November 17, 2021

Colorado Ethics Commission

1300 Broadway, Suite 240
Denver, Colorado 80203

Commissioners:

This Complaint is filed on behalf of Defend Colorado and provides specific evidence
demonstrating that the Office of Governor Jared Polis’s former Chief of Staff Rick Palacio
(“Palacio”) violated Article XXIX of the Colorado Constitution (“Amendment 41”) and specific
state statutes related to ethics and financial improprieties.

Specifically, while Palacio was serving as Governor Polis’ Chief of Staff, his own limited liability
corporation was awarded a lucrative consulting contract. Palacio received both a “full time”
government salary of over $15,000 and a $15,000 payment to his own company for consulting in
the same month for the same work. This self-dealing and double dipping is clearly a conflict of
interest and ethical violation carried out by the Office of the Governor and Palacio.

The lucrative state contract to Palacio, a Polis political ally who in 2018 was paid over $329,000
to help elect Jared Polis as Governor, violates the very public confidence and trust that Amendment
41 was designed to maintain. In 2018, Palacio Strategies Group, LLC (“PSG LLC”) and The
Majority Institute, LLC, both owned by Rick Palacio, were paid $310,400 out of $1,047,400 raised
by the independent expenditure committee supporting Polis’s run for Governor, “Bold Colorado.”
“Polis for Colorado,” the Governor’s candidate committee, also paid The Majority Institute, LLC
$19,000 for “miscellaneous” services in 2018. (Colorado TRACER information attached as
Exhibit A.)

This Complaint is timely, non-frivolous, qualifies under the jurisdiction of the Colorado
Independent Ethics Commission (the “Commission”), and documents conclusive violations under
Amendment 41 as well as violations of C.R.S. §§ 24-18-108, 24-18-201, and 24-18-105.

I. Commission Jurisdiction

The Commission has jurisdiction over both the person and the subject matter of the Complaint.

Pursuant to Amendment 41, the Commission has jurisdiction over state employees of the executive
branch. Palacio was an employee of the State of Colorado as defined by state law during the time
period in which the ethical violations occurred. Colo. Const. art. XXIX, §2(1) and C.R.S. § 24-18-
102(3).
 Rick Palacio IEC Complaint
Page 2

The Commission has jurisdiction over violations of the state’s code of ethics. Colo. Const. art.
XXIX, § 5; and C.R.S. §§ 24-18-101 to 113. Rick Palacio violated the code of ethics under multiple
provisions when he authorized a consulting contract providing personal financial benefits to
himself through his LLC, while he was still employed by Governor Polis as Chief of Staff.

II. Summary of Violations

From August 2020 to December 2020, the Office of the Governor employed Palacio as Interim
Chief of Staff. In this capacity, Palacio served as a full-time state employee with salary and
benefits. In his capacity as Chief of Staff, Palacio managed and directed all staff and divisions of
the Office of the Governor. (Office of the Governor Organizational Structure attached as Exhibit
B.)

While Palacio was serving as Chief of Staff for the Office of the Governor, the Office of the
Governor awarded a highly paid consulting contract to a limited liability company owned and
operated by Palacio, PSG LLC. Palacio, as Chief of Staff, authorized the lucrative contract to
his own company. PSG LLC received monthly payments in the amount of $15,000 from the
Office of the Governor.

Rick Palacio’s conflicting roles overlapped. In December 2020, Palacio received over $15,000
from the State of Colorado for his “full time” state job as Chief of Staff. In that same month, PSG
LLC received $15,000 for his “strategic consulting” work for the Office of the Governor. This
means that Palacio received double payments and Palacio was the state official who authorized
the double payments. This act of self-dealing and double dipping is, of course, illegal under
Amendment 41, as well as a direct violation of multiple state statues, as detailed below.

III. Summary of Facts

On March 9, 2017, Palacio formed PSG LLC. Palacio serves as owner and Registered Agent of
the entity. (Evidence attached as Exhibit C.)

