Veronica Diaz Ethics Investigation

8/12/2019 Veronica Diaz Ethics Investigation

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bidding and selection processes. W ith the exception of the Com munity R edevelopment Agencies, therules are supposed to apply for procurements secured by all city entities or boards, including thequasi-independent authorities, departments and trusts.The city attorney's office, however, is exempted by statute, at 18-72 (b)(16): This article shall notapply to legal services coordinated by and through the office of the city attorney citywide, including,but not limited to: attorney services, paralegals, expert witnesses, jury consultants, legal supportservices, legal research, court reporters and stenographers.The code, at 18-84, Methods of Source Selection, redundantly reinforces this exemption: Allpurchases of goods, including but not limited to supplies, materials, equipment, printed materials andall purchases of services, including bu t not limited to personal, professional, managem ent, technical,contractual and general services needed by the city, but not including legal services may beobtained by contract or through city labor and m aterials shall be exclusively made in the m anner setforth in this article.

Investigation:nterviews

Keri Lynda Horvat (Horvat) is a lawyer with the Miami law firm Trujillo, Vargas, Ortiz &Gonzalez LLC. From March 2011 to September 2013 she was a contract employee at a lawfirm that has subsequently come to be know n as A lvarez, Carbonell, Feltman & DaSilva PL ofCoral G ables (ACF& D). Horvat is an expe rienced real estate and comm ercial litigator, and holdsan active title insurance license. Since 2009 , she has been the sole proprietor of Horvat Law FirmPLLC , which primarily handles real estate closings connected with that title-insurance license.On April 7, 2014, Horvat provided sworn testimony to the COE. Multiple e-mails, withrecords and follow-up contextual explanations from Horvat, will be burned to a disc andadded to the file.

Aldo Bustamante (Bustamante), Real Estate Manager, City of Miami Department of PublicFacilities and Asset Management.Bustamante was interviewed several times in May-June 2013, largely to secure production ofthe city's master file on the project to expand the footprint of the former Coral Way NETcenter and adapt it into a community center and playground with additional parking. A coupleof follow-up conversations occurred in 2014, largely for fact-checking purposes and tocomplete the production of public records related to the successful purchase of two adjacentparcels and the failure to acquire a third.Bustamante was able to provide historic context as the project grew and morphed, how hisdepartment routinely seeks legal services from the City Attorney's Office, and detailedconversations regarding H orvat' s role in helping the city acquire the parcels.

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Veronica Adriana Diaz (Diaz) flia Veronica Xiques), is an assistant city attorney with theCity of M iami. She is currently on a leave of absence w hile pursuing an elected circuit Courtjudgeship. When this file was opened in 2013, she was known professionally by her marriedname, Veronica Xiques, but subsequently reverted to her maiden name prior to announcingher candidacy for the bench.This investigator had one brief phone conversation with Diaz in May 20 13. At the time she notedthat Horvat was an eminently qualified title attorney who was doing excellent work ( She's akick-ass attorney. ) on the city's behalf in trying to untangle a messy set of circumstances toclean up the titles and acquire the parcels in question. Diaz said she was aware that H orvat workedat ACF&D, but said the city's contract was with Horvat Law Firm PLLC. To her knowledge,Diaz said, ACF&D did not handle this type of real estate work. She described Alvarez as myboyfriend --- not fianc.This investigator asked Diaz some general questions regarding the way the city hires outsidecounsel. She confirmed that there is no rotating wheel or list of pre-qualified lawyers to conductspecialized work on a rotating basis. W e just hire people we know are qualified, she said. Diazmentioned that H orvat was hired under a boilerplate contract with a pre-set hourly rate. Thatcontract also caps the number of hours for a particular task. Diaz explained that the City Attorney'sOffice is exempt from many of the procurement rules that must be followed by other departments,agencies and q uasi-independent authorities under city code and charter.In the May 2013 conversation, she said the contract with H LF provides no benefit to ACF &D . Shealso said at the time that she didn't believe there was a conflict of interest worth reporting to hersupervisors at the city attorney's office.This investigator had a second brief phone conversation with Diaz in M arch 2014, asking primarilyfor her files regarding the outside work she assigned to H orvat regarding an Opinion of Title for acity-owned marina parcel at Watson Island. She agreed to forward her complete file on the WatsonIsland title-opinion and a few outstanding documents needed to complete the file on the Coral W aycomm unity center acquisitions. She responded with a series of e-mailed docum ents, all of whichwill be burned to a disc most of her docum entation on the W atson Island title-opinion contractalong with a few documents needed to complete the investigative file on the Coral W ay comm unitycenter acquisitions. She responded with a series of e-mailed docum ents and added to the file.

