December 2, 2014

Richard Briffault, Chair

Mark Davies, Executive Director
Conflicts of Interest Board
2 Lafayette Street, Suite 1010
New York, NY 10007
Dear Messrs. Briffault and Davies:
On behalf of Citizens Union, I write to ask the Conflicts of Interest Board (the Board) to investigate
whether a meeting at P.S. 66 in Brooklyn on July 14, 2014, sponsored by Local 1182 of the
Communications Workers of America (CWA) and attended by Mayor Bill de Blasio, violated the
conflicts of interest provisions of the New York City Charter.
The meeting, which was planned by the Mayors Office and the CWA, was scheduled to coincide with
the end of a Cablevision work shift. At the time, CWA and Cablevision were engaged in a labor dispute
and the site of the meeting, P.S. 66, is near a Cablevision garage where CWA members and prospective
members work.1
On November 25, 2014, the Commissioner of the New York City Department of Investigation (DOI) and
the Special Commissioner of Investigation (SCI) for the New York City School District issued a report
(the Report) into allegations that the meeting excluded members of the press, in violation of state
education law and New York City Department of Education (DOE) regulations. The investigation found
that the Mayors Office and DOE failed to follow rules requiring that the meeting be open to the public
and the press, and rules requiring that flyers announcing the event state that DOE did not sponsor or
endorse the event.2 DOI and SCI found that there did not appear to be an intent to violate the rules but
that the Mayors Office and DOE both needed more effective systems of communication.
In addition, DOI and SCI noted that conduct described in the Report may have violated the conflicts of
interest provisions of the New York City Charter.3 Investigators were not able to determine whether the
meeting was a political activity because they did not have a record of what the mayor and other
participants actually said at the meeting. SCI requested recordings, transcripts or written accounts of
the meeting from the Mayors Office but did not receive any.4

Report dated November 25, 2014, by the New York City Department of Investigation & Special Commissioner of
Investigation for the New York School District, available at
http://www.nyc.gov/html/doi/html/doireports/public.shtml and http://www.nycsci.org
2
Id. at 2
3
Id. at 12
4
Id. at 3.
Citizens Union 299 Broadway, Suite 700 New York, NY 10007
phone 212-227-0342 fax 212-227-0345 citizens@citizensunion.org www.citizensunion.org
Peter J.W. Sherwin, Chair Dick Dadey, Executive Director

Citizens Union
COIB Letter

Page 2
December 1, 2014

Citizens Union, as a good government watchdog organization, is concerned about the conduct described
in the Report and believes the matter warrants investigation by the Board. Several aspects of the event
at P.S. 66 taken together the absence of a record of the meeting, the exclusion of the press, the
possibility that the event was a political activity raise questions about whether the parties violated the
conflicts of interest prohibitions in NYC Charter 2604, even though a mayoral spokesperson called the
mistakes inadvertent. The fact that the commissioners of DOI and SCI have noted the possibility of a
violation of the conflicts of interest rules underscores the need for the Boards review.
The Board is best equipped to determine whether the parties misused city resources for a political
activity or violated the conflicts of interest rules in any other way, and therefore Citizens Union requests
that the Board undertake an investigation and report its findings. It is important that New Yorkers who
want a transparent and accountable city government know that our public officials are faithfully
following the laws of New York and the rules that guide their implementation.
Citizens Union appreciates the Boards attention to this matter. Should you need further information,
please contact me at 212-227-0342, ext. 11.
Regards,

Dick Dadey
Executive Director