MAR 21 0001 IG Final Redacted

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question. Of the 1,445 files actually received, OIG noted that most of them only contained a
one-page document suspending the investigation, juvenile information had been redacted from
some of them, and none of them reflected that any grand jury information had been removed.
In addition, on September 1, 2020, OIG requested that MTPD provide OIG a list of grand jury
cases with the respective MTPD and grand jury case number. To date, OIG has not received
that information. At no time did MTPD advise OIG that it had found any of the missing 1,665
files or that they deliberately withheld them from OIG.
OIG began its investigation in August 2020 and has made multiple attempts to recover all 3,110
investigative files. OIG has provided MTPD numerous opportunities to produce all investigative
material associated with these complaints, but MTPD’s production, to date, has been
incomplete. After six months, multiple suspense deadlines, and given the significant decrease
in the volume of investigative case files being produce by MTPD, the OIG closed its investigation
with MTPD’s limited production of investigative files. In February 2021, OIG advised MTPD in
writing that we concluded our investigation and no longer needed MTPD to submit any more
investigative case files, documentation, or ERs.
An analysis of the documentation provided revealed that approximately 84.1% (1,215 cases) of
what MTPD described as investigative case files lacked any documentation of investigative
activity. MTPD staff’s failure to properly and accurately maintain investigative files, evidence,
and/or associated judicial records obstructed OIG’s ability to determine if CID Detectives ignored
victim complaints between 2010 and 2017. Furthermore, failure to properly maintain
investigative files could affect past prosecutions and appeals and loss of public confidence in
WMATA’s police department. Also, without fully understanding what steps were taken, if any,
to investigate these alleged crimes, there is no assurance that the individuals who may have
perpetrated these crimes have been apprehended.
Furthermore, in 2012, the OIG received an allegation that CID falsified investigations. During
the investigation of that allegation, OIG found discrepancies between what CID Detectives
documented and what the victims in those cases told the OIG. As in this current investigation,
in 2012, the OIG requested to review 2011 and 2012 CID case files; however, MTPD could not
produce 88 out of 134 randomly selected suspended case files. At the time, the former MTPD
Chief of Police informed OIG that MTPD would implement corrective actions based on OIG’s
report; however, OIG found evidence that the corrective actions were never fully implemented.
Implementation of these corrective actions in 2012 could have avoided further mishandling of
CID investigative case files and could have clearly depicted how, if at all, the investigations were
conducted.
Lastly, MTPD provided OIG with some steps that they had implemented as early as 2017;
however, during this investigation OIG did not review how these steps have been implemented
and therefore cannot comment on their impact.
OIG Investigative Findings

