Office of Campaign Finance
Notice opening an investigation into a possible gift by Vincent Mark Policy, a lobbyist, to Mayor Anthony Williams
Investigation 03-04
December 3, 2003

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OFFICE OF CAMPAIGN FINANCE
DISTRICT OF COLUMBIA BOARD OF ELECTIONS AND ETHICS
FRANK D. REEVES MUNICIPAL BUILDING, SUITE 420, 2000-14th STREET, N.W.
WASHINGTON, D.C. 20009  

December 2, 2003

Dorothy A. Brizill
D.C. Watch
1327 Girard Street, NW 
Washington, D.C. 20009-4915

Re:   Investigation 03-04 

Dear Ms. Brizill:

This is to acknowledge the receipt of your November 7, 2003 request for an investigation into the possible violation of the District of Columbia Campaign Finance & Reform Act (Act) by Vincent Mark Policy, Esq.. Additional information regarding this matter was received from you on November 17, 2002. Following the review of your complaint for legal sufficiency, it was accepted for filing Monday, November 24, 2003.

At the November 2003 meeting of the Board of Elections and Ethics, I announced that the Office of Campaign Finance (Office) was initiating an internal inquiry into the matter of allegations that Mayor Anthony Williams was receiving pro bono services from Mr. Policy in defense of a personal lawsuit. The inquiry was also to have involved whether Mayor Williams may also have been the subject of lobbying on his part with regard to Bill 15-133, the "Rental Housing Conversion and Sale Act of 1980 Amendment Act of 2003."

In your complaint, you alleged that Mr. Policy may have violated the Act because of his representation of Mayor Anthony Williams, as an individual, in a lawsuit brought against the Mayor and his re-election committee in the Superior Court of the District of Columbia by Thomas Lindenfeld. Specifically, your complainant alleges that Mr. Policy is providing legal services to the Mayor pro bono while registered as a lobbyist in the District for the Apartment and Office Building Association and the Washington, D. C. Association of Realtors and that Mr. Policy is lobbying the Mayor on the aforementioned Bill.

If true, there is a possibility that his actions may have constituted a gift or contribution to the Mayor in violation of the Act. This Office is considering the application of the following statutory provisions to this matter.

D.C. Official Code Section 1-1105.01(5) (2001 Edition) states: 

"The term "gift" means a ,payment, subscription, advance, forbearance, rendering, or deposit of money, services, or anything of value, unless consideration of equal or greater value is received, for the purpose of influencing the actions of a public official in making or influencing the making of an administrative decision or legislative action; and shall not include a political contribution otherwise reported as required by law, a commercially reasonable loan made in the ordinary course of business, or a gift received from a member of the person's household as defined by Section 1-1106.01(i)(4)."

D.C. Official Code Section 1-1105.06(a) states: 

No registrant [as a lobbyist] or anyone acting on behalf of a registrant shall offer, give, or cause to be given a gift to an official in the legislative or executive branch or a member of his or her staff, that exceeds $100 in value in the aggregated in any calendar year. This section shall not be construed to restrict in any manner contributions authorized in Sections 1-1131.01 through 1-1131.02 and Section 1-1104.03.

D.C. Official Code Section 1-1106.01(c) states: 

"No person shall offer or give to a public official or a member of a public official's household, and no public official shall solicit or receive anything of value, including a gift, favor, service, loan gratuity, discount, hospitality, political contribution, or promise of future employment, based on any understanding that such public official's official actions or judgment or vote would be influenced thereby, or where it could reasonably be inferred that the thing of value would influence the public official in the discharge of his or her duties, or as a reward, except for political contributions publicly reported pursuant to D.C. Official Code Section 11102.06 and transactions made in the ordinary course of business of the person offering or giving the thing of value."

Finally, according to D.C. Official Code Section 1-1101.01(6)(B)(i), a contribution shall not be interpreted as: 

"Services provided without compensation, by individuals (including accountants and attorneys) volunteering a portion or all of their time on behalf of a candidate or political committee."

The Office of Campaign Finance has opened an investigation into this matter to determine whether there is any merit to the allegations. See generally 3 DCMR Section 3701 (1998). All proceedings in this matter are confidential. However, the disposition of this investigation shall be made part of the public record.

If you have any additional information you wish to provide to this Office, please do so in a written notarized document, with any necessary attachments, on or before Friday, December 12, 2003.

Thank you for your cooperation in this matter. If you have any questions, please contact Wesley Williams, Investigator, at (202) 671-0555.

Sincerely,
Cecily E. Collier-Montgomery Director

cc:   Kathy S. Williams General Counsel
William 0. SanFord Senior Staff Attorney
Wesley Williams Investigator