Putting it all Together: Case Development Process (Participant's Guide)


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    Putting It AH Together
  ' ^ f ,; JiV The Case Development Process

         *                  Participant's Guide
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 Module 1: Course Overview
MODULE 1 OVERVIEW

       The purpose of this module is to:

       •  Review the goals and objectives for this training course.
       •  Determine participants' expectations for this course.
       •  Introduce participants to the enforcement case development process.
       •  Define the roles of key enforcement personnel in the process and their effect and
          influence on other roles.
CONTENTS  ,                •   "                         ••'..-.-'

       This module includes the following:

       •  Lesson 1: Getting the Most from the Case Development Training Course
       •  Lesson 2: Understanding the Case Development Process
       •  Summary
           Your Notes:
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Page 1-1

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 Module 1: Course Overview
LESSON 1: Getting the Most From the Case Development Training Course
             Your Notes:
                                       Course Objectives


                                Identify the four steps in the process.

                                Describe the roles of key enforcement personnel.

                                Select the type of evidence required to support each
                                element of an enforcement action.

                              > List the requirements for preserving the integrity of
                                evidence.

                              J* Identify the challenges inherent in each of the steps.

                              * Describe the roles in the courtroom process.
                                                                          L1C
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Module 1: Course Overview
ACTIVITY: Course Expectations
Purpose:      The purpose of this activity is to identify your expectations of the knowledge
               and skills that you will acqiiire upon completion of this training course.
Instructions:   Take a few moments to write down your expectations of this course.
               For the next 2 days, I will be learning about...
               Specifically, I need to know more about...
               The biggest need that this course will satisfy for me is.
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 Module 1: Course Overview
LESSON 2: Understanding the Case Development Process
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Page 1-4
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Module 1; Course Overview
                     Enforcement Case Development
                                   Process
         Your Notes:
Putting It All Together — The Case Development Process - Participant's Workbook

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Module 1: Course Overview
Step 1: Gather evidence.
Enforcement Case Development
? Process
.
Oather evidence.
Your Notes:
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Page 1-6
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(Vlodule I: Course Overview
Step 2: Determine violations.
Enforcement Case Development
Process
Your Notes:
Putting It AH Together — The Case Development Process - Participants Workbook
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Module 1: Course Overview
Step 3: Select appropriate enforcement response.
Enforcement Case Development
i^l*n>i,Lj-f- VKif •*• .
Process
1
Sfepl.
fcihet evidence.
*, .SfepZ.
Your Notes:
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Module It Course Overview
Step 4: Pursue the enforcement action.

Enforcement Case Development:
Process
evidence
Your Notes:
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Page 1-9
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Module I: Course Overview
Roles of Key Enforcement Personnel
Your Notes:
Roles of Key Enforcement
Personnel
Putting It All Together— The Case Development Process - Participant's Workbook
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Module 1: Course Overview
ACTIVITY: Challenges for;Key Players in the Enforcement Case Development Process
Purpose: The purpose ofthis activity is to recognize and identify potential challenges
that key players in the case development processfmay encounter.
Instructions: Talk with the other members of your group. Using your knowledge of the
. enforcement case development process and the,roles of key players,
,, brainstorm possible challenges .or obstacles that you may see for specific roles
in me ease development process. Think about:

V- The effect of one role on .others. - \ '
/ Outside forces and roles not identified in the process.
Your Notes:
Putting It All Together— The Case Development Process - Participant's Workbook
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ModvAe a-. The Four Steps to Case Development
MODULE 2 OVERVIEW
The purpose of this module is to:
Explain the roles and responsibilities of each of the key players in the four steps'.
Identify the purpose of each of the four steps.
Determine the triggers that might initiate case development.
Explain each of the four steps in the enforcement case development process.
Identify the challenges (and ways to overcome the challenges) that may be
encountered in each of the four steps.
CONTENTS
This module includes the following:

• Lesson 1: Gathering Evidence
• Lesson 2: Determining Violations
• Lesson 3: Selecting the Appropriate Enforcement Response
• Lesson 4: Pursuing the Enforcement Action
• Summary ,
Your Notes:
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I!;11! :'''V • '
2: The Four Steps to Case Development
LESSON 1: Gathering Evidence

The Fourth Amendment to the United States Constitution
What is the purpose of the Fourth Amendment?
Your Notes:
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Module 2: The Four Steps to Case Development
Exception;.
Precedent Case, -
Open
fields
Oliver v. United States. 466 US 170

