Title:قوانین اخلاقی و ملاحظات برای برنامه ریزان، کمیسران طرح و وکلا

توجه: این پخش اینترنتی واجد شرایط دریافت ۱٫۵ سانتی متر امتیاز آموزش از راه دور اخلاقی برای هر کسی است که بین ۱ ژانویه ۲۰۱۴ تا ۳۱ دسامبر ۲۰۱۴ آن را مشاهده کند. با حمایت مالی: کانکتیکات شرح فصل: لطفاً به این پخش اینترنتی مهم، آموزنده و جذاب در مورد قوانین اخلاقی و ملاحظات حاکم بر برنامه ریزان، کمیسیونرهای طرح و وکلایی که با برنامه ریزان کار می کنند و در کمیسیون های طرح حضور دارند، بپیوندید. پخش اینترنتی منابع اولیه قوانین اخلاقی برای برنامه ریزان و وکلا، اشتباهات رایج اخلاقی و نحوه اجتناب از آنها و موارد اخیر را پوشش می دهد. علاوه بر این، پخش اینترنتی دارای یک جزء تعاملی است که شرکت کنندگان را قادر می سازد تا با ارائه دهندگان و سایر شرکت کنندگان در مورد سناریوهای اخلاقی تعامل داشته باشند.

قسمتي از متن فيلم: Good afternoon everybody and welcome to the webcast my name is Christine Darcy I’m the executive director of APA Ohio and vice-chair of the New Urbanism Division I will be the moderator for today’s webcast along with David Silverman today Friday November 22nd we will hear the presentation ethical rules and considerations for planners plan

Commissioners and lawyers for technical help during today’s webcast type your questions in the chat box found in the webcast toolbar to the right of your screen or call the 1-800 number shown for content questions related to the presentation type those in the questions box also located in the webcast toolbar

To the right of your screen we will answer those if time allows at the end of the presentation during the QA on your screen is a list of the sponsoring chapters and divisions I’d like to thank all of the participating sponsors for making these webcasts possible today’s webcast is sponsored by the Connecticut

Chapter for more information on this chapter and how to become a member visit CCAP a org to learn more about all the chapters visit planning org slash checkers there we go on your screen is a list of the remaining 2013 webcasts to register for these webcasts please visit Utah

APA org slash webcast the 2014 season is right around the corner so stay tuned for the list of 2014 webcasts to log your cm credits for attending today’s webcast visit planning that org slash cm select today’s date and today’s webcast this webcast is approved for 1.5 CM ethics credits yay

Like us on Facebook planning webcast series to receive up-to-date information on upcoming sessions we are recording today’s webcast and it will be available on our youtube channel just search planning webcast on youtube a PDF of the PowerPoint will be available at Ohio planning org slash webcast presentations I’d now like to introduce David

Silverman he’s my co-moderator for today’s session David is a partner with Ansel Glink in Chicago specializing in local government and land use matters prior to his career as an attorney David was an urban planning and economic development consultant David is a frequent writer and speaker on a wide variety of land-use and economic

Development issues David is a member of the American Institute of Certified planners and the honorary Society for advancement of land economics lambda alpha International Eli chapter David is co-chair of Ansel Glenn’s zoning and land use group and co-editor of the group’s enewsletter in the zone David also serves as moderator for the zoning

And land use groups Twitter site and sold Glink land so with that I would like to turn it over to David who will get the presentation rolling and introduce the rest of our speakers David I want to introduce our panelists then I’ll give an overview of our program

Today and give a basic introduction to some sources of ethical rules were professionals and various fields I don’t want to spend a lot of time on that because we did do this program back in September and we do know that it goes almost 90 minutes we do want to leave

Some time for questions and answers but without further ado I’d like to introduce Hiram Peck he is the current director of planning for Simsbury Connecticut he is an AICP planner with over 25 years of experience working with Anisa palette ease the federal government regional planning agencies and private clients among his recent

Activities in Simsbury and actually nationally are working with several planning firms and groups in many states and formed based codes specific to Simsbury the completion of planned area development regulations for that city that have resulted in two significant development projects work on low-impact development store regulations and workforce housing developed workforce

Housing development zones also with us as brian smith he is a partner robinson and cole in Hartford Connecticut he chairs that law firms land law section he concentrates his practice and land use and real estate representing both public and private sector clients prior to his career as an attorney brian

Worked in planning for Saratoga County New York and Eugene Oregon finally Evans seaman evan is an attorney of Robinson and Cole also owned Hartford Connecticut and is in the firm’s land use group he concentrates his practice and land use matters environmental in real estate representing both public and private sector clients he co-authors

Robinson and Colts excellent blog real loop a defense and if you’re not familiar with it I would highly recommend that you become familiar with it it is a great resource for the regulation and legal development of religious institutions he co-chairs the Connecticut associations municipal law section and serves on the APA planning

And law divisions Education and Outreach Committee with me so our roadmap for today is we will go over state and local ethical regulations certain sections of the ASEP code of ethics and professional conduct there are lawyers with us so we are going to also deal with ethical rules

For lawyers and the focus of course is always going to be on the interaction between planners plan commissioners zoning board members and lawyers we’re going to talk about common in new issues that raise ethical concerns and then there’s a series of hypotheticals with questions that will provide an interactive component to today’s

Presentation you will see when we get to that that there will be a series of questions with the hypotheticals that you’ll be able to vote on through your computers and the results will be instantly tabulated for everyone to see so let’s move into some of the ethical rules sources for ethical rules

Certainly begin at the state level for for the various public ethics laws that every state has for government officials a good example of this is for instance in Illinois the gift ban Act yeah Illinois’s gift ban acts certainly covers planners and plan commissioners and zoning board members in a it seeks

To ensure that the process of government is not unduly influenced by people being overly solicitous to the people that they have to work with to get development approvals now for those of you who don’t aren’t in Illinois that might seem kind of funny to you given our state’s history with these kinds of

Things but Illinois actually does have some very fairly extensive ethical rules then a lot of plan commissions and certainly zoning boards have their own ethic ethical rules and procedural rules and you do become familiar with those obviously when you become a playing commissioner or a zoning board member

Those are very important sources for how you conduct yourself as well and they would typically also include your own interactions with petitioners who may appear before you and then the municipality and the appointed officials and employees of the municipality and a Planning Department or certainly cover by the state laws that govern the

