March 19, 2017

To the City of New Brunswick Ethics Board:

Please consider this AMENDED COMPLAINT of repeated violations of the Local Government
Ethics Law (LGEL) and the Citys Code of Ethics on the part of Andrea Eato-White.

I hereby swear and affirm that the following statements are true:

1. Andrea Eato-White has been an employee of the New Brunswick Housing Authority
(NBHA) continuously since January 18, 1995. She currently earns an annual salary in
excess of $83,000 for her work at the NBHA, and enjoys other perks such as the use of a
NBHA-owned vehicle, and taxpayer-funded travel to events outside New Jersey.
2. Ms. Eato-White was appointed to the position of member of the New Brunswick Parking
Authority (NBPA) Board of Commissioners on June 3, 2015, and has continuously served
in this capacity since that time.
3. As such, Ms. Eato-White was required to file a financial disclosure statement (FDS)
within 30 days of her appointment to the NBPA board, and annually thereafter.
4. According to the Local Government Ethics Law, Ms. Eato-White must disclose on these
statements all sources of income in excess of $2,000, and all sources of gifts,
reimbursements or prepaid expenses having an aggregate value exceeding $400 from
any single source, as well as all real property in the State of New Jersey in which an
interest was held during the prior year.
5. Ms. Eato-White failed to file any FDS during 2015, despite the requirement to do so.
6. Ms. Eato-White filed an inaccurate, deficient FDS on April 29, 2016 that did not identifying
her sources of income by name, as required by law. [SEE EXHIBIT A]
7. Instead, Ms. Eato-Whites FDS only listed sources of income as earned income or
unearned income, and did not list any gifts, reimbursements or prepaid expenses.
8. The FDS also inaccurately listed the municipality in which she owns property (She owns
real property in the City of New Brunswick, not the Borough of Middlesex).
9. Ms. Eato-White was questioned about her deficient 2016 FDS, specifically the cryptic
sources of income, at a November 30, 2016 public meeting where she remained silent,
and allowed the NBPAs general legal counsel to speak about the issue.
10. The NBPAs general counsel responded to concerns about Ms. Eato-Whites April 29,
2016 FDS at the November 30 meeting of the NBPA Board, making the following
statements about Ms. Eato-Whites failure to disclose the sources of her income:
a. Certainly by the next meeting, it will be handled however it needs to be handled
b. Youve found something thats not correct.... And by the next board
meeting--which is how this board works--it will be corrected.
11. However, at the December 21, 2016 NBPA meeting, the counsel changed his story, and
made the following statements regarding Ms. Eato-Whites failure to disclose her income:
a. The filing has not been made.
 b. I told you at the next meeting I would report to you and hope to have it resolved by
the next meeting if you want to be precise.
c. I had said that we hope to have it resolved for you for this meeting.
d. Theres a failure. Theres a failure on my part.
e. We acknowledge that you found this thing.
f. I thought I brought the correct paperwork with me today, because I knew I was
anticipating you having these questions, and again my fault, I didnt bring it.
12. On January 20, 2017, Ms. Eato-White filed an amended 2016 FDS that continues to
include false information about her real estate holdings. [SEE EXHIBIT B]
13. Ms. Eato White was questioned about her amended FDS on January 25, 2017. Again,
she remained silent and allowed others to speak about the issue.
14. The NBPAs general counsel made the following statements about Ms. Eato-Whites two
inaccurate financial disclosure statements:
a. Regarding her April 29, 2016 FDS: All sources of income were disclosed. What
was not disclosed was where it came from.
b. Regarding her January 20, 2017 FDS: Theres no conspiracy. If theres a
mistake, well correct that.
15. On March 8, 2017, Ms. Eato-White filed a second amended FDS that corrected the
the municipality where her home is located. [SEE EXHIBIT C]
16. In all three versions of her disclosure forms, Ms. Eato-White effectively certified
that she had received no gifts, reimbursements or prepaid expenses having an
aggregate value exceeding $400 from any single source.
17. However, Ms. Eato-White traveled to Huntsville, Alabama in July 2015, on an
excursion funded by her employer, the New Brunswick Housing Authority (NBHA).
18. As part of that trip, the NBHA paid $745.02 for Ms. Eato-Whites accommodations
at a Hilton Hotel. [SEE EXHIBIT D].
19. On July 13, 2015, Ms. Eato-White requested and was approved for a $600 check
from the NBHA to cover per diem expenses related to the trip. [SEE EXHIBIT E]
20. Under the NBHAs Personnel Policy, Section XVIII, employees authorized for
work-related travel may receive travel advances (i.e. prepaid expenses) of up
to $100 per day, but in order to keep the money (as a reimbursement), they are
required to submit relevant records, including but not limited an expense report:
Within thirty (30) days of the completion of the travel, all travelers shall submit
the completed NBHA Expense Sheet and provide all receipts for all reimbursable
expenses in excess of $25.00 dollars and shall refund to the Authority that part of
the advance which was not documented on the expense sheet. [SEE EXHIBIT F]
21. Expense records for this trip were among the public documents at issue in a case
brought before the Superior Court under the Open Public Records Act in 2016
(Kratovil v. New Brunswick Housing Authority, MID-L-001267-16). [SEE EXHIBIT G]
22. That case was settled in November 2016 in an agreement with NBHA counsel.
However, NBHA attorney Joseph Manfredi did not immediately sign the
agreement, which required NBHA to produce documents reflecting expenses for
Ms. Eato-Whites trip to Huntsville, Alabama within 10 days.
 23. On January 18, 2017, Mr. Manfredi finally provided a signed copy of the settlement
agreement, backdating it to the date of December 15. [SEE EXHIBIT H]
24. As of March 19, 2017, no further records, receipts, and/or expense reports have
been received from the NBHA regarding Ms. Eato-Whites trip to Huntsville.
25. Attempts to follow up with Mr. Manfredi and city officials about the existence or
nonexistence of additional records related to the Huntsville trip have been
unsuccessful.

As a result of these facts, it would be wise to use your subpoena power to require the
testimony and/or production of documents from the following individuals:
1. Andrea Eato-White
2. Leonard T. Bier, Esq.
3. John Clarke
4. Joseph Manfredi, Esq.

Please do not hesitate to contact me if I can be helpful. Thanks for your time and consideration.

Sincerely,

Charles Kratovil
New Brunswick, NJ
732-993-9697