HomeMy WebLinkAboutLindemannPatrick Affidavit Disclosure 1989 (2) r
October 20 , 1989
Council President Blair and Members
of the Lansing City Council
loth Floor , City Hall
Lansing , Michigan 48933
Dear Councilmembers :
Attached herewith for your information is an Affidavit of
Disclosure from Patrick Lindemann, First Ward Councilmember .
Sincerely,
Rita M. Bauman
City Clerk
REFERRED TO THE BOARD OF ETHICS
CITY OF LANSING
BOARD OF ETHICS
T0: OFFICERS AND EMPLOYEES
WHO FILED DISCLOSURES OF CONFLICTS OF
INTEREST PRIOR TO MARCH 11 1989
The Board of Ethics has attempted to review a disclosure of
t 'pled by you. Your disclosure
contains
a conflict of interest - however. To assist
insufficient information to allow such,ieeaeb' law, the Board of
you to make the full disclosure required y
Ethics has adopted a revised o o fuse or use his in disclosing
fo1icany
While you are not required ` for
disclosure you file must contain the ;�?fO`�'Gion with blank nform
Enclosed is a copy
of vour original filing , g
with instructions , which you are requested to complete and resubmit
Clerk as soon as possible.
to the City
contract with the Ci_y, he
If vou_r disclosure pertains to a t
MCL 15 .323 ( c) . To ..ne
MU contain the information required by ;t must meet
ertains to other government decisions , "Blanket
extent it p disclosure.
Charter rern=i rements for a fu11 and complete charter
do not comply with either state law or Tare required
disclosures" t Ofr; cers and employees are
and ordinance Tequirements. specific transacuion
to r-1e a separate disclosure for each
po�ential con`lict of in merest before any
involving an actual or - Iso indicate
dealing with the City 6-akes place. A disclosure Teso mve � he d-sclosed
how the oi_icer or employee =ntends �o
conflict.
t completing and returning the
Your Cooperation in promptly y
' enclosed form v,ill be appreciated.
THE ;,ANSING BOARD OF ETHICS
�l
F
1
1
CITY OF LANSING
TO: [K] CITY CLERK
�] CITY ATTORNEY
�] MAYOR
[K] CITY COUNCIL PRESIDENT
I ] DEPARTMENT HEAD
AFFIDAVIT OF DISCLOSURE
OF
CONFLICT OF INTEREST
STATE OF MICEIGAN)
COUNTY OF Ingham )
Patrick Lindemann , being duly sworn, says
under oath:
1. I am an elected or appointed officer or employee of the
Ci ty of Lansing, holding the position of First-Ward Councilmember
in the Lansing City Council Department.
This position is: [ ] Fulltime Part-time ( less than 25 hours/wk)
[ ] Unpaid.
2. [ ] I, and/or I ] my a member of my
immediate family as defined in Ordinance 290. 02 U) , and/or
[ ] Caster and Associates , a business with
which I an associated as defined in Ordinance 290. 02 (b) , ( c) and
(d) :
[ ] a. may receive a financial benefit of more than a de
minimus nature which is distinguishable from the benefits to the
person as a member of the public or as a member of a broad secrment
of the public,' from a decision I would . otherwise make or
participate in as an officer or employee. The decision involved
is described as follows: the resolution dealing with the Parking Package
being passed on October 23, 1989, the naraQranh regarding the purchase of
properties involved, and what is described as, the Triangle, boardering
Grand River, Kalamazoo Street, Grand Avenue and Washtenawe Street.
The financial benefit will be received by the following
persons in the following amounts: Jim Caster — Broker of Caster
and Associates Amount Unknown
fit] I will not mare or participate in the making of the
affected decision, or
[ ] Despite the conflict of interest, I am able to make or
participate in the making of the affected decision fairly,
objectively, and in the public interest because: N/A
[ ] b. intend to have business dealings with the City of
Lansing, either directly or indirectly. The business dealings are
specifically described in detail as follows (include names of each
party, the duration of the dealings, the financial consideration
between the parties, the governmental facilities or sera,-ices
.involved, the nature and degree of assignment of government
emplovees for ful-fillment of dealings, and the nature of any
pecuniary interest): N/A
--. 2
] I will not make or participate in the making of
a_overnmentaI decisions concerning the business dealings, or
[ ]
interest I am able to make or
Despite the conflict of ,
participate in the making of governmental decisions concerning the
business dealings fairly , objectively, and in the public interest
because: N/A
[ ] may derive income or benefits , either directly or
c.
