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1 CHRIS CHRISTIE KIM GUADAGNO Ls. btate of nett) YenSep 101 SOUTH BROAD STREET TRENTON, NJ RICHARD E. CONSTABLE, Ill February 23, 2015 Dominic P. DiYanni, Esq. Eric M. Bernstein & Associates, LLC 34 Mountain Blvd. Building A PO Box 4922 Warren, NJ Re; Local Government Ethics Law Complaint #LFB Dear Mr. DiYanni: The Local Finance Board (Board) issued a regarding its findings in the matter of Complaint #LFB against your client, Derek Armstead. Enclosed is the NOTICE issued by the Board. Please be advised that the NOTICE is not a final determination if Mr. Armstead desires to avail himself of the right to request an administrative hearing. If a hearing is requested in accordance with the enclosed NOTICE, the Board will not issue a final decision until the completion of the administrative hearing process. Should you have any questions regarding this matter, please contact Eileen Brennen at (609) Sincerely, 1. 1C:ch Enclosure cc. Complainant 01 Timothy J. Cunningham, Chair Local Finance Board 1 ru.h iv (in l wool 111'1,n rand 1 inplotvr Printed art Rt party em.i Reoctahh:

2 CHRIS CI IRISTIE RIM GUADAGNO Lt. Mite of Reiu letgep 101 SOUTH BROAD STREET TRENTON, NJ RICHARD E. CONSTABLE, III annrninioner STATE OF NEW JERSEY In Re: [Derek Armstead, Councilmember, City of Linden (County of Union) Complaint LFB #13-037] This matter having come before the Local Finance Board (Board) pursuant to the Local Government Ethics Law, N.J.S.A. 40A: et seq., upon complaint that as a Councilmember in the City of Linden, Derek Armstead voted to approve Resolution , which rejected a bid offered by Cherokee Equities on Block 188, Lot 30 also known as 200 East St. Georges Avenue, a property owned by fellow Councilman John Sheehy and his brother Stephen Sheehy, in violation of N.J.S.A. 40A: c.; and, WHEREAS, the Board determined that the allegations were within its jurisdiction, were not frivolous and were based upon a reasonable factual basis, authorized an investigation of this complaint; and WHEREAS, the Local Government Ethics Law states: N.J.S.A. 40A: c. No local government officer or employee shall use or attempt to use his official position to secure unwarranted privileges or advantages for himself or others; WHEREAS, during the course of the investigation, claims were made by certain Councilmembers that the property was excluded because it was purportedly under contract for sale or had a potential buyer; and WHEREAS, there was no evidence in the investigation record demonstrating that any effort was made by City officials/representatives to substantiate that Sheehy's property was under contract of sale or to determine whether or not the balance of properties included in the City's tax sale of May 7, 2013, and made a part of Resolution , were purportedly under contract or had a potential buyer; and Vto Jel$4.'11 ts,ur liy,uf ijr1.,,,r run Et011111)Yei" hq ReLyde(1/101ter and Ret.1 lahle

3 WHEREAS, the Board, having considered the matter, and the relevant statements and information presented and all documentation submitted by Dominic DiYanni, Esq. on behalf of Mr. Armstead in response to the allegations set forth in the complaint concluded that voting to approve Resolution , entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens," which rejected the bid offered for Councilman Sheehy's property, constitutes the use or attempted use of Councilmember Armstead's official position to secure an unwarranted privilege or advantage for Councilman Sheehy, in violation of N.J.S.A. 40A: c. It is therefore, DETERMINED that Derek Armstead, shall be assessed a tine in the amount of $ for the violation as related to his engaging in activities prohibited by the statute. Payment of said fine shall be waived as the Board concluded that the action taken by Councilmember Armstead did not impact him personally and that his level of influence over how the bid for Councilman Sheehy's property was exempted from Resolution was de minimus. NOTICE that Derek Armstead is entitled to an administrative hearing in accordance with N.J.S.A. 40A: to contest this NOTICE. Any request fbr an administrative hearing shall be filed with the Local Finance Board within 30 days receipt of this NOTICE. If an administrative hearing is requested, the Board will not issue a final decision until the completion of the administrative hearing process. Said hearing request shall be filed with Patricia Parkin McNamara, Executive Secretary, Local Finance Board, Department of Community Affairs, P.O. Box 803, Trenton, New Jersey TIMOTHY J. CUNNINGHAM, CHAIR

4 CHRIS CinusTIE Kim GUADAGNO Ls. aftate of.tetra Yergep 101 SouTII BROAD SIRFET MEN ton, NJ February 23, 2015 RICHARD E. CONSTABLE, III Raymond S. Londa, Esq. Londa & Londa 277 North Broad Street Elizabeth, NJ Re: Local Government Ethics Law Complaint #LFB Dear Mr. Londa: The Local Finance Board (Board) issued a regarding its findings in the matter of Complaint #LFB against your client, Rhashonna Cosby-Hurling. Enclosed is the NOTICE issued by the Board. Please be advised that the NOTICE is not a final determination if Ms. Cosby-Hurling desires to avail herself of the right to request an administrative hearing. If a hearing is requested in accordance with the enclosed NOTICE, the Board will not issue a final decision until the completion of the administrative hearing process. Should you have any questions regarding this matter, please contact Eileen Brennen at (609) Sincerely, 1.R..!eb Enclosure cc! Complainant. 01 Timothy J. Cunningham, Chair Local Finance Board 1e lervet is an Enna' Opportutun Landow Pruned on ko.vulrd paper and Weldable

5 CHRIS CHRISTIE KIM GUADAGNO Lt. estate of.0 Chi YenSep 101 SOUTH BROAD STREET TREN ori, NJ RICHARD E. CONSTABLE, III STATE OF NEW JERSEY In Re: [Rhashonna Cosby-Hurling, Councilmember, City of Linden (County of Union) Complaint LFB #13-037] This matter having come before the Local Finance Board (Board) pursuant to the Local Government Ethics Law, N.J.S.A. 40A: et seq., upon complaint that as Councilmember, in the City of Linden, Rhashonna Cosby-Hurling voted to approve Resolution , which rejected a bid offered by Cherokee Equities on Block 188, Lot 30 also known as 200 East St. Georges Avenue, a property owned by fellow Councilman John Sheehy and his brother Stephen Sheehy, in violation of N.J.S.A. 40A: c.; and, WHEREAS, the Board determined that the allegations were within its jurisdiction, were not frivolous and were based upon a reasonable factual basis, authorized an investigation of this complaint; and WHEREAS, the Local Government Ethics Law states: N.J.S.A. 40A: e. No local government officer or employee shall use or attempt to use his official position to secure unwarranted privileges or advantages for himself or others; WHEREAS, during the course of the investigation, claims were made by certain Councilmembers that the property was excluded because it was purportedly under contract or had a potential buyer; and WHEREAS, there was no evidence in the investigation record demonstrating that any effort was made by City officialsirepresentatives to substantiate that Sheehy's property was under contract of sale or to determine whether or not the balance of properties included in the City's tax sale of May 7, 2013, and made a part of Resolution , were purportedly under contract or had a potential buyer; and ts on Equal ibfrortunto l'mphrvir Priont.f/ oft Recycled parer and Reollabk

