Loading...
HomeMy WebLinkAbout554-R HagenMr. Gerald Hagen c/o George C. Mahfood Rosen & Mahfood 628 Grant Building Pittsburgh, PA 15219 Re: 86 -122 -C A. Findings: • STATE ETHICS COMMISSION :3Q8 P :NANCE BUIL,PING HARRIS gIJRG, PENNSYLVANIA 17120 ORDER OF THE COMMISSION Order No. 44..R DATE DECIDED: June 10 1988 DATE MAILED: June 24, X988 Dear Mr. Hagen: The State Ethics Commission has received a complaint regarding you and a possible violation of Act 170 of 1978. The Commission has now completed its investigation. The individual allegations, conclusions, and findings on which those conclusions are based are as follows: I. Allegation: That you, the President of North Huntingdon Township Board of Commissioners, violated Section 3(a) of the State Ethics Act which prohibits a public employee's or public official's use of office or confidential information gainri through that office to obtain financial gain by being reimbursed for attending conventions when you did not actually attend those conventions. 1. You have served as an slected commissioner of North Huntingdon Township, a first class township, 'since at lsast 1980. 2. Review of records on file with the township confirms that the township has authorized the attendance by commissioners at annual and semi - annual conventions of various municipal government associations. a. This practice has been in effect during your term as township commissioner. 3. Records obtained from North Huntingdon Township disclosed that payments were made on your behalf to attend the annual convention of the Pennsylvan :a. State Association of Township Commissioners (PSATC) held from J ar,e 15, 1980 to Jt!ile 18, 1980 at the Downingtown Inn. a You received from the township 4=. Gerald r-pgen Pace Commissioner: (PST"' from June 15, 198n to ,.7rne 18, 1980 at the Downingtown Inn._ a. You received fro._a the "Lc aship $300.00 - per diem $75.00 x 4 days 86.70 - mileage 510 miles x 17b /mile 11.10 - tolls $397.80 40.00 - Registration $437.80 b. : costs $36.00 per day, per person based on dor "le occupancy. These costs included overnight Eccom and three meals a day beginning on day cf arrival and concluding with lunch the day of departure, plus taxes. Single occupancy rates were $46.0 per day, per person. . "'oar actual expenses: $276.86 - hotel bl.w.'. includes r'ami�y ) 86.70 - mileage 11.10 - tolls $374.66 d. Actual reimbursable expenses: $374.46 78.00 - Difference between Jitigle and double $296.66 rates x 3 days e. You agree that you were over paid by $141.14 for attending this convention. (1) Registrations are to be included as part of per diem expenses. 4. Township records disclosed that you attended the 1981 annual conference of the Allegheny League of Municipalities (ALOM) from April 2, 1981 to April 5, 1981. Payments made to you and actual expenses are : a. You received from the township:. $140.00 - per diem, $35,00 x 4 days 13.60 - mileage $153,60 Mr. Gerald Hagen Page 3 _ b. Allowable expenses: $136.50 - per diem 13.60 - mileage $150.10 c. You agree that you were overpaid by $2.50. 5. Township records disclosed that you attended the annual PSATC Convention held from June 28, 1981 to July 1, 1981 at Tamiment Resort in the Poconos. Payments made to you and expenses were: a. You received from the township: $300.00 - per diem $75.00 x 4 days 122.40 - mileage 720 x 17 /mi $422.40 60.00 - Registration $482.40 b. Per diem costs were listed at $65.34 /day single roam rates. c. Reimbursable expenses $196.02 - $65.34 x 3 days 122.40 - mileage 2.06 - misc. $320.48 J. You agree that you were overpaid by $161.92 for attending this conference. (1) Registrations are to be paid from per diem expenses. 6. You attended the 1982 ALOM Conference held from April 1, 1982 through April 4, 1982 at Seven Springs Resort. Payments made to you and actual expenses were: a. Yoc received from the township: $240.00 - per diem $60-.00 x 4 days _ 13.60 - mileage 80 x 1n/mi $253.60 Actual expenses Mr. Gera Pc s- 4 $313.00 - hote °,i11, includes family 13.60 - mileage $323.60 c. You were only entitled to the single room rate at 63% of the actual bill ($310.00 x .65) or $201.50. d. Reimbursable expenses computed at $201.50 - room and board 13.60 - mileage $215.10 e. You agree that you were overpaid by $38.50 for attending this conference. 