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HomeMy WebLinkAbout1584 Schell In Re: Jonas Schell, : File Docket: 09-041 Respondent : X-ref: Order No. 1584 : Date Decided: 6/23/11 : Date Mailed: 7/6/11 Before: Louis W. Fryman, Chair John J. Bolger, Vice Chair Donald M. McCurdy Raquel K. Bergen Nicholas A. Colafella Mark Volk This is a final adjudication of the State Ethics Commission. Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding possible violation(s) 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 allegations. Upon completion of its investigation, the Investigative Division issued and served upon Respondent a Findings Report identified as an “Investigative Complaint.” An Answer was filed and a hearing wasrequested. A Stipulation of Findings and a Consent Agreement waiving an evidentiary hearing were subsequently submitted by the parties to the Commission for consideration. The Stipulated Findings are set forth as the Findings in this Order. The Consent Agreement has been approved. I.ALLEGATIONS: That Jonas Schell, a public official/public employee in his capacity as a Supervisor for Foster Township, Luzerne County, violated Sections 1103(a), 1103(f) and 1105(b) of the State Ethics Act (Act 93 of 1998), 65 Pa.C.S. §§ 1103(a), 1103(f) and 1105(b), when he used the authority of his public position for private pecuniary benefit, including but not limited to participating in discussions and actions of the Board of Supervisors to award contracts to him and/or his private business, J.A. Schell Contractor; when he participated in approving payments to J.A. Schell Contractor; when contracts were entered into between the Township and J.A. Schell Contractor in excess of $500.00 without an open and public process; when he failed to disclose on Statements of Financial Interests for the 2005, 2006, 2007 and 2008 calendar years all direct and/or indirect sources of income, financial interests in any legal entity engaged in business for profit and any office directorship or employment or [sic] any nature whatsoever in any business entity. II.FINDINGS: 1. Jonas Schell served as a Supervisor of Foster Township, Luzerne County, from or about 1998 until October 13, 2008. a. Schell resigned from his position as Foster Township Supervisor on October 13, 2008, due to health problems. Schell, 09-041 Page 2 2. Foster Township is a Second Class Township governed by a three Member Board of Supervisors. a. Supervisors in Foster Township serve 6 year terms. 3. Voting at Foster Township Supervisor meetings occurs by roll call vote after a motion is made and properly seconded. a. Any abstentions or objections made to the motion are specifically noted in the minutes. 4. Motions are made at regular monthly meetings to pay bills for invoices received. a. Bill lists are provided at each meeting. 1. Each bill is available for review by the Supervisors prior to approval. 5. Signature authority over Township accounts is held by all three Supervisors. a. Checks require the signature of two Supervisors. 6. Schell was a 50% partner in J&A Schell General Contractor with his brother, Allen Schell. a. Due to Schell’s declining health, Allen Schell assumed full control of the business in late 2008. b. Types of work performed by J&A Schell General Contractor include general contracting and construction work. c. During the winter months, J&A Schell has also performed snow plowing services for several property developments in Foster Township. 7. In January 2005, J&A Schell performed snow/ice removal services for the Township. a. J&A Schell performed the services without public notice or bidding and without vote of the Board of Supervisors. 8. From January 7, 2005, to January 9, 2005, a severe ice storm occurred in the Foster Township area. a. The ice storm damaged many trees in the Township, causing branches and limbs to fall onto and along Township roads and on power lines and phone lines. 9. Jonas Schell made the decision to utilize his private business, J&A Schell Contractor, to perform storm cleanup work in the Township. a. At the time that the storm hit, Supervisor Robert Lesko was out of town and Supervisor Thomas Potoskie was ill and sick at home. 1. Schell did not discuss his decision to perform the work with Potoskie until after the work was completed. 2. Schell did not contact Lesko until he had already begun the work. Schell, 09-041 Page 3 b. Schell did not advise Potoskie and Lesko of the rates J&A Schell would be charging the Township until after the work had been completed. 10. At the time Schell made the decision to utilize J&A Schell to perform storm cleaning work, the road crew was available to complete the work. a. Normally, the Township road crew would be utilized to clean up damage to Township roadways caused by a storm. 1. The road crew had completed storm cleanup work in the past. 2. Some of the Township road crew workers were temporarily laid off when the ice storm struck the Township. 3. It is customary for the Township road crew to be laid off due to lack of work during the winter months. b. Neither the Township nor Schell sought or solicited any bids from other contractors or businesses prior to J&A Schell performing the work for the Township. 11. During the same time frame that J&A Schell was performing storm cleaning work for the Township, road workers were also performing similar work for the Township. a. Township road crew members’ time sheets show the following hours were worked from January 10, 2005, to January 13, 2005, by the road crew: Hours Date Name Worked Project(s) 1/10/2005 Walter Jones 5.5 Clear Fallen Trees 1/10/2005 Christopher Spock 5.5 Clean Up Fallen Trees 1/10/2005 Michael Searfoss 5.5 Clean Up Fallen Trees 1/10/2005 Merritt Sheaman 5.5 Clean Up Fallen Trees Salt and Cinder Road 1/11/2005 Walter Jones 8 and Work on F350 1/11/2005 Christopher Spock 4 Salt Township Roads Salt and Cinder Township Roads 1/11/2005 Michael Searfoss 8 and Repairs to Tools and Machinery 1/11/2005 Merritt Sheaman 4 Salt Township Road 1/12/2005 Walter Jones 4 Salt and Cinder Road 1/12/2005 Christopher Spock 4 Salt Township Roads 1/12/2005 Michael Searfoss 4 Salt and Cinder Township Roads 1/12/2005 Merritt Sheaman 4 Salt Township Road 1/13/2005 Walter Jones 0 None Clean F550, fix F350, 1/13/2005 Christopher Spock 4 grease Cat Loader 1/13/2005 Michael Searfoss 0 None 1/13/2005 Merritt Sheaman 0 None b. Only Walter Jones and Michael Searfoss worked a full 8 hour day of work during the 4 day time period that J&A Schell performed the cleanup work for the Township. Schell, 09-041 Page 4 1. Both Jones and Searfoss worked the full 8 hour day on January 11, 2005, which included 4 hours of work on equipment repair. c. Foster Township road crew members are unionized, and pursuant to a clause in the union agreement with the Township, road crew members must be called to do work when it is available. d. Schell alleges that the road crew members were completing storm cleanup in another area of the Township, and the amount of the damage was more than they could handle. 