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CITY OF BOARD OF ETHICS

Contact: J. Shane Creamer, Jr., Executive Director, 215-686-9450 For Immediate Release: September 17, 2015

PHILADELPHIA – On September 16, 2015, the Board of Ethics approved four settlement agreements. The agreements are listed below by category of violation. Copies of the approved agreements are attached.

Political Activity Cameron Kline: Resolving three violations of the Philadelphia Home Rule Charter’s political activity restrictions.

Single Committee Rule, Material Omissions in a Campaign Finance Report, and Late Filing of Campaign Finance Reports Friends of Ori Feibush and Ori Feibush: Resolving violations of the City's Campaign Finance Law for using more than one checking account to make expenditures supporting Mr. Feibush's candidacy for City office, making material omissions from 24 hour reports filed with the Board, and late filing campaign finance reports with the Board.

Late Filing of Campaign Finance Reports

Friends of Tomas Sanchez and Committee to Elect Anthony Clark: Resolving violations of the City’s Campaign Finance Law for the late filing of campaign finance reports with the Board.

The Philadelphia Board of Ethics is a five-member independent board established by ordinance, approved by Philadelphia voters in May 2006, and installed on November 27, 2006. It is charged with administering, enforcing, and interpreting the City’s campaign finance law, lobbying law, political activity restrictions, and standards of conduct and ethics laws. ###

SETTLEMENT AGREEMENT

This Settlement Agreement (“Agreement”) is made and entered into by the Board of Ethics of the City of Philadelphia, J. Shane Creamer Jr., the Executive Director of the Board, and Cameron Kline, jointly referred to as “the Parties.”

RECITALS

A. The Board of Ethics of the City of Philadelphia is a five-member, independent board established by ordinance, approved by Philadelphia voters in May 2006, and installed on November 27, 2006. Pursuant to section 4-1100 of the Home Rule Charter, the Board is charged with, among other things, enforcing the section of the Philadelphia Home Rule Charter that prohibits City officers and employees from being concerned in the collection, receipt, or solicitation of contributions intended for a political purpose. B. Cameron Kline is the Communications Director and Spokesperson at the Philadelphia District Attorney's Office. He has been an employee of the City of Philadelphia since February of 2015. C. Section 10-107(4) of the Philadelphia Home Rule Charter provides that a City employee may not engage in certain types of political activity. The political activity restrictions in the Home Rule Charter ensure that government operates effectively and fairly and that employees are free from improper influences and perform their duties without bias or favoritism for or against any political party, candidate, or partisan political group. D. Ethics Board Regulation No. 8, which became effective March 28, 2011, provides a detailed interpretation of Charter Subsection 10-107(4). E. Pursuant to Regulation No. 8, Paragraph 8.1(n), political activity is an activity directed toward the success or failure of a political party, candidate, or partisan political group. F. Pursuant to Regulation No. 8, Paragraph 8.1(l), a partisan political group is any committee, club, or other organization that is affiliated with a political party or candidate or whose primary purpose is to engage in political activity. G. Pursuant to Regulation No. 8, Paragraph 8.10, an appointed officer or employee shall not be an officer of a partisan political group. H. Pursuant to Regulation No. 8, Paragraph 8.11, an appointed officer or employee shall not take any part in the management or affairs of any political party, political campaign or partisan political group, which includes any political activity that is performed in concert or coordination with a political party, candidate, or partisan political group. I. Pursuant to Philadelphia Code Section 20-606(1)(h), if the Board finds a violation of Section 10-107(4) of the Home Rule Charter, it may impose a civil monetary penalty of $300. J. On August 27, 2015, Board enforcement staff received a complaint about Mr. Kline that alleged that he had violated the Home Rule Charter’s political activity restrictions as a result of his activities with the Liberty City LGBT Democratic Club. Because the complaint stated potential violations of the Charter, enforcement staff accepted the complaint and opened an investigation. K. In 2013, Mr. Kline became a board member of the Liberty City LGBT Democratic Club. In February of 2015, when Mr. Kline took his current position with the City, he disclosed to his superiors that he was a member of the organization’s board. L. Liberty City LGBT Democratic Club was founded in 1994 by activists who wanted to build political power for the Lesbian, Gay, Bisexual and Transgender (LGBT) community through involvement within the Democratic Party. The primary objectives of the organization are to: 1. Register, educate and mobilize LGBT voters. 2. Elect openly LGBT candidates for public and party office. 3. Support LGBT-friendly candidates and work to oust anti-gay office holders. 4. Promote legislative issues of importance to the LGBT community. 5. Provide a forum for LGBT voters to meet candidates and officeholders. M. For the purposes of Board Regulation No. 8, Liberty City LGBT Democratic Club is a partisan political group. By serving as a board member of the organization, Mr. Kline was an officer of a partisan political group. N. Liberty City LGBT Democratic Club endorsed numerous candidates in the May 2015 Democratic primary election. Mr. Kline did not serve on the endorsement committee and did not participate in the vote by members of the organization on which candidates to endorse. However, Mr. Kline helped prepare a press release announcing the endorsements. Mr. Kline was listed as a contact on the press release, a copy of which is attached hereto as Exhibit A. O. On August 25, 2015, a representative from Jim Kenney’s mayoral committee emailed the co- chair of the board of Liberty City LGBT Democratic Club and asked if the organization would be willing to issue a statement about online comments made by the largest contributor to the Republican nominee for Mayor. The Kenney campaign provided the text of the proposed statement, a list of reporters’ email addresses, and screenshots of Facebook posts made by the contributor. P. On August 26, 2015, at the request of the co-chairs of the organization’s board, Mr. Kline sent the email attached hereto as Exhibit B to the list of reporters provided by the Kenney campaign. Q. The screenshots the Kenney campaign provided were included as attachments to the email. Mr. Kline did not help draft the statement and did not participate in discussions with the Kenney campaign about it. He sent the email from his personal computer at his home using a gmail account.

