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HomeMy WebLinkAbout1451 EathorneIn Re: Robert Eathorne, Respondent File Docket: X -ref: Date Decided: Date Mailed: Before: Louis W. Fryman, Chair Donald M. McCurdy Paul M. Henry Raquel K. Bergen Nicholas A. Colafella 06 -053 Order No. 1451 12/19/07 12/28/07 This is a final adjudication of the State Ethics Commission. Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding a possible violation of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq., by the above -named Respondent. At the commencement of its investigation, the Investigative Division served upon Respondent written notice of the specific allegation(s). Upon completion of its investigation, the Investigative Division issued and served upon Respondent a Findings Report identified as an "Investigative Complaint." An Answer was not filed and a hearing was deemed waived. All of the averments in the Investigative Complaint are admitted and are set forth as the following Findings. The record is complete. This adjudication of the State Ethics Commission is issued under the Ethics Act and will be made available as a public document thirty days after the mailing date noted above. However, reconsideration may be requested. Any reconsideration request must be received at this Commission within thirty days of the mailing date and must include a detailed explanation of the reasons as to why reconsideration should be granted in conformity with 51 Pa. Code § 21.29(b). A request for reconsideration will not affect the finality of this adjudication but will defer its public release pending action on the request by the Commission. The files in this case will remain confidential in accordance with the Ethics Act. Any person who violates such confidentiality commits a misdemeanor and, upon conviction, may be subject to a fine of not more than $1,000 or imprisonment for not more than one year. Confidentiality does not preclude discussing this case with an attorney at law. Eathorne, # 06 -053 Page 2 I. ALLEGATION: That Robert Eathorne, a (public official /public employee) in his capacity as a Member of the Westmoreland Municipal Authority (WWMA) violated the following provisions of the State Ethics Act (Act 93 of 1998) when he used the authority of his public position when he authorized advances of expenses for his attendance at conferences and conventions and then claimed expenses in excess of actual expenses incurred; when he used expense advancements for expenses incurred by his spouse; when he authorized advance payments of expenses to him for conferences and convention related events he did not attend; and when he authorized the use of WWMA credit card for the payment of expenses and items of a personal nature for himself and his spouse. § 1103. Restricted activities (a) Conflict of interest - -No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 Pa.C.S. § 1103(a). § 1102. Definitions "Conflict" or "conflict of interest." Use by a public official or public employee of the authority of his office or employment or any confidential information received through his holding public office or employment for the private pecuniary benefit of himself, a member of his immediate family or a business with which he or a member of his immediate family is associated. The term does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. 65 Pa.C.S. § 1102. II. FINDINGS: 1. The Investigative Division of the State Ethics Commission received a signed, sworn complaint alleging that Robert Eathorne violated provisions of the State Ethics Act (Act 93 of 1998). 2. Upon review of the complaint the Investigative Division initiated a preliminary inquiry on September 14, 2006. 3. The preliminary inquiry was completed within sixty days. 4. On November 9, 2006, a letter was forwarded to Robert Eathorne, by the Investigative Division of the State Ethics Commission, informing him that a complaint against him was received by the Investigative Division and that a full investigation was being commenced. a. Said letter was forwarded by certified mail, no. 7006 2150 0000 8776 4254. b. The domestic return receipt bore the signature of Patricia Henrickson, with a Eathorne, # 06 -053 Page 3 delivery date of November 16, 2006. 5. On March 27, 2007, the Investigative Division of the State Ethics Commission filed an application for a ninety -day extension of time to complete the investigation. 6. The Commission issued an order on March 7, 2007, granting the ninety -day extension. 7 On June 8, 2007, the Investigative Division of the State Ethics Commission filed an application for a second ninety -day extension of time to complete the investigation. 8. The Commission issued an order on June 11, 2007, granting the ninety -day extension. 9. On October 26, 2007, an amended Notice of Investigation was forwarded to Robert Eathorne, c/o Ronald Carnevali, Jr., Esq. Law Offices of Spence, Custer, Saylor, Wolfe & Rose, L.L.C., by the Investigative Division of the State Ethics Commission informing him that the allegations contained in the November 9, 2006, Notice of Investigation were being amended. a. Said letter was forwarded by certified mail, no. 7006 2150 0000 8776 4919. b. The domestic return receipt bore the signature of Robert Snyder, with a delivery date of October 29, 2007. 10. Periodic notice letters were forwarded to Robert Eathorne in accordance with the provisions of the Ethics Law advising him of the general status of the investigation. 11. The Investigative Complaint was mailed to the Respondent on November 2, 2007. 12. Robert Eathorne has served as a member of the Western Westmoreland Municipal Authority (WWMA) from July 18, 1996, until December 2006. a. Eathorne was appointed to the WWMA by the Manor Borough Council. 1. Eathorne is also an elected member of Manor Borough Council. 13. Eathorne has held the position of board treasurer of the WWMA since February 17, 2000. a. Eathorne was appointed WWMA treasurer at the WWMA reorganization meeting of February 17, 2000, and reappointed at reorganization meetings on the following dates: 02/15/01 02/21/02 02/20/03 02/19/04 02/17/05 02/16/06 b. Eathorne is not compensated in his position as treasurer. 14. The WWMA was formed in 1972 as a Joint Authority by the boroughs of Manor, Irwin, and North Irwin; and the townships of North Huntingdon, Penn, and Hempfield. Eathorne, # 06 -053 Page 4 a. Articles of Incorporation were filed with the Pennsylvania Department of State on February 24, 1972. b. The WWMA was formed pursuant to the requirements of the Municipality Authorities Act of 1945, as amended. c. The purpose of the Authority is defined in the Articles of Incorporation: The purpose of this Joint Authority is to and it is hereby directed and empowered to undertake the planning, acquisition, construction, financing and operation of a regional sewage transportation and treatment system to serve the incorporating municipalities and adjacent areas." 15. Bylaws for the WWMA were originally adopted on February 29, 1972, and amended on April 19, 1978; April 19, 1984; August 20, 1986; and April 23, 1996. a. Article 11 of the bylaws provided for the appointment of officers including the following: Chairman Vice - Chairman Secretary Treasurer Assistant Secretary- Treasurer Chairman of each Sludge Disposal, Insurance Grounds and maintenance, and legal and Engineering services All positions with the exception of Assistant Secretary- Treasurer shall be members of the Board of the Authority. b. Compensation of officers of the Authority Board shall be determined by resolution adopted at the annual meeting of the board subsequent to the election of officers. 16. The position of Treasurer, as outlined in the bylaws, has the following duties and responsibilities: The Treasurer shall have the care and custody of all funds of the Authority and shall deposit the same in the name of the Authority in such bank or banks as the Board of the Authority may select. The Treasurer shall sign all orders and checks for the payment of money, and shall pay out and disburse such monies under the direction of the Board of the Authority. Except as otherwise authorized by resolution of the Board of the Authority, all such orders and checks shall be countersigned by the Chairman. He shall keep regular books of accounts showing receipts and expenditures, and shall render to the Board of the Authority at each regular meeting (or more often when requested) an account of his transactions and also of the financial condition of the Authority. He shall give such bond for the faithful performance of his duties as the Board of the Authority may determine and pay for. 17. Eathorne's main function as treasurer has been to co -sign checks along with assistant secretary /treasurer Barbara Balcerek. a. Eathorne has reviewed invoices prior to payment being made by Balcerek. Eathorne, # 06 -053 Page 5 18. The WWMA annually budgets for board members to travel for seminars and meetings. a. The budget for such travel also includes the Plant Manager and Assistant Secretary- Treasurer. 19. Since 2003, the WWMA has budgeted and spent the following for travel expenses: Years Budd Spent 2003 $30,000.00 $39,269.00 2004 $35,000.00 $63,070.00 2005 $35,000.00 $49,240.00 a. Travel expenses for seminars /conventions decreased in 2006 around the time that the investigation of Eathorne began. 20. WWMA board members and selected employees have regularly attended conferences, conventions, and seminars since at least 2001. a. Board authorization has not been required prior to each travel pursuant to travel policies adopted by the WWMA Board of Directors. b. Travel for conventions and conferences has included but has not been limited to the following: Allegheny League of Municipalities (ALOM) Pennsylvania Municipal Authorities Association (PMAA) Water Environment Federation (WEFTEC) Pennsylvania Water Environment Association (PWEA) 21. WWMA procedures for a board member or employee attending conferences, seminars, and conventions include the following: a. Board members are provided announcements of seminars and conferences by Balcerek. 1. The member will advise Balcerek of events of interest. 2. Balcerek registers members to attend various events and arranges airfare and hotels, at the conference site. b. Balcerek w i l l issue advance payments to board members for travel expenses and pay registration fees for hotels and conferences. 1. Eathorne co -signs all checks issued for advances and registration fees. 22. The WWMA board does not vote to authorize member travel for conferences and conventions. a. Authorization to travel does not require a board vote pursuant to WWMA travel policies. b. Authorization is not necessary to receive expense advancements. 23. Policies for travel have been amended on occasion since 1999. Eathorne, # 06 -053 Page 6 a. Policy changes have included increasing the advance expense amounts allotted to board members. b. Eathorne has advocated and participated in WWMA decisions to increase advances issued to members for travel - related expenses. 24. During his tenure on the WWMA, Eathorne has consistently advocated for increased advance payments to board members for travel and has argued against any attempts to restrict travel or put limits on board members' travel. a. Eathorne has argued against any restrictions due to the extensive travel by him and his wife at rate payer expense. 25. During the September 16, 1999, WWMA board meeting, Eathorne commented on his review of the policy for conference expenses and advocated for an increase in the advance amount. a. Eathorne reported that the advance amount of $1,500.00 approved by the WWMA was insufficient. b. Eathorne stated that expenses have increased and [he] feels the advance should be increased. c. A motion made by Eathorne to amend the policy for conference expenses by increasing advances to $2,000.00 was approved unanimously. 26. The costs incurred by members of WWMA when attending conferences has been the subject of comments and criticism by the public. a. Criticisms have been raised at times when the WWMA has authorized sewer rate increases. 27. On February 21, 2002, as a result of questions raised regarding member travel and a State Ethics Commission investigation of a public official in another jurisdiction, the WWMA unanimously voted to approve a moratorium on all travel by members to conferences and meetings until September 4, 2002. a. Municipalities' objections to a sewer rate increase was also a factor in this action being taken. 28. At the subsequent board meeting held on March 21, 2002, Eathorne attempted to rescind the moratorium on travel to conferences and seminars. a. Eathorne's motion was defeated by a 5 to 2 vote. 29. The WWMA lifted the moratorium in September 2002. a. Contemporaneously with the moratorium being lifted, Eathorne advocated the increase from $2,000 to $2,500 in expense advance funds in time for his travel to the WEFTEC conference in Chicago. 30. Eathorne participated in WWMA board action in September 2002 which again increased the conference advance of expenses. a. A motion was approved by the board on September 19, 2002, increasing the amount of the advance money from $2,000.00 to $2,500.00. Eathorne, # 06 -053 Page 7 1. Eathorne seconded the motion. 2. Eathorne advocated the advance prior to his attendance at 2002 WEFTEC conference held in Chicago. b. Eathorne advocated the advance increase 18 days after a travel moratorium was lifted. c. The advance expenses for conference attendance have remained at $2,500 since September 19, 2002. 31. The WWMA's policies and procedures approved on April 19, 2000, regarding conference attendance and expenses includes the following: a. The Authority shall maintain membership in the Pennsylvania Municipal Authorities Association and its Regional Organization, the Water Pollution Control Federation, the Water Pollution Control Association of Pennsylvania, and the Western Pennsylvania Water Pollution Control Association, Inc. In addition, the Authority may, by motion of the board, join other associations and organizations concerned with municipal or governmental affairs. b. Any board member, officer, manager, or solicitor of the Authority is authorized, without further action of the Authority, to attend any convention, conference, seminar, or meeting of any of the above organizations. c. The Authority shall reimburse the expenses of each such person attending the above functions. d. Such expenses shall consist of the following: 1. Registration fees; 2. Travel; A. Mileage for personal vehicle - current I.R.S. allowance. No mileage will be paid for rental vehicles, or Authority -owned vehicles. B. Commercial travel -- as arranged by the Authority; 3. Lodging; as arranged by the Authority; 4. Meals; 5. All other actual expenses reasonably incurred in traveling to and attending such functions. e. Each attendee may request from the Authority an advancement for expenses not to exceed $2,000.00. Each attendee shall submit to the Authority, within 60 days of the conclusion of the function, or December 31 of the year in which the function occurs, whichever first occurs, an itemized expense statement on a form designated by the Authority, together with supporting receipts and documentation of such expenses. Each attendee may incur miscellaneous documented by [sic] unreceipted expenses to a maximum of $25.00 per function. If no expense report is filed along with the proper receipts within the 60 days or on or before December 31 in the year in which the function occurs, whichever first occurs, all advances will become Eathorne, # 06 -053 Page 8 income and a Form 1099 will be sent on the amount advanced. f. The Assistant Secretary- Treasurer of the Authority is authorized and directed to undertake all actions required to carry out the policies and procedures herein set forth. 32. On September 28, 2004, the WWMA board of directors, including Eathorne, approved a revised conference travel policy and procedure. a. The only difference between the April 19, 2000, policy and the September 28, 2004, policy is the documentation of the increase in the advance for expenses from $2,000.00 to $2,500.00. 1. This revision was approved on September 19, 2002 (Finding #30). 33. The WWMA travel policies in effect since at least 2000 have provided for the reimbursement for actual expenses reasonably incurred in traveling to and attending functions provided that the attendee shall submit to the WWMA an itemized expense statement together with supporting receipts and documentation of such expenses. a. Miscellaneous unreceipted expenses of $25.00 per function were also authorized. b. If an attendee failed to submit an itemized expense report, a form 1099 would be issued in the amount of the advance amount. c. Travel policies did not provide for the reimbursement of spousal and /or guest expenses. 34. Board member travel expenses are not approved by a vote of the WWMA board of directors. a. Board members' advanced registrations for conferences, lodging, and airfare are paid by WWMA check or by use of a WWMA credit card. 1. Airfare and related expenses for out -of -state travel were charged to American Express Cards issued to Barbara Balcerek and the WWMA Plant Managers Barry Riley and Kevin Fisher. b. Balcerek issues advance checks to members making a request. 1. All advance checks between 2001 and 2006 were co- signed by Eathorne. 2. The board does not approve advance payments or any expenses claimed by board members. c. Travel expense reports are reviewed only by assistant treasurer Balcerek. 1. Balcerek tabulates receipts submitted to insure amounts claimed equal advances of expenses. 2. Balcerek will issue an additional expense check if amounts claimed exceed the amount of the advance. 3. Balcerek does not challenge any expenses claimed by board Eathorne, # 06 -053 Page 9 members. 4. Prior to 2005, no expenses claimed by board members have been disputed. d. Travel expense reports are not reviewed or approved by the WWMA board. e. Board members have submitted receipts which have not been scrutinized or reviewed by anyone with authority to challenge individual claims. 35. During the July 21, 2005, WWMA board meeting, officials from North Huntingdon Township raised questions regarding board member expenses, including advance payments. a. Solicitor John Campfield addressed the advance payments made to board members and stated that board members were not permitted to use advance funds to pay for spousal expenses. b. Eathorne also responded as follows: "I can tell you that when people get an advance, they'll bring back their receipts and the money that is not spent. Those receipts are for their expenses." c. Eathorne also responded to a question regarding reimbursements in excess of advances: "Legitimate expenses are reimbursed." d. Eathorne also noted that there was no dollar limit on the amount of expenses that could be reimbursed. 36. In or about March 2006 WWMA board member John Shepherd, appointed by North Huntingdon Township (NHT), suggested to the WWMA that the board adopt similar travel policies as enacted for NHT officials. a. The NHT travel policy was distributed to all WWMA board members at the March 16, 2006, WWMA Meeting. b. The NHT travel policy had tight spending limits for board member travel. c. Shepherd proposed the policy due to high costs incurred by Eathorne and other board members when traveling at WWMA expense. 37. During the April 20, 2006, meeting, board members, including Eathorne, commented on the proposal to reduce travel expenses for board members. a. Board members Nabuda, Eathorne, and Pioth were opposed to any changes in the travel policy or the advance amounts given to board members for travel. b. In response to board member Pioth's comment that advance amounts as proposed by Shepherd were low, Eathorne commented, "I consider that an insult." 38. Board travel expenses and board members' lack of attendance at convention and seminar events were again discussed during the May 18, 2006, meeting. a. Board member John Shepherd recommended that the Board invite the State Ethics Commission to look at the expenses for the 2004 convention in New Orleans. Eathorne, # 06 -053 Page 10 b. Eathorne was opposed and is quoted as follows: "What more do you want? North Huntingdon Township has looked at them. John Sarp has looked at them. And found them to be free and clear of any fraud or misrepresentation." c. A motion was made by Shepherd, seconded by board member Larry Chrzan, to have the State Ethics Commission look at the 2004 travel expense vouchers from the WEFTEC New Orleans convention. 1. The motion was defeated by a 7 to 2 vote. 2. Robert Eathorne voted against the motion. 39. Robert Eathorne, as a member of the WWMA, has attended at least 30 conferences, conventions, and workshops between October 2001 and October 2006. a. Eathorne has attended conferences, conventions, and workshops of the following: Pennsylvania Municipal Authorities Association (PMAA) Allegheny League of Municipalities (ALOM) Water Environment Federation (WEFTEC) Pennsylvania Water Environment Association (PWEA) b. PMAA conferences are held annually in either Pittsburgh or Hershey. c. ALOM conferences are held annually in the Spring and Fall of each year at Seven Springs Resort. d. WEFTEC conferences are held annually and have been held in such locations as Chicago, IL; Atlanta, GA; Pasadena, CA; New Orleans, LA; Dallas, TX; and Washington, D.C. 40. Robert Eathorne's spouse, Patricia Henrickson Eathorne, has accompanied Eathorne on all conferences attended by Eathorne. a. The majority of Patricia Eathorne's expenses incurred while accompanying Eathorne have been paid by the WWMA. 1. Eathorne has paid for his spouse's airfare when attending WEFTEC conferences. 41. Eathorne has received advances of expenses for conferences and /or conventions on a regular basis from August 2001 through 2006 as follows: a. ALOM 4/3/03 $ 500.00 9/23/03 $ 800.00 9/21/04 $ 800.00 4/7/05 $ 800.00 9/27/05 $ 800.00 4/6/06 $1,000.00 9/5/06 $ 800.00 $5,500.00 b. PMAA Eathorne, # 06 -053 Page 11 8/23/01 $1,500.00 8/19/03 $1,500.00 8/19/04 $1,200.00 9/8/05 $1,200.00 9/7/06 $ 800.00 $6,200.00 c. WEFTEC 10/19/01 $ 2,000.00 9/24/02 $ 2,500.00 10/9/03 $ 2,500.00 9/28/04 $ 2,500.00 9/27/05 $ 2,500.00 10/19/06 $ 2,000.00 $14,000.00 d. Pumper Expo 2/7/06 $ 2,500.00 e. Legislative Days 5/6/03 $ 700.00 5/6/04 $ 700.00 f. PWEA 7/11/06 Total of Advances $ 800.00 $30,400.00 g. Totals by year: 2001 $ 3,500. 2002 $ 2,500. 2003 $ 6,000. 2004 $ 5,200. 2005 $ 5,300. 2006 $ 7,900. $30,400. h. These advances do not encompass all monies paid to the Eathornes or on Eathorne's behalf by the WWMA for expense claims made by Eathorne. 42. Eathorne would typically submit travel expense reports to Barbara Balcerek at the conclusion of a travel event. a. Eathorne did not submit expense reports in 2001 and 2006. 1. Eathorne received FORM 1099's from the WWMA in both of those years. 2. Tax returns filed by Eathorne for 2001 and 2006 claim expenses in excess of the advances. 43. Travel expense reports submitted by Eathorne would include: - WWMA expense report form - hotel invoice - turnpike toll receipts - restaurant receipts - generic receipt stubs - cab receipts Conference Number Date Amount 2001 Fall ALOM 308370 9/27/2001 $ 21.00 2001 Fall ALOM 357055 9/27/2001 $ 35.00 2001 Fall ALOM 824633 9/30/2001 $ 30.00 2001 Fall PMAA 65622 8/27/2001 $ 40.00 2001 Fall PMAA 65624 8/28/2001 $ 109.00 2001 Fall PMAA 65634 8/25/2001 $ 30.00 2001 Fall PMAA 65636 8/26/2001 $ 32.00 2001 Fall PMAA 85248 8/28/2001 $ 21.00 2001 Fall PMAA 85441 8/27/2001 $ 20.00 2001 Fall PMAA 86349 8/26/2001 $ 25.00 2001 Fall PMAA 145705 8/27/2001 $ 61.00 2001 Fall PMAA 450171 8/25/2001 $ 80.00 2001 Fall PMAA 467817 8/26/2001 $ 75.00 2001 Fall PMAA 717708 8/25/2001 $ 15.00 2001 Fall PMAA 874795 8/28/2001 $ 18.00 2001 Spring PMAA 57281 3/20/2001 $ 25.00 Eathorne, # 06 -053 Page 12 - vehicle rental receipts 44. The generic receipt stubs submitted by Eathorne constituted the bulk of the meal expenses claimed by Eathorne. a. These types of receipts were submitted by Eathorne to justify expenses and enabled him to keep the entire amount of advance expense checks issued to him. b. The stubs never identified a restaurant or location where expenses were allegedly incurred. c. Receipt stubs submitted by Eathorne were often numbered sequentially, matching in style, format, and manufacturer, and giving the appearance that stubs were from the same receipt book. d. Eathorne is not the only WWMA board member to have extensively used these types of receipts. 1. Only Plant Manager Barry Riley submitted such stubs in similar volume as Eathorne to justify expenses. 2. Most board members submit receipts which identify vendor, location, date, and time of purchase or meal. e. Many of the receipt stubs submitted by Eathorne claim dinner expenses. 1. Eathorne was known to frequently dine at dinners hosted by vendors, vendor hospitality suites or dine at the expense of the township engineer. 2. Even though Eathorne did not pay for these meals, he nonetheless submitted receipts claiming the expense. 45. Eathorne has submitted 134 generic receipt stubs claiming expenses totaling $7,148.62 as follows: 2001 Spring PMAA 70478 3/21/2001 $ 30.00 2001 Spring PMAA 364076 3/21/2001 $ 70.00 2001 Spring PMAA 512634 3/19/2001 $ 30.00 2001 Spring PMAA 549287 3/19/2001 $ 15.00 2001 Spring PMAA 591582 3/18/2001 $ 75.00 2001 Spring PMAA 717715 3/21/2001 $ 20.00 2001 Spring PMAA 718903 3/20/2001 $ 16.00 2001 Spring PMAA 806291 3/18/2001 $ 19.00 2001 Spring PMAA 0141 -21 3/18/2001 $ 14.00 2001 WEFTEC 33017 10/13/2001 $ 21.00 2001 WEFTEC 51893 10/18/2001 $ 80.00 2001 WEFTEC 65335 10/18/2001 $ 30.00 2001 WEFTEC 65340 10/16/2001 $ 65.00 2001 WEFTEC 65633 10/14/2001 $ 22.00 2001 WEFTEC 97868 10/16/2001 $ 25.00 2001 WEFTEC 317957 10/14/2001 $ 25.00 2001 WEFTEC 340836 10/17/2001 $ 80.00 2001 WEFTEC 357059 10/17/2001 $ 32.00 2001 WEFTEC 357061 10/13/2001 $ 32.00 2001 WEFTEC 633420 10/16/2001 $ 40.00 2001 WEFTEC 633421 10/18/2001 $ 30.00 2001 WEFTEC 717716 10/17/2001 $ 21.00 2001 WEFTEC 717717 10/13/2001 $ 95.00 2001 WEFTEC 729947 10/14/2001 $ 92.00 2001 WEFTEC 729958 10/15/2001 $ 31.00 2001 WEFTEC 824647 10/15/2001 $ 20.00 2001 WEFTEC 914016 10/15/2001 $ 106.00 2002 WEFTEC 3043 10/2/2002 $ 13.73 2002 WEFTEC 65628 9/30/2002 $ 115.00 2002 WEFTEC 71501 10/2/2002 $ 40.00 2002 WEFTEC 71508 10/1/2002 $ 120.00 2002 WEFTEC 433532 10/2/2002 $ 38.00 2002 WEFTEC 644894 9/30/2002 $ 45.00 2002 WEFTEC 990214 9/28/2002 $ 240.00 2005 WEFTEC 79275 11/2/2005 $ 108.00 2005 WEFTEC 500579 10/31/2005 $ 30.00 2005 WEFTEC 633431 11/2/2005 $ 32.00 2005 WEFTEC 807583 10/29/2005 $ 40.00 2005 WEFTEC 960732 11/1/2005 $ 44.00 2005 WEFTEC 1137384 10/30/2005 $ 110.00 Fall 04 ALOM Conference 874797 9/23/2004 $ 51.83 Fall 04 ALOM Conference 953393 9/28/2004 $ 45.00 Legislative Day 50218 5/14/2003 $ 65.00 Legislative Day 165342 5/13/2003 $ 21.00 Legislative Day 320508 5/12/2003 $ 50.00 Legislative Day 559054 5/14/2003 $ 25.00 Legislative Day 990213 5/12/2003 $ 35.00 PMAA Conference 40841 8/23/2004 $ 52.00 PMAA Conference 65329 9/14/2005 $ 34.00 Eathorne, # 06 -053 Page 13 PMAA Conference 79269 9/13/2005 $ 31.00 PMAA Conference 79272 9/11/2005 $ 110.15 PMAA Conference 128668 8/25/2003 $ 30.30 PMAA Conference 128694 8/26/2003 $ 32.15 PMAA Conference 145026 8/24/2003 $ 25.30 PMAA Conference 204794 8/24/2003 $ 107.00 PMAA Conference 205245 8/27/2003 $ 180.00 PMAA Conference 285932 8/25/2003 $ 25.50 PMAA Conference 291853 8/23/2004 $ 48.00 PMAA Conference 450173 8/23/2004 $ 150.00 PMAA Conference 470143 9/13/2005 $ 69.00 PMAA Conference 497528 9/14/2005 $ 35.00 PMAA Conference 500222 9/12/2005 $ 94.61 PMAA Conference 633415 9/11/2005 $ 31.00 PMAA Conference 740751 9/14/2005 $ 131.00 PMAA Conference 849576 8/23/2004 $ 150.00 PMAA Conference 874799 8/22/2004 $ 15.83 PMAA Conference 981424 9/12/2005 $ 28.00 Pumper Expo 51894 2/16/2006 $ 36.00 Pumper Expo 65333 2/19/2006 $ 134.00 Pumper Expo 65336 2/18/2006 $ 145.00 Pumper Expo 65621 2/14/2006 $ 40.00 Pumper Expo 65638 2/19/2006 $ 35.00 Pumper Expo 65906 2/14/2006 $ 38.00 Pumper Expo 79273 2/17/2006 $ 130.00 Pumper Expo 317953 2/16/2006 $ 31.00 Pumper Expo 405244 2/17/2006 $ 51.00 Pumper Expo 464097 2/18/2006 $ 29.00 Pumper Expo 471734 2/15/2006 $ 31.00 Pumper Expo 843001 2/15/2006 $ 43.00 Pumper Expo 936435 2/16/2006 $ 102.00 Spring 05 ALOM Conference 260323 $ 20.00 Spring 05 ALOM Conference 288409 $ 65.00 Spring 05 ALOM Conference 767329 $ 22.60 Spring 05 ALOM Conference 824624 $ 35.00 Spring 05 ALOM Conference 955635 $ 13.47 Spring 06 ALOM Conference 281329 4/9/2006 $ 126.00 Spring 06 ALOM Conference 373782 4/6/2006 $ 15.00 Spring 06 ALOM Conference 556617 4/6/2006 $ 26.00 2003 WEFTEC 34302 10/17/2003 $ 30.00 2003 WEFTEC 64190 10/13/2003 $ 21.00 2003 WEFTEC 65911 10/15/2003 $ 21.00 2003 WEFTEC 79271 10/12/2003 $ 32.00 2003 WEFTEC 79274 10/11/2003 $ 30.00 2003 WEFTEC 98232 10/12/2003 $ 26.00 2003 WEFTEC 140648 10/14/2003 $ 23.00 2003 WEFTEC 150594 10/15/2003 $ 65.00 2003 WEFTEC 257833 10/15/2003 $ 25.00 2003 WEFTEC 264733 10/17/2003 $ 15.00 Eathorne, # 06 -053 Page 14 Conference Number Date Amount 2002 WEFTEC 3043 10/2/2002 $ 13.73 2001 WEFTEC 33017 10/13/2001 $ 21.00 PMAA Conference 40841 8/23/2004 $ 52.00 Legislative Day 50218 5/14/2003 $ 65.00 2001 WEFTEC 51893 10/18/2001 $ 80.00 Pumper Expo 51894 2/16/2006 $ 36.00 2001 Spring PMAA 57281 3/20/2001 $ 25.00 PMAA Conference 65329 9/14/2005 $ 34.00 Pumper Expo 65333 2/19/2006 $134.00 2001 WEFTEC 65335 10/18/2001 $ 30.00 Pumper Expo 65336 2/18/2006 $145.00 2001 WEFTEC 65340 10/16/2001 $ 65.00 Pumper Expo 65621 2/14/2006 $ 40.00 2001 Fall PMAA 65622 8/27/2001 $ 40.00 2001 Fall PMAA 65624 8/28/2001 $109.00 2002 WEFTEC 65628 9/30/2002 $115.00 2001 WEFTEC 65633 10/14/2001 $ 22.00 2001 Fall PMAA 65634 8/25/2001 $ 30.00 2001 Fall PMAA 65636 8/26/2001 $ 32.00 Pumper Expo 65638 2/19/2006 $ 35.00 Pumper Expo 65906 2/14/2006 $ 38.00 2001 Spring PMAA 70478 3/21/2001 $ 30.00 2002 WEFTEC 71501 10/2/2002 $ 40.00 2003 WEFTEC 287358 10/11/2003 $ 25.50 