HomeMy WebLinkAbout800 FreindSTATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PENNSYLVANIA 17120
In re: Stephen Freind : File Docket: 88- 101 -C; 90- 010 -C2
: Date Decided: Ilav 41, ,1$93.
I
Date Mailed: • IU 1991
Before: Helena G. Hughes, Chair
Robert W. Brown, Vice Chair
Dennis C. Harrington
James M. Howley
Daneen E. Reese
Hoy W. Wilt
Austin M. Lee
4 - F . .. .. t d .
— The Stat Ethics Commission - r complaints , , egar4trig . possible
violations'o ±"the State Ethics Law, Act No. 170 of '1g'78 and Act No. 9
of 1989. Written notice, of the specific allegation(s) was served at
the commencement of the investigatio. A Findings Report was issued
and served, upon completion of the investigation, which constituted
the Complaint by the Investigation Division. An Answer was filed and
a hearing was held. The record is complete. This adjudication of the
Commission is hereby issued which sets forth the individual
Allegations,.F`indings of Fact, Discussion, Conclusions of Law and
Order.
This adjudication is final and will be made available as a public
document fifteen days after issuance. However, reconsideration may
requested whic4,w 11 defer public release of this adjudicat pending
action on the request by the Commission. A request for:
reconsideration, however, does not affect the finality of this
adjudication. A reconsideration request must be received at this
Commission within fifteen days of issuance and must include a
detailed explanation of the reasons as to why reconeidex1atipn should
be granted in conformity with 51 Pa. Code 52.38.
The files in this case will remain confidential in accordance
with Section 8(a) of Act 170 of 1978 . and _Section .8(h) of Act 9 of 1989
during the fifteen day period and no one unless the right to challenge
this Order is waived, may violate confidentiality by releasing,
discussing or circulating this Order. However, confidentiality does
not praclude discussing this case with an attorney at law.
Any person who violates confidentiality of the Ethics Act is
guilty of a _misdemeanor subject to a fine of not more than $1,000 or
imprisonment for not more than one year, 65 P.S.. 409(e).
I. Allegation:
That you, a member of the Pennsylvania House of
Representatives, 166th District, violated the following
provisions of the State Ethics Act, (Act 170 of 1978), when
you used your District Office and attendant facilities,
including but not limited to office space, telephone,
utilities, supplies and postage, for the purpose of
conducting your re- election campaigns, and in aid of your
private practice of law:
Se tion 3. Restricted .,activities
(a) No public official or public employee shall
use his public office or any confidential
information received through his holding public•
office to obtain financial gain other than
compensation provided by law for himself, a
member of his immediate family, or a business
with which he is associated. 65 P.S. S403 .
2. That you have violated the - following section (s) of the
Public Officials and Employees Ethics Law (Act 9 of 1989)
when you, a State Representative for the 166th Legislative
District, used your District Office and attendant
facilities, including but not limited to office space,
telephone, utilities, supplies and postage for the purpose
of conducting your 1990 re-election campaign:
Section 3. Restricted _activities.
(a) No public official or public employee shell engage in
any conduct that constitutes a conflict.of interest. 65,
P.S. 403
•
1. You are a member of ; the Pennsylvania Mousse of 1 epresen
tatives i;or the 166th District.
You were `first elected - 'to this position on April ; 2 '7,
1976.
b.' You have served in this position sine May 10, 1976.
2. - 'YOU hiv,e,maintained a _District Office for the 166th '
Pennsylvaniai,‘Since June or July. of 1976.
3. You are an attornii liCenied 'practice law in the
ADJUDICATION
Mr. . :Freind
1?age 2
a. -The .partnerek p maintained - an of 43.ce in the , P . S . . S .
Bu g;, 4 E#}h�i.la4i�elphia,, Iron early to mid "19 3 .until
early to mi 1$7;7..
(1) . For two mopith period r i r 't , . location of
your oft a to 2 Br ].tine laou your former
campaign he4 ii$uarters .tit '.9.11 ". Mood„ Havertown
was us_eci a§ a Aiist -r, t _coffaive :fir .mo
reintbu en.t was esrted..
�.n ; early t :,F0 - WU Ow Amyl Bd tr.be offi-ce to 2
Brookline pguleyar41,, fiavfertowxt, P *.lar .a.
c ,he law part leX§Pij p r At that location anti.]. the
early 1980's when the praCtice wag effectively
terminated, since you were at 2 Brookline Boulevard
and Mr. Willmann remained for the most part in his
Center City Philadelphia home.
d. The law partnership was formally terminated in 1988.
e. J. Michael Willmann never had a desk for his use at 2
c• Brookline Boulevard. He`' did most of; his; legal work
from an office in his home in Philadelphia.
5 The Di strict Office and the
5 �Y Isis offioe::are .located in the
Same two rooms on the second floor of 2 - Brookline Boulevard
One room is used by your Legislative :Assistant /Legal'
Secretary and a part;-time employes. -..::
The second room is used -for your office.
The property-at 2 Brookline Boulevard • is located- on the
Corner of Darby Road and Brookline Boulevard.
y A deed recorded in the Delaware County Court .douse, in
book 2296 . pages 408,409;410 and '411', indicates, the
property at 2 Brookline Boulevard was acquired by James
L. Morrison on February 2, 1988.
The tax records indicate the property is now owned by
Nancy Morrison of 226 Wesley .Avenue, Ocean City, N.J.
and 636 Kilburn Road, Wilmington„ Delaware.
•
4. YOU ,enter s law partnership with J . .. Michael Willmann in
eai 1y to 3497 •
Fi ' ,✓'
Mr., ' Stephen' F. Freind
Pa
c..
The- entrance to tiie second fld& of the building is
through a doorway on Darby Road.
A sign on that door states "State Representative
Stephen Freind /Law offices Freind and Willmann ".
There are 2 signs in the office windows facing
Brookline Boulevard. One states "Law office John W..
Willmann and Stephen Freind" and the other states
"State Representative Stephen Freind's District
Office".
7 There is no lease on file for the property at 2 Brookline
Boulevard, Havertown, Pennsylvania with the Comptroller's
Office of the B,Partisan Committee, Room 130, Main Capital
Building, Harrisburg PA.
a. There is no appraisal on file at the Comptroller's
office for the above property.
R. Records on file at the administrative offices of the
Pennsylvania Supreme Court indicate Stephen J. Freind has
his. law Office . st 2 $ ekline Beulam4T4,. W
Per nsylvania %
9. The Dialtriet.,. Qf,fioe .is Ti4 lA 3 u RPO4 a414 pgyents for
the rent`. are iaade .. €r-om the iaw: fiVgics checkt g 4ccount .
y
a. The rent for the ciistiet Offics w•s per month
in 19$7 $00.0Q Pe.,-nionll'inJ9ge '440 1989.
The ,offies .e rented fwp Nancy 9ffi §9g-
'Mon.thly payments .ae made 1 ice t 4,y - t9 i }der by you.
You then sO reimhuEs r ,for iaa�ge ' igr on of
these pa Gents,; fro -..the _ go onwaaith a:4 - -
10. The Bell . Teiephofte Di4ect9FY far D4.0-4W#z@ Fou „M4 L .11e
contains the foi1ovi nW sep to if rte- $ , W the fe pTio0
number 760 -0300 at 2 - Broek3L4e ppulevatcl AavertIgn;
a. ?rein*, Stepile4 .amity"
ia. ?reed, Atopixe4 §tae
c. Willoams, 4s Michael ary"
Mr. Stephen F. Freind
Page 4
The number was in the directory_ under _those
names by Bell Telephone after contact with someone from
your office who was advised as to how the telephone was
to be listed.
11. You submitted monthly - legislative expense vouchers to
Comptroller of the Si-Partisan Management- Committee seeking
reimbursement for various expenses inpluding district office
expenses of telephone and utilities,"ppetsonnel, rent,
postage and supplies.
12. Following submission by you of legislative expense vouchers,
you received monthly reimbursement from the Commonwealth for
rent for your district office: r 1.
AMOUNT
1987 REIMBURSED
1/5/87 $.375.00
2/2/87 375.00
3/1/87 375.00
4/1/87 375.00
5/1/87 3
6/1187 375.00
7/1/87 " 375.00
8/1/$7 375.00
9/1/87 375.00
10/1/87 :375.00
1 . 375.00
12/1/87 375.00
Total 1987 $4,500.00
AMOUNT
1988 REIMBURSED
1/1/88 $ 425.00
2/2/88 425.00
3/1/88 425.00'
4/1/8$ 425':00
5/1/$8 425':00
6/1/88 425.0,0`
7/1/ at2L: 0
188/1/00" �}' MAX
r0/1-/ c25:00
i f /x/ ..o 4.
12 /F/8'W • 425:00
Total 19$8 $4,75.00
1
• 1. _F
,PtfOhen P.. Frelnd
5
gb
e ilUMOCE
f REIMBURSED
,
425.00
lir 425.
3'1
,2.89 42540
415.(M
V1Y89
5 /149 4.5.1.0.
e/I/89
7./1/89 05. Q,
416
8:0./89
7,
0/1'485 425.00
9
I
1i/1/89 gil
OS; q
12A/89 425.
Taigf i'§ili i§,f00:60
1990 REIMBURSED
1/2/90 $ 425.00
2/1/90 425.00
3/1/90 •4
Total 1990 $1275.00
13. You paid a total of $16,55D rent for your aittkiat office
and law office from 1987 through Meath 1990; "You received
$15,550 reimbursement for this rent froim the diimmoRWAith$
Your rental cost for your Iaw office fiom 1987 thr0110 Marth
1990 was $1,000.00.
14. Your law office, district office, and campaign &Hit* Wtre
all operated out of the same facility.
15. Michael Willmann was your law partner from 19tt tib 1988 when
the partnership was formally terminated. paYthership
was effectively ended in the early 1980's.
a. The partnership started out as a 50-60 eriali-a but
without a formal partnership document:
b. The law partnership maintained an b in the
P.S.P.S". Building, in Philadelphia, for the first 1 or
2 years and then moved to 2 Brookline Boulevard in
HavertoWn, PA.
°Stephen F.' F rein ca "
Pqe 6
(I ; AAte rt1 Pt 'S office was closed, Mr. Willman%
cohdiacted thh vast majority of his Jaw pract$ -Pe,
out of his ` hrie aaWyou conducted. your law-
practice " from your . Havertown of f ice:
Wi .lmann did- nfibst ofr his- legal work f ar , office:. in
hi as home in P1 } i1a e Iphia acrd l would , travel' tom, HHv t ,
a 'roximatel oncec e-ve . once :
Pp � r �'.� weak or ev ery mom#
T Havertown office. was a muitipurpoae of #ice u4i f
State- Representative P Bind's District Office ian
addi €1.0A" t o the'ir'' law pra=ctice:
Willmann was unable- to estimate titer ratio of uae:.
the o fida
Tie Yaw p ac -tick did not make Tat of money bu* 1b ,
we cs working" at it.
Wil-lmann used, the telephones numbered, 7 , T-qa ,,Q anct.
