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April 15, 2019

PROTECTED AND CONFIDENTIAL ATTORNEY WORK PRODUCT

Mayor Troy Walker

Draper City
1020 East Pioneer Road
Draper, UT 84020

Re: Mountain Ridge Estates Investigation

Dear Mayor Walker:

At the request of the Draper City Council, I have conducted an investigation regarding any
potential conflicts between the developers of the Draper Mountain Ridge Estates Project and
Draper City officials.

Summary of Findings:

Upon conclusion of the investigation it is my opinion that there have been violations of the
Draper Code of Ethics and perhaps the Utah Municipal Officers and Employees Ethics Act in
this case. While I do not believe that Alan Summerhays has violated any ethics rules, he has been
placed in an awkward position by the Michels, creating a conflict of interest. As such, it would
be my recommendation that he recuse himself from voting on the Mountain Ridge Estate Project,
or at the very least, consult with the city attorney regarding his concerns.

I do not believe that the Michels have done anything illegal in the present case. However,
through their actions, as detailed below, in my opinion, they have created clear conflicts of
interest with both Alan Summerhays and Michele Weeks. As such, it is my opinion that both Mr.
Summerhays and Ms. Weeks recuse themselves from voting on the Mountain Ridge Estate
Project.

SALT LAKE OFFICE — 102 SOUTH 200 EAST, SUITE 800, SALT LAKE CITY, UTAH 84111
SANDY OFFICE — 9350 SOUTH 150 EAST, SUITE 820, SANDY, UTAH 84070
Mayor Troy Walker
Draper City
April 15, 2019
Page 2

Finally, I believe that there were potential ethics violations by Michele Weeks in connection with
the Teacher Appreciation Night and the Michels as detailed below. It is my opinion that a
complaint to the Draper City Ethics Commission is warranted, or if no such commission has
been established, such a complaint could be filed with the Utah State Political Subdivisions
Ethics Review Commission.

I. Background:

This investigation surrounds a proposed development near 2100 East Lake Bluff Drive in
Draper, Utah. The project is being proposed by Shaun and Ollie Michel and has been
ongoing for a number of years. In February, 2019, prior to a vote on the project,
Councilmember Alan Summerhays recused himself from the matter based on a potential
conflict of interest that he had, as his son was undergoing treatment for paralysis with
Neuroworx, a company where Shaun Michel serves on the board of directors.
Councilmember Summerhays has since reversed his recusal from the project. There have also
been rumors of other potential conflicts of interest with Councilmember Michele Weeks.

II. Scope of Investigation:

During the investigation, the following individuals were interviewed:

-Mayor Troy Walker

-City Manager David Dobbins
-Shaun Michel
-Ollie Michel
-Bruce Baird
-Councilman Alan Summerhays

-Councilmember Tasha Lowery

-Councilmember Marsha Vawdrey
-Councilmember Michele Weeks
-Councilman Mike Green
Mayor Troy Walker
Draper City
April 15, 2019
Page 3

III. Investigation Findings

Rather than summarizing each individual’s interview, this report will address the potential
conflicts of interest for Councilmember Summerhays and Councilmember Weeks separately.
Further details regarding individual interviews can be provided upon request.

A. Councilman Summerhays

The potential conflict between Alan Summerhays and the Michel’s stems from a tragic
accident where Councilmember Summerhays’ son was involved in December, 2019.
was paralyzed in the accident and is receiving treatment at Neuroworx, a
rehabilitation company where Shaun Michel serves on the board of directors.

It should be noted that prior to his son’s accident, Councilmember Summerhays was in favor
of the Mountain Ridge project.

According to Councilmember Summerhays, he was contacted a number of times by Shaun

Michel in Mr. Michel’s efforts to promote the project prior to his son’s accident. Mr. Michel
would frequent Guadalhonkey’s Restaurant (owned by Summerhays) and would sit in the
lobby for over an hour hoping to speak with Summerhays. Michel even sent Summerhays a
photograph of Michel and Michel’s son on a Harley motorcycle with a note stating “Wish
you were here.” The two however never went on a motorcycle ride together nor was anything
promised or offered.

