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HomeMy WebLinkAbout1417 RemboldIn Re: Charles Rembold, Respondent File Docket: X -ref: Date Decided: Date Mailed: Before: Louis W. Fryman, Chair John J. Bolger, Vice Chair Donald M. McCurdy Paul M. Henry Raquel K. Bergen Nicholas A. Colafella 05 -006 Order No. 1417 10/4/2006 10/20/2006 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 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 filed and a hearing was waived. The record is complete. 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 Effective December 15, 1998, Act 9 of 1989 was repealed and replaced by Chapter 11 of Act 93 of 1998, 65 Pa.C.S. § 1101 et seq., which essentially repeats Act 9 of 1989 and provides for the completion of pending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. Rembold, 05 -006 Page 2 I. ALLEGATION: That Charles Rembold, a (public official /public employee) in his capacity as a Member of the Greene County Industrial Development Authority (GCIDA) Board of Directors, violated Sections 1103(a),(c) ,(f); 1104(a); and 1105(b)(4),(5) provisions of the State Ethics Act (Act 93 of 1998), 65 Pa. .S. § §1103(a),(c),(f); 1104(a); and 1105(b)(4),(5) when he used the authority of his office for a private pecuniary gain of himself and /or a business with which he is associated by participating in discussions, decisions and other actions of the board and /or the GCIDA including making recommendations resulting in a contract being awarded to Prosocial Solutions when he had a reasonable expectation that he would receive payments from Prosocial; and when he made recommendations to award a contract to Prosocial based on his understanding that he would solicit, accept, or receive a portion of any funds paid to Prosocial by the GCIDA; when he used the authority of his position as GCIDA member to take possession of computer equipment from the GCIDA for his personal use; when he participated in discussions and decisions of the GCIDA to award a contract in excess of $500.00 to his son Brian Rembold for the development of a website for Evergreene Technology without an open and public process; when he failed to file a Statement of Financial Interests for the 2003 calendar year by May 1, 2004; when he failed to disclose sources of income and creditors on Statements of Financial Interests filed for the 2002 and 2004 calendar years; and when as Superintendent of the Jefferson - Morgan School District he used school district equipment, facilities, material, and time to further his outside business interests, including but not limited to, acting as a compensated instructor for an on -line university; and when he failed to disclose creditors on Statements of Financial Interests filed for the 2002, 2003, and 2004 calendar years and failed to disclose sources of income on the Statements of Financial Interests filed for the 2004 calendar years; and when he backdated a Statement of Financial Interests filed for the 2000 calendar year giving the impression that it had been timely filed. II. FINDINGS: 1. Charles P. Rembold served as a member of the Greene County Industrial Development Authority (hereafter IDA) Board of Directors from July 3, 1996 through June 30, 2004. a. Rembold served as the President of the IDA from December 12, 1996 to June 16, 2004. b. As a Member of the IDA, Rembold was a public official subject to the provisions of the Ethics Law. 2. Rembold resigned from the IDA effective June 30, 2004. a. The county commissioners recommended Rembold's resignation due to negative publicity Rembold received from his previous violations of the Ethics Act documented in State Ethics Commission Order No. 1303. 3. The IDA concentrates on economic development within Greene County with a focus on the creation, attraction and retention of businesses. a. The IDA offers financial assistance through bond issues, Pennsylvania Industrial Development Authority (PIDA) loans, Machinery and Equipment Loan Financing (MELF), conventional financing, bridge financing, etc. b. The IDA office offers grant writing, business plan development, and training programs for Greene County businesses. 4. A five - member board of directors governs the IDA. Rembold, 05 -006 Page 3 a. IDA board members are appointed to five -year terms by the Greene County Commissioners. 5. As a member of the IDA board, Rembold advocated the pursuit of available grants for which the IDA would serve as the fiscal agent /administrator. a. Rembold actively researched and participated in the application process for various grants applied for by the IDA. b. Rembold was familiar with grant writing through his previous experience in writing grants in his positions as superintendent for West Greene or Jefferson Morgan School Districts. 6. Rembold informed IDA board members and representatives at regular IDA board meetings of various grants applied for and received. a. Grants applied for were not consistently discussed or approved by the IDA board prior to submission of the application. b. IDA board members first knowledge of grants received often occurred when Rembold or other IDA representatives informed them of the receipt of the grant. c. Rembold occasionally presented the information to the board due to his position as board president and due to his involvement with grant pursuit. 7 The 21 Century Community Learning Centers Program (hereafter 21 CCLC) was established by Congress to award grants to rural and inner -city public schools or consortia of such schools. a. The 21 CCLC Program is designed to provide opportunities to students for academic enrichment during non - school hours or periods when school is not in session (before school, after school, and during the summer). b. 21 CCLCs offer students a broad array of additional services, programs, and activities designed to reinforce and complement the regular academic program of the participating students. 8. In Greene County, the 21 CCLC Program is an educational partnership coalition of Community Learning Centers that provides educational, health, social services, cultural, and recreational opportunities for students to achieve success. a. A minimum of thirteen Community Learning Centers are operational in Greene County including two sites in West Greene School District, three sites in Central Greene School District, two sites in Jefferson Morgan School District, one site in Carmichaels School District, two sites in Southeast Greene School District, and the main CCLC office located in Waynesburg. b. Each site has a committee of students, parents, teachers, administrators, community members, and a Site Coordinator who provides support, input, and direction for the program. 9. Linda P. McCracken is the Director of the 21 CCLC Program for Greene County. a. McCracken is considered a consultant with the Greene County Career and Technology Center (formerly the Greene County Area Vocational Technical Rembold, 05 -006 Page 4 School) in her Director's position. b. 21 CCLC grants utilized by the 21 CCLC are administered through the Greene County Career and Technology Center. 10. McCracken reports to the Greene County Education Consortium (hereafter Education Consortium) in her position as Director of the 21 CCLC program. a. The Education Consortium is composed of the superintendent of each of the five school districts in Greene County (West Greene, Central Greene, Jefferson Morgan, Carmichaels, and Southeast Greene) and the Director of the Greene County Career and Technology Center. 1. Rembold served as a member of the Education Consortium from at least October 1995 through May 2005. 11. The 21 CCLC program and the Education Consortium work in collaboration with the IDA. a. The 21 CCLC and the Education Consortium pursue various grants for program funding. 1. Grants pursued through the IDA are typically written by McCracken or an IDA representative. 12. In or about 2002, the IDA, in conjunction with the 21 CCLC, the Education Consortium, the Greene County Technology Consortium, PBS Literacy Link, and the Childcare Program of Greene County, pursued grant funds through the United States Department of Education for the development of three Community Technology Centers to be located at the Carmichaels Area Jr /Sr HS, Jefferson - Morgan Jr /Sr HS, and Waynesburg Central HS. a. Community Technology Centers provide computer access and educational services using information technology. 13. Rembold, in his capacity as the President of the IDA, submitted an application to the United States Department of Education on or about June 30, 2002 for the Greene County Community Technology Center Program. a. The application documents Rembold as the Project Director. b. Rembold's signature is documented as the authorized representative of the applicant. c. The proposed project dates were October 1, 2002 through September 30, 2003. 14. McCracken assisted Rembold with the development of the 2002 Comm -Tech application submitted to the United States Department of Education. a. McCracken was involved in the application due to the fact that the Community Technology Centers were to be located at 21 CCLC sites already established. b. McCracken was primarily involved in writing the section of the application narrative dealing with academic achievement of high school students. Rembold, 05 -006 Page 5 c. Rembold was primarily responsible for developing the budget associated with the grant. 15. The application requested $300,000.00 in federal funding (along with $281,000.00 provided by the IDA) to be utilized for personnel, fringe benefits, equipment, supplies, contractual obligations, and other expenses in association with the proposed Community Technology Centers. a. Included in the "Personnel" category was the establishment of a Comm -Tech Project Director with an annual salary of $50,000.00. 1. Attachment 1 to the application included a job description for the Comm -Tech Project Director. 2. Attachment 2 to the application noted Bryan [sic] Rembold, Rembold's son, as the proposed Comm -Tech Project Director and included Bryan [sic] Rembold's resume. b. Included in the "Contractual" category was the allocation of $30,000.00 to an outside consultant to be commissioned to assist with the program evaluation. 1. The identity of the outside consultant was not noted in the application. 16. Rembold received correspondence dated September 30, 2002 from Cheryl Keenan, Division Director, United States Department of Education, Office of Vocational and Adult Education that the application was not recommended for funding. 17. Rembold, as the President of the IDA, submitted a second application to the United States Department of Education on or about July 4, 2003 for the Greene County Community Technology Center Program. a. The application documents Rembold as the Project Director. b. Rembold's name is documented as the authorized representative of the applicant. c. The proposed project dates were October 1, 2003 through September 30, 2004. d. The application noted the desire to develop a Community Technology Center in each of the five school districts in Greene County (Carmichaels School District, Central Greene School District, Jefferson - Morgan School District, Southeastern School District, and West Greene School District). 18. McCracken and Bertrum Menhart, IDA Director of Special Projects, assisted Rembold with the development of the 2003 Comm -Tech application submitted to the United States Department of Education. a. McCracken was involved in the application due to the fact that the Community Technology Centers were to be located in 21 CCLCs already established. b. Menhart assisted Rembold with the budget. 19. The application requested $497,000.00 in federal funding (along with $350,000.00 provided by the IDA and $883,000.00 in local funding) to be utilized for personnel, fringe benefits, travel, equipment, supplies, contractual obligations, training Rembold, 05 -006 Page 6 stipends, and other expenses in association with the proposed Community Technology Centers. a. Included in the "Personnel" category was the establishment of a Comm -Tech Project Director with an annual salary of $55,000.00. 1. Included with the application was Bryan [sic] Rembold's resume for the Comm -Tech Project Director Position. 2. Bryan [sic] Rembold is Charles Rembold's son. b. Included in the "Contractual" category was the allocation of $30,000.00 to an outside consultant to be commissioned to assist with the program evaluation. 1. The identity of the outside consultant was not noted in the application. 20. The IDA was denied funding by the United States Department of Education, Office of Vocational and Adult Education regarding the application submitted in 2003. 21. The Richard King Mellon Foundation (hereafter Mellon Foundation) is an entity that provides grant funding primarily over a ten to twelve county area in Southwestern Pennsylvania. 22. Scott Izzo was employed as an Associate Director with the Mellon Foundation from approximately mid -2001 through mid -2005. a. Izzo's responsibilities included project assessment and determination if grant funding was appropriate for projects under consideration. 23. The IDA submitted a proposal /request to the Mellon Foundation in January 2003 regarding the project. 24. On April 4, 2003, Chappel and Menhart met with Izzo at Izzo's office in Pittsburgh, Pa, regarding funding in support of the after school programs, the evening classes, and the childcare program associated with the 21 CCLC and the proposed Community Technology Centers. 25. The Mellon Foundation subsequently issued the IDA a $500,000.00 grant in May 2003 under their Regional Economic Development program. a. The grant was issued towards two years of support for newly established childcare centers and after - school tutoring programs in Greene County. 26. Subsequent to the presentation by Chappel and Menhart, Izzo contacted James Denova of the Claude Worthington Benedum Foundation and inquired if Denova was interested in assisting with funding for the project. a. Izzo felt that Denova may be interested in the workforce development aspect of the Comm -Tech project. 27. The Claude Worthington Benedum Foundation (hereafter Benedum Foundation) is an entity that serves the general well being of the citizenry of West Virginia and Southwestern Pennsylvania (specifically Allegheny, Fayette, Washington, and Greene Counties). a. Program categories for funding include education, workforce development, economic development, health and human services, and community Rembold, 05 -006 Page 7 development. b. The Benedum Foundation typically awards approximately fifteen million dollars per year in grants. 28. Denova is employed as a Senior Program Officer for the Benedum Foundation. a. Denova's responsibilities include investigating projects for funding and making recommendations to the Benedum Foundation Board. 29. In approximately mid -2003, Denova contacted the IDA and requested a meeting in order to discuss the possibility of funding the Community Technology Centers. a. The meeting occurred on July 10, 2003 at the IDA office in Waynesburg, Pa. 30. Attending the meeting and participating in the discussion were Rembold, McCracken, Don Chappel (IDA Executive Director), and Bertrum Menhart (IDA Director of Special Projects). a. Rembold supplied Denova with a copy of the Comm -Tech Grant application previously submitted to the U.S. Department of Education for review at the meeting. 1. Included was the $30,000 contract allocation for program evaluation. 31. On or about October 3, 2003, Denova again met with IDA representatives including Rembold to further discuss a grant from the Benedum Foundation to fund the Community Technology Centers. a. Denova informed those in attendance that funding was available and that he wished to fund a project for the IDA. 1. Denova did not know the exact amount of funding available at that time. b. The purpose of the meeting was to establish parameters for the grant which would permit funding to the IDA from the Benedum Foundation. c. Individuals present and participating in the meeting included Rembold, Menhart, and McCracken. 32. After the October 3, 2003 meeting, Denova interacted primarily with McCracken regarding the establishment of goals and objectives for the grant funding. 33. Rembold, McCracken, and Menhart were aware of funding parameters provided by Denova as early as October 21, 2003. a. E -mail communication between McCracken and Denova dated October 23, 2003 documents the following, "Chuck, Bert, and I met on Tuesday to review the Commtech grant as submitted to the federal government for funding and how it could be revised to fit into the money parameters you provided to us. 34. On November 3, 2003, an agenda setting meeting was held by the Benedum Foundation Board of Trustees. a. The purpose of the meeting was to set the agenda for the regular board Rembold, 05 -006 Page 8 meeting to be held on December 9, 2003. b. Included with the agenda was the specific amount of Benedum Foundation funding to be provided to the IDA as determined by Denova. c. Denova completed an Agenda Planning Worksheet at the November 3, 2003 meeting which documented the IDA requested amount of $497,000.00 and the Benedum Foundation proposed amount of $260,000.00. 