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HomeMy WebLinkAbout1378 YoungIn Re: Wilbert Young File Docket: X -ref: Date Decided: Date Mailed: Before: Louis W. Fryman, Chair John J. Bolger, Vice Chair Donald M. McCurdy Raquel K. Bergen Nicholas A. Colafella 04 -021 Order No. 1378 9/12/05 9/21/05 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 9 of 1989, P.L. 26, 65 P.S. § 401 et seq., as codified by 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 allegations. Upon completion of its investigation, the Investigative Division issued and served upon Respondent a Findings Report identified as an "Investigative Complaint." An Answer was filed and a hearing was deemed waived. A Consent Agreement and Stipulation of Findings were submitted by the parties to the Commission for consideration. The Stipulation of Findings is quoted as the Findings in this Order. The Consent Agreement was subsequently approved. Effective December 15, 1998, Act 9 of 1989 was repealed and replaced by Chapter 11 of Act 93 of 1998, 65 Pa.C.S. § 1101 et seq., which essentially repeats Act 9 of 1989 and provides for the completion of pending matters under Act 93 of 1998. 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. Young, 04 -021 Page 2 I. ALLEGATION: That Wilbert Young, a public official /public employee, in his capacity as Mayor of the City of Wilkinsburg, Allegheny County, violated Sections 1103(a) and 1105(b)(5)(8) provisions of the State Ethics Act (Act 93 of 1998), 65 Pa.C.S. § §1103(a) and 1105(b)(5)(8) when he used the authority of his office for a private pecuniary gain, including but not limited to obtaining a cellular telephone at borough expense without council approval and utilizing a cellular telephone supplied by the borough to make personal telephone calls; and when he used the authority of his public position for the private pecuniary benefit of himself and /or a business with which he is associated by negotiating, as mayor, to obtain a property from a borough resident to satisfy a delinquent property tax bill and subsequently converted the property to 827 Partnership, a business with which he is associated; and when he used the authority of his public position to use borough equipment, facilities and personnel in support of his private businesses; and when he failed to disclose on Statements of Financial Interests filed for the 2002 and 2003 calendar years, sources of income and offices, directorships or employment in businesses. II. FINDINGS: 1. Wilbert A. Young has served as Mayor of the Borough of Wilkinsburg, Allegheny County, since 1998. 2. Records of the Pennsylvania Department of State confirm that Young incorporated W.A. Young Company, Inc, on 01/20/99. a. Wilbert A. Young and Meredith W. Young, 575 Ardmore Boulevard, Pittsburgh, PA 15219 are listed as the incorporators. 1. Meredith Young is Wilbert Young's spouse. b. Young is listed as the president and treasurer, and Meredith Young as the secretary. 3. Companies in which Young has a financial interest, is an officer or director or otherwise operates, in addition to W.A. Young Company, Inc., include: Franklin Avenue Associates Sherman Street Associates 827 Partnership NEMO Investments Inc. Housing Development Partnership 4. Franklin Avenue Associates, Shermon Street Associates, 827 Partnership and Housing Development Partnership are paper companies formed by Young for the purpose of acquiring properties, mainly in the borough of Wilkinsburg. a. Sherman Street Associates was a name used by Young when securing ownership of 1116 Sherman Street, Wilkinsburg. b. Housing Development Partnership was a name used by Young to obtain ownership of five properties located in Wilkinsburg from David Bradbury. The properties are: c. 827 Partnership was as name used by Young in 2001, when acquiring property at 827 Holland Avenue, Wilkinsburg. d. None of the above entities created by Young are incorporated or registered Young, 04 -021 Page 3 as fictitious names with Pennsylvania Department of State Corporation Bureau. 5. Young consulting business, W.A. Young Company, and all of his other companies, utilize residence address, 575 Ardmore Boulevard, Wilkinsburg, PA 15221. a. Young does not maintain a separate office from which to conduct his businesses. 6. Young holds an active real estate license through the Pennsylvania Department of State Bureau of Professional and Occupational Affairs. 7 Young has been affiliated with Prudential Realty Company since approximately 1996. a. Prudential Realty Company is in a property management business with a limited involvement in housing sales. b. Young is an independent contractor in the area of sales. c. Young's compensation is based on commission. 8. Young does not utilize the offices of the Prudential Realty Company office on South Water Street, Pittsburgh. a. The contact telephone number Young provided to the owner of the company was that of his borough cellular telephone and his borough office telephone. b. Young also used his home telephone and his personal telephone number as contacts. c. Young has not brought any real estate business to the office since at least April 22, 2002. The following findings relate to Young's use of his position in negotiating to obtain a property from a borough resident to satisfy a delinquent property tax bill and subsequently converting the property to 827 Partnership, a business with which he is associated. 9. Alan and Patricia Middlemiss owned property at 827 Holland Avenue, Wilkinsburg since 1976. a. They initially lived in the house but in 1991 they moved and retained the house as rental property. b. In approximately 1994 they entered into a contract for the sale of the house. 10. In or around 1996, the Middlemiss' became aware that the buyer was not paying the property taxes. a. The Middlemiss' began receiving bills for unpaid taxes. b. Numerous attempts to compel the buyer to pay the taxes went unheeded. c. In 1998, the buyer stopped paying the installment payments. Young, 04 -021 Page 4 11. The Middlemisses subsequently regained possession of the property, attempted to sell or give away the dwelling due to the building's poor condition and the amount owed on back taxes. 12. In or about November 2001 Patricia Middlemiss called the Wilkinsburg Mayor's office in an effort to determine if the Borough could help them with the taxes. a. She believed that the mayor would be the borough official they would need to deal with. b. Patricia Middlemiss was directed to Wilbert Young. 13. The Middlemiss' were not interested in keeping the house even if the taxes could have been forgiven for them. a. Young informed Patricia Middlemiss that there was an individual working for the borough who might be interested in the property. 14. On November 26, 2001, approximately one week after Patricia Middlemiss first contacted Young, the Middlemiss' transferred ownership of 827 Holland Avenue. a. Young assured the Middlemiss' that they would no longer be responsible for the unpaid taxes or anything else to do with the house. 15. Young provided all of the paperwork necessary for the property transfer. 16. The Deed signed by the Middlemisses identified the buyer' as 827 Partnership. a. The Tax Address listed on the Deed for 827 Partnership is 575 Ardmore Boulevard, Young's home address. b. 827 Partnership is a paper company created by Young to secure the property at 827 Holland Avenue. 