789 -0301 when at the, Havertown office. :lltmai
not aware of who placed` the listing under ha "name
those numbers in the telephone directory,
h. Freind was the record keeper and bill payer and Freind
told him that he was pro rating the bills in favor of
the State.
1. Willmann has no personal knowledge of Freind using the
office for campaign activity. He was aware that Freind
rented a place for some campaign work. He wasn't in
the office that often to say whether or not it was used
for political purposes.
There wasn't a word processor in the office when
Willmann was there. There was a typewriter but he was
not aware of who owned it There was a copies' and he
didn't know who owned that.
16. You were the author of a book titled God's Children which
was published in 1987 by Beech Tree Books, William Morrow
And Company, Inc., New York, N.Y. �t '
%a. In the acknowledgements you' identify a number of
individuals who assisted - frith `the preparation of the
'book.
Mr. Stephen F. Freind
Page 7
b. You specifically noted, "Special thanks - to my frien.s .
and co- workers, Mary Ann DelPizzo and Maria Cahill, for
their many hours of assistance in typing, correcting,
and collating the manuscript.
,7. Maria H. Cahill has been employed by you at your District
Office for 14 years. She has worked continuously during
that period of time with the exception of time off for .,,-
; maternity leave. She has worked both full -time and part -
time
a,...:. normal work hours are 9 a.m. to 5 p.m.
,(1) She frequently .. works after hours and takes work
home with her. ,
The district office is very active and most of her
time is taken up with State business. The remainder of
her time is taken up by your law practice.
. Cahill =normally does not take her lunch hour.
(1) She generally eats lunch at her desk - .
(2)?, On the average, she leaves work between 5 :30 and
5:45 p.m.
(3) She takes work home three or four times a week.
(4) The work week of Cahill averages between 50 artd 55
hours per week.
(5) She has never 'received overtime.
�. ..�
d. She typed the manuscript for your ,book at the offio
She would come in early, work her'llinch houtg; gb& ttly
late to do the typing.
(1) Such serv'icee were paid for out of your 6
Personal cI ec1 &dct unt .
e. Yamtr. handled S Teiitidt ]' last oas a ii h from the
diestrfor ctn. cv.. S . 164 6om4 _tefe li a and
=saw fair - dm 161'. *: T ng ilacteb4 is
Y• WW1& Iftor lfteg niRs ,and re are s arate
stamps" and setaqtiicsritkly ti‘ law practice
. Therm is n0 c if cloig r showing a breakdown of
l ° egis ] et v ers1tt 1'e2ja3 *dil ` performed.
1
Mt. Stephen., F Ffg ,nd,
Page 8.
(1), A,cppy_of'.. letter that is written is placed
in a chx<c�,iolpgical - date boa.
(2) Every .incoming telephone call is loggea,in a
spiral notebook. -n A
The office and equipment are privately leased with,a
portion of expenses sUbmitted to the Commonwealth for
pro rata reimbursement.
Telephone calls are answered with the phrase "Steve
F' eind's Office."
Certain equipment or materials such as an air
conditioner, carpeting, typewriter, drapes, book
shelves, fire protection and a photocopier have been
purchased without any submission or reimbursement by
the Commonwealth.
g.
h.
. (
She maintains a time sheet for each whiff.° ..
becomes r p a r t . of . the case €older She doesn't ceep.sano
account: e t a spent'gh estate 'work and . wr:wo s:1
As. to law ca,.ses, time sheets are maintained for
only the cases: wb,etee the' charge; is based -upon .time
but not as to the, cases' wherein a percentage or
flat flee is charred
k. xou pay her $8Q.00 a week for the work. she performs for
the law practi„ The pay, is the same every week and
doesn't depend on the amount of work she handles. This
is in addition to her normal Commonwealth salary.
1. There was never any prorating of her Commonwealth
salary so as to deduct- for her compensation amounts
relative to work she preformed fat you that was not of
an official nature.
m. Campaign work has been done in the District Office but
such was ' ety limited.
Such activity consisted of receiving and
depositing checks, writing thank you letters or
typing a campaign letter to committee people. " -.
Mass mailings would be taken to a private printer
for reproduction.
The campaigns, eithei primary or general, made
payments for expenses in the Disttict Office.
Mr. Stephen F. Freind
Page 9
n. Some campaign wpprk was done in.your district office.
Most campaign meetings a'r`e 110.d at the Saw Mill
Restaurant or the Cheese . Club of Havertown which is
also used for envelope`_ stuffing and` mailings.
You held the imiti4 Tci sign meeting for this Years
election with s't ff .. a A e i istridt - Off ice .
o. She typed �3 campaign - letters , on the office coanuter,
for the 1990 camps gin: -The letters are mainta -ied in
the computer. The letters are typed ion pi in YpaPer and
sent td a local :printer for print4i g and mass g .ai34ng.
e also _typed thank you , letfers .for loth% ign
contributions ,off the office ,computer .ai d e 4orm
v rettei -i-S also inai, in tie ccam i tJer
The _campaign , { work _ was done . uri g her .normal work day.
„She 'rar €1- =,heaves :the office ti1nG�1 after 5 p.m.
Another novel is ,_Y etig wgi
(1) .e typing ` o ^ q.curs . $fter
( the Ming i,s e. u e.�n t
r. Some actiy..ities clf r gah t ill Againg wok _for the
; x �, �i'1 p aQ ; c e �of St
, e ;�,� cl �c�c}�red .during
-t1 e !lours .13etwe'_e n sal
( + 1) Cahill , type letters
(.2)
She wo d take ,telephone c 1ks from law 0;1• s .
s . The computer, word , co pacittirte A
e l ones - ' aY - e us_e_grbgt h or the law pr b c tice and
] egiciative':p'ur OSes . "
t. During the f
the eveniinc, o
Distric?t`
' oir -cam
'CSctbb ' Y ; � :_ Sfie .L s r `curie t
private capacity as` an g otf ic- na
a. De1.Fi z o W.a p4,0 1a 1988.89
s _ 4 �&
a her � �. o -sa
but 't� ow e ' r` Qre f a$ ti.
.a _.chapter is d .tad,.
,of e) vi 4or to 1.tary ° wring
ecti.on at the
e, 4rou ip c te a )!hone calls re] t ing to
our a'
May Ann Delpizzo worked at your Dish ;Qff ice as a
; g�is ative° Assistant Lecea -L c$ecreta y r x -Ku e 15, 1984 to
where in a
qe r for her state work.
for her legal - work
;8 : OO ' ,a week.
Mr. Stephen F. Freind
: Page 10
• The amount of tine,spent doing legal work varied with
the case load.
f.
h.
b. The office was a very active Distri"Ct office with a
tremendous amount of constituent contact.
c. The working hours for DelPizzo were nine to five
Monday through Friday with little variance.
• The rest of her time was spent doing law work, campaign
work and reviewing and typing the manuscript of your
book.
The law practice was an active, varied general
practice.
• She performed legal secretarial work such as typing
wills, correspondence and making client contact.
The amount of time spent on campaign work also varied
with election time being the busiest.
i. DelPizzo performed re- election duties for Stephen
Freind during her nine to five work hours.
(1) She accepted and deposited campaign contributions.
(2) District office equipment such as typewriters,
computers, copy machines and telephones were used
for campaign activities.
▪ Duties were performed by DelPizzo regarding a book,
"All God's Children," authored by Stephen Freind.
(1) The manuscript was typed during her nine to five
work hours.
(2) District office word processing equipment was used
for the typing of the manuscript.
(3) At the time of the rewrites and finishing work on
the manuscript; you directed that the book have
priority over other projects including
legislative matters.
6a) The typing as to the priority period occurred
during regular nine to five hours.
)4;1._ Stephen F Frei
Pam 11
• YoziC tot he t dt you wrote the book wh'ile an the train
go balk grid forth to Harrisburg. You wrote same of
the booX while in fhe-offide and she typed the
manuscript while in tie office .•
I".` This was generally do#id. d'iring the do addhwedl-th• work
days.
• She came into the office- on one Su iday to type
manuscript but it was her own idea. She didn't have
the time to type the manuscript during the week.
n. The additional compensation received b De1Pi•zzo from
the law firm of Stephen Freud was far - egisrative
duties.
• There wasn't a formal bookkeeping system setup at the
Office. She would pay the bills from the law times
checking account and then photocopy the bin9 for you
to take to Harrisburg.
The equipment in the district 6f fide Of Stephen Freind
consisting of a computer, telephone, cep machine were
paid by cheoki out of n• account of gtephen Preind.
(1) The bills for the equipment dnd check were given
to Stephen ?reind for preparation of are expense
report. ° ...
. An otfa.ee, next to tf . tri' attic* wall rented by
ibn ' during the 10'4 election campaip. The electric,
telephone; 'rent and other office bills were paid from
P the = aaiipaign expense account burg t'Itt'° election
r. Office post s tisea foi ld* ho lite work and
campai: 1. l gs- But t' xe Bi�i'1k t w%p ri iilailiags
were paid for by rthe CWIRIPIWh coulee
. ` ie - wa a er y' c . �i�c tune 'set asi for -legal
1,_,... _ aig h She woi'ke� dT :i c n the
�o'r� no r• - "da g
opportuhity'dr 'need - presentee teeif .
t. ¶here was neve]r' iany p'rorat r_r`g °of her commonwealth
salary so as to deduct from her compensation amounts
related to work she performed *or : you that was not of
an official natture
Mr. Stephen F. Freind
Page 12
u DellIbItzdy did not average 37 I/Z- per week op.
legiflati:ve matters during her eMIAMY,MR4t in the
Di §ti:idt bf Vice of Stepbem Fr . .
(1) The Office equipment loam Leased la, gtephen Fr @i d
Witt' partial reimbureement tA0
v. When cdMpaign activity was done in the District Office,
ca pdign Loney Was utilized for office..rent /equipment.
w. The legislative district office of Stephen Freind
defisisted of two poorly furnished rooms, each
aipfimate1y .ten by twelve.
x: bvtk a four year period, approximately 25% of
4541ibizTo't work was devoted to non - legislative matters.
19. C��ign letters with the letterhead "Friends of Freind",
th% 'Cainpaign .Committee of . State Representative of
gt F. Freind, were sent to your district constituents
`durlirr£ 5your 1990 . 'campaign. Letters with the same letterhead
'overt so mailed as far back as 1984.
a. The letters contain a message at= the bottom; Steve
Freind He Makes .A Difference He 'Gets .Results.
b. The' address and telephone number listed at the bottom
is 2 Brookline Blvd., Havertown, PA lam - . 789 -0300,
your district office.
c. Although the campaign letter was typed at the district
office, it was taken to a printer, printed at campaign
expense and disseminated to volunteers for the purpose
of stuffing and mailing. Such procedures were utilized
in the circumstances as to Fact Findings 20 through 22.
20. One campaign letter sent prior to the 1990 primary contained
the following:
a. The was typed as outlined above.
b. The letter was sent to various committee members and
supporters.
c. The le tter. identif ied _ a - Beef and Beer - Night on Friday,
April 20 at the Narbeth Fire
d. If interested in attending, persons were directed to
call the district Office.
