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STATE ETHICS COMMISSION
FINANCE BUILDING
613 NORTH STREET, ROOM 309
HARRISBURG, PA 17120-0400
In Re: Vanessa Lowery Brown, File Docket:
Respondent X-ref:
Date Decided
Date Mailed:
FACSIMILE: 717.767-0806
WEBSITE: www.ethIcs.I2&,_qqy
14-017
Order No. 1756
6/28/19
7/1/19
Before: Nicholas A. Colafella, Chair
Mark R. Corrigan, Vice Chair
Roger Nick
Melanie DePalma
Monique Myatt Galloway
Michael A. Schwartz
Shelley Y. Simms
This is a final adjudication of the State Ethics Commission.
Procedurally, the Investigative Division of the State Ethics Commission conducted
an investigation regardingpossible violation(s) of the Public Official and Employee Ethics
Act ("Ethics Act"), 5 Pa.C.S. § 1101 et seg,, by the above -named Respondent. At the
commencement of its investigation, tli-e- ffivestigative 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." 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.
ln�=%
That Representative Vanessa Brown, a public official/public employee in her
capacity as a Member of the Pennsylvania General Assembly, House of Re resentatives,
specificall representin the190th District, [violated Sections 1 103(a) 1103rc))1105(b)(5),
11 05(b)(6 (7) of the Ethics Act when she] solicited and)or accepted items of
monetary value, including cash, [and/or a] cash gift, loan, and/or political contribution,
based on the understanding, that her action as a Member of the House of Representatives,
including
official action and/or judgment, would be influenced by receipt of said items of
value, including cash; and when she failed to disclose on her] Statement of Financial
Interests for the 2011 calendar year [that she filed as her]
of the [1 901h]
District her receipt of cash payments as ever a direct or indirect source of income and/or
gift(s); and when she failed to disclose her receipt of transportation lodling and hospitality
in excess of $650.00 on her Statement of Financial Interests filed for he 2011 calendar
year.
Vanessa Lowery Brown ("Brown") was a Member of the Pennsylvania House of
Representatives, representing the I 90th Legislative District.
Brown was first elected in 2008 and was reelected [five] times,
The 1 90th Legislative District covers parts of the City of Philadelphia.
Brown� 14-017
NiVw--
2. Tyron B. Ali ("Ali") was a registered lobbyist.
a. Ali was a registered lobbyist with the Pennsylvania Department of State from
about April 2008 to 2012.
1. Ali had a lobbyist registration number of L08823.
2. Ali's registration expired and was not renewed.
b. Ali held no elected or appointed offices.
1 In or about 2010, Ali became a confidential informant for the Pennsylvania Office of
Attorney General.
a. In his role as an undercover informant, Ali was directed to make contact with
elected officials from Philadelphia.
4. As part of a sting operation organized by the Pennsylvania Office of Attorney
General, beginning in or about October2010, Ali began making contact with elected
officials from Philadelphia.
a. Brown was one such elected official from Philadelphia who was contacted by
Ali.
5. Ali first approached Brown on or about January 1, 2011, at a New Year's Day get-
together.
6. At a meeting on January 28, 2011, Brown declined to accept an offer of $1,000 in
cash from Ali.
7. Ultimately, between February 2011 and May 2011, Brown received cash from Ali on
five occasions, totaling $4,000.00.
8. The money provided to Brown by Ali totaled as follows:
February 11, 2011: $ 500.00
February 14, 2011: $ 500.00
March 9, 2011: 500.00
April 22, 2011: 1 500.00
May 23, 2011: $2,000.00
$4,000M
9. The payments made by Ali to Brown occurred on two occasions at Philadelphia
restaurants and on three occasions at Brown's office at the Capitol Complex.
10, In her capacity as an elected public official, Brown was required to file Statements of
Financial Interests ("SFls").
a. Sources of income in excess of $1,300.00 and gift amounts [of $250.00 or
more] in the aggregate from a single source [are to be listed on the SFI],
b. Creditors in excess of $6,500.00, and transportation, lod ing and hospitality
sources in excess of $650.00 [are to be listed on the SPI],
C. Forms are required to be filed b May 1st of each year a person holds office
and one year after leaving a public office.
