>;.

ONONDAGA COUNTY BOARD Oii:ETIDCS

. :: JOllNll. MULROY'CIVIC (;ENTER:
42i)tON'tGOMERY Sl'REE(l41'Ii FLOOR
SYRA<;U~E; NJl\V yoRK

13ih2
.: .::

November 2, 2015
Mr. Robert E. Anton~cci II

Re: . Adv~sory Opinion

Dear Mr. Antonacci:
The Onondaga County Board of Ethics receiv~4 an a.nonymous complaint about your
Annual Statement of Financial Disclosure for Onondaga County for the calendar year of 2015 ~
A copy of that complaint is enclosed hereWith~. together with a copy of your 2015 Disclosure
form.

The Board convene~ on.O~tober 22, 2015 to ~eview the complaint in accordance with its
powers
and duties
under
Section 4'.9 of the Onondaga County
Code of Ethics.

,.
.
:.
. .
.
'

The complaint alleges that in addition to the income earned as the Onondaga County
Comptroller you have derived income from outside sources. Paragraph 4(c) of your 2015
Annual Statement of Financial Disclosure provides that you earned itlcome of $10,001 to
$50,000 as a basketball official. Additionally, in.Paragraph4(e) of the form, you claim that you
earned between $10,001 and $50;000 in income as a Certified Public Accountant It appears
from the initial review of the Oilondaga County Board of Ethics that it may. be improper for you,
as the Onondaga County Comptroller, to derive income from outside sources of employment
during your term of office.
Section 501 of.the Onondaga County Charter states that the Comptroller "shrul devote his
whole time to the duti~s ofhis office and shall hold no other public office." (emphasis added).
Section 5.01 of the Onondaga County Administrative Code provides that "the Comjitroller shall
. ~. devote the entire time to the duties o:f his office and shall hold no other public office."
(emphasis .added). The purpose of the Charter and Code provisions are to ensure that you, as the
duly elected Comptroller, devote your full thne arid energies to the service of your constituency,
and perform your official functions without divesting time and energies to the pursuit of any
other occupation, profession or employment for private gain. It is the concern of the Board of
Ethics that" outside employment is beyond 1:he scope of your duties as Comptroller and is
inconsistent with the mandates of the Onondaga County Charter and Code. Therefore1 the Board
of Ethics respectfully requests that you immediately respond in writing to its concerns and the
allegations in the complaint, and indicate whether you have a differing interpretation of the

.
.
Charter and/or Code.

Robert Antonacci, Il
November 2, 2015
Page2
Re: Board of Ethics Opinion
The complaint raises additional concerns that your failure to disclose the identities of
your clients could shield potential conflicts between Onondaga County and your accounting
business. Should you cease outside employment, you will alleviate the need for disclosure of
your clients.
Finally, the complaint reports a potential need to disclose the receipt of motor vehicle(s)
:from Wilber .Duck Chevrolet which you and/or your spouse and dependents operate on a full
time basis, without personal cost. The Board requires additional details :from you in order to
ascertain whether the vehicle(s) should be included as gifts on paragraph 4(f) of the Disclosure
fonn. Do you own, operate or lease such vehicle(s) from. the dealership? Do you maintain and
insure the vehicle(s)? Do you incur personal expenses for such vehicle(s)? Amending your
2015 annual fmancial disclosure fonn and including such vehicle(s) on future disclosure forms
may remedy any past omissions in disclosing the vehicle(s).
We hope we have been of assistance in resolving issues raised in the complaint received
by the Board. We welcome your input and look forward to receiving your response to this matter
in the very near future.
Very truly yours,

ONONDAGA COUNTY
BOARD OF ETHICS

~~I
~J.t~

~JL1UJ
Fi(x/)~.D_
William J.

~f.

Jcdi; I >tt:

Robert E. Scully, S.J., J.D.

