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HomeMy WebLinkAbout741 AstolosMr. Charles Astolos 419 Point Street Saltsburg, PA 15681 Re: 87 -118 -C Dear Mr. Astolos: STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 ORDER OF THE COMMISSION Order No. 741 Before: Helena G. Hughes, Chair Robert W. Brown, Vice Chair W. Thomas Andrews G. Sieber Pancoast Dennis C. Harrington James M. Howley Date Decided: February 22, 199Q Date Mailed: March 6, 1990 The State Ethics Commission received a complaint regarding you and a possible violation of the State Ethics Act, No. 170 of 1978, 65 P.S. 401 et. seq. You were notified in writing as to the commencement of the investigation and as to the specific allegation(s). The investigation has now been completed and a Findings Report was issued to you which constituted the Complaint by the Investigation Division of the State Ethics Commission. An Answer was filed and a hearing was waived. The record is now completed. This Order of the Commission is hereby issued which sets forth the individual allegations, findings, discussion and conclusion as follows: I. Allegation: That you, a member of the Saltsburg Borough Council, Westmoreland County, violated the following provisions of the State Ethics Act (Act 170 of 1978), in that you participated in and approved purchases for the borough from a business which you own: 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 Mr. Charles Astolos Page 2 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. 5403(a). (c) No public official or public employee or a member of his immediate family or any business in which the person or a member of the person's immediate family is a director, officer, owner or holder of stock exceeding 5% of the equity at fair market value of the business shall enter into any contract valued at $500 or more with a governmental body unless the contract has been awarded through an open and public process, including prior public notice and subsequent public disclosure of all proposals considered and contracts awarded. Any contract made in violation of this subsection shall be voidable by a court of competent jurisdiction if the suit is commenced within 90 days of making of the contract. 65 P.S. S403(c). A. Findinas : 1. You served as a Saltsburg Borough Councilmember. a. You served in this position from 1984 through 1988. b. You resigned your position in December, 1988. c. You also served as Chairman of the Borough Council, Sewer and Water Committee. 2. You are the President of Saltsburg Supply Company, Incorporated. a. This Corporation is comprised of your wife, your two children and yourself. b. Saltsburg Supply Company, Incorporated was formed in December of 1987, although it was operated as a partnership prior to that time. c. This business is a general supply store dealing primarily in hardware. 3. Saltsburg Borough purchased supplies from Saltsburg Supply Company, Incorporated. Mr. Charles Astolos Page 3 4. Records of Saltsburg Borough indicate the following payments made by the Borough to Saltsburg Supply Company during the years 1983 through 1988 regarding the purchase of supplies from that company: Year Date Check No. Amount a. 1983 Fund: Sewage: 1/4/83 410 $ 2.50 3/8/83 425 $ 13.72 4/4/83 429 $ .99 6/7/83 447 $ 26.27 11/9/83 478 $ 2.59 Water: 1/4/83 6987 $ 6.88 2/7/83 7021 $ 7.41 3/8/83 7038 $ 9.09 4/4/83 7055 $ 33.24 6/7/83 7079 $ 25.94 7/12/83 7089 $ 37.08 8/2/83 7102 $ 4.06 9/12/83 7112 $ 57.71 11/9/83 7138 $ 45.19 General: 1/4/83 13634 $107.72 2/7/83 13689 $ 34.25 3/8/83 13725 $ 15.94 4/4/83 13744 $ 39.88 6/7/83 13792 $ 84.90 6/15/83 13822 $ 43.87 7/12/83 13846 $177.80 8/2/83 13871 $ 65.14 9/12/83 13904 $ 70.32 11/09/83 13942 $ 40.88 12/6/83 13991 $125.90 1/4/84 13999 $ 32.11 b. 1984: Sewage: 2/6/84 493 3/5/84 504 1983 Total: $1,111.38 $ 90.38 $197.29 Mr. Charles Astolos Page 4 Year Water: c. 1985: Date, 4/2/84 5/7/84 6/4/84 7/2/84 8/6/84 9/10/84 10/1/84 11/7/84 12/3/84 12/31/84 3/5/84 4/2/84 5/7/84 6/4/84 7/2/84 8/6/84 9/10/84 11/7/84 12/3/84 General: 2/6/84 3/5/84 4/2/84 5/7/84 6/4/84 7/2/84 8/6/84 9/10/84 