1. The IDA requested amount was taken directly from the 2003 Comm - Tech application provided to Denova by Rembold. d. Denova specified the amount of proposed funding to McCracken on or about November 3, 2003. 35. On December 3, 2003, McCracken sent e -mail communication to Denova inquiring if Denova required any additional information from Rembold, Menhart or her regarding the proposed grant. a. The e -mail indicated that Rembold, Menhart, and McCracken were excited about the prospects of working with Denova. 36. Denova responded to McCracken's communication via e-mail dated December 4, 2003. a. Denova responded that the Benedum Foundation trustees would be meeting on December 9, 2003 to approve grants. b. Denova indicated that he did not anticipate a problem with the grant. 37. At the December 9, 2003, meeting of the Benedum Foundation Board of Trustees, Denova presented the trustees with a program staff write -up that summarized the details of the IDA project for funding of $260,000. a. The document prepared by Denova included information provided by the IDA. 38. Documented in the program staff write -up, along with additional information, is the following: The inspiration and direction of the COMM -TEC model came from Dr. Charles Rembold, superintendent of the Jefferson - Morgan School District, Chair of the Technology and Education Consortium and current Chair of the Industrial Development Authority. Dr. Rembold led prior initiatives on behalf of the Consortium including a distance learning network that allows Waynesburg faculty to provide direct instruction to all five high schools in the County." 39. The program staff write -up presented by Denova included funding for an evaluation of the program in the amount of $30,000.00. a. An evaluation by an outside consultant was part of the original Comm -Tech grant application provided by Rembold to Denova as a reference. b. Denova included the evaluation component in the Benedum Grant because he felt it was important for an evaluation to be completed. Rembold, 05 -006 Page 9 c. Denova did not change the evaluation amount from that listed on the original Comm -Tech grant. 40. Minutes of the December 9, 2003 Benedum Foundation Board of Trustees note the approval of a $260,000.00 grant to the IDA as part of the Southwestern Pennsylvania Grants Program. a. The purpose of the grant was noted as development of five Community Technology Education Centers for workforce training. 41. On December 10, 2003, McCracken contacted Denova via e-mail and inquired as to the status of the grant proposal. a. Denova responded via e-mail on December 11, 2003 that the grant was approved for $260,000.00 and that a letter of agreement would be arriving soon. 42. Prosocial Solutions Research (hereafter Prosocial) is a consulting business owned and operated by Stephen Ellsworth. a. Prosocial provides services in grant acquisition and project implementation, management, and evaluation among other services. b. Ellsworth operates the business from his home residence in Virginia. c. As of August 2006, Ellsworth was a Colonel in the U.S. Army stationed at Fort Lee, VA. 43. Rembold and Ellsworth maintained a social and professional relationship. a. Rembold and Ellsworth met at the Indiana University, Bloomington, Indiana, while performing doctorial work in the summer of 1998. b. Ellsworth ultimately developed the Plus Three Program which was provided to King's Bridge, Inc. for utilization in PULSE (People Utilizing Leadership Skills Effectively), a program for assisting, at risk youth. 1. Rembold was one of the originators of King's Bridge, Inc. and was an originator of PULSE Program. c. Ellsworth performed compensated services as a facilitator at various PULSE programs where Rembold also served as a facilitator. 44. Prosocial /Ellsworth knew as early as July 2003 that Prosocial would be utilized by Rembold as the evaluator of future grants. a. E -mails between Ellsworth and Linda - McCracken confirm discussions regarding grants and PULSE Programs. 45. Rembold and McCracken met and discussed the $30,000.00 allocation for the outside evaluation between the approximate dates of November 3, 2003 and December 12, 2003. a. Rembold devised a scheme where Prosocial would be utilized as the outside consultant for the Benedum grant and paid by the IDA where Rembold served as board president. Rembold, 05 -006 Page 10 1 Rembold informed McCracken that Prosocial, the consulting business owned by his friend and colleague, would be the grant evaluator. aa. McCracken was familiar with Ellsworth through Ellsworth's association with the PULSE Program. b. Part of the funds paid by the IDA to Prosocial would be kick backed to Rembold. c. Rembold directed that the $30,000.00 established for the evaluation be divided between himself, McCracken, and Ellsworth. 1. A lesser amount was to be provided to R. Edgar Thacker, an associate of Rembold's in Kings Bridge. 46. Ellsworth was provided information from McCracken that Prosocial would be the evaluator for the project and was provided direction on how the evaluation was to be completed. a. E -mail communication from McCracken to Ellsworth detailed results of a conversation held between Rembold, McCracken, and Menhart as follows: 1. Rembold directed McCracken to give Ellsworth a copy of their last Community Technology Center Grant, a copy of the Community Technology Center guidelines, and the information in the contract with the Benedum so that a "blue ribbon" award Community Technology Center Grant could be submitted in the summer of 2004. 2. Rembold and Menhart wanted the evaluation to be done quarterly (four months, eight months, twelve months, and sixteen months) and to be formative and summative. aa. McCracken noted in the e -mail that this would be Ellsworth's decision. 3. Rembold wanted the evaluation to measure affective results as well as just data collection. 4. The total for the evaluation would be $30,000.00 and divided into five payments, $6,000.00 to begin for planning, design, etc., and then $6,000.00 at each quarter following the quarterly report. aa. Ellsworth was to invoice the IDA directly for services performed. 47. Subsequent to McCracken's meeting with Rembold, in or around November 2003, McCracken conveyed to Ellsworth at Rembold's direction specific instructions regarding the division of funds. a. E -mail correspondence from Ellsworth to McCracken dated December 12, 2003 notes, among other information, "I need to understand how Chuck wants the $30K divided again, just to be sure." 48. Rembold met with McCracken on December 12, 2003 and explained to her how the $30,000 evaluation fee would be divided among Rembold, McCracken, and Ellsworth. 49. McCracken then responded to Ellsworth's message via e -mail communication on Rembold, 05 -006 Page 11 December 12, 2003, which documented the following: "Chuck just spent several minutes trying to explain to me on how he wants this done -the money thing -I will try to do this the best I can; you may still have to have him explain it to you. He asked if you understood the big picture —for all of us to make money -now and in the future? He wanted to know if you understood that he needed money to help pay his legal fees? OK, here I go. The $30,000 will be divided by 3 (you, me, and him) which equals $10,000 per person. $1,000 from each of us will go to Prosocial for administrative costs and taxes. Taxes: 15% of profit. Costs are 80% deductible (with detailed records). 80% of $30,000 = $24,000 as costs. $6,000 as profit for Prosocial. 15% Taxes for Corporate which is .15 x 6000 = $900 corporate taxes on $30,000. $3000 -$900 = $2100 as profit for Prosocial. Then a new wrinkle; he wants you to pay ET $1500 for consultant services which would leave $600 in Prosocial. I asked why ET; he said two things, one he owes ET some money and and secondly it gives ET a legit reason (Brenda) to meet and work with us. He said that all three of us need to keep /document all expenses -when you come here, when we go see you, etc. He says this is only a beginning; as we are successful with future grants you will always be the evaluator. hope I have explained it clearly enough. Can you live with this? Oh, he wants us to be paid in cash. It doesn't make a difference to me how you pay me if some other way works out for you. Tell me what you think." a. "ET" is Rile Edgar Thacker, an associate of Rembold in Kings Bridge Inc. 1. Rembold was found to be in violation of the Ethics Act and fined for using his position as Superintendent of the West Greene School District to obtain grants to fund the PULSE Program and to steer contracts to Kings Bridge Inc. 2. Rembold was a Corporate Officer and Director of Kings Bridge Inc. and received payments from Kings Bridge Inc. for services related to the PULSE Program. b. "Brenda" is Brenda Spratt (Thacker's spouse). 50. Rembold provided McCracken with all of the information in the December 12, 2003 McCracken e -mail communication for ultimate dissemination to Ellsworth. a. Rembold provided McCracken his handwritten notes which formed the basis of the December 12, 2003 e -mail. b. McCracken's e-mail to Ellsworth contained information directly from Rembold's handwritten notes. 1. Handwriting analysis by the Pennsylvania State Police verified that Rembold's handwriting is consistent with the written notes utilized by McCracken to disseminate the information. 51. Ellsworth acknowledged acceptance of and inclusion in the scheme via e-mail response sent to McCracken on December 12, 2003, which documented the following: We will make it work, no problem, but the math is a bit fuzzy, as at this time, one can only estimate. However, it sounds like of the 30,000, I get 12000, and you and Chuck get 9000 each. On top of that, we each divvy up ET's share which will be 500 each, so in reality, I get 11500, and you and Chuck get 8500. My share is larger as I have to bear the cost of the taxes, while Chuck's share is tax -free Rembold, 05 -006 Page 12 essentially as it is under the table. Your share would be taxable. That is how I read this." 52. The legal fees of Rembold referred to in McCracken's e-mail were the result of an Ethics Commission investigation and ruling regarding Rembold's activities as school superintendent in relation to contracts awarded to Kings Bridge and subsequent payments made to Rembold. a. Rembold admitted to violations of the Ethics Act and made a restitution payment to the State Ethics Commission in the amount of $26,397.50 on December 29, 2003 representing the amount that he obtained through his public position in violation of the law. 53. The actual division of funds based upon Rembold's instruction to McCracken was to result in Rembold, McCracken, and Ellsworth each receiving $9,000.00 as shown below: Rembold: $9,000.00 McCracken $9,000.00 Ellsworth: $9,000.00 Thacker: $1,500.00 Prosocial: $ 600.00 Taxes: $ 900.00 Total: $30,000.00 a. The amounts for Thacker, Prosocial, and Taxes were to be paid via $3,000.00 of the $30,000.00 evaluation total. 1. The $3,000.00 resulted from a credit of $1,000.00 each from Rembold, Ellsworth, and McCracken of the original $30,000.00 three - way split. b. Prosocials' profit on the books was $6,000.00 or 20% of $30,000.00 as 80% of the total $30,000.00 could be deducted for tax purposes. c. The amount of taxes was calculated at 15% of the profit to Prosocial. 54. Rembold's solicitation of the $9,000 cash payment from Ellsworth /Prosocial was based upon Rembold's understanding that he would recommend the selection of Prosocial to perform the evaluation for the IDA project. 55. Denova generated a grant agreement letter to Chappel dated December 15, 2003, confirming the authorization of a grant from the Benedum Foundation in the amount of $260,000.00 payable to the IDA to develop five Community Technology Education Centers for workforce training. a. The grant agreement letter indicated that payment of the grant was included with the letter and that endorsement or deposit of the check constituted acceptance by the IDA of all the terms and conditions contained in the agreement letter. b. Chappel signed and returned the grant agreement letter to Denova on or about January 5, 2004. 56. The Benedum Foundation issued the IDA check number 2204, dated December 16, 2003, in the amount of $260,000.00 representative of the grant issued. Rembold, 05 -006 Page 13 a. The check was deposited into an IDA account at First National Bank on January 6, 2004. 57. The receipt of the Benedum Foundation Grant was first presented to the IDA board at the December 18, 2003 regular board meeting. a. Minutes document Rembold's presence at the December 18, 2003 meeting. 58. During the December 18, 2003 presentation of the Benedum Foundation Grant, specific discussion occurred regarding the need to obtain an outside evaluator for the grant. a. Rembold recommended to the IDA board that Prosocial serve as the grant evaluator. 59. After Rembold's recommendation, IDA board member Richard "Skip" Noftzger questioned if any of the board members knew anything about Prosocial. a. Rembold responded that Prosocial had expertise in the area required for the evaluator. b. None of the remaining IDA board members had any knowledge of Prosocial prior to Rembold's recommendation. 60. Noftzger subsequently made a motion, seconded by Board Member Joseph Simatic, to employ Prosocial as the grant evaluator for a fee not to exceed $30,000.00 and to have Prosocial responsible for quarterly reports and the grant closeout. a. The motion passed with no abstention by Rembold. 61. The decision by the IDA Board, in which Rembold participated, to utilize Prosocial was based solely on the recommendations made by Rembold. a. No board members were familiar with or had any knowledge of Prosocial prior to Rembold's recommendation. 62. Rembold's recommendation to select Prosocial as the evaluator was based upon Rembold's understanding that Prosocial would pay $9,000 in cash to him from the funds that Prosocial received from the IDA. 63. Ellsworth /Prosocial did not submit quarterly reports to the IDA as required in the motion to retain Prosocial. a. Ellsworth provided only an Evaluation Framework, an Interim Evaluation (dated November 30, 2004), and a Summative Evaluation (dated August 31, 2005) with abridgements of an IDA narrative added on November 30, 2005. 1. The Evaluation Framework provided background regarding the purpose of the grant issued, the program goal, the method by which the evaluation would be conducted, various models considered for the evaluation, and specific evaluation plan phases regarding the evaluation. 2. The Interim Evaluation provided background on the grant issued by the Benedum Foundation, the program goal, actual figures utilized regarding the goals, and Ellsworth's conclusion that the program initiation was successful, meeting, or was on track in meeting the Invoice No. Invoice Date Amount Description Final Vote April 21, 2004 5634 03/29/04 004 -01 PA 01/12/2004 $6,000.00 Consulting Services: Program Evaluation, Research Model Determination, Set -Up for Quarterly Reports, Data Collection and Program Advisement for First Quarter Project Initiation, Review the USDOE COMM- TEC Grant Proposal. Vitae for Dr. Stephen C. Ellsworth is attached for inclusion in the GCIDA files 07/26/04 NA 4 -0 January 19, 2005 004 -02PA 07/15/2004 $6,000.00 Consulting Services: Program Evaluation, Research Model Determination, Set -Up for Quarterly Reports, Data Collection and Program Advisement for Second Quarter project initiation. May 18, 2005 6732 04/20/05 NA 004 -03PA 12/15/2004 $6,000.00 Consulting Services: Interim Program Evaluation, Research, Data Collection, and Program Advisement for Third Quarter 2004. 005 -02PA 02/10/2005 $6,000.00 Consulting Services: Interim Formative Evaluation 005 -03PA 12/20/2005 $2,000.00 Data treatment, summative project evaluation, consulting and evaluation services completion Meeting Date Check Number Check Date Rembold's Vote Final Vote April 21, 2004 5634 03/29/04 Yes 4 -0* August 18, 2004 6003 07/26/04 NA 4 -0 January 19, 2005 6423 01/04/05 NA 5 -0 May 18, 2005 6732 04/20/05 NA 4 -0 Rembold, 05 -006 Page 14 specified and implied tasks of achieving the desired goals. 3. The Summative Evaluation was an all- encompassing report which included the Evaluation Framework, the Interim Evaluation, and updated data analysis regarding the entire program. 64. The information (i.e. data, figures, etc.) utilized by Ellsworth in compiling the Interim Evaluation and the Summative Evaluation were compiled and provided to Ellsworth by McCracken. a. Rembold was not involved in the organization, analysis, or reporting of any data utilized in the production of the Interim or Summative Evaluation. 