Ethics Matters News

Housing Authority Complaint Update, New Member
At its February meeting, the Ethics Commission voted to hold a hearing on the complaint regarding the members of the Housing Authority of Queen Anne's County. The hearing was held on April 16. On April 30, the Ethics Commission reported its conclusion that a conflict of interest exists for each of the respondents. No fine was levied, but the respondents were given a Cease and Desist Order (see Findings and Decisions on Complaint 17-001 in the Opinions section of this website). The decision of the Ethics Commission in this complaint has been appealed by the respondents to the Circuit Court of Queen Anne's County with the hearing set for November 2018.
Francis Roudiez has withdrawn as an alternate member of the Ethics Commission, and Jerry Jordan of Queenstown has been appointed to complete Mr. Roudiez's term. Mr. Jordan began his service on the Ethics Commission at the August Meeting.
Posted on 30 Aug 2018
Housing Authority Complaint Update, New Member
At its February meeting, the Ethics Commission voted to hold a hearing on the complaint regarding the members of the Housing Authority of Queen Anne's County. The hearing was held on April 16. On April 30, the Ethics Commission reported its conclusion that a conflict of interest exists for each of the respondents. No fine was levied, but the respondents were given a Cease and Desist Order (see Findings and Decisions on Complaint 17-001 in the Opinions section of this website). The decision of the Ethics Commission in this complaint has been appealed by the respondents to the Circuit Court of Queen Anne's County with the hearing set for November 2018.
Francis Roudiez has withdrawn as an alternate member of the Ethics Commission, and Jerry Jordan of Queenstown has been appointed to complete Mr. Roudiez's term. Mr. Jordan began his service on the Ethics Commission at the August Meeting.
Posted on 30 Aug 2018
New Ethics Commission member; investigation of Housing Authority
The County Commissioners have appointed Valerie Hirsch as a member of the Ethics Commission, and she will join the Commission at its February meeting. Mr Steffan Sonneveldt completed his term this past December, serving as Chair of the Commission for the last few years. He was a thoughtful and dedicated chair of the Commission and an outstanding leader. Dale Anderson, a member of the Ethics Commission since 2012 is the new EC Chairman.
At the Ethics Commission's January meeting, the Commission voted to investigate the complaint they received regarding alleged violations by the Housing Authority Board.
Posted on 26 Feb 2018
Update - August 2017
The past couple of years have been quiet ones for the Ethics Commission. Since 2014, there has been one Advisory Opinion sought (in 2014) and no complaints have been filed. The Commission’s work has consisted mainly of reviewing the required County employee financial disclosure forms and lobbyist’s registrations. The Commission members have also met with new County employees at the County’s New Hire Orientations to explain the purpose and content of the County’s Ethics Ordinance. A more detailed overview of the work of the Ethics Commission is found in their Annual Reports for 2014 and 2015 in the Documents section of this website. The Annual Report for 2016 should be approved and posted shortly.

The current Ethics Commission members, all appointed by the County Commission, are Dale Anderson, Merle Rockwell, Francis Roudiez, Stan Ruddie, Kaarin Salisbury and Steffan Sonneveldt who serves as Chair of the Commission.
Posted on 16 Aug 2017
Changes in the Ethics Commission
The New Year brings a change of faces on the County’s Ethics Commission.
After 7 years, many of them as Chairman, Bob Mueller retired from the Commission in December.   The Ethics Commission and the County have clearly profited from his leadership.   His insistence on a careful reading of the relevant parts of the County’s Ethics code prior to giving advice or making a decision should be his legacy, benefiting both the
Ethics Commission itself and County officials and employees. Mr. Mueller met with new employees and
officials and introduced them to the County’s Ethics Law, answering questions and clearing up concerns and confusion. He took his service on the Ethics Commission seriously, investing considerable time and thought in its deliberations, advisories and opinions, and by doing so helped all of us understand the role and importance of the Ethics Commission. Bob Mueller deserves both our respect and our appreciation for his service to the County.

Dale Anderson, who has been serving as an alternate to the Commission has been appointed as its fifth member. Mary Roby of Centreville will replace Mr. Anderson as the alternate.

Posted on 08 Jan 2014
QAC's Revised Ethics Code and Other News

QAC’s Revised Ethics Code - Queen Anne’s County has now met the State General Assembly’s requirement that all county and many municipalities’ Ethics Codes must have conflicts of interest and financial disclosure rules for elected officials (including elected School Board members) that are “equivalent to or exceed” the State’s requirements.  Those requirements became law in 2010 and the State Ethics Commission was given the authority and responsibility to review and approve the necessary revisions required by the law.

The Queen Anne’s County’s Ethics Commission spent considerable time working with the State Ethics Commission to make changes that met these new standards.  In November 2012, Commissioner Dunmyer introduced the State-approved revised Queen Anne’s County Ethics Ordinance (#12-23).  There was no testimony at the required hearing on January 22, 2013, and on February 12, 2013, Ordinance 12-23 was passed unanimously.  It will become law on March 30, 2013, 45 days after it was passed, at which time Ethics Matters will post it on our website, www.ethicsmattersinc.org. There is an uncorrected error in the new ordinance as posted on the County’s website (www.qac.org information>ordinances by year> CY2012 > 12-23), which we hope will be corrected when it officially becomes part of the County Code.

The new financial disclosure provisions require more detailed information from our elected officials.  As a result, the Ethics Commission will be rewriting the financial disclosure forms for our County Commissioners.  The Ethics Committee of the School Board will be responsible for updating their forms. QAC’s Sheriff, State’s Attorney and a number of other QAC officials are subject to the State’s Ethics Code, not the County’s, and already are required to complete the State’s more detailed financial disclosure.

The County’s existing conflicts of interest provisions were fairly close to the State’s provisions, so there were only a few changes necessary.  The County’s conflicts of interest rules, with some exceptions, apply to all officials, whether elected or not, and to all County employees, as well as all Board and Commission members. Generally, these individuals are prohibited from participating in matters in which they, or a family member, have a financial interest that is distinguished from the general public’s.  For example, even though a County official is affected by a vote that raises or lowers taxes, she or he can vote on it because it also affects the public at large.

