HomeMy WebLinkAbout1266 KeeferIn Re: William Keefer
File Docket:
X -ref:
Date Decided:
Date Mailed:
Before: Louis W. Fryman, Chair
John J. Bolger, Vice Chair
Daneen E. Reese
Frank M. Brown
Susan Mosites Bicket
Donald M. McCurdy
Michael Healey
02- 033 -C2
Order No. 1266
12/24/02
12/30/02
This is a final adjudication of the State Ethics Commission.
Procedurally, the Investigative Division of the State Ethics Commission conducted an
investigation regarding a possible violation of the Public Official and Employee Ethics Act, Act
93 of 1998, Chapter 11, 65 Pa.C.S. § 1101 et seq., by the above -named Respondent. At the
commencement of its investigation, the Investigative Division served upon Respondent written
notice of the specific allegation(s). Upon completion of its investigation, the Investigative
Division issued and served upon Respondent a Findings Report identified as an "Investigative
Complaint." An Answer was not filed and a hearing was deemed waived. The record is
complete.
This adjudication of the State Ethics Commission is issued under Act 93 of 1998 and
will be made available as a public document thirty days after the mailing date noted above.
However, reconsideration may be requested. Any reconsideration request must be received at
this Commission within thirty days of the mailing date and must include a detailed explanation
of the reasons as to why reconsideration should be granted in conformity with 51 Pa. Code §
21.29(b). A request for reconsideration will not affect the finality of this adjudication but will
defer its public release pending action on the request by the Commission.
The files in this case will remain confidential in accordance with Chapter 11 of Act 93 of
1998. 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.
Confidentiality does not preclude discussing this case with an attorney at law.
Keefer 02- 033 -C2
Page 2
I. ALLEGATION:
That William Keefer, a ublic official /public employee) in his capacity as a Councilman
for Monaca Borough, Beaver ounty, violated the following provisions of the State Ethics Act
(Act 93 of 1998) when he contracted with the borough for the sale of concrete barriers in
excess of $500.00 without an open and public process; when he used the authority of his
office for a private pecuniary gain by voting to approve payment issued to him for the sale of
concrete; and when he failed to file a Statement of Financial Interests for the 1998 calendar
year by May 1, 1999.
Section 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).
Section 1103. Restricted activities
(f) Contract. - -No public official or public employee or his
spouse or child or any business in which the person or his
spouse or child is associated shall enter into any contract valued
at $500 or more with the governmental body with which the public
official or public employee is associated or any subcontract
valued at $500 or more with any person who has been awarded a
contract with the governmental body with which the public official
or public employee is associated, unless the contract has been
awarded through an open and public process, including prior
public notice and subsequent public disclosure of all proposals
considered and contracts awarded. In such a case, the public
official or public employee shall not have any supervisory or
overall responsibility for the implementation or administration of
the contract. Any contract or subcontract made in violation of
this subsection shall be voidable by a court of competent
jurisdiction if the suit is commenced within 90 days of the making
of the contract or subcontract. 65 Pa.C.S. §1103(f).
Section 2. 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 P.S. §1102.
Section 1104. Statement of financial interests required to
be filed
(a) Public official or public employee. - -Each public
official of the Commonwealth shall file a statement of financial
Keefer 02- 033 -C2
Page 3
interests for the preceding calendar year with the commission no
later than May 1 of each year that he holds such a position and
of the year after he leaves such a position. Each public
employee and public official of the Commonwealth shall file a
statement of financial interests for the preceding calendar year
with the department, agency, body or bureau in which he is
employed or to which he is appointed or elected no later than
May 1 of each year that he holds such a position and of the year
after he leaves such a position. Any other public employee or
public official shall file a statement of financial interests with the
governing authority of the political subdivision by which he is
employed or within which he is appointed or elected no later than
May 1 of each year that he holds such a position and of the year
after he leaves such a position. Persons who are full -time or part -
time solicitors for political subdivisions are required to file under
this section. 65 Pa.C.S. §1104(a).
Section 1104. Statement of financial interests required to
be filed
(d) Failure to file required statement. - -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 a statement of financial interests
as required by this chapter. 65 Pa.C.S. §1104(d).
