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EH Investigations Administrative Action

Jun. 29 2017 — 12:09a.m.

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STATE OF NORTH DAKOTA NORTH DAKOTA PRIVATE INVESTIGATIVE AND SECURITY BOARD North Dakota Private Investigative and Security Board, COMPLAINT Petitioner, v. Jeremie Meisel and EH Investigations and Security, LLC, Respondents. TO: Jeremie Meisel and EH Investigations and Security, LLC, 5603 Copper Point, Bismarck, ND 58504 YOU ARE HEREBY REQUIRED to appear and defend against the Complaint in this action, which is herewith served, by serving upon the undersigned an Answer or other proper written response within twenty-one (21) days after service of this Complaint upon you, exclusive of the date of service. If you fail to do so, the allegations in the Complaint may be deemed admitted and the North Dakota Private Investigative and Security Board (Board) may enter an order in default as the facts and law warrant. The Board complains against Jeremie Meisel and EH Investigations and Security, LLC, and alleges as follows: 1. This is an administrative action pursuant to N.D.C.C. 43-30-12, 43-30-13, 43?30-45, and N.D.C.C. ch. 28?32.

2. N.D.C.C. ch. 43~30 creates the Board for the purpose of licensing and regulating individuals who provide private investigative and security services. N.D.C.C. 43?80-04. 3. Meisel is a licensed security provider in North Dakota holding license number 125. 4. Meisel is the responsible license holder for EH Investigations and Security, LLC, a licensed security agency in North Dakota holding license number 403. 5. The Board is authorized by N.D.C.C. 43-30-120) and ND. Admin. Code 93?02?03?05(6) to suspend or revoke a license, place any licensee on probationary status, or issue a letter of reprimand to any licensee for a violation of N.D.C.C. ch. 43-30 or the rules adopted by the Board. 6. In August of 2016 Meisel and EH Investigations were contacted by Leighton Security Services, Inc. to assist with providing security services in connection with the construction of the Dakota Access Pipeline in North Dakota. Leighton is a Texas foreign business corporation registered to do business in North Dakota. 7. Leighton is in the business of providing private security services. Leighton is not licensed or registered to provide private security Within the State of North Dakota. 8. Leighton employed personnel in North Dakota to provide private security services in connection with the Dakota Access Pipeline. Leighton employees included a project manager, two deputy project managers, three intel and three evidence technicians. None of these employees were properly licensed or registered to provide private security services in North Dakota.

9. Meisel and EH Investigations conspired with Leighton to assist Leighton in hiring and deploying within the State of North Dakota unlicensed or unregistered individuals to provide private investigative services in violation of North Dakota law. 10. Meisel and EH Investigations, during the fall of 2016, hired and deployed unlicensed or unregistered individuals to provide private investigative services in connection with the construction of the Dakota Access Pipeline Within the State of North Dakota. 11. As the license holders, Meisel at all times was responsible for directing and controlling all private security personnel registered under his license. During the fall of 2016 Meisel improperly relinquished this responsibility to Leighton in violation of North Dakota law. 12. Meisel and EH Investigations hired Richard Anderson to provide private security services within the State of North Dakota as part of the Dakota Access Pipeline. At the time that Meisel and EH Investigations deployed Richard Anderson he was not licensed or registered to provide security services. 13. Meisel and EH Investigations hired Jason Wentz and Chris Anderson to provide private security services within the State of North Dakota as part of the Dakota Access Pipeline. Meisel and EH Investigations deployed both Jason Wentz and Chris Anderson prior to either being licensed or registered to provide security services. 14. Meisel and EH Investigations hired Elizabeth Marlow, Merry Jenson and Kimberly Stuart to provide private security services within the State of North Dakota as part of the Dakota Access Pipeline. Meisel and EH Investigations deployed Marlow, Jenson and Stuart prior to any of them being licensed or registered to provide security services.

15. Meisel and EH Investigations have violated N.D.C.C. ch. 43-30 and the rules adopted by the Board. THEREFORE, the Board requests a hearing pursuant to N.D.C.C. 43-30?13 and N.D.C.C. ch. 28?32 and that an order be entered revoking the license and/or registration of Meisel and EH Investigations or taking other appropriate disciplinary action against them as allowed by law In addition, the Board requests that an order be entered pursuant to N.D.C.C. 43-30?12 requiring Meisel and EH Investigations to reimburse the Board for all costs of this action, including the amount paid by the Board for services from? the Of?ce of Administrative Hearings, attorney?s fees, court costs, Witness fees, staff time, and other expenses. Dated this day of February, 2017. BY: State Of North Dakota Wayne Stenehjern Attorney General Myif?? [if . 3?9, 5 rWWEf?g? geese at i tea as Monte L. Rogneby Special Assistant Attorney General US Bank Building 200 North 3rd Street, Suite 201 PO Box 2097 Bismarck, ND 58502?2097 Telephone: 701.25 8.7899 Email: [email protected] ATTORNEYS FOR THE NORTH DAKOTA PRIVATE INVESTIGATIVE AND SECURITY BOARD

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