Category Archives: Ethics

Ethics, Montgomery County Council, Montgomery County Planning Board

Planning Board Proposes to Redefine “Public Hearings” Instead of Holding Them

Yesterday, Montgomery County Council President Gabe Albornoz sent a letter to the Planning Board demanding more transparency, including that they cease abusing their Consent Agenda for discussions of “major amendments” to plans that require public hearings.

They don’t seem to have received the message.

Instead of offering a mea culpa for their past flagrant violations of the zoning code, they excuse themselves, claiming: “Items are placed on the Consent Agenda for votes when they have not generated controversy.” Except that how do you know there is no controversy without holding a public hearing? And if there is no controversy, why not just put it on the regular agenda and just move along if no one wants to testify instead of signalling and pre-judging the question?

Beyond offering no apology, the Planning Board’s proposed “solution” is to redefine “public hearing” to include Consent Agenda items:

“Public Hearing” or “hearing” means a duly-noticed Summary Hearing (emphasis added) or Full Hearing held before the Planning Board, open to the public, and providing an opportunity for any Person, including the general public or Applicant, to appear and present written or oral evidence, cross examination, or rebuttal, all subject to the provisions in these Rules.

Buried in the Rules of Procedure are also new explanations that items can easily be moved from the Consent to Regular Agenda. However, unless a member of the public goes spelunking in the Rules, they are unlikely to know. Meanwhile, the item remains on the Consent Agenda even though the clear intent of the Code is to require genuine public hearings on major amendments.

Poof! Problem solved!

If Planning Board members were really interested in transparency, they could start by providing a tracked changes version of the document, instead of forcing the public to suss out the changes. These legalistic changes might not even solve their problem as they may still violate common law–not to mention common sense–definitions of a “public hearing.”

It is clear that Planning Board Chair Casey Anderson and possibly the rest of the Board have missed Council President Albornoz’s message. After all, Albornoz could have proposed an amendment to the zoning code instead of pushing for transparency. Nevertheless, the Board has chosen the route of less transparency by redefining “public hearing.”

The Planning Board’s statement begins “We take transparency very seriously.” They then proceed to provide excuses for all of their violations of lobbying registration and open meeting requirements along with this “fix” of their Consent Agenda problem. Their response further undercuts confidence in the ability of the Planning Board to conduct the public’s business in a genuinely fair and transparent manner.

If you wish to testify regarding the proposed changes on February 10 at 9am, you can sign up here. Perhaps the Planning Board might consider holding the hearing on this issue before it goes through its lengthy Consent Agenda.

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Ethics, Lobbying

CSG Snaps Back

The Coalition for Smarter Growth seems to think I was wrong to expose their and Jane Lyons’s ethical violations and put out a statement to that effect.

Before they get to attacking me for exposing their dirty laundry, the executive director says he takes “full responsibility” and says that they “have implemented an improved tracking system to ensure such an oversight does not happen again.” It’s great that he takes full responsibility, though it’s unclear that this has resulted in any consequences for him or Jane Lyons.

Nonetheless, they quickly move from taking “full responsibility” to attacking the messenger:

Mr. Lublin’s two posts impugn the reputation of a young and extremely accomplished person — a 2019 graduate of the University of Maryland who has demonstrated utmost integrity in advocating for policies which she and the Coalition for Smarter Growth believe to be important for our collective future.

We believe Mr. Lublin’s attack on Ms. Lyons is driven primarily by his policy disagreements with CSG. Of greatest concern to us is that Mr. Lublin has ignited a round of online harassment and intimidation on Twitter, Facebook, and NextDoor that is is all too common today, as he must certainly be aware.

I don’t see how not registering as a lobbyist in a timely manner demonstrates “utmost integrity” in lobbying. I mentioned Ms. Lyons’s credentials and accomplishments in my post yesterday. It doesn’t explain why she didn’t register or why CSG failed to make sure she did. College educations make people better able to navigate bureaucracy. One reason education is the demographic that best predicts voting is that it gives you the skills to navigate the barriers to getting on the rolls.

In terms of my views, I agree with CSG on some issues and disagree on others. If you summed up my perspective, it would probably be that I agree with the broad thrust of where they want to go but think they are sometimes are overzealous. In any case, it’s a strange and new notion that people can only point out failings on the part on people with whom they agree all of the time.

