Loading...
HomeMy WebLinkAbout825 YezziIn Re: Joseph D. Yezzi STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 File Docket: 90- 018 -C2 . Date Decided: February 20, 19$2 . Date Mailed: February 27, )992 Before: Dennis C. Harrington, Chair James M. Howley, Vice Chair Daneen E. Reese Roy W. Wilt Austin M. Lee James P. Gallagher Allan M. Kluger The State Ethics Commission received complaints regarding possible violations of the State Ethics Law, Act No. 170 of 1978 and Act No. 9 of 1989. Written notice, of the specific allegation(s) was served at the commencement of the investigation. A Findings Report was issued and served, upon completion of the investigation, which constituted the Complaint by the Investigation Division. An Answer was filed and a hearing was held. The record is complete. This adjudication of the Commission is hereby issued which sets forth the individual Allegations, Findings of Fact, Discussion, Conclusions of Law and Order. This adjudication is final and will be made available as a public document fifteen days after issuance. However, reconsideration may be requested which will defer public release of this adjudication pending action on the request by the Commission. A request for reconsideration, however, does not affect the finality of this adjudication. A reconsideration request must be received at this Commission within fifteen days of issuance and must include a detailed explanation of the reasons as to why reconsideration should be granted in conformity with 51 Pa. Code §2.38. The files in this case will remain confidential in accordance with Section 8(a) of Act 170 of 1978 and Act 9 of 1989, 65 P.S. 408(h), during the fifteen day period and no one unless the right to challenge this Order is waived, may violate confidentiality by releasing, discussing or circulating this Order. However, confidentiality does not preclude discussing this case with an attorney at law. Any person who violates confidentiality of the Ethics Act is Joseph D. Yezzi Page 2 guilty of a misdemeanor subject to a fine of not more than $1,000 or imprisonment for not more than one year, 65 P.S. 409(e). I. ALLEGATION$: That, Joseph D. Yezzi, Chairman of the Center Township Water Authority, Beaver County, violated the following provisions of the State Ethics Act (Act 170 of 1978), when he used his position to sell life insurance policies to authority employees and when he failed to file Statements of Financial Interests for the 1984, 1985, 1986 and 1987 calendar years: Section 3. Restricted Activities. (a) No public official or public employee shall use his public office or any confidential information received through his holding public office to obtain financial gain other than compensation provided by law for himself, a member of his immediate family, or a business with which he is associated. Section 3. Restricted activities. (b) No person shall offer or give to a public official or public employee or candidate for public office or a member of his immediate family or a business with which he is associated, and no public official or public employee or candidate for public office shall solicit or accept, anything of value, including a gift, loan, political contribution, reward, or promise of future employment based on any understanding that the vote, official action, or judgment of the public official or public employee or candidate for public office would be influenced thereby. Section 4. Statement of financial interests required to be filed. (a) Each public employee employed by the Commonwealth shall file a statement of financial interests for the preceding calendar year with the department, agency or bureau in which he is employed no later than May 1 of each year that he holds such a position and of the year after he leaves such a position. Any other public employee shall file a statement of financial interests with the governing authority of the political subdivision by which he is employed no later than May 1 of each year that he holds such a position Joseph D. Yezzi Page 3 and of the year after he leaves such a position. And that he violated the following provisions of Act 9 of 1989, when he used his position to participate in the sale of cancer accident and disability insurance policies to the authority: II. FINDINGS: A. PLEADINGS: Section 3. Restricted Activities. (a) No public official or public employee shall engage in conduct that constitutes a conflict of interest. 1. Joseph Yezzi has served as a member of the Center Township Water Authority (CTWA) since October 9, 1984. a. Yezzi has served as the Chairman of the Center Township Water Authority, continuously, since 1988. b. Yezzi's term expires on December 31, 1992. c. Yezzi was appointed to the CTWA by the Center Township Commissioners. 2. The CTWA employs a maintenance department to perform necessary repairs and maintenance to the township water system. a. The CTWA employs both full -time and part -time employees. b. Full -time employees are eligible to become members of the International Brotherhood of Electrical Workers Union. (1) Employees are eligible after serving a (90) day probationary period. c. Full -time employee wages and benefits are set by union contract. d. Part -time employee wages, raises and benefits are approved by board action. 3. The Center Township Water Authority has no written or formal guidelines for hiring of employees. a. All hiring and firings are to be by Board action. Joseph D. Yezzi Page 4 4. Minutes of the CTWA disclose the following regarding the hiring of part -time employees. a. July 28, 1987: Page 3, #4, Item 6, Hiring of a Meter Reader: "The Board instructed Mr. Sisk to hire Mr. David Dechellis as the new meter reader. He has filed an application with the Authority. He will begin reading meters the 1st of August." Present: Cercone, Panetta, Brizzi, and Yezzi who arrived at 7:35 p.m. b. October 20, 1987: Page 8, #13, Committee Reports Section 5, Personnel: "Mr. Panetta and Mr. Cercone - The Chairman reviewed the current applications for employment on file. There may be a need to hire another part -time employee to complete the fire hydrant flushing program." Present: Yezzi, Brizzi, Cercone and Panetta c. May 17, 1988: Page 8, Section 13, Committee Reports #5, Personnel: "There are now two additional part -time summer employees working, and we hope to be receiving manpower personnel soon." Present: Cercone, Brizzi, Panetta, and Onderick who arrived after the bid opening. d. June 21, 1988: Page 6, #7, Part -Time and Manpower Employees: "On the solicitor's recommendation, the Board took the following action regarding the hiring of part -time and Manpower employees for the summer ": Motion, Mr. Brizzi, seconded by Mr. Panetta, to confirm approval of the hiring of all the part- time and Manpower summer employees in the maintenance department. Messrs. Cercone, Brizzi, Panetta and Onderick voting in favor thereof. Mr. Yezzi abstained. Motion carried. At this time, the Board took the following action: Motion, Mr. Brizzi, seconded by Mr. Cercone, to adjourn to Executive Session for the purpose of discussing personnel Joseph D. Yezzi Page 5 and legal matters. All voting in favor thereof. Motion carried. Adjourned to Executive Session at 8:15 p.m.; meeting reconvened at 8:50 p.m." Present: Cercone, Brizzi, Panetta, Onderick, and Yezzi who arrived at 7:50. e. Mav 18, 1989: Page 3, Item 9, Hiring a Summer Employee: "At this time, the Board took the following action regarding the hiring of part -time summer employees ": Motion, Mr. Brizzi, seconded by Mr. Cercone, to confirm the hiring of four part -time employees at the rate of $4.00 per hour and authorize the manager to hire an additional four employees at the same rate for part -time summer employment. All voting in favor thereof. Motion carried." 5. Minutes of the Center Township Water Authority Board indicate the following official action was taken relative to employee raises: a. January 20, 1987: Page 4, #9, Unfinished Business, Item 4: "1987 -88 employee union agreements - there are several grammatical errors which must be corrected on each contract, and the Board would like to have a clause added regarding part -time employees in the ninety -day probationary period. Once these matters are resolved, the contracts can be signed. Attorney DiGiorno will contact Mr. Leek regarding these matters. At this time, the Board agreed to approve the payment of the 1987 wages immediately as per the following action: Motion, Mr. Sisk, seconded by Mr. Panetta, to accept the 1987 -88 employee agreements for the Maintenance Department and office employees contingent upon the correction of several grammatical errors in the addition of an addendum regarding part -time employees in the ninety -day probationary period. Wage increases for 1987 will become effective immediately, retroactive to January 1, 1987. Maintenance employees will receive a $.15 an hour increase; the Chief Clerk will receive a $.25 an hour increase; and the other two clerks will receive an additional $.50 per hour. Also the maintenance employee's pension deductions and contributions will be increased to 5 %. All voting in favor thereof. Motion carried." Present: Yezzi, Cercone, Panetta, and Sisk who arrived after reorganization. Joseph D. Yezzi Page 6 b. October 12, 1988: Page 3, #8, Request for Salary Increase from Mr. Randall Stewart, Meter Reader: "Mr. Sisk presented a letter from Mr. Stewart requesting a wage increase for meter readers. After a brief discussion, the Board took the following action: Motion, Mr. Brizzi, seconded by Mr. Onderick, to authorize the salary increase for the meter readers in the amount of $25.00 per residential route read and $50.00 for the commercial route. Said increase to become effective immediately. All voting in favor thereof. Motion carried." Present: Brizzi, Panetta, Onderick, and Yezzi who arrived at 7:20 p.m. Absent: Cercone c. September 19, 1989: Page 7: ^8:00 p.m., the meeting was adjourned to Executive Session by the Chairman to discuss personnel and related matters. The meeting was then reconvened at 8:20 p.m., and the following action was taken ": Motion, Mr. Brizzi, seconded by Mr. Panetta, to authorize a wage increase for both part -time employees, Mr. Sopko and Mr. Eshbaugh, in the amount of $1.00 per hour to $5.50 per hour, effective with the next payroll calculator. Said increase is a merit raise based on their above satisfactory work record. All voting in favor thereof. Motion carried. Present: Yezzi, Brizzi, Cercone, Panetta and Onderick. 6. Minutes of the Center Township Water Authority indicate the following in regard to authority actions regarding insurance for authority employees. a. July 19, 1988: On page four, Item 5, Summer Work Schedule to Discuss Insurance Coverage for 1988, 1989. It was agreed that a work session would be scheduled for Monday, July 25, 1988, at 7:00 PM in the office to discuss the 1988, '89 insurance proposals. Mr. Sisk will contact Mr. Gray of the Blackwood Agency and request that he attend the meeting. The clerk was directed to advertise the work session. Joseph D. Yezzi Page 7 Board Members Present: Yezzi, Brizzi, Cercone, Panetta and Onderick b. Octolper 12, 1988 - Work Sessiop Aaenda On page three, Item V, Mr. Anthony Fadool. Mr. Sisk advised the Board that Mr. Sisk has reviewed all of our insurance coverage. Mr. Fadool's life insurance policy has been reviewed, and there is no type of sick pay coverage available to him. The Board directed the clerk to transmit a letter to Mr. Fadool advising him of our insurance investigation and suggest he can contact Mr. Onderick to inquire as to whether there may be any state assistance available to him. Board Members Present: Brizzi, Panetta, Onderick and Yezzi, who arrived at 7:20 PM. Absent: Mr. Cercone c. October 18, 1988: On page three, "Section VI, Review of Correspondence. Item No. 2, notice from Penn Prime regarding the feasibility of group self - insurance for the Authority. It was agreed that Attorney DiGiorno will look in to the Penn Prime Program before our current insurance expires ". Board members present: Yezzi, Brizzi, Cercone, Panetta and Onderick d. November 15, 1988: On page three, "Item VI, Review of Section 89 of the IRS. Attorney DiGiorno had discussed Section 89 with an accountant, and it is his opinion that we are in compliance with its requirements. Section 89 concerned discrimination in employee health benefits ". Board members present: Yezzi, Brizzi, Cercone, Panetta and Onderick e. January 17, 1989: Page two, "Item V, Depository Bank and Authorization of the Use of Facsimile Signatures of the Chairman and Treasurer on Checks. Motion, Mr. Cercone; seconded Mr. Panetta. To appoint the Century Joseph D. Yezzi Page 8 National Bank & Trust Company, Beaver Valley Mall Office, as the depository bank for the fiscal year 1989 and to authorize the use of facsimile signatures of the chairman and treasurer on authority checks. All voting in favor thereof. Motion carried ". On page three, Item IX. Unfinished Business. Subparagraph No. 3. 