65. Ellsworth /Prosocial submitted a total of five invoices totaling $26,000.00 to the IDA requesting payment for services rendered in association with the evaluation for the Comm -Tech project funded by the Benedum Foundation Grant as shown below: 66. Between the dates of March 29, 2004 and April 20, 2005, the IDA approved payment and issued four checks from the IDA general account at Community Bank totaling $24,000.00 to Prosocial as shown below: * Board Member Jerome Bartley was absent from the April 21, 2004 meeting. 67. Rembold participated in voting on April 21, 2004 to approve check number 5634. a. Rembold resigned as an IDA board member on June 30, 2004. 68. The IDA has not yet approved payment for Invoice No. 005- 003PA. 69. Prosocial maintains a checking account with Suntrust Bank in Virginia. All checks Check Number Check Date Deposit Date 5634 03/29/04 04/02/04 6003 07/26/04 07/29/04 6423 01/04/05 01/07/05 6732 04/20/05 04/25/05 Rembold, 05 -006 Page 15 received by Prosocial from the IDA were deposited into Prosocial's account at Suntrust on or about the dates shown below: 70. Ellsworth /Prosocial issued three payments to McCracken totaling $6,000.00 in partial fulfillment of the distribution of the funds, as directed by Rembold. a. Ellsworth provided McCracken a personal check from his checking account in the amount of $2,000.00 on or about April 27, 2004. b. Ellsworth provided McCracken with $1,800.00 in cash on or about July 17, 2004. c. Ellsworth provided McCracken with $2,200.00 in cash on or about September 8, 2004. d. Payments to McCracken were made by Ellsworth following his receipt of payments from the IDA. 71. Prosocial Solutions made two payments to Rile Edgar Thacker from the Prosocial account. a. By check dated January 6, 2005, Ellsworth paid Thacker $753, for the incorporation of a company named Syn- Energy, Inc. 1. Syn- Energy was to be a successor to Kings Bridge, Inc. b. By check dated January 6, 2005, Ellsworth paid Thacker $2,000 for advice on tax return preparation for Prosocial Solutions. 72. Thacker did nothing for the $2,000 other than send Ellsworth some written material and provide limited telephonic tax advice. 73. Ellsworth specifically paid Thacker the $2,000.00, at Rembold's direction and insistence. 74. On December 15, 2004, Thacker had issued check numbers 1435 and 1436 from his personal bank account at Bank of America to Burt Menhart in the amounts of $1,120.00 and $4,000.00 respectively. a. Check number 1435 was issued to Menhart as payment for a personal computer (Dell Service Tag #4BVD761) obtained by Menhart for Thacker through the IDA. 1. The cost of the computer and accessories totaled $1,119.51. 2. The $4,000.00 Thacker paid to Menhart was not related to the computer purchase b. Menhart negotiated both checks received from Thacker at First National Bank on December 20, 2004. Date Cash Deposit 12/1/2003 400.00 12/9/2003 850.00 3/22/2004 1,000.00 4/16/2004 500.00 6/7/2004 1,850.00 6/15/2004 1,500.00 6/25/2004 1,000.00 8/31/2004 1,000.00 9/13/2004 2,000.00 Rembold, 05 -006 Page 16 1 Menhart deposited both checks into Account Number 90037068 along with an IDA payroll check totaling $1,483.57 for an initial deposit of $6,603.57. 2. The deposit slip associated with the transaction notes $2,003.57 removed in cash from the deposit for a total deposit of $4,600.00. c. Rembold's personal account at Community Bank (Account Number 2237933) notes cash deposits of $1,500.00 and $400.00 on December 22, 2004, and December 29, 2004, respectively. (See Finding No. 76[sic]). d. Rembold subsequently contacted Ellsworth via telephone and directed Ellsworth to issue a check to Thacker in the amount of $2,000.00. (See Finding Nos. 71 -72 [sic]). 1. Ellsworth subsequently issued Thacker check number 1011, dated January 6, 2005, in the amount of $2,000.00 from the Prosocial Solutions Research account at SunTrust Bank. 2. The memo section of the check noted "tax prep -PSS" in order to conceal the true purpose of the check. 75. Direct payments made by Ellsworth to Rembold were made in cash at Rembold's request. a. Ellsworth was specifically instructed by Rembold through the December 12, 2003 e -mail communication from McCracken that all payments to Rembold were to be made in cash. b. Rembold concealed any payments made to him by directing that the payments be made in cash. c. Ellsworth acknowledges that the payments to Rembold would be "under the table." 76. Rembold and Beverly Rembold (Rembold's spouse) maintain a joint personal checking account with Community Bank in Carmichaels, Pa, 15320. a. Deposit information from Rembold's account spanning the time frame of December 2003 through June 2005 documents cash deposits into Rembold's account totaling $15,100.00 as shown below: Date Cash Deposit Source 11/16/2004 700.00 12/1/2003 400.00 G.L. Wilson personal check to pay his monthly expenses to Beverly 12/9/2003 850.00 Winnings and leftover cash from 11/19/06 trip to Las Vegas - returned 11/23/03 3/22/2004 1,000.00 Beverly's dad died in February, this is cash that G.L. Wilson had in metal box. This was deposited with his life insurance money on this date. 4/16/2004 500.00 Personal spending money leftover from Las Vegas trip on 4/8/04 6/7/2004 1,850.00 First cash deposit from sale of 18k yg royal blue sapphire 4.76 ct. with .50 ctw diamonds $5500 appraised value: $14,000 Rembold purchased ring on 10/16/02 and sold on 1/04 6/15/2004 1,500.00 Second cash deposit from sale of 18k yg royal blue sapphire 4.76 ct with .50 ctw diamonds $5500 appraised value: $14,000 6/25/2004 1,000.00 Third cash deposit from sale of 18k yg royal blue sapphire 4.76 ct with .50 ctw diamonds $5500 appraised value: $14,000 8/31/2004 1,000.00 Fourth cash deposit from sale of 18k yg royal blue sapphire 4.76 ct with .50 ctw diamonds $5500 appraised value: $14,000 9/13/2004 2,000.00 Sale of 4.39 ct Ceylon white sapphire oval ring in 14k gold $2000 estimated value: $4000 Rembold purchased ring on 2/9/03 and sold on 8/04 9/21/2004 400.00 Personal money from winnings ($860) from Mountaineer Casino, WV on 9/16/04 11/16/2004 700.00 Christmas Club account - withdrawn 10/18/04 $698.91 12/15/2004 2,000.00 From check of G.L. Wilson estate to Beverly Rembold on 12/06/04 in the amount of $15,000 ($13,000 into savings account on 12/7/04 and $2,000 into checking account on 12/15/04 12/22/2004 1,500.00 First cash deposit from sale of Pittsburgh Steeler tickets (9 /11/04 Titans $311.67); (10/25/04 Patriots $305.56); (11/12/04 Redskins $414.46); (12/12/02 Ravens $1044.99) Total $2,076.68 12/29/2004 400.00 Second cash deposit from sale of Pittsburgh Steeler tickets (9/11/04 Titans $311.67); (10/25/04 Patriots $305.56); (11/21/04 Redskins $414.46;) (12/20/02 Ravens $1044.99) Total $2076.68 Total $15,100.00 9/21/2004 400.00 11/16/2004 700.00 12/15/2004 2,000.00 12/22/2004 1,500.00 12/29/2004 400.00 Total $15,100.00 Rembold, 05 -006 Page 17 b. Cash deposits were made to Rembold's account following the issuance of payments to Ellsworth /Prosocial. c. Rembold asserts that the cash deposits delineated above emanated from various sources as follows: Date Cash Deposit Source 6/11/2004 80.00 Bev's babysitting money 7/23/2004 60.00 Bev's babysitting money 1/7/2005 50.00 Personal money deposit 3/4/2005 2,000.00 Sale of 4.25 cts. = 10 cts of garnets set in 14k yg (ring, pendant, and earrings) with .50 tcw of vs -vvs white diamonds perfectly matched gemstones $2000; estimated retain value $3000 Rembold purchased gem stones on 12/05/03; set in spring of 2004 and sold on 01/05. Total $2,190 $2,190 Date Cash Deposit 6/11/2004 80.00 7/23/2004 60.00 1/7/2005 50.00 3/4/2005 2,000.00 Total $2,190 Rembold, 05 -006 Page 18 77. Rembold and Beverly Rembold maintain a joint personal savings account with Community Bank in Carmichaels, Pa, 15320. a. Deposit information from Rembold's account spanning the time frame of December 2003 through July 2005 documents cash deposits into Rembold's account totaling $2,190.00 as shown below: b. Rembold asserts that the cash deposits delineated above emanated from various sources as follows: 78. At least one direct payment by Prosocial to Rembold in accordance with Rembold's solicitation was made as follows: a. Payment of $2,000 in cash on July 24, 2004. b. Payment was made personally by Ellsworth in Charlottesville, Virginia, in the form of twenty, one hundred dollar bills. c. The money was provided to Rembold in a white envelope in Rembold's motel room. d. This money was paid as a result of Rembold's previously delineated solicitation. THE FOLLOWING FINDINGS RELATE TO REMBOLD'S USE OF JEFFERSON - MORGAN SCHOOL DISTRICT EQUIPMENT, FACILITIES, AND TIME TO FURTHER HIS OUTSIDE BUSINESS INTERESTS IN SERVING AS AN INSTRUCTOR FOR AN ON -LINE UNIVERSITY. Rembold, 05 -006 Page 19 79. Rembold was employed as the Superintendent of Jefferson - Morgan School District (hereafter JMSD), Greene County, from August 21, 2001, to August 21, 2005. 80. Included in Rembold's JMSD employment contract was Section 4: Duties of Superintendent which outlined Rembold's specific duties and responsibilities in part as follows: a. The Superintendent agrees to serve as chief administrator of the District and as the chief executive officer of the board. Among his duties and responsibilities, the Superintendent shall organize, supervise, direct and assign teachers, administrative employees and other employees of the District under his supervision; furnish recommendations to the board on all matters having to do with the selection, appointment, assignment, transfer, promotion, organization, reorganization, reduction or termination of personnel employed by the district; suggest rules, regulations and procedures for the efficient and proper operation of the District; and perform all other duties incidental to the office of District Superintendent as set forth in the Code and such other duties as may be prescribed by the Board from time to time. b. The Superintendent shall devote his full time attention, energy, skill and labor to his employment as District Superintendent during the term of this agreement; provided however, that he may undertake consultation work, speaking engagements, writing, lecturing, or other professional duties and obligations as long as the District is informed thereof and does not direct him to discontinue said activities. 81. Additionally included in Rembold's employment contract with JMSD was Section 9: Compensation and Benefits which outlined Rembold's salary, cost of living increases, raises, vacation days, retirement, holidays, personal days, sick leave, etc. a. Rembold was considered to be part of the JMSD administrative staff in his position as superintendent. 1. Rembold's employment contract with JMSD designated Rembold as the district's chief administrator. 82. Rembold was expected to generally be present and available in the district during normal district administrative hours of 7:30am- 3:30pm. a. Rembold routinely worked 7:30am- 3:30pm as the district superintendent. b. As a salaried employee, Rembold was expected to work additional hours as necessary (i.e. attending board meetings, conferences, etc.). 83. Rembold reported to the JMSD nine member Board of Directors in his position as the district superintendent. 84. JMSD maintains and utilizes a policy manual in association with the day -to -day operation of the district. 85. As a district employee and member of the administrative staff, Rembold was subject to the policies set forth in the policy manual. Rembold, 05 -006 Page 20 86. Policy No. 319 of the "Administrative Employees" section of the manual titled "Outside Activities" and adopted by the board on October 21, 2002, mandates, in part, the following: a. Subsection 3 of the policy addresses delegation of responsibility and states, The superintendent or designee shall disseminate guidelines so that administrators may avoid situations in which personal interests, activities, and associations may conflict with the interests of the district." b. Subsection 4 of the policy addresses guidelines provided for the direction of administrators that includes Sub - Subsection 3 which directs administrators, "Do not use school time for outside activities when there is no valid reason to be excused from assigned duties." 87. Policy No. 710 of the "Property" section of the manual titled Use of Facilities by Staff" and adopted by JMSD on February 18, 2003 mandates, in part, the following: a. Subsection 1 of the policy addresses authority and states, The Board establishes that school equipment and facilities may not be used by district staff for personal reasons, either on or off school property, without explicit authorization or administrative permission." 88. JMSD maintains a computer /Internet use policy. a. The computer /Internet use policy is not part of the policy manual. b. The computer /Internet use policy is maintained in the office of the JMSD Technology Coordinator. c. Rembold was aware of the computer /Internet use policy. 89. The JMSD computer /Internet use policy sets forth guidelines and procedures, in part, as follows: a. The policy shall apply to all users - district students, faculty, and staff -of all technological /telecommunications systems which are entered via equipment and access lines located at the JMSD, or who obtain their access privileges through association with the district. b. All use of the district's technological /telecommunications systems are intended to be used for educational purposes and to carry out the legitimate business of the district. 1. Appropriate uses are noted as instruction, independent study, authorized research, and the official work of the offices, departments, recognized student organizations, and agencies of the district. c. Use of the networks for commercial or for - profit purposes is prohibited. d. Use of the networks for non -work or non - school related communications is prohibited. 90. As superintendent of JMSD, Rembold maintained a private office in the administrative offices located in the Jefferson - Morgan Jr /Sr High School building. a. District equipment available to Rembold in his private office during his tenure as superintendent included a Dell Optiplex GX 260 computer (Service Tag Rembold, 05 -006 Page 21 No. 7N4DO21) among other equipment. b. JMSD inventory records note the location of the computer as Rembold's office as of July 23, 2003. 91. The JMSD computer represented under Service Tag No. 7N4DO21 was paid for via JMSD General Fund Check No. 4284 dated November 30, 2002 in the amount of $69,889.99 to Dell Marketing, LP. a. The JMSD computer represented under Service Tag No. 7N4DO21 was one of several computers purchased by JMSD via Check No. 4284. b. The cost of the computer represented by Service Tag Number 7N4DO21 was $1,197.00. 92. The University of Phoenix is a private higher education institution whose mission is to educate working adults to develop the knowledge and skills that will enable them to achieve their professional goals, improve the productivity of their organizations, and provide leadership and service to their communities. a. The University of Phoenix offers continuing education through traditional campus programs and via online programs through the Internet. 93. The University of Phoenix/University of Phoenix Online is a subsidiary of Apollo Group, Inc. a. Apollo Group, Inc., is a managing corporation for several higher education institutions. 94. In or about February 2003, Rembold pursued employment with the University of Phoenix through the Apollo Group as an on -line instructor. 95. Rembold used equipment of the JMSD in furtherance of his employment with the University of Phoenix. a. Rembold used JMSD fax machines to send resumes, transcripts, and superintendent certificates to the University of Phoenix. 96. Rembold provided Apollo Group representatives his resume through facsimile transmission utilizing the JMSD facsimile machine on February 10, 2003 at approximately 11:04 am. a. The facsimile transmission information documented at the top of Rembold's resume documents, "Feb -10 -2003 11:04am from - JEFFERSON MORGAN SCHOOL DISTRICT 724 - 883 - 4942..." b. The facsimile transmission sent to Apollo Group representatives was six pages in length c. February 10, 2003, was a regular school day for JMSD. d. Rembold did not obtain permission from the JMSD Board in accordance with Policy No. 710 to utilize the district facsimile machine for personal use. 97. Rembold subsequently completed a University of Phoenix Faculty Application for the Apollo Group on April 8, 2003. a. The application was an on -line application. Rembold, 05 -006 Page 22 1. Documented in the application was that inquiries of educational institutions regarding transcripts would be made. 98. Rembold faxed Apollo Group representatives three Requests for Transcripts via the JMSD facsimile machine on April 9, 2003 at approximately 11:34am. a. The facsimile transmission information documented at the top of the page documents, "Apr -09 -2003 11:34am from - JEFFERSON MORGAN SCHOOL DISTRICT 724 - 883 - 4942..." b. The facsimile transmission sent to Apollo Group representatives was two pages in length c. April 9, 2003, was a regular school day for JMSD. d. Rembold did not obtain permission from the JMSD Board in accordance with Policy No. 710 to utilize the district facsimile machine for personal use. 99. On or about May 8, 2003 Rembold completed an Outlook Express Proficiency Test for the University of Phoenix. a. The test is required to assure that new employees are capable of using Outlook Express. 