THIS SETTLEMENT AGREEMENT is entered into between the Philadelphia…

THIS SETTLEMENT AGREEMENT is entered into between the Philadelphia Board of
Ethics (hereinafter "the Board''), and the Honorable Carol Ann Campbell, Secretary to the
Democratic City Committee (hereinafter "Candidate Campbell''); the Honorable Frank
Oliver, Treasurer, Democratic Campaign Committee PAC; and Martin Weinberg,
Esquire, Treasurer, Finance Committee of the Philadelphia Democratic County Executive
Committee PAC.

RECITALS

   A. The Philadelphia Board of Ethics is an independent board that was established by
      ordinance, approved by voters, and installed on November 27, 2006. It is charged
      with providing ethics training for all city employees and enforcing city campaign
      finance, financial disclosure, and conflict of interest laws. The Ethics Board has
      authority to render advice, investigate complaints and issue fines.

   B. Candidate Campbell is a declared candidate for the City elective office of City
      Council. Candidate Campbell is also the Secretary of the Democratic City
      Committee and is involved with that Committee's two Political Action
      Committees: the Democratic Campaign Committee and the Finance Committee of
      the PDC Executive Committee Political Action Committee (together, the
      "Democratic PACs").

   C. The Honorable Frank Oliver is the Treasurer of the Democratic Campaign
      Committee PAC (the "Campaign PAC").

   D. Martin Weinberg, Esquire is Treasurer of the Finance Committee of the
      Philadelphia Democratic County Executive Committee PAC (the "Finance
      Committee PAC").

   E. As a declared candidate for City Council, Candidate Campbell is subject to the
      City's campaign finance law. That law grants jurisdiction to the Board and
      mandates that the Board enforce its provisions.

   F. Section 20-1003 of the campaign finance law, known as the "Single Committee
      Rule," provides that a candidate for a City elective office shall have no more than
      one political committee and one checking account for the city office being sought,
      into which all contributions for such office shall be made and out of which all
      expenditures for that office shall be made.

   G. Under the Single Committee Rule, when a candidate for office also maintains a
      political or non-political account other than that candidate's single
      committee/account, such funds collected in these accounts shall not be used for
      the purpose of influencing the outcome of a covered election. Philadelphia Code
      § 20-1003. "Covered elections" include all elections for all City elective offices.
      Id. at §§ 20-1001(7) & (5).




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  H. Candidate Campbell's single candidate committee, pursuant to § 20-1003 of the
     Philadelphia Code, is the "Friends of Carol Ann Campbell" committee.

  I. Pursuant to its mandate, the Ethics Board commenced an investigation into the
     Democratic PACs. Through its investigation, the Ethics Board secured recorded
     statements under oath from Candidate Campbell, the Treasurers of the
     Democratic PACs, the Assistant Treasurer of the Campaign PAC, the Bookkeeper
     for the Campaign PAC, and the Accountant for the Democratic PACs, who is also
     the Treasurer of the Friends of Carol Ann Campbell committee. In addition, the
     Ethics Board also obtained bank records and expenditure documents for the
     Democratic PACs.

  J. During the course of its investigation, the Board discovered evidence indicating
     that Ms. Campbell has directed campaign contributions and other expenditures of
     the Democratic PACs to influence "covered elections", in violation of the Single
     Committee Rule. Ms. Campbell denies that she has authority to authorize the
     financial decisions and/or expenditures of the Democratic PACs or that she has
     violated the Single Committee Rule.


AGREEMENT

  A. The Parties hereby desire to enter into this Settlement Agreement and agree as
     follows:

         1. Candidate Campbell will refrain from taking any action whatsoever to
            authorize and/or influence the financial decisions and/or expenditures of
            the Campaign and Finance Committee PACs until after May 15, 2007.

         2. Rep. Oliver, in his capacity as Treasurer to the Campaign PAC represents
            that he has authority to bind the officers, agents and staff of that PAC and
            further agrees that all officers, agents and staff of the Campaign PACs
            shall refrain from accepting or following any instructions from Candidate
            Campbell on matters relating to the financial decisions and/or
            expenditures of the Campaign PACs until after May 15, 2007.

