HomeMy WebLinkAbout2016-02-17 BOE Packet01WWWA
Notice is hereby given that the Board of Ethics of the City of Chula Vista has called and will
convene a Regular Meeting of the Board of Ethics on Wednesday, February 17, 2016, at 5:15 p.m.
in Human Resources Training Room Bl 1, located at 276 Fourth Avenue, Building C, Chula
Vista, California to consider the item(s) on this agenda.
REGULAR MEETING OF THE BOARD OF ETHICS
OF THE CITY OF CHULA VISTA
February 17, 2016 Human Resources Training Room 1111, Building C
5:15 p.m. 276 Fourth Avenue
Chula Vista
CALL TO ORDER
ROLL CALL: Commissioners: Esquer Kish ; Livingston Robles ;
Voorhees ; Jemison, Vice Chair and Chair Schilling
CITY STAFF: Silva ; Ponds ; Malveaux Googins
PUBLIC COMMENTS
Persons speaking during Public Comments may address the Board/Commission on any
subject matter within the Board/Commission's jurisdiction that is not listed as an item on the
agenda. State law generally prohibits the Board/Commission from discussing or taking
action on any issue not included on the agenda, but, if appropriate, the Board/Commission
may schedule the topic for future discussion or refer the matter to staff. Comments are
limited to three minutes.
ACTION ITEMS
The Item(s) listed in this section of the agenda will be considered individually by the
Board/Commission and are expected to elicit discussion and deliberation. If you wish to
speak on any item, please fill out a "Request to Speak" form and submit it to the Secretary
prior to the meeting. Comments are limited to five minutes.
1. Status report regarding revising BOE complaint form from Ad Hoc Subcommittee
assigned to review and propose revisions to the BOE complaint form, and Board review
and comment on proposed revisions.
2. Presentation by City Attorney's Office on potential Lobbyist Registration Ordinance,
Discussion and Action by BOE regarding same, including potential creation of Ad Hoc
Subcommittee.
3. Presentation by City Attorney's Office regarding BOE complaint and hearing process.
OTHER BUSINESS
1. STAFF COMMENTS
2. CHAIR'S COMMENTS
3. COMMISSIONERSVBOARD MEMBERS' COMMENTS
ADJOURNMENT to the regular meeting on March 16, 2016, in the Council Conference
Room C101, Building A at 276 Fourth. Avenue, Chula Vista, California.
Materials provided to the Board of Ethics related to any open -session item on this agenda are
available for public review in the Office of the City Attorney at 276 Fourth Avenue, Chula Vista,
Building A, Chula Vista during normal business hours.
In compliance with the
AMERICANS WITH DISABILITIES ACT
The City of Chula Vista requests individuals who require special accommodations to access,
attend, and/or participate in a City meeting, activity, or service, contact the Human Resources
Department at (619) 691-5041 (California Relay Service is available for the hearing impaired by
dialing 711) at least forty-eight hours in advance of the meeting,
declare under nenalty of requry that I am employed by
the City of Chula v1sta in tte Otfice of the CityAttorney
and that I posted this document on the bulletin board at
the city Mali according to Brown Act requirements,
Dated:4Blignel�-,
Page 2 1Board of Ethics Regular Meeting February 17, 2016
2/1.7/2016
BOE HEARINGS
CVMC 2.01 AND 2.28
BOE HEARINGS
o GOVERNED BY CVMC 2.01 AND 2.28
a TWO ROLES LEGISLATIVE AND QUASI-
JUDICIAL
2/17/2016
BOE HEARINGS
LEGISLATIVE FUNCTION
o BOE ACTS AS A LEGISLATIVE BODY
■ REVIEWING CODE FOR IMPROVEMENTS
■ CVMC 2.28.030(D): "To propose revisions to this
chapter or other City policies to assure its continuing
effectiveness"
■ In this role, positions may be taken and advocated
for
BOE
QUASI -,JUDICIAL FUNCTIONS
o CVMC 2.28.020: "The Board of Ethics will serve
as a hearing body for violations of the code of
ethics, set forth in Chapter 2.01..."
o In that capacity the BCE acts as Judge/Jury in
the matter.
a In so doing, the BOE must be a fair and
impartial trier of fact and decision maker
2
BOE
QUASI -,JUDICIAL FUNCTIONS
o Concepts of "Due Process" under the 141h
Amendment are involved in the BOE's quasi-
judicial role
o Due Process involves notice and an
opportunity to be heard
o For example, the filed complaint form serves to
provide the Respondent notice of what. charges
they need to defend against
BOE
QUASI JUDICIAL FUNCTIONS
o Due Process also involves not engaging in ex -
parte communications
o Ex parte communications involves getting
evidence outside of the hearing process
■ Includes reading newspapers, watching TV, social
media
■ Communicating with witnesses, parties, and other
persons about the matter outside of the hearing
process
Such actions may deny Due Process
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3
BOE
QUASI JUDICIAL FUNCTIONS
o Avoid ex -parte communications
■ Ex Parte Communications denies one party or both
the right to notice and the ability to defend
■ Ex Parte Communications deny Board Members the
ability to have all the evidence they need to reach a
decision
E If you engage in Ex Parte Communications,
you should disclose them on the record
o Ex Parte Communications may be so pervasive
that it may require recusal
BOE
QUASI JUDICIAL FUNCTIONS
o BOE members must be fair and neutral
decision makers
o Can look to the Cannons of Judicial Ethics on
how to conduct yourselves
■ Canon 1: A judge shall uphold integrity and
independence of the judiciary
■ Canon 2: A judge shall avoid impropriety and
appearance of impropriety in all of the judge's
activities
■ Canon 3: A judge shall perform the duties of judicial
office impartially, competently, and diligently
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2/17/2016
BOE
QUASI JUDICIAL FUNCTIONS
o Canon 4: A judge shall so conduct the judge's
quasi-judicial and extrajudicial activities as to
minimize the risk of conflict with judicial
obligations
o Canon 5: A judge or candidate for judicial
office shall not engage in political or campaign
activity that is inconsistent with the
independence, integrity, or impartiality of the
judiciary.
