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HomeMy WebLinkAbout1694 BradleyIn Re: John Bradley, III, File Docket: 15 -028 Respondent X -ref: Order No. 1694 Date Decided: 6/22/16 Date Mailed: 6/29/16 Before: Nicholas A. Colafella, Chair Mark R. Corrigan, Vice Chair Roger Nick Kathryn Streeter Lewis Maria Feeley Melanie DePalma This is a final adjudication of the State Ethics Commission. Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding possible violations 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 not filed. A Stipulation of Findings and a Consent Agreement 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. ALLEGATIONS: That John Bradley, III, a public official /public employee in his capacity as a Council Member for Prospect Park Borough, violated [Sections 1104(a), 1104(d), and 1105(a)] of the State Ethics Act (Act 93 of 1998) when he failed to timely file Statement of Financial Interests forms for the 2009, 2011, 2012 and 2013 calendar years; and when he subsequently filed backdated forms to give the impression that the forms were timely filed. II. FINDINGS: 1. John Bradley, 111 ( "Respondent ") has served as a Council Memberfor Prospect Park Borough, Delaware County, Pennsylvania, since approximately January 1990. 2. Prospect Park Borough Council is comprised of a seven Member board that, amongst other statutorily imposed duties, maintains supervisory responsibility over the employee position of Borough Secretary. 3. Deborah Hurst has served as the Borough Secretary /Treasurer for Prospect Park Borough since approximately 2001. Hurst serves as the custodian of all Prospect Park Borough records, including Statements of Financial Interests. Brad e , 15 -028 Page 2 b. Statements of Financial Interests for Prospect Park Borough are maintained [at] the Prospect Park Borough Municipal Building. 4. Statements of Financial Interests are required to be filed annually by elected and appointed public officials of the Commonwealth. a. The forms are required to be filed by no laterthan May 1St of each yearthata public official holds public office. b. The Statement of Financial Interests requires filers to report financial information pertaining to the preceding calendar year. 5. The State Ethics Commission annually contracts the printing of Statements of Financial Interests. a. Orders for forms are generally placed with the printing company in December of each year. b. The ordered forms are received by the Administrative Division of the State Ethics Commission in December, prior to January 1St of the filing year. C. Forms are then bulk mailed to each municipality in the Commonwealth of Pennsylvania. 6. Pursuant to the procedure outlined above, Statement of Financial Interests forms were annually mailed to Prospect Park Borough, Delaware County, by the Administrative Division of the State Ethics Commission. 7. Statement of Financial Interests forms were annually mailed to Prospect Park Borough between 2009 and the present. a. For filing year 2009, SEC -1, Rev. 01/10 forms were mailed to all municipalities in the Commonwealth, including Prospect Park Borough, on or around December 31, 2009. The SEC -1, Rev. 01/10 [forms] were to be used in reporting financial interests for the 2009 calendar year. b. For filing year 2011, blank SEC -1, Rev. 01/12 forms were mailed to all municipalities in the Commonwealth, including Prospect Park Borough, on or around January 9, 2012. C. Blank SEC -1, Rev. 01/13 forms were mailed to all municipalities in the Commonwealth, including Prospect Park Borough, on or around December 31, 2012. The SEC -1, Rev. 01/13 [forms] were to be used in reporting financial interests for the 2012 calendar year. d. In 2013, blank SEC -1, Rev. 01/14 [forms] were mailed to all municipalities in the Commonwealth, including Prospect Park Borough, on or around December 26, 2013. The SEC -1, Rev. 01/14 [forms] were to be utilized in reporting financial interests for calendar year 2013. Bradley, 15 -028 Page 3 8. Each year that forms are printed, a revision number is listed in the upper left hand corner of the form. a. Forms printed in 2009 contained an identification number of SEC -1, Rev. 01/10 while forms printed in 2011, 2012 and 2013 contained identification numbers of SEC -1, Rev. 01/12, SEC -1, Rev. 01/13, and SEC -1, Rev. 01/14 respectively. b. The revision number [Rev.] would correspond with the year in which the filing was to take place. For example, form Rev. 01/12 was to be filed in the year 2012. 