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R. On August 28, 2015, Mr. Kline contacted Board enforcement staff to discuss how to best address his political activity violations. At all times, Mr. Kline fully cooperated with the Board’s investigation and promptly took all steps necessary to resolve the violations described in the Agreement. S. On August 28, 2015, after becoming aware that being an officer of Liberty City LGBT Democratic Club violated Charter Subsection 10-107(4), Mr. Kline resigned from the organization’s board. T. The Parties desire to enter into this Agreement in order to resolve the matters described herein.

AGREEMENT

The Parties agree that:

1. By serving as an officer of a partisan political group, Mr. Kline violated Section 10-107(4) of the Philadelphia Home Rule Charter. The civil monetary penalty for this violation is $300. However, because Mr. Kline disclosed his membership on the board of Liberty City LGBT Democratic Club to his superiors when he was hired by the City and promptly resigned from the board after becoming aware that being a board member violated of Charter Subsection 10-107(4), the Board waives the monetary penalty for this violation. 2. By creating a press release announcing Liberty City LGBT Democratic Club’s endorsements for the May 2015 Democratic primary and serving as a press contact for that release, Mr. Kline violated Section 10-107(4) of the Home Rule Charter. The civil monetary penalty for this violation is $300. 3. By emailing to reporters a statement by Liberty City LGBT Democratic Club about the Republican nominee for Mayor, Mr. Kline violated Section 10-107(4) of the Home Rule Charter. The civil monetary penalty for this violation is $300. 4. Mr. Kline shall pay the aggregate civil penalty of $600 within two weeks of the effective date of the Agreement. Payment shall be by check or money order made payable to the City of Philadelphia and delivered to the offices of the Board of Ethics. 5. Within six months of the effective date of the Agreement, Mr. Kline shall attend ethics training at the offices of the Board. 6. So long as he is a City employee, Mr. Kline shall not: a) collect, receive, or solicit contributions for Liberty City LGBT Democratic Club, b) participate in get-out-the-vote efforts organized or sponsored by the organization, or c) engage in any political activity in coordination with the organization. 7. Mr. Kline releases and holds harmless the Board and its staff from any potential claims, liabilities, and causes of action arising from the Board’s investigation, enforcement, and settlement of the matters described in the Agreement.

