Ethics Violation Filed Concerning GCEL

To the people of Washington State:

Someone said to me many years ago that the denial of rights to our children with disabilities is because there is not enough funding to support the programs needed to educate our students with disabilities.  I decided to find out why.

Below is an ethics complaint filed against Governor Gary Locke.  In September 2001 I filed an ethics complaint against B.J. Wise and Dr. Terry Bergeson, which is presently being investigated by the executive ethics board.  Knowing that many of you may disagree with my efforts to ensure that our government is held accountable for there activities, in relation to the dispersing of our money, and may be inclined to express your anger of my exposing the facts associated with the expenditures of our Governor and Superintendent, I remain confident that my efforts will benefit the people of this state by affirming to our government leaders that "all political power is inherent in the people, and governments derive their just powers from the consent of the governed, and are established to protect and maintain individual rights" (Washington State Constitution Article 1 Section 1).  Parents, teachers, administrators, all civil service workers, private sector workers, all citizens of this state must hold our government agencies' elected officials and their exempt staff accountable for their activities.  I have and will continue to do so.

Should you feel it necessary to express your thoughts, please share them with our Governor and Superintendent.

Nancy Vernon

What follows is the body of the complaint filed by Nancy Vernon with the Washington State Executive Ethics Board, against Governor Gary Locke, concerning the GCEL.


I am filing a complaint against Governor Gary Locke alleging he has violated ethics law RCW 42.52.070 Special privileges, which specifically states,

Except as required to perform duties within the scope of employment, no state officer or state employee may use his or her position to secure privileges or exemptions for himself or herself, or his or her spouse, child, parents, or others.

After a review of public documents pertaining to the Governor's Commission on Early Learning (GCEL), created in 1998 and ending in May 2000, I believe Governor Locke used public funds and his position to secure for his wife a highly prestigious, influential and powerful position.  Aside from the fact that Governor Locke appointed Mrs. Locke as a co-chair to the GCEL, the GCEL resulted in the creation of the Foundation for Early Learning making Mrs. Mona Lee Locke, the Chair of the non-profit organization, which I believe receives funding/donations from the Melinda and Bill Gates Foundation.

It appears that Governor Gary Locke wrote into the 1999-00, budget proposal 2 million dollars to fund the Commission on Early Learning, in which he appointed as co-chairs Mrs. Mona Lee Locke and Mrs. Melinda Gates.  An email from Tom Saelid dated, May 19, 1999, states,

The legislature cut $500,000 from the Governor's proposal which is the $2 million campaign.  So what is included in the OFM budget is $500,000 free and clear and the option of getting $500,000 more, if we raise that much privately.  Therefore only a $1.5 million campaign.

The 1999-00, budget specifically states,

$1,000,000 of the general fund-state appropriation and $500,000 of the general fund-private/local appropriation are provided solely for the commission of early learning.  One-half of the amount provided from the general fund-state shall not be expended unless matched by an equal amount from private sources.

It is important to note that the Commission on African-American Affairs received a total of $378,000 for a two-year period and the Commission on Hispanic Affairs received a total of $441,000 for a two-year period (combined is less than 1 million).

The December 1998 meeting minutes for the GCEL stated,

Melinda Gates welcomed the Commission and made a few announcements.  First Melinda announced that the Governor had originally placed one million dollars into his budget to support the Commission's efforts.  Since then, the Governor has been able to identify another $500,000 raising the original amount to 1.5 million.  The $500,000 must be matched with private funds.  Governor's Webpage.

Also, noted on the public documents received, it states,

An interagency agreement between OFM and DSHS provided the administrative funding for the Governor's Commission on Early Learning.

The agreement per OFM IAA No. 670-00 was for $250,000 for one year.  A contract with Cocker Fennessy was for 1 million and then an amendment increased the amount by $500,000, with a total of 1.5 million.

At the final meeting in May 2000, it was noted in the meeting minutes,

He [Governor Locke] commented that most Commissions go no farther than making recommendations.  The creation of an ongoing entity to implement the Commission's findings is a unique accomplishment.

However, it is noted on the public document I received the following:

One of the activities of the Commission was to create the Washington Early Learning Foundation (now renamed the Foundation for Early Learning) a 501 (c) (1) non-profit agency.

The $500,000 private/local funding was received from the Washington Early Learning Foundation.