Other News � The County Commissioners appointed Steffan Sonneveldt to the Ethics Commission replacing Hal Wilson, who was not reappointed.  Ethics Matters thanks Mr. Wilson for his constantly thoughtful and dedicated service to the Ethics Commission and the County.  Mr. Sonneveldt, who lives on Kent Island, is a Senior Vice President, Operations, for Towne Park.  The Ethics Commission reelected Bob Mueller as its chair.  The other members of the Ethics Commission are Jody Schulz, Dick Smith, Robert Udoff, and Dale Anderson as alternate. In their first two years in office, the County Commissioners have appointed, in some instances by a 3-2 vote, the alternate and four of the five members of the Ethics Commission.  Lynn Knight is continuing as counsel and Tina Miles as clerk.

 

Posted on 19 Feb 2013
Update on Ethics Commission

The Ethics Commission recently released their Annual Report for 2011. It is posted here on our website under “Documents.”  

The Report both describes the functions of the Commission and gives a brief, but specific, account of their work.

They issued eight advisory opinions (seven regarding conflicts of interest, one regarding a gift), a follow-up order to the Circuit Court appeal of Complaint 10-01,  and a Complaint (11-01) issued by the Ethics Commission regarding a possible violation  of a conflict of interest provision which, following the hearing, the Commission found the subject was exempt from.  It also issued three complaints for failure to file a financial disclosure form (see paragraph below), but the complaints were dismissed when the forms were submitted before the Ethics Commission took further action.

Ethics Matters asked the Ethics Commission for a definition of “recusal” after the Commission’s order that a member of the Planning Commission had an actual and apparent conflict of interest and should cease and desist in any activity as a member of the QAC Planning Commission that relates to the Queenstown Comprehensive Plan (an order subsequently affirmed by the Circuit Court).  That definition can be found at here on our website under “Documents.”

The Commission reviewed for completeness 189 financial disclosure forms, required of some County employees, elected officials, and members of decision-making Boards and Commissions, as well as committees providing advice and/or recommendations regarding acquisition, zoning, or designation of land. It also reviewed 14 lobbyists’ registrations and 15 lobbyists’ year-end disclosure reports.  

Due to the reduced number of new hires in County government, Commission member Robert Mueller offered only one presentation of the Ethics Code to new employees in September.

The Commission spent a great deal of time revising portions of the QAC Ethics Code to put it in compliance with a 2010 State law.  The revision that was submitted to the County Commissioners in September 2011 turned out not to be the revision approved by the Ethics Commission, and in October 2011 the Ethics Commission had to amend their proposed revision.  More recently, there has been some back and forth between the State and the QAC Ethics Commissions regarding the revisions.  At their July 2012 meeting, the Ethics Commission completed further revisions and sent them off to the State.  Once the State finds the proposed code in compliance, the new amended and revised code will be submitted to the County Commissioners.

In January, Robert Mueller was elected Chairman of the Commission. Kendall Ruffatto, Esq, who had served as the Commission’s Chair retired along with the Reverend Nanese Hawthorne.  They were replaced by Robert Udoff  and  Dale Anderson, who was appointed as the alternate member. The Ethics Commission’s members are now Robert Mueller, chair, Hal Wilson, Dick Smith, Jody Schulz, Robert Udoff and Dale Anderson (alternate).  Lynn Knight remains as counsel and Tina Miles as clerk. 

 

Posted on 06 Sep 2012
QAC Circuit Court Issues Opinion "In the Matter of Barry Waterman"

            The Circuit Court for Queen Anne’s County recently handed down its decision “In the Matter of Barry Waterman.” 

            If you recall, after Barry Waterman was appointed to the Planning Commission, a number of citizens and Ethics Matters joined in filing a complaint alleging that Mr. Waterman was in violation of the conflicts of interest provision (8-11 A-2) of the County’s Ethics Code prohibiting certain officials, including members of the Planning Commission, from being employed by or having a financial interest in an entity that is subject to the authority of the governmental unit with which the member is affiliated � a provision required by the State.

            The Ethics Commission found Mr. Waterman in violation of Section 8-11 A-2, and two others as well: 8-11 A-1 (prohibiting acting on behalf of the County on a matter that would have a direct impact on them or a family member or a business entity in which they have a financial interest); and 8-11 A-7 (intentional misuse of prestige of office or confidential information for their own private gain or that of another). 

            The Ethics Commission’s remedy for all three violations was to issue a cease and desist order of recusal from matters before the Planning Commission that have a direct financial impact on him, his family or a business entity in which he or a family member has an interest.  It specifically required him to cease and desist from participating in matters in regarding Wheatlands and the Queenstown Comprehensive Plan as well as the sewer going down Route 8.  Mr. Waterman appealed the decision of the Ethics Commission to the Circuit Court.

            The Circuit Court affirmed the Ethics Commission’s decision that Mr. Waterman was in violation of the conflicts provision 8-11 A-2, and it affirmed the Commission’s order to “cease and desist in any activity as a member of the Queen Anne’s County Planning Commission that relates to the Queenstown Comprehensive Plan.”   

            The Circuit Court further ruled that the Ethics Commission’s finding of violations of 8-11 A-1 and -7 and its remedy of a cease and desist order for potential conflicts “that may never come to fruition”, like the sewer down Route 8 (where Mr. Waterman and his family own numerous lots) or other issues presenting possible conflicts that had not yet come before the Planning Commission, were not “appropriate.” Accordingly, the Court reversed the Ethics Commission’s decision as to violations of 8-11 A-1 and -7.

            The Court’s rationale for its decision stressed that “the Ethics Code is absolutely essential to our system of government”, and a “violation” of it can be either an “act” or it can simply be “descriptive” of a status like having a conflict.   According to the Court, the Ethics Commission rightly concluded that  Mr. Waterman violates 8-11 A-2 just by being on the Planning Commission while having a financial interest in developing Wheatlands, but that it erred in finding violations of the other two provisions, which “require affirmative acts, not passive ones.”

            In sum, the Court upheld the finding of the Ethics Commission that Mr. Waterman, as a member of the Planning Commission, is in violation of the County Ethics Code due to his having a financial interest in a business entity that is subject to the authority of the Planning Commission, and it upheld the Ethics Commission’s remedy for this violation of recusal from anything to do with the Queenstown Comprehensive Plan.  The Court also ruled, however, that the Ethics Commission could not find him in violation of the Ethics Code and order him to “cease and desist” from actions that had not yet occurred.

            Unless either side appeals, the case will now go back before the Ethics Commission for the entry of an order consistent with the court’s judgment.

For the QAC Ethics Commission’s clarification of what “recusal” entails, please look under "Documents" on this website.  For the complete Opinion of the Circuit Court, look under “Opinions” on this website.   

