Combating Alien Smuggling: The Federal Response Can Be Improved
Published: 2005-07-12T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Globally, alien smuggling generates billions of dollars in illicit revenues annually and poses a threat to the nation's security. Creation of the Department of Homeland Security (DHS) in March 2003 has provided an opportunity to use financial investigative techniques to combat alien smugglers by targeting and seizing their monetary assets. For instance, the composition of DHS's largest investigative component--U.S. Immigration and Customs Enforcement (ICE)--includes the legacy Customs Service, which has extensive experience with money laundering and other financial crimes. Another DHS component, U.S. Customs and Border Protection (CBP) has primary responsibility for interdictions between ports of entry. In summer 2003, ICE announced that it was developing a national strategy for combating alien smuggling. This testimony is based on GAO's May 2005 report on the implementation status of the strategy and investigative results in terms of convictions and seized assets.
section_title: What GAO Found
paragraphs: As of July 5, 2005, ICE had not finalized its strategy for combating alien smuggling. ICE was adjusting the draft strategy to focus on the southwest border and encompass all aspects of smuggling, aliens as well as drugs and other contraband. In adjusting the strategy, ICE officials stressed the importance of incorporating lessons learned from ongoing follow-the-money approaches such as Operation ICE Storm, a multi-agency task force launched in October 2003 to crack down on migrant smuggling and related violence in Arizona. Also, the strategy's effectiveness depends partly on having clearly defined roles and responsibilities for ICE and CBP, two DHS components that have complementary antismuggling missions. CBP is primarily responsible for interdictions between ports of entry and ICE for investigations that extend to the U.S. interior. In this regard, ICE and CBP signed a memorandum of understanding in November 2004 to address their respective roles and responsibilities, including provisions for sharing information and intelligence. Currently, however, there is no mechanism in place for tracking the number and the results of referrals made by CBP to ICE for investigation. CBP and ICE officials acknowledged that establishing a tracking mechanism could have benefits for both DHS components. Such a mechanism would help ICE ensure that appropriate action is taken on the referrals. Also, CBP could continue to pursue certain leads if ICE--for lack of available resources or other reasons--cannot take action on the referrals. In fiscal year 2004, about 2,400 criminal defendants were convicted in federal district courts under the primary alien-smuggling statute, and ICE reported seizures totaling $7.3 million from its alien-smuggling investigations. For the first 6 months of fiscal year 2005, ICE reported $7.8 million in seizures from alien-smuggling investigations. A concern raised by ICE and the Department of Justice is the lack of adequate statutory civil forfeiture authority for seizing real property, such as "stash" houses where smugglers hide aliens while awaiting payment and travel arrangements to final destinations throughout the nation. However, Justice does not have a legislative proposal on this subject pending before Congress because the department's legislative policy resources have been focused on other priorities.

section_title: Letter
paragraphs: I am pleased to be here today to discuss federal efforts to combat alien  smuggling. This transnational crime globally generates illicit revenues  estimated to total billions of dollars annually and is recognized as a  significant and growing problem that can pose a serious threat to the  security of the United States, a primary destination country. Although it is  likely that most aliens smuggled into the United States seek economic  opportunities, some are brought into the United States as part of criminal  or terrorist enterprises. This concern has heightened since September 11,  2001. Creation of the Department of Homeland Security (DHS) in March  2003 has provided new opportunities to more effectively combat alien  smuggling, particularly in reference to using financial investigative  techniques to target and seize the monetary assets of smuggling  organizations. For instance, the department’s largest investigative  component—U.S. Immigration and Customs Enforcement (ICE)— integrates the legal authorities and investigative tools of the legacy  Immigration and Naturalization Service (INS) and the U.S. Customs  Service, which has extensive experience in combating money laundering  and other financial crimes. Another DHS component, U.S. Customs and  Border Protection (CBP), has a complementary antismuggling mission  with primary responsibility for interdictions between ports of entry. Given  their complementary antismuggling missions, CBP makes referrals to ICE  on alien-smuggling interdictions that may warrant further investigation.
At congressional hearings 2 years ago, in June and July 2003, ICE officials  testified that ICE was developing a national strategy to dismantle criminal  and terrorist organizations that smuggle or traffic in people by tracing and  stripping away their monetary assets. My testimony today will address two  principal questions:    First, what is the implementation status of ICE’s strategy for combating  alien smuggling, particularly regarding efforts to use financial  investigative techniques to follow the money trail and seize the  monetary assets of smuggling organizations?