indirectly, in addition to official remuneration, as a result of
Council action. The action involved is described as follows: _
N/A
The income or benefits , in addition to of=icial remunerat or., -what
will be derived, either direc= y ,
or indirectly is descrlp�Q
l as
follows: N/A
�] I
will not make or participat-e in the making or the
affected decision, or
} I am able to make cr
[ ] Despite the con_lict of i nteres"
,n the making of the affected decision
fairly,
participate N/A
objectively, and in the public interest because:
[ ] d. may derive income c_ benefits , either directly cr
indirectly, in addition to official remuneration, as a result of
a contract with the City. The contract is specifically described
in detail as follows (include names of each party, the duration cf
the dealings , the financial consideration between the parties, the
governmental facilities or services involved, the nature and degree
Of assignment of government employees for fulfillment of the
N/A
contract, and the nature of any pecuniary interest) :
] I v,,; Il not make or partyciLaue in the making of
governmental decisions concerning the contract, or
[ ] Despite the conflict of interest, i am able to make or
participate in the making of governmental decisions concerning the
contract fairly, objectively, and in the public interest because:
N/A
[ ] e. have a conflict between a personal interest and the
public interest as defined by state law, the Lansing City Charter,
Or ordinance. The personal =nterest that COnfllCtS with the public
4
interest is described as follows• a member of a Real Estate firm that
I belong to has interest inone of the parcels on the nrooerty in the
aforementioned described paragraph.
that the personal interest conflicts with is
The public interest
described as follows: N/A
[� I will not make or participate in the making of
governmental decisions concerning the conflict, or
[ ] Despite the conflict of interest, I am able to make or
participate in the making of governmental decisions concerning the
Conflict fairly, objectively, and in the public interest because:
N/A
3 . I have attached additional detail on the reverse of this
form or on attached sheets , including copies of all relevant
documents , memos , resolutions , and contracts.
4 . I hereby certify that this disclosure is complete and
accurate to the best of my .knowledge, in'Lormation and belief.
5 . I hereby certify that I have not solicited or entered
th the C_ty of Lansing prior to
into any agreement filing t..i s
ki
of iaaV1t.
The foregoing Affidavit of Disclosure of Conflict of Interest
was executed on the 20th day of 0 er 89
Subscribed and sworn before me the ;c day of QGTa�E/¢-
19—E. 7i,�Z741
,.ary Pub, is
F.P.:DALS.N�'OLFi,S eputy Clerk
Notary Public, Climcr. -Michipri C011nty , 1iiChl�Jan
P.ctin.in Ingha,1 CountN j
My Commission apires Feb,ary 7, 199M y Commission E xv i r e s:
FOR CITY CLERK/CITY ATTORNEY USAGE
DATE FILED:
COPIES SENT TO: j ] Mayor
[ ] City Council President
IJ Depar=ent Head
I J Board of Ethics
ON:
BOARD OF ETHICS ACTION ON:
[ ] Accepted
j ] Rejected
OPINION NO.
6
IKSTRU=_IONS FOR COMPLETING AFpIDAV?'-'
UTHORIZED FOR USE FOR ALL DISCLOSURES OF
THIS FORM IS A
CONFLICTS OF INTEREST. IT REPLACES THE ONE PAGE FORM PREVIOUSLY
DISTRIBUTED BY THE CITY CLERK ' S OFFICE.
THE INFORMATION SUPPLIED IN THIS FORM MUST BE GIVENUNDER
pF,mg, THERE MAY BE EMPLOYMENT , CIV_L AND/OR CRIMILVAL SANCTIONS
ALSE OR MISLEADING DATE OR STATEMENT
IMPOSED UPON ANYONE MAFING A F
ON TEIS FORM.
1 , Question 1 asks for identifying information.
2 . Question 2 asks for details of the conflict Of interest.
} describe your
Choose the alternative or alternatives that com le-eiy .
situation, and comple�e the applicable sections ) P
Incomplete information will result in the filing being rejected by
the Board of Ethics.
3- Questions 3 to 5 apply in all cases .