17. The Deed reflects that the Middlemiss' received $4,000.00 as a result of the transfer of the property. a. The Middlemiss' received no payments from Young for 827 Partnership. b. Young told them that it was necessary to list an amount on the Deed for tax purposes. 18. Young sent Patricia Middlemiss an email on 11/27/01 confirming the transaction and that they had not been paid for the property. 19. On March 25, 2002, Patricia Middlemiss e- mailed Young and requested a copy of the note from the title company verifying that the judgment on 827 Holland Avenue had been satisfied, and a letter from him confirming that they did not receive any funds for the property that they transferred to 827 Partnership. a. On March 25, 2002, Young responded as follows: "Hi Patti I will forward to you a settlement statement as soon as the transfer to the new owner is complete. I also would like to indicate that the consideration mentioned in the deed between you and 827 Young, 04 -021 Page 5 Partnership of $4,000.00 was used toward outstanding debt on the property. There were no funds exchanged between the Middlemiss and 827 Partnership. Wilbert" 20. Patricia and Alan Middlemiss filed a joint 2001 U.S. Individual Federal Income Tax Return Form 1040, on which they reported the conveyance of the 827 Holland Avenue property to the Borough of Wilkinsburg. 21. In April 2003, while refinancing the mortgage on their house, the Middlemiss realized that they were still listed on the property taxes for 827 Holland Avenue. a. Patricia Middlemiss again contacted Young and asked him to file an amended municipal claim to have their names removed from the tax roll regarding the property. b. Young advised that he would straighten things out, and call them back. 22. Between April 2003 and September 2003 Patricia Middlemiss made numerous contacts in an effort to have their names removed from the property. a. On September 17, 2003 Middlemiss spoke with Young who told them that he would make an inquiry as to why they were still listed on the docket. b. Young did advise Patricia Middlemiss that he had sold the property to Allegheny County Rentals. 23. On September 24, 2003, Patricia Middlemiss sent a letter directed to Wilkinsburg Borough Solicitor Patricia McGrail recounting the history of the property and her dealings with Mayor Young documenting the history of the property, including their unsuccessful efforts to sell the property for $100.00 as follows: a. Middlemiss contacted the Mayor of Wilkinsburg to see if he could help them with the back taxes and liens. b. The Mayor, Young, told them the unpaid taxes would go along with the house, and they would be relieved of the burden of the unpaid taxes as all delinquent taxes would be paid at closing. c. The Mayor told them that the Borough would probably be able to relieve the new owner of the taxes, and the new owner would be able to purchase the house for very little. d. Upon refinancing their house in 04/03, the Holland Avenue taxes came up. e. Middlemiss personally took the Praecipe to Satisfy Judgments to Mayor Young's office, and asked him to file it with the Allegheny County Prothonotary. 1. In September 2003, when Middlemiss asked Young if he had filed the Praecipe, he blamed his office for mixing things up with the records. f. Middlemiss informed the Mayor that he needed to file an amended municipal claim to have their names removed for the 827 Holland Avenue tax roles. 24. Attorney McGrail responded by letter dated 10/15/03, in which she opined that the Deed for 827 Holland Avenue (which Middlemiss had obtained from the Recorder of Young, 04 -021 Page 6 Deeds Office) showed that the property had been transferred to 827 Partnership. a. At the time of the transactions, all liens would have followed the grantee of the property, 827 Partnership. b. The property was never conveyed to the Borough of Wilkinsburg by the Middlemisses. c. McGrail had not been asked to file a Praecipe to Satisfy Judgments with regard to the property on behalf of the Borough. d. McGrail initiated a full title search with the intent of confirming the status of any judgments or liens involving the Middlemiss' or the property at 827 Holland Avenue. e. McGrail affirmed that the transaction regarding 827 Partnership and 827 Holland Avenue did not involve the Borough of Wilkinsburg. 25. By way of letter dated 10/27/03, Heather M. Johnson, Legal Assistant for Portnoff Law Associates, LTD, provided a copy of the Allegheny County Tax Assessment Office records for the property at 827 Holland Avenue, that showed that the Middlemiss' were no longer the owner of record on the property. 26. Young eventually submitted a document on the letterhead of W.A. Young Company, 575 Ardmore Boulevard, Pittsburgh, PA 15221 to Alan and Patricia Middlemiss which provided as follows: This is a disclosure letter informing you that I am the mayor of Wilkinsburg and that I am not involved in this transaction in any official capacity. When the deed is signed and recorded this will relieve you of any past Borough, School or County Taxes." 27. From at least early 2003, Young was attempting to sell 827 Holland Avenue to Allegheny County Rentals. a. Young, in his capacity as a real estate consultant, has been assisting Allegheny County Rentals locate properties since November 2002. 28. Allegheny County Rentals is involved in the business of scattered site single family property development. a. Cathleen Feder -Perr is the owner of the business. b. Jonathan Perr is responsible for the day to day operation and all administrative matters for Allegheny County Rentals. 29. Between 1/10/03 and 2/06/04, Jonathan Perr and /or Allegheny County Rentals paid Young $60,846 in hand money for various properties Young was helping the company purchase. a. Most of the payments were not designated for specific properties. 1. Young would indicate to Perr that he needed hand money to make offers on property. b. The hand money paid by Allegheny County Rentals to Young was for Young's assistance in obtaining /purchasing property in Wilkinsburg Borough Young, 04 -021 Page 7 and other areas. c. There were no signed contracts or Agreements between Young and Allegheny County Rentals. 30. Checks issued by Allegheny County Rentals to Young /NEMO Investments were deposited into Young's NEMO Investments Account held at Parkvale Bank. a. None of the checks were deposited into an escrow account with Prudential Realty Company. b. The NEMO account was used by Young to issue payments to himself and various living expenses. 31. On March 1, 2003, a General Warranty Deed was recorded between 827 Partnership and Allegheny County Rentals, LLC for 827 Holland Avenue. a. Young, as a partner for 827 Partnership, signed the Deed, and authorized the transfer for the consideration of $1.00. b. Cathleen Perr signed the Deed on behalf of Allegheny County Rentals. 32. The Allegheny Count - Realty Transfer Tax Stamp reflected a total consideration of $4,000.00. a. The assessed value of the property was $21,800.00. b. The fair market value of the property was $23,108.00. 33. During the period from January 10, 2003, to March 2003 when he was locating property for Allegheny County Rentals which resulted in the sale of 827 Holland Avenue, Young received payments totaling $7,750. a. There is no documentation specifically indicating that these payments were related to the 827 Holland Avenue property. b. Although the county transfer stamp reflects a total consideration paid of $4,000; there is no evidence that such was paid to Young. The following findings relate to Young's use of a borough cellular telephone for personal use. 34. Wilkinsburg Borough maintains cellular telephone service with Nextel. a. Young was one of the officials designated to receive a cellular telephone. 