2003 WEFTEC 317956 10/16/2003 $ 15.00 2003 WEFTEC 500461 10/15/2003 $ 35.00 2003 WEFTEC 777119 10/15/2003 $ 23.00 2004 WEFTEC 130867 $ 167.84 2004 WEFTEC 435178 10/2/2004 $ 55.00 2004 WEFTEC 717175 10/6/2004 $ 210.00 2004 WEFTEC 783365 10/4/2004 $ 61.50 2004 WEFTEC 783368 $ 39.00 2004 WEFTEC 783375 $ 21.00 2004 WEFTEC 783377 10/4/2004 $ 25.00 2004 WEFTEC 783378 10/5/2004 $ 110.00 2004 WEFTEC 783379 $ 19.00 2004 WEFTEC 824620 $ 16.37 Legislative Day 58614 5/11/2004 $ 120.30 Legislative Day 95161 5/11/2004 $ 25.00 Legislative Day 129003 5/11/2004 $ 45.80 Legislative Day 724423 5/10/2004 $ 22.10 Legislative Day Legislative Day 872909 0058614 5/10/2004 5/11/04 $ 114.74 $ 120.00 Eathorne, # 06 -053 Page 15 46. Many of the receipt stubs submitted by Eathorne in his handwriting are parts of sequences of numbers identical in format and generated from a series of the same books as depicted below: 2002 WEFTEC 71508 10/1/2002 $120.00 PMAA Conference 79269 9/13/2005 $ 31.00 PMAA Conference 79272 9/11/2005 $110.15 Pumper Expo 79273 2/17/2006 $130.00 2005 WEFTEC 79275 11/2/2005 $108.00 2001 Fall PMAA 85248 8/28/2001 $ 21.00 2001 Fall PMAA 85441 8/27/2001 $ 20.00 2001 Fall PMAA 86349 8/26/2001 $ 25.00 2001 WEFTEC 97868 10/16/2001 $ 25.00 PMAA Conference 128668 8/25/2003 $ 30.30 PMAA Conference 128694 8/26/2003 $ 32.15 PMAA Conference 145026 8/24/2003 $ 25.30 2001 Fall PMAA 145705 8/27/2001 $ 61.00 Legislative Day 165342 5/13/2003 $ 21.00 PMAA Conference 204794 8/24/2003 $107.00 PMAA Conference 205245 8/27/2003 $180.00 Spring 05 ALOM Conference 260323 $ 20.00 Spring 06 ALOM Conference 281329 4/9/2006 $126.00 PMAA Conference 285932 8/25/2003 $ 25.50 Spring 05 ALOM Conference 288409 $ 65.00 PMAA Conference 291853 8/23/2004 $ 48.00 2001 Fall ALOM 308370 9/27/2001 $ 21.00 Pumper Expo 317953 2/16/2006 $ 31.00 2001 WEFTEC 317957 10/14/2001 $ 25.00 Legislative Day 320508 5/12/2003 $ 50.00 2001 WEFTEC 340836 10/17/2001 $ 80.00 2001 Fall ALOM 357055 9/27/2001 $ 35.00 2001 WEFTEC 357059 10/17/2001 $ 32.00 2001 WEFTEC 357061 10/13/2001 $ 32.00 2001 Spring PMAA 364076 3/21/2001 $ 70.00 Spring 06 ALOM Conference 373782 4/6/2006 $ 15.00 Pumper Expo 405244 2/17/2006 $ 51.00 2002 WEFTEC 433532 10/2/2002 $ 38.00 2001 Fall PMAA 450171 8/25/2001 $ 80.00 PMAA Conference 450173 8/23/2004 $150.00 Pumper Expo 464097 2/18/2006 $ 29.00 2001 Fall PMAA 467817 8/26/2001 $ 75.00 PMAA Conference 470143 9/13/2005 $ 69.00 Pumper Expo 471734 2/15/2006 $ 31.00 PMAA Conference 497528 9/14/2005 $ 35.00 PMAA Conference 500222 9/12/2005 $ 94.61 2005 WEFTEC 500579 10/31/2005 $ 30.00 2001 Spring PMAA 512634 3/19/2001 $ 30.00 2001 Spring PMAA 549287 3/19/2001 $ 15.00 Spring 06 ALOM Conference 556617 4/6/2006 $ 26.00 Legislative Day 559054 5/14/2003 $ 25.00 2001 Spring PMAA 591582 3/18/2001 $ 75.00 PMAA Conference 633415 9/11/2005 $ 31.00 2001 WEFTEC 633420 10/16/2001 $ 40.00 Eathorne, # 06 -053 Page 16 2001 WEFTEC 633421 10/18/2001 $ 30.00 2005 WEFTEC 633431 11/2/2005 $ 32.00 2002 WEFTEC 644894 9/30/2002 $ 45.00 2001 Fall PMAA 717708 8/25/2001 $ 15.00 2001 Spring PMAA 717715 3/21/2001 $ 20.00 2001 WEFTEC 717716 10/17/2001 $ 21.00 2001 WEFTEC 717717 10/13/2001 $ 95.00 2001 Spring PMAA 718903 3/20/2001 $ 16.00 2001 WEFTEC 729947 10/14/2001 $ 92.00 2001 WEFTEC 729958 10/15/2001 $ 31.00 PMAA Conference 740751 9/14/2005 $131.00 Spring 05 ALOM Conference 767329 $ 22.60 2001 Spring PMAA 806291 3/18/2001 $ 19.00 2005 WEFTEC 807583 10/29/2005 $ 40.00 Spring 05 ALOM Conference 824624 $ 35.00 2001 Fall ALOM 824633 9/30/2001 $ 30.00 2001 WEFTEC 824647 10/15/2001 $ 20.00 Pumper Expo 843001 2/15/2006 $ 43.00 PMAA Conference 849576 8/23/2004 $150.00 2001 Fall PMAA 874795 8/28/2001 $ 18.00 Fall 04 ALOM Conference 874797 9/23/2004 $ 51.83 PMAA Conference 874799 8/22/2004 $ 15.83 2001 WEFTEC 914016 10/15/2001 $106.00 Pumper Expo 936435 2/16/2006 $102.00 Fall 04 ALOM Conference 953393 9/28/2004 $ 45.00 Spring 05 ALOM Conference 955635 $ 13.47 2005 WEFTEC 960732 11/1/2005 $ 44.00 PMAA Conference 981424 9/12/2005 $ 28.00 Legislative Day 990213 5/12/2003 $ 35.00 2002 WEFTEC 990214 9/28/2002 $240.00 2005 WEFTEC 1137384 10/30/2005 $110.00 2001 Spring PMAA 0141 -21 3/18/2001 $ 14.00 2003 WEFTEC 34302 10/17/2003 $ 30.00 Legislative Day 58614 5/11/2004 $120.30 2003 WEFTEC 64190 10/13/2003 $ 21.00 2003 WEFTEC 65911 10/15/2003 $ 21.00 2003 WEFTEC 79271 10/12/2003 $ 32.00 2003 WEFTEC 79274 10/11/2003 $ 30.00 Legislative Day 95161 5/11/2004 $ 25.00 2003 WEFTEC 98232 10/12/2003 $ 26.00 Legislative Day 129003 5/11/2004 $ 45.80 2004 WEFTEC 130867 $167.84 2003 WEFTEC 140648 10/14/2003 $ 23.00 2003 WEFTEC 150594 10/15/2003 $ 65.00 2003 WEFTEC 257833 10/15/2003 $ 25.00 2003 WEFTEC 264733 10/17/2003 $ 15.00 2003 WEFTEC 287358 10/11/2003 $ 25.50 2003 WEFTEC 317956 10/16/2003 $ 15.00 2004 WEFTEC 435178 10/2/2004 $ 55.00 Eathorne, # 06 -053 Page 17 2003 WEFTEC 500461 10/15/2003 $ 35.00 2004 WEFTEC 717175 10/6/2004 $210.00 Legislative Day 724423 5/10/2004 $ 22.10 2003 WEFTEC 777119 10/15/2003 $ 23.00 2004 WEFTEC 783365 10/4/2004 $ 61.50 2004 WEFTEC 783368 $ 39.00 2004 WEFTEC 783375 $ 21.00 2004 WEFTEC 783377 10/4/2004 $ 25.00 2004 WEFTEC 783378 10/5/2004 $110.00 2004 WEFTEC 783379 $ 19.00 2004 WEFTEC 824620 $ 16.37 Legislative Day 872909 5/10/2004 $114.74 Eathorne, # 06 -053 Page 18 47. None of the generic receipt stubs submitted by Eathorne could be documented as expenses actually incurred for any conference - related purpose. a. Eathorne used these receipts to justify retaining entire advance expense payments. b. Of the approximate (30) thirty events attended by Eathorne when he received an advance, he returned funds to the WWMA on only one occasion. THE FOLLOWING FINDINGS RELATE TO EATHORNE'S EXPENSES IN RELATION TO ALOM EVENTS 48. Eathorne attended Spring and Fall conferences held by the ALOM annually between 2003 and 2006. a. Eathorne did not attend the 2002 conferences due to the WWMA's ban on travel in 2002. b. Expenses for Eathorne's attendance were paid by the WWMA. 1. Expenses for Eathorne's wife were also paid by the WWMA. 2. The expenses for his wife were submitted to the WWMA by Eathorne. c. WWMA board members' attendance, particularly Eathorne's, has been questioned because ALOM events relate most to concerns of Allegheny County Municipalities. 1. Eathorne ignored concerns and attended the events. 49. The ALOM is an organization of borough(s), townships, cities, municipalities, municipal authorities and Allegheny County, formed to assist local elected and appointed officials in areas of communication and cooperation on mutual matters of area -wide concern. a. Officials participate through the league's board of directors, committees, municipal workshops, and county associations of borough(s) and townships. b. The ALOM was established in or about February 1963. 50. The WWMA is a member of the ALOM. Eathorne, # 06 -053 Page 19 51. The ALOM hosts Spring and Fall conferences annually. a. The events are held at the Seven Springs Resort. 52. Since 2003, the ALOM has hosted conferences on the following dates: a. 2003: April 3, 2003, to April 6, 2003 September 25, 2003, to September 28, 2003 b. 2004: April 1, 2004, to April 4, 2004 September 23, 2004, to September 26, 2004 c. 2005: April 7, 2005, to April 10, 2005 September 29, 2005, to October 2, 2005 d. 2006: April 6, 2006, to April 9, 2006 September 28, 2006, to October 1, 2006 53. Standard conference schedules from 2003 to 2006 included as follows: a. Registration on the first day from 2:30 p.m. to 6:30 p.m. b. League business meeting agenda 8:00 p.m. to 8:15 p.m. c. Program 8:15 p.m. to 9:00 p.m. d. The conference would conclude on the last day (a Sunday) with a concluding business meeting for directors at 9:00 a.m. 1. Eathorne was not a director. 54. Conference attendees were offered two different plans to select for lodging and meals. a. Plan A included the following: Thursday dinner and lodging, Friday and Saturday breakfasts, lunches, dinners, and lodging and Sunday breakfast. b. Plan B included the following: Friday dinner and lodging, Saturday breakfast, lunch, dinner, and lodging and Sunday breakfast. c. The two plans included the same amenities from 2003 through 2006. 55. Eathorne attended the 2003 ALOM Spring conference held at Seven Springs Resorts, Champion, PA. a. Eathorne's wife, Patricia, accompanied him. b. Other WWMA officials attending included Board Members John Nabuda and Pat Altman and Sewer Plant Manager Barry Riley. 56. Conference attendees were required to pay a registration fee. Eathorne, # 06 -053 Page 20 a. On March 18, 2003, the WWMA issued check no. 29846 in the amount of $720.00 to the ALOM in direct payment of Eathorne's and Riley's registration. b. No registration fees were required for spouses. 57. A pre- registration form for Eathorne was submitted to the ALOM by WWMA staff. a. The forms were completed based on information provided by Eathorne. b. The registration included Eathorne and his wife. c. Eathorne selected Plan A which included 3 nights lodging and all meals from Thursday evening through Sunday morning for his wife and himself. 58. The cost for Plan A for the Spring 2003 conference was as follows: Official /attendee: $570.00 Spouse $164.00 59. Eathorne received an advance of expenses on April 3, 2003, in the amount of $500.00. a. The advance was in the form of WWMA check no. 29968. 1. Eathorne signed the check as one of the authorized signators. 2. Assistant secretary /treasurer Balcerek also signed the check. 3. The advance was not approved by a vote of the WWMA board of directors. b. Check no. 29968 was deposited on April 3, 2003, to Eathorne's personal bank account at National City Bank. 60. Seven Springs Hotel invoice for account no. 855785 confirms Eathorne checked into the hotel on April 3, 2003, and was registered to Room #325. a. The invoice lists one additional person in the room. b. Eathorne is reflected as departing on April 6, 2003. 1. Checkout time was not noted. c. Total charges on the invoice were $734.00 and identified that Eathorne had purchased Plan A. 1. Plan A included lodging and all meals for both Eathorne and his wife. d. A balance of $660.00 remained at the time of checkout. 1. Eathorne paid the balance by debit from a National City Bank account in his name. 61. Eathorne submitted an ALOM certificate of attendance to the WWMA confirming his attendance at the conference. Eathorne, # 06 -053 Page 21 a. The certificate is signed by ALOM Executive Director David Mayernik. 62. Eathorne claimed expenses including his spouse's expenses on the form and a payment of $307.07 for additional expenses as follows: Lodging & meals $734.00 Mileage 118 @ 0.365 /mile $ 43.07 Tips $ 30.00 $807.07 Advance - $500.00 $307.07 63. Authority check #30117, dated May 6, 2003, was issued to Eathorne in the amount of $307.07, which was the difference between the expenses he claimed ($807.07) and the advance he received ($500.00). a. Authorizing signatures included Eathorne's as Treasurer and Assistant Secretary /Treasurer Barbara Balcerek. b. The extra payment was not approved by a vote of the board. 64. Eathorne utilized Authority funds to pay for his wife's attendance at the conference and participation in Plan A, which totaled $164.00. 65. Eathorne did not reimburse the Authority for his wife's participation in Plan A while attending the conference with him. a. Eathorne realized a private pecuniary gain of $164.00 when WWMA funds were used to pay spousal expenses. 66. Eathorne attended the ALOM 2003 Fall conference at Seven Springs from September 25, 2003, to September 28, 2003. a. Other WWMA attendees were Board Members Robert Pioth, James Nabuda, and Pat Altman, and Plant Operator Barry Riley. 1. Eathorne, Pioth, and Nabuda all were accompanied by their spouses. b. The conference itinerary included the following: 09/25/03: check -in /registration: 2:30 p.m. to 6:30 p.m. business meeting: 7:30 p.m. 09/28/03: business meeting: 9:00 a.m. check -out: 11:00 p.m. 67. Eathorne registered for Plan A for his spouse and himself. a. Plan A costs were: Attendee $570.00 Spouse: $164.00 b. Plan A included all meals for Eathorne and his spouse from Thursday evening to Sunday morning plus three nights lodging. Eathorne, # 06 -053 Page 22 c. Eathorne's registration form lists a check -in date of September25, 2003, and a departure date of September 28, 2003. d. The WWMA sent check no. 30736 to Seven Springs on September 11, 2003, as a direct room deposit for Eathorne and the other attendees. 1. The township also paid a $164.00 conference registration fee on Eathorne's behalf. 68. On September 23, 2003, the WWMA issued check no. 30806 in the amount of $800.00 to Eathorne as an advance of expenses for the Fall 2003 conference. a. Eathorne signed the check as one of the authorized signatories. b. The check was deposited to Eathorne's National City Bank account on September 24, 2003. 69. Seven Springs Hotel invoice no. 895977 confirms the following regarding Eathorne: 09/12/03: Deposit $ 75.00 09/25/03: Arrival Plan A $320.00 09/26/03 Plan A $208.00 09/27/03 Dining Room $ 15.75 09/27/03 Plan A $206.00 Balance $674.75 70. Eathorne's National City Bank account confirms a withdrawal in the amount of $674.75 on October 1, 2003, payable to Seven Springs Resort. 71. Eathorne submitted an expense report to the WWMA detailing the following expenses: Mileage: 90 @ .036 /mile $ 32.40 Tolls $ 1.80 Hotel including meals $674.75 $708.95 Less advance $800.00 Amount due to WWMA $ 91.05 72. The expenses claimed by Eathorne included his spouse's costs for Plan A and an additional meal as delineated below: Plan A: $164.00 Meal09/27/03: $ 15.75 $179.75 73. Robert Eathorne realized a private pecuniary gain when he claimed and received expenses for his spouse, extra meals, and when he failed to return excess expense funds to WWMA. $164.00 $ 15.75 $ 91.05 $270.75* Eathorne, # 06 -053 Page 23 *[sic]. [There is a five -cent discrepancy in the calculation, to the advantage of Respondent. Respondent receives the benefit of the indicated amount. Bartholomew v. State Ethics Commission, 795 A.2d 1073 (Pa. Cmwlth. 2002).] 74. Eathorne and other WWMA officials attended the 2004 ALOM Spring Conference at Seven Springs Resort. a. The conference was held from April 1, 2004, to April 4, 2004. b. In addition to Eathorne, Board Member Robert Pioth and Plant Manager Barry Riley attended. 75. The registration fees for Eathorne, Pioth, and Riley were pre -paid by way of Authority check #31616, dated March 23, 2004, in the amount of $1,080.00 ($360.00 x 3). 76. Eathorne and his wife were registered to attend the conference and participate in Plan "A." a. Plan "A" included meals and lodging from Thursday dinner through Sunday breakfast. b. The Plan costs for Eathorne, $576.00, and his wife, $172.00, totaling $748.00, were paid directly by the Authority. c. Authority check #31615, dated March 23, 2004, was issued to Seven Springs Resort in the amount of $1,900.00 ($576.00 x 3 + $172.00). 1. The Plan costs for Pioth and Riley were included in the payment. d. Eathorne co- authorized the check along with the Assistant Secretary /Treasurer. 77. Eathorne submitted an expense report in the amount of $39.30, which included the following: Mileage $ 37.50 (100 miles @ .375 cents /mile) Tolls $ 1.80 TOTAL $ 39.30 78. The cost of Eathorne's wife's attendance and participation in Plan A paid by the Authority through Eathorne's action was $172.00. 79. Seven Springs Resort Hotel invoice for Eathorne confirmed the following regarding his attendance at the 2004 ALOM Spring Conference. a. Check in: 04/03/04 Check out: 04/04/04 b. Charges: 04/01/04: $326.00 04/02/04: $212.00 04/04/04: $210.00 c. Credits: $748.00 (paid by WWMA) Eathorne, # 06 -053 Page 24 80. Eathorne did not attend the conference on either April 1, 2004, or April 2, 2004. a. The WWMA paid expenses on Eathorne's behalf for lodging and meals as follows: 04/01/04 04/02/04 09/23/04: 09/24/04: 09/25/04 09/26/04: $326.00 $212.00 $538.00 b. Eathorne realized a private pecuniary gain of $538.00 when the WWMA incurred costs for his non - attendance at the ALOM functions. 81. Eathorne attended the Fall 2004 ALOM Conference held at Seven Springs from September 23, 2004, to September 26, 2004. a. Conference itinerary included the following: 2:30 p.m. - 6:30 p.m. 7:30 p.m. 8:00 p.m. 9:00 a.m. to 3:00 p.m. 9:00 a.m. to 3:00 p.m. 9:00 a.m. check -in business meeting speaker programs programs concluding business meeting 82. The WWMA paid registration fees and room reservation fees for Eathorne, Barry Riley and Robert Pioth. a. Room reservation fees were $75.00 for each attendee. b. Conference fees were $360.00 for each attendee. 83. Eathorne was registered for Plan A for both him and his wife. a. Plan A costs: Attendee: $576.00 Spouse: $172.00 $748.00 b. Plan A included room costs for September 23, 2004, through September 25, 2004, and all meals from Thursday evening (September 23, 2004) through Sunday breakfast (September 26, 2004). 84. Eathorne requested and received an expense advance of $800.00. a. WWMA check no. 32488 was issued to Eathorne on September 21, 2004, in the amount of $800.00. 1. Check no. 32488 was deposited to Eathorne's personal bank account on September 21, 2004. 2. Eathorne signed check no. 32488 as one of the authorized signatures. 3. This payment was not approved by board vote. 85. Seven Springs Resort invoice, for the Fall 2004 conference, confirms the following regarding Eathorne's stay: Eathorne, # 06 -053 Page 25 a. Arrival: 09/23/04 Departure: 09/26/04 No. in party: 2 Rate: $249.33 b. Charges /credits: 09/17/04 Reservation $ 75.00 09/23/04 Thursday arrival $326.00 09/24/04 Plan A $212.00 09/25/04 Plan A $210.00 09/26/04 Balance due $673.00 86. The balance of $673.00 was paid by Eathorne at the time of checkout by use of his National City Bank debit card. 87. Eathorne submitted an expense report to the WWMA after the conference claiming the following expenses totaling $888.88. Tolls: $ 3.00 Mileage 90 mi. @ .345/mi $ 31.05 Hotel $673.00 09/23 Breakfast $ 40.00 09/23 Dinner $ 51.83 09/26 Dinner $ 60.00 Tips $ 30.00 $888.88 88. Eathorne claimed breakfast expenses on September 23, 2004, even though Seven Springs is less than one hour travel from his home and the conference did not begin until 7:30 p.m. on September 23, 2004. a. Eathorne submitted a generic receipt stub claiming a breakfast expense of $45.00.* 1. The generic receipt no. 953393 contains Eathorne's handwriting in the date and amount sections. 2. The receipt does not identify a restaurant where meals were allegedly purchased. *[Cf., Fact Finding 87. Respondent will receive the benefit of the lower amount, specifically, $40.00. Bartholomew, supra.] 89. Eathorne also claimed dinner on September 23, 2004, even though dinner for he and his wife was included as part of Plan A. a. The generic receipt no. 874797 submitted by Eathorne claimed an expense $51.83. b. The amount section, not in Eathorne's handwriting, was altered from $5.83 to $51.83. c. Receipt no. 874797 is identical in format manufacturer and in the same sequence as receipt no.'s 874795 and 874799 used by Eathorne to claim expenses for other conferences in other years. Eathorne, # 06 -053 Page 26 1 Receipt no. 874795 was used by Eathorne to claim an expense for the 2001 PMAA Conference. 2. Receipt no. 874799 was used by Eathorne to claim an expense at the 2004 PMAA Conference. 90. Eathorne claimed a dinner expense of $60.00 on September 26, 2004, the day the conference ended. a. No receipt was submitted. b. The dinner was claimed even though no conference events were scheduled on September 26, 2004. c. Turnpike receipts submitted by Eathorne confirm he exited the turnpike at 12:08 p.m. on September 26, 2004. 1. Eathorne was less than fifteen minutes from his residence upon exiting the turnpike at 12:08 p.m. 91. Eathorne also claimed $30.00 in tips while at the conference. a. The maximum limit per the WWMA travel policy for undocumented expenses is $25.00. 92. Eathorne received a private pecuniary gain of at least $335.83* while attending the 2004 Fall ALOM conference. a. Spousal package $174.00* b. Extra meals 09/23/04 $ 45.00* 09/23/04 $ 51.83 09/26/04 $ 60.00 c. Tips $ 5.00 $335.83* *[sic]. [Cf., Fact Findings 83 a, 87, and 88 a. The cost of the spousal package was $172.00. The cost of the September 23, 2004, breakfast was $40.00. Bartholomew, supra.] 93. Eathorne and other WWMA officials attended the 2005 ALOM Joint Spring Conference. a. The conference was held at Seven Springs Resort from April 7, 2005, to April 10, 2005. b. Package costs for attending were as follows: Plan A Plan B - $580.00 /member, $174.00 guest - $417.00 /member, $125.00 guest 94. Registration forms were submitted for the WWMA Board Members and Plant Manager as follows: Name Plan Staff Amount Guest Amount Robert /Pat Eathorne Plan A $ 580.00 $ 174.00 M. Pat Altman Plan A $ 580.00 -- John /Pat Nabuda Plan A $ 580.00 $ 174.00 Sam /Denise Testa Plan B $ 417.00 $ 125.00 Kevin /Debi Fisher PIanA/Plan B $ 580.00 $ 125.00 Check No. Check Date Amount Payable To 33070 01/20/05 $ 400.00 Eathorne, Fisher, Pioth, Hall 33072 01/25/05 $ 100.00 Falta 33148 02/10/05 $ 100.00 Testa Name Plan Staff Amount Guest Amount Edward Falta Plan A $ 580.00 -- Dan /Mary Hall Plan A $ 580.00 $ 174.00 Robert /Carol Pioth Plan A $ 580.00 $ 174.00 Check No. Check Date Amount Payable To 33072 01/20/05 $1,520.00 ALOM 33077 01/25/05 $ 380.00 ALOM Eathorne, # 06 -053 Page 27 a. Board Members Altman and Nabuda cancelled. b. Additional registration forms were submitted for board members as follows: 95. The WWMA prepaid $380.00 per official registration fees: a. Eathorne co- signed these checks. 96. The WWMA paid the $100.00 per room deposit fees to Seven Springs Resort: a. Eathorne co- signed all three checks with the Assistant Secretary /Treasurer. b. The registration forms indicated that the wives of Eathorne, Pioth, Hall, and Testa were attending the conference. 97. Eathorne received an advance of $800.00 by way of Authority check #33437 on April 7, 2005. a. Eathorne signed the check authorizing payments. b. The check was deposited to Eathorne's account at National City Bank. 98. Seven Springs Hotel invoice for Eathorne confirmed the following regarding Eathorne's attendance at the 2005 Spring ALOM Conference. a. Check in: 04/07/05 Check out: 04/10/05 b. Charges (Eathorne): 04/07/05 Pkg.: 04/08/05 Pkg.: 04/09/05 Pkg.: $ 230.00 $ 187.00 $ 163.00 $ 580.00 Eathorne, # 06 -053 Page 28 Charges (Spouse): 04/07/05 Pkg.: 04/08/05 Pkg.: 04/09/05 Pkg.: c. Payments /credits: 01/20/05 deposit by WWMA $ 100.00 04/10/05 payments $ 654.00 d. Included in the costs was $174.00 for Patricia Eathorne's expenses as part of Plan A. 99. Itinerary for the 2005 Spring conference included the following: April 7, 2005: 8:00 p.m. League Business Meeting 8:15 p.m. Speaker April 8, 2005: 9:00 a.m. to 12:00 p.m. Sessions 1:15 p.m. to 5:00 p.m. Sessions April 9, 2005: 9:00 a.m. to 12:00 p.m. Sessions 1:15 p.m. to 4:00 p.m. Sessions April 10, 2005: 9:00 a.m. Concluding Business Meeting 100. Eathorne submitted an expense report in the amount of $918.92* which detailed the following expenses: Lodging: $ 674.00 Mileage: $ 36.45 (90 miles @ .405 cents /mile) Tolls: $ 3.00 Tips: $ 50.00 Meals: $ 155.44 $ 918.92* *[sic]. [There is a three -cent discrepancy in the calculation, which does not affect the calculation of the private pecuniary benefit in Fact Finding 109.] 101. Eathorne claimed additional meal expenses even though all meals related to the conference were pre -paid by the WWMA for both Eathorne and his wife through Plan A. 102. Eathorne's expense report detailed additional meal costs and tips as follows: a. 04/07/05: b. 04/10/05: $ 101.00 $ 24.00 $ 49.00 $ 174.00 Breakfast $ 13.47 Lunch $ 20.00 Dinner $ 65.00 Lunch $ 22.00 Dinner $ 35.00 c. 04/07/05 to 04/10/05: Tips $ 50.00 Date Generic Receipt # Amount 04/07/05 288409 $ 65.00 04/07/05 260323 $ 20.00 04/10/05 824624 $ 35.00 04/10/05 767329 $ 22.60* Undated 955635 $ 13.47 Eathorne, # 06 -053 Page 29 103. Eathorne submitted generic receipts as proof of his expenditures for additional meal expenses totaling $155.47. a. *[Cf., Fact Finding 102a. The lower amount, $22.00, is reflected in the calculation of the private pecuniary benefit in Fact Finding 109.] b. Receipt no. 824624 is identical in format, manufacturer, and from the same book of receipts as Receipt no. 824620, 824633, and 824647 used by Eathorne to justify expenses at other conferences. Stub No. Conference 824620 2004 WEFTEC 824633 2001 Fall ALOM 824647 2001 WEFTEC c. All of the generic receipts submitted by Eathorne contained dates and amounts in his handwriting. 104. Turnpike toll receipts submitted by Eathorne confirm travel on the turnpike on April 7, 2005, and April 10, 2005. a. April 7, 2005, Exit Donegal 11:00 a.m. b. April 10, 2005, Exit Irwin 11:05 a.m. c. Travel time from Eathorne's home to Seven Springs is approximately one hour. 1. Eathorne's home is less than one half hour from the Irwin exit of the turnpike. 105. Eathorne claimed additional meal expenses even though all meals were included as part of his participation in Plan A at the conference. 106. The conference did not begin until 8:00 p.m. on April 7, 2005, but Eathorne claimed breakfast, lunch, and dinner expenses for April 7, 2005, totaling $98.47. a. Dinner was provided on April 7, 2005, as a result of Eathorne selecting Plan A for both his wife and himself. 107. Eathorne claimed both lunch and dinner expenses on April 10, 2005, totaling $57.00 even though the conference concluded prior to 9:00 a.m. on that date. a. Toll records confirm Eathorne exited the Pennsylvania Turnpike at Irwin at 11:05 a.m. on April 10, 2005. b. Eathorne was less than 15 minutes from his residence upon exiting the turnpike. Name Plan Staff Amount Guest Amount Robert /Pat Eathorne Plan A $ 580.00 $ 174.00 John /Jean Thornton Plan A $ 580.00 $ 174.00 Robert Pioth Plan A $ 580.00 -- Kevin Fisher/ Debbie Carnello Plan A $ 580.00 $ 174.00 TOTALS $2,320.00 $ 522.00 Eathorne, # 06 -053 Page 30 108. Eathorne claimed $50.00 of un- documented expenses in the form of tips. a. The WWMA travel policy permits only $25.00 of such expenses per trip. 109. Eathorne used his public position to obtain additional expense reimbursements not related to his attendance at the conference and also used his position to have the WWMA pay for expenses related to his spouse's travel as follows: Spouse expenses: $ 174.00 Meals $ 155.47 Excess tips $ 25.00 TOTAL $ 354.47 110. Eathorne and other WWMA officials attended the 2005 ALOM Fall Conference held at Seven Springs from September 29, 2005, to October 2, 2005. 111. Conference itinerary and costs included the following: a. Costs: Plan A: Attendee $ 580.00 Guest $ 174.00 Plan A included all meals beginning with dinner on September 29, 2005, through breakfast on October 2, 2005, and three nights lodging for the attendee and guest. b. Itinerary: 09/29/05 Check -in begins 2:30 p.m. Business meeting 8:00 p.m. Speaker 8:10 p.m. 09/30/05 Programs 9:00 a.m. to 12:00 p.m. and 1:00 p.m. to 3:00 p.m. 10/01/05 Programs 9:00 a.m. to 12:00 p.m. and 1:00 p.m. to 3:00 p.m. 10/02/05 Concluding business meeting 9:00 a.m. 112. Registration forms were submitted by the WWMA for Board Members and the Plant Manager as follows: 113. The WWMA prepaid the conference registration of $175.00 per official. a. Check #33918, dated July 15, 2005, in the amount of $700.00 was issued to the 2005 Joint Fall Conference Committee. Eathorne, # 06 -053 Page 31 b. Eathorne co- signed the check along with the Assistant Secretary/Treasurer. 114. The WWMA prepaid a room deposit of $100.00 per room for Eathorne and the other three Authority representatives. a. Check #33917, dated July 15, 2005, in the amount of $400.00 was issued to Seven Springs Resort. b. The registration forms indicate that the wives of Eathorne, John Thornton, and Kevin Fisher attended. 1. The registrants and their wives were all signed up for Plan "A." c. Eathorne co- signed the check along with the Assistant Secretary/Treasurer. 115. Eathorne received an advance on his expenses in the amount of $800.00. a. Check #34318, dated September 27, 2005, was issued to Eathorne. b. Eathorne signed a receipt stating that he had received the check. c. Eathorne deposited the check to his National City Bank account. 116. The Seven Springs Resort Hotel bill for Eathorne confirms the following: a. Arrival: 09/09/05 [sic] Departure: 10/02/05 b. No. in party 3 09/29/05: Meal tickets $ 190.00 Bavarian Lounge $ 25.50 Pkg. $ 230.00 09/30/05 Pkg. $ 187.00 c. Charges: 09/29/05 $ 230.00 09/30/05 $ 187.00 10/01/05 $ 163.00 $ 580.00 Plan A for Eathorne 09/29/05 $ 101.00 09/30/05 $ 24.49 10/01/05 $ 49.00 $ 174.00* Plan A for P. Eathorne *[There is a forty -nine cent discrepancy in the calculation, but the accurate charge for the plan for Eathorne's spouse was $174.00. See, Fact Finding 111 a.] d. Other charges: Meal tickets $ 190.00 Bavarian Lounge $ 25.50 e. Total charges c & d $ 969.50 f. Deposit 07/15/05 $ 100.00 Eathorne, # 06 -053 Page 32 g. Balance $ 869.50 117. Eathorne paid the $869.50 balance owed on October 2, 2005, at checkout. a. Eathorne used his National City Bank debit card. 118. The Bavarian Lounge charges incurred by Eathorne included drink purchases made on September 29, 2005, at 2:30 p.m. prior to the start of the conference. a. The drinks included three mixed drinks, two beers, and a soda. 119. Extra meal charges related to a third person in Eathorne's party. a. Eathorne's grandchildren would accompany Eathorne and his wife on some trips. 120. Eathorne submitted an expense report to WWMA claiming expenses for the Fall 2005 ALOM Conference as follows: Hotel and meals $ 869.50 Tolls $ 3.00 Mileage 90 mi @ .485 $ 43.65 Less Advance $ 800.00 Balance Due $ 116.15 121. The WWMA issued check no. 33569 to Eathorne, which included the $116.15 additional expense claims. 122. Turnpike toll records submitted by Eathorne confirm his approximate arrival to the Seven Springs area and return to his home in Irwin. 