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STATE OF LOUISIANA <br /> °F 71.6"---. DEPARTMENT OF STATE CIVIL SERVICE <br /> oi ; , �'71 LOUISIANA BOARD OF ETHICS <br /> P.O.BOX 4368 <br /> • ' „L BATON ROUGE,LA 70821 <br /> , (225)219-5600 <br /> ".,,,''""°', FAX:(225)381-7271 <br /> 1-800-842-6630 <br /> www.ethics.state.ta.us <br /> April 29, 2014 <br /> Clayton E. Lovell <br /> P.O. Box 3017 <br /> Houma, Louisiana 70361 <br /> Re: Board Docket No. 2014-182 <br /> Dear Mr. Lovell: <br /> The Louisiana Board of Ethics, at its April 25, 2014 meeting, considered your request for an <br /> advisory opinion regarding whether W.L.Gaiennie Company(hereinafter as"WLGC")can enter into <br /> a contract for public relations work with Terrebonne Parish School Board. Charles Gaiennie is the <br /> husband of Oaklawn Junior High School teacher Elisabeth G. Gaiennie. You stated that Charles <br /> Gaiennie owns ninety percent (90%) of WLGC. You stated in email that the public relations work <br /> would include organizing and distributing information on the activities of students and of the school <br /> district for parents and the community at large. <br /> The Board concluded and instructed me to inform you that the Code of Governmental Ethics(Code <br /> of Ethics) would not prohibit W.L. Gaiennie Company from entering into a contract for public <br /> relations work with Terrebonne Parish School Board.Section 11 13A(I)(a)prohibits a public servant <br /> or member of such a public servant's immediate family,or legal entity in which he has a controlling <br /> interest from bidding on or entering into any contract, subcontract,or other transaction that is under <br /> the supervision or jurisdiction of the agency of such public servant. Elisabeth Gaiennie's agency is <br /> Oaklawn Junior High. Assuming WLGC is not attempting to contract with Oaklawn Junior High <br /> School, but rather WLGC would be contracting with the Terrebonne Parish School Board, this <br /> contract would not be prohibited. <br /> However, the Board concluded and instructed me to inform you that WLGC would be prohibited <br /> from performing public relations work that includes Oaklawn Junior High School. The Code of <br /> Ethics defines a "controlling interest" in Section 1102(8) as any ownership in any legal entity or <br /> beneficial interest in trust, held by or on behalf of an individual or a member of his immediate <br /> family, either individually or collectively, which exceeds twenty-five percent of that legal entity. <br /> Charles Gaiennie's ninety percent ownership is considered a controlling interest held by an <br /> immediate family member. <br /> A transaction involving the governmental entity is defined by the Code of Ethics Section <br /> 1102(23)(c) as: <br /> Any proceeding,application,submission,request for a ruling or other determination, <br /> contract, claim, case or other such particular matter which the public servant or <br /> AN EQUAL OPPORTUNITY EMPLOYER <br />