II. FINDINGS:
1. The Investigative Division of the State Ethics Commission received a signed, sworn
complaint alleging that William Keefer violated provisions of the State Ethics Act (Act
93 of 1998).
2. Upon review of the complaint the Investigative Division initiated a preliminary inquiry on
March 27, 2002.
3. The preliminary inquiry was completed within sixty days.
4. On May 23, 2002, a letter was forwarded to William Keefer, by the Investigative
Division of the State Ethics Commission informing him that a complaint against him
was received by the Investigative Division and that a full investigation was being
commenced.
a. Said letter was forwarded by certified mail, no. 7001 0360 0001 4061 4935.
b. The domestic return receipt bore the signature of William Keefer, with a delivery
date of May 28, 2002.
5. Periodic notice letters were forwarded to William Keefer in accordance with the
provisions of the Ethics Law advising him of the general status of the investigation.
6. The Investigative Complaint was mailed to the Respondent on November 18, 2002.
7. William Keefer has served as a Monaca Borough Councilman since January 1998.
a. Keefer previously served on Monaca Borough Council from January 1980
through February 1, 1983.
Keefer 02- 033 -C2
Page 4
b. Keefer was employed by Monaca Borough as the Public Works Director from
February 1983 through January 1998.
8. In or around the fall of 2001, Monaca Borough was looking to purchase concrete
barriers for use as a safety barrier around a borough playground.
a. The barriers were to be used at the playground located adjacent to the borough
pump house on Atlantic Avenue.
b. The barriers were to be purchased as a result of a recommendation made by
the borough's insurance carrier.
9. The borough was unable to locate concrete barriers for the project due to the demand
caused by the events of September 11, 2001.
10. In late November 2001, William Keefer purchased various items from William Zajac,
owner of Four Seasons Landscape and Building Supply Company, a company that
was going out of business.
a. Keefer paid cash for the items.
b. Included in the items purchased by Keefer, were 12 round -top concrete barriers
and 12 jersey concrete barriers.
1. The cost of the barriers was $400.00 ($16.66 each).
11. Keefer purchased the barriers and other items for a lawn care business his son, Eric
Keefer, was starting.
12. In late November or early December 2001, Monaca Borough purchased for [sic] round
top concrete barriers from Eric Keefer.
a. There was no public bid or advertisement prior to the purchase.
13. Keefer acted as the liaison between the borough and his son in determining the cost of
the barriers.
a. No other borough official had contact with Eric Keefer in regard to the purchase
of the barriers.
b. William Keefer discussed the price for the barriers with Eugene Caltury, council
president.
14. Council President Eugene Caltury authorized the purchase of the barriers from Eric
Keefer.
a. Caltury was aware at that time that concrete barriers were difficult to locate.
15. On December 3, 2001, a generic invoice, no. 162760, was submitted to the Borough of
Monaca by Keefer for the concrete barriers in the amount of $600.00.
a. The invoice noted four round -top 12 -foot concrete barriers at $150.00 each.
16. The December 3, 2001, invoice was prepared by William Keefer and submitted to the
borough on behalf of his son.
a. Keefer handwrote his son's name and address at the top of the invoice.
Keefer 02- 033 -C2
Page 5
b. Keefer recorded his address, 1308 Center Road, Monaca, instead of his son's
address.
1. Eric Keefer's address is 1306 Center Road, Monaca.
17. At the December 11, 2001, Monaca Borough Council meeting several residents
questioned the purchase of the barriers.
a. Residents felt the barriers were an eyesore.
18. Monaca Borough check no. 6695, dated December 13, 2001, was issued to Eric
Keefer in the amount of $600.00.
a. The ayment covered the purchase of four round -top 12 -foot concrete barriers
at $150.00 each.
19. Check No. 6695 was included on the bill list approved for payment at the December
11, 2001, regular Monaca Borough Council meeting.
a. Keefer was present and participated in the vote to approve payment of the bills.
b. The bills were approved for payment by a unanimous vote, 10/0.
20. Signature authority for Monaca Borough's general fund is held by council president,
vice president and the borough treasurer.
a. Two signatures are required on borough checks.
b. Keefer did not sign the check issued to his son.
