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 Situational Approaches to Making Communities and Correction Institutions Safer Archival Notice
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June 1, 2010
Your browser does not support the audio element.1 of 4: Situational Approaches to Making Communities and Correction Institutions Safer, Winnie Reed, National Institute of Justice
      Your browser does not support the audio element.2 of 4: Situational Approaches to Making Communities and Correction Institutions Safer, Nancy La Vigne, Director, Justice Policy Institute, Urban Institute
      Your browser does not support the audio element.3 of 4: Situational Approaches to Making Communities and Correction Institutions Safer, Gary Wedge, Captain, Administrative Services Division, Chula Vista Police Department, Calif.
      Your browser does not support the audio element.4 of 4: Situational Approaches to Making Communities and Correction Institutions Safer, Tara H. Wildes, Chief, Jails Division, Jacksonville Sheriff's Office, Fla.
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Speakers
        Winnie Reed, Director, Crime Control and Prevention Research Division, Office of Research and Evaluation, National Institute of Justice, Washington D.C.;               Nancy G. La Vigne, Director, Justice Policy Institute, Urban Institute, Washington D.C.;               Gary Wedge, Captain, Administrative Services Division, Chula Vista Police Department, Calif.;               Tara H. Wildes, Chief, Jails Division, Jacksonville Sheriff's Office, Fla.
NIJ Conference****panelists will present the results of three studies that applied situational crime prevention (SCP) principles: (1) an evaluation of the Safe City initiative in Chula Vista, Calif., designed to combine the expertise and resources of local law enforcement, retailers and the community to increase the safety of designated retail areas; (2) a randomized controlled trial (in partnership with the Washington Metro Transit Police) that assessed the effectiveness of SCP to reduce car crime in Metro's parking facilities; and (3) an evaluation of the impact of SCP on preventing sexual assaults and inmate misconduct in a jail setting. Panelists will also discuss the studies' implications for theory, policy and practice.
  
  
          Transcript
**Winnie Reed:** My name is Winnie Reed. I'm with the National Institute of Justice, and I'm the moderator for this panel.

This afternoon, we're going to hear from three presenters talking about three evaluations of situational crime prevention efforts. Nancy La Vigne from the Urban Institute is going to speak first about the evaluations themselves and some about the projects. Nancy is the director of the Justice Policy Institute at the Urban Institute in Washington, D.C.

She will be followed by Captain Gary Wedge. He is with the Administrative Services Division of the Chula Vista Police Department in California. He's going to be speaking about some of the benefits and challenges involved in the implementation of the Target Safe City Initiative in San Diego.

Finally, Tara Wildes, chief of the Jails Division in the Jacksonville Sheriff's Office in Florida, will be talking about some of the benefits and challenges of the implementing a situational crime prevention initiative preventing sexual assault and inmate misconduct in a jail setting.

First, we'll hear from Nancy La Vigne.

**Nancy G. La Vigne:** Good afternoon, everybody. I am going to try to cover a lot of information in a relatively short period of time.

I'm not going to assume that everyone in this room knows what situational crime prevention is, so I'm going to begin by giving you a broad overview of that, so you have a context with which to interpret the remainder of this session.

Then I'm going to be focusing on three different NIJ funded evaluations that have both applied situational crime prevention concepts, and they're in various forms of evaluating the impact of those applications, trying to tie it all together, a lot of lessons learned both for practitioners and for researchers who undertake this kind of work. So we'll, hopefully, have some good discussion at the end.

And just real broad brush stroke, although this isn't rocket science and it always stuns me because I think it's just such common sense, it's really based on microeconomic theory. It assumes that most offenders aren't really motivated to commit crimes. They don't wake up in the morning and say, “I'm going to rob a bank.” Yes, those people do exist, but most of the people who commit crimes are committing crimes of opportunity. They walk by and see a situation where, you know, maybe it's a door that looks ajar or something like that. They take advantage of those opportunities.

They also weigh the costs and benefits of engaging in criminal behavior, and those costs include the risk of getting caught, right, the risk of apprehension, how much effort it takes to engage in the criminal act, and then the benefits or what they hope to gain from it. And it could be monetary gain, or it could be some other kind of gain. Like, you know, a lot of violent acts, the gain is sort of status among one's peers, for example, be it juveniles or in a correctional setting.

So situational crime prevention says given that theory, we can change aspects of the environment and aspects of potential criminal targets to alter that cost benefit ratio in a way that closes off criminal opportunities and discourages a lot of those would be criminals who didn't wake up in the morning dead set on committing a crime.

This chart on the right hand side just gives you a lot of examples of ways that you can increase the effort or risk and reduce the rewards and also remove excuses of some of those low level criminal activities, “Oh, I didn't know I was breaking the law.” Post the laws more prominently. So those are just some examples right there.

So, with that as the backdrop, I'm going to describe three different evaluations. The first one is looking at crimes occurring in the D.C. area Metro, the subway system — we call it “Metro” here — in the parking facilities.

And I want to acknowledge my project director, Samantha Lowry, who did the bulk of the analysis for this presentation. She's not here today, but she's here in spirit.

So why did we decide to look at this issue? Well, frankly, it stemmed from my doctoral dissertation when I was looking at crime occurring in subway systems, specifically looking at Metro as a case study because it had always been held up as this great example of this good design that closed off criminal activities, that it was managed very well, et cetera, but no one had set out to look to see whether that was true. And in the course of doing that research, what I learned was, yeah, crime is really low on the rail, but above ground, crime is relatively high. Most of the part one crimes are occurring in the parking facilities. They're mostly auto thefts or auto break-ins or sometimes other parking related crimes, and, you know, that's the bulk of the crime problem that Metro was facing.

And so we reached out to the Transit Police, and we said would you like to partner with us, an action research partnership which means that we were involved in the beginning to set out to understand what the factors were behind these crimes and how could we together develop the series of interventions that could close off criminal opportunities and then we would evaluate it along the way and see if there was an impact.

So that was our goal to do a lot of research looking at historical data, doing site observations of the parking facilities, trying to identify all of the environmental and management characteristics that seem to be related to crimes occurring there, identifying strategies.

And then this is a randomized control trial design in that there were 51 — actually 52 parking facilities. We ended up looking at just 50 and randomly assigning the intervention to 25 of those 50, and I'll tell you a little bit more about that later.

