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In Re: Jennifer Storm,
Respondent
File Docket:
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Date Decided:
Date Mailed:
FACSIMILE: 717-787-0806
WEBSITE: www.etNGS.DaMV
20-001
Order No. 1789
6/23/21
6/28/21
Before: Nicholas, A. Colafella, Chair
Mark R. Corrigan, Vice Chair
Roger Nick
Melanie DePalma
Michael A. Schwartz
Shelley Y. Simms
This is a final adjudication of the State Ethics Commission.
Procedurally, the Investigative Division of the State Ethics Commission conducted an
investigation regarding possible violation(s) of the Public Official and Employee Ethics Act
("Ethics Act"), 65 Pa.C.S. § 1101 et M., by the above -named Respondent. At the commencement
of its investigation, the Investigative Division served upon Respondent written notice of the
specific allegations, Upon completion of its investigation, the Investigative Division issued and
served upon Respondent a Findings Report identified as an "Investigative Complaint." A
Stipulation of Findings and a Consent Agreement were subsequently submitted by the parties to
the Commission for consideration. The Stipulated Findings are set forth as the Findings in this
Order. The Consent Agreement has been approved.
I. ALLEGATIONS:
That Jennifer Storm, a public official/public employee in her capacity as the Victim
Advocate for the Commonwealth of Pennsylvania Office of Victim Advocate, and/or as a Member
of the Pennsylvania Commission on Crime and Delinquency ("PCCD") and/or as a Member of the
PCCD Victims' Services Advisory Committee ("VSAC"), violated Sections 1103(a), 1103(c),
1103(d), 1104(a), 1104(d), 1105(b)(5), and 1105(b)(7) of the State Ethics Act (Act 93 of 1998)
when she used the authority of her public office as the Victim Advocate for a private pecuniary
benefit of herself and/or a business with which she is associated, namely The Blackout Girl, LLC,
by advocating for the enactment of Marsy's Law in Pennsylvania, at a time when she and/or The
Blackout Girl, LLC, accepted money and/or other items of value from a lobbyist representing a
principal seeking to influence legislative action regarding Marsy's Law in Pennsylvania; when, as
a Member of the VSAC and/or PCCD, she utilized the authority of her public office to approve
disbursement of grant funding to entities at a time when she and/or The Blackout Girl, LLC,
storm, 20-001
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accepted money and/or other items of value from individuals associated with those entities
receiving grant funding; when, as the Victim Advocate, she accepted improper influence when she
and/or The Blackout Girl, LLC, received money or other items of value in an effort to finance a
movie ("The Blackout Girl") with the understanding that she (Jennifer Storm) would continue to
work to promote the passage of Marsy's Law in Pennsylvania; when as a Member of the VSAC
and/or PCCD, she accepted improper influence when she and/or The Blackout Girl, LLC, accepted
money or other items of value in an effort to finance a movie ("The Blackout Girl") with the
understanding that she (Jennifer Storm) would vote/continue to vote to approve disbursement of
grant funding through PCCD to organizations affiliated with the person(s) providing money/items
of value to Jennifer Storm/The Blackout Girl, LLC; when she accepted honorarium from her
speech/presentation at the 2018 Delaware Statewide Victim Services Conference; when she
utilized Office of Victim Advocate work product in furtherance of her appearance(s), speech(es)
and/or presentation(s) at the 2018 Delaware Statewide Victim Services Conference; when she
failed to disclose travel/hospitality/lodging provided by the National Crime Victim Law Institute
for travel to Portland, Oregon, for calendar year 2017, and failed to identify all reportable sources
of income for calendar years 2018 and 2019.
11. FINDINGS:
1. Jennifer Storm ("Storm") served as the Victim Advocate for the Commonwealth of
Pennsylvania from November 8, 2013, until her resignation effective January 29, 2021.
a. Storm was nominated for the position by Governor Tom Corbett.
b. Storm was confirmed by the Pennsylvania Senate and initiated a six -year terra on
December 10, 2013.
C. Prior to the expiration of her term in December 2019, Governor Tom Wolf
nominated Storm for an additional six -year term as the Victim Advocate.
d. On November 16, 2020, the Pennsylvania Senate rejected the Governor's
appointment of Storm as the Victim Advocate by a 32-18 vote.
C. Storm served as the Victim Advocate in an "acting" capacity from March 2020
until she resigned effective January 29, 2021.
2. The Pennsylvania Office of Victim Advocate ("OVA") was created by Act 8 of 1995
during Governor Tom Ridge's Special Session on Crime.
a. The Victim Advocate is nominated by the Governor and confirmed by the Senate
to serve a term of six years.
b. The Victim Advocate has the authority and the duty to represent the rights and
interests of all Commonwealth crime victims in general, including victims of
juvenile offenders and victims of those who come before the Pennsylvania
Department of Corrections, the Pennsylvania Parole Board, and the Board of
Pardons.
Storm, 20-001
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C. Act 8 of 1995 also authorizes the Victim Advocate to address the interests of all
victims before the Board of Probation/Parole/Pardons or a hearing examiner
concerning any issues determined appropriate by the Victim Advocate.
3. Through Act 8 of 1995, OVA is provided with clerical, technical, and professional staff as
may be available within the budget of the Board of Probation/Parole.
4. In addition to her service as the Victim Advocate, Storm also served as a Member of the
Pennsylvania Commission on Crime and Delinquency ("PCCD") and as a Member of the
Victims' Services Advisory Committee ("VSAC") housed within PCCD.
a. Storm was initially appointed as a Commissioner for PCCD in 2003.
b. Storm was subsequently appointed as a Member of the VSAC in 2011.
5. Prior to serving as the Victim. Advocate for the Commonwealth, Storm served as Executive
Director of the Dauphin County Victim/Witness Assistance Program from approximately
2003 to 2013.
a. The Dauphin County Victim/Witness Assistance Program is a nonprofit
organization which provides assistance to witnesses and victims of crime occurring
in Dauphin County, Pennsylvania.
b. Although only responsible for representing victims/witnesses of crime in Dauphin
County, Storm frequently attended high profile criminal trials in other regions of
the state.
1. One such instance was the Jerry Sandusky ("Sandusky") criminal trial in
the Centre County Court of Common Pleas.
C. Storm frequently attended the Sandusky legal proceedings and commented to the
media during the criminal trial in Centre County, Pennsylvania.
d. Following the Sandusky trial, Storm was appointed as the Victim Advocate by the
Corbett administration.
C. Storm's frequent commentary at the high -profile Sandusky trial in 2012 and the
subsequent trial of Bill Cosby in Montgomery County boosted both her position as
the Victim Advocate and her private business interests as an author, speaker, and
filmmaker.
6. In addition to serving as the Victim Advocate, Storm's social media presence identifies her
as a victim rights expert, maintaining a large social media presence, including a webpage,
Facebook, and Twitter accounts.
a. Storm's social media states "[s]he has worked many high profile cases including
helping victims/survivors of[:] Jerry Sandusky, Bill Cosby, Catholic Clergy victims
and thousands of other cases in her twenty year long career as a victim advocate,
Jennifer Storm is often times the first call media make when stories break."
7. PCCD was created by Act 274 of 1978 (1978 Act 274), which established PCCD as an
administrative commission in the Governor's Office.
Storin, 20-001
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a. In determining the need to establish PCCD, the General Assembly declared, in part,
"that crime and delinquency are essentially State and local problems" and that
"crime and delinquency are complex social phenomena requiring the attention and
efforts of the criminal justice system, State and local governments, and private
citizens alike."
b. The purpose of PCCD is to establish goals, objectives, and standards for the
reduction of crime and delinquency and to more efficiently and effectively
coordinate these efforts.
8. PCCD is comprised of at least 27 individuals, including no less than 15 who are specifically
identified as Members by virtue of holding public office/employment within the
Commonwealth.
a. Those individuals specifically appointed include:
• Attorney General
• Court Administrator of Pennsylvania
• Commissioner of the Pennsylvania State Police
• Majority Chairmen of the House and Senate Appropriations Committees
• Chairman of the Juvenile Justice and Delinquency Prevention Committee
• Secretary of Corrections
• Victim Advocate
+ Secretary of Public Welfare
+ Secretary of Education
• Secretary of Health
+ Chairman of the Board of Probation and Parole
• Executive Director of the Juvenile Court Judges' Commission
• Executive Director of the Pennsylvania Commission on Sentencing
• Secretary of Drug and Alcohol Programs
b. Although initially appointed to PCCD in 2003, StoiTn also served as a Member by
virtue of her holding the office of the Victim Advocate.
9. Through Act 274 of 1978, PCCD possesses the authority to, in part:
a. Apply for, contract for, receive, allocate, disburse and account for funds, grants-in-
aid, grants of services and property, real and personal, particularly those funds made
available pursuant to the Omnibus Crime Control and Safe Streets Act of 1968
(Public Law 90-351), as amended, and the Juvenile Justice and Delinquency
Prevention Act of 1974 (Public Law 93-415), as amended.
b. Receive applications for financial assistance from State agencies, units of general
local government and combinations thereof, private nonprofit organizations and
other proper applicants, and to disburse available Federal and State funds to such
applicants in accordance with the provisions of applicable statutes and regulations
and in conformity with the comprehensive plan.
Storm, 20-001
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C. Establish such fund accounting, auditing, monitoring and evaluation procedures as
may be necessary to assure fiscal control, proper management and disbursement of
grant funds, including the requirements of supporting papers being submitted to the
disbursing agency by persons requiring reimbursement, and to establish such
procedures as may be necessary to assure compliance with nondiscrimination
requirements.
d. Establish, and the chairman of the commission appoint, such subcommittees as it
deems proper.
C. Establish advisory committees, in addition to those provided for under this act, as
it deems advisable, except that only the commission may set policy or take other
official action.
10. As authorized by Act 274 of 1978, PCCD established the VSAC, which serves in an
advisory capacity to PCCD.
a. The VSAC was established with the stated purpose to "assure that the voices, needs
and perspectives of all crime victims/survivors will be considered in the
development of services, services standards, policies, funding priorities, legislation
and outcomes."
b. The VSAC oversees two subcommittees: Access to Services Subcommittee and the
Services & Standards Subcommittee.
C. Each VSAC Member is requested to serve on one of the two subcommittees, along
with others who are not VSAC Members, to ensure appropriate discipline, size, and
geographic representation in rendering recommendations to PCCD.
THE FOLLOWING FINDINGS RELATE TO THE ALLEGATIONS THAT STORM
UTILIZED THE AUTHORITY OF HER PUBLIC OFFICE TO APPROVE
DISBURSEMENT OF GRANT FUNDING TO SUSQUEHANNA TOWNSHIP AT A TIME
WHEN SHE AND/OR THE BLACKOUT GIRL, LLC, ACCEPTED MONEY FROM THE
INDIVIDUALS ASSOCIATED WITH THOSE ENTITIES; AND/OR WHEN SHE
ACCEPTED IMPROPER INFLUENCE BY ACCEPTING MONEY WITH THE
UNDERSTANDING THAT SHE WOULD VOTE/CONTINUE TO VOTE TO APPROVE
DISBURSEMENT OF GRANT FUNDING TO SUSQUEHANNA TOWNSHIP AS A
MEMBER OF THE VSAC AND/OR PCCD.
11, In December 2014 the federal "Consolidated and Further Continuing Appropriation Act,
2015" ("Federal Act") was enacted.
a. The Federal Act raised the Victims of Crime Act ("VOCA") appropriations cap
from $745 million to $2.361 billion.
b. The increase in funding tripled the amount of federal VOCA funding provided to
states in federal fiscal year 2015-2016 to help crime victims.
1. The increase in federal funding resulted in a likewise increase in federal
VOCA funding for Pennsylvania, increasing federal funding from $17
million to $77 million.
Storm, 20-001
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2. The increase in federal funding allowed for an expansion of the
Commonwealth's victims services.
3. In 2015 the VSAC initiated a comprehensive strategic planning process for
the distribution of VOCA funding.
4. The VSAC's goal was to establish a framework for the distribution of
VOCA funding that would ensure stable and predictable funding for the
delivery of direct services to crime victims in Pennsylvania over the next
several years while also providing the opportunity for new and innovative
programs to obtain VOCA funding to promote new or enhanced service
delivery for crime victims.
12. On September 16, 2014, Storm announced via her personal social media platform
Oenniferstorm.com) that she, Danielle Hall Count, and DolGer Films agreed on an option
deal to produce a film based on the screenplay adaptation of Storm's memoir, "Blackout
Girl: Growing Up and Drying Out in America," published in 2008 by Hazelden Publishing.
a. Storm and Danielle Hall Count co -wrote the adaptation of the memoir for film
application.
b. The film was identified as being produced and directed by Sylvia Caminer of
DolGer Films.
C. Storm's personal social media stated that the film was "[c]urrently in production,
no firm release date set yet."
d. Storm began collaboration with DolGer Films in 2010 when Sylvia Caminer
approached her at Book Expos America.
13. In an effort to raise capital to produce the film, Storm solicited donations via her various
social media platforms, including her website.
a. Storm's personal website stated:
Support the Film!
You can help by making a tax-deductible donation towards the film.
Simply visit the link below, fill out the donation form and put
"Blackout Girl" in the Notes field upon checkout.
Donate! [clickable button]
b. By clicking on the "Donate!" button, the viewer was directed to the
website <[web address redacted]>.
14. Below the solicitation for the film funding portion of Storm's web page, Storm identified
and thanked numerous individuals who had contributed monetary funding to the production
of her film as follows:
Thank you to those who have already donated including: Ben
Andreozzi, Anne Seymour, Carroll Ellis, Jeff Dion, Heather
Warnken, Caitlin Morneau, Beya Thayer, Jessica Barfield, Ronald
Storm, 20-001
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Williams, Renee Harare's, Bob Davis, Shannon May, Heather
Cartwright, Tammy Woodbarns, Carolyn Holeran, Dave Leber,
Movita Johnson -Harrell, Holli Yoder Nigh, Marylin Fuller Smith,
Kristina Mellinger, Tammy Lamert Harris, Kimberly Coy,
Christopher Brown, Phyllis Parsons, Shawn Fortune, Kim Minnich,
Joe Martin, Mary Prestipino, Maggie Fitter, Jennifer Merchant
Riley, Jane Adams, Lee Tarasi, Meg Garvin, Susan Blackburn,
Tracy Ingram, Chazy Smith, Kim Harlan Oyer, Anne Marie
Labenberg, Chris Jason, Amy Delong, Dawn Lee Hummel,
Donovan Judy, Mary Emelio, Wendy Kinash and Rebecca Khalil.