10/1/84 11/7/84 12/3/84 12/31/84 Check No. 514 521 535 544 550 571 581 593 603 612 1984 Total: 7190 7209 7218 7245 7250 7262 7287 7317 7328 14045 14064 14093 14114 14153 14173 14224 14249 14265 14310 14326 14361 Sewer: 2/4/85 622 3/4/85 634 4/1/85 643 5/6/85 663 6/3/85 672 7/1/85 679 8/5/85 691 9/9/85 704 10/7/85 720 Amount $ 80.87 $210.57 $ 57.03 $ 13.27 $ 8.46 $ 4.47 $ 10.33 $ 34.76 $114.74 $ 36.42 $1,764.83 $ 44.26 $ 41.40 $ 3.51 $ 8.15 $ 43.08 $162.65 $ 33.34 $ 22.91 $ 4.73 $ 40.03 $ 2.83 $ 10.57 $ 17.17 $114.78 $ 57.42 $ 44.58 $ 56.62 $ 12.45 $ 57.05 $102.30 $ 26.41 $199.03 $202.88 $ 70.15 $ 19.73 $ 6.97 $ 4.29 $ 4.14 $ 77.80 $ 4.61 Mr. Charles Aatolos Page 5 Tear d. 1986: Date 12/2/85 Water: 2/4/85 3/4/85 4/1/85 5/6/85 6/3/85 7/1/85 8/5/85 10/07/85 11/4/85 12/2/85 12/31/85 General: 2/4/85 3/4/85 4/1/85 5/6/85 6/3/85 7/1/85 8/5/85 8/5/85 9/9/85 10/7/85 11/4/85 12/2/85 12/31/85 Sewage: 2/3/86 3/3/86 4/7/86 6/2/86 7/7/86 8/4/86 9/8/86 10/6/86 11/3/86 12/1/86 12/31/86 Water: 1/6/86 2/3/86 4/7/86 5/5/86 check No. 736 7345 7367 7377 7395 7408 7419 7424 7465 7474 7487 14401 14429 14442 14496 14523 145552 14561 14576 14612 14639 14670 14700 14722 1985 Total: 753 761 766 788 800 810 820 829 837 845 862 7501 7512 7531 7549 Amount $ 2.58 $ 6.00 $ 4.37 $ 34.47 $ 5.59 $ 1.19 $ 96.49 $ 51.48 $ 71.74 $ 3.26 $ 3.57 $ 12.13 $ 3.52 $ 14.69 $ 23.90 $ 34.03 $ 88.51 $ 5.38 $ 80.44 $ 1.29 $132.33 $ 36.17 $ 12.08 $124.49 $ 68.31 $1,507.61 $ 45.42 $ 20.86 $ 3.48 $ 4.07 $ 17.53 $ 31.85 $ 66.94 $ 14.58 $109.24 $ 13.64 $144.06 $ 6.50 $ 35.69 $ 4.86 $ 57.94 Mr. Charles Astolos Page 6 Year e. 1987: Date 6/2/86 7/7/86 8/4/86 9/8/86 10/6/86 11/3/86 12/1/86 General: 3/3/86 4/7/86 5/5/86 6/2/86 7/7/86 8/4/86 9/8/86 10/6/86 11/3/86 12/1/86 12/31/86 Sewage: 2/2/87 3/2/87 4/6/87 5/4/87. 6/1/87 7/6/87 8/3/87 9/15/87 10/5/87 11/2/87 12/7/87 Water: 2/2/87 3/2/87 4/6/87 5/4/87 6/1/87 7/6/87 8/3/87 9/15/87 10/5/87 11/2/87 12/7/87 Check No. Amount 7562 $ 13.03 7574 $ 8.77 7592 $108.35 7611 $ 46.68 7623 $ 16.82 7635 $ 36.31 7643 $ 11.28 14777 $ 16.85 14807 $ 13.40 14838 $ 5.46 14864 $ 56.41 14884 $ 20.13 14928 $ 59.47 14957 $ 34.62 14982 $ 73.28 14998 $ 15.42 15017 $ 75.51 15062 $102.42 1986 Total: 877 885 901 908 920 934 945 954 964 969 901 7669 7680 7698 7711 7728 7744 7763 7778 7794 7798 7816 $1,290.87 $ 22.00 $ 75.53 $ 45.41 $ 23.83 $ 37.80 $237.27 $ 49.59 $ 72.60 $141.64 $ 54.13 $138.15 $ 27.04 $ 65.29 $ 28.86 $ 27.70 $ 55.86 $ 10.33 $ 12.04 $ 13.23 $ 60.86 $146.32 $178.19 Mr. Charles Astolos Page 7 Tear General: Streets: f. 1988: General: Date 12/31/87 2/2/87 3/2/87 4/6/87 5/4/87 6/1/87 6/1/87 7/6/87 8/3/87 9/15/87 10/5/87 11/2/87 12/7/87 12/31/87 4/6/87 Sewage: 2/1/88 3/7/88 4/4/88 5/3/88 6/7/88 7/12/88 9/13/88 10/4/88 11/9/88 12/6/88 Water: 2/1/88 4/4/88 5/3/88 6/7/88 7/12/88 8/2/88 9/6/88 10/4/88 11/9/88 12/6/88 2/1/88 3/7/88 4/4/88 Check No. 7826 15097 15124 1538 15163 15190 15192 15230 15256 15292 15321 15342 15366 15376 166 1987 Total: 1001 1016 1020 1035 1040 1048 1062 1066 1080 1087 7846 7872 7889 7897 7912 7920 7941 7956 7980 7989 15423 15443 15460 Amount $ 18.57 $ 41.99 $ 72.49 $ 81.82 $ 22.79 $ 14.67 $ 21.41 $101.79 $ 75.71 $ 10.37 $ 35.84 $ 15.88 $ 62.99 $ 27.23 $ 8.43 $2,135.65 $101.21 $ 15.85 $ 21.95 $ 7.83 $ 5.94 $ 2.48 $ 71.71 $129.72 $ 14.87 $ 77.37 $ 26.15 $ 36.36 $ 53.51 $ 12.52 $ 68.45 $ 7.23 $172.88 $ 52.84 $ 77.67 $ 50.54 $ 81.12 $ 26.95 $ 3.69 Mr. Charles Astolos Page 8 Year Date Check No. Amount 5/3/88 15488 $ 2.57 6/7/88 15503 $ 14.07 7/12/88 15535 $ 39.95 8/2/88 15557 $ 39.52 9/13/88 15577 $ 36.13 10/4/88 15597 $ 50.24 11/9/88 15640 $ 47.02 12/6/88 15658 $ 56.58 1988 total: $1,404.92 5. Total expenditures made by Saltsburg Borough regarding purchases from Saltsburg Supply Company, Incorporated were as follows: Year Amount 1983 $1,111.38 1984 $1,764.83 1985 $1,507.61 1986 $1,290.87 1987 $2,135.65 1988 $1,404.92 Total: $9,215.26 6. Minutes of the meetings of the Saltsburg Borough Council indicate the following information in relation to the instant situation: a. January 3, 1984 - Charles Astolos began serving on council. b. February 6, 