Corbett Press Release

  • June 2020
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HARRISBURG - As part of an ongoing public corruption investigation into the Pennsylvania Legislature, agents from the Attorney General's Public Corruption Unit today filed criminal charges against Representative John Perzel and former Republican Representative Brett Feese. Also charged are eight current or former aides to Perzel and Feese. Attorney General Tom Corbett said the charges are part of an ongoing grand jury investigation into the misuse of public resources and employees for campaign purposes in the Pennsylvania Legislature. (Review the grand jury report: Part 1, Part 2 & Part 3) Corbett said the grand jury issued a 188 page presentment recommending that he file criminal charges against the defendants. Among those charged, in addition to Perzel and Feese, are Perzel's former Chief of Staff, Brian Preski; his current Chief of Staff, Paul Towhey; Perzel's brother-in-law and former House employee, Samual "Buzz" Stokes; Perzel legislative aide John Zimmerman; Perzel campaign aide Don McClintock; Feese aides Jill Seaman and Elmer Bowman; and former House Republican Information Technology Deputy Director Eric Ruth. The defendants are each charged with numerous theft, criminal conspiracy and conflict of interest charges. Additionally, Perzel, Feese, Seaman, Towhey and Zimmerman are each charged with obstruction of justice. Corbett said that in the first phase of the investigation his agents charged 12 defendants in July of 2008. Trials are scheduled for December and January 2010. As in the first phase of the investigation, Corbett said, the grand jury uncovered a concerted plan to use taxpayers' funds, employees and resources for political campaign purposes. Corbett said during this phase of the investigation, millions of e-mails, faxes, contracts, letters, memos and other documents were acquired and thousands of pages of testimony have been presented to the grand jury. Additionally, hundreds of interviews were conducted. Evidence was recovered from various locations in the United States. Agents and attorneys traveled to New Orleans and Washington, D.C. as part of their efforts to reconstruct the extensive amounts of pertinent evidence that was reportedly missing from the House Republican Caucus.

Obstruction of the Investigation Corbett said the review and analysis of this huge volume of material, in a criminal investigation of this magnitude, was an extremely time consuming but necessary process. He noted that the criminal obstruction by some in the House Republican Caucus, as well as a determined effort by some in the House Republican Caucus not to cooperate with the investigation, played a large part in the length of the investigation. Corbett said his office, as well as the grand jury, experienced a series of deliberate acts by House Republican members and employees to obstruct and hinder the investigation. As a result of their impediment to the investigation, significant amounts of time and resources had to be spent in litigation, investigating the absence of certain evidence and testing the accuracy of information provided in response to the grand jury process. Corbett said that these efforts to obstruct the investigation have resulted in significant delays in the grand jury's efforts to define potential crimes, identify those who committed the crimes and to protect those who are innocent of criminal wrongdoing. Corbett said that while some charges of obstruction of justice have been filed today, an obstruction of justice investigation within the House Republican Caucus continues. Habay Precedent As mentioned in the prior phase of the investigation, Corbett said, the investigation, prosecution, conviction and prison sentence of former Republican Representative Jeff Habay in 2004 and 2005 by the Attorney General's Office for using his legislative staff for campaign and fundraising purposes should have put legislative leaders and their staffs on notice that the Attorney General's Office and the courts take a stern view of such illegal activity. Corbett said the grand jury used the guidance of the Pennsylvania Superior Court in its Habay decision, when the Court stated that an elected representative is "not allowed to direct state paid employees under his authority to conduct campaign and or fundraising related work, during state paid time, for his personal benefit." The court said such actions secure "a private monetary advantage" for an elected representative because, "by having state employees work for him on his campaign and or fundraising tasks while they

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were being paid by the state, he obtained the benefit of free campaign work funded by the taxpayers."

John Perzel

Representative John Perzel The grand jury found that John Perzel was the architect behind a sophisticated criminal strategy that ultimately spent more than $10 million of taxpayers' money purely for campaign work. Once the foundation of Perzel's illegal scheme was in place, the grand jury found Perzel went to great lengths to maintain control and expand his power through illegal means. The grand jury heard testimony on John Perzel's rise to power and his plan to maintain and expand his power.

Brett Feese

John Perzel was elected to the House of Representatives by the voters from Northeast Philadelphia in 1978, he was elected by the Republican House members as Chairman of the House Republican Caucus in 1990, and then House Majority Leader in 1994 when the Republicans won the majority in the House of Representatives. Perzel served as Majority Leader until 2003, when he was elected Speaker of the House by the members upon the death of Representative Matthew Ryan. Perzel remained Speaker until the Democratic Caucus regained the majority status of the House of Representatives in 2006.

Brian Preski

The grand jury found that Perzel was aggressive in the acquisition and retention of power. He demanded obedience and loyalty and punished those, whether they were elected officials or employees, who challenged his power.

Paul Towhey

Contrary to prior practices as speaker, Perzel retained a virtually unprecedented degree of power over the resources of the House Republican Caucus, including funding for various caucus departments such as Research, District Operations, Printing and Information and Technology. Republican House members and employees who were favored by Perzel, such as former Representative Brett Feese, were rewarded with prominent positions in the Republican Caucus. Brian Preski, who served as Perzel's Chief of Staff from 2000 to 2007, was arguably the most powerful person in caucus short of Perzel himself.

