BEFORE THE GAMING CONTROL BOARD DOWNS RACING, LP. COMMONWEALTH OF MOHEGAN SUN POCONO GID 1267?3 GAMING IN RE: MINIMUM SECURITY CONTROL BOARD STAFFING DOCKET NO. CONSENT AGREEMENT AND STIPULATION OF SETTLEMENT THIS CONSENT AGREEMENT AND OF SETTLEMENT is made and entered into by the Commonwealth of Gaming Control Board (?Board?), Of?ce of Enforcement Counsel and Downs Racing, LP. d/b/a Mohegan Sun Pocono CBC and MSP are collectively referred to as the ?Parties;? and WHEREAS, has its principal place of business at 1280 Highway 315, Wilkes~ Barre, 18702, and is the holder of a Category 1 slot machine license as approved by the Board on October 4, 2007; and WHEREAS, the Board?s Bureau of Investigations and Enforcement is the investigative body established by 4 1517 for the purpose of, inter alia, investigating licensees, permittees, registrants and other persons for potential violations of 4 103 et seq., known as the Race Horse Development and Gaming Act (the including potential violations referred to BIB by the Board or other persons; and WHEREAS, OEC is the prosecutorial body established by 4 1517(a2) and has the power and duty to initiate proceedings for administrative violations of the Act pursuant to section of the Act; and WHEREAS, pursuant to 4 1 102(1), the primary object of the Act to which all other objectives and purposes are secondary is to protect the public through the regulation and policing of all activities involving gaming and practices that continue to be unlawful; and WHEREAS, pursuant to 4 BIB shall have the power and duty to monitor gaming operations to ensure the implementation of adequate security measures by a licensed entity; and WHEREAS, pursuant to section 465.i4(a) of the Board?s Regulations, slot machine licensees shall be required to submit a minimum staf?ng submission with regard to its security department. The minimum staf?ng submission must consider the size and layout of the licensed facility as well as the number and con?guration of slot machines and table games on the gaming ?oor and must at all times provide l?or security of the gaming floor and restricted areas servicing the gaming operation; and WHEREAS, section 465.14(a) of Board approved Internal Controls, which are con?dential pursuant to 4 ?l206(t), mandate speci?c security staf?ng levels at MSP during all. hours of operation; and WHEREAS, this is the first Consent Agreement of this nature since last renewal. WHEREAS, the Parties do not dispute thejurisdiction of the Board; and WHEREAS, the Parties now seek to enter into this Consent Agreement as a compromise of any disputed claims and in consideration of the Parties waiving, releasing, and forbearing any regulatory dispute; and NOW, THEREFORE, the Parties stipulate and agree, and present to the Board for its consideration, the following: STIPULATION OF FACTS On January 3,2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1 :50 RM. (January 2, 2019) through 4:00 AM. 2 mandated security of?cer rover positions were vacant; 0 4:00 AM, through 8:00 AM. - 3 mandated security of?cer rover positions were vacant. On January 4, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (January 3, 2019) through 12:30 AM. - 2 mandated security officer rover positions were vacant; 12:30 AM. through 1:00 AM. 3 mandated security of?cer rover positions were vacant; 1:00 AM. through 4:00 AM. - 2 mandated security of?cer rover positions were vacant; 4:00 AM. through 5:00 AM. - 3 mandated security of?cer rover positions were vacant; 5:00 AM. through 5:30 AM. - 2 mandated security of?cer rover positions Were vacant; 5:30 AM. through 06:00 AM. 3 mandated security of?cer rover positions were vacant; 6:00 AM. through 8:00 AM. - 2 mandated security of?cer rover positions were vacant. 9121 -1 9 On January 6, 2019, failed to meet the minimum security staffing requirements as follows: 1:00 AM. through 1:30 AM. - 1 mandated security of?cer rover position was vacant; 2:30 AM. through 3:00 AM. - 1 mandated security of?cer rover position was vacant; 3:00 A.M. through 3:30 A.M. - 2 mandated security of?cer rover positions were vacant; 3:30 A.M. through 4:00 AM. - 1 mandated security of?cer rover position was vacant; 4:00 A.M. through 4:30 A.M. - 3 mandated security of?cer roverpositions were vacant; 4:30 AM. through 5:00 AM. - 2 mandated security of?cer rover positions were vacant; 5:00 AM. through 6:00 A.M. - I mandated security of?cer rover position was vacant; 6:00 A.M. through 6:30 AM. 2 mandated security of?cer rover positions were vacant; 6:30 AM. through 7:00 AM. - 1 mandated security of?cer rover position was vacant; 7:00 AM. through 07:30 A.M. - 3 mandated security of?cer rover positions were vacant; 7:30 AM. through 8:00 A.M. - i mandated security of?cer rover position was vacant. On January 10, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (January 9, 2019) through 8:00 A.M. - 2 mandated security of?cer rover positions were vacant. On January 11, 2019, MSP failed to meet the minimum security staf?ng requirements as foiiows: 1 4:30 AM. through 5:30 AM. i mandated security of?cer rover position was vacant; 6:00 A.M. through 6:30 A.M. - mandated security of?cer rover position was vacant. On January 12, 2019, failed to meet the minimum security staf?ng requirements as foiiows: 1 1:50 RM. (January 1 1, 2019) through 1:00 AM. - 2 mandated security of?cer rover positions were vacant; 1:00 AM. through 2:00 AM. - 1 mandated security of?cer rover position was vacant; 4:00 A.M. through 4:30 AM. - 2 mandated security of?cer rover positions were vacant; 4:30 A.M. through 5:00 AM. - 3 mandated security of?cer rover positions were vacant; 5:00 AM. through 7:00 AM. - 1 mandated Security of?cer rover position was vacant. On January 13, 2019, MSP faiied to meet the minimum security staf?ng requirements as foiiows: I 11:50 RM. (January 12, 2019) through 2:00 A.M. 2 mandated security of?cer rover positions were vacant; i 1 2:30 A.M. through 4:00 A.M. - 1 mandated security of?cer rover position was vacant. 