This film could not happen without your generosity.
15. Several of those persons who donated or provided Storm with funding for her film were at
the same time also officers, directors, or employees of entities receiving grant monies
disbursed by PCCD.
a. At the time of the donations to Storrn, she was a Member of both PCCD and the
VSAC, as well as the Victim Advocate.
1. As a Member of the VSAC, Storm participated in authorizing the
recommendation for disbursement and/or increases in grant monies to
entities who employed or were otherwise associated with donors to her film
enterprise.
2. As a Member of PCCD, Storm participated in authorizing the
recommendation for disbursement and/or increases in grant monies to
entities who employed or were otherwise associated with donors to her film
enterprise.
16. Donors to Storm's private business venture included:
a. Jennifer Merchant Riley ("Riley"), who was at the time a registered lobbyist with
the Pennsylvania Department of State and the State Director of Marsy's Law for
Pennsylvania.
b. Lee Tarasi, who was at the relevant time a police officer for the Susquehanna
Township Police Department.
17. During the time period that Storm was both a Member of the VSAC and PCCD, she
recommended and voted to authorize a disbursement of grant monies to the Susquehanna
Township Police Department as follows:
Award Date Agency Award Amount Adjusted Award Amount
12/09/2015 Susquehanna Township $47,700.00 $47,167.35
03/28/2019 Susquehanna Township $15,000.00 $I5,000.00
a. At the time Storm participated in the award of grant monies to the Susquehanna
Township Police Department through PCCD, Storm also accepted a $50.00 gift
Storm, 20-001
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from Tarasi, who was an employee of the Susquehanna Township Police
Department.
b. Tarasi's gift/donation to Storm was in furtherance of Storm's motion picture
project.
18. While serving as a Member of the VSAC and as a Commissioner for PCCD, Storm
solicited and accepted no less than $1,315.00 from 30 members of the public in furtherance
of her private motion picture project.
a. Individuals who provided Storm with monetary donations included Tarasi, who
was employed by a police department receiving PCCD grant funding for body
cameras, the amount and disbursement approval of which Storm voted in favor of
while she served as a public official for the VSAC and PCCD.
19. None of the 3 0 donations reached the reportable thresholds for gifts a public official/public
employee must report in the Statement of Financial Interests.
a. There is insufficient evidence that Storm solicited any of the donations referenced
above in return for her funding vote.
THE FOLLOWING FINDINGS RELATE TO THE ALLEGATIONS THAT STORM
ATTEMPTED TO MARKET/DISTRIBUTE A BOOK SHE AUTHORED AT A VICTIM
SERVICES CONFERENCE THAT SHE PRESENTED AT IN HER PUBLIC POSITION.
20. Between December 2 and December 4, 2019, PCCD's Office of Victims' Services held the
151h Pathways for Victim Services Conference at the Hershey Lodge and Convention
Center in Hershey, Pennsylvania.
a. The three-day conference was designed to provide an opportunity for education and
networking to more than 300 victim service providers and allied professionals.
b. The conference agenda identified that on Tuesday, December 3, 2019, between
7:00 and 8:30 p.m., Jennifer Storm, Victim Advocate, Commonwealth of
Pennsylvania, would conduct a plenary session.
1. The topic of the session was `Blackout Girl: Sexual Assault and Addiction;
Understanding The Link."
2. `Blackout Girl" is the title of Storm's book.
21. After being invited to be a presenter at PCCD's 2019 Pathways Conference, Storm
attempted to sell copies of her 2008 edition of "Blackout Girl: Growing Up and Drying
Out in America" following the conclusion of her presentation on December 3, 2019.
a. Storm proposed for PCCD staff to sell 50 of her books and donate the proceeds to
PCCD's VCAP fund.
b. Storm's efforts to sell the books was discussed at a Pathways Committee Meeting
held on or about October 2, 2019.
C. Upon hearing of Storm's plan, PCCD Director Kathleen Buckley ("Buckley")
directed that an opinion be sought from PCCD's Chief Counsel.
Storm, 20-001
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22. On November 15, 2019, at 9:40 a.m., at Buckley's direction, Jennie Seigler ("Seigler"),
Supervisor of Efforts to Outcomes and Special Projects at PCCD, sent the following email
to PCCD Chief Counsel Debra Sandifer:
a. Hi Debra!
Kathy asked me to reach out to you to see if you had any red flags with the
situation I will outline below........
Jennifer Storm is providing a plenary session on Tuesday evening (12/3/19)
during our Pathways Conference. She is donating 50 books that she
authored to be sold after her plenary session. The proposal is for PCCD
staff to collect money for the books and then donate that money to our
VECAP fund.
Are there any issues surrounding this that we need to be aware of`? We want
to make sure we are doing everything properly.
b. PCCD Chief Counsel Sandifer responded on November 15, 2019, at 11:27 a.m.
stating:
I do think the involvement of PCCD staff in promoting and selling Jennifer
Stonn's books at the conference presents a problem. It would look as if
PCCD is taking the opportunity at a PCCD-sponsored event to endorse a
recommended book, to a financial gain of the author, a PCCD
Commissioner. Even though the proceeds from the sale of the 50 books
would go to the Commonwealth, the author would still gain financially from
the advertisement and endorsement. I understand that it is usually PCCD's
position that speakers at PCCD-sponsored conferences do not bring their
published works for sale.
I do not, however, see any problem with Jennifer Storm just presenting a
check to the Commonwealth for the fund.
C. Following the email from Chief Counsel Sandifer, Seigler emailed Storm at her
Commonwealth email address at 1:20 p.m. on November 18, 2019, stating:
Thank you so much for offering to sell the books you authored at our 15th
Pathways for Victim Services Conference during your plenary session on
the evening of Tuesday, December 3, 2019. It was very generous of you to
donate all of the proceeds to the Victim's Compensation Assistance
Program (VCAP). Nick Hartman informed me that in order to do this you
requested that PCCD staff handle the book sales and the collection of the
funds from the sales and then make the donation to VCAP.
Since this is slightly outside the norm for us at PCCD, I conferred with our
Chief Counsel Debra Sandifer, who is copied on this email. Debra has
advised against having PCCD staff involved in the sale of the books to avoid
any suggestion of a conflict of interest.
Stare, 20-001
Page 10
d. Storm, following receipt of PCCD Chief Counsel Sandifer's determination, sought
an opinion from the Pennsylvania Department of Corrections ("DOC") Chief
Counsel,
23. On November 15, 2019, at 3:40 p.m., Storm responded to Seigler utilizing her
Commonwealth email address, advising that she would seek advice from her legal counsel:
a. Jennie, thank you, okay. Let me pull in my legal here LOL and see what he
says.
b. Storm's reply to Seigler included a "cc" to Timothy ("Tim) Holmes, then Chief
Counsel for DOC, which provided as follows:
Tim, I am giving a keynote speech at the PCCD sponsored Pathways
Conference sharing my personal story and showing my documentary.
They wanted to make books available which I am fine with and have done
before in similar settings, obviously we all want to make sure it is done
ethically and appropriately. I did not want theta to purchase the books
from the publisher because I would've earned royalties that way, so I
offered to buy them myself and donate them to PCCD so they could see
them and keep the proceeds for the VCAP program. PCCD's legal has
concerns about that, see below. This is how I have usually handled anyone
in state who wants to offer the sale of my book, I donate the books and let
the conference handle the sales that way they keep everything and no
money crosses into my account or hands. People often pay with credit
cards, checks etc.
Can you offer any guidance on what you think would work best? Or are
we just better off not doing this at all? I just want to make sure there is
ZERO ethical concerns here.
C. DOC Chief Counsel Holmes opined that to avoid any ethical concerns, Storm
should not distribute/sell her books at the conference.
24. On December 3, 2019, Storm presented the Plenary Session "Blackout Girl: Sexual
Assault and Addiction, Understanding the Link, Jennifer Storm, Victim Advocate,
Commonwealth of Pennsylvania."
a. Storm's presentation included a retelling of her life story focusing on her memoir
"Blackout Girl" and a potential movie.
b. Storm was not compensated for her presentation.
25. Storm did not sell her book at the 2019 PCCD Pathways Conference, where she was
presenting in her public position, due to objections and concerns raised by PCCD staff and
Chief Counsel.
Storm, 20-001
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THE FOLLOWING FINDINGS RELATE TO THE ALLEGATIONS THAT STORM
ACCEPTED IMPROPER INFLUENCE AND/OR OTHERWISE UTILIZED THE
AUTHORITY OF HER OFFICE WHEN SHE ADVOCATED FOR THE ENACTMENT
OF MARSY'S LAW IN PENNSYLVANIA, AT A TIME WHEN SHE AND/OR THE
BLACKOUT GIRL, LLC, ACCEPTED MONEY AND/OR OTHER ITEMS OF VALUE
FROM A LOBBYIST REPRESENTING MARSY'S LAW FOR PENNSYLVANIA.
26. On December 21, 2017, Marsy's Law for Pennsylvania, LLC ("Marsy's Law PA") filed a
Lobbying Registration statement with the Pennsylvania Department of State as a registered
principal.
a. The Lobbying Registration statement included the following information:
Registration No: P50079
Address: c/o National Registered Agents, Inc. Dauphin
116 Pine Street, Suite 320, Harrisburg, PA 17101
Registration Name: Marsy's Law for Pennsylvania, LLC
Lobbying Commenced: 12/11/2017
Authorized Representative's Name: Margaret Durkin
Authorized Representative's Email: durkin@thebravogroup.com
b. Jennifer Merchant -Riley (Registration No.: L00542) was one of the lobbyists
identified by Marsy's Law PA as conducting lobbying on behalf of the principal.
27. Marsy's Law PA initiated lobbying activity in Pennsylvania in an effort to effectuate an
amendment to the Pennsylvania Constitution to include crime victims' rights in the
Pennsylvania Constitution Declaration of Rights.
a. If enacted, a Marsy's Law amendment to the Pennsylvania Constitution would
provide crime victims with specified constitutional rights.
b. A ballot question posed to Pennsylvania voters that sought to enact Marsy's Law
passed with a majority of Pennsylvanians voting in favor.
1. A challenge to the procedure/language of the ballot question was raised in
the Commonwealth Court of Pennsylvania.
2. On January 7, 2021, the Pennsylvania Commonwealth Court ruled that the
ballot measure violated the separate vote requirement for constitutional
amendments, and as such the results of the November 2019 vote could not
be certified.
28. As a principal, and in furtherance of its lobbying efforts, Marsy's Law PA reported the
following expenses in relation to direct and indirect communications:
Stour►, 20-001
Page 12
Principal Name Reg. No. Period Submit Date Total Cost
Marsy's Law for Pennsylvania, LLC P50079 Jan - Mar 2020 04/02/2020 None Rpt.
Marsy's Law for Pennsylvania, LLC P50079 Oct - Dec 2019 01/24/2020 $2,582,531
Marsy's Law for Pennsylvania, LLC P50079 Jul - Sep 2019 10/29/2019 $ 178,698
Marsy's Law for Pennsylvania, LLC P50079 Apr - Jun 2019 07/29/2019 $ 247,600
Marsy's Law for Pennsylvania, LLC P50079 Jan - Mar 2019 04/30/2019 $ 181,581
Marsy's Law for Pennsylvania, LLC P50079 Oct - Dec 2018 01/30/2019 $ 152,489
Marsy's Law for Pennsylvania, LLC P50079 Jul - Sep 2018 10/30/2018 $ 152,490
Marsy's Law for Pennsylvania, LLC P50079 Apr - Jun 2018 07/24/2018 $ 192,314
Marsy's Law for Pennsylvania, LLC P50079 Jan - Mar 2018 04/26/2018 $ 148,086
Marsy's Law for Pennsylvania, LLC P50079 Oct - Dee 2017 01/30/2018 $ 22,000
29. Contained within OVA's official website <https://www.ova,pa.gov/> is a link and
information regarding Marsy's Law PA's efforts to effectuate a constitutional amendment.
a. Contained within the drop -down "Key Initiatives" is a link to the Marsy's Law PA
website, https://www.marsyslawforpa.com/.
b. The Marsy's Law PA website engages in indirect communication to persuade
Pennsylvania voters.
30. As the Victim Advocate, Storm participated in numerous communications, discussions,
events, and planning sessions with individuals from The Bravo Group, Marsy's Law PA,
the Pennsylvania District Attorney Association, and the Pennsylvania Department of State.
a. The Bravo Group is a registered lobbying firm with the Pennsylvania Department
of State.
b. The majority of the communications focused on developing language of the
proposed Marsy's Law constitutional amendment to be presented before the
Pennsylvania House and Senate.
C. Additionally, Storm communicated regarding strategies to garner support for the
passage of Marsy's Law in Pennsylvania.
31. In a March 21, 2018, email initiated by Storm, she expressed her appreciation for the work
completed by numerous individuals (including employees of The Bravo Group) regarding
the drafting of language for the proposed Marsy's Law in Pennsylvania.
a. On March 21, 2018, Storm sent the following email:
Appreciations for your time with us this week
email. jstorm@pa.gov Storm, Jennifer
To: email: "jmiller@[email address redacted] Joe Miller", email: [email
address redacted] HAHA! ! ! You guys are amazing and I sent Jon K a text
to tell him how awesome the Bravo Team has been to work with!!
Storm, 20-001
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Jennifer R. Storm I Victim Advocate
Office of Victim Advocate
Commonwealth of Pennsylvania
1101 S. Front Street I Suite 5200 1 Harrisburg I PA 117104
Phone: 717.214.22561 Fax: 717.787-0867
jstorm@pa.gov I www.ova.gov
b. On March 21, 2018, Joe Miller of The Bravo Group responded to Storm's email as
follows:
From: Joe Miller [email address redacted]
Sent: Wednesday, March 21, 2018 1:10 PM
To: Jennifer Riley; Storm, Jennifer
Subject: Appreciations for your time with us this week
Clearly, you two were the difference this week. Thanks so much for your
time and hard work on Senate Bill 1011. We couldn't have done it without
you and your people. [... ]
1. Within his email, Miller was referring to the efforts of Storm and Riley as
"the difference" and "your people."