Brown, 14-017
PIN4��
11. Brown filed SFls with the State Ethics Commission as follows:
12. The SFI filed by Brown on February 6, 2013, for calendar year 2011 included, in
part, the following information:
a. Direct/Indirect Sources of Income (No. 10):
House of Representatives
b. Gifts (No. 11):
PECO Dinner value $500.00
C. Transportation, Lodging, Hospitality (No. 12):
None
13. During calendar year 2011, Brown received travel, hospitality and/or lodging which
was paid for and provided by "Women in Government."
a. Specifically, Brown attended the Third Annual Energy Summit held August
24-25, 2011; the Thirteenth Annual Eastern Regional Conference Cd
August 25-27, 2011; the Outreach to Vulnerable Populations Conference
he8Asugust 27-28, 2011; and a program for the Diabetes Task Force held
March 4-6, 2011, at Naples Grand 6each Resort, Naples, Florida.
14, Total travel, hospitality and lodging which was received by Brown and provided by
"Women in Government' included:
a.[Third Annual Energy Summit, Thirteenth Annual Eastern Regional
Conference, and Outreach to Vulnerable Populations Conference]:
0 Hotel Room: $424.66
0 Meals:
Third Annual Energy Summit: $264.32
Thirteenth Annual Eastern Regional Conference: $397.00
0 Outreach to Vulnerable Populations Conference: $179.52
• Total [hospitality and lodging provided]: $1,265.50.
b. Diabetes Task Force:
0 Hotel Room: $292.90
• Travel: $350.00. Check Reimbursement ("Women in Government"
deducted $150.00 for registration fee from the full reimbursement of
$500.00). Total reimbursement $500.00
0 Meals: $495.00
Brown, 14-017
F -a-g —e4
• Total [travel, hospitality and lodging provided]: [approximately]
$1,224.90.
15. [GeneralYj the Penwlvania Public Official and Employee Ethics Act, 65 Pa.C.S. §
11 05(b)( requires S Is to include travel, hospitality and/or lodging which is paid
for by a third party in excess of $650,00 in the aggregate.
16. Duri calendar year 2011, Brown received travel, hospitality and lodging provided
b� ( Women in Government" in a total aggregate amount of [approximately]
$ 490.40.
17. Brown failed to disclose her receipt of travel, hospitality and lodging in excess of
11
$650.00 provided by "Women in Government" on the SH she filed for the 2011
calendar year.
18. Brown did not initially disclose the receipt of the $4,000.00 in cash payments she
accepted from Ali during 2011 on the SRform she filed for the 2011 calendar year,
a. Brown filed an initial calendar year 2011 SFI with the State Ethics
Commission on or about February 6, 2013.
b. Brown's initial calendar year 2011 SH was filed approximately nine months
after the deadline to do so.
C. The cash accepted by Brown in 2011 exceeded the reporting thresholds and
was required to be disclosed on [Brown's calendar year 2011 SFI],
19. Brown did not report cash received from Ali on an campaign finance reports filed
b her, or on her behalf, with the Pennsylvania Qartment of State, Bureau of
0 ETections.
20. Brown appeared before the 27th Philadelphia County Grand Jury and offered
testimony that included the following:
a. She took the five cash payments from Ali totaling $4,000.00; and
b. Until that time, Brown had not disclosed the receipt of the payments from Ali
on any campaign finance reports or SFls.
21. On January 13, 2017, Brown filed an amended calendar year 2011 SH with the
State Ethics Commission.
a. In filing her amended 2011 form, Brown disclosed the following:
Vanessa Lowery Brown SFIs (Amended) — 2011
Attachment "A"
11. GIFTS
1 Source of Gift: PECO Pennsylvania Electric Company)
Dinner
Value of Gift: $500.00
Address Source of Gift: PECO
2301 Market Street
Philadelphia, PA 19103
Brown 14-017
PA�6�_
Circumstances (including description) of Gift: The PECO
dinner was part of a Pennsylvania Society weekend celebration
in New York City,
2. Source of Gifts: Tyron Ali
Value of Gift: $4,555.00
Address Source of Gift: 2001 West Cambria Street,
Philadelphia, PA 19132
Circumstances (including description) of Gift,
* Cash was given to me as a gift on the following dates:
2/11/ "0.00 2/14/11 500.00 1 1500.00
4/22/11 $500.00 and
5/23/11 $2,000. 0).