From August 1, 2020, through December 4, 2020, Palacio served as Chief of Staff in the Office of
the Governor. Palacio served as a full-time state employee with full benefits. Over these four
months, the State of Colorado paid Palacio $58,846.24 in regular wages, and 40 hours of annual
leave paid out in the amount of $3,269.24. Palacio’s annual leave for four months was accumulated
at the rate of 10 hours per month. According to State Personnel rules, that rate of accumulation (10
hours per month) is limited to employees of the state after employment of 6 to 10 years (Palacio
does not have 6 to 10 years of employment history with the State of Colorado). (Evidence of State
Employment Payments attached as Exhibit D.)

Starting on December 1, 2020, which was prior to the expiration of Palacio’s state employment as
Governor Polis’ Chief of Staff, the Office of the Governor executed a Purchase Order for PSG
LLC for consulting services through May 31, 2021, paying Palacio’s private company $85,000.
Remarkably, the state contract engaging PSG LLC was created and managed by the Chief of Staff.
(Evidence of LLC Contract and Payments attached as Exhibit E.)

In December 2020, Palacio received two separate payments, one for $16,346.20 from the State of
Colorado: as a “full time state employee,” and second, PSG LLC was paid $15,000 from the State
of Colorado for his consultant work providing “Strategic Consulting December 2020.”
 Rick Palacio IEC Complaint
Page 3

IV. Statutory and Constitutional Violations

A) C.R.S. § 24-18-108 Violation

C.R.S. § 24-18-108 requires that each public officer and state employee shall comport with basic
fiduciary duties. Specifically, it provides that:

[a] public officer or a state employee shall not:

(a) Engage in a substantial financial transaction for his private business purposes with a
person whom he inspects, regulates, or supervises in the course of his official duties;

(b) Assist any person for a fee or other compensation in obtaining any contract, claim,
license, or other economic benefit from his agency;

(c) Assist any person for a contingent fee in obtaining any contract, claim, license, or
other economic benefit from any state agency; or

(d) Perform an official act directly and substantially affecting to its economic benefit a
business or other undertaking in which he either has a substantial financial interest or is
engaged as counsel, consultant, representative, or agent.

C.R.S. § 24-18-108(2) (emphasis added).

The Office of the Governor and Palacio, in his role as Chief of Staff to the Office of Governor,
unequivocally violated C.R.S. § 24-18-108. As Chief of Staff, Palacio managed and provided
oversight of the Office of the Governor. Approving a high value consulting contract that
benefitted his own financial interests is a direct violation of C.R.S. § 24-18-108(2)(a) and C.R.S.
§ 24-18-108(2)(d).

Palacio was a state employee who, during his state employment, obtained a contract with the
very state agency that he directly managed as a state official. Directly approving or influencing
the approval of a contract from the State of Colorado to his own limited liability corporation is a
clear and direct violation of the fiduciary duties set forth in state statue. Palacio’s contract was
not only approved during his employment, but the contract term began when Palacio was still
serving as Chief of Staff to the Office of the Governor.

B) C.R.S. § 24-18-201 Violation

C.R.S. § 24-18-201(1) prohibits a state employee from being involved with a self-dealing contract.
The statute also prohibits the state entity from engaging in any contract involving an employee of
that same entity. More broadly, this same statute also prohibits a former employee from entering
into a contract with that former employer for a period of six months. While only one of the three
facts are required to prove a violation of C.R.S. § 24-18-201(1), the Rick Palacio, with the
assistance of the Office of the Governor, violated all three provisions. The relevant statute is
 Rick Palacio IEC Complaint
Page 4

unambiguous and provides:

Members of the general assembly, public officers, local government officials, or

employees shall not be interested in any contract made by them in their official capacity
or by any body, agency, or board of which they are members or employees. A former
employee may not, within six months following the termination of his employment,
contract or be employed by an employer who contracts with a state agency or any local
government involving matters with which he was directly involved during his
employment.

C.R.S. § 24-18-201 (emphasis added). Palacio’s consulting contract with the Office of the
Governor while he was serving as Chief of Staff to the Office of the Governor violates each
separate provision of this statute. First, Palacio, as Chief of Staff, managed and provided oversight
over all Office of the Governor activities and expenditures and, therefore, was interested in the
contract made by him. Second, Palacio’s consulting contract was with the state agency in which
he was an employee. Third, Palacio’s consulting contract was with the state agency in which he
was employed within six months of his termination.

