: 11/20/2009)
32 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Dave Thomalla waiver sent on 10/28/2009, answer due 12/28/2009. (Hopper, Robert) (Entered: 11/20/2009)
33 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Dave Pecchla waiver sent on 11/4/2009, answer due

11/20/2009 11/20/2009 11/20/2009 11/23/2009 11/30/2009 12/02/2009 12/02/2009 12/14/2009
01/07/2010
01/11/2010 01/13/2010

1/4/2010. (Hopper, Robert) (Entered: 11/20/2009)
34 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Dave Indrehus waiver sent on 10/19/2009, answer due 12/18/2009. (Hopper, Robert) (Entered: 11/20/2009)
35 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Michael Davis waiver sent on 10/29/2009, answer due 12/28/2009. (Hopper, Robert) (Entered: 11/20/2009)
36 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Barry Fritz waiver sent on 10/21/2009, answer due 12/21/2009. (Hopper, Robert) (Entered: 11/20/2009)
37 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Bob Flectcher waiver sent on 11/16/2009, answer due 1/15/2010. (Hopper, Robert) (Entered: 11/23/2009)
38 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Ron Ryan waiver sent on 11/12/2009, answer due 1/11/2010. (Hopper, Robert) (Entered: 11/30/2009)
39 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Metro Gang Strike Force waiver sent on 11/23/2009, answer due 1/22/2010. (Hopper, Robert) (Entered: 12/02/2009)
40 WAIVER OF SERVICE Returned Executed filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Kathleen Yankovic, John Yankovic, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. Metro Gang Strike Force Advisory Board waiver sent on 11/23/2009, answer due 1/22/2010. (Hopper, Robert) (Entered: 12/02/2009)
41 JOINT ANSWER to Amended Complaint by Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of Richfield, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Bob Flectcher, Barry Fritz, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Dave Pecchla, Ramsey County, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County. (Attachments: # 1 Certificate of Service) (Flynn, Joseph) (Entered: 12/14/2009)
42 STIPULATION FOR PROTECTIVE ORDER by Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of Richfield, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Bob Flectcher, Barry Fritz, Zelaido Rivera Garcia, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Camerina Cuevas Lopez, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Dave Pecchla, Adrian Ramirez−Cuevas, Ramsey County, Ron Ryan, Maura Gonzalez Salinas, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County, John Yankovic, Kathleen Yankovic. (Attachments: # 1 Certificate of Service)(Flynn, Joseph) (Entered: 01/07/2010)
43 PROTECTIVE ORDER. Signed by Magistrate Judge Arthur J. Boylan on 1/11/10. (kt) (Entered: 01/11/2010)
44 STIPULATION REGARDING DISCLOSURE OF "HOTLINE" CLAIMANT INFORMATION by Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of Richfield, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Doe Officers, Bob Flectcher, Barry Fritz, Zelaido Rivera Garcia, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Other Unknown Doe Officers, Dave Pecchla, Adrian

01/15/2010 01/27/2010 02/24/2010 02/25/2010 03/23/2010 03/24/2010 03/29/2010 04/23/2010 05/06/2010 08/25/2010
08/25/2010
08/25/2010
08/25/2010

Ramirez−Cuevas, Ramsey County, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County. (Attachments: # 1 Certificate of Service)(Schweich, Leonard) (Entered: 01/13/2010)
45 ORDER re 44 STIPULATION. Signed by Magistrate Judge Arthur J. Boylan on 1/14/10. (kt) (Entered: 01/15/2010)
46 Minute Entry for proceedings held before Magistrate Judge Arthur J. Boylan: Settlement Conference held on 1/27/2010. No settlement reached. Settlement conference continued to 2/24/10 at 9:15 a.m. (kt) (Entered: 01/28/2010)
47 Minute Entry for proceedings held before Magistrate Judge Arthur J. Boylan: Settlement Conference held on 2/24/2010. No settlement reached. Settlement negotiations are continued to March 24, 2010, at 10:00 a.m. (LMB) Modified text on 4/29/2010 (JME). (Entered: 02/25/2010)
48 ORDER/NOTICE of Settlement Conference set for 3/24/2010 10:00 AM in Judge's Chambers, Suite 334 (STP) before Magistrate Judge Arthur J. Boylan. Signed by Magistrate Judge Arthur J. Boylan on 2/25/10. (kt) (Entered: 02/25/2010)
49 Minute Entry for proceedings held before Magistrate Judge Arthur J. Boylan: Status Conference held on 3/23/2010. The settlement conference currently scheduled for 3/24/10 will be rescheduled. (kt) (Entered: 03/23/2010)
50 Minute Entry for proceedings held before Magistrate Judge Arthur J. Boylan: Status Conference held on 3/24/2010. (kt) (Entered: 03/24/2010)
51 AMENDED ORDER of Settlement Conference set for 4/21/2010 08:00 AM before Magistrate Judge Arthur J. Boylan. Signed by Magistrate Judge Arthur J. Boylan on 3/29/10. (kt) (Entered: 03/29/2010)
**TEXT ENTRY ONLY** NOTICE to Attorneys − The settlement conference on April 21, 2010, was stricken from the Court's calendar and has been continued to May 6, 2010, at 9:00 a.m. (kat) (Entered: 04/23/2010)
52 Minute Entry for proceedings held before Magistrate Judge Arthur J. Boylan: Status Conference held on 5/6/2010. (kt) (Entered: 05/07/2010)
53 Joint MOTION for Approval of Settlement Preliminary Approval of Settlement, Conditional Certification of Settlement Class, Approval of Class Counsel and Approval of Notice to Be Furnished to Settlement Class by Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of Richfield, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Doe Officers, Bob Flectcher, Barry Fritz, Zelaido Rivera Garcia, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Camerina Cuevas Lopez, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Other Unknown Doe Officers, Dave Pecchla, Adrian Ramirez−Cuevas, Ramsey County, Ron Ryan, Maura Gonzalez Salinas, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County. (Attachments: # 1 Certificate of Service)(Hopper, Robert) (Entered: 08/25/2010)
54 NOTICE OF HEARING ON MOTION 53 Joint MOTION for Approval of Settlement Preliminary Approval of Settlement, Conditional Certification of Settlement Class, Approval of Class Counsel and Approval of Notice to Be Furnished to Settlement Class : Motion Hearing set for 9/24/2010 11:00 AM in Judge's Chambers 12W (MPLS) before Judge Joan N. Ericksen. (Attachments: # 1 Certificate of Service)(Hopper, Robert) (Entered: 08/25/2010)
55 MEMORANDUM in Support re 53 Joint MOTION for Approval of Settlement Preliminary Approval of Settlement, Conditional Certification of Settlement Class, Approval of Class Counsel and Approval of Notice to Be Furnished to Settlement Class filed by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Certificate of Service)(Hopper, Robert) (Entered: 08/25/2010)
56 AFFIDAVIT of Robert R. Hopper in SUPPORT OF 53 Joint MOTION for Approval of Settlement Preliminary Approval of Settlement, Conditional Certification of Settlement Class, Approval of Class Counsel and Approval of Notice to Be Furnished

