 As to allegations that Pruitt's daughter stayed in a separate bedroom, Minoli's memorandum did not opine on the implication of those or other allegations explaining that to evaluate them "would have required factual information that was not before" the ethics office.Minoli's memorandum also explained that it was limited only to the question of whether the rental agreement constituted a gift and "did not address other portions of the Federal ethics regulations such as the impartiality rule.Other apartments in the building complex, located in a prime location less than a block away from the U.S. Capitol, rented for as much as $5,000 per month.