Loading...
HomeMy WebLinkAbout964 CoccariSTATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 In re: Barbara Coccari File Docket: 92- 031 -C2 Date Decided: 02/23/95 Date Mailed: 03/10/95 Before: Daneen E. Reese, Chair Roy W. Wilt Austin M. Lee Allan M. Kluger John R. Showers Rev. Joseph G. Quinn Boyd E. Wolff The Investigative Division of 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 52.38 and /or 51 Pa. Code §21.29(b). 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. 5408(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 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). Coccari, 92- 031 -C2 Page 2 I. ALLEGATION: That, Barbara Coccari, violated the following sections of the Public Officials and Employees Ethics Law (Act 9 of 1989) , when she directed purchases for the food bank from a company she operates and subsequently authorized payment to that company; when she transferred $50,000 from a food bank account to her private consulting account; and, when she authorized payments from authority accounts to herself: Section 3(a) of Act 9 of 1989 provides: Section 3. Restricted Activities (a) No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 P.S. §403(a). (c) No public official, public employee or nominee or candidate for public office shall solicit or accept, anything of monetary value, including a gift, loan, political contribution, reward, or promise of future employment based on any understanding of that public official, public employee or nominee that the vote, official action, or judgment of the public official or public employee or nominee or candidate for public office would be influenced thereby. 65 P.S. §403(c). That Barbara Coccari, in her position with the Greene County Food Bank, violated the below cited provisions of the Public Official and Employee Ethics Law, Act 170 of 1978 as amended by Act 9 of 1989 and Act 170 of 1978 when she used her position to transfer funds from Food Bank accounts to bank accounts in her name or the name of her private business enterprise; when she used funds from the Food Bank to purchase certificates of deposit in her name or the name of her private business enterprise; when she deposited funds belonging to the Greene County Food Bank into her personal bank accounts or the accounts of her private business enterprise, and when she used Greene County Food Bank funds for her personal benefit or the benefit of her private business enterprise. Section 3. Restricted Activities (a) No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 P.S. §403(a). Coccari, 92- 031 -C2 Page 3 Act 9 -1989 II. FINDINGS: A. PLEADINGS: 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. §402. Act 170 -1978 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. 65 P.S. §403(a). Section 2. Definitions "Immediate family." A parent, spouse, child, brother or sister. 65 P.S. §402. 1. Barbara Coccari served as the Program Administrator/ Coordinator of the Greene County Community Food Bank. a. Barbara Coccari also uses her birth name of Barbara Mooney. Coccari, 92- 031 -C2 Page 4 b. Coccari served through February, 1992. 2. In this position, Coccari was responsible for oversight and executive decision - making of the day -to -day operations of the Greene County Community Food Bank including: a. The hiring of staff. b. The procurement of goods and services. c. Operational control of all Greene County Community Food Bank funds. 3. The Greene County Community Food Bank was originated in 1980 as a community effort. 4. Barbara Coccari served as secretary of the Food Bank board at in 1985. a. The By -laws called for the Greene County Community Food Bank to consist of between 11 and 15 board members. 5. The county received state funding for the operation of the Greene County Community Food Bank through the execution of a °grantee certification" or grant agreement. a. Such an agreement was executed for each year that state funding was received. b. Pursuant to said agreements, the county must identify the county coordinating or lead county agency that will operate the food purchase program. c. The county commissioners designated the Greene County Community Food Bank as the county's lead agency in each year that funding was received through 1992. d. Two of the county commissioners were required to execute the agreements. 6. The County Commissioners were responsible for establishing a separate bank account /fiscal reporting system for state grants.In each year that the county entered into a grant agreement with the Commonwealth of Pennsylvania, the county was required to submit a plan for the utilization of the state funds. a. As part of that plan the commissioners must designate representatives to coordinate the execution of the plan. 7. Between the years 1984 and 1992, the Greene County Food Bank Coccari, 92- 031 -C2 Page 5 maintained the following bank accounts: Account Name a. Greene County Community Food Bk. b. Greene County Community Food Bk. c. Greene County Community Food Bk. (Turkey Fund) d. Greene County Community Food Bk. FEMA e. Greene County Bank D.C.A. f. Greene County Food Bank g. h. j. Greene County Community Food Bk. Greene County Food Community Bank Bank USDA Commodities Program i. Greene County Food Bank Bank Account No. Gallatin/ 70 -70212 Checking Integra First Federal 010858 Checking Savings & Loan Assoc. of Greene County First Federal 541723 Savings Savings & Loan Assoc. of Greene County First Federal 40954 Checking Savings & Loan Assoc. of Greene County Checking Savings First National 025451 Savings Bank /Bank One 1004417 Checking Food First Federal 10627480 Savings & Loan Assoc. of Greene County First Bank/ 025451 Huntington Bk. Community Bank 800059 Greene County Food Community Bank 10 -06404 Bank Payroll Account Savings Checking 8. Barbara Coccari /Mooney was the sole signature authority for the accounts identified in 7.c,e,f,g,h and i. 9. Barbara Coccari was one of two signature authorities for accounts identified in 7.a,b,d,j. 10. During the years 1988 through 1992, more than $500,000.00 was deposited into the Greene County Community Food Bank, bank accounts. 11. Funds deposited into the Greene County Community Food Bank accounts emanated from a number of sources including: Type Coccari, 92- 031 -C2 Page 6 The Commonwealth of Pennsylvania Greene County Greene County Human Services Shared maintenance fees (transportation costs assessed participating pantries at a cost /pound). Private donations 12. During the years from 1988 through and including 1992, the Greene County Community Food Bank received approximately $286,242 from the Commonwealth of Pennsylvania in funding and reimbursement. 13. During the years from 1988 through and including 1992, the Greene County Community Food Bank received approximately $93,924 from Greene County and the Greene County Department of Human Services. 14. The Greene County Community Food Bank received approximately $13,750 from the United Way. 15. The following findings relate to the Greene County Community Food Bank savings account (no. 800059) at the Community Bank of Carmichaels. (Finding 7(i)) 16. Records of the foregoing account (no. 800059) indicate that on September 27, 1991, Barbara Coccari withdrew $15,750 therefrom: a. On that same day Barbara Coccari utilized the funds to purchase a cashier's check no. 25827 in the amount of $15,000. b. The $15,000 cashier's check was made payable to Community Service Program. 17. Records of the Integra Bank (Gallatin) indicate that on September 27, 1991, the $15,000 cashier's check identified in finding 16(a) above was utilized to purchase a certificate of deposit no. 24600042326. a. The certificate of deposit was placed in the name of Community Service Program. b. Barbara Coccari was the sole signatory for this certificate of deposit. 18. On March 16, 1992, the $15,000 certificate of deposit was surrendered by Barbara Coccari to the Greene County Food Bank. 19. Records of the previously identified Greene County Food Bank savings account (no. 800059) at the Community Bank of Coccari, 92- 031 -C2 Page 7 Carmichaels indicate that on November 5, 1991, Barbara Coccari withdrew $5,750 therefrom: a. Coccari used $5,000 of that withdraw to purchase a cashier's check no. 25891, on November 6, 1991. b. The cashier's check was made payable to Community Services Program. 20. Records of the Community Service Program Bank account (no. 70- 74352) at the Integra (Gallatin) Bank confirm that on November 6, 1991, the $5,000 cashier's check was deposited therein. 21. On the same day, November 6, 1991, Barbara Coccari issued a check from the Community Service Program account no. 70 -74352 to John Howard Chrysler Plymouth Jeep Eagle, Inc. in the amount of $5,000. 22. Records of John Howard Chrysler Plymouth Jeep Eagle confirm that the $5,000 check was a partial payment for the purchase of a 1992 Dodge Shadow ES automobile. a. The price of the vehicle (less rebate) was $13,552 with taxes. b. Coccari was credited with a $4,964 trade in. c. The balance of the vehicle cost was paid with the $5,000 check from Community Service Program and a $3,588 check from the personal checking account of Dr. Barbara J. Mooney at the Community Bank of Carmichaels. d. No loan was used for the purchase of the automobile. 23. Records of the previously identified Greene County Food Bank account (no. 800059) at the Community Bank of Carmichaels indicate that on December 9, 1991, Barbara Coccari made a withdrawal therefrom in the amount of $2,500. a. On that same date, December 9, 1991, Coccari purchased a cashier's check no. 25957 in the amount of $2,500 payable to Citibank. b. The cashier's check has a notation thereon "Community Services Program." c. There is also a handwritten notation on the check "Gene Coccari" and "4128 -590- 826 - 934." 24. Records of the Citibank Corporation indicate that account no. 4128590826934 is a Mastercard credit account in the name of Coccari, 92- 031 -C2 Page 8 Gene M. Coccari. a. Gene M. Coccari is the son of Barbara Coccari's ex- husband. b. He resides in West Virginia. 25. Records of the Mastercard account 4128590826934 of Gene Coccari indicate the following: a. The credit limit was $3,000 in 1991. b. Throughout 1991, the balance owed was between $2,000 and $2,900. c. Minimum monthly payments between $60 -$70 were made but purchases were continually made and monthly interest in excess of $150 accrued. d. Payments were not made in March or July, 1991, which resulted in the suspension of card privileges. (In August a payment was made and privileges restored). e. In November 1991, an outstanding balance of $2,917.38 existed. f. The monthly statement for December, 1991, reflects a $2,500 payment credited to the account. g. Said payment was made through the cashier's check identified in finding 23(a) above. 26. None of the purchases made through the above referenced Mastercard account related to the Greene County Food Bank. 27. Barbara Coccari utilized $2,500 in Greene County Food Bank funds to pay the Mastercard charge account bill of her stepson. a. Barbara Coccari admits she utilized the funds to pay the Mastercard account of Gene Coccari, but denies that the funds were GCCFB funds and asserts that the funds were paid to her as compensation as part of an agreement between her and the GCCFB association. 28. Records of the previously identified Greene County Food Bank account (no. 800059) at the Community Bank of Carmichaels indicate that during the period from January, 1988, through December, 1991, Barbara Coccari withdrew $17,161.89 in cash therefrom. Coccari, 92- 031 -C2 Page 9 29. Records of the previously identified Greene County Bank account (no. 800059) at the Community Bank of Carmichaels indicate that on December 24, 1991, a withdrawal was made therefrom by Coccari in the amount of $4,707.89. a. This equalled all of the funds in the account which was thereafter closed. 