1. Proficiency in Outlook Express is necessary in performing the functions of an online professor. b. E -mail dated May 8, 2003 from James Finical, Internet Technical Support Level 11, Resolution Center, University of Phoenix, to Chad Gentry verified Rembold's proficiency in the use of Outlook express. 100. On May 9, 2003 at approximately 1:50 p.m., Rembold faxed Apollo Group representatives correspondence dated July 8, 1993 from the Pennsylvania Department of Education regarding Rembold's eligibility to hold a superintendent position in the Commonwealth of Pennsylvania and Rembold's current Pennsylvania Department of Education Commission as Superintendent of JMSD via the JMSD facsimile machine. a. The facsimile transmission information documented at the top of the page documents, "May -09 -2003 1:50pm from - JEFFERSON MORGAN SCHOOL DISTRICT 724 - 883 - 4942..." b. The facsimile transmission sent to Apollo Group representatives was three pages in length c. May 9, 2003, was a regular school day for JMSD. d. Rembold did not obtain permission from the JMSD Board in accordance with Policy No. 710 to utilize the district facsimile machine for personal use. 101. On May 16, 2003, Rembold was approved to teach classes as an online instructor for the University of Phoenix as shown below: Course /Cluster CLUS- ADM500 ADM -590 ADM -591 Title Administrative Practicum Internship Cluster Administrative Internship Program Administrative Internship Program Date Subject 9/4/2003 Brad's Bio 9/4/2003 Ben, Biography 9/4/2003 Elizabeth Copeland's Bio 9/4/2003 EDA 564: Course Text 9/4/2003 Friday, Sept 5 Assignment 9/5/2003 Scot's Biography 9/5/2003 Frederick's Bio 9/5/2003 BIO- Woodhouse 9/5/2003 Kat's Bio 9/5/2003 Questions For Chuck 9/5/2003 Week One Assignments 9/5/2003 Friday, Sept 5 Assignment 9/8/2003 For All Students: Mini - Lecture 9/8/2003 Mini Lecture - Yearly Format For Change 9/8/2003 Mini Lecture: Motivation 9/9/2003 1st Week Summary 9/9/2003 1st Week Discussion Question Stats Rembold, 05 -006 Page 23 ADM -592 Internship on the Supervisor ADM -590 A/B /C Administrative Internship EDA -599 Practicum in School Administration EDA -532 Human Relations and Organizational Behavior in Education EDA -564 The Role and Functions of the Principal 102. Rembold entered into agreements with the Apollo Group to teach EDA -564, The Role and Functions of the Principal, online for the University of Phoenix under Contract No. 588470 and Contract No. 673393. a. The dates of the class for Contract No. 588470 spanned from September 4, 2003 through October 15, 2003. 1. Contract No. 588470 was Rembold's first contract with the Apollo Group. b. The dates of the class for Contract No. 673393 spanned from January 8, 2004 through February 18, 2004. 103. Rembold routinely utilized the JMSD computer (Service Tag No. 7N4DO21) in his private district office to facilitate his online instruction of EDA -564 during regular district working days and hours. a. Rembold sent and received messages regarding student biographies, course questions, discussion questions, student feedback, grade certifications, etc., from his JMSD district computer. 104. A forensic search of the Hard Drive (Serial No. TH- 02M920- 12567- 266 -0R7W) installed in Rembold's district computer (Service Tag No. 7N4DO21) confirmed Rembold's usage of the JMSD computer in his private district office a minimum of one hundred fifty -six times between the dates of September 4, 2003 through February 5, 2004 to facilitate his teaching of EDA -564, The Role and Functions of the Principal, to his online classes as shown below: Date Subject 9/9/2003 Lecture 2 9/9/2003 Week One DQ 3: Learning Communities 9/9/2003 Week One DQ 3: Learning Communities 9/9/2003 Week One DQ 3: Learning Communities 9/9/2003 Week One DQ 3: Learning Communities 9/9/2003 Feedback For Students 9/10/2003 Week 2: DQ1 -Group Decision 9/10/2003 Week 2: DQ3- Site Based Management 9/10/2003 Week 2: DQ4- Strategic Planning 9/10/2003 Week 2: DQ5- Implementation 9/10/2003 Week 1 Feedback 9/10/2003 Week 2: DQ 3- Site Based Management 9/10/2003 Week 2: DQ 4- Strategic Planning 9/10/2003 Week 2: DQ 5- Implementation 9/10/2003 Questions For Chuck 9/10/2003 Questions For Chuck 9/10/2003 Week 2: Discussion Questions 9/10/2003 Week One Summary 9/26/2003 Week 3 Feedback 9/29/2003 Week 4: DQ3- Principal's Role- Danielle Blue 9/29/2003 Week 4: DQ3- Principal's Role -Brad Corey 9/30/2003 Mini Lectures 9/30/2003 Lecture 5 9/30/2003 Lecture 5 9/30/2003 Week 5: DQ2- Philosophy Of Guidance 9/30/2003 Week 5: DQ3- Multicultural Diversity Change 9/30/2003 Week 5: DQ4- Equitable Educational Opportunities 9/30/2003 Week 5: DQ5- Master Schedule 10/1/2003 Week 4: DQ3- Principal's Role 10/1/2003 Lecture 6 10/2/2003 Lecture 6 10/2/2003 Lecture 6 10/3/2003 Week 4 Feedback 10/3/2003 Week 4 Feedback 10/3/2003 Week 4 : Feedback 10/7/2003 Inadequate Assignment 10/7/2003 None 10/8/2003 Mini - Lecture: Goals And Objectives 10/13/2003 Week 5: Feedback 10/13/2003 Week 5: Feedback 10/13/2003 Week 5 Feedback 10/13/2003 Week 5: Feedback 10/13/2003 Week 5: Feedback 10/13/2003 Week 5 Feedback 10/13/2003 Week 5: Feedback Rembold, 05 -006 Page 24 Date Subject 10/13/2003 Week 5 Feedback 10/13/2003 Week 5: Feedback 10/13/2003 Week 5 Feedback 10/13/2003 Week 5: Feedback 10/13/2003 Week 5 Feedback 10/13/2003 An Offer You Can't Refuse 10/14/2003 Week 6: DQ2 Budget Cuts 10/14/2003 Week 6: DQ2 Budget Cuts -PACE 10/14/2003 Week 6: DQ2 Budget Cuts 10/14/2003 Week 6: DQ2: Budget Cuts 10/15/2003 Final Grade Summary Form 10/16/2003 Week 6 Feedback 10/16/2003 Week 6: Feedback 10/16/2003 Week 6: Feedback 10/16/2003 Week 6 Feedback 10/16/2003 Week 6: Feedback 10/16/2003 Week 6: Feedback 10/16/2003 Week 6 Feedback 10/17/2003 Week 6 Feedback 10/17/2003 Week 6: Feedback 10/17/2003 Week 6: Feedback 10/17/2003 Week 6 Feedback 10/17/2003 Week 6 Feedback 10/17/2003 Week 6: Feedback 10/17/2003 Week 6 Feedback 10/17/2003 Week 6: Feedback 10/20/2003 Grade Certification 10/20/2003 Grade Certification 10/20/2003 Grade Certification 10/20/2003 Grade Certification 10/20/2003 Grade Certification 10/20/2003 Grade Certification 10/20/2003 Grade Certification 10/20/2003 Grade Certification 10/21/2003 Grade Certification 10/21/2003 Grade Certification 10/21/2003 Grade Certification 1/7/2004 Week One DQ !: Distinguish School Leadership 1/7/2004 Week One DQ 2: Leadership Style and Qualities 1/7/2004 Week One DQ 3: Learning Communities 1/7/2004 Week One DQ 4: Performance Organization 1/7/2004 Week One DQ 5: Principal's Role 1/7/2004 Questions For Chuck 1/7/2004 Week One Discussion Questions 1/7/2004 Mini - Lecture Week One: Leadership Domains Rembold, 05 -006 Page 25 Date Subject 1/7/2004 Week One Mini - Lecture: Yearly Plan For Principals 1/7/2004 Week One Mini - Lecture: Motivation 1/7/2004 Week One: Summary (Due Date 1/14/04) 1/7/2004 Chuck's Biography 1/8/2004 Post Your Biography 1/8/2004 Post Your Biography 1/8/2004 Post Your Biography 1/8/2004 Peg Culhane's Bio 1/8/2004 Post Your Biography 1/8/2004 Post Your Biography 1/8/2004 Learning Team Assignments 1/8/2004 Week One: Questions For Chuck 1/8/2004 Learning Team Assignments 1/8/2004 Week One: Questions For Chuck 1/8/2004 Week One: Questions For Chuck 1/9/2004 Post Your Biography 1/9/2004 Week One: Questions For Chuck 1/9/2004 Course Syllabus And Course Text Verification 1/11/2004 Week One DQ 4: Performance Organization 1/12/2004 Moral Leader Question From The Lecture 1/13/2004 Participation Check 1/13/2004 Week 1: Summary 1/13/2004 Week 2: DQ 2 1/13/2004 Week 2: DQ 3 1/13/2004 Week 2: DQ 4 1/13/2004 Week 2: DQ 5 1/13/2004 Week 2: DQ 3 1/13/2004 Week 2: DQ 1 1/13/2004 Mini Lecture: Site -Based Management 1/13/2004 Mini - Lecture: Value -Added Education 1/13/2004 Mini Lecture: Site -Based Management Plan Reference 1/13/2004 Personal Vision Statement 1/13/2004 Week 2: Questions For Chuck 1/13/2004 Team A 1/14/2004 Send Your E -Mail Addresses 1/14/2004 Week 2: Questions For Chuck, Chelsea 1/22/2004 Change Bibliography 1/22/2004 Mini - Lectures: Conflict Styles: Week 3 1/23/2004 Mini - Lecture: Changes In Education 1/27/2004 Questions For Chuck: Week 4 1/27/2004 Week 3: Feedback For Chuck 1/27/2004 To All Students: Week 4 Assignments 1/27/2004 Week 4: Mini - Lecture /Standards 1/27/2004 Week 4 Mini - Lecture /Comprehensive Assessment Plan 1/27/2004 Week 4: Mini - Lecture /Strategic Plan Rembold, 05 -006 Page 26 Check Date Check Number Gross Payment Net Payment 09/25/03 336624 $884.40 $762.54 10/24/03 435315 200.00 179.06 11/10/03 458406 455.60 407.89 01/23/04 45125 884.40 759.53 03/10/04 111398 455.60 406.34 Total $2,880.00 $2,515.36 Date Subject 2/4/2004 Week 5 Mini Lecture: Master Schedule 2/5/2004 Master Schedule /Thoughts 2/5/2004 Sample School Improvement Plan -An Model Elementary 2/5/2004 Week 4 Feedback Rembold, 05 -006 Page 27 a. The actual number of times Rembold utilized the district computer in his private district office to facilitate in instruction of online courses is in excess of one hundred fifty -six times. 1. The forensic examination of the Hard Drive revealed a multitude of e- mail communications associated with Rembold's online instruction which did not detail the date /time sent or received and were not documented here. b. All specific dates noted above were regular working days for JMSD Administrative Staff. 105. Rembold received five payments from the Apollo Group, Inc totaling $2,515.36 for services provided as an online instructor for the University of Phoenix regarding Contract No. 588470 and Contract No. 673393, during the timeframe that he used the JMSD computer for his University of Phoenix employment, as shown below: a. All payments received were deposited into Rembold's account at Community Bank. 106. At no time during Rembold's pursuit of employment or during his actual employment with Apollo Group did Rembold inform the JMSD board of his secondary employment as required per his employment contract. a. Rembold did not disclose his intention to obtain secondary employment or his actual employment to the board at any executive session or regular meeting. 107. At no time while employed with the Apollo Group did Rembold request or receive permission from the board to utilize the JMSD computer in his private district office during or after regular school hours to facilitate his instruction of online classes for the University of Phoenix. a. Rembold never advised any member of the JMSD Board of Directors that he would be utilizing district equipment on district time in furtherance of his private interests. 108. Rembold's use of JMSD technology equipment during regular school days and regular administrative hours to facilitate his instruction of online classes for the The University of Phoenix in circumvention of JMSD policies and requirements of his own employment contract resulted in a personal financial gain to Rembold in the Rembold, 05 -006 Page 28 amount of $2,515.36. THE FOLLOWING FINDINGS RELATE TO REMBOLD'S MISAPPROPRIATION OF A COMPUTER AND RELATED ACCESSORIES ORDERED BY THE GREENE COUNTY INDUSTRIAL DEVELOPMENT AUTHORITY (IDA) FOR HIS OWN PERSONAL USE 109. Rembold served as a member of the IDA Board of Directors from approximately July 1996 through June 2004. 110. From approximately May 2002 through June 2005, Menhart was responsible for computer /technology concerns for the IDA. a. Menhart addressed the needs not only of the IDA office but also various needs associated with the childcare program and the Comm -Tech centers. 111. The IDA employed various individuals in Information Technology positions to assist Menhart including Cody Kuhns, Scott McCracken, Helio Gomez, and Adam Swinchock. 112. On July 25, 2003, the IDA placed an order with Dell Marketing, LP, (hereafter Dell) for the purchase of seven computer systems in the amount of $10,997.00 a. b. The Purchase Order Number associated with the invoice was 1422072203. The Order Number associated with the purchase was 416755016. 1. The order number and the invoice number are the same number. 113. The computer systems purchased were complete systems including mini - towers, hard drives, keyboards, monitors, floppy disk drives, software programs, mouses, digital sound cards, speakers, media, zip drives, and service agreements. a. At that time, the systems purchased were high end regarding performance and capabilities. b. The computers were purchased for distribution to the various Information Technology employees at the IDA and the 21 CCLC. c. The cost of each system was $1,571.00. 114. The Service Tag Numbers of the seven computers associated with the order were J33M531, 243M531, 443M531, 543M531, 743M531, 943M531, and B43M531 as documented on the invoice. a. The invoice documented a "Ship To" address of Carmichaels Area Elementary, 225 North Vine St, Carmichaels, PA 15320. 1. The computers were shipped to Carmichaels Area Elementary School as a result of the order being "piggybacked" with an order from Carmichaels Area Elementary School. 115. On or about August 8, 2003 a representative from the IDA contacted Dell and reported that the original order shipped under Order Number 416755016 had not been received. a. Dell recorded the shipment as "Lost" at that time. Rembold, 05 -006 Page 29 116. On August 25, 2003, Dell issued the IDA an exchange order to replace the original order which was reportedly not received. a. The Purchase Order Number associated with the invoice was 1422072203X. b. The Order Number associated with the purchase was 448860172. 1. The order number and the invoice number are the same number. c. An Exchange Number of 36964305 was assigned to the invoice. 117. The Service Tag Numbers of the seven computers associated with the exchange order were BOJDC31, FOJDC31, 21JDC31, 41JDC31, 81JDC31, FIJDC31, and 22JDC31 as documented on the invoice. a The exchange invoice documented a "Ship To" address of Burke Manhart, Greene County IDA, 225 North Vine St, Carmichaels, Pa 15320. 1. Menhart's name was spelled incorrectly on the exchange invoice. b. The computers were shipped via Eagle Global Logistics Next Day Delivery. 118. The IDA issued Check Number 5039 dated August 26, 2003 to Dell Computers in the amount of $83,738.00 from its General Fund Account at Community Bank. a. Check Number 5039 was written in association with payment of several separate Dell invoices (Invoice Numbers 416755016, 416755750, 416755594, 420708506, and 422036864). b. The memo section of Check Number 5039 documented, "Childcare." 119. All checks issued by the IDA from August 19, 2003 through September 16, 2003 were reviewed at the September 17, 2003, regular IDA board meeting. a. Check Number 5039 in the amount of $83,738.00 to Dell Computers was documented on the bill list. b. Rembold was present at the meeting. 120. At the September 17, 2003 IDA meeting, a motion was made by Board Member Jerome Bartley, seconded by Simatic to approve the monthly checks. a. The motion passed 4 -0 with no abstention by Rembold. 1. Rembold was one of the four board members present. 121. The computers shipped with the exchange order were replicas of the computers originally ordered in terms of model numbers, type, capabilities, accessories, etc. a. Current Dell records continue to classify Service Tag Numbers J33M531, 243M531, 443M531, 543M531, 743M531, 943M531, and B43M531 as "Lost." 122. The computers associated with both the original invoice and the exchange invoice were ultimately received at Carmichaels Area School District. Rembold, 05 -006 Page 30 a. Menhart, Kuhns, and Bryan [sic] Rembold removed one of the two orders from Carmichaels Area School District prior to the start of the 2003 -2004 school year. 1. Bryan [sic] Rembold was employed at the 21 CCLC at that time. b. Menhart and Scott McCracken removed the remaining order from Carmichaels Area School District during or about April /May 2004. 123. The computers included in both the original order and the exchange order were taken to the 21 CCLC office for unpacking and inspection after removal from Carmichaels Area School District. a. The IDA did not pay for or return the extra order of computers to Dell upon receipt. b. Menhart distributed the computers for use from the 21 CCLC office. 124. Three computers from the exchange order (Service Tag Numbers BOJDC31, 41 JDC31, AND F1 JDC31) were eventually provided to JMSD for use. a. The computer represented by Service Tag Number BOJDC31 was utilized by Connie Palfrey, JMSD Technology Administrator at that time, in Palfrey's JMSD office. b. The computer represented by Service Tag Number 41 JDC31 was utilized by Cody Haden, JMSD Computer Technician at that time, in JMSD's Technology Office. c. The computer represented by Service Tag Number F1 JDC31 was damaged and was stored at the JMSD Technology Office. 