Jacobs Report
Jacobs Report
The OIG investigation also determined that the Town’s former Finance and Budget Director Roy
Brown had a hand in the improper procurement. We established that Mr. Brown authorized a
$6,625.00 wire transfer to pay the balance due for the holiday party without determining whether
the purchase complied with the Town’s laws regarding procurement. He did not review the
invoice for the yacht charter, endeavor to learn the amount of the deposit, or otherwise
determine the total cost of the charter. As a result of these shortcomings, the Town illegally
procured a yacht charter for a holiday party for Town officials, staff, and guests that ultimately
cost approximately $440.63 for each person who attended.
In response to the preliminary version of this report, the Town reiterated the steps it had taken to
remedy its overall procurement shortcomings following a previous OIG investigation. It also
offered that the Town may have considered the purchase to fit an exclusion featured in the
Town’s Procurement Code. Although the OIG remains encouraged by the steps the Town has
taken to strengthen its procurement authority, it does not accept the Town’s effort to defend
those involved in the yacht charter purchase by reading the exclusion in an unreasonable way.
FINAL REPORT
OIG 23-018-M
September 5, 2024
SUMMARY
The OIG has concluded its investigation into an allegation that the Town of Pembroke Park’s (“Town’s”)
then-Mayor and current Commissioner Geoffrey Jacobs unlawfully contracted with a vendor for a
$10,575.00 yacht charter for the Town’s 2022 annual holiday party without first obtaining competitive
proposals. We substantiated the allegation.
The OIG’s investigation determined that Mayor Jacobs 1 made a non-refundable credit card payment of
$3,950.00 as a deposit and executed a contract with a yacht charter brokerage service (“the Brokerage”)
for the provision of a yacht charter for the annual holiday party the Town held for its officials, staff and
guests on December 21, 2022. This amounted to misconduct, 2 as only the Town Manager or his or her
designee could legally contract on behalf of the Town, and the then-Town Manager 3 had not delegated
that authority to Mayor Jacobs. The Town’s applicable code provisions required three written,
documented proposals and further required the Town Commission to select the vendor from among such
proposals. By making the payment and signing the contract himself, Mayor Jacobs selected the vendor
without complying with the procurement process as set forth in the Town’s ordinances, which constituted
additional misconduct.
Our investigation also determined that Mayor Jacobs involved the Town’s former Finance and Budget
Director Roy Brown in the procurement misconduct. We established that Mr. Brown authorized a
$6,625.00 wire transfer to pay the balance due for the holiday party without determining whether the
purchase complied with the Town’s laws regarding procurement. He did not review the invoice for the
yacht charter, endeavor to learn the amount of the deposit, or otherwise determine the total cost of the
charter, which would have established the Town’s legal requirements for the purchase.
Section 10.01 of the Charter of Broward County empowers the OIG to investigate misconduct and gross
mismanagement by any official or employee of either the Charter Government of the County or a
1 Although Geoffrey Jacobs is currently a Town Commissioner, this report refers to him as “Mayor” when referring to events that
occurred when he held that title and as “Commissioner” when referring to his OIG interview, which occurred after he no longer
held the title of “Mayor.”
2 The Broward County Charter defines “misconduct” as “any violation of the state or federal constitution, any state or federal
statute or code, any county or municipal ordinance or code; or conduct involving fraud, corruption, or abuse.” Section 10.01
A.(2).
3 The Interim Town Manager who currently manages the Town was not involved with the procurement of the 2022 annual
holiday party. This report refers to the individual who managed the town at the time as “the Town Manager.”
municipality within the County. It also empowers the OIG to investigate misconduct and gross
mismanagement by those that provide goods and services to the County or any of its municipalities
under contract for compensation. On her own initiative or based on a signed, verified complaint, the
Inspector General may find good cause and commence an investigation. As part of any investigation,
the Inspector General is empowered to subpoena witnesses; administer oaths; require the production of
documents and records; audit any program, contract, or operation of the County or any municipality; and
audit the operations or performance of any provider relating to its contract for compensation with the
County or any municipality.
The OIG is also empowered to issue reports, including recommendations; to require officials to provide
reports regarding the implementation of those recommendations; and to notify the appropriate civil,
criminal, or administrative agencies charged with enforcement. If there is no appropriate agency for
enforcement, the Inspector General may bring a quasi-judicial enforcement proceeding before an
administrative hearing officer.
In March 2019, Mr. Jacobs was elected as the Town’s Commissioner for District 3. In November 2020,
his fellow Commissioners appointed him as the Mayor. In April 2023, when the Commission selected a
new mayor, Mr. Jacobs was re-designated a Commissioner.
Roy Brown, Former Finance and Budget Director, Town of Pembroke Park
Mr. Brown began working for the Town as its Finance and Budget Director in June or July 2022. His
duties included procurement and approving the Town’s expenditures. He separated from the Town in
September 2023.
The Town Manager, or his or her designee, shall be the Town's Chief Purchasing Officer ("CPO")
The CPO shall serve as the principal officer for the contracting and/or purchase of goods and
services and shall have the authority to approve all purchases, contracts, change orders, and
purchase orders for the purchase of goods and services, provided they are in conformance with the
Procurement Manual, the law, and all applicable rules and regulations. The chief procurement officer
may delegate rights, powers, and authority vested in the CPO to subordinate procurement services
employees, or other Town staff, when deemed necessary by the chief procurement officer, provided
such staff shall comply with all applicable laws, ordinances, resolutions, rules and procedures
established by the Town. . . .
Final Report Ref. OIG 23-018-M
09-05-2024
Page 3 of 17
(a) Unauthorized purchases. No officer of the Town shall, except in cases of emergency as
specified herein, issue any oral or written purchase order, contract, or conduct open market
purchases in any manner unless specifically authorized by this article. The Town shall not be
bound by purchases made without proper authorization or in any unauthorized manner.
Except as provided in this division, it shall be unlawful for any Town Officer or employee
under the supervision of the Town Manager to order the purchase of any materials or supplies
or make any contract for municipal materials or supplies or services within the purview of this
division other than through the central purchasing organization, and the Town shall not be
bound by any purchase order or contract made contrary to the provisions of this division. . . .
(a) The Town Manager, or designee, may authorize the purchase of services or commodities in
an amount of ten thousand dollars ($10,000.00) or less without the approval of the Town
Commission.
(b) The purchase of services or commodities in the amount of greater than ten thousand dollars
($10,000.00), requires the prior approval of the Town Commission at a regular or special
meeting, except as may otherwise be provided in this article.
(c) The purchase of services or commodities in the amount of five thousand dollars ($5,000.00)
or greater shall be permitted only after written proposals from at least two (2) different sources
are received by the Town for consideration, and the Town approves the most responsible and
responsive proposal.
(d) The purchase of services or commodities in the amount of ten thousand dollars ($10,000.00)
or greater shall be permitted only after written proposals from at least three (3) different
sources are received by the Town Commission for consideration, and the Town Commission
approves the most responsible and responsive proposal. . . .
INVESTIGATION
Investigation Overview
This investigation originated from an allegation that, when he was the Town’s Mayor, Pembroke Park
Commissioner Geoffrey Jacobs unlawfully contracted with a vendor for the provision of a $10,575.00
yacht charter for the Town’s 2022 holiday party for staff. We substantiated the allegation and also
determined that then-Mayor Jacobs unlawfully procured this yacht charter by personally making a non-
refundable deposit with his Town-issued credit card and signing a contract without authority and without
ensuring that at least three written proposals from different vendors were presented to the Town
Commission for its consideration and selection. Furthermore, we found that the Town’s former Finance
and Budget Director, Roy Brown, engaged in misconduct by failing to ensure that the Town lawfully
procured the yacht charter before authorizing a $6,625.00 wire transfer for the final balance payment.
Final Report Ref. OIG 23-018-M
09-05-2024
Page 4 of 17
The OIG’s investigation involved the review of Town and vendor records, including but not limited to
emails, meeting agendas, meeting minutes, resolutions, ordinances, bank records, credit card records,
accounts payable process records, records for previous holiday parties, marketing materials, contracts,
and proposals. The OIG also interviewed several current and former Town employees and the
Brokerage’s president.
According to the National Institute of Governmental Purchasing (NIGP), competitive bidding is “[t]he
process of inviting and obtaining bids from competing suppliers, by which an award is made to the lowest
responsive bid from a responsible bidder meeting written specifications.” Competitive bidding
requirements protect the public by preventing public agencies from making arbitrary and capricious
awards or making awards based on personal preference. As noted in the American Bar Association’s
(ABA) Model Procurement Code, “Fair and open competition is a basic tenet of public procurement.
Such competition reduces the opportunity for favoritism and inspires public confidence that contracts are
awarded equitably and economically.”
Article V of the Town’s Code of Ordinances, titled “Procurement” and consisting of Sections 2-120 et seq.
(“Procurement Code”), specifies the legal requirements for the Town’s purchase of goods and services.
The Town Commission passed and adopted the Procurement Code upon second reading on October 13,
2021, by way of Town Ordinance No. 2021-006. Mayor Jacobs voted for and, as mayor, attested to
Ordinance No. 2021-006. (Exhibit 1)
• Section 2-122 of the Town’s Procurement Code reserves the duty of contracting on behalf of the
Town to the Town Manager or his or her designee, the chief procurement officer.
• Section 2-125 of the Procurement Code prohibits a Town officer from contracting or conducting open
market purchases on behalf of the Town unless Article V specifically authorizes the officer to do so.
• Finally, Section 2-128 of the Procurement Code dictates the process the Town is to follow when
procuring its goods and services, depending on purchase amount. That section allows the Town
Manager to authorize the purchase of goods and services in the amount of $10,000.00 or less. The
code permits purchases of $5,000.00 or greater only if the Town receives and considers written
proposals from at least two (2) different sources and approves the most responsible and responsive
proposal. That section also instructs that the Town Commission must provide prior approval of
purchases of $10,000.00 or greater at a regular or special meeting. Furthermore, the code only
permits such purchases if the Town Commission receives and considers written proposals from at
least three (3) different sources and approves the most responsible and responsive proposal.
The Town’s Procurement of a $10,575 Yacht Charter for its 2022 Holiday Party for Staff
On December 21, 2022, the Town hosted its annual holiday party aboard a yacht charter. According to
witnesses who attended, the party included music, dinner, and non-alcoholic beverages for the guests.
Final Report Ref. OIG 23-018-M
09-05-2024
Page 5 of 17
The holiday party invitation emails indicated that the party was open to Town officials, Town employees,
four others, and one guest each. (Composite Exhibit 2)
A review of the Town’s and Brokerage’s records reflected that planning for its December 21, 2022,
holiday party began on or about December 8, 2022. According to M.R., the president of the Brokerage,
J.B., the Town’s former Executive Assistant Chief of Police, 4 called her and requested a quote for 70
people. Between December 9, 2022, and December 16, 2022, M.R. and J.B. exchanged emails
reviewing different pricing, culminating in the lowest priced proposal of $10,575.00 to charter the Sun
Dream on December 21, 2022, for 40 guests. (Exhibit 3) The final proposal, variously referred to as an
“invoice” or a “quote,” was for a three-hour cruise, which included a menu ($2,800.00) and non-alcoholic
beverages ($1,000.00) for 40 guests, charter fees of $3,000.00, a fuel charge of $375.00, a dockage fee
of $700.00, a labor charge of $1,700.00, and gratuity of $1,000.00. For 40 guests, this came to
approximately $264.38 per person. M.R. reported to the OIG that 24 guests actually attended the event;
based on the reported attendance, the cost per person was approximately $440.63. 5
On December 16, 2022, J.B also received an email from a representative of the company that operated
the Sun Dream, which email attached a credit card authorization form and requested its completion and
submission along with menu choices. It also specified that the deposit was $3,950.00 and that the
balance was due Monday (December 19, 2022) by wire transfer. The Sun Dream representative copied
Mayor Jacobs and M.R.’s company, the Brokerage, on this email. (Exhibit 4) That same day, M.R. also
forwarded her copy of the email to J.B. and Mayor Jacobs. (Exhibit 5)
On December 17, 2022, Mayor Jacobs returned the credit card authorization form to M.R., authorizing a
non-refundable $3,950.00 charge to his Town credit card to charter the Sun Dream on December 23,
2022. 6 (Exhibit 6) On December 19, 2022, an email from DocuSign 7 confirmed that all parties had
completed the documents, which included the signature of “Mr. Mayor Jacobs” 8 affixed to a chartering
agreement with the Brokerage agreeing that “Mr. Mayor Geoffrey Jacobs” was hiring the Sun Dream at a
non-refundable cost of $10,575.00 on December 21, 2022, from 5 p.m. to 8 p.m. (Composite Exhibit 7)
On December 19, 2022, the Town also paid the remaining $6,625.00 balance through a wire transfer.
The Town’s former Finance and Budget Director, Roy Brown, authorized the wire transfer. According to
a December 19, 2022, email from the Town’s Accounts Payable/Purchasing Clerk to J.B., “We moved
forward” with the wire transfer after Mr. Brown spoke to Mayor Jacobs about it. (Composite Exhibit 8)
Our investigation determined that Mayor Jacobs engaged in misconduct by procuring a yacht charter for
the Town’s annual holiday party without abiding by the mandates of the Town’s Procurement Code.
4 J.B. also served as Executive Assistant to the Commission and Events Coordinator.
5 This calculation does not include deejay services of $675.00 procured from another vendor.
6 As the discussions, proposals, and contract were for a cruise on December 21, 2022, the December 23, 2022, date on the
electronic agreements with electronic signatures. Retrieved on July 24, 2024, from
https://en.wikipedia.org/wiki/Docusign#:~:text=Docusign%2C%20Inc.%20is%20an%20American,million%20clients%20in%2018
0%20countries.
8 The agreement was between Star Vision Events LLC, and “Mr. Mayor Geoffrey Jacobs.”
Final Report Ref. OIG 23-018-M
09-05-2024
Page 6 of 17
Specifically, between December 17, 2022, and December 19, 2022, Mayor Jacobs unlawfully selected
and contracted with a yacht brokerage service for the provision of the yacht charter on December 21,
2022.
To begin with, according to the Procurement Code, only the Chief Procurement Officer, that is, the Town
Manager or his designee, was authorized to contract on behalf of the Town. As the Town Manager had
not designated this title to another individual, he served as the Chief Procurement Officer, and he
informed the OIG that he had no control over the procurement of the yacht charter and that Mayor
Jacobs did not tell him about it.
As the cost of yacht charter exceeded $10,000.00, the Procurement Code directed that a proper
procurement required the Town Commission to review written proposals from at least three different
vendors for the service and to approve the most responsible and responsive proposal at a regular or
special meeting. But that did not happen here. Instead, the Town’s records showed that Mayor Jacobs
himself, on behalf of the town, selected and contracted with the Brokerage.
We spoke to Commissioner Jacobs about his involvement in the procurement of the yacht charter. His
explanations lacked credibility, as they contradicted the Town’s records as well as explanations that
other members of Town staff offered, which were consistent with each other.
For example, according to Commissioner Jacobs, J.B. provided the Town Commission with proposals
from different companies, which names he could not recall. According to him, the Commission voted on
the holiday cruise. He offered that he would not be surprised if the Town did not have that information,
as the Town could not find other records, either.
No other Town official or employee we spoke to recalled that the matter came before the Commission –
including J.B., who said that it did not come before the Commission because there was not enough time.