It’s certainly not an approach that CSG and their allies have taken in their own attacks and would seemingly have prevented them from issuing their own “personal attack” to discredit me. Recently, CSG attacked both an individual homeowner as a hypocrite and anti-Thrive 2050 protestors generally in a press release. And they and their friends haven’t shied away from attacking the ethics of their opponents.

One area I do very much agree with CSG is the lamentable state of social media. That’s why (unlike CSG) I stopped putting out blog posts on Twitter and Facebook. (I’m sufficiently a philistine that I had to look up NextDoor after reading their statement.) While some people manage the rare feat of holding thoughtful discussions, social media promotes incredible negativity and piling on.

Again, I have never seen CSG object when their supporters engage in this behavior and attack people who disagree with them. Today, in fact, CSG Executive Director Stewart Schwartz liked a tweet by former Councilmember George Leventhal (a guy not exactly known for being unwilling to attack people) suggesting that I’m a misogynist. I haven’t seen the harassment of Lyons mentioned here but I hope it is no worse than served to me on occasion. “Politics ain’t beanbag” so I’m not surprised people are unhappy with me on occasion even if, like CSG and Lyons, I might wish they were kinder about it.

I received a polite email from a friend of Lyons telling me that they have found her an ethical and thoughtful person. I don’t know Lyons but I am not surprised that people find her this way. Effective advocates usually are personable and, while CSG and Lyons have their perspective on the issues, they are certainly informed and knowledgeable–as are their opponents. But she and CSG should have been on top of these problems. I’m glad they’ve taken the time to address them.

CSG is an influential, effective organization with tight links over at the Planning Board and the County Council as well with business interests. Indeed, Councilmember Hans Riemer complimented Jane Lyons for “chairing” the discussion on Thrive 2050. Clearly, I’ve stepped on some powerful and influential toes.

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Ethics, Lobbying

Coalition for Smarter Growth Lobbyist Didn’t Register with State

Coalition for Smarter Growth Lobbyist Jane Lyons did not register with the State of Maryland despite having testified before the Montgomery County delegation on behalf of the Coalition for Smarter Growth in December 2020. Lyons is the paid Maryland Advocacy Manager of the Coalition, so she is required to register under the law. Paid lobbyists must register unless they earn under the $2500 minimum compensation for related activities.

This new violation of state lobbyist law follows on last week’s report that Lyons failed twice to register as a lobbyist with Montgomery County. She did this despite knowing about the county legal requirement since she had registered previously.

This repeated failure to comply with lobbying laws contrasts with CSG’s touting that Lyons’s experience “spans multiple levels of government” including the “Maryland General Assembly” and a “fellowship at the Montgomery County Council.” Lyons has an BA and Master’s in Public Policy from the University of Maryland, College Park.

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Ethics, Lobbying, Montgomery County

Coalition for Smarter Growth Lobbyist Didn’t Comply with County Ethics Law

Lobbying laws? What lobbying laws?

Jane Lyons, a lobbyist for the Coalition for Smarter Growth, failed to register as a lobbyist during 2020 despite conducting paid lobbying activities on behalf of the organization.

The evidence appears on the Montgomery County Ethics Commission website. Timestamps on the reports reveal that they were not submitted until the end of July 2021, well after the filing deadline.

Jan 1-June 30, 2020 Report Timestamp
July 1-Dec 30, 2020 Report Timestamp

But she need not worry. It turns out that Montgomery County’s lobbying laws have no teeth. According to Robert Cobb, Staff Director and Chief Counsel of the County Ethics Commission, there is no real penalty for failing to register or to report earnings:

Typically, we will have no idea if a registration is made late because we normally do not have insight as to when (or even if) the criteria for registration has been met. If someone registers for a prior year, that is likely to suggest non-compliance with the lobbying requirements. We have not sought to penalize entities when they subsequently register after having been notified by the Commission of registration requirements.  We have emphasized obtaining compliance.

Cobb goes on to explain why they do not enforce penalties:

[A] program of aggressive seeking of penalties for non-compliance would affect the non-profit communities the most.  Non-profit enterprises occasionally engage in lobbying activity and trip the registration requirements without registering.  This may be a consequence of inadvertence or lack of sophistication in meeting regulatory requirements.  Nonetheless, we have again focused on obtaining compliance rather than instituting punitive measures.

Except that Lyons cannot plead ignorance of the law because she had filed reports in 2019 when she had also acted as a paid lobbyist.