9 On January 17, 2019, failed to meet the minimum security staf?ng requirements as follows: 1 1 :50 RM. (January 16, 2019) through 12:30 A.M. 1 mandated security of?cer rover position was vacant; 4:30 through 5:00 AM. - 1 mandated security of?cer rover position was vacant; 5:00 AM. through 5:30 AM, - 2 mandated security of?cer rover positions were vacant; 5:30 AM. through 6:00 A.M. 1 mandated security of?cer rover position was vacant; 6:00 AM. through 6:30 A.M. - 2 mandated security of?cer rover positions were vacant; 6:30 A.M. through 8:00 AM. 1 mandated security of?cer rover position was vacant. On January 18, 2019, failed to meet the minimum security staf?ng requirements as follows: 5:00 AM. through 5:30 A.M. mandated security of?cer rover position was vacant; 6:00 AM. through 6:30 AM: - mandated security of?cer rover position was vacant. On January 19, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 12:30 AM. through 1:30 A.M. 1 mandated security of?cer rover position was vacant; 5:00 AM. through 6:00 A.M. - 1 mandated security of?cer rover position was vacant. On January 20, 2019, failed to meet the minimum security staf?ng requirements as follows: 12:30 A.M. through 1:30 AM. - 1 mandated security of?cer rover position was vacant; 5:00 A.M. through 6:00 AM. 1 mandated security officer rover position was vacant. On January 24,2019, MSP failed to meet the minimum security staf?ng requirements as foilows: 4:30 A.M. through 5:30 AM. - 1, mandated security of?cer rover position was vacant; 6:00 A.M. through 6:30 AM. a 1 mandated security officer rover position was vacant. 9152-19 On January 25, 2019, faiied to meet the minimum security staf?ng requirements as foiiows: 1 1:50 RM. (January 24, 2019) through 12:30 A.M. 1 mandated security of?cer rover position was vacant; 4:00 A.M. through 4:30 A.M. 1 mandated security of?cer rover position was vacant; 4:30 A.M. through 5:30 A.M. 2 mandated security officer rover positions were vacant; 5:30 A.M. through 6:00 A.M. mandated security of?cer rover positiOn was vacant; 6:00 A.M. through 6:30 A.M. - 2 mandated security of?cer rover positions were vacant; 6:30 A.M. through 8:00 A.M. - 1 mandated security of?cer rover position was vacant. On January 31, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (January 30, 2019) through 12:30 A.M. - 1 mandated security of?cer rover position was vacant; 2 4:00 A.M. through 4:30 A.M. - mandated security of?cer rover position was vacant; 4:30 A.M. through 5:00 A.M. - 2 mandated security officer rover positions were vacant; 5:00 A.M. through 5:30 A.M. 1 mandated security officer rover position was vacant; 6:00 A.M. through 6:30 A.M. '1 mandated security officer rover position was vacant. 9 On February 1, 2019, MSP failed to meet the minimum security staffing requirements as follows: 11:50 RM. (January 31, 219) through 4:00 A.M. - 2 mandated security officer rover positions were vacant; I 1 4:00 A.M. through 5:00 A.M. - 3 mandated security of?cer rover positions were vacant; 05:00 A.M. through 8:00 A.M. 2 mandated security officer rover positions were vacant. On, February 4, 2019, failed to meet the minimum security staffing requirements as follows: 4:00 AM. through 4:30 A.M. 1 mandated security of?cer rover position was vacant; 4:30 A.M. through 5:00 A.M. 2 mandated security officer rover positions were vacant; 5:00 A.M. through 6:00 A.M. - mandated security officer rover position was vacant; 6:00 AM. through 7:00 A.M. 2 mandated security of?cer rover positions were vacant; 7:00 A.M. through 8:00 A.M. 1 mandated security of?cer rover position was vacant. On February 5, 2019, failed to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (February 4, 2019) through 1:00 A.M. - 2 mandated security officer rover positions 0 were vacant; 1:00 AM. through 3:30 A.M. ?1 mandated security of?cer rover position was vacant; 3:30 A.M. through 4:00 AM. 2 mandated security of?cer rover positions were vacant; 4:00 AM. through 5:30 AM. - 3 mandated security of?cer rover positions were vacant; 5:30 AM. through 8:00 AM. 2 mandated security officer rover positions were vacant. 1 On February 6, 2019, MSP failed to meet the minimum security staffing requirements as follows: 11:50 P.M. (February 5, 2019) through 1:30 AM. 1 mandated security of?cer rover position was vacant; 4:00 A.M. through 4:30 A.M. 2 mandated security officer rover positions were vacant; 4:30 AM. through 5:00 A.M. 3 mandated security officer rover positions were vacant; 5:00 A.M. through 6:30 A.M. - 2 mandated security of?cer rover positions were vacant; 6:30 A.M. through 7:00 1 mandated security of?cer rover position was vacant; 7:30 A.M. through 8:00 A.M. - 1 mandated security officer rover position was vacant. On February 7, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 11:50 P.M. (February 6, 2019) through 1:30 A.M. - 1 mandated security of?cer rover position was vacant; 4:00 A.M. through 4:30 A.M. - 1 mandated security of?cer rover position was vacant; 4:30 A.M. through 5:00 AM. - 2 mandated security of?cer rover positions were vacant; 5:00 AM. through 6:00 A.M. - 1 mandated security of?cer rover position was vacant; 6:00 A.M. through 6:30 AM. 2 mandated security of?cer rover positions were vacant. 71-19 On February 8, 2019, faiied to meet the minimum security staffing requirements as follows: 11:50 RM. (February 7, 2019) through 1 :00 2 mandated security of?cer rover positions were vacant; 1:00 A.M. through 2:00 A.M. - 1 mandated security officer rover position was vacant; 2:30 A.M. through 04:00 A..M. - 1 mandated security officer rover position was vacant; 4:00 A.M. through 4:30 A.M. - 2 mandated security of?cer rover positions were vacant; 4:30 A.M. through 5:00 AM. 3 mandated security officer rover positions were vacant; 5:00 AM. through 6:30 AM. - 2 mandated security officer rover positions were vacant; 6:30 A.M. through? 7:00 AM. - 1 mandated security of?cer rover position was vacant; 7:30 AM. through 8:00 A.M, - mandated security officer rover position was vacant. 7230-19 February l, 2019, failed to meet the minimum security staf?ng requirements as follows: 4:00 AM. through 4:30 A.M. - mandated security officer rover position was vacant; 4:30 AM. through 5:00 AM. - 2 mandated security of?cer rover positions were vacant; 5:00 through 6:00 AM. - 1 mandated security of?cer rover position was vacant; 6:00 AM. through 7:00 A.M. 2 mandated security of?cer rover positions were vacant; 7:00 A.M. through 8:00 AM. - i mandated security of?cer rover position was vacant. 7233-19 On February 12, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (February 1 I, 2019) through 1:00 AM. 2 mandated security officer rover positions were vacant; 1:00 A.M. through 3:30 AM. - mandated security of?cer rover position was vacant; 3:30 A.M. through 4:00 A.M. - 2 mandated security officer rover positions were vacant; 4:00 A.M. through 5:30 AM. - 3 mandated security of?cer rover positions were vacant; 5:30 A.M. through 8:00 A.M. - 2 mandated security of?cer rover positions were vacant. 7236-19 On February 13, 2019, failed to meet the minimum security staffing requirements as follows: 1 1:50 RM. (February 12, 2019) through i :30 A.M. - mandated security of?cer rover position was vacant; 4:00 AM. through 4:30 A.M. 1 mandated security officer rover position was vacant; 4:30 AM. through 5:00 AM. - 2 mandated security officer rover positions were vacant; 5:00 AM: through 6:00 AM. - 1 mandated security officer rover position was vacant; 6:00 AM. through 6:30 AM. 2 mandated security of?cer rover positions were vacant. 