9. Deborah Hurst, Prospect Park Borough Secretary, is responsible forthe distribution of Statement of Financial Interests forms to Borough public officials and employees who are required to file the Statement of Financial Interests. a. Hurst provided blank Statement of Financial Interests forms for all Prospect Park Borough officials, including Council Member John Bradley, III, in or around January of each year. b. Hurst attempted to obtain timely compliance from all public officials in Prospect Park Borough, including the Council Members, concerning the filing of their Statements of Financial Interests. 10. John Bradley, III, in his capacity as a Prospect Park Borough Council Member, was annually required to file a Statement of Financial Interests form by May 1St with information pertaining to the prior calendar year. 11. Bradley, as a Prospect Park Borough Council Member, was provided with blank Statement of Financial Interests forms each year by Borough Secretary Deborah Hurst, for completion. a. Hurst provided Bradley with forms to be completed in calendar years 2009, 2010, 2011, 2012, 2013, and 2014. 12. On or around January 30, 2015, a Right -to -Know Request was submitted by a Borough resident to the Prospect Park Borough Municipal Office, requesting duplicate copies of the following information: a. Statements of Financial Interests for Councilman John Bradley, representing financial interests for calendar years 2013, 2012, 2011, 2010, 2009, and 2008. 13. On or around February 4, 2015, Borough Secretary Deborah Hurst, who also serves as the Right -to -Know Officer for Prospect Park Borough, responded in part to the Right -to -Know Request as follows: a. "Please be advised that the Borough requires additional time to provide the records requested to allow for remote storage of the records involved forthe request regarding `State Ethics Commission's Statement of Financial Interest for Councilman John Bradley for calendar years 2008, 2009, 2010, 2011, 2012, and 2013. "' 14. On or around February 4, 2015, Hurst could not locate the Statements of Financial Interests that were filed by John Bradley for calendar years 2008 through 2013. Brad e , 15 -028 Page 4 a. A copy of Bradley's timely filed 2010 calendar year Statement of Financial Interests was later located by Borough officials. 15. On or about February 4, 2015, Hurst advised Bradley that a Right -to -Know Request had been submitted, and that his (Bradley's) Statements of Financial Interests for years 2008, 2009, 2011, 2012, and 2013 were not located. 16. On or around February 4, 2015, John Bradley 111, in his capacity as a Prospect Park Borough Council Member, filed Statements of Financial Interests for calendaryears [2008, 2009, 2011, 2012, and 2013], listing his public position and governmental entity, and affixing his signature and purported date he signed /completed the form, as follows: Calendar Year Purported Date of Completion SEC Form Used 2008 2/10/2009 SEC -1 Rev. 01/15 2009 2/8/2010 SEC -1 Rev. 01/15 2011 2/14/2012 SEC -1 Rev. 01/15 2012 2/10/2013 SEC -1 Rev. 01/15 2013 2/11/2014 SEC -1 Rev. 01/15. a. Bradley's 2008, 2009, 2011, 2012, and 2013 Statements of Financial Interests contained dates of execution /completion which were factually impossible, as SEC -1, Rev. 01/15 was not printed /distributed until January 2015. b. It was impossible for Bradley to have completed these forms on the dates purported (as signed) as the forms had not yet then been distributed. 17. On April 15, 2015, and again on April 29, 2015, a Statement of Financial Interests Compliance Review was conducted at Prospect Park Borough by a State Ethics Commission Investigator. a. The purpose of the compliance review was to review the Statement of Financial Interests forms that were completed by all Borough officials. b. During this review, calendar year 2008, 2009, 2010, 2011, 2012, 2013, and 2014 Statements of Financial Interests filed by John Bradley were maintained within Borough files. 