1989 Union Contract Negotiations. The Board took the following action regarding union contracts: subcontract, subparagraph 3, an increase to 30% and a benefit paid to those office employees who elect not to be covered under the Authority's medical insurance. Subparagraph 4, a weekly indemnity insurance coverage to be paid by the Authority. Board members present: Yezzi, Brizzi, Cercone, Panetta and Onderick f. June 20, 1989: Page four, "Item X, Solicitors Report, Subparagraph 5. Review of Section 89 of the IRS Code. Attorney DiGiorno advised the Board that he has reviewed the Section 89 requirements and attended several seminars, and it is his opinion that our benefit plans are not discriminatory. He and the chief clerk will prepare a program to be presented to all covered employees which will provide each with a listing of all benefits along with a complete description of said benefits ". Board members present: Yezzi, Brizzi, Cercone, Panetta and Onderick g January 16, 1990: Page nine, "Section XIII, Paragraph 4. Review of Section 89 of the IRS Code. Attorney DiGiorno has prepared a draft of the handout he is going to present to all employees which describes all insurance and health benefits available to all full -time employees. After the Board reviews the draft, a final copy will be prepared and each employee will receive a copy in compliance with Section 89 of the IRS Code ". Board members present: Brizzi, Gulla, Panetta, Onderick and Yezzi h. April 17, 1990: On page two, "Section VI, Review of Correspondence. Item: In reviewing the employee benefits information given to the employees in compliance with Section 89 of the IRS Code, Mr. Onderick is questioning the employees accidental death and Joseph D. Yezzi Page 9 i. May 15, 1990: dismemberment policy. Attorney DiGiorno the policies in question and report back Board members present: Brizzi, Panetta, Yezzi June 19, 1990: k. July 17, 1990: directed to review to the Board ". Onderick, Gulla and Page five, "Section VIII, Paragraph 6. Review of employees Accidental Death and Dismemberment insurance plans. Attorney DiGiorno suggested the manager and /or chief clerk look into the coverage of the Accidental Death and Dismemberment insurance plans and report their findings to the Board. This matter does not really require legal interpretation ". Board Members Present: Brizzi, Panetta, Onderick, Gulla and Yezzi Page eight, "Section XII, Paragraph 4. At this time, there was a lengthy discussion regarding the employees Accidental Death and Dismemberment insurance coverage. Mr. Sisk is going to research this matter further and discuss it with Mr. Leek of the I.B.E.W. before any changes are made ". Board Members Present: Brizzi, Panetta, Onderick, Gulla and Yezzi Page three, "Section V, Paragraph 5. Received a survey from Municipal Risk Property & Casualty Company Incorporated concerning health insurance. They are requesting information to determine if there is a need for a pooled arrangement for health insurance coverage similar to the Workers Compensation Program they now offer. The clerk was directed to complete and submit the survey." 7. The Center Township Water Authority provided Cancer Insurance and Accident Indemnity Insurance to full -time employees. Coverage was provided through the American General Life and Accident Insurance Company. 8. The CTWA Board member, Patrick Brizzi, brought American General Insurance Company to the Board. a. The purpose was to service a cancer insurance policy for employees. Joseph D. Yezzi Page 10 b. This was prompted due to one employee having cancer and incurring large medical bills. 9. In addition to the Life and Cancer Insurance for employees through American General, the CTWA also provided insurance benefits for employees through the Travelers Insurance Company. a. Coverages included Life Insurance, Accidental Death and Dismemberment, Weekly Income Insurance. b. This coverage was in effect at the time the coverage with American General was obtained. (1) The coverage remained in effect through 1990. 10. The Center Township Water Authority received invoices from American General Insurance Company in regard to the Accidental Death and Dismemberment and Cancer policies purchased for authority employees. a. August 3, 1989 invoice in an amount of $158.67 for monthly payment of insurance policies. b. October 24, 1989 invoice for balance due of annual premiums: Accident Cancer Life Name Plans Plans Insurance Elsie Spearing $ 58.30 $ 121.77 - James Lasky 58.30 58.89 - Verna Dugan 58.30 58.87 - Karen Galdony 58.30 121.77 Kevin Eshbaugh 58.30 43.47 - Joseph Sopko 58.30 183.76 - Paul Barker 58.30 188.35 - Anthony Fadool 58.30 - $685.74 Lawrence Zon 58.30 65.50 - Kenneth Sisk 58.30 156.50 - Steve Gulla 58.30 52.20 - $641.30 $1,051.08 $685.74 TOTAL $2,378.12 c. September 28, 1989 invoice in an amount of $88.30 for initial payment of Life Insurance for Anthony Fadool. 11. Records of the Center Township Water Authority include the following checks issued from the Revenue Fund Account to the American General Life and Accident Insurance Company as payments for the Accident and Cancer policies: Joseph D. Yezzi Page 11 a. Check No. 11375 Account No. 170 Date - August 4, 1989 Amount - $158.67 b. Check No. 11484 Account No. 176 Date - September 28, 1989 Amount - $88.30 c. Check No. 11619 Account No. 176 Date - October 24, 1989 Amount - $2,378.12 d. The checks bear the facsimile signature of Joseph D. Yezzi and Joseph Panetta, as Chairman and Secretary, and Verna Dugan's original signature as Chief Clerk. e. Check Numbers 11375 and 11484 are co- signed by Joseph Yezzi for deposit by Century National Bank & Trust Company, Freedom, Pennsylvania into the American General Life and Accident Insurance (PA No. 12/937), Account No. 31008064/P.E.G. 12. Minutes of the CTWA meeting of August 15, 1989 confirm that payments to American General Insurance Company were approved as follows: To approve the list of billings to be ratified August 15, 1989 and to confirm approval of the payment of the monthly statement from American General Life Insurance Company for employee Accidental Death and Dismemberment and Cancer Insurance, Messrs. Brizzi, Cercone, Panetta and Onderick voting in favor thereof; Mr. Yezzi abstaining. Motion carried. It was noted that the premium from American General Life Insurance Company is going to be changed to an annual billing rather than monthly. 13. Records of the Center Township Water Authority reflect that a reimbursement to the Authority was from the American General Life & Accident Insurance Company, Monaca, Pennsylvania for an overpaid premium: a. Check No. 1056 Date - March 23, 1990 Amount - $124.39 Description - Refund on Premium (0012) Received by the Authority on June 21, 1990 Joseph D. Yezzi Page 12 14. Records of the American General Life Insurance Company confirm that Center Township Water Authority employees, Joseph Sopko, James Lasky and Kevin Eshbaugh all had personal life insurance dealings with Joseph Yezzi. a. Joseph Sopko: Policy Number - 189226111 Date Written - March 7, 1989 Type of Policy - Life Premium - $566.85 /Annual Agent - Joseph D. Yezzi Agent ID - 133512 b. Kevin Eshbaugh: Policy Number - 188281733 Date Written - October 17, 1988 Type of Policy - Life Premium - $547.47 Agent - Joseph D. Yezzi Agent ID - 133512 c. James Lasky: Policy Number - 189018383 Date Written - June 16, 1989 Type of Policy - Life Premium - $501.50 Agent - Joseph D. Yezzi Agent ID - 133512 15. Joseph Sopko was hired by the CTWA on December 19, 1985 as a part -time employee. a. He had previous work experience with the CTWA in the mid - 1960's. b. As a part -time employee, Sopko has no benefits or union protection. 16. James Lasky was hired by the CTWA on May 22, 1989 as a maintenance employee. a. He had no previous work experience with the CTWA. b. Minutes of the May 18, 1989 CTWA meeting confirm the following action regarding Lasky's hiring: (1) "Mr. Yezzi indicated that the Board has considered Joseph D. Yezzi Page 13 hiring a full -time employee and has reached the following decision: Motion, Mr. Brizzi, seconded by Mr. Panetta, to authorize the hiring of a full -time maintenance employee, namely Mr. James L. Lasky, at a rate of $7.50 per hour with full employee benefits effective Immediately. Messrs. Yezzi, Brizzi, Panetta and Onderick voting in favor thereof. Mr. Cercone abstaining. Motion carried. Mr. Lasky will begin working Monday, May 22, 1989. The Chief Clerk was directed to have Mr. Lasky placed on all insurance, pension and other benefits available to full -time employees of the Authority. His coverage is to begin immediately. c. On June 16, 1989, Joseph Yezzi wrote a life insurance policy for Lasky with an effective date of June 28, 1989. d. Lasky allowed the policy to lapse on December 11, 1989 for non - payment of premiums. 17. Kevin Eshbaugh was hired by the CTWA on May 11, 1988 as a part - time employee. a. He is a part -time employee with no benefits or union protection. b. His hiring was not approved by the CTWA Board. c. Yezzi wrote the life insurance policy, #188281733, on October 17, 1988. d. Center Township payroll records confirm that Eshbaugh received a $.50 /hour raise on October 24, 1988 and retroactive to May 11, 1988, the effective date of his employment. 18. Minutes of the Center Township Water Authority Board meeting indicate the following relative to a full -time position for Kevin Eshbaugh. a. July 26, 1989: Page 2, #6, Part -Time Employee, Mr. Kevin Eshbaugh: "Mr. Eshbaugh attended the meeting to request the Board consider him for full -time employment. After a brief discussion, the Board advised Mr. Eshbaugh that at this time, there are no full -time positions available." Present: Yezzi, Brizzi, Cercone and Panetta Joseph D. Yezzi Page 14 Absent: Onderick 19. Lawrence Zon has been a full -time employee of the Center Township Water Authority since May 1982. a. Zon is a member of the union and has full benefits. b. Authority payroll records confirm that Zon received a raise from $6.90 /hour to $9.05 /hour, effective January 1, 1987. 20. Donald Haldeman was employed by the CTWA on a part -time basis from June 19, 1986 until April 13, 1989. a. His hiring was not approved by the CTWA Board. b. Haldeman had no benefits or union coverage. c. During the summer of 1988, Yezzi, and another American General Insurance agent, went to Haldeman's home attempting to sell a Life Insurance Policy. (1) The Haldeman's did not purchase a policy at that time. 21. Joseph Yezzi was employed as an Agent by the American General Life and Accident Insurance Company. a. Yezzi worked in the Beaver Valley District which included Center Township. 22. Records of the Commonwealth of Pennsylvania's Insurance Department confirm that Joseph Yezzi has the following active insurance agent licenses. a. Colonial Life & Accident Insurance Company; issued 3/2/89. (1) Yezzi has not made a sale through this company. 23. Joseph Yezzi filed Statements of Financial Interests with the Center Township Water Authority for the 1984 through 1989 calendar years. a. Calendar Year - 1984 Filed - 4/18/84 on SEC Form 1/88 Occupation - Insurance Salesman Position - Water Authority Member Direct /Indirect Income - American General Life Insurance Company, PIA Marie Yezzi - Employer, US Air All Other Financial Interests - None b. Calendar Year - 1985 Joseph D. Yezzi Page 15 Filed - 4/20/85 on SEC Form 1/88 Occupation - Insurance Salesman Position - Water Authority Member Direct /Indirect Income - Office of Employment Security, Ambridge, PA - Unemployment, PIA Marie Yezzi, Employer, US Air. All Other Financial Interests - None c. Calendar Year - 1986 Filed - 4/25/86 on SEC Form 1/88 Occupation - Insurance Salesman Position - Water Authority Member Direct /Indirect Income - American General Life Insurance Company, PIA Marie Yezzi - Employer, US Air All Other Financial Interests - None d. Calendar Year - 1987 Filed - 3/25/87 on SEC Form 1/88 Occupation - Insurance Salesman Position - Water Authority Member Direct /Indirect Income - American General Life Insurance Company, PIA Marie Yezzi - Employer, US Air All Other Financial Interest - None e. Calendar Year - 1988 Filed - 3/28/89 on SEC Form 1/89 Position - Water Authority Member Occupation - Insurance Salesman Direct /Indirect Income - American General Life Insurance Company, Monaca, PA All Other Financial Interests - None f. Calendar Year - 1989 Filed - 4/18/90 on SEC Form 1/89 Position - Water Authority Member Occupation - Insurance Salesman Direct /Indirect Income - American General Life Insurance Company, Monaca, PA All Other Financial Interests - None 24. The Statement of Financial Interest filings for years 1984 through 1987 were completed on forms SEC -1, Rev. 1/88. a. State Ethics Commission filing form SEC -1, Rev. 1/88, was not printed until December 1987. b. Form SEC -1, Rev. 1/88, was forwarded to municipal governmental entities in January 1988. c. The form used for the filing in Finding #30, a through d, was not available on the dates that it was allegedly filed Joseph D. Yezzi Page 16 in that the said form had not yet been printed. 25. Minutes of the CTWA meeting, held on September 16, 1986, confirm that it was reported that one Statement of Financial Interest for the 1985 calendar year was outstanding. a. That form was for Joseph Yezzi. B. TESTIMONY: 26. David H. Miller is a manager of the field compensation department for American General Life and Accident Insurance Company. a. He maintains the agent's compensation system as to agents' records, calculation of pay and payroll authorization. b. Selling agents report to sales managers who in turn report to district managers. c. Selling agents receive different types of commissions. (1) The sales commission is paid for the first year's annualized premium. (2) The conservation incentive commission is based upon the production and conservation of existing business. (a) It serves as an incentive for the agent to retain existing business and a reward for new business. (3) The collection commission is based upon the collection of business assigned to an agent. d. A commission pool is a fund to which commissions are credited whereby the agent is paid from the pool over a period of time. (1) An agent's starting pay and the agency size affect the initial amounts set up for the agent as the pool from which amounts will be withdrawn for the agent. (2) New business for an agent gives credit to the pool. (3) Business losses are deducted from the pool of the agent. e. An agent's policy register is a weekly record of the production activity of an agent for that week. (1) Each policy register statement has a service number Joseph D. Yezzi Page 17 f. An agent's weekly statement is a summary of the agent's record. g. j which is unique to each agent. (a) The service number for Yezzi is 133512. (2) The policy register statement provides an agent with his progress record for the week and the calculation of his sales commission. (1) The record provides the credit to an agent's accumulated commission fund and the calculation of gross pay for each week as well as a production record based on the annualized premiums that are credited to the agent. (2) There is a section for collective commissions. (3) There are other sections reflecting the incentive progress record of an agent and some bonus benefits which an agent may receive. (4) The compensation section establishes the first year commission credit and renewal commission credits as to an agent's accumulated commission fund. (5) The weekly statement reflects the weekly as well as the year -to -date compensation. (6) Club standings is an incentive plan for possible trips for agents. A sales manager receives an override which is a percentage computed based upon an agent's commission. h. An annualized premium factors into commission determination. (1) The commission rate is applied to the annualized premium to determine the amount of commission credit. i. The Company generates three sets of policy registers and weekly statements. (1) One copy is for the agent, one copy is for the sales manager and the third copy is for the district manager. The FAM (group of policies) number 5636 reflect accident indemnity insurance policies for Elsie Spearing, James Lasky, Joseph Sopko, Paul Barker, Anthony Fadool, Lawrence Joseph D. Yezzi Page 18 Zon and Kenneth Sisk, with Yezzi as writing agent who received the commission. (1) These new policies were issued on August 2, 1989. k. For Kevin Eshbaugh, a different FAM number reflects an adjustable premium whole life policy with a supplementary annuity benefit rider. (1) This new policy was issued in November, 1988. (2) Yezzi received the commission on this policy. 