With respect to disqualifying crimes committed before November 1, 1987, exemption proceedings under 29 U.S.C. §§ 504 and 1111 are held before the United States Parole Commission where the Department of Labor attorneys and the Federal or state prosecutor have standing to appear, present evidence, and cross-examine witnesses pursuant to 28 C.F.R. § 4.11(b). Pursuant to memoranda of understanding between the Secretary of Labor and the Attorney General, the Department of Labor is primarily responsible for appearing on behalf of the Federal Government in proceedings for exemptions before the United States Parole Commission.
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