LICENSE APPI;'lr:ATION DISAPPROVED
PD 616-121A (R., YJy"
LICENSE DIVISION
ADMINISTRATIVE APPEAL UNIT
1 POLICE PLAZA- Room 110
New York, NY 10038
1-646 610 5873
Mr. Robert Reynolds
IDATE:
New York, NY
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NOTICE OF DISAPPROVAL
Dear Applicant:
Your application for a Handgun License has been DISAPPROVED for the following reasons:
Your application for an unrestricted carry handgun license failed to meet the requirements to show ''proper cause" pursuant to 400.00
(2) (t) of the NYCS Penal Law.
In your letter you state that you travel/buy/sell tactical items that need to be properly safeguarded at all times. With this type of
assertion, the Rules of the City Of New York 5-03(a) require you to provide documentary proof that your business actually requires
you to routinely engage in cash or other transactions that expose you to extraordinary danger.
•
•
•
•
•
You have not demonstrated a special need for self-protection distinguishable from that of the general community or of
persons engaged in the same profession which is required for a license to carry a concealed firearm in public.
You did not provide any contracts with current or potential clients with whom you conduct business with as required.
You have not shown you have made any sales nor received any payments for any products.
You do not have cash or products on hand ready for sale.
You have not provided any substantial proof that would substantiate your claim of carrying any products for
demonstrations on a routine basis.
Your application is DISAPPROVED for a CARRY BUSINESS license at this time. Title 38 OF THE RULES OF THE CIRY OF NEW YORK
§5-10 AND New York State Penal Law section 400.00(2) (f) were taken into consideration when making the determination for the
DISAPPROVAL of this CARRY BUSINESS license.
To appeal this decision, the applicant must submit a sworn statement setting forth the grounds for the appeal and shall
contain the following statement to be signed by the applicant in the presence of a Notary Public:
"Under penalty of perjury deponent being duly sworn, says that he/she is familiar with all of the statements
contained herein and that each of these statements are true, and no pertinent facts have been omitted."
Appeals that are unsworn by applicant or submitted by individuals or business entities other than the applicant
(or applicanfs attorney who's duly licensed to practice in New York State} will not be accepted. Appeals must be
forwarded to the Director of the license Division within (30) days of the date of this notice.
Mark Envelope- ATTENTION: APPEAL UNIT
By direction of
7JfAndrew
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Inspector
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REASONS FOR NYPD CARRY BUSINESS LICENSE DENIAL & MY REBUTTAL
Company: Cavalier Knight LLC.
Tactical Equipment, Ballistic Threat Management, Licensed Firearms Dealer FFL 01.
Member Business: NRA Business Alliance, National Shooting Sports Foundation
(Retailer), New York State Sheriff's Association (Business).
Memberships Civilian: FBI New York Metro InfraGard (Intelligence), Fraternal
Order of Police DC Lodge No.1 (Associate), New York State Rifle & Pistol Association,
NYC OEM - C.E.R.T., NYPD - Police Square Club (Masonic), NYPD Operation Nexus
(Anti-Terrorism), NYPD SHIELD (Anti-Terrorism).
Licenses & Permits: NYPD Premise License, NYPD Rifle Shotgun Permit,
Connecticut, Florida, Maine, Utah CCW's, FFL 01 & C&R 03.
1: APPLIED: November 26, 2013
2: INTERVIEWED: February 11, 2014
3: DENIAL DATE: June 13, 2013
4: POST MARKED: July 08, 2014
5: RECEIVED: July 09, 2014
Total: 6 months, 19 days to process
1: You have not demonstrated a special need for self-protection
distinguishable from that of the general community or of persons engaged
in the same profession which is required for a license to carry a concealed
firearm in public.
SCOTUS: The State Has No Duty To Protect. DeShaney v. Winnebago County
Department of Social Services (No. 87-154) LINK: Cornell University Law
But nothing in the language of the Due Process Clause itself requires the
State to protect the life, liberty, and property of its citizens against invasion
by private actors. The Clause is phrased as a limitation on the State's power
to act, not as a guarantee of certain minimal levels of safety and security.