Second, since the creation of DHS and ICE, what results have been  achieved from alien-smuggling investigations in terms of prosecutions  and convictions, as well as seizures of smugglers’ monetary assets?
My testimony is based on a report we issued in May 2005 to the House  Judiciary Subcommittee on Immigration, Border Security, and Claims.  Also, on July 5, 2005, we contacted ICE headquarters to obtain an update  on the implementation status of ICE’s strategy for combating alien  smuggling.
subsections: section_title: Background
paragraphs: By definition, alien smuggling (sometimes called people smuggling or  human smuggling) is transnational in that it involves more than one  country and also usually involves persons who have consented to be  transported to another country. This activity generally produces short- term profits for the smugglers. That is, after the aliens reach their final  destinations, they have no continuing relationship with the smugglers. In  legal and diplomatic references, alien smuggling is distinct from human  trafficking, although both smuggling and trafficking may have similarities  or common elements. In human trafficking, the criminality and human  rights abuses—such as coercion for prostitution, labor sweat shops, or  other exploitative purposes and servitude arrangements—may continue  after the migrants reach the United States in order to produce both short- term and long-term profits. Whereas a trafficked person is a victim, an  alien who consents to be smuggled is subject to criminal processing and  deportation.
Given the underground nature of alien smuggling, exact figures quantifying  the size or scope of this transnational crime are not available. Nonetheless,  estimates by the United Nations and the federal law enforcement and  intelligence communities indicate that people smuggling is a huge and  highly profitable business worldwide, involving billions of dollars  annually, and the United States is a major destination country. People  smuggling is a continuously growing phenomenon, according to the  International Criminal Police Organization (Interpol). The types of  smugglers can range from opportunistic business owners who seek cheap  labor to well-organized criminal groups that engage in alien smuggling,  drug trafficking, and other illegal activities. Partly because of increased  border monitoring by governments, Interpol has noted that criminal  networks increasingly control the transnational flow of migrants. That is,  willing illegal migrants increasingly rely on the services of criminal  syndicates that specialize in people smuggling, even though traveling  conditions may be inhumane and unsafe.
Alien smuggling generally is prosecuted under section 274 of the  Immigration and Nationality Act, which prohibits knowingly or recklessly  bringing in, transporting, or harboring certain aliens. Depending on the  conduct charged, a conviction under section 274 could result in a  maximum penalty of 10 years’ imprisonment per alien smuggled.  Moreover, significant enhanced penalties are provided for some section  274 violations that involve serious bodily injury or placing life in jeopardy.  If certain violations result in the death of any person, the convicted  defendant may be punished by imprisonment for any term of years or be  subjected to a death sentence. Other federal criminal statutes may also be  applicable. Specifically, alien-smuggling-related offenses are among the list  of Racketeer Influenced and Corrupt Organizations predicate offenses (18  U.S.C. § 1961(1)) and also are included within the definition of specified  unlawful activity for purposes of the money-laundering statute (18 U.S.C. §  1956). Further, criminal and civil forfeiture statutes may apply to alien- smuggling cases.
Although ICE is a primary DHS component for investigating alien  smuggling, combating the smuggling of aliens into the United States can  involve numerous federal agencies, as well as the cooperation and  assistance of foreign governments. In addition to ICE, other relevant DHS  components are the Border Patrol (a “front-line defender”), which is now  part of CBP, and the U.S. Coast Guard, which is tasked with enforcing  immigration law at sea. Additionally, significant roles in combating alien  smuggling are carried out by Department of Justice components, including  the Criminal Division, the Federal Bureau of Investigation (FBI), and U.S.  Attorney’s Offices, and Department of the Treasury components, such as  Internal Revenue Service (Criminal Investigation) and the Financial  Crimes Enforcement Network (FinCEN). Further, Department of State  components have significant roles. For instance, the Bureau of Diplomatic  Security—the law enforcement arm of the State Department—is  statutorily responsible for protecting the integrity of U.S. travel  documents. Perhaps the most coveted and sought after travel documents  in the world are U.S. passports and visas. Alien smuggling and travel  document fraud often are inextricably linked.