12. Cleanup work was completed by J&A Schell on the following dates: Date Description of Work Hours 1/10/2005 Cut trees and brush along Township roads 11 1/11/2005 Cut trees and brush along Township roads 12 1/12/2005 Cut trees and brush along Township roads 12 1/13/2005 Cut trees and brush along Township roads 5 Total 40 a. J&A Schell billed Foster Township at the rate of $95.00 per hour for a total bill of $3,800.00 for the 40 hours of work. 13. J&A Schell used Foster Township equipment including a loader to complete the cleanup work in the Township. a. Fuel for the equipment was also furnished by the Township. b. Supervisors Potoskie and Lesko were not aware that Township equipment was used by Schell to complete the work. 14. No quotes were solicited by Schell or the Township from other vendors to provide tree removal services. a. Section 68102(b) of the Second Class Township Code, 53 P.S. § 68102(b), requires that written or telephonic price quotations from at least three qualified and responsible contractors [be] requested for all Township contracts that exceed four thousand dollars ($4,000). b. Schell asserts that he did not obtain formal quotes from other vendors because of the emergency nature of the work. c. J&A Schell billed the Township $3,800 for cutting the brush and trees, which was just under the $4,000 threshold requiring quotes from three contractors as set forth in the Second Class Township Code. 15. On or about January 14, 2005, J&A Schell submitted an invoice totaling $3,800.00 to the Township for the storm cleanup. a. The invoice was for a total of 40 hours of work at the rate of $95.00 per hour. 16. Foster Township records confirm that J&A Schell was issued check number 4656 in the amount of $3,800.00 from the Township’s General Fund Account on February 14, 2005. a. Check number 4656 was signed by Supervisors Jonas Schell and Robert Schell, 09-041 Page 5 Lesko as authorized Township signatories. b. On February 16, 2005, check number 4656 was deposited into a PNC Bank account maintained by J&A Schell. 17. The $3,800.00 payment to J&A Schell for the storm cleanup work was approved at the February 14, 2005, Board of Supervisors meeting as shown below: Check Check Action By Date No. Amount Meeting Date Jonas Schell Recorded Vote 2/14/2005 4656 $3,800.00 2/14/2005 abstain 2 to 0 a. Schell abstained from voting on the approval of Township bills at the February 14, 2005, meeting. 18. J&A Schell did storm cleanup work at the same time that four Township road crew workers were available to do the work. 19. The total amount received by J&A Schell for road cleanup work in January 2005 was $3,800.00. THE FOLLOWING FINDINGS RELATE TO THE ALLEGATION THAT SCHELL USED HIS PUBLIC POSITION TO AWARD A CONTRACT TO J&A SCHELL TO CONSTRUCT A TOWNSHIP BUILDING. 20. In 2002, the Foster Township Supervisors began discussions regarding the construction of a new municipal building. a. The proposed construction included the building of offices for Township employees and the construction of a conference room for meetings to be held. b. At the time discussions to build a new municipal building began, meetings were being held in a Township garage that was located on Township property. c. The new building was to be built beside the previously existing Township garage. d. Jonas Schell was an advocate of building a new municipal building in Foster Township. 21. On August 16, 2002, the Foster Township Supervisors held a Special Meeting to act on plans for construction of a municipal building. a. Meeting minutes from the August 16, 2002, Special Meeting contain the following: “Mr. Schell made the motion to advertise for bids for the Municipal Building Renovation Project. Mr. Potoskie seconded the motion. Roll Call: Mr. Potoskie – Yes; Mr. Lesko – Yes; Mr. Schell – Yes” 22. On September 16, 2002, the Foster Township Supervisors held a Special Meeting to open bids that were received for the municipal building project. Schell, 09-041 Page 6 a. Meeting minutes from the September 16, 2002, Special Meeting contain the following: “Opening of bids for the addition and renovation of the Municipal Building. Bids were opened for General Construction: Power Builders $175,000.00 Bognet, Inc. $211,200.00 Apollo Group, Inc. $219,000.00 G.C. Wall, Inc. $179,000.00 Electrical Construction: Hayden, Inc. $24,220.00 Mechanical Construction: Bognet, Inc. $48,700.00 Mr. Potoskie made the motion to table the bids until October 16, 2002 at which time the board will make their decision. Mr. Schell seconded the motion. Roll Call: Mr. Potoskie – Yes; Mr. Schell – Yes; Mr. Lesko – Yes” 23. At the October 16, 2002, Foster Township Supervisors Special Meeting, the Board decided to reject all of the bids for the municipal building project. a. Meeting minutes from the October 16, 2002, Special Meeting contain the following: “Mr. Lesko stated that after careful review of the bids for the different work disciplines the Board of Supervisors decided that they are quite high so he entertained a motion to reject all of the bids and take no further action. Mr. Schell made the motion to reject all the bids. Mr. Lesko seconded the motion. Roll Call: Mr. Schell – Yes; Mr. Lesko – Yes” 24. A special meeting was held on July 18, 2003, for the approval of the municipal building project and for the authorization to advertise for bids for the project. a. Meeting minutes from the July 18, 2003, meeting confirm that the project was approved with the Board of Supervisors serving as general contractor and Schell serving as project manager as noted below: “Mr. Lesko stated the first order of business is the authorization of construction of the Township building. Mr. Lesko made the motion to approve the construction of the new Foster Township municipal building, the Foster Township Supervisors are to serve as general contractors for the project, Township Supervisor Jonas Schell will serve as the project manager and where necessary bids will be solicited for various phases of the project. Mr. Schell seconded the motion. Roll call: Mr. Lesko –Yes; Mr. Schell –Yes.” b. Schell was appointed as project manager for the municipal building project, tasking him with the responsibility to solicit bids when necessary for the project. Schell, 09-041 Page 7 25. As project manager, Schell solicited quotes for various aspects of the project. 26. Quotes were presented by Schell to the Board for the framing of the building and for the shingling of the roof at the July 18, 2003, special meeting. The meeting minutes contain the following: a. “Mr. Schell stated he had three quotes for the framing of the building: Dennison Development - $9,670.00 Bulls Eye Construction - $9,925.00 Eagle Construction - $9,850.00 Mr. Schell made the motion to award the bid for the framing of the building to Dennison Development in the amount of $9,670.00. Mr. Lesko seconded the motion. Roll call Mr. Lesko – Yes; Mr. Schell – Yes.” b. “Mr. Schell stated he had three quotes for the shingling of the roof: Dennison Development - $4,250.00 Eagle Construction - $4,685.00 Bull Eyes Construction - $4,565.00. Mr. Lesko made the motion to award the bid for the shingling of the roof to Dennison Development in the amount of $4,250.00. Mr. Schell seconded the motion. Roll call: Mr. Lesko –Yes; Mr. Schell – Yes.” c. The bids presented to the Board by Schell were [submitted] in response to a notice printed in the Hazleton Standard Speaker, a local newspaper. 