18. The Statement of Financial Interests forms on file for Bradley for calendar years 2008 through 2014 at Prospect Park Borough, in part, listed the following information: a. Calendar Year- Dated - Public Position: Governmental Entity: Direct or Indirect Sources of Income: Q 2008 2/10/2009 on Form SEC -1 Rev. 01/15 Council Prospect Park ADP 1125 Virginia Dr., Fort Washington. Brad e , 15 -028 Page 5 Calendar Year: 2009 Dated: 2/8/2010 on Form SEC -1 Rev. 01/15 Public Position: Borough Council Governmental Entity: Prospect Park Direct or Indirect Sources of Income: ADP 1125 Virginia Dr., Fort Washington. C. Calendar Year: 2010 Dated: 3/06/2011 on Form SEC -1 Rev. 01/11 Public Position: Council Governmental Entity: Prospect Park Borough Direct or Indirect Sources Of Income: ADP Fort Washington, PA. Calendar Year: 2011 Dated: 2/14/2012 on Form SEC -1 Rev. 01/15 Public Position: Council Governmental Entity: Prospect Park Direct or Indirect Sources of Income: ADP 1125 Virginia, Fort Washington, PA. e. Calendar Year: 2012 Dated: 2/10/13 on Form SEC -1 Rev. 01/15 Public Position: Council Governmental Entity: Prospect Park Direct or Indirect Sources of Income: ADP 1125 Virginia Dr., Fort Washington, PA 19034. f Calendar Year: 2013 Dated: 2/11/14 on Form SEC -1 Rev. 01/15 Public Position: Borough Council Governmental Entity: Prospect Park Direct or Indirect Sources of Income: ADP 1125 Virginia Dr., Fort Washington, PA 19034. Calendar Year: 2014 Dated: 2/4/2015 on Form SEC -1 Rev. 01/15 Public Position Council Governmental Entity: Prospect Park Direct or Indirect Sources of Income: ADP 1125 Virginia Dr., Fort Washington, PA 19034. Brad e , 15 -028 Page 6 19. Prospect Park Borough Secretary Deborah Hurst confirmed that the Statement of Financial Interests forms filed by Bradley were not filed on the dates reflected on the forms. 20. On or around February 4, 2015, Bradley completed calendar year 2008, 2009, 2011, 2012, and 2013 Statement of Financial Interests forms and arbitrarily selected and affixed a date of when he believed the forms should have been completed. 21. Bradley's backdated filings created the impression that he was complying with the filing requirements of the law. 22. The compliance reviews which were conducted on April 15, 2015, and again on April 29, 2015, confirmed that Bradley had previously filed a Statement of Financial Interests form for calendar year 2010, which contained a signature date of March 6, 2011 (03/06/2011). a. Bradley's 2010 calendar year Statement of Financial Interests was filed on SEC -1 Rev. 01/11. b. Bradley filed the form as a candidate for Borough Council and as a current Council Member. 23. Bradley submitted backdated Statement of Financial Interests forms for calendar years 2009, 2011, 2012 and 2013 after being advised that a Right -to -Know Request had been made by a Borough resident requesting copies of Bradley's Statements of Financial Interests for calendar years 2008 through 2013. a. Bradley inserted arbitrary dates to create the impression the forms were timely filed. 24. As a Borough Council Member, Bradley was annually compensated $1,800.00 for executing his duties as a public official. 25. Section 1104(d) of the Ethics Act, 65 Pa.C.S. § 1104(d), states that no public official shall receive compensation from public funds unless he has filed a Statement of Financial Interests. 26. Bradley annually accepted compensation from the public funds of Prospect Park Borough, as a Borough Council Member, during calendar years 2009, 2011, 2012, and 2013, at a time when he did not have timely /properly filed Statement of Financial Interests forms on file with the Borough as follows: a. 2009: $1,800.00 2011. $1,800.00 2012. $1,500.00 2013. $1 800.00 Total 6,900.00. 27. On March 4, 2016, Bradley filed amended Statement of Financial Interests forms for calendar years 2008 through 2014. a. Bradley filed the amended forms voluntarily to correct backdated forms and deficiencies on prior filings. III. DISCUSSION: Brad e , 15 -028 Page 7 As a Council Member for Prospect Park Borough ( "Borough "), Delaware County, Pennsylvania, since approximately 1990, Respondent John Bradley, III, also referred to herein as "Respondent," "Respondent Bradley," and "Bradley," has been a public official subject to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seg. The allegations are that Bradley violated Sections 1104(a), 1104(d), and 1105(a) of the Ethics Act when he failed to timely file Statement of Financial Interests ( "SFI ") forms for the 2009, 2011, 2012 and 2013 calendar years, and when he subsequently filed backdated forms to