We used a lot of different data to try to understand the nature of this problem, and we really need to look at not just data that was maintained by the Transit Police but also the data for all the law enforcement jurisdictions that serve Metro. You know, it's a pretty big system, and so that ended up being seven different jurisdictions where we had to go and ask for crime data. So we looked at part one crimes within a mile radius of the Metro station. We looked at a lot of administrative data on sort of the nature of the parking facilities, what their capacity was, how full they were. There's a lot of different factors that I'll describe in a moment, including the site observations where we went and we made note systematically of all the different characteristics that we observed, whether there was fencing around the facilities, whether there's one exit or two, was there an attendant booth or not, was the attendant booth stationed, et cetera.

This is just some of the highlights from the site observations. Most of them had payment facilities where you had to pay upon exit. We saw that as a very good way to prevent auto theft. If you have to pay to exit, you need some kind of demonstration that you got the parking ticket that you received when you entered the system. There were some places that had multiple exits that made it more difficult to monitor the facility. We looked at the surroundings, and then, as I just showed you already, we looked at above ground crime rates in the surrounding jurisdictions. We looked at whether or not they had attendant booths and the degree to which there were actual humans in the attendant booths and many other things.

So, given all that, we came up with a long laundry list of interventions, and some of them were really creative. And one by one, they all got shot down. Either they weren't feasible practically or politically and sometimes both. So what we ended up doing is rather mundane. It was to install cameras at the exits of half of the randomly selected facilities. In addition to the cameras, we put prominent signs that said, you know, your car and your license plate could be captured on camera, and we said “could be” because, you know, we didn't want — there's liability issues. You have to be very careful with the language that you put on these signs because then you don't want people to assume that they're somehow protected and, if the camera malfunctions, they're not, but they were very prominently placed.

Even though a lot of these facilities had challenges with both auto thefts and car break-ins, mostly this intervention was aimed at auto thefts because most of these places, there's only one exit. We positioned cameras, so that they were at the exits. You know, you're going to leave. You're thinking that you're going to be captured on camera. You don't know whether they're going to capture the license plate or you behind the driver, in the driver's seat or both. You know, you'd think that that might make a difference, but we were also hoping that that would also sort of send a message that Metro cares, that they're looking in other ways, and it might even discourage some thefts from autos, some car break-ins, right?

The intent was to link. The cameras had an ability to record. The intent was to link that to some license plate recognition software that they already had in place; however, during the course of the intervention, the auto theft unit was disbanded. We have yet to locate a human being who can tell us whether or not they're using the cameras in any way. So this could be an evaluation of the bare minimum of like put the technology up and hope something, you know, makes a difference because it's probably not human interaction with that technology.

So this slide just tells you a little bit about how we did the random assignment. Since we only had 50 parking facilities, that's not a huge N to work with for random assignment purposes, and even if we were to flip a coin each time and decide for each 50, do you go in treatment or control, we couldn't ensure that those two groups would be equivalent. So what we did first was to create matched pairs on a lot of different factors. Once we created these pairs based on historical crime rate in the surrounding area, the capacity of the facilities, their payment policies and so forth, then for each pair, we assign them to treatment or control. And that method was designed to ensure more equivalency between the two groups.

So I wish I had more exciting findings to share with you, but this is one of those lessons learned that I think we'll talk about later on, and that is that all the things that can go wrong when you try to engage in this kind of evaluation work, in the real world, where staff changes and policies change, so we knew originally that when we did our analysis to understand the factors that were driving the auto thefts and other types of car crimes in the facilities, that the data was not maintained as well as we would like.

So how many of you have been on Metro, are familiar with the facilities? Some of you not. Well, yeah, fair share.

So, in some places, like Shady Grove, you've got multiple parking facilities. You've got parking lot A, parking lot B. You've got a multilevel garage, whatever. There's a lot of different options for parking, and when events occur, you sort of want to know where, right? We were counting each of these facilities as a separate entity.

So, within Shady Grove, of the three facilities, you know, two could be in treatment and one could be in control. So we'd really want to know the location of the events.

We made a lot of efforts to ensure that officers were recording that data very well at the onset of the project and then came to learn that they changed their MIS system. They changed staff, and the auto theft unit who we were relying on to make sure that they were recording this information well was disbanded. So now when we're looking at post intervention data, we have a lot of data where we don't know what facility within a larger station area experienced the crime. So we're like, “Oh, great, all this work.”

What we did so far was to look at five matched pairs where there was only one parking facility, so we knew exactly where it happened. Even with that very narrow analysis, it looks like we've seen a bit of an impact on crime. It's really too soon to tell. We really need to aggregate across all 25 treatment and control facilities, but it looks like it could have made an impact, could have made a difference.

And we're in the process of developing a strategy where we can estimate the location of those crimes in those situations where you have stations with multiple facilities.

So that is — see, I told you I have a lot to share. I've got two more studies to share with you, but we promised we'd do it all, didn't we, Winnie?

**Winnie Reed:** We did.

**La Vigne:** So hold those thoughts because I'm sure there's a lot of burning questions, and then I'm going to move on to our Safe City Evaluation, which is another application of situational crime prevention, but it didn't really start out that way.

It started out by the Target Corporation — everybody knows Target, right? — approaching us because they had this crime prevention program called Safe City. It had a lot of great packaging. I mean like glossy little folders that you give to communities. It was designed to encourage law enforcement to partner with retailers in mall environments and then, together, engage in crime prevention activities, but the Target's original focus was really on we're going to help you make these partnerships, then we're going to quickly leave, we don't want to control this crime prevention activity, but we will give you a big blown up check, you know, for the photo op and the press conference and so forth, so that you can spend money on something really cool, like CCTV technology. And so a lot of jurisdictions said, “Oh, this is cool. We can get money to buy cameras.”

And Target wanted us to evaluate it, and we said, “Well, what could you pay us?” And they couldn't pay us anywhere near what it cost to evaluate something. So we said, “Well, why don't we partner and go to NIJ and see if we can get funding?” and they said OK. And then we looked at their materials and we said, “There's nothing to evaluate because there's no real 'it' there. You know, there's like money for technology. What if we started anew and identified some sites and worked with you and developed more of a model that's based on theory, say situational crime prevention, and then together we help jurisdictions implement it?” And so that's what we ended up doing.

We selected four sites: Chula Vista, which you'll hear about in a moment; Cincinnati, Ohio; Tucson, Arizona; and Hyattsville, Maryland. All of them have their own unique stories, but just to give you some background about the way we were looking at this, we were looking at this as a retail crime issue.

