— tit NORAD sre msreucr cour oF OKLAHOMA COT 1 race count OKLAHOMA COUNTY OKLAHOMA SECOND ) AMENDMENT ASSOCIATION, etal, NOV ~ 2 2020 ) Bo Plains, ) ob ) 34. vs. ) — CaseNo. — CV-2020-2065 ) ‘THE OKLAHOMA CRIMINAL ) JUSTICE AUTHORITY, et al., ) ) Defendants, ) MOTION TO DISMISS PETITION FOR DECLARATORY RELIEF BY DAVID PRATER, DISTRICT ATTORNEY INTRODUCTION Before this Court is a legal proceeding in which Plaintiffs attempt to manufacture a controversy where none actually exists in hopes of obtaining a court order that not only violates long-standing decisions of the United States Supreme Court but which could effectively render the Oklahoma County Criminal Justice Authority a sham public trust. As the officer statutorily charged with representing Oklahoma County in all legal proceedings, the District Attorney is not only entitled to intervene in these proceedings but further seeks to vindicate the interests of the County through seeking dismissal of the instant Petition for Declaratory Judgment. ARGUMENT AND AUTHORI Ss Section 2012 of tle 12 of the Oklahoma Pleading Code provides that a party may move to dismiss a Petition where the court lacks jurisdiction over the matter. 12 0.$.2011, § 2012(B)(1). Section 2012 further provides that a party may challenge by motion to dismiss the failure to join a necessary party to suit or the lack of capacity on a party to sue. 12 0.$.2011, § 2012(B)(7), (10). While motions to dismiss are often viewed with disfavor, this general rule is limited to motionsthat seek to challenge the sufficiency of the allegations of a petition to state a claim upon which relief may be granted. H & En Inc., v. Okla, Dep't of Labor, 136 P.3d 1070, 1071 (Okla.Civ.App. 2006); see also Alexander v. Alexander, 357 P.3d 481, 483 (Okla. 2015); Fanning v. Brown, 85 P.3d 841, 844 (Okla, 2004); Indiana Nat, Bank v. State, $80 P.2d 371, 765 (Okla. 1994). Where other legal grounds pursuant to Section 2012 exist, this general rule does not apply; this is particularly true where the jurisdiction of the court is at issue. Id. In the matter sub judice, Plaintiffs’ Petition is subject to dismissal for failing to include a necessary party — the Board of County Commissioners of Oklahoma County — to the proceedings. Even apart from Plaintiffs" failure to include the Board as a necessary party to this litigation, this Court lacks subject matter jurisdiction to grant the declaratory relief requested for want of an actual case and controversy brought by litigants with standing to do so. PLAINTIFFS HAVE FAILED TO INCLUDE THE BOARD OF COUNTY COMMISSIONERS OF OKLAHOMA COUNTY AS A NECESSARY PARTY TO THESE PROCEEDINGS AND, THUS, THEIR PETITION SHOULD BE DISMISSED PURSUANT TO SECTION 2012 OF TITLE 12. As an initial matter, Plaintiffs’ Petition for Declaratory Judgment is subject to dismissal pursuant to Section 2012 of Title 12 on the grounds that it fails to include the Board of County Commissioners as a necessary party to suit. Plaintiffs admit that it was the Board of County Commissioners that unanimously voted to create the Oklahoma County Criminal Justice Authority, a public trust operating for the benefit of Oklahoma County, and delegate to the Authority the powers and responsibilities to operate the Oklahoma County Detention Center for the benefit of the County. Petition, 44. Plaintiffs have also expressly pled that the Board of County Commissioners voted on October 5, 2020, to declare that it was the policy position of the County that the Oklahoma County Detention Center should fully cooperate with the Immigration and Customs Enforcement Agency (ICE) by allowing federal ICE officers to not only have access 2to the facilities but to honor agency detainers issued for the temporary detention of suspected illegal aliens. Petition, 116. Itis this policy declaration that Plaintiffs seek to declare to be binding upon Defendant Authority. As the body that not only created the Oklahoma County Criminal Justice Authority but passed the policy declaration now at issue, the Board of County Commissioners is the only body that may protect its interests in both regards, Whatever interest Plaintiff Calvey may have in the proceedings as an individual County Commissioner, he has no power to represent either the Board's interests or those of Oklahoma County in these proceedings. AL THE BOARD OF COUNTY COMMISSIONERS HAS AN INTEREST ENSURING THE PROPER INTERPRETATION IS GIVEN TO ITS NON- BINDING IMMIGRATION POLICY STATEMENT. At the core of this litigation is a non-binding immigration policy statement of the Board of County Commissioners that Plaintiffs’ seek to make binding upon Defendant Authority. As the body that made the policy statement, the Board is a necessary party to these proceedings in order to ensure that the same is properly construed by this Court. Contrary to Plaintiffs’ assertions, the Board’s immigration statement is not binding upon Defendant Authority as a matter of law. To illustrate this notion, it is first necessary to understand the division of powers of County officers and, in particular, the limited power of the Board to act in the operation of a detention center. ‘The Oklahoma Constitution creates counties to be bodies corporate and politic. Okla. Const. art. 17, § 1. The Constitution and statutes provide that County functions are spread among, eight elected officials, namely, a Court Clerk, a County Clerk, a Sheriff, a Treasurer, a County Assessor, and three County Commissioners who together comprise the Board of County Commissioners.' Okla. Const. art. 17, § 2; 19 O.S.2011, § 3; 68 O.S.2011, § 2814. As "The offices of County Judge, County Attorney, Registrar of Deeds, County Surveyor, and County Superintendent of Public Instruction created within the Oklahoma Constitution have all been abolished by the Legislature. 19 OS. §§ 215.19, 225, $70; 20 OS. § 91.1; 70 OS. § 4-101constitutionally independent officers, no one County official exercises superintending authority over another. Okla, Const. art. 17, § 2. Though created by the Oklahoma Constitution, neither counties nor County officers have inherent sovereign power; rather, itis left to the Legislature to define the powers and duties of County officials. Okla. Const. art. 17, § 2; Shipp v. Southeastern Okla, Indus, Auth., 498 P.2d 1395, 1398 (Okla. 1972). It is for this reason, public officials possess only those powers which are expressly conferred upon them by statute and that which is incidental to carry out express powers. /d.; Tulsa Exposition, 468 P.2d 501, 507-08 (Okla. 1970); Oklahoma Pub. Emp. Ass'n v Oklahoma Dep'tof Cent. Serv., 55 P.34 1072, 1084 (Okla. 2002). In this manner, each of the eight elected county officials have their own realm of statutory authority outside of which they cannot act. This is true of the Board of County Commissioners as well. Though the Board is the body corporate and politic of the County, 19 0.S.201 1, §3, it too is limited in the powers it may exercise. As stated by the Oklahoma Supreme Court, “The Board of County Commissioners in exercising corporate powers is limited to those fields expressly assigned to such subdivision of the state by the legislature.” Tulsa Exposition, 468 P.2d at 507. Itis often said that the provision of a county jail is a constitutional obligation of the County. Bryson v. Oklahoma County, 261 P.3d 627, 636 (Okla.Civ.App. 2011). Yet, the Legislature has divided the obligations of providing a county jail between the Board of County Commissioners and the Sheriff. Statute requires the Board of County Commissioners to provide the physical structure to be used as a jail, or enter into contracts to provide a jail facility. 57 0.8.2011, § 41 This is consistent with the Board’s general power to make all orders respecting real property of the County. 19 0.S.Supp.2019, § 339(A)(I). The Board is also responsible for providing adequate funding for jail operations ~ a responsibility that is transferred to the Budget Board in counties,like Oklahoma County, operating under the County Budget Act. 57 0.S.2011, § 41; 19 0.8.2011, §§ 1401-1421. Despite its obligation to provide a physical structure to be used as a detention facility and the possible ability to indirectly impact its operation through funding, a Board of County Commissioners has no power to act in the daily operations of a jail. 19 0.S.Supp.2019, § 339 (general powers of the Board); Estate of Crowell v. Bd. of Cnty. Comm'rs, 237 P.3d 134, 142 (Okla. 2010)(noting that the Sheriff is the policy-maker for a county jail and acknowledging that a Board of County Commissioners has no power to hire, train, or supervise employees of a county jail nor power to set policies for the jail, or to oversee the treatment of inmates confined therein). Although the Board of County Commissioners has limited power to act, the same is not true of a County Sheriff. It is upon the Sheriff that the Legislature places all of the day-to-day operational responsibilities of a jail. As provided by Section 513 of Title 19, “The sheriff shall have charge and custody of the jail of his county, and all the prisoners in the same, and shall keep such jail himself, or by his deputy or jailer, for whose acts he and his sureties shall be liable.” 19 08.2011, § 513; see also 57 O.S.2011, § 4 (obligation to keep jail in clean and healthful condition); 57 0.S.2011, § 47 (sheriff to have charge of jail conform its operation to rules promulgated by the Department of Health pursuant to 74 0.8. § 192 governing admission and release procedures, security measures, sanitary conditions, training requirements, housing assignments, medical care, ete. ); 57 O.S.201 1, § 52 (sheriff to provide bedding, clothing, washing, board, medical care and other necessities for inmates), 57 0.8.2011, § 53 (sheriff or his designee shall inquire into the condition of prisoners at least once a month and must comply with standards set by Department of Health); 57 0.S.2011, § 54 (sheriff or his designee to appoint personnel as needed to operate the county jail and provide training for such personnel). In fact, the SupremeCourt has expressly recognized that it is the Sheriff that is the policy-maker for a county jail Crowell, 237 P.3d at 142. ‘While the Legislature placed the obligation for the daily operations of a county jail upon the Sheriff, consistent with its constitutional power to define the duties of County officers, the Oklahoma Supreme Court has recognized that the Legislature altered those duties by enacting statutes that allow for jail operations to be performed by private entities or public trusts. Tulsa Cnty. Deputy Sheriff's Fraternal Order of Police v. Bd. of Cnty. Comm'rs, 995 P.2d 1124, 1130- 31 (Okla. 2000); see also 2007 OK AG 35 4 2 (stating, “a county jail may be operated and ‘maintained by the county sheriff, a public trust or a private contractor retained by the county.”). In effect, these statutes place the operation of a county jail upon the Sheriff by default, with alternative options for the County to place the operational duties upon a private entity or a public trust instead, When operational duties have been placed upon a private entity or a public trust, the statutory obligations of a Sheriff in the operation of a jail are transferred as well. As provided by Section 513.2, “For purposes of any jail facility, holding facility or detention center, every reference in statute or rule to any duty or responsibility imposed upon the sheriff or any jailer to operate, manage or provide any service to any person in the custody of such facility or any service related to the management or operation of such facility shall be deemed applicable to and imposed upon the public trust or private owner or management entity who by contract or otherwise legally operates such jail facility, holding facility or detention facility.” 19 OS.2011, § 513.2(A). This provision is key. To be sure, Section 513.2 makes clear that even when a county jail is operated by a public trust like the Oklahoma County Criminal Justice Authority, the limited powers of the Board of County Commissioners are neither changed nor enlarged. Rather, there is only a change in the officer charged with policy-making authority ~ thepolicy-making authority shifts from the Sheriff to the public trust. 