give the impression that the forms were timely filed. Per the Consent Agreement, the Investigative Division has exercised its prosecutorial discretion to nol pros the allegation under Section 1104(d) of the Ethics Act. Based upon the nol pros, we need not address the Section 1104(d) allegation that is no longer before us. Section 1104(a) of the Ethics Act provides that each public official /public employee must file an SFI for the preceding calendar year, each year that he holds the position and the year after he leaves it. Section 1105(a) of the Ethics Act provides that the SFI shall be filed on the form prescribed by this Commission; that all information requested on the form shall be provided to the best of the knowledge, information and belief of the filer; and that the form shall be signed under oath or equivalent affirmation. 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. As a Borough Council Member, Bradley is required to annually file an SFI by May 1 disclosing financial information for the prior calendar year. This Commission contracts for the annual printing of SFI forms. Each year when forms are printed, a revision number is listed in the upper left hand corner of the form. Pertinent to the instant matter, SFI forms printed for use with filings for calendar years 2009, 20117 2012, and 2013 contained revision numbers of SEC -1, Rev. 01/10; SEC -1, Rev. 01/12; SEC -1, Rev. 01/13; and SEC -1, Rev. 01/14, respectively. This Commission mailed blank SFI forms to the Borough for use with the aforesaid calendar year filings as follows: (1) SEC -1, Rev. 01/10 forms, for use with calendar year 2009 filings, mailed on or around December 31, 2009; (2) SEC -1, Rev. 01/12 forms, for use with calendar year 2011 filings, mailed on or around January 9, 2012; (3) SEC -1, Rev. 01/13 forms, for use with calendar year 2012 filings, mailed on or around December 31, 2012; and (4) SEC -1, Rev. 01/14 forms, for use with calendar year 2013 filings, mailed on or around December 26, 2013. Deborah Hurst ( "Hurst ") has served as the Borough Secretary /Treasurer since approximately 2001. In or around January of each year from 2009 through 2014, Hurst provided Bradley with blank SFI forms for completion. Hurst serves as the custodian of all Borough records, including SFIs. The SFIs filed by Borough officials /employees are maintained at the Borough Municipal Building. Hurst also serves as the Right -to -Know Officer for the Borough. On or around January 30, 2015, a Borough resident submitted a Right -to -Know request to the Borough Municipal Office, requesting copies of SFIs for Bradley for the 2008 through 2013 calendar Brad e , 15 -028 Page 8 years. On or around February 4, 2015, Hurst responded in part to the Right -to -Know request by advising that the Borough required additional time to provide the records requested to allow for remote storage of the records involved. On or around February 4, 2015, Hurst could not locate SFIs for Bradley for calendar years 2008 through 2013. A copy of Bradley's timely filed 2010 calendar year SFI was later located by Borough officials. On or around February 4, 2015, Hurst advised Bradley that a Right -to -Know request had been submitted and that Bradley's SFIs for the 2008, 2009, 2011, 2012, and 2013 calendar years were not located. On or around February 4, 2015, Bradley filed SFIs for calendar years 2008, 2009, 2011, 2012, and 2013. The SFIs were signed with purported dates of completion as follows: (1) calendar year 2008, dated 2/10/2009; (2) calendar year 2009, dated 2/8/2010; (3) calendar year 2011, dated 2/14/2012; (4) calendar year 2012, dated 2/10/2013; and (5) calendar year 2013, dated 2/11/2014. The SFI for each of the aforesaid calendar years was completed using an SEC -1 Rev. 01/15 form. It was impossible for Bradley to have completed the SFI forms on the dates purported because the SEC -1 Rev. 01/15 form was not distributed until January 2015. Bradley arbitrarily selected and affixed to each SFI a date of when he believed the form should have been completed in order to create the impression that the forms were timely filed. On March 4, 2016, Bradley voluntarily filed amended SFIs for calendar years 2008 through 2014 to correct backdated forms and deficiencies on prior filings. 