Document/Audio/Video Review:

City public records, reports, emails, closing documents and contracts rearding the acquisitionof two parcels of land adjacent to the community center at 1300 SW 12 Ave. and theunsuccessful attempt to acquire a third adjacent parcel.

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Disc of all e-mails and attachments between this investigator and Horvat regarding her workfor the City of Miami in 2013 while she was employed at ACF&D.The materials include HUD- 1 closing documents, invoices, bank statements and cancelledchecks indicating when Horvat received payment and then transferred her entire fee of $6,448to ACF&D, per her verbal employment agreement with ACF&D.The materials also include bank statements, cancelled checks and invoices related to her workon a separate Opinion of Title on Watson Island, for which she was paid a $1,000 fee plus$150 in expenses. During her delivery of the documents to this investigator, she discoveredthat she under billed the city for another $195 that she paid to a title abstract vendor. She atethose expenses. She kept the entire $1,000 fee for the Watson Island work because the citypaid her shortly after she was fired by ACF&D in September 2013.

Miscellaneous investigative notes from the early stages of the investigation before anyone wasinterviewed.These notes will include photographs of Diaz and Alvarez and other friends that were posted(and subsequently deleted) from Facebook; Horvat's background, CV and other materialsfound on Facebook and Linkedln; the state of Florida corporate record history for Horvat LawFirm PLLC and the various permutations of the ACF&D law firm.The files also include some public records confirm the marriages and divorces of Diaz andAlvarez and some of the related litigation between Alvarez and his ex-wife and his formerfather-in-law.

Conclusion(s):Please refer to the attached 7-page memorandum dated June 10, 2014 (Exhibit A) for acomplete narrative history of the case, relevant facts, analysis and suggestedrecommendations forwarded to the city auditor's office.Diaz steered two complicated city legal assignments to Horvat dlb/a Horvat Law Firm PLLC.[The first task, helping the city acquire a residential parcel tainted by title fraud andforeclosure pressures, ultimately generated a fee of $6,448. The second task, requiring anOpinion of Title for a marina site on Watson Island, so that sewer construction permits andeasements could be legally obtained, generated a fee of $1,000.]Horvat was employed at the time by a Coral Gables law firm headed by Diaz's live-inboyfriend, Alvarez.Horvat testified, under oath, that she had never met Diaz prior to receiving the first of thesetwo assignments for outside legal counsel from the city.Horvat and her paralegal conducted most of the work on the city's behalf for Horvat LawFirm PLLC while physically sitting inside the ACF&D offices in Coral Gables; Horvat usedACF&D phones and faxes, and, at times sent e-mails to city officials and others involved in


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the city real estate transaction from her ACF&D e-mail address.Horvat testified, again under oath, that she learned of the impending first assignment from herboss and Diaz's boyfriend, Alvarez. Under the terms of Horvat's employment agreement, shewas required to deliver the entirety of her fees for these two city jobs to ACF&D. Shetransferred the $6,448 fee for the first city job to ACF&D in July 2013. Had she not beenabruptly fired by ACF&D in September 2013 before she received her $1,000 fee for thesecond city assignment, Horvat would have been obligated to transfer that entire fee as well.While there were legitimate reasons for the city to hire Horvat's solely owned affiliate firm,Horvat Law Firm PLLC, for the first job, since it maintained all of the appropriate titleinsurance licenses and escrow accounts, it served to obscure the fact that Horvat's firm wouldultimately be required to pass through the entirety of its fees to Alvarez's firm.

ANAL YSISThis is one of those difficult situations where the appearance of impropriety is strong, but thefact pattern isn't specifically covered under state anti-Nepotism statutes or the Miami-DadeConflict of Interest and Code of Ethics Ordinance.It also illustrates one of the ways in which the legal definitions of immediate family havenot kept pace with the realities of modern families. Alvarez and Diaz have lived togethersince at least November 2011, but are not married, nor have they filed to certify a domesticpartnership. It would also be difficult to present a case accusing Diaz of exploitation ofofficial position under the county code because the City of Miami procurement lawsspecifically allow her to select any attorney of her choosing to do city work.It should also be noted that Horvat received two complicated jobs, in quick succession, whenshe was a contract employee of ACF&D and by all accounts; she performed admirably on thecity's behalf, especially in untangling the fraud-tainted title and foreclosures near the formerCoral Way NET Center.It might be purely coincidental, but Horvat received no further work from Diaz or the citysince Horvat and her paralegal were fired by ACF&D in September 2013.