Posted on 05 Sep 2011
Two New Ethics Commission Members

At their January 24 meeting, the County Commissioners appointed two new members to the Ethics Commission, Jody Schulz and Richard Smith.  Mr. Smith will serve as an alternate.  He replaces Neal Jackson, who resigned last spring to run for County Commissioner.  Mr. Schulz replaces Ben Tilghman, who filled out the term of a former Ethics Commissioner and was not appointed for a full term in his own right.

It was interesting to learn that at the County Commissioners’ most recent meeting, Commissioner Simmons took issue with the meeting minutes which described the selection of the two new Ethics Commission members as unanimous.  Commissioner Simmons said he was very opposed to their selection.  Commissioner Dunmyer joined Mr. Simmons in correcting the minutes, noting that he, too, had opposed their selection.  The vote was 3-2.

Mr. Schulz and Mr. Smith will have big shoes to fill.  Mr. Tilghman and Mr. Jackson conscientiously familiarized themselves with all provisions of the Ethics Law and took special concern to consider all sides of an issue and apply the Ethics Law fairly. They were active, contributing members of the Commission, volunteering whenever the Chairman asked for help with drafting and distributing informational material and playing a major role in producing the Commission’s Annual Report.  Ethics Matters thanks Mr. Tilghman and Mr. Jackson for their service on the Commission.  

Ethics Matters welcomes new members Jody Schulz and Dick Smith.  Mr. Schulz is President of the Kent Island Fire Department, and Fisherman’s Inn and the Crab Deck are family businesses.  He is a developer with a number of projects throughout the County.  Mr. Smith owns his own real estate company and numerous parcels of land in Queen Anne’s County.  An unsuccessful three-time candidate for County Commissioner, Mr. Smith served for two years as County Commissioner when he was appointed to complete “Nemo” Niedomanski’s term.  Mr. Smith is active in the Farm Bureau, has served on a number of County Boards and Commissions, and has chaired the Kent Narrows Development Foundation.  In addition to the Ethics Commission, he was recently appointed to the Task Force on Government Sustainability, a group charged with making recommendations on restructuring County government to ensure sustainability.

Ethics Matters appreciates Mr. Schulz’s and Mr. Smith’s willingness to serve the citizens of the County as they perform their new duty of carrying out the purpose of the County’s Ethics Law: to assure “that the financial interests of holders of and candidates for public office and public officials and employees present no conflict with the public interest.”

 

Posted on 18 Feb 2011
Waterman Complaint Appeal; Recusal Definiton; New Chair

“In the Matter of Ethics Complaint 10-01 Against Barry Waterman”

In response to the Ethics Commission’s Complaint Opinion and Order issued this past December In the matter of Barry Waterman (Case 10-01), Mr. Waterman filed a Petition for Judicial Review on January 4, 2011 with the Queen Anne’s County Circuit Court. Attorney Jeffrey Thompson is representing Mr. Waterman. On January 11, the County Ethics Commission responded to the Circuit Court that it “intends to participate as a party in this action.”  Lynn Knight, Counsel to the Ethics Commission, will represent the Ethics Commission. To date, no brief has been filed by Mr. Thompson, so we do not know the grounds of Mr. Waterman’s appeal.

Ethics Commission’s Clarification of “Recusal”

On December 9, shortly after the Ethics Commission issued its Opinion in this matter, Ethics Matters requested a clarification of “Recusal” from the Commission.  At their January 10th meeting, the Ethics Commission adopted the following:

            The Queen Anne’s County Ethics Commission adopts this clarification of the term “recusal,” which means to disqualify oneself entirely from all aspects of the consideration of the relevant matter.  This includes, but is not necessarily limited to:

·       Excusing oneself from the room whenever the relevant matter is under discussion and whenever any vote of any kind is taken on the relevant matter by a county board or commission;

·       Not engaging in any conversation, informal or casual or otherwise, with any person or persons who are members of the county board or commission;

·       Not engaging in any conversation with any County office or staff member relating to the relevant matter; and

·       Not taking any other action that fairly may be construed as intending to or tending to affect the consideration of and decision on the relevant matter by the county board or commission.

·       Assuring that any actions or conversations with persons other than members or staff support of the county board or commission be in a context in which that person affirmatively takes steps to ensure that the other persons clearly understand that he/she is speaking as a private citizen and not as a member of the county board or commission and that he/she is not reflecting the views of the members of the county board or commission.

 

New Chair of the Ethics Commission Chosen

Also at their January meeting, the Ethics Commission selected member Kendall Ruffatto as the Chairman of the Commission.  Ms. Ruffatto is an attorney who is Executive Secretary of the Attorney Grievances Commission of Maryland.  She has served on the Ethics Commission since 2007.  Ms Ruffatto is suceeding Robert Mueller, who has been the Commission’s Chair for a number of years.  He had announced when re-elected as Chair last year that it would be the last year he would serve in that capacity.  Mr. Mueller, who is both an attorney (formerly with the US Court of Appeals for the Armed Services) and a mediator, will continue as a member of the Commission.  Ethics Matters thanks Mr. Mueller for his careful and thoughtful leadership of the Commission and looks forward to Ms Ruffatto’s tenure as Chair. 

Posted on 28 Jan 2011
Complaint Opinion - Waterman/Planning Commission

ETHICS COMMISSION ISSUES OPINION IN COMPLAINT AGAINST BARRY WATERMAN

    On December 6, the Queen Anne’s County Ethics Commission issued its opinion on a complaint brought in February 2010 by a nine citizens and Ethics Matters alleging that Barry Waterman’s “historic and current real estate activities in Queen Anne’s County present actual and/or apparent conflicts of interest with his service on the QACPC (Planning Commission).”  The Ethics Commission found Mr. Waterman has conflicts of interest in violation of the Ethics Law: “Respondent’s and his immediate family members’ financial interests in certain business entities whose activities include residential and commercial real estate brokering, consulting, development and construction projects, and investments that implicate the jurisdiction and responsibility of the QACPC, present actual and apparent conflicts of interest in violation of Section 8-11.A (1) (2) and (7), Ethics Law.”

 

Recusal in Two Matters and in Other Decisions

            Stating that Mr. Waterman, his wife, parents or entities in which they have a financial interest own approximately 45 parcels in Queen Anne’s County, the Ethics Commission ordered Mr. Waterman to recuse himself in two matters that are currently within the scope of discussion and review by the Planning Commission, namely, the Queenstown Comprehensive Plan and issues related to sewer along route 8 on Kent Island. 