Narcotics agents investigated a tip that marijuana was being grown on a farm.
Agents inspected the fields, and the Court upheld the search. . . •" -

Dow Chemical Co. v. United States. 476.US 227 (1986)

EPA flew over the Respondent's facility and photographed, smokestack
emissions. The Court ruled that since the area observed was an open field, the
inspection did not constitute a search.
Plain view
Coolidse v. New Hampshire. 403 US 443 (1971)'

The seizure of a murder suspect's car on the basis of the plain view exception
was denied since there was opportunity for police to obtain a valid warrant, the
car's location was known in advance, and the car was intended to be seized as
part of the murder investigation. Criteria fora plain-view exception for a
warrantless search and seizure are that the Inspector must have:

S Prior independent justification for being in a position to observe the
evidence, ,
«/ Immediately recognized the information as evidence, and
/" Discovered the evidence inadvertently.

Horton v. California. 496 US 128 '(1990)

A policeman obtained a warrant to search a home for stolen goods. During the
search, the officer seized weapons that were in plain view. The Court upheld
that inadvertent discovery of evidence is a characteristic of a plain view seizure,
but it is not a necessary condition.
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.Module 2: The Four Steps to Case Development
Exception
Emergency
situations
Camara v. Municipal Court. 3 87 US (1967)

Camara refused to allow housing inspectors to enter his house without a warrant.
The Court ruled that a warrant is required to search a home except in certain
narrow circumstances such as emergencies.

Example: An Inspector suspects that an illegal chemical has been used on a
lawn, and rain is imminent. In the time it might take to obtain a warrant, the rain
may spread the chemical. This situation may qualify as an emergency.
Informed
consent
In re: George Huth. d/b/a/ Huth Oil Company and Joyce Nichols. Docket No.
TSCA-V-C-196

The Respondent filed a Fourth Amendment challenge to information collected
by a TSCA State Inspector. The Court ruled that a search conducted pursuant to
valid consent is constitutionally permissible. Consent must be given in the
absence of threats, coercion, deception, or entrapment.

In re: Aeland Incorporated.CO-OP.. I.F.&R. No. VIII-91C

The Respondent consented to an inspection and later changed his mind. The
Court ruled that a warrant is unnecessary when consent to an. inspection is given
and documents requested were voluntarily provided.

In re: Lihue Plantation Co.Ltd.. Docket No. TSCA-0990-00()l, Initial Decision
(1991)

An EPA Inspector conducted an inspection to determine compliance under the
Clean Air Act, and requested an opportunity to look at PCB transformers. Since
the Inspector did not provide written notice of his intention to conduct an
inspection under TSCA, the Respondent contended that evidence obtained in the
TSCA inspection be excluded. The Court ruled that the Respondent in effect
consented to the TSCA inspection by failing to voice any objection to the
inspection and voluntarily complying with the requests.
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iS •. i , ,1.1:
ii:!!!1!!
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Module 2.-. The Four Steps to Case Development
Step 1: Gathering Evidence
What is the purpose of gathering evidence?
a&-!*ft$ft-s^
What are some triggers that would initiate an investigation and
gathering of evidence?
Your Notes:
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Module 2: The Four Steps to Case Development
Types of Evidence
Type
,;,' Notes ''
Testimonial
Physical
Documentary
Demonstrative
Judicially nQted
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ModuVe 1-. The Four Steps to Case Development
Federal Rules of Evidence/Part 22 Rules
Rule
, "" 'Notes ,
Authenticity and
identification
Relevance
Foundation
Competence
Credibility
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Module 2: The Four Steps to Case Development
Maintaining the Integrity of Evidence
Guideline
Note the collection
conditions and
surroundings
Look for the general
identity and sameness
Take precautions to
ensure identity
Present conditions or
features that vary
Determine the
representativeness of
an item
Connect the chain-of-
custody
Additional guidelines
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Module 2-. The Four Steps to Case Development
Challenges of Step 1: Gathering Evidence
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Module 2: The Four Steps to Case Development
LESSON 2: Determining Violations

Step 2: Determining Violations
What is Otis purpose of Step 2?
Your Notes:
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ModuVe 1-. The Four Steps to Case Development
Verifying a Violation
Review the inspection
report.
Review statute and
regulations.
Confer with the
Investigator/Inspector.
Review previous
inspections.
Determine if there is a
violation.
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Module 2: The Four Steps to Case Development
Challenges of Step 2: Determining Violations
Challenge , :
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Module 2: The Four Steps to Case Development
LESSON 3: Selecting the Appropriate Enforcement Response

Step 3: Selecting the Appropriate Enforcement Response
What is the purpose of Step 3?