35. Borough Fire Chief Owen McAfee is responsible for administration of the borough telephone service. 36. In a memo dated 11/09/01, Finance Director DaShana Jacobs issued a memo to all department heads, outlining the procedure to be followed for the cellular telephone bills, as follows: a. Review the bills with your staff, noting all personal phone calls. Please review directory assistance calls with your staff in an effort to reduce these charges where possible. Young, 04 -021 Page 8 b. Photocopy the bill for each staff member that has had personal phone calls. c. Have staff members initial their personal calls and collect payments. d. Bring your department copies (in 2 above) to the Finance Office, Room 303, to make reimbursement to the Borough and have your departments phone expense property credited. e. Initial and return the attached copy to the Finance Director. 37. Wilkinsburg Borough paid a basic plan rate for each Nextel cellular telephone. a. All of the Nextel cellular telephones are on a shared minutes plan (3500 minutes) with the exception of Young's. 38. McAfee upgraded the plan for Young's cellular telephone several times between 08/01 and 01/05 due to Young repeatedly exceeding the number of minutes allowed by the plan. a. McAfee attempted to obtain plans for Young which would increase the number of cellular minutes offered in the monthly plan in an effort to minimize extra charges incurred by Young. b. The adjustments were made in with Young's consent, and in consultation with the borough manager. 39. The Nextel plans implemented for Young's cellular telephone included various coverage plans. a. The plan was upgraded in or about May 2002 to the National Unlimited NDC Plus Plan because of the volume and cost of Young's phone usage. 1. The plan afforded unlimited incoming and outgoing calls, with the exception of Directory Assistance. 40. Between August 2001 and March 2005 Young incurred costs which exceeded the plan rate by $2,250.31 for the borough Nextel cellular telephone he used. 41. Young approximated his personal use of the borough cellular telephone at $20.00 per month. a. Based on this estimation, Young has reimbursed the borough in the amount of $367.14, one month of his net pay from the borough. b. Young has had possession of the cellular telephone for 43 months. 1. Based on Young's estimate of $20.00 /month, Young should have reimbursed the borough $860.00 42. By email dated August 23, 2004, Young informed Borough Finance Director Wayne Jones that he would forgo his monthly compensation in lieu of reimbursing the borough for his personal use of the Nextel cellular telephone. a. Jones withheld Young's payment for the month of September 2004 in the amount of $367.84. b. Jones made a handwritten notation of the amount of the salary withheld on Young, 04 -021 Page 9 the email. c. Young's gross monthly stipend is $416.67. The net amount of $367.84 was given back to the borough and deposited into the general fund. 43. Council was aware of the cost to the borough for Young's telephone usage. a. Council reviews bills in the finance committee meetings. b. Although some questions were raised regarding the excessive charges, no action was taken to limit Young's cellular telephone use. 44. Young has made a total of $367.84 in reimbursement to the borough for personal use of the borough cellular telephone. 45. Based on Young's estimation of $20.00 /month cellular telephone use, Young owes the borough $492.16 for his use of the borough cellular telephone. 46. Young believed that he had reimbursed the borough for at least an additional month and that the amount remaining was de minimis. The following findings relate to Young's use of borough computers, employees and equipment for his personal use. 47. Wilbert Young has utilized borough equipment, supplies and employees in furtherance of his private business interests. a. Young's use of borough equipment, facilities and personnel to conduct his personal real estate and development business was not approved or authorized by council. 48. Young would use the borough offices to transact his private real estate consulting /sales business. 49. Wilkinsburg Borough does not have a written policy that is enforced borough wide relating to the use of borough equipment for non - borough related purposes. 50. Since at least March 2002 Young has been in possession of a laptop computer which had been in possession of former Police Chief Mark Springer. 51. The laptop was purchased by the borough in or about June 15, 2001, from CompUSA. a. The computer is a Compaq Presario laptop, Model# 18XL280. b. The price of the computer was 1,058.88. 52. Young utilized the computer for over two years until approximately mid -2004 when a substance was spilled on the keyboard damaging the unit. 53. Young was also assigned a desktop computer, property of the borough, for official borough use. a. The borough experienced problems with hard drive of this unit and other similar units. Young, 04 -021 Page 10 b. The desktop was replaced by Young with the laptop. 54. In or around mid -2004 Young was provided with a Gateway desk -top computer to use in place of the laptop computer that had been damaged. 55. Both the laptop and desktop were utilized by Young to further his private business interests. 56. Michelle Kenney has been employed by the Borough of Wilkinsburg in the position of Police Department clerical /secretary employee for five years. 57. From approximately October 2002 Young has occasionally utilized Kenney to type letters and correspondence, and to correct and review drafts letters of Young had written related to his private business interests. a. The information was most often saved to floppy disks which Young and Kenney transferred between them. 1. The work was prepared on borough computers assigned to Young and Kenney. b. Kenney performed the work for Young during her regular work hours for the borough. c. Kenney also performed the work for lunch on her lunch hour and breaks. d. The typing generally consisted of one page letters. 58. When preparing correspondence of a personal nature for Young, Kenney would use letterhead of the borough mayor's office. a. The municipal building address and telephone numbers were printed on the bottom of the page. b. The letters contained Young's name and the title of mayor. 59. Kenney typed documents for Young that were provided to her by Young in handwritten form or on a disk. a. Kenney did not document when she performed work for Young. 60. Files contained on floppy diskettes maintained by Michelle Kenney confirm Kenney's use of a borough computer to prepare documents related to Young's outside business interests. a. The documents were prepared by Kenney at Young's direction. 61. Files obtained from the hard drives of computers used by Young contain documents that relate to property Young had a personal business interest in, or that relate to real estate /development clients. 