21. Check no. 6695, issued to Eric Keefer, was cashed by Eric Keefer.
a. Signatures of William Keefer and Eric Keefer appear on the reverse side of the
check.
22. In a sworn statement provided to the State Ethics Commission investigators on June
10, 2002, Keefer provided the following in regard to the concrete barriers.
a. He was first made aware of the borough's need for barriers during a
conversation with Council President Eugene Caltury.
b. He did not purchase the items for his son's lawn care business until after his
conversation with Caltury.
c. At the time he purchased the lawn care items, he became aware that 24
concrete barriers were included.
d. He paid $400.00 for the 24 barriers, or $16.66 each.
e. He did not obtain a receipt and paid for the barriers and other items in cash.
f. He made Caltury aware that his son had concrete barriers for sale.
g. Caltury subsequently advised him that the borough was interested in
purchasing four of the round top barriers.
h. He advised his son, Eric Keefer, who established the price of $150.00 for each
barrier, not including delivery.
Keefer 02- 033 -C2
Page 6
1.
Borough workers and equipment transported the barriers to the playground on
Atlantic Avenue, Monaca, PA.
Eric Keefer retained the proceeds of the sale.
k. Keefer has not received any roceeds from his sons [sic] business; his son has
not repaid him for the cost of the barriers or any other items Keefer purchased
for him.
He was unaware of the contracting provisions of the Ethics Law.
23. On June 10, 2002, Keefer reimbursed Monaca Borough for the concrete barriers with
personal check no. 222 in an amount of $600.00.
a. Under his signature on the front of the check Keefer wrote, "No new bill will be
sent."
b. Keefer's reimbursement was made after he provided a sworn statement to
Ethics Commission investigators on that same date.
24. Monaca Borough Acting Manager Pat Hogan issued Receipt No. 34920 to Keefer on
June 10, 2002, for the reimbursement.
25. Keefer's personal check no. 222 was deposited into the borough's account at Sky
Bank on June 10, 2002.
26. The borough is in possession of the four concrete barriers received from Eric Keefer.
a. No other payment has been made by the borough for the barriers.
27. On June 12, 2002, Acting Borough Manager Pat Hogan issued a letter to the State
Ethics Commission advising of the reimbursement received by the borough for the
concrete barriers purchased from Eric Keefer.
a. The letter was initiated at William Keefer's request.
The following findings relate to Keefer's failure to file a Statement of Financial
Interests
28. A Statement of Financial Interests Compliance Review was conducted by the
Investigative Division of the State Ethics Commission of Monaca Borough on
April 5, 2002.
29. No Statement of Financial Interests was on file with Monaca Borough for William
Keefer for calendar year 1998.
a. Statements of Financial Interests on file for Keefer included calendar years
1997, 1999, 2000.
30. Keefer filed a Statement of Financial Interests for the 1998 calendar year with the
Borough of Monaca on June 10, 2002.
a. Keefer filed the form after being advised by a State Ethics Commission
investigator on June 10, 2002, that no form for 1998 was on file with the
borough.
Keefer 02- 033 -C2
Page 7
31. The financial gain realized by Eric Keefer as a result of the use of the authority of office
by William Keefer to facilitate the sale of four concrete barriers to the Borough of
Monaca was $600.00.
III. DISCUSSION:
Respondent William Keefer (also referred to herein as "Respondent," "Keefer," or
"Respondent Keefer") has at all times relevant to this matter been a public official subject to
the provisions of the Public Official and Employee Ethics Act, Act 93 of 1998, Chapter 11, 65
Pa.C.S. § 1101 et seq., which Act is referred to herein as the "Ethics Act."
The allegations are that Keefer, in his capacity as a Councilman for Monaca Borough,
Beaver County, violated Sections 1103(a), 1103(f), 1104(a), and 1104(d) of the Ethics Act
when he contracted with the borough for the sale of concrete barriers in excess of $500.00
without an open and public process; when he used the authority of his office for a private
pecuniary gain by voting to approve a payment issued to him for the sale of concrete; and
when he failed to file a Statement of Financial Interests for the 1998 calendar year by May 1,
1999.