1. The FAM number 5636 also reflects a cancer indemnity policy for Lawrence Zon, Elsie Spearing, Paul Barker, Kevin Eshbaugh, Joseph Sopko, Karen Galdony, Verna Dugan, Steve Gulla, and Kenneth Sisk which is new business. m. Number G B 20L reflects a life policy for Anthony Fadool which is new business with Yezzi as agent credited with receiving the commission. n. An excess interest whole life policy on James Lasky lapsed in the first year of that policy. o. The cancer insurance application of American General indicates in the production credit area the name of the agent who receives the credit, his service number and the district code and agency number. (1) Cancer insurance policies were written for the following individuals as to which Yezzi received the commissions: Paul Barker, 118298010; Kevin Eshbaugh, 118298011; Joseph Sopko, 118298012; Karen Galdony, 118298014; Verna M. Dugan, 118298015; Steven W. Gulla, 118298016; Kenneth Sisk, 118298017; and Lawrence Zon, 115506984. p. Accident indemnity insurance policies of American General were issued to the following individuals with the agent's name listed as H. DeLouis but with Yezzi's service number of 133512: Steven Gulla, 13071468; James Lasky, 130710471; Verna Dugan, 130710472; Karen Galdony, 130710473; Elsie Spearing, 130710470; Kevin Eshbaugh, 130710474; Joseph Sopko, 130710475; Paul Barker, 230710476; Anthony Fadool, 130710477; Lawrence Zon, 130710479; and Kenneth Sisk, 130710480. (1) The service number reflects that Yezzi was credited with the commission. Joseph D. Yezzi Page 19 q. Three life insurance policies of American General Insurance Company were issued to Kevin Eshbaugh, 188281733; James Lasky, 189018383 and Joseph Sopko, 189226111 with the service number reflecting Yezzi as the agent receiving the commission. r. A graded benefit whole life insurance policy of American General for Anthony Fadool, 118317803 was issued with Yezzi, service number 133512 receiving the commission. s. The cancer and accident indemnity policies, referenced in sub - findings o and p were issued in 1989 and lapsed in September or October 1990. t. Yezzi terminated employment with American General during the week of August 27, 1990. u. An agent may receive a commission rate from 15% to 45 %. v. An insurance policy is a contract between the company and the insured. w. An agent's weekly compensation varies depending upon when commissions are incoming. x. American General's production quota for their agents has varied over the years but the variance was not great. y. The overrides for a sales manager and district manager are fixed at 25% and 12% respectively. z. A district manager gets a base salary plus incentives based upon the production of the agents in his district. aa. An agent who consistently fails to meet production quotas would be terminated after a period of time. 27. Kevin Eshbaugh is employed as a part -time laborer for the CTWA. a. Eshbaugh began working for the CTWA in May of 1988 at a starting salary of $4.00 per hour. b. Yezzi was Chairman of the Board of CTWA when Eshbaugh got the job. c. Yezzi approached Eshbaugh regarding insurance in the fall of 1988. (1) Yezzi telephoned Eshbaugh to come to Yezzi's house to talk about policies. Joseph D. Yezzi Page 20 (a) Yezzi did not mention that the policies would be insurance policies. (2) When Eshbaugh arrived at Yezzi's house, Yezzi and another insurance company representative were present. (3) Yezzi proposed a savings life insurance plan to Eshbaugh at a cost of $55.00 per month. (4) Eshbaugh advised Yezzi that he might not be able to afford a premium of $55.00 per month. (5) Yezzi offered to Eshbaugh that "we'll" (the CTWA) give you (Eshbaugh) a $.50 raise retroactive to the day you (Eshbaugh) started and the raise would pay for the policy. (6) Yezzi told Eshbaugh that through the mechanism of the raise, Eshbaugh would get "almost a free policy." (a) Yezzi performed a calculation to determine whether the raise would cover the insurance. d. Following the purchase of the insurance policy by Eshbaugh, he received the $.50 per hour retroactive raise on his next paycheck. e. When Eshbaugh did not make timely payments on his insurance policy, Yezzi telephoned Eshbaugh at the CTWA or plant during working hours to go to the American General office to discuss the non - payment and the potential policy cancellation. (1) Yezzi placed these telephone calls to Eshbaugh on four or five separate occasions, which coincided with the week or the very day of Eshbaugh's pay days. (2) On at least one occasion the CTWA manager Ken Sisk picked Eshbaugh up from the job site in a CTWA vehicle and took Eshbaugh to Yezzi's office, stating that Yezzi wanted to see Eshbaugh. (3) Eshbaugh felt intimidated by Yezzi. f. Eshbaugh had been laid off before he bought insurance from Yezzi for two days. (1) The lay off occurred in September or August, 1988. 28. Joseph Sopko is employed by the CTWA as a part -time laborer. Joseph D. Yezzi Page 21 a. Sopko approached Yezzi in an effort to obtain more working hours. b. Yezzi approached Sopko about buying life insurance. (1) The approach was made in 1986 or 1987 when Sopko was employed by the CTWA. (2) Sopko bought a life insurance policy. (a) The policy was purchased about one year after the initial approach by Yezzi. c. Sopko did not feel that he had to purchase a life insurance policy from Yezzi. d. Sopko could have purchased insurance elsewhere but Sopko purchased the insurance from Yezzi because Yezzi helped him (Sopko). (1) The favor done by Yezzi for Sopko was giving him more working time. 29. Lawrence Zon is a full -time laborer employed by the CTWA. a. As part of his union benefits, he . receives health insurance as well as accident and cancer insurance. b. The CTWA provides life insurance for Zon. c. In 1986 or 1987, Yezzi approached Zon about the purchase of life insurance. (1) At that time Yezzi was a member of the Board of the CTWA. (2) At that time Zon was an employee of the CTWA. (3) Zon was contacted during working hours of the CTWA and went to Yezzi's office at American General during the CTWA working hours. (4) Yezzi told Zon that he (Yezzi) would work up a plan for Zon and his wife and wanted to set up an appointment. (a) An appointment was subsequently set up but Yezzi did not appear. (5) Zon was told by Yezzi that the insurance would cost approximately $50.00. Joseph D. Yezzi Page 22 (a) Zon responded that he could not afford insurance at that time. (6) Yezzi inquired of Zon as to Zonis pay rate. (a) Yezzi indicated to Zon that a raise was possible. (b) With the raise Zon could afford the insurance. (c) Zon received a $1.00 per hour raise about a month later but did not buy the insurance. (7) An understanding existed whereby Yezzi offered to obtain a raise for Zon in return for Zon purchasing insurance from Yezzi. (Fact Findings 29(c)(1) through ( d. Zon had approached the CTWA Board about the inequity of his doing the work of another employee who was in a rehab program and who was receiving more money than Zon. (1) Zon received the $1.00 per hour raise. (2) Yezzi advised Zon to go to the Board meeting. e. Zon has not received any raises after the $1.00 per hour raise referenced in sub - finding c(6)(c) other than through the contract. f. The contract with the CTWA for January 1, 1987 shows a typewritten pay rate for Zon of $8.05 which is crossed out and handwritten 9 under the 8. (1) As of January 1, 1988, the typed figure of $8.30 is crossed out with a handwritten $9.30 substituted. (2) As of July 1, 1988, the typewritten rate was $8.55 with a handwritten rate of $9.55. (3) There is also a handwritten notation: "as per JDY." 30. Kenneth Sisk is the manager of the CTWA. a. His duties as manager are to oversee the clerical and maintenance operations. b. The CTWA Board does the hiring and firing. c. Full -time employees are paid according to the union contract. Joseph D. Yezzi Page 23 (1) Part -time employees are paid at the going rate. d. Sisk was a CTWA Board member prior to his employment as manager. e. The following individuals are employed by the CTWA. (1) Elsie Spearing is a clerk who is a full -time employee. (2) Paul Barker is full -time in maintenance. (3) Kevin Eshbaugh is part -time in maintenance. (4) Joseph Sopko is part -time in maintenance. (5) Karen Galdony is a full -time office clerk. (6) Verna Dugan is the office chief clerk. (7) Steve Gulla is full -time in maintenance. (8) Anthony Fadool is full -time in maintenance. (9) James Lasky is full -time in maintenance. (10) Lawrence Zon is full -time in maintenance. (11) Randall Steward is a part -time meter reader. f. Donald Haldeman is a former part -time employee of the CTWA. (1) Haldeman was terminated on April 23, 1989. (2) Haldeman was in a laborer position. (3) Yezzi directed Sisk to tell Haldeman to call him (Yezzi). (a) Yezzi on a few occasions repeated the direction to Sisk to have Haldeman contact him (Yezzi). (4) Yezzi subsequently directed Sisk to tell Haldeman to contact Yezzi by 5:00 on that day (Friday) or he (Haldeman) would be "done." (a) Haldeman did not show up for work the following Monday. g. Through the CTWA, the full -time employees received Blue Cross /Blue Shield, eye and dental care and cancer insurance through American General. Joseph D. Yezzi Page 24 (1) Accident and dismemberment indemnity insurance is provided through Travelers. (a) At one point, that type of insurance was also provided in addition to the cancer insurance by American General. (b) The cancer and accident indemnity through American General lapsed around September, 1990. h. On at least one occasion, Yezzi directed Sisk to bring Eshbaugh to his office at American General because he (Yezzi) wanted to see him (Eshbaugh). i. When Sisk was a CTWA Board member, he filed Statements of Financial Interests (FIS). (1) Sisk currently files FIS's as the CTWA manager. (2) The chief clerk distributes the FIS forms at a meeting, usually in December or January. (a) Such action was taken every year as a matter of course. At Board meetings, there is a vote to pay total billings from the revenue checking account unless someone has a question. k. Yezzi abstained at the August 15, 1989 CTWA Board meeting as to the vote regarding the payment for the American General cancer and accidental death and dismemberment policy. 1. At the October 17, 1989 CTWA Board meeting, Yezzi did not abstain as to a unanimous vote to approve a group of bills which included a bill from American General. J m. At the November 21, 1989 CTWA Board meeting, Yezzi voted to approve a list of bills which included a billing from American General. n. In 1986, Zon came to the Board to talk about a raise. (1) The members of the Board were in favor of Zon getting a raise. (2) The Board minutes do not contain any notation as to a raise for Zon. o. Eshbaugh got a raise to bring his rate equal to that of Joseph D. Yezzi Page 25 Sopko. p. Eshbaugh was called to the office of Ronald DiGiorno who is the CTWA solicitor and nephew of Yezzi. (1) Sisk was present during the conversation between DiGiorno and Eshbaugh. (2) Upon questioning by DiGiorno, Eshbaugh stated that Paul Baker told him (Eshbaugh) that he would get a full -time position if "things work out." (a) The offer was not made in connection to Eshbaugh's testimony. 31. Susan Haldeman is the spouse of Donald Haldeman who is a former part -time laborer with the CTWA. a. Donald Haldeman received no benefits from his employment with CTWA. b. Yezzi approached Susan Heldeman regarding the purchase of insurance. (1) Yezzi and another young man came to her house without any prior notice. (2) Yezzi asked her about insurance and wanted to see her policies. (3) After being told by Mrs. Haldeman that she did not know where her policies were located, Yezzi and the other man left. (a) Mrs. Haldeman told Yezzi she would contact him when she decided on insurance. (4) Yezzi telephoned Mrs. Haldeman on several subsequent occasions concerning insurance. c. Her spouse was terminated in his employment with the CTWA. (1) The period between Yezzi's contact concerning insurance and the termination of her spouse was approximately two weeks. 