2. Storm utilized Renee Bressler, Special Assistant to the Victim Advocate, in
coordinating her (Storm's) interactions with The Bravo Group.
32. After assisting with the Marsy's Law bill, Riley and representatives of The Bravo Group
requested Storm to utilize her influence as the Victim Advocate to support Riley's position
with Marsy's Law to further support for Marsy's Law passage efforts.
a. Storm was requested to comment on a press release as follows:
From: Katelyn Howard [email address redacted]
Sent: Monday, April 2, 2018 1:26:11 PM
To: Storm, Jennifer
Cc: Jennifer Riley
Subject: ML Release about Jeri Riley for approval
Hi Jen,
Attached is a news release regarding Jeri Riley's new position with
Marsy's Law, and it includes a quote from you. We are hoping to
send this out this week, and I wanted to make sure that you had a
chance to review and []approve your quote.
Stoin, 20-001
Page 14
Please let me know if you have any questions!
Thanks,
Katelyn Howard
2. On April 11, 2018 Storm utilizing her Commonwealth email
(jstorm apa.gou) responded:
This is awesome!
b. On November 5, 2019, Storm was again lobbied by The Bravo Group to provide a
quote/assistance regarding support of Marsy's Law as follows:
From: Katelyn McNally [email address redacted]
To: Storm, Jennifer
Cc: [email address redacted]
Subject: [External] Quote for Approval
Hi Jennifer,
We would like to send out a release tomorrow with the message of, "the
people have spoken; the ACLU needs to follow suit."
Below is a proposed quote for you. Please let me know if you have any
concerns or want to make edits. Thanks!
"The people of Pennsylvania have shown that they will not be bullied, by
standing with crime victims and voting overwhelmingly to pass the crime
victims' rights amendment," said Jennifer Storm, Commonwealth Victim
Advocate. "If the ACLU persists in trying to undo the outcome of the
election, victims of crime in Pennsylvania will be left without
constitutionally protected rights, doing irreparable harm to their lives. The
ACLU should drop this desperate, antidemocratic lawsuit immediately."
I. The above quote attributed to Storm was drafted by someone other than
Storm, with Storm adopting the quote in an effort to further support Marsy's
Law in Pennsylvania.
2. Storm's proposed quote invoked her authority as the Victim Advocate.
33. Storm was also contacted by the Governor's Press Office seeking comments of support for
Marsy's Law:
a. On April 11, 2018, Sara Goulet, Deputy Press Secretary of the Office of the
Governor, sent the following to Storm:
To: Storm, Jennifer
Subject: Quote for release: Governor Wolf Supports Marsy's Law for Crime
Victims Constitutional
Storm, 20-001
Page 15
Amendment
Good morning, Jennifer,
I know this is short notice and I apologize, but we'd love to include a quote
from you in the release below.
Would you have a moment to send me one, please?
Thank you for considering!
Sara
FOR IMMEDIATE RELEASE
April 11, 2018
View Online
Governor Wolf Supports Marsy's Law for Crime Victims Constitutional
Amendment
Harrisburg, PA — Governor Tom Wolf today backed Marsy's Law, which
proposes a state constitutional amendment securing permanent, enforceable
rights of victims.
"It is important for us all to reflect on how we can improve the lives of crime
victims in Pennsylvania,"
Governor Wolf said. "Marsy's Law will amend the state constitution to
provide crime victims with equal protections and participation in the
process. Victims and their families deserve equity. I thank the Senate for
approving this bill unanimously and I urge the General Assembly to
continue advancing Marsy's Law."
The proposed amendment stipulates that there be notice of hearings and
other proceedings, protection from the accused, notice of release or escape,
full and timely restitution, proceedings free from delays and with prompt
conclusion, the ability to confer with the government's attorney and
information on all of these rights.
Jennifer Storm quote
The Senate recently advanced Senate Bill 1011 unanimously and sent it to
the House. The bill is also supported by Pennsylvania's Office of Victim
Advocate and the Pennsylvania District Attorneys Association.
Governor Wolf also announced that the Capitol building in Harrisburg will
be lit purple in honor for Crime Victims' Rights Week,
MEDIA CONTACT: J.J. Abbott, 717-783-1116
Storm, 20-001
Page 16
Storm forwarded this press release to Riley and representatives of
The Bravo Group.
2. Storm was requested to provide a quote as to Marsy's Law in the
section notated "Jennifer Storm quote."
34. Storm was lobbied by Riley/The Bravo Group to utilize her contacts with victims across
Pennsylvania in assisting with identifying a victim of crime who would be willing to be
interviewed by the media in furtherance of advancing Marsy's Law in Pennsylvania.
a. On July 17, 2018, Riley [email address redacted] sent the following email to Storm:
To: Storm, Jennifer <jstorm@pa.gov>
Cc: Will Elliott [email address redacted]
Subject: WATM-TV
Hey there -
A reporter from WATM-TV is interested in doing a victim/survivor profile
in State College for a Marsy's Law piece.
I recently met a rep from the Centre Co Women's Resource Center, so I can
reach out to him for thoughts, but wanted to run it past you first to see if you
have anything that you think. would be good to feature for this piece.
Thanks!
Jennifer Riley
b. On July 17, 2018, Storm [jstorm@pa.gov] responded as follows:
I have a woman who is willing to speal-,. Her name is [redacted] and her
number is [redacted] rape victim who was royally screwed over by the prior
DA.
Jennifer R. Storm I she • her • hers I Victim Advocate
Office of Victim Advocate
1101 S. Front Street, Suite 5200 1 Harrisburg PA 17104
Phone: 717.214.22561 Cell: 717.756.9741
35. Riley also contacted Storm to request that Storm utilize her position as the Victim Advocate
to advance Marsy's Law, as illustrated below:
a. On August 10, 2018, Riley sent the following email to Storm at her Commonwealth
email address Ustorm@pa.gov]:
Subject: National Campus Safety Awareness Month
Good morning!
Storm, 20-001
Page 17
Since Sept is National Campus Safety Awareness Month, we were thinking
about hosting a statewide conference call with college newspapers on ML
and would love if you could join the call.
If you are interested, I can work with Renee to get a date/time. I'm thinking
mid -Sept. Also, you can do the call from anywhere (but a landline works
best).
Also, what do you think about asking a member of law enforcement to join
the call, too? You and he/she could talk about safety tips, etc -- but maybe
that is diluting the message?
Thanks!
Jennifer Riley
b. Riley was requesting Storm to participate in a campus safety event to lobby support
for Marsy's Law.
In the email "Renee" referred to Renee Bressler, the Special Assistant to the
Victim Advocate.
36. At the same time Storm was participating in numerous Marsy's Law events as the Victim
Advocate, she was simultaneously accepting hospitality from The Bravo Group.
a. Emily Luckenbill [email address redacted] sent the following emails to Storm at
her Commonwealth email address:
Date: April 17, 2018
Subject: Gridiron entree selection
Good morning:
Thank you for your interest in attending this year's Gridiron event
at The Hilton on Monday, April 23, 2018.
Below are the entree options for this year's dinner - please let me
know by COB Thursday, April 19, 2018 which option you'd prefer.
Cocoa -crusted shoulder tenderloin
Spinach & goat cheese ravioli
Thank you!
2. April 17, 2018
Subject: Fwd: Gridiron entree selection
Good afternoon, Ms. Storm,.
Jen Riley informed me you would be seated at one of our Bravo
tables for the Gridiron event ... please see my note below and let me
know your selection, thanks!
atgKm, 20-001
Page 18
Have a great afternoon!
b. On April 17, 2018, at 3:22 p.m., Storm responded to Luckenbill as follows:
Spinach and goat ravioli thank you very much.
Jennifer R. Storm I Victim Advocate
Office of Victim Advocate
C. Katelyn Howard [email address redacted] sent the following email to Storm
Ustorm@pa.gov] and Riley [email address redacted]:
Hi there. Just one other quick note about tomorrow: we'll have lunch
available at the Bravo office, so no need to eat before you come! Lunch is
coming in around 11:30 so that we can eat before we get started.
On September 19, 2018, Storm responded: "YAAS dress down day in effect
LOL."
37. The Bravo Group asserted to Commission investigative staff that it did not have records to
evidence the costs of the hospitality provided to Stoirn or if Storm paid for the hospitality.
a. During an interview with Commission investigators, Riley claimed that Storm paid
for all hospitality provided to her but offered no records of payment.
b. Storm asserts that she did not attend the Gridiron event.
38. Riley, as a registered lobbyist and State Director of Marsy's Law PA, provided Storm with
a cash donation/gift of $50.00 in support of Storm's endeavor to complete the filming of
"The Blackout Girl" motion picture documentary.
a. At the time Riley made the donation to Storm, Riley's employer was lobbying
Storm to support Riley's efforts to achieve passage of an amendment to the
Pennsylvania Constitution to recognize crime victim's rights (i.e., Marsy's Law).
b. Storm, in her public office as the Victim Advocate, advocated for the passage of
Marsy's Law.
l . Storm, in her public position, engaged in direct communication in an effort
to achieve enactment of Marsy's Law.
2. Storm, in her public position, engaged in indirect communication with a
lobbyist in an effort to achieve enactment of Marsy's Law.
C. There is insufficient evidence that Storm engaged in direct/indirect communication
with lobbyists and/or otherwise utilized the authority of her office in furtherance of
Marsy's Law with the understanding that her doing so was predicated on receiving
monetary donations/gifts from lobbyists.
1. Insufficient evidence exists that hospitality provided to Storm by The Bravo
Group exceeded the Statement of Financial Interests reporting limits.
Stone, 20-001
Page 19
THE FOLLOWING FINDINGS PERTAIN TO STORM'S RECEIPT OF HONORARIUM.
39. Public employees and public officials in the Executive Branch are subject to
directives/policies regarding travel, supplemental employment, and codes of conduct.
a. Directives and policies include:
• Management Directive 515.1 &-Supplemental Employment
• Governor's Code of Conduct
State Ethics Act, including Statement of Financial Interests filing
requirements
• Governor's Gift Ban
b. As an appointed public official, Storm was subject to these Executive Branch
directives and policies.
40. Following her appointment as the Victim Advocate in November 2013, Storm completed
a new employee orientation checklist which included financial disclosure filing
requirements, the Governor's Code of Conduct, and supplemental employment
(Management Directive 515.18).
a. Storm signed an acknowledgement on December 13, 2013, indicating her
understanding of the above requirements.
41. On December 13, 2013, Storm signed an acknowledgement form pertaining to engaging in
supplementary employment during her time as the Victim Advocate.
a. The acknowledgement stated:
"I understand that if I am engaged in supplementary employment as of the
date, I receive this document, or if I wish to commence such employment
in the future, I must obtain form STD-355, Supplementary Employment
Request, from my supervisor and forward the completed request to the
Agency Personnel Office immediately. I understand that I will receive
notification of approval or disapproval of my request within fifteen (15 days
of their receipt of the STD-355). Whenever I change supplementary
employment, experience a break in supplementary employment service, or
engage in supplementary employment of a seasonal nature, e.g, teaching, I
must have prior approval each time I begin such employment. I must
resubmit a supplementary employment request whenever my full-time
duties with the Board significantly change. I further understand that
approval by the Chairman of the Board is conditional and is subject to final
approval by the Secretary of Administration. If I commence supplementary
employment without prior approval, or if I commence or continue engaging
in such employment after receipt of notice that my request has been
disapproved, such action will constitute grounds for discipline up to and
including removal."
1gm, 20-001
Page 20
92, Management Directive 515.18, which was issued on or around September 13, 2013, as
amended reads, in part, as follows:
a. All employees who work for compensation or remuneration in any capacity outside
of their commonwealth employment, except for military duty, are required to file
supplementary employment requests with their agency head or designated official
who will either approve or disapprove the requests. Such supplementary
employment shall include self employment. Employees are required to resubmit
requests when changing supplementary employment or whenever the duties of
either their commonwealth or supplementary employment position change
substantially.
b. Approval for supplementary employment must be obtained prior to accepting such
employment for current employees and prior to employment with the
commonwealth for prospective employees.
C. Supplementary employment is considered secondary to commonwealth
employment and any conflicts arising out of supplementary employment will be
resolved in favor of the commonwealth. Conflicts of interest in supplementary
employment include, but shall not be limited to, conflict with conditions of
employment established by the Executive Board (see Management Directive
525.11, Dual Employment) and, where applicable, the State Civil Service
Commission; conflicts with conditions of employment, including hours of work, or
regulations promulgated by the commonwealth agency in which such employee is
employed; and conflicts with other applicable laws, rules, or regulations.
Commencing or continuing in supplementary employment after receipt of notice
that such supplementary employment has been disapproved shall constitute
grounds for discipline up to and including removal.
d. Unless otherwise provided by specific agreement, the Secretary of Administration
has final authority for resolving all conflict of interest disputes.
e. Approval to engage in volunteer activities generally is not required. Approval of
volunteer activities is required where the activity may present a conflict of interest
with the employee's regular work hours, regular job duties or the mission of the
agency or may affect the public's trust and confidence in the employee, the agency,
or state government. Where the provisions of a collective bargaining agreement or
memorandum of understanding address involvement in volunteer activities (e.g.,
participation in fire -fighting activities), such provisions will control.
f. Approval of the Secretary of Administration is required for the following:
Supplementary employment, including voluntary activities, for employees
in senior level positions as defined in Management Directive 515.16,
Appointment to Senior Level Positions.
Storm, 20-001
Page 21
2. Supplementary employment involving political activity, with or without
compensation or remuneration.
43. During her tenure as the Victim Advocate, Storm submitted multiple supplementary
employment requests including:
a. 2014: DolGer Films
2015: ICF Inc.
2017: Parsons Company
2018: Hazelden Publishing
b. The requests were approved by Executive Branch Human Resource Departments,
44. Storm's requests for supplemental employment with DolGer Films, Parsons Company, and
Hazelden Publishing were related to the publishing of her memoir "Blackout Girl" and her
attempts to get her book made into a movie.
a. Storm was to speak on occasion as part of her publishing contract with Parsons
Company.
b. Storm obtained supplemental employment approval with Hazelden Publishing to
engage in follow-up writings.
