With the revelation that Bulletproof Security, Inc.had been operating illegally in Wisconsin, attorney Stella filed complaints today with the Iron County district attorney and the Wisconsin Department of Safety and Professional Services. He also chides DA Lipske for apparent intended lenience toward Bulletproof.
Letter to Iron County District Attorney from ANTHONY J. STELLA, JR. -Attorney at Law- P.O. Box 296 Hurley, WI 54534 Phone: 906-364-2255 Email: firstname.lastname@example.org
July 11, 2013
TO: Martin Lipske, District Attorney 300 Taconite Street, Hurley, WI 54534
Dear Mr. Lipske:
Attached is a letter I submitted to the Wisconsin Dept. of Safety and Professional
Services today. You are aware of the situation, as reported in the newspapers.
Although the State has the authority to refuse to issue licenses or permits, you have the
authority to obtain criminal convictions which insure that the company is not allowed to
continue to work in Wisconsin.
As you can see by the attached letter, the violations are numerous. The criminal statute is
clear, and does not require intent. Anyone caught driving or hunting without a license or
insurance would be expected to pay a fine. This is a much more serious situation,
involving private security persons armed with assault weapons, showing lack of
knowledge or respect for state laws regulating their licensing and their use of weapons.
It is fortunate that a serious incident did not result -- it was extremely fortunate for
Bulletproof Securities and GTAC from a liability standpoint.
The Milwaukee Journal Sentinel quoted you as saying you would “take into account the
fact that the security services were being voluntarily suspended,” when deciding whether
to issue charges. If that is true, that is ridiculous. There is nothing voluntary about
discontinuing undisputed violations of a criminal statute. The statement suggests the
company had a choice to continue in violation of state laws, even while the newspapers
and other media were reporting the failure to be in compliance. It’s sort of like
suggesting an embezzler get leniency because he “voluntarily” agreed to stop stealing
after he was caught. Furthermore, GTAC’s press release indicates the company was
directed to “stand down” by GTAC, so it’s hard to see how Bulletproof Securities’
actions were in any way voluntary on their part.
Iron County faces a long road ahead with the division over the mining issues. You have
sent a message already to those who would intimidate workers and damage property at
the mine site. Large, out-of-state corporations intending to do business in Iron County
should also be sent the early message that they will be expected to play by the rules, and
will not be given breaks for violations after the fact. GTAC and its contractors cannot be
allowed to claim ignorance at the outset, as much is expected of them with regard to
compliance with a myriad of public safety, environmental and mining regulations in the
future. A mere slap on the hand sends the wrong message.
In the event you consider any agreement to withhold or dismiss charges in this matter, it
will hopefully include provisions to prevent Bulletproof Securities, Inc. from operating in
Iron County in the future.
Anthony J. Stella, Jr.
Letter to Wisconsin Department of Safety and Professional Services
ANTHONY J. STELLA, JR. -Attorney at Law- P.O. Box 296 Hurley, WI 54534 Phone: 906-364-2255 Email: email@example.com
July 11, 2013
Wisconsin Department of Safety and Professional Services P.O. Box 8935 Madison, WI 53708-8935
Sent VIA FAX #608-266-2264
RE: Anticipated Application of Bulletproof Securities, Inc. of Scottsdale Arizona to be Licensed as a Private Detective Agency Employing Security Personnel in the State of Wisconsin
It has come to my attention that Bulletproof Securities, Inc. will be seeking a license to
operate in the State of Wisconsin as a private detective agency pursuant to Section 440.26
Wis. Stats. It is the apparent intent of Bulletproof Securities to employ private security
personnel in Wisconsin.
It is my understanding that in order to provide private security services, the company
must obtain a private detective agency license pursuant to Section 440.26(2)(a)1. Further,
any employees working for Bulletproof as private security personnel must receive a
private security permit under Section 440.26(5m).
It has been widely reported in state and local newspapers that Bulletproof Securities, Inc.
has employed private security personnel at the site of the proposed Gogebic Taconite, Inc.