The completed form should be dated and executed, and your
signature notarized.
r financial conflicts of interest should be filed
Disclosures o�
*ith the City Clerk. Disclosures of nor_f'_nancral conr-�icus c:
A�tcrney . Two copies of
interest should be filed wi th the C 'Y , -v Clerk or the
your Affidavit should also be supplied =moo the C �. -moo the
City Attorney so that it can also be sent, as approprlater
City Council President and your Department Bead,
N;aycr or y
applicable.
After filing, your form will be reviewed by the Board of
��o sta��e law , the chaste-
Ethics for completeness and conformi_y
You will be advi sed if any
and any applicable ordinances. action � s rern,ired.
it further
additional information or - you_ filing-
Generally r the review will occur wi th�.n 2-4 weeks of
Tr seedier review is recru_redr please indicate the dace your
e re6uest, in a separate
is needed by and your reasons for th
letter filed with your affidavit.
COMMONLP AS D 9 ESTIORS
l, Why do I have to f ill out this f o=:m?
Both State law and local charter pZ-cv.5 5icn5 reQL'.re t=Tne-'y
full and complete disclosure, in writing, of actual and ^poten�_al
ccnf li c��s of interest. These prov�sjons have been _Ln e__ec� since
the mid and late 157Us.
2_ When is an officer or employee required to file an Affidavit
of Disclosure?
As soon as a conflict exists, an officer or employee must
promptly file an Affidavit of Disclosure with the City Clerk or the
City Attorney, but in no event less than 10 days before any meeting
of any governing body at which the matter will be discussed or
considered. Where an officer or employee serves on a governing
body responsible for approval of the matter in which there is a
conflict, the disclosure must be made at the same time as the
filing with the City Clerk, to the governing body (the Council
President, in the case of Councilmembers ) and be included in the
public record of the proceedings.
Last minute disclosures , except in an unusual circumstances ,
do not comply with state law or the Charter. However, in the event
the issue unavoidably arises for the "first time a a particular
meeting , the governing body may determine by vote of an affirmative
majority of disinterested members if a conflict exists which
recuires or permits a member to be excused from vo-ing. At -he
very least, the nature of the conflict and the reasons for excusal
or nonexcusL, froir, voting should always appear in the record of -he
meeting. An Affidavit of Disclosure must then be filed as soon as
practibie after the meeting .
3. Does a person have to file an Affidavit of Disclosure on each
transaction in which '-...hey are or may be in conflict, or may the
Affidavit be generic in nature?
An officer or employee must rile an AfLidavi t of Disclosure
on each separate transaction that involves a financial con__ict.
4. What level of detail satisfies the reo7uirement to folly
disclose a conflict of interest?
state law, the Charter and Conflict of Interest O_dirance
require complete and specific details in order to satisfy the
reuiremen=t of a Lull disclosure. The form is designed so that =_
c
^ally completed, it will satisLy the disclosure requirement.
5. Is the pu--pose of the Affidavit of Disclosure to serve notice
that I am unable to speak or vote on a matter, or does it simply
sez—ve as notice to other pa_-ties in the decision making process
that I have a self interest as opposed to a public one?
Both. in the appropriate case, 1t aiso not" `les a governing
body (and the public) , on the record, why the officer orremplovee
with the conflict believes he or she can, in ii gh- of the conflict,
the matter fa yrly,
make or participate in making a decision on
8
objectively , and in the public interest.
6. Is the filing of an Affidavit of Disclosure required even if
I have already been excused from voting or participating in the
decision of the matter?
Yes.
7. What standards of conduct apply if I have a conflict of
interest?
When there is a conflict of interest relative to a public
contract, state law sets the standards of conduct which apply.
Officers and employees who contemplate being a party to a contract
with the City are referred to MCL "15 . s21 et sec. , entitled,
"Contracts Of Public Servants With Public Entities" . As a general
rule, state law prohibits a full time officer or employee from
havina direct business dealings kith the City. Volunteer and part
time officers and employees may, if state law is complied with,
have business dealings with the City. Violation of the state
statute is a misdemeanor.
In all other cases, Chapter 5 of the Charter and Chapter 290
of the Code of Ordinances supply the applicable rules .
Any officer or employee may seek an adviscry-opinion from the
- r
Board of Ethics based on the facts of their speci=ic situation,
they are uncertain about what rules apply to them, e_ about what
they are required to oc to resolve a conflict or interest.
S. Who an I allowed to communicate with about this matter, once
I have filed an Affidavit of Disclosure?