45. On February 13, 2015, Storm submitted a Supplementary Employment Request form to
the Office of Administration seeking approval to work as a professional trainer for ICF
Incorporated, LLC.
a. On the application, Storm reported that the type of position was "trainer."
I . Storm provides training and educational resources as part of her position as
the Victim Advocate.
b. Storm reported that the workdays/hours of the supplemental employment with ICF
would be "S, M, TU, W HOURS UNKNOWN."
C. Storm answered "no" to questions on the form pertaining to the supplemental
employment creating an actual or potential conflict of interest with her
Commonwealth employment.
d. Storm answered "no" to a question pertaining to whether ICF Inc., LLC would be
associated with a political subdivision.
e. Storm signed the form, acknowledging that if any of the listed information changes
she would be required to submit a new form.
£ Storm swore and affirmed that the information she provided contained no omission
of material fact.
45. Storm's request for Supplementary Employment was submitted in accordance with
Management Directive 515.18.
Storm, 20-001
Page 22
47. ICF is a global advisory and digital services provider. Per its website, icf.com, ICF
combines unmatched expertise with cutting -edge engagement capabilities to help clients
solve their most complex challenges, navigate change, and shape the future.
a. The Office for Victims of Crime Training and Technical Assistance Center ("OVC
TTAC") provides training and technical assistance to victim services organizations.
b. OVC TTAC is operated by ICF under the Office of Justice Programs/Office for
Victims of Crime contract GS-00E-010CA DJO-OVC-16-G-0250.
48. Storm worked on three specific training assignments for OVC TTAC for which she was
compensated between 2015 and 2019.
a. For each assignment, OVC TTAC offers three blind resumes to the OVC TTAC
client to be selected from.
b. The presenter, in this instance Storm, utilized materials provided to her by OVC
TTAC and did not create or use any of her own PowerPoints, slides, or handouts.
C. The presentations given by Storm did not contain any information relating to her
employment as the Victim Advocate.
d. The materials utilized by Storm, provided to her by OVC TTAC, did not list her as
the Victim Advocate.
C. The three presentations given by Storm for OVC TTAC were compensation for
nonpublic, professional services.
49. Storm also made a presentation at the 2018 Victim Services Conference hosted by the
Delaware Criminal Justice Council ("CJC").
a. Storm did not seek supplementary employment approval to appear at this
conference.
b. Storm received payment from the State of Delaware for the presentation.
50. The CJC is an independent governmental agency of the State of Delaware, similar to
PCCD.
a. The CJC distributes federal grant dollars for juvenile justice, victim's laws,
offender reentry, and various victim services related programs and trainings
b. The CJC held a Victim Services Conference in March of 2018.
Storm, 20-001
Page 23
51. The 2018 CJC Victim Services Conference ("2018 CJC Conference") was for professionals
who deal with victims' services, such as mental health professionals, police, prosecutors,
and others to discuss relevant topics in the field.
a. Prospective attendees registered to attend and indicated on the registration what
agency or industry in which they worked.
b. A CJC working group, consisting of leaders in their network in varying professions
that deal with victims' services, accepted and verified the registration paperwork
for attendees.
C. The 2018 CJC Conference was free to attend.
52. The CJC working group selected speakers and topics relevant to the attendees in their
professions that provide victim services.
a. After topics were selected, the CJC working group contacted individuals with skill
sets related to those topics.
b. The CJC working group often asked already -selected speakers and those in their
network to provide suggestions for additional speakers/presenters.
53. The CJC booked Anne Seymour ("Seymour") of Justice Solutions, a nationally accredited
victim services speaker, to present at the 2018 CJC Conference.
a. Seymour recommended Storm as someone who is successful in the field of victim
services and could present on the topic "Professional Boundaries."
b. Storm disclosed to Commission investigators that she is a good friend of Seymour.
54. Between November 3, 2017, and March 21, 2018, Storm communicated with CJC officials
via her Commonwealth email account to make arrangements for her paid appearance at the
2018 CJC Conference.
a. Storm communicated her presentation plans and drafts to the CJC and also
discussed the 2018 CJC Conference budget in relation to the CJC's ability to pay
her a fee.
b. Storm began using her private email account on or about April 1, 2018, when
discussing payment options for her appearance.
55. On November 3, 2017, the CJC emailed Storm at her Commonwealth email address to
inquire if she would be interested in speaking at the 2018 CJC Conference on March 26-
27, 2018:
Storm, 20-001
Page 24
Kathleen D. Kelley [email address redacted] sent the following email to Storm:
Ustorm@pa.gov]:
"Hi Jennifer,
Anne Seymour gave me your contact information for a conference I am
coordinating that she'll be speaking at. The event is under the OVC VOCA-
Assistance Discretionary Grant Training Program. The conference is scheduled for
March 26,27, 2018, for Victim Service Professionals and Allies in Delaware. I told
her I was looking for a good speaker for a session about setting professional
boundaries, and she recommended you with very high praise!
I am happy to discuss details and answer any questions about the conference. If
you're a consultant with OVC-TTAC, I can submit the request through them. I
wanted to get an idea of your availability before moving ahead with the requests.
Thank you for the consideration; I hope to hear from you soon.
Kathleen Kelley"
56. On December 27, 2017, Storm replied to inquire about details, payment, and logistics for
the 2018 CJC Conference from her Commonwealth email account:
Storm U storm@pa.gov] sent the following email to Kathleen D. Kelley [email
address redacted]:
"Hello,
I wanted to follow -upon this and see if you were moving forward with the TTAC
application. I have a tentative hold on these dates.
Jennifer"
57. The CJC responded to Storm's inquiries on the same day to Storm's Commonwealth email
account:
Kathleen D. Kelley [email address redacted] sent the following email to Storm
U storm@pa.gov] :
"Thanks for following up, Jennifer! I contacted TTAC and they indicated I should
coordinate directly with you since we have grant funds for this event.
Kathleen Kelley"
a. OVC TTAC was not involved in planning or funding Storm's participation at the
2018 CJC Conference.
58. Storm responded with an email from her Commonwealth email account two minutes later
on December 27, 2017:
Storm Ustorm@pa.gov] sent the following email to Kathleen D. Kelley [email
address redacted]:
Storm 20-001
Page 25
"Awesome. A few questions then. What is your budget? How long of a presentation
are you looking for? Where is the event being held? Which date are your
requesting?
Jennifer"
59. On December 29, 2017, the CJC responded to Storm at her Commonwealth email account:
Kathleen D. Kelley [email address redacted] sent the following email to Storm
Ustorm@pa.gov]:
"Hi Jennifer,
The presentation we're looking for on setting professional boundaries has a time
slot of 75 minutes, with a possibility of an extra 15 minutes for questions. The event
is being held on Monday and Tuesday, March 26-27 at the Outlook at the Duncan
Center in Dover, DE. Your presentation is currently scheduled for the 26th, the
same day that Anne is speaking. Let's talk budget/speaking fee over the phone next
week. My schedule is pretty open except for Wednesday morning; is there a date
and time where you can spare 15 minutes for a call?
Please let me know a date/time that works for you and the best number to reach
you. I look forward to speaking with you; have a great weekend!
Kathleen Kelley"
60. Storm responded to Kelley with an email from her Commonwealth email account on
January 2, 2018:
Storm [ storm@pa.gov] sent the following email to Kathleen D. Kelley [email
address redacted] :
"IF you are available. I am free until 1 today: 717-214-2256."
61. On the same day, the CJC responded to Storm's Commonwealth email account:
Kathleen D. Kelley [email address redacted] sent the following email to Storm
Ustorm@pa.gov]:
"Great! I will call at 1 Oam.
Kathleen Kelley"
62. Although Storm took her personal vehicle to Delaware, she originally planned on taking
the trip via Amtrak, and sent the following email on January 8, 2018, to the CJC from her
Commonwealth email account, along with a train schedule:
Storm [storm@pa.gov] sent the following email to Kathleen D. Kelley [email
address redacted]:
"I hope this comes through okay, if you want me to stick around later on Tuesday
then I would have to depart on Wednesday. Whichever works for you!"
Storm, 20-001
Page 26
63. Storm was sent an email by the CJC at her Commonwealth email address on January 31,
2018, containing her biographical information pulled from her website by the CJC.
Kathleen D. Kelley [email address redacted] sent the following email to Storm
[jstorm@pa.gov]:
"Yes, that sounds good. I'll call (717) 214-2256 at 10:30am tomorrow (2/1).
On another note, we heard back from our CEI provider. They requested the
following information and I inserted what I could (open to editing by you).
Name and Degree(s) held: Jennifer Storm, BS in Rehabilitation Services, MS in
Organizational Management
Title of Presentation: Professional Boundaries in Victim Services
Brief Speaker Bio: (From your website) Jennifer Storm is the Victim Advocate for
the Commonwealth of Pennsylvania. As Victim Advocate, she is responsible for
representing the rights and interests of crime victims before the Board of Probation
and Parole and the Department of Corrections and to provide notification to crime
victims of the potential for inmate release, opportunity to provide testimony, and
notification of the inmate's movement within the correctional system. Further, Ms.
Storm is responsible for advocating the interests of adult and juvenile crime victims
throughout Pennsylvania. Ms. Storm has received several awards including the
2012 Gail Burns Smith Award from the National Crime Victim Law Institute, the
2012 Liberty Bell Award from the Dauphin County Bar Association, and the 2011
Pathfinder Award for Excellence in Victims Services in the Commonwealth of PA.
She served on the Victims Advisory Board for a four year term. She also serves on
the Criminal Justice Advisory Committee, Mental Health Advisory Committee,
Pennsylvania Commission on Crime and Delinquency, Victim Services Advisory
Committee, PA Commission on Sentencing, Crime Victims Alliance of PA, the
State Council for The Interstate Compact on Juvenile and Adult Offenders and
chairs the PA Task Force on Restitution. Jennifer Storm was born and raised near
Allentown, PA and attended Northampton High School. She graduated from
Pennsylvania State University with a Bachelor of Science in Rehabilitation
Services and a Master's Degree in Organizational Management from the University
of Phoenix. Most recently Jennifer received a certificate from Cornell University
in Conflict Resolution and Dispute Management.
Brief description of the session including an indication of it's a) content, b)
objectives and c) format:
a) Content Summary (2-3 sentences):
b) 2-3 Learning Objectives:
c) Format
The info for CEUs does not have to be elaborate, so I'm happy to take notes during
our call tomorrow, unless you'd prefer to send your edits separately. Thank you!
Kathleen Kelley"
Storm, 20-001
Page 27
64. In the 2018 CJC Conference Agenda, the following biography appeared for Storm, which
included her position as the Victim Advocate:
JENNIFER STORM, Commonwealth Victim Advocate, Pennsylvania Office of the
Victim Advocate
Jennifer Storm is the Victim Advocate for the Commonwealth of Pennsylvania. As
Victim Advocate, she is responsible for representing the rights and interests of
crime victims before the Board of Probation and Parole and the Department of
Corrections and to provide notification to crime victims of the potential for inmate
release, opportunity to provide testimony, and notification of the inmate's
movement within the correctional system. Further, Ms. Storm is responsible for
advocating the interests of adult and juvenile crime victims throughout
Pennsylvania.
Ms. Storm has received several awards, including the 2012 Gail Burns Smith
Award from the National Crime Victim Law Institute, the 2012 Liberty Bell Award
from the Dauphin County Bar Association, and the 2011 Pathfinder Award for
Excellence in Victims Services in the Commonwealth of PA. She served on the
Victims Service Advisory Board for a four year term.
She also serves on the Criminal Justice Advisory Committee, Mental Health
Advisory Committee, Pennsylvania Commission on Crime and Delinquency,
Victim Services Advisory Committee, PA Commission on Sentencing, Crime
Victims Alliance of PA, the State Council for The Interstate Compact on Juvenile
and Adult Offenders and chairs the PA Task force on Restitution.
Jennifer Storm was born and raised near Allentown, PA and attended Northampton
High School. She graduated from Pennsylvania State University with a Bachelor of
Science in Rehabilitation Services and a Master's Degree in Organizational
Management from The University of Phoenix. Most recently Jennifer received a
certificate from Cornell University in Conflict Resolution and Dispute
Management.
65. The CJC compensates conference speakers through travel reimbursement and/or speaking
fees.
a. The CJC negotiates with speakers and/or their representatives and then obtains a
signed contract between both parties.
b. A copy of the signed contract is then sent to the Delaware Division of Accounting
for payment.
66. CJC conference speakers are required to register as a vendor with the State of Delaware
Division of Accounting.
a. In order to register as a vendor with the State of Delaware Division of Accounting,
Storm submitted a Delaware Substitute Form W-9.
Storm, 20-001
Page 28
67. Storm signed a contract with the CJC on January 29, 2018, as "Conference Speaker."
68. Storm's contract with the CJC required Storm's attendance at the 2018 CJC Conference on
March 26 and 27.
a. Storm negotiated an hourly rate of $81.25 or $650 per diem based on an eight -hour
workday.
b. Under "Deliverables," the contract required Storm to prepare and present two
training sessions: "Professional Boundaries in Victim Services" and "The Role of
Victim Services in Offender Reentry" (tentative titles).
C. The contract permitted reimbursement for mileage at a rate of $0.545 per mile and
meals and incidental expenses at a rate of $40.50/travel day, $54.00/full day in
Dover, Delaware.
d. The contract stipulated that the CJC was responsible for the reservation and
payment of two nights of lodging at a hotel in Dover, Delaware.
e. The contract disclosed that the CJC utilized funds secured through a grant awarded
to the CJC through the US Department of Justice, Office for Victims of Crime,
VOCA Discretionary Training Program.
69. At the 2018 CJC Conference, Storm presented on two topics, "The Role of Victim Services
in Offender Reentry" and "Professional Boundaries in Victim Services."
a. Even though Storm was originally contacted to offer one presentation, Storm and
Seymour decided to present together for the second of Storm's presentations.
