Logosm.gif (1927 bytes)
navlinks.gif (4688 bytes)
Hruler04.gif (5511 bytes)

Back to Dorothy Brizill’s main page Back to Mayor’s Office main page

Dorothy Brizill, DCWatch
Complaint to the Office of Campaign Finance on violations of the prohibition against a lobbyist giving a gift to an elected official, or an official receiving a gift
November 7, 2003




Dorothy Brizill
Bonnie Cain
Jim Dougherty
Gary Imhoff
Phil Mendelson
Mark David Richards
Sandra Seegars


DCWatch Archives
Council Period 12
Council Period 13
Council Period 14

Election 1998
Election 2000
Election 2002

Election 2004
Election 2006

Government and People
Anacostia Waterfront Corporation
Boards and Com
Campaign Finance
Chief Financial Officer
Chief Management Officer
City Council
Control Board
Corporation Counsel
DC Agenda
Elections and Ethics
Fire Department
FOI Officers
Inspector General
Housing and Community Dev.
Human Services
Mayor's Office
Mental Health
Motor Vehicles
Neighborhood Action
National Capital Revitalization Corp.
Planning and Econ. Dev.
Planning, Office of
Police Department
Property Management
Public Advocate
Public Libraries
Public Schools
Public Service Commission
Public Works
Regional Mobility Panel
Sports and Entertainment Com.
Taxi Commission
Telephone Directory
University of DC
Water and Sewer Administration
Youth Rehabilitation Services
Zoning Commission

Issues in DC Politics

Budget issues
DC Flag
DC General, PBC
Gun issues
Health issues
Housing initiatives
Mayor’s mansion
Public Benefit Corporation
Regional Mobility
Reservation 13
Tax Rev Comm
Term limits repeal
Voting rights, statehood
Williams’s Fundraising Scandals


Appleseed Center
Cardozo Shaw Neigh.Assoc.
Committee of 100
Fed of Citizens Assocs
League of Women Voters
Parents United
Shaw Coalition



What Is DCWatch?

themail archives

Supplement to complaint, November 11, 2003 OCF notice opening investigation, December 2, 2003 

1327 Girard Street, N.W., Washington, D.C. 20009-4915
202-234-6982, fax 202-232-1215

November 7, 2003

Ms. Cecily Collier-Montgomery
Office of Campaign Finance
2000 14th Street, NW
Washington, DC 20009

Dear Ms. Collier-Montgomery:

This letter is a formal complaint of a violation of District of Columbia laws and regulations regarding election campaigns, lobbying, and conflict of interest by Mayor Anthony Williams and attorney/lobbyist Vincent Mark Policy.


A political consultant to Mayor Anthony A. Williams, Thomas Lindenfeld, is currently suing Mayor Williams and Committee to Re-Elect Anthony "Tony" Williams (hereinafter "the Committee"), alleging that he had contracted to do work for Mayor Williams, both as an individual and as a candidate for office, and also for the Committee, and that Mayor Williams and the Committee have refused to pay debts that they owe him for his services (Superior Court of the District of Columbia, Case No. 02CA005119). In this suit, the Committee is being represented by Douglas J. Patton and the firm of Holland & Knight and Mayor Williams, as an individual, is being represented by Vincent Mark Policy, of the firm of Greenstein, DeLorme, and Luchs (see Attachment A).

To date, this case has required a significant number of hours of legal work that at normal rates would already have cost tens of thousands of dollars. Mr. Policy, however, by his own admission in a letter that he filed as a matter of public record in this case, is representing the Mayor at no charge and has endeavored to keep secret the fact that he is not charging a fee for his services (see Attachment B). Mr. Policy is registered as a lobbyist with the District of Columbia Office of Campaign Finance, and he represents the Apartment and Office Building Association (AOBA) and the Washington, DC, Association of Realtors, among others, on matters before the DC government (see Attachment C).


Mr. Policy's representation of Mr. Williams at no charge constitutes a prohibited and illegal contribution to an elected official, and it would do so even if he were to represent Mr. Williams at a reduced or discounted fee.