As you can imagine, shopping malls, most of these were strip malls that were anchored by a Target store. They present a lot of opportunities for crime because they're designed to attract people, right? I mean, that's part of the business model is bring people in, make it attractive, make it accessible. You want to be on a transportation network, and all of those factors also make it attractive to would be offenders.

Malls are also places where shoppers can easily be distracted, so it's a good opportunity for pickpocketing. It's a place where people park their cars for, you know, an hour or more, so their cars are unattended for a significant period of time, which leaves them vulnerable to break-ins or even thefts, and all kinds of crimes end up occurring there.

So we wanted to document the process of retailers partnering with local law enforcement. To implement Safe City, we were viewing this again as action research where we weren't just these Ivy Tower evaluators who are over here waiting until the end and saying yes or no to the intervention work. Rather, we were there every step of the way. We were interviewing stakeholders. We were trying to understand better whether they were moving forward on their initiatives, whether they were adhering to the fidelity of the model, and giving them feedback, so they could improve along the way if they were able to. And so then we guided them on strategies and evaluated the impact.

This is just a lot of the common strategies that are used in retail environments, but I don't think I'll read them out to you because I feel like I'm already out of time. So I'm just going to talk about the kind of measures we use. We looked at the types of meetings that occurred, the topics that were covered, the composition of the meeting attendees. We looked at the types of interventions that were employed. We did surveys with businesses, both before and after the Safe City intervention. And, in the meantime, as part of this action research role, we also prepared a series of guides that we could share not just with the sites we were evaluating but also with the larger community.

So we have a bunch of very practically oriented guides that Target kindly put into a very nice looking format that's better than what we tend to do at the Urban Institute, and they printed them out, hard copy. We're able to distribute them to the sites, and, hopefully, that provided some good guidance along the way.

So, in terms of the impact measures, we looked at both perceptions of safety based on these pre and post surveys. We looked at level of communications and whether they increased over time, whether crime reporting increased over time, and then we looked at more of the hard impacts on the types of crimes that they were trying to reduce.

So what did we find? We found that two of the sites never really got off the ground, and those two sites had problems pretty much from the outset based on the fact that they never really followed the model. They were enamored by that big, blown up check concept and really had set their sights on using the money to buy cameras and hadn't gotten the right people around the table, the right stakeholders to engage in what is the nature of our crime problems, you know, how do we want to address them. There was no real problem analysis to understand what crimes were occurring as reported crimes. They didn't interview any real retailers. They really didn't do any of that work that needs to happen in order to get buy in for an intervention, and so various reasons, neither one of them really got off the ground.

Cincinnati was successful. They found an impact on increased perceptions of safety. More retailers were likely to report crimes. They also saw a total crime reduction in their areas. It wasn't huge, but it was cost beneficial. We did have a cost benefit component to the evaluation.

The thing about Cincinnati was they were already engaged in this huge crime prevention effort before Safe City and the Target Corporation stepped in. So it's very hard to identify cause and effect, whether they would have achieved those crime reductions anyway.

Chula Vista, however, is our poster child, which is why Captain Wedge is here today. They really embraced the model of looking at the nature of their crime problems, trying to understand what was causing them. They saw good results in terms of their surveys, increased perceptions of safety, reduced concerns about crime.

Unfortunately, we were unable to detect real significant reductions in the kinds of crimes that they were trying to reduce. We did see reductions in robberies, but we also some increases in property crimes. But the thing of this is and something that I want to talk about later if we have time, one of the problems with any kind of rigorous evaluation is that we always have this endpoint of our evaluation, even if the intervention is ongoing.

We had to stop. I don't know. We were probably on our third no cost extension as it was. What do you think, Winnie?

**Reed:** It was something like that.

**La Vigne:** You know, it was like we were out of time, we were out of money. We had to just say, “OK. This is the evaluation end date.” And I'm not so sure that our story is the right one. As a matter of fact, I think from what you'll hear from Captain Wedge, they went on and analyzed it further down the road, and they did detect a significant change. So these are some of the challenges we encounter when we're evaluating things.

We worked pretty closely with the Chula Vista PD to help interpret our findings and present them in a way that everyone felt good about.

To just summarize this Safe City evaluation, both Chula Vista and Cincinnati were more successful because they already had a strong grounding in community policing. They already had some good collaborations in place between law enforcement and the retailers. They weren't fixated on one silver bullet response. They weren't thinking CCTV. Actually, Cincinnati was, but they were thinking of it as part of a much larger crime prevention strategy. Chula Vista actually felt almost pressured, I think, by Target to implement CCTV, and they said, “No. That's not the way we want to do this,” and I'm sure we'll hear more about that soon.

So I think that there's reasons why we saw some success there, and the other two sites, as I already explained, they just weren't really following the model as intended.

Some implications that we learned from this project, one is that it really needs to be led by law enforcement but not dictated by it. It had to be a partnership and an authentic partnership with the retailers and the other members of the community, and that requires a lot of communication.

The problem solving, you know, I'm calling it “situational crime prevention.” A lot of us call it “problem oriented policing.” I find the two to be closely aligned, complementary if not overlapping strategies, and that problem solving was real key in developing responses that would be effective.

And then we already talked about evaluations that become derailed by a lot of different things, including local politics, which certainly came to play in Tucson.

And we talked about the confined evaluation period already.

So, two down, one to go, and this is a more unique application of situational crime prevention. As far as I know, there's not a lot of examples of evaluations in correctional settings. Richard Wortley wrote an excellent book on the topic of theoretically how would situational crime prevention be applied in correctional settings, but I think this is the only published evaluation of it.

And what we did was set out to look at reducing sexual violence in three jails. Now, this was funded with Prison Rape Elimination Act money that was through NIJ. So, of course, we were expected to focus on sexual violence, which, of course, we did, understanding that the rates of reporting of these acts are extremely low and unreliable, but we felt that theoretically if you look not just at those rare events but also looked in the larger context of violence and infractions, we could still develop some strategies and implement them and see if they had an impact.

I am ashamed to say that I want to acknowledge my colleague, Sara Debus Sherrill, and late last night, I added an “h” to her name, and I don't know where that came from, but I'll take it back later. She is S a r a, Debus Sherrill, and she's in the audience, and she's the project director. And I thank you very much for all your contributions on this.

So I told you to be forgiving, did I not? OK.