Mr. Stephen g. Frei: z i
„Page 13
e. The letter was signed by Stephen'. Freind.
f. The initialling at the end of the letter indicating
author and typist is SFF:mlc.
21. A second campaign letter sent prior to 1990 primary was also
typed on stationary with. the "Friends of Freind" letterhead:
a. The letter was related to the pro -life movement and
urged support.
b. Attached to the letter was a form to fill out if anyone
could assist with the campaign.
c. Persons were directed to return the form to Freind's
Campaign address listed on the letter.
d. Anyone wishing to make a contribution was directed to
send it. to the Havertown address listed on the letter
whichwas, your district office.
e. The address listed was 2 Brookline; Blvd., Havertown, PA
19083.
2 2. On January 30, 1990, a letter typed on "Friends of Freind"
stationery was sent to the. Delaware County Board of
Elections and included a copy of a campaign finance
statement. Your district office address, 2 Brookline
Avenue, Havertown, PA, was listed on the letterhead.
23. You have paid your legislative assistants an additional
amount for the work they perform for your . law practice. and
to supplement their state wages. You submitted those
supplemental legislative assistants on monthly legislative
expense vouchers but did not receive reimbursement:
1987
Date Amount - Paid Amount Reimbursed
01/02/87 $ 80.00
fl1/09/87 80.00
01/6/87 80.00
01/23/87 80.00
02/06/87 80.00
02/13/87 80.00
02/20/87 80.00
02/27/87 80.00
03/08/87 80.00
03/13/87 80.00
Yob
NOD
MOP
ONO
M. Stephen F. Freind
Page 14
1987 - continued
ate
03i O /8�
03/21/87
04/03/87
04/10/87
04/17/87
04/24/87
05/06/87
05/13/87
05/20/87
05/27/87
06/05/87
06/12/$7
06/19/87
06/26/87
07/01/87
1 0.7/08/87
0111`5 / 8.7
O7T22/87-
07/29/8?7
08/05713°7
08/1 /87
08/1:918
08/2V87
09 " /04', 7
0. 9' /�r,1 /87
09/415M7
0 97
10 7.O'Z 7
1 O Man
1 CY/Z.3MR
1 0' ./3'/8'7
10[10787
11'/Xf6 7
11 L20`m7
11 /117
12/02 kr7,-
12'/16187".
"12/23/87.
12/30/87
TOTAL
Amount Paid
$4,020.00
80.00
80.00 -
80.00 -
80.00
80.00
80.03
80.00
80.00
80.00
80.00
80.00
80.00
80.00 -
8U00 -
80.00 .
80.00
80.00 .
80.00
80.0 _
80.00
80.00 -
80.00
80.00 -
80.00
8O.D0 -
80.. -
., 80.00 -
80.00
80.00
80.00 -
80.00 �..
80.00
80.0 -
80.00 -
80.0x0 -
.0V
80.00 _.
80.00_ -
80.00
Amount Reimbursed
I$r. $tephen ` F E.teind
Page 15 . nr
; $4 8
Dale
tho n . -.Paid AMOunt Reimbursed
01/0148 $ 80.00
01/ 08% 8 I «. 90.00
01/15/88 90.00
01/22/88 90.00
01 /. ?9/88 90.00
02/.5/8$ 90.00
02/ /8 90.00
02•,� ` t8 90.00
O / /BB - `9O.00
o'/e 48 , r '90030
03/ Vb .b^o
03/.8 -. ro
0•.0x0
o --- 90.'00
ox/ go . QO
p=4 /. . : I :
p4/ ':
a :: Nsyibo
05.1 '; : X3'0 .fib
05.127 1D:a00
08/.V3 3 4 , 0:x0
o6 /r'l4: 90f0
t8472, gfokoo
6Jt 4 9'o moo
alt X;$'8 40 26'o
_ _90. Q0
'i' l/ 8 '4812.613 9 0. °b�0
07X21108.
ORD
OMB
OEN
..
p,7RU 00
AN0T Legislative Assistant salaries were nest submitted
,,n � submit'
You s b m tted other legislative expenses for your .district
of f'i've to`' 'the `'CO trol3ter the B3.=- Part ±saref Manatpmfint
Committee for which'ireitiL rcebeived - refmbilrsements. - °.
j
NOTE: The difference between the amount paid and tire amount
reimbursed is the fig ure that you assert: was Ineurred by
you for your private law related,and campaign activities.
Az. ,Stephen F. Freind
'Page • 16
1987
Amount
mate Expense Paid
12/86 to 1/87
1/5/87 Electric $ 24.96
Answering Srv. 60.00
AT &T 27.38
Telephone 92.00
Computer Lease 368.88
Stamps (100.00)*
12/1 ; ,to ,Supplies 92.71
1/5/87 $665.93
(100.00)*
$765.93
1/87 to 2/87
2/2/87
1/6/87 to
2/4/87
2/87 to 3/87
Electric $ 50.53
Answering Srv. 60.00
AT &T 27.38
Telephone 94.24
Computer Lease 368.88
Photocopier 166.64
Stamps (150.00)*
Supplies 33.6
$801.36
(150.00)*
$951.36
3/2/87 Electric
Answering Srv.
AT &T . ...
Telephone
Computer Lease
Stamps
2/4/87 to Supplies
3/8/87
* No ReceLptMailable
$ 27.32
60.00
27.38
94.57
368.88
(300.00)*
3',00
$581
(300.0W
$881
Amount
Reimbursed pifference
$ 24.00
55.00
25.00
85.00
350.00
100.00
90.00
$729.00
$ 20.00
55.00
25.00
90.00
350.00
150.00
150.00
25
$865.00
$ 25..00
55..00
'25.00
350.00_
300.. 00
2. -50
$847.50
$ .96
5.00
2.38
7.00
18.88
0
. :71
$36
$30.53
5.00
2.38
4.24
18.88
1
0
8.69
$86.36
$ 2. 32
5:00
2. 3 $'
4.57
18_.•88
0
-�.
.50
. t e
P 1i7
Date? Expense-
3 / aft/ to-
4 /13/ F
imyerling Sry
meter Lease
3/2/8 t'o-.. S
4jVE
3 /. 41A7.= tct Supplies -
4 /:2 /Wt
4/2/87 to
51,51,0g;
5/1/87 E�et a
Aztsweri4ng; S v
Computer: Lease
Photopgp:er
4/1/ to 5/5 Stawngs-
Snpp1 ize s-
* No Receipts- Subrak44
$s 21.50
60 .00 ,
27.. 3;
363.88
(2(10,00) *.
7, 76
$44%11:52
(200 .0)
$� 29_.42:
60°,00
2 7,. 3$
3 -,8
1,66.64,
(417&. 00 )ti*
St._2'4
$E736 ;. "
(11753. 08) • *,
5/,5j97' t 6 1 8 :1! . 81}
6/110 Eliectrijo' $. 27 5%
Answe31.4ng ' Srv 60 Alb
AT &;1,,' 27;.3
Coiaputer Lease± 34 f.8a•
FIotocogier if ..Er4
TeteF3ane 8 ..E6•. 8 2
. S antge- (2OA . QR'):
5/5 tQ, Supplles ( %**-
6/3/87i $7
(200 r.) *
30;. Q( 4
•
APRIDAPit
R e nce
$ir 5.5 K 'w
, 5 •
25 ,. 0 • 2:%313 ‘
354.00': 1i:. 88
2 a.0: 0
7., 0 .7 6
$29.52
$ 25.00
551.00
25. 00.
35 . QQ
160. Q :D'
1x75
50 00
S.; 4P
25. 0.0
354i. 00
15Q 00
Q0.00
200 . . QO
3.0.00
5 ". 00
R9
2c 3-
1 ,
,6 64
0
34,. 2
$$ 2. 50 t
5 • Ceit
2.38
h &.�8
1 4
6 . a9
$ 52':3
)1r. Stephen F. ?mind
Page 18
Date
614
714/87
6/1 to
-;'.- / 2/ 87
6/1 to
T/2/87
7/2187 to 81/11/81
' 4/.1/87i
7/5 to
`8/1./87
6 /1D to
7/29;/87
7/29Y87
Exvensq
to 7/1/87
Electric $ 34.70'
Answering Srv. 6'0.00
AT &T 27.38
Computer Lease 368.88
Telephone 91.19
Copier Lease 166.64
Stamps (175.00)*
Supplies
glectric:
riswering Srv,
AT &T
Computer Lease-
abpier Lease
Stamps
Supplies
Supple'
8/2/87 to 9/1/87
9/1/87 Electric
Answering Srv.
AT &T
Computer Lease
Telephone
Cole Directory
Copier Lease
8/1 to Stamps
9/1°/87
* No, Receipt Available_
Amount
Paul
10.57 _
$ 59 -36'
cI75..lay *
$ 34
$ 5
60.00
77,311
36 .ft
I6'0.64
((20tf. 00;).*'
23.6'2
].6,.&:•77
$717.
$517 .0.6
$ 73.16
60.00
27.38
368.88
98.80
150.50
166.64
(100.00)*
,
roittxt
eimbursec1 Differeuop
$ 3Q.'00
55.00
2'5:00•
350.00
85.00
150.00
11T.40)
-1;.0, -
'. 00
55=.66
51..0
25.61:
356,60 '
P O;.ao
260'.60
25.-00
10.00
$870.00
$,65.00
55.00
25.00
350.00
50.00
135.00
160.00
100.00
$ 4 70
5.00
2.38
18.88
6.19
' 16.61.
- 0*
*• 9;p
5)..0.6
S,31
1?8". 68>
15.64'
0
-1.38
7
$47.06
$- 8.16
5.00
2.38
18.88
8.80
15.50
6.64
0
Mr. Stephen F.` Preind
Page 19
Date
7/9 to
-9/1/87
9/2/87 to 10/1/87
Expense
Supplies
40/1/87 Electric
Answering Srv.
AT &T
AT &T
Computer Lease
Telephone
Copier Lease
9/1 to Stamps
10/1/87
9/1 to Supplies
40/1/87
40/ -2/87 to -11:/7/87
Stamps
Supplies
'No 'receipt iA raii1eble
-11/7/87 :Electric
AT &T
Computer Lease
Telephone
Amount
Paid.
27.28
$972.64
(100.00)*
$1,072.64
108.98
60.00
27.38
253.00
368.88
82.63
166.64
(175.00)*
19.75
$1,087.26
(175.00)*
$1,262.26
$ 72.32
27.38
368.88
98.89
(100.00)*
15.00
. $582.47
(10
$ 682..
Amount
Reimbursed
25.00
$1,005.00
$100.00
50.00
25.00
240.00
350.00
75.00
160-. a
175.00
15.00.
$1,190A0
$ 32.44
25..00
.350.;
9.O.too
100. 010
x$'61a:+ x
Difference
2 .28
$67..64
$ 8.98
10.00
38
13.00
11.8..4.8 8
7.63
6.64
0
4.75
$x9
`2,._38
.'1 .A 8
:8•:89
0
0
47.0.4-3
mt iiARTA
1988
t
Date 24ei1S% Laic
11/7/87 to 1271187
12/1/87 6 L_, t� . il .00
An 9 ��v
ATo ._ .. 4.46
Comp 4f Leas 36848
.aipt _ L k n 1 4
r fiypp it6 Repair .2347
7
.. / _
/ b 8t .. �'p (120.00)* 1 0.0
-
: 'suppli
es
1212070
11123/$7 ` sow
Ppil e ..
