COMMONWEAI IF 1 POLICE CRIMINAL COMPLAINT PENNSYLVANIA. COMMONWEALTH OF PENNSYLVANIA, COUNTY OF:DAUPHIN vs. ‘Magisterial District Number: 12-3-03 ° MoJ: Hon, WILLIAM. C, WENNER DEFENDANT: (NAME and ADDRESS): Address: 5925 STEVENSON AVE, SUITE B ‘STEPHEN _ RUSSELL ____—_REED _ HARRISBURG, PA 17112 Frat Name — Mile Name Laat Kana Bo ‘Telophone: (717)545-0261 212 CUMBERLAND STREET HARRISBURG, PA 17102 NCIC Exiradition Code Type Bi tFooy Fur (14 Felony Wo Bx. Ti Btisdemeanar Lined TIEWisdeneanor Pending Dh2Felony Ld 15 Felony Pen. CeWisdemeancr Surounding States] Distance: T1s-Fetory Surounding States EI AMisdemesnorFul ___C] D-Mlodemeanr No traction ‘DEFENDANT IDENTIFICATION INFORMATION Dacket Number Dato Filed ~~] OTWLiveScan Number | Compainlincidont Number] SID Request Lab Sarees? R215 a7i14/2015 | Torrie" | 43°19 36-13 Dyes C1No enDeR | pos 08/09/1949 _[ po SHIPPENSBURG, PA ‘Add 08 —[ee-botendantsy 5 | Ba Mate FirstName Mae Name LastName Gen, Female | aka _ STEVE REED RAGE Ea wie “iar Caea TI Nive nee Titainarn > ETHNICHY C1 ipo Tifetispane Titian HAIR COLOR Borv Gas) CireD(Reanven) — ClSv Senay Catv oy Tete Pani) Cher omy Dlarxceiech Conc orange) Elway Chrooc unkseas) — CoRN (Green) Cpa i) ain onde svantery) EVE COLOR That (ea Chow i) BEBRO ron) lean Greeny Terrien _ Chic taco) Caan avon) Cea Dime arises C00 usknc) Driver License _| statoPA [License Number 14809417, Expires: 08/10/2015 WEIGHT (lbs}) DNA Des INO | pwatocation _ 150 FBlNumber | 359630FB5 [WU Nambor FL_HEIGHT tn Defendant Fingerprinted [JES BNO _ _ 5 10 FlogorrntClatelfiations | DEFENDANT VEHICLE INFORMATION ~ ‘Slate | Hazmat | ~ Registration somm'i Veh. chook ‘ih, NIG Veh, Code] Rag. iwte#GB00007 | ‘pa’ | “CT | sucker — / | ma OO] See" oo same ‘VIN | ‘Year | Make ‘Model Stylo Color G ‘a8 Def L CHEVY, EO! Uy - 8 Office of the attorney for the Commonwealth CI Approved [1 Disapproved because: (he atfomey forthe Commonwostth may require that the complain, gee warrant alidavit, ox both bo approved bythe atornay for the Commanwaalh lor Cae conRee eam de lb Bie DAG CLARKE H. MADDEN (Nae fe stoma the Conmanwcaly ‘Spat ait Corer) pon 1, INSPECTOR CRAIG S. LECADRE 902 = Ze (Name ofthe At) . PSPMPOTE-Aecied Mant Nini ase — of PA OFFICE OF ATTORNEY GENERAL 0222400 {ently Department or Ajoey Ropes ed and Fazal Sian) — Paice Age ORT ROTO do hereby state: (check appropriate box) 1. Bl accuse the above named defendant who lives at the address set forth above 1D J accuse the defendant whose name is unknown to me but who is described as. 1 accuse the defendant whose name and popular designation or nickname are unknown tome and whom | have therefore desianated as John Doe or Jane Doo with violating the penal laws of the Commonwealth of Pennsylvania at SIDMSOTCOOR. ~PRCE-PORICAT SUBIR ——— in DAUPHIN County £1 onorabout (County Codey OPC 442A ~ Rev. 09/12as POLICE CRIMINAL COMPLAINT Docket Number: Date Filed? | OFNiLiveSean Number Complainvineident Number | 28-15 07/14/2015 | T 676764 43-1036-13 | Defendant Namo | Fist Tier Task N STEPHEN RUSSELL REED 2. ask that @ warrant of arrest or a summons be issued and that the defendant be required to answer the charges | have made. 3. | verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief This verification is made subject to the penaities of Section 4904 of the Crimes Code (18 Pa.C.S. § 4904) relating to unsworn falsification to authorities. 4. This complaint consists of the preceding page(s) numbered __ through _. “The acts committed by the accused, as listed and hereafter, were against the peace and dignity of the Commonwealth of Pennsylvania and were contrary-o the Act(s) of the Assembly, or in violation of the statutes cited. (Before a warrant of arrest can be issued, an affidavit of probable cause must bo completed, sworn to before the issuing authority, and attached.) (@ate) 2 Leg” fon AND NOW, onthisdate July 14, 2015 | ceriy that the complaint has been properly completed and verified, ‘An affidavit of probable cause must be completed before a warrant can be issued. 12-3-23 \we-) < i Distt Court Number) “Testing Acar) AOPC 412A — Rev. 09/1248 POLICE CRIMINAL COMPLAINT Docket Numbor Date Fed | OTWiLiveScan Number Compfaintincident Number LL CR28-15, 07/13/2015 T 676764~4 43-1036-13 First: i ast Defendant Name STEPHEN RUSSELL REED ‘The acts cominitted by the accused are described below with each Act of Assembly or statute allegedly violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically inchoate | Ll attempt TT Soictation i Conspiracy [Offense | feoora se0024 rece O [or [oir B(2)(3) [eitte [18 CSA 2. [rt | Laer “ofa et —— "Sion Px Sis (as) Camis —s05 WOE Gena Cae — WORNERS Cae PennDOT Data] —Accient 5 roar | eet Ti inerstato 1 Saety Zone i Werk zone Salute Description (include the name of stalule or ordinanos) Comat Orsanzalins [ Tnchoate] CY Atompt Ti Solctaton Ti Gonspirasy - ] Offense _| — oor Yeo _ |e raao8! J O [oz [sit A (12) [ore [ascsa [2 - | sect Ofte Sst; sen ~~ “PRS [oa NGI Oana 6s — Ton PonnDOT Data] Acciont (appiieabiay | nonter _ interstate Safety 2000 Cl Work Zo00 Statute Description (include the namie of statute or ordinance): Dean in Poised of Uw Aaties inchoate | Cl Atop? Ci Sonctaton Ti Conspiracy 7 Offense | — 109074 tooo : ‘e308 O [03 | 3922 [aq [ort [ascsa [2 Pl eae oss Sieg — sass PA Sais TNS] Caas ~ — Ges NS Osa Came — VERNER Cas — PonnDOT Data —] Accident camper bas | Asien i inersate UD sely Zo Tl werk zone Statute Description (include the name of statute or ordinance): Theft by Deception ‘Set fora bref summary of tie facts Sifcint to aavive tho defendant of the nature of he oensla) charged A caton tothe Hataa(e) aTegealy Wlolated, without more, isnot sufficient Ina summary case, you must cite the specific action(s) and aubsoction(s) of the statutes) or raiars(o) allegedly violated, The age of the victn at the ine ofthe offense may bo Included f known. in adtton, sacal soeusty numbers std nance! information | (e.g, PINs) should not be listod, ithe Ident ofan account must be estlished it ony the last four digits 204 PA Code $6213. = 210.7 Acts of the accused: 4, That on and about diverse dates from December 24, 1990 through January 2010, the Defendant, @ person, uniawfull through a pattem of racketeering activity that includes but isnot imited to acs which are inditable under Chapter 47 (eating to bribery and corrupt infuence) and Chapter 39 (relating to theft offenses), acnuired or maintained, recy or indteciy, any interest In or contol oF the enterprise then knowm as The Harsburg authority. On er ‘bout diverse dates from December 24, 1990 through January 2010, the defendant, a person employed by or associated with te enterprise, partes, ether dirty or indirectly inthe conduct of The Harrisburg Author's affairs through a pater of racketeering actives that includes but not Ried acts which are incictable under Chapter 47 (relaling to bribery and coruptinfience) and Chapter 39 (relating fo theft elenses) 2. ‘On or about diverse dates from January 1, 200 through September 7, 2007 the defendant conducted a financial transaction with the knowedge thatthe Broperty involved, including stolen or legally obtained property, represents the proceeds of unlawful activity, the defendant acted with the tent to promate {the carving on of the unlawful activity. On or about civerse dates between May 18 and May 31,2015, the defendant conte a finance transaction Involving consigning 20 firearms to acetal establishment in Gettysburg with knowledge thatthe property involve, Ince stolen or legal cbtained broperty, represented the proceeds ofan unlawful act and thatthe transaction was designed in whole of In part to conceal or disguise the nature, location, Source, ownership or contro of the proazeds of sald uniawful ativty by use of monies urfawfuly obtained fromm the City of Harsburg and the Haisouny ‘Authority and by dealing in stolen property obtained with those monies, '3._On or about September 2003, the defendant intentionaly obtained property wth a value over $500,000.00 from the Hartsburg School District by deception with respect to the ising costs of ts 2003 debt offering. On or about various dates from May 2000 tolanuary 2010 the defendant ntenvonally | ‘obtained property With a value over $500,000.00 from the Harrisburg Parking Authority by deception by transfering montes into the special projects fund, DPC 412A — Rev. 09/12a8 POLICE CRIMINAL COMPLAINT Docket Number: Dao Fed: OFNiLiveScan Number ‘Complaintincident Number Ree15 | 07/14/2015 T 67676 43-1036-13 First: ~ Middle: ~ Last: Defendant Name STEPHEN RUSSELL REED The acts committed by the accused are described below with each Act of Assembly or statute allegedly violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically. (Bet forth abrir summary of the facts suficient to advise the defendant of the nature ofthe offense(s) charged, A ellation fo the statute(s) allegedly Violated, without more isnot sufficient Ina summary eas, you must ete the zpecific section(s) and subseetion(s) ofthe statutes) or ordinanen(s} allegedly violated. Tho age ofthe vet at the time of tho offense may be Included f known In adeltion, social seounly numbors and financial information (6.9. PIN) shoul! not be listed. the identity of an account must ba established, list only the last fur digits. 204 PA.Code $§ 218.1 213.7) inchoate | LI Atiompr Ti Solictaton [Drees - Offense _| 1890" : ieo0za toa ; G [o+ [3022 [A@) _ [ortte [18 csa 1 ([F3 Leet, “oma ——~Saeiay — “se PASE (i) — Gas ede — WD CaaS TERNS PennDOT Data | Accident memos see | sce | Ones | Geet] Chveznw ‘Statute Description (include the name of statute or ordinance): Theft by Deception Ais of the accused associated with this Offense: On or about diverse dates between June 2008 and December 2008, the defendant intentionally obtained or withheld property of the Cty of Harsburg , by deception in an amount In excess of $2,000.00 and less than $200,000.00 with respect to Invoices submitted for travel relnbuisement. Tnchoate | Ei Atempe Ti Seitation - Ti Ganapiacy Offense_| ~ 100014 even aso 7 G [os [3922 Jaq) forme Jiscsa [a F2 : Lease Oemast—_— Sasa ——" “Sica PAS Ci] — Cui —— als — Wei sas Cae — DONATE Vaamnoane | acauet i ertto Disatiy2an0 | CWozono | Statue Description (include the name of statute or ordinance): Theft by Deception . ‘Acts of the accused associated with this Offense: On or about diverse dates between 2004 and December 2006, the defendant intentionally ‘obtained or withheld property ofthe Gty of Harisbura by deception in an arnaunt in excess of $100,000.00 and less than $00,000.00 with respect to ‘expenses forthe National Sports Hal of Fame Foundation. inchoate | CT Amt Toten Offense | 199074 Hoon ; © [06 [a7or [ad [oti [ascsa [7 [FS 1 Leo onan — seas — "i 2A Site Te] — aa eae” “NO Oma me — URS cae PennDOT Data] Accident ° Coe | atent [Crista Cisutayzen0 [Ch wazone ‘Statute Description (inciude the name of statute or ordinance): Bribery in Official and Poltical Matters: ‘Acts of the accused associated with this Offense: On or about dverse dates bebween October 1999 and December 33, 2003, the defendant ‘offered, conferred or agreed to confer upon Richard House the poston as "Director of Community Relations forthe Harisburg Senators Baseball team as ‘consideration for the decison, vote, recommendation or other exercise of official cscetion by the recipient In ajuda, administrative or legsatve proceeding. On or about diverse dates between 2003 and December 14, 2005, the defendant offered, conferred or agreed to confer upon (6) members of Farisburg éty councl a beneft as consideration for their decision, vote, recommendation ar ater exercise of offical disretion by the redpient in a judical, administrative or legiatve proceeding \OPC 43.2A— Rev. 09/12 Page ofas POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: — ‘OTN/LiveScan Number ‘Complaintiincident Number 28-15, 07/14/2015 T6767 43-1036-13, First wid ast Pefendant Name | STEPHEN RUSSELL REED The acts committed by the accused are described below with each Act of Assembly or statute allegedly violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically. (Sot fort a brief summary of th facts sufcient to advise the dofendant ofthe nature ofthe offense(s) charged. Action to tha statuto()alogealy lated, without more, snot sifciont.n a summary case, you must ete tho specific section(s) and subsections) ofthe statutes) or ortnanec{s) allegedly volatod, The age ofthe victim a the time of the offense may bo included f known. In adatlon, social secur numbars and finance! nfermation {c.g PINs) should not bllsted. I the Monty ofan account must be established stanly tha last four digits. 204 PA.Codo g§ 218.1 218.7), Inchoate | [) Attempt TI Sollettation C1 Conspiracy Offense | 13001 sen 13503, O [or [4113 18 CSA 158 | m-2 seas“ Oteneat So PA Siuis (TR Co__ GSS WEIS OFanea Coa —UoRATBRS a PennDOT Data ‘Accident | “ (ifapplicable) ‘Nurnber Di interstate Safety Zone (Cl Work Zone: ‘Slatule Description (include the name of statute or Ordinance): Misapplialion of Eneusted Propary and Propeny of Govamment or Fenda Instutons ‘Acts of the accused associated with this Offense: On or about January 2000, the defendant Gsposed of property of the government (see ‘Attachments, B and C), namely the Cty of Harrisburg in a manner which he knows is Unlawful and involves substantial sk of lessor detriment to the ‘owner of the property or toa petson fr whose benefit the property was entrusted. Tnchoate | CI Atompe Tr Salicaton TiGonspiracy Offense | 18007A 189024 19003 © [os |4910 A(t) Jotthe'[iscsa [a M2 taser “Ore ay Sse PAS THS|_—_ Cou — Gadi NOI Ona ce UGB Oo PennDOT Data | Accident eames | Ae i Irorstate U1 Setety Zone Work Zone ‘Statute Description (include the name of statute or ordinance): Tampering with or Fabricating Physical Evidence ‘Acts of the accused associated with this Offense: On or about dverse dates in May 2015, te defendant balleing that an offidal proateding or investigation was pending or about to be instituted, he altered, destroyed, concealed or removed any record, document or ting with intent to impale Is verty or availabilty in such proceesing or investigation by attempting to dispose of evidence by commercial Sale ata real establishment In Gettysburg, I Inchoate | [1] Attempt 0 Solicitation Di Conspiracy” Offense | — 189074 1e902A Yaoee Q [09 [ai07 A) ferme [18csA [1 M2 Least “omar es ——— ses ASS [e)” Counts Gags NOE Oss 5s" UGRNUBRS Code PennDOT Data] Accident Wrempbeaeie | aaaet Ti inerstate Cisaeyzom [Ch Workzone Statute Description (include the name of statute or ordinance): Densptive Business Pracices ‘Acts of the accused associated with this Offense: On or about September 2003, the defendant, in the couse of business, made or duced ‘others to rely on false or misleading writen statements with respect to the dosing cats ofthe Harishurg Schoo! District 2003 debe offering for the purpose ‘of promoting the sale of secures or omitted information required by lw to be discosed in writen documents related to secures. AOPC 412A — Rev. 09/12 Page of+a POLICE CRIMINAL COMPLAINT Docket Number Date Filed OTWLWeScan Numbar Complaindineident Number BS 07/14/2015 | _T 676i 43-1036-13 Fist Wadia 3 PefendantName | STEPHEN RUSSELL REED The acts committed by the accused are described below with each Act of Assembly or statute allegedly violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically. (Set forth a brief summary ofthe facts sufiiant to advise the defendant ofthe nature ofthe offenses) charged. A cltalion tothe statute(s) allagedy Violated, without more isnot sufficient. Ina summary eae, you must clte the specific escton(e) and aubesetion() ofthe statutes) or erlinanes(s) allegedly Violated. Tho ago of tho victim atthe te ofthe offense may be Included If known. In adition, socal securly numbers and financial information {0.g. PINs) should not betiste, Irth identity of an account must be established lat only the last fou digits. 