So this project, as I said, was funded under PREA. A few years back now, again, another action research partnership where we come in and we help the practitioners understand the nature of their problems, helping them analyze data, conducting site observations, interviewing staff, in this case interviewing inmates as well, and then trying to develop strategies that will help reduce the problems that are of issue.

So, earlier you saw a very fuzzy matrix of situational crime prevention in general. This is one that's applied specifically to looking at sexual assault, other violence and also acts of self harm which we felt were also important to look at in the jail setting.

And just to pull out any example, things like double bunking, which could be a precipitater for some kinds of violence in a correctional setting, actually is helpful in reducing acts of self harm, or target hardening, locking off risky areas like broom closets, which we found were likely areas of staff sexual misconduct, which is something that we ended up finding in some of our sites. So there's just the different kinds of things that you can do to close off opportunities for these events, even in correctional settings.

So what did we do? We had meetings with our three jail sites. We did these site observations where we systematically collected data and all the different characteristics of the facilities, the design, the visibility from where the correction officers sit, the frequency with which they do their rounds, staff perceptions about where the strengths and vulnerabilities are in the facility, interviews with inmates to learn the same from them, analysis of incident data which, of course, in the case of sexual assault was not that great but certainly lots of data on incidence of violence, of contraband, of self harm. And we took all that information, we synthesized it, and we developed a list of recommendations that stemmed from it.

And then we went back to each of our sites and we said, “OK, here is what we found.” Similar to our experience with the study of the car crime and the Metro facility, this really long creative list of things and then one by one, “No, can't do that. No, no, no, no.” But we found some interesting things to do in each of the three sites.

Here's some overall findings across three sites. In terms of sexual assault, again, it's just a really murky area. There's no real consensus on how often it happens. We found that because we were doing a lot of qualitative data collection on this that people would talk about an incident, and we discovered it was the same incident over and over again that everyone was talking about, but it was a sole incident.

There were some perceptions about sort of the common victims in terms of males being the stereotypical younger, weaker, smaller, you know, white males are more likely to be targets. We learned of some sexual harassment issues of female staff by the male inmates. There was talk of some staff sexual misconduct but no real sexual assault findings. With suicide and self harm, there was more to work off of and a lot of, I think, education that need to occur, at least in one of our sites, with the staff about what constitutes call for help versus an excuse to get out of the cell and how to treat those cases in the proper manner, and then a lot on physical assaults which are quite common, not in all the facilities. There was quite a bit of variation, but we looked at the type of weapons, the locations, the cause of the fights, whether they were mostly one-on-one or were they group and so forth.

So we came up with a series of recommendations, and as I said before, not all of them were implemented at any one of the three sites, but one that was prominent was this increased monitoring of the inmates. And we also looked at things like changing the classification system, which is what predicted who would be bunked with whom and in what proximity to other people. We looked at access to mental health care, which we found was an issue in one of the facilities, and then that led to a recommendation for training.

But what we're going to talk about today and then Chief Wildes is going to share her personal experiences with is this officer tour system that was implemented in the Jacksonville jail, one of our three study sites.

So what — and, Chief Wildes, I don't want to steal your thunder. Can I describe your facility?

**Tara H. Wildes:** Sure.

**La Vigne:** OK. So it's sort of like the panopticon. Does anyone know? It's like it's not direct supervision. OK? It's like you're in a sort of booth, and you can look down on everybody. And you're supposed to get out and make rounds periodically, and that's supposed to be documented, but in interviewing both staff and inmates, we came to learn that that was done on a very inconsistent basis, and we felt like the more the officers were interacting with the inmates, the more they're there. They're going to be increasing the risk of detection, right, but also removing excuses because they're going to be there to be approached if there's a personal problem that, if not addressed, might lead to self harm. So there's a lot of reasons why we think that this kind of physical interaction by ensuring that they're going to be doing the rounds in there physically could make a difference, and so this was the technology that was selected.

It's based on RFID technology. So it's like those cards that you use, proximity cards to get in and out of buildings, and there's boxes placed periodically around the floor, so that you can ensure that the officers, he or she, does the rounds taps with this blue — what do you call it?

**Audience Member 1:** Pipe.

**La Vigne:** Pipe, the pipe. They use the pipe and touch the pipe on this to demonstrate that they've been there physically, and that's about as much as they know about it. And Sara and Chief Wildes can tell you more because they've seen it implemented, and I have not.

So what we're doing right now is we're tracking implementation, and the end of that year, Sara, is, what, September? Yeah. So we're not quite through the year mark on the actual implementation of the intervention. Then we're looking forward to analyzing the impact, but I believe Chief Wildes has some anecdotal evidence to share with us.

So I have three minutes, and I'm just going to throw out some lessons learned, and then, hopefully, we'll have time. I know some of you are researchers, some of you are practitioners. You both know the pros and cons of engaging in these kinds of partnerships. They can really rewarding; they can also be quite challenging.

From our perspective as researchers across these three projects, I think that it's real important to find the true champions, people who really embrace research based practice, and, you know, I think by now I know how to find them, but I don't think I knew a few years ago. There's people who say “yes” to everything, and then there's people who really mean it. And then you've got to hope that they stick around because they're the really good ones and they often end up moving somewhere else. There's no control over that.

And that's one of the reasons why I increasingly think that when we write proposals, Winnie, we should propose more sites than we ever intend on evaluating. We've talked about this before, but more often than not, there's going to be one or two or more sites that just don't get off the ground for reasons that are beyond virtually any single individual's control.

Encouraging adherence to the model, the more you do it, the better, because we know that adherence to the model is more likely to yield the desired effect.

We do believe that it's important to not just be quantitative in our approach but also to collect qualitative data because that kind of context is really important in interpreting our findings. The longer the evaluation period, the better, resources permitting.

And then this is my own personal question mark. I always want to isolate what about an intervention makes a difference, but with situational crime prevention, that's sometimes difficult. Sometimes there's multiple interventions, so you don't really know what's making the difference, and I'm wondering if I should just stop worrying about that, but maybe we can talk about that later.

Thank you for your time.

**Reed:** Thank you, Nancy.

[Applause.]

**Gary Wedge:** Thank you.

OK. First of all, has everybody heard of Chula Vista? Everybody knows where Chula Vista is before today's presentation? If you haven't, we are about five minutes north of the U.S. Mexico border, one of the most southwesterly cities in the country. We are a population of about 235,000, predominantly Hispanic now, about 52 percent. That continues to change, looking at our elementary schools. We've got about 80, 81 percent Hispanic, so you can see how the demographics, the population is changing over the years.