30. Records of account no. 800059 indicate that on the same day of the foregoing withdrawal, $4,000 of the funds withdrawn were utilized to purchase a cashier's check (no. 25985). a. The cashier's check indicates "closing acct. #800059." b. The cashier's check was made payable to the "Greene County Food Bank." c. The back of the cancelled cashier's check indicates "Greene County Food Bank deposit only 70- 74352." 31. Account no. 70 -74352 identified on the back of the cancelled cashier's check was not a Greene County Food Bank account but was the bank account at the Integra Bank for Community Service Program, Coccari's personal business account. a. Records of the Community Service Program account at the Integra Bank, account no. 70 -74352 confirm that on December 31, 1991, the $4,000 cashier's check made payable to the Food Bank was deposited into Coccari's personal business account. 32. Records of the Community Service Program bank account (no. 70- 74352) at the Integra (Gallatin) Bank indicate that checks made payable to the Greene County Food Bank by various groups or individuals were deposited therein by Barbara Coccari as follows: Deposit Date 07/18/91 07/18/91 07/18/91 07/18/91 07/18/91 G.A.R.C. Source Jefferson Community Food Bank $ 28.85 United Methodist Church Food Bank $ 158.01 Valley Chapel Methodist Church $ 79.78 West Union Church Amount Comment $ 126.18 Coccari, 92- 031 -C2 Page 10 Food Bank $ 57.33 08/02/91 G.A.R.C. Rangers $ 121.24 08/02/91 West Union Church Food Bank $ 57.76 08/02/91 United Methodist Church Food Bank $ 78.99 08/02/91 Greene Valley Presbyterian Church $ 32.50 08/02/91 Greene Valley Presbyterian Church $ 2.70 08/02/91 Greene Valley Presbyterian Church $ 46.84 08/02/91 Charles M. & Maria J. Walker $ 41.44 08/02/91 Greene County $ 13.95 08/07/91 Valley Chapel Methodist Church $ 68.61 08/07/91 Bates Fork Baptist Church $ 18.24 08/07/91 CBM Ministries Inc. $ 36.55 08/07/91 AMI Inc. of Washington Greene Counties $ 15.04 09/20/91 Greene County $ 18.00 09/20/91 American Legion Post 330 $ 1,000.00 09/20/91 Jefferson Community Food Bank $ 40.00 09/20/91 Charles J. & Karen Brashear $ 45.00 12/04/91 AFSCME Local 2249 $ 50.00 12/04/91 Machine Tool Service $ 50.00 12/04/91 Kenneth & Coccari, 92- 031 -C2 Page 11 Frances Tompkins $ 50.00 12/04/91 Alltel Corp $ 100.00 12/04/91 Knights of Columbus Council 3569 $ 500.00 12/04/91 First Presbyterian Church of Waynesburg $ 200.00 12/04/91 Commonwealth of PA $ 1,649.06 12/31/91 Louis F. Leathers $ 20.00 01/17/92 First Presbyterian Church $ 100.00 01/17/92 First Presbyterian Church $ 268.00 01/17/92 Commonwealth of PA $ 1,074.32 TOTAL $ 6,148.39 Barbara Coccari denies that she deposited any of the above checks other than those deposits indicated by n * * " a. * Checks bear stamp on back "for deposit only Gallatin National Bank Greene County Food Bank 70- 70212." b. ** Checks bear stamp on back "for deposit only Greene County Food DCA Community Food Bank 3010027480." c. * ** Checks bear hand written notation on back "Greene County Community Food Bank 70 -74352 for deposit only." 33. Although all of the checks identified in the foregoing finding were made payable to the Greene County Community Food Bank, the funds were deposited into the personal business account of Barbara Coccari. a. Coccari denies that the checks were deposited into a personal business account. 34. Although the account numbers stamped on the back of checks identified in finding 32(a -b) were official Food Bank accounts, the funds were not deposited into said accounts. a. Coccari admits to the above but denies that the error involved her. Coccari, 92- 031 -C2 Page 12 35. Although the back of the checks identified in finding 32(c) indicated that the funds were to be paid to the Food Bank, the account number written thereon was that of Community Service Program, Coccari's personal business account. a. Coccari admits the above but denies that the Community Service Program is her personal business account. 36. All of the sources of funds identified in finding 32 above specifically made payment to the Greene County Food Bank and intended the funds to be utilized for Food Bank purposes. a. None of the sources of these payments intended the funds to go to Barbara Coccari personally or to her private business enterprises. b. Some of the payments were donations to the Food Bank. c. The payments from the Commonwealth of Pennsylvania (12/04/91 and 1/17/92) were reimbursements to the Food Bank for incurred expenses. 1. In February, 1992, Coccari issued a check to the Greene County Community Food Bank (USDA) from Community Services Program in the amount of $1,649.06, the amount of the 12/04/91 check. 37. All of the checks identified in finding 32 were endorsed in a manner that would give the appearance that said checks were deposited into an official Greene County Food Bank account when in reality they were deposited into Coccari's personal business account. a. Coccari admits to the above but denies that the checks were deposited into her personal business account. 38. $1,649.06 of the funds identified in finding 32 was repaid to the Food Bank in 1992. 39. The checks identified in finding 32 above payable to the Food Bank but deposited into Barbara Coccari's account were not part of Coccari's authorized compensation. 40. Records of the Integra Bank indicate that the following checks were deposited into the Community Service Program bank account (No. 74352): Date Pavor Payee Amount 02/02/92 Patricia Johnson St. Anns Roman $ 25.00 Jane Zumpetta Catholic Church Coccari, 92- 031 -C2 Page 13 12/16/91 Raymond & Glenna Strawn Food Bank Washington County $ 50.00 Food Bank 41. In relation to the above referenced checks the payment of $25.00 was a donation to Saint Anns Church Food Bank. a. Said check was not intended by the donor to be disbursed to Barbara Coccari's business account. b. Said check was intended to be a donation to the food bank. 42. In relation to the above referenced checks to payment of $50.00 was a donation to either the Washington or Greene County Food Bank. a. Said check was donated in memory of Camilla Stockdale and Morris Strawn. b. Said check was not intended by the donor to be disbursed to Barbara Coccari's personal business account. c. Said check was intended to be a donation to the food bank. 43. The following findings relate to the Greene County Food Bank account, no. 01025451, at the First Bank (Bank One of the Huntington National Bank), (formerly at First National Bank and Trust Company) . (see finding 7 (f -g) . 44. The signatory authorities for the account were Barbara Coccari or Patricia D. Peck. a. Patricia D. Peck was an employee of the Greene County Food Bank. 45. Records of the foregoing account, no. 01025451 indicate that on March 15, 1991, a withdrawal was made from the account by Barbara Coccari in the amount of $50,000. 46. On the same day as the $50,000 withdraw, a certificate of deposit (no. 003302) was purchased by Barbara Coccari in the amount of $50,000 at the First Bank N.A. a. The certificate was in the name of Greene County Community Services. b. The sole signatory for the certificate of deposit account was Barbara Coccari. Coccari, 92- 031 -C2 Page 14 c. The term of the certificate of deposit was for six months with a maturity date of September 13, 1991. 47. On September 13, 1991, the maturity date of the $50,000 certificate of deposit, Barbara Coccari cashed in the certificate of deposit and utilized the funds as follows: a. A certificate of deposit (no. 003449) in the amount of $15,000 was purchased at the First Bank N.A. b. A certificate of deposit (no. 003448) in the amount of $35,000 was purchased at the First Bank N.A. 48. Both of the certificates of deposits referenced in finding 47 above were purchased on September 13, 1991. a. Both certificates of deposit were purchased in the name of Greene County Community Services. b. The sole signatory for the certificates of deposit is Barbara Coccari. c. The terms of the certificates of deposit were for 36 months with a maturity date of September 13, 1994. 49. At the time of maturity the original certificate of deposit in the amount of $50,000 (Finding 46(c)) had earned $1,570.36 in interest. a. On September 23, 1991, the interest ($1,570.36) was deposited into the previously identified Greene County Food Bank account no. 01025451. b. On that same day, September 23, 1991, Barbara Coccari withdrew that amount $1,570.36 from the Greene County Food Bank account. c. The funds were then utilized to open up a new bank account at the First Bank N.A. (no. 720 - 001538) on September 24, 1991. d. The new account was in the name of Greene County Community Services. e. The sole signatory for the account is Barbara Coccari. 50. Neither Greene County nor the Greene County Food Bank operate an entity known as Greene County Community Services. 51. On March 2, 1992, based upon the filing of a petition by the office of the Greene County Controller in the County Court of Coccari, 92- 031 -C2 Page 15 Common Pleas, an order was issued to the First Bank N.A. (Huntington Bank) to freeze certificates of deposit nos. 003449 and 003448. a. On March 16, 1992, Barbara Coccari surrendered to the Greene County Food Bank certificates of deposit nos. 003449 and 003448 as well as bank account no. 720 00 1538. 52. Records of the previously identified bank account (no. 01025451) at First Bank indicate that on January 28, 1992, a withdraw was made therefrom by Barbara Coccari in the amount of $2,550.00. a. This withdrawal was made 53. The following findings relate account under the name Greene (account no. 010858) at the Association of Greene County. in cash. to the Greene County Food Bank County Food Assistance Program First Federal Savings & Loan (See finding 7(b)). 54. This account was a checking account and Barbara Coccari was one of the signatories for this account. 55. Records of the foregoing account (010858) indicate that three checks were issued to an entity known as the Warehouse as follows: Date Amount 03/15/91 $ 3,674.45 05/20/91 $ 1,365.00 06/13/91 $ 1,381.05 TOTAL $ 6,420.50 56. Barbara Coccari was one of two signatories on all three checks. 57. Records of the Union National Bank (Integra) indicate that all three checks referenced above were deposited into an account maintained there. a. That account no. 0740000835 was in the name of Barbara Mooney DBA, the Warehouse, P.O. Box 152, Washington, PA. b. The account was opened in November, 1990, and the sole signatory was Barbara Mooney. c. Barbara Mooney is the former name of Barbara Coccari. d. A sole proprietorship authorization form dated November 16, 1990, filed in relation to this account indicates Coccari, 92- 031 -C2 Page 16 that the warehouse is an unincorporated business owned entirely by Mooney. e. The only deposits into this account were the three checks noted above (Finding 55) and one additional check in the amount of $25.00 from the personal account of Dr. Barbara J. Mooney. 1. This check ($25.00) was dated November 26, 1990, and was used as the initial deposit to open the account. f. The deposited funds remained in the account until April, 1992. 58. Records on file with the Greene County Food Bank included three undated invoices for the purchase of food. a. The above invoice figures coincide with the checks issued to the warehouse. 59. No foods were purchased at the time the checks to the warehouse were issued. 60. On April 6, 1992, a withdrawal in the amount of $6,649.29 was made from the account by Barbara Mooney. This equaled the total funds in the account. 