91 73?19 On February '14, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1 :50 RM. (February 13, 2019) through 1:00 A.M. 2 mandated security of?cer rover positions were vacant; 1:00 A.M. through 2:00 AM. - I mandated security of?cer rover position was vacant; 2:30 A.M. through 4:00 A.M. mandated security of?cer rover position was vacant; 4:00 AM. through 4:30 AM. 2 mandated security of?cer rover positions were vacant; 4:30 A.M. through 5:00 AM. - 3 mandated security of?cer rover positions were vacant; 5:00 AM. through 6:30 AM. - 2 mandated security of?cer rover positions were vacant; 6:30 A.M. through 7:00 AM. - 1. mandated security of?cer rover position was vacant; 7:30 AM. through 8:00 A.M. - 1 mandated security of?cer rover position was vacant. 74-1 9 On February 15, 2019, MSP failed to meet the minimum security staffing requirements as foilows: i 1 1:50 RM. (February 14, 2019) through 12:30 AM. 2 mandated security of?cer rover positions were vacant; 12:30 A.M. through 1:00 AM. - 3 mandated security of?cer rover positions were vacant; 1:00 A.M. through 2:00 AM. - 2 mandated security of?cer rover positions were vacant; 2:00 AM. through 2:30 A.M. - I mandated security of?cer rover position was vacant; 2:30 A.M. through 4:00 A.M. - 2 mandated security of?cer rover positions were vacant; 4:00 AM. through 05:30 A.M. 3 mandated security of?cer rover positions were vacant; 5:30 A.M. through 8:00 A.M. - 2 mandated security of?cer rover positions were vacant. 76?19 On February 16, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1:50 P.M. (February 15, 2019) through 1 :00 AM. I mandated security of?cer rover position was vacant; 4:00 A.M. through 4:30 A.M. 2 mandated security officer rover positions were vacant; 4:30 AM. through 5:00 A.M. - 3 mandated security of?cer rover positions were vacant; 5:00 AM. through 7:00 A.M. - 1 mandated security of?cer rover position was vacant. . On February 17, 2019, MSP failed to meet the minimum security staf?ng requirements as foiiows: 1 1 :50 RM. (February 16, 2019) through 12:30 A.M. - i mandated security officer rover position was vacant; 1:00 AM. through 1:30 A.M. - 2 mandated security of?cer rover positions were vacant; 1:30 AM. through 2:00 A.M. mandated security of?cer rover position was vacant; - 2:30 A.M. through 3:30 AM. 2 mandated security of?cer rover positions were vacant. 91 78?] 9 On February 22, 20419, MSP failed to meet the minimum security staf?ng requirements as follows: 11:50 RM. (February 21,, 2019) through 1:00 AM. - 2 mandated security of?cer rover positions were vacant; 1:00 A.M. through 4:00 A.M. 1 mandated security of?cer rover position was vacant; 4:00 AM. through 5:00 AM. 3 mandated security of?cer rover positions were vacant; 5:00 A.M. through 5:30 AM. - 2 mandated security of?cer rover positions were vacant; 5:30 A..M. through 6:00 A.M. - 3 mandated security of?cer rover positidns were vacant; 6:00 AM. through 8:00 AM. - 2 mandated security of?cer rover positions were vacant. On February 23, 2019, failed to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (February 22, 2019) through 1:30 A.M. - 1 mandated security of?cer rover position was vacant; 4:00 A.M. through 4:30 A.M. - 1 mandated security of?cer rover position was vacant; 4:30 AM. through 5:00 AM. - 2 mandated security of?cer rover positions were vacant; 6:00 AM. through 6:30 A.M. 1 mandated security of?cer rover position was vacant. i On February 24, 2019, failed to meet the minimum security staf?ng requirements as follows: 1:00 A.M. through 1:30 A.M. - 1 mandated security of?cer rover position was vacant; 2:30 AM. through 3:30 AM. 1 mandated security of?cer rover position was vacant; 4:00 A.M. through 4:30 A.M. - 2 mandated security of?cer rover positions were vacant; 4:30 AM. through 5:00 AM. - 1 mandated security of?cer rover position was vacant; 6:00 AM. through 6:30 A.M. - 1 mandated security of?cer rover position was vacant. On February 27; 2019, MSP faiied to meet the minimum security staf?ng requirements as follows: 1:00 A.M. through 2:00 AM. - i mandated security officer rover position was vacant; 2:30 A.M. through 3:00 A.M. 1 mandated security of?cer rover position was vacant; 5:00 AM. through 5:30 AM. - 2 mandated security of?cer rover positions were yacant; 5:30 A.M. through 6:00 A.M. - 3 mandated security officer rover positions were vacant; 6:00 A.M. through 8:00 A.M. - 2 mandated security of?cer rover positions were vacant. On February 28, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: I 1 :50 RM. (February 27, 2019) through ?1 :00 AM. 1 mandated security of?cer rover position was vacant; 1:30 AM. through 2:00 - mandated security of?cer rover position was vacant; 4:30 AM. through 5:00 AM. mandated security officer rover position was vacant. On March 1, 2019, MSP failed to meet the minimum security staf?ng requirements as foiiows: 4:00 A.M. through 4:30 A.M. - 1 mandated security officer rover position was vacant; 4:30 AM. through 5:00 AM. - 2 mandated security of?cer rover positions were vacant; 6:00 A.M: through 6:30 AM. 1 mandated Security of?cer rover position was vacant. On March 2, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 11:50 RM. (March 1, 2019) through 1:00 AM. - 2 mandated security of?cer rover positions were vacant; 1:00 A.M. through 2:00 AM. - 1 mandated security of?cer rover position was vacant; 2:30 A.M. through 4:00 AM. 1 mandated security of?cer rover position was vacant; 4:00 A.M. through 5:00 A.M. 2 mandated security of?cer rover positions were vacant; . 