Ordinance 2010-349 - Laserfiche WebLink

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- obtain building permits for clients may also be considered "lobbying, dependent on the circumstances.' , Regarding the second issue presented, the Ethics Commission determined that the submission of routine administrative requests or applications is permissible and does not violate the two year post employment restriction. The Ethics Commission broadly construed the two year post employment restriction, specifically stating the following: "lobbying by former employees contemplates a broad interpretation and common understanding of the word 'lobbying' by capturing activities and subject matters which may not be precisely outlined by subsection (s) in its definition of 'lobbyist." (emphasis added), In accordance with this broad interpretation, the Ethics Commission opined that "communications and activities, whereby former employees are trying to persuade County staff on a particular course of action or to make some determination, are considered 'lobbying'." 02-68 June 27.2002 In RQO 02-68, the Ethics Commission addressed the applicability of the two year rule to a former Deputy Chief of Staff and General Counsel to Mayor Penelas who formed his own consulting company and sought to lobby the Empowerment Trust, a not for profit 501(c)(3) corporation. The Ethics Commission ruled that the former County employee could lobby the Empowerment Trust Board members and neighborhood assembly persons, since the Empowerment Trust was an independent not for profit corporation and its board members and neighborhood assembly persons were not considered County officials. However, the Ethics Commission ruled that in accordance with the two year prohibition, the former County employee could not lobby Empowerment Trust employees or any County official in regards to Empowerment Trust business. 01-38 April 5. 2001 In RQO 01-38, dated, the Ethics Commission construed the applicability of the two year rule to a former aid to County Commissioner who subsequently worked for a law firm as an associate. The Ethics Commission ruled that the two year rule outlined in Section 2-11.1 (q) "is broad and would cover any activity where the employee attends meetings and is publicly identified as part of a lobbying team employed by the principal." The Ethics Commission noted that the associate could attend quasi judicial hearings and County Commission meetings, but only for purposes of "provid[ing] administrative support if he is not publicly identified as a member of the lobbying team." 01-01 January 22, 2001 In RQO 01-01, the Ethics Commission addressed the issue of a former Director of the Department of Planning and Zoning who subsequently worked as a consultant to the County for purposes of revising its Zoning Code. In analyzing the extent of the two year post employment