HomeMy WebLinkAboutStaff Report 331-06City
City of Palo Alto
Manager’s Report
TO:
FROM:
DATE:
HONORABLE CITY COUNCIL
CITY MANAGER
AUGUST 7, 2006
DEPARTMENT: POLICE
CMR: 331:06 9
SUBJECT: APPROVAL OF AGREEMENT WITH MICHAEL J. GENNACO
AND ROBERT MILLER OF THE OIR GROUP FOR POLICE AUDITOR
SERVICES IN THE AMOUNT NOT TO EXCEED $19,936.
RECOMMENDATION
Staff recommends that the City Council approve the attached agreement with Michael J.
Gennaco and Robert Miller of the OIR Group for Police Auditor services for a period of
one-year not to exceed $19,936.
BACKGROUND
On March 13, 2006, the City Council voted to institute a one-year trial period for a
contract Police Auditor. After a Request for Proposal process, four applications were
received. One applicant voluntarily withdrew prior to the interviews. The Council
interviewed the three remaining applicants and selected Michael J. Gennaco and Robert
Miller of the OIR Group.
DISCUSSION
The attached agreement between the City and the OIG Group provides for the following
services:
~ Review of the Police Department’s policies and training materials and a meeting
with the Police Chief to develop a thorough understanding of existing practices
concerning citizen complaints and internal affairs.
~Receive citizen complaints directly.
~Review investigations and disposition of citizen complaints involving police
misconduct.
~ Review internal investigations for thoroughness, objectivity and consistency and
recommend changes to dispositions.
~Meet with the Police Chief and City Manager on a quarterly basis to discuss
trends, issues and/or problems.
CMR 331:06
Produce two semi-annual reports and meet with the City Council to discuss those
reports.
An evaluation will be conducted by the City Council at the end of the year’s trial period
to determine the status of the program.
RESOURCE IMPACT
Funds for this agreement were approved as part of the City Council’s 2006-07 budget.
POLICY IMPLICATIONS
This agreement is consistent with City policies.
ATTACHMENT
Copy of agreement
DEPARTMENT HEAD:
Police Chief
CITY MANAGER APPROVAL: ~P(i-~~~-~
c EMIL’) HARPd~gON
Assistant City Manager
CMR 331:06
CITY OF PALO ~d]TO CONTRACT NO.
AGREEMENT BETWEEN THE CITY OF PALO ALTO AND
OIR GROUP
FOR PROFESSIONAL SERVICES
(Police Auditor)
This AGREEMENT is entered into , by and
between the CITY OF PALO ALTO, a chartered city and a municipal
corporation of the State of California ("CITY"), Michael J.
Gennaco, an individual, and Robert Miller, an individual, doing
business as OIR Group, located at 4900 South Eastern Avenue, Suite
204, Commerce,California 90040 (collectively referred to as
"CONSULTANT").
RECITALS
The following recitals are a substantive portion of this
Agreement.
A. CITY desires to engage a consultant to perform auditing
services for the City’s Police Department.
B. CONSULTANT has represented that it has the necessary
professional expertise, qualifications, and capability, and all
required licenses and/or certifications to provide the Services.
C. CITY in reliance on these representations desires to engage
CONSULTANT to provide the Services as more fully described in
Exhibit "A", attached to and made a part of this Agreement.
D. CONSULTANT has agreed to perform the Services on the terms and
conditions contained in this Agreement.
NOW, THEREFORE, in consideration of the recitals,
covenants, terms, and conditions, this Agreement, the parties
agree:
AGREEMENT
Section i. SCOPE OF SERVICES. CONSULTANT shall perform the Services
described in Exhibit "A" in accordance with the terms and
conditions contained in this Agreement. The performance of all
Services shall be to the reasonable satisfaction of CITY.
SECTION 2. TERM. The term of this Agreement shall be for one (i)
year from the date of its full execution unless terminated earlier
pursuant to Section 20 of this Agreement.
SECTION 3. SCHEDULE OF PERFORMANCE. Time is of the essence in the
performance of Services under this Agreement. Any Services for
which times for performance are not specified in this Agreement
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shall be commenced and completed by CONSULTANT within the term of
this agreement in a reasonably prompt and timely manner based upon
the circumstances and direction communicated to the CONSULTANT.