Ethical rules for their involvement in various processes so we’re not obviously the focus of this is going to be on the AICP code but every professional organization establishes its own ethical rules for the conduct of its members and the goal of course for all of these is

To ensure that it’s the membership in the American Institute of Architects Society of landscape architects and other organizations engineering organizations and whatnot is the same they want their members to operate in at the highest level with the most integrity to protect the process the public process and you know zealously

Represent their clients it matters that terms zealously represent certainly Falls for lawyers but I think at the same time for anyone who takes clients who are paying them to get results the the ethical rules and obligations that the various organizations that they need belong to also seek to protect that and

Ensure that for the integrity of the entire profession so I’m now going to turn it over to Hiram who will now go over various parts of the AICP update and without that here we go okay good afternoon everybody glad to have you with us this afternoon

Has been said my name is Hiram Peck I had the pleasure of being the Connecticut chapter professional development officer for six years a while ago and when I was doing that of course I dealt with a ICP certification and education of the chapter members with regard to the code a little bit

About the code today and then talk about some other specifics later on the code was originally the 2005 code was revised in 2009 was similar to the previous code there are four sections of the code there specifically important section a has to do with the ASP racial principles and ideals there are

۲۱ of those which is a daunting number certainly there are a number of rules of conduct 26 which are mandatory talk a little bit about that in a moment there are procedures that have to do with how various parts of the code work and how it functions and then rules for

Planners that are convicted of serious crimes I certainly hope that that doesn’t apply to anybody here today but primarily the aspirational principles and ideals in the code serve to indicate to the public what our primary obligation is and our primary obligation is in fact to the public interest it’s

Interesting that are there are a number of all parts of what constitute the aspirational principles and public interest to me many of the things can be consumed by things like excellence and design and social justice those items are especially critical in just about everything we do in one way or another

There are other parts of the code under the aspirational principles section which talks about the responsibilities to clients and employers to which we owe diligent creative and professional work the important part of this section of the code however though it says that such performance however shall always be

Consistent with our faithful service to the public interest so clearly the public interest resonates throughout the code and even in this section when you have clients and employers some interesting situations occur when this happens but you still need to make sure that you’re clearly keeping the public interest in mind at

All times these responsibilities derive from our special responsibilities to the profession and the ability to serve the public interest with specifically with compassion is really critical to our functioning on a professional basis on a daily basis I’m also found just sort of that it’s important that basic politeness is

Critical and while this isn’t stated in the code it does talk about the respect to all participants in the process and anybody that would like to be part of the process helping them become part of the process and that politeness might invite them into the process where they might

Otherwise feel unwelcome the concept of public interest is often debated and continuously redefined but it should be fairly firm in your mind and the planners mind as to what the public interest is well this is a concept that continuously evolves it’s important that we have a pretty firm basis in what

Constitutes the public interest on a daily basis we also have as the code says responsibility to our clients and employers an obligation to act with high integrity and daily basis consider for example an allegation that we failed to achieve our aspirational principles cannot be used as a subject of

Misconduct charge as part of the code or be the cause for disciplinary action but we still have to aspire to the aspirational principles that we seek to achieve and have also special concern for the long-range consequences of those things that we do on a daily basis we

Need to try to avoid real conflicts of interest or even the appearance of conflict of interest I know that any planners and other professionals that have done this for any length of time have probably been accused at one time or another of having some sort of conflict of interest whether they had

One or not it’s important to to avoid a real conflict of interest it’s also important that we explain to the public commissioners that we work with the fact that we’re presenting simply factual information sometimes might be viewed as a conflict but it’s important to make sure that people know that those are

Just facts that we’re presenting where we need to be responsible to the profession we need to make sure that our comments on other work of other professionals is fair and we need to contribute time and our professional expertise to groups that are lacking in adequate planning resources so that they

Have access to the process as well the section is that’s perhaps the most important at least immediately for us is section B of the code rules of conduct this section is is mandatory that is the ethics even though their situational often our mandatory that we follow these rules there’s 26 of these rules

Violations of their rules can result in a charge of misconduct investigation and possibly even enforcement procedures being launched against us if we’re found to be blameworthy by the AICPA thix committee we will be subject to sanctions that might include losing our AICP certification possibility of sanctions and the loss of license is

Obviously important to our continued professional work conflicts of interest possibly for direct personal or financial gain must also be avoided unless those arrangements are worked out in writing ahead of time with your principal employer or the client that you’re dealing with it’s important that we make sure that people are aware that

We are not misrepresenting either what we can do for them or the way in which we’ll do it we need to make sure that it’s done perfectly and with regard to the other professionals involved in the process Section C of the code talks about procedures there are 17 different

Procedural provisions that describe how we may obtain either a formal or informal advisory ruling should a potential question come up it’s important to know that only the ethics chairman which is Paul Farmer at the present time can give formal or information advisory rulings the details of how a charge or misconduct can be

Filed is contained in this section of the code as well and how these are investigated and prosecuted and even adjudicated is also contained in this section it’s important to know many planners may not realize that any person whether they’re a planner or not they file a charge of

Misconduct against an AICP planner so keep that in mind when you’re dealing with people it’s your counter or at people at public hearings especially when items get heated as they sometimes do and that SS come ethics complaints or requests for guidance can be sent in by

Phone or even by regular snail mail the planner can be expelled suspended or reprimanded if it’s if he or she is determined to be found guilty of the allegations against him or her the rules for the planners that is those are contained in section D of the code are

Basically have to do with serious crimes if the planner is convicted of a serious crime you have certain responsibilities in addition to being automatically suspended you need to notify the ethics officer and if you decide to seek reinstatement you can certainly file a petition for that but there are procedural provisions that govern

Situations in which the planner is convicted of a serious crime it’s interesting to note that the crimes are called out in the in the code in Section D and there are specific sections of it which talks about what those particular crimes are in fact conflict of interest

Is actually listed as a serious crime I suspect that not only would be the accusation of conflict of interest would be important but the proof of it would have to be absolutely important as well what to do if you were accused of such a thing the executive director ASEP

Executive director is the ethics officer only he can give a formal ethics opinion advice as I indicated before it can be issued in writing and it’s binding on the AICP member there can be formal and informal ethics advice you can call a ICP to discuss the details and know several people who have

Done that and you can ask for the opinion in writing or not but you certainly can ask for an informal opinion at any time you have a question it’s often better to talk to someone either a colleague that you might respect his opinion you might respect