11/1/87 'Copier teas
January 1988
1/4/88
CQ r ease 16 ij . 8
telmohon4
12/1 to Stamps k150 :003*
4/1/88
12/1 to Suppli'i
1/5/88
1/5/88 Copier Lease
* No Receipt Avai1142i ±e
$89 5.41
r - '.•,
52.00
58.29
:64
r4. D2 X $1,15 .59
$1;222.56
Res e
c .,
40:b0
— =ao
$855.00
18.88
9.89
0
0
6.64
$40:41
$ .00
9.36
1
10.49
6.4
8;g7
• 0
x :29
$71:97
r, Stephen F. F `eind
Page 21
bate
Februa 1988 -
2/1/88
1/4 to
2/3/88
2/1 to
2/9/88
March 1988
3/1/88
2/3 to
3/1/88
2/9 to
3/1/88
April 1988
4/1/88
3/1 to
4/1/88
3/1 to
4/4/88
* No redeipts
Expense
Answering Srv.
Computer Lease
Telephone
AT &T
Copier Lease
Stamps
c� x:
Supplies
Electric $ **
Answering Srv, 60.00
Computer Lease 368.88
Telephone
AT &T
Copier Lease
Stamps
Supplies
Electric $ 26.96
Answering Srv. 60.00
Computer Lease 232.14
Telephone 119.58
AT &T / 46.96
Stamps (150.00)*
58.40
Supplies
available
Amount
Paid
$ -60.00
368.88
106.26
65.62
166.64
(100.00)*
.69-.30
$836.70
(.100.001*
$93.6.70
11
46.96
166.64
(40.00)*
(10.00)*
$755.30
(40.00)*
(10.00 - )*
$805.30
Amount
Reimbursed Difference
$ 55.00
.350.00
100.00
,_.40.0 0
,' 0.00
100.00
1.00
55.00.-
350.00
100.00
40.00
160.00
40.
10.00
$756.00
$ 25.00
55.00
215.00
110.00
40.00
150.00
56.11
$ 5.0
18.88
6.26
5.62
6.64
0
• •
68.00 - . 1.30'
$893.00 $43.70
r 0
$ -1.00
5.00
1$.88
• . 12:82
6.96
6.64
0
0
$49.30
$ 1.96
5.00
17.14
9.58
6.96
0
2.29
Mr. Stephen F. Freind
Page 22
Date
3/31 to
4/4/88
4/5/88
May 1988
- 4/6188
. 51278 :8 -
5/3/88
June 1988
6/1/88
5/1. to
6/1/08
July 1988
7/1/88
6/1 .to
7/1/88
* No Receipt Available
Amount
Expense Pa id
Supplies- 10.39
Copier Lease 166 :64
$721.07
'/150.00.1*
$871.07
Supplies $ 3.69
Electric- ` ''' 27.68
Answering Srv.
Telephone
AT &T
•60.00
124.49
46.96
Copier Lease 166.64
$429.4
Electric- $ 54.3
Answering Srv.. 60; 00
Telephone 113.18
AT &T 46.96
Computer Lease 105.47
Copier Lease 166.64
Supplies 39.38
$585.93
Electric -
Answering Srv.
Telephone
AT &T
Copier Lease
Supplies
Stamps
$- 8.9
50.00
112.10
46.96
166.64
57.87
(180.00)*
$442.47
(180.00)*
$622.47
Amount
Reimbursed
9.00
160,0
$820.11
$• 3.50
25.00
55,00
120.00
40.00
160.00
$403.50
$; 25.00
55.00
105:00
40.00
100
160.00
23.00
$508.00
$ 7.00
45.00
105.00
45.00
160.00
50.00
180.00
$592.00
Da.fferyz ce
1:39
6.64
$50.96
$ .19
2.68
5 00
4.49
6.96
6°.64=
$25.96
$29.30
5.00
8.18
6.96
5.47
6.64
16
$77.93
$ 1.90
5.00
7.10
1.96
6.64
7.87
$30.47
_lg. -A
- 4 4 .,Se 2
Deceakor 1908
12/6/46
A.2/5/88
No recej,
Phwl r•arod
P.1113 ,Expense
-1kWoutt 11988
S014:46 FElectrkc
qTeleptione
I T
tcamtputex Lease
771. troo 7Suivolietts
'6414
• 7/1 -,to -Stamps
8/1/48
Septemitqr ,1
S8/1/88 Up 'SUPPleS
911488
0t0Pr
9 /14!4$9 rto. - SuRplies
1043AP
NolgValkoar119108
7/2048
9/1/3$ Lto
11/1 /8'6
10111/88 $14ppIies
simPlies
Stamps
, enrei4404,ke
"
Anwentit
P el t d.
$ .413224
116 v74
44,6 P96
105.47
3.98
• (419A*
$tZ.16
$n 9
$23 :310
$29 24
$ 4,09
(120/140?*
6
.9 • 48
00)*
$15.19.4.43
CmPutar $S2 .85
CRP:xerlDOM4e JO6i64
AzralintirtgArv• •11140
SuRpliires
,$41t4.47
JUnctiAnt
ReiVpur*0 Difference
$ 660000
1 110 00
45.0
100.00
5 9.19 0
,$568 f50
$23.03
$30.00
$ 4.89
150 0
• ms
$11to: ,o
- r5 .G0
c55.00
4159.98
3.24
- 6.74
1.96
5.47
48
$17.89
$ .. 47
- • 76
$ 0
o
0
1532.85
1X6.64
0
$54.49
Stephen F. Freind
Pirge 24
190
'expense
Date
January 1989
1/4/89
4 to
1/9/89
12/1 to
1/31439
jr '1'489
2t176
a/1 to
2/1/89
1/9 to
2/1/89
W5189
211/t9
March /809
:3/4/89
3/2189
- 2/1 to
3/2/8:9
Copier Lease
Stamps
* No Receipt Available
t` t
Elgct.,rE $ 26.93
AnsWel'in;§
Srv. 60.00
AT&T :146.96
Telephone 173 i43
Computer Lease 428
166.64
Snpplies 26.56
Answering Srv. $ 60.Q0
AT&T_ 46.96
• Telephone 119.40
Computer Main. 77.38
Supplies 39.59
Stamps (75.00)*
Copier Lease 166.64
Electric 27.27
Copier Lease
Electric
AT&T
Telephone
Compute= Lease
Answer_ing Srv.
Sqppligts
$537.24
(75.
$612.24
$166.64
60.22
46.96
124.20
182.85
60.0O
34.08
Amount
Paid
(
$683.37
(75.00)*
$753.37
Reimbursed
$ 25.00
45.00
45.00
133.00
170.00
160.00
25.00
QS!
75.00
$690.00
$ 55.40
45
100
75.04'-
35.00
.75.00
155.00
25.00
$565.00
$160.00,
55.00
45.00
115.00
170.04 ,
30.00
Difference
c t
$ 1.93
SAID
38.43
112-.85
5.64
1.56
sF
$68.37
$ 5.00
1.16
19.4D
2.3t
4.59
0
11.'64
2.27
'$47.24
$
5-.22
1.9.6
9.20
5.00
4.08
Nxiltabhen F. Freind
Page 25
Z/11.; to
3/2/89'
May 1989
P •
5/1/89
t/1 to
10
4 /I' Ao
5/1/89
5/1/89
N, hz
* No Receipts Available
--,-- Amount Amoun
Expense Paid
Stamps ( 50.00) * .: 90 .
• $720.00 $14:95
(90 .
$764.95
stc trio $ 28
- .126 .77
,r]Computer tease 746, 447'
• Computer Main • •*5.77
141,014Tering •Sry .90
Copier Lease , 186.64
Stamps . (150.00)*
Supplies 22.90
Supplies 32.49
4856.28
(150,00)'*
$808.28
,
Reimburse&
April 1989
...
4/1/89 Copier Lease ' $ §6;t8 7 $ p040 $ d.. a
ETectric 4 • 7§: 45:00 44 7 6
... AT&T .,, , , . 46.96 " 1 :98 1..96
(-- Telephone , - , 1 40 . g7 . . . 115.00 11.77
Com...puter..:Lease (100 . po)* 100.00 0
Anewerin4 Sry . ; 60.00 * -.54 00 5.00
3/2 te Stamps (200.00)* 200.00 - 0
4/1189
3/1, to Supplies . 62:81 - 50.00 12.81
4/1/89
4/1/89 Computer L4 ..43 - 10Q.40 , 5 471'
Copier Lease - ..OPF - - .=: -1 0
$04,- sil-- , $ - 5 -310 • 00 64 87
. - .
Cl.<99,..:Q04'
tIDEPri*
. $994.87
•
$ 4
_cT:00
145 .`.[P k0
U QO
14
-50.
150.00
20.0.0
28.00
8753.00
Di - et'ar e d . rice
$.; 4428
6.7.96
1.77
5.7
5 ..001
L6.64
0
$53.28
Mr. Stephen F. Freind
Page 26
Date*
J1] 989
4f1
67;419
Juli49
7/1/89
611 to
7/1/89
6/1 to
7/1/89
1 = .
.Ur
L . 41
Expense
* No Receipt;A:kittiatle
,
AT&T
:Te4.00,6
CoTputer „Lease
CoMpUter Main.
Answering Srv.
;IRr =
,CopIer Lease
Amount
.
POdi
4 444
1.4
10-5.47
65.71
60.00
(100.00)*
25.01
_166.64
$643.68
(100.00)*
$743.68
Electric $ 46.45
AT&T 46.96
Telephone 140.41
Computer RibbOn4 40.22
Computer Main. 65,77
Answering Srv. 60,8Q,
Copier Lease 166.64
Stamps (90.o0)* ,
'Supplies 25.49
$591.94
(90.00t*
$681.94'
. -
444. i4tifiz6016
R
$ 25.00
4 9.4 0
125.00
100.00
60.00
55.00
100.00
2000
160.00
$685.00
$ 45
45.00
130.00
35.00
60.00
55.00
168.00
9049 •
$643. 0
$ 4.91
6.96
18.92
5.47
5.77
5:00
8_58.68
•
2.49
$38.94
0
5.01
6.64
$ 1.45
1.96
10.41
5.22
, 5•77
5.00
6.64
0
Date
August 1989
7 / % 1 /,$
8/1/89
811 to.
9/11/89
8/4.0
9/8/89
.September 1988'
9/1/89
October 1989
10/1/89
:9/1 to
'10/4/89
-:9/1 to
:10/4/89
10/2/89
. Expense
Electric
leph'n
ring $ v,•
Goier: Leas
bleetric _
AT &T
Telephone
AAswPring Srv.
Comp3 ter Lease
Computer Main.
Stamps
Supplies
_electric
Teg- ]O
: a.We ne
g :•.