Pursuant to Section 1103(a) of the Ethics Act quoted above, a public official /public
employee is prohibited from engaging in conduct that constitutes a conflict of interest.
Specifically, Section 1103(a) of the Ethics Act prohibits a public official /public employee 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. The Ethics Act defines the term "immediate family" to include
"[a] parent, spouse, child, brother or sister." 65 Pa.C.S. § 1102.
Section 1103(f) of the Ethics Act imposes certain restrictions as to contracting. Section
1103(f)fl provides in part that no public official /public employee or spouse or child or business
with which he or the spouse or child is associated may enter into a contract with his
governmental body valued at five hundred dollars or more or any subcontract valued at five
hundred dollars or more with any person who has been awarded a contract with the
governmental body with which the public official /public employee is associated unless the
contract is awarded through an open and public process including prior public notice and
subsequent public disclosure.
Section 1104(a) of the Ethics Act quoted above requires that each public official /public
employee must file a Statement of Financial Interests 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 quoted above prohibits a public official from taking
the oath of office, entering or continuing the duties of his public office, or receiving
compensation from public funds unless he has filed a statement of financial interests as
required by the Ethics Act.
Having noted the issues and applicable law, we shall now summarize the relevant facts.
Given Respondent's failure to file an Answer to the Investigative Complaint, the facts as
averred in the Investigative Complaint are deemed admitted by the Respondent. 65 Pa.C.S. §
1108(e); 51 Pa. Code § 21.5(k).
Keefer has served as a Monaca Borough Councilman since January 1998. Keefer
also previously served as a Monaca Borough Councilman from January 1980 through
February 1, 1983, and as the Monaca Borough Public Works Director from February 1983
through January 1998.
In or around the fall of 2001, Monaca Borough ( "Borough ") was seeking to purchase
Keefer 02- 033 -C2
Page 8
concrete barriers for a particular project. The borough was unable to locate concrete barriers
for the project due to the demand caused by the events of September 11, 2001.
In late November 2001 Keefer purchased items including concrete barriers from a
company that was going out of business. Keefer purchased the items for a lawn care
business that his son, Eric Keefer, was starting. The total cost to Keefer for 12 "round -top"
concrete barriers and 12 "jersey" concrete barriers was $400.00 ($16.66 each).
In late November or early December 2001, the Borough purchased four round top
concrete barriers from Eric Keefer. There was no public bid or advertisement prior to the
purchase. Respondent Keefer acted as the liaison between the Borough and his son in
determining the cost of the barriers. No other borough official had contact with Eric Keefer
regarding the purchase of the barriers.
Keefer discussed the price for the barriers with Council President Eugene Caltury
( "Caltury "), who authorized the purchase of the barriers from Eric Keefer. Caltury was aware
at that time that concrete barriers were difficult to locate.
On December 3, 2001, Respondent Keefer submitted a generic invoice to the Borough
in the total amount of $600.00 for four round -top 12 -foot concrete barriers at $150.00 each.
The December 3, 2001, invoice was prepared and submitted to the Borough by Respondent
Keefer on behalf of his son. Keefer handwrote his son's name and an address at the top of
the invoice, using his own address, rather than his son's (different) address (Finding 16).
Subsequently, the Borough issued check no. 6695, dated December 13, 2001, in the
amount of $600 to Eric Keefer as payment for the concrete barriers. The check was included
on a bill list and was approved for payment at the December 11, 2001, regular Borough
Council meeting. Respondent Keefer was present and participated in the unanimous vote to
approve payment of the bills.
Respondent Keefer did not sign check no. 6695 in his capacity as a Borough
Councilman. The check was issued to Erik Keefer (Findings 18, 21), but bears signatures of
William Keefer and Eric Keefer on the reverse side of the check (Finding 21).
Respondent Keefer provided a sworn statement to State Ethics Commission
investigators on June 10, 2002, as detailed at Finding 22.
The financial gain realized by Eric Keefer as a result of the use of the authority of office
by Respondent Keefer to facilitate the sale of four concrete barriers to the Borough was
$600.00. On June 10, 2002, Keefer reimbursed the Borough for the concrete barriers with a
personal check in the amount of $600.00. Such reimbursement was made after Keefer
provided his sworn statement to Ethics Commission investigators.