Ir you have a conflict of interest, whether or not you have
filed an Affidavit Of Disclosure, you may not officially Or
unofficially participate in the discussion or consideration of lthe
item in conflict in any way, shape, or form, either directly or
indirectly, either in furtherance of your public responsibilities
or of VOLT private interests , at any stage of the consideration of
the matter in which you have a conflict, except in compliance with
State law or Ordinance 290 .
9 . Does being excused from voting or late filing of an Affidavit
of Disclosure absolve any prior actions I may have taken on behalf
of the matter in which I have a conflict of interest?
No.
October 20 , 1989
Council President Blair and Members
of the Lansing City Council
loth Floor , City Hall
Lansing , Michigan 48933
Dear Councilmembers :
Attached herewith for your information is an Affidavit of
Disclosure from Patrick Lindemann, First Ward Councilmember.
Sincerely,
Rita M. Bauman
City Clerk
REFERRED TO THE BOARD OF ETHICS
CITY OF LANSING
BOARD OF ETHICS
TO: OFFICERS AND EMPLOYEES WED FILED DISCLOSURES OF CONFLICTS OF
INTEREST PRIOR TO MARCH 1 , 1989
The Board of Ethics has attempted to review a disclosure of
a conflict of interest filed by you. Your disclosure contains
insufficient information to allow such review, however. To assist
you to make the full disclosure required by law, the Board of
Ethics has adopted a revised form for use in disclosing conflicts .
While you are not required to use this specific form, any
disclosure you file must contain the information called for in it.
Enclosed is a copy of your original filing, along with a blank form
with instructions , which you are requested to complete and resubmit
to the City Clerk as soon as possible.
If your disclosure pertains to a contract with the City, it
must contain the information required by MCL 15 . 323 ( c) . To the
extent it pertains to other government decisions, it must meet
Charter requirements for a full and complete disclosure. "Blanket
disclosures" do not comply with either state law or local charter
and ordinance reauirements . Officers and employees are required
to file a separate disclosure for each suecific transaction
involving an actual or potential conflict of intLerest before any
dealing with the City takes place. A disclosure must also indicate
how the officer or employee intends to resolve the disclosed
conflict.
Your cooperation in promptly completing and returning the
enclosed form will be appreciated.
THE LANSING BOARD OF ETHICS
CITY OF LANSING
TO: [K] CITY CLERK
[X] CITY ATTORNEY
R] MAYOR
JK] CITY COUNCIL PRESIDENT
[ ] , DEPARTMENT HEAD
AFFIDAVIT OF DISCLOSURE
OF
CONFLICT OF INTEREST
STATE OF MICHIGAN)
COUNTY OF Ingham )
Patrick Lindemann , being duly sworn, says
under oath:
1. I am an elected or appointed officer or employee of the
City of Lansing, holding the position of First-Ward Councilmember
in the Lansing City Council Department.
This position is: [ ] Fulltime Parttime (less than 25 hours/wk)
[ ] unpaid.
2. [ ) I , and/or my , a member of my
immediate family as defined in Ordinance 290. 02 (i) , and/or
[ ] Caster and Associates , a business with
which I am associated as defined in Ordinance 290. 02 (b) , ( c) and
( d) :
[ ] a. may receive a financial benefit of more than a de
minimus nature which is distinguishable from the benefits to the
person as a member of the public or as a member of a broad segment
of the public , from a decision I would . otherwise make or
participate in as an officer or employee. The decision involved
is described as follows: the resolution dealing with the Parking Package
being passed on October 23, 1989, the paragraph regarding the purchase of
properties involved, and what is described as, the Triangle, boardering
Grand River, Kalamazoo Street, 'Grand Avenue and Washtenawe Street.