Comguter Main.
Copier Lease
Supplies
Stamps
Supplies
* No receipt available
Amount
Paid
$ 27.6
6.5."
:147.8q
94.21
6.67
46.96
13
.28
60.0
166.$4
0./7 :
io0o�*
34.49
580.81
-:+( " 0)*
$680.81
$ Y42 ...81 "$ 40.00
121`'45 ; 1104
;60.00 x45 :00
,:6'5.7 ,7 }0.100
'166;64 l :b`0 .00
24.00 22.00
'(i00% 00) * 100 .'00
;A S?pp{'A 1F r
$485.4 "6, , $541:0
(100.00)*
$585,.46
Amount
Reimbursed Difference
$ 26.00
601 .. ,
45.06
5.00
e 1$0. 0 0 .i
,
$'5 1.00
40.00
45.
180.00
16D.00
60.00
100.00
. - . - t0.00
$640.00
5r.•1
1
9 :00
6:x'4
- 0
$3 2 11
1 :96
9 : '28
.0
8:64
5.77
0
.....,4.49
t40.81
15 0
5. 77
2 1.00
0
egg
W4 M6
Mt, SterihOh F. Freind
Page t%
Pate
Nowesiber19t0
10,4/
10/4 V..t•
11/1/8
11/30/8
HDeceMber 1989
12/1/89
12/1 to
12/3/89
latliklutte
* No Receipt Availakile
Electrit
AT&T
Tel**bwe
lAmm*rIng Srv,
Compute Main.
C4I'llie'r 'Leave
Supplivs
stamps
lie's
Electric
AT&T
Telephone
Answering Srv.
Computtv Main.
Copier Lease
Supplies
Amount
Pat
$ 41,2/7
46,A
IS6.31
60.00
1 6'5.77
(1.50,01))*
U•15..'7.2
':11.5
$1$5.72
$ 31 -96
143..47
60.00
65.77
166.64
(23.4)1*
$514.80
-1214.421,
$538.23
1990
January 1990
1 Electric $ a
AT&T
Telephone 137..39
Answering Srv. 60.00
Computer Main. 65,77
Copier Leste 1
$510.08
Amount
Reimbursed Cdttomite
130.00
55
. 60.00
160.00
45.00
150.00
• $ 41) .441Y
-- 1.96
6.31
5.00
5.77
6.64
9.76
'$72500
$ 10,0M
45.110
130.00
• 55.00
60.00
160.00
23.43
• $503.43
$ 10,
• 45 AO
110.00
55.00
50.0
160.00
4.01
$40.72
$ 1..96
4 1.96
13 • 47
5.00
5.77
6.64
$34,80
$ 3.32
1.96
7.39
5.00
15.77
§.64
$470.00 $40.08
l~r. ~hen' F. Fre[nd
~ 2:9:
Amount
~ ,Ex~.e Paid
2:1~ t'90
~i~ferencR
Sug9lies 29:.14 28.00 ~..~
* NO Receipt Avai~'b~e-
Ther~ ~ave ~ee~ other varied expense~ ~' ~he
dis~riot/la~ o~'~:.~e as ~'o~ which .you hav~ ~~ n~
r~~~e~-=. '~n~isting o~ the 6~ai
o=iq~n~ p~~,,' dra~s, bo0ks'he~ve~ ~' ca~ing
~. ~h~' ~'~ c~nd&tioner'~ over the ~-ars.,
$'I5,550,0'0'
Stephen~F.
Page 30
9'6'.
Freind
$50,968.-~1 $4i, 042.56 $9,925.95
Of~ t~ .~'5'0,968.51 ~Xpend'.~d from January 1987 to MarCh 1990
to m&~nta/n to your dis~riut'off~.ice', law office, and in
-~-.part, .y~ur. campaign office, you ~paid $9,925.95.
~ou have filed Campaign Finance Reports with the-State
Bureau of Elections for the years 1987, 1988 and 19~9.
Information related to your district o~fice was' de~ailed in
those r~portS:
Campaign Expense Report - 11/24/86 to 12/31/87
Name and Address: Friends of Freind
2 Brookline 'Blvd.
Havert°wn, PA
Signed By: stephen F. Freind
(215).789-0300
Section 2.2 - Contributions Over $250~O0':
Ce
Freind & Willmann
2 Brookline Blvd.
Havertown, PA
'~g~e~ate Value - $750.00
1/1/88 t~ 4/4/88
Name and Address:~ Friends of
Freind
2 Brookline Blvd.
Havertown, PA
Stephen F. Frein~'
Schedule II: Freind & Willmann
Summary of Expenditures:
4/12/88to 5/16/88
Name and Address~.
S~gned By:
Office Supplies - $100.00
P6stage; Photocopying
Friends~of
2 Brookllne. Blv~'~
Havertown,-.PA
Step~&n F. Freind (215) 789-0300
Page 31
9/13/88
9/13/88
9/13/88
97 '3/88
9/13'/88
Sc~edul~ II..
Cole ~blicatio~s
901 W., Bond Ave.
Lincoln~.~,~ebraska 6825~'
First, Eastern Leasing Co.
P.O... BOx~230'~'t
Scranton,-.~A ~8501
Bell of PA
P.O. Box 85~5
Phila. PA 19173
ABE Computer. Svcs. Inc.
-4539 Hamilton Blv~' ~
Allentown, P~ 1~103
2 Brookline Blvd.
~avertown', PA
Stephen F. Freind (215) 789-0300
- Summary of Expenditures:
Rental of
Cross Directory
Lease of-Computer
TelePhone
Computer Ma~n~efiance
~o~traCt
AT&T~
~ittsburgh-,~ PA 15.286
Del,c,o .Response
Haverto~, PA 1905 3 -
.Phones "~,
A~Swering ~ervice
158.50'
105.47
110.51
77.38
46.96
60.00
88.41
Mr. Stephen F Fre'ind
10/11/88 'U.S. 'Posthaster -
Havertown, -PA ' 19083
10/17/8~ 'Bell' of PA
('Listed above )
10/1'7/88
-10/17/88
Party's Answering ~erVice
8908 West Cheister Pk.
U~per Darby, PA 19082
Meridian Leasing Inc
(Listed above)
Lease of Photoc6Pt6r
Stamps
Phone
Answeri~g Service
Leas? of Photocopier
10/17/88
'10/17/88
10/17/88
10/17/88
10/17/88
10/21/88
Phila. Electric-
(Listed above)
AT&T
(LiSted above).
~0PI
700 Parkway
Broomall, pA
Nuss Printing .... -_.
(Listed Above~
ABE Compute~ g~}c~ i~6~.'
(LisCe-d ahoy6F : "....-~.
U.S ~os s "
Electric
Lease of Phones
Copier'.Supplies
P inti g-'
· .Cq~.~ter Maintenance
~ohtract
'64 ~ 66
:237.50
.120.00
250.00
269104
60.00
166.64
34.31
93.92
37.63
25.55
77.38
1056.00
Page~ $3
. . .<~ ~,~Na~Address:
10/25/88
10/2718-8
10/28/88
peg Giac~mucc~.
1356 Harrin~ton-Rd~
'Havertown, PA -19883
Nuss Printi'ng I~c.
2024 Darby Rd.
HavertoWn, PA 19083
'McNichol Business Madh
'94'1 Stoney Brook Dr.
Springfield, PA 19064
107 -7 88
Bell of PA
P. O. BoX 8585
Phila. PA 19173
~Twp. 2311 Dafby Road
Havertown, PA -19083
Edward &ailagher
C/0 Cheese Club
i0/28/88
Ollie Matti°li
C/O Cheese Club
U.'S..'.Postmaster
Upper Darby, PA
19082
10/28/88
U.S. Postmaster
Upper Darby, PA
19082
Phila. Electric
'P.O. Box 3438.
Phila. PA 191'01
.~at~y,s Answering Serv-
8905 W'. Chester Park
UpPer Darby, PA'
F~igndS'o~ Freind~
HaVertOwn,,~PA. 190~~ - .
S%ephen F'~.Freind~(215) ~89-0300
.~ .. -~. :. . ~eimbu:semen%' for -.. - .-: ~ ,telephone. ·
.,. ,% .... - . .. ;
Printing'
Maintenance of
.Typewriter
.... PhOne Installation
...... /"~ - l'": ' .....
.R~ntai of Hall-for
L~iter~tur~
- Custodial Service
Custodial Service
Mailing
Stamps
E~ectric Office
Answering Service
29.08'
.841.64
73.67
148.65
35.00
50.00
35.00
2640.00
200'.00
68.0-1
60..-'00
11/.2/88 iJ~E ~c~.,p~er S, ervice
1:1,/2~/88:; -Nuss Printing 'Inc
-.'~, 3 - ( Listed above )
11/28/88 Bell of PA ~.-c~
(Listed above)
.'Lease of PhotOcopier
Printing
Phone '
f. ll/28f88'to 12:/31/88
77.38
1939.80
-105.47
82.68
46:96
1'66.64
69;96
249~'88
ge
Name/Address~
Signed by~
1/1/89 TO 12/31/89
Name/Address:
Friends of Freind
2 Brookline Blvd.
Havertown, PA 19083
Stephen F. Freind .(~15') 789=03~0..-~ ~,
Friends of'Freind
2 Brookline Blvd..
Havertown, PA 19083'
Signed-by: Stephen F. Freind (215)78-9-0300
Schedule II -'Summai-ybf Expenditures:
Freind.&-Willmann Reim. for Telegrams
2 Brookline Bivd.
Havertow~, .PA 19083 ~.~'
35.82
Mr.'Stephen F.'-Freiad~,
.page 35
28. Statements 'o~"'FiUan~iat'~n~res~'~n f$1~ f..or..:S~ph~a.~.~,.
Freind. 241 Brook-~ine BOHl~ard~ Ha~er~o~
Ethics Co~tss-ion~ ~ontain the fOltowi~_~n~o~=_~oA~
a. State~e~' of Financial Interes~'fOt.'~tg~f::lts~s
- occu.patio~ ~' profession as Legislator - L~ -
Writer. Sburces of income as PA Ho~s~, of--
Representa%ives, Main capitol Bu~ldin~.:Harr%'sbUrg, PA
and Freind .and ~ill~a~, 2 Brooklin6 ~lvd, Haver~o~,
PA -19083.
b. Statement of Fina. nCial Inte=es~-~o~. ~986 liSt'~ ..
o~Cupation as Leg.i"slator -A~t~n~y.~-Write~--and
sources of in60me~as'PA House of Representatives, Main
· ,~ Capital~ Buii~i~g, Harrisburg~ PA; Freind ~nd.-Wilt~nn
· . (Law Practice):'2' -B~okli~e B~ule~ard, Haverto~ PA
19083; and ~ :.Morrow,~& Co., 185 Madison Avenue, New
: Y~rk., N~.Yv' 100l~.: ' -' ' ' ' ""-
c. statemen~ of./'Financfal 'Interests for 1987 lists
occupation or' profession as Legislator-A~torney-
· - Writer. Sources of income aS Freind and W~lma~.a..:~.