6 WHEREAS, the Board, having considered the matter, and the relevant statements and information presented and all documentation submitted by Raymond Londa, Esq. on behalf of Ms. Cosby-Hurling in response to the allegations set forth in the complaint, concluded that voting to approve Resolution , entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens," which rejected the bid offered for Councilman Sheehy's property, constitutes the use or attempted use of Councilmember Cosby-Hurling's official position to secure an unwarranted privilege or advantage for Mr. Sheehy, in violation of N.J.S.A. 40A: c. It is therefore, DETERMINED that Rhashonna Cosby-Hurling, shall be assessed a fine in the amount of $ for the violation as related to her engaging in activities prohibited by statute. Payment of said tine shall be waived as the Board concluded that the action taken by Councilmember Cosby-Hurling did not impact her personally and that her level of influence over how the bid for Councilman Sheehy's property was exempt from Resolution was de minimus. NOTICE that Rhashonna Cosby-Hurling is entitled to an administrative hearing in accordance with N.J.S.A. 40A: to contest this NOTICE. Any request for an administrative hearing shall be filed with the Local Finance Board within 30 days receipt of this NOTICE. If an administrative hearing is requested, the Board will not issue a final decision until the completion of the administrative hearing process. Said hearing request shall be filed with Patricia Parkin McNamara, Executive Secretary, Local Finance Board, Department of Community Affairs, P.O. Box 803, Trenton, New Jersey TIMOTHY J. CUNNINGHAM, CHAIR

7 CHRIS CHRISTIE KIM GUADAGNO Lt. g tate of Rau 3fergep 101 SOUTH BROAD StREET TRENTON, NJ RICHARD E. CONSTABLE, III February 23, 2015 Christopher Kolibas, Councilman City of Linden Re: Local Government Ethics Law Complaint #LFB Dear Councilman Kolibas: The Local Finance Board (Board) issued a regarding its findings in the matter of Complaint #LFB against you. Enclosed is the NOTICE issued by the Board. Please be advised that the NOTICE is not a final determination if you desire to avail yourself of the right to request an administrative hearing. If a hearing is requested in accordance with the enclosed NOTICE, the Board will not issue a final decision until the completion of the administrative hearing process. Should you have any questions regarding this matter, please contact Eileen Brennen at (609) Sincerely,.110th Enclosure cc: Complainant 03 Timothy J. Cunningham, Chair Local Finance Board ire its air ilord Opplinuorin' Einployer Pill:toil oft kerv t.led paper rift,/ kvollable

8 CHRIS CHRISTIE KIM GUADAGNO Lt. Mate of Reim jetlep 101 SOUTH BROAD SrREET THErkrroN, NJ RICHARD E. CONSTABLE, III STATE OF NEW JERSEY In Re: [Christopher Kolibas, Councilmember, City of Linden (County of Union) Complaint LFB #13-037] This matter having come before the Local Finance Board (Board) pursuant to the Local Government Ethics Law, N.J.S.A. 40A: et seq., upon complaint that as Councilmember, in the City of Linden, Christopher Kolibas voted to approve Resolution which rejected a bid offered by Cherokee Equities on Block 188, Lot 30 also known as 200 East St. Georges Avenue, a property owned by fellow Councilman John Sheehy and his brother Stephen Sheehy, in violation of N.J.S.A. 40A: c.; and, WHEREAS, the Board determined that the allegations were within the its jurisdiction, were not frivolous and were based upon a reasonable factual basis, authorized an investigation of this complaint; and WHEREAS, the Local Government Ethics Law states: N.J.S.A. 40A: e. No local government officer or employee shall use or attempt to use his official position to secure unwarranted privileges or advantages for himself or others; WHEREAS, Christopher Kolibas did not respond to the Notice of Investigation dated, March 21, 2014 or to the second request for a response dated, June 20, 2014; and WHEREAS, during the course of the investigation, claims were made by certain Councilmembers that the property was excluded because it was purportedly under contract or had a potential buyer; and WHEREAS, there was no evidence in the investigation record demonstrating that any effort was made by City officials/representatives to substantiate that Sheehy's property was under contract of sale or to determine whether or not the balance of properties included in the City's tax sale of May 7, 2013, and made a part of Resolution , were purportedly under contract or had a potential buyer; and t..k.n srt rs nn Lima, 1.frivnwinnity I initl.n cf. Primed in; Ref.n. led ;m iner :mil Roo., lin*

9 WHEREAS, the Board having considered the matter, and the relevant statements and information presented in response to the allegations set forth in the complaint concluded that voting to approve Resolution , entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens," which rejected the bid offered for Councilman Sheehy's property, constitutes the use or attempted use of Councilmember Kolibas' official position to secure an unwarranted privilege or advantage for Councilman Sheehy, in violation of N.J.S.A. 40A: c. It is therefore, DETERMINED that Christopher Kolibas, shall be assessed a fine in the amount of $ for the violation as related to his engaging in activities prohibited by statute. Payment of said fine shall be waived as the Board concluded that the action taken by Councilmember Kolibas did not impact him personally and that his level of influence over how the bid for Councilman Sheehy's property was exempt from Resolution was de minimus. NOTICE that Christopher Kolibas is entitled to an administrative hearing in accordance with N.J.S.A. 40A: to contest this NOTICE. Any request for an administrative hearing shall be filed with the Local Finance Board within 30 days receipt of this NOTICE. If an administrative hearing is requested, the Board will not issue a final decision until the completion of the administrative hearing process. Said hearing request shall be filed with Patricia Parkin McNamara, Executive Secretary, Local Finance Board, Department of Community Affairs, P.O. Box 803, Trenton, New Jersey TIMOTHY J. CUNNINGHAM, CHAIR

10 CHRIS CHRISTIE KIM GUADAGNO Lt. 'tote of.ietu Nerlep DEPARTMENT OP COMMUNITY Al'PAIRS 101 SOUTH BROAD STREET TRENTON, NJ RICHARD E. CONSTABLE, III February 23, 2015 Todd D. Palumbo, Esq. 123 N. Union Avenue, Ste. 305 Cranford, NJ07016 Re: Local Government Ethics Law Complaint #LFB Dear Mr. Palumbo: The Local Finance Board (Board) issued a regarding its findings in the matter of Complaint #LFB against your client, Richard Koziol. Enclosed is the NOTICE issued by the Board. Please be advised that the NOTICE is not a final determination if Mr. Koziol desires to avail himself of the right to request an administrative hearing. If a hearing is requested in accordance with the enclosed NOTICE, the Board will not issue a final decision until the completion of the administrative hearing process. Should you have any questions regarding this matter, please contact Eileen Brennen at (609) Sincerely, ric eb Enclosure Cornplain.01( 04 Timothy J. Cunningham, Chair Local Finance Board I Dal V 411, , 111",Irer!el' is On hiteal Qty,tof MUM 1:111111i1Ve I. Prink cf..n RI'41L pap r.111(1 Reel't table