08/25/2010 08/25/2010
09/14/2010 10/06/2010 10/06/2010 10/26/2010 11/04/2010 11/04/2010 11/04/2010
11/04/2010
11/04/2010 11/04/2010

to Settlement Class filed by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) 1, # 2 Exhibit(s) 2, # 3 Exhibit(s) 3, # 4 Exhibit(s) 4, # 5 Exhibit(s) 5, # 6 Exhibit(s) 6, # 7 Exhibit(s) 7, # 8 Exhibit(s) 8, # 9 Certificate of Service)(Hopper, Robert) (Entered: 08/25/2010)
57 LR7.1 WORD COUNT COMPLIANCE CERTIFICATE by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas re 55 Memorandum in Support of Motion,. (Hopper, Robert) (Entered: 08/25/2010)
58 MEMORANDUM in Support re 53 Joint MOTION for Approval of Settlement Preliminary Approval of Settlement, Conditional Certification of Settlement Class, Approval of Class Counsel and Approval of Notice to Be Furnished to Settlement Class (DEFENDANTS') filed by Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of Richfield, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Bob Flectcher, Barry Fritz, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Dave Pecchla, Ramsey County, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County. (Attachments: # 1 LR7.1 Word Count Compliance Certificate)(Flynn, Joseph) (Entered: 08/25/2010)
59 ORDER PRELIMINARILY APPROVING SETTLEMENT AND APPROVING NOTICE TO CLASS MEMBERS. Signed by Judge Joan N. Ericksen on September 14, 2010. (slf) (Entered: 09/14/2010)
60 NOTICE of Proposed Class Action Settlement and Release of Claims (slf) (Entered: 10/06/2010)
61 PUBLICATION NOTICE OF PROPOSED CLASS ACTION SETTLEMENT AND RELEASE OF CLAIMS (slf) (Entered: 10/06/2010)
62 ORDER APPOINTING SPECIAL MASTER. Signed by Judge Joan N. Ericksen on October 26, 2010. (slf) (Entered: 10/26/2010)
63 MOTION for Approval of Settlement Final, MOTION to Certify Class Settlement, MOTION for Attorney Fees and Reimbursement of Litigation Expenses by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Hopper, Robert) (Entered: 11/04/2010)
64 NOTICE OF HEARING ON MOTION 63 MOTION for Approval of Settlement Final MOTION to Certify Class Settlement MOTION for Attorney Fees and Reimbursement of Litigation Expenses : Motion Hearing set for 12/16/2010 02:00 PM in Judge's Chambers 12W (MPLS) before Judge Joan N. Ericksen. (Hopper, Robert) (Entered: 11/04/2010)
65 MEMORANDUM by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas re 63 MOTION for Approval of Settlement Final MOTION to Certify Class Settlement MOTION for Attorney Fees and Reimbursement of Litigation Expenses filed by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 LR7.1 Word Count Compliance Certificate)(Hopper, Robert) (Entered: 11/04/2010)
66 AFFIDAVIT of Robert R. Hopper in SUPPORT OF 63 MOTION for Approval of Settlement Final MOTION to Certify Class Settlement MOTION for Attorney Fees and Reimbursement of Litigation Expenses filed by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) 1, # 2 Exhibit(s) 2, # 3 Exhibit(s) 3, # 4 Exhibit(s) 4, # 5 Exhibit(s) 5, # 6 Exhibit(s) 6, # 7 Exhibit(s) 7)(Hopper, Robert) (Entered: 11/04/2010)
67 AFFIDAVIT of Elizabeth A. Peterson in SUPPORT OF 63 MOTION for Approval of Settlement Final MOTION to Certify Class Settlement MOTION for Attorney Fees and Reimbursement of Litigation Expenses filed by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Dave Pecchla, Maura Gonzalez Salinas. (Hopper, Robert) (Entered: 11/04/2010)
68 DECLARATION OF MAILING AND PUBLICATION OF NOTICE re 63 MOTION for Approval of Settlement Final MOTION to Certify Class Settlement MOTION for

11/04/2010 11/19/2010 11/19/2010 11/19/2010 11/23/2010
11/23/2010
11/23/2010 12/15/2010 12/16/2010