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 1104(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1104(a), occurred when Respondent, in his capacity as a Council Member for Prospect Park Borough, failed to timely file Statement of Financial Interests forms forthe 2009, 2011, 2012 and 2013 calendar years; b. That a violation of Section 1105(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1105(a), occurred when Respondent filed backdated 2009, 20117 2012 and 2013 calendar year Statement of Financial Interests forms in his capacity as a Council Member for Prospect Park Borough, falsely giving the impression that the forms were timely filed; [and] C. That no action will be undertaken pursuant [to] Section 11 04(d the Public Official and Employee Ethics Act, 65 Pa. S. § 1104(d). Bradley agrees to make payment in the amount of $1,250.00 in settlement of this matter as follows: Bradley, 15 -028 Page 9 a. $1,000.00 payable to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter. b. $250.00 which represents a portion of the expenses and costs incurred by the State Ethics Commission in the investigation and administrative prosecution of the instant matter, payable by certified check or money order made payable to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter. 5. To the extent he has not already done so, Bradley agrees to file complete and accurate Statements of Financial Interests with Prospect Park Borough through the Pennsylvania State Ethics Commission, for 2009, 2011, 2012 and 2013 calendar years within thirty (30) days of the issuance of the final adjudication in this matter. 6. Bradley agrees to not accept any reimbursement, compensation or other payment from Prospect Park Borough representing a full or partial reimbursement of the amount paid in settlement of this matter. 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 accept the parties' recommendation fora finding that a violation of Section 1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), occurred when Respondent, in his capacity as a Borough Council Member, failed to timely file SFI forms for the 2009, 2011, 2012 and 2013 calendar years. On or around January 30, 2015, a Borough resident submitted a Right -to -Know request to the Borough, requesting copies of Bradley's SFIs for the 2008 through 2013 calendar years. On or around February 4, 2015, Borough Secretary/Treasurer Hurst could not locate SFIs for Bradley for calendar years 2008 through 2013. A copy of Bradley's timely filed 2010 calendar year SFI was later located by Borough officials. Based upon the Stipulated Findings and Consent Agreement, the parties are in agreement that the SFIs that Hurst was unable to locate for calendar years 2009, 2011, 2012 and 2013 were not timely filed by Bradley. We hold that a violation of Section 1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), occurred when Respondent, in his capacity as a Borough Council Member, failed to timely file SFI forms for the 2009, 2011, 2012 and 2013 calendar years. We further hold that a violation of Section 1105(a) of the Ethics Act, 65 Pa.C.S. § 1105(a), occurred when Respondent filed backdated 2009, 2011, 2012 and 2013 calendar Bradle , 15 -028 Page 10 year SFI forms in his capacity as a Borough Council Member, falsely giving the impression that the forms were timely filed. As part of the Consent Agreement, Respondent Bradley has agreed to make payment in the amount of $1,000.00 payable to the Commonwealth of Pennsylvania and forwarded to this Commission within thirty (30) days of the issuance of the final adjudication in this matter. Respondent Bradley has further agreed to make payment to this Commission in the amount of $250.00, representing a portion of the expenses and costs incurred by this Commission in the investigation and administrative prosecution of the instant matter, payable by certified check or money order made payable to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter. Respondent Bradley has agreed to not accept any reimbursement, compensation or other payment from the Borough 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 Bradley has agreed to file complete and accurate SFIs with the Borough, through this Commission, for the 2009, 2011, 2012 and 2013 calendar years within thirty (30) days of the issuance of the final adjudication in this matter. We determine that the Consent Agreement submitted by the parties sets forth a 