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EXHIBIT A

CONTACT: Cameron Kline FOR IMMEDIATE RELEASE 215-435-1262 [email protected]

Mason Lane 717-382-8542 [email protected]

LIBERTY CITY LGBT DEMOCRATIC CLUB ENDORSES JIM KENNY FOR MAYOR AND A FULL SLATE OF CANDIDATES FOR MAY 19TH PRIMARY ELECTION

PHILADELPHIA (April 16, 2015) – Liberty City Democratic Club (LCDC), ’s premiere lesbian, gay, bisexual and transgender (LGBT) political organization, today endorsed Philadelphia mayoral hopeful Jim Kenny at its annual primary endorsement meeting.

"Philadelphia is the most LGBT-friendly city in the nation and that is due in large part to the hard work and leadership of Jim Kenny. Liberty City members overwhelmingly voted to endorse Jim Kenny and look forward to hitting the streets, neighborhood by neighborhood, to elect Kenny Mayor of Philadelphia,” said Liberty City Co-chair Sara Jacobson.

Liberty City also endorsed the following candidates for Philadelphia City Council (District):

, Second District; and  Maria Quinones-Sanchez, Seventh District.

- more - Add 1

Liberty City also endorsed the following candidates for Philadelphia City Council (At Large):

 Blondell Reynolds Brown;  Sherrie Cohen;  ;  Bill Greenlee; and  Paul Stenke.

The LCDC also endorsed Lisa Deeley and Carol Jenkins for Philadelphia City Commissioner.

"We had a spirited and robust discussion on which candidates to endorse for such important elected positions – many of which will have a direct impact on the hundreds of thousands of LGBT Pennsylvanians across the Commonwealth. We will now begin to implement an aggressive GOTV operation on behalf of all our endorsed candidates,” said Liberty City Co-chair Tony Campisi.

For the judicial races, LCDC endorsed:

 Kevin Dougherty and Anne Lazarus for PA Supreme Court;  Alice Beck Dubow for PA Superior Court;  R. Todd Eagan for PA Commonwealth Court;  James Berardinelli, Abbe Fletman, Diane Grey, Anthony Kyriakakis, Chris Mallios, Brian Ortelere, Rainy Papademetriou, Kenneth Powell, Mia Roberts- Perez, Stephanie Sawyer, Kia Scott and Stella Tsai for the Court of Common Pleas of Philadelphia County;  Daniel Clifford for Court of Common Pleas of Montgomery County; and  Joffee Pittman and Dan Sulman Philadelphia Municipal Court.

Liberty City LGBT Democratic Club was founded in 1994 to build political power for the Lesbian, Gay, Bisexual, and Transgender (LGBT) community through involvement within the Democratic Party. Liberty City remains dedicated to registering, educating and mobilizing LGBT voters; electing open LGBT candidates for public and party office; supporting LGBT-friendly candidates and working to oust anti-gay office holders; promoting legislative issues of importance to the LGBT community; and providing a forum for LGBT voters to meet candidates and officeholders. For more information on Liberty City Democratic Club visit www.libertycity.org