11 CHRIS CHRISTIE KIM GUADAGNO Lt. tfite of _eau jerop WI Sou rh BRoAD S MEET Tx I.N mint, NJ RICHARD E. CONSTABLE, III STATE OF NEW JERSEY In Re: [Richard Koziol, Councilmember, City of Linden (County of Union) Complaint LFB #13-037] This matter having come before the Local Finance Board (Board) pursuant to the Local Government Ethics Law, N.J.S.A. 40A: et seq., upon complaint that as Councilmember, in the City of Linden, Richard Koziol voted to approve Resolution , which rejected a bid offered by Cherokee Equities on Block 188, Lot 30 also known as 200 East St. Georges Avenue, a property owned by fellow Councilman John Sheehy and his brother Stephen Sheehy, in violation of N.J.S.A. 40A: c.; and, WHEREAS, the Board determined that the allegations were within its jurisdiction, were not frivolous and were based upon a reasonable factual basis, authorized an investigation of this complaint; and WHEREAS, the Local Government Ethics Law states: N.J.S.A. 40A: c. No local government officer or employee shall use or attempt to use his official position to secure unwarranted privileges or advantages for himself or others; WHEREAS, during the course of the investigation, claims were made by certain Councilrnembers that the property was excluded because it was purportedly under contract or had a potential buyer; and WHEREAS, there was no evidence in the investigation record demonstrating that any effort was made by City officials/representatives to substantiate that Sheehy's property was under contract of sale or to determine whether or not the balance of properties included in the City's tax sale of May 7, 2013, and made a pan of Resolution , were purportedly under contract or had a potential buyer; and \1:11' linphlyer Pouted On RCC. 1 C led paper and Ro.n hrbk

12 WHEREAS, the Board, having considered the complaint, and the relevant statements and information submitted by Todd Palumbo, Esq. on behalf of Mr. Koziol in response to the allegations set forth in the complaint, concluded that voting to approve Resolution , entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens" which rejected the bid offered for Councilman Sheehy's property, constitutes the use or attempted use of Councilmember Koziol's official position to secure an unwarranted privilege or advantage for Councilman Sheehy, in violation of N.J.S.A. 40A: c. It is therefore, DETERMINED that Richard Koziol, shall be assessed a fine in the amount of $ for the violation as related to his engaging in activities prohibited by statute. Payment of said fine shall be waived as the Board concluded that the action taken by Councilmember Koziol did not impact him personally and that his level of influence over how the bid for Councilman Sheehy's property was exempt from Resolution was de minimus. NOTICE that Richard Koziol is entitled to an administrative hearing in accordance with N.J.S.A. 40A: to contest this NOTICE. Any request for an administrative hearing shall be filed with the Local Finance Board within 30 days receipt of this NOTICE. If an administrative hearing is requested, the Board will not issue a final decision until the completion of the administrative hearing process. Said hearing request shall be filed with Patricia Parkin McNamara, Executive Secretary, Local Finance Board, Department of Community Affairs, P.O. Box 803, Trenton, New Jersey TIMOTAY J. CUNNINGHAM, CHAIR

13 Cttxts CIIRISTIE KIM GUADAGNO Lt. 'tote of POD lergep 101 SOUTH BROAD STREET TREN'toN, NJ February 23, 2015 RICHARD E. CONSTABLE, III Cornrnissioner Gaetano M. DeSapio, Esq. Olde Theatre Centre 1110 Harrison Street Suite H Frenchtown, NJ Re: Local Government Ethics Law Complaint #LFB Dear Mr. DeSapio: The Local Finance Board (Board) issued a regarding its findings in the matter of Complaint #LFB against your client Adam Kuczynski. Enclosed is the NOTICE issued by the Board. Please be advised that the NOTICE is not a final determination if Mr. Kuczynski desires to avail himself of the right to request an administrative hearing. If a hearing is requested in accordance with the enclosed NOTICE, the Board will not issue a final decision until the completion of the administrative hearing process. Should you have any questions regarding this matter, please contact Eileen Brennen at (609) Sincerely, 1.1C:ch Enclosure CA.. Complainant Timothy J. Cunningham, Chair Local Finance Board ^AfF p1 It It itcp'et' r Nun, fliintrionfir mpforer Printed on Rectr/ed purer mu/ Relit /(1/7/e.

14 CHRIS CIIRISTIE KIM GLIADAGNO Li. 'tate of.met jeroep 101 SOUTH BROAD STREET TRENTON, NJ RICHARD E. CONSTABLE, III Commis: loner STATE OF NEW JERSEY In Re: [Adam Kuczynski, Councilmember, City of Linden (County of Union) Complaint LFB #13-037] This matter having come before the Local Finance Board (Board) pursuant to the Local Government Ethics Law, N.J.S.A. 40A: et seq., upon complaint that as Councilmember, Adam Kuczynski voted to approve Resolution which rejected a bid offered by Cherokee Equities on Block 188, Lot 30 also known as 200 East St. Georges Avenue, a property owned by fellow Councilman John Sheehy and his brother Stephen Sheehy, in violation of N.J.S.A. 40A: c.; and, WHEREAS, the Board determined that the allegations were within its jurisdiction, were not frivolous and were based upon a reasonable factual basis, authorized an investigation of this complaint; and WHEREAS, the Local Government Ethics Law states: N.J.S.A. 40A: c. No local government officer or employee shall use or attempt to use his official position to secure unwarranted privileges or advantages for himself or others; WHEREAS, during the course of the investigation, claims were made by certain Councilmembers that the property was excluded because it was purportedly under contract or had a potential buyer; and WHEREAS, there was no evidence in the investigation record demonstrating that any effort was made by City officials/representatives to substantiate that Sheehy's property was under contract of sale or to determine whether or not the balance of properties included in the City's tax sale of May 7, 2013, and made a part of Resolution , were purportedly under contract or had a potential buyer; and,icrce3 ty an Eq ual f.ifynn-runny hnithjyer Printed on Reerded pyrex omit Recychthfr

15 WHEREAS, the Board, having considered the matter, and the relevant statements and information presented and all documentation submitted by Gaetano DeSapio, Esq. on behalf of Mr. Kuczynski in response to the allegations set forth in the complaint, concluded that voting to approve Resolution , entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens," which rejected the bid offered for Councilman Sheehy's property, constitutes the use or attempted use of Councilmember Kuczynski's official position to secure an unwarranted privilege or advantage for Councilman Sheehy, in violation of N.J.S.A. 40A: c. It is therefore, DETERMINED that Adam Kuczynski, shall be assessed a fine in the amount of $ for the violation as related to his engaging in activities prohibited by statute. Payment of said fine shall be waived as the Board concluded that the action taken by Councilmember Kuczynski did not impact him personally and that his level of influence over how the bid for Councilman Sheehy's property was exempt from Resolution was de minimus. NOTICE that Adam Kuczynski is entitled to an administrative hearing in accordance with N.J.S.A. 40A: to contest this NOTICE. Any request for an administrative hearing shall be tiled with the Local Finance Board within 30 days receipt of this NOTICE. If an administrative hearing is requested, the Board will not issue a final decision until the completion of the administrative hearing process. Said hearing request shall be tiled with Patricia Parkin McNamara, Executive Secretary, Local Finance Board, Department of Community Affairs, P.O. Box 803, Trenton, New Jersey TIMOTHY J. CUNNINGHAM, CHAIR