o Canon 6: Compliance with the code of Judicial
Ethics
BOE
QUASI JUDICIAL FUNCTIONS
"A judge shall accord to every person who has alegal
interest in a proceeding, or that person's lawyer, full right
to be heard accordin& to law. Unless otherwise
authorized by law, a judge shall not independently
investigate facts in a proceeding and shall consider only
evidence, presented or facts that may be properly
judicially noticed. This prohibition extends to information
available in all media, including electronic. A judge shall
not initiate, permit, or consider ex parte communications,
that is, any communications to or from the judge outside
the presence of the parties concerning a pending or
impending proceeding, shall make reasonable efforts to
avoid such communications, except as follows:" (1) ok to
talk with other judges and (2) ok to talk to those
authorized by law to assist a judge, i.e. research attorneys.
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BOE
QUASI -,JUDICIAL FUNCTIONS
o Fair and neutral decision maker
o Treating both side fairly
o Considering only evidence presented in
hearing
BOE
Hearing Process
a CVMC 2.01.030 -violations
o Complaint comes in
o Prima facie review
o Probable cause hearing
o Hearing and Decision
R
CVMC 2.01
0 2.01.030 is broken down into three sections:
■ A (Guiding Principles)
■ B (BOE members)
■ And C (Specified Prohibitions)
o Sections A and B are not subject to sanctions.
They were intended to provide aspirational
goals to assist in City Officials in conducting
themselves and making decisions
AND
CVMC 2.01
a CVMC 2.01.030 states, "The guiding principals
are intended to provide a set of principles from
which City officials can draw upon to assist
them in conducting the public's business. As
such, they are directory in nature ant not
subject to the complaint procedures...."
The Guiding Principles are found in CVMC
2.01.030(A) and (B).
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2/17/2016
BOE
CVMC 2.01
o CVMC 2.01.030(C) lists the "Specified
Prohibitions."
o If a City Official violates them, then a
complaint may be filed with the BOE and the
BOE may vet the complaint and issue a finding
and referral to City Council.
E Specified Prohibitions are the only actionable
items by the BOE.
Complaint Intake Process
o CVMC 2.28.100
Very clerical in nature
Complaint comes in and it is given a case #
13 Chair is contacted to put on agenda (Prima Facie
review to be held within 30 days or 15 days if
complaint received within 90 days of election
• Subject of complaint is notified (standard email/letter)
• Complaining party sent letter that complaint received
and that next step to Prima Facie review (standard
letter sent)
13 City Attorney staff take no actions related to the merits
of the complaint.
N
2/17/2016
BOE
Complaint intake Process
E The intake process may include request for
confidentiality:
■ CVMC 2.28.090(C) -request for confidentiality
• Chair convenes a Ad Hoc committee, consisting of chair
and two other BOE members chosen by chair on
rotating basis.
• The Ad Hoc will meet within 2 days and determine if
good cause exists
o If no good cause, the complainant will have their
complaint returned of they so chose
• If good cause, complainant name will not be disclosed
unless and until after probable cause finding is made
Prima Facie Review
o CVMC 2.28.110 sets forth the requirements of a
Prima Facie Review
o This was intended to be an initial review to
determine if the case falls within the
jurisdiction of the BOE.
E If the complaint states the required elements
(found in CVMC 2.28.090 (A)) then the case can
proceed
o If it does not then it shall be dismissed
E It is a document only review -also serves as
notice document to Respondent
BOE
Prima Facie Review
o The required elements include:
■ Must be in writing made under penalty of perjury
■ Must name a person subject to the code of conduct
(2.01) -Elected officials, City Manager, Department
Directors, and Board and Commission members
■ Complaint must have been filed within 90 days of
occurrence or when it should have been discovered
■ Must contain a full set of facts that would constitute
a violation of the Specified Prohibitions set forth in
CVMC 2.01.030(C)
BOE
Prima Facie Review
El "Full set of facts
■ Review the factual statement presented
When this was written, the example of a criminal
complaint was used—the facts in the complaint must
state a crime
Facts should not be conclusionary statements
Facts should not be speculative
Generally assume facts to be true
A case should be dismissed when— even if the facts are
true they do not state a violation of the specified
prohibitions
■ Recent cases
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10
BOE
Prima Facie Review
o CVMC 2.28.110(A) states basis' for dismissal
o If case dismissed, letter sent notifying parties
o The BOE may refer the complaint to other
enforcement agencies that may have
jurisdiction
o A neutral form letter is used for referral; not a
document to advocate a position -consistent
with role of BOE as fair and neutral decision
maker
BOE
Probable Cause Hearing
o If the BOE determines a Prima Facie showing has
been made then the next step is a PC hearing
o The BOE has some ability to gather additional
information via
■ Request of parties
■ Formation of Ad Hoc Committee to obtain additional
information
■ Use of investigator
o In gathering information as set forth above, BOE
should be mindful of crossing line between
decision maker and advocate.