7. You attended the 1983 annual convention of the PSATC held from June 26, 1983 through June 29, 1983 at Tamiment in the Poconoc,. Payments made to you and expenses were: a. You received from the township: $ 20.00 - Registration 300.00 - Per diem $75.00 x 4 days 158.40 - mileage 120 x 22s /mi. $478.40 b. Room rates were $72.60 /day, meals included based on single occupancy. c. Reimbursable expenses computed as: $217.80 - 72.60 x 3 days 158.40 - mileage $376.20 d. You agree that you were overpaid a total of $102.20. This includes per diem and registration. 8. Records confirm that you attended the 1984 ALCM conference held from April 5, 1984 through April 8, 1984 at Seven Springs Resort. Payments made to you and actual expenses were: a. You received from the township: $360.00 - per diem $90.00 x 4 days 17.60 - mileage 80 x 22t mi. $377.60 Mr. Gerald 7 Page 5 b. ie townshir also paid .c.gistrat on in the amount d. $110.00. c. Ycur actual reimbursable expenses: $52.80 - mileage $17.60 /day x 3 days 3.30 - tolls 35.00 - meals $91.10 d. You commuted to the conference on a daily basis. e. You admit that you were overpaid by 286.50 for expenses. 9. Memo dated April 19, 1984 to Mary McKay, North Huntingdon Township Secretary, from you states that you are in the process of transmitting exact expenses for the ALOM held at Seven Springs on April 5, 1984 to April 8, 1984, and as soon as expenses are completed, you will submit them along with a personal check refunding and all expense money not used. a. No receipts were ever submitted or money returned. 10, Records confirm that you attended the 1984 fall convention of the Allegheny County and Western PA Association of Township Commissi.)ners from September 27, 1984 through September 30 1984 at Seven Springs Resort. Payments made to you and expenses were: a. You received from the township: $360.00 - per diem $90.00 x 4 days 17.60 - mileage 80 mi x 22 /mi $377.60 h, Reimbursable expenses: $ 70.40 - mileage $17.60 per day x 4 days 140.00 - Compensation $35.00 /day x 4, per section $210.40 §55611 Township Code c. You admit that you did not stay at the hotel and that you commuted to the conference on a daily basis. d. You admit that you were overpaid by $16e.20 for expenses. Mr. Gerald Paje 6 - 11. You did not submit an: receiptb to North Huntingdon Township for expenses occurred although the township records disclose AC & WPATC forms certifying that you were in attendance and entitled to full remuneration. This was a blank form which was signed by Matt Mathews and was completed by you - claimed as remuneration was the amount of $377.60. 12. Records confirm that you attended the 1985 conference of the AT held from April 11, 1985 to April 14, 1985 at Seven Springs Resort. Payment made to you and expenses were: a. Your received from the township: $360.00 - per diem $90.00 x 4 days 17.60 - mileage 80 x 2n/raj. $377.60 Conference registration paid by township $125.00, Reimbursable expenses: $70.40 - mileage 320 x 22b /mi (4 days) 50.00 - meals $120.40 d. You do not recall staying at the hotel, but believe you commuted on a daily basis. e. You agree that you were over -paid by $257.20 for expenses. 13. Township records disclose reservations and payments made the 1985 PSATC conference held 1985 at Split Rock Lodge, Lake the following registration, to you or on your behalf to attend from June 16, 1985 to June 19, Harmony. a, Conference registration paid by the township - $60.00 b. Room reservation for you, your wife and children in an amount of $61.00 paid by the township. (Deducted from per diem) c. You received from the township: $360.00 - per diem $90.00 x 4 days 132.00 - mileage 600 x 220/mi $492.00 Mr. Gerald Hager Page 7 _ Costs for attending were $80.00 per day single occupancy. e. - Reimbursable expenses: $240.00 - $80.00 x 3 days 132.00 - mileage $372.00 f. You agree that you were overpaid by $180.00 for expenses. This includes $120.00 per diem and $60.00 registration. 14. You furnished to a State Ethics Commission investigator a copy of a guest bill from Split Rock Lodge bearing your name. a. The bill is for the period beginning June 16, 1985. b. The daily rate is computed as $137.00 (61.00 x 2 adults = $122.00 + $15.00 child rate =- $137.00) c. $350.00 total balance paid by Visa on June 19, 1985. d. Monthly credit card bill listing charge of $350.00 to Vacation Charters Lt.,Lake Harmony, PA on June 17, 1985. (1) Credit card bill listing Receipt No. 5788297 dated June 17, 1985 showing $350.00 charge to Split Rock Lodge. 