204 PA Goda $§ 2131 219.7). Inchoate | [J Attempt Bi Solicitation TiGonspiracy Offense | 18900A 18902 16.903, 902 ‘tthe | 18 CSA 3 M-2 Sain PA Sia ia] Coune NGIC Offense Case UCRNIERE Coe sanDOT Data 7 i applicable) Ci inerstate Di sutety Zone Work zone Statule Description (include the name of statuie or ordinance): Criminal Soldtavon ‘Acts of the accused associated with this Offense: On or about August 17, 2004, the defendant, wit te tent of promoting or foclitating ts ‘commission, he commanded, encouraged oF requested another person to fkify a lave record fr Rchard Pickles, On or about August 3, 2005, the defendant, withthe intent of promoting or facltating its commission, he commanded, encouraged or requested another person to falsy’@ leave recoed for Richard Piles, On or about February 12, 2007, the defendant, withthe intent of promoting or faciitating Its comission, he commanded, encouraged or requested another person ta fala a leave record for Richard Pckes. ‘inchoate [1 Attempt Ti Solicitation Teonspiracy Offense | 185014 189024 16.903 B [11 [3925 ‘ofthe | 18 CSA 29 F3 Lead —oneat Sean Saeaton PASiauia Wa] Couns Gaga ~ NCTE Ofenas Gade USRUBIS Cae PennDOT Data | Accident fty Zone lork Zone ‘ifapphicabiey Nanber interstate Safety Zo Work Zon Siatule Description (include the name of statute or ordinance): Taft by Receiving Stlen Property ‘Acts of the accused associated with this Offense: On or about diverse dates from April 2015 to Jane 2015, the defendant intentionally received, retained or disposed of movable property (see Attachment A) of the Cty of Harsburg knowing that it Rad been stuen, or believing tat ithad probably ‘been stolen, Tnchoate | 1 Atompt Ti Sofcitation TH conspiracy Offense | 139004 189024 18.908. O [12 | 3925 ofthe || 18 CSA 110 | Mt Leas? __Oiaast Sion ‘Stes PAS (Tia) _— Counts Gea ie Ofenan Code UGRAINBRS Gade PennDOT Data | Accent interstate ‘one lek Zone (if applicable) Number interstate C1 sstety 2 Cl wWork zo Statute Description (include the name of staiuie or ordinance): Theft by Receiving Sklen Property ‘cis of the accused associated with this Offense: On or about diverse dates from Ap 2015 to une 2015, the defendant intentionally received, ‘eained or disposed of movable property (see Attachment 8) ofthe Cy of Harsburg knowing tat Ie had Been stolen, or belleving that t had probably been stolen,288 POLICE CRIMINAL COMPLAIN Docket Number Data Filed: | ~~ OTNLiveSean Number Complainutaci R8-15, 07/14/2015 | T6767 43-1036-13 _ Fist Wide Last Defendant Namo i STEPHEN ___| RUSSELL, ___| REED The acts committed by the accused are described below with each Act of Assembly or statute allegedly violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically, (Set forth a brief summary of tho facts suficient to advise tho deondant of the nature of tho offenees) charged, A citation tothe statues) allogody ‘violated, without more isnot sufcont. Ina summary case, you must cife the specific scton(s) and subsection} ofthe statutes) or vainanee(s) allegedly violated, The age of the victim a the time of the offense may be included if known. In edition, social securty munibors and fnancll Information (6.5. PINs) should not bo iste. If the Identity of an account must be established, ist only the les our gis, 204 PA.Gode $§ 218.1 213.7) [ inchoate [T Attempt Ti Solicitation. — Ci Conspiracy ~ Offense _| ~ /000"A sean 10003 O [13 [3925 ofthe. | 18 CSA [20 [F2 Leos? ORR Secon Babee PA Se To} — Gomis — — Sade C16 Oense Code UCRRIBRS Came PennDOT Data] Accor ‘appicabioy | Nant | Clinaiste [Ed satayzone | C1 Warczone ‘Statute Description (include the name of statute or ordinance): Theft by Receiving Stolen Property ‘Acts of the accused associated with this Offense: On or about diverse dates from Apr 2015 to June 2015, the defendant intentionally received, retained or disposed of movable property (see Attachment C) of the City of Harsburg knowing that Had been stolen, or believing that It had probably been stolen, Inchoate | [1 Attempt [Paes Ti Conspiracy Offense _| ~ /090"A yoann _ 18905, O [a4 [3026 [tte Tas csa [3 F3 Lect OR ——_ Seas ——~— sro Sains] Cans Gas WiC Of aa — USERS Tals PennDOT Data] Accident FembOt Oats [Asian Cie | Esstyzom [Wenz | | Statute Description (Inciude the name of statute or ordinance), Thet of Series ‘Acls of the accused associated with this Offense: On or about May 10-17, 2004, the defendant who had contol over the disposition of services of others to which he is not entitled, knowingly diverted the services of Richard Piles to his own benefit orto the beneft of another nt ented thereto ‘On or about July 8-17, 2005, the defendant wo had control over the dspostion of services of aters to which he isnot ented, knowinaly diverted the ‘Serves of Richard Pickles to his own beni orto the benefit of another not entitled thereto. On or about November 29-Decemiber 13, 2005, Une defendant ‘who had control over the disposition of senvces of others to which he Is nt eed, knowingly verted the series of Richard Pikes to his own bene Or {0 the benefit of another not entitled thereto, Inchoate | TJ Attempt Solicitation Di Conspiracy Offense_| 1090" foo [Preset _ o [15 [3021 i ie [18 CSA [29 | F-3 Lado “Ofiasat —— sani —"— saan Bi San — aa — ee oi CoS Cae PennDOT Data] Accent Femoor bua [Aiea Gras | elesepene |G wouca Statute Description (indlude the name of tafe or ordinance) Tel by Unlawal Tting or Dspction ‘Acts of the accused associated with this Offense: On or about January 2010, the defendant exercised unlawful control over movable property (Gee Attachment A) ofthe Cty of Harisburg with the intent to deprive the cty thereof. L (OPC 4124 ~ Rev. 09/12Ey POLICE CRIMINAL COMPLAINT Basket Number Data Filed: ‘OFiiLiveSean Number Complaintineidant Number R215 o7piaja0is | 676764 43-1036-13 First: Wiad ast Defondtont Nemes STEPHEN RUSSELL REED The acts committed by the ‘accused are described below with each Act of Assembly or statute allegedly violated, if appropriate, When there is more than one offense, each offense should be numbered chronologically. (Set forth a bref summary of the facts sufllentto advise tho defendant ofthe nature of the offense(s) charged. Acton to tha statuo(e) allogodly ilated, without more, is not suficent Ina summary ease, you must cathe specie section(s) and subsections) ofthe state(s) or ordinancele). edly Violated The go of the victim atte time ofthe afense maybe tncluded if own. In ado, social sxeunty numbers a inanctal Information PINs) should not be sted. f the identity ofan account must be established, ist only the lat four gts. 208 PA.Code 66 2121 218.7) inchoate | TI Attempt Ti Soliekation Ti Conspiracy Offense | 189074 12902 18503 O [16 [3921 ofthe: | 18 CSA 110 [Mt Lea — OFerae in ‘Satan PASS (Ti) — Counts Gado WIC Ofenes Coda _—JORNIBRS Coie PennDOT Data | Accldant epee ttt Aecident interstate Li satety Zone Work Zone Statute Description (Include the name of statute or ordinance): Theft by Unlawful Taking or Dispostion ‘Acts of the accused associated with this Offense: On or about January 2010, the defendant everclsed unlawfll control over movable property oF the Gty of Harisburg (see Attachment B) withthe intent to deprive the Gty thereof. Tnchoato [TI Atempt TT Sottation Ty Conspiracy Offense _| 16801 tes02A e003 © [47 [3021 atte liscsA [20 [2 Lost “oes saa PASuiie TW] Couns Gade N03 Ones Cade — DORNER ase PennDOT Data Accident Trereaate | ete C inertto i saety Zone Tl work Zone ‘Statute Description (Include the name of statule or ordinance): Theft by Unlawil Taking or Dispstion ‘Acts of the accused associated with this Offense: On or about January 2010, the defendant exercised unlawful control over movable property of the City of Harrisburg (see Attachment C) with the intent to deprive the ety thereof inchoate] Ty Atompt Ti Sotetaton Ti conspiracy Offense | 18507A ras024 ass a ofthe Loser Daa ten Sa Pais Re — Cas TG Oa ade UCR Ce PennDOT Data] Acciant tote | ae Di irerstato Satay Zone iWork zone ‘Statute Description (include the name of statute or ordinance): ‘Acis of the accused associated with this Offense: SPC a128—Rev. 09/12 ee Page of48% POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: ‘OTWiLiveScan Number ~ | Complaintincident Number 28-15 | 97/14/2015 | _T 67676 43-1036-13 _ First waddle Last DefendantName: | STEPHEN ——__| RUSSELL REED _ AFFIDAVIT of PROBABLE CAUSE Your Affiant, Inspector Craig S. LeCadre, Pennsylvania Office of Attorney General (hereinafter: OAG), being duly sworn, deposes and says: Your Affiant has been conducting an investigation of allegations of public corruption involving the City of Harrisburg and many of it's ancillary governmental entities which includes but is not limited to The Harrisburg Authority, former owner of the Harrisburg Resource Recovery Facility (incinerator). The OAG's investigation has utilized the 37th Statewide Investigative Grand Jury seated in Allegheny County under Presentment No. 21, same accepted by order of the Honorable Norman A. Krumencker, III, Supervising Judge. This Presentment, attached to this affidavit and incorporated herein by reference, recommends charges to be filed by the Attorney General or her designee, against the defendant, Stephen R. Reed. Additionally, there are three attachments to this affidavit which are referenced as “Attachments A,B and C", respectively. Your Affiant has reviewed the above cited Presentment and having been present at all proceedings, finds that the factual findings described therein correspond to the OAG Investigative findings. Your Affiant has reviewed the sworn testimony given by the witnesses before the Grand Jury and finds that itis consistent with the information contained within the Presentment. Your Affiant has reviewed the evidence presented to the Grand Jury and finds that it comports with the results of the OAG investigative efforts and findings as to the allegations contained in this instant criminal complaint. Your Affiant states that based upon the above facts, there is probable cause to believe that the defendant, Stephen R. Reed, committed the acts alleged therein, in violation of Pennsylvania law and respectfully requests the issuance of this warrant of arrest. 1, CRAIG S. LECADRE, BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY THAT THE FACTS. SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. Poo- (Signature of Aftant) ‘Sworn to me and subscribed before me this 14 day of shay 2015 TAS Date we Joe - Macitoig Rlulge Sey My commission expires first Monday of January, Alb ey oe COUR GS TERS rig AOPC 4116 ~ Rev, 07/10 Page 1 ofAttachment Aowisgs | Que RTE Wasa ei wElonirrae meet Tsanaooo | _w_ [19953161 08/18/01 | Bronze (Cowboy on Bucking Bronco) si920000 | w [2001873 4/10/95 _| Ford's Theatre Bill, Lincolt’s Asassination night 314900 [ NCWM | NEWNE-00215 [ 05/25/00 | Spanish Armor _ $14,000.00 w | 2001231 1995 | Single colt action i'd Marcelina Baca $12,000.00 Ww | 1995.66.1 02/01/96 | Set of 4 Stagecoach Hamoss - $10,000.00 W | 1996.142ad 15/1995. | "Low Wallac Set* s3,so000 | Newm |Newwco0391 | 11/01/00 | #10 Saloon; Deadwood, SD items 3750000 | Ww | 20001018 11/01/95 | Anchor deseribed and copy of cet. authenticity $7,050.00 w | 1995478. Tain | Rae Re, War Caen Cs FES URE T5599 | Con | 08/01/01 | Vanipire Hunter's Set 36,500.00 | Misc 03/04/95 | Tombstone Epitaph, June 15, 1880 $4,900.00 wa |1995.62.7 03730702 | Hanging Rope and Knife of SP. Vigilante Commitee sas0.00 | Ww | 2003389 09720199 | 1890 Large Gaming Wheel 4,000.00 w | 2000.65.146 11/1298 | Morgan Earp Door Frame $3,500.00 w |is98887 (01/28/97 | Geronimo by Mary E. Fly Tombstone, Arizona Terr 1903 $3,500.00 wa |199751.1 10/01/96 | Union Pacific Mounted Ranger Set (4 pes) $3,000.00 w | 196.101.1084 (08/26/02 | Adobe Walls Knife With Letter Of Provenance $3,000.00 w | 2002.213.18 08727199 | Texas Str Gun-Knife Rig $3,000.00 w | 2000.63.18 01/14/00 | Pistol, Colt, Dug up relic 7 52,800.00 we | 2000154 (05/05/00 | Pharo Table, Portable _ $2,700.00 w__| 200.254 (02/01/96 | All Metal Wells Forgo Express Box $2,500.00 w | 1996146 72718794 | Sacramento Newspaper Jul-Dec 1861 ~- [$2,500.00 wa [1994818 1103/98 | Chum Razor & Mug — $2,500.00 w | 1998.89.8 05/05/00 _| ‘Tombstone Tobias Set $2,500.00 W__| 2000.29. 05/05/00 | Knife, th Cav. Little BigHom Relio $2,500.00 w_ | 2000.60.12 11/01/97 | Missouri Convicts letter $2,376.00 wa | 1997458 (08/27/01 | Wells Fargo Knife & Pistol (Smoot) 3220000 | W | 2001.70.29 05/05/00 | Cavalry Saddle Set ~ | $2,000.00 Ww | 2000392[ vow00 | wettsFarg Seales $2,000.00 | w | 2000.101.10Attachment B1998.44.17 08/11/98. | Memoirs of S.P. Allen, 1870-80 under G, Crook Sth Calvary | $1,900.00 WA 08/27/01 | Saloon #10 Spitoon & Chuck-s-Luck $1,800.00 Ww | 2001.70.50,b 09/24/99 | Bowie Knife, th Cavalry $1,800.00 w | 199.502 O72 T106 _ __| $1,600.00 Ww _| 2006262 8/08/95 _ $1,500.00 W | 19952903 (08/08/97_| Crystal Palace liquor license $7,500.00 | WA} 1997.35.1 owa002 Ghost Danse Bendod Medicine Pouch & Chular wide yop 09 w | 2002221.13 08/1295 | Gun § _____| $1,500.00 W | 1995.51631 (08/12/95 | Smith & Wesson Tip up wibullets $1,500.00 | W__| 1995.516.63 (08/21/02, | Cross Bow $1,450.00 W [200221543 06/15/95 | Colt Bisley Model 5-1/2 barrel 32-20 cal wistag grips 1,400.00 W | 1995.180.1 05/05/00 | Photograph, Sth U.S. Infantry Ft. Keogh, MI Terr $1,350.00 WA | 2000315 [11701797 | Hugh Beckwith Court Findings 31,327.00 WA | 1997.45.6 1/0u97 am Rynerson letter ___[s1327.00_ [wa _|1997.45.5 08/17/95 | Cheyenne Indian bag $1,300.00 w | 195,308.17 (09/01/97 | Indian expedition letter - $1,238.00 | WA [1997315 12/18/94 | Sacramento Newspaper Jan-Tune 1882 1,200.00 WA | 1994815 12122194 | Tombstone Epitaph (19th Century) $1,150.00 WA | 19949.130 03/21/02 | Apache Holster & Matching Knife Sheath $31,100.00 w | 2002.35.20, 09/01/97 | election certificate $1,054.00 WA | 1997312 08/11/98 | 7th Calvary Marching Photo $1,050.00 WA | 1998.44.50 08/08/97 | Stereoview of Clum & Indians $1,000.00 wa | 197352 Arapaho Fully Beaded Sheath W/Knife (Scarce On Rawhide) | $1,000.00 w | 202.221.1746 04/11/02. | "Billy The Kid" Circulated Poster $81,000.00 wA | 2002.70.1 tiosie7 | Sib0x Chik Lave Fate, Yew Bll Cloud TRIS 5955.99 wt isozana 11/03/97 | Navajo Chief Manuclito & his Tribe, ca 1865 albumen, $950.00 wa | 197.472 [11712797 | 3 original photographs €1890 of Crow Indians $925.00 WA | 1997.53.06 05/05/00 | Strong Box, Stage $900.00 ww | 2000.59.56 08/11/98 | 7th Calvary Photo 5900.00 WA | 1998.44.40 ik | Confederate "bowie" marked "CSA" State of Georgia $900.0 ‘NOW | NCWM-00264 11/13/98 | Buffalo Beaded Bag wipipeknive $900.00 Ww | 1998.87.261297 original photograplrof outlaw Al Jennings c1915 $875.00 wa | 197534 07727006 | Andirons (239) = $850.00 w | 2006.28.1 09/2499 | Bear Head dress ea) w | 199.402 onosns [SRE NESTA TAHA ROTAT TAT IAT Yoys.qg | w sssten 02/13/95 | Indian Buffalo Hom Rattle 3800.00 W | 1995333 08/1295 | Badge US nd police $800.00 w | 199551652 canons | Na Daa HAT RTPI | s9oy | yaa 08/1295 | Apache Shoulder Bag wikaife 300.00 | _w_| t995.5t6a6 {09/04/95 | Stetson Hatin box [8750.00 W_| 195.3353 _ 12/05/02 | Genuine Porter Saddle $750.00 w | 200.21 osroams | Photograph Indian Sky Ranch fer Apasie Aiack, Randal, T7555 | Wa | gos. t4ais0 10/02/98 | 1896 Indian Tenory Bill Doolin Gang {#700000 WA _| 1998485 05705/00 8700.00 Ww | 2000.29.17 TA697 $650.00 WA__| 1997423 02/22/02 | Whorehouse Box W/Pinfire Revolver $650.00 w. | 2002366 09/2499 | Green Chest (#200) ; 8637.00 w_ | 1999345 05/05/00 | Dice Drop with ol Dice $625.00 w | 2000478 11/01/95 | Pistol in Book $3600.00 ww | 1995.475.t7a 09/03/98 | San Francisco Cased Dagger $3600.00 w | 1998.41.24 10/07/02. | Gambler's Gun $550.00 ww | 2002,168.1 08/11/98 | Crow Foot, Sitting Bull's son, Bury photo $550.00 wa | 1998.44.11 11/12/97 | 2 original photographs of Sioux Indians 01880 $525.00 WA | 1997.533ab 08/08/97 | 1898 Al Jennings Signed check (Okla outlaw) $500.00 wa | 1997.83 | 06/2995 | Sioux or Cheyenne War Trophy knife === $500.00 w | 195.2181 01/28/05 | Original Photo Roswell, NM/Gen, Lee $484.16 ww | 2005.11.24 09/01/97 | Mormon polygamy leter ; - 3478.00 wa | 1997316 05/05/00 | Photograph, Bill Dalton & Marshall Lidsey $450.00 wa | 2000444 08/20/01 | Sombrero wiSilver Hat Band 3450.00 w | 2001.805 (0770601. | Bedu Mask - Gurunsi Tribe, Rep of Upper Volta ‘$450.00 ‘AFAM | Citylist02/01/96 | Wells Fargo Mail Bag $400.00 w | 1996.14.56 : 02/0196 | Wells Fargo Mailbag $400.00 Ww |i996145ab | 07727105 | Rug, Two Grey Hills ; 400,00 w [20053638 | 11/14/98 | Platform scales weights $400.00 Ww | 198.9430 10/01/95 | Tndian beaded holster for colt lightuing pistol $400.00 w | 195.4169 i (08/08/95 | Possee photo " [$400.00 wa | 199529228 | 11/01/97 | 1865 Kansas Lever 7 $397.00 wa fiszasa | | 09720799 | Green Spitoon from Oriental Saloon in Tombstone $385.00 ww | 2000065.138 [ 08/11798 | Cody Fire Dept w/Buffalo Bill 1907 $575.00 Ww | t998.449 05702795 | photograph, Railroad track laying crew, Hinze photo, famed | 837500 | WA | io9saa7e | 11/0197 | Indian-Mining payroll - sooo | WA | 1997457 | oa06i95 ‘Newspaper, Daly Denver Times, July 19, 1881 "Billy The | 56559 wa liso. | i 08/21/02. | Texas Fighting Knife $360.00 W_| a00017230 10/03/06 Cowboy Bathtub: _ - $350.00 | Ww | 200647. 8 ! 05/03/00 | Photograph, Lawman R. Ewing w/Body $350.00 WA _| 2000.44.15 11/1697 | Albumen 3 Apache women photo - $325.00 wa [iar || i TI/A6(97_[ Tndian women wichild by Parkeriphoto $525.00 WA_| 197425 ! 03/01/02. | Copper Ladle $318.75 w | 2002432 01/15/03 | Childs Bath Tub From Westcliff Ranch 36° 50000 |W faomasz0 |, 03/01/02 | tron Bell 7 7 300.00 | w | 20025320 | 08/15/97 | Photo of lian Burial Ground w/discount s30000 | WA | 1997851 05/05/00 | Stereoview, T. Roosevelt on Horseback $300.00 wa | 2000.44.18, i 09/08/01 | Beaded Skull - $300.00 | W | 20011062 | 05/05/00 | Photograph, Framed, Conway, Texas 7 $3300.00 wa. | 20005937 05/0295 | photograph Ft, Grant, AZ framed $300.00 Wa | 195.144.1352 _ | 08/20/01 | U.S. Whiskey Flask s2s00 | Wf 2001971 05/02/95 | newspaper, Tombstone epitaph, (sn) famed saasoo | WA | 1995144167 08/29/00 | Hanging Lamp Glass Painted Shade $275.00 Ww | 20001118608/1198 | Chief & Son, Barry photos & mat $275.00 wa | 1998.44.10 08/05/95 | Wells Fargo Corp Stamp/Sea, prints Exp. San Fran, CA | $275.00 w |is9ssa6.i0 | 10/01/95 | Geo. Mason $250.00 wa | 199539143. | 08/11/98 | sitting Bull Camp Ft, Randal stereo $250.00 wa | 1998.44.14 08/25/02 | Custer Postcard Series $250.00 wa | 2002.230.10 11/0197 | Governor's Rifle Duel letter $227.00 wa | 197.453 11/16/97 | Cabinet Card Apache Squaw 7 $225.00 wa | 197.422 11/16/97 | Two Indian men, no Photo LD. 7 ; $225.00 wa [isa | 03/0496 | leter-indian Fighter Geo. P. Buell Ft, Stanton 1881 $225.00 wa | 1996282 [11701797 | US Commissioners Complaint $217.00, WA [197.452 11/0197 | Arizona Territory Court Document $217.00 wa [i951 | | 08/19/01 | 1914 Cent. Childs High Chair Payson, AZ) $215.00 w [20017810 | 72106 | Yarn Winder 2813) $200.00 ww | 2006244 (08/25/02 | Rertier Tool Box $200.00 w | 2003333 10/02/98 | 1884 Fort Stanton Broadside $200.00 wa | 1998.48.9 05/05/00 | Photograph, Cental iy $200.00 wa | 200061.14¢Attachment C02/22/02 | Russian Miquelet $4,800.00] Ww | 2002.36. 