An interagency coordination mechanism to help ensure that available  resources are effectively leveraged is the National Security Council’s  Migrant Smuggling and Trafficking Interagency Working Group, which is  cochaired by State and Justice. The Interagency Working Group has a  targeting subgroup, whose role is to identify for investigation and  prosecution the most dangerous international alien smuggling networks,  especially those that pose a threat to national security. Another  coordination mechanism is the Human Smuggling and Trafficking Center,  an interagency entity for disseminating intelligence and other information  to address the separate but related issues of alien smuggling, trafficking in  persons, and clandestine terrorist travel. Although its establishment was  announced in December 2000, the center was not operational until July  2004.
The March 2003 creation of DHS, including its largest investigative  component (ICE), ushered in an opportunity for developing a strategy to  combat alien smuggling by, among other means, using financial  investigative techniques. Two months later, in May 2003, ICE used such  techniques to follow the money and prosecute the perpetrators of a  smuggling operation that had resulted in the deaths of 19 aliens in Victoria,  Texas. The Victoria 19 case has been cited by ICE as representing a new  model for fighting alien smuggling—a model that ICE (1) subsequently  used to launch a multi-agency task force (Operation ICE Storm) in the  Phoenix (Arizona) metropolitan area and (2) reportedly was using to  develop ICE’s national “Antismuggling/Human-Trafficking Strategy.”
section_title: ICE’s Strategy for Combating Alien Smuggling Not Yet Issued
paragraphs: Although its development was announced as early as June 2003, a national  strategy for combating alien smuggling had not been finalized and  implemented by ICE as of July 5, 2005. During congressional testimony,  an ICE official said ICE was developing a strategy that would address alien  smuggling (and human trafficking) at the national and international level  because as in the war on terrorism, the most effective means of addressing  these issues is by attacking the problem in source and transit countries to  prevent entry into the United States. In the absence of a national strategy  to combat alien smuggling, including investigating the money trail, ICE has  used various means to provide interim guidance to investigators. Such  guidance included, for instance, the formation of working groups with  members from various field offices and disciplines, as well as a  presentation at a March 2004 conference of special-agents-in-charge and  attachés. Moreover, ICE said it continues to provide guidance to the field  in the form of training seminars and managerial conferences. Also, ICE  indicated that it has posted guidance and policy memorandums to the field  on its Web site, which is available and accessible to agents at their  desktops for reference. According to ICE, the Web site is regularly  reviewed and updated to ensure that the most recent guidance is available  to the field. Additionally, ICE officials said that headquarters staff  routinely travel to field offices to review ongoing undercover operations  and large-scale investigations to help ensure compliance with existing  policies and priorities.
ICE officials indicated that the draft strategy was being adjusted to  broadly cover all aspects of smuggling—encompassing aliens, as well as  drugs and other illegal contraband—and to focus initially on the  Southwest border, between the United States and Mexico—the most  active area in terms of smuggling activity and open investigations. The  officials explained that ICE was developing a comprehensive southwest  border strategy, given the anticipated displacement of smuggling activity  to other areas along the border resulting from Operation ICE Storm and its  expansion statewide under the Arizona Border Control Initiative. The  officials explained that criminal enterprises tend to smuggle not only  people but also drugs, weapons, counterfeit trade goods, and other illegal  contraband. The ICE officials emphasized that irrespective of whether  smuggling involves aliens or contraband, ICE can use similar investigative  techniques for following the money trail. Moreover, the officials said that,  following a certain period of implementation, the Southwest border  strategy would be evaluated and expanded into a nationwide strategy. The  officials noted, for instance, that although there is no one law enforcement  strategy totally effective in all areas of the nation, the methodologies  applied in Arizona with both Operation ICE Storm and the Arizona Border  Control Initiative would be evaluated and tailored for use in other parts of  the country.