Attorney Fees and Reimbursement of Litigation Expenses filed by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Hopper, Robert) Modified on 11/5/2010 (kt). (Entered: 11/04/2010)
69 CERTIFICATE OF SERVICE by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas re 64 Notice of Hearing on Motion, 66 Affidavit in Support of Motion, 63 MOTION for Approval of Settlement Final MOTION to Certify Class Settlement MOTION for Attorney Fees and Reimbursement of Litigation Expenses, 67 Affidavit in Support of Motion, 65 Memorandum, 68 Declaration in Support, (Hopper, Robert) (Entered: 11/04/2010)
70 Supplemental AFFIDAVIT of Elizabeth A. Peterson in SUPPORT OF 63 MOTION for Approval of Settlement Final MOTION to Certify Class Settlement MOTION for Attorney Fees and Reimbursement of Litigation Expenses filed by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) Certificate of Translation, # 2 Exhibit(s) Certificate of Accuracy)(Peterson, Elizabeth) (Entered: 11/19/2010)
71 Supplemental Declaration of Jonathan Reid of Mailing and Publication of Notice in Support of 63 MOTION for Approval of Settlement Final MOTION to Certify Class Settlement MOTION for Attorney Fees and Reimbursement of Litigation Expenses filed by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Peterson, Elizabeth) Modified on 11/22/2010 (kt). (Entered: 11/19/2010)
72 CERTIFICATE OF SERVICE by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas re 70 Affidavit in Support of Motion, 71 Declaration in Support, (Peterson, Elizabeth) (Entered: 11/19/2010)
73 RESPONSE in Support re 63 MOTION for Approval of Settlement Final MOTION to Certify Class Settlement MOTION for Attorney Fees and Reimbursement of Litigation Expenses filed by Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of Richfield, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Bob Flectcher, Barry Fritz, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Dave Pecchla, Ramsey County, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County. (Attachments: # 1 LR7.1 Word Count Compliance Certificate)(Flynn, Joseph) (Entered: 11/23/2010)
74 Declaration of LEONARD J. SCHWEICH in Support re 63 MOTION for Approval of Settlement Final MOTION to Certify Class Settlement MOTION for Attorney Fees and Reimbursement of Litigation Expenses filed by Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of Richfield, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Bob Flectcher, Barry Fritz, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Dave Pecchla, Ramsey County, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County. (Attachments: # 1 Exhibit(s) Ex. A − 8−30−10 Letter to US Dept of Justice & MN Att General, # 2 Exhibit(s) Ex B. − Aff of Service)(Flynn, Joseph) Modified on 11/24/2010 (kt). (Entered: 11/23/2010)
75 CERTIFICATE OF SERVICE by Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of Richfield, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Bob Flectcher, Barry Fritz, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Dave Pecchla, Ramsey County, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County re 74 Declaration in Support,, 73 Response in Support of Motion,,, (Flynn, Joseph) (Entered: 11/23/2010)
76 REPORT of Administrator regarding Opt Outs by Zelaido Rivera Garcia. (Attachments: # 1 Exhibit(s) A)(Peterson, Elizabeth) (Entered: 12/15/2010)
77 SETTLEMENT ORDER AND FINAL JUDGMENT(Written Opinion). Signed by Judge Joan N. Ericksen on December 16, 2010. (slf) (Entered: 12/16/2010)

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78 ORDER FOR CLASS COUNSEL'S ATTORNEYS' FEES AND REIMBURSEMENT OF LITIGATION EXPENSES. Signed by Judge Joan N. Ericksen on December 16, 2010. (slf) (Entered: 12/16/2010)
79 Minute Entry for proceedings held before Judge Joan N. Ericksen: Fairness Hearing (Court Reporter Maria Weinbeck) (slf) (Entered: 12/17/2010)
80 ORDER (Written Opinion). Signed by Judge Joan N. Ericksen on March 30, 2011. (slf) (Entered: 03/30/2011)
81 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES. Signed by Judge Joan N. Ericksen on May 17, 2011. (slf) (Entered: 05/17/2011)
82 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas. (Attachments: # 1 Exhibit(s))(Cialkowski, David) (Entered: 05/25/2011)
83 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s))(Cialkowski, David) (Entered: 05/25/2011)
84 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES. Signed by Judge Joan N. Ericksen on June 1, 2011. (slf) (Entered: 06/01/2011)
85 ORDER: WHEREAS, the Court has received a letter dated July 26, 2011, addressed to the Honorable Joan N. Ericksen from Phillip F. Fishman, counsel for Ms. Maura Gonzalez Salinas, relative to her claims against the Metro Gang Strike Force. In particular, the correspondence is a request by Mr. Fishman on behalf of his client for U Certification pursuant to 8 U.S.C. 1101(a)(15)(U), and WHEREAS, the undersigned Magistrate Judge had previously considered a request on behalf of Ms. Gonzalez Salinas for U Certification and had denied the same, and WHEREAS, the Court having reviewed the Affidavit of Maura Gonzalez Salinas submitted in support of U Certification and having considered the same, hereby denies the request for U Certification. Signed by Chief Mag. Judge Arthur J. Boylan on 08/05/2011. (lmb) (Entered: 08/05/2011)
86 AFFIDAVIT of David M. Cialkowski re Request for Disbursement from Settlement Fund Escrow Account by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s))(Cialkowski, David) (Entered: 08/05/2011)
87 ORDER re 86 Affidavit, filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on August 8, 2011. (slf) (Entered: 08/09/2011)
88 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) US Bank statement)(Cialkowski, David) (Entered: 09/30/2011)
89 ORDER re 88 Affidavit filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on October 7, 2011. (slf) (Entered: 10/07/2011)
90 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) 10/20/11 Invoice of Collins, Buckley, Sauntry & Haugh)(Cialkowski, David) (Entered: 11/09/2011)
91 ORDER re 90 Affidavit filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on November 14, 2011. (slf)cc: K.U., USDC Financial Unit. Modified on 11/15/2011 (lmb). (Entered: 11/14/2011)
92 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) 1)(Cialkowski, David) (Entered: 01/04/2012)
93 ORDER re 92 Affidavit filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen

02/06/2012
02/13/2012
03/22/2012
03/26/2012 04/27/2012 04/30/2012 06/01/2012 06/01/2012 06/01/2012 06/04/2012 06/19/2012
06/20/2012 06/20/2012 06/21/2012