The Town Clerk substantiated that there was no item on any Commission meeting agenda related to the
December 2022 Town holiday party other than the approval of a holiday party budget of $8,000.00 as
part of the Town’s budget for fiscal year 2023. (Composite Exhibit 9)
In other inherently incredible statements, Commissioner Jacobs told the OIG that (1) he had no idea who
used his credit card to make the $3,950.00 deposit, (2) he had no recollection of anyone telling him on
December 18, 2022, 9 that his card was going to be used to pay it, and (3) “They had me sign one of the
credit card receipts.” He also said that he had spent half the year in Las Vegas as an airline pilot, so it
was J.B. who handled everything for the holiday cruise, and that the OIG should be asking J.B. and Mr.
Brown how the event came about because he (Commissioner Jacobs) just dealt with what came before
the Commission.
Again, email correspondence we reviewed directly disputed Commissioner Jacobs’s claims of ignorance.
These emails showed that the Sun Dream’s representative sent an email to J.B., copying Mayor Jacobs
and the Brokerage, on Friday, December 16, 2022. That email included, “The deposit is $3950. [M.R.]
will send you the contract to be signed along with the balance due Monday morning by wire transfer.
Need copy of front and back of card and driver’s license as well.” As noted above, the email attached a
9The transaction date on the credit card statement was December 18, 2022; the date on the Sun Dream Credit Card
Authorization was December 17, 2022. (Exhibit 6)
Final Report Ref. OIG 23-018-M
09-05-2024
Page 7 of 17
..
credit card authorization form to be completed. (Exhibit 4) Shortly thereafter, M.R. forwarded that email
directly to both J.B. and Mayor Jacobs. (Exhibit 5) On Saturday, December 17, 2022, Mayor Jacobs
forwarded the credit card authorization form, which gave his authorization, as a representative of the
Town, to charge his Town credit card a non-refundable initial deposit amount of $3,950.00 for a charter
on December 23, 2022. 10 (Exhibit 6)
1. --"G'--'eo=ff
""r'-'e'--'y'--'J'--'a"'c"-o=b"-s_ _ _ _ _ . re presenting The Town o f Pe m bro ke Park
(Print Na me)
authorize Sun Dream Yacht Charters. Inc. l o c harge the fo llowing cred it card
Account # : ■■■■■■■■------------------------
Expiration Dal e =- - • • 1 - - - - - - - - - - - - - - - - - - - - - - - - - - -
House or PO Bo x num ber o f Billing Ad dress 3 150 SW 5200 Ave. Pe m bro ke Park. FL
Other. $._ _ _ _ _ __
I agree tha t my liability fo r the c harges will no t be waived, and I a gree to be held p e rsonally
liable in the e vent t hat the c redit card com pany fa ils to p a y fo r the fu ll a mount o f the
charges. These charges are irre vocab ly due l o Sun Drea m Yacht C harters. Inc .
OIG Figure 1: Credit Card Authorization Form that Mayor Jacobs sent by email to
M.R., the Brokerage’s president, on December 17, 2022. (Exhibit 6, p. 4)
Later that day, the Brokerage emailed Mayor Jacobs, reiterating its need to have copies of the photo
identification and credit card. Mayor Jacobs replied with the requested copies attached, including the
front and back of his credit card. (Exhibit 10) Thereafter, M.R. wrote to Mayor Jacobs, stating that he
10 See footnote 6.
Final Report Ref. OIG 23-018-M
09-05-2024
Page 8 of 17
had completed the credit card authorization form with the wrong date for the event, asking him to sign the
electronic document with the contract and invoice, and reminding him that the balance needed to be
wired on Monday morning. In his Sunday, December 18, 2022, reply, the Mayor did not deny that he
executed the credit card authorization form or that he provided the copy of his credit card and requested
M.R. to deal with his “assistant” for further assistance. He copied J.B. in this reply to M.R. (Exhibit 11)
On Monday, December 19, 2022, DocuSign forwarded the completed contract and invoice to Mayor
Jacobs on M.R.’s behalf. Both documents specified that the price for the charter was $10,575.00 and
were signed by “Mr. Mayor Jacobs” on that day. (Composite Exhibit 7)
In his interview, Commissioner Jacobs said that he “probably” electronically signed the contract with the
Brokerage, because it needed to be signed for a deposit on the dinner. He maintained that things were
forwarded to him to sign and approve and that he relied on employees to do the right thing. He finally
recalled that Mr. Brown asked or told him that the Town needed to do a wire transfer for the holiday
event’s deposit; he said he relied on Mr. Brown for procurement matters and to ensure that everything
was done correctly. In Commissioner Jacobs’s view, Town employees should have reached out to him if
the procurement was not done properly. He told us he did not know anything about the financial aspect
or the “numbers” of the 2022 holiday event or that the 2022 holiday event exceeded $10,000.00.
But, again, our investigation’s findings conflicted with his assertions. The OIG observed that, by
December 17, 2022, Mayor Jacobs was working directly with the president of the Brokerage and the
representative of the yacht charter company that owned the Sun Dream – not with, through, or at the
behest of Town staff members. (Exhibit 6) And, by December 19, 2022, at 12:50 p.m., it was the Mayor
who electronically signed the contract and invoice, both of which made clear to him that the holiday event
was costing the Town over $10,000.00. (Composite Exhibit 7) M.R., the Brokerage’s president,
considered Mayor Jacobs the decisionmaker for the event, observing that “[e]verything was through him.”
Based on the OIG’s review of the Town’s internal accounts payable register, detail, and audit records,
staff did not enter the December 19, 2022, $6,625.00 payment until January 10, 2023, when the
Accounts Payable/Purchasing Clerk input the “Create Process” action and additional payable entries. 11
On January 12, 2023, the former police chief and Mr. Brown respectively performed “Department Head”
and “Finance Director” actions. On January 17, 2023, the Town Manager performed a “Town Manager”
action. In conjunction with Commissioner Jacobs’s statement that Town staff should have reached out to
him if the yacht charter had not been procured correctly, these after-the-fact entries demonstrate that it
was the Mayor and not staff who led the procurement.
We also interviewed J.B. about the procurement. She explained that Mayor Jacobs, the former Vice
Mayor, and she began planning the event approximately three or four weeks before the event took place
and that it was “last minute.” She told the OIG that Mayor Jacobs authorized her to obtain quotes for a
dinner cruise. She initially said she believed she obtained different quotes from different boats and
emails from different yacht charter companies but did not recall the other vendors’ names. She later
recalled that a person named M.R. dealt with different yacht charter companies and provided her with
quotes from different companies for the date on which the event was to be held.
11 There was no associated invoice number for this expenditure; the detail referred to it only as, “Balance for Yacht Charter for
Holiday Party.” The record also noted that $3,950.00 was “Paid on Mayors Town Credit Card on December 17, 2022.” (Exhibit
12, p. 9)
Final Report Ref. OIG 23-018-M
09-05-2024
Page 9 of 17
M.R., the Brokerage’s president, provided the OIG with “all” three quotes the Brokerage worked on for
the Town’s 2022 holiday party dinner cruise, as shown in OIG Table 1:
OIG Table 1:
Proposal Pricing for Town Holiday Dinner Cruise
December 21, 2022
(Exhibit 13)
Our investigation determined that Mayor Jacobs received and reviewed only one vendor’s negotiated
proposal from the Brokerage, the one for $10,575.00. (Exhibits 3, 13) Instead of ensuring that the Town
had obtained proposals from at least two other vendors or even from two other sub-contractors such as
the yacht charter company that owned the Sun Dream, Mayor Jacobs improperly selected and
contracted with the Brokerage between December 17, 2022, and December 19, 2022. That is, in the
absence of Commission selection or approval at a regular or special meeting and without the
authorization of the Town Manager as the Chief Procurement Officer, Mayor Jacobs unlawfully selected
M.R.’s company by making a partial, non-refundable deposit payment on and executing a contract for the
yacht charter on behalf of the Town. In doing so, he violated sections 2-122, 2-125, and 2-128 of the
Town’s Procurement Code.
The Former Finance and Budget Director’s Misconduct in the Procurement of the Yacht Charter
Our investigation determined that Mayor Jacobs also involved Mr. Brown in the yacht charter’s unlawful
procurement.
As Mayor Jacobs used his Town-issued credit card on Saturday, December 17, 2022, to pay the
$3,950.00 deposit, a $6,625.00 balance remained. The Brokerage demanded the Town pay the
remaining balance on Monday, December 19, 2022, two days before the event. (Exhibit 11) Town
records showed that Mr. Brown authorized, and the Town issued, a wire transfer for $6,625.00 on
December 19, 2022, to pay the remaining balance. (Composite Exhibit 8) Given the lack of any
indication that the Town Commission approved the procurement of the yacht charter, let alone
considered proposals from at least three vendors, we interviewed Mr. Brown about the circumstances of
his authorization of the wire transfer.
Mr. Brown told the OIG that Mayor Jacobs was the host and the person managing the holiday party. The
Mayor communicated what he wanted to do for the party to J.B., and J.B. then communicated with Mr.
Brown. When the issue of payment for the holiday party reached Mr. Brown, the vendor needed
payment of the balance before the end of the day, as the party was scheduled to take place soon. He
12 This proposal included a boarding time of 5 p.m. and a disembarkation time of 9 p.m., however, the itemized line titled,
said he questioned why the payment request was coming in at the last minute. He recalled having a
conversation with a person whose identity he did not recall who advised him that Mayor Jacobs was in
communication with the vendor. He also recalled a conversation with Mayor Jacobs about the urgency
of the payment approval. In one way or another, Mayor Jacobs communicated to him through the
Accounts Payable/Purchasing Clerk that a wire was going to be placed in the system for his approval.
The Accounts Payable/Purchasing Clerk communicated to Mr. Brown that the wire had to be approved
before 5:00 pm.
Mr. Brown recalled approving the wire transfer for $6,625.00 but said he did not know whether the 2022
yacht holiday party was presented to the Town Commission for its approval. He said he did not know
whether three written proposals were obtained for the 2022 yacht holiday party before he began working
for the Town 13 and did not believe there were appropriate bidding processes in this case, because
everything was rushed.
Mr. Brown said he may have inquired about having two quotes since the $6,625.00 amount was over a
$5,000.00 threshold. The answer he received was, “This is what the Mayor wants.” Mr. Brown believed
that the Town paid the vendor because the direction came from Mayor Jacobs. He explained, “Despite
the process, I think, you know, it’s like, hey, this is the Mayor. This has to be done. You know, the party
is in three days. This is a rush. In order for us to have anything, this has to be done.”
Mr. Brown also told us that, at the time, he did not know the total invoice was $10,575.00. He said he
only knew that the wire transfer was a partial payment and did not know the amount of the first payment.
He acknowledged that he did not see the invoice until after he approved the wire transfer. He said he did
not recall what he reviewed, if anything, in tandem with the wire transfer authorization.
He went on to say that staff did not follow a lot of the Town’s policies because it essentially operated as if
Mayor Jacobs were the Town Manager. Mr. Brown said that, while he did not fear losing his job for not
following directions, he was afraid of repercussions such as getting berated by Mayor Jacobs at a Town
Commission meeting.
The OIG acknowledges that other Town employees previously described a similar atmosphere within
Town Hall, but the fact remains that Mr. Brown, as the Town’s Finance and Budget Director, authorized a
$6,625.00 wire transfer without so much as reviewing the associated invoice, let alone confirming that
the purchase complied with the Town’s Procurement Code. Although Mr. Brown said he believed the
purchase was under the $10,000.00 threshold, he also said he knew the $6,625.00 was a partial
payment. Thus, he still knew that the procurement was unlawful, because the Procurement Code for a
purchase of $5,000.00 or greater required the Town Manager or designee to consider written proposals
from at least two different vendors and to approve the most responsible and responsive proposal.
Mr. Brown’s conduct after speaking to Mayor Jacobs, which included authorizing the payment without
making further inquiries about the procurement, went against what one would expect from the Town’s
finance and budget director. This disregard for the Town’s purchasing laws amounted to misconduct on
Mr. Brown’s own part.
13 Mr. Brown’s employment with the Town began in June or July 2022, several months prior to the day he authorized the wire
transfer of $6,625.00.
Final Report Ref. OIG 23-018-M
09-05-2024
Page 11 of 17
INTERVIEW SUMMARIES
As a part of the investigation, OIG investigators conducted several interviews. The statements made in
significant interviews are summarized below.
No one has ever held the procurement officer job title. The Town’s Finance Department is
responsible for the Town’s procurement.
Prior to his becoming a Commissioner, the Town hosted holiday events annually and has continued
hosting them during his time as an elected official. In 2020, he went to GG’s Waterfront restaurant,
met with GG’s event coordinator, and made arrangements with her for the annual holiday party. He
did not go to other venues because GG’s was a nice place, and it had provided a great service to the
Town the year before. He brought the item to the Commission. The Commission voted on and
approved it, so the Town held its holiday lunch at GG’s for a second time in 2020.
The following year, 2021, he was provided with a few places to consider. The Commission voted on
GG’s and kept it the “same.”
In 2022, he spent half of the year in Las Vegas as an airline pilot, so J.B. handled everything. He
would have kept the event at GG’s, but Town employees wanted something different. J.B. presented
at a Commission meeting a dinner cruise, including a couple of different companies that the Town
looked at for the chartering. He did not remember the names. The Town should have that
information, but he would not be surprised if it did not as the Town cannot find other records either.
The Commission did not decide on the vendor. The Events Coordinator [J.B.] put it before the
Commission, or the Finance Director. Moreover, the Commission did not ask further questions about
the event or the event’s options. The Commission discussed the event and voted to do it. He did not
know the date of the meeting at which the Commission discussed the event. It could have taken
place during a workshop, a special Commission meeting, or a regular Commission meeting.
The invoice and the payments to the Brokerage for the 2022 holiday party all goes through the
Finance Department, and Commissioners have no access to wire transfers. Also, the Town used his
Town purchasing card for “everything.”
Initially, Commissioner Jacobs said he had no idea who used his card to make the $3,950.00 deposit
and had no recollection of anyone telling him on December 18, 2022, that his card was going to be
used to pay it. However, he later stated, “They had me sign one of the credit card receipts.”
He “probably” DocuSigned the contract between the Brokerage and himself because it needed to be
signed for a deposit on the dinner. He did not ask questions, because they said they needed to get it
done. “They” would give him things to approve and sign, and he relied on employees to do the right
thing. In this instance, he relied on Mr. Brown for procurement and for him to ensure that everything
Final Report Ref. OIG 23-018-M
09-05-2024
Page 12 of 17
was right. Town employees should have reached out to him (Commissioner Jacobs) if it was not
done properly. However, no one ever indicated to him that the yacht chartering was in violation of
the Procurement Code.
Commissioner Jacobs did not know anything about the financial aspect or the “numbers” of the 2022
holiday event. The Finance Department took care of it. The OIG should be asking J.B. and Mr.
Brown how the event came about because he (Commissioner Jacobs) just dealt with what came
before the Commission.
Initially, Commissioner Jacobs did not recall discussing the 2022 holiday event with Mr. Brown.
However, he then recalled his only communication with Mr. Brown was about authorizing a wire
transfer. Mr. Brown asked or told him that the Town needed to do a wire transfer for the holiday
event’s deposit.
He did not know the 2022 holiday event went over $10,000.00. J.B. took care of the event, Mr.
Brown took care of the money, and the Town Manager was supposed to be managing the Town.
Mr. Brown joined the Town as its Finance and Budget director on July 14, 2022, and left the Town’s
employ on September 1, 2023. His main job was to monitor the Town’s finances, including oversight
of the payroll, accounts receivables and payables, payroll, audit, and debt and treasury management.