Your Notes:
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Module 2: The Four Steps to Case Development
Five Types of Enforcement Responses
Response
Ott
Notice of
violation (NOV)
Administrative
order vvdthout
penally
Administrative
order with
penalty
Referral to the
Department of
Justice
Defer to the state
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ntf
Enforcement Responses
E vidence of violation
(Process Steps 1 and 2)
Administrative Order
with penalty (APO)
1
APO
administrative hearing
Referral to the
Department of Justice
1
Civil judicial
trial
Appeal
Notice of Violation
(HOV)
1
Administrative Order'
without penalty

Defer to
state

23D
Your Notes:
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Module 2: The Four Steps to Case Development
sys^iSXfi*"^ *
Administrative Order
Admi n islralivc O rdc r
without penalty
Adminstnativc
complaint
Service
pracerss
Respondent's
Settlement
conference
Law Judge
23E
Your Notes:
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Module 1\ The Four Steps to Case Development
Challenges of Step 3: Selecting the Appropriate Enforcement Response
Ways fc* Overcame tine Challenge
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Module 2: The Four Steps to Case Development
LESSON 4: Pursuing the Enforcement Action

Step 4: Pursuing the Enforcement Action
What is the purpose of Step 4?
Your Notes:
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Module 2: The Four Steps to Case Development
Five Types of Enforcement Actions
ic* JPWSU6 *it0 Five Types af Enfe
Significance
Notice of
violation (NOV)
Administrative
order without
penalty
Administrative
order with
penalty
Referral to the
Department of
Justice
Defer to the state
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*,;',
Module 2: The Four Steps to Case Development
Challenges of Step 4: Pursuing the Enforcement Action
/,,.' W&ys
~
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Reference

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Case Development Reference Materials
Table of Contents
Enforcement Case Development
What is enforcement case development?
The Fourth Amendment to the United States Constitution ...... ............ ............ 2
Fourth Amendment , ,
Warrant Requirement Exceptions and Precedent Cases . . .................. 3
5
5
Step 1: Gathering Evidence ........ ......
What do we mean by evidence and why is it important to the case .
development process? ................... .................
What is ike purpose of gathering evidence? .......... . .......... . . ---- ;
What are some triggers that would initiate an investigation and
...... gathering of evidence? ..... ................................ . ........ 6
Types of Evidence .......................... .............................. 7
Federal Rules of Evidence ........ . . . . . ...... ....... .......... ......... .... 8
Guidelines for Marntaining the Integrity of Evidence ........................ .... 9
.. ' . , , .f| .,, .' • ' • , •„, . '•
Step 2: Determining Violations ........... . .................. . ...... ............. 10
Whatisthe/»MrpojeofStep2? ........ ....... . ..... ..... ..... ... ........ ...10
Verifying a Violation ................................... ................. 11

Step 3: Selecting the Appropriate Enforcement Response ...... ...... . . .............. .12
What is tiaepurpose of Step 3? . . ................... . . . . . ---- ...... ... ...... 12
Five Types of Enforcement Responses ........ . ........ ....... ..... ......... 13

Step 4: Pursuing the Enforcement Action ..... ....... . .......................... ... 14
What is ib&purpose of Step 4? . . . •. ....... ....... ---- ............... ---- . . . 14
Spotlight on Environmental Justice ...................... ................... 14
Actions to Pursue the Five Types of Enforcement Responses . ................. ... 15
> .1 'i1 • . . ~ ' .'•,';,••'•
Roles of Key Enforcement Personnel
in Each Step of the Case Development Process ............. . ....... . . ......... 16
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Case Development Reference Materials
Enforcement Case Development
What is enforcement case development?
S Case development includes all the activities involved in the enforcement process.