on January 5, 2012. (slf) (Entered: 01/05/2012)
94 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) 1 − January 16, 2012, invoice of Collins, Buckley, Sauntry & Haugh, P.L.L.P.)(Cialkowski, David) (Entered: 02/06/2012)
95 ORDER re 94 Affidavit, filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on February 13, 2012. (slf) cc: USDC Financial Unit. Modified on 2/13/2012 (lmb). (Entered: 02/13/2012)
96 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) 1: March 16, 2012, invoice). (Cialkowski, David) Modified text on 3/22/2012 (lmb). (Entered: 03/22/2012)
97 ORDER re 96 Affidavit filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on March 26, 2012. (slf) (Entered: 03/26/2012)
98 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) 1)(Cialkowski, David) (Entered: 04/27/2012)
99 ORDER re 98 Affidavit filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on April 30, 2012. (slf) (Entered: 04/30/2012)
100 NOTICE of Appearance by Jason P Johnston on behalf of Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Johnston, Jason) (Entered: 06/01/2012)
101 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Cialkowski, David) (Entered: 06/01/2012)
102 AFFIDAVIT of Jason P. Johnston by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Johnston, Jason) (Entered: 06/01/2012)
103 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES re [101 and 102]. Signed by Judge Joan N. Ericksen on June 4, 2012. (slf) (Entered: 06/04/2012)
104 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) Collins, Buckley, Sauntry & Haugh invoice, # 2 Exhibit(s) Lurie Besikof Lapidus invoice)(Cialkowski, David) (Entered: 06/19/2012)
105 ORDER re 104 Affidavit, filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on June 20, 2012. (slf) (Entered: 06/20/2012)
106 STIPULATION Regarding the Appeals Notification Protocol by all parties. (Cialkowski, David) Modified filers on 6/21/2012 (lmb). (Entered: 06/20/2012)
107 ORDER re 106 Stipulation filed by Dave Indrehus, Metropolitan Council, City of Maplewood, Dave Pecchla, Ken Schilling, Bill Hutton, Doe Officers, John Harrington, Metro Gang Strike Force Advisory Board, City of Brooklyn Park, Dakota County, Ron Ryan, Ramsey County, Bob Flectcher, City of West St. Paul, Mark W. Gehan, Other Unknown Doe Officers, Zelaido Rivera Garcia, Dave Bellows, Manila "Bud" Shaver, Barry Fritz, City of Richfield, Michael Davis, Kathleen Yankovic, City of Lino Lakes, Camerina Cuevas Lopez, Metro Gang Strike Force, Hennepin County, Washington County, City of Minneapolis, Adrian Ramirez−Cuevas, John Yankovic, Dave Thomalla, Maura Gonzalez Salinas, Rob Allen, City of St. Paul. Signed by Judge Joan N. Ericksen on June 21, 2012. (slf) (Entered: 06/21/2012)

07/06/2012
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108 LETTER TO DISTRICT JUDGE re: determinations of the claims by Zelaido Rivera Garcia. (JME) Document QC'd by RMS. Modified on 7/10/2012 (RMS). (Entered: 07/06/2012)
109 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 110 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 111 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 112 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 113 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 114 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 115 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 116 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 117 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 118 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 119 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 120 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 121 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 122 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 123 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 124 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 125 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 126 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 127 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 128 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 129 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 130 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 131 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 132 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 133 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 134 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 135 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 136 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 137 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 138 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 139 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 140 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 141 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 142 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 143 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012)

07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012

144 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 145 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 146 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 147 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 148 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 149 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 150 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 151 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 152 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 153 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 154 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 155 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 156 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 157 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 158 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 159 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 160 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 161 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 162 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 163 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 164 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 165 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 166 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 167 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 168 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 169 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 170 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 171 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 172 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 173 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 174 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 175 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 176 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 177 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 178 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 179 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 180 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012)

07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012

181 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 182 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 183 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 184 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 185 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 186 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 187 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 188 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 189 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 190 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 191 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 192 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 193 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 194 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 195 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 196 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 197 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 198 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 199 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 200 SPECIAL MASTER REPORT Determinaton. (Gehan, Mark) (Entered: 07/23/2012) 201 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 202 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 203 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 204 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 205 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 206 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 207 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 208 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 209 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 210 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 211 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 212 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 213 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 214 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 215 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 216 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 217 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012)

07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/23/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012

218 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 219 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 220 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 221 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 222 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 223 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 224 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 225 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 226 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 227 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 228 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 229 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 230 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 231 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 232 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 233 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 234 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 235 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 236 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 237 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 238 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 239 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 240 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 241 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 242 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 243 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 244 SPECIAL MASTER REPORT Determinations. (Gehan, Mark) (Entered: 07/23/2012) 245 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 246 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/23/2012) 247 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 248 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 249 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 250 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 251 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 252 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 253 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 254 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012)

07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012

255 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 256 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 257 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 258 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 259 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 260 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 261 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 262 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 263 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 264 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 265 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 266 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 267 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 268 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 269 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 270 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 271 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 272 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 273 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 274 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 275 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 276 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 277 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 278 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 279 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 280 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 281 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 282 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 283 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 284 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 285 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 286 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 287 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 288 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 289 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 290 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 291 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012)

07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/24/2012 07/26/2012

292 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 293 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 294 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 295 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 296 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 297 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 298 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 299 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 300 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 301 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 302 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 303 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 304 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 305 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 306 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 307 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 308 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 309 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 310 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 311 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 312 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 313 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 314 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 315 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 316 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 317 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 318 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 319 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 320 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 321 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 322 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 323 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 324 SPECIAL MASTER REPORT Determination. (Gehan, Mark) (Entered: 07/24/2012) 325 NOTICE by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian
Ramirez−Cuevas, Maura Gonzalez Salinas of Appeal of the Special Master's Determinations (Redacted) (Attachments: # 1 DOCUMENT FILED IN ERROR: WILL REFILE. Placeholder for Notice of Appeals of the Special Master's Determinations (Un−Redacted))(Cialkowski, David) Modified on 7/26/2012 (kt). (Entered: 07/26/2012)

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08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012

326 AFFIDAVIT of Jason P. Johnston in Support re 325 Notice (Other). (Cialkowski, David) Modified text on 7/26/2012 (lmb). (Entered: 07/26/2012)
327 CERTIFICATE OF SERVICE by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas re 325 Notice (Other), Notice of Appeals of the Special Master's Determinations (Un−Redacted) (Cialkowski, David) (Entered: 07/26/2012)
328 EXHIBIT re 325 Notice (Other), Placeholder for Notice of Appeals of the Special Master's Determinations (Un−Redacted) by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Cialkowski, David) DOCUMENT RECEIVED IN CLERK'S OFFICE 7/26/12 Modified on 7/27/2012 (jam). (Entered: 07/26/2012)
329 OBJECTION re 110 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
330 OBJECTION re 111 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
331 OBJECTION re 113 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
332 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 114 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Attachments: # 1 Objection − Part 2, # 2 Objections − Part 3). (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
333 OBJECTION re 117 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
334 OBJECTION re 119 Status Report filed by Maura Gonzalez Salinas, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez, Zelaido Rivera Garcia. (Cialkowski, David) (Entered: 08/03/2012)
335 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 127 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
336 OBJECTION re 137 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
337 OBJECTION re 140 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
338 OBJECTION re 144 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
339 OBJECTION re 145 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
340 OBJECTION re 146 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
341 OBJECTION re 147 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)

