HomeMy WebLinkAbout618-R YanchulisMr. John A. Yanchulis
c/o Frank Tamulonis, Jr. Esquire
Zimmerman, Lieberman & Derenzo
111 East Market Street
P.O. Box 238
Pottsville, PA 17901
Re: 85- 093 -C, 85 -098 -C
Dear Mr. Yanchulis.
A. Findings:
STATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
ORDER OF THE COMMISSION
ORDER NO. 618 -R
DATE DECIDED: August 18, 1988
DATE MAILED: September 13, 1988
The Ethics Commission has reviewed the allegation(s) that you
have violated the Ethics Act, Act 170 of 1978. The nature of the
alleged violation(s) is as follows..
I. Allegation: That you, a Township Supervisor in West Mahanoy
Township, violated Section 3(a) of the Ethics Act which prohibits a
public employee's or public official's use of office or confidential
information gained through that office to obtain financial gain other
than compensation allowed by law, because the township is currently
paying for your annuity program and group life and hospitalization
insurance.
1. You have served as a West Mahanoy Township Supervisor from
January, 1978 until the present.
a. You have been either Chairman or Vice Chairman of the board
of supervisors during your tenure.
b. You were not employed by the township in any capacity until
a meeting of the township supervisors on December 5, 1985,
when the other two supervisors approved your appointment as
treasurer.
2. You were enrolled in a retirement annuity program as a township
supervisor at the township's expense.
Mr. John A. Yanchulis
Page 2
3. Records relating to this program indicate as follows.
a. The retirement program was originally obtained through
Baltimore Life Insurance Company.
b. Your policy number at that time was A0687708.
c. This coverage was obtained later through Life of Maryland,
Incorporated.
d. ; This change occurred in 1982.
e. Your new policy No. was 01010016620.
4. Baltimore Life Insurance Company and Life of Marl :nd,
Incorporated premium statements indicated semi - annual li.11ings for the
above policy as follows:
Statement Date Amount
06 -14 -85 $300.00
11- -85 $300.00
06 -13 -86 $300.00
12 -12 -86 $300.00
Payments were also made to the plan beginning in March, 1980
and continuing on an annual basis.
5. Township records indicate the following in relation to payments by
'the township for the above benefit:
Check
Date Number Company
06/12/85 6705 Life of
Maryland
12/05/85 7169 Life of
Maryland
06/11/86 7591 Life of
Maryland
12/17/86 8005 Life of
Maryland
Coverage Amount
Annuity $1,500.00
Annuity $1,500.00
Annuity $1,200.00
Annuity $1.,500.00
Mr. John A. Yanchulis
Page 3
*These and subsequent payments represent premiums for various
township officials and employees including you.
6. The policy was terminated in June, 1987, and you have received
benefits in the amount of $9,054.57.
a. This included payments made on your bahalf commencing in
June, 1980.
7. You were enrolled in a life insurance program at the township's
expense.'
8. This insurance was with the Trustee's Insurance Fund and
sponsored by the Pennsylvania State Association of Township
Supervisors.
a. The policy was effective (for you) on February 1, 1978.
b. Policy No. 53- 14 -10.
9. Premium statements from the Trustee's Insurance Fund to West
Mahanoy Township indicate the following billings for your life
insurance coverage.
Statement Date Amount
07- -85 $66.95
08 -15 -86 $45.00
10. Records of West Mahanoy Township indicate the following
regarding the township payment of the above premiums for your life
insurance coverage.
Date Check No. Payee Coverge Amount
08/29/35 6882 Trustees Life $401.70
Insurance
Fund
a. Payments represent premiums for various township officials
and employees including you.
11. You were enrolled in a hospitalization and medical program at the
township's expense.
12. This Thsurance was obtained through the Trustee's Insurance Fund.
This covercje was effective Februay 1, 1978. Your policy number was
42433.
Mr. John A. Yanchulis
Page 4
13. Premium statements from TrusteL's Insurance Fund to West Mahanoy
Township indicate that payments for your hospitalization/medical
insurance coverage were paid by the township from 1979 through 1985.
14. A review of the above indicates that from March 31, 1985 tF
present, West Mahanoy Township expended the following for your
various benefits.