32 P. Donald Haldeman is a former part -time laborer with the CTWA. a. He worked forty hours per week but was classified as part - time. Joseph D. Yezzi Page 26 (1) He received no benefits from his employment with the CTWA. b. Yezzi and another individual came to his house to discuss insurance with his spouse. (1) When asked to produce their insurance policies, Mrs. Haldeman responded that she did not know where they were. (2) Yezzi and the individual left shortly after they arrived. c. Haldeman's employment was terminated with the CTWA. d. At the end of one work day at CTWA, someone asked Haldeman if he was going to buy Yezzi's insurance. e. Kenneth Sisk told Haldeman to call Yezzi. (1) Haldeman called the office but was told Yezzi was not in. (2) Haldeman called Yezzi's home but Yezzi was not there. (3) When Haldeman reached Yezzi, Yezzi told Haldeman that . . we take care of those who take care of us." (a) The remark of Yezzi to Haldeman related to insurance. (b) Haldeman told Yezzi that Yezzi's remarks meant that Haldeman was "done" and Yezzi did not want him back to which Yezzi responded in the affirmative. f. Haldeman did not purchase insurance from Yezzi. g. Haldeman and his spouse never received a specific insurance proposal from Yezzi. h. Haldeman had an expectation of the cost of the insurance after he talked to another individual. 33. Patrick A. Brizzi was a member of the CTWA Board until December, 1990. a. Brizzi recommended cancer insurance to the Board. b. He has no recollection as to any Board action as to accident /dismemberment insurance. Joseph D. Yezzi Page 27 c. When Fadool, an employee of the Board developed cancer, Brizzi made inquiries as to how Fadool could be helped. d. Brizzi favored American General because it was local. e. Brizzi knew that Yezzi worked for American General. f. Brizzi's recollection was that Yezzi abstained on the vote to purchase the cancer insurance from American General. g. J Brizzi's memory was that the raise Eshbaugh received resulted from him (Eshbaugh) bringing to the Board's attention that he was getting less than the other part - timers. h. Brizzi had many dealings with Yezzi because Brizzi was the secretary and Yezzi was Chairman of the Board. i. If the Chief Clerk Verna Dugan left something out of the minutes, the Board could insert the omitted item through vote which would appear in subsequent minutes. Brizzi did no comparisons or independent research to compare rates for cancer insurance. k. Cancer insurance for Elsie Spearing, Gulla and Lasky was purchased in 1989 while Brizzi was on the Board. 1. The CTWA Board Chairman is primarily in charge of hiring. m. Yezzi recommended to Brizzi that Zon be given a $1.00 per hour raise. (1) Brizzi followed up on the recommendation with his own inquiries. n. Brizzi was unaware that the CTWA had accidental death and dismemberment policies with Travelers Insurance when the Authority obtained the same type of coverage from American General. (1) The American General policies were allowed to lapse because certain individuals were of the opinion that Yezzi got the coverage to benefit himself. (2) Brizzi believed that Yezzi was not receiving commission on the policies. 34. Joseph Panetta is a member of the CTWA Board. Joseph D. Yezzi Page 28 a. Panetta has served on the Board for approximately seven or eight years. b. Panetta is the current secretary of the Board. c. Eshbaugh's father contacted Panetta to see if there would be work for Eshbaugh at the CTWA. (1) Eshbaugh was hired by the CTWA Board. d. Eshbaugh came to the Board about getting a $.50 per hour raise. e. Panetta did not recall the circumstances surrounding Haideman's termination of employment with the CTWA. f. Panetta's recollection was that Haldeman was officially terminated by Board action in an official meeting or in an executive work session. g Cancer insurance was purchased after Anthony Fadool, a CTWA employee, developed cancer. (1) Brizzi volunteered to look into the matter of insurance. h. Panetta was unaware that Yezzi was getting commissions on the CTWA insurance policies with American General. 35. John Onderick is a member of the CTWA Board. a. Onderick was appointed to the Board in 1988. b. When an Authority employee developed cancer, Brizzi suggested that cancer insurance be obtained. c. Onderick learned at some point that the Board already had accident indemnity insurance with Travelers and questioned the duplicate coverage of accidental indemnity insurance with American General. (1) Onderick questioned why the Board did not have only one general policy that covered everybody. 36. Stuart Johnson is a sales manager for American General Life and Accident Insurance Company. a. He has been employed by American General since 1983 and as a sales manager since 1989. b. Yezzi was formerly a sales agent under Johnson. Joseph D. Yezzi Page 29 c. In Fall, 1988, he and Yezzi talked to Eshbaugh's about insurance. (1) The appointment was unusual in that it occurred at Yezzi's home. (2) No paperwork or information was ready for the appointment which is not unusual. d. Johnson was present on an insurance sales call to the Haldeman residence with Yezzi. (2) Mrs. Haldeman indicated to Johnson and Yezzi that she did not have her policies ready. (3) The meeting, which was a very short interview, ended. e. As a sales manager, Johnson receives an override from an agent's production but no salary. f. Johnson informally became sales manager in September, 1988 with Yezzi as one of the agents under his supervision. g. j. (1) There was no appointment for the meeting with Mrs. Haldeman. From May, 1989 to August, 1990 Johnson was transferred for that period of time to another area, Pittsburgh North, as sales manager. h. Yezzi's performance as a sales agent was average in the period between September 1988 and January 1989. (1) Yezzi was behind in preset quotas by American General as to goals to attend conferences. i. When Johnson returned in 1990 after his first assignment, the performance of Yezzi was low. It was Yezzi's idea to have the insurance sales meeting with Eshbaugh. (1) The meeting occurred during a weekday. (2) The meeting was prearranged. (3) Johnson brought a lap top computer to the meeting. (a) The lap top is capable of performing premium calculations and monthly costs for a particular Joseph D. Yezzi Page 30 type of policy. (4) The insurance policy discussed was an adjustable premium whole life policy. k. As to a cancer policy application, a representative of American General witnesses the signature of the insured and binds the company to provide insurance at the premium rate quoted. (1) On the back of the one page application is the agent's report followed by a box for the agent's certification. (a) The agent's signature and certification establish that he asked the questions and recorded the answers. 1. The policy register statement shows the total of business in the agency which is different from the agent's weekly statement, the latter being a computation of all compensation. (1) Copies of the policy register statements are given to the district manager, staff manager and agent. (a) Johnson puts the policy register statements in the agents in- boxes. m. An agent is compensated by commission with no salary (1) An agent is in the market to generate business. n. American General sets quotas for agents. (1) An agent must meet a minimum standard of sales. (2) The quota has been fairly consistent at one hundred dollars of matched progress per week. (a) Matched progress is net gain after lapse. (b) Matched progress above $5200 per year is above minimum. (3) An agent is put on counseling if he fails to meet the minimum standard. (a) Counseling is a corrective action to increase productivity. Joseph D. Yezzi Page 31 (b) An agent is terminated if counseling does not work. o. If there are high lapses, an agent could run into problems with minimum standards. 37. James Lasky is employed as a laborer for the CTWA. a. Lasky purchased an insurance policy from Yezzi when he was first employed by the CTWA. b. Lasky began employment on May 22, 1989 with the CTWA. c. After Lasky obtained the policy referenced in sub - finding (a) for two months, he cancelled the policy because he could not afford it. d. Lasky had a prior insurance dealing with Yezzi in 1983. e. Lasky's father -in -law was on the CTWA Board when Lasky was hired. f. Prior to his return to Pennsylvania in May, 1989, Lasky lived in Arizona. (1) He returned to Pennsylvania due to the lack of work in Arizona. g. Lasky did not have a job lined up when he returned to Pennsylvania in May, 1989. (1) He could not afford insurance when he returned. h. Lasky became employed by the CTWA on a full -time basis. (1) Through the employment and living with in -laws, Lasky could afford insurance. i. As of September 5, 1989, arrangements were being made for Lasky to be inducted into the union. 38. Henry A. DeLouis is an insurance manager for the Beaver Valley District of American General Life and Accident Insurance Company. a. He was the supervisor for Yezzi who worked out of his office. b. Yezzi left employment with American General in 1990. c. A Board member of the CTWA contacted him regarding cancer insurance. Joseph D. Yezzi Page 32 d. DeLouis states that he filled out the cancer insurance application. (1) DeLouis states that some policies were completed by someone else in his office. e. DeLouis testified that Yezzi was not involved in taking the cancer and accident indemnity policies with the CTWA. (1) DeLouis states that he put Yezzi's service number on the cancer and accident indemnity policies to give Yezzi the credit. (a) DeLouis states that he did not tell Yezzi that he (DeLouis) assigned the production credit to him. f. DeLouis receives an override on the business the agents in his office generate. g • Yezzi left employment with American General because he was not meeting company minimum standards as to business. h. DeLouis states that when the State Ethics Commission subpoenaed American General records, DeLouis spoke to Yezzi who, according to the testimony of DeLouis, indicated surprise that he (Yezzi) was assigned the production credit. i. DeLouis had no involvement with the sale of life insurance to Kevin Eshbaugh, James Lasky or Joseph Sopko. As to cancer applications for the CTWA personnel, the front page of the application, top portion was filled out by DeLouis as to Spearing, Barker, Eshbaugh, Sopko, Gaidony, Gulla, Sisk and Zon. j• (1) As to a second group of policies, the top portion was written by DeLouis as to Dugan and Sisk but not Gulia, Lasky, Gaidony, Spearing, Eshbaugh, Sopko, Barker, Fadool, or Zon. k. As to policy identified as Exhibit ID -23, DeLouis did not write Yezzi's name in the production credit box. (1) The writing appeared to be Yezzi's. 1. For the policies referenced in sub - finding j the policy register statement for August 21, 1989 for the policy dated August 21, 1989 establish that the production credit box was filled in prior to the application being sent to American General's Nashville office. Joseph D. Yezzi Page 33 m. DeLouis never appeared at a CTWA Board meeting or made any presentation to the Board about insurance. n. When a commission is assigned to an agent, he is responsible for collecting the premiums. o. Cancer insurance is different from accident and indemnity insurance and each type of policy may be purchased separately. (1) For the CTWA personnel, there were separate applications for cancer and accident and indemnity policies. p. Yezzi was terminated after he received a number of written warnings from the Nashville office of American General and from DeLouis. q• (1) Since a March, 1990 counseling form advised Yezzi that he did not meet $100.00 matched part progress, an insurance business drop occurred as to Yezzi prior to the date on the form. A conversation occurred between DeLouis and Yezzi regarding why he (Yezzi) could not participate in the policies with the CTWA. (1) The conversation occurred before DeLouis filled out part of some of the applications of the CTWA personnel. (2) DeLouis testified that he saw a distinction between Yezzi having a problem selling insurance to the CTWA but not in receiving commission which was assigned by DeLouis. r. As to the CTWA cancer and accident /indemnity policies, the premiums were monthly but later switched to annual premiums. (1) The premiums were paid by the CTWA. (2) The bills were generated from the American General office. s. Yezzi was meeting American General's performance standard up to the latter part of 1989. (1) Yezzi's failure to meet standards in the first quarter of 1990 would be based upon the last three quarters of Joseph D. Yezzi Page 34 1989 and the first quarter of 1990. t. As to Exhibit ID -23, 25, and 27, the acknowledgements that the applicants were known for specified years were completed by Yezzi. (1) DeLouis did not personally know the applicants. 39. Richard A. Cercone was a member of the CTWA. a. Cercone was a Board member from 1980 until December, 1989. b. After an employee on the work force contracted cancer, a direction was given to Brizzi to look into insurance. (1) Cercone knew at that time that Yezzi was working for American General. c. Cercone states that the Board discussed both cancer and accident /indemnity insurance. d. Kevin Eshbaugh came to the CTWA Board and requested that he be given a raise to be in parity with the hourly rate of Joe Sopko. e. As to the $1.00 per hour raise for Zon, Zon came to the Board and stated he deserved the raise because he was also doing the work of another employee. f. James Lasky was hired shortly after the termination of Haldeman. g. Cercone was unaware that the CTWA had accident /indemnity insurance with Travelers. 