27. Further action was taken at the July 18, 2003, special meeting by the Board to solicit bids for materials for the project. Meeting minutes contain the following: “Mr. Schell stated the Township is supplying the materials and will advertise for quotes on the various lumber and materials needed in the construction of the building. Mr. Schell made the motion to advertise for quotes for the building materials for the construction of the new Foster Township municipal building. Mr. Lesko seconded the motion. Roll call: Mr. Lesko – Yes; Mr. Schell – Yes.” a. Following a brief discussion, the decision was made for Township Solicitor Albert Maier to prepare a stipulation [against] liens document listing the Township as contractor. Meeting minutes contain the following: “Attorney Maier stated he would prepare, file, and record a stipulation against liens. Mr. Schell made the motion for attorney Maier to prepare, file, and record a stipulation against liens. Mr. Lesko seconded the motion. Roll call: Mr. Lesko – Yes; Mr. Schell – Yes.” 28. The bid for the material for the municipal building project was awarded to Shelly Enterprises, Inc. of Perkasie, Pennsylvania, at the August 8, 2003, Supervisors Schell, 09-041 Page 8 meeting. a. Meeting minutes from the August 8, 2003, meeting contain the following: “Opening of bids and awarding the material contracts for the municipal building project - Bids were open and read. Murphy Lumber - $30,298.37 Shelly Enterprise - $28,612.68 Mr. Schell made the motion to award the material contract to Shelly Enterprise for $28,612.68. Mr. Lesko seconded the motion. Roll call: Mr. Lesko – Yes; Mr. Schell – Yes.” 29. A stipulation [against] liens contract between owner Foster Township and contractor Foster Township dated July 18, 2003, shows that on the same date Foster Township entered into an agreement with Foster Township to provide materials and perform labor necessary for the construction of a new 40’ x 60’ municipal building. a. The document was signed on July 18, 2003, by Robert Lesko, Chairman of the Board of Supervisors, as both owner and contractor. 30. A Foster Township building permit for the new municipal building was approved by the Foster Township Code Enforcement Officer on July 18, 2003. a. Schell signed the application as owner on July 18, 2003. 31. A Foster Township zoning application for the purpose of building a 40’ x 60’ municipal building with dimensions of 60’ x 40’ x 18’ was approved by the Foster Township Zoning Officer on July 19, 2003. a. The application was signed by Jonas Schell on July 18, 2003, as owner. 32. No other actions regarding the construction of a municipal building were taken by the Board until or about March 2005, when Schell solicited quotes for interior aspects of the project and other finish work. 33. In or about March 2005, Schell, acting as project manager, solicited local contractors to provide estimates for various aspects of the Township building construction. a. The solicitations were not formally advertised. b. Schell contacted owners of local contracting companies to inform them that the Township was seeking estimates for work on the Township building. 1. The contractors would later meet Schell at the Township building, and Schell would then outline the various stages of the projects and the specifications to the company representatives. 34. In March 2005, Foster Township received the following estimates for work related to the municipal building: Date Amount Company Description Dennison Labor only to install drop ceilings throughout 3/7/2005 $6,689.00 Development the building Schell, 09-041 Page 9 Clause Labor to install drop ceilings throughout the 3/14/2005 $7,000.00 Construction building Dennison 8' x 14' rear PT deck, stairs, and roof, labor 3/7/2005 $4,032.00 Development only Clause 3/14/2005 $4,200.00 Construction 8' x 14' rear deck, stairs, and roof, labor only Dennison Labor only to install all interior doors and trim, 3/7/2005 $7,762.00 Development window trim, and chair rail Clause Labor to install all interior doors and trim, 3/14/2005 $7,900.00 Construction window trim, and chair rail Dennison Labor only to construct a 6' x 6' PT deck and 3/7/2005 $1,890.00 Development stairs on side of building Clause Labor to construct pressure treated 6' x 6' deck 3/14/2005 $2,000.00 Construction and stairs - side deck Dennison Front porch columns and railings and handicap 3/7/2005 $8,678.00 Development ramp to front porch and side door, labor only Clause Front porch columns and railings and handicap 3/14/2005 $8,920.00 Construction ramp to front porch and side door, labor only R.A. Bachman Sub Floor: 46 shts 4x8 1/4" plywood, labor to 4/28/2005 $1,495.54 Sales install, 2 bgs misc materials and floor leveling Joe Farko Sub Floor: 47 4'x'8' plywood 1/4", labor and 5/2/2005 $1,555.00 Flooring misc exp a. No [estimates/quotes] from J&A Schell were found on file with Foster Township for work on the municipal building. b. Schell asserts that J&A Schell did in fact submit quotes for work on the municipal building about the first week of March 2005 and that these quotes were filed at the Township building in 2005. 35. Schell presented the estimates to the other Members of the Board of Supervisors for review and discussion. a. The estimates were not presented or discussed at public meetings. b. Schell explained the scope of the estimates to the other two Supervisors and offered his recommendation as to which contractor should complete each subcontracted job. 1. This included recommending that his company, J&A Schell, be utilized. i. Schell asserts that the Supervisors chose J&A Schell to complete the work because J&A Schell had the lowest estimates. 36. Schell also presented prices to the Board that J&A Schell would charge to complete various phases of the project. a. Although no written estimates were on file with the Township, Schell asserts that he submitted written estimates to the Township for the work in March 2005. Schell, 09-041 Page 10 b. If J&A Schell’s quote for a portion of the project was lower than a competing contractor, the Board agreed to authorize J&A Schell to complete that portion. 37. No official actions were taken at public meetings to authorize J&A Schell to perform work on the municipal building. a. All discussions and decisions to utilize J&A Schell occurred outside public meetings. 