From the way Cobb tells it, lobbyists have little to fear:

In theory there could be a situation where an entity repeatedly fails to register and is intransigent towards efforts to obtain compliance that Commission staff or the Ethics Commission itself believes warrants further action including imposition of a penalty.  This would require compelling evidence of noncompliance and persistent reluctance to register.

In other words, the Commission doesn’t even engage in public sanction for failure to comply, let alone impose a meaningful monetary penalty. If lobbyists like Lyons who clearly know better can avoid even the slightest sanction by filing whenever, it is hard to see how public interest in knowing who is being paid to lobby in a timely fashion is being served.

Ethics, schmethics.

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Ethics, Montgomery County Planning Board

Planning Board Violated Open Meetings Act

Like many institutions, the Montgomery County Planning Board has taken to holding meetings online during the pandemic. Incredibly, they chose not to give public notice about how members of the public could attend the meeting online.

Del. Al Carr (D-18) filed a complaint on November 1 alleging that the Development Review Committee (DRC) of the Montgomery County Planning Board repeatedly violated the Open Meetings Act by failing to provide the public this information.

Unbelievably, the Planning Board Counsel, overseen by Planning Board Chair Casey Anderson, defended this decision as acceptable because there was no physical location for the meetings:

Since March 2020, due to the COVID-19 pandemic, the DRC meetings have been held via Microsoft Teams. Someone wishing to join the Teams meeting would call the Information Counter (number provided on the website) and request to be added to the Teams meeting. There was no in-person option so no “location” was required.

The Open Meetings Compliance Board did not agree:

We believe the DRC construes the Act’s notice requirement too narrowly. The purpose of § 3-302(b)(2) is to ensure that members of the public who would like to attend a public body’s meeting have enough information to be able to do so.

An individual cannot attend a meeting without knowing where the meeting will take place. And while a virtual meeting may not happen in a physical location in the traditional sense, a person hoping to attend the meeting must still know where to go to observe the public body’s business. . .

The notices further indicated that “project applicants and their team” would receive information about “how to participate in the DRC meeting[s]” remotely. But the notices gave no indication of how an interested member of the public could obtain access information for the meeting. In its response, the DRC asserts that “[s]omeone wishing to join [a] Teams meeting would call the Information Counter” and “request to be added to the Teams meeting.” But the DRC fails to explain how an individual interested in attending such a meeting would even know to call “the Information Counter” or where to find that number, as such details are missing from the meeting notices.

Notice that the Board not only called out the Planning Board for failing to provide the information but also for their disingenuous claim that members of the public would somehow magically know to call the Information Center to be added to the meeting.

As with M-NCPPC’s complete ignoring of lobbying disclosure requirements and failure to address this ongoing violation despite their assurances, the Planning Board’s failure shows contempt for ethics laws and the public that they are supposed to serve.

In this case, the Planning Board finally altered its behavior in response to Del. Carr’s complaint But it should not take action by a member of the General Assembly for the Montgomery County Planning Board and M-NCPPC to comply with ethics laws.

And why didn’t the County Council, which has responsibility for appointing and overseeing the Planning Board, take action? Or do they condone this illegal nexus between the Board and the interests that they are supposed to regulate.

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Ethics, Lobbying, Montgomery County Planning Board

M-NCPPC Violating Ethics Laws and its own Lobbying Policy

Maryland Public Ethics Law mandates that the Maryland National Capital Park and Planning Commission (M-NCPPC), a bi-county agency which includes the Montgomery and Prince George’s Planning Boards and other departments, require disclosure by lobbyists.

Towards that end, M-NCPPC adopted a policy on lobbying disclosure in 1983, which was amended in 1985. The policy requires lobbyists to register with M-NCPPC and to file a report annually with the Commission. Paid lobbyists should be reporting expenditures on meals, entertainment and gifts to Commissioners or their employees in addition to their compensation and monies spent on lobbying materials and research subject to certain regulations and thresholds.

The current Commission does none of this.

That means that lobbyists before the Planning Boards, which handle decisions with incredible monetary impact, aren’t registering or filing reports. A recent evaluation in by the Office of the General Counsel in response to a citizen complaint, reveals that even the old policy doesn’t fully comply with current law.

You can read M-NCPPC’s Office of the General Counsel’s recent report and review the 1985 policy below. Even their own counsel says that M-NCPPC is way out of compliance: “no lobbying registrations had apparently been filed in recent memory.”

