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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON.. D.C 20460
MEMORANDUM
OFi-Civ of -NFGRCSf'!T AUD CO ;F F :. AfvC AS 3 URROC 0
HL'BJUC i : Approval ol Request it>i*Outside Activity-'Hmplovment
FROM:
Jonathan S, Cole Depul)' fithies Official Associate Director Olhee ol Criminal finlurcemeni. Forensics and Training
Pasquale Fermila Special Agent
You hove requested approval Tor outside employment in accordance with 5 (.`Hi 6401.103, to consult or develop business, or both, for a security firm that will provide cybersecurity and denial ol service insurance to consumers. The basis for your compensation will be by commission. You stale that you will he self-employed in this activity and that you expect to provide consulting, to 2-3 clients, for approximately 3-6 hours per week.
You are a (IS-13 Special Agent will) O il ITT. on the Protective Services Detail. You stale that all consulting and business activities relating to this outside employment will he conducted outside of your duty hours or l.fiAP favailability pays requirements, or any necessary unexpected or emergency weak,
You also stale 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, and that you will not be employed pursuant to an I-PA contract or grant.
You indicate that have read, arc familiar with, and will abide by the restrictions described in 5 CFR Part 2635 (.Subpart H on Outside Activities) and Section 6401.102 iHITVs Supplemental Regulations),
I am approving your request to accept this outside employment and conduct it in accordance with the applicable rules and regulations concerning outside employment. Please keep in mind dun if the nature or scope of the duties or services performed changes, you must submit a revised request for approval. Absent such changes, this approval is ef lective for a
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Sierra Club v. EPA 18cv3472 NDCA
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ED 002061 00017428-00001
period o f five (5) years,
The Office o f General Counsel (OGC) has noted certain issues which should guide you in conducting this outside employment. The first issue relates to the use o f 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 o f 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 m ust 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) S642533.
cc: Jonathan S. Cole Steven Drielak Brian Maas Sam Wiggins
Sierra Club v. EPA 18cv3472 NDCA
2 Prod 1
ED 002061 00017428-00002