38. The following chart compares bids received by Foster Township for municipal building work with the amounts that were invoiced by J&A Schell: J&A Schell Description Bid Date Bid Amount Contractor Invoice Date Amount of Work Dennison 3/7/2005 $1,890.00 Development 4/05 $1,600.00 Side deck Clause 3/14/2005 $2,000.00 Construction Dennison 3/7/2005 $4,032.00 Development 5/3/2005 $3,900.00 Rear deck Clause 3/14/2005 $4,200.00 Construction R.A. Bachman 4/28/2005 $1,495.54 Sales 5/30/2005 $1,100.00 Sub floor Joe Farko 5/2/2005 $1,555.00 Flooring Dennison 3/7/2005 $7,762.00 Development 8/5/2005 $6,800.00 Interior work Clause 3/14/2005 $7,900.00 Construction Dennison Handicap ramp, 3/7/2005 $8,678.00 Development 11/9/2005 $8,400.00 railing, porch posts Clause 3/14/2005 $8,920.00 Construction a. Although J&A Schell charges, as outlined above, were a total of $2,057.00 less than the lowest bidder’s charges, Schell had solicited the quotes/bids submitted by other contractors and had access to such quotes/bids prior to him advising the Board that his company could do the work for less. 1. Schell and the other Supervisors reviewed the submitted quotes. 39. J&A Schell began submitting invoices to Foster Township for work on the municipal building in February 2005, prior to the time that he asserts he filed quotes/bids with the Township. a. J&A Schell invoiced Foster Township a total of $30,500.00, between February 2005 and November 2005, for work completed on the Foster Township municipal building as shown below: Date Invoice Amount Description 2/27/2005 $2,400.00 26' chimney and concrete work April 2005 $7,500.00 wall angles, ceiling tiles, deck stairs and railings side of Schell, 09-041 Page 11 bldg 5/3/2005 $4,300.00 back deck, kitchen cabinet, countertop 5/30/2005 $1,100.00 1920 sq. ft. subfloor 8/5/2005 $6,800.00 interior work 11/9/2005 $8,400.00 handicap ramp - railing - porch posts 40. No bids from any contractors are on file with Foster Township for the following work that was performed by J&A Schell: Date Invoice Amount Description 2/27/2005 $2,400.00 26' chimney and concrete work 5/3/2005 $400.00 Kitchen work a. J&A Schell invoiced Foster Township $2,800.00 for services for which no estimates were solicited. 41. All materials for work completed by J&A Schell on the municipal building were furnished by Foster Township. a. Invoices submitted by J&A Schell were for labor only. b. Foster Township also purchased tools that were used by J&A Schell for work in the municipal building. 42. Foster Township Supervisors meeting minutes do not contain any official votes to authorize J&A Schell to complete any work on the Foster Township municipal building. 43. J&A Schell Contractors [was] compensated a total of $30,500.00 for invoices submitted in relation to municipal building work with the following checks: Check Date Check No. Amount Signed 3/14/2005 4715 $2,400.00 Schell, Potoskie 4/11/2005 4757 $7,500.00 Schell, Potoskie 5/9/2005 4799 $4,300.00 Lesko, Potoskie 6/13/2005 4849 $1,100.00 Schell, Potoskie 8/8/2005 4924 $6,800.00 Schell, Lesko 11/14/2005 5061 $8,400.00 Schell, Lesko a. Schell signed 5 of 6 checks that were issued to J&A Schell for work on the municipal building. 44. Schell voted to approve 5 of 6 payments totaling $26,200.00 to J&A Schell Contractors for work on the Foster Township municipal building as shown below: Check Date Check No. Amount Meeting Date Action Recorded Vote 3/14/2005 4715 $ 2,400.00 3/14/2005 motion, vote 2 to 0 4/11/2005 4757 $ 7,500.00 4/11/2005 motion, vote 3 to 0 5/9/2005 4799 $ 4,300.00 5/9/2005 absent 2 to 0 6/13/2005 4849 $ 1,100.00 6/13/2005 motion, vote 3 to 0 8/8/2005 4924 $ 6,800.00 8/8/2005 motion, vote 2 to 0 11/14/2005 5061 $ 8,400.00 11/14/2005 motion, vote 3 to 0 Schell, 09-041 Page 12 45. J&A Schell Contractor filed a Federal Income Tax Return for calendar year 2005. a. J&A Schell reported total income of $67,865.00, which reflected [its] gross receipts or sales minus the cost of goods sold. b. J&A Schell reported deductions of $36,785.00, for a total ordinary business income of $31,080.00. c. J&A Schell realized a profit percentage of 45.8% from total income reported for 2005, calculated as follows: Total income: $ 67,865.00 Ordinary business income: $ 31,080.00 Profit percentage: 45.8% 46. For the storm cleanup and the construction on the Foster Township Building, J&A Schell received a profit of $15,709.40. 47. Jonas Schell and/or J&A Schell Contractor, a business with which Jonas Schell is associated, realized a private pecuniary gain of at least $15,709.40 when Schell participated in approving contracts in excess of $500.00 between Foster Township and J&A Schell which were not awarded through an open and public process, and when Jonas Schell used the authority of his public position as Foster Township Supervisor to approve payments to J&A Schell Contractor for work done on the Township building. THE FOLLOWING FINDINGS RELATE TO THE ALLEGATIONS THAT SCHELL FAILED TO DISCLOSE ON STATEMENTS OF FINANCIAL INTERESTS FOR THE 2005, 2006, 2007, AND 2008 CALENDAR YEARS ALL DIRECT AND/OR INDIRECT SOURCES OF INCOME, FINANCIAL INTERESTS IN ANY LEGAL ENTITY ENGAGED IN BUSINESS FOR PROFIT, AND ANY OFFICE, DIRECTORSHIP, OR EMPLOYMENT OF ANY NATURE WHATSOEVER IN ANY BUSINESS ENTITY. 48. As a Supervisor for Foster Township, Jonas Schell was annually required to file a Statement of Financial Interests form by the May 1 deadline containing information for the prior calendar year. 49. A Statement of Financial Interests compliance review conducted by the Investigative Division of the State Ethics Commission on October 6, 2009, revealed the following filings by Schell: a. Calendar Year: 2004 Filed: 3/8/05 on SEC form 01/05 Position: Supervisor Occupation or Profession: Self-employed contractor Creditors: None Direct/Indirect Income: Foster Township Office, directorship or employment in any business: None All Other financial interests: None b. Calendar Year: 2005 Filed: 01/17 on SEC form 01/05 Position: Supervisor Creditors: None Direct/indirect sources of income: None Office, directorship or employment in any business: None Schell, 09-041 Page 13 All other financial interests: None c. Calendar year: 2006 Filed: 3/15/07 on SEC form 01/06 Position: Supervisor Creditors: None Office, directorship or employment in any business: None All other financial interests: None d. Calendar Year: 2007 Filed: 1/10/08 on SEC form 01/08 Position: Supervisor Creditors None Direct/indirect Income: J&A Schell Contracting Office, directorship or employment in any business: None All other financial interests: None e. Calendar Year: 2008 Filed: 3/10/09 on SEC form 01/09 Position: Supervisor Creditors: None Direct/indirect sources of income: None Office, directorship or employment in any business: None All other financial interests: None 50. Schell failed to list all sources of direct or indirect income on his Statement of Financial Interests forms for calendar years 2005, 2006, 2007, and 2008. a. Schell did not list income received from Foster Township and from J&A Schell Contractors on his 2005 calendar year form. 1. Schell’s tax return documents show that he received $15,540.00 in income from J&A Schell and $6,360.00 in income from Foster Township in 2005. b. Schell did not list income received from Foster Township and from J&A Schell Contractors on his 2006 calendar year form. 1. Schell’s tax return documents show that he received $13,113.00 in income from J&A Schell and $1,500.00 in income from Foster Township in 2006. c. Schell did not list income received from Foster Township on his 2007 calendar year form. 1. Schell’s tax return documents show that he received $1,500.00 in income from Foster Township in 2007. d. Schell did not list income received from Foster Township and from J&A Schell Contractors on his 2008 calendar year form. 1. Schell’s tax return documents show that he received $22,825.00 in income from J&A Schell and $4,989.12 in income from Foster Township in 2008. 