RECOMMENDATIONSGiven the difficulty in establishing probable cause to any possible charges that could bebrought before the COE, we forwarded a copy of the complete investigative file to the CityAuditor General, who has already been in contact with the City Manager's office and the CityAttorney's office regarding the factual summary detailed in the memo of June 10, 2014,which is attached below. That memo lays out the fact patterns and recommends suggestedreforms.

Lawrence Le owitz, C vestigator5


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Approved by:

~ A111 / ~~Michael Murawski, Advocate iriam eputy General Counsel

7//'entorino, Executive Director ate Closed:


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FACTSEstablished relationshipAccording to public records, Diaz and Alvarez have cohabitated since at least November2011. In a brief conversation with this investigator in May 2013, Diaz referred to Alvarez as herboyfriend, not her fianc.Diaz's marriage was dissolved in 2008. Even though she continued to use her married name(Xiques) in professional settings, including her employment at the Miami City Attorney'sOffice, in November 2011 a Florida Driver's License was issued in her maiden name, VeronicaAdriana Diaz, listing the same address as Alvarez -830 Lugo Ave., Coral Gables. Diazrenewed the driver's license, in the same name and at the same address, in December 2013.Alvarez has owned the waterfront home on Lugo Avenue since August 2009, but only took solepossession of the homesteaded property in February 2014 after an extremely contentiousdivorce and a series of subsequent civil litigations involving his ex-wife and former father-in-law. Alvarez filed for divorce from his ex-wife in March 2011; it was dissolved in May 2012.

Other public records are available tying Diaz to the same address as Alvarez and additionalwitness testimony could be developed, if necessary, to further confirm their relationship.

The first contract: Expanding the Coral Way NET centerThe city-owned property at 1300 SW 12 Ave., which had been used as the Coral WayNeighborhood Enforcement Team ( NET ) center for several years, was damaged by fire inthe mid-2000s. Shortly after he was elected, Commissioner Frank Carob, who represents theLittle Havana district, started pushing city administrators to use federal CommunityDevelopment Block Grant ( CDBG ) funds to rehab and repair the existing building for acommunity center with a small park, playground equipment and expanded parking.

The city purchased a condemned, bank-owned home, at 1320 SW12th

Ave., a narrow parceldirectly behind the NET Center, for $32,000 in September 2011. (Folio# 0 1-4138-008-0140;Deed of Sale is Consumer Solutions REO LLC, to City of Miami, ORB 27905/940; relevant cityresolutions: R-1 1-0291 and R-1 1-0287).Carollo pushed the Regalado administration and the Public Facilities department to furtherexpand the footprint for the envisioned community center and park. At the commissioner'surging, Public Facilities targeted two adjacent parcels to the south in an attempt to squareoff the block between Southwest 13th and 14t h Streets.This turned into an incredibly complicated task, according to various city records, emails andinterviews with Aldo Bustamante, Real Estate Manager at Public Facilities and AssetManagement, and in sworn testimony from Horvat.One of the targeted parcels, a single-family home at 1330 SW 12 th Ave., (Folio# 01-4138-008-0150), was facing foreclosure in 2012. Through a broker, owners Jesus Ramirez and KathyRivera indicated they were amenable to a short-sale. In October 2012, the city tentativelyoffered to buy the Raniirez-Rivera home for the full asking price of $270,000. Under the offersheet terms, the seller was responsible for any costs accrued to provide clean title.