06/0195 | Rifle, 1873 Winchester $450.00] w | 1995.175.35 11/01/95 | Indian Scout rifle soabhbard $2,450.00] Ww | 1995.475.7a,b (06/29/95 | 1894 Winchester 38-55 made in 1898 1,000.00] w_ | 19952182 08/1495 | 1884 Springfield (indian) 35,000.00] w_ |.1995.303.4 12/09/95 | Winchester 94 Indian Gun $900.00] Ww | 1995.512.6 07/11/95 | Colt lightning 41 cal. wiholster Lot Ww | 1995.243.4a os/0sns | Sih & Wesson DA Ist Model “rome” 44 al Marked 3850.00! w | 199s:5469 s Fargo 01/12/97 | Gunfighters Remington Pistol (David Rudabaugh) _$1,600.00| W | 1997.614a__| (08/05/95 | Winchester 1873 carbine 44 cal, 20" bar. Marked Wells Fargo $1,700.00} w_ | 195.5468 01/11/95 | Remington Pistol w/Holster& belt $1,400.00] Ww | 1994203 06/2700 | Flintlock Pistol - Ojibuay/Lakota Wars $1,250.00] w | 2000.80.1 08/27/99 | Meeker Massacre Rifle, Sharps (Relic) Lot Ww | 2000.63.10 08/10/95 | Double Barrel Pin Fire $500.00] w_ | 1995.294.6 02726102 | Cheyenne Scabbard, w/ Musket $3,500.00] Ww | 2002.139.24a,b 11/20/01 | Robbers Shotgun & Case $1,500.00] w | 2002.134.3 r Sioux beaded bar, 1873 Winchester (silver inlaid) Appache | o3/10095 | Seseaiete | 400000] w _ | 1995:43.1a0 03/27/97 | Barly 19th Cent Rifle & powder horn $1,275.00] w | 197.171 09/04/95 | Leman Indian trade rifle $4,500.00] w | 195,335.30 10/03/06 | Rifle, Model 73 Winchester 44-40 $2,800.00] Ww | 2006474INTRODUCTION ‘We, the members of the Thirty-Seventh Statewide Investigating Grand Jury, having received and reviewed evidence regarding allegations of violations of the Pennsytvania Crimes Code and related laws, occurring in Dauphin County, Pennsylvania, pursuant to Notice of ‘Submission of Investigation Number 11, do hereby make the following findings of fact, conclusions, and recommendation of charges. FINDINGS OF FACT This investigation was commenced upon a conflict referral from the Dauphin County District Attomey’s Office. It concemed allegations of potential criminal misconduet with respect to the financing, operation, and management of the Harrisburg Resource Recovery Facility or what hes popularly become known as the “incinerator.” Over time, this Grand Jury’s inquiry broadened in scope to receive and consider evidence of misconduct in-the administration of other Harrisburg municipal entities and by officials of the Harrisburg City government. Much has been written elsewhere about the public debt crisis which resulted from the decision by Harrisburg City, Dauphin County, and state public officials, to encumber the region ‘through serial issuance of public debt in the forlom hope of transforming the ‘incinerator’ into a profitable enterprise. ‘The Forensic Andit prepared for the Harrisburg Authority comprises a thoughtful and, this Grand Jury finds, accurate exegesis of the incinerator project. ‘This Grand Jury, however, finds that the root causes of this crisis were endemic to Harrisburg city government itself at the time. The misguided decisions which later became criminal misconduct are visible in a number of civic institutions which this Grand Jury has studied.‘The scope and complexity of this investigation make précis difficult but, in short, this Grand Jury finds that then Mayor Stephen Reed, abetted by associates in government and the professional community, exploited the availability of capital in the municipal debt market to raise money for purposes utterly unrelated to the civic project for which a given bond was issued. In other words, in every instance this Grand Jury examined, Reed and his associates marketed. and sold bonds for one purpose, such as retrofitting the incinerator or renovating schools, then diverted at least some of those proceeds to buy things in which Reed was interested and to create fees payable to 4 coterie of professionals. ‘This model of the issuance of public debt for one purpose and the expenditure-of proceeds on totally unrelated goods and services appears in not just the former Harrisburg Authority, but in the Hanisburg School District, the Harrisburg Civio Baseball Club, the Harrisburg University of Science and Technology, and other municipal enterprises. Each was exploited to raise capital ostensibly necessary for a legitimate purpose and each was damaged under the crushing weight of the debt incurred in its name. Itis the investigation of this engine of debt which drove the City of Harrisburg inexorably info receivership, and Stephen Reeds role in fueling it, which is the subject of this presentment: Accordingly, the instant presentment is addressed to the alleged criminal misconduct of Stephen Reed only. This presentment is issued in furtherance of the Thirty-Seventh Statewide Investigating Grand Jury’s ongoing investigation into allegations of misconduct by those named herein and others as yet unnamed. ‘This presentment will address the role of each municipal entity in what became the ‘Reed model’ of the misuse of public debt and other public funds. Additional findings of fact and a recommendation of criminal charges follow.Stephen Reed graduated from Bishop McDevitt High School in Harrisburg in 1967. He attended Dickenson College but left off his studies prior to graduation in favor of pursuing a career in polities. In 1974, when he was only 25 years old, Reed won a seat in Pennsylvania’s House of Representatives. He served three terms there before departing in 1980. In 1981, Reed was elected Mayor of the City of Harrisburg, am office he would hold ‘without interruption or meaningful opposition until January 4, 2010. A dynamic and forceful personality, Reed would come to exercise near absolute control over the offices and institutions of the city he govemed. Undoubtedly, Reed did much that was good for the City of Harrisburg and its residents. This Grand Jury finds however that, over time, the prudent stewardship and innovative thinking which Reed brought to his office early on gave way to a.use of public money and other resources to gratify his own interests at the city’s expense. L “INCINERATOR” AND THE HARRISBURG AUTHORITY ‘In December of 1993, the City of Harrisburg sold the Resource Recovery Facility, hereinafter referred to as the incinerator, to a municipal entity called The Harrisburg Authority. ‘Thomas Mealy, one time executive director of The Harrisburg Authority testified before this Grand Jury. He was appointed to that position by Stephen Reed in 1990. ‘The Authority began as a mundane municipal entity overseeing traditional city utilities such ds sewer and water. Under Reed’s conttl, the scope of the Authority’s portfolio would swell to include administration of the incinerator and participation in the issuance of public debt on behalf of theHarrisburg School District, Harrisburg University of Science and Technology and in other municipal finance transactions. Organizationally, Mealy testified the Authority's board of directors comprised five individuals who were all appointed by then Mayor Reed. They served terms of either two or four years. ‘Mealy testified that in 2000 or 2001 the Authority began to divert money into a “special project fund” the idea of which was to bring in “non-Harrisburg money” to be used and spent on improving city services. Mealy indicated that some of the initial projects paid for by this fund inchided installing lights on the Walnut Street Bridge and creating a running trail on City Island. Mealy testified that over time Reed became more “iggressive” with the use of money from this fund. Specifically, Reed used it to purchase antiquities and Mealy testified that the Board would entertain requests by Reed to use Authority money for that purpose’. *Reed had indicated to the Harrisburg Authority through a memo that “the ‘law does not prescribe any particular manner in which such funds should be utilized”. This notion is incorrect. To the extent money in the Special Projects Reserve Fund is money of THA, the Municipality Authorities act expressly prescribes: i) permitted usage - to include acquisition of. land, structures, equipment, and facilities and improvements thereto, and ii} permitted projects and purposes for which money can be spent - to include water, sewer, storm water, parking, airports, incinerators, schools and healthcare facilities (nowhere is acquisition of museum artifacts mentioned as a proper use, purpose or project of a municipal authority). Moreover, the Authority, like the City was subject to competition in award of contracts and these provisions at the time would have applied to any contract for purchase with a cost of over $10,000 per Section 5614 (that is, had the acquisition of anvartifact with THA or City money been legal in the first instance). To the éxtent that money in the Special Projects Reserve Fund was money of the City, the City Charter and applicable State law have bidding requirements and would requixe that such amounts are properly budgeted and-appropriated by City Council‘The city sold the incinerator to the Authority at a time when the EPA introduced more stringent regulations of waste to energy facilities like the incinerator. Tt became clear it would be necessary either to close the incinerator or to spend a great deal of money to retrofit it to bring it into compliance, with federal lew. In 1993, the Harrisburg Authority purchased the incinerator from the City of Harrisburg for $26.7 million dollars. As the forensic audit for the Harrisburg Authority noted, that purchase was made entirely with borrowed money. It was necessary to borrow an additional $7.5 million Gollars at the same time bringing the 1993 purchase price, all of which was borrowed, to $34.2 million, In 1996 and 1997, it was necessary to borrow $3.5 million and $10.9 million respectively. Millions of dollars of that aggregate borrowing were consumed by a working capital deficit signifying that the revenues generated by the incinerator were not sufficient to pay the expenses. In 1998, it was necessary for the Authority to issue close to $56 million dollars in debt ‘which purported to refinance the 1993 and 1997 borrowings. Far from generating revenue or cutting expenses, this borrowing was necessary to prop up the operation of the facility with ever increasing borrowing at increasing cost to incinerator operations. Again, in 2000, the Authority issued another $25.2 million dollars’ worth of debt to restructure prior borrowing and to back fill the hole which the previous bond issues had created. Despite the self-evident need for every available dollar to go to debt service and operations, $4.2, rnin dollars more in debt was incurred in 2000 and diverted to the City of Harrisburg as a “guaranty fee.” This “guaranty fee” ‘was created and sized to fill a budget deficit in the City of Harrisburg’s General Fund. This Grand Jury finds that this fee was disproportionate to the value of the guaranty, and a clearexample of Reed taking bond proceeds from one bond issue and using them for a purpose that Reed believed would be beneficial to him. ‘The incinerator could ill afford this additional debt constituting the guaranty fee bonds and this is an instance of exploitation of the municipal bond market by Reed, Jn 2002, still more debt was issued, and the: Authority offered $17 million dollars of additional bonds for sale. The vast majority of bond proceeds from this offering had to be cexpended-as working capital, By this time; the incinerator was producing nothing but additional debt, and each bond issuance forged a new link in the chain of debt wrapped around the city end which the city still drags behind it to this day. But the woist was yet to come, In 2003 the Authority issued Series A, B and C notes of 2003 for a total amount of almost $76 million dollars. Like paying one credit card with another, ‘the massive 2003 issuance accomplished little more than kicking the can down the road at great expense to “incinerator operations. “This borrowing pushed principal out into the future so that THIA was able to make interest payments on the prior debt. As the forensic audit noted, by this point in 2003 the incinerator was carrying almost $105 million dollars’ worth of debt. The Authority issued still more debt, comprising its D, E and F series of 2003 which encumbered the facility with a spectacular additional $125 million dollars’ worth of debt. It was from this malignant mass of debt that Reed picked “fees” to be spent on artifacts and curiosities. By the end of 2006, things had gone from bad to worse at the incinerator. The task of retrofitting the incinerator to make it fall in line with EPA standards had fallen far shoxt of ? me expense of this, and other, municipal debt offerings and their certification as “self-liquidating” to the ‘Commonwealth of Pennsylvania, and to the investors to whom the bonds were marketed, is the subject of an ongoing investigation by this Grand Jury. 8projection and the Authority was faced with needing to raise an estimated of $25.5 million to complete the project. This coupled with the fact that the Authority had debt service and swap payments due in 2007 that totaled $13.4 million, made it clear to the Authority that additional debt would have to be issued in order to save the project and prevent further financial min for the city of Hanisburg. At this same time, Reed was attempting to hash out the terms of the borrowing in such a way that the city of Harrisburg and county of Dauphin would be on board anid willing to guarantee the loans. A city council woman from 2001-2009, testified that the city council was not in favor of the 2007 borrowing. Council had come together and drafted a set of 15 conditions that had to be met prior to them voting to approve the borrowing. One of the conditions was that none of the professionals that were paid on the first round of borrowings could be used this time around. This condition-was ultimately removed due to the former special projects advisor and a senior counselor to Reed threatening to sue her for tortious interference with contract. Some of the other conditions included reducing the working capital amount, repaying the city for the guarantee payment that it had made on June 1, fring all individuals connected with the Barlow retrofit, replacing the Authority board, an agreement from the Authority board that it would attempt to sell the facility on or before July 1, 2009, and hiring individuals to perform a forensic audit of the project. ‘Dauphin County had its own list of conditions that had to be met before they would guarantee the debt as well. Some of the conditions included that it would receive all money that ‘was past due to it and its professionals from the working capital loan that was a part of the 10borrowing, that the working capital loan would be for no more than $30 million and that the debt would be restructured prior to June 30, 2009. Jeff Haste, a Dauphin County Commissioner since 2003 testified before the Grand Jury. He recalled the discussions leading up to the 2007 borrowing as being very difficult, “I remember sitting in the meeting being very frustrated, and I made a comment, and this still holds true today. I felt that the County was almost like that Coast Guard rescue person that we had jumped into the waters to save-the City, to swim with them to shore, You know, agein, financially that’s what we were doing to try to save them, and-we weren't told the whole story. And.I remember stating at that time when we had to make a decision in *07, do we continue to try on our mission and swim to shore with the City or do we Just say it's time to sink and drown.” ‘Ultimately, both the City and County were able to reach a compromise whereby they got some of their conditions met and, in return, agreed to act as a guarantor for the 2007 borrowing. Bemadette Barattini, the attomey for the PA Department of Community and Economie Development who administers the Local Government Debt Act which includes the certification of debt as self-liquidating, testified before the Grand Jury. She indicated that it would have been “problematic” to certify the existing debt as self-liquidating if all of the projections that were prepared indicated that the incinerator would not be able to produce sufficient revenne to pay for past bonds let alone the new ones being issued. She stated if this was the case, the seli- liquidating certification should have been changed to indicate only the amount of the debt that could be paid for by reasonable projections of revenue. In an effort to proceed with the issuance of new debt, the Authority asked multiple parties, to prepare projections of the expected operations for the incinerator for the period 2007 through. uw2011. All but one of the projections? indicated that the Authority would be unable to service the current debt for the facility, let alone any new debt that would be issued. In spite of this dubious forecast, the Authority went ahead with issuing the debt and all parties to the borrowing still signed the form, certifying all of the previons debt as self liquidating, On December 26, 2007, the Harrisourg Authority issued the 2007 C’Note for $20,961,574.40 and D Note for $9,033,234.45. Included in the closing documents was a reference-to the Tri Party Interim Funding Agreement which was drafted to prevent Covanta from terminating its services. ‘The agreement included the Authority, the city and the county and provided that the Authotity would make a payment of $800,000 to Covanta, the city would make a payment of $250,000 to Covanta and the County would make a payment of $2.25 million to Covanta. ‘The money paid by the City and County would be reimbursed to them through the 2007 borrowing, effectively paying them back for having to make payments that they were contractually obligated to make, as guarantors of the previous loans. ‘The 2007 Notes also included payments outstanding to Covanta as well asthe monies that would be owed to Covanta in 2008 totaling $5,716,728.55. Aside from that amount, the remainder of the money that was acquired through the borrowing was spent to pay past debts, to cover upcoming debt service payments and to pay the professionals who put together the deal. ‘There was a $3,456,097.99 payment to the City of Harrisburg to reimburse if for a June and September debt service payment. The Notes were also used to repay the city and county for debt service payments that were coming due in November and December of 2007 as well as to cover the payments that were due in 2008, totaling $14,220,927.86. There was also a $1,067,783.00 The one projection was stale, based upon facts that were known to have changed well before issuance of the debt, and did not contain the information generated by experts on which the bond professionals ultimately relied. 