            The Ethics Commission further stated that land-use decisions by the Planning Commission that do not directly involve properties owned by Mr. Waterman, his family or their financial entities nevertheless can set precedents that could affect the value of Mr. Waterman’s properties. To remedy these potential conflicts, the Commission ordered Mr. Waterman to “cease and desist, by recusing himself from any discussion, any decision or any activity on any other matter before the Queen Anne’s County Planning Commission . . .  which will have, or reasonably could be believed by an informed member of the public to have, a direct financial impact, as distinguished from the public generally, on Respondent or a member of his family or on a business in which he or a member of his family has an interest.”

 

Recusal Involving “Prestige of Office” and Confidentiality

             The Commission also ordered Mr. Waterman to recuse himself from any discussion, decision, or any other activity in which an informed member of the public reasonably could believe that he used the prestige of his office or confidential information acquired in that office for his or others’ personal gain.

 

Recusal Challenges for Mr. Waterman as a Member of the Planning Commission

            The Ethics Commission observed that “the scale of Respondent’s property ownership in the area, as well as that of other family members, dramatically multiplies the financial interests and, thus, is meaningfully distinct from someone owning a single built-out parcel as a residence.”

            Further, “the appearance of a conflict of interest can be cured by recusal only if that remedy is invoked by Respondent in a generous fashion to a situation in which an informed member of the public could reasonably reach this conclusion � whether or not Respondent himself believes the conclusion is reasonable.”

            The Ethics Commission stated that  “…if recusal is to be an adequate remedy, it is imperative that Respondent remains constantly vigilant and sensitive to both the actual and apparent conflicts of interest as to the groups of properties that may be inherent in ANY particular land-use question that comes before the QACPC.”

 

Background

            The complaint was filed by nine citizens and Ethics Matters following the appointment to the Planning Commission of Barry Waterman, notwithstanding the Ethics Commission‘s advisory opinion (10-01) that Mr. Waterman’s service on the Planning Commission would be a violation of the Ethics Law.  In their complaint, the citizens and Ethics Matters noted Mr. Waterman’s conflicts of interest and asked for a strict interpretation of the section of the Ethics Law that prohibits holding conflicting financial interests while serving on the Planning Commission.  Citing a “recognition of the need for citizens possessing technical knowledge to serve on the Planning Commission,” the Ethics Commission noted that “ with a rigorous application of the Ethics Law to each decision in which Respondent participates and recusal where appropriate to prevent the appearance of, or actual, conflict of interest, Respondent may continue to serve on Planning Commission.”           

Comment

             Ethics Matters questions this rationale for a recusal-only result.  Even assuming such a need for “technical knowledge,” a person who develops in another county or has retired from development in our County could meet the claimed need without presenting conflicts of interest. Ominously, the Ethics Commission itself admits it is not hopeful that “a rigorous application of recusal actually will consistently occur, based on Respondent’s posture on various matters during the investigative and hearing process.” It sounds like the public’s trust is not assured but will have to be protected by vigilant citizens and Planning Commission members during Mr. Waterman’s tenure on the Planning Commission.

 

            Ethics Matters has filed a request to the Ethics Commission for clarification of what the Commission understands to be required of the respondent when recusal is necessary.  The complete opinion in this complaint, Opinion 10-01, is available at Ethics Matters’ website www.ethicsmattersinc.org under Opinions.  The Ethics Matters letter requesting clarification of recusal follows below.

 

             Ethics Matters, Inc.

P.O. Box 93, Centreville, MD 21617

www.ethicsmattersinc.org  ~ ethicsmattersinc@gmail.com

 

                     

December 9, 2010

 

 

Dear Ethics Commissioners,

 

Pursuant to your opinion in Complaint No. 10-01, would you be good enough to provide clarification on several questions?  Exactly what does it mean to “recuse” oneself?  That word does not appear in the County’s Ethics Code, and it would be helpful to all concerned to know just what a “recusal” requires.  The dictionary defines “recuse” generally as removing oneself from participation due to a conflict.  Just what does that involve?

·       Should the person who is recusing leave the room when a conflicting matter is under consideration by the Board or Commission so his/her presence will not influence/intimidate those discussing and making a decision? 

·       Are “discussions, decisions or any other activities” on matters with conflicts or apparent conflicts prohibited with staff/counsel and other Planning Commission member(s) at any time and place, not just in connection with Commission meetings?

 

There are a couple other clarifications that would be helpful.

·       Is a person who is on a Board or Commission considered a member of that body in all circumstances?  Can they identify themselves to another governmental body or member of another governmental body as speaking as a private citizen and then go on to discuss or advocate on a matter where a conflict exists or appears to exist as a Board or Commission member?

           

·       In trying to understanding   “prestige of office” � do discussions or activities on matters where a conflict is actual or apparent with a County Commissioner(s),  members of the Public Works Advisory Committee or Board or other County Agencies amount to a misuse of “prestige of office”?  How about State Agencies like Roads?

 

Thank you for any clarification you can provide on these questions.

 

Sincerely,

 

 

Mary Campbell

President

 

 

          

Posted on 16 Dec 2010
Ethics Commission Update

            At its May 17th meeting, the Ethics Commission dismissed a complaint for a conflict of interest violation brought before it at its April 19th meeting. The Ethics Commission does not disclose the identity of the person who brings the complaint (the complainant) or of the person against whom the complaint is lodged (the respondent).  Those involved are under no constraints as to confidentiality. 

            The decision of the Commission in this case is very helpful in informing the public about the County’s Ethics Law.  In this case, the respondent, Sheila Tolliver, had been publicly asked at a televised Planning Commission meeting by another member of the Planning Commission, Barry Waterman, to recuse herself from discussions and votes regarding Queenstown and Wheatlands Farm which she refused to do.  The complaint against Mrs. Tolliver, brought by Mr. Mareen Waterman, alleged that she had a conflict of interest and had violated the County Public Ethics Law by not recusing herself.  The Ethics Commission considered both Mr. Waterman’s complaint and Mrs. Tolliver’s response.

