Director's Report Details

The Special Investigations Unit is a civilian law enforcement agency that investigates incidents involving police officers where there has been death, serious injury or allegations of sexual assault. The Unit’s jurisdiction covers more than 50 municipal, regional and provincial police services across Ontario.

Under the Police Services Act, the Director of the SIU must determine based on the evidence gathered in an investigation whether an officer has committed a criminal offence in connection with the incident under investigation. If, after an investigation, there are reasonable grounds to believe that an offence was committed, the Director has the authority to lay a criminal charge against the officer. Alternatively, in all cases where no reasonable grounds exist, the Director does not lay criminal charges but files a report with the Attorney General communicating the results of an investigation.

Freedom of Information and Protection of Personal Privacy Act (“FIPPA”)

Pursuant to section 14 of FIPPA (i.e., law enforcement), certain information may not be included in this report. This information may include, but is not limited to, the following:

• Confidential investigative techniques and procedures used by law enforcement agencies; and
• Information whose release could reasonably be expected to interfere with a law enforcement matter or an investigation undertaken with a view to a law enforcement proceeding.

Pursuant to section 21 of FIPPA (i.e., personal privacy), protected personal information is not included in this document. This information may include, but is not limited to, the following:

• subject officer name(s)
• witness officer name(s)
• civilian witness name(s)
• location information
• witness statements and evidence gathered in the course of the investigation provided to the SIU in confidence and
• other identifiers which are likely to reveal personal information about individuals involved in the investigation

Personal Health Information Protection Act, 2004 (“PHIPA”)

Pursuant to PHIPA, any information related to the personal health of identifiable individuals is not included.

Other proceedings, processes, and investigations

Information may have also been excluded from this report because its release could undermine the integrity of other proceedings involving the same incident, such as criminal proceedings, coroner’s inquests, other public proceedings and/or other law enforcement investigations.

The Unit’s investigative jurisdiction is limited to those incidents where there is a serious injury (including sexual assault allegations) or death in cases involving the police.

“Serious injuries” shall include those that are likely to interfere with the health or comfort of the victim and are more than merely transient or trifling in nature and will include serious injury resulting from sexual assault. “Serious Injury” shall initially be presumed when the victim is admitted to hospital, suffers a fracture to a limb, rib or vertebrae or to the skull, suffers burns to a major portion of the body or loses any portion of the body or suffers loss of vision or hearing, or alleges sexual assault. Where a prolonged delay is likely before the seriousness of the injury can be assessed, the Unit should be notified so that it can monitor the situation and decide on the extent of its involvement.

This report relates to the SIU’s investigation into the serious injury reportedly sustained by a 27-year-old man during his arrest on September 14, 2017.

Notification of the SIU

At approximately 9:50 a.m. on September 14, 2017, the Toronto Police Service (TPS) notified the SIU of the serious injuries sustained by the Complainant.

The TPS reported that on September 14, 2017, at 9:13 a.m., TPS police officers responded to a stabbing incident at Driftwood Avenue and Cobbler Crescent, in the area of Hwy 400 and Finch Avenue, in the City of Toronto. A police officer discharged his firearm and a man was struck.

The stabbing victim and the man that was struck by the projectile(s) were taken to hospital.

The Team

Number of SIU Investigators assigned: 10

Number of SIU Forensic Investigators assigned: 4

Complainant:

27-year-old male, not interviewed

On September 15, 2017, SIU investigators attempted to speak with the Complainant at the hospital but the Complainant stated that he did not want to speak with the investigators.

On September 18, 2017, SIU investigators attended the Detention Centre where the Complainant was being held but they were told that the Complainant had assaulted one of their physicians earlier in the day and as a result, the Complainant was placed in segregation.

When the investigators attended the Complainant’s cell, the Complainant said that he did not remember the SIU investigators and spoke incoherently. The Complainant said that a man had snitched on him and that is the reason why he was shot. He also said that he was at the front door of that man’s residence when the man called 911.

The Complainant believed that the police officer who shot him [now known to be the SO] had been following him since he was in grade 7. He recalled strangers standing near him and that he faced the SO at the time he was shot. When the Complainant was asked about his interactions with the police officer, the Complainant refused to speak any further with the investigators.