Annuity: $1,200.00 (Cash surrender $9,054.57) Life
Insurance: $ 111.95
Hospitalization: $ 0
15. A review of minutes of the meeting of the township board of
auditors from 1976 through January, 1987, do not indicate that
life, medical or pension coverages were fixed or renewed for t.... Zip
supervisors employed by the township.
a. Auditor minutes prior to 1976 could not be located and have
been missing for many years.
16. Minutes of the township board of supervisors from January, 1979,
to December, 1986, indicate as follows:
a. January 3, 1984 - Minutes reflect a paragraph that all
po'L icies and procedures previously in effect will continuo.
b. January 7, 1985 - Minutes reflect a paragraph that
unanimous approval by the Board of Supervisors was given to
continue all past policies and procedures that are currently
in effect.
c. Both of these recordings were made at reorganization
meetings.
d. Minutes from January, 1979 through December, 1986 do not
reflect that any life, medical or pension coverages were
specifically fixed or renewed for township supervisors
employed by the township.
e. The township secretary /manager advised that the township
supervisors wanted the paragraphs mentioned in a and b above
to include being a reference to the township's life, medical
and pension programs.
17. By letter dated May 23, 1985, over signature of Leonard J.
Tragus, Township Secretary /Manager, to Peter Sarno, Jr., it is
verified that township supervisors are enrolled in life and health
insurance programs and are also enrolled in a retirement program.
Mr. John A. Yanchulis
Page 5
18. Michael Kovalich served as a West Mahanoy Township auditor from
1966.
a. Mr. Kovalich indicated that the township auditors approved
the anmity, life and medical plans for supervisors in 1971.
b. Kovalich could not provide auditor's minutes prior to
January, 1976.
c. .Kovalich advised that former auditor Anthony Domarotsky was
- the last person to have the auditor's minutes prior to
January, 1976 in his possession.
19. Anthony Domarotsky served as a township auditor from 1970 to
1976.
a. He indicated that the auditors did nothing other than the
annual audit.
b. Domarotsky stated that he never voted on any motion to give
auditor's approval for insurance benefits to the township
supervisors.
20. You provided the following information in relation to the
instant situation:
a. You have served as a township supervisor since 1978.
b. You
were not employed by the township until December, 1985.
c. You serve currently as treasurer.
d. You acknowledge your participation at the expense of the
township in the health, life and retirement programs.
e. The auditors approved these programs prior to your election
on the board of supervisors.
f. You voluntarily terminated
June, 1987.
g.
your township pension plan in
You received $9,054.57 from this plan and kept it for your
personal use.
h. You admit to the amounts paid by the township on your
behalf as outlined in Finding No. 15.
i. You stated that other township supervisors and employees
have terminated their pension plans and received the money
for their personal use.
Mr. John A. Yanchulis
Page 6
You stated that you terminated your township
hospitalization /medical coverage on September 15, 1983,
because you discovered that you had such coverage with your
employer, the Reading Company.
k. You related that the township has made no payments for your
hospitalization /medical coverage subsequent to September 15,
1983.
B. Discussion. As a Township Supervisor you are a public official as
that term is defined in the State Ethics Act. 65 P.S. 402. As such,
you are subject to the provisions of the Ethics Act and the
restrictions therein are applicable to you.
Generally the Ethics Act provides that:
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).
The question of the propriety of pension and annuity pans for
supervisors of second class townships has been reviewed by t1iic
Comission on many occasions. McCutcheon, No. 127, Hoak, No. 128,
Marcello, 85 -003. The Commission determinations in these matters have
been reviewed and affirmed by the Commonwealth Court of Pennsyiva,Lia.
McCutcheon v. State Ethics Commission, 77 Pa. Commw. Ct. 529, 466 A.2d
283, (1982).
Generally, in situations such as the instant matter, it must be
determined whether the official used his position to obtain or secure
financial gain other than the compensation that is authorized by law.
It is now clear that pension /annuity benefits and other insurance
such as the type herein question, constitute a financial gain. See
McCutcheon v. State Ethics Commission, 466 A.2d 283, at 288.
