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c/o Office of the County Attorney

Winchester Hall
12 East Church Street
Frederick, Maryland 21701

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
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
Information about the Complainant:
Patrick Allen
Name of person making the complaint: _____________________________________________

4905 Rosehill Drive - Jefferson, Maryland 21755


Telephone number(s):
Home: __________________________
Work: __________________________
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:
Frederick County Ethics Ordinance : Section 1-7.1-5, Conflict of Interest - (G) Use of prestige of office, (1).
Frederick County Government Charter : Section 203.

Name of official or employee who is the subject of the complaint: Frederick County Council Members:
Mr. Billy Shreve and Mr. Kirby Delauter

Describe the facts and circumstances that support the complaint. (Provide as much detail as
possible. Attach additional pages if necessary.)
County Council members Shreve and Delauter, by sending a letter to the Governor of Maryland, using County
Council stationary and without consultation, deliberation and / or approval of the "Council as a Body", have
violated both Maryland State Ethics Law as well as governing provision(s) stipulated in the Frederick County
Please see Shreve / Delauter letter, dated February 20, 2015, as evidence of the violation(s). Copy of letter is
placed below the signature block of this ethics complaint document.
Supporting comments from County Executive Jan Gardner, County Council President Harold "Bud" Otis and
an admission by Councilman Shreve that he and Delauter did not consult with, discuss, or seek approval of
the letter and its content with the full County Council prior to sending the letter on his County Council
stationary and on top of signatures by himself and fellow County Council member Kirby Delauter.:
GARDNER : To a certain extent, its a rogue letter from two council people, County Executive Jan Gardner
said. It doesnt carry the weight of a letter from the county executive or the council as a whole.
OTIS : Council President Bud Otis said to his knowledge, Shreve and Delauter did not discuss the letter with
other council members before sending it.
SHREVE : Shreve said he did not engage the full council about his letter to Hogan...

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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.

Complainants Signature

____February 26,2015________

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