Civilian Witnesses

CW #1 Interviewed

CW #2 Interviewed

CW #3 Interviewed

CW #4 Interviewed

CW #5 Interviewed

CW #6 Interviewed

CW #7 Interviewed

CW #8 Interviewed

CW #9 Interviewed

CW #10 Interviewed

Witness Officers

WO #1 Interviewed, notes received and reviewed

Subject Officers

SO #1 Declined interview or to provide notes, as is the subject officer’s legal right

On September 14, 2017, at approximately 8:30 a.m., CW #8 walked his young grandchildren to school in the City of Toronto. While CW #8 was walking home from the school, he was in the company of his neighbour, CW #6. As CW #8 and CW #6 walked north on Driftwood Avenue towards their townhome complexes, the Complainant was walking south on Driftwood Avenue towards them. Just as the Complainant passed CW #8, the Complainant attacked him with a knife. The Complainant stabbed and punched CW #8 several times in the face and head area. Many civilian witnesses yelled at and told the Complainant to stop, however, the Complainant continued to repeatedly stab and punch CW #8.

A few minutes later, the SO and WO #1 arrived and they repeatedly told the Complainant to stop and to drop the knife. The SO discharged his firearm once, striking the Complainant in the abdomen area.

CW #8, the Complainant, and the SO were transported to various hospitals in the city.

Nature of Injuries/Treatment

SIU investigators were not able to obtain the Complainant’s medical records as he appeared to be incapable, based on his mental state, of consenting to their release. From the brief conversations that SIU investigators had with the Complainant, it was apparent that the Complainant’s mental health was questionable.

The Scene

Driftwood Avenue was a paved roadway that travelled north and south. There were sidewalks on both sides of the road. Cobbler Crescent travelled west from Driftwood Crescent. The area consisted of apartment buildings, residential homes, and schools.

The incident took place in the northwest quadrant of Driftwood Avenue and Cobbler Crescent in the City of Toronto. There were overgrown hedges along the sidewalk which ran east on Cobbler Crescent and south on Driftwood Avenue. A .40 calibre cartridge was located on the west curb of Driftwood Avenue, north of Cobbler Crescent. There was a large area of blood staining on the sidewalk. A blood stained handle-less knife was located on the grass, west of the west sidewalk of Driftwood Avenue. There were various clothing items around the area. There was a TTC bus parked on Driftwood Avenue, just north of Cobbler Crescent.

Physical Evidence

The blade used by the Complainant to stab CW #8.

SIU Examination of the SO’s service firearm Summary

On September 14, 2017, an SIU investigator examined the SO’s use of force equipment. Upon examination of the SO’s firearm, which was a Glock 22 .40 calibre pistol, and magazines, the following was observed:

• Two spare magazines which both contained 14 bullets, and
• One magazine, which had been unloaded from the SO’s firearm, contained 13 bullets

Forensic Evidence

No submissions were made to the Centre of Forensic Sciences.

Video/Audio/Photographic Evidence

Civilian Witnesses Cell Phone Video Footage Summary

On September 14, 2017, CW #2, CW #9, and CW #7 provided SIU investigators with their cell phone video footage of the incident. The videos were reviewed and were found to be consistent with each other. The following is a summary of the footage:

September 14, 2017

• At approximately 9:13 a.m., people were seen standing on the road on Driftwood Avenue facing west towards Cobbler Crescent. The sound of horns can be heard from vehicles that were parked facing west on Driftwood Avenue. People can be heard yelling, “Stop” and, “Oh my God.” A man wearing a blue vest [now known to be the Complainant] was standing on the west sidewalk of Driftwood Avenue and Cobbler Crescent. The Complainant was hovering over another man [now known to be CW #8] kicking and striking him repeatedly. A large amount of blood was seen on the sidewalk and on the Complainant and CW #8. It appeared that CW #8 was on his knees trying to protect himself by covering his face and head with his arms and hands. It did not appear that CW #8 was fighting or striking back at the Complainant
• At approximately 9:14 a.m., a police officer [now known to be the SO] ran in a westerly direction from Driftwood Avenue towards Cobbler Crescent with his right hand on his holstered firearm. The SO stepped onto the west side grassy boulevard of Driftwood Avenue and Cobbler Crescent and stood with his firearm pointed towards CW #8. A man’s voice could be heard saying, “Hey, Hey” and a gunshot could be heard. A police officer [now known to be WO #1] ran to the Complainant, who was lying on the sidewalk, and took hold of the Complainant’s right arm

Communications Recordings

911 and Communications Recording Summary

On September 14, 2017, at approximately 9:12 a.m., multiple calls were made to 911 advising that a man [now known to be CW #8] was being stabbed multiple times at the corner of Driftwood Avenue and Cobbler Crescent. The callers sounded upset and in a state of panic. One of the 911 callers [name unknown] said that she saw a box cutter in the hands of the man [now known to be the Complainant] who was stabbing CW #8.