In August 2020, OIG requested that MTPD provide all intake complaint data, electronic case
files, hard-copy case files, case status, closing memos, ROI’s, and related records associated
with the approximately 3,110 victim and general complaints referenced above. An analysis of
“This document contains sensitive information and is the property of the WMATA Office of Inspector General (OIG). It should not be copied or reproduced without the written consent of the
OIG. This document is for OFFICIAL USE ONLY, and its disclosure to unauthorized persons is prohibited in accordance with WMATA P/I 7.8.10/5 – Code of Ethics, Section 5.07. It must be
protected during transmission, handling and storage in accordance with WMATA P/I 15.12/2 – Data Sensitivity.”
-3-
the MTPD electronic records, provided to date, revealed that 3,110 victim and general
complaints assigned to CID between 2010 and 2017 were still classified as being in an open
status in CID’s case management database.
OIG’s analysis of MTPD’s partial production of what were purported to be CID investigative case
files (1,445 to date) revealed that of the case files provided, 96% (1,393 cases) involved an array
of felony and misdemeanor offenses such as armed robberies, sexual offenses, kidnapping,
assaults, and other crimes within MTPD’s jurisdiction. In addition, MTPD represented that there
is a corresponding ER for each of the 3,110 investigative case files; however, MTPD could only
produce 1,154 ERs.
Out of the 1,445 case files provided, 82.1% (1,186 cases) contained only a one-page closing
document without any evidence that an actual investigation was ever conducted. Moreover, 2%
(29 cases) contained only two documents, a closing document and the ER, which is a document
generally prepared based on information gathered by the responding MTPD officer. In these 29
cases, however, there was still no evidence that an actual investigation was ever conducted.
Even though these one-page closing documents did not contain investigative activity, they were
nonetheless used to change the status of these investigations from open to suspended, which
signifies that no further investigative activity was warranted. Most closing documents were
signed by CID management officials who justified the suspension status change of these
investigations based solely on a written claim that the statute of limitations to bring charges
against a suspect had passed along with a statement indicating they were unable to locate the
original report and case file.
Based on interviews of CID management officials, the determinations that the statute of
limitations had expired was made solely by reviewing the electronic data manually entered into
CID’s database. According to MTPD, this database contained a general description of the date,
crime, jurisdiction where it occurred, complainant’s, witnesses, suspect’s name if available, and
the name of the Detective assigned, but did not contain details regarding the crime. CID
management officials completed the aforementioned one-page closing documents without
speaking to the assigned Detectives and without reviewing the initial ER if not found in the
original CID investigative file. These one-page reports also did not have the signature of the
investigating Detective assigned to the investigation, according to MTPD documentation.
As reflected above, 84.1% (1,215 cases) of the CID investigative case files produced by MTPD
lacked any documentation of investigative activity to determine if CID Detectives ever performed
basic investigative steps such as interviews of victims, complainants, witnesses, and/or suspects
of the crimes. Furthermore, there was no information in the CID investigative case files to assess
whether evidence such as criminal record checks, photographs, crime scene reports/sketches,
and/or other reports typically used in an investigation were ever collected.
Only 11.7% (169 cases) contained documented evidence of investigative activity which included
not only a closing document and an ER but also documents such as a Summary of Investigative
Activity, Digital Video Recording Request form, email correspondence, court records, and/or
background research documentation. In these 169 cases, although there was some
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investigative activity, 78 investigative case files contained a one-page closing document

suspending the complaints in 2020 by indicating that the statute of limitations expired, and 14
justified the suspension on grounds that there were no suspect or investigative leads.
A CID management official acknowledged that in the Fall of 2019, when the current Assistant
Chief was made aware of this issue, he assigned and instructed CID management officials to
collect documents associated with these complaints. However, this CID management official
said that they still had their normal responsibilities, viewed the effort as a collateral assignment,
and lacked the “manpower” to adequately complete the internal audit they were tasked to do.
The CID management official also indicated that a “cold case” unit would need to be assembled
to properly investigate the aforementioned 3,110 complaints. In addition, they did not know how
to recreate a case file when one was not found; therefore, the CID management official
completed a one-page closing document for the missing case files to show that a case could not
be located.
OIG interviewed numerous other individuals who were current and/or former CID supervisors
from 2010 through 2020. None of these individuals could definitively state that all 3,110 victim
and general complaints were investigated. They all expressed concern over the discovery of
3,110 complaints that still appeared to be in an open status in the CID database. They generally
attributed the lack of accountability and oversight of CID cases to a variety of factors, including
lack of supervisory knowledge of CID’s duties and responsibilities; insufficient supervisory staff;
lack of administrative case oversight; high caseloads; nonexistence of policies and procedures;
and lack of a case tracking system. In addition, the interviews uncovered that performance
evaluations of case work only focused on closure rates, which did not account for suspended
cases and/or disposition of previously open cases from past fiscal years.
During communications and interviews of both the MTPD Chief and Assistant Chief of Police,
OIG was informed that they initiated an audit involving CID case files focused on locating hard-
copy case files (started on or about April 2019). They both said that upon the conclusion of their
internal audit, they expected a final report memorializing their audit findings, but they did not
know when it would be completed. Both the Chief and Assistant Chief expressed concern over
the high number of cases referenced above, the nature of the alleged crimes, and the fact that
the cases were currently being closed with a one-page closing document without any further
investigative activity. Despite almost two years since the start of this audit, OIG must conclude
that the case files cannot be found because, to date, they have not provided OIG with over 1,500
investigative case files.
MTPD’s failure to properly and accurately maintain investigative files, evidence and/or
associated judicial records obstructed OIG’s ability to determine whether CID Detectives ignored
victim complaints between 2010 and 2017. Furthermore, failure to properly maintain
investigative files could affect past prosecutions and appeals and loss of public confidence in
MTPD. In addition, OIG is alarmed that this matter has not been resolved, despite the
commencement of MTPD’s internal audit almost two years ago. OIG is concerned that MTPD
top officials have not made this matter a priority and have not officially determined the root cause
related to the mishandling of these investigative case files or the possibility the victim and general
complaints were never investigated.
-5-
MTPD Associated Administrative Investigation and Personnel Action