/ Case development functions are performed by a variety of key personnel, including
inspectors, case developers, program staff, attorneys, and enforcement officers,

V Case development actually begins when the Inspector prepares for an inspection. For the
purpose of this course, the process begins when evidence is gathered and is concluded
when an appropriate enforcement response is carried out.
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Case Development Reference Materials
The Fourth Amendment to the United States Constitution
What is the purpose of the Fourth Amendment?
»/ The Fourth Amendment to the United States Constitution is designed to protect citizens
from unauthorized government invasion.
', • !i ' ' I V '"•» .' • , , ' - „ ,, • '''„ • '' , , ' i ' " ,''','''„"
/ The Fourth Amendment also clarifies and distinguishes the EPA inspector's authority to
enter and conduct inspections or investigations.

v' The U.S. Supreme Court has consistently ruled that a warrant must be issued prior to a
search. There are several relevant exceptions to this requirement.

/ These exceptions have been established through several precedent cases, which clarify
the EPA inspector's right and responsibilities for entering to conduct inspections or
investigations.
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Case Development Reference Materials
Fourth Amendment
dreiaeiit Exeeptuais and JPrecedtettt Cases
Open
fields
Oliver v. United States. 466 US 170

Narcotics agents investigated a tip that marijuana was being grown on a farm.
Agents inspected the fields, and the Court upheld the search.
Dow Chemical Co. v. United States. 476 US 227
EPA flew over the Respondent's facility' and photographed smokestack
emissions: The Court ruled that since the area observed was an open field, the
inspection did not constitute a search.
Plain view
Coolidee v. New Hampshire. 403 US 443 ri97n

The seizure of a murder suspect's car on the basis of the plain view exception
was denied since there was opportunity for police to obtain a valid warrant, the
car's location was known in advance, and the car was intended to be seized as
part of the murder investigation. Criteria for a plain view exception for a
warrantless search and seizure are that the Inspector must have:

S Prior independent justification for being in a position to observe the
evidence,
S Immediately recognized the information as evidence, and
S Discovered the evidence inadvertently.

Horton v. California. 496 US 128 (1990')
A policeman obtained a warrant to search a home for stolen goods. During the
search, the officer seized weapons that were in plain view. The Court upheld
that inadvertent discovery of evidence is a characteristic of a plain view seizure,
but it is not a necessary condition.
Putting It All Together — The Case Development Process - Participant's Workbook
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Case Development Reference Materials
Wa
a»4 Ihreee&aat Cmps
Emergency
situations
Camara v. Municipal Court. 387 US (1967)
Camara refused to allow housing inspectors to enter his house without a warrant.
The Court ruled that a warrant is required to search a home except in certain
narrow circumstances such as emergencies.

In re: Agland Incorporated. CO-OP.. I.F.&R. No. VIII-91C

The Respondent consented to an inspection and later changed his mind. The
Court ruled that a warrant is unnecessary when consent to an inspection is given
and documents requested were voluntarily provided.

In re: Lihue Plantation Co. Ltd.; Docket No. TSCA-0990-0001, Initial Decision
(1991)

Evidence is any information or proof that helps establish me truth.

In enforcement case development, evidence is gathered (such as collecting samples) to
determine if there is a violation of a statute or regulation.

The person or persons who gather the evidence for. a case must clearly state their findings
in an inspection report.
What is the purpose of gathering evidence?
To'collect samples and determine if there is a violation.

Proper development, documentation, and maintenance of samples and records is critical
to successful case development, so that evidence is admissible if it becomes a case. .
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Case Development Reference Materials
What are some triggers that would initiate an investigation and
gathering of evidence?
Citizen complaint
Neutral scheme inspection
Follow-up on previous inspection
Request from the state
Self-monitoring reports
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Case Development Reference Materials
,- Type&-a£ Evidence--" "
,-%*'
Testimonial
t
Physical
Documentary
Demonstrative
Judicially noted
Description
What an Investigator/Inspector:
•/ Saw. .
V Heard. ' . ,
V Smelled. . - .
/ Felt. ' "
Objects
Documents which substantiate the
company's compliance or
non-compliance.
Evidence that helps the judge or jury
form a mental picture of the situation.
Evidence that is scientifically
accepted.
— -% Exalte ^'- '
• Leaking barrels
• Chemical odor
Contaminated dirt
• Reports
• Logs ' .
• Accounting ledgers
• Computer printouts
• Photographs
• Maps ,
« Schematics ,
• Testing devices
• Geographic locations
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Case Development Reference Materials
• • : " '
Rule
Authenticity and identification
Relevance
Foundation
Competence
Credibility
Federal Hutes of Evidence , , ' '$ •."&**
..?.':...' .-;•!.> '/' '..*. '. -• / f f :
S Evidence must be proven to be what it is claimed to be
(for example, a sample taken during the inspection).
S Evidence must relate to the fact in question.
S Preliminary evidence presented must establish that the
additional evidence is what the proponent says it is.
S Evidence must be efficient, effective, and gathered with
expertise.
^ Evidence must be worthy of belief. ,
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Case Development Reference Materials
, ' "' GiiyelJniesfftrMaimtaiiiiagtlielitle^ritf dfEvldettce
,
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Case Development Reference Materials
Step 2: Determining Violations
What is the purpose of Step 2?
Determination, pf whether a violation exists is based on the information in the inspection
report created in Step 1 of the process.

