Docket No. 440

In the Matter of William J. Stanton

April 28, 1992

Disposition Agreement

This Disposition Agreement (Agreement) is entered into between
the State Ethics Commission (Commission) and William J. Stanton
(Stanton) pursuant to Section 5 of the Commission's Enforcement
Procedures. This Agreement constitutes a consented to final
Commission order enforceable in the Superior Court pursuant to G.L.
c. 268B, s. 4(j).

On March 16, 1987, the Commission initiated a preliminary
inquiry into possible violations of the conflict of interest law,
G.L. c. 268A, involving Stanton, the former manager of the
Speaker's business office at the House of Representatives. On May
25, 1988, Stanton and the Commission entered into a letter
agreement by which he agreed to enter into a disposition agreement
regarding his violations of G.L. c. 268A and/or 268B while he was
such business manager. Thereafter, at the request of the Department
of the Attorney General, the Commission deferred taking any further
civil action regarding Stanton's conduct pending that office's
criminal investigation of that conduct. In April, 1991, Stanton
plead guilty in the Superior Court to four counts of violating G.L.
c. 268A and one count of violating G.L. c. 266, s. 67A (submitting
false invoices). On September 11, 1991, the Commission formally
concluded its inquiry and found reasonable cause to believe that
Mr. Stanton violated G.L. c. 268A, s.s. 2 and 3.

The Commission and Stanton now agree to the following findings
of facts and conclusions of law:

1. Between January, 1985 and February, 1987, Stanton was the
manager of then Speaker George Keverian's State House business
office. As such, Stanton was a state employee within the meaning of
G.L. c. 268A, s. 1. His responsibilities as business manager
included the ordering of all furniture and supplies for the House.

2. Between January 1985 and April 1988, Gregory Delcore was
employed by the Speaker's office as the chief of staff.

3. Between February, 1985 and February, 1987, Tony Ciaramataro
(Ciaramataro) was employed by the Speaker's Office as the assistant
House photographer.

4. Between early 1985 and February, 1987, Ciaramataro ordered
and the House paid for approximately $50,000 in photographic
equipment and supplies from General Photographic Supply, Inc.
(General Photo), a Boston photographic supply vendor owned by
Milton Mishara (Mishara).

5. At some point in 1985 Delcore, Ciaramataro and Mishara
created a "substitution scheme" whereby Delcore and Ciaramataro
could substitute, and keep for personal use, any item they wanted
instead of the item appearing on a state purchase order. At some
later point, Stanton became a participant. As business manager,
Stanton approved each purchase order for equipment and/or supplies
the House purchased from General Photo. Ciaramataro signed General
Photo's invoices certifying that the goods had been delivered to
the state. In turn, Stanton, as business manager, approved the
invoices for payment. The state would subsequently pay for the item
in the amount indicated on the invoice, and this payment would
cover the items the participants in the scheme personally received
from General Photo.

6. Through this "substitution scheme" Mr. Stanton received a
number of consumer goods, including a widescreen Sony color
television set, the total value of which was approximately

7. Section 2 of G.L. c. 268A, in pertinent part, prohibits a
state employee from corruptly soliciting or accepting anything of
value for himself from another person in return for being
influenced to commit or aid in committing a fraud on the

8. The consumer goods referenced above were obviously of
value. Mr. Stanton accepted them in return for his committing or
aiding in committing a fraud on the commonwealth, i.e., the above
described "substitution scheme." Stanton aided the scheme by his
approving first the purchase order, and then the invoices for
payment. Stanton corruptly accepted these items because he knew
they were to him in exchange for his aiding the "substitution

Page 580

9. By corruptly accepting these consumer goods in exchange for
his being influenced to commit or aid in committing a fraud on the
commonwealth, Stanton violated s. 2.

10. According to Stanton, the Samuel Bluestein Company is a
furniture and office supply company located in Malden. Between
July, 1986 and February, 1987, it sold approximately $42,000 in
office furniture to the House. This furniture was ordered by
Stanton as the Speaker's business manager. In addition, he approved
the invoices for payment upon proof of delivery of the furniture.

11. According to Stanton, in the fall of 1986, the Samuel
Bluestein Company offered Stanton a Henry Miller leather chair and
ottoman (valued at approximately $3,500) as a gratuity in
appreciation for Stanton's purchases of furniture from the company.
Stanton accepted the offer.

12. Section 3 of G.L. c. 268A, prohibits a state employee,
except as otherwise provided by law for the proper discharge of
official duties, from soliciting or accepting any item of
substantial value for or because of any official act or act within
his official responsibility performed or to be performed by him.

13. The chair and ottoman were items of substantial value.
They were given to Stanton in appreciation for his having done
substantial business with the Samuel Bluestein Company and to
create goodwill in the hopes that he would continue to do business
with the Samuel Bluestein Company.

14. By accepting an item of substantial value (the chair and
ottoman) for himself for or because of the business he had or would
do with the Samuel Bluestein Company as a House vendor, Stanton
violated s. 3.

15. According to Stanton, in or about November or December,
1985, Stanton, along with the then Speaker's Office Chief of Staff,
Gregory Delcore, took two personal trips to Vermont, along with
certain family members and guests. While in Vermont, they and their
invitees, dined at local restaurants. On two occasions, Stanton, at
Delcore's direction, used his American Express card to pay for
dinners, where the cost of each dinner was approximately $300.
Delcore told Stanton he would take care of the costs of the meals

16. According to Stanton, in or about February, 1986, State
House lobbyist Joseph Grant approached Stanton in his State House
office and gave him an envelope containing $300 in cash. Grant
indicated that he was doing this at Delcore's direction. Stanton
reviewed his American Express records and realized that the $300
would not cover the costs for the dinners in question. Stanton then
told Delcore that the money he received was not enough to pay for
the meals. Subsequently, in or about March, 1986, Grant gave Mr.
Stanton another $300 cash payment in Stanton's office.

17. In his capacity as business manager, Stanton was in a
position to indirectly affect Grant's interests as a lobbyist.

18. Stanton accepted the $600 in cash knowing that Grant was
seeking to establish goodwill with Stanton and Delcore in their
official positions.

19. By accepting an item of substantial value ($600 cash) for
himself for or because of official acts he had or would perform
within his official responsibility, Stanton violated s. 3.

20. During all times relevant herein, Richard Sousa was the
State House carpenter.

21. As business manager, Stanton had some official
responsibilities for Mr. Sousa's job performance.

22. According to Stanton, in or about 1986, Stanton asked
Sousa to construct a cabinet and shelves for Stanton's personal
residence. Sousa did this. The value of the materials and labor was
in excess of $50. Stanton did not pay anything for the labor or

23. Stanton accepted the cabinet and shelves knowing that
Sousa was giving them to him in the hopes of generating goodwill in
Stanton's official capacity.

24. By accepting an item of substantial value (the cabinet and
shelves) for himself for or because of his official business
relationship with Sousa, Stanton violated s. 3.

25. In view of the foregoing violations of G.L. c. 268A, the
Commission has determined that the public interest would be served
by the disposition of this matter without further enforcement
proceedings on the basis of the following terms and conditions
agreed to by Stanton:

Page 581

1. that he pay to the Commission the amount of $3,500 (three
thousand five hundred dollars) as a civil penalty for his
violations; and

2. that he waive all rights to contest the findings of fact,
conclusions of law and terms and conditions contained in this
Agreement in any related administrative or judicial proceeding to
which the Commission is or may be a party.

Page 582