His duties also included budgeting, analyzing, and approving anything with a cost to the Town. Mr.
Brown’s position did not include procurement when he first joined the Town. However, he later
realized that procurement did, in part, fall under his umbrella.
Mr. Brown twice participated in procurement selection processes. He confirmed that, at the end, the
Town Commission had to approve the vendor selection.
After the Town awarded a vendor a contract, the vendor performed the required service or provided
the required goods and submitted an invoice. The Town’s Accounts Payable/Purchasing Clerk
reviewed the invoice and the agreement to make sure that the vendor met its contractual obligations
and looked at the encumbrance. A draw was then be made on the purchase order (PO) until it was
reduced to zero. Mr. Brown reviewed and approved the request for payment after the Accounts
Payable/Purchasing Clerk’s review. The Town Manager then conducted his review and hit “the
green check mark.” The Town Commission provided final approval. The Town Commission
reviewed and approved a check register reflecting the checks to be drawn from the Town’s account
before they can be issued.
The Town held an annual holiday party in 2022. Mr. Brown did not know if anyone presented it to the
Town Commission for their approval, as required by the Town’s Procurement Code. He recalled the
message being, “They [the vendors] have to be paid, because the event is next week.”
Mr. Brown did not know if three written proposals were obtained for the 2022 yacht holiday party
before he began working for the Town, as required by the Town’s code. He did not know details
Final Report Ref. OIG 23-018-M
09-05-2024
Page 13 of 17
about its planning, selection, and arrangement. He did not believe there were significant or
appropriate bidding processes because everything related to it was rushed.
By the time the issue of payment for the holiday party reached him, the holiday party was coming up,
and the vendor needed the payment before the end of the day. Mr. Brown questioned why the
payment request was coming in at the last minute, which led to a conversation with someone whose
identity he did not recall. During that conversation, Mr. Brown learned that Mayor Jacobs was in
communication with the vendor.
He was the host and the person managing the holiday party. He communicated what he wanted to
do for the party to J.B. J.B. then communicated with Mr. Brown.
Brown did not attend the party but heard from someone in the Town that about 25 people attended
the party.
Mr. Brown recalled approving a wire transfer for $6,625.00. At the time, he did not know that the total
invoice was $10,575.00. He only knew that the wire transfer was a partial payment. He did not know
that, given the amount of the first payment, the total amount went over the $10,000.00 threshold.
The first time Mr. Brown saw the agreement between Mr. Jacobs and the Brokerage was at his
interview with the OIG. He had seen the invoice in the past. It was after he approved the $6,625.00
wire transfer.
Mr. Brown may have inquired about having two quotes since the $6,625.00 amount was over a
$5,000.00 threshold. The answer he received was, “This is what the Mayor wants.” Mr. Brown
believed that the Town paid the yacht chartering vendor because the direction came from Mayor
Jacobs. Mr. Brown explained, “Despite the process, I think, you know, it’s like, hey, this is the Mayor.
This has to be done. You know, the party is in three days. This is a rush. In order for us to have
anything, this has to be done.”
Mr. Brown also explained that in one way or another, Mayor Jacobs communicated to him through
the Accounts Payable/Purchasing Clerk that a wire was going to be placed in the system for his
approval. She communicated to Mr. Brown that the wire had to be approved before 5:00 pm.
Mr. Brown also recalled having a conversation with Mayor Jacobs about the urgency of the payment
approval.
Mr. Brown did not fear losing his job if he did not follow directions. However, he was afraid of the
repercussions of following his gut instinct, such as getting berated at a Town Commission meeting.
Mayor Jacobs was going to pick on him from the dais during meetings.
The Town did not follow a lot of its policies because it essentially operated as if Mayor Jacobs was
the Town Manager. The 2022 holiday party was an example of that.
Final Report Ref. OIG 23-018-M
09-05-2024
Page 14 of 17
J.B. began her employment with the Town as the Commissioners’ Executive Assistant in August
2019. She was terminated on May 12, 2023.
As Executive Assistant, J.B.’s duties included attending meetings, including Commission meetings,
scheduling the Commissioners’ meetings and trips, and sending out letters. She was also the Town’s
Events Coordinator. At first, she planned the events with the Mayor at the time; she and Mayor
Jacobs were involved in the planning, selecting, and arranging of the Town holiday party once he
became Mayor. Mayor Jacobs and the other Commissioners reviewed the events. Following a
transfer to the Town’s police department, J.B. served as Executive Assistant to the Chief of Police
and Accreditation Manager.
The Town did not have a chief procurement officer. For procurement, the Town followed the
procedure that the Finance Department put in place with the Commission. For the holiday parties
that the Town held every year, J.B. planned the event, put in a purchase order (“P.O.”) request,
obtained quotes subject to the cost of the event, and presented them to the Commission. Once the
Town Commission gave the approval, there was a P.O. process that took place through the Finance
Department. Once the Finance Department approved, J.B. continued planning the event.
In 2022, the holiday party was held on a boat. Planning for this party began approximately three to
four weeks before the event took place. J.B., Mayor Jacobs, and the former Vice Mayor were
involved in the planning, which was last minute. Town employees wanted something different, where
they could bring their spouses. After obtaining Mayor Jacobs’s authorization, J.B. obtained different
quotes from different boats.
The Town’s Accounts Payable/Purchasing Clerk told J.B. to make sure she had additional quotes,
and she did. J.B. did not recall the names of the vendors from which she sought the other quotes but
recalled researching online what type of yacht would hold a given amount of people as well as the
food cost. At first, J.B. believed emails with quotes from different yacht charter companies existed.
However, she later recalled that a person named M.R. dealt with different yacht charter companies
and provided J.B. with different quotes for the event date. J.B. believed that M.R. provided her with
the different quotes through email, and that the Town went with the cheapest quote.
J.B. recalled knowing that she had to get “two additional quotes,” and indicated she got them in
writing from M.R. However, no one presented them to the Town Commission in a meeting as there
was no time to do so. J.B. indicated, “Everything was so rushed because the holiday party needed to
be done.”
J.B. acknowledged that the Town did not follow its Procurement Code.
M.R. was the president of a yacht charter brokerage service, the Brokerage. Ordinarily, clients
reached out to the Brokerage and provided information about their needs and the number of guests
Final Report Ref. OIG 23-018-M
09-05-2024
Page 15 of 17
for an event. The Brokerage researched and provided a few yachts that would fit the client’s needs
and the pricing for each. Normally, each yacht charter company offered different menu options that
came with different prices per person. The client chose the yacht and then went to see it. If the client
liked it, the deal moved forward. The Brokerage signed an agreement with the client and a sub-
contractor agreement with the company that owned the yacht. The Brokerage generally received
payment from the client and then paid the yacht company.
J.B. initially contacted the Brokerage by telephone for a quote for 70 people, which she provided to
J.B. M.R. believed J.B. told her she was reaching out to other companies as well.
M.R. did not recall if she provided the Town with options from three different yacht charter
companies, like she normally did, because December was a busy month. 14 She did not recall if only
one or two yachts were available on the date the Town had picked for its holiday party.
J.B. considered the quote for 70 people too high, so she requested pricing for 50 people, and
subsequently for 40 people. Ultimately, J.B. informed M.R. that the Town only had a $10,000 budget.
M.R. did not provide J.B. or Mayor Jacobs written proposals, quotes, or estimates from at least three
different sources. She provided different pricing for 70, 50, then 40 people.
M.R. considered Mayor Jacobs the decisionmaker, indicating that, “Well, the Mayor. Everything was
through him.” M.R. did not come to the Town to make a presentation at a Town Commission
meeting. Like with other clients, M.R. met J.B. and Mayor Jacobs at the yacht in advance, so they
could see if it was what they wanted.
In accordance with Section 10.01(D)(2)(a) of the Charter of Broward County, preliminary copies of
this report were provided to the Town of Pembroke Park and any implicated parties for their
discretionary written responses. The OIG received a written response from the Town. This response is
attached and incorporated herein as Appendix A.
In its response, through its Acting Town Manager, the Town acknowledged the gravity of the
shortcomings we identified and reiterated the steps it has taken to address the Town’s overall
procurement deficiencies since the OIG issued its Closing Memorandum re: The Town of Pembroke
Park Lacks Adequate Authority to Control its Purchasing Card Expenditures, Ref. 22-007-M. These
steps included not only adopting a Travel Reimbursement Policy and strengthening the Town’s p-
card controls but also included adopting a Purchasing Manual Policy on November 8, 2023. The
Town also reported having recently reclassified a Town employee as a dedicated purchasing agent
who has received the requisite training and certification for her new duties.
Although we remain encouraged by the Town’s progress, we are disappointed by the Town’s attempt
to excuse then-Mayor Jacobs’s and Mr. Brown’s misconduct by offering that, in procuring the yacht
14 Following her OIG interview, M.R. forwarded the three proposals that the Brokerage had forwarded to the Town. (Exhibit 13)
Final Report Ref. OIG 23-018-M
09-05-2024
Page 16 of 17
charter, the Town may have been operating under section 2-125(d)(21) of its procurement code,
which excludes “[p]urchase for services and facilities at hotels, motels, restaurants and similar
facilities for Town sponsored events.”
This suggestion is not only disputed by the Town’s policies and by the individuals we interviewed, but
it also defies the entire spirit of competitive bidding in government procurement.
Our first observation regarding this suggestion is that it is unlikely that anyone involved believed that
the procurement of this holiday party met this exclusion, given that other holiday parties routinely
went before the Town Commission for approval before and after 2022.
Although the mandatory commission approval amount threshold and the competitive solicitation and
selection processes do not apply to purchases listed in section 2-125, the exclusionary language was
not intended to act as de facto permission for a Town official or employee to make a purchase that he
or she felt fit the definition of an exclusion without so much as an approval process. In fact, part D of
Section III of the Town’s Purchasing Manual now specifically instructs:
Moreover, the Town’s suggestion that those involved in the improper procurement may have
operated under section 2-125(d)(21) is directly contradicted by the Town employees involved and
then-Mayor Jacobs, themselves. As discussed above, when we interviewed them, they did not tell us
that they operated under section 2-125(d)(21) of the procurement code. Generally, the employees
told us that there was no time to conduct a proper procurement and agreed the Town did not follow
proper procurement procedures because the purchase did not go before the Commission for
approval. On the other hand, then-Mayor Jacobs incorrectly told us that the purchase did go before
the Commission and was approved.
But most unsettling is that the Town’s suggestion erodes public confidence in the belief – and
expectation – that local governments award contracts equitably and economically. A plain reading of
section 2-125(d)(21) shows that the types of purchases envisioned in this exclusion are those
facilities and services that establishments such as hotels, motels, and restaurants offer for Town-
sponsored events at the establishments. For instance, if the Town were to appropriately sponsor a
meeting at a hotel, the exclusion would arguably apply to the rental of the meeting room and
whatever services the hotel offered. To accept the Town’s suggestion would be to accept as
reasonable that (1) a yacht charter is similar to a hotel, motel, or restaurant; (2) such an extravagant
holiday party for Town officials, staff, and guests serves a public purpose; and (3) the purchase of the
yacht charter for the extravagant holiday party does not need the safeguards afforded by proper
procurement procedures.
We do not accept the Town’s effort to defend those involved by reading the exception in an
unreasonable way.
Final Report Ref. OIG 23-018-M
09-05-2024
Page 17 of 17
CONCLUSION
The OIG has concluded its investigation into an allegation that Pembroke Park’s then-Mayor and current
Commissioner Geoffrey Jacobs engaged in misconduct by unlawfully contracting with a yacht charter
brokerage services company for a $10,575.00 yacht charter for the Town’s 2022 Holiday Party.
We substantiated the allegation, determining that Mayor Jacobs made a non-refundable credit card
payment of $3,950.00 as a deposit and executed a contract with a yacht charter brokerage service for
the provision of a yacht charter for the annual holiday party the Town held for its officials, staff, and
guests. This amounted to misconduct, as only the Town Manager or his or her designee could legally
contract on behalf of the Town, and the Town Manager had not delegated that authority to Mayor
Jacobs. Mayor Jacobs also committed misconduct when he failed to ensure that the Town Commission
itself selected a vendor from among written proposals from at least three (3) different sources, as
required by the Town’s Procurement Code.
Additionally, the OIG’s investigation found that the Town’s former Finance and Budget Director Roy
Brown also violated the Procurement Code. We found that he authorized a $6,625.00 wire transfer to
pay the balance due for the holiday party without determining whether the purchase complied with the
Town’s laws regarding procurement. He did not review the invoice for the yacht charter, endeavor to
learn the amount of the deposit, or otherwise determine the total cost of the yacht charter, which would
have informed him of what needed to be done to comply with the Town’s Procurement Code.
Here, through Mayor Jacobs and Mr. Brown’s misconduct, the Town illegally procured a holiday party for
officials, staff, and guests that cost approximately $440.63 for each person who attended. It is not the
prerogative of any local government official or staff to knowingly use taxpayer funds to make a purchase
that does not fully comply with the law. Each individual who has the power to expend public money must
exercise that power with due care.
OIG 23-018-M
EXHIBIT 1
ORDINANCE NO. 2021-006
WHEREAS, Article VIII, Section 2, Florida Constitution, grants municipalities the power
to conduct municipal government, perform municipal functions and render municipal services; and
WHEREAS, Section 166.021, Florida Statutes, referred to as the Municipal Home Rule
Powers Act, grants all municipalities the expansive home rule power contemplated by the Florida
Constitution; and
WHEREAS, the Town of Pembroke Park (the "Town") finds it in the best interest of the
Town to revise its Procurement Code in order to streamline and delineate procurement procedures
and to ensure that the Procurement code is up to date and in compliance with local, state and federal
regulations.
ARTICLE V. - PROCUREMENT
Sec. 2-120. - Purpose. The Town wishes to provide for the purchase of the highest quality and best
value of goods and services at fair and reasonable cost, and ensure equitable treatment of entities doing
business with the Town. The Town's procurement code shall:
(b) Encourage and promote fair and equal opportunity for all entities doing business with the Town;
(c) Obtain goods and services of good quality and appropriate quantity at fair and reasonable cost
for the Town;
(d) Permit the continued development of procurement policies and procedures through the
promulgation of internal procedures (Procurement Manual), containing administrative regulations
and internal processes of procurement;
(e) Foster effective broad-based competition within the free enterprise system; and,
(f) Provide safeguards for the maintenance of a procurement system of quality and integrity.
Sec. 2-121. Definitions. The following words, terms and phrases, when used in this article, shall have the
meanings ascribed to them in this section, except where the context clearly indicates a different meaning:
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Town of Pembroke Park
Ordinance No. 2021-006
benefits; a variety of arrangements whereby two (2) or more public entities purchase from the same
supplier or multiple suppliers using a single solicitation. Cooperative procurement efforts may result in
contracts that other public entities may "piggyback".
Debarment. Permanent prohibition of a vendor or contractor engaging in future procurement actions
with the Town.
Design-build contract. A single contract with a design-build firm for the design and construction of a
Town construction project.
Designee. An authorized representative of a person holding a position of authority.
Emergency purchase. A purchase made due to an unexpected and urgent request where health and
safety or the conservation of public resources is at risk.
Firm. Any corporation, partnership, individual, sole proprietorship, limited liability company, joint
stock company, joint venture, governmental body or other legal entity.
Goods. Anything purchased other than services or real property.
Internal procedures of procurement. Those appropriately promulgated directives having general or
particular applicability designed to implement or interpret this article, or describing organization,
procedure, processes, or practice requirements as prescribed by the chief procurement officer. Such
directives shall be included in the Town's Procurement Manual.
