In the Matter of Randolph Wills

IN THE MATTER OF RANDOLPH WILLS COIB Case No. 95-45 June 22, 1998

SUMMARY: The Board also fined a Deputy Commissioner of the City Human Rights Commission $1,500 for subleasing an apartment from a subordinate attorney and for using City equipment in the private practice of law.

STIPULATION AND DISPOSITION

Respondent Randolph Wills states the following:

1. I am currently employed as a Deputy Commissioner at the City Commission on Human Rights ("CCHR"). I previously served as a Managing Attorney in the Law Enforcement Bureau of CCHR.

2. From July 1992 to July 1996, I subleased an apartment belonging to Nancy Alisberg, a staff attorney at CCHR whom I supervised. In doing so, I admit that I entered into a financial relationship with a subordinate employee with whom I worked.

3. I conducted the private practice of law while employed as a Managing Attorney at CCHR.

4. I admit that during the end of 1993 to the beginning of 1994, I used City equipment to conduct my private legal practice. I drafted wills for two private clients for which I received monetary compensation. I also admit that I conducted a training seminar for the Queens County Bar Association for which I received further monetary compensation, and drafted an employment policy manual, pro bono, for my former employer, Queens Legal Services.

5. I admit that my using City equipment for my private legal work and entering into a financial relationship with a subordinate employee constituted conflicts of interest that allowed me to take advantage of my City position and placed undue pressure on the professional relationship between my subordinates and myself. I understand and admit that I thereby violated New York City Charter §§ 2604(b)(2), (b)(3) and (b)(14), which state:

“No public servant shall engage in any business, transaction or private employment, or have any financial or other private interest, direct or indirect, which is in conflict with the proper discharge of his or her official duties. [Section 2604(b)(2).]”

“No public servant shall use or attempt to use his or her position as a public servant to obtain any financial gain, contract, license, privilege or other private or personal advantage, direct or indirect, for the public servant or any person or firm associated with the public servant. [Section 2604(b)(3).]”

“No public servant shall enter into any business or financial relationship with another public servant who is a superior or subordinate of such public servant. [Section 2604(b)(14).]”

6. In recognition of the foregoing, I agree to pay to the New York City Conflicts of Interest Board a fine of $1,500, of which $750 shall be paid upon signature of this Disposition. The balance shall be due and payable two weeks thereafter. I understand that the amount of the fine reflects the fact that when I engaged in the private practice of law, CCHR did not have the formal or written policy now in effect regarding outside legal practice by its attorneys. I acknowledge that Chapter 68 of the City Charter prohibits me from using City equipment to conduct my private work.

I agree that this statement is a public and final resolution of the charges against me. Furthermore, I agree to provide a copy of this Disposition to any City agency where I might apply for employment prior to accepting employment with the City.

Randolph Wills Dated: June 1, 1998

The New York City Conflicts of Interest Board accepts this Disposition and the terms contained therein as a final disposition of the above-captioned matter, and, accordingly hereby dismisses the above-captioned case.

The New York City Conflicts of Interest Board

Benito Romano Acting Chair Dated: June 22, 1998