70. "The Role of Victim Services in Offender Reentry" was listed in the program as presented
by "Anne Seymour, Justice Solutions & Jennifer Storm, Victim Advocate for the
Commonwealth of Pennsylvania."
a. "The Role of Victim Services in Offender Reentry" was scheduled for 10:30 —
11:45 a.m.
b. The description of the session was, "The majority of incarcerated offenders will
eventually return to the community. What types of services and support do their
victims need and deserve? This session will focus on promising practices,
programs, and protocols that identify and meet the needs of crime victims and
survivors when their offenders prepare to reenter the Community."
71. Storm utilized a PowerPoint slideshow during the "Role of Victim Services in Offender
Reentry" presentation at the 2018 CJC Conference.
5to , 20-001
Page 29
a. The first page of the slideshow listed Jennifer Storm, Pennsylvania Victim
Advocate as a presenter.
b. The slideshow described the learning objectives of the session as: "Describe
victims' major needs throughout reentry process; Identify survivors' rights and
services needed throughout reentry; and Identify the components of a Victim
Transition Protocol for reentry."
C. The slideshow contained information and education resources.
1. One of the listed resources was the Pennsylvania Office of Victim
Advocate, http://www.ova.pa.gov/pages/default,aspx.
d. The slideshow's final slide titled "For More Information" listed contact information
for Jennifer Storm as jstormgpa.gov.
e. The slideshow did not have an OVA watermark.
f. The slideshow was created by Seymour and Storm.
1. On March 20, 2018, Seymour sent the CJC the PowerPoint presentation.
Seymour ce'd Storm's Commonwealth address on the email.
Anne Seymour [email address redacted] sent the following email to
Kathleen D. Kelley [email address redacted] Storm
Ustorm@pa.gov] CC: Jeri Storm Ustorm@pa.gov]:
"Hi Kathleen, we are attaching our slide deck for our reentry/victims
plenary — we think it will be fabulous!
Also, is it possible to get copies made for participants of the one
page Victim Transition Protocol, attached?
FINALLY, have you made hotel reservations for me for Sunday
and Monday night? Went through emails and could not figure it
out!
I am working on finalizing "Advancing Victims' Rights" slide deck,
and will have to you by tomorrow at the latest.
VERY excited for conference and lovely drive North, hope the
weather improves!
Anne Seymour"
72. "Professional Boundaries in Victim Services" was listed in the program as presented by
"Jennifer Storm, Victim Advocate for the Commonwealth of Pennsylvania."
a. "Professional Boundaries in Victim Services" was scheduled for 1:00 — 2:30 p.m.
Storm, 20-001
Page 30
b. The description of the session was, "This session will be about setting professional
boundaries within the context of delivering victim services. How to properly
engage clients in trauma informed care without crossing ethical or professional
boundaries will be the focus. This session will address specific interactions
survivors/advocates and clients — knowing when to put your survivor self on the
shelf."
73. Storm utilized a PowerPoint slideshow during the "Professional Boundaries in Victim
Services" presentation at the 2018 CJC Conference.
a. The first page of the slideshow listed Jennifer Storm, Victim Advocate of the
Commonwealth of Pennsylvania as well as "The Pennsylvania Office of Victim
Advocate (OVA) is dedicated to representing, protecting and advancing the
individual and collective rights and interests of crime victims."
b. The slideshow stated, "Appropriate boundaries increase our ability to provide
quality victims services."
C. Each slide in the 33 page slideshow featured the logo/watermark of OVA in the
bottom right-hand corner.
d. The slideshow was created solely by Storm.
Storm provided the PowerPoint to the CJC in an email dated February 20,
2018, from her Commonwealth email account:
"Okay I worked all weekend and think I am happy with this as the final
product. If you see something you are not comfortable with, please let me
know and I can make adjustments when I return from Europe. I do have two
handouts, one for the exercise and one that will give them a sample set of
standards. I will bring those if you can just let me know how many copies
Thank you!"
74. OVA's website lists "training" as a resource provided by the office.
a. The website containing training links can be found at the OVA's Commonwealth
website at https://www.ova.pa.gov/Resources/Training/Pages/default.asp .
b. The logo on the website is the same logo used by Storm during her "Professional
Boundaries in Victim Services" presentation at the 2018 CJC Conference.
C. On the training/resources website, the OVA describes "Institutional Offerings"
wherein the OVA partners with DOC to bring programs to raise awareness of the
long term effects that crime has on victims/survivors, their families and
communities.
Storm, 20-001
Page 31
1. Under the same "Institutional Offerings" heading, the website states that
OVA staff take part in events and activities to generate dialogue around
issues of redemption, restoration, rehabilitation and responsibility to
prepare those who are close to release and to plant roots of these concepts
to long serving offenders.
75. The slideshow presentations given by Storm at the 2018 CJC Conference for which she
received payment were directly related to her public position as the Victim Advocate.
a. Storm's public position as the Victim Advocate was not a mere backdrop against
which Storm described her life history or personal experiences prior to holding the
position of the Victim Advocate at the 2018 CJC Conference.
b. The group spoken to at the 2018 CJC conference consisted of professionals in the
field of victim services.
C. The purpose of the 2018 CJC Conference was to educate professional victim
services providers.
d. Storm was invited to speak at the 2018 CJC Conference specifically because of her
knowledge and expertise in the area of victim services and offender reentry, which
were her primary job duties as the Victim Advocate.
76. Kelley confirmed to Commission investigators that she personally attended the 2018 CJC
Conference and confirmed that Storm did present slideshows on topics as described in the
Conference Agenda.
77. The presentation Storm made at the 2018 CJC Conference was nearly identical to a
presentation Storm made before the Pennsylvania Senate.
a. On June 26, 2019, Storm provided written testimony re: Parole Reform to the
Pennsylvania Senate Judiciary Committee.
1. The full text of the testimony can be found at
htWs://judiciary pasenate op.copVm
content/uploads/sites/42/2019/06/storm 2.pdf.
b. The testimony before the Pennsylvania Senate Judiciary Committee covered
offender reentry and its effect on victims' rights.
78. Storm submitted the following invoice to the CJC from her personal Gmail account
following the 2018 CJC Conference:
Storm, 20-001
Page 32
Jennifer Storm
Jennifer Storm
TO:
Kathleen Kelley, Senior Criminal Justice Planner
Carvel State Building
820 N. French Street, loth Floor
Wilmington, DE 19801
INVOICE
INVOICE #001
DATE: MARCH 29, 2018
FOR:
DE Victim Services Conference
DESCRIPTION
QUANTITY
RATE
1 Day of Preparation
8.0
$81.25
1 Day of Travel
8.0
$81.25
1.5 Day of Training
12.0
$81.25
.5 Day of Training
4.0
$81.25
TOTAL
$2,600.00
Make all checks payable to Jennifer Storm
Total due within 30 days of this invoice as per contract.
Thank you for your business!
AMOUNT
$650.00
$650.00
$975.00
$325.00
79. On April 30, 2018, Storm emailed Kelley from her personal Gmail account, to confirm
receipt of payment for travel reimbursement, but questioned if the honorarium would arrive
separately.
Storm Uenniferstorml19@gmail.com] sent the following email to Kathleen D.
Kelley [KathleenD.Kelley@state.de.us]:
"Hello,
I did get a check today but only for the travel reimbursements, does the honorarium
come separately? Your controller's office called me last week to verify my w-9.
Thanks,
Jennifer"
Storm, 20-001
Page 33
a. Storm submitted meal receipts and a Delaware Division of Accounting itemized
report for reimbursement for Governor's Cafe, Chick-fil-A, Cheesecake Factory,
and Piccolini Italian Restaurant.
Storm received $83.77 for meal reimbursement.
b. Storm received $244.71 for mileage costs at a rate of $0.545 per mile for 449 total
miles.
1. Storm traveled from her personal residence to her hotel in Dover, Delaware,
on March 25, 2018, spoke at the 2018 CJC Conference on March 26, 2018,
and performed on -site consulting at the 2018 CJC Conference and traveled
back to her personal residence on March 27, 2018.
2. On -site Consultation included Storm's availability for attendee questions
and informal discussion on the best practices for victim services providers.
3. Storm traveled in her private car.
The CJC paid for Storm's lodging, which cost $186.00 for two nights' stay at the
Home2 Suites Hotel (222 S. Dupon Highway, Dover, Delaware) on March 25 and
26 while she presented at the 2018 CJC Conference.
d. A payment issued in the amount of $328.48 was deposited on April 30, 2018, into
Storm's personal checking account with Members I" Federal Credit Union.
80. The invoice Storm submitted to the CJC was approved for payment on May 10, 2018, by
Delaware Business Manager Julie Bolline with the description "conference speaker."
a. A payment issued in the amount of $2,600.00 was deposited on May 17, 2018, into
Storm's personal checking account with Members 1 st Federal Credit Union.
81. Storm received a total of $2,928.48 from Delaware to attend and present at the 2018 CJC
Conference in March 2018, which included the $2,600.00 payment and expenses.
82. Storm never submitted a Supplementary Employment Request to present at the 2018 CJC
Conference.
a. In accordance with Management Directive 515.18, employees are required to
resubmit requests when changing supplementary employment or whenever the
duties of either their Commonwealth or supplementary employment position
change substantially.
b. Storm was never approved to appear at this conference as a compensated presenter.
83. Despite listing the amount received as part of total consulting fees received in 2018, Storm
did not separately disclose the income she received from Delaware for her presentations at
the 2018 CJC Conference on the Statement of Financial Interests she filed for the 2018
calendar year.
Storm,20-001
Page 34
a. As an appointed public official, Storm was required to annually file a Statement of
Financial Interests with the Ethics Commission.
84. Despite identifying the consulting fees that included the fees from the Delaware
presentation generally, Storm did not separately disclose the income she received from
Delaware for her presentations at the 2018 C3C Conference on her 2019 Code of Conduct
Statement of Financial Interests for 2018 filing year that she was required to file with the
Governor's Office.
85. On her website, Storm has a list of "Conferences & Events that she has keynoted and/or
presented at" which can be found at https://jenniferstorm.com/bio/past-appearancesl.
The 2018 C.IC Conference does not appear on that list.
86. Storm obtained payment of $2,600.00 from Delaware.
THE FOLLOWING FINDINGS PERTAIN TO STORM'S FAILURE TO MAKE
REQUIRED FINANCIAL DISCLOSURES ON STATEMENTS OF FINANCIAL
INTERESTS.
87. Storm, in her capacities as the Victim Advocate, a Member of PCCD, and a Member of
VSAC, was required to file a Statement of Financial Interests ("SFI") form on an annual
basis, reporting among other mandated disclosures, financial information for the prior
calendar year.
a. Storm was first appointed as the Victim Advocate on November 8, 2013. She was
confirmed by the Pennsylvania Senate on December 10, 2013.
88. Storm, in her capacity as the Victim Advocate, was also subject to the Governor's Code of
Conduct and required to file a Code of Conduct foam.
a. All Commonwealth employees/officials of the Executive Branch are subject to the
Governor's Code of Conduct.
b. The Governor's Code of Conduct includes language on restricted activities,
conflicts of interest and adverse pecuniary interests.
C. The Governor's Code of Conduct provides that an employee, appointee or official
in the Executive Branch of the Commonwealth may not do the following:
(1) Engage directly or indirectly in business transactions or private arrangement
for profit which accrues from or is based upon his official position of authority.
89. In her public positions, Storm filed SFIs with the Pennsylvania State Ethics Commission
and Code of Conduct forms with the Office of the Governor.
90. Storm's SFI filing for calendar year 2017 contained the following:
Storm, 20-001
Page 3 5
Calendar year:
Date Piled:
Public Position:
Governmental Entity:
Occupation/Profession:
Real Estate Interests:
Creditors:
Direct/Indirect
Source of Income:
Gifts:
Transportation, Lodging,
Hospitality:
Office, Directorship or
Employment in any Business:
Financial Interests in any Legal
Entity and Business for Profit:
Business Interests transferred to
an immediate family member:
2017
3/6/201 S
Probation and Parole
PCCD
VSAC
Camp Hill HRC
Dir Off Victim Advct P&P
Commissioner
Commissioner
Chairwoman
Victim Advocate of PA
None
Members 1st
3512 Market St.
Camp Hill, PA
Interest Rate: 2%
Probation and Parole
1101 S Front St Harrisburg, PA 17104
The Parsons Agency, Walnut Creels California
Hazelden Betty Ford Foundation, Minnesota
Kings College, Wilkes-Barre, PA
None
None
Commonwealth of PA, PBPP, Victim Advocate
Hazelden Publishing, Author
Kings College, Trainer
The Parsons Agency, Author/Speaker
OVC TTAC, Trainer
None
None
Storm, 20-001
Page 36
91. Storm routinely traveled out of state in her position as the Victim Advocate.
a. Storm traveled out of state on 23 occasions between 2016 and 2019.
b. Storm's travel to out of state locations required approval by the Office of the
Governor pursuant to Commonwealth travel policies.
C. Storm's travel would include going to the National Crime Victim Law Institute
("NCVLI") annual conferences.
92. Some of Storm's travel expenses were paid by vendors or conference hosts.
a. Expenses in excess of $650,00 paid by vendors or conference hosts are required to
be disclosed on SFIs.
b. The NCVLI paid Storm's expenses for her travel to that group's annual conferences
in her capacity as a Member of the Board of Directors.
93. NCVLI is a Section 501(c)(3) nonprofit legal education and advocacy organization based
at Lewis & Clark Law School in Portland, Oregon. NCVLI's mission is to actively
promote balance and fairness in the justice system through crime victim centered legal
advocacy, education, and resource sharing.
a. Storm was a Member of the Board of Directors of NCVLI in 2017, 2018, and 2019.
1. Storm resigned from the NCVLI Board of Directors following her
resignation as the Victim Advocate.
94. Storm failed to disclose transportation, lodging, and hospitality totaling $842.77 from
NCVLI for the Voices for Justice Reception held on January 25, 2017.
a. During an interview with the Investigative Division, Storm told investigators that
her failure to list travel/hospitality/lodging received from NCVLI was an oversight
that had occurred due to the close proximity to the date of the conference with the
passing of her father. She told investigators that she had not originally planned to
attend but did so at the last minute.
95. Storm received travel reimbursement in 2017 from NCVLI as follows:
Check Date Check Number Payor Payee Amount Check Description
2/27/2017 1154 National Crime Victim Jennifer Storm 842.77 VFJ Travel Reimb.
