US. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT ‘an? WASHINGTON, BC 20410-0500 “ser ‘OPE OF GeNtRAL COUNSEL July 6, 2017 Memorandum for Fite From: Linda M. Cruciani, General Counsel for Operations, CAG. Subject: Ethics Advice for Secretary Carson’ Listening Tour OGC received several versions ofa list of entities and people with whom the Secretary planned to visit during a listening tour in Baltimore. OGC checked on the entitics and people and provided a summary of legal issues with respect (o pending litigation, legal issues, suspensions and debarments, Mason Alexander scheduled a meeting to discuss the Bultimore Listening Tour on June 14, 2017, After the meeting, { met with Mason Alexander and Lynne Patton to discuss the Tour. They raised concerns that some of the people on the list had been invited by the Secretary's son, Ben Carson, Jr,, and daughter-in-law. Lynne stated that Ben Carson, Jr. and his wife had asked for the following people to be included in the Baltimore Listening Tour: Bob Embry, Abell Foundation; Kevin Plank, Under Armour; Dan Hirschfeld, Genesis Rehab Services; the Paterakis Family; Teresa Carlson, Amazon Web Services; Bart Harvey, former chair of Enterprise, Fannie Mae board member, ind chair of the Calvert Foundation; and Seema Verma, Director of the Centers for Medicaid Services. Lynne also said that Ben Carson, Jr. and his wife may be doing business with these entities or may be interested in doing business with these entities. expressed my concern that this gave the appearance that the Secretary may be using his position for his son's private gain. After discussion, Lynne and Mason suggested pulling these names from the Listening Tour and. having a private family dinner with invited guests in Baltimore after the official business had concluded. Mason and Lynne had calendared a briefing on the Listening Tour for SOHUD for the next Monday or Tuesday. | was unavailable as 1 was at my son's college orientation. Beth Zore participated in person. and Sheryl Johnson by phone. 1 do not know wrether any ethics issues were discussed, but Sheryl later called me and said that she should have attended in person and that the details of the program and events were covered. (On Friday, June 23, I met with Beth Zore and Mason Alexander to discuss Mason's continued concems that Ben Carson, Jr. continued to be involved in the planning for the Baltimore Listening Tour and that some of Ben Carson, Jr.'s business associates were going to bc on the Tour as well as Ben Carson, Jr. and his wife. Following that conversation, Mason sent an ernail and asked us to participate in a televonference with Ben Cersun, Jr. on Monday morning. ‘On Monday, June 26, atthe beginning of the call around 9:00 am., {reintroduced myself and Beth introduced herself. | said that | wanted to clarify that when OGC had reviewed and approved entities and persons for the Listening Tour that this had been research into whether the entities were involved in litigation with the Department or had been suspended or debarted. I said wee hd gov-——espanol ad govthat OGC did not review the groups for whether they were doing business with Ben Carson, Jr. and ‘would not have the ability to do this. (I was concerned that Ben Carson, Jr. thought that OGC had “cleared” all the entities and people on the list.) | reminded him about our discussion in the early days of his father’s tenure and said that the Secretary could not have the appearance of misusing his position fora relative's private gain, Ben Carson, Jr. stated that his dad had asked him to help with the Baltimore tour. He said that he had invited associates “who work with us, but {who] advance HUD initiatives.” He said that hhe works with almost everyone who works in Baltimore. He said that his dad wanted to meet Kevin Plank and he had called Kevin Plank for his dad. He explained that “nothing we would do would be ‘near a conflict” and that “we don’t mix and match parties.” He said that his dad wanted him to be in the room [during the Listening Tour}. Ben Carson, Jr. said that he has three faw firms and 2600 ‘employees and gets audited on a regular basis. He said “our goal is for Dad to have a successful tenure” and that it was “helpful for us to get the right people in the room” to help build vision centers, He said that “HUD can't operate in Baltimore without touching on us.” As an example, he stated that he was on the Mt. Washington Pediatric Hospital board and gives them money, but does not get anything in return, Ben Carson, Jr. emphasized his desire to help his father ask the right questions during the Listening Tour. Beth suggested that he provide his father with alist of questions in advance. Beth said that withthe extensive list of participants on the tour, participants would not have the ‘opportunity to speak for more than six minutes each. Ben Carson, Jr. said that it was important that he ensure that there was follow-up on what was being said to his father. I explained that I understood that he might have staffed his father during the campaign in this way, but that the follow-up from the official meetings would be the resporsibility of HUD staff. Ben Carson, J. said that he had not staffed his father during the campaign. explained that the government-wide ethics regulations are the responsibility of the employee of the Department and that the issue would be whether his father (SOHUD) would be misusing his position for his (Ben Carson, Jr.'s gain.) or creating the appearance of the misuse of position. He asked me to email him the rules 2t am He said that he was comfortable that “our businesses are being insulated.” He also said that he didn't want to create undue concer for folks at the office and that he would speak to his dad Around 2:30, Beth, Mason and I went to discuss the issue with the Secretary. We advised the Secretary not to include Ben Carson, Jr. in the Listening Tour. handed SOHUD a copy of the email that I sent to his son with the government-wide ethies regulations about misuse of position. “The Sceretary said that it would be difficult to have a Listening Tour in Baltimore without his son’s involverrent as his son was the largest employer in Maryland. | said that [ understood his frustration, but explained thatthe rule that he avoid any actions that might create the appcerance of Violating the law was broad. He went over different components of the tour and we discussed the ethics issues invotved in each setting (Baltimore employee meeting, meetings with HABC and industries/government contractors, and the Health Fair.) We lef the meeting believing that the Secretary would not include Ben Carson, Jr. on any component of the Listening Tour with the possible exception of the Health Fait.Fror Sent: Benjamin Carson 17 Jun 2017 13:14:31 +0000 To: Michee| III atton, Lynne M Ce: poe 2 NE Meyrin Corson Subject: FW: HUD Baltimore Tour Anita, thank you for connecting us with Mike, we are excited to share details on the HUD tour and look forward to Exelon/BGE involvement. Mike, itis @ pleasure to meet you electronically. 1 am adding Lynne Patton, Special Advisor to the Secretary, who is coordinating the tour. If you have a couple times that would be convenient for a call over the next couple days to discuss the tour agenda, I am sure that we ean accommodate to your schedule, We look forward to speaking with you in the near future Warm Regards, Ben Jr. Benjamin S. Carson. J. Interprise Partners, LLC 6711 Columbia Gateway Dr Suite 475, Columbia, MD 21046 MOVE) ‘www. InterprisePartners.com From: "np we Date: Thursday, June 15, 2017 at 7:09 PM To: Benjamin Carscr Subject: Fwd: HUD Baltimore Tour Mark L. Powell Begin forwarded message: From: “jackson, Anita M:(8CE)" Date: June 25, 2017 at 3:28:29 PM EDT To: * 190 Ce: "Abboud, Michae! F: (°C as a ‘Subject: HUD Baltimore Tour ellom, Stacey:(BGE)" HUD-17-0330-A-000001Good afternaon Mr. Powell ~ Mr. Butler is schedule allows. terested in participating, provided his Byway of this email, llask you to contact Mike Abboud, CEO Office Principal Business Analyst, when you receive more information. Mike will serve as BGE point person, as it relates to Mr. Butler's possible tour participation. Thank you and have a good day, Anita Jackson Anita Jackson Chief of Staff to Calvin G. Butler, Ir, Chief Executive