61. Records of the Union National Bank (Integra) indicate that the withdrawn funds $6,649.29 were used to purchase a cashier's check no. 234545 (Integra) in said amount. a. Said check was made payable to Save -A -Lot. 62. Representatives of Save -A -Lot confirmed that in May, 1992, Coccari used the Cashier's check for $6,649.29 plus a check in the amount of $576.50 from Community Service Program to purchase food for the Food Bank. a. This purchase was made more than a year after Coccari took the funds. 63. The Greene County Food Bank maintained a bank account titled "Greene County Food Bank USDA Commodities Program" at the Community Bank of Carmichaels (No. 10- 04417). (See Finding 7(h)). a. Barbara Coccari was the sole signature authority for this account. 64. Records of the Greene County Food Bank USDA Commodities Coccari, 92- 031 -C2 Page 17 Program account indicate the following checks issued to Community Service Program: Date Check Nimber Amount 01/04/88 522 $ 150.00 01/29/88 529 $ 200.00 02/16/88 541 $ 200.00 03/14/88 549 $ 200.00 04/14/88 562 $ 200.00 05/16/88 569 $ 200.00 06/09/88 575 $ 200.00 07/15/88 584 $ 250.00 08/26/88 599 $ 250.00 09/15/88 604 $ 250.00 02/01/89 633 $ 800.00 02/01/89 634 $ 200.00 02/15/89 638 $ 200.00 04/14/89 663 $ 200.00 05/15/89 676 $ 200.00 06/15/89 688 $ 200.00 07/13/89 694 $ 200.00 08/03/89 701 $ 200.00 08/30/89 712 $ 200.00 11/21/89 743 $ 200.00 11/21/89 744 $ 200.00 01/18/90 761 $ 200.00 02/15/90 768 $ 200.00 03/09/90 773 $ 200.00 04/20/90 783 $ 200.00 05/24/90 798 $ 200.00 06/13/90 803 $ 200.00 07/23/90 808 $ 200.00 08/24/90 816 $ 200.00 10/09/90 827 $ 200.00 10/26/90 835 $ 200.00 12/26/90 847 $ 200.00 01/15/91 849 $ 200.00 01/31/92 989 $ 150.00 65. All of the foregoing checks were signed by Barbara Coccari. 66. An internal ledger from the Greene County Community Food Bank indicates that most of the above referenced payments were for "occupancy ". 67. All of the foregoing checks were deposited into the Community Service Program bank account (No. 70- 74352) at the Integra (Gallatin) Bank 68. The total amount of funds disbursed by Coccari from the Greene County Food Bank USDA Commodities account was $7,650.00. Coccari, 92- 031 -C2 Page 18 69. The Greene County Food Bank maintained a bank account at the Gallatin (Integra) Bank (account no. 70- 70212). (See Finding 7 (a)) . a. Barbara Coccari had signature authority for this account. 70. Records of the Greene County Food Bank account at the Gallatin Bank indicate the following checks issued to Community Service Program: Date 12/15/87 01/11/88 01/29/88 02/11/88 04/14/88 05/13/88 06/09/88 07/15/88 08/26/88 09/15/88 02/01/89 02/11/89 02/13/89 03/15/89 04/14/89 05/15/89 06/15/89 07/13/89 08/03/89 08/30/89 10/12/89 12/12/89 01/18/90 02/15/90 03/19/90 04/20/90 05/24/90 06/13/90 07/23/90 08/27/90 10/26/90 09/24/90 01/15/91 02/18/91 01/31/92 02/13/92 Check Number 251 253 256 262 268 270 277 279 282 284 295 296 298 252 256 260 264 266 268 274 128 133 137 138 141 147 148 301 305 308 312 322 325 366 372 Amount $ 125.00 $ 250.00 $ 250.00 $ 250.00 $ 250.00 $ 250.00 $ 250.00 $ 250.00 $ 250.00 $ 250.00 $ 600.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 400.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 200.00 $ 300.00 $ 150.00 71. All of the foregoing checks issued to Community Service Program were signed by Barbara Coccari and James Dunn, a member of the Food Bank Board of Directors. Coccari, 92- 031 -C2 Page 19 72. All of the foregoing checks were deposited into the Community Service Program Bank account (No. 70- 74352) at the Integra (Gallatin) Bank. 73. The total amount of funds disbursed by Coccari from the Greene County Food Bank account referenced in Finding 70 above was $8,225.00. 74. Barbara Coccari also issued a check in the amount of $340 (no. 167) from the Greene County Community Food Bank DCA Account (no. 10627480) to Community Service Program on August 30, 1991. a. This check indicates that it was payment for six months utility costs. 75. Records of the Greene County Community Food Bank D.C.A. account maintained at the First Federal Savings and Loan Association of Greene County (No. 27480) indicate that two checks were written to Barbara Kirby as follows: Date Check Number Amount 08/08/91 162 $ 220.00 08/23/91 163 $ 220.00 76. Barbara Kirby is the wife of James Kirby who was a Greene County Food Bank employee at that time. 77. Barbara Coccari had sole signature authority for the D.C.A. account referenced in Finding 74 above. a. Coccari signed both checks to Kirby. 78. The checks represented a loan from the Food Bank to Barbara Kirby. a. Barbara Coccari authorized this loan. 79. Records of the Community Service Program bank account at the Gallatin (Integra) Bank (account no. 70- 74352) indicate that the following check was deposited therein: Deposit Check Check Date Date Number Pavor Payee Amount 09/03/91 08/30/91 167 Barbara Kirby Community $ 440.00 Service Program 80. The above check was written on the account of James F. Kirby, Jr. and Barbara T. Kirby (No. 7057456) at the Integra (Gallatin) Bank. Coccari, 92- 031 -C2 Page 20 a. The check was signed by Barbara Kirby. b. The Notation in the memo section of the check indicated "loan repayment ". 81. Barbara Coccari used Greene County Food Bank funds in the amount of $440.00 to make a loan to Barbara Kirby. 82. From 1986 through November, 1990, the Greene County Community Food Bank paid for a Commercial General Liability insurance policy. a. The policy covered personal liability and injury to individuals as well as fire. (1) Coccari admits that the GCCFB average included general liability and special product liability but denies that the policy covered fire. b. The policy was in the name of Community Services of Greene County. 83. The building at 243 East High Street was owned by Coccari. 84. The insurance premium was $150 per year. 85. Records of several Greene County Community Food Bank accounts indicate a number of checks issued to a C.R. Ashe or Cooper Ashe. 86. C.R. Ashe was a name used by William Elwood, a friend of Barbara Coccari. a. Ashe /Elwood performed certain services for the Food Bank. 87. The following checks were made payable to C.R. or Cooper Ashe from the Greene County Community Food Bank U.S.D.A. Commodities Program No. 1004417 at the Community Bank of Carmichaels: CHECK DATE NUMBER PAYEE AMOUNT a. 03/09/89 (651) Cooper Ashe $ 9.54 NOTE: This check was issued by Barbara Coccari and co- endorsed by C.R. Ashe and Barbara Mooney. b. 07/14/89 (698) C.R. Ashe $ 55.50 NOTE: This check was issued by Barbara Coccari and co- endorsed by C.R. Ashe and Barbara Mooney. Coccari, 92- 031 -C2 Page 21 d. 03/27/91 The check was deposited into the personal account of Dr. Barbara J. Mooney (No. 12- 04103) at the Community Bank of Carmichaels. c. 11/21/89 (740) C.R. Ashe $ 65.00 NOTE: This check was issued by Barbara Coccari and endorsed by C.R. Ashe. The check was subsequently deposited into an account in the name of Moonwood Productions at the Community Bank of Carmichaels (No. 709204). This account was for a sole proprietorship for which Barbara J. Mooney had signature authority. 874 C.R. Ashe NOTE: This check is endorsed by Cooper Ashe and deposited into the bank account of Community Service Program (No. 7074352). The check was issued by Coccari. 89. The following checks were issued to Cooper and C.R. Ashe from the Greene County Community Food Bank payroll account (No. 10- 06404) : NOTE: This check was issued by Barbara Coccari and endorsed by C.R. Ashe and Barbara Mooney. NOTE: This check was issued by Barbara Coccari and co- endorsed by C.R. Ashe and Barbara Mooney. $ 70.00 NOTE: This check wa co- endorsed by C.R. Ashe and Patricia D. Peck. 88. The following checks were issued to C.R. or Cooper Ashe from the Greene County Community Food Bank D.C.A. account at the First Federal Savings & Loan Association of Greene County (No. 10027480). CHECK DATE NUMBER PAYEE AMOUNT a. 07/29/91 161 C.R. Ashe $ 200.00 b. 08/30/91 166 Cooper Ashe $ 150.00 CHECK DATE NUMBER PAYEE AMOUNT a. 10/31/88 265 C.R. Ashe $ 100.50 b. 11/30/88 273 C.R. Ashe $ 201.00 Coccari, 92- 031 -C2 Page 22 c. 03/16/89 NOTE: d. 03/31/89 NOTE: e. 04/28/89 NOTE: 313 C.R. Ashe This check was issued by Barbara Coccari and co- endorsed by C.R. Ashe and Barbara Mooney. 318 C.R. Ashe This check was issued by Barbara Coccari and co- endorsed by C.R. Ashe and Barbara Mooney. 332 C.R. Ashe $ 80.00 $ 88.00 This check was issued by Barbara Coccari and co- endorsed by C.R. Ashe and Barbara Mooney. 90. All of the checks issued to C.R. or Cooper Ashe were done so by Barbara Coccari. 91. Most of the checks issued to C.R. or Cooper Ashe were co- endorsed for cashing by Barbara Coccari using the name Barbara Mooney. 92. Some of the checks issued by Coccari and co- endorsed by her to C.R. or Cooper Ashe were deposited into personal bank accounts of Barbara Coccari /Mooney. a. Barbara Coccari asserts that the checks were deposited into her account after she cashed them for Ashe. 93. Several Greene County Food Bank checks were issued to an entity known as Moonwood Productions. a. Moonwood Productions maintained several bank accounts for which Barbara Coccari /Mooney had signature authority. b. Moonwood Productions was a business started by Barbara Coccari and several other individuals. 94. The following checks were written to Moonwood Productions from the Greene County Community Food Bank: a. CHECK NUMBER DATE ACCOUNT AMOUNT 286 09/15/88 70 -70212 $ 225.00 1. This check was co- signed by Barbara Coccari and Lance Dunn. The check was deposited into an account in the name of Moonwood Productions at the First Federal Savings & Loan Association of Greene County (No. 5- 41528). 2. The sole signator for this account was Barbara 70.00 Coccari, 92- 031 -C2 Page 23 Mooney. b. CHECK NUMBER DATE ACCOUNT AMOUNT 06/01/89 70 -70212 $ 45.00 1. This check was signed by Barbara Coccari and deposited into the above identified account of Moonwood Productions (No. 709204) at the Community Bank of Carmichaels. c. CHECK NUMBER DATE ACCOUNT AMOUNT 736 11/10/89 10 -04417 $ 50.00 1. This check was signed by Barbara Coccari and deposited into an account in the name of Moonwood Productions at the Community Bank of Carmichaels (No. 709204). 2. The sole signator for this account was Barbara Mooney. 95. Barbara Coccari had hired Moonwood Productions to paint the Food Bank truck and perform calligraphy services. a. Coccari did this in her position of Food Bank director. 96. A number of checks were issued from various Greene County Community Food Bank accounts directly to Barbara Coccari /Mooney as follows: a. CHECK NUMBER DATE ACCOUNT AMOUNT 617 11/10/88 10 -04417 $ 150.00 628 12/09/88 10 -04417 $ 24.00 1. These checks were issued by Barbara Coccari and deposited into the personal account of Dr. Barbara J. Mooney. The checks indicate travel expenses and reimbursement. b. CHECK NUMBER DATE ACCOUNT AMOUNT 735 11/15/89 10 -04417 $ 60.00 1. This check was issued by Barbara Coccari and made payable to Barbara Mooney. c. CHECK NUMBER DATE ACCOUNT AMOUNT 741 11/21/89 10 -04417 $ 60.00 1. This check was issued by Barbara Coccari and made payable to cash. The check is endorsed by Barbara Mooney. The check indicates "gas F.S. D Day ". Coccari, 92- 031 -C2 Page 24 d. CHECK NUMBER DATE ACCOUNT AMOUNT 155 05/31/91 100627480 $ 100.00 1. This checks was issued by Barbara Coccari to cash and deposited into the personal account of Dr. Barbara J. Mooney. e. CHECK NUMBER DATE ACCOUNT _ AMOUNT 191 12/18/91 100627480 $ 250.00 f. CHECK NUMBER DATE ACCOUNT AMOUNT 197 12/30/87 10 -06404 $ 787.80 g• 1. This check was issued by Barbara Coccari to cash and endorsed by Barbara Coccari. 1. This check was issued by James Dunn to Barbara Mooney. The check is endorsed by Barbara Mooney. CHECK NUMBER DATE ACCOUNT AMOUNT 253 08/31/88 10 -06404 $ 283.00 1. This check was issued by James Dunn payable to Barbara Mooney. The check is endorsed by Barbara Mooney and deposited into the account of Community Service Program. 