16 CIIRIS CHRISTIE KIM GUADACNO Ls. *tate of fete Yer5tp DFPAIITMENT OF COMMUNITY AFFAIRS IRE SOUTH BROAD STREET TILENToN, NJ RICHARD E. CONSTABLE, February 23, 2015 Steven D. Grossman, Esq. Walder Hayden P.A. 5 Becker Farm Road Roseland, NJ Re: Local Government Ethics Law Complaint 4LFB ' Dear Mr. Grossman: The Local Finance Board (Board) issued a regarding its findings in the matter of Complaint #LFB against your client, Armando Medina. Enclosed is the NOTICE issued by the Board. Please be advised that the NOTICE is not a final determination if Mr. Medina desires to avail himself of the right to request an administrative hearing. If a hearing is requested in accordance with the enclosed NOTICE, the Board will not issue a final decision until the completion of the administrative hearing process. Should you have any questions regarding this matter, please contact Eileen Brennen at (609) Sincerely, ric eh Enclosure cc: Complainant 06 I imothy J. Cunningham, Chair Local Finance Board Vvir ts rin 1.4pial Op/ortririr Lorploro. Printed tin Wert /edpopur am/ Rec,lahle

17 CHRIS CIIRISTIE KIM GUADAGNO Le. *tote of Re131 YerVep 101 SOUTH BROAD STREET TR EIVFON NJ RICHARD E. CONSTABLE, III STATE OF NEW JERSEY In Re: [Armando Medina, Councilmember, City of Linden (County of Union) Complaint LFB #13-037] This matter having come before the Local Finance Board (Board) pursuant to the Local Government Ethics Law, N.J.S.A. 40A: et seq., upon complaint that as Councilmember, in the City of Linden, Armando Medina voted to approve Resolution which rejected a bid offered by Cherokee Equities on Block 188, Lot 30 also known as 200 East St. Georges Avenue, a property owned by fellow Councilman John Sheehy and his brother Stephen Sheehy, in violation of N.J.S.A. 40A: c.; and, WHEREAS, the Board determined that the allegations were within its jurisdiction, were not frivolous and were based upon a reasonable factual basis, authorized an investigation of this complaint; and WHEREAS, the Local Government Ethics Law states: N.J.S.A. 40A: c. No local government officer or employee shall use or attempt to use his official position to secure unwarranted privileges or advantages for himself or others; WHEREAS, during the course of the investigation, claims were made by certain Councilmembers that the property was excluded because it was purportedly under contract or had a potential buyer; and WHEREAS, there was no evidence in the investigation record demonstrating that any effort was made by City officials/representatives to substantiate that Sheehy's property was under contract of sale or to determine whether or not the balance of properties included in the City's tax sale of May 7, 2013, and made a part of Resolution , were purportedly under contract or had a potential buyer; and ten./0" :11 IS an 1.1prof Linployr Prinkel in! Reciehq paper midi 1?ecl1t lahk

18 WHEREAS, the Board, having considered the matter, and the relevant statements and information presented and all documentation submitted by Steven Grossman, Esq. on behalf of Mr. Medina in response to the allegations set forth in the complaint, concluded that voting to approve Resolution , entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens," which rejected the bid offered for Councilman Sheehy's property, constitutes the use or attempted use of Councilmember Medina's official position to secure an unwarranted privilege or advantage for Councilman Sheehy, in violation of N.J.S.A. 40A: c. It is therefore, DETERMINED that Armando Medina, shall be assessed a fine in the amount of $ for the violation as related to his engaging in activities prohibited by statute. Payment of said fine shall be waived as the Board concluded that the action taken by Councilmember Medina did not impact him personally and that his level of influence over how the bid for Councilman Sheehy's property was exempt from Resolution was de minimus. NOTICE that Armando Medina is entitled to an administrative hearing in accordance with N.J.S.A. 40A: to contest this NOTICE. Any request for an administrative hearing shall be filed with the Local Finance Board within 30 days receipt of this NOTICE. If an administrative hearing is requested, the Board will not issue a final decision until the completion of the administrative hearing process. Said hearing request shall be filed with Patricia Parkin McNamara, Executive Secretary, Local Finance Board, Department of Community Affairs, P.O. Box 803, Trenton, New Jersey TIMO HY J. CUNNINGHAM, CHAIR

19 CHRIS CHRISM! KIM GUAD GNO Lt. estate of ietu lettep tot SOUTH BROAD STREET TREN TON, NJ RICHARD E. CONSTABLE, III February 23, 2015 Joann Neylan, Esq. Spector Foerst & Associates 159 Millburn Avenue Millburn, N Re: Local Government Ethics Law Complaint #LFB Dear Ms. Neylan: The Local Finance Board (Board) issued a regarding its findings in the matter of Complaint #LFB against your client, James Moore. Enclosed is the NOTICE issued by the Board. Please be advised that the NOTICE is not a final determination if Mr. Moore desires to avail himself of the right to request an administrative hearing. If a hearing is requested in accordance with the enclosed NOTICE, the Board will not issue a final decision until the completion of the administrative hearing process. Should you have any questions regarding this matter, please contact Eileen Brennen at (609) Sincerely, 11C:ett Enclosure cc: Complainant 07 Timothy J. Cunningham, Chair Local Finance Board!en A:3. w '. is on twin/ Opportunto I nip/ayer Prurwil on Ruci pow and lino( fable

20 CHRIS Cuaisru KIM GUADAGNO Le. estate of Rein Verge' DEPARIMMT OF COMMUNITY AFFAIRS 101 SOUTH BROAD STREET TRENTON, NJ RICHARD E. CONSTABLE, III STATE OF NEW JERSEY In Re: [James Moore, Councilmember, City of Linden (County of Union) Complaint LFB #13-037] This matter having come before the Local Finance Board (Board) pursuant to the Local Government Ethics Law, N.J.S.A. 40A: et seq., upon complaint that as Councilmember, in the City of Linden, James Moore voted to approve Resolution which rejected a bid offered by Cherokee Equities on Block 188, Lot 30 also known as 200 East St. Georges Avenue, a property owned by fellow Councilman John Sheehy and his brother Stephen Sheehy, in violation of N.J.S.A. 40A: c.; and, WHEREAS, the Board determined that the allegations were within its jurisdiction, were not frivolous and were based upon a reasonable factual basis, authorized an investigation of this complaint; and WHEREAS, the Local Government Ethics Law states: N.J.S.A. 40A: c. No local government officer or employee shall use or attempt to use his official position to secure unwarranted privileges or advantages for himself or others; WHEREAS, during the course of the investigation, claims were made by certain Councilmembers that the property was excluded because it was purportedly under contract or had a potential buyer; and WHEREAS, there was no evidence in the investigation record demonstrating that any effort was made by City officials/representatives to substantiate that Sheehy's property was under contract of sale or to determine whether or not the balance of properties included in the City's tax sale of May 7, 2013, and made a part of Resolution , were purportedly under contract or had a potential buyer; and a tt \en ,2i IN en, Lqual Onfurrinun 1 MphA t 4 Printiql tnt ROCVelt'd paper WO ldrerc l,hie

