Commissioner Dominguez Form 9City Clerk USPS CERTIFIED MAIL
I 11 111 II
9214 8901 9403 8331 9488 20
FLORIDA COMMISSION ON ETHICS
PO BOX 15709
TALLAHASSEE FL 32317-5709
Return Reference Number:
Username: Charles Dagostin
Code Violation # :
Court Case #:
Property Address : :
Permit ID#:
Custom 5:
Postage: $8.6200
+1 A M /BEA CH /\/\/A//\ I
OFFICE OF THE CITY CLERK
City of Miami Beach, 1700 Convention Center Drive, Miami Beach, FL 33139
www.miamibeach!l,gov
Telephone: 305.673-7411
September 28, 2023
Florida Commission on Ethics
P.O. Drawer 15709
Tallahassee, FL 32317-5709
Pursuant to Sec. 112.3148, Florida Statutes, please find a Quarterly Gift Disclosure State Form
(9) for the quarter ending June 2023, for the following City of Miami Beach Personnel:
• Laura Dominguez - Commissioner (City of Miami Beach)
Should you have any questions or require any additional information, please contact me at
305.673. 7 411.
Respectfully,
Rafau.nado,
City Clerk
Attachment
REG:cd
Sent Certified Return Receipt
Form 9 QUARTERLY GIFT DISCLOSURE
(GIFTS OVER $100)
LAST NAME -- FIRST NAME -- MIDDLE NAME: NAME OF AGENCY:
Dominguez - Laura Citv of Miami Beach
MAILING ADDRESS: OFFICE OR POSITION HELD:
10 Venetian Way #2101 Commissioner, Group 2
CITY: ZIP: COUNTY: FOR QUARTER ENDING (CHECK ONE): YEAR
Miami Beach 33139 Miami-Dade OMARCH JUNE SEPTEMBER O DECEMBER 2023
PART A- STATEMEN T OF GIFTS
Please list below each gift, the value of which you believe to exceed $100, accepted by you during the calendar quarter for which this statement is
being filed. You are required to describe the gift and state the monetary value of the gift, the name and address of the person making the gift, and the
date(s) the gift was received. If any of these facts, other than the gift description, are unknown or not applicable, you should so state on the form. As
explained more fully in the instructions on the reverse side of the form, you are not required to disclose gifts from relatives or certain other gifts. You
are not required to file this statement for any calendar quarter during which you did not receive a reportable gift.
DATE DESCRIPTION MONETARY NAME OF PERSON ADDRESS OF PERSON
RECEIVED OF GIFT VALUE MAKING THE GIFT MAKING THE GIFT
4/14/2023 Pride Event $100 City of Mi ami Beach 1700 Convention Center Dr
Vendor Deal Miami Beach FL 33139
4/21/2023 Better Beach Awards Lunch $100 City of Miami Beach 1700 Convention Center Dr
Miami Beach FL 33139
4/21/2023 World Polo Event $250 City of Mi ami Beach 1700 Convention Center Dr
Vendor Deal Miami Beach FL 33139
5/6/2023 Miami New Drama $200 City of Mi ami Beach 1700 Convention Center Dr
Vendor Deal Miami Beach FL 33139
A CHECK HERE IF CONTINUED ON SEPARATE SHEET
PART B- RECEIPT PROVIDED BY PERSON MAKING THE GIFT
If any receipt for a gift listed above was provided to you by the person making the gift, you are required to attach a copy of that receipt to this
form. You may attach an explanation of any differences between the information disclosed on this form and the information on the receipt.
□CHECK HERE IF A RECEIPT IS ATTACHED TO THIS FORM
PART C OATH
I, the person whose name appears at the beginning of this form, do
depose on oath or affirmation and say that the information disclosed
herein and on any attachments made by me constitutes a true accurate,
and total listing of all gifts required to be reported by Section 112.3148,
Flori~ /'
SIGNAfUREOF~FICIAL
soeo op9 a.a·- D)tit couNro L'LT'L LI[
or affirmed) and by means of
Jes=i o2
«GOSTIN
(Print, Type, or Stam C
Personally Known
Type of Identification Produced
PART D - FILING INSTRUCTIONS
This form, when duly signed and notarized, must be filed with the Commission on Ethics, P.O. Drawer 15709, Tallahassee, Florida 32317-5709; physi-
cal address: 325 John Knox Road, Building E, Suite 200, Tallahassee, Florida 32303. The form must be filed no later than the last day of the calendar
quarter that follows the calendar quarter for which this form is filed (For example, if a gift is received in March, it should be disclosed by June 30.)