Montgomery and Prince George’s need to wake up. Montgomery has always prided itself on being a squeaky-clean reform county, but its own Planning Board has failed to enforce any of its own or Maryland’s ethics requirements even though its decisions and recommendations can provide many millions in benefits to people invested and involved in property development.

This raises serious questions. Why hasn’t the Commission or either Planning Board done anything to enforce ethics regulations related to lobbying? Why has Planning Board Staff failed to carry out the Board’s adopted policy? Why didn’t the Office of the General Counsel make sure that M-NCPPC was in compliance up until now?

At the end of its report, the Office of the General Council states:

OGC recommends that the Commission promptly complete the process for a substantial overhaul of its lobbying regulations. The Commission’s executive team has made a commitment to revise and adopt new, clarifying lobbying regulations before the end of the 2021 calendar year, and to launch an energetic campaign of public education to introduce them after adoption.

None of that has happened.

The report was supposed to be discussed finally at the December 2021 M-NCPPC Board meeting but was yanked from the agenda at the last minute. In other words, M-NCPPC has already failed to honor its “commitment” to clean up this ethics mess by the end of 2021.

The Montgomery and Prince George’s County Councils, which fund and appoint each county’s Planning Board, need to investigate quickly and ensure that a new, cleaner regime arrives at the Planning Board’s new Wheaton headquarters with officials and planners willing to abide by and to enforce the law.

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Adam Pagnucco, COVID-19, Department of Liquor Control, Ethics, Fire Service, Judicial Elections, MCDCC, MCEA

The Top Twenty Seventh State Posts of 2020, Part Two

By Adam Pagnucco.

Yesterday, we listed posts 11 through 20 in terms of page views for the year 2020. Here are the top ten.

  1. Volcano in Rockville

In the wake of former Chief Administrative Officer (CAO) Andrew Kleine’s admitted ethics violations, County Executive Marc Elrich wanted him to stay in his job. But the county council was outraged by the scandal and exploded in public fury. The council’s anger wound up forcing Kleine out and opened the door to the ascension of the new CAO, former county budget director and state senator Rich Madaleno.

  1. Repeal the Linda Lamone for Life Law

The problems with the 2020 primary election prompted this historical post summarizing why the state has a law protecting its elections administrator, Linda Lamone, from accountability. Comptroller Peter Franchot and Lieutenant Governor Boyd Rutherford called for Lamone’s resignation but she survived for the thousandth time. Thankfully, the general election was a smoother affair than the primary.

  1. Sitting Judges Get Temporary Restraining Order Against Pierre
  2. Progressive-Backed Judge Candidate Courted, Donated to Republicans
  3. Judge Candidate on Floyd Cops: “Lock Em Up”

It’s fitting that these three posts finished back-to-back-to-back because they all concern the nastiest judicial election in recent MoCo history: the challenge by attorney Marylin Pierre to four sitting judges. This one had a LOT going on: partisanship, charges of racism, charges of lying and even a temporary restraining order. The whole thing cast a foul odor over the ballot box and led me to conclude that judicial elections should mostly be abolished.

  1. Harris Blasts MCEA Over School Reopening

School board elections are mostly sleepy affairs in which candidates agree at least 90% of the time and the only difference between them is which ones are endorsed by the Apple Ballot and the Post. Not this year! MCPS’s boundary study dominated the primary and school reopening took the spotlight in the general, with Lynne Harris (the Post’s candidate) blasting the teachers union for allegedly resisting reopening. Harris told Blair High School’s Silver Chips newspaper that the teachers “were obstructionist, inflammatory, and just said ‘no’ to everything.” That provoked a furious response and the teachers are unlikely to forget it.

  1. What’s More Important? The Liquor Monopoly or a Thousand Bartenders?

Early in the COVID crisis, Governor Larry Hogan gave counties discretion to allow restaurants to offer takeout and delivery of mixed drinks. Many other states and the City of Baltimore allowed it, but MoCo’s liquor monopoly did not. The issue prompted a mass revolt by restaurants and consumers and the county ultimately allowed it.

  1. IG Investigates “Overtime Scam” in the Fire Department

County Inspector General Megan Davey Limarzi blew the lid off county government with her landmark report on an overtime scam in the fire department. The scandal involved more than $900,000 of overtime which exceeded limits set by the fire chief and was scheduled outside of the system usually used by county public safety agencies. Readers were all over this but I have not heard of anyone being disciplined for it. As of this writing, this is the sixth most-read post in the history of Seventh State measured by page views.