Any one of these three scenarios is a violation of state statute. In this egregious case, the Office of
the Governor and Palacio violated all three provisions of the statute.

C) C.R.S. § 24-18-105(3) Violation

C.R.S. § 24-18-105(3) provides that a state employee shall not obtain employment in which he
will take advantage, unavailable to others, of matter in which he was directly involved. The
statute provides:

A public officer, a local government official, or an employees should not, within six months
following the termination of his office or employment, obtain employment in which he will take
direct advantage, unavailable to others, of matters with which he has been directly involved
during the term of his employment. These matters include rules, other than rules of general
application, which he actively helped to formulate and applications, claims, or contested cases
in consideration of which he was an active participant.

C.R.S. § 24-18-105(3). Palacio served as Chief of Staff, managing and overseeing all matters
before the Office of the Governor, and within six months obtained a consulting contract related
to functions with which he was involved during state employment in direct violation of C.R.S. §
24-18-105(3). In this case, not only did Palacio and the Office of the Governor fail to comply
with the six month “cooling off period,” the private consulting contract was entered into and
began while he was still employed by the very agency in which the contract was formed. This
situation represents an outrageous and wanton conflict of interest that violates the public trust. It
is a direct and flagrant violation of C.R.S. § 24-18-105(3).
 Rick Palacio IEC Complaint
Page 5

D) Amendment 41 Violations

Amendment 41 is designed to maintain public confidence and trust in Colorado government

activities. The constitutional provision requires government employees to not only “avoid conduct
that is in violation of public trust” but to avoid even an “impression among members of the public
that such trust is being violated.” Colo. Const. art. XXIX, §1(1)(c). The relevant provision of
Amendment 41 provides:

The people of the state of Colorado hereby find and declare that: (a) The conduct of public
officers, members of the general assembly, local government officials, and government
employees must hold the respect and confidence of the people; (b) They shall carry out
their duties for the benefit of the people of the state; (c) They shall, therefore, avoid conduct
that is in violation of their public trust or that creates a justifiable impression among
members of the public that such trust is being violated; (d) Any effort to realize personal
financial gain through public office other than compensation provided by law is a violation
of that trust; and (e) To ensure propriety and to preserve public confidence, they must have
the benefit of specific standards to guide their conduct, and of a penalty mechanism to
enforce those standards.

Colo. Const. art. XXIX, §1(c). (emphasis added). Having the Office of the Governor authorize a
lucrative contract with an LLC owned and operated by the Governor’s Office Chief of Staff is an
egregious violation of Amendment 41. Such self-dealing and double dipping is unequivocally
conduct that violates the public trust and, without question, creates a justifiable impression among
members of the public that such trust is being violated.

In addition, accepting consulting payments from the Office of the Governor while serving as Chief
of Staff to the Office of the Governor, and immediately after serving as Chief of Staff to the Office
of the Governor, clearly imparts a “personal financial gain” to Palacio and is a violation of
Amendment 41. Such violations must be subject to penalty in order to enforce these standards
under Amendment 41.

V. Penalty

Amendment 41 provides that any public officer or government employee “who breaches the public
trust for private gain and any person or entity inducing such breach shall be liable to the state or
local jurisdiction for double the amount of the financial equivalent of any benefits obtained by
such actions.” Colo. Const. art. XXIX, § 6. In this case, Palacio and the Office of the Governor
are responsible for breaching the public trust and must be held liable in accordance with
Amendment 41.

In addition, the specific penalties for violations of C.R.S. §§ 24-18-108, 24-18-201, and 24-18-
105 should be separately administered.
 Rick Palacio IEC Complaint
Page 6

VI. Conclusion

This Complaint demonstrates egregious ethical violations committed by Rick Palacio with the
assistance of the Office of the Governor. These activities violate constitutional ethical standards
under Amendment 41, as well as specific state ethics statutes (C.R.S. §§ 24-18-108, 24-18-201,
and 24-18-105). Enforcement of these ethical violations is immediately necessary to preserve
public trust in state government.

The Governor of Colorado is “[t]he supreme executive power of the state…who shall take care
that the laws be faithfully executed.” Colo. Const. art. IV, § 2. The Office of the Governor
committing flagrant violations of state ethics laws not only represents specific illegal acts, but
creates a dangerous precedent for every other covered official in the State of Colorado.