During this investigation, OIG learned that even though the failure to properly and accurately
maintain investigative files involved many CID Detectives, only one individual was formally
investigated for violating MTPD’s Ethical Standards of Conduct and Failure to Perform Duties
and Responsibilities. Although this investigation reflected that MTPD’s Office of Professional
Responsibility and Inspection (OPRI) opened an investigation into the matter, the investigation
was actually conducted by management officials from within CID. OPRI is the Internal Affairs
division of MTPD.
In both a May 4, 2019 and May 15, 2019 email, a former CID management official wrote to his
superiors that he found similar issues with other CID Detectives who also did not do follow-up
and/or had missing case files. These emails detailed the issues found regarding the
investigations in question. Additionally, during the current OIG investigation, other witness
statements confirmed that there were similar issues with other CID Detective’s work, similar to
those described in the May 4, 2019 and May 15, 2019 emails.
MTPD’s internal investigation of the one CID Detective focused on investigative work conducted
between 2011 and 2017. It uncovered approximately 177 cases that lacked sufficient
investigative activity. The internal investigation was completed on June 17, 2019 and in
response, the CID Detective under investigation admitted, in part, the following:
“I discerned that I had failed to properly document any investigative effort taken in the
outstanding cases . . . I could not recall what measure of investigative effort had been
conducted on many of these cases due to the amount of time passed and the lack of
documentation on my part. . .”
Although the internal administrative investigation sustained the violations of MTPD’s Ethical
Standards of Conduct and Financial Interest and Failure to Perform Duties and Responsibilities,
MTPD senior management officials did not discipline the aforementioned detective citing the
time that had lapsed since the violations occurred. This CID Detective continues to be assigned
to the unit. In addition, no other Detective was investigated or disciplined for failure to properly
investigate alleged crimes.
Prior OIG Investigation

In August 2012, OIG received a complaint that CID Detectives falsified investigations. On
October 9, 2012, OIG issued an ROI (Case No. 13-0009-I) in which OIG found discrepancies
between what CID Detectives documented and what the victims in those cases told OIG. At the
time, OIG requested to review 2011 and 2012 suspended CID case files; however, MTPD could
not produce 88 out of 134 randomly selected files. At the time, the former MTPD Chief of Police
informed OIG that MTPD would implement corrective actions based on OIG’s report. As part of
a corrective action plan, the Chief issued two memoranda, dated November 26, 2012 and
December 17, 2012. In these memoranda, the former Chief of Police outlined new duties and
responsibilities for CID Sergeants, Lieutenants, and Captains. During this current investigation,
OIG found evidence that those corrective actions were never fully implemented. Implementation
of the corrective actions in 2012 (outlined below) could have avoided further mishandling of CID
-6-
investigations. MTPD suggested the following corrective actions to address OIG

recommendations in 2012:
CID Sergeants will be responsible for:
Conducting a weekly case review of at least one Detective in the unit;

Ensuring that Detectives have started their investigation and victims of crimes have
been contacted within 48 hours; and
Conducting monthly random call backs for ten percent of the cases assigned during a
month or a minimum of ten suspended/closed cases assigned during a month, which
will be documented in a memorandum and sent to the Homeland Security
Investigation and Intelligence Bureau Deputy Chief.
CID Lieutenants will be responsible for:
Holding a minimum of one weekly formalized roll call when Detectives will provide
updates on their cases;
Conducting examinations of the cases that have been reviewed by the CID Sergeants
to ensure that they are being properly classified and stored at the completion of the
investigation; and
Ensuring that every assigned case is being investigated in a timely and efficient
manner.
CID Captains will be responsible for:
Oversight of the entire case management process and will ensure that the controls
set forth are being adhered to; and
Conducting periodic assessments of the Lieutenant’s administration of the case
management system.
CID Management and Oversight

The current Chief of Police advised OIG that for several years he has been aware there were
issues with CID, including reports not being completed, cases lacking follow-up, and cases not
being properly filed. He added that when he hired the current Assistant Chief in 2018, he made
management oversight of CID one of his top priorities. During his interview, the Assistant Chief
confirmed he had been briefed on CID issues when he was hired. During his early assessment
of CID, he found the unit did not have a case management model in terms of who assigned
cases, supervisors were not well versed in case reviews or case management and file room
management, and there were loosely written standard operating procedures (SOPs) that
Detectives did not know much about.
CID Corrective Action