The financial benefit will be received by the following
persons in the following amounts: Jim Caster -- Broker of Caster
and Associates Amount Unknown
;] I will not mare or participate in the making of the
affected decision, or
[ ] Despite the conflict of interest, I am able to make or
participate in the making of the affected decision fairly,
objectively, and in the public interest because: N/A
[ ] b. intend to have business dealings with the City of
Lansing, either directly or indirectly. The business dealings are
specifically described in detail as follows (include names of each
party, the duration of the dealings, the financial consideration
between the parties, the governmental facilities or services
involved, the nature and degree of assignment of government
emr)lovees for fulfillment of dealings, and the nature of anv
pecuniary interest) : N/A
-__ 2
(g] I will not make or participate in the making of
governmental decisions concerning the business dealings, or
[ ] Despite the conflict of interest, I am able to make or
participate in the making of governmental decisions concerning the
business dealings fairly, objectively, and in the public interest
because: N/A
[ ] c. may derive income or benefits, either directly or
indirectly, in addition to official remuneration, as a result of
Council action. The action involved is described as follows: _
N/A
The income or benefits , in addition to official remuneration, that
Will be derived, either directly or indirectly, is described as
follows: N/A
[X] I will not make or participate in the making of the
affected decision, or
[ ] Despite the conflict of interest, I am able to make or
participate in the making of the affected decision fairly,
objectively, and in the public interest because: N/A
3
I d. may derive income or benefits , either directly or
indirectly, in addition to official remuneration, as a result of
a contract with the City. The contract is specifically described
in detail as follows (include names of each party, the duration of
the dealings, the financial consideration between the parties, the
governmental facilities or services involved, the nature and degree
of assignment of government employees for fulfillment of the
contract, and the nature of any pecuniary interest) : N/A
T will not make or participa,_e in the making of
q_overnmental decisions concerning the contract, or
[ ] Despite the conflict of interest, I am able to make or
participate in the making of governmental decisions concerning the
contract fairly, objectively, and in the public interest because:
N/A
[ ] e. have a conflict between a personal interest and the
public interest as defined by state law, the Lansing City Charter,
or ordinance. The personal interest that conflicts with the public
4
interest is described as follows: a member of a Real Estate firm that
I belong to has interest in one of the parcels on the property in the
aforementioned described paragraph.
The public interest that the personal interest conflicts with is
described as follows: N/A
[�] I will not make or participate in the making of
governmental decisions concerning the conflict, or
[ � Despite the conflict of interest, I am able to make or
participate in the making of governmental decisions concerning the
conflict fairly, objectively, and in the public interest because:
N/A
3 . I have attached additional detail on the reverse of this
form or on attached sheets , including copies of all relevant
documents , memos , resolutions , and contracts.
4 . I hereby certify that this disclosure is complete and
accurate to the best of my .knowledge, information and belief.
5. I hereby certify that I have not solicited or entered
ty of Lansing prior to filing this
into any agreement with the Ci
affidavit.
5
The foregoing Affidavit of Disclosure of Conflict of Interest
was executed on the 20th day of 0 er , 89
Subscribed and sworn before me the day of knvo .FA-
19 .
teary Public
RA;dDALS.Vt'OLFFIS eputy Clerk
Notary Public, Clinten Ccuciy,Michigan County, Michigan
Actin,in Irahan Caaaty
My Commission Expires Febmary 7, 199M y C ommi s s i o n Expires:
FOR CITY CLERK/CITY ATTORNEY USAGE
DATE FILED:
COPIES SENT TO: [ ] Mayor
[ ] City Council President
[ ] Department Head
[ ] Board of Ethics
ON:
BOARD OF ETHICS ACTION ON:
[ ] Accepted
[ ] Rejected
OPINION N0.
6
INSTRUCTIONS FOR COMPLETING AFFIDAVIT
THIS FORM IS AUTHORIZED FOR USE FOR ALL DISCLOSURES OF
CONFLICTS OF INTEREST. IT REPLACES THE ONE PAGE FORM PREVIOUSLY
DISTRIBUTED BY THE CITY CLERK ' S OFFICE.
THE INFORMATION SUPPLIED IN THIS FORM MUST BE GIVEN UNDER
OATH. THERE MAY BE EMPLOYMENT, CIVIL AND/OR CRIMINAL SANCTIONS
IMPOSED UPON ANYONE MAKING A FALSE OR MISLEADING OATH OR STATEMENT
ON THIS FORM.
1. Question 1 asks for identifying information.
2. Question 2 asks for details of the conflict of interest.
Choose the alternative or alternatives that describe your
situation, and complete the applicable section( s ) completely.
Incomplete information will result in the filing being rejected by
the Board of Ethics.
3. Questions 3 to 5 apply in all cases.
The completed form should be dated and executed, and your
signature notarized.
Disclosures of financial conflicts of interest should be filed
with the City Clerk. Disclosures of nonfinancial conflicts of
interest should be filed with the City Attorney . Two conies of
vour Affidavit should also be supplied to the City Clerk or the
City Attorney so that it can also be sent, as appropriate, to the
Mayor or City Council President and your Department Head, if
applicable.
