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Provide a statement of the facts upon which your complaint is based. Describe the events in
the order in which they occurred. Keep dates of events in sequence. Include full names,
addresses, and phone numbers of all individuals involved, including any witnesses present
when the alleged violations took place. Be factual; the information you provide in this statement
must be based on facts and not on personal conjecture. Try to answer the questions who,
what, where, and when. Attach extra sheets if more space is needed.
District 10 Park and Recreation Board Representative Robb Stewart is a partner at the law firm
Locke Lord LLC.
R. Nathan Crow, an attorney with Locke Lord LLC confirmed yesterday that he is providing Walt
Humanns Fair Park Texas Foundation (FPTF) with pro bono legal assistance by consulting on
the Agreement between the Foundation and the City.
The FPTF Agreement is to be voted upon at the Dallas Parks and Recreation Board at the
August 4, 2016 Park and Recreation Board meeting.
As Mr. Stewarts firm Locke Lord LLC is representing Walt Humann and the Fair Park Texas
Foundation, allowing Mr. Stewart to vote for the Fair Park Texas Foundation proposal would be
grossly inappropriate and demonstrably unethical.
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SEC. 12A-6. CONFIDENTIAL INFORMATION - The private interests of the Fair Park Texas
Foundation are being represented by Locke Lord LLC. Mr. Stewart is a partner at Locke Lord
LLC. As partnership in a law firm is the equivalent of being in management and/or having
ownership, anyone in a partner position at Locke Lord LLC and serving on the Park Board
would be in a position to glean confidential information from the both the City of Dallas and the
Fair Park Texas Foundation. Having one law firm representing both the city and the private
interest in an agreement of this scope is shocking and likely warrants a more thorough
investigation.
SEC. 12A-7. REPRESENTATION OF PRIVATE INTERESTS - The private interests of the
Fair Park Texas Foundation are being represented by Mr. Stewarts law firm Locke Lord LLC.
The FPTF contract is worth over $500,000,000. and should only be voted upon by those whose
firms that do not represent the private interests of Walt Humann or the FPTF. While Locke Lord
LLCs R. Nathan Crow is representing Mr. Humann, Mr. Stewart is a partner in the firm.
Partnership in a law firm is the equivalent of being in management an/or having ownership. R.
Nathan Crow of Locke Lord LLC attended the 7/21/2016 Park and Recreation Board Special
Meeting as advisor to the Fair Park Texas Foundation and Walt Humann. While Mr. Crow made
clear his work his legal work on behalf of the FPTX is pro bono, the Agreement involves
hundreds of millions of dollars to be received by the private interests of the Fair Park Texas
Foundation. Locke Lord LLCs Partner Robb Stewart is serving on the Dallas Parks and
Recreation Board and in that position he could benefit/represent/advance Locke Lord LLCs
client if he is not recused from voting on this matter.
SEC. 12A-8. CONFLICTING OUTSIDE EMPLOYMENT, SEC. 12A-12. PROHIBITED
INTERESTS IN CONTRACTS Locke Lord LLC attorneys represent both Walt Humanns
Fair Park Texas Foundation and, as a Park and Recreation Board Representative, the City of
Dallas negotiating an Agreement that has a 25-year term over which some $500,000,000. of tax
payer dollars will be given over to a private interest for management fees. Most certainly the
contract could have been modified to safeguard the citys irreplaceable Art Deco assets in Fair
Park. Many provisions in the contract said that the FPTF may perform a requirement, rather
than will perform a requirement. Despite Mr. Stewarts extensive legal training and success in
his field, he offered not one suggestion to modify the contract or tighten up the language on
behalf of the City of Dallas unless first requested by another Park Board and Recreation Board
Representative. Unfortunately, to have modified the contract on behalf of the citys park interests
he was to protect, Mr. Stewart would have been in the unenviable position of conflicting with his
Outside Employment, as his firm is actively representing the Fair Park Texas Foundation. How
the firm of Locke Lord LLC allowed this conflict is baffling, but the city should find that there is
a conflict or sufficient appearance of a conflict and that Robb Stewart D-10 Park and Recreation
Board Re should be recused from voting on the Fair Park Texas Foundation Contract.
City of Dallas
City Secretarys Office
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Locke Lord LLCs website confirms the employment of both Dallas D-10 Park and Recreation
Board Representative Robb Stewart and the Fair Park Texas Foundations legal counsel R.
Nathan Crow.
If the above photos of Walt Humann conferring with Locke Lord LLCs R. Nathan Crow are too
blurred, the citys recordings of the 7/21/2016 Special Meeting for the Park Board will show that
Mr. Walt Humann attended the meeting with R. Nathan Crow.
After the meeting was adjourned, I introduced myself and met Nathan Crow an attorney with
Locke Lord who told me that he was working pro bono for the Foundation. I asked him if that
was the same law firm where Robb Stewart works and Mr. Crow confirmed that D- 10 Park and
Recreation Board Representative Mr. Robb Stewart also works at Locke Lord LLC. I swear and
affirm this is true.
City of Dallas
City Secretarys Office
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City of Dallas
City Secretarys Office
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I CERTIFY THAT I HAVE READ THIS COMPLAINT, I FULLY UNDERSTAND ITS CONTENTS,
AND I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATE OF
TEXAS THAT THE COMPLAINT STATES A VIOLATION OF CHAPTER 12A OF THE DALLAS
CITY CODE, THAT THIS COMPLAINT IS NOT BEING PRESENTED FOR ANY IMPROPER
PURPOSE, AND THE FOREGOING STATEMENTS AND EVIDENCE ARE TRUE AND
CORRECT OR, TO THE BEST OF MY KNOWLEDGE, ARE SUPPORTED BY CREDIBLE
EVIDENCE FORMED AFTER AN INQUIRY REASONABLE UNDER THE CIRCUMSTANCES.
I UNDERSTAND THAT A COPY OF THIS COMPLAINT WILL BE SENT TO THE CHAIR OF
THE ETHICS ADVISORY COMMISSION AND TO THE INDIVIDUAL CHARGED IN THIS
COMPLAINT. ALL PAPERS AND COMMUNICATIONS RELATING TO A COMPLAINT MUST
BE TREATED AS CONFIDENTIAL LAW UNLESS REQUIRED TO BE MADE PUBLIC BY THE
PUBLIC INFORMATION ACT (CHAPTER 552, TEXAS GOVERNMENT CODE) OR OTHER
APPLICABLE LAW.
_____________________________________
Signature
Before me the undersigned authority, on the _____ day of ___________, 20__, personally
appeared, ______________________________, known to me to be the person whose name is
subscribed hereto, and being duly sworn stated that such facts are true and correct, or, to the
best of his/her knowledge, formed after an inquiry reasonable under the circumstances, the
factual contentions are supported by credible evidence submitted in and with the complaint.
_____________________________________
Notary Public
<NOTARY SEAL>
_________________________
County, Texas
My Commission expires:
_____________________________________
Special Note: Section 3.2 of the Ethics Advisory Commission Rules of Procedure states that
supplements to a complaint may only be filed within seven days after the city secretarys
acceptance of the original completed complaint.
Should you have any questions concerning this form, please contact the City Secretarys Office,
at (214) 670-3738 during regular business hours (8:15am 5:15pm).
Upon completing ALL sections of this form, please hand deliver or send by certified mail with
any attachments to:
Office of the City Secretary
CITY HALL
1500 Marilla Avenue Suite 5DS
Dallas, TX 75201
City of Dallas
City Secretarys Office
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City of Dallas
City Secretarys Office
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