The strategy’s continuing development period is attributable partly to  organizational and training needs associated with integrating the separate  and distinct investigative functions of the legacy INS and the U.S. Customs  Service, following creation of DHS in March 2003. Also, ICE and CBP— two DHS components with complementary antismuggling missions— signed a memorandum of understanding in November 2004 to address  their respective roles and responsibilities, including provisions to ensure  proper and timely sharing of information and intelligence. CBP has  primary responsibility for interdictions between ports of entry while ICE  has primary responsibility for investigations, including those resulting  from alien smuggling interdictions referred by CBP. Accordingly, sharing  of information between the two components is critical to achieving ICE’s  investigative objective of determining how each single violation ties into  the larger mosaic of systemic vulnerabilities and organized crime. The  ability to make such determinations should be enhanced when DHS  components have compatible or interoperable information technology  systems—which is a long-term goal of an ongoing, multiyear project called  the Consolidated Enforcement Environment. Currently, however, there is  no mechanism in place for tracking the number and the results of referrals  or leads made by CBP to ICE for investigation, including even whether ICE  declined to act on the referrals. Without such a mechanism, there may be  missed opportunities for identifying and developing cases on large or  significant alien-smuggling organizations. For instance, if a tracking  mechanism were in place, CBP could continue pursuing certain leads if  ICE—for lack of available resources or other reasons—does not take  action on the referrals.
section_title: Prosecutions and Convictions Pursued in Alien-Smuggling Cases; Asset Seizures Expected to Increase
paragraphs: The principal federal statute used to prosecute alien smugglers is section  274 of the Immigration and Nationality Act, which prohibits knowingly or  recklessly bringing in, transporting, or harboring certain aliens. Under this  statute, which is codified at 8 U.S.C. § 1324, about 2,400 criminal  defendants were convicted in federal district courts in fiscal year 2004.  According to federal officials we interviewed, most alien-smuggling  prosecutions stem from reactive or interdiction-type cases at the border,  wherein in-depth investigations to follow a money trail are not warranted.
However, during our field visits in September 2004 to Phoenix and  Houston, we asked U.S. Attorney’s Office officials for their observations  regarding whether there has been an increasing emphasis on the financial  aspects of alien-smuggling investigations since the creation of DHS and  ICE. In Arizona, federal prosecutors emphasized that Operation ICE Storm  is a clear indication of ICE’s efforts to become more proactive in alien- smuggling investigations. Also, federal prosecutors in Texas (Houston)  said the money trail is being pursued when appropriate, such as proactive  cases involving smuggling organizations that are based in the Far East  (e.g., Thailand and certain provinces in the People’s Republic of China)  and have networks in Latin America and Mexico. The federal officials  noted that investigations of these cases may include FBI participation and  the use of undercover agents and electronic surveillance and may result in  assets being seized and suspects being charged with money laundering  and violations of the Racketeer Influenced and Corrupt Organizations Act.  More recently, in December 2004, ICE headquarters officials told us that  ongoing alien-smuggling cases in other areas of the nation—Florida,  Georgia, New York, and Washington—were also using financial  investigative techniques and are expected to result in asset seizures.  Because these cases were ongoing, the officials declined to provide  specific details, other than information already made available to the  public.
For fiscal year 2004, ICE reported seizures totaling $7.3 million from its  alien-smuggling investigations—plus an additional $5.3 million generated  by the state of Arizona under Operation ICE Storm. To obtain additional  perspectives on the results of alien-smuggling investigations in terms of  recovered funds or seized assets, we contacted Treasury’s Executive  Office for Asset Forfeiture, which provides management oversight of the  Treasury Forfeiture Fund—the receipt account for the deposit of nontax  forfeitures made pursuant to laws enforced or administered by the Internal  Revenue Service-Criminal Investigation and DHS components (including  ICE, CBP, the U.S. Secret Service, and the U.S. Coast Guard). The Treasury  officials told us they anticipate that ICE will have increased seizures in  fiscal year 2005 or later, as ICE further applies its financial and money- laundering expertise to address alien smuggling. Similarly, ICE officials  anticipate increased seizures. In this regard, for the first 6 months of fiscal  year 2005, ICE reported seizures of $7.8 million from alien-smuggling  investigations.
As mentioned previously, alien smuggling globally generates billions of  dollars in illicit revenues annually, according to some estimates. How  much of the total involves aliens smuggled into the United States is not  known, although the United States is often a primary destination country.  Also, according to ICE officials, much of the U.S.-related smuggling  revenues either may not be paid in this country or, if paid here, may be  transported or transmitted abroad quickly. As such, federal efforts to  combat alien smuggling by following the money trail frequently may  present investigators and prosecutors with opportunities and challenges  related to identifying and seizing funds or assets not located in the United  States.