97. The total amount of checks made payable to Barbara Coccari /Mooney as outlined above (Finding 96) equalled $1,714.80. 98. $1,714.80 in checks was issued from various Greene County Food Bank accounts to Barbara Coccari and /or Barbara Mooney. (see Findings 96 to 97). 99. Coccari makes the following arguments: a. The allegation fails to state a cause of action or basis for investigation under Act 170 of 1978 and /or Act 9 of 1989. b. Coccari is not a public official /employee under the Ethics Law. c. The investigation is barred by the statute of limitations. d. The Greene County Commissioners caused, contributed to, acquiesced in and condoned the actions of Coccari. e. Coccari rendered administrative duties to the Greene Coccari, 92- 031 -C2 Page 25 County Community Food Bank from 1980 to 1992 and did not receive compensation for such services. B. TESTIMONY AND EXHIBITS: 100. Cheryl Christopher is the custodian of records of the Corner Cupboard Food Bank (CCFB) which is the successor organization of the Greene County Community Food Bank (GCCFB). a. Investigative Division (ID) 31 is a job description for the GCCFB administrator. g. b. ID 27 is a financial report for the years 1986 mid 1991 from the records of the GCCFB. c. ID 25 is a letter from Coccari to Donald J. Hess United Way of Southwestern Pennsylvania donor section from the records of the GCCFB. d. A review of the minutes authorization by the contracts for Coccari (CSP) . e. A search of GCCFB records resulted in a finding of no executed contracts, agreements, no executed authorizations for payment as to compensation or contracts with Coccari or CSP. f. through of the option of the GCCFB do not reflect any board as to compensation or or Community Services Program (1) There was not any GCCFB savings account No. 80059 at Community Bank of Carmichaels. Christopher was hired by the Greater Pittsburgh Food Bank (GPFB) as the Acting Director of GCCFB. (1) GCCFB changed its name to CCFB. (2) The food bank was shut down for several months before Christopher stepped in. (3) Christopher renewed operations in August, 1992. (4) Monies previously held by GCCFB were frozen by the Court. The salary of Christopher was set by the board of GPFB as per a signed agreement. 101. Robert Caruso is the Deputy Executive Director and Director of Investigations of the State Ethics Commission. Coccari, 92- 031 -C2 Page 26 a. Investigations are started by the receipt of a signed, sworn complaint or by own motion of the Executive Director. b No member of the State Ethics Commission plays any role in determining whether an investigation is initiated. (1) No Commission member plays any role in an investigation. (2) No Commission member has any access to the investigative files. (3) No Commission member plays any part in drafting the investigative complaint. c. ID 5 is a redacted photocopy of the signed sworn complaint filed against Coccari. (1) The complaint was docketed on April 7, 1992. d. ID 1 is the notice of investigation to Coccari. (1) The notice was issued June 5, 1992 via certified mail. e. The investigation was not completed in 180 days and two 90 -day extensions were obtained. (1) The investigation was completed within the second 90 -day extension. f. ID 2 is an amended notice of investigation. (1) The amended notice includes investigating allegations against Coccari under both Act 170 of 1978 and Act 9 of 1989. g. ID 6 is a compilation of the 90 -day notice letters sent to Coccari. h. ID 3, 4 are letters outlining the various documents provided to Coccari's attorney. i. ID 12 includes a cashier's check withdrawn from the food bank account in 1991 and deposited in a Certificate of Deposit (CD) account in CSP. (1) CSP was Coccari's consulting service for activities that she independently performed. Coccari, 92- 031 -C2 Page 27 (2) Coccari admitted that the $5000.00 that went into the CSP bank account was used to purchase a vehicle as to CSP which was her personal entity. (3) The CSP account was acknowledged by Coccari as her personal business account. (4) The net effect of Coccari's action was to withdraw $15,000 from the food bank account and purchase a CD for CSP which was Coccari's personal account. ID 13 includes a photocopy of a cashier's check drawn on a food bank account payable to CSP for $5,000.00 deposited on November 7, 1991. (1) On November 8, 1991 a check in the amount of $5,000.00 was written from the account of CSP under the signature authority of Coccari. (a) The $5,000.00 was used in whole or part to purchase a vehicle from John Howard Chrysler Plymouth for Coccari's personal use. k. ID 14 entails the withdrawal of $2,500.00 from a GCCFB account for the purchase of a cashier's check in the amount of $2,500.00 which was used to make a payment on a Citibank Visa Card. (1) The Visa card was the credit card of Gene Coccari. (a) Gene Coccari is the son of Coccari's former husband. (2) The net effect of the above transaction was that Coccari took $2,500.00 from the GCCFB account to make a payment on the credit card balance of her former husband's son. 1. ID 15 entails the withdrawal by Coccari of $4,000.00 from the GCCFB account 80059 on December 24, 1991 and deposited into her CSP account 74352. (1) The GCCFB account was closed out by the withdrawal of $4,707.89. (2) The $4,000.00 withdrawal was used to purchase a cashier's check payable to GCCFB. (a) The check was marked "For Deposit Only." (b) The check was deposited to an account number Coccari,, 92- 031 -C2 Page 28 7074352 which is CSP. (3) Nowhere on the check was the phrase CSP used. (a) Only the account number would indicate that it was deposited into the CSP account. m. Two withdrawals made by Coccari from GCCFB, cash of $750.00 as to one withdrawal and $707.00 plus change as to the other, could not be accounted for by Coccari. n. ID 16 includes deposits to the CSP account 74352. (1) Deposits include checks payable to GCCFB. (a) The deposits were not made to the GCCFB account. (b) Coccari herself deposited certain of these checks. (2) The net effect of the transactions was that GCCFB checks were deposited into CSP which is the account of Coccari. (3) The endorsements on the back of the checks state a deposit to GCCFB. o. ID 17 entails a document as to a $50,000 withdrawal by Coccari from the GCCFB account 901 - 02541031591. (1) Two CD's were subsequently purchased by Coccari in the amounts of $15,000.00 and $35,000.00. (a) The CD's were purchased in the name of Greene County Community Service (GCCS) and signed by Coccari. (b) The tax ID numbers for the two CD's were CSP. (c) Coccari admitted that the ID number for the two CD's was the CSP. (2) Interest of $1,570.36 was earned in the CD. (a) The interest was deposited into GCCS account over which Coccari had signature authority. ID 18 includes documentation as to Coccari for a bank account named "The Warehouse." p. Coccari, 92- 031 -C2 Page 29 q. (1) The sole proprietorship authorization lists Coccari as the owner of the account. (2) The social security number of Coccari is listed as the taxpayer ID number. (3) Three checks from the Greene County Food Assistance Program (GCFAP) were deposited into the Warehouse account. (a) A check dated April 25, 1991 in the amount of $3,674.45 was deposited. (b) Two checks dated May 20, 1991 and June 13, 1991 totalling $112,746.05 were deposited. (c) The GCFAP is a GCCFB account. (d) The funds were subsequently deposited into the Warehouse account. (e) Invoices exist from the Warehouse to the GCCFB for various food items which correspond to the checks. (1) The items in the invoices were never in fact purchased or received by GCCFB. (2) Coccari admitted that the items were not delivered to GCCFB. (f) The funds remained in the Warehouse account from the time of deposit until early in 1992. ID 19 includes a monthly account statement for DCA- GCCFB- CD -DCA account, checks payable to Barbara Kirby, deposits to CSP and a CSP bank statement. (1) Two checks each in an amount of $220.00 were made payable to Barbara Kirby from the Food Bank DCA account in August, 1991. (2) On September 3, 1991 a check from James F. and Barbara T. Kirby in the amount of $440.00 was made payable to CSP. (a) The memo portion of the check stated "loan repayment." (b) The CSP account number was 7074352. Coccari, 92- 031 -C2 Page 30 (c) Coccari admitted telling Kirby to make the check out to the named payee. r. ID 27 is a financial report covering a five year period of the GCCFB from 1986 through mid 1991. (1) 79% to 81% of the funding of GCCFB came from the federal, state and local government moneys. s. Coccari was the one person who had signature authority over GCCFB account 800059. (1) ID 33 reflects withdrawals from January, 1988 through December, 1991. (a) $17,105 was withdrawn in cash during that period as evidenced by withdrawal slips. (1) The legible slips shows Coccari's signature. (2) The disposition of the cash withdrawals could not be traced. t. ID 21 entails CSP bank account 74356. (1) Disbursements were made from the account to pay utility and other bills of Coccari. (a) Payments included Coccari's personal telephone bills. (b) Payments included the utility companies such as sewer, water, gas and electric. (c) Payments were made to Coccari's charge cards, for a mortgage and to a savings and loan company. (d) Smaller disbursements were made from the account for six months after Coccari left GCCFB. u. GCCFB maintained a payroll bank account. (1) Coccari received $1795 from that account. v. There were a series of checks ranging in amounts from $200 to $800 from the GCCFB account to CSP account. (1) Coccari asserted that the amounts were rent Coccari, 92- 031 -C2 Page 31 payments. w. Coccari admitted that CSP was her own account as to which she balanced the check book and kept the records. (1) Coccari admitted that she had food bank moneys in her personal account. (2) Coccari admitted to a pattern of putting food bank money in her own account. (3) Coccari admitted to the Food Bank Board when they suspended her that she had food bank moneys in her own checking account. x. After an investigation was commenced against Coccari, a 90 day status letter, sent to Coccari on or about September 7, 1993, was returned with an address unknown notation on the envelope. (1) The full investigation began on or about June 5, 1992 with a notice of investigation being sent to Coccari. y. No determination was made by the Investigative Division whether any compensation was being paid to Coccari as administrator for GCCFB. z. The payments from GCCFB to CSP which Coccari claimed as rent payments could not be verified due to the absence of a rental agreement. aa. As to certain GCCFB checks that were deposited into the Warehouse account for food purchases, no food was in fact purchased. (1) At a later date, food was purchased in an amount greater than the invoices. (a) The food bank received the food. (b) Coccari made up the difference as to the additional amount to cover the difference. bb. As to the GCCFB payroll account, salaries or stipends were paid to certain individuals. (1) Payments were made to James Kirby and Patty Locy. (2) Patty Peck and James Kirby sporadically received payments. Coccari, 92- 031 -C2 Page 32 (3) Bonnie Smouse received some monies. cc. Other employees of GCCFB received payments but no compensation agreements were found for the individuals. dd. Documents of the GPFB reflect that Coccari was not a paid employee. ee. The minutes of the GCCFB do not contain any rental agreements. ff. When deposits were made in the Warehouse account, no food was purchased until approximately ten or eleven months later. (1) The purchases occurred at the time Coccari was being investigated. gg. ID 20 relates to a document as to a building fund prepared by Patty Locy. (1) Coccari told Locy to make the entry. (2) The entry was made a substantial time after the actual event occurred at a time when questions were starting to be raised about how food bank monies were being spent. 