Law Institute
96. The SFI Storm filed for calendar 2018 included the following:
Calendar Year: 2018
Date Filed: 2/26/19
Public Position: Probation and Parole
Commission on Crime and Deliqu
Victim Services Advisory Commi
Interstate Compact for Adult 0
5tonn, 20-001
Page 37
Governmental Entity
Occupation/Profession:
Real Estate Interests:
Interstate Compact for Juvenil
Sentencing Commission
Child Advocacy Committee
Camp Hill Human Relations Comm
National Crime Victim Law Inst
Criminal Justice Advisiy Commi
Victim Advocate
Commissioner
Member
Member
Member
Ex-Officio Member
Member
Chair
Board Member
Member
Victim Advocate of PA
None
Creditors: Members 1" 2% interest rate
PSECU: 2% interest rate
Bank of America: 9% interest rate
Toyota Financial: 7% interest rate
Direct/Indirect
Source of Income: Probation and Parole, 1101 S Front St Harrisburg, PA 17104
Hazelden Publishing, 15251 Pleasant Valley Road Center City, MN
55012
Parsons Company Inc, 1630 N Main Street Suite 412 Walnut Creek,
CA 94596
ICF, 9300 Lee Highway Fairfax, VA 22031
Gifts: None
Transportation, Lodging, None
Hospitality:
Office, Directorship or Comm. Of PA, PBPP, Victim Advocate
Employment in Any Business Hazelden Publishing, Author
Parsons Company Inc, Author/Speaker
ICF, Trainer
Storm, 20-001
Page 38
Financial Interests in any Legal
Entity and Business for Profit: None
Business Interests transferred to
an immediate family member: None
a. Storm transposed the Public Position or Public Office and Governmental Entity
blocks in her 2018 SFI.
97. Storm failed to disclose and/or otherwise identify the State of Delaware as a direct or
indirect source of income for payments Storm received in calendar year 2018 for her
presentation at the 2018 CJC Conference, which exceeded the $1,300.00 threshold to be
disclosed on her SFI:
Check Date Check Number Payor Payee Amount
4/25/2018 1441893 State of Delaware Vendor Payment Account Jennifer Storm 328.48
5/10/2018 1449604 State of Delaware Vendor Payment Account Jennifer Storm 2,600.00
TOTAL 2,928.48
98. Storm received
$514.48 from the State of Delaware
in calendar year 2018 for
transportatioidlodging/hospitality for her presentation at the
2018 CJC conference.
Date
Description
Amount
3/26/2018
Home2 Suites Hotel, Two Nights
$186.00
3/25/2018
Mileage to Travel to Delaware
$117.18
3/26/2018
Mileage to Conference
$1.09
3/27/2018
Mileage Onsite Consulting and Travel
$126.44
3/25/2018
Governors Cafe
$19.49
3/26/2018
Chic Fit A
$6.93
3/26/2018
Cheesecake Factory
$39.35
3/27/2018
Piccolini Italian
$18.00
Total
$514.48
a. This amount was not required to be disclosed on her SFI because the payments did
not exceed the $650.00 reporting threshold.
99. The SFI Storm filed for her nomination for a new term as the Victim Advocate through the
Governor's Office as the Victim Advocate for calendar 2019 included the following:
Calendar Year: 2019
Date Filed: 1/10/2020
Storm, 20-001
Page 39
Public Position: Victim Advocate
Commissioner - HOLD
Member - HOLD
Commissioner & Chair of Board - HOLD
Member — HELD
Member — HOLD
Member — HOLD
Member — HOLD
Governmental Entity: Probation & Parole --- Office of the Victim Advocate
Pennsylvania Commission Crime and Delinquency
Victim Services Advisory Committee
Borough of Camp Hill Human Relations Commission
Pennsylvania Commission on Sentencing
State Council for Interstate Adult Offender Supervision
State Council for Interstate Juvenile Supervision
The Children's Advocacy Center Advisory Committee
Occupation/Profession: Victim Advocate
Real Estate Interests: None '
Creditors: Toyota Financial: 4.5% interest rate
American Education Services: 2.9% interest rate
Members 1 ": 11.5% interest rate
PSECU: 2.9% interest rate
Bank of America: 1.9% interest rate
Direct/Indirect
Source of Income: Commonwealth of Pennsylvania (Probation and Parole — Office of
Victim Advocate, 1101 S front St Harrisburg, PA 17104
ICF Consulting, 9300 Lee Highway Fairfax, VA 22031
Hazelden Publishing, 15251 Pleasant Valley Road Center City, MN
55012
Parsons Company Inc, 1630 N Main Street Suite 412 Walnut Creek,
CA 94596
Blackout Girl LLC, 2006 Princeton Ave Camp Hill, PA 17011
Gifts: None
Transportation, Lodging, Hospitality:
NCVLI — National Crime Victim Law
Institute
1130 SW Morrison
Portland, Oregon 97205
Value: $1,500.00
Street, Suite 200
Storm, 20-001
Page 40
Office, Directorship or Employment
in Any Business
Financial Interests in any Legal
Entity and Business for Profit:
Business Interests transferred to
an immediate family member:
ICF Consulting Group, Inc
9300 Lee Hwy, Fairfax, VA 22031
Hazelden Publishing 15251
Pleasant Valley Road Center City, MN
55012-0176
Position Held: Author
Parsons Company, Inc,
1630 N Main Street #412
Walnut Creek CA 94596
Position Held: Speaker
Blackout Girl LLC
2006 Princeton Ave
Camp Hill PA 17011
Position Held: President
NCVLI — National Crime Victim Law
Institute
1130 SW Morrison Street, Suite 200
Portland Oregon, 97205
Position Held: President Elect
Backout Girl LLC
2006 Princeton Avenue
Camp Hill, PA 17011
Interest Held : 100%
None
100. Storm submitted four additional SFIs for calendar year 2019 which included three amended
filings.
101. On February 6, 2020, Storm filed an SFI through the Office of Administration for calendar
year 2019 that included the following:
Calendar Year: 2019
Date Filed: 2/6/2020
Public Position: Probation and Parole - Seeking
Commission on Crime and Deliqu - Hold
Victims Services Advisory Commission - Hold
Interstate Compact for Adult 0 - Hold
Storm, 20-001
Page 41
Interstate Compact for Juvenil - Hold
The Children's Advocacy Center - Hold
Criminal Justice Advisory Comm — Hold
Camp Hill Human Relations Comm — Hold
Sentencing Commission --- Held
PA Task Force on Restitution — Held
Dauphin County Domestic Violen — Held
Office of Victim Advocate - Held
Governmental Entity:
Victim Advocate - Seeking
Commissioner - Hold
Member - Hold
Member - Hold
Member - Hold
Member - Hold
Member — Hold
Char and Commissioner --- Hold
Ex Officio — Held
Chair ---- Held
Member -- Held
Victim Advocate - Held
Occupation/Profession:
Victim Advocate of PA
Real Estate Interests:
None
Creditors:
Direct/Indirect
Source of Income
Members 1st:
PSECU:
Bank of America:
Toyota Financial:
2% interest rate
2% interest rate
9% interest rate
7% interest rate
Probation and Parole, 101 S Front St. Harrisburg, PA 17104
Hazelden Publishing, 15251 Pleasant Valley Road Center City, MN
55012
Parsons Company Inc, 1630 N Main Street Suite 412 Walnut Creek,
CA 94596
ICF Consulting, 9300 Lee Highway Fairfax, VA 22031
Blackout Girl LLC, 2006 Princeton Ave Camp Hill, PA 17011
Gifts: None
Transportation, Lodging, Hospitality: National Crime Victim Law Institute
1130 SW Morrison Street, Suite 200 Portland,
Oregon 97205
Value: $1,500.00
Stonn, 20-001
Page 42
Office, Directorship or Employment Commonwealth of PA, PBPP
in Any Business Position Held: Victim Advocate
Hazelden Publishing
PO Box 11 Center City MN
Position Held: Author
The Parsons Agency
1630 N Main Street 4412
Walnut Creek CA 94596
Position Held: Author/Speaker
ICF
Position Held: Trainer
Blackout Girl LLC
2006 Princeton Ave
Camp Hill PA 17011
Position Held: Owner
Financial Interests in any Legal
Entity and Business for Profit: Backout Girl LLC
2006 Princeton Avenue
Camp Hill, PA 17011
Interest Held: 100%
Business Interests transferred to
an immediate family member: None
102. Storm filed an amended SFI for calendar year 2019 on March 13, 2020, amending as
follows:
a. Direct or Indirect Sources of Income - Global Peace Film Festival PO Box 3310
Winter Park, FL 32790-3310
b. Transportation, Lodging, Hospitality — changed the value from $1,500.00 to
$1,380.42
C. Global Peace Film Festival is the vendor that Storm used to collect donations for
Blackout Girl, a documentary film based on her memoir.
103. Storm filed a third SFI for calendar year 2019 (through the Governor's Office — her
appointing authority) on June 12, 2020, which did not include the Global Peace Film
Festival under Direct/Indirect Sources of Income but included disclosures for
Transportation, Lodging and Hospitality, as follows:
Transportation, Lodging, Hospitality:
Storm, 20-001
Page 43
*NCVLI — National Crime Victim Law Institute
1130 SW Morrison Street, Suite 200
Portland Oregon, 97205
Value - $1,500.00
*This expense was paid directly by the Commonwealth for Mrs. Storm's attendance of the
annual NCLVI board meeting and conference event in Portland. The listed travel and
lodging expenses were booked by and paid for by the Commonwealth, and reimbursed
directly to the Commonwealth by NCVLI without the involvement of Mrs. Storm.
a. This form was filed through the Governor's Office as there was no action in 25
session days on Storm's nomination.
104. Storm filed a fourth overall SFI for calendar year 2019 (through the Governor's Office --
her appointing authority) on June 18, 2020, which added "Acting Victim Advocate —
HOLD" under Section 4 — Public Position or Public Office on the second page, Statement
of Financial Interest Form Addendum.
105. Storm failed to disclose and/or otherwise identify direct or indirect sources of income in
calendar year 2019 in the amount of $5,000.00 received from Kathleen M. Bernhard
("Bernhard"), which were required to be disclosed on her SFIs:
Check Date Payee Amount Payor Memo
5/1/2019 Jennifer Storm 600.00 Kathleen M. Rent —
Bernhard May
6/1/2019 Jennifer Storm 600.00 Kathleen M. June Rent
Bernhard
7/1/2019 Jennifer Storm. 600.00 Kathleen M. Rent July
Bernhard
8/1/2019 Jennifer Storm 600.00 Kathleen M. Rent
Bernhard
9/3/2019 Jennifer Storm 600.00 Kathleen M. Rent
Bernhard
10/1/2019 Jennifer Storm 800.00 Kathleen M. Rent
Bernhard
11/1/2019 Jennifer Storm 600.00 Kathleen M. Rent
Bernhard
12/1/2019 Jennifer Storm 600.00 Kathleen M. Dec Rent
Bernhard
TOTAL 5,000.00
Storm, 20-001
Page 44
a. Bernhard resided in Storm's personal residence in the finished lower level of the
home from May 2019 through February 2020.
b. Bernhard is a longtime friend of Storm's spouse, Fianne Van-Schaaik. Bernhard
met Storm through Van-Schaaik and they became friends.
C. Bernhard paid Storm $600 per month via check for rent.
d. Bernhard did not execute a written lease agreement/contract for the rental. The per
month figure was agreed on, orally, by the parties.
1. Storm asserted to Commission investigators that a rental agreement existed.
e. Storm did not rent the space previously, nor has she rented the space to any other
tenants after Bernhard.
III. DISCUSSION:
In her capacities as: (1) a Member of the Pennsylvania Commission on Crime and
Delinquency ("PCCD") beginning in 2003; (2) a Member of the PCCD Victims' Services
Advisory Committee ("VSAC") beginning in 2011; and (3) the Victim Advocate for the
Commonwealth of Pennsylvania from November S, 2013, until January 29, 2021, Respondent
Jennifer Storm, also referred to herein as "Respondent," "Respondent Storm," and "Storm," has
been a public official/public employee subject to the provisions of the Public Official and
Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et sec .
The allegations are that Storm violated Sections 1103(a), 1103(c), 1103(d), 1104(a),
1104(d), 1105(b)(5), and 1105(b)(7) of the Ethics Act:
(1) When she used the authority of her public office as the Victim Advocate for a
private pecuniary benefit of herself and/or a business with which she is associated,
namely The Blackout Girl, LLC, by advocating for the enactment of Marsy's Law
in Pennsylvania, at a time when she and/or The Blackout Girl, LLC, accepted
money and/or other items of value from a lobbyist representing a principal seeking
to influence legislative action regarding Marsy's Law in Pennsylvania;
(2) When, as a Member of the VSAC and/or PCCD, she utilized the authority of her
public office to approve disbursement of grant funding to entities at a time when
she and/or The Blackout Girl, LLC, accepted money and/or other items of value
from individuals associated with those entities receiving grant funding;
(3) When, as the Victim Advocate, she accepted improper influence when she and/or
The Blackout Girl, LLC, received money or other items of value in an effort to
finance a movie ("The Blackout Girl") with the understanding that she would
continue to work to promote the passage of Marsy's Law in Pennsylvania;
(4) When, as a Member of the VSAC and/or PCCD, she accepted improper influence
when she and/or The Blackout Girl, LLC, accepted money or other items of value
in an effort to finance a movie ("The Blackout Girl") with the understanding that
Storm, 20-001
Page 45
she would vote/continue to vote to approve disbursement of grant funding through
PCCD to organizations affiliated with the person(s) providing money/items of
value to Storm/The Blackout Girl, LLC;
(5) When she accepted an honorarium for her speech/presentation at the 2018 Delaware
Statewide Victim Services Conference;
(6) When she utilized Pennsylvania Office of Victim Advocate work product in
furtherance of her appearance(s), speech(es) and/or presentation(s) at the 2018
Delaware Statewide Victim Services Conference; and
(7) When she failed to disclose travel/hospitality/lodging provided by the National
Crime Victim Law Institute for travel to Portland, Oregon, for calendar year 2017,
and failed to identify all reportable sources of income for calendar years 2018 and
2019.
