Document 44d56kjx74go3rqg5dB08XB0R

Cavanaugh^ From: Sent: To: Subject: Cavanaugh, Charles Thursday, January 25,2018 12:05 PM Perrotta, Pasquale Outside Activity Request Extension - Perrotta Nino, Being that all the underlying information on which former DEO Jon Cole made his affirmative determination, and being this is simply a time extension, I approve the extension of your Outside Activity Request for one year (until March 5 ,2019). PLEASE NOTE: In addition to the counsel Jon provided in his 2013 approval which remains in effect, I would also counsel you that since it is a compensated outside activity, you may NOT utilize any government resources including phones, computers, fax machines, copiers etc in support of this activity. Please remember this includes government time. You may not conduct any outside compensated activities while on official duty (even utilizing your personal cellphone etc). Thanks for checking in on this, and call with any questions. Chuck Cavanaugh (MC Associate Director and Deputy Ethics Official Office of Criminal Enforcement, Forensics and Training 2231A), Room 1211WJC-S Office of Enforcement and Compliance Assurance United States Environmental Protection Agency (202) 564-0791 (202) 501-0599 (fax) From: Perrotta, Pasquale Sent: Thursday, January 25, 2018 11:54 AM To: Cavanaugh, Charles <Cavanaugh.Charles@epa.gov> Subject: Re: Good Morning - Nino Yes sir it is still accurate and correct. V/r, Nino Perrotta | Special Agent in Charge U.S. Environmental Protection Agency | Protective Service Detail | Perrotta.Pasquale@epa.gov | www.epa.gov C: Ex. 6 Sierra Club v. EPA 18cv3472 NDCA 1 Prod 1 ED 002061 00017427-00001 CONFIDENTIALITY NOTICE: This message and any attachments is from a Federal Law Enforcement Officer of the U.S. Environmental Protection Agency, Protective Service Detail which may contain CONFIDENTIAL and legally protected information. It is intended exclusively for the individual(s) or entity(s) to whom or to which it is addressed. This communication may contain information that is proprietary, privileged, or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy, or disseminate this message or any part o f it. If you have received this message in error, please notify the sender immediately by email and delete all copies o f the message. On Jan 25,2018, at 11:51 AM, Cavanaugh, Charles <Cavanaugh.Charles@,epa.gov> wrote: Nino, Thanks for staying diligent on this! Before I can make the final determination - can you confirm that all of the information you submitted in your outside activity request to Jon Cole on February 28,2013 via email is still accurate and correct? Chuck Cavanaugh Associate Director and Deputy Ethics Official Office of Criminal Enforcement, Forensics and Training (MC 2231A), Room 1211WJC-S Office of Enforcement and Compliance Assurance United States Environmental Protection Agency (202) 564-0791 (202) 501-0599 (fax) From: Perrotta, Pasquale Sent: Thursday, January 18,2018 10:14 AM To: Cavanaugh, Charles <Cavanaugh.Charles(5>epa.gov> Subject: Good Morning - Nino Sir I hope you are well! This is coming due and was looking to extend it for one year if possible? Respectfully, Nino Sierra Club v. EPA 18cv3472 NDCA 2 Prod 1 ED 002061 00017427-00002 UNITED STATES EN VIRON M ENTAL PROTECTION AG EN C Y W ASHINGTON, D.C. 20460 MEMORANDUM March 5,2013 O f-FCc OF Ei'-iFOrOF'.r?,; AND lOMFUAN D1 " SS'JRANCfc SUBJECT; Approval of Request for Outside Activity/Employment FROM: JDAOoefsnfspiaocutcehtyiaaontEfetSChD.riciiCmrseoicOlnetoarl Enforcement. Forensics and Training TO; PSpaescqiuaal.leAPgeernrtotta pbser6yoc4cuv0ori1idmt,ey1mY0cai3oonsu.ndssithooduanelctvn.ioeninaYgrlseoutoqoulftu2sseot-esra3rttedvecdeilctvihaeeepanlitpontsyrps,ouobvfruoauarwnlsicafineloplerptsborosoe,ucxotsoisermnildbsfae-uotemetemhlmye,prpfls3oo.l-ory6yeTahmdhsoeeeiuncnrbutstarhisipnitiseysaraffcwcoicrtromeiveyrdikottahy.unaractcnewodwmiltlihptahpetnr5oysvaoCitudiFoeeRnxcpwyebicleltr-btoe csutonanetedxupthceatcYettdeoadulolouacrtroseenidmaseueGlortSgifne-y1gno3cauynSrdwpdeuobctruyikas.ilhnoAeusgrsesanoctrtwiLviiEtthiAeOsPCr(eEalvaFtaTiinl,agobtniolittthyheipsPaoryou)tterseicdqtieuvieermeSmpeelrovnyitcsme, seonrDtaewntayiillln.ebceYeossuary nthoattayvoauiYlwaobiullelantlosootthsbeteagteeemnthpealroat ylnepoduobpfluficircsiwuaalilnldtubtteoyuatsnimeEdePionArcGcoononnvteeracrnctitmoonernwgt riptahrnottp.heertoyu, trseidsoeuermcepsl,ooyrmfeancti,litaineds CRFegRulPataYirotonu2s)6i.n3d5ic(aStuebtphaatrthaHveonreaOdu, tasriedefamAicltiiavritwieisth),aanndd wSielcltaiobnide64by01th.1e0r2est(rEicPtAio!nssSduepscprliebmedeninta5l aksucecbeopmrdiintaaInmacrimeenvdwiasitpethhpdarttorheivefqiuntahegpespytnloifacoutaurrbrarleepeqporurruoeslvsectasoltp.aoenadocAcrfeebtghpseuetnltdathtuisistouineocshsutoccsorihdnasecenergevremniscip,enlstgohypiosmeuratefsponipdrtmreaoneveddamlccpiholsoaneyndfmgufeecesctn,titiyt.voeinuPflomerausaest 1 Internet Address {URL} http://www.epa.90v iW cyd m V R ee yoiyblo Primed with Vegetable Oil Based inks on 100% Postconsumer. Process CWorine Free Recycled Paper Sierra Club v. EPA 18cv3472 NDCA Prod 1 ED 002061 00017427-00003 period of five (5) years. The Office of General Counsel (OGC) has noted certain issues which should guide you in