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December 28, 2001

Mr. Brian Connett
PRIDE Enterprise

12425 28" Street, North
Suite 103
St. Petersburg, FL 33716
.Re: . Union Correctional Institution; Our File NO. 125002·99
Dear Brian:
I have reviewed your MemorandumofDecember 28,2001 relating to a
projected Union Food Project. As I understand the issue, PRIDE will receive the
customer supplied raw meat product; grind the raw meat product and package the
same raw meat product into various custotner supplied and specified packages.
"'O"-lUw meat will be chilled to the customer's speci.fied·temperature; and some of the .
raw meat may be made into patties (1/3 initially) and over time decreasing as the
bulk volume increases.

raw

It is iny undexstanding !bat the customer supplied
meat products will
not undergo any material change (i.e., it will not be cooked or further processed
with the adding of any product other than the cuStomer supplied raw meat
product). It is my understanding further, tba(the product will undexgo USDA
inspection testing as required; and !bat the raw meat product will be loaded into
refrigerated trocks for transport back to the customer.

I
Mr. Brian Connett
December 28, 2001
Page 2

It is my understanding further that approximately seventy (70) inmates will
participate in this correctional work program and will provide a service to a

customer located in tlte State of Georgia. The product will be shipped to
destinations as determined by the customer.
.
Brian, this service, which is proposed to be provided by the inmates of
Union Food, is no different from tlte type service utilized in refurbishing torque
converters, such as at Soutlt Bay; grapefruit sectioning; or, any other type service,
in tltat inmate labor is being utilized to can:y out one asj>ect of the proposed
customer's business (i.e., tlte grinding ofraw meat product and paclcaging).
Therefore, absent further iDformalion andlor subsequent administrative or
judicial determination to tlte contrary, I can see no reason why this project
description for Union Food would not be permissible lDlder state and federal law.

Wilbur E. Brewton
General ColDlSel
WEB:ps
cc:

Dr. Pamela'1o Davis

Mr. Carl Deimling

Mr. Jack Edgemond
H;\~wmro..e-1U1.01

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