Any agreement by City to extend the term or the schedule for
performance must be given in writing prior to the expiration of
this Agreement and shall not preclude recovery of damages for delay
if the extension is required due to the fault of CONSULTANT.
SECTION 4. NOT TO EXCEED COMPENSATION. The compensation to be paid
to CONSULTANT for performance of the Services described in Exhibit
"A", including both payment for professional services and
reimbursable expenses, shall not exceed nineteen thousand nine
hundred thirty-six dollars ($19,936.00). The applicable rates and
schedule of payment are set out in Exhibit "B", entitled
"COMPENSATION," which is attached to and made a part of this
Agreement.
Additional Services, if any, shall be authorized in accordance with
and subject to the provisions of Exhibit "C". CONSULTANT shall not
receive any compensation for Additional Services performed without
the prior written authorization of CITY. Additional Services shall
mean any work that is determined by CITY to be necessary for the
proper completion of the Project, but which is not included within
the Scope of Services described in Exhibit "A".
SECTION 5. INVOICES. In order to request payment, CONSULTANT shall
submit monthly invoices to the CITY describing the services
performed and the applicable charges (including an identification
of personnel who performed the services, hours worked, hourly
rates, and reimbursable expenses), based upon the CONSULTANT’s
billing rates (set forth in Exhibit "B"). If applicable, the
invoice shall also describe the percentage of completion of each
task. The information in CONSULTANT’s payment requests shall be
subject to verification by CITY.
SECTION 6. QUALIFICATIONS/STANDARD OF CARE. All of the Services
shall be performed by CONSULTANT or under CONSULTANT’s supervision.
CONSULTANT represents that it possesses the professional and
technical personnel necessary to perform the Services required by
this Agreement and that the personnel have sufficient skill and
experience to perform the Services assigned to them. CONSULTANT
represents that it, its employees and subconsultants have and shall
maintain during the term of this Agreement all licenses, permits,
qualifications, insurance and approvals of whatever nature that are
legally required to perform the Services.
All of the services to be furnished by CONSULTANT under this
agreement shall meet the professional standard and quality that
prevail among professionals in the same discipline and of similar
knowledge and skill engaged in related work throughout California
under the same or similar circumstances.
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SECTION 7. COMPLIANCE WITH LAWS. C~ONSULTANT shall keep itself
informed of and in compliance with all federal, state and local
laws, ordinances, regulations, and orders that may affect in any
manner the Project or the performance of the Services or those
engaged to perform Services under this Agreement. CONSULTANT shall
procure all permits and licenses, pay all charges and fees, and
give all notices required by law in the performance of the
Services.
CONSULTANT shall report immediately to the CITY’s project manager,
in writing, any discrepancy or inconsistency it discovers in the
laws, ordinances, regulations, orders, and/or guidelines in
relation to the Project of the performance of the Services.
All documentation prepared by CONSULTANT shall provide for a
completed project that conforms to all applicable codes, rules,
regulations and guidelines that are in force at the time such
documentation is prepared.
SECTION 8. ERRORS/OMISSIONS. CONSULTANT shall correct, at no cost
to CITY, any and all errors, omissions, or ambiguities in the work
product submitted to CITY, provided CITY gives notice to
CONSULTANT.
SECTION 9. INDEPENDENT CONTRACTOR. It is understood and agreed
that in performing the Services under this Agreement CONSULTANT,
and any person employed by or contracted with CONSULTANT to
furnish labor and/or materials under this Agreement, shall act as
and be an independent contractor and not an agent or employee of
the CITY. The manner and means of conducting the Services are the
responsibility of and under the control of CONSULTANT, except to
the extent they are limited by applicable law and the express
terms of this Agreement.
CONSULTANT will be responsible for employing or engaging all
persons necessary to perform the Services. All contractors and
employees of CONSULTANT are deemed to be under CONSULTANT’S
exclusive direction and control. CONSULTANT shall be responsible
for their performance.
SECTION I0. ASSIGNMENT. The parties agree that the expertise and
experience of CONSULTANT are material considerations for this
Agreement. CONSULTANT shall not assign or transfer any interest in
this Agreement nor the performance of any of CONSULTANT’s
obligations hereunder without the prior written consent of the city
manager. Consent to one assignment will not be deemed to be consent
to any subsequent assignment. Any assignment made without the
approval of the city manager will be void.