2reimbursement to the County for fees that the Authority had collected on its behalf and had failed to remit for 2006 and 2007. Finally, there was'$1,222,671.12 in legal and financial fees that ‘were tied to the borrowing that were also paid from the Notes. Although he was the executive director of the Harrisburg Authority, Mealy could not explain how the Authority became entangled in so many different municipal transactions, so many of which seemed plainly outside the scope of the Authority’s institutional expertise. For example, $77 million dollais of debt was issued by the Authority on behalf ofthe school district of the City of Hanisburg. The official statement provided with respect to that debt issuance announces the purpose of the bond float as follows “the bonds are being issued to provide funds that will be used, together with certain other available funds, to finance a project of the school district consisting of (i) the financing of various capital projects of the school district (“the capital projects”); (ji) the current refunding of the outstanding amount of the school district's general obligation notes,..; (ii) the funding of capitalized interest on the bonds; (jv) the payment of the costs of issuance of the bonds.” Although investors were told that proceeds of this bond issue would be spent on the improvement of the schools of the City of Hamisburg for the benefit of its students; Reed took more than balf a million dollars to buy Wild West and other curiosities. Reed himself, in memorandum dated September 21, 2003 to ‘Thomas Mealy then the Executive Director of the Harrisburg Authority candidly announced the purpose of the “administrative fee.” In a thirteen (13) line memo attached to a thick stack of artifact invoices, Reed informed Mealy that the balance in the “Special Account” had dwindled to $8,783.97. “With the closing on September 23° of the THA bonds,” Reed told Mealy “there will be an additional $515,000.00 added.” . That money would not long remain in the “Special Account,” because Reed simultaneously presented to Meely close to half a million dollars’ worth of artifact, Binvoices which he instructed Mealy are to be paid the day after the bond closing. From the nearly $550,000.00 syphoned into the Special Account from the school district of Harrisburg, only $56,000.00 by Reed’s own account would be left after payment of the “already pending” orders for curiosities. As part of that transaction, Authority board member Frederick Clark moved that the Authority take a $515,000 “administrative fee™ from the issuance of 77 million dollars of Harrisburg School District debt and move it into a special projects fund. Mr. Mealy had no idea what role the Authority could have played in a refinancing done by the Harrisburg School District that would justify a fee of more than a half'a million dollars. Mealy testified that Stephen Reed or “the other two that I mientioned,” referring to a senior counselor to Reed and a former special projects advisor, would tell him what amount the Authority fee would be: The Grand Jury wishes to emphasize this is the first, but by no means the only, instance in which a witness'in a position of authority testified that Reed would dictate the particular terms of a * such an amount is largely outside the bounds of the traditional fee charged by a conduit issuing authority. Some other examples of administrative fees that are typical in this area include: a. City of York General Authority. This authority was used by ‘the School District prior to Stephen Reed's control of the board for a borrowing in 1999, Their fee on an $80 million transaction was $75,000.00, approximately 686% lower than what the School District was required to pay to THA in 2003. State Public School Building Authority. For the past 10 years or so, issuing through this authority has been relatively inexpensive and today, it is free of cost to the borrower. When the School Board was given a choice, it availed itself to this low cost option and on a borrowing of very similar size ($77 million) paid $12,500 or, 4;1208 less than the School District.paid THA in.2003. ¢.. Dauphin County General Authority. This Authority charges a flat fee based upon size of the transaction and complexity. In 2010, in connection with a continuing care retirement community (considered moze complex than a school district financing) DGGA charged $25,000 which was also intended to cover legal costs of the DCGA. Another general authority in Pennsylvania (Delaware County General Authority) for-this sized transaction would have also charged $25,000 according to its published fee schedule. rTfinancial transaction into which city entities under his control would enter. This extended to dictating the actual amount of the fee in this instance. It is self-evident that this fee cannot have been related to services performed by the Authority where the amount of that fee is not determined by the labor of Authority employees but is rather declared by the Mayor. Professionals retained by the Authority , such as Authority legal counsel and a financial advisor, who did employ Isbor on behalf of the Aufhority were paid separately by the School District from proceeds of the bonds. At that very same September of 2003 meeting, the Board voted to pay $471,506.00 worth of artifacts payments to various antiquities dealers. Reed would simply submit requisitions for © payment and, Mealy testified, the Auttiority would then vote to approve payment. ‘Then Grand Jury notes that the amount of the reinibursement corrélates to the amount of the Authority's ‘fee. This was not the only such fee taken. In a November 2002 letter, Reed told Mealy to expect money from the Parking Authority and from the school district and directed that those funds should be moved into the special projects fund. In a review of the city special projects fund revenue from 2000-2005, it is notable that large sums of money flow into the fund from the Harrisburg Parking Authority, begining with a deposit of $1.3 million on May 5, 2000. On. August 3, 2001, there is $750,000.00 that makes its way into the special projects fund from a series of bonds issued on behalf of the Parking Authority. October 9, 2001, there is an additional {$973,000.00 that is deposited into the special projects fimnd for what is noted to be the 7" Street Garage sale, Less than three months after this deposit of close to $1 million, the fund was down fo a balance of $4,456.64 and an additional $175,000.00 was deposited for the remainder of the 7 Steet Garage sle on December 27,2001. Again on February 28,2003 $250,000.00 makes 15its way. into the fund from the Parking Authority. An additional $500,000.00 is deposited on April 3, 2003 and another $170,130.00 is deposited on May 16, 2003. The Grand Jury notes that ‘cach influx of cash from the Packing Authority seems to occur at a time when the balance for the fund is nearing zero and a deposit is needed to prevent the fund from going into the red. Bach payment fiom the Paiking Authority decreases the amount the Parking Authority would otherwise be transferring to the City's General Fund for core municipal services and/or requires it to borrow more for parking improvements. Tn August of 2002, Mealy acknowledged a request by Reed to move $175,000.00 worth of proceeds from bonds sold on behalf of the incinerator to make them available for the purchase of artifacts. Mealy candidly assessed the difficulties in using the bond money for that purpose, and suggested to Reed in that letter that perhaps it would be possible to re-charactetize money from bond proceeds as “fees” so that they could be used for another purpose. Mealy testified ‘that, in retrospect, it was improper for the Authority to give Reed money in that manner by characterizing it as a.fee when no services, that Mealy could recollect, were rendered. Mealy testified that no one had more influence in the affairs of the Authority than Stephen Reed, During his testimony, Mealy was shown a document that was included in-the closing documeiits for a March 2003 swap in which the school district participated. ‘The swap involved an underlying $80 million borrowing (1999 Bonds) that utilized the City of York General Authority as the conduit issuer on behalf of the Harrisburg School District Not wanting to be left out of an oppoitunity to reap the benefits of a swap, Reed negotiated that the Harrisburg Authority would receive a $239,000.00 fee, paid by JP Morgan, for “research and 16development”, Mealy could not say what “research and development” a municipal Authority ‘would have undertaken on behalf of a school district and an investment bank to justify such a fee. He testified the Authority did a small amount of research into the wastewater treatment plant and a unique treatment process that was being used but indicated that it would not have been appropriate to take inoney out of the bonds floated to benefit the school district to pay the Authority for thet research. ‘Trent Hargrove testified before this Grand Jury. Hargrove served on the board of the Authority and as its chairman from 1991 to 2004. Hargrove also served, at various times, on the Harrisburg School Board of Control to which he was appointed by Reed, the Board of the Harrisburg Civic Baseball Club to which he was appointed by Reed, and as chairman of the Board of Control for the Harrisburg University of Science and Technology to which he was appointed by Reed. Indeed, Hargrove served on the Authority Board at the same time as he was Chairman of the Board of Control for the Harrisburg University of Science and Technology during the period the Authority was involved in the issuance of debt on behalf of the University. With respect to the $77 million dollar school district debt transaction, from which the Authority claimed a $515,000 dollar fee, Hargrove had no personal knowledge of what work ‘would have been done by the Authority to justify that fee, He concurred that the Authority did not determine the amount of the fee they simply approved it at the time of the closing of a given transaction. Of Reeds influence over the Authority, Hargrove testified “obviously, everybody Sithe $239,000 fee that Reed created was paid to THA on March 19, 2003 and coincidentally filled the deficit that existed in the special projects fund. According te the City Special Project Fund QuickReport, on the date of the deposit of the $239,000.00, the fund was operating in the red to the tune of $224,216.28. The influx of money filled the void and allowed the fund to be in the black by $14,783.72. 7would know the true reality of process that was that no major decisions were made, n6 major bonds were issued, no financial transactions occurred, nobody was appointed as-a contractor, advisor, or Counsel without [Reed’s] expressed or tacit approval. If Reed did not want it to happen, it would have not happened.” Frederick Clark testified before this Grand Jury. He was appointed by Reed to the board of the Harrisburg Authority from 2002-2007. He'also served on the board of the Harrisburg Redevelopment Anthority and the Parking Authority. Both positions were bestowed upon him by Reed. He sat on the Board of Control for the Harrisburg School District as well.. He testified that Reed selected every professional that was involved with every financial transaction that occurred in the city and that their fees were always paid out of the proceeds from the bonds. ‘Wir. Clark discussed the Special Projects Fund and indicated that there were often times ‘when the fund had no money remaining in its coffers and the board would have to approve movement of money from other Authority accounts into the special projects account. The other way that the board would balance the budget of the special projects fiand was through the administrative fees that came out of most of the financial transactions. He testified that the administrative fee was-something wholly created by Reed. It had no basis in work that was done by the Authority and the board had no.voice in determining what the fee would be. David Brinjac, of Brinjac Engineering, testified before this Grand Jury. Brinjac had performed work on the incinerator from 1982 to 1988 or 89. Brinjac installed the initial turbine engine in that facility. When talk began in the mid ‘90’s of the need to retrofit the incinerator, Brinjac, in association with Chester Engineers and Malcom Pimie, responded to a 1995 request for proposal concerning the feasibility of bringing the incinerator into compliance, Brinjac 18concluded such an effort was not financially viable for either the City or the Authority because of the amount of debt already outstanding and the additional amount it would be necessary to incur. In Angust of 1995, Brinjac presented his conclusions to Reed and his executive staf ‘The engineers informed Reed that if it was easy to do this kind of waste to energy facility project, they would be “building incinerators everywhere” and that it was much harder with the $68 million or $70 million dollars alzeady outstanding in debt. Reed said “[{Jhank you. You are fired.” Reed walked out of the room, ‘Ultimately, the decision was made to hire Barlow, an unknown entity in the City of Harrisburg, to perform the retrofit. The problems with that company and the project itself are ‘widely known and certainly served to send Harrisburg deeper into financial main. IL_HARRISBURG SCHOOL DISTRICT ‘William Gretton, III, testified before this Grand Jury. Gretton served as business administrator of the school district from December of 2001 to March of 2008. In that capacity, he oversaw all non-educational functions of the school district to include facilities, transportation, food service, information technology, and others. He reported to the superintendent who in turn reported to the Harrisburg Schoo! Board of Control. When Gretton began his work, the school district was undertaking a process of major renovations to its facilities around the district. The money to make those improvements was raised by issuing municipal bonds. Gretton testified that he was aware that the school distict paid a fee to the Harisburg Authority. Gretton testified he was under the impression that school districts couldn’t issue their ‘own debt and had to pay the Authority a fee for the use of their “service” in issuing the debt on the district’s behalf. This is not actually the case and the School District had issued directly 19before and after his tenure. When shown the 2003 closing statement which records the $515,000.00 paid to the Authority by the school district, Gretton theorized that the amount of the fee was based on the size of the underlying transaction, but testified he would not be surprised to learn that in this instance, Reed had set the amount of that fee. He “understood at the time [Reed] directed that certain bond counsel be utilized and that certain legal firms be involved. So certainly that would not surprise [him] that that amount was established in that manner.”