Relevant Sections of the Code and Regulations

DC Code §1-1105.01(5) The term "gift" means a payment, subscription, advance, forebearance, rendering, or deposit of money, services, or anything of value, unless consideration of equal or greater value is received, for the purpose of influencing the actions of a public official in making or influencing the making of an administrative decision or legislative action, and shall not include a political contribution otherwise reported as required by law, a commercially reasonable loan made in the ordinary course of business, or a gift received from a member of the person's household as defined by §1-1106.01(i)(4)

DC Code §1-1105.06(a) No registrant [as a lobbyist] or anyone acting on behalf of a registrant shall offer, give, or cause to be given a gift to an official in the legislative or executive branch or a member of his or her staff, that exceeds $100 in value in the aggregate in any calendar year. This section shall not be construed to restrict in any manner contributions authorized in §§1-1131.01 through 1-1131.02 and §1-1104.03.

DC Code §1-1106.01(c) No person shall offer or give to a public official or a member of a public official's household, and no public official shall solicit or receive anything of value, including a gift, favor, service, loan gratuity, discount, hospitality, political contribution, or promise of future employment, based on any understanding that such public official's actions or judgment or vote would be influenced thereby, or where it could reasonably be inferred that the thing of value would influence the public official in the discharge of his or her duties, or as a reward, except for political contributions publicly reported pursuant to §1-1102.06 and transactions made in the ordinary course of business of the person offering or giving the thing of value.

DC Code §1-1101.01(6)(B) Notwithstanding the foregoing, such term [campaign "contribution"] shall not be construed to include:

    (1) Services provided without compensation, by individuals (including accountants and attorneys) volunteering a portion or all of their time on behalf of a candidate or political committee.
U.S. Code Title 2, Chapter 14, Subchapter 1, §431(6)(viii)(II) [The term "contribution" does not include any legal or accounting services rendered to or on behalf of] an authorized committee of a candidate or any other political committee, if the person paying for such services is the regular employer of the individual rendering such services and if such services are solely for the purpose of ensuring compliance with this Act or chapter 95 chapter 95 or chapter 96 of title 26, but amount paid or incurred by the regular employer for such legal or accounting services shall be reported in accordance with section 434(b) of this title by the committee receiving such services. . . .


Mr. Policy is a registered lobbyist in the District of Columbia, and Mayor Anthony Williams is an elected official. As such, Mr. Policy is absolutely prohibited from giving to Mr. Williams, and Mr. Williams is absolutely prohibited from receiving from Mr. Policy, anything of value worth over one hundred dollars in any calendar year. This prohibition includes Mr. Policy's legal services.

I contend that Mr. Policy's pro bono representation of Mr. Williams also violates other sections of the elections and ethics laws and regulations of the District of Columbia. Certainly, individuals are not only entitled, but encouraged, to volunteer their time and services to political campaigns, and such volunteer efforts are not considered campaign contributions. However, Mr. Policy's services are not and cannot be considered volunteer services to the Committee.

First, Mr. Policy is explicitly not representing the Committee, which has separate representation. He is representing Mr. Williams as an individual. Therefore, his services do not fulfill the legal requirement that the volunteer activities be performed for the political Committee.

Second, District and Federal law place special requirements and limitations on the type of professional volunteer activities that lawyers and accountants may perform for political committees. While these limitations are not explicitly spelled out in District law, District election officials have a well established practice of relying upon Federal law and regulations in order to interpret District election laws and regulations where they are vague or incomplete. And Federal election campaign laws clearly state that lawyers and accountants may volunteer their professional services to political campaigns only insofar as those services are dedicated to enabling campaigns to comply with election laws and regulations.

A lawyer (provided he or she is not a lobbyist) may freely volunteer legal advice and representation to a committee to keep it in compliance with election laws or to defend it against a complaint of having broken election laws. But the Lindenfeld complaint does not involve election law. It is a matter of contract law. Though some of the services that Mr. Lindenfeld provided related to Mayor Williams's reelection, the dispute over payment of the bill has no relationship to election law. It is therefore outside of the legal area in which lawyers are permitted to volunteer their services to a political campaign.


On the basis of the above discussion, I am requesting the Office of Campaign Finance to investigate whether Mr. Policy's donation of pro bono legal representation to Mr. Williams as an individual violates the election laws and regulations of the District of Columbia — including whether it constitutes an illegal donation of something of value by a lobbyist to an elected official, whether services that are explicitly provided to an elected official as an individual can be considered as having been provided to that individual's political committee, and whether the representation that Mr. Policy is providing in this case falls within the boundaries of legal services that can legitimately be provided as volunteer services to a political campaign.