Invitation to bid {1TB). The solicitation document used for soliciting competitive sealed bids for goods
or services.
Invitation to negotiate (/TN). All solicitation documents, regardless of medium, whether attached to or
incorporated by reference in solicitations for responses from firms that invite proposals from interested
and qualified firms so the Town may enter into negotiations with the firm(s) determined most capable of
providing the required goods or services.
Piggyback. A form of intergovernmental purchasing in which the Town will be extended the pricing,
terms, or conditions of a competitively solicited contract entered into by another public entity; also referred
to as accessing another public entity's contract.
Procurement. All functions pertaining to buying, purchasing, renting, leasing, contracting for, or
otherwise acquiring any goods, supplies, services, professional services, capital improvement and
construction projects, including description of requirements, solicitation and selection of sources,
negotiations, preparation, award and execution of contracts and orders. Procurement may also include
the combined functions of purchasing, inventory control, transportation, receiving, inspection,
storekeeping, salvage and disposal operations.
Procurement Manual. The administrative regulations which implement this article and the internal
procedures of procurement services and describes rules, regulations, policies and procedures to be
followed by procurement services and the departments it serves.
Professional services. Services, the value of which is substantially measured by the professional
competence of the person performing them, and which are not susceptible to realistic competition by cost
of services alone, rendered by members of a recognized profession or possessing a special skill. Such
services are generally acquired to obtain information, advice, training, or direct assistance. Professional
services shall include, but not be limited to, services customarily rendered by architects, engineers,
surveyors, certified public accountants, financial experts, attorneys, planners, lobbyists, and consultants.
Proposal. The response to a competitive solicitation that addresses a proposer's experience,
qualifications, approach and other factors that may be required by the Town in the solicitation documents.
Public entity. A county or municipal government, school board, school district, authority, special
taxing district, other political subdivision, or any office, board, bureau, commission, department, branch,
division, or institution thereof.
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Town of Pembroke Park
Ordinance No. 2021-006
Purchase order (PO). A document, including electronic document, by which the Town acquires
goods and services at a stated price, specifying all the terms and conditions of a proposed transaction,
such as a description of the requested items, delivery schedule, terms of payment, and transportation.
Request for information (RF/). A non-binding method whereby the Town publishes its need for input
from interested parties for an upcoming solicitation. A procurement practice used to obtain comments,
feedback or reactions from potential suppliers (contractors) prior to the issuing of a solicitation. Generally,
price or cost is not required. Feedback may include best practices, industry standards, technology
options, preferred timeframes, innovative approaches, or other related criteria.
Request for proposals (RFP). A solicitation method used for soliciting competitive sealed proposals
to determine the best value among proposals for goods or services for which price may or may not be the
prevailing factor in award of the contract, or the scope of work, specifications or contract terms and
conditions may be difficult to define. Such solicitation will consider the qualifications of the proposers
along with evaluation of each proposal using identified and generally weighted evaluation criteria. RFPs
shall include price criteria.
Request for qualifications (RFQ). A solicitation method used for requesting statements of
qualifications in order to determine the most qualified proposer for professional services.
Responsible vendor, bidder, offeror, or respondent. A firm who is fully capable of meeting all
requirements of the solicitation and subsequent contract. The respondent must possess the full capability,
including financial and technical, ability, business judgment, experience, qualifications, facilities,
equipment, integrity, capability, and reliability, in all respects to perform fully the contract requirements
and assure good faith performance as determined by the Town.
Responsive vendor, bidder, offeror, or respondent. A firm who has submitted a bid, offer, quote, or
response which conforms in all material respects to the competitive solicitation document and all of its
requirements.
Services. The furnishing of labor, time, skill, expertise, or effort by a consultant or a contractor rather
than providing specific goods and commodities. Such services may include, but not be limited to: general
consultations, construction, operation, repairs, maintenance, studies, reports, and technical and social
services. This term shall not include employment agreements or collective bargaining agreements for
purposes of this article.
Sole source. An item that is the only one (1) that will produce the desired results, or fulfill the specific
need, and the item is available from only one (1) source of supply.
Specifications. A precise description of the physical or functional characteristics of a good, service,
or construction item. It may include a description of any requirement for inspecting, testing, or preparing a
supply or service for delivery. It may also include a reference to a specific name brand name, model, or
equal.
Supplies. All tangible items purchased or consumed by the Town.
Suspension. The temporary prohibition of a vendor or contractor from doing business with the Town
for a period not to exceed two (2) years.
Unauthorized purchase. Any item(s) or service(s) that is purchased in a manner that is inconsistent
with this article or the Procurement Manual, including any item or service that is: (a) Purchased without
sufficient funds as determined by finance, or (b)Splitting orders of the same or like materials/requirements
into two (2) or more individual purchases with the intention of circumventing the competitive solicitation
requirements.
Vendor or supplier. A supplier of goods or services.
Page 4 of 15
Town of Pembroke Park
Ordinance No. 2021-006
The Town Manager, or his or her designee, shall be the Town's Chief Purchasing Officer ("CPO").
The CPO shall serve as the principal officer for the contracting and/or purchase of goods and services
and shall have the authority to approve all purchases, contracts, change orders, and purchase orders for
the purchase of goods and services, provided they are in conformance with the Procurement Manual, the
law, and all applicable rules and regulations. The chief procurement officer may delegate rights,
powers, and authority vested in the CPO to subordinate procurement services employees, or other
Town staff, when deemed necessary by the chief procurement officer, provided such staff shall comply
with all applicable laws, ordinances, resolutions, rules and procedures established by the Town. The
CPO shall have the authority to do as follows:
(a) Purchase or lease or contract for the purchase or lease of commodities or services required
for or by the Town, in accordance with purchasing procedures prescribed in this article and in accordance
with such administrative policies and procedures as the Town may prescribe for internal management
and operation of the purchasing office;
(b) Negotiate and recommend execution of contracts for the purchase of commodities or
services;
(c) Act to procure for the Town the needed quality in commodities or services at the least
expense;
(d) Encourage uniform bidding and full and open competition on all purchases;
(e) Prepare revisions and amendments to the purchasing regulations set forth herein, as
necessary, and recommend such revisions and amendments to the Town Commission;
(f) Prepare policies and procedures governing the purchase of commodities or services for the
Town;
(g) Keep informed of current developments in the field of purchasing, prices, market conditions
and new projects;
(h) Prescribe and maintain such forms as may be reasonably necessary to the operation as
well as other rules and regulations;
(i) Supervise the inspection of all commodities and services purchased to ensure conformance
with specifications;
U) Transfer surplus commodities between Town departments as needed;
(k) Maintain a vendors' list, vendors' catalog file and records needed for the efficient operation
of the purchasing office;
(I) Conduct all sales of surplus property that the Town Commission may authorize to be sold as
having become unnecessary or unfit for the Town's use;
(m) Upon direction by the Town Commission, the CPO shall have the power to negotiate
options on real property for consideration by the Town commission so long as any good faith deposit
money does not exceed the purchasing limits contained in this Article; however, the CPO may not
purchase or close on the purchase of real property without the direct authorization of Town commission.
All statutory requirements governing the purchase of real property by a municipality shall be complied
with. This section does not authorize the CPO to borrow any money on the Town's behalf, including the
financing of any purchases that may be made pursuant to this article, without the direct authorization of
the Town commission.
2-123. Applicable Laws; County Ethics Ordinance. The Town shall comply with all applicable federal,
state and local laws. In the event of a conflict between the provisions of this Article and the County Ethics
Ordinance, the County Ethics Ordinance shall control.
2-124. Requirement of good faith. The provisions of this article require all parties involved in the
procurement of good or services and the issuance of contracts for the Town to act in good faith.
(a) Unauthorized purchases. No officer of the Town shall, except in cases of emergency as
specified herein, issue any oral or written purchase order, contract, or conduct open market purchases in
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Town of Pembroke Park
Ordinance No. 2021-006
any manner unless specifically authorized by this article. The Town shall not be bound by purchases
made without proper authorization or in any unauthorized manner. Except as provided in this division, it
shall be unlawful for any Town officer or employee under the supervision of the Town manager to order
the purchase of any materials or supplies or make any contract for municipal materials or supplies or
services within the purview of this division other than through the central purchasing organization, and the
Town shall not be bound by any purchase order or contract made contrary to the provisions of this
division.
(b) Prohibition against subdivision. No contract or purchase shall be subdivided to avoid the
requirements of this article and the Procurement Manual.
(c) Competitive solicitation and selection. The competitive solicitation and selection process
provisions of this article shall apply to every purchase by the Town commission and the departments that
are under the control of the Town commission, regardless of their fund source, including state and federal
assistance monies and grants, except as otherwise specified in this article, or by federal, state or local
laws or grant terms and conditions, or as follows:
(d) Exclusions. The mandatory commission approval amount and the competitive solicitation
and selection processes set forth in this article shall not apply to the following:
(1) Contracts with, and purchases from, other public entities, i.e.: public state
colleges, public state universities, federal government agencies, state governments, county governments,
Town governments, government school boards, county sheriff's offices, and other government entities.
(2) Utilities, including water, wastewater, sewer, gas, electric, or other utilities as
defined by law.
(3) Cable and satellite television services.
(4) Magazine subscriptions, periodicals, and publications.
(5) Membership dues for trade or professional organizations.
(6) Travel and training expenses for employees.
(7) Items purchased for resale.
(8) Advertisement: radio, newspapers, magazines, professional organizations, trade
shows, television, and any other related media.
(9) Shipping services, including postage, overnight delivery, and courier services.
(10) Copyrighted materials or patented works, including books, maps, periodicals,
testing or instructional materials.
(11) Governmental fees.
(12) Regulatory or government licenses and permits.
(13) Real estate transaction-related costs, including closing/processing fees,
abstracts of titles, title insurance.
(14) Durable medical equipment (DME).
(15) Professional services, including:
a. Court reporter services.
b. Medical services, including wellness activities and pharmacy services.
c.Animal services, including veterinary services and the acquisition or training of
animals.
d.Legal services.
e. Expert witnesses.
f. Entertainers.
Page 6 of 15
Town of Pembroke Park
Ordinance No. 2021-006
(a) Except as otherwise exempted or provided herein, or by state or federal law, the
procurement of all goods, supplies, material, equipment, services and combinations of goods and
services by or on behalf of the Town, including those transactions through which the Town shall receive
revenue, in an amount equal to or in excess of the mandatory commission approval amount, shall be
solicited by a competitive selection process, such as: the competitive sealed bidding (1TB) process,
competitive sealed proposal (RFP) process, the request for qualifications (RFQ) process, or the
competitive negotiations (ITN) process, or other methods, as determined by the CPO.
(b) The use of electronic media, including acceptance of electronic signatures, is authorized
consistent with F.S. Ch. 668, as may be amended, for use of such media, when practical or appropriate.
(c) Evaluation and negotiation teams shall be considered dissolved upon award or rejection
by the Town for any specific competitive solicitation.
(d)The Town manager is delegated the authority to execute contracts for purchases that have
been approved by the Town commission.
(a)The Town manager or the Town manager's designee is authorized to issue a change order or
multiple change orders increasing the adjusted contract price of any contract awarded by the Town
commission up to a cumulative maximum amount of ten percent (10%) of the adjusted contract value. For
purposes herein, "adjusted contract value" means the original contract value or the contract value
resulting from Town commission-approved change orders or contract amendments.
(b)The Town manager or the Town manager's designee is authorized to issue a change order
increasing the value of a contract awarded by the Town commission in excess of the amount set forth in
(a) of this section where the increase is necessary to effect emergency repairs or replacements, due to
exigent circumstances encountered during the performance of the contract, or to prevent increased costs
Page 7 of 15
Town of Pembroke Park
Ordinance No. 2021-006
due to reasonable delay claims by the contractor. A full report of change orders exceeding the amount set
forth in subsection (a) of this section shall be submitted to the Town commission at the earliest available
commission meeting.
2-128. Procurement Amount Thresholds.
(a) The Town Manager, or designee, may authorize the purchase of services or commodities
in an amount of Ten Thousand Dollars ($10,000) or less without the approval of the Town Commission.
(b) The purchase of services or commodities in the amount of greater than Ten Thousand
Dollars ($10,000), requires the prior approval of the Town Commission at a regular or special meeting,
except as may otherwise be provided in this article.
(c) The purchase of services or commodities in the amount of five thousand dollars
($5,000.00) or greater shall be permitted only after written proposals from at least two (2) different
sources are received by the Town for consideration, and the Town approves the most responsible and
responsive proposal.
(d) The purchase of services or commodities in the amount of ten thousand dollars
($10,000.00) or greater shall be permitted only after written proposals from at least three (3) different
sources are received by the Town Commission for consideration, and the Town Commission approves
the most responsible and responsive proposal.
(e) The purchase of services or commodities in the amount of twenty-five thousand dollars
($25,000.00) or greater shall be permitted only after a competitive solicitation process (as defined in this
chapter) and the Town Commission approves the most responsible and responsive proposal.
Page 8 of 15
Town of Pembroke Park
Ordinance No. 2021-006
(1) When the CPO determines that the use of competitive negotiations is
advantageous to the Town, the competitive negotiations process may be used. An invitation to negotiate
("ITN") may be the solicitation method.
(2) The goal of an ITN is to obtain proposals from interested and qualified firms so
that the Town may enter into negotiations with the firm or firms determined most capable of providing the
required supplies and services.
(3) The ITN document will supply the firms with information necessary to understand
the need; however, the terms, scope of work, price, method of delivery, conditions of performance, and
approaches of the project may be open to consideration and negotiations, including simultaneous
negotiations with the most qualified firms.
(4) ITNs may not be used for procuring professional services addressed by F.S. Ch.
287.055 (the "Consultants' Competitive Negotiation Act").
(e) Request for information process. When it is considered impractical to prepare a
purchase description to support an award based on price or detailed scope of work, any competitive
solicitation may be preceded by a request for information ("RFI") requesting the submission of unpriced
submittals, which will provide input for the specifications or scope of work to be included in a subsequent
competitive solicitation.
(f) Late competitive responses. Bids and responses received after the time and date
specified in the solicitation document shall not be opened, but will be reported to the Town manager. Only
the Town manager may authorize the opening of a late bid or proposal.
(g) Alternative source selection.
(1) Small purchases. Any purchase for an amount less than the mandatory
commission approval amount shall be made in accordance with those procedures promulgated in the
Procurement Manual, provided, however, no purchase shall be artificially divided so as to constitute a
small purchase under this section.
(2) Sole source purchases. The CPO may make or authorize the procurement of
goods and/or services, subject to the mandatory commission approval level stipulated in this article,
without competitive solicitation when the director of the client department has documented in writing that
such good or service is the only item that meets the need and is available through only one (1) source of
supply, or when the intent to award through sole source is posted on the Town's website for a reasonable
time period, or when a documented research effort by the CPO or designee fails to identify further
competing sources of the goods or services. Such written determinations and supporting documentation
shall be retained by the CPO for public inspection and auditing purposes. The sole source process shall
be further delineated in the Procurement Manual.
(3) Proprietary purchases. The CPO may make or authorize the procurement of
goods and/or services, subject to the mandatory commission approval level stipulated in this article,
without competitive solicitation when the director of the client department has documented in writing that
such goods and/or services is proprietary in nature. Such written determination and supporting
documentation shall be retained by the CPO for public inspection and auditing purposes. The proprietary
purchase process shall be further delineated in the Procurement Manual.