CE FORM 9 -EF F. 1/2016 (Refer to Rule 34 -7.010(1)g), F.A.C.) (See reverse side for instructions) °
Form 9 QUARTERLY GIFT DISCLOSURE
{GIFTS OVER $100)
LA ST NAM E -- FIRST NAM E -- MI DDLE NAME: NAME OF AGENCY:
Dominguez -- Laura Citv of Miami Beach
MAILING ADDRESS: OFFICE OR POSITION HELD:
10 Venetian Way Ap t 2101 Commissioner, Group 2
CITY : ZIP: COUNTY : FOR QUARTER ENDING (CHECK ONE): YEAR
Miami Beach 33139 Miami-Dade OMARCH JUNE SEPTEMBER DECEMBER 2023
PA R T A - STATE M E N T O F G IFTS
Please list below each gift, the value of which you believe to exceed $100, accepted by you during the calendar quarter for which this statement is
being filed. You are required to describe the gift and state the monetary value of the gift, the name and address of the person making the gift, and the
date(s) the gift was received. If any of these facts, other than the gift description, are unknown or not applicable, you should so state on the form. As
explained more fully in the instructions on the reverse side of the form, you are not required to disclose gifts from relatives or certain other gifts. You
are not required to file this statement for any calendar quarter during which you did not receive a reportable gift.
DATE DESCRIPTION MONETARY NAME OF PERSON ADDRESS OF PERSON
RECEIVED OF GIFT VALUE MAKING THE GIFT MAKING THE GIFT
5/9/20 23 Ar sht C enter Ticket $10 0 Harvey Burstein 1775 Washington Ave PH2
Miami Beach, FL 33139
5/18/2023 Miami-Dade County Police Dinner $10 0 City of Miami Beach 1700 Convention Center Dr
Vendor Deal Miami Beach FL 33139
5/27/20 23 Air an d Sea Show $250 City of Miami Beach 1700 Convention Center Dr
Comp Vendor Deal Miami Beach FL 33139
5/28/2023 - 6/5/2023 Israel Seminar for Florida Leaders $16,950 American Israel 251 H St, NW
Education Foundation Washington, DC 20001
a CHECK HERE IF CONTINUED ON SEPARATE SHEET
PA R T B - R E C E IP T PR O V ID E D BY PE R S O N M A KING TH E G IFT
If any receipt for a gift listed above was provided to you by the person making the gift, you are required to attach a copy of that receipt to this
form. You may attach an explanation of any differences between the information disclosed on this form and the information on the receipt.
ill CHECK HERE IF A RECEIPT IS ATTACHED TO THIS FORM
PA R T C - OATH
I, the person whose name appears at the beginning of this form, do
depose on oath or affirmation and say that the information disclosed
herein and on any attachments made by me constitutes a true accurate,
me by means of
an 23
$gs-m'
and total listing of all gifts required to be reported by Section 112.3148, by -)_ nu. } _
EE
SIGNATURE OF REPORTING OFFICIAL
J. DAGOSTIN
(Print, Type, or Stamp, 'om
Personally Known _ €RR?ridiedldentifiee'lien.sassasss~
Type of Identification Produced _
PA R T D - FILI N G IN S T R U CT IO N S
This form, when duly signed and notarized, must be filed with the Commission on Ethics, P.O. Drawer 15709, Tallahassee, Florida 32317-5709; physi-
cal address: 325 John Knox Road, Building E, Suite 200, Tallahassee, Florida 32303. The form must be filed no later than the last day of the calendar
quarter that follows the calendar quarter for which this form is filed (For example, if a gift is received in March, it should be disclosed by June 30.)
CE FORM 9 - EF F. 1/2016 (Refer to Rule 34-7.010(1)(g), F.A.C.) (See reverse side for instructions) @°
A ttached is docum entation w ith respect to a ticket I received for
attendance at a local event, and m y paym ent for the full cost of the
ticket w ithin the tim efr am e provided by Florida law . A lthough this
transaction is neither a prohibited gift no r a report able gift , I am
disclosing this inform ation in the interests of transparency.
DocuSign Envelope ID: ACD8OB1D-9CAC-4906-BC5B-3A01373D5150
August 1, 2023
Major Food Group LLC
c/o Jamey R. Campellone, Esq.