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EXHIBIT B

SETTLEMENT AGREEMENT This Settlement Agreement (“Agreement”) is made and entered into between the Board of Ethics of the City of Philadelphia, J. Shane Creamer Jr., Executive Director of the City of Philadelphia Board of Ethics, Friends of Ori Feibush, and Ori Feibush, jointly referred to as “the Parties.” RECITALS A. The Board of Ethics of the City of Philadelphia is a five-member, independent board established by ordinance, approved by Philadelphia voters in May 2006, and installed on November 27, 2006. Pursuant to section 4-1100 of the Home Rule Charter, the Board is charged with, among other things, enforcing the City’s campaign finance law which is found at Chapter 20-1000 of the Philadelphia Code. B. The Friends of Ori Feibush is the authorized candidate political committee of Ori Feibush, who was a candidate for the Democratic nomination for Philadelphia City Council’s 2nd District seat in the 2015 May primary election. C. Jon Adler is the treasurer of Friends of Ori Feibush. D. Pursuant to Philadelphia Code § 20-1006(1)(a) and Regulation No. 1, Paragraph 1.19(b), candidates for City office and their political committees are required to electronically file campaign finance reports with the Board. E. Pursuant to the City’s Campaign Finance Law, from May 5 through May 19, 2015, within 24 hours of accepting a contribution of $500 or more, Friends of Ori Feibush was required to electronically file a campaign finance report with the Board disclosing that contribution.

F. During the 24 hour reporting period, the Friends of Ori Feibush filed several reports that omitted contributions that should have been included in them. The contributions that were omitted were: 1. $500 from Reuven Mosheyev on May 5, 2015; 2. $500 from Charles Bernier on May 6, 2015; 3. Two in-kind contributions of $5,000 from Ori Feibush on May 6, 2015; 4. In-kind contribution of $25,000 and $5,000 from Ori Feibush on May 8, 2015; and 5. An in-kind contribution of $12,000 from Ori Feibush on May 11, 2015. Friends of Ori Feibush filed amended reports correcting these omissions. G. Pursuant to Philadelphia Code § 20-1006(4) and Regulation No. 1, Paragraph 1.24, the making of a material omission in a report filed with the Board is a violation of the City’s Campaign Finance Law.

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H. In addition, Friends of Ori Feibush failed to file four required 24 hour reports with the Board. The committee self-reported the reporting failure and subsequently filed all of the required reports.

I. Pursuant to Philadelphia Code § 20-1003 and Regulation No. 1, Paragraph 1.25, candidates for City office shall have no more than one checking account for the City office being sought, into which all contributions and post-candidacy contributions for such office shall be made, and out of which all expenditures for that office shall be made, including post-candidacy expenditures. J. On May 8, 2015 and June 18, 2015, Mr. Feibush filed Cycle 2 and Cycle 3 campaign finance reports with the Board disclosing that Mr. Feibush made numerous, significant, campaign-related expenditures from his personal account. The expenditures are listed in Exhibit A attached hereto. K. Mr. Feibush did not accept or deposit any campaign contributions into his personal accounts. All contributions to the Feibush campaign were deposited into the Friends of Ori Feibush’s checking account. L. Pursuant to Philadelphia Code § 20-1008 and Regulation No. 1, Paragraph 1.55, the penalty for a violation of Philadelphia Code §§ 20-1003 and 1006(4) is $1,000, which can be increased to $2,000 if aggravating factors are present and decreased to $250 if mitigating factors are present. M. At all times, Friends of Ori Feibush, Ori Feibush, and Jon Adler fully cooperated with the Board’s investigation and resolution of the matters described in this Agreement. N. The Parties desire to enter into this Agreement in order to resolve the issues described herein.

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AGREEMENT The Parties agree that: 1. By making material omissions from several of the 24 hour reports it filed with the Board, Friends of Ori Feibush violated Philadelphia Code § 20-1006(4), and is subject to a civil monetary penalty of $1,000. 2. Friends of Ori Feibush’s late filing of four 24 hour reports with the Board violated Philadelphia Code § 20-1006(1) and is subject to a civil monetary of $2,000. 3. Ori Feibush’s use of more than one account to make campaign expenditures violated Philadelphia Code Section 20-1003 and is subject to a civil penalty of $1,000. 4. Ori Feibush shall pay the aggregate civil monetary penalty of $4,000 within 14 days of the effective date of the Agreement. Payment shall be by check made payable to the City of Philadelphia and delivered to the offices of the Board. 5. Mr. Feibush and Friends of Ori Feibush release and hold harmless the Board and its staff from any potential claims, liabilities, and causes of action arising from the Board’s investigation, enforcement, and settlement of the matters described in this Agreement.