Sincerely yours,
Dorothy A. Brizill

cc: Mr. Benjamin Wilson, Chairman, D.C. Board of Elections and Ethics
Ms. Alice Miller, Executive Director, D.C. Board of Elections and Ethics
Mr. Kenneth McGhie, General Counsel, D.C. Board of Elections and Ethics

Subscribed and sworn or affirmed to by me this 7th day of November 2003.

My Commission Expires: 07-31-05, Sidney W. Williams, III, Notary

Back to top of page

Attachment A


THOMAS LINDENFELD, Plaintiff, v. ANTHONY WILLIAMS, et al., Defendants.
Case No. 02CA005119
Judge Jeanette J. Clark  
Calendar 14



Please take notice that counsel of record, Robert M. Krasne and Margaret A. Keeley of Williams & Connolly LLP are hereby withdrawing as counsel to defendant Anthony A. Williams ("Williams") in the above-captioned matter, and Vincent Mark J. Policy of Greenstein DeLorme & Luchs, P.C. is entering his appearance as counsel' of record for Anthony A. Williams. Please copy Mr. Policy at 1620 L Street, N.W., Suite 900, Washington, D.C., (202) 452-1400 with any pleadings, orders, or other documents issued by the Court in the above-captioned case.

We also enclose a proposed Order for the Court permitting this substitution of counsel.

Respectfully submitted,
Vincent Mark Policy
1620 L. Street, N.W. Suite 900
Washington, D.C. 20036 
Phone: (202) 452-1400 Fax: (202) 452-1410

Robert M. Krasne (375750) 
Margaret A. Keeley (454962)
725 Twelfth Street, N.W. 
Washington, D.C. 20005 
Phone: (202) 434-5000 Fax: (202) 434-5029

Anthony A. Williams


I hereby certify that on February 13, 2003, I caused true and correct copies of the foregoing Defendant Anthony A. Williams’ Notice of Appearance and Substitution of Counsel to be served by first class mail upon: 

Sherri L. Wyatt
1825 I St., N.W.
Suite 400
Washington, D.C. 20006
(202) 429-2009

Douglas J. Patton
Holland & Knight LLP
2099 Pennsylvania Ave., N.W.
Suite 100
Washington, D.C. 20006-6801
Phone: (202) 955-3000
Fax: (202) 955-5564

Vincent Mark J. Policy

Back to top of page

Attachment B

1620 L STREET, N.W., SUITE 900
WASHINGTON, D.C. 20036-5605
TELEPHONE (202) 452-1400
FACSIMILE (202) 452-1410

September 17, 2003


Sherri L. Wyatt, Esq. 
Sherri L. Wyatt, PLLC 
1017 12th Street, N.W. Suite 300
Washington, D.C. 20005

Re: Lindenfeld v. Williams, et al., Civil Action No. 02-005119

Dear Sherri:

I noted in your Opposition to our Motion to Compel Attorneys' Fees that you stated to the Court that my services are being provided on a pro bono basis. That information was provided to you in the Mediation and you and Mr. Lindenfeld agreed that any statements made in the Mediation would not be used in Court or made public. By making this statement in your pleading, you have breached that confidentiality agreement.

Vincent Mark J. Policy

VMP:vjh 215218
CC: Damien G. Stewart, Esq. (by regular mail)

Back to top of page

Attachment C (edited to relevant entries)

Greenstein, DeLorme & Luchs, P.C.
1620 L Street, N.W. Suite 900
Washington, DC 20036-56
Abraham J. Greenstein
Vincent Mark J. Policy
Richard W. Luchs
Washington DC Association of Realtors
1400 Eye Street, N. W., #400
Washington, DC 20005
Legislation: real estate, housing etc.
Apartment and Office Building Assoc.
1050 17th Street, N.W. #300
Washington, DC 20036
W. Shaun Parr
Greenstein, DeLorme & Luchs, PC
Margaret O. Jeffers
Apartment and Office Building Assoc.
1050 17th Street, N.W. #300
Washington, , DC 20036
Matters regarding housing/taxes

Friday, August 08, 2003

Back to top of page

Send mail with questions or comments to webmaster@dcwatch.com
Web site copyright ©DCWatch (ISSN 1546-4296)