08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012

342 OBJECTION re 151 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
343 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 152 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified on 8/7/2012 (lmb). (Entered: 08/03/2012)
344 OBJECTION re 153 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
345 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 154 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
346 OBJECTION re 158 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
347 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 161 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
348 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 175 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
349 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 173 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
350 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 174 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
351 OBJECTION re 181 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
352 OBJECTION re 191 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
353 OBJECTION re 233 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
354 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 218 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
355 OBJECTION re 225 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
356 OBJECTION re 227 Status Report filed by Maura Gonzalez Salinas, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez, Zelaido Rivera Garcia. (Cialkowski, David) (Entered: 08/03/2012)
357 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 232 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas,

08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012

Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
358 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 235 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
359 OBJECTION re 238 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
360 OBJECTION re 241 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
361 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 243 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
362 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 247 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
363 OBJECTION re 248 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
364 OBJECTION re 250 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
365 OBJECTION re 251 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
366 OBJECTION re 254 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
367 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 252 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Attachments: # 1 Objection − Part 2, # 2 Objection − Part 3)(Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
368 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 253 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
369 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 255 Status Report filed by Maura Gonzalez Salinas, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez, Zelaido Rivera Garcia. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
370 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 257 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
371 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 261 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)

08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/03/2012 08/06/2012

372 OBJECTION re 264 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
373 OBJECTION re 265 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
374 OBJECTION re 268 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
375 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 271 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
376 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 274 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
377 OBJECTION re 249 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
378 OBJECTION re 275 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
379 OBJECTION re 276 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
380 OBJECTION re 277 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
381 OBJECTION re 298 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
382 OBJECTION re 300 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
383 OBJECTION re 301 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/03/2012)
384 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 307 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
385 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 308 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
386 DOCUMENT FILED IN ERROR−WILL REFILE. OBJECTION re 313 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) Modified text on 8/7/2012 (lmb). (Entered: 08/03/2012)
387 OBJECTION re 110 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)

08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012

388 OBJECTION re 111 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12.(Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
389 OBJECTION re 113 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
390 OBJECTION re 114 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
391 OBJECTION re 117 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
392 OBJECTION re 119 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
393 OBJECTION re 127 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
394 OBJECTION re 137 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
395 OBJECTION re 140 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
396 OBJECTION re 144 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
397 OBJECTION re 145 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
398 OBJECTION re 146 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
399 OBJECTION re 147 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
400 OBJECTION re 151 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
401 OBJECTION re 152 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on

08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012

8/23/2012 (akl). (Entered: 08/06/2012)
402 OBJECTION re 153 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
403 OBJECTION re 154 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
404 OBJECTION re 158 Status Report filed by Maura Gonzalez Salinas, Adrian Ramirez−Cuevas, Zelaido Rivera Garcia, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
405 OBJECTION re 161 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
406 OBJECTION re 175 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
407 OBJECTION re 173 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
408 OBJECTION re 174 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
409 OBJECTION re 181 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
410 OBJECTION re 191 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
411 OBJECTION re 233 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
412 OBJECTION re 218 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
413 OBJECTION re 225 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
414 OBJECTION re 227 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)

08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012

415 OBJECTION re 232 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
416 OBJECTION re 235 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
417 OBJECTION re 238 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
418 OBJECTION re 241 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
419 OBJECTION re 243 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
420 OBJECTION re 247 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
421 OBJECTION re 248 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
422 OBJECTION re 250 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
423 OBJECTION re 251 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
424 OBJECTION re 254 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
425 OBJECTION re 252 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
426 OBJECTION re 253 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
427 OBJECTION re 255 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
428 OBJECTION re 257 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on

08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012 08/06/2012

8/23/2012 (akl). (Entered: 08/06/2012)
429 OBJECTION re 261 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
430 OBJECTION re 264 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
431 OBJECTION re 265 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
432 OBJECTION re 268 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
433 OBJECTION re 271 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
434 OBJECTION re 274 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
435 OBJECTION re 249 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
436 OBJECTION re 275 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
437 OBJECTION re 276 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
438 OBJECTION re 277 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
439 OBJECTION re 298 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
440 OBJECTION re 300 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
441 OBJECTION re 301 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)

08/06/2012
08/06/2012
08/06/2012
08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012

442 OBJECTION re 307 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
443 OBJECTION re 308 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
444 OBJECTION re 313 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 8/7/12. (Cialkowski, David) Modified on 8/23/2012 (akl). (Entered: 08/06/2012)
445 OBJECTION re 114 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Attachments: # 1 Objection Part 2, # 2 Objection Part 3)(Cialkowski, David) (Entered: 08/07/2012)
446 OBJECTION re 127 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Attachments: # 1 Objection Part 2)(Cialkowski, David) (Entered: 08/07/2012)
447 OBJECTION re 152 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
448 OBJECTION re 154 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
449 OBJECTION re 161 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
450 OBJECTION re 175 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
451 OBJECTION re 173 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
452 OBJECTION re 174 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
453 OBJECTION re 218 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
454 OBJECTION re 232 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
455 OBJECTION re 235 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
456 OBJECTION re 243 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
457 OBJECTION re 247 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
458 OBJECTION re 252 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Attachments: # 1

08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/07/2012 08/15/2012 08/20/2012
09/04/2012 09/05/2012 10/04/2012
10/05/2012 10/11/2012 11/08/2012