'"' ' ' :~" '(L~W Partnership), 24t Brookline Blvd~ ~ HaV~tO~, PA~
.......... '-.: ~. ~orrow & Co. (Publisher), 105 .MadisontAv~nue~
'"';~ '" - 'York, N;Y. 10016; Stephen J. an~ Jud~,tkiR,..:.F~eind,~.?
~:'".',, ~ :']':. ,Investment property at 5252 We~t Avenue, ~:::City,
· 13.mi';~- · ".-~ . .~.J. ;. and PA House of .Representatives, Harrisburg, PA.
'~ ::h~flie ~ S'tate~ent-of' Financial Interests for 19~8 ,lists
....... O~ ~..occupatibn? ~- profession as ~gislat0r
· ;~:, i;l,~dwrlter. "~r~s' of i~co~ as Stephen'
~ f ~Law 'praCtice) ~ Brookline Blvd,,
C~onWealth of PA, House of Re~ese~t~~'~'~;
- ' aa~ri~bu~g,"P~ Real Estate,-5252 Wes~
' '~ City,: 'N.J.'; and St. Joseph's
29. YoUr distri'ct office has always be~en-use'd 'for your~di~t~Lut
T~e rc:~fice, la~ ~a~t~e.6 and
rs.~r~:, ~. ~°f~'~e'~'ime"-for'Sta~e-'b~Sl~ss,~and,.,1% of the time"~or
........ ~y~=,".kawr, practicezand-.in,.Four,-'campaign for re-election.
~?athnri ~Br.:~,~..y~u,r. ~,I=ulations ;'wer~base4r.oa~:.~practi=ality. When
f~r ~ ~".'de~~g t~:.s~a~e.s oos.~.f~r:.the office.~
,.:~prove~-,e~ ~ p r~, f "'O~rkl~lk~hg. ~t~e 'la~.' fi~"s:,~ and; ~e-?re-elect~on
~v~st*~T'- ~ ' breakdo~ of such expenses.
Dur~ ~:~ ~. ~- ~f~r'.'pa~i~m~he;~ent and."offic~bills f=om .the law
..:~tu~.t~es .~, f'~'-s ~6~ih~ account, you submit t,he bills~ ~along
nner' fo~~ ~' r~"Wi~h ~~f~gislative Expense~'Voucher, for~par~ia-1
~elsei. ~ 'm~'~e~ent by the Stat~; ' . ~. -~.
~Z' 202' "- ~' ' ,i" .. ~.-~.,.
~ d,tr.d,' 'Th6ie is no daily log~maintained ~or the ~ount-
: .:ei= ": '-time spent on State work and the 'amount of time· .sp.~t
~]=~,ua,.~.. z, . for law fi~ Or ~ampai~ work'l ,'- :- '
~uu~ e. ~'he office ~u~pme~t~'is leased in ybur? h~e and you are
' - res.ponsib~c, fo~'any de'fault: in-pa~en%~. ,~ The monthly
pa~e~a~6~T,'tSe o~f!ce ~i~nt:~are .als~ made fr~
the law fi~'s checking account. The state re~urs~
you for,this equipme~ upon the su~ssion of re~ests
~ ' ~ (1)' The'o~fic~ lease,, e~ipment- lease, and other
financial liabilities are incurre~,in your
' ' "~-' .without qualification as 'to yo~ ~i'on o~
.]~-, ' "legislator or la~er. -, '-
-'-f:%~: Y6u' prOVided office furniture~ 'carpets, bookcase
'- ~ ~'."~ insurance 'for the office at' you~ o~,' expense.
g. Yo~ provided a .'copier .that was used for the first' 5
. ~ears in the office for state business, at your o~
expense. .~ .
h.- ..... ~Ou assert tha= your leg~l, ative-assistant~?wOrks~k 40
._ to 45 hour week by staxing' late' and retu~ing at' night
~or ,State functions,, a. nd' that this makes up for the
...... time spent on,'legal. 'or campaign work that she does
.~'~ .... during~o~l/state hours~
Mr. ~te'phen F; Freind
Page 3'7
-.i' · ' ' re'ceiVed~' a, ~83,008100' referral fee f~6m a m~Tcat
el comuute'r%v'~%e4 ~'ev' ar~ p~tn-t~a ~ a local prih{ing
~: ~ c~y.~'. "~.~': '. . ~ . .
:', '' ~;''- ~D'~t~i~'~e add~es~ ~.nd telephon~: n~er are
~'~': '~ ,, 1.T. '- Th~~iptS~ for your b6o~ ~ere t~ed in. the office,
,. ~ .'. on. t~? offence dompute~, by your Legislative Assistant/
· ~- ~ ,. ~gal' Se~creta~ but most of ,the wo,~k was done on other
· - ~- tha~. St,a~e time% - .
~:-'::' ': m. The boOR .,was ~i~ten o~ {h~ ~ra~h,~iie you traveled
~ '~t.', ., back 'an~ forth t6 ~.HarriSbu:rg~~ '~ ,p~i~ricians'?aiting
"~"": rooms and at .i~'ttle league
"~' ' n-i' The book was ~i~ten piecemeal and when you completed a
.... ' ' "6hapter. you wouid .~iCtate it for ~ing by your
...... Legislative A~'sist~nt'/Le~ai' Secreta~.
o.. ~'to the:'199.0 ~neral~Election,. you dete~ined %hat it
w~s nedessa~' tO-Wa~e an ~gr~e~sive campai~ an'd ~en'ted
a complete c~paign office from jUne through Nove~er
199.O f~°m which virtually all· campaign a~tiwities were
condJoted from that office_which was staff~ by full-
'" '~ tim~ volunteers.
Jiil Heffe~on is .emPloyed ~y 'the 'Republi~a9 ~Caugus al. the'
P~n~ylvania House of Repre~enta%'ives.
c. ~. 'She was assigned tO yo~. in' Ju~e%:.. 1984;
=.;-, .
~" :"/~" (1)' Her n0~al .work day~ is from ~'h~ine~..to,~4:30.
' b. C~n~s in. ,~=k t~-or leave', ak
.~:-~M~..~Stephen F. Freind
:~ P~age~ ~ 8
'You have pro~ided~-the.'following addit~Sflal informat~on~'
The District 0ffice'is..p~ivateIy:teasg~ by you..
The law practice is-peripheral to~'~he :~egislative :Work
Tn the.-Office.-.
c. As.~o an out.s£de employment questlonaalre~
reflected .that Maria cah-ill apppa~s in aho~her
capacity as-Secretary to'Steve Freind..
d. The telephone book liStings.~.f Re r~en~ive st'ephen
F.'Freind and'Stephen F... Freind, At~4~q~.rn~_.F. ref~l~ct the
dual purpose"office..
You make the fOllowing arguments ..~egar~ding th6 use of
your legislative distrfct office for re-election
activities or as a private law office.
(1) The~private u'se:o~:~he 'district office, eqp~pment
and:Derso3me~cw~s~re thanbffset by priva~e...
(2) 'The non-l~gis'~a~i~e work in his district office
was pa~d from your.qwq..funds on a prorated~asis'.
(3) It is :imp:acti'eai'tom. inthin an official
.accounting sys~em.~s./~o %eg~sl~tive/non-
legislative.~'ctlvities but ch~0n61ogical day ,
books/noteboekspro~ide a comparison of
correspondence/telephOne callS.
(4) Prior precedent Of-this Commission supports the
use of dual-purpose resources if Private payment
is made-f~r non-official uses.
(a) ~es$a~, Opinion 82-002 'all6ws for the use of
a district office for Campaign purposes if a~
. acceptable-accounting system is devised.
(b) .Bell,. Opinion 84'-'013 r~ognized dual purpose
us~,~bY~atl~wing'a re-election bumper sticker
on'a'vehicle 18a4ed ~o~ a me~e,r of the
General As ~mbl-~.
('c) Reiqerr 0rd~r 6'~0, wherein a state
representative wa'S'~ound 'to violate SeCtion
-3(a) of' AeC. !70%~$" 1.~78 ~ t~6~e of
legis~T~ ~ffC~ fbf 're'-ei~6ti0,:
P~ge 39
7act~it~esl,d~d.::nQ~ i~yolve dual purpose.;use.
ogrrei~b~rsemen~.
. i(~2' ~L~%- 0~ier' ..$~0'i Street, Qz..~e~ I~1o~
~, ~der 436;.Salo~m, Order 378,
~~;-Order' 372} Fischer, Order 486 and
~t~',.Order 494 are distinguishable, as
~ ,L~:~v~ving dua~ purpose Use coupled with
-[.,:~O~a~ =ei~ursement.
,(.e),..~'-'~f~o~-'~;,'; 0pinion 89-011, under Act 9 of 1989,.
· ' ','~estr-icts the utilization_ of- office,
.. personnel and eqg. ipment for private
.ac~i.ties only as to offices o~ed by the
. .CD~nwea-l'th.
(f) "~er, Opinion 90-013 interpreted Section
'3,(a) of Act 9 of 1989 as not barring a
· ~mp~: paid telephone in the state office.
~ ~ ~ .
~ 'st-a:~e' i~".~ator ma~, Lease fr~ a-private vendor.
.a'. district) office; t~: I:~islator is- en~-$~%'ed: to
exclusive use of the d~stric.t office and the
l~gisiator may~ seek rei~.ement to the extent
~i.~ized for legislative duties.
~ le~sl~ti~l, assistant in his district office
~as. ~msistently exceeded the 37.~ hour ~r Week
· ~q~!rement/a~" to perfo~ing legislative related
;~ies.
~h~j aU~i~ emplo~ent questionnaires for ~ari~
~i~.~i1~ ~ef~'ct the following: in 1983, 1 ho~ a,
~tT.,f:.~ay~O~ay! through ~riday as a legal secreta~ to
s2S.~Xe~;. ~ AgiO, ninety percent of work is
.~jeg:kslati~e with the remainder of time as legal
~?.5~e~ai~ a~% in 1979, twenty percent of work as
~.~. secre~a~.
~e( :~ye~: ~a~oll info~ation as t9
~ahi~ ~fl~cts inter alia dutig~ 9~
Freind
(i~) ':~h~ ~,MassaChusetts Ethics Commission ,:case
~8~2112 ,-only stands for the..~pr~p~i~i~n ,:~.b~.t
~pe=s~l l~easing of wo=d pro~i~g ~-.~%~t
~pers~al ~'u'se':Within a ~isla~i~ ~o:~f~ce ~is.
p~hibited only 'in~s%a.~e..~p~ Of.f~s.
~I1 ) On seve=~l 'Occasio~s, ir'],was .:yo= t.hw-~mct~ce or
c~paign c~i-tt~.w~i~.h 'f~ily :~ded the
]tegtsia~i~ office at .~ ~nd~-of each legislative
(12) The transfercof the ~taw~pra~tice 'from ~a separate
location .to ~the.~dis~ict office~was done for t~
. reasoRs:
(a)
~'The,.desire to have:thetaw-office'in[.the
.'legislative district'office,so that.you
would always be-accessible.to, your
constituents.