6. In consideration of the above and in exchange for Mr. Feibush’s and Friends of Ori Feibush’s compliance with all of the terms of the Agreement, the Board waives any further penalties or fines against them for the violations described in this Agreement. 7. The Parties will not make any public statements that are inconsistent with the terms of the Agreement. 8. If the Board or the City is forced to seek judicial enforcement of this Agreement, and prevails, Mr. Feibush and Friends of Ori Feibush shall be liable for attorneys’ fees and costs reasonably expended in enforcing compliance with the Agreement. Fees for time spent by Board or City attorneys shall be calculated based upon standard and customary billing rates in Philadelphia for attorneys with similar experience. 9. The Agreement contains the entire agreement between the Parties. 10. The Executive Director will submit a signed copy of the Agreement to the Board for approval. 11. The Agreement shall become effective upon approval by the Board. The effective date of the Agreement shall be the date the Board Chair signs the Agreement. 12. If the Board rejects the proposed Agreement, presentation to and consideration of the Agreement by the Board shall not preclude the Board or its staff from participating in, considering, or resolving an administrative adjudication of the matters described in the Agreement. If the Board rejects the proposed Agreement, nothing in the proposed Agreement shall be considered an admission by either party and, except for this paragraph, nothing in the Agreement shall be effective.

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Dated: __,-+-'--+----JL\ [,) J. Shane Creamer. Jr.

By Friends of Ori Fcibush: Dated: _f-'-{__.11{__.rS'----- ~

Dated: -

Approved by the Board of Ethics:

Dated: _1-+-{1~---1-l i_S _ ~~chae~.·R~ Chair

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EXHIBIT A Ori Feibush Campaign Related Expenses from Personal Account

Date Amount Expenditure 3/7/2015 $500.00 40th Ward Democratic Club event 4/23/2015 $100,000.00 I Slept on My Face Productions consulting 4/28/2015 $28,000.00 Bergmann Zwerdling mailers 5/1/2015 $20,000.00 Bergmann Zwerdling mailers 5/3/2015 $200.00 Democratic City Committee event 5/6/2015 $5,000.00 LJR Custom Strategies mdeia 5/6/2015 $5,000.00 I Slept on My Face Productions media 5/8/2015 $25,000.00 Bergmann Zwerdling media 5/8/2015 $5,000.00 I Slept on My Face Productions media 5/11/2015 $12,000.00 Bergmann Zwerdling media 5/13/2015 $25,000.00 Bergmann Zwerdling media 5/14/2015 $26,679.00 Bergmann Zwerdling media 5/14/2015 $5,000.00 I Slept on My Face Productions media SETTLEMENT AGREEMENT This Settlement Agreement (“Agreement”) is made and entered into by the Board of Ethics of the City of Philadelphia, J. Shane Creamer, Jr., the Executive Director of the Board, the Friends of Tomas Sanchez, and Steven Barrett, the treasurer of the Friends of Tomas Sanchez, jointly referred to as “the Parties.”

RECITALS A. The Board of Ethics of the City of Philadelphia is a five-member, independent board established by ordinance, approved by Philadelphia voters in May 2006, and installed on November 27, 2006. Pursuant to section 4-1100 of the Home Rule Charter, the Board is charged with, among other things, enforcing the City’s campaign finance law. B. The Friends of Tomas Sanchez is a political committee based in Philadelphia. The Friends of Tomas Sanchez has previously filed campaign finance reports with the Board.