Enclosures

,l

August 13, 2015

Ms. Ann Rooney
Onondaga County Ethics Board
421 Montgomery Street
Syracuse, NY 13202
Dear Ms. Rooney,
According to Mr. Robert Antonacci and the article I read on Syracuse.com, you are the sole member of the
Onondaga County Ethics Board. Therefore I direct my correspondence to you. Additionally, I am aware the
District Attorney Fitzpatrick will joining your board, I would ask you to pass this on to him once he becomes
official.
The purpose of my letter is to file a formal complaint against Comptroller Robert Antonacci. Based on the below
stated information, I do not believe that Mr. Antonacci is fit to serve in his capacity as County Comptroller and I
believe he should either be removed from office or prosecuted for his actions.
Allegation #1: Perjury
On Mr. Antonacci's 2015 ethics form, which he declared to be accurate under penalty of perjury, Mr. Antonacci
stated that neither he nor his spouse had received any gifts greater than $1,000. This is false. Mr. Antonacci has
perjured himself with this false statement. It is a well-known fact that Mr. Antonacci operates a motor vehicle with
dealer plates from Wilbur Duck Chevrolet. While he may be related by marriage to people who have an ownership
stake in the dealership, the gift is from the dealership, not his family. Additionally, there is a cost for the dealership
associated with maintaining the vehicle and insuring the vehicle. Other members of Mr. Antonacci's immediate
family may also receive this benefit. Under penalty of perjury when asked if he or his spouse or his dependent
children have receive any gift greater than $1,000, Mr. Antonacci stated "NONE".
Allegation #2: Acceptance of illegal gifts
As alleged above, Mr. Antonacci has the exclusive use of a vehicle that he does not pay for. This is a violation of
the Onondaga County Gift policy as car dealerships like Wilbur Duck constantly compete for work with counties
like Onondaga County. Alternatively, Mr. Antonacci could state that this gift is actually a campaign contribution
and that may be legal- except it was not disclosed which would make Mr. Antonacci guilty of violations ofNYS
Election Law.
Allegation #3: Violation of County Charter - Outside income
On Mr. Antonacci's 2015 ethics form, which he declared to be accurate under penalty of perjury, Mr. Antonacci
stated that he earned between $10,001 and $50,000 in outside income from JD Rotundo Accounting. Mr. Antonacci.,
states this is from sale and consultation. The Onondaga County Charter clearly states, "He [The Comptroller of
,.,
Onondaga County] shall devote his whole time to the duties ofhis office ... " Clearly Mr. Antonacci is not following
the County Charter.
Allegation #4: Conflicts of Interest
On Mr. Antonacci's 2015 ethics form, which he declared to be accurate under penalty of perjury, Mr. Antonacci
states that he earned outside income as an accountant. Mr. Antonacci fails though to disclose his clients. There is
no way for the public to know who JD Rotundo Accounting's clients are, there is no way to know if they do
business with Onondaga County. Mr. Antonacci should disclose each of the clients that JD Rotundo Accounting
serves so that the public can be the judge. If any of JD Rotundo Accounting clients do have business before
Onondaga County then Mr. Antonacci may be in clear violation of multiple policies and/or statutes.

At this time, my associates and I are not willing to disclose our identity as we are in fear of reprisal from Mr.
Antonacci who is known to be petty, vindictive and inappropriate in his conduct. Our interests could be irreparably
damaged by Mr. Antonacci.

ANNUAL STATEMENT OF FINANCIAL DISCLOSURE

u M 1 !015
FOR ONONDAGA COUNTY FOR CALENDAR YEAR 2015 FO
,& . 5
LEVEL I OFFICERS/EMPLOYEES, AND APPOINTED OFFICIA S .._
__. - - - - - - '
.
ETHICS BOARD

Your Name:

::

Robert E. Antonacci 11

(a) Title of Onondaga County Position:

Comptroller

(b) County Department, County Agency, or other County Government Affiliation:

County Comptroller's Office
(c) Present Business or Home Address:
(d) Present Business or Home Telephone Number:.

-L----------------

(a) Your Present Marital Status: if married, please give spouse's full name, including maiden name
where applicable:
Married Michele Duck

(b) List the names and ages ()f any child. For purposes of completing this statement "child" is defined as a son,
daughter, stepson or stepdaughter .under 18 years of age, or a dependent as defined by the Internal Revenue
Code:

(a) "Reporting Category." For the purpose of completing the statement of financial disclosure, no exact dollar
amounts are to be included. Rather, whenever a v~!ue or amount is required to be reported herein, such value or
amount shall be reported as being within one (1) of the following categories:
Category A: $0 ~ $10,000
Category B: $10,001 - $50,000
Category C: Over $50,000
(b) List the location of any real property within the County or within five miles of the County in which he or she,. or
his or her spouse, or his or her dependent child, has an ownership or other financial interest:
Family Member

'