(GTAC) iron mine in Iron County since July 4th. The personnel have patrolled a
wooded area in the vicinity of drilling sites dressed in camouflaged clothing with their
faces concealed, while carrying semi-automatic weapons. Both GTAC and Bulletproof
have admitted this. Several photos confirm the activity.
I am informed, and both GTAC and Bulletproof have apparently confirmed, that no
Wisconsin-issued licenses or permits exist for either Bulletproof Securities or any of its
According to Section 440.26(8), “Any person, acting as a private detective, investigator
or private security person, or who employs any person who solicits, advertises or
performs services in this state as a private detective or private security person, or
investigator or special investigator, without having procured the license or permit
required by this section, may be fined not less than $100 nor more than $500 or
imprisoned not less than 3 months nor more than 6 months or both.”
It is clear, therefore, that both Bulletproof Securities, Inc. and its individual employees
have committed criminal offenses punishable by fines and jail. The statute also provides
that if they were to be convicted, they would be disqualified from holding the necessary
licenses and permits. Thus, it is clear that if the district attorney were to obtain
convictions, the corporation and its employees would, as a matter of law, be disqualified
from working in Wisconsin. It remains to be seen what will happen in this regard.
However, according to Wisconsin Administrative Code Rule SPS 31.05, any applications
for permits or licenses as describe above may be denied if the applicant’s conduct is
grounds for discipline under Rule 35.01.
Rule 35.01(2) provides grounds for discipline for anyone: “Violating, or aiding or
abetting the violation of, any law the circumstances of which substantially relate to the
practice of a private detective or private security person.” This section does not appear to
require a conviction. The violation, in this case, by both Bulletproof and its employees is
clear and has been admitted.
Rule 35.01(4m) says it is a violation and therefore grounds for discipline for “failing to
have on his or her person a private security permit while on duty as a private security
person and, if carrying a firearm on, about or near his or her person while on duty, failing
to have on his or her person the firearms permit issued by the department.”
Section 35.01(13) states it is a violation to assign “any person to perform private
detective or security personnel duties who has not been issued a license or permit prior to
performing the services or who has not properly notified the department of an
employment transfer pursuant to Section 32.05.
Section 35.01(19) specifically makes it a violation to practice without a current
Each of the above Administrative Rules has been violated, and is therefore grounds to
deny issuance of a license to Bulletproof Securities, or permits for the offending
Additionally, I believe the following other rules have been violated. Pursuant to Section
35.01(9), violation of any of these rules constitutes grounds for discipline of a license or
permit holder, and hence, grounds for denial of a license or permit pursuant to Rule
Section 33.025 states: “A private security person shall have on his or her person while on
duty as a private security person the private security permit issued to him or her by the
department and, if carrying a firearm, the firearms permit issued to him or her by the
Section 33.03 Requires name tags which must be clearly visible to the public at all times.
I do not know if name tags were present, but if they were, clearly the intent was that the
persons themselves would not even be seen.
Section 33.02 states: “A private security person holding a permit shall wear a uniform
while on duty.” Section 30.01(14) defines uniform as “any clothing, badge, patch or
lettering which clearly identifies to the public a person being a security guard.” (emphasis
The violation of this last rule is perhaps the most distressing. The clear intent of the law
is to give the public notice that those who carry guns and attempt to exert authority be
easily recognized as persons of authority. It would not be unreasonable for a citizen to
act in fear and refuse to obey, and perhaps even draw a weapon, on a person appearing
from within the woods dressed in full camouflaged gear with his face covered,
brandishing what looks like a military weapon. The intent of the law is to provide for
visibility and deterrence -- not stealth, deception and fear. There are many possible
results to being approached in the woods by someone dressed like the Bulletproof
employees were, and a lot of them aren’t good.