About 51 square miles. No real distinction or claim to fame. Forbes magazine, I think it was last year, ranked us the most boring city in the United States. You know, having said that, it is a beautiful community. We enjoy a relatively low crime rate, home to one of four Olympic training centers in the country, got a very nice bay front that is as of yet completely undeveloped or partially developed.

Last year, that's our Little League Championship World Series team from Chula Vista, put us on the map.

But the city is changing, and, unfortunately, our city is tied — the budget is tied largely to the growth of our city, the housing, and when the housing market crashed, so did the budget and the city and actually in advance of some of the economic problems that other cities went through. So that impacted our project just a little bit, and I'll talk about that.

OK. I was going to talk a little bit about Safe City, but Nancy did a great job explaining what Safe City is. We were approached by the Target Corporation in spring of 2006. At that time, we decided to participate in the project. We gave the project to our then community relations unit, which consisted of a sworn police sergeant and two civilian police community relations specialists. We also had an analyst assigned to the project, Karin Schmerler, who is actually the reason behind the success of our project. I think Karin and I had a number of debates over whether things were appropriate, whether they weren't appropriate. I am, more or less, an advocate for cameras; Karin is not. We met sort of in between. I'll talk about that.

So it was given to our community relations unit, and, again, as Nancy said, it's not a whole lot different than a problem solving effort with perhaps a little more emphasis on the use of technology. Target did push heavily for the use of technology; in particular, cameras. When Target began their Safe City program in Minneapolis where their corporate headquarters are housed, there was that reliance on technology. They spend a significant amount of money, anywhere from $5[00,000] to $600,000, on infrastructure for the camera system, as well as radio communications for a lot of the businesses.

Those of you who are familiar with Minneapolis know that it's much like been described as a “Haba trail,” a lot of buildings with a lot of connecting tunnels. The radio communications enabled them to be successful in their project.

So, looking at our focus area, you can see where the orange oval is on the north part of the map. The yellow outlines our city and the current beat structure, but our Safe City area actually overlapped two cities, Chula Vista and then, our neighbor to the north, National City. And the reason we did this, at the time we implemented Safe City, the two cities were going through a process to realign the borders, realign the boundaries, and we thought it was going to happen within a year. Well, unfortunately, the problems with the economy hit, staffing changes, a lot of staffing reductions. So that was put on the back burner, but because it fit so nicely in the project area, we kept it in there. It did present a couple of challenges, which I'll touch on later on, but it was a natural fit.

And then more specifically, looking at our focus area, obviously Target being one of the anchor stores, there is a Wal Mart just to the west of the Target, a total of 55 businesses in our Safe City zone, as well as a government building, Department of Motor Vehicles, and a city park on the south side.

OK. Just real quickly on the process, again, not unlike a problem solving effort, this isn't necessarily in the order that they were done. We identified the focus area, as you've seen, did our analysis — I'll touch on that in just a minute — a couple of very lengthy, very thorough CPTED assessments as well as stakeholder meetings.

Now, we did have a number of meetings throughout the project initially with all the stakeholders who were interested in participating. We did get a good turnout; I want to say between 45 and 50 participants representing a significant number of businesses. And then we also established a steering committee made up of not only representatives from the police department and other city departments but also, obviously, the business owners. And then we staggered the meetings. One month, we would do an all partner meeting; the next month, we would do the steering committee.

We also had the funding drive. Nancy talked about how Target would roll out this great big check, great media event, great publicity for Target, but I got to tell you Target was an incredible corporation to work with throughout this whole process. They did push a lot for certain things, but when we pushed back, said we didn't want to go down that road, they were fine with it.

But at the funding drive, we had been told all along that Target was looking at funding us with about $35,000. They wouldn't commit to an exact amount. When we had our media event to roll out the Safe City project, they gave us a check for $100,000, and then we had raised several thousand dollars from some of the other businesses in the area, gave us the funding to start what we wanted, some of the projects that we wanted to do and then, of course, the project implementation.

Now, we had to decide what we were going to focus on. So, when we began the project after we took it on, we wrote up a little flyer on what Safe City was. We had a number of people from the police department go out to the Safe City area, hand deliver the flyers to every business in the area, talk about the Safe City model, what we were trying to accomplish, inviting the folks to our first stakeholder meeting, and then giving them a survey to ask them what concerns they had, had they experienced any one of these problems during the recent six months.

We also looked at calls for service, looked at crime reports, crime statistics, and then we surveyed the officers to get their perception on problems in the Safe City area, and from that, we came up with — you see the three areas that we focused on.

Far and away, the most significant reported problem was unwanted persons on property. This was transients, panhandlers, but also day laborers, and then, obviously, shoplifting and then vehicle theft.

OK. I mentioned the CPTED assessments. We did the daytime CPTED assessment. We had a number of people from the steering committee and the stakeholders from the businesses walk through the area with us to do the assessments as well as the community relations specialist from community relations to do the assessment and document what we found, and the we also did one at night, again, with a number of people. We also had a number of officers participate who had volunteered for the project and went along for the assessment, and we found what people typically find on CPTED assessments, shrubbery, a lot of the light issues, lighting being a problem, and then some of the access, interestingly enough, from some of the transient encampments.

Now, to get a quick win, one of the things that we did was worked with our city graphics, graphic artist, to develop a handful of signs that we could post throughout the Safe City area. Obviously, you can see them up there. I won't go into all the specifics, but, you know, again, what Nancy said, sort of reinforcing what is unlawful behavior, telling them what people can and cannot do.

We also wanted to brand the Safe City area, so we came up with a sign in the middle. If you're ever down in Chula Vista, you'll note that these signs are still prominently displayed throughout. We had initially identified about 175 locations. I think ultimately we ended up with just shy of a hundred signs, but, nonetheless, they are pretty much everywhere.

Now, we also worked with a steering committee to identify the order in which we wanted to tackle these projects, and, in retrospect, we were far too aggressive in our timeline. We didn't even really stick to this timeline, but this is what our goal was. Sequentially, more or less, that's what we stayed true to, but these were the areas we focused on.

Now, I mentioned the involvement of patrol. This was one of the more significant parts of the project as well for a number of reasons. Not only did it show the business owners that we had a great deal of interest on the part of patrol officers, but the patrol officers became more familiar with what was happening in that area. Consequently, they spent more time in the area. They knew what we were trying to accomplish. They knew what the issues were. So that in itself, we believe, impacted some of the perceptions that were out in the Safe City area.