102. Barbara Kirby was a volunteer for the GCCFB. a. When working for the Greene County Association of Retarded Citizens (GARC) in July, 1991, funding became limited. (1) Kirby asked Coccari for an advance on her salary. (a) Coccari issued two checks each in the amount of $220 to Kirby. (b) Kirby through Check 2920 on her and her husband's bank account made payment to CSP as a "loan repayment." (1) Coccari asked Kirby to make the check payable to CSP. 103 Sister Audrey Quinn is a member of the Benedictine Order. a. In 1991, Quinn was affiliated with GCCFB as a foster parent. Coccari, 92- 031 -C2 Page 33 b. In January, 1992, Quinn was on the board of GCCFB. (1) Quinn attended the January board meeting at the invitation of Coccari. (a) Statistical financial data was presented by Coccari. ID -27. (b) Most of the people left the meeting after lunch. c. A meeting about the Warehouse occurred at the Iron Griddle in February, 1992, attended by Quinn, Coccari, two men, Wanda Wright, Jack Dunn and possibly Marla Walker. (1) The two men inquired about having the GCCFB rent rooms if they bought a certain property. (2) After the two men left, Coccari had forms which would authorize the receipt of a salary or stipend for her. (a) The contact was for both past and future services. (1) The contract was back dated. (b) Coccari admitted taking money as compensation because she said she knew the board would have approved it. (c) The contract was not signed by Quinn. (3) After the meeting, Quinn and others went to the County Office Building and met with Messrs. Stets and Rhinehart. (a) Stets and Rhinehart suggested that Coccari be suspended until the matter was investigated. (4) Quinn learned that Coccari was being investigated at that meeting. (a) Coccari scheduled that meeting. 104. Marla Walker was affiliated with the GCCFB in January, 1992. a. Walker attended a meeting at the Iron Griddle in early 1992. Coccari, 92- 031 -C2 Page 34 (1) Coccari presented a paper that she wanted to have signed. (a) Walker refused to sign the paper because she was not familiar with it. (b) The paper was back dated. (c) Coccari stated there was a problem and if the paper were signed, it would help the situation. (d) Two people did sign the paper as Walker observed. 105. Joyce Rothermel is the Executive Director of the GPFB since 1987. a. A contractual relationship existed between GPFB and GCCFB whereby there would be a fair sharing of food that comes from the national network of food banks. b. The national network of food banks is called Second Harvest. (1) Second Harvest affiliates would be local distribution agencies. (2) Smaller local banks are called subsidiary distributor organizations (SDO). (a) GCCFB was an SDO. c. Rothermel as part of her job description did auditing and monitoring of SDO's. (1) A report is prepared based upon visits, discussions and information gathered. (a) The report checks out the viability of the SDO. d. ID 28 is a report completed by Rothermel relative to GCCFB. (1) Under the category of paid personnel is James Kirby, William Locy and Patty Peck. (2) Rothermel understood that Coccari was not a paid employee. Coccari, 92- 031 -C2 Page 35 (3) General category 2 of the report is "Facility /Equipment." (a) The report reflects a lease at $250 per month. (1) Rothermel believed that warehouse space was donated by the county so that the rental was for office space. e. ID 29 reflects under the category of key personnel the names of Kirby, Locy and Peck. (1) The bracket around the names signifies paid personnel. (2) Coccari was not considered a salaried employee. f. ID 30 reflects a listing of GCCFB personnel. (1) Peck and Stanley were full time employees. (2) Jim (Kirby) was part time. (3) Coccari was not in a salaried position. Rothermel learned that Coccari was not salaried when Rothermel interviewed Coccari. h. Coccari was knowledgeable in the area of food banking. g• i. Rothermel opined that it would be inappropriate to take food bank moneys and place same into a personal business account. 106. John Stets is the Greene County Controller. a. ID 24 are pages of the annual report of the Controller from 1991. (1) The report was prepared in an official capacity as Greene County Controller. b. Stets characterizes GCCFB as an association to distribute supplies, food and moneys from state and federal sources. (1) The county was responsible for the moneys that went to GCCFB from the state and federal government. (2) GCCFB was performing a function designated by the county. Coccari, 92- 031 -C2 Page 36 c. Stets had an auditor do a general audit of the 1991 accounts of GCCFB. b. d. (1) After conclusions were reached, attorney and county commissioner's notified. d. The Corner Cupboard was originated by Court order. (1) Certain funds (of the GCCFB) were frozen and others were placed in a court - ordered escrow account. 107. Richard Kalsey is an insurance broker who is one of the founders of GCCFB. a. ID 32 includes an insurance policy that Kalsey underwrote for CSP. (1) The insurance (2) was general liability. the district offices were The first two groupings were for CSP but the third was for GCCFP. (a) The third grouping was done at the request of the attorney who was reorganizing GCCFB through the county. Coccari informed Kalsey that CSP was an umbrella organization for other organizations like Catholic charities and GCCFB. c. Coccari told Kalsey to put the insurance on CSP. d. GCCFB was originally formed in the early 1980's by four people as the successor to Community Action. 108. Barry Shutt is employed by the Pennsylvania Department of Agriculture (PDA) as the Director of the Bureau of Government Donated Food (BGDF). a. BGDF receives food commodities of Agriculture (USDA). b. Food is distributed to schools, organizations across the state. c . from the U.S. Department institutions and other The Emergency Food Assistance Program (TEFAP) gives USDA commodities to needy individuals. The State Food Purchase Programs (SFPP) provides cash grants for the purchase of food to needy individuals. Coccari, 92- 031 -C2 Page 37 (1) Contacts are made between SFPP and various boards /commissions in the sixty -seven counties. (2) Quarterly distribution of funds is made to the county commissioners. (3) Funds are appropriated by the General Appropriations Act. (4) Grant agreement exist for the years 1989 through 1993 for Greene County. e. ID 8 relates to the agreement between Greene County Commissioners and the PDA. g. (1) The county will use a lead agency to act in the county's stead. (2) Greene County designated GCCFB as its lead agency. (3) Lead agencies must execute all terms of the agreement including PDA reviewing their activities. (4) Lead agencies assume the obligations of the county. (5) The county may set eligibility requirements in PDA's. (6) Officials and employees of the county and lead agencies are prohibited from entering contracts or for providing services for profit under the program. (7) PDA retains the right to access the records of the county or designated lead agency. (8) Greene County Commissioners authorized direct payment to the lead agency to Gene Lee, the county chief clerk or Coccari as GCCFB administrator. (9) The ultimate responsibility for grant funds is the county. f. SFPP is a state program and TEFAP and FEMA are federal programs. In the agreement with GCCFB, it provides that the county appointed Gene Lee as representing the county and Coccari representing the GCCFB. (1) ID 7, p. 11 GCCFB is designated as a county Coccari, 92- 031 -C2 Page 38 coordinating agency. h. The program is monitored by field representatives. i. Full fledged audits by auditors are done randomly. 109. Jean Smouse was affiliated with the GCCFB. a. Patty Locy and James Kirby were two employees of GCCFB. b. Coccari was the person in charge of the GCCFB. c. Smouse did not have responsibilities as to the finances or accounts of GCCFB. d. In approximately the Fall of 1991, Coccari called Smouse on the telephone. (1) In the conversation, Coccari accused Smouse of telling people that Coccari was misappropriating money. (2) Smouse told Coccari that she, Smouse, knew about the Warehouse account. (3) The following day Coccari spoke to Smouse. (a) Coccari told Smouse the $50,000 was Coccari's money but was put in the GCCFB account because Coccari was going through a divorce. (b) As to the Warehouse, Smouse told Coccari she knew about the invoices and check. (1) Coccari responded that the government doesn't give enough money and this is a way to get ahead and put money aside. (2) Coccari admitted the invoices were not real but false. e. Smouse was asked to recreate ledgers that did not exist. (1) In March, 1992, Smouse observed Patty working on a ledger. (a) Patty was making a cash ledger of all cash received. f. Smouse first volunteered for the GCCFB and then became paid for service in February, 1991. Coccari, 92- 031 -C2 Page 39 g. Coccari gave Smouse the title of program coordinator. h. Jim Kirby and Bill Locy were at GCCFB when Smouse was paid for services. i. To obtain warehouse space for food, Smouse contacted people in the township. (1) A donation of space for the warehouse was sought. Coccari told Smouse that the GCCFB was broke but Patty told Smouse there was plenty of money. k. When certain mail came to GCCFB in the name of CSP, Smouse became aware of the entity. 1. Smouse learned that the $50,000 was not available for the purchase of a food bank warehouse when Patty Locy showed Smouse the withdrawal from the ledger. (1) Patty showed the ledger to Hilda Aiken. (2) Smouse talked to Commissioner Mosley and Marian Ruse at the Red Cross about the withdrawal. m. Messrs. Stets and Pollock called Smouse in for questioning about the misappropriation of money at the GCCFB. n. Coccari was terminated from the GCCFB in February, 1992. (1) Coccari suspended Smouse at that time. o. Smouse was asked to return to the GCCFB by Richard Rhinehart. (1) Smouse was salaried until June, 1992 and then volunteered until January, 1993. 110. Patricia Locy was employed by the GCCFB from 1986 to 1992. a. The duties of Locy were to keep the books, give food out, do computer work and reconcile the paper work for the pantries. b. Coccari was in charge of the daily operations of the GCCFB. c. GCCFB paid money to CSP. d. The mail for Coccari and CSP would be put in the same box Coccari, 92- 031 -C2 Page 40 at GCCFB. e. When Locy was hired, she was advised of her rate of pay with the GCCFB. f. Locy was under the impression that GCCFB paid CSP rent for the building. Locy stated she had no connection with CSP, CSP accounts or CSP financial transactions. h. The ledger entry was made by Locy as to the $50,000.00. (1) Locy "reconcile[d]" the entry as for the warehouse. i. Locy had no knowledge of the $50,000 withdrawal until she saw the bank statement. g• (1) When Locy asked Coccari about the withdrawal, Locy was told by Coccari that it was for the warehouse. 