At approximately 9:14 a.m., the dispatcher broadcast that there was a person being stabbed at Cobbler Crescent and Driftwood Avenue. WO #1 and the SO responded and advised that they were en route.

At approximately 9:15 a.m., the SO broadcast that shots had been fired and requested an ambulance.

Materials obtained from Police Service

Upon request, the SIU obtained and reviewed the following materials and documents from the TPS

• 911 Call Recordings
• Police Transmission Communications Recordings
• Event Details Reports (x2)
• Notes of WO #1
• TPS Scene Photos
• Summary of Conversation, and
• TPS History Summary

The SIU obtained and reviewed the following materials and documents from other sources:

• Toronto Paramedic Services Ambulance Call Reports (x2)
• Toronto EMS Incident Reports (x3)
• Toronto EMS Incident Summary Report
• Four Cell Phone recordings of the incident captured by civilian witnesses, and
• CCTV recording from TTC bus

Section 25(1), Criminal Code - Protection of persons acting under authority

25 (1) Every one who is required or authorized by law to do anything in the administration or enforcement of the law

1. as a private person
2. as a peace officer or public officer
3. in aid of a peace officer or public officer, or
4. by virtue of his office

is, if he acts on reasonable grounds, justified in doing what he is required or authorized to do and in using as much force as is necessary for that purpose.

25 (3) Subject to subsections (4) and (5), a person is not justified for the purposes of subsection (1) in using force that is intended or is likely to cause death or grievous bodily harm unless the person believes on reasonable grounds that it is necessary for the self-preservation of the person or the preservations of any one under that person’s protection from death or grievous bodily harm.

Section 27, Criminal Code of Canada – Use of Force to Prevent Commission of Offence

27 Every one is justified in using as much force as is reasonably necessary

1. to prevent the commission of an offence
   1. for which, if it were committed, the person who committed it might be arrested without warrant, and
   2. that would be likely to cause immediate and serious injury to the person or property of anyone; or
2. To prevent anything being done that, on reasonable grounds, he believes would, if it were done, be an offence mentioned in paragraph (a)

Section 34, Criminal Code - Defence of Person – Use of Threat of Force

34 (1) A person is not guilty of an offence if

1. They believe on reasonable grounds that force is being used against them or another person or that a threat of force is being made against them or another person
2. The act that constitutes the offence is committed for the purpose of defending or protecting themselves or the other person from that use or threat of force, and
3. The act committed is reasonable in the circumstances

(2) In determining whether the act committed is reasonable in the circumstances, the court shall consider the relevant circumstances of the person, the other parties and the act, including, but not limited to, the following factors:

1. the nature of the force or threat
2. the extent to which the use of force was imminent and whether there were other means available to respond to the potential use of force
3. the person’s role in the incident
4. whether any party to the incident used or threatened to use a weapon
5. the size, age, gender and physical capabilities of the parties to the incident
6. the nature, duration and history of any relationship between the parties to the incident, including any prior use or threat of force and the nature of that force or threat;
   1. (f.1) any history of interaction or communication between the parties to the incident
7. the nature and proportionality of the person’s response to the use or threat of force, and
8. whether the act committed was in response to a use or threat of force that the person knew was lawful

Section 239, Criminal Code – Attempt to Commit Murder

239 (1) Every person who attempts by any means to commit murder is guilty of an indictable offence and liable

1. if a restricted firearm or prohibited firearm is used in the commission of the offence or if any firearm is used in the commission of the offence and the offence is committed for the benefit of, at the direction of, or in association with, a criminal organization, to imprisonment for life and to a minimum punishment of imprisonment for a term of
   1. in the case of a first offence, five years, and
   2. in the case of a second or subsequent offence, seven years

1. (a.1) in any other case where a firearm is used in the commission of the offence, to imprisonment for life and to a minimum punishment of imprisonment for a term of four years, and
2. in any other case, to imprisonment for life

Section 267, Criminal Code - Assault with a weapon or causing bodily harm

267 Every one who, in committing an assault,

1. carries, uses or threatens to use a weapon or an imitation thereof, or
2. causes bodily harm to the complainant

is guilty of an indictable offence and liable to imprisonment for a term not exceeding ten years or an offence punishable on summary conviction and liable to imprisonment for a term not exceeding eighteen months.