62. Files obtained from the desktop computer used by Police Department clerical /secretarial employee, Michelle Kenney, confirm the use of such computer for Young's personal business interests. a. The files contained documents prepared and /or edited by Kenney for Young. Young, 04 -021 Page 11 63. Young's computer contained a Folder titled `Excel Spreadsheets', which contained development spreadsheets relating to real estate. a. The spreadsheets generally reflected information on revenue, expenses, and per unit cost. b. A number of the spreadsheets were titled `proforma' or `Sources'. c. Forty -nine (49) of the sixty -three (63) files related to businesses and development cost overviews for real estate ventures in which Young had a private interest. 64. Kenney prepared various correspondences at Young's direction that were related to Allegheny County Rentals /Jonathan Perr. a. Kenney was provided with floppy disks containing correspondence and documents that Young instructed her to review and make corrections as necessary. 65. The floppy disks in Michelle Kenney's possession included various documents that relate to Young's private real estate /development businesses with Allegheny County Rentals and other Young real estate ventures. 66. Young also utilized the computers assigned to him to prepare and store documents related to his business relationship with Allegheny County Rentals /Jonathan Perr. 67. During the period from late 1992 through early 2004, Young did not maintain a private office to maintain his business relationship with Allegheny Rentals. a. Young occasionally utilized his public office, equipment and employees for this private business interests. 68. Young used the desktop computer in his office to access the Allegheny County Real Estate Web Site in relation to properties that he was attempting to secure for clients of his private business interests. a. 456 files on the hard drive were contained in a folder titled "Web Pages" b. Thirty -six files related to property that Young had sold or had accepted hand money. c. Thirty -nine files were property images, and 21 files were search related. d. All but 14 files were related to real estate. 69. Young utilized the borough computer to prepare documents related to Deliverance Inc., an entity he was involved with in private real estate ventures. a. Deliverance Incorporated is a non - profit charitable corporation whose purpose is to purchase and rehabilitate property for rental and resale purposes. 1. Mark Lewis is the President and Chief Executive Officer of the company. 70. Young sold property to, accepted hand money from, and was working with Deliverance Incorporated on various projects. Young, 04 -021 Page 12 a. Young, acting as Housing Development Corporation, sold 1235 Morrow Street, Wilkinsburg to Deliverance Inc. for 16,500. 1. Young obtained the Morrow Street property from David Bradbury. b. Young received hand money from Deliverance Inc. to secure property at 417 Peebles; 812 Coal Street; and 1215 Franklin Avenue. 1. Young received $2,500 for 417 Peebles and $1,000 for 812 Coal Street. 2. Young obtained these properties from David Bradbury. (See Finding 102) 3. Young retained the funds even though no agreements on the property were reached. 71. Young's computers contained documents Young utilized in his private real estate transactions involving Deliverance Inc. 72. In the spring of 2002, Young was involved in a real estate transaction with a David Bradbury. a. Bradbury was delinquent in paying the property taxes on a number of properties he owned in the borough. b. Bradbury had been trying to sell or give the properties away which were in poor condition. c. Young was interested in obtaining some of Bradbury's property: 417 Peebles Street 1123 South Avenue 1235 Morrow Street 812 Coal Street 1307 Labelle Street 73. On May 1, 2002, Young and Bradbury entered into an Agreement to transfer the properties to Young. a. Bradbury agreed to transfer the properties to Young with the understanding that he would not pay any of the costs associated with the transaction, including taxes. b. Young obtained the properties in the business name Housing Development Partnership, an entity Young created for the transfer of property. e. Young did not pay Bradbury for the properties. 74. The Agreement was for five properties, including: 417 Peebles Street, 1235 Morrow Street, 1307 LaBelle Street and adjacent lot to the left, 1123 South Avenue, and 812 Coal Street. a. Young agreed to accept ownership of the properties with the knowledge that there were, or may have been, numerous tax liens, judgments, municipal service liens, code violation, and /or utility liens filed against the properties. b. Young agreed to accept the properties and take title subject to any and all liens, judgments, or violations against them. Young, 04 -021 Page 13 75. Young utilized Benita Todd, Police Department Office Manager in 2002, to notarize documents for Young on borough time. 76. At the time that Bradbury transferred the properties to Young, the total market value was $67,600.00. 417 Peebles Street - 1235 Morrow Street - 1307 La Belle Avenue - 1123 South Avenue - 812 Coal Street - c. Young returned the money. $11,400.00 $21,400.00 $30,400.00 $ 2,300.00 $2,100.00 a. The Labelle Avenue property was eventually sold by Young to Deliverance Inc. b. Young eventually sold 1235 Morrow Street to Deliverance Inc. for $16,500. 77. Young maintained files on his borough computers related to the acquisition of the five properties from David Bradbury. 78. Young used borough cellular telephones, borough landlines and computers in furtherance of a private business relationship with R.E. Crawford Construction Company. 79. Young was paid $1000.00 per month as a consultant for R. E. Crawford Construction Company from 10/03 through 12/03. a. Young was to receive commissions on leads on potential development projects that he provided to R. E. Crawford Construction. b. Young was also working on leads for R. E. Crawford in Atlanta, Georgia. c. Contact telephone numbers that Young provided to R.E. Crawford Construction were the borough cellular telephone and his borough office telephone number. 80. Young maintained files on his borough computers related to his association with R. E. Crawford Construction Company. 81. In or about June 2001 Young was providing real estate services to Strength Inc. a. Strength Incorporated is a non - profit corporation located in the Borough of Wilkinsburg that provides treatment facilities and recovery housing. b. Strength Inc. owns property on South Avenue, Wilkinsburg. 82. Young was utilized by Strength Inc. for information regarding other property on South Avenue that Strength was interested in acquiring. a. Young was given $1,000.00 in hand money toward the acquisition of the property. b. Young was asked to return the hand money when no action was taken to acquire the property on behalf of Strength Inc. Young, 04 -021 Page 14 83. Two letters from Mayor Young dated 6/16/01, related to Strength's interest in purchasing property on South Avenue, were contained on a floppy diskettes maintained by Kenney. 84. Young maintained other files on his borough computers related to various other property sales, and or developments in which Young had a financial interest. The following findings relate to Young's failure to disclose sources of income on Statements of Financial Interests. 