09/29/05 Exit Donegal 1:03 p.m. 10/02/05 Exit Irwin 11:05 a.m. 123. Eathorne realized a private pecuniary gain when he charged expenses for his spouse, a third party, and drinks not related to his attendance at the conference. Spouse Plan A $ 174.00 Extra Meals $ 190.00 Lounge $ 25.50 $ 389.50 124. Records of the WWMA and the ALOM confirm that Eathorne registered and attended the 2006 ALOM Spring Conference held at Seven Springs from April 6, 2006, to April 9, 2006. 125. A notification from ALOM regarding the Spring 2006 Conference detailed the costs for registration and the lodging /meal packages, as follows: a. The registration fee was $400.00 per municipal official. b. The cost of the lodging /meal packages clearly defines the additional costs for a spouse or guest. Plan A - $580.00 per first person; $174.00 per second person Plan B - $417.00 per first person; $125.00 per second person Eathorne, # 06 -053 Page 33 1. The package includes tax on food, lodging, and gratuities for food service. c. A $100.00 advance deposit for each registered delegate requiring lodging was to be issued to Seven Springs Mountain Resort. 126. Authority check #35158, dated March 21, 2006, was issued to the Allegheny League of Municipalities in the amount of $1,200.00. a. The payment was for the registration fees of Eathorne, Kevin Fisher, and Robert Pioth. b. The registration form was completed by the Assistant Secretary /Treasurer. 127. Authority check #35157, dated March 21, 2006, in the amount of $300.00, was issued to Seven Springs Resort representing the deposits for three rooms, at $100.00 per room. a. Eathorne's wife was listed on the registration as attending the conference. b. All participants registered for Plan "A." c. Eathorne co- signed the check along with the Assistant Secretary/Treasurer. 128. Eathorne received check #35239 in the amount of $1,000.00 on April 6, 2006, from the WWMA as an advance for attending the conference. a. Eathorne signed the check along with the Assistant Secretary /Treasurer. 1 Eathorne was the only board member to approve the payment. b. Eathorne signed an Authority form indicating receipt of the check. c. Eathorne deposited check #35239 in his National City Bank account. 129. The Authority prepaid the room registration deposit for Eathorne in the amount of $100.00. a. A WWMA check was issued to ALOM on March 29, 2006, in the amount of $100.00. 130. Itinerary for the conference included the following: April 6, 2006: 6:00 p.m. Registration 8:00 p.m. Business Meeting 8:15 p.m. Speaker April 7, 2006: 9:00 a.m. to 12:00 p.m. Programs 1:15 p.m. to 4:30 p.m. Programs April 8, 2006: 9:00 a.m. to 12:00 p.m. Programs 1:15 p.m. to 3:30 p.m. Programs April 9, 2006: Date Receipt No. Amount 04/06/06 373782 $ 15.00 04/06/06 556617 $ 26.00 04/09/06 281329 $ 126.00 Eathorne, # 06 -053 Page 34 9:00 a.m. Business Meeting 131. Seven Springs Hotel invoice confirms Eathorne checked in on April 6, 2006, and checked out on April 9, 2006. a. There were three people assigned to his room. b. Expenses charged to the room included the costs of Plan Afor Eathorne and his wife totaling $754.00 plus a lounge charge of $9.25. 1. The bill noted a deposit of $100.00 and a balance due of $663.25 at check out. c. Eathorne paid the balance of $663.25 on April 9, 2006, using his National City Bank debit card. 132. On or about April 12, 2006, Eathorne submitted an expense report claiming expenditures for attending the conference: Mileage: 150 mi @ .445 /mile $ 66.75 Tolls $ 3.00 April 6, 2006: Breakfast $ 15.00 Lunch $ 26.00 Hotel Conference $ 663.25 April 9, 2006: Dinner $ 126.00 Tips $ 50.00 $ 950.00 133. The actual mileage to Seven Springs Resort from Eathorne's home is 39 miles each way (78 miles round trip). a. Eathorne claimed 72 extra miles at a cost to the WWMA of $32.04. b. Eathorne overcharged the WWMA for mileage by $32.04. 134. Total expenses for Eathorne's attendance at the conference were $1,050.00. Reservation fee $ 100.00 Claims by Eathorne $ 950.00 $1,150.00 [sicl 135. Eathorne submitted generic receipts as justification for meal expenses. a. The three generic invoices are all in Eathorne's handwriting including date and dollar amount. b. Generic receipts submitted by Eathorne: c. None of the receipts identify a restaurant or place of purchase. Eathorne, # 06 -053 Page 35 136. Turnpike toll receipts submitted by Eathorne confirm his arrival to the Seven Springs area and return to Irwin as follows: 04/06/06 Exit Donegal at 10:54 a.m. 04/09/06 Exit Irwin at 12:43 p.m. 137. Eathorne claimed breakfast and lunch expenses on April 6, 2006, even though the conference did not begin until 8:00 p.m. and he lives less than one hour from the conference site. a. Eathorne claimed a $126.00 dinner expense on a generic receipt on April 9, 2006, despite returning home at approximately 1:00 p.m. 138. Eathorne also claimed $50.00 in tips even though the maximum un- receipted expense permitted by WWMA policy is $25.00. 139. Eathorne received a private pecuniary gain of $407.29 when claiming conference expenses for his wife, expenses not related to the conference, and excess tips totaling: Plan A Wife $ 174.00 Lounge $ 9.25 Breakfast $ 15.00 Lunch $ 26.00 Dinner $ 126.00 Excess Tips $ 25.00 Mileage $ 32.04 $ 407.29 140. Eathorne attended the 2006 ALOM Fall Conference held at Seven Springs from September 28, 2006, through October 1, 2006. a. A registration form submitted to ALOM for Eathorne reflects his attendance at the conference from September 28, 2006, to October 1, 2006, and that two people were in his party. b. Eathorne was registered for Plan A. c. Plan A included Thursday dinner and lodging; Friday and Saturday breakfast, lunch, dinner, and lodging; and Sunday breakfast. 1. The cost was $580.00 per official and $174.00 per spouse /second person. d. Other WWMA officials in attendance included Robert Pioth and Kevin Fisher. 141. Two Authority checks were issued to Seven Springs Resort, representing the deposit of $100.00 per room, totaling $300.00. a. Check no. 35250, dated 07/27/06, in the amount of $200.00 was issued for Eathorne and Robert Pioth. b. Check no. 35397, dated 08/24/06, in the amount of $100.00 was issued for Kevin Fisher. Eathorne, # 06 -053 Page 36 c. Eathorne co- signed the checks along with the Assistant Secretary/Treasurer. d. Written confirmation of the room reservations in the names of Eathorne, Robert Pioth, and Kevin Fisher document the check -in and check -out times as 5:00 p.m. on September 28, 2006, and 12:00 Noon on October 1, 2006. 142. Two Authority checks were issued to ALOM, representing the registration fee of $175.00 per person, totaling $525.00. a. Check no. 35257, dated July 27, 2006, in the amount of $350.00, represented fees for Eathorne and Robert Pioth. b. Check no. 35398, dated August 24, 2006, in the amount of $175.00 represented the fee for Kevin Fisher. c. Eathorne co- signed the checks along with the Assistant Secretary/Treasurer. 143. Seven Springs Resort Hotel invoice confirms Eathorne checking in on September 28, 2006, and checking out on October 1, 2006. a. Two other individuals are listed as being in the room. b. Charges to Eathorne's room included the following: Package costs for Plan A $ 580.00 Package costs for Plan A (2 person) $ 174.00 c. Other charges included: 09/28/06 Meal tickets 09/28/06 Bavarian Lounge $ 194.00 $ 53.00 d. The Bavarian Lounge charges included $17.00 in alcohol purchases and $27.49 in food, tax, and an $8.51 tip. e. A balance of $901.00 remained at checkout. f. Eathorne paid the Seven Springs Resort bill of $901.00 by debit from his National City Bank account. 144. Eathorne received WWMA check #35550 in the amount of $800.00 on September 5, 2006, as an advance of expenses. a. The check was deposited to Eathorne's National City Bank account. 145. Eathorne did not submit an expense report to the WWMA to document expenses related to the $800.00 advance of expenses. 146. Eathorne received a private pecuniary gain of $217.00 when he received expense reimbursement in excess of actual expenses incurred for his attendance at the Fall 2006 ALOM Conference. Advance $800.00 Documented $583.00 Due to WWMA $217.00 147. Between April 2003 and September 2006 the WWMA incurred total expenses for Eathorne, # 06 -053 Page 37 Eathorne's travels to ALOM events of $9,979.30. 148. Eathorne realized a private pecuniary gain as result of his use of office to approve expenses for his wife and excess expenses for himself for ALOM events totaling $2,676.84.* *[Respondent is deemed to have admitted the indicated amount. However, we determine that Respondent's total private pecuniary gain as to ALOM events was $2,672.84. See, Discussion, infra.] THE FOLLOWING FINDINGS RELATE TO EATHORNE'S RECEIPT OF EXPENSE MONIES FOR PMAA EVENTS 149. The Pennsylvania Municipal Authorities Association "PMAA" is the recognized association for municipal authorities in the Commonwealth of Pennsylvania. a. The PMAA, formed in 1941, was established to provide its members with a medium for exchange of ideas on municipal problems, to present a united and common front in advocating favorable legislation, and opposing detrimental legislation, and to otherwise promote the general welfare of municipal authorities of the Commonwealth of Pennsylvania." 150. The WWMA is a member of the PMAA. a. The PMAA is split into regions. b. The WWMA is located in Region 9. 151. The PMAA holds various events for the benefit of member associations including the following: a. Annual Conference and Trade Show b. Legislative Day Conferences c. One day seminars d. Dinner meetings for each region. 152. Robert Eathorne, as a WWMA member, has regularly attended the various events hosted by the PMAA. a. Eathorne's wife has accompanied him at all events he attended. b. Eathorne approved all payments issued to him for travel - related expenses, including those of his spouse. 1. WWMA travel policy does not permit spousal expenses. 153. The PMAA holds an Annual Conference and Trade Show in or around September or October of each year. a. Eathorne has regularly attended the annual conferences since at least 2001. b. Eathorne did not attend the 2002 conference due to a WWMA ban on travel at that time. Eathorne, # 06 -053 Page 38 c. Eathorne's wife has accompanied him to all of these PMAA functions at WWMA expense, even though WWMA travel policies do not permit such expenses. 154. The 2003 PMAA Annual Conference was held in Hershey, Pennsylvania, from Sunday, August 24, 2003, to Wednesday, August 27, 2003. a. The conference location was at the Hershey Lodge and Convention Center. 155. Conference agenda included the following: 08/24/03: 08/25/03: Noon to 5:00 p.m. - Registration 2:30 p.m. to 5:00 p.m. - Trade Show 8:00 a.m. to 4:00 p.m. - Registration 8:00 a.m. - Opening ceremonies 10:00 a.m. to Noon - Trade Show Noon to 1:30 p.m. - Professional luncheon seminars 2:30 p.m. to 4:00 p.m. - Educational tracks 4:00 p.m. to 6:00 p.m. - Exhibitor reception 7:00 p.m. to 11:00 p.m. - Outdoor barbeque 08/26/03: 7:30 a.m. to 9:30 a.m. - Complimentary breakfast 9:30 a.m. to 11:00 a.m. - Educational tracks 11:00 a.m. to 12:30 p.m. - Educational tracks 12:30 p.m. to 2:00 p.m. - Lunch 2:00 p.m. to 3:30 p.m. - Educational tracks 5:30 p.m. to 6:30 p.m. - Banquet reception 6:40 p.m. - Annual awards banquet 08/27/03 8:30 a.m. - Family breakfast 156. A spouse /guest program was also included as part of the conference. a. 08/25/03 8:00 a.m. - Complimentary breakfast 11:00 a.m. to 3:00 p.m. - Felicita Resort Garden Tour b. 08/26/03 7:30 a.m. - Complimentary breakfast 11:00 a.m. - West Hanover Winery Presentation 157. The WWMA paid a registration fee of $195.00 each for Eathorne and other WWMA officials to attend. a. WWMA check #30346 was issued on June 19, 2003, in the amount of $1,710.00 which included Eathorne's registration. 158. In addition to the cost of registration, fees were charged for various activities that were offered over the duration of the conference, as noted below: Sunday, August 24 Hershey Park Admission and Picnic: Hershey Park Admission only: Monday, August 25 Opening Ceremonies Breakfast Board Member's Luncheon Manager's Luncheon Adult, each $33.50 Adult, each $21.25 $ 0.00 $23.00 per person $23.00 per person Eathorne, # 06 -053 Page 39 Engineer's Luncheon Solicitor's Luncheon Financial Officer's Luncheon Outdoor Barbeque with Entertainment Monday Spouse and Guest Program Felicita Garden Tour and Luncheon Tuesday, August 26 Exhibit Area Breakfast Registered Banquet Ticket Non - Registered Banquet Ticket Wednesday, August 27 PMAA Family Breakfast a. Arrival: 08/24/03 Departure: 08/27/03 No. in party: 2 Rate: $165.00 /night b. Charges: 08/24/03 $ 179.85 room & tax 08/28/03 $ 179.85 room & tax 08/26/03 $ 179.85 room & tax $ 13.00 Lounge $ 552.55 $23.00 per person $23.00 per person $23.00 per person $49.00 per person $45.00 per person $ 0.00 $45.00 per person $47.00 per person $18.00 per person 159. Conference registration data for Eathorne confirms that Eathorne was accompanied by his wife, Patricia Eathorne, and that they registered for the Monday Spouse /Guest Program and the banquet. a. Costs were $45.00 for the Monday program and $90.00 (2 @ $45.00) for the banquet. 160. Costs for the spouse program and banquet were included as part of WWMA check #30346. 161. Eathorne, as a WWMA Board Member, requested and received an advance of expenses to attend the 2003 PMAA Conference. a. Authority check #301616 in the amount of $1,500.00 was issued to Eathorne on August 19, 2003. 1. The check was deposited to Eathorne's account at National City Bank on August 19, 2003. 162. Hershey Lodge and Convention Center Guest Folio for Eathorne confirms the following. c. Upon checkout on August 27, 2003, Eathorne paid the balance of $552.55 using his National City Bank debit card. 163. Eathorne submitted an expense report to the WWMA claiming total expenses of $1,506.10* which included the following: Mileage: * *430 mi @ .36 /mile$ 154.80 Date Stub No. Amount Eathorne's Reference 08/24 145026 $ 25.30 Lunch 08/24 204794 $ 107.00 Dinner 08/25 285932 $ 25.50 Breakfast 08/25 128668 $ 30.30 Lunch 08/26 128694 $ 32.15 Lunch 08/27 205245 $ 180.00 Dinner TOTAL $ 400.25 Eathorne, # 06 -053 Page 40 08/24/03: Lunch $ 25.30 Dinner $ 107.00 08/25/03: Breakfast $ 25.50 Lunch $ 30.30 Dinner $ 305.18 08/26/03: Lunch $ 23.00 08/27/03: Breakfast $ 26.22 Lunch $ 32.15 Dinner $ 180.00 Lodging $ 552.25 Tips $ 30.00 Tolls $ 14.10 $1,506.10 *[sic]. [There is a thirty -cent discrepancy in the calculation, which does not impact the calculation of the total private pecuniary benefit for PMAA events.] * *The actual round trip mileage from Eathorne's home to the convention center is 386 miles. 164. Eathorne included with the expense report three receipts and six generic receipt stubs in support of his expense claims. 165. Actual receipts submitted by Eathorne included the following: a. Receipts: 08/27 Lebbie Lebkickher's - 2 guests $ 23.22 $ 3.00 tip $ 26.22 2 breakfasts @ $10.95 each $1.32 tax 08/25 Event Lunch (11:55 a.m.) $ 23.00 $ -- $ 23.00 08/25 Union Canal House (9:07 p.m.) $206.67* $ 44.51 tip $305.18 $306.89 $ 47.51 $354.40 *[sic]. [This appears to be a typographical error, intended to have been $260.67. Cf., Fact Finding 163. In any event, a $54.00 difference in this expense would not impact the final calculation of the private pecuniary benefit from PMAA events.] 166. Eathorne submitted 6 generic receipts totaling $400.25 as follows: a. Generic Receipts Eathorne, # 06 -053 Page 41 b. The receipt stubs are all made out in Eathorne's handwriting. c. None of the generic receipts submitted by Eathorne identify the restaurant. d. Receipt no. 204794 is identical in format and manufacturer and part of the sequence as receipt no. 204776 used by WWMA board member Robert Zentner in 2002 for attending a WEF Conference. e. Receipt no.'s 128668 and 128694 are identical in format and manufacturer and part of the same sequence but were used for meals on different dates. 167. Eathorne's expenses included turnpike toll receipts totaling $14.10 as follows: Day Time Plaza 236 (08/24/03) 4:14 718 239 (08/27/03) 2:46 1907 a. Eathorne exited the turnpike at Irwin /Greensburg at 2:45 p.m. on August 27, 2003. 1. The turnpike exit is 2.25 miles, approximately a 7 (seven) minute drive to his residence. 168. Eathorne claimed a reimbursement of $180.00 for dinner on August 27, 2003, through the submission of a generic receipt (No. 205425) even though he returned to his home prior to 3:00 p.m. on August 27, 2003. a. Eathorne did not identify where he claimed the dinner was purchased. 169. Eathorne claimed reimbursement for spousal expenses for the entire time of the conference including meals and spousal entertainment programs. a. Lodging did not require additional expenses for the second person in the room. 170. Eathorne claimed and received reimbursement for spousal expenses as follows: a. 08/25/03 Felicita Garden Tour $ 45.00 08/26/03 Banquet $ 45.00 08/27/03 Breakfast $ 13.11 $ 103.11 171. With the exception of lunch on August 25, 2003, Eathorne and his wife ate all of their meals together. 172. Based on half of the remaining meal expenses, Eathorne claimed and received reimbursement for $352.72 in meal expenses related to his spouse's travel. a. This amount is calculated dividing the balance of meal expenses by 2 ($705.43 _ 2 = $352.72). 173. Eathorne used the authority of his public position for private pecuniary gain by claiming expense for his spouse's travel and when he claimed and received reimbursement for expenses after the conclusion of the conference. a. Spousal expenses: Eathorne, # 06 -053 Page 42 b. Meal after conference $ 180.00 $ 635.83 174. The 2004 PMAA Annual Conference was held at the Westin Hotel, Pittsburgh, PA, from Sunday, August 22, 2004, until Wednesday, August 25, 2004. 175. Eathorne and other WWMA officials including John Thornton, Robert Zentner and Barry Riley were registered to attend. a. Spouses, including Eathorne's wife, Patricia, also were registered to attend. b. The WWMA issued check #32061 on June 30, 2004, in the amount of $1,056.00 to cover registration fees. 1. This amount included a $46.00 per person fee to attend the banquet. 2. Banquet charges for Eathorne's wife were included. 176. Conference schedule and itinerary included the following: 08/22/04: Noon to 5:00 p.m. - Registration 8:00 p.m. to 10:30 p.m. - PMAA Welcome Reception 08/23/04: 8:00 a.m. to 4:00 p.m. - Registration 8:00 a.m. - Complimentary Breakfast 8:30 a.m. - Opening Ceremonies 10:30 a.m. - 12:30 p.m. - Trade Show 12:30 p.m. - 2:00 p.m. - Professional Luncheon 2:30 p.m. - 4:00 p.m. - Educational Tracks 4:00 p.m. - 6:00 p.m. - Exhibitor & Delegate Reception 6:45 p.m. - Carnegie Science Center 08/24/04: 7:30 a.m. to 9:30 a.m. - Complimentary Breakfast 9:30 a.m. to 11:00 a.m. - Educational Tracks 11:00 a.m. to 12:30 p.m. - Educational Tracks 12:00 p.m. to 2:00 p.m. - Trade Show 12:00 p.m. to 2:00 p.m. - Complimentary box lunch with Exhibitors 2:00 p.m. to 3:30 p.m. - Open Authority Clinic 5:30 p.m. to 6:30 p.m. - Banquet Reception 6:45 p.m. - Annual Awards Banquet 08/25/04: 8:30 a.m. - Family Breakfast 177. The conference also included a spousal /guest program as follows: a. 08/23/04: Felicita $ 45.00 Banquet $ 45.00 Breakfast $ 13.11 Other meals $ 352.72 Eathorne, # 06 -053 Page 43 8:00 a.m. - Complimentary Breakfast 9:45 a.m. - Trolley Tour & Luncheon b. 08/24/04: 7:30 a.m. - Complimentary Breakfast 10:00 a.m. - Program Noon to 2:00 p.m. - Complimentary Box Lunch c. Eathorne's wife was not registered to participate in either program. 178. Eathorne requested and received an advance of expenses prior to the 2004 PMAA conference. a. WWMA check #32342 in the amount of $1,200.00 was issued to Eathorne on August 19, 2004. b. The check was deposited to Eathorne's account at National City Bank on August 20, 2004. 179. Eathorne submitted an expense report dated August 26, 2004, to WWMA, claiming conference expenses totaling $1,319.55 and seeking reimbursement of additional $119.55 in expenses. a. A WWMA check in an amount of $119.55 was issued to Eathorne. 180. Eathorne included the following on the expense report submitted on August 26, 2004: 08/22/04 Mileage 80 mi @ $.345 /mile $ 27.60 Breakfast $ 15.83 Dinner $ 150.00 08/23/04 Breakfast $ 48.00 Lunch $ 52.00 Dinner $ 150.00 Hotel $ 826.12 Tips $ 50.00 $1,319.55 181. Eathorne submitted, with the expense reports, generic receipt stubs and a hotel registration form. a. The hotel registration form was from a Holiday Inn and contained Eathorne's name. 1. No address was indicated on the form. 2. No room rate was listed. 3. Two guests were identified. 4. No room number was identified but 2132 was handwritten in the section identified for the room. 1. No Holiday Inns in the Pittsburgh area have a room number 2132. Date Stub No. Amount Expense 08/22/04 874799 $ 15.83 Breakfast 08/22/04 450173 $ 150.00 Dinner 08/23/04 291853 $ 48.00 Breakfast 08/23/04 040841 $ 52.00 Lunch 08/23/04 849576 $ 150.00 Dinner Eathorne, # 06 -053 Page 44 5. "$826.12 pd." was written, in Eathorne's handwriting, in a blank section of the form. b. Generic stubs listed below did not identify where meals were purchased. 182. All of the generic receipts were made out in Eathorne's handwriting. 183. Generic receipt stubs numbered 874799 and 450173 are identical to receipt stubs generated by Eathorne as documentation of expenses for attendance at other conferences. a. Receipt no. 450173 is identical in format and manufacturer and two numbers off in the sequence as Receipt no. 450171 submitted by Eathorne when attending the 2001 fall PMAA Conference. b. Receipt no. 874799 is identical to and part of the same sequence as receipt No.'s 874795 and 874977. 1. Receipt no. 874795 was used by Eathorne for the fall 2001 PMAA event. 2. Receipt no. 874797 was used by Eathorne in September 2004. 184. Eathorne claimed identical amounts of $150.00 for dinner on both August 22, 2004, and August 23, 2004. 185. Eathorne claimed a breakfast of $15.83 on Sunday, August 22, 2004, even though conference registration did not begin until 2:00 p.m. [sic]. [See, Fact Finding 176.] a. Eathorne resides approximately one hour from the conference site. 186. Eathorne claimed a breakfast of $48.00 on Monday, August 23, 2004. a. Breakfast was provided and part of the $195.00 registration fee. 187. Eathorne claimed a dinner meal of $150.00 on generic receipt #849576 on August 23, 2004, the night of the banquet. a. Eathorne and his wife were both registered to attend the banquet. 1. The WWMA paid $46.00 each for Eathorne and his wife to attend the banquet. 188. HDR Engineering provides engineering services to the WWMA. a. HDR provided such services in 2004. b. Mark Poole, P.E., has been HDR's main representative to the WWMA. Eathorne, # 06 -053 Page 45 189. Poole attended the 2004 PMAA Conference held in Pittsburgh. a. On August 23, 2004, Poole paid for dinner and drinks for Eathorne and other WWMA officials including John Thornton, Robert Nabuda, Pat Altman, Samuel Testa, and employees Barry Riley and Barbara Balcerak. 1. Spouses of officials were also in attendance. b. Poole submitted an expense report for August 23, 2004, which confirmed dinner was purchased for the above named officials at Palomino Restaurant totaling $427.95 and drinks totaling $118.60. 190. Eathorne submitted a bogus, generic receipt stub claiming to have spent $150.00 for dinner on August 23, 2004, when his and his spouse's dinner was paid by the WWMA engineer. 191. Eathorne submitted a bogus Holiday Inn receipt claiming total expenses of $826.12. a. Eathorne actually stayed at the Westin Hotel while in Pittsburgh and incurred lodging expenses less than the $826.12 he claimed. b. Eathorne's National City Bank account confirms a debit at the Westin Hotel on August 24, 2004, in an amount of $703.50. 192. Eathorne received a private pecuniary gain of $532.45 when he submitted and was reimbursed for expenses not related to actual conference expenses. a. 08/22/04 Breakfast $ 15.83 b. 08/22/04 Dinner $ 150.00 c. 08/23/04 Breakfast $ 48.00 d. 08/23/04 Dinner $ 150.00 e. 08/23/04 Spouse $ 46.00 f. Excess hotel expense $ 122.62 $ 532.45 193. The 2005 PMAA Conference was held at the Hershey Lodge and Convention Center from Sunday, September 11, 2005, to Wednesday morning, September 14, 2005. a. Check -in time on September 11, 2005, was after 4:00 pm and check -out on September 14, 2005, was before 11:00 am. 194. WWMA officials registered to attend included Eathorne, Altman, Nabuda, and Zentner. a. Eathorne's wife was also registered to attend. 195. A registration form completed on Eathorne's behalf identified activities and fees for Eathorne and his spouse. Registration $ 195.00 Monday Spouse & Guest Program Eathorne, # 06 -053 Page 46 Christmas Tree Hill and Luncheon $40.00 per person Banquet Ticket 2 @ $49.00 $ 80.00 $ 98.00 $ 373.00 196. The registration fee of $195.00 included breakfasts on September 12, 2005, and September 13, 2005, and lunch on September 13, 2005. 197. Registration fees for Eathorne and his wife were paid by Authority check #33995, dated July 21, 2005, in the amount of $373.00. Eathorne Registration $ 195.00 Christmas Tree Hill/ Luncheon (2 @ $40.00 each) $ 80.00 Banquet including after party (2 @ $49.00 each) $ 98.00 $ 373.00 198. Eathorne and Board Member Zentner registered for the golf outing on September 11, 2005, at Parkview Golf Course at a cost of $70.00 each. a. Authority check #33996 dated September 21, 2005, was issued for $140.00 to pay for the golf outing. 199. By way of invoice #1822, dated July 20, 2005 [sic], PMAA notified WWMA that an additional $57.00 was owed in regard to Board Member Eathorne's attendance at the 2005 Annual Conference. a. Eathorne, his wife, and one other unidentified person participated in the family breakfast on the last day of the conference (September 14, 2005). 1. The identity of the third person is not known. 2. WWMA officials have confirmed that Eathorne's grandson did accompany him at conventions. b. The breakfast event fee was $19.00 per person. c. The Authority issued check #34314, dated September 27, 2005, in the amount of $57.00 to PMAA in payment of the invoice. d. Eathorne co- signed the check along with the Assistant Secretary/Treasurer. 1. No other board member approved the expenditure. 200. Conference itinerary and schedule included the following: 09/11/05 Noon to 5:00 p.m. - Registration 8:00 p.m. to 10:30 p.m. - PMAA Welcome Reception 09/12/05 8:15 a.m. - Complimentary Breakfast 8:30 a.m. - Opening Ceremonies /Annual Business Meeting 10:30 a.m. - 12:30 p.m. - Exhibitor Show 12:30 p.m. - 2:00 p.m. - Professional Luncheon Eathorne, # 06 -053 Page 47 2:00 p.m. - 4:00 p.m. - General Session 4:00 p.m. - 6:00 p.m. - Exhibitor /President's Reception 6:30 p.m. - Buffet Dinner 09/13/05 7:30 a.m. to 9:30 a.m. - Breakfast with Exhibitors 9:30 a.m. to 11:00 a.m. - Idea Labs 11:00 a.m. to 12:00 p.m. - Idea Labs Noon to 2:00 p.m. - Exhibitor Lunch 2:00 p.m. to 3:30 p.m. - Idea Labs 5:30 p.m. to 6:30 p.m. - Pre - Banquet Reception 6:45 p.m. - Annual Awards Banquet 9/14/05 Family Breakfast 201. Spouse /Guest Program included the following: 09/12/05 8:15 a.m. - Complimentary Breakfast 10:15 a.m. - Christmas Tree Hill Mansion 202. Eathorne received a $1,200.00 advance of expenses on September 8, 2005. a. WWMA check #34205 was issued to Eathorne. 1. Eathorne co- authorized the payment. b. Check #34205 was deposited to Eathorne's checking account at National City Bank. 203. Hershey Lodge & Convention Center Guest Folio confirms Eathorne checked into the hotel on September 11, 2005, and departed on September 14, 2005. a. The room rate was $159.00 /night plus tax. b. Two people were identified in the party. c. Eathorne was assigned Room #4807. 204. Charges and credits to Eathorne included the following: 08/12/05 Advance Deposit Cr. $ 173.31 09/11/05 Room and tax Hershey Grill (1:29 p.m.) 09/12/05 Room and tax Bears Den (3:41 p.m.) Bears Den (3:42 p.m.) 09/13/05 Room and tax Gift shop $ 173.31 $ 33.00 $ 173.31 $ 5.00 $ 9.00 $ 173.31 $ 5.25 Date Stub No. Amount Eathorne's Reference 09/11/05 633415 $ 31.00 Breakfast -- -- -- Lunch *Hershey Grill 09/11/05 79272 $ 110.15 Dinner 09/12/05 981424 $ 28.00 Breakfast -- -- -- Lunch Eathorne, # 06 -053 Page 48 09/11/05 Breakfast Dinner 09/12/05 Breakfast Dinner Balance Due $ 398.87 205. The balance due of $398.87 was paid by Eathorne at the time of checkout by debit from his National City Bank account. 206. Eathorne submitted a travel expense report after September 14, 2005, claiming the following expenses for the 2005 PMAA Conference: $ 31.00 $ 110.15 $ 28.00 $ 94.61 09/13/05 Breakfast $ 31.00 Lunch $ 69.00 09/14/05 Breakfast $ 34.00 Lunch $ 35.00 Dinner $ 130.00 Hotel $ 398.87 Tips $ 19.57 Mileage *430 mi @ $.485/mi $ 208.55 $ 1,210.25 ** Less Advance $(1,200.00) $ 10.25 ** *The actual round trip mileage from Eathorne's home to the convention center is 386 miles. * *[sic]. [There is a $20.50 discrepancy in the calculation, which does not affect the calculation of the private pecuniary benefit in Fact Finding 216.] 207. Eathorne claimed expenses at ratepayer expense for September 12, 2005, even though most of his time was spent on a personal tour unrelated to any conference event. a. The Christmas Tree Hill event did not conclude until after 1:00 p.m. on September 12, 2005. 208. Eathorne submitted receipt "generic receipt stubs" for meals beginning with breakfast on September 11, 2005, through dinner on September 14, 2005, totaling $562.76. 09/12/05 50222 $ 94.61 Dinner 09/13/05 79269 $ 31.00 Breakfast 09/13/05 470143 $ 69.00 Lunch 09/13/05 -- -- Dinner 09/14/05 65329 $ 34.00 Breakfast 09/14/05 740751 $ 131.00* Lunch* 09/14/05 497528 $ 35.00* Dinner* TOTAL $ 562.76* Eathorne, # 06 -053 Page 49 *[sic]. [The amounts for lunch and dinner have been reversed. Fact Finding 206. The amount of $131.00 should be $130.00. Id. The sum of $562.76 reflects usage of the correct amount of $130.00 in the calculation.] a. All of the receipt stubs are in Eathorne's handwriting. b. None of the "stubs" identify a restaurant. c. No restaurant receipts were submitted by Eathorne for any meal expenses claimed. d. Eathorne typically did not incur expenses for dinners when attending conference events. 