5:00 AM. through 8:00 A.M. 2 mandated security of?cer rover positions were vacant. On March 3, 2019, failed to meet the minimum security staf?ng requirements as follows: 1:00 A.M. through 1:30 A.M. 2 mandated security of?cer rover positions were vacant; 2:30 A.M. through 3:00 A.M. - 1 mandated security of?cer rover position was vacant; 3:00 AM. through 3:30 A.M. - 3 mandated security of?cer rover positions were vacant; 3:30 A.M. through 4:00 A.M. 2 mandated security of?cer rover positions were vacant; 4:00 A.M. through 4:30 A.M. - 3 mandated security of?cer rover positions were vacant; 4:30 AM. through 5:00 A.M. - 2 mandated security of?cer rover positions were vacant; 5:30 AM. through 6:00 A.M. - 1 mandated security of?cer rover position was vacant; 6:00 AM. through 6:30 AM. 2 mandated security of?cer rover positions were vacant; 7:00 A.M. through 8:00 AM. - 1 mandated security of?cer rover position was vacant. On March 4, 2019, failed to meet the minimum security staf?ng requirements as follows: {:50 PM. (March 3, 2019) through 1:00 AM. - 2 mandated security of?cer rover positions were vacant; 1:00 AM. through 4:00 A.M. 1 mandated security of?cer rover position was vacant; 4:00 A.1V1. through 5:00 A.M. - 3 mandated security of?cer rover positions were vacant; 5:00 A.M. through 6:00. A.M. - 2 mandated security of?cer rover positions were vacant; 6:00 AM. through 8:00 AM. i mandated security of?cer rover position Was vacant. On March 5, 2019, faiied to meet the minimum security staf?ng requirements as foiiows: 1 iz50 RM. (March 4, 2019) through 1:00 AM. 2 mandated security of?cer rover positions were vacant; 1:00 AM. through 4:00 A.M. - 1 mandated security officer rover position was vacant; 4:00 A.M. through 5:00 AM. 3 mandated security of?cer rover positions were vacant; 5:00 A.M. through 5:30 AM. - 2 mandated security of?cer rover positions were vacant; 5:30 A.M. through 6:00 AM. 3 mandated security of?cer rover positions were vacant; 6:00 A.M. through 8:00 A.M. 2 mandated security of?cer rover positions were vacant. On March 6, 20 i 9, failed to meet the minimum security staffing requirements as follows: 1 i:50 RM. (March 5, 20i9) through 3:30 2 mandated security of?cer rover positions were vacant; 3:30 A.M: through 08:00 A.M. - 3 mandated security of?cer rover positions were vacant. On March 7, 2019, MSP failed to meet the minimum security staf?ng requirements as folloWs: 1 1:50 RM. (March 6, 2019) through 3:30 AM. 1 mandated security of?cer rover position was vacant. On March 8, 2019, failed to meet the minimum security staf?ng requirements as foiiows: 11:50 RM. (March 7, 2019) through 5:00 AM. - 1 mandated security of?cer rover position was vacant; 5:00 A.M. through 8:00 AM. 2 mandated security of?cer rover positions were vacant. On March 9, 2019, failed to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (March 8, 2019) through 12:30 .. 2 mandated security of?cer rover positions were vacant; 12:30 A.M. through 1:00 A.M. - 3 mandated security of?cer rover positions were vacant; 1:00 AM. through 2:00 AM. - 2 mandated security of?cer rover positions were vacant; 2:00 A.M. through 2:30 AM. - 1 mandated security of?cer rover position was vacant; 2:30 A.M. through 4:00 A.M. 2 mandated security of?cer rover positions were vacant; 4:00 AM. through 5:00 A.M. 3 mandated security of?cer rover positions were vacant; :00 A.M. through 5:30 A.M. - 2 mandated security of?cer rover positions were vacant; :30 A.M. through 8:00 A.M. - 1 mandated security of?cer rover position was vacant. On March 10, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 11:50 PM. (March 9, 2019) through 3:00 AM. - 2 mandated security of?cer rover positions were vacant; 3:30 A.M. through 4:00 AM. - 2 mandated security of?cer rover positions were vacant; 4:00 A.M. through 4:30 AM. 3 mandated security of?cer rover positions were vacant; 5:00 A.M. through 6:00 A.M. 2 mandated security of?cer rover positions were vacant; 6:00 AM. through 8:00 AM. - mandated security of?cer rover position was vacant. On March 1 l, 2019, failed to meet the minimum security staf?ng requirements as follows: 1 1:50 PM. (March 10, 2019) through 4:00 A.M. 2 mandated security of?cer rover positions were vacant; 4:00 AM. through 5:00 AM. - 3 mandated security of?cer rover positions were vacant; 5:00 A.M. through 8:00 AM. 2 mandated security officer rover positions were vacant. On March 12, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (March 1 1, 20119) through 12:30 A.M. 2 mandated security officer rover positions were vacant; 12:30 A.M. through 1:00 A.M. - 3 mandated security officer rover positions were vacant; 1:00 A.M.through 4:00 A.M. 42 mandated security of?cer rover positions were vacant; 4:00 AM. through 5:00 AM. 3 mandated security of?cer rover positions were vacant; 5:00 A.M. through 5:30 A.M. - 2 mandated security of?cer rover positions were vacant; 5:30 AM. through 6:00 A.M. - 3 mandated security of?cer rover positions were vacant; 6:00 A.M. through 8:00 A.M. - 2 mandated security officer rover positions were vacant. On March 13, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 11:50 RM. (March 12, 2019) through 12:30 A.M. 2 mandated security officer rover positions were vacant; 12:30 A.M. through 1:00 AM. 3 mandated security of?cer rover positions were vacant; 1:00 AM, through 5:30 A.M. - 2 mandated security officer rover positions were vacant; 5:30 AM. through 6:00 AM. 3 mandated security of?cer rover positions were vacant; 6:00 A.M. through 8:00 A.M. - 2 mandated security of?cer rover positions were vacant. On March 14, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 11:50 P..M (March '13, 2019) through 8:00 A.M. - 2 mandated security of?cer rover positions were vacant. On March 15, 2019, MSP failed to meet the minimum security staf?ng requirements as foilows: 11:50 RM. (March 14, 2019) through 12:30 A.M. 1 mandated security of?cer rover position \yas vacant; 1 1:00 AM. through 2:00 A.M. 1 mandated security officer rover position was vacant; 4:00 AM. through 4:30 A.M. 1 mandated security officer rover position was vacant; 4:30 A.M. through 5:30 A.M. - 2 mandated security officer rover positions were vacant; 5:30 A.M. through 6:30 A.M. - ~1 mandated security officer rover position was vacant. On March 16, 2019, failed to meet the minimum security staf?ng requirements as follows: 1 1 :50 RM. (March 15, 2019) through 1:00 AM. - 2 mandated security of?cer rover positions were vacant; 1:00 AM. through 2:00 A.M. i mandated security officer rover position was vacant; 4:00 AM. through 4:30 A.M. 2 mandated security of?cer rover positions were vacant; 4:30 A.M. through 5:00 AM. - 3 mandated security of?cer rover positions wcre?vacant; 5:00 A.M. through 7:00 A.M. - 1 mandated security of?cer rover position was vacant. On March 17, 2019, MSP faiied to meet the minimum security staf?ng requirements as foilOws: 2:30 AM. through 4:00 AM. - 2 mandated security officer rover positions were vacant; 4:00 A.M. through 4:30 A.M. - mandated security of?cer rover position was vacant; 4:30 AM. through 8:00 AM. - 3 mandatedsecurity officer rover positions were vacant. On March 18, 2019, faiied to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (March 17, 2019) through 4:00 AM. - 2 mandated security of?cer rover positions were vacant; 4:00 AM. through 5:00 AM. 3 mandated security of?cer rover positions were vacant; 5:00 A.M. through 8:00 A.M. - 2 mandated security of?cer rover positions were vacant. On March 19, 2019, MSP faiied to meet the minimum security staf?ng requirements as follows: 1 1:50 