To help investigators and prosecutors meet the opportunities and  challenges associated with transnational crime, the United States has  negotiated and signed more than 50 bilateral mutual legal assistance  treaties (MLAT) with law enforcement partners around the world,  according to the Department of Justice. Such treaties—which are a  mechanism for obtaining evidence in a form admissible in a prosecution— provide for a broad range of cooperation in criminal matters, such as  locating or identifying persons, taking testimonies and statements,  obtaining bank and business records, and assisting in proceedings related  to immobilization and forfeiture of assets.
To get a sense of the extent to which federal law enforcement agencies  were using the MLAT process to follow the money trail abroad in alien  smuggling cases, we contacted Justice’s Office of International Affairs,  which is responsible for coordinating the gathering of international  evidence and in concert with the State Department, engages in the  negotiation of new MLATs. According to the Deputy Director, the number  of outgoing requests for formal law enforcement assistance in alien- smuggling cases is few in comparison with cases in drug trafficking,  money laundering, fraud, and various other offenses. For matters  considered to be alien-smuggling cases, the Deputy Director noted that it  would be very difficult to quantify the exact number of requests made to  foreign countries because, among other reasons, the Office of  International Affairs’ database was not originally designed to include a  category of “alien smuggling.”
Also, we asked ICE headquarters for information regarding use of MLAT  requests made in attempts to follow the money trail on alien-smuggling  investigations that have extended overseas. That is, we asked how many  MLAT requests were made in fiscal years 2003 and 2004, to which  countries, and what have been the results in terms of assets tracked or  seized. ICE’s Office of Investigations’ Asset Forfeiture Unit responded that  it had no way of determining the number of MLAT requests. ICE officials  noted, however, that none of ICE’s reported seizures from alien-smuggling  cases in fiscal year 2004 ($7.3 million) and the first 6 months of fiscal year  2005 ($7.8 million) were made abroad.
Generally, regarding asset seizures and forfeitures, ICE officials noted that  there can be competing demands for investigative resources. The mission  of ICE’s Office of Investigations—which has more than 5,000 agents in 26  field offices nationwide—encompasses a broad array of national security,  financial, and smuggling violations, including narcotics smuggling,  financial crimes, illegal arms exports, commercial fraud, child  pornography or exploitation, immigration fraud, and human trafficking.  ICE headquarters officials cautioned that alien-smuggling cases, in  comparison with drug cases, are much less likely to result in seizures of  money. The officials explained that almost all drug deals are conducted in  cash, and it is not unusual for law enforcement to arrest criminals  handling hundreds of thousands or even millions of dollars in drug money.  In contrast, the officials noted that alien-smuggling fees per person  generally involve less money and the alien smuggler is not arrested with  large cash amounts. However, even absent the significant differences in  amounts of seized money or other assets from alien smugglers, ICE  headquarters and field office officials stressed the importance and utility  of applying investigative expertise for determining the scope and  operational patterns of alien-smuggling organizations, identifying the  principals, and obtaining evidence to build prosecutable cases.
Both criminal and civil forfeiture authority have limitations that affect the  government’s ability to seize real property in alien smuggling cases— particularly stash houses used by smugglers. Asset forfeiture law has long  been used by federal prosecutors and law enforcement as a tool for  punishing criminals and preventing the use of property for further illegal  activity. In a criminal forfeiture action, upon conviction, the defendant  forfeits and the government takes ownership of property that the  defendant used to commit or facilitate the offense or property that  constituted the proceeds of the illegal activity. Criminal asset forfeiture is  rarely an option in alien-smuggling cases for two reasons. First, because  criminal asset forfeiture is dependent on conviction of the defendant, it is  not available if the defendant is a fugitive, which alien smugglers often are  according to Justice. Second, because the stash house is often rental  property, it is rare that the property owner is convicted as it is difficult to  establish the owner’s knowledge of the smuggling.
In contrast to criminal forfeiture, in a civil forfeiture action, the  government is not required to charge the owner of the property with a  federal offense. However, to forfeit property used to facilitate the offense  but purchased with legitimately earned funds, the government must  establish a substantial connection between the use of the property and the  offense. Once that connection is established, the government can forfeit  the house if the owner cannot show innocent ownership due to the  owner’s willful blindness to the criminal activity. However, taking civil  action as an alternative to criminal action for real property seizures is not  an option in alien smuggling cases. Civil forfeiture in alien smuggling cases  is generally limited to personal property such as vessels, vehicles, and  aircraft and does not extend to real property. Thus, the house used to hide  the aliens and conduct the alien-smuggling business could not be forfeited  in a civil forfeiture action. Civil forfeiture of real property is available in  cases where the house was used to conduct drug transactions, including  the storing of drugs and money, child pornography, and money  laundering. In the view of Justice and ICE, this statutory distinction  between alien smuggling and other criminal offenses is inappropriate.