The additional question to be answered is, therefore, whether
such benefits are compensation provided by law. A complete analysis
of this exact issue has been set forth in the above authorities. See
also Hendricks v. East Rockhill Township, 1 D & C 3d 763, (1977).
Generally, the compensation to be paid to a township supervisor who
serves only in that position is specifically set by Statute. 53 P.S.
65515. A Supervisor who is also employed by the township in one of
the positions authorized in the Second Class Township Code, may
Mr. John A. Yanchulis
Page 7
receive additional compensation. Such compensation, however, in order
to be authorized by law, must be affirmatively fixed by the Township
Board of Auditors. 53 P.S. 65542.
Similarly, this Commission has also ruled in accordance with the
above, that a non - working township supervisor may not receive health,
medical and life or other insurance benefits without violating the
provisions of the State Ethics Act. Krane, No. 84 -001, Glova, No.
326.
Additionally, even if such a supervisor is employed by the
township as a superintendent, secretary /treasurer, roadmaster, or
laborer in accordance with the Second Class Township Code, such
benefits are considered compensation and must, therefore, be fixed as
such by the township board of auditors. See Svnoski v. Hazle
Township, Pa. Commw. 168, 500 A.2d 1282, (1985); In re: Appeal of
the Auditors Report of Muncv Creek Township, Pa. Commw. Ct.
520 A.2d 1241, (1987); Hunt, No. 348 -R. The foregoing principle was
recently reaffirmed by Pennsylvania Commonwealth Court in Yocabet v.
State Ethics Commission,. Pa. Commw. Ct. , 531 A.2d 536 (1987).
In the cited case, the Court held inter alia that a township
supervisor violated Section 3(a) of the Ethics Act when he received a
salary for the position of secretary /treasurer which had not been set
by the auditors. The Court, in affirming the Order of the Ethics
Commission which required a restitution of the financial gain, noted
on page 539 of its opinion.
"Section 7 of the Ethics Act instructs the
Commission to investigate situations where there
is a reasonable belief that financial conflict
may exist, and if conflict is found, to require
the offender to remove himself from the conflict
without gain."
Any benefits received other than as provided for above, would
constitute a financial gain obtained in violation of the State Ethics
Act. See, McCutcheon v. State Ethics Commission, supra, Conrad v.
Exeter Township, 27 D & C 3d 253, (1983). These principles of law are
now well settled and constitute the law under which this situation
must be reviewed. See, In Re: Report of Audit or South Union
Township, 47 Pa. Commw. 1, 407 A.2d 906, (1979).
In this case, you were a non - working supervisor from January,
1978 until December, 1985, at which time you were appointed to the
position of township treasurer.
Since you were not employed by the township between January,
1978 and December, 1985, you were not entitled to the annuity, group
life and hospitalization insurance benefits that were paid at the
township's expense. As stated above, a non - working supervisor is not
entitled to these benefits under the Ethics Act, the Second Class
Township Code or under decisional law.
Mr. John A. Yanchui. y.s
Page 8
As to the period from December, 1985, forward, you were a
working supervisor; however, you still would not be entitled to the
above benefits because of the absence of the requisite auditor
approval. The minutes of the meetings of township auditors from 11,P,
through January, 1987, reflect that there was neither a review nor
approval of these types of benefits. Indeed, until November of 1935,
there was no auditor approval of any compensation for working
:supervisors. Parenthetically, there are contradicting statements from
two auditors concerning whether there was auditor approval for these
benefits in 1971. However, it is noted in this regard that the
auditor's minutes are unavailable for the period prior to January.
1976. Since it appears that auditor approval was never given for'
these benefits, you were not entitled to the receipt of same at the
township s expense.
You, as a public official, violated Section 3(a) of the Ethics
Act in that you have obtained a financial gain through the rece.ilt of
the benefits which is not compensation as provided for by law.
It also should be noted that even if these benefits had be r
received in good faith, such would not be controlling.' Good fPit.h
receipt of such benefits, even when based upon a solicitor s af`r.ce,,
will not alleviate the necessity of a public official reimbursing ;
governmental body for the receipt of a financial gain for which he w
not entitled. See Allegheny County v. Grier, 179 Pa. 639, 36 A.