More importantly, I think they were also that direct point of contact for the business owners and the employees of the businesses. Once we opened those line of communications between the patrol officers and the folks from the different businesses, the stakeholders, and they had a go to person, it addressed a number of their problems that in the past they had reported problems with getting done, not knowing who to go to, feeling like they were being given the runaround. Now they had somebody in particular that they could reach out to who could help them with their problems. And time and time again, we got feedback from the business owners that it made a difference, and it eliminated a lot of the red tape of the process that was typically involved.

Just to run through some of the accomplishments, we talked about signage. There were a number of things we accomplished, a number of things that we had hoped to accomplish, but for some reasons I'll touch on in a minute, we couldn't do.

But another one of those was window clings that we were able to do, put together small, little, static, vinyl clings that went on windows throughout the businesses, prominently displayed, essentially reminding people or asking patrons to call the police if they saw something suspicious, you know, a very minor thing but something that reinforces the fact that people are looking out for one another in the Safe City area.

We also cleared a number of transient encampments, not a huge transient problem, but, consistently, there'd be anywhere from three to five transients at any given time at any part in the Safe City area that were in this particular gateway, the Safe City area being a gateway on the north part of our city. So we were able to clear the transient encampments on the south side of the Safe City zone.

As part of that, we were also able to fence off an area that provided basically unrestricted access for the transients to get into the Safe City area. So, by erecting the fence, that limited their access or made it more difficult, more challenging for them, so they had to take a longer route and consequently were less likely to do it.

Now, one of the bigger parts of the project, of the Safe City project in general, was a day laborer issue. Now, this was kind of an interesting beast. Day laborers, if you look at calls for service only, wasn't a big problem, but when we went out and we talked to the business owners, we found that most of the businesses in the day laborer zone were directly impacted. They felt that it intimidated their customers, people weren't shopping there, and we asked them why they weren't calling, why the calls for service didn't reflect that, and they said they had just given up. They felt that there was nothing that could be done. They tried to call border patrol. Border patrol wouldn't come out. You know, there were just a number of issues.

So we took on a number of smaller parts to this project. We met with not only the business owners, but we also had a number of meetings with the day laborers themselves. Using some of the Safe City money, we used the services of a translator who could do simultaneous translation, and we sought their feedback.

What we found was most of the day laborers were people who had been there long term. The ones who were causing most of the problems were the folks who were coming in working for a week or two and then moving on. So the day laborers, obviously they didn't want us there, and they didn't want us there certainly anymore than we wanted to be there, but they knew that these transient day laborers were the ones causing the focus, causing the emphasis to be placed on them and really creating those issues.

So they came up with a number of suggestions, looking at ways to perhaps reduce that. Again, we had the signs identifying that it was an alcohol and a drug free zone. You know, a number of the complaints being people were drinking alcohol which caused them to urinate in the bushes, obviously created some issues.

To help the day laborers in what they were trying to accomplish, we made signs that businesses posted in the area directing them to a certain location on the southeast part of the day laborer zone.

We also implemented some traffic calming measures because we restricted the hiring of the day laborers to a small area, and we were able to do that with the help from a then unbeknownst to us, or initially unbeknownst to us, California vehicle code section which said solicitation was unlawful within 500 feet of any off ramp from a freeway.

Now, we interpreted that to mean 500 feet radius. So that conveniently happened to push the day laborers into an area on the south side of the map. You can see — if I can use this nifty little laser — the little white highlighted area, not the entire area, but on the north end of that white area is where we were able to restrict the day laborers from lurking, had a significant impact on the problem in the area.

I'll tell you what really had the greatest impact was the first meeting we held between the day laborers and the businesses. We had one business owner who was particularly vocal. We were a little concerned when he showed up to the first meeting because we thought there was going to be some pretty significant issues between him and the day laborers. He was clearly frustrated. He explained to the day laborers that he didn't want them standing in front of his driveway because it was intimidating customers and went on and spoke about a number of the concerns he had.

The following day, the day laborers had self policed themselves, moved away from the driveway and to this day have not gone back. So, again, the communication was a huge part of the success in that part of the project.

OK. A few more of the project accomplishments. Some of the security procedures were revised. We did meet early on with representatives from the big three: Target, Wal Mart, and then a strip mall to the north, South Bay Marketplace, to look at ways of joining security forces or coming up with some consistent ways of doing business. Wal Mart revised their security procedures. They were pretty close lipped about everything that they did, but suffice to say they did change their procedures, took a more proactive approach and had an impact as a result on robbery.

I'm going to wrap this up in the next few minutes. Thank you.

We also worked with a sober living facility to provide services to some of the folks in the area who had substance abuse problems and implemented most of the more than 50 CPTED recommendations.

So, now, Nancy had talked about our evaluation, crime being reduced by 23 percent, robbery seeing the most significant reduction, 53 percent, and then vehicle theft. Based on the survey, I should say, pre and post, we saw that the panhandling, the unwanted people, unwanted persons in the area was down as well.

Strengths. I talked about the communication, far and away the greatest strength, and the partnership that developed, but also having an active steering committee was one of the big benefits because they were the folks who really drove this process.

And, again, we didn't rely on the technology. We did have a vendor come out and we walked the Safe City area, got a bid on cameras, looked at erecting 12 cameras. The bid they gave us is about $350,000, cost prohibitive at that time. We felt that the efforts to raise the money would have taken away from the other things we were trying to accomplish, and besides, Karin is an intimidating person and talked me out of it.

[Laughter.]

**Wedge:** Some of the challenges. Projects overlapped in the two cities, didn't create a number of problems, but when we went to a PBID process — I'll talk about that briefly — it did create a few issues.

Personnel changes. Because of the economy, our city staff has gone from about 1,300 at its peak 3 years ago down to about 900 now. With those changes came changes in the police department. We lost about 8 or 9 percent of our sworn staffing. We eliminated our community relations unit. Fortunately, we've been able to save one person with some grant funding, but because of that reduction in staffing, some of the projects took longer to accomplish from that, and that resulted in a frustration among some of the partners, which in turn led to that loss of momentum.