21 WHEREAS, the Board, having considered the matter, and the relevant statements and information presented and all documentation submitted by Joann Neylan, Esq. on behalf of Mr. Moore in response to the allegations set forth in the complaint, concluded that voting to approve Resolution , entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens," which rejected the bid offered for Councilman Sheehy's property, constitutes the use or attempted use of Councilmember Moore's official position to secure an unwarranted privilege or advantage for Councilman Sheehy, in violation of N.J.S.A. 40A: c. It is therefore, DETERMINED that James Moore, shall be assessed a fine in the amount of $ for the violation as related to his engaging in activities prohibited by statute. Payment of said fine shall be waived as the Board concluded that the action taken by Councilmember Moore did not impact him personally and that his level of influence over how the bid for Councilman Sheehy's property was exempt from Resolution was de minimus. NOTICE that James Moore is entitled to an administrative hearing in accordance with N.J.S.A. 40A: to contest this NOTICE. Any request for an administrative hearing shall be filed with the Local Finance Board within 30 days receipt of this NOTICE. If an administrative hearing is requested, the Board will not issue a final decision until the completion of the administrative hearing process. Said hearing request shall be filed with Patricia Parkin McNamara, Executive Secretary, Local Finance Board, Department of Community Affairs, P.O. Box 803, Trenton, New Jersey TIMOTHY J. CUNNINGHAM, CHAIR

22 CHRIS CHRISTIE KIM GUADAGNO Lt. 'tote of POD 3'erf5ep 101 SOUTH BROAD STREET PO Box. 803 TittNinig, NJ RICHARD E. CONSTABLE, III February 23, 2015 Anthony N. Palumbo, Esq. Palumbo & Renaud 190 North Avenue East (Rte.28) Cranford, NJ Re: Local Government Ethics Law Complaint #LFB Dear Palombo: The Local Finance Board (Board) issued a regarding its findings in the matter of Complaint #LFB against your client, Robert Sadowski. Enclosed is the NOTICE issued by the Board. Please be advised that the NOTICE is not a final determination if Mr. Sadowski desires to avail himself of the right to request an administrative hearing. If a hearing is requested in accordance with the enclosed NOTICE, the Board will not issue a final decision until the completion of the administrative hearing process. Should you have any questions regarding this matter, please contact Eileen Brennen at (609) Sincerely, I JC. 011 Enclosure cc: Complainant Timothy J. Cunningham. Chair Local Finance Board tirial WIturrrit horployte Priilled,nt kelp led paper aid ReLyt fable

23 CHRIS CHRISTI KIM GUADAGNO Lt. Zttate of Petu Yer 101 SOUTH BROAD STREET TRENION, NJ RICHARD E. CONSTABLE, 111 STATE OF NEW JERSEY In Re: [Robert Sadowski, Councilmember, City of Linden (County of Union) Complaint LFB #13-037] This matter having come before the Local Finance Board (Board) pursuant to the Local Government Ethics Law, N.J.S.A. 40A: et seq., upon complaint that as Councilmember, in the City of Linden, Robert Sadowski voted to approve Resolution which rejected a bid offered by Cherokee Equities on Block 188, Lot 30 also known as 200 East St. Georges Avenue, a property owned by fellow Councilman John Sheehy and his brother Stephen Sheehy, in violation of N.J.S.A. 40A: c.; and, WHEREAS, the Board determined that the allegations were within its jurisdiction, were not frivolous and were based upon a reasonable factual basis, authorized an investigation of this complaint; and WHEREAS, the Local Government Ethics Law states: N.J.S.A. 40A: c. No local government officer or employee shall use or attempt to use his official position to secure unwarranted privileges or advantages for himself or others; WHEREAS, during the course of the investigation, claims were made by certain Councilmembers that the property was excluded because it was purportedly under contract or had a potential buyer; and WHEREAS, there was no evidence in the investigation record demonstrating that any effort was made by City officials/representatives to substantiate that Sheehy's property was under contract of sale or to determine whether or not the balance of properties included in the City's tax sale of May 7, 2013, and made a part of Resolution , were purportedly under contract or had a potential buyer; and,"1 1, r '1.1 Mi 1..cpird Ypparirriult. I.inple.lyer PrinIcti rxr lic.cwitli piqwr (Ind,Ret.11:vhfhle

24 WHEREAS, the Board, having considered the matter, and the relevant statements and information presented and all documentation submitted by Anthony Palumbo, Esq. on behalf of Mr. Sadowksi in response to the allegations set forth in the complaint, concluded that voting to approve Resolution , entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens," which rejected the bid offered for Councilman Sheehy's property, constitutes the use or attempted use of Councilmember Sadowski's official position to secure an unwarranted privilege or advantage for Councilman Sheehy, in violation of N.J.S.A. 40A: c. It is therefore, DETERMINED that Robert Sadowski, shall be assessed a fine in the amount of $ for the violation as related to his engaging in activities prohibited by statute. Payment of said tine shall be waived as the Board concluded that the action taken by Councilmember Sadowski did not impact him personally and that his level of influence over how the bid for Councilman Sheehy's property was exempt from Resolution was de minimus. NOTICE that Robert Sadowski is entitled to an administrative hearing in accordance with N.J.S.A. 40A: to contest this NOTICE. Any request for an administrative hearing shall be filed with the Local Finance Board within 30 days receipt of this NOTICE. If an administrative hearing is requested, the Board will not issue a final decision until the completion of the administrative hearing process. Said hearing request shall be filed with Patricia Parkin McNamara, Executive Secretary, Local Finance Board, Department of Community Affairs, P.O. Box 803, Trenton, New Jersey TIMOT Y J. CUNNINGHAM, CHAIR

25 CIIRIS CIIRISTIE KIM GUADAGNO Lt. apt a t e of Beth 3ergep 101 SOUTH BROAD STREET PO Box. 803 Tnfrrrom NJ February 23, 2015 RICHARD E. CONSTABLE, III Michele Yamakaitis, Councilwoman City of Linden MM. Re: Local Government Ethics Law Complaint #LFB Dear Councilwoman Yamakaitis: The Local Finance Board (Board) issued a regarding its findings in the matter of Complaint #LFB against you. Enclosed is the NOTICE issued by the Board. Please be advised that the NOTICE is not a final determination if you desire to avail yourself of the right to request an administrative hearing. If a hearing is requested in accordance with the enclosed NOTICE, the Board will not issue a final decision until the completion of the administrative hearing process. Should you have any questions regarding this matter, please contact Eileen Brennen at (609) Sincerely, l'jc eb Enclosure cc: Lomplaitiant 09 Timothy J. Cunningham, Chair Local Finance Board 1-0 vti./1 l f s In l,gleui Opporismify rinplot Prifl/L'il 011 Ret pied paper and Root

26 CHRIS CHRISTIE KIM GUADAGNO Lt. *tate of ROI) jerap DF_PARTMENT OF COMMUNITY AFFAIRS 101 SOUTH BROAD STREF.T PO Box. 803 TRENTON, N j RICHARD E. CONSTABLE, III Consminioner STATE OF NEW JERSEY In Re: [Michele Yamakaitis, Councilmember, City of Linden (County of Union) Complaint LFB # This matter having come before the Local Finance Board (Board) pursuant to the Local Government Ethics Law, N.J.S.A. 40A: et seq., upon complaint that as Councilmember, in the City of Linden, Michele Yamakaitis voted to approve Resolution which rejected a bid offered by Cherokee Equities on Block 188, Lot 30 also known as 200 East St. Georges Avenue, a property owned by fellow Councilman John Sheehy and his brother Stephen Sheehy, in violation of N.J.S.A. 40A: c.; and, WHEREAS, the Board determined that the allegations were within its jurisdiction, were not frivolous and were based upon a reasonable factual basis, authorized an investigation of this complaint; and WHEREAS, the Local Government Ethics Law states: N.J.S.A. 40A: c. Na local government officer or employee shall use or attempt to use his official position to secure unwarranted privileges or advantages for himself or others; WHEREAS, Michele Yamakaitis did not respond to the Notice of Investigation dated, March 21, 2014 or to the second request for a response dated, June 17, 2014; and WHEREAS, during the course of the investigation, claims were made by certain Councilmembers that the property was excluded because it was purportedly under contract or had a potential buyer; and WHEREAS, there was no evidence in the investigation record demonstrating that any effort was made by City officials/representatives to substantiate that Sheehy's property was under contract of sale or to determine whether or not the balance of properties included in the City's tax sale of May 7, 2013, and made a part of Resolution , were purportedly under contract or had a potential buyer: and 4'11 it. e.st Own( DI plinth WI rn7=101 er Prii, 111 RCtlt len pig Pur turd Reothrbk