            Mr. Maureen Waterman based his complaint on the last provision of  the Chapter 27, the Human Resources Code, which states Standards of Ethical Conduct.  The Ethics Commission determined that the Human Resources Code expressly excludes members of Boards and Commissions appointed by the County Commissioners from its provisions.  They stated  that the Ethics Commission’s jurisdiction is solely Chapter 8, the Code of Public Ethics, and that members of Boards and Commissions appointed by the County Commissioner are subject to Chapter 8.

            Even though the complaint was based on a non-applicable provision of the County Code, the Ethics Commission then considered the allegations in regard to Chapter 8, which is applicable to Planning Commission members.  The conflicts of interest described by Chapter 8 are only those conflicts that arise or could arise from a Board or Commission member’s personal financial interest(s).  To take part in a discussion and vote that involves a belief, a personal, non-financial interest, or a philosophy of a Board or Commission member is not a conflict.  In fact, members are often appointed to Boards and Commissions to make sure a certain philosophy or approach to issues is represented. Because the Ethics Commission found that none of evidence presented showed that Mrs. Tolliver had a financial interest in the discussion and vote regarding Queenstown and Wheatlands Farm, Mr. Waterman’s complaint was dismissed.

            You can find the Ethics Commission’s opinion on the complaint (10-02) on our website, www.ethicsmattersinc.org under Opinions.

********

            Ethics Matters recommends reading the Ethics Commission’s 2009 Annual Report, found under Documents, on our website www.ethicsmattersinc.org , the County’s website, or at the public libraries.  It is an excellent overview of what the Ethics Commission does in general and, in particular, the decisions and actions it took during the past year, including brief descriptions of the 18 Advisory Opinions it issued in 2009.

            The volunteer Commission members are to be congratulated for their dedication, evidenced by the amount of time and thought they have given to creating and sustaining a culture of ethical governance in Queen Anne’s County.  One member, Neal Jackson, recently resigned from the Commission to run for elective office.  As a retired vice-president of a national non-profit organization, Mr. Jackson brought a great deal of experience to EC discussions and decision making.  The current members of the Commission are Bob Mueller, Chair; Kendall Ruffatto, Vice-chair; Hal Wilson; Nanese Hawthorne; and Ben Tilghman.

             The County has issued a press release asking interested citizens to apply for the now vacant alternate position by June 11.  A resume and letter of interest should be sent to by regular mail to:  The QAC Commissioners’ Office, The Liberty Bldg., 107 N. Liberty St., Centreville MD 21617, attn: Jan Edwards or by email to jedwards@ qac.org with “Ethics Commission vacancy” in the subject line.

Posted on 23 May 2010
Planning Commission Advisory

Questions have been asked about the Ethics Commission’s Advisory Opinion process as a result of the Queen Anne’s County Commissioners voting 3 to 1, with one abstention, to seat a QAC businessman, Barry Waterman, on the Planning Commission.

 

The background is as follows.  Before the vote, in response to constituents’ concerns about the appointment to the Planning Commission persons believed to have possible conflicts of interest, Commissioner Fordonski had requested the financial disclosure forms of all the applicants. After reviewing the information on the forms, and in the interest of doing “due diligence”  before making a possibly unlawful appointment, she asked the Ethics Commission for two Advisory Opinions, one of which was whether Mr. Waterman’s membership on the Planning Commission would be an Ethics violation due to his business interests.  The Ethics Commission advised her that Mr. Waterman would be prohibited from membership on the Planning Commission.

 

This request, and the resulting Advisory Opinion, had nothing to do with Mr. Waterman’s character, nothing to do with his views or his politics, nothing to do with his ability to serve the County in other capacities.  They simply addressed whether Mr. Waterman’s business interests, as described by him under oath sixteen months ago in his financial disclosure form (required for transparency for members of Comprehensive Plan Topic Committees), would preclude his membership on the Planning Commission.

 

In his financial disclosure form, Mr. Waterman stated he was President and part-owner of Waterman Realty, a general and limited partner of the Waterman Family Partnership and Vice-President of Waterman, Inc.  He described the nature of the businesses as “Real Estate brokerage, investment, development, consulting, and construction.”  He indicated he owned, in whole or in part, numerous properties, including Wheatlands Farm, currently under consideration for development. 

 

The County Ethics Law provides that a County official is prohibited from being employed by or having a financial interest in an entity that is “subject to the authority of that official or employee or of the governmental unit with which the official or employee is affiliated.”  In short, you cannot serve on a governmental body that supervises or gives approvals to a business you have an interest in.  Simply recusing oneself from decisions directly affecting your business is not enough, because by giving or withholding approvals on other projects, you set precedents and establish policies that can benefit your interests.

 

The prohibition cited by the Ethics Commission assures the public that decisions made on their behalf are free from considerations of personal financial gain.  Notice that the prohibition does not keep all developers from membership on the QAC Planning Commission.  A developer would not necessarily be prohibited from serving if he/she did not develop in Queen Anne’s County. 

 

An Advisory Opinion is simply that � it is a non-binding answer to a question about the application of the Ethics Law.  In responding to a request for an Advisory Opinion, the Ethics Commission applies the Ethics Law to the facts provided in the request, in this case, Mr. Waterman’s financial disclosure form. The Complaint process is quite different; it is an allegation made under oath of a violation of the Ethics Law.  The subject of the complaint is informed of the complaint, notified of his right to respond and present evidence, and his right to an attorney.

 

The Advisory Opinion process is common to most Ethics Laws and is designed to help people avoid violating the Ethics Law and so possibly becoming the subject of a Complaint. Last year, the QAC Ethics Commission issued 17 Advisory Opinions.  They are available both in the Liberty Building and on our website  under Opinions>Advisory Opinions>Conflicts>1.29.10(#10-01) 

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Posted on 02 Feb 2010
Ethics Commission Finds Conflit of Interest Violation

In an important decision, the QAC Ethics Commission has found against a member of the volunteer Queen Anne’s County 4-H Board in a complaint alleging a conflict of interest.  The conflict arose when a private company owned by a Board member entered into a services contract with the Board.

           In the opinion, the Ethics Commission first established its jurisdiction over the Board and the right of the complainant to be heard. 

          In its findings of fact, the Commission noted that 4-H Board members had expressed some concern that the situation could be a conflict of interest, but that at no time - right up to and including the complaint hearing - had any member read or consulted the Ethics Law or sought an Advisory Opinion from the Commission.  The 4-H Board testified that they believed that they had addressed any conflicts concern by having the company-owning Board member leave the room during the final discussion and vote.  The Board awarded the contact to the Board member’s company which was the low bidder by a narrow margin.