2007 OK AG 35, 44 (noting that where a public trust is formed for the operation of a jail, the trust “steps into the shoes of the county and the sheriff for the purpose of operating the county jail.”) ‘This point has been acknowledged by the Supreme Court which has held that the Legislature intended for the laws governing county jails to apply uniformly and irrespective of the entity that operates the facility. Tulsa Cnty. Deputy Sheriff's Fraternal Order of Police, 995 P.2d at 1129, These authorities make clear that state law grants no power to a Board of County Commissioners to set binding policy for or otherwise manage the daily operations of a county jail ~ this is true regardless of whether the jail is being operated by a Sheriff, a private contractor, or a public trust. The fact that the Board entered into a lease agreement with the Authority for control of the physical structure of the jail does nothing to change the fundamental balance of powers established by the Legislature. Rather, the lease is nothing more than an exercise of the Board’s limited power to manage the disposition of the physical structure of the detention center as County- ‘owned real property. 19 0.8.Supp.2019, § 339(A)(1). Any suggestion to the contrary is specious and untenable. Simply stated, the Board cannot by contractual agreement seck to grant unto itself powers that the Legislature expressly denied to it. While the Board of County Commissioners may be able to make broad statements of their position on issues of public concern that impact the County — much like the issue of detaining illegal aliens ~ the law is clear beyond legitimate dispute that there are no circumstances where the Board of County Commissioners can lawfully adopt any binding policies relating to the operation of a county jail. This interest, without more renders the Board of County Commissioners an indispensable party to these proceedings. Plaintiffs’ failure to include the Board as a party, now demands that the Petition be dismissed pursuant to Section 2012(B)(7)..B. THE BOARD OF COUNTY COMMISSIONERS HAS AN INTEREST IN UPHOLDING THE TRUST INDENTURE CREATING THE OKLAHOMA COUNTY CRIMINAL JUSTICE AUTHORITY TO BE A SEPARATE AND INDEPENDENT POLITICAL SUBDIVISION OF THE STATE AND PREVENTING THE TRUST FROM BEING MADE A SHAM ENTITY. In addition to having an interest in ensuring proper effect is given to its policy position statements, the Board of County Commissioners has a compelling interest in this litigation because it impacts the continuing validity of the public trust created by the Board to operate the Detention Center, As noted in the preceding section, state law grants to the County the option to have its county jail operated by a public trust in lieu of the Sheriff. By virtue of Title 60, Section 176 et seq., the Legislature authorized the creation of express public trusts, like Defendant Authority, existing for the benefit of one or more governmental entities. 60 0.8.2011, § 176 etseg. Although they exist to perform a governmental function on behalf of their beneficiary, “the affairs of the public trust shall be separate and independent from the affairs of the beneficiary in all matters or activities authorized by the written instrument creating such public trust including, but not limited to, the public trust’s budget, expenditures, revenues and general operation and management of its facilities or functions...” 60 0.8.2011, § 176.1(D)(emphasis added). In fact, a public trust is a separate political subdivision of the State. 51 O.S.2011, § 152(11)(d).. Because public trusts are legal entities that are separate and distinct from their beneficiaries, the laws that apply to such trusts may differ from the laws that apply to other governmental entities this is particularly true in the area of funding, The Oklahoma Constitution prohibits the County from incurring long-term debt absent a vote of the people. Article 10, Section 26 of the Oklahoma Constitution provides: “Except as herein otherwise provided, no county, city, town, township, school district, or other political corporation, or subdivision of the state, shall beallowed to become indebted, in any manner, for any purpose, to an amount exceeding, in any year the income and revenue provided for such year without the assent of three-fifths of the voters...” Okla, Const. art. 10, § 26. This provision serves to insure that the County operates on a cash basis and prevents indebtedness extending beyond the fiscal year. City of Del City v. Fraternal Order of Police, 869 P.2d 309, 311 (Okla. 1993). Where the County seeks to incur long-term debt, it must do so though general obligation bonds which are secured by property tax levies used to service the bond debt. 2011 OK AG 5, 14; 2010 OK AG 1, 45. Unlike the County which is limited to voter-approved issuance of general obligation bonds as a means of financing, a public trust is expressly authorized to “issue obligations, enter into financing arrangements including, but not limited to lease-leaseback, sale-leaseback, interest rate swaps and other similar transactions...” 60 0.S.Supp.2017, § 176(A). It is for this reason, it has often been said that “the primary reason for the existence of public trusts in Oklahoma is their ability to issue revenue bonds, service debt from available revenues, and construct and operate public facilities on behalf of their respective beneficiaries.” 2010 OK AG 1, €11. In fact, itis this benefit that illustrates the importance of maintaining the separation between the functions of the public trust and its beneficiary. To be sure, these alternative funding mechanisms are only available because the public trust is a separate and distinct legal entity from its beneficiary; as already noted, the County is constitutionally prohibited from engaging in such activities in its own right. Where the County beneficiary maintains de facto or de jure control over the functions of the public trust, the trust may be declared to be illusory. See e.g., Oklahoma City Zoological Trust v, State, 158 P.3d 431, 466-67 (Okla.2007); Elledge v. Stillwater Medical Center, 62 P.3d 793, 795-96 (Okla.Civ.App. 2002). That is to say, if the governmental beneficiary exerts control overthe functions of a public trust so as to render it nothing more than an alter ego of the beneficiary, the legal benefits afforded to a public trust may be lost entirely. Consistent with these principles, the Board of County Commissioners created the Oklahoma County Criminal Justice Authority. To insure the independence of the Authority that is mandated by state law, Article X of the Trust Indenture expressly provides: ‘The Beneficiary of this Authority shall be Oklahoma County, Oklahoma, under and pursuant to Okla, Stats. Tit. 60, § 176 et seq., as amended and supplemented, and other applicable statues of the State presently in force and effect. The Beneficiary shall have no legal title, claim or right to the Trust Estate, its income, or to any part thereof or to demand or require any partition or distribution thereof. Neither shall the Beneficiary have any authority, power or right whatsoever, to do or transact any business for or on behalf of or binding upon the Trustees or upon the Trust Estate, nor the right to control or direct the actions of the Trustees pertaining to the Trust Estate or any part thereof, except as herein provided. The Beneficiary shall be entitled solely to the benefits of this Trust as administered by the Trustees hereunder, and at the termination of the Authority, as provided herein, and only then, the Beneficiary shall receive the residue of the Trust Estate, Exhibit 1, Trust Indenture (emphasis added). In this manner, the Board expressly disclaimed any right or power to take binding action on behalf of the Authority. Despite the clear legal mandate that a public trust operate independently from its County beneficiary in all affairs and despite the express disclaimer of the right to do so in the Trust Indenture, Plaintiffs’ now take a contrary position that is wholly untethered to the law and facts, In seeking to obtain declaratory relief under these circumstances, Plaintiffs jeopardize the validity of the public trust the Board established for the benefit of the County. After all, a judgment of this Court that gives binding effect to the Board’s policy statement operates to declare that the County has, in fact, exercised de facto control over the Authority's ability to set policy governing the operations of the Detention Center. Thus, in order to preserve the benefits to be derived from the existence of the public trust in the first instance, the Board of County Commissioners is 10unequivocally a necessary party to these proceedings. As such, Plaintiffs’ Petition should be dismissed. ©. PLAINTIFF CALVEY IN HIS CAPACITY AS A COUNTY COMMISSIONER CANNOT REPRESENT THE INTERESTS OF THE COUNTY OR THE BOARD OF COUNTY COMMISSIONERS. Itis beyond question that the Board of County Commissioners has two compelling interests that render them an indispensable party to these proceedings. Of course, the Petition for Declaratory Judgment avers that Plaintiff Calvey, as a duly elected County Commissioner, has standing to seek relief from this Court. Petition, 4 2. The question then becomes whether Plaintiff Calvey may lawfully represent the interests of the Board of County Commissioners. Here too the law provides a resounding answer that he may not Section 4 of Title 19 provides in relevant part, “In all suits or proceedings by or against a county, the name in which a county shall sue or be sued shall be, ‘Board of County Commissioners of the County of ___,’ but this provision shall not prevent county officers, where authorized by Jaw, from suing in their official name for the benefit of the county.” 19 O.S.Supp.2019, § 4 (emphasis added). By the plain language of Section 4, a suit brought on behalf of the County must name as a party the Board of County Commissioners, unless another County official is expressly authorized by law to sue in his or her official capacity for the benefit of the County. The rational for requiring the Board of County Commissioners to represent the interests of the County should be clear; it derives from the role of the Board as the body corporate and politic of the County in the first instance. 19 0.S.2011, § 3. To determine whether Plaintiff Calvey may lawfully represent the interests of the County qua County Commissioner, there must be some express statutory authorization for him to do so. This requires the same survey of state law as was undertaken in determining the scope of powersof the Board in Section I(A). That is to say, because a County Commissioner has no inherent authority, there must be some express statutory grant of authority to an individual County Commissioner to sue on behalf of the County. Shipp v. Southeastern Okla. Indus. Auth., 498 P.2d 1395, 1398 (Okla, 1972); Tulsa Exposition, 468 P.2d 501, 507-08 (Okla. 1970); Oklahoma Pub. Emp. Ass'n v. Oklahoma Dep't of Cent. Serv., 55 P.3d 1072, 1084 (Okla. 2002). Here, there is none. In fact, the Oklahoma Supreme Court well over a century ago recognized that, “The powers of county are vested in a board of commissioners as a corporate entity, and not the commissioners separately and as individual officers.” Mahr v. Bd. of Cnty. Comm'rs, 110 P. 751, 752 (Okla. 1910), As there is no statutory authority for Plaintiff Calvey to represent the interests of the County in his capacity as a County Commissioner, state law dictates the County may only be represented by the Board of County Commissioners as.a party to litigation. Accordingly, Plaintiff Calvey lacks legal capacity to bring suit and, thus, the Petition is subject to dismissal pursuant to Section 2012(B)(10) of Title 12 Th. THIS COURT LACKS SUBJECT MATTER JURISDICTION TO GRANT DECLARATORY RELIEF WHERE THERE IS NO THREATENED INJURY TO PLAINTIFFS, NO RIPE CONTROVERSY BETWEEN COMPETING INTERESTS, AND NOTHING MORE THAN A NON-JUSTICIABLE POLITICAL QUESTION FOR WHICH THE RELIEF SOUGHT VIOLATES THE CONSTITUTION. ‘As firmly established in Proposition I, the Petition for Declaratory Judgment must be dismissed for failure to name the Board of County Commissioners as an indispensable party in light of Plaintiff Calvey’s lack of legal authority to sue in a representative capacity as a County ‘Commissioner. Yet, even apart from these deficiencies, the Petition is wholly inadequate to invoke this Court’s subject matter jurisdiction under the Declaratory Judgment Act. In order to invoke the jurisdiction of the district court pursuant to the Declaratory Judgment Act, a Plaintiff must satisfy the following conditions precedent: “(1) there must exist a justiciable 12controversy; that is to say, a controversy in which a clam of right is asserted against one who has an interest in contesting it; (2) the controversy must be between persons whose interests are adverse; (3) the party secking declaratory relief must have a legal interest in the controversy, that is to say, a legally protectable interest; and (4) the issue involved in the controversy must be ripe for judicial determination.” Gordon