51. Schell did not list his office, directorship, or employment in J&A Schell Contractors and his financial interest in any legal entity engaged in business for profit in J&A Schell, 09-041 Page 14 Schell Contractors on his 2005, 2006, 2007, and 2008 calendar year forms. a. Schell’s tax return documents from each calendar year show that Schell received income from J&A Schell Contractors during each calendar year. b. Schell’s tax return documents further confirm that Schell was a 50% partner in J&A Schell Contractors throughout each calendar year, from 2005 through 2008. III.DISCUSSION: As a Supervisor of Foster Township (“Township”), Luzerne County, from or about 1998 until October 13, 2008, Respondent Jonas Schell, hereinafter also referred to as “Respondent,” “Respondent Schell,” and “Schell,” 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 Schell violated Sections 1103(a), 1103(f) and 1105(b) of the Ethics Act: (1) when he used the authority of his public position for private pecuniary benefit, including but not limited to participating in discussions and actions of the Township Board of Supervisors (“Board”) to award contracts to him and/or his private business, J .A. Schell Contractor; (2) when he participated in approving payments to J.A. Schell Contractor; (3) when contracts were entered into between the Township and J.A. Schell Contractor in excess of $500.00 without an open and public process; and (4) when he failed to disclose on Statements of Financial Interests (“SFIs”) for the 2005, 2006, 2007 and 2008 calendar years all direct and/or indirect sources of income, financial interests in any legal entity engaged in business for profit, and any office, directorship, or employment of any nature whatsoever in any business entity. 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. Schell, 09-041 Page 15 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. Section 1103(f) of the Ethics Act imposes certain restrictions as to contracting: § 1103. Restricted activities (f)Contract.— No public official or public employee or his spouse or child or any business in which the person or his spouse or child is associated shall enter into any contract valued at $500 or more with the governmental body with which the public official or public employee is associated or any subcontract valued at $500 or more with any person who has been awarded a contract with the governmental body with which the public official or public employee is associated, unless the contract has been awarded through an open and public process, including prior public notice and subsequent public disclosure of all proposals considered and contracts awarded. In such a case, the public official or public employee shall not have any supervisory or overall responsibility for the implementation or administration of the contract. Any contract or subcontract made in violation of this subsection shall be voidable by a court of competent jurisdiction if the suit is commenced within 90 days of the making of the contract or subcontract. 65 Pa.C.S. § 1103(f). Section 1103(f) of the Ethics Act provides in part that no public official/public employee or his spouse or child or business with which the public official/public employee or his spouse or child is associated may enter into a contract with his governmental body valued at five hundred dollars or more or any subcontract valued at five hundred dollars or more with any person who has been awarded a contract with the governmental body with which the public official/public employee is associated unless the contract is awarded through an open and public process including prior public notice and subsequent public disclosure of all proposals considered and contracts awarded. Section 1105(b) of the Ethics Act and its subsections detail the financial disclosure that a person required to file the SFI form must provide. Subject to certain statutory exceptions not applicable to this matter, Section 1105(b)(5) of the Ethics Act requires the filer to disclose on the SFI the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more. Section 1105(b)(8) of the Ethics Act requires the filer to disclose on the SFI any office, directorship or employment in any business entity. Section 1105(b)(9) of the Ethics Act requires the filer to disclose on the SFI any financial interest in any legal entity engaged in business for profit. The term “financial interest” is defined in the Ethics Act as “[a]ny financial interest in a legal entity engaged in Schell, 09-041 Page 16 business for profit which comprises more than 5% of the equity of the business or more than 5% of the assets of the economic interest in indebtedness.” 65 Pa.C.S. § 1102. As noted above, the parties have submitted a Consent Agreement and Stipulation of Findings. The parties' Stipulated Findings are set forth above as the Findings of this Commission. We shall now summarize the relevant facts as contained therein. Respondent Schell served as a Township Supervisor from or about 1998 until October 13, 2008. The Board consists of three Supervisors. Signature authority over Township accounts is held by all three Supervisors. Checks require the signature of two Supervisors. During the time period from 2005 through late 2008, Respondent was a 50% partner with his brother in a general contracting/construction business named “J&A Schell General Contractor” (also referred to herein as “J&A,” “J&A Schell,” and “J.A. Schell Contractor”). From January 7, 2005, to January 9, 2005, a severe ice storm occurred in the Township area. From January 10, 2005, to January 13, 2005, J&A performed 40 hours of storm cleanup work for the Township without public notice or bidding and without vote of the Board. Respondent made the decision to utilize J&A to perform storm cleanup work in the Township. J&A performed the storm cleanup work at the same time that Township road crew workers were available to do the work. At the time that the storm hit, Supervisor Robert Lesko was out of town and Supervisor Thomas Potoskie was ill. Respondent did not contact Supervisor Lesko until he had already begun the work. Respondent did not discuss his decision to perform the work with Supervisor Potoskie until after the work was completed. Respondent did not advise either of the other Supervisors of the rates J&A would be charging the Township until after the work had been completed. J&A used Township equipment and Township fuel to complete the cleanup work. Supervisors Potoskie and Lesko were not aware that Township equipment was used