Greenspoon Marder LLP
200 E. Broward Blvd.
Suite 1800
Fort Lauderdale, FL 33301
Dear Mr. Campellone,
Enclosed please find a check in the amount of my entrance ticket for the Carbone Beach event,
which took place from May 4-7, 2023, in Miami Beach, Florida {the "Event"}. The Event was hosted
by Major Food Group (the "Event Organizer"} and presented by American Express {the
"Sponsor''}.
When I accepted the ticket, I believed the ticket was provided to me by Major Food Group, as the
Event Organizer, or by American Express, the Sponsor. At all relevant times (including the 12
months preceding the Event}, neither the Event Organizer nor the Sponsor were City of Miami
Beach vendors or lobbyists.1 Therefore, the City Attorney has advised me that the gift restrictions
that apply to vendors or lobbyists under State law or the Miami-Dade County Code of Ethics would
not apply to Major Food Group, as the Event Organizer, or American Express, as the Sponsor.
In fact, in a good-faith effort to comply with my ethics obligations, the City voluntarily sought, and
obtained, a favorable advisory opinion from the Florida Commission on Ethics staff, a copy of
which is attached hereto, confirming that I would be permitted to accept a gift from either the Event
Organizer or the Sponsor, on the basis that neither party was a vendor or lobbyist.
However, it was recently alleged in a lawsuit against the City of Miami Beach in an unrelated
matter that the Boucher Brothers, a City vendor which was separately engaged by Major Food
Group to assist with Event set-up and permitting, was somehow the owner and/or donor of the
ticket that I accepted, as well as the Event tickets accepted by several of my colleagues on the
City Commission.
As I take my ethics obligations seriously, in light of the uncertainty surrounding the identity of the
owner and/or donor of the ticket, I am hereby remitting payment to Major Food Group, as the
Event Organizer, in the amount of the ticket that I accepted to the Major Food Group's Event. If in
fact the actual donor of the ticket was the Major Food Group's event contractor, Boucher Brothers
Miami Beach, or any other party, I request that you please endorse the check and remit this
payment to the appropriate party.
149 Collins Avenue Restaurant LLC and 404 Washington Major Restaurant LLC, both affiliates of Event
Organizer, previously reg istered as lobbyists in connection with two separate Miami Beach land use board
applications. The 49 Collins Avenue Restaurant LLC application was approved by the Design Review Board
on January 4, 2022, and the 404 Washington Major Restaurant LLC application was approved by the
Planning Board on July 27, 2021. Once each of the foregoing applications was approved, any lobbying
activities concluded as of the date of each approval. See Section 2-481 of the City Code; see also Section
112.3148(2)(b)(1 ), Florida Statutes. Accordingly, the Event Organizer and/or its affiliates or principals
thereof were not lobbyists pursuant to the City Code or State law, and were not subject to any gift
restrictions.
DocuSign Envelope ID: ACD8OB1D-9CAC-4906-BC5B-3A01373D5150
Major Food Group LLC
August 1, 2023
Page2
This refund is made pursuant to Section 112.3148(7)(b), Florida Statutes, which provides that
payment made within 90 days after receipt of a gift shall be deducted from the value of the gift,
for purposes of compliance with the gift rules and reporting obligations under State law.?
Please do not hesitate to contact me if you have any questions.
Sincerely,
~OocuSigned by:
ES. aura uommguez
Miami Beach City Commissioner
c: Miguel A. De Grandy, Esq., counsel for Boucher Brothers Miami Beach, LLC
Rafael Paz, City Attorney
2 See also Miami-Dade County Commission on Ethics Opinion INQ 2022-53, dated March 25, 2022, n. 6,
citing the statutory pay-down provision in Sec. 112.3148(7)(b).
DocuSign Envelope ID: ACD80810-9CAC-4906-BC5B-3A01373O5150
Glenton "Glen" Gilzean, Jr.
Chair
Don Gaetz
Vice Chair
Michelle Anchors
William P. Cervone
John Grant
William "WiIIie" N. Meggs
Ed H. Moore
Wengay M. Newton, Sr.