15. Township records disclose the following reservations, registration and payments made to you or on your behalf to attend the 1986 . Spring ALOM conference held from April 3, 1986 through April 6, 1986 at Seven Springs Resort. a, Conference registration $140.00 b. You received from the township: $360.00 - per diem $90.00 x 4 days 17.60 - mileage 80 -x 22O /mi $377.60 Reimbursable expenses Mr. emerald Hag , Page 8 _ - rorx - Tccupancy rate 17.60 -- mileage $281.60 d. You agree that you were overpaid $96.00 .fc expenses, 16. Township records disclosed the following reservations, registrations and payments made to you or on your behalf to attend the 1984 annual conference of the PSATC held from June 24, 1. through June 27, 1984 at Mount Airy Lodge, Mt. Pocono, PA7 e. Registration $70.00 b. roil received from the township: $300.00 - per diem $75,3) x 4 days 145.20 - mileage 660 x 2n/mi $445.20 c Single occupancy rates were $75.00 /day d. Reimbursable expenses $300.00 - room & meals and registration 145.00 $445.00 e. You agree that you were overpaid $70 -0) or the registration costs. 17. You have also attended various (tally conferences and dinner meetings for which you received expense reimbursements, These include : a. May 2, 1985 AC & WPATC Spring Dinner Meeting (1) $90.00 - per diem 4.40 - mileage $94.40 (2) Reimbursable expenses $35.00 - dinner costs 4.40 - mileage $39.40 Mr. Gerald Hagen Page 9 b. September 14, 1985 Westmoreland County Boroughs Association Meeting. (1) $10.00 - registration 90.00 - per diem 4.40 - mileage $104.40 18. Excerpts from North Huntingdon Township Solicitor Thomas Cole's work log disclosed the following regarding per diem payments to township commissioners: a. May 7, 1984 - Met with Commissioner Hagen re: conferences and $90.00 - /day etc. Write for an opinion from John Means, need definitive guide. $90.10 per diem, entitled to $90.00 on May 10, 1984 conferencI, Mary (Township Secretary Mary McKay) called Elizabeth Township, township pays registration which included dinner and mileage: In re: Letter to John Means, per diem, Commissioner Hagen did not like wording, different wording - general guidelines, how much documentation - I can reword letter. August 22, 1984 - Telephone discussion with Mary McKay re: $90.00 per diem payments to Commissioners Beeler and Ludwicki. Mathews (Matt Mathews, ALOM) contacted and no one uses the $90.00 unless for a day, i.e. lost wages. McKay to discuss with Beeler and Ludwicki, c. April ), 1985 - Attendance at seminars, conferences, schools, etc., as authorized by board or in the budget shall be paid for by the township including but not limited to registration gees and mileage; covers elected or appointed township officers and employees. (3) You agree that you were overpaid $55.00 expense: reimbursement. (2) Reimbursable expenses $35.00 - compensation 4.40 - mileage 49.40 (3) You agree that you were overpaid $55.00 per diem expenses. Mr. Gerald I: o en Page 10 _ Actual expenses up to $90.00iday for elected and appointed officials - discussion as to problem of language in the code. 19. The following correspondence was obtained from Solicitor Coles regarding the per diem payments: a. May 29, 1984, letter from Coles to John Means, Legal Counsel to the PSATC, requesting general guidelines as to how much of the $90.00 per diem must be documented through invoices, receipts and statements, or is $90.00 simply a per diem that need not be documented b. June 1, 1984, reply to Coles from Means which notes three. Sections of the First Class Township Code concerning the per diem. Section 611, County Association Conferences $35.00 /day plus mileage, no receipts needed. Section 622, State Conventions, not to exceed $75.00 /day plus mileage, plus registration fees, only actual expenses are collectible and receipts should be kept as proof. Section 624 Conference and Schools, actual expenses up to $90.00 /day plus mileage and registration. Only actual expenses are collectible and receipts should be kept. Section 611 and 624 should be read pri-matera. c. June 4, 1984 Coles to the North Huntingdon Township Commissioners endorsing the Means letter June 1, 1984 d. May 20, 1986, Coles letter to North