But ultimately need to talk to a ICP if the question is serious enough and significant enough that you need outside opinion for that there could be no investigation or there could be no determination based upon the preponderance of evidence or there could be formal findings generally these are

Given within 21 days they are forwarded to the Ethics Committee for action in formal and informal opinions as I said you need to go to the Ethics Committee there are rules that many of us deal with as well with the commissioners that we deal with on a daily basis and there

Can be state ethics laws as David talked about previously there are obviously freedom of information laws there are local ethics ordinances as well and some towns commissioners and I suspect most towns and cities commissioners are asked to sign ethics ordinances that is the acknowledgement that they’re aware of

Them and what they say a prior to their being seated on the commission sometimes the mistakes by planners and commissioners include the following conflicts of interest you might have a board member that worked for an applicant years ago you might have a board member who either is a lawyer or

Real estate person who does closings or participates in closings board member again or a lawyer who went to a firm that represents an applicant or even a land ownership conflict that is a neighbor member of a club whether it’s a golf club or boating club or whatever

Those people may have in fact conflicts of interests that need to be disclosed it’s always better to talk about those ahead of time if the Commission feels that the person should disqualify themselves it would usually leave some Connecticut it’s up to the individual to determine whether

He or she has a conflict and they would ultimately disqualify themselves or not depending upon whether they felt that conflict was real or not there are a number of things that come up on a daily basis most of us know that communications are critically important

In terms of how you handle them you do not use confidential information to any kind of personal advantage no confidential documents are to be disclosed as part of the planning process on something that you specifically could make a final decision on many planners don’t have the ability

To make final decisions some do have administrative authority but you have to be very careful obviously when you’re dealing with confidential documents and your ability to make those decisions be careful with electronic communications and specifically it’s critical that they’re handled carefully even a telephone call conference telephone call

With a number of commissioners on it is determined to be meeting in Connecticut under the laws in Connecticut perhaps most most locations and if that meeting takes place it needs to be properly noticed agenda votes need to be noted and so on minutes taken critically important to be very careful with

Electronic communications email is very critical I need to be very careful with that as well few other critical mistakes are planners or other folks other professionals may take on only information that they feel competent and qualified to undertake for example if you are not a traffic engineer then you

Probably should not volunteer or get involved in taking the specific details of traffic evaluation rather than having a traffic engineer do it it’s also critical to be careful about biasing various individuals or prejudicing individuals of information that’s on incorrect what to do if you are unsure with any of

These things is to consult with your boss or your supervisor as I mentioned before you certainly can request an informal guidance opinion from the ethics officer AICP ethics officer you can consult previous rulings that have been made on similar situations that you may have come across and the basic thing

Is to use common sense it’s often been said that you probably ought not to engage in something that you wouldn’t want your mother to read in the newspaper the next day that’s sometimes a little bit of trait of a discussion but sometimes gives you a little bit of

Perspective about how to handle things on a daily basis to just sort of think talk about them now before you act to make a particular decision that’s the end of my presentation for this time and I’d like to turn the screen over to Evan Thank You Hiram and thank you for the

Opportunity to speak today I am going to cover ethical rules for lawyers and the first question that comes to mind where do these ethical rules for lawyers come from the common law privilege of confidentiality come from an evidentiary line of cases and that protects communications between attorneys and

Clients you also have the common law attorney work product doctrine and this arises from the premise that an attorney can’t provide full representation unless certain information is kept from his or her adverse adversaries the work product doctrine has been codified by Federal Rule of Civil Procedure 26 B 3 and

Federal Rule of Criminal Procedure 16 B 2 it’s also important to know that the states also have their own formulations of these two doctrines I’m sorry I mean I’m sorry we can’t see your screen did you select yes all right hold on one second it just took you away hold on let

Me let me bring you back okay let’s try this again all right well hey there we are this is the first slide not much to show there I’m on my second slide right now sorry for that okay we’re good now thank you yep thank you so as I mentioned it’s

Important to note that states have their own formulations of these two doctrines so for all the lawyers up there and others who may be interested in this you should be aware of that of those in your own jurisdiction in addition there are attorney codes of conduct and professionalism most notably the

American Bar Association’s model rules of conduct most states have adopted these in some form or another and I am going to shortly discuss these model rules and particular provisions that may be of interest there are also state Public ethics laws again it’s important to be aware of your own local state

Ethics laws they could differ from the American Bar Association rules or have additional provisions so you have to be cognizant of those attorney-client privilege everyone’s heard this term before this applies where legal advice is sought from a lawyer and his or her capacity as a lawyer to the communications relating to that purpose

Made and confidence there are a number of elements that have to be met for this privilege to apply it applies to communications between lawyers and clients communications that turn is broadly interpreted and to include more than just a conversation or oral statement it can also include written statements such as emails memoranda

Notes etc for the privilege to apply the communication I estimate be made in confidence or else it could be waived so if you choose to disclose legal advice that was provided to you or you accidentally disclosed to document that contains legal advice you may waive the privilege and very possibly won’t be

Able to later claim it the main purpose of the attorney-client privilege is that the client to allow the client to communicate freely with the attorney without the fear that these communications will end up in the hands of either another attorney or someone adverse to the client moving on

The work of products doctrine the focus of the work product doctrine is on encouraging the attorney to thoroughly prepare and not hold back thinking or work out of a concern that the work will be disclosed to the adversary so while the attorney-client privilege is sort of focused on the client the work product

Doctrine is more geared towards the attorney the work product doctrine extends beyond client communications including documents notes mental impressions of the attorney but it’s limited to preparation for litigation material collected specifically material collected by the attorney in prepper and preparing for possible or anticipated litigation is protected however it’s

Important to note that even if the document is considered work products whether it has to be disclosed depends on the type of information that’s sought and the opponents need for it if the opponent shows a significant need for the material the information might be able to be obtained depending on the

Local rule but the protection is the greatest and in some jurisdictions absolute for the attorneys thinking they’re thinking theories and mental impressions I mentioned the American Bar Association Model Rules of Professional Conduct and I’m going to now highlight some of the rules but as backgrounds the ABA provides standards the service

Models of the regulatory law governing the legal profession the rules are designed to be adapted by appropriate agencies as an inspirational guide for lawyers and as a basis for disciplinary action where appropriate there are three parts to the Model Rules the first part are canons which are norms or principles

Then there are ethical considerations and these are only aspirational finally there are different disciplinary rules which are mandatory the first rule that I want to highlight is model rule 1.6 which deals with confidentiality concerning the client lawyer relationship to summarize a lawyer cannot reveal information relating to representing a client unless