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 Bradley is directed to make payment in the amount of $1,000.00 payable to the Commonwealth of Pennsylvania and forwarded to this Commission by no later than the thirtieth (30t ) day after the mailing date of this adjudication and Order. Per the Consent Agreement of the parties, Respondent Bradley is further directed to make payment to this Commission in the amount of $250.00, representing a portion of the expenses and costs incurred by this Commission in the investigation and administrative prosecution of the instant matter, payable by certified check or money order mpde payable to the Pennsylvania State Ethics Commission by no later than the thirtieth (30t ) day after the mailing date of this adjudication and Order. Per the Consent Agreement of the parties, Respondent Bradley is directed to not accept any reimbursement, compensation or other payment from the Borough 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 Bradley is directed to file complete and accurate SFIs with the Borough, through this Commission, for the 2009, 2011, 2012 and 2013 calendar years by no later than the thirtieth (30t ) day after the mailing date of this adjudication and Order. 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 Council Member for Prospect Park Borough ( "Borough "), Delaware County, Pennsylvania, since approximately 1990, Respondent John Bradley, III ( "Bradley ") Bradle , 15 -028 Page 11 has been a public official subject to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq. Bradley violated Section 1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), when, in his capacity as a Borough Council Member, he failed to timely file Statement of Financial Interests forms for the 2009, 2011, 2012 and 2013 calendar years. A violation of Section 1105(a) of the Ethics Act, 65 Pa.C.S. § 1105(a), occurred when Bradley filed backdated 2009, 2011, 2012 and 2013 calendaryear Statement of Financial Interests forms in his capacity as a Borough Council Member, falsely giving the impression that the forms were timely filed. In Re: John Bradley, III, File Docket: 15 -028 Respondent Date Decided: 6/22/16 Date Mailed: 6/29/16 ORDER NO. 1694 1. As a Council Member for Prospect Park Borough ( "Borough "), Delaware County, Pennsylvania, John Bradley, III ( "Bradley ") violated Section 1104(a) of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1104(a), when, in his capacity as a Borough Council Member, he failed to timely file Statement of Financial Interests forms for the 2009, 2011, 2012 and 2013 calendar years. 2. A violation of Section 1105(a) of the Ethics Act, 65 Pa.C.S. § 1105(a), occurred when Bradley filed backdated 2009, 2011, 2012 and 2013 calendaryear Statement of Financial Interests forms in his capacity as a Borough Council Member, falsely giving the impression that the forms were timely filed. 3. Per the Consent Agreement of the parties, Bradley is directed to make payment in the amount of $1,000.00 payable to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State Ethics Commission by no later than the thirtieth (30th) day after the mailing date of this Order. 4. Per the Consent Agreement of the parties, Bradley is further directed to make payment to the Pennsylvania State Ethics Commission in the amount of $250.00, representing a portion of the expenses and costs incurred by this Commission in the investigation and administrative prosecution of the instant matter, payable by certified check or money order made payablt� to the Pennsylvania State Ethics Commission by no later than the thirtieth (30 ) day after the mailing date of this Order. Per the Consent Agreement of the parties, Bradley is directed to not accept any reimbursement, compensation or other payment from the Borough representing a full or partial reimbursement of the amount paid in settlement of this matter. To the extent he has not already done so, Bradley is directed to file complete and accurate Statements of Financial Interests with the Borough, through the Pennsylvania State Ethics Commission, for the 2009, 2011, 2012 and 2013 calendar years by no later than the thirtieth (30t h) day after the mailing date of this Order. Non - compliance with paragraph 3, 4, 5 or 6 of this Orderwill result in the institution of an order enforcement action. BY THE COMMISSION, Nicholas A. Colafella, Chair