Huntingdon Township Manager Robert Arch regarding the per diem allowance. Coles opined that no rules, decision, etc. could be found that indicate a commissioner has to return any portion of the $90.00 if the actual cost is less than $90.00. Coles stated that each conference must be evaluated separately and that the law was clear that a Commissioner cannot receive any compensation other then the salary he receives by law. It would be improper for a Commissioner to "make" money as the result of attending a conference, seminar or meeting. e. May 21, 1986, Coles letter to Arch amending the May 20 1986 letter by stating that-the $90.00_per day is also applicable to day conferences where overnight stay is required. 20. Township minutes confirm that on May 8, 1935 the North Huntingdon Township Commissioners passed Resolution No. 117 of Mr. Gerald Hager Page 11 _ 1985 involving expenditures for attending conferences, etc. You are recorded as voting in favor of the Resolution which states in part: a. The current law with reference to conferences, institutes and schools of elected . or appointed township officers and employees and which such expenses are hereby fixed at Ninety and 00 /100 ($90.00) dollars per day; and b. In addition to the provision contained in No. 1- the current law provides for the payment by the Township of North Huntingdon of the registration fee and mileage going to and returning from conferences, institutes and schools; and c. Both the Ninety and 00 /100 ($90.00) per day and the registration fee and mileage shall be paid by the Township of North Huntingdon by the Township Secretary when authorized by the board of commissioners of the Township of North Huntingdon to attend conferences, institutes and schools; and d. Once approved, the payment of the ninety and no /100 ($90.00) dollars and the payment of the registration fee and mileage reimbursement shall be made automatically and forthwith by the township secretary; and e. Those who attend conferences, institutes and schools shall return to the township secretary the proof of attendance form duly executed by an authorized person of the conference, institute or school, and in the absence of a proof of attendance form duly executed and returned to the township secretary, the individual may present actual vouchers and receipts as proof of attendance at the conference, institute or school. 21- The North Huntingdon Township Auditors in annual reports for Lhe years 1982, 1983 and 1984 stated that all expenditures should be documented and receipts kept on file. 4, You stated that you were not aware of that recommendation, but that you normally turned in whatever documentation was required. 22, You p::oviued the following information to a State Ethics Commission investigator: y1r. Gerald Aagen ?age 12 a. On the dates when you were working at your profession as a teacher, it would be possible for you to teach on the first day of a convention, normally a Thursday, and then go to the convention, which did not usually start until 4:00 p.m., on the first day. You said that first business session would not start until 9:00 p.m. - b. You denied that you ever were aware that documentation for expenditures was required. c. You admitted to sending the April 19, 1984 memo to Mary McKay (Finding No. 9). You also stated that you did not stay at the convention and that you intended to return to the township money not used, but you were convinced by your associates, not to do so. d. You could not recall ever seeing the letter from John Means. Discussion: As a township commissioner in a.township of the first class, you are clearly a public official as that term is defined in the State Ethics Act. 65 P.S. §402. As such, your cond•ct must conform to the requirements of the State Ethics Act and the restricted activities of that law apply to you. See Hanlon, Order 400 -R. The State Ethics Act provides as follows: Section 3(a) of the Ethics Act provides: 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). This Commission, in the past, has reviewed the above provision of law specifically in relation to the of expense allowances in relation to certain public officials and the retention of excess funds relating to such expense allowance Generally, in reviewing the county code provisions in relation expense allotments for officials who