27 WHEREAS, the Board, having considered the matter, and the relevant statements and information presented in response to the allegations set forth in the complaint, concluded that voting to approve Resolution , entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens," which rejected the bid offered for Councilman Sheehy's property, constitutes the use or attempted use of Councilmember Yamakaitis' official position to secure an unwarranted privilege or advantage for Councilman Sheehy. in violation of N.J.S.A. 40A: c. It is therefore, DETERMINED that Michele Yamakaitis, shall be assessed a fine in the amount of $ for the violation as related to her engaging in activities prohibited by statute. Payment of said fine shall be waived as the Board concluded that the action taken by Councilmember Yamakaitis did not impact her personally and that her level of influence over how the bid for Councilman Sheehy's property was exempt from Resolution was de minimus. NOTICE that Michele Yamakaitis is entitled to an administrative hearing in accordance with N.J.S.A. 40A: to contest this NOTICE. Any request for an administrative hearing shall be tiled with the Local Finance Board within 30 days receipt of this NOTICE. if an administrative hearing is requested, the Board will not issue a final decision until the completion of the administrative hearing process. Said hearing request shall be filed with Patricia Parkin McNamara, Executive Secretary, Local Finance Board, Department of Community Affairs, P.O. Box 803, Trenton, New Jersey TIMOTHY J. CUNNINGHAM, CHAIR

28 CHRIS CHRISTIE KIM GUADAGNO la. Mate of Reim YerfSep 101 SOUTH BROAD STREET 'fa ENTON, NJ RICHARD E. CONSTABLE, III February 23, 2015 Mr. Richard J. Gerbounka Re: Local Government Ethics Law Complaint # LI' B Dear Mr. Gerbounka: The Local Finance Board (Board) issued a regarding its findings in the matter of Complaint #LFB against you. Enclosed is the NOTICE issued by the Board. Please be advised that the NOTICE is not a final determination if you desire to avail yourself of the right to request an administrative hearing. If a hearing is requested in accordance with the enclosed NOTICE, the Board will not issue a final decision until the completion of the administrative hearing process. Should you have any questions regarding this matter, please contact Eileen Brennen at (609) Sincerely, ic7eb Enclosure Lc: Complainant 10 Timothy J. Cunningham, Chair Local Finance Board rit Von er tc itlf hpu11 Frotplover &two/ 011 Rel d paper.eflfd 116,111(1W

29 CHRIS CIIRISTIE KIM GUADAGNO Lt. Mote of,1033 leasep 101 SOUTH BROAD STREET TRENTON* NJ STATE OF NEW JERSEY RICHARD E. CONSTABLE, Ill In Re: [Richard J. Gerbounka, Mayor, City of Linden (County of Union) Complaint LFB # This matter having come before the Local Finance Board (Board) pursuant to the Local Government Ethics Law, N.J.S.A. 40A: et seq., upon complaint that as Mayor, in the City of Linden, Richard J. Gerbounka participated in City Council caucus meetings with Councilmembers where proposed Resolution entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens," including a tax sale list of properties was discussed, and where the issue of whether or not the bid offered by Cherokee Equities on Block 188, Lot 30 also known as 200 East St. Georges Avenue, a property owned by Councilman John Sheehy and his brother Stephen Sheehy, should be rejected, was discussed; and upon complaint that Mayor Gerbounka executed Resolution which accepted all bids with the exception of rejecting the bid made by Cherokee Equities on the Sheehy property in violation of N.J.S.A. 40A: c. and d.; and, WHEREAS, the Board determined that the allegations were within its jurisdiction, were not frivolous and were based upon a reasonable factual basis, authorized an investigation of this complaint; and WHEREAS, the Local Government Ethics Law states: N.J.S.A. 40A: c. No local government officer or employee shall use or attempt to use his official position to secure unwarranted privileges or advantages for himself or others; N.J.S.A. 40A: d. No local government officer or employee shall act in his official capacity in any matter where he, a member of his immediate family, or a business organization in which he has an interest, has a direct or indirect financial or personal involvement that might reasonably be expected to impair his objectivity or independence of judgment; WHEREAS, during the course of the investigation, claims were made by certain Council members that the property was excluded because it was purportedly under contract for sale or had a potential buyer; and ry an hinal Opporinnay 1.94over Prink:4 an Reg Riml paper and Wet+. table

30 WHEREAS, there was no evidence in the investigation record demonstrating that any effort was made by City officials/representatives to substantiate that Sheehy's property was under contract of sale or to determine whether or not the balance of properties included in the City's tax sale of May 7, 2013, and made a part of Resolution , were under contract or had a potential buyer; and WHEREAS, the Board, having considered the matter, and the relevant statements and information presented and all documentation submitted by Richard J. Gerbounka in response to the allegations set forth in the complaint, concluded that participating in City Council caucus meeting discussions involving the status of Councilmember Sheehy's property in Resolution , and executing Resolution , entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens" which rejected the bid offered for Councilmember Sheehy's property, constitutes the use or attempted use of Mayor Gerbounka's official position to secure an unwarranted privilege or advantage for Councilmember Sheehy, as well as an indirect personal involvement relating to Councilmember Sheehy's property that may have reasonably impaired Mayor Gerbounka's objectivity or independence of judgment, in violation of N.J.S.A. 40A: c. and d. It is therefore, DETERMINED that Richard J. Gerbounka, shall be assessed a fine in the amount of $ for the violation as related to his engaging in activities prohibited by statute. Said fine shall be payable to: Treasurer, State of New Jersey, and be submitted to: Timothy J. Cunningham, Chair, Local Finance Board, P.O. Box 803, Trenton, New Jersey, 08625, immediately. If payment of said fine is not received within 30 days receipt of this NOTICE, Richard J. Gerbounka is subject to additional fines as determined by the Board in accordance with its powers pursuant to N.J.S.A. 40A: , Violations and Penalties. NOTICE that Richard S. Gerbounka is entitled to an administrative hearing in accordance with N.J.S.A. 40A: to contest this NOTICE. Any request for an administrative hearing shall be filed with the Local Finance Board within 30 days receipt of this NOTICE. If an administrative hearing is requested, the Board will not issue a final decision until the completion of the administrative hearing process. Said hearing request shall be filed with Patricia Parkin McNamara, Executive Secretary, Local Finance Board, Department of Community Affairs, P.O. Box 803, Trenton, New Jersey TIMOTHY J. CUNNINGHAM, CHAIR