by Respondent/J&A to complete the work. No quotes were solicited by Respondent or the Township from other vendors to provide the aforesaid services. Respondent asserts that he did not obtain formal quotes from other vendors because of the emergency nature of the work. On or about January 14, 2005, J&A submitted an invoice to the Township in the total amount of $3,800.00 for 40 hours of storm cleanup work at the rate of $95.00 per hour. J&A’s charges were just under the $4,000 threshold provided by the Second Class Township Code for requiring quotes from three contractors. (See, 53 P.S. § 68102(b)). On February 14, 2005, Township check number 4656 was issued to J&A in the amount of $3,800.00. Respondent signed check number 4656 as one of two authorized Township signatories. Respondent abstained from the Board’s vote to approve the payment to J&A for the storm cleanup work. On February 16, 2005, check number 4656 was deposited into a J&A bank account. The following facts pertain to the Township’s construction of a new municipal building. In 2003--prior to the time period that is under review in this case (see, 65 Pa.C.S. § 1108(m))--Respondent participated in Board action to approve the construction of a new Township municipal building with the Township Supervisors serving as general Schell, 09-041 Page 17 contractors, Respondent serving as the project manager, and bids being solicited for various phases of the project when necessary. As project manager for the municipal building project, Respondent had the responsibility to solicit bids when necessary for the project. In 2003 Respondent signed zoning and building permit applications for the project, solicited quotes for various aspects of the project, and participated in Board action relating to the project, including action to award certain bids. During the time period that is under review in this case, Respondent, acting as project manager, contacted local contractors in or about March 2005 to solicit estimates for various aspects of the Township municipal building construction. The solicitations were not formally advertised. Respondent met with the contractors and outlined the various stages of the project and the specifications. In March 2005, the Township received estimates for work related to the municipal building as detailed in Fact Finding 34. Respondent presented the estimates to the other Supervisors for review and discussion. The estimates were not presented or discussed at public meetings. Respondent explained the scope of the estimates to the other two Supervisors and offered his recommendation as to which contractor should complete each subcontracted job. This included recommending that J&A be utilized. Respondent presented to the Board the prices that J&A would charge to complete various phases of the project. Although no written estimates from J&A were on file with the Township, Respondent asserts that he submitted written estimates to the Township for the work in March 2005. If J&A’s quote for a portion of the project was lower than that of a competing contractor, the Board agreed to authorize J&A to complete that portion. No official actions were taken at public meetings to authorize J&A to perform any work on the municipal building. All discussions and decisions to utilize J&A occurred outside public meetings. As outlined at Fact Finding 38, J&A’s charges for certain work were a total of $2,057.00 less than the lowest bids of other contractors. However, Respondent had solicited and had access to the other contractors’ quotes/bids prior to advising the Board that J&A could do the work for less. J&A began submitting invoices to the Township for work on the municipal building in February 2005, which was prior to the time Respondent asserts he filed quotes/bids with the Township. Between February 2005 and November 2005, J&A invoiced the Township a total of $30,500.00 for work completed on the Township municipal building as shown in Fact Finding 39a. Of that amount, $2,800.00 was for services for which no estimates were solicited. J&A’s invoices for work on the municipal building were for labor only. The Township furnished all materials for work completed by J&A on the municipal building. The Township also purchased tools that were used by J&A for work on the municipal building. From March 14, 2005, to November 14, 2005, the Township issued six checks to J&A totaling $30,500.00 in payment of the invoices submitted by J&A for work on the Township municipal building. As a Township Supervisor and authorized Township signatory, Respondent signed and voted to approve five of the aforesaid checks totaling $26,200. The parties have stipulated that J&A received a profit of $15,709.40 for the storm cleanup and the construction on the Township municipal building. The parties have further stipulated that Respondent and/or J&A, a business with which Respondent is associated, realized a private pecuniary gain of at least $15,709.40 when Respondent participated in Schell, 09-041 Page 18 approving contracts in excess of $500.00 between the Township and J&A, which were not awarded through an open and public process, and when Respondent used the authority of his public position as a Township Supervisor to approve payments to J&A for work done on the Township municipal building. As for Respondent’s SFIs, Respondent failed to list all direct or indirect sources of income on his SFIs for calendar years 2005, 2006, 2007, and 2008. Respondent did not disclose on his SFI for calendar year 2005 that he had received income from the Township and from J&A, despite the fact that Respondent’s tax return documents show that he received $15,540.00 in income from J&A and $6,360.00 in income from the Township in 2005. Respondent did not disclose on his SFI for calendar year 2006 that he had received income from the Township and from J&A, despite the fact that Respondent’s tax return documents show that he received $13,113.00 in income from J&A and $1,500.00 in income from the Township in 2006. Respondent did not disclose on his SFI for calendar year 2007 that he had received income from the Township, despite the fact that Respondent’s tax return documents show that he received $1,500.00 in income from the Township in 2007. Respondent did not disclose on his SFI for calendar year 2008 that he had received income from the Township and from J&A, despite the fact that Respondent’s tax return documents show that he received $22,825.00 in income from J&A and $4,989.12 in income from the Township in 2008. Respondent did not list his office, directorship, or employment in J&A and his financial interest in J&A on his SFIs for calendar years 2005, 2006, 2007, and 2008. Having highlighted the Stipulated Findings and issues before us, we shall now apply the Ethics Act to determine the proper disposition of this case. The parties' Consent Agreement sets forth a proposed resolution of the allegations as follows: 3. The Investigative Division will recommend the following in relation to the above allegations: a. That a violation of Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. §1103(a), occurred when Schell participated in the award of contracts to J.A. Schell Contractor, a business with which Schell is associated. b. That a violation of Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. §1103(a), occurred in relation to Schell’s approving of payments to J.A. Schell Contractor, a business with which he is associated. c. That a violation of Section 1103(f) of the Public Official and Employee Ethics Act, 65 Pa.C.S. §1103(f), occurred when Schell entered into contracts between the Township and J.A. Schell Contractor, a business with which he is associated, in excess of $500.00 without an Schell, 09-041 Page 19 open and public process. d. That a violation of Section 1105(b) of the Public Official and Employee Ethics Act, 65 Pa.C.S. §1105(b), occurred when Schell failed to disclose all direct and/or indirect sources of income; his office, directorship or employment in J.A. Schell Contractor; and his financial interests in J.A. Schell Contractor on his Statements of Financial Interests filed for the 2005, 2006, 2007, and 2008 calendar years. 4. Schell agrees to make payment in the amount of $4,100.00 in settlement of this matter payable to Foster Township and forwarded to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter. 5. Schell agrees to not accept any reimbursement, compensation or other payment from Foster Township representing a full or partial reimbursement of the amount paid in settlement of this matter. 6. Schell agrees to file amended Statements of Financial Interests for calendar years 2005, 2006, 2007 and 2008 including all direct and/or indirect sources of income, financial interests in any legal entity engaged in business for profit, and any office directorship or employment or [sic] any nature whatsoever in any business entity with Foster Township within thirty (30) days of the issuance of the final adjudication in this matter. Copies of said forms shall be forwarded to the State Ethics Commission for compliance verification purposes. 7. The Investigative Division will recommend that the State Ethics Commission take no further action in this matter; and make no specific recommendations to any law enforcement or other authority to take action in this matter. Such, however, does not prohibit the Commission from initiating appropriate enforcement actions in the event of Respondent's failure to comply with this agreement or the Commission's order or cooperating with any other authority who may so choose to review this matter further. Consent Agreement, at 1-2. In considering the Consent Agreement, we agree with the parties that a violation of Section 1103(a) of the Ethics Act occurred when Respondent participated in the award of contracts to J&A. Respondent used the authority of his public office as a Township Supervisor when he made the decision to utilize J&A to perform 40 hours of storm cleanup work in the Township from January 10, 2005, to January 13, 2005. Respondent did not contact Supervisor Lesko until he had already begun the work. Respondent did not discuss his decision to perform the work with Supervisor Potoskie until after the work was completed. Without the knowledge of the other two Supervisors, J&A used Township equipment and Township fuel to complete the cleanup work. J&A received $3,800.00 for the 2005 storm cleanup work. Schell, 09-041 Page 20 With regard to the Township municipal building project, in 2005, Respondent used the authority of his public position as the Township Supervisor designated project manager when he: contacted local contractors to solicit estimates for various aspects of the project, presented those estimates to the other Supervisors outside the scope of a public meeting, and--during the course of such non-public discussions and review--recommended J&A for various aspects of the work. Having had access to the other contractors’ estimates through his official position, Respondent provided lower prices for J&A to do the work. If J&A’s quote for a portion of the project was lower than that of a competing contractor, the Board agreed to authorize J&A to complete that portion. J&A received $30,500.00 for work on the Township municipal building in 2005. J&A is a business with which Respondent is associated as a 50% partner. The parties have stipulated that J&A received a profit of $15,709.40 for the 2005 storm cleanup work and work on the Township municipal building. With each element of a violation of Section 1103(a) established, we hold that that a violation of Section 1103(a) of the Ethics Act occurred when Respondent participated in the award of contracts to J&A, a business with which Respondent is associated. In addition, the Stipulated Findings establish that a violation of Section 1103(a) of the Ethics Act occurred in relation to Respondent’s approving of payments to J&A. Respondent signed as one of two authorized Township signatories the Township check paying J&A for the 2005 storm cleanup work. Respondent signed as an authorized Township signatory and voted to approve five Township checks totaling $26,200 out of a total of six Township checks totaling $30,500.00 issued in payment of the invoices submitted by J&A for work on the Township municipal building. We hold that a violation of Section 1103(a) of the Ethics Act occurred in relation to Respondent’s approving of Township payments to J&A, a business with which he is associated. As for the allegation pertaining to Section 1103(f) of the Ethics Act, the parties have stipulated that Respondent participated in approving contracts in excess of $500.00 between the Township and J&A, which contracts were not awarded through an open and public process. The contract between the Township and J&A for the 2005 storm cleanup work was valued at $3,800.00. The contract was not awarded through an open and public process as required by Section 1103(f) of the Ethics Act. Respondent entered into the contract without the knowledge or approval of the other Supervisors. The contract was not awarded at any public meeting. The work was performed from January 10, 2005, to January 13, 2005, and J&A’s invoice for the work was submitted to the Township on or about January 14, 2005. The contract between the Township and J&A for the 2005 work on the Township municipal building was valued at $30,500.00. Outside the scope of a public meeting, Respondent presented to and discussed with the other Supervisors the estimates that had been received from other contractors and recommended J&A for various aspects of the work. Having had access to the other contractors’ estimates through his official position, Respondent provided lower prices for J&A to do the work. If J&A’s quote for a portion of the project was lower than that of a competing contractor, the Board agreed to authorize J&A to complete that portion. No official actions were taken at public meetings to authorize J&A to perform any work on the municipal building. All discussions and decisions to utilize J&A occurred outside public meetings. Schell, 09-041 Page 21 We hold that a violation of Section 