These acts, carried out to financially benefit the sitting Chief of Staff, are equivalent to an agency
head granting himself/herself or their spouse a lucrative state contract with the very agency he/she
leads. These are not technical errors, but instead are intentional and egregious ethical violations at
the highest level of state government that directly endanger public trust in government.

Thank you for your review of this important matter.

Sincerely,

George Brauchler
 Exhibit A
Colorado Tracer Information
 2018-19 Payments from “Bold Colorado” to Palacio Strategies
Group, LLC from Colorado TRACER

2018-19 Payments from “Bold Colorado” and “Polis for Colorado”

to Palacio Strategies Group, LLC from Colorado Tracer
 Exhibit B
Office of the Governor Organizational Structure
 Exhibit C
Palacio Strategies Group, LLC Articles of Incorporation
 Colorado Secretary of State
Date and Time: 03/09/2017 12:08 PM
Document must be filed electronically. ID Number: 20171193407
Paper documents are not accepted.
Fees & forms are subject to change. Document number: 20171193407
For more information or to print copies Amount Paid: $50.00
of filed documents, visit www.sos.state.co.us.
ABOVE SPACE FOR OFFICE USE ONLY

Articles of Organization
filed pursuant to § 7-80-203 and § 7-80-204 of the Colorado Revised Statutes (C.R.S.)

1. The domestic entity name of the limited liability company is

Palacio Strategies Group LLC
______________________________________________________.
(The name of a limited liability company must contain the term or abbreviation

-90-601, C.R.S.)
(Caution: The use of certain terms or abbreviations are restricted by law. Read instructions for more information.)

Street address 1350 Lawrence St

______________________________________________________
(Street number and name)
______________________________________________________
Suite 4B
Denver
__________________________ CO ____________________
____ 80204
(City) (State) (ZIP/Postal Code)
_______________________ ______________
United States
(Province if applicable) (Country)

Mailing address ______________________________________________________

(leave blank if same as street address) (Street number and name or Post Office Box information)
______________________________________________________
__________________________ ____ ____________________
(City) (State) (ZIP/Postal Code)
_______________________ ______________.
(Province if applicable) (Country)

agent are

Name
(if an individual) Palacio
____________________ Rick
______________ ______________ _____
(Last) (First) (Middle) (Suffix)
or

(if an entity) ______________________________________________________

(Caution: Do not provide both an individual and an entity name.)

Street address 1350 Lawrence St

______________________________________________________
(Street number and name)
______________________________________________________
Suite 4B
Denver
__________________________ CO 80204
____________________
(City) (State) (ZIP Code)

Mailing address ______________________________________________________

(leave blank if same as street address) (Street number and name or Post Office Box information)
______________________________________________________

ARTORG_LLC Page 1 of 3 Rev. 12/01/2012

 __________________________ CO ____________________.
(City) (State) (ZIP Code)

(The following statement is adopted by marking the box.)

✔ The person appointed as registered agent has consented to being so appointed.

4. The true name and mailing address of the person forming the limited liability company are

Name
(if an individual) ____________________ ______________ ______________ _____
(Last) (First) (Middle) (Suffix)
or

(if an entity) Tierney Lawrence LLC

______________________________________________________
(Caution: Do not provide both an individual and an entity name.)

Mailing address 225 E. 16th Avenue

______________________________________________________
(Street number and name or Post Office Box information)
Suite 350
______________________________________________________
Denver
__________________________ CO ____________________
____ 80203
(City) (State) (ZIP/Postal Code)
_______________________ ______________.
United States
(Province if applicable) (Country)

(If the following statement applies, adopt the statement by marking the box and include an attachment.)
The limited liability company has one or more additional persons forming the limited liability
company and the name and mailing address of each such person are stated in an attachment.

5. The management of the limited liability company is vested in

(Mark the applicable box.)
✔ one or more managers.
or
the members.

6. (The following statement is adopted by marking the box.)

✔ There is at least one member of the limited liability company.

7. (If the following statement applies, adopt the statement by marking the box and include an attachment.)
This document contains additional information as provided by law.

