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The result will contain the open and close for the given period, as well as the maximum and minimum over the new period, reflected in the new high and low, respectively.
The declaration states that “You will for the period you receive the subsidy: use your best endeavours to pay at least 80 per cent of each named employee’s ordinary wages or salary;”
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Section 19 prohibits a municipal employee from participating as such an employee in a particular matter in which to his knowledge he or a business organization in which he is serving as an employee has a financial interest. Although the law office of X would be considered a business organization your relationship with it does not rise to the status of “employee” sufficient to invoke the participation prohibitions of §19. This conclusion is based on the comparatively small portion of your income attributable to services which you perform for the law offices. See EC-COI-83-34. However, should your situation change and a more substantial portion of your time and income be attributable to the services you provide to X, then you would be regarded as an employee for the purposes of §19. You would then be prohibited from taking any action in your capacity as assistant town counsel on any matter in which the law offices had a financial interest. Obviously you are also prohibited from acting in your municipal job on any matter in which you personally have a financial interest, such as any aspect of one of your own client’s cases. Again, as you have stated that the city solicitor is aware of your office-sharing arrangement and screens you from all matters where the law offices are involved, there is no violation of this section.
Section 18(d) prohibits the partners of a municipal employee from acting as agent or attorney for anyone other than the city in connection with any particular matter in which the same city is a party or has a direct and substantial interest, and in which the municipal employee participates or has a participated as a municipal employee or which is the subject of his official responsibility. To advance the purposes of the law, the term “partner” is not restricted to those who enter formal partnership agreements. Thus the Commission has held in previous opinions that a partner is any person who joins with another, formally or informally, in a common business venture. The substance of the relationship is what counts, not the terms the parties use to describe the relationship. Additionally, if a group creates a public appearance of a partnership (for example by linking their names on a letterhead, business cards and business listing), they may be treated as partners even though they may not, in fact, share profits. See EC-COI-82-68; 82-19; 80-43.  See also Formal Opinion 310, ABA Committee on Professional Ethics (June 20, 1963); Massachusetts Bar Association Ethical Opinion 76-19. The substance of your arrangement with X does not constitute a partnership. The occasional payment you receive on an hourly basis from X constitutes a fee for services arrangement rather than a sharing of profits.  You maintain separate files and have your own secretary. However, the fact that your names are linked in the letterhead title would create the public appearance of a partnership, thereby triggering the prohibitions of §18 (d). The ability of X and the other attorney to represent clients in matters in which ABC is a party or has an interest might well be severely limited. In order to prevent this result your name should not be linked with the other two names at the top of the letterhead. The mere listing of your name under X’s in the left-hand side of the stationery would not create the same public appearance of a partnership. Likewise, if you were to be listed as being “of counsel” the Commission has held in the past that such a listing is not by itself sufficient to create a public appearance of a partnership. See EC-COI-83-81.