NY Civil Rights-Article 2 - § 4 Right to Keep and Bear Arms LINK: New York
§ 4. Right to keep and bear arms. A well regulated militia being necessary
to the security of a free state, the right of the people to keep and bear arms
cannot be infringed.
I travel with Level III hard body armor & tactical equipment for law
enforcement demonstrations throughout the country. The BATFE June 2014 FFL 01
list has about 35 FFL 01’s in New York City. Did the NYPD contact each one to
determine if they all sell firearms, tactical equipment as well as travel throughout the
country with body armor for law enforcement? This armor is manufactured by one
company based in California. It is non-ceramic and not Kevlar. It is not available in
stores and it cannot be purchased directly online. It can only be acquired directly
from the manufacturer through an authorized representative. Cavalier Knight is the
only company in the State of New York that has been granted such authorization.
So protecting tactical law enforcement equipment is not in the interest of public
safety or crime prevention? How many FFL 01’s in New York City have demonstrated
a special need for self-protection distinguishable from that of the general
community or of persons engaged in the same profession which is required
for a license to carry a concealed firearm in public? Were all FFL 01’s denied?
Mr. Robert Reynolds | Cavalier Knight LLC | Cell:
| Bus: (646) 580-7801
mrreynolds@cavalierknight.com | www.cavalierknight.com
As a partner of the NYPD Operation Nexus network their mission statement:
“The New York City Police Department’s Operation Nexus is a nationwide network of
businesses and enterprises joined in an effort to prevent another terrorist attack
against our citizens. Our detectives have conducted over 25,000 visits to firms that
have joined us in this mutual effort. Members of Operation Nexus are committed to
reporting suspicious business encounters that they believe may have possible links
to terrorism.
The NYPD believes terrorists may portray themselves as legitimate customers in
order to purchase or lease certain materials or equipment, or to undergo certain
formalized training to acquire important skills or licenses. There is also a concern
that these individuals may simply steal certain types of vehicles, equipment
or materials from the inventory of legitimate businesses. Whatever the
method, once appropriated these items could then be used to facilitate a terrorist
plot.
Through Operation Nexus, the NYPD actively encourages business owners, operators
and their employees to apply their particular business and industry knowledge and
experience against each customer transaction or encounter to discern anything
unusual or suspicious and to report such instances to authorities.
If you agree to join the Operation Nexus network, one of our detectives will explain
why certain types of businesses may be attractive to a terrorist operative and provide
a list of indicators specifically tailored to that business to use as a reference. Once
visited, these businesses receive a framed certificate and become participants in the
NYPD “Operation Nexus Network” to serve as a first alert mechanism to help protect
New York City against the threat of another terror attack. It is important to note that
participation in this network is not limited to New York City businesses.
Terrorist attacks do not occur in a vacuum. They require planning and preparation,
such as the acquisition of certain materials or training in targeted activities. Terrorist
operatives will try to obtain these in the private sector, from businesses both
inside and outside of New York City’s geographic boundaries. Moreover, their
approach to a business will vary, from entering a store and standing directly in front
of a customer-service counter to making an electronic purchase over the Internet at
a company’s website”. http://www.nypdshield.org/public/nexus.aspx
I was contacted several times by different individuals who were attempting to
purchase “Barrett 50 caliber rifles” as my company Cavalier Knight LLC has an FFL01.
As a partner of the NYPD Operation Nexus Network and at that time I was still the
Chair of the Community Board 12 Public Safety Committee. I immediately reached out to Chief Philip Banks, III and Lt. Mario Rivera of the “Intelligence Division”. They
had Detectives from the Intelligence Division expeditiously meet with me to take
official reports of each occurrence.
I have shared information with NYPD Operation Nexus that may lead to
terrorist activity within New York City. My residence is my business address and is
listed publicly within the list of FFL holders on the BATFE website. It doesn’t take
much effort to ascertain my location. Criminals may assume that I am armed at my
residence and wait to approach me outside of my home.