111. Richard D. Rhinehart is employed by Greene County as the Director of Health Community Service. a. Greene County in 1991 had responsibility over grants regarding GCCFB. b. ID 22 is a request by Rhinehart as to the internal control measures of GCCFB and as to the basic procedures and methods of operation. c. ID 23 is a request by Rhinehart as to information about the operation of the GCCFB regarding the state repurchase program. d. ID 36 is a letter sent to various social agencies to obtain information so that the county would have input as to overall human needs. e. Based on records, Rhinehart understood that GCCFB was not paying rent for office space. f. The Human Services Department ensures that contracts are entered into as to programs and that contractors provide service. g. Rhinehart was contacted by the Chief Clerk and County Commissioners about possible improprieties at the GCCFB. (1) Rhinehart was subsequently contacted by the county Comptroller and District Attorney about alleged Coccari, 92- 031 -C2 Page 41 h. In the summer or fall of 1991, Coccari had one or more conversations with Rhinehart. improprieties at GCCFB. (1) There were discussions about the need for a warehouse. (2) The Curry home was discussed as a possible location for certain human services. i. Rhinehart was present when Coccari was suspended from her position with GCCFB. (1) The board members of GCCFB were present. (2) John Stets and County Solicitor Bill Smalis were in attendance. (3) Coccari received her termination letter dated February 28, 1992. Attorney Farley Toothman provided a leadership role in reorganizing GCCFB. (1) When Toothman stepped down to run for political office, Rhinehart took over in May or June, 1992. (2) In August, Sheila Christopher was hired for operations as per a contract with GPFB. k. Rhinehart had prior dealings with Coccari when she worked for the Washington- Greene County Community Action Agency. (1) Coccari was under the direct supervision of Rhinehart for a period of time as assistant planner. 112. David Pollock is the District Attorney of Greene County since 1988. a. Pollock interviewed Coccari on several occasions as part of his official position. (1) The discussions centered on the activities of the GCCFB (a) Pollock made inquiry about funds being placed in the warehouse account. (1) Coccari stated that the funds were put Coccari, 92- 031 -C2 Page 42 into the CD's because they were not earning adequate interest. (2) Coccari stated that the warehouse account was for the purchase of food. (a) Coccari stated the food was bought from David Bowers, a truck driver from Cincinnati, Ohio. (b) Coccari asserted that by selling food at a profit, money could be used to purchase a building to serve the needs of the food bank. (3) In a subsequent meeting with Coccari's attorney present, Coccari admitted she never got food from Bowers. (a) Coccari then claimed that the money was used as a prepayment for food. (b) Discussions focused on the discrepancy between withdrawals and produced invoices. b. Pollock considered the warehouse account to be Coccari's account to purchase food for resale to GCCFB. c. Certain food was purchased from the warehouse account in May, 1992 after the second interview by Pollock of Coccari with her attorney. (1) At the second interview, Coccari stated that she had purchased food. (a) Invoices were given which were generic in nature. 113. Barbara Coccari is an individual who holds a bachelor, master of arts and Ph.D. degrees. a. Coccari was married between 1973 and 1983. b. Coccari held various positions in the areas of welfare, teaching and social service organizations. c. Coccari is currently employed with a group called Community Action Southwest. (1) Coccari is lead manager for the Greene County Office. Coccari, 92- 031 -C2 Page 43 j d. Coccari learned of food banking through Second Harvest, a group formed to reclaim and distribute food to the poor. e. Through Kathleen Sullivan, Coccari became involved with GCCFB. (1) A distribution network in Greene County was contemplated using the churches. f. When Kathleen Sullivan advised that she could not continue the project due to the expiration of the grant, Coccari and others decided there was a need in Greene County to receive food from the GPFB. g- (1) The church groups paid GCCFB a shared maintenance fee of 10 per pound. h. In 1984, GCCFB obtained space to store left over food. i. Under FEMA, GCCFB got a grant from the federal government to purchase food. (1) Once a month a tractor trailer of food would be delivered from GPFB to a location where the church groups would come with their own pick up trucks. (a) The church groups would take the boxed food and regroup the food into individual bags. GCCFB had a shared maintenance fee to GPFB of 5 per pound. The first bank account for GCCFB was a checking account in Gallatin Bank, now the Integra Bank. (1) A separate account was opened when a federal grant was received at the First Federal Savings and Loan. (a) The money came to the county which wrote a check to GCCFB. k. In 1985, the GCCFB was formalized as the Greene County Food Bank Association (GCFBA), a 501(c)(3) charitable organization. (1) Each party (church) nominated one person to an advisory committee wherein officers were elected from that group. 1. Until 1985, no salaries were paid to anyone as to the Coccari, 92- 031 -C2 Page 44 m. In 1985, Coccari compensation for hour. n. In 1986 Coccari (Locy) . (1) Romesberg was the coordinator. (2) Locy was an administrative assistant. o. Coccari claims that in Fall, 1986, the association provided a salary of $450.00 a month. P. GCCFB. claims that the board voted to give her thirty -five hours a week at $10.00 per hired Joe Romesberg and Patty Peck Between 1986 and 1991, Coccari made efforts to obtain additional funding for the GCCFB. q. Coccari opened different bank accounts for separate purposes as to the GCCFB. r. Coccari claims that the withdrawal of $50,000.00 and placing the funds in a single CD followed, after maturity, by placing the funds into two CD's of $35,000 and $15,000 was to segregate warehouse facility money from general operating money. s. Coccari admits that CSP is not a separate business or entity. t. For the years 1987 through 1991, Coccari claims she was entitled to over $5,000.00 a year which she did not take. u. As to the Community Bank check payroll account, the signatures of Coccari and Jack Dunn were required. (1) All other accounts only required Coccari's signature. v. Coccari claims that rent was being paid to her as part of her plan for the warehouse. w. Coccari admits that she took $5,000.00 of GCCFB funds to buy a personal car but asserts that the funds represented fair compensation that she was entitled to for the fiscal year 1990 -91. (1) The funds were withdrawn from GCCFB account 80059 and placed into the CSP checking account of Coccari. Coccari, 92- 031 -C2 Page 45 x. Coccari admits taking approximately $2,500 to pay her ex- husband's son's credit card company but asserts that it was compensation due her for the period from July, 1991 to December, 1991. y• Coccari claims that a payment of $4,000.00 from a GCCFB account into a CSP account was for rent. (1) A withdrawal of $5,000.00 was made from a GCCFB account but the balance of the money taken by Coccari is claimed by her to be due her as compensation. z. Coccari admits that checks from private donors were deposited into her CSP account. (1) Coccari asserts that the funds were to be used for the facility project, the purchase of a warehouse. (2) The checks were marked for deposit in the GCCFB account but were actually deposited in Coccari's CSP account. aa. Coccari claims she had involvement with David Bowers as to the purchase of food. (1) Checks were issued co- signed by Coccari and Gene Lee, the county chief clerk in mid 1991. (a) The checks were made payable to the warehouse account. (b) No food was purchased. (c) Coccari claims that Bowers initially said he would be delayed and after August or September, 1991 she never heard from him. (d) Coccari claims the invoices were for the food items that were ordered. (e) Food was purchased in March, 1992 by the reorganization committees. bb. A payment of $440.00 was made to Barb Kirby. (1) The overpayment was made as a loan. (a) The payment came from a GCCFB account but the repayment was made to the CSP account. Coccari, 92- 031 -C2 Page 46 cc. Coccari claims that the $5,000.00 in cash she withdrew in 1990/91 was a salary authorized by Jack Dunn dd. Coccari claims that payments for her salary and rent were done to have documentation for audits that were occurring as to the years 1990 -92. ee. Coccari asserts that she did not convert GCCFB money for her own pecuniary gain. ff. With the Washington - Greene County Action Agency, Coccari had responsibilities in the areas of budget, finance and other areas. gg. Coccari testified that she was appointed program administrator of the GCFB "... [b]y the general agreement of the association." hh. When GCCFB operated at 243 East High Street, the facility was a three story frame house owned by Coccari. (2) GCCFB operated out of the facility for five or six years. (3) GCCFB paid rent to the CSP. ii. Coccari claims that CSP was a personal venture by Coccari. 77 (1) Coccari states the repayment was placed into the CSP account because "it was excess administration." (1) GCCFB utilized two of the five rooms on the first floor. From the CSP account, Coccari had checks written for Avon, TCI (cable TV), West Penn Power, Equitable Gas, S.P. Water Authority, the second floor telephone in Coccari's name, At -tel telephone, Betty Cole, tax collector, Robert Elliott, treasurer, Chester Jeffrey Plumbing, Coccari's Master Charge, American Express, mortgage payment to First Federal, West Penn Motor Club, Kelsey Insurance, Commonwealth of Pa. (Coccari's auto registration fee), Kemper National Insurance, $500.00 check for David Coccari, Moonlight Productions, Julie Ets (school tax), Prudential Insurance, Paul Panoflic (roofer), $25 check for Dodge Shadow, $7500 check for Coccari. kk. In an interview, Coccari described CSP as her consulting Coccari, 92- 031 -C2 Page 47 service. (1) CSP was her personal entity. (2) CSP account was Coccari's personal business account. 11. The tax ID number Coccari used for the warehouse account was her social security number. (1) Even though food could have been purchased through a GCCFB account, Coccari claims that the warehouse account was a means to create additional administrative dollars. mm. When interviewed by the district attorney, Coccari stated that she purchased food from a truck driver as per invoices. nn. A withdrawal from the warehouse account of $6,049.29 on April 6, 1992 closed the account. (1) A check was written out on April 3, 1992 which was the same day Coccari was interviewed by the district attorney for the second time. (2) The account was closed and food was obtained after Coccari was suspended. oo. The $35,000.00 out of the $50,000.00 withdrawal by Coccari was considered by her to be money owed to her. (1) Coccari claims that portion was put into a facility project as a means of establishing a food bank foundation. PP• (1) In a second interview, Coccari stated that she purchased the food from Save A Lot but did not receive the food. The "rent" Coccari received from the food bank started at $150.00 and went to $250.00 and ended at $400.00. (1) The "rent" payments varied in terms of amount and the times of payment. (2) Coccari claims that staff knew that rent was paid to Coccari as owner of the building. (3) As to ID 36, written in whole or part by Coccari, a statement was made that the GCCFB usually occupies Coccari, 92- 031 -C2 Page 48 qq- office space at no charge. The $5,000.00 withdrawal by Coccari from the GCCFB account, claimed by Coccari as compensation for 1990/91, was used to purchase a personal vehicle and not a food bank vehicle. rr. The checks Coccari received as rent were not written to her personally but to GCCS. (1) Coccari admits the funds were for her. (2) Coccari states that endorsement was to GCCS because "it represented a philosophical approach to the Community Service Program as a management agent for the food bank." ss. There was no written agreement regarding any compensation owed to Coccari. tt. There was no written contract between GCCFB and CSP. uu. Coccari claims that her action in attempting to have the board members sign an agreement was to confirm an authorization for payment made in September 1991. 