          As the Ethics Commission’s opinion points out, however, it was not just the process of awarding of the contract that presented a problem; the on-going relationship was in violation of the law. The Ethics Law provides  “a clear-cut, black-letter ban on a business relationship between a private entity in which a Board member has a financial interest, on the one hand, and, on the other, the county board on which the member sits.” (p.6 of opinion)  In short, the on-going situation of a Board member having a financial interest in an entity which is doing business with the Board he/she sits on presents a conflict of interest and is a violation of the law.

          The Ethics Commission concludes with the following Final Consideration:

To the extent that counsel implied in his argument to the Commission that, somehow, volunteers on county boards and commissions should be given some slack in being charged with at least a basic understanding of the Ethics Law, and possibly some slack even in the application of that law to them, we firmly reject the notion.  Volunteer service to local government is the backbone of good citizenship and is a hallmark upon which local government depends.  Nonetheless, Section 8-4 � like similar provisions in a myriad of governmental codes at the local, state, and federal levels � reflects a legislative balance of this and other considerations against a bedrock of democratic government:  Trust and confidence of the people in the integrity of their government officials.  A government official’s status of volunteer does not reduce the right of the people to be assured that public actions of public officials are not tainted by considerations of private gain or insider status, and it is not unreasonable for the people to expect officials � volunteer and otherwise � to have at least a fundamental appreciation for constraints and expectations in this regard.

            A cease and desist order for any action in furtherance of the contract in question was issued by the Ethics Commission.

          Ethics Matters applauds the Ethic Commission’s carefully considered decision. We have only summarized the opinion here. It is available in full on this website under Opinions.

 

Posted on 17 Jul 2009
Ethics Commissions 2008 Annual Report; EC Creates Committee on Lobbying Reporting

Ethics Commission’s 2008 Annual Report

            Ethics Matters has just posted the Ethics Commission’s 2008 Annual Report on this website under Documents.  The Report reflects the thought and time this volunteer commission devotes to promoting ethical governance in our County.  They deserve our appreciation.

            The Commission continued its Education and Outreach Program by conducting a briefing session last March for members of County Boards and Commissions.  They also conducted sessions with all new employees of County departments in the spring and the fall.  These sessions had a particular emphasis on the conflicts and gift provisions of the County’s Ethics Law.

            Over the course of 2008, the County issued 31 written Advisory Opinions.  The opinions are the Commission’s interpretations of the Ethics Law as it applies to the facts of particular situations. The opinions are summarized in the Annual Report with identifying information redacted to the extent possible.  (They are also available in full on this website under Advisory Opinions.)

             It is interesting to note that in the year before, 2007, there were 20 Advisory Opinions issued. The Ethics Commission attributes the one-third increase to County employees’ and officials’ increased awareness of the law and their desire to comply with it.

            Two hundred and ninety-seven financial disclosure forms were received and reviewed for completeness by the Ethics Commission.  The Commission initiated 5 complaints for late filing or failing to file financial disclosure forums. All outstanding forms were subsequently filed and the complaints were terminated.

             The Commission also initiated a complaint in reference to the gifts provision of the law.  The employee “cured” the complaint and the complaint was terminated.

            In 2008, 21 individuals or organizations/businesses were identified on lobbying registration forms as lobbyists, although many of those did not in fact register.  The Commission received 16 year-end lobbying reports for 2007.

            In its conclusion to its Annual Report, the Ethics Commission complimented the integrity of Queen Anne’s County employees for bringing questions regarding their own actions forward so as to be certain that they are complying with the Ethics Law. 

 

Committee on Lobbying Reporting Created

At the Ethics Commission’s January 2009 meeting, Chairman Mueller appointed a committee of Ms. Ruffato, Mr. Tilghman and Mr. Jackson to look into ways to inform individuals and business/organizations about the lobbying provisions of the Ethics Law.  It is clear that some businesses/organizations and individuals are not in compliance with the law, perhaps because they are not aware of its requirements.

Posted on 07 Apr 2009
NEW MEMBER APPOINTED TO ETHICS COMMISSION

Ethics Matters - and we are sure, all Queen Anne's citizens - are encouraged by the growing culture of ethical governance in Queen Anne's County.  As their first legislative act two years ago, the current County Commissioners replaced the County's previously weak and unlawful ethics code with a law tobe proud of - the strongest on the Eastern Shore.  They have, as is evident below, appointed a group of thoughtful and dedicated volunteer citizens to the challenging tasks of interpreting and enforcing the new law.  Ethics Matters appreciates both Commissions - County and Ethics - for their work in

establishing and preserving the public's trust in their government.

     

Recently, the County Commissioners appointed Neal Jackson of Church Hill to the Ethics Commission and reappointed Robert Mueller from Centreville, each for a five year term.

 

Mr. Jackson was the Chief Legal Officer and Chief Ethics Officer (Vice President for Legal Affairs, General Counsel and Secretary) of National Public Radio from 1996 to 2007.  Before that he was a partner in the Washington office of the Chicago-based law firm of Bell, Boyd, & Lloyd.  Mr. Jackson also served as Chairman of the Hearing Committee of the Board on Professional Responsibility of the DC Court of Appeals, conducting discipline proceedings under the ethics code involving members of the DC Bar.  He is a graduate of the University of North Carolina and Georgetown Law School.  Mr. Jackson will serve as an alternate on the QAC Ethics Commission.  Alternate members take part in all Ethics Commission discussions and proceedings, and vote when a member is absent.

 

Mr. Mueller, who joined the Commission as an alternate, has been serving as Chairman of the Ethics Commission for the past few years. He, too, is an attorney, retired from the federal government where he was Senior Commissioner for Judge Andrew Effron of the U.S. Court of Appeals for the Armed Forces.  Under Mr. Mueller's leadership, the Commission has held numerous informational workshops with County officials and employees, discussing the ethics code and its requirements and answering questions. 

 

Other members of the Ethics Commission include Kendall Ruffato, an attorney who is the Executive Secretary to the Attorney Grievance Commission of Maryland. She joined the Commission in 2007, along with Rev. Nanese Hawthorne, the Rector of St. Luke's Parish in Church Hill. 

 

In January 2008, the Commissioners appointed Benjamin Tilghman of Centreville and Harold Wilson of Chester to the Commission.  Mr. Tilghman is active in farming on his historic property on Tilghman Neck outside Centreville.  He retired in 2004, following a career in book publishing. Mr. Wilson had a 30-year career in management of non-profit housing organizations and international development.  He is a published writer of poetry and fiction.  