o Provision really designed to get readily available
information -public records
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11
BOE
Probable Cause Hearing
o In the Prima Facie Review -little emphasis on
merits
o At this stage the BOE determines (CVMC
2.28.120) "if there are facts and circumstances,
of a reasonably trustworthy nature, sufficient
to justify a person of reasonable caution or
prudence in the belief that a violation of the
specified prohibitions has occurred"
BOE
PROBABLE CAUSE HEARING -
o Procedures:
■ Attempt to set hearing within 45 days
■ Parties will be notifiedof hearing dates
■ Parties will be notified they mayprovide additional
evidence and written statement for the BOE's
consideration
■ At hearing BOE will consider the following information:
• The complaint and supporting documents
• Any additional evidence/ statement filed by parties after
Prima Facie Review
• Any BOE gathered Evidence
• Witnesses may be permitted to testify (subject to cross
examination) --but anyone may also comment under public
speakers in the matter
• Parties may make a statement to the BOE
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12
BOE
PROBABLE CAUSE HEARING
o The BOE then determine if PC exists
El If not, case dismissed
o If so, the proceed to hearing on merits within
45 days
BOE
Hearing on Merits
o Informal type hearing -so technical rules of
evidence do not apply
o While an informal hearing, the hearing should
be conducted with the appropriate conduct and
decorum by the parties
o Complaint bears burden of proof -
preponderance of evidence
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BOE
Hearing on Merits
o Procedures, as set forth in CVMC 2.28.130
■ Each Party may give an opening statement
■ Complainant goes first: may give opening statement and
the present witnesses (subject to cross examination) and
present evidence
■ Respondent may then present his witnesses (subject to
cross examination) and present evidence
■ The BOE may ask questions
■ The Parties then give closing Arguments
■ BOE then deliberates in open session on whether there is
a preponderance of the evidence that a Specified
Prohibition has been violated. Five BOE members must
find a violation
BOE
Hearing on the Merits
o The following is governed by CVMC 2.28.140
o After the BOE makes a decision, it will prepare
a written decision.
o The decision may be a finding of misconduct or
no misconduct.
o The decision must make findings showing a
violation.
o If misconduct is found the BOE decision may
contain recommended sanction, which will be
forward to City Council for their action
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14
Hearings
o In the conduct of hearings the BOE should
remember that they are fair and neutral
decision makers -they are not advocates for
either party
o Be fair and adhere to CVMC 2.01 and 2.28.
o The BOE should look to the Canons of Judicial
Ethics and Due Process principles to guide
their conduct
2/17/2016
15
BOARD OF ETHIC COMPLAINT FORM AND
INSTRUCTIONS
VIOLATIONS OF SPECIFIED PROHIBITIONS
(CVMC 2.01.030(C))
10/15 BOE Complaint Form and Instructions -Revised
CITY OF CHULA VISTA BOARD OF ETHICS
COMPLAINT FORM
The Board of Ethics has the authority to hear complaints regarding alleged conduct violations of
Councilmembers (including Mayor), the City Attorney, Board or Commission members, or City
Department Directors, as set forth in the Specified Prohibitions of Chula Vista Municipal Code
("CVMC") section 2.01.030(C). Please review CVMC section 2.01.030(C) to ensure your allegation(s)
are eligible. Copies of CVMC Chapters 2.01 and 2.28 are included with this complaint packet. The
Board of Ethics does not have jurisdiction to hear complaints about other issues or individuals, but the
Board of Ethics may refer such complaints to other enforcement agencies.
In the complaint process, the complaining party ("Complainant") bears the burden of proving the
allegations. The Board of Ethics acts as the hearing body for complaints involving the Specified
Prohibitions. The Board of Ethics must be impartial in its actions. The complaint process begins with a
prima facie review of the complaint. A prima facie review involves an examination of the information
contained in this complaint form to determine if the complaint was timely filed (a complaint must be filed
within 90 days of the violation), involves a City Official (as described in CVMC 2.01), and whether the
complaint contains a specific and full set of facts which show that a Specific Prohibition has been
violated. As a result, it is important that you provide as much factual and detailed information as
possible, particularly in the narrative section of this complaint form that describes the acts that form the
basis for the alleged violations of the Specified Prohibitions.
As the Complainant, your name is not confidential and would be publically available. If you believe
your name should be confidential, you may make a request (by completing a request for confidentiality
form) to the Board of Ethics for limited confidentiality. If your request is granted, your name would be
kept confidential for the period prior to the prima facie review conducted by the Board of Ethics. If your
request is not granted, you will have the option to either pursue the complaint with your name not
confidential or you may withdraw your complaint.
Please complete a complaint form for each City Official you believe violated the Specified Prohibitions
set forth in CVMC 2.01.030(C). If you have any questions, you may consult with an attorney. The
Board of Ethics must be neutral and cannot assist any party in the complaint process. Thank you for
taking time to submit your complaint.