8. (Caution: Leave blank if the document does not have a delayed effective date. Stating a delayed effective date has
significant legal consequences. Read instructions before entering a date.)

(If the following statement applies, adopt the statement by entering a date and, if applicable, time using the required format.)
The delayed effective date and, if applicable, time of this document is/are __________________________.
(mm/dd/yyyy hour:minute am/pm)

Notice:
Causing this document to be delivered to the Secretary of State for filing shall constitute the affirmation or
acknowledgment of each individual causing such delivery, under penalties of perjury, that the document is the
individual's act and deed, or that the individual in good faith believes the document is the act and deed of the
person on whose behalf the individual is causing the document to be delivered for filing, taken in conformity
with the requirements of part 3 of article 90 of title 7, C.R.S., the constituent documents, and the organic
statutes, and that the individual in good faith believes the facts stated in the document are true and the
document complies with the requirements of that Part, the constituent documents, and the organic statutes.

ARTORG_LLC Page 2 of 3 Rev. 12/01/2012

This perjury notice applies to each individual who causes this document to be delivered to the Secretary of
State, whether or not such individual is named in the document as one who has caused it to be delivered.

9. The true name and mailing address of the individual causing the document to be delivered for filing are

Lawrence
____________________ Cara
______________ ______________ _____
(Last) (First) (Middle) (Suffix)
______________________________________________________
225 E. 16th Avenue
(Street number and name or Post Office Box information)
______________________________________________________
Suite 350
Denver
__________________________ CO
____ 80203
____________________
(City) (State) (ZIP/Postal Code)
_______________________ ______________.
United States
(Province if applicable) (Country)

(If the following statement applies, adopt the statement by marking the box and include an attachment.)
This document contains the true name and mailing address of one or more additional individuals
causing the document to be delivered for filing.

Disclaimer:
This form/cover sheet, and any related instructions, are not intended to provide legal, business or tax advice,
and are furnished without representation or warranty. While this form/cover sheet is believed to satisfy
minimum legal requirements as of its revision date, compliance with applicable law, as the same may be
amended from time to time, remains the responsibility of the user of this form/cover sheet. Questions should

ARTORG_LLC Page 3 of 3 Rev. 12/01/2012

 Exhibit D
Evidence of State Employment Payments
Organization ID EAA Employee ID
Employee Name PALACIO,RICK
Schedule 082
Check/Advice A623440 Check Status
Check Date 08/28/2020 End Date 08/14/2020

Earnings Type Hours Gross Amount Deduction Amount Deduction Amount

REGULAR 80.00+ 6,538.47 PERA RETR 653.85
MEDICARE 94.81
FEDERAL T 760.92
STATE TAX 258.00
LOCAL TAX 5.75
ADL FED T 1000.00

Total Gross 6,538.47+ Deductions 2,773.33+ Net Pay 3,765.14+

Transaction 003 - Employee Check Display Employee

Check/Advice A623440 Organization EAA

Enter Menu Older Check Newer Check Employee Table Inquiry ?

PH03 Page 1 of 1

Organization ID EAA Employee ID

Employee Name PALACIO,RICK
Schedule 091
Check/Advice A627321 Check Status
Check Date 09/11/2020 End Date 08/28/2020

Earnings Type Hours Gross Amount Deduction Amount Deduction Amount

REGULAR 80.00+ 6,538.47 PERA RETR 653.85
MEDICARE 94.91
FEDERAL T 760.92
STATE TAX 258.00
LOCAL TAX 5.75
ADL FED T 1000.00

Total Gross 6,538.47+ Deductions 2,773.43+ Net Pay 3,765.04+

Transaction 003 - Employee Check Display Employee

Check/Advice A627321 Organization EAA

Enter Menu Older Check Newer Check Employee Table Inquiry ?

https://cpps.state.co.us:7443/hrms.cgi?RXKY=88674119 3/4/2021
PH03 Page 1 of 1

Organization ID EAA Employee ID

Employee Name PALACIO,RICK
Schedule 092
Check/Advice A631123 Check Status
Check Date 09/25/2020 End Date 09/11/2020