I have asked the Governor's office to clarify how a foundation, yet to be created, was able to donate $500,000 to a commission responsible for creating the entity donating the money.  I made my inquiry per an email to Robin Zukoski on January 22, 2002, and received the following response:

The clarification you request will be provided along with the response to your pending public disclosure request.

The contract with Cocker Fennessy was initiated to implement the GCEL's Public Engagement Campaign.  At the July 20, 1999, GCEL meeting it is noted in the meeting minutes the following:

Mona then asked with the money allotted, 1.0 million, with potential for more, where could we go?

Rick explained that they were thinking about an A and B track depending upon the level of partnerships.  One level at the minimum the next at a more significant level.

Sheri Flies then asked what are the dollar figures for this outline – what will this cost?

Dave explained that this would be a minimum of 1.5 million – what the Commission has been allotted.  3.5 million dollars could sustain the campaign over 2 or 3 years.

On July 29, 1999, an amendment to the Cocker Fennessy contract was made by adding $500,000 more.

I have requested to inspect, if such document exists, the public announcement of appointments to the GCEL.

My concerns are not in relation to whether Mona Lee Locke financially benefited, as Governor Locke clarified in our telephone conversation on January 4, 2002 that Mona donated all her time and energy; however, the issue in question is whether Governor Locke used his high ranking position and special privileges to establish a commission, providing his wife the opportunity to co-chair, and then writing into the budget 2 million dollars to support the commission's efforts, and then creatively establishing a funding source to administrator the commission's meetings by accessing funding from the Department of Social and Health Services (DSHS), by way of an interagency agreement between the Office of Financial Management and the Department of Social and Health Services for the amount of $250,000.  Also, there was an agreement between the Department of Personnel and the Office of Financial Management to pay for the June 1999 commission meeting for the amount of $1500, specifically for the facilitator.  There also was an agreement between the Department of Personnel (DOP) and the Office of the Governor stating that the Governor's office will reimburse DOP up to $12,000 to prepare and facilitate monthly meetings of the GCEL for the August 1998 through June 1999 meetings.  A final contract with Child Care Services for consultation for the amount of $4,000 was initiated with OFM.

Is it ethical for our Governor to use public money to fund a commission serving to promote his wife, leading to a position as the chair of a foundation that grew out of seed monies obtained from the taxpayers of Washington State?  Furthermore, it appears that the Foundation already existed, but was simply renamed, and the people of Washington State paid for the advertisement to promote the foundation, as well as fund the so-called "research" resulting from the commission's existence.  Moreover, would Mona Lee Locke have been the co-chair of the commission and then the chair of a renamed foundation if it were not for her husband being the Governor, with the ability to designate the funding to support a commission serving to create a foundation already in existence?

When filing an ethic complaint the complainant has the choice of disclosure or nondisclosure.  Believing that nondisclosure would not serve its purpose in this situation, as I am most likely the only citizen that has requested to inspect the public documents associated with the Commission; however, I would like to stress that I have been threatened by two of the Governor's staff members on two separate occasions.  The first incident I was told to leave the Governor's executive policy advisors' office and when I was unable to leave immediately due to my seven-year old deaf and blind son exploring the environment I was told that security would be called.  My nine-year-old son was a witness to the threat.  I visited the Governor's office with my two sons so that I could leave an in-person message for the education policy advisor to please return or respond to my calls, emails and letters.  I had not previously visited the Governor's office, other than an appointment with the former policy advisor some two years ago.  The second incident involved the Governor's community relation's person.  In my efforts to receive a written response to my concerns relating to children with disabilities from the Governor, I was informed by the community relations staff member that I was not to be trusted and that if I continued to request a letter I would get "nasty" letters from the Governor's attorney and staff.  I have addressed these two incidents in a letter to Governor Locke and Christine Gregoire.  I also informed Governor Locke directly in our telephone conversation on January 4, 2002, and have yet to hear of any action taken.

My initial request to receive public documents from the Governors office resulted in a letter being sent to me from Leslie Frank, Governor Locke's Administrative Services Manager, that I would be charged 15 cents a copy.  I contacted the Attorney General's office and as a result I was provided the documents for inspection at no cost.

It is my hope that the threats, harassment and attempts to intimidate me will not continue; however it appears that as I continue to expose the truth of our government I will continue to be subjected to unfavorable behavior by public officials.  I share these sentiments with you as a precaution should it continue as a result of this complaint.

All documents and letters quoted or addressed in the complaint are attached.