�or full form instructions see page I IiSK11
1. COMPLAINTANT (PERSON WHO IS COMPLAINING) INFORMATION
For each person that is filing this complaint (called the Complainant(s)) please provide the below
required information:
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10/15 BOE Complaint Form and Instructions -Revised
REQUIRED
INFORMATION
COMPLAINANT
NAME
ADDRESS
CONTACT PHONE
NUMBER
EMAIL
The name of the complaining person(s) is not confidential. If you want to keep your name
confidential for a limited period of time, you may make request for confidentiality. To do so,
each person complaining must complete a request for Confidentiality form, which is included
I ith this complaint packagesKzl
REQUEST FOR ❑ No
CONFIDENTIALITY
(Check appropriate box) ❑ Yes
If there are more persons complaining, please provide the above information for additional
persons on an additional sheet of paper.
❑ Check if additional pages are attached.
2. RESPONDENT (PERSON YOU ARE COMPLAINING ABOUT) INFORMATION
For each person you are complaining about (called a Respondent) please provide the following required
information:
RESPONDENT 1
Person you are complaining about is:
FULL NAME:
THE ABOVE PERSON IS (CHECK ONE):
❑ THE MAYOR
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10/15 BOE Complaint Form and Instructions -Revised
❑ COUNCILMEMBER
❑ CITY ATTORNEY
❑ BOARD OR COMMISSION MEMBER
NAME BOARD OR COMMISSION:
❑ CITY DEPARTMENT DIRECTOR
NAME CITY DEPARTMENT:
If the person you wish to file a complaint about is not listed above, please contact
. The Board of Ethics is unable to hear complaints regarding individuals not
listed above, but may be able to provide a referral to another agency.
If there are more persons that you are complaining about, please provide the above information
for each additional person(s) on an additional sheet of paper.
❑ Check if additional pages attached.
3. ISPECIFIED PROHIBITION [S.31
The following checklist is a summary of the Specified Prohibitions found in CVMC 2.01.030(C). Please
review the actual language of the Specified Prohibitions to ensure that there are facts that support the
alleged violations. You will be required, in following sections, to provide a detailed description of the
alleged conduct showing a violation of the Specified Prohibitions. The Board of Ethics only considers
violations of the Specified Prohibitions. Any other allegation(s) will ,not be considered and the complaint
will be dismissed.
For each person you are complaining about, please complete the below sentence and check the applicable
box(es) indicating the Specified Prohibition believed to have been violated.
On [insert date or dates of violation] [name of person you are
complaining about] who is [City title of person you. are complaining. about
violated the following Specified Prohibitions]:
❑ 1. The City Official accepted gifts, favors, or promises of future benefits, which might
compromise or tend to impair independence of judgment or action.
❑ 2. The City Official used their official title or position for personal gain. Personal gain includes,
but is not limited to situations, wherein a City Official solicits items of value in consideration of
their official title or position.
❑ 3. The City Official divulged confidential information for personal gain or for the gain of
associates in a manner contrary to the public interest or in violation of any law.
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10/15 BOE Complaint Form and Instructions -Revised
❑ 4. The City Official used or permitted the use of City resources for unapproved non -city
activities, except when available to the general public, provided for by administrative regulations
or policies, or approved by City Council.
❑ 5. The City Official improperly appeared on behalf of the private interests of third parties before
the Council or any board, commission or proceeding of the city.
❑ 6. The Ex -City Official (not including a former mayor or councilmember) within 12 -months of
leaving office improperly appeared, as a compensated representative, before City Council,
commission, board, city administrative office or agency or officer or employee thereof for the
purpose of influencing any action or proceeding involving the issuance, amendment, awarding, or
revocation of a permit, license, grant, or contract for the sale of purchase of goods or property.
❑ 7. The former member of the City Council, including the Mayor within 12 months of leaving
office improperly appeared as a compensated representative before the Council, or any
commission, board, or city staff in connection with any case or other matter with which he/she
personally participated while an official or employee of the City.
❑ 8. The City Official endorsed or recommended for compensation any commercial product or
service in the name of the City or in the employee's official capacity within the City without prior
approval by a City Council policy.
❑ 9. The City Official violated Government Code section 87100 related to financial interests and
governmental decisions made by them.
❑ 10. The City official coerced their subordinates or any other City employee to participate in an
election campaign, contribute to a candidate or political committee, engage in any other political
activity relating to a particular party, candidate, or issue, or to refrain from engage in any lawful
political activity.
❑ 11. The City Official displayed campaign materials in any city owned vehicle under their control
and operated by that City Official.
❑ 12. The City Official aided and abetted another City Oficial to violate the Specific Prohibitions
set forth in the Code of Ethics.
❑ 13. The. City Official negotiated for employment with any person, firm, or organization at the
same time that aforementioned person, firm, or organization had a matter pending before City
Council, Board or Commission, or City department and upon which the City Official must act or
make a recommendation.
4. DESCRIPTION OF FACTS
Provide a specific and full description of the facts constituting the alleged violation of the Specified
Prohibitions set forth in CVMC 2.01.030(C). f You must include the date(s) of the incident, describe the
} espondent's position in the City, and have a full and specific rdescription of what occurred that violated
the Specified Prohibitions set forth in CVMC 2.01.030(C). JsK4jAvoid making unsupported conclusions or
speculation. The Board of Ethics will only consider allegations involving the Specified Prohibitions set
forth in CVMC 2.01.030(C). You may attach additional sheets as necessary.