The client gives informed consent the disclosure is implicitly authorized to carry out the representation or the closure disclosure is explicitly authorized in the rules such as to prevent reasonably certain death or bodily harm there are also certain situations where a lawyer can reveal certain information this is to protect

Prevent crime or fraud from occurring conflicts of interest there are rules for guarding public’s interests for both current clients and former clients you can’t represent a client if the representation will involve a concurrent conflict of interest such as the representation being directly adverse to another client or if there’s a

Significant risk that the representation will limit the lawyers responsibilities to another client or a former client this is model rule 1.7 of the ABA rules regarding former clients a lawyer can’t represent another person in a substantially related matter in which that person’s interests are materially adverse to the former clients interests

Unless the client views informed consent in writing that’s rule 1.9 there are also specific rules to maintain the lawyers professional relationship and avoid any personal conflicts of interest for example a lawyer can’t enter into a business transaction with the client without the clients informed consent a lawyer can’t solicit a substantial gifts

From a client can’t prepare an instrument for non-relatives giving the lawyer a substantial gift and can’t negotiate an agreement with the client to give the lawyer media rights to a portrayal based on information relating to that lawyers representation of the client special conflicts of interest for former and current government officers and and

Employees are also covered by the model rules rule one point eleven states a lawyer who was formerly a public officer or government employee shall not otherwise represent a client in connection with the matter in which the lawyer participated personally and substantially as a public officer or employee unless the appropriate

Government agency gives its informed consent in reading to Allah that representation similarly a lawyer who’s currently a government official or employee shall not participate in a matter in which the lawyer participated personally and substantially while in private practice or non-governmental employment unless the appropriate government agency gives informed consent

In writing so there are certain duties as I mentioned to two former clients there are also duties to prospective clients the model rules section 1.1 ain’t cover covers this aspect so what’s a prospective client a prospective client is someone who consults with the lawyer about possibly forming a lawyer-client relationship if the lawyer

Learns information through that process even if that person never becomes a client the lawyer can’t use to reveal that information unless expressly allowed by the rules a lawyer can’t represent a client with interests materially adverse to the prospective client in the same matter or a substantially related matter if the

Lawyer obtained information that could be harmful to that person unless both the prospective client and effective client give informed consent and then one common example of this that people might hear is an example of a divorce where one spouse goes to a bunch of lawyers to conclude his or her other

Spouse from being able to get that clerics eye that lawyer to represent him or her in litigation the lawyer would be precluded it’s important to note that there are different roles of the lawyer that are covered by the model rules there are rules concerning the lawyer as a counselor as an advocate concerning

The lawyer involving transact transactions with persons other than clients and as well as specific rules for partners and associates of law firms so a lot of the times a lawyer will fit in more than one of these categories so it’s important to know exactly which categories you fit in and the rules that

Apply the Model Rules also discuss public service Hiram mention his presentation pro bono service for planners this also applies for lawyers the model rules state that a lawyer should aspire to around here at least 50 pro bono hours of legal services per year moving on to information about legal services the

Model rules cover what information lawyers can and can’t provide with regard to legal services rule seven point one concerning communication about lawyer services states that a lawyer shall not make a false or misleading communication about the lawyer or the lawyer services this rule also applies to advertising in addition the model

Rules have specific provisions on advertising including one about a lawyer not being able to give anything of value to a person Rik recommending that lawyer services except for reasonable costs of advertisement these rules also apply to firm names letterhead and specializations a lawyer can’t imply that he or she certified any specialist

Unless actually certified by an organization that’s been approved by a state authority or the ABA the rules also cover maintaining the integrity of the profession Hyrum discussed this a bit under the rules a lawyer if a lawyer knows that another lawyer has violated the rules of professional conduct that

Raises a substantial question as to that lawyers honesty trustworthiness fitness as a lawyer etc that lawyer must inform the appropriate authority in Connecticut this Authority is the statewide grievance Trinity so there provisions between the AICP and the Model Rules that are parallel duties to the profession both codes have

Provisions to maintain the integrity of the profession provisions on truthfulness accuracy and communication misrepresentation with regard to advertising don’t make false statements knowing conflicts of interest direct pecuniary pecuniary or mature material interest and finally ex parte communications model rule 3.5 B states that a lawyer shall not communicate ex

Parte with a judge juror or prospective juror common mistakes by lawyers the first conflicts of interests this area is broader than you might think it doesn’t just cover direct obvious conflicts of interests I mentioned previously financial and personal conflicts of interests but a good way to think about the conflicts rule is that

It governs a lawyer’s duty of loyalty to the clients which includes to protect the client from conflicts with other clients to protect the client from their own lawyer and to protect former clients from conflicting interests after representation is over you should also be careful when moving jobs whether from

Government to private practice and vice versa or between firms and you should know the conflicts rules that apply for that another area of common mistakes is client confidences a lawyer has an obligation to keep information confidential however these rules are broader than you might think and special rules apply to

Prospective clients and former government officials and employees one good thing to keep in mind in terms of pro bono clients is a client has a client and no matter who your client is you have to Adele ously represent that client so what are what should you do

After I’m sure the first thing you should do is report something that might concern you team supervisor about a rule 5.2 B says that a subordinate lawyer does not violate the rules of professional conduct if that lawyer acts in accordance with the Supervisory lawyers reasonable resolution of an arguable

Question or professional D D so if you’re an associate attorney and you have a dilemma you go to the partner seeking some advice and the partner offers you reasonable advice to resolve an arguable question of a professional duty that associate attorney has fulfilled his or her ethical obligations

The second thing you can do is a lot of times law firms have an ethics expert or loss prevention partner so you should know who this is and consult with this person in case anything arises and the last piece of advice is to document everything whether getting informed consent from a client

It’s a wave of potential conflicts or you’re notifying opposing parties who aren’t represented by counsel of court filings to avoid ex parte communications better to have hard proof as opposed to just your word in case a situation arises in which you find yourself having to defend yourself against the claim of

A violation of these rules so with that background in mind I am now going to turn it over to Brian Smith Thank You Evan and welcome to everybody good morning or afternoon depending whether you’re here on the west coast or the East Coast and we can

All agree it’s thank God it’s Friday and make sure we have this going so one of the key issues that lawyers face and in the context of land use is identifying the client so if you’re a municipal attorney and you are asked to represent a city or a community or a regional