Perzel's 2000 Election and the Rise of Technology The grand jury found that Perzel's 2000 election campaign became a Samuel "Buzz" defining moment and the impetus for much of the criminal activity that the grand jury investigated. On election eve in 2000, after the Stokes initial vote count, Perzel was losing his re-election in his Northeast

Philadelphia legislative district. After the absentee ballots were counted, he won by fewer than 100 votes. The grand jury found that Perzel vowed to never experience another close electoral challenge and instilled that mindset in his staff and employees of the Republican Caucus. Perzel put everyone on notice that everything possible would be done to prevent another close election. The grand jury found that after the 2000 election, Perzel, who had always been interested in the use of technology in campaigns, made technology a priority and forcefully related his mantra to his campaign staff, his legislative staff and other key employees of the caucus. Perzel traveled to many different technology conventions and shows around the nation as part of his quest for ideas and equipment to realize his ambitions. He also attended campaign seminars and returned to the caucus with ideas. Corbett said that through the use of a small, but loyal and close-knit group, Perzel embarked on his plan to use technology to gain a competitive advantage in campaigns, for himself and other candidates throughout the state in order to maintain and increase his power. The grand jury found that as time went by, campaign work became so pervasive that it was institutionalized. The conduct of campaign work through the Republican Information Technology (RIT) and public resources became so commonplace that such efforts were largely treated as normal assignments by the staff. Virtually every employee of RIT became aware of Perzel's interest and direct involvement in the acquisition, development and use of technology for campaign purposes. Perzel's BlueCard Program The grand jury found that after Perzel's close election in 2000, he initiated the creation of a program that would maintain accurate data about the individuals in each household in his district. A data card would be filled out for every individual in a household and would contain important information about each individual including birthdates, phone numbers, e-mail addresses, who they planned on voting for and whether they would like a yard sign for the candidate. The purpose was to determine whether an individual in a household was for Perzel, against Perzel, undecided or refused to talk. The information was contained on blue cards and became known as the "BlueCard" system. The BlueCard program was a two piece system; the first piece included sending campaign employees to every door in Perzel's district to fill out the information on the BlueCard, while the second part was the creation of a database. Perzel's idea was not simply to keep the BlueCards in a file drawer for manual reference during campaigns, but to align all the information on the cards with technology to make it more easily accessible and deployable for campaign purposes.

Perzel put Samual "Buzz" Stokes, his brother-in-law and campaign manager, in charge of the BlueCard program. The grand jury found that despite the control of the BlueCard program by the campaign, little or no Perzel campaign funds or resources ended up being used in the creation and development of the BlueCard program. The BlueCard effort was achieved at the expense of the Pennsylvania taxpayers. The grand jury found that the RIT staff spent countless hours working on programs to make the BlueCard system more efficient. The grand jury found that Perzel and his campaign personnel became frustrated that the improvements the RIT staff were making did not meet their standards. To help solve this problem Perzel hired his wife's nephew, Eric Ruth, to be the Deputy Director of RIT. Ruth spent most of his time ensuring that Perzel's BlueCard program took priority over everything else the staff did. The grand jury found that in January of 2002, despite the efforts of RIT, the responsibility of the BlueCard program was shifted to a private vendor, GCR & Associates in New Orleans, Louisiana. The grand jury found that Perzel abhorred chance and uncertainty and, as a result, aggressively sought to build redundancy and safety nets into projects he viewed as essential to his success. The grand jury found that Perzel's campaign staff wielded a tremendous amount of power and authority within the Capitol and that their requests took priority even over Republican Representatives and their staffs. In 2003, the grand jury found that another vendor, Aristotle International Inc. from Washington DC, had been retained by the caucus and was heavily involved in improving and modifying the BlueCard program at taxpayers' expense. Aristotle's work modernized the program and made it faster and more user friendly. The grand jury found that Aristotle spent more than $80,000 on the BlueCard program. The grand jury found that with the success of the BlueCard program in his own district in 2002, Perzel directed the RIT staff to create the BlueCard system for numerous other House districts in the 2004 election cycle. It was also created for a state senate district and congressional district. The grand jury found that this was part of Perzel's effort to expand his campaign influence all across the state. In 2005, the BlueCard program was used in a special election in the 131st legislative district. Additionally in 2005, Perzel established the BlueCard system citywide in Philadelphia. Telstar/Election Day Complete As part of his effort to ensure his re-election, the grand jury found that Perzel directed the development of a sophisticated computer system to ensure that his supporters went to the polls on election day.