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10/15 BOE Complaint Form and Instructions -Revised
El If more space is needed, please check this box and attach additional sheets as necessary
5. WITNESSES
Provide the following information about witnesses that can provide facts that support the alleged
violations of the Specified Prohibitions:
WITNESS #1
NAME:
ADDRESS:
CONTACT PHONE NUMBER:
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10/15 BOE Complaint Form and Instructions -Revised
E-MAIL:
Describe what facts the witness would provide in support of'the alleged violations) -if possible have
;witness submit a Separate statem6rAsK51
Provide the following information about person(s) that have information that support the alleged
violations of the Specified Prohibitions:
W ITN ESS #2
NAME:
ADDRESS:
CONTACT PHONE NUMBER:
E-MAIL:
Describe what information the witness would provide -if possible have the witness submit a
A separate statement:
❑ If more space is needed for additional witnesses, please check this box and attach additional
sheets as necessary
6. DOCUMENTATION
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10/15 BOE Complaint Form and Instructions -Revised
List and attach copies of any documents in your possession that support the alleged violations of the
Specified Prohibitions. In addition, indicate below whether there are other records, not in your
possession, that you believe would assist the Board of Ethics in reviewing the complaint.
Documents Attached
Document Name Description of Allegation Support
Other records not attached
Document Name Description of Allegation Support
❑ If more space is needed, please check this box and attach additional sheets as necessary
7. RELATED COMPLAINTS
Have you or someone you know made the same or similar complaint to a court or another agency?
Yes ❑ No ❑
If yes, identify the court or agency and attach a copy of any complaint and response. Briefly describe the
complaint and response below:
Court or Agency Name Describe complaint & response
❑ If more space is needed, please check this box and attach additional sheets as necessary
8. ADDITIONAL INFORMATION
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10/15 130E Complaint Form and Instructions -Revised
Provide any additional information that you believe may assist the Board of Ethics in its evaluation of this
complaint.
❑ If more space is needed, please check this box and attach additional sheets as necessary
9. VERIFICATION
I declare under penalty of perjury under the laws of the State of California that the above statements and
information are true and correct:
Executed:
At:
(Date)
(City and State)
By:
Sign:
(Typed or printed name)
(Signature)
If there is more than one complainant, each one must complete the above verification on a separate sheet
of paper. ❑ Check of there are additional pages with complainant verifications.
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10/15 BOE Complaint Form and Instructions -Revised
BOE COMPLAINT FORM INSTRUCTIONS
The following are instructions to help you complete the BOE complaint form. If you
require assistance you should seek the advice of an attorney.
Section 1 [Complainant Information]: In this section, the person or persons who are
complaining, also called Complainant(s), identify themselves and provide the below listed
contact information.
1. Provide complete name.
2. Provide complete address. This address will be used to send correspondence.
3. Please provide a phone number where you may be contacted.
4. Provide an email address.
If there is not enough room on the form, you may use additional sheets of paper and provide the
requested identifying information.
In this section, the complaining persons can also request to have their name kept confidential.
The request for confidentiality is for a limited period of time, usually up to the probable cause
hearing. To request confidentiality a separate form must be completed and must meet the
requirements of CVMC section 2.28.090(C).
Section 2 [Respondent information): In this section, you are asked to identify the person or
persons you are complaining about and their City position. The required information includes:
1. Complete name
2. Official City Title
3. Identify if the person you are complaining about is the City of Chula Vista Mayor, a
Councilmember, the City Attorney, a Board or Commission Member, or a City of Chula
Vista Department Director.
The person you are complaining about (also called "Respondent") must either be the Mayor, a
City Councilmember, the City Attorney, a City board or commission member, or a City
Department Director, referred to as "City Officials" in the Code of Ethics. If there is not enough
room on the form, you may use additional sheets of paper and provide the requested identifying
information.
The Board of Ethics does not hear complaints regarding other individuals.
Section 3 [Specified Prohibitions]: In this section, for each person you are complaining about,
insert their name in the blank for "[Name]" and insert their City title in the blank for "[City
Title]" and then check the Specified Prohibition(s) that you believe was violated. The checklist
of the thirteen specified prohibitions is a summary. You should review the actual language for
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10/15 WE Complaint Form and Instructions -Revised
each Specified Prohibition. The Specified Prohibitions are found in Chula Vista Municipal Code
section 2.01.030(C), a copy of which is included in this complaint package. Please complete the
above steps for each City Official you are complaining about. You may use additional sheets of
paper if needed.
Please note that the Board of Ethics can only consider complaints regarding the Specified
Prohibitions found in Municipal Code section 2.01.030(C), but cannot consider complaints about
the Guiding Principles found in Municipal Code section 2.01.030(A) and (B).
Section 4 [Description of Facts]: In this section, please describe for each person you are
complaining about the facts that show a violation of the Specified Prohibitions. Legal type
writing is not required. Instead, write it like a story in chronological order. You must include
the specific date the violation occurred and describe in detail what facts show a violation of the
Specified Prohibitions. The specific date the violations occurred is important because the
complaint must be filed within 90 days of the violation. Also, avoid making unsupported
conclusions or engaging in speculation. Finally, this section is very important because the
Board of Ethics uses the facts in this section to determine if a prima facie showing has been
made and to continue BOE consideration of the complaint. You may attach additional sheets if
you need more space.