• Eleven meals were given to me as Ifts. The meal
values are approximated at a total of $?15 for all twelve
meals. The specific dates and approximate costs are as
follows:
1/21/11
M:000)� 1/28f 11 31 0
2/11/11 38.00
2/21/11 M.00
3/01 f 11 1$26.00
3/18/11 52.00
3/25/11 61.00
4/05/11 $38,00
4/22/11 t42.00
5/02f 11 71,00 and
6/07/11 $75.00
A pastry was given tome as a gift onApril 22, 2011,
Its estimated value was $10.
• Chocolates were given tome as a gift in approximately
May 2011. The estimated value of the chocolates was
$2
Total value of gifts from all sources: $5,056.00.
22. On October 31, 2018, following a trial by jury, a verdict was returned a ainst Brown,
finding her guilty of violating provisions of law, including] Pa.C.S.?l 103(c) and
65 Pa.C.S. § 1 1a). See, CP-22-CR-0000525-201 . hat verdict and resulting
sentence are currentIT—in'a posture of post -conviction review and appeal is
anticipated if necessary.
23. Pending the outcome of all post -conviction motions, on November 30, 2018, Brown
paid $4,000.00 to cover restitution owed based on her conviction and sentence.
Ill. DISCUSSION:
Brown 14-017
fi-P-%
As a Member of the Pennsylvania General Assembly, House of Representatives
("House of Representatives"), Respondent Vanessa Lowery Brown, also referred to
'1
hereinafter as 'Respondent,' " Res ondent Brown," and "Brown," 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,1
The allegations are that Brown violated Sections 1103(a), 1103(c), 1105(b)(5),
=(6), and 11 0511b)(7) of the Ethics Act when she solicited and/or accepted items of
ryvalue, including cash and/or a cash gift, loan, arid/or political contribution, based
on the understanding that her action as a Member of the House of Representatives
including official action and/or judgment, would be influenced by receipt of said items of
value, including cash; when she failed to disclose on her Statement of Pinancial Interests
("SFI") for the 2011 calendar year her receipt of Gash payments as either a direct or indirect
source of income and/or gift(s); and when she failed to disclose her receipt of
transportation, lodging and hospitality in excess of $650.00 on her SFI filed for the 2011
calendar year.
Per the Consent Agreement of the parties, the Investigative Division has exercised
irosecutorial discretion to nol pros the allegations under Sections 1103(a 1103(c),and
tsM5(b)(5) of the Ethics Act. Based upon the nol pros, we need noNddress the
allegations no longer before us.
Section 1101a) of the Ethics Act provides that each public official/public employee
must file an SFI for t e preceding calendar year, each year that he holds the position and
the year after he leaves it.
Section1105(b of the Ethics Art and its subsections detail the financial disclosure
that a person requirZto file the SFI form must provide.
Subject to certain statutory exceptions not applicable to this matter, Section
11 05(b)(6) of the Ethics Act requires the filer to disclose on the SFI the name and address
of the source and the amount of any gift or gifts valued in the aggregate at $250 or more
and the circumstances of each gift.
Subject to certain statutory exceptions not applicable to this matter, Section
11 05(b)(7) of the Ethics Act requires the filertodisclose on the SFI the name and address
of the source and the amount of any payment for or reimbursement of actual expenses for
transportation and lodging or hospitality received in connection with public office or
employment where such actual expenses exceed $650 in an aggregate amount per year.
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.
Brown was first elected as a Member of the House of Representatives in 2008, and
she was reelected five times. Brown represented the 190th Legislative District, which
covers parts of the City of Philadelphia ("Philadelphia").
Tyron B. Ali ("Ali' was a registered lobbyist with the Pennsylvania Department of
State from about 08 to 2012. In or about 2010, Ali became a confidential informant
for the Pennsylvania Office of Attorney General. Beginning in or about October 2010, Ali
began making contact with elected officials from Philadelphia as part of a sting operation
organized by the Pennsylvania Office of Attorney General.