The traditional way in which candidates accomplished this was having the campaign check off the names of voters at the polling places as they came in to vote and then taking the list back to campaign headquarters. They would then call or drive to the homes of the people that did not vote. Perzel wanted to use technology to make this system much more efficient and employed the staff of the RIT help to accomplish this. Perzel's idea was to use handheld computers which had each of the registered voters in the precinct or division in Philadelphia loaded onto it. The campaign workers at the polling places would simply click a name on the handheld computer and have that information electronically transmitted to a common database. Perzel believed that this was a way that he could maximize limited resources on Election Day. The original handheld computer idea was called Telstar, however the grand jury found that as the program became much bigger, more complicated and interconnected to many other technological endeavors, over time it became known as Election Day Complete. The key to making this program work was the purchase of handheld computers, which were completely paid for by the Republican Caucus. The first-full scale deployment of the Telstar/Election Day Complete system took place in the April 2002 special election in Monroe County. Telstar was viewed as largely successful in this election. Anthony Painter, who was the director of the RIT, testified before the grand jury that after elections in which the Telstar/Election Day Complete system was used, the RIT staff made improvements to the system for Perzel's re-election campaign. As the system was further refined and improved, Telstar/Election Day Complete was used in the 2002 general election in Perzel's district as well as in the 148th and 153rd legislative districts. The grand jury found that Perzel shared the technology with the House Republican Campaign Committee (HRCC), which is the outside campaign arm of the Republican Caucus. John Hanley, the Executive Director of the HRCC, testified before the grand jury that the system became a part of their election day activities and it was used extensively from 2002 through 2006. Hanley also stated that Perzel was very protective of the system, but also wanted the credit for helping candidates by allowing them use Election Day Complete. In addition to handheld computers, the system also required high-quality servers and other equipment such as modems, laptop computers and stand-alone printers, all paid for by the taxpayers. Additionally, all of the data was put onto the handheld and other computers by the RIT staff. Prior to its implementation on election day, the RIT staffers would physically transfer the equipment from the Capitol and set it up at the candidates campaign headquarters.

However, the first thing the RIT staff would do is remove all property tags identifying the equipment as the property of the Republican Caucus. As the system evolved, Perzel insisted that the vendor GCR work on improving the system and eventually Aristotle also worked on the program, all at taxpayers' expense. Ironically, the grand jury found that the Telstar/Election Day Complete system was used in the April 2006 special election held to replace former Representative Jeff Habay, who was leaving office because he was arrested and convicted by the Attorney General's Office for criminal use of public resources for campaign purposes. One of the RIT employees testified before the grand jury "how truly 'weird' it was to prepare to use all of these public resources to fill the seat of a guy who just went to jail for illegal campaign activities." Enterprise Database The grand jury heard testimony from campaign experts that stated that next to money, information about voters is fundamental to a campaign's success. Accurate and accessible voter information enables campaigns to effectively convey their messages through political mailings, political phone calls, door to door efforts and election day activities. Perzel and his co-conspirators entered into a $4 million contract with GCR specifically designed to fulfill the dual purpose of storing information useful for elected Republican representatives as part of their constituents' service programs and storing information about Pennsylvania voters to fuel campaigns. The data included maps of voting districts, results of all major Pennsylvania elections since 1992, a statewide voter information file of all registered voters, their locations and past voting histories, a profile of all voting precincts in Pennsylvania and voting patterns by the precincts and political affiliations. GCR named the project the Enterprise Database. The caucus provided GCR with huge amounts of data, with well over seven and half million records at a time being sent by the RIT staffers to start the data warehouses. The grand jury found that Perzel campaign workers Stokes and McClintock were very interested in being able to access the Enterprise Database for Perzel's BlueCard system. The grand jury found that the primary user of the Enterprise Database was the House Republican Campaign Committee (HRCC). As part of his fixation for redundancy, the grand jury found that Perzel employed Aristotle to produce a separate and superior version of Enterprise Database. Aristotle called their database ODS and promised they would develop it faster and make it larger and more efficient than the GCR's Enterprise Database.

The Edge The grand jury found that one of the primary campaign programs that Perzel directed GCR to produce for the caucus was called "The Edge," because it was designed to give Republicans the edge in elections. The Edge was fundamentally designed as a web-based tool to "mine" or "model" the Pennsylvania voter data to give it functionality. A user could access the voter database and determine political party, sex, jurisdiction, religion, etc. The Edge also contained data about favorable voters, e-mail addresses and voter preferences. The grand jury reviewed numerous e-mails and other documents that clearly demonstrated that The Edge was created and used solely for campaign purposes. The Edge was frequently used by the HRCC and was recognized as one of their primary campaign tools. Neither the HRCC, nor Perzel's campaign ever paid for any of The Edge, which was entirely paid for by taxpayers. Candidate Connect The grand jury found that one of the largest and most successful of the campaign programs produced by GCR for the caucus was "Candidate Connect," which became a highly sophisticated computer program designed to guide, instruct and assist Republican candidates from start to finish on their campaigns. Candidate Connect was the idea of Feese staffer Al Bowman, who retained oversight and controlled the program throughout its existence. The grand jury found that Candidate Connect became one of the fundamental campaign tools for the HRCC. The HRCC worked in 40 districts, while assisting many others through the assistance of Candidate Connect. The development and maintenance of the Candidate Connect software, which had no constituent purpose, was used in campaigns from 2004 through 2006 and cost the taxpayers $1.4 million. The program was deemed a success because it achieved its primary goal of providing valuable assistance to individual campaigns in a cost saving manner to the HRCC. Requests for access to Candidate Connect or assistance in operating Candidate Connect all came through Al Bowman and Jill Seaman. GCR and Aristotle The grand jury found that both GCR and Aristotle produced constituent service programs for use by the Republican Caucus members and their staffs. GCR's program was called RepNet, which was later replaced by Aristotle's CS-4 program. The grand jury found that the caucus paid GCR $9,286,980 from 2001 through 2007, approximately $4.5 million of which was for work on campaign programs such as