v, Followell, 391 P.2d 242, 244 (Okla. 1964); see also Stevens v, Fox, 383 P.3d 269, 274 (Okla. 2016). Applying these principles to the case at bar, Plaintiffs can establish none of the requirements to establish this Court’s jurisdiction to hear and determine the request for declaratory relief. Having failed to plead the jurisdictional preconditions for declaratory relief, Plaintiffs’ Petition should be dismissed. A. PLAINTIFFS HAVE NO LEGALLY PROTECTABLE INTEREST IN THE ALLEGED CONTROVERSY AND THEIR LACK OF STANDING DEPRIVES THIS COURT OF SUBJECT MATTER JURISDICTION. “Before there can be a case of actual justiciable controversy presented to the court, there must be a party with standing to pursue the action so courts are asked to determine legally protected interests which are concrete, and are not asked to decide hypothetical or conjectural question: Knight v, Miller, 195 P.3d 372, 375 (Okla. 2008). “Standing focuses on the party secking to get his complaint before the court and not on the issues tendered for determination.” Jd. Where there is a lack of standing on the part of the plaintiff, the court is deprived of jurisdiction to hear and determine the issues presented. In re Estate of Doan, 727 P.2d 574, 576 (Okla. 1986); Osage Nation v. Bd. of Comm'rs, 394 P.3d 1224, 1245-46 (Okla. 2017)(noting standing is jurisdictional and properly raised pursuant to Section 2012(B)(1) in a motion to dismiss). “The general, threshold criteria of standing include: (1) a legally protected interest which must have been injured in fact, i.e., suffered an injury which is actual, concrete and not conjectural in nature, (2) a causal nexus between the injury and the complained-of conduct, and (3) a 13likelihood, as opposed to mere speculation, that the injury is capable of being redressed by a favorable court decision.” Hunsucker v. Fallin, 408 P.3d 599, 614 (Okla. 2017). “Not only is standing confined to those whose interest in the controversy is direct, immediate and substantial, a litigant must also have a personal stake in the outcome.” Hendrick v. Walters, 865 P.2d 1232, 1236-37 (Okla. 1993). These criteria are unchanged when the party seeking relief is a government official acting in their official capacity. Id. Where a party is an association, standing is established only where: (1) its members would have standing to sue in their own right; (2) the interests it seeks to protect are germane to the organization’s purpose; and (3) participation of the individual members of the association is not required based upon the claim asserted or the relief sought. Osage Nation, 394 P.3d at 1244. The party seeking to invoke the Court’s jurisdiction bears the burden of establishing their standing to seek relief. Toxie Waste Impact Group, Inc. v. Leavitt, 890 P.2d 906, 910 (Okla. 194). In the present case, Plaintiffs allege nothing more than an abstract, non-Hohfeldian right to have the laws and non-binding policy statements of the Board of County Commissioners enforced. Petition, | 1-3. They articulate no concrete and substantial injury that either has occurred or will befall them personally in the absence of relief being granted. Petition, ‘| 1-3. Nor does Plaintiff Oklahoma Second Amendment Association allege any facts that establish its standing to sue on behalf of its membership and based upon its purpose. The mere generalized right to have laws enforced as they are written, absent some injury to the plaintiff that is different in kind than that experienced by the general public, is wholly insufficient to give a party standing to seek judicial relief. Farley v, City of Claremore, 465 P.3d 1213, 1242-43 (Okla. 2020); State v. Mothershed, 264 P.3d 1197, 1228 (Okla, 2011). Under these circumstances, Plaintiffs have no standing to seek 14relief in this Court. Absent a plaintiff with a legally protectable interest, this Court has no jurisdiction to reach the merits of the issues presented and grant relief thereon, B. PLAINTIFFS’ PETITION IS DEVOID OF ANY ALLEGATIONS THAT THERE EXISTS A RIPE, JUSTICIABLE CONTROVERSY AS IS NECESSARY TO GIVE THIS COURT SUBJECT MATTER JURISDICTION TO CONSIDER THE REQUEST FOR RELIEF. Plaintiffs’ utter lack of standing, without more, demands dismissal of their Petition for Declaratory Judgment for want of subject matter jurisdiction. Nevertheless, Plaintiffs’ Petition fails to establish the existence of a ripe, justiciable controversy ~ the absence of which deprives this Court of subject matter jurisdiction. Tulsa Indus. Auth. v. City of Tulsa, 270 P.3d 113, 120 (Okla. 2011). “The term ‘justiciable” refers to a lively case or controversy between antagonistic demands.” Id. A justiciable controversy is one which is definite, concrete, and capable of a decision that gives conclusive relief. Richardson v, State, 406 P.3d 571, 573 (Okla, 2017). Where there are no antagonistic demands or the same are merely speculative, there is no actual controversy and a prohibited advisory opinion is being sought. Tulsa Indus. Auth., 270 P.3d at 120. Justiciability that exists only because of a collusive or fraudulent controversy deprives a court of jurisdiction as well, Jd. at 122, ‘Though standing is distinct jurisdictional doctrine, “[a] fundamental component of a judicial controversy is that the plaintiff have actual or imminent injury.” Oklahoma Indep. Petroleum Assoc. v. Potts, 414 P.3d 351, 366 (Okla. 2018). Like standing, ripeness is a separate legal doctrine that is a component of justiciability. Independent Sch. Dist. No. 52 v. Hofmeister, P.3d_,2020 OK 56,461 n.91 As aptly explained by the Supreme Court: The ripeness doctrine is part of judicial policy militating against the decision of abstract or hypothetical questions. The conclusion that an issue is not ripe for adjudication emphasizes a prospective examination of the controversy indicating 1Sthat future events may affect its structure in ways that determine its present justiciability, Subsequent events may sharpen the controversy or remove the need for decision of at least some aspects of the matter. French Petroleum Corp. v. Oklahoma Corp. Comm'n, 805 P.2d 650, 652-53 (Okla. 1991). Plaintifis filed the instant lawsuit before the ink was dry on the non-binding immigration resolution of the Board of County Commissioners. Nowhere do they allege that Defendant Authority has, in fact, refused to follow the law in any respect, In fact, Plaintiffs cannot even identify a policy of Defendant Authority that in any way conflicts with the law. At best, Plaintiffs? Petition is based upon nothing more than speculation that Defendant Authority will not adhere to its legal obligations —a fact which will not be known until confronted with an inmate who, but for the existence of an ICE detainer, is otherwise entitled to be released from custody. Only then will Defendant Authority or even this Court be able to know if there is probable cause to hold a suspected illegal alien for the period of 48 hours requested by any ICE detainer. After all, the Fourth Amendment to the United States generally requires that the existence of probable cause to arrest be determined on an individualized, case-by-case basis before or shortly after the time of arrest. Bailey v. U.S., 568 U.S. 186, 192-93 (2013); Gerstein v. Pugh, 420 U.S. 103, 114-120 (1975). Under these circumstances, Plaintiffs’ Petition does not present a justiciable controversy that is ripe for declaratory relief. PLAINTIFFS SEEK RELIEF THAT VIOLATES NOT ONLY THE SEPARATION OF POWERS OF THE CONSTITUTION BUT WHICH VIOLATES THE FOURTH AMENDMENT IN DIRECT CONTRAVENTION OF LONG-STANDING JURISPRUDENCE OF THE UNITED STATES SUPREME COURT. As demonstrated, this Court lacks subject matter jurisdiction to reach the merits of Plaintiffs’ request for declaratory relief, as the same is non-justiciable for lack of standing, ripeness, and a true adversarial controversy. However, the question presented is also non- justiciable as a political question for which Plaintiffs improperly ask this Court to ignore the 16constitutional separation of powers and intrude upon executive functions while simultaneously attempting to dispense with the Fourth Amendment requirement of individualized probable cause determinations by a court in direct contravention of long-standing authorities of the United States Supreme Court. The Oklahoma Supreme Court has acknowledged that courts should be mindful of respecting the separation of powers of the co-equal Judicial, Executive, and Legislative branches of government by avoiding resolution of purely political questions. Oklahoma Educ. Ass'n v. State, 158 P.3d 1058, 1065 (Okla. 2007). As recognized by the Court: The Oklahoma Constitution at article IV, section 1 states: “The powers of the government of the State of Oklahoma shall be divided into three separate departments: The Legislative, Executive, and Judicial; and except as provided in this Constitution, the Legislative, Executive, and Judicial departments of government shall be separate and distinct, and neither shall exercise the powers properly belonging to either of the others.” This provision prohibits one branch of the government from controlling or subjecting another branch to coercive influences either directly or indirectly. Id. “The term ‘political,’ when used in its classical sense, refers to governing, Political activity relating to governing is reviewable solely by political means. This is so because the U.S. Constitution assigns responsibility for political activity to the political branches of government ~ to the legislative or executive department. ‘The answer to a political question is impervious to judicial re-examination.” In re De-Annexation of Certain Real Property, 102 P.3d 120, 126 (Okla. 2004), Plaintiffs ask this Court to affirmatively declare that, in all cases, the existence of an ICE detainer, without more, amounts to probable cause authorizing the detention of an alien who would otherwise be entitled to release from confinement. Coupled with their request for this Court to declare the Board of County Commissioners’ policy statement to be binding upon a separate and independent political subdivision, Plaintiffs seck to remove from Defendant Authority all 7discretionary executive power to act in their own right in the performance of their duties. However, the power of the judiciary may not constitutionally be used to coerce the executive branch in the performance of its daily operations in this manner. As Plaintiffs’ request for relief presents a purely political question, separation of powers precludes it from being granted. More than violating the separation of powers doctrine, Plaintiffs request this Court to enter an order that violates long-standing Fourth Amendment authorities from the United States Supreme Court. Of course, this Court is well aware that the Fourth Amendment protects against unreasonable searches and seizures. U.S. Const. amend. IV; Terry v. Ohio, 392 U.S. 1, 9 (1968). So too does the Oklahoma Constitution. Okla. Const. art. II, §30. “The Fourth Amendment applies to all seizures of the person, including seizures that involve only a brief detention short of traditional arrest. Whenever a police officer accosts an individual and restrains his freedom to walk away, he has ‘s ized’ that person, and the Fourth Amendment requires that the seizure be “reasonable.” United States v. Brignoni-Ponce, 422 U.S. 873, 878 (1975)(citations omitted) It is well established that a seizure that is lawful at its inception may, nonetheless, become unlawful if its manner of execution unreasonably infringes upon the individual’s constitutional rights. Illinois v. Caballes, 543 U.S. 405, 407 (2005). Thus, the mere fact that the Detention Center may have lawful custody of an alien does not preclude the custody from becoming unlawful based upon subsequent events. For brief encounters, a seizure is reasonable if it is based upon reasonable suspicion that criminal activity may be afoot, however, arrests and detention require probable cause. Terry, 392 U.S. at 22-23; see also Brignoni-Ponce, 422 U.S. at 880-81 (holding that border patrol officers may stop vehicles near the board to briefly question the occupants only if they have reasonable suspicion to believe that the occupants are aliens and noting that further detention requires probable cause); Manzanares v. Higdon, 575 F.3d 1135, 1148 (10 Cir, 182009)( distinguishing brief detentions which only require reasonable suspicion from circumstances tantamount to an arrest and detention requiring probable cause), The Supreme Court has defined “probable cause” as “facts and circumstances sufficient to warrant a prudent man in believing that the [individual] had committed or was committing an offense.” Beck