Based on interviews of various MTPD officials, the following are some of the corrective actions
MTPD implemented recently to improve management oversight of CID. OIG did not verify
whether the corrective actions taken by MTPD have improved CID’s ability to manage
investigations. Based on MTPD’s responses identified below, OIG will not close the
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recommendations and will request that MTPD provide evidence that their corrective actions have
been fully implemented.
In 2017:
CID moved from paper-based files to an electronic case file management system.
In 2018:
Hired former Metropolitan Police Department Assistant Chief to oversee police

operations as MTPD’s Assistant Chief;
Formal case reviews were implemented to discuss assigned cases of all Detectives;
and
Implemented reoccurring meetings to discuss Detectives’ priority cases, called
CIDStats.
In and after 2019:
CID updated its SOP, which was adopted by CID, although not approved through
WMATA Office of Quality Assurance, Internal Compliance, and Oversight (QICO);
o Required Detectives to sign a memorandum indicating that they received a copy
and that they were familiar with and understood everything in the revised SOP;
A technical sergeant, Investigative Review Officer (IRO), position was created for CID to
provide an additional layer of supervision and oversight;
o The IRO is supposed to evaluate the solvability of an investigation based on
facts and current evidence, and the likelihood of obtaining additional evidence;
and
o Cases determined to have a low solvability are assigned to the Digital Evidence
Video Unit where they would review footage, if available. If there is no footage,
the IRO places the case in a suspended status.
OIG Recommendations
OIG is bringing these facts and circumstances identified in this MAR to Management’s attention
for action to ensure that Management is aware of the circumstances surrounding these
investigative cases, to ensure a root cause is identified, and to make sure that corrective action
is taken, including holding the relevant parties accountable.
We recommend the General Manager/Chief Executive Officer take the following actions to
address the issues identified above:
1. Train and develop management staff so they gain experience in conducting,

managing, and leading criminal investigations that are thorough, legally sufficient for
a prosecutor, impartial, objective, timely, accurate and complete;
2. Develop a policy that requires Detectives to meet or exceed the highest investigative
standards, be responsive to all victim complaints, and be held accountable when their
performance fails to meet those standards;
-8-
3. Develop a process that allows for periodic review of CID case files at various
management levels to ensure compliance with investigative policies and procedures;
4. Develop protocols for independent annual or bi-annual inspections reviews to ensure
compliance with appropriate policies and procedures;
5. Develop a process that tracks the amount of cases CID opened in a fiscal year and
how many of those cases were properly dispositioned to ensure any remaining open
cases are made a priority;
6. Direct MTPD to complete their internal audit and provide management and the OIG
with their assessment of these matters;
7. Develop written standards for investigative case file management, both hard copy and
electronic, addressing what documentation must be included in an investigative case
file including, but not limited to, evidence collection, ERs, record of interviews, notes
of interviews, documentation contacting the witnesses and victims, documentation of
efforts made to investigate the allegations and consultation with prosecutors, if
applicable, and retention;
8. Retrain Detectives and CID supervisors on case management, and investigative
steps;
9. Require regular updates of CID’s SOP; and
10. Require that case file reviews and management are timely and prioritize the logical
progress of the investigation instead of closure rates.
This matter is being forwarded to you for review and action as appropriate. Please respond, in
writing, by April 23, 2021, documenting any actions planned or taken.
cc: COO – Leader

MTPD – Pavlik
COUN – Lee
MARC – Sullivan
Corrections and Clarifications:
In the background section, the OIG states in its MAR-21-0001 report that the
"OIG agreed that grand jury information and identifying juveniles could be
removed and redacted from the 3,110 investigative files in question." To clarify,
MTPD invited the WMATA-OIG to CID to view the case files but stated that the
WMATA-OIG could not take the physical case files with them, nor could they
record information from these juvenile case files. WMATA-OIG declined the
invitation to view the files and, as a result, it was necessary for each file to be
redacted to protect juvenile information, as well as any Grand Jury information,
as required by law.
As of this writing, MTPD CID is not aware of any Court of Appeals or