Section 5 [Witnesses]: In this section, provide the following information for each witness that
supports your complaint:
1. Full name
2. Complete Address
3. Phone where they may be contacted
4. E-mail where they may contacted
For each witness, have them write a statement detailing what facts they would provide that
shows a violation of the Specified Prohibitions. If that cannot be done in time, a summary of
what they would say is acceptable. Also, the witness must be someone you spoke with and
know what they will say. A witness is not someone who you think will say something in support
of your complaint. Please complete the above steps for each witness. Please note that as the
case progresses, the witnesses may be called to testify before the BOE at a hearing on the merits
of the complaint.
Section 6 [Documentation]: In this section, provide copies any documents that support your
allegation of a violation of the Specified Prohibition. You may also provide web links to the
documents if they are on the internet. Also, if you are specifically aware of document that exist,
but are not in your possession, please explain what the documents are, what information they
will contain, and where they are located.
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10/15 BOE Complaint Form and Instructions -Revised
Section 7 [Related Complaints] : In this section, provide copies of complaints that are the same
as the current complaint or related to the current complaint that you have filed, with another
agency or court. Other agencies may include District Attorney's Office (DA), Attorney
General's Office (AG), or Fair Political Practices Commission (FPPC). If you have received a
response from that other agency, please include that as well.
Section 8 [Additional Information] : In this section, if there is any information that you have
not yet provided in this complaint form, but believe such information is relevant and would assist
the Board of Ethics in determining if there is a violation of the Specified Prohibitions, please
provide that information is this section. If you are not sure, it is ok to err on the side of
providing too much information and you may provide such information in this section.
Section 9 [Verification]: Chula Vista Municipal Code section 2.28.090 requires that the
complaint be filed under penalty of perjury. Each person that is making the complaint must sign
the complaint under penalty of perjury.
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10/15 BOE Complaint Form and Instructions -Revised
BOARD OF ETHIC COMPLAINT FORM AND
INSTRUCTIONS
VIOLATIONS OF SPECIFIED PROHIBITIONS
(CVMC 2.01.030(C))
10/15 BOE Complaint Form and Instructions -Revised
CITY OF CHULA VISTA BOARD OF ETHICS
COMPLAINT FORM
The Board of Ethics has the authority to hear complaints regarding alleged conduct violations of
Councilmembers (including Mayor) the City Attorney Board or Commission members or City
Department Directors, as set forth in the Specified Prohibitions set fi3rffi e of Chula Vista Municipal
Code ("CVMC") section 2.01.030(C). -Please review CVMC section 2.01.030(C) to ensure your
allegation(s) r»••(s) .+in the enumerated S r._.f .a Prohibition are eligible. Copies of CVMC Chapters
2.01 and 2.28 are included with this complaint packet. The Board of Ethics does not have jurisdiction to
hear complaints about other issues or individuals, but the Board of Ethics may refer such complaints to
other enforcement agencies.
As the complaining. party ("Complainanf'), your name is not confidential and would be publiea4ly
available. If you believe your name she uld- b- e- ee fidential, you may make a request (by eempleting
fequest for confidentiality f4m) to the Board of Ethies for limited eenfidentiality. If yeef request is
granted, your name would be kept confidential for the period pfief to the pMnafoeie reviev� eenducted b5
theBeardefEffiies. If your request is not granted, youwill have the eptien to either pufsue
eemplaint with your- name not being eenfidential or you met), withdraw your- eemplaint.
In the complaint process, the complaining pgrty ("Complainant").Cemplainant bears the burden of
proving the allegations. The Board of Ethics acts as the hearing body for complaints involving the
Specified Prohibitions. The Board of Ethics must be impartial in its actions. The complaint process
begins with a prima facie review of the complaint. A prima facie review involves an examination of the
information contained in this complaint form to determine if the complaint was timely filed (a complaint
must be filed within 90 days of the violation), involves a City Official (as described in CVMC 2.01), and
whether the complaints contains a specific and full set of facts which show that a Specific Prohibition has
been violated. As a result, it is important that you provide as much factual and detailed information as
possible, particularly in the narrative section of this complaint form that describes the acts that form the
basis for the alleged violations of the Specified Prohibitions.
As the Complainant, your name is not confidential and would be publically available If you believe
your name should be confidentialyou may make a request (by completing a request for confidentiality
form) to the Board of Ethics for limited confidentiality. If your request is granted, your name would be
kept confidential for the period prior to the prima facie review conducted by the Board of Ethics If your
request is not granted you will have the option to either pursue the complaint with your name not -being
confidential or you may withdraw your complaint.
Please complete a complaint form for each City Official you believe violated the Specified Prohibitions
set forth in CVMC 2.01.030(C). If you have any questions, you may consult with an attorney. The
Board of Ethics must be neutral and cannot assist any party in the complaint process. Thank you for
taking time to submit your complaint.
�or full'form instructions see page J1 JSKII
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10/15 BOE Complaint Form and Instructions -Revised
1. COMPLAINTANT (PERSON WHO IS COMPLAINING) INFORMATION
For each person that is filing this complaint (called the Complainant(s)) please provide the below
required information:
REQUIRED
COMPLAINANT
INFORMATION
............... . ...
NAME
ADDRESS
CONTACT PHONE
NUMBER.
EMAIL
rnni�inrniT�n� rry
P-Nde
SZ1
The name of the complaining person(s) is not confidential. If you want to keep your name
confidential for a limited period of time, you may make request for confidentiality. To do so,
each person complaining must complete a request for 1co*entiality form, which is included
(with this t complaint packagesK31
REQUEST FOR ❑ No
CONFIDENTIALITY
(Check appropriate box) ❑ Yes
If there are more persons complaining, please provide the above information for additional
persons on an additional sheet of paper.