1. Eathorne and his wife would frequent vendor hospitality suites for food and drinks. 2. Vendors would also, on occasion, take Eathorne out to dinner. 209. Receipt stubs submitted by Eathorne as justification for meal expenses are identical to stubs submitted by Eathorne for other travel: a. Receipt stub no. 633415 is identical in format, manufacturer, and part of a sequence as receipt no.'s 633421 and 633431 used by Eathorne for other conferences. 1. Receipt no. 633421 was used by Eathorne for the 2001 WEFTEC and no. 633431 was used by Eathorne for the 2005 WEFTEC. b. Receipt stub no.'s 79269 and 79272 are identical in format and part of a sequence used by Eathorne for other events: Stub No. Event 79269 2005 PMAA 792271 2003 WEFTEC 79272 2005 PMAA 79273 2006 Pumper Expo 79274 2003 WEFTEC 79275 2005 WEFTEC c. Receipt no. 65329 is identical in format and part of a sequence of numbers used by Eathorne for other events. Stub No. Event 65329 2005 PMAA 65333 2006 Pumper Expo 65335 2001 WEFTEC Eathorne, # 06 -053 Page 50 65336 2006 Pumper Expo 65340 2001 WEFTEC 210. Eathorne claimed breakfasts and lunches for himself and his wife totaling $64.00 on September 11, 2005. a. Eathorne claimed this amount even though the conference did not begin until 8:00 p.m. 1. Registration did not begin until 2:00 p.m.* and hotel check -in was 4:00 p.m. or later. *[sic]. [See, Fact Finding 200.] 211. Eathorne claimed breakfast expenses of $93.00 on September 12, 2005, September 13, 2005, and September 14, 2005, even though these meals were provided as part of the registration or were previously paid by the WWMA. a. Eathorne's justification for the breakfast expenses was by submission of generic receipt stubs in his handwriting. 212. Eathorne claimed lunch expenses totaling $69.00 on September 13, 2005. a. Lunch was provided on September 13, 2005, as part of the PMAA Program. b. Eathorne submitted a generic receipt stub no. 470143 in his handwriting as documentation of this expense. 213. Eathorne's dinner expenses totaling $204.76 on September 11, 2005, and September 12, 2005, included spousal expenses. a. Eathorne's spousal expenses were at least half of Eathorne's total or $102.30. 214. Eathorne's turnpike toll receipts confirm the following regarding Eathorne's arrival in the Hershey area and his return home. Date Time Entry Plaza Exit Plaza Cost 09/11/05 8:50 a.m. 067/07 247/019 10.25 09/14/05 3:26 p.m. 247/019 067/07 $10.25 215. Eathorne claimed lunch and dinner expenses for himself and his wife on September 14, 2005, totaling $165.00. a. The conference concluded following breakfast at 8:30 a.m. on September 14, 2005. 1. The WWMA had paid for the Eathornes' breakfasts. b. Eathorne returned to his home shortly after 3:30 p.m. on September 14, 2005, and claimed dinner for himself and his wife. 216. Eathorne realized a private pecuniary gain of $774.40* when he received expense funds for spousal expenses, golf outing, guest tours, and meals for which no documentation could be provided, in violation of Authority travel policy. a. Guest Tours 2 at $40.00 $ 80.00 Eathorne, # 06 -053 Page 51 b. c. d. e. f. g. h. Spouse Banquet Golf fee Gift shop 9/13 Breakfasts 2 at $19.00 Breakfasts 9/11, 9/12, 9/13,* 9/14 Lunch 9/13/05 Meal 9/11/05 Receipt no. 79272 Meal 9/13/05* Receipt no. 79269 Meals 9/14/05 *[sic]. [There is a $64.00 discrepancy i cost for the breakfast of September 13, the calculation.] 217. The 2006 PMAA Conference and Trade Convention Center from September 10, a. Conference itinerary included the following: 9/10/06 10:00 a.m. — 5:00 p.m. 8:00 p.m. — 10:30 p.m. 9/14/06 8:15 a.m. 8:30 a.m. 10:30 a.m. — 12:30 p.m. 2:30 p.m. — 4:30 p.m. 9/12/06 7:30 a.m. - 9:30 a.m. 9:30 a.m. — 10:30 a.m. 10:30 a.m. — Noon Noon — 2:00 p.m. 2:00 p.m. — 3:30 p.m. 2:00 p.m. — 4:00 p.m. 6:45 p.m. b. Spouse and Guest Program: 9/11/05 [sic] Complimentary Breakfast 10:15 a.m.— Pennsylvania Dutch Country 9/12/06 7:30 a.m. — 9:30 a.m. 10:00 a.m. — Noon 1:00 p.m. 9/13/06 Breakfast $ 49.00 $ 70.00 $ 5.25 $ 38.00 $ 93.00 $ 69.00 $110.15 $ 31.00 $165.00 $774.40* n the calculation of the total amount. The 2005, is accurately included only once in Show was held at the Hershey Lodge and 2006, to September 13, 2006. Conference Registration Welcome Reception Complimentary Breakfast Opening Ceremonies Exhibitor Show Idea Labs Complimentary Breakfast Idea Labs (2) Idea Labs (3) Exhibitor Lunch Idea Labs (4) Emergency Response Awards Banquet Complimentary Breakfast Hors D'oeuvres the Hershey Way Hershey Trolley Tours 218. Eathorne was registered to stay at Hershey Lodge and Convention Center. a. Check in time was after 4:00 pm on September 10, 2006. Eathorne, # 06 -053 Page 52 b. Check out time was before 11:00 am on September 13, 2006. 219. Registration fees and room deposits were made by the WWMA. a. A room deposit of $179.85 was made on August 10, 2006, by WWMA check no. 35313. b. Registration fee for Eathorne was $245.00. c. Also paid by check no. 35313 were two banquet tickets for Eathorne and his wife totaling $98.00. 220. Eathorne received an $800.00 advance of expenses by WWMA check dated September 7, 2006. a. The check was deposited to Eathorne's account at National City Bank on September 5, 2006. 221. Advance payments made to Eathorne or on his behalf for the 2006 PMAA event totaled $1,322.85. 222. Eathorne did not submit a travel expense report to the WWMA detailing expenses related to the $800.00 advance. 223. Records provided by Hershey Entertainment and Resorts confirm Eathorne was registered at the Hershey Lodge between September 10, 2006, and September 13, 2006, to account no. 2530780. a. Hotel invoice contained the following: Arrival: 9/10/06 Departure: 9/13/06 Number in Party: 2 b. Expenses and credits: Deposit $179.85 cr 9/10/06 Room & Tax $179.85 9/11/06 Room & Tax $179.85 9/12/06 Room & Tax $179.85 Balance Due $359.70 224. The balance of $359.70 was paid at check -out by Eathorne's National City Bank debit card. 225. Eathorne's only documented expenses for this trip to Hershey was the room expense of $359.70. a. Eathorne submitted no other documented expenses to either the WWMA or to the Investigative Division of the State Ethics Commission. 226. Eathorne realized a private pecuniary gain of $489.30 as a result of not refunding the difference between the advance of $800.00 and actual expenses of $359.70. Eathorne, # 06 -053 Page 53 a. The WWMA also paid a $49.00 banquet charge for Eathorne's spouse. b. Total private pecuniary gain was $489.30. 227. Eathorne regularly received expense monies from the WWMA for attendance at PMAA Region 9 dinners. a. Eathorne's wife accompanied him to these dinners. b. Dinners for Eathorne's wife were paid using WWMA funds. 1. Eathorne approved the payments and signed checks authorizing payments. 228. Eathorne attended PMAA Regional dinners on at least the following occasions: Date Spousal Cost WWMA Check No. 4/17/04 $35.00 31651 11/5/05 $40.00 34508 229. Eathorne realized a private pecuniary gain of $75.00 by using WWMA funds to pay for dinner expenses incurred by his spouse. 230. Eathorne attended other PMAA sponsored events for which he submitted and received expense reimbursements unrelated to event attendance including the following: PMAA Seminar 2004 PMAA Legislative Days 231. PMAA has sponsored Legislative Days in Harrisburg, PA, annually between 2001 and 2004. a. The purpose of the events was to enable PMAA members to meet with legislators to discuss /review legislation affecting the PMAA membership. b. Legislative Days were held as follows: May 1, 2001 April 9, 2002 May 12, 2003 May 7, 2004 232. Eathorne received advances and claimed expenses for attendance at Legislative Day events in 2003 and 2004. 233. The registration form for the May 13, 2003, Legislative Day confirms registration for Eathorne, Board Member John Thornton, and Barry Riley, Plant Manager. a. WWMA Check no. 30119 in the amount of $700.00 was issued to Eathorne on May 6, 2003. 1. Eathorne co- authorized the check. b. On May 6, 2003, the check was deposited to Eathorne's account at National City Bank. 234. Legislative Day 2003 held at the Harrisburg Hilton included the following agenda: Eathorne, # 06 -053 Page 54 8:00 a.m. — 8:30 a.m. 8:30 a.m. — 9:30 a.m. 9:30 a.m. — 10:00 a.m. 10:30 a.m. — 3:00 p.m. 3:00 p.m. — 4:15 p.m. 4:30 p.m. — 6:30 p.m. 235. Harrisburg Hilton guest invoice confirms Eathorne checking into the hotel on May 12, 2003, at 5:21 pm. a. Two adults were registered. b. Room rate was $211.00 plus $18.99 in taxes. c. Eathorne departed on May 14, 2003. 236. Eathorne incurred the following expenses while at the Hilton: 5/12/03 Room, plus tax overnight self parking 5/13/03 Room, plus tax overnight self parking *[Cf., Fact Finding 235 c).] 237. Eathorne's National City Bank account statements confirm a check card payment to the Hilton in an amount of $471.98. 238. Eathorne submitted an expense report to expenses: 239. Eathorne submitted generic receipts with the expense report as noted below: Date 5/12/03 5/12/03 5/13/03 5/14/03 5/14/03 Hotel Mileage 380 at .365/mi Tolls Meals Advance Balance Stub No. 990213 320508 165342 559054 50218 Registration /Continental Breakfast Environmental Issues Forum Overview of Issues & Hill Protocol Meet w /Legislators DEP Secretary Kathleen McGinty Legislative Reception $471.98 $138.70 $ 14.00 $196.00 $820.68 $700.00 $120.68 Amount $ 35.00 $ 50.00 $ 21.00 $ 25.00 $ 65.00 $196.00 $229.00* $ 6.00 $229.00* $ 6.00 $471.98 the WWMA claiming the following Meal Lunch Dinner Breakfast Lunch Dinner a. All of the stubs bear Eathorne's handwriting for the date and amount. b. Meal receipts submitted by Eathorne included the cost of meals for his wife. 1. None of the receipts are itemized or identify a restaurant. Eathorne, # 06 -053 Page 55 c. Receipt no. 990213 is identical in format to Receipt no. 990214 used by Eathorne in 2002 to claim a meal expense for the 2002 WEFTEC in Chicago. d. Meal expenses included a $35.00 lunch and a $50.00 dinner for the day prior to the start of the event. 240. Pennsylvania Turnpike toll receipts submitted by Eathorne reflect the following in regard to his arrival and departure times: Day Time Plaza Cost 132 1649 (4:19p) 1807 7.00 184 1522 (3:22p) 718 $7.00 241. Eathorne submitted a $65.00 expense for dinner on May 14, 2003, even though he exited the turnpike at 3:22 p.m. and his home was only 2.25 miles, (7) seven minutes away. 242. Eathorne received a private pecuniary gain of $176.00 by claiming spousal expenses and an evening meal on May 14, 2003, which was unrelated to the one day conference. a. Eathorne claimed a breakfast on May 13, 2003, in an amount of $21.00 even though breakfast was paid as part of the registration. Spousal expenses (half of $100.00 *) 5/12/03 Lunch 5/13/03 Breakfast 5/14/03 Dinner 9:30 a.m. — 10:00 a.m. Overview of Issues Hill Protocol $ 55.00* $ 35.00 $ 21.00 $ 65.00 $176.00 *[We determine the spousal expenses to have been $50.00 and the total of the above amounts to have been $171.00. Bartholomew, supra.] 243. Eathorne attended the 2004 PMAA Legislative Day held in Harrisburg on May 11, 2004. a. Registration cost was $25.00 per person. b. On April 27, 2004, the WWMA issued check no. 31770 in the amount of $75.00 to the PMAA to cover registration fees for Eathorne, John Thornton, and Barry Riley. 244. Agenda for the 2004 Legislative Day included the following: 8:00 a.m. — 8:30 a.m. Registration Continental Breakfast 8:30 a.m. — 9:30 a.m. Environmental Issues Forum 10:00 a.m. — 3:00 p.m. Meet w /legislators Attend Legislative Sessions Eathorne, # 06 -053 Page 56 3:00 p.m. — 5:00 p.m. Speaker DEP Secretary McGinty 5:00 p.m. — 7:00 p.m. Legislative Reception 245. Eathorne received a $700.00 advance from the WWMA on May 6, 2004. a. WWMA Check no. 31817 was issued to Eathorne. 1. Eathorne co- authorized the issuance of the check. b. The check was deposited to Eathorne's checking account at National City Bank on May 6, 2004. 246. Eathorne's wife accompanied him on the trip to Harrisburg. a. Lodging was obtained at the Crowne Plaza Hotel. b. Eathorne checked in on May 10, 2004, and checked -out on May 12, 2004, and was registered to Room #332. 247. Crowne Plaza guest bill for Eathorne confirmed the following changes: 5/10/04: Room charge & taxes $ 97.01 Caucus Lounge $ 33.75 5/11/04: Room charge & taxes $ 97.01 Room Service $ 14.78 Caucus Lounge $ 17.75 Movies $ 14.84 Movies $ 13.77 $288.90 *[sic]. [There is a one -cent discrepancy, in favor of the Respondent, in the calculation.] 248. The expenses were charged to an American Express credit card account ending in 005. 249. Eathorne submitted an expense report claiming the following expenses totaling $900.35 for the one day legislative day event. Tolls $ 14.10 Mileage *520 at .345 /mile $179.40 Hotel $288.90 Breakfast 5/10 $ 22.10 Dinner $114.75 ** Breakfast $ 25.00 Lunch $ 45.80 Dinner $130.30 ** Tips $ 80.00 $900.35 Hotel expenses claimed included movie rentals of $28.60, lounge expenses of $51.50, and room service of $14.78. *Actual round trip mileage from Eathorne's home to the Crowne Plaza is 384 miles. Eathorne, # 06 -053 Page 57 * *[Differences between these amounts and the amounts indicated in Fact Finding 250 are of no consequence; the lower amounts are used to calculate the private pecuniary benefit in Fact Finding 254.] 250. Eathorne submitted "generic receipt stubs" to document meal expenses outside of those charged to his hotel room. Date Stub No. Amount Meal 5/10/04 724423 $ 22.10 Breakfast 5/10/04 872909 $114.74 Dinner 5/11/04 95161 $ 25.00 Breakfast 5/11/04 129003 $ 45.80 Lunch 5/11/04 0058614 $120.00 Dinner a. The information on the stubs was handwritten by Eathorne, including dates and amounts of charges. b. No restaurants were identified on the stubs. c. No record exists of Eathorne incurring any of the expenses outlined above. 251. Eathorne claimed a breakfast expense of $22.10 on May 10, 2004, even though the Legislative Day did not commence until the morning of May 11, 2004. a. Eathorne also claimed a breakfast expense of $25.00 on May 11, 2004, even though breakfast was provided as part of the PMAA program. 252. Eathorne did not submit accurate turnpike toll receipts to justify turnpike toll expenses. a. The sole receipt produced by Eathorne identifies day traveled as Day 80 of 2004. 1. Day 80 of 2004 was March 21, 2004, not May 10, 2004, as asserted by Eathorne. 253. Eathorne claimed reimbursement of $280.85 for meal expenses related to expenses for himself and his spouse. 254. Eathorne realized a private pecuniary gain when he claimed and received expense reimbursement for expenses not related to the conference and for spousal expenses. a. Breakfast $ 47.10 b. Undocumented meals $280.54 c. Tips (maximum $25.00 $ 55.00 allowed) d. Movie $ 14.84 Movie $ 13.77 e. Lounge $ 33.75 Lounge $ 17.75 f. Excess expense advance $ 55.75 g. Mileage overcharge $ 46.92 136 at .345 $565.42 Eathorne, # 06 -053 Page 58 255. Eathorne was registered to attend a PMAA- sponsored event titled "Administrative Issues Seminar," scheduled for the Nittany Lion Inn on or about 2004. a. The seminar included a golf outing and fall indoor picnic. b. Costs included: Seminar $ 70.00 Golf $ 60.00 Picnic $ 25.00 $155.00 c. The WWMA issued check no. 32483 to the PMAA dated September 21, 2004, which included costs for Eathorne totaling $155.00. 1. No expense report was submitted by Eathorne for this event. 256. The WWMA paid expenses to Eathorne or on his behalf to attend PMAA functions totaling $8,310.74. a. Eathorne's use of the authority of his position to claim spousal expenses and undocumented expenses resulted in a private pecuniary gain of $3,201.48.* b. Eathorne over - billed the WWMA for mileage for PMAA conferences in 2003 and 2005 and the 2004 legislative day totaling $84.10.* *[Respondent's total private pecuniary gain as to PMAA functions was $3,285.58. See, Discussion, infra.] THE FOLLOWING FINDINGS RELATE TO EXPENSES CLAIMED BY EATHORNE IN RELATION TO WEFTEC CONFERENCES 257. Eathorne, as a member of the WWMA, has attended annual conferences hosted by the Water Environment Foundation (WEF). a. Eathorne has received advances of expenses and has received additional reimbursements from the WWMA in relation to these events. b. Eathorne received payment for annual conferences between 2001 and 2006. 258. The WEF is a not - for - profit technical and educational organization consisting of 32,000 individual members and 80 member associations representing approximately 50,000 water quality professionals. a. WEF was formed in 1928 with a mission of preserving and enhancing the global water environment. 259. WEF holds annual meetings /conferences to provide a forum for knowledge and technical exchange within the water and waste water fields. 260. WEFTEC is the Water Environment Federation's Annual Technical Exhibition Conference. a. The conference offers water quality education and training and water quality exhibitions through an expansive show floor for access to advanced technologies in the field, and serves as a forum for domestic and international business opportunities. Eathorne, # 06 -053 Page 59 261. Training and educational seminars provided throughout the conferences are highly technical and directed toward environmental engineers, water and waste water treatment professionals, local, state, and federal regulators, water and waste water utility managers and operators and equipment manufacturers and representatives. a. Attendees must register for seminars they want to attend. 1. Fees are charged for attendance to seminars. b. Badges are provided which authorize entrance to specific seminars. c. Access to seminars is denied without a badge. 262. Since 2001 WEFTEC events have been held in the following locations: 2001 Atlanta, GA 2002 Chicago, IL 2003 Los Angeles, CA 2004 New Orleans, LA 2005 Washington, DC 2006 Dallas, TX 10 -13 -01 to 10 -17 -01 9 -28 -02 to 10 -3 -02 10 -11 -03 to 10 -16 -03 10 -2 -04 to 10 -6 -04 10 -29 -05 to 11 -2 -05 10 -21 -06 to 10 -25 -06 263. For each conference, attendees are required to complete a registration form. a. The form includes the following areas to be completed: Employer Code Job Title Code Environmental Forms b. The form also includes registration fees for various options for attendees including: Full conference and EXPO One day conference and EXPO Student One day EXPO Sunday, Monday or Tuesday, Wednesday Industry Day PWO full week Life Style Program The lifestyle program is intended to provide sightseeing tours of points of interest. Attendees receive color coded badges for event session(s) they have registered to attend. 264. Registration forms completed on Eathorne's behalf for attending WEF Conferences from 2001 through 2006 identified the following: a. Employer Code: Publicly owned municipal or district sanitary, water or wastewater treatment system b. Job Title: Public official c. Environmental focus: Wastewater 265. Eathorne attended the 2001 WEFTEC Conference in Atlanta, GA from October 13, 2001, to October 17, 2001. a. Patricia Henrickson Eathorne, his spouse, accompanied him. Date Day Time Cost /Person Total Description of Week of Day Cost 10/15/01 Monday 1:00 p.m.- $41.00 TEU700 Covington's Mansions 5:30 p.m. 10/16/01 Tuesday 9:30 a.m.- $26.00 $52.00 Good Life in Historic 1:00 p.m. Buckhead 10/17/01 Wednesday 8:30 a.m.- $36.00 $72.00 Atlanta's Famous First 12:30 p.m. Eathorne, # 06 -053 Page 60 b. All expenses for Patricia Eathorne, with the exception of airfare, were paid using WWMA Funds. 266. Eathorne registered for the One -Day EXPO only option for Monday or Tuesday. a. The EXPO only option entitles the attendee to access to the exhibition hall only. b. Eathorne did not register to attend any conference training or seminar. c. The cost for the One Day EXPO was $40.00. 267. Eathorne also registered his wife to attend the lifestyle program. a. The cost for the program was $100.00. 268. The $140.00 registration fees were billed to WWMA American Express card in the name of Plant Manager Barry Riley. 269. Eathorne registered himself and his wife for tours unrelated to any official conference functions. a. The reservations, made through Atlanta Arrangements, Inc., 1350 Spring Street NW #600, Atlanta, GA 30309, were made for Eathorne by WWMA Assistant Secretary /Treasurer Barbara Balcerek at his direction. b. The cost of the tours were charged to the Authority American Express card assigned to Barry Riley. 270. Tours were booked for Eathorne and his wife at Authority expense as follows: Total: $206.00 271. The tours taken by Eathorne occurred during the hours when conference concurrent sessions were being held. a. Eathorne was not involved in any conference - related functions for at least 50% of the conference. 272. Room bookings were handled by Management Resources, Inc. a. A credit card deposit guarantee of $150.00 per room was required. b. The Authority credit card assigned to Plant Manager Barry Riley was used to guarantee the reservations for all the attendees. 273. Eathorne's Hotel Reservation Form lists the occupants as himself and his wife, Eathorne, # 06 -053 Page 61 Patricia Henrickson (Eathorne). a. Eathorne chose a double, non - smoking room. 274. Air transportation to Atlanta for the Authority Board Members and theirwives /guests was charged to the Authority American Express credit card assigned to Barry Riley. a. The cost of the air transportation booked by the Authority for the wives and guests was reimbursed by way of personal check payable to American Express. b. Eathorne's wife, Patricia Henrickson, issued personal check #5376, dated July 19, 2001, in the amount of $156.00, to American Express, and submitted it to the Assistant Secretary /Treasurer. 1. The memo section of the check was marked, "WEF Atlanta /air fare ". 275. The air travel arrangements for Eathorne and the other Board Members were as follows: Leave Pgh International Airport 10/13/01 Arrive Atlanta Airport 10/13/01 Leave Atlanta Airport 10/17/01 Arrive Pgh International Airport 10/17/01 9:05 a.m. 10:15 a.m. 6:28 p.m. 8:13 p.m. 276. Authority check #26974, dated July 19, 2001, in the amount of $1,828.01 was issued to American Express in payment of the credit cards assigned to Plant Manager Barry Riley and Assistant Secretary /Treasurer, Barbara Balcerek. a. The Check was co- signed by Eathorne and the Assistant Secretary /Treasurer. b. The payment made to American Express included the cost of the tours, the airline tickets, and the registration for the conference. 277. Eathorne received WWMA check #273282 dated October 9, 2001, in the amount of $2,000.00 as an advance of expenses for the attendance at the 2001 WEFTEC event. a. Eathorne co- signed the check authorizing the payment. b. Eathorne deposited the check on October 19, 2001, to his National City Bank account. 278. Eathorne did not submit an expense report to the WWMA detailing expenses incurred while attending the 2001 WEFTEC event. a. Eathorne's National City Bank account confirms debit charges in Atlanta, GA during the time frame of the 2001 WEFTEC conference (October 13, 2001, to October 17, 2001). Sheraton Hotel $935.37 Pasta Del Pulcinelle $ 24.00 Jacks & Jills $ 56.00 Marriott Hotel $126.94 Total $1,142.31 Eathorne, # 06 -053 Page 62 279. Pursuant to a subpoena issued by the Investigative Division of the State Ethics Commission, Eathorne provided the following documents regarding his trip to Atlanta between October 13, 2001, and October 17, 2001. a. 18 generic receipt stubs b. Sheraton Hotel receipt c. Bank statement page 2 of 3 280. Sheraton Colony Square Hotel, 188 14 Street, N.E., Atlanta, GA, invoice provided by Eathorne confirmed a check -in date of October 13, 2001, at 12:21 p.m. and a check -out date of October 18, 2001, at 10:36 a.m. and the following expenses and credits: Date Entry Credit Debit 10/13/01 Deposit $150.00 10/13/01 Room $164.00 Tax $ 11.48 Tax $ 11.48 Valet Park $ 18.00 10/14/01 Room $164.00 Tax $ 11.48 Tax $ 11.48 Valet Park $ 18.00 14 St. Grill $ 30.57 10/15/01 Room $164.00 Tax $ 11.48 Tax $ 11.48 Valet Park $ 18.00 10/16/01 Room $164.00 Tax $ 11.48 Tax $ 11.48 Valet Park $ 18.00 14 St. Grill $ 30.00 10/17/01 Room $164.00 Tax $ 11.48 Tax $ 11.48 Valet Park $ 18.00 Total $150.00 $1,085.37 The balance of $935.37 was paid by Eathorne's National City Bank check card upon departure. 281. Eathorne provided generic receipt stubs to document meal expenses for the time period from October 13, 2001, to October 18, 2001. a. Date Meal Amount Stub No. 10/13/01 Breakfast $ 21.00 33017 Lunch $ 32.00 357061 Dinner $ 95.00 717717 Eathorne, # 06 -053 Page 63 10/14/01 Breakfast $ 22.00 65633 Lunch $ 25.00 317957 Dinner $ 92.00 729947 10/15/01 Breakfast $ 20.00 824647 Lunch $ 31.00 729958 Dinner $106.00 914016 10/16/01 Breakfast $ 25.00 97868 Lunch $ 40.00 633240 Dinner $ 65.00 65340 10/17/01 Breakfast $ 21.00 717716 Lunch $ 32.00 357059 Dinner $ 80.00 340836 10/18/01 Breakfast $ 30.00 65335 Lunch $ 30.00 633421 Dinner $ 80.00 51893 Total $847.00 b. All of the stubs contained dates and amounts in Eathorne's handwriting. 282. Other expenses asserted by Eathorne for the time period October 13, 2001, to October 18, 2001, including the following: a. Mileage: Home to airport $31.06 90 miles at $.345 /mile b. Parking: Airport $32.07 c. Tips $25.00 $88.76* *[sic]. [There is a sixty -three cent discrepancy in the calculation, which does not affect the calculation of the private pecuniary benefit in Fact Findings 292 -293.] 283. Eleven (11) of eighteen (18) generic receipt stubs submitted by Eathorne were issued from (5) receipt books. a. Receipt stubs confirmed that receipts were in sequence or receipts were part of a sequence: Stub Date Meal 357061 10/13/01 Lunch 357059 10/17/01 Lunch 717717 10/13/01 Dinner 717716 10/17/01 Breakfast 729947 10/14/01 Dinner 729958 10/15/01 Lunch 633420 10/16/01 Lunch 633421 10/18/01 Lunch Eathorne, # 06 -053 Page 64 65335 10/18/01 Breakfast 65340 10/16/01 Dinner 65633 10/14/01 Breakfast b. All of the sequenced receipts are identical in print and were made out in Eathorne's handwriting. 284. Receipt stubs used by Eathorne were part of a sequence and identical in format as receipts Eathorne used for other conferences: Receipt No. Conference 357055 2001 Fall ALOM 357059* 2001 WEFTEC 357061* 2001 WEFTEC 717708 2001 Fall ALOM 717715 2001 PMAA 717716* 2001 WEFTEC 717717* 2001 WEFTEC 633415 2005 PMAA 633420* 2001 WEFTEC 633421* 2001 WEFTEC 633431 2005 WEFTEC 65329 2005 PMAA 65333 2006 Pumper Expo 65335* 2001 WEFTEC 65336 2006 Pumper Expo 65340* 2001 WEFTEC 65621 2006 Pumper Expo 65622 2001 PMAA 65624 2001 PMAA 65628 2002 WEFTEC 65633* 2001 WEFTEC 65634 2001 PMAA 65636 2001 PMAA 65638 2006 Pumper Expo *Refers to 2001 WEFTEC Receipts 285. Eathorne's bank records also confirmed usage of Eathorne's bank card in Biloxi, MS during the same period as the Atlanta trip: 10/17/01 Biloxi, MS 10/19/01 Biloxi, MS $306.45 $102.00 The $102.00 expense was an ATM withdrawal. The dates listed are the dates the charges were made to Eathorne's bank account and were made within (4) days of bank card use. 286. Eathorne and Plant Manager Riley took a side trip to a casino in Biloxi, MS, during the time frame of the conference. a. Eathorne and Riley took similar trips to the Grand Casino in Biloxi when attending the 1999 WEFTEC. Eathorne, # 06 -053 Page 65 287. Eathorne claimed the following expenses in relation to his trip to Atlanta: a. Room & Tax $934.80 b. Valet Parking $ 90.00 c. Meals $847.00 d. Hotel Meals $ 60.57 e. Mileage $ 31.06 f. Airport Parking $ 32.70 g. Tips $ 25.00 $2,021.13 288. Eathorne's airline reservations confirm travel dates of October 13, 2001, leaving Pittsburgh and a October 17, 2001, return date. a. Eathorne amended his travel to stay an extra day at WWMA expense and did not return until October 18, 2001. b. Eathorne incurred extra expenses including hotel and meals and parking for a vehicle rented while in Atlanta. c. Eathorne extended his stay, in part, due to travel to Biloxi, MS. 289. Eathorne's additional expenses not related to the conference included the following: a. Room & Tax $186.96 b. Meals (by generic receipt) $140.00 $326.96 290. Eathorne did not attend sessions on at least parts of all three main days of the 2001 WEFTEC Conference. a. Eathorne was registered for sight seeing tours of the Atlanta area on the following days: 10/15/01 1:00 p.m. to 5:30 p.m. 10/16/01 9:30 a.m. to 1:00 p.m. 10/17/01 8:30 a.m. to 12:30 p.m. 291. Eathorne's attendance at the 2001 WEFTEC Conference was limited to registration to view the exhibit hall. a. Eathorne was not registered to attend any educational sessions. 1. Registration was required to obtain a badge to gain admission. b. Part of his days were spent sight seeing in the Atlanta area. c. Other time was spent traveling to Biloxi, MS. 292. The WWMA paid a total of $2,612.00 for Eathorne's attendance at the 2001 WEFTEC Conference which was limited to his tour of the exhibit hall. a. Airfare $ 156.00 b. Advance $2,000.00 c. Tours $ 206.00 Eathorne, # 06 -053 Page 66 d. Room Deposit $ 150.00 e. Spouse Lifestyle $ 100.00 $2,612.00 293. Eathorne received a private pecuniary gain of $2,612.00 when the WWMA incurred expenses for his travel to Atlanta for a conference he did not attend. 294. The 2002 WEFTEC conference was held in Chicago, IL, from Saturday, September 28, 2002, to Thursday, October 3, 2002. a. Conference registration occurred on September 28, 2002, and September 29, 2002. b. Conference events occurred from September 30, 2002, to October 3, 2002. 1. The Expo hall was open on September 29, 2002, from 1:00 p.m. to 5:00 p.m. 295. Advance Registration form for the conference completed on behalf of Eathorne identified the following conference events registered for by Eathorne. a. One Day EXPO only $50.00 b. Lifestyle Program (spouse) $100.00 c. The costs of these programs were billed to a WWMA American Express Card issued to Barry Riley. 