         3. Mr. Weinberg, in his capacity as Treasurer of the Finance Committee PAC
            represents that he has the authority to bind the officers, agents and staff of
            that PAC and further agrees that all officers, agents and staff of the
            Finance Committee PACs shall refrain from accepting or following any
            instructions from Candidate Campbell on matters relating to the financial
            decisions and/or expenditures of the Finance Committee PACs until after
            May 15, 2007.

         4. Rep. Oliver, in his capacity as Treasurer to the Campaign PAC represents
            that he has authority to bind the officers, agents and staff of that PAC and



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           further agrees to provide the Ethics Board on a rolling basis with complete
           and detailed information concerning all expenditures already made by the
           Campaign PAC that are intended to influence any of the May 15, 2007
           primary elections. The information will be provided as soon as possible,
           but no later than May 24, 2007.

       5. The Ethics Board reserves the right to obtain additional recorded
          statements under oath and to issue Administrative Subpoenas, pursuant to
          its continuing investigation into all expenditures already made by the
          Campaign PAC that are intended to influence any of the May 15, 2007
          primary elections.

       6. Mr. Weinberg, in his capacity as Treasurer of the Finance Committee PAC
          represents that he has the authority to bind the officers, agents and staff of
          that PAC and further agrees to provide the Ethics Board on a rolling basis
          with complete and detailed information concerning all expenditures
          already made by the Finance Committee PAC that are intended to
          influence any of the May 15, 2007 primary elections, but no later than
          May 24, 2007.

       7. The Ethics Board reserves the right to obtain additional recorded
          statements under oath and to issue Administrative Subpoenas, pursuant to
          its continuing investigation into all expenditures already made by the
          Finance Committee PAC that are intended to influence any of the May 15,
          2007 primary elections.

       8. The Ethics Board will continue to monitor the expenditures of the
          Democratic Committee PACs under terms to be agreed with Rep. Oliver,
          in his capacity as Treasurer to the Campaign PAC, and Mr. Weinberg, in
          his capacity as Treasurer of the Finance Committee PAC.

B. In consideration of the above, the Ethics Board agrees not to pursue injunctive
   relief at this time. In addition, the Ethics Board agrees not to pursue any penalties
   or fines for any potential violations of the Single Committee Rule at this time, but
   reserves the right to pursue penalties and fines for specific expenditures of the
   Democratic PACs up to and including the date of this Agreement that the Board
   may determine upon further investigation constituted violations of the Single
   Committee Rule or other campaign finance laws

C. Other than as previously stated in Paragraph A.8 above, this Settlement
   Agreement contains the entire agreement between the Board and Candidate
   Campbell, Representative Oliver, in his capacity as Treasurer of the Campaign
   PAC and Mr. Weinberg, in his capacity as Treasurer of the Finance Committee
   PAC with regard to the matters set forth herein.




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   D. This Settlement Agreement shall become effective on execution.


                                                 By the Board:


Dated: _________________                         ______________________________
                                                 Richard Glazer, Esquire, Chair


Dated: _________________                         ______________________________
                                                 J. Shane Creamer, Jr., Esquire
                                                 Interim Executive Director


                                                 By the Candidate:


Dated: _________________                         ______________________________
                                                 The Honorable Carol Ann Campbell


Dated: _________________                         ______________________________
                                                 Gary Samms, Esquire


                                                 By the Campaign PAC:


Dated: _________________                         ______________________________
                                                 The Honorable Frank Oliver,
                                                 Treasurer


Dated: _________________                         ______________________________
                                                 Thomas Nocella, Esquire


                                                 By the Finance Committee PAC:


Dated: _________________                         ______________________________
                                                 Martin Weinberg, Esquire, Treasurer


Dated: _________________                         ______________________________
                                                 Walter Phillips, Esquire
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