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10/15 BOE Complaint Form and Instructions -Revised
Memey, Board or Comm-issien- m-effl-ber, or- City Depaftment Difeeten The Board of Ethies does not
If the person you wish to file a complaint about is not listed
above please contact The Board of Ethics is unable to hear complaints
regarding individuals not listed above, but may be able to provide a referral to another agency.
If there are more persons that you are complaining about, please provide the above information
for each additional person(s) on an additional sheet of paper.
❑ Check if additional pages attached.
3. SPECIFIED PROMBITIONS[s41
The following is --a checklist is a summary of the Specified Prohibitions found in CVMC 2.01.030(C).
The-cheeld}st is -a -summary of the SpeEified Prehibitiens. Please review the actual language of the
Specified Prohibitions to ensure that there are facts that support the alleged violations of the Sperm
Pr -e ,anions fund in CVA4G sectio 2.01.030(C). you will be required, in following sections, to provide
a detailed description of the alleged conduct showing a violation of the Specified Prohibitions. The Board
of Ethics only considers violations of the Specified Prohibitions. Any other allegation(s) will not be
considered and the complaint will be dismissed.
For each person you are complaining about, please complete the below sentence and check the applicable
box(es) below indicating the Specified Prohibition believed to have been violated.
A: On [insert date or dates of violation] [name of person you
are complaining about] who is [City title of person you are complaining about
violated the following Specified Prohibitions]:
❑ 1. The City Official accepted gifts, favors, or promises of future benefits, which might
compromise or tend to impair independence of judgment or action.
❑ 2. The City Official used their official title or position for personal gain. Personal gain includes,
but is not limited to situations, wherein a City Official solicits items of value in consideration of
their official title or position.
❑ 3. The City Official divulged confidential information for personal gain or for the gain of
associates in a manner contrary to the public interest or in violation of any law.
❑ 4. The City Official used or permitted the use of City resources for unapproved non -city
activities, except when available to the general public, provided for by administrative regulations
or policies, or approved by City Council.
❑ 5. The City Official improperly appeared on behalf of the private interests of third parties before
the Council or any board, commission or proceeding of the city.
❑ 6. The Ex -City Official (not including a former mayor or councilmember) within 12 -months of
leaving office improperly appeared, as a compensated representative, before City Council,
commission, board, city administrative office or agency or officer or employee thereof for the
purpose of influencing any action or proceeding involving the issuance, amendment, awarding, or
revocation of a permit, license, grant, or contract for the sale of purchase of goods or property.
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10/15 BOE Complaint Form and Instructions -Revised
❑ 7. The former member of the City Council, including the Mayor within 12 months of leaving
office improperly appeared as a compensated representative before the Council, or any
commission, board, or city staff in connection with any case or other matter with which he/she
personally participated while an official or employee of the City.
❑ 8. The City Official endorsed or recommended for compensation any commercial product or
service in the name of the City or in the employee's official capacity within the City without prior
approval by a City Council policy.
❑ 9. The City Official violated Government Code section 87100 related to financial interests and
governmental decisions made by them.
❑ . 10. The City official coerced their subordinates or any other City employee to participate in an
election campaign, contribute to a candidate or political committee, engage in any other political
activity relating to a particular party, candidate, or issue, or to refrain from engage in any lawful
political activity.
❑ 11. The City Official displayed campaign materials in any city owned vehicle under their control
and operated by that City Official.
❑ 12. The City Official aided and abetted another City Official to violate the Specific Prohibitions
set forth in the Code of Ethics.
❑ 13. The City Official negotiated for employment with any person, firm, or organization at the
same time that aforementioned person, firm, or organization had a matter pending before City
Council, Board or Commission, or City department and upon which the City Official must act or
make a recommendation.
4. DESCRIPTION OF FACTS
Provide a specific and full description of the facts constituting the alleged violation of the Specified
Prohibitions set forth in CVMC 2.01.030(C). (You must include the +date(s).of the incident,describe the
respondent's position in the City, and have a full and specif c description of what occurred that violated
the Specified Prohibitions set forth in CVMC 2.01 030(C). ksKslAvoid making unsupported conclusions or
speculation. The Board of Ethics will only consider allegations involving the Specified Prohibitions set
forth in CVMC 2.01.030(C). You may attach additional sheets as necessary.
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10/15 BOE Complaint Form and Instructions -Revised
❑ If more space is needed, please check this box and attach additional sheets as necessary
5. WITNESSES
Provide the following information about witnesses that can provide facts that support the alleged
violations of the Specified Prohibitions:
WITNESS #1
NAME:
ADDRESS:
CONTACT PHONE NUMBER:
E-MAIL:
Pescribe what facts the witness wouldprovide in support of the alleged violations) -if possible have
witness submit a Separate st6tement:ks4
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10/15 WE Complaint Form and Instructions -Revised
Other records not attached
Document Name Description of Allegation Support
❑ If more space is needed, please check this box and attach additional sheets as necessary
7. RELATED COMPLAINTS
Have you or someone you know made the same or similar complaint to a court or another agency?
Yes ❑ No ❑
If yes, identify the court or agency and attach a copy of any complaint and response. Briefly describe the
complaint -and response below:
❑ If more space is needed, please check this box and attach additional sheets as necessary
8. ADDITIONAL INFORMATION
Provide any additional information that you believe may assist the Board of Ethics in its evaluation of this
complaint.