. Gretion testified that he was sometimes surprised by the amount of the fee that the school district ‘was obliged to pay but that he wouldn’t see it until after the bonds had been issued and the fees set and then he just had to accept it. It wasn’t his job, he felt, to question it. Gretton fimther testified that the school district entered into bond “swap” transactions which are complex, and in this instance, expensive, financial products meant to manage interest rate risk. The swap transactions also generated fees which were paid fiom the proceeds of school district bonds to professionals whom Reed selected. Gretton testified that he was unaware that money from the “administrative fee” charged by the Harrisburg Authority to the school district went to the purchase of Wild Westem and other artifacts and memorabilia. He did recall, however; that he received a telephone call from.a reporter inquiring about that misuse of school district money for that purpose and that he referred the matter to then superintendent Dr. Gerald Kohn. Gretion testified he was concemed about the district’s spending at Reed’s direction. He recalled an instance where Reed directed the district to hire the Afiican American Chamber of Commerce for minority and women’s business enterprise compliance services. The chamber had no customers, and so had to be paid in advance by the school district justo begin the work for 20which they had been engaged. Grétton indicated that the work that the Chamber was doing for the school district rapidly fell off to a level that was not worth the money that was paid to them. Gretton recalled too that the district spent more on lobbying and legal fees than any other district for which he worked. Gretton testified that they had their own in house solicitor, their own construction firm, and e firm that dealt with special education services. Gretton testified the district paid $1.1 million dollars in lobbying-costs alone to an area lobbying group which routinely received contracts from Reed. This money was budgeted under “legal fees” although the services provided by this lobbying group were self-evidently non-legal in nature. Of Reeds control of the einterprise that is the Harrisburg School District, Gretton testified “i you look at the history of the [school] board of control ... there were certain times when somebody from the Board of Control didn’t agree with one of [Reed’s] decisions and that person. was quickly replaced. ... “[I}he control was coming from above, [Reed’s] level.” Indeed, Reed threatened to fire Gretton himself when “I made a decision that conflicted with something [Reed] thought should happen...” Dr. Gerald Kohn, Superintendent of the Harrisburg School District from 2001 to 2010, testified before this Grand Jury. Dz. Kohn indicated that he had recently left a New Jersey School District and applied for and was selected to be superintendent of the Harrisburg School District. During that time, Kohn testified, Reed was able to appoint, and remove, members of the school board pursuant to the Education Empowerment Act. § Dr. Kobn recalled that he ‘would meet with Reed and Reed would tell him that the district had to issue bonds for a certain * This Grand Jury has considered and rejected the defense that, the Education Empowerment Act authorized Reed so completely to usurp the basic responsibilities of the board members he appointed and so totally to direct the business of the school district that he picked every vendor and professional and ultimately used school district money to buy collectibles and memorabilia for hinself. 21project. Reed would instruct hinras to the recommendation that would need to be made to the ‘board of control and Kohn would thereafter make that Vote an agenda item for the next board meeting. ‘Kobn recalled he was in attendance at several meetings concerning the issuance of school district bonds where Reed ordained to everyone in the room who would be appointed bond counsel, financial advisor, and so on and what the particular tems of that bond issue would be. Dr. Kohn told this Grand Jury that he was not aware that bond money was being paid to the Harrisburg Authority in the form of an administrative fee. He testified that he was “greatly surprised” that the district had paid more than half a million dollars to the Authority as a transaction fee for the 2003 bond issue. He testified that he did not know Reed was using that money to buy antiquities and collectibles. Incredibly, the post-it-note on which Bill Gretton had ‘written to Kohn regarding the reporter’s inquiries about artifact purchases survived and is an ‘exhibit before this Grand Jury. When confionted with that note, Kohn had testified he did not remember having seen itor its contents. Kohn corroborated Gretton’s testimony that it was Reed who recommended the “swap” transactions to the school district and in fact told him to pat swap approval on the agenda for the board of control. Kohn was unequivocal that Reed dictated the terms of debt transactions both to the school district and the professionals whom he would appoint. He testified that Reed would send his advisors to the board of control meetings to make a PowerPoint presentation and they | were “quite convincing that it was in the school district’s best interest to do this or not do it.” He indicated thet if Reed recommended a specific financial transaction, which they could be certain he had or it wouldn’t have made its way onto their agenda, “then the board would vote for it.” . 2To illustrate that point, Kohn recalled an instance upon which he and other members of the board of control met in public session. A gentleman in the audience, who had just been appointed by Reed as the first president of the Harrisburg University of Science and Technology, stood up to thank the board for its $3.25 million gift to the University. No one on the stage had any idea what he was talking sbout. They didn’t know, Reed had not consulted them, and had negotiated, pledged, and delivered this money from the school district without the slightest involvement of anyone responsible for its governance. Kohn testified “I can’t tell you how surprised I was as was everyone else, Theré was outrage. Literally you could hear the jaws hitting the table as we heard this...” Kohi was apparently only one of two people on the school board that had Reed’s direct phone number. He called and demanded a meeting. When Reed eventually gave them an-audience, “the five members of the board of control-and I were there and they were furious not to have known and the mayor got angry and said, stop, listen to this: and he explained that the $3.25 million dollars was the beginning of down payment on a building that was going to be built for the school district for Sci Tech High School for $20 million doliars of which the mayor had obtained $4 plus million dollar private contributions from a number of business people in the community.” Reed went on to explain, Kohn testified, that Reed had actually pledged $20 million dollars of school district money for this Sci Tech High to be paid in installments over a number of years. Again, this Grand Jury emphasizes that this massive encumbrance of the schools of Harrisburg was accomplished by fist and continues to haunt the financially strapped school district to this day. Dr. Kohn testified that he “was hurt that I didn’t now about [Reed’s $20 million dollar pledge on behalf of the school distrigt}at first; but when you work with Mayor Reed that bappens a lot.” 2‘The Grand Jury was able to review a letter dated August 5, 2004 from James Losty, the managing director at RBC Dain Rauscher to Reed wherein Losty indicated that Act 72 was adopted in Pennsylvania and was to go into effect as of September 3, 2004. The Act was going ‘o require school districts to go to referendum for approval of municipal bond offerings. Losty indicated that he had been in talks with Public Financial Management and Bill Gretton regarding ‘the possibility of negating this requirement by entering into a bond purchase agreement at that time for future delivery of bonds. Losty wrote that such a transaction wouldn’t require any up- front fees but would allow for “future flexibility with regard to the timing of the actual delivery of bonds and the structure of bonds”. He ended his letter by noting that the school district had roughly $25million of borrowing capacity remaining. This Grand Jury finds Reed enthusiastically agreed and encumbered the school district with the maximum possible debt and gave Losty the business inzeturn, Reed also set aside $5 million ftom the $25 million to be used for capital and operating costs at the Harrisburg University of Science and Technology, indicating that this was “a critical component of this bond transaction”. Dr. Kohn testified he ‘was not aware of this transaction until the day of his Grand Jury testimony. ir October 2004, two Memoranda of Understanding were prepared between the Harrisburg School District and the Harrisburg University of Science and Technology. One of the MOU provided for $5 million to be paid to the Harrisburg University of Science and Technology out of the proceeds of the $77 million bomowing from 2003. In exchange, Harrisburg University of Science and Technology agreed to grant district students access to the university. It is unclear what value that should have been fo the School District as consideration considering the entire Purpose of the project was to serve Distiict students. The other MOU provided that the district would provide assistance to the university in the form of planning, staffing and construction of 24the facilities, technical assistance related to the construction, academic support, fundraising and grant counseling and any other assistance agreed to by the parties. In exchange, the university ‘was to make yearly payments of $290,000.00 to the school district for a period of ten years beginning on November 1, 2016 and concluding on October 31, 2025 as payment for the services rendered. Dr. Kohn testified that he was not aware of this transaction either. Notwithstanding the memorunda’s recording many transactions, Dr. Kohn maintained he was only aware of the $3.25 million dollars that was given to the University of Science and Technology and even then only after it was revealed to him by a spectator at an open session board meeting, Kok testified it was normal for him to be excluded from decision making regarding the finances of the school district which he was paid $235,431.00" annually to superintend, Dr. Kohn likewise testified he was unaware of any termination of the swap agreements in to which the school district entered during his tenure or at what cost to the district such ‘terminations were obtained. Il. HARRISBURG CIVIC BASEBALL CLUB ‘This Grand Jury finds that by the time of the debt issuance necessary to renovate the Harrisburg Senators Stadium facility on City Island, Reed had found a model that worked. This Grand Jury further finds that Reed began to view any instance of municipal borrowing as an opportunity to create and divert resources for the acquisition of antiquities and collectibles. ‘This Grand Jury is satisfied that by the time of the transactions described below, Reed was treating the resources of the Harrisburg Civie Baseball Club, the municipal entity which administered the city owned Hanzisburg Senators baseball team, and disposing of them, as his own. Gregory Martini testified before this Grand Jury. Martini served as chairman of the board of directors of the Harrisburg Senators fiom 1996 to 2006. In 2004, during Martini’s 7 As of the end of his tenure. 25temure, the Harrisburg Redevelopment Authority issned $18 million dollars? worth of bonds to ‘pay for the renovation of the Harrisburg Senators” stadium facility on City Island. The state was expected to provide grant money for this project as well, however the money was not immediately forthcoming, Ofnote for this particular borrowing is that the Harrisburg Authority did not participate in the financing in any way, but they still received a fee in the amount of $70,000.00 that was deposited into the special projects fund. ‘This fee was the subject of much debate within city council, as they believed that such a fee was in direct contravention of the ordinance that authorized the project, which directed that all revenue be-placed in the general fund. City Council demanded return of the $70,000.00 to the general fund. The Harrisburg Authority responded by having the solicitor, Bruce Foreman, write a letter to City Council President Richard House wherein he stated that the ordinance-that was passed provides for “payment of excess net revenues from the operation of the Stadium.” He went on to indicate that the ordinance did not refer to receipt and deposit of fees, as they cannot be characterized as operating revenue or net operating revenue and therefore, the receipt by the Authority of the fee ‘was entirely appropriate Around the same time, Reed began buying sports memorabilia and imagining some sort of sports museum in the Harrisburg area. To legitimize that effort, Reed tapped his friend John Levenda to become the only employee of a national sports hall of fame foundation. The question now became how to pay Mr. Levenda, Martini testified he recalled a letter sent to him by Reed in Decémber of 2004 asking the Harrisburg Civie Baseball Club to pay $125,000.00 to the National Sports Hall of Fame. Martini testified he took his direction from Reed and was prepared to cut the check based 26solely on the letter; no further documentation as to its necessity or proposed use was supplied or requested, The fantastically temious reason advanced for why the Harrisburg Civic Baseball Club should want to simply give $125,000.00 to. museum which did not exist and to the one person foundation marketing it came from Reed, The museum, if it was ever built, Reed explained, could be built on City Island. ‘The Senators also play on City Island. So it followed, +o Reed’s mind, that when the non-existent museum appeared it is possible that some of its patrons might-also visit the Senators and that provided sufficient justification for the Harrisburg Civic Baseball Club to simply pour moiey onto John Levenda. ‘This Grand Jury is troubled that Reed went so far as to suggest to Martini that the HCBC could book this payment as a legitimate expense under the 2004 bond agreement based on nothing more than his bald assertion that if such a museum was ever built some of its customers might go to a Senators game, “That transaction between Reed-and Martini was not consummated in 2004. On January 26, 2005, Reed wrote Martini again, this time requesting a payment of $100,000.00 for John Levenda. Martini made this payment from Senators’ bond pfoceeds based on nothing more then Reeds letter, Martini testified that Levencla never submitted any documentation to account for the expenditure and none was requested, Martini testified that the National Sports Hall of Fame never existed in any form more substantial than proposals, never broke ground, and Martini was not sure if city council voted on the project or evenif they were aware of it. a. Midwinter baseball meetings ‘This Grand Jury heard testimony that Reed would travel to the“Mid-Winter Meetings” held by Majo League Baseball in various locations and throughout the country and which also included events for minor league teams. Reed attended these meetings at the expense of the Harrisburg Civic Baseball Club, Martini testified he would write checks directly from the 27HCBC account to Reed.* Sometimes Reed would submit receipts, and sometimes he would simply ask for an amount without supplying any documentation at all. Again, he provided no ‘documentation and no one asked him for any. For travel, Reed would simply ask for a given amount to be paid to him and indicate that he had receipts if anybody wanted to look at them. Reed was unable to confine the activities of these junkets even to their nominal purpose and frequently seized the opportunity to go artifact shopping. Even though these shopping trips were in no Way related to any legitimate business of the Harrisburg Civic Baseball-Club, Reed ‘would ask for and receive reimbursement from the HCBC anyway. Martini testified that he was aware that John Levenda and Richard Pickles, then a member of the Harrisburg Police Department, would sometimes accompany Reed on these shopping trips. The findings of this Grand Jury with respect to those shopping trips are set out more completely below. Storage of property in Martini’s basement Those checks are as follows: 1. July 9, 2007 $ 5,000.00* 2. Rugust 3, 2007 3 9,443. 46+ 3. August 20, 2007 $3,633. 