(b) The income from the law-practice permitted
Initially, it is noted .that of the two allegations in this cas~,
one relates ~o Act 170 of. 1978 and the second rela~,~.o
Unde~ bo~h ACt 1~0 °f.i~78 and-Act
=F~=~=nuu~ves is a pUDliC oIzicial as that te~ is defined in..both
A~ts. Rie~er, Order 680; CaDDab~nca' 0pin~
his conduct is subject to. ~he provisions of~b0t~-~
· " [ d?r Sect~on 3~.)~.of Act .170"of.1978 quo~e~.tab~%~hiS
~o o5~in ~, ~na~c'lal- ga~- himSelf.~>Dra aJ~me~r~Of.~is ~=i~ediate
for~'~n law transgresses '~he.~ ab~ve~:~isie~?of/:..~sw; ~T~usp u~e?of
'b~fi66 5Y:~;[~ubl~c'6ffic~al-['~o..obta. in.a.~financial gain which is not
ut~?j ~d,.2.~ ,~ .of-his.. ~mpgns'ation is' proh~ited--by'Section-. 3 a
.of.~i~ial/e~%O~ee,;ma~i'n~;~se th~ ~s~a~tlZS~,or. positibn~ of!~bil~
for.'h~s o~,,~senat' ~Vant~;~;~ibn 84;0t5. ?~':'
. S~ct'i~n a~'",~'finitionm~~ , .... -
· - ..... "Colflk~ or conf:lict of i~e~l'~'i Use by a
p~blic o~.fici~, or publ'~.c mm~l~ .ef the ,
~.Uthoritx.:of-~Bis 'office omre~l~nt ~or any .
confide~tiaI-iafo~atio~ received through his
ho.lding.>~li~foffice o~ emplo~ent for the
private pecunia~ benefit of himself, a m~er
his i~a~e ~ami'ly .Dr' 'a D~gin'e~s with which he
or a .-m~'~.~f~his~i~edta=e, family is associated.
"Conflic:~kjo~ 3~confli~ "~' interest~ d6es
inclu~:_ ~,action ha~94'a ..de .minimis economic
impact::~ which~ affects, to the same degree a class
consisting of the general public' or a subclass
consisting of 'an inducts, occupation or other
group which includ~.th~ public official or public
'~ employee, a me~e~'~ h'is i~ediate family or a
business with which he' or 'a me~er of-his
i~ediate familF is associated.
T~iS provision of. law in' pa~ restricts a public official/employee
from using the authority--of, office or confidential info~atiOn for a-
privat~ pecunia~, b~nefit for h~self, a me~er o'f his i~ediate
f~ily>'or'~7business -~th: whi~ .he_ or. a me~e~, of his -i~ediate fa~-ly
is.:,as soGiated · .. · -. '~
From. the inception of Act 9 of 1989, we have. interpreted Section
3.(-.a) of Act 9 of 1989-as p~ohibiting;the use of public facilities fo~
private pecunia~ benefit.-- Thus, ,in~.Pancoe/ Opinion' 89-011,. as to the'
question :of 'whether: a staff ..member of "the General A~sembly could
provide, private contractual..se~Jices .:to_ .~membems~of ~.-~he 'General
As se~b.!y ~" we .-.determined: - " ; ....
.In -applying -'the .above..p.r. ~is.$on.s .~;f .:the
Ethics Law to ..the instant ~.ma~ter$' .we --.n~t'e.c t~at -
Section 3(a) of. the Ethics .-:Law~dOes.~,n~t p~hlbit
p~lic .of.ficiats/emptOYees .-from: o~si~b~.siaess '-
activi%~es; .h~weve=,~ the public officia,L/empi°yee '~"
may ~not use the-authority of 'of.fio~f~. the- ~'~'
advancement of his o~ perso~al~fina.ncial gain, ':
Thus, altho.~gh: you are not pr~ibi~d under ,7-
Section 3(a) of the Ethics;La~;-from .entering i~t°.''' :'
a partnershfp...whi=h.wou~ .p~ov~.~ >c~sul~i~9: ~ '
marketing se~ic.es, y~u ~o~
private business using Co~onWeal~h~f~Cl~itieg
Mr. Stephen F. ~reind ~
Page 42
perso.~ne'l~ In-particular you could not-use the ".
~etephone,~ postage, staff, equipment; research '--
materials, persomnel or any'other.printed/drafted
'materia!.~a~ a means, in whole or part, t~.ca~ry
out~.your private~b~siness .activities. .i~TM.
addition, yoU could not-during Commonwealth
working hours,-solicit members of th~ General n .:~
Assemb!y~or- others to promote or conduct..your
mamketing ~and consulting bus~Dess~ Subject to the
qualifications noted above,--Se¢~f6n 3(a)of.~h~.~
Ethics Law~.woul~ not pr0hibitrydu from entering
into the ~rivate partnership a~rahgeme~t~j _i
P:_ancoe~ at P~4.
The issue bef6re us is whet~her the use by Freind of the office;
and facilities situated 'at ~2 Bbo0~line Boulevard,-'.~avertown~no-t..~nlY
'as a legislative d~strict office, ~but a!so as a private 'law 0fffce and
for re~election-campaign acti%aities violated Act lq0 6f 1978,'~a~d
se¢o~dly,'~hether such use as to his 1990 re-election campaign
violated Act 9 .of 1'989.
The facts in this case.-ar~-e.~entially not in disp~tel .~reind
leased office space at 2 Bro~llne Boulevard, HavertOwn in 1976
following his election as a.'i~ep~gsentative for the 166th Legislative
District. Thereafter~'in I~77, Freind moved his private l~a~ practice
from a separate lo~ti~hT~{01t~e 2 BrOokline Boulevard office. The
office consists of~.~Wq rooms; one is used as the office Of Freind and
the second by his l~gislative assistant/legal secr~taryl .The law
practice waS' o~fh~'~/_ya partnership between J% Mlchael,.Willmann and
Freind. which., wa~'~6rm~ll¥~ .- terminated~ in 1988. Willmann-.did :most of
h~s le~:w0~k..~olrt of his home and did not have a desk at the ~
Brookli~e'~Bo~lev~rd-office.
The~ sign-~on the door at the Brookline office 'states :"'St~e
Representative StePhen Freind/Law offices Freind and Willmann.
LikewiSe, there are two signs in the office'windows: "Da~ office John
W. Willmann and Stephen Freind,-.and "State'Representat~ve.~,Stephen
Freind,s District Office~" - Finally, the-local Bell Telephone
Directory..has three.listings_for~%he-telephone~-imstalled in the
Brookline office:-",Freind, Stephen-~tty.-, "Freindv Stepheh'.S~t%
Rep.'- and "Willmann, J. Michael. att~."
-The record reflects that Freind received reimbursement from the
Commonwealth of Pennsylvania for ten= for~his district office
amounting to.. $4,5~Q. :in 1987; ~$~f~?5-~n -'198.8., ?.~5.,'11~-in ~989 ~d"~$1,275
~.n ~0 ~ ~ T~s~ c~ %~i~95~?~-:~n~d.-for -Freind' s distr~ct
re=ea~e~ ~r~.~se~e~%efer rent-. 'from-~ ~'h~ ~Commonwealth l'eaving a
remainder of'$1,000 as the cost attributable to the law office from
P~~I~al:,':~s~~s ~ ~f'~-a~ "I-~gisIaeiv~ -g~rk.'~ As ~o :t~:.. ~
cOmpe~ation -Paid' :~o:~.fa~W'~egi~lative.'assistant/legal secret=ries~, h-
there wa's no.:]proration, of their .salaries" paid', by the Co~onwealth'-but
Fr~'i~d.f~i~4.':s~p~lement;~e!r sala~ so as to compensgte, them for the
~eg~l%s~i~-':the~.-.pm~fo~ed i L. During ..th~ _.peri0d.: of the emplo~ent
Ma~ ~-DelPiz~o, the;:, le~i~lat!ve~or~-.~ad. Priority.except during the
~ that:~hs~. Was. ]~orking.' on-~ ~he~ book ~itten- by Frein4, "GOd' s
, ehil~,i.....::De%Pizzo:also perf6~ed legal 'se~ices for Freind.- AS to
Ma.ria:"Cahill; she also se~ed as legislative:assistant and legal
:secreta~. ~hill filled outside emp!o~ent questionnaires 'wherein
'She i'ndicated that in 1983 she perfo~ed legal secreta~ se~ices
approximately i- hour a day Monday throug, h Friday, that in 1980 she-'
indicated that 90 percent of her work'was legislative with the
implication' that 10 percent was legal and finally ~n 1979 tCahill
indicated that 20 percent of her time was utilized for legal work.
At the district 'office, both. D~l"Pizzo and Cahill performed work
for the Freind re-election campaign. In Particular,' letters were
prepared for the 1990 campaign_with the-2 Brookline BOulevard address.
A campaign tetter was typed at the district office, but taken to a
printer for reproduction at.campaign expense and disseminated, by''
volunteers. Such, activity occurred in prior 5rears as far back'as
1984. One c_ampaign letter in a prior year'Specifically referen6ed an
event and directed that persons ~ould inquire of Maria Cahill at the
district office. (FaCt Finding 20k. Similarly,.a'second.campaign
letter, for the-~99-0~-relating~to-the pro-life movement, Sought support
both as tQ assistance from persons who could help with th~ campaign by
filling out a form and returning it to the campaign' address"'as'we$'l.as
making contributions which could be 'sent to the district"office, at 2
"Bro~line Boulevard. The campaign financ~ statement Which w$~-sent to
~he Delaware County Board of Elections by cove~ le{ter of January 30,
1990~. ~isted the district office on the letterhead.
T~e record 'reflects (Fact'Finding 24) that various
related tO-the district office were paid by Freind fgl~ ~Y the
receipt of p~tial reimbursements in mos~ ca~es-,
expenditures as to rent, the~.legislativ~'~aSsis~n~.~c~f<f~ce,
equipment, uttli~ies and supplies.as wet1 a~ ~h9 .a~o_~4t~'of
reimbursements are reflected ini'Fact Find$~~i~:.~e~bining the.
above three categories, it i~ noted th~~i~_(~91~xPenditu=e .from
January of 1987 through March''of': 19~'t.~..?~.~.~¥the..~fi~e'"as:a.i_
district office, law o~.fice'anda..-pa, rt--~t_%~..me..~a~paign'o'z~ic~qn=eu
to $50,968.51 with $9,925.95 being'paid b~"Fr~ind.~(FacT Finding '26).