40. Ronald J. DiGiorno is the Solicitor for the CTWA. a. DiGiorno states that he was aware that the CTWA had accident /indemnity insurance with American General in addition to the subsequent accident indemnity insurance with American General. b. DiGiorno states that due to the State Ethics Commission investigation, he planned but never made a recommendation to the CTWA Board not to renew the cancer insurance. c. DiGiorno testified that Eshbaugh indicated to him that he (Eshbaugh) was promised full -time employment by the CTWA foreman if he testified properly against Yezzi. d. As to the $1.00 per hour raise for Zon, DiGiorno states Joseph D. Yezzi Page 35 that there were discussions by the CTWA Board as to Zon doing the work of another employee, Gulla and that Zon wanted a raise. e. DiGiorno became Solicitor of the CTWA within a year of Yezzi's appointment to the CTWA. f. Yezzi is the uncle of DiGiorno. g. DiGiorno has acted as counsel for Yezzi in private matters. h. DiGiorno states he called Eshbaugh to his office to discuss threats made to other employees of the CTWA. (1) DiGiorno testified that such actions may be in violation of the Ethics Law. (2) DiGiorno discussed the possible violations with Yezzi. (a) DiGiorno knew at that time that Yezzi was under investigation by the State Ethics Commission. i. DiGiorno asked Zon as to why he (Zon) was not cooperating with the investigator Yezzi hired as to the State Ethics Commission investigation. (1) DiGiorno asserts that he made the comment to Zon to see if he (Zon) was being intimidated like other employees. j. DiGiorno, while township solicitor, purchased insurance from Yezzi. 41. Joseph D. Yezzi is the Chairman of the CTWA. a. Yezzi has been in insurance for approximately 30 years. b. Yezzi worked for American General beginning in the 1980's until his termination in 1990, except for a period when he worked in a private venture as to the purchase of a lounge. c. Yezzi is currently an agent for Western and Southern. d. Yezzi was appointed to the CTWA Board around 1984 for a five year term and was re- appointed. e. The CTWA Board had discussions about insurance after an employee (Fadool) developed cancer. (1) Brizzi was assigned to look into the matter of insurance. Joseph D. Yezzi Page 36 Prior to the CTWA Board obtaining the cancer and accident /indemnity policies from American General, Yezzi advised Brizzi that the American General policies were good ones. f. Yezzi admits that he helped to complete portions of some of the CTWA cancer insurance applications in his own printing, and that he filled in his own name in the production credit box for the production credit and affixed his signature to many of the CTWA cancer insurance policies. (2) (1) Yezzi states that the policy forms were put on his desk with a direction to fill in the blanks. (a) At some point, Yezzi testified that he turned over a policy and became aware that it was for a CTWA employee. (2) Yezzi states that he went to DeLouis' office to advise that he (Yezzi) did not want to be involved with CTWA policies. (a) Yezzi testified that De Louis told him (Yezzi) to fill out the rest of the policies and that he (DeLouis) would insure that Yezzi would not get the commission. (b) Yezzi states that when the policies would be issued, he believed that De Louis would change the policies to annual premiums and exclude him (Yezzi) from the profit for the policies. (c) Yezzi did fill out the portion where it indicated the number of years he (Yezzi) applicant for the CTWA policies. (d) Yezzi testified that at the time he gave applications back to DeLouis he knew his number was on them. knew the these own agent (e) Yezzi acknowledged that he could have crossed out his name and agent number on the policies, but stated that he did not because his boss did not want him to do so. (f) Yezzi testified that he would not put false information on an insurance application if his boss told him to do that. (1) Yezzi admitted that his certification on the Barker and other applications were false Joseph D. Yezzi Page 37 of. because the applications were not signed in his presence and he (Yezzi) did not ask each question on the application as to Barker and the other CTWA employees. (g) Yezzi states that De Louis requested him (Yezzi) one or two weeks later to fill out CTWA policies and he refused but then complied after De Louis assured him that the matter would be taken care g. Yezzi abstained as to the voting to approve the payment of the premium on the American General policies at the August (1989) Board meeting. (1) Yezzi acknowledged that at the November 21, 1989 meeting he voted on paying a bill from American General, but states that he did not know at the time that the bills included a bill from American General. h. Yezzi signed checks to American General as one of the three CTWA signatures, and he also endorsed at least one of these checks on the back for deposit to American General. i. Yezzi received commissions from the CTWA insurance policies with American General. (1) Yezzi states that he first became aware of his receipt of commissions on CTWA's insurance policies from American General in 1991 when DeLouis told him in the context of the SEC investigation. Yezzi testified that he did not read his policy register statements or agent's weekly statements. (1) Yezzi stated that he knew approximately what insurance business he had "written" and what the commission was to be. (2) Yezzi knew from his paycheck whether it reflected the amount of insurance business he did. k. Yezzi had conversations about insurance policies with CTWA personnel after issuance. 1. Yezzi states that Eshbaugh approached him at the election polls about buying insurance. (1) Yezzi testified that there was no connection between Eshbaugh completing an application on October 17, 1988 to buy insurance from Yezzi, and Eshbaugh's raise which Joseph D. Yezzi Page 38 took place seven days later on October 17, 1989. m. Yezzi testified that he did not prepare an application or give a price quote for insurance to Zon. (1) Yezzi states that Zon brought up the subject of an insurance program when Zon came to Yezzi's office to ask for a raise because he (Zon) needed more money due to financial troubles. (2) Yezzi states that there was no understanding by him that the raise for Zon would be tied into Zon purchasing insurance. n. Yezzi states that he went to the Haldeman home concerning insurance at the request of Mrs. Haldeman. (1) Yezzi testified that Mrs. Haldeman told him (Yezzi) that she was concerned about additional coverage because Haldeman was always tired and losing weight. o. Yezzi states that Haldeman was making slanderous remarks against him (Yezzi) about being forced to purchase insurance. (1) Yezzi testified that he told Sisk to tell Haldeman to call him (Yezzi) and became upset when Haldeman failed to do so. P. The period of time between Yezzi's visit to the Haldeman home and the termination of Haldeman was approximately two weeks. q. Haldeman had a telephone conversation with Yezzi on the day he (Haldeman) was terminated as a part -time employee of CTWA. (1) Yezzi states that he told Haldeman that he had two weeks to call him (Yezzi) about slanderous remarks and Haldeman responded that he helped during election time and inquired about insurance. r. As to the sale of insurance to Lasky, Yezzi states that Lasky's wife made the contact to purchase insurance, and that the purchased insurance subsequently lapsed when the Lasky's moved and had to start paying rent. s. The Financial Interest Statements (FIS's), were filed late by Yezzi. (1) Yezzi states that he filed the forms after he went to a Joseph D. Yezzi Page 39 C. EXHIBITS: water convention in Hershey and a speaker of the SEC spoke about filing the FIS form. a. Yezzi testified that he filed the forms the week after he came back from the convention. b. Yezzi backdated the FIS's by filling in the incorrect dates on the bottom of the FIS's when he filed them, which were not the dates the forms were actually filed. c. When Yezzi delinquently filed his FIS's, he used March or April dates so that the forms would bear a date prior to the date they had been due. (2) Yezzi acknowledged that he knew prior to the time he went to the conference in Hershey that he had to file the FIS's but had failed to do so. (3) The April, 1986 minutes of CTWA reflect commentary that notice was served from the SEC that the Board members and others had to file FIS's. (4) Yezzi acknowledged that the minutes of the meeting on September 16, 1986, at which he was present, confirm that it was reported that one FIS was outstanding at that time. (5) Yezzi acknowledged that calendar 1985 was one of the years for which he did not file an FIS on time. t. Yezzi states that his personnel file with American General reflecting his termination in 1984 for failure to meet production standards is inaccurate. u. Yezzi's 1984 employment application with American General reflects Yezzi's statement that he continuously does contacting for politics, charitable organizations, etc., and that he would incorporate this with business. 42. A review of the records of American General reflect the following commissions paid to Yezzi as to CTWA policies and certain other policies as to individuals who are CTWA employees (Exhibit ID -22). Joseph D. Yezzi Page 40 Policy 130710468 118273100 118298010 118298011 118298014 118298015 118317803 130710470 130710473 130710474 130710476 130710477 188281733 189226111 189018383 12 -11 118298012 118298017 115506984 130710471 130710472 130710475 130710479 130710480 Name Gulla, Steve Spearing, Elsie Barker, Paul Eshbaugh, Kevin Galdony, Karen Dugan, Verna Fadool, Anthony Spearing, Elsie Galdony, Karen Eshbaugh, Kevin Barker, Paul Fadool, Anthony Eshbaugh, Kevin Sopko, Joseph M. Lasky, James Policy Lapsed Net Commission Sopko Sisk Zon Lasky, James Dugan, Verna Sopko, Sr. Joseph Zen, Jr. Lawrence Sisk, Kenneth Sales Comm. Conservation 19.08 19.08 47.25 29.70 50.88 44.77 16.98 10.67 47.25 29.70 22.93 14.41 269.32 269.32 19.08 19.08 19.08 19.08 19.08 19.08 19.08 19.08 19.08 19.08 161.29 198.00 300.64 150.32 290.30 133.06 - 193.54 - 133.06 96.76 0.00 50.88 44.77 41.88 36.85 23.23 14.60 19.08 19.08 19.08 19.08 19.08 19.08 19.08 19.08 19.08 19.08 43. An American General Cancer Insurance application for Elsie Spearing, policy number 118273100, dated 08/03/89, reflects the signature of licensed agent as Joseph D. Yezzi in the "Agent's Certification" box whereby Yezzi certifies that he asked each question in the "Agent's Report" box and recorded the answers as given by the applicant (Exhibit (s) ID -23). a. The agent answered question 5 in the "Agent's Report" as to how long he knew the proposed insured as 5 years. b. The production credit box reflects Yezzi's service number 133512 to be credited with commissions. c. The application reflects a collection of $13.23 with premium due in the amount of $121.77. d. The issued policy reflects Elsie Spearing as the insured with an annual premium of $135.00. 44. An American General Cancer insurance application for Paul L. Joseph D. Yezzi Page 41 Barker, policy number. 118298010, dated August 2, 1989, reflects the signature of licensed agent as Joseph D. Yezzi in the "Agent's Certification" box whereby Yezzi certifies that he asked each question in the "Agent's Report" box and recorded the answers as given by the applicant (Exhibit (s) ID -24, 25, 26). a. The agent answered question 5 in the "Agent's Report" as to how long he knew the proposed insured as 20 years. b. The production credit box reflects Yezzi's service number 133512 to be credited with commissions. c. The application reflects a collection of $20.45 with premium due in the amount of $183.05. d. The issued policy reflects Paul L. Barker as the insured with an annual premium of $203.50. 45. An American General Cancer insurance application for Kevin L. Eshbaugh, policy number 118298011, dated August 2, 1989, reflects the signature of licensed agent as DeLouis in the "Agent's Certification" box whereby DeLouis certifies that he asked each question in the "Agent's Report" box and recorded the answers given by the applicant (Exhibit (s) ID -27). a. The agent answered question 5 in the "Agent's Report" as to how long he knew the proposed insured as 4 years. b. The production credit box reflects Yezzi's service number 133512 to be credited with commissions. c. The application reflects a collection of $5.01 with premium due in the amount of $43.49. d. The issued policy reflects Kevin L. Eshbaugh as the insured with an annual premium of $48.50. 46. An American General Cancer insurance application for Joseph M. Sopko, Sr., policy number 118298012, dated August 2, 1989, reflects the signature of licensed agent as DeLouis in the "Agent's Certification" box whereby DeLouis certifies that he asked each question in the "Agent's Report" box and recorded the answers as given by the applicant (Exhibit (s) ID -28). a. The agent answered question 5 in the "Agent's Report" as to how long he knew the proposed insured as 10 years. b. The production credit box reflects Yezzi's service number 133512 to be credited with commissions. c. The application reflects a collection of $19.74 with premium Joseph D. Yezzi Page 42 due in the amount of $183.76. d. The issued policy reflects Joseph M. Sopko, Sr. as the insured with an annual premium of $203.50. 47. An American General Cancer insurance application for Karen Galdony, policy number 118298014, dated August 2, 1989, reflects the signature of licensed agent as Joseph D. Yezzi in the "Agent's Certification" box and recorded the answers as given by the applicant (Exhibit (s) ID -29). a. The agent answered question 5 in the "Agent's Report as to how long he knew the proposed insured as "just met ". b. The production credit box reflects Yezzi's service number 133512 to be credited with commissions. c. The application reflects a collection of $13.23 with premium due in the amount of $121.77. d. The issued policy reflects Karen C. Galdony as the insured with an annual premium of $135.00. 48. An American General Cancer insurance application for Verna M. Dugan, policy number 118298015, dated August 2, 1989, reflects the signature of licensed agent as Joseph Yezzi in the "Agent's Certification" box whereby Yezzi certifies that he asked each question in the "Agent's Report" box and recorded the answers as given by the applicant (Exhibit (s) ID -30). a. The agent answered question 5 in the "Agent's Report" as to how long he knew the proposed insured as 10 years. b. The production credit box reflects Yezzi's service number 133512 to be credited with commissions. c. The application reflects a collection of $6.63 with premium due in the amount of $58.87. d. The issued policy reflects Verna M. Dugan as the insured with an annual premium of $65.50. 