v. Ohio, 379 U.S. 89, 91 (1964). As a general rule, however, the determination of the existence of probable cause must be made by a magistrate on an individualized, case-by-case basis either before an arrest — through issuance of an arrest warrant — or shortly after the time of arrest. Bailey v, U.S., 568 U.S. 186, 192-93 (2013); Gerstein v. Pugh, 420 U.S. 103, 114-120 (1975). In fact, absent limited exceptions not relevant here, the Fourth Amendment requires this determination to be made prior to an arrest through issuance of a warrant. U.S. v. U.S. Dist. Court, 407 U.S. 279, 317-18 (1972). That law enforcement or prosecutorial officers believe there to be probable cause can never substitute for a magistrate’s individualized and independent assessment of the evidence to justify detention. Gerstein, 420 U.S. at 116-117; Shadwick v. City of Tampa, 407 U.S. 325, 350 (1972). As aptly explained by the Supreme Court, “This Court has long insisted that inferences of probable cause be drawn by a neutral and detached magistrate instead of being judged by the officer engaged in the often competitive enterprise of ferreting out crime.” Shadwick, 407 U.S. at 350. “The Fourth Amendment does not contemplate the executive officers of Government as neutral and disinterested magistrates. Their duty and responsibility are to enforce the laws, to investigate, and to prosecute.” U.S. v. U.S. Dist. Court, 407 U.S. 279, 317 (1972). “Whatever else neutrality and detachment might entail, it is clear that they require severance and disengagement from activities of law enforcement.” Shadwick, 407 U.S. at 350. Here, Plaintiffs asks this Court to declare that the issuance of an ICE detainer is sufficient, without more, to establish probable cause in all cases. Of course, an ICE detainer is not the same 19as an administrative warrant. Pursuant to Section 1226 of the Immigration and Nationality Act, “an alien may be arrested and detained” while awaiting a removal decision, but the arrest must be pursuant to “a warrant issued by the Attorney General.” 8 U.S.C. § 1226(a). On the other hand, a detainer is defined by Section 287.7 which states: Any authorized immigration officer may at any time issue a Form 1-247, Immigration Detainer — Notice of Action, to any other Federal, State, or local law enforcement agency. A detainer serves to advise another law enforcement agency that the Department secks custody of an alien presently in the custody of that agency, for the purpose of arresting and removing the alien, The detainer is a request that such agency advise the Department, prior to release of the alien, in order for the Department to arrange to assume custody, in situations when gaining immediate physical custody is either impracticable or impossible. 8 CER. § 287.7(a)(emphasis added). The distinction between a detainer and an administrative warrant has consistently been recognized by courts. See e.g., Galaviz-Medina v. Wooten, 27 F.3d 487, 493 (10" Cir. 1994); Nasious v. Two Unknown B.LC.E. Agents, 366 Fed.Appx. 894, 896 (10 Cir. 2010); Galarza v. Szalezyk, 745 F.3d 634, 636-40 (3" Cir. 2014); see also Exhibit 2, Detainer Form 1-247 (stating that the detainer should not impact decisions about an alien’s release). In this, light, Plaintiffs request this Court to enter an order that dispenses with individualized probable cause determinations by a neutral magistrate and, instead, allows an ICE detainer issued by a federal law enforcement officer to stand in its place in all circumstances. Yet, for nearly fifty years the United States Supreme Court has expressly rejected this very position as violating the protections of the Fourth Amendment. Because Plaintiffs’ request for declaratory relief presents a non-justiciable political question and otherwise seeks relief that affirmatively violates the Fourth ‘Amendment, the same must be denied. CONCLUSION WHEREFORE, David W. Prater, District Attormey of Oklahoma County, respectfully prays that this Honorable Court will grant the instant Motion to Dismiss in all respects. 20Respectfully submitted, DAVID W. PRATER DISTRICT ATTORNEY 320 Robert S. Kerr, Suite 500 Oklahoma City, OK 73102 Phone: (405) 713-1600 Fax: (405) 235-1567 david prater@oklahomacounty.org CERTIFICATE OF MAILING This is to certify that a true and correct copy of the above and foregoing document was served on the followin; Kevin Calvey PO Box 20443 Oklahoma City, OK 73156 Attorney for Petitioners Robert McCampbell Paula M. Williams Brennan Barger Gable Gotwals 211 North Robinson Oklahoma City, OK 73102 Attorneys for Defendant, Oklahoma County Criminal Justice Authority < fe Lh) 2171472019 11:51 an ‘ox.awona secrerany oF starz FILED - Oklahoma Secretary of State #5012760636 06/14/2019 . . ne 118. SUH 107824315 ARQUINOTERNL ou oa CREATING THE Cia ida, Cy, OKLAHOMA COUNTY CRIMINAL JUSTICE AUTHO! “ad KNOW ALL MEN BY THESE PRESENTS: This Trust Indenture dated as of the 22 day of May, 2019, by Kevin Calvéy, acting 28 (Chaisman of the Oklahoma County Commissioners and the trustor hereof and hercinafter refered to as the Trustor, and P-D. Taylor, as Sheriff of Oklahoma County (or his designee), Kevin Calvey, as ‘Couny Commissioner of Oklahoma County (or hivher designee), Frances C. Ekwerelcw, a8 the appointee ofthe Distict One County Corumissioner, Ben Brown, asthe appointee ofthe District’ ‘County Commissioner, Todd Lamb, as the appointee of the District Three County Commissioner, ‘M.T. Bey, im Couch, Tricia Everest, Sue Ann Amall, each es Commission Appointed Trlees 2s ‘provided for herein, and thelr respective muecessors a3 provided herein, who shall be and are ‘hereinafter refered to a6 Trustees of the Oklshome County Criminal Justice Authority, hereinafter referred to as “Awiborty” or “Trust” hereby creates and establishes a public trust for the use and benefit of Oklahoma County, Okshoma (he “Beneficiary”) pursuant to the tems of Okla. Stas. Tit. 60, §176 ef seq. #8 amended, and prescribes the terms thereof a follows: NOW, THEREFORE, in consideration ofthe payment by the Trustor tothe Trustees of the ‘sum of Ten Dollars ($10.00), receipt of which is hereby acknowledged, the rmutual eovenants herein set forth, and othet Valuable considerations, the said Trustees agres to hold, manage, invest, assiga, ‘convey and distribute as herein provided, mthorized and directed, auch property aa Trantor, or others ‘may Reretofore or ftom time to tris hereafter assign transfer, lease, convey, give, bequeath, devise or deliver unto this Trust or the Trustees kereof, ‘TO HAVEAND FOLD such property and the proceeds, rents, profits, and increases thereon, ‘unto said Trustees and said Trustees’ successora and assigns, but nevertheless in trust, forthe use and ‘benefit ofthe County of Oklahoms, State of Oklahoma, such County being hereby designated as the “Beneficiary” and upon the truss, terms and conditions hereinafter stated. ARTICLEL (Creation of Trust The undenigned Trustor creates and establishes a Trust for the use and benefit of the Reneficiary for the public punposes hereinafier set forth under th provisions of Okie, Stata, Tit. 60, § 176 ¢1 seq, as sinended and supplemented, the Oklahoma Trust Act and other applicable statutes and laws ofthe Site of Oklahoma, ‘The undersigned Trustor hereby conveys and assigns to the Trustees of te Authority any and allright ttle and interest he may have in and under this Trust Indenture and the trust ereatedhereunder, including, without liraitetion, the right to consent to and approve any further changes, ‘amendments or supplements to this Trust Indenture, ARTICLE IL ‘Name and Effective Date of Trust ‘The Trustees of this Trust shall conduct all business and execute or authorize the execution of all instruments in the name of this Trust, which shall be the “Oklahoma County Criminal Justice Authority” and otherwise perform the duties and functions required in the exccution ofthis Trust, and ‘hereby authorize the Chair or Vice Chair and the Secretary or Assistant Secretary of the Trust to execute instruments on behalf of the Trust as directed by duly enacted resolutions of the Trust. This ‘Trust Indenture shall be in full force and effect ftom and after the dete of execution by the Trustees of the Trust and acceptance of the benefici! interest herein by tho Beneficiary. ARTICLE I Definitions “Act” shall mean the Oklahoma Public Trust Act, being Okla. Stats. Tit. 60, § 176 ef seq., as amended and supplemented, “Authority” or “Trust” shall mean the “Oklahoma County Criminal Justice Authority" created pursuant to this"Trust Indenture, and the Trustees thereof, acting on behalf of and in the name of said ‘Authority. “Beneficiary” shall mean the County of Oklahoma, State of Oklahoma, acting by and through its Board of County Commissioners, “Bonds” or “Notes” shall mean respectively the bonds and notes or other obligations of the Authority, ‘ “By-Laws” shall mean the By-Laws, if any, duly adopted by the Authority as the same may bbe amended from time to time, “Governmental Agency” shall mean the United States of America and the State or any depertment, division, public corporation, public agency, political subdivision or other public ‘instrumentality of either, “Indenture” or “Trust Indenture” shall mean this Trust Indenture as amended and supplemented from time to time. “Jail Facilities" shall mean only enterprises or facilities relating to, in support of or operated in conjunction with jail, prison, correctional, detention, rehabilitation, mental health, addiction, 2diversion, justice, and related facilites, all as collectively described in Article IV of this Indenture (and as specifically limited therein). “Lending Institution” shall mean any bank or trust company, Federal National Mortgage Association, mortgage banker, mortgage company, rational banking association, savings bank, savings and loan association and any other financial institution or Goveramental Agency or person. “Oath of Office” shall collectively mean any such oath(s) of office, loyalty oath(s), or similar ‘qualifications as may be required of elected or appointed public officials from time to time by applicable law, “State” shall mean the State of Oklahoma, “Trustees” shall mean the Trustees of the Authority, ARTICLE IV Purposes of Authority ‘The purposes of this Authority pertain to Jail Facilities exclusively, as more specifically set forth herein: oO ‘Toassist the Beneficiary, the State of Oklahoma, Govermmental Agencies, municipalities and private entities, agencies and citizens in making the most efficient use ofall oftheir economic resources and powers in accord with the needs and benefit of the State of Oklahoma and the [Beneficiary in order to lessen the burdens on goverment and to insure the safety and security of the citizens theteof, specifically including, but not limited to, the power to conduct studies and prepare comprehensive plans relating to the Beneficiry’s criminal justice and administration facilities, comections and detention facilities and the resources of the ‘Beneficiary, toown, operate and manage ails, prisons, corectional, detention, rehabililation, ‘mental health, addiction, diversion, justice and related facilities (Le, the “ail Facilites"); and ‘0 otherwise promote the general welfare of the Citizens of the Beneficiary and to finance any and all programs end faciltics and develop resources fo pay for the foregoing and, without ‘estriction, in furtherance of the foregoing general objectives, the following specific powers (or purposes, to wit: @ —_Topromote, operate, finance and develop Jail Facilities for the temporary or longer term detention or incarceration of adult or appropriate youthful offender males and females, together with related facilities of any type or description including, but not limited ‘to, those for administration, criminal justice, medical, social services, recreational facilities, food handling, inmate housing end other enterprises or facilities relating to, in support of or operated in conjunction with said Jail Facilities as described herein, (©) Topromote, operate, finance and develop rehabilitation, addiction, mental heath, end other diversion services, projects or facilites relating to the operation of a Jail 3@ ® Facilities of any sort or description inchiding, but not limited to, any land or personal property related thereto. (©) Topromote, operate, develop and finance projects or facilities relating to Jail Facilites, ‘of any sort or description including, but not limited to, any Land or personal property related thereto. : (© —Topromote, operate, finance and develop commercial and other projects or facilities, ‘elated to Jail Feclities and to exercise all of the powers, privileges and