296. Eathorne did not register to attend any conference - related training or seminars. a. Eathorne's sole conference - related activity for the entire six days of the conference was a tour of the exhibitor hall. 297. Eathorne also registered for tours for his wife and himself to attend which were not related to any conference function. a. Highlights of Chicago 2 at $28.00 $56.00 Monday 9/30/02 1:30p. m. -4:30 p.m. 2 at $35.00 $70.00 Wednesday 10/2/02 9:00 a.m. -12:30 p.m. b. Famous Homes of Chicago c. The total cost of $126.00 for the Eathorne's tours was billed to the WWMA American Express Card in the name of Barry Riley on August 21, 2002. 298. Eathorne received an advance of expenses in the amount of $2,500.00 by WWMA check no. 29131 issued on September 24, 2002. a. Eathorne signed the check in his capacity as WWMA treasurer. b. The check was deposited to Eathorne's National City Bank account on September 24, 2002. c. Eathorne authorized the advance to himself five days after he was instrumental in approving the increase in advance payments from $2,000.00 to $2,500.00. Eathorne, # 06 -053 Page 67 299. Eathorne submitted an expense report claiming to have incurred the following expenses in relation to the trip to Chicago: Hotel $1,520.60 Cab & Limo fares $ 95.00 Food & Tips $1,021.69 Car Rental $ 311.15 Mileage 100 at .345/mi $ 34.50 Tips $ 90.00 $3,072.94 Advance $2,500.00 Balance owed $ 572.94 300. WWMA check no. 29282 dated October 29, 2002, in the amount of $572.94 was issued to Eathorne. a. Eathorne signed the check as WWMA treasurer. b. The check was deposited to Eathorne's National City Bank account. 301. Not including airfare, the WWMA expensed $3,348.94 for Eathorne's travel to Chicago. 302. The Chicago Marriott Guest Folio itemized the following in regard to expenses incurred by Eathorne: a. Arrival: 9/28/02 — 12:16 (CST) Departure: 10/3/02 b. Room charges 9/28/02 $263.12 9/29/02 $263.12 9/30/02 $263.12 10/1/02 $263.12 10/2/02 $263.12 $1,315.60 c. Parking fees 9/28/02 $32.00 9/29/02 $32.00 9/30/02 $32.00 10/1/02 $32.00 10/2/02 $32.00 $160.00 d. Lobby $20.00 9/30/02 303. Eathorne submitted restaurant receipts to the WWMA claiming the following expenses: Date Location Amount 9/28/02 Spadaro's $50.00 Murrysville 9/28/02 Bandura $68.88 2:35p.m. (CST) Tip $12.12 Eathorne, # 06 -053 Page 68 9/29/02 9/30/02 10/1/02 $73.00* Inter - Continental Hotel $39.40 10:30a.m. (CST) Tip $ 8.60 (2) Buffet Breakfasts $48.00 Chicago Hotel & Towers $18.61 10:35 a.m. (CST) Tip $ 3.39 $22.00 Inter - Continental Hotel $39.40 10:51a.m. (CST) Tip $ 7.60 (2) Buffet Breakfasts $47.00 Inter - Continental Hotel $39.40 11:21a.m. (CST) Tip $ 7.60 (2) Buffet Breakfasts $47.00 Lamonts $19.56 1:08p.m. (CST) 10/3/02 Bravo Kitchen $61.20 Pittsburgh Tip $11.80 5:32p.m. (EST) $73.00 (2) Dinners *[sic]. [There is an $8.00 discrepancy in the calculation, to the advantage of Respondent.] 304. Eathorne also submitted generic receipt stubs asserting additional meal expenses: Date Amount Receipt No. 9/28/02 $240.00 990214 9/30/02 $115.00 65628 9/30/02 $ 45.00 644894 10/1/02 $120.00 71508 10/2/02 $ 40.00 71501 10/2/02 $ 13.73 03043 10/2/02 $ 38.00 433532 $611.73 305. Receipt stubs submitted by Eathorne as justification for expenses are parts of sequences and identical in format and style as other receipts submitted by Eathorne for other conferences: Receipt No. Conference 990213 2003 Legislative Day 990214* 2002 WEFTEC 65621 2006 Pumper Expo 65622 2001 PMAA 65624 2001 PMAA 65628 2002 WEFTEC 71501* 2002 WEFTEC 71508 2002 WEFTEC Eathorne, # 06 -053 Page 69 *Refers to 2002 WEFTEC 306. The pattern of using receipts identical in design and print and part of a sequence was a common occurrence for Eathorne when traveling at rate payer expense and was done solely to inflate expenses in order to receive private pecuniary gain. a. Eathorne was one of the group of board members who asserted that since they were not compensated as board members, they were entitled to claim, as expenses, all advance monies received. b. Eathorne typically did not go out for dinner when traveling to such conferences unless the meal was paid for by a third party. 1. Eathorne did go to vendor hospitality suites where he was treated to drinks and food items. 2. Eathorne's wife would accompany him. 3. Eathorne would go to these functions in lieu of purchasing dinner. 307. Eathorne also submitted a receipt to the WWMA claiming an expense at ESPN Zone. a. Eathorne submitted the receipt under the guise the purchase was for a meal. b. The purchase of a hat at a cost of $21.75 was made at ESPN Zone on September 29, 2002, at 2:25 p.m. c. Eathorne claimed a total expense of $31.00 claiming that he paid an $8.25 tip. 1. Eathorne's National City Bank debit card records confirms a purchase of $21.75. d. The purchase was made during the time frame when conference seminars were being held. 308. Eathorne rented a vehicle, a Chevy Blazer SUV, from National Car rental while on his Chicago excursion at WWMA rate payer expense. a. The vehicle was rented on September 28, 2002, at 1:01 pm and returned on October 3, 2002, at 10:20 am. b. A total of 40 miles was driven. c. Charges for the vehicle included the following: 1 week rental $250.99 Fuel $ 11.25 Taxes $ 8.91 $311.15* *[sic]. [There is a $40.00 discrepancy in the calculation.] 309. In addition to claiming vehicle rental and parking expenses totaling $471.15, Eathorne claimed an additional cab and limousine expenses of $95.00. Eathorne, # 06 -053 Page 70 9/28/02 9/29/02 10/1/02 10/1/02 9/29/02 $15.00 9/29/02 $15.00 9/30/02 $18.00 10/1/02 $12.00 10/2/02 $35.00 (Limo) All of the receipts are made out in Eathorne's handwriting. 310. Of the $3,348.94 in expense monies paid to Eathorne, or on his behalf, the following were not related in any way to the 2002 WEF Conference: Car Rental $311.15 Lifestyle $100.00 Program Tours $126.00 Parking $160.00 ESPN Zone $ 30.00 $727.15 311. Eathorne asserted a meal expense of $52.00* on September 28, 2002, the day he departed for Chicago. *[sic]. [Cf., Fact Finding 303. Respondent receives the benefit of the lower averred amount of $50.00. Bartholomew, supra.] a. The meal expense was claimed to have been incurred at Spadaro's Restaurant, Murrysville, PA. 1. Spadaro's Restaurant does not open for business until 4:00 p.m. 2. Spadaro's is located approximately one hour by vehicle from the Pittsburgh airport. 3. Eathorne checked in to the Chicago Marriott on September 28, 2002, at 12:16 p.m. (CST) 312. Eathorne claimed spousal meal expenses even though WWMA travel policy does not authorize such expenses: half of $73.00 Duplicate of 10/1/02 $36.50 $24.00 $23.50 $47.00 $131.00 313. Eathorne claimed a meal expense of $73.00 on the evening of October 3, 2002, after returning from Chicago. 314. Expenses not related to any conference function as outlined in findings 299 through 302 claimed by Eathorne totaled $983.15. [sic]. 315. At least part of the conference time was spent by Eathorne on tours of Chicago. a. 9/30/02 — 1:30 p.m.-4:30 p.m. 1. Eathorne and his wife also spent part of the morning at a buffet Eathorne, # 06 -053 Page 71 breakfast at the Inter - Continental Hotel. 2. Eathorne was not involved in any conference functions on September 30, 2002. b. 10/2/02 - 9:00 a.m. to 12:30 p.m. 316. There is no record of Eathorne attending any WEF conference function while in Chicago from September 28, 2002, to October 3, 2002. 317. Eathorne received a private pecuniary gain when he claimed expenses not related to the 2002 WEFTEC and for undocumented expenses. a. Non - conference expenses $983.15* b. Undocumented expenses $611.73 c. Room expenses $526.12 9/30/02 and 10/2/02 $2,121.00* *[[Respondent is deemed to have admitted the indicated amount. However, we determine that Respondent's total private pecuniary gain as to the 2002 WEFTEC Conference was $2,079.00. See, Discussion, infra.] 318. The 2003 WEFTEC Conference was held in Los Angeles, California, from October 11, 2003, until October 16, 2003. a. Eathorne and his spouse traveled to the conference site at WWMA rate payer expense. 1. All expenses incurred, with the exception of spousal airfare, were paid using WWMA funds. b. WWMA manager Barry Riley also was registered to attend. 319. Eathorne received a $2,500.00 advance to attend the conference. a. WWMA check no. 30889 was issued to Eathorne on October 9, 2003. 1. Eathorne signed the check in his position as WWMA treasurer. b. The check was deposited to Eathorne's National City Bank account on October 9, 2003. 320. Eathorne was not registered to attend any conference seminar or official events. 321. Eathorne submitted an expense report to the WWMA claiming expenses totaling $3,009.86 and seeking an additional $509.86 payment from the WWMA. 322. Eathorne's expense report claimed expenses as follows: a. b. c. d. e. f. g. Mileage to /from airport 90 miles at .365 mi* Parking Airport Auto Rental Hotel & meals Airfare Taxi Meals (14 generic receipt stubs) $ 32.40* $ 51.66 $ 376.66 $1,898.14 $ 223.50 $ 35.00 $ 392.50 Date Receipt No. Amount 10/11/03 287358 $ 25.50 10/11/03 79274 $ 30.00 10/12/03 79271 $ 32.00 10/12/03 98232 $ 26.00 10/13/03 64190 $ 21.00 Eathorne, # 06 -053 Page 72 $3,009.86 *[We note a forty -five cent discrepancy in the calculation of the expense for mileage.] 323. Eathorne and his wife stayed at Ritz Carlton Hotel, Huntingdon /Passadena, CA, arriving on October 11, 2003, and checking out on October 17, 2003. a. Itemized expenses from Eathorne's hotel bill confirmed the following: 10/11 to 10/17 Room & Tax $257.69 x 6 $1,546.14 10/11 to 10/17 Parking $ 126.00 10/11 Ritz Bar $ 55.00 10/13 Terrace Dinner $ 120.00 10/15 Terrace Lunch $ 51.00 Total $1,898.14 324. Eathorne rented a vehicle from National Car Rental at the Los Angeles International Airport. a. The vehicle was picked -up on October 11, 2003, at 11:41 a.m. (PST) and returned on October 17, 2003, at 5:50 a.m. (PST). b. Total miles driven during the week were 166. c. Costs for the rental totaled $376.66. d. Eathorne claimed this expense as part of his conference expenses. e. The rental vehicle was used to travel from and to the airport as well as sightseeing trips taken by Eathorne. 1. Shuttle service was available to the hotel from the airport. 325. Eathorne also claimed a $35.00 cab fare on October 12, 2003, from the Westin Hotel to the Ritz Carlton. a. The conference provided free bus service daily between hotels. b. Shuttle service ran every twenty minutes. 326. As he did with every other WEFTEC conference he attended, Eathorne submitted fourteen "generic receipt stubs" totaling $385.50* to validate meal expenses as required by WWMA policy. 10/14/03 140648 $ 23.00 10/15/03 500461 $ 35.00 10/15/03 65911 $ 21.00 10/15/03 777119 $ 23.00 10/15/03 257833 $ 25.00 10/16/03 150594 $ 65.00 10/16/03 * *317956 $ 15.00 10/17/03 34302 $ 30.00 10/17/03 264733 $ 15.00 Eathorne, # 06 -053 Page 73 *[sic]. [There is a $1.00 discrepancy, to Respondent's advantage, in the amount above as compared to the sum of the amounts in the chart.] 327. Receipt stubs submitted by Eathorne to justify the advance and to seek additional reimbursement are parts of sequences and identical in format and style as other receipts submitted by Eathorne for other events. Receipt No. 79269 79271* 79272 79273 79274* 79275 500461* 500579 65906 65911* 317956* 317957 *Refers to 2003 WEFTEC Event 2005 PMAA 2003 WEFTEC 2005 PMAA 2006 Pumper Expo 2003 WEFTEC 2005 WEFTEC 2003 WEFTEC 2005 WEFTEC 2006 Pumper Expo 2003 WEFTEC 2003 WEFTEC 2001 WEFTEC 328. Upon returning to the Pittsburgh area on October 17, 2003, Eathorne claimed a $29.00 meal expense at the Robinson Township Olive Garden. 329. Eathorne received WWMA check no. 31167 in the amount of $418.81 on December 16, 2003, for additional expenses related to the California trip. a. Eathorne claimed $509.87 but $91.05 was deducted as a result of overpayment to Eathorne by the WWMA for a prior conference. 330. No record exists of Eathorne attending any conference - related event. 331. Eathorne received a private pecuniary gain of at least $3,009.86 when he claimed expenses paid by WWMA but did not attend any conference - related events. 332. The 2004 WEFTEC Conference was held at the Ernest N. Morial Convention Center in New Orleans, Louisiana from October 2, 2004, through October 6, 2004. a. Eathorne, accompanied by his wife, was one of the WWMA officials registered to attend. Eathorne, # 06 -053 Page 74 333. Eathorne and his wife pre- registered for conference activities on or about July 2, 2004. a. The registration fees paid on behalf of Eathorne included: One Day Expo - Monday Spouse Lifestyle Program b. The expenses were charged to a WWMA American Express card issued to Manager Barry Riley. 334. Eathorne received an advance of expenses in the amount of $2,500.00 by WWMA check no. 32518 on September 28, 2004. a. Eathorne signed the check as WWMA Treasurer. b. The check was deposited to Eathorne's checking account at National City Bank on September 28, 2004. 335. Airfare for Eathorne in the amount of $216.30 was charged to a WWMA American Express credit card issued to Barry Riley, WWMA Manager. a. In addition to the airfare, additional charges to Riley's credit card, on behalf of Eathorne and his wife, included flight insurance, baggage insurance, and travel delay insurance at the following costs. Flight 2 $8.99 Baggage @ $9.95 Travel Delay 2 @ $9.95 $ 50.00 $ 100.00 $ 150.00 $ 17.98 $ 19.90 $ 19.90 $ 57.78 b. WWMA check no. 32318 was issued to American Express on September 19, 2004, and included payments for Eathorne's airfare, insurances, and spousal programs. 1. Eathorne signed the check as WWMA Treasurer. 336. Eathorne and his wife were scheduled to travel to and from New Orleans as follows: 10/2/04 Depart Pittsburgh Arrive New Orleans 10/6/04 Depart New Orleans Arrive Pittsburgh 9:30 a.m. 10:55 a.m. 11:40 a.m. 2:50 p.m. 337. Advances and expenses paid to or for Eathorne prior to the conference totaled $2,924.18. 338. No record exists of Eathorne registering for, or attending any conference - related activities. a. Records are not maintained for expo hall attendance. 339. Eathorne and his wife were registered to stay at the Fairmont Hotel, 123 Baronne Street, New Orleans, LA. a. Eathorne checked in on October 2, 2004, and departed on October 7, 2004. Eathorne, # 06 -053 Page 75 b. Actual Expo date for Eathorne was Monday October 4, 2004. 340. Charges incurred following: a. Room: 10/02/04 10/03/04 10/04/04 10/05/04 10/06/04 b. Meals: 10/02/04 10/03/04 10/04/04 10/05/04 10/05/04 10/07/04 10/03/04: 10/04/04: 10/05/04: 10/06/04: 10/07/04: to Eathorne's room account at the Fairmont included the In -room Dining Sazerac Sazerac Sazerac Fairmont Court Sazerac Total Bill c. Eathorne paid the bill using his National City Bank debit card. 341. Eathorne submitted an expense report to the WWMA claiming expenses in justification of the $2,500.00 advance he received: Hotel Parking airport 10/02/04 to 10/07/04 Mileage 135 @ .345/mi Meals 10/02/04 to 10/07/04 10/02/04: Breakfast Lunch Dinner Breakfast Lunch Dinner Breakfast Lunch Dinner Breakfast Lunch Dinner Breakfast Lunch Dinner Breakfast Lunch Dinner TOTAL $ 226.87 $ 226.87 $ 226.87 $ 226.87 $ 226.87 $1,134.35 $ 49.16 $ 43.00 $ 49.00 $ 22.00 $ 40.00 $ 19.00 $ 222.16 $1,356.51 $1,356.51 $ 42.88 $ 46.57 Hotel $ 21.00 $ 55.00 $ 19.00 Hotel HDR $ 25.00 Hotel $ 61.50 Hotel Hotel $ 110.00 $ 39.00 $ 210.00 Hotel $ 16.37 $ 167.84 $ 724.71 Date Stub No. Amount Eathorne's Reference 10/04/04 783365 $ 61.50 Dinner Undated 783368 $ 39.00 Lunch (10/6) Undated 783375 $ 21.00 Lunch (10/2) 10/04/04 783377 $ 25.00 Breakfast 10/05/04 783378 $ 110.00 Dinner Undated 783379 $ 19.00 Breakfast (10/3) Eathorne, # 06 -053 Page 76 Hotel refers to meals charged to Eathorne's hotel bill. HDR refers to meals purchased by WWMA's engineer. Cab Service: $ 26.50 $ 22.50 $ 55.00 $ 23.00 $ 55.00 $ 25.00 $ 233.00* All of the cab receipts are made out in Eathorne's handwriting. Bus shuttle service at no cost was provided during the conference. The receipts were distributed by vendors who had booths at the conference exhibitor hall. *[sic]. [There is a $26.00 discrepancy in the calculation.] 342. Eathorne also claimed undocumented tips totaling $120.00. a. The maximum allowed per WWMA travel policy is $25.00. 343. Total expenses claimed by Eathorne for his trip to New Orleans was $2,523.67. a. This did not include airfare, flight insurance, and programs /tours. 344. In justification of meal expenses claimed on his expense report, Eathorne submitted "generic receipt stubs" totaling $724.71. a. The stubs are made out in Eathorne's handwriting. b. None of the stubs identify a restaurant or meals purchased. c. Eathorne generally did not purchase meals at WEFTEC conferences. 1. Eathorne typically ate meals provided by vendors through vendor hospitality suites. 2. Meals were also purchased using the WWMA credit card of Barry Riley. 345. Eathorne claimed a $55.00 dinner expense on October 2, 2004. a. Eathorne's meal was actually purchased by WWMA accountant, John Sarp. 346. Eathorne submitted six (6) generic receipt stubs which are identical in format and within a sequence of fourteen(14) numbers from the same receipt book. Stub Number Date Amount 10/02/04 435178 $ 55.00 Undated 130867 $ 167.84 Undated 824620 $ 16.37 10/06/04 717175 $ 210.00 Eathorne, # 06 -053 Page 77 347. Other generic receipts submitted by Eathorne included the following: 348. Receipt stubs submitted by Eathorne were parts of sequences of identical stubs used by Eathorne for other conferences. Stub Event 717708 2001 Fall PMAA 71715 2004 WEFTEC 717716 2001 WEFTEC 717717 2001 WEFTEC 824620 2004 WEFTEC 824624 2005 ALOM 824633 2001 ALOM 349. Eathorne claimed mileage for the trip from his home to the Pittsburgh Airport and return at 135 miles. a. Google Maps and Rand McNally computations determine the actual miles as: 1. Google 34.9 one way total 69.8 miles 2. Rand McNally 42 miles one way total 84 miles 350. Eathorne over - billed the WWMA for mileage to and from the airport: Miles claimed 135 at .345 miles Actual mileage 84 at .345 miles $46.57 $28.95 $17.59 351. Eathorne realized a private pecuniary gain of at least $1,339.16* as a result of claiming the following: Meals /generic receipts $724.71 Excess Tips $ 95.00 Spouse Lifestyle $100.00 Luggage /Flight insurance $ 57.78 Cab Expenses $233.00* Mileage $ 17.59 1/2 Hotel meals (spouse) $111.08 *[Respondent is deemed to have admitted the indicated amounts. However, we determine that Respondent's total private pecuniary gain as to the 2004 WEFTEC Conference was at least $1,313.16. See, Discussion, infra.] 352. No record exists of Eathorne attending any conference related event. a. Eathorne was only registered for a one day expo. b. Nightly room expenses were $226.87. Tour Description Time Cost Quantity Total Sunday, October 30 Mount Vernon 8:30a.m.- 12:30p.m. $36.00 2 $72.00 Monday, October 31 Welcome to Washington - AM 9:30a.m.- 12:00noon $28.00 2 $56.00 Tuesday, November 1 Hillwood Estate 1:30p.m. — 4:30p.m. $40.00 2 $80.00 Tuesday, November 1 National Cathedral 8:30a.m. — 11:30a. m. $38.00 2 $76.00 Wednesday, November 2 Old Town Alexandria /Optional Shopping 8:30a.m.- 2:30p.m. $44.00 2 $88.00 Total $372.00 Eathorne, # 06 -053 Page 78 c. Eathorne could have completed his conference attendance after one day. 353. The 2005 WEF Conference was held in Washington, DC, from October 29, 2005, until November 1, 2005. a. Eathorne and his wife were registered to attend the event. 354. Registration for Eathorne's attendance at the Conference was made by the Assistant Secretary /Treasurer Barbara Balcerek. a. The registration fees were charged to the Authority American Express credit card assigned to Barbara Balcerek. b. Authority check #33624, dated May 19, 2005, in the amount of $1,675.61, was issued to American Express in payment of (in part) the registration fees. c. This included spousal lifestyle program of $100.00. 355. Attendees were provided with the opportunity to register for sightseeing tours offered during the course of the convention. a. Fees associated with the tours were charged to the Authority American Express credit card assigned to Assistant Secretary /Treasurer Barbara Balcerek. b. Balcerek completed the sightseeing tour registration forms based on information provided by Eathorne. 356. The cost to the Authority for the sightseeing tours for Eathorne and his wife totaled $372.00. 357. Eathorne received a $2,500.00 advance of expenses by WWMA check no. 34485 on September 27, 2005. Eathorne, # 06 -053 Page 79 a. Eathorne signed the check as WWMA treasurer. b. The check was deposited to Eathorne's National City Bank account. 358. Eathorne and his wife were registered to stay at the Churchill Hotel, 1914 Connecticut Avenue, NW, Washington, DC. a. Eathorne is confirmed as checking in on October 29, 2005, at 3:08 p.m. and checking out on November 2, 2005, at 3:48 p.m. 359. Eathorne's hotel bill for the Churchill included the following expenses: a. Room & Tax 10/29/05 10/30/05 10/31/05 11/01/05 b. Parking 10/29/05 10/30/05 10/31/05 11/01/05 c. Meals 10/29/05 10/30/05 10/30/05 10/31/05 d. Bar $234.73 $234.73 $234.73 $234.73 $938.92 $ 28.00 $ 28.00 $ 28.00 $ 28.00 $112.00 $ 56.00 $ 24.00 $ 40.00 $ 8.00 $128.00 10/29/05 $ 73.00 Total $1,251.92 360. Eathorne submitted an expense report to the WWMA claiming the following expenses: a. Mileage 750 mi at .485/mi $ 363.75 b. Hotel $1,251.92 Tips $ 39.00 $1,290.00* c. Cab Fares 4 at $19.50 $ 78.00 1 at $20.00 $ 20.00 $ 98.00 d. Meals 10/29/05 Breakfast $ 40.00 10/30/05 Eathorne, # 06 -053 Page 80 Dinner $ 110.00 10/31/05 Breakfast $ 30.00 11/01/05 Breakfast $ 44.00 Lunch $ 25.00 Dinner $ 35.48 11/02/05 Breakfast $ 32.00 Lunch $ 70.00 Dinner $ 108.00 11/03/05 Breakfast $ 36.50 $ 454.48 Total $2,283.65* *[sic]. [There is a ninety -two cent discrepancy in this calculation. However, the discrepancy is not within the indicated total of $2,283.65.] 361. Eathorne submitted generic receipt stubs to justify meal expenses claimed on the WWMA expense report. Receipt Stub Date Amount 807583 10/29/05 $ 40.00 1137384 10/30/05 $110.00 500579 10/31/05 $ 30.00 960732 11/01/05 $ 44.00 79275 11/02/05 $108.00 633431 11/02/05 $ 32.00 Receipt no. 500579 is identical in format and manufacturer to Receipt no. 500461 submitted by Eathorne when attending the 2003 WEFTEC. Receipt no. 79275 is identical in format and manufacturer and in the exact sequence as stubs 79269, 79271, 79272, 79273, and 79274 that Eathorne used to justify expenses for conferences in 2003, 2005, and 2006. Receipt no. 633431 is identical in format and manufacturer and part of the sequence of numbers of stubs used by Eathorne when justifying meal expenses in 2001 (WEFTEC) and 2005 (PMAA): Stub No. Events 633415 2005 PMAA 633421 2001 WEFTEC 362. Eathorne claimed dinner expenses each night he was in Washington. a. Eathorne generally had dinners provided to him and his wife by convention vendors in the form of either hospitality suites or dinners paid by vendors. b. Eathorne claimed dinner expenses using receipt stubs totaling $253.48. 363. Eathorne claimed a breakfast expense of $36.50 on November 3, 2005, one day after the conference ended. a. The expense claimed occurred on November 3, 2005, at 1:20 p.m. at a Waffle House in Frederick, MD. Eathorne, # 06 -053 Page 81 b. The actual debit from Eathorne's National City Bank account was $31.50. c. Eathorne checked out of the hotel on November 2, 2005, at 3:48 p.m. 364. Eathorne issued personal check no. 1364 in the amount of $215.35 to the WWMA on December 13, 2005, as repayment of advance expenses for the 2005 WEF Conference. 365. The 750 miles claimed by Eathorne to travel from his home in Washington, DC and return was 215 miles more than the next highest WWMA board member claimed for the same trip. a. Other mileage claimed by board members: Thornton 452 Sarp 475 Balcerek 523 Zentner 535 b. MapQuest and Rand McNally have computed the mileage from Eathorne's home to hotel as follows: MapQuest 217 miles Rand McNally 237 miles c. Based on the mileage computations Eathorne over - charged the WWMA for mileage by at least 270 miles (750 -480). d. Eathorne did take a side trip to Anapolis, MD while traveling at WWMA expense. e. Eathorne's over charge of the WWMA resulted in an overpayment to him of $130.95 (270 mi at .485/mi). 366. WEF Conference records confirm Eathorne was not registered for any conference related events. a. Eathorne's sole conference - related activity was registration to tour the Expo Hall. b. The bulk of Eathorne's time was spent taking tours of the Washington, DC area. 10/30/05 10/31/05 11/1/05 11/2/05 8:30 a.m.— 12:30 p.m. 9:30 a.m. — 12:00 p.m. 8:30 a.m. — 11:30 p.m. 1:30 p.m. — 4:30 p.m. 8:30 a.m. — 2:30 p.m. 367. WWMA paid fees and advances to or for Eathorne totaling $2,972.00 as follows: Spouse lifestyle $ 100.00 Tours $ 372.00 Advance $2,500.00 $2,972.00 Eathorne, # 06 -053 Page 82 368. Eathorne realized a private pecuniary gain of $2,756.65 as a result of him not attending the 2005 WEFTEC and claiming expenses and /or having expenses paid on his behalf not related to any conference activity. Total payments Repayment by Eathorne a. Hotel: Embassy Suites b. Parking (Airport) $2,972.00 $ 215.35 $2,756.65 369. Eathorne traveled to the 2006 WEF Conference held in Dallas, TX, from October 21, 2006, through October 25, 2006. a. Eathorne's wife accompanied him on this trip. b. Eathorne traveled to Dallas 20 days after returning from the 2006 PMAA Conference. 370. Airfare for Eathorne totaling $304.61 was paid by a WWMA credit card. a. The WWMA also charged Patricia Eathorne's flight totaling $304.61. b. Patricia Eathorne issued a personal check to WWMA in the amount of $299.60 for her flight. 371. Eathorne was registered for the Expo only full week option portion of the conference and a tour of a Wastewater Treatment Plant. a. Costs included: Expo $135.00 Tour $ 40.00 $175.00 372. Eathorne requested and received a $2,000.00 advance to travel to Dallas. a. WWMA check no. 35661 in the amount of $2,000.00 was issued to Eathorne on October 19, 2006. 1. Eathorne signed the check as WWMA treasurer. 2. The check was deposited to Eathorne's National City Bank account on October 19, 2006. 373. Eathorne did not submit a travel expense to the WWMA documenting expenses to justify the $2,000.00 advance payment. 374. Eathorne's personal records for the trip to Dallas confirm the following expenses: $629.60 $ 45.51 $675.11 375. Eathorne's bank statements for debit card usage reflect no other expenditures during the time period of the Dallas trip. 376. No record exists of Eathorne attending any conference related functions other than the Expo. Eathorne, # 06 -053 Page 83 377. Eathorne received a private pecuniary gain of $2,299.60 as a result of advances and airfare paid on his behalf to travel to Texas. a. This includes the advance and airfare charge of $299.60. 378. Eathorne realized a private pecuniary [gain] of $14,138.27* by claiming /receiving expenses for events not attended, for overcharging the WWMA, and for expenses related to his spouse: 2001 $2,612.00 2002 $2,121.00* 2003 $3,009.86 2004 $1,339.16* 2005 $2,756.65 2006 $2,299.60 *[Respondent is deemed to have admitted the indicated amounts. However, we determine that Respondent's total private pecuniary gain as to WEFTEC events was $14,070.27. See, Discussion, infra.] 379. Eathorne attended a Pumper & Cleaner Environmental EXPO held in Nashville, TN, from February 15, 2006, through February 19, 2006. a. Eathorne's wife accompanied him on this trip. b. Eathorne was the only WWMA board member to travel to Nashville. c. This Expo is similar to WEF. 380. Eathorne received a $2,500.00 advance of expenses by WWMA check no. 34945 dated February 7, 2006. a. Eathorne co- signed the check. b. The check was deposited to Eathorne's account at National City Bank on February 8, 2006. 381. Eathorne was registered to stay at the Sheraton, Music City, Nashville. a. Eathorne checked in at 5:55 p.m. on February 14, 2006, and checked out on February 19, 2006. 382. Sheraton Guest invoice no. 103240 for Eathorne confirmed charges to the account as follows: a. Room & Tax 2/14/06 $137.10 2/15/06 $137.10 2/16/06 $137.10 2/17/06 $137.10 2/18/06 $137.10 Total $685.50 b. Meals — Old Hickory Grill 2/14/06 $ 91.00 2/17/07 $ 31.00 2/18/07 $ 57.11 Eathorne, # 06 -053 Page 84 c. The bill was paid with Eathorne's National City Bank debit card. 383. Eathorne submitted a travel expense report to the WWMA in justification of the $2,500.00 advance and to seek additional reimbursement. a. Hotel b. Tips c. Meals Total 2/14/06 (2 meals) 2/15/06 (3 meals) 2/16/06 (3 meals) 2/17/06 (2 meals) 2/18/06 (2 meals) 2/19/06 (3 meals) d. Mileage 1330 at .445/mi $179.11 $864.61 $864.61 $120.00 $ 78.00 $120.00 $169.00 $181.00 $174.00 $208.00 $930.00 $591.85 e. Total claimed $2,506.46 384. Eathorne received WWMA check no. 35091 in the amount of $6.46 on March 9, 2006. a. Eathorne signed the check as WWMA treasurer. 