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2019-491
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Last modified
7/12/2021 10:15:27 AM
Creation date
4/17/2019 2:33:06 PM
Metadata
2019-491
Fields
Template:
Opinion Item
Opinion Type
Advisory Opinion
Docket Number
2019-491
Requesting Party
CSRS, Inc./Law office of R. Gray Sexon
Decision Date
4/12/2019
Law
La. R.S. 42:1121
Caption
Advisory Opinion whereby the Code of Governmental Ethics would not prohibit CSRS, Inc. from serving as a subcontractor on the Retore Louisiana Program since the former employees did not participate in said program.
Ethics Subject Matters
Post Employment
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CONCLUSION <br /> The Code of Governmental Ethics will not prohibit CSRS from serving as a subcontractor on the <br /> Restore Louisiana Program. The December 2018 RFP is a transaction in which neither Ms. <br /> Bonnaffons nor Mr. Mann participated. The RFP is in connection with work to be performed <br /> regarding the implementation and administration of the Restore Louisiana Program and to <br /> provide other support services to accommodate other federally funded disaster recovery or <br /> resilience/mitigation programs or initiatives currently existing or yet to be defined of which OCD <br /> administers including programs occurring as a result of future disasters. <br /> Moreover, Ms. Bonnaffons and Mr. Mann's services to OCD-DRU, through its employment with <br /> CSRS, are not the same services they now seek to provide as employees of CSRS to OCD-DRU <br /> under the current RFP. The proposed services to be provided by CSRS are in regard to the <br /> implementation and construction management of the Restore Louisiana Program, services that <br /> are distinct from the services that were provided by Ms. Bonnaffons and Mr. Mann as staff of <br /> OCD. Additionally, neither Ms. Bonnaffons nor Mr. Mann will provide services both PEA and <br /> Selective Services contracts at the same time. <br /> Neither Ms. Bonnaffons nor Mr. Mann would be participating in a transaction in which either <br /> participated as a public employee. CSRS will not be assisting any other person in any activities <br /> in which either Ms. Bonnaffons or Mr. Mann participated as OCD-DRU or through PAE <br /> Contract. Since based on the facts provided Ms. Bonnaffons and Mr. Mann would provide <br /> different services under a different "scope of work" on a new transaction in which they never <br /> participated, the post-employment provisions of Section 1121 of the Ethics Code will not <br /> prohibit CSRS from serving as a subcontractor on the Restore Louisiana Program. <br /> This advisory opinion is based solely on the facts as set forth herein. Changes to the facts <br /> presented may result in a different application of the provisions of the Code of Ethics. The <br /> Board issues no opinion as to past conduct or laws other than Code of Governmental Ethics. If <br /> you have any questions,please contact me at(225) 219-5600 or(800) 842-6630. <br /> Sincerely, <br /> LOUISIANA BOARD OF ETHICS <br /> Suzanne Quinlan Mooney <br /> For the Board <br />
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