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<br />- <br /> <br />about how to modify building plans. <br /> <br />In 2008, Carlos Bonzon, a former Assistant County Manager, was allowed to attend public <br />meetings as a principal of a firm that was attempting to do business with the County as long <br />as he did not speak or hold himself out as a representative of the business.4 The rationale for <br />this opinion was that the Sunshine Law entitles everyone to attend public meetings, including <br />the former employee.5 <br /> <br />II. CONCLUSION <br />Based on the foregoing, under the County Code, former government employees are not <br />lobbying when they give testimony in publicly noticed quasi-judicial proceedings. <br />Consequently, they do not violate the prohibition on appearing before their respective <br />governments for two years following their separation from government employment. <br /> <br />Because the city lobbying ordinance differs significantly from the County Code,6 and because <br />the City Code authorizes the City Attorney to interpret both the County and City Ethics <br />Codes,7 the requestor will likely be bound by the opinion of the City Attorney in this <br />particular matter. <br /> <br />4 RQO 08-] 7, opinion given to Luisa Millan-Donovan, Chief, Professional Contracts Division, County <br />Office of Capital Improvements. <br /> <br />5 INQ 07-61, informal opinion given to Carlos Bonzon prior to his formal request in 2008. <br /> <br />6 The Sunny ]sles Beach Code does not allow for many of the exemptions found in the County Code under <br />Lobbying. In the City Code, only those who represent nonprofit entities, without special compensation or <br />reimbursement for the appearance, may seek an exclusion from paying the city lobbyist registration fee. <br />However, they must register as lobbyists with the City Clerk. Sunny Isles Beach City Code at Sec. 33-2 B. <br /> <br />7 Sunny Isles Beach Code at Sec. 33-3 Q. <br /> <br />RQO ]0-19 Poliakoff <br />July 20, 20 I 0 <br />30f3 <br />