PM. (March 18, 2019) through 1:00 AM. - 1 mandated security officer rover position was vacant; 4:00 AM. through 4:30 AM. - 2 mandated security officer rover positions were vacant; 4:30 AM. through 5:00 AM. - 3 mandated security of?cer rover positions were vacant; 5:00 AM. through 5:30 AM. i mandated security of?cer rover position was vacant; 5:30 A.M. through 7:00 A.M. 2 mandated security of?cer rover positions were vacant; 7:00 AM. through 8:00 AM. 1 mandated security of?cer rover position was vacant. On March 20, 2019, failed to meet the minimum security staf?ng requirements as foliows: 1 1 :50 RM. (March 19, 2019) through 12:30 A.M. 2 mandated security of?cer rover positions were vacant; 12:30 A.M. through 2:00 AM. - 1 mandated security of?cer rover position was vacant; 2:30 AM. through 4:30 A.M. - 2 mandated security of?cer rover positions were vacant; 4:30 A.M. through 5:00 A.M. - 3 mandated security of?cer rover positions were vacant; 5:00 A.M. through 5:30 AM. 2 mandated security of?cer rover positions were vacant; 5:30 AM. through 6:00 A.M. 1 mandated security of?cer rover position was vacant; 6:00 AM. through 6:30 A.M. - 2 mandated security of?cer rover positions were vacant; 6:30 AM. through 7:00 A.M. - 1 mandated security of?cer rover position was vacant; 7:30 A.M. through 8:00 AM. 1 mandated security of?cer rover position was vacant. On March 21, 2019, failed to meet the minimum security staf?ng requirements as foiiows: 11:50 P.M. (March 20, 2019) through 3:30 AM. 1 mandated security of?cer rover position was vacant; 3:30 AM. through 4:00 A.M. 2 mandated security of?cer rover positions were vacant; 4:00 A.M. through 5:00 A.M. - 3 mandated security of?cer rover positions were vacant; 5:00 AM. through 8:00 AM. - 2 mandated security of?cer rover positions were vacant. On March 22, 2019, failed to meet the minimum security staf?ng requirements as follows: 1 1 :50 PM. (March 21, 2019) through 12:30 AM. - 2 mandated security officer rover positions were vacant; 12:30 AM: through 1:00 A.M. 3 mandated security officer rover positions were vacant; 1:00 A.M. through 2:00 AM. 2 mandated security officer rover positions were vacant; 2:00 AM. through 2:30 A.M. - 1 mandated security officer rover position was vacant; 2:30 AM. through 4:00 A.M. 2 mandated security officer rover positions were vacant; 4:00 AM through 5:00 AM. 3 mandated security officer rover positions were vacant; 5:00 A.M. through 5:30 AM. 2 mandated security officer rover positions were vacant; 5:30 AM. through 6:00 A.M. - 3 mandated security officer rover positions were vacant; 6:00 A.M. through 8:00 A.M. - 2 mandated security of?cer rover positions were vacant. On March 23, 2019, faiied to meet the minimum security staf?ng requirements as foiiows: 1 1:50 RM. (March 22, 2019) through 1:00 AM. - 2 mandated security officer rover positions were vacant; 1:00 through 2:00 A.M. - 1 mandated security officer rover position was vacant; 2:30 AM. through 4:00 AM. 1 mandated security officer rover position was vacant; 4:00 AM. through 5:00 A.M. - 3 mandated security officer rover positions were vacant; 5:00 A.M. through 6:00 AM. - 2 mandated security of?cer rover positions were vacant; 6:00 AM. through 8:00 AM. 1 mandated security officer rover position was vacant. On March 24, 2019, failed to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (March 23, 2019) through 12:30 AM. - 1 mandated security of?cer rover position was vacant; 12:30 AM. through 1:30 A.M. 2 mandated security officer rover positions were vacant; 2:30 A.M. through 3:00 A.M. 2 mandated security of?cer rover positions were vacant; 3:00 AM. through 5:00 AM. - 3 mandated security of?cer rover positions were vacant; 5:00 AM. through 6:00 A.M. - 2 mandated security of?cer rover positions were vacant; 6:00 through 8:00 AM. 1 mandated security of?cer rover position was vacant. On March 25, 2019, failed to meet the minimum security staffing requirements as follows: 11:50 P.M. (March 24, 2019) through 1:00 A.M. 2 mandated security officer rover positions were vacant; 1 1:00 AM. through 4:00 A.M. - mandated security of?cer rover position was vacant; 4:00 AM. through 5:00 AM. 3 mandated security of?cer rover positions were vacant; 5:00 AM. through 6:00 A.M. - 2 mandated security officer rover positions were vacant; 6:00 A.M. through 8:00 A.M. 1 mandated security of?cer rover position was vacant. On March 26, 201.9, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1 :50 PM. (March 25, 20191t11rough 1:00 AM. - 2 mandated security of?cer rover positions were vacant; 1:00 AM. through 4:00 AM. 1 mandated security of?cer rover position was vacant; 4:00 AM. through 5:30 AM. 3 mandated security of?cer rover positions were vacant; 5:30 AM. through 8:00 AM. - 2 mandated security officer rover positions were vacant. On March 27, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (March 26, 2019) through 12:30 AM. - 1 mandated security of?cer rover position was vacant; 4:00 AM. through 4:30 AM. 1 mandated security of?cer rover position was vacant; 4:30 AM. through 5:00 AM. 2 mandated security officer rover positions were vacant; 5:00 AM. through 5:30 AM. - 1 mandated security of?cer rover position was vacant; 6:00 AM. through 6:30 AM. 1 mandated security officer rover position was vacant. On March 28, 2019, faiied to meet the minimum security staf?ng requirements as foliows: 1 1 :50 RM. (March 27, 2019) through 04:00 AM. - 2 mandated security of?cer rover positions were vacant; 4:00 AM. through 5:00 AM. - 3 mandated security officer rover positions were vacant; 5:00 AM. through 8:00 AM. - 2 mandated security of?cer rover positions were vacant. On March 29, 2019, failed to meet the minimum security staffing requirements as follows: 1 1:50 P.M. (March 28, 2019) through 4:00 AM. 2 mandated security officer rover positions were vacant; 4:00 A.M. through 5:00 AM. - 3 mandated security of?cer rover positions were vacant; 5:00 A..M. through 8:00 AM. - 2 mandated security of?cer rover positions were vacant. On March 30, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (March 29: 2019) through 12:30 A.M. - 1 mandated security of?cer rover position was vacant; 12:30 AM. through 1:30 AM. - 2 mandated security of?cer rover positions were vacant; 1:30 A.M. through 2:00 AM. 1 mandated security officer rover position was vacant; 4:00 AM. through 4:30 A.M. 2 mandated security officer rover positions were vacant; 4:30 A.M. through 5:00 A.M. - 3 mandated security of?cer rover positions were vacant; 5:00 A.M.I through 5:30 A.M. 1 mandated security officer rover position was vacant; 5:30 A.M. through 7:00 A..M. - '2 mandated security of?cer rover positions were vacant; 