On September 14, 2017, numerous 911 calls were received by the Toronto Police Service (TPS) at approximately 9:12 a.m. from a variety of callers requesting assistance in the area of Driftwood Avenue and Cobbler Crescent in the City of Toronto with respect to a man being stabbed multiple times; the 911 recordings reveal that the callers were upset and in a state of panic.

At 9:14 a.m., the TPS dispatcher sent out a call for assistance to all units and the Subject Officer (SO) and Witness Officer (WO) #1 immediately responded to the call and attended the area. The police radio dispatch recordings reveal that within one minute of the original call out for assistance from the dispatcher, a follow up transmission was received from the SO confirming that gunshots had been fired and that an ambulance was being requested.

The Complainant was subsequently transported to the hospital by ambulance. While the Complainant was unable to consent to the release of his medical records, the paramedic, in the EMS records, noted that although the Complainant appeared to have two wounds to his abdomen, which were attributable to a gunshot, he opined that one was an entry wound and one an exit wound.

Civilian Witness (CW) #8 was also transported to the hospital where he was treated for multiple stab wounds.

The Complainant, in various attempts by SIU investigators to obtain an interview from him, was unable to provide any rational recounting of the incident, due to the state of his mental health, and the SO declined to be interviewed or to provide his memorandum book notes for review, as is his legal right. However, ten CWs and one police witness were interviewed by SIU investigators. Additionally, four of the CWs had recorded the incident on their cell phones. These recordings were provided to SIU investigators, as well as the 911 recordings, the police radio transmission recordings, the paramedic records, the SO’s firearm, which was forensically examined, and the notes of WO #1. There is no dispute as to the facts as between the 11 witnesses interviewed and a clear picture of the interaction was able to be determined as a result of the cooperation of all of the independent witnesses to the shooting.

On September 14, 2017 at approximately 8:30 a.m., CW #8 walked his grandchildren to school in the area of Driftwood Avenue in the City of Toronto. After dropping his grandchildren at school, he was walking back to the home of his daughter in the company of a neighbour, CW #6, when he was approached by the Complainant, who was unknown to either of CW #8 or CW #6. The Complainant, who was walking on the sidewalk in the opposite direction in which CW #8 and CW #6 were walking, suddenly stabbed CW #8 in the head with a knife, without warning. CW #6, fearing for her own life, ran towards her home. CW #8 advised that he tried to run away, but fell onto the sidewalk where the Complainant continued to stab him repeatedly in the head and face with the knife. The knife, which was later located, did not have a handle and the Complainant was clutching the bare blade in his hand while stabbing CW #8, inflicting injuries to his own hand in doing so.

Numerous witnesses in the area observed CW #8 crouched down on the sidewalk, while the Complainant repeatedly stabbed, punched, and kicked him. Bystanders were yelling at the Complainant to get off of CW #8, as well as honking their car horns, and video recording the incident. Numerous of the witnesses placed emergency 911 calls to the TPS requesting assistance. The cell phone videos confirmed that at no time did CW #8 retaliate toward the Complainant, but instead he appeared to be trying to shield his face and head with his arms and hands.

An unmarked police minivan was then seen to drive toward the scene at a high rate of speed and WO #1 and the SO were seen to exit the vehicle and run towards CW #8 and the Complainant; the SO was seen to draw his firearm. Both police officers were observed to approach the confrontation and were heard to shout at the Complainant to “Stop,” “Get off him,” and “Drop the knife!” The Complainant was observed to briefly turn his head toward the two police officers, but then returned his attention to CW #8 and continued to stab him. A number of witnesses observed that the Complainant was tiring and that he grabbed onto a bush for support, while continuing to stab CW #8.

WO #1 advised that he observed the Complainant repeatedly stabbing, punching, and kicking CW #8. He and the SO both yelled out police commands to the Complainant, but the Complainant ignored them and continued to stab CW #8. WO #1 advised that he initially considered kicking the Complainant in hopes of stopping the attack, but rejected that option as being too dangerous to his own safety.