Pursuant to Section 1103(a) of the Ethics Act, a public official/public employee is
prohibited from engaging in conduct that constitutes a conflict of interest:
§ 1103. Restricted activities
(a) Conflict of interest. —No public official or public
employee shall engage in conduct that constitutes a conflict of
interest.
65 Pa.C.S. § 1103(a).
The term "conflict of interest" is defined in the Ethics Act as follows:
§ 1102. 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.
The term 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 Pa.C.S. § 1102.
Subject to the statutory exclusions to the Ethics Act's definition of the term "conflict" or
"conflict of interest," 65 Pa.C.S. § 1102, pursuant to Section 1103(a) of the Ethics Act, a public
Storms, 20-001
Page 46
official/public employee is prohibited from using the authority of public office/employment or
confidential information received by holding such a public position for the private pecuniary
benefit of the public official/public employee himself, any member of his immediate family, or a
business with which he or a member of his immediate family is associated.
Section 1103(c) of the Ethics Act provides in part that a public official/public employee
shall not solicit or accept anything of monetary value based upon any understanding that his vote,
official action or judgment would be influenced thereby:
§ 1103. Restricted Activities
(c) Accepting improper influence. —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 Pa.C.S. §1103(c).
Section 1103(d) of the Ethics Act prohibits a public official/public employee from
accepting an honorarium:
§ 1103. Restricted activities.
(d) Honorarium. --No public official or public employee
shall accept an honorarium.
65 Pa.C.S. § 1103(d).
The Ethics Act defines the term "honorarium" as follows:
§ 1102. Definitions
"Honorarium." Payment made in recognition of published
works, appearances, speeches and presentations and which is not
intended as consideration for the value of such services which are
nonpublic occupational or professional in nature. The term does not
include tokens presented or provided which are of de minimis
economic impact.
65 Pa.C.S. § 1102.
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The question of whether a given payment is an honorarium prohibited by Section 1103(d)
is determined by an application of the statutory definition set forth in the Ethics Act, not by the
mere label that may have been attached to the payment. Fiorello, Order No. 1363; Confidential
Opinion, 14-007; Confidential O inion, 01-001.
The statutory definition of "honorarium" generally includes payments that are made in
recognition of speaking engagements/presentations, appearances, and published works, but
excludes such payments if: (1) they are legitimately intended as consideration for the value of
such services; and (2) they are undertaken in the public official's/public employee's private
professional or occupational capacity and are not related to the public position. Fiorello, supra;
Confidential Opinion, 14-007; Confidential Opinion, 01-001,
Section 1104(a) of the Ethics Act provides that each public official/public employee must
file an SFI for the preceding calendar year, each year that he holds the position and the year after
he leaves it.
Section 1104(d) of the Ethics Act provides that no public official shall be allowed to take
the oath of office, or enter or continue upon his duties, nor shall he receive compensation from
public funds, unless he has filed an SFI as required by the Ethics Act.
Section 1105(b) of the Ethics Act and its subsections detail the financial disclosure that a
person required to file the SFI form must provide.
Subject to certain statutory exceptions, Section 1105(b)(5) of the Ethics Act requires the
filer to disclose on the SFI the name and address of any direct or indirect source of income totaling
in the aggregate $1,300 or more.
Subject to certain statutory exceptions, Section 1105(b)(7) of the Ethics Act requires the
filer to disclose on the SFI the name and address of the source and the amount of any payment for
or reimbursement of actual expenses for transportation and lodging or hospitality received in
connection with public office or employment where such actual expenses exceed $650 in an
aggregate amount per year.
As noted above, the parties have submitted a Consent Agreement and Stipulation of
Findings. The parties' Stipulated Findings are set forth above as the Findings of this Commission.
We shall now summarize the relevant facts as contained therein.
Background
In 2003, Storm was appointed as a Member of PCCD, which is an administrative
commission within the Office of the Governor. The purpose of PCCD is to establish goals,
objectives, and standards for the reduction of crime and delinquency and to more efficiently and
effectively coordinate these efforts. PCCD possesses the authority, in pertinent part, to disburse
available federal and state fiords to various applicants who seek financial assistance. In 2011,
Storm was appointed as a Member of the VSAC, which is housed within PCCD and serves in an
advisory capacity to PCCD.
Storm, 20-001
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From approximately 2003 to 2013, Storm served as the Executive Director of the Dauphin
County Victim/Witness Assistance Program, which provides assistance to witnesses and victims
of crime occurring in Dauphin County, Pennsylvania. Storm frequently attended high profile
criminal trials in other regions of the state, including the criminal trial of Jerry Sandusky
("Sandusky") in Centre County, Pennsylvania. Storm frequently attended the Sandusky legal
proceedings and commented to the media during the criminal trial.
Storm served as the Victim Advocate for the Commonwealth of Pennsylvania from
November 8, 2013, until her resignation effective January 29, 2021. The Victim Advocate has the
authority and the duty to represent the rights and interests of all Commonwealth crime victims in
general. Storm provided training and educational resources as part of her duties as the Victim
Advocate. Storm's frequent commentary at the high -profile Sandusky trial in 2012 and the
subsequent trial of Bill Cosby in Montgomery County, Pennsylvania, boosted both her position as
the Victim Advocate and her private business interests as an author, speaker, and filmmaker.
Storm's social media presence identified her as a victim rights expert, and she maintained a large
social media presence, including a webpage and Facebook and Twitter accounts.
Re: Storm's Approval of the Disbursement of Grant Funds as a Member of PCCD and/or
the VSAC
On September 16, 2014, Storm announced via her personal social media platform that she,
Danielle Hall Count, and DolGer Films had agreed on an option deal to produce a film based on
the screenplay adaptation of Storm's memoir, "Blackout Girl: Growing Up and Drying Out in
America," which was published in 2008. 1n an effort to raise capital to produce the film, Storm
solicited donations via her various social media platforms, including her personal website. Storm's
website identified and thanked numerous individuals who had contributed monetary funding to the
production of her film. Several of those persons who contributed funding for Storm's film were
officers, directors, or employees of entities receiving grant monies disbursed by PCCD.
The donors to Storm's film project included Lee Tarasi ("Tarasi"), who at the time was a
police officer for the Susquehanna Township Police Department. Storm accepted a $50.00
gift/donation from Tarasi for her film project during the same time period that she recommended
and voted to authorize the disbursement of grant monies to the Susquehanna Township Police
Department as both a Member of PCCD and the VSAC.
Per the Consent Agreement, the parties are in agreement that there is insufficient evidence
to establish that Storm solicited donations for her film project in return for her funding votes as
both a Member of PCCD and the VSAC.
Re: Storm's Advocacv for the Enactment of Marsy's Law
On December 21, 2017, Marsy's Law for Pennsylvania, LLC ("Marsy's Law PA") filed a
Lobbying Registration statement with the Pennsylvania Department of State as a registered
principal. Jennifer Merchant Riley ("Riley") was one of the lobbyists identified by Marsy's Law
PA as conducting lobbying on behalf of the principal. Marsy's Law PA initiated lobbying activity
in Pennsylvania in an effort to effectuate an amendment to the Pennsylvania Constitution, known
as Marsy's Law, to include crime victims' rights in the Pennsylvania Constitution Declaration of
Rights.
Storm, 20-001
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The Bravo Group is a registered lobbying firm with the Pennsylvania Department of State.
As the Victim Advocate, Storm participated in numerous communications, discussions, events,
and planning sessions with individuals from The Bravo Group, Marsy's Law PA, the Pennsylvania
District Attorney Association, and the Pennsylvania Department of State. The majority of the
communications focused on developing language of the proposed Marsy's Law constitutional
amendment to be presented before the Pennsylvania House and the Pennsylvania Senate.
Riley and representatives of The Bravo Group subsequently requested Storm to utilize her
influence as the Victim Advocate to support efforts to pass Marsy's Law. In particular: (1) on
April 2, 2018, Storm was asked to comment on a press release regarding Riley's new position with
Marsy's Law PA; (2) on July 17, 2018, Storm was asked for assistance in identifying a crime
victim who would be willing to be interviewed by the media in furtherance of advancing Marsy's
Law; (3) on August 10, 2018, Storm was asked to participate in a campus safety event to lobby
support for Marsy's Law; and (4) on November 5, 2019, Storm was asked to provide a quote for a
press release in support of the passage of Marsy's Law.
Riley, as a registered lobbyist and State Director of Marsy's Law PA, provided Storm with
a cash donation/gift of $50.00 in support of Storm's endeavor to complete the filming of "The
Blackout Girl" motion picture documentary. At the time that Riley made the donation to Storm,
Riley's employer was lobbying Storm to support. Riley's efforts to achieve the passage of Marsy's
Law.
Per the Consent Agreement, the parties are in agreement that there is insufficient evidence
to establish that Storm engaged in direct/indirect communication with lobbyists and/or otherwise
utilized the authority of her office as the Victim Advocate in furtherance of the passage of Marsy's
Law with the understanding that her doing so was predicated on receiving monetary donations/gifts
from lobbyists.
Re: Storm's Receipt of Payment for Presentations at a Conference
The Delaware Criminal Justice Council ("CJC") is an independent governmental agency
of the State of Delaware. On March 26 and 27, 2018, the CJC held a Victim Services Conference
in Dover, Delaware. The 2018 CJC Victim Services Conference ("2018 CJC Conference") was
for professionals who deal with victim services, such as mental health professionals, police,
prosecutors, and others, to discuss relevant topics in the field.
A CJC working group selected speakers and topics relevant to the attendees in their
professions. The CJC working group often asked already -selected speakers to provide suggestions
for additional speakers/presenters for the 2018 CJC Conference. The CJC booked Anne Seymour
("Seymour") of Justice Solutions, a nationally accredited victim services speaker, to present at the
2018 CJC Conference. Seymour recommended Storm as someone who is successful in the field
of victim services and who could present on the topic of "Professional Boundaries."
On November 3, 2017, Kathleen Kelley ("Kelley") of the CJC emailed Storm at her
Commonwealth email address to inquire if she would be interested in being a speaker at the 2018
CJC Conference for a session about "setting professional boundaries." In an email sent to Kelley
on December 27, 2017, Storm asked for more information about the proposed speaking
engagement. On December 29, 2017, Kelley sent an email to Storm that stated that the 2018 CJC
Conference would be held on March 26 and 27, 2018, in Dover, Delaware. Kelley indicated that
Storm, 20-001
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Storm's presentation on setting professional boundaries would be scheduled for March 26 and
would have a time slot of 75 minutes with the possibility of an extra 15 minutes for questions.
The CJC compensates conference speakers through travel reimbursement and speaking
fees. The CJC negotiates with speakers or their representatives and then obtains a signed contract
between both parties. A copy of the signed contract is then sent to the Delaware Division of
Accounting for payment. A conference speaker is required to register as a vendor with the
Delaware Division of Accounting.
On January 29, 2018, Storm signed a contract with the CJC to be a conference speaker.
Storm's contract with the CJC required Storm's attendance at the 2018 CJC Conference on March
26 and 27. The contract required Storm to prepare and present two training sessions with the
tentative titles of"Professional Boundaries in Victim Services" and "The Role of Victim Services
in Offender Reentry." Storm negotiated an hourly rate of $81.25 or $650.00 per diem for her
services. The contract permitted reimbursement for mileage at a rate of $0.545 per mile and meals
and incidental expenses at a rate of $40.50/travel day, $54.00/full day in Dover, Delaware. The
contract provided that the CJC was responsible for the reservation and payment of two nights of
lodging at a hotel in Dover, Delaware.
The biography for Storm that appeared in the 2018 CJC Conference Agenda identified her
as the "Victim Advocate for the Commonwealth of Pennsylvania" and noted that as the Victim
Advocate, "she is responsible for representing the rights and interests of crime victims before the
Board of Probation and Parole and the Department of Corrections and to provide notification to
crime victims of the potential for inmate release, opportunity to provide testimony, and notification
of the inmate's movement within the correctional system. Further, Ms. Storm is responsible for
advocating the interests of adult and juvenile crime victims throughout Pennsylvania." The
biography further noted Storm's service as both a Member of PCCD and a Member of the VSAC.
At the 2018 CJC Conference, Storm and Seymour presented together on the topic of "The
Role of Victim Services in Offender Reentry." Storm presented alone on the topic of "Professional
Boundaries in Victim Services."
The program for the 2018 CJC Conference listed "The Role of Victim Services in Offender
Reentry" as presented by "Anne Seymour, Justice Solutions & Jennifer Storm, Victim Advocate
for the Commonwealth of Pennsylvania." Storm utilized a PowerPoint slideshow during the
presentation of "The Role of Victim Services in Offender Reentry." The first slide of the slideshow
listed "Jennifer Storm, Pennsylvania Victim Advocate" as a presenter. The slideshow, which was
created by Storm and Seymour, contained information and educational resources, including the
web address for the Pennsylvania Office of Victim Advocate's website. The slideshow's final slide
listed Storm's Commonwealth email address as contact information for Storm. The slideshow did
not have a Pennsylvania Office of Victim Advocate watermark.
The program for the 2018 CJC Conference listed "Professional Boundaries in Victim
Services" as presented by "Jennifer Storm, Victim Advocate for the Commonwealth of
Pennsylvania." Storm utilized a PowerPoint slideshow during the presentation of "Professional
Boundaries in Victim Services." The first slide of the slideshow stated, "Jennifer Storm, Victim
Advocate of the Commonwealth of Pennsylvania" as well as "The Pennsylvania Office of Victim
Storm, 20-001
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Advocate (OVA) is dedicated to representing, protecting and advancing the individual and
collective rights and interests of crime victims." The slideshow was created solely by Storm, and
the bottom right-hand corner of each slide featured the logo/watermark of the Pennsylvania Office
of Victim Advocate.
The slideshow presentations given by Storm at the 2018 CJC Conference were directly
related to her public position as the Victim Advocate. The purpose of the 2018 CJC Conference
was to educate professionals in the field of victim services. Storm was invited to speak at the 2018
CJC Conference specifically because of her knowledge and expertise in the areas of victim services
and offender reentry, the areas in which she primarily performed her job duties as the Victim
Advocate. Storm's public position as the Victim Advocate was not a mere "backdrop" against
which Storm described her life history or personal experiences prior to holding the position of the
Victim Advocate.