The report must be carefully reviewed in conjunction with the appropriate statutes and
regulations.

If necessary, additional evidence and information are gathered.
V - " " * . • •• . ' ' >Vi ','' • ,i.' . •'•;''••' i ' •( .,
If no violation is found based on the gathered evidence and inspection report, the case is
dropped; if a violation is found, the case continues to Step 3 of the process.
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Case Development Reference Materials
\., ^ \ / ' Step 2i JDeterminiog' Vielaiioas , "'-
\, '' "''<•> , yfi*i%iag«Ti»Iaiio-a * < \ ,, , ' . ,. „
'fr ^ulHS-te|)i
Review the inspection
report.
Review statute and '.
regulations.
Confer with the
Investigator/Inspector.
Review previous
inspections.
Determine if there is a
violation.
- ^ I%eifi£ii6tt ',-, '' _ -_
The Case Developer/Program staff reviews the facts in the inspection
report which was developed and based on the evidence gathered in
Stepl.
The Case Developer/Program staff reviews the statutes and
regulations that are appropriate for the company's business.
The Case Developer/Program staff confers with the
Investigator/Inspector who performed the site visit to clarify any
questions and confirm any assumptions about the case.
The Case Developer/Program staff reviews previous inspections for
the company to ascertain patterns and history.
The Case Developer/Program staff determines if there is a
violation(s) based on his/her:
/ -Review of gathered evidence.
S Review of statutes and regulations.
/ Discussion with the Investigator/Inspector. .
S Review of the company's previous inspections,
S Discussion with the Attorney.
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Case Development Reference Materials
Step 3: Selecting the Appropriate Enforcement Response
What is the purpose of Step 3?
^
Once a violation has been determined in an individual case, there may be multiple
enforcement options available.

There are many considerations used to determine the appropriate enforcement response
Including the:
i, ' ' . ' ' ' • • ;' , . ',!!',': '"• • , • , '
• Type of violation, regulation, and statute.
• Size and significance of the violation.
» Severity of the pollutant.
« Cooperation offered by the company involved:

Once these (and possibly more) considerations have been applied, you are more able to
judge the best enforcement response for the individual case.

Selection of the appropriate enforcement response is based on:
;" '"' , , . ' . ' •" •' '. , • . '' ,";
• The violation identified in Step 2 of the process, which is based on...
• . ..the evidence gathered in Step 1 of the process.
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Case Y>eve\opment Reference Materials
Five Types- <>f Ea&reeiaieKt Releases
Notice of
violation (NOV)
A warning to the company.
Used primarily for CAA SIP violations, RCRA, FIFRA, TSCA, and
EPCRA programs. •-.. ''
Provides an opportunity for me. company to meet with the EPA.
Usually in lien of the penalty. - .".••"
Admini.strative
order without
penalty
An order of compliance and action only.
Frequently used with CWA.
Places the burden on the company to show cause for the violation.
May have a letter of agreement.
Administrative
order with
penalty
i/ Order of compliance and action including a penalty.
/- Use is based on regulatory factors.
S Use is restricted by statues of .limitations.
/ 40 CFR Part 22 describes the procedures for issuing the order.
/ The company and the EPA enter negotiations for settlement by
Consent Agreement/Consent Order (CACO) or litigation.
Referral to the
Department of
Justice
S Tends to be adversarial, confrontational, arid expensive; more
expedient and less expensive for the company to deal with the EPA. ,
V Infrequently used as an enforcement action.
S Used after the limits a statutory act are reached (e.g., CAA - length of
violation, amount of penalty). :
V Referral to DOJ is required in some cases.
Defer to the state
Program is delegated to the state by the EPA; states work separately
from EPA regions; a person does not have to act before a state can
pursue action under a delegated program.
Usually involves smaller penalties.
Company may prefer to deal with the state, less stringent, less time.
Resource or relationship issues may exist.
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Case Development Reference Materials
Step 4: Pursuing the Enforcement Action
What is fas purpose of Step 4?
The EPA enforces identified violations to protect human health and the environment.

