STATE OF NEVADA

BEFORE THE NEVADA COMMISSION ON ETHICS

In re Bonnie Weber, Councilmember, Ethics Complaint

City Council, City of Reno, Case No. 20-010C
State of Nevada,

Subject. /

PROPOSED
STIPULATED DEFERRAL AGREEMENT

1. PURPOSE: This Stipulated Deferral Agreement resolves Ethics Complaint

Case No. 20-010 before the Nevada Commission on Ethics (“Commission”) regarding
alleged misconduct of Bonnie Weber (“Weber”), Councilmember, City of Reno (“City”),
Nevada.
2. JURISDICTION: At all material times, Weber served as a public officer for
the City, as defined in NRS 281A.160 and 281A.182. The Ethics in Government Law
(“Ethics Law”) set forth in NRS Chapter 281A gives the Commission jurisdiction over
elected and appointed public officers and public employees whose conduct is alleged to
have violated the provisions of NRS Chapter 281A. See NRS 281A.280. Accordingly, the
Commission has jurisdiction over Weber in this matter.
3. PROCEDURAL HISTORY
a. On or about February 10, 2020, the Commission received Ethics Complaint No.
20-010C (“Complaint”).
b. A redacted version of the Complaint 1 provided to Weber alleges that private
meetings Weber held with North Valley’s stakeholders, including property
developers and builders, violated the Ethics Law—at least in part because the
meetings included privately paid for lunches and were attended by certain City
staff. The confidential Requester checked boxes on the complaint form alleging

1 The Ethics Complaint was redacted to keep the identity of the Requester confidential pursuant to NRS

281A.750.

PROPOSED
Stipulated Deferral Agreement
Case No. 20-010C
Page 1 of 7
 that Weber violated NRS 281A.400(1), (2), (5) and (7) and NRS 281A.420(1)
and (3).
c. On March 26, 2020, the Commission issued its Order on Jurisdiction and
Investigation directing the Executive Director to investigate allegations that
Weber violated NRS 281A.400(1), (2) and (7), and inviting Weber to provide a
written response to the allegations in the Complaint.
d. On April 2, 2020, the Commission issued its Amended Notice of Complaint and
Investigation pursuant to NRS 281A.720, noting Commissioner Yen’s
disclosure and abstention from these proceedings.
e. On April 2, 2020, the Commission issued its Amended Order on Jurisdiction
and Investigation dismissing allegations that Weber violated NRS 281A.400(5)
and NRS 281A.420(1) and (3) for lack of sufficient evidence in the Complaint.
f. On May 5, 2020, Weber voluntarily waived the statutory time limits for the
Executive Director to complete the investigation, and for the review panel to
render an opinion.
g. On June 29, 2020, Weber submitted documentary evidence, sworn statements,
and a Response to Notice of Complaint and Investigation to the Commission.
Weber argues and maintains that she did not violate NRS 281A.400(1), (2) or
(7) by using City letterhead for a private event or accepting payment for lunches
from developers who had land-use matters before City Council.
h. On August 18, 2021, the Executive Director presented a recommendation
relating to just and sufficient cause to a Review Panel (“Panel”) consisting of
Vice-Chair Brian Duffrin and Commissioners Barbara Gruenewald, Esq. and
James Oscarson pursuant to NRS 281A.720. The Panel reviewed: (1) Ethics
Complaint No. 20-010C; (2) Order on Jurisdiction and Investigation in Ethics
Complaint No. 20-010C; (3) Weber’s Response to the Complaint; (4) Executive
Director’s Recommendation to the Review Panel with Summary of
Investigatory Findings; and (5) Relevant Evidentiary Exhibits.
i. The Panel unanimously concluded that the facts established credible evidence
to support a determination that just and sufficient cause existed for the

PROPOSED
Stipulated Deferral Agreement
Case No. 20-010C
Page 2 of 7
 Commission to render an opinion in the matter regarding the alleged violation
of NRS 281A.400(1), (2) and (7).
j. Pursuant to its Review Panel Determination and Referral Order dated August
18, 2021, the Panel referred the Complaint to the Commission for further
proceedings, including rendering an opinion on whether Weber violated NRS
281A.400(1), (2) and (7) with regard to accepting a gift which would tend
improperly to influence a reasonable person in the public officer’s position to
depart from the faithful and impartial discharge of the public officer’s public
duties, using her position to secure unwarranted privileges, preferences or
advantages, and improperly using governmental time, property, equipment or
resources, including use of public staff, to benefit a significant personal or
pecuniary interest.
k. On August 31, 2021, the Commission issued its Notice of Hearing and
Scheduling Order authorizing the parties to engage in continued investigation
of facts and exchange of written discovery, including interrogatories, requests
for production, requests for admission, and depositions, as permitted by NRS
Chapter 281A and NAC Chapter 281A.
l. On September 1, 2021, the Commission issued its Revised Notice of Hearing
and Scheduling Order, correcting the date for the adjudicatory hearing, and
reaffirming its prior order (“Scheduling Order”).
m. Pursuant to the Scheduling Order, the Executive Director continued the
investigation of the facts and the parties engaged in discovery.
n. During the course of the Executive Director’s investigation and the parties’
discovery efforts, Weber was transparent, forthcoming, and cooperative with
the Commission investigator and counsel, including without limitation,
voluntarily meeting with the investigator and counsel to answer questions,
providing documentary evidence, identifying potential witnesses and persons
with knowledge, producing City policies and procedures, and coordinating with
City officers and employees and Commission staff and counsel.

