Right before she was elected to a second term into office, a series of stories by the New York Times detailed the practice of law firms who were skilled at developing contacts and relationships with the top lawyers of various states - including Attorney General Pam Bondi. These firms helped out corporate clients whose businesses had been targeted by some states, but not others.
One of the stories also pointed out that Bondi allowed a lawyer from one of the firms to recuperate from surgery at Bondi's house.
Now 16 months later the matter has come to a quiet close - at least as it concerns Florida's ethics laws.
The Florida Commission on Ethics voted last week there was no probable cause to conclude that the now-defunct law firm Dickstein Shapiro - or one the lawyers who used to work at the firm, Bernard Nash - had broken the state's ethics laws. The finding was made public Wednesday.
The probe into their activities focused on two items: Was it a violation of Florida's gift ban for the firm and Nash to donate money to an organization that wound up paying for trips by Bondi? During her first four years in office Bondi accepted more than $51,000 worth of travel costs, hotels and meals to conferences and other events with other attorneys general. The trips to places such as California, Michigan and countries such as Mexico were picked up by groups such as the Republican Attorneys General Association.
The other part of the probe focused on whether activities by Nash and the firm constituted lobbying even though Nash and members of Dickstein Shapiro had not registered as lobbyists.
An outside lawyer brought in to help look into the case concluded in his report to the commission that in both instances the law had not been broken.
George Reeves argued that a contribution to RAGA was covered by a part of the lobbying law that makes it clear political contributions are not expenditures.
But during the commission meeting, Reeves acknowledged that the lobbying issue was a bit more complicated.
Lawyers are not considering lobbying if they are representing clients involved in a judicial proceeding. But in this instance Nash was reaching out to Florida on behalf of a client who was under investigation in another state. He called Bondi's then chief of staff, Carlos Muniz, and then sent him a follow up email about the issue.
Reeves told commissioners, according to audio that was released along with the files, that what Nash did was "very risky" and that others may be "well served" to register as a lobbyist but said in this instance there wasn't anything that should have prompted the commission to take action.
Yet a deeper look into the information does comes up with several interesting highlights:
1: Bondi herself was never questioned directly by investigators. The investigative report states "Her staff advised that due to her busy schedule and heavy workload she would be unavailable for an interview." Those close to Bondi contend that this may paint a somewhat inaccurate picture, arguing that after investigators interviewed Muniz they did not make it clear they wanted to talk to her.
2: During an hour-long recorded interview with Nash, he tells the commission investigator about how his firm would set up dinners and receptions where they would invite all attorney generals across the state to join them. He said that those from states with ethical restrictions would pay their own way. Nash is unsure if Bondi or Muniz, who usually accompanied her to some of the conferences, attended those dinners. But Nash said no log or register was ever kept of who attended the events. Nash was not asked if any receipts were kept to verify that attendees bound by ethical restrictions in fact paid.
Muniz told investigators that he is certain he and Bondi attended at least one of the meals and maybe more. He said both he and the attorney general always paid for their meals.
3: Nash explained the rationale behind the dinners as a way for his clients to deal directly with attorneys general: "It's an opportunity for them to hear them directly, not filtered through me, what AG’s are saying."
4: Nash downplayed a Bondi fundraiser that Dickstein Shapiro hosted at Mar-A-Lago, the club owned by GOP presidential frontrunner Donald Trump. He said that his firm was listed because it agreed to give a certain amount. "If you contribute less, you are just an ordinary peon."
5: The investigative report points out that Nash denied that he or any of the Dickstein Shapiro employees lobbied. But Reeves in his recommendations to the commission concluded that there was "insufficient evidence" to determine if the other employees _ including Lori Kalani, the attorney who stayed at Bondi's house, had lobbied Bondi's office. He noted that these employees had called or emailed Bondi's staff regarding issues involving several clients "yet the report of investigation does not elaborate on the substance of these communications and specifically whether matters of policy were discussed."
He added: "This is a very delicate area in which it seems that the line between advocating concerning "policy" and advocating the facts of a specific case could get very blurry," Reeves wrote. "Certainly it seems as though the safer practice would be for such an attorney to register as a lobbyist and then freely advocate for his client regarding the specific facts and policy without concern. However, such safer practice cannot create probable cause where it does not otherwise exist."
Even though Bondi was subjected to scrutiny over her free trips two years ago, she has continued to accept them since she was re-elected.
Gift disclosure forms show that since the fall of 2014 Bondi has received airfare, hotel and meals worth nearly $51,000, including more than $11,000 donated by the government of Taiwan during an eight-day visit in October of last year that appears to have been organized by the National Association of Attorneys General. She has also taken several trips paid by the Rule of Law Defense Fund - a group that bills itself as a "forum for Republican attorneys general to study, discuss and engage on important policy affecting the states and their citizens."