Agency you have to determine what part of the governing body you are representing are you representing a Zoning Board of Appeals pre representing the City Council or other legislative body are you simply representing the mayor or a town or city manager are you representing just the planner or is it

Deemed that you’re representing every citizen in the town and this can relate to the question that Evan had mentioned with duties to a prospective client which is ruled 1.18 for attorneys is one of the things you are in the process of doing at that point is determining who

The client is and as you will see when we discuss some of the cases that have recently occurred the attorneys can get themselves sort of crossed up in this situation and it’s important for the intern attorney not only to determine this but when you are seeking to an

Engagement attorney to be very clear who it is and what role you expect the attorney to provide to you if you are on a commission a board or a viewer a planner now one of the other issues that has cropped up over the recent times is an issue both for attorneys and planners

And just about everybody else in the country which is the question of social networking and how is it used in land use there are all sorts of social networks out there now YouTube Facebook Flickr Twitter and YouTube is one of the means by which this very presentation will be

Transmitted over time so there are advantages to it because it can easily make a record of proceedings and presentations and public hearings it provides for transparency public participation is certainly encouraged with the use of social media however we are discovering there are disadvantages to this round-the-clock ability to to have public input and

Public participation when not everybody in the world is going to be truthful or accurate so when you look at the Internet one can certainly find statements that are not necessarily truthful or accurate again there has been tremendous issues with respect to copyright and sources of materials the the music industry itself founded

Tremendous difficulties when all its music was being downloaded despite copyright until we have cases like MTM versus roster and then you have non users or non governmental people getting involved and if you are a planner and/or attorney who has confidential issues that you are dealing with the minute you put some of these

Items onto YouTube or other social media or even emails that are not properly done such as on a on a you know listserv you can find you were what you had hoped to be confidential so to be suddenly in a worldwide format so what are the ethical considerations

For planners when it comes to social network one of the things you want to avoid is unintentional discrimination if planner is responsible for presenting all sides of an issue that’s going to go before a Planning Board or a city council or Zoning Board of Appeals a planners

Comments are normally taken as part of the record as a professional statement of the situation if a planner makes an offhand remark in in analyzing a situation or responding to a citizen and that becomes part of the record unintentionally it can do great damage to the city or town’s position as well

As the planners own career another thing is using these types of services to solicit prospective clients that’s certainly allowed but one cannot again provide misleading information you should not use the this kind of service for private communications and of course because of planners and Commission members our public officers virtually

Anything you commit to email Twitter Facebook is part of the open meetings and public records laws in both states there are exceptions but they one would need to be consulting with the city town or municipal attorney as to when you don’t have to disclose such items so if ethical consideration

For lawyers which is not surprisingly very similar to that of planners because these issues arise for us all here if you are communicating and you are not careful about how you communicate on a new social media you will you could inadvertently create an attorney-client relationship under the Model Rules of

Evidence had mentioned earlier 1.18 where and that particular rule just to remind everybody is where a person and discusses or communications with a lawyer considering the possibility of a forming client relationship that initial communication is supposed to be private as well at least enough information should be given so the lawyer can

Determine if the case is one that he or she does not have a conflict of interest with and what if the nature of the case is so that’s a you can inadvertently create a situation for yourself with when not paying attention to the transparency that this kind of media

Provides the candor to the tribunals is another issue that can arise and this is in Model Rules section 3 point 3 and that is candor to the tribunal is candor to typically to a court but it also is candor to a Planning and Zoning Commission or any governmental body

Administrative agency that a lawyer appears before so a lawyer cannot make a false or a statement or mislead or fail to disclose precedent and might be adverse to that lawyers clients position to a tribunal so that if you are making a misleading statement on a social network that becomes available to a

Tribunal and that can suddenly caused you to be conveyor a tional the rules on being candid and open and honest before them since this media is worldwide and if that again goes again to misleading communications or advertising under the model rule 7.1 and 7.2 where you take a

A positions or statements of your specialised certain area of law etc that can also cause you difficulties now social networking takes on another flavour an issue for planners and lawyers is the ethical considerations for the courts in maintaining impartiality and creating a public record and of course the issue of

Ediscovery which is really summing up what I’ve just been discussing if you were to a federal court system it now has what we call pacer as you can see a little artistic the representation of what it looks like when you go on to its website which is public access to the

Court electronic records so a federal court proceedings for you can sign on and for relatively minor fees you can search can find any case and look at the files of federal proceedings most states have a similar online service for court proceedings at least at the appellate levels and many at the trial court

Levels at this point so this creates a public record of in the prior to about ten years ago was very difficult for anyone to find money of the court proceedings that were going on but now it’s much easier to find allegations and who is suing whom and for what reasons

So the whole concept is to maintain the impartiality but one needs to be aware of just how broad the information is and its availability is universal talk about some recent cases that describe some of the situations that lawyers and planners find themselves in so first of all is planners who are

Lawyers you need to avoid conflict among competing codes one issue was a public official representing a private client and this is an a planner who’s a staff member but was a Planning Board member and in Newman steel versus a mayor and city council of the borough of Tinton

Falls the there was a development of a proposed development 39 acres of property in this New Jersey town for a redevelopment project and a member of the of a Planning Board Board of Adjustment and the environmental commission also happened to be a real estate broker and was a principal our

Realty firm and in 2002 when the redevelopment was beginning to be considered for this parcel the individual entered into an arrangement with one of the proposed developers for the 39 acres site and entered into a an agreement to to work with them in his capacity as a real estate broker so what

Happened in October of that year he had entered into he had started discussing this relationship in August of 2002 in October the Planning Board was considering a master plan that involved a 39 acre site he recused himself from that discussion in November once he a listening agreement had been signed up

He resigned his position from the board Planning Board that was actually that was exactly it was a November 22nd of 2002 today’s date so this plant went on and a lot of litigation erupted in 2005 and there were accusations made that his role tainted the entire set of proceedings

And the borough itself then said the profit he made representing his client should it be discourse to the borough because his role is a Planning Board official when he was also real estate broker was not proper the court however concluded that he did not improperly undertake the representation of the

Developer because he took appropriate steps and did not cause anybody to consider what he did was incorrect and that is because as soon as he understood that he might be involved with a private client he recused himself when he still on the board so that he did not

Participate in the discussions and then resigned before there was any actual votes made by the Planning Board and the courts found that that was sufficient now in this a different case the there was a County attorney in Kansas and in a situation where a board was going to to