Objection Part 2, # 2 Objection Part 3)(Cialkowski, David) (Entered: 08/07/2012)
459 OBJECTION re 253 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
460 OBJECTION re 255 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Attachments: # 1 Objection Part 2)(Cialkowski, David) (Entered: 08/07/2012)
461 OBJECTION re 257 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
462 OBJECTION re 261 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
463 OBJECTION re 271 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
464 OBJECTION re 274 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
465 OBJECTION re 307 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
466 OBJECTION re 308 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
467 OBJECTION re 313 Status Report filed by Maura Gonzalez Salinas, Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Camerina Cuevas Lopez. (Cialkowski, David) (Entered: 08/07/2012)
468 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) July 18, 2012 Invoice)(Cialkowski, David) (Entered: 08/15/2012)
469 ORDER for Authorization to Pay Fees and Expenses re 468 Affidavit filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on August 17, 2012. (slf) (Entered: 08/20/2012)
470 ORDER Determining Appeals from the Determinations of the Special Master(Written Opinion). Signed by Judge Joan N. Ericksen on 9/4/12. (Attachments: # 1 Addendum to Order of 9/4/2012)(CBC) (Entered: 09/04/2012)
471 CORRECTED ORDER: This order corrects typographical errors contained in docket entry 470 (Written Opinion). Signed by Judge Joan N. Ericksen on 9/4/2012. (Attachments: # 1 Attachment to Corrected Order)(CBC) (Entered: 09/05/2012)
472 AFFIDAVIT of Jason P. Johnston by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) Statement of Collins, Buckley, Sauntry & Haugh PLLP, # 2 Exhibit(s) Statement of US Bank)(Johnston, Jason) (Entered: 10/04/2012)
473 ORDER for authorization to pay fees and expenses. Signed by Judge Joan N. Ericksen on October 5, 2012. (CBC) (Entered: 10/05/2012)
474 AFFIDAVIT of Jason P. Johnston by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Johnston, Jason) (Entered: 10/11/2012)
475 NOTICE of Appearance by J Gordon Rudd, Jr on behalf of Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Rudd, J)

11/08/2012 11/09/2012 11/09/2012 11/09/2012 11/09/2012 11/09/2012 11/16/2012
11/16/2012
11/19/2012 11/28/2012 12/07/2012 01/23/2013

(Entered: 11/08/2012)
476 NOTICE of Withdrawal as Attorney Elizabeth A. Peterson (Rudd, J) (Entered: 11/08/2012)
477 Supplemental AFFIDAVIT of Jason P. Johnston re 474 Affidavit regarding Settlement Fund Accounting by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Johnston, Jason) (Entered: 11/09/2012)
478 MOTION to Enforce Settlement and Authorize Payment of the Claims Administrator's Fees and Expenses by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Rudd, J) (Entered: 11/09/2012)
479 MEMORANDUM in Support re 478 MOTION to Enforce Settlement and Authorize Payment of the Claims Administrator's Fees and Expenses filed by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 LR7.1/LR72.2 Word Count Compliance Certificate)(Rudd, J) (Entered: 11/09/2012)
480 AFFIDAVIT of Jason P. Johnston in SUPPORT OF 478 MOTION to Enforce Settlement and Authorize Payment of the Claims Administrator's Fees and Expenses filed by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Rudd, J) (Entered: 11/09/2012)
481 MEET and CONFER STATEMENT re 478 Motion to Enforce Settlement filed by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Rudd, J) (Entered: 11/09/2012)
482 MEMORANDUM in Opposition re 478 MOTION to Enforce Settlement and Authorize Payment of the Claims Administrator's Fees and Expenses filed by Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of Richfield, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Bob Flectcher, Barry Fritz, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Dave Pecchla, Ramsey County, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County. (Attachments: # 1 LR7.1/LR72.2 Word Count Compliance Certificate)(Flynn, Joseph) (Entered: 11/16/2012)
483 AFFIDAVIT of JOSEPH E. FLYNN in OPPOSITION TO 478 MOTION to Enforce Settlement and Authorize Payment of the Claims Administrator's Fees and Expenses filed by Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of Richfield, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Bob Flectcher, Barry Fritz, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Dave Pecchla, Ramsey County, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County. (Attachments: # 1 Exhibit A)(Flynn, Joseph) (Entered: 11/16/2012)
484 MOTION for Leave to File Reply/Surreply re 478 MOTION to Enforce Settlement and Authorize Payment of the Claims Administrator's Fees and Expenses by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Rudd, J) Modified text, link on 11/19/2012 (lmb). (Entered: 11/19/2012)
485 ORDER granting 484 Motion for Leave to File Reply. Signed by Judge Joan N. Ericksen on November 28, 2012. (CBC) (Entered: 11/28/2012)
486 REPLY re 478 MOTION to Enforce Settlement and Authorize Payment of the Claims Administrator's Fees and Expenses filed by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 LR7.1/LR72.2 Word Count Compliance Certificate)(Rudd, J) (Entered: 12/07/2012)
487 ORDER − IT IS ORDERED THAT: (1) Zimmerman Reeds motion 478 for an award of Claims Administrators fees and expenses of $433,518.00 and $7,940.38, respectively, is DENIED. (2) A payment in the amount of $100,000 from the Settlement Fund Escrow Account shall be made to Zimmerman Reed, P.L.L.P. (3) The remaining funds of the Settlement Fund Escrow Account shall be used to fund the Law Enforcement Training and Education component of the Settlement. Signed by Judge

02/05/2013 02/06/2013 03/11/2013
11/26/2013 12/06/2013 01/22/2014 01/24/2014 04/29/2014 05/05/2014 06/05/2014 06/11/2014 06/18/2014
06/18/2014