BlueCard, TelStar/Election Day Complete, Enterprise Database, The Edge, Candidate Connect and Contribution Tracker. Aristotle received $6.2 million from the caucus, of which the majority was for their work on campaign programs such as BlueCard, ODS, and DataCon. Label and Lists, Constituents Direct and Weiss Micromarketing The grand jury found that the caucus spent millions of dollars purchasing voter data from private vendors to fuel the campaign programs such as the Enterprise Database, The Edge and Candidate Connect. The three primary vendors were Constituents Direct, Weiss Micromarketing and Labels and Lists. Constituents Direct primarily obtained e-mail addresses of registered voters for the caucus and developed a web-based system to distribute the e-mails. From 2002 to 2007 they were paid $3,756,000. Weiss Micromarketing Group is owned by Michael Weiss, a marketing and demographics expert. Through detailed analysis of voter data, Weiss developed predictive models for elections in legislative districts, including Perzel's, and developed plans on how the segmentation of voter data could help with fundraising, campaign advertising and get out the vote efforts. Weiss was paid approximately $400,000. The caucus paid Labels and Lists, a leading national vendor of publicly accessible information about individuals, $500,000 for voter data purchases. Republican Information Technology Staff Costs The grand jury heard that virtually every member of the RIT between 2000 and 2007 provided direct evidence of the misuse of public resources. Many of the workers testified that they spent between 40 to 70 percent of their time dedicated to campaign efforts. William Tomaselli, who was a close aide to Perzel, testified before the grand jury that he had been deeply involved in many of the campaign activities in the RIT office. Tomaselli stated that in 2007 he conducted an extensive study of the historical work and salaries of caucus employees and that from 2001 to 2007, RIT staff members spent approximately $800,000 working on campaign projects. Perzel's Dirty Tricks Against Republicans The grand jury found that Perzel punished a group of Republican House members who refused to adequately conform to his directives on how they should vote by directing untraceable "robo" or automated calls against them in their districts. The calls were scripted in an extremely critical and damaging way against a representative in question and would often allow a constituent to directly connect to the representative's office to complain about the alleged misconduct portrayed in the call.

The grand jury found that Perzel used GCR to carry out the calls and they usually obtained a third-party phone vendor to make the calls. GCR charged the caucus for the calls, which cost approximately $3,200 each time they were implemented. Perzel directed robo calls against his own members about a dozen times. Perzel's Ghost Employee The grand jury found that after Perzel's narrow victory in the 2000 election, he vowed to keep a campaign office in operation year round. Perzel put his brother-in law, Samuel "Buzz" Stokes, in charge of the office and placed Don McClintock as the campaign office manager. Republican Information Technology staffers, who are employed by the taxpayers to work only on the computer and technical needs of the Republican Caucus, treated Perzel's campaign office as their top priority. The RIT staff installed, maintained, upgraded and supported all of Perzel's campaign computers and computer systems. The RIT staff took their direction directly from Stokes and McClintock. In December 2000, Perzel put Stokes on the caucus payroll, although all of his time was spent on Perzel's campaign. Stokes' position as a caucus employee was hidden from nearly all of Perzel's Capitol and district staff. The grand jury found that even Perzel's district office manager, who would have been Stokes' supervisor, had no idea that Stokes was a state employee. A specific review by the grand jury of thousands of e-mails and documents of Stokes' work product from 2000 through 2007 found that Stokes' time was spent on campaign activities and little to no evidence was uncovered that Stokes performed any legislative work. Over a six year period, from 2000 through 2006, Stokes was paid a total of $196,808 by the taxpayers for doing campaign work for Perzel. A grand jury review of Stokes' personnel file indicates that Preski twice recommended raises for Stokes. Perzel Fundraising Operation The grand jury found that Perzel had many staffers perform campaign fundraising duties during normal working hours and used government computers. A key staff member in Perzel's district office stated that, "fundraising was made part of my job."

The grand jury found that many of Perzel's staff members spent hundreds of hours of their taxpayer paid time preparing fundraising mailings for Perzel's re-election efforts. Perzel sent solicitation letters to his constituents, which he dubbed "the little people," who made contributions of small amounts, often as low as $5 or $10. In addition to his own staff, Perzel also tasked the RIT staff to assist in his fundraising efforts. The grand jury found that one RIT computer programmer was directed to develop a fundraising website and database which ultimately became known as the Speaker's Ball management tool. The programmer spent three months on the project. The Speaker's Ball, a charity fundraising event initiated by Perzel, was held in conjunction with a fundraiser for Perzel's re-election efforts. Additionally, the grand jury found that Perzel took advantage of the taxpayer funded resources of GCR and Aristotle for his own campaign fundraising purposes. In July of 2005, Aristotle was developing a comprehensive, full-service fundraising program called 360, which would manage campaign financing. It was paid in part at the expense of Pennsylvania taxpayers. While the 360 program never became fully operational, Perzel's taxpayer-paid staff made extensive use of the fundraising program. While Aristotle was working on the 360 program, Perzel staffers also directed GCR to develop a web-based fundraising tool. GCR programmers spent three months, again at the expense of Pennsylvania taxpayers, developing a program called Contribution Tracker that would "mine" data from campaign finance reports, so that the names of individuals who contributed large sums of money could be easily identified and put into a database. District Operations The House Republican Caucus has employees located throughout the state that were hired to assist elected Republican representatives in their district offices and aid them with a variety of tasks, including constituent outreach programs and helping newly elected members establish practice and procedures in their district offices. These employees are assigned to a department called District Operations. The grand jury found that from 2001 through 2006, and to a lesser extent after 2006, District Operations was a subsidiary of the House Republican Campaign Committee, which was under the direction of Perzel and Feese. The grand jury found that most of the District Operations employees hired during this time were hired because of their campaign and or fundraising skills. For the majority of the new hires, who worked out of their homes, it was clearly understood that as part of their legislative job that they would work on campaigns.