Page 2 of 6
Mr. Robert Reynolds | Cavalier Knight LLC | Cell:
| Bus: (646) 580-7801
mrreynolds@cavalierknight.com | www.cavalierknight.com
Based upon my relationship with the NYPD these individuals would probably
not threaten me beforehand and seek to harm me at a time more suitable to their
success. A sensible thinking person can see that as a potential primary witness the
danger to my well-being does exist. Necessitating a need for an unrestricted carry
business license. As they request that I personally inform them of threats then deny
me the ability to protect myself from retaliation.
§ Section 5-03(a): Carry and Special Handgun Licenses. (a) Exposure of the
applicant by reason of employment or business necessity to extraordinary
personal danger requiring authorization to carry a handgun.
2: You did not provide any contracts with current or potential clients with
whom you conduct business with as required.
I am a third party sales vendor for this body armor so any contracts would be
between the actual manufacturer of the armor and the law enforcement agency. The
NYPD is the primary municipal police department in New York City. Does this mean
that if they do not utilize me as a vendor; I am permanently barred from receiving a
Carry Business License? Is this under statute of law or internal department policy?
3: You have not shown you have made any sales nor received any
payments for any products.
I refer to response (2). I have to travel to demonstrate the product before it
can be considered for purchase. There are 23,655 law enforcement departments that
I am currently aware of. This requires that I travel to potential clients. A law
enforcement vendor can take over a year or more to obtain a contract based on
departmental budgets. Although I have received a response letter from the NYPD
Deputy Commissioner of the Department of Legal Matters dated January 21, 2014.
Which states that my body armor proposal is under review which I sent to my
investigator. Obviously their interest doesn’t count.
TOTAL
53
94
220
268
311
397
Departments \ Agencies
Conservation Law Enforcement
Railroad Law Enforcement
Bureau of Indian Affairs/Tribal
State Criminal Investigation
Airport & Harbor Police
Military Agencies-Installations
TOTAL
1,110
1,026
2,021
5,806
12,349
23,655
Departments \ Agencies
Homeland Security
State Police/Highway Patrols
Federal Law Enforcement
County Law Enforcement
Municipal Law Enforcement
TOTAL
4: You do not have cash or products on hand ready for sale.
During my interview I stated that I did not transport cash. How does the
License Division know what products / inventory I have on hand? Once again did they
compare what products are on hand at all of the other persons engaged in the
same profession in New York City or just arbitrarily make another determination?
5: You have not provided any substantial proof that would substantiate
your claim of carrying any products for demonstrations on a routine basis.
Page 3 of 6
Mr. Robert Reynolds | Cavalier Knight LLC | Cell:
| Bus: (646) 580-7801
mrreynolds@cavalierknight.com | www.cavalierknight.com
N.Y. PEN. LAW § 400.00 Licenses to carry, possess, repair and dispose of
firearms. 2. (f) have and carry concealed, without regard to employment or
place of possession, by any person when proper cause exists for the
issuance thereof;
On June 01, 2012 I met with the Chief of NYPD Community Affairs, Phillip
Banks, III at 1 Police Plaza to discuss matters of public safety. I brought with me one
ballistic armor shield. At my request Chief Philip Banks, III initiated the process which
enabled me to later meet with a representative of the NYPD Emergency Service Unit
to allow them to review the body armor for possible use by ESU.
I have an email from Deputy Chief James G. Molloy, Commanding Officer
NYPD Emergency Service Unit dated July 11, 2012 which states:
Mr. Reynolds
Deputy Commissioner Banks had previously forwarded to me the
information pertaining to your product. The Emergency Service Unit has
asked permission to meet with you regarding (through department
channels). Once permission is granted we will reach out to you. Sorry for
the inconvenience, but I am sure you understand the need to follow
established protocols. I hope we will be able to discuss your product in the
near future. Thank you, James G. Molloy, Deputy Chief Commanding Officer
NYPD Emergency Service Unit
On or about August 09, 2012 I met with Lt. Michael J. McGuiness, Special
Projects Coordinator for the NYPD ESU at the NYPD Police Academy. I travelled from
my residence with several Level III tactical ballistic plates and one Level III tactical
ballistic shield as well as a ballistic laptop bag. I do not own a vehicle. I had no
manner in which to safe guard these restricted items. I then had to return with all of
this equipment with no way to secure it. Should I wear my armor?