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In late 2012, Public Facilities submitted a Legal Services Request ( LSR ) to the City Attorney'sOffice to help with the closing. The request was funneled to Diaz, who was responsible formost of the Real Estate and Public Facilities work generated by the department. Recordsindicate Diaz received approval from her supervisors, including then-City Attorney Julie Bru,to engage Horvat Law Firm PLLLC ( HLF ) as outside counsel (see Prolaw File 12-2586). Diaz,signing on Bru's behalf, sent Horvat an engagement letter dated Jan. 9, 2013 that allowed HLFto charge the standard rate, $235-per-hour, but capping the fees at $1,500. Horvat signed thecontract on Jan. 22, 2013.What the city didn't know at the time - and which nobody appears to have disclosed --- HLFwas required to transfer its entire fee to the law firm run by Diaz's live-in boyfriend, Alvarez,under the terms of Horvat's employment arrangement with Alvarez Carbonell.Horvat was hired as a contract employee by an earlier incarnation of the Alvarez Carbonellfirm in March 2011. She testified she was paid a base salary and received some health-carebenefits, but was responsible for paying her own payroll, Medicare and Social Security taxessimilar to any contractor reporting their income to the Internal Revenue Service on Form 1099.Horvat was an attractive hire for Alvarez Carbonell at the time, in part, because she had anextensive track record in complicated litigation and real-estate closings, and owned an activetitle-insurance brokerage license with Attorney's Title Fund.According to Horvat, at the time of her hire, Alvarez Carbonell had recently lost its affiliationwith the title fund. Some of the allegations, laid out in civil litigation, involved the improper useof the firm's escrow account and failure to pay $50,000 in proceeds to the proper party after aclosing. [This investigator did not independently verify any of the sworn testimony regardingAlvarez Carbonell's loss of the title insurance license and the related civil litigation]Horvat testified that under the terms of her employment arrangement with Alvarez Carbonell,all fees she generated would benefit the firm --- even those generated by her solely ownedaffiliate, HLLF, as long as the work was brought or assigned to her by Alvarez Carbonell. Sheprovided bank statements verifying several independent examples where she handled aclosing as HLF and then transferred the proceeds from her I-ILF escrow account to an HLFoperating account and then wrote a check for the full amount due to Alvarez Carbonell.Even though there were several name partners, according to Horvat's sworn testimony, shewas under the belief that Alvarez was the sole owner of the business, and, as such, was thesole beneficiary of all of the profits generated from the work she, and others, performed at thefirm. [While this testimony might illuminate the mixing of personal and professional businessbetween Diaz and Alvarez, these law firm ownership issues were not independently verifiedbecause they weren't relevant to the primary investigation].Horvat testified that she had never met Diaz prior to her hiring by the City of Miami, but knewthat Alvarez and Diaz were involved in a personal relationship. Horvat also testified that shelearned from Alvarez that she had been hired by the city to handle this specific job; Alvareztold Horvat she would be receiving an imminent phone call from Diaz with the details.As the city soon discovered, thanks in large part to the work by Horvat, any potential short-sale of the Ramirez-Rivera home at the corner of Southwest 12 th Avenue and 14 th Street, wasgoing to be complicated by potentially fraudulent title problems that had occurred on the

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other single-family home that the city was hoping to acquire at 1211 SW 14 h St. (Folio# 01-4138-008-0150).According to Horvat's sworn testimony and supporting city documents, Berta Garcia, theowner of 1211 SW 14t h St., had executed a series of suspicious quit-claim deeds in the mid-2000s with two intended purposes: To forestall a possible bank foreclosure, and to declaresole ownership of the home alter her estranged husband fled the US and became a fugitiveanLid criminal allegations. At least one of the quit-claim deeds, created by a lawyer workingfor Garcia, listed the wrong legal description for the Garcia home, somehow copying the legaldescription for the neighboring Raniirez-Rivera home at 1330 SW 12t h St. that the city wastrying to acquire. This inaccuracy was further exacerbated a few years later when Garcia'smortgage lenders at Bank of New York foreclosed on the home - and used the wrong legaldescription from the last quit-claim deed in the court proceedings.Horvat spent several months working with the banks and the courts to unwind and nullify thebank foreclosure on the Garcia property. This, in turn, allowed Horvat to provide an opinion ofclean title to the title insurance company for the city's intended purchase of the Ramirez-Rivera home.