Reporting Category

Location

Michele & Robert

-1-

111;:; u ""' QI"VUQ"'' "' "'"' "' ug u~::JJ~::nu~::m vrmu, rs a m.emoer, omcer or employee, or rn wnran nt= ur l:lllt:, u 1110 uJ ner
1ouse's position, or his or her dependent child's position, if any,_ with the partnership, association, or business:

Family Member
Michele
Robert

Name and Address of Organization

Crouse Hospital
Basketball Offidial

Reporting Category

Position
RN

) List the name of any corporation of which he or she, or his or her spouse, or his or her dependent child, is an officer,
rector, or employee, or of which he or she, or his or her spouse, or his or her dependent child, legally or beneficially
vns or controls more than five percent of the outstan?ing stock, and his or her position, and his or her spouse's
>s.ition, or his or her dependent child's position, if any, with the corporation:
.

..:-.

Family Member

Name and Address of Organization

Reporting Category .

Position

.'

None

) List the name and description of any outside employment from which he or she, or his or her spouse, or his or her
~pendent child, has derived, during the previous calendar year, gross income in excess of two thousand dollars
2,000):
Family Member
Robert

Name and Address of Organization

_Robert Antonacci {same address)
(JD Rotondo Accounting-sale and consultation)

Position

Reporting Categocy

CPA

) List each. source of gifts, excluding campaign contributions, in excess of $1,000, received during the reporting period
rr which this statement is filed, by the reporting individual or such individual's spouse or dependent child from the
ame. donor < excluding gifts from a relative. Include the name and address of the donor. The term "gifts" does not
1clude reimbursements, which term' is defined in item (g) herein. Indicate the value and nature of each such gift: .
Family Member

Name and Address of Organization

None.

-2-

Position

Reporting Category

,i

:~na expencmures m c;;onnecuon Wltn omc1a1 auttes retmt:>ursed by the political suDaiVISIOn, ror wmcn uu::; ::;~t~L~C~ru~:~m nas
:>een filed, in excess of $1,000 from each such source. For.purposes of this item, the term "reimbursements" shall mean
:~ny travel-related expenses provided by .non-governmental sources and for activities related to the reporting of
ndividu~l's official duties such as, speaking engagements, conferences, or fact-finding events. The term
;reimbursements" does no~ include gifts reported undet item (f) herein:
.

Source

5.

Reporting Category

Descript!on

If a reporting officer, employee or appointed offi.cial is not able, after reasonable efforts, to obtain some or all of the
informi:l~ion required by paragraph four of this section, which relates to his or her spouse or household member, he
or she shall so state, as part of the annual disclosure statement.

None

6.

If a reporting of(icer, employee or appointed official practices law, is licensed by the Department of State as a real
estate broker or agent, or practices a profession licensed by the Department of Education, his or her annual
disclosure statement shall include a general description of the principal subject areas of matter undertaken by
such officer, employee or appointed official in his or her licensed practice. If such officer, employee or appointed
official practices with a partnership, unincorpor,ated association o'r corp.oration, and is a partner or shareholder of
the firm or corporation, his or her annual disclosure statement shall include a general description of the principal
subject areas 0f matters .undertaken by .such firm.or corporation. The disclosure required by this section shall not
include the names of individual clients, customers or patients.

Lawyer---Maintains taw license

CPA--Maintains CPA ligense, tax p~eparation, bookkeeping
l

;Is.

1hereby certify under penalty of perjuoy, that the Information dlscl;t~

Sworn to before me this

/~

{}~.

/NotarY PubliC

-3-

Name

I:.

1~

November 25,2015
Onondaga County Board of Ethics
421 Montgomery Street, 14th Floor
Syracuse, New York 13202
Re:

Letter ofNovember 2, 2015

Dear Board:
Please accept this letter as my response to your correspondence dated November 2, 2015
in regards to an anonymous letter submitted to Deputy County Executive Ann Rooney.
The anonymous letter was addressed to Ms. Rooney in her capacity as the purported sole
member of the Onondaga County Board of Ethics and made claims based on a recent
newspaper article concerning disclosure reports filed by a number of County elected
officials. It should be noted my disclosure was the only disclosure publicly submitted
without redaction as a testament to my commitment to transparency.