prosecutorial body having a case identified in this investigation affected due to
record keeping issues.
The WMATA-OIG acknowledges that since 2017 MTPD has implemented

many steps to cure the lack of policy, case management, and case review from
2010 to 2016.
The WMATA-OIG report mischaracterizes the cases under review, the

overwhelming majority of which were misdemeanor offenses. A breakdown of
all cases referenced in the investigation is provided below:
o 18,586 cases were assigned from 2010-2017

o 15,467 cases were closed/dispositioned (83.22%)
o 909 cases were open robberies (4.89%)
o 108 cases were open felony assaults (.58%)
o 471 cases were open misdemeanor assault (2.53%)
o 3 cases were open felony sex offenses (.02%)
o 66 cases were open misdemeanor sex Offenses (.36%)
o 48 cases were open indecent exposure cases (.26%)
o 1514 cases were open crimes against property (8.15%)
The MTPD acknowledges the severe deficiencies in the case management of

paper files between 2010 and 2017. Regarding the single-page case sheets
that suspended the investigation, we note that these sheets were intended as
placeholders pending individual review of each detective’s case files, a process
that includes interviewing the detective and searching court records.
MTPD does not make any claims about the statute of limitations. Statutes of
limitations are codified in all three jurisdictions that MTPD serves, and law
enforcement agencies are precluded from bringing charges after the statute of
limitations has expired in a case.
LAW ENFORCEMENT SENSITIVE

NOT FOR GENERAL RELEASE
Page 2 of 5
MTPD made the modernization and reorganization of CID a top priority in 2017
and took many steps noted in the OIG report and outlined in this response.
Beyond these efforts, since 2017, the MTPD Chief has taken steps to provide
and implement model case management policies, file room security,
accountability, performance management systems, electronic case
management systems, as well as increased management oversight to ensure
efficiency and accountability in overall operations of MTPD CID and its
management.
The OIG report asserts that only one individual was formally investigated
for violating MTPD's Ethical Standards of Conduct and Failure to Perform
Duties and Responsibilities. MTPD’s collective bargaining agreement with
FOP precludes lookback discipline that is not timely investigated. The
investigation initiated by CID officials was not timely as the offense
occurred 3-8 years before the investigation. The Detective in question had
improved his performance for 2018, 2019, 2020, 2021 due to implementing
the aforementioned SOP, case review, and robust case management and
oversight. CID officials at the time of these offenses (2011-2016) had no
case management or case review structure in place.
o Based on the above facts, the potential violation of the collectively

bargained FOP contract, and the MTPD CID management failures, the
determination was made to not discipline the Detective in question.
Finally, per the CBA management does not have the ability to transfer
members for duty performance.
It is also noteworthy that in 2019 the Chief of Police reassigned management

that was in place due to their leadership and management issues in managing
CID operations.
Recommendation Response
1. Train and develop management MTPD implemented this recommendation in 2018.
staff so they gain experience in CID holds bi-weekly case reviews at the squad level
conducting, managing, and leading and monthly case reviews with the Investigative
criminal investigations that are Review Officer (IRO) and the CID Lieutenant. MTPD
thorough, legally sufficient, CID conducts a Monthly CIDSTAT meeting to
impartial, objective, timely, discuss specific cases with Command level officials
accurate and complete. in addition to weekly district level briefings at the
Crime Strategy Meeting. The new CID SOP provides
clear case management guidelines for all members
of the unit. The CID Captain has conducted an audit
of the 2019-2020 exceptionally closed cases. In
addition to the bi-annual audit of exceptionally closed
cases, the CID Captain will also audit unfounded
cases bi-annually.

Page 3 of 5
applicable, and retention
8. Retrain Detectives and CID We concur in part. Since 2019, all MTPD CID
supervisors on case management detectives and officials have been given and read the
and investigative steps; CID SOP. MTPD will ensure that all CID Officials
and Detectives are trained annually in the
procedures outlined in the SOP and continue to
monitor the established case management policies to
ensure compliance.
9. Require regular updates of CID's MTPD implemented this recommendation in 2018.
SOP The MTPD CID SOP was updated in 2021 and will
continue to be reviewed and updated as necessary.
10. Require that case file reviews MTPD implemented this recommendation in 2018.
and management are timely and Page 85 of the MTPD CID SOP addresses the case
prioritize the logical progress of the review responsibilities and procedures for all CID
nvestigation instead of closure members. As stated earlier, there are bi-weekly and
rates. monthly case reviews with various CID command
levels that will address any perceived investigative
inadequacies that CID Officials discover.