The District Operations employees, under the direction of Feese, recruited candidates for legislative seats, assisted in getting Republican candidates on the ballot, getting opponents off the ballot through nominating petition challenges and conducted opposition research, all at the taxpayers' expense. Greystone and SKP The grand jury found that Perzel's overarching plan in developing data-driven, technologically proficient campaigning programs at the taxpayers' expense was motivated not only by his desire to obtain and keep political power, but also to personally enrich himself. Perzel and Preski formed a business with their wives Sheryl Perzel and Kelly Preski, called Greystone, which later became SKP. The business plan was to market and sell the campaign programs, which the RIT employees and GCR had developed, to candidates around the country. The goal, in the words of Preski, was "to make us millionaires." Although there appears to be little evidence that their business venture was successful, it demonstrates that Perzel, Preski, and their wives, attempted to personally profit from the programs and software that was developed and paid for the by taxpayers of Pennsylvania. Obstruction of Justice: Perzel's Missing Boxes As was previously stated, Corbett said that agents and prosecutors from the Attorney General's Office encountered numerous impediments and obstacles created by the defendants and others during the course of this investigation with respect to records and information. One such incident, which can be revealed at this time, occurred in late February 2008. Corbett said that on Feb. 26, 2008, the grand jury served a series of subpoenas upon the House Republican Caucus seeking an array of information related to this investigation. The caucus was ordered to produce "any and all evidence of campaign work" and listed a number of employees who may have performed the campaign work. Two days later, Corbett said, an employee of the Pennsylvania Legislature came to the Attorney General's Office and stated that boxes containing campaign materials were being removed from room B-02, a basement storage room assigned to Perzel in the Capitol Complex. After further investigation, Corbett said a grand jury subpoena was issued the next day, February 29, ordering the immediate production of any and all documents or materials removed from the storage room on February 26 or during the prior 60 days. It also ordered the disclosure of the location of any and all materials removed from the room.

Corbett said on evening of February 29, an agent and a prosecutor from the Attorney General's Public Corruption Unit went to the Capitol Complex and inspected numerous boxes that reportedly had been removed from the storage room. They were escorted by Capitol security officers, attorneys for the Republican Caucus and Perzel's staff members John Zimmerman and Paul Towhey. When questioned by the Attorney General's Office that evening, Zimmerman and Towhey, denied any knowledge of boxes containing campaign material being removed from the storage room. Corbett said a subsequent investigation by agents found that the boxes containing evidence of campaign work performed by public employees had in fact been removed from the storage room on and before February 26. Corbett said that testimony of caucus messengers, which is corroborated by Capitol security video footage, confirm that two cart loads of boxes were transferred from the storage room to Perzel's office suite located in the Main Capitol Building. The grand jury found that prior to February 29, Perzel's secretary had twice gone to the storage room and examined the materials and told Towhey, who was then Perzel's chief of staff, of the existence of campaign materials. Towhey ordered her to have the materials transferred to Perzel's office suite and then to move the campaign materials and evidence of campaign work out of Perzel's suite to the House Republican Campaign Committee offices, which are located across the street from the Capitol Complex. On February 27, the boxes were transferred by messenger to the HRCC office, which was confirmed by testimony of the messenger who delivered the boxes, messenger logs and testimony of the Executive Secretary of the HRCC, who received the boxes. The HRCC Executive Secretary also testified that a few days after the boxes arrived, she received a call from Feese, who asked her if boxes from Perzel's office had been delivered a few days before. The grand jury reviewed Towhey's phone records for the week of February 25 for the times pertinent to the hiding of campaign materials, including the time of the service of the subpoena and the inspection by the Attorney General's Office. Towhey's phone records indicate that during this time he was in frequent telephone contact with Perzel, Feese, Zimmerman and Perzel's secretary. The grand jury found that Perzel, Feese, Towhey and Zimmerman engaged in obstructing the investigation and hindering prosecution by the removal of evidence, the hiding of evidence and/or the failure to disclose the existence and location of evidence. Obstruction of Justice: Feese's Fraudulent Notes Feese, who had been an elected member of the House of Representatives from Lycoming County, did not run for re-election in 2006 and was hired by the caucus in January 2007