WO #1 observed that the SO had his arms extended and was holding his firearm and he heard one gunshot from the SO’s firearm; this is confirmed by all of the independent civilian witnesses as well as the video recordings. The SO was then heard to broadcast over the radio requesting the attendance of Emergency Medical Services (EMS) and that shots had been fired; both officers then ran to assist the Complainant and CW #8.

WO #1 estimated that approximately five seconds had elapsed between the two police officers exiting their vehicle and the gunshot; this is consistent with the evidence of the civilian witnesses and the videos.

The cell phone videos confirmed that at 9:14 a.m., the SO ran toward the Complainant with his right hand on his holstered firearm; the SO then stood on the grassy boulevard with his firearm pointed and one gunshot is heard. WO #1 is then seen to run toward the Complainant and take hold of his right arm.

Forensic examination of the SO’s firearm confirmed only one bullet had been discharged.

Pursuant to s. 25(1) of the Criminal Code of Canada, a police officer, if he acts on reasonable grounds, is justified in using as much force as is necessary in the execution of a lawful duty. Further, pursuant to subsection 3:

(3) Subject to subsections (4) and (5), a person is not justified for the purposes of subsection (1) in using force that is intended or is likely to cause death or grievous bodily harm unless the person believes on reasonable grounds that it is necessary for the self-preservation of the person or the preservation of any one under that person’s protection from death or grievous bodily harm.

Furthermore, pursuant to subsection 4:

(4) A peace officer … is justified in using force that is intended or is likely to cause death or grievous bodily harm to a person to be arrested, if

• the peace officer is proceeding lawfully to arrest, with or without warrant, the person to be arrested

(d) the peace officer … believes on reasonable grounds that the force is necessary for the purpose of protecting the peace officer … or any other person from imminent or future death or grievous bodily harm …

As such, in order for the SO to qualify for protection from prosecution under section 25, it must be established that he was in the execution of a lawful duty, that he was acting on reasonable grounds, and that he used no more force than was necessary. Furthermore, pursuant to subsection 3, if death or grievous bodily harm is caused, it must further be established that the police officer did so believing on reasonable grounds that it was necessary in order to preserve himself or another person from death or grievous bodily harm.

Turning first to the lawfulness of the Complainant’s apprehension, it is clear from the statements of all witnesses, as confirmed by the various video recordings, that there were reasonable grounds to believe that the Complainant was assaulting CW #8 with a weapon contrary to s.267 of the Criminal Code, as well as causing CW #8 bodily harm (also s. 267) and was possibly attempting to murder him (s. 239). As such, the apprehension and arrest of the Complainant was legally justified in the circumstances.

With respect to the other requirements pursuant to s.25(1) and (3), I am mindful of the state of the law as set out by the Supreme Court of Canada in R v Nasogaluak [2010] 1 S.C.R. 206, as follows:

Police actions should not be judged against a standard of perfection. It must be remembered that the police engage in dangerous and demanding work and often have to react quickly to emergencies. Their actions should be judged in light of these exigent circumstances. As Anderson J.A. explained in R. v. Bottrell(1981), 60 C.C.C. (2d) 211 (B.C.C.A.):

In determining whether the amount of force used by the officer was necessary the jury must have regard to the circumstances as they existed at the time the force was used. They should have been directed that the appellant could not be expected to measure the force used with exactitude. [p. 218]

The court describes the test required under s.25 as follows:

Section 25(1) essentially provides that a police officer is justified in using force to effect a lawful arrest, provided that he or she acted on reasonable and probable grounds and used only as much force as was necessary in the circumstances. That is not the end of the matter. Section 25(3) also prohibits a police officer from using a greater degree of force, i.e. that which is intended or likely to cause death or grievous bodily harm, unless he or she believes that it is necessary to protect him- or herself, or another person under his or her protection, from death or grievous bodily harm. The officer’s belief must be objectively reasonable. This means that the use of force under s. 25(3) is to be judged on a subjective-objective basis (Chartier v. Greaves, [2001] O.J. No. 634 (QL) (S.C.J.), at para. 59).