385. Of the meal receipts submitted by Eathorne, two were from legitimate restaurants and the remaining thirteen (13) stubs totaling $845.00 were in the form of the generic stubs regularly utilized by Eathorne as justification for expenses. a. The two restaurant receipts were: 2/15/06 Scorecard $46.00 Nashville, TN 2/19/06 Texas Roadhouse $39.00 Morgantown, WV 386. The $845.00 in meal expenses claimed by Eathorne was done by submitting the following generic receipt stubs: Stub No. Date Amount 65621 2/14/06 $ 40.00 65906 2/14/06 $ 38.00 471734 2/15/06 $ 31.00 843001 2/15/06 $ 43.00 317953 2/16/06 $ 31.00 51894 2/16/06 $ 36.00 936435 2/16/06 $102.00 405244 2/17/06 $ 51.00 79273 2/17/06 $130.00 464097 2/18/07 $ 29.00 65336 2/18/06 $145.00 65333 2/19/06 $134.00 Eathorne, # 06 -053 Page 85 65638 2/19/06 $ 35.00 $845.00 387. Seven (7) of the generic receipt stubs totaling $558.00 submitted by Eathorne are identical in format, manufacturer, and are parts of sequences used by Eathorne or other WWMA officials for prior travel. a. Stub no. 51894 is identical to stub no. 51893 submitted by Eathorne as part of his trip to Atlanta for the 2001 WEFTEC. b. Stub no. 65333 and 65336 are identical in format and manufacturer and are in a sequence of numbers used by Eathorne for other conferences: 65329 2005 PMAA 65340 2001 WEFTEC c. Stub no.'s 65621 and 65638 are identical in format and manufacturer and are in a sequence of numbers used by Eathorne for prior conferences: 65622 2001 PMAA 65624 2001 PMAA 65628 2002 WEFTEC 65633 2001 WEFTEC 65634 2001 PMAA 65636 2001 PMAA d. Stub no. 65906 is identical in format, manufacturer and sequence to stub no. 65911 used by Eathorne for the 2003 WEFTEC. e. Stub no. 79273 is identical in format, manufacturer and sequence to the following used by Eathorne for other conferences: 79269 2005 PMAA 79271 2003 WEFTEC 79272 2005 PMAA 79274 2003 WEFTEC 79275 2005 WEFTEC 388. Eathorne claimed tips of $120.00 for his trip to Nashville. a. WWMA maximum is $25.00. b. Eathorne submitted no justification for the tips. 389. Eathorne claimed mileage of 1,330 miles for his trip to Nashville. a. Round trip mileage from Eathorne's home to the hotel is 1,180. b. Eathorne over - billed the WWMA for mileage by at least $66.75 (150 at .445/mi). 390. Eathorne realized a private pecuniary gain when he used WWMA advance funds to pay for spousal expenses, when he did not document actual meal expenses, and when he overcharged the WWMA for mileage: Undocumented $845.00 Generic receipts Eathorne, # 06 -053 Page 86 Spousal meals $ 42.50 (from receipts, half of $85.00) Mileage Hotel meals, half of $179.11 $ 66.75 $ 89.55 $1,043.80 391. Eathorne attended the 2006 annual Technical Conference (PENNTEC) of the Pennsylvania Water Environment Association (PWEA). a. The conference was held in State College, PA, from Sunday, July 16, 2006, until Wednesday morning July 19, 2006. 392. The Conference itinerary included the following: 7/16/06 9:00 a.m. 1:00 p.m. — 5:00 p.m. 5:00 p.m. — 7:00 p.m. 7/17/16 [sic] 7:30 a.m. — 8:30 a.m. 8:30 a.m. — 11:30 a.m. 11:30 a.m. — 1:30 p.m. 1:30 p.m. — 4:30 p.m. 7:00 p.m. — 10:00 p.m. 7/18/06 7:30 a.m. — 8:30 a.m. 8:15 a.m. — 11:45 a.m. 11:45 a.m. — 1:30 p.m. 1:15 p.m. — 5:00 p.m. 6:00 p.m. — 9:00 p.m. 7/19/06 8:30 a.m. — 11:45 a.m. Education Sessions Golf Tournament Open Registration President's Reception Continental Breakfast Education Sessions PWEA Annual Business Meeting Education Sessions Annual Dinner and Awards Ceremony Continental Breakfast Education Sessions Complimentary Lunch Education Sessions Annual Social Mixer 393. The conference was held at the Penn Stater Conference Hotel. a. Room rates were $111.00 /per night for a single and $121.00 /per night for double occupancy. 394. On June 27, 2006, WWMA check no. 35103 in the amount of $490.00 was issued to the PWEA for the conference registration for Eathorne and Kevin Fisher. a. Eathorne's costs as a non - member were $260.00 while Fisher's total was $230.00. b. Eathorne co- signed the check. 395. Eathorne received an $800.00 advance of expenses by WWMA check no. 35157 dated July 11, 2006. a. Eathorne co- signed the check. Eathorne, # 06 -053 Page 87 b. The check was deposited to Eathorne's National City Bank account. 396. Eathorne did not submit a travel expense report to the WWMA following the trip. 397. Eathorne checked into the Penn Stater on July 16, 2006. a. The Hotel invoice confirmed the following expenses: 7/16/06 Room & Tax Gardens Restaurant $120.44 $ 19.30 $139.74 7/17/06 Room & Tax $120.44 7/18/06 Room & Tax $120.44 Total $380.62 398. Eathorne claimed or asserted no other expenses in relation to the 2006 PENNTEC Conference. a. Pursuant to a subpoena [served] by the Investigative Division of the State Ethics Commission, Eathorne provided a copy of a bank statement outlining total expenses of $380.62. 399. Eathorne realized a private pecuniary gain of $419.38 as a result of his use of his position to approve an advance of expenses of $800.00 and incurred expenses of $380.62. 400. Eathorne's use of the authority of his position to issue payments to him, claim bogus meal expenses, and approve spousal expenses for travel between the fall of 2001 through October 2006 resulted in a private pecuniary again of $21,563.87.* ALOM Events $ 2,676.84* PMAA $ 3,285.58 WEFTEC $14,138.27* PWEA $ 419.38 Pumper Expo $ 1,043.80 $21,563.87* *[Respondent is deemed to have admitted the indicated amounts. However, we determine that the total private pecuniary gain received by Eathorne was in the amount of $21,491.87. See, Fact Findings 148 and 278; Bartholomew, supra.] III. DISCUSSION: As a Member of the Western Westmoreland Municipal Authority ( "WWMA ") from July 18, 1996, until December 2006, Respondent Robert Eathorne, hereinafter also referred to as "Respondent," "Respondent Eathorne," or "Eathorne," was a public official subject to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa. C. S. § 1101 et seq. The allegations are that Eathorne violated Section 1103(a) of the Ethics Act when he used the authority of his public position when he authorized advances of expenses for his attendance at conferences and conventions and then claimed expenses in excess of Eathorne, # 06 -053 Page 88 actual expenses incurred; when he used expense advancements for expenses incurred by his spouse; when he authorized advance payments of expenses to him for conferences and convention - related events he did not attend; and when he authorized the use of a WWMA credit card for the payment of expenses and items of a personal nature for himself and his spouse. Pursuant to Section 1103(a) of the Ethics Act, a public official /public employee is prohibited from engaging in conduct that constitutes a conflict of interest: § 1103. Restricted activities (a) Conflict of interest. —No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 Pa.C.S. § 1103(a). The term "conflict of interest" is defined in the Ethics Act as follows: § 1102. Definitions "Conflict" or "conflict of interest." Use by a public official or public employee of the authority of his office or employment or any confidential information received through his holding public office or employment for the private pecuniary benefit of himself, a member of his immediate family or a business with which he or a member of his immediate family is associated. The term does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. 65 Pa.C.S. § 1102. Section 1103(a) of the Ethics Act prohibits a public official /public employee from using the authority of public office /employment or confidential information received by holding such a public position for the private pecuniary benefit of the public official /public employee himself, any member of his immediate family, or a business with which he or a member of his immediate family is associated. Preliminarily, we must address a procedural issue that has arisen regarding Respondent's failure to file a timely Answer to the Investigative Complaint. The pleading stage in this case began with the issuance of the Investigative Complaint on November 2, 2007. On its face, the Investigative Complaint stated that an Answer had to be received at this Commission within thirty (30) days of issuance. The Answer was due at this Commission by no later than December 3, 2007. In this case, an Answer was not timely filed. By faxed letter dated December 4, 2007, Chief Counsel notified Respondent's Counsel that an Answer had not been timely filed, such that Respondent had admitted the averments of the Investigative Complaint and waived a hearing. Chief Counsel indicated that the matter would be submitted to this Commission for disposition. Following the issuance of Chief Counsel's aforesaid letter, Respondent's Counsel Eathorne, # 06 -053 Page 89 filed an Application for Permission to File Answer to Investigative Complaint Nunc Pro Tunc ( "Application ") with an attached proposed Answer to the Investigative Complaint. Respondent's Application avers that as a result of an administrative error, the deadline to respond to the Investigative Complaint was inadvertently calculated as being December 5, 2007; that the filing of the Answer one day late would not prejudice any party to the action; and that a decision rendered on the merits would serve the best interest of both the parties and the public. On December 6, 2007, the Investigative Division filed a Response opposing Respondent's Application and asserting New Matter. The Investigative Division references Section 1108(e) of the Ethics Act and Section 21.5 of the Regulations of this Commission, which provide that a response must be filed within thirty (30) days of the issuance of the Findings Report unless the time period is extended by the Commission for good cause shown, and that matters not specifically denied in the response are deemed admitted. The Investigative Division cites various judicial decisions to support its position that the filing deadline is jurisdictional, and that this Commission may not grant Respondent's Application absent a showing of fraud, a breakdown in the administrative or postal process, incapacity, or other circumstances that are non - negligent in nature. The Investigative Division states that Respondent's failure to timely file an Answer to the Investigative Complaint was due to Respondent's or his counsel's error or omission, and that such is legally insufficient to form a basis for allowing Respondent to file his Answer Nunc Pro Tunc. On December 10, 2007, Respondent filed a Reply to New Matter, stating that Respondent's Counsel believed the Answer was due on or before December 5, 2007. Respondent asserts that if the standards for allowing an untimely appeal as enunciated in civil cases and criminal cases are read together, the principle emerges that an appeal Nunc Pro Tunc is intended as a remedy to vindicate the right to an appeal where that right has been lost due to certain extraordinary circumstances." Reply to New Matter, at paragraph 33. It is clear under the Ethics Act and Regulations that a response to the Investigative Complaint must be received within 30 days. 65 Pa.C.S. § 1108(e); 51 Pa. Code § 21.5(k). Cf., Criss v. Wise, 566 Pa. 437, 781 A.2d 1156 (2001). As noted above, even the face sheet of the Investigative Complaint states that an Answer must be received within 30 days. The Answer in this case was not timely received. In order for a late answer to be deemed timely filed, we apply the same civil standard as is applied by the courts to untimely appeals (see, Getz v. Pennsylvania Game Commission, 475 A.2d 1369 (Pa. Cmwlth. 1984) applying that standard in administrative proceedings to an untimely request for a hearing). See, e.q., Nagele, Order 1403; Hoover, Order 1402; Scales, Order 1394; Popkave, Order 1318. The standard is that to accept the untimely filing as if it were timely, there must either have been fraud or a breakdown in the administrative process (see, West Penn Power Co. v. Goddard, 460 Pa. 551, 333 A.2d 909 (1975); Bianco v. Robinson Twp., 556 A.2d 993 (Pa. Cmwlth. 1989)), which includes the postal process (Getz v. Pennsylvania Game Commission, supra), or there must have been unique and compelling factual circumstances establishing non - negligent failure to file timely (Grimaud v. Dep't of Env. Resources, 638 A.2d 299 (Pa. Cmwlth. 1994)). See also, Criss v. Wise, supra. Mere delays in the U.S. mail, even during a holiday season, are considered foreseeable and avoidable and are insufficient grounds to support an Application Nunc Pro Tunc. Criss v. Wise, supra. We reject Respondent's argument that criminal standards may be applied in this civil administrative proceeding, but in any event, Respondent's right to file an Answer to the Investigative Complaint was not lost due to extraordinary circumstances. None of the conditions for allowing the filing of a late Answer is present in this case. Eathorne, # 06 -053 Page 90 In fact, there has not been any allegation of fraud, any breakdown in the administrative process or the mail delivery system, or any unique and compelling factual circumstances that would establish a non - negligent failure to timely file. The only argument that has been proffered is that an Answer was not timely filed by Respondent because Respondent's attorney failed to accurately calculate the filing deadline. That argument presents no basis for allowing the filing of a late Answer. Baxter, Order No. 985. (Cf., In re Tenet Health Systems Bucks County, LLC, 880 A.2d 721 (Pa. Cmwlth. 2005) (Counsel's reliance upon erroneous version of statute as published in Purdon's Statutes when determining the deadline for appeal did not justify the filing of an appeal nunc pro tunc.). Parenthetically, we note that our Regulations allow for the filing of an application for an extension to file an Answer. 51 Pa.Code § 21.5(k). No such request was made in this case prior to the filing deadline. Respondent's Application for Permission to File Answer to Investigative Complaint Nunc Pro Tunc is denied. Having disposed of the procedural matter, we shall now summarize the facts pertaining to this case. Given Respondent's failure to file a timely Answer to the Investigative Complaint, the facts as averred by the Investigative Complaint are deemed admitted by Respondent. 65 Pa.C.S. § 1108(e); 51 Pa. Code § 21.5(k). Respondent Eathorne served as a Member of the WWMA from July 18, 1996, until December 2006. Eathorne served as Treasurer of the WWMA commencing February 17, 2000, through 2006. Eathorne's main function as Treasurer was to co -sign checks with assistant Secretary /Treasurer Barbara Balcerek (also referred to herein as "Balcerek "). Since at least 2001, WWMA Board Members and selected employees have regularly attended conferences, conventions, and seminars. Pursuant to WWMA travel policies in effect since 2000, any WWMA Board member, officer, manager, or solicitor was authorized, without further action of the Authority, to attend any convention, conference, seminar, or meeting of associations and organizations to which the WWMA belonged. WWMA travel policies provided that the Authority would reimburse the expenses for such functions, including registration fees, commercial travel and lodging arranged by the WWMA, mileage for a personal vehicle, meals, and all other actual expenses reasonably incurred in traveling to and attending such functions. Each attendee was authorized to incur miscellaneous, undocumented expenses to a maximum of $25.00 per function. Travel policies did not provide for the reimbursement of spousal and /or guest expenses. During the time period under review, the WWMA advanced some travel expenses directly to conference - related payees, such as conference hosts and hotels. WWMA travel policies also authorized an attendee such as Eathorne to request and directly receive an advancement for expenses, initially for up to $2,000 per function. An attendee who received an advancement of expenses was required to file an expense report with proper receipts, and failure to do so would result in the advancement being considered income for tax purposes. During his tenure on the WWMA Board, Eathorne consistently advocated for increased advance payments to Board Members for travel and argued against any attempts to restrict or put limits on Board Members' travel. On February 21, 2002, after questions had been raised regarding Board Member travel, the WWMA unanimously voted to approve a moratorium on all travel by Members to conferences and meetings until September 4, 2002. At the subsequent Board meeting held on March 21, 2002, Eathorne unsuccessfully attempted to rescind the moratorium. The WWMA lifted the moratorium in September 2002. Contemporaneously with the moratorium being lifted, Eathorne advocated an increase in the amount of expense advancements from $2,000 to $2,500. On September 19, 2002, a motion was approved by the WWMA Board to increase the amount of advance money from $2,000.00 to $2,500.00. Eathorne, # 06 -053 Page 91 Eathorne seconded the motion. The authorized amount for advance expenses for conference attendance has remained at $2,500 since September 19, 2002. During various 2006 WWMA Board meetings, Eathorne opposed recommendations by certain other WWMA Board Members to adopt stricter travel policies with spending limits and to invite this Commission to review expenses from a particular convention that had been attended by Eathorne. Eathorne co- signed all checks issued between 2001 and 2006 for advances and registration fees. See, Fact Findings 21 b 1; 34 b 1. The WWMA Board does not approve advance payments to Board members, review or approve Members' travel expense reports, or approve any expenses claimed by Board members. Travel expense reports are reviewed only by Balcerek. Balcerek does not challenge any expenses claimed by Board members. Board members have submitted receipts that have not been scrutinized or reviewed by anyone with authority to challenge individual claims. Eathorne, as a member of the WWMA, attended at least 30 conferences, conventions, and workshops between October 2001, and October 2006. The events under review in this matter were held by the following organizations: Allegheny League of Municipalities (ALOM); the Pennsylvania Municipal Authorities Association (PMAA); the Water Environment Federation (WEFTEC); and the Pennsylvania Water Environment Association (PWEA). Eathorne's spouse, Patricia Henrickson Eathorne, has accompanied Eathorne on all conferences attended by Eathorne. The majority of Patricia Eathorne's expenses incurred while accompanying Eathorne have been paid by the WWMA. Eathorne has paid for his spouse's airfare when attending WEFTEC conferences. Eathorne has directly received advances of expenses for conferences and /or conventions on a regular basis from August 2001 through 2006 as detailed in Fact Finding 41. These advances did not encompass all monies paid to Eathorne or on the Eathornes' behalf by the WWMA for expense claims made by Eathorne. The WWMA also advanced expenses for Eathorne's travel to conference hosts, hotels, airlines, and other providers. Eathorne was one of a group of Board Members who asserted that since they were not compensated as Board Members, they were entitled to claim, as expenses, all advance monies they received. Travel expense reports submitted by Eathorne included "generic" receipt stubs. Eathorne used these receipts to justify retaining entire advance expense payments that he had received. These stubs never identified a restaurant or location where expenses were allegedly incurred. They were often numbered sequentially, matching in style, format, and manufacturer. As detailed in Fact Finding 45, for the years 2001 through 2006, Eathorne submitted 134 generic receipt stubs claiming expenses totaling $7,148.62. As detailed in Fact Finding 46, many of these receipt stubs submitted by Eathorne, in his handwriting, were identical in format, numbered sequentially, and generated from a series of the same books. The pattern of using receipts identical in design and print and part of a sequence was a common occurrence for Eathorne when traveling at ratepayer expense and was done solely to inflate expenses in order to receive private pecuniary gain. Although our discussion will note some of the instances when sequential receipts were used by Eathorne, we shall not note them all. They are noted in detail in the Fact Findings. None of the generic receipt stubs submitted by Eathorne could be documented as expenses actually incurred for any conference - related purpose. Per the Fact Findings, deemed admitted, Eathorne typically did not go out for dinner when traveling to such Eathorne, # 06 -053 Page 92 conferences unless the meal was paid for by a third party. Eathorne did go to vendor hospitality suites where he was treated to drinks and food items, and Eathorne's wife would accompany him. Eathorne would go to these functions in lieu of purchasing dinner. With respect to the approximately (30) thirty events attended by Eathorne when he received an advance, he returned funds to the WWMA on only one occasion. We shall now review the facts pertaining to the various events in question. ALOM Events Between 2003 and 2006, Eathorne attended Spring and Fall conferences held annually by the ALOM at Seven Springs Resorts ( "Seven Springs ") in Champion, Pennsylvania. Eathorne's wife accompanied him to these conferences. For the 2003 ALOM Spring conference, the WWMA issued check number 29968 in the amount of $500.00 to Eathorne as an advance of expenses. Following the conference, Eathorne claimed and received an additional payment of $307.07 from the WWMA for conference expenses. The expenses claimed by Eathorne included his wife's expenses for a conference lodging and meal plan. Eathorne realized a private pecuniary gain when he utilized WWMA funds to pay for his wife's participation in the conference lodging and meal plan at a cost of $164.00. For the 2003 ALOM Fall conference, the WWMA issued check number 30806 in the amount of $800.00 to Eathorne as an advance of expenses. Eathorne signed the check as one of the authorized signatories. The check was deposited to Eathorne's National City Bank account on September 24, 2003. The expenses claimed by Eathorne and paid for by the WWMA included Eathorne's spouse's costs in the amount of $164 for the lodging and meal plan at the conference and an additional meal in the amount of $15.75. Additionally, Eathorne failed to return to the WWMA excess expense advancement funds in the amount of $91.05. Eathorne realized a private pecuniary gain when he claimed and received the aforesaid expenses for his spouse and an extra meal and when he failed to return excess expense funds to the WWMA. For the 2004 ALOM Spring Conference, the lodging and meal plan costs for Eathorne and his wife were included in a payment made directly by the WWMA to Seven Springs using WWMA check number 31615. Eathorne and the WWMA assistant secretary /treasurer co- authorized the check. The cost of Eathorne's wife's participation in the lodging and meal plan, paid by the WWMA through Eathorne's action, was $172.00. The conference was held from April 1, 2004, to April 4, 2004. Eathorne did not attend the conference on either April 1, 2004, or April 2, 2004. Eathorne checked into the hotel on April 3, 2004, and checked out on April 4, 2004. As calculated in Fact Findings 79 -80, Eathorne realized a private pecuniary gain in the amount of $538.00 when the WWMA incurred costs for his non - attendance at the ALOM function for two of the conference days. For the 2004 ALOM Fall Conference, the WWMA issued check number 32488 in the amount of $800.00 to Eathorne as an advance of expenses. Eathorne signed the check as one of the authorized signatories. The check was deposited to Eathorne's personal bank account on September 21, 2004. The conference expenses claimed by Eathorne and paid for by the WWMA included: (1) Eathorne's spouse's costs in the amount of $172.00 for the lodging and meal plan at the conference; (2) additional meals in the amounts of $40.00 for breakfast on September 23, 2004, $51.83 for dinner on September 23, 2004, and dinner in the amount of $60.00 on September 26, 2004; and (3) $5.00 in excess tips beyond the amount authorized by WWMA policies. Eathorne claimed breakfast expenses for September 23, 2004, even though the conference site, Seven Springs, was less than one hour of travel time away from his home Eathorne, # 06 -053 Page 93 and the conference did not begin until 7:30 p.m. on September 23, 2004. Eathorne claimed a dinner expense on September 23, 2004, even though dinner that evening was included as part of the conference lodging and meal plan. Eathorne claimed a dinner expense on September 26, 2004 - -the day the conference ended - -even though no conference events were scheduled on September 26, 2004, and Turnpike receipts submitted by Eathorne confirm that he exited the Turnpike and was less than fifteen minutes away from his residence by shortly after noon on September 26, 2004. Eathorne submitted generic receipts for two of the aforesaid claimed additional meal expenses and no receipt for the third claimed meal expense. The aforesaid amounts paid by the WWMA for Eathorne's spouse's expenses, claimed additional meals, and unauthorized tip expenses constituted a private pecuniary gain to Eathorne. For the 2005 ALOM Spring Conference, the WWMA issued check number 33437 in the amount of $800.00 to Eathorne as an advance of expenses. Eathorne signed the check as an authorized signatory. The check was deposited to Eathorne's personal bank account. Per the Fact Findings, deemed admitted, Eathorne used his public position to obtain a private pecuniary benefit in the amount of $357.47 when he claimed and received the following conference expenses paid for by the WWMA: (1) Eathorne's spouse's costs in the amount of $174.00 for the lodging and meal plan at the conference; (2) additional meals totaling $155.47 (detailed in Fact Finding 102 as $13.47, $20.00, and $65.00 for breakfast, lunch, and dinner on April 7, 2005, and $22.00 and $35.00 for lunch and dinner on April 10, 2005); and (3) $25.00 in excess tips beyond the amount authorized by WWMA policies. With regard to the claimed additional meal expenses, as noted above, travel time from Eathorne's home to the conference site, Seven Springs, was approximately one hour. Eathorne's home was less than one -half hour from the Irwin exit of the Pennsylvania Turnpike. The conference did not begin until 8:00 p.m. on April 7, 2005, and dinner that evening was included in the conference lodging and meal plan selected by Eathorne for himself and his wife. Nevertheless, Eathorne claimed breakfast, lunch, and dinner expenses for April 7, 2005, in the total amount of $98.47. Additionally, Eathorne claimed both lunch and dinner expenses totaling $57.00 on April 10, 2005, even though the conference concluded prior to 9:00 a.m. that date, and toll records confirm that Eathorne exited the Pennsylvania Turnpike at Irwin at 11:05 a.m. on April 10, 2005. Eathorne submitted generic receipts containing his handwriting as proof of his expenditures for the aforesaid additional meal expenses totaling $155.47. For the 2005 ALOM Fall Conference, the WWMA issued check number 34318 in the amount of $800.00 to Eathorne as an advance of expenses. Eathorne deposited the check in his personal bank account. Following the conference, Eathorne claimed and received an additional payment of $116.15 from the WWMA for conference expenses. This amount was paid to Eathorne by WWMA check number 33569. Eathorne realized a private pecuniary benefit in the amount of $389.50 when he claimed and received the following conference expenses paid for by the WWMA: (1) Eathorne's spouse's costs in the amount of $174.00 for the lodging and meal plan at the conference; (2) additional meal charges totaling $190.00 for a third person in Eathorne's party; and (3) a lounge charge in the amount of $25.50 for drinks not related to Eathorne's attendance at the conference. For the 2006 ALOM Spring Conference, the WWMA issued check number 35239 in the amount of $1,000.00 to Eathorne as an advance of expenses. Eathorne and the WWMA assistant secretary /treasurer signed the check as the authorized signatories. Eathorne deposited the check in his personal bank account. ALOM CONFERENCE PRIVATE PECUNIARY BENEFIT FACT FINDINGS Spring 2003 $164.00 64 -65 Fall 2003 $270.75 73 Spring 2004 $538.00 80, 80 a, 80 b Fall 2004 $328.83 92 (amount as adjusted) Spring 2005 $357.47 109 F a l l 2005 $389.50 123 Spring 2006 $407.29 139 F a l l 2006 $217.00 146 TOTAL $2,672.84 Eathorne, # 06 -053 Page 94 Eathorne received a private pecuniary benefit in the amount of $407.29 when he claimed and received the following conference expenses paid for using WWMAfunds: (1) Eathorne's spouse's costs in the amount of $174.00 for the lodging and meal plan at the conference; (2) claimed additional meals totaling $167.00 (detailed in Fact Findings 132 and 135 as $15.00 and $26.00 for breakfast and lunch on April 6, 2006, and $126.00 for dinner on April 9, 2006); (3) a lounge charge of $9.25; (4) $25.00 in excess tips beyond the amount authorized by WWMA policies; and (5) $32.04 in excess mileage. With regard to the claimed additional meal expenses, Eathorne claimed breakfast and lunch expenses totaling $41.00 for April 6, 2006, even though the conference did not begin until 8:00 p.m. that date, and Eathorne lived approximately one hour from the conference site. Eathorne claimed a $126.00 dinner expense for April 9, 2006, despite returning home from the conference site that day at approximately 1:00 p.m. Eathorne submitted generic receipts containing his handwriting as justification for the aforesaid additional meal expenses totaling $167.00. None of the receipts identified a restaurant or place of purchase. For the 2006 ALOM Fall Conference, the WWMA issued check number 35550 in the amount of $800.00 to Eathorne as an advance of expenses. Eathorne deposited the check in his personal bank account. Following the conference, Eathorne did not submit an expense report. Eathorne received a private pecuniary benefit in the amount of $217.00 when he received WWMA funds for conference expenses in excess of Eathorne's documented expenses in the amount of $583.00. Fact Finding 148 of the Investigative Complaint, which is deemed admitted by Respondent, provides that Eathorne realized a private pecuniary gain in the total amount of $2,676.84 as a result of his use of office to approve expenses for his wife and excess expenses for himself for ALOM events. Our calculation of Eathorne's private pecuniary benefit as to ALOM events is $2,672.84: Respondent will receive the benefit of the lower amount. Bartholomew v. State Ethics Commission, 795 A.2d 1073 (Pa. Cmwlth. 