Page 5 of 5
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that the Chief provide us with the names of prosecutors associated with the Grand Jury cases
so OIG could obtain permission to review those files. We never received a response from the
Chief to that request. As with any investigation, the production of records must meet legal
standards for admissibility should documentary evidence reveal criminal misconduct.
The WMATA-OIG report mischaracterizes the cases under review, the overwhelming
majority of which were misdemeanor offenses.
OIG did not mischaracterize the cases under review. OIG relied on MTPD records which
focused on the central issue - whether CID detectives failed to investigate 3,110 victim
complaints. According to MTPD’s own internal communication and CID management staff
analysis, approximately 40% of the cases under review were classified as felonies, such as
armed robberies, sexual offenses, kidnappings, and assaults.
Regarding the single-page case sheets that suspended the investigation, we note that
these sheets were intended as placeholders pending individual review of each detective’s
case files, a process that includes interviewing the detective and searching court records.
According to interviews of CID management officials, internal written communications, and

CID SOP, these single-page case sheets were used to reclassify these open investigations
from “open” to “suspended.” According to CID’s own SOP and witness interviews, a
suspended status is defined as having exhausted all investigative leads and essentially ends
the investigation.
MTPD does not make any claims about the statute of limitations. Statutes of limitations
are codified in all three jurisdictions that MTPD serves, and law enforcement agencies are
precluded from bringing charges after the statute of limitations has expired in a case.
Documentary evidence of internal communications reflect that CID management officials

instructed CID officials to use the statute of limitations as a way to close out these open
investigations. OIG found no supporting analysis in these files as to which statute of
limitations supposedly applied or what facts in the cases led to a conclusion that charges were
time-barred.
The Detective in question had improved his performance for 2018, 2019, 2020, 2021 due to
implementing the aforementioned SOP, case review, and robust case management and
oversight. CID officials at the time of these offenses (2011-2016) had no case management
or case review structure in place.
The statement is not supported by testimonial, documentary, and internal communications

between MTPD command staff and CID Officials. During fiscal year 2018/2019, the
“Detective in question” received a subpar evaluation for “…multiple investigative deficiencies
in assigned cases to include lack of communication and follow up with victims/complainants
in his assigned cases.” Furthermore, this evaluation resulted in the “Detective in question”
being placed on a Performance Improvement Plan.
“This document contains sensitive information and is the property of the WMATA Office of Inspector General (OIG). t should not be copied or reproduced without the written consent of the OIG.
This document is for OFFICIAL USE ONLY, and its disclosure to unauthorized persons is prohibited in accordance with WMATA P/I 7.8.10/5 – Code of Ethics, Section 5.07. It must be protected
during transmission, handling and storage in accordance with WMATA P/I 15.12/2 – Data Sensitivity.”

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OIG Investigative Findings

investigative activity, 78 investigative case files contained a one-page closing document

MTPD Associated Administrative Investigation and Personnel Action

Prior OIG Investigation

investigations. MTPD suggested the following corrective actions to address OIG

CID Sergeants will be responsible for:

Conducting a weekly case review of at least one Detective in the unit;

CID Lieutenants will be responsible for:

CID Captains will be responsible for:

CID Management and Oversight

CID Corrective Action

Hired former Metropolitan Police Department Assistant Chief to oversee police

In and after 2019:

1. Train and develop management staff so they gain experience in conducting,

cc: COO – Leader

As of this writing, MTPD CID is not aware of any Court of Appeals or

The WMATA-OIG acknowledges that since 2017 MTPD has implemented

The WMATA-OIG report mischaracterizes the cases under review, the

o 18,586 cases were assigned from 2010-2017

The MTPD acknowledges the severe deficiencies in the case management of

LAW ENFORCEMENT SENSITIVE

o Based on the above facts, the potential violation of the collectively

It is also noteworthy that in 2019 the Chief of Police reassigned management

LAW ENFORCEMENT SENSITIVE

LAW ENFORCEMENT SENSITIVE

According to interviews of CID management officials, internal written communications, and

Documentary evidence of internal communications reflect that CID management officials

The statement is not supported by testimonial, documentary, and internal communications

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