7:00 AM. through 8:00 A.M. - 1 mandated security of?cer rover position was vacant. On March 31, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1:50 PM. (March 30, 2019) through 1:30 A.M. - 3 mandated security of?cer rover positions were vacant; 1:30 A.M. through 2:00 A.M. - 2 mandated security of?cer rover positions were vacant; 2:30 AM. through 5:00 A.M. 2 mandated security officer rover positions were vacant; 5:00 A.M. through 6:30 A.M. - 1 mandated security of?cer rover position was vacant. On April 1, 2019, failed to meet the minimum security staf?ng requirements as follows: 11:50 RM. (March 31, 2019) through 1:00 A.M. - 2 mandated security of?cer rover positions were vacant; 1:00 AM. through 4:00 A.M. - 1 mandated security of?cer rover position was vacant; 4:00 A.M. through 5:00 A.M. - 3 mandated security officer rover positions were vacant; 5:00 A.M. through 6:00 AM. - 2 mandated security officer rover positions were vacant; 6:00 AM. through 8:00 A.M. - 1 mandated security officer rover position was vacant. On April 2, 2019, failed to meet the minimum security staf?ng requirements as follows: 1 l:50 RM. (Aprii 1, 2019) through 1:00 AM. 2 mandated security of?cer rover positions were vacant; 1:00 AM. through 4:00 A.M. - mandated security of?cer rover position was vacant; 4:00 AM. through 5:30 A.M. - 2 mandated security officer rover positions were vacant; 5:30 A.M. through 6:00 A.M. - 3 mandated security of?cer rover positions were vacant; 6:00 A.M. through 8:00 AM. - 2 mandated security of?cer rover positions were vacant. On April 3, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 11:50 RM. (April 2, 2019) through 12:30 A.M. - 1 mandated security of?cer rover position was vacant; 1 4:00 A.M. through 4:30 A.M. I mandated security of?cer rover position was vacant; 4:30 AM. through 5:30 A.M. - 2 mandated security of?cer rover positions were vacant; 5:30 A.M. through 6:00 AM. 1 mandated security of?cer rover position was vacant; 6:00 A.M. through 6:30 AM. - 2 mandated security of?cer rover positions were vacant; 6:30 AM. through 7:00 AM. - 1 mandated security of?cer rover position was vacant; 7:30 A.M. through 8:00 A.M. - 1 mandated security of?cer rover position was vacant. On April 4, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1 :50 RM. (April 3, 2019) through 12:30 A.M. 2 mandated security of?cer rover positions were vacant; 12:30 A.M. through 2:00 A.M. - 1 mandated security of?cer rover position was vacant; 2:30 A.M. through 4:00 A.M.. 1 mandated security of?cer rover position was vacant; 4:00 through 4:30 AM. 2 mandated security of?cer rover positions were vacant; 5:00 AM. through 5:30 AM. 2 mandated security of?cer rover positions were vacant; 5:30 A.M. through 6:00 AM. - 1 mandated security of?cer rover position was vacant; 6:00 A.M. through 6:30 A.M. 2 mandated security of?cer rover positions were vacant; 6:30 A.M. through 7:00 AM. - i mandatedsecurity of?cer rover position was vacant; 7:30 AM. through 8:00 AM. - mandated security of?cer rover position was vacant. On April 5, 2019, failed to meet the minimum security staf?ng requirements as follows: 12:30 A.M. through 1:30 A.M. mandated security of?cer rover position was vacant; 4:00 A.M. through 4:30 AM. 2 mandated security of?cer rover positions were vacant; 4:30 AM. through 5:00 A.M. - 3 mandated security of?cer rover positions were vacant; 5:00 A.M. through 7:00 A.M. - 1 mandated security of?cer rover position was vacant. On April 6, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 11:50 RM. (April 5, 2019) through 1:001 A.M. 2 mandated security of?cer rover positions were vacant; 1:00 A.M. through 2:00 A.M. 1 mandated security of?cer rover position was vacant; 2:30 A.M. through 4:00 AM. - mandated security of?cer rover position was vacant; 4:00 A.M. through 6:00 A.M. - 2 mandated security of?cer rover positions were vacant; 6:00 AM. through 8:00 AM. - 1 mandated security of?cer rover position was vacant. On April 7, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1:50 PM. (April 6, 2019) through 12:30 AM. - 2 mandated security of?cer rover positions were vacant; 12:30 A.M. through 1:00 A.M. 1 mandated security of?cer rover position was vacant; 1:00 A.M. through 1:30 AM. - 2 mandated security of?cer rover positions were vacant; 1:30 A.M. through 2:00 AM. 1 mandated security of?cer rover positiOn was vacant; 2:30 A.M. through 3:30 AM. 3 mandated security of?cer rover positions were vacant; 3:30 A.M. through 4:00 A.M. - 2 mandated security of?cer rover positions were vacant; 4:00 AM. through 4:30 A.M. - 3 mandated security of?cer rover positions were vacant; 4:30 A.M. through 5:00 A.M. - 2 mandated security of?cer rover positions were vacant; 5:30 AM. through 6:00 AM. 1 mandated security of?cer rover position was vacant; 6:00 AM. through 6:30 AM. 2 mandated security of?cer rover positions were vacant; 7:00 AM. through 8:00 A.M. - 1 mandated security officer rover position was vacant. On April 8, 2019, failed to meet the minimum security staf?ng requirements as follows: 11:50 PM. (April 7, 2019) through 1:00 AM. - 2 mandated security of?cer rover positions were vacant; 1 :00 A.M. through 4:00 AM. mandated security of?cer rover position was vacant; 4:00 A.M. through 5:00 A.M. - 3 mandated security officer rover positions were vacant; 5:00 A.M. through 6:00 A.M. - 2 mandated security officer rover positions were vacant; 6:00 A.M. through 8:00 A.M. - 1 mandated security of?cer rover position was vacant. On April 9, 2019, failed to meet the minimum security staf?ng requirements as follows: 11:50 P.M. (April 8, 2019) through 1:00 AM. - 2 mandated security of?cer rover positions were vacant; 1:00 A.M. through 4:00 AM. - 1 mandated security officer rover position was vacant; 4:00 AM. through 5:00 A.M. - 3 mandated security of?cer rover positions were vacant; 5:00 A.M. through 5:30 AM. - 2 mandated security of?cer rover positions were vacantgi 5:30 A..M. through 6:00 A.M. - 3 mandated. security of?cer rover positions were vacant; 6:00 AM. through 8:00 AM. - 1 mandated sectirity of?cer rover position was vacant On April 10, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 11:50 RM. (April 9, 2019) through 4:00 A.M. 2 mandated security officer rover positions were vacant; 4:00 AM. through 5:00 A.M. - 3 mandated security of?cer rover positions were vacant; 5:00 A.M. through 8:00 AM. - 2 mandated security of?cer rover positions were vacant. On April I l, 20 9, MSP failed to meet the minimum security staf?ng requirements as follows: li:50 RM. (April 10, 2019) through 4:00 A.M. 2 mandated security officer rover positions were vacant; 4:00 AM. through 5:00 AM. 3 mandated security