125. Rembold was employed as the JMSD Superintendent during the period of time when both orders were received. a. No other Greene County school districts were allocated any of the computers received. 126. Three additional computers from the exchange order (Service Tag Numbers FOJDC31, 21 JDC31, and 81 JDC31) were either distributed to IDA employees for use at the IDA office or maintained in storage. a. The computer represented by Service Tag Number FOJDC31 was utilized by Chappel in the IDA office. b. The computer represented by Service Tag Number 21JDC31 was maintained in storage. c. The computer represented by Service Tag Number 81 JDC31 was utilized by Nancy Wrick, IDA Administrative Assistant. 127. The final computer from the exchange order (Service Tag Number 22JDC31) was issued to Scott McCracken for use in association with his IDA job duties at Waynesburg High School. a. Scott McCracken ultimately transported the computer to his home for use in Rembold, 05 -006 Page 31 association with his IDA job duties. b. Scott McCracken returned the computer to the 21 CCLC office when his employment with the IDA ended. 128. Six of the seven computers associated with the original order shipped by Dell were distributed to IDA employees or to JMSD for use upon removal from Carmichaels Area School District. a. Five of the seven computers (Service Tag Numbers 243M531, 443M531, 543M531, 943M531, and B43M531) were distributed either to IDA employees for use at the IDA office or maintained in storage. b. One additional computer, represented by Service Tag Number 743M531, was provided to JMSD for use. 129. Rembold ultimately took possession of the final computer, represented by Service Tag Number J33M531, from the original order and maintained it at his then personal residence of 1841 Bristoria Road, Holbrook, Pa 15341. a. Rembold utilized the computer for his own personal use. b. Rembold did not issue payment to the IDA or Dell prior to or after taking possession of the computer. c. Rembold was able to obtain possession of the computer as a result of his position as IDA Board President. 130. None of the remaining IDA board members had an IDA computer at their residence for professional or personal use. a. At no time did Rembold receive permission from the IDA board to maintain or utilize an IDA computer at his residence. 131. Rembold failed to return the computer to the IDA after his resignation as an IDA board member on June 30, 2004. a. Rembold maintained possession of the computer at his residence from at least May 2004 through late March 2005. b. On March 23, 2005, Rembold made statements to a Commission Investigator that the computer represented via Service Tag Number J33M531 was his personal computer. 132. Rembold was employed as a professor with the Apollo Group, Inc. to teach classes online for The University of Phoenix during the time that he maintained possession of the computer. 133. Rembold entered into agreements with the Apollo Group to teach EDA -532, Human Relations and Organizational Behavior in Education, online under Contract Numbers 829656, 884928, 927961, and 995570. a. The class date spans associated with the above - listed contracts were as follows: Contract No. Course ID Start Date End Date Check Date Check Number Gross Payment Net Payment 07/23/04 301657 $884.40 $759.54 09/10/04 371653 555.60 495.53 10/08/04 411692 884.40 759.53 11/24/04 481640 455.60 406.34 12/22/04 521301 884.40 759.54 02/25/05 81740 455.60 406.34 03/24/05 121624 924.00 791.72 05/10/05 185758 1,400.00 1,159.07 Total $6,444.00 $5,537.61 Description Value /Wages Misappropriation of computer, speakers, keyboard and $1,392.00 Wages Received for Online Instruction $5,537.61 Total $6,929.61 Rembold, 05 -006 Page 32 829656 EDA -532 07/15/04 08/25/04 884928 EDA -532 09/30/04 11/10/04 927961 EDA -532 12/02/04 01/26/04 995570 EDA -532 03/10/05 04/20/05 134. A forensic search of the Hard Drive (Serial No. 3JTOWNS4) installed in the computer that Rembold took possession of (Service Tag No. J33M531) revealed that Rembold utilized the computer consistently between May 2004 and March 2005 to facilitate his instruction of EDA -532, Human Relations and Organizational Behavior in Education, to his University of Phoenix online classes and for other personal purposes. a. Rembold routinely sent and received messages detailing student biographies, course questions, discussion questions, student feedback, grade certifications, etc., in association with his University of Phoenix online classes. 135. Rembold received eight payments from the Apollo Group, Inc. totaling $5,537.61 for services provided as an online instructor for the University of Phoenix regarding Contract Numbers 829656, 884928, 927961, and 995570 as shown below: a. All payments received were deposited into Rembold's account at Community Bank. 136. Rembold's realized a total financial gain of $6,929.61 when he took possession of a computer ordered by the IDA for his own personal use including but not limited to utilizing the computer to facilitate his instruction of online classes for the Apollo Group through The University of Phoenix which resulted in payment for instruction provided. THE FOLLOWING FINDINGS RELATE TO REMBOLD'S PARTICIPATION IN DISCUSSIONS AND DECISIONS OF THE GREENE COUNTY INDUSTRIAL DEVELOPMENT AUTHORITY TO AWARD A CONTRACT IN EXCESS OF $500 WITHOUT AN OPEN AND PUBLIC PROCESS TO BRYAN [SIC] REMBOLD FOR THE DEVELOPMENT OF A WEBSITE FOR EVERGREENE TECHNOLOGY PARK 137. Evergreene Technology Park is a 248 acre industrial park located adjacent to the Line Item Amount Salaries & Fringes $5,000.00 Training & Technical Assistance 2,500.00 Promotion /Public Relations /Advertising 8,500.00 Rembold, 05 -006 Page 33 Greene County Airport. a. The purpose of Evergreene Technology Park is to attract and create new businesses for Greene County. 138. Funding for the development of Evergreene Technology Park has been obtained primarily through the receipt of state and federal grants including grants from the Infrastructure Development Program, the Redevelopment Capital Assistance Program, and the Business In Our Sites Program. 139. The IDA was the initial driving force for the development of Evergreene Technology Park. 140. The Pennsylvania Department of Community and Economic Development (DCED) provides annual grants through the Local Economic Development Assistance Program (LEDA) to industrial development organizations to plan and promote programs to stimulate the establishment of new or enlarged industrial, commercial, service, or manufacturing enterprises within each county of Pennsylvania. 141. Each county government designates by resolution one industrial development organization to make application to DCED to receive available grant funds. a. The IDA is the current designated applicant for Greene County and has been so from at least 2000 through 2005. 142. Deborah Barrett, Program Administrator, DCED, provided correspondence dated July 26, 2000 to Rembold in his capacity as the President of the IDA regarding the LEDA Program grant available to the IDA for fiscal year 2000 -2001. a. Barrett indicated in the correspondence that the IDA was eligible for a grant in the amount of $17,438.00. 143. Chappel completed the DCED Single Application for Assistance for LEDA grant funds on or about September 20, 2000. a. The application noted the IDA as the applicant /sponsor. b. The application noted Rembold as the Chief Executive Officer /President of the IDA. c. The application noted Chappel as the contact individual for the grant. 1. Chappel developed all of the information and figures incorporated into the application. 144. The application documented the grant funds to be utilized for economic development /revitalization with a project budget specific to grant funds obtained as shown below: Office Equipment 1,000.00 Audit 438.00 Total $17,438.00 Rembold, 05 -006 Page 34 a. The entire $17, 438.00 amount was allocated towards the IDA's operational costs /working capital. b. Rembold signed the application in his position as the IDA president on or about September 20, 2000. 145. Accompanying the application was correspondence from Chappel to DCED dated September 20, 2000 regarding the 2000 -2001 LEDA grant. a. Noted in the correspondence was that the $8,500.00 set aside for promotion, public relations, and advertising would be utilized towards a marketing /advertising campaign to attract interest in a new technology park. 146. Correspondence dated October 10, 2000, from DCED, to Rembold verified the approval of a LEDA grant to the IDA in the amount of $17,438.00 for the 2000 -2001 fiscal year. 147. The IDA subsequently received a contract represented via M.E. No. /Contract No.: 20- 105 -0026 from DCED for the Local Economic Development Assistance Grant Program. a. The contract specified the grant amount of $17,438.00. 148. At the October 25, 2000 regular meeting of the IDA board, a motion was made to authorize Rembold and Board Member Sheila Barger, IDA board Secretary /Treasurer, to sign the 2000 -2001 LEDA grant contract. a. Rembold was present at the meeting. b. Individuals making and seconding the motion are not documented in the minutes. c. The motion passed unanimously with no abstentions noted. 149. Rembold signed Contract No.: 20- 105 -0026 on October 26, 2000, in his capacity as the President of the IDA board. a. The contract was signed by DCED Deputy Secretary Emily White on November 8, 2000. 150. The IDA maintains its General Account at Community Bank in Waynesburg, Pa. a. The $17,438.00 grant amount was deposited into the IDA's General Account at Community Bank on December 27, 2000. 151. At the December 20, 2000, regular meeting of the IDA board, discussion occurred regarding the development of a website for Evergreene Technology Park. a. Rembold was present at the December 20, 2000 IDA meeting. b. Rembold recommended his son for the development of the Evergreene Technology Park website. Rembold, 05 -006 Page 35 1 Bryan [sic] Rembold had an educational background in technology at that time. 152. A motion was made and seconded at the December 20, 2000 IDA meeting by Simatic and Barger respectively to enter into a contract with Bryan [sic] Rembold not to exceed $500.00 to Register Evergreene Technology Park as a website. a. The motion passed unanimously, Rembold was present. b. No abstention by Rembold is documented in the minutes. 153. A subsequent motion was made and seconded at the December 20, 2000 IDA meeting by Simatic and Barger respectively to offer a contract to Bryan [sic] Rembold not to exceed $3,000.00 for the creation of a website for Evergreene Technology Park. a. The motion passed unanimously. b. No abstention by Rembold is documented in the minutes. 154. Bryan [sic] Rembold submitted an invoice dated March 20, 2001 to the IDA for work completed on the Evergreene Technology Park Website and other miscellaneous costs as shown below: Completion of one -third of work on Evergreenepark.net Website $1,000.00 Registration of four domain names for a five -year period: * www.evergreenepark.net 120.00 * www.meadowridgepark.net 120.00 * www.paisleyindustrialpark.net 120.00 * www.greenecountyida.net 120.00 Total $1,480.00 a. The $480.00 associated with the registration of domain names was issued to Bryan [sic] Rembold as a reimbursement. 1. Bryan [sic] Rembold initially utilized personal funds to register the domain names. 155. The invoice submitted by Bryan [sic] Rembold to the IDA directed that the check be issued in the name of King's Bridge, Inc. as shown below: King's Bridge, Inc. Information Technology Division Bryan [sic] Rembold 1841 Bristoria Road Holbrook, Pa 15341 a. Although in existence at that time, King's Bridge, Inc., did not have an Information Technology Division. 1. Kings Bridge is a company where Rembold was an officer and director and to which Rembold directed West Greene School District funds to perform certain services to the school district when Rembold was employed as that district's superintendent. Rembold, 05 -006 Page 36 2. Rembold also received in excess of $26,000 from King's Bridge, Inc. 3. Rembold was found in violation of the Ethics Law and fined by the Ethics Commission for his actions. b. 1841 Bristoria Road, Holbrook, Pa 15341, was Rembold's residence at that time. 1. Bryan [sic] Rembold resided with Rembold at that time. 156. Rembold was associated with King's Bridge, Inc., a Virginia corporation, from at least July 1983 up to and including July 2001. a. Rembold served as an initial director of the corporation along with R. Edgar Thacker, was formally listed as a director on the corporation papers with the Virginia Corporations Commission until 2001 and served as a consultant /contractor providing training programs, research, and other services. b. King's Bridge, Inc., was not involved in the development of websites for business marketing purposes. 157. The IDA issued check number 3049, dated April 30, 2001, in the amount of $1,480.00 to King's Bridge, Inc., for services performed by Bryan [sic] Rembold. a. The memo section of the check noted "LEDA Grant." b. Bryan [sic] Rembold negotiated the check at Community Bank on or about May 8, 2001. 158. At the May 16, 2001 regular meeting of the IDA board a motion was made by Barger, seconded by Simatic, to review and approve all checks issued from March 30, 2000 through April 30, 2000. a. A listing of all checks issued was provided for review. 1. Check No. 3049 payable to King's Bridge from LEDA Grant fund for Marketing /Advertising in the amount of $1,480.00 was documented on the bill list. b. Rembold was present at the meeting. c. The motion passed with no abstention by Rembold. THE FOLLOWING FINDINGS RELATE TO REMBOLD'S FAILURE TO FILE A STATEMENT OF FINANCIAL INTERESTS FOR CALENDAR YEAR 2003 AND REMBOLD'S FAILURE TO DISCLOSE CREDITORS AND SOURCES OF INCOME ON STATEMENTS OF FINANCIAL INTERESTS FILED FOR CALENDAR YEARS 2002 AND 2004 IN HIS POSITION AS A MEMBER OF THE GREENE COUNTY INDUSTRIAL DEVELOPMENT AUTHORITY BOARD OF DIRECTORS 159. Statement of Financial Interests filing requirements for public officials and public employees are mandated by Section 1104 of the State Ethics Act. a. Rembold was required to file Statements of Financial Interests by May 1St annually in his position as a member of the IDA Board of Directors. Rembold, 05 -006 Page 37 160. A review of Statements of Financial Interests on file at the IDA office conducted on March 4, 2005 revealed Statements of Financial Interests on file for Rembold regarding calendar years 1997 through 2002. b. All of Rembold's Statements of Financial Interest on file were dated February 6, 2002 Amended with the exception of Rembold's 2002 calendar year form. 1. Rembold's 2002 calendar year form was dated April 28, 2002. c. Rembold's 2004 calendar year form was subsequently obtained on July 5, 2004. 1. Rembold mistakenly dated the form with his date of birth instead of the date the form was completed. 161. Rembold failed to file a Statement of Financial Interests for calendar year 2003 in his position as a member of the IDA Board of Directors. a. No 2003 calendar year form was on file with the IDA when the review was conducted. 162. Information required to be reported on Statements of Financial Interests is set forth under Section 1105 of the State Ethics Act. a. Required disclosures on Statements of Financial Interest include the name and address of each creditor to whom is owed in excess of $6,500.00 and the respective interest rate. b. Additionally required disclosures on Statements of Financial Interest include the name and address of any direct or indirect sources of income totaling $1,300.00 or more. 163. Rembold did not disclose information regarding creditors and direct or indirect sources of income on his Statements of Financial Interests filed for calendar years 2002 and 2004. a. Rembold failed to disclose National City Bank as a creditor when Rembold owed National City Bank in excess of $6,500.00 at various points during those calendar years. 1. Rembold maintains a Home Equity Variable Rate Credit Line Account with National City Bank with a credit line of $85,000.00. 2. The account was opened in January 2002. b. Rembold failed to disclose income from the Greene County Vo -Tech School totaling $1,608.24 and $1,646.94 for calendar years 2002 and 2004 respectively. 1. Rembold was issued a monthly stipend from the Greene County Vo- Tech School for his service as Superintendent of Record for the Vo- Tech. 2. Rembold served as Superintendent of Record for the Vo -Tech from July 2002 through June 2004. THE FOLLOWING FINDINGS RELATE TO REMBOLD'S FAILURE TO DISCLOSE Rembold, 05 -006 Page 38 CREDITORS ON STATEMENTS OF FINANCIAL INTERESTS FILED FOR CALENDAR YEARS 2002, 2003, AND 2004; REMBOLD'S FAILURE TO DISCLOSE SOURCES OF INCOME ON HIS STATEMENT OF FINANCIAL INTERESTS FILED FOR THE 2004 CALENDAR YEAR; AND REMBOLD'S INTENTIONAL BACKDATING OF HIS STATEMENT OF FINANCIAL INTERESTS FOR THE 2000 CALENDAR YEAR TO GIVE THE IMPRESSION THAT IT HAD BEEN FILED IN A TIMELY MANNER IN HIS POSITION AS THE SUPERINTENDENT OF JEFFERSON - MORGAN SCHOOL DISTRICT. 