Officer Baltimore Gas & Electric, an Exelon Company 2 Center Plaza, 110 West Fayette Street 18° Floor . Baltimore, MO 21201-3708 410-470-8965 From: Mark Powell Date: June 15, 2017 at 12:49:00 PM EDT To: "calvin G. Butler, |" A “eutler J, Clin: Ce: "8enjamin Caro Sse eeereerer marl Subject: [EXTERNAL] HUD Baltimore Tour Dear Calvin, | trust all is well with you, One of my business partners, Ben Carson, Jr, asked if | could extend an invitation to you or one of your senior team ‘members to join Secretary Carson for the official Baltimore HUD Tour as part of the Secretary's National Listening Tour. The Mayor and Governor will be Participating, as will many of the Baltimore Business and Community leaders including, Kaiser Permanente, Genesis Healthcare, Under Armor, Living Classrooms, and Abell Foundation. The HUD Baltimore tour is scheduled to 28-29 June and the agenda is just now solidifying. Sorry for the short notice. lf you would like to participate, | can connect you or a designee to the point of contact at HUD to coordinate. Also, Ben has told me that a large focus of the tour will be on infrastructure and expanding public private partnerships. | am sure that Exelon/SGE participation would certainly add value to this event and all parties would benefit. HUD-17-0330-A-000002Fre Demarzo, Benjamin Sent: 26 Jun 2017 20:22:55 +0000 Te Bacon, James A;Coressel, Jacie Subject FW: HUD Baltimore Tour- La Cite site overview Attachments: LaCite_HU02017 tour.pdt This is for the briefing book for the new construction site visit, sending updated Lx! over now. ‘om: ni Sent: Monday, June 26, 2017 3:19 PM To: Alexander, Mason Ce: Meriynn Carson] Demarzo, Benjamit ; Dan thew ood I Senjarnin a Subjects HUD Baltimore Tour La Ce ste overview Importance: High Good Afternoon Mason, Attached is La Cite’s si will be sent later today ‘questions or Dan on his cell a ‘ional more detaile aif(0)(6) with an [(oX6) Jan G. Arias Co-Founder & EVP 646-674-0064 (main) (o)(6) (cell) ie deciopmen. Luc a Sent: Monday, June 26, 2017 1:09 PM To: Dan Bythewoog| | Senjamin Carson an Arias ‘Ce: Merlyn Carsor Demarzo, Benjamin E es Subject: RE: HUD Baltimore Tour ‘Wonderful. Ben and | will call you at 1:30pm today. Talk to you shortly! Kindest Regards, Mason HUD-17-0330-A-000249a Mason Alexander Director operation | of of US. Deparment of Heung ane Urban Deelament HO. 451 7 See SW Site 20218, 4025968 IC{TBG) From: Dan Sythewood Si Sent: Monday, June 26, 2017 11:04 AM To: Alexander, M5 iE 307 j2oin Csr ‘an Arias Cc: Merlynn Carscr I Dern2rzo, Benjamin erga TanTersrurmmpsse-sel Subject: RE: HUD Baltimore Tour Good Moring Mason, Itisa pleasure meeting via email and I hope you had a great weekend. Alls well on our front, as | hope all is well with you. 1 look forward to meeting you in person and having an opportunity to show you around Center\West. 1am currently in my staff meeting but will be available at call me on my direct dial 646-674-0066 or on my cell phonel(®)(6) ook forward to talking to you soon. with you and Ben. Please All the best, Dan From: Alexander, M250 cc Sent: Monday, June 26, 2017 10:45 AM To: Senjamin C2rs-7 ETT Dan Bythewood Se (20 is Meriynn C2rs°r is emarzo, Benjamin & Es ‘Subject: RE: HUD Baltimore Tour Good morning, Dan and lan. [hope alls well. Ben and | will be reaching out to you to discuss the etal of the visit. Can you please send us the best number to contact you, Look forward to speaking with you soon! Kindest Regards, HUD-17-0330-A-000250Mason ‘Mason Alexander Diectrcf Sched & Operation | Oe ot Admiration From: 8erj2rn 3: Sent: Sunday, June 25, 2017 10:19 AM To: bythe EE Ics: sor a a Subject: HUD Baltimore Tour Dan and Ian, Itis my pleasure to introduce you to Mason Alexander, the head of the advance team at HUD. Mason should be able to provide some details about the tour and logistics. As discussed, we are hoping to visit Center | West toward the end of the day on the 29". Thank you for working us in, we are very excited to learn more about the project. Best Regards, Ben kr. Benjamin S. Carson, Jr Interprise Partners, LLC 6711 Columbia Gateway Dr Suite 475 Columbia, MD 21046 (16) eS HUD-17-0330-A-000251