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10/15 BOE Complaint Form and Instructions -Revised
❑ If more space is needed, please check this box and attach additional sheets as necessary
9. VERIFICATION
I declare under penalty of perjury under the laws of the State of California that the above statements and
information are true and correct:
Executed:
At:
(Date)
(City and State
By:
Sign:
(Typed or printed name)
(Signature)
If there is more than one complainant, each one must complete the above verification on a separate sheet
of paper. ❑ Check of there are additional pages with complainant verifications.
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10/15 BOE Complaint Form and Instructions -Revised
BOE COMPLAINT FORM INSTRUCTIONS
The following are instructions to help you complete the BOE complaint form. If you
require assistance you should seek the advice of an attorney.
Section 1 [Complainant Information]: In this section, the person or persons who are
complaining, also called Complainant(s), identify themselves and provide the below listed
contact information.
1. Provide complete name.
2. Provide complete address. This address will be used to send correspondence.
3. Please provide a phone number where you may be contacted.
4. Provide an email address.
If there is not enough room on the form, you may use additional sheets of paper and provide the
requested identifying information.
In this section, the complaining persons can also request to have their name kept confidential.
The request for confidentiality is for a limited period of time, usually up to the .probable cause
hearing. To request confidentiality a separate form must be completed and must meet the
requirements of CVMC section 2.28.090(C).
Section 2 [Respondent information]: In this section, you are asked to identify the person or
persons you are complaining about and their City position. The required information includes:
1. Complete name
2. Official City Title
3. Identify if the person you are complaining about is the City of Chula Vista Mayor, a
Councilmember, the City Attorney, a Board or Commission Member, or a City of Chula
Vista Department Director.
The person you are complaining about (also called "Respondent") must either be the Mayor, a
City Councilmember, the City Attorney, a City board or commission member, or a City
Department Director, referred to as "City Officials" in the Code of Ethics. If there is not enough
room on the form, you may use additional sheets of paper and provide the requested identifying
information.
The Board of Ethics does not hear complaints regarding other individuals.
Section 3 [Specified Prohibitions]: In this section, for each person you are complaining about,
insert their name in the blank for "[Name]" and insert their City title in the blank for "[City
Title]" and then check the Specified Prohibition(s) that you believe was violated. The checklist
of the thirteen specified prohibitions is a summary. You should review the actual language for
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10/15 130E Complaint Form and Instructions -Revised
each Specified Prohibition. The Specified Prohibitions are found in Chula Vista Municipal Code
section 2.01.030(C), a copy of which is included in this complaint package. Please complete the
above steps for each City Official you are complaining about. You may use additional sheets of
paper if needed.
Please note that the Board of Ethics can only consider complaints regarding the Specified
Prohibitions found in Municipal Code section 2.01.030(C), but cannot consider complaints about
the Guiding Principles found in Municipal Code section 2.01.030(A) and (B).
Section 4 [Description of Factsl: In this section, please describe for each person you are
complaining about the facts that show a violation of the Sp'_�cified Prohibitions. Legal type
writing is not required. Instead, write it like a story in chronological order. You must include
the specific date the violation occurred and describe in detail what facts show a violation of the
Specified Prohibitions. The specific date the violations occurred is important because the
complaint must be filed within 90 days of the violation. Also, avoid making unsupported
conclusions or engaging in speculation. Finally, this section is very important because the
Board of Ethics uses the facts in this section to determine i 1 a prima facie showing has been
made and to continue BOE consideration of the complaint. You may attach additional sheets if
you need more space.
Section 5 [Witnesses] : In this section, provide the following information for each witness that,
supports your complaint:
1. Full name
2. Complete Address
3. Phone where they may be contacted
4. E-mail where they may contacted
For each witness, have them write a statement detailing what facts they would provide that
shows a violation of the Specified Prohibitions. If that cannot be done in time, a summary of
what they would say is acceptable. Also, the witness must be someone you spoke with and
know what they will say. A witness is not someone who you think will say something in support
of your complaint. Please complete the above steps for each witness. Please note that as the
case progresses, the witnesses may be called to testify before the BOE at a hearing on the merits
of the complaint.
Section 6 [Documentation]: In this section, provide copies any documents that support your
allegation of a violation of the Specified Prohibition. You may also provide web links to the
documents if they are on the internet. Also, if you are specifically aware of document that exist,
but are not in your possession, please explain what the documents are, what information they
will contain, and where they are located.
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10/15 BOE Complaint Form and Instructions -Revised
Section 7 [Related Complaints]: In this section, provide copies of complaints that are the same
as the current complaint or related to the current complaint that you have filed with another
agency or court. Other agencies may include District Attorney's Office (DA), Attorney
General's Office (AG), or Fair Political Practices Commission (FPPC). If you have received a
response from that other agency, please include that as well.
Section 8 [Additional Information]: In this section, if there is any information that you have
not yet provided in this complaint form, but believe such information is relevant and would assist
the Board of Ethics in determining if there is a violation of the Specified Prohibitions, please
provide that information is this section. If you are not sure, it is ok to err on the side of
providing too much information and you may provide such information in this section.
Section 9 [Verification]: Chula Vista Municipal Code section 2.28.090 requires that the
complaint be filed under penalty of perjury. Each person that is making the complaint must sign
the complaint under penalty of perjury.
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10/15 BOE Complaint Form and Instructions -Revised