The decision of Justice Power of the Ontario Superior Court of Justice in Chartier v Greaves, [2001] O.J. No. 634, as adopted by the Supreme Court of Canada above, sets out other relevant provisions of the Criminal Code to be considered, as follows:

27. Use of force to prevent commission of offence - Everyone is justified in using as much force as is reasonably necessary
    1. to prevent the commission of an offence
       1. for which, if it were committed, the person who committed it might be arrested without warrant, and
       2. that would be likely to cause immediate and serious injury to the person or property of anyone, or
    2. to prevent anything being done that, on reasonable grounds, he believes would, if it were done, be an offence mentioned in paragraph (a)

This Section, therefore, authorizes the use of force to prevent the commission of certain offenses. Everyone" would include a police officer. The force must not be more than that which is reasonably necessary. Therefore, an objective test is called for. The Ontario Court of Appeal, in R. v. Scopelliti (1981), 63 C.C.C. (2d) 481 held that the use of deadly force can be justified only in either cases of self-defence or in preventing the commission of a crime likely to cause immediate and serious injury.

Further, the court sets out a number of other legal principles gleaned from the legal precedents cited, including the following:

8. Whichever section of the Criminal Code is used to assess the actions of the police, the Court must consider the level of force that was necessary in light of the circumstances surrounding the event
9. "Some allowance must be made for an officer in the exigencies of the moment misjudging the degree of force necessary to restrain a prisoner". The same applies to the use of force in making an arrest or preventing an escape. Like the driver of a vehicle facing a sudden emergency, the policeman "cannot be held to a standard of conduct which one sitting in the calmness of a court room later might determine was the best course." (Foster v. Pawsey) Put another way: It is one thing to have the time in a trial over several days to reconstruct and examine the events which took place on the evening of August 14^th. It is another to be a policeman in the middle of an emergency charged with a duty to take action and with precious little time to minutely dissect the significance of the events, or to reflect calmly upon the decisions to be taken. (Berntt v. Vancouver)
10. Police officers perform an essential function in sometimes difficult and frequently dangerous circumstances. The police must not be unduly hampered in the performance of that duty. They must frequently act hurriedly and react to sudden emergencies. Their actions must therefore be considered in the light of the circumstances
11. "It is both unreasonable and unrealistic to impose an obligation on the police to employ only the least amount of force which might successfully achieve their objective. To do so would result in unnecessary danger to themselves and others. They are justified and exempt from liability in these situations if they use no more force than is necessary, having regard to their reasonably held assessment of the circumstances and dangers in which they find themselves" (Levesque v. Zanibbi et al.)

On the basis of the foregoing principles of law then, I must determine whether the SO:

1. Subjectively believed that CW #8 was at risk of death or grievous bodily harm from the Complainant at the time that he discharged his firearm, and
2. Whether that belief was objectively reasonable, or, in other words, whether his actions would be considered reasonable by an objective bystander who had all of the information available to the SO at the time that he discharged his firearm

On a consideration of all of the evidence in this matter, I have no hesitation in answering yes to both of the above questions; I have no difficulty inferring from the evidence provided by all of the witnesses to this event that the SO reasonably would have believed that CW #8 was at risk of death or grievous bodily harm at the hands of the Complainant at the time that he discharged his firearm, and that his belief was objectively reasonable in the circumstances and was shared by all present and by anyone viewing the various videos.

Having reviewed the relevant legislation in assessing the actions of the SO in discharging his firearm, I have no difficulty finding that there are no reasonable grounds to believe that the SO’s actions amounted to an excessive use of force. In all the circumstances, including the fact that the SO was faced with a man armed with a knife who had already stabbed one person repeatedly, who was unresponsive to police commands to stop, and who was actively engaged in continuing to stab that person, I find that the shot that was fired and struck the Complainant was fully justified pursuant to s.34 of the Criminal Code as being in defence of CW #8 and that the SO, in doing so, used no more force than was necessary to effect his lawful purpose pursuant to s.25(1) and (3) of the Criminal Code.

As such, I am not only satisfied on reasonable grounds on this record that the actions exercised by the SO fell within the limits prescribed by the criminal law and that there are no grounds for proceeding with criminal charges in this case, but it is my view that there was no other option available to the SO than to discharge his firearm, and that his actions in all likelihood saved CW #8 from even more serious injuries, if not death.

Date: July 12, 2018

Original signed by

Tony Loparco
Director
Special Investigations Unit