85. In his capacity as Mayor, Young has filed Statements of Financial Interests (SFIs) with the Borough of Wilkinsburg as follows: CALENDAR YEAR 2002 2003 2003 2004 FILING DATE 01/08/04 01/08/04 01/26/04 03/06/05 03/24/05 86. Young disclosed the following information on Statements of Financial Interests on file with the Borough: a. Calendar Year 2002: Block 6 - Occupation: Real Estate Sales /Consulting Block 10 - Sources of Income: PRC Commercial, 3700 Water Street, Pittsburgh; Consultant work, 575 Ardmore Boulevard, Pittsburgh Pa 15221. Block 13 - Office, Directorship or Employment in any Business: Landmark Development; National Conference of Black Mayors; Federal Home Loan Bank of Pittsburgh Advisory Council. Block 14 — Financial Interest in any Legal Entity in Business fro Profit: None b. Calendar Year 2003: Block 6 - Occupation: Real Estate Sales /Consulting Block 10 - Sources of Income: PRC Commercial, 3700 Water Street, Pittsburgh; Consultant work, 575 Ardmore Boulevard, Pittsburgh Pa 15221. Block 13 - Office, Directorship or Employment in any Business: Landmark Development; National Conference of Black Mayors; Federal Home Loan Bank of Pittsburgh Advisory Council. Block 14 — Financial Interest in any Legal Entity in Business fro Profit: None c. Calendar Year 2004 (filed 03/06/05): Block 6 - Occupation: Real Estate Sales Consulting & Development Block 10 - Sources of Income: PRC Commercial, 3700 S. Water St., Young, 04 -021 Page 15 Wilkinsburg Borough; Consulting Fees, 575 Ardmore Blvd, Wilkinsburg Borough. Block 13 - Office, Directorship or Employment in any Business: NCBM — director Block 14 - Financial Interest in Any Legal Entity in Business for Profit: Nemo Investment, 2932 Webster Ave. - CEO, 100% Owner d. Calendar Year 2004 (filed 03/24/05): 2002 SFI: Block 6 - Occupation: Real Estate Development & Consulting Block 9 - Creditors: None — No lien or debt reduced to executable judgment to any one entity and no credit owed in excess of $6,500.00. Block 10 - Sources of Income: PRC Commercial, 3700 S. Water St., Wilkinsburg Borough, Consulting Fees Private Practice: 575 Ardmore Blvd. Block 13 - Office, Directorship or employment in any Business: NCBM — director. Block 14 - Financial Interest in any Legal Entity in Business for Profit: Nemo Investments, 2932 Webster Ave, 15219, or 575 Ardmore Blvd, 15221 e. Other than as noted, all other financial interest categories for each year are marked none. 87. Young failed to disclose income from Nemo Investments on his Statement of Financial Interest filed for the 2002 calendar year. a. Payments were received by Young payable to Nemo Investments totaling $20,000 in 2002 for real estate services. 88. Young failed to disclose sources of income in excess of $1,300 on his SFI filed for the 2003 calendar year. a. R.E. Crawford b. Allegheny County Rentals c. Nemo Investments d. PRC Commercial 89. Young believed that he had complied with the filing requirements by reporting "consultant work" as a source of income. 90. Young failed to disclose on Block 13 of Statements of Financial Interests filed for the 2002 and 2003 calendar year the following entities: 827 Partnership Housing Development Partnership Nemo Investments 2003 SFI: Housing Development Partnership Nemo Investments Young, 04 -021 Page 16 III. DISCUSSION: At all times relevant to this matter, the Respondent, Wilbert Young (Young), has been a public official subject to the provisions of the Public Official and Employee Ethics Law, Act 9 of 1989, Pamphlet Law 26, 65 P.S. § 401, et seq., as codified by the Public Official and Employee Ethics Act, Act 93 of 1998, Chapter 11, 65 Pa.C.S. § 1101 et seq., which Acts are referred to herein as the "Ethics Act." The allegations are that Young, as Mayor of the City of Wilkinsburg, Allegheny County, violated Sections 1103(a) and 1105(b)(5) and (8) of the Ethics Act when he obtained a cellular telephone at borough expense without council approval and utilized the cellular telephone supplied by the borough to make personal telephone calls; when he negotiated as Mayor to obtain a property from borough residents to satisfy a delinquent property tax bill and subsequently converted the property to 827 Partnership, a business with which he is associated; when he used borough equipment, facilities and personnel in support of his private businesses; and when he failed to disclose on Statements of Financial Interests (SFIs) filed for the 2002 and 2003 calendar years, sources of income, and offices, directorships or employment in business entities. Pursuant to Section 1103(a) of the Ethics Act, a public official /public employee is prohibited from engaging in conduct that constitutes a conflict of interest. The term "conflict of interest" is defined under Act 93 of 1998 as follows: Section 1102. Definitions "Conflict" or "conflict of interest." Use by a public official or public employee of the authority of his office or employment or any confidential information received through his holding public office or employment for the private pecuniary benefit of himself, a member of his immediate family or a business with which he or a member of his immediate family is associated. "Conflict" or "conflict of interest" does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. 65 Pa.C.S. § 1102. 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. Section 1105(b)(5) of the Ethics Act requires that every public official /public employee and candidate list the name and address of any direct or indirect source of income totaling in the aggregate of $1,300 or more. Section 1105(b)(8) of the Ethics Act requires that any office, directorship or employment in any business entity be listed. Young, 04 -021 Page 17 As noted above, the parties have submitted a Consent Agreement and Stipulation of Findings. The parties' Stipulated Findings are reproduced above as the Findings of this Commission. We shall now summarize the relevant facts as contained therein. Young has served as the Wilkinsburg Borough Mayor since 1998. In a private capacity, Young is the President and Treasurer of the W.A. Young Company, Inc. In addition, Young is either the holder of a financial interest, an officer or a director in several other companies: Franklin Avenue Associates, Sherman Street Associates, 827 Partnership, NEMO Investments, Inc. and Housing Development Partnership. Young has used some of these entities, which are neither incorporated nor registered with the Pennsylvania Department of State, for the purpose of acquiring properties in Wilkinsburg. Young holds an active real estate license in Pennsylvania. Young also has an affiliation with Prudential Realty Company, a property management and limited housing sales business, wherein Young acts as an independent contractor and receives compensation on a commission basis. Young does not utilize the offices of Prudential Realty Company. Young provided his Borough cellular number and Borough office telephone number as a contact point to the owner of Prudential Realty Company. The allegations against Young involve the following groups of factual scenarios: property obtained by Young that was the subject of delinquent property tax; the acquisition of a cellular phone by Young at the Borough's expense; the use by Young of a Borough's cellular telephone for business purposes; the use by Young of the Borough computers, employees and equipment for business purposes; and the failure by Young to disclose sources of income and business interests on his SFIs for the 2002 and 2003 calendar years. Regarding the first factual scenario as to the realty that was subject to delinquent property tax, Alan and Patricia Middlemiss owned the property located at 827 Holland Avenue in Wilkinsburg. Subsequently, the