Vacate two roads and there was a damages claim made by the landowner as a result of the vacating of two roads and the county attorney took on an advisor to the board was assessing the damages drafting a letter rejecting the the applicants application for damages and scheduling conducting damages hearings

Of remand and a variety of other things in a second role he became the sole advocate for the board itself and the Kansas Supreme Court found that these dual roles were simply much too close together and did not lead to the confidence that he could be impartial in undertaking his duties

Now there’s a another case here in Connecticut for personal conflicts of interest so this is a very interesting case this is in total Caruso versus Merritt and Zoning Board of Appeals and in this action a there was a youths variance of sought to allow for the use

Of automotive sales and services in a zone that did not normally allow for it and the mr. Caruso is in fact he’s only enforcement officer who sued the Zoning Board of Appeals for granting this use variance and the the merits of the case really wasn’t what this case turned on

What they turn on is one of the zoning boards members who had voted on the approval of the use variance his own personal attorney was representing the applicant and this was convened so a sufficient conflict of interest to say that the the board member should have disqualified himself and painted the

Proceedings so that it was remanded for further considerations and so this is a closed case because if they if you are an attorney and simply representing a board itself does that mean that every time thereafter a board member years later has to recuse him or herself

If you in a later role now appear as an applicants attorney and that’s not the case but in this situation the the applicants attorney had been the personal attorney for a board member for almost 30 years and it was not just on the business but on personal relationship and the confidence is that

This person had that led the court to decide that this was just to close a relationship between the attorney over the applicant and one of the board members that did that anybody in that public would say well wait a minute it’s a possibility there could be a taint and

That’s the standard is if there’s the appearance of impropriety then the court is going to err on the side of saying that we’re going to reverse this even if we don’t think there’s any actual proof of a favoritism now a fourth case another personal conflicts of interest case and

Again this is from New Jersey Supreme Court in this instance the city attorney had represented the City Council on a project and the City Council have made its decision about the project but then the city attorney in his private practice world represented an objector to the same project later before the

Zoning Board of Appeals of the same City and in this instance the New Jersey Supreme Court found that this is not proper and that even if the attorney had no again no obvious malice or favoritism being shown for one or the other the appearance of impropriety is the

Standard that should apply and therefore New Jersey set aside and made the finding that there was a conflict here and this standard is pretty well Universal throughout the country now finally the final case I would like to mention is one on the a topic favored by lawyers perhaps a bribery and corruption

Because it gets a lot more time to spend on issues however the this case the United States versus Plowman has a little bit of an interesting flavor in that the majority leader of the town council in Indiana claimed he had control of the zoning authorities in in

His town and the FBI learned that he was making these suggestions of his ability to control both of other agencies because of his role as Majority Leader of the City Council and so the FBI set up a sting operation and they they had a individual that they named mark called the mature

To say that mark was a strip club owner from San Diego and would like to locate his a similar business in Indiana and he was assured by the individual that yes you know he might be able to get this approved this use approved but he would

Need a fee in order to get this use approved okay he said and in the case to some money to throw around to the appropriate people and the the sum of money involved was five thousand dollars that the was the one payment that was actually made in $100 bills and then

Once that payment was made the FBI who had set up a sting entered the hotel room where there’s the transaction had taken place and arrested the City Council member the City Council member claimed entrapment that he really didn’t mean it etc etc and the court was not impressed

With his defense and in fact he was his conviction was affirmed by the Seventh Circuit so now with that ending I would like to turn it back to David to go over some hypotheticals thanks Bryan ok so we’ve heard a lot of really good information on ethical rules and considerations that plan commissioner

Zoning board members planners themselves and of course attorneys who appear before them must consider what we’ve done next is we’ve taken some of the information and distilled it down to a series of hypotheticals and as I said earlier when we do these hypotheticals there’ll be an opportunity for you to

Vote on some questions that will be associated with each one so without further ado I will move on our first hypothetical for the past year you’ve been an employee of the city’s planning department you are a member of the city committee charged with selecting a consultant to update the

Comprehensive plan your best friend since high school Joe Smith is called to schedule your annual birthday dinner your wives are good friends and for the past 10 years Jonah’s life of taking you and your wife to dinner at a nice local restaurant Jones the largest architectural firm in

The city in his firm as a strong contender for the contract update the plan you don’t immediately accept Joe’s invitation to dinner you wonder if it is ethical for you to accept his gift offer given the possible contractual relationship what should you do so we’re

Going to put a question up on the screen that you’ll have a few moments to react to and you will have an opportunity to vote on it Christina I’m gonna I can’t pull this up up that sure yeah that’s fine right now the polling is going on right now okay okay

I think we have a pretty good number let’s go ahead and share that oh you don’t okay well I can tell you um seventy-five percent yes 25 percent no to the question of whether the employee should stay the heck of it isn’t gonna recuse himself okay umm hiram I’d like

To get your thoughts on that sure I think that that’s probably the wisest thing to do I think that avoiding the the conflict is really important on the other hand I can see the people that that said that voted no I think the important thing there is you just make

Sure you don’t do both of them that is going to dinner and not just qualify yourself you probably need to also talk to the committee about it or indicate that you have a conflict potential conflict and in sees their opinion as well it’s interesting that you know you may

Not all even want to mention who the conflict is with but you just may have a conflict with one of the applicants so you don’t think anybody’s thinking about whether they value your opinion or they don’t value your opinions but I think the people that answered yes that’s

Probably the direction that I would hit it Christy there’s a second question and I think Harry touched that is a bit but why don’t you pose the question to everyone in attendance to give them a few moments to vote of it all right we’re doing it now if you just for me

Can you read the question what sanity to go for the poll results absolutely great okay I think we have a good amount the question is would disclosing the relationship to the department chair or selection committee be enough to cover for any ethical issues yeah I’m gonna

Turn it back to higher abuse I think you touched on this in your first answer but why maybe you can expand I just said sure I think the in this case I would I would agree with the folks who voted no I think it really depends upon what the

What the committee’s view was spent than the answer so I think it’s important that you pay close attention to what the committee’s answer is and then act accordingly so in this case just as simply disclosing and I think doesn’t really answer the question terrific all right 66%

Voted no and 34% voted yes let’s move on to our second hypothetical you are the head of long-range planning in a small city in a Great Plains state the planning director asks you in the zoning enforcement officers who have you having a feasibility of computerizing the president zoning code and to make