164. Statement of Financial Interests filing requirements for public officials and public employees are mandated by Section 1104 of the State Ethics Act. a. Rembold was required to file Statements of Financial Interests by May 1St annually in his position as the superintendent of JMSD. 165. Rembold filed forms with JMSD in his position as superintendent as shown below: Calendar Year Filing Date "13) Additions - -- Amended 2/4/04 2000 08/22/01 2001 04/28/02 2002 12/13/02 2003 02/04/04 2004 01/05/05 a. Forms for calendar years 2000, 2001, and 2002 have "Post -it" notes affixed to the back of the forms which documents the following: (1) President Greene County Industrial Development Authority (2) President Evergreene Technology Park, Inc. (3) Member CAPE" 166. Information required to be reported on Statements of Financial Interests is set forth under Section 1105 of the State Ethics Act. a. Required disclosures on Statements of Financial Interest include the name and address of each creditor to whom is owed in excess of $6,500.00 and the respective interest rate. b. Additionally required disclosures on Statements of Financial Interest include the name and address of any direct or indirect sources of income totaling $1,300.00 or more. 167. Rembold did not disclose information regarding creditors on his Statements of Financial Interests filed for calendar years 2002, 2003, and 2004; and did not disclose direct or indirect sources of income on his Statements of Financial Interests filed for calendar years 2004. a. Rembold failed to disclose National City Bank as a creditor when Rembold owed National City Bank in excess of $6,500.00 at various points during the 2002, 2003, and 2004 calendar years. b. Rembold failed to disclose income from the Greene County Vo -Tech School Rembold, 05 -006 Page 39 totaling $1,646.94 for calendar year 2004. 168. Rembold was required to complete and file a Statement of Financial Interests in 2001 for the 2000 calendar year in his position as JMSD superintendent. a. Rembold began employment as the JMSD superintendent in August 2001 (See Finding No. 90 [sic]). 169. Rembold's' [sic] 2000 calendar year Statement of Financial Interests form documents a revision date of SEC -1 REV. 01/02. a. Forms with the revision date of SEC -1 REV. 01/02 were printed by Digital Ink and mailed by Eagle Progressive. b. The mailing date associated with SEC -1 REV. 01/02 forms was approximately December 14, 2001. 170. Rembold's 2000 calendar year Statement of Financial Interests is dated August 22, 2001 (See Findings No. 191 [sic]). a. SEC -1 REV. 01/02 forms had not been mailed as of August 22, 2001. b. Rembold backdated his Statement of Financial Interests filed with JMSD for calendar year 2000 giving the impression that form had been timely filed. III. DISCUSSION: At all times relevant to this matter, the Respondent, Charles Rembold ( "Rembold "), has been a public official /employee 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 Rembold violated Sections 1103(a),(c),(f); 1104(a); and 1105(b)(4),(5) of the Ethics Act when he participated as a Greene County Industrial Development Authority (IDA) Board Member in making recommendations resulting in a contract being awarded to Prosocial Solutions when he had a reasonable expectation that he would receive payments from Prosocial; when he made recommendations to award a contract to Prosocial based on his understanding that he would solicit, accept, or receive a portion of any funds paid to Prosocial by the IDA; when he took possession of computer equipment from the IDA for his personal use; when he participated in the award of an IDA contract in excess of $500.00 to his son Brian Rembold for the development of a website without an open and public process; when he failed to file a Statement of Financial Interests (SFI) for the 2003 calendar year by May 1, 2004; when he failed to disclose sources of income and creditors on SFIs filed for the 2002 and 2004 calendar years; and when as Superintendent of the Jefferson - Morgan School District (JMSD) he used school district equipment, facilities, material, and time to further his outside business interests as a compensated instructor for an on -line university; when he failed to disclose creditors on SFIs filed for the 2002, 2003, and 2004 calendar years and failed to disclose sources of income on the SFI filed for the 2004 calendar year; and when he backdated a SFI filed for the 2000 calendar year giving the impression that it had been timely filed. 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 9 of 1989/Act 93 of 1998 as follows: Rembold, 05 -006 Page 40 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 1103. Restricted Activities (c) No public official, public employee or nominee or candidate for public office shall solicit or accept, anything of monetary value, including a gift, loan, political contribution, reward, or promise of future employment based on any understanding of that public official, public employee or nominee that the vote, official action, or judgment of the public official or public employee or nominee or candidate for public office would be influenced thereby. 65 Pa.C.S. § 1103(c). Section 1103(c) of the Ethics Act quoted above provides in part that a public official /public employee shall not solicit or accept anything of monetary value based upon any understanding that his vote, official action or judgment would be influenced thereby. Section 1103(f) of the Ethics Act imposes certain restrictions as to contracting. Section 1103(f) of the Ethics Act provides: Section 1103. Restricted activities (f) 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, Rembold, 05 -006 Page 41 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 1103(f) of the Ethics Act 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. Statement of financial interests required to be filed (a) Each public official of the Commonwealth shall file a statement of financial 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(a) of the Ethics Law 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 1105. Statement of financial interests (b) Required information. - -The statement shall include the following information for the prior calendar year with regard to the person required to file the statement. (4) The name and address of each creditor to whom is owed in excess of $6,500 and the interest rate thereon. However, loans or credit extended between Rembold, 05 -006 Page 42 members of the immediate family and mortgages securing real property which is the principal or secondary residence of the person filing shall not be included. (5) The name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more. However, this provision shall not be construed to require the divulgence of confidential information protected by statute or existing professional codes of ethics or common law privileges. 65 Pa.C.S. §§ 1105(b)(4), (5) Section 1105(b)(4) of Act 93 of 1998 requires that every public official /public employee and candidate list the name, address and interest rate as to any creditor who is owed more than $6,500. 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. 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. USE OF IDA GRANT Rembold served as a member of the IDA from July 1996 until June of 2004 when the County Commissioners sought his resignation due to the negative publicity from Rembold, Order 1303. In that the IDA functions for economic development in Greene County through the creation, attraction and retention of business, Rembold routinely pursued available grants for which IDA served as fiscal agent or administrator. The 21 Century Community Learning Center's Program (Program) typically pursued grants for the IDA. The Program was established by Congress for the purpose of awarding grants to rural and inner city public schools. For Greene County, the Program is an educational partnership coalition that provides educational, health, social services, cultural and recreational opportunities for students. Linda McCracken, the Program Director, assisted Rembold with the filing of grant applications. In 2002, IDA in conjunction with the Program, the Greene County Education Consortium, Greene County Technology Consortium, PBS Literacy Link, and the Childcare Program of Greene County pursued grant funds from U.S. Department of Education for the development of technology centers. In June of 2002, Rembold, as IDA President, submitted an application to the U.S. Department of Education for the Greene County Community Technology Center Program seeking a $300,000 grant. After Rembold received notification that the U.S. Department of Education would not fund the application, he submitted a second application in July of 2003 to the U.S. Department of Education for the Greene County Community Technology Center Program for funding in the amount of $497,000. In October of 2003, the IDA received notice that the U.S. Department of Education once again did not recommend funding. Rembold, 05 -006 Page 43 The IDA submitted a request to the Mellon Foundation in January 2003 for a grant. In May of 2003, the Mellon Foundation issued a $500,000 grant to the IDA. The purpose of the grant was to provide support for two years for child care centers and after - school tutoring programs. A representative of the Mellon Foundation contacted the Claude Worthington Benedum Foundation (Benedum Foundation) to determine if it would assist in funding the project. In the Fall of 2003, the IDA sought grants through the Benedum Foundation that provides funding for education, work force development, economic development, health and human services and community development in West Virginia and Southwestern Pennsylvania. In July of 2003, Rembold participated in a meeting with James Denova, a Senior Program Officer for the Benedum Foundation. Subsequently, in October of 2003, Denova again met with Rembold, McCracken and Menhart, the IDA Director of Special Projects, to further discuss the grant from the Benedum Foundation to fund the Community Technology Centers. In November 2003, the Benedum Foundation determined that a grant in the amount of $260,000 would be awarded to the IDA. In December of 2003, Denova, in a meeting with the Benedum Foundation Board of Trustees, presented a program write up that summarized the details of the IDA project. The presentation by Denova also included funding of $30,000 for an evaluation of the program. After the Benedum Foundation Board of Trustees confirmed the approval of the $260,000 grant to the IDA, Denova informed McCracken of the grant's approval. Stephen Ellsworth (Ellsworth) is the sole owner and operator of a consulting business, Prosocial. Prosocial provides various services, including grant acquisition and project implementation, management and evaluation. Ellsworth maintains both a professional and social relationship with Rembold. Ellsworth developed a Plus Three Program that was provided to Kings Bridge, Inc., a business with which Rembold is associated, for utilization in the People Utilizing Leadership Skills Effectively (PULSE) program. Rembold utilized Ellsworth as a compensated facilitator at various PULSE programs. Ellsworth was aware as early as July of 2003 that Rembold would utilize Prosocial as an evaluator for future grants. Rembold set up a scheme whereby Prosocial would be utilized as an outside consultant vis -a -vis the Benedum grant. The $30,000 paid to Prosocial would be divided among Rembold, McCracken and Ellsworth. To that end, Ellsworth was provided with information from Rembold (through McCracken) that Prosocial would be the evaluator for the project. Rembold and Menhart wanted the evaluations to be done quarterly and be both formative and summative. It was proposed that Ellsworth would invoice the IDA directly for services performed and receive five payments of $6,000 each. After McCracken met with Rembold, McCracken conveyed to Ellsworth how Rembold directed the division of the funds. The $30,000 would be divided up according to Rembold's instruction with Rembold, McCracken and Ellsworth each receiving $9,000. As to the remaining $3,000, Thacker, an associate of Rembold in King's Bridge, Inc., would receive $1,500. As to the remainder, $600 would be paid to Prosocial and $900 would be allocated for taxes. Ellsworth agreed to participate in the arrangement and return funds to Rembold as per an e-mail of December 12, 2003. The Benedum Foundation issued a check in the amount of $260,000 to the IDA in December of 2003. Shortly thereafter, Rembold recommended to the IDA Board that Prosocial serve as the grant evaluator. When Rembold recommended Prosocial, one of the IDA Board Members asked if any of the Board Members had information about Prosocial. Rembold responded that Prosocial had expertise as an evaluator. Rembold, 05 -006 Page 44 The IDA Board unanimously voted to appoint Prosocial as the grant evaluator for a fee not to exceed $30,000 with Prosocial providing quarterly reports. The motion was approved based upon Rembold's recommendation of Prosocial. The motion passed without any abstention by Rembold. Prosocial did not submit quarterly reports to the IDA. Ellsworth only provided an Evaluation Framework, Interim Evaluation and Summative Evaluation. The information utilized by Ellsworth in compiling the Interim Evaluation and Summative Evaluation was provided by McCracken. Ellsworth submitted five invoices totaling $26,000 to the IDA requesting payment for services rendered as to the evaluation of the project funded by the Benedum Foundation grant, the details of which appear in Fact Finding 65. Between March of 2004 and April 2005, the IDA approved payments and issued four checks to Prosocial totaling $24,000. See, Fact Finding 66. Rembold participated in voting to approve one of the checks. After Rembold resigned as an IDA Board Member on June 30, 2004, the IDA did not approve payment of the fifth invoice in the amount of $2,000 from Prosocial. The four checks that Prosocial received from the IDA were deposited into a Prosocial account. Thereafter, Prosocial issued three payments to McCracken totaling $6,000 in partial fulfillment of the disbursement of the funds as directed by Rembold. Prosocial also made two payments to Thacker: a check in the amount of $753 for the incorporation of a company named Syn- Energy, Inc. as a successor to Kings Bridge, Inc.; and a check to Thacker in the amount of $2,000 for tax preparation advice. Thacker did not provide any advice to Ellsworth other than to send him some written material and provide some telephonic tax advice. As to Rembold, he performed no duties or services in relation to the grant evaluation. To the contrary, Rembold's sole role was to recommend Prosocial for the position of evaluator in return for a portion of the funds. See, Fact Finding 62. No payments from Prosocial were made by check to Rembold who insisted that he be paid in cash. See, Fact Finding 75. In this regard, Rembold and his spouse maintained a joint personal checking account wherein cash deposits totaling $15,100 were made from December 2003 through December 2004. Prosocial made payments to Rembold in cash consisting of $2,000 in July of 2004. PERSONAL USE OF SCHOOL DISTRICT PROPERTY Rembold served as the Superintendent of JMSD from August 2001 to August 2005. Rembold reported to the JMSD nine member Board of School Directors. As Superintendent and Chief Administrator, Rembold was expected to be present in the District between the hours of 7:30 a.m. and 3:30 p.m. As a District employee and administrative staff member, Rembold was subject to the provisions of a policy manual of JMSD. Policy No. 319 provides in part that a JMSD Superintendent must avoid situations in which his personal interests, activities and associations conflict with the interest of the school district and must not use school time for outside activities unless there is a valid reason to justify such action. Policy No. 710 provides that the school district equipment and facilities may not be used by staff for personal reasons without explicit authorization or administrative approval. Lastly, it is the policy of JMSD as to computer /internet usage that any type of JMSD technological - telecommunication systems are for educational purposes to carry out the business of the District and any type of commercial or for - profit activities is strictly prohibited. In a private capacity, Rembold obtained employment with the University of Phoenix, which is a higher education institution that provides education through traditional campus programs or via the internet. As JMSD Superintendent, Rembold had the use of a computer and other equipment in his JMSD Office. Rembold used JMSD equipment in furtherance of his employment with the University of Phoenix