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Peter P.

Belfiore
161 11th Street
Hoboken, New Jersey
Phone (973) 418-3723
Hoboken411.com

May 10, 2010

By Regular Mail and Fax to (609) 292-9073

Marc Pfeiffer
Acting Director, Division of Local Government Services
New Jersey Department of Community Affairs
101 S. Broad St.
P. O. Box 803
Trenton, NJ 08625-0803

RE: Local Government Ethics Law Complaint


Hoboken City Councilman Ravinder Bhalla

Dear Mr. Pfeiffer:

I am a resident and taxpayer of Hoboken, New Jersey. Please accept this letter as
my request to file a complaint pursuant to the Local Government Ethics Act against Hoboken
City Councilman Ravinder S. Bhalla.

The facts supporting this complaint are as follows: In 2008 the City of Hoboken hired
an attorney, Paul Condon, Esq., to handle disciplinary charges against a number of police
officers after a scandal involving the Hoboken Police SWAT team became public. Mr. Bhalla
joined the Council in July 2009, well after the City first hired Mr. Condon. The disciplinary
matter apparently is still ongoing, and on February 17, 2010, the Hoboken City Council
approved a resolution awarding a $29,000 contract for Mr. Condon’s continued legal services to
the City. I have attached a copy of the February 17, 2010 Council meeting agenda and the
resolution awarding the contract. The resolution was adopted by a 9-0 vote with Councilman
Bhalla voting “yes.”

Shortly after the vote, local Internet sites began to make note of an extremely close business
and personal relationship between Mr. Condon and Councilman Bhalla, including a joint law
practice operating out of 33-41 Newark Street, Suite 4A, Hoboken. I have enclosed a picture of
the office directory from the 33-41 Newark Street building showing a listing for the “Law Office of
Ravinder Bhalla/Paul Condon,” which was taken by a well-known local website,
Hoboken411.com. At a March City Council meeting, Hoboken Councilwoman Beth Mason
raised concerns about this relationship, which was reported in the local newspaper, the
Hoboken Reporter. According to the article, which I have attached, Councilman Bhalla claims
that they are not law partners, but admits that they have a joint lease and share a receptionist.
He also admits that if Mr. Condon were to default on the lease he would be responsible for its
full payment.

I strongly suspect that Mr. Bhalla is significantly understating his business ties to Mr.
Condon, with respect to such typical office costs as office furniture and equipment, utility and
phone bills, and many more. It would also be common for people in their situation to refer
business to each other. Additionally, if they share a computer, fax or filing system, I believe
under attorney ethics rules that they may be treated as if they were actual law partners. Without
a full investigation, it is impossible to tell the true depths of their business relationship.
Hoboken411.com

Councilman Bhalla claims he sought legal advice from the City’s attorney prior to casting
the vote, but since he did not do so in public session it is impossible to tell whether Councilman
Bhalla gave the City’s attorney the full and complete truth. Even if he did so, the City’s attorney
is a political ally of Councilman Bhalla and has a strong financial interest in not “rocking the
boat,” so I have little confidence in his legal analysis. Councilman Bhalla is a member in good
standing of the New Jersey Bar, and has many lucrative public contracts throughout the state,
as shown by the attached news article describing these contracts and Councilman Bhalla’s
failure to file required ELEC forms disclosing his political contributions. This means that the
conflict of interest standards should not be alien to him. As at least one member of the City
Council has already called for the contract to be invalidated, it is clear that Councilman Bhalla’s
failure to disclose the conflict directly impacted the vote to approve Mr. Condon’s contract.

The specific provisions of the Local Government Ethics Law I believe have been violated
include 40A:9-22.5a, which says that “no local government officer or employee or member of
his immediate family shall have an interest in a business organization or engage in any
business, transaction, or professional activity, which is in substantial conflict with the proper
discharge of his duties in the public interest,” 40A:9-22.5c, which says that “no local
government officer or employee shall use or attempt to use his official position to secure
unwarranted privileges or advantages for himself or others,” 40A:9-22.5d, which says that “no
local government officer or employee shall act in his official capacity in any matter where he, a
member of his immediate family, or a business organization in which he has an interest, has a
direct or indirect financial or personal involvement that might reasonably be expected to impair
his objectivity or independence of judgment,” and possibly several others.

I believe that an independent investigation by the Division into Councilman


Bhalla’s actions is desperately needed to safeguard the public trust and re-establish strong
conflict of interest standards in Hoboken.

Thank you for your many courtesies. If I can provide you with any further information,
please call me.

I remain,

Peter P. Belfiore

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