Commissioner Adams and/or his family have landowner and/or ownership interest in the Latigo Project. For example: © Commissioner Adams was previously affiliated with the renewable energy entity “Utah Green Power.” During this time he was directly affiliated with Latigo’s manager, Christine Watson Mikell who, interestingly enough, worked for the State of Utah Energy Office and erected the Monticello wind towers for the state of Utah, See 2.19.04 Wind Power Meeting {attached hereto as Ex. 12). GRAMA responses for wind data obtained during Ms. Mikell’s, tenure with the state reveal that this data is “lost” and no longer available. This is in contrast to the coincidence that Latigo’s wind project sits on one of those state meteorological tower sites. Commissioner Adams must disclose these and other relationships he has through Utah Green Power, Latigo, S*Power, and any other possible conflicting relationship. ‘* Commissioner Bruce Adams is related to the owners of Redd Enterprises and Jones Enterprises—the primary landowners in the Latigo project. ‘© Mr. Greg Adams, the County official authorizing Latigo’s invalid CUP. is Commissioner Bruce Adams's first cousin, ‘+ Mr. Greg Adams's brother Robert “Rob” Adams currently works for S* Power—the entity that recently purchased Latigo. * Commissioner Bruce Adams's home is located on Latigo Loop. See Adams's Home (attached hereto as Ex. 13). Summit Wind is interested in discovering why the Latigo Wind Park Project's name is the same name as the street were Commissioner Adams resides. 7 infact the whole point ofthe February 19,2008 Wind Power Meeting was forthe Cty of Monticello to obtain a rantto erect a meteorological tower to capture wind data. Monticello paid Wasatch Wind, Latigo's predecessor, to erect the towers and to analyze the wind data. This happened in 2006 when Ms. Mikell was the President of Wasatch Wind. This meteorological tower i evident in Latig's own unapproved site plan map. See Latigo Second Unapproved Site Pan Map {attached hereto as Ex. 5). After the data was collected, however, Ms. Mikell refused to give the data to the Monticello until years after it was collected and was, by then, useless.Recent investigations, revealing potential fraud surrounding the Latigo project. also play into these conflicts, The now Chapter 7 bankrupt Renewable Energy Development Corporation (“REDCO") (Case No. 11-38145) held a $250,000 option to purchase the Latigo project. See Champlin Docs (attached hereto as Ex. 14). REDCO insiders, including Michael Adams, Commissioner Adams's brother, was an owner and Vice-President of REDCO, Robert Adams, Commissioner Adams's first cousin, was the REDCO project development manager. Like many other REDCO insiders, Robert Adams now works for S*Power. So it is no surprise why the $250,000 option to purchase the Latigo project was never disclosed in the REDCO bankruptey—hecause it is a very valuable project. In fact, according to public statements by the REDCO insiders and S*Power management, the Latigo project is worth $136 million. See 8.4.15 S*Power Website (attached hereto as Ex. 15)*: see also San Juan County Record Article (attached hereto as Ex. 16) None of these relationships have been disclosed. And, given that Greg Adams, Bruce Adams's first cousin is tasked with processing the County's permits, it is no wonder that the Latigo construction continues despite invalid permits. Commissioner Bruce Adams's connections to this project are simply too many to not find a conflict. B. San Juan County Officials Have Failed in Their Duty. As explained above, County officials have repeatedly failed to substantially perform their duties relative to Latigo’s CUP and BP. Utah law repeatedly requires public servants to perform duties inherent to their office: Official misconduct -- Unauthorized acts or failure of duty, A public servant is guilty of a class B misdemeanor if, with an intent to benefit himself or another or to harm another, he knowingly commits an unauthorized act which purports to be an act of his office, or knowingly refrains from performing a duty imposed on him by Jaw or clearly inherent in the nature of his office 015/news-20Utah Code Ann, § 76-8-201 17-16-10.5. Failure to perform duties constitutes malfeasance in office ~ Felony charges arising from official duties -- Paid administrative leave -- Reassignment of duties. (1) The failure of an elected county ot prosecution district officer substantially to perform the officer's official duties constitutes malfeasance in office under Section 77-6-1. Utah Code Ann. § 17-16-10.5 County officials should be investigated for both failures in their duties and failures to disclose conflicts. These officials should also be required to recuse themselves from any further Latigo matters and any future matters regarding any type of wind project in the County, County attorneys should also investigate possible violations of the following: © Utah Code Ann. § 76. Utah Code Ann. § 76. 201 (Official misconduct) -103 (Bribery or offering a bribe) Utah Code Ann. § 76-8-105 (Receiving or soliciting bribe or bribery by public servant) Utah Code Ann, § 76-8-504 (Written false statement) Utah Code Ann. § 76-10-1603 (Unlawful acts) Utah Code Ann. § 17-16-10.5 (Failure to perform duties constitutes malfeasance in office) Utah Code Ann. § 17-16a-6 (Interest in business entity regulated by county — Disclosure) * Utah Code Ann. § 17-16a-8 (Investment creating conflict of interest with duties ~ Disclosure) * Utah Code Ann. § 17-16a-10 (Violation a misdemeanor ~ Removal from office) © Utah Code Ann. § 71-16a-12 (Recession) Sincerely, Kimberly Ceruti Member of Summit Wind Power. LLC ul