And then, finally, where we're at now, we are, more or less, in a maintenance mode. We are still looking at some of these projects. One of the things we were going to do for the auto theft is subsidize a kill switch. We found in 2006 about 30 percent of the cars that were stolen in the Safe City area belonged to employees. So we were going to use some of the Safe City funding and work with the Best Buy business in the Safe City area to do low-cost kill switch implementations.

And where we're at now is working through a PBID process, property based improvement district. It's really just a self assessment where people can use the money for environmental enhancements, marketing, security, area identification, things like that.

And then, at some point in time, we hope to transition the leadership from the police department taking the lead on everything to where the steering committee is now driving more of what's happening in the Safe City area.

And I know we're going to do questions later on, so I will back out of that. Thank you.

**Winnie Reed:** Thank you, Gary.

[Applause.]

**Tara H. Wildes:** I cannot talk as much or as well about Jacksonville, Florida, as Gary could about Chula Vista. We are the homicide capital of Florida right now as we speak. We're also number one in several sexually transmitted diseases, and I can think of lots of other number ones that may not speak so well for where Jacksonville is in the Florida hierarchy.

We're not as famous as Orlando. We don't have Disney. We're not a tourist destination like Miami or Tampa. We're just this little spot up in the northeast corner of Florida, and we got the Jacksonville Jaguars. We've got an NFL team. Yay! That's about our claim to fame.

But we are a good sized city. We are one of the six major metropolitan areas in the state of Florida.

There it is. As you can see, it's a lovely facility. We built it right on the river, prime real estate property, and we did this before the real estate boom. So that kind of tells you where sometimes the thought processes of our particular community are.

In 1991, we built this facility. We didn't want to do direct supervision, even though that was the cutting edge corrections process for the day, but that cost too much in personnel. So we built this podular design facility, which is if you can remember the old Mad Max movies, the “Thunderdome,” that's kind of what the dorms look like. I'll show you that in a little while.

And, as you can see, our bed count, our capacity is 2,189, and it's currently, as of the day I made this slide, was 2,733. Now, you can address that by adding more bunks. One of the things we did when we first started this project was we had what was called “boat beds.” They're actually plastic portable bedding units, but “PBUs” were too hard to say, so we called them “boat beds.” And those were temporary beds that we sat inside the day rooms and the dorms for inmates to sleep in to help resolve some of the overcrowding.

Eventually, we added a third bunk to the already double bunked cells, and that, again — we've got the capacity now of a little bit over 3,000. So, even now, we're approaching that.

In 2006, we met with the Urban Institute, and I won't get back into what Nancy described as the whole backup of the research project. A lot of correctional facilities do not get involved in research because they don't see any end benefit to them. They see it as additional work with, you know, you're not getting paid additionally from a grant. You're not really gaining anything from it except you get a lot of hassle from people coming in, talking to your inmates, talking to your staff, and sometimes finding out things you really don't want to know. However, from my perspective, I can say that there are a great deal of benefits to that.

Number one, you need somebody to come in and tell you the things that you really don't want to hear. You need that independent perspective to come in and help you improve your system, and that's one of the things, one of the benefits that we have got from this process.

When we first started on this project, we found that there was not a — as I highly suspected, there wasn't a lot of sexual assault within our individual facility. There was some, but real legitimate assaults, inmate on inmate assaults were very rare.

However, I'll tell you a bad story. Right before we got started on the implementation part of this project in September of last year, we had a real sexual assault occur inside one of our cells, and this is a tragic story, but it just illustrates why it's important to follow up on these kind of things. A lot of times people think, ah, they're inmates, they're in jail, they get what they deserve. This was a young man. The victim was a young man. He was arrested for grand theft. So he's placed inside a felony cell, triple bunk cell with two other felony defendants. They're all classified as pretrial. They're all nonviolent offenders.

This young man was in jail for grand theft. He took a gold bracelet from his brother and went and pawned it and bought an iPod with it. Well, dad said, “I'm going to teach you a lesson,” and he called the police and reported the theft of the bracelet, and the young man was arrested and he went to jail to teach him a lesson.

Well, he got taught a lesson. He was sexually assaulted by one of his cell mates pretty brutally. He didn't tell anybody. The only way we found out about it was when the other cell mate who did not participate in the rape came forward on his way out of the system three days later and said, “Hey, you need to check on the kid in my cell because the other dude had his way with him.” We went up, investigated; sure enough found out that it happened.

Now, that's a bad story. The kid was bonded out the next day. Family decided, I guess, he had learned his lesson at that point, but anything that we can do to prevent that sort of thing from happening in a facility — our facilities are supposed to be safe. They're also supposed to be humane, and, yes, they're also supposed to be a place that's designed as punishment, but that's not the kind of punishment that it's designed for.

So, based on that, I was really delighted that we had the opportunity to try to do something to prevent that kind of violence from occurring in our facility.

Now, everybody up here has said something about the changes that have taken place during the research project. One thing you can say about people doing research with people, with human subjects, nothing is ever static. Everything changes. During the course of this project, we've increased, and we've upgraded our cameras. We've gone from an analog to a digital system. We've added recording of our recreation areas. We've started a jail intelligence unit where we track security threat groups and house high profile defendants in a different manner. We've improved our mental health care. We've replaced items that are used as weapons with more difficult to modify models. We've gone to a much smaller razor, for example, that's a lot harder to be made into a shank. We've gone to one piece mop buckets. Everything that you think of that can be made into a weapon; inmates can make it into a weapon.

And something else, too, and this will come up a little bit later, but no matter how rugged it is, if it can be torn up, an inmate can do it, and an officer can do it better.

Here's the way we used to keep data. It really wasn't quite this bad, but it was really —

[Laughter.]

**Wildes:** This was close to it. This was real close to it. When we started the project, we had a very flat data collection system. Our incident reporting system, we wrote reports for everything, but we collected very small bits, just the very essential pieces of data. The data that was required by law was all we kept. So it was really hard to pull some of the things that we needed to analyze out of that system.

Well, now, this is just an example of just one of the reports that comes from our reporting system, and Sara and Nancy haven't even got a chance to see some of the — because that's recently changed, but now we can get virtually every data element involved in incidents. I mean just common everyday incidents, the finding of contraband, inmate fights, of course, sexual assaults and all of the major things, but anything that we have to write an incident on now, we're able to. It goes into our data warehouse. We're able to slice it and dice it any way you can think of. Plus, that all rolls into our intelligence unit as well, and we are really able to do some really neat tracking of problems throughout the system that way.