After a couple of months trying to avoid Michel, Summerhays finally saw Michel after a vote
on the project. Michel approached Summerhays and Summerhays again tried to avoid him,
telling him “he did not mean to ditch him, but his son was recently involved in a serious
motor vehicle accident.” Michel responded that that was the reason he kept trying to get
ahold of Summerhays—to tell him about Neuroworx. Michel told Summerhays that “they
will take care of ” there. Summerhays did not know that Michel was on the board of
directors at the time. Further, his son had already independently decided to receive
treatment with Neuroworx while in the hospital as he became frustrated with treatment at the
University of Utah. had already filled out paperwork and scholarship applications
with Neuroworx prior to the meeting between Summerhays and Michel.
had originally learned of Neuroworx from her daughter’s sister in law.
Summerhays soon received a telephone call from , the main physician at Neuroworx
letting him know that there was an opening and that could begin treatment
immediately. He has had no other communications with Neuroworx staff.

Councilmember Summerhays later learned that Michel sits on the board of directors and
wondered if his son was receiving any special favors due to the connection with the
project. This led to Summerhays recusing himself from voting on the project. After being
Mayor Troy Walker
Draper City
April 15, 2019
Page 4

reassured by Michel that was not getting anything more than any other patient,
Summerhays rescinded his recusal. At the time of his interview however, Summerhays was
still concerned whether his son was receiving preferential treatment and whether his vote
could potentially impact his son’s treatment.

While the connection between Summerhays and Michel would prove coincidental, rumors
grew regarding preferential treatment of . The reason for this is due to
the fact that in June, 2018, Michel attended a board of directors meeting for Neuroworx. A
focus of the meeting was getting funding for Neuroworx. During that meeting, Michel
inquired whether any of the board members knew members of the Draper City council.
Michel stated that “he would make a significant donation to the organization if he could work
out the deal with the Suncrest project.” Contrary to the rumors, Michel did not specify an
amount that he would donate.

sat on the board and verified this story.

He knew Tasha Lowry, and therefore contacted her to inquire what issues the city had with
the project in order to relay them to Michel and hopefully resolve the City’s concerns.

Councilmember Vawdry was also contacted by a Neuroworx board member,

who left a voice message for her requesting that she approve the project so that proceeds
would be given to Neuroworx where his paralyzed son was receiving treatment.
Councilmember Vawdry did not return his call.

Councilmember Green also received a call from Neuroworx board member ,

inquiring the status of the Mountain Ridge project, and stating that Michel would donate a
significant amount to Neuroworx if the project was approved. Councilmember Green
explained the issues he had with the project to . He became angry after the call and
looked into whether or not this was a potentially unethical issue.

It is clear that Shaun Michel used his position on the board of Neuroworx to assist with
lobbying his efforts with Draper City. While the communications between board members
and city council members were awkward, it does not appear that they were unethical or
illegal. Further, the council members handled the communications appropriately and no
conflicts were created.

To date however, Alan Summerhays feels conflicted. He does not know if his son received
special treatment. Further, Alan questions whether his son’s treatment will be affected
depending on how he votes on the Michel’s project. He is concerned with the situation and
does not know what to do. He appropriately notified the council of his perceived conflict but
does not know how to proceed in the future. I have recommended that he seek counsel from
the Draper city attorney regarding the best way to proceed with his concerns.
Mayor Troy Walker
Draper City
April 15, 2019
Page 5

B. Councilmember Weeks:

The potential conflicts of interest regarding Councilmember Michele Weeks involve three
separate incidents: ’ fishing trip with Shaun Michel, ’
participation in Youthlinc, and a $1000 donation made to Ms. Weeks’ Teachers Appreciation
Night event. Each issue will be addressed herein.

