D.C. Human Rights Office director James Baldwin acknowledged yesterday that he had violated city conflict of interest statutes by using city government stationery to recruit students for a private university.

"Yes, I did send the letters, and I did violate the code but I did not intend to do so," Baldwin told a hearing before the city's Board of Elections and Ethics.

Baldwin told the court that he prepared 80 letters during regular office hours last year seeking to recruit students for Nova University at Ft. Lauderdale, Fla. At the time, he said he believed the recruitment to be "job related" because the university program has been "endorsed and supported by the District of Columbia and federal government."

Part of the tuition for participants in the program were to be paid by the District," Baldwin said.

The ethics board held yesterday's hearing to determine whether Baldwin is in violation of the city's conflict of interest code, which prohibits public officials from using their official positions to reap financial gains in addition to their salaries. Baldwin's salary at the time he wrote the letters last year, was about $36,000 a year.

Baldwin, director of the city office that investigates complaints of discriminations, is the first ranking member of Mayor Walter E. Washington's administration to be formally charged under the city's three-year-old conflict-of-interest code.

The conflict-of-interest charges pending against him follow news reports alleging that Baldwin plagiarized substantial portions of one course paper that be submitted to Nova University for a doctorate degree. A Nova lawyer has recommended that Baldwin's degree be revoked but no final decision has yet been made by the university.

Jeamus Parks, a city ethics board member who presided over yesterday's hearing, said he would rule "in several days" whether Baldwin was guilty of conflict of interest when he used city stationery to recruit students.

Winfred R. Mundle, general counsel for the ethics board, recommended that Baldwin not be fined. Mundle said later he believed that recommendation was in line with the offense.

"You don't swat a fly with a cannon," Mundle said after the hearing.

Mundle indicated, nevertheless, that he was not moved by Baldwind's argument that he had not intended to violate the law.

"It's not the question of whether he intend to violate the law," Mundle said. "The evidence shows he did violate the law."

Prior to yesterday's hearing, Mundle met privately with Baldwin and his attorney. Mundle indicated later that Baldwin had agreed to acknowledge his conflict during the hearing in exchange for Mundle's recommendation for leniency.

If the board finds him guilty, Baldwin would received a maximum fine of $4,000. Mundle said it would be up to Mayor Washington to decide whether Baldwin should be fined.

After news reports were published earlier this year about Baldwin's recruitment for Nova, Washington had asked city administrator Julian Dugas to determine whether Baldwin had acted improperly.

Dugas said yesterday he had received answers to questions he asked Baldwin but he had not forwarded a report to the mayor.Dugas said neither he nor the mayor would comment on Baldwin's case while it was pending before the ethics board.

Dugas did say he thought the mayor considered the charges against Baldwin to be a "tempest in a teapot."

At the time Baldwin did the alleged recruiting, he was in line to become a consultant to Nova University and could have been paid up to $500 a month to supervise instruction of those he helped recruit, according to Nova officials.

After news stories appeared about Baldwin's use of city stationery and raising questions about his doctorate degree, Baldwin asked not to be considered for the position, according to Nova officials.