I have an email from Lt. Michael J. McGuiness, Special Projects Coordinator
ESU dated August 15, 2012 which states:
Mr. Reynolds,
Just wanted to drop you a note and say thank you for taking the time to
meet with me last week. It was nice meeting you and seeing the product
line you represent. Best Regards. Lieutenant Michael J. McGuinness.
On February 11, 2014 I appeared at 1 Police Plaza to meet with my
investigator. My investigator P.O. Ochetal asked his supervisor Associate Investigator
II, Mrs. Michelle Gilliam to speak with me.
The current reasons listed in the denial were all discussed during my initial
investigation. I explained each situation in intricate detail. If my application had
missing documents why would they accept an incomplete application? Why didn’t
they contact me to request further documentation? Associate Investigator II, Mrs.
Michelle Gilliam only asked me to provide one final document.
Page 4 of 6
Mr. Robert Reynolds | Cavalier Knight LLC | Cell:
| Bus: (646) 580-7801
mrreynolds@cavalierknight.com | www.cavalierknight.com
She requested that I get a letter from Chief Philip Banks, III who is now Chief
of Department. This letter should “validate” that I possess and have travelled in
New York City with body armor to present it to the NYPD Emergency Service Unit and
the potential for theft of this body armor by criminals presents a danger to public
safety.
This letter should "verify" that I met with Chief Philip Banks, III at 1 Police
Plaza on June 01, 2012 and at my request he approved and initiated the process
which later enabled me to meet with Lt. Michael J. McGuinness, Special Projects
Coordinator ESU. I wrote several letters asking Chief Philip Banks, III or NYPD ESU
to verify this meeting. What other licensee has to get an endorsement for a Carry
Business License from the NYPD Chief of Department or the Emergency Service Unit?
This is arbitrary, capricious and shocking to one’s sense of fairness.
I have an email response which I received from Sgt. Freer Office of the Chief
of Department dated March 12, 2014 which states:
Mr. Reynolds
I received a copy of the additional documentation you sent to PO Gonzalez,
unfortunately that is just a form letter legal sends out to any interested
vendor. It does not convey any standing.
I will contact ESU next week to follow-up, however I am not optimistic that
a one-time meeting that did not result in any purchasing commitments will
generate any sort of standing to justify a permit. I read your letter to the
Chief in detail, and completely understand your concerns, however without
an actual business sales relationship with the City I don’t know if we will be
able to help justify the request.
I know you have been more than patient, so I will check as soon as possible
and let you know either way. Thank you for understanding. Sergeant Joseph
C. Freer Office of the Chief of Department
Although I am enrolled as a vendor for the City of New York for 42 Mayoral
Agencies and several other Non-Mayoral Agencies (Vendor #:
). The
NYPD has implied that doing business with the city is a prerequisite for obtaining a
Carry Business License. I should not be required to have business contracts with the
City of New York to be granted a Carry Business License. I cannot find a penal law
statute to support this arbitrary requirement for a Carry Business License.
I wrote three different letters mailed USPS Priority Mail and cc’d to senior
members of the NYPD including the License Division. Politely requesting this
validation letter of my meeting with the NYPD Emergency Service Unit. To date the
NYPD has not responded to any of my requests for verification.
What form of documentation exists that validates where I went and exactly
what I did when I was there? Why would the NYPD request that I provide some
documented verification of my business travels with body armor after I already met
with their own NYPD Emergency Service Unit to demonstrate the armor as I stated?
Page 5 of 6
Mr. Robert Reynolds | Cavalier Knight LLC | Cell:
| Bus: (646) 580-7801
mrreynolds@cavalierknight.com | www.cavalierknight.com
If the NYPD refuses to verify in writing that I met with the NYPD Emergency
Service Unit how can they arbitrarily ask me to obtain the same such verification
from any other law enforcement department or agency? Then state that meeting with
the NYPD does not justify issuance. Then what law enforcement department
specifically would I have to meet with? Why didn’t they verify this meeting internally?