(1897), McCutcheon v. State Ethics Commission, supra, Kestler AppeLi,
66 Pa. Commw. 1, 444 A. 2d 761, (1982) . As a result, this Commission
believes that you must reimburse the township for this financial.
The State Ethics Act provides as follows:
Section 9. Penalties.
(a) Any person who violates the provisions of
t7ection 3(a) and (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. 409(a).
(c) Any person who obtains financial gain from
violating any provision of this act, in addition
to any other penalty provided by law, shall pay
into the State Treasury a sum of money equal to
three times the financial gain resulting from such
violation. 65 P.S. 409(c).
In addition to the above, the State Ethics Act provides that the
Commission may forward the results of any investigation to the
appropriate prosecuting authority unless the alleged offender removes
himself from the conflict of interest by divesting himself of any
Mr. John A. Yanchulis
Page 9
financial gain received in violation of the State Ethics Act. 65 P.S.
407 9(iii). See also McCutcheon v. State Ethics Commission, supra,
the Commission may order restitution of financial gains received in
violation of the law. It appears to be more than mere coincidence
that you converted the full pension plan in June, 1987. You were well
aware of this investigation of that plan. It is further clear that
while you continue to serve in your public position, you nevertheless
secured the full value of the plan. That is you did not "retire" or
otherwise leave office yet cashed in the plan. This Commission views
such action as an attempt to preclude the township from recovering
these funds.
This action merely evidences an actual intent to use your office
to obtain a financial gain in violation of the law.
The last matter which must be addressed by this Commission
concerns House Bill 1577 of 1987 which was signed into law on March
30, 1988 as Act 41 of 1988.
As to pension benefits that are received by a non - employee
supervisor between January 1, 1959 and March 31, 1985, Act 41
provides, in part, in Section 1(b)(7):
"Township supervisors who are not employes of
the township shall not be eligible for
participation in any pension or anm ity contract
paid in whole or in part by the township. No
township supervisor who was not an employe of the
township but was included in a township -paid
pension or annuity plan or entered into by a
township between January 1, 1959, and March 31,
1985, shall be subject to any penalty,
assessment, surcharge, forfeiture or disciplinary
action of any kind as a result of said
participation...."
Life Insurance and hospitalization benefit received by a
non - employee supervisor between January 1, 1959 and March 31, 1985 are
provided for, in part, in Section 1(c)(2) of Act 41, supra:
"Any life, health, hospitalization, medical service or
accident insurance coverage contract entered into by a
township between January 1, 1959, and March 31, 1985, that
includes or provides coverage for non - employe surpervisors
shall not be void or unlawful solely because such inclusion
of non - employe supervisors was SUBSEQUENTLY FOUND TO BE
WITHOUT LAWFUL AUTHORITY, No penalty, assessment, surcharge,
forfeiture or disciplinary action of any kind may occur as a
result of participation by non - employe surpervisors...."
Mr. John A. Yanchulis
Page 10
Therefore, the annuity, life and hospitalization insurance
benefits that you received between January, 1982 and March 31, 1985
would be implicated by Section 3(a) of the Ethics Act, however, no
penalty or assessment may be imposed in light of above quoted
provisions of the amnesty provisions of Act 41, supra. The receipt of
said benefits after March 31, 1985 would transgress•Section 3(a'. In
this case, you received financial gain of $1,311.95. The foregoing
'mount must be returned to your governmental body, West Mahanoy
Township.
II. Allegation: That you, a Supervisor in West Mahanoy Township',
violated Section 3(a) of the Ethics Act which prohibits a public
official s use of office or confidential information gained through
that office for financial gain other than compensation provided by law
or Section 3(c) of the Ethics Act which prohibits a public official or
a member of his immediate family from entering into a contract valued
$500 or more with his governmental body unless the contract Las
been awarded through an open and public process when you authorized
preparation of a 1984 Community Development Application by your wife
and Helen Monices Tragus at a cost not to exceed $3000.