31 IRIS CHRISM Governer GUADACNO Lt. i tate of ROD Yettep lin SOUTH BROAD STREEr PO Bo 803 TREntroN, NI RICHARD E. CONSTABLE, III Commit:loner February 23, 2015 Edward J. Kologi, Esq. 500 North Wood Avenue Linden, NJ Re: Local Government Ethics Law Complaint #LFB Dear Mr. Kologi: The Local Finance Board (Board) issued a regarding its findings in the matter of Complaint #LFB against your client, Peter Brown. Enclosed is the NOTICE issued by the Board. Please be advised that the NOTICE is not a final determination if Mr. Brown desires to avail himself o f the right to request an administrative hearing. If a hearing is requested in accordance with the enclosed NOTICE, the Board will not issue a final decision until the completion of the administrative hearing process. Should you have any questions regarding this matter, please contact Eileen Brennen at (609) Sincerely, TJC:ch Enclosure CC: complainant I Timothy J. Cunningham, Chair Local Finance Board a Oi tki Iru 4't Vt'S 1 Lord f 1ppr rlu nut L mplivor Prorli.ili.frif Rrr i e Ica elnd ReCyaifille

32 CHRIS CI IRISTIE KIM GUADACNO Lt.,rate of RE133 gerslep 101 Sou-rH Bit An STREET TRENTON, NJ STATE OF NEW JERSEY RICHARD E. CONSTABLE, Ill In Re: [Peter Brown, Councilmember, City of Linden (County of Union) Complaint LFB #13-037] This matter having come before the Local Finance Board (Board) pursuant to the Local Government Ethics Law, N.J.S.A. 40A: et seq., upon complaint that as Councilmember, in the City of Linden, Peter Brown participated in City Council caucus meetings with Councilmembers where proposed Resolution entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens," including a tax sale list of properties was discussed, and where the issue of whether or not the bid offered by Cherokee Equities on Block 188, Lot 30, also known as 200 East St. Georges Avenue, a property owned by Councilman John Sheehy and his brother Stephen Sheehy, should be rejected, was discussed; and upon complaint for voting to approve Resolution which accepted all bids with the exception of rejecting the bid made by Cherokee Equities on said property in violation of N.J.S.A. 40A: c. & d.; and, WHEREAS, the Board determined that the allegations were within its jurisdiction, were not frivolous and were based upon a reasonable factual basis, authorized an investigation of this complaint; and WHEREAS, the Local Government Ethics Law states: N.J.S.A. 40A: c. No local government officer or employee shall use or attempt to use his official position to secure unwarranted privileges or advantages for himself or others; N.J.S.A. 40A: d. No local government officer or employee shall act in his official capacity in any matter where he, a member of his immediate family, or a business organization in which he has an interest, has a direct or indirect financial or personal involvement that might reasonably be expected to impair his objectivity or independence of judgment; WHEREAS, during the course of the investigation, claims were made by certain Councilmembers that the property was excluded because it was purportedly under contract for sale or had a potential buyer; and q,. 0.5e, tc an ton/ opwriarni. Empliner Proui.,1 en) Retitled popur a,z I ketyciahle

33 WHEREAS, there was no evidence in the investigation record demonstrating that any effort was made by City officials/representatives to substantiate that Sheehy's property was under contract of sale or to determine whether or not the balance of properties included in the City's tax sale of May 7, 2013, and made a part of Resolution , were under contract or had a potential buyer; and WHEREAS, the Board, having considered the matter, and the relevant statements and information presented and all documentation submitted by Edward Kologi, Esq. on behalf of Councilmember Brown in response to the allegations set forth in the complaint, concluded that participating in City Council caucus meeting discussions involving the status of Councilmember Sheehy's property in Resolution , and voting to approve Resolution , entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens" which rejected the bid offered for Councilmember Sheehy's property, constitutes the use or attempted use of Councilmember BrOwn's official position to secure an unwarranted privilege or advantage for Councilmember Sheehy, as well as an indirect personal involvement relating to Councilmember Sheehy's property that may have reasonably impaired Councilmember Brown's objectivity or independence of judgment, in violation of N.J.S.A. 40A: c. and d. It is therefore, DETERMINED that Peter Brown, shall be assessed a fine in the amount of $ for the violation as related to his engaging in activities prohibited by statute. Said fine shall be payable to: Treasurer, State of New Jersey, and be submitted to: Timothy J. Cunningham, Chair, Local Finance Board, P.O. Box 803, Trenton, New Jersey, 08625, immediately. If payment of said fine is not received within 30 days receipt of this NOTICE, Peter Brown is subject to additional fines as determined by the Board in accordance with its powers pursuant to N.J.S.A. 40A: , Violations and Penalties. NOTICE that Peter Brown is entitled to an administrative hearing in accordance with N.J.S.A. 40A: to contest this NOTICE. Any request for an administrative hearing shall be filed with the Local Finance Board within 30 days receipt of this NOTICE. If an administrative hearing is requested, the Board will not issue a final decision until the completion of the administrative hearing process. Said hearing request shall be filed with Patricia Parkin McNamara, Executive Secretary, Local Finance Board, Department of Community Affairs, P.O. Box 803, Trenton, New Jersey TIMOTHY J. CUNNINGHAM, CHAIR

34 Chats CIIRISTIE KIM GUADAGNO Lt. gptate o fie t33 e r ep 101 SOUTH BROAD STREET TxiimioN, NJ February 23, 2015 RICHARD E. CONSTABLE, Ill Commitsioner Mr. John Sheehy Re: Local Government Ethics Law Complaint #LFB Dear Mr. Sheehy: The Local Finance Board (Board) issued a regarding its findings in the matter of Complaint #LFB against you. Enclosed is the NOTICE issued by the Board. Please be advised that the NOTICE is not a final determination if you desire to avail yourself of the right to request an administrative hearing. If a hearing is requested in accordance with the enclosed NOTICE, the Board will not issue a final decision until the completion of the administrative hearing process. Should you have any questions regarding this matter, please contact Eileen Brennen at (609) ]C - eh Enclosure cc: Complainant 12 Timothy J. Cunningham, Chair Local Finance Board.4,0,e) iv ern!vial (11131) il nipliovr 'Orin/el/MI Ref 1'4 poper and ReCj'i hihh

35 CHRIS CI MIME KIM GUADAGNO Li. Rotate of Rein leroep 101 SouTH BROAD Si am TIIIINTON, NJ RICHARD E. CONSTABLE, Ill STATE OF NEW JERSEY In Re: [John Sheehy, Councilmember, City of Linden (County of Union) Complaint LFB #13-037} This matter having come before the Local Finance Board (Board) pursuant to the Local Government Ethics Law, N.J.S.A. 40A: et seq., upon complaint that as Councilmember, in the City of Linden, John Sheehy: 1) participated in City Council caucus meetings with Councilmembers where proposed Resolution entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens," including a tax sale list of properties was discussed, and where the issue of whether or not a bid offered by Cherokee Equities on Block 188, Lot 30 also known as 200 East St. Georges Avenue, a property owned by Councilmember Sheehy and his brother Stephen Sheehy. should be rejected, was discussed; and 2) voted to approve Resolution which rejected the bid on his own property, in violation of N.J.S.A. 40A: c. and d.; and, WHEREAS, the Board determined that the allegations were within its jurisdiction, were not frivolous and were based upon a reasonable factual basis, authorized an investigation of this complaint; and WHEREAS, the Local Government Ethics Law states: N.J.S.A. 40A: c. No local government officer or employee shall use or attempt to use his official position to secure unwarranted privileges or advantages for himself or others; N.J.S.A. 40A: d. No local government officer or employee shall act in his official capacity in any matter where he, a member of his immediate family, or a business organization in which he has an interest, has a direct or indirect financial or personal involvement that might reasonably be expected to impair his objectivity or independence of judgment; WHEREAS, during the course of the investigation, claims were made by certain Councilmembers that the property was excluded because it was purportedly under contract for sale or had a potential buyer; and 1o1 it., ce a in I qua/ 191>ren Ingpl,,tvr Pr/m..41.m R.r( i 111,i1 paper mid Rei t c lithk