prerogatives of county public trusts within this State, (© To administer finds for the purpose of acquiring a site(s) for Jail Facilities, for the ‘temporary or longer-term detention or incarceration of adults or appropriate youthful offenders and any related fa ities, © To plan, establish, develop, construc, finance, enlarge, remodel, acquire, improve, alter, extend, maintain, equip, operate, lease, furnish and regulate any fecilities related to any of the foregoing end, if desired, to lease such facilities and to oporate the same ‘in connection therewith and to do, perform, own, sequire, construct or engage in or inance any ofher enterprise or activity, projec or facility to such extent and in such ‘manner as now is or may be considered a proper and lawful fimetion of public trust ‘entities within the State of Oklahoma. © The Authority will not perform on behalf of the Beneficiary any duties that are specifically and exclusively reserved by existing law to a sheriff, jailer, underheriff, or deputy sheriff furthermore, the Authority will not perform on behalf ofthe Beneficiary any duties that relats to any other County Officer's office, cor to the fimetions, duties, responsibilities or funding thereof. ‘Tohold, maintain and administer any leasehold rights in and to physical properties heretofore ‘or hereafter demised to the Beneficiary or the Authority and to comply with the terms end conditions of any such lease, ‘To acquire by lease, purchase, production, reduction to possession or otherwise, and to plan, establish, develop, construct, enlarge, improve, extend, maintain, equip, opemte, fumish, provide, supply, regulats, hold, store and administer any and all physical propertics (real, personal or mixed), rights, privileges, immunities, benefits and any other thing of velue, designated or needful for utilization in furnishing, providing or supplying the aforementioned services, utilities, buildings and facilities; to finance and refinance and to enter info contracts of purchase, lease-purchase or other interest in or operation and maintenance of said properties, and revenues thereof, and to comply with the terms and conditions of any such contracts, leases or other contracts entered into fn connection with the acquisition, equipping, ‘maintenance and disposel of any of said property; and to retinquish, dispose of, rent or ‘otherwise make provisions for properties owned or controlled by the Authority, butmo longer needful fr trust purposes. ‘To acquire, construct, reconstruct, extend, lease, purchase, install, equip, maintain, repair, enlarge, remodel and operate any property, improvements, buildings and other facilities of 4© Beneficiary, or for use by authorities, counties, municipalities, agencies ofthe State of Oklahoma, the United States of America or the Beneficiary or forthe use of corporations, individual, partnerships, associations or proprietary companies; to plan, ‘establish, develop, construct, enlarge, maintain, equip, operate, lease, furnish, provide, supply, regulate, hold, store and administer property, buildings, improvements and facilities of every nature, within the temitorial boundaries of the Beneficiary which may be useful in securing, developing and maintaining such facilites, fimetions or activities, ‘To provide funds for the cost of financing, refinancing, acquiring, constructing, purchasing, equipping, maintzining, leasing, repairing, improving, extending, enlarging, remodeling, holding, storing, operating and administering any or all aforesaid property, improvements, buildings, facilities and all properties (real, personal or mixed) necessary or desirable for ‘executing and fulfilling the Authority's purposes, as set forth in tis instrament, and all other charges, costs and expenses necessarily incurred in connection therewith and in go doing, to ‘incur indebtedness, ether unsecured or secured by all or any part of the Trust Estate and its reverues. ‘To pledge and expend all funds coming into the hands of the Trustees as revere or otherwise, ‘including lease payments or other fimds provided to the Trustees by the Beneficiary for the ‘payment of any indebtedness incurred by the Trustees forthe puxposes specified herein, and in the payment of the aforesaid costs and expenses, and in payment of any other obligation properly chargeable against the ‘Trust Estate, end to distribute the residue and remainder of such finds to the Beneficiary, Specifically excepted and not a part ofthe Purposes of this Authority are the following: (@ The Oklahoma County Courthouse holding/detention facilities and the Oklaboma County Juvenile Justice Center holding/detention facilites. (©) The detention of any inmates or persons held in the Oklahoma County Courthouse holding/detention facilities and the Oklahoma County Juvenile Justice Center holding/detontion facilities who are subject to a Temporary Confinement Order of ‘a Judge of the District Court. (©) Security ofthe Oklahoma County Courthouse or Oklahoma County Juvenile Justice Center for the judges and staff and the public, (© The implementation, operations and transportation of any inmates'or others in custody or in temporery confinement to end fom the Oklahoma County Courthouse or Oklahoma County Juvenile Justice Center.as its purposes shall have been fully fulfilled and all indebtedness ofthe Authority is paid, or unt ARTICLEV Duration of Trust ‘This Trust shall have duration forthe term of duration of the Beneficiary and until such tiie ‘hall be terminated as hereinafter provided. Qo @ 8 ARTICLE VI ‘The Trust Estate ‘The Trust Estate shall consist of: (©The finds and property presently in the hands of the Trustees or to be hereafter acquired or constructed by the Trustees and dedicated by the Trustor, the Beneficiary and others to be used for trust purposes. (©) Any and all leaschold rights heretofore or hereafter remised to the Trustees by the ‘Beneficiary, and others as authorized and empowered by law. (©) Any andl] money, papery (es esol or mixed) sighs, choses inaction, ‘contracts, leases, privileges, immunities, licenses, franchises, benefits, mortgages, ‘mortgage loans, collateral and all ther things of value heretofore orhefeafer coming into the hands of the Trustees under this Trust Indenture, (@) Cash in the sum of $10.00 paid by the Trustor to the Trustees, rectipt of which is hereby specifically acknowledged by the Trustess. ‘The Trust Estate shall under no circumstances consist or be deemed to consist of: @ The Oklahoma County Courthouse or its holding/detention areas or facilites, (©) The Oklahoma County Juvenile Justice Center or its holding/detention arcas or facilities, Funding for the Trust fiom a general fund appropriation shall be determined solely by the Oklahoma County Budget Board. The Budget Board's determination as to the adequate ‘general find appropriation to fund the Trust shall be final, Inthe event ofthe dissolution of ‘the Budget Board, the Board of County Coramissioners shall actin the capacity ofthe Budget Board described herein.qa) ARTICLE Vil ‘The Trustees ‘The Trustees of this Authority shall be nine in number. One of the Trustecs shall be @ member of the Board of County Commissioners of the Beneficiary, or their designee pursuant to Article VII(13) hereof, ss chosen by the Board of County Commissioners ofthe Beneficiary (the “Commissioner Trustee"), One of the memibers shall be the County Sheriff of the Beneficiary, or their designee pursuant to Article VI(13) hereof (the “Sheriff Trustes” and collectively withthe Commissioner Trustee the “Elected Official Trustees"). The Elected ‘Official Trustees shall serve terms coterminous with their then current terms as elected officials. Any successor to the office of Oklahoma County Sheriff (including en official setving in an interim or acting capacity) shall, upon taking the applicable Oath of Office, but ‘without any further act, deed or conveyance, automatically become a Trustee ofthis Authority and become fully vested with all the estate, properties, rights, powers, duties and obligations of their predecessor hereunder with like effect as if orginally named as a Trustec herein. One ‘Trustee shall be appointed by the District One County Commissioner (the District One Appointee"), one Trustee shall be appointed by the District Two County Commissioner (the District Two Appointee"), and one Trustee shall be appointed by the District Three County Commissioner (the Distriet Three Appointee” and collectively with the District One Appointee and the District Two Appointee the “District Appointed Trustees”). ‘The. District Appointed Trustees shall serve terms of six years, shall be Citizens of the Beneficiary, and shall not be an elected official. Each of the District Appointed Trustees shall be confimmed by the Board of County Commissioners, and shall serve inital terms staggered as follows: the appointees of County Commissioner District One and District ‘Three shall serve initial terms of two (2) years, respectively, and the appointee for County ‘Commissioner District Two shall serve an initia term of six (6) years. Upon expiration of ‘District Appointed Truste’s term, that appointee or a successor shall be appointed for a term of six years. Upon resignation, death, or removal of a District Appointed Trustee, a ‘successor shall be eppointed forthe remsining portion ofthe unexpired six-yearterm, Each successor District Appointed Trustee shall be selected in the manner provided hereinabove and shall, upon taking the applicable Oath of Office, but without any further act, deed or conveyance, automatically become a Thistec ofthis Authority and become fully vested with all the estate, properties, rights, powers, duties and obligations of his predecessor hereunder ‘with like effect as if originally named asa Trustec herein. Four Trustees (the “Commission Appointed Trustees”) shall serve terms of six (6) yeats and stall bo Citizens of the Beneficiary, and shall not be an elected official, and whom shall be chosen by a majority vote of the Board of County Commissioners, and shell serve inital terms of four (4) years. Upon expiration of a Commission Appointed Trustee's term, that appointes or a successor shall be appointed for a new term of six (6) years. Upon resignation death, or removal ofa ‘Conunission Appointed Truste, a successor shall be appointed for the remaining portion of the unexpired term of the resigning Trustee. Each successor Commission-Appointed ‘Trustee shall be selected in the manner provided hereinabove and shall, upon taking the applicable Oath of Office, but without any further act, deed or conveyance, sutomatically ‘become Trustees of this Authority and become fully vested with all the estate, properties, rights, powers, duties and obligations of his predecessor hereunder with like effect as if originally named es a Trustec herein. Trustecs shall continu to serve until a successor has 7® @) @) © © been appointed and has the taken the applicable Oath of Office. Any District Appointed ‘Trustee or Commission Appointed Trustee may be removed for cause (for a reason set forth in Oka, Stat, Tit, 22 Sec. 1181 or successor statute pertaining to the removal of officers) from office upon a unanimous vote of all three County Commissioners, after a public hearing ‘held before the Board of County Commissioners not less than ten (10) days following written notice to said Trustee, at which public hearin seid Trustce shall have the opportunity to be heard. The initial nine Trustees shall be those nine persons executing this Trust Indenture, Jn addition to other removal methods mentioned herein, inthe event any ‘Trustee () misses more than one half of the Trst’s meetings (regular or special) in any calendar year (or in the case of a Trustee appointed during any celendar year, computed from the date on which he or she is qualified as a Trustee in accordance with this Indenture); or (ji) is convicted, pleads uilty to, or receives a deferred sentence in a cour of law fora felony; or (ji) remaves his or het residence from Oklehoma County; atid Trustee shall be immediately removed from service and a successor shall be appointed as provided herein. In the case of conviction, plea of guilty o, or receipt a deferred sentence, the position of Trustce shall be vacant as of the date of said disposition of the case, disregarding any subsequent appeal thereof to a higher court. ‘The Chair of the Trustees, who shall not be an elected official, shall be selected by 2 jority of the Trustees and shall preside at all meetings and perform other duties designated by the Trustees. The Trustees shall designate the time and place of all regular meetings. All actions by the Trustees pursuant to the