In September, 2018, Councilmember Michele Weeks was running for office in the State
Legislature. At that time, Shaun Michel approached Ms. Weeks and gave her a donation in
the amount of $1000-1200 for her campaign. Ms. Weeks did not accept the check and sent it
back to Michel. Shortly thereafter, Weeks informed Michel that her
. Michel offered to take
fishing and Weeks thought that would be a good idea. Michel and
then went fishing for a few hours together at Strawberry Lake.

Michel recommended that both

(an entity where Michel is heavily involved) and also suggested that would benefit from
getting involved in Youthlinc, a non-profit organization that provides international service
project opportunities for local youth. Michel does not serve on the board of Youthlinc but
does donate between $30-50,000 a year to the organization.

Michele Weeks encouraged to participate and applied for admittance to

the Youthlinc program and was accepted. applied online, as do all other applicants.
According to , any individual who meets the
correct age requirements and performs the required 80 hours of community service is
accepted to the program. There is no waiting list. has yet to complete his community
service but is planning on attending the humanitarian trip this summer to Thailand.

Youthlinc is a 501(c)3 nonprofit organization. They receive a number of donations each year
in order to function. Typically, there are three different types of donations that are made to
Youthlinc. The first is to fund international construction projects. The second helps to
support a scholarship for the “Young Humanitarian” award that is given in local Utah
schools. The third type of donation is for financial aid and/or scholarships to participants in
the international service projects (such as the one that is doing).

The Michel Foundation are substantial donors to Youthlinc. They have in the past sponsored
particular students attending the humanitarian service projects as well as funded international
construction projects. Youthlinc verified however, that was not sponsored by the
Michels, and in fact, has not received any financial aid for the trip. He has applied for
financial aid, but did not complete the application. As such, no financial assistance has been
Mayor Troy Walker
Draper City
April 15, 2019
Page 6

provided. In addition, the Michels are currently helping to fund international building
projects. However, none are being built in Thailand.

The final area of potential conflict involving Michele Weeks surrounds an event that she has
organized for a number of years called the “Teacher Appreciation Night.” This is an event
that takes place once a year and is held at the Loveland Living Aquarium. Ms. Weeks has not
set up a 501(c)3 organization for the event. The event is paid for by donations from the
public and private sector.

Ms. Weeks informed me that in 2016 and 2017, she had organized the event herself.
However, in 2018, , she did not feel that she
could handle organizing the event alone. She explained to me that the Jordan Valley
Teachers Association stepped up and assisted with the event to help to cover the cost of the
dinner (approximately $8300). She indicated that she did not know if the Michels were
contributors to the Jordan Valley Teachers Association.

When I spoke with the Michels regarding their sponsorship of the Teachers Appreciation
Night, they indicated that they did not make a donation to the event. Instead, they explained
that they donated $1000 in 2018 to the Jordan Valley Teachers Association and that this was
not associated with Michele Weeks.

I subsequently met with . He

provided a different version of events regarding the Teachers Appreciation Night
sponsorship. According to , he and teachers from the Jordan School District were
first invited to the event in 2017. They felt it was a great event for teachers and looked
forward to attending in the future. In 2018, approached Michele Weeks and
asked if he should nominate teachers from the Jordan School district again to attend the
event. explained that Michele Weeks told him , and
that she did not have the energy to organize the event that year. He thought it was a shame as
it was such a good event and offered to help. Ms. Weeks told him that she had all of the
donors lined up, she just did not have the energy to get it all organized. She asked if she
could give the donor information and have the donors give the money directly to the
Teachers Association and then have the Teachers Association pay for the dinner. He told
Michele that would not be a problem as they are a 501(c)3 organization and could easily
assist. Ms. Weeks then connected all of her donors with the Teachers Association and the
Teachers Association then paid for the dinner that year (costing $8300). The Teachers
Association did not donate any funds themselves nor did they solicit any additional donors.
They then paid for the dinner from Ms. Weeks’ donors.

