* Complaint C-12-06

STIPULATION OF SETTLEMENT AGREEMENT

This Agreement was made on this 21^st day of September 2006, between Quincey Gamble, Respondent and Suzanne S. Fox, Executive Director of the State Ethics Commission, acting on behalf of Staff Counsel.

STIPULATIONS

The State Ethics Commission (“Commission”) is an executive agency of the State of Maryland established for the purpose of enforcing the Maryland Public Ethics Law (Title 15, State Government Article, Annotated Code of Maryland, hereinafter the Ethics Law);

The Respondent is an individual whose lobbying activities on behalf of SEIU United Health Care Workers East – MD/DC Division (“the employer”) during the period of November 1, 2005 through April 30, 2006, required registration as a lobbyist with the State Ethics Commission;

The Respondent registered on January 3, 2006 as a lobbyist with the Commission for the period of December 20, 2005 through October 31, 2006, as required by the State Government Article, Section 15-703(d)(1) of the Ethics Law on behalf of the employer;

The Respondent was required to submit a Lobbying Activity Report by May 31, 2006 for the period December 20, 2005 through April 30, 2006, as required by the State Government Article, Section 15-704(a)(i) of the Ethics Law and failed to submit the required report;

On August 15, 2006, the Commission issued a complaint against the Respondent alleging the failure to file a Lobbying Activity Report for the period of December 20, 2005 through April 30, 2006;

The Respondent submitted the delinquent Lobbying Activity Report for the period December 20, 2005, through April 30, 2006 on September 14, 2006; and

The Respondent is voluntarily entering into this Stipulation of Settlement Agreement to admit his failure to timely file the Lobbying Activity Report for the period December 20, 2005, through April 30, 2006, with the Commission and to pay a sum of money in lieu of potential late filing fees pursuant to State Government Article, Section 14-405 of the Public Ethics Law;

IN CONSIDERATION of the September 14, 2006 submission of the required Lobbying Activity Report by the Respondent, and the stipulations recited above, the Respondent and the Executive director on behalf of Staff Counsel agree as follows:

1. Respondent admits that he did not timely file his Lobbying Activity Report on behalf of the employer for the period December 20, 2005, through April 30, 2006 as required by State Government Article, Section 15-704(a)(ii) of the Ethics Law;

2. Respondent subsequently filed the required Lobbying Activity Report with the Commission on September 14, 2006 (a copy of which has been attached hereto and made a part hereof);

3. Respondent understands that failure to comply with the lobbying disclosure provisions of the Public Ethics Law can subject him to a formal complaint by the Commission and upon a finding of a violation the possibility of late fees, civil fines, reprimand or a suspension of his ability to lobby for compensation;

4. Based on the facts stated in this Stipulation of Settlement, the Respondent agrees to pay as settlement of the complaint, the amount of two hundred fifty dollars ($250.00) in lieu of potential late fees and other fines for the admitted late filing of the Lobbying Activity Report.

5. Respondent waives a formal hearing on this matter and agrees that acceptance of the Stipulation of Settlement by the Commission would constitute, based on his admission of violations of the Public Ethics Law, a final action and finding of violation by the Commission, and, pursuant to § 15-407 of the Public Ethics Law, this Agreement and materials relating to this matter are not subject to the confidentiality provisions of the Public Ethics Law and will be public information unless otherwise protected;

6. Executive Director on behalf of Staff Counsel will, upon execution of this Agreement by the Respondent, recommend that the Commission suspend further complaint proceedings against the Respondent and recommend further that the Commission issue a Final Order in accordance with the terms of this Agreement;

7. Respondent accepts that the Commission, pursuant to Section 15-405(c)(2) of the Ethics Law, will issue a reprimand to him effective the date of the Final Order. The reprimand, this agreement, including any documents incorporated herein, and the Final Order will be transmitted to his employer;

8. Respondent and the Executive Director on behalf of Staff Counsel have entered into this Agreement for the sole purpose of resolving the late submission of the Lobbying Activity Report, for the payment in lieu of late fees, and to resolve the complaint now pending, and for no other purpose.

IN WITNESS WHEREFORE, Quincey Gamble, Respondent and Suzanne S. Fox, Executive Director acting on behalf of Staff Counsel for the State Ethics Commission, have signed below.

_____________/s/____________________ __________/s/__________________

Suzanne S. Fox, Executive Director Quincey Gamble

On behalf of Staff Counsel Lobbyist for:

State Ethics Commission SEIU United Health Care Workers

45 Calvert Street, Third Floor East – MD/DC Division

Annapolis, Maryland 21401

(410) 260-7770

---------------

State of Maryland,

County of: _______________________, to wit:

Before me, the undersigned, a Notary Public in and for the State and County aforesaid, personally appeared Suzanne S. Fox, Executive Director of the State Ethics Commission, who made oath on this day of ________________, 2006 in due form of law that she executed this agreement for the purposes set forth herein.

_____________________________

Notary Public

My Commission Expires: _____________________

---------------

State of ____________

County of ____________, to wit:

Before me, the undersigned, a Notary Public in and for the State and County aforesaid, personally appeared Quincey Gamble, who made oath on this __________the day of _______________, 2006 in due form of law that matters and facts hereinabove set forth are true to the best of his knowledge, information and belief, and are his voluntary act and that he executed this document for the purposes set forth herein.

___________________________

Notary Public

My Commission expires: ______________________

Accepted by the Commission

___________/s/_________________

Julian L. Lapides, Chairperson

for the Commission

Date: September 21, 2006

IN THE MATTER OF:

STIPULATION OF SETTLEMENT AGREEMENT