SECTION ii. SUBCONTRACTING. CONSULTANT shall not subcontract any
portion of the work to be performed under this Agreement without
the prior written authorization of the city manager or designee.
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SECTION 12. PROJECT MANAGEMENT. CONSULTANT will assign Michael J.
Gennaco as the project director to have supervisory responsibility
for the performance, progress] and execution of the Services. If
circumstances or conditions subsequent to the execution of this
Agreement cause the substitution of the project director or any
other key personnel for any reason, the appointment of a substitute
project director and the assignment of any key new or replacement
personnel will be subject to the prior written approval of the
CITY’s project manager. CONSULTANT, at CITY’s request, shall
promptly remove personnel who CITY finds do not perform the
Services in an acceptable manner, are uncooperative, or present a
threat to the adequate or timely completion of the Project or a
threat to the safety of persons or property.
The city manager will represent CITY for all purposes under this
Agreement. The City’s Police Chief, Lynne Johnson, is designated as
the project manager for the CITY. The project manager will be
CONSULTANT’s point of contact with respect to performance, progress
and execution of the Services. The CITY may designate an alternate
project manager from time to time.
SECTION 13. DUTIES of CITY. To assist CONSULTANT in the performance
of the Services, CITY will furnish or cause to be furnished the
specified services and/or documents described in Exhibit "A" and
such other available information as may be reasonably requested by
CONSULTANT.
SECTION 14. OWNERSHIP OF M ATERIA!~S. All drawings, plans, reports,
specifications, calculations, documents, other materials and
copyright interests developed or discovered by CONSULTANT or any
other person engaged directly or indirectly by CONSULTANT to
perform the services required hereunder shall be and remain the
property of CITY without restriction or limitation upon their use.
Neither CONSULTANT nor its contractors, if any, shall make any of
such materials available to any individual or organization without
the prior written approval of the city manager or designee.
SECTION 15. AUDITS. CONSULTANT will permit CITY to audit, at any
reasonable time during the term of this Agreement and for three (3)
years thereafter, CONSULTANT’s records pertaining to matters
covered by this Agreement. CONSULTANT further agrees to maintain
and retain such records for at least three (3) years after the
expiration or earlier termination of this Agreement.
SECTION 16. INDEMNITY. To the fullest extent permitted by law,
CONSULTANT shall protect, indemnify, defend and hold harmless CITY,
its Council members, officers, employees and agents (each an
"Indemnified Party") from and against any and all demands, claims,
or liability of any nature, including death or injury to any
person, property damage or any other loss, including all costs and
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expenses of whatever nature including attorneys fees, experts fees,
court costs and disbursements ("Claims") to the extent that such
Claims result from, arise out of or are in any manner related to
any negligent act or omission or the willful misconduct, whether
active or passive, of CONSULTANT, its officers, employees, agents
or contractors in the performance of this Agreement.
The acceptance of CONSULTANT’s services and duties by CITY shall
not operate as a waiver of the right of indemnification. The
provisions of this Section 16 shall survive the expiration or early
termination of this Agreement.
SECTION 17. WAIVERS. The waiver by either party of any breach or
violation of any covenant, term, condition or provision of this
Agreement, or of the provisions of any ordinance or law, will not
be deemed to be a waiver of any other term, covenant, condition,
provisions, ordinance or law, or of any subsequent breach or
violation of the same or of any other term, covenant, condition,
provision, ordinance or law.
SECTION 18. INSURANCE.
18.1.CONSULTANT, at its sole cost and expense, shall
obtain and maintain, in full force and effect during the term of
this Agreement, the insurance coverage described in Exhibit "D".
CONSULTANT and its contractors, if any, shall obtain a policy
endorsement naming the City of Palo Alto as an additional insured
under any general liability or automobile policy or policies.
18.2.All insurance coverage required hereunder shall
be provided through carriers with Best’s Key Rating Guide ratings
of A-:VII or higher which are admitted to transact insurance
business in the State of California. Any and all contractorsof
CONSULTANT retained to perform Services under this Agreement will
obtain and maintain, in full force and effect during the term of
this Agreement, identical insurance coverage, naming CITY as an
additional insured under such policies as required above.
18.3.Certificates evidencing such insurance shall be
filed with CITY concurrently with the execution of this Agreement.