provisions of this Trust Indenfure shall be approved by the affirmative vote of at least a majority of the Trustees qualified to act as such under the provisions of this Trust Indenture, The Trustees may select one of ‘heir members to be Vice-Chairman, who shall not be an elected official, who shall at in the place of the Chair during the latter's absence or incapacity to act, ‘The County Clerk of Oklahoma County, Oklabora, shall be the Seoretary of the Trustees. ‘The Scoretary shall keep minutes of all meetings of the Trustees and shall maintain ‘complete and accurate records of all their financial transactions, all such minutes, books and records to be on file in the office of the Authority. All mectings of the Trustees, their ‘committees, subcommittees, and advisory committees shall be subject to the Oklahoma Open Meeting Law, and the books, records and minutes of the Trustees, their committees, subcommittees, and advisory committees shall be subject to the Open Records Act. The ‘Trustees may appoint individuals, who may or may not be Trustees, fo serve as Assistant Seeretary(ics) of the Trustees, ‘The Oklahoma County Treasurer shall be the Treasurer of the Trustees. ‘The duties of the ‘Treasurer shall be prescribed by the Trustees, ‘The Trustees may, but shall not be required to, appoint a general manager and/or executive director for the Trust Estate, and the Trustees may employ such other clerical, professional, legal and technical assistance as may be deemed necessary in the discretion of the Trustees to properly operate the business of the Trust, and may fix thoi duties, terms of employment and compensstion from the Trust Estate. A Trustees shall serve without compensation, ‘but shall be reimbursed for actusl expenses incurred in the performance of their duties‘hereunder. In the event a general manager and/or executive director forthe Trust Estat ig appointed by the Trustees, the said general manager and/or executive director shall administer the business of the Trust Estate as ditected from time to time by the Trustees, (D) The Trustees are authorized to contract, in connection withthe incurrence of any funded indebtedness secured by the Trust Estate and/or its revenues, or any part of either or both, that in the event of default inthe fulfillment of any contractual obligation undertaken on behalf of the Trust Estate or in the payment of any indebtedness incurred on behalf of the ‘Trust Estate, that a Temporary Trustee or Trustees or Receiver shall be appointed to succeed to the rights, powers and duties ofthe Trustees then in office. Any such contract, if made, may set forth the terms and conditions under which such Temporary Trustee of ‘Trustees or Receiver tay be appointed to operate the Trust Estate and may provide for compensation to be paid, and may provide for such appointment to be vacated and permanent Trustees to be sntomatically reinstated upon termination ofall defaults by which ‘heir appointment was authorized. (8) Bonds or other evidences of indebtedness to be issued by the Trustees shall not constitute an indebtedness or obligation of the State or the Beneficiary nor personal obligations of the ‘Trustocs, but shall constitute obligations of the Authority only, payable solely from the ‘Trust Estate. (©) The Trustees, the State, and the Beneficiary shall not be charged personally with any liability whatsoever by reason of any act or omission committed or suffered in good faith or in the exercise of their honest discretion in the performance of such Trust or in the operation of the Trust Estate; but any actor liability for any omission or obligation of the ‘Trustees in the execution of such Trust, ot in the operation of the Trust Estate, shall extend to the whole of the Trust Estate or 6o much thereof as may be necessary to discharge such liability or obligation. (10) Notwithstanding any other provision of this Indenture which shall appear to provide otherwise, no Trustee or Trustees shall have the power or authority to bind or obligate any other Trustee, or the Beneficiary, in his or its capacity, nor can the Beneficiary bind or obligate the Trust or any individual Trustee. (21) The Authority shall cause to be prepared annually at the close of exch fiscal year of the Authority an audit of the funds, financial affairs and transactions of the Authority including, but not limited to, all fees, salaries and expenditures in exact amounts and specifying to whom such expenditures were paid. ‘Such audit is to be certified with an opinion of an independent, certified public accountant. A copy of the annual audit of the Authority shall be filed within the time period and in conformity with the provisions of Oklahoma law selated thereto. Unless hereafter changed by specific resolution of the ‘Trustees, the fiscal year ofthe Trust shall be July 1 to June 30 of the following year. All expense incurred in connection with the annual audits shall be paid fiom the Trust Estate. (12) Bvery person becoming a Trustee shal ist fake the applicable Oath of Office required by {aww of an elected or appointed public officer. The Oath of Office shell be administered by any person authorized to administer oaths in the State, and shal be filed with the Clerk of 93) the Beneficiary. All Trustecs shall at all times comply with the conflict of intrest provisions of Okla. Stat, Tit, 60 Sec. 178.8 (or successor statute thereto), provided ‘however, the making of any loan or advance of any fds to the Trust, or the purchase of any obligations issued by the Trust, in connection with the performance of eny authorized purpose of the Trust, shall not be considered exempt from the provisions of Ota Stat. Tit. 60 Sec. 178.8 (or successor statute thereto), and provided further, any required lists of conflicts of interest to be filed withthe Secretary of State shall also be filed with the Clerk of the Beneficiary. Every officer and employes who handles funds of the Trust shall furnish a good and sufficient fidelity bond in an amount and with surety as may be specified and approved by the Trustees; the Trustees may, but shal not be obligated to, obtain bonds relating to the performance of their duties as Trustees. Such bonds shall be in a surety company authorized to transact surety business in the State and the cost thereof shall be paid fron the Trust Estate, In the absence of an Elected Official Trustee from a meeting of the Trust or otherwise according to Okla. Stat. Tit, 19 See. 180,81, a8 amended and supplemented and other applicable statutes of the State presently in force and effect, the Elected Official Trustee's ‘Chief Deputy or Undersherif, or other County employee 20 designated of record with the ‘County Clerk of the Beneficiary by that Elected Official Trustee, shall kave authority to ‘actas Trustee. ARTICLE VII. Powers and Duties of the Trustees ‘To accomplish the purposes of the Authority, the Trustees shall have, in addition to the usual powers incident to their office and the powers granted to them otherwise by law or in ofher ports of| this Trust Indenture, including but not limited to the powers and duties provided for in the Act, inchiding the following rights, powers, duties, authority, discretion and privileges all to be exercised on behalf of and inthe name of the Authority: Q) @ @) @ ‘Tosue and be sued. ‘Tohave a seal and alter same at pleasure. To make and execute contracts and all other instruments necessary or convenient for the exercise ofits powers and functions hereunder, To make and alter by-laws for its obligations end internal management as provided herein, and to establish committees, subcommitices imd/or advisory committees as deemed reasonable and prudent and make appointments of individuals thereto. In addition to eny committees, subcommittees and/or advisory committees the Trust may establish, the Trust shall establish 2 Citizens Advisory Board, The Citizens Advisory Board will act in an advisory role to assist the Trust with regards to community relations and best practices in all aspects of the Trust's functions. The Citizens Advisory Board shall be representative ofthe 10o © o community at-large. The Trust will work with the United States Department of Justice's (Community Relations Services Division to establish the Citizens Advisory Board. ‘Tomake and alterrules and regulations pertaining to any loan or other program developed by ‘he Authority. ‘To acquire, lease, convey, oF otherwise hold and dispose of real and personal property for is ‘Trust purposes; provided thet, no purchaser at any sale or lessee under a lease made by the ‘Trustees shall be bound fo inquire into the expediency, propriety, validity or necessity ofsuch sale or ease orto see or be liable forthe application of the purchase or rental monies azising therefrom, ‘To enter into contracts for sale of Bonds, Notes or other evidences of indebtedness, interim Notes or Bonds or other obligations of the Trust and to issue the same for any of the purposes of the Trust authorized hereby including, but not limited to: the acquisition, construction, reconstruction, equipping or otherwise financing facilities discussed in Article TV hereof or for any other lawfully permitted facilites which may be secured with mortgages, security interests oF other collateral satisfactory tothe Trustees; acquiring real or personal property or facilites at foreclosure of any loan or obligation or authorized to be acquired pursuant tothe terms ofthis Trust Indenture or other purposes authorized under any instrument securing any indcbtedness of the Authority; refunding or advance refunding sny outstanding indebtedness of the Authority; creating any reserves or replacement finds, loan funds or other funds or secounts deemed advisable by the Trustees inthe furtherance ofthe Authority purposes or in conection with the securing of any of the Authority's debts or in the adrainistration of Authority programs; and for any other purpose authorized by law and/or by Article IV hereof, ‘and for those purposes the Trustees may: (@) Sell all Bonds, Notes or other evidences of indebtedness or obligations of the ‘Authority at public or private sale in whole or in installments or series and on such ‘terms and conditions and in auch manner as is prescribed by law and as the Trustees shell deem to be in the best interest of the Trust Estate; and (©) Appoint and compensate attomeys, paying agencies and corporate trustees in connection with the issuance of any such Bonds, Notes, evidences of indebtedness or other obligations ofthe Authority, and (© Pay all expenses incident to the reation of any indebtedness or the issuance of any Bonds, Notes or other evidences of indebtedness including, but not limited to, printing expenses, feasibility studies, speciel consultants, travel cxpensea or reproduction expenses; and (@ Create any reserve fimd and any and all other funds and accounts as the Authority shall deern necessary or desirable in connection with the issuance of any Bonds, Notes or ofher evidences of indebtedness. Any such indebtedness shall be deemed tobe incurred or issued on behalf of the Beneficiary ‘and may be general or special obligations of the Authority as the Trustoes may from time to time determine; provided however, such obligations shall not constitute an indebtedness or uobligation of the State or the Beneficiary nor personal obligations of the Trustees, but shall constitute obligations of the Authority only, payable solely from the Trust Estate. (8) To purchase or redeem their Bonds, Notes or other evidences of indebtedness in whole or in. pnt prior to the stated maturity thereof as specified in sn instrument authorizing the issuance or securing the payment of any such indebtedness. (9) To pledge any or all of the Trust's revenues of assets to secure the payment of any of its indebtedness. (10) Toenter into agreements with or participate in any programs of the Beneficiary, the State of Oklahoma, or any agency ot instrumentality thereof, the United States of Americ, or any agency or instrumentality thereof. (11) To enter into and execute, purchase, lease or otherwise acquire property, real, personal or mixed, contacts, leases, rights, privileges, benefits, choses in action or other things of value ‘and to pay forthe same in cash, with bonds ot other evidences of indebtedness or otherwise. (12) To fix, demand and collect charges, rentals and fees for the services and facilites of the ‘Authority and to discontinue the furnishing of services and facilites to, and foreclose on any collateral of, any person, firm, or corporation, or public instrumentality delinquent in the payment of any indebtedness tothe Authority; to purchase and sell such supplies, goods and ‘commodities as are incident tothe operation ofits propertis. (&3) To make and perform contracts of every kind including, management contracts, with any’ ‘person, firm, corporation, association, joint venture, truseeship, municipality, government, sovereignty or other entity; and without limitation as to amount, 1o draw, make, accept, cendonse, assume, guarantee, account, executc and issue promissory notes, draft, bills of exchange, acceptances, warranties, bonds, debenture and other negotiable or non-negotiable instruments obligations and evidences of unsecured indebtedness, or of indebtedness secured by mortgage, deed of trust or otherwise upon any or all income of the Authority, inthe same ‘manner and to the same extent as a natural person might or could do. ‘To collect and receive ‘ay property, collateral, money, rents, of income of any sort and distribute the same or any portion thereof forthe furtherance of the authorized Authority purposes set out herein. (14) To exercise oto request of, arrange or contract with the Beneficiary or any governmental unit, ageacy or political subdivision thereof forthe exercise of the power of eminent domain as necessary in establishing, operating, administering and maintaining any Authority fecilties, systems, projects or programs. (15) To expend all funds coming into the hands of the Trustees as revenue or otherwise for the paymerit of any indebtedness incured by the Trustee for purposes specified herein, and in ‘he payment of the aforesaid costs end expenses, and in payment of any other obligation properly chargeable egainst the Trust Estat, to from time to time transfer any surplus funds to the Beneficiary as the Authority in its sole discretion may determine end, upon termination ‘of the Authority, to distribute the residue and remainder of such funds to the Beneficiary, 2a9 ay ag, a9) (20) en 2) @3) (24) To contract for services with firms or persons or other units and entities of government or private entities or agencies to carry out the purposes of the Trust; to apply for, contmct for, receive and expend for its purposes, finds or grants fiom sny governmental or non ‘Rovernmental agency or entity, the Benoficiry, the State, the Federal Government or any agency or department thereof, or from any other source. ‘To receive funds, money, property, collatéral, services, rights and choses in ection from any source to Finance the programs and operations of the Trust; to receive gran, gifts, ‘contributions end donations to carry out the purposes for which the Trust is formed; to receive ‘and accept from any Federal, State or private agencics or enttics, grants or loans for or in wid ‘of the construction of any facility or system and to receive and accept aid or contributions of money, Iabor or any ofher valuable things from any source. ‘To plan, coordinate, implement, administer or otherwise carry out public works or other projects or programs for public purposes for the benefit of the Beneficiary. To invest monies of the Authority not required for immediate use, including proceeds from the sale of eny Bonds or Note, in accordance with the laws of the State, ‘Torenogotiate, refinance ot foreclose, ot contract for the foreclosure of eny mortgage, security interest or other obligation in default; o waive any default or consent to the modification of ‘the terms of any mortgage; to commence any action to protector enforce any right conferred ‘upon itby any law, mortgage, security interest, contract or other agreement, and to bid for and purchase such property at any foreclosure or at any other sale, or écquire or take possession of-any such property; to operate, manage, rehablltete, imprave, lease, dispose of, and ‘otherwise deal with such property, in such mmanner as may be necessary to protect the interests of the Authority and the holders ofits Bonds, Notes or other obligations. To renegotiate or refinance uny loan in default; waive any defeult or consent to the ‘modification ofthe terms of any loan, and commence any action or proceedings to protect or enforce any tight conferred upon itby law, loan agreement, contract or other agreement. * ‘To make and execute contracts and appoint agents for the administration or servicing of any Jan mace or acquired by the Authority and pay the reasonable value of services rendered to the Authority pursuant to such contracts, ‘To sell any loans made or acquired by the Trust st public or private sale and at such price or prices and on such terms as the Authority shall determine, ‘To collect and pay reasonable fees and charges in connection with making, committing to make, purchasing or committing to purchase and servicing its Notes, Bonds, commitments and other evidences of indebtedness. ‘To procure insurance against any type Joss in such amounts, and from such insurers, asit may deem necessary or desirable. ‘To consent, whenever it shall be deemed necessary or desirable in the fulfillment ofits trust punposes, to the modification of tho rate of interest, time of payment of any installment of 13principal or interest, or any other terms of any morfgage loan, mortgage loan commitment, ‘construction loan, temporary loan contractor agreement of any kind to which the Authority isa party. 27) To do any and all things necessary or convenient fo carry out its porposes and exercise the powers given and granted herein, and to do all other acts in their judgment necessary or ) hy of 019, personally appeared Kevin Calvey and further known to me fo be the identical person who subscribed their name to the foregoing instrument, as Trustee, snd acknowledged to me that they executed the simeas thei Fee and voluntary act and deed, forthe uses and purposes therein mentioned and set forth Chis ME. the undersigned, a Notary Public in sn! for said county and State. on the }Q_ IN WITNESS WHEREOF, Ihave horeunto set my hand and year aforessd. ») 2p My Commission Expires: aie ‘Commission Number: } 400) uf affixed my notarial seat the day Notary PublicSTATE OF OKLAHOMA, ) JSS COUNTY OF OKLAHOMA. ) BEFORJ\ME, the undersigned, a Notary Public in and for the above County and State, on the WD day of , 2019, appeared. P.D. Taylor and further known to me to be the identical person Who subscribed their name to the foregoing instrument, as Trustee, and acknowledged to me that they executed the same as their free and voluntary act and deed, for the uses and purposes therein mentioned and set forth IN WIN! and year aforesaid, WHEREOF. I have hereunto set my hand and affixed my notarial seal the day ‘Notary Br e My Commission Expires: ahielos cS Commi: n Number: STATE OF OKLAHOMA ) )ss COUNTY OF OKLAHOMA ) FORE ME, the undersigned. a Notary Public in and for said county and State, on the 1. day of | . 2019, personally appeared Frances C, Ekwerekwu and further known to ‘me to be thd identical person who subscribed their name to the foregoing instrument, as Trustee, and ‘acknowledged to me that they executed the same as their free and voluntary act and deed, for the uses and purposes therein mentioned and set forth, IN WITNESS WIIEREOF, I have hereunto set my hand and affixed my notarial seal the day and year aforesaid.STATE OF OKLAHOMA, ) yss COUNTY OF OKLAHOMA, ) \O_ dy of . 2019, appeared Tricia Everest and further known to me to be the identical person’ who subscribed their name to the forcgoing instrument, as Trustee, and acknowledged to me that they executed the same as their {ree and voluntary act and deed, for the uses and purposes therein mentioned and set forth. BoB ME; the undersigned, a Notary Public in and for the above County and State, on the IN WITNFSS WHEREOF, | have hereunto set my hand and affixed my notarial seal the day Notary ie te My Commission Expires: S}glaa. Commission Number: AAS, STATE OF OKLAHOMA, ) TY OF GKLAHOMA, ) ie undersigned, a Notary Public in and for said county and State, on the | Q) 2019, personally appeared Suc Ann Amall and further known to me to pers ho subscribed their name to the foregoing instrument, as Trustee, and acknowledged to me that they executed the same as their free and voluntary act and deed, for the uses and purposes therein mentioned and sct forth. IN WITNESS WHEREOK, | have hereunto set my hand and affixed my notarial seal the day and year aforesaid, My Commission Expires: ‘alitlay Ao VS53 ‘Commission Number:STATE OF OKLAHOMA, ) SS COUNTY OF OKLAHOMA d 4 BEFORK ME, the undersigned. a Notary Public in and for the above County and State, on the YO. cay of = 2019, appeared M.T, Berry and further known to me to be the jdentical person” who subscribed their name to the foregoing instrument, as Trustee, and acknowledged to me that they executed the same as their free and voluntary act and deed, for the uses and purposes therein mentioned and set forth. IN WITNESS WHEREOF, | have hereunto set my hand and affixed my notarial seal the day and yearaforesaid. Notary ne Xe ‘My Commission Expires: &, RIDA Commission Number: Wan yS4S, STATE OF OKLAHOMA, ) 18S COUNTY OF OKLAHOMA, ) ____, 2019. personally appeared Jim Couch and further known to me to be the son who subscribed their name to the foregoing instrument, as Trustee, and zed to me that they executed the same as their free and voluntary act and deed, for the uses and purposes therein mentioned and set forth, s "ORE ME, the undersigned, a Notary Public in and for said county and State, on the \Q IN WITNESS WHERKOF, I have hereunto set my hand and affixed my notarial seal the day and year aforesaid Notary Pe te ty Commission Expires: © laa Commission NumberSTATE OF OKLAHOMA ) iss COUNTY OF OKLAHOMA ) BEFOR£ ME, the undersigned, a Notary Public in and for the above County and State, on the AD aay or € Line _ 2019, speared Sen Brown and funher known to me tobe the identical person ‘who subscribed their name to the foregoing instrument, as Trustee, and acknowledged to me that they executed the same as their free and voluntary act and deed, for the uses, and purposes therein mentioned and set forth IN WITNESS WHEREOF, have hereunto set my hand and affixed my notarial seal the day and year aforesaid, Notary ay ' Ae Commission Number: My Commission lx ioe 8 19. c Expire Of): STAI F OKLAHOMA, ) COUNTY OF OKLAHOMA) ‘ORE ME. the undersigned, a Notary Public in and for said county and State, on the [Q_ 2019, personally appeared Todd Lamb and further known to me to be the y son who subscribed their name to the foregoing instrument, as Trustee. and acknowledged to me that they executed the same as ther free and voluntary act and deed, forthe uses ‘and purposes therein mentioned and set forth. IN WITNESS WHEREOF. | have hereunto set my hand and affixed my notarial seal the day and year afo My Commission Expi Commission Number:STATE OF OKLAHOMA, COUNTY OF OKLATIOMA, KNOW ALL MEN BY THESE PRES NTS. ‘That the Board of County Commissioners of Oklahoma Coun accepts the beneficial interest in the Authority for anal of behalf of OKtahoma County, O& trast Indenture. State of Okluhoma, hereby ‘the within and foregoing Trust Indenturs, all respeets in accordance with the terms of said WITNESS my hand as Chairman of the Board of County Commissioners of sxid County, atested by the County Clerk of sid County, pursuant to direction of the Board of County Commissioners this 22" day of May, 2019. OKLAHOMA COUNTY, OKLATIOMA, (SEALY ATTEST4 COUNTY CLE! FILED - Oklahoma Secretary of State #5012760636 06/14/2019 FILED IN orrice AG Gala aw JUN 12 2019 “19. JUN 124%9:44:43 Amendment to Oklahoma County Criminal Justice Authority sepa seeygeny cea on bayst Indenture; Amending Article VIL, Paragraphs | and 2 Adopted by the Oklahoma County Criminal Justice Authorit 06/14/2019 11:5 oktewona secREeTA (i SOS Dosey on June 10, 2019 by a Vote of 6-3 The sees of this Authority shali be ein aber. One of the Trustees shall be a member of the Board of County Commissioners of the Beneficiary, or their designee want to Article VIT(i3) hereof, as chosen by the Board of County Commissioners of the Beneficiary (the “Cosmissioner Trustee”). Cne of the members shall be the County Sheriff of the Beneficiary, or their designee pursuant to Article VIZ{12} hereof (the “Sherif? Truscee” and collectively with the Commissioner Trustee the “Elected Official Trustees”). @ Elected al Trustees shali serve terms coterminous their then current terms as elected officials. Any to the office of Oklahoma County Sheriff {including an official serving in an interim or acting capacity), shall, upon taking the applicable Oath of Office, but without any further act, deed or conveyance, automatically becone a Tru of this Authority and become fuily vested with all the estate, prcperties, rights, powers, duties and obiigetions cf their predecessor hereunder