One of these donors was the Michel Foundation. On May 7, 2018, the Michel Foundation
donated $1000 to the Jordan Education Foundation. While this is consistent with what the
Michel’s told me in their interview, it is quite disingenuous as to what really occurred. The
Mayor Troy Walker
Draper City
April 15, 2019
Page 7

check receipt provided by Jordan School District to the Michels clearly shows that the money
was for the “Teacher Appreciation-Aquarium.” Further, a letter was issued on June 19, 2018
from the Jordan Education Foundation for tax purposes to the Michel Foundation. That letter
clearly expresses appreciation for the donation of $1000 “to be directed towards the Teacher
Appreciation Night at the Loveland Living Planet Aquarium.” I have attached copies of the
check, receipt and letter to this report. There is no doubt that the Michels knew they were
donating to Ms. Weeks’ event. Further, there is no doubt that Ms. Weeks knew of the
donation as she provided all of the donors directly to the Teachers Association, they did not
get any themselves. As such, I believe there is sufficient information to support the fact that
the Michels donated substantial funds to an event founded by, closely associated with, and
for all intents and purposes, was organized by Michelle Weeks. In my opinion, this clearly
represents a conflict of interest.

C. General Lobbying Efforts:

In connection with the investigation, I spoke with individuals regarding general lobbying
efforts made by the Michels. Every council member other than Michele Weeks indicated that
they were heavily lobbied by the Michels. For example, Marsha Vawdry recounted how
Shaun Michel had wanted to speak with her regarding the Mountain Ridge project. She
explained that she had a doctors appointment and therefore could not meet. He then inquired
what doctor she was going to and asked if he could meet her there. Further, on one occasion,
Shaun Michel emailed Ms. Vawdry a picture where she was attending a Best of State dinner.
In the email, Michel stated “you make this look good.”

Shaun Michel has also sent a picture of himself and his son on a Harley motorcycle ride to
Alan Summerhays stating “wish you could be here.” Undoubtedly this was sent as Alan
Summerhays enjoys motorcycles.

Finally, there was an incident involving with

Draper City. In May, 2018, got her purse stolen. When Shaun Michel learned of this,
he gave her a new purse. (It should be noted that Michel verified this fact but indicated it was
one of the purses his wife owned but never used.) While Michel did not recall doing this,
explained that Michel told her to “make sure you check the pockets.” When she did,
she found there was $50.00. did not accept the purse or the money and returned it
immediately. also recalls Michel telling her about the Youthlinc organization. He
explained to her that “if she ever wanted one of her kids to go on a humanitarian project, they
could go without any charge.” did not take him up on the offer. It should also be noted
that has no voting power or influence over the Draper council members.
Mayor Troy Walker
Draper City
April 15, 2019
Page 8

IV. Legal Analysis

As you are aware, and is set forth in the Draper City Code of Ethics,

Ethics is more than the avoidance of criminal behavior. It is a commitment for public
servants to take individual responsibility in creating a government that has the trust and
respect of its citizens. There needs to be a proactive approach in strengthening the
emphasis on ethics and guiding city elected officials and employees in upholding them.
To preserve and maintain the integrity of responsible government and its decision making
process, Draper City believes it is necessary that the identity, activities and expenditures
of certain persons who engage in efforts to influence elected officials and employees of
the city on matters within their official cognizance, either by direct communication or by
solicitation of others to engage in such efforts, be publicly and regularly disclosed.

Draper Code Section 19-1-040 emphasizes that City officers are “bound to observe in their
official acts, the highest standards of performance and to discharge faithfully the duties of their
office, regardless of personal considerations. Recognizing that the public interests must be their
primary concern, their conduct in both their official and private affairs should be above
reproach.”

Further, Draper Code Section 19-1-080 provides that “City officers…should conduct their
official and private affairs so as not to give a reasonable basis for the impression that any such
officer or employee can be improperly influenced in the performance of public duties. Such
officers or employees should so conduct themselves as to maintain public confidence in their
performance of the public trust in the government they represent. All City officials and
employees should avoid even the appearance of conflict between their public duties and private
interests.