The certificates will be subject to the approval of CITY’s Risk
Manager and will contain an endorsement stating that the insurance
is primary coverage and will not be canceled, or materially reduced
in coverage or limits, by the insurer except after filing with the
Purchasing Manager thirty (30) days’ prior written notice of the
cancellation or modification, CONSULTANT shall be responsible for
ensuring that current certificates evidencing the insurance are
provided to CITY’s Purchasing Manager during the entire term of
this Agreement.
18.4. The procuring of such required policy or
policies of insurance will not be construed to limit CONSULTANT’s
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liability hereunder nor to fulfill the indemnification provisions
of this Agreement. Notwithstanding the policy or policies of
insurance, CONSULTANT will be obligated for the full and total
amount of any damage, injury, or loss caused by or directly arising
as a result of the Services performed under this Agreement,
including such damage, injury, or loss arising after the Agreement
is terminated or the term has expired.
SECTION 19. WORKERS’ COMPENSATION. CONSULTANT, by executing this
Agreement, certifies that it is aware of the provisions of the
Labor Code of the S~ate of California which require every employer
to be insured against liability for workers’ compensation or to
undertake self-insurance in accordance with the provisions of that
Code, and certifies that it will comply with such provisions, as
applicable, before commencing and during the performance of the
Services.
SECTION 20. TEI~4INATION OR SUSPENSION OF AGREEMENT OR SERVICES.
20.1.The city manager may suspend the performance of
the Services, in whole or in part, or terminate this Agreement,
with or without cause, by giving ten (I0) days’ prior written
notice thereof to CONSULTANT. Upon receipt of such notice,
CONSULTANT will immediately discontinue its performance of the
Services.
20.2.CONSULTANT may terminate this Agreement or
suspend its performance of the Services by giving ten (I0) days
prior written notice thereof to CITY, but only in the event of a
substantial failure of performance by CITY.
20.3.Upon such suspension or termination, CONSULTANT
shall deliver to the City Manager immediately any and all copies of
studies, sketches, drawings, computations, and other data, whether
or not completed, prepared by CONSULTANT or its contractors, if
any, or given to CONSULTANT or its contractors, if anyr in
connection with this Agreement. Such materials will become the
property of CITY.
20.4.Upon such suspension or termination by CITY,
CONSULTANT will be paid for the Services rendered or materials
delivered to CITY in accordance with the scope of services on or
before the effective date (i.e., i0 days after giving notice) of
suspension or termination; provided, however, if this Agreement is
suspended or terminated on account of a default by CONSULTANT, CITY
will be obligated to compensate CONSULTANT only for that portion of
CONSULTANT’s services which are of direct and immediate benefit to
CITY as such determination may be made by the City Manager acting
in the reasonable exercise of his/her discretion.
20.5. No payment, partial payment, acceptance, or
partial acceptance by CITY will operate as a waiver on the part of
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CITY of any of its rights under this Agreement.
SECTION 21. NOTICES.
All notices hereunder will be given in writing and mailed, postage
prepaid, by certified mail, addressed as follows:
To CITY:Office of the City Clerk
City of Palo Alto
P.O. Box 10250
Palo Alto, CA 94303
With a copy to the Purchasing Manager.
To CONSULTANT: Attention of the Project Director
at the address of CONSULTANT recited above
SECTION 22. CONFLICT OF INTEREST
22.1.In -accepting this Agreement, CONSULTANT
covenants that it presently has no interest, and will not acquire
any interest, direct or indirect, financia.l or otherwise, which
would conflict in any manner or degree With the performance of the
Services.
22.2.CONSULTANT further covenants that, in the
performance of this Agreement, it will not employ subconsultants,
contractors or persons having such an interest. CONSULTANT
certifies that no person who has or will have any financial
interest under this Agreement is an officer or employee of CITY;
this provision will be interpreted in accordance with the
applicable provisions of the Palo Alto Municipal Code and the
Government Code of the State of California.
22.3.If the Project Manager determines that
CONSULTANT is a "Consultant" as that term is defined by the
Regulations of the Fair Political Practices Commission, CONSULTANT
shall be required and agrees to file the appropriate financial
disclosure documents required by the Palo Alto Municipal Code and
the Political Reform Act.