(4) Emergency purchases. The Town manager and/or designee may make or
authorize emergency purchases as defined herein.
a. In the event of an emergency, such as an equipment failure, catastrophic
damage to Town property, or other similar unexpected event, all normal procurement procedures and
requirements directly related to such emergency shall be suspended; and with the approval of the Town
manager or designee, the head of any department may purchase any required emergency supplies,
materials, equipment or services. The head of such department shall send to the CPO, a requisition and
copy of the delivery record together with a full justification and circumstances of the emergency.
Page 9 of 15
Town of Pembroke Park
Ordinance No. 2021-006
Page 10 of 15
Town of Pembroke Park
Ordinance No. 2021-006
(3) Next lowest vendor. The Town commission may, upon the refusal or failure of the
successful vendor to execute the contract, award the contract to the next lowest vendor.
(4) Bid opening procedures. Sealed written bids shall be returned to the Town and
identified as bids on the envelope, together with other information as may be specified in the invitation to
bid. Bids shall be opened in public on the date and at the time and place stated in the public notices. A
tabulation of all bids received shall be made available to the public within ten days of bid opening.
(5) Rejection of bids. The Town commission may authorize the Town administrator
or designee to: (1) Reject all bids; (2) Reject all bids and re-advertise for bids, pursuant to the procedure
prescribed in this section; or (3) Reject all bids and direct that the project or service in question be
performed by the Town upon determining that such activities are in the best interest of the Town.
(6) Performance and payment bonds. A performance bond and a payment bond, or
a "contract bond" combining the elements of a performance and a payment bond, issued by a surety
company licensed to do business in the state, may be required before entering into a contract, in an
amount at least equal to the contract price or such higher amount as may be found reasonably necessary
to protect the best interests of the Town except, in limited circumstances, such as incremental services
contracts or blanket purchase orders, where it has been determined by the department director that the
potential liability resulting from the performance or payment under the contract is an amount less than the
full contract price. The department director, or other authorized person, shall obtain the approval of the
Town administrator or designee to require a bond for less than the full contract price before proceeding
with the bid process. If such bond is required, the form and amount of the bond shall be described in the
notice inviting bids. Bonds required hereunder shall be subject to all other provisions of this section.
(7) Security in lieu of performance and payment bonds. In lieu of the bond required
by this section, a contractor may file with the Town, an alternative form of security in the form of cash, a
money order, a certified check, a cashier's check, an irrevocable letter of credit, or a security of a type
listed in F.S. ch. 625, pt. II (F.S. § 625.50 et seq.). Any such alternative form of security shall be for the
same purpose and be subject to the same conditions as those applicable to the bond required hereunder.
The appropriate representative of the Town shall make the determination of the value of the alternative
form of security.
(b) Procedure.
(1) Any person may protest the specifications contained in a solicitation issued by the
Town by delivering a letter of specification protest to the CPO between the date of the electronic
release of the solicitation and five (5) days prior to the date the bids or proposals are due, excluding
Saturdays, Sundays, and holidays observed by the Town . The date on which the letter of protest is
received in the office of the CPO shall constitute the date of delivery.
(2) The written protest shall state with particularity the specific facts and any law or ordinance
on which it is based, and shall include any and all pertinent documents and evidence.
(1) The CPO shall first have the authority to settle and resolve any written protest within
seven (7) days from receipt of a timely written protest by sending a written decision to the protesting
party by mail or email upholding or denying the protest or staying the award process for further
Page 11 of 15
Town of Pembroke Park
Ordinance No. 2021-006
investigation.
(2) The protesting party may appeal to the Town manager a decision by the CPO denying
the protest by delivering a notice of appeal to the CPO within three (3) days from the protesting party's
receipt of the CPO's decision. Upon receipt of a timely notice of appeal the CPO will forward the protest
to the Town manager for consideration . The Town manager may affirm, reverse , or modify the CPO's
decision.
(3) The Town's consideration of a timely written protest shall not necessarily stay the
solicitation process, as may be in the best interest of the Town . The CPO may recommend to the Town
manager to render moot any written protest that is overtaken by events, in which case such protest
may be abated and dismissed as determined by the Town manager.
(d) Timely submittal of a protest or appeal required. Failure of a person to submit timely a
written protest or a notice of appeal to the CPO within the time provided in this section shall constitute a
waiver of such person's right to do so.
(e) Computation of days. In computing any period of time prescribed or allowed by this
protest policy , the day of the act or event from which the designated period of time begins to run shall
not be included. The last day of the period so computed shall be included unless it is a Saturday,
Sunday or holiday observed by the Town, in which event the period shall run until the end of the next
business day which is neither a Saturday nor Sunday, nor a holiday observed by the Town. Service of a
protest or a notice of appeal by mail or courier shall not expand the time period allowed for delivery.
(f) Costs. Any and all costs incurred by a protesting party in connection with a protest
pursuant to this section shall be the sole responsibility of the protesting party .
2-131. Preference to businesses with drug-free workplace programs. The Town hereby adopts by
reference F.S. § 287.087, as amended, regarding bidding preferences for businesses with drug-free
workplace programs. Whenever two (2) or more bids which are equal with respect to price, quality and
service are received by the Town for the procurement of commodities or services, a bid received from a
business that certifies that it has implemented a drug-free workplace program shall be given a preference,
provided that the drug-free workplace program complies with F.S. § 287.087, and any other applicable
state law. An announcement of this preference shall be included in the bid documents.
2-132. Non-discrimination . Contractors shall not discriminate against any person in its operations,
activities or delivery of services. Contractors shall affirmatively comply with all applicable provisions of
federal , state and local equal employment laws and shall not engage in or commit any discriminatory
practice against any person based on race , age, religion , color, gender, pregnancy, sexual orientation,
gender identity and expression, national origin , marital status, physical or mental disability, political
affiliation or any other factor which cannot be lawfully used as a basis for service delivery.
Page 12 of 15
Town of Pembroke Park
Ordinance No. 2021-006
2-134. Applicability to salaries, benefits. The provisions in this article should not apply to the payment of
salaries or other employment benefits to officers or employees of the Town.
2-135. Adoption of Procurement Procedures Manual. The Town Commission shall adopt a Procurement
Procedure Manual by resolution to be used by the Town's staff setting forth the policies and rules for
billing of accounts due, processing payments received by the Town, purchase orders for procurement of
goods or services and such other matters as are necessary for orderly operation of the financial affairs of
the Town.
(a) Authority and requirement to debar and suspend. After reasonable notice to an actual or
prospective contractual party, and after reasonable opportunity for such party to be heard, the Town
Commission, after consultation with the Town Attorney or Town staff, shall have the authority to debar a
person or entity for the causes listed in this section from consideration for award of Town contracts. The
debarment shall be for a period of not fewer than three (3) years. The Town Manager, the Chief
Procurement Officer or the Using Department shall also each have the authority to suspend a contractor
from consideration for award of Town contracts when there is probable cause for debarment pending the
debarment determination by the Town Commission.
(b) Causes for debarment or suspension. Causes for debarment or suspension include the
following:
(1) Conviction of a criminal offense incident to obtaining or attempting to obtain a public or
private contractor, subcontract, or incident to the performance of such contract or subcontract;
(2) Conviction under state or federal statutes of embezzlement, theft, forgery, bribery,
falsification or destruction of records, receiving stolen property, or any other offense indicating a lack of
business integrity or business honesty;
(3) Conviction under state or federal antitrust statutes arising out of the submission of bids or
proposals;
(4) Violation of Town's contract provisions, which violation is regarded by the Chief
Procurement Officer or Using Department to be indicative of non-responsibility. Such violation may
include failure without good cause to perform in accordance with the terms and conditions of a Town
contract or to perform within the time limits provided in the Town contract, provided that failure to perform
caused by acts beyond the control of a party shall not be considered a basis for debarment or
suspension;
(5) Debarment or suspension of the person or entity by any federal, state, or other
governmental entity; or
(6) Any other cause judged by the Town Commission to be so serious and compelling as to
affect the responsibility of the person or entity performing Town contracts.
(c) Debarment and suspension decisions. Subject to the provisions of this section the Town
Attorney shall render a written decision stating the reasons for the debarment or suspension. A copy of
the decision shall be provided promptly to the debarred or suspended party.
(a) Disposal of surplus property. The Town may sell, trade or otherwise dispose of surplus
and obsolete personal property belonging to the Town either by sale, barter or exchange, by competitive
sealed bid, public auction, cannibalization, trade in or any other means of disposal as may be appropriate
and in the best interests of the Town. Disposal of surplus or obsolete personal property requires prior
approval by the Town Commission. No employee may purchase any such property without Town
Commission approval.
Page 13 of 15
Town of Pembroke Park
Ordinance No. 2021-006
(b) Donation of surplus property. Surplus property may be donated by Town Commission
approval, in any manner as the Town Commission deems fit.
* * *
Section 2: That the provisions of this Ordinance are to be severable and if any section,
sentence, clause or phrase of this Ordinance shall, for any reason, be held to be invalid or
unconstitutional, such decision shall not affect the validity of the remaining sections, sentences,
clauses, and phrases of this Ordinance but shall remain in effect, it being the legislative intent that
Section 3: That it is the intention of the Commission of the Town of Pembroke Park that
the provisions of this Ordinance shall be included in the Pembroke Park Code of Ordinances, and
the sections may be renumbered, or re-lettered, ordinance may be changed to "section", "article"
in conflict herewith be and the same are hereby superseded to the extent of such conflict.
Section 5: That this Ordinance shall be in force and take effect as provided by law.
PASSED AND ADOPTED on First Reading this 8th day of September, 2021.
Page 14 oflS
Town ofPembroke Park
Ordinance No. 2021-006
ATTEST:
Mayor Commissioner
MARLEN D. MARTE
Town Clerk
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Town Attorney
VOTE
Page 15 of 15
OIG 23-018-M
COMPOSITE
EXHIBIT 2
From: Joy Brown
To: [email protected]; Geoffrey Jacobs; Reynold Dieuveille; Bill Hodgkins
Cc: Police Staff; Gloria Rosen; [email protected]; [email protected]; [email protected]
Subject: Holiday Party
Date: Thursday, December 8, 2022 3:08:11 PM
Attachments: image001.png
Kind regards,
WARNING: This email originated from outside of the Town of Pembroke Park Organization. Do
not click links/images or open attachments unless you recognize the sender and know the
content is safe.
- ---------------------
From:
Sent:
Joy Brown <[email protected]>
Thursday, December 8, 2022 4:37 PM
Subject: FW: Holiday Party
Importance: High
The annual Town of Pembroke Park Holiday Party will be on Wednesday, December 21st , 2022
from 5pm to 9pm. The Sundream Cruise Yacht will be the venue and details will follow. Please
1
RSVP, via this email, if you will be in attendance and bringing a guest. There will be a minimal
cost for your guest, as the price information will be forthcoming. Please reply to this email by
end of day on December 14th, 2022. Thank you and have a great evening.
Kind regards,
Joy Brown Executive Assistant Chief of Police/Accreditation Manager
Town of Pembroke Park Police Dept
3150 SW 52nd Ave
Pembroke Park, FL 33023
Office: 954-966-4600 Ext.700
Facsimile: 954-985-2172
[email protected]
https://www.tppfl.gov
2
OIG 23-018-M
EXHIBIT 3
----------------
From:
Sent:
Maribel Rosario <[email protected]>
Friday, December 16, 2022 2:24 PM
To: Joy Brown
Subject: Fwd: udated quote for 12 21 22 event
Attachments: SUN QUOTE 12 21 22 FOR 40P JOY 3hrs.pdf
MARIBEL ROSARIO
Sales and Event Coordinator
Office: 305-922-5980
Mobile: 754-423-6147
www.starvisionyachtcharters.com
Good Morning Joy attached is the invoice we do have a minimum requirement to go out now that is only
40p. need to be a $70pp. menu. Please let me know if you are moving forward to send you a contract that
needs to be paid in full and have menu options asap. thank you
MARIBEL ROSARIO
Sales and Event Coordinator
Office: 305-922-5980
Mobile: 754-423-6147
www.starvisionyachtcharters.com
1
Hope this email finds you well.
Can you please send over the final invoice for the Town of Pembroke Park Holiday party that will take
place on December 21,2022. If you have any questions please give me a call. Thank you and have a
great day.
Kind regards,
Facsimile: 954-985-2172
https://www.tppfl.gov
2
To: Joy Brown <[email protected]>
Subject: Re: udated quote for 12 21 22 event
MARIBEL ROSARIO
Office: 305-922-5980
Mobile: 754-423-6147
www.starvisionyachtcharters.com
Hello Maribel,
Today was the final count for staff that was attending the holiday party. There will only be 40 people
attending this event. Please give me a call in the morning to discuss. Thank you and have a great
evening.
Kind regards,
3
Joy Brown Executive Assistant Chief of Police/Accreditation Manager
Facsimile: 954-985-2172
bttps://www.tppfL2ov
Good afternoon Joy, boat can do cash bar for liquors. You can bring your DJ. The only requirements are
to have his own liability and bring his speakers for both levels.
MARIBEL ROSARIO
Office: 305-922-5980
Mobile: 754-423-6147
www.starvisionyachtcharters.com
4
On Tue, Dec 13, 2022 at 7:06 AM Maribel Rosario <[email protected]> wrote:
Good morning Joy anomaly they have a minimum budget for the holidays season that was the
reason was $70pp. Now I did get the owner to lower it to $65pp. Please let me know if you have any
questions?
MARIBEL ROSARIO
Office: 305-922-5980
Mobile: 754-423-6147
www.starvisionyachtcharters.com
5
The dinner selection I se lected was 65 a person now you send me a invoice for 70 a person please
clarify why the price change.
Kind regards,
Facsimile: 954-985-2172
https://www.tppfl.gov
Hi Joy Attached is the updated invoice for 3hrs. non alcoholic bar for 50p. minimum required for
holiday season. Please let me know if you have any questions?
MARIBEL ROSARIO
6
Sales and Event Coordinator
Office: 305-922-5980
Mobile: 754-423-6147
www.starvisionyachtcharters.com
7
Starvision Yacht Charters
www.starvisionyachtc harters.com
[email protected]
ST,A°RVISION
YACH~ CHARTERS & EVE N TS
Mobile: 754-423-6147
Office: 305 922 5980
ENHANCEMENTS
ENTERTAINMENT
OJ BY CLIENT $0.00
LABOR CHARGE $1,700.00
CARD PROCESSING 4%
Subtotal $9,575.00
EVENT DETAILS
Sales Tax / Admin Fee/none $0.00
Gratuity $1,000.00
Total $10,575.00
$10,575.00
SET UP Gratuity Optional 100/o $957.50
------------------ 150/o $1,436.25
200/o $1,915.00
OIG 23-018-M
EXHIBIT 4
From: Kristin - Sun Dream Yacht Charters <[email protected]>
Sent: Friday, December 16, 2022 4:17 PM
To: '[email protected]'
Cc: '[email protected]'; starvisionyachtcharters
Subject: Holiday party
Attachments: 2022 Credit Card Authorization Form.doc
Please fill this out and return along with menu choices ASAP so we can order the food
before 5 PM.
The deposit is $3950. Maribel will send you the contract to be signed along with the balance
due Monday morning by wire transfer.
Need copy of front and back of card and driver’s license as well.