1 We take administrative notice that Brown resited from the House of Representatives on December 11,
2018. See, https:/Iwww. legis. state. pa. us. cfdocs/ egis. Bios H isto[y/Mem Bio.dfm? I D= 1162 &body=
Brown, 14-017
P — age 7
On or about January 1, 2011, Ali a roached Brown at a New Year's Day get -
to ether. At a meeting on January 28, 2011, Brown declined to accept an offer of
10 R.000 00 in cash from Ali. Brown ultimatelyacre ted five cash payments totaling
$4:000.'00 from Ali between February UZI y11,2011,and ay23,2011. Brown did not report
the cash payments that she received from Ali on any campaign finance reports filed by her
or on her behalf with the Pennsylvania Department of State, Bureau of Elections.
During calendar year 2011, Brown received travel, hospitality, and lodging totaling
approximately$2,490.40 from "Women In Government" when she attended: a program
for the Diabetes Task Force held from March 4, 2011, to March 6, 2011; the Third
Annual Energy Summit held from August 24, 2011, to August 25, 2011; (3) the Thirteenth
Annual Eastern Regional Conference held from August 25, 2011„ to August 27, 2011; and
4) the Outreach to Vulnerable Populations Conference held from August 27, 2011, to
August 28, 2011.
In her official capacity as a Member of the House of Representatives, Brown was
required to file an SFI form by May I annually containing information for the prior calendar
ar. 0
February
Brown filed an SFI for calendar year 2011 with the State Ethics Commission on
6, 2013. Brown failed to disclose her receipt of travel, hospitality, and lodging in
excess of $650.00 provided by "Women in Government" and her recei t of cash payments
totaling $4,000.00 rom Ali on the SFI that she filed for calendar year 2�1 1. On January 13,
2017, Brown filed an amended SFI for calendar year 2011 with the State Ethics
Commission. Brown disclosed the aforesaid cash payments that she received from Ali as
gifts on her amended SFI for calendar year 2011.
On October 31, 2018, following a jurytrial in the Dau hin County Court of Common
Pleas, Brown was found guilty of ections 1103(c and 1105(a) of the Ethics Act
and other laws. Pending the outcome ol'ost-conviction motions and any appeal, Brown
paid $4,000.00 to cover restitution owed, based on her conviction and sentence.
Having highli hted 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:
As part of a negotiated settlement agreement leading to this
Consent Agreement,
the Investigative Division will recommend
the following in relation to the above allegations:
The Investigative Division does hereby nolle pros
the allee violation of Section 1103(c) of the
Public Official and Employee Ethics Act, 65
Pa.C.& § 1103(c).
Based solely on the verdict of a Dauphin County
Juryon October 31, 2Ol 8—and without waiver of
her rights under Article
1, Section 9 of the
Pennsylvania Constitution, the Fifth Amendment
of the United States Constitution, and the
positions asserted at trial and to be further
asserted on appeal —Ms. Lowery Brown will not
contest in this proceeding thata violation of
Section 11105(b)(6) of the Public Official and
Employee Ethics Act, 65 Pa.C.S. § 11105b)(6�,
occurred when Ms. Brown failed to ime y
disclose on Statements of Financial Interests
Brown, 14-017
P-ag-6-8
filed for the 2011 calendar year, her receipt of
$4,000.00 in cash gifts from Tyron Ali, at a time
when Tyron Ali was a registered lobbyist.
c. Based solelyon the verdict of a Dauphin County
Jury on October 31, 2018—and without waiver of
her rights under Article 1, Section 9 of the
Pennsylvania Constitution, the Fifth Amendment
of the United States Constitution, and the
positions asserted at trial and to be further
asserted on appeal —Ms. Lowery Brown will not
contest in this proceedingthat a violation of
Section 1105(b)(7) of the Public Official and
Employee Ethics Act, 65; Pa.C.S. § I 105(%7),
occurred when Ms. Brown failed to disclose er
receipt of transportation, lodging and hospitality
in excess of $650.00 on her Statement of
Financial Interests filed for the 2011 calendar
year.
cl. InvestigativeThe Division does hereby nolle pros
the alleged violation of Section 1103(a) of the
Public Official and Employee Ethics Act, 65
Pa.C.S. § 1103(a).
e. The Investigative Division does hereby nofie pros
the alleged violation of Section 11 05(b)(5) of the
Public Official and Employee Ethics Act, 65
Pa.C.S. § 1105(b)(5).