of?cer rover positions were vacant; 5:00 A.M. through 8:00 A.M. 2 mandated security of?cer rover positions were vacant. On April l2, 2019, failed to meet the minimum security staf?ng requirements as follows: i :50 RM. (April ll, 2019) through 12:30 A.M. 2 mandated security of?cer rover positions were vacant; 12:30 A.M.. through 2:00 A.M. mandated security officer rover position was vacant; 2:30 A.M. through 4:00 AM. - i mandated security officer rover position was vacant; 4:00 AM. through 4:30 A.M. 2 mandated security of?cer rover positions were vacant; 4:30 A.M. through 5:00 AM. - 3 mandated security of?cer rover positions were vacant; 5:00 AM. through 5:30 AM. 2 mandated security of?cer rover positions were vacant; 5:30 A.M. through 6:00 AM. mandated security officer rover position was vacant; 6:00 AM. through 6:30 A.M. - 2 mandated security officer rover positions were vacant; 6:30 AM. through 8:00 A.M. i mandated security officer rover position was vacant. On April 13, 2019, SP failed to meet the minimum security staffing requirements as follows: 11:50 RM. (April 12, 2019) through 1:00 A.M. 1 mandated security of?cer rover position was vacant; 2:30 A.M. through 4:00 A.M. - 1 mandated security of?cer rover position was vacant; 4:00 A.M. through 6:00 AM. 2 mandated security of?cer rover positions were vacant; 6:00 A.M. through 8:00 A.M. - 1 mandated security of?cer rover position was vacant. On April 14, 2019, faiied to meet the minimum security staf?ng requirements as foiiows: 11:50 RM. (Aprii 13, 2019) through 12:30 A.M. 3 mandated security of?cer rover positions were vacant; 12:30 A.M. through 1:30 A.M. 2 mandated security of?cer rover positions were vacant; 1:30 AM. through 2:00 AM. 1 mandated security of?cer rover position was vacant; 2:30 A.M. through 3:30 AM. - 3 mandated security of?cer rover positions were vacant; 3:30 A.M. through 4:30 AM. 2 mandated security of?cer rover positions were vacant; 4:30 AM. through 5:00 AM. - 1 mandated security of?cer rover position was vacant; 5:30 AM. through 6:30 A.M. 1 mandated security of?cer rover position was vacant; 7:00 AM. through 8:00 AM. - 1 mandated security of?cer rover position was vacant. On April 15, 20i9, MSP failed to meet the minimum security staf?ng requirements as foliows: I 1:50 RM. (April 14, 2019) through 12:30 A.M. 1 mandated security of?cer rover position was vacant; 4:00 AM. through 4:30 AM. - 1 mandated security of?cer rover position was vacant; 4:30 A.M.ithrough 5:00 AM. - 2 mandated security of?cer rover positions were vacant; 6:00 A.M. through 6:30 AM. 1 mandated security of?cer rover position was vacant. On April 16, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 11:50 P.M. (April 15, 2019) through 12:30 A.M. 1 mandated security of?cer rover position was vacant; 4:30 A.M. through 5:30 AM. - 1 mandated security of?cer rover position was vacant; 6:00 A.M. through 6:30 A.M. - 1 mandated security of?cer rover position was vacant. On April 17, 2019, failed to meet the minimum security staf?ng requirements as follows: 11:50 RM. (April 16, 2019) through 1:30 AM. - 1 mandated security of?cer rover position was vacant; 4:00 A.M. through 4:30 AM. - .1 mandated security of?cer rover position was vacant; 4:30 A.M through 5:00 AM. 2 mandated security of?cer rover positions were vacant; 5:00 A.M. through 6:00 A.M. mandated security of?cer rover position wasvacant; 6:00 AM. through 6:30 A.M. - 2 mandated security of?cer rover positions were vacant. On April 18, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 11:50 RM. (April 17, 2019) through 12:30 A.M. 1 mandated security of?cer rover position was vacant; 4:00 AM. through 4:30 AM. - 1 mandated security of?cer rover position was vacant; 4:30 AM. through 5:00 AM. - 2 mandated security of?cer rover positions were vacant; 5:00 AM. through 5:30 AM. 1 mandated security of?cer rover position was vacant; 6:00 A.M. through 6:30 A.M. 1 mandated security of?cer rover position was vacant. On April 19, 2019, failed to meet the minimum security staf?ng requirements as follows: 4:00 A.M. through 4:30 AM. 1 mandated security of?cer rover position was vacant; 4:30 A.M. through 5:00 A.M. 3 mandated security of?cer rover positions were Vacant. On April 20, 2019, failed to meet the minimum security staf?ng requirements as follows: 4:00 A.M. through 4:30 AM. - 2 mandated security of?cer rover positions were vacant; 4:30 AM. through 5:00 AM. 3 mandated security of?cer rover positions were vacant; 5:00 A.M. through 7:00 AM. - mandated security of?cer rover position was vacant. On April 21, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1:00 A.M. through 1:30 AM. mandated security of?cer rover position was vacant; 4:00 A.M. through 5:00 A.M. 1 mandated security of?cer rover position was vacant. On April 22, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (April 21, 2019) through 1:30 AM. - mandated security of?cer rover position was vacant; 4:00 AM. through 4:30 AM. 1 mandated security of?cer rover position was vacant; 4:30 A.M. through 5:00 AJM. - 2 mandated security of?cer rover positions were vacant; 5:00 A.M. through 6:00 AM. 1 mandated security of?cer rover position was vacant; 6:00 A.M. through 6:30 AM. - 2 mandated security of?cer rover positions were vacant. On April 23, 2019, failed to meet the minimum security staf?ng requirements as follows: 4:00 AM. through 4:30 AM. - 1 mandated security of?cer rover position was vacant; 4:30 A.M. through 5:00 A.M. - 3 mandated security of?cer rover positions were vacant. On April 24, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1 1 :50 PM (April 23, 2019) through 12:30 A.M. - mandated security of?cer rover position was vacant; 4:00 AM. through 4:30 AM. 1 [mandated security of?cer rover position was vacant; 4:30 AM. through 5:00 AM. - 2 mandated security of?cer rover positions were Vacant; 5:00 AM. through 5:30 AM. - mandated security of?cer rover position was vacant; 6:00 AM. through 6:30 A.M. 1 mandated security officer rover position was vacant. On April 25, 2019, failed to meet the minimum security staf?ng requirements as follows: 1 1:50 RM. (April 24, 2019) through 12:30 A.M. - 1 mandated security of?cer rover position was vacant; 1 4:00 AM. through 4:30 AM. 1 mandated security of?cer rover position was vacant; 4:30 AM. through 5:00 AM. - 2 mandated security of?cer rover positions were vacant; 5:00 AM. through 5:30 A.M. - 1 mandated security of?cer rover position was vacant; 6:00 AM. through 6:30 A.M. - 1 mandated security of?cer rover position was vacant. On April 26, 2019, failed to meet the minimum security staf?ng requirements as follows: 1, l. :50 RM. (April 25, 2019) through 12:30 A.M. - 