CITY OF HARTFORD OFFICE OF THE CORPORATION COUNSEL 550 Main Street Hartford, Connecticut 06103
JOHNROSB.JR. Coiporation Counsel
Telephone: (860)757-9700 Fax: (860)722-8114 www.hartford.gov
CARLR.NASTO Deputy COiparatwn Counsel
April 3,2009 Carol Carson, Executive Director Office of State Ethics 18-20 Trinity Street, Suite 205 Hartford, CT. 06106-1660 Re; Notice of Possible Violation of Code of Ethics for Lobbyists
Dear Ms, Carson: I am legal counsel for the City of Hartford. Recently officials of the City have learned of possible violations of the State's Code of Ethics for Lobbyists (C.G.S. Sec. 1-91, etseq.). We discovered that an engineer, doing business as Richard L, Moffitt and Associates, P.C. solicited a City department head, being Clarence Corbin, Director of the Department of Public Works, to provide services variously described as "political liaison" activity or "political lobbying" related to certain proposed State Bond Commission approvals for funding for a municipal Flood Control Management Project. Neither Mr. Moffitt nor his company is a lobbyist for the City. He secured a sole source contract from DPW on or about November 5,2008 to perform what he described "broadly as financial management services". The contract was for $7000, all of which was billed between November 10,2008 and February 27,2009, and some $6850 has been paid thereon. Our investigation has revealed that Mr. Moffrtt/his company were to perform lobbying activities on behalf of a City department, acting by its department head and an Acting Director. Further, according to documents obtained by the City, Mr. Moffitt or his company, with his knowledge, performed lobbying services. Our information is that neither Mr. Moffitt nor his company is registered as a lobbyist in Connecticut, a violation of C.G.S. Sec. 1-100. We have documentation indicating that Mr. Moffitt actively solicited a Connecticut State Senator and
lobbied him concerning his assistance with placing a certain proposal on the agenda of the State Bond Commission and he misrepresented to the State Senator that he [Moffitt] was "working with the City.. .on its Flood Control Management Program". I have recently written Mr, Moffitt advising him to cease and desist any work for the City or for any department, officer or agency of the City. A copy of that letter is attached. Please initiate an inquiry into this matter. My office and all appropriate City agencies are available at your behest to cooperate with such inquiry.
Yours truly,