Brown has agreed to make payment in the amount of
$4,250.00 in settlement of this matter, and has, in fact made
payment in full of restitution amounts ordered by the Dauphin
County Court of Common Pleas of such amount as follows:
a. Brown will make payment of $250.00
(representing one (1) year of deficient Statement
of Financial Interests filings) 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. Brown has aid restitution in the amount of
$4,000.00 0 the Commonwealth of
Pennsylvania as part of the sentence in the
Dauphin County criminal roceeding docketed
as: eP-22-CR-0000525-05.
To the extent she has not already done so, Brown agrees to
file a complete and accurate amended Statement of Financial
Interests with the Pennsylvania State Ethics Commission, for
the 2011 calendar year within thirty (30) days of the issuance
of the final adjudication in this matter.
Brown agrees to not accept any reimbursement, compensation
or other payment from the Commonwealth of Pennsylvania
B,rown, 14-017
Pe,
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. 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 Agreemen , at 2-3.
In considering the Consent Agreement, we accept the recommendations of the
parties, and we hold that:
(1) Based solely on the verdict of a Dauphin Countjury on October 31, 2018—
and without waiver of her rights under Article 1, Section 9 of the Pennsylvania
Constitution, the Fifth Amendment of the United States Constitution, and the
positions asserted at trial and to be further asserted on appeal —Brown does
not contest in this proceedingthat a violation of Section 1105(b)(6) of the
Ethics Act, 65 Pa.C.S. § 11 01(b)(6), occurred when Brown failed to timel
disclose on her SFI filed for the 2011 calendar year her receipt of $4,0002
in cash gifts from Ali, at a time when Ali was a registered lobbyist; and
(2) Based solely on the verdict of a Dauphin County Jury on October 31, 2018—
and without waiver of her rights under Article 1, Section 9 of the Pennsylvania
Constitution, the Fifth Amendment of the United States Constitution, and the
positions asserted at trial and to be further asserted on appeal —Brown does
not contest in this proceeding that a violation of Section 1105(b)(7) of the
Ethics Act, 65 Pa.C.S. § 11 05(b)(7), occurred when Brown failed to disclose
her receipt of transportation, lodging and hospitality in excess of $650.00 on
her SFI filed for the 2011 calendar
year.
As part of the Consent Agreement, Brown has agreed to make payment in the
amount of $4,250.00 payable as follows: (1) $250,00 representing one year of deficient SFI
filings, payable to the Commonwealth of Pennsylvania and forwarded to this Commission
wl hirty (30) days of the issuance of the final adjudication in this matter; and (2)
$4,000.00 in restitution payable to the Commonwealth of PennsIvania—which restitution
amount has been paid in full by Brown —as ordered by the Dauphin County Court of
Common Pleas as part of the sentence in the Dauphin County criminal proceeding
docketed as: CP-22-CR-0000525-2015.
Brown has agreed to not accept any reimbursement, compensation or other
payment from the Commonwealth of Pennsylvania representing a full or partial
reimbursement of the amount paid in settlement of this matter.
To the extent she has not already done so, Brown has agreed to file a com lete and
accurate amended SFI for calendar year 2011 with this Commission within thirty �310) 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, Brown is directed to make
payment in the amount of $4,250.00 payable as follows: (1$250.00 representing one year
of deficient SFI filings, payable to the Commonwealth of Pennsylvania and forwarded to
Birown, 14-017
Page 10
this Commission by no later than the thirtieth (301h) clay after the mailing date of this
adjudication and Order; and (2) $4,000.00 in restitution payable to the Commonwealth of
Pennsylvania —which restitution amount has been paid in full by Brown —as ordered by the
Dauphin County Court of Common Pleas as part of the sentence in the Dauphin County
criminal proceeding docketed as: CP-22-CR-0000525-2015,
Per the Consent Agreement of the parties, Brown is further directed to not accept
any reimbursement, compensation or other payment from the Commonwealth of
Pennsylvania representing a full or partial reimbursement of the amount paid in settlement
of this matter.
To the extent she has not already done so, Brown is directed to file a complete and
accurate amended SFI for calendar year 2011 with this Commission by no later than the
thirtieth (30th) day after the mailing date of this adjudication and Order.