by using the fax machine to Rembold, 05 -006 Page 45 send resumes, transcripts and certificates. The details of the usage of the school district equipment are delineated in Fact Findings 96, 98, 100. After Rembold obtained approval to teach classes as an online instructor for the University of Phoenix in May of 2003, he routinely used the JMSD computer in his private office to facilitate his online instruction. Such actions by Rembold were done during regular JMSD working hours. A forensic analysis of Rembold's JMSD computer reflects at least 156 instances when Rembold used the computer vis -a -vis his teaching for the University of Phoenix. See, Fact Finding 104. Rembold received five payments from the Apollo Group, the managing corporation for University of Phoenix, totaling $2,515.36 as an online instructor. Rembold never requested or received permission from the JMSD Board to utilize his computer for his instruction of the online classes for the University of Phoenix. Such action by Rembold was a circumvention of the JMSD policies and requirements regarding the usage of JMSD property during school district days and administrative hours. PERSONAL USE OF IDA COMPUTER AND ACCESSORIES While Rembold was a member of the IDA Board of Directors, the IDA placed an order in July of 2003 for seven complete Dell computer systems. In August of 2003, an IDA representative contacted Dell and advised that the shipment had not been received. Dell listed the shipment as lost and issued an exchange order to the IDA to replace the original order. Both the original seven computers that had been sent as well as the seven computers that were sent as an exchange had individualized service tag numbers. The cost of the original order was $10,997 based upon a per unit system cost of $1,571. An IDA check was issued in August 2003 to Dell computers in payment of the order. Subsequently, the Dell computers associated with both the original as well as the exchange invoice were received at the Carmichaels Area School District. Rembold's son Brian and two others removed one of the two orders from the Carmichaels Area School District prior to the start of the 2003/2004 school year. The remaining order was removed from the area school district in April or May of 2004 wherein all computers were taken to 21 CCLC for unpacking and inspection. Rembold's son, Brian, was employed at the time by the 21 CCLC. Three computers from the exchange order were eventually provided to JMSD for its use. Three additional computers from the exchange order were either distributed to IDA employees for use at its offices or maintained in storage. The final computer from the exchange order was issued to Scott McCracken for use in association with IDA job duties at the Waynesburg High School. Six of the seven computers associated with the original order from Dell were distributed to IDA employees or to JMSD for use. Rembold took possession of the seventh computer and maintained it at his residence for his personal use. Rembold, who was able to take possession of the computer as IDA Board President, did not make any payment to the IDA or Dell. No other IDA Board member had a computer at his /her residence for professional or personal use. Rembold failed to return the computer to the IDA after his resignation from the Board in June of 2004. While Rembold maintained possession of that computer, he was employed as a professor with the University of Phoenix. A forensic analysis of the hard drive of that computer reflects that Rembold utilized the computer between May of 2004 and March of 2005 to facilitate his instruction for the University of Phoenix online classes. As an online instructor for the University of Phoenix, Rembold received $5,537.61 for providing such educational services. Rembold received a total financial gain of $6,929.61 as a result of Rembold, 05 -006 Page 46 taking possession of the IDA computer for his personal and business usage. See, Fact Finding 136. AWARD OF AN IDA CONTRACT TO REMBOLD'S SON The IDA obtained various grants that became the linchpin for the development of Evergreene Technology Park (Park), a 248 acre industrial area for the attraction and creation of new businesses. Since IDA was the one and only county designated industrial development organization, DCED contacted Rembold regarding an available LEDA program grant. A single application for assistance for a LEDA grant was completed by IDA with Rembold listed as the CEO /President. The application delineated project budget specifications totaling $17,438. Of the total $17,438, an amount of $8,500 was listed as promotion /public relations /advertising. DCED, by letter of October 10, 2000, verified the approval of an LEDA grant to IDA in the amount of $17,438 for the 2000 -2001 fiscal year. After obtaining authorization from the IDA Board, Rembold signed the contract on October 26, 2000 as IDA Board President. Following receipt of the $17,438 grant, a discussion ensued at the December 2000 IDA Board meeting regarding the development of a website for the Park. After Rembold recommended his son Brian to develop the website, a motion was made, seconded and unanimously passed for the IDA to enter into a contract with Brian Rembold, not to exceed $500, to register the Park as a website. Thereafter, another motion was made, seconded and passed unanimously where the IDA would contract with Brian Rembold, not to exceed $3,000, for the creation of a website for the Park. In March of 2001, Brian Rembold submitted an invoice to the IDA in the total amount of $1,480. The bill was for the registration of four domain names for a five year period and for the completion of 1/3 of the work on the Park website. The invoice from Brian Rembold directed the IDA to make the check payable to Kings Bridge, Inc., even though Kings Bridge, Inc. did not have any IT division. In this regard, Kings Bridge, Inc. was a company to which Rembold directed the West Greene School District funds and then obtained over $26,000 from Kings Bridge for himself. Such actions resulted in Rembold being found in violation of the Ethics Act and fined by this Commission. See, Rembold, Order 1303. The IDA issued a check in the amount of $1,480 to Kings Bridge, Inc. for the services performed by Brian Rembold. At a May 2001 IDA Board meeting, a list of checks was approved, which included the payment to Kings Bridge. The motion to approve the checks passed unanimously at a meeting with Rembold in attendance and with no abstention by Rembold. FAILURE TO FILE SFI OR REPORT FINANCIAL INTERESTS AS AN IDA BOARD MEMBER The Stipulated Findings reflect that Rembold failed to file an SFI for the calendar year 2003 in his position as a member of the IDA Board of Directors. In addition, for the calendar years 2002 and 2004, Rembold failed to disclose information regarding both creditors and direct and indirect sources of income. In particular, Rembold failed to disclose National City Bank as a creditor owed in excess of $6,500. In addition, Rembold failed to disclose income in excess of $1,300 from the Greene County Vo -Tech School for the calendar years 2002 and 2004. Rembold, 05 -006 Page 47 FAILURE TO FILE SFI OR REPORT FINANCIAL INTERESTS AS JMSD SUPERINTENDENT As to Rembold's 2000 calendar year SFI, Rembold filed form SEC -1 Rev. 01/02 with a listed date of August 22, 2001. Because the forms were not mailed until December 14, 2001, that establishes that Rembold backdated the SFI to give the impression that it had been timely filed. For SFI reporting purposes, the record reflects that Rembold failed to disclose direct or indirect sources of income in excess of $1,300 and creditors who were owed in excess of $6,500. In particular, Rembold failed to disclose the Greene County Vo -Tech School as a source of income for calendar year 2004. In addition, Rembold failed to disclose National City Bank as a creditor owed in excess of $6,500 for the SFI calendar years 2002, 2003 and 2004. 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 as follows: "3. The Investigative Division will recommend the following in relation to the above allegations: In relation to Rembold's service as a Member and President of the Greene County Industrial Development Authority: a. That a violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a) occurred in relation to Rembold's solicitation and receipt of funds from Stephen Ellsworth, owner of Prosocial Solutions Research, at a time when Rembold actively participated in the Greene County Industrial Development Authority's actions and decisions to award a contract to Prosocial to perform an evaluation component relating to a grant that Rembold had obtained in his official capacity as IDA President and had a reasonable expectation that he would be receiving said funds from Ellsworth. b. That a violation of Section 1103(c) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(c) occurred in relation to Rembold's solicitation and receipt of funds from Stephen Ellsworth, owner of Prosocial Solutions Research, based upon Rembold's understanding that he would recommend the award of a contract to Prosocial by the Industrial Development Authority where he served as President to perform an evaluation in relation to a grant that Rembold had actively participated in obtaining for the IDA. c. That a violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a) occurred in relation to Rembold's acquisition of a personal computer from the Industrial Development Authority, which computer was thereafter utilized by Rembold at his home for personal purposes, including engaging in activities as an instructor for an online university for which he received compensation. Rembold, 05 -006 Page 48 d. That a violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a) occurred in relation to Rembold's participation as President and a Member of the Industrial Development Authority in the recommendation and employment of his son, by the authority, to perform services in relation to the development and maintenance of a webpage, which services were to be paid out of a grant received by the Industrial Development Authority regarding which Rembold had actively participated in obtaining. e. That a technical violation of Section 1103(f) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(f) occurred in relation to the employment of Rembold's son, by the Industrial Development Authority, to perform services in relation to the development and the maintenance of a webpage, when the contract to employ Rembold's son was in excess of $500 and not awarded through an open and public process. In relation to Rembold's service as Superintendent of the Jefferson Morgan School District: f. That a violation of Section 1103(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1103(a) occurred in relation to Rembold's use of government equipment and facilities, in his position as Superintendent of the Jefferson Morgan School District, in aid of his private employment as an instructor for an online university, which resulted in his receipt of compensation from that entity. In relation to Statements of Financial Interests: g. That a violation of Section 1104(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1104(a) occurred in relation to Rembold's failure to file a Statement of Financial Interests in his position as President of the Industrial Development Authority for calendar year 2003 by May 1, 2004. h. That a violation of Section 1105(b)(4) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1105(b)(4) occurred in relation to Rembold's failure to list creditors on Statements of Financial Interests filed by him in his position as a Member of the Greene County Industrial Development Authority for calendar years 2002 and 2004 respectively, and when he failed to list creditors on Statements of Financial Interests filed for calendar years 2002 through 2004 inclusive, in his position as Superintendent of the Jefferson Morgan School District. That a violation of Section 1105(b)(5) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1105(b)(5) occurred in relation to Rembold's failure to report sources of income on Statements of Financial Interests that he filed for calendar years 2002 and 2004 respectively, in his position as a Member and President of the Greene County Industrial Development Authority; and when he failed to report sources of income on Statements of Financial Interests that he filed for calendar year 2002 and 2004 respectively, in his position as Superintendent Rembold, 05 -006 Page 49 of the Jefferson Morgan School District. That a violation of Section 1104(a) of the Public Official and Employee Ethics Law, 65 Pa.C.S. §1104(a) occurred in relation to Rembold's failure to timely file a Statement of Financial Interests for calendar year 2000, in his position as Superintendent of the Jefferson Morgan School District. 4. Rembold agrees to make payment in the amount of $14,000.00 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. 5. Rembold agrees that he will neither seek nor hold any position of public office or of public employment in the Commonwealth of Pennsylvania at anytime. 6. Rembold agrees that he will not participate in the application or receipt of any state or federal grant funds and that he further will not provide any services for compensation in relation to or paid from any state or federal grants at anytime in the future. 7 The Investigative Division will recommend that this matter be referred for review by the appropriate law enforcement authorities, however, the Investigative Division will further recommend that no specific recommendation be made by the Commission as to the initiation of charges by those agencies. Such, however, does not prohibit the Commission from initiating appropriate enforcement actions in the event of Respondent's failure to comply with this agreement or the Commission's order or cooperating with any other authority who may so choose to review this matter further." J. In applying Section 1103(a) of the Ethics Act to the allegation regarding the IDA grant, there were uses of authority of office on the part of Rembold. But for the fact that Rembold was a member of the IDA, he would not have been in a position to advocate for the award of a $30,000 contract to Prosocial to serve as the grant evaluator of the funds received from the Benedum Foundation. When Rembold was queried as to his recommendation of Prosocial, Rembold responded that Prosocial had expertise as an evaluator. Such actions by Rembold as an IDA Board member were uses of authority of office. The appointment by the IDA Board of Prosocial as the grant evaluator in which Rembold participated was also a use of authority of office by him. Such uses of authority of office resulted in a private pecuniary benefit consisting of the $30,000 that Prosocial would receive under the contract with the IDA. Lastly, a consequent private pecuniary benefit inured to Rembold consisting of the kickbacks that he received from Prosocial vis- a-vis his action of effectuating the award of a contract from IDA to Prosocial. Rembold violated Section 1103(a) of the Ethics Act when he participated as an IDA Board Member in the award of a contract to Prosocial to perform an evaluation in relation to an IDA grant and obtained a portion of those funds for himself. See, Rembold, Order 1303. As to Section 1103(c) of the Ethics Act, this provision encompasses solicitation or acceptance of anything of value that is based upon the public official's understanding that his vote, official action or judgment would be influenced thereby. Rembold, as an IDA Board member, following the receipt of a Benedum Foundation Grant in the amount of $260,000, engaged in two courses of action. First, as an IDA Board Member, he prevailed Rembold, 05 -006 Page 50 upon the Board to enter into a $30,000 contract with Prosocial to perform a program evaluation. Second, Rembold engaged Ellsworth of Prosocial to enter into this arrangement so that Rembold and others could obtain portions of that consulting fee for themselves. Rembold as an IDA member had the understanding that his official action and judgment would be influenced whereby he would advocate and participate in the process of the IDA to award the contract to Prosocial to do the evaluation report and subsequently receive a kickback of a portion of the funds for himself. Under these factual circumstances, all of the requisite elements for a violation of Section 1103(c) of the Ethics Act occurred. Rembold violated Section 1103(c) of the Ethics Act when he solicited and received funds from Stephen Ellsworth, owner of Prosocial Solutions Research, based upon Rembold's understanding that he would recommend the award of a contract to Prosocial to provide for an evaluation of an IDA grant. See, Zwick, Order 1062. Turning to the allegation concerning Rembold's use of the IDA computer at his home for personal purposes, there were uses of authority of office by Rembold. But for the fact that Rembold was an IDA Board Member, he would not have been in a position