as chief counsel to the caucus. Feese's yearly salary as chief counsel began at $155,000 and was increased to $196,999 in November 2008. Feese, as was previously stated, was a confidant of Perzel and had been one of the most powerful members of the caucus, having previously been elected by members of the caucus as Minority Whip, Appropriations Chairman and Chairman of the House Republican Campaign Committee. As chief counsel to the caucus, Feese was intimately involved in the collection and review of evidence sought by the grand jury regarding its investigation of the Republican Caucus. Corbett said that not only was Feese aware of the materials being sought by the grand jury, he was also well aware of the growing frustration of investigators as a result of missing or incomplete information. This frustration was clearly demonstrated at a series of contempt hearings before the Supervising Judge of the grand jury from October 2008 to December 2008, which was held for the purpose of forcing the caucus into compliance with subpoenas and court orders. In December 2008, agents were provided with copies of several handwritten notes by Feese and his assistant, Jill Seaman, directly pertinent to the investigation. The notes purport to have been taken at meetings held by Feese in 2007 and 2008 with various employees of the caucus and some vendors. The notes supposedly represent some kind of investigation conducted by Feese within the caucus beginning in February of 2007 into the illegal use of public resources for campaign purposes. The notes specifically discuss the GCR programs such as the Enterprise Database, The Edge, Candidate Connect as well as contracts with Aristotle, Labels and Lists, Constituents Direct and others. The notes take great pains to state that Feese had no idea that these illegal activities had been occurring and stand in stark contrast with evidence and testimony before the grand jury. The delivery of Feese's handwritten notes led to another extensive and time consuming avenue of the investigation. The grand jury ordered that Feese turn over a complete set of the original handwritten notes to agents and in April 2009, a set of original handwritten notes was turned over to agents. The grand jury found that handwritten notes produced by Feese and Seaman were fabricated for the intentional purpose of obstructing and hindering the investigation. The grand jury also found that the notes are demonstratively false and intentionally sought to

mislead investigators into believing that Feese had been unaware and uninvolved in the use of public resources for campaign purposes. Corbett said the defendants will be prosecuted in Dauphin County by Public Corruption Unit prosecutors Frank G. Fina, Patrick Blessington and Kenneth K. Brown II. They are scheduled to surrender tomorrow and be arraigned before Harrisburg Magisterial District Judge William C. Wenner. Below is a list of the defendants and the charges against them: John Perzel, 59, 7810 Brous Ave., Philadelphia, is charged with: •











Conflict of Interest, 65 Pa. C.S.A.§1103 (F3), 13 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) Perzel Campaign and District Offices; 8) Ghost Employees; 9) Greystone/SKP; 10)Fundraising; 11) District Operations; 12)Trips; 13) Miscellaneous Use of Public Resources; Theft By Unlawful Taking Or Disposition, 18 Pa. C.S.A.§ 3921(F3), 13 Counts (1 Count as to each of the following): 1) Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) Perzel Campaign and District Offices; 8) Ghost Employees; 9) Greystone/SKP; 10)Fundraising; 11) District Operations; 12)Trips; 13) Miscellaneous Use of Public Resources; Theft Of Services, 18 Pa. C.S.A. §3926 (F3), 13 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) Perzel Campaign and District Offices; 8) Ghost Employees; 9) Greystone/SKP; 10)Fundraising; 11) District Operations; 12)Trips; 13) Miscellaneous Use of Public Resources; Theft By Deception, 18 Pa. C.S.A. §3922 (a)(1), (F3), 13 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) Perzel Campaign and District Offices; 8) Ghost Employees; 9) Greystone/SKP; 10)Fundraising; 11) District Operations; 12)Trips; 13) Miscellaneous Use of Public Resources; Theft By Failure to Make Required Disposition of Funds Received, 18 Pa. C.S.A. §3927 (F3), 13 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) Perzel Campaign and District Offices; 8) Ghost Employees; 9) Greystone/SKP; 10)Fundraising; 11) District Operations; 12)Trips; 13) Miscellaneous Use of Public Resources; Hindering Apprehension or Prosecution, 18 Pa.C.S.A.§5105 (F3), 1 Count, as to Missing Boxes.

• •



Obstructing Administration of Law or Other Governmental Function (M2), 1 Count, as to Missing Boxes. Criminal Conspiracy, 18 Pa.C.S.A.§903 (F3), 14 Counts (One count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) Perzel Campaign and District Offices; 8) Ghost Employees; 9) Greystone/SKP; 10)Fundraising; 11) District Operations; 12)Trips; 13) Miscellaneous Use of Public Resources; 14) Hindering-Missing Boxes. Criminal Conspiracy, 18 Pa.C.S.A. §903 (M2), 1 Count as to Obstructing-Missing Boxes.

Brian Preski, 44, 9901 Player Dr., Philadelphia, is charged with: •











Conflict of Interest, 65 Pa. C.S.A.§1103 (F3), 12 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) Perzel Campaign and District Offices; 8) Ghost Employees; 9) Greystone/SKP; 10)Fundraising; 11) District Operations; 12)Trips. Theft By Unlawful Taking Or Disposition, 18 Pa. C.S.A.§ 3921(F3), 12 Counts (1 Count as to each of the following): 1) Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) Perzel Campaign and District Offices; 8) Ghost Employees; 9) Greystone/SKP; 10)Fundraising; 11) District Operations; 12)Trips. Theft Of Services, 18 Pa. C.S.A. §3926 (F3), 12 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) Perzel Campaign and District Offices; 8) Ghost Employees; 9) Greystone/SKP; 10)Fundraising; 11) District Operations; 12)Trips. Theft By Deception, 18 Pa. C.S.A. §3922 (a)(1), (F3), 12 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) Perzel Campaign and District Offices; 8) Ghost Employees; 9) Greystone/SKP; 10)Fundraising; 11) District Operations; 12)Trips. Theft By Failure to Make Required Disposition of Funds Received, 18 Pa. C.S.A. §3927 (F3), 12 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) Perzel Campaign and District Offices; 8) Ghost Employees; 9) Greystone/SKP; 10)Fundraising; 11) District Operations; 12)Trips. Criminal Conspiracy, 18 Pa.C.S.A.§903 (F3), 12 Counts (One count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3)

Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) Perzel Campaign and District Offices; 8) Ghost Employees; 9) Greystone/SKP; 10)Fundraising; 11) District Operations; 12)Trips. Brett Feese, 55, 6330 Dunwoody Road, Munch, is charged with: •









• • •



Conflict of Interest, 65 Pa. C.S.A.§1103 (F3), 9 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) District Operations; 8)Trips; 9) Miscellaneous Use of Public Resources. Theft By Unlawful Taking Or Disposition, 18 Pa. C.S.A.§ 3921(F3), 9 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) District Operations; 8)Trips; 9) Miscellaneous Use of Public Resources. Theft Of Services, 18 Pa. C.S.A. §3926 (F3), 9 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) District Operations; 8)Trips; 9) Miscellaneous Use of Public Resources. Theft By Deception, 18 Pa. C.S.A. §3922 (a)(1), (F3), 9 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) District Operations; 8)Trips; 9) Miscellaneous Use of Public Resources. Theft By Failure to Make Required Disposition of Funds Received, 18 Pa. C.S.A. §3927 (F3), 9 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) District Operations; 8)Trips; 9) Miscellaneous Use of Public Resources. Hindering Apprehension or Prosecution, 18 Pa.C.S.A.§5105 (F3), 2 Counts, as to: 1) Missing Boxes; 2) Handwritten Notes. Obstructing Administration of Law or Other Governmental Function (M2), 2 Counts, as to: 1) Missing Boxes; 2) Handwritten Notes. Criminal Conspiracy, 18 Pa.C.S.A.§903 (F3), 11 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) District Operations; 8)Trips; 9) Miscellaneous Use of Public Resources; 10) Hindering-Missing Boxes; 11) Hindering-Handwritten Notes. Criminal Conspiracy, 18 Pa.C.S.A.§903(M2), 2 Counts as to: 1) Missing Boxes; 2) Handwritten Notes.

Elmer Bowman, 34, 977 David Dr., Red Lion, is charged with:













Conflict of Interest, 65 Pa. C.S.A.§1103 (F3), 8 Counts (1 Count as to each of the following); 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) District Operations; 8) Miscellaneous Use of Public Resources Theft By Unlawful Taking Or Disposition, 18 Pa. C.S.A.§ 3921(F3), 8 Counts (1 Count as to each of the following); 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) District Operations; 8) Miscellaneous Use of Public Resources. Theft Of Services, 18 Pa. C.S.A. §3926 (F3), 8 Counts (1 Count as to each of the following); 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) District Operations; 8) Miscellaneous Use of Public Resources. Theft By Deception, 18 Pa. C.S.A. §3922 (a)(1), (F3), 8 Counts (1 Count as to each of the following); 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) District Operations; 8) Miscellaneous Use of Public Resources. Theft By Failure to Make Required Disposition of Funds Received, 18 Pa. C.S.A. §3927 (F3), 8 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) District Operations; 8) Miscellaneous Use of Public Resources. Criminal Conspiracy, 18 Pa.C.S.A.§903 (F3), 8 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Weiss Micromarketing Group; 7) District Operations; 8) Miscellaneous Use of Public Resources.

Samuel Stokes, 66, 2980 Welsh Road, Philadelphia, is charged with: •

• •



Conflict of Interest, 65 Pa. C.S.A.§1103 (F3), 7 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Perzel Campaign and District Offices; 6) Ghost Employees; 7) Trips. Theft By Unlawful Taking or Disposition, 18 Pa. C.S.A. § 3921 (F3), 7 counts. Theft Of Services, 18 Pa. C.S.A. §3926 (F3), 7 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Perzel Campaign and District Offices; 6) Ghost Employees; 7) Trips. Theft By Deception, 18 Pa. C.S.A. §3922 (a)(1), (F3), 7 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Perzel Campaign and District Offices; 6) Ghost Employees; 7) Trips.





Theft By Failure to Make Required Disposition of Funds Received, 18 Pa. C.S.A. §3927 (F3), 7 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Perzel Campaign and District Offices; 6) Ghost Employees; 7) Trips. Criminal Conspiracy, 18 Pa.C.S.A.§903 (F3), 7 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Perzel Campaign and District Offices; 6) Ghost Employees; 7) Trips.