  1. Restaurant: My Staff Will Not Wear Face Masks

Last July, The Grille at Flower Hill in Gaithersburg posted this on Facebook: “Let me be very clear…my staff will not wear face masks while working here at the Grille. If that bothers you then please dine elsewhere and please try to find something more important to occupy your time such as volunteer at a nursing home or soup kitchen. Whoever you are that filed the complaint, you need to take a good look in the mirror and try to find some real meaning in your life.” The post provoked a huge firestorm from irate customers resulting in the permanent closure of the restaurant four days later. As of this writing, this is the fifth most-read post in the history of Seventh State measured by page views.

  1. MoCo Democrats Issue Statement on Ballot Questions

This post reprinted the Montgomery County Democratic Party’s statement on the four ballot questions. It was originally published on September 17 and initially attracted little site traffic. But it started to pop in early and mid-October and dominated page views in the latter part of the month. Most of the traffic was generated by Google searches. This provided valuable intel: thousands of people were seeking out what the Democratic Party had to say about a group of arcane and confusing ballot questions. And if they were coming to Seventh State, they were no doubt also visiting other sites with similar information like news outlets and the party’s own site. In the end, it seems likely that the party was the dominant force in driving voter reaction to the ballot questions as its positions carried the election by double digits. It was also a huge boon to us as this post ranks third in page views in the history of Seventh State.

On to 2021!

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Adam Pagnucco, Andrew Friedson, Ethics

Real Deal Ethics Bills

By Adam Pagnucco.

The ethics scandal involving MoCo’s former Chief Administrative Officer (CAO) was a trying moment for the county government but it has produced a happy outcome: the introduction of two robust ethics bills by Council Member Andrew “Real Deal” Friedson. Together, the two bills – if passed – will ensure that the events leading to the now-former CAO’s resignation will never happen again.

Quoting the introduction packet, Bill 42-20 would:

1. Require the Executive to disclose a proposed employment contract with an appointee to a non-merit position and any employment contract with an employee currently serving in a non-merit position to the Council;

2. Include the sale or promotion of certain intellectual property by a public employee as other employment;

3. Prohibit a public employee who has received compensation from an individual or organization in the previous 12 months from participating in a procurement with that individual or organization;

4. Require a public employee who participates in a procurement process with an individual or organization seeking to do business with the County that compensated the public employee for services performed more than 12 months before the participation began to disclose the prior relationship to the Procurement Director;

5. Require an elected official or non-merit employee to disclose, with some exceptions, the source of each fee greater than $1,000 received for services in a financial disclosure statement; and

6. Prohibit the Chief Administrative Officer from engaging in other employment.

Bill 43-20 would prohibit severance pay to non-merit employees. The bill’s language says:

The Executive or a Councilmember must not authorize any payment of money or paid administrative leave to a non-merit employee in the Executive Branch or in the Legislative Branch upon separation from County employment unless the payment is expressly authorized by law. The Executive or a Councilmember must not enter into an employment agreement with a non-merit employee that provides for any type of severance pay for an employee who is terminated with or without cause.

The bill allows payments of unused leave and discontinued pensions. It expressly prohibits “severance pay for an employee who admits to or is found to have violated the Ethics Law in the 12 months prior to separation from County employment.”

These bills are an absolute no-brainer. The entire county council should be all over them like white on rice.

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Adam Pagnucco, Ethics, Marc Elrich, Rich Madaleno

End of the Line for Kleine

By Adam Pagnucco.

Chief Administrative Officer Andrew Kleine, who admitted to two ethics violations and attempted to cure them through a $5,000 payment and other remedies, has resigned. County Executive Marc Elrich has announced that former State Senator and current budget director Rich Madaleno will succeed him subject to confirmation by the county council.

Originally, Kleine was set to remain in his position. Bethesda Beat reported this on July 7:

County Executive Marc Elrich, in a statement to Bethesda Beat on Monday, wrote that Kleine is a “committed public servant” and that the CAO’s agreement with the Ethics Commission “resolves the matter.”

“Andrew has acknowledged that his actions were an error in judgment and has accepted responsibility for his actions,” he wrote. “I appreciate that Andrew has cooperated with the Ethics Commission’s investigation from the very beginning to resolve this situation.”

But the matter was far from resolved. On July 28, the county council discussed the ethics report and erupted with fury. Multiple council members vowed to obtain more information about the issue, guaranteeing that it would not die as long as Kleine remained. That forced Elrich’s hand and resulted in today’s announcement, the first resignation of a MoCo Chief Administrative Officer due to ethics issues that anyone can remember.