76* 4. September 20, 2007 $ 1,659.12* 5. June 18, "2008 § 10,000.00 6. July 21, 2008 3 4,821.00 7. August 5, 2008 $ 6,900.00 8. August 18, 2008 $2,600.00 9. September 2, 2008 $2,617.37 10. September 24, 2008 $ 3,750.00 21. November 3, 2008 $3,671.63 12. December 5, 2008 3 1,000.00 13. December 22, 2008 8 4,722.11 Total $ 59,818.25 ‘Prior to sale of team 28‘Martini testified that Reed called him in December of 2009 shortly before he left office, -asking if he could store some things in his building. Martini acquiesced and did not press Reed about theteason that he needed the storage or whet in particular he would be storing. Martini testified that Reed and other city employees showed up to his office with 15 different sized cartons for storage which they put into the storage area in the basement of his building. The items remained in his possession until they were turned over to the Office of Attorney General in 2014, Martini testified that, upon advice from counsel and in answer to a Grand Jury subpoena, ‘he opened the storage containers that were not wooden shipping crates and created an itemized list of the artifacts shat were contained within them. One of the storage containers had a packing slip attached to the outside which matched one of the checks from Harrisburg Civic Baseball Club. .Other items that ‘were within the collection in Martini’s basement are: Box I: ‘Unopened carton from Silvertip in Glorieta, NM Box 2: Unopened carton from Silvertip in Glorieta, NM Box 3: 10 plastic pennant holders Hall of Fame 2006 bat ‘Autographed Adirondack bat forNY Yankees 2 other unopened bats 2 bat holders 1893 baseball print—Unix, of PA Hbg. Colored Elks ticket 1920’s catcher’s chest protector Catcher's glove Box 4: Box of Topps Anniversary collection 1952-1990 baseball cards Senators? shirt Framed cards of Robin Roberts, Ritchie Ashburn, Don Drysdale & Hank Aaron. ‘Yankees flag Yankees 100 card legacy set Autographed Orlando Cepeda baseball Autographed Ron Guidry baseball Autographed Mickie Riveria baseball 6 baseball books 29Box 5: Box 6: Box 7: Box 8 Box 9: Braves shirt for Assenmacher 5 Harrisburg Senators 2008 programs Yankee stadium memorabilia 13 various framed cards, 56 baseball card sets ‘Topps baseball card set for 2008 Wheaties box. ‘Unopened box from Great American Ilustrators—detailed packing list included 4T signed posters ‘Unopened carton from Silvertip in Glorieta, NM 2 Babe Ruth photos 1 Jackie Robinson photo Batting Rug poster ‘US Marines poster 1920. Negro League poster Box 10: 50 Major League baseball card packs 1 shot glass Box I: 1 Western lamp Box 12: 1 Western bar stool Box 13: ‘Negro League leather jacket Hg: Cougars 2002 state champion hat and shirts, ‘Major League duffel bag, 3 baseball gloves 2 Negro League baseballs signed on July 12, 2008 at Broad St. Market NY Yankees and Negro League hats Phillies towel Box of baseball magazines and papers Cateher’s mask Ball holders “Yankees jacket Hg. High license plate holder Baseball encyclopedia Box 14: 8 ball holders 4 catcher’s masks Jason Giambi bobble head 303 packs baseball centennial cards from Cooperstown Yankees shirt 4 baseball gloves 1978 Topps baseball card set Glove & 4 baseballs 6 2008 Hall of Fame programs ‘Mickie Mantel book 4 Yankees magazines Yankees coffee mug Baltimore Orioles pennant Cal Ripkin shirt Shea Stadium shirt 2. Negro League hats Pennants for Baltimore Orioles, Chicago Black Hawks, Chicago Bears, Chicago White Sox & Brooklyn Dodgers 7 autographed baseballs 8 Upstate Life magazines 7 Gatemen programs for 2008 5 Memories & Dreams magazines Box 15: 3 unwrapped photos Goose Gassage framed photo ‘Negro League framed photo “Yankee Stadium collector’s patches Final season Yankee Stadium photo 1942 Whitehouse correspondence to Judge Landis, Shea Stadium final season framed picture Certificates of authenticity signed by Mayor Reed regarding Negro League purchases Jackie Robinson bobble head ‘Maris & Mantle bobble heads 3 Yankees hats Shea Stadium hat 2Negro League hats Correspondence from Tom Snyder to Mayor Reed ‘Wrapped baseball Mickie Mantel and Ted Williams photos Baseball from July 3, 2008 at Commerce Bank Park Hbg. Giants baseball shirt 3 baseball pins Baseball mug 2 Cooperstown souvenir bats 4 posters signed by Jose Cansaco & Jack Clark Other besebail posters 31‘Some of these items were purchased from a vendor called “Silvertip”. Documentation provided by the City of Harrisburg and presented to this Grand Jury establishes that this “Silvertip lot” of items was purchased with city money and considered missing at the time of the inventory of city owned meniorabilia and the subsequent auction of Wild West items. This Grand Jury finds that those Silvertip items belonged to the City of Hamisburg and their rendition, by Reed to Martini’s basement deprived the city and its creditors of their value, Special Agent Craig LeCadre testified that during an interview with Reed, he specifically asked him about the items that were stored in Martini’s basement. Reed’s response was that he 1ad‘no idea why there would be any artifacts stored in Martini’s basement. LeCadtre testified that Reed asked him if a mirror was among the items recovered from Martini’s basement because there were plans to put a restaurant called the “Bullpen Café” in the vicinity of the visiting team’s dugout in the renovation project of the Harrisburg Senator’s ball park. Agent LeCadre testified that he showed Reed pictures of the items that had been retrieved from Martinis basement on his cell phone. Upon viewing the photographs, Reed acknowledged that he recognized the mirror and hors but did not recollect the matching table lamps, He went on to acknowledge that the container shipped to “Harrisburg Civic Baseball Ass, c/o Office of the Mayor”. IV. ‘THE NATIONAL SPORTS HALL OF FAME, John Levenda testified before this Grand Jury. Levenda testified that he served as the President of AA Minor League Baseball's Eastern League from 1993 to 1996. The Eastern Leagues offices moved to Harrisburg because Reed agreed to build a space for them there and to charge them the same amount of rent as their old facility in Plainville, Connecticut, In that role, 32.Levenda oversaw umpires and score keepers and insured that each team was paying its annual dues, He attended ballgames and baseball meetings and looked after league expenses. After his move to Harrisburg, the owners of the Eastem Eeagne did not re-elect him in 1996 and he was looking for work. He suggested to Reed that he be hired to fimidraise for the burgeoning ‘National Civil War Museum and the nascent Sports Hall of Fame, Reed hired him as a consultant fo reise money for both projects. This contract did not need City Council’s approval ‘because it was considered “a personal service contract.” Levenda testified that Reed didn’t advertise or look for other candidates and that this position was created for him at his suggestion, ‘Levenda recalled he was hired in November of 1996 at a salary of $45,000.00 or $50,000.00.a year including health insurance. Levenda testified he began ta try and solicit donors and sponsors for the Civil War Museum and the Sports Hall of Fame. Levenda testified that he discovered the Pennsylvania Sports Hall of Fame, an organization which already existed, had received $9.5 million dollars in RACP® grant money. Levenda testified that Reed attempted to- persuade the PA Sports Hall of Fame to hire an executive director and raise matching finds so that the state grant could be accessed and spent. ‘The PA Sports Hall of Fame in tum asked Reed to loan them the matching moriey. Reed. tentatively agreed but the deal was never consummated. Levenda testified he did not believe Reed discussed the possibility of this $7 million dollar bridge loan with city council nor did he seek city councils approval. Levenda himself did not question Reed about this because, he testified, he just wanted to advance the project. ® The Redevelopment Assistance Capital Program (RACP) is a commonwealth grant program “for the acquisition and construction of regional economic, cultural, civic, recreational, and historical improvement projects.” 33Levenda testified that at some point it became clear that the PA. Sports Hall of Fame was not serious about the museum project anid Reed decided that the city was going to take the project over exclusively and rename it the Pennsylvania National Sports Hell of Fame, In 2002, that name was changed agein to the National Sports Hall of Fame, and was intended to feature athletes, coaches and administrators from youth sports through professional and Olympic level sports. Levenda testified that the RACP money was still available from the State but the newly named National Sports Hall of Fame (NSHF) would still need to raise matching money. In 2005, Levenda testified that the City had been through a round of layoffs and Reed and Levenda decided that it “didn’t look good” for the City to continue paying Levenda’s salary as a consultant for the NSHF so they created a board for the NSHF. Levenda became the only employee of the National Sports Hall of Fame Foundation in 2005, carried the title President and Chief Executive Officer, and received an annual salary of $87,500.00, health benefits, a $600.00 monthly car allowance and four (4) weeks of paid vacation. Again, Levenda testified, Reed re- characterized his employment because it “didn’t look good” to have him continue working for and receiving payment from the City during this time of increasing financial stress, Levenda testified that as the Foundation’s lone employee he approached city council to solicit them to guarantee $10 million dollars? worth of loans for the Sports Hill of Fame Museum. City council refused, and Levenda testified his solicitation came at a time when the fall extent of Reeds’s municipal debt crisis was becoming visible. 34By December of 2008, hope for the museum had been abandoned and, Levenda testified, any money left in the foundation coffers went to pay for his continuing health insurance in accordance witht his employment agreement, Indeed, even after the decision was taken not to pursue the. museum, the foundation continued to accept money. In January of 2009, two checks were written from HCBC to the ‘National Sports Hall of Fame Foundation for $750.00 each after the project was ostensibly abandoned. John Levenda testified that “every dollar that we could still raise, number one, helped with my health insurance.” ‘This Grand Jury finds the administration of the HEBC was consistent with the pattern of the institutjonalization of conflict apparent in every other municipal enterprise which Reed controlled. Levenda himself was placed on the Board of the Harrisburg Civic Baseball Club by Reed in 2003 and remained on the Board during the period he solicited HCBC for money, sometimes for no purpose other than fo pay himself. Levenda testified extensively about his travel with Reed and other associates to “Mid- ‘Winter Baseball meetings,” which would often migrate into artifact shopping trips and pure vacations. ‘Levenda recalled he attended such'meetings with Harrisburg Police officer Rick Pickles, Reed, Martini, and sometimes the general manager in at least the years 2004 through 2008. Levenda testified that the 2004 meeting was held in Anaheim, California. He traveled with Reed to Anaheim four (4) days prior to the meeting, and testified that he and Reed flew to San Francisco, spent the day there, drove into Nevada for a day, drove back through San Jose and spent the night there. They then drove to Los Angeles or San Luis Obispo before traveling to Anabeim for the meeting. Levenda testified that this trip had nothing to do with baseball and 35Reed wanted to “see the sights.” He and Reed submitted all their receipts for reimbut'sement to ‘the HCBC for payment. Levenda also attended the 2005 meeting which was held in Dallas. He scheduled a meeting for Reed with a sports memorabilia collector in Boca Raton, Florida for three days after the baseball meetings ended. Rather than flying. back to Harrisburg and back down for the shopping trip, Levenda and Reed went directly to Florida. They “killed time” before their meeting by visiting Key West, This trip was paid for by HCBC and, Levenda testified, had nothing to do with Senators’ baseball. Levenda testified that at the time he didn’t ask questions about the propriety of these trips but now, in retrospect, recognizes that they were wrong, Levenda testified that no one questioned Reed about these trips and that Levenda did not believe that any HCBC board members saw the receipts from the trips, rather, they were submitted directly to the general manager who simply wrote a check. In addition to accompanying the Mayor on artifact shopping trips, Levenda and Rick Pickles, who was a member of the Harrisburg Police Department at the time, would travel twice a year to locations designated by Reed to pick up artifacts which Reed had purchased and haul them back to Harrisburg. Levenda testified that most of the artifacts they collected appeared to be Wild Wester era pieces but there might have been some civil war artifacts as well. Levenda testified they were not, however, picking up baseball or sports related memorabilia, For these trips Levenda collected his regular salary and did not take vacation time, Richard Pickles was also paid his salary as a Harrisburg City Police Captain. Levenda testified he and Pickles would fly out to a destination designated by Reed then travel on to whatever particular vendor or site was holding the artifacts which Reed had purchased. They would then load those items into a 36conventional U-Haul type rental truck and drive them back to Harrisburg. No special accommiodation for the sensitivity of antiquities to the environraent was made, No insurance or other indemnification was sought or puichased. Levenda testified that the truck could be carrying anywhere from $100,000.00 to $1 million dollars’ worth of artifacts. This Grand Jury has learned that the renial truck would often be left siting unattended in the parking lot of a motel as Levenda and Pickles made their way back across the country to the vity with Reed's purchases. When they arrived, Levenda testified, they would deliver the load of artifacts to the “D and D building” located near the incinerator and unload the artifacts into a storage zoom there. On one suck 2004 trip, Levenda submitted receipts to thé Harrisburg Authority for reimbursement in the amount of $9,900.00. Even Thomas Mealy expressed concern about this reimbursement request because it incliided alcohol, typically an item unewailable for reimbursement by the Authority. Levenda told Mealy that he was “driving a 25 foot truck ‘through blizzards and tomados and at the end of the day if I want a drink Iam going to have one.” That reimbursement request was paid. Special Agent Lecadre testified that he and Special Agent Thomas Gote interviewed Stephen Reed on April 7, 2015. LeCadre testified that during the course of the interview, Reed was asked about using John Levenda and Rick Pickles to transport artifacts. Reed indicated to the agents that the city “literally saved tens of thousands of dollars” by utilizing those gentlemen to do that work. Reed considered Pickles’ actions as part of his duties as a city police officer to protect the artifacts during the shipping process. LeCadre testified thet Reed did not consider the. use of a city police officer to be inappropriate. Reed informed LeCadre that he allowed Pickles to be carried as “administrative leave with pay” while on these assignments, 37Review of documentation from Pickles’ personnel file indicate that there are three separate instances where Pickles’ time sheet was changed from vacation time to “leave with pay” af the behest of Reed. ‘The first incident occurred in 2004, In an August 17, 2004 memo from Reed to the director of Human Resources, Reed indicated that Captain Pickles was “dispatched by the City of Harrisburg for the purpose of renting a vehicle and retrieving items purchased by the City in other states and returning them safely to Harrisburg.” Reed indicated that Pickles? leave for May 10-14 and May 17 should be changed from “Vacation With Pay” to “Administrative Leave”. ‘There is a follow-up email from Deborah Felker, Personnel Officer with the Bureau of Human resourtes to Pickles where she confirms that “pursuant to Mayoral instructions”, she converted those-vacation days to leave with pay. A reviow of his leave history for the year also demonstrates that the modificatiomwas made. ‘The second incident occurred in 2005. In an August 3, 2005 memo from Reed to the director of Human Resources, Reed indicated that Captain Pickles was a representative of the City of Harrisburg in a visit to the Eastern Professional Baseball League All-Star Game in Portland, ME from July 8-17. Reed indicated that Pickles* leave history should be adjusted to administrative leave so that his personal leave and vacation time remain unaffected. A review of his leave history for 2005 does not show that he used vacation or personal time for these dates. ‘The third incident occurred in 2006. In a February 12, 2007 memo from Reed to the director of Human Resources, Reed indicated that Pickles was on “detached assignment in connection with the Winter Meetings of Professional Baseball” from November 29, 2006 until December 13, 2006 and that his leave should be changed to admisiistrative leave rather than 38personal or vacation leave. There is a follow-up email fiom Deborah Felker, Director of Human Resources to Pickles where she indicated that “per Mayoral directive” she converted all vacation usage to administrative leave for the period of November 26 through December 13, 2006, ‘Documentation from the Personnel system indicates that he was on Leave With Pay status for all of these dates. Todd Vander Woude testified before this Grand Jury. Vander Woude was employed as, the general manager for the Harrisburg Senators from 1992 until 2007. Vander Woude testified that the HCBC board had five (5) members and that Reed appointed them. Vander Woude corroborated Martini’s testimony that Reed would attend mid-winter baseball meetings at the civic baseball club’s expense, and therefore the City’s, and sometimes’extend those trips to £0 artifact shopping. Vander Woude recalled in 2005, for example, Reed went fo Boca Raton to look at a collection of sports memorabilia, Vander Woude recalled this instance particularly ‘because Reed-had written requests for reimbursement for the trip in the amount of $10,550.19. ‘Vander Woude testified that he was concemed about this request as it was an unbudgeted item and he didn’t feel the trip was related to Senators’ baseball but rather to the as yet unbuilt