SECTION 23. NONDISCRIMINATION. As set forth in Palo Alto Municipal
Code section 2.30.510, CONSULTANT agrees that in the performance of
this Agreement, it shall not discriminate in the employment of any
person because of the race, skin color, gender, age, religion,
disability, national origin, ancestry, sexual oriehtation, housing
status, marital status, familial status, weight or height of such
person. CONSULTANT acknowledges that it has read and understands
the provisions of Chapter 2.28 of the Palo Alto Municipal Code
relating to Nondiscrimination Requirements and the penalties for
violation thereof, and agrees to meet all requirements of Chapter
2.28 pertaining to nondiscrimination in employment, including
completing the form furnished by CITY and set forth in Exhibit "E".
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SECTION 24. MISCELLANEOUS PROVISIONS.
24.1. This Agreement will be governed by the laws of
the State of California.
24.2.In the event that an action is brought, the
parties agree that trial of such action will be vested exclusively
in the state courts of California or in the United States District
Court for the Northern District of California in the County of
Santa Clara, State of California.
24.3.The prevailing party in any action brought to
enforce the provisions of this Agreement may recover its reasonable
costs and attorneys’ fees expended in connection with that action.
24.4.This document represents the entire and
integrated agreement between the parties and supersedes all prior
negotiations, representations, and contracts, either written or
oral. This document may be amended only by a written instrument,
which is signed by the parties.
24.5. The covenants, terms, conditions and provisions
of this Agreement will apply to, and will bind, the heirs,
successors, executors, administrators, assignees, and CONSULTANTs,
as the case may be, of the parties.
24.6.If a court of competent jurisdiction finds or
rules that any provision of this Agreement or any amendment thereto
is void or unenforceable, the unaffected provisions, of this
Agreement and any amendments thereto will remain in full force and
effect.
24.7.All exhibits referred to in this Agreement and
any addenda, appendices, attachments, and schedules to this
Agreement which, from time to time, may be referred to in any duly
executed amendment hereto are by such reference incorporated in
this Agreement and will be deemed to be a part of this Agreement.
24.8.This Agreement is subject to the fiscal
provisions of the Charter of the City of Palo Alto and the Palo
Alto Municipal Code. This Agreement will terminate without any
penalty (a) at the end of any fiscal year in the event that funds
are not appropriated for the following fiscal year, or (b) at any
time within a fiscal year in the event that funds are only
appropriated for a portion of the fiscal year and funds for this
Agreement are no longer available. This Section 24.8 shall take
precedence in the event of a conflict with any other covenant,
term, condition, or provision of this Agreement.
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IN WITNESS WHEREOF, the parties hereto have by their duly
authorized representatives executed this Agreement on the date
first.above written.
APPROVED AS TO FORM:CITY OF PALO ALTO
Deputy City Attorney
APPROVED:
Director of Administrative
Services
Assistant City Manager
OIR GROUP
By:
Name :
Tit le :
(If corporation: President or Vice-President)
By:
Name :
Title:
(If corporation: Secretary or Treasurer)
Taxpayer Identification No.
Attachments :
EXHIBIT "A" :
EXHIBIT "B" :
EXHIBIT "C"
EXHIBIT "D":
(Compliance with Corp. Code § 313 is
required if the entity on whose behal£
this contract is signed is a corporation.
In the alternative, a certified corporate
resolution attesting to the signatory
authority of the individuals signing in
their respective capacities is acceptable)
SCOPE OF WORK
COMPENSATION
INSURANCE
NONDISCRIMINATION COMPLIANCE FORM
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EXHIBIT ~A"
SCOPE OF SERVICES
Consultant shall perform the following services:
Organizational Culture, Practices and Policies
First, Consultant will review Palo Alto Police Department
written policies and training materials pertinent to internal
affairs and to intake and investigation of citizen complaints.
Second, Consultant will meet with the Police Chief,
thePersonnel & Training Coordinator, and other knowledgeable
personnel within the Police Department to rapidly develop a
thorough understanding of its existing practices concerning citizen
complaints and misconduct investigations.
Citizen Complaints
Intake - The Consultant will arrange to receive an e-mail
synopsis of each citizen complaint within three (3) working days of
the date the complaint is originally made. Consultant will then
converse with the intake officer by telephone to clarify the nature
of the complaint.
Initial investigation - As soon as an investigator is
assigned to the citizen complaint, Consultant will confer with the
Personnel & Training Coordinator by telephone and discuss the
investigative plan.