A. Findings.
21. Findings 1 through 21 are incorporated herein by reference.
22. The minutes of the township board of supervisors meeti:' s
indicate as follows:
a. January 7, 1985 - Chairman John Yanchulis reported that for
1984, West Mahanoy Township is anticipating applying far: a
Community Development Block grant. Vice- Chairman John
Letcavage announced that a public hearing to receive
citizens input as to the possible uses of grant monies will
!e conducted in the near future. In closing, the West
Mahanoy Township Board of Supervisors authorized the
preparation of a 1984 Community Development application by
Helen Monices and Marianne Yanchulis with a total cost not
to exceed $3000. Voting in favor, William Griffin and John
Letcavage.
b. January 15, 1985 - A special meeting was conducted to
receive citizen input on the block grant application.
c. February 11, 1985 - A special meeting was held to adopt a
resolution authorizing the submission of the 1984 Community
Development Block Grant application.
d. December 5, 1985 - A motion was made by John P. Letcavage
and seconded by William Griffin Sr. to have Helen Monices
Tragus share the duties of Community Development Director
Mr. John A. Yanchulis
Page 11
and Administrative Assistant to the Board of Supervisor.
This was approved unanimously.
A motion was made by William Griffin, Sr. and seconded by
John Letcavage to appoint as Treasurer and employ on a full
basis Mr. John A. Yanchulis. Mr. Yanchulis abstained from
voting.
23. Your wife was paid as a township employee in the Community
Development Program as follows.
Year Gross Net
1980 $ 6,000.02 $ 4,599.27
1981 $13,076.92 $ 9,930.36
1982 $14,329.66 $11,578.34
1983 $14,899.82 $11,578.34
1984 $ 8,596.05 $ 6,705.09
*1985 $ 2,500.00 $ 2,030.70
1986 $15,499.92 $12,109.04
*During 1985, your wife received $1,500 of this $2,500 for
helping to prepare an application for 1984 Community Development
funds. This was half of the $3,000 spent for preparation of the
application.
a. She reviewed prospective applicants for the program.
b. She documented the income of the applicants.
c. She verified that all program requirements were met.
d. She provided a determination as to whether or not the
applicant was eligible for the program.
24. Department of Community Affairs, Small Community Program
Contract, No. S- 85 -54 -7 in the amount of $379,940.00 was affirmed
November 15, 1985 and forwarded to you as township chairman.
a. Article VII of the contract provided as follows.
The CONTRACTOR covenants that it and its employees
presently have no interest and shall not acquire any
interest, direct or indirect, which would conflict in anv
manner or degree with the performance of its activities
Mr. John A. Yanchulis
Page 12
hereunder. Ale CONTRACTOR further covenants that in the
performance of this CONTRACT, it wild. not knowingly onpl.:y
any person having any such interest.
The CONTRACTOR will establish safeguards to prohibit
employes from using position for a purpose that is or crives
the appearance of being motivated by a desire for pivate
gain for themselves or others, particularly those with who:...
they have a family, business or other ties.
b. :Article VIII of the contract provided as follows.
No officer, member or employe of the COMMONWEALTH and nc
member of its governing body who exercises any functions
responsibilities in the review or approval of services being
performed under this CONTRACT shall participate in any
decision relating to this CONTRACT, which affects his
personal interest or the interest of any corporation,
partnership, or association in which he is directly or
indirectly interested; nor shall any such officer, member or
employee of the COMMONWEALTH and no member of its gov
body have any interest, direct or indirect, in this C1NTR?ICT
or the proceeds thereof.
25. Township records reflect that the following amounts were paid ..o
consultant Bernard Tatcher, 422 Pheasant Lane, Lafayette Hill,
Pennsylvania for professional services related to community
development application prior to 1984.
a. 1980 - $16,000.00
b. 1981 - $ 8,500.00
c. 1983 - $12,000.00
26. You provided the following information in relation to the
instant situation:
a. In 1985, the township board of supervisors authorized your
wife and Helen Monices to develop and prepare a 1984
Community Developemnt application.
b. The cost of the application was not to exceed $3,000.
c. You stated that you did not participate in this decision„
Mr. John A. Yanchulis
Page 13
d. You stated that a consultant who filed similar application
in prior years charged much more than $3,000 for his
services.
e. You stated that your wife and Helene Monices met the
qualifications for preparing such applications.
f. Your wife was paid $1,500 from the township general fund
which was later reimbursed with federal funds.
g. . Your wife and Helene Monices were rehired as township
employees to prepare the grant application as either
Rehabilitation Specialist or Community Development
Specialist.