Middlemisses entered into a contract for the sale of the realty and became aware that the buyer was not paying the property taxes. The buyer then stopped making the installment payments and the Middlemisses regained possession of the property. Since the Middlemisses were not interested in keeping the property even if the taxes could be forgiven, they contacted Young as Mayor who informed them that there was an individual working for the Borough who might be interested in the property and that if they made the transfer, they would not be responsible for any unpaid taxes or any other expenses related to the property. Young prepared the paperwork for the transfer, including a deed from the Middlemisses to a buyer that was identified as the 827 Partnership. The 827 Partnership, a paper company created by Young to secure the transfer of the property, has a tax address, which is Young's home address. Although the deed for the property reflected that the Middlemisses received consideration of $4,000, the Middlemisses in fact received no payment from Young. After the transaction was completed, the Middlemisses sent an email to Young for a confirmation that the judgment on the property had been satisfied. Young responded that he would send a settlement statement to them. However, when the Middlemisses sought to refinance the mortgage on their house in April of 2003, they learned that they were still listed on the property tax rolls for the Holland Avenue property. The Middlemisses then contacted Young, who advised that he would resolve the matter and call them back. The Middlemisses made numerous subsequent contacts with Young to have their names removed from the property. In September 2003, Patricia Middlemiss contacted the Borough Solicitor and recounted the history of the property transfer with Young. The Solicitor responded that the Young, 04 -021 Page 18 property was not conveyed to the Borough of Wilkinsburg, but to the 827 Partnership. Subsequently, the Allegheny County Tax Assessment Office provided the Middlemisses with a letter that showed they were no longer owners of record of the property. Young attempted to sell the Holland Avenue property to Allegheny County Rentals. Young acted in the capacity of a real estate consultant to assist Allegheny County Rentals in locating properties. Allegheny County Rentals is involved in the business of scattered site single family property development. Allegheny County Rentals paid Young $60,846 for a group of properties that Young was helping the company purchase. The money that Young received was not designated for specific properties but for his assistance in obtaining or purchasing property in the Borough or other areas for Allegheny County Rentals. In March 2003, Young deeded the Holland Avenue property to Allegheny County Rentals for a stated consideration of $1.00. A transfer tax stamp reflected the actual consideration of $4,000.00 for the property. The next factual scenario concerns the acquisition and use of a Borough cellular telephone by Young. The Borough maintained a cellular telephone service with a shared plan for designated individuals with the exception of Young, who had an individual cellular plan as Mayor. The Borough Finance Director had a policy that personal phone calls on the Borough's cellular phones should be identified and the individuals who made such calls should pay for those charges. As to Young, his usage continued to exceed the number of allowable minutes, thereby requiring the Borough Administrator to obtain cellular plans for Young with an increased number of minutes. Finally, the plan for Young had to be increased to a national unlimited plan due to the volume and cost of Young's phone usage. The added cost that Young incurred due to excessive usage between August 2001 and March 2005 totaled $2,250.31. Young estimated that his personal use of the Borough's cellular telephone was $20 per month and reimbursed the Borough $367.14. Even if one were to assume the accuracy of Young's estimate, he should have reimbursed $860 to the Borough. Although Council was aware of Young's telephone usage, no action was taken to limit Young's cellular telephone use. Using Young's estimate as a basis and crediting the payment of $367.84, Young would still owe the Borough at least $492.16 for the personal use of the Borough cellular telephone. The next factual scenario relates to Young's use of Borough computers, employees and equipment for personal use. Young, as Borough Mayor, has utilized Borough equipment, supplies and employees in furtherance of his private business interests. In particular, he used the Borough offices to transact his private real estate consulting /sales business. Since March 2002, Young had been in the possession of a Borough lap top computer that he used for two years for his private business dealings until he spilled liquid on the keyboard and damaged the unit. Young then received a Borough desk top computer and utilized that computer for his private business interests. From October 2002, Young utilized Michelle Kenney, a Police Department employee to type drafts of letters and correspondence for his private business interests. Such work was performed by Kenney during regular work hours as well as on lunch hours and breaks. Young used the stationary with the letterhead of the Borough Mayor's office in conducting his personal business. Files obtained from the hard drive of the Borough computers used by Young reflect matters relating to his private business interests or real estate /development clients. Such files confirm the use by Young of Borough equipment for private business purposes. The computer also contained files that relate to Young's Allegheny County Rentals business connection. During the period of 1992 through 2004, Young did not have any private office in maintaining his business relationship with Allegheny County Rentals. Instead, Young utilized his Borough office, equipment and Young, 04 -021 Page 19 employees for such private business interests. Young also used the Borough computer for files as to properties that he was attempting to secure clients for his private business interests. In addition, Young utilized the Borough computer for documents related to Deliverance, Inc., an entity with which he was involved in private real estate ventures. In another instance, Young was involved in a real estate transaction with David Bradbury, who was delinquent in paying his property taxes in the Borough. Since Young was interested in obtaining some of Bradbury's properties, he and Bradbury entered into an agreement to transfer certain properties to Young. Bradbury agreed to transfer the properties to Young with the proviso that he (Bradbury) would not have to pay any costs associated with the transfers or taxes. The transfer involved five properties by Bradbury. See, Fact Finding 72(c). Young utilized the Police Department Office Manager to notarize the documents for the transfer of the five properties that had a total market value of $67,600. The files relating to the David Bradbury transactions were also on the Borough computers. In another matter, Young used the Borough cellular telephones, Borough line phones and computers in furtherance of a private business relationship with R.E. Crawford Construction Company, from which Young received a $1,000 payment per month as a consultant from October through December of 2003. Lastly, Young maintained other