"WHEREAS, the Approval Request Letter represented that the Governor will abide by all nine
of the established requirements for receiving compensation for writing a book and, in particular,
represented to the Commission that Governor Cuomo will write the (B)ook entirely on his own
time, without the use of State resources or personnel; and
WHEREAS, by letter dated July 17, 2020, the Commissions staff issued an informal advisory
opinion conveying conditional approval of the outside activity described in the Approval Request
Letter (the Conditional Approval Letter); and
WHEREAS, among the other conditions to approval stated therein, the Conditional Approval
Letter imposed, without qualification or exception, the condition that No state property,
personnel or other resources may be utilized for activities associated with the book; and
WHEREAS, contrary to the representations made on behalf of Governor Cuomo, and not
disclosed to the Commission, State property, resources and personnel, including staff volunteers,
were used in connection with the preparation, writing, editing and publication of the Book; and
WHEREAS, the Approval Request Letter further represented that the Book would be a
continuation of Governor Cuomos first book, a memoir published in 2012, and that consistent
with item three of the nine established requirements the subject matter was sufficiently
unrelated to his job responsibilities so that authorship or the advice or material provided in the
(B)ook could not be viewed as part of his job, and
WHEREAS, the Conditional Approval Letter expressly conveys conditional approval of outside
activity comprised solely of authoring a continuation of [the Governors] last book, All Things
Possible: Setbacks and Successes in Politics and Life.
WHEREAS, contrary to the representations made in the Approval Request Letter, the Book is
not in compliance with item three of the Commissions nine established conditions to approval as
stated in the Conditional Approval Letter, in that it is a work that was developed as part of
Governor Cuomos job responsibilities and is substantially related to his job responsibilities;
"