Thanks,
Kristin Sloan
Account Executive
852 NE 20th Avenue
Fort Lauderdale, FL 33304
954.765.1460
www.sundreamyachts.com
1
CREDIT CARD AUTHORIZATION FORM
……………………………………………………………………………….
authorize Sun Dream Yacht Charters, Inc. to charge the following credit card
Account #: _____________________________________________________________________________
Other: $____________________
I agree that my liability for the charges will not be waived, and I agree to be held personally
liable in the event that the credit card company fails to pay for the full amount of the
charges. These charges are irrevocably due to Sun Dream Yacht Charters, Inc.
Date of Charter_________________________________Yacht___________________________________
OIG 23-018-M
EXHIBIT 5
----------------
From:
Sent:
Maribel Rosario <[email protected]>
Friday, December 16, 2022 4:26 PM
To: Joy Brown; [email protected]
Subject: Fwd: Holiday party
Attachments: 2022 Credit Card Authorization Form.doc
MARIBEL ROSARIO
Sales and Event Coordinator
Office: 305-922-5980
Mobile: 754-423-6147
www.starvisionyachtcharters.com
Please fill this out and return along with menu choices ASAP so we can order the food
before 5 PM.
The deposit is $3950. Maribel will send you the contract to be signed along with the balance
due Monday morning by wire transfer.
Need copy of front and back of card and driver’s license as well.
1
Thanks,
Kristin Sloan
Account Executive
www.sundreamyachts.com
2
CREDIT CARD AUTHORIZATION FORM
……………………………………………………………………………….
authorize Sun Dream Yacht Charters, Inc. to charge the following credit card
Account #: _____________________________________________________________________________
Other: $____________________
I agree that my liability for the charges will not be waived, and I agree to be held personally
liable in the event that the credit card company fails to pay for the full amount of the
charges. These charges are irrevocably due to Sun Dream Yacht Charters, Inc.
Date of Charter_________________________________Yacht___________________________________
OIG 23-018-M
EXHIBIT 6
----------------
From:
Sent:
Geoffrey Jacobs <[email protected]>
Saturday, December 17, 2022 8:18 AM
To: Maribel Rosario
Subject: Re: Holiday party
Attachments: Sundream yacht credit card form.pdf
Thank you,
MARIBEL ROSARIO
Sales and Event Coordinator
Office: 305-922-5980
Mobile: 754-423-6147
www.starvisionyachtcharters.com
1
---------- Forwarded message ---------
From: Kristin - Sun Dream Yacht Charters <[email protected]>
Date: Fri, Dec 16, 2022 at 1:16 PM
Subject: Holiday party
To: [email protected] <[email protected]>
Cc: [email protected] <[email protected]>, starvisionyachtcharters
<[email protected]>
Please fill this out and return along with menu choices ASAP so we can order the food
before 5 PM.
The deposit is $3950. Maribel will send you the contract to be signed along with the balance
due Monday morning by wire transfer.
Need copy of front and back of card and driver’s license as well.
Thanks,
Kristin Sloan
Account Executive
www.sundreamyachts.com
2
WARNING: This email originated from outside of the Town of Pembroke Park Organization. Do not click
links/images or open attachments unless you recognize the sender and know the content is safe.
This email may contain confidential and privileged material for the sole use of the intended recipient. Any
review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient
(or authorized to receive for the recipient), please contact the sender by reply email and delete all copies
of this message.
3
CREDIT CARD AUTHORIZATION FORM
……………………………………………………………………………….
authorize Sun Dream Yacht Charters, Inc. to charge the following credit card
Account #: ___________________________________________________________
-
Expiration Date: _ __________________________________________________________________
Other: $____________________
I agree that my liability for the charges will not be waived, and I agree to be held personally
liable in the event that the credit card company fails to pay for the full amount of the
charges. These charges are irrevocably due to Sun Dream Yacht Charters, Inc.
COMPOSITE
EXHIBIT 7
-'------------------
From:
Sent:
DocuSign NA4 System <d [email protected] > on behalf of Maribel Rosario via
DocuSign <dse_N [email protected] >
Monday, December 19, 2022 12:50 PM
To: Mr. Mayor Jacobs
Subject: Complet ed: Complete with DocuSiqn: Sund ream contract.pdf, lnvoice.pdf
Attachments: Sundream contract.pdf; lnvoice.pdf
DocuSign·
Maribel Rosario
[email protected]
If you are having trouble signing the document, please visit the Help with Signing page on our
Support Center.
This message was sent to you by Maribel Rosario who is using the DocuSign Electronic Signature Service. Ifyou would rather not
receive email from this sender you may contact the sender with your request.
WARNING: This email originated from outside of the Town of Pembroke Park Organization. Do not click
links/images or open attachments unless you recognize the sender and know the content is safe.
2
DocuSign Envelope ID: 8FA81540-13AF-4F3E-B01C-765025- ;EFif!KVISJ QN
YAC H T C ARTER5 & fVEN T S
This Chartering AGREEMENT ("Agreement") made on _1 2/17/2022_ by and between Star Vision Events LLC, hereinafter called
the ("Owner"), a Florida Corporation located at 2733 W ashington St reet Hollywood FL 33020 and _Mr. Mayor Geoffrey Jacobs
2. CANCELLATION POLICY:
(a) Owner and Charterer agree that all deposits are non-refundable, and any cancellation shall be in writing.
(b) If Charterer cancels within ninety-one (91 ) days prior to the charter date, all monies due are forfeited to Owner as
liquidated damages, including loss of catering, bar, crew, and other fee which will be based on the number of passengers
and menu selection last discussed.
3. JURISDICTION:
This agreement will be governed by the laws of the State of Florida and both parties agree to be subject to the jurisdiction.
of the County and Circuit Courts located in Miami-Dade County, Florida. In the event Charterer fails to make all required
payments, Charterer will be responsible for all costs of collection, including attorney fees.
4. BOARDING AND DEBARKATION :
(a) Passengers may commence boarding upon time listed on "Invoice".
(b) The vessel will return to the dock generally 20 minutes prior to the end of the charter time, or as specified in "Invoice". At
this time, music will be terminated to not violate any city noise ordinances.
5. RUNNING EXPENSES AND GRATUITIES:
The Charterer agrees to accept the Vessel delivered as hereinbefore provided and to pay all running expenses in the
"Invoice" for the term of the Charter. Any outside fees that the owner has no control over, i.e., dock fees, fuel, etc. cannot
be guaranteed and will be adjusted accordingly to the charterer's final billing.
6. LIABILITY INSURANCE:
Vessels are fully insured as a U.S. Coast Guard Certified Vessel with companies qualified to do business in the U.S.
7. SUB-CONTRACTORS:
(a) All entertainment must be approved by the Owner.
(b) Should the Charterer choose to hire outside sub-contractors i.e ., Florists, Musicians, Photographers, Planners, etc.
Charterers must supply a list of all subcontractors along w ith liability insurance satisfactory to the Owner.
(c) Vendors may not use extended Tripods onboard, unless approved by the owner in advance.
8. DELIVERY:
The Owner agrees to deliver the vessel to the dock at the time and place specified in the "Invoice" in full commission and
proper working order, outfitted as a vessel of her size, type and accommodation, with full equipment, inclusive of that
required by law. In the event that the owner is unable to deliver the vessel for any reason, then the ow ner will attempt to
obtain a comparable vessel. If all attempts at obtaining a comparable vessel fail, then this agreement may be cancelled
by Charterer, and a pro-rata refund or full credit will be administered. In either case the parties shall thereafter be relieved
of all obligations of any nature whatsoever w ith the exception of:
(a) Weather conditions, w hen the charter activity may only be held dockside or when another port must be utilized at the
Captain's discretion, and.
(b) A matfunction of bridges or route obstruction when the closest port for dockage will be utilized. Any secondary dockage or
transportation expenses incurred will be the sole responsibility of the Charterer.
In the event of either (a) or (b) above, there will be no refund. The Owner reserves the right to exercise this option without
incurring any default of this Agreement.
DocuSign Envelope ID: 8FA81540-13AF-4F3E-B01C-7650254FEFF2
9. FORCE MAJEURE:
Force Majeure is any cause attributable to acts, accidents, weather, or omissions beyond the reasonable control of the
OW NER or the CHARTERER. Most charters will continue during rain and most storms; however, no warranty or refunds
are made as to the suitability of weather. If a named hurricane threatens the location of the chartered vessel, the Captain
shall have the option of terminating the charter, if the charter has not yet commenced. The Captain's decision to terminate
or refuse boarding shall be final, as the captain is solely responsible for determining if the weather is compatible with the
purpose of the trip and the safety of the passengers. In the rare instance of a charter termination by Captain, a credit will be
given to the Charterer for the full amount of the charter, to be used for up to one year from the charter date, less minimal
administrative expenses.
10. AFTER DELIVERY :
Owner agrees that should the vessel after delivery, sustain breakdown of equipment, be disabled, damaged by fi re,
grounding, collision, or any other cause so as to prevent the use of the Vessel by Charterer, the Owner will make every
effort to obtain a replacement vessel OR, the Owner shall make a pro-rata refund to Charterer or a new date for a
substitute charter may be arrange by the parties.
11. LIENS:
The Charterer, his agent and employees have no right or power to permit or suffer the creation of any maritime lien
against the Vessel. Charterer may not sub-lease said Vessel without specific permission from Owner in writing.
12. DEFAULTS:
It is mutually agreed that any monies not paid on the date designated in this contract will be fully enforceable under the
terms stated. Any cost or expense incurred by the Owner to enforce its rights pursuant to this Agreement. All complaints
are to be fi led in the State of Florida. Whether for court costs, attorney fees or collection expenses shall be the
responsibility of the non-prevailing party to pay.
13. CONDUCT ABOARD THE VESSEL:
(a) Drugs: The use of or possession of illicit drugs, including marijuana, on board the vessel shall result in immediate
termination of Charter with all monies forfeited.
(b) Misconduct : Any disorderly conduct, possession of unauthorized alcoholic beverage, possession or illegal firea rms or
unlawful gambling on the part of the Charterer, Charterer's guests, agents or subcontractors will not be tolerated and an
immediate return to the dock will be ordered by the Captain, in which this Agreement will become null and void and all
fees paid will be forfeited.
(c) Damage : Damage sustained to the Vessel by Charterer, their guests, their employees, or their subcontractors, beyond
normal wear, is the sole responsibility of the Charterer and will be charged accordingly to the Charterer.
(d) Personal Belongings: The Owner and Vessel staff will not be responsible for articles left UNATTENDED by the
Charterer, Charterer's agent, guests, or subcontractors.
(e) Parkin g: All arrangements and fees in connection with parking of automobiles of guests is the sole responsibility of the
Charterer.
To the true and faithful performance of the foregoing Agreement, the said parties hereto bind themselves, their heirs,
executors, administrators, and assigns, each to the other.
IN W ITNESS WHEREOF, the parties hereto have hereunto set their hands and seals on the day and year fi rst above written.
BY: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ BY:
$10,575.00
_S_E_T_U_P_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Gra t uity Optio na l 10% $957.50
15% $1,436.25
20% $1,915.00
OIG 23-018-M
COMPOSITE
EXHIBIT 8
SYNovus· Good Evening, Christian Noel
Beneficiary Fl FL
State:
33301
Approvals
Beneficiary Fl
ZIP:
APPROVAL(S):
Roy D. Brown
Budget & Finance Director, Town of Pembroke Park
954.966.4600 ext. 232 I [email protected]
3150 SW 52nd Ave Pembroke Park, FL 33023
----Original Message-----
From: [email protected] <[email protected]>
Sent: Monday, December 19, 2022 2:14 PM
To: Harry Taubenfeld <[email protected]>
Subject: [Customer Outgoing Wire Advice - eMail] Message ID:221219135411HS00 Advice Code:OTCSADEM
Dear Customer:
This e-mail receipt serves as immediate notification of the following Funds Transfer that will be DEBITED from your
account. If you have any questions, please contact your local branch.
For your security, the account numbers have been truncated.
***************************************
1
Beneficiary: Sun Dream Yacht Charters Inc.
Beneficiary Account: **********7522
Beneficiary Address: 223 S Gordon Rd.
Beneficiary Address:
Beneficiary Address: Fort Lauderdale, FL 33301
Beneficiary Bank: Locality Bank
***************************************
WARNING: This email originated from outside of the Town of Pembroke Park Organization. Do not click links/images or
open attachments unless you recognize the sender and know the content is safe.
2
Ch ristian Noel
Roy spoke w ith the M ayor regard ing the wire and what is needed by t he Finance Dept. We moved forwa rd w ith the
w ire t ransfer to Sun Dream Yacht Charters. Attached is the confirm atio n information.
Respectfully,
Ms. Christian Noel
1
OIG 23-018-M
COMPOSITE
EXHIBIT 9
B ROWARD O FFICE OF THE I NSPECTOR G ENERAL
September 18, 2023 SENT BY EMAIL
The Broward Office of the Inspector General (OIG) requests that you provide the records set forth
below:
1. Any and all records relating to Town of Pembroke Park Christmas party held in December 2022, to
include but not limited to:
• Invoices
• Quotes
• Agreements
• Receipts
• Copy of checks issued and received
• Emails
• Correspondence
• Town Purchasing Card (P-Card) payments records
• Town issued credit card statements
2. Any and all policies, procedures, rules and guidance that were effective in December 2022 regarding
the use of town purchasing cards, town credit cards, expenditures, competitive quotes, and
procurement process manuals or codes.
3. Any and all regular commission meeting, workshop commission meeting or special commission meeting
agendas, meeting minutes, notes, supporting documentation and vote tallies regarding the December
2022 town Christmas Party.
C ar ol J . B r ee ce, I n sp ec t or Gen er al
One North University Drive, Suite 111 • Plantation, Florida 33324 • (954) 357-7873
[email protected] • www.BrowardIG.org • (954) 357-TIPS
PAGE 2 OF 2
We request that you provide the above referenced items by October 2, 2023. You may comply
with this request by e-mailing the items to Special Agent Gil Suarez, [email protected] or by
delivering them to the OIG, which is located at One North University Drive, Suite 111, Plantation,
Florida 33324. If you need to make alternative arrangements or would like additional clarification on
any requested item, please contact Special Agent Suarez at 954-357-7883.
Regards,
Carol J. Breece
INSPECTOR GENERAL
C ar ol J . B r ee ce, I n sp ec t or Gen er al
One North University Drive, Suite 111 • Plantation, Florida 33324 • (954) 357-7873
[email protected] • www.BrowardIG.org • (954) 357-TIPS
From: Town Clerk
To: Aleem Ghany: Suzi Reutlinger: Christian Noel
Cc: Rnance Pirectoc
Subject: RE: LOR - Broward OIG
Date: Tuesday, September 26, 2023 4:35:33 PM
Hope all is well. We have researched item #3 and t his item was not placed on any meeting agenda. We do
not have any votes or direction given by the Commission to approve the 2022 Christmas Party. I did find in
the budget book on page 58, the approval of the Holiday Party for $8,000. Christmas Party and Holiday Party
are synonymous.
Regards,
Marlen D. Martell, MPA, CMC, CFM
Town Clerk
Town of Pembroke Park
954.966.4600 ext. 235 I [email protected]
.. www.tppfl.gov
3150 SW 52nd Avenue, Pembroke Park, Fl 33023
The Town of Pembroke Parks Clerk's Office is committed to serving the community as the
Town's records custodian; Supervisor of Elections; assisting the public in accessing public
documents and information; and to provide services in a timely, accurate and professional
manner.