B. Discussion: As previously noted above, you are a public official
subject to the provisions of the Ethics Act.
Section 3(c) of the Ethics Act provides.
Section 3. Restricted activities.
(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.
403(c).
Section 3(c) of the Ethics Act, which deals with contracting
restrictions as to a public official's contracting with his
governmental body in excess of $500, not only applies to public
officials but also to their immediate family (or business) which would
include your wife in this case. However, since the allegation has
been filed against you and not your wife, this Commission must
scrutinize your conduct in this matter to determine whether any of
your activities were prohibited by Section 3(c).
Mr. John A. Yanchulis
Page 14
In the instant situation, it is noted that when the township
board of supervisors authorized the preparation of the application by
Helene Monices and your wife, you did not vote in this matter. You
also abstained from voting when a motion was made to appoint you as
treasurer on a full -time basis. As to the community development
application, although it is clear that Helene Monices and your wife
did get township authorization for the preparation of the application,
there was no official action on your part because you did not
participate in the voting of the award of that contract, amounting to
$3,000, to your wife and Helene Monices.
Based upon the foregoing factors and circumstances, this
Commission finds that you did not violate Section 3(c) of the Ethics
Act because you did not vote to authorize the preparation of the
community development application by your wife and Helene Monices. It
must be noted, however, that this Commission has not addressed the
question as to whether any other provisions of law, aside from the
Ethics Act, or contract such as the Department of Community Lffairs,
Small Community Program Grant No. S- 85 -54 -7, has been violated or
breached.
C. Conclusion and Order:
1. As a Township Supervisor in West Township, you are a
"public official" and, as such, are subject to the
provisions of the Ethics Act.
2. Section 3(a) of the Ethics Act was implicated when . lou
received a gain through public office consisting o1
annuity, group life and hospitalization insurance at the
township s expense between January, 1978 and March 31, 98;
but no penalty or assessment will be imposed in :Light of Act
41 of 1988 which provides amnesty as to the receipt of tY'.ese
benefits.
J. You violated Section 3(a) of the State Ethics hct when you
received at township expense amnesty, groups life insurance
and hospitalization benefits for the period April 1, 1985
forward since such gain is not compensation provided for by
law.
4. The financial gain which you received and which was not
part of the compensation provided for by law amounts to
$1,311.95.
5. You are hereby ordered.to remit to the State Ethics
Comission, within thirty (30) days of the date of this
order, the amount of $1,311.95 made payable to West Mahanoy
Township as restitution for the financial gain that you
received.
Mr. John A. Yanchulis
Page 15
6. There is insufficient evidence to establish that you
violated Section 3(c) of the State Ethics Act.
7. Failure to comply with the provisions of this order will
result in a referral of this matter to the appropriate law
enforcement authority with a recommendation that both civil
and criminal proceedings be initiated.
8. This matter will be referred to the Department of Community
Affairs for review as to whether there was a breach of
program contract No. S- 85 -54 -7.
Our files in this case will remain confidential in accordance
with Section 8(a) of the Ethics Act, 65 P.S. 408(a). However, this
Order is final and will be made available as a public document 5
business days after service (defined as mailing).
Any person who violates the 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, see 65
P.S. 409(e). The confidentiality provision does not restrict
respondents consultation with legal counsel.
By the Commission,
/l�lw4rA,
Joseph W. Marshall, III
Chairman
Mr. John Yanchulis
411 East Oak Street
Frackville, PA 17931
ATE ETHICS COMMIS`.
308 FINANCE BUILDINC
P.O. BOX 11470
HARRISBURG, PA 17108 -14 " >:
TELEPHONE (717) 783-161
October 5, 198
Re: Order No 618 -R, File No. 85 -093 -C
Dear Mr. Yanchulis:
The State Ethics Commission received your payment for
reimbursing West Mahanoy Township as requireC by Order No. 518 -•R.
We have forwarded your check No. 753 dated September 27,
1988 in the amount of $1,311.95 to West Mahanoy Township.
such.
JJC /na
This letter will be part of the Order and a public racord as
cc: rqblic Binder
Sinc
IA'
Execw ve Director