Jim Waldman
State of Florida
COMMISSION ON ETHICS
P.O. Drawer 15709
Tallahassee, Florida 32317-5709
Kerrie J. Stillman
Executive Director
Steven J. Zuilkowski
Deputy Executive Director/
General Counsel
(850) 488-7864 Phone
(850) 488-3077 (FAX)
www.ethics.state.fl.us
325 John Knox Road
Building E, Suite 200
Tallahassee, Florida 32303
"A Public Office is a Public Trust"
July 26, 2023
Ms. Freddi Mack
1700 Convention Center Drive, 4 Floor
Miami Beach, FL 33139
Email: freddimack@miamibeachfl.gov
Dear Ms. Mack,
This letter is provided in response to your ethics inquiry. You state that a significant piece
of City-owned property ("Property") has been subject to a 40-year lease term set to expire in May
of 2026. You indicate that the current lessee holds no further rights of renewal, and there has been
a large amount of public interest over what the City will do with the Property at the end of the
lease term.
You state that in March and early-mid April 2023, a restaurant group ("Entity 1 ") publicly
advertised that it would be hosting a high profile food and concert event series in May 2023. You
indicate that in early May 2023, certain City Commissioners received complimentary tickets to
this event, the value of each exceeding $100. You state that, to this day, Entity 1 has not been a
City vendor nor a lobbyist. You indicate that the tickets were distributed via American Express
through its Guest Management partner VOW.
You indicate that on April 28, 2023, the City Commission voted to approve a resolution to
begin negotiations to establish a non-binding term sheet with a known and experienced City vendor
("Entity 2"), which could serve as a stalking-horse bidder for a new lease or management
agreement relating to the Property at the end of the current lease term. You further indicate that,
in lieu of a stalking-horse bid, Entity 2 could be awarded a bid waiver contract upon receiving the
requisite number of votes under City law.
DocuSign Envelope ID: ACD8OB1D-9CAC- 4906-BC5B-3A01373D5150
Ms.Freddi Mack
July 26, 2023
Page2
You state that by the time of the April 28 meeting, at least one Commissioner had been
advised that Entity 1 could be a potential partner with Entity 2 for the property. Regarding the
complimentary tickets that certain City Commissioners received in early May 2023 to the Entity
1 event, you indicate that at least one Commissioner had communicated with a principal for Entity
2 about the tickets in early May 2023. You state that Entity 2 did not contribute the tickets, rather,
it was Entity 1 who made the tickets available. You indicate that the Commissioners who accepted
the tickets understood them to be a gift coming from American Express or Entity 1, and you
indicate that neither of which are City lobbyists or vendors. You further indicate that the subject
Commissioners intend to report the tickets on the appropriate gift disclosure form.
You indicate that on May 17, 2023, the City Commission voted to rescind the April 28"
resolution authorizing non-binding negotiations with Entity 2, and to instead begin a competitive
RFP process to invite any qualified entities, including the current lessee, to submit competing
proposals on the same timeline.
You state that Entity 1 has not lobbied the City for any action on behalf of themselves or
for any other party. Additionally, you indicate that no proposal involving Entity 1 has been
submitted. You state that the RFP solicitation process is still pending, and that submissions are not
due until August 15, 2023. You ask if any ethical standards are implicated by these facts.
Sections 112.3148(3) and 112.3148(4), Florida Statutes,' are not implicated by the facts
you present, as you state that Entity 1, the entity that provided the tickets, is not a vendor doing
business with the City, a political committee, or a lobbyist of the City. However, a statutory
provision that is implicated is Section 112.3148(8), Florida Statutes. This provision states:
(8)(a) Each reporting individual or procurement employee shall
file a statement with the Commission on Ethics not later than the last
day of each calendar quarter, for the previous calendar quarter,
containing a list of gifts which he or she believes to be in excess of
$100 in value, if any, accepted by him or her, for which
compensation was not provided by the donee to the donor within 90
days of receipt of the gift to reduce the value to $100 or less, except
the following:
1. Gifts from relatives.
2. Gifts prohibited by subsection (4) ors. 112.313(4).
3. Gifts otherwise required to be disclosed by this section.
1 Section 112.3148(3), Florida Statutes, prohibits a reporting individual from soliciting any gift
from a vendor doing business with his or her agency, a political committee, or a lobbyist who
lobbies his or her agency, where such gift is for the personal benefit of the reporting individual,
another reporting individual, or any member of the immediate family of a reporting individual.
Section 112.3148(4), Florida Statutes, prohibits a reporting individual or any other person on his
or her behalf from knowingly accepting, directly or indirectly, a gift from a vendor doing
business with his or her agency, a political committee, or a lobbyist who lobbies his or her
agency, ifhe or she knows, or reasonably believes, that the gift has a value in excess of $100.