I cannot overstate the significance of the clothing and weapons displayed, because, as was
clearly admitted by GTAC, these soldier-look-alikes were not confining their activities to
providing necessary safety. When asked why they wore the camouflaged gear, GTAC’s
spokesperson Bob Seitz said, “These people aren’t supposed to be seen. This is probably
the first time that visitors from the Harvest Camp have spotted them.” It is clear from this
statement that the public was not supposed to even see, let alone perceive the outfits worn
as uniforms of security personnel, regardless of whether there might have been small
company patches on them. Mr. Seitz’s statements also indicate the primary purpose
wasn’t to deter persons from advancing on property or employees; rather, it was to gather
intelligence. The Harvest Camp is a group of mostly Native American tribal members
camping in the area. Mr. Seitz indicated it was the job of the security personnel to
conduct surveillance of camps in the area.
SPS 34.01(1) states: “No owner or employee of an agency may carry on, about or near
their person any firearm unless all of the following apply:
(a) The circumstances or conditions of the owner's or employee's assignment as a private
security person give rise to a substantial need for being armed.” (other requirements
follow this provision)
It is clear that semi-automatic weapons were not appropriate for stealth surveillance,
where their presence would only serve to scare or provoke, and there were no clients or
property to protect, and no impending threats. Secretly scouting the woods with guns
near campsites and spying on others while dressed in camo gear is clearly not a private
security detail giving rise to a substantial need for being armed. Any need for firearms in
that situation would have been precipitated by the Bulletproof employees’ own
provocative actions, rather than the need to protect the client or its property. The law
seeks to discourage the display of guns in a manner which is likely to provoke problems
rather than prevent them. It does not allow the use of guns for intelligence gathering
purposes. The activity of carrying the guns was, in any event, a clear violation of
34.01(1)(c) mandating that firearms cannot be carried without a permit issued under Rule
34.015. (Emphasis added) Furthermore, even if a temporary private security permit were to be issued, it
could not allow for carrying firearms.
There are numerous other rules violations, but these are more than sufficient to deny any
licenses or permits. The department should use its discretion to deny all permits and
licenses. As I indicated above, should the Iron County District Attorney use his
discretion to seek criminal convictions, which are clearly warranted under the facts, then
the department will not even have the discretion to issue a license or permits. By copy of
this letter I am apprising Iron County District Attorney Martin Lipske of this matter. I
would hope that any agreement to withhold prosecution in this matter would contain a
condition that Bulletproof and its employees be banned from further activities in
Wisconsin. Those who seek to enforce the law should be held to abide by it.
It stands to reason that if this company and its employees did not read the laws and rules
requiring licenses and permits, they did not read the laws and rules regarding lawful use
of firearms in Wisconsin, along with the rules regulating clothing, I.D.’s, badges,
insurance requirements, etc. GTAC’s spokesperson Bob Seitz was quoted in the
Milwaukee Journal Sentinel as saying “This isn’t normal for any of us, I guess,” when
trying to explain how they were unaware of the permits needed. It should be routine for a
company that does this for a living. It is inexcusable AND criminal that Bulletproof
Securities, Inc. came into Wisconsin without any licenses or permits and broke several
laws and administrative rules while in the process of intimidating local residents with
over-the-top displays of killing capacity.
In explaining its advantage over local law enforcement, the company’s website brags, “In
addition, we have the ability to dress in any fashion with any type of weapon system
made. We have superior equipment and vehicles and are not limited to department
policies and procedures.”
In Wisconsin, they DON’T have the option to “dress in any fashion,” nor to use “any
weapon system made.” And in Iron County, we prefer our law enforcement personnel to
follow “policies and procedures.”
I therefore respectfully request that the Department deny any licenses or permits to
Bulletproof Securities, Inc. and its offending employees. I do not believe any of the
pertinent facts are in dispute, and most of what I have set forth is easily confirmed with
photos, media accounts, and direct admissions by GTAC and Bulletproof Securities,
including a written letter signed by GTAC president Bill Williams.
Anthony J. Stella, Jr
Copy: District Attorney Martin Lipske