From:
Sent: Monday, September 18, 2023 3:03 PM
To: Aleem Ghany <[email protected]>
Cc: Town Clerk <[email protected]>
Subject: RE: LOR - Broward OIG
Thank yo u,
From: Aleem Ghany <[email protected]>
Sent: Monday, September 18, 2023 2:59 PM
To: Town Clerk <[email protected]>; David DiLena
<[email protected]>; Valerie Price <[email protected]>; Christian Noel <[email protected]>; Suzi
Reutlinger <[email protected]>
Cc: Jacob Horowitz <[email protected]>
Subject: RE: LOR - Broward OIG
Good afternoon,
This email acknowledges receipt of your request. We will fill your request as soon as
possible.
Regards,
The Town of Pembroke Parks Clerk’s Office is committed to serving the community as the
Town’s records custodian; Supervisor of Elections; assisting the public in accessing public
documents and information; and to provide services in a timely, accurate and professional
manner.
From:
Sent: Monday, September 18, 2023 1:40 PM
To: Town Clerk <[email protected]>
Subject: LOR - Broward OIG
Marlen D. Martell:
See attached copy of an OIG letter of request. Should you need further assistance, do not hesitate to
contact me.
Thank you,
CIGI
Special Agent
Broward Office of the Inspector General
One North University Drive, Suite 111
Plantation, Florida 33324
Phone: 954-357-7883
Fax: 954-357-7857
www.browardig.org
Under Florida law, most e-mail messages to or from Broward County employees or officials
are public records, available to any person upon request, absent an exemption. Therefore,
any e-mail message to or from the County, inclusive of e-mail addresses contained therein,
may be subject to public disclosure.
WARNING: This email originated from outside of the Town of Pembroke Park Organization. Do not
click links/images or open attachments unless you recognize the sender and know the content is safe.
This email may contain confidential and privileged material for the sole use of the intended recipient. Any
review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or
authorized to receive for the recipient), please contact the sender by reply email and delete all copies of this
message.
WARNING: This email originated from outside of the Town of Pembroke Park Organization. Do not
click links/images or open attachments unless you recognize the sender and know the content is safe.
Town of Pembroke Park Florida
OF
PEMBROKE PARK
FLORIDA
EXHIBIT 10
----------------
From:
Sent:
Geoffrey Jacobs <[email protected]>
Saturday, December 17, 2022 12:58 PM
To: starvisionyachtcharters
Subject: Re: Holiday party
Attachments: Image.jpeg; Image.jpeg; Image.jpeg
Good morning,
First and foremost, it’s Honorable Mayor Jacobs, Mayor Jacobs, or Mr. Mayor Jacobs. If your charter
reservation systems were not so antiquated and outdated this wouldn’t have been an issues. You didn’t
even correctly send a docusign. Who sends an incomplete word document with nothing filled in for a
reservation these days? 20 years ago that would be acceptable but not with all the advanced technology
in reservation systems theses days. Attached is an image of my drivers license, and my town’s credit
card. From my professional opinion, I highly recommend you review the 2022-2023 Federal Trade
Commissions (FTC) on the legalities of credit card processing and update your practices.
The personal information on my drivers license, my license or my home address is not for public
release.
Good morning Geoffrey we need the photo ID and credit photo as well. This form was supposed to be
sent yesterday before 6 pm. Now I have to wait for Monday to process it. I will keep you posted
1
Thank you,
MARIBEL ROSARIO
Sales and Event Coordinator
Office: 305-922-5980
Mobile: 754-423-6147
www.starvisionyachtcharters.com
Please fill this out and return along with menu choices ASAP so we can order the food
before 5 PM.
2
The deposit is $3950. Maribel will send you the contract to be signed along with the balance
due Monday morning by wire transfer.
Need copy of front and back of card and driver’s license as well.
Thanks,
Kristin Sloan
Account Executive
www.sundreamyachts.com
3
WARNING: This email originated from outside of the Town of Pembroke Park Organization. Do not click
links/images or open attachments unless you recognize the sender and know the content is safe.
This email may contain confidential and privileged material for the sole use of the intended recipient. Any
review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient
(or authorized to receive for the recipient), please contact the sender by reply email and delete all copies
of this message.
WARNING: This email originated from outside of the Town of Pembroke Park Organization. Do not click
links/images or open attachments unless you recognize the sender and know the content is safe.
4
GlEOf FREY JACOlBS
SYNOVUS
OIG 23-018-M
EXHIBIT 11
----------------
From:
Sent:
Geoffrey Jacobs <[email protected]>
Sunday, December 18, 2022 8:46 AM
To: Maribel Rosario
Cc: Joy Brown
Subject: Re: Holiday party
Please refer to my assistant to complete anything you need done. I really don’t have time to be dealing
with this anymore.
The reason the cc form is not sent via docusign is because The Sun Dream does not use docusign yet.
They send an empty cc form for the client to fill out the appropriate information. You have filled out the cc
form with the event date reflecting for December 23rd. We have been working with the contract and
invoice reflecting December 21st. We just want to be clear on the date. Please sign the Docusing that
was sent yesterday with the contract and invoice for booking your event. Also Balance needs to be wired
Monday morning please.
Thank you,
MARIBEL ROSARIO
Sales and Event Coordinator
Office: 305-922-5980
Mobile: 754-423-6147
www.starvisionyachtcharters.com
1
On Sat, Dec 17, 2022 at 9:57 AM Geoffrey Jacobs <[email protected]> wrote:
Good morning,
First and foremost, it’s Honorable Mayor Jacobs, Mayor Jacobs, or Mr. Mayor Jacobs. If your charter
reservation systems were not so antiquated and outdated this wouldn’t have been an issues. You didn’t
even correctly send a docusign. Who sends an incomplete word document with nothing filled in for a
reservation these days? 20 years ago that would be acceptable but not with all the advanced technology
in reservation systems theses days. Attached is an image of my drivers license, and my town’s credit
card. From my professional opinion, I highly recommend you review the 2022-2023 Federal Trade
Commissions (FTC) on the legalities of credit card processing and update your practices.
The personal information on my drivers license, my license or my home address is not for public
release.
Good morning Geoffrey we need the photo ID and credit photo as well. This form was supposed to be
sent yesterday before 6 pm. Now I have to wait for Monday to process it. I will keep you posted
Thank you,
MARIBEL ROSARIO
Sales and Event Coordinator
Office: 305-922-5980
Mobile: 754-423-6147
www.starvisionyachtcharters.com
Please fill this out and return along with menu choices ASAP so we can order the food
before 5 PM.
The deposit is $3950. Maribel will send you the contract to be signed along with the
balance due Monday morning by wire transfer.
3
Need copy of front and back of card and driver’s license as well.
Thanks,
Kristin Sloan
Account Executive
www.sundreamyachts.com
4
WARNING: This email originated from outside of the Town of Pembroke Park Organization. Do not click
links/images or open attachments unless you recognize the sender and know the content is safe.
This email may contain confidential and privileged material for the sole use of the intended recipient.
Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended
recipient (or authorized to receive for the recipient), please contact the sender by reply email and delete
all copies of this message.
WARNING: This email originated from outside of the Town of Pembroke Park Organization. Do not click
links/images or open attachments unless you recognize the sender and know the content is safe.
WARNING: This email originated from outside of the Town of Pembroke Park Organization. Do not click
links/images or open attachments unless you recognize the sender and know the content is safe.
5
OIG 23-018-M
EXHIBIT 12
From: Town Clerk
To:
Cc: Chandler Williamson
Subject: FW: Follow-Up on Request for Records
Dat e: Hiday, July 19, 2024 3 :24:41 PM
Attachments: iroageQ03 png
Payable Register.pelf
2719 001.pdf
PROCUREMENT CODE Apprved October 2021.pdf
Report Suspicious
Good afternoon,
Regards,
The Town of Pembroke Parks Clerk's Office is committed to serving the community as the
Town's records custodian; Supervisor of Elections; assisting the public in accessing public
documents and information; and to provide services in a timely, accurate and professional
manner.
Hello Marlen,
Attached is the payables packet and the audit history to show who approved the final payment for the
yacht. On page 5 you'll see a payment in the amount of $6,625.00. That was the balance. The deposit
was paid on December 17th 2022 on Commissioner Jacobs credit card. The audit history will show that
David Howard approved as Dept Head, Roy Brown approved as Finance Director and JC Jimenez
approved as Town Manager. It’s in the Police packet because Joy Brown worked for the Police Dept at
the time and also assisted with the events. If you have any questions, please let me know. thank you
Respectfully,
Ms. Christian Noel
Good afternoon,
Regards,
The Town of Pembroke Parks Clerk’s Office is committed to serving the community as the
Town’s records custodian; Supervisor of Elections; assisting the public in accessing public
documents and information; and to provide services in a timely, accurate and professional
manner.
From:
Sent: Wednesday, July 3, 2024 1:09 PM
To: Town Clerk <[email protected]>
Subject: Follow-Up on Request for Records
Good afternoon,
Pursuant to its authority set forth in Article X of the Charter of Broward County, the Broward Office
of the Inspector General (OIG) requests that you provide the records set forth below:
1. Any and all records from the Town of Pembroke Park’s Tyler Technologies system
related to the procurement and payment of the Town’s Christmas party held in
December 2022, including but not limited to audit trails showing any document upload,
workflow, requests for approval and any approvals granted.
2. Any and all policies and procedures, rules and guidance that were effective in
December 2022, regarding the use of town purchasing cards and expenditures.
This request is considered to be a follow-up of the OIG’s September 18, 2023, request for records.
So, if any of the records listed above cannot be presently located, please indicate that accordingly.
If you would like additional clarification on any of the requested items, please contact me.
We also request that you acknowledge the receipt of this email and provide the records by July 12,
2024.
Regards,
Investigations Manager
Broward Office of the Inspector General
1 N. University Drive, Suite 111
Plantation, FL 33324
(954) 357-7819
www.browardIG.org
954-357-TIPS (8477)
Under Florida law, most e-mail messages to or from Broward County employees or officials
are public records, available to any person upon request, absent an exemption. Therefore,
any e-mail message to or from the County, inclusive of e-mail addresses contained therein,
may be subject to public disclosure.
WARNING: This email originated from outside of the Town of Pembroke Park Organization. Do not
click links/images or open attachments unless you recognize the sender and know the content is safe.
This email may contain confidential and privileged material for the sole use of the intended recipient.
Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended
recipient (or authorized to receive for the recipient), please contact the sender by reply email and delete
all copies of this message.
Payable Register
•PEMBROKE PARK
1111••·•·••••-111
, 11t•MMIM:/1'1\
Payable #
Pembroke Park, FL
Discount Date
Packet: APPKT00640 - January 6, 2022-Police
3293590 Invoice 12/19/2022 12/19/2022 12/19/2022 12/19/2022 891.65 0.00 0.00 0.00 891.65
Crossing Guard Svc Week Ending 12/18/2022 SYNOPER - Synovus - operating Account No
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Crossing Guard Svc Week Ending 12/18/… Service 0.00 0.00 891.65 0.00 0.00 0.00 891.65
Distributions
Account Number Account Name Project Account Key Amount Percent
001-510519-340004-00-0000 Various Contractual Services 891.65 100.00%
3293623 Invoice 12/27/2022 12/27/2022 12/27/2022 12/27/2022 891.65 0.00 0.00 0.00 891.65
Crossing Guard Svc Week Ending 12/25/2022 SYNOPER - Synovus - operating Account No
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Crossing Guard Svc Week Ending 12/25/… Service 0.00 0.00 891.65 0.00 0.00 0.00 891.65
Distributions
Account Number Account Name Project Account Key Amount Percent
001-510519-340004-00-0000 Various Contractual Services 891.65 100.00%
1YKF-PF7G-FKFH Invoice 11/14/2022 11/14/2022 11/14/2022 11/14/2022 667.67 0.00 0.00 0.00 667.67
Projector Screen, Audio Mixer-Movie in the … SYNOPER - Synovus - operating Account No
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Projector Screen, Audio Mixer-Movie in … NA 0.00 0.00 667.67 0.00 0.00 0.00 667.67
Distributions
Account Number Account Name Project Account Key Amount Percent
001-570572-640000-00-9056 Community Movie Night 667.67 100.00%
23010902 Invoice 1/9/2023 1/9/2023 1/9/2023 1/9/2023 4,505.68 0.00 0.00 0.00 4,505.68
Teletype Services Decemeber 2022 SYNOPER - Synovus - operating Account No
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Teletype Services Decemeber 2022 Service 0.00 0.00 4,505.68 0.00 0.00 0.00 4,505.68
Distributions
Account Number Account Name Project Account Key Amount Percent
001-520521-340004-00-0000 Various Contractual Services 4,505.68 100.00%
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Pre-Employment Polygraph Service 0.00 0.00 375.00 0.00 0.00 0.00 375.00
Distributions
Account Number Account Name Project Account Key Amount Percent
001-520521-599999-00-0000 Miscellaneous Expense 375.00 100.00%
This is a five year lease contract to be paid annually for the Police Dept
Vendor: 69947 - First Choice Mobile Auto Repair, In Vendor Total: 753.50
11262022STMT Invoice 11/26/2022 11/26/2022 12/26/2022 12/6/2022 68.50 0.00 0.00 0.00 68.50
Oil and Filter Change for 2021 Dodge Charge… SYNOPER - Synovus - operating Account No
Notes: VIN# ending 88850
11282022STMT Invoice 11/28/2022 11/28/2022 12/28/2022 12/8/2022 68.50 0.00 0.00 0.00 68.50
Oil and Filter Change for 2021 Dodge Charge… SYNOPER - Synovus - operating Account No
Notes: VIN# ending 88856
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Oil and Filter Change for 2021 Dodge Ch… Service 0.00 0.00 68.50 0.00 0.00 0.00 68.50
Distributions
Account Number Account Name Project Account Key Amount Percent
001-520521-599999-00-0000 Miscellaneous Expense 68.50 100.00%
11292022STMT Invoice 11/29/2022 11/29/2022 12/29/2022 12/9/2022 68.50 0.00 0.00 0.00 68.50
Oil and Filter Change for 2021 Dodge Charger SYNOPER - Synovus - operating Account No
Notes: VIN# endinng 88853
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Oil and Filter Change for 2021 Dodge Ch… Service 0.00 0.00 68.50 0.00 0.00 0.00 68.50
Distributions
Account Number Account Name Project Account Key Amount Percent
001-520521-599999-00-0000 Miscellaneous Expense 68.50 100.00%
11292022STMT-A Invoice 11/29/2022 11/29/2022 12/29/2022 12/9/2022 68.50 0.00 0.00 0.00 68.50
Oil and Filter Change for 2021 Dodge Charger SYNOPER - Synovus - operating Account No
Notes: VIN# ending 85273
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Oil and Filter Change for 2021 Dodge Ch… Service 0.00 0.00 68.50 0.00 0.00 0.00 68.50
Distributions
Account Number Account Name Project Account Key Amount Percent
001-520521-599999-00-0000 Miscellaneous Expense 68.50 100.00%
11292022STMT-B Invoice 11/29/2022 11/29/2022 12/29/2022 12/9/2022 68.50 0.00 0.00 0.00 68.50