Recommendations for streamlining administration your report to the director was positive and you both asked to be a site to carry out the work the director decided however that doing the work in-house would be too disruptive to existing activities and said had you prepare a request for proposals the proposal if you were

Advertised at a number of publication no one responded to the RFP you and your Peleg you’ve been kicking around the idea of quitting your job and sending up a consulting firm to take out the project another planner of the department suggested this would be a conflict of interest you strongly resent

The suggestion as much as no one in the private sector seemed interested in doing the work if you don’t do it it’s probably won’t be done furthermore you think that having a streamlined system for administering the zoning code would benefit the public welfare so Christie why don’t you bring up the first

Question and we’ll discuss it a bit sure okay I launched that and it’s did the republication of the RFP to a wider audience cover any ethical concerns for the two planners and it looks like we have a fairly strong response you’ve 72% voted no yep let me give a little bit of

Gloss to that because I think maybe somebody got a little bit lost in translation there and that’s just perhaps the fault of the years Chris so we we we posed the idea that no one had responded they decide to go back out and republish and then after six weeks no

One of the respondents of the two planners and then the you’ve you’ve made the responses to the question hyrum does that does that period of time help the situation at all or is there still a problem here and if that six weeks isn’t sufficient to get past some of the

Ethical concerns that come up out of this hypothetical what in your opinion would be an appropriate amount of time to wait yeah this says this is a tricky question I think that it’s important to note I think that that both the planners that were involved did in fact leave

Their jobs according to what was said I think the republication is helpful and if no one still applied I think it’s it’s probably acceptable for to apply although I think they need to be really clear with everyone that exactly what the situation is so I think complete transparency is critical I know

That that in many cases there there’s a waiting period of a year that is going back to do work for our community that you’ve done work for before I think in this case if no one else is applied and it’s been reno ‘test my sense would be that it would be acceptable I’m

Certainly willing to hear other opinions but that’s that’s where I would come down well let me let me just ask this since it was a little part of the fact pattern we presented the the fact that this is presumably a community in the middle of say Kansas where there’s not a

Lot of primitive professionals to begin with operating and the RFP could just get looked over does it does geographic context play any role in how this might play out because this would clearly be an important project for this community and it would build certain efficiencies that does that change anything at all

Well I’m not sure that geography makes much difference David I think I would I would err on the side of just being completely transparent and if if the planning director and the in the committee are all honest with each other I think it would be certainly better to

Wait but if the committee commission or the committee or the community in fact wants to wait to do the work that’s fine but if they can’t and no one else has responded I still think it would be probably acceptable but again I’m not sure it depends on geography I just

Think you need to be really transparent all right let’s move on to our third hypothetical it’s a little bit of a longer fact pattern you are the planning director in a small but growing upper-income bedroom suburb city of a major metropolitan area as part of the department’s work program that was

Approved by the Planning Commission you were preparing a report about housing opportunities new census data confirms your suspicions that there’s a lack of land zoned for affordable housing by analyzing the median income current housing availability and other trends you’ve concluded that the amount of undeveloped land zoned for apartments

Should be doubled you are not alone in this assessment you planners has worked together at analysis and these recommendations at a plan Commission working session you share the results of the team’s effort and outline your recommendations you see that the commissioners are reacting negatively you know that many of the citizens will

Oppose additional rental units and the recommendations for more quadruplex errs and triplexes would not be popular a Planning Commission member raises the questions at the level of community dissatisfaction such a report might cause there seems to be no question about the validity of the analysis planning commissioners just don’t want

To make waves you feel provoked you share with your Commission components of those code that addresses the planners responsibility to serve the public interest well there has not been much public discourse of the topic you know that many of the citizens will see such an initiative as bringing low income

People into the community so far the news media has not asked any questions but you know from experience that you were likely to get a phone call from the city editor before too long let’s add a wrinkle to this the mayor calls you the person who appointed you and expressed

His grave misgivings about the report the realization of your own job security becomes very clear to you at that point Christie why don’t you bring up the first question sure okay the first question is does your duty to serve the public interest Trump your own personal considerations okay

It appears we have a resounding yes all right Hyrum I’m gonna go back to you and certainly Bryan and Evan if you have any thoughts of us feel free to chime in but Hiram why don’t you respond to that sure I would certainly have to agree with the

Majority on this one I think there are a couple things that that are at work here one is that the code is very clear about doing what you can to include people in in the process that don’t have an opportunity so the social justice thing I mentioned early on is really important

Here as well the other thing too if you’re I think clever about how you do your job is that there are a number of different products that that might be work work in that community it mentions quadruplex –is and triplexes might be better who are possible to suggest that

Other other types of units could could be put in place that would not be necessarily as large perhaps or be better in scale with the community so the design becomes critical but I think you also have to explain to the mayor that these are just the facts and it may

Be that the Commission decides not to accept your your recommendation but I think it’s your responsibility to propose those recommendations that you think are in fact symbolizes a social fill one justice here in this case all right I would just chime in miss Bryant that you also need to stand firm because

If this is a situation where the mayor is putting this kind of pressure on you and you cave in you could find yourself on a slippery slope and caving in every time there’s a somewhat controversial matter coming before your town it’s going to be nearly impossible to perform

Their job thereafter yeah that’s a that’s a terrific point and I think that kind of starts getting to our second question which actually deals with the politics of the community Christine let’s you put that up all right so the this the second question to this hypothetical is it proper to balance the

Real politic of a community with the principles of the planning profession all right this one this is 74% yes 26% now so that’s that’s interesting because you know we we know all of us and everyone participating has probably had some experience with this development matters especially bigger development matters

That have a significant impact at a community are inherently political events so Hiram what do you what’s your thought on that yeah go ahead no III think I think I would agree with the majority here I think it’s important to try to balance those to the extent possible I actually found professional

Career I had the good fortune to not at the same time but to follow Paul Davidoff in a job that he previously had with the municipality and left a large footprint in that community for for me to try to fill so it was very interesting I think you have to try to

To balance those I also think very strongly that if you’re not able to balance those and the politic becomes out of balance significantly out of balance with your professional aspirations and the code then you need to start looking for someplace else to work terrific in writing em and I just I

Don’t want to did you have any additional thoughts or no I I think that that that’s fair I can certainly understand that the question of course is when how real does the real politics have to be because you know you want to choose your battles and as you said

David all of this is inherently political but I put it sort of like the Supreme Court justice saying he knew he knew what an offer he was when he saw I mean you just know when you are at the point of a true ethical conflict

It’ll you sure got to that yep and I that’s an important point because we do operate in a political sphere and those ethical rules are designed to keep us operating with the highest level of integrity and while it is proper as we’ve discussed – just to balance the real

Politic of a community against your various ethical obligations those ethical obligations are geared toward keeping you as much as possible above the fray it’s certainly not completely possible to stay above the fray and various projects can present numerous opportunities certainly the type of scenario we’ve we’ve drawn out here

Could be one of those where the politics could just take on a life of their own let’s move on to the fourth one because we do want to leave some time for questions it answers you are a local land use lawyer represent a developer who in the face of organized community

Opposition led by a resident Joe Brown has just denied a permit to construct development within the city the developer appealed the denial of the permit to the city zoning Board of Appeals and was again denied the permit to concerted development in the face of strong opposition again led by this mr.