Finally, per the undisputed Findings of the Investigative Complaint, a Statement of
Financial Interests Compliance Review of the Borough conducted on April 5, 2002,
established that no Statement of Financial Interests was on file with the Borough for
Respondent for calendar year 1998. Statements of Financial Interests were on file for Keefer
for calendar years 1997, 1999, and 2000. Keefer filed a Statement of Financial Interests for
the 1998 calendar year with the Borough on June 10, 2002, following discussions with a State
Ethics Commission investigator as to the absence of the form.
Having summarized the above relevant facts, we must now determine whether the
actions of Keefer violated Sections 1103(a), 1103(f), 1104(a), and /or 1104(d) of the Ethics
Act.
As we apply the facts to the allegations, we are mindful that due process requires that
we not depart from the allegations. Pennsy v. Department of State, 594 A.2d 845 (1991).
Keefer 02- 033 -C2
Page 9
Based upon our review of the record, we find that there is clear and convincing evidence to
support several violations under the allegations.
Clear and convincing evidence is "testimony that is so 'clear, direct, weighty, and
convincing as to enable the trier of fact to come to a clear conviction, without hesitance, of the
truth of the precise facts in issue. - In Re: Charles E.D.M., 550 Pa. 595, 601, 708 A.2d 88,
91 (Pa. 1998) (Citation omitted).
It is alleged that the Respondent violated Sections 1103(a), 1103(f), 1104(a), and
1104(d) of the Ethics Act when he: (1) contracted with the Borough for the sale of concrete
barriers in excess of $500.00 without an open and public process; (2) used the authority of his
office for a private pecuniary gain by voting to approve a payment issued to him for the sale of
concrete; and (3) failed to file a Statement of Financial Interests for the 1998 calendar year by
May 1, 1999. We shall address the enumerated allegations seriatim.
With regard to the first allegation, involving contracting, the facts are that Respondent
Keefer acted on his son's behalf as to the purchase by the Borough of the concrete barriers.
Erik Keefer did nothing to secure the contract, and no borough official other than Respondent
had contact with Eric Keefer regarding the purchase of the barriers. Respondent acted as a
liaison between his son and the Borough in discussing the price for the barriers with Caltury.
It was Respondent who prepared and submitted to the Borough the December 3, 2001,
invoice for the concrete barriers, affixing his son's name but his own address to the invoice.
Thus, although Respondent was not an actual party with obligations of his own under
the contract, he did in fact secure the contract with the Borough on behalf of his son, acting
essentially as the agent of his son.
Such contracting occurred without any open and public process as required by Section
1103(f) of the Ethics Act. (We would parenthetically note that under Section 1103(f), an open
and public process would have been required regardless of whether Respondent or his son
was the party to the contract.)
Given the absence of the requisite open and public process as to the contract, which
contract was in excess of $500.00, we hold that Respondent violated Section 1103(f) of the
Ethics Act when he /his son contracted with the Borough for the sale of concrete barriers to the
Borough for an amount in excess of $500.00 without an open and public process.
The second allegation is that Respondent used the authority of his office for a private
pecuniary gain by voting to approve a payment issued to him for the sale of concrete.
Factually, the Borough issued check no. 6695 in the amount of $600 as payment for
the concrete barriers. Respondent Keefer participated in the Borough Council's unanimous
vote to approve payment of the bill list which included this particular payment. Respondent's
participation in the vote to approve the payment constituted a use of the authority of
Respondent's public office which resulted in a private pecuniary gain to his son. See, e.q.,
Kurtz, Order 1116.
The check was issued to Erik Keefer (Findings 18, 21), but bears signatures of William
Keefer and Eric Keefer on the reverse side of the check (Finding 21).
Accordingly, we hold that Respondent violated Section 1103(a) of the Ethics Act when
he participated in the December 11, 2001, vote of Borough Council to approve a payment,
check no. 6695 in the amount of $600, issued to him /his son.
The third allegation involves Respondent's failure to file a Statement of Financial
Interests for the 1998 calendar year by May 1, 1999.