to take the IDA computer to his home where he utilized it in his private employment as an online instructor for the University of Phoenix. Through that use of authority of office, Rembold taught the online course and received compensation for such services. Lastly, the compensation was a private pecuniary benefit that inured to Rembold himself. Accordingly, Rembold violated Section 1103(a) of the Ethics Act when he took a personal computer from the IDA to his home and used the computer as part of his teaching for compensation as an instructor for an online University. See, Heck, Order 1251. The next allegation concerns Rembold as an IDA member, recommending and participating in an IDA contract with his son to perform services for an internet webpage. The allegations concern both Sections 1103(a) and 1103(f) of the Ethics Act. After the IDA received funds from DCED, vis -a -vis the development of the Park, a Board discussion ensued about the creation of a Park website. At a December 2000 IDA meeting, Rembold specifically recommended his son for the development of the website. The motion was made and passed at that meeting whereby IDA would enter into a contract with Rembold's son, Brian, not to exceed $500, as to the registration of domain names for the Park. In addition, a subsequent motion at that same meeting was proffered and passed to award a contract to Brian Rembold, not to exceed $3,000, for the creation of a Park website. Both of those motions passed unanimously with Rembold present and with no abstentions noted in the minutes. As to Section 1103(a) of the Ethics Act, the actions by Rembold were uses of authority of office as to his advocacy and participation in the award of those two contracts to his son. The payments that Rembold's son received under those contracts were private pecuniary benefits that inured to Rembold's son as an immediate family member. Accordingly, Rembold violated Section 1103(a) of the Ethics Act when he recommended his son and participated in the award of IDA contracts to his son to perform services as to the development and maintenance of an internet webpage. See, Sanders, Order 1119. As to Section 1103(f) of the Ethics Act, that provision allows a public official, spouse or child to contract with a governmental body but if the contract is $500 or more, it must be awarded through an open and public process. In this case, one of the two contracts, was in excess of $500, but not awarded through an open and public process. As noted above, Rembold was instrumental in advocating and participating as to the award of that contract to his son. Section 1103(f) of the Ethics Act requires that the award of that contract should have occurred through an open and public process. However, there was no public Rembold, 05 -006 Page 51 notice or bidding of that contract. Rembold technically violated Section 1103(f) of the Ethics Act when his son contracted with the IDA to perform services as to the development and maintenance of a webpage when the contract was in excess of $500 and not awarded through an open and public process. See, Sanders, supra. Turning to the allegation regarding Rembold's use of JMSD property in aid of his employment as an instructor for an online University, there were uses of authority of office on the part of Rembold. But for the fact that Rembold was the JMSD Superintendent, he would not have been in a position to use school district property such as the fax machine and computer to apply and become an online instructor for the University of Phoenix internet program. Forensic analysis reflects that there was extensive use of the school district computer for purposes related to his online course instruction. All such actions were uses of authority of office. See, Juliante, Order 809. Such uses of authority of office on the part of Rembold resulted in private pecuniary benefits consisting of the compensation that he received as an online instructor for the course. Lastly, the private pecuniary benefits inured to Rembold himself. Accordingly, Rembold violated Section 1103(a) of the Ethics Act when he as the JMSD Superintendent used school district property to obtain private pecuniary benefits in his private employment as an online university course instructor. See, Cagno, Order 1204. The above is consonant with a plethora of prior decisions of this Commission where we have held that a public official /public employee may not use the authority of office by utilizing government offices, equipment, personnel or supplies for private business or campaign /re- election activities. See, Friend, Order 800, Rockefeller, Order 1004, Catone, Order 994. The remaining allegations in this case involve the charges that Rembold either failed to file, back dated or failed to disclose financial interests on his SFIs that he filed with the IDA or JMSD. The Stipulated Findings filed by the parties reflect that Rembold failed to file an SFI for the calendar year 2003 as a member of the IDA. See, Fact Finding 161. Accordingly, Rembold violated Section 1104(a) of the Ethics Act when he, as President of the IDA, failed to file an SFI for the calendar year 2003 by May 1, 2004. See, Tracy, Order 1255. Rembold, both in his positions as Board Member of the IDA and Superintendent of the JMSD, failed to disclose creditors on his SFIs. In particular, for the IDA, Rembold failed to disclose information regarding creditors for the calendar years 2002 and 2004. For those calendar years, Rembold failed to disclose the National City Bank as a creditor to which he owed an amount in excess of $6,500. See, Fact Finding 163(a). Accordingly, Rembold as an IDA Board Member violated Section 1105(b)(4) of the Ethics Act when he failed to disclose a creditor owed in excess of $6,500 for the calendar years 2002 and 2004. See, Schlegel, Order 1372. As JMSD Superintendent, Rembold failed to disclose the National City Bank as a creditor to which he owed an amount in excess of $6,500 for the calendar years 2002, 2003 and 2004. See, Fact Finding 167. Accordingly, Rembold, as the JMSD Superintendent, violated Section 1105(b)(4) of the Ethics Act when he failed to disclose National City Bank as a creditor owed an excess of $6,500 for the 2002, 2003 and 2004 calendar year SFIs. See, Esposito, Order 1333. Turning to the allegations concerning the non - disclosure of direct or indirect sources of income by Rembold, the Stipulated Findings reflect that he received income in excess of $1,300 from the Greene County Vo -Tech School for calendar years 2002 and 2004. See, Fact Finding 163(b). Accordingly, Rembold, as an IDA Board Member, violated Section 1105(b)(5) of the Ethics Act when he failed to list as a source of income in Rembold, 05 -006 Page 52 excess of $1,300 the Greene County Vo -Tech School for the 2002 and 2004 calendar year SFIs. See, Yarnall, Order 996. The Stipulated Findings reflect that Rembold, as JMSD Superintendent, failed to list the Greene County Vo -Tech School as a source of income on only his 2004 SFI. See, Fact Finding 167. Accordingly, Rembold, as the JMSD Superintendent, violated Section 1105(b)(5) of the Ethics Act when he failed to disclose Greene County Vo -Tech School as a source of income in excess of $1,300 on his SFI for the calendar year 2004. See, Davitt, Order 850. Parenthetically, in that there is no finding to reflect a failure to disclose a source of income in excess of $1,300 on Rembold's SFI for the calendar year 2002, we do not include such in the above finding of violation even though it is so stipulated in the Consent Agreement. See also, Allegation. The last SFI allegation concerns a back dating by Rembold of his SFI with the JMSD for the calendar year 2000. The fact that Rembold back dated and therefore did not timely file his SFI with the JMSD for the calendar year 2000 is verified in the Stipulated Findings of the parties. See, Fact Findings 168 -170. Accordingly, Rembold, as the JMSD Superintendent, violated Section 1104(a) of the Ethics Act when he failed to timely file an SFI for the calendar year 2000. See, Draper, Order 1229. 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, Rembold is directed to make payment in the amount of $14,000.00 in settlement of this matter payable to the Commonwealth of Pennsylvania and forwarded to this Commission within thirty (30) days of the issuance of the final adjudication in this matter. Noncompliance will result in the institution of an order enforcement action. Rembold has agreed that he will neither seek nor hold any position of public office or of public employment in the Commonwealth of Pennsylvania at anytime; that he will not participate in the application or receipt of any state or federal grant funds and that he further will not provide any services for compensation in relation to or paid from any state or federal grants at anytime in the future. Per the recommendation of the Investigative Division, this matter will be referred for review to the appropriate law enforcement authorities without any specific recommendation by the Commission as to the initiation of charges by those agencies. If Rembold has not already done so, he is directed within 30 days of the date of issuance of this adjudication to file SFIs and amended SFIs correcting the failures to file and filing deficiencies as delineated above. Noncompliance will result in the institution of an order enforcement action. Although we would normally chastise Rembold regarding his actions in this case, such action would be pointless given Rembold's prior history (Rembold, Order 1303). In any event, paragraph 14(b) of our attached Order says it all. IV. CONCLUSIONS OF LAW: 1. Charles Rembold, as a Member of the Greene County Industrial Development Authority (IDA) Board of Directors and Superintendent of the Jefferson Morgan School District (JMSD), was a public official /employee subject to the provisions of Act 9 of 1989 as codified by Act 93 of 1998. 2. Rembold violated Section 1103(a) of the Ethics Act when he participated as an IDA Board Member in the award of a contract to Prosocial to perform an evaluation in relation to an IDA grant and obtained a portion of those funds for himself. Rembold, 05 -006 Page 53 3. Rembold violated Section 1103(c) of the Ethics Act when he solicited and received funds from Stephen Ellsworth, owner of Prosocial Solutions Research, based upon Rembold's understanding that he would recommend the award of a contract to Prosocial to provide for an evaluation of an IDA grant. 4. Rembold violated Section 1103(a) of the Ethics Act when he took a personal computer from the IDA to his home and used the computer as part of his teaching for compensation as an instructor for an online University. 5. Rembold violated Section 1103(a) of the Ethics Act when he recommended his son and participated in the award of IDA contracts to his son to perform services as to the development and maintenance of an internet webpage. 6. Rembold technically violated Section 1103(f) of the Ethics Act when his son contracted with the IDA to perform services as to the development and maintenance of a webpage when the contract was in excess of $500 and not awarded through an open and public process. 7 Rembold violated Section 1103(a) of the Ethics Act when he as the JMSD Superintendent used school district property to obtain private pecuniary benefits in his private employment as an online university course instructor. 8. Rembold violated Section 1104(a) of the Ethics Act when he, as President of the IDA, failed to file an SFI for the calendar year 2003 by May 1, 2004. 9. Rembold as an IDA Board Member violated Section 1105(b)(4) of the Ethics Act when he failed to disclose a creditor owed in excess of $6,500 for the calendar years 2002 and 2004. 10. Rembold, as the JMSD Superintendent, violated Section 1105(b)(4) of the Ethics Act when he failed to disclose National City Bank as a creditor owed an excess of $6,500 for the 2002, 2003 and 2004 calendar year SFIs. 11. Rembold, as an IDA Board Member, violated Section 1105(b)(5) of the Ethics Act when he failed to list as a source of income in excess of $1,300 the Greene County Vo -Tech School for the 2002 and 2004 calendar year SFIs. 12. Rembold, as the JMSD Superintendent, violated Section 1105(b)(5) of the Ethics Act when he failed to disclose Greene County Vo -Tech School as a source of income in excess of $1,300 on his SFI for the calendar year 2004. 13. Rembold, as the JMSD Superintendent, violated Section 1104(a) of the Ethics Act when he failed to timely file an SFI for the calendar year 2000. In Re: Charles Rembold, Respondent ORDER NO. 1417 File Docket: 05 -006 Date Decided: 10/4/2006 Date Mailed: 10/20/2006 1 Charles Rembold, as a Member of the Greene County Industrial Development Authority (IDA) Board of Directors and Superintendent of the Jefferson Morgan School District (JMSD), violated Section 1103(a) of the Ethics Act when he participated as an IDA Board Member in the award of a contract to Prosocial to perform an evaluation in relation to an IDA grant and obtained a portion of those funds for himself. 2. Rembold violated Section 1103(c) of the Ethics Act when he solicited and received funds from Stephen Ellsworth, owner of Prosocial Solutions Research, based upon Rembold's understanding that he would recommend the award of a contract to Prosocial to provide for an evaluation of an IDA grant. 3. Rembold violated Section 1103(a) of the Ethics Act when he took a personal computer from the IDA to his home and used the computer as part of his teaching for compensation as an instructor for an online University. 4. Rembold violated Section 1103(a) of the Ethics Act when he recommended his son and participated in the award of IDA contracts to his son to perform services as to the development and maintenance of an internet webpage. 5. Rembold technically violated Section 1103(f) of the Ethics Act when his son contracted with the IDA to perform services as to the development and maintenance of a webpage when the contract was in excess of $500 and not awarded through an open and public process. 6. Rembold violated Section 1103(a) of the Ethics Act when he as the JMSD Superintendent used school district property to obtain private pecuniary benefits in his private employment as an online university course instructor. 7 Rembold violated Section 1104(a) of the Ethics Act when he, as President of the IDA, failed to file a Statement of Financial Interests for the calendar year 2003 by May 1, 2004. 8. Rembold as an IDA Board Member violated Section 1105(b)(4) of the Ethics Act when he failed to disclose a creditor owed in excess of $6,500 on his Statements of Financial Interests for the calendar years 2002 and 2004. 9. Rembold, as the JMSD Superintendent, violated Section 1105(b)(4) of the Ethics Act when he failed to disclose National City Bank as a creditor owed an excess of $6,500 for the 2002, 2003 and 2004 calendar year Statements of Financial Interests. 10. Rembold, as an IDA Board Member, violated Section 1105(b)(5) of the Ethics Act when he failed to list as a source of income in excess of $1,300 the Greene County Rembold, 05 -006 Page 55 Vo -Tech School for the 2002 and 2004 calendar year Statements of Financial Interests. 11. Rembold, as the JMSD Superintendent, violated Section 1105(b)(5) of the Ethics Act when he failed to disclose Greene County Vo -Tech School as a source of income in excess of $1,300 on his Statement of Financial Interests for the calendar year 2004. 12. Rembold, as the JMSD Superintendent, violated Section 1104(a) of the Ethics Act when he failed to timely file a Statement of Financial Interests for the calendar year 2000. 13. If Rembold has not already done so, he is directed within 30 days of the date of issuance of this adjudication to file Statements of Financial Interests and amended Statements of Financial Interests correcting the failures to file and filing deficiencies as delineated above. Noncompliance will result in the institution of an order enforcement action. 14. Per the Consent Agreement of the parties: a. Rembold is directed to make payment in the amount of $14,000.00 to the Commonwealth of Pennsylvania through this Commission within thirty (30) days of the mailing of the final adjudication in this matter; b. Rembold is ordered not to seek or hold any position of public office or of public employment in the Commonwealth of Pennsylvania at anytime, not to participate in the application or receipt of any state or federal grant funds and not to provide any services for compensation in relation to or paid from any state or federal grants at anytime in the future; c. This matter will be referred for review to the appropriate law enforcement authorities without any specific recommendation by this Commission as to the initiation of charges by those agencies. d. Compliance with the foregoing will result in the closing of this case with no further action by this Commission; non - compliance will result in the institution of an order enforcement action. BY THE COMMISSION, Louis W. Fryman, Chair