C. Steven Barrett is the treasurer of the Friends of Tomas Sanchez. D. Pursuant to Philadelphia Code § 20-1006(1)(a) and Regulation No. 1 Paragraph 1.21(a): Any time a political committee or person is required to file a campaign finance report with the City Commissioners or the Secretary of State, as required by the Pennsylvania Election Code, the committee or person shall file electronically a copy of that report with the Board if the report filed with the City Commissioners or Secretary of State discloses, or should disclose, any expenditures made or debt incurred to influence the outcome of a covered election, including expenditures to a candidate for City elective office. E. Pursuant to Philadelphia Code §§ 20-1006(4) and 20-1301(2) and Regulation No. 1 Paragraph 1.54, late filing of a campaign finance report violates the City’s campaign finance law and is subject to a civil monetary penalty of $250 for each day the report is late with maximum total penalties of $2,000 for the first 30 days the report remains unfiled plus $1,000 for each additional 30 day period, or part thereof, the report remains unfiled. F. June 18, 2015 was the deadline for political committees to file a 30 day post-primary (cycle 3) campaign finance report. G. The Friends of Tomas Sanchez made a contribution to a candidate for City office during the 2015 cycle 3 reporting period. Therefore, the committee should have electronically filed a 2015 cycle 3 report with the Board by June 18, 2015. However, the committee failed to file a 2015 cycle 3 report by June 18, 2015 H. On June 24, 2015, Board enforcement staff notified the committee of its failure to file a 2015 cycle 3 report with the Board. The committee filed its 2015 cycle 3 report with the Board on July 3, 2015. I. The Parties desire to enter into this Agreement in order to resolve the issues described herein.

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AGREEMENT The Parties agree that: 1. The Friends of Tomas Sanchez’s late filing of its 2015 cycle 3 campaign finance report with the Board violated the City’s Campaign Finance Law and is subject to a civil monetary penalty of $2,000. However, the penalty is reduced to $1,500 in recognition of the committee’s cooperation and prompt resolution of this matter. 2. The Friends of Tomas Sanchez and Steven Barrett are jointly and severally liable for the civil monetary penalty which shall be paid on the following schedule: 2.1. $500 within 14 days of the effective date of the Agreement; 2.2. $500 within 60 days of the effective date of the Agreement; and 2.3. $500 within 90 days of the effective date of the Agreement. Payment shall be by check made payable to the City of Philadelphia and delivered to the offices of the Board. 3. The Friends of Tomas Sanchez and Steven Barrett release and hold harmless the Board and its staff from any potential claims, liabilities, and causes of action arising from the Board’s investigation, enforcement, and settlement of the matters described in the Agreement. 4. In consideration of the above and in exchange for the compliance of the Friends of Tomas Sanchez and Steven Barrett with all of the terms of the Agreement, the Board waives any further penalties or fines against them for the violations described in the Agreement. 5. The Parties will not make any public statements that are inconsistent with the terms of the Agreement. 6. If the Ethics Board is forced to seek judicial enforcement of the Agreement, and prevails, the Friends of Tomas Sanchez and Steven Barrett shall be liable for attorneys’ fees and costs reasonably expended in enforcing compliance with the Agreement. Fees for time spent by Board staff attorneys shall be calculated based upon standard and customary billing rates in Philadelphia for attorneys with similar experience.

7. The Agreement contains the entire agreement between the Parties. 8. The Executive Director will submit a signed copy of the Agreement to the Board for approval. The Agreement shall become effective upon approval by the Board. The effective date of the Agreement shall be the date the Board approves the Agreement. 9. If the Board rejects the proposed Agreement, presentation to and consideration of the Agreement by the Board shall not preclude the Board or its staff from participating in, considering, or resolving an administrative adjudication of the matters described in the Agreement. If the Board rejects the proposed Agreement, nothing in the proposed Agreement shall be considered an admission by either party and, except for this paragraph, nothing in the Agreement shall be effective.