conducting this outside employment. The first issue relates to the use of your official title. In order to comply with ethics guidelines, you should not refer to your official title or position, to avoid creating the appearance that your activities or services are in any way approved by or affiliated with the EPA. You should also be alert to the potential for conflicts of interest if you represent your outside employer back to the federal government, so you should not do so in relation to any contracts or consulting agreements, or other activities. Please feel free to contact me to discuss any particular situation that might potentially raise a concern. You must also be sure to report this outside activity on your OGE Form 450, Confidential Financial Disclosure Statement, as appropriate, including as an outside position and a source of income. If you have any questions concerning this memorandum or the issues discussed, please contact me at (202) 564-2533. cc: Jonathan S. Cole Steven Drielak Brian Maas Sam Wiggins Sierra Club v. EPA 18cv3472 NDCA 2 Prod 1 ED 002061 00017427-00004 Cole, Jonathan From: Sent: To: Ce: Subject: Perrotta, Pasquale Thursday, February 28, 2013 1:37 PM Cole, Jonathan Wiggins, Samuel Permission: Outside Employment Dear Mr. Jonathan Cole, CC SAIC Samuel Wiggins, Subject: Perm ission: Outside Employment I am seeking permission to conduct outside employment that will not interfere with either my daily obligations as a special agent of the EPA and or obligations to leap. I have attached the guidance provided by Ms. Justina Fugh in order to have this request properly completed. 1. Title: Special Agent, EPA-CID Pasquale Nino Perrotta GS-13-8 2 . 1will consult and or business develop for a security firm that will provide cyber - security and denial of service insurance to the consumer. All compensation will be based on commission. 3. Self employed; will be providing consulting to 2-3 clients. 4 .1will be dedicating approximately 3 to 6 hours a week to this outside employment. 5. All consulting and or busienss developemnt services will be conducted outside of my duty hours and or leap requirements. 6. During the course of my consulting I will not use government property, government duty time, resources or facilities to service my outside employment. 7. Compensation; will be a commission fee that will be based on the service time needed to accomplish the project. 8 .1 read, I am familiar with and will abide by the restrictions described in 5 CFR Part 2635 and section 6401.102. 9 .1 will not conduct business with folks that have an EPA service agreement or contracts with EPA. Thank you, Nino Perrotta Special Agent EPA-CID Protective Services Division 202-263-9115 From: Fugh, Justina Sent: Monday, February 25, 2013 3:40 PM To: Perrotta, Pasquale Subject: closing the loop Hi Nino, Sorry to have taken a few days to get back to you. You had asked whether an EPA special agent could take on a security related job in addition to performing his/her official EPA duties. The answer is a cautious yes, but the agent will have to: (a) seek prior approval of the outside activity by following the directions below; and (b) understand that any outside work must not be put ahead of the EPA work. In the event that the agent is required to work (under LEAP, for instance), then the agent must comply. The outside job cannot take precedence over the EPA work. Sierra Club v. EPA 18cv3472 NDCA Prod 1 ED 002061 00017427-00005 To seek prior approval of the outside activity, the agent must send a request throus n his first level supervisor to be ` approved by his Deputy Ethics Official. In the case of OCEFT, the DEO is Jonathan Cole. The request (which can be an email) must address the following: name, title and grade; the nature of the outside activity, including a full description of the services to be performed and the amount of compensation expected; the name and business of the person or organization for which the work will be done (in cases of self- employment, indicate the type of services to be rendered and estimate the number of clients or customers anticipated during the next six months); the estimated time to be devoted to the activity; whether the service will be performed entirely outside of normal duty hours (if not, estimate the number of hours of absence from work required); a statement that no official duty time or Government property, resources, or facilities not available to the general public will be used in connection with the outside employment; the basis for compensation (e.g., fee, per diem, per annum, etc.) a statement that the employee has read, is familiar with, and will abide by the restrictions described in 5 CFR Part 2635 (Subpart H on "Outside Activities) and Section 6401.102 (EPA's Supplemental Regulations); and an identification of any EPA assistance agreements or contracts held by a person to or for whom services would be provided. Justina Justine Fugh |Senior Counsel for Ethics |O ff ic e of General Counsel |US EPA |Mail Code 2311A |Room 4308 Ariel Rios North |Washington, DC 20460 (for ground deliveries, use 20004 fo r the zip code) |phone 202-564-1786 |cell; E x . 6 il fax 202-564-1772 J Sierra Club v. EPA 18cv3472 NDCA 2 Prod 1 ED 002061 00017427-00006