[After identifying and cleaning up the fraudulent title, and allowing Garcia to regain control ofher foreclosed home, the city attempted to acquire the property. According to Horvat's sworntestimony, plus records and interviews with Aldo Bustamante at Public Facilities, the cityeventually abandoned the effort to acquire the property because Garcia and herrepresentatives kept raising prices. She sold it to private investors in October 2013].Horvat ultimately submitted an invoice for 27.6 hours of legal work - generating a total fee of$6,486. Of that total, 6.7 hours, or $1,574.50, was billed to the city as Buyer's Title Work and20.9 hours, or $4,911.50, was billed to the sellers and their lenders to cure the Seller's titledefect. Most of these fees are clearly delineated, as well, on the HUD- 1 closing statements.The sale closed June 27, 2013.According to Horvat's sworn testimony, alter paying all of the appropriate taxes, recordingfees and costs to messengers, paralegals, surveyors, inspectors, the title insurance companyand the seller's broker, HLF wound up with $6,884 in net proceeds from the closing. On July 2,2013, she wrote a check on the HLF operating account to Alvarez Carbonell for the exact sameamount --$6,884. HLF bank records indicate the check cleared on July 8, 2013.The Second Contract: Watson Island Opinion of TitleIn late 2012, the Public Facilities department submitted another LSR through Diaz seeking anopinion of title on a piece of city-owned land at 1099 MacArthur Causeway that is occupied bythe Miami Outboard Club under the terms of a 20-year lease ratified by the city in 1996. (SeeProlaw file 13-057). The club was under pressure for a long overdue upgrade from septic tosewer and the city needed to provide a clean opinion of title and an easement to the countyDepartment of Water and Sewer in return for the upgraded service.Title at Watson Island is convoluted due to numerous takings and conveyances dating back tothe early part of the 20 th Century between the federal government, the State of Florida, theCity of Miami and other entities with land-based and submerged interests in the area.Pleased with the work that Horvat had performed on the Coral Way NET center acquisitions, inlate May 2013, Diaz, with the approval of then-City Attorney Bru, hired ELF to provide the

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Opinion of Title so the outboard club could pay impact fees and complete the work, and thecity could convey the sewer easement to the county.Diaz sent Horvat a boilerplate engagement letter insuring that HLF would receive a $1,000 flat-fee plus expenses for the Opinion of Title. FILF performed the work and delivered the opinionin an 88-page report dated July 12, 2013.HLF invoiced the city for the $1,000 fee and an additional $150 in title abstract expenses for atotal payment of $1,150. During her delivery of documents to this investigator and insubsequent sworn testimony, Horvat discovered that she actually paid the title abstractvendor $345 for the work performed, so she ate the extra $195 in expenses that she failed tobill the city under the terms of her contract.It should also be noted for the record, that unlike the first contract, where she passed throughthe entirety of her $6,448 fee to Alvarez Carbonell, Horvat did not share her $1,000 fee for theWatson Island title opinion because she received her payment shortly after she and herparalegal were fired by Alvarez Carbonell in September 2013.Otherwise, she testified, she would have been obligated to pass the proceeds of that fee toAlvarez Carbonell as well.Horvat testified that she has received no other work from Diaz, or anyone else at the city, sinceshe was forced to leave Alvarez Carbonell.Contacts with Veronica DiazThis investigator had one brief phone conversation with Diaz in May 2013. At the time shenoted that Horvat was an eminently qualified title attorney who was doing excellent work( She's a kick-ass attorney ) on the city's behalf in trying to untangle a messy set ofcircumstances to clean up the titles and acquire the parcels in question. Diaz said she wasaware that Horvat worked at Alvarez Carbonell, but said the city's contract was with Horvat'sfirm, HLF. To her knowledge, Diaz said, Alvarez Carbonell did not handle this type of realestate work. She described Alvarez as my boyfriend --- not fianc.This investigator asked Diaz some general questions regarding the way the city hires outsidecounsel. She confirmed that there is no rotating wheel or list of pre-qualified lawyers toconduct specialized work on a rotating basis. We just hire people we know are qualified,she said. Diaz mentioned that Horvat was hired under a boilerplate contract with a pre-sethourly rate. That contract also caps the number of hours for a particular task. Diaz explainedthat the City Attorney's Office is exempt from many of the procurement rules that must befollowed by other departments, agencies and quasi-independent authorities under city codeand charter.In the May 2013 conversation, she said the contract with HLF provides no benefit to AlvarezCarbonell. She also said at the time that she didn't believe there was a conflict of interestworth reporting to her supervisors at the City Attorney's Office.If we were to pursue this matter further, this investigator would want to ask Diaz, under oath,whether she ever disclosed that the work she contracted would ultimately benefit the law firmowned by her live-in boyfriend, Alvarez.