Earnings Type Hours Gross Amount Deduction Amount Deduction Amount

REGULAR 80.00+ 6,538.47 PERA RETR 653.85
MEDICARE 94.92
FEDERAL T 760.92
STATE TAX 258.00
ADL FED T 1000.00

Total Gross 6,538.47+ Deductions 2,767.69+ Net Pay 3,770.78+

Transaction 003 - Employee Check Display Employee

Check/Advice A631123 Organization EAA

Enter Menu Older Check Newer Check Employee Table Inquiry ?

https://cpps.state.co.us:7443/hrms.cgi?RXKY=29508535 3/4/2021
PH03 Page 1 of 1

Organization ID EAA Employee ID

Employee Name PALACIO,RICK
Schedule 101
Check/Advice A665021 Check Status
Check Date 10/09/2020 End Date 09/25/2020

Earnings Type Hours Gross Amount Deduction Amount Deduction Amount

REGULAR 80.00+ 6,538.47 PERA RETR 653.85
MEDICARE 94.92
FEDERAL T 760.92
STATE TAX 258.00
LOCAL TAX 5.75
ADL FED T 1000.00

Total Gross 6,538.47+ Deductions 2,773.44+ Net Pay 3,765.03+

Transaction 003 - Employee Check Display Employee

Check/Advice A665021 Organization EAA

Enter Menu Older Check Newer Check Employee Table Inquiry ?

https://cpps.state.co.us:7443/hrms.cgi?RXKY=6538993 3/4/2021
PH03 Page 1 of 1

Organization ID EAA Employee ID

Employee Name PALACIO,RICK
Schedule 102
Check/Advice A668737 Check Status
Check Date 10/23/2020 End Date 10/09/2020

Earnings Type Hours Gross Amount Deduction Amount Deduction Amount

REGULAR 80.00+ 6,538.47 PERA RETR 653.85
MEDICARE 94.91
FEDERAL T 760.92
STATE TAX 258.00
ADL FED T 1000.00

Total Gross 6,538.47+ Deductions 2,767.68+ Net Pay 3,770.79+

Transaction 003 - Employee Check Display Employee

Check/Advice A668737 Organization EAA

Enter Menu Older Check Newer Check Employee Table Inquiry ?

https://cpps.state.co.us:7443/hrms.cgi?RXKY=80830638 3/4/2021
PH03 Page 1 of 1

Organization ID EAA Employee ID

Employee Name PALACIO,RICK
Schedule 111
Check/Advice A702593 Check Status
Check Date 11/06/2020 End Date 10/23/2020

Earnings Type Hours Gross Amount Deduction Amount Deduction Amount

REGULAR 80.00+ 6,538.47 PERA RETR 653.85
MEDICARE 94.92
FEDERAL T 760.92
STATE TAX 258.00
LOCAL TAX 5.75
ADL FED T 1000.00

Total Gross 6,538.47+ Deductions 2,773.44+ Net Pay 3,765.03+

Transaction 003 - Employee Check Display Employee

Check/Advice A702593 Organization EAA

Enter Menu Older Check Newer Check Employee Table Inquiry ?

https://cpps.state.co.us:7443/hrms.cgi?RXKY=45240241 3/4/2021
PH03 Page 1 of 1

Organization ID EAA Employee ID

Employee Name PALACIO,RICK
Schedule 112
Check/Advice A706222 Check Status
Check Date 11/20/2020 End Date 11/06/2020

Earnings Type Hours Gross Amount Deduction Amount Deduction Amount

REGULAR 80.00+ 6,538.47 PERA RETR 653.85
MEDICARE 94.92
FEDERAL T 760.92
STATE TAX 258.00
ADL FED T 1000.00

Total Gross 6,538.47+ Deductions 2,767.69+ Net Pay 3,770.78+

Transaction 003 - Employee Check Display Employee

Check/Advice A706222 Organization EAA

Enter Menu Older Check Newer Check Employee Table Inquiry ?

https://cpps.state.co.us:7443/hrms.cgi?RXKY=14747317 3/4/2021
PH03 Page 1 of 1

Organization ID EAA Employee ID

Employee Name PALACIO,RICK
Schedule 122
Check/Advice C035745 Check Status HANDDRAWN 12/03/20
Check Date 12/03/2020 End Date 12/04/2020