Jill Seaman, 57, 1401 Heritage Lane, Dauphin, is charged with: •

• •





• • •



Conflict of Interest, 65 Pa. C.S.A.§1103 (F3), 7 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Weiss Micromarketing Group; 6) District Operations; 7) Miscellaneous Use of Public Resources. Theft By Unlawful Taking or Disposition, 18 Pa. C.S.A. § 3921 (F3), 7 counts. Theft Of Services, 18 Pa. C.S.A. §3926 (F3), 7 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Weiss Micromarketing Group; 6) District Operations; 7) Miscellaneous Use of Public Resources. Theft By Deception, 18 Pa. C.S.A. §3922 (a)(1), (F3), 7 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Weiss Micromarketing Group; 6) District Operations; 7) Miscellaneous Use of Public Resources. Theft By Failure to Make Required Disposition of Funds Received, 18 Pa. C.S.A. §3927 (F3), 7 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Weiss Micromarketing Group; 6) District Operations; 7) Miscellaneous Use of Public Resources. Hindering Apprehension or Prosecution, 18 Pa.C.S.A.§5105 (F3), 1 Count, as to Handwritten Notes. Obstructing Administration of Law or Other Governmental Function (M2), 1 Count, as to Handwritten Notes. Criminal Conspiracy, 18 Pa.C.S.A.§903 (F3), 8 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Weiss Micromarketing Group; 6) District Operations; 7) Miscellaneous Use of Public Resources; 8) Hindering-Handwritten Notes. Criminal Conspiracy, 18 Pa.C.S.A.§903(M2), 1 Count, as to Handwritten Notes.

Paul Towhey, 38, 202 Amberly Lane, Blue Bell, is charged with:



• •





• • •



Conflict of Interest, 65 Pa. C.S.A.§1103 (F3), 4 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Perzel Campaign and District Offices; 4) Fundraising. Theft By Unlawful Taking or Disposition, 18 Pa. C.S.A. § 3921 (F3), 4 counts. Theft Of Services, 18 Pa. C.S.A. §3926 (F3), 4 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Perzel Campaign and District Offices; 4) Fundraising. Theft By Deception, 18 Pa. C.S.A. §3922 (a)(1), (F3), 4 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Perzel Campaign and District Offices; 4) Fundraising. Theft By Failure to Make Required Disposition of Funds Received, 18 Pa. C.S.A. §3927 (F3), 4 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Perzel Campaign and District Offices; 4) Fundraising. Hindering Apprehension or Prosecution, 18 Pa.C.S.A.§5105 (F3), 1 Count, as to Missing Boxes. Obstructing Administration of Law or Other Governmental Function (M2), 1 Count, as to Missing Boxes. Criminal Conspiracy, 18 Pa.C.S.A.§903 (F3), 5 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Perzel Campaign and District Offices; 4) Fundraising; 5) Hindering-Missing Boxes. Criminal Conspiracy, 18 Pa.C.S.A.§903 (M2), 1 Count as to Obstructing-Missing Boxes.

Don McClintock, 41, 6 Sandra Road, Voorhees, NJ, is charged with: •

• •







Conflict of Interest, 65 Pa. C.S.A.§1103 (F3), 4 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International, Inc. 4) Perzel Campaign and District Offices. Theft By Unlawful Taking or Disposition, 18 Pa. C.S.A. § 3921 (F3), 4 counts. Theft Of Services, 18 Pa. C.S.A. §3926 (F3), 4 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International, Inc. 4) Perzel Campaign and District Offices. Theft By Deception, 18 Pa. C.S.A. §3922 (a)(1), (F3), 4 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International, Inc. 4) Perzel Campaign and District Offices. Theft By Failure to Make Required Disposition of Funds Received, 18 Pa. C.S.A. §3927 (F3), 4 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International, Inc. 4) Perzel Campaign and District Offices. Criminal Conspiracy, 18 Pa.C.S.A.§903 (F3), 4 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International, Inc. 4) Perzel Campaign and District Offices.

Eric Ruth, 34, 21636 Guadalajara, Boca Raton, FL, is charged with:













Conflict of Interest, 65 Pa. C.S.A.§1103 (F3), 8 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Perzel Campaign and District Offices; 7) Fundraising; 8) Trips. Theft By Unlawful Taking Or Disposition, 18 Pa. C.S.A.§ 3921(F3), 8 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Perzel Campaign and District Offices; 7) Fundraising; 8) Trips. Theft Of Services, 18 Pa. C.S.A. §3926 (F3), 8 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Perzel Campaign and District Offices; 7) Fundraising; 8) Trips. Theft By Deception, 18 Pa. C.S.A. §3922 (a)(1), (F3), 8 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Perzel Campaign and District Offices; 7) Fundraising; 8) Trips. Theft By Failure to Make Required Disposition of Funds Received, 18 Pa. C.S.A. §3927 (F3), 8 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Perzel Campaign and District Offices; 7) Fundraising; 8) Trips. Criminal Conspiracy, 18 Pa.C.S.A.§903 (F3), 8 Counts (1 Count as to each of the following): 1)Use of RIT staff and resources; 2) GCR and Associates, Inc.; 3) Aristotle International Inc.; 4) Labels and Lists, Inc.; 5) Constituents Direct, LLC; 6) Perzel Campaign and District Offices; 7) Fundraising; 8) Trips.

John Zimmerman, 61, 462 Roslaire Dr., Hummelstown, is charged with: • •

Hindering Apprehension or Prosecution, 18 Pa.C.S.A.§5105 (F3), 1 Count, as to Missing Boxes. Obstructing Administration of Law or Other Governmental Function (M2), 1 Count, as to Missing Boxes. (A person charged with a crime is presumed innocent until proven guilty.)

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