One of the things that we found as recommendations from the Urban Institute's review of the surveys that they did was that we did need to revise our classification system to more of a behavioral based process. We needed to implement more staff rounds tracking, and that's the piece that we finally decided to focus on because what we found was what constitutes a round was different in the eyes of some correctional officers as opposed to the eyes of the correctional administration. When we would say make a round, we meant, you know, get up, walk, you know, out of the pod, down into the cell, walk around the cell, look around, make sure everybody is OK and walk back out. What they said, “Oh, we did a round. It was a visual round. Looks good,” and that was how a lot of cases — and they would type it in the system, did my round. And we found that there was a disconnect, and it wasn't just the fact that they weren't doing their rounds. It was that some were doing more rounds than others, and if you think about it, how that creates a conflict between officers, between staff at the line level, because some people are doing more work than other people, some people are getting away with doing less work or what's perceived to be less work.

So we decided if we implemented the rounds tracking devices, we would level that particular playing field, and we would also get some good quantifiable data about how often the officers are down in the dorms and interacting with inmates.

This is a view from inside the dorm. You're on the upper level of the dorm looking down. That big area there is the day room. These dorms, this particular one would originally have been a 48 person dorm, but now that we've triple bunked it, it's a 64 person dorm. And that's how large each one of the dorms are in the facility, and there's six floors in the facility.

Now, here's where the officers work. This is inside the pod, looking out. As you can see — now, it's a little bit glarier than it actually is because when we're actually in there, we turned the lights down, and you can see into the dorms better with those lights down. You don't have so much glare, but, still, that's — and there's four of those large dorms around each pod. So you can imagine that's — there's ample opportunities for inmates to get away with stuff. You've got one, maybe two security officers who are making rounds inside the dorms, and then you've got one officer up here in the pod who essentially are watching the officers making the rounds. And you've got now probably an average of 300 to 400 inmates on each one of these pods, and you can see that it's not easy to keep up with what's going on.

We talked already about the reasons why we went to the rounds tracking system, and we looked into a lot of different products. I would have loved to have had the full service RFID which is where it would just essentially track the officer everywhere they went, but you're talking upwards of a million dollars to install a wireless system, an RFID system in a large aging facility that we're likely going to move out of within the next decade. And I couldn't convince the budget powers to be that that was something that we needed to go with; however, we were able to get the budget model, which is the pipe, which essentially is just a series of those buttons. And you just have to go. As an officer, you go and you have to be within the proximity of that button to record your round, and then those rounds are then downloaded later on.

It's not a real time system, which I was disappointed in that. I wanted something that would give us that data right away, but now they go and they downloaded at the end of their shift, and we're able to see what kind of rounds they're making.

So we're still in the process of refining our reports, and the good thing is we've had a couple of issues that have come up right away that we've been able to determine things didn't happen because we were able to prove officers were in the proximity when things were alleged to have been occurring inside of dorms. So that's been one positive out of it.

We've been able to eliminate some manual data entry, some typing in of rounds and things like that on the computer because now they're collecting that with the pipe system.

The anecdotal information from the inmates has been really very positive. Again, this is just the inmates telling us things, but they say that they do have more access to the officers. They say that there is less commissary theft. One of the other recommendations was for us to try to get a place that the inmates could lock up their personal belongings, and we're still trying to come up with a solution for that. Whatever solution that we seem to come up with that we think that we may be able to work out, we've not been able to get funding to do. So we're still trying to look for a budget solution to that as well. But, in the meantime, the inmates are telling us that the officers making the increased rounds are holding down the commissary theft. And, again, like I said, some of our personnel have said, “Hey, I like it because Joe over here who won't ever do nothing, he's having to do the same amount of work that I'm having to do now.”

Now, the challenge is they told us when we got this pipe system, oh, they can't tear them up, they're in correctional facilities all over the United States, we don't have any problems, they're extremely rugged. Well, we have put their ruggedness to the test, and, in fact, right now they're talking to us about voiding our warranty on the products because we have had so many of them that we've had to have replaced. We're working through that with them.

We've had some negative reaction from the corrections personnel, and I think maybe that's why some of them haven't been quite as rugged as advertised. I think we've had some officers who may have been overly enthusiastic in their use of the devices as far as, you know, their hitting the button, so to speak. “Oh, I thought you had to hit the button.” No, you just have to get it in the proximity of the button.”

And we're also working through a process of how we are addressing. When we pull those reports and we see rounds weren't made in a timely manner, what is our response as management? Is that something that we look at for retraining? Do we begin to take disciplinary action? Do we progress in that disciplinary action? And what we've done from this point is we've looked at the first — we take the first instance that somebody isn't making their — somebody is not making their rounds properly, and we address that with counseling or training. And then from that step on, we will move with progressive discipline. Now, if there is a reason why they cannot make their rounds, there is an incident occurring, they are, you know, feeding up or they're doing something else, then they have a way of recording those things, so it's not an unforgiving system, so to speak. There are ways that that can be done, but yet they are responsible for making those rounds, and they're just going to have to get them done.

One of the other things, too, that made the project much more acceptable in the officers' eyes is throughout this research we included them in on the decision making process. We made sure that we had personnel, the personnel that would actually be using those devices in on the research. We had them in on the testing of the product, and we also had them in on the writing of the policy and the procedure and the eventual response to, you know, misproduced rounds. We had them come in and be completely involved in that, and that was a big help because I think when you make a systemic change like this, if you do not have that buy-in from the line level personnel, it is very easy for them to sabotage a project or prevent it from working as well as it could have.

So, hopefully, what we're going to do in the future is we are going to analyze the incident data. We're hoping that it will show a reduction in violence, in self harm attempts and things like that within our system. We do want to continue and add the inmate storage for personnel property, and we do have plans as well, budget permitting, to expand our camera system as well into the inmate housing areas. We currently have a camera system that watches all of our processing areas and our releasing areas, which is where our highest propensity for violence occurs, staff versus inmate type violence within the facility. Now we need to expand into those areas where inmate versus inmate violence has the highest propensity to occur.

So thank you, and you guys come see us.

**Winnie Reed:** Thank you very much.

[Applause.]
    
  
Disclaimer:
              Opinions or points of view expressed in these recordings represent those of the speakers and do not necessarily represent the official position or policies of the U.S. Department of Justice. Any commercial products and manufacturers discussed in these recordings are presented for informational purposes only and do not constitute product approval or endorsement by the U.S. Department of Justice.
  
Date Published: June 1, 2010
    
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