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This investigator had a second brief phone conversation with Diaz in March 2014, asking formost of her documentation on the Watson Island title-opinion contract along with a fewdocuments needed to complete the investigative file on the Coral Way community centeracquisitions. She responded with a series of emailed documents.A PPLICA B LE CO U NTY A ND CITY STA TUTE SUnder IVlianii-Dade County's Conflict of Interest and Code of Ethics ordinances, Sec. 2-11.1(c)(1) prohibits public officials from transacting any business in which he or she or a member ofhis or her immediate family has a direct or indirect interest. Sec. 2-11.1(d) prohibits publicofficials from entering into any contract or transacting any business through a firm,corporation, partnership or business entity in which he or she or any member of his or herimmediate family has a direct or indirect controlling financial interest. The county code, atSec. 2-11. 1 (b)(9), defines immediate family as spouses, domestic partners, parents,stepparents, children and stepchildren of the public official. At 2-11.1(b) (12) the code definesdomestic partners as any persons who have formally registered their relationship as furtherdescribed under the county's anti-Discrimination codes at Sec. 11 A-72 (b) (1-4 and 6).Under Sec. 2-11.1(g), public officials are prohibited from exploiting their official position tosecure special privileges for himself, herself or others except as may be specificallypermitted by other ordinances.Most City of Miami procurements, including the hiring of professional services, are subject totransparent competitive bidding and selection processes detailed in Chapter 18, Article III, ofthe city code. With the exception of the Community Redevelopment Agencies, the rules aresupposed to apply for procurements secured by all city entities or boards, including thequasi-independent authorities, departments and trusts.The city attorney's office, however, is exempted by statute, at 18-72 (b)(16): This article shallnot apply to legal services coordinated by and through the office of the city attorney citywide,including, but not limited to: attorney services, paralegals, expert witnesses, jury consultants,legal support services, legal research, court reporters and stenographers.The code, at 18-84, Methods of Source Selection, redundantly reinforces this exemption: Allpurchases of goods, including but not limited to supplies, materials, equipment, printedmaterials and all purchases of services, including but not limited to personal, professional,management, technical, contractual and general services needed by the city, but notincluding legal sewices, may be obtained by contract or through city labor and materialsshall be exclusively made in the manner set forth in this article.ANALYSISThis is one of those difficult situations where the appearance of impropriety is strong, but thefact pattern isn't specifically covered under state anti-Nepotism statutes or the conflict ofinterest or exploitation of official position sections of the county code.It also illustrates one of the ways in which the legal definitions of immediate family have notkept pace with the realities of modern families. Alvarez and Diaz have lived together since atleast November 2011, but are not married, nor have they filed to certify a domesticpartnership. The only reason a complaint is not being filed under the anti-Nepotismprovisions of the county code is because fianc or long-term, live-in boyfriend are notincluded in the definitions of what constitutes an immediate family member.

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It would also be difficult to present a slam-dunk case accusing Diaz of exploitation ofofficial position under the county code because the City of Miami procurement lawsspecifically allow her to steer the work to any attorney of her choosing.This is particularly ironic given that one of her duties as an assistant city attorney is to act aslegal adviser to city departments, agencies, boards and selection panels as they try tonavigate the complicated competitive-bidding and proposal-ranking processes and the Coneof Silence ordinances.It should also be noted that Horvat received two complicated jobs, in quick succession, whenshe was a contract employee of Alvarez's law firm. And by all accounts, she performedadmirably on the city's behalf, especially in untangling the fraud-tainted title and foreclosuresnear the former Coral Way NET Center.It might be purely coincidental, but Horvat received no further work from Diaz or the citysince Horvat and her paralegal were fired by Alvarez Carbonell in September 2013. It shouldalso be noted that Horvat and her paralegal were immediately hired by a competing firm --Trujillo Vargas - that was created by several disillusioned partners as they left AlvarezCarbonell.RECOMMENDATIONSGiven the difficulty in establishing probable cause to any possible charges that could bebrought before the Commission on Ethics and Public Trust, we are recommending that a copyof this complete investigative file be forwarded to the City Auditor General, the CityAttorney's Office and the City Manager to lay out the fact-pattern and suggest likely reforms.These would include:

Making the City Attorney and City Manager aware that a staff attorney wassteering outside legal work to a law firm owned by the staff attorney's live-inboyfriend;Asking the City Auditor General to investigate, on a broader scale, whetheradditional contract work is being steered to friendly or preferred members of thelegal community, especially in cases where there are plenty of qualifiedproviders available who could compete for non-specialized tasks such as realestate closings, opinions of title, etc.;Asking the Auditor General to urge the City Attorney and the City Manager tocreate a centralized database of Legal Services Requests that can be easilytracked and audited;Recommending that the City Attorney's Office consider narrowing the codifiedexemption in the procurement code in an attempt to create a wheel system thatevenly distributes routine outside work to a previously qualified panel of legalproviders;Recommending that the City Attorney's Office strengthen internal policies, andrestructure its office forms, including the LSRs, so that staff attorneys are requiredto declare and document potential conflicts of interest to their supervisors whileprotecting attorney-client privilege.

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Documents

Veronica Diaz Ethics Investigation