Elrich’s press release appears below. If there is a severance package, the release does not mention it.

*****

County Executive Marc Elrich Nominates Budget Director Rich Madaleno to Serve as New Chief Administrative Officer Following Andrew Kleine’s Resignation
For Immediate Release: Wednesday, Aug. 12, 2020

County Executive Marc Elrich today announced that he will nominate Richard Madaleno as the Chief Administrative Officer (CAO) for Montgomery County. Madaleno’s nomination follows the resignation of Andrew Kleine, who has served a CAO for the first 20 months of the Elrich Administration. Madaleno will begin serving as acting CAO on Aug. 16.

County Executive Elrich expressed appreciation for Kleine’s many contributions to the County Government. “During his time as CAO, Andrew Kleine led the County Government’s effort to reorganize services ranging from public safety to technology services,” said Elrich. “He championed a Turn the Curve initiative to empower County employees to rethink and improve the delivery of services to our million-plus residents. Over the past five months, he has played a critical role in our community’s response to the coronavirus pandemic. I thank him for his many contributions and wish him well in future endeavors.”

Madaleno, who is serving as the Director of the Office of Management and Budget, is a lifelong Montgomery County resident. He has spent his career serving the people of the County in leadership roles at the County and the State levels and had a long career as an elected representative for Montgomery County in the Maryland General Assembly. He served from 2003-2007 in the Maryland House of Delegates and from 2007 to 2019 as a State Senator representing District 18. While in the Senate, Madaleno was the Vice Chair of the Senate Budget and Taxation Committee where he was known for his ability to find solutions to some of the most challenging budget problems facing the state. He was a leader in education reform serving on the Kirwan Commission. Madaleno also worked in the County’s Office of Intergovernmental Relations from 1995 to 2002.

“Rich is trusted by community groups and policymakers throughout the County and State for his leadership skills and budgeting acumen, which will serve the County well as we face the most significant challenges of our generation,” said Elrich. “I am confident that his experience and expertise will help my administration deliver on my promise to build a healthy, well-functioning, innovative, equitable and inclusive community for all of our residents.”

The County Executive’s CAO nomination must be approved by the Montgomery County Council. Councilmembers are scheduled to return from their summer recess in Sept.

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Adam Pagnucco, Ethics

MoCo Finally Bans Tax Dollars for Kleine’s Book

By Adam Pagnucco.

Roughly a year after the Montgomery County Ethics Commission began receiving complaints about Chief Administrative Officer Andrew Kleine’s promotion of his book, the county has finally banned the use of tax dollars to purchase it.

The ethics commission’s report states that county employees began complaining about Kleine “during the summer of 2019.” The commission requested that the county’s inspector general begin investigating Kleine on September 4, 2019. The inspector general completed the investigation and sent a report to the ethics commission on December 12, 2019. At some point thereafter, Kleine offered a proposal to “cure” the issue which the ethics commission accepted and signed on July 1, 2020.

The ethics commission’s report states that the county bought 89 copies of Kleine’s book from October 1, 2018 through September 30, 2019 for a total of approximately $3,000. It contains no information about book purchases since then.

On July 20, 2020, Deputy Chief Administrative Officer Fariba Kassiri – who reports directly to Kleine – sent out the email below to county managers advising them that county funds cannot be used to purchase Kleine’s book so long as he remains a county employee. The amount of county money spent on the book between September 30, 2019 and July 20, 2020 has not yet been reported.

*****

From: Kassiri, Fariba Fariba.Kassiri@montgomerycountymd.gov
Sent: Monday, July 20, 2020
To: #MCG.Department & Office Directors MCG.DepartmentOfficeDirectors@montgomerycountymd.gov
Subject: Restricted Book Purchase

Department and Office Directors,

In accordance with the CAO’s Proposal to Cure certain violations of the Ethics Law and the Ethics Commission’s subsequent acceptance of the proposal on July 1, 2020, I am advising you that your Department/Office should not purchase any copies of City On The Line by Andrew Kleine, so long as Andrew remains County employee. This means no purchases can be paid for through the Oracle system, by P-Card or by reimbursing employees for the purchase of this book.

Please share this information with your appropriate staff and let me know if you have any questions or need additional information.

Thank you,

Fariba Kassiri
Deputy Chief Administrative Officer
Montgomery County, Maryland
Offices of the County Executive

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