1984 - Committees were appointed. Astolos was appointed chairman of the Water /Sewage Committee and a member of the Finance Committee. Water /Sewage Committee reported on repairing fire hydrants, finding Keystone paint /water leak, sealing water meters and fixing frozen water line at the borough office. Present: Kelly, Stramaski, Wagner, Astolos, Brown and Jahenta. Mr. Charles Astolos Page 9 Absents Clawson. c. January 6, 1986 - President Kelly read the resignation of Harry Brown as councilman. Motion by Astolos to appoint John Johnson to fill one vacancy on council, seconded by Stramaski. Motion carried. President Kelly partially set up committees as follows: Water /sewage - Astolos, chairman and Wagner. Water /Sewage Committee reported on replacing fire hydrant and read water meters and tearing down and rebuilding raw sewage pump. Present: Kelly, Wagner, Stramaski, Clawson, Astolos. d. February 3, 1986 - Addition to committees: Water /sewage - Clawson. Finance - Kelly, Chairman and Astolos. Housing Code - Johnson, Chairman and Wagner and Astolos. Water /Sewage Committee reported on changing meters and serving pump and air blower. Letter sent to L.M.C. to finalize payment. Present: Kelly, Wagner, Astolos, Clawson, Stramaski, Johnson. e. September 12, 1988 - In closing business, Astolos informed council that the approved budget of $1,000 allotted to Saltsburg Supply was almost at the limit. Council approved $500 for the remainder of the year on a motion by McDivitt, seconded by Corradini. (No abstentions or no votes recorded). Bills: Borough account, $36.14 - Saltsburg Supply. Water Account, $172.88 Saltsburg Supply, sewage account, $71.71, Saltsburg Supply. Present: Kelly, Astolos, Corradini, Cribbs, McDivitt, Wagner. f. October 3, 1988 - In other business, Mayor Closson stated that he had received a letter of resignation from Chief Lowers. Bills: Borough account - $50.24, Saltsburg Supply. Water account - $52.84, Saltsburg Supply. Sewer account - $129.72, Saltsburg Supply. Mr. Charles Astolos Page 10 December 5, 1988 - Kelly read a letter of resignation from Charles J. Astolos resigning his position as council. Motion to accept Astolos' resignation with deep regret was made by McDivitt, seconded by Wagner. Motion carried. A discussion followed on a possible replacement to fill the unexpired term of one year. Astolos made a motion that council appoint F. Daniel McGregor, seconded by Wagner, motion carried. h. Bills: Borough account - $4.96 and $51.62, Saltsburg Supply. Water Account - $31.56, $6.98, $12.00, Saltsburg Supply. Sewer Account - $53.48, $23.89, Saltsburg Supply. Present: Kelly, Astolos, Corradini, Cribbs, Dice, McDivitt, Wagner. 7. Robert McKnight provided the following information in relation to the instant situation: a. He has been employed by Saltsburg Borough for eleven years. He was in charge of a number of areas of borough operations in his capacity as superintendent. b. These duties included everything regarding water, streets, and sewer operations. c. He was responsible to the Chairman of the Streets Committee, Water and Sewer Committees, and the President of Borough Council. d. The Chairman of the Water and Sewer Committees was Charles Astolos. He was in this position for approximately four years. e. Mr. Astolos performed many duties for the borough while he was on council. f. Prior to the opening of Saltsburg Supply Company, there was another hardware store in the borough, J. C. Moore. At that time, the borough did most of its business with this entity. After this store was destroyed by a fire, the borough began dealing with Saltsburg Supply Company. g. g. Present: Kelly, Astolos, Corradini, Cribbs, Dice, McDivitt, and Wagner. MX. Charles Astolos Page 11 h. McKnight completes most of the purchasing for the Water, Street and Sewer Departments. i. •In making such purchases, he considers utilization of borough vehicles (the wear and tear on such vehicles), and the cost of the items purchased. Saltsburg Supply Company is competitive on some items and is higher on other items. k. Some purchases are made from Wilson's True Value Hardware store which is approximately three miles outside of the borough. McKnight was never told by Astolos that he had to purchase supplies from Saltsburg Supply Company. He was told to shop around for the best price. 