Draper City has also adopted Utah State Code 10-3-1304 Use of Office for Personal Benefit
Prohibited. In pertinent part, 10-3-1304(2) provides:

…It is an offense for an elected or appointed officer or municipal employee to…

(c) knowingly receive, accept, take, seek, or solicit, directly or indirectly, for the officer
or employee or for another, a gift of substantial value or a substantial economic benefit
tantamount to a gift that:
(i) would tend improperly to influence a reasonable person in the person’s
position to depart from the faithful and impartial discharge of the person’s public
duties; or
(ii) the person knows or that a reasonable person in that position should know
under the circumstances is primarily for the purpose of regarding the person for
official action taken.
Mayor Troy Walker
Draper City
April 15, 2019
Page 9

This provision does not include occasional nonpecuniary gifts having value of less than $50 as
well as campaign contributions.

It is my opinion that there have been violations of the Draper Code of Ethics and perhaps the
Utah Municipal Officers and Employees Ethics Act in this case. My legal opinion regarding
those violations follows herein.

A. Alan Summerhays: As was discussed in detail above, the Michels have been very
aggressive in promoting their development proposal with Draper City
Councilmembers. Shaun Michel has vigorously pursued avenues in which to
communicate and/or curry favor with councilmembers (and even with the
administrative staff). While I do not believe that any activities were illegal, many
were awkward, bordering on offensive and inappropriate. While the Michel
Foundation (Shaun Michel in particular) may have had altruistic motives and may
very well be naïve as developers, they have placed the city officials in a very difficult
position where conflicts of interest could easily (and rightfully) be perceived. While
many of the contacts were simply strange, the Neuroworx issue causes me great
concern. When Shaun Michel offered to make a “substantial donation” to Neuroworx
if the members of the board could help convince the Draper City Council to approve
their project, members of the Neuroworx board, Neuroworx itself as well as Draper
City Council were put at risk for perceived potential ethical violations. Thankfully,
the council members that were contacted by Neuroworx board members came
forward and disclosed the communications.

The biggest problem however came when Alan Summerhays’ son was
involved in a horrific accident in 2018. He truly needed the assistance of Neuroworx
and had independently decided to apply for the program. I do not find that there was
any special treatment given to or to the Summerhays family. However,
because Shaun Michel had previously made the “promise” above to the board, the
situation could rightfully be perceived as a “golden opportunity” for Neuroworx to
get the funding Michel could provide. While I do not fault Shaun Michel for
mentioning Neuroworx to Alan Summerhays in his time of need, it is clear that he did
see a potential opportunity to gain favor from Alan through Neuroworx. This is clear
when he contacted and asked him to reach out to Alan Summerhays as he
“was one of the council members on the Draper City Council.” While there has been
no special treatment given to , Alan Summerhays still has significant and
justified concerns. If Shaun Michel would not have made his “promise” to the board
of directors, this issue never would have grown to be such a problem and a conflict of
interest likely would not exist. However, because the “promise” was made and
because Alan has these real concerns, it is my opinion that there is a conflict of
interest. I would therefore recommend that Alan Summerhays consult with the city
Mayor Troy Walker
Draper City
April 15, 2019
Page 10

attorney regarding the appropriate action to take regarding whether or not to recuse
himself from voting on the project.

B. The Michel Foundation: As has been discussed above, I do not feel that the Michel’s
have done anything illegal. However, it is my opinion that they have put numerous
council members in very difficult positions. While they may be inexperienced in the
property development arena, and their motives may have been altruistic, the
“promise” of funding to Neuroworx was just asking for conflicts of interests to
emerge. Further, and even more concerning, are the dealings Shaun Michel has had
with Michele Weeks and her family.

Shaun Michel has taken Michele Weeks’ son on a fishing trip. While there arguably
was little monetary value in this gesture, it creates an appearance of impropriety. In
my opinion, is not appropriate for a developer who is seeking to get his project
approved, and who is actively courting members of Draper City Council, to take a
council member’s son fishing. Further, getting Ms. Weeks’ son involved in
Youthlinc may not be technically inappropriate. However, it also has the clear
potential for appearing unethical. More often than not, a reasonable person would ask
whether or not Ms. Weeks’s son was getting special treatment, sponsorship, etc.
Creating a situation where such questions would be asked is unwise and should be
avoided anytime the Michels (or any other developer) is attempting to get a
development approved by Draper City.