Mr..~.t. ephen F. Fr~ind'
Although .the facts, ~as'no~.'ed,. above, are almost exc-lusi:~ely
.uncoates~ed, the 1.egal li~~Son of t'h'~se facts is in,~-i's~'U:e. ~s :~o
' ~e.~.-h~r z~,~e above aa=tt~vLfiie~-c=f Freind ,violated either ~Se~O:t-"i:~n
~:nto ~ith~r ~ ~ ~a~~.= %~at ~ ~aX :~se use of an office
gain er a ~ri~te ~~ ~Xt wi%h '~ ~q~ence that" there
arguab}y .=an be no, vi~~ ~:~ ~~: ~(a) ua~r ~fther Act and
utilization of'the ~st~' ~iuO':~ithout COntravening the Ethics
Law. Wh~-.cl~ely ~s~inized., ~ of ~h~ ~ore~in~ arg~en.ts are
unavai ling. ' '
As to th~r~t:.grg~ent, t~e inherent f-taw eon~ained therein
based upon; :~e-':t~l~:.~gr~se t.h~t th~ uan'~ ~0 Viola%ion if a
pro~atton .'is.~.~e ~se~upon-a break d~ of ~ ~lized for
legislative versus hon-legislative activl=ie~ at ~ ~l~ie~ Office.
C°~°nwea'lth~ '~:Pennsylvania-based on a p~ora~o~ ~ich does not
exceed the_~ount ~f time utilized for .l~islattve ~ather than non-
le~lslati=e activities-,'then there could be no financial gain or
pr~vat~ pfl=unia~ benefit.
Mrl Stephen iF. Freind
Page 45 "
To ~he contrary, it'is'inContr~vertible:th&t the office at.2
Brookline BdUl'evard' ~s~ a~ law~ office%.- a~well~, as aR-, occasiona!i ~a~p~.~
re~etection ,-office wouTd~ ha~e ex~ihg.- operating expenditure~
regardless'00~ .wH~her' any Law ~ bus, ness, was: gDneTat~ ~h~s,
if ~t were no~ for~ th~- le~ii~i~e offi~e' being~ 1D.c~at,~%-i i~. ,ti'~- same
~uilding with' a' consequent' enL~i~ent~ from~ the~ Commonwealth. for
~tbu~sement~. Freind would~ hawe been z~'~uired to' outlay/funds, f~r.
rent, a.l~gal secretary, utili~i~ equ~ent and supplies regardless.~
of whether he conducted any law'practice activities or received any.
income from'his law. practice. But for the integration of the law
office and district office, Freind would have to outla, y the above
enumerated expenditUres regardless of the amount of business or income
received from the law practice. '
Taking the argument to the extreme, the theory would be that the
law practice (in isolation from the district office) wouid only pay
for rent, a legal secretary, supplies,, equipment or services only to
the extent that s~ch were utilized.. Obviously, such expenditures
would be obligations~ven if there were no activities or income
therefrom as to~ the~ law practice.. Such is typically the case in the
start up of new businesses which do not generate income' for a period
of time but do require large out-of-pocket Payment.s.for operating
expenses. Wi~h the ~Commonwealth providing reimbursement fo~. the'
district Office,.'s~ch payments, serve to underwrite the-la~off~ce to
the extent that Frei~ c~nducts no or little law practice-because the
~w practice is open, opera~ional and available for business during
Such time~ Clearly such is a financial gain as is evidenced in the
{5~ee Yea~ period Where Freind only had-to pay less than $10,000 for
r~%4-%, ~ff~=e equipment, utilities and supplies as to his non-
~egisI&tive law p~actice or campaign activities. (Fact"Finding 25).
T~e ~inahe~a.t gain becomes more apparent by breaking the above down as
%0 re~t alone. Freind only-~adto pay out-of-pocket 'rent for kis law
6ffice of approximately $1,~00 from 1987 through March,' 1990 (Fact
Finding 13). , .
Turning to the Act 9 Of 1989 aspect of the 3(a) allegation, .the
allegation sOlely relates to use of the district office relative to
the 1990 re-election campaign. Based Upon our decision in Pancoe.,
supra and .the abOve analysis,we restate that public'office is to be
~sed solely for the public purposes and not for any private, busines~
~r campaign activities for private pecuniary benefit. Such activities
are clearly contrary tO Section 3(a) of Act 9 of 1989 and the
~ctivities of Freind in utilizing the district office, .telephone,
utilities, supplies or postage relative to the 1990 re~election
campaign violated Section 3(a) of the Ethics Law.
Freind, hoWever, argues that such activities are permitted b~sed
~5~ prior Commission precedent. In particular, it is argued that
~rl~ p~.~ent such as Cessa~, Opinion ~2~002 under Act 170 and
~~ ~i~io~ 9~01.~ under Act 9 permits such activity. It is also
Mr. Stephen F. Freind
Page 46
a~serted that various othe~ adjudications are ~4n,,,~h=~%~ ~ t~
theory that they either concer~ state=ow~@~
n olve the element of proration.
In responding to the second arg~men%, We initi~!ly note.t~t
nowhere have we considered or accepted any type Of distinction,, a~
being meaningful, regarding whether an activity took place in a
state-owned facility versus a rented legiSlative district Office o~ a
so-called dual-purpose office. In Street,'.Opinion ~i-00~, we'held
that the legislative district offic~of a state senator could not be
used for personal fund raising by an independent group on ~he basis
that such would be a financial gain other than dompensation ProVided
for by law. contrary to Section 3(a) of Act 1~0 of 1978.. Similarly,
in Reiqer, supra, which also involve4 inter alia the use of a district
office for re-election, campaign activities, we held that such
activity violated Section 3(a) of Act 170 of 1978. see also
McClatCh¥, Order 130. . '
The main .opinion relied upon by Freind in support Of his po~tion
is .cessar, supra. The specific 'holding in Cessar was.that a sta~~
representative could aot use his distriCt of fide f6r the 6onduct of
campaign re-election ~activi.ty even if a~' appropriate accounting..system
for reimbursement or payment could be devised on the basis =hat such
would be an appearance of conflict with ~he public trust. It:.is .%rue
that there is-dicta.', to' ~the effect that, assumin~ an acceptabl~ ~
accounting system co~ld be devised to pay'.f'or the utilization of' ~he
office for campaign, purposes, then such-would not be an inherent or
per se violation of S'ection 3(a) .Of the Ethics Act. we expressly.
reject that dicta 'at" this time an~reaffirm the .result .'that the use of'
the district office f'or 'campai'~n purposes is prohibited, by the Ethics
Law. The clear 'basis for such a finding is not merely' the appearance
language but the expr~-ss ~anguage.~of 'section 3(a) of Act-' t70 of 197'8.
We follow our. recent d~cisi, on in Rei~e~;~ supra and find that the use
of the district off~ce in this ca~e' for non-legislative matters
violated Section".~3(a)...:of-~ct.~,l.70, of-.1978..-The opinio, n in ~elt,'
Opinion 84-01~.- wherein we-opined .that a r.e-electiOn bumper sticker on
a leased vehicle ~o~-a m~mber of the General ;.:Assembly was permissible,
is distinguishab~.e on-it~., facts.which are ".... differen[t] ... not
only of kind<, but. of' degree-., as :wetI. ,, Id at p. 3.
Likewise, under Act 9 of' 1989, the' 1990 u_tilization of the
district .office for',campaign re-e1%Ction activities violated Sections
3(a) of .Act 9 of 1989:;. "The";arg-umeht:th~:"-a holding would be a~ odds
with Haft. r, supra Where~n; we~' aTl'owed,the u'-tllkzation of 'a private
~phone 'paid- at- campaign; expe~.~e? ia:-'.tl~Au~i-tor .General, s OffiCe,l is
u~awe~tin~. Hafer,.supra'was' exp~-~sly-'pre~icated upon the factual
c~ndit~.~that there:'was no~riVate- peeuniary ben'~fit. In t-he
instant ma%t~.,.pr.~vate pecuniary'benefi~ ekists 'where, as 'noted
above, the COn~M~wealth-is paying for .the' ~aily operation of the
district office r~.~ardless, of the-amount off.time spent for private,
Or: i~6~.ae~~ ~ ~be law.: p~lce ~us~neSs .~ ~~9~x,
. -~-~.%7.i ~, ..i=r ',;"- .............. . 'g d'a ~to=d o er~~ of the
~0fl~hi~i=~n~% u~t~:.afi~? e~en~ re,rd'leSS of t~
pe~~ benefit
the ~tst~:iet ~'~fl~a~' ~&~ ~i~a~ law practice ~es h~ ~re
readily ~'8~e~.i~le 'to his .e~t.ituents, ~ ~st ~ ~id~ ~ the
Provisi~~ .~ ~%~bn~- .3('a~)~ ~ ~' ~70 of 19~8 ~d Act 9
weii in the Z cs Law.
i:~;~%:~. ~i~ '~s di:rect~d-'Withia 9'0. days ,:o'f: the
~'~ ~& ~enarate his Dri'Va~e ~w: prac~i'ce ir~ ~e m.~.~A=~ .
'~'~{et of~i In addition Frel~d ~s d~rec~ ~o .ensure ~nac no
campaign re=election ~ctivities oce~r at ~ district office and
conVersely to ensure that his dis.tric= ~i:ce, personnel, or
~uipment is .no~ us~or'~-~n°m~T'~'~ve' ~cti=/.ties which wo~ld
result in a private.peC~nia~ b~Mefit.
IV. conclu~s .of ~W: ' '
'1. Stephen .F'~ Frei'nd as a me'er of the Pennsylvani~ House of
Representatives for-the 166th Legislative District is a public
O~flcial .subject to the provisions of-Act 170 of 1978 and Act 9 of
2. Freind violated Sec~i6n-3(~') 6f Act 'i70 of ~I978"when he us. ed his
district offic, e, and attendant facilities to '~ond~t his private
practice of law and engage in re-election c~pa~n a~tivities.
3. Freind violated Section-3(a) 'of Act 9 of 1989 when he utilized
his district office, and attendant facilities to engage in_1990
-re-election c~ign activities.
In re =
SteJenp~ ~' ~:
Frein~),: i!
' = Da~e Mailed:
~is[ative ,Di~[riC~.-violated SectiOn 3:(a'), 0f the AC~ 170
· ?8 when h~ Used h~'s distric[ '°~iCe, 'and at~e~daat,. '" '
facilities=to .C°nduct~ his priVY're practice of l~w a~[
Freind vk01ated ~:
Section 3(a) of Act 9 of 1989 when he
utilized hisf ~istri~ offtc~,.~:and at~nd~,.f~t~es, to
engage in.1990 rere!~ion :c~i~ activitYe'~i-'"
Within 96 days O~,..the. i~suanoe ..of this Or.der~.,. ~re~,d ~i~
· egis±ative ,distr:ict..office,.-
4. Freind is. directed to ensure ~that no c~.mpa.igq:
activities Dccur at his dist-ri.ct of fie9 and t..~97 .di_g~rict
office, personnel, or eq~ipm~ is, not uSed for ~-
legislatiw, e-acclivities which would result in a private
pecunia~ benefit.
.--:. ~ ....~ .: .... ,_. ~ . . . :-
?! " '-
. ~ . ~ . ~., ~
Co~ssioner ~ober~ ,'W-,~-Bro~~ did =or -~r,~icipa~e in' ~'h~s ~tter
because he ~c=ed. ~s single presid~n.g 6ff.~eer and re~sed.~ himself
pursuant ~o 51 P~ C~e: S2.34(d).-. , ~ ...... : ~=: ,:.,; :
Co~issi~r- ~in :. L~e: i'Ssent ,.. ~. ,.,, _ . ~