 

The Ethics Commission meets on the third Monday of each month at 5:30 p.m. in the County Commissioners' Meeting Room, except when that day falls on a holiday, in which case the Commission meets on the fourth Monday of the month.  The meetings are open to the public.

Posted on 19 Jan 2009
Advisory Opinions - May-August

Ethics Matters has just posted several months’ worth (May-Aug) of Advisory Opinions issued by the County’s Ethics Commission in “Documents” on this web site. The Ethics Commission (EC) has had problems with the numbering of these opinions, making it difficult to post and refer to the opinions in a meaningful way.  At their September meeting, the EC straightened out the problem.

 

Several of the opinions advise about the financial disclosure requirement for “ad hoc committees and subcommittees providing advice and/or recommendations regarding acquisition, zoning, or designation of land.”  Opinions regarding this provision and the necessity for financial disclosure were issued in regard to the Chesapeake College Area Citizens Advisory Committee , the Committee on Site Selection for the Regional Detention Center , and the Public Works Advisory Board .

 

It should be noted, in passing, that these ad hoc citizen advisory committees are not subject to any other provisions (conflicts, gifts) of the County Ethics Law.  Different interests should be represented on them, while the transparency provided by financial disclosure allows committee members to know where other members are “coming from” and reassures citizens that interests are represented fairly in relationship to the make-up of the community.

 

There were also a number of opinions regarding possible conflicts between County employment and outside/part time employment, as well as possible conflicts regarding spousal employment.  The acceptance of gifts valued at more than $20 was also considered.

 

Ethics Matters made two requests for advisory opinions, both about the same situation regarding a conflict of interest. In September 2007, in an opinion that cited no provisions of the law, the Ethics Commission found there was no conflict of interest for a member of the Ethics Commission to join the law firm of the Ethics Commission’s counsel.  In their opinion about this situation involving itself, the EC failed to consider a central, controlling conflicts provision which prohibits a member of a board from being employed by or having a financial interest in an entity that is doing business with the governmental unit with which the board member is affiliated. 

 

Ethics Matters requested a reconsideration of the opinion, citing the above controlling provision, but at their December meeting in Opinion 07-20, the Ethics Commission reaffirmed their earlier opinion and denied the request for reconsideration, saying the question was moot since the member had resigned. They left on the record the opinion that no conflict existed.

 

Again this April, with two new members on the Commission, Ethics Matters requested a reconsideration of the no-conflict opinions in this situation.  This time, at their May meeting in Opinion 08-12, the Ethics Commission determined that they had overlooked the provision that was “appropriate for consideration in the context of this case” in their September opinion.  They now agreed there was a violation of the law.

 

At this point Ethics Matters has two remaining concerns, both concerning the very confusing guidance this May opinion gives to those subject to the ethics law  First is the opinion’s continuing reaffirmation of their mistaken and unconvincing earlier opinion of no conflict based on a non-controlling provision of the ethics law.  Second, the May opinion is so filled with legalistic discussion that an ordinary person looking for guidance may easily miss the very important fact buried in a paragraph on the second page that a conflict of interest violation does in fact exist in this kind of situation. To see the May opinion on this site, go to Documents, Advisory Opinions, Conflicts 5.20.08 #08-12.

 

Members of Ethics Matters attend all Ethics Commission meetings. The Ethics Commissioners are to be congratulated for their hard work.  We have been impressed by their commitment to conducting information and education programs about the ethics law, and we hope they continue to do so as new officials, employees, and Board and Commission members undertake their responsibilities to Queen Anne’s County citizens.  The resulting awareness of ethics issues serves the County well.  It also creates more work for the Commission with a stream of advisory opinion requests.  Increasingly, the Commission considers these requests carefully with attention both to the circumstances of the request and the provisions of the law.

Posted on 02 Oct 2008
ETHICS MATTERS' CONGRATULATIONS AND CONCERNS

 

Our Congratulations

 The County Ethics Commission recently approved its Annual Report for 2007.  This excellent report is available on this website under Documents.  It should be widely read. The Report does a fine job of informing the reader about the duties of this important Commission, and it provides accountability by detailing the Commission’s activities during the last year. 

 

The accomplishments of the volunteer members of the Ethics Commission are impressive, especially in the area of informing the County government and the public at large about the Ethics Code. They have nurtured a culture of ethical government through their publications and by providing 19 training sessions during the course of the year.  They have spent considerable time with those County employees and officials who find themselves subject to financial disclosure requirements, making the process as clear and non-burdensome as possible while explaining the reason for requiring financial disclosure for some County jobs. 

 

Other duties of the Ethics Commission include resolving complaints regarding Code violations (19), handling lobbyists’ registrations (4) and year-end disclosures (15), and issuing advisory opinions (20).  Because advisory opinions help inquirers understand the law, the Annual Report usefully includes a brief description of the rationale of each advisory opinion.

 

The whole County � government employees and the public at large � benefits from the time and dedication the Ethics Commission gives on our behalf.  They do not have an easy job; they have challenging and difficult decisions to make as they administer the law.  We feel sure that their annual report, publications and information sessions will result in a County with an ever-stronger culture of ethical governance.  Each of the volunteer members deserves our appreciation. The chairman, Bob Mueller, is to be particularly thanked for his thoughtful and energetic leadership of the Commission.

 

Our Concerns

 We have two that we feel are important to note.

 

The first, already expressed to the Ethics Commission, is their opinion advising that there was no conflict with a member of their Commission working in the law firm of the counsel to their Commission.

 

The Commission, by its own admission, focused on one provision of the code, the misuse of the prestige of office, when considering this situation. They found no conflict because the member and counsel are both lawyers and lawyers disagree routinely, so the member’s votes wouldn’t be unduly influenced by counsel.  They neglected to consider the controlling conflicts provision that prohibits the member from being on the Commission at all when she has a financial interest in an entity that is doing business with the Ethics Commission.

 

The member later resigned from the Commission.  Nonetheless, the advisory opinion (9.13.07 #7-13) is incorrect and misleading, yet it stands as a precedent and guide to others in similar situations.

Ethics Matters believes the Commission simply made a mistake and needs to correct it.  They should give serious consideration to withdrawing both of their misleading opinions regarding this conflicts situation. 