Finally, and what I believe is the most egregious conduct and potentially a violation
of the Utah Municipal Officers’ and Employees’ Ethics Act is the donation of funds
to the Teachers Appreciation Night. The Michels claim that their donation was not to
the event organized by Michele Weeks, but rather to the Jordan Valley Teachers
Association. While that is who the check was made out to, clearly, the money was
intended for Ms. Weeks’ event. The Michels knew it and so did Michele Weeks. If
the Michels take the position that they did not know where the money was going prior
to the donation, the error would have clearly been known once the receipt and then
again the letter given by Jordan Valley to the Michels for tax purposes. While there is
no doubt that the Teachers Appreciation Night is a good cause, it is Michele Weeks’
cause. She has not set up a 501(c)3 non-profit for the event. She is the founder, the
organizer and the director of the event. A donation of $1000 to the event by a
developer who is seeking to have its project approved by the
founder/organizer/director could easily “tend to improperly influence a reasonable
person” in Ms. Weeks’ position to depart from her “faithful and impartial discharge”
of her public duties. Whether it did or not, I cannot say. However, in my opinion, the
donation could be seen as a potential violation of UCA 10-3-1304. In the very least,
the donation should have been disclosed by Ms. Weeks and not have it hidden under
the guise of a donation to the Jordan Valley Teachers Association.
Mayor Troy Walker
Draper City
April 15, 2019
Page 11

C. Michele Weeks: The individual that causes me the most concern in this investigation
is Michele Weeks. She is an elected official and is subject to the ethical requirements
of both Draper City and the Utah Code. When Ms. Weeks was asked if her son could
go on a fishing trip with a developer who was trying to get his project approved, she
should have said no. Regardless of the monetary value of the trip or lack thereof, a
reasonable person would realize that this could create a perception of impropriety.
Instead however, she allowed her son to go. Further, she did not disclose this trip to
the City Council in order to prevent rumors and improper conclusions from being
drawn.

The same carelessness occurred when she had her son get involved with
Youthlinc through Shaun Michel’s suggestion. While she failed to disclose this fact to
the council, she took the opposite approach and posted about it on her facebook
page—further fueling the possibility of rumors, innuendo, and the appearance of
impropriety. To be clear, I do not believe that either of Ms. Weeks’ sons received
inappropriate gifts. However, it is the appearance of such, created by Ms. Weeks’
allowance of her sons participation as well as her failure to disclose the connection
where I find fault.

Finally, the most concerning issue is the donation to the Teachers Appreciation Night
Event. As expressed above, while this is no doubt a worthy event, it is not a non-
profit, and for all intents and purposes, is Michele Weeks’ event. A donation of $1000
is substantial, in reality and according to the Utah Code. In my opinion, while the
development was pending approval, this donation should have been refused. In the
very least, it should have been disclosed. Neither occurred. Instead, it was
inaccurately classified as a donation to the Jordan Valley Teachers Association who
did nothing but try and assist Ms. Weeks with the event by gathering the donations
that she had already procured together and paying for the dinner at the event. Ms.
Weeks is a seasoned politician. She is expected to know the Draper City Code as well
as the Utah Code of Ethics. She should have realized in this instance that such a
donation could be viewed as a violation. In the very least, she should have known that
such conduct creates the appearance of impropriety and the impression of
corruptibility. As such, it is my opinion that a complaint to the Draper City Ethics
Commission is warranted, or if no such commission has been established, such a
complaint could be filed with the Utah State Political Subdivisions Ethics Review
Commission.
Mayor Troy Walker
Draper City
April 15, 2019
Page 12

I appreciate the opportunity to conduct this investigation. Should you have any
concerns or questions, please feel free to contact me anytime.

Yours truly,

/s/ Kristin A. VanOrman

Kristin A. VanOrman