with like effect 3 a Trustee herein, One Trustee shall District Cne County Commissioner (the ee”), one Trustee shall be appointed by 0 County ‘Commissiones (the 0. we one Trustee shall be appointed by the ict Three District Three Appointee” and t One Appointee and the District styict Appointed Trustees”). Diseriet, rustees shall serve cerns of six years, shall be Citizens of the Beneficiary or employed full-time in Oklehoma County , and shall not be an Slacted official. Each of the Mistric: Appointed Trustees shall be confirmed by the Hoard of County Cormiseioners, and shal: ‘serve initial terms staggered as follows: the appointees of County Commissioner bistrict One and District three shall serve initial terms cf two (2) years, respectively, and the appointee for County Commissioner District Two shali serve an initial texm of six (6) years. Upon ation of a District Appointed Trustee's term, that appointee or a successor shall be appointed for a term of six years. Upon resignation, death, ofr Appointed Trustee, a successor shail be appeir AU antiremaining portion of the unexpired six-year term. zach successor Dist: Apgointed Trustee shail be selected in the manner provided hereinabove and shali, apon taking the applicable Oath ef Office, but wizhout any further conveyance, automatically become @ Trustee o: ity and become sted with ail the estate, jes, rights, pewe: gations o: predecessor hereunder with like effect as if originally named as Trustee herein. Four Trustees (the “Commission Appointes Trustees”) shall serve terms of six (6) year and shal) be Citizens of the Beneficiary_or full~ ct be en elected official, time in Oklahoma County, anc shal : and whom shall be sen by a majority vote of the Board of y Commissioners, and shall s al terms of fou! years. Upen expiration of a Commission Appoint. e's term, that appointee or a successor shail b ced for a new term ix (6) years. Upon resignation, or removal of a Conmission Appointed “Trustee, .a successor shall be appointed the unexpired term of = Sommission-Appointed Truste provided hereinabove and sh. Cath of Office, but inveyance, automazical and becone- fully rights, powers, di hereunder with ox the remaining portion of ag Trustee, Each successor 1 be selected in the manner pon taking the ap; any furcher act, deed or Trustees of this Authorit the estate, obligations of his if originally named Trustee herein. shall continue to serve ul stccessor has been appointed and has applicable Oath of Cffice. Any District Appointed of Commission Appointed Trustee nay be removed for cause a reason set forth in Okla. tac. Tit. 2 1181 or successor statute pertaining tc the removal of officers) from office upon a unenimous vote of all three County Commissioners, after @ public hearing held before che Board of County Cemmissioners not less than ten (10) days foliow written notice to said Trustee, at which public hearing said Trustee shail have the opportunity to be heard. The initial nine Trustees shall be these nine persons executing th (2} In addition to other removal methods mentione: in the event any Trustee (i) misses more than Trust's meetinge (regular cr special) in any ax (or in the case of a Trustee appointed during any lender year, computed from the date on which he or she 2 a = Indenture, ified as » Truscee A this Indonture}: receives a deferred Lij ds convicted, plservice and a successor shall be appointed as provided herein. In the case of conviction, plea ef guilty to, or receipt a deferred sentence, the position of Trustee shail be vacant as of the dave of said disposition ef he case, disregarding any subsequent appeal therec? to a higher cou! FRosan:DEPARTMENT OF HOMELAND SECURITY IMMIGRATION DETAINER - NOTICE OF ACTION Subject ID. File No _ Eventi: Date: [TO: (Name and Tite of institution - OR Any Subsequent Law FROM (Depariment of Homeland Secutty Ofice Adress) Enforcement Agency) Name of Alien: oe Date of Birth: Citizenship: Sex [ 1. DHS HAS DETERMINED THAT PROBABLE CAUSE EXISTS THAT THE SUBJECT IS A REMOVABLE ALIEN. THIS DETERMINATION IS BASED ON (compete box 1 or 2). {tinal dr of removal aginst the alien o The pendency of ongoing removal proceedings against the alien; Ei Biometic contrmation ofthe alien's identity and a record's check of federal databases that affmatvely indicate, by themselves fr in addition to ather reliable information that the alien either lacks immigration stalus or notwithstanding such stats fs removable under US. immigration law, andior 1 Statements made by th alon to an immigration oficer andlor other reliable evidenge that afimatvely incite the alien ether lacks inimigration status or notwithstanding such status is removable under U.S. immigration lew [ 2. DHS TRANSFERRED THE ALIEN TO YOUR CUSTODY FOR A PROCEEDING OR INVESTIGATION (complete box 1 or 2). [1] Upon completion ofthe proceeding or investigation for which the alien was Yansterred to your custody, DHS intends to resume ‘custody of the alien to compete processing andlor make an“admissibilty determination: IIS THEREFORE REQUESTED THAT YOU: \ * Notify DHS as eats practcable (atleast 48 pours, pacsble) before he alent eloased from your custody. Please nly DHS by cating C] U.S. immigration and Customs Enforcemant (ICE) or L] U.S. Customs and Border Protection (CBP) at _ Ifyou eanot rec an oficial 3 the number(s) provided, please contact the Law Enforcement Support Gonter ai (802) 672-6020, ‘Maintain custody of he alien for a periiy NOT TO EXCEED 48 HOURS beyond the time when halshe would otherwise have been released from your custody to alow CHS to assume custody. The alien must be served with a copy of this farm forthe detainer to take efoxt This detain: arises from DHS authoriies and should not impact deesions about the alien's Bal ‘habitation, pari, release, diversion, cstody classcstion, work, querer assignments. or other matters * Relay this delainer lo ay other lw enforéeent agency to which you transfer custody ofthe alien. * Notify this ofce in the even ef the glen's ceath, hospitalization or transfer to another ins tun, JH checked: please eancil the detsiner related to this alien previously submitted to you on (date) {Name and tie of Immigration Offeer) “Signature of immigration Officer) (Signin iow) [= IF the alien may be the vieim of a erime or you want the alien to remain ia the United States for a law enforcement purpose. noify the ICE Law Enforcement Supper Centor at (802) 872-6020. You may also callthis number # you have ary otter questions OF concerns about this matter. ‘TO BE COMPLETED BY THE LAW ENFORCEMENT AGENCY CURRENTLY HOLDING THE ALIEN WHO IS THE SUBJECT OF THIS Notice: Please provide the information below, sla, and return to DHS by mailing, emaling or faxing a copy to Local Bookingtinmate # Estimated release datetime: an Dat o latest criminal chargeleonvetion Last ofense chargedieanvicion _ This form was served upon the alien on sin the folowing manner Ly irperson ] byinmate mai detvery [] other (please specify): ‘Waa a8 ie FOREN) DHS Form 1-247A (3117)NOTICE TO THE DETAINEE ‘The Department of Homeland Security (OHS) has placed an immigration detainer on you. An immigration detainer is @ Notice to a law enforcement agency that DHS intends to assume custody of you (after you otherwise would be released from custody) because there is probable cause that you are subject to removal from the United States under federal immigration law. DHS has requested that the law enforcement agency that is currently detaining you maintain custody of you for a periad not to exceed 48 hours beyond the time when you would have been released based on your criminal charges or convictions, If DHS does not take you into custody during this additional 48 hour period, you should contact your custodian (the agency that is holding you now) to inquire about your release. If you believe you are a United States citizen or the victim of a crime, please advise DHS by calling the ICE Law Enforcement Support Center toll free at (855) 448-6903, NOTIFICACION A LA PERSONA DETENIDA El Departamento de Seguridad Nacional (DHS) le ha puesto una retencién de inmigracion. Una retencién de inmigracion ‘8s un aviso a una agencia de la ley que DHS tiene la intencién de asumirla custodia de usted (después de lo contrano, sted seria puesto en libertad de la custodia) porque hay causa probable que usted esta sujeto a que lo expulsen de los Estados Unidos bajo la ley de inmigracion federal. DHS ha solicitado que la agencia de la ley que le bene deterido sctualmente mantega custodia de usted por un periodo de tiempo que no exceda de 48 horas més del tiempo original que habria sido puesto en libertad en base a los cargos juiciales o a sus antacedentes penales. Si DHS no le pone en custodia durante este periodo adicional de 48 horas, usted debe de contactarse con su custodio (a egencia que le tiene detenido en este momento) para preguntar acerca de su liberacién, Si usted creo que es un ciudadano de los Estados Unldos ola vetima de un erimen, por favor aise al DHS llamando gratuitamente al Centro de Apoyo ala Aplicacién de la Ley ICE al (855) 448-6903, AVIS AU DETENY OU ALA DETENUE Le Département de la Séoutlé Inttieure (DHS) a plaed uh dépositere dim*higration sur vous. Un dépositaire immigration est un avs & une agence de force de éfde que le DHS a intention de vous prendre en garde a vue (eprés cela vous pourrez par aileurs ere remis en liberte) parce quil ya une cause probable que vous cover sujet 8 ‘oxpulsion des Etats-Unis en vert de la oi fedérale sur inmigration. Le DHS a demandé que Fagence de force de Fordre qui vous détientactuelement puisse vous mainténir én garde pendant une période ne devant pas dépasser 48 heures au-dela du temps apres lequel vous aur été libére en se basant sur vos accusations crminlles ou ondamnations. Si le DHS ne vous prenne pas en garde & vue au cours de cette période supplémentare de 48 heures, vous devez contacter votre gardien (ne) (agence qui vous déient maintenant) pour vous ronseigner sur votre libératon. SI vous eroyez que yous @tos un citoyen ou une citoyenne des Etats-Unis ou une vietime dun crime, s'il vous plait aviserle DHS en appelant gratuitement le centre d'assistance de force de Vordre de TICE au (655) 448.6009 | ; NOTIFICAGAO AO DETENTO © Departamento de Segurenga Nacional (OHS) expediu um mandade de detenso migratéria contra voo8. Um mandado de detencdo migratria 6 uma notifcagao feta 8 uma ayéncia de seguranga pibica que o DHS tem a intengao de assumir a sua custoda (apés a qual voc8, caso contrario, seria liberado da custodia) porque existe causa provavel que ‘ood est sujeito ser removido dos Estados Unidos de acordo com ale federal de imigrago. ODHS solicit a agencia de seguranca publica onde vocé esta atualmente detico para manter @ sua guarda por um periodo de no maximo 48 horas além do tempo que vocé teria sido liberado com base nas suas acusagbes ou condenagies criminals. Se o DHS no leva-lo sob custédia duranto este periodo adicional de 48 horas, vocé deve entrar em contato com quem tivera sua custédia (a agéncia onde vocé esta atuslmente detido) para perquntar a respeito da sva liberagao. Se voce acredita ser um cidadao dos Estados Unidos ou a vitima de um crime, por favor informe ao DHS através de uma ligagao gratuita ao Centro de Suporte de Seguranca Publica do Servico de Imigragao e Alfandega (ICE) pelo telofone (855) 448-6903. DHS Form |-247A (3117) Page 20f 3THONG BAO CHO NGUOIB| GIAM 186 NOI An (DHS) da ra Iénh giam git di tra di v6i quy vi. Giam gi di tra 1a mét théng bdo cho co quan céng Ive rng B6 NGi An 88 dam dvong viec Ivu git quy vi (sau khi quy vi duge thd ra) bai cé ly do kha tin quy vila 61 ‘wong bj tryc xuat khdi Hoa KY theo luat di tru lién bang. Sau khi quy vi da thi hanh day i thoi gian cla bén an ya trén cc ti pham hay cac ket an, thay vi dugc tha ty do, B6 Noi An 48 yeu cu co quan cBng lye git quy vi lai thém khong qua 48 tiéng ébng hd nia. Néu BO NBi An khéng dén bat qui vi sau 48 tiéng déng hd phy ti 46, ‘uy vi cn len lac voi co quan hién dang glam gic quy vi d8 tham kndo vé vige t ty do cho quy vi. Nu quy vil cong dan Hoa Ky hay tin réng minh 18 nan nhan cia m9t t0i &c, xin vui long bao che B86 Noi An bang cach got <8 ign thoai mign phi 1(855) 448-6903 cho Trung Tam H8 Tr Co Quan Céng Lue Oi Tr OS Se Bit 2 2 8h(Department of Homeland Security » fajf#DHS) AS nse RTH = BRINN S oP ACA SGU Ne HR SFE HE ISG REHO + TERAS ECE + (Asi RHE APE Pe « DHSJ iS SURE TR + tEAR RERRRUIISAS F > eee in Ro E/N ARE ° EATER OIE a > TSAR BS ADMSAIEC ES P+ (asi ae ees (RAVES SABIE PRAIA ety AERO DE - HRA ERAARRA PERLE S SPS BICEM CARY HE Ly (Law Enforcement Support Center) s#DHS * s@ 2

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