Sports Hall of Fame. That notwithstanding, Reed receiveid his reimbursement. Vander Woude corroborated Martini’s testimony that Reed would simply submit a request for reimbursement without any receipts or other documentation and HCBC would simply cut him a check. When shown the Silvertip items recovered fom Maartini’s basement which were purchased with HCBC money, and indeed were sent in crates marked HCBC to city hall, ‘Vander Woude testified they had nothing to do with the Senators or even with a Sports Hall of Fame. He testified that he would not have authorized HCBC money for those items had he known thet was what Reed was buying. More generally, Vander Woude testified unequivocally 39that HCBC was not a partner with Reed in purchasing artifacts; it wes not the business of the Harrisburg Civic Baseball Club to provide seed money for the Sports Hall of Fame or to buy: artifacts. Expenditures for artifacts were inno way related to the business of the ball club. As with so many other witnesses, Vander Woude testified he simply did not question Reed. Reed asked for the money and he got it. Y. THE HARRISBURG CITY COUNCIL, Richard House was elected to the Harrisburg City Council in 1989 and served for 16 years. He was Council president for 11 of those years. Reed was the mayor throughout House’s entire tenure on city council. Of Reed’s relationship to the Council, House testified “there was a saying-the media always called him the mayor for life. You know, if you start reading media clips long enough you start believing them. yourself. That was my beginning interpretation of city politics and that’s what Tmeant by saying he ruled with an iron thumb because he never believed in the philosophy that we could agree to disagree. It was always you vote with me ot you are the enemy.” Mr. House testified before this Grand Jury and indicated that in 2001, tliere was a position with the Department of the Auditor General that he wanted. Mr. House asked Reed to help him to get that ob, Reed met withthe Auditor General but then informed Mr, House that he couldn’t help him get the job. Soon after, Reed asked House if he would like to be the director of community relations for the Harrisburg Senators, a position that did not exist, previously. With respect to that job, House testified to the quid quo pro which existed, “[Reed] offered me that position because therefore he knew he could control me and he could get me toget all the votes that he needed for all his projects...” Indeed, Mr. House was asked directly about the existence of a quid quo pro in the following exchange: Question: “Did you feel... that this job, for instance, was an example of a guid quo pro, in other words, that you understood you were being given that job in exchange for your vote or the discharge of your official duty? “ Answer: Thaf’s how I felt, yes, sir.” ‘He went on to testify that when Reed gave him the job with the Senators, Reed was buying not just Mr. House’s vote but also the votes of those on city council that House could control. Randy King, testified before this Grand Jury. Mr. King served as préss secretary and director of communications for Reed from 1989 to 2007. In that role he handled all media requests, was the public information officer, wrote presé releases, gave interviews, arranged press conferences and media events and served as the legislative liaison to city council whose meetings he would attend. He confirmed that when Richard House lost his state job, he went to Mayor Reed to find him another job and, when there was no job to be had in state government, Reed gave him a job as a community relations coordinator with the Harrisburg Senators. House testified that city council often had to deal with issues surrounding the incinerator. The city often had to use general fund money to support the operation ofthe facility. Mr, House recalled that the city got so far in debt because of the need to support the incinerator that there came a time when there was not enough money in the coffers to cover payroll and the city had to go out and secure bridge loans from the bank. In the worst times, city council was approving a a1bridge loan every four months just to cover all the debt that the incinerator-was creating. This financial crisis was hidden from the citizens and was the backdrop to the decision to retrofit the incinerator and to float more than $100 million in bonds in 2003. The decision to go forward with the retrofit of the incinerator was not one that was made lightly by the City Council. ‘There were four public meetings that were held, at which the general project wes discussed. In addition to the public meetings that were ocourring, there were also many closed door, private meetings taking place as well. Richard House met with Mayor Reed on several occasions fo discuss the incinerator and at each of these meetings, it was made clear to Mr. House juist how important it was to get a yes vote for the incinerator bonds, Mr, House testified that at the outset, the votes to move forward with the project were not there, House conveyed this information to Mayor Reed at one of their meetings. Reed’s response to learning that there were not enough-votes was to ask Mrr. House what he had to do for him personally in exchange for Mr. House getting the requisite number of yes votes for the incinerator bonds. Mr. House testified that he found Reed to be so direct iri his proposed bribe that House amiously, and silently, wrote out and held up a note asking Reed whether he was recording the conversation. Reed responded by writing down that he was not recording the conversation and then asked if Mr. House was recording it. After this bizarre meeting between the two public figures, Mr. House went back to City Council and spoke with other members to find a way to make the incinerator bond vote more palatable. They devised a plan to create a city council special projects fund where the money held in the account would be divided amongst the council members and they could use it to donate to their own pet projects. A city council woman suggested that House rsk Reed for $1 million and indicated that was the amount of money it would take for her to vote yes for the bond 42deal. Mr, House testified that he felt that was too large a sumt of money and decided to ask Reed for $700,000.00. He had another meeting with Mayor Reed where he pitched the special projects fund idea and the $700,000.00 figure. Mir. House testified that Reed'was angered by the request, bbut when told that the fund was what it was going to take to get the yes votes from city council, he acquiesced and agreed to $500,000.00. Ultinately, due to budget constraints, the special projects fund only received $200,000.00 which was divided between all 7 city council members, with Mr, House receiving a slightly larger portion as the city council president. The money from the find was then donated to various organizations like The Boys and Girls Club of America, Salvation Army, Goodwill Industries and other community-based organizations in the city of Harrisburg. Mr. House testified that, although the donations were charitable in nature, each city council member derived a political benefit from each donation that was made, Randy King testified that the city council wantec'a WAM fund (Welking Around Money): in exchange for pushing forward the vote on the incinerator bonds. He indicated that the WAM. funds were desirable to city council because “they wanted to throw money around to community groups so they could gather political support” as they were gearing up for re-election. King was asked directly about the quid pro quo of the WAM or ‘councilmanic? find in exchange for votes: Question: “[UJltimately you had to sort of agree to confer the fund just t0 get - them to vote for the - A. That is comect. Question: They held their vote hostage to a benefit at least in the conitext of that '03 deal? 43Aj That's correct. ‘VI. HARRISBURG UNIVERSITY OF SCIENCE AND TECHNOLOGY Dwayne Maun testified before this Grand Jury. Mr. Maun is employed as the Chief Financial Officer for the Harrisburg University of Science and Technology. In that role, he is responsible for all the regularly kept business records of the University’s assets. Mr. Maun testified that Reed is 2 board member on the University and has served in that capacity since 2002. . ‘Mr. Maun testified that in 2010 the president of the University was Mei Schiavelli. Maun testified that Schiavelli and Reed were “very close friends.” Maun testified that the proposal was made by Schiavelli that, when it was clear Reed would not be retuming to the mayor's office, that “[wle’re going to find something for Mayor Reed to do. This will help him get on his fect.” ‘A contract was drafted between the University and Reed under which Reed would'be paid as a regular guest lecturer in the “political mind” or “civic mind” courses. Undér the contract, Reed was also to work with University faculty to develop an elective three credit course in Entrepreneurship in Government which was to be offered in the spring of 2011. Additionally, Reed would serve on the University advisory board for its entrepreneurship program. Reed ‘would also participate in a panel discussion to be scheduled in the fall of 2010 on topics related to the future of government. Reed would additionally participate in student recruiting activities as appropriate. 44For these services Reed was to be paid a monthly stipend of $2,000.00 not to exceed a contract total of $12,000.00. Mann testified thet, the terms of the contract notwithstanding, the only services Reed ever provided were to appear as a guest lecturer several times, Maun testified that he felt the University did not get its money’s worth out of this contract, but that it was paid in fall to Reed. This Grand Jury saw the 1099 form issued by the University for 2010 which demonstrates that he received the full $12,000.00, Another, similar, contract was created-for 2011. Maun testified Reed knew the University was about to come into $10 million dollars in loan proceeds. Maun testified that the relationship between Schiavelli and Reed was “pretty secret.” The two held closed door off site meetings. Maun testified that this new contract for 2011 was limited to six (6) months and that limitation was intended to communicate to Schiavelli the distaste by the University’s adnzinistrators for paying Reed for another year, ‘Maun testified; with respect to the 2011 contract, Reed didn’t perform any of the services for which the University contracted. The class for which Reed was supposed to lecture did not even exist in the University’s curriculum, ‘The only “recruiting” effort Reed made was to goto Harrisburg High School and tell the students that they could come to the University of Science and Technology for free. Maun expressed ambivalence as to whether that was a “recruiting” activity for which Reed should have been paid. The entrepreneurship program Reed was supposed to develop badn’t been established. ‘That notwithstanding, another contract between Reed and the University for the remaining six (6) months of 2011 was drafted. Maun testified ‘that this occurred during a period when the University was in financial distress. In fact, the University missed its debt service payments in 2012 and the County has been paying $1.5 million per year for the past several years due to lack of sufficient funds to pay operations and 45debt service on the bonds. Agein, Maun testified that the contract grew out of the personal relationship between Reed and Schiavelli. Again, Reed received a $1,000.00 a month for each of the six months and again, Maun testified, Reed performed none of the services for which he was being paid. This Grand Jury has seen the 1099 form issued by the University to Stephen Reed for 2011, which confirms that he was paid $6,000.00: Maun testified that during that time the University was illiquid and did not, and could not pay all ofits vendors, which is why Reed did not receive the entire $12,000 in 2011. Reed considered that he was owed additional money. Maun testified that in 2012 the board of the University held a fund raising challenge. ‘The idea was that individual board members would pledge or solicit a certain amount of money which would be matched by other board members, Maun testified that Reed participated in this challenge by offering to “forgive” the money that he was ‘owed’ under the 2011 contract. Reed proposed that he should then be credited with having “contributed” that amount to the capital campaign. ‘Maun testified no contract was drafted between the University and Reed in 2012. ‘Schiavelli was looking for new employment himself and, Maun testified, was no longer focused, on “feeding a friend.” Maun testified he was not aware that Reed created any work product under any of these contracts, No syllabi, time cards, class materials or any other tangible product which the University might use for the benefit of its students, Maun additionally testified that usually guest lecturers are not compensated. By way of comparison, Maun testified, a typical contratt for an adjunct professor would be $3,000.00 per semester. In other words, such an adjunct would teach for fifteen (15) weeks and receive $3,000.00. Reeds’ contract paid him four (4) times what the normal adjunet professor would receive and he did nothing to eam it. 46MIL ARTIFACTS. This-Grand Jury has heard testimony from numerous witnesses on the subject of Stephen Reed’s compulsion to purchase antiquities, collectibles, and other memorabilia. This Grand Jury finds that Reed demonstrated an almost pathological preoccupation with the act of buying such artifacts. It has been the uniform testimony of witnesses before this Grand Jury, and the irrefutable proof of the evidence presented, that Reed little cared for the ultimate disposition of the artifacts he purchased on behalf of the vity. Indeed, this Grand Jury finds, that as a result of his indifference to the storage and maintenance of objects he purchased, those objects were exposed to a substantial risk of diminution in value or outright loss, In addition, as i8 set out in detail below, this Grand Jury finds that Stephen Reed improperly obtained possession of hundreds of thousands, if not millions, of dollars? worth of artifacts purchased with the money of the people of the City of Harrisburg in violation of Pennsylvania’s Criminal Code. Linda Lingle testified before this Grand Jury. Lingle worked for Reed from 1989 to January of: 2008. She began as the city's Director of Bureau of Operations and Revenue, twice served as acting director of Human Resources, and spent her last five (5) years with the city serving as Business Administrator. She testified that she knew John Levenda and Richard Pickles would eccompany Reed on trips to shop for artifacts. She testified Reed would seek reimbursement for those trips and would submit receipts sometimes. The receipts that were submitted to her were for artifacts not for expenses associated with the shopping expeditions. a7Ms. Lingle testified as to the process by which such reimbursements were processed. For example, in 1999, in excess of half.a million dollars was disbursed from the city’s general fund for the purchase of artifacts. Ms. Lingle noted that a secretary to the former special projects advisor handled that particular transaction. Evidence shown to Ms. Lingle and to this Grand Jury comprises the following: Ax invoice dated November 3, 1998 billed to Stephen Reed, Mayor, from Purple Sage Antique Guns and Corrales, New Mexico. This itemized invoice lists the artifacts purchased including a badge, pistol, razor, and cane ostensibly belonging to Wyatt Earp, and other items. ‘This Grand Jury notes that the items which appear on the Purple Sage invoice appear to be Wild Western era artifacts. ‘A city check requisition form was completed: Ms. Lingle did not know why the special project advisor’s secretary filled out the form. That form in tum was submitted to Robert Kroboth, the city’s former financial director, for review and approval. This Grand Jury notes, ‘that the description given on the check requisition form indicates “civil war archives” even though the items purchased are plainly described as belonging to the “Wild West” era. ‘This Grand Jury finds it misleading to characterize an item sold as Wyatt Earp’s cane as an item appropriate for “Civil War” archives. ‘That notwithstanding, a city check numbered 16090 for $540,000.00 and dated August 10, 1999, was produced. This Grand Jury notes that the memo line indicates “Civil War M.” ‘Ms. Lingle observed that it appeared as though the description of the items had transformed from Wild Wester nature on the invoice to Civil War archive on the check requisition to Civil War “M” on the public check diawn on the city’s funds.Randy King described Reed’s acquisition of artifacts, “his first project was the National Civil War Museum, and he bégan buying artifacts for that, probably in the mid-90"s, It got to the point where he had purchased about $2 million dollars’ worth of staff, and to purchase these artifacts he would take money from various city accounts and council eventually found out about this and put road blocks up to prevent him from using public dollars, tax dollars to do this. He reached the point where he had aequired about $2 million dollars’ worth of atifacts for the ‘National Civil War Museum and [Reed’s former special projects advisor} and I were very concemed about this, we thought he was getting out of control. So we went in and talked to him, one night and begged him to stop and he told us he was nearly finished. Well, he was not. He spent a lot more. [The Civil Wat Museurn] opened in 2000 to rave reviews and kind of energized hin to push forward with other museum projects including the National Museum of the Old ‘West, the Pennsylvania Fire Museum, the Pennsylvania Sports Hall of Fame and the African American Museum. His artifuct acquisition activities increased dramatically. By this time [city] couneil prevented him from using regular city budget funds to purchase artifacts, so they set ua special projects fund at the Harrisburg Authority to funnel money through to allow the Mayor to continue his artifact acquisition activities.” ‘Mr. King testified it was his belief that by the mid-2000s the city had collected more than enough artifacts to populate any of the proposed museums and that he began to believe that the purchase of the artifacts was a therapeutic personal endeavor - a personal means of stress management. King testified that artifact collection would ocoupy Reed for days on end. He would add acquisition of artifacts to any official trip he took. King testified that before he would leave for a trip, Reed would have a staffer prepare stacks of UPS slips, filled out with City Hall’s address and his name. When he purchased artifacts he would put them in plastic tubs, tape them 49,up and affix the UPS label to them and, within days of Reed's departure for a given trip, King testified, UPS would begin delivering tubs to city hall. King testified that there were periods of time where the office was so full of these blue plastic tubs that it was difficult for staff to maneuver around them. King testified that both he and other city officials would go to Reed an.a weekly basis and tell him “you've got to.stop this, you've got to cut it out, it’s just going to kill your career” but that Reed would not listen. He would simply repeat to them that he was “almost finished.” King testified that he believed acquisition of artifacts was a personal release for Reed, a sort of private hobby that made him happy and allowed him to feel relaxed. King expressed his personal view, and this Grand Jury notes he is not a clinician, that Reed suffered from depression which began to manifest itself in a more pronounced way in the early 2000's. King felt that ‘Reed developed a binge artifact buying “addiction” that had a salutary effect on his mood. King testified that it was his opinion as a member of Reed’s executive staff that Reed ‘would sometimes claim to be traveling to an engagement on city business at City tax payers* ‘expense when the “real” purpose of the trip was artifact shopping. King testified that as the blue tubs of artifacts would come into city hall, Reed would have public works employees come to transport the tubs to places around the city where they ‘would be stored. King testified Reed made no effort to comiprehensively catalog or record the items bought with public money or the expenses incurred in sequiring them, King testified that when Reed would travel to purchase artifacts he wouild attempt to “sweet talk” the vendor into giving him possession of the artifacts in exchange for subsequent payment by the city. The seller would fax a purchase order to city hall and it was King’s 50impression that Reed did not much concem himself with the city requisition and payment procedure, Robert Kroboth testified before this Grand Jury, Kroboth served as the city’s finance director, a sort of Chief Financial Officer for the city, and testified he was accordingly involved in accounts payable, aiudits, budget development and providing financial data on the business of the city, Kroboth corroborated Lingle’s testiinony with respect to the city check requisition procedure. Mr: Kroboth could not explain why more than half # million dollars was peid out of the city capital projects fund to pay for artifacts pursuant to the Purple Sage invoice described above. Mr. Kroboth testified it was “curious” that the description of the items transformed from ‘Wild Wester era objects on the invoice itself to the “Civil War M” when the check itself was made out. Mr. Kroboth was shown an email obtained by investigators from him to the Executive Director of the National Civil War Museum, in which he directed that Brett Kelly delete then missing THA purchased artifacts from the manifest then add them back to'the manifest once they had been located. Mr. Kroboth was unable to remember the facts that precipitated his request to remove missing artifacts from the THA inventory. He assured the Grand Jury that it was not their intent to hide artifacts, Special Agent Craig LeCadre testified that agents of the Office of Attorney General executed a search warrant upon Stephen Reed’s personal office and storage facility located in downtown Harrisburg. At this facility, which is a former hospital building converted for commercial use; Reed enjoys the use of the entire ground floor comprising some twelve (12) 51.individual rooms." In each and every room they searched, this Grand Jury has learned, agents found artifacts and collectibles of every description co-mingled with documents and other Gbjects and piled from the floor to the ceiling. This Grand Jury finds that Reed created inthis, suite of rooms a veritable treasure house comprising quite literally thousands of items which belonged to the people of the city of Harrisburg. In the first room searched, agents discovered that Reed had re-created his mayoral office in the largest of the commercial storage rooms. Special Agent LaCadre testified to, and this Grand Jury examined photographs of, this area. Init, Reed had displayed his many civic awards and commendatious as well as various historic artifacts including a saddle and other Western items. During the execution of this warrant, agents interviewed Stephen Reed regarding the contents of the rooms being searched. Reed represented to investigators that they would not find any city property stored there, that the items comprised his personal collection, and in the unlikely event that city property was discovered, it would be because it had been “inadvertently” packed by city employees and brought there without his knowledge. This Grand Juy finds that assertion to be wholly incredible and belied by the facts as found below. Special Agent LeCadre testified to, and this Grand Jury examined photographs of, some ‘examples of items discovered in the numerous rooms of Reed’s facility. The contents of these rooms were not organized in any discemable way and objects and documents lay strewn in heaps on the floor and piled in high stacks thet sometimes reached almost to the ceiling. Some of the items observed included a life sized sarcophagus, a full suit of armor, a suit of chain mail, a 2° me owner of this facility provided this very large space to Reed for his personal ahd exclusive use rent free as an accommodation and out of respect for the former mayor. 82Calvary soldier’s saddle, bugle, and sword, native American items, horse and stage coach tack, wardrobes of uniforms from various eras including WWI and Vietnam, militaria, farming implements, litho- and photagraphs, what appeared to be a life sized buffalo head, and a host of other items, Agents of the Office of Attomey General were obliged to spend hundreds of hours, ina process which is still ongging, carefully to sort through the items discovered and safeguard and attempt to identify them. To aid them in this effort, investigators contacted Brett Kelly, a curator of the National Civil War Muséum, Mr. Kelly testified before this Grand Jury. While Reed was stil in office, Kelly worked to catalog and inventory the stream of artifacts flowing into the city from Reed’s sundry shopping expeditions, Particularly, Kelly would retrieve items from city hall when they would arrive in shipments and would take them to the “D and D” building near the incinerator. He would also receive items at the “D and D” building as they were either shipped there or. brought by Levenda and Pickles. Kelly testified that the “D and D” building was a large warehouse located by the incinerator. The building was heated and cooled by the use of large, antiquated suxplus naval units that often broke, rendering the temperature in the building susceptible to vast fluctuations. ‘The warehouse had large rollup garage bay entrances that, when opened, would let ina myriad of insects as well as stray birds. The roof, while mostly waterproof, had sun lights that had been sealed with tar which melted and dripped into the building and onto the artifacts in the sumamer months. None of these conditions were conducive to proper storage of rare historical antiquities, certainly not if the overarching goal was placement in a museum. Kelly recalled withi deep 53regret that artifacts were simply rotting at the “D and D” building. One such example to which he testified was when an exquisite tapestry had been brought into the “D and D* building that ‘was filled with bright colors and intricate designs. Within weeks, the moths had gotten to it and had laid their larvae within it, Shortly thereafter, the entire tapestry had become a pile of grayish goo. He indicated that it was a constant struggle at the building to keep on top of all of the environmental enemies to the artifacts and that the job was bigger than somethinig that he alone _ could handle. Kelly testified that he repeatedly raised his concems with the CEO of the Civil War Museum who then relayed those concems to Reed, The response that Kelly got back froma the CEO was-that he should begin to distance himself from the building and the task of caring for the artifacts. For someone who spent millions of dollars of city money on the purchase of the artifacts, Reed did not seem to have any care or concem about them once they had been purchased. He did not listen to the concerns of Mr. Kelly, as relayed to him by the CEO of the Civil War Museum. He did not venture to the “D and D” building when a big shipment was coming in to be able to view the artifacts as they arrived, Indeed, Mr. Kelly only vaguely recalls one time in which Reed visited the “D and D” building in all of his service there. Kelly testified that in an attempt to maintain some sort of record of the great many items being arbitrarily purchased, Kelly began to undertake an inventory. He was able to take over a list that had been kept by Reed's secretary beginning in 1994 and greatly expand it to capture a great deal more information than it had previously included. Kelly testified that to each item received by him Kelly would assign an “accession number.” This number is a convention used in cataloging the collections of museums. Each number comprises three values separated by decimal points, For example, the number 2000.28.43 would indicate that the particular item was 54.acquired in the year 2000, was the 28" lot of items to be acquired in that year, and was the 43" item within that lot. In the data base he was creating, Kelly testified, in addition to assigning each item an avcession number, he provided a description of the item and the price the city had ‘paid for that item when it could be determined from the documentation which accompanied the shipments. ‘Mr. Kelly did his best to capture in his inventory all of the items of which he was aware. Mr. Kelly provided that inventory to investigators. Investigators then began to compare the items discovered in Reed’s suite of storage rooms to those listed on the city’s manifest, It should be noted, and Mr, Kelly and other witnesses testified, that the items which appear on that inventory are city property. They were acquired with city money, and were shipped or delivered by city employees to a city facility. Over and over, investigators discovered items in Reed’s personal storage facility which appeared on the city’s manifest of city property. A: spreadsheet summarizing those items which belonged to the city and were discovered in Reed’s private storage facility is attached to this Presentment, The aggregate value of those items discovered which appear on the city’s manifest is, so far, $121,169.20. Mr. Kelly testified he was shocked at the sheer scope and number of artifacts discovered in Reed’s storage rooms. Kelly testified he thought he had seen the extent of the Wild Wester collection amassed by Reed but that the staggering number of items found in Reed’s possession ‘would be sufficient to form a museum collection all on its own. Having had the opportunity to survey those items discovered by OAG investigators in Reed’s possession, and understanding that he could not identify and reliably appraise each item, Mr. Kelly nonetheless felt confident 55that such a collection, when compared swith the insured and appraised collection of the Civil War Museum, was worth millions of dollars. This Grand Jury finds Stephen Reed lied to investigators when he represented that there was no city property, or only a small amount of inadvertently transported city property, to be found in his possession. To the contrary, hundreds of artifacts which appear onthe manifest of city property, and for which no evidence exists that Reed subsequently purchased or obtained lawfully, were discovered in this treasure house. In addition to stolen artifacts, investigators discovered:-boxes of documents which belong, to the city of Harrisburg. These do not include Reed’s personal papers, notes, and other documents, which, of course, it would have been appropriate for Reed to take with him when he Jef office, Rather these documents comprise official correspondence, memoranda of negotiation, and other records which belonged to the city and are part of its institutional memory. A warrant was also executed at Reed’s three story private residence in the city of Harrisburg. Even having seen and cataloged the vast collection secreted away by Reed at his storage building, investigators testified they were shocked by what they found. Thousands more artifacts, many of an American Westem theme, were densely packed into the living spaces, basement, and along stairwells and hallways. Statuary, oil paintings, pottery, weapons, clothing a ‘vampire hunting kit’ and all manner of other items were displayed on table tops, walls, in cabinets, on the floor and on top of television sets and furniture. Some items still had tags from. the City’s action of Western memorabilia attached. Both auction houses confirmed to the Grand Jury that no record existed of any auction purchases by Stephen Reed. The process of cataloging these items is ongoing, but many items found in Reed’s home appear on the manifest of city property referenced above, 56ou teaibiel Tatetass Additionally, this Grand Jury heard testimony that in the period between the search of Reed’s storage facility and the search of his home, Reed travelled to Gettysburg to attempt to sell a number of firearms on consignment. Investigators recovered those weapons, and at the times of this presentment, at least twenty appear on the list of city property. In a television interview played for this Grand Jury, Reed asserts that all the artifacts found in his home belong to him. In conclusion, this Grand Jury finds that Reed exercised control over the municipal enterprises described above to such a degree that they became mere ciphers. ‘We find that Reed improperly diverted proceeds from bond offerings which were themselves ill-advised, portions of which were used to fill the coffers or reimburse the City so ‘that Mr. Reed could pursue his interests. In every instance, bonds were sold for one purpose and some of the proceeds spent on another purpose. This diversion was actively hidden from investors and the citizens of Hantisburg. Transparency and competition for city business were subverted in favor of obfuscation and patronage, Debt which encumbers Harrisbirg to this day ‘was heedlessly issued to enable the purchase of artifacts and to pay select professionals. We find that Reed offered things of value to officials in exchange for the discharge of their official duties and to bring them to heel, We find that Reed improperly retained possessiou of a massive collection of city property at the expense of the city and its creditors. Ultimately, Reed began to ‘treatthe city’s assets as his own and to build a city which was a monument to him and not administered for the common good. 87atol-ty on ts ovo fa pases owes es sanyo eg OP] SILI “aaaurs) SED BITE ‘aig na ESTA OT ae s66t SC 6 86ST 97900 ae mig a PA PIO FOTO Eis) -2Pe WA | Ceo sam BE EO0e| SERIA Wo TAL WE SPT] — i Tes T9661 a arty TREOV PP TSI] THEHT SSG Te TWA SIAM cc TNEDY Porem ZT > AAT RTA POAT co appar sear oT BSL T00C aU aT PON aS — —— — _ sniva orang] 10/07/80] RATT ona om Tes OI “aie oam| arr = auirsnm| oo/soFo eae er sca [seer co0e| Tro 000 ec — “Wp RRTAWRD|cH/LO/OT| —= — [ss sr 000 ae ra any maT sre s66r Baan SRT RA TON Aa no FT = TCT “Tesco — SB — SHH aPATOS TIEsoot] ak OO OLL'TS| PPO! soyczia| ‘9qnu pavogpao 8 oprst; Polty| Sauee A moNS MOIPT SpmH ec aHOSRER STAG ws] ay Sorenson uae eres gyn) | : ‘Bonduosap KD ana_ | | wonder DVO. 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