attond the annual meeting Mr. Gerald Hagen. Page 13 of the State Association of County Officials, this Commission specifically determined that such officials were only entitled to receive their expense allowances as actually incurred up to end not exceeding certain per diem amounts for attendance at such meetings. The Commission made this determination based upon a specific review of the county code provisions allocating such expense allowances and under the provisions of the State Ethics Act applied thereto. The Commission further determined that any funds in excess of this amount, received and retained by said officials through their official positions, would constitute financial gain other than the compensation provided for by law and, thus be a violation of Section 3(a) of the State Ethics Act. See Bigler, Opinion 85 -020. Specifically, the Commission determined that because the municipal code only permitted expense reimbursements for actual expenses or within a certain dollar amount, funds requested and received in excess of the permitted expenditure through the public official's office and retained by said public official would constitute a financial gain other than the compensation provided by law. Public officials who, through their public positions, receive and retain excess funds would thus be in violation of Section 3(a) of the State Ethics Act. The foregoing analysis was reaffirmed in Hawkins, Order 368. IA Hawkins, supra, this Commission determined that a county sheriff had violated Section 3(a) of the State Ethics Act when, through his position, he requested and received expense allowances for attendance at a state sheriff's convention in excess of that which was permitted by the code. Specifically, the county sheriff received certain funds even though he had not attended the convention. Additionally, he had received funds in excess of that specifically allowed by the county code. Similarly, it was determined that a county official would not be permitted to receive reimbursement for attending a convention of the official's organization if such individual did not, in fact, attend. See Shultz, Order 369. This Commission's analysis in all of these cases was based upon long standing judicial interpretation of these provisions of law. See Bechak v. Corak, 414 Pa. 522, 201 A.2d 213, (1964); Susquehanna County Auditor's Report, 118 Pa. Super 47, 180 A. 148, (1935); Walker v. Somerset County, 26 D & C 2d 775, (1961). In the instant situation, in order to determine whether Section 3(a) of the Ethics Act has been implicated through the activity as outlined in the findings of fact, it is necessary to first review what compensation in the form of expense allowances is permitted by the First Class Township Code as then enacted. Kr- Gera..d hagEn Page 14 Baser. upon a determination as to wha':, compensation is permitted, this Commission will then be able to determine if you, through your public position, obtained financial gain in the form of excess expense allowances when such was not provided for by law as part of your compensation. The First Class Township Code, which was applicable for the period of time in issue, generally set forth three separate and distinct categories of expense authorizations in relation to conferences, schools, seminars and conventions. Initially, the township code provided for the establishment of county associations of township officers. Such associations are mandated to hold annual conventions or semi - annual or quarterly_ conventions, conferences, institutes or schools. 53 P.S. §55610. Township commissioners authorized to attend such conventions of the county associations are permitted reimbursement on a per diem basis. The township code, in this respect, provided as follows: Membership of associations; expenses of members The township commissioners and other officers of the township designated by the township commissioners shall attend such conventions, conferences, institutes or schools whenever possible. Each township officer attending such convention, conference, institute or school shall receive a certificate, signed by the presiding officer and a secretary or acting secretary of the association, attesting his presence at the convention, conference, institute, or school. Such certificate shall entitle him to collect from the township treasurer the sum of thirty -five dollars per day for each day's attendance and mileage at the rate of twelve cents per mile traveled, to be computed by the route usually traveled from his place of residence to the place where the convention, conference, institute or school is held. No township officer shall be paid for more than seven day's attendance ih any one year. The expenses of holding any such convention shall be paid pro rata by the townships joining therein. 