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<br />99-54 December 20, 1999 <br /> <br />In RQO 99-54, the Ethics Commission opined on the two year rule as it applied to a former <br />County Aviation Department employee and his subsequent employment as a subcontractor <br />providing technical assistance to a third party to develop the Opa- Locka Airport. The Ethics <br />Commission ruled that the former County employee was not prohibited from doing the proposed <br />work on the project, provided it involved no lobbying of County employees or officials, per <br />Section 2-11.1 (q), <br /> <br />99-41 October 14, 1999 <br /> <br />In RQO 99-41, the Ethics Commission addressed the applicability of the two year rule to a <br />former Chief of Staff to Miami Mayor Suarez and his subsequent work as a consultant for a <br />medical firm which was renegotiating a contract with the Public Health Trust. Prior to his <br />position with the County, the employee had worked for Internal Medicine Consultants of Dade <br />("IMCD"). The Ethics Commission found that the two year rule outlined in Section 2-11.1( q) <br />did not prohibit him from renegotiating the contracts with the Public Health Trust because he <br />was not an employee of county government at the time he previously worked for IMCD and the <br />Conflict of Interest Ordinance only prevents employees from lobbying before the entity of which <br />they were a former employee. <br /> <br />99-26 July 27, 1999 <br /> <br />In RQO 99-26, the Ethics Commission opined on the two year rule as it applied to a former <br />County executive who was subsequently employed by American Airlines to serve as Community <br />Affairs Coordinator for the airline. The scope of work included, among other things, serving as a <br />member of the North Terminal Development Team ("NTDT") and reviewing minority <br />participation goals, which were subject to review by the County Commission. <br /> <br />The Ethics Commission found that the employee could assist minority subcontractors and work <br />with NTDT. However, the Ethics Commission found that the employee could not formulate or <br />review the minority participation goals because such activity would violate the two year post <br />employment restrictions, per Section 2-11,1 (q). The Ethics Commission found that such activity <br />constituted "lobbying" within the meaning of Section 2-11.1 (s), because it involved "seeking to <br />encourage the passage, defeat or modification or ordinances, resolutions, actions or decisions of <br />the County Commission, boards or personnel." <br /> <br />99-11 April 6, 1999 <br /> <br />In RQO 99-11, the Ethics Commission opined whether two former County employees who <br />formed their own computer consulting firm could contract with the County to provide computer <br />services. The Ethics Commission found that the two year post employment restriction found in <br />Section 2-11.1 (q) did not prevent them from contracting with the County. <br />