Following the 2018 CJC Conference, Storm submitted an invoice dated March 29, 2018,
to Kelley. The invoice totaled $2,600.00 and was based upon charges at the rate of $81.25 per
hour for one day of preparation (8 hours, $650.00 total), one day of travel (8 hours, $650.00 total),
one and one-half days of training (12 hours, $975.00 total) and one-half day of training (4 hours,
$325.00 total). On April 30, 2018, Storm emailed Kelley from her personal Gmail account. In
her email, Storm confirmed that she had received payment from the CJC for travel reimbursement
and asked, "does the honorarium come separately?" The invoice was approved for payment on
May 10, 2018, and a payment in the amount of $2,600.00 from the State of Delaware was deposited
into Storm's personal checking account with Members 15t Federal Credit Union on May 17, 2018.
Re: Storm's SFIs
Stone, in her capacities as the Victim Advocate, a Member of PCCD, and a Member of the
V SAC, was required to annually file an SFI by May 1 containing information for the prior calendar
year.
Storm routinely traveled out of state in her position as the Victim Advocate. Storm's travel
included going to the National Crime Victim Law Institute ("NCVLI") annual conferences.
NCVLI paid Storm's expenses for her travel to the NCVLI's annual conferences. Storm failed to
disclose on her SFI for calendar year 2017 her receipt of transportation, lodging, and hospitality
totaling $892.77 from NCVLI in relation to her attendance at the Voices for Justice Reception held
on January 25, 2017.
As for Storm's SFI for calendar year 2018, Storm did not separately disclose Delaware as
a direct or indirect source of income in relation to the income she received for her presentations at
the 2018 CJC Conference. Instead, Storm included the income that she received from Delaware
as part of a general disclosure of the total consulting fees she received in 2018.
With regard to Storm's SFIs/amended SFIs for calendar year 2019, Storm failed to disclose
Kathleen M. Bernhard, who paid Storm $5,000.00 in 2019 for renting space in Storm's personal
residence, as a direct or indirect source of income.
Having highlighted the Stipulated Findings and issues before us, we shall now apply the
Ethics Act to determine the proper disposition of this case.
Storm, 20-001
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The parties' Consent Agreement sets forth a proposed resolution of the allegations as
follows:
3. The Investigative Division will recommend the following in relation
to the above allegations:
a. That no violations of Section 1103(a) of the Public
Official and Employee Ethics Act, 65 Pa.C.S. §
1103(a), occurred in relation to the allegations listed
[in the Investigative Complaint in this matter] due to
insufficient clear and convincing evidence. There is
no violation of Section 1103(a) relating to Storm's
utilization of Office of Victim Advocate work
product in relation to the 2018 Delaware Statewide
Victim Services Conference pursuant to Sims, Order
1769.
b. That a technical violation of Section 1103(d) of the
Public Official and Employee Ethics Act, 65 Pa.C.S.
§ 1103(d), occurred when Storm received payment
from the State of Delaware for presentations, which
included portions related to her position as Victim
Advocate, at the 2018 Victim Services Conference
hosted by the Delaware Criminal Justice Council.
All other presentations made by Storm during her
tenure in public office, of which the Investigative
Division has knowledge, did not constitute
honorariums and no violations of Section 1103(d)
occurred in relation to all such other presentations
made by Storm.
C. That technical violations of Section 1105(b)(5) and
(7) occurred when Storm failed to disclose
travel/hospitality/lodging provided by the National
Crime Victim Law Institute for travel to Portland,
Oregon for calendar year 2017; when, despite listing
the amount received as part of total consulting fees
received in 2018, Storm technically failed to
separately identify the State of Delaware as a
reportable source of income for calendar year 2018
similar to Sims, Order 1769; and when she failed to
identify rental income as a reportable source of
income in calendar year 2019.
d. The Investigation Division is not seeking
disgorgement of compensation of public monies
under Section 1104(d).
Storm,20-001
Page 53
4. Storm agrees to make payment in the amount of $3,000.00 in
settlement of this matter payable to the Commonwealth of
Pennsylvania and forwarded to the Pennsylvania State Ethics
Commission within sixty (60) days of the issuance of the final
adjudication in this matter.
5. Storm agrees to file complete and accurate amended Statements of
Financial Interests, with the Pennsylvania State Ethics Commission,
for calendar years 2017, 2018, and 2019 within thirty (30) days of
the issuance of the final adjudication in this matter.
6. Storm agrees to not accept any reimbursement, compensation or
other payment from the Commonwealth of Pennsylvania
representing a full or partial reimbursement of the amount paid in
settlement of this matter.
7. The Investigative Division will recommend that the State Ethics
Commission take no further action in this matter; and make no
specific recommendations to any law enforcement or other authority
to take action in this matter. Such, however, does not prohibit the
Commission from initiating appropriate enforcement actions in the
event of Respondent's failure to comply with this agreement or the
Commission's order or cooperating with any other authority who
may so choose to review this matter further.
Consent Agreement, at 2-3.
It appears that the Investigative Division in the exercise of its prosecutorial discretion has
elected to nolle pros those portions of the allegations pertaining to Sections I I03(c) and 1104(a)
of the Ethics Act. We therefore need not address those particular allegations.
In considering the Consent Agreement, we accept the recommendation of the parties for a
finding of no violations as to the Section 1103(a) allegations. The parties are in agreement that
there is insufficient clear and convincing evidence to establish that Storm violated Section 1103(a)
of the Ethics Act. The parties additionally cite Sims, Order 1769, in support of a finding that Storm
did not violate Section 1103(a) of the Ethics Act in relation to her utilization of work product of
the Pennsylvania Office of Victim Advocate when presenting at the 2018 CJC Conference.
We hold that Storm did not violate Section I I03(a) of the Ethics Act, 65 Pa.C.S. § 1103(a),
in relation to the allegations in this matter based upon an insufficiency of evidence and Sims, Order
1769.
It is clear that a violation of Section 1103(d) of the Ethics Act occurred when Storm
received payment from Delaware for the presentations that she made at the 2018 CJC Conference.
The purpose of the 2018 CJC Conference was to educate professionals in the field of victim
services. Storm provided training and educational resources as part of her duties as the Victim
Advocate. Storm was not invited to speak at the 2018 CJC Conference about her life history or
personal experiences prior to holding the position of the Victim Advocate. Instead, Storm was
invited to speak at the 2018 CJC Conference specifically because of her knowledge and expertise
Storm, 20-001
Page 54
in the areas of victim services and offender reentry, the areas in which she primarily performed
her job duties as the Victim Advocate.
The biography for Storm that appeared in the 2018 CJC Conference Agenda identified her
as the "Victim Advocate for the Commonwealth of Pennsylvania" and noted her responsibilities
in her position as the Victim Advocate. The program for the 2018 CJC Conference listed "Jennifer
Storm, Victim Advocate for the Commonwealth of Pennsylvania" as presenting on the topics of
"The Role of Victim. Services in Offender Reentry" and "Professional Boundaries in Victim
Services," which topics were directly related to the duties that she performed in her public position
as the Victim Advocate. The slideshow presentations that Storm gave at the 2018 CJC Conference
identified Storm as the Victim Advocate and were directly related to her public position as the
Victim Advocate. One of the slideshows featured the logo/watermark of the Pennsylvania Office
of Victim Advocate.
Storm received a total of $2,600.00 from Delaware for malting her presentations at the
2018 CJC Conference. The payment that Storm received for making her presentations constituted
a prohibited honorarium under Section 1103(d) of the Ethics Act because the presentations were
not made in her private professional or occupational capacity but rather were made in her public
capacity and were related to her public position as the Victim Advocate.
Based upon the Stipulated Findings and Consent Agreement, we hold that a technical
violation of Section 1103(d) of the Ethics Act, 65 Pa.C.S. § 1103(d), occurred when Storm
received payment from the State of Delaware for presentations, which included portions related to
her position as the Victim Advocate, at the 2018 CJC Conference.
We note that the parties are in agreement that no violations of Section 1103(d) of the Ethics
Act occurred in relation to any other presentations made by Storm of which the Investigative
Division has knowledge.
Turning to the allegations regarding Storm's SFIs, we hold that technical violations of
Section 1105(b)(5) and (7) of the Ethics Act, 65 Pa.C.S. § 1105(b)(5) and (7), occurred when
Storm failed to disclose travel/hospitality/lodging provided by NCVLI for travel to Portland,
Oregon, on her SFI for calendar year 2017; when, despite listing the amount received as part of
total consulting fees received in 2018, Storm technically failed to separately identify the State of
Delaware as a reportable source of income on her SFI for calendar year 2018; and when she failed
to identify a provider of rental income as a reportable source of income on her SFI for calendar
year 2019.
We note that the Investigative Division is not seeking any disgorgement of Storm's
compensation pursuant to Section 1104(d) of the Ethics Act.
As part of the Consent Agreement, Storm has agreed to make payment in the amount of
$3,000.00 payable to the Commonwealth of Pennsylvania and forwarded to this Commission
within sixty (60) days of the issuance of the final adjudication in this matter.
Storm agrees to not accept any reimbursement, compensation or other payment from the
Commonwealth of Pennsylvania representing a full or partial reimbursement of the amount paid
in settlement of this matter.
Storm, 20-001
Page 55
Storm has agreed to file complete and accurate amended SFIs for calendar years 2017,
2018, and 2019 with this Commission within thirty (30) days of the issuance of the final
adjudication in this matter.
We determine that the Consent Agreement submitted by the parties sets forth a proper
disposition for this case, based upon our review as reflected in the above analysis and the totality
of the facts and circumstances.
Accordingly, per the Consent Agreement of the parties, Storm is directed to make payment
in the amount of $3,000.00 payable to the Commonwealth of Pennsylvania and forwarded to this
Commission by no later than the sixtieth (601h) day after the mailing date of this adjudication and
Order.
Storm is directed to not accept any reimbursement, compensation or other payment from
the Commonwealth of Pennsylvania representing a full or partial reimbursement of the amount
paid in settlement of this matter.
To the extent she has not already done so, Storm is directed to file complete and accurate
amended SFIs for calendar years 2017, 2018, and 2019 with this Commission by no later than the
thirtieth (30"') day after the mailing date of this adjudication and Order.
Compliance with the foregoing will result in the closing of this case with no further action
by this Commission. Noncompliance will result in the institution of an order enforcement action.
IV. CONCLUSIONS OF LAW:
1. In her capacities as: (1) a Member of the Pennsylvania Commission on Crime and
Delinquency ("PCCD") beginning in 2003; (2) a Member of the PCCD Victims' Services
Advisory Committee ("VSAC") beginning in 2011; and (3) the Victim Advocate for the
Commonwealth of Pennsylvania from November 8, 2013, until January 29, 2021,
Respondent Jennifer Storm ("Storm") has been a public official/public employee subject
to the provisions of the Public Official and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S.
§ 1101 et sec .
2. Storm did not violate Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a) in relation to
the allegations in this matter based upon an insufficiency of evidence and Sims, Order
1769.
3. A technical violation of Section 1103(d) of the Ethics Act, 65 Pa.C.S. § 1103(d), occurred
when Storm received payment from the State of Delaware for presentations, which
included portions related to her position as the Victim Advocate, at the 2018 Victim
Services Conference hosted by the Delaware Criminal Justice Council.
4. Technical violations of Section 1105(b)(5) and (7) of the Ethics Act, 65 Pa.C.S. §
1105(b)(5) and (7), occurred when Storm failed to disclose travel/hospitality/lodging
provided by the National Crime Victim Law Institute for travel to Portland, Oregon, on her
Storm, 20-001
Page 56
SFI for calendar year 2017; when, despite listing the amount received as part of total
consulting fees received in 2018, Storm technically failed to separately identify the State
of Delaware as a reportable source of income on her SFI for calendar year 2018; and when
she failed to identify a provider of rental income as a reportable source of income on her
SFI for calendar year 2019.
In Re: Jennifer Storm, File Docket: 20-001
Respondent Date Decided: 6I23/21
Date Mailed: 6/28/21
ORDER NO. 1789
Jennifer Storm ("Storm") —a public official/public employee in her capacities as a Member
of the Pennsylvania Commission on Crime and Delinquency ("PCCD"), a Member of the
PCCD Victims' Services Advisory Committee, and the Victim Advocate for the
Commonwealth of Pennsylvania —did not violate Section 1103(a) of the Public Official
and Employee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1103(a), in relation to the allegations
in this matter based upon an insufficiency of evidence and Sims, Order 1769.
2. A technical violation of Section 1103(d) of the Ethics Act, 65 Pa.C.S. § 1103(d), occurred
when Storm received payment from the State of Delaware for presentations, which
included portions related to her position as the Victim Advocate, at the 2018 Victim
Services Conference hosted by the Delaware Criminal Justice Council.
3. Technical violations of Section 1105(b)(5) and (7) of the Ethics Act, 65 Pa.C.S. §
1105(b)(5) and (7), occurred when Storm failed to disclose travel/hospitality/lodging
provided by the National Crime Victim Law Institute for travel to Portland, Oregon, on her
Statement of Financial Interests ("SFI") for calendar year 2017; when, despite listing the
amount received as part of total consulting fees received in 2018, Storm technically failed
to separately identify the State of Delaware as a reportable source of income on her SFI for
calendar year 2018; and when she failed to identify a provider of rental income as a
reportable source of income on her SFI for calendar year 2019.
4. Per the Consent Agreement of the parties, Storm is directed to make payment in the amount
of $3,000.00 payable to the Commonwealth of Pennsylvania and forwarded to the
Pennsylvania State Ethics Commission by no later than the sixtieth (60`f') day after the
mailing date of this Order.
5. Storm is directed to not accept any reimbursement, compensation or other payment from
the Commonwealth of Pennsylvania representing a full or partial reimbursement of the
amount paid in settlement of this matter.
6. To the extent she has not already done so, Storm is directed to file complete and accurate
amended SFIs for calendar years 2017, 2018, and 2019 with this Commission by no later
than the thirtieth (30"') day after the mailing date of this Order.
7. Compliance with Paragraphs 4, 5, and 6 of this Order will result in the closing of this case
with no further action by this Commission.
Storm, 20-001
Page 58
a. Non-compliance will result in the institution of an order enforcement action.
BY THE COMMISSION,
Nicholas A. Colafella, Chair