Oil and Filter Change for 2021 Dodge Charger SYNOPER - Synovus - operating Account No
Notes: VIN# ending 88848
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Oil and Filter Change for 2021 Dodge Ch… Service 0.00 0.00 68.50 0.00 0.00 0.00 68.50
Distributions
Account Number Account Name Project Account Key Amount Percent
001-520521-599999-00-0000 Miscellaneous Expense 68.50 100.00%
11302022STMT Invoice 11/30/2022 11/30/2022 12/30/2022 12/10/2022 68.50 0.00 0.00 0.00 68.50
Oil and Filter Change for 2022 Ford Explorer SYNOPER - Synovus - operating Account No
Notes: VIN# ending 00601
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Oil and Filter Change for 2022 Ford Expl… Service 0.00 0.00 68.50 0.00 0.00 0.00 68.50
Distributions
Account Number Account Name Project Account Key Amount Percent
001-520521-599999-00-0000 Miscellaneous Expense 68.50 100.00%
11302022STMT-A Invoice 11/30/2022 11/30/2022 12/30/2022 12/10/2022 68.50 0.00 0.00 0.00 68.50
Oil and Filter Change for 2021 Dodge Charger SYNOPER - Synovus - operating Account No
Notes: VIN# ending 88857
12062022STMT Invoice 12/6/2022 12/6/2022 1/5/2023 12/16/2022 68.50 0.00 0.00 0.00 68.50
Oil and Filter Change for 2021 Dodge Charger SYNOPER - Synovus - operating Account No
Notes: VIN# ending 80019
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Oil and Filter Change for 2021 Dodge Ch… Service 0.00 0.00 68.50 0.00 0.00 0.00 68.50
Distributions
Account Number Account Name Project Account Key Amount Percent
001-520521-599999-00-0000 Miscellaneous Expense 68.50 100.00%
12062022STMT-A Invoice 12/6/2022 12/6/2022 1/5/2023 12/16/2022 68.50 0.00 0.00 0.00 68.50
Oil and Filter Change for 2014 Ford Taurus SYNOPER - Synovus - operating Account No
Notes: -VIN# ending 02951
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Oil and Filter Change for 2014 Ford Taur… Service 0.00 0.00 68.50 0.00 0.00 0.00 68.50
Distributions
Account Number Account Name Project Account Key Amount Percent
001-520521-599999-00-0000 Miscellaneous Expense 68.50 100.00%
12222022STMT Invoice 12/22/2022 12/22/2022 1/21/2023 1/1/2023 68.50 0.00 0.00 0.00 68.50
Oil and Filter Change for 2021 Dodge Charger SYNOPER - Synovus - operating Account No
Notes: VIN# ending 88851
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Oil and Filter Change for 2021 Dodge Ch… Service 0.00 0.00 68.50 0.00 0.00 0.00 68.50
Distributions
Account Number Account Name Project Account Key Amount Percent
001-520521-599999-00-0000 Miscellaneous Expense 68.50 100.00%
12222022STMT-A Invoice 12/22/2022 12/22/2022 1/21/2023 1/1/2023 68.50 0.00 0.00 0.00 68.50
Oil and Filter Change for 2021 Dodge Charger SYNOPER - Synovus - operating Account No
Notes: VIN# ending 88852
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Oil and Filter Change for 2021 Dodge Ch… Service 0.00 0.00 68.50 0.00 0.00 0.00 68.50
Distributions
Account Number Account Name Project Account Key Amount Percent
001-520521-599999-00-0000 Miscellaneous Expense 68.50 100.00%
Vendor: 46946 - Law Enforcement Psychological and Counseling Association Inc. Vendor Total: 315.00
12948 Invoice 12/20/2022 12/20/2022 12/20/2022 12/20/2022 315.00 0.00 0.00 0.00 315.00
SYNOPER - Synovus - operating Account No
Vendor: 36141 - Occupational Health Centers Of The Southwest, P.A. Vendor Total: 154.00
1156038469 Invoice 12/26/2022 12/26/2022 1/25/2023 1/5/2023 154.00 0.00 0.00 0.00 154.00
Drug Screening SYNOPER - Synovus - operating Account No
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Drug Screening Service 0.00 0.00 72.00 0.00 0.00 0.00 72.00
Distributions
Account Number Account Name Project Account Key Amount Percent
400-530535-490900-00-0000 Misc. Charges 72.00 100.00%
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
Drug Screening Service 0.00 0.00 82.00 0.00 0.00 0.00 82.00
Distributions
Account Number Account Name Project Account Key Amount Percent
001-520521-599999-00-0000 Miscellaneous Expense 82.00 100.00%
Vendor: 60007 - STAPLES Contract & Commercial, Inc Vendor Total: 608.30
3525391856 Invoice 12/13/2022 12/13/2022 12/13/2022 12/13/2022 608.30 0.00 0.00 0.00 608.30
1inch Binder, Post-It, Paper, Batteries, Scisso… SYNOPER - Synovus - operating Account No
Vendor: 75168 - TransUnion Risk & Alternative Data Solutions Inc. Vendor Total: 100.00
6127732-202212-1 Invoice 1/10/2023 1/10/2023 1/10/2023 1/10/2023 100.00 0.00 0.00 0.00 100.00
TLOxp Investigative Services December 2022 SYNOPER - Synovus - operating Account No
Items
Item Description Commodity Units Price Amount Tax Shipping Discount Total
TLOxp Investigative Services December … Service 0.00 0.00 100.00 0.00 0.00 0.00 100.00
Distributions
Account Number Account Name Project Account Key Amount Percent
001-520521-599999-00-0000 Miscellaneous Expense 100.00 100.00%
Payable Summary
Type Count Gross Tax Shipping Discount Total Manual Payment Balance
Invoice 29 35,685.33 0.00 52.48 0.00 35,737.81 0.00 35,737.81
Grand Total: 35,685.33 0.00 52.48 0.00 35,737.81 0.00 35,737.81
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EXHIBIT 13
From: Maribel Rosario <[email protected] >
Sent: - -02410:33 AM
To:
Subject: Re: Follow-Up - Subpoena OIG 23-018-M-001
Attachments: SUN QUOTE 12 21 22 FOR SOP JOY.pdf; SUN QUOTE 12 21 22 FOR SOP JOY 3hrs.pdf;
SUN QUOTE 12 21 22 FOR 40P JOY 3hrs.pdf
I Report Suspicious
Good morning- don't have much of what we went over before t his has been long. attached are all 3
quotes we worked on. Only 24 guests came to t he event. and Mr Jacob was on board. joy wasn't. was
anot her person that said to my floor manage r that there were 4 hours events not 3hrs named Mayer Ray.
She brought her own dj. His number was 754 234 8124 Eri ck. Honestly t hi s is all I can remember and
searc h for.
Maribel Rosario
Sales and Event Coordinator
Office: 305-922-5980
Mobile: 754-423-6147
www.starvisionyachtcharters.com
Maribel Rosario
Sales and Event Coordinator
Office: 305-922-5980
Mobile: 754-423-6147
www.starvisionyachtcharters.com
1
Starvision Yacht Charters
www.starvisionyachtcharters .com
[email protected]
ST,ARVISION
V A C ., 7 CHARTERS & EVE N TS
Mobile: 754-423-6147
Office: 305 922 5980
ENHANCEMENTS
ENTERTAINMENT
DJ $750.00
LABOR CHARGE $2.375.00
CARD PROCESSING 4%
Subtotal $ 13,825.00
EVENT DETAILS
Sales Tax .' Admin Fee $967.75
Gratuitv
Total $14.792.75
$14,792.75
------------------
SETUP Gratuity Optional 100/o
150/o
200/o
$1,382.50
$2,073.75
$2,765.00
Starvision Yacht Charters
www.starvisionyachtcharters.com
[email protected]
ST,ARVISION
V A C ., 7 CHARTERS & EVE N TS
Mobile: 754-423-6147
Office: 305 922 5980
ENHANCEMENTS
ENTERTAINMENT
DJ $750.00
LABOR CHARGE $1,937.50
CARD PROCESSING 4%
Subtotal $11,512.50
EVENT DETAILS
Sales Tax .' Admin Fee/none $0.00
Gratuitv $1 000.00
Total $12.512.50
$12,512.50
------------------
SETUP Gratuity Optional 100/o
150/o
200/o
$1,151.25
$1,726.88
$2,302.50
Starvision Yacht Charters
www.starvisionyachtcharters.com
[email protected]
ST,ARVISION
V A C ., 7 CHARTERS & EVE N TS
Mobile: 754-423-6147
Office: 305 922 5980
ENHANCEMENTS
ENTERTAINMENT
DJ BY CLIENT $0.00
LABOR CHARGE $1,700.00
CARD PROCESSING 4%
Subtotal $9,575.00
EVENT DETAILS
Sales Tax .' Admin Fee/none $0.00
Gratuitv $1 000.00
Total $10.575.00
$10,575.00
------------------
SETUP Gratuity Optional 100/o
150/o
200/o
$957.50
$1,436.25
$1,915.00
OIG 23-018-M
APPENDIX A
Town of PembrokePark TOWN OF
PEMBROKE PARK
3150 SW 52 nd Avenue• Pembroke Park, Florida 33023 FLORID,\
The Town of Pembroke Park {the "Town") has received and reviewed the Preliminary Report
prepared by the Office of the Inspector General ("OIG") dated August 1, 2024, regarding the
alleged unlawful procurement of a $10,575 yacht charter for the Town's 2022 annual holiday party
for staff (the "Preliminary Report"). This response to the Preliminary Report is submitted pursuant
to Section 10.01 (D)(2)(a) of the Broward County Charter.
The OIG's investigation concluded that the Town's then-Mayor Geoffrey Jacobs unlawfully
contracted with a vendor for a $10,575 yacht charter for the Town's 2022 annual holiday party
without first obtaining competitive proposals 1. Mayor Jacobs is alleged to have been assisted in
this effort by the Town's former Finance and Budget Director. It is important to note that the
Preliminary Report does not find or allege that Mayor Jacobs or the former Finance and Budget
Director took any action to improperly enrich themselves or others. Nevertheless, the Town
1 Consistent with the Preliminary Report, this response refers to Geoffrey Jacobs as Mayor, a position he held at the
time ofthe alleged incident; however, Mr. Jacobs currently serves as a Town Commissioner. In addition, Mayor Jacobs
has been provided a copy of the Preliminary Report and may be submitting his own response to the allegations and
findings set forth therein.
recognizes the gravity of the issues identified in the Preliminary Report. This response is intended
to respond to a number of the representations set forth the Preliminary Report and to detail the
corrective action that has already been taken by the Town in an effort to address the issues raised
by the OIG.
Primary in its response, the Town can confirm that a multitude of policies, controls and safeguards
have been implemented by the Town since the Town's 2022 holiday party which will address the
procurement issues detailed in the Preliminary Report. The Town Commission has also recently
engaged the undersigned Acting Town Manager, who affirms his commitment to ensuring that
the Town is compliant with all rules and regulations related to procurement and the expenditure
of public funds. Further, the Town Attorney's Office, which was retained by the Town Commission
in an interim capacity in February 2023 and retained permanently in March 2024, is further
engaged and committed to supporting the Town Commission and the Town's professional staff in
their good faith efforts to comply with all local, state and federal laws.
On September 28, 2023, the OIG issued its Closing Memorandum re: The Town of Pembroke
Park Lacks Adequate Authority to Control its Purchasing Card Expenditures, Ref. 22-007-M (the
"P-Card Report"). The P-Card Report investigated certain allegations related to misuse of the
Town's purchasing credit cards, and concluded that the Town had a lack of "adequate law, policy
and procedures regulating p-cards and travel expenditures." While the issues identified in the
pending Preliminary Report are not identical to the issues raised in the P-Card Report, there is a
commonality in the context of procurement and safeguarding the expenditure of public funds.
Many of the steps taken by the Town in response to the P-Card Report will help address the
recent issued raised by the OIG related to the Town's 2022 annual holiday party.
In response to the P-Card Report, the Town Commission, at the recommendation of the OIG and
the Town Attorney's Office, adopted a number of policies and procedures, including, but not
limited to, the following:
Page 2 of5
2) Travel Reimbursement Policy - adopted on December 13, 2023 pursuant to Ordinance
No. 2023-014;
3) Utilization of a Credit Card User Agreement signed by staff members and members of the
Town Commission who use p-cards confirming acknowledgement of and compliance with
the Town's rules and regulations regarding p-card usage; and
4) All individuals, including members of the Town Commission, possessing Town p-cards
have undergone procurement training either by the Town's professional staff or the Town
Attorney's Office.
Additionally, while not specifically recommended by the OIG, Mayor Jacobs also voluntarily
surrendered his p-card to the Acting Town Manager. Mayor Jacobs, who was named in both the
P-Card Report and the Preliminary Report, is no longer in possession of a Town credit card.
Further, Mayor Jacobs, along with the rest of the Town Commission, has completed procurement
training; and, aside from action that may be taken at a public meeting, Mayor Jacobs is not
currently involved in any aspect of procurement for the Town.
On May 21, 2024, the OIG issued its follow-up report in response to the Town's efforts to address
the OIG's concerns raised in the P-Card Report. In its follow-up report, the OIG expressly stated,
that "We [the OIG] are pleased to report that the Town has followed virtually all of the OIG's prior
recommendations on the subject." The OIG's follow-up further noted that "We [the OIG] found
that the Town made significant improvement in the protection of taxpayer funds. Although it
tolerated unchecked p-card use in the past, with the implementation of virtually all of the OIG's
September 2023 recommendations, it no longer does so."
In response to the OIG's recent investigations, the Town Commission, in conjunction with the
Town's professional staff and Town Attorney's Office, has worked diligently to restructure and
streamline the Town's procurement procedures. In addition to the adoption and codification of
various policies and procedures, this effort has also included the reclassification of a Town
employee as a dedicated purchasing agent tasked with overseeing all of the Town's procurement.
This individual has recently completed the requisite training and has obtained her purchasing
agent certification.
In defense of then-Mayor Jacobs, the former Finance and Budget Director, and any other staff
member involved in the planning and procurement of the 2022 holiday party, it is relevant to note
the procurement exclusions set forth in Sec. 2-125 of the Town Code. More specifically, Sec. 2-
125(d)(21) of the Town Code expressly states, as follows:
(d) Exclusions. The mandatory commission approval amount and the competitive
solicitation and selection processes set forth in this article shall not apply to the
following:
(21) Purchase for services and facilities at hotels, motels, restaurants and
similar facilities for Town sponsored events.
While the undersigned Acting Manager and the current Town Attorney were not involved or
advising the Town in December 2022, it is possible that the Town was operating under this
exclusion to the competitive solicitation requirements for the procurement of the 2022 holiday
party. In other words, the yacht charter for the holiday event may have been considered to fall
within the exclusion for the procurement of facilities for Town-sponsored events. Admittedly,
such an exclusion does not absolve the Town of the other procurement concerns identified in the
Preliminary Report.
Notwithstanding the foregoing, the Town Commission, the Acting Town Manager and the Town
Attorney's Office remain committed to continuing to strengthen the Town's policies, procedures
and controls as they relate to procurement and the expenditure of public funds.
Ill. CONCLUSION
While the OIG's Preliminary Report admittedly revealed a number of procedural deficiencies
related to the procurement of the Town's 2022 annual holiday party, there was no evidence or
indication that any Town commission member or Town employee, current or former, sought to
enrich themselves or others as a result of that procurement.
Page 4 of5
Furthermore, since 2022, the Town has taken significant action to strengthen its procurement
procedures and to better ensure compliance with all applicable local, state and federal rules,
policies and regulations. While some of this effort was initiated as a result of OIG findings and
recommendations, the undersigned Acting Town Manager and the Town Attorney's Office have
also made independent recommendations to Town Commission related to best procurement
practices and other steps to safeguard the expenditure of public funds.
The new administrative leadership in the Town remains committed to continuing to improve its
procurement procedures and to ensure that the Town is an accountable steward of the public's
trust. The Town expresses its gratitude to the staff of the OIG for its thorough review of this matter
and for the recommendations that have assisted the Town in its ongoing efforts to improve its
operations.
Sincerely,
Page 5 of5