49. An American General Cancer insurance application for Steve W. Gulla, policy number 118298016, dated August 14, 1989, reflects no signature of a licensed agent in the "Agent's Report" box for the recorded answers as given by the applicant (Exhibit (s) ID- 31). a. The agent answered question 5 in the "Agent's Report" as to how long he knew the proposed insured as 5 years. Joseph D. Yezzi Page 43 b. The production credit box reflects Yezzi's service number 133512 to be credited with commissions. c. The application reflects a collection of $6.63 with premium due in the amount of $58.87. d. The issued policy reflects Steve W. Gulla as the insured with an annual premium of $65.50. 50. An American General Cancer insurance application for Kenneth J. Sisk, policy number 118298017, dated August 2, 1989, reflects the signature of licensed agent as Joseph Yezzi in the "Agent's Certification" box whereby Yezzi certifies that he asked each question on the "Agent's Report" box and recorded the answers as given by the applicant (Exhibit (s) ID -32). a. The agent answered question 5 in the "Agent's Report" as to how long he knew the proposed insured as "just met ". b. The production credit box reflects Yezzi's service number 133512 to be credited with commissions. c. The application reflects a collection of $16.32 with premium due in the amount of $151.18. d. The issued policy reflects Kenneth J. Sisk as the insured with an annual premium of $167.50. 51. The American General Cancer insurance application for Lawrence Zon, Jr., policy number 115506984, dated August 2, 1989, reflects the signature of licensed agent as Joseph Yezzi in the "Agent's Certification" box whereby Yezzi that he asked each question in the "Agent's Report" box and recorded the answers as given by the applicant (Exhibit (s) ID -33, 34). a. The agent answered question 5 in the "Agent's Report" as to how long he knew the proposed insured as not completed. b. The production credit box reflects Yezzi's service number 133512 to be credited with commissions. c. The application reflects a premium in the amount of $5.53. d. The issued policy reflects Lawrence Zon, Jr. as the insured with an annual premium of $54.00. 52. The American General Accident and Indemnity insurance applications for the following CTWA employees reflect the name of DeLouis in the "Agent's Name" box but the service number of 133512 (Yezzi) appears opposite the name DeLouis. Joseph D. Yezzi Page 44 Name Steve W. Gulla James L. Lansky Verna M. Dugan Karen C. Gaidony Elsie Spearing Kevin L. Eshbaugh Joseph M. Sopko Paul L. Barker Anthony L. Fadool Lawrence Zon, Jr. Kenneth J. Sisk a. b. Policy Number 130710468 130710471 130710472 130710473 130710470 130710474 130710475 130710476 130710477 130710479 130710480 Exhibit Number ID -35 ID -36 ID -37 ID -38 ID -39 ID -40 ID -41 ID -42 ID -43 ID -44 ID -45 53. Yezzi completed an application for an American General insurance policy for Kevin Eshbaugh, policy number 188281733 on or about 10/17/88 (Exhibit ID -46). a. The "Agent's Certification" box reflects the signature of licensed agent as Joseph D. Yezzi. b. The commission credit would go to Yezzi through his service number 133512. c. The policy date reflects a policy date of November 14, 1988, a face amount for the policy of $25,000, an issue premium of $55.00 and a maximum monthly premium of $58.98. 54. Yezzi completed an application for an American General insurance policy for James Lasky, policy number 189018383 on or about June 15, 1989 (Exhibit ID -47). a. The "Agent's Certification" box reflects the signature of licensed agent Joseph D. Yezzi. b. The commission credit would go to Yezzi through his service number 133512. c. The policy date reflects a policy date of June 28, 1989, a face amount for the policy of $50,000, a premium of $50.40 and premium interval on a monthly basis. 55. Yezzi completed an application for an American General insurance policy for Joseph M. Sopko, Sr., policy number 189226111 on or about February 21, 1989 (Exhibit ID -48). The "Agent's Certification" box reflects the signature of licensed agent Joseph D. Yezzi. The commission credit would go to Yezzi through his service number 133512. Joseph D. Yezzi Page 45 c. The policy date reflects a policy date of March 17, 1989 a face amount for the policy of $15,000, an issue premium of $56.94 and a maximum monthly premium of $74.91. 56. An American General insurance policy for Anthony Fadool, number 118317803 was completed on or about October 17, 1989 with DeLouis's name written for the signature of the licensed agent with Yezzi's service number 133512 given the commission credit (Exhibit ID -49). a. The policy date is October 23, 1989. b. The premium is $74.81 on a monthly basis. 57. The following reflects the wage scale history for certain employees of CTWA (Exhibits ID -1, 2, 13). Name a. Joseph M. Sopko, Sr. b. Kevin L. Eshbaugh c. Lawrence Zon, Jr. Date Rate of pay ($ /hr.) 12/19/85 11/86 09/18/89 01/01/85 07/01/85 01/01/86 07/01/86 11/01/87 01/01/88 4.00, 4.50 5.50 05/11/88 4.00 10/24/88 4.50 (Retroactive to 05/11/88) 09/18/89 5.50 6.40 6.65 6.90 7.90 9.05 9.30 58. By letters dated 03/06/90 and 06/25/90 Yezzi was advised by Samuel J. Billante, Vice President of Marketing Services for American General that Yezzi's progress performance was below the "minimum premium growth standard of $100 matched conference progress per week..." (Exhibits ID -56, 57). 59. The minutes of CTWA reflect in part the following; a. April 15, 1986 meeting (Exhibit ID -3). (1) Notice from the SEC as to FIS's regarding completing the form by Board Members and certain employees. (2) Yezzi listed as present. Joseph D. Yezzi Page 46 (a) No abstentions or nay votes. (3) Approval of bills. b. September 16, 1986 meeting (Exhibit ID -59). (1) Yezzi listed as present. (2) Bills approved. (a) No abstentions or nay votes. (3) Chief clerk advises that one 1985 FIS is outstanding. c. June 21, 1988 meeting (Exhibit ID -4). (1) Yezzi listed as present. (2) Approval of bills. (a) No abstentious or nay votes. d. October 12, 1988 meeting (exhibit ID -5). (1) Yezzi listed as arriving 20 minutes late. (2) Discussion as to Fadool and lack of sick pay. (a) The Board directed the clerk to advise Fadool to the above and to contact Onderick to see if State assistance is available. e. November 26, 1988 meeting (Exhibit R -6). (1) Yezzi listed as present. (2) Board adjourns to executive session to discuss personnel matters and contract negotiations. f. January 17, 1989 meeting (Exhibit ID -6). (1) Yezzi listed as present. (2) Approval of bills. (a) No abstentions or nay votes. (3) Wage increases for maintenance employees covering a three year period. g. May 18, 1989 meeting (Exhibit ID -7). Joseph D. Yezzi Page 47 (1) Yezzi listed as present, arriving one -half hour after the meeting started. (2) Board action to have part -time summer employees at $4.00 per hour. (3) Board action to have James L. Lasky as a full -time employee at $7.50 per hour with Yezzi voting in favor of the motion with no nay votes and Cercone abstaining. h. July 26, 1989 meeting (Exhibit ID -8). (1) Yezzi listed as present. (2) List of bills approved. (a) No abstentions or nay votes. (3) Board advised Eshbaugh that there are no full time positions available as to his request for full time employment. i. August 15, 1989 meeting (Exhibit R -1). (1) Yezzi listed as present. (2) Bills approved. 1 (a) No abstentions or nay votes except Yezzi abstaining for payment to American General as to insurance policy premiums. (3) Notation that premiums from American General are going to be changed from monthly to annual billing. September 19, 1989 meeting (Exhibit R -2). (1) Yezzi listed as present. (2) Bills approved. (a) No abstentions or nay votes. (3) Unanimous Board action to increase the wages of part - time employees Sopko and Eshbaugh by $1.00 per hour. k. October 17, 1989 meeting (Exhibit R -3). (1) Yezzi listed as present. Joseph D. Yezzi Page 48 (2) Bills approved. (a) No abstentions or nay votes. (b) Bills included premium payment for American General insurance policies for CTWA employees which passed with all voting in favor thereof. 1. November 21, 1989 meeting (Exhibit R -4). (1) Yezzi listed as present. (2) Bills approved. (a) No abstentions or nay votes. (b) Bills included premium payment for American General insurance policy for CTWA employees which passed with all voting in favor thereof. 60. The minutes of the CTWA Exhibit ID -63 do not contain any of the following: a. An authorization for Brizzi to investigate obtaining cancer insurance for CTWA employees. b. The termination of part -time CTWA employee Donald Haldeman. c. A $0.50 per hour raise for the CTWA employee Kevin Eshbaugh on or about October 18, 1988 retroactive to May 1988. d. A $1.00 per hour raise for the CTWA employee Lawrence Zon for 1987. e. An authorization to purchase a contract with American General for cancer or accident /indemnity insurance for CTWA employees. III. DISCUSSION: (1) The minutes for August 15, 1989 reflect a vote to approve billings and payment thereof as to which Yezzi abstained. As the Chairman of the Center Township Water Authority (CTWA), Joseph D. Yezzi, hereinafter Yezzi, is a public official as that term is defined under Act 170 of 1978 and under Act 9 of 1989. 65 P.S.S402. As such, his conduct is subject to the provisions of the Ethics Law and the restrictions therein are applicable to him. Initially, it is noted that Section 9 of Act 9 of June 26, 1989 Joseph D. Yezzi Page 49 provides, in part, as follows: "This amendatory act shall not apply to violations committed prior to the effective date of this act, and causes of action initiated for such violations shall be governed by the prior law, which is continued in effect for that purpose as if this act were not in force. For the purposes of this section, a violation was committed prior to the effective date of this act if any elements of the violation occurred prior thereto." Since the occurrences giving rise to the allegations in this case transpired before and after the effective date of Act 9 (June 26, 1989), we must apply the provisions of the respective Acts to determine whether the Ethics Act was violated. The allegations before us are whether Yezzi as the Chairman of the Center Township Water Authority (CTWA) violated provisions of both Act 170 of 1978 and Act 9 of 1989 by using his public position to sell insurance policies to Authority employees and to the Authority. In addition there is an allegation that Yezzi violated section 4(a) of Act 170 of 1978 by failing to file Statements of Financial Interests (FIS's) for the 1984 through 1987 calendar years. Under Section 3(a) of Act 170 of 1978 quoted above, this provision of law prohibits a public official /employee from using public office or confidential information to obtain a financial gain other than compensation provided for by law for himself, a member of his immediate family or business with which he is associated. See Hoak /McCutcheon v. SEC, 77 Pa. Commw. Ct. 529, 466 A.2d 283 (1982); Koslow v. SEC, 116 Pa. Commw. Ct. 19, 540 A.2d 1374 (1988), alloc. den., Pa. , 553 A.2d 971 (1988). Section 3(b) of Act 170 of 1978 specifically provides in part that no person shall offer or give to a public official and no public official shall solicit or accept anything of value based upon an understanding that the vote, official action or judgement of the public official /employee would be influenced thereby. See Volpe, Order 579R; Smith, Order 578R. Section 4(a) of Act 170 of 1978 specifically requires that every public employee and every public official (Kremer v. SEC, 56 Pa. Commw. Ct. 160, 424 A.2d 968 (1981), affirmed, 503 Pa. 358, 469 A.2d 593 (1983) shall file an FIS for the preceding calendar year as to each year that the individual holds public office or employment and for the year after he leaves such position. Under Section 3(a) of Act 9 of 1989 quoted above, a public official /employee shall not engage in conduct that constitutes a Joseph D. Yezzi Page 50 conflict of interest. The term "conflict of interest" is defined under Act 9 of 1989 as follows: Section 2. 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. "Conflict" or "conflict of interest" does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. 