 In March 2018, EPA's Designated Agency Ethics Official and principal deputy general counsel, Kevin Minoli, wrote that Pruitt's lease, which as drafted provided Pruitt with access to a single unlocked bedroom at a rate of $50 per night for the nights used up to a maximum of 37 nights, was not a violation of federal gift rules because of the limited use provided by the lease and the availability of other temporary housing in the area for a similar price.However, Minoli emphasized he had only evaluated the narrow terms of the lease itself, not any other activities or benefits provided outside of the lease that the document did not address.Minoli issued a second memorandum on April 4, 2018, providing additional explanation of his determination and the factual information he considered.