After filing, your form will be reviewed by the Board of
Ethics for completeness and conformity to state law , the charter,
and any applicable ordinances. You will be advised if any
additional information or if further action is required.
Generally, the review will occur within 2-4 weeks of your filing.
If speedier review is required, please indicate the date your
review is needed by and your reasons for the request, in a separate
letter filed with your affidavit.
COMMONLY ASKED QUESTIONS
1. Why do I have to fill out this form?
Both state law and local charter provisions require timely,
full and complete disclosure, in writing, of actual and potential
conflicts of interest. These provisions have been in effect since
the mid and late 1970s.
7
2_ When is an officer or employee required to file an Affidavit
of Disclosure?
As soon as a conflict exists, an officer or employee must
promptly file an Affidavit of Disclosure with the City Clerk or the
City Attorney, but in no event less than 10 days before any meeting
of any governing body at which the matter will be discussed or
considered. Where an officer or employee serves on a governing
body responsible for approval of the matter in which there is a
conflict, the disclosure must be made at the same time as the
filing with the City Clerk, to the governing body (the Council
President, in the case of Councilmembers ) and be included in the
public record of the proceedings .
Last minute disclosures , except in an unusual circumstances ,
do not comply with state law or the Charter . However, in the event
the issue unavoidably arises for the "first time at a particular
meeting , the governing body may determine by vote of an affirmative
majority of disinterested members if a conflict exists which
requires or permits a member to be excused from voting. At the
very least, the nature of the conflict and the reasons for excusal
or nonexcusal from voting should always appear in the record of the
meeting. An Affidavit of Disclosure must then be filed as soon as
practibie after the meeting .
3. Does a person have to file an Affidavit of Disclosure on each
t=ansaction in which they are or may be in conflict, or may the
Affidavit be generic in nature?
An officer or employee must file an Affidavit of Disclosure
on each separate transaction that involves a financial conflict.
4. What level of detail satisfies the requirement to fully
disclose a conflict of interest?
State law, the Charter and Conflict of Interest Ordinance
require complete and specific details in order to satisfy the
requirement of a full disclosure. The form is designed so that i f
fully completed, it will satisfy the disclosure requirement.
5. Is the purpose of the Affidavit of Disclosure to serve notice
that I am unable to speak or vote on a matter, or does it simply
serve as notice to other parties in the decision making process
that I have a self interest as opposed to a public one?
Both. In the appropriate case, it also notifies a governing
body (and the public) , on the record, why the officer or employee
with the conflict believes he or she can, in light of the conflict,
make or participate in making a decision on the matter fairly,
8
objectively, and in the public interest.
C. Is the filing of an Affidavit of Disclosure required even if
I have already been excused from voting or participating in the
decision of the matter?
Yes .
7. What standards of conduct apply if I have a conflict of
interest?
When there is a conflict of interest relative to a public
contract, state law sets the standards of conduct which apply.
Officers and emplovees who contemplate being a party to a contract
with the City are referred to MCL -15. 321 et sec . , entitie;f,
"Cont With Of Public Servants ith Public Entities" . As a general
rule, state law prohibits a full time officer or emplovee from
having direct business dealings with the City . volunteer and part
time officers and employees may, if state law is complied with,
have business dealings with the City. violation of the state
statute is a misdemeanor.
In all other cases , Chapter 5 of the Charter and Chapter 290
of the Code of Ordinances supply the applicable rules.
Any officer or emplovee may seek an adviscry opinion from the
: r
Board of Ethics based on the facts Of their specific sitaatior.,
they are uncertain about what rules apply to them, cr about what
they are required to do to resolve a conflict of interest.
S. Who am I allowed to communicate with about this matter, once
I have filed an Affidavit of Disclosure?
� F you have a conflict of interest, whether or not you have
riled an Affidavit of Disclosure, you may not officially or
unofficially participate in the discussion or consideration of y�he
item in conflict in any way, shape, or form, either directly or
indirectly, either in furtherance of your public reSDOIlSibilltie5
Cr Of vOL'r private interests , at any stage of the consideration of
the matter in which you have a conflict, except in compliance With
State law or Ordinance 290 .
9 . Does being excused from voting or late filing of an Affidavit
of Disclosure absolve any prior actions I may have -tal en on behalf
of the matter in which I have a conflict of interest?
No.