Earnings Type Hours Gross Amount Deduction Amount Deduction Amount

REGULAR 80.00+ 6,538.48 PERA RETR 1634.62
REGULAR 80.00+ 6,538.48 MEDICARE 237.02
FURLOUGH 8.00- 653.85- FEDERAL T 2942.13
REGULAR 8.00+ 653.85 STATE TAX 667.00
ANL LEAVE 40.00+ 3,269.24 LOCAL TAX 5.75
ADL FED T 1000.00

Total Gross 16,346.20+ Deductions 6,486.52+ Net Pay 9,859.68+

Transaction 003 - Employee Check Display Employee

Check/Advice C035745 Organization EAA

Enter Menu Older Check Newer Check Employee Table Inquiry ?

https://cpps.state.co.us:7443/hrms.cgi?RXKY=56306140 3/4/2021
 Exhibit E
Evidence of PSG LLC Contract and Payments
 Exhibit A - Palacio Strategies Group Strategic Consultant - Statement of Work

I. Project Description

Palacio Strategies Group (hereinafter called “Vendor” or “Contractor”) will provide contractor
services to the office of the Governor and serve as Strategic Consultant to the Governor. This
contractor will utilize their federal and state government experience and in-depth relationships
with federal, state, and local elected officials and stakeholders to provide strategic advice to the
Governor, Chief of Staff, and other executive staff focusing on COVID response, economic
recovery, and maximizing federal funds related to these issues.

II. Work Tasks, Deliverables and Timeline

Essential duties and responsibilities of the office include:

● Provide strategic expertise and input for COVID response,
● Provide strategic expertise and input for economic recovery,
● Advise the Governor, Chief of Staff or other designees as appropriate for coordination of
State and Federal efforts of economic recovery,
● Advise the Governor, Chief of Staff or other designees on strategically identifying
spending priorities of anticipated federal funds to align with economic and COVID
response,
● Provide strategic expertise and input to Governor’s communications office as it relates to
COVID response and recovery, and
● Coordinate with other contractors and federal liaison to federal partners.

The Contractor shall use their own equipment, including but not limited to their own office
space, telephone, and computer.

This contract position is intended to last through the end of May, 2021 or at least six months,
with an assessment of ongoing need.

IV. Reporting
This contract position reports to the Chief of Staff, will advise the Governor and assist
members of the Governor’s staff as needed and will participate in meetings as appropriate
to carry out the functions of their contract.
Contractor will work the appropriate number of hours to complete the projects assigned
to them.
Project Manager Lisa Kaufmann, Chief of Staff, will monitor project work performance
to ensure conformance to timeline & scope of work.

V. Budget

The budget for this project is a total of $85,000.

Page 1 of 2
VI. Payment

Payment will be made at the close of the month upon receipt and acceptance of an invoice from
the vendor based on the following schedule:

December, 2020: $15,000

January, 2021 – May, 2021: $14,000 per month

VII. Purchase Order Term

The Vendor shall begin work upon the later of the P.O. Service From Date as shown on the cover
page of this P.O. or upon Vendor’s acceptance of this Purchase Order. This Purchase Order shall
terminate on May 31, 2021, unless sooner terminated or further extended as specified elsewhere
herein.

Authorized Signature:

_________________________

Lisa Kaufmann, Chief of Staff

Page 2 of 2
Palacio Strategies Group LLC
155 Albion Street
Denver, CO 80220 US
(719) 671-4784

INVOICE
BILL TO INVOICE # 5132
Shari Ashley DATE 12/28/2020
200 E. COLFAX AVE. #136 DUE DATE 12/28/2020
Denver, CO 80203 TERMS Due on receipt

ACTIVITY AMOUNT

Consulting 15,000.00
Strategic Consulting December 2020

BALANCE DUE
$15,000.00
Palacio Strategies Group LLC
155 Albion Street
Denver, CO 80220 US
(719) 671-4784

INVOICE
BILL TO INVOICE # 5135
Shari Ashley DATE 01/31/2021
Colorado State Capitol DUE DATE 01/31/2021
200 E. COLFAX AVE. #136 TERMS Due on receipt
Denver, CO 80203

ACTIVITY AMOUNT

Consulting 14,000.00
Strategic Consulting

BALANCE DUE
$14,000.00