Compliance with the foroing 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 Member of the Pennsylvania General Assembly, House of Representatives,
Respondent Vanessa Lowery Brown ("Brown") was a public official sub ect to the
rovisions of the Public Official and Employee Ethics Act ("Ethics Pa.C.S.
1101 et seq.
2. Based solely on the verdict of a Dauphin County juryon October 31, 2018—and
without waiver of her rights under Article 1, Section 9 of the Pennsylvania
Constitution, the Fifth Amendment of the United States Constitution, and the
positions asserted at trial and to be further asserted on ap eal—Brown does not
contest in this proceeding that a violation of Section 1 105(16�(6) of the Ethics Act, 65
Pa.C.S. § 1105(b)(6), occurred when Brown failed to timely disclose on her
Statement of Financial Interests filed for the 2011 calenclawar her receipt of
$4,000.00 in cash gifts from Tyron Ali, at a time when Tyron I i was a registered
lobbyist.
3. Based solely on the verdict of a Dauphin County jury on October 31, 2018—and
without waiver of her rights under Article 1, Section 9 of the Pennsylvania
Constitution, the Fifth Amendment of the United States Constitution, and the
positions asserted at trial and to be further asserted on ap eal_Brown does not
7
contest in this proceeding that a violation of Section 11 05(b)F_1) of the Ethics Apt, 65
Pa.C.S.
5 11 05(b)(7), occurred when Brown failed to disclose her receipt of
transportation, lodging and hospitality in excess of $650.00 on her Statement of
Financial Interests filed for the 011 calendar year.
In Re: Vanessa Lowery Brown,
Respondent
File Docket: 14-,017
Date Decided: 6/28/19
Date Mailed: 7/1/19
ORDER NO. 1756
Based solely on the verdict of a Dauphin County juryon October 31, 2018and
without waiver of her rights under Article 1, Section —9 of the Pennsylvania
Constitution, the Fifth Amendment of the United States Constitution, and the
po
sitions asserted at trial and to be further asserted on appeal —Vanessa Lowery
Brown ("Brown") does not contest in this proceeding that a violation of Section
11 05%g6) of the Public Official and Employee Ethics Act (""Ethics Act"), 65 Pa.C.S.
05bl p
)(6, occurred when Brown, as a Member of the Pennsylvania General
ssem y, House of Representatives, failed to timely disclose on her Statement of
Financial Interests filed for the 2011 calendar year her receipt of $4,000.00 in cash
gifts from Tyron Ali, at a time when Tyron Ali was a registered lobbyist.
Based solely on the verdict of a Dauphin County jury on October 31, 201 8—and
without waiver of her rights under Article 1, Section 9 of the Pennsylvania
Constitution, the Fifth Amendment of the United States Constitution, and the
positions asserted at trial and to be further asserted on appeal —Brown does not
contest in this proceeding that a violation of Section 11 05(b)(7) of the Ethics Act, 65
Pa.C.S. § 1105(b)(7), occurred when Brown failed to disclose her receipt of
transportation, lodging and hospitality in excess of $650.00 on her Statement of
Financial Interests filed for the 2011 calendar year.
Per the Consent Agreement of the parties, Brown is directed to make payment in
the amount of $4,250.00 payable as follows: (1) $250.00 representing one year of
deficient Statement of Financial Interests filings, 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; and (2)
$4,000.00 in restitution payable to the Commonwealth of Pennsylvania —which
restitution amount has been aid in full b� Brown as ordered by the Dauphin
P, ep
County Court of Common as as part o the sentence in the Dauphin County
criminal proceeding docketed as: CP-22-CR-0000525-2015.
Per the Consent Agreement of the parties, Brown is further directed to not accept
y
an reimbursement, compensation or other payment from the Commonwealth of
Pennsylvania representing a full or partial reimbursement of the amount paid in
settlement of this matter.
To the extent she has not already done so, Brown is directed to file a complete and
accurate amended Statement of Financial Interests for calendar year 2011 with the
Pennsylvania State Ethics Commission by no later than the thirtieth (30th) day after
the mailing date of this Order.
Compliance with paragraphs 3, 4, and 5 of this Order will result in the closing of this
case with no further action by this Commission.
Non-compliance will result in the institution of an order enforcement action.
BY THE COMMISSION,
VA, l
I IVA, W, .
M,
I mm 51 ff
1741511WAVIne