1 1. Saltsburg Supply Company has a better stock of materials than Wilson's. m. Saltsburg Supply Company did not provide a discount to the borough. n. When he initially started to serve on council, Astolos would sign purchase orders regarding materials supplied by Saltsburg Supply Company. Sometime thereafter, this practice stopped. 8. You provided the following information in relation to the instant situation: a. You served as a Saltsburg Borough Councilmember from 1984 through 1988. b. You were originally appointed to fill a vacancy and were, thereafter, elected to the position. c. You were Chairman of the Borough Sewer and Water Committee. d. You resigned your position with Borough Council in December, 1988. e. You resigned because there was no compensation attached to the position and there were too many demands on your personal life. Your resignation is also attributable to your wife's illness, your lack of time to continue on council and lost revenues at your store because of council business. f. You are the President of Saltsburg Supply Company, Incorporated. It is a general hardware business. This Mr. Charles Astolos Page 12 The business was originally a partnership between your wife and yourself. This operation was originally opened in February, 1982. h. The closest competitor is Wilson's True Value Hardware store which carries comparable merchandise and is about four miles outside of town. g. i. Generally, purchase orders require two signatures: yours as Chairman of the Water and Sewer Committee and the President of Borough Council. Your store does not give discounts to municipal clients. The borough began purchasing from your store as soon as it was opened and prior to your term on borough council. There was no formal or informal agreement between the borough and your company. Corporation consists of your wife, yourself and your two children. k. Previous to the opening of your store, there was another hardware store which burned down. 1. No questions were ever raised regarding your ownership of the hardware business and your service on the borough Sewer and Water Committees. You assumed that you were serving on this committee in light of your knowledge as a machinist, electrician and plumber. m. You never directed the Superintendent of Public Works, Robert McKnight, to purchase items from your store. McKnight was free to purchase supplies from wherever he wanted. n. During your first years in service on council, you did vote on the payment of monthly bills. More recently, you have abstained. o. You did not vocally abstain from said nothing when the votes were not reflect votes, only that the p. It never occurred to you to have minutes. these votes, you merely taken. Borough minutes do motion. carried. abstentions recorded in the q. Borough council imposed a $1,000 limit on purchases of supplies from your company. This was done because of your ownership in the store. Mr. Charles Astolos Page 13 r. In September of 1988, when a vote to increase the budget allotted to Saltsburg Supply was taken, you did not vocally abstain, you just did not say anything on the vote. II. Allegation: That you, a Councilman for Saltsburg Borough, Indiana County, violated the following provisions of the Ethics Act (Act 170 of 1978), when you failed to file a Statement of Financial Interests for the 1985 calendar year by the May 1, 1986 deadline: Section 4. Statement of financial interests required to be filed. (a) Each public employee employed by the Commonwealth shall file a statement of financial interests for the preceding calendar year with the department, agency or bureau in which he is employed no later than May 1, of each year that he holds such a position and of the year after he leaves such a position. Any other public employee shall file a statement of financial interests with the governing authority of the political subdivision by which he is employed no later than May 1 of each year that he holds such a position and of the year after he leaves such a position. 