114. Ronald Goughler is the Social Service Administrator of Southwestern Pennsylvania Human Services (SPHS). a. SPHS is a non - profit, 501(c)(3), corporation. (1) SPHS provides thirteen categorical services such as mental health, substance abuse and services to the homeless. (2) Funding is a mixture of private and public funds. b. In Goughler's opinion, GCCFB is a grass roots organization run by people who are volunteers. c. "Grass roots" type organizations generally do not have sophisticated accounting or computer systems and rely on an advisor or policy structure. (1) Policy is not usually codified as in a formal organization. 115. Roger W. Grimes was affiliated with GCCFB until 1987. a. As to R -8, the written name Roger Grimes is not the Coccari, 92- 031 -C2 Page 49 signature of Roger Grimes. 116. James J. Dunn was President of the Board of Directors of GCCFB. a. Coccari ran the day -to -day activities of the GCCFB. b. Dunn was affiliated with the GCCFB until 1992. c. Dunn did not know that Coccari owned the building from which GCCFB operated until he was told by the District Attorney. (1) Coccari told Dunn that the GCCFB was not paying rent. d. Dunn did not know of the existence of CSP "until after things broke up." e. At a meeting at the Iron Griddle, Coccari told Dunn that he was shirking his duty and that he "should sign these things." (1) As to a $4,000.00 payment (R -15), Coccari indicated that it was for her services to GCCFB for which she never had been paid. (2) As to payment of $5,000.00 and $2,500.00 (R -13, 14) Dunn is unaware of the purpose of the payments. f. At times, Dunn was given blank checks to sign. g. As President of GCCFB, Dunn did not do business, banking or buying. 117. Robert Fletcher picked up food from the GCCFB and took it to his church for distribution. a. As to the document (R -8) containing the written name Fletcher, that writing is not the signature of Fletcher. 118. Rosemary Fletcher is the spouse of Robert Fletcher. a. Fletcher kept a daily log of her and her husband's activities. (1) The log does not indicate any attendance by Robert Fletcher at a food bank board or association meeting. Coccari, 92- 031 -C2 - Page 50 119. Wanda Wright was associated with the GCCFB. a. The written name of Wright which appears in R -20, 21 is her signature. b. Wright attended the February 28, 1992 meeting at the Iron Griddle. (1) A discussion occurred as to the purchase of the Curry home. (2) Coccari stated that the sheriff or police came to her home questioning her activities as Director of the food bank. (a) Coccari's request for signatures was taken by Wright to mean that Coccari needed verification of her position with GCCFB. (1) Wright signed with her understanding that such action constituted a verification that Coccari was Director. (2) Wright did not read the document she signed. (3) Wright did not observe that she was authorizing the payment of funds to Coccari or CSP. c. Wright was not aware that GCCFB was paying rent. 120. Exhibit R -7 is the Annual Report of the Controller of Greene County, Pennsylvania for the year ending 12/31/91 which contains a Supplement as to the GCCFB that provides in part: FOOD BANK INVESTIGATIVE AUDIT 1991 The Greene County Food Bank is a loosely constituted association apparently formed in the early 1980's to function as the distribution apparatus for surplus foods and monies received from State and Federal sources. As the overwhelming majority of funds are State and Federal the responsibility for audit comes under the Single Act Audit, although the County of Greene is responsible for the receipt of the foodstuffs and funds, and their proper distribution to the individuals and families designated as recipients by the program. Upon receiving reports of irregularities in the operation of the Food Bank, a special audit was Coccari, 92- 031 -C2 Page 51 undertaken for fiscal year 1991 and the finding and recommendations are included as a part of the 1991 report of the Controller. FINDING NUMBER ONE: The food Bank while apparently functioning as a viable organization, possessed no charter, by laws or recognizable set of operational rules or regulations. The "Board was randomly appointed by the Director, Barbara Mooney with no finite term or specific duties or responsibilities. The Controller's Office could not ascertain a chain of command or flow of responsibility. The Food Bank was in effect managed by the Director with no oversite other than the Single Act Audit. The "Board" received little information as to the financial condition of the operation and made no decisions regarding finances. FINDING NUMBER TWO: * * * The Controller's Audit found an absence of financial controls or accounting systems. Food Bank monies were scattered in at least twelve (12) different accounts in four (4) different banks both in and out of the County. These funds still under investigation exceeded Eighty Thousand ($80,000.00) Dollars, and most likely will amount to excess of that figure when a full three (3) year audit is conducted. More disturbing was the removal of "Food Bank" funds from a certificate of deposit /money market instrument held in a Uniontown bank branch and the transfer to an account titled Greene County Community Services. This entity was discovered to be a consulting firm owned and operated by the Director. The Controller's Office has frozen these funds under Court Order and this matter remains under investigation. The Controller's Office also discovered three (3) transactions which occurred in 1991 in which a business owned and operated by the Director allegedly sold foodstuffs to the Food Bank. The transactions were not disclosed to the "Board" or the County of Greene and would constitute a conflict of interest. As of this date the records available to the Controller's Office cannot confirm the foodstuffs were received by the Food Bank. This aspect of the audit has been referred to the District Attorney and the state authorities for their Coccari, 92- 031 -C2 Page 52 review. The Controller's Office continues to pursue this aspect of the audit and will specifically entertain surcharge proceedings depending on its findings, and the actions of the other authorities in this matter. 121. Exhibit R20, 21 purport to be undated agreements between GCCFB and CSP for the fiscal years 1990 /91 and 1991/92 which state that CSP will provide two groups of programs for GCCFB in return for fees of $400.00 per month for the first program and $5,000.00 per year for the second program. 122. Exhibits ID 7 through 11 are agreements between Greene County and the GCCFB whereby GCCFB is the designated lead agency under the State Food Purchase Program as to providing food for the needy. a. One of the program requirements is a prohibition against county and lead agency officials /employees from entering into contracts or providing services for profit under the program. 123. ID -31 are the job descriptions for the various positions of the GCCFB. a. The duties and responsibilities for the Administrator are listed as follows: Administrator- -Part time (approx. 35 hours per month) (1) Responsible for all executive directors (2) Direct and supervise all staff (3) Monitors all records, reports, communication with funding sources or potential funding sources. (4) Monitors all services provided by the Greene County Community Food Bank. b. The duties and responsibilities for the Coordinator are listed as follows: Coordinator - -Part time (approx 20 hours per week) (1) USDA program supervision: (a) Monitor inventory of commodities (b) Assist in securing commodities from Pittsburgh Coccari, 92- 031 -C2 Page 53 (c) Monitor distribution of commodities by MDS (d) Assess needs of MDS (e) Prepare monthly distributions to MDS (f) Reconcile distribution and inventory reports (2) Generic Purchase program supervision: (a) Monitor inventory of product (b) Monitor distribution of product (c) Arrange for purchase of product (d) Prepare bills for payment (e) Prepare reports for FEMA and State Grant (3) Assist in volunteer activities for the general improvement of the Green County Community Food Bank. Such activities might include food drives (Scouting for Food, e.g.), volunteer recognition, requests for donations, and general public relations. 124. Coccari as Coordinator /Administrator of the GCCFB was in an unpaid position. 125. No legitimate agreement existed between GCCFB and CSP as to the performance of services for monetary consideration. 126. Coccari took GCCFB monies comprised of federal, state, county and private funds and used those monies for her personal purposes. III. DISCUSSION: Initially, it is noted that the allegations in this case relate to both Act 9 of 1989 and Act 170 of 1978. In this regard, Section 9 of Act 9 of 1989, P.L. 26, 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 Coccari, 92- 031 -C2 Page 54 section, a violation was committed prior to the effective date of this act if any elements of the violations occurred prior thereto. Since Coccari has filed a Motion to Dismiss seeking a dismissal of the Investigative Complaint on the basis that she is neither a public official nor public employee so as to be subject to the jurisdiction of this Commission, we must address that threshold issue under both Act 170 of 1978 and Act 9 of 1989. On the issue of whether Coccari is a public official /employee under Act 170 and /or Act 9, the following statutory definitions are relevant. Section 2. Definitions individual employed by political subdivision taking or recommending nonministerial nature "Public employee." Any the Commonwealth or a who is responsible for official action of a with regard to: (1) contracting or procurement; (2) administering or monitoring grants or subsidies; (3) planning or zoning; (4) inspecting, licensing, regulating or auditing any person; or (5) any other activity where the official action has an economic impact of greater than a de minimis nature on the interests of any person. "Public employee" shall not include individuals who are employed by the State or any political subdivision thereof in teaching as distinguished from administrative duties. "Public Official." Any elected or appointed official in the Executive, Legislative or Judicial Branch of the State or any political subdivision thereof, provided that it shall not include members of advisory boards that have no authority to expend public funds other Coccari, 92- 031 -C2 Page 55 than reimbursement for personal expense, or to otherwise exercise the power of the State or any political subdivision thereof. "Public Official" shall not include any appointed official who receives no compensation other than reimbursement for actual expenses. Act 170 of 1978, Section 2, P.L. 883. "Public employee." Any individual employed by the Commonwealth or a political subdivision who is responsible for taking or recommending official action of a nonministerial nature with regard to: (1) contracting or procurement; (2) administering or monitoring grants or subsidies; (3) planning or zoning; (4) inspecting, licensing, regulating or auditing any person; or (5) any other activity where the official action has an economic impact of greater than a de minimis nature on the interests of any person. "Public employee" shall not include individuals who are employed by the State or any political subdivision thereof in teaching as distinguished from administrative duties. "Public Official." Any person elected by the public or elected or appointed by a governmental body, or an appointed official in the Executive, Legislative or Judicial Branch of the State or any political subdivision thereof, provided that it shall not include members of advisory boards that have