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STATE OF LOUISIANA <br /> 4of wuI j_. DEPARTMENT OF STATE CIVIL SERVICE <br /> q LOUISIANA BOARD OF ETHICS <br /> H '1 � P.O.BOX 4368 <br /> 4Z, 4. BATON ROUGE,LA 70821 <br /> Ss, ,6, (225)219-5600 <br /> ,.,,, ° FAX:(225)381-7271 <br /> 1-800-842-6630 <br /> www.ethics.la.gov <br /> April 17, 2019 <br /> CSRS,Inc. <br /> (through counsel of record) <br /> Law Offices of R. Gray Sexton <br /> 8680 Bluebonnet Blvd., Ste. D <br /> Baton Rouge, Louisiana 70810 <br /> Re: Louisiana Board of Ethics Docket No. 2019-491 <br /> Dear Mr. Sexton: <br /> The Louisiana Board of Ethics, at its April 12, 2019 meeting, considered your request for an <br /> advisory opinion regarding whether the Code of Governmental Ethics would prohibit CSRS, <br /> Inc., (CSRS) the ability to respond as a subcontractor to the State of Louisiana, Office of <br /> Community Development-Disaster Recovery Unit's ("OCD-DRU") Request for Proposals for <br /> Restore Louisiana Program Selected Services (RFP#107140-055), while also serving as a <br /> subcontractor to the State's Disaster Grant Management Services (RFP# 107140-051) which <br /> included the provision of certain staff augmentation services for OCD-DRU. <br /> FACTS PROVIDED <br /> On November 14, 2017, Pan American Engineers, LLC ("PAE") entered into a Professional <br /> Service, Independent Contractor, Agreement (the "Contract") with the State of Louisiana, <br /> Division of Administration, Office of Community Development ("OCD"). The Agreement had <br /> an effective date of October 1, 2017. <br /> The Contract provides that PAE is to assist OCD and sub-recipients to whom OCD awards <br /> Community Development Block Grant ("CDBG") funds in the effective and expeditious <br /> implementation of the program and of individual CDBG grants awarded to grant recipients. The <br /> Contract enables OCD to call on PAE to assist it and its grant recipients in program design, the <br /> pre-application process, the application process, project development, bidding and pre- <br /> construction, as well as construction and project close out. <br /> On January 24, 2018, PAE entered into a subcontract with CSRS to assist in the performance of <br /> PAE's scope of responsibilities to OCD. The subcontract describes the scope of work as <br /> including grant management services for the OCD/CDBG Disaster Recovery Program related to <br /> Hurricanes Katrina, Rita, Gustav, Ike and Isaac, severe storms and floods of 2016 and future <br /> disasters. The subcontract had an effective date of October 1, 2017. Work would be performed <br /> AN EQUAL OPPORTUNITY EMPLOYER <br />