DocuSign Envelope ID: ACD8OB1D-9CAC-4 906-BC5B-3A01373D5150
Ms. Freddi Mack
July 26, 2023
Page 3
(b) The statement shall include:
1. A description of the gift, the monetary value of the gift, the
name and address of the person making the gift, and the dates
thereof. If any of these facts, other than the gift description, are
unknown or not applicable, the report shall so state.
2. A copy of any receipt for such gift provided to the reporting
individual or procurement employee by the donor.
( c) The statement may include an explanation of any differences
between the reporting individual's or procurement employee's
statement and the receipt provided by the donor.
(d) The reporting individual's or procurement employee's
statement shall be sworn to by such person as being a true, accurate,
and total listing of all such gifts.
( e) Statements must be filed not later than 5 p.m. of the due date.
However, any statement that is postmarked by the United States
Postal Service by midnight of the due date is deemed to have been
filed in a timely manner, and a certificate of mailing obtained from
and dated by the United States Postal Service at the time of the
mailing, or a receipt from an established courier company, which
bears a date on or before the due date constitutes proof of mailing in
a timely manner.
(f) If a reporting individual or procurement employee has not
received any gifts described in paragraph (a) during a calendar
quarter, he or she is not required to file a statement under this
subsection for that calendar quarter.
Essentially, Section 112.3148(8) requires public officers and employees to disclose all gifts
they receive that exceed $100 in value and come from donors who are not vendors, lobbyists,
principals of lobbyists, or political committees (prohibited sources).
Given that you indicate the value of each ticket provided exceeds $100, and the donor is
not a prohibited source, the City Commissioners who accepted the tickets should either (1)
reimburse Entity 1 for the monetary value of the tickets within 90 days of the date they accepted
them, or (2) they must file a CE Form 9, "Quarterly Gift Disclosure," to disclose the ticket(s) that
they accepted. The deadline to file a CE Form 9 is the last day of the calendar quarter following
the calendar quarter in which the gift was received. Thus, the deadline for City Commissioners
who accepted tickets would be September 30, 2023. The form is filed with the Commission on
Ethics, and can be found on the Commission's website.
The guidance provided in this letter is limited to the facts that have been provided. If there
are additional material facts, or if I have misstated them in this letter, please contact me again. The
referenced statutes and advisory opinions are available on the Commission's website at
www.ethics.state.fl.us. If you have any other questions about the guidance contained in this letter,
please send me an email at bums.joseph@leg.state.fl.us.
DocuSign Envelope ID: ACD8OB1D-9CAC-4906-BC5B-3A01373D5150
M s. Fred di M ack
Ju ly 26, 2023
Page4
Sincerely,
o4eel 0. Ga
Jo seph C . B urn s
A tt orn ey
LAURA DOMINGUEZ
10 VENETIA N WAY APT 2101
MIAMI BEA CH , FL 33139
143
7-31-2023 63-1482670
04218
Date ± lajor fod @ou C 83000.00o
Th thousand sos @ EE.
, aboAe beak
MIAMI -DAD E COMMI SSION ON ETHI CS AND PUBLI C TRUST
COMMISSIONERS
Dr. Judith Bernier, CHAIR
Wifredo "Willy" Gort, VICE CHAIR
Nelson C. Bellido Esq.
Judge Lawrence A. Schwartz
Leonard D. Pertnoy, Esq.
EXECUTIVE STAFF
Jose J. Arrojo
EXECUTIVE DIRECTOR
Radia Turay
ADVOCATE
Loressa M. Felix
GENERAL COUNSEL
March 23, 2023
Via electronic mail only to expedite delivery:
Laura@miamibeachfl.gov
Honorable Laura Dominguez
Commissioner
City of Miami Beach
1700 Convention Center Drive
Miami Beach, Florida 33139
Re: INQ 2023-_, Section 2-11.l(e) and (w), County Ethics Code, Gifts and Travel
Dear Commissioner Dominguez:
Thank you for contacting the Miami-Dade County Commission on Ethics and Public Trust and for
requesting ethics guidance regarding the application of the County Ethics Code to your proposed
international travel to Israel to attend an educational seminar and related activities.
You are an elected Commissioner in the City of Miami Beach, Florida. You have been invited to
travel to Israel to attend an educational seminar and related activities. You will be traveling as
part of a larger group that will include elected or appointed government officials, employees, or
other persons serving in public capacities. The travel, seminar, and activities are sponsored by the
American Israel Education Foundation (AIEF) and that organization will be funding some or all
of the expenses related to your travel.