Background
In the Spring of 2015, Onondaga County Legislator Kevin Holmquist brought to my
attention certain claimed deficiencies regarding the Onondaga County Board of Ethics.
Specifically, his employer, Key Bank, had requested he obtain a letter from the County
stating his obligations as a Legislator were not in conflict with his duties as manager of
the Key Bank branch located in Manlius, New York. Mr. Holmquist reported to me he
had made the request some months prior and had received no response from the Board of
Ethics despite repeated follow-ups.
Approximately at the same time of the Holmquist inquiry, my office was conducting an
audit of the Greater Syracuse Property Development Corporation (the "Land Bank"). As
part of our risk assessment we determined it was necessary as part of our audit to review
filed disclosures of the Land Bank Board Members. Our initial requests were ignored, .
and after repeated follow-up we were eventually advised we had no authority to examine
said disclosures without following the Freedom oflnformation Law ("FOIL").
With the knowledge of the above two incidents, I advised my staff to conduct an audit of
the Board of Ethics, and as is widely reported were rebuffed by the County
Administration.
The Board of Ethics was created by Onondaga County Local Law 13-1990 as authorized
by New York State General Municipal Law 808. General Municipal Law 808
authorizes the creation of boards of ethics by counties and other forms of local
governments. Boards of ethics shall consist of a minimum of three members where at
least one shall be an elected or appointed officer or employee of the county, but a
majority shall not be such elected or appointed officers or employees (GMU 808 &

Section 4.4 of Local Law 13-1990). The law further empowers such boards of ethics to
render advisory opinions to officers and employees pursuant to the written request of
officers or employees of the local government. Section 4.5 of Local Law 13-1990
specifically limits the opinions to be rendered only upon written request by t~e officer,
employee or appointed official concerned with the subject matter. Section 4.9 of Local
Law 13-1990 further grants the Board of Ethics all powers necessary for the enforcement
of the Code of Ethics.
Article Ill of Local Law 13-1990 defines the County's Code of Ethics. The Code of
Ethics establishes a standard of conduct for officers, employees and appointed officials of
Onondaga County.. If lays forth the standard for determining whether conflicts of interest
exist and the manner by which subject officers, employees and appointed officials must
disclose their interests so such potential conflicts may be revealed. Article VIII of Local
Law 13-1990 defmes the form which subject officers, employees and appomted officials
must complete and submit to the Board of Ethics.
'
On or about July 3, 2012, the Onondaga County LegislatlJ!e passed Resolution No. 109,
Standard Work Day and Reporting Resolution. Resolution No. f09 provides the standard
work days for elected and appointed officials. Comptroller has a standard work day of
seven hours, as does the County Executive, District Attorney, County Attorney, and
numerous other positions established by the Charter. County Legislators have a standard
work day of six hours.

On or about August 17, 2015, Robert Durr, Onondaga County Attorney, personally
handed to me the anonymous letter which is the subject of this matter. Mr. Durr informed
me anonymous letters would not be responded to or taken up by the Board of Ethics.
Later that same day, I called Mr. Durr to address the issues in the letter, whereupon Mr.
Durr restated anonymous letters would not be responded to by the Board of Ethics. On
August 19, 2015, an envelope from the Office of the Onondaga County Executive was
addressed to me, Bob Antonacci, with the hand-written message "FYI-from Ann
Rooney" on the exterior of the envelope.
Your Letter of November 2, 2015 states "Section 501 of the Onondaga County Charter
states that the Comptroller 'shall devote his whole time [sic] to the duties of his office
and shall hold no other public office."' There is no statement l am holding another public
office so I will not address that concern.

Analysis
The Onondaga County Board of Ethics lacks the authority to consider claims made in an
anonymous letter. Local Law 13-1990 sets forth the powers and duties of the Board of
Ethics and nowhere is the Board of ~thics empowered to consider anonymous letters or
even initiate its own inquiries. It appears its powers are limited to rendering advisory
opinions, such as the one requested by Legislator Holmquist, and to collect and maintain
disciosure forms.