It is important for the EPA to pursue enforcement actions to deter future violations.

To follow-through on the conclusions and decisions made in the previous three steps of
the process, enforcing the determined response types and penalties.

Pursuit of an enforcement action is based on:

• The appropriate enforcement response selected in Step 3 of the process, which is
based on...
" ...the violation identified hi Step 2 of the process, which is based on...
• ...the evidence gathered hi Step 1 of the process.
In
, • ,
lv^clrd^IlS^^^'^gi^^ The
to

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Case Development Reference Materials
AeB««istd^iir£iietlteI^eT^
Res;pGB$£
Notice of
violation (NOV)
Administrative
order without
penalty
Administrative
order with
penalty
.Referral to the
Department of
Justice
Defer to the state
jytti&tt ".-"\ -
S Warning letter identifying:
• Violations(s) found.
" Methods to correct violation.
• Due date to remedy violation.
S Legal order issued requiring the
recipient to take some
corrective/remedial action.
S Legal order issued requiring the
recipient to take some
corrective/remedial action with a
penalty assessed.
%^ A formal lawsuit taken in the
U.S. court system by the DOJ at
the request of the EPA.
S State-led response action.
SigltiOfiAttC^ "'
• Advisory in nature.
• Informal metihod used to
require company to return to
compliance.
• More formal method used to
require company to return to
compliance.
• Used by most EPA programs
that have the authority.
• One of the most expeditious
ways to deal with a violation.
• Used against more serious or
recalcitrant violators or for
criminal conduct.
• May be necessary to correct an
imminent hazard to humans,
health, or the environment.
• - Delegated program.
Putting It All Together— The Case Development Process - Participant's Workbook
Page 15
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Case Development Reference Materials
Step of t&e €ase l)eyjBlept»,eat l£»cess
Step
38Jb'l6 fa the
Step 1. Gather
evidence.
Attorney
Evaluates evidence and determines if it is sufficient to
support or prove violations of the legal requirements.
Determines if additional fact-finding is necessary.
Investigator/
Inspector
Identifies and documents the facts pertaining to
potential violations.
Writes the inspection report.
Creates routine and careful documentation.
Follows chain-of-custody procedures.
Case
Developer/
Program staff
Evaluates documentation provided by
Investigator/Inspector (such as the inspection report) to
determine violations.
Step 2.
Determine
violations.
Investigator/
Inspector
DOES NOT ALWAYS DETERMINE VIOLATIONS.
Serves as a witness to inspection and observation and
should be knowledgeable of regulations, but does not
necessarily determine the violations.
Case
Developer/
Program staff
Analyzes evidence and facts to determine the:
• Violations.
• Facts that support each violation.
• Responsible parties.
Many regions combine the roles of the Investigator and
the Case Developer.
Attorney
Assesses program analyses to determine if the:
• Correct violations have been identified.
• Evidence supports the alleged violations.
Putting It AH Together — The Case Development Process - Participant's Workbook
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Case t>eve\opment Reference Materials
; " Rol^^fKey^foree»t€fttI*eirs^nael -
"- m EadbStep &t the Case Be^dtojpaieat Process , \ ^
- s*» . :
Step 3. Select
appropriate
enforcement
response.
Step 4. Pursue ,
the enforcement
action.
^ KJB? Player, ,
Case
Developer/
Program staff
Attorney
Attorney
Enforcement
Officer
~.~ / K^yPM^r'jsjadl^lfltke^fep
/•' Prepares the penalty calculation.
/ Participates in drafting legal documents and fact-
gathering letters.
S Prepares non-penalty Admmistrative Order.
S Identifies the proper parties to sue.
v^ Prepares legal documents to initiate the law suit.
J Conducts settlement negotiations. •
S Litigates admmistrative cases and participates in the
litigation of judicial cases
%^ Tracks post-settlement compliance with consent
-decrees. .
Putting It All Together — The Case Development Process - Participant's Workbook
Page 17
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