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Documents Released Surrounding Investigation of Violation of City’s Fraud Hotline Protocol

In a notable win for transparency in the City of Carson, the Carson Accountability & Transparency (CAT) group secured the release of a City Investigative Report into alleged misconduct stemming from an anonymous complaint filed via the Fraud Hotline in October 2015.

For more than a decade the City of Carson has operated a Fraud Hotline, established for the purpose of preventing and detecting fraud related to city employees, vendors, contractors and elected officials.  The Protocol established followed strict guidelines to ensure confidentiality for both whistle blowers and alleged abusers of city resources.  Since inception in 2004, it has been a trusted source for whistle blowers and resulted in numerous verifiable complaints causing, in some cases, criminal charges, employee termination and revision of city policies.

At issue in CAT’s recent request was an anonymous complaint which involved two elected officials.  It was clearly demonstrated that the confidential handling and established protocol was violated when the subject of the complaint demonstrated receipt of it by discussing the matter and showing the document at a public Council Meeting in 2015.  The purpose of the anonymous process is to provide safety to whistle blowers and those named in the complaint; but employee names were disclosed in this public display.

In November of that year, Carson commissioned an outside firm, Norman A. Traub Associates, to conduct an independent investigation into the matter. In June 2016 the investigation concluded and was discussed behind closed doors at a City Council meeting. The public results shared at that meeting indicated the investigator’s report substantiated mistrust among elected official(s) involved thereby causing an overhaul of Fraud Hotline Protocol.  However, the public was denied access to the actual report and its findings, which were paid for with taxpayer dollars, not to mention involved two elected officials.

The investigator recommends that this report be made public and the city council take those measures they deem appropriate to uphold and maintain the public trust...

Multiple requests for the investigator’s report were made by various Carson residents over the past several years. All were denied. Carson Accountability & Transparency retained legal services of Gary Winuk, the former Chief of Enforcement for the California Fair Political Practices Commission.

In a letter to the City Attorney this February, Winuk wrote “The severe violations of these processes by providing information about a person complaining to a City Council member who was the subject of the complaint to allow her to attempt to retaliate was bad enough. The failure to disclose the records of the investigation that examined what went wrong is unconscionable. There is no articulable exemption under the CPRA [California Public Records Act] that would outweigh the public’s interest in this disclosure.”

The investigation materials were disclosed within a month of this letter. Its contents were remarkable.

Notably, in the document’s conclusions, “The investigator recommends that this report be made public and the city council take those measures they deem appropriate to uphold and maintain the public trust.”

In a follow-up letter to the City Council dated March 27, CAT asked “that the city publish the full report on its public website,” consistent with the investigator’s recommendations. CAT received no reply.

As such, the full report is being made available on CAT’s website at

CAT’s interest is in assisting the city’s upholding and maintaining of public trust, and CAT will be publishing these findings in the spirit of that collaboration.

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