Minutes 7-29-25

MINUTES OF THE OPEN SESSION

OF THE RHODE ISLAND ETHICS COMMISSION

July 29, 2025

The Rhode Island Ethics Commission held its 11^th meeting of 2025 at 9:00 a.m. at the Rhode Island Ethics Commission conference room, located at 40 Fountain Street, 8th Floor, Providence, Rhode Island, on Tuesday, July 29, 2025, pursuant to the notice published at the Commission offices, the State House Library, and electronically with the Rhode Island Secretary of State.

The following Commissioners were present:

Lauren E. Jones, Chair Frank J. Cenerini

Holly J. Susi, Vice Chair Emma L. Peterson

Matthew D. Strauss, Secretary Scott P. Rabideau

Christopher P. Callahan

The following Commissioners were not present: Dr. Michael Browner, Jr., and Hugo L. Ricci, Jr.

Also present were Herbert F. DeSimone, Jr., Commission Legal Counsel; Jason Gramitt, Commission Executive Director; Katherine D’Arezzo, Senior Staff Attorney; Lynne M. Radiches, Staff Attorney/Education Coordinator; Staff Attorneys Teresa Giusti and Teodora Popova Papa;[1] and Commission Investigators Peter J. Mancini; Gary V. Petrarca; and Kevin Santurri.

At 9:04 a.m., the Chair opened the meeting.

The first order of business was:

Approval of minutes of the Open Session held on July 1, 2025.

Upon motion made by Commissioner Susi and duly seconded by Commissioner Cenerini, it was

VOTED: To approve the minutes of the Open Session held on July 1, 2025.

AYES: Lauren E. Jones; Christopher P. Callahan; Frank J. Cenerini; Scott P. Rabideau; and Holly J. Susi.

ABSTENTIONS: Emma L. Peterson and Matthew D. Strauss.

The next order of business was:

Director’s Report: Status report and updates.

a.) Complaints and investigations pending

There are seven complaints pending. Executive Director Gramitt informed that he is awaiting a new date for the depositions to be conducted in the Thorsen matter, and he expects to have more information by the Commission’s next meeting. Executive Director Gramitt stated that respective counsel for In re: Heidi Weston Rogers have agreed upon October 21, 2025, for an adjudication. The matter of In re: Jason E. Licciardi, Sr. is scheduled for a probable cause hearing today in executive session. In re: Jonathan Pascua is under investigation, and there are two complaints against Robert Lombardo, one of which was initially determined at the last meeting and one of which is scheduled for initial determination today in executive session.

b.) Advisory opinions pending

There are seven advisory opinions pending, three of which have been noticed for today’s meeting.

c.) Access to Public Records Act requests since last meeting

There were three APRA requests received since the last meeting, one of which was granted within one business day. Executive Director Gramitt explained that a second request required attorney review and was granted within four business days. He further explained that the third request was granted within five business days because it sought historic financial disclosure statements from offsite storage.

In response to Chair Jones, Executive Director Gramitt informed that the administrative staff largely handles APRA requests and is aware of what information may be disclosed. He stated that if an APRA request requires attorney review, Staff Attorney Popova Papa is the designated attorney to decide what action to take. Executive Director Gramitt explained that if Staff Attorney Popova Papa redacts or withholds information in response to an APRA request, she informs the requester that they may appeal her decision to the Executive Director. He stated that he did not believe that this has occurred yet, given the staff’s proclivity towards disclosure. He further stated that if such a situation arose, he would decide whether to disclose the requested information and inform the Commission if he believed that the matter might escalate to a complaint against the Commission being filed with the Attorney General’s office or the Superior Court.

d.) Financial disclosure

Executive Director Gramitt informed that there is only one remaining non-filer, a municipal appointed official, and the staff-initiated complaint will be filed tomorrow.

e.) General office administration

Executive Director Gramitt informed that the next meeting will be held on August 19, 2025. He also informed that two of the advisory opinions on today’s agenda will be presented remotely. He explained that attorneys and petitioners may appear remotely before the Commission without violating the Open Meetings Act, but Commissioners are required to appear in person.

The next order of business was:

Advisory Opinions.

The advisory opinions were based on draft advisory opinions prepared by Commission Staff for review by the Commission and were scheduled as items on the Open Session Agenda for this date.

The first advisory opinion was that of:

Joseph A. Balducci, the chief financial officer for the Cranston Public Schools, requests an advisory opinion regarding whether the Code of Ethics prohibits him from accepting, in his private capacity, an appointment to the board of directors of AccessPoint RI, a parent entity to Cornerstone School, a private learning facility attended by several Cranston students which is compensated for the services provided to those students by the City of Cranston.

Staff Attorney Popova Papa presented remotely the Commission Staff recommendation. The Petitioner was present. Upon motion made by Commissioner Callahan and duly seconded by Commissioner Rabideau, it was unanimously

VOTED: To issue an advisory opinion to Joseph A. Balducci, the chief financial officer for the Cranston Public Schools.