53 P.S. §55611, Mr. Gerald Hagen Page 15 - In addition to the foregoing, the township code also provides for the formation of a state association of township commissioners. The association is mandated to hold annual meetings within the Commonwealth of Pennsylvania which township commissioners may attend.- The expense allowances for commissioners so attending were provided for as follows;; Expenses of delegates paid by townships Each delegate and other officer attending the annual meeting of the State association shall be allowed for his expenses incurred in attending the meeting, not to exceed ninety dollars per day for not more than four days including the time employed in traveling thereto and therefrom, together with mileage going to and returning from the meeting. These expenses shall be paid by the respective townships. 53 P.S. §55622. I�. should be noted that the prior per diem expense all tient, as noted above, was previously fixed at $50 per diem and O a later time, increased to $75 per diem, prior to the most recer..t allotment. Finally, the First Class Township Code provided that township officials may attend other conferences, institutes and schools aid be allocated expenses for attending such schools and conferenc ;, as follows: Ccnferences, Institutes and schools Tie actual expenses for attending the conferences, institutes and schools of elected or appointed township officers and employes, which shall be limited to ninety dollars ($90) per day, plus the registration fee and mileage going to and returning from such meetings, may be paid by the township when authorized by the board of township commissioners to attend conferences, i-lstitutes and schools in order to discuss and resolve the various questions arising in the discharge of the duties and functions of the respective officers and employes, and to provide uniform, efficient and economical methods of administeving t Eeir township duties. 53 P.S. §55 "A. Mr. Geca " Hag - Page 16 Once again, it should be noted that the actual per diem allotment, as set forth in the above provision of law, was originally fixed at $20 and later raised in 1974 to $35, in 1982 to $60 and finally in 1984 to $90 as enumerated above. Although not relevant for the time period here in issue, the above three provisions of the First Class Township Code have `eon amended by Act 8 of 1988 wherein under the current law, the Commissioners are entitled to basically the registration fep mileage and actual expenses for which an itemized accountirg at.st be submitted. In applying the above provisions of the township code,'_ °..3 clear,and you do not dispute the fact, that you have receive" excess reimbursements above that which is provided by law. Tila total amount of the excess funds is $1,613.16. Based upon a review of all of the foregoing, you violated the State Ethics Act when you, as a township commissioner, requested from the township, expense payments for participating and attending conferences in excess of that to which you were entitled. Additionally, it must be noted that you have exhibited through your conduct, a pattern of activity wherein you consistently have requested funds in excess of that to which 1ou were entitled. You have used township funds which are to be allocated only for official purposes for benefits that included reservations for your wife and expense allotments that included payments for items of your immediate family members. Clearly the use of township funds for this purpose is in violation of the State Ethics Act. Generally, the State Ethics Act provides as follows: Section 9. Penalties. (a) Any person who violates the provisions of Section 3(a) and 3(b) is guilty of a felony and shall be fined not more than $10,000 or imprisoned for not more than five years, or be both fined and imprisoned. 