]uly 19, 2018

Mayor Bill Barnett
City of Naples
Naples, FL 34102

Dear Mayor Barnett:

I am writing in response to your letter ofjune 20, 2018, regarding my appearance
before City Council on May 2, 2018, on behalf of Ethics Naples.

You state that I may have violated the City of Naples Code of Ethics Law by
appearing before City Council on this date. You base your allegation on the fact that
I serve as an appointed member ofthe Community Redevelopment Agency Advisory
Board and that such advisory board members are restricted from
representing another group or business before City Council.

Frankly, I was more than a little stunned and surprised by your letter and its
allegations. Let me explain why.

First, Ethics Naples and ?its representatives" were invited on March 27 by City
Manager Moss at your behest to appear before City Council at its April 16 workshop
session to discuss the ethics petition. As Executive Director of Ethics Naples, 1 am
the chief representative of our organization, and as the invitation did not state that I
would not be welcome, it was reasonable for me to assume that was included.

As you know, Ethics Naples ultimately decided to decline this invitation, but as
advised by counsel subsequently met on a one?on?one basis with individual
members of City Council to allow free conversation. Representatives of Ethics
Naples [including myself] met with all but one City Council member in the period
between April 16 and May 2. In each of these meetings, I clearly indicated that I
would be appearing before City Council on May 2 to present our views.

At no time during this period, did you, City Attorney Pritt, or any member of Council
indicate any concern with my providing public comment in this regard. Nor did you,
City Attorney Pritt, or other members of Council raise this concern at the May 2
meeting itselfwhen I provided a three-minute public comment. In fact, members of
Council asked me clarifying questions following my comment

Most fair and impartial observers would find it unusual and concerning to invite
someone to meet with them and then attempt to penalize him when he does so.

Second, our View is that there is in fact no prohibited con?ict of interest under the
City Ethics Law between my representation of Ethics Naples and my service on the
CRAAB. Section 2-973 of the code states?

?When the regulatory power over the business entity resides in another
governmental agency, or when the regulatory power that the Council exer-
cises over the business entity or agency is strictly through the enactment

of laws or ordinances, then employment or a contractual relationship with
such business entity by a public officer or employee ofa legislative body shall
not be prohibited by this subsection or be deemed a conflict.?

1 note that regulatory authority over Ethics Naples as a Political Action Committee
resides fundamentally with the State of Florida, the Collier County Supervisor of
Elections, and the Federal Election Commission, not the City of Naples. Further, the
City's regulatory power over Ethics Naples is through enactment ofordinance, such
as voting to place our validated petition on the ballot.

Bill, I am saddened that the Ethics Naples petition which you had reviewed by City
Attorney Pritt and deemed worthy ofyour enthusiastic support last fall has
become, even though not one word has changed, something you find necessary to
attack so vigorously, including these current reckless allegations regarding my
appearance before Council that you yourself in effect facilitated.

We continue to have a deep disagreement about the need for a new and better
ethics code for the City of Naples and about the proper legal process for giving our
citizens the right to vote on this amendment. In the final analysis, these matters will
be determined by the courts oflaw and public opinion. It would be far better to let
these processes play out as they should than to continue to try to in?uence them in a
way that will ultimately prove to be an embarrassment for you and the government
you lead. Your legacy should be better than that.

Sincerely,

Re?t:

Raymond Christman

267 6th Street North
Naples, FL 34102

CC: Members of Naples City Council