Keefer 02- 033 -C2
Page 10
A Statement of Financial Interests Compliance Review of the Borough conducted by
the Investigative Division on April 5, 2002, established that no Statement of Financial Interests
was on file with the Borough for Respondent for calendar year 1998. Statements of Financial
Interests were on file for Keefer for calendar years 1997, 1999, and 2000. Keefer filed a
Statement of Financial Interests for the 1998 calendar year with the Borough on June 10,
2002, following discussions with a State Ethics Commission investigator as to the absence of
the form.
Based upon the facts before us, we hold that Keefer violated Section 1104(a ) of the
Ethics Act when he failed to file a Statement of Financial Interests for the 1998 calendar year
by May 1, 1999.
As for Section 1104(d), which prohibits a ublic official from taking the oath of office,
entering or continuing the duties of his public office, or receiving compensation from public
funds unless he has filed a statement of financial interests as required by the Ethics Act, we
note that the record before us does not include the necessary facts to enable us to properly
analyze this particular portion of the allegations. The only official duties of Respondent
detailed in the Findings are those performed in 2001 pertaining to the concrete barriers. No
other official duties performed by Respondent have been asserted as the basis for a violation
of Section 1104(d), nor has there been any reference to any compensation Keefer may have
received from public funds during non - compliance as to the 1998 calendar year Statement of
Financial Interests. We hold that Keefer did not violate Section 1104(d) of the Ethics Act as to
his failure to timely file a Statement of Financial Interests for the 1998 calendar year based
upon an insufficiency of evidence.
Section 1107(13) of the Ethics Act empowers this Commission to impose restitution in
instances where a public official /public employee has obtained a financial gain in violation of
the Ethics Act. Keefer has already reimbursed the Borough in the amount of $600.00
representing the Borough's full purchase price for the concrete barriers purchased from
Keefer's son.
Finally, Keefer has filed a Statement of Financial Interests for the 1998 calendar year
with the Borough.
Based upon all of the above, this Commission shall take no further action in this case
which is closed. However, Keefer, as a public official, must conduct his future activities in
accordance with the provisions of the Ethics Act.
IV. CONCLUSIONS OF LAW:
1. William Keefer ( "Keefer "), as a Borough Councilman for Monaca Borough ( "Borough "),
has at all times relevant to these proceedings been a public official subject to the Public
Official and Employee Ethics Act, Act 93 of 1998, Chapter 11, 65 Pa.C.S. §1101 et
seq., which Act is referred to herein as the "Ethics Act.'
2. Keefer violated Section 1103(f) of the Ethics Act when he /his son contracted with the
Borough for the sale of concrete barriers to the Borough for an amount in excess of
$500.00 without an open and public process.
3. Keefer violated Section 1103(a) of the Ethics Act when he participated in the
December 11, 2001, vote of Borough Council to approve a payment, check no. 6695 in
the amount of $600, issued to him /his son.
4. Keefer violated Section 1104(a) of the Ethics Act when he failed to file a Statement of
Financial Interests for the 1998 calendar year by May 1, 1999.
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Page 11
5. Keefer did not violate Section 1104(d) of the Ethics Act as to his failure to timely file a
Statement of Financial Interests for the 1998 calendar year based upon an
insufficiency of evidence.
In Re: William Keefer
ORDER NO. 1266
File Docket: 02- 033 -C2
Date Decided: 12/24/02
Date Mailed: 12/30/02
1. William Keefer ( "Keefer "), a public official in his capacity as a Borough Councilman for
Monaca Borough ( "Borough "), violated Section 1103(f) of the Ethics Act when he /his
son contracted with the Borough for the sale of concrete barriers to the Borough for an
amount in excess of $500.00 without an open and public process.
2. Keefer violated Section 1103(a) of the Ethics Act when he participated in the
December 11, 2001, vote of Borough Council to approve a payment, check no. 6695 in
the amount of $600, issued to him /his son.
3. Keefer violated Section 1104(a) of the Ethics Act when he failed to file a Statement of
Financial Interests for the 199 calendar year by May 1, 1999.
4. Keefer did not violate Section 1104(d) of the Ethics Act as to his failure to timely file a
Statement of Financial Interests for the 1998 calendar year based upon an
insufficiency of evidence.
BY THE COMMISSION,
Louis W. Fryman, Chair