PROPOSED
Stipulated Deferral Agreement
Case No. 20-010C
Page 3 of 7
o. Upon completion of the Executive Director’s investigation and the parties’
discovery, the undisputed evidence shows that Weber did not use City
letterhead for private events and did not accept payment for lunches from
developers who had land-use matters before City Council.
p. With regards to claims that Weber improperly used City staff to benefit a
significant personal or pecuniary interest, the evidence shows that City of Reno,
Policies and Procedures, No. 401, Ethical Standards (“Policy No. 401”), does
not adequately address situations where City staff attend meetings that are
hosted or organized by elected officials, but not open to the general public.
q. While Weber did invite City staff to a series of private events, the evidence
shows that—similar to other private events hosted by industry groups and trade
associations—City staff asked for and accepted invitations, attended,
presented, engaged in discussions, and answered questions in furtherance of
their public duties and City business. Specifically, City staff chose to participate
in Weber’s events to educate and engage the development community in North
Valleys, elicit input and feedback on City policies and procedures, exchange
information, and discuss mutual problems and solutions. See, e.g., In re Public
Officer, Comm’n Opinion No. 11-36A (2012). In light of the public benefit
derived from City staff’s participation, coupled with the fact that Weber did not
direct, order, or otherwise compel City staff to attend or participate in any
meeting, there is insufficient evidence to conclude that Weber used City staff
to benefit her personal or financial interests, or the personal or financial interest
of others.
r. In light of the insufficiency in Policy No. 401, Weber’s commitment to
transparency and public integrity, and the parties’ desire to clarify and improve
public officers’ ethical standards of conduct, Weber and the Commission agree
to enter into this Stipulated Deferral Agreement (“Agreement”).

PROPOSED
Stipulated Deferral Agreement
Case No. 20-010C
Page 4 of 7
 4. TERMS AND CONDITIONS: Weber and the Commission agree and
stipulate as follows:
a. The Commission hereby dismisses with prejudice all claims that Weber
violated NRS 281A.400(1) and (2) and claims that she violated NRS
281A.400(7) by using City letterhead for a private event.
b. The Commission will defer all claims that Weber otherwise violated NRS
281A.400(7) by using City staff to benefit her personal or financial interests, or
the personal or financial interest of others, for a period of 90 days from the
Effective Date of this Agreement or as may be extended pursuant to the terms
of this Deferral Agreement (the “Deferral Period”).
c. Weber agrees to waive applicable time limitations set forth in NRS Chapter
281A and defer her defense to claims that Weber violated NRS 281A.400(7)
by using City staff to benefit her personal or financial interests, or the personal
or financial interest of others for the Deferral Period.
d. During the Deferral Period, Weber agrees to work with the City Manager, the
City Attorney’s Office, and the Executive Director or duly authorized designee
to: (i) update and revise Policy No. 401 to address situations where City staff
attend meetings that are hosted or organized by elected officials, but not open
to the general public; and (ii) update and revise Citywide training on Policy No.
401 and encourage impacted City officials and employees to receive training
on Policy No. 401.
e. The Executive Director or duly authorized designee may elect to extend the
Deferral Period up to 30 days.
f. All remaining claims are dismissed with prejudice upon the expiration of the
Deferral Period unless the Executive Director or duly authorized designee
notifies Weber in writing prior to the expiration of the Deferral Period that (s)he
objects to the City’s revisions to Policy No. 401, and the grounds for the
objection.

PROPOSED
Stipulated Deferral Agreement
Case No. 20-010C
Page 5 of 7
 5. ACCEPTANCE: We, the undersigned parties, have read this Stipulated
Agreement, understand each and every provision therein, and agree to be bound thereby.
The parties orally agreed to be bound by the terms of this agreement during the regular
meeting of the Commission on October 20, 2021 (the “Effective Date”).

DATED this day of , 2021. DRAFT

Bonnie Weber

The above Stipulated Agreement is approved by:

FOR BONNIE WEBER

DATED this day of , 2021. DRAFT

Paul A. Lipparelli, Esq.

DATED this day of , 2021. DRAFT

Jonathan D. Shipman, Esq.
Reno City Attorney's Office

FOR EXECUTIVE DIRECTOR,

NEVADA COMMISSION ON ETHICS

DATED this day of , 2021. DRAFT

Elizabeth J. Bassett, Esq.
Associate Counsel

///

///

///

PROPOSED
Stipulated Deferral Agreement
Case No. 20-010C
Page 6 of 7