FREDERICK COUNTY ETHICS COMMISSION

c/o Office of the County Attorney

Winchester Hall
12 East Church Street
Frederick, Maryland 21701
fcec@FrederickCountyMD.gov
ETHICS COMPLAINT FORM

Instructions:
Please type or print the information requested.
Use of this form is not mandatory, but all of the information requested below
should be provided when a complaint is made.
Anonymous complaints are not accepted.
The Ethics Ordinance is found in Chapter 1-7.1 of the County Code of
Ordinances. A link to the Ordinance is provided on the Ethics Commissions
website.
Additional information about the procedures for resolving complaints may be
found in the Ethics Commissions Standard Operating Procedures, which are also
on the Ethics Commissions website.
Decisions on complaints are generally issued within 90 days of receipt of the
complaint.
Information about the Complainant:
Patrick Allen
Name of person making the complaint: _____________________________________________

Address:
4905 Rosehill Drive * Jefferson, Maryland 21755
______________________________________________________________________
Email
patrickwilliamallen@comcast.net
__________________________________________________________________

address:

Telephone number(s):
Home: __________________________
301.606.8727
Cell:
__________________________
Work: __________________________
email or cell phone
Preferred method of communication: _______________________________________________

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Information about the complaint:

Provide the specific provision of the Ethics Ordinance that you believe has been violated:
This allegation and / or charge is significant insofar as it presents unethical, if not illegal conduct,
based
on the Frederick County Ethics Ordinance [Section 1-7.1-5, Conflict of Interest] and / or
_________________________________________
Maryland Adultery statute(s)

Regina Howell and Blaine Young

Name of official or employee who is the subject of the complaint: ________________________

Describe the facts and circumstances that support the complaint. (Provide as much detail as
possible. Attach additional pages if necessary.)
A 20 page, 6 count complaint was filed with the Frederick County Ethics Commission on, or about, February 19, 2014.
NOTE : This document is in the Ethics Commission document archive.
Cited in the complaint document is Charge #6, to wit:
Supervisor / Subordinate Relations - Unethical personal relationship between the Frederick County Board of County
Commissioners President, Blaine R. Young, and the Frederick County Budget Officer, Regina Williams Howell.
__________________________________________
The initial correspondence in January, 2014 to the Ethics Commission was in the form of an email ... with enough information
to warrant a face-to-face hearing with the Commission panelists to present the details.
The Commission chose to treat the email as a complaint and rendered their denial.
Subsequent to the January, 2014 email correspondence, a 20 page, 6 count complaint was filed in February, 2014.
This document was thorough in its presentation of direct evidence.
The BoCC denied a funding request by the Frederick County State's Attorney to have the Washington County SA conduct
an investigation into the charges (4 felonies, 1 misdemeanor and 1 ethics violation).
The BoCC denied the request for investigative funding, which closed the file on the February, 2014 complaint ... a clear
example of obstruction of justice.
Now that Blaine Young and Regina Howell have gone on the record (Frederick News-Post, Dec. 17, 2014) that their
relationship began in December, 2012 ... Mr. Young's remarks in October, 2013 and during 2014, that he physically
separated from his wife and kids in August, 2013 reestablishes the fact that Mr. Young and Ms. Howell were engaged in
an extra-marital, adulterous affair ... a misdemeanor under Maryland law and a violation of county HR code of conduct.
The fact that Mr. Young is still associated with Frederick County government, holding an "office of profit" as a member of
the Planning Commission and Ms. Howell is still associated with Frederick County government, having been reassigned
to a new position within county government, does not diminish or eliminate their unethical conduct which has now been
thoroughly exposed and a matter of public record.

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NOTE : Witnesses are n/a regarding this complaint unless otherwise called by the Ethics Commission
for testimony.

Witnesses:
Identify any witnesses who have personal knowledge of the facts and circumstances related to
the complaint:
1.

Name:

______________________________________________

Address:

______________________________________________

Email address:

______________________________________________

Telephone number(s):

______________________________________________

Relevant information:

2.

Name:

______________________________________________

Address:

______________________________________________

Email address:

______________________________________________

Telephone number(s):

______________________________________________

Relevant information:

3.

Name:

______________________________________________

Address:

______________________________________________

Email address:

______________________________________________

Telephone number(s):

______________________________________________

Relevant information:

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I hereby affirm under the penalty of perjury that the contents of this complaint, including any
attachments, are true and correct to the best of my knowledge, information and belief.
/pwa/
___________________________
Complainants Signature

December 17, 2014

__________________________
Date

The state of Maryland still has what are known as "adultery laws" that afford relief to innocent spouses who
file for divorce on those grounds. MD Code Family Law 7-103.
Generally, adultery is defined as voluntary sexual intercourse between a married person and a person other than that
person's husband or wife. The sexual intercourse necessary for adultery must involve some penetration of the female
organ by the male organ, but a completion of the sexual intercourse is not required. MD Code Criminal Law 10-501.
Many states, including Maryland, make adultery a criminal offense.
----------------------------------------------------------------This Ethics Complaint has been filed with the Frederick County Ethics Commission, December, 17, 2014, citing
adultery and the public admission by both Blaine Young and Regina Howell as supporting evidence.
The complaint seeks an investigation into the adultery by both parties.

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