1103(f) of the Ethics Act occurred when Respondent entered into contracts in excess of $500.00 between the Township and J&A, a business with which he is associated, without an open and public process. As for the allegations involving Respondent’s SFIs, we hold that a violation of Section 1105(b) of the Ethics Act occurred when Respondent failed to disclose: all direct and/or indirect sources of income; his office, directorship or employment in J&A; and his financial interest(s) in J&A, on his SFIs filed for the 2005, 2006, 2007, and 2008 calendar years. As part of the Consent Agreement, Respondent has agreed to make payment in the amount of $4,100.00 in settlement of this matter payable to Foster Township and forwarded to this Commission within thirty (30) days of the issuance of the final adjudication in this matter. Respondent has further agreed to not accept any reimbursement, compensation or other payment from the Township representing a full or partial reimbursement of the amount paid in settlement of this matter. Respondent has agreed to file with the Township, within thirty (30) days of the issuance of the final adjudication in this matter, amended SFIs for calendar years 2005, 2006, 2007 and 2008 including all direct and/or indirect sources of income, financial interests in any legal entity engaged in business for profit, and any office, directorship, or employment of any nature whatsoever in any business entity. Copies of said forms shall be forwarded to this Commission for compliance verification purposes. We determine that the Consent Agreement submitted by the parties sets forth the proper disposition for this case, based upon our review as reflected in the above analysis and the totality of the facts and circumstances. Accordingly, per the Consent Agreement of the parties, Respondent is directed to make payment in the amount of $4,100.00 payable to Foster Township and forwarded to th this Commission by no later than the thirtieth (30) day after the mailing date of this adjudication and Order. Per the Consent Agreement of the parties, Respondent is further directed to not accept any reimbursement, compensation or other payment from the Township representing a full or partial reimbursement of the amount paid in settlement of this matter. To the extent he has not already done so, Respondent is directed to file with the th Township, by no later than the thirtieth (30) day after the mailing date of this adjudication and Order, amended SFIs for calendar years 2005, 2006, 2007 and 2008 including all direct and/or indirect sources of income, financial interests in any legal entity engaged in business for profit, and any office, directorship, or employment of any nature whatsoever in any business entity, and to forward copies of all such filings to this Commission for compliance verification purposes. Compliance with the foregoing will result in the closing of this case with no further action by this Commission. Noncompliance will result in the institution of an order enforcement action. IV.CONCLUSIONS OF LAW: 1. As a Supervisor of Foster Township (“Township”), Luzerne County, from or about 1998 until October 13, 2008, Respondent Jonas Schell (“Schell”) 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. Schell, 09-041 Page 22 2. Schell violated Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), when he participated in the award of contracts to J&A Schell General Contractor, a business with which Schell is associated. 3. A violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred in relation to Schell’s approving of Township payments to J&A Schell General Contractor, a business with which he is associated. 4. A violation of Section 1103(f) of the Ethics Act, 65 Pa.C.S. § 1103(f), occurred when Schell entered into contracts in excess of $500.00 between the Township and J&A Schell General Contractor, a business with which he is associated, without an open and public process. 5. A violation of Section 1105(b) of the Ethics Act, 65 Pa.C.S. § 1105(b), occurred when Schell failed to disclose: all direct and/or indirect sources of income; his office, directorship or employment in J&A Schell General Contractor; and his financial interest(s) in J&A Schell General Contractor, on his Statements of Financial Interests filed for the 2005, 2006, 2007, and 2008 calendar years. In Re: Jonas Schell, : File Docket: 09-041 Respondent : Date Decided: 6/23/11 : Date Mailed: 7/6/11 ORDER NO. 1584 1. As a Supervisor of Foster Township (“Township”), Luzerne County, Jonas Schell (“Schell”) violated Section 1103(a) of the Public Official and Employee Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1103(a), when he participated in the award of contracts to J&A Schell General Contractor, a business with which Schell is associated. 2. A violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred in relation to Schell’s approving of Township payments to J&A Schell General Contractor, a business with which he is associated. 3. A violation of Section 1103(f) of the Ethics Act, 65 Pa.C.S. § 1103(f), occurred when Schell entered into contracts in excess of $500.00 between the Township and J&A Schell General Contractor, a business with which he is associated, without an open and public process. 4. A violation of Section 1105(b) of the Ethics Act, 65 Pa.C.S. § 1105(b), occurred when Schell failed to disclose: all direct and/or indirect sources of income; his office, directorship or employment in J&A Schell General Contractor; and his financial interest(s) in J&A Schell General Contractor, on his Statements of Financial Interests filed for the 2005, 2006, 2007, and 2008 calendar years. 5. Per the Consent Agreement of the parties, Schell is directed to make payment in the amount of $4,100.00 payable to Foster Township and forwarded to the th Pennsylvania State Ethics Commission by no later than the thirtieth (30) day after the mailing date of this Order. 6. Per the Consent Agreement of the parties, Schell is further directed to not accept any reimbursement, compensation or other payment from the Township representing a full or partial reimbursement of the amount paid in settlement of this matter. 7. To the extent he has not already done so, Schell is directed to file with the th Township, by no later than the thirtieth (30) day after the mailing date of this Order, amended Statements of Financial Interests for calendar years 2005, 2006, 2007 and 2008 including all direct and/or indirect sources of income, financial interests in any legal entity engaged in business for profit, and any office, directorship, or employment of any nature whatsoever in any business entity, and to forward copies of all such filings to the Pennsylvania State Ethics Commission for compliance verification purposes. 8. Compliance with Paragraphs 5, 6 and 7 of this Order will result in the closing of this case with no further action by this Commission. a. Non-compliance will result in the institution of an order enforcement action. BY THE COMMISSION, ___________________________ Name, Case # Page 24 Louis W. Fryman, Chair