1 mandated security officer rover position was vacant; 1 4:30 AM. through 5:30 AM. - 2 mandated security of?cer rover positions were vacant; 6:00 A.M. through 6:30 A.M. - 1 mandated security of?cer rover position was vacant. On April 27., 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 4:00 A.M. through 4:30 A.M. 1 mandated security of?cer rover position was vacant; 4:30 A.M. through 5:00 A.M. - 3 mandated security of?cer rover positions were vacant. On April 28, 2019, MSP failed to meet the minimum security staf?ng requirements as follows: 1:00 A.M. through 2:00 AM. - mandated security of?cer rover position was vacant; 2:30 A.M. through 3:30 A.M. - 1 mandated security of?cer rover position was vacant; 400 AM. through 4:30 A.M. 1 mandated security of?cer rover position was vacant; 4:30 A.M. through 5:00 2 mandated security of?cer rover positions were vacant. On December 18, 2018, OEC held one compliance conference with MSP regarding twenty~seven (27) business days wherein the minimum staf?ng requirements were not met and on June 14, 2019, OEC sent one warning letter to MSP regarding three (3) business days wherein the minimum staf?ng requirements were not met since Category 1 slot machine license was last renewed by the Board on January 10, 2018. MITIGATING AND REMEDIAL FACTORS While MSP recognizes that the facts set forth in the foregoing recitals constitute incidents where has failed to meet the Board?s minimum staf?ng requirements, MSP submits that all fixed security posts have been covered at all times. The failure to meet minimum staf?ng has been in rover positions on the overnight shift. These faiiures have stemmed from challenges in the recruitment, retention, and licensing of security employees, as explained below. in an effort to recruit additional security employees, has increased the starting wage for entry-level security officers from $9.50 per hour to {ii 1.50 per hour, and for grave shift officers to $15.00 per hour, to make the rates more competitive and to help staf?ng retention. has implemented a sign?on bonus program that monetarily rewards new security of?cers for remaining in the Security department. The program also rewards team members who transfer in to the department. MSP has also implemented anempioyee referral reward whereby employees who refer successful applicants receive monetary bonuses. has recruited, or attempted to recruit, from the Wilkes University Athletic Department; the Luzerne and Lackawanna Counties? Veteran Affairs offices; and Sears (which is closing a distribution center). has implemented a thrce~dayi expedited onboarding process for new security employees, including training in the form of shadowing experienced securityofticers. This allows new of?cers to receive expedited training. In addition, a mentoring program for security of?cers has been established to assist with identifying professional goals for security employees and to assist in meeting those goals. has also implemented longer shifts on the day and swing shifts to provide additional coverage and ?exibility while the drop takes place. Moreover, has created an Event Security position to attempt to provide greater ?exibility. Since the December 18, 2018 compliance conference, 78 viable applicants were identified; 58 were screened; 27 were'interviewed; 20 were extended officers; and 6 were hired. There were delays in licensing approval of some new hires. From September-November 2018 the average time to receive licensure approval for new hires was 12 days; however, the federal government shutdown in early 2019 interfered with tax clearance and as a result a number of new employees were not able to be approved for licensure Finally, the recent approval of petition forifloor recon?guration will free up security of?cers who can be redeployed to other locations. MSP, therefore, believes that it has remediated and mitigated all minimum staf?ng de?ciencies. TERMS OF AGREEMENT In consideration of the foregoing stipulated facts, and in full and ?nal settlement of any and all claims, causes or actions which could or might be brought under the Act or the regulations promulgated thereunder, whether against MSP, or any of its owners, employees or agents, arising out of the matters identi?ed in the above stipulated facts, the Parties do hereby further stipulate and agree that: 1. This Consent Agreement shall become final and effective only upon its approval by the Board; 2. MSP shall pay to the Board a civil penalty in the amount of one hundred and ?fty thousand ($150,000) dollars within ?ve days of the Board?s Order approving this consent agreement; 3. MSP shall pay to the Board two thousand, ?ve hundred dollars for the costs incurred by DEC, BIB and other related staff in connection with this matter within ?ve days of the Board?s Order approving this consent agreement; 4. shall immediately institute policies and procedures to prevent similar incidents from occurring in the future; 5. If approved, the Board may make information public with respect to the terms and conditions of this Consent Agreement; 6. This Consent Agreement may be set aside by the Board if any term herein is violated by and 7. MSP, through its authorized representatives whose signatures appear below, have read and fully understand the terms of this Consent Agreement. This Consent Agreement is offered and, if approved by the Board, entered for settlement purposes only. If the Board determines not to approve the effectiveness of same, then this Consent Agreement and the representations and obligations contained herein shall be null and void, and neither Party nor any other person shall be entitled to use or rely on any portion hereof for any purpose whatsoever or to admit any portion hereof into evidence in the captioned matter or any subseqoent proceeding. This Consent Agreement shall not preclude the Board, BIB or OEC from reviewing and considering any facts in any future proceeding relating to any application for licensure or qualification of the licensee. MSP expressly acknowledges and agrees that the Board reserves the right to take any actions that the Board, in its sole discretion, believes is necessary to protect the integrity of gaming in including the right to suSpend or revoke any license, approval or permit without limitation if any further violations occur or are subsequently discovered, all in accordance with the Act and?the regulations promulgated thereunder. The undersigned consent to the form and entry of the above. Gaming Control Board Office of Enforcement C0 use} VMVZ 8/2 3617 B: JOHN CROHEV ssistant Enforcement Counsel $125412 President and General Manager Mohegan Sun Pocono