65 P.S. Section 409(a). The Act further provides: (c) Any person who obtains financial gain from violating any provision of this act, in addition to any other penalty provided by Mr. Gerald Hagen Page 17 law; shall pay into the State Treasury a sum of money equal to three times the financial gain resulting from such violation. 65 P.S. Section 409(c). The State Ethics Commission also has the authority to make an affirmative recommendation to an appropriate law enforcement authority for the initiation of criminal charges pursuant to tree above provision of law or for the dismissal of charges pending upon factual circumstances. This Commission has also been granted the authority to offer the opportunity to an individual who has obtained financial gain as a result of a violation of the. State Ethics Act the opportunity to divest himself of said gain. See McCutcheon -P. State Ethics Commisson, 77 Pa. Commw. Ct. 529, 466 A.2d 283 (1983). See also Yocabet v. State Ethics Commission, Pa. Co-mw. Ct. , 531 A.2d 536 (1987). The Commission has, on a numaer of occasions, offered individuals the opportunity to divest themselves of the gain received and thereafter, recommended no further criminal action. Your financial gain which was not provided by law in the instant situation equals the combines: amount of excess expense allotments that you received. This amount totals $1,613.16. Based upon all of the foregoing, you must return to North Huntingdon Township the amount of excess expense allotments which you received. You must, within thirty days of the date of this order, remit payment to the State Ethics Commission made payable to North Huntingdon Township; otherwise this matter will be referred to the appropriate law enforcement agency for further review and appropriate action. C. Conclusion and Order: 1. As a commissioner for North Huntingdon Township, you are a "public official" subject to the provisions of the Ethics Act. 2, You violated Section 3(a) of the State Ethics Act when you, as a township commissioner, requested, received and retained township funds for attendance at various conventions, conferences and schools in excess of that which was provided for by law. 3. You must, within thirty days -of the date of this order remit to the State Ethics Commission made payable to North Eun dngdon Township the amount of excess expense allotments which you received which totals $1,613.16. Mr. Gerald .Hagen Page 18 r. If you do not comply with the provisions of paraghaph 3 :dove, this matter will be referred to the appropriate law enforcement agency for further review and appropriate action. Our files in this case will remain confidential in accordance with Section 8(a) of the Ethic Act. 65 P.S. §408(a However, this Order is final and will be made available as a public document 5 days after service (defined as mailing). By the Commission, Joseph W. Marshall, III Chairman Mr. Gerald P. Hagan 12759 Ridge Road North Huntingdon, PA 15642 such. JJC /na STATE ETHICS COMMISSION 308 FINANCE BUILDING P.O. BOX 11470 HARRISBURG, PA 17108 -1470 TELEPHONE (717) 783 -1610 August 24, 1988 Re: Order No. 554 -R, File No. 86 - 132 -C Dear Mr. Hagan: On August 8, 1988, the State Ethics Commission approved your requested payment method for reimbursing North Huntingdon Township as required by Order No. 554 -R. We have forwarded your check No. 1009 dated August 8, 1988 in the amount of $403.29 to North Huntingdon Township,. We will expect checks in the amount of $403.29 on December 15, 1988, March 15, 1989 and June 15, 1989. This letter will be part of the Order and a public record as cc: Public Hinder n J. 'ontino .2 xecu ve Director Mr. Gerald P. Hagan 12759 Ridge Road North Huntingdon, PA 15642 Re: Order No. 554 -R, File No. 86 -132 -C Dear Mr. Hagan: On August 8, 1988, the State Ethics Commission approved your requested payment method for reimbursing North Huntingdon Township as required by Order No. 554 -R. We have forwarded your check No. 0368 dated December 15, 1988 in the amount of $403.29 to the North Huntingdon Township. We will expect checks in the amount of $403.29 on March 15, 1989 and June 15, 1989. such. JJC /rda This letter will be part of the Order and a public record as cc: Public Binder STATE ETHICS COMMISSION 308 FINANCE BUILDING P.O. BOX 11470 HARRISBURG, PA 1 71 08 -1 470 TELEPHONE (717) 783 -1610 December 29, 1988 Sincerely, hn J. Contino Executive Director