2002). PMAA Events Eathorne, as a WWMA member, has regularly attended various events hosted by the PMAA. Eathorne's wife has accompanied him at all such events. Eathorne approved all payments issued to him for travel - related expenses, including those of his spouse. WWMA travel policies do not permit payment of spousal expenses. The 2003 PMAA Annual Conference was held in Hershey, Pennsylvania from noon on Sunday, August 24, 2003, through breakfast on Wednesday, August 27, 2003. The Eathorne, # 06 -053 Page 95 conference location was at the Hershey Lodge and Convention Center. The conference included, inter alia, a banquet at a cost of $45.00 per person and a spouse /guest program. Eathorne's wife registered for the Monday spouse /guest program and the banquet. Costs for Eathorne's wife's participation in the Monday spouse /guest program and the banquet were paid directly by the WWMA. Eathorne, as a WWMA Board Member, requested and received an advance of expenses to attend the 2003 PMAA Conference. Authority check #301616 in the amount of $1,500.00 was issued to Eathorne on August 19, 2003. The check was deposited to Eathorne's account at National City Bank on August 19, 2003. Following the conference, Eathorne submitted an expense report to the WWMA claiming total expenses of $1,506.10 as detailed in Fact Finding 163. Eathorne included with the expense report three actual receipts and six generic receipt stubs in support of his expense claims. The generic receipt stubs were all made out in Eathorne's handwriting. None of the generic receipt stubs submitted by Eathorne identified a restaurant. Per Fact Finding 173, deemed admitted, Eathorne used the authority of his public position for private pecuniary gain in the amount of $635.83 when WWMA funds were used to pay for: (1) his wife's participation in the spousal program at a cost of $45.00; (2) his wife's attendance at the conference banquet at a cost of $45.00; (3) a breakfast in the amount of $13.11 for his wife; (4) Other meals for his wife in the total amount of $352.72; and (5) a claimed dinner expense (per a generic receipt) in the amount of $180.00 for August 27, 2003, after Eathorne had returned home from the conference. The 2004 PMAA Annual Conference was held at the Westin Hotel in Pittsburgh, Pennsylvania, from noon on Sunday, August 22, 2004, through breakfast on Wednesday, August 25, 2004. The conference included a banquet at a cost of $46.00 per person. Eathorne and his wife were both registered to attend the banquet. Charges for Eathorne's and his wife's participation in the banquet were paid directly by the WWMA. Eathorne requested and received an advance of expenses for the 2004 PMAA conference. WWMA check #32342 in the amount of $1,200.00 was issued to Eathorne on August 19, 2004. The check was deposited to Eathorne's account at National City Bank on August 20, 2004. Following the conference, Eathorne submitted an expense report to the WWMA claiming total expenses of $1,319.55 as detailed in Fact Finding 180. With the expense report, Eathorne submitted generic receipt stubs and a sham Holiday Inn receipt. The generic receipt stubs are detailed at Fact Finding 181 b. They were all made out in Eathorne's handwriting. None of the generic receipts submitted by Eathorne identified a restaurant. Eathorne claimed a breakfast of $15.83 on Sunday, August 22, 2004, even though conference registration did not begin until 12:00 noon and Eathorne resided approximately one hour from the conference site. Eathorne claimed a $150.00 dinner expense for August 22, 2004, using a generic receipt. Per the Fact Findings, the claimed expense was not related to the conference. Fact Finding 192. Eathorne claimed a breakfast expense of $48.00 on Monday, August 23, 2004, when breakfast had been provided as part of the $195.00 registration fee paid for Eathorne by the WWMA. Eathorne claimed a dinner expense of $150.00 on August 23, 2004, using a sham generic receipt. On August 23, 2004, Eathorne's and his wife's dinners were paid for by the WWMA engineer. This was also the same night for which Eathorne and his wife were registered to attend the banquet at WWMA expense. Eathorne submitted a sham Holiday Inn receipt claiming total expenses in the Eathorne, # 06 -053 Page 96 amount of $826.12. Eathorne actually stayed at the Westin Hotel while in Pittsburgh and incurred lodging expenses less than the $826.12 he claimed. Eathorne's National City Bank account confirms a debit at the Westin Hotel on August 24, 2004, in the amount of $703.50. Per Fact Finding 192, which is deemed admitted, Eathorne received a private pecuniary gain in the amount of $532.45 when he claimed and was reimbursed by the WWMA for the following claimed expenses not related to conference expenses: (1) a breakfast expense in the amount of $15.83 for August 22, 2004; (2) a dinner expense in the amount of $150.00 for August 22, 2004; (3) a breakfast expense in the amount of $48.00 for August 23, 2004; (4) A dinner expense in the amount of $150.00 for August 23, 2004; (5) the banquet charge for his wife in the amount of $46.00; and (6) excess hotel expenses in the amount of $122.62. The 2005 PMAA Conference was held at the Hershey Lodge and Convention Center from noon on Sunday, September 11, 2005, through breakfast on Wednesday morning, September 14, 2005. Check -in time on September 11, 2005, was after4:00 p.m. and check -out on September 14, 2005, was before 11:00 a.m. Eathorne's wife was registered to attend the banquet at a cost of $49.00. Eathorne and his wife were both registered to attend the Monday spouse /guest program at a cost of $40.00 per person. Registration fees for Eathorne and his wife were paid by directly by the WWMA. Eathorne and Board Member Zentner registered for the golf outing on September 11, 2005, at Parkview Golf Course at a cost of $70.00 each. Authority check #33996 dated September 21, 2005, was issued in the amount of $140.00 to pay for the golf outing. Eathorne received an advance of expenses in the amount of $1,200.00 for the 2005 PMAA conference. WWMA check #34205 was issued to Eathorne. Eathorne co- authorized the payment. Check #34205 was deposited to Eathorne's checking account at National City Bank. Following the conference, Eathorne submitted an expense report to the WWMA. With the expense report, Eathorne submitted generic receipt stubs as detailed in Fact Finding 208. No restaurant receipts were submitted by Eathorne for any meal expenses claimed. All of the generic receipt stubs were in Eathorne's handwriting. None of them identified a restaurant. Per Fact Finding 216, which is deemed admitted, Eathorne received a private pecuniary gain in excess of $700 when WWMA funds were used to pay for the following expenses: (1) guest tours for Eathorne and his wife totaling $80.00; (2) the banquet charge for Eathorne's wife in the amount of $49.00; (3) Eathorne's golf fee of $70.00; (4) a gift shop charge of $5.25; (5) breakfast expenses for September 11, September 12, and September 14, 2005, in the total amount of $93.00; (6) a breakfast charge for September 13, 2005, in the amount of $31.00; (7) two breakfast charges at $19.00 each, for a total of $38.00; (8) a lunch expense for September 13, 2005, in the amount of $69.00, when lunch had been provided as part of the PMAA program; (9) meal expenses in the amount of $110.15 for September 11, 2005, a portion of which expenses were for Eathorne's spouse; and (10) lunch and dinner expenses for Eathorne and his wife in the amount of $165.00 for September 14, 2005, after the conference had ended. Eathorne returned to his home shortly after 3:30 p.m. on September 14, 2005, yet claimed dinner for himself and his wife. With regard to the breakfast expenses, it is noted that Eathorne claimed breakfasts and lunches for himself and his wife totaling $64.00 on September 11, 2005. Eathorne claimed this amount even though conference registration did not begin until 12:00 noon and hotel check -in was 4:00 p.m. or later. Eathorne's breakfast expenses for September Eathorne, # 06 -053 Page 97 12, 2005, September 13, 2005, and September 14, 2005, were provided as part of the registration or were previously paid by the WWMA. When PMAA notified WWMA that an additional $57.00 was owed as a result of Eathorne, his wife, and one other unidentified person participating in the family breakfast on the last day of the conference (September 14, 2005), the WWMA issued check #34314, dated September 27, 2005, in the amount of $57.00 to PMAA in payment of the invoice. Eathorne co- signed the check along with the assistant secretary/treasurer. No other Board Member approved the expenditure. The 2006 PMAA Conference and Trade Show was held at the Hershey Lodge and Convention Center from September 10, 2006, to September 13, 2006. Eathorne was registered to stay at the Hershey Lodge and Convention Center. Check -in time was after 4:00 p.m. on September 10, 2006. Check -out time was before 11:00 a.m. on September 13, 2006. The WWMA directly paid registration fees, room deposits, and banquet charges for Eathorne and his wife. The banquet charges for the Eathornes totaled $98.00. Eathorne received an $800.00 advance of expenses by a WWMA check dated September 7, 2006. The check was deposited to Eathorne's account at National City Bank on September 5, 2006. Eathorne did not submit a travel expense report to the WWMA detailing expenses related to the $800.00 advance. Eathorne's only documented expense for this trip to Hershey was the balance owed for the room expense, which was in the amount of $359.70. Per Fact Finding 226, which is deemed admitted, Eathorne received a total private pecuniary gain of $489.30 as a result of not refunding the difference between the advance of $800.00 and the actual expenses of $359.70, as well as the WWMA's payment of the $49.00 banquet charge for Eathorne's spouse. Eathorne regularly received expense monies from the WWMA for attendance at PMAA Region 9 dinners, including dinners held on April 14, 2004, and November 5, 2005. Eathorne's wife accompanied him to these dinners. Dinners for Eathorne's wife were paid using WWMA funds. Eathorne approved the payments and signed checks authorizing payments. Eathorne realized a private pecuniary gain of $75.00 by using WWMAfunds to pay for PMAA Region 9 dinner expenses incurred by his spouse. PMAA has sponsored Legislative Days in Harrisburg, Pennsylvania, annually between 2001 and 2004. Eathorne received advances and claimed expenses for attendance at Legislative Day events in 2003 and 2004. For the May 13, 2003, Legislative Day, the WWMA issued check number 30119 in the amount of $700.00 to Eathorne as an advance of expenses. Eathorne co- authorized the check. On May 6, 2003, the check was deposited to Eathorne's account at National City Bank. The 2003 PMAA Legislative Day was a one -day event held at the Harrisburg Hilton. The event began the morning of May 13, 2003, with registration and a continental breakfast at 8:00 a.m., and concluded later that same day with a legislative reception ending at 6:30 p.m. A Harrisburg Hilton guest invoice confirms that Eathorne and another adult checked into the hotel on May 12, 2003, at 5:21 p.m. and departed on May 14, 2003. Eathorne submitted an expense report for the 2003 PMAA Legislative Day, claiming meal expenses in the amount of $196.00 as detailed in Fact Findings 238 and 239. Eathorne submitted generic receipts containing his handwriting as justification for the Eathorne, # 06 -053 Page 98 aforesaid additional meal expenses totaling $196.00. None of the receipts identified a restaurant. Based upon Fact Finding 242, which is deemed admitted, Eathorne received a private pecuniary gain in the amount of $171.00 when he claimed and received the following expenses paid with WWMA funds: (1) unspecified spousal expenses in the amount of $50.00; (2) the entire amount of a claimed lunch expense in the amount of $35.00 for May 12, 2003; (3) the entire amount of a claimed breakfast expense in the amount of $21.00 for May 13, 2003; and (4) the entire amount of a claimed dinner expense in the amount of $65.00 for May 14, 2003. With regard to the claimed additional meal expenses, Eathorne claimed lunch expenses in the amount of $35.00 for May 12, 2003, even though the 2003 PMAA Legislative Day function did not begin until 8:00 a.m. the following day. Eathorne claimed a breakfast expense in the amount of $21.00 for May 13, 2003, even though breakfast that day was paid as part of the registration for the event. Eathorne claimed a dinner expense in the amount of $65.00 for May 14, 2003, despite having returned from the event and exited the Pennsylvania Turnpike at approximately 3:22 p.m., at which time he was only 2.25 miles from his home. Eathorne attended the 2004 PMAA Legislative Day held in Harrisburg on May 11, 2004. Registration cost was $25.00 per person. On April 27, 2004, the WWMA issued check number 31770 in the amount of $75.00 to the PMAA to cover registration fees for Eathorne and two other individuals from the WWMA. The 2004 PMAA Legislative Day was a one -day event, which began the morning of May 11, 2004, with registration and a continental breakfast at 8:00 a.m., and concluded later that same day with a legislative reception ending at 7:00 p.m. Eathorne's wife accompanied him on the trip. Lodging was obtained at the Crowne Plaza Hotel. Eathorne checked in on May 10, 2004, and checked -out on May 12, 2004. Eathorne received a $700.00 advance from the WWMA on May 6, 2004. WWMA check number 31817 was issued to Eathorne. Eathorne co- authorized the issuance of the check. The check was deposited into Eathorne's checking account at National City Bank on May 6, 2004. Eathorne submitted an expense report for the 2004 PMAA Legislative Day, as detailed in Fact Finding 249. Eathorne submitted generic receipt stubs containing his handwriting as justification for claimed meal expenses that were not charged to his hotel room. None of the receipts identified a restaurant. Per Fact Finding 254, which is deemed admitted, Eathorne received a private pecuniary gain in the amount of $565.42 when he claimed and received the following expenses paid with WWMA funds: (1) claimed breakfast expenses in the total amount of $47.10 for May 10, 2004 ($22.10) and May 11, 2004 ($25.00); (2) other undocumented meal expenses in the total amount of $280.54; (3) $55.00 in excess tips beyond the amount authorized by WWMA policies; (4) movie charges totaling $28.61 ($14.84 plus $13.77); (5) lounge charges totaling $51.50 ($33.75 plus $17.75); (6) excess expense advance funds in the amount of $55.75; and (7) $46.92 for a mileage overcharge. With regard to the claimed meal expenses, Eathorne claimed a breakfast expense in the amount of $22.10 for May 10, 2004, even though the 2004 PMAA Legislative Day function did not begin until 8:00 a.m. the following day. Eathorne claimed a breakfast expense in the amount of $25.00 for May 11, 2004, even though breakfast that day was provided and included within the registration fee that had been paid directly by the WWMA. The remaining claimed meal expenses in the total amount of $280.54 were undocumented, supported only by Eathorne's own generic receipt stubs. PMAA EVENT PRIVATE PECUNIARY BENEFIT FACT FINDINGS 2003 PMAA Annual Conference $635.83 173 2004 PMAA Annual Conference $532.45 192 2005 PMAA Annual Conference $710.40 216 (amount as adjusted) 2006 PMAA Annual Conference $489.30 226 PMAA Regional Dinners $75.00 229 2003 Legislative Day $171.00 242 (amount as adjusted) 2004 Legislative Day $565.42 254 Administrative Issues Seminar $85.00 255 Over - Charged Mileage not included above $37.18 163, 206 (the over - charge for the 2004 PMAA Legislative Day is already included in the calculation for that event, see, Fact Finding 254.) TOTAL $3,301.58 Eathorne, # 06 -053 Page 99 Eathorne was registered to attend a PMAA sponsored seminar scheduled to be held at the Nittany Lion Inn in or about 2004. The costs associated with the event included $70.00 for the seminar; $60 for a golf outing; and $25.00 for a fall indoor picnic. The WWMA issued check no. 32483 directly to the PMAA, which payment included costs for Eathorne totaling $155.00. The Investigative Complaint includes the total amount of $155 in the calculation of Eathorne's private pecuniary benefit as to this PMAA event. However, we determine that the $70.00 payment for the seminar itself should not be included in the calculation. Per Fact Findings 256 a and b of the Investigative Complaint, deemed admitted, Eathorne's use of the authority of his position to claim spousal expenses and undocumented expenses as to PMAA events resulted in a private pecuniary gain of $3,201.48 plus $84.10 for over - charged mileage for PMAA events. Thus, per the Investigative Complaint, the total private pecuniary benefit as to PMAA events is $3,285.58. (See, Fact Findings 256 a -b, 400). Our calculation of Eathorne's private pecuniary benefit as to PMAA events is $3,301.58: Respondent will receive the benefit of the lower amount, specifically, $3,285.58. Bartholomew, supra. WEFTEC Events WEFTEC is the Water Environment Federation's Annual Technical Exhibition Conference. For each conference, attendees are required to complete a registration form. The form also includes registration fees for various options for attendees, as detailed in Fact Finding 263 b. Options include, inter alia, the One -Day EXPO only option and the "lifestyle program." The EXPO only option entitles the attendee to access to the exhibition hall only. The lifestyle program is intended to provide sightseeing tours of points of interest. Attendees must register for seminars they want to attend. Fees are charged for Eathorne, # 06 -053 Page 100 attendance at seminars. Badges are provided which authorize entrance to specific seminars. Access to seminars is denied without a badge. Eathorne attended the 2001 WEFTEC Conference in Atlanta, Georgia, from October 13, 2001, to October 17, 2001. Eathorne was accompanied by his spouse. With the exception of airfare, all expenses for Eathorne's spouse were paid using WWMA funds. Eathorne registered for the One -Day EXPO only option for Monday or Tuesday at a cost of $40.00. Eathorne's attendance at the 2001 WEFTEC Conference was limited to registration to view the exhibit hall. Eathorne was not registered to attend any educational sessions. Eathorne also registered his wife to attend the lifestyle program. The cost for the lifestyle program was $100.00. The registration fees for the Eathornes were billed to a WWMA American Express card in the name of Plant Manager Barry Riley ( "Riley "). As set forth in Fact Findings 269 -270, Eathorne and his wife were also registered for tours unrelated to any official conference functions. The reservations for these tours were made by WWMA Assistant Secretary /Treasurer Barbara Balcerek at Eathorne's direction. The tours cost a total of $206.00. The expenses for the tours were charged to the WWMA American Express card assigned to Riley. The tours occurred during the hours when conference concurrent sessions were being held. Authority check number 26974, dated July 19, 2001, in the amount of $1,828.01 was issued to American Express in payment of the credit cards assigned to Riley and Balcerek. The check was co- signed by Eathorne and Balcerek. The payment made to American Express included the cost of the Eathornes' tours and the registration for the conference. Eathorne received WWMA check #273282 dated October 9, 2001, in the amount of $2,000.00 as an advance of expenses for attendance at the 2001 WEFTEC event. Eathorne co- signed the check authorizing the payment. Eathorne deposited the check on October 19, 2001, to his National City Bank account. Eathorne did not submit an expense report to the WWMA detailing expenses incurred while attending the 2001 WEFTEC event. A hotel invoice from the Sheraton Colony Square Hotel, 188 14 Street, N.E., Atlanta, Georgia, confirmed that Eathorne checked in on October 13, 2001, at 12:21 p.m. and checked out on October 18, 2001, at 10:36 a.m. Eathorne's airline reservations confirm travel dates with an October 13, 2001, departure from Pittsburgh and an October 17, 2001, return date. Eathorne amended his travel to stay an extra day at WWMA expense and did not return until October 18, 2001. Eathorne extended his stay, in part, due to traveling to a casino in Biloxi, Mississippi, with Plant Manager Riley. Eathorne incurred an extra expense including hotel and meals and parking for a vehicle rented while in Atlanta. As detailed in Fact Finding 281 a, Eathorne provided generic receipt stubs to document meal expenses for the time period from October 13, 2001, to October 18, 2001. All of the stubs contained dates and amounts in Eathorne's handwriting. Receipt stubs used by Eathorne were part of a sequence and identical in format as receipts Eathorne used for other conferences. The WWMA paid a total of $2,612.00 for Eathorne's attendance at the 2001 WEFTEC Conference, which was limited to Eathorne's tour of the exhibit hall on, at most, one day. The aforesaid amount of $2,612.00 included, inter alia, payments by the WWMA for sight- seeing tours by the Eathornes. Per Fact Finding 293, deemed admitted, Eathorne Eathorne, # 06 -053 Page 101 received a private pecuniary gain of $2,612.00 when the WWMA incurred expenses for his travel to Atlanta for a conference he did not attend. The 2002 WEFTEC conference was held in Chicago, Illinois, from Saturday, September 28, 2002, to Thursday, October 3, 2002. Conference registration occurred on September 28, 2002, and September 29, 2002. Conference events occurred from September 30, 2002, to October 3, 2002. The Expo hall was open on September 29, 2002, from 1:00 p.m. to 5:00 p.m. Eathorne registered for the One -Day EXPO only option at a cost of $50.00. Eathorne did not register to attend any conference - related training or seminars. Eathorne's sole conference - related activity for the entire six days of the conference was a tour of the exhibitor hall. Eathorne also registered his wife to attend the lifestyle program. The cost for the lifestyle program was $100.00. The registration fees for the Eathornes were billed to a WWMA American Express card in the name of Plant Manager Riley. As set forth in Fact Finding 297, Eathorne also registered for tours for himself and his wife to attend, which were unrelated to any official conference functions. The tours cost a total of $126.00. The expenses for the tours were charged to the WWMA American Express card assigned to Riley. The tours occurred during hours when conference events were being held. Eathorne received an advance of expenses in the amount of $2,500.00 by WWMA check number 29131 issued on September 24, 2002. Eathorne signed the check in his capacity as WWMA treasurer. The check was deposited to Eathorne's National City Bank account on September 24, 2002. Eathorne authorized the advance to himself five days after he was instrumental in approving the increase in advance payments from $2,000.00 to $2,500.00. Eathorne submitted an expense report claiming additional expenses in the amount of $572.94, as detailed in Fact Finding 299. WWMA check number 29282 dated October 29, 2002, in the amount of $572.94 was issued to Eathorne. Eathorne signed the check as WWMA treasurer. The check was deposited to Eathorne's National City Bank account. Per Fact Finding 317, deemed admitted, Eathorne received a private pecuniary gain when he claimed non - conference expenses, undocumented expenses, and room expenses for September 30, 2002, and October 2, 2002, relative to the 2002 WEFTEC Conference. Eathorne's claimed expenses that were clearly non - conference expenses are enumerated in Fact Findings 310, 311, 312, and 313. They included the aforesaid tours and lifestyle program, car rental expenses, parking fees, certain meal expenses, and the purchase of a hat at ESPN Zone. The particular meal expenses constituting non - conference expenses included a claimed meal expense in the amount of $50.00, purportedly at Spadaro's Restaurant, on September 28, 2002. Spadaro's Restaurant is a one -hour drive from the Pittsburgh airport. It does not open for business until 4:00 p.m. Eathorne checked into the Chicago Marriott at 12:16 p.m. (CST) on September 28, 2002, and therefore we find that he did not dine at Spadaro's Restaurant on that date as he claimed. Non - conference expenses also included meal expenses for Eathorne's spouse and a claimed meal expense of $73.00 for the evening of October 3, 2002, after Eathorne returned from Chicago. Eathorne submitted a receipt to the WWMA claiming a meal expense at ESPN Zone, which was actually for the purchase of a hat. The hat cost $21.75. Eathorne claimed a total expense of $31.00, asserting that he paid an $8.25 tip. The purchase was Eathorne, # 06 -053 Page 102 made during the time frame when conference seminars were being held. Eathorne's undocumented expenses consisted of additional claimed meal expenses for which Eathorne submitted generic receipt stubs as set forth in Fact Finding 304. The receipt stubs submitted by Eathorne as justification for expenses are parts of sequences and identical in format and style as other receipts submitted by Eathorne for other conferences. Eathorne received a private pecuniary gain in excess of $2,000.00 when he claimed non - conference expenses in the amount of $941.15, undocumented expenses in the amount of $611.73, and room expenses for September 30, 2002, and October 2, 2002, in the amount of $526.12, relative to the 2002 WEFTEC Conference. The 2003 WEFTEC Conference was held in Los Angeles, California, from October 11, 2003, until October 16, 2003. Eathorne and his spouse traveled to the conference site at WWMA ratepayer expense. All expenses incurred with the exception of spousal airfare were paid using WWMA funds. Eathorne received a $2,500.00 advance to attend the conference. WWMA check number 30889 was issued to Eathorne on October 9, 2003. Eathorne signed the check in his position as WWMA treasurer. The check was deposited to Eathorne's National City Bank account on October 9, 2003. Eathorne submitted an expense report to the WWMA claiming expenses totaling $3,009.86 and seeking an additional $509.86 payment from the WWMA. Eathorne received WWMA check number 31167 in the amount of $418.81 on December 16, 2003, for additional expenses related to the California trip. Eathorne claimed $509.87 but $91.05 was deducted as a result of an overpayment to Eathorne by the WWMA for a prior conference. Eathorne was not registered to attend any conference seminar or official events. No record exists of Eathorne attending any conference - related event. Eathorne and his wife stayed at the Ritz Carlton Hotel, Huntingdon /Passadena, California, arriving on October 11, 2003, and checking out on October 17, 2003. Eathorne rented a vehicle, which was used for travel to and from the airport and for sightseeing. Eathorne claimed cab fare in the amount of $35.00 for travel between the Westin Hotel and the Ritz Carlton, even though the conference provided free bus /shuttle service between hotels every twenty minutes on a daily basis. As he did with every other WEFTEC conference he attended, Eathorne submitted "generic receipt stubs" to validate claimed meal expenses. Receipt stubs submitted by Eathorne to justify the advance and to seek additional reimbursement were parts of sequences and identical in format and style as other receipts submitted by Eathorne for other events. Upon returning to the Pittsburgh area on October 17, 2003, Eathorne claimed a $29.00 meal expense at the Robinson Township Olive Garden. Per Fact Finding 331, deemed admitted, Eathorne received a private pecuniary gain of at least $3,009.86 when he claimed expenses paid by WWMA relative to the 2003 WEFTEC Conference but did not attend any conference - related events. The 2004 WEFTEC Conference was held at the Ernest N. Morial Convention Center in New Orleans, Louisiana, from October 2, 2004, through October 6, 2004. The registration fees paid by the WWMA on behalf of Eathorne included the One -Day EXPO only option at a cost of $50.00 and the spouse lifestyle program at a cost of $100.00. Eathorne, # 06 -053 Page 103 These expenses were charged to a WWMA American Express card issued to Riley. Eathorne received an advance of expenses in the amount of $2,500.00 by WWMA check number 32518 on September 28, 2004. Eathorne signed the check as WWMA treasurer. The check was deposited to Eathorne's checking account at National City Bank on September 28, 2004. Eathorne and his wife were scheduled to travel by plane, departing from Pittsburgh and arriving in New Orleans on October 2, 2004, and departing from New Orleans and returning to Pittsburgh on October 6, 2004. Eathorne's airfare was charged to a WWMA American Express credit card issued to Riley. Eathorne and his wife were registered to stay at the Fairmont Hotel, 123 Baronne Street, New Orleans, Louisiana. Eathorne checked in on October 2, 2004, and departed on October 7, 2004. Eathorne was only registered for the one -day Expo. The Expo date for Eathorne was Monday October 4, 2004. Eathorne could have completed his conference attendance after one day. No record exists of Eathorne attending any conference - related activities. Records are not maintained for Expo hall attendance. Eathorne realized a private pecuniary gain in excess of $1,300.00 when he claimed the following expenses paid by the WWMA: (1) asserted meal expenses totaling $724.71, documented by generic receipt stubs made out in Eathorne's handwriting, none of which receipts identified a restaurant or meals purchased and one of which receipts claimed a dinner expense in the amount of $55.00 for a meal that was actually purchased by WWMA accountant, John Sarp; (2) undocumented tips that exceeded the amount authorized by WWMA policies by $95.00; (3) payment in the amount of $100.00 for his spouse's participation in the lifestyle program; (4) luggage /flight insurance in the amount of $57.78; (5) cab expenses in the amount of $207.00, documented by receipts made out in Eathorne's handwriting; (6) over - charged mileage to and from the airport in the amount of $17.59; and (7) meals for Eathorne's spouse in the amount of $111.08. The 2005 WEF Conference was held in Washington, DC, from October 