files on the Borough computers relating to property sales and real estate developments in which Young had financial interests. The last factual scenario involves Young's failure to disclose sources of income and offices, directorships or employment in business entities on his SFIs. Young filed SFIs as Borough Mayor for the calendar years 2002 through 2004. The details of Young's disclosures on his SFI filings for the calendar years 2002 through 2004 are delineated in Fact Finding 86. For the 2002 calendar year, Young failed to disclose income from NEMO Investments from which he received payments of approximately $20,000 for real estate services. For the 2003 calendar year, Young failed to disclose sources of income in excess of $1,300 from R.E. Crawford, Allegheny County Rentals, NEMO Investments, and PRC Commercial. Finally, Young failed to disclose his office, directorship or employment in the following businesses: in 2002, 827 Partnership, Housing Development Partnership and NEMO Investments; and in 2003, Housing Development Partnership and NEMO Investments. Having highlighted the Stipulated Findings and issues before us, we shall now apply the Ethics Act to determine the proper disposition of this case. The parties' Consent Agreement sets forth a proposed resolution of the allegations: "3. The Investigative Division will recommend the following in relation to the above allegations: a. That an unintentional violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a) occurred when Young utilized a borough cellular telephone to make personal telephone calls; b. That no violation of Section 1105(a) [sic] of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1105(a) [sic] occurred relating to Young's acquisition of a borough cellular telephone as council Young, 04 -021 Page 20 approved the acquisition of such equipment for use by borough officials. c. That no violations of Section 1103(a) [sic] of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a) occurred when Young obtained property from a borough resident to satisfy a delinquent property tax bill and subsequently converted the property to 827 Partnership, a business with which he is associated based on an insufficiency of evidence that Young obtained any private pecuniary benefit. d. That a violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a) occurred when Young used borough equipment, facilities and personnel in support of his private business activities; e. That an unintentional violation of Section 1105(b)(5)(8) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1105(b)(5)(8) occurred in relation to Young's failure to disclose sources of income and offices, directorships or employment in businesses, on Statements of Financial Interests filed for the 2002 and 2003 calendar years. 4. Young agrees to make payment in the amount of $4,000 in settlement of this matter payable to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter. Said amount to be completed over a two year period with payments being made in equal amounts of $166.66 every month for twgnty- three months and one final payment of $166.82 to be paid on or before the 15 day of each month consecutively." Consent Agreement, 1[3, ¶4. Applying Section 1103(a) of the Ethics Act to the allegation concerning the transfer of realty that was subject to delinquent property tax, there were uses of authority of office on the part of Young. The Middlemisses, the owners of the property, approached Young as Mayor for assistance with their property. Young saw the situation as an opportunity for financial gain as to his private real estate business endeavors. But for the fact that Young was Mayor, he could not have misled the Middlemisses into believing that he could transfer the property to a Borough employee, or misstated the circumstances surrounding the consideration for the transfer. Young was also evasive or non - responsive when the Middlemisses learned that their names had not been removed as to the listing of that property. Young initially had the property transferred to the 827 Partnership, one of his paper companies, without informing the Middlemisses. Ultimately, the property was transferred by Young to the Allegheny County Rentals, a business with which Young had a business relationship. Although the Fact Findings of record reflect uses of authority of office on the part of Young, there is no showing that such uses of authority of office resulted in a private pecuniary benefit to him. The relationship that Young had with the Allegheny County Rentals involved Young assisting that business in obtaining various properties for purchase. However, there does not appear to be any correlation between the payments that he received and houses that he was instrumental in obtaining for Allegheny County Rentals. Rather, Young received a set amount of money for performing his consulting services to Allegheny County Rentals. Accordingly, there is no showing that a private pecuniary benefit resulted as to the use of the authority of office by Young. Without that resultant private pecuniary benefit, there can be no violation of Section 1103(a) of the Young, 04 -021 Page 21 Ethics Act. See, Wagner, Order 1028. Hence, Young did not violate Section 1103(a) of the Ethics Act when he obtained from a Borough resident property that was subject to delinquent property taxes and transferred that property to 827 Partnership, a business with which he was associated, based upon an insufficiency of evidence that Young obtained a private pecuniary benefit. Turning to the issues of the acquisition and use of the Borough cellular phone for private business purposes, the Fact Findings reflect that Young was not involved in the purchase of the Borough cellular telephone that he used. It appears that the purchase of the cellular telephone and accompanying service was effectuated by the Borough administrator. The Borough's cell phone was then provided to Young for official use in his capacity as Mayor. There was no use of authority of office on the part of Young as to the purchase of the Borough cell phone because it was purchased by the Borough administrator. Without a use of authority of office, there can be no violation of the Ethics Act. See, McGuire & Marchitello v. SEC, 657 A.2d 1346 (Pa. Commw. 1995). Accordingly, Young did not violate Section 1103(a) of the Ethics Act regarding the acquisition of a Borough cellular telephone for official use in that the acquisition of that equipment was made by the Borough through its administrator. As to the use of the Borough's cell phone, since the Borough cell phone was Borough property for official use, the actions of Young in using the cell phone for his private business dealings were uses of authority of office. See, Juliante, Order 809. By virtue of being the Borough Mayor, Young was in a position to use the Borough cell phone for his private business activities. The uses of authority of office on the part of Young resulted in pecuniary benefits to him. By having the Borough pay the bills for his private business cell phone calls, he did not have any out -of- pocket expenses. Further, the pecuniary benefit that Young received was a private pecuniary benefit in that there is no provision in the Borough Code that allows a public official to use municipal paid equipment for private business purposes. In addition, it was Borough policy that individuals who used Borough cell phones to make personal calls had to reimburse