 

Our second concern is the amount of time that is seems to be taking to conduct and complete the investigation, called for at last November’s meeting, into the purview of some of the subcommittees formed by the Public Works Advisory Board.

 

The issue is whether the members of any of these subcommittees should be required to make financial disclosure. The Ethics Code requires financial disclosure by members of certain committees “providing advice and/or recommendations regarding acquisition, zoning and/or designation of land” (emphasis added: taking sewer down Route 8 could arguably cause a change in designation of some lots from don’t perc/ unbuildable to lots receiving sewer/buildable).  Our concern is that committees like these are often, by their nature, short-lived, so that by not accomplishing their investigation in a timely fashion, the Commission is not ensuring the transparency the public has a right to expect under the Ethics Law.

 

 

 

 

Posted on 08 Apr 2008
TWO NEW ETHICS COMMISSION MEMBERS; ADVISORY OPINIONS AVAILABLE ON THIS WEBSITE

Two New Ethics Commission Appointees   At their meeting Tuesday, January 22, the County Commissioners appointed two new members to the Ethics Commission and reappointed a third as an alternate.  The new appointees are Benjamin Tilghman of Centreville and Harold Wilson of Chester

 Benjamin Tilghman is active in farming, managing his farm outside Centreville.  He retired in 2004, following a career in book publishing.  Mr. Wilson had a 30-year career in management of non-profit housing organizations and international development.  He is currently a writer of fiction and poetry.

 Returning Commission member Francis Roudiez was appointed to serve as alternate. The other members of the Commission are Robert Mueller, Kendall Ruffatto, and Nanese Hawthorne. 

 Ethics Matters would like to express its thanks to these six volunteer Ethics Commission members for the time and effort they devote to our County and to promoting ethical governance.  Our county depends on volunteers like these men and women.  They deserve the thanks and appreciation of every citizen.

 Advisory Opinions Available Online!  Ethics Matters is now publishing the Ethics Commission’s Advisory Opinions on our website (www.ethicsmattersinc.org) under “Documents.”  The opinions are organized by issue (conflicts, financial disclosure, applicability) and then by date, beginning in 2007. 

Through Advisory Opinions, the Ethics Commission advises regarding applicability and compliance with the Ethics Law.  The Maryland Attorney General notes that publishing the substance and reasoning of Advisory Opinions benefits the public at large.  Some counties and the State publish their Advisory Opinions on their websites.

Any person may request advice from the Ethics Commission regarding applicability or compliance with the County Ethics Law.  Advisory Opinions are public documents, and information that might identify the person who is subject of the opinion should be absent to the extent possible. 

Posted on 25 Jan 2008
THE ETHICS COMMISSION - A MIXED REVIEW: WHERE IT HAS DONE RIGHT AND WHERE IT HAS GONE WRONG

Done Right:  The Ethics Commission has done a fine job of informing government employees and citizens about the Ethics Law.  They distributed a Guide to the Ethics Law and fact sheets, and they are holding informational meetings with public employees. The volunteer Ethics Commissioners are to be congratulated for the energy, time, and effort they have dedicated to their information efforts.

 Done Right:  The Ethics Commission has been diligent and fair in dealing with those who, after multiple requests and warnings, failed without good cause to submit their financial disclosure form by the January due date.

Having served complaints on the offenders, the Ethics Commission imposed a fine of $200 on those still failing to comply with the law.  Subsequently, they sent a letter to the few individuals who had yet to comply, giving them 30 days to pay the fine and file their disclosure form, or the Ethics Commission would forward the complaint to the State’s Attorney for enforcement.  In October, with one outstanding fine left, the Ethics Commission Chair asked its Counsel to keep checking with the State’s Attorney on the status of the follow-up on this Ethics Law violation. 

Throughout the undoubtedly difficult process of serving ethics complaints on fellow citizens in a small county, the Ethics Commission has made the effort to deal fairly with the disposition of each complaint, keeping in mind both individual circumstances and the unacceptability of non-compliance when the vast majority of those required to file financial disclosure did as the law requires.

Gone Wrong:  Through its Advisory Opinions, the Ethics Commission advises public employees and officials regarding compliance with the law. As the Maryland Attorney General notes, publishing the substance and reasoning of advisory opinions benefits the public at large.

Of real concern is the determination that a member of their Commission, who joined the law firm of the Ethics Commission’s counsel, did not have a conflict of interest, or even the appearance of a conflict of interest. 

The Ethics Law prohibits any County employee or member of a County commission from “having a financial interest in an entity that is … doing business with the governmental unit with which the official or employee is affiliated.”    This is a fundamental financial conflict of interest provision that the State requires as part every county’s ethics law.  In this situation, the Ethics Commission member has a financial interest (as an independent contractor) in an entity (Counsel’s law firm) that is doing business (as counsel) with the Ethics Commission.  It is a clearly prohibited situation.

Surely both the Counsel and the Member, also an attorney, knew this key prohibition and knew that the conditions for an exception did not exist.  Nevertheless, the Member requested an advisory opinion.  Without even considering the key on-point and State-mandated financial conflicts provision, the Ethics Commission advised that there was no conflict or appearance of a conflict.  (See www.ethicsmattersinc.org/documents/conflicts9.17.07d.pdf  second paragraph)

Asked by Ethics Matters to reconsider their opinion, the Ethics Commission refused to do so and instead issued another opinion affirming their decision of no conflict.  Again the Ethics Commission failed to take into account the principal financial conflicts provision applicable to the situation. They advised that because the Member had since resigned, the financial conflicts issue contained in 8-11 (2)(b) was “moot.” (www.ethicsmattersinc.org/documents/conflicts12.20.07.pdf ) It is distressing that the Ethics Commission made no effort to correct its mistake, and instead chose to reaffirm their prior, published decision of no conflict which ignores the law and will certainly lead others astray.

Meanwhile, advised that there was no conflict, the resigned Member continued to act as a member of the Ethics Commission, participating in its discussions and voting on issues before it - while at the same time having a financial interest in the Counsel's law firm.  This is, simply put, a situation expressly prohibited by the Ethics Law.

It is particularly unfortunate that this situation involves the Ethics Commission itself.

The Ethics Commsiion is accountable for both its good works and for its mistakes.  Ethics Matters has noted their good works at evey opportunity.  We hope that the Ethics Commsiion will recognize the presence of a prohibited conflict in this situation by withdrawing their two erroneous and misleading opinions.

 

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Posted on 22 Jan 2008

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