65 P.S. §404(a). (b) Each candidate for public office shall file a statement of financial interests for the preceding calendar year with the Commission prior to filing a petition to appear on the ballot for election as a public official. A petition to appear on the ballot shall not be accepted by an election official unless the petition includes an affidavit that the candidate has filed the required statement of financial interests with the commission. 65 P.S. 9404(b). 9. Findings 1 -9 are in incorporated herein by reference. 10. Statements of Financial Interests on file for you with Saltsburg Borough indicate the following information: a. Filing date: 8/4/79. Source of Income: Allegheny Ludlum Steel Corporation. Office, directorship or employment in any business: residential rentals, co- owner. Financial Interests in any legal entity in business for profit: co -owner with spouse in residential rental units. Creditors: First National Bank of Avonmore, 8 %; Savings and Mr. Charles Astolos Page 14 Trust Company, 9 3/4 %; National Bank of the Commonwealth, 10.46 %. Chrysler. Credit Corporation, 10.25 %. All other financial interest categories: none. b. Filing date: 7/8/81. Source of Income: Allegheny Ludlum Steel Corporation. Office or Directorship: Residential rentals, co- owner. Financial interest in any legal entity in business for profit: co -owner with spouse in residential rental units. Creditors: Savings and Trust Company, 9 3/4 %; National Bank of the Commonwealth 10.46 %. c. Filing date: 4/12/84 for the year 1983. Source of Income: Residential rentals and Saltsburg Supply Company. Office or directorship: Saltsburg Supply Company - owner. Financial interest in any legal entity in business for profit: Saltsburg Supply Company. Creditors: Savings and Trust Company, 14.5 %; Savings and Trust Company, 17.55 %, Savings and Trust Company 13.25 %. All other financial interests categories: none. d. Filing date: 3/11/85 for the year (left blank). Source of Income: Rental properties, Saltsburg Supply Company. Office or directorship in any business: none. Financial Interests in any legal entity in business for profit: 14.5 %, Savings and Trust Company, 13.25 %, Savings and Trust Company, 10.5 %. All other financial interests categories: none. e. Filing date: March 18, 1986 for the year 1985. Source of Income: Saltsburg Supply Company and rental properties. Office or Directorship or employment in any business: none. Financial interests in any legal entity in business for profit: Saltsburg Supply Company - owner. Creditors: Savings and Trust Company of Pennsylvania, 14.5 %, Savings and Trust Company of Pennsylvania, 13.25 %; Savings and Trust Company of Pennsylvania, 9.75 %. All other financial interest categories: none.* f. Filing date: April 20, 1987 for the year 1986. Source of Income: Rental properties and Saltsburg Supply Company. Financial interest in legal entity in business for profit: Saltsburg Supply Company - co- owner. Mr. Charles Astoloa Page 15 g. Creditors: Savings and Trust Company of Pennsylvania, 14.5 %, Savings and Trust Company of Pennsylvania, 13.25 %. Savings and Trust Company of Pennsylvania, 8.5 %. All other financial interest categories: none. Filing date: April 19, 1988 for the year 1987. Source of Income: Saltsburg Supply Company Incorporated and rental properties. Office or directorship or employment in any business: Saltsburg Supply Company, Incorporated, President. Financial interests in any legal entity in any business for profit: Saltsburg Supply Company Incorporated. Creditors: Savings and Trust Company of Pennsylvania, 14.5 %, Savings and Trust Company of Pennsylvania, 13.25 %. All other financial interest categories: none. 11. The filings for 1986 through 1988 were completed on forms SEC -1: Rev. 1/87 (Finding 10 e-g). a. State Ethics Commission filing form SEC -1 Rev. 1/87 was not printed until December, 1986. b. Form SEC -1 Rev. 1/87 was forwarded by the State Ethics Commission to municipal governmental entries in January, 1987. c. The form used for your filing noted in 10 (e) above was not available on the date that it was allegedly filed in that said form had not yet been printed. d. You initially denied the above but then added that you do not remember how or why such a document would have been endorsed by you and you have no explanation for this matter. 