An amendment to the civil forfeiture authority, according to Justice, would  enhance federal efforts to dismantle smuggling organizations because  would-be defendants often are fugitives, which makes criminal forfeiture  unavailable. Also, a civil forfeiture authority for real property used to  facilitate alien smuggling would enable the government to establish willful  blindness arguments against landlords who hope to profit from such  ventures without becoming directly involved. However, our May 2005  report noted that Justice does not have a legislative proposal on this  subject pending before Congress because the department’s legislative  policy resources have been focused on other priorities.
Expanding civil forfeiture authority in alien smuggling cases to include  real property used to facilitate the offense may raise concerns, including  the potential for abuse of this type of forfeiture and the adequacy of  protection for the rights of innocent property owners. In 2000, several  reforms were made to civil asset forfeiture law to provide procedural  protections for innocent property owners. These reforms were part of a  compromise that was developed over several years by Congress, the  executive branch, and interest groups. Some observers felt that the  legislation did not provide enough reforms and protections, while others  felt that it went too far and would curtail a legitimate law enforcement  tool.
section_title: Conclusions
paragraphs: Creation of DHS in March 2003 has provided new opportunities to more  effectively combat alien smuggling, particularly in reference to using  financial investigative techniques to target and seize the monetary assets  of smuggling organizations. However, after more than 2 years, the federal  response to alien smuggling is still evolving, including development and  implementation of a strategy to follow the money trail. Also evolving is the  working relationship of ICE and CBP, two DHS components that have the  primary responsibility for investigating and interdicting alien smugglers.  Having clearly defined roles and responsibilities for these components is  important, given their complementary antismuggling missions. In this  regard, ICE’s and CBP’s November 2004 memorandum of understanding  did not address a mechanism for tracking the number and the results of  leads referred by CBP to ICE for investigation. If a tracking mechanism  were in place, CBP could continue pursuing certain leads if ICE—for lack  of available resources or other reasons—does not take action on the  referrals. As such, a tracking mechanism would help to further ensure that  large or significant alien-smuggling organizations are identified and  investigated.
Federal law enforcement has concerns that efforts to dismantle alien- smuggling organizations are constrained by the current absence of civil  forfeiture authority for real property used to facilitate the smuggling of  aliens. In contrast, for drug trafficking and various other criminal offense  categories, civil forfeiture authority is available for seizing real property  used to facilitate these crimes. According to Justice and ICE, the absence  of civil forfeiture authority for real property used to facilitate the  smuggling of aliens is inappropriate because law enforcement is unable in  many cases to seize stash houses where smugglers hide aliens while  awaiting payment and travel arrangements to final destinations throughout  the nation.
To enhance the federal response to alien smuggling, our May 2005 report  made two recommendations. Specifically, we recommended that  the Secretary of Homeland Security establish a cost-effective  mechanism for tracking the number and results of referrals by CBP to  ICE, and  the Attorney General, in collaboration with the Secretary of Homeland  Security, consider developing and submitting to Congress a legislative  proposal, with appropriate justification, for amending the civil  forfeiture authority for real property used to facilitate the smuggling of  aliens.
DHS and Justice expressed agreement with the respective  recommendation. DHS said CBP and ICE, in consultation with Border and  Transportation Security, would work together to identify and implement a  solution to address our recommendation. Justice said it plans to move  forward with a proposal as GAO recommended.
Mr. Chairman, this concludes my prepared statement. I would be happy to  respond to any questions that you or Members of the Subcommittee may  have.
For information about this testimony, please contact Richard Stana,  Director, Homeland Security and Justice Issues, at (202) 512-8777, or  stanar@gao.gov. Contact points for our Offices of Congressional Relations  and Public Affairs may be found on the last page of this report. Other  individuals making key contributions to this testimony include Danny  Burton, Grace Coleman, Frances Cook, Odilon Cuero, and Kathleen Ebert.
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