29, 2005, until November 1, 2005. Assistant Secretary /Treasurer Barbara Balcerek made reservations for Eathorne and his wife to attend the event. The registration fees were charged to the WWMA American Express credit card assigned to Barbara Balcerek. WWMA check #33624, dated May 19, 2005, in the amount of $1,675.61, was issued to American Express in payment of (in part) the registration fees. This included the spousal lifestyle program of $100.00. Attendees were provided with the opportunity to register for sightseeing tours offered during the course of the convention. Fees associated with the tours were charged to the Authority American Express credit card assigned to Balcerek. Balcerek completed the sightseeing tour registration forms based on information provided by Eathorne. The cost to the Authority for the sightseeing tours for Eathorne and his wife totaled $372.00. Eathorne's sole conference - related activity was registration to tour the Expo Hall. The bulk of Eathorne's time was spent taking tours of the Washington, DC, area, as detailed in Fact Finding 366 b. Eathorne received a $2,500.00 advance of expenses by WWMA check no 34485 on September 27, 2005. Eathorne signed the check as WWMA treasurer. The check was deposited to Eathorne's National City Bank account. Eathorne and his wife were registered to stay at the Churchill Hotel, 1914 Connecticut Avenue, NW, Washington, DC. Eathorne is confirmed as checking in on WEFTEC EVENT PRIVATE PECUNIARY BENEFIT FACT FINDINGS 2001 WEFTEC Conference, Atlanta, GA $2,612.00 292 -293 2002 WEFTEC Conference, Chicago, IL $2,079.00 303 -304; 308; 310 -313; 317 2003 WEFTEC Conference, Los Angeles, CA $3,009.86 322, 331 2004 WEFTEC Conference, New Orleans, LA $1,313.16 341, 351 2005 WEFTEC Conference, Washington, DC $2,756.65 368 2006 WEFTEC Conference, Dallas, TX $2,299.60 377 Eathorne, # 06 -053 Page 104 October 29, 2005, at 3:08 p.m., and checking out on November 2, 2005, at 3:48 p.m. Eathorne submitted an expense report to the WWMA claiming expenses in the total amount of $2,283.65. Eathorne submitted generic receipt stubs to justify meal expenses claimed on the WWMA expense report. Eathorne generally had dinners provided to him and his wife by convention vendors in the form of either hospitality suites or dinners paid by vendors. Eathorne claimed a breakfast expense of $36.50 on November 3, 2005, one day after the conference ended. Eathorne over - charged the WWMA for mileage by at least 270 miles, resulting in an overpayment to him of $130.95. WWMA paid fees and advances to or for Eathorne totaling $2,972.00, calculated as follows: (1) spouse lifestyle program, $100.00; (2) tours, $372.00; and (3) advance of $2,500.00. Eathorne issued personal check number 1364 in the amount of $215.35 to the WWMA on December 13, 2005, as repayment of advance expenses for the 2005 WEFTEC Conference. Per Fact Finding 368, deemed admitted, Eathorne realized a private pecuniary gain of $2,756.65 as a result of him not attending the 2005 WEFTEC Conference and claiming expenses and /or having expenses paid on his behalf not related to any conference activity. Eathorne traveled to the 2006 WEFTEC Conference held in Dallas, Texas, from October 21, 2006, through October 25, 2006. Eathorne's wife accompanied him on this trip. Eathorne was registered for the Expo only full week option portion of the conference, at a cost of $135.00, and a tour of a Wastewater Treatment Plant, at a cost of $40.00. No record exists of Eathorne attending any conference - related functions other than the Expo. Eathorne requested and received a $2,000.00 advance to travel to Dallas. WWMA check number 35661 in the amount of $2,000.00 was issued to Eathorne on October 19, 2006. Eathorne signed the check as WWMA treasurer. The check was deposited to Eathorne's National City Bank account on October 19, 2006. Eathorne did not submit a travel expense report to the WWMA as to this conference. Per Fact Finding 377, deemed admitted, Eathorne received a private pecuniary gain of $2,299.60 as a result of advances and airfare paid on his behalf to travel to Texas. This includes the advance and airfare charge of $299.60. Per the Investigative Complaint, deemed admitted, Eathorne realized a private pecuniary gain of $14,138.27 as to WEFTEC Conferences. (See, Fact Finding 378). Our calculation of Eathorne's private pecuniary gain as to WEFTEC events is $14,070.27: Eathorne, # 06 -053 Page 105 TOTAL $14,070.27 Respondent will receive the benefit of the lower amount, specifically, $14,070.27. Bartholomew, supra. Pumper & Cleaner Environmental Expo Eathorne attended a Pumper & Cleaner Environmental EXPO held in Nashville, Tennessee, from February 15, 2006, through February 19, 2006. Eathorne's wife accompanied him on this trip. Eathorne was the only WWMA Board Member to travel to Nashville. Eathorne received a $2,500.00 advance of expenses by WWMA check number 34945 dated February 7, 2006. Eathorne co- signed the check. The check was deposited to Eathorne's account at National City Bank on February 8, 2006. Eathorne was registered to stay at the Sheraton, Music City, Nashville. Eathorne checked in at 5:55 p.m. on February 14, 2006, and checked out on February 19, 2006. Eathorne submitted a travel expense report to the WWMA in justification of the $2,500.00 advance and to seek additional reimbursement in the amount of $6.46. Eathorne received WWMA check number 35091 in the amount of $6.46 on March 9, 2006. Eathorne signed the check as WWMA treasurer. Of the meal receipts submitted by Eathorne, two were from legitimate restaurants and the remaining thirteen(13) stubs totaling $845.00 were in the form of the generic stubs regularly utilized by Eathorne as justification for claimed expenses. Eathorne claimed tips of $120.00 for his trip to Nashville. As noted above, the WWMA maximum is $25.00. Eathorne submitted no justification for the tips. Eathorne over - charged the WWMA for mileage by at least $66.75. Per Fact Finding 390, deemed admitted, Eathorne realized a private pecuniary gain in the amount of $1,043.80 when he used WWMA advance funds to pay for spousal expenses, when he did not document actual meal expenses, and when he over - charged the WWMA for mileage. PWEA Event Eathorne attended the 2006 annual Technical Conference (PENNTEC) of the Pennsylvania Water Environment Association (PWEA). The conference was held in State College, Pennsylvania, from Sunday, July 16, 2006, until Wednesday morning, July 19, 2006. The conference was held at the Penn Stater Conference Hotel. On June 27, 2006, WWMA check number 35103 in the amount of $490.00 was issued to the PWEA for the conference registration for Eathorne and Kevin Fisher. Eathorne's costs as a non - member were $260.00. Eathorne co- signed the check. Eathorne received an $800.00 advance of expenses by WWMA check number 35157 dated July 11, 2006. Eathorne co- signed the check. The check was deposited to Eathorne's National City Bank account. Eathorne checked into the Penn Stater on July 16, 2006. The hotel invoice confirmed room expenses and a restaurant expense in the total amount of $380.62. Eathorne claimed no other expenses in relation to the 2006 PENNTEC Conference. Eathorne, # 06 -053 Page 106 Eathorne did not submit a travel expense report to the WWMA following the trip. Per Fact Finding 399, deemed admitted, Eathorne realized a private pecuniary gain of $419.38 as a result of using his position to approve an advance of expenses of $800.00 where his incurred expenses were only $380.62. Based upon the above, we find that the total private pecuniary benefit(s) received by Eathorne relative to travel during the time period under review was in the amount of $21,491.87: ALOM Events $ 2,672.84 PMAA $ 3,285.58 WEFTEC $14,070.27 PWEA $ 419.38 Pumper Expo $ 1,043.80 $21,491.87 Having highlighted the facts and issues, we must now determine whether the actions of Eathorne violated Section 1103(a) of the Ethics Act. Based upon our analysis below, the Fact Findings as deemed admitted by Respondent necessitate the conclusion that Respondent has violated Section 1103(a) of the Ethics Act as alleged. Through his actions as a WWMA Member /treasurer, Respondent has received, over a course of years, private pecuniary benefit(s) in the total amount of $21,491.87 with respect to payments by the WWMA of excess expenses claimed by Respondent, expenses for Respondent's spouse, expenses for conferences and convention - related events Respondent did not attend, and expenses and items of a personal nature for Respondent and his spouse. We begin our analysis by determining that Respondent's claimed expenses that were supported only by Respondent's generic receipt stubs were unauthorized and illegitimate. Per the Fact Findings, deemed admitted, Respondent Eathorne was one of a group of Board Members who asserted that since they were not compensated as Board Members, they were entitled to claim, as expenses, all advance monies received. Eathorne used "generic" receipt stubs to justify retaining entire advance expense payments. These stubs never identified a restaurant or location where expenses were allegedly incurred. They were often numbered sequentially, matching in style, format, and manufacturer. The pattern of using receipts identical in design and print and part of a sequence was a common occurrence for Eathorne when traveling at ratepayer expense and was done solely to inflate expenses in order to receive private pecuniary gain. Eathorne typically did not go out for dinner when traveling to conferences unless the meal was paid for by a third party. Eathorne did go to vendor hospitality suites where he was treated to drinks and food items, and Eathorne's wife would accompany him. Eathorne would go to these functions in lieu of purchasing dinner. WWMA travel policies in effect during the time period under review provided that an attendee who received an advancement of expenses was required to file an expense report with proper receipts, and that the failure to do so would result in the advancement being considered income for tax purposes. The WWMA's failure to enforce its policies as to Respondent's generic receipts does not change the fact that such receipts were not proper. We determine that Respondent's "generic" receipt stubs were not proper receipts, such that the amounts Respondent claimed and received through the use of generic receipt stubs constituted unauthorized payments to Respondent. In addressing the specific allegations, we shall first consider the allegation that Eathorne, # 06 -053 Page 107 Respondent violated Section 1103(a) of the Ethics Act when he authorized advances of expenses for his attendance at conferences and conventions and then claimed expenses in excess of actual expenses incurred. Each element of a violation of Section 1103(a) has been established. Respondent used the authority of his public position as WWMA Member /treasurer when he authorized advances of expenses for travel between 2001 and 2006. But for being a WWMA Member, Respondent would not have been in a position to receive or benefit from such advances of expenses for travel. Some of the expense advancements were paid directly by the WWMA to a conference - related payee or other provider, while other advances were paid directly to Respondent. Respondent used the authority of his public position as WWMA Member /treasurer when he co- signed all WWMA checks issued for registration fees and when he co- signed other advances of expenses for his travel between 2001 and 2006. Respondent also used the authority of his public position when he claimed expenses through the submission of expense reports and accepted WWMA payments for expenses. Respondent received a private pecuniary benefit when he claimed expenses in excess of actual expenses incurred, thereby receiving /retaining WWMA funds to which he was not lawfully entitled. In some instances, Respondent's receipt /retention of expense monies was particularly blatant. For example, with respect to the 2003 ALOM Fall conference, Respondent directly received an expense advance in the amount of $800, submitted an expense report in the amount of $708.95, and simply retained the balance of $91.05. For the 2006 ALOM Fall Conference, Respondent directly received an expense advance in the amount of $800, failed to submit any expense report, and retained $217.00 of WWMA funds in excess of actual documented expenses. Likewise, for the 2006 PMAA Conference and Trade Show, Respondent directly received an $800 advance, failed to submit an expense report, and retained the advance monies where the documented expenses were only $359.70. For the 2006 PWEA PENNTEC Conference, Respondent directly received an expense advance in the amount of $800, failed to submit any expense report, and retained $419.38 of WWMA funds in excess of actual documented expenses. The Fact Findings are replete with instances in which Respondent received /retained advance monies by claiming expenses in excess of actual expenses incurred. The following are just some of the examples: • For the 2004 ALOM Fall Conference, excess meal expenses ($151.83) and excess tips ($5.00); • For the 2005 ALOM Spring Conference, excess meal expenses ($155.47) and excess tips ($25.00); • For the 2005 ALOM Fall Conference, excess meal expenses ($190.00) and lounge charges ($25.50); • For the 2006 ALOM Spring Conference, lounge charges ($9.25), excess meal expenses ($167.00), excess tips ($25.00), and excess mileage ($32.04); • For the 2003 PMAA Annual Conference, an excess meal expense ($180.00); • For the 2004 PMAA Annual Conference, excess meal expenses ($363.83) and excess hotel expenses ($122.62); • For the 2005 PMAA Annual Conference, excess meal expenses (exceeding $396.00), golf outing ($70.00), Christmas Tree Hill /Luncheon Guest Tour ($40.00 for Eathorne), and gift shop expense ($5.25); • For the 2003 PMAA Legislative Day, excess meal expenses ($121.00); • For the 2004 PMAA Legislative Day, excess meal expenses ($327.64), excess tips ($55.00), movie charges ($28.61), lounge charges ($51.50), and excess mileage ($46.92); • For the 2004 WEFTEC Conference, excess meal expenses ($724.71), excess Eathorne, # 06 -053 Page 108 tips ($95.00), cab expenses ($207.00), and excess mileage ($17.59); and • For the 2006 Pumper & Cleaner Expo, undocumented expenses ($845.00) and excess mileage ($66.75). The egregious nature of Respondent's conduct is perhaps best demonstrated by those instances when Respondent submitted a bogus, generic receipt for a meal that had been purchased by someone else (the WWMA accountant) (see, Fact Findings 187 -190); a bogus Holiday Inn hotel receipt claiming expenses in excess of actual expenses incurred for his stay at the Westin Hotel in Pittsburgh (see, Fact Findings 181 -182, 191); receipts for claimed meal expenses after Respondent had returned home from various events (see, Fact Findings 90, 107, 137 a, 168, 215, 215 a -b, 241 -242, 313, 328, 363); and when Respondent claimed expenses for one particular meal that did not occur at all, given that Respondent was in Chicago at the time and could not have been present at the restaurant (Spadaro's Restaurant) that he claimed to have patronized in Pennsylvania (see, Fact Finding 311). We hold that Respondent violated Section 1103(a) of the Ethics Act when he authorized advances of expenses from the WWMA for his attendance at conferences and conventions and then claimed expenses in excess of actual expenses incurred. Cf., Matta, Order 1439; Sullivan, Order 1245; Farley, Order 1096; Baxter, Order 985; Choura, Order 942. We shall next consider the allegation that Respondent violated Section 1103(a) of the Ethics Act when he used WWMA expense advancements for expenses incurred by his spouse. Some of the expense advancements were paid directly by the WWMA to a conference - related payee or other provider, while others were paid to Respondent. Respondent used the authority of his public position as WWMA Member /treasurer when he co- signed all WWMA checks issued for registration fees and when he co- signed other advances of expenses for his travel between 2001 and 2006. Respondent also used the authority of his public position when he claimed expenses through the submission of expense reports and accepted WWMA payments for expenses. The Fact Findings are replete with instances in which Respondent used expense advancements for expenses incurred by his spouse. The following are just some of the examples: • For the 2003 ALOM Spring Conference, spousal lodging and meal plan ($164.00); • For the 2003 ALOM Fall Conference, spousal lodging and meal plan ($164.00); • For the 2004 ALOM Fall Conference, spousal lodging and meal plan ($172.00); • For the 2005 ALOM Spring Conference, spousal lodging and meal plan ($174.00); • For the 2005 ALOM Fall Conference, spousal lodging and meal plan ($174.00); • For the 2006 ALOM Spring Conference, spousal lodging and meal plan ($174.00); • For the 2006 ALOM Fall Conference, at least a portion of the spousal lodging and meal plan (at least a portion of $174.00); • For the 2003 PMAA Annual Conference, spousal program, banquet, and other meal expenses ($455.83); • For the 2004 PMAA Annual Conference, spousal banquet expenses ($46.00); • For the 2005 PMAA Annual Conference, spousal banquet ($49.00) and meal expenses (at least $102.30); • For the 2006 PMAA Annual Conference, spousal banquet ($49.00); • For the 2003 PMAA Legislative Day, spousal expenses ($50.00); • For the 2002 WEFTEC Conference, spousal meal expenses ($131.00); • For the 2004 WEFTEC Conference, spousal meal expenses ($111.08); and Eathorne, # 06 -053 Page 109 • For the 2006 Pumper & Cleaner Expo, spousal meal expenses ($42.50). The use of WWMA funds for Respondent's spouse's expenses was unauthorized. We hold that Respondent violated Section 1103(a) of the Ethics Act when he used WWMA expense advancements for expenses incurred by his spouse. Cf., Tancredi, Order 1434; Krisher, Order 1425; Stephens, Order 1133; Shepler, Order 1127. The third allegation is that Respondent violated Section 1103(a) of the Ethics Act when he authorized advance payments of expenses to himself for conferences and convention - related events he did not attend. Respondent used the authority of his public position as WWMA Member /treasurer when he authorized advances of expenses that he received for travel between 2001 and 2006. See, Fact Findings 21 b 1, 34 b 1, 41. Respondent also used the authority of his public position when he claimed expenses through the submission of expense reports and accepted WWMA payments for expenses. For some events, Respondent and his wife traveled at the expense of the WWMA while engaging in personal pursuits, including sight- seeing. In some instances, Respondent was not even registered for any conference - related events. Per the Fact Findings, deemed admitted by Respondent, Respondent co- signed and received advances of expenses for conferences and convention - related events he did not attend, including the following: • The 2001 WEFTEC Conference, for which Respondent directly received an advance of expenses in the amount of $2,000.00 and a total private pecuniary benefit in the amount of $2,612.00; • The 2003 WEFTEC Conference, for which Respondent directly received an advance of expenses in the amount of $2,500.00 and a total private pecuniary benefit of at least $3,009.86; • The 2005 WEFTEC Conference, for which Respondent directly received an advance of expenses in the amount of $2,500.00 and a total private pecuniary benefit in the amount of $2,756.65; • The 2006 WEFTEC Conference, for which Respondent directly received an advance of expenses in the amount of $2,000.00 and a total private pecuniary benefit in the amount of $2,299.60. Based upon the Fact Findings, deemed admitted by Respondent, we hold that Respondent violated Section 1103(a) of the Ethics Act when he authorized advance payments of expenses by the WWMA to himself for conferences and convention - related events he did not attend. Cf., Matta, Order 1439. The final allegation is that Respondent violated Section 1103(a) of the Ethics Act when he authorized the use of a WWMA credit card for the payment of expenses and items of a personal nature for himself and his spouse. This allegation has been established for expenses /items including the following: • For the 2001 WEFTEC Conference, tours for Respondent and his wife ($206.00) and spousal lifestyle program ($100.00); • For the 2002 WEFTEC Conference, tours for Respondent and his wife ($126.00) and spousal lifestyle program ($100.00); • For the 2004 WEFTEC Conference, spousal lifestyle program ($100.00); and • For the 2005 WEFTEC Conference, tours for Respondent and his wife ($372.00) and spousal lifestyle program ($100.00). For each of the above events, Respondent used the authority of his public position Eathorne, # 06 -053 Page 110 by either directly registering himself and his wife for the event(s) or by providing the necessary information to the WWMA assistant secretary /treasurer to make the reservations, at WWMA expense. But for his status and authority as WWMA Member /treasurer, Respondent would not have been in a position to arrange for sight- seeing tours or lifestyle programs at WWMA expense. We hold that Respondent violated Section 1103(a) of the Ethics Act when he authorized the use of a WWMA credit card for the payment of expenses and items of a personal nature for himself and his spouse. Cf., Krisher, Order 1425; Gorr, Order 1423. Based upon the above, we find that Respondent Eathorne received private pecuniary benefit(s) in the total amount of $21,491.87 as a direct result of his violations of Section 1103(a) of the Ethics Act referenced herein. The parties were given an opportunity to file, concurrently, their respective Position Statements. Respondent filed a Position Statement contending: (1) that Respondent's Counsel requested but was not provided by the Investigative Division with copies of documents as required by 65 Pa.C.S. § 1108(e), making it impossible for Respondent to respond or counter arguments relating to the documentary evidence; (2) that the Investigative Complaint contains the Investigative Division's subjective judgments about whether the events attended by Respondent were worthwhile; and (3) that the Investigative Complaint "presumes to know" precise mileage as to Eathorne's travel and presumes to disqualify Eathorne's generic receipt stubs. We reject Respondent's arguments for the following reasons. Respondent's first argument is a new argument, which was not raised in Respondent's Application for Permission to File Answer to Investigative Complaint Nunc Pro Tunc. The Investigative Division had no notice that such an argument would be raised by Respondent, and therefore, had no opportunity to respond to it. To the extent we would consider Respondent's new argument, we would reject it as having no merit. Factually, Respondent's failure to file a timely Answer was not due to a lack of access to documents in the possession of the Investigative Division. Respondent has admitted that the failure to timely file an Answer was due to Respondent's Counsel's miscalculation of the due date. Position Statement of Respondent, at 2. We have denied Respondent's Application for Permission to File Answer to Investigative Complaint Nunc Pro Tunc because Respondent's excuse for failing to meet the filing deadline is inadequate under the well - established civil standard for permitting a late filing. As for Section 1108(e) of the Ethics Act, 65 Pa.C.S. § 1108(e), that Section (pertaining to findings reports, answers to findings reports, requests for hearing, hearing locations, access to evidence, and the deadline for conducting a hearing) does not provide a specific deadline by which access to evidence must be provided to a respondent. We decline to interpret Section 1108(e) to require that access to evidence must be provided prior to the filing of an Answer to the Investigative Complaint /findings report. In statutory construction, "...the General Assembly does not intend a result that is absurd, impossible of execution or unreasonable." 1 Pa.C.S. § 1922(1). It would be an absurd interpretation of Section 1108(e) to require the Investigative Division to provide access to "evidence intended to be used at ... the hearing" prior to the filing of an Answer, when the very filing of the Answer, with admissions and denials of a factual nature, would likely impact decisions of the Investigative Division as to what evidence it would intend to use at hearing. Eathorne, # 06 -053 Page 111 We interpret Section 1108(e) of the Ethics Act to require that a respondent be provided access to evidence sufficiently in advance of a hearing to enable a respondent to fully and fairly prepare for hearing. (We parenthetically note that in addition to our above analysis, Respondent's first argument has no basis in standard pleading practice; attorneys must routinely file pleadings prior to having access to discovery /evidence, and the obvious and standard pleading technique that is used when a defendant or respondent lacks sufficient facts to respond to an averment is to so state, such that the averment is deemed denied.) We reject Respondent's second argument in that, even if the Investigative Division included subjective judgments in the averred Fact Findings, such Fact Findings are deemed admitted by Respondent. We reject Respondent's argument as to mileage overcharges for the same reason. We reject Respondent's argument as to the generic receipt stubs because the Fact Findings are deemed admitted by Respondent and because we have found Respondent's generic receipt stubs to be improper for reasons set forth above. The Investigative Division has filed a Position Statement contending that Respondent's conduct was egregious and in clear violation of Section 1103(a) of the Ethics Act, and that Respondent should be found in violation of Section 1103(a) of the Ethics Act and ordered to pay both restitution and a treble penalty. The Investigative Division further contends that this matter should be referred to all appropriate law enforcement authorities with a specific recommendation that criminal charges be initiated. We have determined that Respondent violated Section 1103(a) of the Ethics Act as alleged. As for the imposition of a financial penalty in this case, Section 1109(c) of the Ethics Act, 65 Pa.C.S. § 1109(c), provides that any person who obtains financial gain from violating the Ethics Act, in addition to any other penalty provided by law, shall pay a sum of money equal to three times the amount of the financial gain (hereinafter referred to as a "treble penalty ") into the State Treasury or the treasury of the political subdivision. In the instant matter, Respondent obtained a financial gain in the total amount of $21,491.87 as a direct result of his violations of Section 1103(a) of the Ethics Act referenced herein. We shall order Respondent to pay a treble penalty in the amount of $64,475.61, with such payment to be made payable to the Commonwealth of Pennsylvania and forwarded to this Commission within 30 days of issuance of this Order for deposit in the State Treasury. Additionally, given the egregious nature of the violations of Section 1103(a) of the Ethics Act, this case will be referred to the Westmoreland County District Attorney, the Pennsylvania Attorney General, and the U.S. Attorney for review and such action as they may deem appropriate. Eathorne, # 06 -053 Page 112 IV. CONCLUSIONS OF LAW: 1. As a Member of the Western Westmoreland Municipal Authority ( "WWMA ") from July 18, 1996, until December 2006, Respondent Robert Eathorne ( "Eathorne ") was a public official subject to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq. 2. Eathorne violated Section 1103(a) of the Ethics Act when he authorized advances of expenses from the WWMA for his attendance at conferences and conventions and then claimed expenses in excess of actual expenses incurred. 3. Eathorne violated Section 1103(a) of the Ethics Act when he used WWMA expense advancements for expenses incurred by his spouse. 4. Eathorne violated Section 1103(a) of the Ethics Act when he authorized advance payments of expenses by the WWMA to himself for conferences and convention - related events he did not attend. 5. Eathorne violated Section 1103(a) of the Ethics Act when he authorized the use of a WWMA credit card for the payment of expenses and items of a personal nature for himself and his spouse. In Re: Robert Eathorne, Respondent ORDER NO. 1451 File Docket: 06 -053 Date Decided: 12/19/07 Date Mailed: 12/28/07 1 Respondent Robert Eathorne ( "Eathorne "), a public official in his capacity as a Member of the Western Westmoreland Municipal Authority ( "WWMA ") from July 18, 1996, until December 2006, violated Section 1103(a) of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1103(a), when he authorized advances of expenses from the WWMA for his attendance at conferences and conventions and then claimed expenses in excess of actual expenses incurred. 2. Eathorne violated Section 1103(a) of the Ethics Act when he used WWMA expense advancements for expenses incurred by his spouse. 3. Eathorne violated Section 1103(a) of the Ethics Act when he authorized advance payments of expenses by the WWMA to himself for conferences and convention - related events he did not attend. 4. Eathorne violated Section 1103(a) of the Ethics Act when he authorized the use of a WWMA credit card for the payment of expenses and items of a personal nature for himself and his spouse. 5. Eathorne is ordered to pay a treble penalty in the amount of $64,475.61, with such payment to be made payable to the Commonwealth of Pennsylvania and forwarded to this Commission within 30 days of issuance of this Order for deposit in the State Treasury. 6. This case will be referred to the Westmoreland County District Attorney, the Pennsylvania Attorney General, and the U.S. Attorney for review and such action as they may deem appropriate. BY THE COMMISSION, Louis W. Fryman, Chair