The AIEF is a nonprofit charitable organization affiliated with pro-Israel groups and provides
educational seminars for elected officials and civic leaders in support of its mission. Notably, for
purposes of this opinion, the AIEF is not a City of Miami Beach contractor, vendor, service
provider, bidder, or proposer, nor is it the principal of a Miami Beach lobbyist.
701 Northwest 1 Court • 8th Floor • Miami, Florida 33136 • (305) 579-2594 • ethics@miamidade.gov
Wh e t h e r y o u m a y a c c e p t a gi ft c o n s is tin g o f tr a v e l r e la te d e x p e n s e s fr o m a c h a ri ta b le o r g aniz ati o n
in o r d e r t o tr av e l t o I s ra e l fo r an e du c a t io n a l s e mi n ar an d r e la te d a c tiv iti e s .
D i s c us s i o n :
1 . G ift s
S e c ti o n 2 -1 1 .1 ( e ) o f th e C o un ty E thi c s C o d e g o v e rns th e s o lic ita tio n a n d a c c e p ta n c e o f gi fts b y
lo c a l g o v e rnm e n t e l e c t e d o ffi ci a ls in M iami -D a d e C o un ty . Th at s e c ti o n d e fi n e s a "gi ft " a s th e
tr a n s fe r o f a n yt hin g o f e c o n o mi c v a lu e w ith o u t a d e q ua te o r la wfu l c o m p e n s a tio n . A ls o , it p r o h ib its
t h e s o l i ci ta t i o n o r d e m an d o f a g ift , o r an y g ift tr ans a c t io n , w h e n c o nn e c te d to an o ffi c ia l a c tio n o r
p e rfo rm an c e o f a le g a l du ty b y th e o ffi c ia l. 1
Consequently, AIEF's payment of some or all of your travel related expenses to Israel would
constitute a gift as defined in the County Ethics Code. However, the quid pro quo prohibition in
that section would not apply to gifted costs related to an educational program provided by a
charitable organization that has no pending interest in any official action that you may have or will
be taking as a Miami Beach Commissioner. INQ 2023-23; INQ 18-76; INQ 11-140.
Inasmuch as the travel costs that will be assumed by AIEF are undoubtedly valued at over $100,
you are required disclose the gift to the State of Florida in your quarterly gift disclosure filing.
2. Travel Costs
Section 2-11.l(w) of the County Ethics Code prohibits the acceptance by a local government
official in Miami-Dade County of travel related expenses from a County or municipal contractor,
vendor, service provider, bidder, or proposer, or the principal of a County or municipal lobbyist.
This prohibition would not apply to your proposed travel to Israel because AIEF does not fit into
any of these categories of persons or entities that are transacting with the City of Miami Beach.
Opinion:
Based upon the facts presented, your travel and participation in the American Israel Education
Foundation's Educational Seminar in Israel does not violate any provision in the Miami-Dade
County Conflict of Interest and Code of Ethics Ordinance and you may accept that organization's
funds to cover some or all of your travel expenses related to attendance at the seminar or related
activities.
1 Section 2-11.l(a), Miami-Dade Code (The County Ethics Code provides the minimum standard
of ethical conduct and behavior for all municipal officers [including those in the City of Miami
Beach] and references in Ethics Code to County officials shall be applicable to municipal officials
who serve in comparable capacities to County officials referred to.)
Page 2 of3
T hi s o p ini o n is limi te d to th e fa c ts a s y o u p r e s e n te d th e m to th e C o mmi s s io n o n E th ic s , is limi te d
to an in te rp r e ta tio n o f th e C o un ty E th ic s C o d e .
P le a s e d o n o t h e s ita te to c o n ta c t m e s h o ul d y o u r e q ui r e a ny a d d itio n a l a s s is ta n c e .
S in c e r e ly ,
lo#»
Jose J. Arrojo, Esq.
Executive Director
cc: Rafael Paz, Esq.
Miami Beach City Attorney
All COE Legal Staff
INQs are ethics opinions provided by the legal staff after being reviewed and approved by the
Executive Director. INQs deal with opinions previously addressed in public session by the
Ethics Commission or within the plain meaning of the County Ethics Code. RQOs are opinions
provided by the Miami-Dade Commission on Ethics and Public Trust when the subject matter
is of great public importance or where there is insufficient precedent. Covered parties that act
contrary to the opinion may be referred to the Advocate for preliminary review or investigation
and may be subject to a formal Complaint filed with the Commission on Ethics and Public
Trust.
Page 3 of3