Joan N. Ericksen on January 23, 2013. (CBC) (Entered: 01/23/2013)
488 LETTER to Request Permission to File Motion to Reconsider . (Rudd, J) (Entered: 02/05/2013)
489 ORDER re 488 Letter to Request Permission to File Motion to Reconsider filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on February 6, 2013. (CBC) (Entered: 02/06/2013)
490 LETTER TO DISTRICT JUDGE by Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of Richfield, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Bob Flectcher, Barry Fritz, Zelaido Rivera Garcia, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Camerina Cuevas Lopez, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Dave Pecchla, Adrian Ramirez−Cuevas, Ramsey County, Ron Ryan, Maura Gonzalez Salinas, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County, John Yankovic, Kathleen Yankovic RE: SELECTION OF LAW ENFORCEMENT REPRESENTATIVES. (Attachments: # 1 Exhibit(s) CV Israel Reyes, # 2 Exhibit(s) CV Robert Boe, # 3 CV Kevin Ross)(Flynn, Joseph) (Entered: 03/11/2013)
491 AFFIDAVIT of Jason P. Johnston by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s))(Johnston, Jason) (Entered: 11/26/2013)
492 ORDER re 491 Affidavit of Jason P. Johnston by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. Signed by Judge Joan N. Ericksen on November 30, 2013. (CBC) (Entered: 12/06/2013)
493 AFFIDAVIT of Jason P. Johnston by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) December 12, 2013 invoice)(Johnston, Jason) (Entered: 01/22/2014)
494 ORDER re 493 Affidavit filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on January 24, 2014. (CBC) (Entered: 01/24/2014)
495 AFFIDAVIT of Jason P. Johnston by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) The Reyes Law Firm Invoices)(Johnston, Jason) (Entered: 04/29/2014)
496 ORDER re 495 Affidavit filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on May 5, 2014. (CBC) (Entered: 05/05/2014)
497 AFFIDAVIT of Jason P. Johnston by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) May 27, 2014, invoice)(Johnston, Jason) (Entered: 06/05/2014)
498 ORDER re 497 Affidavit filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on June 10, 2014. (CBC) (Entered: 06/11/2014)
499 LETTER TO DISTRICT JUDGE by Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of Richfield, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Bob Flectcher, Barry Fritz, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Dave Pecchla, Ramsey County, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County (SUBMITTED JOINTLY WITH CLASS COUNSEL). (Attachments: # 1 Ex. A − Proposed Training, # 2 Ex. B − Project Objectives, # 3 Ex. C − Neil Melton C.V.)(Flynn, Joseph) (Entered: 06/18/2014)
500 ORDER for Appointment of Executive Director. Signed by Judge Joan N. Ericksen on June 18, 2014. (CBC) (Entered: 06/18/2014)

08/01/2014 08/05/2014 09/05/2014 09/08/2014 10/27/2014 10/30/2014 12/22/2014 12/23/2014 02/25/2015 03/06/2015 03/09/2015 03/11/2015 04/24/2015 04/28/2015 06/26/2015

501 AFFIDAVIT of Jason P. Johnston by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) Receipt)(Johnston, Jason) (Entered: 08/01/2014)
502 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES re 501 Affidavit of Jason P. Johnston filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on August 5, 2014. (CBC) Modified on 8/6/2014 (las). (Entered: 08/05/2014)
503 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Cialkowski, David) (Entered: 09/05/2014)
504 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES re 503 Affidavit of David M. Cialkowski by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on September 8, 2014. (CBC) (Entered: 09/08/2014)
505 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) Receipt and invoices)(Cialkowski, David) (Entered: 10/27/2014)
506 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES re 505 Affidavit of David M. Cialkowski by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on October 30, 2014. (CBC) (Entered: 10/30/2014)
507 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s))(Cialkowski, David) (Entered: 12/22/2014)
508 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES re 507 Affidavit of David M. Cialkowski by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on December 23, 2014. (CBC) (Entered: 12/23/2014)
509 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) 1)(Cialkowski, David) Modified on 2/25/2015 (kt). (Entered: 02/25/2015)
510 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) February 22, 2015 letter from Neil Melton)(Cialkowski, David) (Entered: 03/06/2015)
511 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES re 509 Affidavit of David M. Cialkowski by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on March 9, 2015. (CBC) (Entered: 03/09/2015)
512 ORDER re 510 Affidavit of David M. Cialkowski filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on March 10, 2015. (CBC) (Entered: 03/11/2015)
513 AFFIDAVIT of David M. Cialkowski by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) Invoices)(Cialkowski, David) (Entered: 04/24/2015)
514 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES re 513 Affidavit of David M. Cialkowski by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on April 28, 2015. (CBC) (Entered: 04/28/2015)
515 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member A.G. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Placeholder for conventionally filed document pursuant to Fed. R. Civ. P. 5.2) SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 6/26/15. (Rudd, J) Modified on 6/29/2015 (AKL). (Entered: 06/26/2015)

06/26/2015 06/26/2015 06/26/2015 06/26/2015 06/26/2015 06/26/2015 06/26/2015
06/26/2015

516 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member J.R.R. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Placeholder for conventionally filed document pursuant to Fed. R. Civ. P. 5.2) SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 6/26/15. (Rudd, J) Modified on 6/29/2015 (AKL). (Entered: 06/26/2015)
517 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member B.R.H. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Placeholder for conventionally filed document pursuant to Fed. R. Civ. P. 5.2) SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 6/26/15. (Rudd, J) Modified on 6/29/2015 (AKL). (Entered: 06/26/2015)
518 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member J.S.R. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Placeholder for conventionally filed document pursuant to Fed. R. Civ. P. 5.2) SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 6/26/15. (Rudd, J) Modified on 6/29/2015 (AKL). (Entered: 06/26/2015)
519 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member J.M.R. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Placeholder for conventionally filed document pursuant to Fed. R. Civ. P. 5.2) SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 6/26/15. (Rudd, J) Modified on 6/29/2015 (AKL). (Entered: 06/26/2015)
520 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member S.M.R. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Placeholder for conventionally filed document pursuant to Fed. R. Civ. P. 5.2) SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 6/26/15.(Rudd, J) Modified on 6/29/2015 (AKL). (Entered: 06/26/2015)
521 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member C.M.R. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Placeholder for conventionally filed document pursuant to Fed. R. Civ. P. 5.2) SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 6/26/15. (Rudd, J) Modified on 6/29/2015 (AKL). (Entered: 06/26/2015)
522 CERTIFICATE OF SERVICE by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas re 520 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member S.M.R., 518 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member J.S.R., 516 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member J.R.R., 519 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member J.M.R., 517 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member B.R.H., 521 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member C.M.R., 515 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member A.G. Certificate of Service of Conventionally Filed/Sealed Documents (Rudd, J) (Entered: 06/26/2015)
523 CERTIFICATE OF SERVICE ON PROPOSED ORDER by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas re 520 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member S.M.R., 518 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member J.S.R., 516 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member J.R.R., 519 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member J.M.R., 517 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member B.R.H., 521

07/01/2015 07/01/2015 07/01/2015 07/01/2015 07/01/2015 07/01/2015 07/01/2015 07/23/2015 07/24/2015
09/18/2015 09/18/2015
10/29/2015 10/30/2015
01/05/2016 01/07/2016

MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member C.M.R., 515 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member A.G. (Rudd, J) (Entered: 06/26/2015)
524 ORDER granting 515 Motion to Withdraw/Disburse/Release Funds re. Petition for Distribution of Settlement Funds to Minor Class Member A.G. Signed by Judge Joan N. Ericksen on July 1, 2015. (CBC) (Entered: 07/01/2015)
525 ORDER granting 516 Motion to Withdraw/Disburse/Release Funds re. Petition for Distribution of Settlement Funds to Minor Class Member J.R.R. Signed by Judge Joan N. Ericksen on July 1, 2015. (CBC) (Entered: 07/01/2015)
526 ORDER granting 517 Motion to Withdraw/Disburse/Release Funds re. Petition for Distribution of Settlement Funds to Minor Class Member B.R.H. Signed by Judge Joan N. Ericksen on July 1, 2015. (CBC) (Entered: 07/01/2015)
527 ORDER granting 518 Motion to Withdraw/Disburse/Release Funds re. Petition for Distribution of Settlement Funds to Minor Class Member J.S.R. Signed by Judge Joan N. Ericksen on July 1, 2015. (CBC) (Entered: 07/01/2015)
528 ORDER granting 519 Motion to Withdraw/Disburse/Release Funds re. Petition for Distribution of Settlement Funds to Minor Class Member J.M.R. Signed by Judge Joan N. Ericksen on July 1, 2015. (CBC) (Entered: 07/01/2015)
529 ORDER granting 520 Motion to Withdraw/Disburse/Release Funds re. Petition for Distribution of Settlement Funds to Minor Class Member S.M.R. Signed by Judge Joan N. Ericksen on July 1, 2015. (CBC) (Entered: 07/01/2015)
530 ORDER granting 521 Motion to Withdraw/Disburse/Release Funds re. Petition for Distribution of Settlement Funds to Minor Class Member C.M.R. Signed by Judge Joan N. Ericksen on July 1, 2015. (CBC) (Entered: 07/01/2015)
531 AFFIDAVIT of J. Gordon Rudd, Jr. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) Reyes Law Firm invoices)(Rudd, J) (Entered: 07/23/2015)
532 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES re 531 Affidavit of J. Gordon Rudd, Jr. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, and Maura Gonzalez Salinas. Signed by Judge Joan N. Ericksen on July 24, 2015. (CBC) (Entered: 07/24/2015)
533 LETTER TO DISTRICT JUDGE by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas Joint Letter from J. Gordon Rudd and Joseph Flynn. (Rudd, J) (Entered: 09/18/2015)
534 ORDER authorizing payment of compensation to Mr. Melton pursuant to 533 Letter to District Judge filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on September 18, 2015. (CBC) (Entered: 09/18/2015)
535 AFFIDAVIT of J. Gordon Rudd, Jr. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) Reyes Law Firm invoices)(Rudd, J) (Entered: 10/29/2015)
536 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES re 535 Affidavit of J. Gordon Rudd, Jr. by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on October 30, 2015. (CBC) (Entered: 10/30/2015)
537 AFFIDAVIT of J. Gordon Rudd, Jr. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) Invoices)(Rudd, J) (Entered: 01/05/2016)
538 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES re 537 Affidavit of J. Gordon Rudd, Jr. by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on January 7, 2016. (CBC) (Entered: 01/07/2016)

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11/04/2016 11/08/2016 11/16/2016 11/16/2016 11/16/2016 11/18/2016

539 ORDER for Appointment of Executive Director. Signed by Judge Joan N. Ericksen on April 8, 2016. (CBC) (Entered: 04/08/2016)
540 AFFIDAVIT of J. Gordon Rudd, Jr. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) Invoices)(Rudd, J) (Entered: 06/08/2016)
541 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES re 540 Affidavit filed by Zelaido Rivera Garcia, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas, Camerina Cuevas Lopez. Signed by Judge Joan N. Ericksen on June 9, 2016. (CBC) (Entered: 06/09/2016)
542 LETTER TO DISTRICT JUDGE by Rob Allen, Dave Bellows, City of Brooklyn Park, City of Lino Lakes, City of Maplewood, City of Minneapolis, City of Richfield, City of St. Paul, City of West St. Paul, Dakota County, Michael Davis, Doe Officers, Bob Flectcher, Barry Fritz, John Harrington, Hennepin County, Bill Hutton, Dave Indrehus, Metro Gang Strike Force, Metro Gang Strike Force Advisory Board, Metropolitan Council, Dave Pecchla, Ramsey County, Ron Ryan, Ken Schilling, Manila "Bud" Shaver, Dave Thomalla, Washington County (STATUS OF LAW ENFORCEMENT TRAINING COMPONENT OF SETTLEMENT). (Flynn, Joseph) (Entered: 06/14/2016)
543 AFFIDAVIT of J. Gordon Rudd, Jr. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Exhibit(s) US Bank invoice, # 2 Exhibit(s) WebAnywhere invoice)(Rudd, J) (Entered: 11/04/2016)
544 ORDER FOR AUTHORIZATION TO PAY FEES AND EXPENSES re 543 Affidavit of J. Gordon Rudd, Jr. Signed by Judge Joan N. Ericksen on November 7, 2016. (CBC) (Entered: 11/08/2016)
545 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member J.L.B. by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas. (Attachments: # 1 Placeholder for conventionally filed document pursuant to Fed.R.Civ.P. 5.2)(Rudd, J) Sealed document received on 11/16/2016 (SAE). (Entered: 11/16/2016)
546 CERTIFICATE OF SERVICE by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas re 545 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member J.L.B. Certificate of Service of Conventionally Filed Document (Rudd, J) (Entered: 11/16/2016)
547 CERTIFICATE OF SERVICE ON PROPOSED ORDER by Zelaido Rivera Garcia, Camerina Cuevas Lopez, Adrian Ramirez−Cuevas, Maura Gonzalez Salinas re 545 MOTION to Withdraw/Disburse/Release Funds Petition for Distribution of Settlement Funds to Minor Class Member J.L.B. (Rudd, J) (Entered: 11/16/2016)
548 ORDER granting 545 Motion to Withdraw/Disburse/Release Funds re Petition for Distribution of Settlement Funds to Minor Class Member J.L.B. Signed by Judge Joan N. Ericksen on November 18, 2016. (CBC) (Entered: 11/18/2016)