12. You provided the following information in relation to this situations a. You believed that you filed Statements of Financial Interests in every year that you served. You acknowledged that the statement dated March 18, 1986 was in fact by you and contained your signature. b. You believe that you filed this form on or about the date that it was signed. You do not recall any specific factors regarding filing of this statement. B. Discussion: Mr. Charles Astolos Page 16 As the councilman for Saltsburgh Borough, you were a public official as that term is defined under the Ethics Act and Regulations of this Commission. 65 P.S. $402; 51 Pa. Code 1.1. As such, you are subject to the provisions of the Ethics Act and the restrictions therein are applicable to you. /�nitiaily, it is noted that Section 5 of Act 9 of June 26, 1989 provides, in part, as follows: "This amendatory act shall not apply to violations committed prior to the effective date of this act, and causes of action initiated for such violations shall be governed by the prior law, which is continued in effect for that purpose as if this act were not in force. For the purposes of this section, a violation was committed prior to the effective date of this act if any elements of the violation occurred prior thereto." Since the occurrences in this case transpired prior to the effective date of Act 9 (June 26, 1989), we must apply the provisions of Act 170 of October 4, 1978, P.L. 883 to determine whether the Ethics Act was violated. Under Section 3(a) quoted above, this Commission has determined that use of office by a public official to obtain a financial gain for himself or a member of his immediate family or a business with which he is associated which is not provided for in law transgresses the above provision of law. Thus, use of office by a public official to obtain a financial gain which is not authorized as part of his compensation is prohibited by Section 3(a): Hoak /McCutcheon, Orders No. 128, 129, affirmed McCutcheon V. State Ethics Commission, 77 Pa. Commw. Ct. 529, - A.2d (1983); Yacobet, Order No. 412 -R, affirmed Yacobet v. State Ethics Commission, 109 Pa. Commw. Ct. 432, 531 A.2d 536 (1987). Similarly, Section 3(a) of the Ethics Act would prohibit a public official /employee from using public office to advance his own interest; Koslow, Order 458 -R, affirmed Koslow v. State Ethics Commission, Pa. Commw. Ct. , 540 A.2d 1374 (1988). Likewise, a public official /employee may not use the status or position of public office for his own personal advantage; Huff, Opinion 84 -015. Additionally under section 3(c) of the Ethics Act quoted above, this provision of law provides, in part, that no public official shall enter into a contract valued at $500 or more with this governmental body unless the contract was awarded through an open and public process. In the instant matter, you served on Saltsburg Borough Council between 1984 and 1988. During that period of time, Saltsburg Supply Mr. Charles Astolos Page 19 The files in this case will remain confidential in accordance with Section 8(a) of the Ethics Act, 65 P.S. 408(a) during the fifteen day period and no one, including yourself, unless the right to challenge this Order is waived, may violate confidentiality by releasing, discussing or circulating this Order. However, confidentiality does not preclude you from discussing this case with your attorney at law. Any person who violates confidentiality of a Commission proceeding is guilty of a misdemeanor and shall be fined not more than $1,000 or imprisoned for not more than one year or both, 65 P.S. 409(e). By t - Commissio elena G. Hughes Chair 4 11