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SETTLEMENT AGREEMENT Pursuant to Section 4-1100 of the Philadelphia Home Rule Charter, the Board of Ethics is responsible for enforcing the Philadelphia’s Campaign Finance Law, which is found at Chapter 20-1000 of the Philadelphia Code. 1. The Committee to Elect Anthony Clark is the authorized candidate political committee of the Hon. Anthony Clark, a City Commissioner and candidate for City Commissioner in the November 2015 Philadelphia general election. Commissioner Clark was a candidate in the May 2015 primary election. John Raimondi is the treasurer of Committee to Elect Anthony Clark. 2. Pursuant to the City’s Campaign Finance Law, from May 5 through May 19, 2015, within 24 hours of accepting any contributions of $500 or more, Committee to Elect Anthony Clark was required to electronically file a campaign finance report with the Board disclosing those contributions. 3. During the 24 hour reporting period, Committee to Elect Anthony Clark should have electronically filed a campaign finance report with the Board disclosing an $11,500 contribution it received on May 11, 2015, but failed to do so. The committee did disclose the contribution in the 2015 post-primary (Cycle 3) campaign finance report it filed with the Board. 4. The Committee to Elect Anthony Clark has fully cooperated with Board enforcement staff in the resolution of this mater. After being contacted by Board enforcement staff, Committee to Elect Anthony electronically filed with the Board its late 24 hour campaign finance report. 5. The Committee to Elect Anthony Clark’s late filing of a 24 hour report with the Board violated the City’s Campaign Finance Law, for which Mr. Raimondi and Committee to Elect Anthony Clark are jointly and severally liable for a civil monetary penalty of $1,500. 6. The civil monetary penalty of $1,500 shall be paid on the following schedule: 6.1 $500 within 14 days of the effective date of the Agreement; 6.2 $500 by October 31, 2015; and 6.3 $500 by November 30, 2015. Payment shall be by check made payable to the City of Philadelphia and delivered to the offices of the Board. 7. Mr. Raimondi and Committee to Elect Anthony Clark release and hold harmless the Board and its staff from any potential claims, liabilities, and causes of action arising from the Board’s investigation, enforcement, and settlement of the matters described in this Agreement. 8. In consideration of the above and in exchange for the compliance of Mr. Raimondi and Committee to Elect Anthony Clark with all of the terms of the Agreement, the Board waives any further penalties or fines against them for the violations described in this Agreement.

9. !fthe Board or the City is forced to seek judicial enforcement of this Agreement, and prevails, Mr. Raimondi and Committee to Elect Anthony Clark shall be liable for attorneys' fees and costs reasonably expended in enforcing compliance with the Agreement. Fees for time spent by Board or City attorneys shall be calculated based upon standard and customary billing rates in Philadelphia for attorneys with similar experience. 10. The Executive Director will submit a signed copy of the Agreement to the Board for approval. The Agreement shall become effective upon approval by the Board. The effective date of the Agreement shall be the date the Board Chair signs the Agreement. 11. If the Board rejects the proposed Agreement, presentation to and consideration of the Agreement by the Board shall not preclude the Board or its staff from participating in, considering, or resolving an administrative adjudication of the matters described in the Agreement. If the Board rejects the proposed Agreement, nothing in the proposed Agreement shall be considered an admission by either party and, except for this paragraph, nothing in the Agreement shall be effective. By the Executive Director of the·iJr~J-- Dated: --rl+-L--tl(~\ ::>_ J. Shane Creamer, Jr.

By Committee to Elect Anthony Clark:

Dated: __f~/_i.~l /_11!1_11_~_ John Raimondi, Treasurer

By John Raimondi:

Dated: du1~'

Approved by the Board of Ethics:

Dated: ----..j~<-+-(f~-t-( l_.S _ Michael H. Reed Chair