65 P.S. 5402. Turning to Section 3(a) of Act specifically provides that a public authority of office for the private member of his immediate family or a of his immediate family is associat 9 of 1989, this provision of law official /employee may not use the pecuniary benefit of himself, a business with which he or a member ed. The specifics of the allegations are that under Section 3(a) of Act 170 of 1978 Yezzi used public office to obtain a financial gain consisting of commissions on individual insurance policies that he sold to the employees of the Authority and under Section 3(b) that an understanding existed whereby Yezzi offered to obtain raises for certain employees as to their hourly rate of pay at the CTWA in return for the purchase of insurance by these employees from Yezzi. The specific allegation under Section 3(a) of Act 9 of 1989 is that Yezzi used the authority of office to obtain a private pecuniary benefit for himself consisting of cancer and accident /indemnity insurance policies that were sold to the CTWA for its employees. Factually, Yezzi has been a member of the CTWA since he was appointed in October of 1984 and has served as Chairman since 1988. The CTWA is a municipal authority which supplies water services and employs a maintenance department to perform necessary repairs and maintenance on the system. The CTWA employs full time individuals, who are eligible to become union members after serving a ninety day Joseph D. Yezzi Page 51 probationary period with wages and benefits set by union contract, and part time employees whose wages, raises and benefits are approved by the Board of the CTWA. The record reflects that Yezzi had discussions regarding the sale of insurance policies and in some cases actually sold insurance policies to individuals who were also full time or part time employees of the CTWA. The individual employees as to whom Yezzi had discussions or sold policies are Kevin Eshbaugh, Joe Sopko, James Lasky, Lawrence Zon and Donald Haldeman. As to each of these individuals, we must review the record to determine whether Yezzi used public office under Section 3(a) of Act 170 of 1978 to obtain a financial gain for himself through selling policies or whether under Section 3(b) of Act 170 of 1978 Yezzi offered something of value to these individuals based on an understanding that the individuals would purchase policies from Yezzi. We will now consider the facts and circumstances as to the approach or sale of insurance by Yezzi to each of the Authority employees. As to Kevin Eshbaugh, Eshbaugh is a part time laborer without any union protection. The starting salary for Eshbaugh was $4.00 per hour. In the fall of 1988, Yezzi approached Eshbaugh regarding insurance. Yezzi telephoned Eshbaugh to come to Yezzi's house to talk about policies. Eshbaugh was not informed that the policies to be discussed were insurance policies. When Eshbaugh arrived at Yezzi's house, Yezzi and another company representative were present. After Yezzi proposed a savings life insurance plan to Eshbaugh and Eshbaugh responded that he would not be able to afford the premium, Yezzi at that time offered to get Eshbaugh a raise at the CTWA so that Eshbaugh would be able to buy insurance. In particular, Yezzi told Eshbaugh that through the mechanism of a raise, Eshbaugh would get "almost a free policy ". Yezzi performed a calculation to determine whether the raise would cover the insurance. Eshbaugh purchased the insurance policy and received the retroactive raise one week later in his next paycheck. Subsequently, when Eshbaugh did not timely make payments on his insurance policy, Yezzi would call Eshbaugh or would have Sisk, the CTWA manager, bring Eshbaugh to his office from the job site in a CTWA vehicle. Such activity occurred during weeks that Eshbaugh was to be paid by the CTWA or even on the very same day that Eshbaugh was to be paid. Eshbaugh was intimidated by Yezzi. Yezzi however argues that he did not solicit Eshbaugh but rather Eshbaugh approached him about insurance and that there was no connection between Eshbaugh buying insurance from Yezzi and Eshbaugh receiving the retroactive raise one week later. For the reasons noted infra, we do not find Yezzi to be credible. Contrariwise, we find Eshbaugh to be credible and in fact courageous in his testimony considering that he is a part time employee with no union protection and is testifying against the Chairman of the Board of the CTWA, his Joseph D. Yezzi Page 52 employer. Under the above facts, we find violations of both Sections 3(a) and 3(b) of Act 170 of 1978. As to Section 3(a), Yezzi has used public office consisting of his position of Chairman of the CTWA to pressure Eshbaugh, a part time, at will, employee to purchase insurance from Yezzi, and further has used public office by using the staff, facilities, time and resources of CTWA effectuating insurance transactions. The purchase of the insurance generated a financial gain consisting of the commissions and wages that Yezzi received from the insurance company by selling the policy to Eshbaugh. Lastly, the financial gain is other than compensation provided by law because there is no provision in law which allows or authorizes a member of a municipal authority to specifically use the status of his office or exert pressure because of the position he holds to obtain, as a result thereof, a private financial gain for himself. See Verszyla, Order 799. We are particularly concerned by the totality of the circumstances whereby Yezzi has used public office in terms of the status and power that he wields as Chairman to pressure an at will employee, Eshbaugh, to purchase insurance through him and has then used the authority of office to intimidate that employee to continue paying the premiums on the policy so as to insure the continued generation of commissions to Yezzi. Likewise, we find a violation of Section 3(b) of Act 170 of 1978 because an understanding did exist whereby Yezzi offered to obtain a raise for Eshbaugh from the CTWA based on the expressed understanding that through the mechanism of the raise Eshbaugh would have enough money to purchase an insurance policy through Yezzi. Thus, the understanding existed that Yezzi's actions would be influenced whereby he would attempt to obtain a raise for Eshbaugh based on the understanding that Eshbaugh would purchase insurance from Yezzi. (Fact Finding 27). See Volpe, supra; Smith, supra. As to Joseph Sopko, Sopko is also employed by CTWA as a part time laborer. The record reflects that at some point Sopko approached Yezzi in an effort to obtain more working hours. Subsequently Yezzi approached Sopko about purchasing life insurance. In 1986 or 1987, approximately, Yezzi approached Sopko about insurance, and Sopko did buy a life policy. Sopko did not feel that he had to purchase the policy from Yezzi but did so because Yezzi had helped him in a prior occasion regarding obtaining more working time. As to Sopko, we do not find a violation of Section 3(a) or 3(b) of Act 170 of 1978. Although it is clear that Yezzi did approach Sopko about insurance and subsequently sold him a policy, there is nothing of record to establish in this instance a use of public office on the part of Yezzi to obtain the financial gain consisting of the commission on the sale of the policy. Absent the requisite use of public office, we are constrained to find that there was no violation as to Section 3(a) of Act 170 of 1978 as to the sale of insurance to Sopko. Likewise, we do not find the requisite understanding necessary for violation under Joseph D. Yezzi Page 53 Section 3(b) in that Sopko indicated that he did not feel that he had to purchase the life insurance policy from Yezzi but in fact did so merely because Yezzi had helped him on a prior occasion in obtaining more working time. Based upon the facts of record and for the reasons noted above, we find no violation as to the sale of insurance to Sopko. Turning to the sale of insurance to Lawrence Zon, Zon is a full time laborer with the CTWA and hence a member of the union with the accompanying various benefits and job security. Yezzi approached Zon regarding the purchase of life insurance when Zon was a CTWA employee. Zon was contacted during the CTWA working hours and went to Yezzi's office. Yezzi told Zon that he would work up an insurance plan for Zon and his wife and indicated that the insurance would be approximately $50 a month. After Zon responded that he could not afford insurance, Yezzi inquired as to Zon's pay rate. It was made clear that a raise was possible and through a raise Zon could afford insurance. Subsequently Zon received a dollar per hour raise about a month later. Zon never purchased insurance from Yezzi. In reviewing the evidence or established facts in a case, an administrative agency may adopt inferences of facts. Simon v. Fine, 167 Pa. Super 386, 74 A.2d 674 (1950). In reviewing all of the evidence and facts in this record, we find as a matter of fact (Fact Find 29c) that as to Zon, Yezzi offered to obtain a raise for Zon in exchange for Zon purchasing insurance from Yezzi. Once again, as in the case of Eshbaugh, the facts and evidence in their entirety reflect that such an understanding existed. Zon was brought, during CTWA working hours, to Yezzi, the Chairman of the Board, at his insurance office. When Yezzi solicited insurance from Zon who responded that he could not afford insurance, Yezzi thereupon inquired as to Zon's wages as a CTWA employee, and advised that a raise could be obtained. It is patently clear and obvious from our review of the record that such an understanding did exist in this case and we so find. (Fact Finding 29c(7)). In applying the provisions of Section 3(a) and 3(b) of Act 170 of 1978, we do not find a violation of Section 3(a) in that although we believe that there was a use of public office on the part of Yezzi, he did not receive the financial gain as to his dealings with Zon since Zon did not purchase the insurance. Hence the requisite element of a financial gain is absent and we therefore find no violation of Section 3(a) of Act 170 of 1978. However, we do find a violation of Section 3(b) of Act 170 of 1978 because, just as in the case of Eshbaugh, Yezzi offered to obtain a raise for Zon based upon the understanding that Zon would buy insurance from Yezzi. We find the testimony of Zon to be both compelling and credible. However, Yezzi's counter testimony, that Zon came to Yezzi's office to ask for a raise because he needed more money and at the same time expressed an interest in purchasing insurance strains the bounds of credulity. It is simply nonsensical to assert that an employee would approach the Joseph D. Yezzi Page 54 chairman of a municipal authority for a raise because he was in financial straits and at the same time inquire about insurance coverage. In this regard, we note the history of Yezzi's employment with American General and his problem of failing to meet minimum sales quotas to sustain employment. We do not find Yezzi's testimony that there was no understanding by him concerning the Zon raise and Zon purchasing insurance to be credible and as such we totally discount such testimony. Although there was testimony by other Board members that Zon did approach the CTWA board at a meeting and request a dollar an hour raise in light of the fact that he was picking up the duties of another employee who had certain personal problems, we note that Yezzi directed him to go to the Board meeting to request the dollar raise when Yezzi was discussing insurance with Zon at his office. Zon in fact did go to the Board and received the raise. Therefore, we view the testimony of the other Board members as being consistent with Yezzi's direction to Zon that Yezzi would get the dollar raise for Zon in return for Zon's purchasing the insurance from Yezzi. As to Donald Haldeman, he was a part time laborer with the CTWA prior to his termination. While Haldeman was employed as a part time employee, Yezzi and a representative from American General came unannounced to Haldeman's house. Haldeman's spouse let Yezzi and the company representative enter at which time Yezzi requested that Mrs. Haldeman obtain her insurance policies for Yezzi's review. Mrs. Haldeman indicated that she did not have the policies available at which time Yezzi left. About the same time, Haldeman was told by the CTWA manager, Ken Sisk, that Yezzi wanted to talk to him and that Haldeman should get in contact with him (Yezzi). At the end of one work day at the CTWA, someone asked Haldeman if he was going to buy Yezzi's insurance. Haldeman made several attempts to contact Yezzi but did not actually talk to him until several days later. During the conversation Yezzi told Haldeman that "...we take care of those who take care us." Although there was no specific reference to insurance in Yezzi's remarks, Haldeman understood the statement as relating to insurance. Haldeman then responded to Yezzi that he (Haldeman) assumed that he was "done" (terminated) to which Yezzi agreed. Neither Haldeman nor his wife purchased an insurance policy from Yezzi. Applying the provisions of Section 3(a) and 3(b) of Act 170 of 1978, we find no violation of either Section. Although we believe there was a use of public office on the part of Yezzi, the requisite financial gain is absent in that the Haldeman's did not purchase insurance and on that basis we find no violation of Section 3(a). As to Section 3(b), we find no violation in that the record does not establish the requisite understanding and on that basis we find no 3(b) violation as to the insurance discussions with the Haldeman's. The last individual who was sold insurance by Yezzi is James Lasky who was employed as a laborer by the CTWA. The record reflects that Lasky returned to Pennsylvania in May of 1989 from Arizona where Joseph D. Yezzi Page 55 there was a lack of work. On May 22, 1989, Lasky immediately began employment with the CTWA. Although Lasky testified that he could not afford insurance when he returned, he did purchase insurance from Yezzi around the time he became employed by the CTWA. Lasky shortly thereafter let the policy lapse but stated that he did so because he could no longer live with his in -laws and hence having to move and pay rent made insurance unaffordable. Around the same time, Lasky became a member of the union. Finally, we must note that Lasky's father -in- law was on the CTWA board when Lasky was hired. Based upon the above, we do not find violations of either Sections 3(a) or 3(b) of Act 170 of 1978 as to Yezzi's conduct involving Lasky. We do find difficulty with Lasky's testimony as to his purchase of insurance from Yezzi shortly after his return to Pennsylvania from Arizona where he had no work and when he had no job lined up in Pennsylvania according to his testimony. In this regard, we question why Lasky under those financial circumstances would seek insurance and receive gainful employment. However, the record lacks the requisite evidence of a use of public office by Yezzi and the existence of an understanding and therefore on that basis we find no violations of Section 3(a) or 3(b) of Act 170 of 1978 as to Yezzi's conduct involving Lasky. As part of the above analysis and finding, we also note as to the violations for Yezzi's conduct involving Zon and Eshbaugh, that Yezzi was both terminated in 1980 and 1990 for failure to meet minimum production standards by his insurance company employer, American General. We also note that Yezzi received letters dated March 6, 1990 and June 25, 1990 advising that his performance was below minimum standards (Fact finding 58). It is clear that Yezzi was motivated to