Sheriff’s Elected Report for Commissioner’s Meeting on October 04, 2018

Approximately four months ago, Sheriff Office staff began a

comprehensive study of our brothel work card registration
procedures and a detailed 2017 brothel employee and prostitute
demographic analysis. It must be noted that our procedures have
not changed much since code language was adopted in 1971, and
to my knowledge, no such study or comprehensive report has ever
been conducted, prepared, or released to the commissioners or the
public. The Sheriff’s Office is prepared to present this report to the
Commissioners on Agenda during the next County Commissioner
meeting if requested. This report was developed due to the
enormous amount of public record requests my Office has received
over the past several months related to criminal histories and
prostitute registrations.

As a reminder for the people in audience today, Lyon County Code

requires all brothel employees to register with the Sheriff for a
work card specific to the brothel they are employed. The Sheriff's
Office is also required by code to conduct periodic inspections to
ensure compliance for brothel employee and prostitute registration.
In addition, these compliance checks ensure the medical
certifications for the prostitutes are up-to-date.

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As stated publically, the Sheriff’s Office does not, nor has it ever
had enough staff to routinely conduct adequate compliance checks,
which has been prevalent during both Sheriff Sid Smith and Sheriff
Allen Veil’s administration. And while a code mandates certain
Sheriff responsibilities, the reality is that legal brothels in Lyon
County have become a self-regulating industry.

Nonetheless, our study and analysis revealed that Sheriff Office

prostitute registration procedures, which span several decades,
were found inadequate. Before I detail revealed issues, I want to
point out that none of these issues are one-time or isolated events,
but multiple occurrences that were discovered during the 2017
review.

The issues include US immigration law violations, foreign country

human trafficking indicators, fraudulent statements, issuance of
work cards prior to completing criminal history background
checks, inability to validate out-of-state and US and other foreign
national documents determine identity, and clerical staff
processing these application who do not have the required
knowledge and skills to conduct the mandated background checks..
Corrective procedures are being developed and implemented to
better align with Lyon County Code as it relates to work card

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registration.

Yesterday, October 3, 2018, the Lyon County Sheriff's Office with

the assistance of US Immigration and Customs Enforcement (ICE)
agents and Homeland Security Investigators (HSI) agents from the
Department of Homeland Security conducted a series of prostitute
work card compliance checks of prostitutes who obtained work
cards contrary to Lyon County Code and are in violation of United
States immigration law for the following Mound House brothels:
Bunny Ranch, Kit Kat Ranch, and the Love Ranch.

At this time, only the following acts of federal investigation will be

released to illustrate our challenges. One specific prostitute target
used her Canadian passport as part of her application, which
flagged her as illegal in the US to work as a prostitute under
federal law. During the on-scene interview process ICE was able to
determine she was granted US citizenship by the US State
Department, which could only be verified with a telephone call
with State Department staff. Another female target had left Lyon
County two days earlier. Her out-of-county location is known and
she will be picked up shortly. There was a third target initially
identified, but we determined she was no longer at any of the
brothels.

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In addition, LCSO staff gathered 19 expired work cards from the
three brothels. Furthermore, our staff is attempting to work with
brothel staff in an effort to improve procedures to align with
County Code.

However, the discovery of US immigration law violations and

possible acts of international human trafficking into a legal brothel
system is extremely alarming. The ability to coerce, exploit and
traffic non-US citizens into Lyon County by foreign criminal
enterprises is going to be difficult to detect and deter by our limited
capabilities and resources during background checks of foreign
born applicants, especially now that we must work with three
federal agencies to combat human trafficking efforts into Lyon
County. It is projected that a qualified and trained full-time clerk
needs to replace the part-time Dayton clerk to process all
applications, and our Investigations Bureau will need to be initially
increased by one detective to become part of a regional sex
trafficking task force on a ½ time basis until more work load data
is obtained in order to determine if the position warrants a full-time
work-load.

Before I continue, I do want to add that we do not believe Mr. Hof

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or any of his staff are knowingly engaged in international human
trafficking, but foreign criminal enterprises exploit vulnerabilities
and weaknesses in US systems and laws to generate profit. This
investigation has revealed several exploitable vulnerabilities in
county, state, and federal laws.

As a note, any female prostitute removed in Lyon County by

federal agents would be interviewed by a qualified linguist of their
country of origin to determine if they have been trafficked into the
US. Any women claiming to have been sex trafficked into the US
will receive victim support services under the Asylum program,
not arrest and deportation.

This is first time we applied a task force of multiply agencies for a

work card compliance check. While we already use this approach
quite successfully to conduct compliance checks in other law
enforcement areas, and we will give serious consideration to using
this approach with future brothel compliance checks. In addition, I
want to thank the US Immigration and Custom Enforcement and
Homeland Security Investigators from the Department of
Homeland Security for their hard work and assistance.

In closing, to repeat myself again, we are prepared to present the

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2017 Brothel Work Card Demographic and Analysis Report, that
led up to yesterday’s actions if requested, but that report will not
include any information of on-going investigations.

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