36 WHEREAS, there was no evidence in the investigation record demonstrating that any effort was made to substantiate that the Sheehys' property was under contract of sale or to determine whether or not the balance of properties included in the City's tax sale of May 7, 2013, and made a part of Resolution , were under contract or had a potential buyer; and WHEREAS, the Board, having considered the matter, and the relevant statements and information presented and all documentation submitted by Councilmember Sheehy in response to the allegations set forth in the complaint, concluded that participating in City Council caucus meeting discussions involving property in which he has an interest and voting to approve Resolution , entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens" which rejected the bid offered for his property, constitutes the use or attempted use of Councilman Sheehy's official position to secure an unwarranted privilege or advantage for himself as well as a direct personal and financial involvement that may have reasonably impaired his objectivity or independence of judgment, in violation of N.J.S.A. 40A: c. and d. It is therefore, DETERMINED that John Sheehy, shall be assessed a fine in the amount of $ for the violation as related to his engaging in activities prohibited by statute. Said fine shall be payable to: Treasurer, State of New Jersey, and be submitted to: Timothy J. Cunningham, Chair, Local Finance Board, P.O. Box 803, Trenton, New Jersey, 08625, immediately. If payment of said fine is not received within 30 days receipt of this NOTICE, John Sheehy is subject to additional fines as determined by the Board in accordance with its powers pursuant to N.J.S.A. 40A: , Violations and Penalties. NOTICE that John Sheehy is entitled to an administrative hearing in accordance with N.J.S.A. 40A: to contest this NOTICE. Any request for an administrative hearing shall be filed with the Local Finance Board within 30 days receipt of this NOTICE. If an administrative hearing is requested, the Board will not issue a final decision until the completion of the administrative hearing process. Said hearing request shall be filed with Patricia Parkin McNamara, Executive Secretary, Local Finance Board, Department of Community Affairs, P.O. Box 803, Trenton, New Jersey TIMOTHY J. CUNNINGHAM, CHAIR

37 CHRIS CIIRIS II: KIM GUADAGNO Li. 73;itate of jaeto gettep 101 SOUTH BROAD Si REI-IT PO Rox 803 TIMNIIIN, NJ RICHARD E. CONSTABLE, III March 12, 2015 Joseph P. Depa, Jr., Esq. 214 Walnut Avenue PO Box 276 Cranford, NJ Re: Local Government Ethics Law Complaint #LFB AMENDED Dear Mr. Depa: The Local Finance Board (Board) issued an AMENDED regarding its findings in the matter of Complaint #LFB against your client, Christopher Kolibas. Enclosed is the NOTICE issued by the Board. Please be advised that the NOTICE is not a final determination if Mr. Kolibas desires to avail himself of the right to request an administrative hearing. If a hearing is requested in accordance with the enclosed NOTICE, the Board will not issue a final decision until the completion of the administrative hearing process. Should you have any questions regarding this matter, please contact Eileen Brennen at (609) Sincerely, 1 IC eh Enc losure C'C' Complditurit (11 Timothy J. Cunningham, Chair Local Finance Board 1t II.h rwt e. an 14m:I 111 yr rrtrrrull 1-mpli)re., 1rimed.vi Rea tele,' 'wilier,00

38 CHRIS CIIRISTIE Gavernor Kim GuA om;no Lt. Go ernor tate of Petu jergep DEPARIMENT of COMMUNITY AFFAIRS 101 SOUTH BROAD STREW!' PO Ben 803 TRENT EON, NJ RICHARD E. CONSTABLE, Ill STATE OF NEW JERSEY AMENDED In Re: Christopher Kolibas, Councilmember, City of Linden (County of Union) Complaint LFB This matter having come before the Local Finance Board (Board) pursuant to the Local Government Ethics Law, N.J.S.A. 40A: et seq., upon complaint that as Councilmember, in the City of Linden, Christopher Kolibas voted to approve Resolution which rejected a hid offered by Cherokee Equities on Block 188, Lot 30 also known as 200 East St. Georges Avenue, a property owned by fellow Councilman John Sheehy and his brother Stephen Sheehy, in violation of N.J.S.A. 40A: c.; and, WHEREAS, the Board determined that the allegations were within the its jurisdiction, were not frivolous and were based upon a reasonable factual basis, authorized an investigation of this complaint; and WHEREAS, the Local Government Ethics Law states: N.J.S.A. 40A: e. No local government officer or employee shall use or attempt to use his official position to secure unwarranted privileges or advantages for himself or others; WHEREAS, during the course of the investigation, claims were made by certain Councilmembers that the property was excluded because it was purportedly under contract or had a potential buyer: and WHEREAS, there was no evidence in the investigation record demonstrating that any effort was made by City officials/representatives to substantiate that Sheehy's property was under contract of sale or to determine whether or not the balance of properties included in the City's tax sale of May 7, and made a part of Resolution , were purportedly under contract or had a potential buyer; and ? I.911W/ 1.)1,1 riq :Willi 1 Pitt, 11'1'.P1 (Wed Re+.11 l tllluper hdlle

39 WHEREAS, the Board having considered the matter, and the relevant statements and information presented and all documentation submitted by Joseph Depa, Jr., on behalf of Mr. Kolibas in response to the allegations set forth in the complaint concluded that voting to approve Resolution , entitled, "Resolution Authorizing Jones Act Assignment Sale of Municipally Held Tax Title Liens," which rejected the bid offered for Councilman Sheehy's property, constitutes the use or attempted use of Councilmember Kolibas' official position to secure an unwarranted privilege or advantage for Councilman Sheehy, in violation of N.J.S.A. 40A : c. It is therefore, DETERMINED that Christopher Kolibas, shall be assessed a fine in the amount of $ for the violation as related to his engaging in activities prohibited by statute. Payment of said fine shall be waived as the Board concluded that the action taken by Councilmember Kolibas did not impact him personally and that his level of influence over how the bid for Councilman Sheehy's property was exempt from Resolution was de minimus. NOTICE that Christopher Kolibas is entitled to an administrative hearing in accordance with N.J.S.A., 40A: to contest this NOTICE. Any request for an administrative hearing shall be tiled with the Local Finance Board within 30 days receipt of this NOTICE. If an administrative hearing is requested, the Board will not issue a final decision until the completion of the administrative hearing process. Said hearing request shall be tiled with Patricia Parkin McNamara, Executive Secretary, Local Finance Board, Department of Community Affairs, P.O. Box 803, Trenton, New Jersey TIMOTHY J. CUNNINGHAM, CHAIR

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