8/7/2019 OCF letter on Harry Thomas investigation

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March 22, 2011

Bob Kabel, ChairmanDC Republican Committee1275 K Street, NWSuite 102Washington, DC 20005

Re: Preliminary Investigation 2011-105

Dear Mr. Kabel:

This is to inform you that the Office of Campaign Finance (OCF) has initiated apreliminary investigation pursuant to the complaint you filed alleging thatCouncilmember Harry Thomas, Jr., might have violated certain provisions of theCampaign Finance and Conflict of Interest Act. OCF determined that an investigationwas warranted following an extensive review of the information compiled in this matter.

Specifically, you alleged that Mr. Thomas failed to disclose the receipt a motor vehiclefrom a Limited Liability Company (LLC) with whom he is affiliated and that he also didnot disclose travel expenses he received from a non-profit organization known as TeamThomas. You additionally alleged that the LLC in question was paid in excess of$10,000 by the Councilmembers Principal Campaign Committee for services.

An additional issue of whether Mr. Thomas and members of his Council staff usedgovernment resources for other than official government business in violation of theStandards of Conduct will also be examined.

D.C. Official Code 1-1106.02(a) states in pertinent part: the Mayor, the members ofthe Council, and members of the Board of Education shall also disclose annually alloutside income and honoraria, as defined in 1-1108.01, accepted during the calendaryear

DPM 1804.1 states in pertinent part: An employee may not engage in any outsideactivity which is not compatible with the full and proper discharge of his or her dutiesand responsibilities as a government employee. Activities or actions which are notcompatible with government employment include but are not limited to the following:

8/7/2019 OCF letter on Harry Thomas investigation

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Bob Kabel, ChairmanPreliminary Investigation 2011-105Page Two

(b) Using government time or resources for other than official business, orapproved or sponsored activities, except that a District employee may spend areasonable amount of government time and resources on such projects, reports,and studies as may be considered in aid of other government jurisdictions (local,state, federal), provided the work so performed is within the scope of theindividuals regular assignments as a District employee;

(c) Ordering, directing or requesting subordinate officers or employees toperform during regular working hours any personal service not related to officialgovernment functions and activities; and,

(e) Engaging in any outside employment, private business activity, or interestwhich permits an employee, or others, to capitalize on his or her official title orposition.

The Office of Campaign Finance has opened an investigation into this matter todetermine whether there is merit to the allegations. Please see 3 D.C. M. R.,3701(2010). You are further advised that all proceedings and records of the Office ofCampaign Finance relating to the initiation or conduct of any investigation are held inconfidence until final disposition by order by the Director. However, the final dispositionof this matter shall be made part of the public record. See 3 D.C. M. R., 3700.4 and3700.5.

Finally, please refer to the above referenced Preliminary Investigation number on allcorrespondence you transmit regarding this matter.

If you have any questions, do not hesitate to contact William O. SanFord, GeneralCounsel, on (202) 671-0550.

Sincerely

Cecily E. Collier-MontgomeryDirector

cc: William O. SanFordGeneral Counsel