Miami-Dade County Commission on Ethics and Public Trust Miami-Dade County Commission on Ethics and Public Trust Petitioner

Vs !uan Alberto Pascual "espondent #################################$ Statement of Jurisdiction The Miami-Dade County Commission on Ethics and Public Trust %C&E' has (urisdiction pursuant to Article )**V+++, section --.06/ o0 the Code o0 MiamiDade County and sections --.. .%a' and %y' o0 the Miami-Dade County Con0lict o0 +nterest and Code o0 Ethics &rdinance %the Code' COUNT I -!!"! #$% Prohibition on outside em&loyment !" Miami-Dade County Code, 1ec --.. .%2' %-', Prohibition on outside employment, statin3 in applicable part that all 0ull-time municipal employees en3a3ed in any outside employment 4 5shall 0ile, under oath, an annual report indicatin3 the source o0 the outside employment, the nature o0 the 6or2 bein3 done pursuant to same and any amounts or types o0 money or other consideration recei7ed 48 " "espondent admitted that he did, in 0act, ha7e unauthori9ed employment outside o0 his position 6ith the City o0 Miami, 6ith an entity 2no6n as the 1outh :lorida Tra7el )ea3ue %1:T)' Amended Ethics Complaint # C06-05

'" A re7ie6 o0 "espondent;s personnel 0ile did not produce any copies o0 0orms re<uestin3 outside employment or reportin3 outside income The City o0 Miami has ad7ised the C&E that no outside employment or 0inancial disclosure 0orms ha7e been 0iled by "espondent COUNT II -!!"! #(% Conflictin) Em&loyment &rohibited *" Miami-Dade County Code, 1ec --.. .%(', Conflicting employment prohibited, statin3 in applicable part that no person 4 5shall accept other employment 6hich 6ould impair his or her independence o0 (ud3ment in the per0ormance o0 his or her public duties 8 +" "espondent;s (ud3ment in per0ormin3 his public duties at the Par2s Department 6as sub(ect to recurrin3 con0lict bet6een the 6ants and needs o0 the ta=payin3 citi9ens o0 the City o0 Miami and "espondent;s o6n 0inancial sel0-interest in the 1:T) COUNT III -!!"! #n% Prohibited in,estments -" Miami-Dade County Code, 1ec --.. .%l', Prohibited investments, statin3 in applicable part that no person 4 5shall ha7e personal in7estments in any enterprise, either himsel0 or throu3h a member o0 his immediate 0amily, 6hich 6ill create a substantial con0lict bet6een his pri7ate interests and the public interest 8

." "espondent has put si3ni0icant personal in7estments o0 his time, e00ort and money into the 0ormation, administration and operation o0 the entity 2no6n as the S/T0 1" "espondent;s 6or2 as Par2 1uperintendent puts him in direct con0lict 6ith his employment 6ith S/T0 Throu3h his public position and o00ice, "espondent comes into almost daily contact 6ith the 1:T) and "espondent;s position 6ith the City places him in an optimum position to control and manipulate the circumstances that tend to enhance the 0inancial 6ell bein3 o0 "espondent, throu3h the S/T0, to the detriment o0 other citi9ens NOT234 2ND 5E3I/IED ST2TEMENT 1TATE &: :)&"+DA C&>?T@ &: M+AM+-DADE Personally 2no6n to me, and appeared be0ore me, Michael P Mura6s2i, bein3 0irst duly s6orn, says that the alle3ations set 0orth in this complaint are based upon 0acts 6hich ha7e been s6orn to as true by a material 6itness or 6itnesses and 6hich, i0 true, 6ould constitute the o00enses alle3ed, and that this complaint is instituted in 3ood 0aith ####################### M+CAAE) P M>"AB1C+ :D?E F-.GG0 Ad7ocate 0or the Miami-Dade Commission on Ethics and Public Trust .F B :la3ler 1treet, 1uite --0

1B&"? T& and 1>D1C"+DED to be0ore me this day o0, -006, at Miami-Dade County, :lorida

############################# My Commission E=piresE Personally Cno6n or Produced +denti0ication #########################