the Borough for the cost of such calls. Accordingly, Young unintentionally violated Section 1103(a) of the Ethics Act when he made personal telephone calls on a Borough cellular telephone assigned to him for official Borough business. See, Bryant, Order 1367. Regarding the issue of the use of Borough equipment facilities and personnel, the Fact Findings are replete with instances where Young used a Police Department employee to do typing for him as to his private business dealings. In addition, Young used the Borough offices as a contact point where he could conduct his private business dealings. Further, Young, in conducting his private business, utilized both a lap top and a desk top computer of the Borough for private business purposes. These activities are established by the Police Department employee, the Borough stationary with the Borough Mayor office letterhead, and the computer files that contain documents or spreadsheets relating to Young's private business activities. The decisions by this Commission are legion that public officials /public employees may not use government offices, equipment, personnel, facilities or supplies for campaign, re- election or business activities. Governmental offices, staff, supplies and equipment are to be used for governmental purposes. See, Rockefeller, Order 1104. See also, Friend, Order 800; Fiorello, Order 1363. Accordingly, Young violated Section 1103(a) of the Ethics Act when he used Borough equipment, facilities and personnel in support of his private business dealings. As to the SFI allegations concerning Young's filings for the calendar years 2002 and 2003, the Findings reflect that Young failed to list NEMO Investments as a source of income on his 2002 calendar year SFI and R.E. Crawford, Allegheny County Rentals, NEMO Investments and PRC Commercial as sources of income on his 2003 calendar year SFI. Young, 04 -021 Page 22 In addition, Young failed to list as an office, directorship or employment in a business entity for his 2002 SFI: 827 Partnership, Housing Development Partnership and NEMO Investments. For the 2003 calendar year SFI, he failed to list Housing Development Partnership and NEMO Investments under office, directorship or employment in any business entity. Young unintentionally violated Section 1105(b)(5) and (8) of the Ethics Act when he failed to list the above entities as sources of income and his office, directorship or employment in those business entities for the 2002 and 2003 calendar year SFIs. See, Hoover, Order 1348. If Young has not already done so, he is directed within thirty (30) days of the date of mailing of this Order to file amended SFIs with the Borough of Wilkinsburg with copies forwarded to this Commission for compliance verification purposes, correcting the above deficiencies. Failure to comply will result in the institution of an Order enforcement action. We determine that the Consent Agreement submitted by the parties sets forth the proper disposition for this case, based upon our review as reflected in the above analysis and the totality of the facts and circumstances. Accordingly, Young is directed to make payment in the amount of $4,000 in settlement of this matter payable to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State Ethics Commission. Said amount to be completed over a two year period with payments being made in equal amounts of $166.66 every month for twenty -three months and one final payment of $166.82 to be paid on or before the 15 day of each month consecutively. Compliance with the foregoing will result in the closing of this case with no further action by this Commission. Noncompliance will result in the institution of an order enforcement action. In reviewing this case, it is clear to us that Young used public office for personal financial gain. As the Preamble to the Ethics Act states in part, public office is a public trust. Young violated that public trust when he used his position as Mayor to carry on his private business activities. In his future conduct as Mayor, Young is reminded that the Ethics Act prohibits the use of public office for personal financial gain. Young must ensure that he follows both the letter and spirit of the Ethics Act in his future conduct. IV. CONCLUSIONS OF LAW: 1. Wilbert Young, as Mayor of the City of Wilkinsburg, Allegheny County, is a public official subject to the provisions of Act 9 of 1989 as codified by Act 93 of 1998. 2. Young unintentionally violated Section 1103(a) when he utilized a borough cellular telephone to make personal telephone calls. 3. Young did not violate Section 1103(a) of the Ethics Act when he obtained from a Borough resident property that was subject to delinquent property taxes and transferred that property to 827 Partnership, a business with which he was associated, based upon an insufficiency of evidence that Young obtained a private pecuniary benefit. 4. Young did not violate Section 1103(a) of the Ethics Act regarding the acquisition of a Borough cellular telephone for official use in that the acquisition of that equipment was made by the Borough through its administrator. 5. Young violated Section 1103(a) when he used borough equipment, facilities and personnel in support of his private business activities. 6. Young unintentionally violated Section 1105(b)(5) and (8) when he failed to disclose sources of income and offices, directorships or employment in businesses, Young, 04 -021 Page 23 on Statements of Financial Interests filed for the 2002 and 2003 calendar years. In Re: Wilbert Young ORDER NO. 1378 File Docket: 04 -021 Date Decided: 9/12/05 Date Mailed: 9/21/05 1 Wilbert Young (Young), as Mayor of the City of Wilkinsburg, Allegheny County, unintentionally violated Section 1103(a) when he utilized a borough cellular telephone to make personal telephone calls. 2. Young did not violate Section 1103(a) of the Ethics Act when he obtained from a Borough resident property that was subject to delinquent property taxes and transferred that property to 827 Partnership, a business with which he was associated, based upon an insufficiency of evidence that Young obtained a private pecuniary benefit. 3. Young did not violate Section 1103(a) of the Ethics Act regarding the acquisition of a Borough cellular telephone for official use in that the acquisition of that equipment was made by the Borough through its administrator. 4. Young violated Section 1103(a) when he used borough equipment, facilities and personnel in support of his private business activities. 5. Young unintentionally violated Section 1105(b)(5) and (8) when he failed to disclose sources of income and offices, directorships or employment in businesses, on Statements of Financial Interests filed for the 2002 and 2003 calendar years. 6. Per the Consent Agreement of the parties, Young is directed to make payment in the amount of $4,000 in settlement of this matter payable to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State Ethics Commission. Said amount to be completed over a two year period with payments being made in equal amounts of $166.66 every month for twenty -three months and one final payment of $166.82 to be paid on or before the 15 day of each month consecutively: a. Compliance with the foregoing will result in the closing of this case with no further action by this Commission. b. Non - compliance will result in the institution of an order enforcement action. BY THE COMMISSION, Louis W. Fryman, Chair