November 25, 2015

Page2

However, .in the spirit of transparency and as you suggested, I have a differing
interpretation contrary to your preliminary opinion reached without input from me. .
The concern I am not "devoting the whole of my time" to the Office of County
Comptroller is not a concern of a conflict of interest as def:tned by the Code of Ethics and
as such is outside the authority of the Board of Ethics. The claim citing the County
Charters is outside the authority of the Board of Ethics. Assuming arguendo the Board of
Ethics did have the ability to consider this claim, I would proffer f:trst the term "whole of
my time" is not defined by the County Charter, but has since been defined by the
Onondaga County Legislature to mean at least seven hours per work day or thirty-f:tve
(35) hours a week (See Onondaga County Resolution 107 of 2012). Furthermore, I am
only aware of a statutory prohibition on the County District Attorney deriving certain
types of income from private sources.
To the contrary, the disclosure form specifically anticipates private relationships and
investments that derive income or may need to be maintained during an elected official's
time in office. The crux of the issue is disclosure of these relationships so conflicts may
be properly vetted. My disclosure forms comply with this policy for all to see. The
anonymous letter raises no new information beyond which I have disclosed for the past
eight years.
What I do after my regular work hours is only subject to examination by the Board of
Ethics if it creates a conflict of interest. To my knowledge there are no concerns I am
using my position to benefit any of my private relationships. With regard to disclosures
of private relationships, please be advised the disclosure f()rm at question numbered six
specifically states "[t]he disclosure required by this section shall not include the names of
indiviclual clients, customers or patients."
The anonymous letter was a general claim but did name one private relationship of mine.
According to the anonymous letter, "[i]t is a well-known fact that Mr. Antonacci operates
a motor vehicle with dealer plates from Wilbur Duck Chevrolet." The vehicle I drive is
hidden in plain sight at the County parking lot and everywhere else I go. I have done
nothing to conceal my use of this vehicle. To the best of my knowledge Wilbur Duck
Chevrolet has done no work with Onondaga County or any of the municipalities within
Onondaga County. I recognize income (including the use of the motor vehicle) from this
relationship on my disclosure which is included within the income disclosed in question 4
(e) of the disclosure form. Should the law regarding disclosure of all clients, patients,
and customers, be changed to apply to all employees and their spouses, I would be happy
to follow said law.
I would further proffer this question of whether I devote the whole of my time to the
Office of County Comptroller is a political question to be decided by the voters of
Onondaga County. I have disclosed my outside income in the forms of basketball
officiating and professional work in every one of my disclosure forms for the past eight
years. These forms are a public document and are available. It is their availability (rather
than some nefarious scheme or hidden action) that directly led to the anonymous letter.
November 25,2015

Page3

This issue was aired in public by media sources and was an issue in my recent campaign
for Onondaga County Comptroller. The voters answered this political question by
honoring me as the highest vote-getter in the contested races. Had the voters thought I
was not devoting the whole of my time, they surely would not have returned me to office.
This political question was asked and answered.

Conclusion
The Board of Ethics lacks the authority to consider claims brought by anonymous thirdparties. While the Code of Ethics specifically limits the Board of Ethics to issuing
advisory opinions when requested by interested County. officers and employees and to
maintain the required disclosure forms, I have responded to the substance of your letter.
Even if the Board of Ethics had the ,ability to examine the questions raised in the
anonymous letter, the claims are either urif<;>unded or do not create a conflict. For the ,
reasons brought up in my respons.e and illustrated in my office's Audit of the Board of
Ethics, it is clear to methe Legislature needs to reexamine Local Law 13-1990 and
expand the power of the Board of Ethics. I would be happy to assist in any way possible
to craft legislation that will bring greater transparency to County Government and ensure
tax dollars are spent effectively, efficiently, and in the manner intended by the
Legislature.

November 25,2015.

Page4

ONONDAGA COUNTY BOARD OF ETIDCS

. :JOlL'i U. ~lliLR<WtiVICCENTER
421:M6NTGOMERY STREEtt4i1IFLOOR
SYR~CllSE; NEW YORK I:1202

January 4, 2016 .

. Mr. Robert E. Antonacci 11

Dear Mr. Antonacci:

Thank you for your response. dated November 25, 2015, to the letter of the Onondaga
County Board of Ethics, dated Noverilber 2, 2015. In your response, you assert that the Board
lacks authority to consider the claims addressed in the anonymous complaint regarding the
annual statement of financial disclosure you submitte<;l in your capacity :as Onondaga County
Comptroller. It is the position of the Board of Ethics that your assertion is incorrect. Regardless
of the manner in which the issues came to the Board's attention, we retain authority to act on the
issues raised therein. Pursuant to Local Law No. 13-1990, the Onondaga County Board of Ethics
is the repository for completed annual statements of financial disclosure and shall possess,
exercise; and enjoy all the rights, powers, and pnvileges necessary and proper to the enforcement
Of the Code of Ethics regarding the completion and filing of the annual statements of financial
disclosure. It is in the exercise of such powers that we address the concerns raised in the
complaint.