The next advisory opinion was that of:

Molly Moran-Ogren, an environmental policy analyst with the Rhode Island Department of Environmental Management, who in that capacity also serves as the chairperson of the Seafood Marketing Collaborative, requests an advisory opinion regarding whether the Code of Ethics prohibits her from starting a private business to offer and provide marketing and business development services to seafood businesses outside of Rhode Island.

Staff Attorney Popova Papa presented remotely the Commission Staff recommendation. The Petitioner was present. In response to Commissioner Peterson, the Petitioner stated that her marketing campaigns will include techniques and indicators to exclude Rhode Island. She explained that as a marketing strategist, she will not be offering techniques that would target Rhode Island. The Petitioner further explained that if an out-of-state seafood company wants to do business in Rhode Island, she will not take that client. She stated she will not do business with private clients that would cut against Rhode Island businesses. Commissioner Peterson commented that the lines sound blurred but hopes the Petitioner will be able to work through any issues. The Petitioner explained that there are many West Coast businesses that are not targeting Rhode Island seafood businesses as a consumer base, given that the seafood market in the New England area is saturated and investing in marketing strategies in this area would not be profitable for West Coast businesses. She represented that the West Coast businesses, instead, are targeting areas such as New York, Los Angeles, and Las Vegas.

In response to Commissioner Callahan, the Petitioner stated that the goal of the Seafood Marketing Collaborative, of which she is the chairperson, is to foster the in-state consumption and purchasing of locally-caught seafood, and the Collaborative’s charter does not allow for marketing to other states. In response to Chair Jones, the Petitioner informed that members of the Collaborative are not precluded from selling to other states but, as a collaborative, the intent is to stay in state. Upon motion made by Commissioner Susi and duly seconded by Commissioner Rabideau, it was unanimously

VOTED: To issue an advisory opinion to Molly Moran-Ogren, an environmental policy analyst with the Rhode Island Department of Environmental Management, who in that capacity also serves as the chairperson of the Seafood Marketing Collaborative.

Chair Jones expressed gratitude to Staff Attorney Popova Papa for presenting remotely today despite her illness.

The final advisory opinion was that of:

Christopher E. Buonanno, a member of the Cranston City Council, requests an advisory opinion regarding whether he is prohibited by the Code of Ethics from participating in the city council’s discussion and voting to accept or reject as a whole the collective bargaining agreement reached between the Cranston School Committee and the Cranston teachers’ union, given that his spouse is employed by the Cranston School District and is a member of the union.

Staff Attorney Radiches presented the Commission Staff recommendation. The Petitioner was present. Staff Attorney Radiches informed that the Petitioner had received a safe-harbor letter along with his draft to allow him to participate in last night’s City Council meeting, pending the Commission’s decision today. The Petitioner expressed gratitude for the safe harbor letter that he received and explained the basis for his expedited request and the accelerated process of the contract negotiations. In response to Commissioner Susi, the Petitioner stated that the City Council’s meeting lasted approximately 35 minutes and was very straightforward with no issues raised, and the vote to accept the contract was unanimous. Upon motion made by Commissioner Peterson and duly seconded by Commissioner Callahan, it was unanimously

VOTED: To issue an advisory opinion to Christopher E. Buonanno, a member of the Cranston City Council.

The next order of business was:

Education Update.

Education Coordinator Radiches presented an education update on ethics trainings conducted during FY 2025 which included a handout summarizing information about the trainings. She informed that a total of 2,963 people received training, an increase of 354 people over last year, and that she conducted 56 in-person/zoom/hybrid trainings attended by 2,324 people, which is seven more trainings than last year. Education Coordinator Radiches explained that live trainings are broken down by month and category on page one of the handout, and pages two and three provide an alphabetical listing by category of the groups that received training. She stated that live trainings of note included the Bonnet Shores Fire District, two virtual sessions for solicitors for CLE credit, the Commerce Corporation, and the Department of Revenue. She added that Executive Director Gramitt presented live, in-person trainings to members of the House and Senate and their staff.

Education Coordinator Radiches informed that consistent with the Ethics Commission’s recommendation that people receive ethics training every one to three years, she sent letters on July 1, 2025, to the clerks of the 10 municipalities which have not hosted a training for at least three years. She further informed that she since has received a response from two of the 10 clerks for whom she is in the process of scheduling ethics trainings. Education Coordinator Radiches stated that in August, she will call those who have not responded to her letter and encourage them to schedule a training.

Education Coordinator Radiches informed that the number of people from state departments, boards, commissions, and agencies who completed prerecorded online ethics training course is found on pages four and five of the handout and totals 461. She further informed that the total number of people from municipalities who completed the same online training is on page six of the handout and totals 178. She stated that the total of 639 persons who completed the prerecorded trainings in FY 2025 marks an increase of approximately 45% from FY2024. Education Coordinator Radiches noted that her focus for the upcoming year will be on contacting human resources staff from municipalities and state agencies to strongly encourage their employees to take the training.