Brown now you have appealed the decision of the CBA to the city Superior Court you later receive and this is a unique thing I think on the East Coast this business of a City Superior Court but anyway you later receive court notice that mr. Brown has lawyered up and his

Filed elections across motions to your appeal shortly thereafter you look at your email inbox to notice and message with the subject Joe Brown wants to be your friend on Facebook you open the email and discover that is the same Joe Brown has become a terrific thorn in

Your side that has requested that you confirm him as a friend on Facebook even more fascinating mr. brown and what can only be described as an incredible moment of husba has sent you a private message asking if you would like to meet with them for drinks this weekend to

Serve this may demystified you said to share your computer screen all night Christine can you please pull up the first question certainly okay this one does the fact that Joe initiated the friend request matter okay let’s close this up and see what we have here

Okay 61% say no Brian this is right in your wheelhouse why don’t you give your thoughts on those yes well I think it’s it’s very helpful in fact that Joe Brown in this year the federal question that I as the attorney if I was the local industry did not do so because the

Ethical rules say he’s not supposed to be communicating with the opposing party directly if they have a lawyer and so anything where pro se it’d still be really an awkward situation to have them as your friend on Facebook for all the reasons I said before this social media

Is fraught with dangers yeah in you know these a you know I think social media itself is gonna evolved and just present more opportunities for these complications I’m Christine why don’t you pull up the second question and let’s get some chair actually okay this one so to be ignoring disclose to the

Judge and mr. Brown’s tourney okay let’s close it up 86% say yes okay Evan like to get your thoughts on this one I would agree with the was an 86% I think I would ignore I wouldn’t click deny the request because I wouldn’t want that to be construed as any type of communication

With the client I would talk to the opposing attorney and let him know what his clients up to and it’s appropriate speak to the judge there’s an issue that should be raised before him her great and I think we have a third question doing that Christine yes we do let’s

Pull that one up this is our last one let’s launch that one so do we convinced mr. Brown that his case has no merit on the basis of your duty to zealously represent your clients interests and I think he they usually friending him and then engaging him in

That conversation all right I’m gonna go ahead and close this up let’s share the results 92% say no um you know Evan and Brian you want to kick it around for a second well the temptation would be to say yes and convinced this person that he’s got

Nothing to win by proceeding but it’s going to be a nightmare for you if you were to do that especially if he has counsel because you’re going to find yourself probably before a grievance committee in your state yeah I would agree with that if you want to look for

A new profession then you can go ahead and try to convince him but otherwise I would not do that all right we have about five minutes left for questions and comments I’m gonna turn this over to Chrissy because I think you’ve been probably collecting some questions maybe there are there are

A lot of questions and sort of comments from the hypotheticals which will be a little difficult to answer in five minutes so there are a few kind of concrete question answers that that we can quickly go through way back in the towards the beginning of the presentation when we’re talking about

The serious crimes and why is accusation of conflict a serious crime because anyone can accuse that’s all right yeah I think the accusation is important because something led to it obviously but it’s important to make sure that that the accusation be not be allowed to stand I certainly wouldn’t say that

That’s the important the totally important part of it I would certainly say that the conviction where the proof of a conflict is really the important part there not the accusation Christine there’s a few others all right regarding conflicts of interest is there a time limit for example I worked for a private

Firm then switch to public sector which has the ability to let out contracts to firms that you previously worked at yeah this actually touches on one of our hypose and I’ll give it back to Hyrum I think he’s probably best to maybe take that one on yeah I would certainly think

That if it’s possible at all you know at least a year should should transpire between any time limit again I think being clear was the fact that you used to work there work for the other firm is important so just be as transparent as possible but again I would try to give

It at least a year before you did that there is there is something in the code that talks about three years I think that’s a little different situation the change in circumstances and so on you can take a look at the code there but I think a year certainly is a good enough

Time to allow that to pass maybe we have time for two more questions good yeah that some states have revolving door policies or laws the books depending on what kind of public official you were so you might want to check with that point yeah that’s that’s a really good point okay

Um do we as professionals forgo our freedom of speech in face of potential conflict of interest questions Brian where’s your thought on that one well we be yes in yes you could do in that context I mean because you are trying to balance in your role as professional you’re trying to balance

And be fair to others so your personal opinion or your freedom of speech isn’t really relevant to your job in that regard but it’s a very touchy area because there’s a certain point where you need to be able to speak freely as a professional and that goes to that

Hypothetical what do you do when the mayor wants to suppress your report so in some ways that is almost a First Amendment issue but really there are some trade-offs when you when you are in a professional context and again like a lawyer who has a client confidence to

Not speak freely about what the client conveyed to him or her despite his his or her personal opinion and otherwise right to free speech yeah and I would concur with that and I you know at least in matters of important public policy issues there might be other ways for you without directly

Being out front with this to get those thoughts and opinions out there do we have time for one more or do you want to move on to the other stuff that you need to go through Christine hello and not Christine hello there we go now we’re working um I think we’ll just

Close up shop now okay thank you so much this was really great so Hiram and Evan and Bryan and David Connecticut chapter thanks everybody this was really great and the questions are even just still coming in so you know so feel free to contact them for those stolen attendance just as a

Reminder to log those cm credits for attending today’s webcast it is approved for 1.5 CM ethics credits and this session is being recorded and will be available on our youtube channel however it’s not available for distance education so this concludes today’s session thanks again everyone for attending thank you to our speakers and

The Connecticut chapter and everybody have a great weekend Thanks thank you

ID: ii5UcOc0ceQ
Time: 1385400672
Date: 2013-11-25 21:01:12
Duration: 01:30:06

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