Your expressed opinion is that your disclosure of income earned outside. of the scope of
your position as County Comptroller reveals any potential conflict of interest with the fulfillti:Ient
of your elected duties. You further contend that the completion of thirty-five (35) hours per
week of your duties as Comptroller .is consistent with the requirement that you devote your
"whole time" to the duties of your elected office.
With regard to your outside employment, while we respect your alternate interpretation
of "whole time", we rely on the pertinent provisions of the Onondaga County Charter and
Administrative Code, legislative history, past practice and applicable case law. The requirement
that a duly elected official, such as the Comptroller, devotes his ''whole time" and energies to the
service of his constituency, ensures that official functions are fully performed without diverting
time and energy to the pursuit of any compensated occupation, profession or employment. A
requirement to devote his "whole ti~e" to the. elected office guarantees the public will enjoy the
undivided services of the Comptroller. It is, therefore, the opinion of this Board that accepting
compensation for outside employment, or accepting supplementation, is inconsistent with the
Ononda:ga County Charter and Administrative Code.
With the exception of the elected office of Onondaga County Legislator, which is a parttime position, all other elected county officials are mandated by the Charter and/or
Administrative Code and/or state law to devote their "whole time" to the duties of their offices.
The Charter, the Administrative Code and the Code of Ethics are designed to protect the public
confidence in government. To that end, certain public officers are designated as being required
to devote their "whole time" to the duties of that office. The Office of the County Comptroller is
one such office. Please be advised that, in considering the complaint, the Board of Ethics

Robert Antonacci, II
January 4, 2016
Page2
reviewed the 201 5 annual statements of financial disclosure for the Onondaga County Executive,
District Attorney, Clerk and Sheriff, and none ofthese elected officials reported income from
outside employment or the receipt of any gifts. Yours is the only annual statement that reported
income and other financial benefit from outside sources.
You rely upon Onondaga County Resolution i09 of 2012 in support of your position.
That resolution, however, does not serve to limit the work day to seven (7) hours a day or thirtyfive (35) hours per week. Instead, that resolution was adopted pursuant to a state statute and was
designed to create service credits for earning retirement benefits.
The Board of Ethics disagrees with your alternative interpretation of"whole time", and as
such, ultimate resolution of this matter may lie with a court of proper jurisdiction. Pending any
finding to the contrary, the Board suggests that you discontinue all outside employment.
Thank you for your attention to this matter.
Very truly yours,
Onondaga County Board of Ethics

~~
p. {1-t./Mi/q_

(@

~(.~@
Robert E. Scully, S.J., J.D.

Department
JOhn H. MQI[uY CMc CMt~t.10tl1 Floor

421' MontgorneJy Slr~eJ)Syr;ICU$a. NewYorK 13202

]O:U)!)e M, Mt\~IOU(ly

C.QuntyExeculive.

.Phone;',3l5~435.2t7.0

Pax:$18.43~.57l9'Mun'iclpal/lili9.alibn011U

Fax:3:15A35;21aOFailiily'CourfUnit

WWtv;onr;t>v;tie.t

Jar1uary 27, 2016

Via E!mail anti Hand D.effvety

Robert E. Antonaccl, 11 ,. Comptroller

0.ffi'cef.
fro'11'er.
, . o the
.......eomp
1
Oivr9 Oenter, 1'4 h Floor
421 Montg.o.mery Street
Syrac:use., NewYork. 13202

,R$: E:thics ltlve$tigati<lrt

D.ear Sob:
Pursuant to your letter dated January 151 2:016 and your fo:How.-up .emaU of

January .19, :201 a, please .. be adVised that the County itltends to release the
tnveatigatlon otthe Ethics Bocard pursuant to the FO.ILrequ~st

I have spoken with members. of the Ethics Board, and they consider this an
investigation which had a finding and determination, as' stated in the report which you
Pf$Viotisly received. AccQtding to the Soard, you were- given a full and fair opportunity
to be heard and dtd not $VaH y.our$elf <:lf th~t opportuoity1 Which some member$ -deemed

to be unco,operafive.

By:

Rol:lert A Durr
County Attorney
RAD/nlm