Follow up - Consultant will confer with the Personnel &
Training Coordinator within two weeks of the original complaint to
evaluate results and determine whether further investigation is
necessary.
Disposition -When the investigation is complete,
Consultant will confer with the Police Chief to recommend a
disposition or to resolve any issues about process not previously
resolved.
Status and tracking -- Consultant will track case status
and disposition on an updated chart and will include current charts
in all reports.
Meet to discuss trends -- Consultant will meet quarterly
with the City Manager and Police Chief to present current tracking
charts and discuss citizen complaint trends, procedural problems
identified and any potential policy issues.
Semi-Annual Reports -- Cumulative tracking charts and
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findings as to identified trends will be included in semi-annual
reports.
Internal Affairs Investigations
Investigation plan -Consultant will discuss the
investigation plan with the Personnel & Training Coordinator and
arrange for a mutually convenient way to update Consultant on the
progress of the investigation.
Follow up; Additional investigation -Consultant will
confer with the Personnel & Training Coordinator periodically to
evaluate results and determine whether further investigation is
necessary. When appropriate, Consultant will request further
investigation from the investigator and/or the investigator’s chain
of command.
Disposition -When the investigation is complete,
Consultant will review the file and then confer with the Police
Chief to recommend a change of disposition, if needed, or to
resolve any issues about process not previously resolved.
Status and tracking - Consultant will track case status
and disposition on an updated chart and will include current charts
in all reports.
Meet to discuss trends - Consultants will meet quarterly
with the City Manager and Police Chief to present current tracking
charts and discuss citizen complaint trends, procedural problems
identified and any potential policy issues.
Reports
Consultant will produce two reports during the year
summarizing its findings and reporting in detail on each
investigation and disposition. It will meet with the City Council
to present each report and discuss any issues or questions raised.
Prior to finalizing each report it is Consultant’s practice to
discuss significant identified problems and recommendations that
the report will contain with the Police Department and the City
Manager. Consultant will solicit the Police Department’s response
and attempt to reach a consensus as to solutions. Consultant will
document the Department’s efforts in its reports.
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EXHIBIT "B"
COMPENSATION
The CITY agrees to compensate the CONSULTANT for professional services
performed in accordance with the terms and conditions of this Agreement, and as set
forth in the budget schedule below. Compensation shall be calculated based on
Consultant’s hourly billing rates up to the not to exceed budget amount for each task
set forth below.
The compensation to be paid to CONSULTANT under this Agreement for all services
described in Exhibit "A" ("Basic Services") and reimbursable expenses, including
travel, shall not exceed $19,936.00. Travel expenses shall be a portion of the total
compensation and shall not exceed $1,260.00. CONSULTANT agrees to complete
all Services, including reimbursable and travel expenses, within these amounts. Any
work performed or expenses incurred for which payment would result in a total
exceeding the maximum amount of compensation set forth herein shall be at no cost
to the CITY.
CONSULTANT shall perform the tasks and categories of work as outlined and
budgeted below. The CITY’s Project Manager may approve in writing the transfer of
budget amounts between any of the tasks or categories listed below provided the
total compensation for Basic Services, including reimbursable expenses, does not
exceed $19,936.00, and travel expenses as a portion of that total compensation do
not exceed $1,260.
BUDGET SCHEDULE NOT TO EXCEED AMOUNT
Task 1 Total $1,710.00
Travel as a portion of total $360.00
(Review Department written policies and training materials and meet with Police
Chief, unit commander of internal affairs and other knowledgeable personnel re:
Department policies, practices, and culture.)
Task 2 Total $5,390.00
Travel as a portion of total $none
(Review intake, investigation, and disposition of an estimated 16 to 22 citizen
complaints)
Task 3 Total $5,582.00
Travel as a portion of total $.none
(Internal Affairs investigation planning, monitoring, evaluation
recommendations for an estimated 6 to 9 investigations.)
and
Task 4 Total $4,174.50
Travel as a portion of total $900.00
(Meet with City Manager & Police Chief quarterly and with City Council semi-
annually.)
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Task 5 Total $
Travel as a portion of total $
(Two semi-annual reports.)
3,080.00
none
Sub-total Task Services
Sub-total Travel Expenses
(as a portion of Basic Services)
Total Basic Services and Travel expenses
$_18,676.00_
$ 1,26O
$ 19,936.00
Maximum Total Compensation $19,936.00
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