use public office to obtain financial gain through the mechanism of selling or attempting to sell policies to Eshbaugh and Zon. Turning to the matter of the Section 4(a) allegation under Act 170 of 1978 regarding the failure to file FIS's for the 1984 through 1987 calendar years, Yezzi originally testified that he filed the forms late after he went to a water convention in Hershey and heard a speaker of this Commission concerning the filing requirements. Yezzi stated that he then filed the forms approximately a week later and admitted that he inserted incorrect dates on the forms when he filed them. After being made aware that the CTWA minutes in April '86 reflect commentary about the notice from this Commission that the board members had to file, Yezzi then changed his testimony and admitted that he knew he had to file the FIS's and failed to do so even prior to the time he went to the conference in Hershey. In fact, the incorrect dates Yezzi chose to insert were March or April dates because he knew the filings had to be done by May 1. Thus, by his own admission Yezzi establishes his violation of Section 4(a) of Act 170 of 1978 for failing to timely file FIS's for the 1984 through 1987 calendar years. We find the circumstances of the violations particularly blatant given Yezzi's own testimony, the changes in his testimony, and lastly and most importantly Yezzi's admission that he knew he had to file but nevertheless failed to do so. Joseph D. Yezzi Page 56 At this juncture, it is necessary to comment upon Yezzi's lack of credibility. In this regard, we note the above tale by Yezzi, ostensibly proferred to explain his failure to timely file FIS's, when in fact he knew all along of the FIS filing requirement but failed to observe it. We likewise note Yezzi's testimony that he would not put false information on insurance applications which he recanted when he admitted that he falsified certifications on insurance applications. (Fact Finding 41f(2)(f)). We need not recount Yezzi's testimony as to the Eshbaugh and Zon insurance solicitation set forth above but must make note of Yezzi's spurious testimony as to his purported lack of knowledge or limited involvement as to the cancer and accident/ indemnity policies discussed below. In short, in our view of the record, we find that Yezzi has no credibility. We now must turn to the final allegation as to whether Yezzi violated Section 3(a) of Act 9 of 1989 regarding the sale of cancer and accident /indemnity policies to the CTWA. Factually, after an employee of the Authority, Anthony Fadool, contracted cancer, various members of the Board believed that the Authority should provide insurance to its employees, and Board member and Secretary Patrick Brizzi was directed to look into the matter of cancer insurance. Brizzi indicated that he did no comparisons or independent research to compare rates for cancer insurance and chose American General, Yezzi's company, because it was local (Fact finding 33). Brizzi however did not inquire as to accident indemnity insurance and had no recollection of Board action as to how accident dismemberment insurance was also acquired from American General in addition to the cancer insurance. In accord with the above is the testimony of Board members Panetta, Onderick and Cercone, none of whom had knowledge or recollection as to how the accident /dismemberment insurance was acquired by the Authority. In fact, Board member Onderick, after he learned that the Board already had accident indemnity insurance with Travelers, questioned the duplicate coverage with American General. As to the actual acquisition of both the cancer and indemnity policies by the Authority, the record is devoid of any evidence to show that the CTWA Board took action to contract for the insurance. There is also a lack of testimony from the Board members as to how and for what reason the Authority acquired the accident indemnity policies from American General. Henry A. DeLouis was the insurance manager for the Beaver Valley district of American General and was the supervisor for Yezzi. Although DeLouis states that a CTWA Board member contacted him regarding cancer insurance and that he filled out the cancer insurance applications as to some policies but as to others had someone (Yezzi) in the office complete the policies, Delouis's testimony is deficient Joseph D. Yezzi Page 57 as to the circumstances of why accident indemnity policies were issued. In this regard DeLouis admitted he never appeared at a CTWA Board meeting or made any presentation to the Board about insurance. It is clear as to all of these cancer and accident indemnity policies of American General that Yezzi's service number was inserted in the production credit box of the policies so that Yezzi did in fact receive the commissions from these policies. Yezzi testified that he completed certain policies at the direction of DeLouis and further testified that DeLouis assured him that he would not be assigned the credit even though in actuality he was assigned the credit and did in fact receive it. Yezzi also states that he did not read his weekly policy register statement which reflected that Yezzi was receiving commissions from the sale of the cancer and accident /indemnity policies to the CTWA. Yezzi also admitted that he knew from the amount of his paycheck whether that corresponded to the amount of insurance business he was producing. The minutes of the CTWA board reflect that on August 15, 1989 Yezzi abstained as to a payment to American General for insurance policy premiums. However, the November 21, 1989 minutes reflect an approval of the premium payments for American General Insurance where Yezzi did not abstain on the affirmative vote to pay those premiums. In addition, Yezzi signed checks of the Authority for payment of the premiums to American General and on at least two occasions (one which Yezzi admits) endorsed the checks for deposit into the American General account. Under the above facts and circumstances, we must determine whether Yezzi violated Section 3(a) of Act 9 of 1989 quoted above regarding the purchase of the cancer and accident /indemnity policies from American General to the CTWA. Section 3(a) quoted above provides that no public official /employee shall engage in conduct that constitutes a conflict of interest. The term "conflict" is defined under the Ethics Law as follows: Section 2. 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. "Conflict" or "conflict of interest" does not include an action having a de minimis economic impact or which affects to the same degree a class Joseph D. Yezzi Page 58 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 or his immediate family or a business with which he or a member of his immediate family is associated. 65 P.S. S402. As to the sale of the cancer and accident indemnity policies to the CTWA, it is clear, even by Yezzi's own admission, that he received commissions on the sale of that insurance. Hence there is no question that Yezzi received a private pecuniary benefit in this case. The pivotal remaining question is whether there was a use of authority of office on the part of Yezzi to obtain that private pecuniary benefit. In this case, there is no question that Yezzi had extensive involvement with the cancer and accident /indemnity policies in terms of completing certain applications. However, our focus must be limited as to what Yezzi did as CTWA Chairman relative to any use of authority of office as to those policies. In particular, the Authority policies were purchased without formal action taken by the CTWA Board. (Fact Finding 60(e)). The minutes merely reflect Yezzi in one instance voting on a routine, uncontested list of bills including one from American General while in another instance Yezzi abstained. As noted above, there was a great deal of involvement by Yezzi as to the Authority policies in his capacity as a sales agent. However, we cannot find that there is clear and convincing evidence that Yezzi, as the Chairman of CTWA and in that capacity, used the authority of office to obtain a private pecuniary benefit for himself with regard to these particular policies. On that basis we are constrained to find no violation of Section 3(a) of Act 9 of 1989 as to the allegation concerning the sale of the cancer and accident /indemnity insurance to the CTWA. As to the violations of Act 170 of 1978 regarding Kevin Eshbaugh, Section 9(c) of Act 170 of 1978 provides: Section 9. Penalties (c) Any person who obtains financial gain from violating any provision of this act, in addition to any other penalty provided by law, shall pay a sum of money equal to three times the amount of the financial gain resulting from such violation into the State Treasury or the treasury of the political subdivision. Treble damages shall not be assessed against a person who acted in good faith reliance on the advice of legal counsel. 65 P.S. 5409 (c). Joseph D. Yezzi Page 59 As to the policies sold to Eshbaugh by Yezzi, Yezzi received a gain of $359.29 (Fact finding 42). A treble penalty in this case is appropriate given the egregious nature of Yezzi's conduct. Therefore we impose a treble penalty in the amount of $1077.87 payable to the State Treasury of the Commonwealth of Pennsylvania. Accordingly Yezzi is directed within thirty days of the date of this order to forward a check or payment in full of the treble penalty in the above amount to this Commission. Failure to comply with the above will result in the institution of an enforcement action by this Commission. IV. CONCLUSIONS OF LAW: 1. Joseph D. Yezzi as Chairman of the Center Township Water Authority is a public official subject to the provisions of Act 170 of 1978 and Act 9 of 1989. 2. Yezzi violated Sections 3(a) and 3(b) of Act 170 of 1978 when he used public office to obtain a financial gain for himself and when he offered to sell CTWA employee Kevin Eshbaugh insurance based on the understanding that he would obtain a raise for Eshbaugh to cover the cost of the insurance. 3. Yezzi violated Section 3(b), but not Section 3(a), of Act 170 of 1978 when he offered to obtain a dollar per hour raise for CTWA employee Lawrence Zon based on the understanding that Zon would purchase insurance from Yezzi. 4. Yezzi did not violate either Section 3(a) or 3(b) of Act 170 of 1978 as to the sale of insurance to CTWA employee Joseph Sopko after Sopko requested and received additional work time from Yezzi and subsequently purchased insurance from Yezzi approximately one year later of his own volition. 5. Yezzi did not violate either Section 3(a) or 3(b) of Act 170 of 1978 regarding the purchase of insurance from him by CTWA employee James Lasky. 6. Yezzi did not violate Section 3(a) or 3(b) of Act 170 of 1978 regarding his attempt to sell insurance to Donald Haldeman who did not purchase insurance. 7. Yezzi violated Section 4(a) of Act 170 of 1978 when he failed to file Financial Interest Statements for the calendar years 1984 through 1987. 8. Yezzi did not violate Section 3(a) of Act 9 of 1989 regarding the sale of the cancer and accident /disability insurance policy to the CTWA in that there is not clear and convincing proof that Yezzi used the authority of office to obtain a private pecuniary benefit for himself. In Re: Joseph Yezzi . File Docket: 90- 018 -C2 Date Decided: February 20, 1992 Date Mailed: February 27, 1992 ORDER No. 825 1. Joseph D. Yezzi as Chairman of the Center Township Water authority violated Sections 3(a) and 3(b) of Act 170 of 1978 when he used public office to obtain a financial gain for himself and when he offered to sell CTWA employee Kevin Eshbaugh insurance based on the understanding that he would obtain a raise for Eshbaugh to cover the cost of the insurance. 2. Yezzi violated Section 3(b), but not Section 3(a), of Act 170 of 1978 when he offered to obtain a dollar per hour raise for CTWA employee Lawrence Zon based on the understanding that Zon would purchase insurance from Yezzi. 3. Yezzi did not violate either Section 3(a) or 3(b) of Act 170 of 1978 as to the sale of insurance to CTWA employee Joseph Sopko after Sopko requested and received additional work time from Yezzi and subsequently purchased insurance from Yezzi approximately one year later of his own volition. 4. Yezzi did not violate either Section 3(a) or 3(b) of Act 170 of 1978 regarding the purchase of insurance from him by CTWA employee James Lasky. 5. Yezzi did not violate Section 3(a) or 3(b) of Act 170 of 1978 regarding his attempt to sell insurance to Donald Haldeman who did not purchase the insurance and was subsequently terminated in his CTWA employment. 6. Yezzi violated Section 4(a) of Act 170 of 1978 when he failed to file Financial Interest Statements for the calendar years 1984 through 1987. 7. Yezzi did not violate Section 3(a) of Act 9 of 1989 regarding the sale of the cancer and accident /disabiilty insurance policy to the CTWA in that there is not clear and convincing proof that Yezzi used the authority of office to obtain a private pecuniary benefit for himself. 8. The financial gain received by Yezzi as to the violation referenced in Paragraph 1 was $359.29. 9. A treble penalty in the amount of $1077.87 is imposed against Yezzi as to the financial gain referenced in Paragraph 8. 10. Yezzi is directed within 30 days of the date of the issuance of the Order to forward a check or payment in full of the above treble penalty to the Commission in the amount of $1077.87 payable to the order of the State Treasury of the Commonwealth of Pennsylvania. 11. Failure to comply with the provisions of Paragraph 10 will result in a directive by the Commission to initiate an Order Enforcement Action. BY THE COMMISSION, 0 gY, VICE CHAIR Chair Dennis C. Harrington did not participate in this matter because he acted as single hearing officer and recused himself pursuant to 51 Pa. Code S2.34(d). Commissioner Roy W. Wilt dissents as to the finding of no violation of Section 3(a) of Act 9 of 1989 regarding the sale of the cancer and accident /disability insurance policies to the CTWA.