I have included two response letters from NYPD Legal Matters in regards to
requesting them to review the body armor. The first is dated September 06, 2011
the second is dated January 21, 2014. The NYPD did not review the armor until
August 09, 2012, that’s approximately 11 months and 4 days from their first
response letter.
Although I have not established a contract with the NYPD. This proves that
acquiring a possible contract from a municipal agency takes a great deal of time to
achieve. It can’t be predicted when agencies will be ready to test and evaluate a
potential vendor’s product and there is no commitment to purchase.
I have 30 days to file an appeal. The letter is dated June 13, 2014 but the
envelope is post marked July 08, 2014. I received it July 09, 2014. That means
that 27 of my 30 days to appeal has lapsed while my letter sat at 1 Police Plaza. All
of the people I contacted for verification are listed below. Thank you.
William J. Bratton
Commissioner
NYC Police Department
John J. Miller
Deputy Commissioner
NYC Police Department
Philip Banks, III
Chief of Department
NYC Police Department
Thomas Galati
Chief
NYC Police Department
Harry J. Wedin
Assistant Chief
CO of SO Bureau
NYC Police Department
Andrew Lunetta
CO License Division
NYC Police Department
Lt. Michael J. McGuinness
SP Coordinator
NYC Police Department
Emergency Service Unit
Page 6 of 6
POLICE DEPARTMENT
NEW YORK, N.Y. 10038
S. ANDREW SCHAFFER
DEPUTY COMMI SSIONER, LEGAL MATTERS
September 6, 2011
Robert Reynolds
Cavalier Knight
New York, NY
Dear Mr. Reynolds:
The New York City Police Department appreciates your interest in doing business with the
City ofNew York. However, the Department is prohibited from endorsing or referring
particular products or services.
We recommend that you check the City Record On-Line (CROL) http://a856intemet.nyc.gov/nycvendoronline/home.html for future procurement opportunities. The
CROL is the electronic version of the Procurement Notices appearing in The City Record
printed version. The web site includes the following:
A fully searchable database of current awards and solicitations. Users can search
with a variety of criteria, such as due date, publish date, agency, procurement
category, commodity codes, and keywords (this database and search function has
replaced all the Asolicitations and awards@ pdf documents).
Online registration to receive emails when a solicitation of interest is posted.
Solicitations that can be downloaded from the web site.
In addition, the City ofNew York maintains a central bidders list that all City Agencies are
required to use for procurements. By becoming a registered vendor on the City=s bidder
list, you will receive notice of current procurement opportunities from City agencies that
are soliciting bids or proposals in your field of interest. You can access the Vendor
Enrollment Application at the following website:
http://www. ci.nyc.ny.us!html/moc/html/bidderform.html
Thank you for your interest in doing business with the New York City Police Department.
COURTESY
• PROFESSIONALISM •
Website: ·http://nyc.gov/nypd
RESPECT
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POLICE DEPARTMENT
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Douglass B. Maynard
Deputy Commissioner, Legal Matters
One Police Plaza,
New York, N.Y. 10038
January 21, 2014
Robert A. Reynolds
Cavalier Knight, LLC
New York, NY
Dear Mr. Reynolds:
The New York City Police Department appreciates your interest in doing business with
the City ofNew York. Your proposal has been forwarded to the appropriate units for their
information and review. If there should be a future interest in purchasing the product/service that
you are offering, we will be in contact with you.
In the meantime, we recommend that you check the City Record On-Line (CROL)
http:/I a856-intemet.nyc. gov/nycvendoronline!home.html .for future procurement opportunities.
The CROL is the electronic version of the Procurement Notices appearing in The City Record
printed version. The web site includes the following:
•
A fully searchable database of current awards and solicitations. Users can search with a
variety of criteria, such as due date, publish date, agency, procurement category, commodity
codes, and keywords (this database and search function has replaced all the "solicitations and
awards" pdf documents).
•
Online registration to receive emails when a solicitation of interest is posted.
•
Solicitations that can be downloaded from the web site.
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soliciting bids or proposals in your field of interest. You can access the Vendor Enrollment
Application at the following website: http://www.nyc.gov/html/mocs!html/research!vendex.shtml
Thank you for your interest in doing business with the New York City Police Department.
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