In response to Chair Jones, Education Coordinator Radiches explained how requests for prerecorded trainings are received and processed. She noted that there are seven modules that comprise the prerecorded training, and these modules are available through the state’s learning center. Education Coordinator Radiches explained that the municipal clerks submit to her the names and email addresses of those persons requesting access to the prerecorded training modules. Education Coordinator Radiches, in turn, sends the names to the state, on a weekly basis, and the state provides the links to those who have requested them. Education Coordinator Radiches explained how she tracks the numbers of those who have requested the links and those who completed all seven modules.

At 10:00 a.m., upon motion made by Commissioner Susi and duly seconded by Commissioner Rabideau, it was unanimously

VOTED: To go into Executive Session, to wit:

a.) Motion to approve minutes of Executive Session held on July 1, 2025, pursuant to R.I. Gen. Laws § 42-46-5(a)(2) & (4).

b.) In re: Jason E. Licciardi, Sr., Complaint No. 2025-1, pursuant to R.I. Gen. Laws § 42-46-5(a)(2) & (4).

c.) In re: James Durkin, Complaint No. 2025-4, pursuant to R.I. Gen. Laws § 42-46-5(a)(2) & (4).

d.) In re: Robert L. Lombardo, Complaint No. 2025-5, pursuant to R.I. Gen. Laws § 42-46-5(a)(2) & (4).

e.) Motion to return to Open Session.

At 11:27 a.m., the Commission reconvened in Open Session. The livestream resumed at 11:28 a.m.

The next order of business was:

Motion to seal minutes of July 29, 2025, Executive Session.

Upon motion made by Commissioner Callahan and duly seconded by Commissioner Peterson, it was unanimously

VOTED: To seal the minutes of Executive Session held on July 29, 2025.

The next order of business was:

Report on actions taken in Executive Session.

Chair Jones reported that the Commission took the following actions in Executive Session:

Voted (5-0) to approve the minutes of the Executive Session held on July 1, 2025.

[Reporter’s Note: The vote was as follows:

AYES: Lauren E. Jones; Christopher P. Callahan; Frank J. Cenerini; Scott P. Rabideau; and Holly J. Susi.

ABSTENTIONS: Emma L. Peterson and Matthew D. Strauss.]

Voted (6-0) in the matter of In re: Jason E. Licciardi, Sr., Complaint No. 2025-1, to find that probable cause does not exist to believe that the Respondent, a member of the West Warwick Town Council, violated R.I. Gen. Laws § 36-14-5(a) or 5(d) by his participation in the Town Council’s February 4, 2025, discussion and vote regarding Shoreline Properties, LLC’s request for a bond reduction.

[Reporter’s Note: The vote was as follows:

AYES: Lauren E. Jones; Christopher P. Callahan; Frank J. Cenerini; Emma L. Peterson; Matthew D. Strauss; and Holly J. Susi.

RECUSAL: Scott P. Rabideau.]

Voted (6-0) in the matter of In re: Jason E. Licciardi, Sr., Complaint No. 2025-1, to find that probable cause does not exist to believe that the Respondent, a member of the West Warwick Town Council, violated R.I. Gen. Laws § 36-14-5(a) or 5(d) by his participation in the Town Council’s February 12, 2025, discussion and vote regarding Shoreline Properties, LLC’s request for a bond reduction.

[Reporter’s Note: The vote was as follows:

AYES: Lauren E. Jones; Christopher P. Callahan; Frank J. Cenerini; Emma L. Peterson; Matthew D. Strauss; and Holly J. Susi.

RECUSAL: Scott P. Rabideau.]

Unanimously voted (7-0) in the matter of In re: Robert L. Lombardo, Complaint No. 2025-5, to initially determine that the Complaint states facts that, if true, are sufficient to constitute a violation of the Code of Ethics and to authorize a full investigation.
Unanimously voted (7-0) in the matter of In re: James Durkin, Complaint No. 2025-4, to initially determine that the Complaint states facts as to paragraphs six through nine that, if true, are sufficient to constitute violations of the Code of Ethics and to authorize a full investigation.

As to Lombardo and Durkin, an Initial Determination is a preliminary vote that should not be construed as an opinion regarding the truth of the facts alleged in the complaint but is merely a vote to conduct an investigation into the allegations raised.
Unanimously voted (7-0) to return to Open Session.

The next order of business was:

New Business proposed for future Commission agendas and

general comments from the Commission.

There were none.

At 11:32 a.m., upon motion made by Commissioner Callahan and duly seconded by Commissioner Rabideau, it was unanimously

VOTED: To adjourn the meeting.

Respectfully submitted,

___________________________

Matthew D. Strauss

Secretary

[1] Staff Attorney Popova Papa attended the open session portion of the meeting remotely.