no authority to expend public funds other than reimbursement for personal expense, or to otherwise exercise the power of the State or any political subdivision thereof. "Political subdivision." Any county, Coccari, 92- 031 -C2 Page 56 city, borough, incorporated school district, vocational institution district, and entity or body organized mentioned. town, township, school, county any authority, by the afore- "Governmental body." Any department, authority, commission, committee, council, board, bureau, division, service, office, officer, administration, legislative body, or other establishment in the Executive, Legislative or Judicial Branch of a state, a nation or a political subdivision thereof or any agency performing a governmental function. Act 9 of 1989, P.L. 26, 65 P.S. 8402. Since the facts of record reflect that Coccari was not hired by GCFB to a compensated position, Coccari was not employed by a political subdivision and hence was not a "public employee" under both Act 170 of 1978 and Act 9 of 1989. As to whether Coccari was a public official, separate analyses must be made under Act 170 and Act 9 since the definition of "public official" was amended by the latter Act. Under Act 170, a person is a public official if appointed by the Commonwealth or a political subdivision. Under Act 9, there are two separate tests for a public official: the first is the same as under Act 170; the second is whether there was an appointment by a "governmental body" which latter phrase is defined to include inter alia ". . . any agency performing a governmental function." In resolving this question of Ethics Law coverage, the first issue concerns whether an appointment was made. The record reflects that there are two separate scenarios involving possible appointments as to Coccari. First, Coccari testified that she was appointed to the GCFB by "general agreement" of the Board (Fact Finding 113gg) after the Internal Revenue Code (IRC) 501(c)(3) status was obtained. Second, appointments occurred beginning in 1988 and continuing thereafter (until Coccari's termination) when Greene County contracted to designate GCFB as the "lead agency" as to the State Food Purchase Program. As to Act 170 of 1978, we must conclude that Coccari was not a public official. The narrow statutory definition under Act 170 of 1978 for a public official requires an appointment by a political subdivision. Clearly GCFB under Act 170 of 1978 was not a political subdivision. Greene County, which is a political subdivision, appointed GCFB as "lead agency" but such appointments were to the agency and not Coccari. Thus, it was Greene County which made appointments; it was GCFB and not Coccari that received Coccari, 92- 031 -C2 Page 57 those appointments. Coccari herself was not appointed by Greene County. Hence, Coccari was not a public official under Act 170 of 1978. Similarly, under Act 9 of 1989, Coccari was not a public official. As noted above, the appointment by Greene County was to GCFB and not Coccari. As to any appointment by the GCFB Board, the testimony of Coccari that her appointment occurred through general agreement does not equate to an actual appointment. The record does not reflect any action by the GCFB Board to appoint Coccari. In fact, the evidence of record suggests the opposite, namely that Coccari appointed the GCFB Board. GCFB started informally and continued despite its subsequent IRC 501(c)(3) status. Hence, Coccari never received any appointment by the GCFB Board. As the Greene County Controller noted in his 1991 report, the GCFB was a loosely constituted association with no charter, by laws or recognizable set of rules or regulations with Coccari randomly appointing the Board. Fact Finding 120. The fact that Coccari was not a public official /employee under either Act 170 of 1978 or Act 9 of 1989 compels us to a determination that there were no violations of the Ethics Law. Since being a public official /employee is a jurisdictional requirement for establishing a violation of the Ethics Law, assuming Sections 403(b) has no application, there can be no violation if there is no public official /employee. Accordingly, we grant the motion by Coccari to dismiss the action on the basis that she was not a public official /employee. The Ethics Law does empower this Commission to refer matters to law enforcement officials at any time during or after the preliminary inquiry stage of an investigation. 65 P.S. §408. In light of the following factual review, such a referral is warranted in this case. GCFB had its genesis when people or church groups received food from the Greater Pittsburgh Food Bank (GPFB) for distribution in Greene County . The initial operation was "grassroots" whereby food typically would be received for a group of churches with the food being deposited in one of several designated locations. Thereafter, the church groups would take and regroup the food into individual bags for distribution. Fact Finding 113f. As time progressed, Coccari and others evolved the process whereby leftover food would be stored at GCFB. In 1985, the GCFB became formalized after receiving charitable organization status under the IRC. Each church nominated one person to an advisory committee with an officer elected from that group to the GCFB Board. When money began to be received from both private and governmental sources, GCFB bank accounts were opened. Finally, in 1986 Coccari hired staff for the GCFB. Coccari, 92- 031 -C2 Page 58 At some point during the operation of GCFB, Coccari in a private capacity opened an account in the name of CSP, which was not any type of entity but merely the name that Coccari used for her own personal business. Fact Finding 101i. After GCFB became operational with funding, 80% of which generally was from government sources, Coccari began taking various actions to withdraw GCFB funds and either deposit those funds into her personal CSP accounts or utilize them for her own personal purposes. Coccari was able to take such actions because she was sole signatory for withdrawals or disbursements and in a few cases co- signatory as to the GCFB accounts. Fact Findings 8, 9. The notable and questionable withdrawals by Coccari as to GCFB funds will be outlined below. In one GCFB account, Coccari withdrew $50,000.00 and placed that money into a CSP account as a Certificate of Deposit (CD) for a term of six months; upon maturity, the funds were split and reinvested into two CD's, in the amounts of $35,000.00 and $15,000.00 respectively, while the interest was placed into a separate CSP account. Fact Findings 46 -49: Coccari did surrender the CD's after allegations surfaced about the misappropriation of GCFB funds which resulted in Coccari's termination. Coccari in 1991 withdrew $5,000.00 from a GCFB account to purchase a vehicle. Fact Findings 19 -22. Although Coccari asserts that she was entitled to the money as salary which she had not taken, the record reflects that the Board never authorized a salary for Coccari in that she was in a non - compensated position. Another withdrawal of $2,500.00 from a GCFB account was made by Coccari and used as a payment for a Citibank charge card payment for her stepson. Fact Findings 23 -27. Once again, Coccari asserted that this was salary due her. Since GCFB operated out of a building that was owned by Coccari, a series of checks from GCFB accounts to a CSP account were asserted by Coccari to be legitimate rent payments. However, there was no valid lease agreement between GCFB and CSP for the rental of space for GCFB operations. Parenthetically, we do note that after an investigation began, Coccari prepared a contract which purported to be an agreement for services between the GCFB and CSP. However, the record reflects that no such agreement was entered into by the GCFB Board. The are numerous instances of record where Coccari took CSP funds, which originally were GCFB funds, to pay her various utilities payments. Fact Findings 74, 101t, 113jj. In another instance, Ms. Kirby, who was an employee of the GCFB, sought a loan of $440.00 which Coccari gave Kirby and her husband from a GCFB account. However, when the Kirbys sought to Coccari, 92- 031 -C2 Page 59 repay the loan, Coccari directed that the Kirbys make the check payable to the CSP which was Coccari's personal account. Fact Findings 75 -81. Separate and apart from GCFB funds being deposited into CSP accounts, there were also instances when GCFB funds were deposited into a warehouse account. Once again, the warehouse was ostensibly set up for any number of different reasons as proffered by Coccari at any given point in time. When Coccari was questioned by the Greene County District Attorney as to disbursements for the warehouse account, Coccari asserted in her first interrogation that the disbursements were for food which was purchased; however, on the second interrogation, Coccari with her attorney present, admitted that no food was actually purchased but prepayments were made for food that had not been received. Fact Findings 112 (a) (1) (a) (2) . Subsequently, food was in fact purchased by Coccari, but only after Coccari was aware that she was under scrutiny as to the utilization of GCFB funds for personal use. The last notable activity occurred when Coccari wrote out checks from a GCFB account to an individual named Ashe with some of those checks being deposited into Coccari's personal accounts. Fact Findings 85 -92. We as a Commission are quite shocked that Coccari would take funds which came from governmental and private sources that were earmarked for the purpose of buying foods for the needy in Greene County and utilize those funds for her own personal purposes. Coccari, more than anyone else, had to be acutely aware that every dollar that she used would be one less dollar that could buy food for needy Greene County people. It is quite obvious to us that when money, in addition to donated food, started being received by the GCFB, an irresistible temptation arose in Coccari who had control over that money with little or no oversight. The result was that Coccari used GCFB funds for her own personal purposes. Thus, the evidence of record establishes that Coccari's actions warrant the referral of this case to law enforcement authorities for requisite action under various criminal statutes. Since federal, state and local government funds were involved, this matter will be referred to the Office of U.S. Attorney, Pennsylvania Office of Attorney General and the Greene County Office of District Attorney with our recommendation for review as to the institution of criminal prosecutions against Coccari. IV. CONCLUSIONS OF LAW: 1. Barbara Coccari as the Program Administrator /Coordinator of Coccari, 92- 031 -C2 Page 60 the Greene County Community Food Bank was not a public official or employee under Act 170 of 1978 and Act 9 of 1989 in that Coccari was not employed by a political subdivision nor appointed by a political subdivision or governmental body. In re: Barbara Coccari File Docket: 92- 031 -C2 . Date Decided: 02/23/95 Date Mailed: 03/10/95 ORDER NO. 964 1. There being insufficient evidence to conclude that Barbara Coccari, as Program Administrator /Coordinator of the Greene County Community Food Bank, was a public official /public employee subject to the Ethics Law, the Respondent's Motion to Dismiss is granted. 2. The record as developed to date would suggest strongly the need for additional review of this matter which will be referred to the Office of U.S. Attorney, Pennsylvania Office of Attorney General and the Greene County Office of District Attorney as to the institution of criminal prosecutions against Coccari. BY THE COMMISSION, cO DANEEN E. REESE, CHAIR Commissioners Austin M. Lee and Boyd E. Wolff abstained as to the decision of this matter.